ML041890098

Issuance of License Amendment No. 217 Regarding the Relocating of the Primary Coolant System Pressure, Cold-Leg Temperature and Flow Departure from Nucleate Boiling Limits to the Core Operating Limits Report

ML041890098
Person / Time
Site:	Palisades
Issue date:	08/02/2004
From:	Stang J NRC/NRR/DLPM/LPD3
To:	Domonique Malone Nuclear Management Co
Stang JF, NRR/DLPM, 415-1345
Shared Package
ml042160428	List: ML041890098
References
TAC MC0804
Download: ML041890098 (9)

Text

August 2, 2004 Mr. Daniel J. Malone Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

PALISADES PLANT - ISSUANCE OF AMENDMENT RE: RELOCATING THE PRIMARY COOLANT SYSTEM PRESSURE, COLD-LEG TEMPERATURE, AND FLOW DEPARTURE FROM NUCLEATE BOILING LIMITS TO THE CORE OPERATING LIMITS REPORT (TAC NO. MC0804)

Dear Mr. Malone:

The Commission has issued the enclosed Amendment No. 217 to Facility Operating License No. DPR-20 for the Palisades Plant. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 18, 2003.

The amendment would revise TS Section 3.4.1, by relocating the primary coolant system pressure, cold-leg temperature, and flow departure from nucleate boiling limits to the core operating limits report. The amendment also revises TS section 5.6.5 to reflect the proposed change to TS section 3.4.1.

A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commissions biweekly Federal Register notice.

Sincerely,

/RA/

John F. Stang, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosures:

1. Amendment No. 217 to DPR-20

2. Safety Evaluation cc w/encls: See next page

ML042160428(Package)

ADAMS Accession No: ML041890098 ADAMS Accession No: ML042160408 (TS)

OFFICE PDIII-1/PM PDIII-1/LA SRXB/SC IROB/SC OGC PDIII-1/SC NAME JStang THarris JUhle TBoyce BPoole LRaghavan DATE 07/16/04 07/16/04 07/16/04 07/19/04 07/29/04 08/02/04 NUCLEAR MANAGEMENT COMPANY, LLC DOCKET NO. 50-255 PALISADES PLANT AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 217 License No. DPR-20

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nuclear Management Company, LLC (the licensee), dated September 18, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public; and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to the license amendment and Paragraph 2.C.(2) of Facility Operating License No. DPR-20 is hereby amended to read as follows:

The Technical Specifications contained in Appendix A, as revised through Amendment No. 217, and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. NMC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of issuance and shall be implemented within 90 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: August 2, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 217 FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3.4.1-1 3.4.1-1 3.4.1-2 3.4.1-2 5.0-25 5.0-25 5.0-27 5.0-27

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 217 TO FACILITY OPERATING LICENSE NO. DPR-20 NUCLEAR MANAGEMENT COMPANY, LLC PALISADES PLANT DOCKET NO. 50-255

1.0 INTRODUCTION

By application dated September 18, 2003, the Nuclear Management Company, LLC (NMC),

requested changes to the Technical Specifications (TSs) for the Palisades Plant. The proposed changes would revise Limiting Condition for Operation (LCO) 3.4.1 of TS, by relocating the primary coolant system (PCS) pressure, temperature, and flow departure from nucleate boiling (DNB) specific value limits to the Core Operating Limits Report (COLR). NMC also proposes to revise TS Section 5.6.5, Core Operating Limits Report, to reflect the proposed change to LCO 3.4.1. These proposed changes would allow NMC to modify these limits using Nuclear Regulatory Commission (NRC)-approved methodologies described in TS section 5.6.5 without the need for a license amendment request.

2.0 REGULATORY EVALUATION

Generic Letter (GL) 88-16, Removal of Cycle-Specific Parameter Limits from TS, provides the specific guidance for removing cycle-specific parameters from the TSs and putting them in an owner-controlled document. In the case of the Palisades Plant, the owner-controlled document is the COLR. The NRC staff evaluates TS changes for COLR implementation in accordance with the GL 88-16 guidance that allows the cycle-specific parameters to be relocated to the COLR provided that the parameters are calculated using the approved methods listed in Administrative Control Section of the TSs.

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, specifies the Commissions regulatory requirements related to the content of TSs. The NRC staffs evaluation of the acceptability of the proposed changes to the TSs is based on 10 CFR 50.36, Technical Specifications. Paragraph (A) of 10 CFR 50.36(c)(1)(ii) provides that, where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. Specifically, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether a LCO is required to be included in TSs. A TS LCO must be established for each item meeting one or more of the following criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant system (RCS) pressure boundary;

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design-basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; Criterion 3: A structure, system or component (SSC) that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; and Criterion 4: An SSC which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

The licensees proposed TS change will be evaluated against the above regulatory requirements and guidance.

3.0 TECHNICAL EVALUATION

TS LCO 3.4.1 addresses requirements for maintaining pressurizer pressure, PCS cold-leg temperature, and PCS total flow rate within limits assumed in the safety analyses. The safety analyses of normal operating conditions and anticipated operational occurrences assume initial conditions within the normal steady state envelope. The limits placed on departure from nucleate boiling (DNB)-related parameters ensure that these parameters, when appropriate measurement uncertainties are applied, will not be less conservative than those assumed in the safety analyses and thereby provide assurance that the minimum departure from nucleate boiling ratio will meet the required criteria for each of the analyzed transients in the final safety analysis report (FSAR).

These limits are potentially subject to change with each core reload. This currently requires the processing of changes to the TSs to update each parameter for each reloaded core. These limits are developed using a NRC-approved methodology. The license amendment process to change the parameters is an unnecessary burden. The proposed TS change will move the specific value and defining function for each parameter to the COLR in accordance with the guidance contained in GL 88-16. The current functions which defined each parameter in the TSs will be moved verbatim to the COLR without change.

It is essential to safety that the plant is operated within the bounds of cycle specific parameter limits. A requirement to maintain the plant within the appropriate bounds must be retained in the TS. However, the specific values of these limits may be modified by licensees, without affecting nuclear safety, provided that these changes are determined using a NRC-approved methodology and are consistent with all applicable limits of the plant safety analysis that are addressed in the FSAR. The current Palisades TSs require that a formal report should be submitted to NRC with changes that are made to the COLR. This will allow NRC staff to continue trending this information even though prior NRC approval of the changes to these limits will not be required.

The specific requirements of 10 CFR 50.36 will continue to be met in that a requirement for and surveillance of each parameter remains in the TSs. The LCO, as revised, continues to meet Criterion 2 because pressurizer pressure, reactor coolant system cold leg temperature, and reactor coolant system total flow rate are initial conditions assumed in safety analyses. The

specific value of each parameter will be moved to the COLR. Each parameter will be calculated as required by Section 5.6.5 of the current TSs using a methodology approved by the NRC.

Relocation of the PCS DNB numerical values of these parameters to the COLR, while leaving the parameters in the TS, will comply with existing operating fuel cycle analysis requirements.

Relocation of these parameter values to the COLR will provide the licensee the flexibility to enhance operating and core design margins without the need for cycle-specific license amendment requests. Any future revisions to the safety analyses that require prior NRC approval will be identified by the 10 CFR 50.59 review process.

The NRC staff concludes that the proposed TS changes to relocate the three PCS DNB numerical values to the COLR meets the GL 88-16 guidance that allows the cycle-specific parameters to be relocated to the COLR provided that the parameters are calculated using the approved methods with these methods, listed in Administrative Control Section of the TSs.

Therefore, the NRC finds the proposed changes to the TS acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Michigan State official was notified of the proposed issuance of the amendment. The Michigan State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding (68 FR 59218). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: John Stang Date: August 2, 2004

Palisades Plant cc:

Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 525 West Ottawa St.

1945 Parnall Rd. Sixth Floor, G. Mennen Williams Building Jackson, MI 49201 Lansing, MI 48913 Arunas T. Udrys, Esquire Manager, Regulatory Affairs Consumers Energy Company Nuclear Management Company, LLC 1 Energy Plaza 27780 Blue Star Memorial Highway Jackson, MI 49201 Covert, MI 49043 Regional Administrator, Region III Director of Nuclear Assets U.S. Nuclear Regulatory Commission Consumers Energy Company 801 Warrenville Road Palisades Nuclear Plant Lisle, IL 60532-4351 27780 Blue Star Memorial Highway Covert, MI 49043 Supervisor Covert Township John Paul Cowan P. O. Box 35 Executive Vice President & Chief Nuclear Covert, MI 49043 Officer Nuclear Management Company, LLC Office of the Governor 700 First Street P. O. Box 30013 Hudson, WI 54016 Lansing, MI 48909 Jonathan Rogoff, Esquire U.S. Nuclear Regulatory Commission Vice President, Counsel & Secretary Resident Inspectors Office Nuclear Management Company, LLC Palisades Plant 700 First Street 27782 Blue Star Memorial Highway Hudson, WI 54016 Covert, MI 49043 Douglas E. Cooper Michigan Department of Environmental Quality Senior Vice President - Group Operations Waste and Hazardous Materials Division Palisades Nuclear Plant Hazardous Waste and Radiological Nuclear Management Company, LLC Protection Section 27780 Blue Star Memorial Highway Nuclear Facilities Unit Covert, MI 49043 Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741