ML18053A652

Application for Amend to License DPR-20,changing Tech Specs to Clarify Present Linear Heat Rate Specs.Fee Paid

ML18053A652
Person / Time
Site:	Palisades
Issue date:	10/06/1988
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18053A653	List: ML18053A652 ML18053A654
References
NUDOCS 8810130123
Download: ML18053A652 (5)

Text

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consumers Power Kenneth W Berry Director PllWERINli Nuclear licensing llllUllliAN"S PROliRESS General Offices: 1945 West Parnell Road. Jackson, Ml 49201 * (517) 788-1636 October 6, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATIONS CHANGE REQUEST - LINEAR HEAT RATE Attached is a proposed change to the Palisades Technical Specifications to provide clarification to the present Linear Heat Rate Specification.* The change clarifies required action statements and time limits of the existing Technical Specification. The change also is consistent with Consumers Power Company's submittal of September 1, 1988, Technical Specifications Change Request - Peaking Factors and LOCA Limits.

Confusion over the present requirements occurred in an incident April 27, 1987, and Consumers Power Company described, in our response to IEIR 87-008, the root cause as a poorly worded Technical Specification and resolved to submit a revision. We request the amendment become effective upon issuance.

A check for $150.00, as required by 10CFR170.12, is enclosed.

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Palisades Attachment I

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1 CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I. Changes and Discussion of Changes A. Section 3.23.1 is completely revised to include all requirements of the prior section 3.23.1 and to clarify required actions and time limits to assist in prompt, proper operator actions. Section 3.23.1 is written in a more directive style. Branching to other Action Statements and decision making within Action Statements have been removed. Each of the methods, ensuring Linear Heat Rate (LHR) is maintained within limits, are written as a self-contained subsection which stands on its own without referencing similar requirements in the other methods of maintaining LHR within limits~

B. References to FB(E) an F (Z) have been deleted from the first paragraph of section 3.25.1 to be consistent with a concurrent Technical Specification Change Requ~st regarding Peaking Factors which has been submitted separately.

c. Sections 3.23.1.1 and 3.23.1.2 are added and sections 3.11.1 and 3.11.2 are referenced to help ensure that applicable requirements are.not overlooked when changing the method being used to monitor LHR.

D. Section 3.23.1.2.b is added to .be consistent with section 4.19.1.2.b to maintain quadrant power tilt less than 3%.

E. Section 3.23.1.2.c is added to be more consistent with section 4.19.1.2.c to maintain reactor power less than or equal to the Allowable Power Level (APL) and not more than 10% of rated power greater than the power level used in determining the APL.

F. Section 3.23.1.2, Action a., is added to implement section 4.19.1.2.c.

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2 G. The requirement to stop using the excore monitoring system for monitoring LHR, if quadrant tilt exceeds 3%, is added in section 3.23.1.2, Action b., to implement section 4.19.1.2.b.

H. Section 3.23.1.4 is added to provide time limits to reduce reactor power to less than 50% when LHR cannot be monitored. The two-hour time limit to reduce reactor power to less than 85% is consistent with section 3.23.1.2, Action a, and section 3.23.1.3.a and allows adequate time to commence and perform an orderly power reduction.

The additional two hours to reduce reactor power to less than 50%

allows adequate time to continue an orderly power reduction to a power level at which it is improbable that LHR limits could be exceeded.

I. The APPLICABILITY statement has been changed from "Power Operation above 50% of rated power" to "Power Operation" in order to maintain internal consistency of the proposed Technical Specification. This is necessary due to the addition of section 3.23.1.4, which explicitly includes power operation at less than 50% power as one of the methods for satisfying LHR limits. This change in APPLICABILITY does not change the requirements of the current Technical Specifi-cation 3.23.1 and is editorial in nature due to the restructuring of Technical Specification 3.23.1.

II. Analysis of No Significant Hazards Consideration Consu~ers Power Company finds that activities associated with the. change request involve no significant hazards, and, accordingly, a no significant hazards determination per 10CFR50.92(c) is justified. The following evaluation supports that finding.

Evaluation

1. Involve a significant increase in the probability or consequences of an accident previously evaluated:

Existing requirements in the Linear Heat Rate Technical Specifications are all maintained in this proposed Technical Specifications change. The Technical Specifications change is written to clarify required actions and time limits and thereby assist in prompt, proper operator actions to satisfy Technical Specification require-ments.

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3 Proposed changes 3.23.1.l thru 3.23.1.3 are administrative changes which reformat former Actions 1, 2, and 3. These changes are made to clarify the former Action Statements.

Proposed Technical Specification 3.23.1.4 is added to provide time limits to reduce reactor power to less than 50% when LHR cannot be monitored. The requirement in proposed Technical Specification 3.23.1.4 to reduce reactor power to less than 85% within two hours is consistent with two-hour time limits to reduce power to less than 85% in proposed Technical Specification 3.23.1.2, Action a.,

and proposed Technical Specification 3.23.1.3.a and allows adequate time to commence and perform an orderly power reduction. The requirement to reduce reactor power to less than 50% within the next two hours, if LHR cannot be monitored, allows for an orderly reduction of reactor power to a power level at which it is improbable that LHR limits could be exceeded. Proposed Technical Specification 3.23.1.4 requires a timely response to complete loss of ability to monitor LHR. The action statement for proposed Technical Specification 3.23.1.4 also allows power increases up to 50% of .rated thermal power without monitoring LHR per 3.23.1.1, 3.23.1.2 or 3.23.1.3. This provision is necessary during .Plant startup and is consistent with Technical Specification 4.19.1.1.

Therefore, the proposed Technical Specifications change does not increase the probability or consequences of an accident previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated:

The proposed Technical Specifications change is an administrative revision. It maintains all requirements which currently exist in the Technical Specifications and provides additional time limits for reduction of reactor power when the ability to monitor LHR is completely lost. Thus, the Technical Specifications change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of. safety:

The proposed Technical Spectfications change maintains all require-ments which currently exist. The Technical *specifications change also requires a more rapid response to complete loss of ability to mQnitor LHR than is currently required by Technical Specification 3.0.3. Therefore, the Technical Specifications change does not alter the margin of safety.

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4 III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specif-ication Change Request and has determined that this change does not involve an unreviewed. safety question and, therefore, involves no significant hazards consideration. This change has also been reviewed by the Nuclear Safety Board. A copy of this Technical Specification

• Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY By \.\--t-=-~----u..n... (~c?

David President ns Sworn and subscribed to before me this 6th day of October 1988.

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Elaine E Buehrer, 'Notary Public Jackson County, Michigan My commission expires October 31, 1989 OC0988-0151-NL02