ML18054A700

Application for Amend to License DPR-20,revising Tech Specs Re Airlock Leak Tests

ML18054A700
Person / Time
Site:	Palisades
Issue date:	04/20/1989
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18054A699	List: ML18054A698 ML18054A700 ML18054A701
References
NUDOCS 8904260105
Download: ML18054A700 (2)

Text

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 Revised Technical Specifications are attached. Proposed changes are shown by vertical slashes in the margin.

II. Discussion The proposed changes were initiated originally in a letter to NRC dated March 3, 1982. The revisions were proposed to comply with the requirements of Appendix J to 10CFR50 following NRC denial of a request for an exemption to the requirement that the personnel air lock be tested after each opening. The NRC denial letter was dated December 11, 1981. A March 21, 1988 Technical Specification Change Request revision was submitted that deleted part of the original change request (specifically section 4.5.2.c(3)). The deleted section resolved concerns raised by the NRC reviewer.

This cha~ge incorporates those previously docketed proposed change requests. In addition, it resolves comments identified by the current NRC reviewer who requested that the proposed Technical Specifications Change Request_(TSCR) be more consistent with the Standard Technic~l Specifications. This required the addition of an acceptance criterion that is currently specified by plant procedures for the between the seals door lock test and an action statement consistent with industry practice.

Analysis of-No-Significant-Hazards-Consideration The probability of occurrence of an accident has not been increased.

This-TSCR imposes containment air lock seal leakage criteria that was previously_specified and will continue-to be specified by plant procedures. The consequences of an accident are not increased as the containment leakage rate is specified by 10CFR50 Appendix J as an overall rate identified as La which is based on the calculated peak containment internal pressure, Pa. This change serves to reduce the consequences of an accident by imposing action statements with increasingly shorter periods of operability_when air_lock door seal leakage exceeds the acceptance criteria at .023 La, .6 La and La.

OC0489-0llS-NL04

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2 The probability of occurrence of a malfunction of equipment also has not been increased. The additional between the seals test serves to more conservatively protect from a single door seal failure causing the plant to exceed its total leakage limit. The consequences of a malfunction of equipment are no greater than those already analyzed in the FSAR.

The proposed Technical Specifications provide more conservative plant limiting conditions for operation so that there is no increase in the probability of occurrence or consequences of a new accident or new malfunction of equipment described in the FSAR and additionally no reduction in the margin of safety as described in the Plant Technical Specifications.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications 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 been reviewed by the Nuclear Safety Board. A copy of this Technical Specifications Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY By Hoffman, Vice r Nuclear Operations Sworn and subscribed to before me this 20th day of April 1989;

~l Elaine E Buehrer, Notary Jackson County, Michigan My commission expires Octoher 31, 1989 OC0489-0115-NL04