ML18059A941

Application for Amend to License DPR-20,relocating Cycle Specific Operating Limits to Colr,Per Guidance of GL 88-16, Removal of Cycle-Specific Parameter Limits from Ts. Proposed COLR Encl

ML18059A941
Person / Time
Site:	Palisades
Issue date:	04/07/1994
From:	Rogers D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18059A942	List: ML18059A941 ML18059A943 ML18059A944
References
GL-88-16, NUDOCS 9404190241
Download: ML18059A941 (4)

Text

consumers Power David W. Rogers Plant Safety and Licensing Director POWERINli

/llllCHlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 April 7, 1994 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - TECHNICAL SPECIFICATIONS CHANGE REQUEST - CORE OPERATING LIMITS REPORT A request for a change to the Palisades Technical Specifications (TS) is enclosed. This change is necessary to relocate cycle specific operating limits to a Core Operating Limits Report, which will reduce future need for recurrent changes to the Technical Specifications. While no definitive evaluation of averted cost has been completed, this proposed Technical Specifications change is expected to reduce costs of change request preparation and review. These changes are proposed in accordance with the guidance of Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications."

The attached change request provides a description and discussion of each proposed change. In addition to the change request, several attachments have been included to assist the reviewer:

1) The Proposed Technical Specifications pages.

2) Existing Technical Specifications pages, marked to show the changes.

3) The Proposed Core Operating Limits Report It is requested that the Amendment associated with this Technical Specifications change request become effective upon approval.

David W. Rogers Plant Safety and Licensing Director CC Administrator, Region III, USNRC Resident Inspector, Palisades Attachments A 01AS ENERGY COMPANY

CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 It is requested that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described below:

I. Changes:

It is proposed that the specifications listed below be changed to relocate fuel cycle-specific parameter limits to a Core Operating Limits Report (COLR) in accordance with the guidance of Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications." Several of the specification bases are revised to refer to limits relocated to the COLR. In each case where Technical Specification (TS) limits have been rel-ocated to the COLR, the limits placed in the COLR are unchanged and the bases have been revised accordingly. The following changes are proposed:

1.4: A definition for the Core Operating Limits Report is added to the miscellaneous definitions. The proposed definition was taken from NUREG 1432, Standard Technical Specifications, Combustion Engineering Plants (STS).

3.1.lg: The primary coolant Tinlet function with associated inlet temperature limits and the Axial Shape Index limit, Figure 3-0, are relocated to the COLR. Specification 3.1.lg has been revised to include an explicit requirement that ASI be within limits; this is only implied in existing TS. Also an action statement has been added for the condition when reactor inlet temperature is not within limits. The action specified is the same as that specified in STS for Tavg being out of limit. There is currently no action statement provided for inlet temperature being out of limits. The text of Specification 3.1.1 and of its basis have been consolidated to eliminate blank space and unnecessary pages.

3.10.5: The regulating group insertion limits and the control rod insertion limits curve, Figure 3-6, currently in section 3.10.5, have been relocated to the COLR. The action statement, currently part of paragraph 3.10.5a, has been reworded to enhance clarity.

3.10.8: Test exception 3.10.8 has been deleted; it is no longer needed.

3.11.2: The method for determining the Allowable Power Level (currently in the basis) and the Axial Variation Bounding Condition limit, Figure 3.11-1, are relocated to the COLR. Page numbers for Specifications 3.11.2, 3.12, and 3.13 have been revised to eliminate out of sequence page numbering.

3.23.1: The Linear Heat Rate limit, the tables (3.23-1, 3.23-2, 3.23-3),

and Figure 3.23-1 are relocated to the COLR.

3.23.2: The Radial Peaking Factor limits and associated Tables (3.23-2 and 3.23-3) are relocated to the COLR.

6.9.1: An administrative reporting requirement for the COLR is added to the routine reports. The proposed wording is modeled after the wording in STS.

2 II. Discussion The proposed changes relocate limits and parameters that can generally change with core reloads. These values are to be maintained in a Core Operating Limits Report, which will be submitted to the NRC with each change. This amendment request will result in resource savings for Consumers Power Company and the NRC by eliminating routine license amendment requests on changes in values of fuel cycle-specific parameters.

The limits proposed for relocation from the TS to the COLR are required to be developed using NRC-approved methodology. The proposed changes also list the NRC-approved methodology documents in the administrative reporting requirements. In this manner, the calculation methodology and acceptance criteria are referenced in the TS, but not the cycle specific limits. This change will permit specific values to be changed without prior NRC review and approval, but only in accordance with the specified methodologies.

Therefore, a requirement to maintain the plant within the appropriate bounds is retained in the TS. The specific values will be in the COLR.

III. Analysis of No Significant Hazards Consideration Consumers Power Company finds the activities associated with this Technical Specifications (TS) change involve no significant hazards and accordingly, a no significant hazards determination per 10 CFR 50.92(c) is justified.

The following evaluation supports the finding that operation of the facility in accordance with the proposed TS would not:

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

The proposed changes to the TS simply move the values and parameters for fuel cycle-specific limits from the TS to a Core Operating Limtts Report (COLR). The requirements to maintain the plant within appropriate bounds are retained in the TS. The values of the cycle-specific parameter limits in the COLR are determined using an NRC-approved methodology and remain consistent with all applicable limits of the plant safety analyses that are addressed in the Final Safety Analysis Report (FSAR). A requirement for the COLR and identification of the approved methodology documents are added to the TS. There are no associated changes in plant operation. Therefore, operation of the facility in accordance with the proposed TS would not result in a significant increase in the probability or consequences of an accident previously evaluated.

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

As discussed above, the proposed changes do not remove or alleviate any requirements to maintain the plant within the appropriate bounds.

There are no associated changes in plant operation. Therefore operation of the facility in accordance with the proposed TS would not create the possibility of a new or different kind of accident from any previously evaluated.

3

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

The proposed changes to the TS simply move the values and parameters for cycle-specific limits from the Specifications to a Core Operating Limits Report (COLR). The requirements to maintain the plant within appropriate bounds are retained in the TS. The values of the cycle-specific parameter limits in the COLR are determined using an NRC-approved methodology and remain consistent with all applicable limits of the plant safety analyses that are addressed in the Final Safety Analysis Report (FSAR). A requirement for the COLR and identification of the approved methodology documents are added to the TS. There are no associated changes in plant operation. Therefore, operation of the facility in accordance with the proposed TS would not involve a significant reduction in a margin of safety.

IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications change request and has determined that the change involves no significant hazards consideration. This change has been reviewed by the Nuclear Performance Assessment Department. A copy of this Technical Specifications change request has been sent to the State of Michigan.

CONSUMERS POWER COMPANY To the best of my knowledge, the contents of this Technical Specifications Change Request are truthful and complete.

By '2Mt1-.£ o~

Robert A. Fenech, Vice President Nuclear Operations Sworn and subscribed to before me this 1 day of --=Gp~.Jtii

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LeAnn Morse, Notary Public Berrien County, Michigan Acting in Van Buren County, Michigan  ::: -......:

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