ML20128B913

Application for Amend to License DPR-6,changing Tech Specs to Allow Operation of Plant Between Refueling Shutdowns W/O Potential of Requiring Surveillance Test to Be Performed.Fee Paid

ML20128B913
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	06/27/1985
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
Shared Package
ML20128B916	List: ML20128B913 ML20128B929
References
NUDOCS 8507030381
Download: ML20128B913 (5)

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@ Consumers Power o vio a v o w ii-Director of Nuclear Dcensmg General offmes: 1945 West Parnall Road, Jackson, MI 49201 . (517) 788-1636 June 27, 1985 Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - SURVEILLANCE FREQUENCIES Attached are three (3) original and thirty-seven (37) conformed copies of a request for change to the Big Rock Point Technical Specifications. Several of these changes are requested to allow operation of the plant between refueling shutdowns without the potential of requiring a surveillance test to be performed that may affect plant availability. Also, these changes are consistent with, and in some cases, more conservative than Standard Technical Specifications.

While past history has shown the NRC staff amenable to granting relief from such tests for a single cycle, (e.g., Amendment 11 issued February 23, 1977),

the process to request and receive such relief would tax our manpower resources. The potential for this problem is reduced with these proposed changes.

Pursuant to 10CFR170.12(c), a check in the amount of $150.00 is attached.

i avid J V deWalle Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment 8507030381 850627 00 PDR ADOCK 05000155 P PDR g/50 o\

qfd OC0685-0233-NLO4 ij u)

CONSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Facility Operating License DPR-6, Docket 50-155, issued to Consumers Power Company on May 1, 1964, for the Big Rock Point Plant be changed as described in Section I below:

I. Changes Section 5.2.3 Change the surveillance frequency for the squib primer and trigger assembly to read as follows:

"One squib primer and trigger assembly from the equalizing line shall be removed and test-fired at least every 18 months. These shall be tested on an alternate basis ensuring valve replacement every 36 months. One squib primer and trigger assembly from the remaining five units shall be removed and test-fired at least every 18 months. These shall be tested on an alternate basis. In no case shall a squib primer and trigger assembly remain in service longer than five years. The tests shall consist of monitoring of the input firing current and shearing of the integral inlet cap."

. . . and delete asterisk and footnote relating to surveillance due in February 1977.

Section 6.1.5(a) l Change the surveillance frequency for functional testing of the reactor safety system to read as follows:

"This system shall be functionally tested during each major refueling shutdown, but not less frequently than once every 18 months and in addition . . ."

Section 6.1.5(b)

Change the surveillance frequency for functional testing of the emergency condenser control initiation sensors to read as follows:

"The emergency condenser system control initiation sensors shall be functionally tested at each major refueling shutdown but not less fregt:ently than once every 18 months."

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2 Section 6.2.2 Change the surveillance frequency for functional testing of the control rod permissive circuits to read as follows:

" Permissive circuits shall be functionally tested prior to each major refueling but no less frequently than every 18 months. However, the refueling interlocks will be functionally tested prior to each major refueling."

Section 7.6 Change the tabularized test frequency for the liquid poison system component operability to read:

"Two months or less during power operation. One equalizing line squib and one remaining squib assembly test fired at least every 18 months."

Change the single asterisk relating to reactor safety system scram circuits requiring plant shutdown, containment sphere isolation trip circuits, emergency condenser trip circuits, and control rod drive withdrawal permissive interlocks to read:

"*But no less than once every 18 months."

Change the tabularized test frequency for control rod withdrawal permissive interlocks function to read:

" Prior to each major refueling shutdown *"

II. Discussion The above proposed Technical Specification changes are requested to allow operation of the plant between refueling shutdowns without the potential of requiring a surveillance to be performed that may affect plant availability. The proposed changes are consistent with, the surveillance frequencies in the Standard Technical Specifications (STS),

NUREG-0123, Revision 3, ucctions 4.1.5, 4.3.1.2, and 4.3.2.2 and in some cases are more conservative than the STS requirements which require just an 18 month surveillance. These proposed changes are also consistent with the surveillance frequency of each refueling shutdown but no less than once every 18 months which is used in several other sections of the Big Rock Point Technical Specifications. In addition, a similar change request was filed and approved by Amendment No. 30 dated October 19, 1977 on our Palisades Docket (50-255).

The potential exists for having to shut down just to perform a surveillance test. The present surveillance frequency requires that certain testing be done if the plant enters a forced outage prior to a refueling shutdown if the potential exists for the surveillance interval to be exceeded prior to the refueling shutdown. If the Technical NUO585-0200-NLO4

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3 Specification frequency for a particular test requires it to be done during a refueling shutdown the test will be done again, in some cases only months after it had been done during a forced shutdown. The additional testing may require additional manpower and may affect the outage period, especially during short duration forced outages.

The changes in frequency of the liquid poison system squib primer and trigger assemblies, although not tied to a refueling outage continue to limit the longest service life of the squib assemblies to the manufacturers limit of five years. Allowing 18 months between removal and testing would allow the surveillance to be performed during any cold shutdown, rather than a specific refueling shutdown. The STS allow an 18 month surveillance frequency.

The surveillance frequency for the control rod drive withdrawal permissive interlocks is also changed to 18 months. The capability exists to accomplish this testing while on-line. Therefore there is no need to tie the surveillance to a refueling shutdown. The 18 month surveillance is also consistent with the STS.

The remaining changes, related to the reactor safety system scram circuits, containment sphere isolation trip circuits, and the emergency condenser trip circuits maintain the surveillance frequency of each refueling outage but changes the bounding limit from 12 months to 18 months in order to permit a longer cycle between refueling shutdowns in the event that an unscheduled outage occurs. The STS for similar requirements simply allow an 18 month surveillance frequency.

Analysis of No Significant Hazards Consideration This Technical Specification Change Request provides for consistency throughout our Technical Specifications and with the Boiling Water Reactor Standard Technical Specifications (STS). The results of these changes are within all acceptable criteria with respect to the system or component specified in the Standard Review Plan (SRP) in that the SRP specifies that Boiling Water Reactor STS is consistent with regulatory guidance contained in the SRP. These changes are similar to examples (1) and (vi) of the examples of amendments that are considered not likely to involve significant hazards considerations as published in the Federal Register, Wednesday, April 6, 1983 (48 FR 14870). Therefore, these changes are considered not to involve significant hazards considerations.

III. Conclusion The Big Rock Point Plant Review Committee has reviewed this Technical Specification 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 under the cognizance of the Nuclear Safety Board. A copy of this i

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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

{ i f A LL--

By . 2

_ Mk R K )eWittT Vice Presfdent Nuclear Operations Sworn and subscribed to before me this 27th day of June 1985.

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HelenIDempski,NotargPublic

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Jackson County, Michigan My commission expires October 12, 1987 NUO585-0200-NLO4

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