ML20153B588

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Forwards Application for Amend to License DPR-6,revising Tech Specs Re Reactor Depressurization Sys (Rds) Surveillance Testing,Eliminating Partial Quarterly Stroke Exercising of Rds Depressurizing Valves
ML20153B588
Person / Time
Site: Big Rock Point File:Consumers Energy icon.png
Issue date: 07/05/1988
From: Berry K
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20150C786 List:
References
NUDOCS 8807130139
Download: ML20153B588 (2)


Text

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Consumers

@MMM g q qq M Poiver Kennetn W Berry Director Nwlear Lkensing Generst offus: IMS west Pernall Road. Jackson, MI 49201 . (517) 788 1639 July 5, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - RDS SURVEILLANCE TESTING AND RDS RELIEF REQUESTS Attached is a Request for Change to the Big Rock Point Technical Specifications.

Approval of thesa proposed ADS surveillance testing changes, which eliminate quarterly partial stroke exercising of the RDS depressurizing valves, is requested as part of the Big Rock Point Integrated Plan, Issue B-082, Reactor Depressurization System (RDS) Reliability Improvements. The quarterly partial stroke exercise is replaced with a requirement to full stroke exercise all four depressurizing valves each refueling outage. RDS reliability is believed to be enhanced by this request in two ways: (16 Improving depressurizing valve testing by requiring full stroke exercising all depressurizing valves each refueling outage (currently valves are only partial stroke exercised) and (2) Reducing the prc5 ability of deprcssurizing valve pilot valve leakage (existing evidence indicates partial stroke exercising is a significant contributor to chronic pilot valve leakage). These proposed changes have been discussed with cognizant FRC Regional and Headquarters staff. Since this proposal meets the intent of applicable industrial standards and your technical staff has informally indicated their concurrence, we will implement these proposed changes pending NRC review and approval.

By letter dated November 26, 1984, Consumers Power Company had previously proposed a RDS surveillance testing frequency change. This request was denied

! by NRC letter dated December 18, 1984 on the baeis that it was not supported by a thorough evaluation of the proposed testing frequency or of other alternatives to reduce pilot valve leakage. Our letter dated February 11, 1985 provided the necessary data and evaluation t- asolve the specific concerns that resulted in the denia). Subseque initiatives to reduce pilot valve leakage have been provided in our Integrated Plan Semiannual Updates dated February 12, 1985, and August 31, 1987. Additional initiatives are included with this change request.

8807130139 DR 880705 ADOCK 05000J 55 PrK) n\

OC0688-0056-NLO2 6g 1

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- - 1 Nucisar Rsgulatory Commission 2' Big Rock Point Plant TSCR RDS Surveillance Testing & Relief Reqsts July 5. 1988 Attachment 2 contains two ASME Code Relief Requests for the RDS system. One requests relief from the quarterly full stroke exercise frequency and the other requests relief frem the post maintenance operability testing require-ment following pilot valve assembly removal and reinstallation.

By letter dated March 22, 1988, a proposed Technical Specification Change Request, entitled Frequency of RDS Depressurizing Va.'ve Testing, was submitted for NRC review and approval. This submittal supersedes the Merch 22 change request and it is hereby withdrawn. Pursuant to 10CFR170.12(c), a check in the amount of $150.00 was remitted with the previous change request. We request this check be applied as the application fee for this submittal.

Y Kenneth W Berry Director Nuclear Licensing

.C0 Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point Attachments r

OC0688-0056-NLO2

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