ML20247L089

Application for Amend to License DPR-6,to Align Specs to 10CFR50,App J Requirements That Permit Removal of 24 H Duration Restriction on Integrated Leak Rate Test

ML20247L089
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/25/1989
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247L098	List: ML20247L089 ML20247L114
References
NUDOCS 8906020087
Download: ML20247L089 (4)

Text

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p,,;.3 5 C0DSumers P POW 8f-Kenneth W Berry

. MM Director

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Go tal Offices: 1945 West Parnell Roed. Jackaan, MI 49201 e (517) 788-1636 LMay,25,'1989 (Draft)

Nuclear Regulatory. Commission

' Document Control Desk-

Washington, DC 20555

, ' DOCKET 50-155.- LICENSE DPR BIG ROCK POINT PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - CONTAINMENT SPHERE LEAKAGE TESTING i

Attached is a request for change to the Big Rock Point Plant Technical Specifi-  !

cations. This change.is being requested to align the specifications to the  ;

current requirements of 10CFR50 Appendix J, which permits removal of the 24 i hour' duration restriction. . This vill permit test method changes needed to reduce the impact of diurnal effects which inherently cause testing problems

'due to the Big Rock Point containment design. Consumers Power Company recognizes that Appendix J.and the endorsed Industry Standards do permit Integrated Leak Rate Test durations of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This proposed Technical Specification Change Request was discussed with the Big Rock Point Project Manager and NRC Staff Technical Specialist earlier this year.

Big Rock' Point is scheduled to perform an Integrated Leakage Rate Test during the 1989 Refueling Outage. Consumers Power Company recognizes that this request is not being submitted as timely as it could have been, and any effort to issue'an Amendment by July 21, 1989 would be appreciated in order to  !

implement these improvements in the upcoming ILRT.

IO h445 Berry &' I Ken eth Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point Attachment i

8906020087 890525 ADOCK 05000153 g

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l cf CONSUMERS POWER COMPANY J Docket 50-155 Request for Change to the Technical Specifications License DPR-6

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l 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 3.7 - (d)(e)(f) ,

Revise these sections to read as follows:

(d) A containment sphere integrated leakage rate test shall be performed at a pressure rot less than 11.5 psig in conformance with

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the criteria specified in Appendix J'of 10 CFR 50. Three tests shall be conducted at 40 i 10 month intervals during each 10-year service period.

(e) If any containment sphere integrated leakage rate test (ILRT) fails

. to meet the specifications of 0.5%/ day of contained atmosphere (weight basis) at the design pressure (27 psig) or extrapolated to the-design pressure, the test schedule for subsequent ILRTs shall-be reviewed and approved by the Commission. If two consecutive ILRTs fail to meet these specifications, then an 1LRT shall be performed at least every 18 months until two consecutive ILRTs meet the acceptance criteria, at which time the above test schedule may be resumed.

(f) The accuracy of each ILRT shall be verified by a supplemental test in accordance with Appendix J of 10 CFR 50 which confirms the accuracy of the test by (1) verifying the difference between the supplemental test data and the ILRT is 0.25 L or 0.25 L , (2) continuing the test for a duration sufficient"to establish accurately the change in leakage rate between the ILRT and supplemental test.

l II. Discussion l

The intent of this Technical Specification Change Request.is (1) to l modify this section to depict the requirements of 10 CFR 50 Appendix J j and NUREG-0123, Standard Technical Specifications for General Electric Boiling Water Reactors; (2) remove the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration requirement to permit use of the " Total Time" and Point-to-Point methods described in  !

ANS N45.4-1972 and Bechtel Topical Report BN-TOP-1. Both of these methods permit a reduced duration needed to minimize the diurnal effects to insure that a leakage rate and upper bound 95% confidence limit can be accurately determined.

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2 The Big Rock Point Containment is a large (130 ft. diameter) sphere constructed of 3/4 inch plate steel. The exterior is covered by a thin layer of mastic and paint as a protect'or to the outside environs but provides minimal insulating value. This design inherently results in variations in containment temperatures due to variations in windspeed, temperature, and percent overcast conditions. With the plant located )

on the northern shore of Lake Michigan, these variations can be very extreme during the summer months due to " lake effect" cooling after i dark. l This problem is discussed in NRC Inspection Report #85-020 dated  !

11/21/85, Section F, Test Witnessing, "Due to the aforementioned )

diurnal effects, the supplemental verification test took 10.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> to stabilize within the acceptance criterion."

Never silo-type containment structures do not experience the same difficulties, where the concrete thickness precludes the diurnal i effects. Big Rock Point can, however, minimize the effects of atmo-spheric instability by using the point-to-point method of calculating the leak rate as described in ANSI N45.4-1972 permitting a decreased j test length. A reduction in test length would not decrease the accuracy  !

of the test. This is supported by ANSI-N45.4-1972 wherein it states, "If it can be demonstrated to the satisfaction of those responsible for the acceptance of the containment structure that the leakage rate can be accurately determined during a shorter test period, the agreed upon q shorter period may be used." 1 A discussion of the proposed changes are as follows:

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1. The revised section (d) now endorses the requirements of 10 CFR 50 Appendix J and also includes the test frequency requirements of Appendix J and the Standard Technical Specifications. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration and maintenance guidance has been removed, however, Appendix J and associated references still provide requirements for duration and "as found" test results.

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2. The revised section (e) includes the previous requirements of l section (f) and last portion of (d), however, also adds the requirements of 10 CFR 50 Appendix J (III) (A)(6).

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3. The revised section (f) now includes verification requirements of 10 CFR 50 Appendix J (III)(A)(3)(b). The existing section (d) of the Big Rock Point Specifications did include verification require-ments but did not fully depict 10 CFR 50 Appendix J.

III. Analysis of No Significant Hazards Consideration The proposed change to the Big Rock Point Technical Specifications involves no significant hazards consideration because:

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1. The proposed change does not alter the containment leakage rate  !

acceptance criteria used to determine the consequences of accidents l previously evaluated, thus does not affect the results of the previous evaluations. The proposed changes also do not ' require any system or component modifications nor a change to the operational q mode in which the testing is performed thus concluding no effect on the probability of occurrence of an accident previously evaluated.

2. Integrated leak rate testing will still be performed during cold i shutdown conditions which is unaffected by the proposed change. j Methods used to perform the test do not affect containment components or systems and modifications are not needed to implement the change thus avoiding the possibility to create a new or different kind of accident or malfunction.

3. The proposed change does not involve a reduction in the margin of safety because the containment leakage rate limit is not being changed. -Surve111ance interval for performance of the test remains essentially unchanged (3 per 10 year service period). The change does remove the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration requirement, however, accuracy of the test.will not be reduced because verification requirements are  ;

still in place to insure that the upper bound 95% confidence limit j is achieved per 10 CFR 50 Appendix J.

1 IV. Conclusion  !

The Big Rock Point. Plant Review Committee has reviewed this Technical Specification Change Request and has determined this change does not involve an unreviewed. safety question and therefore, involves no  !

significant hazards consideration. This change has been reviewed by l 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, ,

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CONSUMERS POWER COMPANY i

E By <

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David P Hoffman, V Q sident Nuclear Operati Sworn and subscribed to before me this 25th day of May, 1989.

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Elaine E Buehrer,' Notary Public Jackson County, Michigan My commission expires October 31, 1989 I

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