ML18051B094

Application for Amend to License DPR-20,changing Radiological Effluent Tech Specs to Add Footnote to Table 3.24-2 to Exempt Three Instrument Setpoints from Spec 3.24.5.1

ML18051B094
Person / Time
Site:	Palisades
Issue date:	10/25/1984
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	Office of Nuclear Reactor Regulation
Shared Package
ML18051B095	List: ML18051B094 ML18051B096
References
NUDOCS 8410290202
Download: ML18051B094 (5)

Text

consumers Power David J VandeWalle company Director of Nuclear Licensing General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 October 25, 1984

Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - TECHNICAL SPECIFICATION CHANGE REQUESTS MODIFICATION RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)

By letter dated July 31, 1984, Consumers Power Company submitted our proposed Radiological Effluent Technical Specifications (RETS) for our Palisades Plant, and committed to their implementation on January 1, 1985. During procedure development for implementation of the RETS, Consumers Power Company has identified two areas where minor changes to our proposed RETS are required. A summary of these required changes is below.

Waste Gas Release - Xenon-133 Proposed technical specification 3.24.6.1 states *** "the waste gas decay tank with the lowest Xe-133 concentration shall be released." This action state-ment was written in conformance with the wording of the model RETS (Reference 1). The gas decay tanks at the Palisades Plant are of two capacities.

Release of waste gas in accordance with the above action statement could therefore result in a larger total amount of Xe-133 being released in the event that a larger capacity tank contains gas with a lower Xe-133 concentra-tion than a smaller capacity tank. In order to ensure that the intent of this specification is satisfied, Consumers Power Company is requesting this action statement be changed to " *.* the waste gas tank with the lowest Xe-133 content shall be released."

Accident Monitoring Instrumentation - Location of Process Monitor Requirements Consumers Power Company determined that all process monitor requirements should be located within one table to facilitate plant operations (Reference 2). This resulted in the listing of three process monitors used during and after an accident in Table 3.24-2 of the proposed RETS. These three process monitors are the High Range Noble Gas Monitor, Main Steam Safety and Dump Valve Discharge Line Monitor and Engineered Safeguards Room Vent System Monitor.

...

,Director, NRR 2 Palisades Plant TSCR MODIFICATION - RETS October 25, 1984 Proposed Specification 3.24.2.1 states that the instrumentation of Table

3. 24-2 shall have "their alarm/trip set points set to ensure that the l_imits of Specification 3.24.5.1 (essentially the MPC-maximum permissable concen~ra tion) are not_exceeded." This Limiting Condition of Operation (LCO) is not appropriate for the above three process monitors as the setpoints for these instruments are governed by the Emergency Implementing Procedures per NUREG-0737 or other technical specifications.

Consumers Power Company is requesting that a footnote be added to our proposed Table 3.24~2 that exempts these three instrument setpoi~ts from_ Specification 3.24.5.1.

Since these changes constitute a modification to our previous RETS submittal, we understand that the technical specification change request fees will be covered under our earlier submittal of July 31, 1984.

Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Insp~ctor - Palisades Attachments OC1084-0007A-NL02

Director, NRR 3 Palisades Plant TSCR MODIFICATION - RETS October 25, 1984 Reference 1 NRC letter dated October 31, 1983 transmitting Draft "7" of NUREG-0472, Revision 3, "Standard Radiological Effluent Technical Specifications for P~essurized Water Reactors, September 1982" Reference 2 DJVandeWalle (CPCo) to DMCrutchfield (NRC) "Palisades Plant Radiological Effluent Technical Specifications (RETS), Offsite Dose Calculation Manual (ODCM) and Process Control Program (PCP)," dated July 31, 1984 OC1084-0007A-NL02

CONSUMERS POWER COMPANY DOCKET.50-255 - LICENSE DPR PALISADES PLANT REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS 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. CHANGE(s)

A. Change specification 3.24.6.1 proposed in Consumers Power Company letter dated July .31, 1984, Action 'a', to read .** "the waste gas decay tank with the lowest Xe-133 content shall be released."

B. Add footnote to Table 3.24-2 in our.proposed Technical Specifica-tions change request dated July 31, 1984 "Radioactive Gaseous Effluent Monitoring Instrumentation" applicable to items:

3d. High Range Noble Gas (RIA 2327) Sa. Gross Gamma Activity Monitor (RIA 2323 and 2324) 6a. Noble Gas Activity Monitor (RIA 1810 and 1811)

The Footnote shall read: "Instruments exempted from Specification 3.24.5.1 setpoints. Setpoints for these instruments are governed by Emergency Implementing Procedures,operating procedures or technical specifications."

II. DISCUSSION A. This item being changed for the reasons specified in the cover lette.r to this change request.

B. .This item being changed for the reasons specified in the cover letter to this change request.

III. CONCLUSION The Palisades Plant Review Committee has*-reviewed this Technical Specifi-cation Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no signifi-cant hazards consideration. This change has also been reviewed under the cognizance of'the Nuclear Safety Boar~. A copy of this Technical Specifi-cation Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

OC1084-0007B-NL02

....

.:Director, NRR 2 Palisades Plant TSCR MODIFICATION - RETS October 25, 1984 CONSUMERS POWER COMPANY By @b&1--1--1-rli-R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 25th day of October 1984.

Sherry L Du ey, Notary Jackson ~ounty, Michigan My commission expires November 5, 1986.

SHERRY l YNN DURFEY Notary Public, Jackson County, Mic1.

My. Crrrrrission Exriir~~ Nov. 5 1936 OC1084-0007B-NL02