ML18052B291

Application for Amend to License DPR-20,deleting Tech Spec Table 4.2.1,Item 5 Footnote Re Performance of Surveillance Frequency for Boron Concentration in Safety Injection Tank T-82B for Cycle 5.Fee Paid

ML18052B291
Person / Time
Site:	Palisades
Issue date:	09/11/1987
From:	Berry K, Reynolds J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML18052B293	List: ML18052B291 ML18052B295
References
NUDOCS 8709170045
Download: ML18052B291 (4)

Text

consumers Power l'OWERIN&

ll/llCHlliAN'S l'R.O&R.ESS

.._ ' ' IP General Offices: 1945 West Parriall Road, Jackson, Ml 49201 * (517) 788-1636 September 11, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -TECHNICAL SPECIFICATION CHANGE REQUEST -SURVEILLANCE FREQUENCY FOR BORON CONCENTRATION IN SI TANK T-82B Kenneth W Berry Director Nuclear Licensing A Consumers Power Company letter dated December 15, 1982 submitted changes to the Palisades Technical Specifications for required boron concentration and sampling frequency of one of the four safety injection tanks (T-82B) for the remainder of Cycle 5. Amendment 74 to the Provisional Operating License No. DPR-20 approved the changes. Our letter of December 19, 1985 requested deletion of the Cycle 5 specific limits for boron concentration and Amendment 101, dated February 10, 1987 approved the removal of the outdated specifications.

However, both our request and the amendment failed to also delete the Cycle 5 specific frequency for performing the sample tests of the T-82B tank. This letter requests deletion of the out-of-date footnote.

The Palisades Technical Specifications, Section 3.3.1.b require all four Safety Injection Tanks to contain a boron concentration of at least 1720 ppm but not more than 2000 ppm. Table 4.2.1 establishes a monthly surveillance frequency for sampling the boron concentration in the SI Tanks. Section 3.3.1.b. footnote allows the concentration of T-82B to be reduced to PCS concentration.

This Cycle 5 specific footnote was added to resolve problems associated with primary coolant in-leakage tank T-82B. In recognition of* the reduced concentration limits, the monthly sampling requirements for the one tank was changed to weekly to allow for closer monitoring of the boron concentration.

This temporary change was added by footnote to Table 4.2.1, item No. 5, "SI Tanks" and a second requirement that T-82B be sampled within one hour of a PCS boration of 70 ppm to ensure the boron concentration in the SI Tank was maintained above PCS concentration under all operating and shutdown conditions.

On September 3, 1987, we discovered that the footnote still remained in the Palisades Technical Specification.

A Corrective Action Document (Event Report No. E-PAL-87-041) was initiated in response to our failure to maintain the l OC0987-0155-NL04:

I PDR ADOCK 05000255 \!

• p PDfl':

r Nuclear Regulatory Commission Palisades Plant TSCR -Surveillance Frequency for Boron Concentration September 11, 1987 weekly sampling tests for the T-82B SI Tank. The discovery was considered a Technical Specification Violation and will therefore be reported via Licensee Event Report. (Reference LER 87-030) 2 Conduct of this additional test, subjects our employees to additional radiation exposure and is therefore an ALARA concern. The test requires three persons, two operators to perform valve line-ups and one chemistry technician to obtain the sample. This takes approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. The technician will also be subjected to additional exposure while analyzing the sample. The total accumulated dose is approximately 50 mrem for sampling and analysis on the average. Since this particular test contributes unnecessary radiation exposure to our employees and was only intended *for Cycle 5 operation, we have decided not to reinitiate the surveillance test. The Palisades NRC Senior Resident Inspector has reviewed this change and concurs that due to the ALARA concerns, we should not recommence weekly testing for the T-82B SI Tank. Since this change involves a Technical Specification Violation, your prompt review is requested.

A check as required by 10CFR170.21 is included.

We request the proposed Technical Specification to become effective upon issuance of the Amendment.

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector

-Palisades Attachment OC0987-0155-NL04

, CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 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. Changes A. Delete the asterisk (*) on Table 4.2.1, Item #5, following FSAR Section Reference 6.1.2. B. Delete the entire asterisk (*) footnote "*For T-82B -weekly -within one hour * *

• than 70 ppm." of Table 4. 2. 1, Item ti 5. II. Discussion The asterisk and footnote may be deleted since the footnote was only applicable to Cycle 5 operation.

This change was inadvertently omitted from our request dated December 19, 1985 and the subsequent Amendment No. 101, dated February 10, 1987. Analysis of No Significant Hazards Consideration This change is administrative.

It deletes an out-of-date footnote that provided an alternative action for one of four similar components during a previous operating cycle. The proposed administrative change does not impact on plant design or operation in a manner different than previously evaluated; hence the probability or consequences of previously evaluated accidents are unaltered.

Because this change does not introduce any new equipment or modes of operation, it will not create the possibility of a new or different kind of accident from that which was previously evaluated.

The margin of safety is not being compromised because the original Technical Specification surveillance interval is being maintained.

The deletion of a more frequent surveillance interval for one specific component was established by previous Amendment as a result of reduced concentration limits which are no longer applicable to the operation of the plant. Therefore, this administrative change involves no significant hazards consideration.

Furthermore, this change fits example [i] of the types of amendments that are considered not likely to involve significant hazards considerations published in the Federal Register on March 6, 1986 (51FR7751), in that it represents a purely administrative change, i.e., a correction of an error since the footnote no longer applies to current operating cycles. OC0987-0155-NL04 2 III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change _Request and has determined that this change does not involve an 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 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 By Sworn and subscribed to before me this 11th day of September 1987. Elaine E Jackson County, Michigan My commission expires October 31, 1989 OC0987-0155-NL04