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E-M:/ Palisades Nuclear Plant wants higher power Trip



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Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>
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CONSUMERS ENERGY WANTS HIGHER POWER LEVEL SET BEFORE
REACTOR TRIPS OUT FROM EXCESSIVE POWER OPERATION.

TODAY'S FEDERAL REGISTER

Nuclear Management Company, LLC, Docket No. 50-255, Palisades Plant,
Van Buren County, Michigan

     Date of amendment request: November 2, 2001.
     Description of amendment request: The proposed amendment would
revise Technical Specification (TS) Table 3.3.1-1, Item 1, ``Variable
High Power Trip'' (VHPT), by increasing the maximum allowable value for
the VHPT from 106.5 percent to 111 percent.
     Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), the licensee has
provided its analysis of the issue of no significant hazards
consideration, which is presented below:

     Nuclear Management Company has evaluated whether or not a
significant hazards consideration is involved with the proposed
amendment by focusing on the three standards set forth in 10 CFR
50.92, ``Issuance of Amendment.'' The following evaluation supports
the finding that operation of the facility in accordance with the
proposed change would not:
     1. Involve a significant increase in the probability or
consequences of an accident previously evaluated.
     The proposed change to the maximum Allowable Value for the
Variable High Power Trip (VHPT) function in the Technical
Specifications would not change or remove any considerations of
uncertainties from the FSAR [Final Safety Analysis Report]
Chapter
14 Safety Analysis. The methodology that was utilized in determining
the recommended change in the maximum allowable value follows
standard ANSI/ISA-S67.04-1994, ``Setpoints for Nuclear Safety-
Related Instrumentation,'' and NRC Regulatory Guide 1.105,
``Setpoints for Safety-Related Instrumentation,'' Revision 3. With
the proposed changes to the maximum allowable value and calculated
setpoint of the VHPT in place, the reactor is still protected from
reaching the analytical limit of 115% reactor power.
     Therefore, operation of the facility in accordance with the
proposed change to the Technical Specifications would not involve a
significant increase in the probability or consequences of an
accident previously evaluated.
     2. Create the possibility of a new or different kind of accident
from any previously evaluated.
     The proposed changes to the maximum Allowable Value and
Calculated Setpoint for the Variable High Power Trip function in the
Technical Specifications would not change or add a system function.
The proposed change alters the way the uncertainties (including
uncertainties of instrument measurement and calibration) are
accounted for without actually removing uncertainties from the
calculation. This proposed change follows the standard ANSI/ISA-
S67.04-1994 and NRC Regulatory Guide 1.105, Revision 3.
     Thus, this change does not create the possibility of a new or
different kind of accident from any accident previously evaluated.
     3. Involve a significant reduction in a margin of safety.
     The proposed change to the maximum Allowable Value for the
Variable High Power Trip function in the Technical Specifications
would account for all uncertainties in the VHP trip setpoint
calculation, instead of taking them into account in the maximum
allowable value calculation, as is currently done. In addition,
double accounting for nuclear instrumentation uncertainties has been
removed. The uncertainties will still be taken into account in
determining the calculated setpoint based on the maximum allowable
value of the VHPT, in accordance with the standard ANSI/ISA-S67.04-
1994 and NRC Regulatory Guide 1.105, Revision 3. This methodology
continues to assure that the Analytical Limit will not be exceeded.
     Therefore, the proposed change to the Technical Specifications
would not involve a significant reduction in a margin of safety.

     The NRC staff has reviewed the licensee's analysis and, based upon
this review, it appears that the three standards of 10 CFR 50.92(c) are
satisfied. Therefore, the NRC staff proposes to determine that the
amendment request involves no significant hazards consideration.
     Attorney for licensee: Arunas T. Udrys, Esquire, Consumers Energy
Company, 212 West Michigan Avenue, Jackson, Michigan 49201.
     NRC Section Chief: William D. Reckley (Acting).
Nuclear Management Company, LLC, Docket No. 50-255, Palisades Plant,
Van Buren County, Michigan

     Date of amendment request: November 2, 2001.
     Description of amendment request: The proposed amendment would
revise Technical Specification (TS) Table 3.3.1-1, Item 1, ``Variable
High Power Trip'' (VHPT), by increasing the maximum allowable value for
the VHPT from 106.5 percent to 111 percent.
     Basis for proposed no significant hazards consideration
determination: As required by 10 CFR 50.91(a), the licensee has
provided its analysis of the issue of no significant hazards
consideration, which is presented below:

     Nuclear Management Company has evaluated whether or not a
significant hazards consideration is involved with the proposed
amendment by focusing on the three standards set forth in 10 CFR
50.92, ``Issuance of Amendment.'' The following evaluation supports
the finding that operation of the facility in accordance with the
proposed change would not:
     1. Involve a significant increase in the probability or
consequences of an accident previously evaluated.
     The proposed change to the maximum Allowable Value for the
Variable High Power Trip (VHPT) function in the Technical
Specifications would not change or remove any considerations of
uncertainties from the FSAR [Final Safety Analysis Report]
Chapter
14 Safety Analysis. The methodology that was utilized in determining
the recommended change in the maximum allowable value follows
standard ANSI/ISA-S67.04-1994, ``Setpoints for Nuclear Safety-
Related Instrumentation,'' and NRC Regulatory Guide 1.105,
``Setpoints for Safety-Related Instrumentation,'' Revision 3. With
the proposed changes to the maximum allowable value and calculated
setpoint of the VHPT in place, the reactor is still protected from
reaching the analytical limit of 115% reactor power.
     Therefore, operation of the facility in accordance with the
proposed change to the Technical Specifications would not involve a
significant increase in the probability or consequences of an
accident previously evaluated.
     2. Create the possibility of a new or different kind of accident
from any previously evaluated.
     The proposed changes to the maximum Allowable Value and
Calculated Setpoint for the Variable High Power Trip function in the
Technical Specifications would not change or add a system function.
The proposed change alters the way the uncertainties (including
uncertainties of instrument measurement and calibration) are
accounted for without actually removing uncertainties from the
calculation. This proposed change follows the standard ANSI/ISA-
S67.04-1994 and NRC Regulatory Guide 1.105, Revision 3.
     Thus, this change does not create the possibility of a new or
different kind of accident from any accident previously evaluated.
     3. Involve a significant reduction in a margin of safety.
     The proposed change to the maximum Allowable Value for the
Variable High Power Trip function in the Technical Specifications
would account for all uncertainties in the VHP trip setpoint
calculation, instead of taking them into account in the maximum
allowable value calculation, as is currently done. In addition,
double accounting for nuclear instrumentation uncertainties has been
removed. The uncertainties will still be taken into account in
determining the calculated setpoint based on the maximum allowable
value of the VHPT, in accordance with the standard ANSI/ISA-S67.04-
1994 and NRC Regulatory Guide 1.105, Revision 3. This methodology
continues to assure that the Analytical Limit will not be exceeded.
     Therefore, the proposed change to the Technical Specifications
would not involve a significant reduction in a margin of safety.

     The NRC staff has reviewed the licensee's analysis and, based upon
this review, it appears that the three standards of 10 CFR 50.92(c) are
satisfied. Therefore, the NRC staff proposes to determine that the
amendment request involves no significant hazards consideration.
     Attorney for licensee: Arunas T. Udrys, Esquire, Consumers Energy
Company, 212 West Michigan Avenue, Jackson, Michigan 49201.
     NRC Section Chief: William D. Reckley (Acting).


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Alex J. Sagady & Associates  http://my.voyager.net/~ajs/sagady.pdf

Environmental Enforcement, Technical Review, Public Policy and
Communications on Air, Water and Waste/Community Environmental Protection

PO Box 39,  East Lansing, MI  48826-0039
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com
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