Reissued 2/28/80 due to ormnission of Notary'ssworn statement date line not completed.

6(::::;% CORSumBIS_

k n Power

g* ^ Companyyg gp

General Offices: 212 West MecNgan Avenue. Jao son MicNgan 49201. Area Code 517788-0550

February 25, 1980

Director, Nuclear Reactor RegulationAtt Mr Dennis L Ziemann, ChiefOperating Reactors Branch No 2US Nuclear Regulatory CommissionWashington, DC 20555

DOCKET 50-155 - LICENSE DPR-6 -BIG ROCK POINT PLANT - TECHNICALSPECIFICATIONS CHANGE REQUEST:ECCS OPERATING LIMITS

Transmitted herewith are three (3) original and thirty-seven (37) conformedcopies of a request for change to the Technical Specifications of LicenseDPR-6. The proposed change revises operating limits based on Loss of CoolingAccident analysis to be consistent with the new analysis submitted byConsumers Power Company letter dated March 7, 1979. The proposed change alsoincorporates limits for single loop operations as requested by NRC letterdated October 9, 1979.

Also transmitted herewith, in support of the proposed change, find thefollowing attachments:

Exxon Nuclear Company Report XN-NF-79-21, Revision 1, " Big Rock Point LOCAAnalysis Using the Exxon Nuclear Company WREM NJP-BWR ECCS Evaluation Model -MAPLHGR Analysis." This report describes the techniques used in deriving theproposed new limits on Maximum Average Planar Linear Heat Generation Rate(MAPLHGR).

General Electric Company Report dated March 31, 1977, " Big Rock Point PlantSingle-Loop Operation Loss-of-Coolant Accident Analysis for General ElectricFuel in Conformance With 10 CFR 50 Appendix K (Non-Jet Pump Boiling WaterReactor)." This report describes the MAPLHGR limits for single loopoperation.

Exxon Nuclear Company Report dated July 13, 1979, " Big Rock Point LOCA-ECCSAnalysis With Delayed Start of Diesel Drive Spray Pumps." This report showsthat a delay in diesel drive spray pump start from 26.9 seconds used in ExxonReport XN-NF-29-21, Revision 1, to 39.3 seconds does not affect the proposedMAPLHGR limits.

) : 8003110 0 0

g~:30 O CORSumerSP f) power

Companyam =v

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General OMeces: 212 West Michegan Avenue, Jac kson, Michsgan 49201 e Area Code S17 7H8-055o J

February 25, 1980

Director, Nuclear Reactor RegulationAtt Mr Dennis L Ziemann, ChiefOperating Reactors Branch No 2US Nuclear Regulatory CommissionWashington, DC 20555.

DOCATT 50-155 - LICENSE DPR-6 -BIG ROCK POINT PLANT - TECHNICALSPECIFICATIONS CHANGE REQUEST:ECCS OPERATING LIMITS

Transmitted herewith are three (3) original and thirty-seven (37) conformedcopies of a request for change to the Technical Specifications of LicenseDPR-6. The proposed change revises operating limits based on Loss of CoolingAccident analysis to be consistent with the new analysis submitted byConsumers Power Company letter dated March 7, 1979. The proposed change alsoincorporates limits for single loop operations as requested by NRC letterdated October 9, 1979.

Also transmitted herewith, in support of the proposed change, find thefollowing attachments:

Exxon Nuclear Company Report XN-NF-79-21, Revision 1, " Big Rock Point LOCAAnalysis Using the Exxon Nuclear Company WREM NJP-BWR ECCS Evaluation Model -MAPLHGR Analysis." This report describes the techniques used in deriving theproposed new limits on Maximum Average Planar Linear Heat Generation Rate(MAPLHGR).

General Electric Company Report dated March 31, 1977, " Big Rock Point PlantSingle-Loop Operation Loss-of-Coolant Accident Analysis for General ElectricFuel in Conformance With 10 CFR 50 Appendix K (Non-Jet Pump Boiling WaterReactor)." This report describes the MAPLHGR limits for single loop ,

operation..

Exxon Nuclear Company Report dated July 13, 1979, " Big Rock Point LOCA-ECCSAnalysis With Delayed Start of Diesel Drive Spray Pumps." This report showsthat a delay in diesel drive spray pump start from 26.9 seconds used in ExxonReport XN-NF-29-21, Revision 1, to 39.3 seconds does not affect the proposedMAPLHGR limits.

.

2

It has been determined that this proposed change involves a single safetyissue and, accordingly, is classified as Class III pursuant to 10 CFR 170.22.A check for $4,000 is attached.

Timely review and approval of this proposed change would be appreciated.

David P Hoffman (Signed)

David P HoffmanNuclear Licensing Administrator

CC JGKeppler, USNRC

Attachments: Technical Specifications Change RequestMAPLHGR Analysis - ExxonBRP Single Loop Operation LOCA Analysis for GE FuelBRP LOCA-ECCS Analysis With Delayed Start of SprayPumps - Exxon

.

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BIG ROCK POINT

Technical specifications Change Request

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CONSUMERS POWER COMPANYDocket 50-155

Request for Change to the Technial SpecificationsLicense DPR-6

For the reasons hereinafter set forth, it is requested that the TechnicalSpecifications contained in Facility Operating License DPR-6, Docket 50-155,issued to Consumers Power Company on May 1, 1964 for the Big Rock Point Plant bechanged as described in Section I below:

I. CHANGES

A. Change the column headings of Table 1 of Section 5.2.1.(b) to read:

Reloads Reload G Reload ReloadF & Modified F G-1U G-3/G-4

B. Change the following entries in Table 1 of Section 5.2.1.(b) as shown:

Minimum Bundle Figure 1 - - -

Dry Out Time **

Maximum Bundle Figure 2 x 0.95 Figure 2 Figure 2 Figure 2Power, MW

***To be determined by linear extrapolation from Table 2. For opera-tion with only one recirculating loop in service, these limitsshall be reduced by 5 percent for reload F & Modified F and10 percent for other fuel types.

C. Replace Table 2 of Section 5.2.1.(b) with the new Table 2 attached.

D. Delete Figure 1 of Section 5.2.1.(b).

E. Redesignate Fieure 2 of Section 5.2.1.(b) as Figure 1.

F. Redesignate Figure 3 of Section 5.2.1. (b) as Figure 2 and revise thisfigure as attached.

NOTE: Corrected Technical Specifications pages are attached.

II. DISCUSSION-

These changes revise reactor operating limits which are based on the Lossof Coolant Accident (LOCA) analysis required by 10 CFR 50.46 to beconsistent with the new LOCA analysis submitted by Consumers Power Companyletter dated March 7,1979 (Exxon Nuclear Company (ENC) ReportXN-NF-78-53). The derivation of new Maximum Average Planar Linear HeatGeneration Rate (MAPLHGR) limits using this new LOCA analysis is describedin ENC Report XN-NF-79-21, Revision 1, " Big Rock Point LOCA Analysis Usingthe Exxon Nuclear Company WREM NJP-BWR ECCS Evaluation Madel - MAPLHGRAnalysis" which is forwarded herewith. MAPLHGR limits were notrecalculated for General Electric fuel Types F and Modified F since the

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2

existing limits were calculated in 1975 using General Electric integratedblowdown / fuel rod heatup analysis methods. The limits for fuel Types Fand Modified F have not been changed in the proposed new Table 2 fromthose currently included in the Big Rock Point Technical Specifications.

Table 1 is also modified to limit MAPLHGR for operation with a singlerecirculating loop. In this case, MAPLHGR limits are reduced by 5 percentfor GE fuel types and 10 percent for Exxon fuel types. These limits arebased on a single loop Los; of Coolant Accident analysis performed byGeneral Electric and described in a report dated March 31, 1977(attached). This analysis shows that MAPLHGR limits must be reduced by 5percent for GE fuel types, thereby showing that MAPLHGR is relativelyinsensitive to the flow reduction associated with single loop operation.An equivalent analysis has not been performed for Exxon fuel; however,reducing MAPLHGR limits by 10 percent for single loop operation isbelieved to be quite conservative based on the insensitivity to flow shownby the GE analysis.

The proposed changes include deletion of dry out time limits for ENC fueltypes (G, G-lU and G3/G4). The dry out time limits currently included inthe Technical Specifications resulted from previous ENC methodology forperforming LOCA analyses. The WREM NJP-BWR ECCS Evaluation Model used indeveloping the proposed limits explicitly calculates fuel dry out timeusing the RELAP4-EM and HUXY computer codes Fuel dry out is primarilyrelated to the bundle peaking factor at the initiation of the event;accordingly, a conservatively high radial peaking factor of 1.4(corresponding to a bundle power of 4.0 MW ) was used in the beatupanalysis. The proposed Figure 2 has been modified to reflect this peaking-

factor limit.

To assure that available emergency core cooling system core spray flow isadequate to remove decay heat, Amendment 26 to the Big Rock PointTechnical Specifications added limits on bunale thermal power. Asdiscussed in Consumers Power Company letter dated March 28, 1979, theselimits were calculated using the decay heat present at the earliest timefor which rated core spray was assumed in the LOCA analysis. This timeis increased in the analysis reported in KN-NF-78-53 to 26.9 seconds fromthe 20.4 seconds used as the basis for bundle thermal power limits. Thereduction in decay heat fraction from 20.4 seconds to 26.9 seconds issufficient to permit an increase in bundle power limits of 4.69 percentwhile maintaining the same safety margin. Proposed Figure 2 has beenrevised to increase bundle thermal power limits by 4.69 percent for allcore bundles not otherwise limited to 4.0 MW by the radial peaking factor

tassumption discussed above. Since GE fuel types (F and Modified F) were -

not reanalyzed, bundle thermal power limits for these fuel types arelimited to 95 percent of the values in proposed Figure 2.

Also, as an attachment find Exxon Nuclear Company, Inc Report datedJuly 13, 1979 which describes the results of a " Big Rock Point LOCA-ECCSAnalysis With Delayed Start of Diesel Drive Spray Pumps." This reportshows that the MAPLHGR limits established in Report XN-NF-29-21,Revision 1 (attached), remain valid when maximum allowed start time forthe diesel-driven spray pump is increased from 20 to 45 seconds. Based onthese results, the acceptance criteria for the weekly diesel generator

3

start test at the Big Rock Point Plant will be relaxed to 39.3 secondsfrom the 26.9 seconds used in Report XN-NF-78-53 (attached).

This change also corrects an editorial error in that the dry out timelimits for different fuel types were previously referenced to the wrongfigure by Table 1. The limits have been applied correctly duringoperation.

This change also deletes limits for fuel Type J-2 since this fuel type isnot expected to be used in future cycles at Big Rock Point.

III. CONCLUSION

Based on the foregoing, both the Big Rock Point Plant Review Committee andthe Safety and Audit Review Board have concluded that this change isacceptable from a safety standpoint.

CONSUMERS POWER C0!!PANY

By R B DeWitt (Signed)R B DeWitt, Vice President

Nuclear Operations

Sworn and subscribed to before me this 25th day of February 1980.

Linda K Carstens (Signed)Linda K Carstens (SEAL)

Notary Public, Jackson County, MichiganMy commission expires June 10, 1981.

.

TABLE 1

Reloads: Reload ReloadF & Modified F Reload G G-1U G-3/G-4

Minimum Critical Heat Flux Ratioat Normal Operating Conditions * 3.0 3.0 3.0 3.0

Minimum Bundle Dry Out Time ** Figure 1 - - -

Maximum Heat Flux at Overpower,Btu /h-Ftz 500,000 395,000 407,000 392,900

Maximum Steady State Heat Flux,Btu /h-Ft2 410,000 324,000 333,600 322,100

Maximum Average Planar LinearHeat Generation Rate, SteadyState, kW/Ft*** Table 2 Table 2 Table 2 Table 2

Maximum Bundle Power, MW Figure 2 x 0.95 Figure 2 Figure 2 Figure 2e

Stability Criterion: MaximumMeasured Zero-to-Peak FluxAmplitude, Percent of AverageOperating Flux 20 20 20 20

Maximum Steady State PowerLevel, MW 240 240 240 240e

Maximum Value of Average CorePower Density @ 240 MW , kW/L 46 46 46 46

Nominal Reactor Pressure DuringSteady State Power Operation, Psig 1,335 1,335 1,335 1,335

Minimum Recirculation Flow RateLb/h 6 x 106 6 x 106 6 x 106 6 x 106

Rate-of-Change-of-Reactor-Power During Power Operation:

Control rod withdrawal during power operation shall be such that the average rate-of-c'ange-of-reactor power is less than 50 MWe per minute when power is less than120 c;W , less than 20 MWe per minute when power is between 120 MW and 200 MW , ande e e10 MWe per minute when power is between 200 MW and 240 MW ..

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*The bundle Minimum Critical Heat Flux Ration (MCHFR), based on the Exxon NuclearCorporation Synthesized Hench-Levy Correlation, must be above this value.

**The actual dry out time for GE 9x9 fuel (based on the General Electric Dry OutCorrelation for non-jet Pump Boiling Water Reactors, KEDE-20566) should be abovethe dry out time shown in Figure 1.

***To be determined by linear extrapolation from Table 2. For operation with onlyone recirculating loop in service, these limits shall be reduced by 5 percentfor Reloads F and Modified F and 10 percent for other fuel types.

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TABLE 2

MAPLHGR (kW/FT) LIMITS

PlanarAverage Exposure Reload Reload Reload

(MWD /STM) Modified F Reload F Reload G G-1U G-3/G-4

0 7.21- - - -

200 9.5 9.4 - - -

360 - - - - 7.621,000 7.95- - - -

1,630 7.56 7.81- - -

3,810 - - - 7.57 -

3,900 7.65- - - -

5,000 9.9 9.7 - - -

6,440 7.28- - - -

6,620 7.50 7.48- - -

10,000 9.9 9.7 - - -

1 ,880 - - 7.17 - -

13,520 - - - - 7.4913,610 - - - 7.56 -

15,000 9.8 9.6 - - -

19,050 - - 7.11 - -

20,000 8.7 8.6 - - -

20,320 7.56- - - -

20,870 - - - 7.78 -

24,580 - - 6.84 - -

25,000 8.4 8.3 - - -

26,400 - - - - 7.3226,760 7.64- - - -

28,210 - - 6.08 - -

31,210 - - - - 6.7333,020 7.12 -

- - -

33,380 - - - - 6.6934,470 - - 5.73 - -

36,290 5.73- - - -

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GENERATION RATE G(KW/FT)

FIGURE 1

FUNCTir'l T(0) FOR GE S X 0 FUEL, 0?!ER '/010 REL.\T 10N'

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2.30 3.22 3.22 3.22 3.22 2.30

3.69 h.00 h.00 h.00 h.00 3.69

2.30 3.69 h.00 h.00 3.9h 4.00 k.00 h.00 3.63 2.30

3.22 h.00 h.00 h.00 h.00 h.00 h.00 h.00 h.00 3.22

3.22 h.00 h.00 h.00 h.00 h.00 h.00 h.00 h.00 3.22

3.22 h.00 h.00 h.00 h.00 h.00 h.00 h.00 h.00 3.22

3.22 h.00 h.00 h.00 h.00 h.00 h.00 h.00 h.00 3.22

2.30 3.69 h.00 h.00 h.00 h.00 h.00 h.00 3.69 2.30

3.69 h.00 h.00 h.00 h.00 3.69

2.30 3.22 3.22 3.22 3.22 2.30

Figure 2

Maximum Bundle Power, W

.'

XN-NF-79-21Revision 1Issue Date: 04/09/79

BIG ROCK POINT LOCA ANALYSIS

USING THE EXXON NUCLEAR COMPANY WREM

NJP-BWR ECCS EVALUATION MODEL

MAPLHGR ANALYSIS

Prepared by

P. J. ValentineS. E. JensenG. C. Cooke

/14,5

Concur: / M- 4/-19K. P. fa braith, ManagerNuclear} Safety Engineering

Concu h bV-2 yg'MafgerG. A. So[8els Engineering

e rNuclear 4

Y ky. MW[+ //E '7v#Concur:. /

G. J.vBusselman, ManagerContract Performance

'/1Y }N|'is ) / f'

h/[/29IApproved: // /u ;

R.INilson', Manager ' /(" Licensingi

DUPLICATE DOCUMENTE N NUCLEntire document previouslyentered into system under:

hANO

No. of pages:,

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-.

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BIG ROCK POINT ?LA'.iT

SINGLE-LOOP OPERATION

LOSS-OF-COOLANT ACCIDE:iT 12iALYSIS

FOR GFl!ERAL ELECTRIC IVEL

IN CONF 0P3) lice 'JITF.10CF?d0 APPEIDII E

(NO.Y-JET PUMP SOILING L'ATER REACIOR)

.

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HARCH 31, 1977

GENERAL ELECTRIC COM?.UTI

h. D

DUPLICATE DOCUMENT

Entire document previouslyentered into syste. unde -

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3 ' ' j'l 'IANO

N o. of pages: /h ''! ' us'

g ,

.

Exxon Nuclear Company, Inc

Report to

Consumers Power Company

July 13, 1979

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DUPLICATE DOCUMENT

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M-U)dC - '- f)/entered into s stem under:

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No. of pages: