ML033030121

Issuance of License Amendment Regarding Administrative Controls Section of the Technical Specifications

ML033030121
Person / Time
Site:	Palisades
Issue date:	12/15/2003
From:	Hood D NRC/NRR/DLPM/LPD3
To:	Domonique Malone Nuclear Management Co
References
TAC MB8755
Download: ML033030121 (10)

Text

December 15, 2003 Mr. Daniel J. Malone Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT:

PALISADES PLANT - ISSUANCE OF AMENDMENT REGARDING ADMINISTRATIVE CONTROLS SECTION OF THE TECHNICAL SPECIFICATIONS (TAC NO. MB8755)

Dear Mr. Malone:

The Commission has issued the enclosed Amendment No. 213 to Facility Operating License No. DPR-20 for the Palisades Plant. This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated April 11, 2003.

The amendment revises TS Section 5.0, Administrative Controls, to make various administrative, editorial, and typographical changes.

Your application also proposed a change to TS 5.6.1 to change 100 mrem to 100 mrems.

We find that use of the plural form of mrem is optional, and also inconsistent with the use of the term elsewhere in the Palisades TSs and other documents such as the Final Safety Analysis Report and the Offsite Dose Calculation Manual. Therefore, we have not approved this proposed change.

A copy of our related safety evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Darl S. Hood, Senior Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-255

Enclosures:

1. Amendment No. 213 to DPR-20

2. Safety Evaluation cc w/encls: See next page

ML033490630 (Package)

ML033030121 (Amendment)

ML033490585 (TS)

Palisades Plant cc:

Robert A. Fenech, Senior Vice President Michigan Department of Attorney General Nuclear, Fossil, and Hydro Operations Special Litigation Division Consumers Energy Company 525 West Ottawa St.

1945 Parnall Rd. Sixth Floor, G. Mennen Williams Building Jackson, MI 49201 Lansing, MI 48913 Arunas T. Udrys, Esquire Manager, Regulatory Affairs Consumers Energy Company Nuclear Management Company, LLC 1 Energy Plaza 27780 Blue Star Memorial Highway Jackson, MI 49201 Covert, MI 49043 Regional Administrator, Region III Director of Nuclear Assets U.S. Nuclear Regulatory Commission Consumers Energy Company 801 Warrenville Road Palisades Nuclear Plant Lisle, IL 60532-4351 27780 Blue Star Memorial Highway Covert, MI 49043 Supervisor Covert Township John Paul Cowan P. O. Box 35 Executive Vice President & Chief Nuclear Covert, MI 49043 Officer Nuclear Management Company, LLC Office of the Governor 700 First Street P. O. Box 30013 Hudson, WI 54016 Lansing, MI 48909 Jonathan Rogoff, Esquire U.S. Nuclear Regulatory Commission Vice President, Counsel & Secretary Resident Inspector's Office Nuclear Management Company, LLC Palisades Plant 700 First Street 27782 Blue Star Memorial Highway Hudson, WI 54016 Covert, MI 49043 Douglas E. Cooper Michigan Department of Environmental Quality Senior Vice President - Group Operations Waste and Hazardous Materials Division Palisades Nuclear Plant Hazardous Waste and Radiological Nuclear Management Company, LLC Protection Section 27780 Blue Star Memorial Highway Nuclear Facilities Unit Covert, MI 49043 Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 October 2003

NUCLEAR MANAGEMENT COMPANY, LLC DOCKET NO. 50-255 PALISADES PLANT AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 213 License No. DPR-20

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Nuclear Management Company, LLC (the licensee), dated April 11, 2003, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public; and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to the license amendment and Paragraph 2.C.(2) of Facility Operating License No. DPR-20 is hereby amended to read as follows:

The Technical Specifications contained in Appendix A, as revised through Amendment No. 213 , and the Environmental Protection Plan contained in Appendix B are hereby incorporated in the license. NMC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of issuance and shall be implemented within 60 days.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

L. Raghavan, Chief, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: December 15, 2003

ATTACHMENT TO LICENSE AMENDMENT NO. 213 FACILITY OPERATING LICENSE NO. DPR-20 DOCKET NO. 50-255 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 5.0-5 5.0-5 5.0-7 5.0-7 5.0-24 5.0-24

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATING TO AMENDMENT NO. 213 TO FACILITY OPERATING LICENSE NO. DPR-20 NUCLEAR MANAGEMENT COMPANY, LLC PALISADES PLANT DOCKET NO. 50-255

1.0 INTRODUCTION

By application dated April 11, 2003, the Nuclear Management Company, LLC (the licensee),

requested changes to the Technical Specifications (TSs) for the Palisades Plant. The proposed amendment would revise TS Section 5.0, Administrative Controls, to make various administrative, editorial, and typographical changes. Specifically, the proposed changes would:

(1) correct TS 5.4.1.a by adding Appendix A after the reference to Regulatory Guide 1.33, Revision 2, and deleting of before this reference.

(2) change TS 5.5.2.e by deleting the phrase (approximately 44 psig) which is an invalid reference to the normal hydrostatic head from the safety injection refueling water tank for the test conditions required for maximum allowable leakage from recirculation heat removal systems components.

(3) make several editorial changes to TS 5.6.1 to be consistent with the wording of NUREG-1432, Standard Technical Specifications-Combustion Engineering Plants, Revision 2 (STS), and the changes to the STS in Technical Specification Task Force (TSTF) Traveler TSTF-152, "Revise Reporting Requirements to be Consistent with 10 CFR [Part] 20." The editorial changes include (a) adding the word collective to describe the associated collective deep dose equivalent, (b) adding thermoluminescence dosimeter to define its acronym (TLD), (c) changing stations to station, (d) adding the words received from when describing the 80 percent of total deep dose equivalent received from external sources, and (e) making punctuation changes.

In its application, the licensee also proposed to change 100 mrem to 100 mrems in TS 5.6.1.

The Nuclear Regulatory Commission (NRC) staff finds that use of the plural form of mrem is optional, and also inconsistent with the use of the term elsewhere in the Palisades TSs and other documents such as the Final Safety Analysis Report and the Offsite Dose Calculation Manual. Therefore, the NRC staff has not approved this proposed change.

2.0 REGULATORY EVALUATION

The changes to TS 5.6.1 were proposed, in part, to conform to the wording of TSTF-152. The NRC staff approved TSTF-152 on March 13, 1997. Therefore, the April 11, 2003, application constitutes a request for TS changes, to the extent applicable to the Palisades Plant, that the NRC staff has previously approved generically for the Combustion Engineering Standard Technical Specifications, NUREG-1432, Revision 2. The licensee also included other minor changes to TS 5.6.1 for consistency with the wording in NUREG-1432, Revision 2.

3.0 TECHNICAL EVALUATION

TS 5.4.1 describes the administrative controls for written procedures. TS 5.4.1 currently contains two editorial errors that were introduced by the licensees license amendment application dated December 7, 2000, which forwarded a revised TS page for use to this end.

Within Regulatory Guide (RG) 1.33, Quality Assurance Program Requirements (Operation),

Revision 2, dated February 1978, typical safety-related activities that should be covered by written procedures are listed in Appendix A of RG 1.33, rather than in the main body of RG 1.33. The revised TS page failed to include the term Appendix A when describing applicable procedures recommended in this RG, and also inadvertently included the word of before Regulatory Guide 1.33" (i.e., ...applicable procedures recommended in of Regulatory Guide 1.33.... ). The NRC staff used this TS page containing the two errors when issuing Amendment No. 196, dated May 3, 2001. The changes proposed in the April 11, 2003, application would correct these editorial errors by adding Appendix A and deleting of. The NRC staff finds that the more specific reference to the RG is appropriate, and that deleting of in this specification is purely an editorial correction. These two corrections have no adverse effect upon the safety of the facility and are therefore acceptable.

TS 5.5.2.e describes the maximum allowable leakage criteria from the recirculation heat removal systems components under the normal hydrostatic head from the SIRW tank.

TS 5.5.2.e currently indicates that this normal hydrostatic head is (approximately 44 psig).

The licensee notes that this approximate value is erroneous and is not a credible value for any of the components (located at various elevations) covered by this specification. The various elevations of the components covered by this specification result in significant psig differences for component test conditions, such that specifying a single approximate value for the hydrostatic head is not appropriate. The NRC staff finds that the testing program described by TS 5.5.2 is appropriately controlled by plant procedures and is sufficiently characterized in TS 5.5.2 by the reference to normal hydrostatic head from the SIRW tank, without including a specified approximate value. The specified approximate value is not needed in the TS.

Therefore, deleting this erroneous approximate value is appropriate and acceptable.

TS 5.6.1, which describes requirements for Occupational Radiation Exposure Reports, currently contains several errors in wording and punctuation which differ from the licensees intended adherence to TSTF-152 and NUREG-1432, Revision 2. These errors were introduced by the January 26, 1998, application which proposed a license amendment to change TS 5.6.1 and forwarded a revised TS page for use to this end. The NRC staff used the revised TS page to issue Amendment No. 189 on November 30, 1999. These errors included omitting the word collective when describing associated collective deep dose equivalent, omitting thermoluminescence dosimeter to identify its acronym (TLD), using stations for station, and omitting the words received from when describing the 80 percent of total deep dose

equivalent received from external sources. The errors also included some punctuation changes. The NRC staff has reviewed the proposed corrections and finds that they improve consistency with TSTF-152 and NUREG-1432, Revision 2 and are therefore acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: D. Hood Date: December 15, 2003