ML18054B051
| ML18054B051 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/13/1989 |
| From: | Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18054B048 | List: |
| References | |
| GL-89-01, GL-89-1, NUDOCS 8910260182 | |
| Download: ML18054B051 (6) | |
Text
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 - Discussion The Technical Specifications changes proposed below are in accordance with Generic Letter 89-01 and consistent with the Nuclear Regulatory Commission's Interim Policy Statement on Technical Specifications Improvements.
Programmatic controls are revised and retained in the Administrative Controls section of the Technical Specifications to satisfy the regulatory requirements of 10CFR20.106, 40CFR190, 10CFR50.36a and 10CFR50 Appendix I.
Procedural details in the present Technical Specifications on radioactive effluents, solid radioactive wastes, environmental monitoring and associated reporting requirements are relocated to :the ODCM or PCP as appropriate.
Definitions for the ODCM and PCP have been updated.
Other definitions have been relocated to the ODCM for consistency with relocation of the present Technical Specifications procedural requirements.
The Specific Technical Specifications changes are:
A.
Change Table of Contents as indicated on attached page changes (pages iii, iv, v, vi and vii) to reflect the removal of the Radiological Effluents Technical Specifications (RETS) procedural requirements.
1 B.
Revise definit~ons for OFFSITE DOSE CALCULATION MAJ\\TUAL (ODCM) and PROCESS CONTROL PROGRAM (PCP) per Generic Letter 89-01 as indicated on attached page changes (page 1-6) and delete definitions for GASEOUS RADWASTE TREATMENT SYSTEM, and VENTILATION EXHAUST TREATMENT SYSTEM, as they are no longer used in the Technical Specifications.
C.
Delete Section 3.24, and Bases (redlined pages 3-114 through 3-133) and relocate to ODCM and PCP per GL 89-01 (Sections 3.24.1,.2,.3,
.4,.5,.6, and.8 to ODCM and 3.24.7 to PCP).
In Table 3.24-2, item 3a, remove RlA-2318 as it has been removed from the plant (Table 3.24-2 relocated to ODCM, Appendix A, Table A-1).
D.
Delete Note on item 4 of Table 4.1.3 which is no longer applicable as the_Tables 4.24-1 and 4.24-2 have been removed (see item G below).
OC0989-0196-NL04 8910260182 891013 PDR ADOCK 05000255 P
PNU
2 E.
Delete item 6, "Environmental Monitors" on Table 4.1.3 and relocate requirement to ODCM.
The relocation of these surveillance requirements are consistent with GL 89-01.
F.
Delete Section 4.ll_including TABLES 4.11-1, 4.11-2, 4.11-3 and Bases Sections 4.11.1, 4.11.3, and 4.11.5 (redlined pages 4-47 through 4-59a) and relocate to ODCM per GL 89-01.
G.
Delete Section 4.24 including TABLES 4.24-1, 4.24-2, 4.24-3, and 4.24-5 (redlined pages 4-90 through 4-98) and relocate to ODCM and PCP (Sections 4.24.1,.2,.3,.4,.5, and.8 to ODCM and 4.24.7 to PCP).
Table 4.24-1 (relocated to ODCM, Appendix A, Table C-2) item 3a the quarterly functional test of the liquid radwaste effluent line has been deleted since the controller has no functional requirements.
H.
I.
Item 6 on Table 4.24-1 (relocated to ODCM, Appendix A, Table C-2),
steam generator blowdown effluent compositor, has been added.
In Table 4. 24-3 (relocated to ODCM Appendix A, Table D-1), footnote f has been modified to clearly reflect the sampling method used.
Change Section 6.8 heading to "PROCEDURES AND PROGRAMS".
Add new Sections 6.8.4a "Radioactive Effluent Controls Program" and 6.8.4.b "Radiological Environmental Monitoring Program" as specified in Generic Letter 89-01 and as indicated on attached page changes (pages 6-11, 6-12 and 6-13).
Pages 6-11 and 6-12 have been renumbered to 6-14 and 6-15.
Change Section 6.9.3.lA to "Semiannual Radioactive Effluent Release Report" as specified in Generic Letter 89-01.
Place details of old section (redlined pages 6-18 through 6-24) in ODCM and PCP.
Change the reporting interval from 60 to 90 days after January 1 and July 1 (see page 6-18).
Section 6.9.3.lA has been modified to be like that for the semiannual radioactive effluent release reporting requirements in GL 89-01 except that the report submittal date has been changed from 60 to 90 days after January 1 and July 1 of each year.
This change is to allow incorporation of the actual calculated strontium (Sr-89 and Sr-90) release quantities which are provided by a contracted laboratory and which, in the past, have been estimated and then later corrected as the contract laboratory cannot meet the 60-day reporting requirement.
An exemption from the 60-day requirement, of 10CFR50.36a(a)2., pursuant to 10CFR50.12 is therefore requested since it is believed that special circumstances described in 10CFR50.12(a)(2)(ii) and (a)(2)(v) are present in that the 60 days reporting requirement is not necessary to achieve the underlying purpose of the rule which is to provide a complete reporting of the Palisades' radioactive effluent releases.
Furthermore, the exemption OC0989-0196-NL04
3 to the 60-day report to 90 days would only provide schedular relief from the applicable regulation and not totally exempt the requirement.
Consumers Power Company has made good faith efforts to obtain contractor results within the 60-day reporting time frame, however the contractor has consistently not been able to meet that time frame.
This inability to meet the 60-day reporting requirement is not unique to our contractor, therefore, changing contractors would not aleviate the need for a schedular exemption.
J.
Change Section 6.9.3.lB "Annual Radiological Environmental Operating Report" as specified in Generic Letter 89-01.
Also, relocate TABLE 6.9-1 which provided an example report format, to ODCM Appendix A (Table F.1)
- K.
Revise 6.9.3.2 "Nonroutine Reports" to indicate requirements are now in ODCM and not in TS Section 4.11.
(See attached page changes, page 6-18).
L.
Add new Section 6.10.20 that states "Records of reviews for changes made to OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM", per GL 89-01, providing record retention requirements (see attached page changes, page 6-28)
- M.
Revise 6.18 "OFFSITE DOSE CALCULATION MANUAL" and 6.19 "PROCESS CONTROL PROGRAM" per Generic Letter 89-01 as indicated Qn attached page changes (See attached page changes, see page 6-35).
These reflect revisions in the documentation, reviews and methods for changing the ODCM and PCP.
N.
Delete Section 6.20 (redlined page 6-36) and relocate requirement to the ODCM and PCP in accordance with GL 89-01.
A change for the reporting requirement from a special report to that consistent with 10CFR50.59 has been made in the now administratively controlled program.
The change of the reporting requirement for major modifi-cation to the radioactive treatment systems via a special report to annual reporting via 10CFR50.59 requirement is consistent with that presently incorporated in the Big Rock Point Technical Specifications, Docket 50-155.
This change is consistent with 10CFR50.59 and removes an administrative reporting requirement that is unduly restrictive and not a requirement of 10CFR50.36a.
Analysis of No Significant Hazards Consideration NRC Generic Letter 89-01 provides for retention of the programmatic controls for Radiological Effluent Technical Specifications (RETS) in the Administrative Control Section of the Technical Specifications and the relocation of procedural details of RETS to the ODCM or to the PCP.
Minor changes consistent with those described in the Generic Letter are also included in the proposed changes in the TS, ODCM, and PCP.
Procedural requirements related to gaseous and liquid effluents, total dose, environmental monitoring program, and OC0989-0196-NL04
associated reporting requirements were relocated to the ODCM.
Procedural requirements related to solid radwaste were relocated to the PCP.
Program-4 matic controls revised and retained in the TS include requirements for establishment, implementation, maintenance and changes to the ODCM and PCP as well as record retention and reporting requirements.
A change other than the relocation of requirements is also requested.
The requested change will increase the 60-day reporting requirement for the semiannual effluent release report to 90-days.
A contractor laboratory presently does not have adequate time to obtain samples and calculate the release quantities of Sr-89 and Sr-90 during the 60-day reporting period.
The change to 90-days will allow adequate time to include the results in the report and achieves the purpose of the report to provide complete effluent releases.
This change also requires an exemption from the 60-day reporting requirement of 10CFR50.36a(a)2.
An exemption is permitted by 10CFR50.12 and is requested since the underlying purpose of the rule will still be met.
Several changes have been made to the ODCM as described below.
The most significant of these changes would modify the requirement, relocated to the administratively controlled ODCM and PCP, to report major modifications of the radioactive waste treatment systems in a special report to the NRC.
The proposed change (see page 50 of the ODCM, Appendix A) will require modifica-tions be reported in the annual report pursuant to 10CFR50.59.
Such a change is consistent with the present Big Rock Point Technical Specifications where it was identified and agreed to th~t the special report requirement is not required by 10CFR50.36a or 10CFR50.59.
In the ODCM Appendix A, Table A-1 (p.4), present Technical Specifications Table 3.24-2, item 3.a.
RIA 2318 has been deleted as it has been physically removed from the plant.
The remaining RIA 2326 has been upgraded and meets R.G. 1.97 requirements.
On table C-2 of the ODCM, Appendix A (p.19), present Technical Specifications Table 4.24-1, item 3.a.
The Quarterly functional test of the liquid radwaste effluent line (FlC 1051 or 1050) has been deleted since the controller has no functional requirements.
On the same table, C-2, a new item 6, steam generator blowdown effluent compositor, has been added.
In the ODCM, Appendix A, Table D-1, Table Notation (p.24), present Technical Specifications Table 4.24-3, footnote f has been modified to more clearly reflect the sampling method used.
This change has been previously discussed with the NRC.
Since the changes are administrative in nature which do not lessen the radiological effluent monitoring program at Palisades, and only minor changes being made to the reporting requirements, the proposed changes to the Technical Specifications, ODCM, and PCP described above do not affect the probability or consequences of an accident previously evaluated.
There is also no possibility of an accident or malfunction of a new or different type than previously evaluated having been created due to these administrative changes.
- Finally, OC0989-0196-NL04
- there is no affect on the margin of safety as defined in the basis for any Technical Specifications due to these administrative program changes to the radiological effluent monitoring program.
III.
Conclusion 5
The Palisades Plant Review Connnittee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and, therefore, involves no significant hazards consideration.
This change has been reviewed by the Nuclear Safety Services Department.
A copy of this Technical Specific-ation Change Request has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.
CONSUMERS POWER COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete *
. ~.90.
David P Hoffman, e
Nuclear Operations Sworn and subscribed to before me this 13th day of October, 1989.
~~~
/J{A_(fkJ Elaine E Bue1irer, Notary Public Jackson County, Michigan My connnission expires October 31, 1989 OC0989-0196-NL04
ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 PROPOSED TECHNICAL SPECIFICATIONS PAGE CHANGES October 13, 1989 17 Pages TSP0689-0146-NL04