ML18054B532

Application for Amend to License DPR-20,deleting Assignment of Functional Responsibility for Industry Operating Experience Review Program from Tech Specs

ML18054B532
Person / Time
Site:	Palisades
Issue date:	04/02/1990
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18054B533	List: ML18054B532 ML18054B534
References
TAC-76156, NUDOCS 9004110082
Download: ML18054B532 (4)

Text

consumers Power - Kenneth W Berry Director POWERiNii Nuclear licensing NllCHlliAN'S PROliRESS General Offices: 1945 West Parnall Road, Jackson, Ml 49201 * (517) 788-1636 April 2, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -

TECHNICAL SPECIFICATION CHANGE REQUEST - EDITORIAL CORRECTIONS (TAC NO 76156)

Enclosed is a Technical Specification Change Request which proposes editorial corrections and changes to bring Palisades Technical Specifications in line with the current plant organization. The change proposes to delete assignment of the functional responsibility for the Industry Operating Experience Review Program from the Technical Specifications.* It is Consumers Power Company's intent to maintain responsiblity for this program under the Palisades Plant General Manager. The FSAR will be revised to reflect this responsibility.

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\)_ - Kenneth W Berry 0 Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades Attachments

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OC0390-0305-NL04 A CMS' ENERGY COMPANY

1 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 the Technical Specifications contained in Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for Palisades Plant be changed as described in Section I below:

I. Changes A. Change the first "SV-2412B" for penetration 40B in Table 3.6.1 to "SV-2412A".

B. Change "4.20" to 4.21" at the end of Section 3.25.1.

C. Revise Section 6.5.3.1 to read as follows:

"6.5.3.1 FUNCTION The Plant Safety and Licensing organization shall function to examine proposed changes in design or operation and such other matters as the PRC may assign to identify issues significant to nuclear safety and recommend nuclear safety improvements."

D. Change "NSB" to "NSSD" at the end of Section 6.10.2.i by deleting "NSB" and adding "reviews performed by NSSD".

II.* Discussion Proposed change A corrects a typographical error made during the issuance of Amendment 128 dated September 5, 1989.

Proposed change B corrects a typographical error made during the issuance of Amendment 122 dated Ma~ 19, 1989.

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Proposed change C is requested to lrring Palisades Technical Specifications in line with the cuyrent plant organization. When the current Technical Specification wording was approved by the NRC in Amendment 127 dated August 16, 1989, the program to examine nuclear industry operating experience was to be the responsibility of the Plant Safety and Licensing organization. Since that time the responsibility for this program has been reassigned to a newly created organizational unit under the Engineering and Maintenance Manager.

TSP0390-0305-NL04

2 With respect to the examination of nuclear industry operating experience, it is not relevent whethe'r this responsibility is assigned to Plant Safety and Licensing or another organization. It is also not required that Technical Specifications assign this responsibility. As stated in the NRC Safety Evaluation for Amendment 127, Palisades is not required to have an Independent Safety Engineering Group (ISEG). One of the functions of ISEG, as stated in draft Combustion Engineering Standard Technical Specifications, is to examine operating experience information. Accordingly, it is proposed that all reference to the function to examine industry operating experience be deleted from the Palisades Technical Specifications.

It should be emphasized that deletion of a Technical Specification reference requiring examination of industry operating experience does not imply the function is being eliminated. Consumers Power Company recognizes this function offers the potential for both safety and financial benefits, and its elimination would be inadvisable. It is our intent to maintain this function within the organizational structure.

Elimination of reference to this function from the Technical Specifications is also consistent with the intent of the NRC's Technical Specification improvement program to remove organization charts (Generic Letter 88-06) from the Technical Specifications. It allows management flexibility to assign this responsibility as the needs of the organizational structure change.

Proposed change D corrects an oversight made during the issuance of Amendment 127 dated August 16, 1989.

III. Analysis of No Significant Hazards Consideration These changes as proposed are editorial in nature. Proposed change C will have no practical impact on examination of industry operating experience or safety review functions at the plant or offsite.

Assigning the responsibility for industry operating experience review to the Engineering and Maintenance Manager provides more direct feedback to the affected organizations. The changes have no effect on the probability of occurrence or consequences of an accident, nor has the possibility of an accident or malfunction of a different type been created because they do not effect the plant configuration nor the plant operating requirements.

The margin of safety as defined in the basis for the Technical Specifications will not be affected because no margin of safety is defined for the Administrative Controls Section of the Technical Specifications, and the proposed changes are editorial corrections.

TSP0390-0305-NL04

3 IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined 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 Specification 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 Technical Specification Change Request are truthful and complete.

By~p~~e-n_t _ __

Nuclear Operations Sworn and subscribed to before me this 2nd day of April 1990.

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Elaine E Buehrer, Notary Public Jackson County, Michigan My commission expires October 11, 1993 TSP0390-0305-NL04