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Category:CORRESPONDENCE-LETTERS
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML20210G8351999-07-29029 July 1999 Final Response to FOIA Request for Documents.Records in App a Encl & Will Be Available in PDR ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20209B2081999-06-29029 June 1999 Discusses Closure of Response to RAI Re GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity. Rvid,Version 2 Issued as Result of Review of Responses.Info Should Be Reviewed & Comments Submitted by 990901 ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML20203F2541999-02-10010 February 1999 Informs That Beginning 990216,DE Hills Will Be Chief of Operations Branch Which Includes Operator Licensing Function 1999-09-30
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML18066A6871999-10-19019 October 1999 Forwards Response to NRC 990908 RAI Re Inservice Insp Program Relief Request 14.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6881999-10-19019 October 1999 Forwards Rev 5 to Palisades Nuclear Plant COLR, Per Requirements of TS 6.6.5.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A6741999-10-0202 October 1999 Forwards MOR for Sept 1999 for Palisades Nuclear Plant & Operating Data Rept Sheet for Month of Aug 1999.MOR for Aug 1999 Inadvertently Had Copy of Ref Data Sheet for Apr 1999 Data ML18066A6791999-10-0101 October 1999 Provides Response to RAI Re Draft Rept, Study of Air- Operated Valves in Us Nuclear Power Plants. ML18066A6621999-09-30030 September 1999 Notifies NRC That Util Will Implement ITS at Plant on or Before Oct 31,2000 & Attachments 1 & 2 Contains Request for License Condition Which Relates First Performance of New or Revised Surveillance Requirements to Implementation of ITS ML18066A6601999-09-29029 September 1999 Forwards NRC Form 536,in Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Examinations. ML18066A6471999-09-17017 September 1999 Forwards Final Clean Copies of ITS & Bases Pages Which Incorporate All Changes Proposed in Listed Ltrs.Clean Copies Also Incorporate Some Editorial Changes & Bases Clarifications as Result of Ongoing Reviews to LCOs ML18066A6331999-09-0202 September 1999 Forwards Monthly Operating Rept for Aug 1999 & Revised Monthly Operating Rept for Apr 1999 for Palisades Nuclear Plant ML18066A6261999-08-26026 August 1999 Forwards Addl New Valve Relief Request as Alternative to Code Requirements That Will Provide Acceptable Level of Quality & Safety.Request Would Allow Use of App II, Check Valve Condition Monitoring Program, of ASME OM Code-1995 ML20211D5661999-08-17017 August 1999 Forwards semi-annual Fitness for Duty Program Performance Rept for 990101-990630,IAW 10CFR26.71(d).Attachments 1 & 2 Summarize Test Results at Palisades Plant,Big Rock Point Plant & Corporate Ofc ML18066A6111999-08-13013 August 1999 Requests Exemption from Certain Requirements of 10CFR50,App R, Fire Protection Program for Nuclear Power Facilities Operating Prior to 790101. Request Concerns Oil Collection Sys Requirements for PCP Motors ML18066A5971999-07-30030 July 1999 Forwards Markup of Draft NRC SE Re Util Proposal to Convert to Its.Ltr Contains No New Commitments & No Revs to Existing Commitments ML18066A5881999-07-30030 July 1999 Provides Rev to Instrument Channel Drift Measurement Submitted on 990611,in Response to NRC Comments on Util RAI Response for Sections 3.3,3.5 & 3.6 & Editorial Changes Revs Necessary for Consistency within ITS ML18066A5921999-07-30030 July 1999 Forwards Results of Review by Consumers Energy of Two NRC Draft Repts Entitled, Evaluation of Air-Operated Valves at Light-Water Reactors & Study of Air-Operated Valves in Us Nuclear Power Plants. ML18066A5651999-07-19019 July 1999 Forwards Corrections to Previously Submitted TS Section 3.7, Plant Systems, Converting to Its,Per NUREG-1432.Licensee Realized That Certain Provisions of CTS Had Been Inappropriately Replaced with Provisions from STS ML18066A5111999-06-29029 June 1999 Provides Voluntary Confirmation of Facility Readiness as Outlined in GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Disclosure & Response Encl ML20210G8791999-06-23023 June 1999 FOIA Request for All Document Communications Between NRC & Region III Involving R Landsman,B Jorgensen & R Caniano & NRC Staff Under Their Supervision & All Communications in Their Possession to & from Consumers Power Re Plant ML18066A5061999-06-17017 June 1999 Forwards Responses to NRC Questions for ITS LCOs 3.6.3 & 3.6.6 of 990126 Submittal.One Editorial Change in Addition to Those Made in Response to NRC Comments & Conforming Changes Made to Associated Bases,Encl ML18066A4991999-06-11011 June 1999 Forwards Responses to NRC Comments Re ITS Section 3.3 & Associated Revs to ITS Sections 1.0,3.3,3.4 & 3.9 of 990126 ITS Conversion Submittal.One Technical Change & Several Editorial Changes Unrelated to NRC Comments,Also Provided IR 05000255/19970181999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18066A4921999-06-0909 June 1999 Discusses Response of 980226 Violation Re Insp Rept 50-255/97-18 Re Failure to Take Adequate Corrective Action. Ltr Contains New Commitments & No Rev ML18068A6011999-06-0808 June 1999 Forwards Description of Recent Changes Made to Palisades Site Emergency Plan,Excluding Minor & Editorial Changes Not Requiring Further Explanation ML18066A4881999-06-0404 June 1999 Provides Responses to NRC Questions & Associated Editorial Revs for ITS LCOs 3.6.1,3.6.2,3.6.4,3.6.5 & 3.6.7 of 980126 Submittal.Responses to Comments on Remaining Section 3.6 LCOs Will Be Submitted Separately ML18066A4801999-05-24024 May 1999 Forwards Copy of Rev to NPDES Permit Number MI0001457 Renewal Application as Submitted to Mi Dept of Environ Quality on 990513 ML18066A4721999-05-18018 May 1999 Informs That During Period from 981101-990430,there Were No NPDES Permit Violations & No Repts of Oil,Salt or Polluting Matl Losses Were Made to Govt Agencies ML18066A4651999-05-17017 May 1999 Forwards ISI Program Relief Request 14 for NRC Approval in Accordance with 10CFR50.55(a)(3) as Requirement for Which Proposed Alternative Provide Acceptable Level of Quality & Safety.Rev 0 to SIR-99-032 Rept Also Encl ML18066A4611999-05-14014 May 1999 Requests Approval to Use Alternative Requirements IAW 10CFR50.55a(a)(3)(i),proposing to Follow Requirements of ASME Boiler & Pressure Vessel Code Case N-566-1.IST Program Relief Request 6 for NRC Approval Encl ML18068A5831999-05-0303 May 1999 Forwards Proposed TS Section 3.5,in Response to NRC 990317 RAI Re Util 980126 TS Change Request Re Conversion to Improved Ts,Per NUREG-1432 ML20206J2411999-04-30030 April 1999 Submits Corrected Copy of Ltr Forwarding 1998 Consumers Energy Co Annual Rept. Ltr Contains Corrected Docket & License Number for Big Rock Point.With One Oversize Encl ML20217A8191999-04-29029 April 1999 Forwards Listed Matls Related to Palisades Plant June 1999 Initial License Exam ML20206E8271999-04-28028 April 1999 Forwards Palisades Plant Annual Radiological Environ Operating Rept for 1998. There Were No Reportable Events During This Period ML20207B4661999-04-23023 April 1999 Forwards Copy of Final Exercise Rept for Biennial Radiological Emergency Preparedness Exercise Conducted on 981201 for Palisades Npp.No Deficiencies Noted.Seven New Arcas Identified ML18066A4531999-04-0707 April 1999 Forwards ITS Pages 3.1.4-2 & 3.1.4-8,revising Completion Time for Action D.1,as Requested by NRC 990406 Telcon,Per TS Change Request Submitted 980126.Change Submitted Does Not Alter Conclusions of No Signficant Hazards Considerations ML18066A4481999-04-0202 April 1999 Responds to Violations Noted in Insp Rept 50-255/98-06. Corrective Actions:Nuclear Performance Assessment Dept Has Reviewed Observations & Agrees That Field Observations by Qualified Personnel Are Important Aspect of Program ML18066A4471999-03-30030 March 1999 Confirms Completion of Util Review of Design Engineering Contractor Cable Ampacity Evaluation.Evaluation Available at Plant for NRC Review ML18066A4411999-03-30030 March 1999 Forwards Response to NRC 990126 RAI Re TS Section 3.7 of Util 980126 LAR Request for Conversion to Its.Licensee Received Permission to Delay TS Section 3.6 Response to Allow for Addl Time for Preparation & Internal Review ML18066A4441999-03-26026 March 1999 Submits Certification of Financial Assurance for Decommissioning of Palisades Nuclear Plant.Certified Rept of Status of Consumers Energy Co Decommissioning Funding & Trust Agreement Encl as Attachments 1 & 2 ML18066A4401999-03-25025 March 1999 Forwards Revised Best Estimate Fluence Evaluation Using Industry Data, Providing Justification for Using Industry Data to Determine Best Estimate Fluence.Review of Info & SE Requested ML18066A4191999-03-23023 March 1999 Forwards 1998 Annual Radioactive Effluent Release & Disposal Rept, for Palisades Plant,Providing Summary of Quantities of Radioactive Liquid & Gaseous Effluent Releases & Solid Radioactive Waste Processed During 1998 ML18066A4231999-03-22022 March 1999 Forwards Answers to 990311 Telcon Request for Addl Clarification & Revs Re ITS Section 3.4.Markups of Previously Submitted TS Pages & Revised Pages for Section 3.4 Also Encl ML20204F2091999-03-18018 March 1999 Requests That Listed TS Change Requests (Tscrs) Be Issued with Allowance That Tscrs Be Fully Implemented within Sixty Days of Issuance.Request Will Allow Time for Completion of Final Training & Procedure Changes Associated with Amend ML18066A4141999-03-18018 March 1999 Forwards Rev 4 to COLR, Containing Limits for Fuel Cycle 14 & Future Cycles ML18066A4121999-03-18018 March 1999 Concludes That Mod to Provide Automatic Switchover of Control Room Heating,Ventilation & Air Conditioning (CRHVAC) Sys to Emergency Mode Is Not Needed to Meet Regulatory Requirements.Mod Commitment Cancelled ML20204E5861999-03-16016 March 1999 Submits Current Limits of Property Insurance Maintained at Consumers Energy Co Operating Nuclear Power Plants ML18066A4131999-03-11011 March 1999 Responds to NRC 990210 Ltr Re Violations Noted in Insp Rept 50-255/98-22.Corrective Actions:Analytical Evaluation, EA-C-PAL-98-1067-01, P-50A Case to Cover Stud Evaluation, Was Submitted to NRC on 981220 ML18068A5241999-02-12012 February 1999 Resubmits Relief Request 12,with Addl Info That Includes Specific Locations Where Relief Request Would Be Applied,Per 10CFR50.55a(g)(5)(iii) ML18068A5211999-02-11011 February 1999 Informs NRC That Implementation of Formal Industry Position on Severe Accident Mgt at Palisades Plant Was Completed on 981217 ML18066A4051999-02-10010 February 1999 Requests Copy of Consumers Energy (Palisades) Formal Response to RAI Dtd 990512 (USI A-46) ML18066A3921999-01-29029 January 1999 Forwards Licensee Interpretation of TS Requirements for Performance of SRs as Applied to Instrumentation Channel Calibr.Ltr Established No New Commitments ML18066A3891999-01-28028 January 1999 Submits Response to Concern Expressed in Insp Rept 50-255/98-06 Re Whether Palisades ISI Program Was Being Conducted IAW Applicable Requirements 1999-09-30
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consumers Power
- G BSlade General MizMge, POWERING lllllCHIGAN'S l'IUJGRESS Palisades Nuclear Plant: 27780 Blua Star Memorial Highway, Coven. Ml 49043 December 20, 1991 Nuclear Regulatory Co11111ission Document Control Desk Washington, DC 20555 DOCKET 50.:255 - LICENSE DPR-20 .:. PALISADES PLANT - .
TECHNICAL SPECIFICATIONS CHANGE REQUEST. - ADMINISTRATIVE CONTROLS - REVISION:. }
Consumers Power Company letter dated July 15, 1991 submitted a Technical Specifications Change Request (TSCR) to align the Technical Specification requirements with the April 1, 1991 Nuclear Operations Department (NOD) organizational changes and to facilitate change~,to the Palisades Plant Review Connnittee (PRC). * .
The proposed changes increased the number of PRC members from nine to ten without increasing the quorum requirement of five. They also eliminated the listing of position titles in favor of allowing the Palisades Plant-General Manager to designate PRC members in the Palisades Administrative Procedures -
thus eliminating the need to change Technical Specifications in the future whenever a position title is changed.
The April 1, 1991 NOD organizational.changes marked the beginning of the Nuclear Performance Assessment Department (NPAD) which is responsible for the reviews which.were the responsibility of the Nuclear Safety Services Department (NSSD). Since the NPAD is an organizational unit functioning as an independent review body in compliance with Section 4.3.3 of ANSI NlS.7-
. 1976/ANS-3.2 (which does not require second level review except by the supervisor of the unit) and the number of qualified reviewers is increased, no second level technical review within the NPAD was proposed unless the initial reviewer determined it to be necessary. Additionally, since the requirements of a subsection of ANSI 3.1-1987 remain affected by other subsections of that section and to clarify the qualification requirements for those performing independent review (Nuclear Performance Specialists), the July 15, 1991 TSCR proposed the qualificat*lon requirement for the Nuclear Performance Specialists to be changed from Section 4.7 of ANSI 3.1-1987 to include all the subsections of Section 4 of ANSI 3.l-li87.
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IA CMS ENERGY COMPANY
! \ i ' ~-DR*.) ADOCK 0.5000255 ... * ! i .. I .
iPDR. r ,
As a result of telephone discussion between the NRC staff and the Palisades 2
staff, NRC letter dated October 28, 1991 forwarded comments regarding- our July 15,. 1991 proposed changes and requested a response within 45 days of its receipt. Subsequently, in view of the revision being made to the July 15, 1991 TSCR, the NRC Palisades Project Manager agreed to waive the 45 day
_requirement. The following is our response to those comments and the technical specifications revisions we propose in view of those convnents.
- 1. Con111ent (l)lal "The proposed TS wording states that "the PRC members shall meet or exceed the minimum qualifications of ANSI NlB.1-1971." Your committee currently is comprised of three Managers, three Superintendents, one Director, and one Shift Supervisor or Shift Engineer. Your proposed generic wording states that the PRC will be comprised of "representatives" from the major plant departments thereby potentially allowing less experienced members to participate in PRC discussions and decisions. PRC member qualifications should, for example, meet or exceed Section 4.2 and/or 4.4 of ANSI NlB.1-1971 (with an exception for an SRO qualified member)."
Response
The proposed change is revised to require PRC members to have qualifications at least equivalent to those described in Section 4.4 of ANSI NlS.1-1971. (See attachments)
- 2. Comment O)(bl "The proposed TS increases PRC composition to nine members, not including the Chairman, yet. failed to take into account the need to increase the quorum requirement."
Response
The proposed change is revised to keep the PRC composition at the existing eight members, not including the Chairman. There is no change to the
- existing quorum requirement. (See attachment)
- 3. Comment l2lCal "The proposed change ~eletes the second~1eve1 NPAD review. This second-1eve1 review was added by Amendment 127, dated August 16, 1989.
Sufficient justification for deleting this independent review was not provided for in your application. Crediting a second, in-1-fne organizational review by the originating group, is not acceptable to the staff. A second-level review by the "Offsite Safety Review Group" is warranted, since your NPAO only meets as a committee under special circumstances.* -
Response .
- 3 The proposed change is revised to require NPAD Independent Safety Review (ISR) meetings at least twice yearly and as conditions requiring interdisciplinary review may warrant. The initial NPAD Specialist reviewer has the option of requesting a second review by another Specialist, requesting an item be reviewed at the next ISR meeting or requesting an item be reviewed at a special meeting called for such purpose. NPAD procedures require that samples of reviews approved by only one independent reviewer shall be reviewed again in the twice yearly NPAD ISR meetings. '
Thus, while not requiring a second-level review per se, the proposed change provides for levels of reviews appropriate to assure that required review is accomplished and that unreviewed safety questions will be identified. (See attachments). The Nuclear Performance Spec.1al i sts Group within NPAD is considered an organizational unit functioning as an independent review body which is the ANSI NlS.7-1976/ANS-3.2 preferred method of* review; and, as such, meet the independent review program requirements of Section 4.3 of ANSI NlS.7-1976/ANS-3.2.
- 4. Coinment (2l(bl "The NRC Safety Eva1uation approving* Amendment. 127 recognized that your "off-site safety review" members wi11 meet or exceed t.he qua1ifications described in Section 4.7 of ANSI/ANS 3.1-1987. Your current proposa1 has
- re1axed the minimum expected qua1ifications for members, quoting the more
- genera] Section 4. This is considered unacceptab1e."
Response
- consumers Power Company has revised the July 15, 1991 proposed change to*.
refer to Section 4.7 ANSI/ANS 3.1-1987 with the understanding that "General" provisions of Section 4.1 would also apply. *This is necessary to assure qualified Specialists who may not hold degrees in ~ngineering or science can be assigned reviews of non-engineering areas specified in Section 6.5.2.1, such as emergency planning.
- 5. Comment (31
. "Your change proposes to de1ete NPAD review in the areas of non-destructive testing, administrative contro1s, emergency p1anning and training. Your Justification for these de1etions is to more c1ose1y align this sub-section with Standard Technical Specifications (STS). This justification for deleting items from the TS *is not accejJtable .. iii that-* is too selective. There are additional Section 6.0 "Administrative Controls" that could be applied to your TS, should you reque*st a comparison with Standard TS. Therefore, any such proposed deletions should be performed in .the context of a larger compari$on with Standard TS."
Response
- 4 Consumers Power Company has revised our July 15, 1991 proposed change to the areas for which NPAD shall function to review. Thus, Section 6.5.2.1 is not changed except that NPAD shall function to provide review instead of NSSD. (See attachments) contains revised proposed technical specifications pages. contains existing technical specifications pages marked up to show the proposed changes. Attachment 3 contains changed pages proposed by our July 15, 1991 submittal marked up to show the revisions to those changes proposed by this Revision 1. Attachment 4 contains organizational charts for the restructured Nuclear Operations Department. *
,~~-
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspect_pr - Palisades Attachments
- 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 that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described in Section I below:
I. Changes A. Revise Section 6.5.1.2 as follows:
R6.5,1.2 COMPOSITION The PRC is composed of nine regular members from either the *I Palisades staff or the Nuclear Engineering and Construction Organizatiori (NECO) staff. The qualification level for PRC members sha11 be at least equivalent to those described in Section 4.4 of ANSI NlS.1~1971. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments. The members shall be designated in administrative procedures by the Plant General Manager; The Plant General Manager shall also designate the Chairman and Alternate Chairmen in writing.n B. Delete the last sentence of Section 6.5.1.3.
_C. Change Section 6.5.1.5 to read:
RA quorum of the PRC shall consist of the Chairman or Alternate Chairman and four members (including alternates).R D. Change Section 6.5.1.6.c as follows:
. Re. Results of investigations of all violations of the Technical Specifications.. (A report shall be prepared covering evaluation and reconunendations to prevent recurrence and be forwarded to the Vice President - NOD and to the Director Nuclear Performance Assessment Department (N~~D).)"
E. Change Section 6.5.1.6.f and 6.10.1.c to read:
- All reportable events as defined in Section 6.9.2.R F. In Sections 6.~.1.6.e, 6.5.1.7.c and 6.5.1.8 change nNSSDR to "NPADR and "Nuclear Safety Services Departmentn to "Nuclear Performance Ass.essment Department" as applicable.
G. Change the title of Section 6.5.2 to "NUCLEAR PERFORMANCE_
2 .
ASSESSMENT DEPARTMENT (NPAD) *. -.
H. In Section 6.5.2.1 change "Nuclear Safety Services Department (NSSD)* to *Nuclear Performance Assessment Department (NPAD).*
I. Change Section 6.5.2.2 to read:
- 6.5.2.2 COMPOS IT ION The NPAD shall include the Director, who reports to the Vice President ~ NOD, and a full-time staff of Nuclear Performance Specialists reporting to the Director. The Director and the
- Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1-1987. The NPAD shall have no direct responsibility for activities subject to its review.*
J. In Sectiort.~.5.2.3, change "NSSD* t.o NPAD* in two locations.
K. In Section 6.5.2.4.1, change "NSsD* to *NPAD*.
L. Delete the first sentence.and the second sentence before the colon in Section 6.5.2.4.2 and insert:
Audits of operational nuclear safety-related facility activities shall be performed by the NPAD staff under the cognizance of the Nuclear Performance Specialists. These
M. In Section 6.5.2.4.2.f, change "NSSD* to "NPAD.*
N. Delete "NSSD* from the last paragraph of Section 6.5.2.4.2 and insert "Director, NPAD".
O. _Change Section 6.5.2.4.3 to read:
1* NPAD review of the subjects in Specifications 6.5.2.4.1 and 6.5.2.4.2 shall be performed by an assigned Nuclear Performance Specialist selected on the basis of technical expertise relative to the subject being reviewed.* If the assigned Nuclear Performance Specialist determines the need for interdisciplinary review, a committee consisting of the Director, NPAD, or his designate, and at least four Nuclear Performance Specialists, shall be assigned. Such co11111ittee shall meet as conditions requiring interdisciplinary review arise, but no less than twice yearly.
P. In Sections 6.5~2.5, 6.5.2.6, 6.7.1.b and 6.7.1.d change
3 "NSSD" to "NPAD."
lF. Discussion This request changes the composition of the PRC by deleting specific titles and replacing them with a generic statement which allows the Plant General Manager to change the composition of the PRC without processing a Technical Specifications change every time a position title changes. Members of the PRC will meet at least the equivalent of the qualifications described in Section 4.4 of ANSI 18.1-1971 and thus meet the criteria of Standard Review Plan 13.4.
The Nuclear Performance Assessment Department (NPAD) is an organizational unit functioning as an independent review body which provides independent review of activities in the areas where review was previously performed by the Nuclear Safety Services Department. NPAD review (described in change 0 above) will be performed by a Nuclear Performance Specialist appointed
- on the basis of his expertise in the area concerned. If the appointed Nuclear Performance Specialist determines the need for additional revJ~w, the subject of the review will be further -*
evaluated by a committee cons*isting of the Director, NPAD, and at least four Nuclear Performance Specialists. Thus, if review by a multi-disciplined conmittee is deemed appropriate by the appointed reviewer, further review is performed by committee.
This practice combines the best features of past review practices. Both the practice of commft'tee review and the practice of individual review have existed in the past. This proposed change combines the most effective parts of each. As was the case previously (Section 6.5.2.3), consultants may be used where sufficient expertise is not available within NPAD.
Second level NPAD review wnl no longer be required. Review by a ,.
Nuclear Performance Specialist provides, in most cases, sufficient depth of review to assure the margin of safety. In those cases when the Director, NPAD, or the appointed reviewer determines more depth of review is appropriate, the aforementioned committee will provide it. The Director, NPAD,
.... and the Nuclear Performance Specialists will also meet at least twice yearly and review at least one independent review performed by each special 1st. * * * **
The requirement that NSSD staff meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1-1987 continues in effect for the Director and Nuclear Performance Specialists of the NPAD staff. Thus, Section 6.5.2.2 continues to meet the acceptance criteria of Section 13.4 of the Standard Review plan.
Sections 6.5.1.6.4 and 6.10.1.c (change D) now refer to reportable events as required by Section 6.9.2 instead of as defined by Section 1.4. This change is editorial and is for
clarity and consistency since both Secttons 1.4 ~nd 6.9.2 refer 4
to 10CFRS0.73.
Changes D, F, G, Ji K, Mand P only change the name of the reviewing or receiving department from Nuclear Safety Services Department (NSSD) to Nuclear Performance Assessment Department (NPAD). As discussed above, this proposed Technical Specifications change does not significantly change the type of review or the skill, experience or knowledge required for effective Company review. These changes are purely administrative.
Change H describes and prescribes the c*omposition of the NPAD, ensures its direct access to the Nuclear Operations Vice President and requires its independence as a reviewing body.
III. Analysis of No Significant Hazards Consideration Consumers Power Company finds, in compliance with 10CFRS0.92(c),
that activities associated with this change request involve no significant h~lilrds. The following evaluation supports that finding.
- 1. Will the orooosed change involve a significant increase in the probability or consequences of an accident oreyioysly evaluated?
This change does not affect the probability or consequences of an accident. The changes are to the administrative section of the TS with the significant changes affecting the PRC co~pdsition and changj~g the method of independent review.
The PRC member titles will be removed from the TS to facilitate not requiring that a TS change be submitted for*
NRC approval whe.n position titles change. PRC member qualifications will still.be consistent with those described for the Plant Staff and meet or exceed Section 4.4 of ANSI 18.1-1971 as endorsed by the NRC in SRP 13.4~ The Plant
. , General Mali.ager will be required to designate the PRC
- members, chairman and alternate chairmen in administrative procedures. This places appropriate authority over PRC selection. Therefore, these changes will not affect the probability or consequences of an accident.
The review method of the organizational unit functioning as an independent review body continues to meet the requirements of ANSI NlS.7-1976/ANS 3.2 but has changed in that a second level review.is no longer required. When necessary, the depth of r~view will be enhanced as appropriate either through the pas.t practice of use of consul tan ts or by
s committee review. The independent review body (the Nuclear
- Performance Assessment Department) *naff tasked with review of the TS required functional areas will continue to meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1-1987 in accordance with SRP 13.4. This change is administrative and does not increase the probab1l ity or consequences of an accident.
The change to reference the reporting requirements to Section 6.9.2 is purely administrative to gain consistency throughout the technical specifications.
Thus the changes proposed do not affect the operation or material condition of the facility. The accident analyses are not affected by this proposed change. Proper review and independent oversight by qualified personnel as recommended or required by the Standard Review Plan and Administrative Procedures will be in place. Therefore, the changes do not increase the probability or consequences of an accident.
- 2. Will the prooosed change create the possibility of a new or different k-ind of accident from any accident previously **~
evaluated?
The composition of onsite Plant Review Committee .(PRC) and the independent review body (NPAD) will be made up of qualified fodividual s providing functional *reviews that are consistent with the Standard Review Plan and administrative program requirements. These changes are purely administrative and do not affect the material condition, plant operation or accident analyses; and therefore, d~ not create the possibility of a different type of accident than any previously evaluated
. 3. _Will _the..prooosed change involve a signifiGant reduction -in-the margin of safety?
The changes to PRC composition provide internal flexibility in changing the organization titles, but do not reduce the PRC function to provide review and advise the Plant General Manager on matters of nuclear safety. *The PRC will be composed of individuals from appropriate functional areas of Operations, Maintenance, Radiological Services, and Engineering Departments and will be designated in administrative procedures by the Plant General Manger. The NPAD will continue to provide an independent overview by qualified individuals, or by conunittee, of the functional areas delineated in the TS. These changes are administrative and do not affect the material condition or plant operation and neither the consequences of an accident nor the fission product boundaries have been affected *. Therefore the margin of safety has not been reduced.
- 1 IV. Conclusion e 7 The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that this change does not involve an unreviewed. safety question. Further, the change involves no significant hazards consideration. This change has been reviewed by the Nuclear Performance Assessment Department. A copy of this Technical Specifications 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 Specifications Change Request are truthful and complete.
By~ ~il.~-"*-*.___,
David P.~ent Nuclear Operations Sworn and subscribed to t>efore me this~ day of ~
1991..
Notary Public [Seal]
County, Michigan My co11111ission expires LeANN MORSE, NOTARY PUBLIC VAN BUREN COUNTY, STATE OF MICHIGAN_
MY COMMISSION EXPIRES 06*0&-94