ML18348A861

Review of Proposed Technical Specification Changes

ML18348A861
Person / Time
Site:	Palisades
Issue date:	03/09/1977
From:	Bixel D Consumers Power Co
To:	Schwencer A Office of Nuclear Reactor Regulation
References
Download: ML18348A861 (4)

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• Power company General Offices: 212 West Michigan Avenue, .Jackson, Michigan 49201

• Area Code 517 788-0550 March 9, 1977 Re&ulalofy Uockel rile Director of Nuclear Reactor Regulation Att: Albert Schwencer, Chief Operating Reactor Branch No 1 US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255, LICENSE DPR PALISADES PLANT - REVIEW OF PROPOSED TECHNICAL SPECIFICATIONS CHANGES

• By letter dated January 19, 1977, the office of inspection and enforcement -

Region III r'3.ised certain questions related to our practice of reviewing proposed Technical Specifications changes. We responded to their questions by letter dated February 9, 1977 (attached) and indicated that we would re-view the :rr.atter fur+ her with the Director of Nuclear Reactor R.egulation.

As described in our February 9, 1977 letter, we believe that our present practice is appropriate and that a significant change in this practice could have significant undesirable effects.

If you should find it desirable, we would be happy to participate in a meet-ir.g on this subject and could present a detailed review of our concern.

David A Bixel Nuclear Licensing Administrator CC: JGKeppler, USJ.IJnC

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consumers

• Power company General Offices: !21!2 West Michigan Avenue, Jackson, Michigan 49201

• Area Code 517 788-0550 February 9, 1977 Mr Jam.es G Keppler Office of Inspection & Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-255, LICENSE DPR PALISADES PLANT - CITATION RESPONSE This letter is w-~itten to explain action taken with respect to an apparent deficiency reported in your IE Inspection Report 050-255/76-24. This report was transmitted by letter dated January 19, 1977. The stated deficiency and a discussion of this deficiency follow below:

11 Deficiency Contrary to Technical Specification 6.5.1.6.c, the Plant Review Committee did not review the proposed Technical Specifications change dealing with steam generator tube plugging criteria prior to it being transmitted to the Office of Nuclear Reactor Regulation (ONRR) on March 9, 1976. 11 Discussion In order to develop a perspective of the review of proposed Technical Specifica-tions, we would like to note the following:

1. As observed in the "Report Details, 11 your inspector noted that the specification for Plant Review Committee (PRC) review reads 11 * *

• review of all proposed changes to the Technical Specifications."

Specifically the requirement does not indicate when this review is to be done and, therefore, the intent of this specification is sub-ject to interpretation.

2. Technical Specification 6.5.2.7(b) states the review requirements for our Safety and Audit Review Board (SARB).. These requirements are similar and read" ... proposed changes to the technical speci-fications .... " We note this item because we conclude that SARB review requirements may also need to be clarified.

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• 3. From reviewing your "Report Details," it was not clear whether or not your inspector observed that in the conclusion section of the referenced proposed Technical Specifications (submitted by letter dated March 6, 1976) we stated the following: "This change has not been reviewed by our Palisades Plant Review Committee or the Safety and Audit Review Board. These reviews will be conducted in the near future and we will advise you should any of the proposed changes be deemed inappropriate."

4. The subject Technical Specifications involved the previous submittal of two technical reports, a meeting held with the Office of Nuclear Reactor Regulation (ONRR) in Bethesda (on February 26, 1976) and the transmittal letter noted by your inspector (March 9, 1976). That letter contained over 100 pages of information and figures.

Where practical, we prefer and practice obtaining PRC approval of proposed Tech-nical Specifications prior to submittal to the ONRR. There are, however, times when this is not practical and the example observed is typical of this type of event. Significant data were trans~tted and meetings held with the ONRR in February and March of 1976. However, it was understood at that time that a final technical specification change could not be submitted until after the results of the inspection program were obtained and analyzed. In order to afford the ONRR staff as much time as possible to complete their review and not infringe on the anticipated plant start-up date (ie, cause the outage to be delayed due to licensing matters), we on occasion do submit proposed Technical Specifications prior to completing their review by the PRC. As in the March 9, 1976 submittal, the status of PRC approval is noted in the conclusion section of the report.

Your inspector indicated concern that this procedure might influence the PRC.

We have concluded that processing of the proposed Technical Specifications changes in the present manner will not adversely affect PRC review and, in fact, has a positive effect in that it allows them additional time to perform the review.

Should the results of a PRC review determine that a proposed change is inappro-priate, we would immediately advise the ONRR.

Handling of reviews by our SARE is done in a significantly different manner.

We have generally considered SARE responsibility more as an overview. Although there are times when the SARE is asked to review proposed Technical Specifica-tions prior to submittal, most of the reviews are conducted after the submittal has been made. We conclude that this manner of performing the review is con-sistent with the purpose of the SARE.

We note in the "Report Details" that IE:III management has concluded that the interpretation of Technical Specification 6.5.1.6.c was meant to have PRC consider proposed Technical Specifications changes prior to their being forwarded to ONRR.

While we generally do perform our PRC review in conformance with this interpre-tation, we conclude that there will be times when this is not practical or

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• desirable. Such a rigid interpretation, we have concluded, will cause unneces-sary extension of plant outages and/or unnecessarily reduce the time available for review by both our PRC and members of the ONRR staff.

We will review this matter with the Director of Nuclear Reactor Regulation and make changes in our operating practice if that is determined to be required.

David A Bixel (Signed)

David A Bixel Nuclear Licensing Administrator CC: Director of Nuclear Reactor Regulation