ML20206N262

Application for Amend to License DPR-6 to Delete from Defueled Ts,Subsection 1.16,change Definition of Site & Other Associated Editorial Changes

ML20206N262
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/11/1999
From:	Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206N268	List: ML20206N262 ML20206N275
References
NUDOCS 9905170189
Download: ML20206N262 (8)

Text

A CMS Energy Cornpany Big Rock Point Nuclear Plant Kenne P. hnners 10269 US-31 North Site General Manager Charlevoix. MI 49/20 May 11,1999 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 - 0001 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT - DEFUELED TECHNICAL SPECIFICATION REQUEST TO DELETE DEFINITION OF SITE BOUNDARY AND REMOVE SITE MAP A request for amendment of the Big Rock Point Defueled Technical Specifications in accordance with 10 CFR 50.90 is enclosed. In order to be consistent with other decommissioning facilities and current NRC guidance, Consumers Energy Company proposes to delete from the Defueled Technical Specifications subsection 1.16, SITE BOUNDARY, which is already defined in 10 CFR Part 20; Figure 5.1-1 BRP Site Map, which is already provided in the Updated Final Hazards Summary Report (UFHSR); change the definition of the Big Rock Point site; and other associated editorial changes. Any future changes made to the UFHSR will be performed under 10 CFR 50.59.

This request is also consistent with guidance issued by the NRC for proposed standard technical specifications for permanently defueled plants.

In accordance with 10 CFR 50.91, Consumers Energy Company has made a determination that the proposed amendment change request involves no significant hazards considerations.

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enneth P Powers Site General Manager i cc: Administrator, Region III NRC Reactor Decommissioning Inspector - BRP NRR Project Manager - OWFN, USNRC Attaclunent(s) 9905170109 990511 DR ADOCK 0 Q5

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CONSUMERS ENERGY COMPANY 2 LICENSE DPR-6 DOCKET 50-155 Request for amendment to the Defueled Technical Specifications (DTS)

For the reasons hereinafter set forth, it is requested that the Defueled Technical Specifications contained in the Facility Operating License DPR-6, Docket 50-155 for the Big Rock Point Plant be amended as proposed in Section I below. Revised Defueled Technical Specification pages are provided in Attachment 1. The proposed changes are shown utilizing the " strikeout" and

" redline" method. The proposed new pages of the Defueled Technical Specifications are provided in Attachment 2 to this letter.

I. CllANGES

1. Delete subsection 1.16 SITE BOUNDARY. Delete 1.16 SITE BOUNDARY from the Table of Contents. Eliminate the capitalization of this term where necessary as it appears throughout the following subsection (s) of the Defueled Technical Specifications and Bases:

Defueled Technical Bases #

Specifications 6.6.2.5.h 3.3.1.d 6.6.2.6.b

2. Delete Figure 5.1-1, BRP Site Map from Defueled Technical Specification , Section 5.0, DESIGN FEATURES. Delete "(reference Figure 5.1-1)" from Defueled Technical Specifications subsections 5.1.1.

Delete "(see Figure 5.1-1)" from Defueled Technical Specifications subsections 6.6.2.5.g, and 6.6.2.5.j.

3. Delete the following from subsection 5.1.1 of the DESIGN FEATURES section of the Defueled Technical Specificationsi

a. 5.1.1 LOCATION AND BOUNDRIES j

b. ... site, consisting of approximately 600 acres,... l

c. ...The nearest landside property line is about 2680 feet and the ]

nearest shoreline property line is about 200 feet from the ,

containment sphere... l I

4. Delete 5.1.1 Location and Boundaries, and FIGURE 5.1-1, BRP Site Map, from the Table of Contents.

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CONSUMERS ENERGY COMPANY 3 LICENSE DPR-6 DOCKET 50-155 Request for amendment to the Defueled Technical Specifications (DTS)

II. DISCUSSION

1. Delete subsection 1.16, SITE BOUNDARY. Eliminate the capitalization of this term as it appears throughout the Defueled Technical Specifications and Bases. Remove this subsection from the Table of Contents.

Including the definition of SITE BOUNDARY in the Big Rock Point Defueled Technical Specifications is unnecessary and redundant because the definition and application of this term already exists in 10 CFR Part 20. Furthermore, it appears that the duplication of temis already defined in the regulations in facility's technical specifications is not necessary since this l requirement is not part of the format prescribed in proposed Standard Technical Specification guidance for decommissioned plants.

As a matter of Use and Application, the defined terms of Section 1.0 of the Technical Specifications appear in capitalized type and are applicable throughout. The use of the term " site boundary" remains appropriate in the Defueled Technical Specifications and Bases, however since it is not a defined tenn, it will noi be capitalized.  ;

2. Delete Figure 5.1-1 BRP Site Map and its reference from the Defueled Technical Specifications. Delete from the Table of Contents.

3. Replace Subsection 5.1 of the DESIGN FEATURES section of the Defueled Technical Specifications in its entirety with the following:

5.1 SITE The plant site is located in Charlevoix County, Alichigan, about 4 miles northeast ofCharlevoix, Afichigan, and about 11 miles west ofPetoskey, Alichigan.

The applicable section of the NRC's regulations dealing with the required content of Technical Specifications, Section 10 CFR 50.36(c)(4), states:

" Design features to be included are those features of the facility such as material of construction, and geometric arrangements, which, if altered or modified, would have a significant effect on safety and are not covered in categories described in paragraphs (1), (2), and (3) of this section."

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CONSUMERS ENERGY COMPANY 4 LICENSE DPR-6 DOCKET 50-155 Request for amendment to the Defueled Technical Specifications (DTS)

The referenced paragraph (c)(1) deals with safety limits, limiting safety system settings, and limiting control settings; paragraph (c)(2) deals with limiting conditions for operation; and paragraph (c)(3) deals with surveillance requirements. None of the above cited criteria for content of Technical Specifications applies to the site map, figure 5.1-1, in the current Big Rock Point Defueled Technical Specifications.

Two NRC guidance documents also support the proposed changes. NUREG-1625, " Proposed Standard Technical Specifications for Permanently Defueled Westinghouse Plants", which recommends a textual site location description and Regulatory Guide 1.70," Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants", which directs applicants and licensees to provide the site map for their facility in their Safety Analysis Report.

Therefore, removal of the site map and its reference from the Big Rock Point Defueled Technical Specifications and replacement with a textual site location description is appropriate and follows current NRC guidance.

4. Delete 5.1.1 Location and Boundaries from the Table of Contents.

it logically follows that these be removed from the table of contents.

III. ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION In accordance with 10 CFR 50.91, Consumers Energy Company has made a determination that the proposed amendment does not involve significant hazards considerations. Consumers Energy Company has concluded that the proposed amendment will not:

1) involve a significant increase in the probability or consequences of an accident previously evaluated; or

2) create the possibility of a new or different kind of accident from any accident previously evaluated; or

3) involve a significant reduction in a margin of safety.

The proposed change is administrative in nature and has no affect on the health and safety of the public. There is no reduction or elimination of federal regulatory requirements associated with the proposed amendment. The information being removed from the Defueled Technical Specifications is unnecessary since SITE BOUNDARY is already defm' ed in 10 CFR Part 20, and the site map is already provided in the Updated Final Hazards Safety Report. Furthermore, the proposed changes are consistent with the guidance provided in NUREG -1625.

CONSUMERS ENERGY COMPANY 5 ,

LICENSE DPR-6 DOCKET 50-155 Request for amendment to the Defueled Technical Specifications (DTS)

The proposed change does not:

1) Involve a significant increase in the probability or consequence of an accident previously evaluated.

The proposed amendment does not change the site boundary as it currently exists.

Deleting the SITE BOUNDARY definition and changing the upper case characters to lower case throughout the DTS and the Bases where it appears, and deleting the site figure from the DTS and related references will not increase the probability or consequences of a new or different kind of accident previously evaluated. This proposed change is administrative in nature and does not involve fuel handling or affect or modify any system, structure or cornponent.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not change the site boundary as it currently exists.

Deleting the SITE BOUNDARY definition and changing the upper case characters to lower case throughout the DTS and the Bases where it appears, and deleting the site figure from the DTS and related references will not create the possibility of a new or different kind of accident from any accident previously evaluated. This proposed change is administrative in nature and does not involve fuel handling or affect or modify any system, structure or component.

3) Involve a significant reduction in the margin of safety.

The proposed changes do not involve any physical changes to the plant or plant procedures. There will be no reduction in a margin of safety.

i CONSUMERS ENERGY COMPANY 6 ;

LICENSE DPR-6 DOCKET 50-155  ;

4 Pequest for amendment to the Defueled Technical Specifications (DTS) j IV. CONCLUSION The Big Rock Point Safety Review Committee has reviewed this Defueled Technical Specification Change request and has determined this proposed change does not involve significant hazards consideration. This proposed change has also been reviewed and J

approved by the Nuclear Performance Assessment Department. A copy of this proposed change request has been sent to the State of Michigan official designated to receive such proposed Amendments to Appendix A of the Big Rock Point Facility Operating License.

CONSUMERS ENERGY COMPANY - 7 LICENSE DPR-6 '

DOCKET 50-155 Request for amendment to the Defueled Technical Specifications (DTS)

CONSUMERS ENERGY COMPANY To the best of my knowledge, information and belief, the contents of this submittal are truthful and complete.

By W

se'nneth P Powers Site General Manager Sworn and subscribed to before me this day May 11,1999.

hattO, bnw bhn '

Jyp'nifer Lyfn Helms, Notary Public L>harlevoix County, Michigan My commission expires August 29,1999 SEAL

ATTACHMENT l' CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET 50-155 Revised Defueled Technical Specification Presenting Proposed Revisions.

Submitted May 11,1999

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