ML20217A599
| ML20217A599 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 04/16/1998 |
| From: | Harris P NRC (Affiliation Not Assigned) |
| To: | Powers K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| References | |
| TAC-M99687, NUDOCS 9804220290 | |
| Download: ML20217A599 (31) | |
Text
[
Mr. Ksnnsth P. Powzrs April 16, 1998 Pitnt Grnsral MInigsr Big Rock Nucitar Plant l
Consumers Energy Company 10269 US 31 North Charlevoix, MI 49720
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE PROPOSED BIG ROCK POINT NUCLEAR PLANT DEFUELED TECHNICAL SPECIFICATIONS (TAC #M99687) l
Dear Mr. Powers:
l We are continuing our review of your proposed changes to your proposed Defueled Technical Specifications, as detailed in your letter to us dated September 19,1997.
However, questions have arisen for which we require' additional information and clarification. These questions were discussed with members of your staff on January 21 and 22, and March 11,1998. The enclosed request for additionalinformation summarizes 1
the questions that remain.
This request affects nine or fewer respondents and therefore, is riot subject to Office of Management and Budget review under P.L.-96-511'. In accordance with 10 CFR 50.30(b),
.your response must be executed in a signed original under oath or affirmation.
l If you have any questions regarding this review, please contact me at (301) 4151169.
Sincerely,
' ORIGINAL SIGNED BY:
Paul W. Harris, Project Manager Non-Power Reactors and Decommissioning 9804220290 980416 Project Directorate DR ADOCK 0500 5
Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-155
Enclosure:
As stated cc w enclosure: See next page l
DISTRIBUTION (har,d copy)
[ Docket Fue.50155 Region lli DISTRIBUTION (e-mail)
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OFFICE PDND: FW E PDN(/:LA E
PDND:(A)SC HOMB:SC PDND:(A)D
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NAME PHarris W EM[4Rin/g%4) MMasnik C RGramd(Note 1)
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OFFICIAL RECORD' COPY l
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Nots 1:
Concurrence on sections entitled " Quality Assurance,"" Procedures," and " Programs," commencing
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with page'19, comments 70-79.
a l
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I Mr. Kenneth P. Pawirs April 16, 1998 Plant G:nerti Manag2r l*
Big Rock Nuclear Plant j
Consumers Energy Company 10269 US-31 North j
Charlevoix, MI 49720
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE PROPOSED BIG ROCK POINT NUCLEAR PLANT DEFUELED TECHNICAL SPECIFICATIONS (TAC #M99687)
Dear Mr. Powers:
We are continuing our review of your proposed changes to your proposed Defueled Technical Specifications, as detailed in your letter to us dated September 19,1997.
However, questio1s have arisen for which we require additional information and clarification. These questions were discussed with members of your staff on January 21 and 22, and March 11,1998. The enclosed request for additional information summarizes the questions that temain.
This request affects nine or fewer respondents and therefore, is not subject to Office of Management and Budget review under P.L. 96 511. In accordance with 10 CFR 50.30(b),
your response must be executed in a signed original under oath or affirmation.
If you have any questions regarding this review, please contact me at (301) 4151169.
Sincerely, ORIGINAL SIGNED BY:
Paul W. Harris, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Rego;ation Docket No. 50-155
Enclosure:
As stated cc w enclosure: See next page DISTRIBUTION (hard copy)
Docket File 50155 Region lli DISTRIBUTION (e-mail)
PUBL :
OGC (AHodgdon)
RBurrows RDudley PDND rf EHylton MFairtile TFredrichs SWeiss MMasnik AMarkley JMinns PHarris RLeemon, BRP LThonus MWebb JRoe MMendonca LWheeler RGranin DOCUMENT NAME: G:\\SECY\\ HARRIS \\TSRA1316.BRP Ta receive a copy of this document, indicate in the box:
"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
_ OFFICE PDND: fMi t E PDNp:LA E
PDND:(A)SC HQMB:SC PDND:(A)D f /,,
NAME PHarris W E8Sn/g%c4,'l MMasnik Y RGramld(Note 1)
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DATE 3/^h/98 3/.$/ /98
$/l b /98 A// (c/ 98 h lh/98 OFFICIAL RECORD' COPY Nota 1:
Concurrence on sections entitled " Quality Assurance," " Procedures," and " Programs," commencing with page 19, comments 70-79.
, =.,
t UNITED STATES (n -
j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 20555-0001
"\\,....,/
April 16, 1998 l
Mr. Kenneth P. Powers Plant General Manager f
Big Rock Nuclear Plant Consumers Energy Company 10269 US 31 North Charlevoix, MI 49720
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE PROPOSED BIG ROCK POINT NUCLEAR PLANT DEFUELED TECHNICAL SPECIFICATIONS (TAC #M99687)
Dear Mr. Powers:
We are continuing our review of your proposed changes to your proposed Defueled Technical Specifications, as detailed in your letter to us dated September 19,1997.
However, questions have arisen for which we require additional information and clarification. These questions were discussed with members of your staff on January 21 and 22 and March 11,1998. The enclosed request for additional information summarizes the quettions that remain.
This request affects nine or fewer respondents and therefore, is not subject to Office of Management and Budget review under P.L.96-511. In accordance with 10 CFR 50.30(b),
your response must be executed in a signed original under oath or affirmation.
If you have any questions regarding this review, please contact me at (301) 4151169.
- Sincyely, i
l P u W.
a is, Project Manager Non-Power Reactors and Decommissioning Project Directorate Division of Reactor Program Management Office of Nuclear Reactor Regulation Docket No. 50-155
Enclosure:
As stated cc w enclosure:
See next page
[6 l
Mr. Kenneth Powers Big Rock Point Nuclear Plant i
Docket No. 50155 (PAGE 1 C ' 2) cc:
Mr. Thomas A. McNish, Secretary Lake Michigan Federation l
Consumers Energy Company ATTN: E. Roemer, Attorney l
212 West Michigan Avenue 59 E. Van Buren #2215 l
Jackson, Michigan 49201 Chicago, Illinois 60605 Judd L. Bacon, Esquire Michigan Department of Attorney Consumers Energy Company General j
212 West Michigan Avenue Special Litigation Division Jackson, Michigan 49201 630 Law Building P.O. Box 30212 Ms. Jane E. Brannon, County Clork Lansing, Michigan 48909 County Building Annex 203 Antrim Street Mr. Rich Bachus Charlevoix, Michigan 49720 Traverse City Record - Eagle 7401 Middle Road Office of the Governor Harbor Springs, Michigan 49740 Room 1 - Capitol Building Lansing, Michigan 48913 Ms. Angela S. Greenman U.S. NRC Region til regional Administrator, Ragion til 801 Warrenville Road U.S. Nuclear Regulatory Commission Lisle, Illinois 6C332 801 Werrenville Road Lisle, Illinois 60532 4351 Ms. Janenne trene Froats I
P.O. Box 528 Michigan Department of Petoskey, Michigan 49770 Environmental Quality Drinking Water and Radiological Mr. Henry Peters Protection Division Route 1 3423 N. Martin Luther King Jr. Blvd.
Ewen, Michigan 49925 P.O. Box 30630 Lansing, Michigan 48909-8130 Ms. Doris Schaller 2310 M-119 Lakeside Condo U.S. Nuclear Regulatory Commission Unit #55 Resident inspector Office Petoskey, Michigan 49770 Big Rock Point Plant 10253 U.S. 31 North Mr. Michael Winnell Charlevoix, Michigan 49720 3250 Krouse Road Petoskey, Michigan 49770 Mr. Robert A. Fenech Senior Vice President Mr. James S. Rang Nuclear, Fossil Operations Consumers Power Company Consumers Energy Company 10269 U.S. 31 North l
212 W. Michigan Ave.
Charlevoix, M;chigan 49720
(
Jackson, Michigan 49201 Ms, Kay Cumbow l
15184 Dudley Road Brown City, Michigan 48416
]
l 1
1
Mr. Kenneth Powers Big Rock Point Nuclear Plant Docket No. 50155 (PAGE 2 OF 2) l cc:
Mr. Brennain Uoyd Northwatch P.O. Box 282 I
North Bay, Ontarlo PIB 8H2 Mr. John W. Campbell Executive Director Eastern U.P. Regional Planning
& Development Commission 524 Ashmun Street P. O. Box 520 Sault Ste. Marie, Michigan 49783 Lake Michigan Federation Attn: T. Cabala, Director 425 W. Western Avenue Muskegon, Michigan 49440 Citizens Awareness Network Box 83 Shelburne Falls, Massachusetts 01370 Jonathan M. Block, Esquire Main Street P.O. Box 566 Putney, VT 05346-0566 Ms. Deborah B. Katz, President Citizens Awareness Network P. O. Box 83 Shelburne Falls, Massachusetts 01370-0083 Ms. Corinne Carey 2213 River Side Drive NE Grand Rapids, MI 49505 Mr. Kenneth P. Powers Plant General Manager Big Rock Nuclear Point Consumers Energy Company 10269 US-31 Nort:-
Charlevoix, Michigan 49720 I
S-ENCIDSURE y
t UNITED STATES 3
j NUCLEAR REGULATORY COMMISSION o
WASHINGTON, D.C. 2006&4001
'+, *****,d REQUEST FOR ADDITIONAL INFORMATION CONCERNING BIG ROCK POINT NUCLEAR PLANT DEFUELED TECHNICAL SPECIFICATIONS The proposed Big Rock Point (BRP) Defueled Technical Specifications (DTS) were evaluated against, in part, Standard Technical Specifications for General Electric Plants (NUREG-l 1434) for boiling water reactors,10 CFR 50.36, " Technical Specifications," and the l
permanent shutdown and defueled condition of BRP. The following information is needed to determine whether the proposed DTS provides adequate assurance that facility activities j
will meet regulatory requirements and not be adverse to public health and safety. The BRP DTSs will be derived from the analysis and evaluation included in the safety analysis report (otherwise known as the BRP Final Hazards Summary Report (FHSR)).
The licensee should review and evaluate the following comments and (1) revise its proposed DTSs, as appropriate, or (2) describe how the proposed DTSs adequately address the specific comment, or (3) provide a rationale why the specific comment is not applicable to BRP or will not be incorporated.
Comments t
DPR-6 LICENSE j
1.
The proposed DPi.-6 license removes the following original DPR 6 license l
requirements. Justify why these licensee requirements are proposed for removal.
a.
2.B.(2)(e) human factors analysis of noble gas stack l
monitor system; l
b.
2.8.(2)(f) calibration of the high range containment l
radiation monitors; l
l c.
2.B.(2)(g) prompt notification to State and local planning I
authorities; and d.
2.C.(7)
Plan for the BRP Integrated Assessment.
l l
2 2.
The NRC staff notes that the requirements of DPR-6 license paragraph 2.B.(2)(a)-(c) are currently in Appendix A of the license as limiting conditions for operation (LCO),
as shown below. Justify why these requirements should be retained in both the license and Appendix A of the license.
License paragraph 2.8.(2)(a) and DTS 3.1.3.a regarding the storage of a.
materials in the area between rack B and the east wall of the spent fuel pool (SFP).
b.
License paragraph 2.B.(2)(b) and DTS 3.3.1.a regarding the use of the primary gantry' crane over the pool for loads of more than 24 tons.
License paragraph 2.B.(2)(c) and DTS 3.1.3.b regarding the storage of spent c.
fuelin the outer three rows of the fuel rack adjacent to the south wall of the SFP.
3.
Deleted.
DPR-6, APPENDIX A, TECHNICAL SPECIFICATIONS 4.
10 CFR 50.55a, " Codes and standards," requires, in part, the inservice testing and inspection of ASME Code Class 3 components to verify operational readiness.
Commission rules and regulations regarding the decommissioning of nuclear power 1
plants were amended on August 28,1996, as described in Federal Register Notice, Vol. 61, No.146, page 39278. On page 39288 of this notice, the NRC staff responded to a question regarding the applicability of 10 CFR 50.55a, Codes and Standards, to permanently defueled reactors. This response stated that the requirements of 10 CFR 50.55a provide assurance that relevant portions of the facility are maintained functional or operational to adequate standards so that they are operationally capable.
NUREG 1482, " Guidelines for Inservice Testing at Nuclear Power Plants," provides guidance as to the selection of pumps and valves to be included in the IST program, such as pumps and valves classified as ASME Code Class 1,2, and 3 that are required to: (1) shutdown the reactor; (2) maintain the reactor shutdown; or, (3) mitigate the consequences of an accident. Table 2.2 of NUREG-1482 indicates, in part, that the SFP cooling, service water, and ventilation systems are typically Code class systems in boiling water reactors.
I 1
i 3
Original technical specification (TS) 9.0, " Inservice Testing and Inspectica," required inspection and testing of ASME Code Class 1, Class 2, and Class 3 system components.
FHSR, revision 6, Table 3.1, designates the SFP pit, SFP cooling system, fire protection system, service water system, and others as ASME Code class components. This determination was subsequently retracted with submittal of Revision 7 of the FHSR to the NRC staff on February 12,1998, (see FHSR, rev. 7, paragraph 3.9.2.2).
CPC 2A, revision 18, stated that the inservice inspection program would be conducted in accordance with technical specifications and State of Michigan rules.
This requirement was subsequently deleted from CPC-2A with revision 19a (see CPC 2A, section 1.2.2, paragraph 27).
Justify why previously-approved requirements for the inservice inspection of components, as described in original TS 9.0, " Inservice inspection and Testing,"
were deleted from the proposed DTS. See Comment 74.
Qniinitions 5.
DTS Definitions
- a. Justify why a definition for Certified Fuel Handler was not provided in the proposed DTS.
6.
DTS 1.4, Containment Closure (see similar comments 32 and 35c)
- a. Clarify in the proposed TS bases (or appropriate location) whether containment closure could be temporarily disabled, defeated, or removed during plant conditions that require containment closure,
- b. Name the plant procedure (s) that would provide instructions that assure containment closure during plant conditions that require conte;nment closure, including: (1) the temporary disabling, defeating, or removal of containment closure and (2) how temporary containment closure devises (i.e., PVC, wood, or garage doors) would be evaluated for suitability and maintained as a containment closure devise.
7.
DTS 1.9, Operable - Operability The NRC staff is concerned that the proposed DTS definition for operability is too narrowly focused on safety-related structures, systems, and components (SSCs),
thereby omitting those SSCs that perform safety functions such as, in part, SSCs necessary for safe spent fuel storage, maintenance, and control and radiological effluent monitoring and control.
l NRC Manual Chapter 9900, " Technical Guidance," entitled
- Operable / Operability:
Ensuring the Functional Capability of a System or Component" states that "A system, subsystem, train, component, or a device shall be OPERABLE or has l
OPERABILITY when it is capable of performing its specified functions, and when all necessary attendant instrumental, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that is required for the system, subsystem, train, component, or a device to perform its function (s) are also capable of l
performing their related support functions."
Manual Chapter 9900 also states that OPERABLE / OPERABILITY is to apply to: (1) l safety related structures, systems, or components (SSCs); (2) all SSCs whose l
l f ailure would result in the f ailure of a safety-related SSCs; (3) all SSCs relied on in the safety analysis or plant evaluations that are part of the plant's current licensing l
basis; (4) any SSCs subject to 10 CFR 50, Appendix B; (5) any SSCs subject to 10 CFR 50, Appendix A, Criterion 1; (6) any SSCs explicitly subject to the facility TSs; (7) any SSCs subject to facility TS through the definition of operability; and, (8) any i
Justify the proposed DTS definition of operable / operability.
8.
DTS 1.12, Site Boundary Original TS 2.2 specifically details the size and distances associated with the site boundary.
l Original TS Figure 2.1, " Big Rock Point Site Map," is a pictorial representation of the
~BRP f acility.
Original TSs 13.1.2 (liquid effluent concentrations),13.1.3 (a gaseous effluent dose rate), and 13.1.4 (an effluent dose), etc. refer to original TS Figure 2.1.
Proposed DTS 1.12, " SITE BOUNDARY," states "the SITE BOUNDARY is that line beyond which the land is not owned, leased or otherwise controlled by the licensee" and Figure 2.1 was deleted.
- a. State whether the dimensions provided by original TS 2.2 and Figure 2.1 are maintained in a de:ument or program required by DTSs.
- b. Describe whether the site boundaries described in original TS 2.2 and Figure 2.1 are proposed for changed.
l
)
{
P,
)
i 5
i Safetv Limit 1<
j 9.
10 CFR 50.36(c)(1)(1)(A) defines a safety limit as, " limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain physical barriers that guards against the uncontrolled release of radioactivity."
Justify why the proposed DTSs do not consider the spent fuel clad as a physical barrier that guards against the uncontrolled release of radioactivity.
Soent Fuel Storaae 10.
FHSR paragraph 9.1.3.3.3 provides typical values for SFP chemistry (pH-6.9, conductivity-0.3 mhos/cm, and turbidity-20 ppb).
- a. Name the site procedure that implements FHSR chapter 9.1.3.3.3 that provides for SFP water chemistry control and provide a briet statement as to the actions required if SFP chemistry is out of specification,
- b. Place your SFP water chemistry control activities as a " program" under proposed TS 6.6.2. See comment 81.
- c. FHSR paragraph 9.1.3.4 describes SFP make-up water sources. Briefly describe whether these make-up water sources are required to have the same water purity requirements as the water in the SFP. See similar comment 23b.
11.
DTS 4.1.1.a Justify the consistency of the following LCO and Surveillance.
3.1.1.a "The water level in the Spent Fuel Pool will be maintained above the elevation of the syphon breaker (630' 4")."
4.1.1.a "Approximately once per four hours, the water levelin the Spent Fuel pool will be determined to be equal to or greater than its minimum required depth."
12.
DTS Bases 3.1.1.b
- n. Describe why the DTS bases does not provide additional detail as to the margin of safety between the TS SFP temperature limit (40150'F) and the temperature in which concrete degradation will begin (150'F in FHSR 9.1.3.4.2, revision 6) and temperature at which there is a criticality concern.
- b. Describe where the " minimum specified temperature of 40 degrees"is specified; FHSR 9.1.2.1.2, revision 6, describes " nominal conditions of 68 degrees."
l 6
13.
DTS 3.1.1.c Describe your basis for removing the following from your original TS 6.4.2 f
requirement: (1) the alarm in the control room; (2) the ability for having the I
instrument recorded; (3) the reduction from two instruments to one instrument; and (4) the requirement to have two instruments operable during fuel handling. See comment 16b.
14.
DTS 3.1.1 Action i 10 CFR 50.36(C)(2) states that if an LCO is not met, the licensee will follow any remedial action permitted by the TS until the condition can be met.
Justify why a time to initiate restoration of SFP water level (i.e., immediately) and a l
time when SFP water level needs to be restored to greater than or equal to 630'4" (i.e.,24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) are not provided. Or, justify why refill time requirements are not l
l necessary.
I 15.
DTS 3.1.1 Action il 10 CFR 50.36(C)(2) states that if an LCO is not met, the licensee will follow any remedial action permitted by the TS until the condition can be met.
Justify why a time (such as "immediately") is not identified in the LCO when the -
Actions must be initiated to restore acceptable SFP water temperature and when temperature must be restored (such as within seven days) is not provided. Or, justify why a 24-hour delay is acceptable, if temperature falls below 40'F.
If temperature were to fall below 40*F, discuss whether this would represent an unreviewed safety question.
16.
DTS 3.1.1.lii
- a. Justify why the alternate method of monitoring SFP radiation area radiation levels need not be immediate.
- b. Justify why communications with the control room are not required, when persons are stationed in the vicinity of the SFP with an inoperable radiation monitor, since one function of this radiation monitor is to alarm in the control room (see original TS 6.4.2 and comment 13).
l l
7 17.
DTS 4.1.1.a & b..
1 10 CFR 50.36(a)(3) states, in part, that surveillance requirements are to assure that limiting conditions for operation will be met.
Based only on the discussion provided in proposed DTS Bases 3/4.3.1.1, the NRC l
staff notes that 10 CFR 50.36(a)(3) could be met with a less frequent surveillance interval (i.e.,12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) than that proposed (a 4-hour surveillance interval), if determined by the licensee, plant procedures could then require a 4-hour surveillance interval to provide additional assurance of early detection of abnormal SFP conditions.
(
Justify the 4-hour surveillance frequency based on ALARA.
l 18.
DTS 4.1.1.b l
Briefly describe in the Bases for DTS 3.1.1/4.1.1 the limiting accident (s) or an event situation (s) that would result in approaching or exceeding the SFP water l
temperature limits.
19.
DTS 4.1.1.c.il l
Describe why the DTS proposes to use the surveillance interval of "once per 31 days" in TS 4.1,1.c.ii and " monthly" in DTS 4.1.2.a.ii.
i 20.
DTS Bases 4.1.1.c Describe where in 10 CFR 70.24(a)(2) does the regulation " approves" of the proposed " equivalent monitoring capability." If not, provide a revision to this DTS.
l 21.
DTS 3.1.2 t
l-l
- a. In proposed DTS 3.1.2.a, the BRP staff could either choose to operate with:
(Option 1) a " delayed" diesel make up water (MUW) supply in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> And an "immediate" offsite ac MUW supply OR (Option 2) a " delayed" electric MUW supply available in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, without entering the LCO Action statement.
l l.
Justify why Option 1 and Option 2 are equivalent in providing reasonable assurance that SFP MUW is available.
ii. Describe in the Bases for DTS 3.1.2 (first paragraph) whether the 24-hour MUW capability also includes allowance for SFP leakage and provides in the Bases an estimate of what SFP leakage is, if any.
iii. Describe in the Bases for DTS 3.1.2. (last paragraph) whether the 24-hour make up requirement to establish an alternate source is also based on
8
- leakage,
- b. Describe what is meant by the " spent fuel pool emergency makeup line" and "at the point the spent fuel pool emergency makeup line enters the spent fuel pool" (DTS 3.1.2.b).
- c. Describe whether the word "line" is required in DTS 4.1.2.b.ii.
22.
DTS 3.1.2, Applicability Original TS 4.2.11(b), last paragraph, stated that the " spent fuel pool makeup system will be operable whenever spent fuel is stored in the spent fuel pool..." and did not differentiate between spent fuel and spent fuel assemblies.
DTS 3.1.2, Applicability, states "When the spent fuel assemblies are stored in the Spent Fuel Pool." This DTS, therefore, differentiates between assemblies and spent fuel (pins).
Justify why the DTS proposes to reduce the previously approved TS requirement to only spent fuel assemblies when spent fuel pins could also be stored in the SFP.
23.
DTS Bases 3.1.2 l
- a. Describe what is meant by " Acceptable options" in the middle of the first paragraph.
- b. State the procedure that provides assurance that these make-up water sources have the proper flow and temperature requirements. See similar comment 10c.
- c. State whether BRP samples Lake Michigan water to substantiate that this potential water source has sufficient water purity for use in the BRP SFP.
24.
DTS 3.1.3
- a. Justify why the following previously-approved TS requirements (TS 4.2.11(b))
was removed from the proposed DTSs: " Spent fuel will be stored in the fuel storage racks in the spent fuel pool." See comment 53.
- b. Original TS 6.4.1(b), Table 7.6, and TS 13.2 requires a stack gas monitor for the SFP. Justify why an equivalent requirement is not proposed or why this original TS requirement was removed.
- c. Original TS 6.4.1(d), Table 7.6, and TS 13.2 requires a process liquid monitor for the SFP. Justify why an equivalent requirement is not pronosed or why this original TS requirement was removed.
c f*
I 1.
9 t
25.
DTS 3.1.3, Action Justify why other SFP activities (not just fuel handling operation) should not be halted, if materials have been inappropriately stored in the SFP. See similar comment 29b.
26.
DTS4'J List the BRP procedure that requires a periodic visualinspect~on of the SFP. Or, justify why TS 4.1.3 does not have a surveillance requirement that periodically insoects the SFP for conditions adverse to safe fuel storage.
27.
DTS 4.1.3.a i
Justify why a time requirement is not provided tc assure timely completion of this surveillance requirement for the storage of materials in the SFP.
28.
DTS 4.1.3.b Justify why a time requirement is not provided to assure timely completion of this surveillance requirement for the storage of fuel near the south wall.
l 29.
DTS 4.1.3.b, Bases f
l 1
I
- a. Justify in the Bases why DTS 4.1.3 need not be performed after " September 15, 1998."
l l
. b. Describe whether maintenance activities (that do not move fuel or do not involve l
' movement of components in the SFP) could result in not meeting this DTS. See similar comment 25.
l l
30.
DTS 3.2.1 Justify why an introductory phrase to this proposed DTS is not provided.
I 31.
DTS 3.2.1.a l
The original TS 3.7(b) list valves associated with containment isolation. Justify why a list of valves associated with Containment Closure are not provided or justify why this information was removed from the proposed DTSs. See similar comment 34.
32.
DTS 3.2.1.b, Bases Describe whether Containment Closure can be temporarily removed or defeated, if closure is required as a result of entry into an LCO Action statement or an abnormal condition (i.e., low SFP water level, out-of-specification SFP water temperature,
10 etc.). See similar comments 6 and 35c.
33.
DTS 3.2.1, Surveillance Requirements 10 CFR 50.36(a)(3) states that surveillance requirements are " requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation shall be within safety limits, and that the limiting condition for operation will be met."
- a. Justify why surveillance requirements are not provided to assure that LCO 3.2.1.a can be maintained.
- b. Justify why surveillance requirements are not provided to assure that LCO 3.2.1.b can be maintained.
34.
DTS 3.2.1, Surveillance Requirements 10 CFR 50.36(a)(3) states that surveillance requirements are " requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation shall be within safety limits, and that the limiting condition for operation will be met."
Original TS 7.6 Table, page 68, requires surveillance testing of the radiation monitor that caused automatic containment valve closure on high radiation levels. See similar comment 31 and 33.
Justify why the DTS proposes to remove this requirement.
35.
DTS 3.2.1, Bases
- a. Describe whether or not a " fuel handling accident" includes maintenance operations (i.e., highly radiative material removal) utilizing the 24-ton dry fuel transport cask,
- b. Describe what is meant by the twice-used word "significant" as used in DTS Bases 3.2.1a & b. For example, provided a comparison to 10 CFR Part 100 or i
j l
- c. Describe why Containment Closure can be temporarily removed or defeated during fuel handling and how this is controlled and why such a situation is acceptable. See similar comments 6 and 32.
36.
DTS 3.2.2 Original TS 4.2.11 required (1) manual guidance, (2) visual observation, and (3) water shielding for fuel handling.
L*
11 Justify why the proposed DTS reduces previously-approved requirements for the assurance of safe fuel handling, l
37.
DTS 3.2.2.b The NRC staff notes that the DTS limit of 50 mrem /hr in the SFP sock would not allow for any planned increase in radiation levels as a result of decommissioning activities.
See similar comment 40.
38.
DTS 3.2.2, Action a Justify why it is not necessary to suspend fuel handling activities in addition to placing the fuel assembly in a safe condition, if the LCO is not met.
39.
DTS 3.2.2, Action b Briefly describe the procedure and requirements regarding who makes the determination that fuel handling may resume, if it is determined that the increased I
radiation levels have not been caused by the handling of spent fuelin the spent fuel pool.
40.
DTS 4.2.2.a The NRC staff notes that the DTS limit of 50 mrem /hr in the SFP sock would not allow for any planned increase in radiation levels as a result of decommissioning activities.
Briefly state why BRP proposes to maintain this requirement. See comment 37.
41.
DTS 4.2.2, Surveillance Requirements
- a. Justify why the surveillance paragraphs do not correspond to the associated LCO.
- b. Original TS 7.4(j) required functional testing of the trip mechanism of the fuel transfer cask safety catch devise. Justify why this previously-approved TS requirement was removed from the proposed DTSs.
- c. If a surveillance is required for the fuel transfer trip mechanism, as discussed immediately above, justify why an LCO is not required.
42.
DTS Bases 3.2.2
- a. The Bases refers to placing the irradiated spent fuel assembly is an " analyzed
)
1
- )
I 12 1
configuration." Described whether this " analyzed configuration" is equivalent to the term " safe condition" as used in TS 3.2.2, Action a.
- b. Describe how " excessive contribution to radiation levels in the area" relates to ALARA.
l 43.
DTS 3.3.1 l
l
- a. Justify why Containment Closure should not be required during the conduct of l
heavy load operations.
j l
- b. FHSR paragraph 9.1.5.3 defines a heavy load as weighing more than 500 l
pounds. However, LCOs 3.3.1.a and 3.3.1.b are written exclusively for " loads exceeding 24 tons" and " fuel transfer cask, or other cask," respectively, l
Justify how and whether DTS 3.3.1 would apply to loads greater than 500 pounds.
' 44.
DTS 3.3.1.b.ili This DTS states that "No fuel shall be stored in the fuel storage racks adjacent to the cask handling area in the southwest corner of the spent fuel pool during cask handling operations."
Justify why this requirement is listed under subparagraph DTS 3.3.1.b and not as a l
separate subparagraph under DTS 3.3.1, since it would apply to heavy loads in general. See comment 48.
And/or, state why proposed DTS 3.3.1.b.iii is not listed under DTS 3.2.2, Fuel Handling.
45.
DTS Bases 3.3.1 Justify why the weight value corresponding to a heavy load (500 pounds) is not described in the DTS Bases.
46.
DTS Bases 3.3.1.a 10 CFR 36(a) states that a " summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application."
DTS Bases 3.3.1.a does not adequately describe the basis for the DTS requirement.
Propose bases for DTS 3.3.1.a that meets the 10 CFR 36(a) requirement.
4
O 13 47.
DTS Bases 3.3.1.b 10 CFR 36(a) states that a " summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application."
C'lS Bases 3.3.1.b does not adequately describe the basis for the DTS requirement.
Propose bases for DTS 3.3.1.b that meets the 10 CFR 36(a) requirement.
48.
DTS 4.3.1, Surveillance Requirements 10 CFR 50.36(a)(3) states that surveillance requirernents are " requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation shall be within safety limits, and that the limiting condition for operation will be met."
Justify why surveillances are not proposed for DTS 3.3.1.a and b.
49.
OTS 3.4.1 Bold p.ovided for example only.
- a. Justify why the DTS proposes to change from "100 microcurie or less of beta and/or gamma" to "100 microcurie of beta or gamma." See original TS 6.16.1.a.
- b. Justify why the DTS proposed to change from "O.005 microcuries or more" to "which exceeds 0.005 microcuries." See original TS 6.16.3.
- c. Justify why the DTS 4.4.1 proposes to change from testing for "lenhage and/or j
contamination" to testing for " contamination" only.
L 50.
DTS 3.4.1.1.a I
l Original TS 6.16.3 required a 30-day report to the Commhsion, if sealed source test l
results indicates greater than or equal to 0.005 microcuries of removable contamination.
Justify why DTSs 3.4.1.1.a and 6.7.4 proposes to decrease the periodicity of this report to annually " Prior to February 1."
51.
DTS 3.4.1 A number of original TS requirements were removed from the proposed DTS.
i Justify why the following previously-approved requirements (a-c) were removed and indicate and justify whether additional requirements are being proposed for deletion, i
1 l
14 "In the absence of a certificate...the source shall not be put into l
- a. TS 6.16.1.a use until tested."
- b. TS 6.16.2 "The test sample shall be taken from the sealed source or from the su.-f aces... stored on which one might expect contamination to accumulate." See similar comment 52.
" Records of the leak test results shall be kept...and maintained..."
- c. TS 6.16.2 52.
DTS Bases 4.4.1 Original TS 6.16.2 required leakage testing of the surfaces on which the sealed source is permanently mounted or stored. Proposed DTS Bases 4.4.1 states:
" Sealed sources which are continuously enclosed within a shielded mechanism (such as sealed sources within radiation monitoring devices) are considered to be stored and need not be tested unless they are removed..." See similar comment 51b.
Justify why the DTSs proposes to reduce this previously-approved TS requirement.
Desian Features 53.
DTS 5.2 The title of proposed DTS 5.2 is " Storage of Special Nuclear Material."
Original TS 4.2.11(b) indicates that spent fuel can be placed 'n a spent fuel inspection stand,if certain requirements are met. See similar comment 24a.
The NRC staff acknowledges that the original TS 4.2.11(b) inspections stand requirements are maintained in the proposed DTS, however, justify whether spent fuel can be " stored" in a fuel inspection station, as ind;cated by the proposed title of DTS 5.2.
54.
DTS 5.2.1 Original TS 5.1.5(a) described fuel enrichment as a function of uranium and plutonium.
FHSR paragraphs 9.1.2.1.1 and 9.1.2.1.2 provide uranium enrichment information.
Provide the FHSR paragraph that provides the plutonium enrichment or revise the FHSR and/or DTS to maintain this information.
15 55.
DTS 5.2.2 i
- a. Add the " feet" indication following "630" or justify the proposed DTS.
- b. This prcposed DTS states that the spent fuel poolis " designed to maintain a normal water level" of 630' 6."
Describe whether the proposed DTS 5 2.2 would allow for securing of SFP pumps. In particular, if 630' 6" would not support securing the SFP pumps, as plant procedures could allow, justify why proposed DTS 5.2.2 is accurate.
56.
DTS 5.2.3 Original TS 4.2.11(b) describes conditions associated with spent fuel storage and specifically states that spent fuel can be placed in inspection stations as long as design requirements are met.
Proposed DTS 5.2.3 states the design features asso :iated with spent fuel cooling in spent fuel storage racks and does not mention the inspection stand.
Justify whether the proposed design cooling description applies to spent fuel placed in an inspection station.
57.
DTS 5.2.4 i
Provide the name of the plant procedure that instructs where and how spent fuel j
pins could be stored in the SFP to assure adequate cooling and to prevent criticality.
Administrative Controls 58.
TS 6.1.1 l
Original TS 6.1.2 describes the Shift Suparvisor position.10 CFR 50.120 also describes the training program requirements associated with the Shift Supervisor position.
Justify why the description of SHIFT SUPERVISOR was removed from thn DTSs or restore an appropriate description / definition for this command and controi position.
See comment 68d.
59.
Deleted.
1 60.
DTS 6.2.1.b CPC-2A does not indicate nor describe any positic,n entitled " Senior Nuclear Officer," as used in DTS 6.2.1.b.
16
- a. Provide clarification as to the name of the position who the Site General Manager reports to (see CPC-2A, paragraph 1.2.2.b).
- b. Provide in the proposed DTS a position description for the individual the Site General Manager reports to.
l 61.
DTS 6.2.1 Original TS 6.2.1.d provides requirements for the operator training staff, stating specifically that individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager, however, they shall have sufficient organizational freedom to ensure their independence from operating pressures.
Justify why the proposed DTS reduces this previously-approved requirement that would be applicable to the Certified Fuel Handlers and radiation protection technicians during the conduct of decommissioning, Facility Oraanization 62.
DTS 6.2.2.a (DTS Table 6.21)
Original TS Table 6.2-1, " Minimum Shift Crew Composition," and associated requirements stated that shift staffing may go below the minimum staffing requirement for a period not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition.
This original TS also stated that "This provision does not permit any shift crew position to be unmanned upon hiiiit chango due to an oncommg shift crewman being late or absent."
Proposed DTS Table 6.21 does not provide or allow shift staffing to go below minimum requirements for less than two hours. Further, the DTS does not state that this provision only applies to onshift personnel and does not permit any shift crew position to be unmanned upon shift change due to on oncoming shift crew member being late or absent.
Justify why the proposed DTS does not provide for the above allowances and requirement.
63.
DTS 6.2.2.b l
10 CFR 50.120, " Training and Qualification of Nuclear Plant Personnel," establishes the regulatory requirements for the training of non-licensed operators (such as l
Certified Fuel Handlers) and Shift Supervisors.
l' L
I l
17 Justify why DTS 6.2.2.b. limits qualifications only to the " station's administrative procedures" and not a training program derived from a systems approach to training, as provided in DTS 6.4, " Training."
64.
DTS 6.2.2.c Original TS 6.2.2.d allowed the radiation protection (RP) coverage to be less than the minimum staffing for a period not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Justify why the minimum shift crew allowance does not apply to RP technicians.
65.
DTS 6.2.2.d Original TS 6.2.2.g(4) describes the TS process for exceeding the overtime requirements.
Justify why the proposed DTS 6.2.2.d(3) deletes reference to the Plant Manager's approval and review requirements.
66.
DTS 6.2.2.d, Footnote 1, page DTS 6-2 Name the procedure for the conduct heavy load coerations in or about the SFP.
Indicate whether there are overtime restrictions ta meiated with personnel conducting heavy load operations in and about the SFF.
67.
DTS 6.2.2.d The DTSs proposes to only limit overtime restrictions to persons who perform safety-related functions.
l
- a. Describe whether the overtime rr 'rictions apply to persons performing i
nonsafety-related activities, such as fuel handling, ISFSI cask operations, radiation protection coverage for dismantlement and decontamination, and non-licensed operators performing activities necessary for the safe storage, maintenance, and control of the spent fuel.
- b. Revise DTS 6.2.2.d to reflect the BRP position described in response to comment 67a.
68.
DTS Table 6.2-1 a.
10 CFR 50.120 establishes the training program requirements for non-licensed operators (Certified Fuel Handlers), maintenance personnel, radiation protection technicians, etc. This training program shall be based on a systems approach to training and reflect the status of the facility, technical specifications, etc.
18 Justify why the following Footnote 2 is required in the proposed DTSs:
2 The individual designated as the shift supervisor is not required to hold a Senior Reactor Operator License; however, if this individual does hold a valid Senior Reactor Operator license, or holds an SRO license limited to fuel handling, that individual will satisfy the requirements to have a Certified Fuel Handler on a shift."
- b. Describe whether the following Footnote 3 applies to the Shift Supervisor and Control Operator or just the Control Operator.
"3 Although the normal work station for this position is in the control room, the control room is not required to be staffed when the reactor is defueled."
- c. Regarding the above Footnote 3, provide a detailed justification why B3P would allow the control room to be unmanned during decommissioning and why the DTS proposes to reduce previously-approved control room staffing requirements (original TSs 6.2.2b & c).
- d. Footnote 1 for DTS Table 6.21, " Minimum Shift Crew Composition During Permanently Defueled Condition," states that at least one position (Shift Supervisor, Control Operator, or Auxiliary Operator) of the shift crew shall be filled by a Certified Fuel Handler.
Proposed DTS 6.2.2.b. states that "All fuel handling operations shall be directly supervised by a Certified Fuel Handler."
Footnote 3 on DTS page 6-4 (see comment 68b) states that the control room need not be staffed.
Comment 58 questions why the position description of the SHIFT SUPERVISOR is not provided in the proposed DTSs.
Provide a description of the command and controlline organization during fuel handling. This discussion should include: (1) who has overall command and control of f acility activities should a fuel handling ( c it injure or contaminate the Certified Fuel Handler; (2) a description of the relationship between the control room (which does not have to be staffed, as proposed by the DTS) and the Certified Fuel Handler performing fuel handling operations; and, (3) who is in charge of facility operations if the Certified Fuel Handler is injured and the control room is unmanned at that particular time.
Trainino 69.
Deleted.
19 Quality Assurance On September 19,1996, Consumers Energy provided a number of documents to the NRC staff, one of which was a request for amendment of their facility license, DPR 6, and associated technical specifications, Appendix A of DPR 6. Although Consumers provided a no significant hazards assessment, justification for the removal, deletion, or change of TS requirements was not provided. Further, Consumers did not provide confirmation that the previously-approved TS requirements (that were subsequently removed, deleted, or changed in the proposed DTS) were maintained in other documents.
Regarding quality assurr.;e, on October 10,1997, Consumers provided information regarding proposed changes to their quality assurance program and requested approval of these changes in accordance with 10 CFR 50.54(a)(3)(ii). These program changes included 1
changes, in part or in total, to TS sections 6.5, " Review and Audit," 6.8, " Procedures,"
l 6.9, " Reporting Requirements," 6.10, " Record Retention," and others. This submittal appeared to utilized the guidance provided in NRC Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Relating to Quality Assurance" and
/
provided justification for proposed TS changes associated with the September 19,1996, TS amendment request.
Notwithstanding the October 10,1997, request foi approval of quality assurance program changes, TS requirements remain in effect until amended by the Commission. Therefore, defacto approval of a quality assurant.e program change (10 CFR 50.54(a)(3)(iv)) does not represent Commission approval of a license amendment request (10 CFR 50.91). The NRC staff comments below represent staff review of the September 19,1997, license j
l amendment request, as supplemented by the information provided by the licenses m the October 19,1997, quality assurance program change request. Additionalinformation may be requested to support staff review of the license amendmant.
70.
Original TS 6.5.1.2 required that the Plant Review Committee (i.e., BRP Safety l
Review Committee) be compc. sed of representatives from various disciplines such as radiation protection, engineering, maintenance, operations, and licensing.
l CPC-2A, " Quality Assurance Program Description for Nuclear Plants," rev.19a, Appendix B, B2, second paragraph, does not retain the requirement that the CRP SRP be composed of individuals representing various disciplines, such as fuel handling and storage, engineeririg, radiation protection, quality assurance, etc.
Justify why the previously-approved TS requirement is not maintained.
t 71.
The current TS 10.0 (Section 6.0) Administrative Controls 6.8.3 required approval of ternporary procedure changes at the next scheduled PRC meeting which is at least once a calender month (TS 6.5.1.4).
CPC-2A, rev.19a, Appendix A, Paa 1, ipag.' 48) Item 2h, Exception / interpretation c, E.,ows tempc,r/ procedure changes to take up to three 9
^
20 (3) months before the PRC reviews the change (s).
Justify why a monthly review is not needed for temporary procedure changes, where " temporary" means a month or less.
72, 10 CFR 50.48(f)(2) states that the fire protection program shall be assessed by the licensee on a regular basis.
CPC-2A, rev.19a, Appendix C, C4.1.) states that the ISRG shall review the fire protection program and implementing procedures changes for Palisades only.
State whetner such a fire protection review is performed for the BRP facility and the licensee procedure that provides instructions and assurance that the fire protection program will be assessed on a regular basis.
73.
CPC-2A, rev.19a, Appendix E, E3.h, states that records of changes, tests and experiments purcuant to 10 CFR 50.59 shall be retained.
Justify why CPC-2A does not require the retention of records associated with evaluations made pursuant to 10 CFR 50.82(s)(6) and (7).
74.
Original TS 6.10.2.g. required that records be retained for inservice inspections.
!!evision 19a of CPC-2A, Appendix E, E3.f states that records shall be retained for inservice inspections.
I The NRC notes that the proposed DTS has deleted all reference to the conduct of an inservice inspection and test program (original TS 9.0, see Comment 4).
Clarify or correct either CPC-2A and/or the proposed DTS to reflect whether the records associated with inservice testing and inspection shall be retained.
75.
CPC-2A, rev.19a, Appendix E, E3.m, rtates that records for environmental qualification which are covered under the provisions of 10 CFR 50.49 shall be retained for BRP only.
10 CFR 50.49(a), Environmental Qualification, states that licensees that have provided the certifications required under 10 CFR 50.82(a) need not establish an environmental qualification program.
Justify why records for environmental qualification are required for BRP.
76.
DTS 6.6.2.3, Process Control Program (PCP)
Original TS 6.14 required that changes to the PCP be reviewed by the Nuclear Operations Department (NOD) per CPC-2A.
l 7,
21 CPC-2A, rev.19a, Appendix E, E3.p, states that records of reviews performed for changes made to the Offsite Dose Calculation Manual (ODCM) and the PCP shall be retained for Palisades only.
DTS 6.6.2.3 proposes to remove the requirement for NOD review of changes made to the PCP.
i Justify why the DTS pr0 poses to remove previously-approved requirement and why CPC-2A does not maintain the requirement for NOD review.
77.
Original TS 6.15 Original TS 6.15 required that changes to the ODCM be reviewed by the NOD per CPC-2A.
CPC-2A, rev.19a, Appendix E, E3.j, states that records of reviews performed for changes made to the ODCM and ths PCP shall be retained for Palisades only.
DTS 6.6.2.3 rroposed to remove the requirement for NOD review of changns made to the ODCM.
I
'ustify why the DTS proposes to remove previously approved requirement and why l-CPC-2A doec not maintain the NOD review requirement.
1 Procedures i
78.
DTS 6.6.1.1 l
l Original TS 6.8.1 required procedures for "all structures, systems, and components and safety actions described in the Big Rock Point Quality List."
Original TS 7.0, " Operating Procedures," required procedures for " principles and procedural safeguards which have a potential effect on safety...for normal and emergency operation of the plant."
Original TS 7.4(a) required detailed procedures for refueling outages, which would include fuel handling procedures.
Proposed DTS 6.6.1.1 states:
" Written procedures shall be established, implemented and maintained for safety-related structures, systems and components and safety actions defined in the Big Rock Point Quality List. These procedures shall meet or exceed the requirements of ANSI N18.7[-1972), as endorsed by the Quality Program Description (CPC-2A)."
- a. Justify why the original TS requirements for procedures were reduced and why i
l 22 BRP proposes to have procedures for only safety-related SSCs and activities,
- b. Indicate the ANSI N18.7 reference date (as shown in the brackets above).
- c. Provide a statement under proposed DTS 6.6.1.1 that ties the requirement to have procedures to the requirement to have programs (proposed DTS 6.6.2).
For example:
" Written procedures shall also be established, smplemented, and maintained covering the following activities:
- a. Site security plan;
- b. Site emergency plan; Quality assurance far radiological effluent and environmental c.
monitoring; and,
- d. All programs listed in Specification 6.6.2."
Proarams 79.
10 CFR 50, Appendix A, Introduction, states that SSCs important to safety are SSCs that provide reasonable assuranco that the facility can be operated without undue risk to the health and safety of the public.
10 CFR 50, Appendix A, Criterion 1, states that a quality assurar ce program shall be established and implemented in order to provide adequate assurance that SSCs important to safety will satisfactorily perform their safety functio 1s and that appropriate records are maintained.
The NRC staff is aware that BRP maintains and implements a quality assurance program. As stated in CPC-2A, CPC-2A predominately pertains to safety-related SSCs, however, in Revision 19a to CPC-2A, the program scope was increased to include decommissioning.
- a. Justify why CPC-2A is not referenced as a program under DTS 6.6.2,
" PROGRAMS."
- b. State whether CPC-2A applies to SSCs that are not safety-related,'but are important to safety, in that, they provide reasonable assurance that the facility can be operated without undue risk to the health and safety of the public.
These nonsafety-related SSCs could include, but are not limited to, those SSCs necessary for spent fuel storage, contiol and maintenance, and radiological effluent control and monitoring.
- c. Depending on the answer to a and b directly above, propose a revision to the DTS the address the particular comment.
l
1 I
23 80.
The NRC staff is aware that BRP maintains and implements a procedure that assures cold weather protection of plant SSCs. However, to provide further assurance that conditions adverse to decommissioning or to the safe storage of irradiated fuel do not occur, justify why a Cold Weather Protection Program was not proposed under DTS 6.6.2.
81.
The NRC staff is aware that BRP maintains and implements a procedure that assures proper water chemistry control for the SFP. However, to provided further assurance that conditions adverse to the safe storage of spent fuel do not occur, justify why a SFP Water Chemistry Control Program was not proposed under DTS 6.6.2.
Radiation Areas 82.
DTS 6.6.2.2.1. and 6.6.2.2.2
- a. Justify why the proposed TS do r'ot address dose rates " equal" to 1000 mrem / hour.
- b. Depending on the resolution of' comment 82a. propose a corrcction to the appropriate DTS paragraphs.
l l
Radioloaical Effluent Controls Proaram (RECP) and Radioloaical Environmental Monitorina Program (REMP) 83.
The NRC staff notes that it appears that the licensee used the information provided in Generic Letter (GL) 89-01, entitled " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specification and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program," and associated NUREG-1302, entitled "Offsite Dose Calculation Manual Guidance:
Standard Radiological Effluent Controls for Be ling Water Reactors," to relocated the TS information regarding thers topics to procedures and programs. _Therefore, l
respond to comments 84 - 87 and:
' a. Provide confirmation that the procedural details covered in the current BRP RETS, consisting of the limiting conditions for operation, their applicability, remedial actions, surveillance requirements, and the Bases section of the TSs for these requirements, were relocated to the ODCM, PCP, RECP, and REMP as appropriate and in a manner that ensures that these details will be incorporated in applicable procedures; and,
- b. Provide a summary listing of each change, other than editorial change, made during the transfer of details from the TSs to applicable procedures and programs; this summary listing should include a simple explanation why the change or deletion was made.
1 24 84.
The DTS 6.6.2.5 proposes to utilize "old" 10 CFR Part 20 requirements.
Justify why the "new" 10 CFR Part 20 requirements were not proposed for the
' following DTS.
- a. DTS 6.6.2.5.b
" Limitations on the concentrations of radioactive material released in liquid effluents to UNRESTRICTED AREAS conforming to 10 CFR Part 20, Appendix B, Table ll, Column 2,"
' b. DTS 6.6.2.5.c
" Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.106."
- c. DTS 6.6.2.5.g
" Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas beyond the SITE BOUNDARY."
85.
DTS 6.6.2.5.g Original TS 6.4.1(e) required an in-plant radio-lodine measurement system for accident conditions and sets forth surveillance requirements for this system.
The NRC staff notes that the lodines at the BRP facility may have decayed to a point where the requirement (comment 84c) is no longer applicable; however, this may not be the case for tritium and radionuclides in particulate form located in the SFP.
- a. Justify why the DTS proposes to remove the limits associated with iodinet, tritium, and radioactive particulates, as referenced above.
- b. Justify whether the radio-iodine measurement system is no longer applicable or refer to the DTS program that maintains this system.
86.
Original TS 13.1.6.3 Original TS 13.1.6.3 required " Cumulative dose contributions from direct radiation from the reactor units and from radwaste storage tanks shall be determined in accordance with the methodology and parameters in the ODCM. This requirement is applicable only under conditions set forth ir. Specification 13.1.6.1."
State whether original TS 13.1.6.3 is incorporated into proposed DTS 6.6.2.5.1, or justify 'why this requirement was deleted.
h
25 87.
Original TS 6.4.1 Original TS 6.4.1 required a stack gas monitoring system.
j Revision 7 to the FHSR, Chapter 11.5.2, describes the stack gas monitoring system.
State whether the original TS requirement for the stack gas monitoring system is maintained in the proposed DTS programs (i.e., the PCP or RECP) or justify why this
)
requirement was deleted.
I fire Protection Prcoram 88.
The NRC staff notes that it appears that BRP utilized the information provided in GL 86-10, implementation of Fire Protection Requirements," and GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications" for the proposed removal of fire protection TS requirements from Append;x A of license DPR-6.
Further, it appears that the licensee proposes to implement a fire protection program consistent with 10 CFR 50.48(f) to reflect the permanently shut down and defueled condition of the BRP facility.
On February 12,1998, the licensee submitted Revision 7 to their Updated Final Hazards Summary Report, in accoraance with 10 CFR 50.71, reflecting the permanently shut down and defueled condition of the BRP facility. Chapter 9.5.1, Tire Protection System (FPS) General," of the FHSR provides descriptions, operability and surveillance requirements, and Bases for instrumentation, suppression, instrumentation, fire water pumps and piping systems, spray and sprinkler systems, hose stations, barriers and penetration seals, fire brigade, plant lighting, etc. Using the guidance provided in GL 88-12, the NRC staff does not
{
intend to repeat its review of the approved Fire Protection Program !ncorporated in the updated FHSR. Therefore:
- a. Provios confirmation that the orc,cedui,1 details covered in the current BRP TS, consisting of the limiting conditio's for operation, their applicability, remedial actions, surveillance require nents, and the Bases section of the TSs for these requirements, were relocated to the facility's fire protection program as appropriate and in a manner that ensures that these details are incorporated in applicable procedures; and,
- b. Provide a summary listing of each change, other than editorial change, made during the transfer of details from the TSs to applicable procedures and programs; this summary listing should include a simple explanation why the change or deletior was made or reference to the applicable FHSR paragraph (s).
26 Reoortina Reauirements Original TS 6.9.3 required a special report for inservice inspection, fire system, high-89.
range containment gamma monitoring, and stack gas monitoring.
- a. If the particular reporting requirements are maintained, describe the licensee document that assures that the proper reports are made,
- b. If the particular requirement is proposed for deletion, justify why the requirement is no longer necessary.
Electrical Power Sources 90.
Original TS 11.3.5.3.B states that during " power and refueling operations the 2400 volt bus under voltage components shall be operable or placed in a tripped condition, except during the monthly channel testing period."
l The NRC staff, in general, considers refueling and fuel handling synonymous.
f
- a. Justify why this previously-approved TS requirement is no longer necessary.
- b. Justify why an electrical DTS was not proposed.
1
(
Coolina Water Svstems 91.
Original TS 4.2.5 stated that the " reactor cooling water system shall be a closed cooling loop utilizing inhibited demineralized water to remove heat from" a number of systems, one of which included the fuel pit cooling water heat exchanger. In addition, TS 4.2.5 states design flow and heat exchange parameters for the cooling water pumps and heat exchangers.
Justify why these requirements are not provided in the proposed DTS.
Administrative Comments 1.
DTS 4.0.2 Correct the word "per cent."
2.
DTS General Comment Ensure consistent capitalization of the phrase " spent f uel pool."
3.
DTS 3.1.1, Action i.
Peplace " requirements" with " requirement."