ML20244D611

Responds to Request for Addl Info Re Tech Spec Change Requests Dtd 870723,880908 & 0922.Specs Cover Inservice Insp & Testing,Fire Spray &/Or Sprinkler Sys & Plant Staff Qualifications

ML20244D611
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	04/12/1989
From:	Marbaugh K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GL-88-06, GL-88-6, NUDOCS 8904240029
Download: ML20244D611 (8)

Text

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MKH8GAN5 PRGGRE55 POVVer 90%TRING oeneral Offices; 1945 West Parnali Road, Jackson, MI 49201 * (517) 788-0550 April 12, 1989-Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO VERBAL REQUEST FOR ADDITIONAL INFORMATION (RAI)

ON TECHNICAL SPECIFICATION CHANGE REQUESTS DATED JULY 23, 1987, SEPTEMBER 8, 1988, AND SEPTEMBER 22, 1988 i

NRC Staff review of Consumers Power Company submittals dated July 23, 1987, September 8, 1988, and September 22, 1988 requested additional information to resolve reviewer comments on.the wording of certain sections. These comments were discussed with appropriate plant staff. This letter provides Consumers Power Company's responses to the NRC Staff's suggestions for revision, as discussed below.

The Technical Specification Change Request submitted by the July 23, 1987 letter was to make several Administrative Corrections. NRC staff had three comments on this submittal:

1. Changes K., U., and V. corrected reference to section 6.9.4 to be 6.9.3. Two additional instances were found where the same correction is necessary, being sections 9.3(b) and (12) 3.7.11.2(a), and (b) .

Revised pages 92 and 154 (proposed) are included with this letter.

2. Change R. requested removal of "As Modified by Order Dated October 24, 1980 (Attached Hereto)" from the license signature page.

Consumers Power Company understands from the reviewer's comment that this had already been deleted from the official license maintained by NRC, and deletion from copies issued by Consumers Power Company is acceptable.

3. Change E. requested removal of a portion of a footnote concerning set point drift correction of water level monitoring instruments. Plant staff have considered the reviewer's comment and agree that the first portion of the sentence being deleted should be retained. The footnote will thus include the statement: " Set point drift between OC0489-0117-NLO4 Ok 8904240029 89041 i' l PDR ADOCK O Oc A C%G EN67PGYCOMPANY b P

e at Nuclear Regulatory. Commission 2 Big

• Rock Point Plant L Additional.Information on TSCRs April 12, 1989 calibration chechs within the specified tolerance limit shall be corrected." A revised page 51 (proposed) is included with this letter.

'The Technical Specification Change Request submitted by the September 8, 1988 letter was to remove organization charts, consistent with NRC Generic Letter 88-06 guidance. Item I.E. in the description of changes refers to NFPA-Code-1974, while the proposed Technical Specification page refers to NFPA Code-1975. It has been verified that the proposed page.is correct, ie, the proper reference is NFPA Code-1975. In addition, the reviewer identified a

, concern that the transfer of the information in footnote -(b) of the " Plant Organization" chart on page 105 to the new section 6.3.4 on proposed page 107 did not meet the guidance provided in Discussion Item (4) of the Generic Letter. Consumers Power. Company has determined that, even though Nuclear Operations Department Standards and Big Rock' Point Administrative Procedures specify the positions that must hold a Senior Reactor Operators license (SRO),

the proposed change on page 107 will be modified to include specific designation that "Either the Production & Performance Superintendent or the Operations Supervisor shall hold a SRO." A corrected page 107 (proposed) is attached to this letter. No other sections of the Technical Specifications than those addressed in the September 8, 1988 letter, as supplemented, are affected by the removal of organization charts.

The Technical Specification Change Request submitted by the September 22, 1988 letter was to allow the independent review function to be accomplished by an organizational unit, instead of a standing committee. The NRC reviewer commented that the change described for section 6.5.2.4.2(c) in the Request did not match the wording supplied as proposed on page 112. It has been determined that the Request wording is correct, and a revised page 112 (proposed) is included with this letter.

Kenneth E Marbaugh Plent Licensing Engineer CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point Attachment OC0489-0117-NLO4

I I

ATTACHMENT Consumers Power Company Big Rock Point Plant Docket 50-155 CORRECTED PROPOSED TECHNICAL SPECIFICATION PAGES April 12, 1989 5 Pages TSB0489-0117-NLO4

' . . 92 9.0 INSERVICE INSPECTION AND TESTING 9.1 APPLICABILITY Applies to inservice inspection and testing of the reactor vessel and other ASME Code Class 1 Class 2 and Class 3 system components.

9.2 OBJECTIVE To insure the integrity of the Class 1, Class 2 and Class 3 piping systems and components.

9.3 SPECIFICATIONS

a. Inservice Inspection of ASME Code Class 1, 2 and 3 components and inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50, Section 50.55a(g),.except where specific written relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(i), snd where provisions of Sections 11.4.1.4, 4.1.5 and 11.4.3.4 take precedence.

b. Sufficient records of each inspection shall be kept to allow comparison and evaluation of future tests. (See also Sections 6.9.3 and 6.10.2.g.) /

c. The inservice inspection program shall be reevaluated as required by 10 CFR 50, Section 50.55a(g)(5) to consider incorporation of new inspection techniques that have been proven practical, and the conclusions of the evaluation shall be used as appropriate to update the inspection program.

d. A surveillance program to monitor radiation induced changes in the mechanical and impact properties of the reactor vessel materials shall be maintained as described in Section 4.1.1(h) of these Technical Specifications.

9.4 BASIS i

The inspection program implementsSection XI of the ASME Boiler 1 and Pressure Vessel Code to the maximum extent practical. It is recognized that plant design a0d construction were completsd approximately seven years prior to he development of Section XI and it is, therefore, not possible to comply fully with the code.

Proposed j I

1 TSB0489-0117-NLO4 l

__-_____A

PLANT SYSTEMS i FIRE SPRAY AND/OR SPRINKLER SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.11.2 The spray and/or sprinkler systems located in the following areas shall be OPERABLE.

a. Cable Spreading area under the control room,

b. Exterior cable penetration area.

c. Recirculation pump sump area.

APPLICABILITY: At all times when the equipment in the area is required.

ACTIONS:

a. With one or more of the-spray and/or sprinkler systems required by a or b above inoperable 7'istablish a continuous fire watch with backup fire suppression equipment for the unprotected area (s) within one (1) hour; restore the system to OPERABLE status within 14 days or, in lieu of any other report required by Specification 6.9.2, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.3 within /

the next 30 days outlining the action taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status,

b. With the spray and/or sprinkler system required by c. above inoperable, stage backup fire suppression equipment for the area within one (1) hour.

If the inoperable condition is due to equipment outside the recirculation pump room, restore the system to OPERABLE status within 14 days or, in lieu of any other report required by Specification 6.9.2, prepare and submit a Special Report to the Commission pursuant to Specification 6.9.3 /

within the next 30 days outlining the action to be taken, the cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status. If the inoperable condition is due to equipment inside the recirculation pump room, restore the system to OPERABLE status before the next start-up from cold shutdown. If the system is not returned to OPERABLE status within 14 days, submit, in lieu of any other report required by Specification 6.9.2, a Special Report to the Commission pursuant to Specification 6.9.3 within the next 30 days outlining the /

cause of the inoperability and the plans and schedule for restoring the system to OPERABLE status.

SURVEILLANCE REQUIREMENTS 4.7.11.2 The spray and/or sprinkler systems shall be demonstrated to be OPERABLE:

a. Once per 18 months:

1. By visual inspection of spray headers to verify their integrity.

2. By visual inspection of each nozzle to verify no external blockage.

b. Once per three (3) years by an airflow test of the open head I spray and/or open head sprinkler system and verifying each open head spray and/or sprinkler nozzle is unobstructed.

NOTE: The airflow test requirement is not applicable to the closed head recirculation pump sump area system.

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3 ADMINISTRATIVE CONTROLS l

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PLANT STAFF QUALIFICATIONS (continued) /

/

6.3.4 Either the Production & Performance Superintendent or the /

Operations Supervisor shall hold a Senior Reactor Operator /

license. The individual holding the Senior Reactor Operator /

license shall be responsible for directing the activities of /

licensed operators. He shall meet the other requirements of /

Section 6.3.1 (as applicable to Operations Manager in ANSI N18.1). /

6.4 TRAINING 6.4.1 A retraining and replacement training program for the plant staff shall be maintained and implemented and shall meet or exceed the /

requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and 10 CFR 55. //

6.4.2 A fire brigade training program shall be maintained and implemented /

and shall, as practicable, meet or exceed the requirements of /

Section 27 of the NFPA Code-1975. Fire Brigade training drills shall be held at least quarterly. ,

6.5 REVIEW AND AUDIT 6.5.1 PLANT REVIEW COMMITTEE (PRC)

FUNCTION 6.5.1.1 The Plant Review Committee (PRC) shall function to advise the Plant Manager on all matters related to nuclear safety. //

COMPOSITION 6.5.1.2 The PRC shall be composed of:

Chairman: Plant Manager or Designated Alternate Appointed by the //

the Plant Manager. //

Member: Production & Performance Superintendent Member: Maintenance Superintendent /

Member: Engineering Superintendent /

Member: Operations Supervisor Member: Instrument and Control Supervisor Member: Reactor Engineer Member: Chemistry and Health Physics Superintendent Member: Shift Supervisor Member: Technical Engineer 107 Proposed Proposed by CR of 7/23/87 TSB0489-0117-NLO4

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-ADMINISTRATIVE CONTROLS I

AUDITS 6.5.2.4.2 (Continued) /

/

c. The performance of activities required by the Quality /

Assurance Program Description for Operational Nuclear /

Power. Plants (CPC-2A) to meet the criteria of /

10 CFR 50, Appendix B, at least once per 24 months. /

/

d. The Site Energency Plan and implementing procedures at /

least once per 12 months. /

/

e. The Site Security Plan and implementing procedures (as /

required by the Site Security Plan) at least once per /

12 months. /

/

f. Any other area of plant operation considered appropriate /

by NSSD or the Vice President - Nuclear Operations. /

/ '

g. The plant Fire Protection Program and implementing /

procedures at least once per 24 months. /

/

h. An independent fire protection and loss prevention /

inspection and audit shall be performed annually /

utilizing either qualified offsite licensee personnel /'

or an outside fire protection firm. /

/

1. An inspection and audit of the fire protection and loss /

prevention program shall be performed by an outside /

qualified fire consultant at intervals no greater than /

3 years. /

/

j. The Radiological Environmental Monitoring Program and /

the results thereof at least once per 12 months. /

/

k. The Offsite Dose Calculation Manual and implementing /

procedures at least once per 24 months. / ,

/

1. The Process Control Program and implementing procedures /

for processing and packaging of radioactive wastes at /

least once per 24 months. /

/

Audit reports encompassed by 6.5.2.4.2 above shall be /

forwarded to the NSSD, and management positions responsible /

for the areas audited within thirty (30) days after /

completion of the audit. /

/

6.5.2.4.3 NSSD review of the subjects in Specifications 6.5.2.4.1 /

and 6.5.2.4.2 shall be carried out by an assigned lead /

reviewer selected on the basis of his technical expertise /

relative to the subject being reviewed. A second level /

review shall also be performed. If the lead reviewer or /

second-level reviewer determines the need for interdiscip- /

linary review, additional reviewers shall be assigned. /

112 Proposed TSB0489-0117-NLO4

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