ML18065A438

Application for Amend to License DPR-20,revising TS to Allow Use of 10CFR50 App J Option B Containment Testing & Use of Warning Light to Identify Certain High Radiation Areas,To Suppl 951211 Administrative Controls Change Request

ML18065A438
Person / Time
Site:	Palisades
Issue date:	01/18/1996
From:	Smedley R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18065A439	List: ML18065A438 ML18065A441
References
NUDOCS 9601250083
Download: ML18065A438 (6)

Text

• POWERiNii MICHlliAN"S PROliRESS Palisades Nuclear Plant: 27760 Blue Star Memorial Highway, Covert, Ml 49043 January 18, 1996 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - REVISION OF ADMINISTRATIVE CONTROLS

- ADDITIONAL CHANGES A request for a change to the Palisades Technical Specifications Administrative Controls was submitted on December 11, 1995. During the time that change request was being developed, the industry and the NRC were developing guidance for changing Technical Specifications to allow usage of the newly approved 10 CFR 50, Appendix J "Option B" containment testing. In addition, Palisades is in the process of developing a Technical Specification change request to convert to Standard Technical Specifications. These two efforts have resulted in two additional changes to the December 11, 1995 change request.

The first change adds a Containment Leak Rate Testing Program to the Administrative Controls section and revises the containment leak rate testing surveillance requirements to allow use of "Option B" testing. The second change revises the Administrative Controls for High Radiation Areas to incorporate the Standard Technical Specification High Radiation Area controls which allow for certain High Radiation areas to be identified by posting and a flashing light, rather than by being enclosed and locked.

/--- ----96012500a3--96Cfi1B ---- ------ --

PDR ADOCK 05000255 p PDR

-250034 A<bf1/S~COMPANY

SUMMARY

OF COMMITMENTS This letter establishes no new commitments and makes no revisions to existing commitments.

Richard W Smedley Manager, Licensing CC Administrator, Region Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector - Palisades Enclosure

ENCLOSURE CONSUMERS POWER COMPANY PALISADES PLANT DOCKET 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST ADMINISTRATIVE CONTROLS ADDITIONAL CHANGES 3 Pages

.! CONSUMERS POWER COMPANY Docket 5.0-255 Request for Change to the Technical Specifications License DPR-20 It is requested that the Technic~ Specifications (TS) contained in the Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described below. These proposed changes allow use of 10 CFR 50 Appendix J "Option B" testing and use of a warning light to identify certain High Radiation Areas.

Two attachments are included.with this TS change request:

1. The proposed TS pages

2. Existing pages marked to show the proposed changes This change requests supplements the Administrative Controls change request submitted on December 11; 1995. The pages provided in the attachments replace the respective pages of the December 11, 1995, submittal.

I. Changes Proposed:

1. Changes have been proposed to allow containment Type A leak rate testiflg to be performed in accordance with 10 CFR 50, Appendix J, Option B. Surveillance requirement 4.5.1; Integrated Leakage Rate Tests, has been revised to require that Type A containment testing to be performed in accordance with a newly added "Containment Leak Rate Testing Program". The Containment Leak Rate Testing Program has been added to the Administrative Controls section as item 6.5.14. The wording of .the proposed program. i.s very similar to that contained in the model Technical Specifications developed by the NRC and NEI. The proposed wording specifies that Type A testing be performed in accordance with Option B, and Type B and C testing be performed in accordance with Option A.

These changes are administrative in nature, and involve no change in testing methodology. They simply implement the newly approved Option B testing frequency for Type A testing. This option is desired for Type A testing*because it avoids unnecessary testing and thereby affords a reduC:tion in costs, outage tiine, and personnel radiation exposure. The-Type B and C testing will continue to be performed in accordan~e with Option A because no evaluation has yet been performed to determine the impact of changi~g these tests to Option B.

2. A change i~ proposed to th~ Administrative Controls for High Radiation Areas. Section 6.7 of the proposed Technical Specifications (corresponding to section 6.12 of the existing Technical Specifications) has been revised to use the wording from the CE Standard Technical Specifications, NUREG 1432, Revision 1 (STS). The major change in requirements due to this change is the addition of paragraph 6.7.3 (5.7.3 ifl STS) which allo~s high radiation areas, greater than 1ooo*mrem per hour, inside large areas such as the containment, where no enclosure exists for purposes of locking, to be controlled by barricading and posting, and identified with a flashin9 light. The current Technical Specifications require that high radiation areas be locked. Construction of lockable enclosures, solely for the purpose of bounding high radiation areas incurs both significant cost and personnel radiati.o.n exposure.

II.

Reasons for Changes:

• 2 These changes are administrative in nature~ They are intended to provide the following benefits:

1. Reduction in personnel radiation exposure,

2. Reduction in -0utage time and the associated purchase power costs.

3. Reduction in direct costs associated with unnecessarily frequent testing and with cori~truction of lockable enclosures around certain high radiation areas.

III. Analysis of No Significant*Hazards Consideration Consumers Power Company*finds that this proposed Technical Specifications change involves no significant hazards and, accordingly, that a no significant hazards determination per 10CFR50.92(c) is justified.

Both of the proposed changes involve substituting requirements from NRC model Technical Specifications or from the Standard Technical Specifications. Neither change alters plant equipment or settings, operation of the plant, or the methods of testing plant equipment. The change allowing containment testing in accordance with Option B implements an NRC approved testing frequency whi~h is intended to eliminate unnecessary testing where prior testing experience shows that no significant increase in.containment leakage (and thereby consequences of an accident) would occur. The change to High Radiation Area controls simply substitutes one administrative control method for another; the intended result, avoiding inadvertent entry into a high radiation area, is unchanged. Therefore, operation of the facility in accordance with the proposed changes cannot involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any previously evaluated, or involve a significant reduction in a m~rgin of safety.

IV. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specifications Change Request and has determined that proposing this change does not involve an unreviewed safety question. Further, the change involves no significant h~zards consideration. This change has been reviewed by the Nuclear Performance Assessment Department.

CONSUMERS POWER COMPANY

• 3 To the best of my knowledge, the contents of this Technical Specifications change request, which revises the Administrative Controls section to emulate STS and to allow use of 10 CFR 50, Appendix J, Option B testing, are truthful and complete.

By Q ).. .fc:s <;::? ~

Richard W. Smedley ~

Manager, Licensing Sworn and subscr;bed to before me th;s ~day of ~ 1996.

~~~*CkJ~

. Alora M. Davis, Notary Public Berrien County, Michigan (Acti~g in Van Buren County, Michigan)

My commission expires August 26, 1999

/ !

"' [SEAL]

• 1 / ~ * .J  ;