ML18067A468

Provides Addl Info & Revised TS Pp to Support Completion of Administrative Control Changes Review Proposed in 951211 Safety Evaluation for Amend 174

ML18067A468
Person / Time
Site:	Palisades
Issue date:	03/28/1997
From:	BORDINE T C CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18067A469	List: ML18067A468 ML18067A470
References
NUDOCS 9704070091
Download: ML18067A468 (6)

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l'llWERINli MICHlliAN"S PROliRES5 Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 March 28, 1997 U S Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT Thomas C. Bordine Manager; Licensing TECHNICAL SPECIFICATION CHANGE REQUEST -ADMINISTRATIVE CONTROLS -REVISED PAGES FOR CHANGES STILL UNDER REVIEW Consumers Power Company submitted a Technical Specifications change request proposing revision of the Administrative Controls section on December 11, 1995. On October 31, 1996, the NRC issued Amendment 17 4 to tile Palisades Facility Operating License. As discussed in section 3. 5 of the Safety Evaluation for Amendment 17 4, several of the changes proposed in the December 11, 1995, request were not included in that Amendment, and are still under NRC review. This letter provides additional information and revised Technical Specifications pages to support completion of that review. 1. Proposed Technical Specifications Pages, 0 1 , Three attachments are provided with this letter: 2. Existing Technical Specifications Pages Marked to Show Proposed Changes, 3. Table of CPC-2A Locations for Relocated Material.

9704070091 970328 PDR ADOCK 05000255 P PDR A OHS ENERGY COMPANY ------, 1111111111111111111111111111111111111111111111111111111

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,. Section 3.5 of the Safety Evaluation for Amendment 17 4 discusses those changes requested in our December 11, 1995 letter which are still under NRC review. Each of these changes is discussed below: 1. Changes 21 and 24 of our December 11, 1996, letter: Amendment 17 4 SE Discussion:

2 The licensee proposed to relocate the requirements of TS 6. 5 related to review and audit functions, TS 6. 8. 2 related to procedure review and approval, and TS 6.8.3 related to temporary procedure changes, to the Quality Program Description, CPC-2A. The licensee submitted a revision to CPC-2A on May 31, 1996, which was intended to incorporate the existing TS requirements.

The staff identified several discrepancies between the existing TS requirements and the relocated requirements contained in the May 31, 1996, CPC-2A revision.

The licensee will need to revise CPC-2A to correctly incorporate the TS requirements and submit the changes to the NRG for review prior to staff approval to delete these requirements from the TS. Consumers' response:

Change 21 proposed relocation of Administrative Controls Section 6.5 (renumbered to section 6.8 by Amendment 174) to the Quality Program Description, CPC-2A. Change 24 proposed relocation of Administrative Controls paragraphs 6.8.2 and 6.8.3 (renumbered to 6.4.2 and 6.4.3 by Amendment 17 4), to the Quality Program Description, CPC-2A. The Quality Program Description, CPC-2A, has been revised to incorporate the subject Technical Specifications requirements.

A copy of CPC-2A, Revision 17, was submitted to the NRC on March 7, 1997 to assist in their review of the Technical Specifications change request. The text in CPC-2A includes some administrative changes which reflect changes in titles and organization:

a) The department that performs 50.59 and other safety related reviews is now "Safety/Design Review"; b) The former "Director-NPAD" is now the "Manager -NPAD"; and

" c) The group within the NPAD organization which performs the reviews required by CPC-2A, Appendix C, is called the "Independent Safety Review Group" (ISRG). 3 The requirements of Technical Specification 6.4.2 are addressed in CPC-2A Policy Statement 6.1 on page 24. The requirements of Technical Specification 6.4.3 are addressed in CPC-2A Appendix A, item 2h. Appendix A states: "The Consumers Power Company Quality Program complies with the regulatory position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated in Part 2." Regulatory Guide 1.33, which endorses ANSI N18. 7, is referenced as item 7 in Part 1 of Appendix A Item 2h of Appendix A, Part 2, contains the requirements of existing Technical Specification 6.4.3 as an interpretation of ANSI 18.7, Section 5.2.2. The requirements of Technical Specification 6.8 were relocated to CPC-2A Appendices B, C, and D. Attachment 3 contains a listing which provides the location in CPC-2A of each requirement in current Technical Specifications 6.4.2, 6.4.3, and 6.8. 2. Change 7 of our December 11, 1996, letter: Amendment 17 4 SE Discussion:

In addition to the proposed relocation of the TS 4.3f primary coolant pump flywheel inspection requirement to the Administrative Controls section as discussed in Section 3. 4 of this SE, the licensee proposed to delete the TS 4.3f requirement to inspect the regenerative heat exchanger.

This change, in concert with the relocation of the flywheel requirements, would permit the deletion of TS Table 4.3.2, which is referenced by TS 4.3f and which contains the details of the inspections required by TS 4.3f. The licensee stated that this requirement is redundant to the ASME Boiler and Pressure Vessel Code, which requires the inspection to be performed once every 1 O years. The existing requirement mandates that the inspection be performed at a maximum 5-year frequency.

The staff requires additional information regarding the design codes and inspection results for the heat exchanger to complete review of this proposed change.

Consumers' response:

Change 7 proposed deletion of Surveillance 4.3f, a five year inspection of the Regenerative Heat Exchanger, with reliance placed on the ASME Code Section XI requirement to perform such an inspection every ten years. Discussions with the NRC, subsequent to the issuance of Amendment 17 4, indicate that no additional information is necessary to support the review of this proposed change. 3. Change 9 of our December 11, 1996, letter: Amendment 17 4 SE Discussion:

4 The licensee proposed to delete the requirements of TS 4.5.4, "Surveillance for Prestressing System," 4. 5. 5, "End Anchorage Concrete Surveillance," and 4. 5. 8, "Dome Delamination Surveillance," and replace the requirements with proposed TS 4. 5. 4, which would require verification of containment structural integrity in accordance with proposed TS 6. 5. 5, "Containment Structural Integrity Surveillance Program," which would require containment tendons to be inspected in accordance with Regulatory Guide (RG) 1.35, Rev 3, July 1990. During review of the proposed change the staff identified that the RG does not address the dome delamination surveillances currently required by TS 4.5.8. Additional information will be necessary for the staff to complete its review of this proposed change. Consumers' response:

Change 9 proposed replacement of Containment Surveillance Requirements 4.5.4, 4.5.5, and 4.5.8 (renumbered to 4.5.4, 4.5.5, and 4.5.6 by Amendment 17 4) with a proposed Containment Structural Integrity Surveillance Program, Section 6.5.5. This proposed change is no longer appropriate, and is hereby withdrawn.

Since the time of our initial submittal on this subject, the NRC has amended 10 CFR 50 to include the methods of containment testing presented in Section XI of the ASME Boiler and Pressure Vessel Code, subsections IWE and IWL. Since this newer methodology must be adopted on or before September 9, 2001, it is not desired to first change the current program to reflect the requirements of Regulatory Guide 1.35, and then, soon thereafter, change it again to reflect the requirements of the subject code sections.

5 4. Change 25 of our December 11, 1996, 1.etter: Amendment 17 4 SE Discussion:

The licensee proposed to revise limits on liquid and gaseous effluent release concentrations of proposed TS 6. 5. 4b and e, respectively, to adopt the requirements of 10 CFR Part 20, Appendix B, Table 2, in place of the former Appendix B, Table II limits. The licensee also proposed to revise related references to 10 CFR 20.106 contained in proposed TS 6.5.1c and 6.5.4c to refer to the revised requirement, 10 CFR 20.1301 [Sic]. During review, the staff identified that licensees proposing this revision typically adopt a requirement to require effluent concentrations to be maintained below 1 O times the 10 CFR Part 20, Appendix B, Table 2, limits, which is equivalent to the existing requirements.

The licensee stated that this was its intent and it will submit a supplement to revise this request. The existing references to 10 CFR Part 20, Appendix B, Table II, and related references to 10 CFR 20. 106, will be retained pending completion of staff review. Consumers' response:

Change 25 pmposed revision of Technical Specifications 6.5.1 c, Changes to ODCM, and 6.5.4, Radioactive Effluent Control Program to reflect the revision of 1 O CFR Part 20. Paragraphs 6.5.4b and 6.5.4e have been revised to limit the concentrations of radioactive material released in liquid effluents to unrestricted areas to "1 O times the value in 10 CFR 20, Appendix 8, Table 2, Column 2", rather than to "the value in 10 CFR 20, Appendix 8, Table II, Column 2" currently required.

The former Table II was based on a 500 mrem per year value , and Table 2 is based on a 50 mrem per year value. Therefore the proposed limitation is effeGtively equivalent to the existing limitation.

This limitation is the basis for effluent monitor alarm set points and monitor sensitivities do not support a lower value. Paragraphs 6.5.1 c.1.b and 6.5.4c have been revised to reference "10 CFR 20.1302", rather than "10 CFR 20.106". 10 CFR 20.1302 is equivalent to the former 10 CFR 20.106 except that 20.1302 lowers the effluent release annual dose value to 50 mrem per year. The former 20.106 reference was based on 500 mrem per year. These changes implement one of the new Part 20 objectives to lower effluents to unrestricted areas.

6 The changes included in the attached pages are clarifications and editorial revisions of those changes proposed in our December 11, 1995, and September 3, 1996 letters on this subject. They do not alter the No Significant Hazards Analyses provided in those letters.

SUMMARY

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

Thomas C. Berdine Manager, Licensing CC Administrator, Reg.ion Ill, USNRC Project Manager, NRR, USNRC NRC Resident Inspector

-Palisades Attachments