Text

License Amendment Request - Additional Information
	ML033380975
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/01/2003
From:	Haas K; Consumers Energy
To:	; Document Control Desk, NRC/FSME
References
	+kBR1SISP20060420, -RFPFR
	Download: ML033380975 (108)
	v • d • e

consumers A CMS Energy Company Big Rock Point Restoration Project Kurt M. Haas 10269 US-31 North General Manager Charlevoix, Ml 49720 December 1, 2003 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 DOCKETS 50-155 AND 72-043 - LICENSE DPR BIG ROCK POINT PLANT -

LICENSE AMENDMENT REQUEST - ADDITIONAL INFORMATION On August 6, 2003, Big Rock Point submitted a request to amend the Facility Operating License and Appendix A to the Operating License, Big Rock Point Defueled Technical Specifications pursuant to 10 CFR 50.90. As a result of Nuclear Regulatory Commission review, telephone conversations were held on November 10, November 13, and November 21, 2003 to resolve questions. Attachment 1 documents the questions discussed and Big Rock Point responses.

Attachments 2 through 5 are re-submittals of Attachments 3 through 6 originally submitted on August 6, 2003. This re-submittal corrects the original attachments, by incorporating comments from the questions, above. Corrections are marked with a double line in the right margin.

The revisions resulting from these discussions did not require safety reviews as they only correct typographical errors and re-insert previously removed programmatic descriptions in the Technical Specifications Administrative Section.

Prompt Nuclear Regulatory Commission review in this matter is appreciated. Once approved, the License and Defueled Technical Specification amendments will be implemented immediately. Should you have any questions concerning this letter, please c ntact Mr. Gregory C. Withrow at (231) 547-8176.

Kurt M. Haas Site General Manager cc: Administrator, Region Ill, USNRC NRC Decommissioning Inspector- Big Rock Point NRC NMSS Project Manager - James C. Shepherd NRC NMSS Reviewer - Bill Huffman Attachments

STATEMENT OF SIGNATURE UNDER OATH OR AFFIRMATION Consumers Energv Big Rock Point Plant LICENSE AMENDMENT REQUEST - ADDITIONAL INFORMATION Docket Numbers 50-155 and 72-043 License No DPR-6 At the request of the Commission and pursuant to the Atomic Energy Act of 1954, and the Energy Reorganization Act of 1974, as amended and the Commission's Rules and Regulations thereunder, Consumers Energy submits corrections to the request for revision of Defueled Technical Specification supplementing our August 6, 2003 License amendment request. The additional information corrects a typographical error and re-inserts Defueled Technical Specification Administrative requirements for Big Rock Point Programs.

Consumers Energy Company To the best of my knowledge, information, and belief, the contents of this submittal are truthful and complete.

By:

Kurt M. Haas Site General Manager Sworn and subscribed before me this 1 st day of December, 2003.

Do . Field, N y ubli (SEAL)

Emmet County, Michigan My Commission expires July 18, 2006. -7,

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Attachment 1 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Questions Related to Big Rock Point August 6, 2003 Defueled Technical Specification Amendment Request December 1, 2003 2 Pages

Questions Related to Big Rock Point Defueled Technical Specification Amendment Request of August 6, 2003 The following items were discussed in telephone conversations held on November 10 and 13, 2003 between the NRC, NMSS reviewer (Bill Huffman) and Big Rock Point (Greg Withrow and Linda Castiglione):

1) Need to discuss the process used to arrive at the currently proposed license modification for Physical Protection. (In addition, what is the applicable NRC security order in effect at your site)

Applicable NRC Security Order in affect at Big Rock Point, with all spent nuclear fuel and special nuclear material located in the ISFSI facility, is dated October 16, 2002. BRP responded to the Order on November 4, 2002. However, the applicability of only the ISFSI Security Plan is documented in an NRC letter to BRP dated July 18, 2002. The July 18, 2002 letter approved revisions incorporating the Independent Spent Fuel Storage Installation (ISFSI) Security Plan. This approval recognized the applicability of the existing security plans (for spent fuel stored in wet storage in the Spent Fuel Pool. Consumers Energy letter dated March 27, 2003, provided revision to the Defueled Security Plan. The revision included an applicability statement for the Plan, which, in effect, stated that the Plan was no longer applicable with all spent fuel stored at the ISFSI.

2) Does the commitment to move the Plutonium - Beryllium neutron source to the ISFSI protected area need to be captured in the license or technical specifications?

The location of the Plutonium-Beryllium source is specified in Chapter 12 of our Updated Final Hazards Summary Report. This location was revised when the source was moved from its former location, inside the former plant industrial area, to the ISFSI facility.

3) Explain further how the requirements for the Offsite Dose Calculation Manual (ODCM)

[and the Process Control Program (PCP)] can be removed from technical specifications.

The standards for Operating Plant Technical Specifications have not relocated these requirements. It is unclear how 10 CFR 50.59 could be applied to the ODCM as a change control program.

We agree that the requirements for the ODCM and the PCP should NOT be eliminated from the Technical Specifications. These programs will be incorporated as License Conditions.

4) Please further explain what is replacing the existing monitoring station at Big Rock Point.

(ISFSI Central Alarm Station?) Where will radiation alarms be monitored (for effluent releases from the decommissioning industrial site for instance)? Where will fire emergencies, medical emergencies, and Emergency Plan be coordinated?

The monitoring of licensed material is from the ISFSI Central Alarm Station.

Radiation alarms are monitored locally for effluent releases. No releases are performed when the Operations monitoring is not available. Fire, medical, and Emergencies continue to be coordinated from the Emergency Support Center (ESC), which is located in the lower level of the ISFSI Administrative Building and includes the Central Alarm Station. Communications between Operations personnel is outlined in the Site Emergency Plan (phone/radios).

I of 2

Questions Related to Big Rock Point Defueled Technical Specification Amendment Request of August 6, 2003

5) What will be the shift staffing for the ISFSI? Is this defined in any licensing basis document?

Shift staffing is defined by Emergency Plan and Security Plan requirements.

Per telephone conversation on November 21, 2003, the Big Rock Point Updated Final Hazards Summary Report will be updated (Chapter 13, Section 13.1.1, MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION). The second paragraph of this section currently reads:

"The Big Rock Point Site organization is shown on Figure 13.1. The Big Rock Point Site General Manager is responsible to the SNO for operation, maintenance, and decommissioning of the nuclear plant in such a manner as to achieve compliance with plant licenses and applicable regulations. These responsibilities and the associated authority are delegated in writing during the absence of the Site General Manager. The Site General Manager administers the Quality Program for the plant."

It will be revised to:

"The Big Rock Point Site organization is shown on Figure 13.1. The Big Rock Point Site General Manager is responsible to the SNO for operation, maintenance, and decommissioning of the nuclear plant in such a manner as to achieve compliance with plant licenses and applicable regulations. The Site General Manager verifies that Dry Fuel Storage Technical Specification surveillance(s) have been met. These responsibilities and the associated authority are delegated in writing. The Site General Manager administers the Quality Program for the plant. The Site General Manager, or his designate, shall verify that required security and emergency plan staffing has been met."

6) Please explain the struck-out words in the Fuel Storage Section of your Proposed change justification table in Attachment 3? The struck-out words under the Limiting Conditions for Operation are not in the current technical specification so why do you show them at all?

The struck-out words in question are a typographical error, and should not have been in the table (Attachment 3, Page 14.)

7) By removal of the shift supervisor position, who has the command and control function onsite at any given time? What licensing based document discusses this?

As defined by the Quality Program Description for Nuclear Power Plants Part 1 Big Rock Point Nuclear Plant, the Site General Manager, or his designate performs the normal command and control function. Delegation of the command and control function is defined in the Emergency and Security Plans. Currently, the Emergency Plan requires a Site Emergency Director (SED) on-Shift plus staffing required by the Security Plan. In the future (Emergency Plan Exemption submitted October 31, 2003), security will provide around-the-clock staffing with an on-call Emergency Manager.

2of2

Attachment 2 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Discussion of Proposed FACILITY OPERATING LICENSE AND DEFUELED TECHNICAL SPECIFICATIONS (Originally submitted as Attachment 3 to August 6, 2003 Correspondence)

Revisions are Marked by a Double Line in the Right Margin December 1, 2003 36 Pages

J1 ATTAeiaMENT 3 PROPOSED CHANGES - FACILITY OPERATING LICENSE I.A Deleted space after "licensee"' dtra C.(2) Technical Specifications When approved, the NRC will issue the next The Technical Specifications contained in Appendix A, as revised through consecutive number.

Amendment No.4-24, xxx are hereby incorporated in the license. The licensee I shall maintain the facility in accordance with the Technical Specifications.

C.(3) Physical Protection The required physical protection requirements The licensee shall fully implement and maintain in effect all provision of the (now that all spent fuel is physical security, guard training and qualification, and safeguards contingency in the ISFSI) for the plans approved by the Commission and all amendments and revisions to such facility are all addressed by plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), as modified by NRC-approved exemptions. The plans, which contains Safeguards the Big Rock Point ISFSI information protected under 10 CFR 73.21, ofe- is entitled: aBigtReel. eiMt-Plant Security Plan that was 2nfilxllo DI---

Dl, -41 Area .. ngtn *:A- Is~ds r submitted to the Pla I .1 . -,tit-revisieffs - I I-- Commission by letter dated 12, 2002; "Big Reek Pe nt-Wmt Defueled-We-twi,45 0 January 27, 2003. The 4=MY1TTM r_1UT?

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- v - , - .t t1 L Dlr dates are removed so that Rock Point ISFSI Security Plan". as s*bmitteden Jutly 31, 2001 and ameoited-by future submissions will not letter-dated-Marel 6,-202-Changes made in accordance with 10 CFR 73.55 require an administrative shall be implemented in accordance with the schedule set forth therein. license amendment.

Deleted expiration date -

D. Revise from: "This amended license becomes effective as of the date of its issuance certification of cessation of and shall expire at midnight, May 31, 2000." operation and permanent To: "The license amendment is effective as of the date of its issuance and shall be implemented removal of spent fuel was within 45 days of its issuance." mad pursuant to 10 CFR I

-. I ATTA'lilMENT 3 PROPOSED CHANGES - FACILITY OPERATING LICENSE I S S OS _ IIR 50.82 on September 23, 1997.

In accordance with 10 CFR 50.5 1(b), for license facilities that have permanently ceased operation (continuation of license) continues in effect beyond the expiration date

... until the Commission notifies the licensee in writing that the license is termninated.

2

ATT)iIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS 1W9 N I Si[$Hl OS .Re I El S

These deletions are TABLE OF CONTENTS administrative in nature and are a direct result from the DEFUELED TECHNICAL SPECIFICATIONS changes made throughout the FOR following pages of the BIG ROCK POINT PLANT technical specifications. See the reasons listed below for each of the proposed changes.

SECTION 1.0 DEFINITIONS ........... 1-l 1.1 Action .................... 1-1 I -% r, - _.: 5If i .1 .-1 . _I I I I I -- I

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Is@4 1.:l2 Channel Calibration ............... 1-l 1.43 Channel Check ............... 1-1 1.54 Channel Functional Test ............... 1-1 1.6 ConUmenment-Gfirc. I.l 1.7 Direet-Pain th.2 ............... 1 1.8 FDiet-HandliPa .................... 2 1.95 Immediately .............. 1-2 1.1-0---ls--r---MenifoFinStfltio fl...1................ 2

-1. 1 0f fsit e-PD o -le ua tio n Mn nu i-( D G )- - -- -- - -- -- -l - 2 1.12 Operflbde-Opernbihitey ..................... l3 1.13 Proeesz Centrol-P-regra m (P.CP). .................... 13 1.446 Reportable Event .................... 1-3 1.5 ShISt.................... 1-3 3

.. i ATTA-iIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I 6O SO 1WU M11MO IThese deletions areM ---

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3/4.0 AM GA-MBITY ................. 3/1 1 administrative in nature and

/4.1 lrUE-gSU}TO1RAGE ................ 3/1 2 are a direct result from the Spent-Fue1ooi-armeters 31 ! 4 321.1 changes made throughout the 3/Y. 1.2 -Spent-el Pool St pport-Systenimequirements 3/4 5 & 6 following pages of the 3/1.1.3 Fuel-Sterage-General R quieients .. ------...3/4 7 technical specifications. See 314.2 FUE-L-HANDLMNG ....... 3,14 R the reasons listed below for 3Ft~~~~~~~llsW14ANOI ING.................................................3/1 8~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~.......................

3/14.2.1 Fue-Hanndling.tippe Systen-Requiferents ...........3/1 each of the proposed changes.

3/14.2.- iteeln ladlhng-generil-Requirements............ 3/14 9 & 10 These deletions arc 5-:2 SO r681113-S14-TFUEL .............. 5 1 administrative in nature and 5.2.1 Critieafit3 ....................................... 51 are a direct result from the 5.2.2 Wnter-Level ....................................... 5l changes made throughout the 5.2.3 Cooling .............. ............. 5 1 following pages of the 5.2.4 -Capaeit3 ....................................... 53 technical specifications. See

.3 R A OI. ............................................ 53 S the reasons listed below for Status .53.1 .......

54 each of the proposed changes.

These deletions arc 6.1.3 Shift-Super-visor ..... .................................. 6 1 administrative in nature and are a direct result from the

ABL--&624-MinimumwSlhift-Grew-onopositin ......-6 3 changes made throughout the following pages of the 64-.1 AIWNING technical specifications. See 6.6.2.7 Fire l'teetion Program ...................................... 6 10 the reasons listed below for 6.6.2.8 Cold-W4ather-lketeetie ogram...........................6 l each of the proposed changes.

6.6.2.9 Spen 1-12elP P-Wateref. Ch ist Pro m ................ . .. 6 11.

6.6-2.10 insier-viee-soeenie-and Testing-Progra...6 II 4

- B ATIATVIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_ X I I am S I Based on the permanent 4.12-GE411 3F119E-FUHANDLER removal of the spent fuel from the spent fuel pool and GER4::l E ED-rUEL4:DL-E-R-is-nanindividunat-whoios-quaified-ienaeeordanee w iftM placement into dry storage, Ilr*4ranm-WD4. -ertiified-Ftuei4-Wnd~er4nitial-Certiieation- Pregramru 2 maintaining individuals qualified as CERTIFIED FUEL HANDLERS is no longer required.

Correct typo (encompasses) 1.9a2 CHANNEL CALIBRATION and renumber. No other change proposed at this time.

A CHANNEL CALIBRATION is the adjustment as necessary, of the channel output such that the channel responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompasses the entire channel including the sensor and alarm and/or trip functions, and I includes the CHANNEL FUNCTIONAL TEST. The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

Former section 1.4, (CHANNEL CHECK), renumber to 1.3 I Editorial 5

i ATTkCHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I.54 CHANNEL FUNCTIONAL TEST 6 6 6 6Dlfl 7 9 RU I 01S This definition of J,~

OPERABILITY is based on A CHANNEL FUNCTIONAL TEST is the injection of a simulated signal into the channel the regulatory definition of as close to the sensor as practicable to verify OPERABILITY performance, including alarm Safety-related structures, and trip functions.. systems and components that are relied upon to remain functional during and following design basis events to assure: (I) The integrity of the reactor coolant pressure boundary (2) The capability to shutdown the reactor and maintain it in a safe shutdown condition; or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential.offsite exposure comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 10

.CFR 100.1 1 or this chapter, as applicable.

Based on the permanent removal of the-spent fuel from ihe spent fuel pool and placement into dry storage, there are no design basis events as evaluated in the UFHSR and the BFS SFSS SARS that require remaining systems, structures, or components to provide the assurances 6

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ATTAAI1MENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS SO11Sk-71 OSW 171I R WI [$)T[$ SR1._

defined above. This defined term will be deleted from the technical specifications.

For decommissioning the site boundary doses calculated for GONdNMNm T 4_{- f-URslhat-endition-ofcontainmentin-whieh hefeare-ne-direet the postulated fuel handling paths-foi-eenltiment-atiiesphere-o-ite-eutsidentnesphere, eceept-ferhe eentinment accidents described in venriatjiaon-inletfln4~-ha, st-lvestwhiehn-ay-beopen4falenst-ene-e ehausthna-i-n Chapter 15 of the UFHSR do

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CQEn-- J Tlf-- it not credit the containment vessel for mitigative purposes. However, the concept of CONTAINMENT CLOSURE and no DIRECT PATH were conservative and existed to mitigate the consequences of potential fuel handling accidents.

Based on the permanent removal of the spent fuel from the spent fuel pool and placement into dry storage, the need and/or desire for CONTAINMENT CLOSURE is no longer applicable. This defined term will be deleted from the technical specifications.

7

ATTACHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I ;.7 Mt IW a CI I DIRE-C-T-1AT Based on the permanent 11 removal of the spent fuel A-DIRE-A:4A 4i v isua4observa e-nening-i4t- e-leeccxhnge-aif from the spent fuel pool and between--ontainnment-nind-the-eiwifens-.- uipment-cnuratiens eIan-engineered feature placement into dry storage, such as a elosed-vsveeheevilve,-atier-sealloseddef-membrane4yeir-or-,eetrely the concept of DIRECT Fastened-plate-may-be-uised-to-preelude difeetpatl-s-.--Redunfdaney of-engineefed--eatures-te PATH and the relationship to eiimiinatedi-eet-pnths-iiset-reqtired- CONTAINMENT CLOSURE to mitigate potential fuel handling accidents is no longer applicable. This defined term will be deleted from the technical specifications Based on the permanent 4-.8 FU-1--L-HANDIAN- removal of the spent fuel from the spent fuel pool and 144L4lAr;DANGmeains-he-aetivitie-sseei-ated witwningspent-nu4ear-ftiel. When placement into dry storage, spent-nuelear-fuelis eontnined in aelsedd-sealed eanistete-avities assoeeiated-with handling individual spent fuel mevin&4he enisteirenot-to-beeensidered- F4UEL HANDILIG. assemblies *inthe spent fuel pool has ended. This defined term is no longer applicable and will be deleted from the technical specifications..

Formner section 1.9 (IMMEDIATELY) renumber to 1.5 Editorial.

8

ATTAVHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

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Based on the permanent 0-4G- NjT-ORI4NG-&WFO-lN removal of the spent fuel from the spent fuel pool and

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placement into dry storage, aIlrei iing-find-iimite-eonifolkeapfsabiites4-seleeed systew-paranieters-duingtelie monitoring, alarming, data archiving and limited P1. 1- . I n o - I II LIstoUica III I 1un1til-.11 Ufit I I IfX-nr@n1' PC

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A,I I capabilities for selected system parameters are no longer applicable. In a permanently shutdown condition with all fuel stored at the ISFSI, Big Rock Point presents a significantly reduced risk to public health and safety. Big Rock Point SSCs that were required for spent fuel storage are not required and no longer require monitoring. There are no remote actions or indications other than security. This defined term will be deleted from the DTS. -

9

ATTAtHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS ml] OUR a Ita I 1 as 0 Thcsc technical specification I II nrrQFC 1T'r1 Mn' fr A T'1 TT A 'TlnX1 W AATT I A T InrCTI(' AN

i. I - -L..\L U J iE-i fio t'l J\ requirements currently exist in a manual (Volume 25-4p: h I~ufr4 5 ~sr~-Z k W -T I O A.. N- A. O ~--.... _ Big Rock Point Radiological matstanlassn........r I I I~tTIt 'tt~t7Jt7l7t1Tlt 1t1 till 1t~ ~ttt~t~tU9UI

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.,i Iiu WXVV-t Calculations and B. Process Control Program), and are R;eaetsivcefnuMtent-Centrolst n4vnfitielegicaI En irenent-a oiterin referenced by the Updated pregamnis-required-by-Seeion -. 6-.2.-5-ion-66S -and-{2)-eseriptiens-Ofthe .Final Hazards Summary infornmatieintlat-ahoild-be inehided-inth e-Annual4aioelgieaI-Eai nimeent Report. Pursuant to NRC Qp~er-alingand-Annual-Ral;oaeffvaetiEf~ent-Release Reperts-requifed-by Administrative Letter 96-

&peeifieeens-6nnd 6.7.3 04: Efficient Adoption of Improved Standard Technical Specification, relocating the details of technical specification requirements in this manner is an acceptable approach because there is an applicable regulatory process for future changes, namely 10 CFR 50.59. Therefore this section will be deleted from the technical specifications. I This definition is based on the

1.412n O ABLhPE-O RABILITY regulatory definition of Safety-related structures, A yste. sbysten tresl be OPERABLE or have systems and components that

-PP-ERABHA wlen-4t-teipabhWfperfing-ingspeeifeifiedfutnetieon(s).

-- a-ndwhen are relied upon to remain al-l- leeessar-D~ttentia1?hfllstiunlelttrols,-elee-e-powespr-eeogr-seal functional during and water-Hbriefio-or--othera-t;liaF-equiipmnent4hna r-eqtired-hee-systein? following design basis events subsystem~rnain-e1pon~eneviee4o-pe~orm-rits-* safefimetion*s)-nr-e nalso to assurc: (1) The integrity of eapjlhle<o1-pe~lbrin~iiig-I ei r-relfatedsupperl---funetion7e -) the reactor coolant pressure 10

ATTAX&HMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS boundary (2) The capability II to shutdown the reactor and maintain it in a safe shutdown condition; or (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposure comparable to the applicable guideline exposures set forth in 10 CFR 50.34(a)(1) or 10 CFR 100.1 1 of this chapter, as applicable. Administrative procedures are in place to ensure compliance with 10 CFR Part 21.

Based on the permanent removal of the spent fuel from the spent fuel pool and placement into dry storage, there are no design basis events as evaluated in the UFHSR and the BFS SFSS SARS that require remaining systems, structures, or components to provide the assurances defined above.

This defined term will be deleted from the technical specifications.

11

ATTA;HMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

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+4- GE L-PROGRAMPP P4 These technical specification requirements currently exist in a manual (Volume 25 -

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W m Big Rock Point Radiological be-ncomplislie-siuetelhay-as-to rmassur hee 10ClfRParts - Effluent T/S Required and 7S-lte--egulfations;-btrialgreun*-r-equiementsrad-ethief-requifeniefts Documents: A. Offsitc Dose governing-tlhe-ispe-of-selid-iofletive waster Calculations and B. Process Control Program), and arc referenced by the Updated Final Hazards Summary Report. Pursuant to NRC Administrative Letter 96-04: Efficient Adoption of Improved Standard Technical Specification, relocating the details of technical specification requirements in this manner is an acceptable approach because there is an applicable regulatory process for future changes, namely 10 CFR 50.59. Therefore this section will be deleted from the technical specifications. .1 Former section 1.14 (REPORTABLE EVENT) renumber to section 1.6. Editorial.

Also revised referenced section I from 6.9 to 6.8 to reflect section 6 re-numbering.

12

ATTkCHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS 41 MIN 0 I WI IME93 a UU13 M13:4 MI 11 F.-IMN n 791 Me0 Based on the permanent 4 __5 8S IW-T removal of the spent fuel from the spent fuel pool and placement into dry storage, as-determifine4P-bl-le-Si te-General-Mfvimaer-.F r-ptfrpeses-ef-determaiing-4he SHIFT as defined has no merit. Pursuant to 10 CFR

.In -itl sll~flllw~tabge-i67e-betweenT-suar~edhmeesleeviee-speeiffed-u yeifanee-tmteFvid9s 50.54, SHIFT is directly

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.- eeFeaWVgeIf*H1tge" bat-fmne: applicable to the permanently defueled and decommissioning reactor facility. The only remaining surveillance is related to Sealed Sources, and the associated surveillance period is defined as every six months. This defined term will be deleted from the technical specifications.

13

I b~~~I j ATTA 14MENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I 111 l 66 6@ I The definition of 1

3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE OPERABILITY has been REQUIREMENTS removed from the technical specifications. See previous 3/4.0 APPLICABILITY and following discussions. to the permanently defueled and SURVEILLANCE REQUIREMENTS decommissioning reactor facility.

4.0.3 Unless specified otherwise, performance of a Surveillance Requirement within the specified time interval including the maximum allowable' extension shall constitute compliance with OP-'13RA tli-requifements-fee-abmiting-Cenditien-fbr Opemalenind-associated ACTION statements.

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Based on the permanent 3i44-V44-S- RA 6 E removal of the spent fuel from the spent fuel pool and I4".i. I SPN~Z4bPG~AvETERS placement into dry storage, related Limiting Conditions h4IM PING-GONDT4ONS-rOR-OPl-ERAT-IPN for Operation and Surveillance Requirements Ba en~h erm-r nniren l-o en oi i -f are no longer applicable and

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~~ie~spN~eentrolle y-a-d ~~ere . t-Al 4 technical specifications. The spent fuel is now managed by a different set of approved V.Iwttt-jU-ttttt 1..ivt E?1rtImT

-,tntvtitttrut:I-t-I--rt It ITT TV I technical specifications issued and approved pursuant I _.

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ATTAbilMENT 3 .

PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

- 00 IIMt e:. -- wter-elem-ostr-y-li~ne-6pen~t-ueI~sSt~tl

-Nwthintelollleowinfg pH-1-,4Oto-9:O0 Condt!7 ' iFtessthan-o r-equaJt-rierornos-eie afl77°F I

,t I-I I

I _

I

_I _

. .I

.I _

,`.. A ___ _._ I _ I _sI t L_

4 al.s_ _

SII 1

mrw~L_

. . _ _ _.1 I I t

ltx~ II -I. I I I I-It 1 -rrv . .... w-.,I . . v- -.- ". Irur ...

-v--nlv twogan -rwidatiet-* iiofir-s, o e eieea a loeafny-Fefn*r1ely-audiblefarrset-at not-Iess-thwan--&i Hirems peI-eur-andotn~eethaI2-ni~iferns-pef-heurewr xeecf during4he-neveientofspent-l-oraioaetveopnoenents in or adja-enit4he Spent-r-uel-P-eel.-vzertoalarn settingiwma4-e-r- ised--a IFnrvidedhle everal~~eteetieCR crt7in 0 X2WQIiz ziqfied. At le R required4e-E-OP-E-RABE.The-enitorssha-hlfiwe-rmete-indieatien-mile eApablia;tye4-reeorsng-iataeS A1 2 PAR}I-4A:Y'-WienspenI-fuel Bs-inethle-;,ent-V~eI-eeb TAW .. ....

i l44e-rewn~renent' rn, n ot I. I. I . not M;

... . - . A. .,1 - .-

. .. . . t.- .-

A - . -- - A l\IA%Ar'-l AT~ V-lX dfRmin-4e-&pent-riieWnotPee-fue1lassemblies-an4- te-rne leadin--sfe 1/4.1.Jl Sldfl151155, szcI.y1/4. 511 551) S nfal t.w1/4amhAr1nd ar.nnp-an =..

wulv lr nuprqhen stlIPnnl. nfiate nct on to reiere Xnpn4el-PoI AW umlp"Awal.

o , f X A e s X st Wir-.s

q I

j I iif t s-IQ I 9 A\t (j

A T\st Pi;IAl rA

£v\z ii* WitInherequirenients of 34b notet-e

-IMMISDhTEL-Y-plaee-fuelassembfles-and4e-ernne- lfad-n-a-s;nfe 15

ATTA 1iMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS M tE II[)T$ S14 o 0071 i a.1 Ia 6 ii I

eenditi -suspn-ther-vement of fuel ssembeandemne-epmtions_

witlh4eadsin-erover-4rie-Spenfit-el4e2eeand-ini~eACTIsI o-torestore aeeeptable-empernturtu-W in 24 heurs establWi-CONTAWIMENT hiii 1-Pe-waterfflualit".peecivficatisf 3. 1.1ke areeNeeeded-,nitiateorree~v meastires4eneef-ehemstfy-requirements within2-l-hrsiand-sample pool water-otIeast-enee-a-day--uitiI-readinigsr-meethe-requirements-oF3.4..e. if water-qualityeannotberee-eredber one eeek-reprprfaeeeiailreport thatdtlenti-fies4he eat sesnid-preposedoerreetive aetien(Ao-ensute-futre water-qiality-iin eop1ianee-and-ubm4is e-NR by 3Idays"fowin-g entiy-intot~e-tG em -Wditlihe-requirefnents-ef3.14-..d--net-mel, IMMEDIATELY preside-s allernate-dnetiod--monitering-Spet-Feel-Pool-ratdiien4evels.-If-Whe alterate-ilistmnenmol-deestio-lhave-anaudible-alafmh-4eefal~y-fd-iflhe MONITOWRNG J4- d,ra intion- evels-halbe-continuously mnonitoered-hy-pefsenner-n-enu-niettionewi-t-whe-MONTORNIl-G ST-MAI0N-ewhenperonne-are bheieinity-4"ce-Spent-ueWl-Poeo 4:l e-provisians-efeeifieationG 3.. not-Epliefe Eare

.sIJrMEr IkAG1rEQ 141 RM1BN

4. 1.1 a -Twiee-petr%-&1F ie-waterevel ie-penlpent-RPe1e-sal- -deternined-o-be-atxoi above~ie-elevatie"P630 444.b Tkiee-per-F4IWTSp-1uenI-Peal-Pow tertemperattresha-lbe-determined-fo-meeete requirementsofSpeci fieation-3.1.1 b.

16

ATTA\&AMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS 9,

I

4. 1.1.c he nee-peF31-dayrSpent-PelPe -watef-ehemistr-y-shemI-e-eter-ined4e-meetle reqwiremeiits-of-Speeifi-ation 3.1.1 ce 4.11..( l le-&pent-leriel radiation-nenit-r eqpiifed-bythis speeifie tie-shal-be-derenstated operable-

-. Daily-by-per-erming-n C-ANN-Eb-HEK ii Oneee-pef41-days-by-eff 4rfin gHANNEL GALIBRATBON-Based on the permanent I-I.l I

. I IT1II I v CV1 l . l-Tfl A f-11 J removal of the spent fuel from the spent fuel pool and 3//1.1.2 SPE1NT ;UEI1 P(O 1JPO SYSTEM REQUIREMENTS placement into dry storage, related Limiting Conditions MlT1NG G N:l-GN8-FGR-4QPE-RA-T4N for Operation and Surveillance Requirements arc no longer applicable and will be deleted from the technical specifications. The nXTsefJ-%TnXpermIflflernfemovfiet-i Aspeflln 1 r__- . r.

- LI r___- .t eImutesTeni-ule-peeTT r..A ___l-eeTssatea

.__ A r TT ATITk It Ll-'111 11'-I--I- spent fuel is now managed by

-= a different set of approved

- I_- . -r - - _. tr 1 .- I -

,L, .T F+

-. _A.

- - ~- nArA_ . - --- ,; n I, - X _1 11.--'t'9"'-

AItIC technical specifications

_LI2a_r MUIA.$la " A11cl4 ...... rI IWI t~ rtzt -Utt-tef~~~t-Ht-tiet-.--U"l'1VVC -t-l_~

urI" "IN. -,-IIW r t t,_ w t l ut~~fet~ttypt rrm-"t

,I - - -# #_ IO RmttU nLrD 1r- I ~ *lI..

D).# 7Y)

It t_

issued and approved pursuant to 10 CFR Part 72.

I Al--------

.-1-1-1t _-_h Ig.u tl.

_nn .__t..

-I

~x_m_n_t. ni Ih 4L_. ~ .w4,;.__

s I A t-Ws nUR X vvs

-II-Iu I dz;-s- vs

~

L I_ _ v li

--Wllls\W45 fd J * . _

follaws:

ad- 2--- iese1-generatef eapable-of-previdingpwerhin24hours-teperatensite eleetrie-eter-driven-ptum-shlahi-bcavfI bble- R -

17

ATTAXiMENT 3

( 1.

)#

PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_=1WjIWIg U *1O _

mI 1 T

I One-offsitesou~re~e -epewer-erableof-previdin~g-pwer to opefate-aensite eleetrie-noter-4riven-pmishll-beailable, R,

An-0t7*ite-pum-n~ot uirinag eleetrfseal pnvc-Jh e-apableo-fovidigmakup water-toie-Spent-FuePle1-wihin-24-houfs

h. :leqpllpesignate-t-ttsft}?e requireienesetpeeifletion 3 a rwtessf~ -4ls _ .')A I--- --- _# - -.- I t ralsahlr f or-1ess-thnn-1Ov'ljtt-Spent-lfet-P1tha0il

- i n-- ot ___ -elr Ity lr n UtI--tt--t tMl or~es-s thaF tQO2r4olie-Spenlt-rel-PeeH---4ie-capailit),toe-minlala iytiate-weast-a-gprn-IThw-tehe-Spen-Fuef-POOI-shuhfl-be-maintf*rned API-PAGI3'AI6 TY4hen sperit-uelis-i-tse4-Spent--PeI-PoeeJ L ._ .... ^ -^,A I- ..

A0+Ji Ir _ -I I _ - - I 1 I

.1_

A l-VIl 3wtt.O.u A_

Y.l.

UnotiF AI II Jim l A _ A Ni-: eqiemenI5-ei--.pee*featns .t or b.. I . eet-WfH-2 establissh-fm ternate-source of NY ter-eapableeo-elivegng ateas8p~m water ateampertture-equo-e tess-han tole-Sp entI Poole.

le-preVisiens efip~ecifteation 3.0.3 are-no~ppfiae, SEtANGI-REM EMENTS

__ _A- Arr I 9_ A

..t- -- -I- A_: ..- r _A_ _'- A A^

.1 I

n

^

1 n .

I A:

-"{IJIJ

- w1-I,.J -X5-75.W1~7 - I V- a I".- I-4Y44

____ 13 I 'L_ J:---l ___j r__ 'Ifl ___.

. .. ...- era414V-anff-f . W avs^_ dln(W sV. sW v

.. V ...... L ^ ,

{#. I . Tfnee4,e44-%T---;ff4 .. W. ;zvvz using41n-eleetrierneter-frven~urnpas-a~ead; 18

ATTAC1HMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

~1116t- 6 66i R ( M1a6jM

. 4.: I-11 I rli I I-

{.

- - - I A% _- _ A vef1iy

^4v..__r - I- t ne-pithes A _ A _e -

A 1 -.

rtytnFequirementse I-.

1-hims It. 2 ._ n VfeeFper--mo ! Mt, speeifiea i~re e pal- epnwttewn-244teur-n4wleetvef at lea 28gpm-wPAater.

ii. Onee-per monthiso-pent-Fuel-Poel-makeup-ialbe determined4e-be-OP-E I36b1E by-verifying-i iis-l-ec-apaiy-ty-be-tleast-'8 -pnh Based on the permanent 311 7i r4--LS-T0MrRAGE removal of the spent fuel from the spent fuel pool and lI1 I I ..,_

1 rT TUlT

&I- J C-TCf)

£ '. it*.

A T- r-E I

S fl'L--

II rL AT I- rT I V.*

c In r% A s.<S-3.,,f-l.-

dXTrC I *'

placement into dry storage, related Limiting Conditions U@l-4TJG- ONDIrTONNS-FOR-OQP-E4ATON for Operation and Surveillance Requirements

.n t _. r_

..____-.T.1 lX-r I In {LI..11tLA h1~..r'.a rz nnran~rttrpl na lft' ~~r~LA r

I~rII r.

. r-I rII r nnt~ItI flaljt1 r I .I

- w..r .s are no longer applicable and f"rf 'X ICrs'r'r.f rIrnl) A PII'%)T r-. C1TITTAr"l T A 'kTf'Tr D rTrNT TTTf?'. AWT

' I rfc 2..

.- 1

-f ~az ttngtei- will be deleted from the

%=itt4t 'FtN ' tf .4f-I rjt'*tNI I Rfttt-rytskft V' e ILjLt *.i. '.I i< 12it oi f.tite-tt:

arn^heah}.7-Phe-snent-uel-.snowfeenlled-by a different-setef-aipprwed teehnieaI technical specifications. The spe4fieatims-iseued-and- I

. _l 1rvtq1" ,._- t ....-

I-r-N n_ -

1 I-7 spent fuel is now managed by a different set of approved n . n S1.3 1lett~lewinttt~tatio~s<?H amate4?edtrfqet --....

rnPPehn-ent1U

-I- -I-r1 . . --- - --

technical specifications 1 o.,7 issued and approved pursuant to 10 CFR Part 72.

a. Spentt-fue-ssemblies-shlli-storedin-fuel-sterage-raeks oeate4-n-te Spent-Fuel-Po&.

b.--Te-storage-f-miter-ialsn4he-areadireetlybetween-raek-B-and4he-east zval£al=Rnnt~lelDnnl is nrn~r-cL

-I'-, F,.

AP'IGRW1heLT-Y:-Uien-pent-fiie4Spent-Fuel-P-ooe AC-T1GN: U-ithqlle-reqtirements-6fSpeefi-eations3.3no--3a- -. not-met-,sispend 3.bi 19

ATTACtIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS M 1 -Ma MI _ $]AlS - 01t]10M ioely ' - -- MIM

_!.._ M OIIS C_____. - .__1 _

kJJ,..It

-11.- B t4'*

-. I

_1

'.JtSI

- *'tgL I -.

_ 8 _.!_ !.!.

1IIt~Lfl.11 fl V IhI.....

I.uSl VJtI

. I_

11 .. -

I

. I 1.

tI5t&IIS lII..-

- -r l ____ _11__

_!__ t5t'A5I

-T

.411'.'W'

. 1- . .

and-per-ferm-fl-promptdnvestigatien-tdsetermine-te-eiule-6tand-fnate approprinte eorreetive-aetions,

, NC-SE RMET 44-.-3 n. At- east-sefi-annuagI 7rf71t~ne'rS 01 cnvmeeenee uty nmtevelty

_v r r . -fI-- I - f1- - A~~~~~. . vvPll @tf A

'..1 ._i DII%- -1 A .1 - l

.. e v - . .eqiI .e t e -- -etion4- k--hv eb e- - t7 - vv ., '--*-*

F~eqtiirements-eiSeeifie-atiotl 3.1.3 .a have-beeF>n-et-At...i, ., .,,

,, f _ _r _.. Ir _.! !.A tl.

invik4lngmovmemt-*peen-penemnt4-i-e-peiiee P-eeYeenfyhatthe reqI}irernenttof~e~ ipeien-3-44-b-te-een-mfet Based on the permanent

!4.' i'-FI4L-,-AND WNG removal of the spent fuel from the spent fuel pool and placement into dry storage, related Limiting Conditions MWUN'INS-CNDVUOS-JOR-FOIl'{NT4 for Operation and Surveillance Requirements Uased-entlhe-perrmanent-rem~val#~pentelfs - tplT~e-peT~t-fe1-peasoeiafted-[JMJ4NG arc no longer applicable and (I nT pry l r nD4~TC rlnrn A '1rP'NI--J -1 IMAM ITTa T AXfl.C' T'\T InIn T-TCrAXTTC' --

Tr - - VI 1-_1-TtITl, -_ V."

- B.,V.JiIBV..,1,

-. , I ._ - till A

-w-VI~s 'ax.; 1/4.' ISV LB 141 ii N 14 LaB VS I *VL.fl A L1 N I Si A. .-

BIB

-StIf'TI

,VI6DUT~

tA -1 P- 1 I A will be deleted from the he spentpuress-eiotw4eoFr-olld-7by-ierent-etppr-vedfeehieapeec fictisstfedlid technical specifications.

appr-ved-ursw1Tt}H4G~~ 'I R4a~r. 1) I 7-2.

71- 1.--Al:-- A.-I :--:A-~ ~ ~ ~ ~~~~~~~~~~~~" The spent fuel is now managed by a different set of

-s *- II ttItIs r S t ttI t t t~tTrJE MCI 1121CIJttt approved technical specifications issued and

.n ti.

-- -IVXII rntauxm^Ra~trntiorc~ruxu tttil r5 ltvttirll-tib,_

r I Ss^JSX*foXt

('(lN-I-AIIU-l;N ' ( 'I_ ()Xl _

I-1shnLIlI i -~ ,tt!T yt approved pursuant to 10 CFR

-rrA tnes Vt I t snsso 3latnt L --- -s1-A -"- - n-- l~ I,-fLp---1 Ttt rttr-l IMII TttmVII ~ttttteiswV*1~tTtl . e-l- -. Us-ftttt U-t Part 72.

bv. Itadfffon-1nvelv-s bel inwntamned-below~hclak~rmseu~inrequirement&4 I 20

I .

ATTAti-MENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_IfiS _*61 I Speei ficaIion-4-bd-.

AP-MU:GAB4TY-P ring- E-HFIAND G-perajiens A flflYCSl?

ASW416t- -'

.."I.II...1111-A IIs

._ > *rw

L L VI ifitinLit

.' ^ ^ -

ixc-ttt"'U1 -. _. . - vrzItt n1'L ztor' If-.ximnt L1 t Dl s

fliI l t

. .. . .. . I . II 'tlll -it'ttTylft inn-safenditioiandsuspend-V4JsbHaeNG-iei es-inside eentainnent, I'[?!. I- --

. I- - --- - - -.-- Ir 0 -- - -f- - -.____.1 IN I I- - -

, - - 'I a~norfnlat -- - I len

Ir--'---W-f--

. fi-

- 4 . I+ElUfq1I4I-FT} PRn

- . I'....-. . .MP-A-'r

_ . -11 __- -J ne~t 1

,_ a . ._ - vv

,.X.. l^;4lt,-

eentainnment ecntiatien4nlet-and-exhaust-vavesa-initiat eeereetive Retnr-tbo-redtuee4he-r(di-ation-eN~elst naee ptable values.

SURXLIM14A G I~REQU1R EMIN S

. I' I ,..i w.. ,.. ,,s\.- - _. x. rY , ' 1irtxsa rJ m

t1 n.- - l ..tlirJl 11 r'.T T r'A I - -A _ .

ve4VUttrterln-"t I-

- P f Vf_k AItT A

flfdi' A11L T t

I n-ffr 1tseei intainmen*

11 UnlaLfll-AMA ,-

dr AMC

~~I

~ ,-

r-1 Aors TV,'.Jf ir Ana7%

- .J

- k- ."z b1. Verify41hn-the-tleadiatio-l~evels-onhe-Spent-FueI-Pee -rea radiatien-meniter--afe4ess tlhalh~e4aforl7-seting-req q*rements-of~peeIlieetien at at-Ieastwiee-pef-SWFT-4 Based on the permanent 3/4'2 FUEL,h4N-PIN removal of the spent fuel from the spent fuel pool and 34-/.'. FUEUBL44ANP IGJNRREM ESNTS placement into dry storage, related Limiting Conditions LMYVl4N-@(GNDf-lON&FOR-OP-RA4ITN for Operation and Surveillance Requirements

{Bised-on-tperanetent-rem-e~sf-ent-fiel-frenti-4e-spent-fuepool, nssoe cita1bteNG are no longer applicable and CND1T U& PEOA -an enger-app e will be deleted from the Fhc spent-h~el-i5-noeontreI~-by-n different-set-ofepproved--teel~mnic1speeifieatioensissued-and technical specifications.

21

ATTXeIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I

approved-pur-si e--rt--7 The spent fuel is now I

7 managed by a different set of 3 E.' .' IT4ADL-NGeperatins ....................

ha~l-eenfrrmAt-the-ff~lel onvg .................. approved tcclnical req ~irernent*+ specifications issued and approved pursuant to 10 CFR a Wqevenlentsf-spelltate~intban+Gef-tlle-storage-raekerispecrion-stat ensshl Part 72.

he-restrieted-4o-one-nlssemhw-t-a-time.~

h. Radiwiefi-leve+fs-t-the-outhl wa~ll of-the-&ent-Ftel eel evlti on 6006.shal1e nirin tiinedeflnttc hf40-mre11 nAir-tbeve ie-bnekegfe-b1eveI-dt*f*Tg-R4Eb HANDUNGoperatiens-

c. F-UE4ND61NJsiM-e-aceoliipiisliedb)-anua-gidanee-vsuaI ebservttionaNoIZUE;ISL -1ANDM boperation*

4-W *Atter.- haH-be-ed-ese-he-basie-shielding-exeept-when4frantsfenfing-sent-fuel-ffem tihe-pent I~el-Peol-sing-the dry->fuielst rage-system-4tmnsfeask-AP-1i1-CABIl-T-Y,.-- Whei-4iadiing-fuewIe-pent-r-ueI-Peek ACIIbJ -4 i. -- Wi th-the-requireie o£pefnto .. ~ ent v se HANDUNGoperaionsnd -pae-rfuaiatelte kissemb1ic-s in-asafe eendi tion.e-dueti-,t-pr pt-investigation-tetermine-the-efmse-ead initiate-apprepriate-eerreetive aefiens-ii. Wit4e-requiremrentsofpeeifieatien 32.2..b not-met, IMM1DJATELYsuspend-FUEL H/ANDhINGopertieosn-tnitiate-aetien-to restorersdiatie-lo toesss4han5mrem/lrnabeve- baOX nd-evel ar, eonductapremptnvestigatietetemitne~he-caue nereased i ievels. FUELHAN PMNGmay-reume-~it is detemiined-hat-inefeased radiatien-evels-1ave-net been eaused by-the4ling of fue1-n-the Spent ke-Pee~ar-adiatien~evel ar-e vcrified-tocith requife -range.-

22

?

ATTAkHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_ . I 11 OW01 NS _ a _ If._ ..

ii. hW th-4he-requirerementsSpeecifiatin 3.2.2.e no-t-met-suspend-t AR13 hANDWNGepeferias.U.. HANDMNG-mayfes**mec nee hc r~equiremienits of .-.nmce-heen-e-est-ablisied-.

iv.-With-4he-reqiremeq el oSpe -ifie ation-d.-2t---et-me I iend-l1UEL WDIANPIneDatIons~-I44Be-F1aNe~AN B6a-Fe"*1rne one the rAn....-n...A...r

- I n __ , w-^ hA r SEIRIV-A-IC'E-RE-UIRlTIA -ITS

h. Wiortfo~mlltenern~-

.- 1 -- _ 1I--

dtrinoanrWM 4IDA TM ~4unon

-' "'b "&&' *^ -- >,^ ,,,-,, $

..t-tC tVt tlTry, 1- A NIrnTJt H.TXC!

Ftte ttff-itiff tf-iitttt - i11 1Itt t-t.......t- tl... -N I 1-1 1E seuttl-wvll-efP(Ie-Spenit-FruelePel. leevation-6OO'6", to

erir-hahe reqtiirenients£$peeific-atienlra c-Nfne 7 Former section 3/4.4 was re-numbered to 3 /4.1 (SEALED SOURCE CONTAMINATION) Editorial / administrative Report reference was revised to 6.4.4a revision to match repagination.

Based on the permanent 5.2G E ANNSTl2A1QPE-P-ET l;UEL removal of the spent fuel from the spent fuel pool and Ap eesign-features-seeefied;etion aor yen irfWuelrlirt4biiatLy placement into dry storage, is-stered-ni le-Spent-FieI-PtooIe these sections are are no longer applicable and will be deleted from the teclmical 5.A-G.lC ALI-T-Y- specifications.

23

Io ATTAk-IMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

- SO@6 I0 Or~~aflL.Z 1- -

arua Il !_ I_.

ra. nfnt-ti aI r

lrnrsraaku I I. . a__ . _ In 1.nnhIJr I_ l.___

ho I ntflinl withs-uffteient-eentier-4o-eeierdistene-betweenstored-ftiel assemblies4ensure-n-k~eness tlila?4o-eqrws7,tabt.9-5wlieti-the-raeks-are-floodedv-i-~tinborated "water-.Th-futel~oading~er a.x-ifakeent imieteer-- nea~,ssemibt~aleed4ile-ipent-F-elP-osi~albe esa-thmaier-equal-to Enfl-n11?Ui7um-f-ov873-gfflnlS-of-U -eF-e;Vflefl7t Fuel-inspeen-stations-idhstaolIled,-shI-besigned-asd-wientai ed-wifh-suffieient eenter-4o--eeiier-distainee-betweet-4hekssenmblies-pIaeedinhe-ienspee4itin-statiens4e"nsure aken4ess4h or-eqtuni-to-.9-wiei l~odedt4r"nberated Nvater, 5.2.2 WATFIJ-"4:E6

H}~nllt~tpl'oli~eiele~blla~7Xinol7rB~hvtercXelbetween-63 O' an&-63 ' "

- . 11. .., - -I.. - - . --

Fhe-c-oniguritioei{:sialge-rnekl*phieed-in he~pent-F~elP-aooIosfor-asdeq**ite eireulatioflf--wateF40)-prevefit4eeal ized-ei4-iing.l Fire 4-1-BRP-Site-Mep

.2.4 CAPACITY Subjeed-to-itelerniits-istedbelw-,te-fewl-proses4gned-fo~nd--sha1-be-m~aitained-with

-storgeuapneitno -iore41l-fa1em asesmbties. inpin,-fueli?-wh'ie t a"e been-remoed-from-fueasseinbliessh4l-bsteredin4he-pent-FueI Peel and-shall be ina geornetry-whie-i-ensures-sibe-riftieity.-4ie-oelving-4iniits-pIyo4h"e4amountof-speei I nhielear-nfateriat-whie4i-nf-be-stefedn4e-Spent-Fiel-Peel+

Ir5OkiJografns44-eofltrnnled-urfmnium-2 35.

24

ATTAktfIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I0 _ O_ Di _ _

rn I n A, At r . . _ - : **t ?C A

_:_ - I_

DI-322--1 rams-*MukinIunl-7-eentaineo-if-+i-Hsef-e-otiner-s.

A rl'~eai ltntleenuaea~ein4firc Delete reference. Extraneous

.'_______ 3 R~sinformation that is no longer required in Technical Specifications.

The re.aeor-iot-liteesed-for-wer-peratien--uekhall-et-e--eed--he-rcactor vessel-Based on the permanent 64.S. 4-.';F-[lF--S'P 11 J--WV-1SSQ removal of the spent fuel from the spent fuel pool and

I~le-.Slli hift ~wemml~fttn4-fuetieRi:

h-.~lferisewl71He--es0}7tb e-fl placement into dry storage, T-his posifiofiw~ilbe-Filleel-yot-ertified-es-iler. the shift supervisor is no longer required (see "SHIFT" and "CERTIFIED FUEL HANDLER" discussion) and the definition will be deleted from the technical specifications.

25

ATTAt-IMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

=~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~0 k Correct typo

-I 6.1.2 SITE GENERAL MANAGER (Decommisssioning).

The Site General Manager shall be responsible for overall facility operation, maintenance and decommisssioning and for periods of absence shall delegate in writing the succession to this responsibility. Unless otherwise specified, the Site General Manager's delegate has authority to perform all actions and grant approvals assigned by these specifications to the Site General Manager. The Site General Manager may delegate specific tasks to other individuals who may perform those tasks whether the Site General Manager is absent or present at the site.

26

ATTX1HMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_NETM I&AI Man a 0FM 2~13 __ pi MWITA, M 11MMU I

Based on the permanent 6.2 ORGANIZATION removal of the spent fuel from the spent fuel pool and placement into dry storage, 6.2.1 REPORTING RELATIONSHIPS CPC-2A has been revised and submitted to the NRC for review. CPC-2A provides a description of the Onsite organization and corporate reporting relationship shall be established foi-aetmties organization, and can be affeet inetf-y-ohe-~e~oilit-y. as described in the "Quality Program Dcscription for Nuclear directly referenced to Power Plants, Part I - Big Rock Point (CPC-2A)". improve this technical specification section.

a.k-ines&-eiithyorie . t d ita n-e ni n ien-shaiaibi ll- be esinhiishled -nn -doelo ented-i ity- i nistreti ep reedures h.- Fhe--Si te-Gener~el alMoiier-sibe-responsible~br-safe-epefrnon-efp e faeilit-anad stina Ii)Have e-oFOI Oei-F4yOSe-inSiteei-tieS4eeeSsaFpY-ei Safeo-heioatioenand ma intne{Rl~iiasTlddveu~ thitpsion-shaI-epel4dreedy to-tIle-SenioiF--uelear-Offieer .

e--The-i ndi vid un Iswhoper-f-Tormaudi tsurvelIan Res -andindependent safety-reviews repf~ft-to-tlhe-MinagevFR aeleuar-erkfornonee Assessment Depai4nent-dt - 1-e-iiidividutals--whlo4r-tai Cer-titied-Ftel44andltrsi-nd-4hose-who earry-out rndiatieon-roteeiin-litnerions-repor4t eoheappropr8te ensifte managerh they-v slal l-ave-suffieient-ergaizationaIfreeem4e*

ensur e-tlheir-iindependenee freon-operrttint-pfess res Based on the permanent 6.2.2 FACIIITY ORGANIZATION removal of the spent fuel from the spent fuel pool and The Site General Manager or his designate shall verify that required security staffing and placement into dry storage, 27

ATT "z1IMENT 3 .-

PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_IC S F.-S S i)ry, Fuel Storage Tecinical Spccificationis surveillanices heave becn 11ct. this section is no longer applicable and can be revised to improve the technical specifications.

The-feility-organii,.tion-shal [be-sAbjeet-~ihe-fbliewing1 See previous discussions for

0. emrprised-of-aFeasfhemitlimunm-ii ba}e~tsidle deleted definitions as they crew comsp*itionshow~nian-Tble 6.2 1. appear in this paragraph.

b.- Atleeast-knenetidividviad rewhanb qtuai ed4o-standwateh-isle WAflXllT^O~ IAj-L CI 'r ArTtIXT-I-I t5 Ln1 : - -- At^ n'KT'rnDT],Tkt. ~ Acrn X...

s. .I Ji .. L..-, . IISII. i _ - - .5 -* I4-v ** .-

'1. ,f

-&fl 'nfl.SI irrodifted-fuel-s-fine-Spe-t-Fuel-Peol}

ro.

_b .. . - 1_1rEvA rr wr., _w. .s_ T tt be r .rA.iIntIt-5 ' I r

I I fijI l 1in rnv-- ...... - -... - V --. - 1-STiper-yFf iS -OfTtlie-NoeT-Cer~ewperate-siml n 1 ifite to,-~ia _T _

edaiatieRTmtee3tio T-)

narin ;_ Iry

_-__A -_- - - li-A:-i:-- in t'lliLtulcvtftlczr.-"T-C"IttItutit","IA g _ _ _ _

IITANPM NG- perntikFnsq<TwTTiTIedadiafion-Ptee tienTeehieTi en-lTShlaTbbeeonT

l. hnspetlieI-spest4'red-in~heenbL~atue1-peoIei~oourinlg-F4b TIAN>NDNGoper Fntiontlminist tive-proeedures-sha6be implemented444imit-theewrking-heurs&efhe facility-staff-Mio pe-forrni-afety-fehted-funetinesnd-oetities-impeorhtinohe-safe storage-f-spen 4nISSFeqnd nietrainnd-e ntret-

-ndA:--: o1-1ISt t-~lF , IIX4t-3 INds r1..^lr _-Is.d.A in#j- rLIIE tt ttH_ t! I r IC .t I . -.

ffeW-

_ __ '* __! I I

I - . .

n K a- - Promotion e* J

-, J__.1 V --

Teeinieians Adequate-1T-eoerage-shall-bedaitnTaheitl- r utinea1 y-se-ef overthne-.Hewever-i tle-evenenht- tiunreseen-&bTes equire-substantial am oun of t.. vertime-4 bsed. the folewine-fdelines shall be fe11owed-28

I ATTACiTMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS 4

... .... Y-Tt, t-- tt-tttA

_-]

i *VI tt%, 'slr 1_

X, X _Itl s* -

I-nr-...1.-

._...._.t

._ +1s+A heou-,straight-,e ttding SHIFT tinover4ie (2-) --- An*nlividcdt-slouild-net4bepermitted4o-work-moretflmn 164-hurs-i nniy 24-hour-peFiod-nemore4han-4 houfurs4-i-AO4-h*r perio4-tmore-tln724ur-sinany-7-day-peried-aI ing-Sl-lT turnover4ime-

.3-)----A-breaikl+ne~tding-Hl4T r4urnover-ime-f4t,-easg-.h

-1leuld-be- wewevflerntinu uus wof16 f-s-duratien

_t _ I I L .1I *__ Il . _ '.

_ . _ ^: _.

. _ r_ _ _ .4 _ -__1 __

+W~ev~abwremauwtneslulbe aumetzeorqlzte A .-._t Getieral-Mniagefr-oesignate-alternates-inardamee-h-estaibished adeunistatioiwvAreeednresativ withoedummefsationh-tie-basisfor-gernttheg the-deviation- Adimiiiistative-preeedulreshaeti-ielueareq7uiremenaer tlie!

oet: ctelimVV!fwitnzgefvr-e!tgnuett uften~tutet~lttrevew i-nd-j..l~r have not heen-ossite4-UII na -~ atlol; r tiite-te 4ation4 lt

_ - *Ap, Ar ttm-he-tKih fl-

-c*essivehours have-not-been nsirspned.- uinqestueaet -- - --- ---- --- -

lt;ft

- C;,--- ---

Al ;" Afen no-autlhorized 29

ATTACIIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS

_ 01 R.--il Rlk 1 i a lio CA Mil KI I S TAB-14-MINIMI4M-54 HFP.-SXWOMPOgITION PV4R JNO-IPSRMANE-NTFU4D-GONT4N

&TAFFNG-FOR , TAFFING OP4RTOPNS DURING-PUSI, POSTON WI1hOUT 9"PING

___________________________~_FU EL,-ANDIANGlOPERAIIONS SHIr-~TS ie Fvi sor-(lr- T-Il IU)-r. tj1;" NpL Nen-Gertified-Operateo . 4 Q E-RXTI F It -F Wr. 4 tA-N P L F-R________4 RPtdiatiot-Protection-Teehni-ian -- 4 t--i/Sli pervisoor-Noii-GettifiedOpertor-rnot-ertifiedinaediatien-P otection-reedures I 11 v II? A TIE1 -

f. Tl IJtfl..

tt- l~

-.4JJ-I

--T

.IIflrflrtflCQflngfl

-__ _l tZt I I hp

_1 rn I -1:14 t~sr I

1I 1

)

T II 1 H

s. I II .. flZ

"- - t vW IX ,.

.,Tr* l-lU ff OF...... .r : -A 1.-11 .- --

a ...I srra.lol V IJIJI a11t15 I - -r Ixr7 i..

_ SfltJ5 Ir ITIfl1SLIjJ'...I tIt T1 Y A KIT rt . t - v Ir....

,r DT`Tbr"I ll %l~T-TITT IT AXlTrT "T.

t- -_. I---_.., I- - - I- -

- -P-ernnepreI-ireupth1nt: f (a ntt-

.s z *4- zs5-1-1 vs. 11-\ t~--w X - s;---- z -- w-

-.

wv---w minifmmspeei ied-apri-vod-e me entoeeed-2-hurs-ierdef tn-necomtimdatemnepeeted-absenee-fon-duty-persenne-previded immediate AC-T-PIN4s4enve-estore4he-w num-e-quifemenits spefied-.Ts prionvis-wienvtloSI;T personnc.-ad doesnett-permit-any-SH re pesition-to-be unmanned-upen SI I-FT chge-ne-toeneriem lFS revf-member-e [ate-ef absent.

30

ATTA)EHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS J .41I11Irve 0@~~~~~~ 2 1 1- fa IN a*e I I Based on the permanent 6.41-TRAINING removal of the spent fuel from the spent fuel pool and

.t .. n- 1A 1 T -"-D Is ,..:..:.. £ I-- 1r T .T A I % 1 A1 -

placement into dry storage, these sections are no longer

Ulie4;i to-GenerolM ag~erhlas-over~4Iresen~si-ltyfbtw-impernentafion-ea applicable and will be deleted flminleflflflee-ot:" l=e-tminh -progI.af from the technical specifications.

Renumber section 6.5 (REVIEW AND AUDIT) to 6.4 and reformat title of CPC-2A within the Editorial.

paragraph.

The regulatory definition of 6.65 PROCEDURES AND PROGRAMS Safety-Rclated structures, systems and components that 6.65.1 PROCEDURES are relied upon to remain functional during and 6.65.1.1 Scope following design basis events I to assure: (l) The integrity of Written procedures shall be established, implemented and maintained for sAety the reactor coolant pressure quality related stfketures,-systens-eotponent.-an4 afet-aetions-activitics defined in the boundary (2) The capability Big Rock Point Decommissioning Quality List and theses uetesystems-, to shutdown the reactor and eempfenenlts-ttd-7etivitiesemportsneflafe-st~eerge-espent-fuel-(1SSS-P) maintain it in a safe shutdown andmonth}]eiibringnnd eeon l-ofred{:feleg ia gir a CrH These condition; or (3) The prosedures shall meet or exceed the requirements of NSI-N-l-87 1976 as capability to prevent or described endorsed by the Quality Program Description (CPC-2A). mitigate the consequences of Written procedures shall also be established, implemented, and maintained accidents which could result covering the following activities: in potential offsite exposure comparable to the applicable

a. Defuele4. ISFSI Security Plan; guideline exposures set forth

b. Defiuele-Emergency Plan; in 10 CFR 50.34(a)(1) or 10 C. Fire Protection Plan CFR 100.11 of this chapter,

d. Quality Program Description (CPC-2A); and, as applicable, is no longer

c. All programs listed in Specification 6.65.2. applicable to the Big Rock 31

I ATTACeiHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS Point site.

I.

Based on the permanent removal of the spent fuel from the spent fuel pool and placement into dry storage, there are no design basis events consequences as evaluated in the UFHSR and the BFS SFSS SARS that require remaining systems, structures, or components to provide the assurances defined above.

The term "safety-related" has been modified to be consistent with the term "Important to Safety", which is used in the recently revised Quality Program Description that endorses the requirements of ANSI N1 8.7 1976.

This paragraph has also been revised to reflect revisions in terminology in the Quality Program Description, the removal of"Defueled" prior to Security (renamed the "ISFSI Security Plan to be consistent with the license),

and Emergency Plans for simplification, and the deletion of section 6.6.2.7 of 5

this current technical 32

ATTAiIMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS l specification.

Renumber items in section 6.6 as 6.5 Editorial 4- ~ ~

Former section 6.6.1.1 (Renumbered to 6.5.1.1), Deleted reference to "safety related" and replaced with Safety-related SSCs are no "quality related" longer applicable with all Deleted Important to the Safe Storage of Spent Fuel (ISSSF) and Important for the Control and spent fuel stored on the Monitoring of Radiological Hazards (IMCRH) form paragraph and "endorsed by the Quality Program ISFSI. Activities/programs Description" was revised to "described by the Quality Program Description..." that are ISSSF are no longer applicable with all spent fuel on the ISFSI. IMCRH is achieved through compliance with CPC-2A and alO CFR Part 20.

Revised the list of activities requiring written procedure from: ISFSI security plan is the "a. Defueled Security Plan; only applicable security plan

b. Defueled Emergency Plan; with all spent fuel on the

c. Quality Program Description (CPC-2A); and ISFSI (reference letter to the d.AII programs listed in Specification 6.6.2." NRC dated March 27, 2003.)

To: Emergency Plan name has "a. ISFSI Security Plan; been revised.

b. Emergency Plan;

c. Fire Protection Plan; Added Fire Protection Plan

d. Quality Program Description (CPC-2A); and for consistency with revision

e. Radiation Protection Program." in deletion of former section 6.6.2.7 Added Radiation Protection Program to eliminate numbering-cross references.

I Ii 33 II

ATTACHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I-

&6-6.24 Fire-roteGtien-Pmgram

9 IW 1al OS~~1 R1OWIMI - ~ S As a Part 50 licensee Big Rock Point is obligated to 11 abide by Federal Regulation.

A-iepee.inpora-etn~Gr-ureet-f4-r~0S4~ilb-salse- This is a redundant implemente-d-,and-maintainc-d requirement and will be deleted from this section of the technical specifications.

Also see section 6.6.1.1 above.

Based on the permanent 6.6.2.9 Spent- el-Pool-Water-hemi-itr~-Program removal of the spent fuel from the spent fuel pool and placement into dry storage, This-progruaniss-rdurese-tprovide Gontrels-for-monitoring-Spent-Fuel this section is no longer PIowater-heniist-e-pent-;uel-eelWaterChemistvr-egr~a-shall-o applicable and will be deleted establisheim n, whenever iadmdiatei-fti-is stortinhe from the technical Spent ue loolo specifications.

Based on the permanent 6.6.2. 10 Inser-ieG4ngptien-and-Testing-Pr-ogam removal of the spent fuel from the spent fuel pool and a.Appl cability placement into dry storage, and the fact that there are no Applis-to-nse-vioonspertion and Testing-of ASME- ode-Glass.}-1 longer any Code Class 1, Gass -2and-Cls4-piping-systems-and-mponents 7 Class 2 and Class 3 piping systems and components inservice at the facility, these sections are no longer b-. Objectivo applicable and will be deleted from the technical 34

ATTACHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS I _ _llDi UU411 h-19[el ___3 specifications.

[file II T-ins-intogrity- e-Glass- 1, Class and Class 3 piping-systems andiompents 6.Sp e-fiations 1.- Insevic-InspeGtien-ofASME-Godo-gass 1, 2 nd4 cenmpene-nts-and&*ser-ie,-e~sting ofA-SME-od-lass4I,-2 and -punmpsand-valves-sha1I-ber-formodn-acordane-,with Sectienn.I-eftheASME-Boier-and-Pr4ssuro-Vess1C-Gode-and appicab bldd dd-ag-roq 1 GFR-soy-se-tion 50.55a(g), exrept w e nifi bhere, writtn - ra n-ranted hby the Commnission pur-su nt-o l 0 GGFR 50-teien

-5.55aagn6(),an-hersfGien-ionf S__tins 1l.4. 1.4, 4.1.5 and 11.1 .3.1 take precedenoe,

2. Suffiaient-records-feainspe~tiensha ale llow comparison-and-ezaluation-ofituro-tests.

3. Te~nserviee~nspeotion- gr-am-ssalvreevaluated-as required by 10 C150,-SeGtion-50.55a(g)(5)4to-consider ineorporation-ofnewinspeGtion-teGhniqus4hat-havo-ben pr-oven-pra~firal,-andhronelu;ionns of-the-valuatiosallbes used-as-appropr-iate4tpdatethenspection-program.

Editorial.

Renumbered former section 6.7 to 6.2.

I 35

ATTACHMENT 3 PROPOSED CHANGES - DEFUELED TECHNICAL SPECIFICATIONS a 11tOS 0. I 1Lo 1.j Based on the permanent 6.76.4 SPECIAL REPORTS removal of the spent fuel from the spent fuel pool and The following special reports shall be submitted to the NRC as indicated. placement into dry storage, this section is no longer a If the-at6qualitpe-GfiGationnf 3.1.1 .. arxced ndtho applicable and will be deleted water-qualyG nno etewrafter- weklprarasial from the technical repthat-ideti he causeand-proposed-GerrestivaGtion(s)to specifications. Re-letter as ensure-fitur-wateruality-i&in Gempliance-and-submit-teo4hNRC-by shown.

X-lsa-ollowingntyinto-the L O.

ba. If the sealed source contamination limits of Specification 3.4.1 are exceeded, a special report shall be submitted to the NRC within 30 days of identification of the existence of the excessive contamination. The report shall describe the equipment involved, the test results and corrective actions taken.

. .. - --- - 11 I- .. 11 l

nd Section-A.1 44h Smg-Baer-and Press roAlossGI-Gede-Renumbered former section 6.8 (RECORDS) to 6.7 Editorial.

Corrected title of CPC-2A Added 10 CFR 72.75 to 6.98 REPORTABLE EVENTS ensure that events or conditions requiring reporting A reportable event is any event or condition that must be reported to the NRC are initiated.

in accordance with 10 CFR 50.72, 10 CFR 50.73, or-10 CFR 50.9(b), or 10 CFR72.75. l 36

Attachment 3 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Proposed FACILITY OPERATING LICENSE AND TECHNICAL SPECIFICATIONS (Lined Copy)

(Originally submitted as Attachment 4 to August 6, 2003 Correspondence)

Revisions are Marked by a Double Line in the Right Margin December 1, 2003 42 Pages

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555 CONSUMERS ENERGY COMPANY DOCKET NO 50-1 55 BIG ROCK POINT PLANT FACILITY OPERATING LICENSE License No DPR-6

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Consumers Power Company (renamed Consumers Energy Company by Amendment No. 119, the licensee-) dated January 13, 1975, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter 1; B. Construction of the Big Rock Point Plant (the facility) has been substantially completed in conformity with Construction Permit No. CPPR-9 and the application, as amended, the provisions of the Act and the rules and regulations of the Commission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; E. The licensee is technically and financially qualified to engage in the activities authorized by this operating license in accordance with the rules and regulations of the Commission; F. The licensee has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this operating license will not be inimical to the common defense and security or to the health and safety of the public; and Big Rock Point Amendment . 1N19XXX A6UG 1A41997DATE

H. The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40, and 70, including 10 CFR Sections 30.33, 40.32, and 70.23 and 70.31.

2. Facility Operating License No. DPR-6, issued to the Consumers Energy Company, is hereby amended in its entirety to read as follows:

A. This license applies to the Big Rock Point Plant (the facility) owned by Consumers Energy Company (the licensee). The facility is located in Charlevoix County, Michigan, and is described in the licensee's application dated January 14, 1960, and the Final Hazards Summary Report, as supplemented, updated, and amended by subsequent filings by the licensee.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Consumers Energy Company:

B.(1) Pursuant to Section 104b of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" to possess the facility at the designated location in Charlevoix County, Michigan, in accordance with the procedures and limitations set forth in this license; B.(2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," to possess at any one time up to (a) 2500 kilograms of contained uranium 235 in fuel rods, (b) 10.32 grams of uranium 235 as contained in fission counters, (c) 150 kilograms of plutonium contained in PuO 2-UO2 fuel rods, and (d) 5 curies of plutonium encapsulated as a plutonium-beryllium neutron source; (a) Deleted (b) Deleted (c) Deleted (d) Deleted (e) Deleted (f) Deleted (g) Deleted (3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of By-product Material," to receive, possess and use at any one time up to 7000 curies of antimony-beryllium in the form of neutron sources, 3.7 curies of colbalt-60 as sealed sources, 45 curies of cesium-137 as sealed sources, 1O microcuries of miscellaneous alpha emitting material as sealed sources, and up to 500 millicuries per nuclide of any byproduct material between atomic numbers I and 83, inclusive, without restriction as to chemical and physical form; Big Rock Point Amendment No. 120 Dec. 24, 1998

2.B.(4) Pursuant to the Act and 10 CFR Part 40, "Domestic Licensing of Source Material," to possess at any one time up to 500 kilograms of depleted uranium dioxide contained in the facility's fuel assemblies; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such by product and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

C.(l) Reactor Operation The reactor is not licensed for power operation. Fuel shall not be placed in the reactor vessel.

C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No.4124, xxx are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical Specifications.

C.(3) Physical Protection The licensee shall fully implement and maintain in effect all provision of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), as modified byNRC-approved exemptions. The plans, which contains Safeguards information protected under 10 CFR 73.21, afe- is entitled: "Big Rock Point Plant Defuaeld Securit' Plan," Witherevisions submitied tlhrou-,h January 16, 2002; "Big Rcek Point Defieled Suitabilit:' Training and Qualification Plan," with revisions submitted through March 12, 2002; "Big Rock Point Plant Dcfuczld Safeguards Contingono'en Plafn," with revisions submitted throeug January 11, 2002; nd "Big Rock Point ISFSI Security Plan" as submitted on July 31, 2001 and modified b ltter dated March 6, 2002. Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

2.C.(4) Deleted 2.C.(5) Deleted 2.C.(6) Deleted 2.C.(7) Deleted Amendment 443214-24xxx September I:I, 2002DATE

D. This anmended likeisc becemesThe license amendment is effective as of the date of its issuance and shall expiFe OtMhay 3!. 2000be implemented within 45 days of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Original signed by Richard D. Silvr ferSignature Dnnis L. Ziemam+n. "eCNare Operating Reactor Branch No. 2 Disiecn of ieeiTITLE

Attachment:

Change No. 46 xxx to the Technical Specifications Date of Issuance: DeeembeF 19, 1975DATE

-NUGL-E-AR-RE-GULAT-ORY-GOMMISSION GONMERS-E-NERG'y-CGOA nnrc:KE GO.50 15-5 BIG ROK PROINT-PAINT AMENDMENT TO FACILITY OPERATING LICENSE

-AmeRdet-No.424 IKg. nmm) a be

1. The Nuclear-Re ulatory Commission (thc Commission) has found that:

A.~ ~ phto for amendment by osmr ncg opn (h iese dated Junc 11, 2002, as supplemented by letter dated July 3, 2002, complies with the Stanrds ad r-equirenents of the Atomic Enegy Act of 1951, as ameded (the At), a thCommission's es and regulations set forh in 10 CFR Chapter l; B. The faciit wIAl be maintained in conformity with the application, as amended, the provisions of-the Act, and the ules and regulations of the Commission; C. There is reasonable assufance (i) that the activAties authorized by this amendment Gan be conducted Gsithout endangering the health and safety of the publiGand (ii)that suGch aities will be conducted in compliance iwht the rules and Feaulations of the Commission; D. The issuance of this license amendment-- ll not be inimical to the common defense and security or to the health and safty of the public; and E. The issuance of this amendmc.t is in accordance with 10 CFR Pat 51 of thc f iles and regulations of the Commission and all applicable requirements have been satisfied-.

2. Aeeordingly. the license is amended by ehlanges to the Technical Specifications as indic-ated in the attaehrncflt to this lic-ense amendment anld paragraph 2.C.(2) ef Faity Operating License No. DPR 6 a.,d is hereb amended to read as folo.s:

2. Technical Specifications The Technical Specifications contained in Appendix A. as r-e'ised through Amendment No. 124I, arc hereby incorporated in the license. The licensee shall maintain the facility in accordance *ith the Technical Speeifications.

2. :eTe license amendmcnt is effcetive as of its date of issuance and shall be implemented mvithin 15 days from the date of issuance.

FOR TH4E NUCLEAR REGULATORY COQMNSSION Robert A. Gramm, Chief, Section 1 Project Directorate IA Division of Licensing Project -Management Offie of Nu v. r Reator 1tA Regulation Attachiment: Chang.,es to the T-echnical Specifications Pt lef Aissuance oSeptember ua 11, 2002

Amendment XXX2.-, 11 l DATEScptember 11, 2002 1

DEFUELED TECHNICAL SPECIFICATIONS FOR BIG ROCK POINT PLANT DOCKET 50-155 LIST OF EFFECTIVE PAGES as of AMENDMENT 14XXX Septe ber 141 -2OO2DATE I AMENDMENT REVISION DESCRIPTION NUMBER DATE LICENSE - Page 1 .................................................................... 44-9XXX 08t14/1997DATE I LICENSE - Page 2..... 120 12/24/1998 LICENSE

- Pae 2 ...................................................................

LICENSE - Page 3 .................................................................... 424XXX 09 11I2002DATE LICENSE - Page 4 .................................................................... t-124XXX t2491O/t1975DATE AMENDMENT TO LICENSE (2 Pag ) .................................. 121 09/1 t 2002DATE Table of Contents (3 Pages) ...................................................... 41224XXX 0114P-I000DATE I Section 1 - DEFINITIONS Page 1-1 .................................................................................... 1-20-XXX 1-2/24,11998DATE Page 1 2. 120 09/28/2001 Page 1 3 ... 120 01/13/2000 Section 2 - SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS Page 2-1 ... , 120 12/24/1998 Section 3 & 4 - LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS Page 3/44-0 ................ ;.................... 10XXX 42/2411998DATE Page 3/4-2 ................. . ......................

! 12/2499DATE 120.%XXX Page 3/1 3 .......................................... 120 12124/1998 Page 3/1 4 ............................................................................. 120 1/2 1/998 Page 3/1 5 .......................................... 120 12/21/1998 Pbgc3/1 6 .......................................... 120 12/21/1998 Pagc, 141: 7 ................................................................................. .

2 nov 12/2/1998 _v.

Page 3/1 8 Pace3/1 8 ............................................. .. .... ... .. .. .. ... .... .. 122 09/28/02001 Pag. 3/1 1.122 09/28/2001....................

Pagege 314 b>4 119 0 v................................................................................ *vrIS 122 09/28/2001 PaPage/1 e 3/AI 1 3

. ............................................................. 1.2_ 09/_8/001 120 12241/1998

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P~age 3/413 .............................................................. 120 12/124 1998-Amendment 121123, 1234-2IXXX Januafy 13, 2000eSptember- 11,422DATE I Page 1 of 2

DEFUELED TECHNICAL SPECIFICATIONS BIG ROCK POINT PLANT - DOCKET 50-155 AMENDMENT 414-XXX DATED .PTEM1 i R h-4002DATE I AMENDMENT REVISION DESCRIPTION NUMBER DATE Section 5 - DESIGN FEATURES Page 5-1 .................................................................................... 124 09/11/2002 Page 5 2 .................................................................................... 4191 01113/2000 J--4 Page 5 3 .................................................................................... 12/24499 I Section 6 - ADMINISTRATIVE CONTROLS Page 6-1 ..................................................................................... 4210XXX 12P-4/1998DATE Page 6-2..................................................................................... 420XXX 1 e24/41998DATE Page 6-3 ..................................................................................... 4-OXXX 412,21/4199QDATE Page 6-4..................................................................................... 44OXXX .12P244998DATE Page 6-5..................................................................................... 4aOXXX 124141998DATE Page 6-6..................................................................................... 4-OXXX 1212411998DATE Page 6 7..................................................................................... 120 12P21/1998 Page 6 8..................................................................................... = 120 12121'1993 Page 6 9 ..................................................................................... 121 01/1312000 Pa,,- 6 . v .................................................................................... 121 01/13/2000 Page 6 11 ................................................................................... = 12-1 09411/200 Page 6 12 ................................................................................... 120 12,421/1998 Pagc 6 13 ................................................................................... 120 1-2/2411998 BASES ...................................................................................... N/A (Pages B3/4-1 through B 3/4443) I Amendment 121123, 123124XXX January 13, 200OSeptember-11,2002DATE I Page 2 of 2

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 1.0 DEFINITIONS 1.1 ACTION ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

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- I-- 11c 1 1 1 1 = t=P F k1-I-- t-- M f 'I 1 -1 tv't7f-CERTIFIED FUEL HANDLER, is an individual 'xho is qualified in accordance wvith BRP Program D251.. "Certified Fucl Handler Initial Cctification Program."

1.- , CHANNEL CALIBRATION I A CHANNEL CALIBRATION is the adjustment as necessary, of the channel output such that the channel responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompasses the entire channel including the sensor and I alarm and/or trip functions, and includes the CHANNEL FUNCTIONAL TEST.

The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

1.43 CHANNEL CHECK I A CHANNEL CHECK is the qualitative assessment of channel behavior during operation by observation. This assessment shall include, where possible comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measuring the same parameter.

L.64 CHANNEL FUNCTIONAL TEST I A CHANNEL FUNCTIONAL TEST is the injection of a simulated signal into the channel as close to the sensor as practicable to verify OPERABILITYperformance, I including alarm and trip functions.

CONT-AINMENT CLOSURE

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UUN AINMEPHI CLOSURE is that condition el containment in which there are

' * . is And t A. _l, A -- ro f:K 3aireci naths frrn containment atmospher c to the outside atmosphere, exeept for ten

.I ote.^t ,^ !-+- t --- I r l ~he-~ t valves, which may be open if at least one exhaust fan is in operation. Leak tightness is not required for CONT-A.IMENT CLOSURE to exist.

1-1 .AAM1Pn%412FTLIS1 1 ?OAmendment xxx l Date I

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 1.0 DEFINITIONS 1.7 DIRECT P.Th A DIRECT PATH is a visually obServable opening whilh permits the free exchange of air betveen containment and the environs. Equipment configurations or an engineered featufre such as a closed valve, check valve, water seal, closed door, membrane lay er, or securely fastened plate may be used to preclude direct paths. Redundancy of engineered features to eliminate direct paths is not required.

1.8 FUEL HAJNDLING FUEL HANDLING means the activities associated with moving spent nuclear fuel.

When spent nuclear fuel is contained in a closed and sealed canister, the activities assoiated with moving thecasr a nt to be considered FUEL HANDLUnG.

1.95 IMMEDIATELY When "IMMEDIATELY" is used as a completion time for a required ACTION, the ACTION should be pursued without delay and in a controlled manner.

4. 10 ONITORINIG STATION The 40NQITORING STATION is the facility which has monitoring, alarming, data archiving and limited control capabilities for selected system parameters during the decommissioning process. The Control Room shall remain the MONITORING STATION n-til suh time as a new facility is activated to ser-e this funetion.

1.1 OFFSITE DOSE CALCULATION MANUAL (ODCM)

The OFFSITE DOSE CALCULA.TION NMANUUAL (ODC-I) contains the methedelegy and paranieter-sused in thc calculation of offsite doses resulting fromn radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent moniring alar-m and trip setoeints, and in the6 enduet of the kadiolegical Environmental M4onitoring Program. The ODCM4 shall also contain (1) the Radioactive Effluent Controls and Radiological Environmental Mlonitoring programs r-equifed by Sections 6.6.2.5 and 6.6.-2.6 and (2) descriptions of the information that should be included in the Annual Radiological Environmental Operating and Annual Radioactive Effluent Release Repoes required by Specifications 6.7.2 and 6.7.3.

1-2AMIEDN4MENT NO. 120, 122Amendment xxx September 28, 2001Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 1.0 DEFINITIONS 1-1

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A system, subsystem, tran copolnt or-device shall be OPERABLE or-havc OPERABI-ITY.v hen it is capabl of peeforming its specified function(s) and -v4wen all necessary attendant instmetai, ntrls, electrical power-, cooling r seal water, lubrication or other auhiliaf~ equipment 1hat are r-equireA for +the-system, subsystem, train. compenent cr device to perform its safet) function(s) arc also capablc of performing their related support funetion(s).

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The PROCESS CONTROL PROGRAMb contains the methods and determinations wMhich ensure that the processing and packajing of wet solid radioactive *wasteswill be accomplished in such a wa) aast sure ompliance with 10 CFR Parts 20, 61 and 71, State regulatidns, burial ground requirements, and other requirements governing the disprsal of solid radioativ t 1.446 REPORTABLE EVENT I

A REPORTABLE EVENT is any of those conditions specified as reportable in Specification &96.8.

A SHIFT shall be the duration of the nornal weor period, which will be either O 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in length as determined by the Sitc General Manager. For purposcs ot detcrnining the maximumn allowable time between surveillances, when the specified su;r.'illanee inter.al is "Once per SHIFT," the maximum allowable exto tt exceed 25 percent of the specified surneillanee interval described in Surveillance Requirement 4.0.2 shall be based uper the SHIFT duration apprfe.cd by the Site General Manager- at that time.

I I

I Amendment 120,-1-21 xxx January-13, 2OOODate 1-3

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS There are no safety limits or limiting safety system settings applicable to the permanently defueled condition.

Is 2-1 A.MENDME-NT NO. 120Amendment 120 December 24, 1998

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITIONS FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 Unless otherwise specified, entry into an applicability condition shall not be made unless the conditions of the associated Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements.

SURVEILLANCE REQUIREMENTS 4.0.1 Unless specified otherwise, Surveillance Requirements shall be applicable during the specified applicable conditions for the associated Limiting Conditions for Operation.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 Unless specified otherwise, performance of a Surveillance Requirement within the specified time interval including the maximum allowable extension shall constitute compliance with OPERABILITY requirements for a Limiting Condition for Operation and-associated ACTION statements.

4.0.4 Unless specified otherwise, entry into a specified applicable condition shall not be made unless the Surveillance Requirements associated with the Limiting Condition for Operation have been performed within the stated surveillance interval including the maximum allowable extension.

3/4-1 AM4EN1DMEN1T NO. 120Amendment xxx Date l

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS I IA I FUEL STORAGE 3/14.1.1 SPENT FUEL POOL PARA1.1ETERS LIMITING CON!DITIONS FOR OPERATION The following parameters shall b e monitored and i......ted within the limits indieated:

a. The wvater level in the Spent Fuel Pool shall be maintained at or above 630'..

b. Spent Fuel Pool water temperature shall be maintained greater than 10 0 F and less than 1100 F.

c. VtWater ehemistry in the Spent Fuel Pool shall be maintained within the pH 5.0 to 9.0-Conductivity less than or equal to 10.0 micromhos per em at 77 °F

d. Radiation lcvels in the area of-the Spent Fucl Pool shall be normally monitored by two gamma radiation monitors, each with a locally and remotely audible alarm set at not less than 5 millirems per hour and not more than 20 millirems per- hour, emcept during the moevcment of spent fuel or radioactive components in or adjacent to the Spent Fuel Pool, when alam settings may be raised above 20 mrea~hr provided the overall detection criterion in 10 CFR 70.21(a)(2) is satisfied. At least one monitor is required to be 'OPERABLE. The monitors shall have remote indication and the capabilty of recording data.

APPLICABILITY: When spent el is in the Spent Fuel Poel.

ACTION: i. With the requirements of 3.1 ... a not met, I1MMEDIATELY suspend activities having potential to drain the Spent Fuel Pool. Place fuel assemblies and the crane load in a safe condition, suspend further movement of fuel assemblies and crane operations with loads in or over the Spent Fuel Pool, and initiate action to restore Spent Fuel Pool wvater level. Within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months establish CONTAINMENT CLOSURE, ii.With the requirements of 3.1.1.b not met, IMMEDIA.TELY place fuel assemblies and the crane load in a safe condition, suspend fufther movement of fuel assemblies and crane operations with loads I

3/4-2 AMENDMENT NO. 120Amendment xxx Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS lAt I T-T TTT C(jT. A f1T'

s 1.l r UML b I UKA#ik 3,';i.l SPENT FUEL PQOL PARAI1E T ERS LN1M1TWl}G C-ONIDITIONS FOR OPERATION in or over the Spent Fuel Peel. and initiate ACTION to restore acceptable temperaturc. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months establish CONTAINMENT CLOSURE.

ii if the water quality specifications ofg.3l.e are exceeded, initiate corrective feasures to meet chemistry requirementS within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months and sample pool water at least onec a day until readings meet the requirements of 3.l.l.c. If water quality cannot be recovered aftec one *eek, prepare a special report that identifies the causes and proposed corrective action(s) to cnsure future water quality is in compliance and submit to the NRC by 3 1 days following entr) into the LGO.

iv. \'With the requirements of 3.1.l.d net met, I1MMEDIATELY provide an alternate method of monitoring Spent Fuel Peel radiation levels.

If the alternate instrumcntation does not have an audible alarm, locally and in the MONITORING STATION, r.adiation le.els shall be continuously monitr ed by personnel in communication with the MONITORDIG STATION, Ywhren personnel are in the vicinity of the Spent Fuel Peeol The provisions of Specification 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS 4.1.1I.a Twice per SHIFT, the uater level in the Spent Fuel Pool shall be determined to be at or above the elevation of 630'.

4.1. l.b T-wAice per SHIFT. Spent Fuel Pool water temperature shall be detemiined to meet the requirementsof Sperifiation 3.1.1 .b.

4.1.1.c Onee per 31 days.-Spent Fuel Pool water chemistri shall be determined to meet the reqireens of Specification 33.1.1 .e 3/4-3 AMENDMENT T NO. I -0Amendment xxx Date

Bi1G RO C§- PI DE I-N4GAL SPEC-FIGAT4ONS I 1A I FUEL STORAGE 3!1.1 1 SPFNT rFUjLPOOLfT PAPA-MrPTFRR SURVEILLA.NCE REQUIREMENTS

. ihe >6eent s!~ ~spceilication

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s .1..El Pucl pool radiation monitor required b' *~~~~

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demonstrated operable:

i. Daily by performing a CHGAKO EL CI ECK.

ii. Onee per 31 days by performinlg 1 - CHANNEL CALIBRATION.

I 3/4-4 A 4EENDDMENT NO. 12OAmendment xxx I Date I

341.1 FUEL STOR(AGE 3,1.'1.2 SPENT FUEL POOL SUPPORT SYSTEM REQUIREMEN4TS LIMITING CONDITIONS FOR OPERATION 3.1.2 The capability to supply malkcup to the Spent Fuel Pool shall be maintained as felles+Nr

a. A diesel generator capable ofproviding power within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months -t operate an onsite electric motor driven pump shall be available OR One offsite source of ae power capable of providing poever to operate an onsite electric motor driven pump shall be available, OR, An onsite pump not requiring eleetrical power shall be capable of providing maalieup wvater to the Spent Fuel Pool within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months .

b. The pump designated to satisfy the requirements of Specification 3.1.2.a shall be capable of supplying at least 28 gpm of water wvithin 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months at-a temperature equal to or less than 100 2F to the Spent Fuel Pool. The capability to manually initiate at least 2< gpm flow to the Spent Fuel Pool shall be maintained.

APPLICABILITY: When spent fuel is in the Spent Fuel Pool.

ACTION: With the requirements of Specifications 3.1.2.a or 3.1.2.b not met, within 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months establish an alternate souree of water capable of delivering at least 28 gpm of water at a temperature equal to or less than 100 OF to the Spent Fuel Peel.

The preo isiens ef Speeifieation 3.0.3 are not applieabile.

SURVEILLANCE REQUIREMENTS 1.2.2.a i. Daily, verify the presenee of potential on the offsite power- line.

ii. Once per 31 days, manually start the diesel generator and fun loaded for 30 minte uing an electrie moter- driven pump as a lead.

1.2.2.b i. Onee per 12 months, verify that the pumps satisfying the requirements of this specification are capable of supplying water within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and will deliver at least 22 gpm of water.

3/4-5 AM1EN!DM4EN1T NO. 120Amendment xxx Date

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311.1.2 SPENT FUEL POOL SUPPORT SYSTEM REQUIREME1ENTS SURVEILLANCE REQUIREMENTS ii.Onee per 12 months. Spent Fuel Pool malkeup shall be determined to be OPERABLE b. vcrify ing its floev capacity to be at least 28 gpm.

3/4-6 AMENDM4ENT NO. 12OAmendment xxx Date

BIG ROC44-ROINT DP-Ur_4,,r4,)--TKC-44N4 _cirjcAqpMwQ

,11~.1 FUEL STORAGE 14 .1.33 2:3 FUEL STORAGE GENERNAL REQUIREMENTS LAUITPlG CONDITIONS FOR OPERATION a14, The follewing limitati F) A S shall apply to the storg. of spent fuel in the Spent Fuel pk~b

a. Spen!a ful- assemb~tlies shall be rt1r^.d in fuel sterage raclis located in the Spent F-el Peo.

b. The storage of materials in the area directly between rack B and the east

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_______________ When spent fuel is in the Sp'ent Fuel Pool.

A A nO: With the requirements of Speifications 9.3.a or 3.1.b not met, suspend Spent Fuel Pool weor activities other than required surneillance activities and perfbr a prompt investigation to determine the cause and initiate appropriate corrective actions.

SURVEILLAANCE REQUIREMENTS 1.1 .3 a. At least semi annually and within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of completion of any activity involving movement of spent fuel in the Spent Fuel Pool, verify that the

-reur1ements of Specification 3.12.a have been met.

b. At least semi annually and within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of completion of an) activity involving- movement of components in the Spent Fuel Peol, verify that the requirements of Specification 3.1.3.b have been met.

3/4-7 AMENIDMENT NO. 12OAmendment xxx l Date I

14.2.1 FUEL HANDLING SUPPORT SYSTEMN4 REQUIREMENTS LIMNTING CONDITIONS FOR OPERATION0

3 1 i The follcwing cendi-i-ns apply when handling fuel insidr containment. 2-s , . .\ , .s . . n, ,

-Ar CFlnt I nmiant-Pon vv wvasuzal^A^^wsx; Antriticnn- 'r rnn-ninaq. ( 'i )N I A IN' A4FN

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I 'I( )N1 11<I-e v v s v E shall ehist and-containnment cntilation valves shall be closed or eespable-ef being lsed-.

r U. Kadiation levels shall be maintained below the alarm setting- requirements el Specification 2.1. l.d.

A.PPLICABflILITY: During FUEL HANDLING prations ACTION: i. With the requirements ef Specificatien ,21.2. .a not met, place fuel assemblies in a safe condition, and suspend IFUEL HANDLPIG activities inside cent-ainmnent.

ii. With the requirents ef Speeification 3.2.1 .b not met, initiate closure of containment ventilation inlet and exhaust valves and initiate corrective actions to reduce the radiation levels to aceep table

,values.

SURVEILLANCE REQUIREMENTS 4.2.1 a. Prior to commencement of FUEL HANDLING activities, perform verification of CONTAINMENT CLOSURE for all containment peneatins or opnings and verify OPERABILITY of containment ventilation valves (CY 1091, CV' 1095, CAI 1096, CVt 1097).

b. Verify that the radiation levels on the Spent Fuel Pool area radiation monitor are less than the alarr ef Speifieation 3.1H.l.d at least tweeerSIT 3/4-8 AMENDMENT NO. 4-0, 122 September 28, 2001

BIG40 . - - 4N4CAL -SPIP-C4-RGATIONS 31.2. FUEL HANDLING 3/1.42.2 FUEL HANDLING GENERAL REQUIREMNENTS LIMITING CONDITIONS FOR OPERAsTIoN 0 3.2.2 FUEL HANDLING operations shall contform to the following requirements:

a. Movenment e1 spent -ucl into and out et the storag!e racls or inspection

- - .. - - - -I- - 11 I - --

Ptatinnr, ,llall he reetr -icted to one assembly a4+a -Hme

b. Radiation levels at the south wall of the Spent Fuel Pol. _e levao 600'6".

shal! be maintained at less than 50 mnrthr-above the background lev l during FUEL HANDLING operations.

c. FUEL HANDLING shall be accomplished by manual guidance and visual observation of all FUEL HANEDLING operations.

d. Water shall be used as the basic shielding exeept when transfcrring spent fuel from the Spent Fuel Pool using the dry fuel storage system transfer

.^ _PL_r_ nrrIT__ Ahen hrAf dling fuel in thi Spent Fuel Pool.

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. .. i. XWith the requiremei 4-r- of Spec-ification 9.2.2.a net met, suspend FUEL HA.NDLPIG operations and place irradiated fuel assemblies in a safe condition. Conduct a prompt investigation to determine the eause and initiate appropriate c^rrective actions.

ii. With the requirements of Specification 3.2.2.b not met,

!MMEDIATTLY suspend FUEL HANDLING oper-ations, inhitiae action to restore radiation levels to less than 50 mr-em. above background levels and conduct a prompt investigation to determine thc cauise raiatinn AflncrrasH I vels.ITPI -UANV)l -- -. T.1 mav resume if it is determined that increased radiation Ievels have not been caused by the handling of fuel in the Spent Fuel Pool and radiation levels are verified to be within the required range.

iii. With the requirements of Specification 3.2.2.c net met, suspend once the requirements of 3.2.2.e have been r-e established.

iv. With the requirements of Specification 9.2.2.d not met, suspend FUEL HANDLING operations. FUEL HANDLING may resume onc-e the requirements of-3.2.2.d have been rne established.

3/4-9 AMENDMENT NO. 420,122 September 28, 2001

mG- To4-p-N T-D F -TGIINS AC.l Fs4CT-I4JNS 2/4.2 FUEL HANDLIMNG As1.2.2 FUEL HNDLPIG GENERAL REQUIREMN4NTS SURVEILLANiCE REQUIREmENYTS

b. Prior to commencing. once per SHIFT during and IWMEDIA4TELY upon completion of FUEL HAN4DLIN~G operations. monitor the radiation levels at the south wall of the Spcnt Fuel Pool, elevation 600'6", to verif:y that the reguirements of Specification 3.2.2.b arc met.

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3/4-10 AMENDMENT NO. 120

B lG4ZOCAl.' POINT4r-T-l r--D-T-r-lC4 l ONSCCAT Y14.- CONTROL- O HEAVY LOADS LIMITING CONDITIONS FOROPEROTION 3.3.1- (DELETED) I I

3/4-11 AMENDMENT NO. 120,122Amendmentxxxi Septc c2 ,2 Date I

BIG4ZQC4<--P4-0l T-r-GI1NT A m A-T4oNs 3/14.3 CONTROL OF 14E4AXY LOADS SURVEILLANCE-REQUIREMENTS 1.3.1 (DELETED) I I

3/4-12AMENDMENT NO. 120, 122Amendment xxxi Sctember8, 001DateI

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 3/4.41 SEALED SOURCE CONTAMINATION LIMITING CONDITIONS FOR OPERATION 3.4.1 Each sealed source containing more than 100 microcuries of beta and/or gamma emitting material, or more than 5 microcuries of alpha emitting material shall not have removable contamination which equals or exceeds 0.005 microcuries.

APPLICABILITY: At all times.

ACTION: 1. Each sealed source with removable contamination in excess of the above limits shall be IMMEDIATELY withdrawn from use and either decontaminated and repaired, or disposed of in accordance with NRC regulations.

a. A special report shall be submitted to the NRC as indicated by Specification 6.7.4.b.

SURVEILLANCE REQUIREMENTS 4.4.1 Except for: 1) sealed sources which are stored and not in use, and 2) start up sources and fission detectors previously subjected to core neutron flux, sealed sources containing radioactive materials in any form other than gas and with a half-life greater than 30 days (excluding 1H 3) shall be tested for contamination and/or leakage at least once per six months by the licensee or other person specifically authorized by the NRC or an Agreement State to perform such services.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. The test sample shall be taken from the sealed source or from the surfaces of the device in which the sealed source is permanently mounted or stored, on which one might expect contamination to accumulate. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the NRC.

a. Sealed sources requiring testing by this section, but exempted on the basis of not being in use, shall have been tested within 6 months prior to being transferred or put into use.

3/4-13 A.ENDMENT NO. 120Amendment 120 December 24, 1998

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 5.0 DESIGN FEATURES 5.1 SITE 5.1.1 LOCATION AND BOUNDARIES The plant site is located in Charlevoix County, Michigan, about 4 miles northeast of Charlevoix, Michigan, and about II miles west of Petoskey, Michigan.

5.2 STOR4AGE ANSD INSPECTION OF SPENiT FUEL Atpplfieabilitv: The desien feattlres specificd, inl sceeiin 5.2 applv enl vwhen irradiaied fuel is stor-ed in the Spent Fuel Pool.-

5.2.1 CRIT]CALITY Spent fuel is stored in spent fuel storage racks which are designed and shall be maintained with sufficient center to center distance betwveen stored fuel assemblies to ensure a -k less than or equal to 0.95 when the raclks are flooded with unborated-water.

The fuel loading per- axial centimeter of an) assembl) placed in the Spent Fuel Pool shall be less than or equal to a maximum of 28.3 grams of Um ef

equivn~

Fuel inspection -stations, if installed, shall be designed and maintained Wvith sufficient centierto center distane between fuel assemblies placed in the inspection stations to ensure a -k less than cr equal to 0.95 when flooded with unborated water.

.WATER LE.'EL The Spent Fuel Pool is designed to maintain a normal water level between 630' and 632'6".

5.2.3 COOLING Theeenfigur-ation of storage racks placed in the Spent Fuel Pool allows for adequate circulation of water to prevent localized pool boiling.

Amendment 14-xxx September 1 1, 2002Date 5-1

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 5.0 DESIGN FEATURES Figture 5.1 1, BRP Site Map I

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-1 II Amendment 120, lPlxxx l January- 13, 2000Date I 5-2

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 5.0 DESIGN FEATURES 5.2.1 CAPACITY Subject to the limits listed below. the fuel pool is designed for and shall-be maintained with a storage capacity of no more than 411 fuel assemblies.-In addition, fuel pins which have beeni removed from fuel assemblies shall be stored in the Spent Fuel Pool and shall be in a gcometr-y whichl ensures suberiticalitv.

The following limits apply to the anmount of special nuelear material which may be stored in the Spent Fuel Pool:

22500 kilograms cf contained uranium 235.

10.32 grams of uranium 235 as contained in fission counters.

LI 150 kilograms of plutonium ccntained in PuO-UO2 fuiel reds.

S5 curics of plutonium encapsulated as a plutonium bery5llium source.

5.3 REACTOR The reactor is not licensed for pewef eper-ation. Fuel shall not be placed in the reaetor -vessc.

5-3 AMENDMENT NO. 12-0, Amendmient xxx Date I

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY AND AUTHORITY 6.1.1 SENIOR NUCLEAR OFFICER The Senior Nuclear Officer shall be the Senior Vice President - Nuclear, Fossil, and Hydro Operations and shall be responsible for the overall operation, maintenance and decommissioning of the Big Rock Point nuclear power plant.

6.1.2 SITE GENERAL MANAGER The Site General Manager shall be responsible for overall facility operation, maintenance and deco-mnisssioningdecommissioning and for periods of absence shall l delegate in writing the succession to this responsibility. Unless otherwise specified, the Site General Manager's delegate has authority to perform all actions and grant approvals assigned by these specifications to the Site General Manager. The Site General Manager may delegate specific tasks to other individuals who may perform those tasks whether the Site General Manager is absent or present at the site.

6.1.3 SHIFT SUPERVISOR The Shift Superviseor shall be responsible for the shift command -funioen.This position .vill be filled by a Certified Fuel Handler.

6.2 ORGANIZATION 6.2.1 REPORTING RELATIONSHIPS Onsite organization and corporate reporting relationship shall be established for activities affeeting safety of the facilityas described in the "Quality Program Description for Nuclear Power Plants, Part I - Big Rock Point (CPC-2A)".

a. Lines of authority. responsibility and eemmunieation shall be s ished and documented in facility administrative procedures.

b. The Site General Manager shall be responsible for safe operation of the facility and shall have control over those onsite activities necessary fo safe operation and maintenance of the facility. The individual filling this position shall report directly' to the Senior Nuclear Officer.

c. The individuals who perform audits, sufveillanees and independent 6-1 A41ENDME-NNT ]2OAmendment xxx Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS

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satety reviews report to the Manager, Nuclear l'ertorianee Assessment Depafrnie

d. ThPe individuals' who train thc Certified Fuel Handlers and thosc wvho carry out-radiation protection funections report to the appropriate onsite nmanager; hovwever, they shall have sufficient organizational freedom to enSUre tneir independence !From operaung A----

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6.2.2 FACILITY ORGANIZATION The Site General Manager or his designate shall verifv that required security staffing and Dry Fuel Storage Technical Specifications have been met. The faeility erganization shall be subject to the following:

a. Each on duty shift shall be comprised of at least the minimum shift crew composition shown in Table 6.2 1.

b. At least one individual, vho shall be qualified to stand watch in the MONITORING STATION, shall be in the 4O0N1iTORING STATION w^hen irradiated fuel is in the Spent Fuel Pool.

c.- During operations wit lel,it 11 I i W~AN WkiNti P iher-$hp NW!IVI

- I Supervisor or the Non Certified Operator shall be qualified in radiation tll U_ __

protection procedures; or a Radiation P site. During FUEL tpercHANDLING ations a qualified Radiation Pro-etetion Technician shall be on site

d. When spent fuel is -tored in the Spent Fuel Pool or during FUEL HANDLING operations, administrati-vze procedures shall be mentca to-llmlt the xvorlvlnt -llouro ;f the facility staff-w-h-A perfonm safety related functions, and activities important to the safe steageA sentfol (ISeS^T) rof ^an the meniter-ing and eentre}-Ao4 radiological hazards (IMC1RH). These individuals include the minimum SHIFT crew required by Table 6.2 1, key maintenanee personnel and Radiation Protection Technicians.

,4dequatc SHIF-T-co erage shall be maintained wvithout routine hea"y us ce ovenilmc. HoeWcver, in fic eVenlt tina uniUresetn prUoiems

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require substantial amounts of overtime to be used, the following guidelines shall be followed:

(1) An individual should not be permitted to work more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, exeluding SHIFT turnover time.

6-2 AM1ENT DM1ENT NO. 120Amendment xxx Date I

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS.

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-J J - s-llvvaa - - De D-nl~e 16 hoers in an 241 houlr period., nor more than 21 hours2.430556e-4 days 0.00583 hours 3.472222e-5 weeks 7.9905e-6 months in any 48 heur Period. nor m ore than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day prio.

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T t At least X hnior-should be allowed after continuous worlk periods of 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months dufatien.

Any deviation from the above guidelincs shall be authorized by thc Sitc General Manager or designated alternates in aeecordanec with cstablished adminitrativc procedures and with documentaien f the basis for granting the deviatn.

Administr-ative procedur-es shall include a requirement for-the Site General Manager or designated alternates to review individual ovcrtimc on a monthly basis in orderf to e fy that efmessive hours have not been assigned. Routine deviations TABLE 6.2 1: MWNIMUM SHIFT CREW COMIPOSITION DURING PERMANENTLY DEFUELED CONDITION STAFFING FOR S GA4-NG OPERA.TIONS DURING FUEL POSITON AI HA1DING FUEL HANDLING OPE;RA.TIONS SHIFT Super.'isor (CERTIFIED FUEL HANDLER) 4- 4 Neon Cerificd Operatef 3- 4-CERTIFIED FUEL HAkNDLER -I Radiation Protection Technician .

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.rt spons1iai.ues ourin- itseper-ation. GER IPIL* VUL HANDLERS shall meet qualifications set forth in theCGERTFIED FUEL 13AND rR -TrininoPr~orimm 6-3 AMENDMNENT NO. -l2OAmendment xxx Date I

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS

f. The SHIFT Supervisor shall be a CERTIFIED FUEL HANDLER.

g. The SHI4FT Supervisor shall report to an individual .vlho is CERTIFIED FUEL HANDLER.

h. Personnl reauirmcnnts of (an)nndi (c) above may hp less than the-minimum specified for a period of time. not to exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in order to accommodate unexpected absence of on duty personnel provided immnediate ACTION is !aiken to restore the minimum re irements specified. This proevision only applies to on SHIFT personnel and dees not permit an' SHIFT crew position to be unmanned upon SHIFT chance due to oncoming SHIFT crew member being late or absent.

6.3 STAFF QUALIFICATIONS Each member of the facility management and supervisory staff shall meet the minimum requirements of ANSI N18.1-1971 for comparable positions. The individual responsible for radiation protection functions shall meet the minimum requirements of Regulatory Guide 1.8, September 1975.1 6.1 TPc412!ThG A training program for the facility's CERTIFIED FUEL HANIDLERs shall meet the requirements and recomnmendations of Section 5.5 of ANSI N 18.1 1971.

The Site General Manager has overall responsibility for implementation and maintenance of the traininl nreoram.

6.A4 REVIEW AND AUDIT l 6.t4.1 Requirements for onsite and offsite reviews and audits are described in I CPC-2A, Quality Program Description.

As applied to this specification, "equivalent," as used in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following: (a) formal training in science engineering or (b) operational or technical experience and training in nuclear power.

64 AM4ENDMENT NO. 120Amendment xxx Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.65 PROCEDURES AND PROGRAMS I 6.65.1 PROCEDURES I 6.65.1.1 Scope I Written procedures shall be established, implemented and maintained for safetyquality related structures, systems components and safety actionsactivities defined in the Big Rock Point Decommissioning Quality List and those structures, systems, components and activities important te the safe storage of spent fuel (ISSSF) and monitoring and control of radiological hazards (IMCRH). These procedures-shall meet or exceed the requirements of ANSI NI 8.7 1976, as endefsed-described by the Quality Program Description (CPC-2A).

Written procedures shall also be established, implemented, and maintained covering the following activities:

a. DefuieledISFSI Security Plan;

b. Defueled-Emergency Plan;

c. Fire Protection Plan; ed. Quality Program Description (CPC-2A); and, de. All programs listed in Specification 6.6.2.Radiation Protection Program.

6.65.1.2 Review and Approval I Requirements for review and approval of procedures (and revisions thereto) required by this section are described in CPC-2A, Quality Program Description.

6.65.1.3 Temporary Changes I Requirements for making temporary changes to procedures which fall within the scope of this section are described in CPC-2A, Quality Program Description.

6-5 AMIEN!DM4ENIT NO. 12OAmendment xxx Date I

BIG 1ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.65.2 PROGRAMS The following programs sh&4-behas been established, implemented and maintained in accordance with written procedures meeting the requirements contained in Specification 6.65.1:

6.65.2.1 Radiation Protection Propraml Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6.65.2.21.1 High Radiation Area 6.65.2.21.1.1 Dose Rates less than or equal to 1000 Millirem per Hour In lieu of the "control device" or "alarm signal" required by Paragraph 20.1601 (a) of 10 CFR Part 20, each high radiation area in which the intensity of radiation is greater than 100 mrem/hr but less than or equal to 1000 mrem/hr at 30 cm (12 inches) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by the use of a Radiation Work Permit (RWP). Radiation protection qualified personnel or personnel continuously escorted by radiation protection qualified personnel may be exempt from working under an RWP during the performance of their assigned radiation protection duties in high radiation areas with exposure rates of less than or equal to 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area, or

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas may be made after the dose rate levels in the area have been established and personnel have been made knowledgeable of them, or

c. A radiation protection qualified individual (e.g., Radiation Protection Technician) with a radiation dose rate monitoring device, responsiblel 6-6 AMENDMENT NO. 120Amendment xxx Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS for providing positive control over the activities within the area.

6.65.2.21.1.2 Dose Rates greater than 1000 Millirem per Hour In addition to the requirements of 6.65.2.2 1.1.1, areas accessible to personnel with radiation levels greater than 1000 mrem/hr at 30 cm (12 inches) but less than 500 rad/hr at I meter from the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under administrative controls specified in the facility administrative procedures. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of a stay time specification, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

For individual high radiation areas accessible to personnel with radiation levels greater than 1000 mrem/hr that are located within large areas where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

6.6.2.3 -Preeess Control Pregfam-WIQ41) 6.6.2.3.1 Changes to the PCP Changes to-the PCP shall become effective after approval by the Site General Managef, 6.6.2.3.2 Repei4s Changes to the PCP shall be submitted to the Commission in the Radioactive Effluent Relcase Report for the period in w.hich the changes were made effective. This submittal shall contain sufficiently detailed information to support the rationale for each change and a determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid vastes.

6-7 AM1ENIDM1ENT NO. 12Amendment xxx Date I

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.6.2.4 Offsite Dose Calculation Manual (ODCM) 6.6.2.4.1 Changes to the ODCM Changes to the ODCM shall become effective after approval by the Site General Manager.

6.6.2.4.2 Reports Changes to the ODCM shall be submitted to the Commission in the Radioactive Effluent Release Report for the period in which the changes were made effective. This submittal shall contain sufficiently detailed information to support the rationale for each change and a determination that the change did not reduce the accuracy or reliability of dose calculations or setpoint determinations.

6.6.2.5 Radioactive Effluent Controls Program A program, conforming with 10 CFR 50.36a, for the control of radioactive effluents and for maintaining doses from radioactive effluents to members of the public as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by facility procedures, and (3) shall include remedial actions to be taken whenever program limits are exceeded. The program shall include the following elements:

a. Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

b. Limitations conforming to 10 times the concentration values specified in Appendix B, Table 2, Column 2, to 10 CFR 20.1001 - 20.2402 for the radioactive material release in liquid effluents to unrestricted areas.

c. Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d. Limitations conforming to Appendix I to 10 CFR Part 50 on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from the facility to unrestricted areas; Amendment 120,I ~1 January 13,2000

-~~~~~~~~~~ 610

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS

e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;

f. Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31 -day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50.

g. The dose rate due to radioactive materials released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the following:

(a) For noble gases: Less than or equal to 500 mrems/yr to the total body and less than or equal to 3000 mrems/yr to the skin, and (b) For tritium and for all radionuclides in particulate form with half lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.

h. Limitations conforming to Appendix I to 10 CFR Part 50 on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the facility to areas beyond the site boundary; and

i. Limitations conforming to 40 CFR Part 190 on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources.

j. The dose to a member of the public from tritium and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents released to areas at or beyond the site boundary shall be limited to the following:

(a) During any calender quarter: Less than or equal to 7.5 mrems to any organ, and (b) During any calender year: Less than or equal to 15 mrems to any organ.

-Amendment 120, 121 January- 13,2000 4 IA

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.6.2.6 Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the facility. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

a. Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM;

b. A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and that modifications to the monitoring program are made if required by the results of this census, or alternatively, that critical receptors are assumed to exist at the site boundary or offsite location of highest dose consequence; and

c. Participation in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

6.6.2.7 Fire Protection Profram A fire rteion program meeting the requirements of 10 CFvR 50.48(f) shall be g~~~estabrs Pr ntain aitot^ d-This program pro ides administratie cont t rthat arpriate measures are implemented and maintained during cold weather to protect the facilit against cold tempe-rawres which could impact the safe stg runeot irradiated fuel or result in unplanned or unmonitored radioactive material Fekease-6, -'w 611 AMENDMENT O. 120121 September 11, 2002

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS r ra n1 c_ .t r. n_

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v .era This program uses proeedures to provide cow trols for monitoring Spent Fuel Pool water chemistry. The Spent Fuel Pool Nk'ater ChemistrFy Program shall be established, implemented. and m~aintained whhenever irradiated fuel is stored in the Spent Fuel DPeAA 6.6.2.10 lnsr.Aicc Incnectinn and Tpctin- mrmarnm

a. Applieabjiity.

Applies o ,nser~iee inspection and T-esting., of ASME Code Class 1.

Class 2 and Class 3 piping systems and components.

b. Objuetie Teinsufe^l finterity efthe Class 1, Clas 2anddClass 3 pipng sys~tems and components.

e. Specifleations

1. inservie inspection of ASME Code Class 1, and 3 components and inseri.ie Testing ofASME Code Class 1, 2 and 3 pumps and valves shall be performed in accor-dance with Section Xi of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFPR 50, Section 50.55a(g), emcept where specific vNitten relief has been granted hv thp ($Anirion nurr1uant to 10 CF'R 50 Sretion

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4.1.5 and 11.4.3.1 take precedence.

2. Sufficient records of each inspection shall be hept to allow comparison and evaluation of futurc tests.

3. The inse-viee inspection pr6gr-am shall be reevaluated as

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6-11 AM*ENDME*T- NO. .2-Amendment xxx September 11, 2002Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.46 REPORTING REQUIREMENTS The reports identified in this section shall be submitted in accordance with 10 CFR 50.4.

6.46.1 ANNUAL OCCUPATIONAL RADIATION EXPOSURE REPORT An annual report of radiation exposures received during the previous calendar year shall be submitted prior to March 1 of each year. This report shall tabulate the numbers of facility, utility and other personnel (including contractors) receiving exposures greater than 100 millirem during the year, along with their associated dose according to work and job functions, for example, operations and surveillance, routine maintenance, special maintenance (identify), and waste processing. The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD or film badge measurements. Small exposures totaling less than 20 percent of the individual total dose need not be accounted for. In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.

6.76.2 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT An annual radiological environmental operating report covering operation of the facility during the previous calendar year shall be submitted prior to May 1 of each year. The report shall include summaries, interpretations, and statistical evaluation of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the ODCM and Sections IV.B.2, IV.B.3 and IV.C of Appendix I to 10 CFR 50.

6.76.3 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT An annual radioactive effluent release report covering operation of the facility during the previous calendar year shall be submitted prior to May I of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outlined in the ODCM and the PROCESS CONTROL PROGRAM, and shall comply with the requirements of 10 CFR 50.36a and Section IV.1B.1 of Appendix I to 10 CFR Part 50.

6-12 AXMENDM4ENT lO. 120Amendment xxx Date

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.76.4 SPECIAL REPORTS I The following special reports shall be submitted to the NRC as indicated.

a. If the water quality specifications of 3.1.1.c are exceeded, and the wvater quality cannot be recovered afer one .. eek, prepare a special report tlat identifies the causes and proposed eorr-cctive action(s) to ensure future watef quality is in compliance and submit to the NRC by

.1 days fol.lwine intoe the LCO.

b. If the sealed source contamination limits of Specification 3.4.1 are exceeded, a special report shall be submitted to the NRC within 30 days of identification of the existence of the excessive contamination. The report shall describe the equipment involved, the test results and corrective actions taken.

c. Inser.icc Inspection reports quired by 10 CFR 50.55a and Sedtion Xi fireP

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6.87 RECORDS I Record retention requirements are described in CPC-2A, Quality Program Description.

6.98 REPORTABLE EVENTS I A reportable event is any event or condition that must be reported to the NRC in accordance with 10 CFR 50.72, 10 CFR 50.73, or 10 CFR 50.9(b).

6-13 AMENDM1ENrTNO. 120Amendment xxx Date l

Attachment 4 Consumers Energy BIG ROCK POINT Docket Numbers 50-155 and 72-043 Replacement Pages FACILITY OPERTING LICENSE AND DEFUELED TECHNICAL SPECIFICATIONS (Originally submitted as Attachment 5 to August 6, 2003 Correspondence)

Revisions are Marked by a Double Line in the Right Margin December 1, 2003 22 Pages

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, DC 20555 CONSUMERS ENERGY COMPANY DOCKET NO 50-155 BIG ROCK POINT PLANT FACILITY OPERATING LICENSE License No DPR-6

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Consumers Power Company (renamed Consumers Energy Company by Amendment No. 119, the licensee) dated January 13, 1975, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. Construction of the Big Rock Point Plant (the facility) has been substantially completed in conformity with Construction Permit No. CPPR-9 and the application, as amended, the provisions of the Act and the rules and regulations of the Commission; C. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; D. There is reasonable assurance: (i) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the rules and regulations of the Commission; E. The licensee is technically and financially qualified to engage in the activities authorized by this operating license in accordance with the rules and regulations of the Commission; F. The licensee has satisfied the applicable provisions of 10 CFR Part 140, "Financial Protection Requirements and Indemnity Agreements," of the Commission's regulations; G. The issuance of this operating license will not be inimical to the common defense and security or to the health and safety of the public; and Big Rock Point Amendment XXX DATE

H. The receipt, possession, and use of source, byproduct and special nuclear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30,40, and 70, including 10 CFR Sections 30.33, 40.32, and 70.23 and 70.31.

2. Facility Operating License No. DPR-6, issued to the Consumers Energy Company, is hereby amended in its entirety to read as follows:

A. This license applies to the Big Rock Point Plant (the facility) owned by Consumers Energy Company (the licensee). The facility is located in Charlevoix County, Michigan, and is described in the licensee's application dated January 14, 1960, and the Final Hazards Summary Report, as supplemented, updated, and amended by subsequent filings by the licensee.

B. Subject to the conditions and requirements incorporated herein, the Commission hereby licenses Consumers Energy Company:

B.(l) Pursuant to Section 104b of the Act and 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities" to possess the facility at the designated location in Charlevoix County, Michigan, in accordance with the procedures and limitations set forth in this license; B.(2) Pursuant to the Act and 10 CFR Part 70, "Domestic Licensing of Special Nuclear Material," to possess at any one time up to (a) 2500 kilograms of contained uranium 235 in fuel rods, (b) 10.32 grams of uranium 235 as contained in fission counters, (c) 150 kilograms of plutonium contained in PuO2-U0 2 fuel rods, and (d) 5 curies of plutonium encapsulated as a plutonium-beryllium neutron source; (a) Deleted (b) Deleted (c) Deleted (d) Deleted (e) Deleted (f) Deleted (g) Deleted (3) Pursuant to the Act and 10 CFR Part 30, "Rules of General Applicability to Domestic Licensing of By-product Material," to receive, possess and use at any one time up to 7000 curies of antimony-beryllium in the form of neutron sources, 3.7 curies of colbalt-60 as sealed sources, 45 curies of cesium-137 as sealed sources, 10 microcurie6 of miscellaneous alpha emitting material as sealed sources, and up to 500 millicuries per nuclide of any byproduct material between atomic numbers I and 83, inclusive, without restriction as to chemical and physical form; Big Rock Point Amendment No. 120 Dec. 24, 1998

2.B.(4) Pursuant to the Act and 10 CFR Part 40, "Domestic Licensing of Source Material," to possess at any one time up to 500 kilograms of depleted uranium dioxide contained in the facility's fuel assemblies; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such by product and special nuclear materials as may be produced by the operation of the facility.

C. This license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

C.(l) Reactor Operation The reactor is not licensed for power operation. Fuel shall not be placed in the reactor vessel.

C.(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No., xxx are hereby incorporated in the license. The licensee shall maintain the facility in accordance with the Technical Specifications.

C.(3) Physical Protection The licensee shall fully implement and maintain in effect all provision of the physical security, guard training and qualification, and safeguards contingency plans approved by the Commission and all amendments and revisions to such plans made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p), as modified by NRC-approved exemptions. The plan, which contains Safeguards information protected under 10 CFR 73.21, is entitled: "Big Rock Point ISFSI Security Plan" Changes made in accordance with 10 CFR 73.55 shall be implemented in accordance with the schedule set forth therein.

2.C.(4) Deleted 2.C.(5) Deleted 2.C.(6) Deleted 2.C.(7) Deleted Big Rock Point Amendment No. xxx DATE

D. The license amendment is effective as of the date of its issuance and shall be implemented within 45 days of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Signature Name TITLE

Attachment:

Change No. xxx to the Technical Specifications Date of Issuance: DATE

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BIG ROCK POINT tRSTORATION PROJECT-S I- .... .l a e DEFUELE.-D TECH . -- CL-.'-. ECIFICATIN

. i.n Amendment XXX Date

DEFUELED TECHNICAL SPECIFICATIONS FOR BIG ROCK POINT PLANT DOCKET 50-155 LIST OF EFFECTIVE PAGES as of AMENDMENT XXX DATE AMENDMENT REVISION DESCRIPTION NUMBER DATE LICEN SE - Page 1 .................................................................... XXX DATE LICEN SE - Page 2 .................................................................... 120 12/24/1998 LICENSE - Page 3 .................................................................... 'ocx DATE LICENSE - Page 4 .................................................................... xxx DATE Table of Contents (3 Pages) ...................................................... xxx DATE Section I - DEFINITIONS Page 1-1 .................................................................................... XXX DATE Section 2 - SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS Page 2-1 .......................................... 120 12/24/1998 Section 3 & 4 - LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS Page 3/4-1 .......................................... XXX DATE Page 3/4-2 .......................................... XXX DATE Section 5 - DESIGN FEATURES Page 5-1 .................................................................................... DATE Section 6 - ADMINISTRATIVE CONTROLS Page 6-1 ...... )OO( DATE Page 6-2 ...... xxx DATE Page 6-3..................................................................................... XXX DATE Page 6-4..................................................................................... XXX DATE Page 6-5..................................................................................... XXX DATE Page 6-6..................................................................................... )OO( DATE BASES ...................................................................................... N/A (Pages B3/4-1 through B 3/4-3)

Amendment XXX Date Page 1 of I

TABLE OF CONTENTS DEFUELED TECHNICAL SPECIFICATIONS FOR BIG ROCK POINT PLANT SECTION DESCRIPTION PAGE 1.0 DEFINITIONS ................................................ 1-1 1.1 ACTION ................................................ 1-1 1.2 CHANNEL CALIBRATION ................................................ 1-1 1.3 CHANNEL CHECK ................................................ 1-1 1.4 CHANNEL FUNCTIONAL TEST ................................................ 1-1 1.5 IMMEDIATELY ................................................ 1-1 1.6 REPORTABLE EVENT ................................................ 1-1 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS ................ .......... 2-1 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS...........................................3............................................................. 3/4-1 3/4.0 APPLICABILITY ................ 3/4-1 3/4.1 SEALED SOURCE CONTAMINATION ................ 3/4-2 5.0 DESIGN FEATURES ................ 5-1 5.1 SITE ................ 5-1 5.1.1 Location and Boundaries ................ 5-1 6.0 ADMINISTRATIVE CONTROLS ................ 6-1 6.1 RESPONSIBILITY AND AUTHORITY ................ 6-1 6.1.1 Senior Nuclear Officer............................................................................. 6-1 6.1.2 Site General Manager ................ 6-1 6.2 ORGANIZATION ................ 6-1 6.2.1 Reporting Relationships ................ 6-1 6.2.2 Facility Organization ................ 6-1 6.3 STAFF QUALIFICATIONS ................ 6-2 6.4 REVIEW AND AUDIT ................ 6-2 6.5 PROCEDURES AND PROGRAMS ................ 6-3 6.5.1 Procedures ................ 6-3 6.5.2 Programs ................ 6-3 6.5.2.1 Radiation Protection Program ................ 6-3 6.6 REPORTING REQUIREMENTS ................ 6-5 6.6.1 Annual Occupational Radiation Exposure Report .6-5 Amendment XXX Date i

TABLE OF CONTENTS DEFUELED TECHNICAL SPECIFICATIONS BIG ROCK POINT PLANT SECTION DESCRIPTION PAGE 6.6.2 Annual Radiological Environmental Operating Report ........................... 6-5 6.6.3 Annual Radioactive Effluent Release Report .......................................... 6-6 6.6.4 Special Reports .......................................... 6-6 6.7 RECORDS .......................................... 6-6 6.8 REPORTABLE EVENTS .......................................... 6-6 Amendment XXX Date ii

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 1.0 DEFINITIONS 1.1 ACTION ACTION shall be that part of a specification which prescribes remedial measures required under designated conditions.

1.2 CHANNEL CALIBRATION A CHANNEL CALIBRATION is the adjustment as necessary, of the channel output such that the channel responds with the necessary range and accuracy to known values of the parameter which the channel monitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and includes the CHANNEL FUNCTIONAL TEST.

The CHANNEL CALIBRATION may be performed by any series of sequential, overlapping, or total channel steps such that the entire channel is calibrated.

1.3 CHANNEL CHECK A CHANNEL CHECK is the qualitative assessment of channel behavior during operation by observation. This assessment shall include, where possible comparison of the channel indication and/or status with other indications and/or status derived from independent instrumentation channels measurifig the same parameter.

1.4 CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST is the injection of a simulated signal into the channel as close to the sensor as practicable to verify performance, including alarm and trip functions.

1.5 IMMEDIATELY When "IMMEDIATELY" is used as a completion time for a required ACTION, the ACTION should be pursued without delay and in a controlled manner.

1.6 REPORTABLE EVENT A REPORTABLE EVENT is any of those conditions specified as reportable in Specification 6.8.

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BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 2.0 SAFETY LIMITS AND LIMITING SAFETY SYSTEM SETTINGS There are no safety limits or limiting safety system settings applicable to the permanently defueled condition.

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BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4.0 APPLICABILITY LIMITING CONDITIONS FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding specifications is required during the conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Condition for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 Unless otherwise specified, entry into an applicability condition shall not be made unless the conditions of the associated Limiting Condition for Operation are met without reliance on provisions contained in the ACTION statements.

SURVEILLANCE REQUIREMENTS 4.0.1 Unless specified otherwise, Surveillance Requirements shall be applicable during the specified applicable conditions for the associated Limiting Conditions for Operation.

4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

4.0.3 Unless specified otherwise, performance of a Surveillance Requirement within the specified time interval including the maximum allowable extension shall constitute compliance with associated ACTION statements.

4.0.4 Unless specified otherwise, entry into a specified applicable condition shall not be made unless the Surveillance Requirements associated with the Limiting Condition for Operation have been performed within the stated surveillance interval including the maximum allowable extension.

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BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 3/4.1 SEALED SOURCE CONTAMINATION LIMITING CONDITIONS FOR OPERATION 3.4.1 Each sealed source containing more than 100 microcuries of beta and/or gamma emitting material, or more than 5 microcuries of alpha emitting material shall not have removable contamination which equals or exceeds 0.005 microcuries.

APPLICABILITY: At all times.

ACTION: 1. Each sealed source with removable contamination in excess of the above limits shall be IMMEDIATELY withdrawn from use and either decontaminated and repaired, or disposed of in accordance with NRC regulations.

a. A special report shall be submitted to the NRC as indicated by Specification 6.6.4.a.

SURVEILLANCE REQUIREMENTS 4.4.1 Except for: 1)sealed sources which are stored and not in use, and 2) start up sources and fission detectors previously subjected to core neutron flux, sealed sources containing radioactive materials in any form other than gas and with a half-life greater than 30 days (excluding 1H ) shall be tested for contamination and/or leakage at least once per six months by the licensee or other person specifically authorized by the NRC or an Agreement State to perform such services.

The test method shall have a detection sensitivity of at least 0.005 microcuries per test sample. The test sample shall be taken from the sealed source or from the surfaces of the device in which the sealed source is permanently mounted or stored, on which one might expect contamination to accumulate. Records of leak test results shall be kept in units of microcuries and maintained for inspection by the NRC.

a. Sealed sources requiring testing by this section, but exempted on the basis of not being in use, shall have been tested within 6 months prior to being transferred or put into use.

3/4-2

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 5.0 DESIGN FEATURES 5.1 SITE 5.1.1 LOCATION AND BOUNDARIES The plant site is located in Charlevoix County, Michigan, about 4 miles northeast of Charlevoix, Michigan, and about 11 miles west of Petoskey, Michigan.

5-1

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY AND AUTHORITY 6.1.1 SENIOR NUCLEAR OFFICER The Senior Nuclear Officer shall be the Senior Vice President - Nuclear, Fossil, and Hydro Operations and shall be responsible for the overall operation, maintenance and decommissioning of the Big Rock Point nuclear power plant.

6.1.2 SITE GENERAL MANAGER The Site General Manager shall be responsible for overall facility operation, maintenance and decommisssioning and for periods of absence shall delegate in writing the succession to this responsibility. Unless otherwise specified, the Site General Manager's delegate has authority to perform all actions and grant approvals assigned by these specifications to the Site General Manager. The Site General Manager may delegate specific tasks to other individuals who may perform those tasks whether the Site General Manager is absent or present at the site.

6.2 ORGANIZATION 6.2.1 REPORTING RELATIONSHIPS Onsite organization and corporate reporting relationship shall be established as described in the Quality Program Description for Nuclear Power Plants Part I - Big Rock Point (CPC-2A).

6.2.2 FACILITY ORGANIZATION The Site General Manager or his designate shall verify that required security staffing and Dry Fuel Storage Technical Specification surveillance(s) have been met.

6-1

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.3 STAFF QUALIFICATIONS Each member of the facility management and supervisory staff shall meet the minimum requirements of ANSI N18.1-1971 for comparable positions. The individual responsible for radiation protection functions shall meet the minimum requirements of Regulatory Guide 1.8, September 1975.1 6.4 REVIEW AND AUDIT Requirements for onsite and offsite reviews and audits are described in the Quality Program Description for Nuclear Power Plants Part 1- Big Rock Point (CPC-2A).

As applied to this specification, "equivalent," as used in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following: (a) formal training in science engineering or (b) operational or technical experience and training in nuclear power.

6-2

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.5 PROCEDURES AND PROGRAMS 6.5.1 PROCEDURES 6.5.1.1 Scope Written procedures shall be established, implemented and maintained for quality related activities defined in the Big Rock Point Decommissioning Quality List and shall meet or exceed the requirements described by the Quality Program Description (CPC-2A).

Written procedures shall also be established, implemented, and maintained covering the following activities:

a. ISFSI Security Plan;

b. Emergency Plan;

c. Fire Proteciion Plan;

d. Quality Program Description (CPC-2A); and

e. Radiation Protection Program.

6.5.1.2 Review and Approval Requirements for review and approval of procedures (and revisions thereto) required by this section are described in CPC-2A, Quality Program Description.

6.5.1.3 Temporary Changes Requirements for making temporary changes to procedures which fall within the scope of this section are described in CPC-2A, Quality Program Description.

6.5.2 PROGRAMS The following programs shall be established, implemented and maintained in accordance with written procedures meeting the requirements contained in Specification 6.5.1.

6.5.2.1 Radiation Protection Program Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

6-3

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.5.2.1.1 High Radiation Area 6.5.2.1.1.1 Dose Rates less than or equal to 1000 Millirem per Hour In lieu of the "control device" or "alarm signal" required by Paragraph 20.1601(a) of 10 CFR Part 20, each high radiation area in which the intensity of radiation is greater than 100 mremlhr but less than or equal to 1000 mremnlhr at 30 cm (12 inches) from the radiation source or from any surface which the radiation penetrates shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by the use of a Radiation Work Permit (RWP). Radiation protection qualified personnel or personnel continuously escorted by radiation protection qualified personnel may be exempt from working under an RWP during the performance of their assigned radiation protection duties in high radiation areas with exposure rates of less than or equal to 1000 mrem/hr, provided they are otherwise following facility radiation protection procedures for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area, or

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas may be made afier the dose rate levels in the area have been established and personnel have been made knowledgeable of them, or

c. A radiation protection qualified individual (e.g., Radiation Protection Technician) with a radiation dose rate monitoring device, responsible or providing positive control over the activities within the area.

6.5.2.1.1.2 Dose Rates greater than 1000 Millirem per Hour In addition to the requirements of 6.5.2.1.1.1, areas accessible to personnel with radiation levels greater than 1000 mrem/hr at 30 cm (12 inches) but less than 500 rad/hr at I meter from the radiation source or from any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be maintained under administrative controls specified in the facility administrative procedures. Doors shall remain locked except during periods of access by personnel under an approved RWP which shall specify the dose rate levels in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of a stay time specification, direct or remote (such as closed circuit TV cameras) continuous surveillance may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities 6-4

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS For individual high radiation areas accessible to personnel with radiation levels greater than 1000 mrem/hr that are located within large areas where no enclosure exists for purposes of locking, and no enclosure can be reasonably constructed around the individual areas, then that individual area shall be barricaded, conspicuously posted, and a flashing light shall be activated as a warning device.

6.6.2.3 Process Control Program (PCP) 6.6.2.3.1 Changes to the PCP Changes to the PCP shall become effective after approval by the Site General Manager.

6.6.2.3.2 Reports Changes to the PCP shall be submitted to the Commission in the Radioactive Effluent Release Report for the period in which the changes were made effective. This submittal shall contain sufficiently detailed information to support the rationale for each change and a determination that the change did not reduce the overall conformance of the solidified waste product to existing criteria for solid wastes 6.6.2.4 Offsite Dose Calculation Manual (ODCM) 6.6.2.4.1 Changes to the ODCM Changes to the ODCM shall become effective after approval by the Site General Manager.

6.6.2.4.2 Reports Changes to the ODCM shall be submitted to the Comnmission in the Radioactive Effluent Release Report for the period in which the changes were made effective. This submittal shall contain sufficiently detailed information to support the rationale for each change and a determination that the change did not reduce the accuracy or reliability of dose calculations or setpoint determinations.

6.6.2.5 Radioactive Effluent Controls Program A program, conforming with 10 CFR 50.36a, for the control of radioactive effluents and for maintaining doses from radioactive effluents to members of the public as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by facility procedures, and (3) shall include remedial actions to be taken whenever program limits are exceeded. The program shall include the following elements:

6-5 I'

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS

a. Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM;

b. Limitations conforming to 10 times the concentration values specified in Appendix B, Table 2, Column 2, to 10 CFR 20.1001 - 20.2402 for the radioactive material release in liquid effluents to unrestricted areas.

c. Monitoring, sampling and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM;

d. Limitations conforming to Appendix I to 10 CFR Part 50 on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from the facility to unrestricted areas;

e. Determination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days;

f. Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 3 1-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50.

g. The dose rate due to radioactive materials released in gaseous effluents from the site to areas at or beyond the site boundary shall be limited to the following:

(a) For noble gases: Less than or equal to 500 mrems/yr to the total body and less than or equal to 3000 mrems/yr to the skin, and (b) For tritium and for all radionuclides in particulate form with half lives greater than 8 days: Less than or equal to 1500 mrems/yr to any organ.

h. Limitations conforming to Appendix I to 10 CFR Part 50 on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the facility to areas beyond the site boundary; and

i. Limitations conforming to 40 CFR Part 190 on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources.

j. The dose to a member of the public from tritium and all radionuclides in particulate form with half lives greater than 8 days in gaseous effluents 6-6

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS released to areas at or beyond the site boundary shall be limited to the following:

(a) During any calender quarter: Less than or equal to 7.5 mrems to any organ, and (b) During any calender year: Less than or equal to 15 mrems to any organ.

6.6.2.6 Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the facility. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

a. Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM;

b. A Land Use Census to ensure that changes' in the use of areas at and beyond the site boundary are identified and that modifications to the monitoring program are made if required by the results of this census, or alternatively, that critical receptors are assumed to exist at the site boundary or offsite location of highest dose consequence; and

c. Participation in a Interlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

6.6 REPORTING REQUIREMENTS The reports identified in this section shall be submitted in accordance with 10 CFR 50.4.

6.6.1 ANNUAL OCCUPATIONAL RADIATION EXPOSURE REPORT An annual report of radiation exposures received during the previous calendar year shall be submitted prior to March 1 of each year. This report shall tabulate the numbers of facility, utility and other personnel (including contractors) receiving exposures greater than I 00 millirem during the year, along with their associated dose according to work and job functions, for example, operations and surveillance, routine maintenance, special 6-7

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS maintenance (identify), and waste processing. The dose assignments to various duty functions may be estimated based on pocket dosimeter, TLD or film badge measurements. Small exposures totaling less than 20 percent of the individual total dose need not be accounted for. In the aggregate, at least 80 percent of the total whole body dose received from external sources should be assigned to specific major work functions.

6.6.2 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT-An annual radiological environmental operating report covering operation of the facility during the previous calendar year shall be submitted prior to May I of each year. The report shall include summaries, interpretations, and statistical evaluation of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the ODCM and Sections IV.B.2, IV.B.3 and IV.C of Appendix I to 10 CFR 50.

6.6.3 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT An annual radioactive effluent release report covering operation of the facility during the previous calendar year shall be submitted prior to May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the facility. The material provided shall be consistent with the objectives outlined in the ODCM and the PROCESS CONTROL PROGRAM, and shall comply with the requirements of 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

6.6.4 SPECIAL REPORTS The following special reports shall be submitted to the NRC as indicated.

a. If the sealed source contamination limits of Specification 3.4.1 are exceeded, a special report shall be submitted to the NRC within 30 days of identification of the existence of the excessive contamination. The report shall describe the equipment involved, the test results and corrective actions taken.

6.7 RECORDS Record retention requirements are described in the Quality Program Description for Nuclear Power Plants Part 1- Big Rock Point (CPC-2A).

6-8

BIG ROCK POINT DEFUELED TECHNICAL SPECIFICATIONS 6.0 ADMINISTRATIVE CONTROLS 6.8 REPORTABLE EVENTS A reportable event is any event or condition that must be reported to the NRC in accordance with 10 CFR 50.72, 10 CFR 50.73, 10 CFR 50.9(b), or 10 CFR 72.75.

6-9

ML033380975

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