ML18051B236
| ML18051B236 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/11/1985 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC |
| Shared Package | |
| ML18051B235 | List: |
| References | |
| GL-82-12, NUDOCS 8501160355 | |
| Download: ML18051B236 (14) | |
Text
- CONSUMERS POWER COMPANY DOCKET 50-255 - LICENSE DPR PALISADES PLANT REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:
I. CHANGE(s)
A. The title of "Plant Superintendent" should be changed to "Plant General Manager" in Section 6 .1.1.
B. Add Section 6.1.2:
Either the Shift Supervisor or the Shift Engineer shall be respon-sible for the shift command function. A directive to this effect shall be issued annually by the Vice President - Nuclear Operations."
C. Revise item b of Section 6.2.2 to read as follows:
At least one licensed Operator shall be present in the control
- room at all times when fuel is in the reactor.
D. Revise item c of Section 6.2.2 to read as follows:
At least one licensed Senior Operaior and one licensed Operator shall be present in the control room at all times during conditions other than cold shutdown or refueling shutdown".
E. Add an asterisk to the end of item d of Section 6.2.2. Conse-quently, the footnote at the bottom of page 6-1 should be revised to read:
"* Radiation Protection coverage and Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence provided immediate action is taken to restore the minimum requirements." ,
F. Revise item e of Section 6.2.2 to read as follows:
"All core alterations, after the initial fuel loading, shall either be performed under the direct supervision of a licensed Senior Operator or Senior Operator holding a license limited to fuel handling. During this time no other responsibilities shall be assigned to this individual."
G. The second sentence of Section 6.2.2, item f, should read:
II "The Fire Brigade shall not include 3 members 8501160355 850111 PDR ADOCK 05000255 P PDR OC1184-0009A-NL02
I. CHANGES (Continued) 2 H. Add item g to Section 6.2.2 which reads as follows:
"Administrative procedures shall be developed and implemented to limit the working hours of Plant staff who perform safety-related functions; ie, Licensed Senior Operators, Licen.sed Operators, Auxiliary Operators, Chemistry, Health Physics and key Maintenance personnel and the first-line supervision of the above listed personnel.
Adequate shift coverage shal.l be maintained without routine heavy use of overtime. However, in the event that unforeseen problems require substantial amounts of overtime to be used, the following guidelines shall be followed:
A. An individual shall not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> straight (excluding shift turnover time).
B. An individual shall not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period (all excluding shift turnover time).
C. A break of at least eight hours shall be allowed between work periods (including shift turnover time).
D. The scheduling and use of extended work shifts for an entire work group or shift complement is prohibited except during extended Plant shutdown periods.
Any deviation from the above guidelines shall be authorized by the Plant General Manager or his Alternate, or higher levels of Manage-ment, in accordance with established procedures and with documenta-tion of the basis for granting the deviation.
Controls shall be included in the pr.ocedures such that individual overtime will be reviewed monthly by the Plant General Manager or his designee to assure that excessive hours have not been assigned.
Routine deviation from the above guidelines is not authorized."
I. Change the title of Section 6. 2. 3 to "Independent Safety Engineering Group (ISEG)", and replace "NAPO" with "ISEG" and "Executive Engineer - NAPO" with "Director - Nuclear Safety" throughout. Delete phrase "and General Office interface." from end of Section 6.2.3.1. Revise Section 6.2.3.2 to read as follows:
"The ISE~ shall consist of a minimum of five (5) technical personel located at the Palisades Plant Site. The ISEG may include members located at other Consumers Power Company facilies."
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3 I. CHANGES (Con~inued)
J. Revise Section 6.3.3 to read as follows:
"The Shift Technical Advisor/Shift Engineer (STA/SE) shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and/or opera-tions, and response and analysis of the plant for transients and accidents. The Shift Engineer shall be a licensed Senior Operator."
K. Replace Figure 6.2-1 with revised Figure 6.2-1, "Offsite Organization."
L. Replace Figure 6 .* 2-2 with revised Figure 6. 2-2, "Plant Organization."
M. Replace Table 6.2-1 with revised Table 6.2-1, "Minimum Shift Crew Composition."
N. In Section 6.4.1, the title of "Nuclear Training Administrator" should be changed to "Director of Nuclear Operations Training."
- 0. Revise Section 6.4.2 to read as follows:
"The Director of Property Protection is responsible for the
- development, revision, approval and implementation of the Fire Brigade training program. This training, shall, as practicable, meet or exceed the requirements of Section 27 of the NFPA Code-1975. Fire Brigade training drills shall be held at least quarterly."
P. Revise Section 6.5.1.2 to read as follows:
"The PRC shall be composed of:
Composition Chairman: Plant General Manager or Designated Alternate Member: Engineering and Maintenance (E/M) Manager or Plant Projects Superintendent Member: Plant Operations Manager or Plant Operations Superintendent Member: Radiological Services Manager or Health Physics Superintendent or Staff Health Physicist Member: Mechanical E/M Superintendent Member: Electrical E/M Superintendent Member: Instrumentation and Control E/M Superintendent Member: Reactor Engineering Superintendent or Reactor Engineer Member: Shift Supervisor or Shift Engineer Member: Chemistry and Radwaste Superintendent or Chemical Engineer Member: Supervisory, Senior or General Engineer" Q. In Section 6.5.1.6.e replace "Executive Engineer - NAPO" with "Director - Nuclear Safety."
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/
I. CHANGES (Continued)
- 4 R. In Section 6.5.2.3 replace "Executive Director of Nuclear Activities" with "Executive Director of Nuclear Assurance" and "Executive Engineer - NAPO" with "Director - Nuclear Safety."
S. In Section 6.5.2.8.1.c replace "Executive Engineer - NAPO" with "Director - Nuclear Safety."
T. In Sect ion 6. 5. 2. 8. 1. g replace "NAPO" with "ISEG."
U. Revise Section 6.10 to read as follows:
"In addition to the applicable record retention requirements of Title 10, Code of Federal Regulations, the following records shall be retained for at least the minimum period indicated:"
V. Move item e and item f from Section 6.10.1 to Section 6.10.2. The word "current" should be deleted from item e. These two items shall be qualified in Section 6.10.2 with the footnote "Effective as of December 31, 1984."
W. Revise item g of Section 6.10.1 to read as follows:
"Records of changes made to the procedures required by Specification 6. 8.1."
X. Delete item k of Section 6.10.1.
Y. Revise item g of Section 6.10.2 to read as follows:
"Records of Quality Assurance activities required by the QA Program Description."
Z. Revise item i of Section 6.10.2 to read as follows:
"Records of meetings of the PRC and NSB."
NOTE: Revised Technical Specifications pages are attached. Proposed changes shown by a vertical line in the right hand margin.
II. DISCUSSION The above proposed Technical Specifications changes are requested in order to clarify existing'regulatory requirements, to achieve closer conformance to the Standard Technical Specifications and to recognize organizational reporting and title changes within the plant and corporate organizations as described in the letter from D J VandeWalle to the Director, NRR dated November 8, 1984.
A. This change is editorial in that the Plant Superintendent now holds the title of Plant General Manager.
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II. DISCUSSION (Continued) 5 B. S~ction 6.1.2 has been added ro meet the intent of the Standard Technical Specifications.
C. This change is editorial. The words "at all times" have been added to conform with the wording in Section 50.54(m)(2)(iii) to 10 CFR Part 50.
D. The requirement for a licensed Senior Operator and a licensed Operator in the control room at all times during conditions other than cold shutdown and refueling shutdown has been added to conform with the requirements of 10 CFR 50.54(m)(2)(iii). This represents an increase in license requirements in that the current Technical Specifications require two licensed Operators while the proposed Technical Specifications would require one licensed Operator and one license Senior Operator.
E. A footnote has been added to conform to the Standard Technical Specifications.
F. Section 6.2.2.e has been revised to conform with the requirements of 10 CFR 50.54(m)(2)(iv). This represents an increase in license requirements in that all core alterations will be required to be performed under the direct supervision of a licensed Senior Operator with no collateral duties.
G. This change is purely editorial to clarify the specification intent.
H. Section 6.2.2.g has been added to incorporate the revised working hour guidelines of NRC Generic Letter 82-12 dated June 15, 1982.
I. This change is editorial in that the Nuclear Activities Plant Organization is now called the Independent Safety Engineering Group and the Executive Engineer now holds the title of Director -
Nuclear Safety. In addition, the ISEG may no longer have personnel in the General Office and therefore Sections 6.2.3.1 and 6.2.3.2 have been revised to reflect this fact. The requirement for five technical personnel at the Palisades Plant Site is not changed, however.
- J. The title of Shift Engineer has been added to Section 6.3.3. The Shift Engineer must meet all of the qualification requirements of the Shift Technical Advisor plus be a licensed Senior Operator.
K. Figure 6.2-1 has been revised to reflect current reporting relationships and titles for the offsite organization as follows:
Nuclear Safety Board The function and reporting relationship of the Nuclear Safety Board (i.e. the offsite review committee) remains essentially the same as specified in the current Technical Specifications. The Board Chairman is the Executive Director - Nuclear Assurance (fo,rmerly OC1184-0009A-NL02
6 II. DISCUSSION (Continued) the Executive Director - Nuclear Activities) and the Vice Chairman and Secretary is the Director, Nuclear Safety (formerly the Executive Engineer. The Director, Nuclear Safety reports to the Executive Director - Nuclear Assurance who in turn reports to the Vice President.
Quality Assurance Organization The Quality Assurance (QA) functions described in our QAProgram Description (CPC-2A) are strengthened as a result of the organizational changes specified by Figures 6.2-1 and 6.2-2 of this proposed change. The responsibility for operational Quality Assurance functions, formerly at the Director level, has been elevated to the level of Executive Directbr-Nuclear Assurance. The Executive Director's authority and responsibility have been expanded to include technical assessment functions related to nuclear safety. The reporting level of the QA/QC functions at the nuclear plant has also been elevated. The onsite quality assurance organization reports directly to the Executive Director-Nuclear Assurance rather that through the offsite QA support organization as previously specified. These changes provide sufficient authority, organizational freedom and independance from the cost and schedule impacts to assure that activities affecting the quality of safety-related items are performed in accordance with QA Program requirements.
Independent Safety Engineering Group The functions of the Independent Safety Engineering Group (formerly the Nuclear Activities Plant Organization) remain as specified in the Plant Technical Specifications. The reporting level also remains as specified except for a title change by which the organi-zation reports to the Director-Nuclear Safety rather than the
- Executive Engineer as is currently reflected in the Plant Technical Specifications.
L. Figure 6.2-2 has been changed to reflect current reporting relationships and titles in plant organization as follows:
Plant General Manager The Plant General Manager (currently identified as the Generating Plant Superintendent in the Technical Specifications) is respon-sible for the overall plant operation. The Technical Director will serve as the Acting Plant General Manager in the Plant General Manager's absence (ref CPCo letter 10/12/84).
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7 II. DISCUSSION (Continued)
Plant Operations Manager The Plant Operations Manager reports to the Plant General Manager and is responsible for the day-to-day operation of the plant. In addition, the Operations Manager is assigned responsibility for plant chemistry/radwaste and reactor engineering. Reporting to the Operations Manager is the Plant Operations Superintendent, and reporting to the Plant Operations Superintendent are the licensed Shift Supervisors and Shift Engineers. The Plant Operations Superintendent is also licensed.
Engineering and Maintenance Manager The Engineering and Maintenance Manager reports to the Plant General Manager and is responsible for all preventive and correc-tive maintenance as well as implementing plant major and minor modification projects. Reporting to the Engineering and Maintenance Manager are superintendents for - Mechanical Engineering and Maintenance; Electrical Engineering and Maintenance; Instrumentation and Control (I&C) Engineering and Maintenance; and Plant Projects.
Radiological Services Manager The Radiological Services Manager reports to the Plant General Manager and is responsible for all health physics support of the plant including dose/release assessment, dosimetry, the ALARA program and the onsite implementing procedures for the Site Emergency Plan. Reporting to the Manager is the Health Physics Superintendent.
A Radiation Safety Manager (RPM as defined in Regulatory Guide 1.8) shall be designated by the Plant General Manager and shall be either the Radiological Services Manager, the Health Physics Superintendent or a Radiation Safety Supervisor. The Radiation Safety Supervisor. The Radiation Safety Manager shall have direct access to the Plant General Manager in the matters of radiation safety.
Plant Technical Director The Plant Technical Director reports to the General Manager and is responsible for providing him overall technical advise. He is also responsible for managing the Plant Safety Committee (PRC).
While the managerial titles in the new plant organization are changed and certain responsibilities have been shifted between managers, it is our belief that the organization meets the intent of our current Technical Specifications and the basis therein.
This basis was discussed in NRC letter dated January 19, 1979 which transmitted Amendment No 45 to the Plant License. This amendment promulgated the current Technical Specification requirements OC1184-0009A-NL02
I 8
regarding the plant organization and provided for four line supervisors reporting to the plant manager (ie, operations, maintenance, health physics and technical). The letter stated that: "the revised specification would specify the the required safety related dissciplines which must be represented by the staff and would require that the personnel supervising these disciplines report to the Generating Plant Superintendent - Nuclear or to an individual who reports directly to the Generating Plant Superinten-dent - Nuclear. The change would therefore provide flexibility in the organization without affecting the number and type of technical disciplines or the reporting levels of the supervisors of these disciplines." The change that is described above provides for the same technical disciplines in the same reporting relationships to the Plant General Manager as currently required by Plant Technical Specifications, and therefore the change is considered editorial in nature.
M. Table 6.2-1 has been expanded to include all individuals required to be on shift at the Palisades Plant. This includes the indivi-dual required by the Site Emergency Plan as well as Section 50.54(m)(2)(i) to 10 CFR Part 50.
In addition, the proposed change permits the shift engineer to fulfill the combined roles of shift technical advisor and licensed senior operator. This position is consistent with the NRC Staff requirements memorandum from the Secretary of the Commission to the Executive Director for Operations dated November 19, 1984.
N. This change is editorial in that the Nuclear Training Administrator how holds the title of Director of Nuclear Operations Training.
- 0. This section has been revised to make it consistent with Consumers Power Company's Fire Plan in addition to the Standard Technical Specifications.
P. This change is editorial and reflects changes in managerial and engineering titles in the plant organization. Where the organiza-tion has sufficient depth of expertise and experience in a given functional area, more than one position title in included in the PRC quorum. The number of PRC members is not changed and more than one member from a given functional area is not permitted.
Q. This change is editorial reflecting organizational title changes.
R. This change is editorial reflecting organizational title changes.
- s. This change is editorial reflecting organizational title changes.
T. This change is editorial reflecting organizational title changes.
- u. This change is editorial and consistent with wording in the Standard Technical *specifications.
- v. This change is to achieve consistency with the Standard Technical Specifications.
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I 9
W. This change is to achieve consistency with the Standard Technical Specifications.
X. The inclusion of the Chlorine Treatment Records in the Record Retention section of the Palisades Technical Specifications is considered inappropriate. These records are addressed in the National Pollution Discharge Elimination System (NPDES) program.
Y. This change is to achieve consistency with the Standard Technical Specifications.
Z. This change is editorial in that the Safety and Audit Review Board (SARB) is now called the Nuclear Safety Board (NSB).
ANALYSIS OF NO SIGNIFICANT HAZARDS CONSIDERATION This change is administrative involving changes in nomenclature and format for closer consistency with the NRC Standard Technical Specifications and current organizational reporting relationships and titles within the plant and corporate organizations. The change also incorporates current regulatory requirements related to staff working hours (NUREG-0737, Item I.A.1.3) and shift manning (10 CFR 50.54(m)).
The proposed change fits examples (i) and (ii) of the types of amendments that are considered not likely to involve significant hazards considerations published in the Federal Register on April 6, 1984 (48 FR 14870). Example (1) involves a purely administrative change to the techinical specifications: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature. Changes A, B, C, E, G, I, K, L, N, 0, P, Q, R, S, T, U, V, W, X, Y and Z fit this example. Example (ii) involves a change that constitutes an additional limitation, restriction or control not presently included in the technical specifications and the remaining changes (D, F, H, J and M) fit this example. Consequently the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92.
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10 III. CONCLUSION The Palisades Plant Review Committee has reviewed this Technical Specifi-cation Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no signifi-cant hazards consideration. This change has also been reviewed under the cognizance of the Nuclear Safety Board. A copy of this Technical Specification Change Request has been sent to the State of Michigan official designated to receive such applications for license amendment.
- NS~~E:uLtttl-1-J/~-
R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 11th day of January 1985 rfey, Notar ic County, Michigan My commission expires November 5, 1986.
SHERRY l YNN DURFEY Notary Pu~fi?, Jackson County, Mich.
My Comm1ss1on Expires Nov. 5, 1986 OC1184-0009X-NL02
POSITION NUMBER OF INDIVIDUALS REQUIRED TO FILL POSITION 11 Power Operation, Hot Cold Shutdown and Standby and Hot Shutdown Refueling Shutdown*
SS/SE l** 1 SRO/SE l** None RO 2 1 AO 2 2 STA l** None Radiation Safety 1 1 Technician Chemistry Technician 1 1 Security As stated in As stated in Security Plan Security Plan SS Shift Supervisor with a Senior Operator Licen$e SRO/SE - Shift Engineer with a Senior Operator License SRO Individual with a Senior Operator License RO Licensed Reactor Controls Operator AO Auxiliary Operator Except for the Shift Supervisor, the Shift Crew Composition may be one less than the minimum requirements of Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the Shift Crew Composition to within the minimum requirements of Table 6.2-1. This provision does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crewman being late or absent.
- Does not include additional personnel required when core alterations are being conducted. See Section 6.2.2.e.
- There shall be two individuals with Senior Operator licenses on shift. If the Shift Engineering is on shift, the STA is not required.
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6.5.2 NUCLEAR SAFETY BOARD (NSB) 12 RESPONSIBILITIES 6.5.2.1 The Nuclear Safety Board (NSB) is responsible for maintaining a continuing examination of nuclear safety-related Corporate and plant activities and defining opportunities for policy changes related to improved nuclear safety performance.
The NSB shall operate in accordance with a written charter, approved by the Vice President - Nuclear Operations, which designates the membership, authority, and rules for conducting the meetings.
FUNCTION 6.5.2.2 The NSB shall function to provide a review of designated activities in the areas specified in Specifi~ation 6.5.2.3 .
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11.1111"1 c ,_.,
ur~iTED l'IO ocr.:111 STATES l\Tnov "'"'"M1111cc1n11.1 WASHINGTON, 0.C. 20555
PLEASE November 19, 1984 OFFICE OF THE SECRETARY 984 1~V 20 A10 :51 MEMORANDUM FOR: William J. D~rcks I ExiC1.?.t.i,.'1-eu** ~_i;;ector for Operations * :. **.:..i.J '- 1 *
- FROM: Samuel J. Chilk, Secretary
SUBJECT:
STAFF REQUIREMENTS - DISCO SIO ST.A:'F ON REQUIREMENTS FOR SENICR MAN GERS, 2:30 P.M., MONDAY, NOVEMBER 5, 1984,"COMMIS-S IO?-"ERS ' CONFERENC~ ROOM (OPEN TO PUBLIC
- ATTENDANCE)
The staff discussed with the Commission the status of the rulemaking on senior managers and the policy statement on engineering expertise on shift.
The Commission unanimously voted to postpone action on the rulemaking on senior ~~nagers.
(Subsequent to the meeting, a majority of the Commission disapproved the rule:r.aking on senior managers [SECY-84-106]
and provided comments thereon.)
The Commission also unanimously voted to postpone.action on the policy statement on engineering. expertise on.shift and directed that the staff coordinate a revised policy statement with the industry (INPO and NUMARC) that will be provided to.
the Commission for re.view and approval. The new policy
- statement should clearly state the direction the Commission should follow. Primarily it should include the Commission preference for a combined shift technical advisor/senior reactor operator position. If times permits, the policy statement should further provide for enhanced qualifications for the position over a perioe of time, i.e. increased knowledge and capabilities through experience, education, and training.
'(NRR) (SECY Suspense: 1/31/85)
Commissioner Roberts prefers that the policy statement identify those areas where increased knowledge is required for
,. senior.operators to perform the STA function.* He also wants the policy statement to be adequately flexible to allow a variety of ways for licensees to demonstrate that there is
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sufficient shift e~pertise. In particular the statement should be flexible enough to allow the necessary expertise to be derived through practical relevant experience combined with some coursework.
The Commission will consider in the future a rulemaking that would include the policy statement requirements.
cc: Chairman Palladino Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Zech Commission Staff Off ices PDR - Advance DCS - 016 Phillips
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