ML18051B504
| ML18051B504 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 08/05/1985 |
| From: | Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8508120403 | |
| Download: ML18051B504 (3) | |
Text
consumers Power company General Offices:
1945 West Parnell Road. Jackson, Ml 49201 * (517) 788-1636 August 5, 1985
- Director, Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington, DC 20555 DOCKET 50-255 - LICENSE DPR PALISADES PLANT -
APPROVAL OF PROCEDURES REQUIRED BY TECHNICAL SPECIFICATION 6.8.1 David J VandeWalle Director of Nuclear Licensing Technical Specification 6.8.1 establishes the requirement for written procedures addressing certain plant activities.
Specification 6.8.2 states that the Plant Review Committee (PRC) is responsible for the review of procedures and changes thereto, and that the Plant General Manager shall approve procedures and procedure changes prior to implementation.
The PRC review of proc.edures and procedure changes consists of a multidisciplinary safety review by appropriate management and technical experts within the plant staff.
PRC comments on procedures are resolved by line management, and disagreements between PRC and line management are resolved by the Plant Manager.
A PRC recommendation for approval is required before a procedure or procedure change may be approved, except on rare occasions when the Plant Manager may choose to overrule the PRC.
The Plant Manager reviews PRC meeting minutes and indicates, by his signature on the minutes, his approval or disapproval of PRC recommendations.
Consequently, the Plant*Manager!s signature-approval of procedures is for the most part*
based on his review of PRC deliberations as described in the PRC meeting minutes and, therefore, is largely administrative in nature.
We believe that it would be more efficient for the Plant Manager to delegate.
his procedure approval authority to members of plant management as appropriate based on the activities addressed by the procedure.
Delegation of this activity will clarify line manager accountability for procedures in his functional area of responsibility, and relieve the plant manager of the largely administrative task of approving changes to the nearly 2000 procedures currently in place at Palisades Plant.
Delegation of the Plant Manager's procedure approval authority appears to be permissible under current Technical Specifications requirements.
We have discussed this matter with the Palisades Licensing Project Manager and the NRC Region III QA Programs Section, and both support this interpretation.
- Hence, OC0785-0006A-NL03
Director, Nuclear Reactor Regulation Palisades Plant Approval of Procedures August 5, 1985 it is our intention to immediately implement necessary changes to our administrative controls to permit delegation of the Plant Manager's procedure approval authority.
In addition, at the request of the Palisades Licensing Project Manager, we will promptly submit a proposed change to section 6.8 of the Palisades technical specifications to reflect our interpretation of the current requirements.
A draft technical specification revision is attached for your information.
~J/.f!tf&tdafL Director, Nuclear Licensing CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades OC0785-0006A-NL03 2
Director, Nuclear Reactor Regulation Palisades Plant
.Approval of Procedures Date ATTACHMENT
- 6. 8. 2 PRC is resp'onsible for the review of each procedure of 6. 8. 1 above, and changes thereto (except for Security Implementing Procedures which are reviewed and approved in accordance with the Site Security Plan).
Procedures and changes shall be approved prior to implementation by a member of plant management designated by the plant manager.
6.8~3 Temporary changes to procedures of Specificat~on 6.8.1 above may be made provided:
- a.
The intent of the original procedure is not altered.
- b.
The change is approved by two members (or designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator's License.
- c.
The change is documented, reviewed by the PRC at the next regularly scheduled meeting and approved by a member of plant management designated by the.plant manager.
OC0785-0006A-NL03