ML18051B570

Application for Amend to License DPR-20,revising Tech Spec 6.8 to Allow Delegation of Plant Manager Procedure Approval Authority by Plant Manager,To Other Appropriate Members of Plant Mgt

ML18051B570
Person / Time
Site:	Palisades
Issue date:	10/15/1985
From:	Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18051B569	List: ML18051B568 ML18051B570 ML18051B571
References
NUDOCS 8510220258
Download: ML18051B570 (3)

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CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 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. Changes A. Change the last sentence of section 6.8.2 to read:

"Procedures and changes shall be approved prior to implementation by a member of plant management designated by the plant manager."

B. Change section 6.8.3.c to read:

"The change is documented, reviewed by the PRC at or by the. next regularly scheduled meeting and approved by a member of plant management designated by the plant manager."

II. Discussion The above proposed Technical Specifications changes are requested to allow the plant manager to delegate his procedure approval authority to appropriate members of plant management.

The PRC review of procedures 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- occas1:ons--when-the- Plant Managel" 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.

2 Analysis of No Significant Hazards Consideration PRC review of procedures consists of a multidisciplinary review by

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---- - - approprfate management and-tedinicaT personnel wl.Ehin- the -plant si:afL This review will remain intact. The proposed change, will however, allow the plant manager to delegate the procedure approval authority to appropriate members of plant management. The delegation of this authority to the appropriate line manager will put greater emphasis on the line managers area of responsibility and relieve the plant manager of an administrative task of approving all changes to nearly 2000 Palisades procedures. The change in this administrative approval authority produces no significant increase in the probability of occurrence or the consequences of an accident of malfunction of equipment important to safety previously evaluated in the Safety Analysis Report because multidisciplinary reviews and procedural approval will be conducted by appropriate members of the plant staff.

The change in delegation of procedure approval authority does not increase the possibility of an accident or malfunction of a different type than any evaluated previously in the SAR.

No basis for this Technical Specification is provided and therefore no margin of safety is affected.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does not involve an unreviewed safety question and therefore involves no significant 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 Amendments to the Operating License.

CONSUMERS POWER COMPANY By-Q~~~mu ---- --- -------- , __ *- --- -* ---*-----------

R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 15th day of October 1985.

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{~:Jefc~~qti.'Cqunf:f, Michigan My commission expir~s October 12, 1987.

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ATTACHMENT Consumers Power Company

-Palisades- P1an_t_

Docket 50-255 TECHNICAL SPECIFICATION CHANGE REQUEST PROCEDURE APPROVAL October 15, 1985 1 Page IC1085-0299-NL04