ML18052A718
| ML18052A718 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/29/1986 |
| From: | Buckman F CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18052A717 | List: |
| References | |
| NUDOCS 8610090054 | |
| Download: ML18052A718 (13) | |
Text
CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Palisades Operating License DPR-20 and the Technical Specifications For the reasons hereinafter set forth, it is requested that the Provisional Operating License DPR-20, and the.Technical Specifications, 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.
The title of "Plant Superintendent" should be changed to "Plant General Manager" in Section 6.1.1.
B.
Add Section 6.1.2:
"The Shift Supervisor or, in his absence from the control room, the second.licensed senior operator on duty shall be responsible.for the shift command function.
A directive to.this effect shall be issued annually by the Vice President - Nuclear Operations."
C.
Revised item b of Section 6.2.2 to read as follows:
"b.
At least one licensed senior operator shall be in the control room at all times during conditions other than cold shutdown or refueling.
In addition to this senior operator, at least one licensed operator or senior operator shall be present at the controls at all times when fuel is in the reactor."
D.
In section 6.2.2 delete existing item c and reletter items d, e, and f as c, d, and e.
E.
Revise the new item c of Section 6.2.2 and revise footnote at the bottom of page, to read:
F.
"c.
A radiation safety technician shall be on site when fuel is in the reactor.*"
"*The radiation safety technician and the 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."
Revise the new item d of Section 6.2.2 to read as follows:
"d.
All core alterations.,_ after the initial fuel loading, shall either be performed under the direct supervision of a. licensed f
8610090054 860929
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PDR ADOCK 05000255 I
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Request for Change - Admin Controls 2
- 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, new item e, should read:
"The Fire Brigade shall not include 3 members of the minimum shift crew..* "
H.
Add new item f to Section 6.2.2 which reads as follows:
"f. Administrative procedures shall limit the working hours of Plant staff who perform safety-related functions.
In the event that overtime is used, the following guidelines shall be followed:
A.
An individual shall not be permitted to work more th~n 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.
Except during extended shutdown periods the use of overtime should be considered on an individual basis and not for the entire staff on a shift.
Deviations from.the overtime guidelines shall be authorized by the Plant General Manager or his Alternate.
The basis for granting the deviation shall be documented.
Routine deviations are not to be authorized.
Individual overtime will be reviewed monthly by the Plant General Manager or his designee to assure that excessive hours have not been assigned."
I.
Change title of Section 6.2.3 to Plant Safety Engineering (PSE) and replace Sections 6.2.3.1, 6.* 2.3.2, 6.2.3~3, and 6.2.3.4 with the following and also delete footnote 1 in 6.2.3.2.
"6.2.3 FUNCTION 6.2.3.1 TSOP0686-0104-NL04 PLANT SAFETY ENGINEERING (PSE)
PSE shall function to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety.
The organization shall report to the Director of Nuclear
Request for Change - Admin Controls Safety.
With the concurrence. of the Director_, PSE may function as staff to the onsite and offsite review
- organizations and provide. technical support* for problem resolution.
COMPOSITION 6.2.3.2 PSE shall consist of a minimum of five (5) technical personnel located onsite at the Palisades Plant.
QUALIFICATIONS 6.2.3.3 At least three of the full-time members at the Palisades Plant shall have a bachelor's degree in engineering or a related science.
At least one of the three shall have a minimum of five years' professional experience which includes a minimum of two years' experience in nuclear power plant operation and/or design.
Those individuals REPORTS comprising the minimum complement of five and not having bachelor's degrees in engineering or a related science shall have at least two years' experience in the field for which they will provide expertise to PSE.
3 6.2.3.4 Reports of PSE activities shall be submitted regularly to the NSB."
J.
In Section 6.3.2 replace "Health Physicist" with "Health Physics
- Superintendent".
Change footnote superscript 1 to an asterisk(*)
and identify the footnote with the same.
K.
Revise Section 6.3.3 to read as follows:
"The Shift Technical Advisor and the Shift Engineer shall have a bachelor's degree or equivalent in.a scientific or engineering discipline with specific' training in plant design and/or operations, and response and analysis of the plant for transients and accidents.
The Shift Engineer shall be a licensed Senior Operator."
L.
Replace Figure 6.2-1 with the revised Figure 6.2-1, "Offsite Organization."
(Provided in the attached Proposed Technical Specification Page Changes.)
M.
Replace Figure 6.2-2 with revised Figure 6.2-2, "Plant Organization."
N.
Replace Table 6.2-1 with revised Table 6.2-1, "Minimum Shift Crew Composition."
O.
In Section 6.4.1, the title of "Nuclear Training Administrator" should.be changed to "Executive Director of Energy Supply Planning, Training and Administration."
TSOP0686-0104-NL04
Request for Change - Admin Controls P.
Revise-Section 6.4.2 to read as follows:
"The Director of Property Protection is respons~ble for the development, revision, approval and implementat'ion 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."
Q.
Revise Section 6.5.1.2 to read as follows:
"The PRC shall be composed of:
Chairman:
Technical Engineer or Designated Alternate Member:
Operations Manager*
Member:
Engineering and Maintenance Manager*
Member:
Radiological Services Manager*
Member:
Technical Director*
Member:
Reactor Engineering Superintendent Member:
Operations Superintendent Member:
Instrumentation and Control Superintendent Member:
Shift Supervisor or Shift Engineer (l)"
- may serve as Designated Alternate for the Chairman" R.-
Revise Section 6. 5.1. 3 to read as follows:
"Alternate members of the PRC shall be appointed in writing 'by the PRC Chairman to serve on a temporary basis.
No more than two alternates shall participate as voting members at any one time in PRC activities.
Members identified with a asterisk (*) above may function as the Designated Alternate for the Chairman, and in so doing, are not considered alternate members for voting purposes."
S.
Change Plant Manager to "Plant General Manager" in Section
- 6. 5.1. 6a.
T.
In Section 6.5.1.6.e replace "Executive Engineer - NAPO" with "Director of Nuclear Safety."
U.
In Section 6.5.2.3 change the first paragraph to read:
4 "The NSB shall consist of members appointed by the Vice President -
Nuclear Operations.
NSB shall be chaired by the Director of Nuclear Safety who will report directly to the Vice President on Nuclear Safety Board matters."
U.1 In section 6.5.2.7 change the first sentence to read as below and delete the parenthetical sentence entirely.
"A quorum of NSB shall consist of the Chairman, or his designated alternate, and at least four (4) members."
TSOP0686-0104-NL04
Request for Change - Admin Controls V. -
Iri Sect-ion 6. 5. 2. 8. le delete "Execu~ive Engineer - NAPO".
W.
In Section 6.5.2.8.lg replace "NAPO" with "PSE."
\\
X.
Correct typographical errors as follows:
- 1.
Section 6. 5. 2. 8. 2c "quality"
- 2.
Section 6.5.2.8.2f "appropriate"
- 3.
Section 6.5.2.8.3 "positions" (in last paragraph)
Y.
In paragraph three of Section 6.9.3.1.B change Table 4.11-4 to "Table 6.9-1".
5 Z.
In Section 6.9.3.3a, delete the requ.irement for a five year Primary System Surveillance Evaluation and Review.
AA.
Delete item bin Section 6.9.3.3, remove item c., and reletter item
- d. as item b.
BB.
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:"
CC.
Move item e and f from Section 6.10.1 to items m and n of Section 6.10.2.
The word "current" should be deleted from new item m.
These two items shall be qualified in Section 6.10.2 with the
.footnote "**Effective with the issuance of Amendment No.
(Consumers Power Company requests the NRC to add the Amendment number upon issuance.)
DD.
.Revise old item g of Section 6.10.1 to read as follows and reletter as item e:
"e.
Records of changes made to the procedures required by Specification 6.8.1" EE.
Delete item k of Section 6.10.1.
FF.
Reletter items h through j in Section 6.10.1 as items f through h.
GG.
Revise item g of Section 6.10.2 to read as follows:
"Records of Quality Assurance activities required by the QA Program Description."
HH.
Revise item i of Section 6.10.2 to read as follows:
"Records of meetings of the PRC and NSB."
TSOP0686-0104-NL04
- l Request for Change - Admin Controls 6
II.
Delete item k and-add new item k to Section 6.10.2 to read:
"k.
Records of secondary water sampling and water quality.**"
JJ.
Delete Section 6.13 "FIRE PROTECTION INSPECTION."
KK.
Delete Section 6.14, "ENVIRONMENTAL QUALIFICATION."
LL.
Delete from the Provisional Operating License the following Orders:
Order dated August 29, 1980; revised September 19, 1980, modifying License.
Order dated October 24, 1980, modifying License.
MM.
Delete item 3.J in the Provisional Operating License, entitled "18-month Surveillance.Test Requirements, During Cycle S".
II.
DISCUSSION The above proposed Technical Specifications changes are requested in order to clarify existing reguiatory 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; the title of Plant General Manager replaces the Plant Superintendent title.
B.
Section 6.1.2 has been added to meet the intent of the Standard Technical Specifications and Section 2.2.1.a of NUREG-0578, TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations.
C.
This change is to conform with the wording of 10CFR 50.54(m)(2)(iii).
D.
Editorial change to reletter items.
E.
The change and footnote have been made to conform to the Standard Technical Specifications.
F.
Section 6.2.2.d 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 alternations will be required to be performed under the direct supervision of a licensed.Senior Operator with no collateral duties.
G.
This change is editorial to clarify the specification intent.
TSOP0686-0104-NL04
. I Request for Change - Admin Controls
- H.
New section 6.2~2.f has been added to incorporate the revised working hour guidelines of NRC Generic Letter 82-12 dated June 15, 1982 and Generic Letter 82-16 dated September 20, 1982.
I.
This change is editorial in that the Nuclear Activities Plant.
Organization is now called Plant Safety Engineering (PSE) and is the responsibility of the Director of Nuclear Safety instead of the Executive Engineer.
In addition, the PSE no longer has 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 changes of titles, Health Physicist to Health Physics Superintendent reflect changes made in plant staff.
K.
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.
This section is consistent with CPC letter to NRC dated May 23, 1986.
L.
Figure 6.2-1 has been revised to reflect current reporting relationships and titles for the offsite organization as follows:
Nuclear Safety Board 7
The function and reporting relationship of the Nuclear Safety Board (the offsite review committee) remains essentially the same except that the-Director of Nuclear Safety (formerly the Executive Engineer -
NAPO) will be the Board Chairman instead of the Executive Director of Nuclear Assurance (formerly the Executive Director of Nuclear Activities).
The Director of Nuclear Safety will report directly to the Vice President - Nuclear Operations on Nuclear Safety Board matters.
Quality Assurance Organization The Quality Assurance (QA) functions described in our QA Program 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 Director of 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 of ~uclear Assurance rather than through the off site QA support organization as previously specified.
These change provide sufficient authority, organizational freedom and independence from the cost TSOP0686-0104-NL04
- e Request for Change - Admin Controls 8
and schedule impacts toassure that.activities affecting the quality of safety-related items are performed in accordance with QA Program-requirements.
Plant Safety Engineering (PSE)
The functions of the PSE (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 organization reports to the Director of Nuclear Safety rather than the Executive Engineer as is currently reflected in the Plant Technical Specifications.
Training The Vice President - Energy Supply Services is responsible for training services for all company plants including nuclear.
Reporting to the Vice President is the Executive Director of Energy Supply Planning, Training and A_dministration who is respon~ible for the training programs.
M.
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 responsible 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).
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 corrective 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.
TSOP0686-0104-NL04
Request for Change - Admin Controls Radiological Services Manager The Radiological Services Manager reports to the Pl.ant General Manager and is responsible for all health physics support of the plant including do~e/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 the Regulatory Guide 1.8, shall be designated by the Plant General Manager and shall be either the Radiological Services Manager, or the Health Physics Superintendent.
The Radiation Safety Manager shall have direct access to the Plant General Manager in the matters of radiation safety.
Plant Technical Director 9
The Plant Technical Director reports to the Plant General Manager and is responsible for providing him overall technical advice and provid~s an overview function of safety-related activities.
He is also responsible for managing the Plant Safety Committee (PRC), and assists the Plant General Manager in administration of operations and maintenance matters.
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 regarding the plant organization and provided for four line supervisors reporting to the Plant General Manager (ie, operations, maintenance, health physics and technical).
The letter stated that:
"the reyised specification would specify the required safety related disciplines 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 Superintendent - 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 forthe 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.
TSOP0686-0104-NL04
Request for Change - Admin Controls N~
Table 6.2-1 has beeµ.changed to include individuals requj_red to be on shift consistent with 10CFRS0.54(m)(2)(i) and the Standard Technical Specifications
- 10
. In addition, the proposed change permits a licensed senior reactor operator to fulfill a combined role of shift technical advisor and licensed senior reactor operator.
This position is consistent with the NRC Policy Statement on Engineering Expertise on shift effective October 28, 1985 ie, "..* in the long term the Commission would prefer that the STA be combined with the Shift Supervisor in the dual-role position."
- 0.
This change reflects an organizational change.
The Executive Director of Energy Supply Planning, Training and Administration is responsible for retraining and replacement training programs for the plant staff.
P.
This section has been revised to make it consistent with Consumers Power Company's Fire Plan in addition to the Standard Technical Specifications.
Q.
This change is primarily editorial and reflects changes in managerial and engineering titles in the plant organization.
The Technical Engineer has been specifically identified as the PRC Chairman to more closely represent actual plant practice in which the Technical Engineer routinely functions as the designated chairman.
R.
The identification of specific members, eligible to function as alternate chairman represents an additional administrative control which ensure PRC activities are conducted by appropriate members of the plant management.
S.
This change is editorial reflecting the correct title for the Plant General Manager.
T.
This change is.editorial reflecting organizatio!l title changes.
U.
This change reflects the normal practice of the Director of Nuclear Safety, formerly the Executive Engineer -
NAPO, acting as the chairman of NSB.
The title of Vice Chairman of NSB has been eliminated.
U.l This charige is to reflect the organization as discussed in U.
above.
V.
This change is editorial reflecting organization title changes.
W.
This change is editorial reflecting organization title changes.
X.
Typographical corrections are editorial changes.
Y.
This change is editorial.
Table 4.11-4 was eliminated by a prior amendment.
The correct format is now provided by Table 6.9-1.
TSOP0686-0104-NL04
Request for Change - Admin Controls 11 Z.
- The Primary Surveillance*Evaluation and Review was a requirement
-imposed by Section 4.3 of the original Technical Specifications.
The original requirement provided that the in-service inspection program was to be reevaluated at the end of five years to consider the incorporation of new in~pection techniques that have been proven practical and the conclusions of this evaluation were to be reviewed with the NRC.
On October 15, 1979, the requirements of 10CFR50.55a were incorporated irito the Technical Specifications by ~endment 53.
The amendment replaced Section 4.3 and eliminated the requirement for a five year review.
However, Section 6.9.3.3a was not deleted as it should have been.
Therefore, this change is editorial.
The five year review of the original Section 4.3 was satisfied by the activities related to the implementation of 10CFR50.55a.
The special report is no longer a valid requirement.
AA.
The special report required by Section 6.9.3.3b is no longer required.
The activities related to the improvement of the reliability of the paths to prevent post-LOGA boron precipitation are complete.
The reporting requirement was instituted by Amendment 21, dated April 29, 1976.
On completion of the necessary modifications in 1981, the reports were discontinued.
However, the _unnecessary reporting requirement still remains in the Technical Specifications.
Therefore, the deletion of the requirement is for editorial purposes.
BB.
This change is editorial and consistent with wording in the Standard Technical Specifications.
CC.
This change is to achieve consistency with the Standard Technical Specifications.
Since the retention requirement was previously five years the new lifetime requirement will become effective with the issuance of *an amendment approving the change request.
DD.
This change is to achieve consistency with the Standard Technical Specifications.
EE.
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.
The requirement is also not contained in the Standard Technical Specifications.
FF.
Relettering of items is an editorial change.
GG.
This change is to achieve consistency with the Standard Technical Specifications.
TSOP0686-0104-NL04
Request for Change - Admin Controls 12 HH.
This chatig-e is editorial in tohat the Safety and Audit Review Board (SARB) is now called the Nuclear Safety Board (NSB).
II.
Removal of the old item k is necessary because Section 6.14 is being deleted per KK. below.
The addition of a new item k requirement will achieve consistency with the Standard Technical Specifications.
Permanent record keeping will be initiated with the approval of an amendment approving the change request.
JJ.
The fire protection inspection requirements provided by Section 6.13 are identical to the audits required by Section 6.5.2.8.2, items h. and i. Therefore, the deletion of Section 6.13 is editorial.
No reduction in current requirements will result from this change.
KK.
The Environmental Qualification requirement of safety-related electrical equipment in Section 6.14 was rendered obsolete by 10 CFR Part 50.49 which was adopted January 21, 1983 and amended November 19, 1984.
LL.
The Orders dated August 29, 1980, revised September 19, 1980 and October 24, 1980, modifying the Provisional Operating License relate to an Environmental Qualifications compliance date of June 30, 1982 and as in item KK. above became obsolete by 10CFR50.49.
MM.
Deletion of the 18-month Surveillance Test Requirements During Cycle 5 is.an editorial change to remove an obsolete license stipulation.
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)).
Requirements related to Environmental Qualification and Primary System Surveillance Evaluation and Review have become obsolete by NRC regulations.
Other requirements have also been removed as they were redundant to other specifications.
There is no affect on the probability of occurrence or consequences of an accident nor has the possibility of an accident or malfunction of a different type been created.
The safety margin defined in the basis for the Technical Specifications has not been affected by the organizational and editorial changes because no safety margin is defined for the Administrative Section of the Technical Specifications.
TSOP0686-0104-NL04
Request for Change -. Admin Controls 13 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 Buckman, Vice Presiden Nuclear Operations Sworn and subscribed to before me this 29th day of September 1986.
- ~u~e~
Jackson County, Michigan My commission expires October 31, 1989 TSOP0686-0104-NL04