ML18053A599

Application for Amend to License DPR-20,changing Tech Specs Re Administrative Controls

ML18053A599
Person / Time
Site:	Palisades
Issue date:	09/23/1988
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18053A598	List: ML18053A597 ML18053A599 ML18053A600
References
NUDOCS 8810030148
Download: ML18053A599 (8)

Text

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 Facility Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company September 1, 1972 on Palisades Plant be changed as described in Section I below:

I. Changes A. Delete Section 6.2.3, Plant Safety Engineering (PSE) in its entirety (Items 6.2.3, 6.2.3.1, 6.2.3.2, 6.2.3.3, and 6.2.3.4).

B. Revise Section 6.5.1.2 as follows:

Chairman: Change "Technical Engineer" to "Plant General Manager" Member: Change "Technical Director" to "Plant Safety and Licensing Director" C. Revise Section 6.5.1.6 to read as follows:

"6.5.1.6 The PRC shall be responsible for review of:

a. All proposed changes to the Operating License and Technical Specifications.

b. Results of investigations of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and recommendations to prevent recurrence and be forwarded to the Vice President-NOD and the Nuclear Safety Services Department (NSSD).)

c. Plant operations to detect potential safety hazards.

d. Reports of special reviews and investigations as requested by the Plant General Manager or Nuclear

_ Safety Services Department.

e. All reportable events as defined in Section 1.4.

f. All items identified under Specification 6.5.3.4 as significant to nuclear safety.

g. Monthly reports from Plant Safety and Licensing.

PRC review of the above items may be performed by routing subject to -the requirements of Specification 6.5.1.7."

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D.

Administrative Controls In Section 6.5.1.7, change reference from "6.5.1.6(a) through 2

(d)" to "6.5.1.6."

E. Revise Section 6.5.2 to read as follows:

"6.5.2 NUCLEAR SAFETY SERVICES DEPARTMENT (NSSD) 6.5.2.1 FUNCTION The Nuclear Safety Services Department shall function to provide independent review of activities in the areas of:

a. Nuclear Power Plant Operat_ion

b. Nuclear Engineering

c. Chemistry and Radiochemistry

d. Metallurgy

e. Nondestructive Testing

f. Instrumentation and Control

g. Radiological Safety

h. Mechanical and Electrical Engineering

i. Administrative Controls and Quality Assurance Practices

j. Emergency Planning

k. Training 6.5.2.2 COMPOSITION The NSSD shall consist of a full-time staff reporting to the Vice President - Nuclear Operations. NSSD staff shall have no direct responsibility for activities subject to their review.

• The NSSD staff shall meet or exceed the qualifications described in Section 4.7 of ANSI/ANS 3.1 - 1987.

6.5.2.3 CONSULTANTS If sufficient expertise is not available within NSSD to review particular issues, the NSSD shall have the authority to utilize consultants or other qualified organizations for expert advice.

6.5.2.4 RESPONSIBILITIES 6.5.2.4.1 REVIEW The NSSD shall review:

a. The safety evaluations for: 1) changes to procedures, equipment or systems, and 2) tests or experiments completed under the provisions of 10 CFR 50.59 to verify that such actions do not OC0988-0138-NL04

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e Administrative Controls 3 constitute an unreviewed safety question. Review of safety ey~luations may be accomplished through sampling.

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.

c. Proposed tests or experiments which involve an unre-viewed safety question as defined in 10 CFR 50.59.

d. Proposed changes to Technical Specifications or the Operating License.

e. Violations of codes, regulations, orders, Technical Specifications, license requirements or internal procedures or instructions having nuclear safety significance.

f. Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affects nuclear safety.

g. All reportable events having nuclear safety significance.

h. All recognized indications of an unanticipated defi-ciency in some aspect of design or operation of structures, systems or components that could affect nuclear safety.

i. Reports and meeting minutes of the Plant Review Committee.

6.S.2.4.2 AUDITS Audits of operational nuclear safety-related facility activities shall be performed under the cognizance of NSSD. These audits shall encompass:

a. The conforniance of plant operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.

b. The performance, tra-ining and qualifications of the entire facility staff at least once per 12 months.

c. The performance of activities required by the Quality Assurance Program Description for Operational Nuclear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50, Appendix B, at least once per 24 months.

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d. The Site Emergency Plan and implementing procedures at least once per 12 months~

e. The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 12 months.

f. Any other area of plant operation considered appropriate by NSSD or the Vice President - Nuclear Operations.

g. The plant Fire Protection Program and implementing procedures at least once per 24 months.

h. An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

i. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

j. The Radiological Environmental Monitoring Program and the results thereof at least once per ~2 months.*

k. The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.

1. The Process Control Program and implementing procedures for processing and packaging of radio-active wastes at least once per 24 months.

Audit reports encompassed by 6.5.2.4.2 above shall be forwarded to the NSSD, and management positions responsible for the areas audited within thirty (30) days after completion of the audit.

6.5.2.5 AUTHORITY The NSSD shall report to and advise the Vice _f,resident -

Nuclear Operations of significant findings associated with those a~eas of responsibility specified ~in Sec-tion 6.5.2.4.1 and Section 6.5.2.4.2.

6.5.2.6 RECORDS Records of NSSD activities shall be maintained. Reports shall be prepared and distributed as indicated below:

a. The results of reviews, performed pursuant to Section 6.5.2.4.1 and s.ection 6.5.2.4.2, shall be reported to OC0988-0138-NL04

TSCR ~ Administrative Controls 5 the Vice President - Nuclear Operations at least

. monthly.

b. A report assessing the overall nuclear safety performance of the Palisades Plant shall be provided to senior Consumers Power Company management annually."

F. Add a new Section 6.5.3 as follows:

"6.5.3 PLANT SAFETY AND LICENSING 6.5.3.1 FUNCTION The Plant Safety and Licensing organization shall function to examine industry operating experience, plant events, and proposed changes in design or operation to identify issues significant to nuclear safety and recommend nuclear safety improvements.

6.5.3.2 COMPOSITION The Plant Safety and Licensing staff shall be composed of at least five experienced technical staff, reporting to the Plant Safety and Licensing Director, to carry out these functions.

6.5.3.3 RESPONSIBILITIES The Plant Safety and Licensing staff shall provide technical review of safety evaluations performed under 10 CFR 50.59 for:

a. procedures, programs and changes the.re to identified in Specification 6.8

b. all proposed tests or experiments

c. all proposed changes or modifications to plant systems or equipment

d. all proposed changes to Appendix A Technical Specifications.

6.5.3.4 AUTHORITY The Plant Safety and Licensing staff shall determine those issues significant to nuclear safety which require review by the Plant Review Committee from items considered under Specification 6.5.3.3.a through c.

6.5.3.5 RECORDS Reports of Plant Safety and Licensing activities pursuant to Specification 6.5.3.3 shall be submitted monthly to PRC."

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TSCR - Administrative Controls 6 G.. Delete the following from Section 6.8.2: "PRC is responsible 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)." The second sentence of Section 6.8.2 is retained.

H. In Section 6.8.3.c, change "PRC at the next regularly scheduled meeting" to "Plant Safety and Licensing within 30 days of issuance,"

and change "Plant Manager" to "Plant General Manager" in two places.

I. Revise the Table of Contents as shown on page changes.

II. Discussion The above proposed Technical Specification changes are requested to strengthen the onsite and independ~nt nuclear safety review function for Palisades.

A. In Change A, the independence of the Plant Safety Engineering Group is eliminated. The Plant Safety and Licensing organization reporting to the Plant General Manager, is established as described in Section 6.5.3. This change will improve the effectiveness of Nuclear Safety Review at the plant by establishing an organizational unit responsible for nuclear safety review at the same reporting level in the plant organization as Engineering & Maintenance, Operations, and Radiological Services functions. As was the function of the Plant Safety Engineering group, the PS&L will be responsible for examination of NRC issuances, industry advisories, and to identify nuclear safety issues and make recommendations to improve nuclear safety. In addition, the PS&L group will be responsible for conducting technical reviews of all safety evaluations completed under 10 CFR 50.59 and for submitting those considered significant to safety for review by the Plant Review Committee. Refer to Item (C) for further discussion.

B. Section 6.5.1.2 is revised to reflect the Plant General Manager as the PRC Chairman and changes the Plant Technical Director title to Plant Safety and Licensing Director. The Plant General Manager as PRC Chairman has the authority to convene a PRC quorum consisting of the senior plant department heads, thus, significantly strengthening the role of PRC in reviewing plant safety issues.

C. Section 6.5.1-6 is revised to reflect the relationship between the PRC and the Plant Safety and Licensing organization with respect to the review of 10 CFR 50.59 safety evaluations. PS&L will technically review all safety evaluations and will submit to PRC for review those considered to be significant to safety, including all unreviewed safety questions; those involving a safety limit, safety system setting, or limiting condition for operation; and any technical concerns not resolved between the initiator and technical reviewer. In this way, PRC attention will be focused on important safety issues requiring the attention of the senior plant department heads.

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e Administrative Controls 7 D. The changes in 6.5.1.7 result in routing reviews being permitted for all items subject to PRC review subject to the identified restrictions.

E. *Changes to Section 6.5.2 are the result of the offsite independent review function being carried out by a full-time organization rather than a committee. Per Specifications 6.5.2.4.la, b, c, all safety evaluations completed under 10 CFR 50.59 will be submitted to NSSD.

Those determined not to involve an unreviewed safety question will be reviewed by NSSD based on a random and selective sampling method to verify that the unreviewed safety question determination was correct and that PS&L is selecting items for PRC review appropriately.

All safety evaluations determined by the plant to constitute.an unreviewed safety question will be reviewed by NSSD prior to submittal to the NRC to ensure the safety analysis is adequate.

Safety evaluations will be reviewed by NSSD on a sampling basis in order to:

1. Ensure that responsibility for the technical adequacy of the safety evaluation remains in the line organization and is not assumed by the oversight organization.

2. Provide NSSD the opportunity to conduct an in-depth review of a limited population of safety evaluations and, thereby, draw conclusions as to the overall quality of the entire population.

The combination of Items 1 and 2 will provide a more effective review than is currently provided by committee overview of all safety evaluations. Because procedures and changes thereto make up the vast majority of safety evaluations and are generally not controversial with respect to 10 CFR 50.59, a random method will be employed to select those for NSSD review. Changes to the facility, as well as tests and experiments, will be selectively sampled based on a screening review. Initially, the sample size will be essentially 100% until adequate performance is established by the line organization in the preparation of safety evaluations.

It is intended that NSSD review of the subjects in Section 6.5.2.4 will be carried out by an assigned lead reviewer, selected on the basis of technical expertise relative to the subject to be reviewed.

A second-level review will be performed by the Director of Nuclear Safety. If the lead reviewer or the Director determines the need for interdisciplinary review, additional reviewers will be assigned.

As a result, all items subject to NSSD review will receive more in-depth_consideration than is currently the practice with committee overview.

F. Section 6.5.3 establishes the authority and responsibility of the Plant Safety and Licensing organization. See items (A) and (C) above for further discussion.

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TSCR ~ Administrative Controls 8 G. Section 6.8.2 is revised for consistency with proposed changes to

6. 5 .1. 6 and proposed Specification 6. 5. 3. 3. PRC will review safety evaluations for procedures, as determined by Plant Safety and Licensing, subject to independent review by the Nuclear Safety Services Department.

H. Section 6.8.3c requires PS&L to review temporary changes to procedures rather than PRC. This review will be accomplished within 30 days of issuance of the temporary change, which is consistent with the current time frame for PRC review. PRC review would be required for those considered significant to safety as established in Specification 6.5.3.

Analysis of No Significant Hazards Consideration The changes. as proposed are organizational, designed to strengthen the nuclear safety review function at the plant and offsite. There is no effect 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 margin of safety defined in the basis for the Technical Specifications has not been affected because no margin of safety is defined for the Administra-tive Controls Section of the Technical Specifications.

III. Conclusion The Palisades Plant Review Committee has reviewed this Technical Specification Change Request and determined that this change does not involve an unreviewed safety question and, therefore, involves no*

significant hazards consideration. This change has also been reviewed by the Nuclear Safety Board and found to be acceptable. A copy of this change has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.

CONSUMERS POWER COMPANY By~~~ Nuclear Operations Sworn and subscribed to before me this 23rd day of September 1988.

Bever! Ann Avery, No y Public Jackson County, Michigan My commission expires December 27, 1988 OC0988-0138-NL04

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