ML18057B168
| ML18057B168 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 07/15/1991 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18057B169 | List: |
| References | |
| NUDOCS 9107240117 | |
| Download: ML18057B168 (9) | |
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consumers Power POW ERi Nii MICHlliAN'S PROliRESS Palisades Nuclear Plant:
27780 Blue Star Memorial Highway, Covert, Ml 49043 July 15, 1991 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 - LICENSE DPR-20
~ PALISADES PLANT -
TECHNICAL *SPECIFICATIONS CHANGE REQUEST - ADMINISTRATIVE CONTROLS GB Slade General Manager Effective April 1, 1991, Consumers Power tompany restructured the Nuclear Operations Department (NOD) with emphasis on changes in the engineering, offsite review and quality assurance organizations (See Attachment 3 for.the new organization charts). A new design engineering group, the Nuclear Engineering and Construction Organization (NECO), which is formed from a combination of resources from existing NOD and Energy Supply Services departments, was implemented and located at Palisades. This group is headed by the Nuclear Engineering Manager who reports directly to the Vice President of Nuclear Operations. Another new group, called the Nuclear Performance Assessment Department (NPAD) is responsible for both the traditional QA audit function and the independent review function. This group wi 11 be headed by the Director, NPAD, who reports directly to the Vice President of Nuclear Operations.
To align the requirements of the Palisades Technical Specifications with the above described organizational changes, a technical specifications change is requested.
Additionally, to facilitate changes in the Plant Review Committee (PRC) composition,_.t.h_is_r~quest propo_ses to change the composition of the PRC in that the specific titles of members are being de1et~d ~nd repl~~ed with a generic statement.
With the management reorganization, some of the position titles listed in the existing technical specifications for PRC members have been eliminated while other comparable position titles have been added.
Expeditious approval of this change is requested to avoid possible confusion regarding PRC membership.
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~ contains proposed new technical specifications pages.
Attachment 2 contains existing technical specifications pages marked up to show proposed changes. contains organization charts for the restructured Nuclear Operations Department.
Gerald B Slade General Manager CC Administrator, Region III, USNRC NRC Resident Inspector - Palisades
I CONSUMERS POWER COMPANY Docket 50-255 Request for Change to the Technical Specifications License DPR-20 1
For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Facility Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on February 21, 1991, for the Palisades Plant be changed as described in Section I below:
I.
Changes A.
Revise Section 6.5.1.2 as follows:
6.5.1.2 COMPOSITION The PRC is composed of ten regular members from either the Palisades staff or the Nuclear Engineering and Construction Organization (NECO) staff. The PRC members shall meet or exceed the minimum qualifications of ANSI NlB.1-1971 for comparable positions. The PRC shall include representatives from the Operations, Radiological Services, Maintenance and Engineering Departments.
The members shall be designated in administrative procedures by the Plant General Manager.
The Plant General Manager shall also designate the Chairman and Alternate Chairmen in writing.
B.
Delete the last sentence of Section 6.5.1.3.
C.
Change Section 6.5.1.5 to read:
"A quorum of the PRC shall consist of the Chairman or Alternate Chairman and four members (including alternates)."
D.
Change Section 6.5.1.6.c as follows:
"c. 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 to the Director Nuclear Performance Assessment Department (NPAD).)"
E.
Change Section 6.~.l.~.f and 6.10.1.c to read:
"All reportable events as defined in Section 6.9.2."
F.
In Sections 6.5.1.6.e, 6.5.1.7.c and 6.5.1.8 change "NSSD" to "NPAD" and "Nuclear Safety Services Department" to "Nuclear Performance Assessment Department" as applicable.
G.
Change the title of Section 6.5.2 to "NUCLEAR PERFORMANCE ASSESSMENT DEPARTMENT (NPAD)".
H.
Change Section 6.5.2.1 to read:
- 6. 5. 2.1 FUNCTION The Nuclear Performance Assessment Depart (NPAD) shall function to provide independent review of activities in the areas of:
- a.
Nuclear power plant operation
- b.
Nuclear engineering
- c. Chemistry and radiochemistry
- d.
Metallurgy
- e.
Instrumentation and control
- f.
Radiological safety
- g.
Mechanical and electrical engineering
- h.
Quality assurance practices I.
Change Section 6.5.2.2 to read:
6.5.2.2 COMPOSITION The NPAD shall include the Director, who reports to the Vice President - NOD, and a full-time staff of Nuclear Performance Specialists reporting to the Director.
The Director and the Nuclear Performance Specialists shall meet or exceed the qualifications described in Section 4 of ANSI/ANS 3.1-1987.
The NPAD shall have no direct responsibility for activities subject to its review.
J.
In Section 6.5.2.3, change "NSSD" to NPAD" in two locations.
K.
In Section 6.5.2.4.1, change "NSSD" to "NPAD".
L.
Delete the first sentence and the second sentence before the colon in Section 6.5.2.4.2 and insert:
Audits of operational nuclear safety-related facility activities shall be performed by the NPAD staff under the cognizance of the Nuclear Performance Specialists. These audits shall encompass:
M.
In Section 6.5.2.4.2.f, change "NSSD" to "NPAD."
N.* Delete "NSSD" from the last paragraph of Section 6. 5. 2. 4. 2 and insert "Director, NPAD".
- 0.
Change Section 6.5.2.4.3 to read:
NPAD review of the subjects in Specifications 6.5.2.4;1 and 6.5.2.4.2 shall be performed by an assigned Nuclear Performance Specialist selected on the basis of technical expertise relative to the subject being reviewed.
If the assigned Nuclear Performance Specialist determines the need 2
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I for interdisciplinary review, a committee consisting of the Director, NPAD, or his designate, and at least four Nuclear Performance Specialists, shall be assigned.
P.
In Sections 6.5.2.5, 6.5.2.6, 6.7.1.b and 6.7.1.d change "NSSD" to "NPAD."
II.
Discussion 3
This request changes the composition of the PRC by deleting specific titles and replacing them with a generic statement which allows the Plant General Manager to change the composition of the PRC without processing a Technical Specifications change every time a position title changes.
Members of the PRC will meet at least the equivalent of the qualifications described in ANSI 18.1-1971 and thus meet the criteria of Standard Review Plan 13.4.
The Nuclear Performance Assessment Department (NPAD} provides independent review of activities in the areas of Nuclear Power Plant Operation, Nuclear Engineering, Chemistry and Radiochemistry, Metallurgy, Instrumentation and Control, Radiological Safety and, Mechanical and Electrical Engineering.
This review was previously performed by the Nuclear Safety Services Department.
NPAD review (described in change 0 above}
will be performed by a Nuclear Performance Specialist appointed on the basis of his expertise in the area concerned.
If the appointed Nuclear Performance Specialist determines the need for additional review, the subject of the review will be further evaluated by a committee consisting of the Director, NPAD, and at least four Nuclear Performance Specialists. Thus, if review by a multi-disciplined committee is deemed appropriate by the appointed reviewer, further review is performed by committee.
This practice combines the best features of past review practices.
Both the practice of committee review and the practice of individual review have existed in the past. This proposed change combines the most effective parts of each.
As was the case previously (Section 6.5.2.3}, consultants may be used where sufficient expertise is not available within NPAD.
Second level NPAD review will no longer be required.
It has been determined that second level NPAD review.is not necessary because before being forwarded to NPAD for independent review, the subject under review will have been evaluated by the individual originating the report of the change, test, violation, abnormality, meeting or event and at least_ one other qualified individual.
Review by*one of the Nuclear Performance Specialists provides, in most cases, sufficient depth of review to assure the margin of safety.
In those cases when the Director, NPAD, or the appointed reviewer determines more depth of review is appropriate, the aforementioned committee will provide it.
Additionally, NPAD may use consultants, as described in Section 6.5.2.3, to enhance expertise on particular issues.
The requirement that NSSD staff meet or exceed the qualifications described in Section 4 of ANSI/ANS 3.1-1987 continues in effect
- v for the Director and Nuclear Performance Specialists of the NPAD staff. Thus, Section 6.5.2.2 continues to meet the acceptance criteria of Section 13.4 of the Standard Review plan.
Sections 6.5.1.6.4 and 6.10.1.c {change D) now refer to reportable events as required by Section 6.9.2 instead of as defined by Section 1.4. This change is editorial and is for clarity and consistency since both Sections 1.4 and 6.9.2 refer to 10CFR50.73.
Changes D, F, G, J, K, M and P only change the name of the reviewing or receiving department from Nuclear Safety Services Department {NSSD) to Nuclear Performance Assessment Department {NPAD).
As discussed above, this proposed Technical Specifications change does not significantly change the type of review or the skill, experience or knowledge required for effective Company review.
These changes are purely administrative.
Change G deletes required NPAD review in the areas of non-destructive testing, administrative controls, emergency planni~g and training to more closely align the function of NPAD with the function prescribed in the Standard Technical Specifications for the Company Nuclear Review and Audit Group {CNRAG).
The NPAD plans to continue to review selected items in these areas but will not be required to review all aspects pertaining to them.
Change H describe~ and prescribes the composition of the NPAD, ensures its direct access to the Nuclear Operations Vice President and requires its independence as a reviewing body.
III.
Analvsis of No Significant Hazards Consideration Consumers Power Company finds, in compliance with 10CFR50.92{c),
that activities associated with this change request involve no significant hazards.
The following evaluation supports that finding.
- 1.
Will the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
This change does not affect the probability or consequences of an accident.
The changes are to the ad~inistrative secti-0n of the TS with th~ significant changes affecting the PRC composition and changing the NSSD to NPAD.
The PRC member titles will be removed from the TS to facilitate not requiring that a TS change be submitted for NRC approval when position titles change.
PRC member qualifications will still be consistent with those described for the Plant Staff and meet or exceed ANSI 18.1-1971 as endorsed by the NRC in SRP 13.4.
The Plant General Manager*
will be required to designate the PRC members, chairman and 4
5 alternate chairmen in administrative procedures, this places appropriate authority over PRC selection. Therefore, these changes will not affect the probability or consequences of an accident.
The NPAD will continue to provide independent review.
Changes to delete certain areas in the TS where the NPAD provides independent review align the TS with the Standard Technical Specifications. The NPAD will still continue to review some activities as appropriate in the areas that have been deleted in the TS, but they will not be TS required functions. This change, although it reduces the functional requirements presently in the TS, aligns the TS to the Standard TS and does not increase the probability or consequences of an accident.
The review method of the NPAD has changed as a second level review is no longer required, but the depth of review will be enhanced as appropriate either through the past practice of use of consultants or by NPAD committee review.
The NPAD staff tasked with review of the TS required functional areas will meet or exceed the qualifications described in Section 4 of ANSI/ANS 3.1-1987 in accordance with SRP 13.4. This change also does not increase the probability or consequences of an accident.
The change to reference the reporting requirements to Section 6.9.2 is purely administrative to gain consistency throughout the technical specifications.
The changes do not affect the operation or material condition of the facility.
The accident analyses are not affected by this proposed change.
Proper review and independent oversight by qualified personnel as recommended or required by the Standard Technical Specifications, Standard Review Plan, and Administrative Procedures will be in place.
Therefore, the changes do not increase the probability or consequences of an accident.
- 2.
Will the proposed change create the possibility of a new or different kind of.accident from anY accident previously
- evaluated?
The composition of PRC and NPAD will be made up of qualified individuals providing functional reviews that are consistent with the Standard Technieal Speciftcatio~s, Standard Review Plan and administrative program requirements.
These changes and the purely administrative changes do not affect the material condition, plant operation or accident analysis and, therefore, do not create the possibility of a different type of accident than any previously evaluated.
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- 3.
Will the proposed change involve a significant reduction in the margin of safety?
The changes to PRC composition provide internal flexibility in changing the organization titles, but do not reduce the PRC function to provide review and advise the Plant General Manager on matters of nuclear safety.
The PRC is comprised of individuals from appropriate functional areas of Operations, Maintenance, Radiological Services, and Engineering Departments and will be designated in administrative procedures by the Plant General Manger.
The NPAD will continue to provide an independent overview by qualified individuals, or by committee, of the functional areas delineated in the TS.
These changes do not affect the material condition or plant operation and neither the consequences of an accident nor have the fission product boundaries have been affected. Therefore the margin of safety has not been reduced.
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IV.
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.
Further, the change involves no significant hazards consideration. This change has been reviewed by Nuclear Performance Assessment Department functionally operating as the Nuclear Performance Assessment Department.
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 To the best of my knowledge, information and belief, the contents of this Technical Specification Change Request are truthful and complete.
Sworn and subscribed to before me this 1r.d..cJ.ay of --~.,,.,....._---"7'--=-- 1991.