ML19345F755
| ML19345F755 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 02/16/1981 |
| From: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML19345F751 | List: |
| References | |
| NU0281-0214A-43, NU281-214A-43, NUDOCS 8102190223 | |
| Download: ML19345F755 (11) | |
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j CONSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications 4
License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical SpecificatJons contained in the Facility Operating License DPR-6, Docket 50-155, issued to Consumers Power Company on May 1, 1964, for the Big Rock Point Plant be changed as described in Section I below:
I.
Changes NOTE: These proposed changes involving Administrative ' Controls, Sec-tion 6.0 incorporate new changes and applicable portions of those changes requested by our submittals dated July 16, 1979, August 3, 1979, and October 31, 1979.
A.
Figure 6.2-1 Replace with revised Consumers Power Coepany Off-Site Organization, Figure 6.2-1.
(See attached page changes.)
B.
Figure 6.2-2 i
Replace with revised Consumers Power Company Plant Organization, Figure 6.2-2.
(See attached page changes.)
C.
Table 6.2-1 Add to the minimum shif t crew for normal reactor operation the Shift Technical Advisor as follows:
"I Shift Technical Advisor (STA) - Nonlicensed."
Change the title for Paragraph (a) to read:
"a.
Cold Shutdown and Shutdown (as Defined by Section 1.2)."
D.
Section 6.3.2 Add footnote (1) at the end of Section 6.3.2 after " September 1975" and include footnote (1) at the bottom of the page as follows:
I
"(1)For the purpose of this section, " Equivalent," as utilized in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following:
(a) formal schooling in science or engineering, or (b) operational or technical experience / training in nuclear power."
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E.
Section 6.3.3 Add new Section 6.3.3 which reads:
"The Shift Technical Advisor (STA) shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents."
F.
Section 6.4.2 Replace the words "under the direction the Plant Training Coordinator" with "under the direction of the Director of Property Protection."
G.
Section 6.5.1.2 Change Section 6.5.1.2 to read:
"6.5.1.2 COMPOSITION The PRC shall be composed of the:
Chairman: Plant Superintendent or Designated Alternate Member:
Operations and Maintenance Superintendent Member:
Technical Superintendent Member:
Maintenance Superintendent or Engineer Member:
Operations Superintendent or Supervisor Member:
Instrument and Control Supervisor or Engineer Member:
Reactor Engineer Member:
Health Physicist Member:
Shift Supervisor Member:
Technical Engineer or Nuclear Safety Technical Engineer Member:
H.
Section 6.5.1.3 Insert the words, "as voting members," in the phrase, "...partici-pate as voting members in PRC activities at any one time."
l I.
Section 6.5.1.6 Change Paragraph 6.5.1.6.a to read:
(
"a.
Review of:
(1) All procedures required by Technical Speci-fication 6.8 and changes thereto, and (2) any other proposed procedures or changes thereto as determined by the PRC Chairman to affect nuclear safety."
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3 Change Paragraph 6.5.1.6.e to read:
4 "e.
Investigation of all violations of the Technical Specifica-tions. A report shall be prepared covering evaluation and recommendations te prevent recurrence and forwarded to the Vice President-Nuclear Operations (NO) and to the Chairman of the Safety and Audit Review Board (SARB)."
Change Paragraph 6.5.1.6.f to read:
f. Review of plant operations to detect potential nuclear safety i
hazards."
Add new Paragraph 6.5.1.6.1 which reads:
"i. Review of all events which are required by NRC Regulation. or Technical Specifications to be reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
J.
Section 6.5.1.7 Change Paragraph 6.5.1.7.a to read:
"a.
Recommend in writing to the Plant Superintendent approval or disapproval of items considered under 6.5.1.6(a) through (d) above."
Change Paragraph 6.5.1.7.c to read:
"c.
Provide immediate written notification to the Vice President--
Nuclear Operations and the Chairman of SARB of disagreements between the PRC and the Plant Superintendent. However, the Plant Superintendent shall have responsibility for resolution of such disagreements pursuant to 6.1.1 above."
K.
Section 6.5.1.8 Replace the words " Manager of Production, Nuclear" with "Vice President-Nuclear Operations."
L.
Section 6.5.2.1 Change Section 6.5.2.1 to read:
"SARB is responsible for maintaining a continuing examination of designated plant activities.
In all cases, where a matter is formally considered by SARB, its findings and recommendations are communicated in writing to the Vice President-Nuclear Operations (NO) and other appropriate levels of management. A written charter is prepared and approved by the Vice President-NO which designates the membership, authority and rules for conducting the meetings.
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"SARB membership, qualifications, meeting frequency, quorum, responsibilities, authority and records are in accordance with the nuclear plant Technical Specifications and ANSI N18.7-1972."
M.
Section 6.5.2.2 Change Section 6.5.2.2 to read:
"SARB shall function to provide independent review of designated activities in the areas specified in 6.5.2.3."
N.
Section 6.5.2.3 Change the introductory sentence of Section 6.5.2.3 to read:
" Collectively, the personnel appointed for SARB by the Vice President-NO shall be competent to conduct reviews in the following areas:"
0.
Section 6.5.2.4 Replace the words "Vice President-P&T" with "Vice President-NO."
P.
Section 6.5.2.8 Change Paragraph 6.5.2.8.d to read:
"All events which are required by regulations or Technical Specifi-cations to be reported to the NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and other violations (of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements or of internal procedures or instructions) having nuclear safety significance."
Delete Paragraphs 6.5.2.8.f, g, h and i.
Add new Paragraph 6.5.2.8.f which reads:
"f.
The results of actions taken to correct deficiencies identified by the audit program specified in Section 6.5.2.9 at least once every six months."
Q.
Section 6.5.2.9 Change Section 6.5.2.9 to read:
"6.5.2.9 AUDITS Audits of operational nuclear safety-related facility activities shall be performed under the cognizance of SARB. These audits shall encompass:
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a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
b.
The perfcrmance, training and qualifications of t ?
h entire facility staff at least once per 12 months.
c.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 10 CFR 50, at least once per 24 months.
d.
Tne facility Site Emergency Plan and implementing procedures at least once per 24 months.
The facility Security Plan and implementing procedures e.
(as required by the Security Plan) at least once per 24 months.
f.
Any other area of facility operation considered appropriate by SARB or the Vice President-NO.
g.
The facility 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 off-site 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.
Audit reports encompassed by 6.5.2.9 above shall be forwarded to the Vice President-N0 and management j
positions responsible for the areas audited within thirty (30) days after completion of the audit."
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i R.
Section 6.5.2.10 Replace the words "V1 o President-P&T" with "Vice President-NO."
l S.
Section 6.5.2.11 l
Change Paragraph 6.3.2.11.a to read:
" Minutes of each SARB meeting shall be prepared and' forwarded to the Vice President-N0 and each SARB member within approximately two nu0281-0214a-43 I
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" weeks following the meeting. Minutes shall be approved at or before the next regularly scheduled meeting following the distribution of the minutes."
Change Paragraph 6.5.2.11.b to read:
"If not included in SARB meeting minutes, reports of reviews encompassed by Section 6.5.2.8 above shall be prepared and forwarded to the Vice President-N0 within approximately two weeks following completion of the review."
Delete Paragraph 6.5.2.11.c.
T.
Section 6.6 Delete Section 6.6.
U.
Section 6.7.1 Change Paragraph 6.7.1.a to read:
"a.
The reactor shall be shut down immediately and not restarted until the Commission authorizes resumption of operation (10 CFR 50.36(c)(1)(1))."
Change Paragraph 6.7.1.b to read:
"b.
The Safety Limit violation shall be reported immediately to the Commission in accordance with 10 CFR 50.36 to the Vice President-N0 and to SARB."
Change Paragraph 6.7.1.d to read:
"d.
The report shall oe submitted within 10 days to the Commission (in accordance with the requirements of 10 CFR 50.36) and to the Vice President-N0 and to SARB."
V.
Section 6.8.2 Replace the words " Company Security Department" with " Company Property Protection Department."
NOTE: Revised Technical Specifications pages are attached. All changes are denoted by a vertical line in the right margin.
II.
Discussion The above proposed Technical Specifications changes are requested to update and clarify the Administrative Controls Section o.0.
These changes consolidate the currently applicable portions of those changes requested by our submittals dated July 16, 1980, August 3, 1979 and nu0281-0214a-43
7 October 31, 1979, and incorporate Shift Technical Advisor (STA) and other recent changes in our Organization. The intent of the requested changes is to bring the Big Rock Point Technical Specifications into closer agree =ent with those of our other plants and the Standard Technical Specifications.
The requested changes reflect an increased e=phasis placed on Nuclear Operations by Consu=ers Power Cocpany. Manage =ent changes at both the corporate (election of Vice President-Nuclear Operations) and the plant (assign =ent of a Plant Superintendent / Manager and an Operations and Maintenance Superintendent) level are intended to provide a higher degree of =anage=ent awareness and participation in the operation of Consu=ers Power Co=pany's nuclear facilities. A specific co=parison of the Big Rock Point Plant organination titles to those of ANSI N18.1-1971 has been previously provided by our sub=ittal dated August 3, 1979.
This change also incorporates the require =ent for a Shift Technical Advisor (STA) as part of the operating staff in accordance with NRC letters dated July 2, 1980, October 31, 1980 (NUREG-0737) and January 7, 1981.
So=e of the previous Consu=ers Power sub=ittals addressing the STA are dated Septe=ber 25, 1980 and Dece=ber 19, 1980 (response to NUREG-0737). The incorporation of the STA in Table 6.2-1 is =ade on the basis that this require =ent =ay be fulfilled by different alte rnatives.
Currently, the STA require =ent is fulfilled by STAS being a part of the nor=al operating shif ts (ie, 8-hour shif ts).
Consu=ers Power reserves the right to =odify the STA staffing as allowed by NUREG-0737 by changing the STA duty hours but in so doing will assure that an STA is on site and available on a 24-hour continuous basis during the required plant conditions.
The following,'rovides explanation of the individual change requests, using the lettet designations of Sect'.on I:
A.
Figure 6.2-1 The changes in this : we represent the establish =ent of a Vice President-Nuclear Operati ns (NO) and the assign =ent of responsi-bility to the Director of Property Protection for the everall Fire l
Protection Progra=.
B.
Figure 6.2-2 The changes in this figura represent the current plant =anage=ent organination and the assign =ent of responsibility to the Plant Superintendent for the i=ple=entation of the Plant Fire Protection Progra=.
C.
Table 6.2-1 The changes in this table represent the addition of the Shift Technical advisor (STA) to the operating staff and provide clarifi-cation for the plant condition specified in paragraph (a).
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a D.
Section 6.3.2 The added footnote is identical to that in the current Technical Specifications for our Palisades Plant and is added for clarity and consistency.
E.
Section 6.3.3 The added section provides a description of the qualifications of an STA.
i F.
Section 6.4.2 This change is made to indicate that the Director of Property Protection is responsible for maintaining the Fire Brigade Training Program.
G.
This change permits the Plant Superintendent to designate another individual to serve as PRC Chairman (identical to the Palisades Technical Specifications).
It also incorporates the current manage-ment titles of those personnel from which the PRC is typically comprised.
H.
Section 6.5.1.3 This change is made to clarify how many alternates may participate in PRC as voting members.
I.
Section 6.5.1.6 The changes for paragraphs a and e recognize that the PRC Chairman could be an individual other than the Plant Superintendent and that the Vice President-NO replaces the Manager of Production-Nuclear, respectively. The change for paragraph f clarifles PRC responsi-bilities for review of plant operations to detect potential safety problems by specifying that this concern relates to nuclear safety as opposed to, for example, industrial safety concerns covered by the Occupational Safety and Health Act.
This is identical to the l
Palisades Technical Specifications and the~ Standard Technical Speci-fications. The change for paragraph i transfers the current requirement of Section 6.6.1.b to this section.
t J.
Section 6.5.1.7
[
These changes are editorial in nature and recognize the establish-i ment of the Vice President-NO position.
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9 K.
Section 6.5.1.8 This change recognizes the establishment of the Vice President-NO position.
L.
Section 6.5.2.1 See discussion for Section 6.5.1.8(k).
M.
Section 6.5.2.2 This change clarifies the function of SARB asd removes the ambiguity inherent in the current wording relating to " designated activities" which are not clearly designated in the current specifications.
N.
Section 6.5.2.3 This change deletes the requirement that CARB members collectively be competent to conduct " technical audits" in the listed areas.
This requirement is inherently a part of the requirement that SARB members be collectively competent to conduct reviews in these areas.
The specific reference to audits is deleted to avoid the possible misinterpretation that SARB members are therefore required to perform audits; in f act, audits are conducted under the cognizance of SARB (as specified in Section 6.5.2.9) but may be conducted by other organizations and not necessarily by SARB members. This change also recognizes the establishment of the Vice President-NO position.
O.
Section 6.5.2.4 See discussion for Section 6.5.1.8(k).
P.
Section 6.5.2.8 The change for paragraph d involves the addition of parentheses for clarity. The changes involving the deletion of existing para-graphs f, g, h and i ind the addition of new paragraph f are made to simplify Sections 6.5.2.8 and 6.5.2.9.
These changes consolidate all requirements for audits in a single section (6.5.2.9).
Four separate audit requirements are deleted from the tabulation of SARB review functions (Sections 6.5.2.8) and incorporated iu6v 0..
tion 6.5.2.9; these specific requirements in Section 6.5.2.8 are replaced with a general requirement that SARB review actions to correct deficiencies found in all audits of Section 6.5.2.9.
Addi-tional changes are made in the revised Section 6.5.2.9 to delete the specific designation of responsibility for various audits thereby providing greater flexibility for use of all technical resources within Consumers Power Company for performing audits. The proposed Section 6.5.2.9 is consistent with that in the Standard Technical Specifications.
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Section 6.5.2.9 See discussions for Sections 6.5.2.8(p) and 6.5.1.8(k).
R.
Section 6.5.2.10 See discussion for Section 6.5.1.8(k).
S.
Section 6.5.2.11 The shanges for paragraphs a and b are editorial in nature in that they recognize the establishment of the Vice President-NO position and change the time period for submittal to approximately two weeks which is consistent with the present Palisades Technical Specifi-cations. Paragraph c is deleted because it was incorporated in the revised Section 6.5.2.9(Q).
T.
Section 6.6 Section 6.6 is redundant to requirements in other sections, such as Section 6.5.1.6(I).
Therefore, this request deletes this section in its entirety. This section has been previously deleted from the Palisades Technical Specifications.
U.
Section 6.7.1 1
These changes provide clarification and also denote the establish-ment of the Vice President-Nuclear Operations.
V.
Section 6.8.2 This change is edirnriel ir nature and only serves to provide the correct department title.
i Consumers Power Company takes exception to one specific requirement of Section 6 of the Standard Technical Specifications. This requirement is that which states SARB "shall review...all recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components." Consumers Power Company considers this requirement to be so ambiguous that it could not be administered properly. Furthermore, Consumers Power. Company considers that all deficiencies which might be reviewed under this requirement. auld already require review under other existing require-ments; for example, most such deficiencies now require reporting under l
Section :.9.2.a(9) and therefore review by SARB under Section 6.5.2.8.d.
C a;.umers Power Company has attempted to obtain examples from the NRC staff of deficiencies which would require review under the Standard Technical Specifications requirement cited above which would not require review under other Technical Specifications requirements; the staff has l
been unable to provide any such examples. Accordingly, Consumers Power l
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Consumers Power Company has decided not to include this requirement in the Big Rock Point Technical Specifications.
III. Conclusions Based on the foregoing, both the Big Rock Point Plant Review Committee and the Safety and Audit Review Board have reviewed these changes and find them acceptable.
CONSUMERS POWER COMPANT
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6 By 4 R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 16th day of February 1981.
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Linda K Carstens, Notary Public Jackscn County, Michigan My commission expires June 10, 1981.
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