ML20028A315
| ML20028A315 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 11/12/1982 |
| From: | Reynolds J CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML18047A666 | List: |
| References | |
| NUDOCS 8211180234 | |
| Download: ML20028A315 (4) | |
Text
r SECTION I CONSUMERS P0h'ER COMPANY PALISADES PLANT REQUEST FOR CHANGE TO THE PALI 3AN.S TECHNICAL SPECIFICATIONS November 5, 1982 nu1182-0139a142-155 3 pages
(~B2111Sd234 E521112 l
~
l PDR ADOCK 05000155 P
g 1
CONSUMERS POWER COMPANT DOCKET 50-255 i
REQUEST FOR CHANGE TO THE TECHNICAL SPECIFICATIONS LICENSE DPR-20 P
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.
Add Section 6.2.3 B.
Revise Sections 6.5, 6.7 and 6.8 C.
Delete Section 6.8.4 Revised Technical Specifications pages are attached asSection II.
Prorosed changes are shown by a vertical line in the right-hand margin.
II.
DISCUSSION Consumers Power Company intends to implement a coordinated approach to the safety review function. The plan encompasses NUREG-0737, Item I.B.1.2, " Independent Safety Engineering Group" as well as the onsite and offsite review committees required by the Technical Specifications.
Consumers Power Company was motivated to re-evaluate its safety review policy by three principal factors. First was the the Regulatory i
Improvement Program currently underway at Palisades, second was a perception of a significant increase in workload for the offsite review board associated with Midland, and last was a study conducted by MAC.
The MAC study found, among other comments, that the Plant Review Com-mittees' carried an extremely high workload, and that required supple-mental reviews caused this workload to cascade throughout the review process.
This high workload and the composition of the review commit-tees (Senior Line Managers) has the potential to detract from the quality of safety reviews and/or the effectiveness of plant management.
The proposed new scheme involves significant changes to the Administra-tive Controls Section of each of the plant's Technical Specifications.
i These particular sections of the Technical Specifications are nearly identical for all three plants. Some differences, however, do exist.
The new organizational structure involves the creation of a new depart-ment titled " Nuclear Activities Plant Organization" (NAPO) headed by an Executive Engineer. The Company safety review organization also includes the Nuclear Safety Board (NSB) as the offsite review committee and a Plant Review Committee (PRC) at each plant.
nu1182-0139bl42-43 i
4 2
The NAPO will report to the Vice President-N0D through the Executive Director, Nuclear Activities.
It consists of the Executive Engineer and supporting staff at the General Office and staff at Palisades and -
Midland. NAPO support for Big Rock Point will ba through a small onsite staff or from other parts of the NAPO. The intention of this organization is to permit the NAPO staff on site to act as a technical resource to the PRC by performing safety reviews and assisting PRC in completing other PRC responsibilities.
(Concurrence of the Executive Engineer - NAPO is required as detailed in the proposed Technical Specifications.) This organization will also perform independent safety appraisals, trend plant performance and generally perform those functions described in NUREG-0737, Item I.B.1.2.
This organization reports off site and is therefore independent of direct line responsi-bilit3 for operating the plant although total independence from operating pressures is recognized to be difficult to attain.
The NAPO staff will also snrve as a technical resource to the NSB.
Since NAPO will be a single entity, individuals with specific experi-ence/ qualification levels will be available to support NSB reviews at all plants regardless of their permanent "home" location.
Providing this resource for PRC and NSB serves two purposes. First, it elevates the review committees from a level of issue identifiers to one of issue resolvers. Key safety issues can thus be addressed more effectively, better utilizing the talents of the senior and experienc.ed managers who serve on these committees. Secondly, the full-time avail-ability of NAPO will permit safety reviews to be conducted in more detail than is possible using part-time PRC and NSB members.
Specific issues not addressed above include:
A.
Control of NAPO activities will be exercised by the NSB. NAPO will be expected to report to the NSB at regular intervals (approximately quarterly) regarding ongoing safety evaluations, problems identified, etc.
B.
As stated in Section 6.5.1.7, the PRC organization is required to make determinations and recommendations of items considered under 6.5.1.6, a through e, with regard to the issues stated. The PRC, however, may utilize reviews conducted by NAPO or any other technical resource.
C.
Independence from plant management will be fostered by development of career paths not dependent on plant management experience, and by personnel selection.
D.
The requirement of a five member onsite NAPO staff is not effective until January 1, 1983. At the present time the onsite NAPO consists of three members whose qualifications meet the requirements of Section 6.2.3.3.
nu1182-0139bl42-43
3 E.
The' requirements of 10 CFR 50.54(t) for an independent review of the emergency preparedness program at least every 12 months (Generic Letter 82-17) are addressed under Item d, Section 6.5.2.8.2.
III. CONCLUSION Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Review Board have concluded that these changes do not involve an unreviewed safety question.
CONSUMERS POWER COMPANY By J W g olds, Executive Vice President Energy Supply Sworn and subscribed to before me this 12th day of November 1982.
6 O
C )
IIelen I Dempski, Noyfiry Public Jackson County, Michigan My commission expires December 14, 1983.
nu1182-0139bl42-48
~.
4 4
1 1
T i
i i
.i i
l 4
i 4
i SECTION III r
a CONSUMERS POWER COMPANY-4-
BIG ROCK POINT PLANT REQUEST FOR CHANGE TO THE BIG ROCK POINT TECHNICAL SPECIFICATIONS I,
1 November 5, 1982 1'
i.
i 4
i e
i 4
1-i 1
f I
I i
)
i 1
I J
I l
5 I
i 2
t 1
1-nu1182-0139a142-155 2 pages i
i
)
~., --.,. _, _
..,._,,.m,......--____.-...
._.-..m.,
- ~
1 CONSUMERS POWER COMPANY-Docket 50-155 Request for Change to the Technical 5,3ecifications License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical Specifications 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 Revise Sections 6.5, 6.7 and 6.8.
The subsections of each are also included.
Revised Technical Specifications pages are attached asSection IV.
Proposed changes are shown by a vertical line in right-hand margin.
1 II.
Discussion A.
The entire " Discussion" section of the attached Palisades Technical Specifications Change Request is also applicable to Big Rock Point with the exception that there may not be an onsite NAPO staff at Big Rock Point.
I The reasons for not requiring an onsite NAPO staff at Big Rock Point are twofold. First, Big Rock Point is a small, simple plant with relatively few p.ac.edures, systems and modifications; also, it is a relatively mature roullity where the number of future modifications /
operational changes is expected to be low. Second, an independent safety group already exists in the form of the Continuing Risk Management Program (CRIMP). This group consists of three personnel and reports to the Reactor Engineering Department (General Office).
Their purpose is to utilize risk assessment techniques to ovaluate I
plant performance, proposed modifications and operating experience using the existing PRA as a tool. The reporting relationship of the CRIMP Group will not be changed, but it will be expected to work closely with NAPO and assist in the technical resource aspects of the NAPO function.
4 B.
The Plant Health Physicist " title" is no longer used at Big Rock Point and the individual is now classified as the Chemistry and Health Physics Superintendent. This change is reflected in Sections 6.3.2 and 6.5.1.2.
C.
Sections 6.3 and 6.5.1.2 reflect the elimination of the Shift Technical Advisor from the shift and placing him on a 24-hour on-call basis, as proposed by Consumers Power Company's Technical Specifications Change Request dated June 25, 1982.
l l
1 nu0782-0010bl42-43 4
,,-_-__-m.-
,.m..
---.. m---
~
.--.-.~------<---4
- - - - - - - - - - ~
III.. Conclusion Based on the foregoing, both the Big Rock Point Plant Review Committee and the Safety and Audit Review Board have concluded that these changes do not involve an unreviewed safety question.
CONSUMERS POWER COMPANY
/
By 1
J W R6FHolds, Executive Vice P' resident -
Energy Supply Sworn and subscribed to before me this 12th day of November 1982.
vt_.)
41 Helen I Dempski, Notarpf Public Jackson Ccunty, Michigan My commission expires December 14, 1983.
nu0782-0010bl42-48