ML20031A286
| ML20031A286 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/03/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20031A284 | List: |
| References | |
| NUDOCS 8109220848 | |
| Download: ML20031A286 (6) | |
Text
UNITED STATES
["
' NUCLEAR REGULATORY COMMISSION g
9 E WASHINGTON, D. C. 20555
\\...../
SAFET) EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION _
SUPPORTING AMENDMENT NO. 46 TO FACILITY OPERATING LICENSE NO. DPR CONSUMERS POWER COMPANY BIG RO^K POINT PLANT DOCKET NO. 50-155
1.0 INTRODUCTION
By letter dated February 16, 1981 and supplement dated July 1,1981, Consumers Power Company (the licensee) requested an amendment to Facility Operating License No. DPR-6 for the Big Rcck Point Plant.
These filings supersede the licensee's submittalt dated July 16, August 3, and October 31, 1979. This amendment would modify the Technical Specifications tc incorporate changes to Section 6.0, Administrative Controls.
Included in these changes is the addition of a Shift Technical Advisor to the shift staffing requirements.
2.0 DISCUSSION AND EVALUATION The purpose of this evaluation is to assure that the requirements of the existing Big Rock Point Technical Specifications are tdequately included in the proposed revised Technical Specifications and that the changes do not diminish the level of safety that is provided by the existing Technical Specid :ations.
The evaluation is not directed at determining whether or not the revised administrative controls section of the Technica1. Specifications is in conformance with recently developed NRC criteria that have not yet been formally imposed on the licensee.
The evaluation was performed, to a large extent, by comparing the l
differences between the proposed wording and the wording of the most recent (September 16, i980 revision) Standard Technical Specification Section 6.0 - Administrative Controls.
The following items refer to the proposed changes in the Big Rock Technical Specifications:
A.
Figure 6.2 A new position of Vice President - Nuclear Operations has been established. All personnel involved in nuclear activities now report to him vno in turn reports to the Executive Vice President.
Previously the Manager of Production -
E109220848 810903 PDR A00';K 05000155 P
PDR l
. Nuclear reported to the Vice President - Production and Transmission.
Reporting to the new Vice President - Nuclear Operations are the Plant-Superintendent - Big Rock Point, the Director of Quality Assurance, and the General Managers of the Midland and Palisades plants (see Figure 6.2-1).
The Safety and Audit Review Board slso reports to the Vice President - Nuclear Operations. The responsibility of the overall Fire Protection Program has been assigned to the Director of Property Protection.
By integrating all nuclear power func+.ional responsibilities under a single responsible head, we find that the licensee has established an integrated organizational arrangement to provide for the overall manage-ment of nuclear power gilant operations. We, therefore, find the proposed changes acceptable.
B.
Figure 6.2 The plant organization has also undergone changes.
The positions of Operations Superintendent and Maintenance Superintendent have been combined into the position of Operations and Maintenance Superintendent.
Reporting to the Plant Superintendent are the Technical Superintendent, the Health Physicist and the Operations and Maintenance Superintendent (see Figure 6.2-2).
The Plant Superintendent is also responsible for implementation of the Plant Fir 2 Protection Program.
We find the new proposed plant organization acceptable; however, we have some reservations about combining the positions of Operation Superintendent and Maintenance Superintendents into a single position. Since Big Rock Point is a small nuclear plant (63 MWe), we find that the single position of Operations and Maintenance Superintendent is an acceptable arrangement.
l C.
Table 6.2 The change to Table 6.2-1 represents the addition of the Shift Technical Advisor (STA) to the operating staff.
He find this change acceptable as it meets the requirements of NUREG-0737, " Clarification of Till Action Plan Requirements," dated November 1980.
D.
Section 6.3.2 - The addition of a footnote on " Equivalent," as utilized in Regulatory Guide 1.8 (Prop. 2nd Revision, February 1979) is acceptable.
l E.
Section 6.3.3 - The STA shall have a bachelor's degree or equivalent 1
in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant for transients and accidents. We find that this is acceptable.
F.
Section 6.4.2 - The change made to indicate that the Director of Property Protection is responsible for maintaining the Fire Brigade Training Program
~
l is acceptable.
i G.
Section 6.5.1.2 - The change in the Plant Review Committee (PRC) to permit the Plant Superintendent to designate anotter individual to serve as PRC Chairman is acceptable, as it meets the provisions of ANSI 18.7-1976 end ANS 3.2 as endorsed by Regulatory Guide 1.33.
l i
i i
)
- l H.
Section 6.5.1.3 - The change to clarify how many alternates may participate in the PRC as voting members is acceptable.
I.
Section 6.5.1.6 - The changes recognize that the PRC Chairman could be in individual other than the Plant Superintendent and that the Vice President -
Nuclear Operations replaces the Manager of Production - Nuclear, respectively.
The change also clarifies PRC responsibilities for review of plant operations.
These changes are acceptable.
J.
Section 6.5.1.7 - Paragraph (C) states:
" Provide immediate written notification to the Vice President - Nuclear Operations...." The
. Standard Technical Specification has a different wording of Paragraph (C) as follows:
Provide within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification....."
We discussed the above item with Consumers Power Company and they agreed to change Paragraph (C) to the above wording of the Standard Technical Speci fica tion. The licensee's July 1,1981 submittal includes this change.
K. and L.
Sections 6.5.1.8 and 6.5.2.1 - These changes are editorial in nature and recognize the establishment of the Vice President - Nuclear Operaticas position and are, therefore acceptable.
3 In a letter dated July 1,1981, Consumers Power Company states that they acceot our requested modifications based on the following positions:
"Our updating to the ANSI N18.7-1976 edition for Section 6.5.2.1 is based on the NRC staff acceptance of our positions with respect to Sections 4.3.l(5) and 4.3.4(3) of ANSI N18.7.976 edition.
Our positions are as follows:
L ANSI N18.7-1976 Section 4.3.l(5)
"The Safety and Audit Review Board (SARB),will not specifically contain an individual knowledgeable in Nondestructive Testing (NDT) but will use consultants to perform this function as deternined necessary by the SARB chairman."
4.3.4(3)
"SARB will not rereview Technical Specification-changes after NRC approval prior to implementation.
Our basis for this positicn is that SARB reviews all Technical Specifications change requests prior to submi ctal to the NRC."
We have reviewed the above positions and found them acceptable. Section 4.3.1 of ANSI N18.7-1976 edition states that if sufficient expertise is not available from within the osner's org=nization, independent reviews
I
. shall be supplemented through outside consultants or organizations.
It is, therefore, not required to have an individual knowledgeable in Nondestructive Testing on the S/RB as long as this function is performed by consultants.
For the case of Section 4.3.4 we will not require SARB to rereview Technical Specification changes if these changes have already been reviewed prior to submittal to the NRC.
M.
Section 6.5.2.2 - This change clarifies the function of the Safety and Audit Review Board (SARB) and removes the ambiguity inherent in the current wording relating to " designated activities" which are not clearly designated in the current specifications.
This is acceptable.
.N.
Section 6.5.2.3 - The introductory sentence of Section 6.5.2.3 has been changes to read: " Collectively, the personnel appointed for SARB by the Vice President - Nuclear Operations shall be competent to conduct reviews in the following areas:"
Audits are conducted under the cognizance of SARB but may be conducted by other organizations and not necessary by SARB members. These changes are acceptable.
O.
Section 6.5.2.4 - Tha proposed editorial change is acceptable.
P. Q. and R.
Sections 6.5.2.8, 6.5.2.9 nd 6.5.2.10 - The 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 (6.5.2.8) and incorporated into Section 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.
The proposed Sections 6.5.2.9 and 6.5.2.10 are consistent with that in the Standard Technical Soecifications and are, therefore, acceptable.
The licensee hai taken exception to paragraph (h) in Section 6.5.2.7 of the Standard Technical specification that states: "SARB shall review: All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety."
Consumers Power Company considers that all deficiencies which might be reviewed under this requirement would already require review under other existing requirements. Accordingly, Consc,ers Power Company has decided not to include this requirement ir. the Big Ros x Point Technical Speci fi cations.
We find the deletion acceptable as the proposed Section 6.5.2.8 meets or exceeds the. intent of the Standard Technical Specification.
S.
Section 6.5.2.11 - The p*oposed editorial changes are acceptable.
I
. T.
Section 6.6 (Reportable Occurrence Action) has been deleted because it has been found redundant to requirements in other sections. This.section has also previously been deleted from the Palisades Technic'al Specifications.
We find the deletion acceptable.
U.
Section 6.7.1 - Paragraph (a) states:
"The reactor shall be shut down ime.ejiately and not restarted until the Commission authorizes resumption of operation." The Standard Technical Specification has a different wording of Paragraph (a), as follows:
"The unit shal t be placed in at least Hot Standby within one hour."
We find the proposed chance acceptable.
Paragraph (b) of Section 6.7.1 states:
"The safety limit violation shall be reported immediately to the Commission in accordance......" The Standard Technical Specification has a different wording of Paragraph (b),
as follows:
"The NRC Operations Center shall be notified by telephone as soon as possible ar.d in all cases within one hour."
We discussed the above item with Consumers Power Company and they agreed to change Paragraph (b) to read as follows:
"The safety limit violation shall be reported within one hour to the Commission in accordance....."
This charge is included in the licensee's July 1,1981 submittal.
Paragraph (d) of Section 6.7.1 states: "The report shall be submitted within ten days to the Commission.."
The Standard Technical Specification allows 14 days for the submittal to the Commission.
Consumers Power Company will, therefore, change Paragraph (d) to read:
"The report shall be subnitted within 14 day to the Commission...." Thi: change is included in the licensee's July 1,1981 submittal.
V.
Sections 6.8.1 and 6.8.2 - Section 6.8.1 stated in part:
"These procedures shall meet or exceed the requirements of ANSI -18.7."
The Standard Technical Specifications, Section 6.8.1, Paragraph (a) reads:
"The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, Fcbruary 1978" (endorses N18.7-1976).
We discussed the above item with Ccasumers Power Company and they agreed to change the above to:
"These procedures shall meet or exceed the require-ments of ANSI 18.7-1976." This change is included in the licensee's July 1,1931 submittal.
The change in Section 6.8.2 is acceptable.
~.
~
3.0 ENVIRONMENTAL CONSIDERATION
~
We have determined that.the amendment does not authorize a change in-effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.
Having made this determination, we have further concluded that the amendment involves an action which is insignificant j
from the standpoint of environmental. impact and pursuant to 10 CFR 151.5(d)(4) that an environmental impact statem'ent or negative declaration and environmental t
impact appraisal need not be prepared in connection with the issuance'of this amendment.
4.D CONCLUSIONS We have concluded, based on the considerations discussed above, that: (1) because the amendment doesnot involve a significant increase in the pro-bability or consequences of accidents previously considered and does not I
involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reason 6ble assurance that the health and safety of the public will not be endangered oy operation in the proposed manner, and -(3) such activities will be con-i ducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to l
the health and safety of the public.
i l
Date: September 3, 1981 l
l l
l ll 4
,.