ML20058E388
| ML20058E388 | |
| Person / Time | |
|---|---|
| Site: | Palisades, Big Rock Point, 05000000 |
| Issue date: | 07/20/1982 |
| From: | CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | |
| Shared Package | |
| ML20058E381 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.B.1.2, TASK-TM NUDOCS 8207280199 | |
| Download: ML20058E388 (4) | |
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SECTION I CONSUMERS POWER COMPANY PALISADES PLANT REQUEST FOR CHANGE TO THE PALISADES TECHNICAL SPECIFICATIONS i
July 20, 1982 i
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8207280199 820720 PDR ADOCK 05000155 P
PDR nu0782-0010c142 3 pages
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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 Provicional 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.
The subsections of each are also included.
C.
Delete Section 6.8.h.
This section is now incorporated in Sections 6.8.1 and 6.8.2.
NOTE: Revised Technical Specification pages are attached asSection II.
Proposed 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 funtion involving all three plants. 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 Technical Specifications.
Consumers Power Company was motivated to reevaluate its safety review policy by three principal factors.
First was the Regulatory 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 Committees' carried an extremely high workload, and that required supplemental reviews caused this workload to cascade throughout the review process. This high workload and the composition of the review committees (senior line managers) has the potential to detract from the quality of safety reviews, and/or the effectiveness of plant management.
The proposed new s'cheme involves significant changes to the Administrative Controls Section of each of the plant's technical specifications. These particular sections of the Technical Specifications are almost identical for all three plants. Minor differences may exist, but the organizational structure and review requirements will be the same. Section 3 provides a Table which compares our proposed Technical Specifications with the Standard Technical Specifications for the Unit Review Group and Company Nuclear Review and Audit Group.
Comments have been provided where our proposed Technical Specifications are not equivalent to the Standard.
Palisades Plant - DPR-20 2
Request for Change to the Tech Specs July 20, 1982 II.
DISCUSSION (Con't)
On May k, 1982, Consumers Power. Company discussed ~our overall approach to safety review with the NRC Staff in Bethesda.
Our Presentation was conducted with the use of the overhead projector and the slides shown are attached asSection IV.
Section IV provides an overview of major concerns with our present organization and the concept of the proposed new organization.
It should be noted that in this enclosure the organizational title " Nuclear 4
i Activities Department On-Site" (NADO) has been changed since the May h, 1982 meeting and should now read as " Nuclear Activities Plant Organization" (NAPO).
The new organizational structure involves the creation of a new department I
titled " Nuclear Activities Plant Organization" (NAPO) headed by an Executive Engineer. The Company safety review organization also includes the Nuclear Safety Board (NSB) (offsite review committee) and the Plant Review Co=mittee (PRC) at each plant.
The NAPO department will report to the Vice President through the Executive Director, Nuclear Activities.
It details a small staff supporting the Executive Engineer at the General Office and a Staff at each of the three plants reporting to the Executive Engineer. The intention of this organization is to permit the NAPO Staff on site to act as a technical resource to the PRC performing safety reviews on request and relieving PRC of responsibility for handling routine matters such as event reporting (the PRC Chairman's concurrence in the results of these reviews vill be required as detailed in the proposed Technical Specifications).
This group will also perform independent safety appraisals, trend plant performance and generally perform those functions described in NUREG-0737, Item I.B.l.2.
The group reports offsite and is thus independent of direct line responsibility for operting the plant although total independence from operating pressures is recognized to be difficult to attain.
The NAPO Staff vill also serve as a technical resource to the NSB.
l Since NAPO vill be a single entity, individuals with specific experience / qualification levels vill 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 i
experienced managers who serve on these committees. Secondly, the l
full time availability of NAPO vill permit safety reviews to be conducted in more detail than is now possible using part-time PRC members.
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Palisades Plant 3
Request for Change to the Tech Specs July 20,1982 II.
DISCUSSION (Con't)
The Staffing targets for NAPO at each location are detailed in.
At Palisades and Midland, ultimate staffing vill be approximately 10 while at Big Rock Point the NAPO group will be a single individual.
Specific issues not addressed above include:
a.
Control of NAPO activities will be exercised by the NSB and NAPO vill be expected to report to the HSB at regular intervals (approximately quarterly) regarding ongoing safety evaluations, problems identified, etc.
b.
As stated in Section 6.5.1.h.a, the PRC organization is required to make determinations and recommendations of items considered under 6.5.1.3 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 and by personnel selection.
d.
NAPO staff vill have one vote on the PRC. This was deemed appropriate to establish NAPO responsibility and authority.
The format for Sections 6.2.3 through 6.8.3 has been modeled after the Standard Technical Specifications.
Future Technical Specification change submittals for Section 6 vill be formatted similarly.
III.
CONCLUSION Based on the foregoing, both the Palisades Plant Review Co=mittee and the Safety and Audit Review Board have concluded that these changes do not involve an unreviewed safety question.
CONSl' VERS POWE COMPANY
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R B DeWitt, Vice President Nuclear Operations Sworn and subscribed to before me this 20th day of July 1982.
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' Helen I Dempski, Notary / Public Jackson County, Michigan My commission expires December 1k,1983.