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UNITED STATES i
8-t NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS l
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- WASHINGTON, D. C. 20888 May 17, 1982 MEMCRANDUM PUt:
Membe FRCM:
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, Reactor Engineer StBJECT:
MID[AND PLWP SAFETY REVIEW GROUPS
-Se Consumers Power Company (CPCo), which will have its application to operate Midland Plant Units 1 & 2 reviewed by the full ACRS in June 1982,.
intends to implement a coordinated approach for satisfying safety review requirements at Big Rock Point, Palisades, and Midland.
CPCo acknowledges the extremely high workload on the three Plant Review Committees (PRC's) and the fact that required supplemental reviews cause this workload to cascade throughout the review process. CPCo is concerned that the magnitude of the workload and the composition of the review com-mittees (senior line managers) might combine to detract from the quality of safety reviews, the effectiveness of plant management, or both.
Se proposed new scheme involves creation of a raw department titled the Nuclear Activities Department Onsite (NADO). % is new department will be headed by an Executive Engineer. Se Executive Engineer will report to the VP of Nuclear Operations through the Executive Director of Nuc1 car Activities. A small Staff will support the Executive Engineer at the Gen-eral Office plus there will be a Staff at each of the three plants reporting l
to the Executive Engineer (the size of the plant based staff will vary from i
plant to plant). Se Company's safety review organization also includes the Nuclear Safety Board (NSB) (offsite review committee) and the PRC (onsite i
review comunittee) at each plant.
CPCO's intention is to permit;the NADO Staff onsite 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 Olairman's concurrence in the results of these reviews will be re-i his group will also perform independent safety appraisals, trend quired).
P plant performance, and generally perform those functions called out in -
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~ 1MI Action Plan, NUREG-0737, Item I.B.l.2. (Independent Safety Engineering Grog (ISEG) ~ requirement). %e group reports offsite and is thus indepen-l-
dont of direct line responsibility for operating the plant although total ~
l independence from operating pressures is recognized to be difficult to attain L
in a utility.
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'the 1900 Staff will also serve as a technical resource to the ISB.
Since the Department will be a single entity, individuals with specific resources would be available to support NSB reviews at all plants regard-less of their permanent "home" location.
CPCo believes that providing this resource for PRC and NSB will serve two purposes. First it will elevate the review committees from a level of issue identifiers to one of issue resolvers. Key safety issues could thus be addressed more effectively, better utilizing the talents of the senior and
- experienced managers t o serve on these' committees. Secondly, the full
- time availability of NADO would permit safety reviews to be conducted in more detail than.is now possible using part time PRC members.
- I.would like to point out that the projected staffing for the NADO organi-zation at each location is:
Midland 10 Palisades 10 Big Rock Point 1
. [ Recall, that operating plants are not currently required to have an ISEG.]
~ Noting that Big Rock Point has a Continuing Risk Management Program (CRIMP) staffed by 3 people which functions sort of like an ISEG, one NADO person onsite might be appropriate.- At any rate, the 3 CRIMP people basically u n-age Big Rock's ongoing PRA.
It might be interesting to have Midland address
. how its PRA will influence the composition of its' NADO Staff.
Familiarity with Midland's safety review organization will assist you in your review during both the May 20-21 Subcosmittee and June full committee meetings.
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Attachment:
CPCo Summary of May 4, 1982 Meeting re Midland's approach to safety review.
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cc:. R..Fraley M. Libarkin J. McKinley
' K. Kirby ACRS Consultants:
P. Davis P. Pomeroy-R. Scavuzzo
- E. Epler'
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W. Lipinski F. Parker
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&Y, MEETING
SUMMARY
May 4, 1982 Bethesda, Maryland A meeting was held between Consumers Power Company (CPCo) and the NRC Staff in Bethesda on May 4, 1982. The meeting was held at the request of CPCo to permit a discussion of our overall approach to. safety review.
1This plan encompasses NUREG-0737. Item I.B.I.2, " Independent Safety Engineering Group" as well as the onsite and offsite review committees required by Technical. Specifications.
CPCo intends to implement a coordinated approach to the safety review function involving all three plants, Big Rock Point, Palisades, and Midland.
The CPCo presentation was made by David Bixel; slides used during the presentation are attached as Enclosure 1.
Prior to the meeting, draft portions of Section 6 " Administrative Controls" of the Midland Technical Specifications and a table comparing them to the current B&W Standard Techrical. Specifications (NUREG-0103, Revision 4) had been provides for informal review by the Licensee Qualification Branch. The portions provided were those which would relate to the proposed new safety review
. policy; similar Technical Specifications would be required at each of the other plants. Minor differences may exist in the final Technical Specifications for the three plants due to plant unique features or differing basic requirements, but the Midland draft adequately describes the organizational structure and review requirements. The Midland draft specifications are attached as Enclosure 2.
The attendees are listed in.
d CPCo was motivated to reevaluate its safety review policy by three principal factors. First was the Regulatory Improvement Program currently E
. 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 Management Analysis Corporation (MAC). A major finding of the st'udy was that the Plant Review Committees (PRC's) carried an extremely high workload, and that required supplemental reviews caused this workload to cascade throughout the review process.
CP_Co;was concerned that the magnitude of the workload and the comp ~osition of the review committ"ees (senior line"manageiWciould combine 'to detiact'from the
. quality of safety review, the effectiveness of plant manageme,nt, ir_both.
-The proposed new scheme involves creation of a new' department titled Nuclear Activities Department Onsite (NADO) headed by an Executive Engineer (Mr. Bixel). This department will report to the VP of Nuclear Operations through the Executive Director of Nuclear Activities. The NADO organization chart is included in Enclosure 1.
It details a small Staff supporting Mr. Bixel at the General Office and a Staff at each of the three plants reporting to Mr. Bixel (the size of this Staff varies as discussed below). The Company safety review organization also includes the Nuclear Safety Board (NSB) (offsite review committee) and the PRC (onsite review committee) at each plant.
The intention of this organization is to permit the NADO 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 4.
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these reviews would be required as detailed in the draft Technical Specifications). This group would also perform independent safety appraisals, trend plant performance, and generally perform those functions called out in Item I.B.l.2.
The group reports offsite and is thus independent of direct line responsibility for operating the plant although total independence from operating pressures is recognized to be difficult to attain in'a utility.
The NADO Staff would also serve as a technical resource to the NSB.
Since the Department would be a single entity, individuals with specific resources would 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 experienced managers who serve on these committees.
Secondly, the full time availability of NADO will permit safety reviews to be conducted in more detail than is now possible using part time PRC members.
The Staffing targets for the NADO organization at each location are detailed in Enclosure 1.
At Midland and Palisades ultimate Staffing vill be approximately 10 while at Big Rock Point the NADO nroupawill be a
_s in gle,_indivi dn=1 The reas'ons for this are twofold.
First,~ Big Kock is a small and simple plant with relatively few procedures, systems, and modification; it is a relatively mature facility where the number of future modifications / operational changes is expected to be low. Second, an_ independent safety _m_roup already exists in the fonn of the Continuin_g Risk Management Program (CRIMP); this group consists of three personn'e'l M at and reports to the~1teicEiir"In$eering Department in Jackson. Their bsy" p purpose is to utilize risk assessment techniques to evaluate plant
-performance, proposed modifications, and operating experience using the PMb#
y existing PRA as a tool. The reporting relationship of the CRIMP group i ASSE*
will not be changed, but it will be expected to work closely with the NADO representative and assist in the technical resource aspects of the NADO function.
Fred Buckman, Executive Director of Nuclear Activities, emphasized that this plan can only work if it is implemented company wide. Its organiza-tion provides career paths which will tend to enhance the psychological l
independence of department members. Approval of this concept at less than all three plants would damage this as well as create an untenable situation in so far as offsite review requirements would differ for each plant. NRC insistence on a five member NADO group at Big Rock Point would also require that the plan be abandoned as too costly considering the existing CRIMP program to which the company has already committed. CPCo's l
l intent at this meeting was to obtain agreement in principle prior to finalizing the program and submitting implementing Technical i
Specifications changes for Big Rock Point and Palisades and proposed Technical Specifications for Midland.
l The NRC Staff questioned organizational structure, independence, and operating procedures quite extensively. Most of this discussion is i
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reflected in the summary paragraphs above.
Specific issues not addressed 1
above include:
- control of NADO activities would be exercised by the NSB and NADO would I
be expected to report to the NSB at regular intervals (approximately quarterly) regarding ongoing safety evaluations, problems identified, etc.
- independence from plant management will be fostered by development of career paths not dependent on plant management and by personnel selection.
The Staff indicated a general acceptance of the concept and encouraged a prompt submittal of the necessary Technical Specification changes.for Big Rock Point and Palisades. LQB anticipates no difficulty in handling this as a package for all three plants.
It was noted,'however, that ISEG is a
-requirement for NTOL plants like Midland. The Staff is willing to propose this program to the Director of NRR as an alternative since it is company wide;and encompasses the ISEG role and philosophy. The Staff cautioned, however, that they cannot guarantee a favorable response from the Director and it is possible that some additional aspects could be added to the
' Midland. Technical Specifications to explicitly cover all ISEG requirements.
CPCo agreed to submit the necessary Technical Specifications changes in the near future.
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IN RESPONSE TO THE.NEED FOR i
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BASED ON THE SAFETY MANAGEMENT ASSESSMENT CONDUCTED BY MANAGEMENT ANALYSIS COMPANY-(MAC)'AND CONSUMERS POWER COMPANY (CP C0) IT WAS CONCLUDED THAT L
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BOTH A MORE EFFECTIVE AND EFFICIENT REVIEW PROCESS COULD BE DEVELOPED
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MAJOR CONCERNS WITH PRESENT ORGANIZATION e THE REVIEW WORKLOAD OF THE PLANT REVIEW COMMITTEES (PRC) PLACES AN UNACCEPTABLE BURDEN ON TOP LEVEL PLANT MANAGEMENT
- THE REVIEW WORKLOAD OF THE SAFETY AND AUDIT REVIEW BOARD (SARB)
PLACES AN UNACCEPTABLE BURDEN ON TOP LEVEL NUCLEAR OPERATIONS DEPARTMENT MANAGEMENT
- SOME REVIEWS BEING CONDUCTED.ARE NOT AS CONSISTENTLY THOROUGH-AS DESIRED
- RECOGNITION THAT PRESENT REVIEW PROCESS WILL NOT ACCOMMODATE THE ADDITIONAL WORKLOAD THAT WILL BE REQUIRED BY THE MIDLAND UNITS
- NEED FOR TECHNICAL PROBLEM-S0LVING SUPPORT
- NEED TO IMPROVE INTERFACE BETWEEN PLANT AND GENERAL 0FFICE L
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AREAS IDENTIFIED FOR IMPROVEMENT IN SAFETY MANAGEMENT QA AUDIT PROCESS UNNECESSARY OVERLAP 0F AUDIT FINDINGS BY DIFFERENT AUDITS.
PLANT REVIEW COMMITTEE SPENDS T00 MUCH TIME WITH PROCEDURAL MATTERS.
IT HANDLES "0N-LINE" PROBLEMS BUT IS UNABLE TO ADDRESS FORWARD-LOOKING
- SAFETY, SAFETY AND AUDIT REVIEW BOARD CONSIDERS A LARGE NUMBER OF TRIVIAL ISSUES.
l SELDOM HAS DIRECT IMPACT ON PLANT OPERATION DR SAFETY POLICY FORMULATIONS.
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SAFETY MANAGEMENT CRITERIA
.o A PROGRAM WHICH AVOIDS THE FIRST ERROR RATHER THAN ONE WHICH MERELY REPORTS THAT IT HAS OCCURRED.
e A PROGRAM THAT IS PROACTIVE, WHICH THINKS AHEAD AND WHICH ASSESSES MEANINGFULLY HOW SAFELY THE PLANTS ARE OPERATED FROM BOTH A PEOPLE AND HARDWARE PERSPECTIVE.
e A PROGRAM THAT DISCLOSES DEFICIENCIES AND OPPORTUNITIES i
FOR SAFETY IMPROVEMENTS.
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A PROGRAM IN WHICH ACCOUNTABILITY IS IMPORTANT AND WHICH DOES NOT WASTE PEOPLE'S TIME,
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SAFETY MANAGEMENT PHILOSOPHY TO CONTINU00 SLY QUESTION:
ARE WE DOING THE THINGS WE ARE COMMITTED TO D07 e
D0 OUR COMMITMENTS, IF PERFORMED PROPERLY, RESULT IN OUR REQUIREMENTS BEING MET?
ARE OUR REQUIREMENTS APPROPRIATE AND SUFFICIENT?
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PR3P3 SED NUCLEAR ACTIVITIES DEPARTMENT 6NSITE (NA93)
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NUCLEAR SAFETY ASSESSMENT AND POLICY PLANT NUCLEAR sat t:IV REVIEW t
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- CURRENT ACTIVITIES PROPOSED TO BE INCLUDED.
IN THE NEW ORGANIZATIONAL ARRANGEMENT r
PLANT REVIEW COMMITTEE ACTIVITIES e
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PALISADES CORPORATE DAILY AUDIT REVIEW PROGRAM e
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FUNCTIONS OF THE INDEPENDENT SAFETY ENGINEER e
ONSITE DIRECT TECHNICAL SUPPORT TO THE OPERATING PLANT FOR PROBLEM RESOLUTION INTERFACE IMPROVEMENT BETWEEN THE PLANT STAFF AND THE GENERAL OFFICE SUPPORT GROUPS l
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NUCIFAR ACTIVITIES DEPARTMENT ON-SITE (NAD0)
REPORTING PHILOSOPHY
~NADO WILL BE AVAILABLE TO ASSIST THE FOLLOWING:
e VICE-PRESIDENT NUCLEAR OPERATIONS e
PLANT MANAGERS e
EXECUTIVE DIRECTOR NUCLEAR ACTIVITIES e
NUCLEAR SAFETY BOARD (NSB)
PLANT REVIEW COMMITTEES (PRC)
TO PROMOTE A CLOSE WORKING RELATIONSHIP WITH EACH GROUP, REPORTS GENERATED AT THE REQUEST OF AN ORGANIZATION WILL BE DIRECTED SOLELY TO THE REQUESTING ORGANIZATION.
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PROPOSED REVIEW ORGANIZATION FLEXIBILITY ALL MEMBERS OF NADO MAY D0 REVIEWS AND ASSESSMENTS AT ANY LOCATION
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NUCIFAR ACTIVITIES DEPARTMENT ON-SITE (NADO)
EXAMPLES OF REVIEWS THAT MAY BE CONDUCTED BY NADO, BUT WHICH REQUIRE DETERMINATION OR RECOMMENDATION BY PRC OR NSB ARE:
- PROCEDURES REQUIRED BY 16.6.8.2 AND CHANGES THERETO:
(RG1.33 APPENDIX A, ETC) (BY PRC) ePROPOSED CHANGES OR MODIFICATIONS (BY PRC AND NSB) 4
- VIOLATIONS OF TECHNICAL SPECIFICATIONS (BY PRC AND NSB)
EXAMPLES OF REVIEW THAT MAY BE CONDUCTED BY NADO AND WOULD REQUIRE NO FURTHER ACTION BY PRC OR NSB ARE:
i eEVENTS REQUIRING 24-H00R WRITTEN NOTIFICATION (FOR PRC)
ESPECIAL REVIEWS AND INVESTIGATIONS (FOR BOTH PRC AND NSB) r
- PLANT EMERGENCY PLANS AND IMPLEMENTING PROCEDURES (FOR BOTH PRC AND NSB)
- 0PERATING EXPERIENCE INFORMATION (FOR BOTH PRC AND NSB)
- PROPOSED TECHNICAL SPECIFICATIONS CHANGES (FOR NSB)
- SAFETY EVALUATIONS FOR CHANGES TO PROCEDURES AND EQUIPMENT (FOR NSB) i-i
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-PROPOSED REVIEW ORGANIZATION
. NUCLEAR ACTIVITIES DEPARTMENT ON-SITE (NADO)
AT THE DISCRETION OF PRC AND/0R SARB:'
- MAY PERFORM REVIEW RESPONSIBILITIES FOR BOTH PRC AND SARB e MAY PERFORM OTHER RESPONSIBILITIES AS SPECIFIED IN THE TECHNICAL SPECIFICATIONS AT THE DISCRETION OF PRC:
- MAY ASSIST OR CONDUCT THE OPERATING EXPERIENCE REVIEW PROGRAM AT THE DISCRETION OF SARB:
- MAY REVIEW PRC MEETING AND VERIFY UNREVIEWED SAFETY QUESTION DETERMINATIONS OTHER NADO ACTIVITIES:
- TECHNICAL REVIEW 0F OPERATIONS l
- -CONDUCT PALISADES CORPORATE DAILY AUDIT l
- CONDUCT OR PARTICIPATE IN PALISADES NUCLEAR SAFETY ASSESSMENT TEAM PLANT TECHNICAL ASSISTANCE
- PROVIDE ON-SITE TECHNICAL SUPPORT FOR PROBLEM RESOLUTION
- PROVIDE PLANT - GENERAL OFFICE (GO) INTERFACE
- THE P.R0 POSED ORGANIZATION RENAMES SARB TO NUCLEAR SAF
PROPOSED ORGRNIZATION e
VCE PRESDENT
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f NUCLEAR OPERATIONS NSB EXECUTIVE DIRECTOR GENERAL MA' NAGER GENERAL MANAGER SUPERIN TENDENT NUCLEAR ACTIVITIES MIDLAND. PLANT PALISADES PLANT BIG ROCK PLANT i
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ENGWEERWG PROJECTS LA ADMNISTRATM DEPARTMENT SITE
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1 GENERAL OFFICES MIDLAND PALISADES BIG ROCK POINT NAD ONSITE NAD ONSITE NAD ONSITE NAD ONSITE
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NUCLEAR ACTIVITIES DEPARTMENT ON-SITE (NADO)
ORGANIZATION INDEPENDENCE
- NADO-REPORTS THROUGH THE EXECUTIVE DIRECTOR OF NUCLEAR ACTIVITIES TO THE VICE PRESIDENT OF NUCLEAR OPERATIONS.
R IT REPORTS INDEPENDENT OF PLANT ACTIVITIES.
e FOR GENERAL OFFICE NUCLEAR ACTIVITIES, IT REPORTS e
SEPARATELY FROM THE DEPARTMENT PERFORMING THE ACTIVITY.
i PROBLEMS IDENTIFIED BY NADO WILL BE BROUGHT TO CORPORATE MANAGEMENT ATTENTION.
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STAFF QUALIFICATION THE PALISADES AND MIDLAND PLANTS WILL HAVE AN ADMINISTRATOR AND A STAFF APPROXIMATELY EQUALLY DIVIDED INTO THREE EXPERIENCE /
QUALIFICATION LEVELS.
ADMINISTRATOR A BACHELOR DEGREE IN ENGINEERING OR RELATED SCIENCE OR EQUIVALENT AND A MINIMUM 0F TEN YEARS' EXPERIENCE, SIX OF WHICH ARE IN POWER
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PLANT OPERATION AND/0R DESIGN.
GROUP A A BACHELOR DEGREE IN ENGINEERING OR A RELATED SCIENCE OR EQUIVALE AND A MINIMUM OF FIVE YEARS' PROFESSIONAL EXPERIENCE WITH A MINIMUM
.0F TWO YEARS' EXPERIENCE IN POWER PLANT OPERATION AND/0R DESIGN.
GROUP B A BACHELOR DEGREE IN ENGINEERING OR RELATED SCIENCE OR EQUIVALENT AND A MINIMUM OF TWO AND ONE-HALF YEARS' EXPERIENCE.
GROUP C-PROFESSIONAL OR TECHNICAL PEOPLE WITH MINIMAL EXPERIENCE.
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EQUIVALENT 'IS AS DEFINED IN ANSI /ANS 3.1 SECTION 14 (DECEMBER 1979 DRAFT).
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STAFF QtlALIFICATION BIG ROCK POINT CURRENTLY HAS A PROBABILITY RISK ASSESSMENT (PRA)
GROUP (THREE PEOPLE)'WHO ARE INVOLVED IN ACCESSING PLANT SAFETY AND REPORT TO A GENERAL OFFICE ORGANIZATION.
TO DISCHARGE NADO RESPONSIBILITYr DNE NADO PERSON WILL BE LOCATED AT THAT FACILITY, THIS INDIVIDUAL WILL HAVE-GROUP A QUALIFICATIONS.
THE NADO ORGANIZATION LOCATED AT THE GENERAL OFFICE WILL CONSIST-0F THE DEPARTMENT HEAD AND TWO ADDITIONAL PROFESSIONAL / TECHNICAL INDIVIDUALS.
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OffSIIE ORGANIZAllON PRESIDENT EXECUTIVE EXECUTIVE VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT VICE PRESIDENT NUCLEAR SAFETY CENERAL SERVICES NUCLEAR OPERATIONS BOARD DIRECTOR Or Pfl0PERTY PROTECT 10N***
OTHER EXECUTIVE DIRECTOR OF CENFRAL MGR CENERAL MCR PLANT SERVICES DIRECTOR *-
QUAllTY MIDLAND PALISADES SUPERINTENDENT NUCLEAR ASSURANCE BIC ROCK PolNT ACTIVITIES EXECUTIVE ENGINEER **
NUCLEAR ACTIVITIES DEPARTMENT ONSITE e
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ADMINIS'IRATIVE CONTROLS 16.6.2.3 NUCLEAR ACTIVITIES DEPARTMENT ONSITE (NADO)
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FUNCTION 16.6.2.3.1 The NADO shall function as staff to the onsite and offsite review organizations and provide technical support for problem resolution and General Office interface. The individuals shall report to the Executive Engineer, NADO.
COMPOSITION 16.6.2.3.2 The NADO shall be composed of members located off the plant site, i
ehting in this capacity for all three plants, and full-time members at the plant.
QUALIFICATIONS
.16.6.2.3.3 At least one of the onsite members shall be at or above the staff engineering level.
On a temporary basis, any NADO member may be drawn upon to perform NADO duties at another nuclear plant location.
16.6.2.4 SHIFT ENGINEER The Shift Engineer shall serve in an advisory capacity to the Plant Supervisor on matters pertaining to the enginnering aspects assuring safe operation of the unit.
16.6.3' PLAhT STATT QUALIFICATIONS l
16.6 3.1 Each member of the plant staff shall meet or exceed the minimum quali-fications of ANSI N18.1-1971 for comparable positions.
l 16.6.3.2 The Health Physicist shall meet or exceed the qualifications of Regu-latory Guide 1.8, May 1977.8 16.6.3.3 The Shift Engineer shall have a bachelor's degree or equivalent in a scientific or engineering disciplins with specific training in plant design and response and analysis of the plant for transients and accidents.
l 16.6.4 TRAINING 16.5.4.1 A retraining and replacement training program for the plant staff shall be maintained under the direction of the Director of Nuclear Operations Training and shall meet.or exceed the requirements and recommendations of Section 5.5 of l
aTor the purpose of this section, " Equivalent," as utilized in Angulatory Guide 1.8 for the bachelor's degree requirement, may be set 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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P ADMINISTRATIVE CONTROLS ANSI N18.1-1971 and.&ppeedix "A" of 10,CTA Part 55, and shall include familiari-sation with relevant industry operations! e,xperience.
16.6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Director of Property Protection and shall meet or exceed the re-quirements of Section 27 of 3he NTPA Code-1975, except for Fire Brigade training sessions which shall be held at least quarterly.
16.6.5 REVIEW AND AUDIT 16.6.5.1 PLANT NUCLEAR SAFETY REVIEW [PNSR)
-FUNCTION 16.6.5.1.1 The Plant Nuclear Safety Review (PNSR) organization shall function to advise the General Manager on all sati.ers related to nuclear safety and to provide an examination of plant operating characteristics.
COMPOSITION 16.6.5.1.2 The PNSR organization shall consist both of individuals from the plant staff acting as a Plant Review Committee (PRC), and the Nuclear Activities Department Onsi'.e (NADO) staff acting in an ex officio capscity to the PRC (see 16.6.2.3).
The PRC shall be chaired by the Technical Engineer or by an alternat+
appointed by the Plant General Manager.
16.6.5.1.2.1 PLAN *r REVIEW COMMITTEE (PRC)
COMPOSITION 16.6.5.1.2.1.1 The PRC shall be composed ef:
Chairman:
Technical Engineer l-Member -
. Plant Superintendent l
Member:
Operations Superintendent Member:,
Tec.hnical Superintendent Member:lj'G
.Mahtenanc's Superintendent i
l Member: -
Chemistry / Health Physics Superintendent l
Memberi I Reactor Engineer Mezber:
'/
Senior Engineer Member:2 Plant / Shift Supervisor or Shift Engineer l
1 l
ALTERNATES l
16.6.5.1.2.1.2.AlterNat's members of the:PRC shall be appointed in writing by the PRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as a voting member in PRC activities at any one time.
/
l MEETING FREQUENCY 16.6.5.1.2.1.3 The PRC shall ee.c: at least once per calendar month, with special meetings as required.
au0142-0040a-43'A2 16.6-6 4-23-82/MID
NUCLEAR ACTIVITIES DEPARTMENT ON-SITE (NADO)
INDEPENDENCE OF REVIEWS NADO MAY D0 REVIEWS FOR THE PLANT REVIEW COMMITTEE (PRC)
NADO MAY D0 REVIEWS FOR THE NUCLEAR SAFETY BOARD (NSB)
NADO MAY PROVIDE PROBLEM S0LVING SUPPORT THE IMPORTANT UNREVIEWED SAFETY QUESTION DETERMINATIONS AND RECOMMENDATION RESPONSIBILITIES REMAIN WITH PRC AND NSB THIS RELATIONSHIP ASSURES THAT SAFETY-RELATED ACTIVITIES ARE OVERVIEWED BY' INDIVIDUALS NOT INVOLVED IN THE ACTIVITY, e
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1-s ADMINISTRATIVE CONTROLS s.
QUORUM.
-16.6.5.1.2.1.4 A quorum for PRC shall consist of the Chairman or his designated alternate and four (4) members oc : heir alternates, exclusive of NADO staff members.
RESPONSIBILITIES 16.6.5.1.3 The PNSR organization shall be responsible for:
a.
Review of:
(1) all-procedures required by Technial Specifica-tion 16.6.8.2 and changes thereto and (2). any other proposed pro-cedures or changes thereto as determined by the PRC Chairman to affect nuclear safety, b.
Review of all proposed tests and experiments that affect nuclear safety.
Review of all proposed changes to'the_ Technical Specifications.
c.
d.
Review of all proposed changes or modifications to plant systems-or equipment that affect nuclear safety.
Investigation of all violations of the Technical Specifications.
e.
A report shall ha prepared covering evaluation and recommendations to prevent recurrence and forwarded to the Vice President -
Nuclear Operations and to the Executive Engineer, NADO.
f.
Review of events requiring 24-hour written notification to the Commission.
i; 3
Performance of special reviews and investigations and reports thereon as requested by the Plant General Manager or Chairman of NSB.
h.
Review of the plant Emergency Plan and implementing procedures..
1.
Exam *ining plant operating characteristics, NRC issues, industry advisories, Licensee Event Reports and other sources which may indicate a need for improving plant safety.
- j. Provide trending data of plant operating. characteristics for use by the NSAP organization.
i:
, muC182-0040a-43_42 16.6-7 4-23-82/MID o
s 4DMINISTRATIVE CONTROLS AUTHORITY
- 16.6.5.1.4 Authority within the~PNSR organization is to be delegated between PRC and NADO as follows:
a.
The PRC organization shall:
i (i) Recommend in writing to the Plant General Manager approval or disapproval of items considered under 16.6.5.1.3.a.
through d. above.
k (ii) Render determinations in writing with regard to whether or I
not each item considered under 16.6.5.1.3.b. and d. above constitutes an unreviewed safety question.
.(iii) Render determinations in writing with respect to the impact on_ safety of each item considered under 16.6.5.1.3.a.
through e.
(In making determinations and recommendations, the PRC may utilize reviews conducted by NADO.)
b.
The PRC organization or the NADO organization, upon request of the PRC Chairman, shall:
(i) Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Operations and to the Nuclear Safety l -
Assessment and Policy organization of disagreement between L
the PNSR and the Plant General Manager; however, the Plant l
Genaral Manager shall have responsibility for resolution of I
such disagreements pursuant to 16.6.1.1 above.
(ii) Fulfill the responsibilities other than those specified in 16.6.5.1.4.a. above. For those responsibilities completed by NADO, however, concurrence of the PRC Chairman is required.
RECORDS j~
16.6.5.1.5 The PNSR organization shall maintain written minutes of each PRC meeting and records of transactior.= specified in 16.6.5.1.4.b.
16.6.5.2 NUCLEAR SAFETY ASSESSMENT AND p0LICY (NSAP)
RESPONSIBILITIES 16.6.5.2.1 The Nuclear Safety Assessment and Policy (NSAP) organization is responsible for maintaining a continuing examination of nuclear plant and nuclear
- safety-related ' activities and defining opportunities for policy changes related to
. improved nuclear safety performance.
h Mm MA-m 6-M-9NMID
~
i ADMINISTRATIVE CONTROLS FUNCTION
'16.6.5.2.2 The NSAP organization shall function to provide review of designated activities in the areas specified in 16.6.5.2.4.
COMPOSITION 16.6.5.2.3 The NSAP organization shall consist of both a Nuclear Safety Board (NSB) and the Nuclear Activities Department Onsite (NADO) staff. Members of NSB shall be appointed by the Vice President - Nuclear Operations. NSB shall be chaired by the Executive Director, Nuclear Activities (the Vice Chairman or a duly appointed alternate). The Executive Engineer, NADO, shall be the Vice Chairman and Secretary.
16.6.5.2.3.1 NUCLEAR SAFETY BOARD (NSB) 16.6.5.2.3.1.1 Collectively, the personnel appointed for NSB shall be competent to conduct reviews in the following areas:
a.
Nuclear Power Flant Operations b.
Nuclear Engineering Chemistry and Radiochemistry c.
d.
Metallurgy e.
Instrumentation and Control f.
Radiological Safety 3
Mechanical and Electrical Engineering h.
Quality Assurance Practices An individual appointed to NSB may possess expertise in more than one of the above specialties. He or she should, in general, have had professional experience at or above the Senior Eugineer level in his specialty.
ALTERNATE MEMBERS 16.6.5.2.3.1.2 Alternate members may be appointed in writing by the Vice President - Nuclear Operations to act in place of members during any legitimate and unavoidable absences. The qualifications of alternate members shall be similar to those of members.
j-9 ADMINISTRATIVE CONTROLS CONSULTANTS 16.6.5.2.3.1.' - Consultants shall be utilized as determined by the NSB Chairman or 3
Vice Chairman to provide expert advice to the NSB. NSB members are not restricted as'to sources of technical input and may call for separate investigation from any competent source.
~ MEETING FREQUENCY 16.6.5.2.3.1.4 NSB shall meet at least once per calendar quarter during the initial year of facility operation following fuel loading and at least once every six months thereafter.
. QUORUM 16.6.5.2.3.1.5 A quorum of NSB shall consist of the Chairman or his designated alternate and four (4) members or their alternates. No more than a minority of the quorum shall have line responsibility-for operation of.the facility.
It is
. the responsibility of the Chairman 'to ensure that the_ quorum convened for a meeting contains appropriately qualified members or has at its disposal consul-tants sufficient to carry out the review functions required by the meeting agenda.
16.6.5.2.4 RESPONSIBILITIES REVIEW 16.6.5.2.4.1 NSAP shall review:
4 a.
Significant operating abnormalities or deviations from normal.
~
and expected performance of plant equipment that affect nuclear safety.
b.
All events which are required by regulatiens or Technical Speci-l fications to be reported to 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 sig-nificance.
[
c.
Operational assessments and trending data.
d.
Issues of safety significance identified by the Plant General Manager, the NSB Chairman, Executive Engineer NADO or the PNSR.
L Proposed changes in Technical Specifications or licenses.
e.
j.
f.
The results of actions taken to correct deficiencies identified by the audit program specified in Section 16.6.5.2.4.2 at least once every six months.
1 3 Safety evaluations for changes to procedures, equipment or systems, tests or experiments, completed under the provisions of
. mu0182-0040s-43-42 16.6-10 4-23-82/MID
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ADMINISTRATIVE COh"IROLS 10 CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.
. AUDITS 16.6.5.2.4.2 Audits of operational nuclear safety-related facility activities shall be performed under the cognizance of NSAP..These audits shall encompass:
The conformance of facility operation to provisions contained a.
within the Technical Specifications and applicable license conditions at least once per 12 months.
b.
The performance, training and qualifications of the entire facility staff at least once per 12 months.
The performance of activities required by the Operational c.
Quality Assurance Program to meet tha criteria of Appendix "B,"
10 CFR 50, at least once per 24 mon:hs.
d.
The facility Site Emergency Plan and implementing procedures at least once per 24 months.
The facility Security Plan and implementing procedures (as e.
required by the Security Plan) at least once per 24 months.
f.
Any other area of facility operation considered appropriate by NSAP or the Vice President - Nuclear Operations.
3 The facility Fire Protection Program and implementing procedures at least once per 24 months.
l h.
An independent fire protectinn and loss prevention inspection l
and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
- i. An inspection and audit of the fire protection and loss l
prevention program shall be performed by an outside qualifed l
fire consultant at intervals no greater than 3 years.
(
Audit reports encompassed by 16.6.5.2.4.2 above shall be forwarded to the NSB Vice l
Chairman and Secretary and Management positions responsible for.the areas audited within thirty (30) days after completion of the audit.
l l
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1 nu0182-0040a 43 42
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ADMINISTRATIVE CONTROLS AUTHORITY 16.6.5.2.5 Authority within the NSAP organization is to be delegated between NSB and NADO as follows:
a.
For responsibilities specified in 16.6.5.2.4.1.a. through c., the NSB shall be convened. In making determinations and recommenda-tions, the NSB may utilize reviews conducted by NADO.
b.' NSAP responsibilities, other than those specified in 16.6.5.2.4.1.a. through c., may be discharged as described in a.
above or by NADO r6 view and approval of the NSB Chairman or the Executive Engineer, NADO.
c.
The NSB Chairman shall report to and advise the Vice President -
Nuclear Operations of significant findings associated with NSAP activities and of recommendations related to improving plant nuclear safety performance.
RECORDS 16.6.5.2.6 Records of NSAP activities shall be prepared and distributed as indi-
. cated below:
Minutes of each NSB meeting shall be prepared and forwarded to the a.
Vice President - Nuclear Operations and each NSB member. Minutes r3all be approved at or before the next regularly scheduled meeting following the distribution of the minutes.
b.
If not included in NSB meeting minutes, reports of reviews encem-passed by Section 16.6.5.2.4.1, above, shall be prepared and forwarded to che Vice President - Nuclear Operations.
c.
Regular reports of NADO activities shall be presented to the NSB.
16.6.6 (Deleted) i 16.6.7 SAFETY LIMIT VIOLATION 16.6.7.1 The following actions shall be taken in the event a safety limit is vio-lated:
a.
The reactor shall be shut down immediately and not restarted until the Commission authorizes resumption of operation
-(10 CTR 50.36(c)(1)(i)).
[
b.
The safety limit violation shall be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the Commission in accordance with 10 CTR 50.36 to the Vice President -
i
, Nuclear Operations and to NSAP.
l nu0182-0040s-43-42 16.6-12 4-23-82#MID
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ADMINISTRATIVE CONTROLS l
A report shall be prepared in accordance with 10 CFR 50.36 and
.c.
16.6.9 of this specification. The safety limit violation and the report shall be reviewed by the PNSR.
d.
The report shall. be submitted within 14 days to the Commission (in accordance with the requirements of 10 CFR 50.36) and to the Vice President - Nuclear Operations and to NSAP.
-16.6.8 PROCEDURES 16.6.8.1 Written procedures shall be established, implemented and maintained cov-ering the activities referenced below:
'a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, February 1977.
b.
Refueling operations.
i Surveillance and test activities of safety-related equipment.
c.
d.
Security Plan implementation.
Emergency Plan implementation.
e.
f; Fire Protection Program implementation.
16.6.8.2 Each procedure. and ' administrative policy of 16.6.8.1, above, and changes thereto, shall be reviewed'by the PNSR (except for Security Implemer31ag Proce-dures which are reviewed and approved in accerdance with ~the Site Security Plan) and approved by the Plant Manager prior to implamentation.
16.6.8.3 Temporary changes to procedures of 16.6.8.1, above, may ha made pro-vided:
j s.
The intent of the original procedure is not altered.
b.
The change is approved by two members of the plant management staff.
at least one of whom holds a Senior Reactor Operator's License on the unit affected.
- c. -The change is documented, considered by the PRC at the next regularly scheduled meetirg, and approved by the Plant General Manager.
16.6.9 REPORTING REOUIREMENTS ROUTINE REPORTS AND REPORTABLE OCCURRENCES 16.6.9.1 In addition to the applicable reporting requirements of Title 10. Code of Federal Regulations, the following reports shall be submitted to the Director af the Regional Office of Inspection and Enforcement unless.otherwise noted:
cam 2:w40.-43-62.
4-23-82fMID 16.6-13
1'
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PLANL_NUCt.t AR_SAIJJY_Rryl[W i P45RJ StCllog P110POSEI) MIDt.AllD Pl Alli TI ll E STAIIDARD 1[CillllCAL. SPFCirlCATIONS TEClinlCAl. SPEClflCAil0NS AND/OR COISIDITS reenc t ion the (Unit Review Croup) shall reenct ion "The Plant Nuclear Sarety Review (PIISR) organization shall func-to advise the (Plant Sosperintendent) on tion to advise the General Manager ori all matters re'ated to all matters related to nuclear safety, nuclear sarety and to provide an examination or plant operating cha racte r s s t ics. "
4 Composition 1he (Unit Revled Group) URG shall be "The PNSR Organization shall consist both or individuals from composed or the:
the plant starr acting as a Plant Revit.w Committee ( PRC), and the Nieclear Activities Department Onsite (NADO) starr acting in en Clia l rean: Plant Steperintendent ex-arricio capacity to the PRC (see 16.6.P.3).
The PNSR shall be Mesimr:
Operations Supervisor chaired by the Plant General Manager or by a member of his imme-Membe r:
Technical Supervisor diste starr appointed by the Plant General Manager."
Menimr:
Maintenance Supervisor Membe r:
Plant Ihc Engineer The PRC shall be composed or:
Member:
Pteret Nuclear Engineer Equivalent to the Stonetard with the exceptions or the Tech-Member:
Ilealth Physiclat nical Engineer as Chnirman and an additional member - the Plant / Shirt Supervisor or Shirt Engineer.
Alternates A l l a l te rna te membe rs sha l l b3 appo i n ted Identical to the Standard, in writing by the (URC) Chairen.e to se rye on a tempo r a ry be s I s ; howeve r, nn aware than two alternates shall partici-pate as voting members In (URC) activl-ties at any one time.
Meeting f requens y the (ifRG) shall meet at least once per "The PRC sha l l mee t a t least once per calendar month, with calendar month and as convened by the special meetings as required."
( IIRC ) Cha i rma n o r h i s de s i gna ted a l te r-nate.
l 13eso rten The minimism gesorten of the (URC) neces-rquivalent to the Standard, i
sary for the Performance of the (URG) responsibility and sisthority provisions or themse Technical Spectrications shall consist or the Clos t rean or his desig-nated alternate and rner members inclu-ding alternates, i
t 4
nuG482-0072a-43-47
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,i PROPOSEO MIDLANO PLANT SECTION
. TECHNICAL SPECirICATIONS AND/OR COIW4EISTS
. TITLE STANDARO TECHIIICAL SPECirtCATIO8tS d
llesponsibilities The (URC) shall be responsible for:
The P8ISR organf ration shall be responsible for:
e.
Review or (1) oli procedures re- -
s.
" Review or (1)'all procedures required by Technical Specirl-quired by Specification 6.8 and cation 16.6.8.2 and changes thereto, and (2) any other pro--
chariges thereto, (2) all programs posed procedures or changes thereto as determined by the PRC requ i red by Spec t rica t i on 6.8 and Chai rman to arrect nuclear safety."
changes thereto, and (3) any other (Review or all programs requi red by Spect rication 16.6.8 and proposed procedures or changes thereto as determined by the ( Plant changes thereto, has been excluded because we have no pro-Superintendent) to arrect nuclear g rams l isted in Spec t rication 16.6.8. )
- sarety,
( i n Pa rt ( 3 ) the PRC Cha i rman rep l aces t he P l ant Supe r I n-4
}
tendent.)
l b.
Review or sII proposed tests and b.
Identical to the Standa rd, experiments that arrect nuclear safety.
i c.
Review of all proposed changes to c.
" Review or all proposed changes to the Technical Specifice-i Appendix "A" Technical Specirl-tions."
l cations.
d.
Review or all proposed changes or d.
Identical to the Standa rd.
modifications to unit systems or j
equipment that arrect nuclear i
- sarety, i
nvestigation or all violations of e.
- " Investigation or all violations of the Technical Specirles-e, a
i she Technical Specifications in-tions. A repart sha l l be p repa red cove r i ng eva l ua t i on a nd j
c l ud i ng the p repa ra t ion and fo r-recommendations
- to prevent recurrence and forwa rded to the warding or reports covering Vice President-Nuclear Operations and to the Executive i
evaiustion snd recommendstions to Eng i nee r, NADO. "
i prevent recurrence to the (Super-i intendent of Power Plants) and to (CP Ce concludes that this meets the Intent of the Stenderd. )
I the (CNRAG).
r.
Review of events requiring 24-hour f.
Identical to the Standa rd.
i written notification to the Commission.
j I
i 4-30-82 j
nuG482-0072e-43-48 o
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3 SECTION PROPOSED MIDLAND PLAIIT Titl[
STAIISARD TECHIllCAI. SPrClflCAfl0NS TECH 00lCAI. SPECirlCAT10905 AND/OR C0fWlEllTS Resporosibilities g.
Review or senit operations to detect The intent or this Standard is incorporated in 16.6.5.1.3.1.
(Contd) potential twsc lea r se rsty haza rds, in addition. respnnsibility ( I) includes ifRC lastees, ladesst ry advisories, l.icensee Ivent Reports and other sources which may indicate a need for Improving plant safety.
h.
Porrormance or special reviews, g.
Iqesivalent to the Stenderd.
investigations or snelyses and re-parts thereon as regesested by the (Plant Steperintendent) or the
( C80 RAG ).
j l.
Review or the Seceerity Plan and in-Section 16.6.8.2 states that the Security Plan procedesres and plomenting procedures and shell po l ic ies a re exc luded f rom the PNSR responsibilities and sutsmit recommended changes to the are to be reviewed in accordance with the Site Security Plan.
(CNHAG).
I i
J.
Review or the Emergency-Plan and h.
" Review or the plant Emergency Plan and implementing l
Implementing procedesres and shell procedures."
~
sidsei t recommerwied changes to the t
(CNHAG).
(Review may be performed by NADO and thus need not be considered by NSR. )
J.
" Provide trerading date or plant o p rating cherectoristics for use by the NSAP organization
}
i Aestho ri ty The (IIRC) shall:
i s.
Recommend in writing to the (Plant e.
Identical to the Standard.
superintendent) approval or dissp-proval or items considered under 6.5.1.6t a l through (d) above, e
b.
Retwier determinetlens in writirig b.
" Render determinations in writing with regard to whether or I
with regard to whether or not each not each item considered urwier 16.6.5.1.3.h and d above con-Item considered under 6.5.1.6(e) stitutes an unreviewed sarety question.
4 1
through le) above constitutes an i
unroviewed sarety gesestion.
Render determination in writirig with respect to the impact j
on serety or each item considered under 16.6.5.1.3.s through e."
f (CP Ce conclawles that this meets the Intent of" the Stenderd. )
1 nien482-OnT?e-43-42
.s t
SECTIDN PROPOSED MIDLAND PLANT TITLE STANDARD TECHNICAL SPEClflCATIDMS TECHNICAL SPEClrlCATIDMS AND/OR COMMENTS Authority c.
Provide written notification within c.
Equivalent to the Standa rd.
(Contd) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the (Superintendent or Power Plants) and the (CNRAG) or Responsibility may be completed by NADO review and concur-disagreement between the (URG) and rence or the PRC Cha i rman, the ( Plant Superintendent); however, the ( Plant Superintendent) shall have responsibility for resolution or such disagreements pursuant to 6.1.1 above.
Futriti the responsibilities other than those specirled in 16.6.5.1.4.s.
Responsibilities may be completed by NADO review and concurrence of the PRC Chai rman.
Reco rds The (URG) shall maintain written minutes "The PNSR organization shall mainteln written minutes or each or each (URG) meeting that, et e alni-PRC meeting and records or transactions specirled in mum, document the results or all (llRG 16.6.5.1.4.b."
activities performed under the respon-)
sibility and authority provisions or The presence of the NADO organization will assure that these Technical Spec I r t ce t loits.
Copies important safety problems are brought to Management's atten-shall be provided to the (Superintendent tion.
Distribution or meeting minutes need not be required.
of Power Plants and the (CNRAG)).
(CP CL concludes that this meets the intent or the Standard. )
nuG4 2-007Pa-43-48 s
e.
j 9
IlllCMfl._S_ ARI,Y A. SSF_SMO(llT AND POI.lCY ll(SAP _1 SECilpel PROPOSED MIDI.AND Pl. ANT title STAIIDARD TECNellCAL SPECIFICAT1080s TECHellCAl. SPECirlCAil00lS AND/Olt COISIDITS Responsibilities'.
m Ito Standard "The NSAP orgenlistion is responsible for molntelnifeg a continas-Ing eweelnation or neoclear pleest and neoclear seroty-related j
ectivities and defining opporteenities for policy changes related I
to IPproved nuclea r serety performance."
Insnction 80n Standard "The NSAP orgenl2stlen shall function to provide review of desig-noted activities in the areas specirled in 16. 6. 5.2. as. "
l Composition No Standard "The NSAP orgenlistion shell consist or both a 90uclear Serely l
Woerd (4S8) and the NescIner Activities Department Onsite (ISADO) sterr. Members or ;4S8 shall be oppointed by the Vice President-1 Nuclea r Operations. 458 shall be che f red by the Executive j
Director. Isueleer Activities Ithe Vice Chelrmen or e duty sppointed alternate). the Executive Engineer, IIADO, shell be the Vice Che f renn and Secreta ry."
(CP Ce concludes that the above statements meet the Intent or leUREC-0T37, Item II.R.1.2.)
4 q
company feesclear The (CIIRAC) shell function to provide Fetulwelent to the Standard, in addition we stater Review enal Asadit Independent review enal audit or destel-troup (OtttAG) poted activities in the areas or:
"An Individual oppointed to NS8 may possess expertise in more j
r eenc tion then one or the above specieltles. He or she should, in s.
90seclear Power Plant Operations general, have had professional experience et or above the
{
b.
10esclear Engineering Senior Engineer level in his specialty."
c.
Cheelstry anel RedIocheelatry d.
Mete I Itergy
}
e.
Instrtamentation and Control f.
Radiological Sorety j
g.
Mechanical and Electrical E nginee ring h.
Oesst Ity Asseerence ProctIces 1
8 tother Appropriate fields Associated
%f i th 19ee un istus Cha rac t o r l a t i c s o r :
q the meclear Power Plant) 1 4
1 1
i I
niinaisp-00T?b-Is3 8 2 6
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SFC t less PRCPOSED MIDLAIIn Pt.AIIT Tlit t SI AIIDARD TECHillCAl. SPECIFICATIOIIS TECIIIllCAI. SPECIFICAT IOteS A00Df0ft Cof00ElitS (CsestaC)
The (CBIRAC) sheiI be composed of the:
CP Ce concludes thet this Standsrd Is adequetely setIsrled Composition by Sections 16.6.5.2.3 and 16.6.5.2.3.1.1 fil rector: ( PosItlen Title) poember:
(Position Title)
Ptember:
( Position t itle)
Per ehe r:
(Position Title)
Member:
(Position Title) i l
(C80stAC)
All alternato swebers shall be oppointed
" Alternate members may be appointed in writing by the Vice Clternates in writing by the (CsestAG) Director to Pressistent-Nuclear Operations to act in place of members desring serve on a temporary basis; however, no any legitimate and smavoidable absences. The quellrications or more than two meternates shalt partici-a l te rna te membe rs sha l l be s imi l a r to those membe rs."
pato es voting members in (C90RAC) activities at any one time.
f CP Co conclesdes thet this meets the Intent of the Stenefs rd. )
(C988 TAC)
Consesitants shall One settlized as deter-Equivalent to the Standard.
Gesorism mined by the (C80ftAC) Director to provide expert advice to the (CIORAC).
( C808 TAC )
The (CleftAC) she l l mee t a t least once per Identical to the Standard.
Pteeting Fregesency calenefar quarter during the Initlet year or emit operation rollowing fuel loading at least once per six months thereerter.
(CsestAC) lie minimein gesoress of the (CteftAC) neces.
Equivalent to the Stenderd.
Qisc rean sary for the petrrormance of the (CMitAG) review and audit remetions of these Technical Specificat'ons shall consist or the Director or his designated alter-nate and (at least roser CBIRAC) mealsers Including alternetes. 900 more than a alperity or the guersam sheiI fiave 1Ine I
responsibility for operation of the un t e..
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StCf Iest PROPO*r0 M108. Alto PLAllT Ilitt STAN0 Alto itCHIIICAl. SPEclflCAT10815 T[cliellCAL SPLCIIICAT108ts Allo /OR ColelEllTS Review The (CNRAC) shell review:
g.
"Serety evaluations for changes to procedures, equipment or systees, tests or experleents, completed tender the provisions s.
The safety evolustions for of 10 CIR 50.59, to verify that sesch actions did not consti-(I) changes to procedesres, egtelpeent tute en unreviewed safety question."
or systems, and (2) tests or experi-monts completed tmder the provision Requires NSAP review of changes mede tmder the provlslons or of Section 50.59, 10 CTR, to vert ry Section 50.59, 10 CTR.
that such actions did not constitute an amreviewed serety question, b.
Proposed changes to procedures.
Changes that involve an tmreviewed safety question will re-equipment or systems which involve goalre a Technical Spect rications chang
- I see d below).
en tenreviewed safety question as defined in Section 50.59, 10 CTR.
c.
Proposed tests or experiments which Unreviewed safety gemstlons require a Technical Specifica-Involve en tmreviewed seroty ques-tions change (see d below).
tion as defined in Section 50.59, 10 CfR.
d.
Proposed changes to Technical e.
Identical to the Standard.
Spect rications or this Operating 1.lcense.
e.
Violations or codes, regulations.
4 Incorporated in (h).
CP Co concludes that this meets o rde rs, lechnical Specifications, the Intent or the Standerd.
license requirements, or of Internal procedures or instrisctions having nucient sarety significance.
l F.
Significant operating almoreelltles a.
Identical to the Standard.
I or deviations free normal and ex-i pected performance or unit equipment that arrect nuclear safety, t
g.
Events requiring 24-hour written Incorporated in (b).
CP Ce concludes that this meets notification to the Comelssion.
the intent of the Standard.
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..n SI ct ical PltoPOSFO MIDl_Alec Pt Afff IlftF STANDARD TFCNellCAL. SPfCIFICAilotes TECHIllCAL SPECIF ICAt tofts ASIO/ Oft CofGEEllTS h.
All recognlied Indications or en All derictencies which might be reviewd esnder this require-asnenticipated deficiency in soews ment woesid s t reedy require review seder other existing espect or design or operation or requirements. T he re rn re, this Standard has been excluded.
strisetures, systems or components that could errect nuclear seroty.
8.
Reports and meeting minutes or the Pnc activities will be reviewed es part of the NADO. Inter-( utec ).
action with PRC.
This will surrece important issues. IIe l
rormal review or meetlog minutes is considered necessary.
80 0 Standard c.
" Operational assessments and trending date."
CP Co concludes that this meets the Intent of
]
ItttRrc-0 T3 7, Ac t ion I tem I.R. I.2.
1 Section 6.5.P.8.r. of the Standa rd F.
"Ihn results or actions taken to correct deficiencies iden-i tirled by the stadit program specirled in Section 16.6.5.2.4.2 4
et least once every six months."
(This Standard is more oppropriate in the review section then audit section.)
i Acadits Auslits of amit activltles shell be per-j rormed sander the cognirence of the
( CleMAC ). These audits shall encompass:
l e.
Ilse conformance or unit operation s.
Identical to the Standard.
i to provisions contained within the Icctmical Speelrications and appil-cohle license conditions et least j
wnce per 12 months.
1 b.
The perroreence, treinlag and quell-b.
Identical to the Stenderd.
rications of the entire unit starr et least once per 12 months.
I c.
Ilse resisits or actions taken to This Stenderd is incorporated in 16.6.5.2.4.1.F.
CP Co enrrect deficiencies occurrinet in concludes that this meets the intent of the Stenderd, emit egotipment, strisctures, systems 8
or mettsed or operation that errect nasclear serety et least once per six months.
4 nesnee82-00 T?h-43-il?
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Pp0 POSED MIDLA810 PLAlli SECTICII feltE STAIIDARD 1rCHellCAL SPfCIflCAT1000S TrCleellCAI. SPECIT ICAlI0005 AleO/OR CoselEllTS d.
The performance or activities re-c.
Identical to the Stendard, agos t red by the Ope ra t iona l Qua l i ty Asseerence Progree to meet the crl-toerla or Apperedix "R."
10 CF R Me, a t Inast once per 24 months.
4 e.
The roergency Plan end implementing d.
Identical to the Standard.
procentieres at leer.t once per 28 months.
t F.
The Security Plan and laplementing e,
rquivalent to the Standard, procedseres et least once per 24 months.
g.
Any other eroe or unit operation F.
Identical to the Stenderd.
considered approerlate by (CleRAG) or tite (Vice President-Operations),
1 h.
The fire Protection Progree and g.
Identical to the Standard, implementirig procedures et least once per 24 months.
k i
1.
An Independent fire protection and h.
Identical to the Standard.
loss prevention inspection and semilt
?*ll be performed annually util-liing either quellfled errsite licensee personnel or en oostside 4
fire protection rire.
i J.
An inspection and audit or the rire 1
Identical to the Staride rd, i
protectinn and loss prevention pro-grace shall be performed by en out-1 side gesellfled fire consesitant at 4
- ntervals no greater then three years.
"Aeedit reports enconpassed by 16.6.5.2.4.2 above shell be forverded to the NSR Vice Chaireen and Secretary sted Itenageoefst positions responsible for time areas audited written thirty (30) days af ter completion or the audit."
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e SECT 10s0 PetOPOSED MIDI Asen Pl.AsIT ilill STAseOAft0 TECNellCAl. SPECIF ICATICIIS TECHIllCAl. SPECIF ICATIO0lS A800/OR C00SIEllTS This section outlines how stethority within the NSAP orgen-
. Asstheri ty The (CWAC) shell report to and advise the (Vice President operations) on Eliose listion is to be delegated between 1858 and NADO.
CP Co areas or responsibility specirled in conclesdes that this section arvets the Intent of* the Sections 6.5.2.F and 6.5.2.8.
Standa rd and stuREC-0737, Action I tem f.B.1.2. -
Records Records or (C80RAC) activities sheii be prepared, approved and distributed as Iridicated below:
e.
Ministes of* each (CNRAC) meeting e.
"Minentes or each NS8 meeting shell be prepared and for-shsII be prepared, approved and wervleet to the Vice President-Itasclear Operations and each Forwarded to the (Vice President-NSR mesher. Minestes shall he approved at or before Else Operations) within its days following next regularly scheduled meeting rollowing the distribu-each meeting.
tion of the ministes."
i
~
(CP Co coricludes that this meets the intent of the j
Standa rd. )
b.
Reports or reviews encompassed by b.
"If not included in NS8 meeting ministes, reports or reviews Section 6.5.2.7 above, shall be pre-encompassed by Section 16.6.5.2.4.1 above sha l l be prepa red l
pared, approved and forwarded to the and forwarded to the Vice President-Nuclear Operations."
l (Vice President-operations) within (CP Co conclesdes that this meets the intent of the 14 days rollowing completion of the review.
Stende rd, j c.
Aesdat reports encompassed by This Standerd is stated in Section 16.6.5.2.8s.2, last pare-Section 6.5.2.8 above, shall be g ra ph.
Cogolzonce or sendits is en NSAP responsibility.
forwarded to the (Vice President-leportant sorety lastres will be brought to the attention of*
Operations) orid to the management the Vice President-Nuclea r Operations, positions responsible for the areas sesellted within 30 days arter comple-tion or the audit by the auditing o rg en lis t ion.
I Regular reports or NADO activltles shall be forwarded No Standard to MSB.
i 1
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STCT 5081 PROPOSED HIDIAIID Pt_Alli
. TAIID48tn TECHIIICAL SPECIFICATIOlts TECHellCAL SPtCIF ICATIosts AIID/OR COIGGENTS S
IIIt[
Itepartets t e The followissig actions shell be toisen for Occeerrence RE PORIAntt DCCURRElects:
w
,'s.
Action CP Co has conclesded that this Stanilard is redundant to The Cnemission shall be notirled 4
enst/or a report subelttN pursesent Section 16.6.9.
Therefore, this section has been excluded, to the rege:I rements or
?ci fica-titwa 6.9.
b.
Each RT Polti A8t E OCCultftEIICF. re-y enest ring 78e-tooter noti rication to Llie Commission shell be reviewed by the (UltG) and sutunitted to the (C8ePAC) enes the (Superintendent of Power Plants).
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May 4, 1982 Meeting Attendees NRC Staff CPCo John A Zwolinski Frederick Buckman E. J. Weinkam Kenneth Terry T. Wambach Roger W. Huston W. D. Shafer Ralph R. Frisch E. S. Pederson David A. Bixel Charles M. Overbey David J. VandeWalle Frederich A11enspach Kenneth J. Straup Bob Benedict J. J. Persensky J. M. Peschel Richard Each I-4
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May 14, 1982 MEMORANDUM FOR: William J. Dircks, Executive Director for Operations FROM:
R. F. Fraley, Executive Director, ACRS
SUBJECT:
FOUNDATION PROBLEMS AND RELATED REMEDIAL ACTIONS Af THE MIDLAND PLANT SITE Consistent with the request of the Office of Nuclear Reactor Regulation for comments, an Ad hoc ACRS Subcommittee has reviewed the foundation problems and related remedial actions at the Midland Plant Units 1 and 2.
These issues were discussed during an April 29, 1982 meeting of the Ad hoc Subcommittee and during the 265th full Comnittee mee"1g (May 6-8, 1982). As a result of these meetings, the ACRS accepted '
Subcommittee's recommendations that:
1.
The ACRS Midland Plant Subcommittee review the adequacy of the seismic input criteria and the Site Specific Response Spectrum and its relation to the proposed pernanent site dewatering as a means of reducing the probability of soil liquefaction due to an earthquake.
2.
Subject to a finding by the Midland Plant Subcommittee regarding the adequacy of the seismic input criteria, the ACRS recognize the adequacy of the NRC Staff's efforts and consider the proposed remedial measures as a matter that can and should be resolved in a manner satisfactory to the NRC Staff.
3.
The E00 be informed at this time that the ACRS has found the Staff's approach to be acceptable, subject to the further re-view nentioned in Item 1 above.
The seismic related issues at Midland are tentatively scheduled to be discussed during the May 20-21, 1982 Midland Plant Subcommittee meeting in Midland, MI. These issues and others related to the application of Consumers Power Company for a license to operate Midland Plant Units 1 and 2 are tentatively scheduled for review by the full ACRS during its 266th meeting (June 3-5, 1982).
cc:
H. Denton, NRR h!!$ J '
FILE: Midland E. Goodwin, NRR bec:
ACRS members,, f Hoo { NRR, D. Fischer, ACRS D
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