ML20097H337
| ML20097H337 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/09/1992 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20097H335 | List: |
| References | |
| NUDOCS 9206260091 | |
| Download: ML20097H337 (4) | |
Text
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SAJBLEVALUAJ104 BLTHE OFFKE Of NMIAR_1LADOR R[Cl)LAUQU g[ LATED TO AMEi[DMENT f[Qm 146 TO FAClllT_YJfRA1111Ci_LLCEf15Lfl0MR-LQ (QNSUMERS POWEFLCOMPAf.{1 EAjjnQLS PLANI QQMT No. SQ-lM 1.O INTRODifLT_1QB By letters dated April 2, 1990 and July 15, 1991; as amendei September 2l, 1990, and December 20, 1991, respectively, Consumers Power (ompaay (the licensee) requested amendment to the lechnical SpecificMions (f;) appendea to facility Operating License No. DPR-20 for the Palisades Plant The proposed amendment would revise the Palisades Technical Specifications to:
(1) transfer responsibility for the industry operating experience review program from the plant safety and licensing group to the plant review committee, (2) make various editorial corrections, and (3) incorporate changes from the most recent Palisades Plant reorganization.
The supplemental abmittals provided additional information and clarifications ano did not alter the initial proposed no significant hazards determination.
2.0 LValVATION 2.1 Industry Operating Experience Consumers Power Company (CPC) letter dated April 2,1990 proposed a TS change to delete assignment of the functional responsibility for the Industry Operating Experience Review Program from the TS.
Amendment No. 127, dated August 16, 1989 added the Plant Safety and Licensing Group to the Palisades Organization.
One of the group's functions was to en mine industry safety and to recommend nuclear safety improvements.
The NRC staff found this change acceptable as it established a formal group to perform reviews for the Plant Review Committee (PRC) and to perform some of the functions normally done by an Independent Safety Engineering Group.
CPC letter Lated April 2, 1990 noted that due to a Palisades Plant reorganiza-tion, the reipnnsibility for the Industry Operating Experience Program had been reassigned to a newly created organizational unit under the engineering and maintenar ce ma. lager. Although CPC's intent is to maintain this function within their organizational structure, they stated that deleting reference to this function froin the TS would " allow" management the flexibility to assign this responsitility as the needs of the organizational structure change. As such, CPC requested that TS 6.5.3.1, Plant Safety and Licensing function be revised to delete reference to the industry optrating experience review.
The NRC staff was concerned that deletion of this responsibility from the TS could result in a reduction in CPC's commitment to perform adequate reviews of industry operations experience.
Discussion with the licensee indicated that 9206260091 920609 PDR ADOCK 05000255 P
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2-the Plant Review Committee (PRC) currently performs a nuclear safety review of indust'ry operating experience, and would continue to perform this function regardless of the organizational unit this review is assigned to.
CPC supplemented this proposed change by letter dated September 27, 1990, which added nuclear industry operating experience to the list of PRC responsibilities in TS 6.5.1.6 and 6.5.1.7.
Wa find these changes acceptable as they allow flexibility in the assignment i
of the industry operating experience review function, yet formalizes responsibility for the nuclear safety review of this program to the PRC.
2.2.
Editorial Correctio_qi CPC ! u + ;o proposed the following editorial changes to the TS:
1.
Change the first "SV-2412B" for penetration 40B in Table 3.6.1 to
- SV-2412A".
2.
For penetration number 49, change service line size from (3") to (6").
3.
Change "4.20" to "4.21" at the end of Section 3.25.1.
4.
Change *NSB to "NPAD" at the end of Section 6.10.2., by deleting "NSB" and adding " reviews performed by NPAD."
Changes 1 and 2 correct typographical errors made during the issuance of Amendment 128 dated September 5, 1989.
Change 3 corrects a typographical error made during the issuance of Amendment 122 dated May 19, 1989.
Change 4 corrects an oversight made during the issuance of Amendment 127 dated August 16, 1989.
We have reviewed these TS amendments and_ find the proposed editorial changes consistent with previously approved TS sections.
Therefore, these changes are considered acceptable.
2.3 Plant Reorganization Effective April 1,1991, Consumers Power Company restructured the Nuclear Operations Department (N00) with emphasis on changes in the engineering off-site review and quality assurance organizations.
A new design engineering group, the Nuclear Engineering and Construction Organization (NECO), formed from a combination of resources from existing N00 and Energy Supply Services departments, was implemented and located at Palisades.
This group is headed by the Nuclear Engineering and Construction Hanager, who reports directly to the Vice President of Nuclear Operations. Another new group, called the Nuclear Performance Assessment Department (NPAD), is responsible for both the traditional QA audit function and the independent review function.
This group i
is headed by the Director, NPAD, who reports directly to the Vice President of Nuclear Operations.
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' To align the reqd rements of the Palisades Technical Specifications with the above described otyanizational changes, a technical specification change was requested by letter dated July 15, 1991.
Additionally, to facilitate changes in the Plant Review L wmittee (PRC) corrposition, this request proposed to l
change the composition 3f the PRC in that the specific titles of members are l
being deleted and replaced with a generic description.
With the management I
reorganization, some of the position titles listed in the existing technical i
specifications (nr PRC roembers have been eliminated while other comparable i
posit ion titles have been added.
Changes were also proposed to the member qualification requirements and review functiom uf, the *0f f-site Safety j
Review Group," called f1 PAD under the new organization.
l flRC review of the propcsed TS changes resulted in a letter to the licensee dated October 28, 1991, requesting clarification of tne following items:
l
- fiinimum PRC and f1 PAD member qualification requirements.
- PRC quorum requirements,
- Deletion of the second-level fiPAD review, and
- f4 PAD functional area review responsibilities.
The licensee responded with a revised TS amendment request dated December 20, 1991.
The revision referenced conservative Af4SI standard qualification requirements for PRC and flPAD members.
Reg 2rding the PRC quorum, the revision maintained PRC compositiert at eight members, thereby removing the need to address an increase in the quorum requirement.
Regarding second-level f4 PAD review, the lictnsee proposed that flPAD will meet at least two times a year.
l Furthermore, at these meetings, the committee will sample reviews approved by only one independent reviewer.
Finally, the licensee has proposed to maintain fiPAD review in all areas currently stated in the TS.
The revised TS amendment request is considered acceptable to the staff.
PRC make-up, member qualification requirements, and quorum are maintained and are l
acceptable.
Reportable event determinations are properly referenced to TS I
Sect un 6.9.2.
Changes to organizational unit descriptions (i.e., flPAD) are clearly editorial in nature.
And finally, the "Off-site Safety Review Group,"
flPAD, maintains its independence as a reviewing body-with direct access to the Vice-President, fluclear Operations.
This group maintains member qualification requirements in accordance with Section 4.7 of Af1SI/Af15 3.1-1987, and will meet as conditions requiring interdisciplinary review arise, but no less than twice yearly.
These organizational changes are considerad acceptable.
-3.0 STATE C0tiSULTAT10N l
In accordance with the Commission's regulations, the Michigan State official was notified of the_ proposed issuance of the amendment.
The State official had no comments.
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4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to administrative procedures.
The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no pubile connent on such finding (56 FR 27041 and 56 FR 41578).
Accordingly, this amendment meets the sligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
The staff has concluded, based on the considerations discussed above, that (1)
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there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2)_such activities will be conducted in compliance with the Commission's regulations, and (3) the
.lssuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
B. Holian Date:
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