ML20128D708

Application for Amend to License DPR-6,revising TS to Reflect Administrative Changes in Engineering,Offsite Review & QA Organization

ML20128D708
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/29/1993
From:	Beckman W CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128D710	List: ML20128D708 ML20128D725
References
NUDOCS 9302100205
Download: ML20128D708 (7)

Text

'

O l .

h 9

9 5W%

3 g Consumers William L Beckman

• ggh I'lant Manager MKNIGAN'S PROGRE.55 BiGRock Point Nuclear Plant,10269 US-31 North, Charlevoix, MI 49720 Januar; 29, 1993 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT TECHNICAL SPECIFICATION CHANGE REQUEST - ADMINISTRATIVE CONTROLS Consumers Power Company has restructured the Nuclear Operations Department (N0D) with emphasis on changes in the engineering, offsite review and quality assurance organizations.

Formerly known as the Nuclear Safety Services Department (NSSD), the Nuclear Performance Assessment Department (NPAD) is now responsible for both the traditional QA audit function and the independent review function. This group will be headed by the Director, NPAD, and will report directly to the Vice President of Nuclear Operations, The description of th' Plant Review Committee (PRC) was also altered by deleting specific titles and replacing them with a generic statement, which allows the Plant Manager to designate members of the PRC without processing a Technical Specification Change Request every time a position title changes.

Members of the PRC will be required to meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions thus meeting the criteria of Standard Review Plan 13.4.

To align the requirements of the Big Rock Point Technical Specifications with the changes described above, a Technical Specification Change is requested.

Attachment 1 contains proposed new Technical Specification pages._ Attachment 2 contains existing Technical Specification pages marked up to show the proposed changes.

/

l -t' MG)

William'L Beckman -

Plant Manager 050031 CC: Administrator, Region III, USNRC NRC Resident Inspector - Big Rock Point

' Attachments I )

9302100205 930129 '

PDH ADOCK 05000155 4 C4f5 CV67?GY COMPANV I P PDR g

CONSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications License DPR-6 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Facility Operating License DPR-6, Docket 50-155, issued to Consumers Power Company on May 1, 1964, for the Big Rock Point

- Plant be changed as described in Section I below:

1. Chanaes A. Change the reference to " Nuclear Safety Services Department" to read " Nuclear Performance Assessment Department" in Sections:

I 6.5.1.6e 6.5.1.6h 6.5.1.6j 6.5.1.7c 6.5.2 6.5.2.1 J

B. Change the reference to "NSSD" to read "NPAD" in Sections:

6.5.1.8-6.5.2 6.5.2.3 6.5.2.4.1 6.5.2.4.2f

. 6.5.2.5 6.5.2.6 6.7.lb 6.7.ld C. Delete 6.5.1.2 and insert the following:

"The PRC is composed of nine regular members from the Big Rock Point Staff. The PRC members shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions. The PRC shall include representatives from the Operations, Chemistry /

Health Physics, Maintenance and Engineering Departments. The Members shall be designated in Administrative Procedures by the Plant Manager. The Plant Manager shall also designate'the Chairman and Alternate Chairman' in writing."

D. Revise 6.5.1.5 to read:

"A quorum for PRC shall consist of the Chairman or alternate Chairman and four (4) voting members (including alternates)."

E. Precede " Nuclear Performance Assessment Department" with

" Director", in Sections 6.5.1.6e and 6.5.1.6j.

,' NUCLEAR REGULATORY COMMISSION 3-BIG ROCK POINT PLANT

TECH SPEC CHANGE REQUEST - ADNINISTRATIVE CHANGES-I. Chances (Continued)

F. Revise Section 6.5.2.2 to rea'd:

- "The NPAD shall include the Director, who reports to the Vice President - N00, and a full-time staff of Nuclear Performance Specialists reporting to the Director. The Director and the Nuclear Performance Specialists shall meet or exceed the .

qualifications described in Section 4.7 of ANSI /ANS 3.1-1987. The NPAD shall have no direct responsibility for_ activities subject to its review."

, G. Revise Section 6.5.2.4.2 to read:

! " Audits of operational nuclear safety-related facility activities shall be performed by-the NPAD Staff under the-cognizance of the Nuclear Performance Specialists. These audits shall. encompass:"-

H. Delete " Assurance" frcm the CPC-2A' title in sections 6.5.2.4.2c, 6.14 lc and 6.15.lc.

I. Revise-the last paragraph in Section 6.5.2.4 2 to read:

i

" Audit reports encom3assed by Specification 6.5.2.4.2 above shall

! be forwarded to the )irector, NPAD, and management positions

responsible for the_ areas audited within thirty (30) days after completion of the audit."

! J. Revise Section 6.5.2.4.3=to read:

"NPAD review of the subjects in Specification 6.5.2.4.1 and 6.5.2.4.2 shall be performed by an assigned Nuclear Performancel Specialist selected on the basis of technical expertise relative to the subject being reviewed. If the assigned Nuclear Performance ,

Specialist determines _ the need for interdisciplinary review, a

i. committee consisting'of the_ Director, NPAD,.or.his; designate-and at least four Nuclear Performance Specialists, shall be assigned.

Such committee shall: meet as conditions requiring interdisciplinary review arise, but no less than twice yearly."

i II. Discussion The PRC member titles will be removed from the _ Technical- 3pecifications so that- a Technical Specification Change Request will not be required for NRC approval when position titles change. . PRC member qualifications will still be consistent with those' described for the Plant Staff and meet or exceed the minimus aualifications of ANSI N18.1-1971 for comparable positions as endorsed by .the NRC in Standard Review' Plan 13.4. The Plant Manager will be. required _to designate _ the PR_C members,

<. chairman and alternate chairinan in Administrative:Frocedures.-

Appropriate authority is pla'ced over PRC selection'.

- _ - =

s

~

.' NUCLEAR REGULATORY CONMISSION 4 BIG ROCK POINT PLANT TECH SPEC CHANGE REQUEST - ADNINISTRATIVE CHANGES q l

II. Discussion (Continued)

The Nuclear Performance- Assessment Department (NPAD) is an organizational unit functioning as an independent review body which

provides independent review of activities in the areas where review was ,

l previously performed by the Nuclear Safety' Services Department. . NPAD l

will be performed by a Nuclear review (described Performance in Change Specialist J. above)d on the basis of his expertise in (NPS) appointe the area concerned. If the appointed NPS determines the need for additional review, the subject of the review will be further evaluated by a committee consisting of the Director, NPAO, and at least four-Nuclear _ Performance Specialists. Thus,_ if review by a multi-disciplined committee is deemed appropriate by the appointed reviewer, further review is performed by the committee.. This practice _ combines the best features of past review practices. Both the practice of committee review and_ the practice = of individual ' review have existed in the past.

This proposed change combines the most effective parts of each. As was 4 the case previously (Section 6.5.2.3), consultants may be used where sufficient expertise is not available within NPAD. Second-level NPAD review will no longer be required. Review by a Nuclear Performance Specialist provides, in most cases, sufficient depth of review to assure the inargin of safety. - In those cases when the Director, NPAD, or the-appointed reviewer determines more depth of review is appropriate, the aforementioned committee' will provide it. The Director, NPAD, and the Nuclear Performance Specialists will also mee.t at least twice yearly and 4 review at least one independent review performed by each specialist.

The requirement that NSSD Staff meet or exceed the qualifications described in Section 4.7 of ANSI /ANS 3.1-1987 continues in effect for the-Director and Nuclear Performance Specialists of the NPAD-Staff.

Thus, Section 6.5.2.2 continues to meet the acceptance criteria of Section 3.4 of the Standard Review Plan.

• Chanaes

Changes A. and B. only change the name of the reviewing.or receiving .

4 department from_the Nuclear Safety Services Department (NSSD) to Nuclear Performance Assessment Department (NPAD). As discussed above, this proposed Technical Specification change does not significantly change the type of review or the skill, experience or knowledge. required for effective Company review.

Change C. and .D. describe the composition and-qualification of the Plant Review Committee and the responsibilities of the Plant Manager in conjunction with the Committee.

Change E. requires that the Director, Nuclear Performance Assessment Department,-receive any report prepared covering the investigation of-all ' violations of _the Technical Specifications,- and review if any non-controlled radioactive release, 1

_ _ _ . _ - _ _ _ o

. s

! NUCLEAR REGULATORY COMMISSION 5

BIG ROCK POINT PLANT TECli SPEC CHANGE REQUEST - ADMINISTRATIVE CHANGES - 1 II. 01mL11gn (Continued) 1 Change F. describes and prescribes the composition of the NPAD, ensures its direct access to the Nuclear Operations Vice President and requires '

its independence as a reviewing body.

l Changes G. and I 6 scribe the audit and reprting responsibilities by the NPAD Staff, and change H. deletes the word " Assurance" from the-CPC-

! 2A title, i-

[ Change J. describes the reviews required by the Nuclear-Performance '

~

Specialist and what-actions will be required if the assigned NPS determines the need for interdisciplinary review.

All of these changes 'are administrative in nature.

l

III. Malysis of No Sionificant Hazards-Consideration

' Consumers Power Company finds, in complihnce with 10 CFR 50.92(c), that

! activities associated with this change request involve ra significant

hazards. The following evaluation ;upports that- fi.. ding.

l 1. Will the proposed change involve a significant increase in the

probability or consequences

cf an accident. previously evaluated?

i This change does not affect the probability or consequences of an accident. The changes are to the administrative section of the Technical Specifications with the significant- changes affecting the

PRC composition and changing the- ethod of. independent review.-

a

] The .PRC member titles will' be remed from the Technical-l Specifications to facilitate not requiring that a Technical' .

Specification Change be submitted for NRC approval when position -

4

. titles change. PRC member qualifications'will still be consistent 4 with those described for.the Plant Staff and meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable-positions i as. endorsed by the NRC in Standard Review Plan 13.4.- The Plant

Manager will be required to designate the PRC_ members, chairman and 4

alternate' chairman in Administrative' Proce~dures. Appropriate authority is placed over PRC selection. Therefore, these changes.

will not affect the probability or consequences;of an; accident.

The review method of. th'e organizational' unit functioning as an independent review body (Nuclear Performance Assessment Department) continues to meet the requirements of ANSI N18.7-1976/ANS 3.2 but-has changed in that a.second-level review is no longer . required.

When'necessary, the depth of review will be enhanced as appropriate either through the past practice _of using consultants:or by committee. review. The independent review body staff tasked with review of the Technical Specification required functional areas

!- NUCLFAR REG 9LATORY COMM!tSION- 6 SIG ROCK PO!!!T PLANT -

TECH SPEC CHAME REQUEST - ADMINISTRAT!H! CHANGES' f 111. enalysis_of No Sionificant Hazards _Considerai. ion (Continued) ,

will continue to meet or exceed the qualifications' described in Section 4.7 of ANSI /ANS 3.1-1987 in accordance with the Standard Review Plan 13.4. This change is administrative and dces not-

! increase.the probability or consequences of an accident, d

. Thus the changec proposed do not _ affect the operation or material-condition of the facility. The accident analyses are not _affected by this proposed change. Proper review and independent oversight by qualifled personnel as recommended.or-required by the Standard.-

- Review Plan and Administrative Procedures 4111 be in place.

Therefore, the changes do not increase the probability or

, consequences of an' accident.

2. Will the proposed change create the possibility of a new or different kind of accident'from any accident previously evaluated?

I The composition of-the' onsite PRC and the independent review group

, -(NPAD) will be~ made up of qualified individuals providing:

functional reviews that are consistent:with the Standard Review .

l ' Plan and administrative program requirements. These changes are-

j. administrative in nature and do not affect the material condition, plant operation or_ accident analyses;. and therefore, do not create

the possibility of a different type lof accident than-previously

evaluated.

3. Will the proposed change involve a significant reduction-in the-margin of safety?

l The changes to PRC' composition provide internal . flexibility in

! changing the organization titles, but do not reduce the PRC function to provide review and advise the Plant Manager on. matters of nuclear safety.- The PRC:will be. composed of individuals from-appropriate functional areas of Operations, Maintenance, _ _ _

Radiological Services and Engineering-departments. They.will be

designated by the Plant' Manager.

4 The'NPAD will continue to provide an' independent overview by_

qualified individuals, or by committee, of the functional areas-delineated in the Technical Specifications. These changes are-administrative in. nature and do-not1 affect the material condition -

or the operation of the plant, and neither:the' consequences of an .

accident nor the. fission product boundaries have been affected.

Therefore the margin of safety; has not' been. reduced.

l i

~ r y - , , -t 2-.>

_ _ _.. . ~ . . . . _ _ _ - _ _ _. - _ _ _ . . ~ . . . - - . . . _ . _ . . . . .. - - _ . . _ _

4- q MUCLEAR REGULATORY COMMISSION- BIG ROCK POINT PLANT- -)

TECH SPEC CHANGE REQUEST - ADMINISTRATIVE CHANGES- -1 I-i IV. Conclusion

!=

The Big Rock Point Plant Review Committee has reviewed this Technical-Specification Change Request and has determined this change does not involve an unreviewed safety question.- Further, the change involves no E significant hazards consideration. (This change has also been reviewed by the Nuclear Performance Assessment Department functionally operating as the Nuclear Safety Ser_ vices De)artment.) A copy of this Technical-

- -Specification Change Request _has )een sent to the State of Michigan -

! official designated to receive such Amendment requests to the Operating

License.

1 .

! CONSUMERS POWER COMPANY To the best of my knowledge, informat_ ion and _ belief, the contents of this 4 submittal are truthful and complete.-

4 By

, David P 'Hoffq3 A JVice President

' Nuclear Operations

. Sworn and subscribed to before me this 15th day of January.1993.

I Onmml)tn Y WDvms1-1-

e nifer/L Lampman, Notalry Public Char $evoix _ County, Michigan My commission' expires August ?.7, 1995.

(Seal) l y p - - - w e ~v a , y - ,- . - ,