ML20132B847
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'o UNITED STATES i
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WASHINGTON D C. 20555 g2 i 1984 i f f' { [
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d MEMORANDUM FOR:
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tor ucensing Division of Licensing
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i FROM:
William T. Russell, Deputy Director Division of Human Factors Safety
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SUBJECT:
CHANGES TO GRAND GULF TECHNICAL SPECIFICATIONS By letter dated April 7, 1983, MP&L requested changes to Technical i
Specification 6.5.2.8.
This specification presently requires that audits of plant activities be performed under the cognizance of the SRC. The requested change would have the audits performed under the cognizance of the Manager of Quality Assurance, with a copy of the reports sent to the SRC.
The Manager of Quality Assurance is responsible, in accordance with the 4
NRC-approved QA manual, for conducting audits.
We do not believe the proposed change is necessary.
The word " cognizance" indicates " awareness, understanding," which is what the SRC should have concerning the audits delineated in Specification 6.5.2.8, not
" responsibility." The present wording permits the audits to be conducted by someone other than the SRC itself, but requires the SRC to be knowledgeable about the audits of the listed activities.
Furthermore, by letter dated May 26, 1982, MP&L submitted its interpretation, to which the staff had agreed, of the existing wording of this specification:
"The SRC shall review the results of audits (or summaries thereof) of nuclear activities conducted in accordance with the MP&L Operational Quality Assurance Manual. Audits shall be conducted and results (summaries) shall be reviewed in the areas of:..."
i Another proposed change to Specification 6.5.2.8 would delete from 6.5.2.8.b the word " performance," such that only training and qualifications of the 1
plant staff would be audited. Staff performance would be evaluated by appropriate management personnel.
We agree that one's performance is normally evaluated by one's supervisor.
However, the SRC should be interested in making sure that such evaluations are conducted on schedule, that they are performed in accordance with established criteria, and that they result in conclusions that are fair and unbiased. Therefore, although performance is evaluated by supervisors, the performance evaluation process should continue to be audited.
Therefore, the proposed changes to Specification 6.5.2.8 should not be approved.
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. By letter dated June 14, 1983, MP&L requested that a change be made to Technical Specification 6.5.2.2 to permit the corporate Safety Review Committee (SRC) to include more than two consultants from outside MP&L as voting members of the SRC, rather than only two'as Specification 6.5.2.2 permitted at the time. This request was approved, as indicated in License Amendment Number 9.
However, should more than five consultants be used as voting members at any SRC meeting, the present Specification 6.5.2.6 would be inadequate. Specification 6.5.2.6 states-that a quorum for the SRC shall consist of the Chairman or his delegated alternate and at least six SRC voting members. A quorum should be at least one-half of the voting members plus one.
With the present eight voting corporate members, this quorum requirement could accommodate no more than five voting consultants.
Furthermore, we do not believe that the use of outside consultants should be permitted to the extent that the decisional responsibilities of the corporate members are significantly reduced.
It is conceivable that the SRC could conduct its business with the Chairman as the only corporate member--the other voting members could all be outside consultants. We envision most consultants being used primarily for their expertise in particular subjects with which corporate personnel are not sufficiently knowledgeable.
Therefore, we do not believe that more than a few consultants should be vating members at all meetings--let consultants provide knowledge that corporate members can consider when they, the corporate members, vote or otherwise take responsible action. We suggest that the licensee revise his proposed change to consider the staff's concerns noted above. The staff would find the following wording to be acceptable for Specification 6.5.2.6:
"A quorum of the SRC necessary for the performance of the SRC review and audit functions of these Technical Specifications shall consist of the Chairman or his designated alternate and at least six corporate SRC voting members including alternates. No more than three consultaat members shall be voting members for any particular matter being considered. No more than a minority of the quorum shall have line responsibility for operation of the unit."
Note that the word " minimum" has been del <uo from Specification 6.5.2.6; it is superfluous.
M.T.
Mb William T. Russell, Deputy Director Division of Hunan Factors Safety cc:
A. Schwencer M. D. Houston L. Kintner C. Thomas
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