ML20154S637
| ML20154S637 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/22/1988 |
| From: | Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20154S641 | List: |
| References | |
| NUDOCS 8810050116 | |
| Download: ML20154S637 (7) | |
Text
-
m d
e
@99WM Consumers Power Kenneth W B+try Director gmg Nuclear Ikeruing Generaf Offices: 1945 West Pernati Roed. Jackson, MI 492o1 e (517) 7881636 September 22, 1988 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -
TECHNICAL SPECIFICATION CHANGE REQUEST - ADMINISTRATIVE CONTROLS Attached is a request for change to the Big Rock Point Technical Specifications. These proposed changes will allow the independent review and audit functions to be accomplished by an independent organizational unit rather than a standing committee. The requested changes are consistent with the Boiling Water Reactor Standard Technical Specifications, ANSI N18.7-1976 and ANS 3.1-1987.
They are intended to strengthen the offsite independent safety review function.
The attached Proposed Technical Specification Page Changes reflect previously submitted change requests which are still pending NRC action. Approval and issuance of these proposed changes should be coordinated with our previous proposals dated July 23, 1987 and September 21, 1988 to ensure the issued pages do not contain inadvertent omissions or errors.
Pursuant to 10CFR170.12(c), a check in the amount of $150.00 is remitted with this application.
i Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector - Big Rock Point i
Attachments ACO l I I g ([50 '
OC0988-0128-NLO4 ghoMhhh$$@P 4t: 9 3ocil P
I L
~.
e.
i f
f CONSUMERS POWER COMPANY Docket 50-155 Request for Change to the Technical Specifications License DPR-6 I
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:
l 3
I.
Changes A.
Delete Section 6.2.3, Independent Safety Engineering Group, in its l
j entirety (Items 6.2.3, 6.2.3.1, 6.2.3.2 and 6.2.3.3).
t l
B.
Change "Director - Nuclear Safety" to "Nuclear Safety Services Department" in Section 6.5.1.6.e.
i r
i C.
Change "Chairman of NSB" to "Nuclear Safety Services Department" in f
Section 6.5.1.6.h.
D.
Change "Nuclear Safety Board (NSB)" to "Nuclear Safety Services Department" in Section 6.5.1.6.j.
i E.
Change "Vice Chairman of NSB" to "Nuclear Safety Services i
Department" in Section 6.5.1.7.c.
l F.
Change "NSB" to "NSSD" in Section 6.5.1.8.
l 1
j G.
Revise Section 6.5.2 to read as follows:
"6.5.2 NUCLEAR SAFETY SERVICES DEPARTMENT (NSSD) j 1
i FUNCTION i
l 6.5.2.1 The Nuclear Safety Services Department shall function to 4
provide independent review of activities in the areas of:
i-a.
Nuclear Power Plant Operation b.
Nuclear Engineering c.
Chemistry and Radiochemistry d.
Metallurgy e.
Nondestructive Testing
]
l f.
Instrumentation and Control j
g.
Radiological Safety i
i l
j TSOB0888-0086-NLO4
2 h.
Mechanical and Electrical Engineering 1.
Administrative Controls and Quality Assurance Practices J.
Emergency Planning k.
Training COMPOSITION 6.5.2.2 The NSSD shall consist of a full-time staff reporting to the Vice President - Nuclear Operations. NSSD staff shall have no direct responsibility for activities subject to their review.
The NSSD staff shall meet or exceed the qualifications described in Section 4.7 of ANSI /ANS 3.1 - 1987.
CONSULTANTS 6.5.2.3 If sufficient expertise is not available within NSSD for review of particular issues, the NSSD shall have the authority to utilize consultants or other qu?lified organizations for expert advice.
6.5.2.4 RESPONSIBILITIES EVIEW 6.5.2.4.1 NSSD shall review:
a.
The safety evaluations fort
- 1) changes to procedures, equipment or systems, and 2) tests or experiments completed under the provisions of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question. Review of safety evaluations may be accomplished through sampling.
b.
Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50.59.
c.
Proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59.
d.
Proposed changes to Technical Specifictitians or the Operating License.
e.
Violations of codes, regulations, orders. Technical Specifications, license requirements or internal procedures or inctructions having nuclear safety significance.
TSOB0888-0086-NLO4
3 i
f.
Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety, g.
All REPORTABLE EVENTS having nuclear safety significance.
h.
All recognized indications of an unanticipated deficiency in some aspect of design or operation of struc.tures, systems or components that could affect nuclear safety.
1.
Reports and meeting minutes of the Plant Review Committee.
t AUDITS i
6.5.2.4.2 Audits of operational nuclear safety-related facility i
activities shall be performed under the cognizance of NSSD.
These audits shall encompass i
a.
The conformance of plant operation to provisions j
contained within the Technical Specifications and applicable license conditions at least once per 12 l
months.
b.
The performance, training and qualifications of the entire facility staff at least once per 12 months.
c.
The performance of activities required by the Quality Assurance Program Description for Operational Nuc.' Lear Power Plants (CPC-2A) to meet the criteria of 10 CFR 50, 1
Appendix B, at least once per 24 months.
j d.
The Site Emergency Plan and implementing procedures at least once per 12 months.
4 e.
The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 12 months.
f.
Any other area of plant operation considered appropriate i
by NSSD or the Vice President - Nuclear Operations.
l g.
The plant Fire Protection Program and implementing procedures at least once per 24 months.
h.
An independent fire protection and loss prevention j
inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
a j
TCOB0888-0086-NLO4 i
. = - - -
4 1.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
- j. The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.
k.
The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.
1.
The Process Control Program and implementing procelures for processing and packaging of radioactive wastes at least once per 24 months.
Audit reports encompassed by 6.5.2.4.2 above shall be forwarded to the NSSD, and management positions responsible for the areas audited within thirty (30) days after completion of the audit.
AUTHORITY 6.5.2.5 The NSSD shall report to and advise the Vice Preaident -
Nuclear Operations of significant findings associated with those areas of responsibility specified in Section 6.5.2.4.1 and Section 6.5.2.4.2.
RECORDS 6.5.2.6 Records of NSSD activities shall be maintained. Reports shall be prepared and distributed as indicated below:
a.
The results of reviews performed pursuant to Section 6.5.2.4.1 and Section 6.5.2.4.2 shall be reported to the Vice President - Nuclear Operations at least monthly.
b.
A report assessing the overall nuclear safety performance of the Big Rock Point Plant shall be provided to senior Consumers Power Company management annually."
H.
Change "Chairman - NSB" to "NSSD" in Section 6.7.1.b and Section 6.7.1.d.
II.
Discussion The above proposed Technical Specification changes are requcated to strengthen the offsite independent safety review function.
A.
The Independent Safety Engineering Group (ISEG) is eliminated. This function had been carried out by Palisades staff with limited activities at Big Rock Point primarily in support of the Nuclear Safety Board. Creation of a full time independent offsite safety review staff (as discussed in Item B below) will increase the level TS0B0888-0086-NLO4
5 of independent oversight of Big Rock Point and eliminates the need for an ISEG for Big Rock Point.
Examination of plant operating characteristics, NRC issuances and industry advisories will continue to be carried out by the Plant staff.
B.
Changes to Secttan 6.5.2 are due to independent safety review fur.etions bek < carried out by a full time organization rather than a committee. Per revised Sections 6.5.2.4.1.a. b and c, all safety evaluations completed in accordance with 10 CFR 50.59 aill be submitted to the NSSD organization. Those which the Plant Review Committee concludes do not constitute an unreviewed safety question, will be reviewed by NSSD based on both a random and selective sampling method. All safety evaluations which constitute an unraviewed safety question, as determined by the Plant Review Comnittee, will be reviewed by NSSD prior to implementation.
Safety evaluations will be reviewed by NSSD on a sampling basis in order tot
- 1) ensure responsibility for tha technical adequacy of the cafety evaluation remains in the line organization and is not I
assumed by the oversight organization, and 2) provide NSSD the opportunity to conduct an indepth review of a limited population of safety evaluations and, thereby, draw conclusions as to the overall quality of the entire population.
The combination of 1) and 2) above will provide a more effective independent review than currently is provided by committee overview of all safety evaluations. Because procedures and changes thereto make up the vast majority of safety evaluations, and, generally, are not controversial with respect to 10CFR50.59, a random method will be employed to select those for NSSD review. Changes to the facility, as well as tests and experiments, will be selectively sampled based on a screening review.
Initially, the sample size will be ecsentially 100% until adequate performance is established in the preparation of safety evaluations performed by the line organization.
In general, NSSD review of the subjects in Section 6.5.2.4 will be carried out by an assigned Lead Reviewer who will be selected on the basis of his technical expertiso relative to the subject to be i
reviewed. A second level review will be performed by the Director of Nuclear Safety.
If the Lead Reviewer or the Director of Nuclear Safety determines the need for interdisciplinary review, additional i
reviewers will be assigned. As a result, all items subject to NSSD i
review will receive more indepth consideration than is currently the practice with committee overview.
1 1
l C.
All of the other proposed changes are necessary to reflect the i
organizational changes made in Section 6.5.2.
D.
The offsite organization chart (Figure 6.2-1) is not being revised because removal of the figure has been requested by a separate change request dated September 8, 1983, in accordance with Generic Letter 88-06.
TSOB0888-0086-NLO4 l
6 III. Analysis of No Significant Hazards Consideration These proposed changes eliminate the independent safety engineering function for Big Rock Point which had been <,arried out on a limited basis by other offsite groups. These proposed changes also replace the Nuclear Safety Board with a full-time Nuclear Safety Services Department. These changes strengthen the independent nuclear safety reviews for Big Rock Point by increasing the total resources committed to safety reviews and to provide more timely reviews. Since these proposed changes are organizational in nature, probability of occurrence or consequences of an accident or malfunction previously evaluated are not affected. The evaluation of plant operating characteristics, licensee event reports NRC issuances, and industry advisories will continue to be carried out by the plant staff subject to oversight by the new Nuclear Safety Services Department. Since these proposed changes are organizational in nature, the possibility of an accident or malfunction of a different type than any previously evaluated is not r
created. The level of independent safety review will be increased by these proposed changes. These proposed changes affect only the Administrative Control Section of the Technical Specifications. No margin of safety is defined for the Administrative Controls Section of Technical Specifications, hence, the margin of safety is not reduced.
]j Consequently, these proposed changes do not involve a significant hazards consideration, f
1 i
l I
IV.
Conclusion, The Big Rock Point Plant Review Committee has reviewed this Technical Specification Change Request and has determined that this change does
[
not involve an unreviewed safety question and, therefore, involves no 3
significant hazards consideration. This change has also been reviewed
{
by the Nuclear Safety Board and found to be acceptable. A copy of this l
change has been sent to the State of Michigan official designated to receive such Amendments to the Operating License.
CONSt'MERS POWER COMPANY l
By b
D d
1 D.tvid P llof f man, Vice"PMident j
Nuclear Operations Svern and subscribed to before me this 22nd day of September 1988.
i hov Y/
MA
)
Elaine E Buehrer, Notary Public j
Jackson County Michigan l
My commission expires October 31, 1989 1
TSOB0888-0086-NLO4
\\