ML20236D677
| ML20236D677 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/21/1987 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236D673 | List: |
| References | |
| NUDOCS 8710280313 | |
| Download: ML20236D677 (6) | |
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UNITED STATES j
, 3, NUCLEAR REGULATORY COMMISSION l-l'
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.l-WASHINGTON, D. C. 20655
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION 1
i RELATED TO AMENDMENT NO.108 TO PROVISIONAL OPERATING LICENSE NO. DPR-20 i
i CONSUMERS POWER COMPANY PALISADES PLANT i
DOCKET NO. 50-255 INTRODUCTION By letter dated September 29, 1986, the Consumers Power Company (the licensee) requested changes to the Administrative Controls Section of.the Technical Specifications for the Palisades Plant.
Supplemental information was provided in submittals dated March 19 and April 9,1987..The specific changes are addressed and evaluated below.
j EVALUATION Note that the letter designations in this evaluation correspond to the designations of the changes in the licensee's September 29, 1986, submittal.
A.
The proposed change would change the title un Plant Superintendent to Plant General Manager.
This is a position title change only and is, i
therefore, acceptable.
B.
The proposed change would add a new Section 6.1.2 which says:
"The Shif t Supervisor or, in his absence from the control room, the second licensed senior operator on duty shall be responsible for the shift command function. A directive to this effect shall be issued annually by the Vice President - Nuclear Operations."
This change is acceptable as it conforms to the wording of the Standard Technical Specifications (STS).
C.
Section 6.2.2.b would be revised to say:
"At least one licensed senior operator shall be in the control room at all times during conditions other than cold shutdown or refueling.
In addition to this senior operator, at least one licensed operator or senior operator shall be present at the controls at all times when fuel is in the reactor."
This change is acceptable as the change brings the Specification into I
conformance with 10 CFR 50.54(m)(2)(iii).
l D.
Section 6.2.2.c would be deleted and the subject matter incorporated into the new Section 6.2.2.b (see above).
Consequently, Items d.,
e., and f.
j of Section 6.2.2 would be relettered c.,
d.,
and e., respectively.
These changes are editorial in nature and, therefore, acceptable.
8710280313 871021 PDR ADOCK 05000255 P
PDR I
1 E.
New Section '6.2.2.c would be changed to read-I "A radiation safety technician shall be on site when fuel is in the reactor *."
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"*The radiation safety technician and the Fire Brigade' composition-may be less than the minimum requirements for.a perio.d of time not to exceed two hours in order to accommodate. unexpected absence provided 1
immediate action is taken to restore the minimum requirements."
This change is' acceptable as it conforms to the STS.
F.
New Section 6.2.2.d would be changed to read:
i "All core alterations, after the initial fuel loading, shall either i
be performed under the direct supervision of-a licensed Senior 1
Operator'or Senior Operator holding a license limited to fuel handling.
During'this time no other responsibilities shall be assigned to this individual."
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This change is acceptable as it conforms to the STS.
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i G.
The proposed change is editorial in nature and is, therefore,
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acceptable.
H.
A new Section 6.2.2.f would be added that'provides for administrative controls that limit the working hours of plant staff who perform safety-related functions.
This change is acceptable as it I
conforms to the staff position describef in Generic Letter 82-16.
j I.
The proposed changes to Specification 6.2.3 concerning the Nuclear Activities Plant Organization are acceptable because the only changes are in the name of the organization and the deletion of off-site membership reflecting the fact that the engineering staff is now located on-site.
Qualifications of members and function of the organization remain the same.
J.
In Section 6.3.2, the title Health Physicist would be replaced by the title Health Physics Superintendent.
This change is acceptable as it is titular in nature.
K.
The licensee has proposed adding to Section 6.3.3 qualifications for the Shift Engineer.
The change is intended, in conjunction with a required change to Table 6.2-1, to allow for the use of Option 1 (dual role SR0/STA) of the Commission Policy Statement on Engineering Expertise on Shift.
The licensee has stated that the qualifications for the Shift Engineer will be a Bachelor's Degree in a scientific or engineering discipline. We find this proposed change acceptable as it meets Option 1 of the Commission Policy Statement on Engineering I
Expertise on Shift.
If neither SR0 on shift has the qualifications i
of the Shift Engineer, they will have a separate STA.
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3 L.
The licensee has proposed changes to Figure 6.2-1.
These changes are acceptable because reporting levels of safety-related functions have not been lowered and, in some cases, have been raised.
M.
The licensee has proposed changes to the plant organization, Figure 6.2-2.
These changes include the titles of Generating Plant i
Superintendent Nuclear, Operations Superintendent. and Operations l
Supervisor to Plant General Manager, Plant Operations Manager and Plant Operations Superintendent respectively; Health Physicist to l
Radiological Service Manager; deleting the positions of Maintenance Superintendent and Technical Superintendent and establishing the new j
positions of Engineering and Maintenance Manager, and Technical i
Director.
These changes are acceptable as they do not delete any of l
the technical support to the Plant General Manager and they meet the acceptance criteria of Section 13.1 of NUREG-0800, the Standard i
Review Plan, j
l N.
The licensee proposed changes to Table 6.2-1 that would provide for the use of Option 1 of the Commission Policy Statemeat on l
Engineering Expertise on Shift.
We find this proposed change l
acceptable since the Shift Engineer will have a Bachelor's Degree in l
A scientific or engineering discipline (See K. above).
l 0.
The requested change to Section 6.4.1 would reassign the responsibility for plant staff training from the Nuclear Training i
Administrator tc the Executive Director of Energy Supply Planning, j
Training, and Administration.
This change is acceptable as the i
responsibility for training is assigned at a'high level of utility management.
I P.
The proposed changes to Specification 6.4.2 would make the Director of Property Protection, rather than the Plant Training coordinator, responsible for the fire brigade training program and would require that fire brigade training drills be held at least quarterly.
These changes are acceptable because they are. consistent with the licensee's fire protection plan which was approved by the NRC.
j Q.
The proposed change to Section 6.5.1.2 would change the composition u of the Plant Review Committee (PRC) to reflect position title changes and would provide for a broader range of alternatives for the PRC chairman.
This change is acceptable as it meets the acceptance criteria of Section 13.4 of NUREG-0800, the Standard Review Plan.
R.
The proposed change to Section 6.5.1.3 would modify the provisions for alternates to the PRC chairman.
This change is acceptable as it meets the acceptance criteria of Section 13.4 of NUREG-0800, the Standard Review Plan.
S., T.
The proposed changes to Sections 6.5.1.6.a and 6.5.1.6.e are titular in nature and are, therefore, acceptable.
U.
The proposed change to Section 6.5.2.3 would change the chairmanship of the Nuclear Safety Review Board (NSRB) to the Director of Nuclear Safety and deletes the Vice Chairman as part of the composition of the NSRB.
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- The troosed changes - te Section.6.5.2.7 would revise the. quorum 'of.
tte 3.iW to include the alternate for the Chairman.'
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These. changes'(V.-'and U.1)'are.. acceptable as they meet the j
W acceptance criteria of Section'13.4 of NUREG-0800, the Standard l
Review Plan.
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V.
The proposed. change to!Section 6.5.2.8.lt.c would' delete'the position of. Executive Engineer-NAPO from 'the Specification..This change is
'1 acceptable as it is editorial:and reflects a. title change.
j W.
The proposed change't'o Section 6.5.2.8.1.g would change the title 1
'" NAP 0" to "PSE."
This change is acceptable as,it reflects.an l
. organizational change (Section I. above).
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'X..-
The changes to Sections'6.5.2.8.2.c.'and f.'and 6.5.2.8.3 are purely-p editorial in nature and therefore, are acceptable.
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.Y.
The change to..Section 6.9.3.1.B is an editorial change'with respect'to an incorrect < reference and ther'efore, is' acceptable.
Z.
This. request (part.of'Section 6.923.3) would delete a' requirement for a.special report with respect to primary system surveillance L
evaluation and review-related to Specification 4.3 which had been-
.previously' removed from the Technical Specifications..We therefore find.this proposed change-to be editorial'in nature and acceptable.
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I AA.
<This chan'ge requests the deletion'of a bimonthly status report on the d
' program to improve the reliability of the paths to prevent post-LOCA-
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boron precipitation.
Since this program has been completed, the reports. are no. longer necessary.
Therefore, we find the request i
acceptable, i
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BB.
The licensee has requested that Section 6.10, Records Retention, be changed to read:
0 "In addition to the applicable record retention requirements of Title
- 10, Code of Federal Regulations, the following records shall be j
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retained for at least the minimum period indicated."
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L This change is acceptable as it is consistent with the STS.
j CC.
The licensee has requested that records related to the training and qualifications of the plant staff and records of the reactor tests
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and experiments be moved from Section 6.10.1 to Section 6.10.2.
This
^j change is acceptable as it is consistent with the records retention 1
period of the STS.
l 0D.
The licensee has requested that Item g. of Section 6.10.1 be l
relettered Item e., and changed to read:
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" Records of changes made to the procedures required by Specification 6.8.1."
i We find this change acceptable as it conforms to the STS.
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EE.
The licensee has. requested that. Item k. of Section 6.10.1, which requires the. retention of chlorine treatment records, be deleted.
We find this request acceptable.as.the.recordkeeping requirements
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of the National. Pollution Discharge Elimination System (NPDES) for Palisades Plant cover this.and make this item' unnecessary.
FF.
The licensee's request reletters parts of 6.10.l as a consequence-of the above noted changes.
We find this acceptable as it is an editorial ~ change.
i L GG.
'The licensee has requested that Item g. of Section 6;10.2 be revised to read:
" Records of Quality Assurance activities required by the QA Program Description."
We find this change acceptable as it is consistent with the STS.
HH.
The licensee has requested that Item i of Section 6.10.2 be. changed to read:
" Records of the meetings of the PRC and NSB."
This change is acceptable as it is editorial in nature since the
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Safety and Audit Review Board is now called the Nuclear Safety Board (NSB).
II.
The licensee requests that Item k of Section 6.10.2, which requires
-retention of environmental qualification records, be deleted and that a new Item k be added with respect.to records of water sampling and quality.
We find this change acceptable as it is consistent with the STS and the recordkeeping requirements for' environmental qualification are now covered by 10 CFR 50.49.
JJ.
The licensee has requested that Section 6.13, which covers fire protection inspection, be deleted.
We find this change acceptable as the same fire protet ion requirements are found in Items h. and i of Section 6.5.2.8.2.
9 KK.
The licensee has requested that Section 6.14, which covers environmental qualifications, be deleted.
We find this acceptable as the requirements have been replaced by 10 CFR 50.49.
LL.
The licensee has requested that two Orders be deleted from the Provisional Operating License.
These are the Orders dated August 29, 1980, and October 24, 1980, both of which relate to Environmental Qualifications.
We find this change acceptable as environmental qualification requirements are now covered by 10 CFR 50.49.
MM.
The licensee has requested that Item 3.J of the Provisional Operating License with respect to 18-month Surveillance Test Require-ments during Cycle 5 be deleted.
We find this change acceptable as it is obsolete.
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' ENVIRONMENTAL CONSIDERATION
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.This amendment relates.to changes in recordkeeping, reporting,'or administrative-j procedures orErequirements; 'Accordingly, this. amendment meets the eligibility' 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 assess-ment need be prepared in connection with the issuance of this amendment.
l CONCLUSION
'We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance i
J of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
i Date: October 21, 1987
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Principal Contributors:
F. A11enspach
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