ML20084F522

Responds to IE Insp Rept 50-255/83-24 Open Item Re Plant Review Committee Reviews by Ballot.Strict Controls Established Over Ballot Type Reviews to Ensure Thorough Review of safety-related Matters

ML20084F522
Person / Time
Site:	Palisades
Issue date:	02/21/1984
From:	Johnson B CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20084F512	List: ML20084F522
References
NUDOCS 8405040217
Download: ML20084F522 (2)

Text

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yt 2 s. g-Consumets Power

Company General offices: 1945 West Pernali Road, Jackson, MI 49201 e (517) 788-0550 February 21, 1984 4

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James G Keppler, Administrator Region III 4

US Nuclear Regulatory Commission 799 Roosevelt, Road l

Glen Ellyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - RESPONSE TO NRC OPEN ITDi CONCERNING PLANT REVIEW COMMITTEE REVIEWS BY BALLOT NRC Inspection Report 83-24, dated October 20, 1983, included the following i Open Item (78-30-08).

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! This item identified that the Plant Review Conaittee (PRC) and the J Safety and Audit Review Board (SARB) were using a ballot type review.

The Inspection report and a letter dated July 12, 1979, from the NRC Office of Nuclear Reactor Regulation (NRR) to Consumers Power Company-stated that the ballot type review does not conform with the position j that each committee must formally convene a quorum tci act on issues for which it is responsible. In response, the licensee submitted a letter to NRR dated September- 12, 1979, stating they were in the process of surveying other utilities on how best to deal with the tremendous amount of material being reviewed by ballot. . The licensee.

committed to respond more fully on this subject a month later..

The inspector discussed this item with the Technical Engineer and

found that the additional response committed'to in the September-12, i 1979 letter was never completed. Additionally, the Plant Administra-

~J tive Procedures still allow'use of the ballot. type review. The Technical Engineer estimated that approximately 95% of the documents reviewed by ballot were withheld from implementation until subsequent-ly reviewed by a formally convened; quorum. The Technical Engineer -l committed to' complete the followup to the September. 12, 1979 correspon-I dance on this matter.

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8405040217 840501 PDR'ADOCK 05000255 G .- PDR. ,

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4 I JCKcppler, Administretor 2 Palisades Plant RESPONSE TO NRC OPEN 1 TEM I- CONCERNING PRC REVIEWS BY BALLOT

j. February 21, 1984 4

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! The response provided herein addresses the use of a ballot type review by the-PRC only. i i

i Palisades Plant Technical Specifications section 6.5.1.5 defines the

PRC quorum as "....the Chairman and four members (including i alternates)." Nuclear Operations Department Standards (NODS) - A17,

" Management Overview", section 5.3.4.b, states in part that " Reviews i  ;

! by document routing shall be considered complete when no safety-

_ related comments by designated members remain unresolved and the PRC Chairman has approved the review".- NODS-A17, section 5.3.6,

qualifies PRC review by ballot by stating, in part, that "After the

routing is complete, the document and review comments shall be-d 1 delivered to the PRC Chairman for review. If there_are no unresolved safety issues and, if.the Chairman is satisfied that the reviewers

collectively _have the necessary expertise, he may approve the

!= document.;This approval shall be documented in the minutes of the j next regular PRC meeting. If. unresolved' comments exist, or if the j Chairman chooses not to approve the document, it shall either be

[i re-routed for comment resolution or put on the agenda for deliber-ation at the next regular PRC meeting or at a special meeting". . This. ,

f method of controlling PRC review by ballot is implemented at the *

, Palisades Plant by Administrative Procedure 3.01, " Review and Audit",

section 5.6.

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The contrcls described above ensure that all documents which are reviewed by I the PRC via balloting must be approved ~by the PRC Chairman prior tjt their.

1 implementation. If, for any reason, the Chairman determines that further.

] review of a routed document is warranted the Chairman has the authority to. -

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! withhold his approval, and consequently implementation of the' document, until-j such time as the Chairman considers that the review is adequate and complete.

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Therefore, in response to this Open Item, Consumers Power Company has j established strict controls over ballot type PRC reviews rather_ than . surveying i other utilities as stated in'our letter of September 12,.1979. Consumers j Power Company believes that these controls ensure ~that~the PRC review of l safety-related matters.is thorough and comprehensive.

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- Brian D Johnson -

Staff Licensing Engineer i

j i CC Administrator, Region Ill..USNRC

{ NRC Resident-Inspector - Palisades ,

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