ML18047A665

Proposed Tech Spec Changes to Licenses DPR-6 & DPR-20 Re Administrative Controls,Providing coordinated,company-wide Safety Mgt Program.Proposed Tech Specs Supersede 820720 Submittal

ML18047A665
Person / Time
Site:	Palisades, Big Rock Point, 05000000
Issue date:	11/05/1982
From:	CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML18047A666	List: ML18047A665
References
NUDOCS 8211180238
Download: ML18047A665 (16)

Text

SECTION I CONSUMERS POWER CO~lPANY PALISADES PLAN1

. REQUEST FOR CHA~GE TO THE PALISADES TECHNICAL SPECIFICATIONS November 5, 1982 null82-0139a142-155 3 pages 8Utt84'2:38- 4-3f1

1 CONSUMERS POWER COMPANY

. DOCKET 50-255 REQUEST FOR CHANGE TO THE TECHNICAL SPECIFICATIONS LICENSE DPR-20 For the reasons hereinafter set forth, it is requested that the Technical Specifications contained in the Provisional Operating License DPR-20, Docket 50-255, issued to Consumers Power Company on October 16, 1972, for the Palisades Plant be changed as described in Section I below:

I. CHANGES A. Add Section 6.2.3 B. Revise Sections 6.5, 6.7 and 6.8 C. Delete Section 6.8.4 Revised Technical Specifications pages are attached asSection II. Proposed changes are shown by a vertical line in the right-hand margin.

II. DISCUSSION Consumers Power Company intends to implement a coordinated approach to the safety review function. The plan encompasses NUREG-0737, Item I. B. 1. 2, 11 Independent Safety Engineering Group" as well as the onsite and offsite review committees required by the Technical Specifications.

Consumers Power Company was motivated to re-evaluate its safety review policy by three principal factors. First was the the Regulatory Improvement Program currently underway at Palisades, second was a perception of a significant increase in workload for the offsite review board associated with Midland, and last was a study conducted by MAC.

The MAC study found, among other comments, that the Plant Review Com-mittees' carried an extremely high workload, and that required supple-mental reviews caused .this workload to cascade throughout the review process. This high workload and the composition of the review commit-tees (Senior Line Managers) has the potential to detract from the quality of safety reviews and/or the effectiveness of plant management.

The proposed new scheme involves significant changes to the Administra-tive Controls Section of each of the plant's Technical Specifications.

These particular sections of the Technical Specifications are.nearly identical for all three plants. Some differences, however, do exist.

The new organizational structure involves the creation of a new depart-ment titled "Nuclear Activities Plant Organizatipn" (NAPO) headed by an Executive Engineer. The Company safety review organization also "includes the Nuclear Safety Board (NSB) as the offsite review committee and a Plant Review Committee (PRC) at each plant.

nu1182-0139b142-43

2 The NAPO will report to the Vice President-NOD through the Executive Director, Nuclear Activities. It consists of the Executive Engineer E~d supporting staff at the General Office and staff at Palisades and Midland. NAPO support for Big Rock Point will be through a small onsite staff or from other parts of. the NAPO. The intention of this organization is to permit the NAPO staff on site to act as a technical resource to the PRC by performing safety reviews and assisting PRC in completing other PRC responsibilities . . (Concurrence of the Executive Engineer - NAPO is required as detailed in the proposed Technical c-::-c*~--

Specifications.) This organization will also perform independent safety appraisals, trend plant performance and generally perform those functions described in NUREG-0737, Item I. B .1. 2. This organization r:eports off site and is therefore independent of direct line responsi-bility for operating the plant although total independence from operating pressures is recognized to be difficult to attain.

The NAPO staff will also serve as a technical resource to the NSB.

Since NAPO will be a single entity, individuals with specific experi-ence/qualification levels will be available to support NSB reviews at all plants regardless of their permanent "home" location.

Providing this resource for PRC and NSB serves two purposes. First, it d-'~:=::~~~

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~ * **'*effectively, better utilizing the talents of the senior and experienc_ed

~-- (managers who serve on these committees. Secondly, the full-time avail-

i. ability of NAPO will permit safety reviews to be conducted in more cr*,;c0*

• detail than is. possible using part-time PRC and NSB members.

Specific issues not addressed above include:

• ~----'-'-=A. ~el of.:::liU!:PO activities-wi*H**;::be=ex~~. NAPO will

• . - ' \" *-' * '-' *. . . /f be expected to report to the NSB at regular intervals (approximately

.* .-1_dj(~d:. quarterly) regarding ongoing safety evaluations, problems

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identified, etc.

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. ..~L- *.o B. As stated in Section 6.5.1.r, the PRC organization is required to

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make determinations and recommendations of items considered under

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d..5-0 ~ 6.5.1.6, a through e, with regard to the issues stated. The PRC, however, may utilize reviews conducted by NAPO or any o~her technical resource.

C. Independence from plant management will be fostered by development of career paths not dependent on plant management experience, and cy personnel selection.

D. Th~ requirement of a five member onsite NAPO staff is not effective until January 1, 1983. At the pre~ent time the onsite KAPO consists of three members whose qualifications meet the requirements of Section 6.2.3.3.

null82-0132bl42-43

e* 3 E. The requirements of 10 CFR 50.54(t) for an indepe:i.dent reviei;..* of the emerge*ncy preparedness program at least every 12 months (Generic Letter 82-17) are addressed under Item d, Section 6.5.2.8.2.

rrr~ CONCLUSION Based on the foregoing, both the Palisades Plant Review Committee and the Safety and Audit Review Board have concluded that these changes do not involve an unreviewed safety question, CONSUHERS POWER.COMPANY J W Reynolds (Signed)

J W Reynolds, Executive Vice President Energy Supply Sworn and subscribed to before me this 12th day of November 1982.

Helen I Dempski (Signed)

(SEAL)

Helen I Dempski, Notary Public Jackson County, Hichigan My commission expires December 14, 1983.

null82-0139bl42-48

SECTION II CONSUHERS POWER COMPM1Y PALISADES PLANT PROPOSED PALISADES TECHNICAL SPECIFICATIONS PAGES November 5, 1982 null82-0139a142-155

e*

THIS PAGE INTENTIONALLY LEFT BLANK.

nul082-0506a-43-46 6-la PR'.JPOSED..'PAL 10-29-82

ADHINISTR...\TIVE COt\'TROLS

6. 2. 3 NUCLEAR ACTIVITIES PLA~'T ORGANIZATION (NAPO)

FUNCTION c:~~~~~:~~:":~~=~=z~~ ~-

6.2.3.1 The NAPO shall funct-;~~am.;i;ne plant operating c~aracteristics, KRC issuances, industry. advisories, Licensee Event Reports and other sources which may indicate areas for improving plant safety .\/"The organization shall report to the Executive Engineer - NAPO. With the concurrence of the Executive Engineer, NAPO may function as staff to the onsite and offsite *review organizations and provide techriical support for problem resolution and General Office interface.

COMPOSITION 6.2.3.2. The ~APO shall ,be comp9seQ of members located at other Consumers Power cK Comp.iti'y'.~f~crf.1fiies-;'*arfd 7 "6rfEg{~ ;_m~;;i;~fs at the Palisades Plant. The NAPO on site shall consist of fJ."' minimum of five (5) technical personnel. 1 QUALIFICATIONS

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3. 3 ';*Three of the full-timr* meJilbers /\shall each have a bachelor's degree in engineering or a related scier{c!d:-'~:One 'o'f the three shall have* a mLJ.imum of five

~~~!c~Lrrofessional e~perience whic~ includes. a ~~n1imum of tw~, years_' exp~rience. . *,. _

in pov.'er plant operation and/or design./hc;:e ;r.d1i';d1'-*a_l:;.,U,.1(lr1!0>1l'IS 7hi:.. mir:;m...:1-1~ c.:~*"f-'". 1 "'1t'J' c-f:/\:..r:; ,.., 1.:.,..,j ;*,d hc.>'iY"; oe:c..hcfcr'...; d125r'"eG ;,, 1<*..-...; 1-..ecri1>15 or<.l..:-elet:(eJ:.9c:/e}~ce :;hc..11 tu:.>'e,~-r /ec.sTrwc kr§!-~~~Af Pnr~~E;~ie. m*~ytng:\'.I~iv.~' ri/c;~n ~c:p~P£ J(i *~:\poe~'r{~it:'.o~c- aN~t~orary bas is at any nuclear plant location.

REPORTS 6.2.3.4 -~:~eports I? of .NAPO activities shall be 6.3 PLANT STAFF QUALIFICATIO~S 6.3.1 Each member of the plant staff shall meet or e~ceed the m~~~~alifica tions of ANSI Nl8. 1-1971 for comparable positions. . *t:, ~E QU

6. 3. 2 The Plant Health Phys~cist sha~J,....ne(S. ~ ~~ the qualifications of Regu-latory Guide 1. 8, S~ptember 69f5 *'t~ \'::>

• 6.3.3 The~~ 'fb~&11 Advisor/Shift Engineer (STA/SE) shall have a bachelor's degree .o~Vi,alent in a scientific or engineering discipline with specific.

training in plant design and/or operations, and response and analysis of the plant for trarisients and accidents.

• 1 The requirement for a minimum of five (5) technical personnel shall be effective on 1/1/83.

~For the purpose of this section, "Equivalent," as utilized in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following: (a) Formal schooling in science or engineering, or (b) o~erational or technical experience/training in nuclear power.

nu1082-0506a~43-46 6-lb PRCiPOSED/PAL 10-29-82

CONSUM[RS POWCR COMPANY

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AD~HNISTRATIVE CONTBOLS

6. 4 TRAINING 6.4.1 A retraining and replacement training program for the plant\5f!~hall be maintained under the direction of the Director of Nuclear ~~~~~ining, and shall meet or exceed the requirements and recommanti'~ cJl'~ecticn 5.5 of ANSI NlB.1-1971 and Appendix "A" of 10 ~ Q\'t\~\"'Q

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6.4.2 The Director oJ~e~Pro~ection is responsible for the cievelopment, revision, af.~"'{:l~~np~ementation of the Fire Brigade training program. Tnis training ~\.\!', as practicable, meet or exceed the requirements of Section 27 of the NFPA ~ode-1975. Fire Brigade training drills shall be held at least quarterly.

6.5 REVIEW At..1TI AUDIT

6. 5 .1 PLAt-..1 REVIEW COMMITTEE (PRC)

FUNCTION 6.5.1.l The Plant Review Committee (PRC) shall function to advise the Plant General Manager on all matters related to nuclear safety.

~ COMPOSITION G,£, 1, 2..

The PRC shall be composed of:

Chairman: Plant General Manager or Designated Alternate Member: Technical Superintendent Member: Maintenance Superintendent Member: Operations Superintendent Member: Instrument and Control Engineer Member: Reactor Engineer Member: Health Physicist Member: Shift Superviso~

Member: Chemical Engineer Member: Technical Engineer or Supervisory Engineer Member: Shift, Senior or General Engineer ALTERNATES 6.5.1.3 Alternate members of the PRC shall be appointed in ~riting by the PRC Chairman to serve on a temporary basis. However, no more than two alternates shall participate* as )'{voting member5at any one time in PRC acti\*ities.

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MEETING FREQUENCY 6.5.1.4 The PRC shall meet at least once per calendar month, ~ith special meetings as required.

nu1082-0506a-43-46 6-5 PROPOSED.!PAL 10-29-82

AD~lINISTRATIVE CO!\'TROLS QUORU~f.

.6.5.1.5 A quorum for PRC shall consist of the Chairman and four (4) voting members.

RESPONSIBILITIES 6.5.1.6 The PRC shall be responsible for: ...-t~

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a. Review of: (1) all procedures requ-i--r~by Specification 6. B..t$' and changes thereto and (2) any other proposed procedures or changes thereto as determined bv the ~ER=man to affect nuclear safetv.

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• oK b. Review of all proposed tests and experiments that affect nuclear s*afetye"ilne :::cJ:ra:1:i:ge5 tO'- proce~-5'-"tlest-Hbed in th.e_Eina-1--Sa*f~

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c. Review of all proposed changes to Appendix "A" Technical Specifica-tions.

d. Review of all proposed changes or modifications to plan~ystems or equipment that affect nuclear safety.

e. Investigation of all violations of the Technical Specifications. (A report shall be prepared covering evaluation and recommendations to prevent recurrence and forwarded to the Vice President - Nuclear Operations and to .~he Execu~ive Enginee~ - NAPO.)

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~. Review of events requiring 24-hour written notification to the Commission.

Performance of special reviews and investigations and reports thereof as requested by the Plant General Manager or Chairman of NSB.

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nul082-0506a-43-46 6-6 PROPOSED(? .;.1 10-29-82

AD~INISTRATIVE CONTROLS ACTHORITY

..-a<". The PRC shall:

Cc.*, (-tj-, Recommend in writing to the Plant General ~Jar.ager approval or disapproval ,of items considered under Specifica-tions 6.5.1.6.a. through d. above.

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v b, fii-) Render determinations in writirtg with regard to whether or not each item considered under Specifications 6. 5 .1. 6 ~ -antl-ct:. __

above constitutes an unreviewed safety question. ° -fhrc~n C::.'

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• safety ef o.ach item consMered UF1der ~pe.c.i f'j ca-.

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• • ~ Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - Nuclear Operations and to the Vice Chairman of NSB of any disagreement between the PRC and the Plant General Manager; however, the Plant General Manager shall have respon-sibility for the resolution of such disagreements pursuant to Specification 6.1.l above.

. . __._ -<>.-.'.f..he-F.RC-may-d~~c.:t.i..v-i-t:i:es ~ssocic.ted with falf .:.Eing rts

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RECORDS

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• 6. 5. 1. 8 'The PRC shall maintain written minutes of each PRC meeting and shall f ~:* \1 ":; c

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6.5.2 NUCLEAR SAFETY BOARD (NSB) 6.5.2.1 The,Nuclear Safety Board (NSB) is responsible for maintaining a con-tinuing examination of nuclear safety-related Corporate and plant activities a..-id defining oppor~uriit~es. for po}i~y changes relate~. !:o imprc:>ved nu'i_le.e..I safety per1- .

1 formance. ;he. /v*S 13 .s nc~ II c.J{\e ro.1 (.. rn ace ci.~d C'- "*.er;, ..,; 1 f-'r-i a__ w r,-H,,:;.n c *. est e 0 '*ff r:c ~*eo.. b J 1

{/1 *~~~ \.'c(.t: (,-:::>,d'2v.t-/~;.cc,/,;;.,.,_y Uf'*"Tc.::t;*~*{Eo7 whr'c~ de.S-1:j!'a.:te.s fhe. *me*.,*.bers.h,f) ':::..;,:.fhcrif'jJ C<.Yld FUNCTION (Ll!*~c; 1*crcc1*.c.L=h*~-. 3 *;he. ;-...;e'2f,n5.s.

6.5.2.2 The NSB shall function to provide review o~ designated activities in the areas specified in Specification 6.5.2.3 ..

nul082-0506a~43-46 6-7 PR:1POSE:2 'PAL

• 1c-29-82

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AD~lINISTRATI\'E C0!\1ROLS COMPOSITION 6.5.2.3 The NSB shall consist of members appointed by the Vice President -

• Nuclear Operations. NSB shall be chaired by the Executive Director of Nuclear Activities, the Vice Chairman or a duly appointed alternate. The Executive Engineer - NAPO, shall be the Vice Chairman and Secretary, Collectively, personnel appointed for NSB shall be competent to conduct reviews in the following areas:

a. Nuclear Power Plant Operations

b. Nuclear Engineering

c. Chemistry and Radiochemistry

d. Metallurgy

e. Instrumentation and Control

f. Radiological Safety  ; i

g. Mechanical and Electrical Engineering

h. Quality Assurance Practices An individual appointed to NSB may possess expertise in more than one of the above specialties. These individuals should, in general, have had professional experi-ence in their specialty at or above the Senior Engineer level.

ALTERNATE MEMBERS 6.5.2.4 Alternate members may be appointed in writing by the Vice President -

Nuclear Operations* to act in place of members during any legitimate and unavoid-able absences. The qualifications of alternate members shall be similar to those of members.

COl\SULTANTS 6.5.2.5 Consultants shall be utilized as determined by the NSB Chairman or Vice Chairman to provide expert advice to the NSB. NSB members are not restricted as to sources of technical input and may call for separate investigation from any .

competent source.

~fEETING FREQl:ENCY 6.5.2.6 NSB shall meet at least once per calendar quart~r during the initial year of 1acility operation following fuel loading and at least once* every six months thereaffer.

nul082-0506a-43-46 6-8 PROPOSED/PAL 10-29-82

ADMINISTRATIVE CONTROLS QUORUM 6.5.2.7 A quorum of NSB shall consist of the Chairman and four (4) members. (The Vice Chairman may be~ voting member when not acting in the capacity of Chaircan.)

No more than a minority of the quorum shall have line responsibility for operc.t.ion of.the facility. It is the responsibility of the*Chairman to ensure that the quorum convened for a meeting contains appropriately qualified members or has at its disposal consultants sufficient to carry out the review functions required by the meeting agenda.

6.5.2.8 RESPONSIBILITIES REVIEW 6.5.2.8.1 NSB shall be responsible for the review of:

a. Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

b. All events which are required by regulations or Technical Speci-fications to be reported to NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at>d other violations (of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements or of internal procedures or instructions) having nuclear safety sig-nificance.

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c. Issues of safety significance identified by the Plant General Manager, the NSB Chairman, Exe<:<utive Engineer NAPO or the PRC.

d. Proposed changes in the operating license or Appendix "A" Technical Specifications.

e. The results of actions taken to correct deficiencies identified by the audit program specified in Specification 6.5.2.8.2 at least once every six months. . . ~

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f. Safety evaluations* for char{gesA completed under the provisions of 10 CFR 50. 59, to verify that such actions did not constitute an un~evi~wed sa~ety ques~ion:.,. , _ .... """~ ....1.... * * * ,.. 01 ~ ,. LL.. .' Y.",,

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AUDITS ,.,T Gc..f:c::J.t,ft::.;;; ('1.:c. *y,;t:::...e.f-;'~;J::,, t'r hirc.~~jli i et-,c,., c'-t- Ii'-~ ,,1eo: 11 'J r"**r:--1 t::_....

6.5.2.8.2 Audits of operational nuclear safety~related facility activities shall be performed under the cognizance of NSB. These audits shall encompass:

a. The conformance of plant operat-ion to provisions contained ~*1t~1n the Tech~ical Specifications and. applicable license c6nditions at least once per 12 months.

b. The performance, training and qualifications of the entire facility staff at least once per 12 months.

nul0S2-0506a~43-46 6-9 PROPOSE=:* 'PAL

• 10-29-82

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AD~!\ISTRATIVE CONTROLS

c. The performance of activities required by the operational quality assurance program (CPC-2A QAPD) to meet the criteria of Appendix "B," 10 CFR 50, at least once per 24 months.

d. The Site Emergency Plan and implementing procedures at least once per 12 months.

e. The Site Security Plan and implementing procedures (as required by the Site Security Plan) at least once per 24 months.

f. Any other area of plant operation considered appropriate by NSB or the Vice President - Nuclear Operations.

g. The plant Fire Protection Program and implementing procedures at least once per 24 months.

h. An independent fire protection and loss prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

i. 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.

Audit reports encompassed by Specification 6.5.2.8.2 above shall *be forwarded to the .t\SB Vice Chairman and Secretary, and Management positions responsible for the areas audited ~ithin thirty (30) days after completion of the audit.

AFFiORITY 6.5.2.9

__a.--~~F-G~i-=i-+/-tie-s~ied in -5}feti-ficetions-6-:-5-.-2-.-8.-1-.-a-.-and -b*. ,

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~ The NSB Chairman shall report to and advise the Vice President -

Nuclear Operations of significant findings associated with NSB activities and of recommendations related to improving plant nuclear safety performance.

-c.......-.-T-he-NS-B-m*ay--<le.1.e.ga t:e-a:ct:i-\:...i-t i e s-as-s-E>G-i-a.t.ec:Lw.i...th--fu l f :i: 11 ing **its

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de-legat-ed.

nul:S2-0506a-43-46 6-10 PROPOSED/PAL 10-29-82

AD~lINISTRATIVE CONTROLS RECORDS 6.5.2.10 Records of NSB activities shall je prepared and distributed as indicated below: ,:: ; *1; 11 et.ff rG (-I w..(.'Je,_I '\ tv.ic .....,. i:.:..  :.s

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Minutes of each NSB meeting shall* be prepared ~ar:Qed to the Vice President - Nuclear Operations and each NSE memberK~M~ *l~{f:£1 shall be approv:e.cLa:t or be.fur-e -.:he n~-Fe.gu-l-tti-+/-y---sci1edu"ted-mee~gr following the distn.bution o: i::he rninutes.F "" * -:'.~ * ; ed .. ., .. * ,'-,-if-.. \.. ~ ~ J If not included in NSB meeti~g minutes, reports of reviews encom-

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passed by Specification 6.5.2.8.l~>:e,.J shall be prepared *and for-

~ar~ed to the Vice .Presiden~ - Nuclear Operation * "-' * ..* .' ' ... ~ ~~~::::. __.,...:..""":-~,.-

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JI ' . J 6.6 (Deleted) fcl/cv..1;1,5 cc*.-"'f/efi'c11 cf'{ie'('ev/ew.

6. 7 SAFETY LIHIT VIOLATION

6. 7. 1 The foliowing actions shall be take:;. in the event a safety limit is vio-lated:

a. The reactor shall be shut down immediately and not restarted until the Commission authorizes resumption of operation (10 CFR 50.36(c)(l)(i)(A)).

b. The safety limit violation shall be reported within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the Com-mission in accordance with 10 CTR 50.36, as well as to the Vice President - Nuclear Operations and.to the Chairman - ~SB.

c. A report shal 1 be prepared in acco:!:'dance w.ith. 10 CFR 50. 36 and 6. 9 of this specification. (The safety iimit violation and the report shall be reviewed by the PRC.)

d. The report shall be submitted within 14 days to the Commission (in accordance with the requirements of 10 CFR 50.36), to the Vice

.President - Nuclear Operations and to the Chairman - KSB.

6.8 PROCEDURES

6. 8. 1 Written procedures *shal 1 be established, implemented and maintained co\r-ering the activities referenced below:

a. The applicable procedures recom::iende.d in Appendix "A" of Regulatory Guide 1.33 Quality Assurance Program Requirements, as endorsed by CPC72A QAPD.

b. Refueling operations.

c. Surveillance and test activities of safety-related equipment.

nu10S2-0506a?43-46 6- ::.oa PROPOSED/PAL

• 10-29-82

ADMINISTRATIVE CONTROLS

d. Site Security Plan implementation.

e. Site Emergency Plan implementation.

f. Site Fire Protection Program implementation.

6.8.2 PRC is responsible for the review of each procedure of 6.8.1 above, and changes thereto (except for Security Implementing Procedures which are reviewed and approved in accordance with the Site Security Plan). The Plant General Manager shall approve such procedures and changes prior to irnplemen~ation.

6.8.3 Temporary changes to procedures of Specification 6.8.1 above may be made provided:

a. The, intent of the original procedure is not altered.

b. The change is approved by two members (or designated alternates) of the PRC, at least one of whom holds a Senior Reactor Operator's License.

c. The change is documented, reviewed by the PRC at the nex~ regularly scheduled meeting and approved by the Plant General Manager.

nul082-0506a-43-46 6-lOb PROPOSED/PAL 10-29-82