L-77-107, Proposed Amendment to Facility Operating License. Specification 6.8.3.C Time Limit for Facility Review Group Review & Plant Manager Approval of Temporary Procedure Changes Is Extended from 7 Days to 14 Days

Proposed Amendment to Facility Operating License. Specification 6.8.3.C Time Limit for Facility Review Group Review & Plant Manager Approval of Temporary Procedure Changes Is Extended from 7 Days to 14 Days

ML18096B662
Person / Time
Site:	Saint Lucie
Issue date:	04/04/1977
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-77-107
Download: ML18096B662 (11)

Text

U.S. NUCLEAR REGULATORY Co 'SION NRC FoRM 195 (2 76)

FILE NUMBER NRC DISTRIBUTION FoR PART 50 DOCKET MATERIAL FROM: DATE OF DOCUMENT TO:

Florida Power & Light Company 4/4/77 Mr. Victor Stello Miami', Florida DATE RECEIVED Robert E. Uhrig 4/6/77 o

" ~TTE R NOTOR IZED PROP INPUT FORM NUMBER OF COPIES RECEIVED

~ RIG INAL Pj" NCLASSIFIED COPY

+~gal DESCRIPTION ENCLOSURE I M.~

Ltr. trans the, following: Amdt; to. OL/change to A'ppendix A tech specs ..concerns extension from 7 days to 14 days the spec. 6, 8. 3 c time'imit for Facility Review Group review and Plant Mgt.

approval of temporary'procetIures changes

~ .notorized,4/4/77 ~ ~ ~ ~ ~

PLANT NAME:

(1-P) (4-P)

RJL SAFETY FOR ACTION/INFORMATION ASSIGNED AD:

RO ECT MANA PROJECT MANAGER~

LIC~ ASST LIC ASST 0 INTERNAL D IST RIBUTION REG FILE SYSTEMS SAFETY PLANT SYSTEMS S TE SAFE NRC PDR 'EINEMAN TEDESCO I&E(% SCHROEDER N 0 OELD GOSSICK & STAFF ENGINEERING IPPOLITO MIPC ERNST CASE BOSMK BALLARD SIHWEIL OPERATING REACTORS YOUNGBLOOD HARLESS PAWLICK STELLO SITE TECH PROJECT MANAGEMENT REACTOR SAFE OPERATING TECH GAMIIILL BOYD ROSS EISENHUT STEPP PE COLLINS NOVAK HULMAN HOUSTON ROSZTOCZY PETERSON CHECK BUTLE SITE ANALYSIS MELTZ VOLLMER HELTEMES AT& I BUNCH SKOVHOLT SALTZMAN J COLLINS RUTBERG KREGER EXTERNAL DISTRIBUTION CONTROL NUMBER LPDR' e~ NAT LAB O e TIC: REG V IE ULR KSON OR NSIC:

ASLB:

LA PDR CONSULTANTS:

q t o~qeqig ACRS CYS STING/ ET CM ApZ NRC FORM 195 (2.76

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FLORIDA POWER 8( LIGHT COMPANY April

~LI1INIl M~ klE LOOI 4, 1977 L-77-107 Office of Nuclear Reactor Regulation Attention: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission c p Washington, D. C. 20555

Dear Mr. Stello:

Re: St. Lucie Unit 1 Docket No. 50-335 Proposed Amendment to Facility Operatin License DPR-67 In accordance with 10 CFR 50.30, Florida Power 6 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating License DPR-67.

The proposed amendment is described below and shown on the accompanying Technical Specification page bearing the date of this letter in the lower right hand corner.

Pa e 6-14 The Specification 6.8.3.c time limit for Facility Review Group review and Plant Manager approval of temporary procedure changes is extended from 7 days to 14 days.

The proposed amendment is, based on the Standard Techni'cal Specifications for the various Pressurized Water Reactors.

has been reviewed by the St. Lucie Plant Facility. Review'roup It and the Florida Power 6 Light Company Nuclear Review Board and they have concluded that it does not involve an unreviewed safety question. A written safety evaluation is attached.

Very truly yours, Robert E. Uhrig Vice President REU/MAS/cpc g y'yy g~+/M Attachment cc: Mr. Norman C. Moseley, Region Robert Lowenstein, Esquire II PEOPLE... SERVING PEOPLE

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A~CHMENT TO L-77-107 A~1 4, 1977 SAFETY EVALUATION Introduction This safety evaluation supports a proposed revision to Technical Specification 6.8.3.c, which would extend the time limit for Facility Review Group,(FRG) review and Plant Manager approval of temporary changes to procedures from 7 days to 14 days.

Discussion Plant activities are conducted in accordance with preplanned methods which are described in approved procedures. Periodically these procedures need to be revised. There are two methods by which this can be done. First, procedures can be changed by FRG review and Plant Manager review and approval prior to the change taking effect. This is the method used for almost all procedure changes. Second, procedures can be changed more quickly, if necessary, by using She temporary change option permitted by Technical Specification 6.8.3. This method is provided in case a relatively rapid procedure change is needed to allow for handling conditions beyond the scope of the original procedure, to prevent an unnecessary delay in operation or maintenance, or to handle conditions encountered in implementing a procedure which were no't an'ticipated when the procedure was first written. Both of the procedure plant change methods described procedures.

above are authorized by approved A temporary change is made only if it does not change the intent of the procedure, does not conflict with other facility require-ments, does not adversely affect nuclear safety, and is approved by at least two authorized members of the plant management staff.

The Facility Review Group (FRG) then reviews the, temporary change at a later date. The FRG can cancel the temporary change, modify it, or establish it as a permanent change.

Manager then acts on the FRG recommendation regarding the The Plant temporary change.

Since it is implicitly understood that performance of an approved procedure does not involve an unreviewed safety question, then any temporary change to that procedure which does not change the intent of the procedure also does, not involve an unreviewed safety question. Therefore, a written safety evaluation is not required prior to on-the-spot approval of a temporary change and the FRG is not, required to act immediately to review it.

Under the current St. Lucie Unit 1 Technical Specifications, the FRG 'is allowed 7 days to review temporary changes. However, the Administration Section of the Standard Technical Specifica-tions (STS) permit as much as 14 days for review of temporary changes. Florida Power 6 Light Company requests authorization to utilize the longer time frame permitted by the STS in order to establish greater flexibility in scheduling FRG meetings.

I SAFETY EVALUATION (Continued)

Conclusions The requested change is administrative in nature and does not involve any physical change to the facility, nor does it represent, a significant deviation from present operating philosophy.'ased on the above considerations, (1) the proposed change does not increase the probability or consequences of accidents or malfunctions of equipment important to safety and does not reduce the margin of safety as defined in the basis for any technical specification, therefore, the change does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

AOMINISTRATIVE CONTROLS 6.8.3 Temporary changes to procedures of 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 of theplant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.

c. The change is documented, reviewed by the FRG and approved by the Plant 'Manager within 1< days of hnplemeritstion.

6.9 REPORTING RE UIREMENTS ROUTINE REPORTS Al'lD REPORTABLE OCCURRENCES 6.9.1 Information to be reported to the Commission, in addition to 'the reports required by Title'1.0, .Code of Federal Regulations, shall be in accordance with the Regulatory Position in Revision 4 of Regulatory Guide 1.16, "Reporting of Operating Information - Appendix "A" Technical Specifications."

SPECIAL REPORTS 6.9.2 Special reports shall be submitted to the Oirector of the Office of Inspection and Enforcement Regional Office within the time period specified for each report. These reports shall be submitted covering the activities identified below pursuant to the requirements of the applicable reference specification:

a. Inoperable Seismic- Monitoring Instrumentation, Specification 3.3.3.3.

b. 'noperable Meteorological Monitoring Instrumentation, Specification 3.3..3.4.

C. Inservice Inspection Program Reviews, Specifications 4.4.10.1 and 4.4.10.2.

d. ECCS Actuation, Specifications 3.5.2 and 3.5.3.

e. Sealed Source leakage in ex'ce'ss of limits, Specification 4.7.9..1.3.

f. Sei smi c event anal ys i s, Speci fi cation 4.3.3.3.2.

g. Beach survey results, Specification 4.7.6.1.1 ST. LUCIE - UNIT 1 6-14.

4/4/77

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STATE OF FLORIDA )

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COUNTY OF DADE )

Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Vice President of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the state-

.ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document, on behalf of said Licensee.

Robert E. Uhrig Subscribed and sworn to before me this day of

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Z:PUBLIC, in and f. r the County of Dade,

-State~ o f Plorida NofARY PImUC STATE Of fLORICA AT LhIIQf MY COMMISSION EXPIRES NOV, 30 1919

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My commission expires: >oIGE0 THIIIj +N'+*< TNs UIGE++tIE+

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