ML17222A745
| ML17222A745 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 04/04/1989 |
| From: | FLORIDA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML17222A744 | List: |
| References | |
| NUDOCS 8904180014 | |
| Download: ML17222A745 (21) | |
Text
ATTACHMENT 1 Marked-up St. Lucie Unit 1 Technical Specification Pages:
6-9 (plus insert) 6-12 EJWPLA2 85'04180014 890404 PDR ADOCK 05000335 P
Af:iiINISTRAT IVE CONT
'6.5.2 COHPANY NuCLEAR REVIEW BOARD CNRB F'".iCTIOil I
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-h Company Nuclear Review Board shall function to provide indepen-dent review and audit of designated activities in the areas of a.
nuclear power plant operations b.
nuclear engineering c.
chemistry and radiochemistry d.
metallurgy e.
instrumentation and control f.
radiological safety g.
mechnical and electrical engineering h.
quality assurance practices COMPOSITION pager k p~c4J ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the CNRB Chair-man to serve on temporary basis;
- however, no more than two alternates shall participate as voting members in CNRB activities'at any one time.
ST.
LUCIE - UNIT 1
6-9 Amendment No. 28,$ $,$9. PPs
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Insert Page 6-9 6.5.2.2 The Executive Vice President shall appoint at least ten members to the CNRB and shall designate from this membership, in writing, a Chairman.
The membership shall function to provide independent review and audit in the areas listed in Specification 6.5,2.1.
All members shall have at least a Bachelor' degree in engineering, related sciences or equivalent experience per ANSI/ANS-3.1
- 1978Property "ANSI code" (as page type) with input value "ANSI/ANS-3.1</br></br>- 1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as endorsed by Regulatory Guide 1.8, September 1975 (reissued May 1977),
Section 4.1, and at least 5 years of cumulative professional level experience in one or more of the fields listed in Specification 6.5.2.1.
The Chairman shall have nuclear background in engineering or operations and shall be capable of determining when to call in experts to assist the CNRB in review of complex problems beyond the scope of the CNRB's expertise.
The Chairman shall have at least 6 years of professional level management experience in the nuclear power field.
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ADMINISTRATIVE CONTROLS
-'UTHQRITY 6
5 2
9 The CNRB sha1 1 report to and advi se the Executive Vice President on
-pose areas of responsibility specifed in Specifications 6.5.2.7 and 6.5.2.8.
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ECOROS I,'.5,2.10 Records of CNRB activities shall be prepared, approved and distrib-
~ ~ted as indicated below:
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I a.
b.
Minutes of each CNRB meeting shall be prepared, approved and forwarded to the Executive Vice President within 14 days following each meeting.
Reports of reviews encompassed by Section 6.5.2.7
- above, shall be
- prepared, approved and forwarded to the Executive Vice President within 14 days following completion of the review.
c.
Audit reports encompassed by Specification 6.5.2.8
- above, shall be forwarded to the Executive Vice President and to the management positions responsible for the areas audited within 30 days after
'ompletion of the audit by the auditing organization.
6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
a.
The Commission shall be notified and a report submitted pursuant
".o the requirements of Section 50.73 to 10 CFR Part 50, and b.
Each REPORTABLE EVENT shall be reviewed by the
- FRG, and the results of the review shall be submitted to the CNRB, and the Senior Vice President - Nuclear.
6.7 SAFETY LIMIT VIOLATION C]v RG 6.7.1 The following actions shall be taken i the event a Safety Limit is violated:
a.
'The NRC Operations Center shall e notified by telephone as soon as possible and in all cases w'in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The Senior Vice President - Nuclear and the sh'all be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
b.
A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the FRG.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures, and (3) corrective action taken to prevent recurrence.
ST.
LUGIE - UNIT 1
6-12 Amendment No.
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ATTACHMENT 2 Marked-up St. Lucie Unit 2 Technical Specification Pages 6-1 6-6 6-10 (plus insert)
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RESPONS Ie ILITV 6.1.1 The Plant Manager shall be responsible for overall unit operation and shaII delegate in wr iting the succession to this r esponsibility during his absence 6.1.2 The Shift Supervisor, or during his absence, from the control
- room, a
designated individual, shall be responsible for the control room command function.
A management directive to this effect, signed by the Senior Vice President
- Nuclear
, shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION ONS ITE ANO QFFS ITE ORGANIZATION 6.:. I An onsite and an offsite organization shall be established for unit operation and corporate management.
The onsite and offsite organization shaI'I include the oositions for activities affecting the safety of the nuclear power plant.
a.
Lines of authority, responsibility and comm a fon shall be established and defined from the highest man gement levels through intermediate levels to and'including all operating organization positions.
Those relationships shall be documented and updated, as appropriate, in the form of organizational charts.
These organizational charts will be documented in the Topical guality Assurance Report and updated in accordance with 10 CFR 50.54(a)(3}.
b.
The. Senior Vice President - Nuclear shall be responsible for overall plant nuclear safety.
This individual shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and"providing technical support in the plant so that continued nuclear safety is assured.
c.
The. Plant Manager shall. be responsible for overall unit safe operation and shall have control over thoseonsite resources necessary for safe operation and maintenance of the plant.
d.
M though the individuals who train the operating staff and those who carry out the quality assurance fdnctfons may report to the appropriate manager onsite, they shall have sufficient organiza-tional freedom to be independent from operating pressures.
e.
Although health physfcs individuals may report to any appropriate manager onsi te, for matters relating to radiological health and safety of employees and the public, the health physics manager shall have dfrect access 'to that onsite individual having responsibility for overall unit management.
Health physics personnel shall have the authorfty to cease any work activity when worker safety fs jeopardized or in the event of unnecessary personnel radiation exposures.
ST.
LUCIE - UNIT 2 Amendment No l8s
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, ANINISTRATIVE CONTROLS 6,2.3 INOEPENOENT SAFETY ENGINEERING GROUP ISEG FDNCT1DR 6.2.3.1 The ISEG shall function to examine plant operating characterfstlcs, NRC fssuances, industry advfsorfes, Licensee Event Reports and other sources of plant desfgn and operating experience informatfon, including pl.ants of simflar design, which may indicate areas for i oving plant safety.
BdlC.LC led 'S COMPOSITION 6.2.3.2 The ISEG shall be composed of varied backgrounds and disciplines rela than two members shall be assigned from the members shall be engineers with a fve dedicated, full-time members with ed to nuclear power plants.
No more any one department.
Three or more of degree fn engfheeefhg or -a=.
RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of selected plant activitfes to provide independent verification* that these activities are performed correctly and that human errors are reduced as much as practical.
The ISEG shall make detailed recomnendatfons for revised procedures, equipment modi-fications, maintenance activities, operations actfvftfes, or other means of improving plant safety to the AUTHORITY 5;4 Vlcc. Pew;J~- Rf./.uc'c Pl~~/
6.2.3e4 The SEG fs an onsfte independent technfcal review group that reports
-ef4shh~ to the The ISEG shall have the authority necessary to perform the functions and responsibilities as delineated above.
RECORDS 6.2.3.5 Records of actlvltles performed by the 1SEG shall be prepared main,-
tained and a report of the activities forwarded each calendar month to the S,g (g;~ Pnme:dc 4-6.2.4 SHIFT TECHNICAL ADVISOR sS.~~em P/..~>
The Shift Technical Advisor function is to provide on shift advfsory technical support in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit.
6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI/ANS-3.1-1978 as endorsed by Regulatory Gufde 1.8, September 1975 (reissued May 1977), except for the (1) Health Physics Supervisor who shall meet P
Not respons e
or sign-off function.
~elated science, with at least 2.years of professional level experfence in the nuclear field.
Any nondegreed ISEG members will either be licensed as a Reactor Operator or Senior Reactor Operator, or will have been previously licensed as a
Reactor Operator or Senior Reactor Operator within the last year at the St. Lucfe Plant site; or they will meet the"qualifications of a department head as specified in Specification 6.3.1 of the St. Lucie Unit 2 Technfcal Specifications.
The qualifications of each nondegr eed candidate for the ISEG shall be approved by the
, pr for to jofnfng the group.
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ST.
LUCIE - UNIT 2 6-6 Amendment No.
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'Ot4INISTRATIVE CONTROL FUNCTION (Continued) instrumentation and control radiological safety mechanical and electrical engineering qual i ty assurance practices COMPOS I7 ION
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ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the CNRB Chairman to serve on a temporary basis;
- however, no more than two alternates shall participate as voting members in CNRB activities at any one time.
CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the CNRB Chairman to provide expert advice to the CNRB.
MEETING FRE UENCY 6.5.2.5 The CNRB shall meet at least once per calendar quarter during the initial year of unit operation following fuel loading and at least once per 6 months thereafter and as convened by the CNRB Chairman or his designated alternate.
QUORUM gore~
6.5.2.6 he ~~m of the CNRB necessary for the performance of the CNRB review and audit functions of these Technical Specifications shall consist of the Chairman ~ his designated alternate and at least four CNRB members including alter ates.
No more than a minority of the quorum shall have line responsibility or operation of the unit.
ST.
LUCIE - UNIT 2 6-10 Amendment No. Jg, 29
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Insert Page 6-10 6.5.2.2 The Executive Vice President shall appoint at least ten members to the CNRB and shall designate from this membership, in writing, a Chairman.
The membership shall function to provide independent review and audit in the areas listed in Specification 6.5.2.1.
All members shall have at least a Bachelor' degree in engineering, related sciences or equivalent experience per ANSI/ANS-3.1
- 1978Property "ANSI code" (as page type) with input value "ANSI/ANS-3.1</br></br>- 1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as endorsed by Regulatory Guide 1.8, September 1975 (reissued May 1977),
Section 4.1, and at least 5 years of cumulative professional level experience in one or more of the fields listed in Specification 6.5.2.1.
The Chairman shall have nuclear background in engineering or operations and shall be capable of determining when to call in experts to assist the CNRB in review of complex problems beyond the scope of the CNRB's expertise.
The Chairman shall have at least 6 years of professional level management experience in the nuclear power field.
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ATTACHMENT 3 Safet Anal sis Introduction These proposed license amendments are typographical errors in the Administrative Review Board (CNRB) specific composition statement defining the requisite level of the Independent Safety Engineering Group requirements (St. Lucie Unit 2 only).
intended to make corrections to Controls, delete the Company Nuclear list and replace it with a general expertise for membership, and revise (ISEG) reporting and administrative discussion o
Typographical Errors St. Lucie Unit 1 Specification 6.7.1 a.
on page 6
12 has a typographical error in the last line; "CNBR" should read "CNRB".
St Lucie Unit 2 Specification 6.2.1 a.
on page 6
1 has a typographical error in the first line; "communcation" should read "communication"
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Specification 6.2.3.2 on page 6 - 6 has a typographical error in the fourth line; "bachelor" should read "Bachelor'".
Specification 6.5.2.6 on page 6
10 has a typographical error in the first line; "quorom" should read "quorum".
Additionally, the statement
"...shall consist of the Chairman and his designated alternate..."
should read "...shall consist of the Chairman or his designated alternate...".
t By proposed license amendment request L-87-145, dated March 31,
- 1987, FPL requested various administrative changes to the St.
Lucie Unit 2 Technical Specifications.
On October 23,
- 1987, by Amendment No.
25 to St. Lucie Unit 2 Operating License NPF-16, the NRC issued the requested amendment.
However, in issuing the amendment, two typographical errors resulted
- the mis-spelling of "quorum" and "and" being replaced for "or". It should be noted that the similar specification for St.
Lucie Unit 1, Specification 6.5.2.6, states
"...shall consist of the Chairman or his designated alternate...".
o Company Nuclear Review Board (CNRB) Composition St Lucie Units 1 and 2
Specification 6.5.2.2 in both Units'echnical Specifications lists by title the ten members of the CNRB.
This list requires revision each time an organizational EJWPLA2
<<4 change occurs, or when the titles of CNRB members are changed.
In fact, this Specification of the St. Lucie Unit 1 Technical Specifications has been revised 5 times in the last 12 years and the St. Lucie Unit 2 Technical Specification has been revised 3 times in the last 5 years'nother change to both Units'echnical Specifications is now required.
These changes result in the expenditure of FPL and NRC staff resources for processing license amendments which have no effect on plant safety.
To obviate the need for future amendments to the CNRB composition resulting from organizational or title changes, FPL proposes to delete the specific composition list for the CNRB and replace it with a statement defining the composition of the CNRB and specifying the requisite level of technical, operational, and nuclear management expertise for CNRB membership.
This statement requires the FPL Executive Vice President to appoint at least ten members to the CNRB and designate from this membership, in writing, a Chairman.
The membership shall function to provide independent review and audit of designated activities in the following areas, as listed in the Technical Specifications:
a.
nuclear power plant operations b.
nuclear engineering c.
chemistry and radiochemistry d.
metallurgy e.
instrumentation and control f.
radiological safety g.
mechanical and electrical engineering h.
quality assurance practices All members shall have at least a Bachelor's degree in engineering, related sciences or equivalent experience per ANSI/ANS 3.1 1978 as endorsed by Regulatory Guide 1.8, September 1975 (reissued May 1977), Section 4.1, and at least 5 years of cumulative professional level experience in one or more of the fields listed in Specification 6.5.2.1.
The Chairman shall have nuclear background in engineering or operations and shall be capable of determining when to call in experts to assist the CNRB in review of complex problems beyond the scope of the CNRB's expertise.
The Chairman shall have at least 6 years of professional level management experience in the nuclear power field.
This proposal is consistent with recent NRC practice in defining requirements in the Technical Specifications for Near Term Operating Licenses (NTOLs) for the offsite corporate overview committee.
The paragraph which is proposed to replace the CNRB composition list ensures that there will be no reduction in the collective talents of the CNRB and that the quality and scope of independent review will be maintained.
St Lucie Unit 2 The St. Lucie Unit 2 Technical Specifications, Specification 6.2.3.3 currently
- requires, "The ISEG shall make detailed recommendations to the Assistant Chief Engineer
- Power Plant Engineering".
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"Clarificatj.on of TMI Action Plan Requirements",
NUREG-0737, November, 1980, Item I.B.1.2, "Independent Safety Engineering Group" discusses the.establishment of an onsite Independent Safety Engineering Group (ISEG) intended to perform independent review of plant operations.
NUREG-0737 further discusses that the principal function of the ISEG is to examine plant operating characteristics, NRC issuances, and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety.
The ISEG is intended to perform independent review and audits of plant activities including maintenance, modifications, operational
- problems, and operational
- analysis, and aid in the establishment of programmatic requirements for plant activities.
Where useful improvements can be achieved, it is expected that this group would develop and present detailed recommendations to corporate management for such things as revised procedures or equipment modifications.
Another function of the ISEG is to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable.
ISEG will then be in a position to advise utility management on the overall quality and safety of operations.
ISEG is not required to perform detailed audits of plant operations and is not responsible for sign-off functions such that it becomes involved in the operating organization.
0 The St. Lucie Unit 2 ISEG is located onsite and currently, as required by NUREG-0737, reports offsite to an FPL official in a high level, technically oriented position that is not in the management chain for power production, i.e.,
the Assistant Chief Engineer
- Power Plant Engineering.
On September 1,
- 1988, FPL implemented organizational changes to include the nuclear plant engineering function within the Nuclear Energy Department.
As a result of these organizational
- changes, the position of Assistant Chief Engineer Power Plant Engineering was eliminated from the nuclear organization line responsibility.
The ISEG currently reports to the Manager Nuclear Engineering Technical (the Nuclear Energy Department position most closely resembling the level of responsibility of the prior Assistant Chief Engineer Power Plant Engineering).
FPL now proposes an alternative approach to TMI Item I.B.1.2 to meet the intent of safety oversight.
This proposed change is discussed below.
The ISEG is responsible for independent review of a variety of topics, as discussed
- above, not all of which are under the direct control of the nuclear engineering corporate staff organization, e.g., plant operations, maintenance, operational analysis, etc.
As a result, the reporting responsibility of the ISEG is more broadly based than purely "engineering" related issues and encompasses diverse nuclear topics from maintenance to fuels to chemistry and radiation controls.
As a result, since the ISEG produces a product which is more wide ranging than solely engineering related topics, it is logical that the customer of this organization make use of the ISEG's product from an integrated nuclear safety viewpoint.
FPL's nuclear power plant responsibility is stated in Technical Specification 6.1.1:
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"The Plant Manager shall be responsible for overall unit operation..."
Additionally, Specification 6.2.1 c. states:
"The Plant Manager shall be responsible for overall unit safe operation and shall have control over those onsite resources necessary for safe operation and maintenance of the plant".
FPL's Nuclear Energy organization is discussed in FPL's "Topical Quality Assurance Report" (TQAR).
The Nuclear Energy Department is responsible for the operation, maintenance, refueling and modification of St.
Lucie Unit 2 in accordance with written and approved procedures.
FPL's nuclear organization structure is shown in TQAR Figure 1-1 (attached).
The Site Vice President
-St.
Lucie is accountable for the operation, maintenance, and modification of St.
Lucie Plant.
He acts as liaison between St.
Lucie Plant and the corporate nuclear energy organization.
Since the Plant Manager is "... responsible for overall unit safe operation..."
and has "... control over those onsite resources necessary for safe operation and maintenance..."
his responsibility, as indicated in Figure 1-1 confirms him as FPL's line manager for St.
Lucie Unit 2.
While assigned to the site, and physically located there, the Site Vice President
- St. Lucie can be seen to be in an oversight mode for safe operation and maintenance of the unit.
This position makes him uniquely qualified to receive the reports of the ISEG.
His day-to-day presence at the site puts him in the best position to appreciate all aspects of the independent examination of plant operating characteristics, NRC issuances, and other appropriate sources of plant design and operating experience information that may indicate opportunities for further enhancing plant safety.
As a result, it is proposed that Specification 6.2.3.2 be revised to require non-degreed candidates for the ISEG be approved by the Site Vice President
- St.
Lucie prior to joining the group; that Specification 6.2.3.3 be revised to require the ISEG to make its detailed recommendations to the Site Vice President St. Lucie; that Specification 6.2.3.4 be revised to delete "offsite" and to require the ISEG to report to the Site Vice President
- St.
Lucie; and that Specification 6.2.3.5 be revised to require ISEG activity reports be forwarded to the Site Vice President
- St. Lucie each calendar month.
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ATTACHMENT 4 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulations, 10 CFR 50.92, which states that no. significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a
new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety.
Each standard is discussed as follows:
(1)
Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed changes are administrative in nature and do not affect assumptions contained in the safety analyses nor do they affect Technical Specifications that preserve safety analysis assumptions.
Additionally, these changes do not modify the physical design and/or operation of the plant.
Therefore, the proposed changes do not affect the probability or consequences of accidents previously analyzed.
(2)
Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The changes being proposed are administrative in nature and willnot lead to material procedural changes or to physical modifications to the facility.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident.
(3)
Use of the modified specification would not involve a significant reduction in a margin of safety.
The changes being proposed are administrative in nature and do not relate. to or modify the safety margins defined in or required and maintained by the Technical Specifications.
The typographical corrections proposed do not affect any margin of safety.
The deletion of the composition list of Company Nuclear Review Board (CNRB) membership and replacement with qualifications requirements guidelines will not decrease the effectiveness of this organization's independent review scope nor will there be a
reduction in the collective talents of the CNRB.
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The changes proposed to the Independent Safety Engineering Group (ISEG) administrative control and reporting requirements will focus the control, reports and reporting requirements of the ISEG to the Site Vice President
- St. Lucie, Florida Power 6 Light Company (FPL) and thus ensure the most efficient and effective use of the ISEG's products.
- However, changing the administrative control and reporting requirements will not affect any margin of safety.
Based on the above, we have determined that the proposed amendment does not (1) involve significant increase in the probability of consequences of an accident previously evaluated, (2) create the probability of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazard consideration.
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