ML20044B267

Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Spec Change Request 89-15-0,changing Tech Spec Section 6.0 to Add New Section 6.5.3 Re station- Qualified Reviewer Program

ML20044B267
Person / Time
Site:	Limerick
Issue date:	07/13/1990
From:	Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20044B268	List: ML20044B267 ML20044B269
References
NUDOCS 9007180245
Download: ML20044B267 (9)

Text

i,. 10 CFR 50.90 -[

PHILADELPHIA ELECTRIC COMPANY ,

NUCLEAR GROUP HEADQUARTERS l 955-65 CHESTERBROOK BLVD.  !

i WAYNE, PA 19087 5691 (u si sao soco July 13, 1990 Docket Nos. 50-352 50-353  :

License Nos. NPF-39 l NPF-85 i l

U.S. Nuclear Regulatory Commission Attn: Document Control Desk

. Washington, DC 20555 '

SUBJECT:

Limerick Generating Station Units 1 and 2 Technical Specifications Change Request '

Dear Sir:

Philadelphia Electric Company hereby submits Technical Specifications Change Pequest No. 89-15-0 in accordance with 10 CFR 50.90. requesting an amendment I

.totheTechnicalSpecifications(TS)(AppendixA)ofOperatingLicenseNos.NPF-39  ;

and NPF-85. Information supporting this Change Request is contained in Attachment 1 l to this letter, and the proposed replacement pages are contained in Attachment 2.

This submittal requests changes to TS Section 6.0, including the addition Lof a new TS Section 6.5.3, to reflect the implementation of a Station Qualified t l Reviewer (SQR) Program for review and approval of new station programs, procedures.

and changes thereto.

p If you have any questions regarding this matter, please contact us.

l  !

/ Very truly yours.

N

.26 M G. A. unger, Jr. / '

Manager e Licensing Section ,

Nuclear Engineering and Services 9007180245 900713 PDR ADOCK 05000352 .;

P PDC '

Attachments cc: ,T. T. Martin, Administrator, Region I. USNRC 00 T. J. Kenny,~USNRC Senior Resident inspector, LGS

.T. M. G,erusky, Director, PA Bureau of Radiological Protection iIk [

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COMMONilEALTH OF PENNSYLVANIA S 4

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COUNTY OF CHESTER  :

D. R. Helwig, being first duly. sworn, deposes and says:

That he is Vice President of Philadelphia Electric Company; the Applicant hereint that he has read the foregoing Application for o - Amendment of Facility Operating License Nos. NPF-39 and NPF-85 (Technical Specifications Change Request No. 89-15) to reflect the implementation of a Station Qualified Reviewt' Program, and knows the contents thereof; and that the statements and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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Vice Preside P

Subscribed and sworn to

beforeme.this13Tay of ,>d ,1990.

y fet/mNs d. "h t wdn i Notary Public CATHERN E E2 Nothry Pubhc JCJ32:rLSTka

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ATTACHMENT 1 L.

L LIMERICK GENERATING STATION

..f m< Units 1 and 2-Il, ,- :

. Docket Nos. .50-352-1e- 353 te License Nos.'NPF-39 NPF-85 e

LTECHNICAL SPECIFICATIONS CHANGE REQUEST

- " Station Qualified Reviewer ~ Program" Supporting information for Changes 6 pages y.

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Docket NCs. 50-352 a'

50-353 License Not. NPF-39 ,

NPF-85 l

l l

Philadelphia _ Electric Company (PECo), Licensee under Facility Operating Licenses HPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2. respectively, i lereby requests that'the Technical Specifications (TS) contained in Appendix A of the Operating Licenses be amended as proposed herein to reflect the implementation of a Station Qualified Reviewer (SQR) Program for the review and approval of new programs, procedures, and changes thereto at LGS. The proposed changes are indicated by a i vertical bar in the margin of pages xxvii (INDEX), 6-8. 6-12, 6-12a (new page), 6-13 and 6-19 for both LGS Unit I and Unit 2 TS, and are contained in Attachment 2.

t We request the changes proposed herein to be Jffective upon issuance of the Amendments. '

This Change Request provides a discussion and description of the proposed TS '

changes, a safety assessment of the proposed TS changes, information supporting a finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment. '

Discussion and Description of Changes TheStationQualifiedReviewer(SQR)Programisaprogram/proceduralreviewand approval process using qualified reviewers to perform a review and designated  ;

Superintendents for approval of new programs, procedures, and changes thereto. This program has been approved by the NRC for the Public Service Electric and Gas (PSE&G)

Company facilities. There are two key areas of importance under the SQR program.

The Plant Operations Review Comm?ttee (PORC) will no longer be required to render a determination as to whether or not a new program. procedure, or change thereto constitutes an unreviewed safety question (USQ) in accordance with 10 CFR 5C.59, i PORC will no longer be required to review and recommend approval / disapproval of new programs or program changes and certain types  ;

of procedures or procedure changes to the Plant Manager.  ;

l'

' t l The responsibility and authority to perform these functions will be transferred to responsible Superintendents designated by the Plant Manager. .

A brief description of how this program will be implemented at LGS is provided below.

1 i

o The PORC Chairman approves plant personnel recommended to be Station I Qualified Reviewers (SQRs) for specific types of programs and classes of .

L' procedures. The SQR will be an individual knowledgeable in the functional area affected and may be from the same organization, but who is not the individual preparer.

P

1 a * .

Docket Nos. 50-352 50-353 i 1

License Nos. NPF-39 i NPF-85 o The Plant Manager, as authorized by Administrative Procedures, appoints l plant Superintendents to be responsible for approving specific types of  ;

programs and classes of procedures. The appointed Superintendent will be the individual responsible for and cognizant of the affected functional area.

o Each new program, procedure, or change thereto is reviewed by the designated SQR. The SQR determines when a cross-disciplinary review by .

other personnel is necessary prior to ap roval. The new program. '

procedure, or change thereto and accompanying 10 CFR 50.59 Review ,

documentation (i.e.,evaluationoftheproposedchange,newprocedureor '

new program in accordance with 10 CFR 50.59) is reviewed by the.  :

responsible Superintendent, including a determination as to whether a 10 CFR 50.59 safety evaluation is required or not. If not, the new program, '

procedure, or change thereto is then approved by the responsible Superintendent or the Plant M eager. If a 10 CFR 50.59 safety evaluation is required, the entire new progism, procedure, or change package, including the 10 CFR 50.59 safety evaluation, is reviewed by PORC.

o- PORC continues to be responsible for the review and recommendation for '

approval / disapproval of Administrative Procedures, and any new program, procedure, or change thereto that requires an unreviewed safety question >

determination (i.e.,10CFR50.59safetyevaluation)beperformed, o The Plant Manager continues to be responsible for the approval of 4 Admi11strative Procedures. Security Plan Implementing Procedures.

Emergency Plan implementing Procedures, and any new program, procedure, or change thereto that requires an unreviewed safety question determination

, (i.e., 10 CFR 50.59 safety evaluation) be performed.

I  !

o Temporary procedure changes (TPCs) will be implemented as before, however, the TPC will be reviewed by the designated SQR (including a cross- ,

disciplinary review, if necessary) and approved by the Plant Manager or '

' responsible Superintendent, as appropriate, within 14 days of implementation.

i 1

L 1mplementing the SQR Program at LGS, Units 1 and 2 will involve the proposed TS changes described below. All changes are reflected in the unit specific TS pages y contained in Attachment 2.  !

1. . '

Revise TS Section 6.5.1.6.a to read " Review of (1) Administrative Procedures and changes thereto, (2) ner programs or procedures required by Specification 6.8 and requiring a 10 CFR 50.59 safety evaluation, and (3) proposed changes to programs or procedures required by Specification 6.8 and requiring a 10 CFR 50.59 safety evaluation;" to indicate the reduction l

in the scope of PORC's program / procedural review. -

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Docket Nos. 50-352

. SC 353  !

License Nos. HPF-39 I NPF-85 j s

2. . Revise TS Section 6.5.1.6.e to read " DELETED." The new provisions added  !

under. item #4 below will require PORC to review 10 CFR 50.59. safety  !

evaluations for those new procedures and changes to existing procedures for which a 10 CFR 50.59 safety evaluation is prepared as part of the l overall new procedure or procedure change package. Therefore, the  ;

requirement for PORC to review 10 CFR 50.59 safety evaluations associated  ;

with procedures and changes thereto can be deleted.  ;

3. Change the reference to TS Section "6.5.1.6a" under TS Section 6.5.1.7b to' ,

read "6.5.1.6b" to indicate that PORC will no longer be responsible for +

rendering determinations in writing with regard to whether or not new ,

programs, procedures, or changes thereto constitute an unreviewed safety  :

question. The responsibility and authority for this function is  !

transferred to the responsible Superintendent under the SQR program.

4. Add the following new TS section to specify the basic requirements of the SQR program.

"6.5.3 PROGRAM / PROCEDURE REVIEW AND APPROVAL All programs and procedures required by Specification 6.8 shall be reviewed and approved as described below. ,

l 6.5.3.1 Each new program, procedure, or change thereto shall be '

independently reviewed by a Station Qualified Reviewer (SQR) who is knowledgeable in the functional area affected but is not the individual preparer. The SQR may be from the same organization as the preparer. The ,

SQR shall render a determination in writing of whether or not cross-disciplinary review of a new program, procedure, or change thereto is #

l necessary. If necessary, such review shall be performed by appropriate I

personnel.

6.5.3.2 Each new program, procedure, or change thereto shall be reviewed

=by the Superintendent designated by Administrative Procedures as the responsible Superintendent for that program or procedure, and the review shall include a determination of whether or not a 10 CFR 50.59 safety evaluation is required. If a 10 CFR 50.59 safety evaluation is not i required, the new program, procedure, or change thereto shall be approved by the rtisponsible Superintendent or the Plant Manager prior to I

i implementation. Administrative Procedures shall be reviewed by PORC prior ,

to approval. Administrative Procedures, Security Plan Implementing l

Procedures, and Emergency Plan Implementing Procedures shall be approved by the Plant Manager or his designated alternate in accordance with Specification 6.1.1.

! 6.5.3.3 If the responsible Superintendent determines that a new program, l procedure, or change thereto requires a 10 CFR 50.59 safety evaluation, l.

the responsible Superintendent shall render a determination in writing of whether or not the new program, procedure, or change thereto involves an unreviewed safety question (USQ), and shall forward the new program, .

procedure, or change thereto with the associated safety evaluation to PORC for review. If an USQ is involved, NRC approval is required by 10 CFR 50.59 prior to implementation of the new program, procedure, or change.

Docket Nos.

50-352 e

50-353 ,

License Nos. NPF-39 i NPF-85 j l

6.5.3.4 Personnel recommended to be SQR$ shall be approved and designated j as such by the PORC Chairman. The responsible Superintendents shall i ensure that a sufficient complement of SQRs for their functional area is I maintained in accordance with Administ'ative Procedures, j l

6.5.3.5 Temporary procedure changes shall be reviewed and approved in j accordance with Specification 6.8.3.

l i

6.5.3.6 Records documenting the activities performed under Specifications l 6.5.3.1 through 6.5.3.5 shall be maintained in accordance with  ;

Specification 6.10." i l

5. Revise TS Section 6.8.2 to read "6.8.2 Each procedure of Specification i 6.8.1, and changes thereto, and any other procedure or procedure change i that the Plant Manager determines to affect nuclear safety, shall be l reviewed and approved in accordance with Specifications 6.5.1.6. 6.5.1.7 '

and/or 6.5.3, as appropriate, prior to implen,entation. Each procedure of l Specification 6.8.1 shall also be reviewed periodically as set forth in Administrative Procedures," to indicate that procedural review and l approval will be in accordance with the appropriate TS Sections. ,

6. Revise TS Section 6.8.3.c to read "The change is documented, reviewed by  ;

an SQR in accordance with Specification 6.5.3.1, and approved by either t the Plant Manager or his designated alternate in accordance with Specification 6.1.1, or the Superintendent designated by Administrative Procedures as the responsible Superintendent for that procedure within 14 days of '

lementation." to make the review and approval process for TPCs ,

consists with that for permanent procedure changes. This TS change provides f or a cross-disciplinary review, if necessary, and maintains the same level of management approval, a

7. Revise IS Section 6.10.2.e to read " Records of changes made to the programs and procedures required by Specification 6.8." to require a five ,

year retention period for records of changes made to programs as a result i of the SQR activities conducted in accordance with proposed Specification 6.5.3, and maintain consistency between the requirements of Specification >

L s

6.10 and proposed Specification 6.5.3.6.

8. Add "6.5.3 PROGRAM / PROCEDURE REVIEW AND APPROVAL 6-12" to page xxvii of the Index to indicate the addition of TS Section 6.5.3, and revise the 1

page numbers for TS Sections 6.6 and 6.7 from "6-12" to "6-12a" due to relocation of these requirements to the new proposed page.

s

1 Docket Nos. 5f-352 ,

5)-353 i

License Nos. NPF-39 NPF-85 Safety Assessment The proposed changes are administrative in nature. The institution of the SQR Program will help to streamline PORC ectivities and improve the effectiveness of PORC reviews by making more efficient use of technical expertise available. There are no changes to plant equipment, plant design, limiting safety sys%n settings, or plant system operation. New programs, procedures, and ches:; inereto will be reviewed by qualified personnel designated by the PORC Chairman and knowledgeable in the affected functional area. The program will be controlled by Administrative Procedures which will continue to be reviewed by PORC and approved by the Plant Manager. PORC will continue to review those new programs, procedures, and changes thereto for which an unreviewed safety question determination (i.e., 10 CFR 50.59 safety evaluation) is required to be performed. As a result, the proposed administrative changes will not ,

decrease the safety oversight function which PORC performs.

Information Supporting a finding of No Significant Hazards Consideration We have concluded that the proposed changes to the LGS TS, which reflect the implementation of a Station Qualified Reviewer Program, do not constitute a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three standards set forth in 10 CFR 50.92 is provided below.

1) _The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes are administrative changes which implement a program / procedural review and approval process through the use of qualified personnel designated by the PORC Chairman for review purposes and Superintendents designated by the Plant Manager, as authorized by Administrative Procedures, for approval of specific types of programs and classes of procedures. The SQR will be required to consider, document, and implement a cross-disciplinary review prior to approval, if necessary. The program will be controlled by Administrative Procedures which will continue to be reviewed by PORC and approved by the Plant Manager. PORC will continue to review those new programs, procedures, and changes thereto for which an unreviewed safety question determination (i.e., 10 CFR 50.59 saf y evaluation) is required to be performed. As a result, the proposed administrative changes will not decrease the safety oversight function which PORC performs. The proposed changes will add more detailed requirements regarding program / procedure review and approval to the TS which will strengthen the controls over this process. The proposed changes do not affect any plant hardware, plant design, limiting safety system settings, or plant systems, and therefore, do not modify or add any initiating parameters that would cause a significant increase in the probability or consequences of any accident previously evaluated.

2) The proposed changes do not create the possibility of a new or different kind of l accident from any accident previously evaluated.

l The proposed changes will implement a program / procedural review and approval l process and are administrative in nature. The program will be controlled by Administrative Procedures which will continue to be reviewed by PORC and approved by the Plant Manager. PORC will continue to review those new programs, procedures, and changes thereto for which an unreviewed safety question determination (i.e., 10 CFR 50.59 safety evaluation) is required to be

' + i Docket Nos. 50-352 e*

50-353  !

License Nos. NPf-39 NPF-85 performed. As a result, the proposed administrative changes will not decrease the safety oversight function which PORC performs. The proposed changes do not involve any physical alterations of plant configuration, changes to setpoints, or operating parameters, nor do they involve any potential initiating events that would create the possibility of a new or different kind of accident from '

any accident previous'y evaluated. ,

i (3) _The proposed changes do not involve a significant reduction in a margin of safety, i

The proposed changes are administrative in nature and involve only the transfer of responsibilities and authority for program / procedural review and approval to responsible Superintendents. PORC will continue to review and the Plant Manager will continue to approve those new programs, procedures, and changes thereto for which an unreviewed safety question determination (i.e., 10 CFR 50.59 safety evaluation) is required to be performed. Accordingly, the same management level >

of review and approval of new programs, procedures, and changes thereto as currently required by TS is maintained. That is, the responsible Superintendents are also PORC members. Therefore, the margin of safety is not reduced. The proposed changes do not impact plant systems or operations and, i therefore, do not involve a significant reduction in a margin of st fety.

Information Supportina an Environmental Assessment An environmental assessment is not required for the changes proposed by this Change Request because the requested changes conform to the criteria far " actions eligible for categorical exclusion," as specified in 10 CFR 51.22(c)(10). The requested changes will have no impact on the environment. The requested changes do not involve a significant hazards consideration as discussed in the preceding section. The requested changes do not involve a'significant change in the types or significant increase in the amounts of any effluents that may be released offsite, in addition, the proposed changes do not involve a significant increase in individual or cumulative occupational radiation exposure.

Conclusion +

The Plant Operations Review Committee and the Nuclear Review Board have reviewed these proposed changes to the TS and have concluded that they do not involve an unreviewed safety question, or a significant hazards consideration, and will not endanger the health and safety of the public.

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