ML20044B274
| ML20044B274 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 07/13/1990 |
| From: | Hunger G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20044B275 | List: |
| References | |
| NUDOCS 9007180261 | |
| Download: ML20044B274 (9) | |
Text
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10 CFR 50.90 m.
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PHILADELPHIA ELECTRIC COMPANY NUCLEAR GROUP HEADQUARTERS 955 65 CHESTERBROOK BLVD.
WAYNE, PA 19087 5691 (zis) sao sooo
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July 13, 1990 Docket Nos.
50-277-50-278 License Nos. DPR-44 i
DPR-56 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk.
Washington, D. C. 20555
SUBJECT:
Peach Botton Atomic Power Station. Units 2 and 3
-Technical Specifications Change Request j
Dear Sir:
Philadelphia Electric Company hereby submits-Technical Specifications Change
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. Request No. 89-10, in accordance with 10 CFR 50.90, requesting changes to-Appendix:A:
of the. Peach Bottom Facility Operating Licenses. -These changes would establish j
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. provisions for-a Station Qualified Reviewer Program for-the review and approval ofi i
new procedures-and procedure' changes. This program was modeled after the programs at, L
the Public Service Electric-and~ Gas. Sales'and Hope Creek stations. The changes.are limited to Section 6.0 of'the. Technical-Specifications.-
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Attachment I to this;~1etter describes the proposed changes, and provides j
-justification for.the changes. This program was modeled after,the programs at Public
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Service' Electric and Gas, Salen.and Hope Creek stations. Attachment 2.contains the revised Technical Specifications pages, i
i If you have any questions, please do not hesitate to contact Mr. Frank ~ Lear:
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'of my staff at (215) 640-6786.
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Very truly yours, f'
pa3A A l
G. A. Hunger, Jr.
7 Manager-Licensing Section Nuclear Engineering & Services
Enclosure:
Affidavit Attachments 1 and 2 cc:
T. T. Martin, Administrator, Region I,'USNRC J. J. Lyash, USNRC Senior Resident Inspector.
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. T. M. Gerusky, Director, PA Bureau of Radiological Protection 9007180261 9007;3 hDR ADOCK 05000277 9
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COM ONWEALTH OF PENNSYLVANIA ss.
CHESTER COUNTY D. R. Helwig, being first duly sworn, deposes and says:
That he is Vice President of Philadelphia Electric Company, the Applicant-L herein; that he has read the attached request (number 89-10) for changes to Peach Bottom facility Operating Licenses DPR-44 and DPR-56, 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 President
' Subscribed a'nd sworn to g
before me! th'is I3 day.
w h 1990.
of-d-(hu l I ltA.As:
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n Notary Public I
. NOTARIAL SEAL CATHERINn A. MENCEZ. Notary Public Treopfnn Two Cnester Counet My Committica Exores Sect A 1993 _
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ATTACHMENT 1
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PEACH BOTTOM ATOMIC POWER STATION-
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a UNITS 2 AND 3 f
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.i Docket Nos. 50-277' 50-278 License Nos. DPR-44 DPR-56
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TECHNICAL SPECIFICATIONS CHANGE REQUEST-No. 89-10 A t
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" Station Qualified Reviewer Program" a
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Docket Nos. 50-277 50-278 License Nos. DPR-44 DPR-56 l
l Introduction-l Licensee proposes changes to Section 6.0, " Administrative Controls." of the Technical Specifications to establish provisions for a Station Qualified Reviewer i
(SQR) Program. Station Qualified Reviewers will be responsible for the review of new procedures and procedure changes. The purpose for establishing the SQR Program is to i
shift more' responsibility for safety reviews-to the line organizations and to alter the scope of Plant Operations Review Committee (PORC) reviews to be more appropriate for that of a safety oversight committee.
In lieu of the PORC reviewing every new procedure and every procedure change, PORC will review those that require a 10 CFR 50.59 Safety Evaluation and any Administrative procedure or change thereto, A SQR and a station Superintendent will review each new procedure and procedure change.
Rather than the Plant Manager approving every new procedure and every procedure change, appropriate station Superintendents will approve those that do not require a 10 CFR 50.59 Safety Evaluation. A SQR, rather than PORC, will review temporary procedure changes after implementation, and appropriate Superintendents will be permitted to approve temporary procedure changes after implementation, rather than only the Plant Manager being permitted to approve them.
The Plant Manager will continue to approve Administrative procedures, Security Plan implementing procedures and Emergency Plan implementing procedures. Some minor administrative changes to the Technical Specifications are also proposed.
The proposed amendment would change pages 247, 248, 252a, 253, 254 and 260 of the Technical Specifications as indicated by vertical bars in the page margins.
Revised pages are enclosed as Attachment 2.
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Description of Changes:
i Licensee proposes to revise Sp?cification 6.5.1.6.a to identify that PORC reviews new procedures and procedure changes that require a 10 CFR 50.59 Safety Evaluation and all Administrative proctdures and changes to Administrative procedures. Currently, this specifica ion requires all Technical Specifications-required procedures and changes.theret3, and any other procedure or procedure change that the Plant Manager determines affrcts nuclear safety to be reviewed by PORC.
This proposed change reduces the scopo of PORC's review by eliminating less L
significant items that will not impact nuclear safety. These items will instead be l'
- reviewed by the appropriate PORC Chairman-approved SQR and then will be reviewed and approved by the Superintendent that the Plant Manager designates as responsible for that procedure.
Licensee proposes that Specification 6.5.1.7.b be revised to exclude procedures and procedure changes from the items for which PORC renders a written I
Unreviewed Safety Question (USQ) determination. An element of the new SQR program is that the responsible Superintendent shall be accountable for the USQ determination.
In reality this will have no affect on PORC's review of Safety Evaluations for procedures and procedure changes; it merely shifts the responsibility for the actual USQ determination to the appropriate line nrganization.
PORC will still independently review the Safety Evaluation and advise the Plant Manager of its
. concurrence or disagreement with the USQ determination.
USQ deterutnations are l l
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.Dockst Nss.:50-277 50-278-License Nos. DPR-44 DPR-56 D
' governed by a Nuclear Group Administrative Procedure for 10 CFR 50.59 reviews of changes, tests and experiments, including procedure changes. This procedure was reviewed by PORC prior to implementation.
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Licensee proposes to add a new section to the Technical Specifications to set forth-the principal SQR Program provisions. The new section is titled " Procedure Review and Approval" and is numbered 6.5.3.
This new section is summiarized below:
1)
Each new procedure and procedure change must be reviewed by a PORC Chairman-approved SQR who is knowledgeable in the functional area involved.
Cross-disciplinary review must be considered by the SQR.
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2)
Each new procedure and procedure change must be approved by the designated Superintendent or the Plant Manager. The Plant Manager approves
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Administrative procedures. Emergency Plan implementing procedures and Security Plan implementing procedures, and changes thereto. The Plant Manager also approves any procedure or procedure change that requires a 10 CFR 50.59 Safety Evaluation.
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Responsible Superintendents determine if a 10 CFR 50.59 Safety Evaluation is required for new procedures and procedure changes, and they render the USQ determinations prior to sending the Safety Evaluation, if one is required, to PORC, PORC reviews procedures and procedure changes.that require a 10
-CFR 50.59 Safety Evaluation and all. Administrative procedures (and changes i
thereto). After considering PORC's. recommendation regarding the documents, i
-the Plant Manager approves or rejects the procedure or procedure change and associated Safety Evaluation (if one is required).
4).
Individuals are only designated as SQRs after approval by,the.PORC Chairman.
'The: Plant Manager designates a responsible Superintendent for review / approval of each procedure (and changes thereto).
Each designated Superintendent also maintains a sufficient number of'SQRs qualified to review the procedures for which he or she, the Superintendent, is a
responsible.
5)
Records of review / approval under this program are required to be maintained.
6)
No changes are proposed relative'to plant modifications, tests or-experiments.
7)
The term " responsible Superintendent" as used in this new Technict!
-Specification section is not meant to correspond, in all cases, with the organizational title of superintendent used in Chapter 13 of the Updated Final Safety Analysis Report.
In this new Technical Specification section the title superintendent is identifying a minimum level of management. For example, the Support Manager may be designated as the " responsible Superintendent" for certain fire protection related procedures since the Fire Protection Section reports directly to him with no intervening l
superintendent.
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Docket Hos. 50-277 50-278 License Nos. DPR-44 DPR-56 Licensee proposes to change Specification 6.8.2 to require that each Technical Specifications-required procedure and change thereto, and any other procedure or procedure change determined by the Plant Manager to affect nuclear safety be reviewed and approved in accordance with Specification 6.5.3 (and
' Specifications 6.5.1.6.a and 6.5.1.7.a. if required). This means that 1) if an Administrative procedure is affected or a 10 CFR 50.59 Safety Evaluation is required.
PORC reviews it in addition to a SQR and the responsible Superintendent, and 2) if an Administrative procedure Emergency Plan implementing procedure or Security Plan implementing procedure is affected, or a 10 CFR 50.59 Safety Evaluation is required, the Plant Manager approves it; otherwise the responsible Superintendent approves _it.
Currently, this Spect'ication requires each procedure and procedure change to be reviewed by PORC and approved by the Plant Manager.
Currently, Specification 6.5.1.6.a states that PORC shall review, in addition to Technical Specifications-required procedures. "any other proposed procedures or changes thereto as determined by Plant Manager to affect nuclear safety." This provision has been incorporated into the proposed revision of Specification 6.8.2.
Thus, any procedure or procedure change that in the Plant Manager's view affects nuclear safety, even if it does not involve a procedure specifically required by the Technical Specifications, will be reviewed and approved in accordance with the Technical Specification requirements.
Licensee proposes to change Specification 6.8.3.c to require that temporary procedure changes (TPCs) be reviewed by a SQR, rather than by PORC, and that TPCs be
-approved by a member of management consistent with the approval requirements for permanent' procedure changes'as proposed in this' application. Currently.
Specification 6.8.3.c requires each TPC to be reviewed by PORC and approved by the Plant Manager within 14 days of implementation. As for permanent changes, the SQR=
review of TPCs will be in accordance with proposed Specification 6.5.3.1.
Approval of TPCs could be by the Superintendent who is permitted by proposed Specification
- 6.5.3.2 to approve permanent changes to the af fected procedures.
The following administrative changes, unrelated to the new SQR program, are proposed.
The first change is merely a format change of Specification 6.8.1 to itemize the procedures which are required to be established, implemented and maintained. Also, in order to specify all of the required procedures in one location, the procedures currently specifi ' in 6.8.4 have been relocated into the reformatted 6.8.1.
The second change broadens the records retention requirements of Specification 6.10 to include records of changes to all of the procedures required by Specification 6.8.
Currently, only records of Operating procedure changes need to be retained in accordance with Specification 6.10.1.f.
Lastly, in several locations references to other Technical Specifications were clarified by stating
" Specification" or " Technical Specification" before the. number referenced in the text.
' Safety Assessment:
Currently, the Technical Specifications do not require that anyone other than PORC review new procedures or procedure changes prior to approval. However, in.,
1 Docket Nos. 50-277 50-278 o
License Nos. DPR-44 l
DPR-56 practice, PORC rarely reconnends that any procedure or procedure change be approved unless a review by qualified personnel has been perfomed and documented.
Nevertheless, including the key requirements of the SQR Program in the Technical Specifications strengthens the controls over procedure reviews, which could improve safety. The Technical Specifications, as proposed, will require review prior to approval by a qualified individual (other than the preparer) who is knowledgeable in the functional area affected. This could constitute an enhancement over the current PORC quorum requirement of the Technical Specifications since the types of PORC members that need to be present are net specified.
Eliminating PORC. review of procedures and procedure changes that do not require a Safety Evaluation will not affect safety. Rather, this will free PORC from reviewing items that are outside the charter of a " safety review" committee because these non-safety-significant items can dilute the time that PORC members can spend on matters that are safety-significant.
Philadelphia Electric Company has implemented one Nuclear Group Administrative Procedure to govern 10 CFR 50.59 reviews of proposed changes at each' of its nuclear plants, including permanent procedure changes.
This procedure embodies the guidance in NSAC-125. " Guidelines for 10 CFR 50.59 Safety Evaluations,"
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June 1989.
Screening criteria delineated in the procedure are.used to determine if a Safety Evaluation is necessary. This screening process is documented, including the l
basis for the disposition of each screening criterion, and is titled the
" Determination". Under the SQR Program, if the Determination for a new procedure or procedure. change yields the conclusion that a Safety Evaluation is required, then the Safety Evaluation would be prepared, and PORC would review the evaluation and the new procedure or procedure change.
If the Detemination for a new procedure or procedure change yields the conclusion that a Safety Evaluation is not required, then PORC l;
would not review the procedure or procedure change unless it was a new Administrative procedure or a change to an Administrative procedure. Rather, the station l
Superintendent to whom the Plant Manager has assigned responsibility for the procedure would review the Determination prior to approving the procedure or procedure change. However, the PORC will review and the Plant Manager will approve Administrative procedures and changes thereto because these are the highest tier-station procedures. The SQR program will be controlled by such Administrative procedures. Also, the Plant Manager will approve Emergency Plan implementing procedures and Security Plan implementing procedures (and changes thereto) because the impact of these procedures crosses several organizational boundaries.
The pre-implementation review and approval process for temporary procedure changes is governed by Technical Specification 6.8.? and is not being affected by the SQR program.
However, for the same reasons that n:
.11 permanent procedure changes need to be reviewed by PORC and approved by the Plr. Manager, neither do temporary procedure changes (after implementation). Temporary procedure changes are only permitted by Technical Specification 6.8.3 if the intent of the procedure is not being changed. Philadelphia Electric does not permit temporary changes to be made to Administrative procedures, despite the fact that Technical Specification 6.8.3
-permits such changes. Temporary procedure changes are controlled by an Administrative procedure, which can only be changed after review by PORC and with the approval of the Plant Manager. The Administrative procedure governing TPCs provides l
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Docket Nun 50-277 50-278 License Nos. DPR-44
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DPR,
guidance limiting the scope of permissible TPCs, i.e., what can be considered a change that doesn't change the intent of the procedure. Also, additional pre-implementation reviews / approvals are required for certain types of TPCs.
For example, PORC approval is currently required prior to implementation of TPCs that would disable scram, emergency core cooling system or primary containment isolation system functions. Therefore, considering the controls over TPCs, replacing the post-implementation PORC review / Plant Manager approval' requirement with a SQR review / responsible Superintendent approval requirement will not adversely impact safety.
The proposed miscellaneous administrative changes to the Technical Specifications have no safety significance. The meaning of Specifications 6.8.1 and 6.8.4 is not being changed; the Specifications are merely being reformatted. The change to Specification 6.10.1.f will require more records to be retained.
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- Significant Hazards Consideration Determination:
Licensee proposes that this application does not involve significant hazards considerations for the following reasons:
1)
The proposed revisions do not involve a significant increase in the
)robability or consequences of an accident previously evaluated because (1) 20RC will still review procedures and procedure changes that require a 10-CFR 50.59 Safety Evaluation (2) the review / approval process will be l
controlled by Administratim procedures, which will continue to be reviewed by PORC and approved by the Plant Manager, (3) qualified personnel l."
knowledgeable in the affected functional area will review each procedure and procedure change, and (4) the SQRs will be required to consider and document whether cross disciplinary review is necessary, and such reviews,_if E
necessary, shall be performed prior to approval. This Technical Specification change will add more detailed requirements regarding procedure review and approval to the Technical Specifications'which will strengthen L
the controls over the process. The SQR program will provide a safety review process for procedures commensurate to that of the existing process.
The miscellaneous administrative changes cannot affect the probability or consequences of an accident because they do not affect operations, equipment, or any safety-related activity.
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- 11) The proposed revisions do not create the possibility of a new or different kind of accident from any accident previously evaluated. No physical changes to the plant or changes in operating procedures are being proposed.
The changes are purely administrative and will not have any direct affect on equipment important to safety. Changing the process by which procedures are reviewed and approved cannot in itself create the possibility of a new or different kind of accident. Furthermore, since the controls for review and approval of procedures and procedure changes will be commensurate with the existing process, the likelihood of implementing a procedure that could
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Docket Mos. 50'-277 50-278 License Nos. DPR-44~
DPR-56 create the possibility of an accident is not affected. A 10 CFR 50.59 review of each new procedure and permanent procedure change will be performed.
The miscellaneous administrative changes cannot create the possibility of an accident because they do not affect operations, equipment or-any safety-related activity, iii) The proposed revisions do not involve a :ignificant reduction in a margin of safety because a process controlled by Administrative Procedures using.
qualified personnel approved by the PORC Chairman will be in place to review new procedures and procedure changes.- A 10 CFR 50.59 review of each new procedure and permanent procedure change will be performed and PORC will continue to review those-that require a 10 CFR 50.59 Safety Evaluation.
Cross disciplinary reviews will be conducted as appropriate, and the independent Quality Assurance organization will monitor the effectiveness of implementation of the 10 CFR 50.59 review process though audits, surveillances and/or assessments. Thus, margins of safety will be maintained once the SQR program is implemented.
The miscellaneous administrative changes a not reduce any margin of safety because they do not affect any safety. rela.ed activity or equipment._- These changes increase the probability that the Technical Specifications are correctly -interpreted by clarifying infomation, and will require-that additional records be retained.-
Environmental Assessment:
. An environmental assessment is not required for the changes requested by this Application because the requested changes conform to the criteria for." actions eligible for categorical exclusion" as specified in 10 CFR 51.22(c)(9). The
-requested changes have been shown by this Application not to adversely affect the systems and equipment that prevent the uncontrolled release of radioactive material to the environment. The Application involves no significant hazards consideration as demonstrated in the preceding sections. The Application involves no significant change in the types or significant increase in the amounts of any effluents that may-be released offsite, and there will be no significant increase in individual or cumulative occupational radiation exposure.
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Conclusion:==
The Plant Operations Review Committee and the Nuclear Review Board have
- reviewed these proposed changes to the Technical Specifications and detemined that they:do not involve an Unreviewed Safety Question and will not endanger the health
- and safety of the public.
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