ML20044G626

TS Section 6.8 Re Review & Approval Process for Procedure Changes

ML20044G626
Person / Time
Site:	Nine Mile Point
Issue date:	05/26/1993
From:	NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML20044G623	List: ML20044G622 ML20044G624 ML20044G626
References
NUDOCS 9306040024
Download: ML20044G626 (8)

Text

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l ATTACIIMENT A I NIAGARA MOIIAWK POWER CORPORATION LICENSE NO. NPF-69 ' ,

DOCKET NO. 50-410 PROPOSED CIIANGES TO THE TECHNICAL SPECIFICATIONS Replace existing page 6-16 with the attached revised page. This page has been retyped in its entirety with marginal markings to indicate changes to the text.  :

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b 9306040024 930526 0 PDR ADOCK 0500 P

AO'MINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS

{ PROCEDURES

. 6.8.1 (Continued)

d. Surveillance and test activities of safety-related equipment

e. Security Plan implementation

f. Emergency Plan implementation

g. Fire Protection Program implementation

h. PROCESS CONTROL PROGRAM implementation

i. OFFSITE DOSE CALCULATION MANUAL implementation and l

j. Quality Assurance for effluent and environmental monitoring.

REVIEW AND APPROVAL 6.8.2 Each procedure of Specification 6.8.1, and changes thereto, shall be reviewed in accordance with Spacification 6.5.2 and approved prior to implementation by the branch manager for the functional area of the procedure or higher levels of management as governed l by administrative procedures. Each procedure of Specification 6.8.1 shall be reviewed periodically as set forth in administrative procedures.

l l TEMPORARY CHANGES 6.8.3 Temporary changes to pt: a. ;ures of Specification 6.8.1 may be made provided:

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

b. The change is approved by two members of the unit management staff, at least one of whom holds a Senior Operator license on the unit affected; and

c. The change is documented, reviewed in accordance with Specification 6.5.2 and l approved within 14 days of implementation by the branch manager for the functional area I of the procedure or higher levels of management as governed by administrative procedures.

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NINE MILE POINT - UNIT 2 6-16 Amendment No.)fI

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l ATTACIIMENT B Page 1 of 6 NIAGARA MOIIAWK ' POWER CORPORATION LICENSE NO. NPF-69 DOCKET NO. 50-410 SUPPORTING INFORMATION AND NO SIGNIFICANT IIAZARDS  !

CONSIDERATION ANALYSIS-INTRODUCTION The proposed changes to Niagara Mohawk Power Corporation's Nine Mile Point Unit 2 Technical Specifications contained herein represent revisions to Section 6.8, " Procedures and Programs." The proposed amendment would modify the approval requirements for procedures important to nuclear safety to allow the branch manager for the functional area of the procedure to approve changes to procedures. This will alleviate undue burden on the

! Plant Manager and place the responsibility with the appropriate branch manager.for the functional area of the procedure. Currently, the Plant Manager is required to review and approve each procedure prior to its implementation.

In addition, an editorial change has been proposed to correct the spelling of "DOES" to

" DOSE" in Technical Specification section 6.8.1.i. This change will correct a spelling error in amendment 25 of the Technical Specifications for Nine Mile Point Unit 2.  :

The proposed changes to delete the footnote on page 6-16 and to replace the reference to SORC in Specifications 6.8.2 and 6.8.3.c with a reference to Specification 6.5.2 are being requested for clarification purposes and do not change what is currently allowed by the Nine Mile Point Unit 2 Technical Specifications.

DESCRIFFION OF PROPOSED TECIINICAL SPECIFICATION CIIANGES Niagara Mohawk Power Corporation (NMPC) proposes the following changes:

1) Technical Specification (TS) Section 6.8.2, " Review and Approval", currently states:

"Each procedure of Specification 6.8.1 and changes thereto, shall be approved by the Plant Manager based on the recommendations of SORC* before implementation and reviewed periodically as set forth in administrative procedures."

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i Page 2 of 6 NMPC proposes to modify the above TS Section to state:

"Each procedure of Specification 6.8.1, and changes thereto, shall be reviewed in -

accordance with Specification 6.5.2 and approved prior to implementation by the branch manager for the functional area of the procedure or higher levels of management as governed by administrative procedures. Each procedure of Specification 6.8.1 shall be reviewed periodically as set forth in administrative procedures."

2) TS Section 6.8.3.c, which addresses temporary changes to procedures, currently states:

"The change is documented, approved by the Plant Manager based on the recommendations of the SORC within 14 days ofimplementation."

NMPC proposes to modify the above TS section to state:

"The change is documented, reviewed in accordance with Specification 6.5.2 and approved within 14 days of implementation by the branch manager for the functional area of the procedure or higher levels of management as governed by administrative procedures."

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3) The footnote on Technical Specification page 6-16 currently statcs:

"*SORC recommendations to the Plant Manager are to be based on SORC responsibilities as identified in Specification 6.5.1.7.a."

1 NMPC proposes to delete this footnote.

4) TS Section 6.8.1.i currently states:

"OFFSITE DOES CALCULATION MANUAL implementation and" l

NMPC proposes the following editorial change:

"OFFSITE DOSE CALCULATION MANUAL implementation and" EVALUATION The proposed amendment consists of administrative changes which shift the approval of procedures important to nuclear safety from the Plant Manager to the branch manager for the functional area of the procedure. These changes will allow the approval of a procedure by l

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Page 3 of 6 the branch manager in the area of expertise for the procedure, thereby providing the Plant j Manager with more time for other responsibilities. In addition, an editorial change has been '

proposed to correct the spelling of "DOES" to " DOSE" in TS section 6.8.1.i. This change will correct a spelling error in Amendent 25 of the Technical Specifications for Nine Mile Point Unit 2. ,

The logical basis for requiring the Plant Manager to approve all procedures prior to implementation is to ensure that overall plant impact is considered from an adequate management and power plant experience base as well as for effectiveness in achieving its purpose. Niagara Mohawk concludes that the proposed changes do not reduce the effectiveness of the Specification and will relieve the Plant Manager of administrative duties which the branch managers are fully capable and qualified to perform.

The quality of plant procedures will be preserved since approval will rest with the branch managers in the area of expertise for the procedure. Niagara Mohawk believes that it is prudent to have plant procedures approved by the appropriate branch manager. This allows the person most familiar with the procedure the opportunity to approve it. Any safety concerns regarding a procedure change can be elevated to higher levels of management. The proposed changes are intended to enhance the overall management capability and performance of Nine Mile Point Unit 2 by freeing the Plant Manager for other duties involving plant safety.

Niagara Mohawk's current procedure program requires that:

• Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure.

• Procedures shall be approved as designated by the owner organization before initial use. Rules shall be established which clearly delineate the review of l procedures by knowledgeable personnel other than the originator and the l approval of procedures and procedure changes by authorized individuals.

• Changes to documents shall be reviewed by the same organization that performed the original review unless the owner organization designates another i

qualified organization.

i The footnote on page 6-16 is proposed for deletion to clarify the Station Operations Review

Comn.ittee (SORC) functions with respect to procedures and changes thereto. It is also i l

proposed to replace the reference to SORC in Specifications 6.8.2 and 6.8.3.c with a reference to Specification 6.5.2. These changes are being made to more accurately depict the process currently in place for review of procedures and procedure changes.

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The review and control of procedures and procedure changes is required per Specification l 6.5.2, " Technical Review and Control Activities." This section requires an independent review by technically qualified personnel and, if necessary, additional cross-disciplinary  !

review. The proposed changes to remove the footnote on page 6-16 and to replace the l reference to SORC in Specifications 6.8.2 and 6.8.3.c with a reference to Specification 6.5.2 )

will not alter the process that is currently in effect at Nine Mile Point Unit 2. These  !

proposed changes will state more succinctly what is currently allowed by the Nine Mile Point i Unit 2 Technical Specifications. Furthermore, these changes are in agreement with Section l 5.0 of NUREG-1433, " Improved Standard Technical Specifications", for BWR/4.

CONCLUSION The proposed amendment incorporates an editorial change and administrative changes and does not affect assumptions contained in any safety analyses. There are no physical changes to the facility or any changes to operating procedures. Limiting Conditions for Operation (LCO's), limiting safety system settings, and safety limits specified in the Technical Specifications will also remain ur. changed as a result of the proposed amendment. Since there are no changes in the way the plant is operated and plant equipment and physical features are not affected, the potential for an unanalyzed accident is not created.

Furthermore, the quality of plant procedures will be preserved since approval will rest with the branch managers in the area of expertise for the procedure. For these reasons, there is reasonable assurance that the changes that would be authorized by the proposed amendment can be implemented without endangering the health and safety of the public and are consistent with common defense and security.

NO SIGNIFICANT HAZARDS CONSIDERATION 10CFR 6 50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10 CFR 6 50.92 concerning the issue of no significant hazards consideration. Therefore, in accordance with 10 CFR f 50.92, the following analysis has been performed:

The operation of Nine Mile Point Unit 2 in accordance with the nronosed amendment will not involve a significant increase in the nrobability or consecuences of an accident j oreviousiv evaluated. l The proposed amendment incorporates administrative and editorial changes and does not affect assumptions contained in any safety analyses nor do the changes affect Technical l Specifications that preserve safety analyses assumptions. Additionally, these proposed  !

changes do not modify the physical design or operation of the plant. Furthermore, the quality of plant procedures will be preserved since approval will rest with the branch i

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. Page 5 of 6 j managers in the area of expertise for the procedure. Niagara Mohawk believes that it is prudent to have plant procedures approved by the appropriate branch manager. This allows the person most familiar with the procedure the ability to approve it. Any safety concerns t regarding a procedure change can be elevated to higher levels of management. The proposed  :

l changes are intended to enhance the overall management capability and performance of Nine Mile Point Unit 2 by freeing the Plant Manager for other duties involving plant safety. The  !

proposed changes to delete the footnote on page 6-16 and to replace the reference to SORC in Specifications 6.8.2 and 6.8.3.c with a reference to Specification 6.5.2 are being requested

! for clarification purposes and do not change what is currently allowed by the Nine Mile Point ,

Unit 2 Technical Specifications. In addition, an editorial change has been proposed to

, correct the spelling of "DOES" to " DOSE" in Section 6.8.1.i. Therefore, the proposed l amendment will not increase the probability or consequences of an accident previously evaluated.

The operation of Nine Mile Point Unit 2 in accordance with the oronosed amendment will not create the nossibility of a new or different kind of accident from any accident . ,

previousiv evaluated. i l

Sir.ce there are no changes in the way the plant is operated and plant equipment and physical l features are not affected, the potential for an unanalyzed accident is not created. The ,

l proposed changes are administrative and editorial in nature and do not affect any accident l initiators for Nine Mile Point Unit 2. Therefore, no new failure modes are introduced.

Furthermore, the quality of station procedures will be preserved since approval will rest with the branch managers in the area of expertise for the procedure. Niagara Mohawk believes that it is prudent to have plant procedures reviewed by the appropriate branch manager. 'This allows the person most familiar with the procedure the ability to approve it. Any safety ,

concerns regarding a procedure change can be elevated to higher levels of management. The proposed changes are intended to enhance the overall management capability and performance of Nine Mile Point Unit 2 by freeing the Plant Manager for other duties ,

l involvi.ng plant safety. The proposed changes to delete the footnote on page 6-16 and to -

l replace the reference to SORC in Specifications 6.8.2 and 6.8.3.c with a reference to l Specification 6.5.2 are being requested for clarification purposes and do not change what is ,

currently allowed by the Nine Mile Point Unit 2 Technical Specifications. In addition, an '

l editorial change has been proposed to correct the spelling of "DOES" to " DOSE" in Section l 6.8.1.i. The proposed amendment will, therefore, not create the possibility of a new or different kind of accident from any accident previously evaluated.

The operation of Nine Mile Point Unit 2 in accordance with the proposed amendment will not involve a significant reduction in aJmLrein of safety.

Plant safety margins are established through LCO's, limiting safety system settings, and safety limits specified in the Technical Specifications. As a result of the proposed ,

amendment, there will be no changes to eiti.er the physical design of the plant or to any of i

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. Page 6 of 6 these settings and limits. No margin of safety is affected by this change. The initial conditions utilized in the conduct of the accident analysis are unchanged. The methodologies used for the analyses are unchanged. The analyses results are not impacted. Sufficient controls are included in the procedure review methodology to ensure that the plant conditions and equipment availability required to support the integrity of the analyses, and hence the margin of safety, will continue to be maintained.

The proposed amendment does not involve a significant reduction in a margin of safety because Niagara Mohawk, through its Quality Assurance programs and other required controls, maintains ANSI standard or Regulatory Guide 1.8, as appropriate, qualified personnel in positions of responsibility. This assures that procedures and procedure changes are approved at a high level of competence.

The proposed changes are administrative and editorial in nature and do not affect the safe operation of the plant. Therefore, there will be no changes to any of the margins of safety.

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