ML20045B566

Comment Re Proposed Generic Communication on Mod of TS Administrative Control Requirements for Emergency & Security Plans,As Published in Fr on 930401 (58FR17293).Believes Concept of Technical Review Not Addressed by STS

ML20045B566
Person / Time
Site:	Perry
Issue date:	06/07/1993
From:	Stratman R CENTERIOR ENERGY, CLEVELAND ELECTRIC ILLUMINATING CO., TOLEDO EDISON CO.
To:	NRC
References
FRN-58FR17293 58FR17293, PY-CEI-NRR-1659, NUDOCS 9306180075
Download: ML20045B566 (3)

Text

-.

' GNTECDOR .

ENEN jMQg3 ,

PERRY NUCLEAR POWER PLANT Mail Address: 7' I t ,%

PO BM 97 3 DmWn p ;

10 CENTER ROAD PERRY, OHIO 44081 VICE PRESIDENT . NUCLEAR lD.

PERRY, OHIO 44081

- (216) 259E37 JW 16 P4 :)4  !

PY-CEI/NRR-1659 L June 7, 1993 [

Chief, Rules and Directives Review Branch U.S. Nuclear Regulatory Commission Vashington, D. C. 20555 Subj ect: Comments on Proposed Generic Communication: Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans

Dear Sir:

This letter forwards comments relative to the proposed generic communication on modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans, as published in the Federal Register on '

Thursday, April 1, 1993 (58FR17293).

During the development of the Perry Nuclear Pover Plant (PNPP) Technical Specifications, the review of the emergency and security plans and implementing procedures was not listed as a responsibility of the Company Audit and Reviev ,

Group (called the Nuclear Safety Review Committee at PNPP); instead, a similar '!

requirement was placed in a new section entitled " Technical Review and Control." Copies of the applicable PNPP Technical Specification pages are .

attached to this letter; see attached Section 6.5.3.l(f) addressing the i Security Plan and Emergency Plan. The concept of a Technical Review and Control section is not specifically addressed by the Standard _ Technical Specifications (STS), therefore the model Technical Specifications discussed in Enclosure 2 to the proposed Generic Letter do not address the treatment of requirements similar to those in the PNPP Technical Specifications.

The draft Generic Letter currently states that " Enclosure 2 contains sample technical specification requirements that have been marked to show the {

requirements that may be removed." It is suggested that the Generic Letter be-

~

vritten to recognize that requirements "similar to" those in Enclosure 2' vill be similarly processed, provided that licensees retain' review activities in a ,

manner that fully satisfies the regulatory requirements summarized in -!

Enclosure 1.

If there are any questions, please feel free to call.

I Sincerely, i

Ji /

f l! /h) W IM*

ift ~ .

Rob'ert A. Stratman  ;

RAS:BSF:ss cc: ' NRC Project Manager Owanng Compames ', i Cleveionc Electoc mummotmg )

Toledo Ectson j 9306180075 930607 'l PDR PR

. MISC 5BFR17293 PDR _

. PY-CEI/NRR-1659 L

.- . Attachment Page 1 of 2 ADMINISTRATIVE CONTROLS g

( 6.5.3 TECHNICAL REVIEW AND CONTROL .

ACTIVITIES

6. 5. 3.1. Activities which affect nuclear safety shall be conducted as follows:

a. Procedures / instructions required by Specification 6.8 and other procedures / instructions which affect plant nuclear s'afety, and changes thereto, shall be prepared, reviewed and approved. Each such procedure / instruction or procedure / instruction change shall be reviewed by a qualified individual (s) other than the individual (s) which prepared the procedure / instruction or procedure / instruction change, but who may be from the same section as the individual (s) which prepared the procedure / instruction or procedure / instruction change. Instructions shall be approved by appropriate management personnel as designed in writing by PORC, and approved by the appropriate Section managers. The General Manager, PNPPD, shall l approve Administrative Procedures.

b. Proposed godifications to plant structures, systems and components that affect nuclear safety shall be reviewed by individuals desig-nated by the Director, Perry Nuclear Engineering Department. Each l such modification shall be reviewed by a qualified individual (s) other than the individual (s) which designed the modification, but who may be from the same section~as the individual (s) which designed the modifications. Proposed modifications to plant

( structures, systems and components that _ affect nuclear safety shcIl be reviewed by PORC and approved prior to implementation by the General Manager, PNPPD. l

c. Proposed tests and experiments which affect plant nuclear safety ,

shall be prepared, reviewed, and approved. Each such test or experiment 'shall be reviewed by a qualified individual (s) other than the individual (s) which prepared the proposed test or experi- '

ment. Proposed tests and experiments shall be approved before implementation by the General Manager, PNPPD. l

d. Sections responsible for reviews, including cross-disciplinary reviews, performed in accordance with Specifications 6.5.3.la. and 6.5.3.lc., shall be designated in writing by PORC and approved by the General Manager, PNPPD. The individual (s) perfoming the review l shall meet or exceed the qualification requirements or appropriate section(s) of ANSI N18.1-1971;

e. Each review shall include a determination pursuant to 10 CfR 50.59 of whether_or not the potential for an unreviewed safety question exists.

If such a potential does exist, a safety evaluation per 10 CFR 50.59 to detemine whether or not an unreviewed safety question is involved shall be perfomed. Pursuant- to 10 CFR 50.59, NRC approval of items  ;

involving unreviewed safety questions shall be obtained prior to  ;

implementation; and l

(

PERRY - UNIT 1 6-14 Amendment No. 22,42 l l

l

• PY-CEI/NRR-1659 L

- . Attachment Page 2 of 2 ADMINISTRATIVE CONTROLS f.

i.

ACTIVITIES _ (Continued)

f. The Plant Security Plan and Emergency Plan, and implementing instructions, shall be reviewed at least once per 12 months.

Recomended changes to the Plans and implementing instructions -

shall be reviewed pursuant to the requirements of Specification 6.5.1.6 and approved by the General Manager, Perry Nuclear Power Plant Department. NRC approval shall be obtained as appropriate.

6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Co:: mission shall be notified and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and

b. Each REPORTABLE EVENT shall be reviewed by the PORC and the results of the review submitted to the NSRC and the Vice President - Nuclear.

6. 7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is t

violated:

a. The NRC Operations Center shall be notified by telephone as soon as possible and in all cases within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> The Vice President Nuclear and the NSRC shall be not3fied 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 rev-iewed by the PORC. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit components, systems, or structures, and (3) corrective action taken to prevent recurrence.

c. The Safety Limit Violation Report shall be submitted to the Commission, tne NSRC, and the Vice President - Nuclear within 30 days of the violation.

d. Critical operation of the unit shall not be resumed until authorized by the Comission.

6. 8 PROCEDURES / INSTRUCTIONS AND PROGRAMS 6.8.1 Written procedures / instructions shall be established, implementec, and maintained covering the activities referenced below:  !

a. The applicable procedures recommended in Appendix A of Regulatory Guide _ l.33, Revision 2, February 1978. l l

(

PERRY- UNIT 1 6-15 Amencmer.t No. 22,

• 6, 42 1