ML20045C557
| ML20045C557 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/18/1993 |
| From: | NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | |
| Shared Package | |
| ML20045C548 | List: |
| References | |
| NUDOCS 9306230292 | |
| Download: ML20045C557 (17) | |
Text
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II, Markup of Proposed Chances See attached markup of proposed changes to Technical Specifications.
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ADMINISTRATIVE CONTROL 5 xC.2.2 'IN::?:NDENT SAI:T'f [NCINEEP!MC CEU? (ISEC
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N 6,2.3.1 The ISEG shall function to examine station operating character *stics, NRC issuances, 'ndustry advisories, Licensee Event Reports, and othe sources of station design nd operating experience information, includin nits of similar design, whic..may indicate areas for improving station,Mafety.
The ISEG shall make detaile4 modifications, maintenanc\\ recommendations for revised proced#es, equipment e activities, operations activi (1is, or other means of improving station safety th t.,e Senior Vice Presid it.
COMPOSITION
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6.2.3.2 The ISEG shall be composed of at '(ast five, dedicated, full-time engineers located on site.
Each shall ave a'b chelor's degree in engineering or related science and at least 2 y rs profess 1 gl level experience in his field, at least 1 year of which.perience shall be % the nuclear field.
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RESPONSIBILITIES 6.2.3.3 The ISEG sh, be responsible for maintainina surveille, a nf e atinn activities to proftiue independent verification" that these activitik are performed corr tly and that human errors are reduced as much as pract
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RECORDS
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.4 Records of activities performed by the ISEG shall be prepared, main-ined, and forwarded each calendar month to the Senior Vice President.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to the Control Room Commander in the areas of thermal hydraulics, reactor engi-neering, and plant analysis with regard to t.he safe operation of the station.
- 6. 3 TRAINING 6.3.1 A retraining and replacement licensed training program for the station staf f shall b.e maintained under the direction of the Training. Manager and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix A of 10 CFR Part 55 and the supplemental require-ments specified in Sections A and C of Enclosure 1 of the NRC letter dated March 28, 1980 to all licensees, and shall include familiarization with relevant industry operational experience.
SEABROOK - UNIT 1 6-5 l
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INSERT A 6.2.3 INDEPENDENT TECilNICAL REVIEWS A Technical Review Program shall be established, implemented and maintained to encompass the following Technical Review responsibilities.
FUNCTION j
6.2.3.1 The Technical Review Program responsibilities shall encompass:
a.
NRC issuances, industry advisories, Licensee Event Reports, and other sources j
that may indicate areas for improving plant safety; i
- b. Internal and external operating experience information that may indicate areas for improving plant safety; Plant operating characteristics, plant operations, modifications, maintenance and c.
l surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical, and
- d. Making -detailed recommendations to the Senior Vice President and Chief Nuclear
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Officer for procedure revisions, equipment modifications or other means ofimproving i
nuclear safety and plant reliability.
The Technical Review Program shall utilize sufficient on site personnel who are independent i
of the plant management chain to perform the reviews.
RECORDS 6.2.3.2 Written records of technical reviews shall be maintained. As a minimum these records shall include the results of the activities conducted, the status of recommendations made pursuant to Specification 6.3.2.1 and an assessmeut of company operations related to the reviews performed.
OU ALIFIC ATIONS 6.2.3.3 Personnel performing reviews pursuant to Technical Specification 6.2.3.1 shall have either a bachelor's degree in engineering or related science and at least 2 years professional level experience, at least 1 year of which shall be in the nuclear field, or equivalent education and experience as defined in ANSI /ANS 3.1, 1981, Section 4.1.
III.
Retype of Proposed Chances See attached retype of proposed changes to Technical Specifications. The attached retype reflects the currently issued version of Technical Specifications. Pending Technical Specification changes or Technical Specification changes issued subsequent to this submittal are not reflected in the enclosed retype. The enclosed retype should be checked for continuity with Technical Specifications prior to issuance.
Revision bars are provided in the right hand margin to designate a change in the text.
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ADMINISTRATIVE CONTROLS 6.2.3 INDEPENDENT TECHNICAL REVIEWS A Technical Review Program shall be established, implemented and maintained to encompass the following Technical Review responsibilities.
FUNCTION 6.2.3.1 The Technical Review Program responsibilities shall encompass:
a.
NRC issuances industry advisories, Licensee Event Reports, and other sourcesthatmayIndicateareasforimprovingplantsafety; b.
Internal and external operating experience information that may indicate areas for improving plant safety; c.
Plant operating characteristics, plant operations, modifications, maintenance and surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical, and d.
Making detailed recommendations to the Senior Vice President and Chief Nuclear Officer for procedure revisions equipment modifications or other meansofimprovingnuclearsafetyandplantreliability.
The Technical Review Program'shall utilize sufficient on-site personnel who are independent of the plant management chain to perform the reviews.
RECORDS 6.2.3.2 Written records of technical reviews shall be maintained.
As a minimum these records shall include the results of the activities conducted, the status of recommendations made pursuant to Specification 6.3.2.1 and an assessment of company operations related to the reviews performed.
!LUALIFICATIONS 6.2.3.3 Personnel performing reviews pursuant to Technical Specification 6.2.3.1 shall have either a bachelor s degree in engineering or related science and at least 2 years professional level experience, at least 1 year of which shall be in the nuclear field, or equivaient education and experience as defined in ANSI /ANS 3.1, 1981, Section 4.1.
l 6.2.4 SHIFT TECHNICAL ADVISOR Control Room Commander in the areas of thermal hydraulics,y technical support to the 6.2.4.1 The Shift Technical Advisor shall provide advisor L
reactor engineering, and I
plant analysis with regard to the safe operation of the station.
6.3 TRAINING 6.3.1 A retraining and replacement licensed training program for the station staff shall be maintained under the direction of the Training Manager and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix A of 10 CFR Part 55 and the supplemental requirements specified in Sections A and C of Enclosure 1 of the NRC letter dated March 28, 1980 to all licensees, and shall include familiarization with relevant industry operational experience.
1 SEABROOK - UNIT 1 6-5 Amendment No.
4 IV.
Safety Evaluation of License Amendment Rennest 93 09 Proposed Channes The purpose of License Amendment Request 93 08 is to propose changes to the Seabrook Station Technical Specification 6.2.3, Independent Safety Engineering Group (ISEG). The proposed changes revise the title of Technical Specification 6.2.3 to Independent Technical Reviews and delete the requirement to maintain a five person organization, known as the ISEG, that is dedicated to perform the independent technical reviews. The proposed revision to Technical Specification 6.2.3 maintains the requirement to perform the reviews specified in the current Technical Specification and requires that the reviews be performed by personnel who are independent of the plant management chain.
North Atlantic has long recognized that the current Technical Specification 6.2.3 does not provide flexibility in the performance of the required reviews. In addition, the Technical Specification places a constraint on North Atlantic by requiring the establishment of a separate organization, composed of at least five full time engineers, that is dedicated to perform the independent technical reviews. This constraint places unnecessary limitations upon North Atlantic's utilization of its technical resources in that it requires some duplication of effort in order to ensure that the ISEG reviews the specified material while it maintains independence related to in line functions such as assigning action items, scheduling and expediting the completion of activities. In some cases, the ISEG is not the organization most qualified to perform the reviews of a particular event or industry occurrence. In these cases there is a duplication of review effort as North Atlantic always strives to perform the best review or analysis possible performed even if it means duplicating effort, in these cases where effort is duplicated places an unnecessary burden upon North Atlantic and causes resources to be utilized in a manner that is not the most effective and does not provide any additional benefit with regard to protecting the health and safety of the public. The proposed license amendment will allow North Atlantic to utilize existing programs, such as the Operating Experience Review Program or the human Performance Enhancement Program, to perform some reviews and thereby enhance the effectiveness of the overall organization.
The NRC's. Regulatory Review Group (RRG),in its draft " Assessment of the Seabrook Station Operating License" dated February 1993, examined Technical Specification 6.2.3. The RRG chose this item for review because it is very prescriptive with regard to manpower requirements.
The RRG assessment noted that in the improved j
Standard Technical Specifications (NUREG 1431, Standard Technical Specifications Westinghouse Plants) the ISEG has been replaced with an independent review i
function which provides a relaxation of the five person staffing requirement and permits more flexible methods of performing the independent technical reviews. The i
RRG concluded that the:
"Seabrook Technical Specification requirement related to the composition of the ISEG provides no flexibility."
Furthermore, the RRG noted that a Technical Specification change could be submitted adopting the Improved Standard Technical Specification approach and thereby providing considerable flexibility in the implementation of what is currently the ISEG review requirement.
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The proposed revision to Technical Specification 6.2.3 utilizes 'the approach to independent technical reviews that is presented in NUREG-1431, Standard Technical Specifications Westinghouse Plants. The proposed revision will ensure ' that the.
reviews specified in the current Specification 6.2.3 are performed through the establishment of a Technical Review Program. The Technical Review Program will allow North Atlantic to more effectively manage its resources in performing the required reviews.
The Technical Review Program will be defined in North Atlantic procedures which are available for review at Seabrook Station.
From the perspective of review j
requirements and recording keeping there will not be a major change from the l
current practices'which utilize the ISEG to perform the reviews, with the exception l
of maintaining a full-time five person organization dedicated to performing these I
I reviews.
The proposed change adopts the independent review principles contained in the Improved Standard Technical Specifications, NUREG-1431, Standard Technical Specifications Westinghouse Plants.
North Atlantic believes that the proposed changes are consistent with the intent of the Executive Order issued by President Bush and with the NRC Regulatory Review effort as discussed during the 1993 Regulatory Information Conference. The ISEG composition requirement is burdensome to a utility as it restricts the capability to utilize resources to their maximum advantage and does not result in an increase in the protection afforded to the health and safety of the public.
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V.
Determination of Sien t rica n t Ilarards for License Amendment Request 93 09 Proposed Channes (1) The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
The requirements of Technical Specification 6.2.3, Independent Safety Engineering Group (ISEG), specify reviews that must be performed and specify the staffing of a review organization. The changes proposed by License Amendment Request (LAR) 93 08 delete the requirement to maintain a full-time five person organization dedicated to performing the reviews. The revised Technical Specification 6.2.3, independent Technical Reviews, continues to specify the review requirements that are in the current Technical Specification, and therefore satisfy the intent of NUREG-0737, Itern 1.B.1.2.
The proposed change does not affect the operation of the plant, nor does it revise any plant design, configuration, or procedures related to the operation of the plant.
Since the physical plant is not affected and the only change is the deletion of the requirement to maintain a five person organization dedicated to performing the independent technical reviews, the probability of an accident previously evaluated is not affected by the changes proposed in License Amendment Request 93 08.
Additionally, since the proposed change affects only the requirements for an organizational composition, it does not have any effect upon the radiological consequences of an accident previously evaluated.
Based upon the foregoing, the changes proposed by License Amendment Request 93-08 do not have any affect on the probability or consequences 'of nay previously evaluated acciden (2) The proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes to Technical Specification 6.2.3 do not affect the design or function of any plant system, structure or component. The changes do not affect procedures related to plant operation nor the way any plant equipment is operated.
Since the revision to the ISEG composition requirement does not affect the operation of equipment, change its reliability, nor revise the requirements for maintenance or repair, the proposed changes do not have the potential to introduce any new failure mechanism.
Therefore, the changes proposed by License Amendment Request 93-08 do not create the possibility of a new or different kind of accident from any previously evaluated accident.
(3) The proposed changes do not result in a significant reduction in the margin of safety.
The proposed revisions to Technical Specification 6.2.3 and in particular to the ISEG composition requirement modify an existing administrative requirement that was established with the issuance of the Seabrook Station Operating License. The changes do not alter the design or operation of any plant system structure or component, nor do they change the manner in which any plant system is operated.
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4 The changes do not introduce any new failure mode and do not affect any previously analyzed accident or malfunction, nor do the changes create the possibility of a different accident or malfunction not previously analyzed, in addition, the ISEG composition requirement is an NRC imposed administrative requirement that is not referenced in the bases of any Technical Specification to define or establish a margin of safety for the operation of the plant.
Therefore, the changes proposed by License Amendment Request 93-08 do not reduce the margin of safety as defined in the bases of any Technical Specification.
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VI.
Proposed Schedule for License Amen' ment Issuance and Effectiveness d
North Atlantic requests NRC review of License Amendment Request 93-08 and issuance of a license amendment having immediate effectiveness by December 30, 1993.
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t VII.
Environmental Impact Assessment North Atlantic has reviewed License Amendment Request 93-08 against the criteria of 10CFR$1.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, North Atlantic concludes that the proposed change meets the criteria delineated in 10CFR51.22(c)(9) for a categorical exclusion from the requirements for an Environmental Impact Statement.
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VIII. Supportine Informatio2 Revisions to Updatud Final Safety Analysis Report Sections 1,9 and 13.4.3 are enclosed.
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cj 3. o SEABROOK UPDATED FSAR reports are issued to the Committee and the results discussed - regularly scheduled meetings.
13.4.2.4 Audit program NSARC audits are considered management audits and are normally performed under the qualiry assurance audit program described in the Seabrook Operational Quality Assurance program contained in Section 17.2.
13.4.3 N~~'
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Independent Safety Engineering Group (ISEG) performs r[e.T k
views of plant op ations, independent of those reviews performed by the Station Operatic Revi Committee (SORC) and the Nuclear Safety Audit and Review Committee (NSAR The ISEG g co= posed of five, full time, dedicated engineers located nsite who report t eir findings to the Director - Quality Programs. Quall'fications bers meet or exceed the requirements in Section 4.[of ANS 3.1, of the ISEG m i.e., a Bachelo. s degree in engineering and two to four years e perience in their field, inc ing one to two years nuclear exp rience.
A e ISEC members e
receive,'asaminimb,theTrainingforSupervisorsidentifi in Subsection 13.2.2.
Tne ISEG was activated three months prior to fuel-cading.
13.4.3.1 Duti - and Re st..nsibilities N
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a.
The general review functions of the ISEC indlude:
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Examine plant oper(ting characteri tics, NRC issuances, and f
other appropriate sogrees of platre design and opeMing experience informatio. thatmay/indicateareasforimproving plant safety.
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2.
Maintain surveillance of pl' ant. operations and maintenance activities to provide indepettdent verification that these activities are performed correl ly and that human errors are reduced as far as practicable.
3.
Perform independent review and evaluation of plant activities including maintenance, modifications,\\ operational problems, and operational analysis, and aid in the est'ablishment of programmatic requirements for plant activhies.
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Where usef improvements can be achieved, this group develops and pres,ehts detailed recommendations to corporate management for such items as revised procedures or equipment.
modifications.
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The ISEG is not responsible for sign-off functions such that'it becomes involved in the operating organization.
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SE.GROOK UPDATED FSAR c 13. ^. 3. 2 Rever4 The 5'SEC-prepares written summaries of reviews and evaluations perforca as noted above'.NThese summaries include the results of and reco==er!efions from such reviews and svaluations. Monthly reports containing a d ary of work completed and recommendhrions made are forwarded to rector - Quality Programs, with an information' copy to the NHY P ent and Chief Executive Officer. The Director - Quality Pro Rams, hat een given appropriate and sufficient authority to ensure that
. Gits 4nd recoc=endations of reports are addressed and acted upon by the erating orga'nizations.
13.4.3.3 Charter The c
. ion, qualifications, duties and responsibilities, and re
-ing-ements stated above are incorporated into the ISEC Charter.
1 13.4-5 e
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SEABROOK UPDATED FSAR
Response
See Updated FSAR Subs'ection 13.2.1.
Task I.A.3.1 Revise Scope and Criteria for Licensing Examinations -
Simulator Exams (Ites 3) ()GREG-0737) i Position:
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Simulator examinations are included as part of the licensing erninations.
Response
See Updated FSAR Subsection 13.2.1.
Task I.B.1.2 Indeoendent Safetv Engineerine Group (1mREG-07373 Position:
Each applicant for an operatin'g license shall establish an ensite Independent Safety Engineering Group (ISEG) to perform independent reviews of plant operations.
4 The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience infor: ation that may indicate areas for improving plant safety. The ISIG is to perform independent review and audits of plant activities including maintenance, modifications, operational problems, and operational analysis, and aid in the establiduant vi propan:3.atic requireceuts iur plant activit:.es. Vnere useful improvements can be achieved, it is expected that this group vill develop and present detailed recoc:nendations to corporate management for such things as revised or equipment modifications.
Another function of the ISEG is to =aintain' 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 canagement on the overall quality and safety of operations. ISEG need not perform detailed audits of plant operations and shall not be responsible for sign.off functions such that it becomes involved in the operating organization, Resconse:
See Updated FSAR Subsections 13.2.2 and 13.4.3 and Technical Specifi 6.2.3.
y TN5EST 55 1.9-3
l IliSERT A l
13.4.3 INDEPENDENT TECHNICAL REVIEWS I
A Technical Review Program is established, implemented and maintained to encompass the following Technical Review Responsibilities and to address the reviews of NUREG-0737, Task
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I.B.1.2.
I 13.4.3.1 E_ unction The Technical Review Program responsibilities encompass:
a.
NRC issuances, industry advisories, Licensee Event
- Reports, and other sources that may indicate areas for improving plant safety; b.
Internal and external operating experience information that may indicate areas for improving plant safety; c.
Plant operating characteristics, plant operations, modifications, maintenance and surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical; and d.
Makeing detailed recommendations to the Senior Vice l
President and Chief Nuclear Officer for procedure revisions, l
equipment modifications or other means of improving nuclear safety and plant reliability.
The Technical Review Program utilizes sufficient on-site personnel who are independent of the plant management chain to perform the reviews described above and specified in Technical Specification 1
6.2.3.1.
13.4.3.2 Records Written records of technical reviews are maintained.
As a minimum these records include the results of the activities conducted and the status of recommendations made pursuant to Technical Specification 6.2.3.1 and an assessment of company operations related to the reviews performed.
13.4.3.3 Oualifications Personnel performing the reviews described above and defined in Technical Specification 6.2.3.1 have either a bachelor's degree in engineering or related science and at least 2 years professional level experience, at least 1 year of which is in the nuclear field, or equiklant education and experience as defined in ANSI /ANS 3.1, 1981, Section 4.1.
MR 93-08/UFCR 93-019 1
ILSERT D North Atlantic ensures that the reviews addressed in Task I.B.1.2 are performed as required through the implementation of a Technical Review Program.
See Updated FSAR Subsection 13.4.3 and Technical Specification 6.2.3 for details.
LAR 93-08/UFCR93-019 2