ML20045G653
| ML20045G653 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/25/1993 |
| From: | CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20045G651 | List: |
| References | |
| NUDOCS 9307150010 | |
| Download: ML20045G653 (13) | |
Text
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F1-CE Z/NM~lg M L A L A,, u f..t 6.0 ADMINISTRATIVE CONTROLS h@
6.1 RESPONSIBILITY Pla n + o 6.1.1 The t.. d Manage,
_ @ ll l s
Shall be responsible for overall unit operation and shall delegate in writing the succession to this responsibility during his ' absence.
6.1.2 The Shift Supervisor or, during his absence from the control room, a designated individual shall be responsible for the control room comand r
function. A management directive to this effect, signed by the Vice President - Nuclear shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION 6.2.1 0FFSITE AND ONSITE ORGANIZATIONS Onsite and offsite organizations shall be established for unit operation and corporate management, respectively. The onsite and offsite organiza-tions shall include the positions for activities affecting the safety of the nuclear power plant, a.
Lines of authority, responsibility, and communication shall be established and defined from the highest management levels through intermediate levels to and including all operating organization positions. These relationships shall be documented and updated, as appropriate, in the form of organization charts,
(
functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation. These requirements shall be documented in.the USAR and updated in accordance with 10 CFR 50.71(e).
-.[ Manager;r;-c;': ci; r "..;r "! r.i a-
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b.
The' g?"^^^Oshallberesponsibleforoverallunitsafeoperation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
c.
The Vice President - Nuclear shall have corporate l
responsibility for overall plant nuclear safety and shall take any measures needed to ensure acceptable performance of 1
the staff in operating, maintaining, and providing technical l
support to the plant to ensure nuclear safety.
d.
The individuals who train the operating staff and those who carry out health physics and quality assurance functions may report to the appropriate onsite manager; however, they shall have sufficient organizational freedom to ensure their independ-i ence from operating pressures.
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We PERRY - UNIT 1 6-1 Amendment No.
W, M/,42 9307150010 930625 PDR ADOCK 05000440 P
PDR jf;
P y-ceI/N A R-14 f 7 L A H a d ma n + A 1% e.
,t A 10
-ADMINISTRATIVE CONTROLS
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6.2.3 INDEPENDENT SAFETY ENGINEERING GROUP (ISEG)
FUNCTION 6.2.3.1 The ISEG shall function to examine unit operating characteristics, NRC issuances, industry advisories, Licensee Event Reports, and other sources of unit design and operating experience information, including units of simil-ar design, which may indicate areas for improving unit safety. The ISEG shall make detailed recom.endations for revised procedures, equipment modifications, maintenance activities, operations activities, or other means of improving unit H u a.
lll safety to the Ci :r--
^ 1 M :: O Engineering DepartmentG L,.;t T
COMPOSITION 6.2.3.2 The-ISEG shall be composed of at least five, dedicated, full-time engineers or technically oriented individuals located onsite. Each shall have either (1) a bachelor's degree in engineering or related science and at least 2 years professional level experience in his field, at least 1 year of which experience shall be in the nuclear field, or (2) equivalent work experience as described in Section 4.1 of ANSI /ANS 3.1, December 1981.
RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of unit activities to provide independent verification
- that these activities are per-formed correctly and that human errors are reduced as much as practical.
RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be_ prepared._ main-tained, and forwarded each calendar month to theGmtr, M
Ce4 l
Engineering Departmentx HuA.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shif t Technical Advisor shall provide advisory technical support to the Shift Supervisor in the areas of themal hydraulics, reactor engineering,
- nd plant analysis with regard to safe operation of the unit. The Shift Technical Advisor shall have a bachelor's degree or equivalent in a scientific or engineering discipline and shall have received specific training in the response and analysis of the unit for transients and accidents, and in unit design and layout, including the capabilities of instrumentation and controls in the control room.
6.3 UNIT STAFF OUALIFICATIONS I
6.3.1 Eacn member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI N18.1-1971 for comparable positions, except for the Plant Health Physicist wno shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. The licensed Operators and Senior Operators shall also meet or L
exceed the minimum cualifications of the supplemental recuirements specified in p
Sections A and C of Enclosure 1 of the Maren 28, 1980 NRC letter to all licensees.
- %t responsiale :or sign-off function.
PERRY - UNIT 1 6-7 Amendment No. N. C
. =
l P y-ceI/NAR-/C Y9' L 4%abue f ' A I
Pye 3 af to ADMINISTRATIVE CONTROLS
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6.4 TRAINING rHenA 6.4.1 A retraining and replacement training pqpgram for the un it staff shall be maintained under the direction of the h" Training Sectiorf-'_ :::, and l
shall meet or exceed the requirements and recommendations of S'ectibn 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 March 28, 1980 NRC I
letter to all licensees, and shall include familiarization with relevant industry operational experience.
6.5 REVIEW AND AUDIT 6.5.1 PLANT TERATIONS REVIEW COMMITTEE (PORC)
FUNCT10N Plan t as o
6.5.1.1 The__PgRC shall function to advise the r.cnc _'2 Manages " n "__ ::S C:x: ' :n: 0;:;; r n: '"'""0C on all matters related to nuclear saf ety.
T COMPOSITION R e p l.cc w HA L o.t A o.
2 The PORC shall be composed of the:
Chairman:
Director, Perry Nuclear Engineeri artment Vice-Chairman /.
Manager, Perry Operations n
(
Member:
er, Systems ring Section k
Member:
Manage,
intenance Section Member:
Rea
- ng1 -
Member:
. nager, Radiation-tion Section Member:
Plant Health Physicist 4
Mem Manager, Instrumentation and Con ection
.. mber:
Manager, Licensing and Compliance Sect 1 ALTERNATES 5.5.1.3 All alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in PORC activities at any one time.
MEETING FREQUENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as cor.vened y
by the PORC Chairnn or his &cci; :::: ;?:: m 1
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gtsopee.
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D PERRY - UNIT 1 6-8 Amend:.. ant No.////f,42
PY-CEI/NRR-1649 L Page 4Lof 10
]
Insert A i
6.5.1.2 The Plant Operations Review Committee (PORC) shall be composed'of at least six but not more than eleven members of the Perry Nuclear Power Plant onsite management organization. The members shall be Section heads or above, except for selected Professional-Technical disciplines which report directly to Section heads, collectively having experience and competence in at least the following disciplines: operations, maintenance, technical,-reactor engineering, instrumentation and controls, and' radiation protection, plus any other areas as determined by the Plant Manager. The PORC membership shall be designated in writing by the Plant Manager.
The PORC members shall meet the applicable unit staff _ qualifications for their respective discipline (s) as stated in Specification 6.3.1.
The PORC Chairman shall be drawn from the PORC members and shall be designated in writing by the Plant Manager.
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1
f1-cEZ/NRR-IC V 1 L
/\\ tied m a nt' 2.
f*y e r of lo ADMINISTRATIVE CONTROLS QUORUM pa m$jerify ef f he m e m kers.
- 6. 5.1. 5 The quorum of the PORC necessary for the performance of the PORC responsibility arid authority pfovisions of these Technical Specifications 8
shall consist of The Chairman M;n:::: ::::::::: ::: :: ::::t f: C i t:r. 'n:hdh; di:rn:t::7(or his C:4 T
g L.- desig n et). a n a v fm, 3 altcena te RESPONSIBILITIES memkers m ay ke u.filis c A f e meet the porem re pir em en t.
6.5.1.6 The PORC shall be responsible for:
a.
Review of all Administrative Procedures; b.
Review of the safety evaluations for (1) proposed procedures /
instructions.-(2) changes to procedures / instructions, equipment, systems or facilities, and (3) tests or experiments perfonned under the provisions of 10 CFR 50.59 to verify that such actions do not constitute an unreviewed safety question; c.
Review of proposed procedures / instructions and changes to procedures /
instructions, equipment, systems or facilities which involve an unreviewed safety question as defined in 10 CFR 50.59; d.
Review of proposed tests or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59; e.
Review of proposed changes to Technical Specifications or the Operating License; f.
Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evalua-tion and recomendations to prevent recurrence to the Vice President -
Nuclear and to the Nuclear Safety Review Committee; g.
Review of all REPORTABLE EVENTS; h.
Review of the plant Security Plan and Security Contingency Instruc-tions; i.
Review of the Emergency Plan and implementing instructions; j.
Review of changes to the PROCESS CONTROL PROGRAM, the OFFSITE DOSE CALCULATION MANUAL, and Radwaste Treatment Systems; k.
Review of any accidental, unplanned or uncontrolled radioactive release including the preparation of reports covering evaluation, recommendations, and disposition of the corrective action to prevent recurrence and the forwardinq of these reports to the5:r;. ;l f Manager,I
, W r:- Y -- 9:rt 2 ::. :- M ' ~ '
- 1the Nuclear Safety Review Co
- nittee ano the Vice President - NucleTf; 1.
Review of Unit operations to detect potential hazards to nuclear safety; Investigations or analysis of special subjects as requested by the m.
Chairman of the fiuclear Safety Review Comittee; and Review of the Fire Protecticn Program and impiementing procedures.
n.
PERRY - UNIT I 6-a Amen: rant No. ?A. 5,47,
P Y-c E r/NRR -Ic V1 L A b A m a. -f 4 (Q e G of 16 ADMINISTRATIVE CONTROLS RESPONSIBILITIES. (Continued) 6.5.1.7 The PORC sull:
flot u
g Recomend in uriting to the"in:nL' Manager,l"'"Tapproval or ll a.
disapproval oi items considered under Specifications 6.5.1.6a.
through e., h., i., J., and k., above prior to their implemen-
.1 tation; b.
Render determinations in writing with regard to whether or not each item considered under Specifications 6.5.1.6b. through e.,
.above, constitutes an unreviewed safety question; and Pint)
Provide written notification withi 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to the Vice President-c.
Nuclear and the Nuclear Safety R ew Comittee of disagreement m;. mni anager. :., 2 : n ":r:r r T
, between the PORC and t 4;r.. O anager. %,
...L.. L " L. C i
' m a. ;;r.: however t
=.. n;nt.'.shall b' ave responsibility for resolution of such dis N
i kagreements pursuant to Specification 6.1.1. above.
)
RECORDS l
- 6. 5.1. 8 The PORC shall maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility provisions of these Technical Specifications. Copies shall be (f
provided to the Vice President - Nuclear anif the Nuclear Sa'fety Reviiw Committee.
6.5.2 NUCLEAR SAFETY REVIEW COMMITTEE (NSRC)
FUNCTION 6.5.2.1 The NSRC shall function to provide independent review and audit of designated activities in the areas of:
Nuclear power plant operations, a.
b.
Nuclear engineering, c.
Chenistry and radiochemistry, d.
Metallurgy, Instrumentation and control, e.
f.
Radiological safety, Mechanical and electrical engineering, g.
h.
Quality assurance practices and administrative controls, and i.
Nondestructive testing.
&D..
The NSRC shall report to and advise the Vice President - Nuclear on those areas of responsibility speci'4ed in Specifications 6.5.2.7 and 6.5.2.8.
PERRY - UNIT 1 6-10
'cendment No. 22, 76,42
_ f y-cEI/NAK~ IC 79 L.
A NAwant A l'a y 7 a+
lo i
ADMINISTRATIVE CONTROLS COMPOSITION 6.5.2.2 The membership of the NSRC shall be composed of at least eight person-nel appointed by the Vice President - Nuclear to provide collective experience l
and competency in the following areas:
Nuclear power plant operations Nuclear engineering Chemistry and radiochemistry Metallurgy Nondestructive testing Instrumentation and control Radiological safety Mecnanical and electrical engineering Administrative controls and quality assurance practices The Chairman, appointed by the Vice President - Nuclear shall have 10 years l
of power plant experience, of which 3 years shall be nuclear power plant experience.
The. NSRC members shall hold a bachelors' degree in an engineering or physical science field, or equivalent experience, and a minimum"of 5' years:-
of technical experience of which a minimum of 3 years shall be in one or more of the disciplines in Specification 6.5.2.1.
Competent alternates may be designated in advance and consultants may be used for in-depth expertise if-desired by the committee.
ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the NSRC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in NSRC activities at any one time.
CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the NSRC Chairman to provide expert advice to the NSRC.
MEETING FREQUENCY a-6.5.2.5 The NSRC shall meet":t ::::t :n : ;:- : l:nd:r ;;:rt:r durM; %e3 P it. '
z ;; - ;f.ca t e.;i;r f;"
'n; ';;l 1;; d i r.; _ r.d a t 6 east once per i
6 month p ;. ;ft:r.;
QUORUM Aasi n.e 3
6.5.2.6 The quorum f the NSRC necessary for the performance of the NSRC review and audit fu tions of these Techgical Specifications shall consist of No more than a minority of ll the Chairman or his =:1;u:;; :!::rn::;.and at least four but not less than one-half of the NSRC members including alternates.
the quorum shall have line responsibility for operation of the-unit.
PERRY - UNIT 1 6-11 Amendment No. 36
l' Y~ C EZ /N RR~ 14 f f L A #ashmut A ADMINISTRATIVE CONTROLS i;h 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 safety, and.
3 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 Section7n:-- " The C;nc rC'_ Manager; "'"""2 shall ll l approve Administr'at veprocedures.
Plu tX X
- 4. As]
b.
Proposed modifications to plant structures, systems and components that affect nuclear safety shall be uviewed by individuals desi -
nated by the f"irc;=r. ":r "xl::rr ingineering Departmenta ach lll-such modification shall be reviewed by a qualified individual (s) other than the individual (s) which desi_gned the modification, but who may be from the same section as the individual (s) which designed the modifications. Proposed modifications to plant c
structures, systems and components that affect nuclear safety shall be reviewed by PORC and appro_ved prior to implementation by the Nl
. C: : n" Managerf """"" 'o
" fluf C
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 impiementation by the-. _. ManageC "'"""' e ll l Flut d.
Sections responsible for reviews, including cross-disciplinary reviews, performed in accordance with Specifications 6.5.3.la. and 6 4 3.lc., shall be designatpd in writing by PORC and approved by thP;.:ncrp Managerf""""".;othe individual (s) performing the review ll g shall meet or exceed the quaTification requirements or appropriate section(s) of ANSI N18.1-1971; e.
Each review shall include a detennination 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 determine whether or not an unreviewed safety question is involved shall be performed. Pursuant to 10 CFR 50.59, NRC approval of items involving unreviewed safety questions shall be obtained prior to j
implementation; and ih I
PERRY - UNIT 1 6-14 Amendment No. 22,42
.~
l'Y~ C E X/NtW-lC YT L A +fadmant A l'sy 9 a lo ADMINISTRATIVE CONTROLS 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 rgguirements of Soec<fication
]
6.5.1.6 and approved by the '_:xrManagerf":m i:' ::S NRC approv i shall be obtained as ' '
r appropriate, g
6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:
I a.
The Commission 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 Presiden: - Nuclear.
.i 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is 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 notlfied within' 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, i
b.
A Safety Limit Violation Report shall be prepared. The report shall be reviewed 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 Comission, the 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 P
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 1.33, Revision 2. February 1978.
' $$b PERRY-UNIT 1 6-15 Amendment No. 22,;6, 42
P y-cEI/NK R - l C V 9 L A u,,,u t t e
ADMINISTRATIVE CONTROLS '
I"J i 10 ef 10 6.8 PROCEDURES / INSTRUCTIONS AND PROGRAMS (Continued) b.
The applicable procedures required to implement the requirements of NUREG-0737 and supplements thereto.
c.
Security Plan implementation.
d.
Emergency Plan implementation.
e.
PROCESS CONTROL PROGRAM implementation.
f.
OFFSITE DOSE CALCULATION MANUAL implementation.
g.
Radiological Environmental Monitoring Program implementation.
h.
Fire' Protection Program implementation.
6.8.2 Each administrative procedure of Specification 6.8.1, and chances thereto, shall g reviewed by the PORC and shall be ~ approved by the"u.de,. ll f%t Managerf ^"T prior to implementation. All procedures / instructions shall h
4 be ~ reviewed periodically as set' forth-in administrative pr'ocedures. '
~
6.8.3 Temocrary changes. Temporary changes to procedures / instructions which do not change the intent of the approved procedures / instructions shall be j
approved for implementation by'two members of the plant management staff, at
,/
least one of whom holds a Senior Operator license. These temporary changes -
shall be documented. The temporary changes shall be approved by the original approval authority within 14 days. For changes.to' procedures / instructions which may involve a change in intent of the procedures / instructions, the original approval authority shall approve the change prior to implementation.
6.8.4 The following programs.shall be established, implemented, and maintained:
a.
Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as_ low as practical levels. - The systems include the HPCS, RiiR, RCIC, LPCS, feedwater leakage control system, the hydrogen analyzer portion of Combustible Gas Control, and post-accident sampling systems. The program shall include the following:
1.
Preventive maintenance and periodic visual inspection requirements, and 2.
Integrated leak test requirements for each system at refueling cycle intervals or less.
$ps pe..,
PERRY - UNIT 1 6-16 Amendment No. /22',42
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PY-CEI/NRR-1649 LL i
- Page 1 of 3 SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards considerations are included in the Commission's Regulations, 10CFR50.92, which state that the operation of'the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any previously evaluated, or (3) involve a significant reduction in a margin of safety.
The proposed amendment has been reviewed with respect to these three factors and it has been determined that the proposed changes do not involve a significant hazard because:
1.
The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.
These changes are administrative in nature only. -The change to the Plant Operations Review Committee (PORC) composition Specification-provides statements defining the requirements for committee membership, including the necessary training and qualifications. The membership requirements provide for representation from selected plant functional review areas, together with provisions permitting the Plant Manager to expand the-membership, thereby enhancing the interdisciplinary review function of the PORC. The disciplines listed within the Specification correspond to the plant functional areas found in the BVR Standard Technical Specifications, but have been renamed to reflect the generic disciplines identified in ANSI N18.1.
Overal1 PORC membership qualifications are maintained as a result of the proposed changes.
The revision in the number of PORC personnel from nine to "at least six but not more than eleven" provides for supplementation of'the committee membership to broaden the experience base. The lover bound of six is a result of eliminating a requirement for duplication of a specific-discipline (Health Physics), removing the requirement-for Licensing representation, and recognizing that the PORC Chairman could be drawn from among the members instead of being an additional individual, as at present.
The uppe> bound of eleven helps to ensure the continuity of reviews.
Also, the qualifications and requirements for membership have been clearly specified. The quorum requirements have been modified to ensure that at least a majority of the members vill be present at all meetings, regardless of the total number of members specified to make up the PORC at any given time.
The proposed changes to the other Section 6 Specifications to-replace the specific management position titles with functional titles in no way reduces the authority or confuses the responsibilities for safe operation of the plant by management personnel since the functional titles used within the Technical Specifications vill be correlated against the
5
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1 PY-CEI/NRR-1649 L i
Page 2 of 3 l
current position-specific titles listed within plant administrative procedures and the USAR. This vill continue to make it clear as to which specific positions are responsible for the overall plant nuclear safety and unit operations.
The editorial changes are being made to avoid confusion.between similar terms and eliminate a no longer needed stipulation.
Therefore, they are strictly administrative and have no bearing on the probability or consequences of an accident.
These administrative changes by their nature do not impact accident initiation or mitigation sequences, or other assumptions contained-in the safety analyses, nor do they affect the Technical Specifications that preserve safety analysis assumptions. Additionally,.these' changes do not modify the physical design and/or operation of the plant. Therefore, they cannot possibly impact the probability or consequences of any previously analyzed accidents.
2.
The proposed changes do not create the possibility of a new or different kind of accident.from any accident previously evaluated.
These changes are administrative in nature only. No physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.
No material procedural changes are proposed. The proposed language does not significantly alter the overall requirements for PORC 1
membership, while preserving the quorum requirements and providing for cross-disciplinary reviews to be performed by the various disciplines represented on the Committee. Replacing the specific. management position titles with functional titles cannot confuse organizational position responsibilities since the USAR and plant administrative procedures vill continue to make it clear as to which specific positions are responsible for the overall plant nuclear safety and unit operations.
The editorial changes are strictly administrative and are being made to avoid confusion between similar terms and eliminate a no longer needed stipulation. Therefore, these proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
3.
The proposed changes do not involve a significant reduction in a margin of safety.
The changes being proposed are administrative in nature and do not relate to or modify the margin of safety defined in and required to be maintained by the Technical Specifications. The deletion of the position-specific composition list of the PORC membership and it's replacement by a set of requirements defining the necessary level of training and qualifications (i.e. the technical, operational and management experience required) vill not decrease the effectiveness of=
this organization. The PORC vill continue to provide cross-disciplinary reviews of the operational, maintenance, design and safety issues
--m
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[c PY-CEI/NRR-1649 L Page 3 of 3 addressed in their charter. This proposed change preserves reviews in selected plant functional areas while maintaining a varied PORC membership composition. Administrative controls contsined within the USAR and plant administrative" procedures are in place to control the.
membership of the PORC and to specify management lines of authority.
This amendment request also proposes to utilize functional management titles 'rather than position-specific titles for selected management-positions. These functional management positions vill be clearly identified and cross-referenced to the corresponding position-specific titles within plant procedures and the USAR. Therefore, distinct, unambiguous lines of authority and responsibility vill continue to exist and be delineated. The editorial changes merely avoid confusion between similar terms and eliminate an obsolete requirement.
Both of the major changes vill simply reduce the need for. license amendments based solely on title changes. Therefore, based on the'above discussion, the proposed changes do not involve a significant reduction in the margin of safety.
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