ML20059H632
| ML20059H632 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/14/1994 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | |
| Shared Package | |
| ML20059H630 | List: |
| References | |
| NUDOCS 9401310055 | |
| Download: ML20059H632 (9) | |
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, SEABROOK STATION UNIT 1 iiiii2EE Aflanfic Energy Service Corporation Facility Operating License NPF-86.
Docket No. 50-443 License' Amendment Request No. 93-20 ADMINISTRATIVE / EDITORIAL CHANGES TO TECHNICAL SPECIFICATIONS '
This License Amendment Request is submitted by North Atlantic Energy Service Corporation pursuant to 10CFR50.90. The following information is enclosed in support of this License Amendment Request:
Section 1 - Introduction and Description of Proposed Changes Section ll -
Markup of Proposed Changes Section ill -
Retype of Proposed Changes 4
Section IV -
Safety Evaluation of Proposed ChangesSection V -
Determination of Significant Hazards for Proposed ChangesSection VI -
Proposed Schedule for License Amendment issuance and Effectiveness Section Vil -
EnvironmentalImpact Assessment Sworn and Subscribed to before me this N day of Tetmattu ,1994
- 3. stabi 2 S GW1 ' / Ted C. Felgenpfum Ndtary Public Senior Vice President and Clyfef Nuclear Officer 9401310055 940114 #
PDR ADOCK 0500044T $<
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- 1. Introduction and Description of Proposed Channes .
A. Introduction The purpose of. License Amendment Request 93-20 is to propose several changes to administrative controls in the Seabrook Station Technical Specifications and to propose a number of editorial changes. The administrative controls are specified in Secticn 6.0 of the Seabrook '
Station Technical Specifications. The editorial changes occur throughout the Technical Specifications.
Changes to the administrative controls in Section 6.0 are proposed to:
- Redefine the composition of the Station Operation Review Committee (SORC) based on i experience and expertise and delete the requirement that no more than two alternate SORC members shall participate as voting members in SORC activities. The areas of expertise include Nuclear Power Plant Administrative Controls, Mechanical Maintenance, Electrical Maintenance, instrumentation & Control, Chemistry, Health Physics, Operations, Technical Support / Engineering, and Reactor Engineering. The SORC Chairman will continue to be the Station Manager or his designated a!temates, and the Station Manager will appoint all members of SORC in writing. Alternate members will also be appointed in writing by the Station Manager, -
and will be required to have qualifications equivalent to those of the SORC member. Defining i SORC composition in this manner rather than by the current method utilizing organization titles ensures that the SORC haA the desired experience and expertise, allows operational flexibility with a combination of menWers and alternates and eliminates the requirement to request a i Technical Specification amendment when the organization is changed. i
- Create a Station Qualified Reviewer Program whereby review of designated procedures or J classes of procedures that are required by Technical Specification 6.4.1.6a will be performed by Station Qualified Reviewers and approved by designated managers. These reviews would l be in lieu of reviews by the SORC. Those procedures or classes of procedures that would be .l reviewed by a Station Qualified Reviewer in lieu of SORC will be designated in writing by the ]
Station Manager. Station Qualified Reviewers and managers authorized to approve procedures j will be designated in writing by the Station Manager. Procedures which require a 10CFR50.59 i evaluation will continue to be reviewed by SORC. The purpose of this program is to reduce the amount of material that is currently being reviewed by SORC by eliminating those less significant items that do not affect nuclear safety and allow ng SORC to direct its attention to safety related activities. This proposed program is similar to Qualified Reviewer Programs approved by the NRC for the Limerick Generating Station, Units 1 and 2, and the Calvert Cliffs Nuclear Power Plant.
- Delete the requirement to perform periodic procedure reviews. Currently, Technical Specification 6.7.2 requires that each procedure of Specification 6.7.1 be reviewed periodically as set forth in administrative procedures. The North Atlantic Operational Quality Assurance Program (OQAP) and the Seabrook Station administrative procedures specify that Station l procedures will be reviewed at least every two years to determine if changes are necessary or !
desirable. However, North Atlantic has determined that the biennial procedure reviews require !
a significant expenditure of resources, impose a significant administrative burden, and do not significantly contribute to the quality of plant procedures. Most procedure changes are identified during the performance of other activities, such as plant design changes, operating experience reviews, and when the procedure is being used to perform plant evolutions. These existing i programmatic requirements will ensure that procedures are reviewed and revised when required, and make biennial procedure reviews redundant and unriccessary. North Atlantic is submitting a change to the OQAP under separate cover to delete the biennial procedure review requirement [see Reference (b)].
- Revise the requirement in Technical Specification 6.4.2.9 to forward Nuclear Safety Audit.
Review Committee (NSARC) meeting minutes to the Senior Vice President within 14 days following each meeting to forwarding the minutes within 30 days following each meeting. The 1
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4-current requirement places an unnecessary administrative burden on Seabrook Station staff since any significant safety problems found during NSARC mview would be reported to senior management by the NSARC Chairman prior to the issuance of the meeting minutes. A similar change from 14 to 30 days is made for reports that aren't included in the NSARC minutes. The change would have no effect on plant systems or operation and would not adversely impact nuclear safety.
Editorial changes included in License Amendment Request 93-20 delete items that only applied ~ ;
prior to the plant exceeding 5% power or until completion of the first refueling outage, revise -
system / equipment names to be consistent with those used elsewhere in the Seabrook Station Technical Specifications, correct the value used for Reactor Coolant System volume, clarify the .
NSARC Function, Composition, and use of alternates, and update the Bases for a Technical Specification requirement that was not included in the final draft of the Seabrook Station Technical Specifications.
For all of the above changes, there are no associated modifications to plant systems, structures, l or components, nor is the design, function, or method of operation of any plant system, structure, or component altered.
B. Description of Proposed Changes
- Index page ix: Technical Specification 3/4.10.6 is deleted. The basis for deleting Technical .
Specification 3/4.10.6 is described below.
- index page xiv: Technical Specification 6.4.2, Station Qualified Reviewer Program, is added to the index, current Technical Specification 6.4.2, Nuclear Safety Audit Review Committee (NSARC) is renumbered.to Technical Specification 6.4.3, and the page numbers for the ;
Function, Composition, Altemates. Consultants, and Audits sections are revised. !
- Section 1.31: The definition for Containment Enclosure Building integrity refers to the ;
Containment Enclosure Filtration System. This definition is revised to state'" Containment Enclosure Emergency Air Cleanup System" vs" Containment Enclosure Filtration System". The +
revised terminology is consistent with Technical Specification 3.6.5.1. ,
- Bases for Technical Specification 2.2.1: Page B 2-7, first paragraph, 9th line is changed to show that the time required for a signal to reach the Reactor trip breakers following-the simultaneous trip of two of more reactor coolant pump bus circuit breakers shall not exceed 1.5 '
seconds vs 1.2 seconds. This is consistent with UFSAR Section 7.2, Table 7.2-3, Reactor Trip .
System Instrumentation.
- Technical Specification 3.3.1, Table 4.3-1: Table notation (13) states that the - TRIP ACTUATING DEVICE OPERATIONAL TEST shall verify the OPERABILITY of the undervoltage .
and shunt trip circuits for the Manual Reactor Trip Function and the OPERABILITY of the !
Bypass Breaker trip circuits. An asterisk next to Table Notation (13) refers to a note at the bottom of page 3/4 3-13, that states complete verification of shunt trip circuit OPERABILITY will- !
be implemented prior to startup from the first planned or unplanned shutdown, to MODE 3 or lower, occurring after July 30,1992. This testing was completed during the second refueling '
outage and thus this note is no longer required. The asterisk and the note are deleted.
- Technical Specification 3.3.3.6, Action b.: The term " containment atmosphere-high range radialbn monitor" is changed to " containment post-LOCA high range area monitor" This is consistent with Table 3.3-10 of Technical Specification 3.3.3.6.
- Technical Specification 3.4.1.2: The double asterisks in the APPLICABILITY statement and the reference to Special Test Exception 3.10.6 (which involves natural circulation testing) are doeted. The basis for deleting Special Test Exception is described below.
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- TechrCcal Specification 4.6.3.2: The phrase "during the COLD SHUTDOWN or FkEFUELING l MODE" is changed to "dt; ring shutdown".to be consistent with similar Technical Specifications (e.g . Technical Specifications 4.6.2.1 and 4.6.2.2).
- Technical Specification 3.7.1.2: The asterisk in the APPLICABILITY statement and (ne note at the bottom of the page stating that this Te::hnical Specification is not required in Mode 3 until initial criticality is achieved are deleted.
- Technical Specification 3/4.10.6: This Special Test Exception is deleted. It concerns suspending the limitation of Technical Specification 3.4.1.2 (Reactor Coolant Loops and Coolant l Circulation) during the performance of natural circulation testing. This testing is only required 1 to be performed during initial startup testing, and was performed during low power testing. l
- Bases for Technical Specification 3/4.1.2: The reference to Mode 3 in the last paragraph is deleted. Technical Specification 3.1.2.7, Isolation of Unborated Water Sources - Shutdown, does not apply in Mode 3.
- Bases for Technical Specification 3/4.2.5: In the first paragraph, last line, " pressure" is added l after the word " pressurizer" for clarity. j
- Bases for Technical Specification 3/4.3.1 and 3/4.3.2: " Equation 3.3-1" is changed to " Equation 2.2-1" on page B 3/4 3-2, first paragraph, second line and twelfth line, to be consistent with i Technical Specification 3.3.2. ;
- Bases for Technical Specification 3/4.4.0: The second paragraph of the Bases for Technical Specification 3/4.4.8 is deleted. This paragraph refers to an ACTION statement which was not included in the final draft of the Seabrook Station Technical Specifications. However, this paragraph was inadvertently included.
- Bases for Technical Specification 3/9.10.6: The Beses are deleted consistent with deleting Technical Specification 3/4.10.6 as described above.
- Technical Specification 5.4.2: The total water and steam volume of the Reactor Coolant System was revised from 12,265 ft to 12,255 ft' to reflect the removal of the Resistance Temperature Detector (RTD) bypass piping.
- Technical Specification 6.3.1: The reference to Appendix A of 10 CFR 55, which no longer exists, was deleted. The phrase " sections A and C of Enclosure 1 of the NRC letter dated March 28,1980 to all licensees" was replaced with "NUREG-1021" The letter which is currently.
referenced was superseded by NUREG-1021.
- Tchnical Jpecification 6.4.1.2 as it currently exists is replaced with the following:
"6.4.12 The SORC shall, as a minimum, be composed of the Chairman and nine indivkiuals who collectively have experience and expertise in the following areas:
Nuclear Power Plant Administrative Controls Mechanical Maintenance Electrical Maintenance instrumentation & Control Chemistry -l Health Physics j Operations l Technical Support / Engineering Reactor Engineering The Station Manager shall serve as Chairman of the SORC and shall appoint the SORC members in writing."
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- Technical Specifhation 6A.1.3 rephces the reference to having no more than two alternates l participate as voting members in SORC activities at any one time with the following statement:
1 l~ . and shall have qualifications equivalent to those of the members."
- Technical Specificatien 6.4.1.4: The statement " ..by the SORC Chairman or his designated alternate" is changed to " ..by the SORC Chairman or one of his designated attemates." This provides the flexibility of having more than one designated alternate.
l E Technical Specification 6.4.1.5:
- The statement " ..shall consist of the Chairman or. his designated alternate and four members.. " is changed to " ..shall consist of the Chairman or one -
of his designated alternates and at least four SORC members.. "
- l l-L - The following statement was added to Technical Specification 6 4.1.6a:
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" Procedures and programs required by Specification 6.7 that are designated for j review and approval by the Station Qualified Reviewer Program in accordance j with Specification 6.4.2 do not require SORC review". -
- Technical Specification 6.4.1.6i: " Security Plan" is added between " recommended" end
" changes" for clarity.
- Technical Specification 6.4.1.6): " Emergency Plan" is added between " recommended" and -)
" changes" for clarity.
i i - Technical Specification 6.4.1.6m: " Fire Protection Program"is added between " recommended" l and " changes" for clarity.
- The following new Technical Specifications are added:
l 6.4 2 STATION QUALIFIED REVIEWER PROGRAM !
l FUNCTION !
l 6.4.2.1 The Station Manager may establish a Station Qualified Reviewer Program l whereby required reviews of designated programs and procedures required by l
Specification 6.4.1.6.a are performed by Station Qualified Reviewers and approved by designated managers. These reviews are in lieu of reviews by the SORC.
However, procedures which require a 10 CFR 50.59 evaluation must be reviewed by the SORC.
RESPONSIBILITIES 6.4.2.2 The Station Qualified Reviewer Program shall:
- a. Provide for the review of designated programs, procedures, and changes thereto by a Quahfied Reviewer (s) other than the individual who prepared the procedure, program, or change.
1 i b. Provide for cross-disciplinary review of programs, procedures, and changes thereto when organizations other than the preparing organization are affected j by the procedure, program, or change. !
- c. Ensure cross-disciplinary reviews are performed by a Qualified Reviewer (s) in affected disciplines, or by other persons designated by cognizant Managers or Directors as having specific expertise required to assess a particular program, j procedure or change. Cross-disciplinary reviewers may function as a !
committee.
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- d. Provide for a screening of designated programs, procedures, and changes thereto to determine if an evaluation should be performed in accordance with ;
the provisions of 10 CFR 50.59 to verify that an unreviewed safety quastion does not exist. This screening will be performed by personnei trained and qualified in performing 10 CFR 50.59 evaluations.
- e. Provide- for written recommendation by the Qualified Reviewer (s) to the ;
responsible Manager for approval or disapproval of programs and procedures -
considered under Specification 6.4.1.6a and that the program or procedure was screened by a qualified individual and found not to require a 10 CFR 50.59
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6.4.2.3 If the responsible manager determines that a new program, procedure, or. ,
change thereto requires a 10 CFR 50.59 evaluation, that Manager will ensure the required evaluation is performed to determine if the new procedure, program, or change _ -
involves an unreviewed safety question. The new procedure, program, or change will then be forwarded with the 10 CFR 50.59 evaluation to SORC for review. ,
6.4.2.4 Personnel recommended to be Station Qualified Reviewers shall be designated in writing by the Station Manager for programs and procedures within the scope of the Station Qualified Reviewer Program.
6.4.2.5 Changes to procedures shall be made in accordarice with Specification 6.7.3 ,
with the exception that changes to procedures for which reviews are assigned to ;
Qualified Reviewers will be reviewed and approved s described in Specification l 6.4.2.2. ,
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6.4.2.6 The review of programs and procedures performed under the Station Qualified Reviewer Program shall be documented in accordance with administrative procedures.
TRAINING AND OUAllFICATION ]
.1 6.4.2.7 The training and qualification requirements of personnel designated as a j Qualified Reviewer in accordance with the Station Qualified Reviewer Program shall be l in accordance with administrative procedures. .;
- Existing Technical Specification 6.4.2 was renumbered based on adding the above Technical Specifications.
- Existing Technical Specifications 6.4.2.1 and 6.4.2.2: These Specifications were renumbered il to 6.4.3.1 and 6.4.3.2, respectively, and the description of the function and composition of NSARC were revised. The current description of the NSARC function states the following:
"The NSARC shall function to provide independent review and audit of designated activities in the areas of,
- a. Nuclear power plant operations,
- b. Nuclear engineering,
- c. Chemistry and radiochemistry,
- d. Metallurgy, l
- e. Instrumentation and control, ;
- f. Radiological safety, l
- g. Mechanical and electrical engineering, and -l 5
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- h. Oudity assurance practices."
The NSARC shall report to and advise the Senior Vice President on those areas ot responsibility -
specified in Specifications 6.4.2.7 and 6.4.2.8."
The proposed description would remove the words "in the areas of" and would move the areaa l listed as a. through h. to the composition section. '
The NSARC composition section would read as follows:
"The NSARC shall be composed of at least five .(5)' individuals. The Chairman, Vice Chairman and members, including designated alternates, !
shall be appointed in writing by the Senior Vice President. Collectively, the ;
individuals appointed to the NSARC should have experience and expertise in the following areas: .
[ areas a. through h. would be listed as they currently appear in Technical' Specification 6.4.2.1]
Each member shall meet the qualification of ANSI 3.1-1978, Section 4.7." ,
l The list of areas (a through h) would remain unchanged. The designated NSARC review and ,
audit responsibilities would be specified in Technical Specifications 6.4.3.7 and 6.4.3.8, !
respectively. These changes more accurately reflect the duties and necessary composition of the NSARC.
Existing Technical Specification 6.4.2.3: This Technical Specification is renumbered to 6.4.3.3, ,
and the words "to serve on a temporary basis" are deleted. These words are confusing and ;
unnecessary. Alternate members are appointed to serve indefinitely, but are used only when '
the regular member cannot attend a meeting. The intent of this section is to ensure that regular -
NSARC members normally attend NSARC meetings. This intent is achieved in the statement '
" ..no more than a minority shall participate as voting members in NSARC activities at any one. l time.
- Existing Technical Specification 6.4.2.4: This Technical Specification is renumbered to 6.4.3.4. *
- Existing Technical Specification 6.4.2.5: The words "at least once per calendar quarter during :
the initial year of unit operation following fuel loading and thereafter" are deleted. This !
requirement is irrelevant since the initial year following fuel loading has passed.
Existing Technical Specification 6.4.2.6: This Technical Specification is renumbere'd to 6.4.3.6. '
Existing Technical Specification 6.4.2.7: This Technical Specification is renumbered to 6.4.3.7.
- Existing Technical Specification 6.4.2. 8: This Technical Specification is renumbered to 6.4.3.8. ';
Existing Technical Specification 6.4.2.9 is renumbered to 6.4.3.9, and "14" in 6.4.3.9a and 6.4.3.9c is changed to "30".
The following paragraphs were added to Technical Specification 6.7 as part of the Station -
Qualified Reviewer proposal:
- A 6.7.2 The Station Manager may designate specific programs and procedures to be reviewed in accordance with the Station Qualified Reviewer Program in lieu of review ;
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uy the SORC. The review per the Qualified Reviewer Progran shall be in accordance with Specification 6.4.2.
6.7.3 Programs and procedures listed in Specification 6.7.1, and changes thereto, shall be approved by the Station Manager or by cognizant Manager.or Directors who are ,
designated as the Approval Authority by' the Station Manager, as specified in administrative procedures. The Approval Authority for each program and procedure shall be specified in administrative procedures. ;
- Existing Technical Specification 6.7.2 was renumbered to 6.7.4, and the following statement was added after " ..shall be approved by the Station Manager":
"or be reviewed and approved in accordance with the Station Qualified Reviewer Program" in addition, the following words were deleted, "..and reviewed periodically' as set forth in !
administrative procedures".
- Existing Technical Specification 6.7.3 was renumbered to 6.7.5. The statement " Temporary-changes to procedures of Specification 6.7.1 may be made provided." was changed to -
" Changes to procedures of Specification 6.7.1 may be made prior to SORC review provided:"
- Existing Technical Specification 6.7.3b: The words "on the unit affected" are deleted. These .
- words are irrelevant since Seabrook Station is a single unit plant.
- Existing Technical Specification 6.7.3 c: The following words were added after." .. approved by.
the Station Manager.. ", "or reviewed and approved in accordance with the Station Quahfied Reviewer Program".
- Existing Technical Specification 6.7.4: This Technical Specification was renumbered to 6.7.6. _
- Existing Technical Specification 6.7.4f: The asterisk and note stating this specification becomes. i
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effective when the plant goes above 5% power for the first time is deleted. The revision number of Regulatory Guide 1.97 is changed f, .n. Revision 2 to Revision 3 in the first paragraph and ,
in the note at the bottom of the page. The double asterisk for the remaining note is changed to a single asterisk. ,
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- Technical Specification 6.8.1.4: The reference to Technical Specification 3.11.2.6 is deleted..
Technical Specification 3.11.2.6 does not exist.
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Markup of Proposed Channes '
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See attacheo markup of proposed changes to Technical Specifications.
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