ML20072F187

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Safety Evaluation Supporting Amend 65 to License NPF-58
ML20072F187
Person / Time
Site: Perry FirstEnergy icon.png
Issue date: 08/14/1994
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20072F172 List:
References
NUDOCS 9408230240
Download: ML20072F187 (4)


Text

@ CEQu y-t UNITED STATES j

j NUCLEAR REGULATORY COMMISSION c

WASHINGTON, D.C. 205S5-0001

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SAFETY EVALVATION BY THE OFFICE OF NVCLEAR REACTOR REGVLATION RELATED TO AMENDMENT NO. 65 TO FACILITY OPERATING LICENSE NO. NPF-58 THE CLEVELAND ELECTRIC ILLVMINATING COMPANY. ET AL.

PERRY NVCLEAR POWER PLANT. UNIT NO. 1 DOCKET NO. 50-440

1.0 INTRODUCTION

By letter dated June 25, 1993, Cleveland Electric Illuminating Company proposed an amendment to Facility Operating License No. NPF-58 for the Perry Nuclear Power Plant, Unit No. 1.

The amendment revises the Plant Operation Review Committee (PORC) composition and quorum description.

The amendment changes the term " designated alternate" to " designee," " General Manager Perry Nuclear Power Plant Department" to the " Plant Manger," and " Director Perry Nuclear Engineering Department" to the " Engineering Department Head."

In addition, the amendment changes the titles " Perry Training Section Manager" to the " Training Section Head" and "Section managers" to "Section heads."

Finally, the amendment removes the requirement to have NSRC meetings "at least' once per calendar quarter during the initial year of unit operation following fuel loading and...thereafter."

2.0 EVALVATION 2.1 Plant Operation Review Committee (PORC) composition and auorum The proposed changes revise the PORC composition and quorum.

The composition of the PORC was designated in Section 6.5.1.2 and is given below:

6.5.1.2 The PORC shall be composed of the:

Chairman:

Director, Perry Nuclear Engineering Department Vice-Chairman / Member: Manager, Perry Operations Section Member:

Manager, Systems Engineering Section Member:

Manager, Perry Maintenance Section Member:

Reactor Engineer Member:

Manager, Radiation Protection Section Member:

Plant Health Physicist Member:

Licensing and Compliance Section The proposed new section would read:

9408230240 940817 ADDCK 0500044U PDR p

PDR-6.5.1.2 The Plant Operation 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.

The major change is the revision of the number of PORC members from nine to "at least six but no more than eleven." The reduction in the minimum results from combining the Radiation Protection / Health Physics discipline, removing the Licensing and Compliance Section Manager, and eliminating the Chairman as a separate person in the listing. Although the Licensing and Compliance Section Manager is no longer specifically mentioned, it could be retained by the Plant Manager.

The allowance of a larger size of the PORC provides opportunities to extend the cross discipline review.

The purpose of the PORC is contained in 10 CFR 50.36(c)(5) " Administrative Control." The administrative controls are provisions relating to organization and management to review and audit ensuring safe operation of the plant.

Guidance for administrative control is provided by ANSI N18.7-1976/ANS-3.2,

" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," endorsed by Regulatory Guide 1.33.

These documents provide guidance to the review activities during plant operation.

The Standard Review Plan (NUREG-0800) Section 13.4 " Operational Review" sets the acceptance criteria for the Plant Review:

a.

Scope of this review should include that of Section 4.4 of ANSI N18.7/ANS 3.2 as endorsed by Regulatory Guide 1.33.

b.

Organizational arrangements should provide for interdisciplinary reviews of subject matter, c.

Qualification levels for plant staff personnel performing review should be at least equivalent to those described in Section 4.4 of ANSI N18.1 as endorsed by Regulatory Guide 1.8.

d.

Review activities should be documented and results forwarded to appropriate members of management.

The changes do not affect items a, c, and d.

With respect to b, the changes still allow the objective to be reached (interdisciplinary review), however, the licensee has more flexibility available to accomplish the matter.

The added requirement that the members be section heads or above, provides the assurance that the members remain senior members of management.

The addition of the reference to TS 6.3.1 ensures the members meet or exceed the 4

qualifications of Regulatory Guide 1.8, " Personnel Selection and Training" and applicable industry standard ANSI N18.1.

The qualification requirements of j

the personnel supported by the above documents are listed in the USAR J

Section 13.1.

j The licensee's proposal changes the quorum from "... consist of the Chairman or his designated alternate and at least four members including alternates" to

)

" consist of a majority of the members. The Chairman (or his designee) and voting alternate members may be utilized to meet the quorum requirement." The new statement would require at least four members be present (assuming a minimum PORC committee of six) and since the chairman is now a member of the committee; the basic requirements have not been changed by the new statement.

Based on the above discussion, the staff finds the changes acceptable.

2.2 Position-Specific Manaaement Titles to Functional Manaaement Titles TS 6.1. 6.2. 6.4. 6.5. and 6.8 The proposed amendment changes the specific titles of " General Manager Perry Nuclear Power Plant Department," " Director Perry Nuclear Engineering Department," " Perry Section Manager," and "Section manager" to " Plant Manager," " Engineering Department Head," " Training Section Head," and "Section head," respectively.

The purpose for the change is to eliminate the need for a Technical Specification amendment each time a specific position or Department /Section title is changed.

This amendment allows for more flexibility in implementing title changes.

The details of the specific position titles for the management titles changed will be located in administrative procedures and the PNPP Updated Safety Analysis Report (USAR).

The changes follow the intent of Generic letter (GL) 88-06 and are within the regulation set forth in 10 CFR 50.36. The regulation states that

" administrative controls are the provisions relating to organization and management...necessary to ensure operation of the facility in a safe manner."

In the USAR, the General Manager, Perry Nuclear Power Plant Department is already referred to as the Plant Manager (USAR 13.1.2.2.1).

In USAR 13.1.2, the section will be appropriately changed to note the Director, Perry Nuclear Engineering Department performs the duty of Engineering Department Head and the Section manager performs the duty of Section head.

The changing of the titles from management to functional does not contradict 10 CFR 50.36.

Replacing the specific position titles with function titles in no way confuses the chain of command to prevent safe operation of the plant.

The proposed changes meet the characteristics identified in Generic Letter 88-06 by the fact that the Technical Specification will continue to include the " general requirements that capture the essential aspects of the organizational

p e.

structure." The specifics will continue to be stated in the administrative procedures and the PNPP USAR.

Based on the above discussion and since the changes are in agreement with the intent of GL 88-06, the staff finds the changes acceptable.

2.3 Editorial Chanaes. TS 6.5 The two editorial changes proposed are changing " designated alternate" to

" designee" and to remove the requirement to have NSRC meetings "at least once per calendar quarter during the initial year of unit operation folladng fuel loading and...thereafter." The first change is to eliminate possible confusion between designated alternate and the alternate PORC and NSRC members.

The second change involves removal of a sentence that described affected meeting frequency only during the first year after initial fuel loading.

The situation no longer applies since the licensee is past the year after initial fuel loading.

These changes, and the correction of a typographical error on page 6-14, are administrative only and present no safety significance; therefore, the staff finds them acceptable.

i

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified of the proposed issuance of the amendment.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

5.0 CONCLUSION

1 The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such-activities will be conducted in compliance with the Commission's replations, and (3) the issuance of this amendment will not be inimical to the cannon defense and security or to the health and safety of the public.

Principai Contributor:

G. Dentel Date: August 14, 1994 Y

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