ML20082U904

Application to Amend License DPR-72,Rev 1 to Tech Spec Change Request 103,clarifying Portions of Section 6, Administrative Controls & Modifying Audit Frequencies of Security,Emergency & Fire Protection Plans

ML20082U904
Person / Time
Site:	Crystal River
Issue date:	12/13/1983
From:	FLORIDA POWER CORP.
To:
Shared Package
ML20082U864	List: 3F1283-20, Forwards Application to Amend License DPR-72,changing Tech Specs to Clarify & Update Portions of Section 6, Administrative Controls & Modify Audit Frequencies of Security & Emergency Plans.Certificate of Svc Encl ML20082U904 ML20082U910
References
NUDOCS 8312190215
Download: ML20082U904 (3)

Text

r TECHNICAL SPECIFICATION CHANGE REQUEST NO.103, REVISION 1 TITLE: SECTION 6: ADMINISTRATIVE CONTROLS Replace pages 3/4 7-31a, 3/4 7-34, 6-2, 6-3, 6-3, 6-6, 6-8, 6-9, 6-10, 6-12, 6-12a and 6-15 of Appendix A with the attactied corresponding revised pages.

PROPOSED CHANGES

1) On new page 3/4 7-31a and page 3/4 7-34: Add six new safety-related hydraulic snubbers to Table 3.7-3.

2) On page 6-2: Change Figure 6.2-1 to indicate the present corporate organizational structure and add the following footnote:

"The Corporate Organization may be changed without prior License Amendment to Figure 6.2-1 provided that a revision to Figure 6.2-1 is included with the next License Amendment request."

3) On page 6-3: Revise Figure 6.2-2 to show the general responsibilities of each department rather than every position in each department and add a footnote similar to that added to Figure 6.2-1.

4) On page 6-5: In T.S. 6.4 change " Nuclear Plant Training Manager" and " Nuclear Plant Manager" to " Director, Site Nuclear Operations." In T.S. 6.5.1.2 update the PRC member's title to their current titles. Add an additional two "At Large" members to the list of Plant Review Committee (PRC) members in T.S. 6.5.1.2.

5) Page 6-6: In T.S. 6.5.1.6.e change " preparation and forwarding of reports" to " review of reports".

6) On page 6-8: Add to T.S. 6.5.2.3 "or the equivalent" after " Bachelor of Science in Engineering or related field" in both parts a. and b.

7) On page 6-9: In T.S. 6.5.2.8 change Nuclear General Review Committee (NGRC) review requirements to be:

a. Safety evaluations of changes to the facility, changes in procedures, and tests and experiments not described in the Final Safety Analysis Report, which were completed without prior NRC approval.

b. Proposed changes in the facility, changes in procedures or proposed tests or experiments which may involve an unreviewed safety question.

c. Changes in the Technical Specifications or license amendments relating to nuclear safety prior to implementation, except in those cases where the change is identical to a previously reviewed proposed change.

d. Violations, deviations and reportable events, which require reporting to the Nuclear Regulatory Commission in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This review should include results of investigations and recommendations resulting from such investigations.

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e. Any other matter involving _ safe operation of the plant which an independent reviewer deems appropriate for consideration, or which is referred to the reviewers by members of Nuclear Operations staff or by other functional organizational units within Florida Power Corporation.

'f. Reports and meeting minutes of the Plant Review Committee.

8) On page 6-10: In T.S. 6.5.2.9. under items e, f, and g replace ."24 months".with "12 n onths".

9) On pages 6-12 and 6-12a: Change the organization of T.S. 6.8 so that 6.8.1 has the heading " Scope" and 6.8.2 has the heading " Review Process". Change 6.8.2 to 6.8.2.1, 6.8.2.c to 6.8.2.2, and 6.8.2.d.to 6.8.2.3. Also revise T.S. 6.8.2.a to read:

a. . The Radiological Emergency Response Plan, Security Plan (s), Fire Protection Plan and implementing procedures, Administrative Instructions and thnse test

. procedures associated with safety related plant modifications shall be reviewed by the PRC and approved by the Nuclear Plant Manager prior to implementation.

10)- On page 6-15: update T.S. 6.9.1.6 to specify the correct address:

Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555 REASONS FOR PROPOSED CHANGES By and large, most of the proposed changes to Section 6 of Florida Power Corporation (FPC)

Technical Specification will update or clarify the current FPC position on the affected Specification. A more detailed breakdown of the reasons for the proposed changes follows.

An addition of six more hydraulic snubbers is being made in accordance with Specification 3.7.9.1 which states that snubbers may be added to safety related systems without a prior-License Amendment provided that a revision to Table 3.7-3 is included with the next License Amendment request. LRH-59,60,68 and 69, RCH-530 and 531 were added to safety related systems during Refuel IV and should be included on Table 3.7-3.

The new Figures 6.2-1, Corporate Organization, and 6.2-2, Facility Organization, will update T.S. 6.2.1 and T.S. 6.2.2 to agree with the present organization. Moreover, listing departmental responsibilities on Fig. 6.2-2, rather than the positions within each department, will help clarify the responsibilities of each group and interdepartmental i

relationships. This may also reduce the frequency of changing this organization chart.

The NRC staff has expressed a concern that the current organization is not in concurrence

'with the organization as described in the Technical Specifications. While the staff is not i expressly concerned with the actual mechanics of the organization, it is concerned that a portion of the Technical Specifications is not being followed. To resolve this concern Florida Power proposes the footnote that is very similar to the footnote for Table 3.7-3.

f l.

The transfer of training direction from the Nuclear Plant Manager and Nuclear Plant Training Manager to the Director, Site Nuclear Operations will update T.S. 6.4 to concur with present management structure.

The changes in T.S. 6.5.1.2 reflects PRC members' title revision. The addition of two more "At Large" PRC members will allow FPC to have more voting attendees available for PRC meetings including on-site non-plant areas.

Changing PRC responsibility to review of Technical Specification violations will clarify the PRC's role in the submittal process concerning Technical Specification Violations.

The proposed NGRC membership qualifications in T.S. 6.5.2.3 will allow FPC to equate adequate experience to a degree. By doing this,otherwise highly qualified individuals will not be excluded from NGRC membership.

The proposed change to T.S. 6.5.2.8 will update the NGRC review requirements to concur with Standard Technical Specifications and ANSI N18.7,1972, Administrative Controls and Quality Assurance of Nuclear Power Plants.

The proposed change to T.S. 6.5.2.9. will revise the Emergency Plan, Security Plan and Fire Protection Plan auditing frequency from 24 months to 12 months as required by 10 CFR 73.40(d).

The revision of T.S. 6.8 Procedures will help to clarify the scope and reviewing process of FPC procedures.

SAFETY ANALYSIS OF PROPOSED CHANGES Most of the proposed changes will clarify or update current administrative positions and policies and as such will not degrade plant safety.

Expanding the Plant Review Committee membership to include two additional "At Large" members will permit a wider variety of expertise on the PRC, thus increasing the quality of the review. Assurance of representation from all essential disciplines will be provided via the PRC Charter.

PRC review of Technical Specification violations will continue to assure that proper evaluations and recommendations concerning these violations are performed.

Substantial expertise exists within the corporation with a large number of non-degreed individuals. To include these non-degreed individuals in the NGRC will potentially increase the effectiveness and quality of this committee.

The changes of Emergency Plan, Security Plan and Fire Protection program audits to 12 months is required by 10 CFR 73.40 (d).

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