ML20084N469
| ML20084N469 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/30/1984 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML20084N470 | List: |
| References | |
| NUDOCS 8405170016 | |
| Download: ML20084N469 (10) | |
Text
-
MAR 301984 ENCLOSURE 1
~
SAFETY EVALUATION PROPOSED AMENDMENT TO CRYSTAL RIVER UNIT 3 TECHNICAL SPECIFICATION DOCKET NO. 50-302 Introduction Florida Power Corporation (FPC), the licensee of the Crystal River Unit 3 Steam Electric Plant, proposed changes to the Operating Licerise (No. OPR-72) in a letter written to this Commission, dated December 13, 1983. The Amendment to License DPR-72 consists of administrative changes to the Technical Specifica-tions.
ADDITION OF HYDRAULIC SNUBBERS Discussion and Evaluation FPC proposed changes to the Technical Specifications, Table 3.7-3, " Safety Related Hydraulic Snubbers," which would add six new s,afety-related hydraulic snubbers to the Table.
The proposed FPC changes to Table 3.7-3, of their Technical Specification will update their current position. The 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 in Table 3.7-3.
Conclusion The proposed change is accepted as submitted and amends Table 3.7-3.
PRESENT CORPORATE ORGANIZATIONAL STRUCTURE Discussion and Evaluation FPC proposed changes to the Administrative Controls, Figure 6.2-1 " Corporate Organization" to indicate the present corporate organizational structure and add a footnote stating that the corporate organization may be changed without prior License Amendment provided that a revision to Figure 6.2-1 is included with the next License Amendment request.
The proposed change is administrative in nature and would allow the licensee to-update Technical Specification 6.2.1 to agree with the current corporate organi-zational structure.
chMg PDR
2 Conclusion The,ification. proposed change is accepted as subm.itted and amends the corresponding spec 3
FACILITY ORGANIZATION Discussion and Evaluation FPC proposed changes to the Administrative Controls, Figure 6.2-2 " Facility Organization" 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.
The proposed changes are administrative in nature and listing departmental responsibilities rather than the positions within each department will help clarify the responsibilities of each group and the interdepartmental relation-ships.
Conclusion The proposed change is accepted as submitted and ameads the corresponding specification.
TRAINING AND PLANT REVIEW COMMITTEE l
Discussion 2nd Evaluation FPC proposed changes to the Administrative Controls as follows:
Technical Specification 6.4, change " Nuclear Plant Training Manager" and
" Nuclear Plant Manager" to " Director, Site Nuclear Operations."
Technical Specification 6.5.1.2, update the Plant Review Committee (PRC) members title to their current titles and add an additional two "At Large" members to the list of PRC members.
The proposed changes are administrative in nature and will update Technical Specification 6.4 and Technical Specification 6.5.1.2 to concur with current management structure and title.
However, the addition of two more PRC members "At Large" could lead to the situation of diluting the intent of the Standard Technical Specifications.
The Standard Technical Specifications defines the minimum quorum to be a chairman and four members including alternates and does not allow any members "At large". We do not agree with this proposed change as stated;however minimum quorum,we will allow the addition of two members "At Larga" provided the stated in the Crystal River Unit 3 Technical Specifications for the PRC is increased by two more members (i.e., a Chairman and Seven Members).
4 yr 9
. ~.
l MAR 301984 3
i Conclusion Based on the reason as stated in the FPC submittals the intent of the change was to increase the number of voting members available for a meeting; therefore, it is determined that the approved Technical Specification should reflect that a chairman and seven members be required for a minimum quorum. The other proposed changes are accepted as submitted and are incorporated into the Techincal Specification.
^ PLANT REVIEW COMMITTEE RESPONSIBILITIES Discussion and Evaluation FPC proposed a change to the Administrative Controls of Technical Specification 6.5.1.6.e by replacing " preparation and forwarding of reports" with " review of reports."
Changing PRC responsibility to review of Technical Specification violations clarifies the role of the PRC in the submittal process concerning Technical Specification violations and should continue to assure that proper evaluations and recommendations concerning these violations are performed. This change does not involve a significant hazard consideration.
Conclusion The proposed change is accepted as submitted and is incorporated into the Technical Specifications.
NUCLEAR GENERAL REVIEW COMMITTEE QUALIFICATIONS Discussion and Evaluation FPC proposed a change to the Administrative Controls, Technical Specification 6.5.2.3 which would add "or the equivalent" after " Bachelor of Science in Engineering or related field "in both parts a and b.
The proposed Nuclear General Review Committee (NGRC) membership qualifications will allow FPC to equate adequate experience to a degre-otherwise highly qualified individuals may be excluded from NGRC membership.
To include these non-degreed individuals, with substantial expertise, in the NGRC can potentially increase the effectiveness and quality of this committee.
This change does not involve a significant hazard consideration.
Conclusion The proposed change is accepted as submitted and is incorporated into the Technical Specifications.
nr
.~
n 4
MAR 301984 NUCLEAR GENERAL REVIEW COMMITTEE, REVIEW. REQUIREMENTS Discussion and Evaluation FPC proposed changes to the Administrative
- Controls, Technical Specification 6.5.2.8 which would update the NGRC review receirements to conccr with ANSI N18.7, 1972 (Administrative Controls for Nuclear Power Plants).
ANSI N18.7,1972 has been endorsed by the NRC in Regulatory Guide 1.33 and FPC has stated compliance to this standard in their FSAR. The NRC Staff recommends that the word " Proposed" be inserted as the first word in Item c.
The NRC Staff has determined that the statement "except in those cases where the change is identical to a previously reviewed proposed change" be deleted from Item C.
The Staff can see no reason for its intended use or why such a statement is required.
In addition, the staff recommends deleting the words " relating to nuclear safety" from Item C.
If the changes involve the Technical Specifications or License Amendments then by definition they are related to nuclear safety therefore the words serve no purpose.
Conclusion With the modifications required by the Staff the submitted administrative change to the specification is accepted and amends the existing specification.
NUCLEAR GENERAL REVIEW COMMITTEE AUDITS Discussion and Evaluation FPC proposed changes to the Administrative
- Controls, Technical Specification 6.5.2.9 which would revise the Emergency Plan, Security Plan and Fire Protection Plan auditing frequency from 24 months to 12 months. This change.
is required by 10 CFR 73.40(d).
Conclusion Tne proposed change is accepted as submitted and is incorporated into the Technical Specifications.
PROCEDURES Discussion and Evaluation FPC proposed changes to the Administrative Controls, Technical Specification 6.8 which would add the heading " Scope" for 6.8.1 and the heading " Review Process" for 6.8.2.
FPC also proposed to add the words " safety related" regarding plant modifications and to delete approval responsibility for the PRC in Technical Specification 6.8.2.a leaving only review responsibility with the PRC and approval of the procedures with the Nuclear plant Manager.
==w-.
e
^
...:. ~..
c MAR 301984 5
The NRC Staff recommends that Technical Specification. 6.8.1.a. be updated to comply with the current QA Plan as stated in the FPC, FSAR under " Florida Power Corporation Quality Program Commitments."
4 The NRC Staff is concerned that the licensee did not provide adequate justification for adding the words " safety related" to Technical Specification 6.8.2.1.a and that important procedures would not receive adequate review due to misinterpretation by the licensee.
l Therefore, the NRC Staff has determined that the following rewording for 6.8.2.1.a would be preferred:
"The Radiological Emergency Response Plan (s), Security Plan, Fire Protection Plan and implementing proccdures, Administrative Instructions, and those test procedures associated with plant modifications for equipment or systems 1
whose operations are governed by the Technical Specifications or licensed conditions shall be reviewed by the PRC and approved by the Nuclear Plant Manager prior to implementation."
These revisions to Technical Specification 6.8 will help to clarify the scope and reviewing process of FPC procedures. This change does not involve a significant hazard consideration.
Conclusion The proposed changes are accepted as modified by the staff and are. incorporated into the Technical Specifications.
MONTHLY OPERATING REPORT Discussion and Evaluation FPC proposed to update Administrative Controls, Technical / Specifications 6.9.1.6 to specify the correct NRC address.
Conclusion i
The proposed change is accepted as submitted and is incorporated into the Technical Specifications.
i-i i
- I a,
y -., - -
,w
,g
~-ro.--+.
g
,r..,
---e-
T 8
Ej Table 3.7-3 ny SAFETY RELATED HYDRAULIC SNUBBERS
- a>
F SNUBBER SYSTEM SNUBBER INSTALLED ON, ACCESSIBLE OR HIGH RADIATION ESPECIALLY DIFFICULT 20 NO.
LOCATION ** AND ELEVATION INACCESSIBLE ZONE ****
TO REMOVE (A orI) a
- o (Yes or No)
(Yes or No)
I
- I@
Post Accident Venting System G
w LRil-59 AB 160'- 10" A
No No i
LRil AB 160'- 10" A
No No LRil-68 AB 161'- 0" A
No No 1.Ril-69 AB 161'- 0" A
No No y
y Additionally, Florida Power Corporation requests that the following snubbers be 4
classified as " inaccessible" instead of " accessible" as is the current case:
m EFH-92 FWH 154 FWH-167 MSH-212 EFH-93 FWH-155 FWH-169 MSH-213 EFH-106 FWH-156 MSH-125 MSH-227 m4
')
U EFH-110 FWH-137 MSH-126 MSH-232 iA I
EFH-144 FWH-158 MSH-205 MSH-240 FWH-149 FWH-162 MSH-206 FWH-153 FWH-166 MSH-207 The following snubbers should be classified as " accessible" snubbers instead of
" inaccessible":
g N
3>
DHH-661 x
DHR-18 g
DHR-31 US O
DHR-37 i
DHR-49 g
)
A j
N l
j
- ~.
... ~
6 pen 30 G84 m
ADMINISTliATIVE' CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Chemistry and Radiation Protection Superintendent who shall meet or exceed l -
the qualifications of Regulatory Guide 1.8, September 1975, and the Operations Technical Advisor, who shall have a Bar.helor's degree, or the equivalent, in a scientific or engineering discipline with specific training in plant design and response and analysis of the plant for transients and accidents.
~
4 6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Director, Site Nuclear Operations and shall l meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55.
6.4.2 A training program for the Fire Brigade shall be maintained under the direction of the Director, Site Nuclear Operations and shall meet or exceed the l requirements of Section 27 of the NFPA Code-1976, except for Fire Brigade training sessions which shall be held at least quarterly.
6.5 REVIEW AND AUDIT 6.5.1 PLANT REVIEW COMMITTEE (PRC)
FUNCTION 4
6.5.1.1 The Plant Review Committee shall function to advise the Nuclear Plant Manager on all matters related to nuclear safety.
_COMPOSITI_ON 3
6.5.1.2 The Plant Review Committee shall be composed of the:
l Chairman: Nuclear Plant Operations Superintendent Member:
Nuclear Maintenance Superintendent kmber:
Nuclear Security and Special Projects Superintendent Men.ber:
Nuclear Compliance Supervisor Member:
Nuclear Chem / Rad Protection Superintendent Member:
Nuclear Plant Engineering Superintendent Member:
Nuclear Safety & Reliability Superintendent Member:
At Large (Designated by Chairman) r:
l At Larre (Desinnated by Chairman) 1 ember:
At Large (Designated by Chairman g
Member:
At Large (Designated by Chairman) g 5, ALTERNATES
~
h 6.5.1.3 All alternate members shall be appointed in writing by-the PRC Chairman to 3
serve on a temporary basis; no more than two alternates shall participate as voting members in PRC activities at any one time.
I MEETING FREOUENCY 6.5.1.4 The PRC snall meet at least once per calendar month and as convened by the PRC Chairman or his designated alternate.
CRYSTAL RIVER - UNIT 3 6-5 l
w
. ~. -
- Enclosure 2 7
MAR 301984 ADMINISTRATIVE CONTROLS QUORUM
~
6.5.1.5 A quor m of the PRC shall consist of the Chairman or his designated alternate.
and av members induding alternates.
RESPONSIBILITIES 6.5.1.6 The Plant Review Committee shall be responsible for:
a.
Review of 1) a!! proceduren and changes thereto as required by Specification 6.1.2, 2) any other presosed procedures or changes thereto as determined by the Nuclear Plant Manager to affect nuclear safety.
i b.
Review of all proposed tests and experiments that affect nudear safety.
c.
Review of all proposed changes to the Appendix "A"
Technical Specifications.
d.
Review of all proposed changes or modifications to p1
- systems or equipment that affect nudear safety.
Investigation of a!! violations of the Technical Specifications including t e.
review of reports covering evaluation and recommendations to prevent recurrence to the Vice President, Nudear Operations and to the Chairman of the Nuclear General Review Committee.
f.
Review of events requirin5 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission.
Review of f acility operations to detect potential nudear safety hazards.
g.
h.
Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman of the Nudear General Review Committee.
i.
Review of the Plant Security Plan and implementing procedures, j.
Review of the Emergency Plan and implementing procedures, i
i CRYSTAL RIVER - UNIT 3 6-6
En:.tesure 2 9
f.iAR 3 0 GS4 ADMINISTRATIVE CONTROLS CONSULTANTS 6.5.2.5 Consultants shall be utilized as determined by the NGRC Chairman to provide.
expert advice to the NGRC.
MEETING FREQUENCY 6.5.2.6 The NGRC shall meet at least once per calendar quarter during the initial year of facility operation following fuel loading and at least once per six months thereafter.
CUORUM 6.5.2.7 A quorum of NGRC shall consist of the Chairman or his designated alternate and five additional NGRC members, including alternates. No more than a minority of the quorum shall have line responsibility for operation of the facility.
REVIEW 6.5.2.3 The NGRC shall review:
Safety evaluations of changes to the facility, changes in procedures,and a.
tests and experiments not described in the Safety Analysis Report,which were completed without prior NRC approval b.
Proposed changes in the facility, changes in procedures or proposed tests or
'frgosnd4xperiments which may involve an unreviewed safety ques
~
- c. pinuclear safety] prior to imolementation fexcept in those cC 0,leh:
ases where g_
nge is ioenucal 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.
e.
Any other matter involving safe operation of the piant 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 witnin Florida Power Corporation.
. f.
Reports and meeting minutes of the Plant Review Committee.
CRYSTAL RIVER - UNIT 3 ro f
I
- ~
ll ADMINISTRATIVE CONTROLS 6.7 SAFETY LIMIT VIOLATION 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:
The facility shall be placed in at least HOT STASDBY within one hour.
a.
b.
The Safety Limit violation shall be reported to the Commission, the Vice President, Nuclear Operations and to the NGRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
A Safety Limit Violation Report shall be prepared. The report shall be c.
reviewed by the PRC.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems or structures and (3) corrective action taken to prevent recurrence.
d.
The Safety Limit Violation Report shall be submitted to the Commission, the NGRC and the Vice President,' Nuclear Operations within 14 days of the violation.
6.3 PROCEDURES 6.8.1 SCOPE Written procedures shall be established, implemented and maintained covering the activities referenced below:
a.
The acelknkla p--a"-a=
Guide (i.33, November,197 recommenced ip Appendix "A" of Regulatory W%
g g
b.
Refueling operations, Cwama? Q (p.e. RenSmn 2,f*b"'*A Surveillance and test activities of safety related equipment.
c.
d.
Security Plan implementation.
Emergency Plan implementation.
e.
f.
Fire Protection Program implementation.
g.
Systems Integrity Program implementation.
h.
lodine Monitoring Program implementation.
6.S.2 REVIEW PROCESS 6.S.2.1 snall be reviewed and approved prior to imolementation as fntl'"
l a.
The Radiological Emergen sponse Plan (s), Security Plan,. Fire
[
Protection Plan and imo nting procecures, Administrative Instructic and those test
, ocedures associated with fety be reviewed by the PRC and a@pprovec ey Ine Nuc
//
1 modifications Plant Manag r prior to implementation.
ef,$ KIN CRYSTAL RIVER - UNIT 3 6-12
~
~-
c v
4