ML20093J213
| ML20093J213 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/17/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20093J216 | List: |
| References | |
| NUDOCS 9510230152 | |
| Download: ML20093J213 (5) | |
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ADMIN [S.TRATIVE CONTROLS LjL3 DELETED.
The information from this section is located in the UFSAR.
6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to Shift Supervision in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to safe operation of the unit. The Shift Technical Advisor shall meet the qualifications specified by the 1985 NRC Policy Statement on Engineering Expertise on Shift.
6.3 UNIT STAFF OUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of s
ANSI /ANS 3.1-1978 for comparable positions, except for the Manager - Radiation Protection who l 4
shall meet or exceed the cualifications of Regulatory Guide 1.8, September 1975, and the' licensed operators who shall comply with the requirements of 10CFR55<
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9510230152 951017 PDR ADOCK 05000352 P
PDR Amendment No.70,77,JJ, H. 16 LIMERICK - UNIT 1 6-6 Corrected by Letter dated October 17, 1995 t..
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ADMINISTRATIVE CONTROLS t-l 6.4 TRAINING 6.4.1 Training programs for the unit staff shall be maintained under the i
direction of the site training organization. The retraining and replacement training programs for all affected positions except licensed operators shall meet or exceed the standards of ANSI /ANS 3.1-1978. The retraining and replacement training programs for licensed operators shall comply with the requirements of 10 CFR 55, and shall include familiarization with relevant industry operational experience.
6.5 REVIEW AND AUDIT 6.5.1 PLANT OPERATIONS REVIEW COMITTEE (PORC) i FUNCTION 6.5.1.1 The PORC shall function to advise the Plant Manager on all matters related to nuclear safety.
l COMPOSITION 6.5.1.2 The Plant Operations Review Committee is composed of nine regular members from the Limerick Generating Station staff.
Members shall collectively have experiencelin the following areas:
l Plant Operations
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Engineering 1
Maintenance
-Instrumentation and Controls Planning Radiation Safety Chemistry Experience Assessment Members shall meet the requirements of ANSI /ANS 3.1-1978, Section 4.7, for the applicable required experience and be appointed in writing by the Plant Manager.
The Chairman and alternate Chairman of the PORC shall be drawn from the PORC members and appointed in writing by the Plant Manager.
ALTERNATES 6.5.1.3 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 FRE00ENCY 6.5.1.4 The PORC shall meet at least once per calendar month and as convened by the PORC Chairman or his designated alternate.
000 RUM 6.5.1.5 The quorum of the PORC necessary for the performance of the PORC responsibility and authority provisions of these Technical Specifications shall consist of the Chairman or his designated alternate and four members including alternates.
Amendment No. 10,33,55,96
$$0j7bygterdated LIMERICK - UNIT 1 6-7
i EDMINISTRATIVE CONTROLS 5JLJ DELETED. The information from this section is located in the UFSAR.
I 6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall provide advisory technical support to Shift Supervision in the areas of thermal hydraulics, reactor engineering, and plant analysis eith regard to safe operation of the unit.
The Shift Technical Advisor shall meet the e
qualifications specified by the 1985 NRC Policy Statement on Engineering Expertise on Shift.
6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for comparable positions, except for the Manager - Radiation Protection who l shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and the licensed operators who shall comply with the requirements of 10CFR55.
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J Amendment No. 2, 20, 29, 60 1.lMERICK - UNIT 2 6-6 Corrected by Letter dated October 17, 1995
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3.3 TS Chance Raouest 94-51-0 i
PEco proposes to delete TS Section 6.2.3, and to relocate the independent technical review program in UFSAR Section 17.2.1.2.3.2.
In relocating the independent technical review functions to the UFSAR, PEco is eliminating the 4
ISEG composition requirement while maintaining the independent technical review function by establishing an independent technical review program.
In UFSAR Section 17.2.1.2.3.2, PEco has revised this TS requirement to delete the requirement of at least five dedicated, full time engineers,.and has i
integrated this function into the Nuclear Quality Division.
In' addition, this function is being retitled the Independent Technical Review Program.
PEco will utilize several on-site personnel who are independent of the plant j
management chain to perform this function.
The staff finds that the revised Independent Technical Review Program provisions meet the appropriate acceptance criteria of Section 13.4 of NUREG i
0800, and will be under the control of the provisions of 10 CFR 50.54(a)(3) which is applicable to Section 17.2 of the UFSAR. Therefore,thestafffindsi the deletion of this requirement from the TS and its relocation in UFSAR Section 17.2.1.2.3.2 (as described in PEco's April 6, 1995, letter) acceptable.
3.4 TS Chance Reauest 94-52-0 & TS Chance Reauest 94-53-0 PEco proposes to delete TS Section 6.5.2.7, NRB review responsibilities, and TS Section 6.5.2.8, NRB audit responsibilities.
PECo states that NRB review, audit, and assessment details are addressed in UFSAR Chapter 17, Section 17.2.1.2.5.
These specific requirements, which are being relocated from the TS to the UFSAR, are not required to be in the TS under 10 CFR 50.36 or 5182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal. situation or event giving rise to an immediate threat to the public health and safety.
Further, they do not fall within any of the four criteria set forth in the Commission's Final Policy Statement, discussed above.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.54(a) to address future changes to these requirements. Accordingly, the staff has concluded that these requirements may be relocated from the TS to the licensee's UFSAR.
The relocated requirements are subject to the provisions of 10 CFR 50.54(a)(3). Therefore, the staff firds the deletion of this requirement from the TS and its relocation to UFSAR Chapter 17 acceptable.
l corrected by Letter dated October 17, 1995
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3.5 OAPO Chanaes 4
PECo proposes to delete reference in the QAPD to the ISEG and will reference the new Independent Technical Review Program in Sections 17.,2.1.2.3.1 and 17.2.2.16.. Additionally, responsibility for the Independent Technical Review Program is assigned to the Quality Division Manager.
PEco also proposes to delete UFSAR Section 17.2.1.2.3.2 which describes the location of the ISEG in l I
the UFSAR.
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In addition, PECo has revised the Nuclear Quality Assurance Organization l
Chart,-Figure 17.2-4, by deleting the ISEG organization. The new Independent L
Technical Review Program will be the responsibility of the Quality Division i
Manager.
' As noted above (3.3), the restructuring of the ISEG function to the l
i Independent Technical Review Program is acceptable. The Independent Technical i
Review Program is subject to the provisions of 10 CFR 50.54(a)(3). Therefore j
the deletion of UFSAR Section 17.2.1.2.3.2 anditsrelocationinUFSARChapted, 17, as described in PEco's April 6,1995, letter, is acceptable.
3 PEco is also proposing in UFSAR Chapter 17, Section 17.2.1.2.5, to change the term ndit to assessment, and that the assessment program is as described in 1
l UFSAR Section 17.2.18, " Audits." Further, PECo proposes to increase the audit / assessment frequency to 24 months for: (1) conformance of unit operation 4
I to provisions contained within the TS and applicable License Conditions, (2) performance, training, and qualifications of the operating staff, (3) results of actions taken to correct deficiencies occurring in unit equipment, structures, systems, or a method of operation that affect nuclear safety, (4) radiological environmental monitoring program and the results thereof, and (5) performance of activities required by the Quality Assurance Program to meet the criteria of RG 4.15, " Quality Assurance for Radiological Monitoring Programs (Normal Operations)-Effluent Streams and the Environment," December i
1977.
Also PEco proposes to change UFSAR Section 17.2.18.6, listing specific NRB review and audit details. The staff finds this change acceptable, since the information should remain under the provisions of 10 CFR 50.54(a)(3). This assures NRC notification of any commitment reduction.
Further, the staff notes that the TS and QAPD changes should be implemented simultaneously.
Pursuant to 10 CFR 50.54(a)(3), PEco states that the UFSAR changes will reduce the commitments in its QA Program.
PECO states that these changes in frequency will result in an increase in QA program effectiveness and that for j
such assessment activities to be effective, they should be performed with a frequency commensurate with their safety significance, and with due consideration of performance data.
PECO further states that the reduced frequency can be substantiated by the fact that on-going surveillances are 4
performed during the interval between assessments and that these surveillances are conducted to provide progressive assessments of functional performance.
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corrected by Letter dated 0ctober 17, 1995-
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