ML20115G199

Application for Amend to License NPF-38,consisting of TS Change Request NPF-38-128,revising Administrative Controls Section 6.2.3, Independent Safety Engineering Group for Compatibility W/Current C-E STS (Rev 2 to NUREG-0212)

ML20115G199
Person / Time
Site:	Waterford
Issue date:	10/21/1992
From:	Barkhurst R ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20115G203	List: ML20115G199 ML20115G215
References
RTR-NUREG-0212, RTR-NUREG-212 W3F192-0326, W3F192-326, NUDOCS 9210260054
Download: ML20115G199 (5)

Text

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-QA October 21, 1992 U.S. Nucinar Rer;.:latory Commission Attn: Documer : C t., *rol Desk.

Washington, F.C e10555 Labject: Waterford 3 SES Docket No. 50-382 License No NPF-38 Technical Specification Change Request NPF-38-128 Gentlemen:

Entergy Operations, Incorporated hereby files an application for an a m e n d aie n t t o the Waterfoid 3 Technical Specifications.- The i proposed change revises the Administrative Controls Section 6.2.3

" Independent Safety Engineering Group (ISEG)". The proposed change is compatible with the current Combustion Engineering. (CE) Standard.

Technical Specifications (STS) NUREG-0212 Revision 2 and is-therefore submitted for processing as a plant specific amendment, i

Questicas or comments concerning this proposal may-be directed to Paul Caropino'at (504) 739-6692.

Very truly-yours, h

R.P. Barkhurst L

Vice President, Operations

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Attachment:

Affidavit L NPF-38-128 l

cc: J.L. Milhoan (NRC Region IV)

D.L. Figginten (NRC-NRR)

R.B. McGehee N.S. Reynolds NRC Resident Inspectors Office-l- Administrator Radiation ~ Protection Division (State of Louisiana) f- American Nuclear Insurers

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• UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Entergy Operations, Incorporated ) Docket No. 50-382 Waterford 3 Steam Electric Station )

AFFIDAVIT R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3.of Entergy Operations, Incorporated; that he is duly authorized tc sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-128 ; that he is familiar with the content thereof; and that the matters set forth therein are true and-correct to the best of his knowledge, information and belief.

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s R P . Barkhurst Vice President Cperations - Waterford 3 STATE OF LOUISIANA )

) ss PARISH OF ST. CHARLES )

l Subscribed and sworn to before me, a Notary Public in and for the Parj sh and State above named this P i $_ day of l t. '< tor?A , 1992.

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Y s. S / ks Notary Public l

My Commission expires w r" c/ed ,.

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DESCRIPTION AND SAFETY ANALYSIS OF DROPOSED CHANGE NPF-38-128 This proposal requests a chango to the Administrative Controls Section 6.2.3 of the Waterford 3 Technical _ Specifications.

Existina Soecification See Attachment A Pronosed Soecifications See Attachment B pescriotion This proposed change modifies technical specification 6.2.3

" Independent Safety Engineering Group (ISEG)" to accommodate an organi::ational restructuring. The reorganization is intended to reduce redundancy and increase the effectiveness of independent technical reviews by consolidating assessments, operations experience reviews, and ISEG functions, within the Nuclear Safety Organization. Waterford 3 has established a new group entitled Operational Experience Engineering (OEE), therefore reference to ISEG in the proposed technical specification has been removed. The independent technical review functions prescribed by NUREG-0737 1.B.1.2 vill be performed within OEE. The new organization will be .

accountable for Operating Experience Assessments- (NUREG-0737 1.C.5); Nuclear Operations & Maintenance Information . Service (NOMIS) Network; NRC Information Notices; Individual Plant Examinations and other related inputs. Within .the new group, inputs as described above, will be utilized to key in on plant and industry design and operating experience information which may indicate areas for improving plant safety. The. independent -

technical review function will then encompass evaluation and closure thereby reducing redundancy and allowing for greater independent technical engineering involvement. While this group' may perform other related review activities, at least five full--

time engineers meeting the education and experience requirem6ats, will be dedicated to perform independent-technical reviews. The new group will provide continuing, systematic, independent assessments of plant activities and report to an individual that is not in the management chain fcr power production. As such organizational independence will be- maintained and the criteria of NUREG-0737 1.B.1.2 will continue to be satisfied. A specific description of each change is provided below.

Section 6.2.3.1 was modified to remove reference to ISEG and the

last sentence appearing in our current technical specification was incorporated under section 6.2.3.4 AUTHORITY, which is consistent with NUREG 0212.

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Section 6.2.3.2 was modified to remove reference to ISEG. This section was also changed to incorporate an equivalent educational allowance which ir consistent with the exceptions and-endorsements established in the Waterford 3 NRC approved Quali ty - Assurance Program. FSAR Table 17.2.1.2 takes exception to Section 4.7.2 of ANSI 3.1 (qualification requirements for ISEG personnel) and endorses the qualification requirements of NUREG-0731 2.B.2.B, i.e., a bachelors degree in engineering with two or four-years experience in their field, or equivalent as described in Section 4.1 of ANSI 3.1.

Section 6.2.3.3 was modified to remove reference to ISEG.

Section 6.2.3.4 was modified to remove reference to ISEG _ and incorporate authority requirements previously included in 6.2.3.1.

Section 6.2.3.5 was modified to require recommendations for improving unit safety to be forwarded to the Director of Nuclear Safety each calendar month. This change is consistent with the j intent of NUREG-0737 I.B.1.2.

l l Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of'the following aruas:

1. Will operation of the f acility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No l The proposed change has no effect on the assumptiono contained in the safety analyses nor does the propcsed change directly affect any material condition of the plant that could directly contribute to causing or mitigating the affects of an accident. Therefore,_ the proposed change will not involve a significant increase in the probability or consequences of any _

accident previously evaluated.

2. Will operation of the facility in accordance with the proposed change cre6te the possibility of a new or different kind of-

, accident from any accident previously evaluated?

Response: No l The proposed change is administrative in nature. This change will not r'.ter tne operation of the plant or the manner in which it iu operated. No physical modifications will result.

Taerefore, the proposed change will not create the pcssibility of a new or different kind of accident.

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3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No The Waterford-3 safety margins are defined and maintained by the Technical Specifications in Sections 2-5 which are  !

unaffected by the proposed change. The independent safety review criteria as prescribed by NUREG-0737 I . B .1. 2 , will continue to be met. Therefore, the proposed change will not involve any reduction in a safety margin The Commission 1.aa prcvided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazarcs considerations. This proposal most closely resembles example (1) A purely adminirtrative change to technical specifications, (i.e., a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature);

Safety and Sianif..: ant Hazards Determination l-Based on the above safety analysis, it is concluded that: (1) the i proposed change does not constitute a significant hazards

! consideration as defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC final environmental statement.

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