ML20135F039
| ML20135F039 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/13/1985 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20135F014 | List: |
| References | |
| LCA-130, TAC-60020, NUDOCS 8509170132 | |
| Download: ML20135F039 (6) | |
Text
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1 PORTLAND GENERAL ELECTRIC COMPANY i
EUGENE WATER & ELECTRIC BOARD l
AND PACIFIC POWER & LICHT COMPANY I.
l Operating License NPF-1 Docket 50-344 License Change Application 130 i
l This License Change Application requests modifications to Technical Specification 6.8, Procedures, of Operating License NPF-1 for the Trojan Nuclear Plant to reflect a more efficient manner for review and approval of Plant procedures.
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l PORTLAND GEHERAL ELECTRIC COMPANY By hY Bart D. Withers Vice President Nuclear Subscribed and sworn to before me this 13th day of September 1985.
Mr Notary Public of Orq(6n My Commission Expires:
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l 8509170132 050913 PDR ADOCK 05000344 p
LCA 130 Page 1 of 5 LICENSE CHANGE APPLICATION 130 As shown in Attachment A Specifications 6.8.2, 6.8.3 and 6.5.1.6 will be changed as follows:
Existina:
"6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed by the PRB and approved by the General Manager prior to implementation and reviewed periodically as set forth in administrative procedures."
"6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:
a.
The intent of the original procedure is not altered, b.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
c.
The change is documented, reviewed by the PRB and approved by the General Manager within 14 days of implementation."
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Proposed:
i "6.8.2 Each procedure and administrative policy of 6.8.1 above, 4
and changes thereto, shall be reviewed and approved prior to implementation and reviewed periodically as set forth in administrative procedures as follows:
For those procedures and administrative policies covering a.
activities performed by the Facility Staff, review and approval shall be by the Plant General Manager; or by (1) the Manager of Operations and Maintenance, or (2) the Manager of Technical Services, (3) the Manager of Plant Services, or (4) the Manager of Plant Modifications.
b.
For those procedures and administrative policies covering activities performed by Company organizations other than the Facility Staff, review and approval shall be in accordance with the Nuclear Quality Assurance Program.
"6.8.3 Temporary changes to procedures of 6.8.1 may be made provided:
s.
The intent of the original procedure is not altered.
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LCA 130 3
Page 2 of 5 b.
For procedures covering activities performed by the Facility Staff, the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected, and documented by the Responsible Manager within thirty (30) days of implementation.
c.
For procedures covering activities performed by Company
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organizations other than the Facility Staff, the change is reviewed and approved in accordance with the Nuclear Quality Assurance Program.
Specification 6.5.1.6 is proposed to be revised as follows:
Original subparagraph "a" should be deleted; all remaining subparagraphs should be redesignated "a" through "1".
REASON FOR CHANGE Section 6.8.2 of the Technical Specifications states that each procedure and administrative policy of Specification 6.8.1, and changes thereto, I
l shall be reviewed by the PRB and approved by the General Manager prior to
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implementation and reviewed periodically as set forth in administrative i
procedures. This specification, as written, requires PRB review and General Manager approval of virtually all Plant-related procedures j
regardless of their safety significance and has resulted in an overload of the PRB and a dilution of the PRB's ability to perform their safety-related activities.
i This License Change Request pcoposes to correct this situation by allow-ing the administrative policies and procedures of Specification 6.8.1 to be established, implemented, and maintained in accordance with the Nuclear Quality Assurance Program without requiring PRB review of the implementing procedures. For completeness, specification 6.8.3 will j
include a statement that temporary changes to procedures of Specifica-tion 6.8.1 may be made provided that, for procedures implementing activities performed by company organizations other than the Facility Staff, the change is reviewed and approved in accordance with the Nuclear Quality Assurance Program.
Allowing procedures to be reviewed and approved in accordance with the Nuclear Quality Assurance Program should enable the PRB and General Manager to provide more thorough reviews of other safety-related l
activities.
The requirement in Specification 6.8.3.c for temporary changes to proca--
dures to.be documented, reviewed by the PRB, and approved by the General i
Manager within fourteen (14) days of implementation is'being changed to l
thirty (30) days and approved by the Responsible Manager to maintain con-l sistency with other Technical Specifications and'further reduce the emphasis to be placed on nonsignificant safety issues.
s LCA 130 Page 3 of 5 SIGNIFICANT HAZARDS CONSIDERATIONS The proposed change deals with administrative controls required for the review of safety-related procedures and changes to safety-related proce-dures. The proposed change would not result in a decrease in the review process but would change the method in which the review would occur. A similar level of review of changes to safety-related procedures would occur after the change. The new review would be performed by and within the department responsible for the procedure which is expected to result in a better evaluation of the change since personnel who are more familiar with the procedure would be reviewing it.
At the same time, the PRB would no longer be involved in the review of items in which certain members are unfamiliar, and would have more time to devote to items of safety significance.
The proposed change is similar to the requirements established for several other nuclear plants. The proposed change is almost identical to the Technical Specifications for procedures for the San Onofre Units 2 and 3, Catawba, and McGuire Nuclear Plants. The proposed change is some-what similar to the Technical Specifications for procedures for the Palo Verde, Grand Gulf, Byron, Calloway, Susequehanna, and LaSalle Nuclear Plants; the intent of the proposed change is the same as the intent of the Technical Specifications for these latter six plants.
As a result, it is determined that this change is administrative and does not:
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated, or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) Involve a significant reduction in a margin of safety.
1 SAFETY / ENVIRONMENTAL EVALUATION I
Summary of Chanze j
This License Change Application proposes to define more clearly the review responsibilities of the PRB, Plant General Manager, other members of Plant l
Management, and offsite Departmental Managers, and to allow credit for the Nuclear Quality Assurance Program.
Effect on Technical Specifications /
Effect on Bases for Technical Specifications The Technical Specifications are affected as described above in the Description of Change and as shown in Attachment A.
The Bases for the Technical Specifications are not affected by this change.
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LCA 130 Page 4 of 5 These changes constitute an improvement to the Technical Specifications since the PRB and General Manager review responsibilities are more clearly delineated. Procedural changes which do not directly affect the Facility Staff should not require their review or approval. A requirement for the PRB to review all changes creates an excessive burden that can reouce the available time for review of issues that may affect nuclear safety. By relying upon the Nuclear Quality Assurance Program, the PRB should have more time'to thoroughly evaluate safety-related issues. The overall.
effectiveness of the review process will be assured by the Department responsible for the procedure (eg, Operations for OIs, GOIs, etc).
i Effect on FSAR FSAR Section 13.4, Review and Audit, discussing the PRB review responsi-1 bilities has already been revised to reflect the changes due to this License Change Application.
Environmental Effect This proposed change will not affect effluent types, amounts or release rates and will not result in any significant impact to the environment.
No changes to the environmental analyses presented in the FSAR, she Environmental Report or the Final Environmental Statement are required.
Effect on Other Licensina Documents. Commitments. or Criteria Other documents, commitments, and criteria reviewed in consideration of this LCA are (1) the NRC Safety Evaluation Report (SER) for the Trojah Nuclear Plant dated October 7, 1974 including Supplement 1 (dated i
November 21, 1975), (2) the NRC Standard Review Plan (NUREG-0800) dated July 1981, (3) NRC Regulatory Guide 1.33 Rev. 2 dated February 1978, and (4) ANSI N18.7-1976/ANS 3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants including Draft 8 (dated April 1981) of a revision to this standard. The change proposed by this LCA is consistent with all of the above documents except for the NRC SER which states in Section 13.2, "The Plant Review Board is advisory to the Plant Superintendent and will review all proposed tests, changes in operating procedures, and design modifications." It is not clear if the SER is referring only to the Operation Instructions (OIs), the General Operation Instructions (GOIs), Off-Normal Instructions (ONIs), and Emer-4 gency Instructions (EIs) or the entire Plant Operation Manual (POM).
In any case, by reviewing the Technical Specifications issued to the plants recently obtaining an Operating License, it is obvious that the NRC posi-tion has changed. The Administrative Controls for San Onofre Units 2 and 3, Catawba, and McGuire Nuclear Plants are almost identical to those pro-posed changes in this LCA, requiring procedures and procedure changes.to be reviewed and approved by any one of several plant' departmental managers or the Station Manager and not the Onsite Review Committee. In addition, the Technical Specification Administrative Controls for Palo Verde, Grand Gulf, Byron,' Calloway, Susequehanna, and LaSalle are somewhat similar in that the 4
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'v LCA 130 Page 5 of 5
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Onsite Review Committee does not have to review all of the safety-related procedures and procedure changes but only certain ones, or a separate group of individuals is established to perfo'em the necessary reviews. Management review is adequate especially since the NOB reviews the safety evaluations for all procedure changes and the Nuclear Quality Assurance Department per-forms periodic audits of this activity.
It is concluded that this LCA would not have an effect on nuclear safety as a result of any other licensing document, commitment, or criteria.
Review and approval of temporary changes to procedures by the Responsible Manager within thirty (30) days is more than adequate. It has proven difficult in practice to have temporary changes documented, reviewed, and approved within the current Technical Specification requirement of 14 days.
Since the temporary changes will already have been reviewed technically by two members of Plant management, this proposed change is purely administra-tive and does not affect safety.
GAZ/3kal 1361G.985
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