ML20140D191

Proposed Tech Specs,Clarifying Station Review Board Duties & Responsibilities

ML20140D191
Person / Time
Site:	Davis Besse
Issue date:	01/22/1986
From:	TOLEDO EDISON CO.
To:
Shared Package
ML20140D152	List: ML20140D145 ML20140D174 ML20140D191
References
TAC-61468, NUDOCS 8601290207
Download: ML20140D191 (15)

Text

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Attachment i ACF.lNISTRATIVE CONTROLS Page 1 of 10 COMPOSITION 6.5.1.2 The Station Review Board shall e composed of the:

Chairman: Assistant Station Superintendent Member: Operations Engineer Member: Technical Engineer Member: Maintenance Engineer Member: Lead Instrument and Co'ntrol Engineer Member: Nuclear and Performance Engineer Member: Chemist and Health Physicist Nember: Nucisar Italimhility Manager Member: Station Superintendent m

B LINb NOTEt ALTERNATES DEL ET'E 6.5.1.3 All alternate members shall appointed in writing by the SRB Chaima 2 se ~ e en a t ; r: y bari_, however, no more than two alternat hall articipate as voting members in SRB activities at any one time.

MEETING FREOUENCY_

6.5.1.4 The SRB shall meet at least once per calendar month and as convened by the SRS Chairman or his designated alternate.

OUORUM 6.5.1.5 A quorum of the SRS shall consist of the Chainnan or his designated alternate and four members including alternates.

RCPLACSWITH j RESPONSI31LITIES IA/ SERT ~

ug n 6.5.1.6 The Station Review Soard shall be responsible for:

Eeview cf 11 all ;:rocedures required by Specific .3 and c., thereto, 2) any other proposed pr~ res or changes thereto a termined ::y the St auperintendent to affect nuclear safety.

b. Review prop: sed tests experiments that affect i ear safety.

DAVIS-3 ESSE, UNIT 1 6-6 knend.v.ent No.12, 76 e601290207$$$$46 PDR ADOCK PDR P

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Attachment 1 Page 2 of 10

$6%AC6taorH INSERT ADMINf5IRATIVE CONTROLS "A"

/ ~ a 3

Review of all proposed changes to Appendix "A" Technica Specifications,

d. Rev" w of all proposed changes or modifications to p nt syst or equipment that affect nuclear safety.

e. Investigat. of all violations of the Techni- Soecificatient including pre ration and femarding of re: ts c vering evalua-tien and rec:me. aticns t: :revent recur .nce to the Vice President - Nuclea nd to the Chair .an f the C maany 4 Nuclear Review Board. )

f. Review of events requirin 4 he written notification to the Comission.

g. Review of facility operat ns to tect potential safety hazards.

i h. Pere :r ance of sce ' I reviews, investiga ens and analyses and recorts ther n as recuested by the Cha. .an of t.".e Ccm:any Nuclea Review Board,

i. Review of e Plant Security elan and irclementing :cet tes and sha submit rec:rrended changes to the Chair:ran tne Comp Nuclear Review Board.

j. view of the Emergency Plan and implementing procedures and shall submit recemended changes to the Chair =an of the Com ny Nuclear Review Board.

4 h Review of any unplanned, accidental or un' controlled radioactive releases, evaluation of the event, ensurance that remedial action l L is identified to prevent recurrence, ' review of a report y I covering the evaluation and forwarding of the report to the i s

&44e46ee-L;;--int;nnt Plant Manager and to the CNRS.

3 j l

'h Review of the OFFSITE COSE CALCULATION MANUAL and implementation of procacures at least onca per 24 months.

. l h Review of the PROCESS CONTROL PROGRAM and inclementation of W, o procedures for processing and packaging of radioactive wastes at gg least once per 24 months.

$ q) /,

@ Review of the Annual Radiological Environmental Operating ,

Q2 Report, j

/ o. Review of the Semiannual Radicactive Effluent Release Report.

I DAVIS-BESSE, UNIT 1 6-7 Amendment No. 27,85

Attachment 1

, Page 3 of 10 INSERT "A"

a. Plant administrative procedures and changes thereto,

b. The safety evaluations for 1) procedures, 2) changes to procedures, equipment or systems and 3) tests or experiments completed under the provisions of 10 CFR 50.59, to verify that such actions do not constitute an unreviewed safety question. This review will normally take place after items 1), 2) and 3) have been approved in accordance with Section 6.5.3.

c. Proposed procedures and changes to procedures and equipment determined to involve an unreviewed safety question as defined in 10 CFR 50.59.

d. Proposed tests or experiments determined to involve an unreviewed safety question as defined in 10 CFR 50.59.

e. All proposed changes to the Technical Specifications or the Operating License.

f. Reports of violations of codes, regulations, orders, Technical Specifications or Operating License requirements having nuclear safety significance.

g. Reports of significant operating abnormalities or deviations from normal and expected performance of plant equipment that af fect plant safety.

h. The Plant Security Plan and changes thereto,

i. The Emergency Plan and changes thereto.

j. Items which may constitute potential nuclear safety hazards as identified during review of facility operations.

k. Investigations or analyses of special subjects as requested by the Company Nuclear Review Board.

1. All REPORTABLE EVENTS.

m. All Safety Limit Violation Reports (Section 6.7).

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Attachment 1 Page 4 of 10 l ' ADMINISTRATIVE CONTROLS AUTHORITY 6.5.1.7 The Station Review Board shall:

Plant Mana

a. Recomend to the : ;ti;n 0;ger-;;r';;;;d;;t written approval or disapproval of items considered un above. lions 6.5.I. 6 s,c,d,e"h aid i0.5.1.5(;,) th Seefiens &.er.i. 6 a,,e ,4 a / e

b. Render determinations in writing with re not each item considered under . 5.1.S(; gard to whether

'-) or ve constitutes an unreviewed safety question,xtha"IEc[/n ofE /0Cfd 50.59.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President, Nuclear and the Company Nuclear Review Boatd p/s,fA

/ of disagreement between the SRB and the Ots.t';[ ;pf fat;nd;nt; D,f-7dowever,theJ;ti; 0;;;r';t;nd;;0 shall have responsibility

_ for resolution of such disagreements pursuant to 6.1.1 above.

QIsd NdTidd he~e)

RECORDS =- -

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6. 5.1. 8 The Station Review Board shall maintain written minutes of 4ach meeting and copies shall be provided to the Vice President, Nuclear and Chaiman of the Company Nuclear Review Board.

6.5.2 CO'4PANY NUCLEAR REVIEW BOARD,(CNRB)

FUNCTION 6.5.2.1 The Company Nuclear Review Board (CNRS) shall function to provide independent review and audit of designated activities in the 4

areas of:

a. Nuclear power plant operations, I

i b. Nuclear engineering, l

c. Chemistry and radiochemistry,

d. Metallurgy, j e. Instrumentation an control, j f. Radiological safety,

g. Mechanical and electrical engineering, and

h. Quality assurance practices.

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' d. Nake. trakneenda$ ions in tWiling alwe do 10L 1%ur{Nasuy{

a conslil ale hf ac/ims

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• Nviewed tnder Seefim 66.l. b b an untenewed Sdely gkes{tbrt.

! DAVIS-BESSE, UNIT 1 6-8 Amendment No. 27, 86

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. Attachment 1 Page 5 of 10 ADMINISTRATIVE CONTROLS AUTHORITY 6.5.2.9 The Company Nuclear Review Board shall report to and advise the President and Chief Operating Officer on those areas of responsibility specifled in Sections 6.5.2.7 and 6.5.2.8.

RECORDS j 6.5.2.10 Records of' Company Nuclear Review Board activities shall be l prepared, approved and distributed as indicated below:

a. Minutas of each CNRB meeting shall be prepared, approved and forwarded to the President and Chief Coerating Officer and CNRS memoers within 14 days following each meeting.

b. Reoorts of reviews encomcassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the President and Chief Coerating Officer and CNRS meccers within 14 days following completion of the review.

c. Audit recorts encomoassed by Section 6.5.2.8 above, shall be forwarded to the President and Chief Operating Officer and CNRS members and to the management oositiens resconsible for the areas audited within 30 days after comoletion of tne audit.

Abb Section s.6.3 SEE Insur*S"~

t 4.3 7 BL OCCUiWi$[ ACTION

6. 6.1 The following actions shall be taken for REPORTAELE OCCURRENCES:

a .. The Carmission shall be notified and/or a report sub=itted

pursuant to the requirements of Specification 6.g.

b. Each REPORTABLE OCCURRENCE recuiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to the Cornission sna11 be reviewed by the SRB and submittad to the CNR8.

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MIS-3E13E. UNIT 1 6-12 Amendment No. 72. M 86

1 Attachment 1 INSERT "B" Page 6 of 10 6.5.3 TECHNICAL REVIEW AND CONTROL i l

ACTIVITIES 6.5.3.1 Activities which af fect nuclear safety shall be conducted as follows:

a. Plant procedures required by Section 6.8.1 and changes thereto shall be prepared, reviewed and approved. Each such procedure or procedure change shall be reviewed by an individual / group other than the individual / group which prepared the procedure or procedure change, but who may be from the same organization as the individual / group which prepared the procedure or procedure change. Plant procedures other than plant administrative procedures will be approved as delineated in writing by the Plnnt Manager. The Plant Manager will approve plant administra-tive procedures, Security Implementing Plant Procedures and Emergency Implementing Plant Procedures.

b. Temporary approval of changes to plant procedures cited in Section 6.8.1 which clearly do not change the intent of the approved procedures, can be made by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License. For changes to plant procedures, which may involve a change in intent of the approved procedures, the person authorized in Section 6.5.3.la to approve the procedure shall approve the change,

c. Proposed changes or modifications to plant nuclear safety-related structures, systems and components shall be reviewed as designated by the Plant Manager. Each such modification shall be reviewed by an individual / group other than the individual / group which designed the modification, but who may be from the same organization as the individual / group which designed the modifications. Implementation of modific-ations to plant nuclear safety-related structures, systems and components shall be approved by the Plant Manager.

d. Proposed tests and experiments which affect plant nuclear safety and are not addressed in the Safety Analysis Report shall be reviewed by an individual / group other than the individual /

group which prepared the proposed test or experiment and approved by the Plant Manager or designee.

e. Individuals responsible for reviews performed in accordance with Section 6.5.3.1 a, b, c, and d above shall meet or exceed the appropriate qualification requirements of Section 4 of ANSI 18.1, 1971, and be previously designated by the Plant Manager.

Each such review shall include a determination of whether an additional, cross disciplinary, review is necessary. If deemed necessary, such review shall be performed by the review persor.nel of the appropriate discipline.

Attachment 1 Page 7 of 10

f. Each review will include a determination of whether an unreviewed safety question is involved as defined in 10 CFR 50.59.

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- Attachment 1 Page 8 of 10 ADwiMISTRATIVE CONTR0tS 6.7 SartTy (fMIT yIctATton 6.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The facility shall be placed in at least HOT STANCSY within one hour.

b. The Safety Limit violation shall be recorted to the Comission, the Vice President. Nuclear and to the CNRS within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. A Safety Limit Violatica Recort shall be prepared. The recort shall be reviewed by the SRB. This racert sna11 describe (1) applicable circumstances preceding the violation. (2) effects of the violation upon facility comocnents, systems or structures, and -(3) corrective action taken to prevent recurrence.

d. The Safety Limit Violation Recort shall be submitted to the Corrission, the CNR! and the Vice President, Nuclear within 14 days of the violation.

5.! 88.00E0t'*E*

6.3.1 Writte'n procedures shall be established, icolemented and main-tained covering tne activities referenced below:

a. The applicable procedures reccmended in Appendix "A" of Regulatory Guide 1.33 Novemer,1972.

b. Refueling operations.

c. Surveillance and test activities of safety related equipment.

d. Security Plan implementation.

e. Emergency Plan implementation.

f. Fire Protection Program implementation.

g. The radiological environmental monitoring program. i

h. The Process Control Program. '

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1. Offsite Oose Calculation ttanual implementation. "c" 6j 8. tach-pmcedgre of 6

,. rev ewe.d by the SF3h.8.1mve44. above, and changes thereto

" 'taaiefHhm r ncendent prior i er adical y a t-fe pfJOx J CAVIS-BESSE, UNIT 1 6-13 Amendment No. 7, 72, 27,86

Attachment 1

, Page 9 of 10 INSERT "C" 6.8.2 Each procedure of 6.8.1 above, and changes thereto, shall be reviewed and approved prior to implementation as set forth in 6.5.3 above.

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Attachment 1 Page 10 of 10 DEL E TE ADMINie RATIVE CONTROLS

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h a.i..: .. orary changes to procedures of 6.8.1 above may be made

( ' previoed:

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a. The intent of . riginal procedure is altered.

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b. The change is approved by ers of the plant management

[ staff, at least one om holds ior Reactar Operator's

( License on the affected.

c. T ange is documented, reviewed by the SRS and app y the Station Superintendent within 14 days of implementa 6.8.4 The fo low ng pro, ams shall be established, impiemented, and maintained:

a. Primary Coolant Sources Outside Containment ,

A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include makeup, letdown, seal injection, seal return, low pressurt injection, containant spray, high pressure injection, waste gas, primary sagling and reactor coolant drain systems. The program shall include j

the following: i (1) Preven'tive maintenance and/or periodic visual inspection requirements, and (11) Integrated leak test requirements for each system at refueling cycle intervals or less, N[

b. In-Plant Radiation Monitoring A pmgram which will ensure the capability to accurately deter-mine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

(1) , Training of personcel, ,

(ii) Procedures for monitoring, and (iii) Provisions for maintenance of sampling and analysis eouip-ment.

deh DAVIS-BESSE, UNIT 1 6-14 Mendment No.)fM 51 l

Attachment 2 l -

Page 1 of 3 i

FCR 85-329 Safety Evaluation This Operating License Amendment is being requested to revise and clarify the Station Review Board (SRB) duties and responsibilities. The safety function of the SRB is to advise the Plant Manager on all matters relating to nuclear safety. In performing these duties, the SRB has responsibilities for reviews as outlined in Section 6.5.1.6.

The SRB currently reviews not only the nuclear safety aspect of the reviews but also the technical content of each procedure, modification, test or experiment. The proposed change to Section 6.5.1.6 would require the SRB to review the safety related (i.e., Safety Evaluation) aspect, instead of the technical aspect, of proposed procedures, modifications, tests or experiments in cases where an unreviewed safety question does not exist. This review would normally take place following completion of a technical review. If an unreviewed safety question is determined to exist, the SRB will perform a technical as well as a safety review. This change in responsibilities must be considered in conjunction with the addition of the technical review and control activities of proposed Section 6.5.3. The addition of Section 6.5.3 (Technical Review and i Control) provides for technical reviews and is addressed below.

> Changing these SRB responsibilities and Technical Review and Control

, technical specifications will provide for a total comprehensive technical i and safety related review with resources prudently allocated to areas of prime safety concern. Other changes to Section 6.5.1.6 " Responsibilities" are administrative in nature in that the revisions clarify the responsibilities and extent of the responsibilities of the SRB.

The addition of Section 6.5.3 Technical Review and Control, in conjunction with the changes to Section 6.5.1.6, delineates the technical review process for activities which affect the nuclear safety

, of Davis-Besse. Individuals responsible for performing reviews in accordance with 6.5.3.1 a through 6.5.3.1 e will be designated by the Plant Manager. These individuals shall meet or exceed the appropriate qualification requirements of Section 4 of ANSI 18.1, 1971. Each review l (which includes 10 CFR 50.59) under this section (6.5.3) will be reviewed

by an individual / group other than the individual / group who initiated the review, but who may be from the same organization as the individual /

l group which prepared the review. This technical review allows for an I indepth, cross-discipline and unbiased review. This allows the SRB to

address the safety related aspect of the review without also being

! required to perform a detailed technical evaluation.

Temporary approval to procedures which do not change the intent of the I approved procedure, can be made by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator License. For temporary changes which may change the intent of the approved procedure, the Plant Manager's, or authorized designee's, approval is required. This will ensure proper review of any temporary procedure change.

in Section 6.5.1.3, Alternate,"to serve on a temporary basis" is deleted as it is an undefined term. The proposed changes to 6.5.1.7, Authority, outline the recommendations and determination that the SRB is required to perform. These changes reflect the revised responsibilities in Stetion

, Attachment 2 Page 2 of 3 6.5.1.6 and is consistent with proposed changes. Section 6.8.2 is revised to reflect the addition of Section 6.5.3. Section 6.8.3 is deleted as Section 6.5.3 incorporates these requirements with the exception of Section 6.8.3 c. The requirement of Section 6.8.3 e is deleted because a similar requirement will exist in administrative procedures. It is not considered necessary that this requirement be repeated here in the Technical Specifications.

Implementing these changes would not:

1. Increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report (10 CFR 50.59(2)(1)) .

The proposed change in the SRB responsibilities provide for the SRB to review the safety aspect of procedures, modifications, tests or experiments and unreviewed safety questions. The SRB will not be required to review the technical aspect, unless it concerns an unreviewed safety question. The addition of Section 6.5.3 (Technical Review and Control) is to provide a more indepth and detailed technical review. These changes provide for a complete review of any proposed procedure, modification, test or experiment thereby assuring the matters relating to nuclear safety receive appropriate technical and safety review. The other changes are administrative in nature to provide consistency within the Technical Specific-ations.

These changes do not increase the probability of occur-rence or consequence of an accident or malfunction of equipment previously evaluated, but provides for a more detailed evaluation and review thereby providing for a increase in overall plant safety.

2) Create the possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report (10 CFR 50.59(2)(11)) .

The proposed revision to the SRB Responsibilities.

Technical Review and Control and other administrative changes (for consistency) provide for an indepth technical and safety review and does not create the probability of an accident or malfunctior, of a different type than previously evaluated.

3) Reduce the margin of safety as defined in the basis for any Technical Specification (10 CFR 50.59(2)(111)).

The margin of safety is not reduced by this change because of the detailed technical and safety review and the administrative changes.

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Attachment 2 Page 3 of 3 These changes to Section 6. Administrative, are provided to enhance the safety related and technical reviews at Davis-Besse. Therefore, based on

-the above this is not an unreviewed safety question. It should be noted that these changes are similar to NRC approved Technical Specifications for other nuclear power plants.

i Attachment 3 Page 1 of 2 Significant Hazards Consideration This amendment request revises Sections 6.5.1.3, 6.5.1.6 a-j, 6.5.1.7 a-d.

6.5.3, 6.8.2 and 6.8.3 of the Technical Specifications. Section 6.5.1.3 designates that Station Review Board (SRB) alternate members are "... to serve on a temporary basic..." This phrase is being deleted because it is an undefined term.

Section 6.5.1.6 delineates the responsibilities of the SRB. The proposed change to Section 6.5.1.6 would require the SRB to review only the safety related (i.e. Safety Evaluation) aspect, instead of both the technical and safety related aspects, of proposed procedures. modifications, tests or experiments in cases where an unreviewed safety question does not exist. In cases where an unreviewed safety question does exist, the SRB will perform both a technical and a safety review.

The addition of new Section 6.5.3 delineates the requirements for the technical review process. The changes proposed in Sections 6.5.1.6 and 6.5.3 will continue to provide a total comprehensive technical and safety related review.

The remaining proposed changes in Sections 6.5.1.7 a-d, 6.8.2 and 6.8.3 provide consistency to the Technical Specifications as a result of the proposed changes in Sections 6.5.1.3, 6.5.1.6 and 6.5.3. Additionally, these changes reficct title changes already in effect at Davis-Besse as a result of recent corporate reorganization.

The granting of the request would not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated (10 CFR 50.92(c)(1)).

This amendment request reassigns a portion of the technical reviews previously done by the SRB, but only for cases where an unreviewed safety question does not exist. The change will provide more tine for the SRB to concentrate on the safety related aspect of their required reviews. This amendment request does not increase the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident previously evaluated (10 CFR 50.92(c)(2)).

All accidents are still bounded by previous analysis and no new accidents are involved.

3) Involve a significant reduction in a margin of safety (10 CFR 50.92(c) (3)) .

This auendment request rennsigns a portion of the technical reviews previously done by the SRB, but only for cases where an unreviewed safety question does not exist. This change will provide more time for the SRB to concentrate on the safety related aspect of their

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l Attachment 3

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Page 2 of 2 required reviews. Therefore, the margins of safety previously assumed remain unchanged.

On the basis of the above, Toledo Edison has determined that the amendment request does not involve a significant hazard.

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