ML20202D765

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Proposed Tech Spec Changes Replacing Onsite Safety Committee & Orc Membership Lists W/Ref to Areas of Experience in Lieu of Listing Specific Titles & Clarifying Plant Manager Review Responsibilities
ML20202D765
Person / Time
Site: Beaver Valley
Issue date: 07/03/1986
From:
DUQUESNE LIGHT CO.
To:
Shared Package
ML20202D709 List:
References
NUDOCS 8607140211
Download: ML20202D765 (6)


Text

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ATTACHMENT A

Revise our previous Application dated January 15, 1986 as follows:

Remove Pages Insert Pages 6-5 6-5 6-8 6-8 6-12 6-12 l

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B607140211 860630 PDR ADOCK 05000334 P

PDR

7 ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility and Radiation Protection staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the Radiological Control Manager j

who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and the technical advisory engineering representative l

who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design and response analysis of the plant for transients and accidents.

6.4 TRAINING 6.4.1 A retraining and replacement training program for the facility staff shall be maintained under the direction of the Nuclear Training Manager and shall meet or exceed the requirements and recommendations l

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 Emergency Squad shall be maintained under the direction of the Nuclear Training Manager and shall meet or l

I exceed the requirements of Section 27 of the NFPA Code-1975.

6.5 REVIEW AND AUDIT 6.5.1 ONSITE SAFETY COMMITTEE (OSC)

FUNCTION 6.5.1.1 The OSC shall function to advise the Plant Manager on all matters related to nuclear safety and shall provide review capability in the areas of:

a.

nuclear power plant operations b.

radiological safety c.

maintenance d.

nuclear engineering e.

nuclear power plant testing f.

technical advisory engineering g.

chemistry h.

quality control 1.

instrumentation and control 6.5.1.2 The Plant Safety Review Director is the OSC Chairman and shall appoint-all members of the OSC.

The membership shall con.sist l

j of a minimum of one individual from each of the areas designated in 6.5.1.1.

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l OSC members and alternates shall meet or exceed the minimum qualifications of ANSI 18.1-1971 Section 4.4 for comparable positions.

The nuclear power plant operations individual shall meet the qualifications of Section 4.2.3.

BEAVER VALLEY - UNIT 1 6-5 PROPOSED WORDING I

^3 ADMINISTRATIVE CONTROLS COMPOSITION 6.5.2.2 The chairman and all members of the ORC shall be appointed by the Vice President, Nuclear.

The membership shall consist of a minimum of five individuals who collectively possess a broad based level of experience and competence enabling the committee to review and audit those activities designated in 6.5.2.1 above and to recognize when it is necessary to obtain technical advice and counsel.

An individual may possess expertise in more than one speciality area.

The collective competence of the committee will be maintained as changes to the membership are made.

ALTERNATES 6.5.2.3 All alternate members shall be appointed in writing by the ORC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in ORC activities at any one time.

CONSULTANTS 6.5.2.4 Consultants shall be utilized as determined by the ORC Chairman to provide expert advice to the ORC.

BEAVER VALLEY - UNIT 1 6-8 PROPOSED WORDING

~l ADMINISTRATIVE CONTROLS 6.7 SAFETY LIMIT VIOLATION 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 STANDBY within one (1) hour.

b.

The Safety Limit violation shall be reported to the Commission, the Nuclear Operations General Manager and to the ORC within 24 l

hours.

c.

A Safety Limit Violation Report shall be prepared.

The report shall be reviewed by the on-site Safety Committee (OSC).

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 ORC and the Nuclear Operations General Manager I

within 14 days of the violation.

6.8 PROCEDURES 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

a.

The applicable procedures recommended in Appendix "A"

of Regulatory Guide 1.33, November 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.

PROCESS CONTROL PROGRAM implementation.

h.

OFFSITE DOSE CALCULATION MANUAL implementation.

6.8.2 Each procedure and administrative policy of 6.8.1 above and changes of intent

thereto, shall be reviewed by the OSC and all procedure changes approved by the Plant
Manager, predesignated alternate or a

predesignated Manager to whom the Plant Manager has assigned in writing the responsibility for review and approval of specific subjects considered by the committee, as applicable.

BEAVER VALLEY - UNIT 1 6-12 PROPOSED WORDING

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7 ATTACHMENT B Proposed Ter.hnical Specification Change No.106, Revision 1 No Significant Hazard Consideration Description of amendment request: Change Request No. 106, Revision 1 would change the Administrative Controls by removing the OSC and ORC membership lists and providing clarification of Section 6.8.2.

Basis for no significant hazard determination: Based on the criteria for determining whether a significant hazards consideration exists as setforth in 10CFR50.92(c), plant operation in accordance with the proposed amendment would not:

(1) Involve a significant increase in the probability of occurrence or the consequences of an accident previously evaluated because:

These revisions are proposed.to provide clarification of our previous submittal by replacing the OSC and ORC membership lists with reference to are s of experience, such

that, specific titles are not specified. This will allow flexibility in maintaining the required level of OSC and ORC membership experience and competence.

Previous to this, when company organization changes are enacted, many of the membership titles are chinged or deleted and are no longer consistent with the lists in the technical specifications. The proposed changes would eliminate these inconsistencies by requiring that the OSC and ORC memberships are made up of experienced individuals consistent with the list of different responsibility areas in lieu of specific job titles.

This would allow changing individual-members and/or titles without the corresponding time lag required for initiation, review and approval of the applicable technical specification changes.

These changes are consistent with amendments granted to other utilities.

Revision to specification 6.8.2 provides clarification of the Plant Manager review responsibilities to ensure that he is responsible for approving all procedure changes. Therefore, those changes will not affect the probability of occurrence or the consequences of an accident previously evaluated since they provide clarification and are administrative and not technical in nature.

(2) Create the possibility of a new or different kind of accident from any accident previously evaluated because: No change in plant operations or to equipment or components is required.

The changes are administrative in nature and do not affect the safe operation of the plant. Therefore, these changes will not create the possibility of a new or different kind of accident from those described in the Safety Analysis Report.

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(1) Involve a significant reduction in the margin of safety because: The changes are administrative in nature, do not affect the bases for any technical specification and will not affect the safe operation of the plant.

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Attachment B Page 2 Conclusion The proposed changes do not involve a significant increase in the probability or consequences of a previously evaluated accident, do not create the possibility of a new or different kind of accident and do not involve a significant reduction in a margin of safety.

In addition, the changes will more closely align the OSC and ORC membership requirements with the ANSI 18.1-1971 and ANSI 18.7-1972 standards to which the plant is committed.

Flexibility in maintaining OSC and ORC membership competence and experience can then be achieved without the need to maintain the membership lists in the technical specifications.

This is consistent with amendments granted to other utilities.

Therefore, based on the above, it is proposed to characterize 'the change as involving no significant hazards consideration.

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