ML20203A596

Safety Evaluation Accepting Licensee Proposed Revs to Responsibilities of Plant Operations Review Committee as Described in Chapter 17.2 of USAR

ML20203A596
Person / Time
Site:	Perry
Issue date:	02/02/1999
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20203A583	List: ML20203A596
References
NUDOCS 9902100040
Download: ML20203A596 (3)

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' NUCLEAR REGULATORY COMMISSION o ' WASHINGYoN, D.C. 30000 0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE PLANT OPERATIONS REVIEW COMMITTEE FIRSTENERGY NUCLEAR OPERATING COMPANY PERR'( NUCLEAR POWER PLANT DOCKET NO. 50-440 1.0 ~ INTRODUCTION By letter dated December 3,1998, FirstEnergy Nuclear Operating Company, the licensee, proposed modifications to the responsibilities of the Plant Operations Review Committee

- (PORC) as described in Chapter 13 and Chapter 17 of the Updated Safety Analysis Report for a; the Perry Nuclear Power Plant. These changes constitute a reduction to previous commitments and were submitted pursuant to 10 CFR 50.54(a)(3).

2.0 EVALUATION 2.1 : Function of the Plant Operations Review Committee Pursuant to Criterion I, Appendix B,10 CFR Part 50, Perry must clearly establish and delineate in writing the authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components. Also, pursuant to the American National Standards institute (ANSI) Standard N18.7-1976, Section 3.4.2 as endorsed by Regulatory Guide 1.33, the Plant Manager must have the overall responsibility for the execution of the administrative controls and quality assurance program at the plant to assure safety. Perry proposes to revise their Updated Safety Analysis Report to reflect the PORC's functions and actual responsibilities with respect to the oversight associated with the preparation, review, and approval process of Plant Administrative Procedures and Instructions.

Specifically, the PORC will no longer recommend or designate, in writing, the organizations

. responsible for preparing, reviewing, and approving the various procedures, instructions, tests, and experiments.

Pony Plant Administrative Procedure, " Preparation, Review, and Approval of Procedures,"

designates the organizations responsible for preparing, reviewing, and approving the various procedures.' Furthermore, Perry Technical Specification 5.1.1 requires the Plant Manager to approve all Plant Administrative Procedures. Therefore, the staff concludes that Perry is in agreement with Criterion I, Appendix B,10 CFR Part 50 and ANSI N18.7-1976, Section 3.4.2 as endorsed by Regulatory Guide 1.33.

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. .4 2.2 - Administrative Procedures Perry proposes that the PORC review only selective administrative procedures. The list of selected administrative procedures includes (1) major plant processes that have potential plant safety significance, and (2) vital plant complianco programs. Perry states that all administrative procedures will be reviewed by a qualified individual, in section 17.2.5.2 of Perry's Updated Safety /ualysis Report, the qualified individual is described as meeting or exceeding the appropriate qualifications of ANSI Standard N18.1-1971. Also, each procedure is reviewed by a qualified individual other than the individual who prepared the procedure, but who may be from the same section as the individual who prepared the procedure. The staff concludes that Perry is in agreement with ANSI N18.7-1976, Section 4.4 as endorsed by Regulatory Guide 1.8.

2.3 Technical Soecification Chanaes Chapter 17.2.1.3.4.1.b of the Perry Updated Safety Analysis Report currently requires that the PORC will review all proposed changes to the plant Operating License, including changes to the Technical Specifications (TS). In addition, the USAR states that the PORC will also review the safety evaluations supporting license amendment changes, submitted pursuant to 10 CFR 50.90, for the presence of an unreviewed safety question. The licensee has proposed to eliminate this latter requirement for the PORC.

10 CFR 50.59(a)(1) requires prior NRC review and approval for changes in the TS and for proposed changes, tests, or experiments that involve an unreviewed safety question. The unreviewed safety question determination is only made to provide the basis that a change does or does not require prior approval by the NRC, Since paragraph 50.59(a)(1) states that changes to the TS already require prior NRC approval, a separate PORC review of safety evaluations supporting TS changes simply to determine whether an unreviewed safety question exists (and thereby requiring NRC review and approval) is duplicative and unnecessary.

The staff finds this proposed revision acceptable because all unreviewed safety questions and changes to the Operating License, including all TS changes, are currently submitted to the NRC for review and approval prior to implementation pursuant to 10 CFR 50.59 and 50.90.

2.4 Emaraency and Security Plans Perry proposes to relocate the requirement for the PORC to review changes to the Emergency Plan and Security Plan. The requirement for the PORC to review changes to the Emergency Plan has been relocated from the Updated Safety Analysis Report to the Perry Plant Emergency Plan and implementing Instructions (Perry Plant Operations Manual), Section 8.2. The requirement for the PORC to review changes to the Security Plan has been relocated from the Updated Safety Analysis Report to the Perry Plant Security Plan, Revision 24, Section 1.9.

These revisions are consistent with Generic Letter 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans," and, therefore, are acceptable.

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3.0 CONCLUSION

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While the proposed revisions constitute a reduction in commitment, they meet the acceptance ' l criteria in Chapter 13.4 of the Standard Review Plan (NUREG-0800) and Generic Letter 93-07,

" Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans." Therefore, the proposed revisions to Perry Nuclear Power Plant's quality assurance plan, dated December 3,1998, continue to comply with the quality assurance criteria of Appendix B to 10 CFR Part 50 and are acceptable.

Principal Contributor: Michael Bugg Date: February 2, 1999 i

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