ML20206F822

Proposed Tech Specs,Amending App a to Address NRC Recommendations Identified in NRC Interim Safety Evaluation,

ML20206F822
Person / Time
Site:	Beaver Valley
Issue date:	04/06/1987
From:	DUQUESNE LIGHT CO.
To:
Shared Package
ML20206F764	List: ML20206F760 ML20206F792 ML20206F822
References
NUDOCS 8704140373
Download: ML20206F822 (7)

Text

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. ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF OUALIFICATIONS 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 who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, and the technical advisory engineering representative 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 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 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 provido review capability in the areas of:

a. nuclear power plant operations

b. radiological safety

c. maintenanco

d. nuclear engineering

c. 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 consist of a minimum of one individual from each of the arcas designated in 6.5.1.1.

OSC members and alternatos shall meet or excced the minimum qualifications of ANSI N18.1-1971 Section 4.4 for comparabic positions. The nuclear powcr plant operations individual shall moet the qualifications of Section 4.2.2 and the maintenanco individual shall meet the qualifications of Section 4.2.3.

BEAVER VALLEY - UNIT 1 6-5 PROPOSED WORDING '

0704140373 DR 070406 ADOCK 05000334  ;

PDR l

ADMINISTRATIVE CONTROLS MEETING FREQUENCY 6.5.2.5 The ORC shall meet at least once per calendar quarter during j the initial year of facility operation following fuel loading and at

least once per six months thereafter.

QUORUM

$ 6.5.2.6 A quorum of ORC shall consist of the Chairman or his designated alternato and at least 4 members including alternates. No more than a minority of the quorum shall have line responsibility for Ii operation of the facility.

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REVIEW j

i 6.5.2.7 The ORC shall review:

I I a. The safety evaluations for 1) changes to procedures, equipment or t

systems and 2) tests or experiments completed under the provision

of Section 50.59, 10 CFR, to verify that such actions did not

constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment or systems which

involvo an unroviewed safety question as defined in Section 1 50.59, 10 CFR.

J j c. Proposed tests or experiments which involve an unreviewed safety

, question as defined in Section 50.59, 10 CFR.

i i d. Proposed changos in Technical Specifications or licenses.

j c. Violations of applicablo statutes, codes, regulations, orders, l Technical Specifications, license requirements, or of internal J procedures or instructions having nuclear safety significance.

f. Significant operation abnormalitics or deviations from normal and l l cxpected performance of plant equipment that affect nuclear

safety, i

g. All REPORTABLE EVENTS

h. All recognized indications of an unanticipated deficiency in some 1 aspect of design or operation of safoty-related structures, j systems, or components.

! 1. Reports and mooting minutes of the OSC. l l

j j. The results of the Radiological Environmental Monitoring Program annual report provided in accordance with Specification 6.9.1.10, l prior to submittal.

DEAVER VALLEY - UNIT 1 6-9 j PROPOSED WORDING

ADMINISTRATIVE CONTROLS l

AUDITS (Continued)

I l 6.5.2.9 The ORC shall report to and advise the Senior Vice President, Nuclear Group on those areas of responsibility specified in Section 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.10 Records of ORC activities shall be prepared, approved and distributed as indicated by the following:  ;

a. Minutes of each ORC meeting shall be prepared for and approved by the ORC Chairman or Vice-Chairman within 14 days following each l meeting.

b. Reports of reviews encompassed by Section 6.5.2.7 above, shall be documented in the ORC meeting minutes.

c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Senior Vice President, Nuclear Group and to the management positions responsible for the areas audited within 30 days after completion of the audit.

1 6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Commission shall be notified in accordance with 10 CFR 50.72 and/or a report be submitted pursuant to the requirements of Section 50.73 to 10CFR Part 50, and

b. Each REPORTABLE EVENT shall be reviewed by the OSC, and results of this review shall be submitted to the ORC.

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 bo placed in at least HOT STANDBY within onc  !

(1) hour.

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b. The Safety Limit violation shall be reported to the Commission, the Senior Managor, Nuclear Operations and to the ORC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.  !

l BEAVER VALLEY - UNIT 1 6-11 PROPOSED WORDING

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4 ADMINISTRAT2VE CONTROLS l l r

I SAFETY LIMIT VIOLATION (Continued)

c. A Safety Limit Violation Report shall be prepared. The report  :

l shall be reviewed by the On-Site safety committee (OSC). This l 1 report shall describe (1) applicable circumstances preceding the  !

! violation, (2) effects of the violation upon facility components, I systems or structures, and (3) corrective action taken to prevent i recurrence. l l d. The Safety Limit Violation Report shall be submitted to the

} Commission, the ORC and the Senior Manager, Nuclear Operations

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within 14 days of the violation.

6.8 PROCEDURES t

I 6.8.1 Written procedures shall be established, implemented, and l maintained covering the activities referenced below  ;

i

] a. The applicable procedures recommended in Appendix "A" of l

Regulatory Guide 1.33, Revision 2, February 1978.

a

b. Refueling operations.

c. Surveillance and test activities of safety related equipment.

d. Security Plan implementation.

f I

e. Emergency Plan implementation.

[ f. Fire Protection Program implementation.

I j g. PROCESC CONTROL PROGRAM implementation. l f h. OFFSITF 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 approved i by the Plant Manager, predesignated alternate or a predesignated i

! Manager to whom the Plant Manager has assigned in writing the i

responsibility for review and approval of specific subjects conuidored by the committee, as applicable. Changes to procedures i

and administ.rative policies of 6.8.1 above that do not receive OSC 1

review, such as correcting typographical errors, reformatting  !

! procedures and other changes not affecting the purpose for which the j procedure is performed shall receive an independent review by a j qualified incividual and approved by a designated manager or i director.

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! BEAVER VALLEY - UNIT 1 6-12

, PROPOSED WORDING l

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ATTACHMENT B i

Proposed Technical Specification Change No. 106, Revision 5 No Significant Hazard Evaluation Description of amendment request: The proposed amendment would revise our previous submittals concerning the Nuclear Group organization and administrativo controls to address the NRC recommendations identified by letter dated March 5, 1987. Provided are the recommendations in the order listed in the NRC Interim Safety Evaluation Summary followed by the applicable response:

1. Figurc 6.2-1 should be changed to show the ORC reporting to the Senior Vice President, Nuclear Group; and the ISEG reporting to the Vice President, Nuclear.

Response

Figure 6.2-1 was revised and provided to the NRC in Change Request 106, Revision 4 to show the ORC reporting to the Senior Vice President, Nuclear Group and the ISEG reporting to the Manager, Nuclear Safety who reports to the Vice President, Nuclear. Thorofore, no additional revision is required.

2. Section 6.5.1.2 should be changed to correctly specify tho

qualifications of OSC members.

Responso Section 6.5.1.2 has boon revised to correct the typographical error. See the attached revised page 6-5.

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3. Section 6.8 should be changed to provide for indopondent qualified review and approval by a designated manager of changes ,

to procedures that are not reviewod by the OSC and approved by 1 the Plant Manager.

Responso Section 6.8.2 has been revised to c1carly specify the review and ,

approval requirements for proceduro changes that do not roccivo l j OSC review. The phrase all proceduro chancos in the first <

! sentonce has bocn doloted, since this was incorporated by a previous revision as a means to satisfy the above recommendation. However, to provido additional clarification, the following sentonce has been added Chancos to proceduros and administrativo policios of 6.8.1 abovo that do not roccivo osc review, such as correcting typographical errors, reformatting procedures and other changes not affecting the purposo for which the procedure is performed may receive an indopondent review by a qualified individual and approved by a dosionated manaqor s Soc attached revised page 6-13.

4. Section 6.5.2.2 should be changed to show that ORC members are appointed by the Senior Vice President, Nuclear Group.

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• Atttchment B l

Pcg3 2 Responso Section 6.5.2.2 was revised to show that the ORC members are appointed by the Senior Vice Prcsident, Nuclear Group and was provided to the NRC in Change Request 106, Revision 4.

Thorofore, no additional revision is required.

5. Section 6.5.2.6 should be changed to specify acceptable quorum requirements for the ORC.

Responso The change to Section 6.5.2.6 has boon withdrawn, thoroforo, Section 6.5.2.6 has boon revised, relative to previous submittals, to incorporato the existing wording. Thoroforo, this section will be consistent with the Standard Technical Specification wnich requires a quorum consisting of the Chairman or designated alternato and 4 members including alternatos. This is consistant with current ORC membership and satisfios the NRC requirements. In addition, Section 6.5.2.7.j has boon revised to ensure the ORC rovicws the annual report prior to submittal. The  ;

phraso prior to submittal has boon moved to the end of tho sentenco. Sinco the results of the Radiological Monitoring i

Program is part of the annual report and is submitted with the annual report, the ORC will review the annual report before it is submitted to the NRC.

6. Section 6.5.2.9 should be changed to show that the ORC reports to and advisos the Senior Vice President, Nuclear Group.

Responso i Section 6.5.2.9 was revised to show that the NRC reports to and advisos the Senior Vico President, Nuclear Group and was provided to the NRC in Chango Roquest 106, Revision 4. Thoroforo, no additional revision is required.

7. Section 6.5.2.10.a should be changed to show that ORC mooting minutos are handled in 14 days, not 14 working days.

Responso Section 6.5.2.10.a has boon revised to show that ORC mooting minutos are handled in 14 days. Soo attached rovised pago 6-11.

8. Section 6.5.2.10.c should be changed to specify that the Senior Vico President, Nuclear Group rocoivos ORC reports.

Responso Section 6.5.2.10.c was revised to specify that the Senior Vico Prosident, Nuclear Group rocoivos ORC reports and was provided to the NRC in Chango Roquest 106, Rovision 4. Thoroforo, no additional revision is required.

Attcchment

'* Pcg3 3 Basis for no significant hazard determination: Based on the criteria for determining whether a significant hazards consideration exists as setforth in 10 CFR 50.92(c), plant operation in accordance with the proposed amendacnt would not:

1. Involvo a significant increase in the probability of occurrence or the consequences of an accident previously evaluated because:

These changes are adninistrative in nature, such as the chango to section 6.8 which adds provisions for independent review of procedures that do not roccivo OSC review by a qualified individual and approved by a designated manager. The change to section 6.5.2.6 withdraws our previous change to this section and returns to the existing wording. This is consistent with the Standard Technical Stocification wording and clearly requires a quorum consisting of the chairman or designated alternate and 4 members including alternatos.

The chango to Section 6.5.2.10.c requires preparation and review of ORC mooting minutes within 14 days to reflect the Standard Technical Specification requirements and NRC recommandations. A chango to Section 6.5.2.7.j has boon incorporated to provido additional clarification to ensuro the ORC reviews the results of the Radiological Environmental Monitoring Program. Thoroforo, thoso changes will not affect the probability of occurrence or the consequences of an accident previously ovaluated sinco they are administrativo and not technical in naturo.

2. Create the possibility of a now or different kind of accident from any accident previously ovaluated becauso: No changos in plant operations or to equipment or components is required.

Thoso changos are administrativo in naturo, do not affect the safe operation of the plant and do not affect the accident analysos of UFSAR Goction 14. Thoroforo, thoso changos will not  !

creato the possibility of anew or different kind of accident from those described in t?no UFSAR.

3. Involvo a significant reduction in the margin of safoty because:

Those changos are administrativo in naturo, do not affect the bases for any technical specification and will not affect tho l safo oporation of the plant, t

, Conclunion The proposed changos do not involvo a significant increano in the probability or consequonco of a previously evaluated accident, do not croato the possibility of anow or difforont kind of accident and do not involvo a significant reduction in a margin of safoty. Thoso changos reflect tho NRC recommandations identified in the NRC Intorim i Safety Evaluation dated March 5, 1987. Thoroforo, based on the abovo, it is proposed to charactorizo the chango to involvo no significant hazard considoration.

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