ML20216D709

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Safety Evaluation Supporting Amend 110 to License DPR-66
ML20216D709
Person / Time
Site: Beaver Valley
Issue date: 06/23/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20216D698 List:
References
NUDOCS 8706300577
Download: ML20216D709 (9)


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[g,G RfCg#'o UNITED STATES

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NUCLEAR REGULATORY COMMISSION n

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.p WASHINGTON, D. C. 20555 f

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.110 TO FACILITY OPERATING LICENSE NO. DPR-66 DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY l

BEAVER VALLEY POWER STATION, UNIT NO. 1 DOCKET NO. 50-334

1.0 INTRODUCTION

By letters dated January 15, May 8 and June 30, 1986, and January 15, l

March 5. March 17 and April 6, 1987, the licensee requested changes I

to the Administrative Controls, Section 6, of the Technical Specifications for Beaver Valley Power Station, Unit 1.

The licensee's letter of May 8, 1986, furnished information in response to questions that had been raised by the staff following its initial review of the January 15, 1986 letter.

This evaluation addresses all of the changes requested by the licensee such that it presents the staff evaluation of the organization as finally proposed through Revision 5 of the submittal (April 6, 1987).

2.0 DISCUSSION AND EVALUATION 1.

Sections 6.1.1,6.5.1.1.,6.5.1.6(a),6.5.1.7(a),6.5.1.7(c),6.8.2 1

and 6.8.3(c) - The previous title of " Plant Superintendent" would be changed to " Plant Manager". This is a title change only and is acceptable.

2.

Sections 6.2 and 6.2.1 - The previous designation of "Offsite Organization" would be changed to " Corporate Organization". This is a title change only and is acceptable.

n5 3.

Figure 6.2 The January 15, 1986 letter proposed extensive changes to this figure, including a title change to " Corporate Organization (Partial)", consistent with Item 2, above. The licensee's letter of y

May 8,1986, provided a comparison of the new position titles with the titles appearing in the existing Technical Specifications, and a

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functional description of each of the new positions. Our review of'the R$

proposed changes indicated that the resulting organization would be in accordance with the guidance of the Standard Review Plan, Section 13.1.1.

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j The licensee's letter dated Janusry 15, 1987 (Revision 2) proposed to further modify the corporate organization. The previously proposed title change of the senior nuclear officer to Nuclear Group Vice President would be further changed to Senior Vice President, Nuclear Group. This is a title change only and is acceptable. Reporting to this position would be a Manager, Budget and Fuel Contracts; a Manager, Ouality Assurance; a Senior Manager, Nuclear Operations; a Vice President, Nuclear; and the Beaver Valley Unit 2 Project. The latter office will disband when Unit 2 achieves commercial operation,.

The Senior Manager, Nuclear Operations is the proposed new title for 1

the previously designated Nuclear Operations General Manager.

Reporting to this position would be the Plant Manager; the Manager, Technical l

Services; the Manager, Planning and Outage Management; and the Manager, Radiological Control.

The newly established Vice President, Nuclear would provide support services to the nuclear program.

Reporting to this position would be the Manager, Nuclear Training; the Manager, Nuclear Construction; the Manager, Admin. Services; the Manager, Nuclear Safety; the General Manager, Nuclear Engineering and Records; and the Shippingport Atomic Power Station (SAPSI Decommissioning Project.

The March 17, 1987 letter (Revision 4)furthermodifiedFigure6.P-1to show the Offsite Review Connittee (ORC) reporting to the Senior Vice President, Nuclear Group, and the Independent Safety Engineering Group (ISEG) reporting to the Manager, Nuclear Safety, who reports to the Vice President Nuclear. These reporting relationships are consistent with the SRP Section 13.4 requirements and are acceptable.

We have reviewed the proposed changes to the licensee's corporate organization including the changes through Rcvision 5 We find that the resuiting organization provides for the type of support services I

. that normally are provided at the corporate level and that the functional groupings for corporate support are logically organized. Overall, the proposed revisions result in an organization that is consistent with the guidance of the Standard Review Plan, Section'13.1.1. We therefore find the proposed organization acceptable.

4.

Figure 6.2 The January 15, 1986 letter proposed certain changes to the figure describing the plant organization, but essentially the revised figure would be merely a simplified version of the figure appearing in the existing Technical Specifications.

Functions regarding refueling activity planning and engineering support activities were moved from the plant to the corporate support groups. The proposed revision included extensive title changes of the positions at the plant. The licensee's letter dated May 8,1986, provided a comparison of the proposed new titles

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with those in the existing figure and provided a functional description of the proposed new positions. Our review found that the functions pro-a vided in the revised organization were consistent with those in the existing organization except for the refueling and engineering support j

activities noted earlier. Overall, we found that the proposed new organization was consistent with the guidance of the Standard Review

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Plan, Section 13.1.2, and was, therefore, acceptable.

The licensee's letter of January 15, 1987 (Revision 2), propo'ses further changes to the plant organization. The previously proposed title of Operations Djrector would now be changed to Assistant Plant Manager, with responsibilities for operation of both Unit 1 and Unit 2.

Two Nuclear Operating Supervisors would be provided, one for each. unit, supervising separate groups of licensed and unlicensed operators. A third group would also be provided, headed by the Nuclear Operating Supervisor, Operations Support. Within this group would be the Radwaste Coordinator and staff, and the Operations Coordinators and Operations Engineers, who would provide support to both units. A Maintenance Support Supervisor and staff would be added to the maintenance department.to provide addi-l l

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tional manpower in support of plant maintenance requirements.- Minor changes would be made to the I&C organization to show the staffs (ISC Foreman and I&C Staff) reporting to the I&C Maintenance Supervisor and to the I&C Calibration Supervisor. The position.of the Plant Safety.

Review Director (OSC) has been clarified to show that he reports:directly to the P.lant Manager, but with a communication line to the Technical, Services Manager.

We have reviewed the proposed changes to the plant organization through the changes proposed by Revis. ion 2.

We find that the resulting organi-zation provides. coverage.for those. functions normally reouired at an.-

operating plant and that the functional groupings are logica11y' organized.

Overall, we find that the proposed ravisions' result in~ an organization that is consistent with the guidance.of the Standard Review Pla'n, Section-13.1.2, and that'the revised organization is, therefore,~ acceptable.

-5.

Table 6.2 A proposed change to this table would delete a footnote-

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regarding a temporary staffing change which was authorized until December 1,1983. This temporary authorization.has now expired and deletion of the footnote is, therefore, acceptable.

A second change to this table, proposed in the March 5,1987 letter (Revision 3), would add a footnote stating that a single qualified person may act as Shift Technical Advisor (STA). for both. Unit 1 and Unit 2.

This statement is consistent with the reouirements for STAS as specified in the Standard Review Plan, Section 13.1.2, and is acceptable.

6.

Section 6.3.1 and 6.17 -' Change-the title Radiological Ope' rations Coordinator to Radiological Control Manager. This change is consistent with the revised tities at the plant,-is aichange only in title,.and; is, therefore, acceptable.

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Sections 6.4.1 and 6.4.2 - Change the title of the Director Nuclear l

Division Training to the Nuclear Training Manager. This change is consistent with the revised titles at the plant, is a change only in title, and is, therefore, acceptable.

Section 6.4.2 has also been f

revised to correct a typographical error, changing "NEPA Code-1976"

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to "NFPA Code-1975". This is acceptable.

Section 6.5.1.1 - Revise to add the words, "and shall provide review 8.

capability in the areas of:

a.

nuclear power plant operations b.

radiological safety c.

maintenance 2

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nuclear engineering

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nuclear power plant testing f

f.

technical advisory engineering i

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chemistry h.

quality control 1.

instrumentation and control" j

This change specifies the functional areas of OSC review capability and, in conjunction with Item 9 below, is acceptable.

Section 6.5.1.2 - Delete the titles of the OSC members and replace with, 9.

"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 i

one individual from each of the areas' designated'in 6.5.1.1."

In conjunction with the proposed changes to Section 6.5.1.1, described in 4

l Item 8 above, and the change to Section 6.5.1.5, described in Item 12 below, this change accomplishes.the purpose of specifying OSC membership and is acceptable.

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p-10. Section 6.5.1.2 - The.first NOTE to this section has been deleted.

The. intent of the note regarding who appoints OSC members is now incorporated in the boh of the section while.the reference to minimum periods of membership has been_ deleted. The result is in accordance with the Standard Review Plan; Section 13.4,-and is acceptable.

11. -Section 6.5.1.2

.A second NOTE to'this section has been deleted and the words have been incorporated in.the body of the Section. This is acceptable. A change also has been made,to specify that OSC alternate members will meet the same minimum qualification as members. This is.

acceptable.

12. Section 6.5.1.5

,0uorum requirements for OSC meetings would be changed-to specify that, "A quorum of the OSC shall consist of the Chairman or his designated alternate and at least one-half of the members-including-altermates". This accomplishes the intent of having a ma.iority of the.

members or their alternates present to conduct OSC business', and is acceptable.

13. Section 6.5.1.6.a and 6.8.2 - Add the words >"o'f intent" to specify that the OSC will review. "all procedures _ required by Specification-6;8 and changes of intent thereto". - This change would decrease the OSC workload by reducing the changes that must be reviewed by the OSC.;such as.cor-recting typographical errors,' reformatting procedures and other changes not affecting the purpose for which the procedure is performed. The intent of this change is acceptable.
14. Section' 6.5.1.6.c - Delete the words " Appendix A" such that this:

section reads." Review of all! proposed changes to the Technical-Specifications". This change is. acceptable since the Technica1'.

Specifications are no longer' divided into;an Appendix'A and' Appendix B.

15. Section 6.5.1.6.e, 6.5.1.7.c, 6.5.1.B. 6.7;1.b, and 6.7.1.d Revise' the title
  • Manager of Nuclear Operations" to " Senior Manager Nuclear Operations"..This change.is consistent' with-the title changes in the '

i corporate organization',. is. a' change only in title, and istacceptable.:

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. 16. Section 6.5.2.2 - Change to delete the listing of designated ORC members and replace with, "The Chaiman and all members of the DRC shall be appointed by the Senior Vice President, Nuclear Group. The membership shall consist of a minimum of five individuals who collectively possess a

a broad based level of experience and competence enabling the comittee 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.

4 The collective competence of the comittee will be maintained as changes to the membership are made".

This change assures that the broad review capability of the ORC will be maintained, while avoiding the necessity of changing the Technical Specifications each time there is a title change among the designated ORC members. The composition of the ORC as revised is in accordance I

with the guidance of the Standard Review Plan, Section 13.4, and is therefore, acceptable.

17. Section 6.5.2.6 - Change the quorum requirements for the ORC to specify that, "A quorum of the ORC shall consist of the Chairman or his-designated alternate and at least four members including alternates. No-more ihan a minority of the quorum shall have line responsibility for operation of the facility".

In conjunction with Section 6.5.2.2

" Composition" and Section 6.5.2.3 " Alternates" 'this section would allow l

an ORC meeting to be conducted with a total of five" members.

18. Section 6.5.2.7.j - Change the wording to s'pecify that the ORC will i

review "The results of the Radiological Environmental Monitoring Program annual report provided in accordance with specification 6.9.1.10, prior--

j to submittal." The intent of this' change is to assure that the ORC reviews these reports prior to submittal.to the NRC., This change.

l clarifies only the language of this requirement and is acceptable.

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19. Section 6.5.2.9 - This section would be' revised to show the ORC reporting to and advising the Senior Vice President,l Nuclear Group.. This. is.

l consistent with Figure 6.2-1 and is acceptable.

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.. 20.. Section 6.5.2.10.a - This section would be revised to allow approval of ORC meeting minutes by the Vice Chairman as.well as the Chairman. We find this acceptable since the Vice Chairman would be the knowledgeable individual for the meetings he chairs.

21. Section 6.5.2.10.'b - A change to this section would delete the requirement

' that reports of ORC. reviews encompassed by Section 6.5.1.7 be forwarded to the ORC Chairman within 14 days following: completion of the review and replace it with, " Reports of reviews encompassed by Section 6.5.2.7 above shall be documented in the ORC meeting minutes". We~ find this acceptable since forwarding of reports by the ORC Chairman to the' ORC Chairman is a meaningless requirement. The review shot 1d be documented in the meeting minutes..

22. Section 6.5.2.10.c - The person who should receive ORC reports is the Senior Vice President, Nuclear Group. This.is consistent with the revised organization and is acceptable.
23. Section 6.5.2.10.d - The' licensee proposes to. delete this section, which requires the Vice President, Nuclear to review all ORC recomendations, on the basis that the Vice President, Nuclear is the ORC Chairman ~and:

perfoms the ORC meeting ' minute review and approval.. 'In fact, the ~ proposed changes to the Technical Specifications do.not now specify the 'Chaiman of the ORC, stating only that the Chaiman and members 'of the ORC are appointed by the Senior Vice President, Nuclear Group. However, the Standard Technical Specifications do not specify what the recipient"of ORC reports is to do with them. Therefore,'we have'no reason to-prescribe-what.the Senior Vice President, Nuclear Group.does with the. Beaver Valley ORC reports, and we agree that this section may be deleted.

24. Section 6.8.1.a - This section would be changed to specify that procedures recommended in Appendix "A" of Regulatory Guide 1.33. Revision 2, would be' addressed. This. change updates the reference to the' latest version of the Regulatory Guide, and makes this specification consistent with'

,l; those for Unit 2.

Thezchange is,;therefore,, acceptable.-

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25. Section 6.13.3 - This section would be renumbered to 6.16.3 to correct a typographical error. This. change is acceptable.
26. Section 6.17 - This section would be changed to revise the title, "Marager of Nuclear Safety" to " Senior Manager Nuclear Operations". This changa is acceptable since the Manager cf Radiological Control will now repart to the Senior Manager Nuclear Operations.

27 Index of the Technical Specifications - The Index has been retyped and a listing of Tables (Table Index) has been introduced. There are no technical issues involved and the changes are purely editorial.

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28. A number of technical specifications have been deleted or relocated by previous amendments, leaving blank pages behind. These blank pages are l

deleted and remaining pages that have been affected are renumbered. No technical issues are involved. The Attachment to the license amendment lists the affected and deleted pages.

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3.0 ENVIRONMENTAL CONSIDERATION

This amendment involves changes in administrative procedures or requirements.

Accordingly, this amendment meets the eligibility criteria for categorical i

exclusionsetforthin10CFR51.22(c)(10). Fursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical'to the common. defense and security or to the h'ealth and safety of the public.

Dated:

June 23,1987 Principal Contributors:

.L. Crocker--

l V. Benaroya P. Tam L

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