ML20235H304
| ML20235H304 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/11/1987 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20235H120 | List: |
| References | |
| NUDOCS 8710010012 | |
| Download: ML20235H304 (11) | |
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SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS
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SUPPORTING AMENDMENT NO. 138 TO FACILITY OPERATING LICENSE NO. DPR-33 AMENDMENT NO. 134 TO FACILITY OPERATING LICENSE NO. DPR-52 AMENDMENT NO. 109 TO FACILITY OPERATING LICENSE NO. DPR-68 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2 AND 3 DOCKET N05. 50-259, 50-260, AND 50-296
1.0 INTRODUCTION
By letter dated September 27, 1984 as supplemented January 17. June 2, and December 10, 1986, (TS-201) the Tennessee Valley Authority (TVA or the licensee) requested amendments to Facility Operating Licenses Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, Units 1, 2 and 3 (BFN). The amendments would change the Technical Specifications (TS) to show recent organization changes, provide improvements and clarifications, and reformat the administration control section to conform more closely with the Standard i
Technical Specifications (STS). Minor changes were made to proposed Specifications 6.5.1.6.b and k, 6.5.3.1 and 6.8.1.1 to clarify the Specifications. These changes were discussed between the NRC staff and the licensee on September 8,1987, and l
accepted by the licensee.
The licensee's letters dated June 2,1986, and December 10, 1986, consisted of minor administrative changes and enhancements per staff discussions. These supplements did not significantly change the application from that initially noticed on February 26, 1986 (51 FR 6830) and do not alter the staff's proposed no significant hazards determination.
2.0 EVALUATION 0-
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2.1 Fomat of the Entire Administrative Controls, Section 6 The proposed amendment adopts the same fonnat and method for numbering subsections b
that are used by STS. This includes a revised index and table of contents.
The request to adopt the STS page numbering system for the Administrative
%@g Controls Section by this amendment has been obviated by TVA's letter dated March 19, 1987 since that letter provided a complete set of retyped TS, which contained the new page numbering system, for use as the NRC record copy. The 8
table of contents will be revised and expanded to reflect the changes of the pg amendment.
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Changing the TS format should piake the Administrative Controls Section clearer to follow due to the more logical order, the better indexing, and the improved l
section headings. Therefore, the staff finds this reformatting, including i
renumbering of the subsections, to be acceptable, i
, 2.2 Responsibility, Section 6.1 Section 6.1 has been revised to change the Plant Superintendent to Plant Manager since that is the new title of the position.
In addition, Section 6.1 has been revised to change the Assistant Director of Nuclear Power (Operations) to the Browns Ferry (BF) Site Director since that is the new title of the position to which the Plant Manager now reports.
These changes are acceptable since they represent title changes only.
2.3 Revisions to the Offsite Organization Chart, Figure 6.2-1 Figure 6.2-1 has been revised to reflect the TVA corporate offsite nuclear organization for facility management and technical support. The corporate level changes represent a restructuring of the corporate offsite organiza-tion to provide for centralized direction and control of nuclear activities.
Each of the offsite corporate departments shown in Figure 6.2-1 will be responsible for direct support of the sites in their areas of responsi-l bilities. The TVA corporate organization was developed so that support to each of the sites follows clear lines. The functional alignment of departments within corporate is paralleled at the plant sites (including Browns Ferry).
The staff considers this functional alignment of departments and standardization of TVA an improvement over the organization presented in the existing Browns Ferry TS. The corporate organization is acceptable, since it provides for management attention to cnd support of the Browns Ferry nuclear program, meets the acceptance criteria of Section 13.1.1 and 13.1.2 of the Standard Review Plan I
(SRP) and is consistent with the TVA organization presented in the revised TVA Corporate Nuclear Performance Plan which was approved in NUREG-1232, Volume 1.
l 2.4 Revision to,the Facility Organization Chart, Figure 6.2-2 Figure 6.2-2 has been revised to reflect the new site organization at the Browns Ferry Nuclear (BFN) Plant as detailed in the latest revision of the Browns Ferry Nuclear Performance Plan (BFNPP), submitted to NRC on July 1, 1987. The BFN site support organizations have been reorganized into functional departments that generally parallel the functional departments in the headquarters of the Office of Nuclear Power. The BFNPP describes the plan for providing management control and performing specific actions to correct past problems at BFN.
l Specifically, the BFNPP outlines the management approach to overcoming past I
problems and improving regulatory performance at the BFN. This TS change revises the organization chart in the TS to be consistent with the organization necessary to carry out the improvements specified in the BFNPP.
, The Plant Manager is responsible for conducting day-to-day plant operation in compliance with licensing and regulatory requirements. A plant manage-ment organization has been implemented with a unit superintendent assigned to each of the units. As a result of the reorganization, the Plant Manager is free to concentrate his attention on the actual conduct of plant operations.
Due to the reorganization, many position titles have changed. Of these, the most significant are the following:
Previous Title New Title l
ManagerofPower(andpreviously Manager of Nuclear Power Manager of Power and Engineering)
Assistant Director of Nuclear Power Browns Ferry Site Director (Operations)
Plant Superintendent Plant Manager Health Physics Radiological Control Supervisor Quality Assurance Supervisor Site 0A Manager In conclusion, Figure 6.2-2 represents the BFN organization which (1) reflects an increase in staffing, (2) provides a higher level of management control at the site, (3) shows improved management involvement in plant operations, (4) has distinct functional areas that are separately supervised (5) meets the acceptance criteria of Section 13.1.2 of the SRP, and (6) is consistent with the BFN organizational structure presented in the BFNPP. Therefore, Figure 6.2-2 is acceptable.
2.5 Plant Staff, Section 6.2.2 Section 6.2.2 has been revised as follows:
Existing Note No. 7 which required the Shift Technical Advisor (STA) a.
to be present at all times has been deleted and replaced by the requirement for an STA when any unit is in operation. This change is consistent with past practice and meets the guidance provided in NUREG-0737, Item I.A.1.1 and is, therefore, acceptable.
b.
Existing Note No. 6 which required the Operations Supervisor to have an SRO license has been deleted. The Operations Supervisor shall meet the minimum qualifications specified in Regulatory Guide 1.8 which endorses ANSI-H18.1, which includes the requirement for an SR0 license (see new Section 6.3) and therefore, this change is acceptable.
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The following has been added to Section 6.2.2 "d," "In addition, a person holding a senior operator license shall be in the control room for that unit when ever it is in an operational mode other than cold shutdown or refueling." This addition is acceptable since it is in conformance with 10 CFP, 50.54 d.
The requirement for a senior licensed operator with respect to fuel handling has been clarified and is in conformance with 10 CFR 50.54 and is, therefore, acceptable.
e.
The requirement to maintain a site fire brigade has been added.
This change also includes the addition of a note regarding the minimum requirements for the site fire brigade and health physics technician. This addition is acceptable since it adds requirements delineated in STS and is conformance with 10 CFR 50.54.
2.6 Minimum Shif t Crew Requirements, Table 6.2. A Table 6.2.A has been revised as follows:
a.
The minimum shif t requirements have been increased to reflect the requirements in 10 CFR 50.54(m), and b.
Note "e," which described the STA qualifications, has been deleted since these qualifications are described in the new Section 6.3.
Table 6.2A which adds the new minimum shift crew requirements and deletes an unnecessary note is acceptable since the table meets the requirements of 10 CFR 50.54, adopts STS terminology, meets the objectives of Section 13.1.2 of the SRP and will result in increased clarity and usefulness.
2.7 Plant Staff Qualifications, Section 6.3 The description of the STA qualifications have been added to Section 6.3.
The STA qualifications are now in the TS text and no longer only a footnote to the shift crew table (6.2.A). This is an administrative change that improves the way the information is presented and does not alter the requirements and therefore is, acceptable.
2.8 Plant Operations Review Committee (PORC) Composition and Quorum Sections 6.5.1.1, 6.5.1.2, 6.5.1.3, 6.5.1.4, and 6.5.1.5 The proposed changes to the Plant Operations Review Comittee (PORC) Composition and Quorum including the following:
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The addition of a new Section 6.5.1.1 to the TS which describes the function of the PORC, This section allows PORC to function as a body or as individuals and through the use of subcommittees.
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The membership of the PORC would be revised to be consistent with the reorganization discussed in Section 2.4.
The revised membership includes the Plant Manager or the Assistant to Plant Manager as Chairman, the Technical Services Superintendent as Chairman or a member, three' unit Superintendents, the Maintenance Superintendent the' Quality Assurance Staff Supervisor and the Health Physics Supervisor.
The minimum number of persons necessary for a quorum for the PORC would be revised to be the Chairman or the alternate chaiman and five members.
The revised PORC membership provides a broad cross-section of expertise from the plant staff, therefore, preserving interdisciplinary ' reviews of the subject matter.
In addition, the PORC membership will maintain a diversity of backgrounds j
among its members'(1.e., operations, engineering, maintenance, quality assurance and health physics). The new minimum gyorum requirements of Chairman plus five members is a majority of the revised total PORC membership of eight.
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We find that these proposed. changes to the PORC do not degrade the capabilities of the PORC and meet the acceptance criteria of Section 13.4 of the SRP and the relevant requirements of Regulatory Guide 1.33 (R.G. 1.33). Therefore 'these proposed changes are acceptable.
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2.9 Plant Operations Review Committee (PORC) Responsibilities, Section 6.5.1.6 and new 5ection 6.5.3 Technical Review and Approval of Procedures Ths'licenset proposed to revise Section 6.5.1.6 and to add a new Section 6.5.3.
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As discussed in detail below, several review responsibilities of PORC would be i
transferred to designated technical reviewers. The new proposed process of
.Section 6.5.3 will establish an " independent qualified review" and a cross-disciplinary review and approval to support certain changes currently under PORC review responsibility. The PORC review responsibility for Appendix "A" TS, Emergency Operating Procedures, the Security Plan and the Radiological Emergency Plan remains unchanged.
The following PORC responsibilities are proposed to be deleted from Specification
.6.5.1.6 as discussed below:
Review and approval of corporate site-level procedures issued by the site director thereto will be controlled under the new Section 6.5.3
" Technical Review and Approval of Procedures."
The following PORC responsibilities would be revised in Specification 6.5.1.6 1
as discussed below:
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. PORC will review the administrative procedures listed in Appendix A of R.G. 1.33. Revision 2, February 1978, and the administrative procedures for the control of the technical and cross-disciplinary review of written procedures.
PORC responsibilities have been changed so that PORC will be responsible for the review of all " safety evaluations for modifications to structures, systems or components that affect nuclear safety instead of " proposed changes to equipment or systems having safety significance." Revised Section 6.5.3.2 of the TS establishes the new technical methods for individual review and approval for these plant changes or modifications.
The new, more commonly used wording " modifications to safety-related structures, systems or components" is preferable since the previous words were unclear and difficult to interpret.
PORC will be responsible for reviewing the safety evaluations for proposed tests or experiments instead of the plans.
A rewording of the responsibilities of the PORC to more closely match responsibilities listed in TS of more recently licensed BWR plants.
On September 8,1987 the staff discussed minor clarification changes to proposed Specification 6.5.1.6.b and 6.5.3.2 to provide more precise determination of the PORC responsibilities for review of administrative procedures and review of safety evaluations for modification of systems or components that affect safety. These changes were acceptable to the licensee.
These changes are minor and provide better clarification of Specification 6.5.1.6.b and k, and therefore, these changes do not need to be submitted and noticed in accordance with 10 CFR 50.90 and 10 CFR 50.91.
Section 6.5.3, Technical Review and Approval of Procedures, is added to describe the new technical review and control process. The new process establishes an independent qualified review and a cross-disciplinary review and approval that supports changes to procedures and plant changes or modifications to plant nuclear safety-related structures, systems and components.
Each procedure required by Section 6.5.3 of the TS will be reviewed by an individual other than the preparer. The reviewer may be from the same organization or from a different organization.
Individuals who conduct these reviews, at a minimum, will be members of the BFNPP supervisory staff and shall be previously designated by the Plant Manager. Each review will include a determination of whether or not a cross-disciplinary review is necessary.
If so a cross-disciplinary review will be conducted.
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Each proposed change or modification to plant nuclear safety-related structures, systems and components will be reviewed by a reviewer I
designated by the Plant Manager. Each modification will be reviewed by an individual or group other than the person (s) which designed the modification. The Plant Manager will approve the modifications prior to implementation.
A new Site Director's Standard Practice, SDSP-7.4 (Plant Operations Review Committee and Technical Review and Approval of. Procedures),
will establish requirements for qualified review of procedures.
It will also establish qualifications and training requirements necessary for qualified reviewers.
Each individual perfonning the qualified review will possess technical expertise in the area or discipline in which he is performing the review. Every qualified reviewer will receive training in how to determine if an i
interdisciplinary review is necessary. Specific guidelines are i
given for performing the independent qualified review, including the cross-disciplinary review, and the appropriate level of mhnagement to approve chances is specified. SDSP will contain a clause which l
allows the qualified reviewer or the responsible manager approving the procedures or procedure change the right to request PORC review.
NQAM (Nuclear Quality Assurance Manual) will require review and approval in accordance with SDSP-74. Appropriate managers responsible for approval of different groups of procedures will be designated within their field of responsibility. Quality Assurance (QA) will be given the option to review all changes.
After revising PORC, the members will have a reduced administrative
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burden and, therefore, will have more timt available for the review of significant issues. These amendments would permit PORC members to focus their attention on the issues essential to the operation of the plant thereby improving PORC's effectiveness. This aspect is increasingly important because of the growing number of procedures, procedural changes, and modifications that must be reviewed.
The proposed changes would allow for the use of individual technical reviewers who can spend more time on the review. The detailed tech-nical reviews of procedures can be accomplished by qualified technical reviewers not encumbered with other managerial duties, but possessing 1
the technical expertise to conduct a thorough review. The proposed changes allow for an independent technical and cross-disciplinary review and approval.
The current TS requirement for review of chsnges is actually satisfied by individuals of a similar responsibility level, however, considerable management time is consumed in the assigning of these personnel to review each item, collecting results from those reviews, and finally attending a formal meeting to recommend a disposition. The method requested by these amendments eliminates much of the unnecessary effort 9
and'at the same time provides for a more consistent and timely review l
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., and approval process.
It would focus responsibility and account-ability to the technical reviewers and provide a better review, Cross-disciplinary review would also be improved from current methods since reviewers will be able to concentrate on their particular areas of expertise.
On September 8, 1987 the staff discussed minor clarifications changes to Specification 6.5.3.1 to define specifically the person or persons who may approve procedures other than Site Director Standard Practices. These changes were acceptable to the licensee. These changes are minor and provide only the specific person or persons who may approve procedures, and therefore, these changes do not need to be submitted and noticed in accordance with 10 CFR 50.90 and 10 CFR 50.91.
The proposed changes have been designed so as to improve PORC operations. The above changes are acceptable since they (1) are consistent with the acceptance criteria of SRP Section 13.4, (2) meet the objectives of Regulatory Guide 1.33 which requires that decisions affecting safety are made at the proper level of responsibility and with the necessary technical advice and review (3) provide technical review and approval, and (5) ject matter, (4) allow for independent for interdisciplinary review of the subprovide qualified designated reviewers.
2.10 Plant Operations Review Committee (PORC) Authority and Records, Sections 6.5.17 and 6.5.18 These sections have been rewritten to generally correspond with STS and to be consistent with the previously discussed changes and are, therefore, acceptable.
2.11 Nuclear Safety Review Board (NSRB), Audits, Authority and Records Qualifications, Sections 6.5.2.3, 6.5.2.8, 6.5.2.9, 6.5.2.10 Change " Manager of Power" to " Manager of Nuclear Power." This change is acceptable since it is a title change only.
2.12 Technical Review and Approval of Procedures, Section 6.5.3 Since changes outlined in Item 2.9 above reduce the responsibilities of PORC, this section has been added to describe the new technical review and approval process for procedures required by TS 6.8.1.1.
Procedures required by 6.8.1.1 include those recommended by Appendix A of R.G. 1.33 (except the administrative procedures which will be reviewed by FORC); overtime, surveillance and test activities, and Security Plan, Emergency Plan and Fire Protection Program implementation.
Each procedure required by the TS will be reviewed by an individual other than the preparer. The reviewer may be from the same organization or from a different organization.
Individu61s who conduct these reviews will be members of the BFN site supervisory staff and shall be previously designated by the Plant Manager.
Procedures other than Site Director Standard Practices will be approved by the responsible section supervisor or the applicable plant superintendent. Each review will include a determination of whether or not a cross-disciplinary review is necessary.
If so a cross-disciplinary review will be conducted.
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4 9-Each proposed change or_ modification to plant' nuclear. safety-related structures, systems and components will be reviewed by a reviewer designated by the Plant-Manager. Each modification described above will be reviewed by an individual or group other than the person (s) which designed the modification. The Plant ~
Manager will approve the modifications prior to implementation.
The above changes are acceptable since they (1) are' consistent with the acceptance criteria of SRP Section'13.4, (2) meet the objectives of R.G.1.33, (3) provide the opportunity for interdisciplinary review of the subject matter, (4) allow for independent technical' review and approval, and (5) provide qualified. designated reviewers.
2.13 Reportable Event Action and Safety Limit Violation. Sections 6.6 and 6.7 Since these sectio'ns have been rewritten for clarity to closely correspond to STS they are acceptable.
2.14 Procedures. Section 6.8.1 The procedures section, which lists those procedures that are required to be
' established, implemented and maintained by BFNP, has been upgraded to include the procedures listed in Appendix A of R.G. 1.33, Revision 2. February 1978.
Rather than individually list general. categories of procedures to be prepared, Section 6.8.1 has been revised to. incorporate those listed ~1n R.G. 1.33.
R.G.
1.33 more precisely lists the types of procedures to be established, implemented and maintained. Since the proposed Section 6.8.1 confoms with R.G.1.33 and uses STS terminology, it is acceptable.
2.15 Radiation Control Procedures. Section 6.8.3.1 This section contains a minor change to show that Browns Ferry Nuclear Plant has changed the title of the Special Work Permit to the Radiological Work Permit.
This change.is acceptable.
2.16 Reportina Requirements. Section 6.9 The section on Reporting Requirements has been revised as follows:
a.
Footnote 2 and 3 of the current TS section 6.7, which defined the tems " forced reduction in power" and " forced outage" are deleted by this amendment since they are not referenced anywhere in TS.
b.
The notes 1 and 2 are moved and properly referenced by the Annual Operating Report requirement and the Radioactive Effluent Release Report requirement as in STS.
c.
The reference to safety relief valves in the current TS on the Annual Operating Report has been changed to properly reference only relief valves, since " safety valves" were deleted from Units 1, 2, and 3 TS by Amendments 92, 85, and 51, respectively.
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The requirement for the Monthly Operating Report has been changed to allow 15 days for submission to NRC instead of the current requirement of 10 days. This extension of 5 days is consistent with STS.
The above proposed changes to the Reporting Requirements reflect an upgrading and clarification of the TS. We find that the Reporting Requirements, as revised, are acceptable for the following reasons:
Deleting notes that are not referenced in the current TS and a.
are not in STS will clarify the actual requirements by removing notes which are not applicable to the TS.
b.
Moving notes to the area where they are to be referenced and properly noting the reference will clarify these requirements.
Removing this reference to safety valves is correcting an error c.
and does not actually change the requirement.
d.
Allowing 15 days to submit the monthly report will provide needed additional time for its preparation and conforms to STS.
2.17 Station Operating Records and Retention, Section 6.10 This section has been revised to slightly modify the words of the current TS Section 6.6.A.17 to reflect the revised format. The current TS Section 6.6.A.18 has been deleted since it was solely in reference to a Section 6.10 which was previously deleted by Amendments 79, 75, and 48 for Units 1, 2, and 3, respectively.
These changes are acceptable since they improve the clarity of Section 6.10.
3.0
SUMMARY
The proposed amendments to Section 6, " Administrative Controls" revise the TS for Units 1, 2 and 3 to reflect the new TVA and Browns Ferry plant organization, changes to the PORC, and changes to convert Section 6 of the TS to more closely ratch the content of the STS. The staff concludes for the reasons stated in the above evaluation that all proposed changes are acceptable.
4.0 ENVIRONMENTAL CONSIDERATION
S These amendments relate to changes in recordkeeping, reporting, or administrative procedures and requirements. Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to10CFR51.22(b)noenvironmentalimpactstatementnorenvironmentalassessment need be prepared in connection with the issuance of these amendments.
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5.0 CONCLUSION
S 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 Comission's regulations and the issuance of j
these amendments will not be inimical to the coninon defense and security nor to the health and safety of the public.
Principal Contributor:
C. Goodman Date: September 11, 1987 l
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