ML20245A825

SER Re Proposed Changes to Administrative Controls Section of Tech Specs Concerning Min Shift Crew Composition,Unit Staff Qualifications,Training,Plant Safety Review Committee & Safety Review Committee Composition.Changes Unacceptable

ML20245A825
Person / Time
Site:	Grand Gulf
Issue date:	04/17/1989
From:	NRC
To:
Shared Package
ML20245A819	List: ML20245A816 ML20245A825
References
GL-88-06, GL-88-6, NUDOCS 8904250402
Download: ML20245A825 (2)

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. . ENCLOSURE SAFETY EVALUATION REPORT GRAND GULF NUCLEAR STATION UNIT 1 TECHNICAL SPECIFICATION CHANGE By letter dated December 16, 1988, Systems Energy Resources, Inc., (SERI) requested several changes to the Administrative Controls Section of the Technical Specifications for the Grand Gulf Nuclear Station, Unit 1.

Following is a brief description and our evaluation of the requested changes.

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1. Table 6.2.2 Minimum Shift Crew Composition SERI proposes to add a footnote to this chart permitting the dual role SR0/STA provided the SR0 or SS on shift meets the qualification to be an STA as described in Section 6.3.

We find the requested change unacceptable as the qualifications for the STA in Section 6.3 do not meet that described for the dual role in Option 1 of the Commission Policy Statement on Engineering Expertise on Shift.

2. Section 6.3 - Unit Staff Qualifications i SERI proposes to delete the specific reference in Section 6.3 to the title of Chemistry / Radiation Control Superintendent and replace it with the general title of Radiation Protection Manager (RPM). The position of RPM does not exist, and it is not shown on the organization chart in the FSAR.

We find this requested change unacceptable as it is the staff's position that the Technical Specifications contain the actual position titles so that the responsibility and qualifications are associated with a specific position. Additionally, this proposed change does not meet the in, tent of Generic Letter 88-06.

3. Section 6.4 - Training SERI proposes to delete the specific reference in Section 6.4 to the title of Training Superintendent and replace it with the general title of i Training Manager. The position of Training Manager does not exist, and it is not shown on the organization chart in the FSAR.

We find this requested change unacceptable as it is the staff's position that the Technical Specifications contain the actual position titles so that the responsibilities and qualifications are associated with a specific position. Additionally, this proposed change does not meet the intent of Generic Letter 88-06.

4. Section 6.5.1.2 - Plant Safety Review Committee (PSRC) - Composition SERI proposes replacing the specification of PSRC membership by title with a specification describing the numbers of members and the qualifications as at the Superintendent level or above.

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We find the requested change-unacceptable as stated because the number of members are not precisely described and the designation of Superintendent level or above is too ambiguous.

'5. Section 6.5.2.2 - Safety Review Committee (SRC)'- Composition .!

SERI proposes replacing the specification of SRC membership by title with a specification describing the numbers of members and specifying the qualifications of the' Chairman (the qualifications of the members are currently in.the specification).

We find the requested change acceptable except for allowing the Chairman to have an equivalent to a Bachelor's degree in an engineering or physical science field without describing the aquivalent.

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