ML20246M933
| ML20246M933 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/29/1989 |
| From: | DUQUESNE LIGHT CO. |
| To: | |
| Shared Package | |
| ML20246M921 | List: |
| References | |
| NUDOCS 8909070302 | |
| Download: ML20246M933 (5) | |
Text
7-m.
k'y l L',
A'TTACHMENT A
Revise the Technical Specifications as follows:
Remove Pace Insert Pace 6-3 6-3 8909070302 390829 PDR ADOCK 05000412 P
I
,}ADMINISTRATIVECONTROLS
+
COMPOSITION Me/ $ [l) 6.2.3.2 The ISEG shall.be composed of at.
ast five, dedicated, full-time is Jengineers located on site.
Each shall hav 4 bachelor's degree in engineering l=
- or related science and at least 2 years professional level experience in his field, at least 1 year of which experience shall he'in the nuclear field ofy j
RESPONSIBILITIES 6.2.3.3 The ISEG shall be responsible for maintaining surveillance of unit activities to provide independent verification
- that these activities are-L performed correctly and that human errors are reduced as much as practical.
I RECORDS 6.2.3.4 Records of activities performed by the ISEG shall be prepared, main '
tained, and a summary report shall be' forwarded each calendar month to the Vice i:
President, Nuclear Group.
I.
l (2) At least 5 years of nuclear experience and hold or have held a Senior Reactor Operators license, or (3) At.least 10 years of pr of essi anal level experience in his field, at least.5 years of which experience shall be in the nuclear field.
A minimum of 50% of these personnel shall have the qualifications-specified in (1) above.
1 l:
1.
- Not responsible for sign-off function.
BEAVER VALLEY - UNIT 2 6-3 (next page is 6-5) 020 90.5 El>
__l__._______'_____.
_.._m_.
_______.__i__ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
p ATTACHMENT B
. Safety Analysis Beaver Valley Power Station, Unit No. 2 Pronosed Technical Specification Chance No. 28 Description of Amendment Reauest:
The proposed amendment would revise the qualification requirements for Independent Safety Evaluation Group (ISEG) members.
Currently all ISEG members must have a
bachelor's degree in engineering or related science.
Specification 6.2.3.2 would 'be revised to allow up to two ISEG members with (1) a current or previously held Beaver Valley Power Station Senior Reactor operator's license and 5
years of professional level experience in the nuclear field or (2) at least 10. years of professional level experience in his field with at
'least 5
years of nuclear field experience to be substituted in lieu of a bachelor's degree Discussion NUREG-0737 Section I.B.1.2 required all applicants for operating licenses to implement an ISEG.
Thus BVPS Unit 2, with the issuance of its operating license in 1987, established an ISEG at Beaver Valley.
As per NUREG 0737, the principal function of the ISEG is to examine plant operating characteristics, NRC issuances, industry advisories and other appropriate sources of plant design and operating experience information that may indicate areas for improving plant safety.
The ISEG is also to perform independent review-of plant activities including maintenance, operational problems and operational analysis.
Where useful improvements can i
be
- achieved, it is expected that this group will develop and present detailed recommendations to corporate management.
- However, NUREG-0737 (nor its listed references of NUREG-0660 and NUREG-0694) did not specify any minimum qualification requirements for ISEG.
It only called for an
" increase in the available technical expertise located onsite" and to " provide continuing, systematic, and independent assessment of plant activities."
In the spirit of this
- concept, a
more knowledgeable and experienced ISEG group would produce higher quality and useful recommendations for improvement as envisioned by NUREG-0737.
Current Technical Specifications prohibit highly trained and experienced personnel in the operations or operations support Departments who do not possess a
bachelor's degree from being eligible for ISEG consideration even though a significant portion of ISEG evaluations review plant activities involving operations, Maintenance and Instrumentation and Control.
Thus this change would allow a person with (1) a current or previously held Beaver Valley Power Station Senior Reactor operator's license and five years of experience in the nuclear field or (2) at least 10 years of professional level experience in his field with at least 5 years of nuclear field experience to be substituted in lieu of a bachelor's degree.
The ability to add such an experienced operations or operations Support person to the Beaver Valley Power Station ISEG staff would be very valuable by enhancing the ISEG's knowledge level and insight into its evaluations.
This change would also provide an additional career path option for these personnel.
i
'AttOchm:nt B L
Proposed Technical Specification Change No. 28 Page 2 The criteria requiring a bachelor's degree used in Beaver Valley Unit 2
Technical Specification 6.2.3.2 stemmed from Section II.B.2.b of NUREG-0731 which stated " Qualification requirements for these individuals should be at a level generally comparable to that described in Section 4.2 of ANSI /ANS 3.1 (December 1979 draft),
i.e.,
a bachelor's degree in engineering with two to four years experience in their
- field, or equivalent as described in Section 4.1 of ANSI /ANS 3.1".
H 5ever, Section 4.1 of ANSI /ANS 3.1 (December 1979 draft) also states that " Individuals who do not possess the formal education requirements specified in this section shall not be automatically eliminated where other factors provide sufficient demonstration of their abilities.
These other factors should be evaluated on a case-by-case basis."
The level of training and knowledge needed to obtain a Senior Reactor Operator's license is well documented and known.
This change would provide the ability of the Beaver Valley ISEG to broaden its expertise with direct first-hand operations experience.
In
- addition, this change would require 5 years of professional level experience in the nuclear field which is above the current BVPS Specification criteria of two years experience and is in accordance with Section 4.7.2 of ANS 3.1-1981.
(Note that Beaver Valley remains committed to ANSI 18.1.1971).
A second option would substitute 10 years of professional level experience in his field with at least 5 years of which experience shall be in the nuclear field.
This option has already been approved at Millstone Unit 3.
This Specification change would limit the ISEG to a
maximum of two such substitutions in consideration of the NUREG-0731 criteria.
In
- summary, this change to Technical Specification 6.2.3.2 would provide the opportunity to significantly increase Beaver Valley's ISEG knowledge level and experience of nuclear power plant operation activities without suffering any discernable reduction in technical knowledge or skills.
Hence, if this option is used, it would significantly increase the quality and usefulness of ISEG evaluation recommendations.
I
T
. ?.
ATTACHMENT C No Significant Hr.zard Evaluation Proposed Technical' Specification Change Unit No. 2 - Chance No. 28 Basis for Proposed No Significant Hazards Consideration determination:
The Commission has provided standards for determining whether a
significant hazards consideration exists (10CFR50.92(c)).
A proposed amendment to an operating license for a
facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a
significant increase in the probability or consequences of an accident previously evaluated:
(2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a
i significant reduction in a margin of safety.
The proposed change does not involve a significant hazards consideration because; 1.
This change will not involve a significant increase in the probability or consequences of an accident previously evaluated since this change only addresses qualification requirements of an independent review group and has no change to any plant equipment or structures.
2.
This change would not create the possibility of a new or different kind of accident from any accident previously evaluated.
There would be no change to system configurations, plant equipment or analysis as a
result of this proposed amendmenc.
3.
This change would not involve a significant reduction in a margin of safety.
The proposed revised Technical Specification wil.!
substitute appropriate qualification criteria for an independent review group and thus will not alter any margin of safety.
Baspd on the above consideration, it is proposed to characterize the change as involving no significant hazards considerations.
_ _ _ _ _ - - _ -