ML20246N965

Application for Amend to License NPF-82,consisting of Change Application 1,revising Tech Specs to Remove Inconsistency in Plant Procedural Change Approval Process

ML20246N965
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	07/14/1989
From:	Leonard J LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20246N960	List: ML20246N965 ML20246N973 SNRC-1612, Forwards Application for Amend to License NPF-82,consisting of License Change Application 1,revising Tech Specs to Remove Inconsistency in Plant Procedural Change Approval Process Required by Specs.Fee Paid
References
NUDOCS 8907200075
Download: ML20246N965 (4)

Text

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I LONG ISLAND LIGHTING COMPANY

' Operating License NPF-82 Docket 50-322 License Change Application #1 This License. Change Application requests modification to Operating License NPF-82 for the Shoreham Nuclear Power Station

1. To remove an inconsistency in the Plant Procedure Change Approval process required by the Technical Specifications.

The request and supporting documentation is contained in Attachment 1 to this License Change Application.

Long Island Lighting Company By: \Jo  % .

n D. Leonard, Jr.

417h & A i Vi e President - Nuclear g/ ations C-

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Subscribed and sworn to before me this l4 day of duy 1989.

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W ggNewWsk Notary Publi o NM j GuestedinJuh h Empires SunalkCouner 31, M1* \

My Commission Expires: ) 'A )90 8907200075 890713 '

PDR ADOCK 05000322 P PDC

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n UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the' Matter of

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Long Island Lighting Company ) Docket No. 50-322

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SHOREHAM NUCLEAR POWER STATION - UNIT 1

' CERTIFICATE OF SERVICE I hereby' certify that copies of License Change Application #1 to the Operating License for Shoreham Nuclear Power Station Unit 1, dated have been served on the following by hand delivery or by deposit in the United States mail, first class, this day of ,,1989:

.Mr. Jay Dunkleberger New York State Energy Office 2 Rockefeller Plaza i Albany, New York 12223

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L. F. Britt, Manager Nuclear Licensing and Regulatory Affairs Subscribed and sworn to before me this N day of d w.9\ , 1989.

g A9 k Notary Public, t o((yg Notary Publ f Mad ,\ynrk OusilRedin suNok County 4 8b My Commission Expires 3 31 1@

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SNRC-1612 Attachment 1 Page 1 of 2 Attachment 1 To License Change Application #1 1.0 Description of Change This change deletes the phrase "...and shall be approved by the Plant Manager ..." in Technical Specification 6.8.2. The phrase requires that all new and revised procedures covered under Specification 6.8.1 be approved by the Plant Manager prior to implementation.

2.0 Reason for Change The requirement to be deleted is inconsistent with the remaining text of Specification 6.8.2 in that it prevents implementation of subsequent. statements in Specification

'6.8.2. Those statements identify specific activities from Specification 6.8.1 which require Plant Manager approval prior to implementation and allow app min.l' prior to implementation of other procedures of Specification 6.8.1 by the appropriate Division Manager or the Plant Manager. The inconsistency currently. requires Plant Manager approval of all Plant procedures identified in Specification 6.8.1 prior to implementation. The requested change will allow implementation of the subsequent statements in Specification 6.8.2 and relieve the Plant Manager of unnecessary administrative duties which his plant Division Managers are fully capable and qualified to perform.

3.0 Basis for No Significant Hazards Finding Section 13.1.3 of the Shoreham USAR identifies the minimum qualification requirements for station personnel. The various Division Managers have qualification and experience requirements which are very similar or in one case equivalent to those for Plant Manager. It is anticipated that they will obtain additional training and experience toward their further professional growth. As indicated in Appendix 13A of the Shoreham USAR, most of these Division Managers are or have been licensed or certified as Senior Reactor Operators.

In most cases, individual Division Manager qualifications substantially meet the minimum qualification requirements of the Plant Manager as stated in USAR Section 13.1.3. Those attributes not covered are compensated for by extensive experience in specific areas.

SNRC-1612 Attachment 1 Page 2 of 2 The logical basis for requiring the Plant Manager to approve all procedures prior to implementation is to ensure that overall plant impact-is considered from an adequate management, engineering and power plant experience base as well as for effectiveness in achieving its purpose. Based on a review of qualification requirements specifled in Shoreham USAR Section 13.1.3 and actual qualifications identified in USAR Appendix 13A, it is concluded that the proposed change does not reduce the effectiveness of the Specification.

The Commission has provided guidance concerning the application of standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are not likely tu involve significant hazards consideration. Example (i) relates to a purely administrative change to technical specifications such as a change to achieve consistency throughout the technical Specifications. In this case, the change relates to an inconsistency in administrative requirements.

Based on the following reasoning, LILCO has determined that the proposed change does not involve a significant hazards consideration because operation of Shoreham Nuclear Power Station - Unit 1, in accordance with this change, would not:

(1) Involve a significant increase in the probability or consequence of an accident previously evaluated. The change is not related to any accident analysis and does not affect the function or operation of any plant system or equipment.

(2) Create the possibility of an accident that is different than any already evaluated in the USAR. No physical alteration of plant configuration or changes to setpoints or operating param3ters are proposed. The changes does not affect the function or operation of any plant system or equipment.

(3) Involve a significant reduc' 1 in the margin of safety.

The reassignment of respons. 111 ties for procedure approvals is administrative in nature and is unrelated i to any margin of safety as defined in the bases for any technical specification.

4.0 Timing of Change {

Since all procedure changes must currently be approved by the Plant Manager prior to implementation, LILCO requests that NRC approval be granted on a high priority basis to relieve this unnecessary burden.

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