PY-CEI-NRR-0823, Application for Amend to License NPF-58,revising Tech Specs Administrative Controls Section,Clarifying Wording in Sections 1.0 & 6.8.4.a,correcting Typos in Sections 4.7.7.1 & 4.8.1.1.2.e.2 & Deleting Footnotes.Fee Paid

Application for Amend to License NPF-58,revising Tech Specs Administrative Controls Section,Clarifying Wording in Sections 1.0 & 6.8.4.a,correcting Typos in Sections 4.7.7.1 & 4.8.1.1.2.e.2 & Deleting Footnotes.Fee Paid

ML20151C398
Person / Time
Site:	Perry
Issue date:	04/08/1988
From:	Kaplan A CLEVELAND ELECTRIC ILLUMINATING CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20151C402	List: ML20151C409 PY-CEI-NRR-0823, Application for Amend to License NPF-58,revising Tech Specs Administrative Controls Section,Clarifying Wording in Sections 1.0 & 6.8.4.a,correcting Typos in Sections 4.7.7.1 & 4.8.1.1.2.e.2 & Deleting Footnotes.Fee Paid
References
PY-CEI-NRR-0823, PY-CEI-NRR-823, NUDOCS 8804120420
Download: ML20151C398 (9)

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TliE C L EV E L A N D E L E CT RIC IL L U MIN ATIN G C O M P A N Y PO BOX 97 e PERRY, OHIO 44081 e TELEPHONE (216) 259-0737 m ADDR E S S - 10 CENTER ROAD Serving The Best Location in the Nation PERRY NUCLEAR POWER PLANT Al Kaplan April 3, 1988 m ensiocnr PY-CEI/NRR-Od23 L NUCLEAR GAOUP U.S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Perry Nuclear Power Plant Docket No. 50-440 Technical Specification Change Request; Administrative Controls and Definitioy Gentlemen:

The Cleveland Electric Illuminating Company (CEI) hereby requests amendment of Facility Operating License NPF-58 f or the Perry Nuclear Power Plant, Unit 1.

In accordance with the requirements of 10 C/R 170.12 a check in the amount of

$150.00 is enclosed. In accordance with the requirements of 10 CFR 50.91(b)(1), a copy of this request for amendment has been sent to the State of Ohio as indicated below.

This amendment tequests miscellaneous administrative changes to the Technical Specifications, inclading revisione to the Administ rativa Controls section, wording clarifications in Sections 1.0 and 6.8.4.a. correction of typographical e rrors *.n sections 4.7.7.1 and 4.8,1,1.!.e.2, and deletion of several footnotes that are no .1.onge: applicable. It also includes the rieletion of the Organizatiort Charts per the guidelines given f .1 Generic Letter 83-06.

Attachment 1 provides the Summary, Significant Hozarils and Environmentd Impact Considerations. Attachment 2 is a copy of the .ouked up Technical Specification pages.

Should you have any questions, please call.

Very truly ours,

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$<(. J Al Kaplan Vice President Nuclear Group AK: cab At tachme n t s cc: K. Connaughton T. Colburn y' /g J. Harris (State of Ohio) 'J 7,.

U.S. NRC Region III 8 g

8804120420 880408 PDR ADOCK 05000440 P DCD

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Attachment 1 i PY-CEI/NRR-0823 L )

Page 1 of 4 Summary / Safety Analysis l

On December 28, 1987 CEI submitted a letter PY-CEI/NRR-0761 L indicating that ,

various Organizational titles had changed, and that the Technical l Specifications vould be revised during a subsequent Technical Specification change. The major portion of this change request is modifying Section 6 titles to come into conformance with the present organizational titles. No reduction in review or approval responsibilities have been requested via these title changes.

Numerous other administrative changes are also being requested. A brief description of each change is presented in Enclosure (1). An analysis of each general type is given below.

The Definition on page 1-7 and in section 6.6.1.a is being revised to clarify the definition of REPORTABLE EVENT making it consistent with the requirements of Generic Letter 83-43 dated December 19, 1983.

Technical Specification Surveillance Requirement 4.6.1.2.f is being revised to delete the footnote accompanying this surveillance requirement. The footnote was added in Amendment 5 to defer testing on HSIV's IB21-F022A and 1B21-F028A.

The exception expired on July 12, 1987, and is no longer applicable.

Technical Specification 3.7.3 is being modified to delete footnotes added in Amendment 1 and 4. These footnotes permitted continued operation with the automatic opening function of the RCIC injection valve disabled under certain plant ronditions. The footnotes are no longer applicable, and are therefore being deleted.

A typographical error in Technical Specification surveillance requirement 4.7.7.1.b.1 is being corrected. The surveillance requirements apply to Fuel Handling Building subsystems; this is correctly reflected throughout 4.7.7.1 except for a single reference,which states "system" rather than "subsystem".

Two more typographical errors are being corrected in Technical Specification surveillance requirement 4.8.1.1.2.e.2. First the load corresponding to one RHR pump for Division 1 is being corrected from 725 kw to 729 kv. The other correction is to the load corresponding to the HPCS pump on the Division 3 diesel generator. It is being changed from 2200 kw to 2400 kv. Surveillance Test data taken per 4.8.1.1.2.e verifies that the diesel generators have met

the proposed requirements for 4.8.1.1.2.e.2 vith the corrected loading values.

1 The sixth proposed change is a deletion of the organizational charts (Figure 6.2.1-1 and 6.2.2-1), and the addition of statements in Sections 6.2.1 to compensate for the organization chart deletions. These changes meet all the guidance set forth in Generic Letter 88-06. The Generic Letter noted that proposed license amendments conforming to the guidance in the Letter vill be reviewed and approved without need for a detailed review.

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Attachment 1 PY-CLI/NRR-0823 L Page 2 of 4 The next change is to delete the exception to Section 6.3.1 for the Senior Operations Coordinator. The person presently filling.this position meets the minimum qualifications of ANSI 18.1-1971 for comparable positions so this exception is no longer required.

Technical Specification 6.5.1.2, 6.5.1.3, and 6.5.1.5 have been revised as follows:

a) The PORC membership is being changed, for the following reasons:

1) The General Manager, Perry Plant Operations Department (PPOD) and the '

Director, Perry Plant Technical Department (PPTD) are being removed as PORC members / chairman /vice-chairman. The function of PORC is to advise the General Manager, (PPOD) and the Director, (PPTD). It is felt that this role can better be performed if these two positions are not also major contributors to PORC itself.

2) The Technical Superintendent PPTD has been assigned as the PORC Chairman, replacing the General Manager, PPOD.

3) The Manager, Operations Section has been elevated to Vice Chairman / member. This is to give some flexibility so that PORC meetings can occur in the absence of the Technical Superintendent, PPTD.

4) The Principal Nuclear Operations Engineer is being removed as a Vice Chairman / member. The Principal Nuclear Operations Engineer is presently functioning as the NSRC Chairman. It is felt that it is inappropriate for the same person to act as PORC Vice Chairman, and NSRC Chairman.

5) The Manager, Outage Planning Section is being removed. The remaining PORC members have an adequate knowledge of the various aspects of i Nuclear Pover Plant operations and therefore this position is not required. '

b) Due to the deletion of the various titles above, the definition of QUORUM in 6.5.1.5 is being changed to require the Chairman or his designated alternate and at least four members including alternates. Since the Quorum has been reduced, the number of Alternates permitted by 6.5.1.3 has been reduct-d to no more than 2. This vill maintain the present condition that there is always at least a majority at each PORC meeting who are permanent PORC members, c) Changes are being made to Technical Specifications 6.5.1.6.h, 6.5.1.6.1, 6.5.1.6n and 6.5.3.1.f to make these sections consistent with the Technical Specification required responsibilities of the NSRC described in Technical Specification section 6.5.2.7.

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Attachment PY-CEI/NRR-0823 L Page 3 of 4 The next change moved the requirements for approval of temporary procedure changes from Technical Specification section 6.5.3.la into a new section 6.8.3.

This is to improve the readability of Section 6.5.3.la, and also results in making the Technical Specifications more consistent with Standard Technical Specifications. Based on this new addition the old section 6.8.3 has been renumbered as 6.8.4.

The final change is a clarification to the systems addressed in Technical Specification 6.8.4.a. the "CS" is being deleted and the words "the hydrogen analyzer portion of Combustible Gas Control" is being added. This is to clarify what "CS" meant. This is consistent with the present wording in the FSAR Appendix 1A Item III.D.l.1, and the wording in Supplement 0 to the Perry Nuclear Pover Plant Safety Evaluation Report Section 11.5.

None of the above changes vould result in a reduction in safety. They are administrative in nature, and with the exception of tha reorganization of the PORC membership, are not significant. The PORC reorganization vill create a truly advisory review committee, to review safety issues and report their recommendations to the General Manager, PP0D and Director, PPTD. CEI feels this vill increase overall plant safety by having the PORC and the General Manager PP0D/ Director PPTD independently review and conclude on safety issues.

4 Significant Hazards Analysis The standards used to arrive at a determination that a request for amendment requires no significant hazards consideration are included in the Commission's Regulations, 10 CFR 50.92, which state that the operation of the facility in accordance with the proposed amendment vould 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 significant reduction in a margin of safety. CEI has reviewed the proposed change with respect to these three factors.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evnluated.

The proposed changes as described above are administrative and as such can not involve a significant increase in the probability or consequence of an accident previously evaluated. The only non-administrative change is the reorganization of the PORC membership. The function of PORC remains the same; to advise the General Manager, PP0D and Director, PPTD on matters relating to safety. By creating a PORC independent from the General Manager, PPOD/ Director, PPTD, the Committee's ability to carry out its function should be enhanced. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed changes does not create the possibility of a new or different kind of accident.

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Attachment 1 PY-CEI/NRR-0823 L Page 4 of 4 As stated above, most of the proposed changes are administrative changes which do not create the possibility of any new accident. The proposed changes to PORC memberships also can not create the possibility of a new or different kind of accident since the overall function of PORC remains the same.

The proposed change does not involve a significant reduction in the margin of

< safety.

The majority of these changes are administrative in nature, and as such involve no reduction in the margin of safety. The reorganization of PORC membership should enhance safety by. creating a truly independent safety review committee to advise the plant management. Thus, there is not a significant reduction in the margin of safety.

Therefore, CEI has concluded that this proposed amendment involves no significant hazards considerations.

Environmental Impact The Cleveland Electric Illuminating Company has reviewed the proposed Technical Specification change against the criteria of 10 CFR 51.22 for environmental considerations. As shown above, the proposed change does not involve a significant hazards consideration, nor increase the types and amount of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, CEI concludes that the proposed Technical Specificatian ch ange meets the criteria given in 10 CFR 51.22(c)(9) for a categcrical exclusion from the requirement for an Environmental Impact Statement.

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Enclosure PY-CEI/NRR-0823 L Page 1 of 4 TECHNICAL SPECIFICATION PAGE CHANGE REASON 1-7 Delete reference to 10 Hake Specifications CFR 50.72 consistent with Generic Letter 83-43 3/4 6-5 Delete ** from 4.6.1.2.f This footnote expired

, and delete footnote ** at July 12, 1987 bottom of the page 3/4 7-6 Deletion of # sign and Footnote no longer accompanying footnote applicable 3/4 7-6a Deletion of entire page Note no longer applicable 3/4 7-17 Change surveillance To correct designation requirement 4.7.7.1.b.1 and make it consistent wording from system to with rest of the LCO to subsystem 3.7.7.1/4.7.7.1 3/4 8-5 Change surveillance Correct typographical requirement 4.8.1.1.2.e.2 error from 725 kv to 729 kv 3/4 8-6 Change surveillance Correct typographical 4.8.1.1.2.e.2 from 2200 kv error to 2400 kw 6-1 Change Manager to General Title Change Manager Delete references in 6.2.1 To comply with Generic and 6.2.2 to organization letter 88-06 guidance charts (Figures 6.2.1-1 and for deletion of 6.2.2-1) Add 6.2.la.b,c and organization charts d statements 6-3 Delete figure 6.2.1-1 To incorporate guidance of Generic Letter 88-06 6-4 and 6-5 Delete figure 6.2.2-1 To incorporate guidance of Generic Letter 88-06.

6-7 Section 6.2.3.1 changed Title change Manager to Director Section 6.2.3.4 changed Title change Manager to Director

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Enclosure PY-CEI/NRR-0823 L Page 2 of 4 TECHNICAL SPECIFICATION PAGE CHANGE REASON Deleted the exception for Person holding job the Senior Operations meets qualifications Coordinator to meet the minimum qualifications of ANSI N18.1-1971 for first cycle.

6-8 Section 6.4.1 changed Title change General Supervisor to Manager Section 6.5.1.1 changed Title change Managers to General Manager PPOD and Director PPTD Section 6.5.1.2 changed PORC composition by a) Deleting General Manager To make PORC PP0D/ Director PPTD, independent from NSRC Principal Nuclear and from General Engineer and Manager Manager / Director Outage Planning b) Establishing Technical Needed Chairman Superintendent as Chairman c) Establishing Manager, Alternate Chairman Operations Sectiun as Vice-Chairman / member d) Changing titles from Title change General Supervisor /

General Supervising Engineer to Manager Section 6.5.1.3 changed Reduction in PORC number of alternates membership requires from 3 to 2 similar reduction in Alternates 6-9 Section 6.5.1.5 reduced Reduction in PORC Ouorum from six to four membership requires (plus the Chairman) similar reduction in Quorum

Enclosure PY-CEI/NRR-0823 L Page 3 of 4 TECHNICAL SPECIFICATION PAGE CHANGE REASON Section 6.5.1.6h, i, & a There is no deleted requirement to accompanying send these changes to requirement for NSRC NSRC to review these changes Section 6.5.1.6k changed Title changes Manager to General Manager /

Director 6-10 Section 6.5.1.7a changed Title changes Managers to General Manager /

Director Section 6.5.1.7c changed Title change Manager to General Manager 6-14 Section 6.5.3.las a) Changed Managers to "both Title changes the General Manager PPOD and the Director PPTD" b) Deleted last 4 sentences Hoved these of paragraph requirements into a new Section 6.8.3 Section 6.5.3.lb changed Title change Manager NED to Director s

NED and changed managers IPD to "both the General Manager PPOD/ Directer PPID"

' action 6.5.3.1c changed Title change fianagers PPD to "both the General Manager PP0D/

Director PPTD" 6-15 Section 6.5.3.1d changed Title change appropriate Manager PPD to "General Manager PP0D or the Director PPTD as appropriate" Section 6.5.3.lf:

(a) Changed Manager to Title change Director in line 4 and 6

Enclosura PY-CEI/NRR-0823 L Page 4 of 4 TECHNICAL SPECIFICATION-PAGE CHANGE REASON (b) Deleted "and 6.5.2.7" on There is no line 6. accompanying

-Technical Specification requirement in section 6.5.2.7 for NSRC to review these changes (c) Added General Manager, Add additional Perry Plant Operations Technical Specification Department to line 6. requirement to have General Manager,.PP0D approve Security Plan and Emergency Plan Section 6.6.la delete To clarify "pursuant to the require- requirements and ments of Section 50.72 make them to 10 CFR Part 50" consistent with Generic Letter 83-43 6-16 Section 6.8.2 changed Title change Managers PPD to "General Manager PPOD and the Director, PPTD Inserted new section 6.8.3 Reorganized section to dealing with Temporary make it conform more changes that was deleted closely with standard from Section 6.5.3.la. No Technical Specifications change was made to the vording.

Renumbered old 6.8.3 to Due to inserting of nev 6.8.4 6.8.3 6.8.4a deleted "CS" and This is to clarify what added "the hydrogea "CS" meant as identified

, analyzer portion of in FSAR Appendix 1A Item Combustible Gas Control" III.D.1.1 and SER Supplement 8 Section 11.5