U-602139, Application for Amend to License NPF-62,changing TSs 6.2.3.1 Independent Safety Engineering Group (Iseg) Function, 6.2.3.4 Iseg Records, 6.4.1 Training, & 6.5.2.2 Nuclear Review & Audit Group (Nrag) Composition

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Application for Amend to License NPF-62,changing TSs 6.2.3.1 Independent Safety Engineering Group (Iseg) Function, 6.2.3.4 Iseg Records, 6.4.1 Training, & 6.5.2.2 Nuclear Review & Audit Group (Nrag) Composition
ML20045D554
Person / Time
Site: Clinton Constellation icon.png
Issue date: 06/18/1993
From: Jackie Cook
ILLINOIS POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20045D555 List:
References
JGC-2383-93, U-602139, NUDOCS 9306290130
Download: ML20045D554 (6)
v • d • e


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Ilknois Power Cornpany Chnton Power Station P.O. Box 678 Cknton. IL 61727 m 217 eressi JGC-2383-93 ILLIN@lS June 18, 1993 u-co2 39 POWER uv.93(o6. iate 8E.100a Docket No. 50-461 10CFR50.90 Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-62: Revision to Technical Specifications 6.2.3.1. 6.2.3.4. 6.4.1 and 6.5.2.2 (LS-93-004)

Dear Sir:

Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications, for Clinton Power Station (CPS). This request consists of proposed changes to Technical Specifications 6.2.3.1 " Independent Safety Engineering Group'(ISEG) Function," 6.2.3.4 "ISEG Records," 6.4.1 " Training," and 6.5.2.2 " Nuclear Review and Audit Group (NRAG) Composition." Most of the proposed editorial changes reflect or are prompted by recent administrative / organizational changes which have occurred at CPS, Also included is a proposed change to correct a particular position title from " Director-Nuclear Training" to " Director-Operations Training."

A description of the proposed changes and the associated justification (including the Basis For No Significant Hazards Consideration) are provided in Attachment 2.

Marked-up copies of the afTected pages from the current CPS Technical Specifications are provided in Attachment 3. In addition, an aflidavit supporting the facts set forth in this letter and its attachments is provided in Attachment 1.

IP has reviewed the proposed changes against the criteria of 10CFR51.22 for categorical exclusion from environmental impact considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase the amounts or

-change the types of efIluents that may be released off-site, nor do they significantly increase individual or cumulative occupational radiation exposures.-

Based on the foregoing, IP concludes the proposed changes meet the criteria given in -

10CFR51.22(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.

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John G. Cook, being first. duly sworn, deposes and says:. ThatLhe is' Vice'Pfesident of1

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I to U-602139 Ls-93-oo4 Page 1 of 3 Description ofProposed Changes In accordance with.10CFR50.90, the following' changes to the CPS Technical Specifications are being proposed:

1)

TS 6.2.3.1 and 6.2.3.4: The titles " Manager-Licensing and Safety" and " Director-Nuclear Safety" are being replaced with ' the title _ of

" Manager-Nuclear Assessment" to reflect the reassignment'of the Independent Safety Engineering Group (ISEG).

2)

TS 6.4.1: The position title " Director-Nuclear Traininj;" is being corrected to

" Director-Operations Training."

3)

TS 6.5.2.2: Within this section, the following sentence is being deleted: " Senior representatives from Nuclear Station Engineering, Quality Assurance, Plant Staff, Licensing and Safety, and Nuclear Training shall be members of the committee."

The proposed changes are reflected on the marked-up ~ copies o'f pages from the CPS Technical Specifications contained in Attachment 3.

Justification for Prooosed Changes As part of a reorganization effort at CPS, the Licensing and Safety department has been restmetured. The department title is_being revised from " Licensing and Safety" to.

" Licensing" as certain positions and/or functions within the department are being eliminated or relocated to other areas /depanments of the CPS organization; Pursuant to these changes, the positions of " Manager-Licensing and Safety".and " Director-Nuclear Safety" are being eliminated.

As an additional change resulting from the reorganization effort at CPS, the " Quality Assurance" department has been renamed the " Nuclear Assessment" depanment. This change in department name reflects an expansion in the scope and responsibilities of this department. The ISEG has been reassigned from the (former) Licensing and Safety department to the Nuclear Assessment department. The ISEG will thus now be reponing to the " Manager-Nuclear Assessment."

As a result of the above-described organizational changes, Technical Specifications 6.2.3.1 and 6.2.3.4 are being revised. As Technical Specification 6.2.3.1 describes the function of the ISEG and currently states that the ISEG "shall make........~. recommendations.'..... to the Manager-Licensing _and Safety, Director Nuclear Safety, and to members of the Nuclear Review and Audit Group (NRAG)" this Technical Specification is being revised to delete the references to the Manager-Licensing and Safety and the Director-Nuclear Safety and

to U-602139 LS-93-004 Page 2 of 3 -

replace these with a reference to the Manager-Nuclear Assessment. A similar change must be made to Technical Specification 6.2.3.4 as this specification similarly describes to whom records of activities performed by the ISEG must be forwarded (i.e., "to the~

Director-Nuclear Safety, Manager-Licensing and Safety and members of the NRAG").

As indicated previously, IP also proposes to revise Technical Specification 6.5.2.2 which describes the composition / membership of the Nuclear Review and Audit Group (NRAG).

Currently, this specification contains several sentences describing the NRAG membership:

1)

The NRAG, as a minimum, shall be composed of a Director and four members.

2)

Senior representatives from. Nuclear Station Engineering,. Quality l

Assurance, Plant Staff, Licensing and Safety, and Nuclear Training shall be members of the committee.

l 3)

Individuals filling positions as required by ANSI /ANS 3.1-1978, section 4.7.2, shall meet the education and experience requirements of the same section.

Due to the recent reorganization at CPS, IP recognized that the second sentence above requires revision due to the name changes in the departments of Licensing and Safety (now named Licensing) and Quality Assurance (now named Nuclear Assessment).. In lieu of simply changing these department names, it has been determined that this entire sentence should be deleted from Technical Specification 6.5.2. Removing this sentence would preclude the possibility of having to revise it again in the future if any other changes are made to the CPS organization or if department titles are simply changed.

IP does not feel that the sentence identified above is needed, from a Technical Specification point of view, to ensure the proper composition / membership.of the NRAG.~

Such a statement was not specified by the Standard Technical Specification, (NUREG-0123), and the remaining portion of CPS 6.5.2.2 (i.e., the first and third ' sentences above) is suflicient to describs the composition of the NRAG. The sentence to be deleted only provided additional detail which IP now feels is unnecessary. Further, the appropriate l

level of detail regarding the membership of the NRAG will_ continue to be specified in the -

l NRAG charter established by IP. The proposed change is only editorial in nature and will not impact the function or effectiveness of the NRAG.

As another part of this proposed editorial change package, a correction'to' Technical-Specification 6.4.1, " Training," is requested to correct the reference to a particular position title. Specifically, " Director-Nuclear Train ~mg" should be referred to as " Director-Operations Training " This change is not related to the current reorganization at CPS.'

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to U-602139 LS-93-004

-Page 3 of 3 This is an editorial change only and none of the current duties, responsibilities, or required qualifications for this position are affected by this change.

Basis for No Significant Hazards Consideration In accordance with 10CFR50.92, a proposed change to the Operating License (Technical Specifications) involves no significant hazards consideration if operation of the facility in accordance with the proposed change would not: (1) involve a significant increase in the probability or consequences of any acciden_t previously evaluated, or (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. The proposed changes are evaluated against each of these criteria below.

(1)

The proposed changes do not involve a significant increase in the probability or

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l consequences of any accident previously evaluated.

The proposed changes are of an administrative or editorial nature. : Since these are -

changes which do not impact plant design or operation, they cannot increase the probability or the consequences of any accident previously evaluated.

(2)

The proposed changes do not create the possibility of a new or_different kind of accident from any accident previously evaluated.

The proposed changes are editorial only and do not affect the plant design or operation. No new failure modes are introduced by changes of this nature, and as a result, the proposed changes cannot create the possibility of a new or different kind of accident from any accident previously evaluated.

-(3)

The proposed changes do not involve a significant reduction in a margin of safety.

The proposed changes only involve corrections to position titles or the removal of extraneous information. They do not alter the duties, responsibilitie~, or required '

s qualifications associated with the affected positions or the affected review groups

.(ISEG and'NRAG).' An equivalent level of safety and effectiveness is maintained, and, in addition, the proposed changes do not alter the plant design or operation..

As a result, the proposed changes cannot reduce a margin of safety.

Based upon the foregoing, IP concludes that this request does not involve a significant hazards consideration.

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