U-603097, Forwards Proposed Changes to CPS USAR & Operations Requirements Manual Which Will Impact Commitments Made in Plant QA Program Description.Licensee Concluded That Changes Constitute Reduction in Commitment & Require NRC Approval

Forwards Proposed Changes to CPS USAR & Operations Requirements Manual Which Will Impact Commitments Made in Plant QA Program Description.Licensee Concluded That Changes Constitute Reduction in Commitment & Require NRC Approval

ML20197G921
Person / Time
Site:	Clinton
Issue date:	12/04/1998
From:	Walter MacFarland ILLINOIS POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
U-603097, NUDOCS 9812110075
Download: ML20197G921 (11)

Text

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. Hhr.ois Power Company

, Chnton Power Station

. P.O. Box 678 Chnton. IL 61727 Tel 217 935-5623 Fax 217 935-4632 Walter G. MacFarland IV

" Senior Vice President and Chief Nuclear Officer ILLINSIS u.w3o,2 POWER a.no An unnova company December 4, 1998 l Docket No. 50-461 10CFR50.54(a)(3)

Document Control Desk Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Clinton Power Station Ouality Assurance Program Revision

Dear Madam or Sir:

Attached for NRC review and approval are proposed changes to the Clinton Power Station (CPS) Updated Safety Analysis Report (USAR) and Operations Requirements Manual (ORM) which will impact commitments made in the CPS Quality Assurance Program Description (QAPD). These changes concern the procedure approval process at CPS.

Currently, per USAR section 13.5.1.2 and ORM sections 6.5.3.1,6.8.2, and 6.8.3, the Manager-Clinton Power Station provides final approval for changes to and initial issue of all station administrative procedures, safety-related procedures, and all procedere changes which require the completion of a 10CFR50.59 safety eveluation.

Illinois Power is proposing to allow the final approval of safety-related procedures and changes to these procedures be performed by the applicable Department Head / Designee. By delegating the approval of these procedures to the appropriate level ofmanagement, the Manager-CPS will be able to focus his attention on the station

()I administrative procedures and those procedures, or procedure changes, which require a 10CFR50.59 safety evaluation.

This change will affect the Updated Safety Analysis Report (USAR) section h) 13.5.1.2 and the Operational Requirements Manual (ORM) sections 6.5.3.1, 6.8.2, and 6.8.3. The attachment to this letter identifies the specific USAR and ORM changes Illinois Poweris proposing.

9812110075 991204 k PDR ADOCK 05000461 (

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Per USAR section 1.8, CPS complies with the requirements of Regulatory Guide (RG) 1.33, Rev. 2 (February 1978)" Quality Assurance Program Requirements l (Operation)," with exceptions as noted. RG 1.33 endorses American National Standards l Institute (ANSI) Standard N18.7-1976/ANS-3.2, " Administrative Controls and Quality Assurance for the Operational Phase ofNuclear Power Plants." Pertaining to the approval of procedures, ANSI N18.7-1976/ANS-3.2, section 5.2.15, " Review Approval and l

Control of Procedures," requires in part that:

l 1). " Procedures shall be approved as designated by the owner organization before initial use."

2). " Rules shall be established which clearly delineate the review of procedures by l knowledgeable personnel other than the originator and the approval of procedures ,

I and procedure changes by authorized individuals."

i 3). " Changes to documents shall be reviewed and approved by the same organization that performs the original review and approval unless the owner organization designates another qualified organization".

l IP has evaluated the proposed changes to the CPS procedure approval process against the procedure approval process as stated in ANSI N18.7-1976/ANS-3.2. This evaluation has concluded that the CPS proposed procedure approval process meets t'.e requirements as stated in ANSI N18.7-1976/ANS-3.2, section 5.2.15.

! Implementation of the proposed method for approval of procedures at CPS will not affect IP's ability to comply with 10CFR50, Appendix B, criteria or other previously accepted Quality Assurance Program Description commitments contained in the CPS USAR.

Illinois Power has evaluated these proposed changes and has concluded that the changes constitute a reduction in commitment to the previously approved CPS Quality Assurance Program Description (QAPD). Therefore, these changes require NRC approval prior to implementation.

l Illinois Power requests approval of the proposed changes within sixty (60) days as provided in 10 CFR 50.54(a)(3)(iv).

Sincerely yours, V$ -

Walter G. MacFarland, IV l, Senior Vice President and ChiefNuclear Officer i

! MEM/krk

U-603097

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Attachment:

Affected USAR and ORM pages

! cc: NRC Clinton Licensing Project Manager l NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety l \

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CPS-USAR Revision 8 December 1997 13.5.1.2 Preparation of Procedures Proced0res needed for fuel loading shall be written by the plant staff or consultants prior to fuel loading. Procedures required for plant operations under normal and emergency conditions shall be written by the plant staff or consultants, to the extent practical, for use during the initial plant testing phase to allow for correction prior to fuel loading and for use in the plant operator training program. The responsibility for writing and preparing plant procedures is assigned to the appropriate members of the plant staff as indicated in Table 13.5-1. ,

Administrative procedures and procedures requiring a safety evaluation are reviewed by the FRG and approved by the Manager-Clinton Power Station prior to implementation.

Safety-related procedures are approved by the Manager-Clinton Power Station prior to implementation. They are reviewed periodically as set forth in Administrative Procedures.

Temporary changes to procedures which clearly do not change the intent of the approved procedure shall, as a minimum, be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. At least one of the two members of plant management staff shall hold a Senior Reactor Operator's license or prior to personnel being licensed, shall be certified on the unit affected. Section 13.4 defineu types of procedures requiring FRG review.

Appropriate plant management shall approvc all permanent and temporary procedures in accordance with Administrative Procedure requirements. Distribution of the CPS Operating Manual and portions thereof shall be controlled as prescribed in appropriate Administrative Procedures. Subsequent revisions, changes or temporary changes shall be controlled in accordance with the Administrative Procedures and as prescribed by the Technical Specifications and the Operational Requirements Manual (ORM).

Changes which conflict with the intent of the Operating License and/or the Technical Specifications or involve an unreviewed safety question shall be made only with the review of the FRG and the NRAG and authorization from the Nuclear Regulatory Commission.

13.5.1.3 Procedures Administrative Procedures which consist of Plant Management Procedures (PMP's), Department Administrative Procedures, and Plant Management Special Procedures define the responsibilities, I methodology, and procedural actions required to assure that the plant shall be managed in a safe and dependable manner. They include basic guidelines and controls for efficient dissemination of information and direction to plant personnel and describe the interfaces with external organizations. Plant procedures describe the method by which operating experience information is disseminated to plant personnel.

00 13.5-2

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CPS-USAR Revision 8 December 1997 13.5.1.2 Precaration of Procedures Proced'ures needed for fuel loading shall be written by the plant staff or consultants prior to fuel loading. Procedures required for plant operations under normal and emergency conditions shall be written by the plant staff or consultants, to the extent practical, for use during the initial plant testing phase to allow for correction prior to fuel loading and for use in the plant operator training program. The responsibility for writing and preparing plant procedures is assigned to the appropriate members of the plant staff as indicated in Table 13.5-1.

Administrative procedures and procedures requiring a safety evaluation are reviewed by the FRG and approved by the Manager-Clinton Power Station prior to implementation.

Safety-related procedures are approved by the applicable Department Head / Designee"anagcr Clinton rowcr Station prior to implementation. They are reviewed periodically as set forth in Administrative Procedures. Temporary changes to procedures which clearly do not change the intent of the approved procedure shall, as a minimum, be approved by two members of the plant staff knowledgeable in the areas affected by the procedure. At least one of the two members of plant management staff shall hold a Senior Reactor Operator's license or prior to personnel being licensed, shall be certified on the unit affected. Section 13.4 defines types of procedures requiring FRG review.

Appropriate plant management shall approve all permanent and temporary procedures in accordance with Administrative Procedure requirements. Distribution of the CPS Operating Manual and portions thereof shall be controlled as prescribed in appropriate Administrative Procedures. Subsequent revisions, changes or temporary changes shall be controlled in accordance with the Administrative Procedures and as prescribed by the Technical Specifications and the Operational Requirements Manual (ORM).

Changes which conflict with the intent of the Operating License and/or the Technical Specifications or involve an unreviewed safety question shall be made only with the review of the FRG and the NRAG and authorization from the Nuclear Regulatory Commission.

13.5.1.3 Procedures Administrative Procedures which consist of Plant Management Procedures ( PMP s ) , Department Administrative Procedures, and Plant Management Special Procedures define the responsibilities, methodology, and procedural actions required to assure that the plant shall be managed in a safe and dependable manner. They include basic guidelines and controls for efficient dissemination of information and direction to plant personnel and describe the interfaces with external organizations. Plant procedures describe the method by which operating experience information is disseminated to plant personnel.

f 13.5-2

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OPERATIONAL REQUIREMENTS MANUAL (ORM) 6.5.3 TECHNICAL REVIEW AND CONTROL ACTIVITIES Procedures required by Technical Specification 5.4.1 and ORM 6.8 and other. procedures which affect plant nuclear safety as determined by the Manager-Clinton Power Station or the responsible snanager* and changes thereto, other than editorial or typographical changes, shall be reviewed as follows: . .

6.5.3.1 TECHNICAL REVTEW l .

a. Each such procedure or procedure change shall be independently reviewed by an individual knowledgeable in-the area affected other than 4 l

the individual who prepared the procedure, or procedure change. The l Manager Clinton Power Station or the responsible manager

• shall prior

, , to Wian approve all plantprocedures and changes.thereto.

b. Individuals ig-:=='le for reviews performed in accordance with Item 6.5.3.1.a above shall be dia==*~t by the Manager-Clinton Power '

Station or the responsible manager *. Each such review shall include a determination ofwhether or not ad4tian*1. cross disciplinary, review is

, A -:===-y. Ifdeemed ery, such review shallbe performed by.the review personnel of the appropriatediscipline.

i Individuals performing these reviews'shall'meet or exceed the qualifications stated in ANSUANS 3.1-1978 for the appropriate discipline '

c. When required by 10 CFR 50.59, a safety evnination to determine whether or not an unreviewed safety question is involved shall be included in the procedure or the procedure change review. Ifit is det,ermirwt that an nr.rdd safety questionis not involved, a -

written safety evaluation to support that decision will be prepared and

, submitted to the PRG for review. P=w==t to 10 CFR 50.59, NRC i

approval ofitems involving unreviewed safety questions shall be obtained prior to the Manager.dictan Power Station approval for implementation.

d. Written records of reviews performed in accordance with Item ,

.6.5.3.1.a above, including recommentiations for approval or disapproval, shall be prepared and maintained.

[* The responsible. manager must be the equivalent of t'he,' Manager - Clinton Power Station 3 with respect to his/her level ofresponsibility within the corporate structure.]

t 98 Rev.7 Date: 01/16/96

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OPERATIONAL REQUIREMENTS MANUAL (ORM) 3

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6.5.3 TECHNICAL REVIEW AND CONTROL -

ACTIVITIES Procedures required by Technical Specification 5.4.1 and ORM 6.8 and other procedures which affect plant nuclear safety as determined by the Manager-Clinton Power Station or the responsible .

manager

• and changes thereto, other than editorial or typographical changes, shall be reviewed as follows:

j 6.5.3.1 TECHNICAL REVIEW l l

l l a. Each such procedure or procedure change shall be independently reviewed by j an individual knowledgeable in the area affected other than the individual who i prepared the procedure, or procedure change. The applicable Department i Head / Designee shall approve all plant ),rocedures and changes thereto, prior to implementation.

b. Individuals responsible for reviews perfonned in accordance with Item 6.5.3.1.a above shall be designated by the Manager-Clinton Power Station or the responsible manager *. Each such review shall include a determination of whether or not additional, cross-disciplinary, review is necessary. Ifdeemed necessary, such review shall be p'e rformed by the review personnel of the appropriate discipline.

Individuals performing these reviews shall meet or exceed the qualifications stated in ANSI /ANS 3.1-1978 for the appropriate discipline.

c. When required by 10 CFR 50.59, a safety evaluation to detennine whether or not an unreviewed safety question is involved shall be included in the procedure or the procedure change review. Ifit is determined that an unreviewed safety question is not involved, a written safety evaluation to support that decision will be prepared and submitted to the FRG for review.

Pursuant to 10 CFR 50.59, NRC approval ofitems involving unreviewed safety questions shall be obtained prior to the Manager-Clinton Power Station approval forimplementation.

d. Written records of reviews perfonned in accordance with Item 6.5.3.1.a above, including recommendations for approval or disapproval, shall be prepared and maintained.

[* The responsible manager must be the equivalent of the Manager - Clinton Power Station with respect to his/her level of responsibility within the corporate structure.]

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• l OPERATIONAL REQUIREMENTS MANUAL (ORM) .

6.8 PROCEDURES AND PROGRAMS (- ,

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PROCEDURES ]

1 6.8.1 Written procedures shall be established, implemented, and maintained covering the  ;

i activities referenced below;

a. Refueling operations;

b. Surveillance and test activities ofsafety-related equipment;

c. Security Plan implementation;

d. Emergency Plan implementation;

e. Fire Protection Program implementation;

f. Process Control Program implementation; and

g. Offsite Dose Calculation Manual implementation. l

. 1 REVIEW AND APPROVAL / '

6.8.2 Each procedure ofTechnical Specification 5.4.1 and Operational Requirement 6.8.1 and changes thereto, shall be reviewed in accordance with Operational Requirements 6.5.1.6 and 6.5.3 as appropriate and shall be approved by the Manager-Clinton Power Station or the responsible manager

• prior to implementation and reviewed periodically as set forth in administrative procedures.

[*The responsible manager must be the equivalent of the Manager-Clinton Power Station with respect to their level of responsibility within the corporate structure.)

TEMPORARY CITANGES 6.8.3 ' Temporary changes to procedures ofTechnical Specification 5.4.1 and Operational Requirement 6.8.( may be made provided:

a. The intent of the original procedure is not altered; j* b. The change is approved by two members of the unit management stafE at least l- one of whom holds a Senior Operator license on the unit affected; and 102 Rev.5 Date: 06/20/95 l

>;ew..,. --.L, OPERATIONAL REQUIREMENTS MANUAL (ORM) l 6.8 PROCEDURES AND PROGRAMS )

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PROCEDURES 1 l 6.8.1 Written procedures shall be established, implemented, and maintained covering the

! activities referenced below;

a. Refueling operations; i

l b. Surveillance and test activities of safety-related equipment;

c. Security Plan implementation; i

1 p . d. Emergency Planimplementation; j l

e. Fire Protection Program implementation; i f. Process Control Program implementation; and

g. Offsite Dose Calculation Manual implenientation.

l REVIEW AND APPROVAL l

6.8.2 Each procedure ofTechnical Specification 5.4.1 and Operational Requirement 6.8.1 l- and changes thereto, shall be reviewed in accordance with Operational Requirements 6.5.1.6 and 6.5.3 as applicable and shall be approved by the applicable Department Head / Designee prior to implementation and reviewed periodically as set forth in administrative procedures.

i TEMPORARY CHANGES 6.8.3 Temporary changes to procedures of Technical Speci6 cation 5.4.1 and Operational Requirement 6.8.1 may be made provided:

. a. - The intent of the original procedure is not altered;  ;

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b. The change is approved by two members of the unit management staff, at least  :

one ofwhom holds a Senior Operator license on the unit affected; and i 103 Rev.5 Date: 06/20/95

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l OPERATIONAL REQUIREMENTS MANUAL (ORM) j/ -

6.8 PROCEDURES AND PROGRAMS (continued) l' l c. The change is documented, reviewed in accordance with Operational l l Requirements 6.5.1.6 and 6.5.3 as appropriate, and approved by the Manager-Clinton Power Station or the responsible manager

• within 14 days of implementation.

[*The responsible manager must be the equivalent of the Manager-Clinton Power Station with respect to their level of responsibility within the corporate structure.]

l l 6.8.4 The following programs shall be established, implemented, and maintained:

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a. In-Plant Radiation Monitoring l

t j ' A program which will ensure the capability to accurately determine the

{ airborne iodine concentration in vital areas under accident conditions. This program shall include the following:

1. Training ofpersonnel,

! 2. Procedures for monitoring, and j 3. Provisions for maintenance of sampling and analysis equipment.

b. Fire Protection Program l

A program to implement and maintain in effect all provisions of the approved l

fire protection program as described in the Updated Safety Analysis Report as

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amended, and as approved in the Safety Evaluation Report (NUREG-0853) l dated February 1982 as supplemented. Noncompliance with the above Fire Protection Systems described in plant procedure CPS No. 1893.01 shall be reported in accordance with Operational Requirement 6.6.1. I

c. Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and l- modeling of environmental exposure pathways. The program shall (1) be i

contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR L Part 50, and (3) include the following:

1I 103 Rev.5 Date: 06/20/95

.' OPERATIONAL REQUIREMENTS MANUAL (ORM) l 6.8 PROCEDURES AND PROGRAMS (continued)

c. - The change is documented, reviewed in accordance with Operational l Requirements 6.5.1.6 and 6.5.3 as appropriate, and approved by the applicable Department Head / Designee within 14 days ofimplementation.

6.8.4 The following programs shall be established, implemented, and maintained:

a. In-Plant Radiation Monitoring A program which will ensure the capability to accurately determine the airborne iodine concentration in vital areas under accident conditions. This program shall include the following:  ;

1. Training of perr.onnel,

2. Procedures for monitoring, and

3. Provisions for maintenance of sampling and analysis equipment,

b. Fire Protection Program A program to implement and maintain in effect all provisions of the approved fire protection program as described in the Updated Safety Analysis Report as amended, and as approved in the Safety Evaluation Report (NUREG-0853) dated February 1982 as supplemented. Noncompliance with the above Fire Protection Systems described in plant procedure CPS No. 1893.01 shall be reported in accordance with Operational Requirement 6.6.1.

c. Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

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104 Rev.5 Date: 06/20/95

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