ML17228A316

Proposed Tech Specs 6.5.2.9, Technical Review Responsibilities.

ML17228A316
Person / Time
Site:	Saint Lucie
Issue date:	09/23/1993
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17228A315	List: ML17228A314 ML17228A316
References
NUDOCS 9309300013
Download: ML17228A316 (11)

Text

St. 'Lucie Unit 2

'ocket. No. 50-389 Proposed License Amendment Technical Review Res onsibilities ATTACHMENT 1 ST LUCIE UNIT 2 MARKED-UP TECHNICAL SPECIFICATION PAGES Page 6-6 Page 6-12

( 9309300013 930923 PDR ADOCK 05000389 PDR

ADMINISTRATIVE CONTROLS

. ~ NDEPENBE~AFH~CRHKR-NG-GR8UP-QS FUNCTION

.3.1 The ISEG shall function to examine plant operating characteristi suances, industry advisories, Licensee Event Reports and other so es N

of p design and operating experience information, including plant f simi la sign, which may indicate areas for improving plant safet .

COMPOS ITIO 6.2.3.2 hall of five dedicated, ful ime members with-The I i

be composed v~ied backgroun gd disciplines related to nuclear py plants. Three .or more of the members h 11 be engineers with a bachelo egree in engineering or a related science, with least 2 years of professioy level experience in-the nuclear field. Any nond reed ISEG members will er be licensed as a Reactor Operator or Senior Reacto 0 erator, or will hy, een previously licensed as a

~

Reactor Operator or Senior a tor Oper r yi'n

's the last year at the St. Lucie of a department head as specified Plant site; or they will meet qu c' in Specification 6.3.1 of the S . e Technical Specifications. The qualifications of each nondeg d i for the ISEG shall be approved by the Chairman, Company Nuclear Re iew NRB) prior to joining the group.

RESPONSIBILITIES 6.2.3.3 The ISEG shall b sible for ma aining survei 1 lance of selected plant activities to provjd independent verific n* that these activities are performed correctly andi at human errors are re as much as practical; The ISEG shall make detail recommendations for revise ocedures, equipment modifi-cations, maintena e activities, operations activitie r other means of improving plant safety to t'hairman, CNRB.

AUTHORITY 6.2.3.$ e ISEG is an onsite independent technical review grou at reports offs't to the Chairman, CNRB. The ISEG shall have the authority ssary to pe m the functions and responsibilities as delineated above; CORDS 6.2.3.5 Records of activities performed by the ISEG shall be=prepared, maint d and a ort ctivities forwarded each calendar month to the Chairman, C LAc 6.2. HIFT TECHNICAL ADVISOR The Shift Technical Advisor, function is to provide on shift advisory technical support in the areas of thermal hydraulics, reactor engineering, and plant.

analysis. with regard to the safe operation of the unit.

6.3 UNIT STAFF VALIF ICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifica-tions of ANSI/ANS-3.1-1978 as endorsed by Regulatory Guide 1.8, September 1975 (reissued May 1977), except for the (I) Health Physics Supervisor who shall meet r-s-ign-oA fuoc44en ST. LUCIE"- UNIT 2 6-6 Amendment No.

l 5, 49,

0 ~ ~

~'E a.

I

)b 4 '

AOMINISTRATI VE CONTROLS AUDITS (Continued)

d. The performance of activities required by the guality Assur ance program to meet the criteria of Appendix B, 10 CFR Part 50, at least once per 24 months.

e. Any other area of unit operation considered appropriate by the CNRB or the President - Nuclear Oivfsion.

The fire protection prograrrmratic controls includfng the implementing procedures at least once per 24 months by qualiffed licensee gA personnel.

g. The fire protection equipment and prograN implementation at least once per 12 months utilizing either a qualified offsfte license'e fire protection engineer or an outside independent fire protection consultant. An outside independent fire protection consultant shall be-used at least every third year.

h. The radiological environmental monitoring program and the results thereof at least once per 12 months.

The OFFSITE OOSE CALCULATION MANUAL and fmpleaentfng procedures at least once per 24 months.

'I

j. The PROCESS CONTROL PROGRAM and fmpleraentfng procedures for devatarlng of radioactive bead resin at l ~ ast once par 24 eonths AUTHORITY 0

6.5.2.4 he CNRB shall report to and advise the President - Nuclear Ofvfsfon on those areas of responsibility specified tn Specifications 6.5.2.7 and. 6.5.2.8. co 2 RECORDS tt v PgfuAt 6

DaeTe

/r..5 Z.

6.5.2.26 Records of CURB activities shall be prepared, approve , and Jhb distributed as indicated below:

a. Minutes of each CNRB meeting shall be prepared, approved,"and forwarded to the President - Nuclear Ofvfsfon within 14 days following each meeting.

b. Reports of revfews encompassed by Specfffcatfon 6.5.2.7 above shall be prepared, approved, and forwarded to the President - Nuclear Oivision 14 days following completion of the review. 'f c Audft reports encomoassed by Specfffcatfon 6.5.2.8 above shall be forwarded to the President - Nuclear Ofvfsfon 'and 'to the management posftfons responsible for the areas audited within 30 days after completion of the audit by the audftfng organization.

d. Technical reviews encompassed by Specification 6.5.2.9 above shall be prepared, maintained and a report of the j!,DD activities forwarded each calendar month to the Chairman, CNRB.

ST. LUCIE - UNIT 2 6-12 Arrrendrrrent No. 47.

r ~

a.

cw t~

l

~ ~

S Ib c'g

~ I.'V

~ < e I r a 8 ~ > II ~

~ t ls 4

4g

St. Lucie Unit 2 Docket No. 50-389 Proposed License Amendment Technical Review Res onsibilities INSERT 1 TECHNICAL REVIEW RESPONSIBILITIES 6.5.2.9 The technical review responsibilities under the cognizance of the CNRB shall encompass:

'a ~ Plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources that may indicate areas for improving plant safety:

b. Plant operations, modifications, maintenance,, and surveillance to verify independently that these activities are performed safely and correctly and that human errors are reduced as much as practical; c ~ Internal and external operational experience information that may indicate areas for improving plant safety; and Making detailed recommendations through the Chairman CNRB for revising procedures, equipment modifications or other means of improving nuclear safety and plant reliability.

St. Lucie Unit 2 Docket No. 50-389 Proposed License Amendment Technical Review Res onsibilities ATTACHMENT 2 EVALUATION OF PROPOSED TS CHANGES Introduction Florida Power and Light Company (FPL) proposes to change the St.

Lucie Unit 2 Technical Specifications (TS) for the Independent Safety Engineering Group (ISEG). The proposed change maintains the requirement to perform technical reviews independent of the plant management chain. FPL believes this PLA to be consistent with the NRC guidance for line-item improvements to the existing facility TS.

Descri tion of Chan e The proposed Technical Specification changes are:

• delete TS 6.2.3 "Independent Safety Engineering Group"

• add TS 6.5.2.9 "Technical Review Responsibilities" Justification for TS Chan e The existing TS 6.2.3 requires that a five person organization, known as ISEG, be dedicated full-time to conduct in'dependent technical reviews. FPL has recognized over the years that the specification in its current form provides very little flexibility for the performance of the required reviews. The requirement to have a full-time dedicated staff places constraints on the existing FPL organization. The ISEG composition requirement is burdensome to a utility as it restricts the capability to utilize resources to their maximum advantage and does not result in an increase in the protection afforded to the health and safety of the public. The proposed change would maintain the requirement to perform independent technical reviews while providing increased flexibility to accomplish this function.

The proposed amendment will add TS 6.5.2.9 "Technical Review Responsibilities" under the responsibilities of TS 6.5.2 "Company Nuclear Review Board." This will maintain the requirement to conduct independent technical reviews and will give FPL the flexibility to better integrate programs such as the Human Performance Enhancement System, Operating Experience Feedback Program as well as the Nuclear Assurance Audit program to perform the required independent technical reviews. This flexibilitywill increase the effectiveness of the overall organization.

St."Lucie Unit 2 Docket No. 50-389 Proposed License Amendment Technical Review Res onsibilities The proposed amendment is consistent with the recommendations contained in the NRC's Regulatory Review Group Report draft, "Assessment of the Seabrook Operating License" dated February, 1993. This report found the current TS concerning the ISEG inflexible and provided the Revised Standard Technical Specifications as a solution. Specifically the report states, the composition of ISEG provides little flexibility. However, a Technical Specification change can be submitted adopting the Improved Standard Technical Specification approach; that would provide considerable flexibility in the implementation of this requirement."

The proposed change to the St. Lucie Unit 2 license is consistent with the guidance of NUREG-1432, "Standard Technical Specifications for Combustion Engineering Plants." FPL believes this PLA meets the NRC guidance for generic line-item improvements to the existing facility TS.

Based on the considerations discussed above, FPL considers the proposed change to the St. Lucie Unit 2 TS to be acceptable.

St."Lucie Unit 2 Docket No. 50-389 Proposed License Amendment Technical Review Res onsibilities ATTACHMENT 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10CFR50.92, a determination may be made that a proposed license amendment involves no significant hazards consideration operation of the facility in accordance with the proposed amendment if would not: (1) involve a significant increase in the probability or consequences of an accident 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. Each standard is discussed as follows:

(1) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed amendment maintains the requirement to perform independent technical reviews. The proposal does not change the plant design, limiting conditions for operation or related plant operating procedures. Therefore, operation of the facility in accordance with the proposed amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed amendment does not change the physical plant or the modes of plant operation defined in the Facility License. The change does not impact the operation, reliability or repair of existing equipment and cannot introduce any new failure mechanism to existing systems. Therefore, operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

St.-Lucie Unit 2

'ocket No. 50-389 Proposed License Amendment Technical Review Res onsibilities (3) Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The proposed amendment does not change the physical plant, the procedures for operation or the maintenance of plant components.

The change maintains the requirement to perform independent technical reviews. Assumptions, plant conditions, and analyses used to define or otherwise establish margins of safety for the operation of St. Lucie Unit 2 are not altered. Therefore, operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

Based on the discussion presented above and on the supporting Evaluation of Proposed TS Changes, FPL has concluded that this proposed license amendment involves no significant hazards consideration.

r

<<'0 0 1 j%

S

~ \ ~