ML18142C032

Submittal of Application for Amendment to Applicant'S Technical Specifications, Describing Duties and Responsibilities of the Plant Review and Audit Groups

ML18142C032
Person / Time
Site:	Ginna
Issue date:	07/09/1974
From:	Babcock H LeBoeuf, Lamb, Leiby & MacRae., Rochester Gas & Electric Corp
To:	O'Leary J US Atomic Energy Commission (AEC)
References
Download: ML18142C032 (37)

Text

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RO'4 DATE OF DOC I DATE REC D LTR RP OTHER LeVoeuf,Lamb,Leiby & MacRae Washiggton, D.C. 20036 Mr. LeBoeuf et al 7-9-74 7>>9-74 X TO: ORIG CC OTHER SENT AEC PDR IXI JF O'eary 3 signed CLASS UNCLASS PROP XNFO INPUT NO C S REC'D DOCKET NO:

XXX XXX 22 50-244 DESCRXPTXON: ENCLOSURES:

Ltr trans the foll@wing.... Application for Amdt to the Tech Specs....

notarized 7-3-74.......

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WAsHINGToN, D. C. 20036 ARVIN C. UPTON ONE CHASE MANHATTAN PLAZA EUGENE B. THOMAS) JR. NEW YORK, N.Y. IOOOS LCONARD M. TROSTCN July 9, 1974 HARRY H. VOIGT WASHINGTON TELEPHONE LCX K. LARSON WASHINOTON PARTNCRS ZOZ-872-8888 CASLE ADDRESS LALALUsWASHINGTON D.C.

Mr. John F. O'eary lg Director 0 +

OOCXETEO Directorate of Licensing ORAEC U.S. Atomic Energy Commission JUL 3.0 1974 Washington, D.C. 20545 REOOLlTORY gRII. SECTION Re: Rochester Gas & Electric Corporation OOCRET CLERK R. E. Ginna Nuclear Power Plant, Unit 1 Docket No. 50-244

Dear Mr. O'eary:

Transmitted herewith are three (3) signed originals and nineteen (19) copies of Rochester Gas 6 Electric's Appli-cation for Amendment to Technical Specifications and forty (40) copies of the proposed change. A safety evaluation of the proposed change is also transmitted. The proposed change is submitted to conform Applicant's technical specification de-scribing the duties and responsibilities of. the plant review and audit groups with those described in ANSI,N18.7-1972 as

-well as to reflect the addition of the positions of cpality control and training coordinator.

Copies of these documents have been served upon those persons listed in the Certificate of Service also trans-mitted with this letter.

Respect fully submitted, LeBoeu f, Lamb, Levy S acRae Attorneys for Rochester Gas s Electric Corporation Enclosures

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BEFORE THE UNITED STATES ATOMXC ENERGY COMMISSION Xn the Matter of )

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ROCHESTER GAS & ELECTRXC CORPORATION ) Doc'ket No. 50-244 (R. E. Ginna Nuclear Power Plant, )

Unit,No. 1) )

CERTIFXCATE OF SERVICE I hereby certify that, I have served a document entitled "Application for Amendment to Technical Specifications" by mail-ing copies thereof first class, postage prepaid, to each of the following persons this 9th day of July, 1974.

Chairman, Atomic Safety C. John Clemente, Esq.

and Licensing Board Panel New York State Department U.S. Atomic Energy Commission of Commerce Washington, D.C. 20545 99 Washington Avenue Albany, New York 12210 Atomic Safety and Licensing Appeal Board Howard M. Wilchins, Esq.

U.S. Atomic Energy Commission Counsel, Regulatory Staff.

Washington, D.C. 20545 U.S. Atomic Energy Commission Washington, D.C. 20545 Mr. Michael Slade 1250 Crown Point Drive Edward Luton, Webster, New York 14580 Safety and Licensing Esq.'tomic Board Panel Warren B. Rosenbaum, Esq. U.S. Atomic Energy Commission One Main Street East Washington, D.C. 20545 707 Wilder Building Rochester, New York 14614 622 7

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Thomas W. Reilly, Esq. Dr. A. Dixon Callihan Atomic Safety and Licensing Union Carbide Corporation Board Panel P. O. Box Y U.S. Atomic Energy Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20545 Mr. Bruce .E. Thompson Dr. Franklin C. Daiber Supervisor, Town of Ontario Department of Biological 528 Furnace Road Sciences Ontario, New York 14519 University of Delaware Newark, Delaware 19711 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board Panel U.S. Atomic Energy Commission Washington, D.C. 20545 Hope M. Babcock LeBoeuf, Lamb, Leiby & MacRae Attorneys for Rochester Gas &

Electric Corporation

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UNXTED STATES OF AMERICA ATOMIC ENERGY'OMMISSXON ll

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ROCHESTER GAS 6 ELECTRXC CORPORATXON ) Docket No. 50-244 (R.E. Ginna Nuclear Power Plant, )

Unit No. 1) )

APPLICATION FOR AMENDMENT TO TECHNXCAL SPECXFXCATIONS Pursuant to Section 50.59 (c), of the regulations of the Atomic Energy Commission ("the Commission" ), Rochester Gas and Electric Corporation, holder of AEC Provisional Operating License No. DPR-18, hereby requests that the Technical Speci-fications net. forth in Appendix A to Provisional Operating License No. DPR-18 be amended. Specifically, Rochester requests that section 6.1 of Technical Specifications be amended to re-flect the organization and responsibilities of the station staff, station management organization, Plant Operations Review Comm-ittee and Nuclear Safety and Audit Review Board to satisfy the requirements of ANSI N18.7 and 10CFR50 Appendix B.

The proposed technical specification change is set forth in Attachment A to this application. A safety evaluation, which demonstrates that. the proposed change does not. involve a signi-ficant hazards consideration, is set forth in Attachment B.

WHEREFORE, Applicant respectfully requests that Section 6.1 of Appendix A to Provisional Operating License No. DPR-18 be amended in the form attached hereto as Attachment A.

ROCHESTER GAS 6 ELECTRIC CORPORATXON By

/a Keith W. Amish Sr. Vice President, Electric 6 Steam Subscribed and sworn to before me on this 3 day of July, 1974 N tary ublz.c STEPHEN KOWBA NOTARY PUBLIC, State of II.Y Monroe County

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l ATTACHMENT A 6.0 ADMINISTRATIVECONTROLS 6.1 ORGANIZATION, REVIEW AND AUDIT 6.1.1 RES PONSI BILITY The Station Superintendent is directly responsible for the safe operation of the station. During periods when the Station Super-intendent is absent, he may delegate this responsibility to other qualified supervisory personnel. In all matters pertaining to operation of the plant and to these Technical Specifications, the Station Superintendent shall report to and be directly responsible to the Division Superintendent of Electric and Steam Production or equivalent.

6.1.2 ORGA NIZATION OFFSITE 6.1.2.1 The offsite organization for station management and technical support shall be as shown on Figure 6.2-1.

STATION STAFF 6.1.2.2 The station organization shall be as shown on Figure 6.2-2 and

a. Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Figure 6. 2-2,

b. At least one licensed Operator shall be in the control room when fuel is in the reactor.

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c. At least two licensed Operators shall be present in the con-trol room during reactor start-up, scheduled reactor shut-down and during recovery from reactor trips caused by tran-sients or emergencies.

6.1.3 STATION STAFF QUALIFICATIONS 6.1.3.1 . ANSI Standard N18.1-1971, "Selection and Training of Nuclear Power Plant Personnel" will provide the criteria for the selection of personnel for comparable positions. In addition, the Quality Control Engineer and Training Coordinator shall have the following qualifications,

a. Quality Control Engineer A person with a Bachelor's Degree in an Engineering discipline.

The Quality Control Engineer shall have a minimum of 3 years of responsible power plant experience or applicable industrial exper-ience of which a minimum of 1 year shall be nuclear power plant E

experience. This person should have an understanding of 10 CFR50, II Appendix B requirements; regulatory guides involving quality assurance; and the various piping, material, pressure vessel, welding and inservice inspection codes.

b. Training Coordinator A high school graduate with a minimum of 4 years experience in power plant operation of which 1'ear is nuclear power plant ex-perience. This person shall have additional experience in training

6. 1-2

and have previously held a reactor operator license.

6.1.4 TRAINING 6.1.4.1 The ANSI Standard N18.1 "Standard for Selection and Training of Personnel for Nuclear Power Plants" will provide criteria for the training of personnel.

6.1.5 REVIEW AND AUDIT 6.1.5.1 General Three separate organizational units shall be established for the purpose of review and audit of plant operations and safety related matters.'ne of these will be an on site operations review group, the Plant Operations Review Committee (PORC). A second, is the off site quality assurance group, responsible for the audit of safety related activities associated with plant operations. A third is the independent 4

audit and review group, the Nuclear Safety Audit and Review Board (NSARB). This group is responsible for the periodic review of the activities of the Plant Operations Review Committee, for directing audits and evaluating their results, and for the management evaluation of the status and adequacy of the quality assurance program.

6. 1. 5. 2 Plant Operations, Review Committee 6.1.5.2.1 The Plant Operations Review Committee shall provide timely and con-tinuing review of plant operations to advise the Station Superintendent on the overall safety of plant operations a'nd for referral of appropriate matters to the Nuclear Safety Audit and Review Board.

6. 1-3

6.1.5. 2. 2 Membership The chairman shall be the Station Superintendent, or designated I

alternate. Other regular members shall include:

a. Assistant Station Superintendent

b. Operations Engineer

c. Maintenance Engineer

d. Nuclear Engineer

e. Results and Test Engineer

f. Supervisor Chemistry and Health Physics

g. Quality Control Engineer Alternate members shall be designated by name, in writing, by the Chairman.

6. 1.5. 2. 3 Qualifica tions The qualifications of the regular members of the Plant Operations Review Committee, with regard to the combined experience and technical specialties of the individual members, shall be maintained at a level at least equal to or higher than as described in Section 6.1.3.

6.1.5.2.4 Meeting Frequency: At least once per calendar month and a's con-alternates vened by the Chairman.

6.1.5.2.5 Quorum: Chairman plus four members. No more than two shall be

6. 1. 5. 2. 6 Responsibilities

a. Review all proposed normal, abnormal and emergency operating procedures. Review all proposed maintenance procedures and proposed changes to those procedures, and any other proposed 6.1-4

I procedures or changes thereto as determined by the Station Superintendent to affect nuclear safety.

b. Review all proposed tests and experiments.

c. Review proposed changes to Technical Specifications.

d. Review all proposed changes or modifications to plant systems or equipment.

e. Review plant operations to detect potential safety hazards. Inves-tigate all reported instances of violations of Technical Spe'cifications; such investigations to include reporting, evaluation, and recom-mendations to prevent recurrence, to the Sr. Vice President of r

Electric and Steam and to the Chairman of the Nuclear Safety Audit and Reviewr Board.

f. Review all Abnormal Occurrences.

g. Review Unusual Events as described in Section 6.6.2 of these Technical Specifications.

h. Perform special reviews and investigations and render reports thereon as requested by the Chairman of the Nuclear Safety Audit and Review Board.

Authority

a. The Plant Operations Review Committee shall be advisory and shall render determinations, in writing with regard to whether or not each proposal considered under 6.1.5.2.6 (a) through (d) constitutes an unreviewed safety question as defined in 10CPR Section 50.59 of the Regulations of the Atomic Energy Commission.

6.1-5

b. The Plant Operations Review Committee shall recommend to the Station Superintendent approval or disapproval of proposals under items 6.1.5.2.6 (a) through (d) above. In the event of disagreement between the recommendations of the Plant Operations Review Committee and the actions contemplated by the Station Superintendent, the course determined by the Station Supenntendent to be the more conservative will be followed with immediate noti-fication to the Division Superintendent of Electric and Steam E

Production and to the Chairman of the Nuclear Safety Audit and Review Board.

6.1.5.2. 8 Records Minutes shall be kept of all meetings of the Plant Operations Review Committee and copies shall be sent to tne Stauon Superintendent, to the Chairman of the Nuclear Safety Audit and Review Board, and such others as the Chairman may designate.

6.1.5.2.9 Procedures Written administrative procedures for committee operation shall be prepared and maintained describing the method of submission and the content of presentations to the committee; provisions for the use of subcommittees; review and approval by members of written committee evaluations and recommendations; the distribution of minutes and such other matters as may be appropriate.

6.1.5.3 Quality Assurance Group 6.1-6

e 6.1.5. 3. 1 The organization, qualifications, responsibilities and training of quality assurance personnel responsible for audits of safety related activities I

are described in the Technical Supplement Accompanying Application for a Full-Term L'icense as supplemented. The frequency and method for performing audits and reporting audit results are as described in the Technical Supplement Accompanying Application for a Pull-Term License as supplemented.

6.1.5.4 Nuclear Safety Audit and Review Board 6.1.5.4.1 Function The Nuclear Safety Audit and Review Board (NSARB) shall function to provide independent review and audit of designated activities in the areas of:

a. nuclear power plant operations

b. nuclear engineering

c. chemistry and radiochemistry d .. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance practices 6.1.5.4.2 Membership

a. Chairman and Vice Chairman appointed by name by the Chairman of the Board and Chief Executive Officer of the Corporation or officer of his designation.

6.1-7

ll b.. At least four technically qualified persons who are not members of the plant staff to provide expertise in the functional areas described in 6.1.5.4.1.

c. Two members from the supervisory staff of the R. E. Ginna Nuclear Power Plant staff. These two members shall serve as non-voting members of 'the Nuclear Safety Audit and Review Board.

d. Members in.(b) and (c) above to be designated by the Chairman of the Board and Chief Executive Officer.

e. At least one qualified non-company affiliated technical con-sultant and others as required. Duly appointed consultant members shall have equal vote with company affiliated members of the Board.

6.1.5.4.3 Qualifica tions I,

The minimum qualifications of the Nuclear Safety Audit and Review Board shall be as defined by ANSI N18. 7 and shall collectively have the competency required to review problems related to the areas des-cribed in Section 6. 1. 5.4. 1.

6.1.5,4,4 Meeting Frequency at least semi-annually and as required on call of the Chairman.

6.1.5.4.5 Quorum: a quorum of five members including the Chairman or Vice Chairman. At least one of the quorum shall be a non-company affiliated technical consulta nt.

6. 1.5.4. 6 Res ponsibilities

6. 1 . 5. 4. 6. 1 The NSARB shall review:

a. Safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision.

6. 1-8

of 10CFR 50.59, to verify that such actions did not constitute an unreviewed safety question.

b. Proposed changes to procedures, equipment or systems which have been determined by PORC to involve an unreviewed safety question as defined in 10CFR 50. 59.

c. Proposed tests or experiments which have been determined by PORC to involve an unreviewed safety question as defined in 10CFR 50. 59

d. Proposed changes in Technical Specifications.

e. Violations of applicable statutes, codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f. Significant operating abnormalities or deviations from normal and expected performance of plant equipment.

g. ABNORMAL OCCURRENCES, as defined in Section 1.0 of these Technical S pecifications.

h. Unusual Events, as described in Section 6.6.2 of these Technical Sepcifica tions.

i. Any indication of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems, or components.

j. Reports and meeting minutes of the Plant Operations Review Committee.

k. Matters referred by the Plant Operations Review Committee.

l. Occurrences if safety limits are exceeded.

6. 1-9

m. Audit results on activities related to the station.

n. Corrective action reports to ensure appropriate corrective action has been accomplished.

o. Other matters deemed essential to the safe operation of the facility.

6.1.5.4.6.2 The NSARB shall direct the establishment of an audit program and evaluate audits performed to ensure safe facility operation. Audits shall encompass:

a. The conformance of station operation to the Technical Specifications, applicable license requirements, and Operating procedures.

b. The performance of the operating staff.

c. The Radiation Emergency Plan.

d. The performance of all activities required by the Quality Assurance program to meet the criteria of 10CFR 50 Appendix B and to comply with corporate policy.

e. The adequacy of the Quality Assurance program to meet criteria of 10CFR 50, Appendix B and to comply with corporate policy.

f. The results of actions taken to correct anomalies occurring in facility equipment, structures systems or method of operation.

g. Any other area of station operation considered appropriate by the NSARB.

6.1.5.4.7 Authority

a. The chairman of the Nuclear Safety Audit and Review Board is responsible to the Chairman of the Board on all activities for which the review board is responsible.

6.1-10

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b. The Nuclear Safety Audit and Review Board shall advise the Company Sr. Vice President of Electric and Steam of appropriate action to prevent recurrence of any violations of applicable codes, regulations, orders, Technical Specifications, license requirements or of internal procedures or instructions having nuclear safety significance.

6.1.5.4.8 Records Minutes shall be recorded of all meetings of this committee. Copies of the minutes shall be forwarded to the Chairman of the Board, Sr.

Vice President of Electric and Steam and such others as the Chairman may designate.

6.1.5.4.9 . Procedures Written administrative procedures for committee operation shall be prepared and maintained describing the method of submission and the content of presentations to the committee, provisions for use of subcommittees, review and approval by members of written committee evaluations and recommendations, distribution of minutes, and such other matters as may be appropriate.

6.1-11

V ROCHESTER GAS AND ELECTRIC CORPORATION GINNA STATION MANAGEMENT ORGANIZATION Chairman of the Board and Chief Executive Officer 1

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I President I

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I Sr. Vice President Sr. Vice President Nuclear Safety Audit Finance A General Services Electric 5 Steam and Review Board Vice President Vice President Vice President Purchasinq. Narketing, and and Districts Chief Engineer 'Steam and Electric General Superintendent Purchasing Aqent Electric f Steam .Operations Chief Ouality Assurance Coordinator Division Superintendent Design Engineers Elec. & Steam Production Superintendent Plant Operations Ginna Station Review Committee Supervision and Administration Other Functional Relationships guality Control Engineer plant Operations Staff Fig 6,2-1 July 1, l974

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OCHESTER CAS AND ELECTRIC CORPORATION GINNA STATION ORGANIZATION Superintendent Training Coordinator Assistant Superintendent Supervisor SOL Results and Teste Operations Maintenance Nuclear IIuailty Control Engineer Chenistry and Engineer Engineer Engines'r Engineer Health Physics iSOL Shift Foreman 1/Shift OL Head Control Operator 1/Shift Control Operator OL SOL - Senior Operator License 1/Shi ft OL - Operator License Auxiliary Operator 2/Shift Pigure 6 ~ 2-2 July 1, 1974

ATTACHMENT B Safety evaluation for proposed change to Section 6. 1" Technical Specifications.

The proposed change is determined not to involve an unreviewed safety question for the following reasons:

1. The format and descriptions of duties and responsibilities for the Review and Audit groups are consistent with those described in the ANSI N18. 7-1972.

2. Training and qualification requirements for review and audit personnel are consistent with the guidelines of ANSI N18. 1 and ANSI N18. 7-1972.

3. The management organization chart now reflects the Quality Assurance Group for performing audit activities under the direction of the Nuclear Safety Audit and Review Board.

4. 'he organization chart for Ginna Station reflects additional I

positions of Quality Control Engineer and Training Coordinator to satisfy recent corporate policy staffing requirements for the activities of Training and Quality Control.

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