ML20196B760

Application for Amends to Licenses NPF-35,NPF-52,NPF-9 & NPF-17,clarifying Tech Spec 6.2.3 Re Safety Review Group.Fee Paid

ML20196B760
Person / Time
Site:	Mcguire, Catawba, McGuire, 05000000
Issue date:	11/28/1988
From:	Tucker H DUKE POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196B764	List: ML20196B760 ML20196B768
References
TAC-71400, TAC-71401, NUDOCS 8812070025
Download: ML20196B760 (11)

Text

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. Il I Duke 1%urr Company lin B Tuon p o gax33]93 Vice Praident Charlotte, N C 28242 h I'M Pmd"twa (70 t)3:1-IUl DUKE POWER November 28, 1988 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

McGuire Nuclear Station Docket Nos. 50-369 and 50-370 Catawba Nuclear Station Docket Nos. 50-413 and 50-414 Proposed Technical Specification Revision Regarding Techni:al Specification 6.2.3, Safety Review Group Gentlemen:

Attached are proposed license amendments for Facility Operating License NPF-9 and NPF-17 for McGuire Nuclear Station, Units 1 and 2 respectively, and Facility Operating License NPF-35 and NPF-52 for Catawba Nuclear Station, Units 1 and 2 respectively. The proposed changes seek to clarify the specifications governing the requirements of the McGuire and Catawba Safety Review Groups.

Attachment No. lA contains the proposed changes to Technical Specification 6.2.3 for McGuire and Attachment No. 1B contalas the proposed changes to Technical Specification 6.2.3 for Catawba. Attachment No. 2 contains the justification and safety analysis in support of the proposed changes.

Attachment No. 3 contains an analysis conforming to the standards contained in 10CFR 50.92 as required by 10CFR 50.91 which concludes that the proposed revisions do not involve any significant hazards consideration. l This request involves one application for amendment to the McGuire Technical Specifications and to the Catawba Technical Specifications. Accordingly, an application fee of $150.00 is enclosed as required by 10CFR 170.21.

Should there be any questions regarding this submittal, contact S.E. LeRoy at (704) 373-6233.

Very truly yours, m ,

- [ igi, b ,

Hal B. Tucker Attachment 00 1 SEL/338/sel p Vd fly \

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U.S. Nuclear Regulatory Commission i November 28, 1988 Page 1 of 6 0 UKE POWER COMPANY .

McGUIRE AND CATAWBA NUCLEAR STATION ATTACHMENT NO. 2 Justification and Safety Analysis for Proposed Amendment i

Background:

During an NRC inspection at McGuire Nuclear Station (MNS) on June 25 - July 22, 1988, and as transmitted by NRC Inspection Report No. 50-369,370/88-20, a i violation was identified. The violation stated that contrary to Technical i Specification 6.2.3.3, McGuire Safety Review Group (MSRG) activities covering the period of 1986, through June 1988, revealed that the MSRG did not perform t routine indepen M surveillance of plant operations and maintenance activities, to provide independent verification that these activities were  ;

performed correctly. This violation followed a meeting at MNS during which Ouke presented the methods by which the MSRG and the Catawba Nuclear Station  !

(CNS) Safety Review Group (CSRG) meet regulatory requiremen % (Reference l July 28, 1988 summary of meeting from NRC to Duke). .

l l By letter dated September 16, 1988, Duke responded to the violation. Duke I

stated that the violation was admitted in that an insufficient number of j independent in-plant reviews /surveillances were performed during the period -

i stated to adequately meet the intent of the Technical Specification {

requirement, and that Duke believes the requirements were being met through t the combined performance of unusual event investigations and in-plant  !

reviews / surveillance. Subsequently, Duke has increased emphasis on the i

requirement for MSRG and CSRG to perform pro-active in-plant reviews, and on '

! increasing the percentage of MSRG time spend conducting in-plant reviews,  !

i and instructed the MSRG and CSRG to documant the conduct of surveillance / (

, programmatic type activities when performed in conjunction with unusual event

' investigations, where deemed appropriate.

4 During an NRC inspection at Catawba Nuclear Station (CNS) on August 1 - 5 ('

l 1988, and as transmitted by NRC Inspection Report No. 50-413,414/88-29, a j violation was identified that stated that no objective evidence existed that  :

j the CSRG reviews NRC issuances, industry advisories, or other sources which  !

i J may indicate areas for improving plant safety in order to make detailed j recommendations for revised procedures, equipment modifications, or other (

1 means of improving piant safety. By letter dated October 4, 1988, Duke t

] responded to this violation. Duke stated the violation was admitted in that #

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the requirement of the technical specification is not totally performed by the 4 CSRG. As stated in the violation discussion, (paragraph 2a of NRC Inspection i

Report 50-413,414/88-29), this function is performed by Duke Corporate Nuclear ,

Production Department Engineering / Technical staff and other Duke support  !

groups coordinated by Duke's Operating Experience Management Assessment Group (

under the management of the Nuclear $sfety Assurance Grooo Manager, (this l l person also serves as the Chairman of Duke's Nuclear St/ sty Review Board). l l Duke believes this method of reviewing plant operating character % tics, NRC [

issuances, etc.., satisfies the requirement of Technical Specification 6.2.3. i I

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U.S. Nuclear Regulatory Comission l November 28, 1988 Attachment No. 2 Page 2 of 6 In response to both the CNS and MNS violations, Duke stated that it would  :

submit a proposed revision to the CNS and MNS Technical Specification related to the CSRG and MSRG to clarify their functions, responsibilities, and authority. Duke alto believes the MNS Technical Specification 6.2.3, McGuire Safety Review Group and the CNS Technical Specification 6.2.3, Catawba Safety Review Grcup are overly general and ambigucus, and do not specify requirements imposed by previously issued regulatory documents, (e.g. NUREG 0737, NUREG 0800, MNS SER Supplement No. 4). The proposed changes will specifically define the Safety Review Group functions, responsibilities, and authority in a manner that will meet or exceed regulatory requirements. It should also be noted that the proposed Technical Specification is written the same for CNS and MNS. Both Safety Review Groups are organized and operated in the same l manner.

Proposed Revision:

Section 6.2.3.1, Function This section would be revised to state the CSRG and MSRG shall function to provide the review of plant design and operating experience for potential opportunities to improve plant safety, provide evaluation of plant operations and maintenance activities, and to provide advice to management on the overall quality and safety of plant operations. Also, the CSRG and MSRG shall mcke recomendations for revising procedures, equipment modifications, or other means of improving plant safety to appropriate station and/or corporate management.

Technical Specification 6.2.3, Station Safety haview Group is the culmination of comitments and requirements relative to TMI Action Item I.B.1.2. The intent of the Safety Review Group is tu perform independent reviews of plant operations in accordance with the guidelines of item I.B.1.2 of NUREG-0737.

The group is to also examine plant operating characteristics, NRC issuances, and other operating experience information areas for improving plant safety, and to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are being performed corret.tly, and that human errors are reduced as far as practicable. The group is to perform independent reviews and audits of plant activities including maintenanco, modifications, operational problems, and aid in the establishmant '

of programatic requirements for plant activities. The group is also expected to develop detailed recomendations for revised procedures, equipment modifications, or other means of achieving the goal of improved plant safety.

The current Technical Spe.ification is general and not specific in that it briefly describes some of the requirements to be fulfilled by the Safety '

Review Group, but does not compictely describe the intent of the specification as described by 1.B.1.2 of NUREG 0660 and NUREG 0737, NUREG 0800 Standard Review Plan Section 13-4, and findings of NRC Inspection Report 50-369,370/88-20 in which MNS was cited for failing to meet the intent of the subject specification. The proposed revision to this section (6.2.3.1) provides specific requirements that are necessary to meet the intended function of the Safety Review Group, and envelops the requirements stated above, as described by NRC documents.

U.S. Nuclear Regulatory Commission November 28, 1988 l Attachment No. 2  !

Page 3 of 6 The MNS specification refers to the MSRG as the Station Safety Review Group.

1 The revision would change this designation to the McGuire Safety Review Group  !

or MSRG. Th h change is purely administrative and simply changes the standard l l

techaical specification description to the site specific description used by  ;

Duke.  !

l Section 6.2.3.2, Jomposition l

This section of the standard technical specification states that at least five, dedicated full time engineers are to comprise the tafety Review Group.

The standard technical specification also states that the composition of the j Safety Review Group be specified by the use of an overall qualification statement referencing an ANS! Standard, agreed to by the NRC staff, or by r

specifying individual position qualifications. The proposed revision states  !

the staffing requirements of the Safety Review Groups and the level of experience required to be assigned as a member of the group. The revision I l

states that the group shall be composeu of at least five dedicated, full time l

engineering / technical personnel to be located on site. The engineering / [

technical personnel shall have at least six years of technical experience with I a minimum of two of these six years being nuclear station related experience. l Also, a maximum of four years of the six years may be fulfilled by academic or  !

j related training, t

. Engineering personnel are those that have obtained an engineering degree.

l Technical personnel are those that have backgrounds in maintenance (electrical  !

]

or mechanical), health physics, chemistry, operations, etc., and are in staff (

1 or supervisory positions prior to being assigned to the Safety Review Group. i

! This combination of technical experience and academic background paovides the l l group with a wide breadth of qualifications and knowledge. Safety Review (

Group members are assigned to the CSRG and MSRG for a period of approximately 1 l '

J twelve to eighteen months. The members are administratively assigned to the management responsible for the CSRG and MSRG to provide independence in work [

activities and resolutions. Duke believes the proposed revision will better "

l define the composition and qualifications of the Safety Review Group, and

) continue to ensure the Safety Review Group is staffed with knowledgeable and i experienced personnel consistent with MNS SER Supplement No. 4, in meeting the requirement described in the standard technical specification.

l Section 6.2.3.3, Responsibilities This section is being revised to provide a more specific description of f l activities that are the responsibility of the Safety Review Group. The l i

! following are the proposed changes and a description of how the Safety Review I j Group performs each function. l

a. The group shall review selected plant operating characteristics and other appropriate sources of plant design and operating experience information for awareness and incorporation into the performance of other duties.  ;

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U.S. Nuclear Regulatory Commission November 28, 1988 Attachment No. 2 Page 4 of 6

b. 'he group shall review the effectiveness of corrective actions taken as a result of the avaluation of selected plant operating characteristico, and other appropriate sources of plant A sign and operating experience information.

Within Duke's Nuclear Production Departmeit is a group of engineering /

technical personnel that have the respontibility to ensure that operating experience information is effectively distributed, that the recipient is provided lastructions regarding the informrtion or evaluation, and to properly communicate, document, and track the resolution of corrective actions resulting from the review of such information. This group is referred to as the Operating Experience Management and Analysis SectM (OEMA). OEMA processes operating experience information, (i.e.. plant operating characteristics, NRC issuances, industry advisories, reportable events, Duke events,etc..). OEMA utilizes resources from within Duke's Nuclear Production Department, Design Engineering Department, Production Services Department, and the McGuire, Catawba, and Oconee Nuclear Stations for the detailed teview and evaluation of these materials with the objective of improving plant safety.

Within the flow path of this information/ review network, the CSRG and MSRG serve an important role. The Safety Review Group is respontible for distributing documents to station personnel that require urgent notification.

The Safety Review Group is responsible for periodically conducting a review to determine the effectiveness of the operating experience program at the station. The Safety Review Group is responsible for input of information into the operating experience program resulting from incident investigations performed by the Safety Review Group members. Additionally, the Safety Review Group is responsible for reviewing selected completed operating experience packages that contain the review and recomended actions, and for conducting follow-up reviews on corrective action affectiveness. Therefore, as the Safety Review Groups actively participate in Duke's OEMA operating experience program, the intent and requirement of the technical specification are satisfied.

c. The Safety Review Group is responsible for the review of selected programs, procedures, and plant activities includirg maintenance, modifications, operational problems, and operational analysis,

d. The Safety Review Group is responsible for surveillance of selected plant operations and maintenance activities to provide independent verification that these activities are performed correctly and that human errors are reduced as far as practicable. (It should be noted that the gaoup is not responsible for the sign-off function of independent verification.)

These activities are fulfilled by the group members under the direction of the Safety Review Group Chairman (group supervisor). The subject of these reviews is determined by the member based on activities at the plant or based on other information or stimulus. The intent of the specification is to allow the member to investigate any plant activity where that member feels an improvement in plant safety might be made. The group members are also avsilable to plant personnel who may wish to discuss problem areas or items of concern related to plant safety. The subject for the review is discussed by the member and the group Chairman. A completed report of the review is then forwarded to the Station Manager and to the Manager of Nuclear Safety Assurance.

I U.S. Nuclear Regulatory Commission November 28, 1988 h Attachment No. 2 i Page 5 of 6 (

The Manager of Nuclear Safety Assurance provides supervision to the Safety Review Group Chairman and reports to the General Manager of Nuclear Support within Duke's Nuc1 C Production Department. The General Manager reports to the Nuclear Production Department Vice President. The Manager of r Nuclear Safety Assurance also serves as the Chairman of Duke's Nuclear Safety j Review Board.

e. The Safety Review Group is responsible for the investigation of selected  !

unusual events and other occurrences as assigned by Station Management or  !

the Manager of Nuclear Safety Assurance. l t

The Safety Review Group performs investigations of selected incidents that  !

occur at the plant. When an event occurs and is reported to station  !

management, a group with the necessary expertise is assigned to investigate  !

the situation and orepare a report addressing the incident, corrective I actions, and impact on plant safety. Normally, reports concerning events that l that are reportable to the NRC are assigned to the Safety Review Group for  !

investigation. A group member will then investigate the event and prepare a i report containing the sequence of events, background information, a  !

I description of the event, the cause of the event, corrective actions taken and planned, and the impact on the safety of the plant. These reports are [

l forwarded to the Station Manager, and to appropriate Licensing peasonnel to be  ;

i reported to the NRC. Theso investigations have played an important part in ,

i analyzing various aspects of the station and providing actions that have l improved plant safety.

l i

l The proposed changes listed above under the section titled Responsibility is a j comprehensive listing of requirements that the Safety Review Group must .

1 perform to fulfill the commitments relative to TMI Action Item 1.B.1.2. The l j intent of the Safety Review Group is to perform independent reviews of plant [

j operations in accordance with the guidelines of item I.B.1.2 of NUREG-0737.

The group is to also examine plant operating characteristics, NRC issuances, l and other operating experience information areas for improving plant safety, j

and to maintain surveillance of plant operations and maintenance activities to provide independent verification that these activities are being pttformed l l correctly, and that human errors are reduced as far as practicable. The group i is to perform irdependent reviews and audits of plant activities including .

i maintenance, modifications, operational problems, and aid in the rstablivment  !

l of programmatic reauirements for plant activities. The group is also expected i

} to develop detailed recomendations for revised procedures, equipment l j modifications, or other means of achieving the goal of improved plant safety.

This existing technical specification section is ge.eric and briefly describes the requirements of the Safety Review Group; but, it does not completely  !

l describe the requirements as described by 1.B.1.2 of NUREG 0660 and NUREG .

0737, NUREG 0800 Standard Review Plan Section 13-4, and responsibilities as  !

defined by NRC Inspection Report 50-369,370/88-20. The proposed revision to i section 6.2.3.3 provides a sogeific description of the responsibilities and j duties of the Safety Review Group, and envelops the requirements stated above.  :

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U.S. Nuclear Regulatory Commission l November 28, 1988  ;

Attachment No. 2  !

Page 6 Of 6 Section 6.2.3.4 Authority l l

The Safety Review Group shall report to and advise the Manager of Nuclear 6 Safety Assurance on those areas of responsibility specified in Section 6.2.3.

The Safety Review Group is independent of station management in that it reports directly to the Manager of Nuclear Safety Assurance. The intent of  ;

this reporting requirement included in the generic specification is to provide )

an atmosphere under which the members of the group can carry out their  :

responsibilities without being under the supervision of station personnel, and  !

to provide a working attitude that would be unbiased towards station  !

activities. The change in the requirement for reporting to the Manager of (

Nuclear Safety Assurance instead of the Director of Duke's Nuclear Safety  :

Review Board is purely an administrative change in that the Manager of Nuclear  !

Safety Assurance also serves as the Director of Duke's Nuclear Safety Review l Board. [

t The proposed change to the specification better defines the person in Duke's  !

organization that the Safety Review Group would report to, and defines the i areas 'those listed under Responsibilities) that the group would have the  !

authority to review or investigate. The positions of Chairman of Duke's [

Nuclear Safety Review Board and Manager of Nuclear Safety Assurance are L occupied by the same person; therefore, the change in reporting to the Manager t of Nuclear Safety Assurrance is purely administrative. }

Section 6.2.3.5, Records

' Records of activities performed by the Safety Review Group shall be prepared, r l maintained, and forwarded each calendar month to the Manager of the Nuclear  ;

1 Safety Assurance Group, and to the Station Manager. i

Currently, the reporting requirement states that activities shall be reported l j to the Director of Duke's Nuclear Safety Review Board. The proposed change [

l is administrative in that it would require the group to report its activities i to the Mariager of Nuclear Safety Assurrance which also servec as the Director j l

of Duke's Nuclear Safety Reivew Board, as previously discussed. The reporting i requirement provides adequate management oversight for the Safety Review Group  !

! in that communications between the group and management will be maintained at }

) a level that will ensure that an appropriate amount of reviews and activities i q are being performed to improve plant safety. The additional requirement. l 1 imposed by Duke, for the group to report their activities to the Station j J Manager ensures the Station Manager will be made aware of activities being i j addressed by the group. j i

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U.S. Nuclear Regulatory Comrhsion November 28, 1988 DUKE POWER COMPANY CATAWBA AND McGUIRE NUCLEAR STATIONS ATTACHMENT NO. 3 Significant Hazards Consideration Pursuant to if)CFR 5'.i.91, the following analysis provides a determination that the proposed amendment does not involve any significant hazards considerations as defined by 10CF50.92

1. The proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

Duke believes the MNS Technical Specification 6.2.3, McGuire Safety Review Grcup and the CNS Technical Specification 6.2.3, Catawba Safety Review Group are ambiguous and do not reflect requirements imposed by previously issued regulatory documents, (e.g. NUREG 0737, NURES 0800, MNS SER Supplement No. 4).

The proposed changes will define the Safety Review Group functions, responsibilities, and authority in a manner that will meet or exceed regulatory requirements. The changes would add to the specification all of the responsibilities the CSRG and MSRG needed to achieve regulatory compliance. The changes also clearly define the composition and experience tavel of Safety Review Group, and is consistent with the intent of the specification. The proposed changes are administrative in nature in that the changes will clarify the CSRG and MSRG functions, responsibilities, and authority.

2. The proposed amendment would not create the possibility of a new or different kind of accident previously evaluated.

The changes will place into the specification all of the responsibilities the ,

CSRG and MSRG need to fulfill in order to achieve regulatory compliance. The changes also clearly define the composition and experience level of Safety Review Group members. There will be no changes in the operation of the  ;

station or plant systems as a result of this revision. The proposed changes ,

are administrative in nature and merely clarify the responsibilities, authority, and staffing requirements of the CSRG and MSRG.

3. The proposed amendment would not involve a significant reduction in the margin of safety.

The changes will place into the specification all of the responsibilities the CSRG and MSRG need to fulfill in order to achieve regulatory compliance. The changes also clearly define tne composition and experience level of Safety ,

Revision Group members. There will be no changes in the operation of the station or plant systems as a result of this revision. The proposed changes "

are purely administrative in nature and merely clarify the responsibilities, au+.hority, and staffing requirements of the CSRG and MSRG.

Based upon the proceeding analysis, Duke concludes, in accordance with 10CFr.

50.91, that the proposed changes do not involve any significant hazards considerations as defined by 10CFR 50.92.

m

• t 4c U.S. Nuclear Regulatory Commission-

'4 November 28, 1988

! 'Page 2 m xc: Mr. M. L. Ernst, Acting Regional Administrator U.S. Nuclear Regulatory Commission

• ' ' Region II 101 Marietta Street, NW, Suite 2900 [

Atlanta, GA 30323 L Mr. Heyward Shealy, Chief >

Bureau of Radiological Health South Carolina Department of Health &

4 Environmental Control .

.2600 Bull Street l Columbia, SC 29201 '

o ,

American Nuclear Insurers-c/o Dottie Sherman, ANI Library  :

Ti.e Exchange, Suite 245 ' i

' 270 Farmington' Avenue Farmington, CT 06032' i

M & M Nuclear Consultants 1, 1221 Avenue of the Americas

[ New York, NY.10020 INPO Records Center Suite 1500- i 1100 Circle 75 Parkway Atlanta, GA 30339 l Mr. W.T. Orders l NRC Resident inspector Catawba Nuclear Station [

Mr. Darl Hood '

b U.S. Nuclear Regulatory Comission i

' Office of Nuclear Reactor Reguistion Washington DC 20555 l Mr. P.K'. Van Doorn )

i NRC Resident Inspector  !

! McGuire Nuclear Station V Mr. Dayne Brown, Chief l

. Radiation Protection Branch J Olvision of Facility Services  !

! 1 Department of Human Resources  ;

! P.O. Box 12200 i s

Raleigh, NC 27605 Dr. K.N. Jabbour i U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation l Washington, DC 20555 l l

1 2,

U.S. Nuclear Regulatory Commission November 28, 1988 Page 3 HAL B. TUCKER, being duly sworn, states that he is Vice President of Duke Power Corapany; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this revision to the Catawba Nuclear Station Technical Specifications, Appendix A to License No. NPF-35 and NPF-52 and to the McGuire Nuclear Station Technical Specifications, License No. NPF-9 and NPF-17; and, that all statements and matters set f orth therein are true and correct to the best of his knowledge.

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Hal B. Tucke'r, Vice President Subscribed and sworn to before me this / day of ,O.S.>./31,1988.

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'" U.S. Nuclear Regulatory Comission November 28, 1988 Paga 4 bxc: A.V. Carr R.C. Futrell R.L. Gill R.M. Glover C.L. Harlin P.G. LeRoy 0.W. Murdock T.B. Owen T.L. McConnell 0.L. Rehn R.O. Sharpe C4-801.01 MN 801.01 (13) l e