ML20077E426

Application for Amend to License NPF-3,revising Tech Spec 6.0 Changing Station Review Board Composition & Reflecting Organizational Changes

ML20077E426
Person / Time
Site:	Davis Besse
Issue date:	05/10/1991
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20077E423	List: ML20077E422 ML20077E426 ML20077E433
References
NUDOCS 9106100190
Download: ML20077E426 (6)

Text

I

, Docket Number 50-346 i License Number NPF-3 Seriel Number 1840 l Enclosure l Page 1 APPLICATION FOR AMENDHENT TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1 Attached are the requested changes to the Davis-Besse Nuclear Power Station linit Number 1 Facility Operating License Number NPF-3. Also included is the Safety Assessment and Significant flazards Consideration.

The proposed changes (submitted under cover letter Serial Number 1840) concern Technical Specifications: 6.5.1.2, SRB Compositior 6.5.1.4, Heeting Frequer cy 6.5.1.5, Quorum 6.3, Facility Staff Qualifications 6.4, Training f .

i j l/  ;- --~~

By: N h D. C. Shelton, Vice President, v Nuclear, Davis-Besse l Sworn and subscribed before me this 10 th day of May. 1991.

bu'lk:N -

~

1/

Notary Pubfic, State of Ohio EVEl.YNL DRESS NOTARY PUBLC,STEOF OH10 pycormsenEgre.uy28,19H l .

9106100190 910510 l PDR ADOCK 05000346 l

P PDR l . _ - .

. Docket Number 50-346

, License Number NPF-3 Serial Number IP40 Enclosure Page 2 The following informstion is provided to support issuance of the requested changes to the Davis-Besse Nuclear Power Station, Unit Number 1 Operating License Number NPF-3. Appendix A, Technical Specifications, Section 6.0.

A. Time Required to Implement: This change is to be implemented within 45 days after the NRC issuance of the License Amendment.

B. Reasca for Change (License Amendment Request Number 90-0010): This change affects TS 6.0 by revising the Station Review Board (SRB) composition. These composition changes are proposed in order to reduce the necessity of a License Amendment Request each time a specific position or department title which involves SRB members is changed. In addition, various other position titles are proposed for revision to reflect organizational position title changes.

C. Safety Assessment and Significant Hazards Consideration: See Attachment 1.

I v l

l f

l' I

i

Docket Number 50-346 License Number NPF-3 Serial Number 1840 Attachment 1 Page 1 SAFETY ASSESSMEN'T AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 90 0010 TITLE Revision of Technical Specifications Section 6.0, Administrative Controls, regardlag Station Review Board Composition and Organizational Title Changes.

DESCRIPTION The purpose of the proposed changes is to modify the Davis-Besse Nuclear Power Station (DBNPS) Operating License NPF-3, Appendix A Technical Specifications (TS) Section 6.0 (Administrative Controls). The proposed changes are administrative in nature and involve revising the organizational position titles within the composition of the Station Reviev Board (SRB). In addition, various position titles are proposed for revision to reflect organizational changes. The proposed changes are similar to the intent of the Nucleat Regulatory Commission's (NRC's) guidance of Generic Letter (CL) 88-06, dated March 22, 1988, Removal of Organization Charts from TS Administrative Control Requirements (Toledo Edison letter Log Number 2534).

The proooaed change to TS b.S.I.2, SRB Composition, vill replace the specific titles of the SRB members with the following: "The Station Review Board shall be composed of at least six members of the Davis-Besse onsite management organization at the supervisor level or above. Each of the following disciplines shall be represented: plant operations, maintenance, planning, radiological controls, engineering, and quality assurance. The SRB Chairman shall be drawn from the SRB members and designated in vriting by the Plant Manager."

These composition char.ges are proposed in oroer to reduce the necessity of a License Amendment Request (LAR) each time a specific position or department title which involves SRB members is changed. Six License Amendments have been requested end approved to date, in order to change the specific titles in this particular TS. This is an unnecessary administrative burden which could better be handled under the 10 CFR 50.59 process. The details of the specific position titles for members of the SRB will be located in administrative procedures. Changes to these procedures are made in accordance with 10 CFR 50.59.

This proposed change is similar to that approved by the NRC on October 10, 1989 l as License Amendment Number 122 (TAC Number 74194) to the Crystal River Nuclear l Generating Plant Operating License Number DPP-72, Appendix A Technical l Specifications and approved by the NRC on November 14, 1990 as License i Amendment Number 10 (TAC Number 75616) and 20 (TAC Number 75617) to South Texas l Project Unit 1 and 2 Oparating License Number NPF-80, Appendix A, Technical Specifications.

l l

l

Docket Nunbar 50-346

. License Number NPF-3 '

Serial Number 1840 Attachment 1 Page 2 The additional proposed changes refleet organizational changes, are administrative in nature, and affect the following sections in TS 6.0 (Administrative (sn, rolsi t 6.3 (page 6-5) - Change " Radiological Controls Superintendent" to ' Manager -

Radiological Control" in order to reflect the current position title.

6.4.1 (page 6-5) - Change " Nuclear Training Director" to " Manager - Nuclear TraininE" in order to reflect the current position title.

6.4.2 (page 6-5) - Change Naclear Training Director" to " Manager - Nuclear Training" in order to reflect he current position title.

6.5.1.4 (page 6-6) . Change Inated alternate" to " designee".

6.5.1.5 (page 6-6) - Change " designated alternate" to " designee".

SYSTEMS, COMPONENTS AND ACTIVITIES AFFECTED These proposed changes affect specific position titles within Section 6.0 of the TS and the specific composition of the SRB.

S3FETY FUNCTIONS OF THE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIES The function of TS Section 6 is to provide the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the station in a safe manner. The function of the SRB is to advise the Plant Manager on matters related to nuclear safety.

EFFECTS ON SAFETY The SRB is currently composed of eight members, one of whom is designated Chairman. The SRB meets as required, but not less than once each month, advising the Plant Manager on matters related to nuclear safety.

Responsibilities of the SRB include review of plant administrative procedures and review of the safety evaluations for 1) procedures, 2) changes to procedures, equipment or systems, and 5) tests or experiments completed under the provision.= of 10 CFR 50.59 to verify such actions do not constitute an unreviewed safety question. The SRB also renders written determinations of I whether certain items it has reviewed constitute an onreviewed safety question, l

.d may recommend approval, disapproval, or other dispositions of review items.

The composition description for the SRB is proposed to be changed in TS 6.5.1.2 l

so that the specific position titles are not used to designate memberships rather, general requirements that capture the essential aspects of the SRB l composition are added. This change is consistent with the intent of GL 88-06 I which allotts the removal of the position titles and reporting requirements in -

l the onsite and offsite organization charts from the TSs to provide greater l flexibility to implement changes in tht;e organizations, i

1 r

Docket Number 50-346

, License Number NPF-3 Serial Number 1840

- Atta,chment 1 Page 3 The proposed change requires that the SRB members and chrirman be part of the DBNPS onsite managemer.t organization. This ensures that with the elimination of specific position titles, che SRB vill continue to be comprised of personnel clos 91y involved with daily activities at the station. The proposed change requires that the six SRB members and chairman be of a supervisor level or above representing the disciplines of plant operations, maintenance, planning, radiological controls, engineering, and quality assurance. This change ensures that the SRB vill continue to be composed of experienced individuals with varied expertise, while instituting additional flexibility as to specific appointments to the board.

The reduction in SRB members from eight to six is as a result of eliminating duplicate representation from the plant operations discipline. There is no adverse effect on safety since operations vill continue to b? a member of the SRB.

The additional proposed changes to update position titles (e.g., changing

" Radiological Controls Superintendent" to "Hanager - Radiological Control) are administrative changes.

Accordingly, it is determint 7.a t the proposed changes are administrative in nature and do not hnve a detrimental effect on safety.

SIGNIFICANT HAZARDS CONSIDERATION The NRC has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) Not create the possibility of a neu or different kind of accident from any accident previously evalusted; or (3) Not involve a significant reduction in a margin of safety.

Toledo Edison has re/ieved the proposed changes and determined that a significant hazards consideration does not exist because operation of the DBNPS Unit Number 1, in accordance vith these changes vould:

la. Not involve a significant increase in the probability of an accident -

pieviously evaluated because no initiators or assumptions for a previously evaluated accident are affected by these proposed changes to TS 6.0.

Ib. Not involve a significant increase in the consequences of an accident previously evaluated because no initiators or assumptions for a previously evaluated accident are affected by these proposed changes to TS 6.0.

2a. Not create the possibility of a new kind of accident previously evaluated because no accident initiators are created. No new hardware changes are being made, no new testing is being created and no new operating manipulations are being created by these proposed changes to TS 6.0.

Docket Number 50-346 License Number NPF-3 Serial Number 1840

. Attachment 1 Page'4 2b. Not create the possibiliiy of a different kind of accident from any accident previously evaluated because no accident initiators are created.

No changes in hardware, testing, or plant manipulations are being created by these proposed changes to TS 6.0.

3. Not involve a significant reduction in a margin of safety because the Station Reviev Board vill continue to be composed of experienced, onsite ,

supervisory personnel with expertise in the disciplines of plant operations, maintenance, planning, radiological controls, engineering and quality assurance. The other proposed changes are strictly administrative in nature.

CONCLUSION On the basis of the above, Toledo Edison has determined that the License Amendment Request does not involve a significant hazards consideration. As the License Amendment Request concerns a proposed change to the Technical Specification that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question.

ATTACHMENT Attached are the nroposed marked-up changes to the Operating License, i

l l

l

_- , . - _ - .