ML20205C433

Application for Amend to License NPF-1,revising Tech Specs Re Review Board Requirements to Review Changes to Plant Procedures

ML20205C433
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/07/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20205C371	List: ML20205C367 ML20205C433 ML20205C450
References
TAC-60020, NUDOCS 8608120327
Download: ML20205C433 (9)

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t PORTLAND CENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 Decket 50-344 License Change Application 130, Revision 1 This License Change Application requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to reflect a more efficient manner for review and approval of Plant procedures.

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PORTLAND GENERAL ELECTRIC COMPANY  ;

I By Bart D. Withers Vice President I Nuclear l Subscribed and sworn to before me this 7th day of August 1986.

Notary Public of Ors (fon My Commission Expires: [

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P h 27 860007 CK 05099344 PDR

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LCA 130, Nevision 1 Page 1 of 8 DESCRIPTION OF CHANGE ,

As shown in Attachment 1, Specifications 6.5.1.6, 6.8.1.h, 6.8.2, and 6.8.3 will be changed and a new Specification 6.5.3 added as follows:

Existing:

"6.5.1.6 The Plant Review Board shall be responsible for:

"a. Review of 1) all procedures required by Specification 6.8 and changes therato, 2) any other proposed procedures or changes thereto as determined by the General Manager to affect nuclear safety.

"b. Review of all proposed tests and experiments that affect nuclear safety.

"c. Review of all proposed changes to Appendix "A" Technical Specifications.

"d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety."

"6.8.1.h Radiological Effluent Program Implementation."

"6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed by the PRB and approved by the General Manager prior to implementation and reviewed periodically as set forth in administrative procedures."

"6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:

"a. The intent of the original procedure is not altered.

"b. The change is approved by two members of the plant management staff, at least one of whom holds a Senior '

Reactor Operator's License on the unit affected.

"c. The change is documented, reviewed by the PRB and approved by the General Manager within 14 days of implementation."

Proposed:

"6.5.1.6 The Plant Review Board shall be responsible for the:

"a. Review of safety evaluations for: (1) procedures, (2) changes to procedures, equipment, systems or facilities, and (3) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question.

LCA 130, Revision 1 Page 2 of 8 "b. Review of proposed procedures and changes to procedures, equipment, systems or facilities which may involve an unreviewed safety question as defined in 10 CFR 50.59 or involves a change in Technical Specifications.

"c. Review of proposed test or experiments which may involve an unreviewed safety question as defined in 10 CFR 50.59 or requires a change in Technical Specifications.

"d. Review of proposed changes to Technical Specifications or the Operating License."

"6.8.1.h Radiological Effluent Monitoring."

"6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, including temporary changes, shall be reviewed and approved prior to implementation as set forth in Specification 6.5.3 above."

"6.8.3 Temporary changes to procedures of 6.8.1 may be made provided:

"a. The intent of the original procedure is not altered.

"b. For procedures covering activities performed by the Facility Staff, the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected, and documented by the Responsible Manager, within fourteen (14) days of implementation.

"c. For procedures covering activities performed by Company organizations other than the Facility Staff, the change is reviewed and approved in accordance with the Nuclear Quality Assurance Program."

A new Specification 6.5.3, Technical Review and Control, is added as follows:

"6.5.3 TECHNICAL REVIEW AND CONTROL "6.5.3.1 Activities which affect nuclear safety shall be conducted as follows:

"a. Procedures required by Specification 6.8.1 and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved. Each such procedure or procedure change shall be reviewed by a qualified individual other than the individual who prepared the procedure or procedure change, but who may be from the same organization as 1

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LCA 130, Revision 1 Page 3 of 9 the individual who prepsred the procedure or procedure, change.

Procedures shall be approved by the appropriate Responsible Manager as designated in writing by the General Manager, Trojan Nuclear Plant. The General Manager, Trojan, shall approve Administrative Procedures, Security Plan implementing procedures and Radiological Emergency Response Plan implementing procedures.

"b. Proposed changes or modifications to plant nuclear safety-related structures, systems and components shall be reviewed by a qualified individual / group other than the individual / group which designed the modification, but who may be from the same organization as the individual / group which

designed the modifications. Proposed permanent modifications to plant nuclear safety-related structures, systems and components i

shall be approved prior to implementation by the General

! Manager, Trojan Nuclear Plant.

I "c. Proposed tests and experiments which affect plant nuclear safety

and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared, reviewed, and approved. Each such test or experiment shall be reviewed by a qualified individual other than the individual who prepared the proposed test or experiment. Proposed test and experiments shall be approved before implementation.

"d. Individuals responsible for reviews performed in accordance with Specifications 6.5.3.1.a., 6.5.3.1.b., and 6.5.3.1.c.,

! shall be members of the groups designated by approved written I procedures. Each such review shall be performed by qualified

{ personnel of the appropriate discipline.

i l "e. Each review shall include determination of whether or not i an unreviewed safety question is involved. Pursuant to Section 50.59, 10 CFR, NRC approval of items involving unreviewed safety questions shall be obtained prior to the General Manager, Trojen Nuclear Plant, approval for j implementation."

REASON FOR CHANGE l

A new Section 6.5.3 is being added to describe the controls to be placed upon the individual (s) responsible for review of procedure changes in

, lieu of the PRB. The original License Change Application did not specify the necessary level of detail provided in this new Specification.

An editorial change is made to 6.8...h to reflect that no single documented program exists for radiological effluent monitoring.

Instead, there are several procedures that exist to implement the Technical Specification requirements for radiological effluent monitoring and the change will reflect this concept.

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LCA 130, Revision 1 Page 4 of 8 Section 6.8.2 of the Technical Specifications states that each procedure and administrative policy of Specification 6.8.1, and changes thereto, i shall be reviewed by the PRB and approved by the General Manager prior to l implementation, and reviewed periodically as set forth in administrative  !

procedures. This specification, as written, requires PRB review and l General Manager approval of virtually all Plant-related procedures regardless of their safety significance and has resulted in an overload of the PRB and a dilution of the PRB's ability to perform their safety-related activities.

This License Change Application proposes to correct this situation by allowing the administrative policies and procedures of Specifica-tion 6.8.1 to be established, implemented, and maintained in accordance with Specification 6.5.3 without requiring PRB review of the implementing procedures. For completeness, changes to procedures identified in Specification 6.8.1 may be made provided that, for procedures imple-menting activities performed by Company organizations other than the Facility Staff, the change is reviewed and approved in accordance with 1 the Nuclear Quality Assurance Program.

t Allowing onsite procedures to be reviewed and approved in accordance with Specification 6.5.3 should enable the PRB and General Manager to provide i more thorough reviews of other safety-related activities.

The proposed changes to 6.5.3 and 6.8.2 are essentially identical to the

Technical Specifications issued for the Callaway Nuclear Station.

SIGNIFICANT HAZARDS CONSIDERATIONS In accordance with the requirements of 10 CFR 50.92, this License Change Application is judged to involve no significant hazards based upon the following considerations:

1. Does the proposed license amendmant involve a significant increase in the probability or consequences of an accident?

The proposed change deals with administrative controls required for the review of safety-related procedures and changes to safety-related procedures and the review of proposed changes or modifications to Plant systems or equipment. The proposed change would not result'in a decrease in the review process, but only change the method in which the review would occur. An appropriate level of technical review and management approval of changes to safety-related procedures and changes-to Plant systems or equipment would occur after this amend-ment as before. The new review would be performed by and within the department responsible for the procedure, Which is expected to result in a better evaluation. As such, a change.in the administrative controls which has no effect upon the operation of the Plant and that

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. results in an equivalent level of review would have no effect upon the probability or consequences of an accident previously evaluated.

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. l LCA 130, Revision 1 ,

Page 5 of 8 I l

One editorial change is made to 6.8.1.h to more accurately describe the implementation of radiological effluent monitoring. No change i in requirements or implementation is associated with this editorial change so there would be no change in the probability or consequences of an accident.

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2. Does the proposed license amendment create the possibility of a new

or different kind of accident from any accident previously evaluated?

Again, since this proposed change deals with administrative controls required for the review of safety-related procedures, and changes to i safety-related procedures, a possibility of a new or different kind of accident from any previously evaluated would not be affected by this license change request. Procedure review would occur equivalent to the level currently being performed with no new or different kind-

of accidents created. The proposed change would result in no Plant modifications, and no changes to the assumptions or conclusions in the Trojan Safety Analysis Report, nor lead to the creation of any

. new or different kinds of accidents.

The editorial change to 6.8.1.h would not create a new or different i kind of accident from any accident previously evaluated since there is no change in requirements or implementation of requirements.

l 3. Does the proposed amendment involve a significant reduction in a margin of safety?

Finally, the proposed change deals with administrative controls con-cerning the review of safety-related procedures and changes to safety-related procedures, and would have no effect on the safety I analysis or the margin of safety established by the Trojan Safety Analysis Report or by the Technical Specifications. There are no bases in the Technical Specifications for Section 6.0 Technical Specifications, so there would be no char.ge to any bases. Since the margins of safety for Plant operation and equipment operation re-established by the Safety Analysis and provided as limits in the Technical Specifications, this change in administrative controls would have no effect upon those limits and thus would not affect the margin of safety.

The editorial change to 6.8.1.h again would not involve a reduction in a margin of safety since the only change that'is being made is to the title of the category of various implementing procedures.

In the April 6, 1983 Federal Register, the NRC published a list of examples of amendments that are not likely to involve significant hazards 4

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LCA 130, Revision 1 Page 6 of 8 concerns. Example No. 1 of that list states the following to show why this amendment is not considered likely to involve a significant hazards

, consideration:

" Purely administrative change to Technical Specifications: For example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature."

i GAZ/djh 0808W.0486 1

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LCA 130, Revision 1 Page 7 of 8 SAFETY / ENVIRONMENTAL EVALUATION .

Summary of Channe This License Change Application proposes to define more clearly the review

. responsibilities of the PRB, Plant General Manager, other members of Plant Management, and offsite Departmental Managers, and to allow credit for the Nuclear Quality Assurance Program.

L Effect on Technical Specifications /

Effect on Bases for Technical Specifications The Technical Specifications are shown affected as described in the Description of Change and as shown in Attachment 1. The Bases for the Technical Specifications are not affected by this change.

These changes constitute an improvement to the Technical Specifications since the PRB and General Manager review responsibilities are more clearly delineated. Procedural changes which do not directly affect the Facility Staff should not require their review or approval. A requirement for the PRB to review all changes creates an excessive burden that can reduce the available time for review of issues that may affect nuclear safety. By relying upon the Nuclear Quality Assurance Program, the PRB should have more time to thoroughly evaluate safety-related issues. The overall effectiveness of the review process will be assured by the Department responsible for the procedure (eg, Operations for OIs, GOIs, etc).

Effect on FSAR FSAR Secti on 13.4, Review and Audit, which discusses the PRB review respon-sibilities, has already been revised to reflect the changes due to this License Chenge Application.

Environmental Effect 4

l This proposed change will not affect effluent types, amounts or release j

rates and will not result in any significant impact'to the environment.

l No changes to the environmental analyses presented in the FSAR, the Environmental Report or the Final Environmental Statement are required.

Effect on Other Licensina Documents. Commitments, or Criteria i

Other documents, commitments, or criteria reviewed in consideration of this 1 l

LCA are (1) the NRC Safety Evaluation Report (SER) for the Trojan Nuclear Plant dated October 7, 1974 including Supplement 1 (dated November 21, 1975), (2) the NRC Standard Review Plan (NUREG-0800) dated July 1981, (3) NRC Regulatory Guide 1.33, Revision 2, dated February 1978, and i (4) ANSI N18.7-1976/ANS3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants including Draft 8 (dated i April 1981) of a revision to this standard. The change proposed by this LCA is consistent with all of the above documents except for the NRC SER

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LCA 130, Revision 1 Page 8 of 8 which states in Section 13.2, "The Plant Review Board is advisory to the Plant Superintendent and will review all proposed tests, changes in operat-ing procedures, and design modifications." It is not clear if the SER is referring only to the Operating Instructions (OIs), the General Operating Instructions (GOIs), Off-Normal Instructions (ONIs), and Emergency Instructions (EIs) or the entire Plant Operating Manual (POM). In any case, by reviewing the Technical Specifications issued to the plants recently obtaining an Operating License, it is obvious that the NRC position has changed. The Administrative Controls for San Onofre Units 2 and 3, Catawba, and McGuire Nuclear Plants are almost identical to those proposed changes in this LCA, requiring procedures and procedure changes to be reviewed and approved by any one of several plant departmental managers or the Station danager and not the Onsite Review Committee. In addition, the Technical Specification Administrative Controls for Palo Verde, Grand Gulf, Byron, Callaway, Susquehanna, and LaSalle are somewhat similar in that the Onsite Review Committee does not have to review all of the safety-related procedures and procedure changes but only certain ones, or a separate group of individuals is established to perform the necessary reviews. Management review is adequate especially since the TNOB reviews the safety evaluations for procedure changes and the Nuclear Quality Assurance Department performs periodic audits of this activity. It is concluded that this LCA would not have an effect on nuclear safety as a result of any other licensins document, commitment, or criteria.

Review and approval of temporary changes to procedures by the Responsible Manager within thirty (30) days is more than adequate. It has proven difficult in practice to have temporary changes documented, reviewed, and approved within the current Technical Specification requirement of 14 days. Since the temporary changes will already have been reviewed technically by two members of Plant management, this proposed change is purely administrative and does not affect safety.

GAZ/3kal 5537k.585 i

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