ML20078L549

Responds to Request for Addl Info Re License Amend Request 93-08 Re Independent Technical Reviews

ML20078L549
Person / Time
Site:	Seabrook
Issue date:	11/23/1994
From:	Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20078L553	List: ML20078L549 ML20078L556
References
NYN-94131, TAC-M86501, NUDOCS 9411300262
Download: ML20078L549 (3)

Text

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.3 Nordi North Atlantic Energy Service Corporation y.O. nea 300 o

Mgh Seabrook, NH 03874 (603) 474-9521, Fax (603) 474-2987 The Northeast Utilities System Ted C. Feigenbaum Senior Vice president &

NYN- 94131 Chief Nuclear Officer November 23,1994 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk

References:

(a) Facility Operating License No. NPF-86, Docket No. 50-443 (b) North Atlantic Letter NYN-93088 dated June 18,1993, " License Amendment Request 93-08: Independent Technical Reviews (TAC No. M86501)" T. C.

Feigenbaum to USNRC

Subject:

Response to Request for Additional Information, License Amendment Request 93-08:

Independent Technical Reviews (TAC No. M86501)

Gentlemen:

North Atlantic Energy Service Corporation (North Atlantic) proposed in License Amendment Request (LAR) 93-08 [ Reference (b)] that Seabrook Station Technical Speci6 cation 6.2.3, be revised to change the title to independent Technical Reviews and to delete the requirement that a dedicated five person organization known as the Independent Safety Engineering Group (ISEG) be maintained to perform independent reviews. This letter supplements LAR No. 93-08 to address questions raised by the NRC Staff during the review of LAR No. 93-08 and is submitted pursuant to the requirements of 10CFR50.90 and 10CFR50.4. A copy of this letter has been forwarded to the State of New Ilampshire State Liaison Officer pursuant to 10CFR50.91(b).

North Atlantic has long recognized that the current Technical Specification 6.2.3 does not provide flexibility in the performance of the required reviews. The current Technical Specification places an operational constraint upon North Atlantic by requiring the establishment of a separate, dedicated five person organization to perform the reviews specified in Technical Specification 6.2.3. This requirement places unnecessary limitations upon North Atlantic's ability to utilize its resources in the most effective manner and in some cases requires the duplication of effort. The NRC Regulatory Review Group, in its February 1993 report, also noted that the ISEG Technical Specification is very restrictive and does not allow flexible methods to be utilized to more effectively accomplish the required reviews. Furthermore, the Regulatory Review Group noted that a Technical Specification change could be submitted adopting the Improved Standard Technical Specification approach and thereby provide considerable flexibility in the implementation of what is currently the ISEG review requirement.

Technical Specification 6.2.3 states in part that "The ISEG shall function to examine station operating characteristics, NRC issuances, industry advisories, Licensee Event Report, and other sources of station design and operating experience information, including units of similar design which may l indicate areas for improving station safety." North Atlantic had, within the Licensing Services Division, )

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United States Nuclear Regulatory Commission November 23,1994 Attention: Document Control Desk Page two an Operating Experience Review Group (OERG) that was responsible for the review of operating experience infbnnation generated by the NRC and the industry, and for assisting in the review of in-house operating experience events. The OERG performed functions similar to those performed by the ISEG and also made recommendations to improve station safety and performance. The OERG forwarded some items, such as Institute ofNuclear Power Operations (INPO) Significant Operating Event Reports (SOERs) and Significant Event Reports (SERs) to the ISEG for review, llistorically, in instances where the ISEG was not the most qualified organization to perform the review, the OERG performed additional reviews or obtained matrixed assistance from other organizations such as Engineering or vendors to perforra additional reviews.

North Allantic has combined the ISEG organization with the OERG organization within the Licensing Services Division to create an integrated organization known as the Nuclear Safety Engineering Group (NSEG). The NSEG includes the ISEG and continues to perfbrm all of the functions of Technical Specification 6.2.3 and continues to maintain the dedicated five person organization. The NSEG organization reports through the Licensing Manager to the Director of Licensing Services, who reports directly to the Senior Vice President and Chief Nuclear Officer. There is no change in the level of reporting with the integration of the ISEG and the OERG to create the NSEG. The NSEG is independent of the plant management chain.

The integrated organization was created to eliminate duplication of effort and to promote more efTective and eflicient reviews. In addition, this integration ensures that all of the ISEG review requirements specified in Technical Specification 6.2.3 and all of the review responsibilities assigned to the OERG receive the best review possible and that recommendations provide the maximum enhancement to station safety and performance. The NSEG, through the use of matri: ed reviewers, will allow personnel with unique expertise, such as former licensed operators or design engineers, to be utilized in the review process to supplement the capabilities of the NSEG. This organization integration produced a consolidated review of NRC, station and industry operating experience infonnation and events. In add' tion, because the review function is located in the Licensing Services Division, the review efrort bem fits from the close interaction with the Regulatory Compl ance personnel who are in daily contact witl the NRC regarding Seabrook Station and industry issues and events. This contact allows emerging issues to be referred to the NSEG for a prompt review and provides additional resources and expertise that the NSEG can draw upon during the perfbrmance of reviews. North Atlantic believes that the issuance of the requested revision to Technical Speci6 cation 6.2.3 is essential to allow the integrated organization to operate most effectively and promote the performance of effective and quality independent technical xviews.

The StalT has suggested that North Atlantic revise the last sentence of Technical Specification 6.2.3.1 to change the word sufficient to several. The Staff suggested this change to be consistent with the wording in the improved Standard Technical Specifications. North Atlantic agrees with the suggestion and has provided marked up and retyped versions of page 6-5 in the Enclosure. North Atlantic is committed to provide sufficient and appropriate personnel to ensure that the technical reviews specified in Technical Specification 6.2.3 are adequately perfbrmed. North Atlantic will utilize the standard dictionary definition of several as more than two, and will ensure that the NSEG has a lead individual, currently titled the Lead Engineer - NSEG and additional personnel equivalent to average at least two additional personnel assigned to the independent technical review function. The personnel, other than the lead engineer, may be rotated or matrixed as necessary to ensnre the performance of the reviews. In addition, at any given time more or less than two personnel may be utilized in the independent technical

United States Nuclear Regulatory Commission November 23,1994 Attention: Document Control Desk Page three review function, including some on a part time basis for periods to address variations in the workload and to effect the required reviews. Ilowever, the lead engineer position is intended to be a long tenn position i to provide stability and oversight for the independent review function and therefore will not be rotated or matrixed out of the position. North Atlantic is committed to effectively implementing the independent technical review function and will ensure that the reviews specified in Technical Specification 6.2.3 are effectively perfbrmed.

The Staff also questioned at what frequency reports of the independent technical review function would be provided to the Senior Vice President. The NSEG will provide a copy of the monthly perfonnance report to the Senior Vice President. In addition, special reports will be provided on an as requested basis. This monthly reporting requirement has been added to Technical Specification 6.2.3.2.

to provide consistency with the improved Standard Technical Specifications. The revision is included on the marked up and retyped versions of page 6-5 as referenced above. The term Senior Site Official was utilized instead of Senior Vice President to preclude the processing of a Technical Specification change request in the event that company titles should change.

This supplement to License Amendment Request 93-0R has been reviewed and approved by the Station Operation Review Committee and the Nuclear Safety Audit Review Committee.

We trust that this information will facilitate the review and approval of LAR 93-08. Should you have any questions regarding this matter, please contact Mr. Terry L. liarpstergrector c of Licensing Services, at (603) 474-9521, extension 2765, Very truly yours, m

gg g;;&% fr' Ted C. FeigEhbaum TCF:JMP/act cc: Mr. Thomas T. Martin Mr. Richard Laura Regional Administrator NRC Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 1149 Region I Seabrook, Nil 03874 475 Allendale Road King of Prussia, PA 19406 ,

Mr. Albert W. De Agazio, Sr. Project Manager Mr. George L. Iverson, Director Project Directorate 1-4 NH Office of Emergency Management Division of Reactor Projects 107 Pleasant Street U.S. Nuclear Regulatory Commission Concord, Nil 03301 Washington, DC 20555