ML20069P525

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Proposed Tech Specs Re PORC Membership & Review Responsibilities
ML20069P525
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 06/17/1994
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
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ML20069P513 List:
References
NUDOCS 9406240232
Download: ML20069P525 (34)
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i ATTACHMENT l to JPN-94-029 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING !

PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES JPTS-90-011 t

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l New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59 9406240232 940617 PDR ADDCK 05000333 P PDR

, JAFNPP 6.3 PLANT STAFF QUALIFICATIONS 6.3.1 The minimum qualifications with regard to educational background and experience for plant staff positions shown in FSAR Figure 13.2-7 shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions; except for the Radiological and Environmental Services Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975. ,

6.3.2 The Shift Technical Advisor (STA) shall meet or exceed the minimum requirements of either Option 1 (Combined SRO/STA Position) or Option 2 (Continued use of STA Position), as defined in the Commission Policy Statement on Engineering Expertise on Shift, published in the October 28,1985 Federal Register (50 FR 43621). When invoking Option 1, the STA role may be filled by the Shift Supervisor or Assistant Shift Supervisor. (1) 6.3.3 Any deviations will be justified to the NRC prior to an individual's filling of one of these positions.

NOTE:

(1) The 13 individuals who hold SRO licenses, and have completed the FitzPatrick Advance ' Nhnical Training Program prior to the issuance of License Amendment 111, st' to insidered qualified as dual-role SRO/ STAS.

6.4 RETRA /! '.G AND REPLACEMENT TRAINING A training program shall be maintained under the direction of the Training Manager to assure overall pruficiency of the plant staff organization. It shall consist of both retraining and replacer at training and shall meet or exceed the minimum requirements of Secr a 5.5 of ANSI N18.1-1971.

The retraining program shall not exceed periods two years in length with a curriculum designed to meet or exceed the requalification requirements of 10 CFR 55.59. In addition, fire brigade training shall meet or exceed the requirements of NFPA 27-1975, except for Fire Brigade training sessions which shall be held at least quarterly. The effective date for implementation of fire brigade training is March 17,1978.

1 6.5 REVIEW AND AUDIT Review requirements are accomplished by using designated technical reviewers / qualified safety reviewer and two separate review committees. The Plant Operating Review Committee (PORC) is an onsite review group; the Safety Review Committee (SRC) is an independent offsite review and audit group.

6.5.0 REVIEW AND APPROVAL OF PROGRAMS AND PROCEDURES 6.5.0.1 The procedure review and approval process shall be controlled and implemented by administrative procedure (s).

6.5.0.2 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes tt'ereto, shall be reviewed by a minimum of two designated technical reviewers who are knowledgeable in the affected functional area.

Amendment No. 22 s 34,57,99, 41,134, M7, W8, MO, 248

. 4 JAFNPP 6.5.0.3 Designated technical reviewer (s) shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions.

6.5.0.4 The designated technical reviewer shall determine the need for cross-disciplinary reviews.

Individuals performing cross disciplinary reviews shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions.

6.5.0.5 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall be reviewed from a safety perspective by a qualified safety reviewer. Safety and/or environmental impact evaluations, when required, shall be reviewed by PORC per Specification 6.5.1.6.a.

6.5.0.6 Nuclear safety related procedures and procedure changes shall be reviewed and approved, prior to implementation, by the appropriate member (s) of management.

6.5.1 PLANT OPERATING REVIEW COMMITTEE (PORC) 6.5.1.1 Function PORC shall function to advise the Resident Manager on matters related to nuclear safety and environmental impact.

6.5.1.2 Membership The Plant Operating Review Committee shall be composed of the:

Chairman: General Manager - Operations Vice-Chairman / Member: General Manager - Support Services Vice-Chairman / Member: General Manager - Maintenance Member: Operations Manager Member: Maintenance Manager Member: Technical Services Manager Member: Instrument and Controls Manager Member: Radiological and Environmental Services Manager ,

Member: Site Engineering Manager l Member: Reactor Analyst Supervisor ,

Special consultants to provide expert advice may be utilized when the nature of a particular i problem dictates.

Amendment No. 34. 5% Na, 248a

JAFNPP 6.5.1.3 Alternates Alternate members shall be appointed in writing by the PORC Chairman to serve on a temporary basis.

6.5.1.4 Meeting Frequency Meetings will be called by the Chairman as the occasions for review or investigation arise.

I Meetings will be no less frequent toan once a month.

6.5.1.5 Quorum A quorum of the PORC shall consist of the Chairman or one of two Vice-Chairmen and five members including designated alternates. Vice-Chairmen may act as members when not acting as Chairman. A quorum shall contain no more than two alternates.

l 6.5.1.6 Responsibilities The PORC shall be responsible for the:

a. Review of 10 CFR 50.59 safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8, and changes thereto.
b. Review of proposed tests and experiments that affect nuclear safety.
c. Review of proposed changes to the Operating License and Technical Specifications.
d. Review of proposed changes or modifications to plant systems or equipment that affect nuclear safety.
e. Investigation of violations to the Technical Specifications. The PORC shall prepare and present a report covering the evaluations and recommendations to prevent recurrence to the Resident Manager, who will then forward the report to the Executive Vice President -

Nuclear Generation and to the Chairman of the Safety Review Committee.

f. Review of plant operations to detect potential safety hazards.
g. Performance of special reviews and/or investigations at the request of the Resident Manager,
h. Review of all reportable events.
i. Review of the Process Control Program and the Offsite Dose Calculation Manual (ODCM) and changes thereto.

Amendment No. R, M, %, Na, 249

_ ~ _ _ - _ _ _ . _ _ _ _ _ _ _ _ _

JAFNPP l l

t 6.5.1.7 Authority The PORC shall:

a. Recommend to the Resident Manager, approval or disapproval of those items reviewed under Specifications 6.5.1.6.a through 6.5.1.6.d. ,

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b. Render determinations with regard to whether or not items considered under l Specification 6.5.1.6.a through 6.5.1.6.e constitute an Unreviewed Safety Question as defined in 10 CFR 50.59.  ;
c. In the event of a disagreement between the PORC and Resident Manager, notify [

the Executive Vice President - Nuclear Generation and the SRC Chairman, or their designated alternates, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provide written notification by the next  ;

business day. The Resident Manager shall have responsibility for resolution of such _;

disagreement pursuant to Section 6.1.

6.5.1.8 Records  ;

Minutes of all meetings of the PORC shall be recorded and numbered. Copies will be  !

retained in file. Copies will be forwarded to the Chairman of the SRC and the Executive Vice President - Nuclear Generation.

l; 6.5.1.9 Procedures Conduct of the PORC and the mechanism for implementation of its responsibilities and l authority are defined in the pertinent Administrative Procedures. l l

6.5.2 SAFETY REVIEW COMMITTEE (SRC) ,

FUNCTION l 6.5.2.1 The SRC shall function to provide independent review and audit of designated j activities in the areas of: ,

a. Nuclear power plant operations
b. Nuclear engineering ,
c. Chemistry and radiochemistry j
d. Metallurgy
e. Instrumentation and control l

Amendment No. 50,ita. Ba, B4, MO, 1 250

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JAFNPP

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B",10 CFR 50, at least once per 24 months.
e. Any other area of facility operation considered appropriate by the SRC or the Executive Vice President-Nuclear Generation.
f. The Facility Fire Protection Program and implementing procedures at least once per two years.
g. An independent fire protection and loss of prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.
h. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
i. The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.
j. The Offsite Dose Calculation Manual and implementing procedures at l least once per 24 months.
k. The Process Control Program and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
l. The performance of activities required by the Quality Assurance Program j to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

AUTHORITY 6.5.2.9 The SRC shall report to and advise the Executive Vice President - Nuclear Generation on those areas of responsibility specified in Section 6.5.2.7 and 6.5.2.8.

Amendment No. ABO,,65.,4 RH  !

252a

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JAFNPP CHARTER 6.5.2.11 Conduct of the committee will be in accordance with a charter approved by the Executive Vice President - Nuclear Generation setting forth the mechanism for implementation of the committee's responsibilities and authority. I 6.6 REPORTABLE EVENT ACTION The following actions shall be taken for Reportable Events:

(A) The Commission shall be notified and a report submitted pursuant to the requirements of Section 50.73 to 10 CFR Part 50, and ,

(B) Each Reportable Event shall be reviewed by the PORC, and the results of this review shall be submitted to the SRC and the Executive Vice President - Nuclear Generation.

6.7 SAFETY LIMIT VIOLATION (A) If a safety limit is exceeded, the reactor shall be shut down and reactor operation shall only be resumed in accordance with the provisions of 10 CFR 50.36, (c) (i).

(B) An immediate report of each safety limit violation shall be made to the NRC by the Resident Manager. The Executive Vice President - Nuclear Generation and Chairman of the SRC will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(C) The PORC shall prepare a complete investigative report of each safety limit violation and include appropriate analysis and evaluation of: (1) applicable circumstances preceding the occurrence, (2) effects of the occurrence upon facility component systems or structures and (3) corrective action required to prevent recurrence. The Resident Manager shall forward this report to the Executive Vice President - Nuclear Generation, Chairman of the SRC and the NRC.

6.8 PROCEDURES i l

(A) Written procedures and administrative policies shall be established, implemented, and maintained that:

1. meet or exceed the requirements and recommendations of Section 5 of ANSI 18.7-1972 " Facility Administrative Policies and Procedures."
2. are recommended in Appendix A of Regulatory Guide 1.33, November 1972.
3. implement the Fire Protection Program.
4. include programs specified in Appendix B of the Radiological Effluent Technical Specifications, Section 7.2.

(B) Each procedure of Specification 6.8.(A), and changes thereto, shall be approved prior to implementation by the appropriate responsible member of management as specified in Specification 6.5.0.

Amendment No. 50, 60, 85, 76, sa, MQ, 253

JAFNPP (C) Temporary changes to the procedures required by Specification 6.8.(A) may be made provided:

1. the intent of the original procedure is not altered.
2. the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's license.
3. the change is documented, reviewed and approved by the appropriate member of plant management as required by Specification 6.5.0 within 14 days of implementation.

6.9 REPORTING REOLilREMENTS (A) ROUTINE REPORTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.

1. STARTUP REPORT
a. A summary report of plant startup and power escalation testing shall be submitted following (1) amendment to the license involving a planned increase in power level, (2) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (3) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report shall address each of the tests identified in the FSAR and shall include a description of the measured values of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other commitments shall be included in this report.

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t Amendment No.h 2R,32, t4Q, 254-a i

ATTACHMENT ll to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES JPTS-90-011 i

New York Power Authority JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 DPR-59

Attachment 11 to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) ,

I. DESCRIPTION OF THE PROPOSED CHANGES The proposed changes to the James A. FitzPatrick Technical Specifications delegate a portion of the Plant Operations Review Committee's (PORC's) procedure review responsibilities for nuclear safety related procedures and procedure changes to the line organizations. PORC will continue to perform safety reviews associated with procedures i that are of safety significance. The proposed procedure review and approval process v will alter the . scope of the PORC function to be more appropriate for that of a safety oversight committee by reducing the administrative burden on the PORC.

A change is also being proposed to the PORC Membership requirements to remove the Resident Manager from PORC. The General Manager of Operations is being proposed as the Chairman of PORC.

In addition, a change is also being proposed to implement the guidance of Generic Letter 93-07. This Generic Letter discusses the removal of the review and audit responsibilities for the Emergency and Security Plans from the technical specifications.

These requirements shall be relocated to the respective Emergency and Security Plans.

The changes to the James A. FitzPatrick Technical Specifications are separated into two categories: A). Administrative and editorial changes which improve the human factors aspects of the Technical Specifications; and B). changes to reflect the implementation of the procedure review and approval process, changes to PORC Membership and i changes to implement the guidance of Generic Letter 93-07.

A. Administrative and editorial changes

1. Page 248a. Soecification 6.5.11A)
a. In the Specification outline numbering pattern, replace section number "(A)" with "6.5.1.2".
2. Page 249
a. In the Specification outline numbering pattern, replace Section numbers *(B)",

"(C)", "(D)" and "(E)" with "6.5.1.3", "6.5.1.4", "6.5.1.5", and "6.5.1.6", respectively.

b. Renumber the " Responsibilities" section "1 through 12" as "a through i". Item numbers 7 and 8 have been removed to implement the guidance of Generic Letter 93-07. Note that "11" and "12" have been combined into one line item, "i".
c. In section 6.5.1.6.e, replace the position title " Manager- Nuclear Operations" with

" Executive Vice President-Nuclear Generation."

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. Attachment il to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)

3. Page 250 l

In the Specification outline numbering pattern, replace "(F)", "(G)", and "(H)" with  !

, "6.5.1.7", "6.5.1.8" and "6.5.1.9", respectively. l l l 4 Pace 253 Replace Section 6.8.(A) on page 253 (current TS) with 6.8.(A) on page 253 of the proposed Technical Specifications. The format of this section was changed from a l paragraph form to an outline form. l l

B. Proposed changes to the procedure review and approval process, I implementation of the guidance of Generic Letter 93-07 and changes to the  !

PORC membership requirements are identified below (note that all sections i are now referenced with the new, proposed outline numbering pattern).

1. Paae 248. Soecification 6.5 Replace section 6.5 with " Review requirements are accomplished by using ,

designated technical reviewers / qualified safety reviewer and two separate review l committees. The Plant Operating Review Committee (PORC) is an onsite review group, the Safety Review Committee (SRC) is an independent offsite review and .

audit group". I Pace 248. Soecification 6.5.0 insert new Section 6.5.0, titled " Review and Approval of Programs and Procedures" (see attached prcposed TS pages 248 and 248a for exact wording).

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2. Paae 248a. Soecification 6.5.1
a. Insert section 6.5.1.1 titled " Function" with the following sentence, "PORC shall function to advise the Resident Manager on matters related to nuclear safety and environmental impact". ,
b. Remove the " Resident Manager" as Chairman and replace with the " General Manager-Operations" in section 6.5.1.2.
3. Page 249
a. In 6.5.1.3, remove "however, no more than two alternates shall participate in '

PORC activities at any one time".

b. In 6.5.1.5, add the sentence,"A quorum shall contain no more than two alternates".

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Attachment il to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)

c. In 6.5.1.6.a replace " Review plant procedures, and changes thereto, required by Specification 6.8" with " Review of 10 CFR 50.59 safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8 and changes thereto".
d. Add the phrase "The PORC shall be responsible for the:" at the beginning of 6.5.1.6. Minor changes are rnade in 6.5.1.6.a through i to make them grammatically consistent with the new phrase "The PORC shall be responsible for the:".
e. Replace sections 6.5.1.6.e with " Investigation of violations to the Technical Specifications. The PORC shall prepare and present a report covering the evaluations and recommendations to prevent recurrence to the Resident Manager, who will then forward the report to the Executive Vice President -

Nuclear Generation and to the Chairman of the Safety Review Committee".

f. Remove what used to be line items 7 and 8 from the list of PORC responsibilities.
g. Combine what used to be line items 11 and 12 into one line, "i" which states

Review of the Process Control Program and the Offsite Dose Calculation Manual (ODCM) and changes thereto".

4. Pace 250
a. Replace Specification 6.5.1.7 titled " Authority" with the following:

"The PORC shall:

a. Recommend to the Resident Manager, approval or disapproval of those items reviewed under Specifications 6.5.1.6.a through 6.5.1.6.d.
b. Render determinations with regard to whether or not items considered under Specification 6.5.1.6.a through 6.5.1.6.e constitute an Unreviewed Safety Question as defined in 10 CFR 50.59.
c. In the event of a disagreement between the PORC and Resident Manager, notify the Executive Vice-President Nuclear Generation and the SRC Chairman, or their designated altemates, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provide written notification by the next business day. The Resident Manager shall have responsibili'.y for resolution of such disagreement pursuant to Section 6.1."
5. Pace 252a I

Rernove requirements to review and audit sections 6.5.2.1.e and f from the technical specifications. Items "g through I" are relettered to accommodate this change.

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.Attachmant ll to JPN-94-029  ;

SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING  !

PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) i

6. Paae 253
a. Replace section 6.8.(B) on page 253 (current TS) with 6.8.(B) on page 253 of the proposed Technical Specifications. -
7. Pace 254-a
a. Replace section 6.8.(C) with " Temporary changes to the procedures required by I Specification 6.8.(A) may be made provided:"
b. Replace section 6.8.(C).2 with "The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's ;

license".

c. Replace section 6.8.(C).3 with "the change is documented, reviewed and  ;

approved by the appropriate member of plant management as required by  ;

Specification 6.5.0 within 14 days of implementation." '

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lI. PURPOSE OF THE PROPOSED CHANGES  !

The proposed changes to the James A. FitzPatrick Technical Specifications reduce the administrative burden on the Plant Operating Review Committee (PORC) by establishing '

a procedure review and approval process which shifts a portion responsibility for the )'

review of nuclear safety related procedures and procedure changes from the PORC to the line organizations. PORC will continue to review any new procedures and procedure changes that are of safety significance. These changes alter the scope of PORC's review function to be more appropriate to that of a safety oversight committee.

Currently, all Technical Specification required procedures and changes thereto must be reviewed by PORC. Instead, these items will be reviewed and approved through a new procedure review and approval process.

Specifications for the procedure review and approval process are being added. The new process shall be controlled by adrninistrative procedures. The process requires that all nuclear safety related procedures and procedure changes be reviewed by two designated technical reviewers, a qualified safety reviewer and approved by a responsible procedure owner. The designated technical reviewers verify the technical accuracy and useability of procedures and revisions including human factors considerations. The qualified safety reviewer performs the 10 CFR 50.59 safety and environmental impact screening and evaluation associated with the procedure or procedure change.

Another Technical Specification change is being proposed which will remove the l Resident Manager from PORC. The General Manager of Operations is being proposed l as the Chairman of PORC.  !

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Attachment 11 to JPN-94-029 SAFETY EVALUATION FOR

~ PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)  ;

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In addition, a change is also being proposed to the Technical Specifications to  !

implement the guidance of Generic Letter 93-07. This Generic Letter discusses the removal of the review and audit responsibilities for Emergency and Security plans from the Technical Specifications. These requirements shall be relocated to the respective  :

Emergency and Security Plans.

The purpose of each change identified in Section I (the letters and numbers in Sections I  !

and 11 correspond) is as follows: i k

A. Administrative changes have been made to the Specification outline numbers i to be consistent with the pattern used elsewhere in the Technical '

Specifications. Editorial changes have also been made to clarify and improve the quality of the Technical Specifications. These editorial changes do not  :

involve any safety issues.

B. The following changes reflect the implementation of the procedure review and 3 approval process, changes to the PORC Membership requirements and changes to implement the recommendations of Generic Letter 93-07. i

1. Pace 248. Soecification 6.5 The proposed change adds the use of " designated technical reviewers" and qualified -

safety reviewer (s)" in the review and audit process. Safety / technical reviewers will pedorm reviews of procedures and procedure changes prior to approval by the '

responsible procedure owner.

Paae 248. Soecification 6.5.0 A new section (6.5.0) is proposed which sets forth the principal provisions of the review and approval of programs and procedures. The review and approval of programs and procedures is outlined below and shall be controlled by an administrative procedure as required by Appendix A of Regulatory Guide 1.33,1972.

l Technical Specification 6.8.(A).2 requires that an administrative procedure be i maintained and established covering procedure review and approval activities.

1. Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall also be reviewed by two designated technical reviewers who are knowledgeable in the functional area affected. Designated technical reviewers shall meet or exceed the qualifications-described in Section 4 of ANSI N18.1-1971 for applicable positions. A designated technical reviewer shall also identify when cross-disciplinary reviews i are required. Designated technical reviewers shall be approved by the  ;

Department Managers. '

2. If necessary, cross-disciplinary reviews shall be performed by additional ,

designated technical reviewer (s).

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. Attachment 11 to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)

3. Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, will be reviewed by a qualified safety reviewer. The qualified safety reviewer evaluates the procedure from a safety perspective. This reviewer completes the 10 CFR 50.59 safety and environmental impact screening and evaluation.
4. Each new procedure or proposed procedure change required by Specification 6.8 shall be reviewed by the responsible procedure owner. The responsible procedure owner is to ensure that the proposed activity has been prepared, documented, and reviewed in accordance with the administrative procedure governing the procedure review and approval process.
5. If a safety or environmental impact evaluation is not required, the new procedure ,

or procedure change shall receive final approval by the responsible procedure owner prior to implementation. PORC review is not required.

6. If a safety or an environmental impact evaluation is required, it shall be reviewed by PORC. The new procedure or procedure change shall receive final approval by the responsible procedure owner.
7. Proposed changes to the Process Control Program and the Offsite Dose Calculation Manual must be reviewed and approved by the PORC prior to implementation whether or not a safety or an environmental impact evaluation is necessary.
8. Designated technical reviewers in the various functional areas shall be approved by the Department Manager. Designation of responsible procedure owners for l each procedure type shall be approved by the Resident Manager.
9. Temporary procedure changes shall be reviewed and approved in a similar  ;

manner to the procedure review and approval process. 1

2. Paae 248a. Soecification 53.J,

)

a. The proposed change moves the description of PORC's function to the beginning of the Section. In the current Technical Specifications, this portion of PORC responsibility is described in TS 6.5.1.F. This change is for clarity and improvement in the Technical Specifications,
b. The proposed change eliminates the Resident Manager from PORC. The Resident Manager should be independent of PORC since PORC's function is to act in an advisory role to the Resident Manager. The Resident Manager will remain as a voting member of the SRC. This would allow the Resident Manager l to participate in the SRC's oversight role without any conflict of interest.

The level and quality of the PORC's review would not be adversely altered by the 1 6

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, Attachment il to JPN-94-029 i

SAFETY EVALUATION FOR >

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING .

PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) proposed changes. The PORC quorum is currently composed of a Chairman and five members of which no more than two are designated alternates. This composition is not diminished by the proposed changes. The Technical Specifications retain the same PORC quorum requirement.

3. Pace 249
a. (and b.) Specification 6.5.1.3 and 6.5.1.5; The sentence "however, no more than two altemates shall participate in PORC activities at any one time" was removed and replaced in Specification 6.5.1.5 for the purpose of clarity and improvement in the Technical Specifications,
c. The proposed change revises Specification 6.5.1.6.a to identify that PORC <

reviews 10 CFR 50.59 safety and environmental impact evaluations associated with procedures in accordance with the new proposed procedure review and approval process.

d. The phrase "The PORC shall be responsible for"is added to make this section consistent with the Standard Technical Specifications (STS, Reference 5).
e. The proposed editorial change is needed to make the sentence grcmmatically s correct with the addition of the phrase in the above section d.
f. This change removes what used to be items 7 and 8 to incorporate the guidance of Generic Letter 93-07.
g. This change is made for consistency with the contents of the STS. I
4. Pace 250 The proposed change alters the format of this section from a paragraph form to an outline form. The statement "The PORC shall function to advise the Resident Manager on all matters related to nuclear safety and environmental operations" has been moved from this section to Section 6.5.1.1. This is purely an administrative change.
5. Pace 252a  !

l This change is made to incorporate the guidance of Generic Letter 93-07. I

6. Pace 253
a. The proposed change in section 6.8.(B) allows for an appropriate responsible member of management to approve procedures rather than the Resident Manager. l This specification is changed to allow for the implementation of the proposed '

procedure review and approval process. " Appropriate responsible member of 4

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Attachment ll to JPN-94-029 l l

SAFETY EVALUATION FOR

{

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING '

PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) management" is defined as the responsible procedure owner.

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b. This change clarifies the fact that the procedures contained in section 6.8.(A) can go through the temporary procedure change process.
c. The proposed change removes "on the unit affected" from the sentence since the James A. FitzPatrick Plant is a single unit plant.
d. The proposed change allows for temporary procedure changes to be reviewed per the procedure review and approval process and approved by the responsible procedure within 14 days. PORC review of the temporary procedure changes may or may not be required depending on whether or not the procedure change has a safety or environmental impact evaluation associated with it. The responsible procedure owner is responsible for ensuring that the intent of the procedure is not changed. The current Technical Specifications require each temporary procedure to be reviewed by PORC and approved by the Resident Manager.

111. IMPACT OF THE PROPOSED CHANGES Procedure Review and Approval Process The proposed procedure review and approval process requires that PORC review safety and environmental impact evaluations associated with procedures and procedure changes. These changes alter the scope of PORC's review function by eliminating reviews of items that do not impact the environment or nuclear safety and, therefore, enhance PORC's function by improving its efficiency and effectiveness. PORC can then focus its attention on matters which could affect nuclear safety.

The proposed process establishes flow and documentation requirements for the review and approval of all nuclear safety related procedures and procedure changes. The l program builds on a nuclear safety evaluation process which will be implemented through administrative procedures.

The Authority will implement a new administrative procedure to govern the 10 CFR 50.59 reviews of proposed procedure changes. This procedure will meet the intent of the guidance contained in EPRI report NSAC-125, " Guidelines for 10 CFR 50.59 Safety i Evaluations" (Reference 3). The " safety review" is a two step process comprised of 1) a '

Nuclear Safety and Environmental Impact Screening and 2) a Nuclear Safety Evaluation (10 CFR 50.59 safety evaluation) and/or an Environmental Impact Evaluation. The screen consists of a series of questions whose responses determine whether or not a Nuclear Safety and/or Environmental impact Evaluation is required. The results of the screening process, and safety and/or environmental impact evaluations will be documented in writing. If a safety or an environmental impact evaluation is not required, the screening alone constitutes a complete safety review. If the safety review for a new procedure or procedure change conclude that a safety or an environmental evaluation is required, then the evaluation (s) shall be prepared and then reviewed by PORC.

8

l Attachment 11 to JPN-94-029 i SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-0111 Personnel completing safety reviews will be appropriately qualified and trained to perform this function. If qualified to do so, the same individual may prepare both the safety and environmental impact screening and evaluation.  !

l The completed procedure or procedure change package is reviewed by two designated '

technical reviewers. The designated technical reviewers are individuals knowledgeable in the functional / technical subject matter related to the proposed activity. Designated I technical reviewers are designated by the Department Managers. Designated technical reviewers shall be responsible for reviewing the procedure or procedure change for ,

adequacy, completeness, and accuracy. Designated technical reviewers shall also be i responsible for identifying whether or not cross-disciplinary reviews are required. A

  • designated technical reviewer can be the same individual as the qualified safety reviewer if qualified to perform both functions. Designated technical reviewers shall meet or exceed the qualifications described in section 4 of ANSI N18.1-1971 for applicable positions. ANSI N18.1-1971 is applicable with the selection and training of nuclear power plant personnel. Section 4 of this Standard applies to qualifications of plant ,

personnel. ,

If necessary, cross-disciplinary reviews shall be performed by other appropriate  :

designated technical reviewer (s) before the procedure or procedure change is forwarded  :

to the approving authority. After all the necessary reviews (safety and technical reviews)  ;

have been completed, the procedure or procedure change package is reviewed by the responsible procedure owner. The " responsible procedure owner"is a member of the  :

management staff having approving authority and responsibility for specific procedures.

The responsible procedure owner is responsible for ensuring that the proposed activity has been prepared, documented and reviewed in accordance with the administrative ,

procedure that governs the procedure review and approval process. The responsible  !

procedure owner is the appropriate member of management as described in the Technical Specification.

l if a safety / environmental impact evaluation is not required, the new procedure or procedure change receives final approval by the responsible procedure owner. PORC review is not required. If, however, an evaluation is required, PORC is responsible for reviewing the safety /environmentalimpact evaluation. Responsible procedure owners are designated by the Resident Manager.

1 As currently specified, temporary changes to procedures listed in Specification 6.8.(A) may be made provided the intent of the original procedure is not altered, and the change is approved by two members of the plant management, at least one of whom holds a Senior Reactor Operator's License. Temporary procedure changes will be approved by the responsible procedure owner within 14 days. The responsible procedure owner will be responsible to ensure that the intent of the procedure is not changed.

9 l l

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l Attachment il to JPN-94-029 SAFETY EVALUATION FOR  ;

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING j PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) '

i l

l PORC Membership ,

1 An onsite review group (PORC) at JAF was established to assist the plant Resident i Manager in keeping abreast of general plant operating conditions in accordance with

)

American National Standard (ANS) N18.7-1972. PORC's function is to advise the  ;

Resident Manager in matters related to the nuclear safety and environmental impact.

l The proposed change to Technical Specification 6.5.1.2 to remove the Resident Manager from the PORC would strengthen PORC's independent advisory role. Any influence exhibited by the routine presence of the Resident Manager, whether perceived or actual, would be alleviated and members would be free to make decisions and recommendations based on their own judgements. The Committee's collective but independent recommendation would then be presented to the Resident Manager.

it is proposed that the General Manager-Operations replace the Resident Manager as PORC Chairman. The General Manager-Operations has the appropriate level of education and experience necessary to ensure that decisions made by the PORC will  !

consider safety as the primary consideration. The proposed changes in membership / chairmanship do not adversely alter the level and quality of PORC's review function. Diversity in educational background and work experience will continue to exist. I Additionally, the quorum requirement will not be diminished. The quorum will continue to be comprised of a Chairman and five members (a majority) of which no more than two are designated alternates.

Additional Changes Other changes include the deletion of what used to be Technical Specification sections 6.5.1.E.7,6.5.1.E.8,6.5.2.1.e, and 6.5.2.1.f to implement the recommendations of NRC Generic Letter 93-07. The Generic Letter allows Technical Specification changes to  !

remove the review and audit requirements for the emergency and security plans from the  !

unit review group (known as PORC at JAF) and the company nuclear audit and review group (known as the Safety Review Committee or SRC at the Authority's headquarters i office) list of responsibilities provided these requirements are relocated to the respective emergency and security plans. l The proposed changes to JAF Technical Specifications 6.5.1.E.7 and 6.5.2.1.f delete the annual review and audit requirements, respectively, for the JAF Security Plan from the list of responsibilities of PORC and SRC. Likewise, the proposed changes to Technical Specifications 6.5.1.E.8 and 6.5.2.1.e delete the annual review and audit requirements, respectively, for the JAF Emergency Plan from the list of responsibilities of PORC and SRC. The review and audit requirements will be relocated to the respective security and emergency plans. The changes are in accordance with NRC Generic Letter 93-07 and are administrative in nature.

10

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, Attachment 11 to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING EQRC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) '

IV. EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION Operation of the FitzPatrick plant in accordance with the proposed amendment would not involve a significant hazards consideration as defined in 10 CFR 50.92, since the proposed changes would not:

1. involve a significant increase in the probability of an accident or consequence  ;

previously evaluated.

The proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated since: 1) PORC will continue to review environmental impact and 10 CFR 50.59 safety evaluations associated with procedures and procedure changes; 2) Only personnel knowledgeable in the affected functional areas will review procedures and procedure changes; 3) Review and approval personnel (designated technical reviewers, and responsible procedure  ;

owners) will be identified in the appropriate administrative procedures. Designated technical reviewers shall meet or exceed the qualifications described in section 4 of '

ANSI N18.1-1971 for applicable positions. Designated technical reviewers are ,

designated by the Department Managers. The responsible procedure owners are designated by the Resident Manager; 4) The designated technical reviewers will be responsible for identifying whether additional cross-disciplinary reviews are required;

5) The qualified safety reviewers will be responsible for reviewing the procedure changes from a safety perspective; and 6) The responsible procedure owners will be responsible for verifying that procedure reviews are performed in accordance with the administrative procedure governing the procedure review and approval process.

The proposed changes 1) will add more detailed requirements regarding procedure {

review and approval to the Technical Specifications which will strengthen the controls  ;

over the process, and 2) will free PORC from reviewing items that are outside the j charter of a " safety review" committee because non-safety significant items can 1 reduce the time that PORC members can spend on matters that are safety significant. The proposed Technical Specification change establishes a highly structured review and approval program for procedures.

The proposed change to the PORC Membership requirements would not significantly increase the probability or consequences of an accident because it does not adversely affect the level of expertise applied to the PORC review function. There will not be an adverse loss of PORC effectiveness as a result of this change. The PORC quorum is currently composed of five members including up to two designated alternates and a Chairman. This composition is not changed by the proposed amendment.

The miscellaneous administrative changes not related to the procedure review and approval process or the PORC Membership requirements cannot affect the probability or consequences of an accident because they do not affect operations, equipment, or any safety-related activity. i 11

Attachment ll to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)

2. create the possibility of a new or different kind of accident from those previously evaluated.

No physical changes to the plant or changes in plant equipment operating procedures are being proposed. The changes are administrative and will not have any direct affect on equipment important to safety. Changing the process by which procedures are reviewed and approved cannot in itself create the possibility of a new or different kind of accident. Furthermore, a documented safety review, utilizing screening criteria, will be performed for all nuclear safety related procedures and procedure changes. The proposed change establishes detailed controls while allowing PORC to spend more time on safety significant issues.

The proposed change to the PORC Membership requirements would not create the possibility of a new or different kind of accident from any previously evaluated since no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.

The miscellaneous administrative changes not related to the procedure review and approval or the PORC Membership requirements cannot create the possibility of an accident because they do not affect operations, equipment or any safety-related activity.

3. involve a significant reduction in the margin of safety.

The proposed amendment does not involve a significant reduction in the margin of safety because a program controlled by Administrative Procedures using designated technical reviewers approved by the Department Managers will be in place to review new procedures and procedure changes. A 10 CFR 50.59 screening of each new procedure and permanent procedure change will be performed by a qualified safety reviewer and PORC will continue to review 10 CFR 50.59 Safety and Environmental Impact Evaluations associated with procedures and procedure changes. Cross-disciplinary reviews will be conducted as appropriate. Thus the margin of safety will be maintained by in plementing the new procedure review and approval process.

The proposed change to the PORC Membership requirements would not involve a significant reduction in the margin of safety since the level and quality of PORC review will be maintained and there will not be an adverse change to the collective educational background and work experience of PORC. There will not be an adverse loss of PORC effectiveness as a result of this change. The PORC quorum is currently composed of five members including up to two designated alternates and a Chairman. This composition is not changed by the proposed changes.

The miscellaneous administrative changes not related to the procedure review and approval process or PORC Membership program cannot reduce any margin of safety because they do not affect any safety-related activity or equipment. These changes increase the probability that the Technical Specifications are correctly interpreted by 12

Attachment 11 to JPN-94-029 SAFETY EVALUATION FOR PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011) clarifying information. I

)

V. IMPLEMENTATION OF THE PROPOSED CHANGES Implementation of the proposed changes will not adversely affect the ALARA or Fire l Protection Program at the FitzPatrick plant, nor will the changes impact the environment. ,

l VI. CONCLUSION l l

The changes, as proposed, do not constitute an unreviewed safety question as defined j in 10 CFR 50.59. That is, they:

a. will not increase the probability of occurrence or the consequences of an accident or  :

malfunction of equipment important to safety as previously evaluated in the safety i analysis report; '

b. will not increase the possibility of an accident or malfunction of a different type from l any evaluated previously in the safety analysis report; and l

\

c. will not reduce the margin of safety as defined in the basis for any technical ,

specification; and j

d. involve no significant hazards consideration, as defined in 10 CFR 50.92.

Vll. REFERENCES l

1. James A. FitzPatrick Nuclear Power Plant Updated Final Safety Analysis Report I (FSAR).
2. James A. FitnPatrick Nuclear Power Plant Safety Evaluation Report (SER), dated Novembei % 1972, and supplements thereto.

i

3. EPRI report, NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations", June  ;

1989. <

4. James A. FitzPatrick Nuclear Power Plant Technical Specifications.
5. NUREG-1433," Standard Technical Specifications for General Electric Boiling Water Reactors" Revision 0, dated September 28,1992.

~

6. NRC Generic Letter 93-07, dated December 28,1993, "Mc f Wion of the Technical Specification Administrative Control Requirements for Emes .y and Security l

. Plans." '

13

, Attachment il to JPN-94-029 SAFETY EVALUATION FOR '

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING l PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES (JPTS-90-011)  ;

I

7. American National Standard (ANS) N18.7, " Administrative Controls for Nuclear Power '

Plants," 1972.

8. Regulatory Guide 1.33 (Safety Guide 33), " Quality Assurance Program Requirements (Operation)," November 1972.
9. American National Standard Institute (ANSI) N18.1, " Selection and Training of l Nuclear Power Plant Personnel," 1971. I 1

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f i

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i 14 j

Attachment 111 to JPN-94-029 CURRENT TECHNICAL SPECIFICATION TO BE CHANGED REGARDING PORC MEMBERSHIP AND REVIEW RESPONSIBILITIES JPTS-94-XXX t

h b

9 b

J New York Power Authority

  • JAMES A. FITZPATRICK NUCLEAR POWER PLANT Docket No. 50-333 i DPR-59 r

i 4

. . JAFNPP

. 6.3 PLANT STAFF QUALIFICATIONS 6.3.1 The minimum guelifications with regard to educetional background and exponence for piant staff positions shown in FSAR Figure 13.2-7 shell meet or encoed the trununum gueirficecons of ANSI N18.1-1971 for comparable poestions: except for the Radiological and Envronmental Serwces Meneger who shen meet or exceed the qualifications of Reguistory Guide 1.8, September 1975.

6.3.2 The Shrft Techrucal Adwoor (STA) shen meet or exceed the emnimum reguromonts of either Option 1 (Comtuned SRO/STA Poeshon) or Option 2 (Conanued use of STA Positiore, as defined in the Commission Policy Statement on 4 :1-., Experuse on Shift, puhkehod in the October 28,1885 Federal Repeater (50 PR 43821). When erwoksng Oppon 1, the STA role eney be flEed by the Shrft Supervisor or Asestant Shift Supervisor. (1) 6.3.3 Any deviscon's win be justrfied to the NRC prior to en individual's fiEng of one of these positions.

NOTE:

' (1) The 13 indrwduals who hold SRO licenses, and have completed the FitrPetnck Advanced Technical Trenung Program prior to the imeuence of License Amendment 111, shall be consadored qualified as dual role SRO/ STAS.

6.4 RETRAINING AND REPLACEhENT TRAINING A trawun0 program eheN be maintemed under the direction of the Tranune 'ir -; ,

to aoeurs overeN proficsoney of the plant stoff orgeruzeDon. It shen consist of both retrainm0 and repiscoment trenung and shen most or exceed the punimum rogueroments of Soccon 5.5 of ANSI N18.1-1971.

The retraining program shall not exceed periods two voors in length with a i

cumculum designed to meet or exceed the requehficecon regurements of 10 CFR 55.59. In addroon, fire bngede treuung shen rnest or exceed the rogurements of NFPA 27-1975, except for Fire Srisode treinm0 sessions which shen be held et least guertorty. The effacave dets for imptomentation of fire bngede training is March 17,1978.

6.5 REVIEW AND AUDIT

[Two seperste groups for plant operations have been coneptuted. One of these, the Plant Operating Review Committee (PORC), is an onente review group. The other is an independent review and audit group, the offsite Safety Review Commrttee (SRC). j 7

b.p c e, w% Tex + A p+ ~TcAk Amendment No. , f, f, ,1 f t,1f4,1 7, If8,1/0 1

E - _

JAPNPP

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s .5.1 6 PLANT OPERATING REVIEW COMMITTEE (PORC) g Membership

(, . S. \. '2- -

The Plant Operating Renew Committee shall be CORM of the:

(o. S. L \

Lsed f ( f f

&ce Chairman /Memner[ General Manager- Opershons wig" VeeCharman/ Member: General t'c+F - Support Services Vce Chairman / Member: General Manager- Maintenance Member: Operations Manager cWman Member:

Member.

Maintenance Manager Techncal Serwces Manager Member: Instrument and Controis Memger Member.  %' and Ermronmental Services Manager Member: Site Engirmenng Manager Member: Reactor Analyst Superwsor Special consultants to prcmde expert advice may be utilized when the nature of a partcular problem dctates.

Amendment No. 3/l, f,1/8 248a

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JAFNPP j 1

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l g g,3 (B). Afternat l Alterna#ve temporary basi I membegLahallbe_appoiged bowever, in writing no more than two attomates shall participate _by almt in PORC the PORC C (aTaryoniitimi.

(o . *E I & (C) Meeting Frequency Meetings will be called by the Chairman as the occasions for renew or irwestigation arise. '

Meetings will be no less frequent than once a month.

to . S 1. S 0) bl '

A quorum of the PORC shall consist of the Chairman or one of three Vice-Chairmen and, five members including designated attomates. Vice-Charmen may act as members when not acting as Chairman. A <tev % -skJLeCd % v e 4% i 6 a-Yv es ' ~

(, . S. I . (, (E) Responsibilities - *

( [ (Review plant p,wcedures, and changes thereto, requred by S;+:" 9ti:-rg:ry hD

b. (2[ Review p,wpeeed tests and expenments that affect nuclear safety.

wa e .(Ji Review proposed changes to the Operating Ucense and Technical S;+:*-:+::ons.

TPd "c# cf.[ Remw proposed changes or modifications to plant systems or equipment that affect nuclear safety. .

l e.,[ Firt::tWe violations of the Technical M=d~is and prepare and forward a j report covenng evaluation and recommendations to prevent recurrence to the  !

Resident Manager, who will forward the report to the Manager Nuclear Operations Land to the Chairman of the Salsty Review Committee. Lud '

rege** '

4. Review plant operations to detect poten_tial salsty}=wda. ,  !
7. Review the Security Plan (wiciuding the Saloguards Contingency Plan) and implementing procedures annuah.j .

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Amendment No. h,f,f,J7d

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(8. Ravicw tha Em2rgsney Plan cnd irplemnting pecesdurss ennual J2_,

Q h Perform special review and/or investigations at the request of the U Resident Manager.

(- Review of all Reportable Events, h y

f eview the Offsite Dose Calculation Manual (ODCM) and implementing (9U ') . procedures at least once per 24 months. l M

'r,- l" g (eview the Process Control Program at (PCP) least once per 24 months JF)' Authority #

g

(, ~6. \ ' l I The PORC shall function to advise the Resident Manager on all k matters related to nuclear safety and environmental operations. The Vet $

PORC shall reconunend approval or disapproval to the Resident Manager  ;

of those items considered in 6.5 IE (1) through (4) and determine if D '

4 items considered in 6.5 IE (1) through (5) constitute unreviewed

) safety questions, as defined in 10 CFR 50.59.

QOcf~ tdS In the event of a disagreement between the PORC and the Resident e 4

Manager, the Chairman of the SRC and the Executive Vice President-Nuclear Generation, or their designated alternates, shall id "b 4 be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and written notification provided on the next business day; however, the Resident Manager shall have responsibility for resolution of such disagreement pursuant to ^

on 6.1 -

7 6 .0 .NMinutes " " ' of all meetings of the PORC shall be recorded and numbered.

Copies will be retained in file. Copies will be forwarded to the Chairman of the SRC and the Executive Vice President-Nuclear Generation.

( Procedures Conduct of the PORC and the mechanism for implementation of its responsibilities and authority are defined in the pertinent Administrative Procedures.

6.5.2 SAFETY REVIEW COMMITTEE (SRC)

FUNCTION

. 6.5.2.1 The SRC shall function to provide independent review and audit of designated activities in the. areas of:

a. Nuclear power plant operations j
b. Nuclear engineering
c. Chemistry and radiochemistry  ;
d. Metallurgy
e. Instrumentation and control Amendment No. x, Je, M, swr y0 250 I

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c.

Thb rocults of cetions takcn to corroet

  • d3ficiencies oscurring is fccility equipment, otrteturos, oyatcas or mothed of operatien that affect nuclear safety at least once per 6 months.
d. The performance of activities required by the operational Quality Assurance Program to meet the criteria of Appendiz '3*,10 CFR 50, at least once per 24 months.

[e. The Pacility Emergency Plan and implementingD f procedures at lease once per 12 montes.

f. ' The Facility Security Plan (including the safeguards Con;tagency Plan) and implementing

, procedures at least once per 12 months, g* g. Any other area of facility Operation considered appropriate by the SRC or the Executive vice President-Nuclear Generation.-

  1. ' # F. The Pacility Fire Protection Program and  !

implementing procedures at least once per two years.

.. O O'

i. An independent fire protection and loss of prevention inspection and audit shall be ,

performed annually utilizing either qualified '

offsite licensee personnel or an outside hre i i protection firm. '

(, An inspection and audit of the fire protection  !

and loss prever. tion program shall be performed  ;

by an outside qualified fire consultant at intervals no greater than 3 years. .

L

1. The Radiological Environmental. Monitoring Program and the results thereof at least once per 12 months.

The offsite Dose calculation Manual and .

- implementing procedures at least once per 24 months.

k. The Process control Program and implementing procedures for processing and packaging of '

radioactive wastes at least once per 24 months.

l. n. The performance of activities required by the Quality Assurance Program to' meet the provisions of Regulatory Guide.l.21, Revision 1, June 1974 -

and Regulatory Guide 4.1, Revision 1,. April 1975 at least once per 12 months. ~ .*

i AUTRotITY -

)

4.5.2.9 The sac shall report to and adelse the Ezeestive Tice i president-esclear Generation os those areas of responsibility *specified la section 6.5.2.7 and 6.5.2.8 ,

Amendment No. )(, pf, KI, % ,JHI, 252a -

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CHARTER 6.5.2.11 Conduct of the comittoa will be in cectrdance with a charter approved by the Executive Vice President-Nuclear Generation setting forth the mechanism for implementation of the conunittee's responsibilities and authority.

6.6 REPORTABLE EVENT ACTION The following actions shall be taken for Reportable Events:

(A) The Conunission shall be notified and a report submitted pursuant to {

the requirements of Section 50.73 to 10 CFR Part 50, and (B) Each Reportable Event shall be reviewed by the PORC, and the results of this review shall be submitted to the SRC and the Executive Vice President - Nuclear Generation.

6.7 SAFETY LIMIT VIOLATION (A) If a safety limit is exceeded, the reactor shall be shut down and -

reactor operation shall only be resumed in accordance with the <

provisions of 10 CFR 50.36, (c) (1).

(B) An immediate report of each safety limit violation shall be made to the NRC by the Resident Manager. The Executive Vice President-Nuclear Generation and Chairman of the SRC will be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(C) The PCRC shall prepare a complete investigative report of each safety limit violation and include appropriate analysis and evaluation of: (1) applicable circumstances preceding the occurrence, (2) effects of the occurrence upon facility component systems or structures and (3) corrective action required to prevent recurrence. The Resident Manager shall forward this report to the Executive Vice President-Nuclear Generation, Chairman of the SRC and the NBC.

l 6.8 PROCEDURES (A) Written procedures and administrative policies shall be ,

established, implemented ano maintained that meet or exceed the l

\C4 requirements and recosunendations of Section 5 " Facility '

Administrative Policies and Procedures" of ANSI 18.7-1972 and

[k g Appendiz A of Regulatory Guide 1.33, November 1972. In addition, procedures shall be established, implemented and maintained for the Fire Protection Program and other programs, as specified in i

f 9 Appendix B of the Radiological Effluent Technical Specifications, s y Section 7.2.

W (B) Those procedures affecting nuclear safety-shall be reviewed by PORC 4cd and approved by the Resident Manager prior to implementation.

j& o oi 4%. tmu (C) Temporary changes to cuele:r n m u provided:

FG;y::A s ve

-r  % && L* W may be made

1. e intent of the original procedure is not altered.

Amendment No. M, MY, M, M, M}4D 253

1 s * . l

2. tha ch nge is cpprsved by two memb3rs cf tha plcst mannstment stoff, i

- et locst ens of whom hsids a S3nier R3 ctcr Opercter's licGnsa ea ;.i.,: l

-...x...e.e sa.

3. The change is documented, reviewed by th: =^r ::d epproved by th-: l

^#

-::::id::t W c'6 ".;;;;EM

.ith1: 1e dsye 8 .-1:;;.; t;ti:: _ _ . I a2  %

6.9 REPORTING REQUIREM!NTS 69,6 & M dfL s  % 4%%

l (A) ROUTINE REPORTS l

t In addition to the applicable reporting requirements of Title 10, '

I Code of Federal Regulations, the following reports shall be submitted to the Director of the Regional Office of Inspection and Enforcement unless otherwise noted.

1. STARTUP REPORT >

, - o

a. A summary repot t of plant startup and power escalation testing shall be submitted following (1) amendment to the license involving a planned increase in power level, (2) .

installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (3) modifications that may have significantly altered the nuclear, thermal, or hydraulic. performance of the plant. .

The report shall address each of the tests identified in the FSAR and shall include a description of the measured values >

of the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described. Any additional specific details required in license conditions based on other consnitments shall be included in this report.

P Amendment No. # M M e M 254-a

Text "A"

" Review requirements are accomplished by using designated technical reviewers / qualified safety reviewer and two separate review committees. The Plant Operating Review Committee ,

(PORC) is an onsite review group; the Safety Review Committee (SRC) is an independent  ;

offsite review and audit group".

Text "AA" l

"6.5.0 REVIEW AND APPROVAL OF PROGRAMS AND PROCEDURES 6.5.0.1 The procedure review and approval process shall be controlled and implemented by administrative procedure (s).

6.5.0.2 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall be reviewed by a minimum of two designated technical reviewers who are knowledgeable in the affected functional area.

6.5.0.3 Designated technical reviewer (s) shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions.

6.5.0.4 The designated technical reviewer shall determine the need for cross disciplinary reviews. Individuals performing cross-disciplinary reviews shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions.

6.5.0.5 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall be reviewed from a safety perspective by a qualified safety reviewer. Safety and/or environmental impact evaluations, when required, shall be reviewed by PORC per Specification 6.5.1.6.a.

6.5.0.6 Nuclear safety related procedures and procedure changes shall be reviewed and approved, prior to implementation, by the appropriate member (s) of management."

Text "B"

" Function PORC shall function to advise the Resident Manager on matters related to nuclear safety and environmental impact".

Text "C"  ;

"The PORC shall be responsible for the:" l l

l i

l

e 0 .

4 Text "D"

" Review of 10 CFR 50.59 safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8 and changes thereto".

Text "E"

" investigation of violations to the Technical Specifications. The PORC shall prepare and present a report covering the evaluations and recommendations to prevent recurrence to the Resident Manager, who will then forward the report to the Executive Vice President - Nuclear Generation and to the Chairman of the Safety Review Committee".

Text "F"

" Review of the Process Control Program and the Offsite Dose Calculation Manual (ODCM) and changes thereto".

Text "G" "The PORC shall:

a. Recommend to the Resident Manager, approval or disapproval of those items reviewed under Specifications 6.5.1.6.a through 6.5.1.6.d.
b. Render determinations with regard to whether or not items considered under Specification 6.5.1.6.a through 6.5.1.6.e constitute an Unreviewed Safety Question as defined in 10 CFR 50.59.
c. In the event of a disagreement between the PORC and Resident Manager, notify the Executive Vice President-Nuclear Generation and the SRC Chairman, or their designated alternates, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provide written notification by the next business day. The Resident Manager shall have responsibility for resolution of such disagreement pursuant to Section 6.1."

Text "I"

" Written procedures and administrative policies shall be established, implemented, and maintained that:

1. meet or exceed the requirements and recommendations of Section 5 of ANSI 18.7-1972 " Facility Administrative Policies and Procedures."
2. are recommended in Appendix A of Regulatory Guide 1.33, November 1972.
3. implement the Fire Protection Program.
4. include programs specified in Appendix B of the Radiological Effluent Technical Specifications, Section 7.2."

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Text "J" "Each procedure of Specification 6.8.(A), and changes thereto, shall be approved prior to implementation by the appropriate responsible member of management as specified in Specification 6.5.0."

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