ML022770234

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Savety Evaluation Regarding License Amendment Request Proposed Amendment to the South Texas Project Technical Specifications to Revise Administrative Control Requirements
ML022770234
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 10/30/2002
From: Trimble D
NRC/NRR/DIPM
To: Gramm R
NRC/NRR/DLPM/LPD4
Bongarra J, IEHB/DIPM/NRR 415-1046
References
TAC MB3589, TAC MB3593
Download: ML022770234 (9)
v • d • e


Text

October 30, 2002 MEMORANDUM TO: Robert A. Gramm, Chief Project Directorate IV-1 Division of Licensing and Project Management, NRR

/RA/

FROM: David C. Trimble, Chief Operator Licensing and Human Performance Section Equipment and Human Performance Branch (IEHB)

Division of Inspection Program Management, NRR

SUBJECT:

SAFETY EVALUATION REGARDING LICENSE AMENDMENT REQUEST -PROPOSED AMENDMENT TO THE SOUTH TEXAS PROJECT TECHNICAL SPECIFICATIONS TO REVISE ADMINISTRATIVE CONTROL REQUIREMENTS Plant Name: South Texas Project, Units 1 and 2 Utility: STP Nuclear Operating Company Docket Nos. STN 50-498, STN 50-499 TAC Nos.: MB3589, MB3593 Operating Licenses: NPF-76, NPF-80 Project Manager: John Minns Review Branch: IEHB Review Status: Complete In a work request dated December 21, 2001, IOHS was asked to review the STP Nuclear Operating Company (STPNOC) amendment request to the South Texas Project Operating Licenses NPF-76 and NPF-80 for revising various requirements denoted in or associated with Section 6.0 of the Technical Specification (TS), Administrative Controls. The proposed change, submitted in accordance with 10 CFR 50.90, updates the TS to be consistent with current industry standards and guidance.

The IOHS staff concludes that the STPNOC request is consistent with and meets the relevant review criteria and is acceptable. The staff's safety evaluation (SE) is attached.

The principal reviewer for this assessment was James P. Bongarra, Jr. If you have any questions he can be reached at 301-415-1046. IOHS considers its efforts on TAC Nos.

MB3589 and MB 3593 to be complete.

Attachment:

As stated

October 30, 2002 MEMORANDUM TO: Robert A. Gramm, Chief Project Directorate IV-1 Division of Licensing and Project Management, NRR

/RA/

FROM: David C. Trimble, Chief Operator Licensing and Human Performance Section Equipment and Human Performance Branch (IEHB)

Division of Inspection Program Management, NRR

SUBJECT:

SAFETY EVALUATION REGARDING LICENSE AMENDMENT REQUEST -PROPOSED AMENDMENT TO THE SOUTH TEXAS PROJECT TECHNICAL SPECIFICATIONS TO REVISE ADMINISTRATIVE CONTROL REQUIREMENTS Plant Name: South Texas Project, Units 1 and 2 Utility: STP Nuclear Operating Company Docket Nos. STN 50-498, STN 50-499 TAC Nos.: MB3589, MB3593 Operating Licenses: NPF-76, NPF-80 Project Manager: John Minns Review Branch: IEHB Review Status: Complete In a work request dated December 21, 2001, IOHS was asked to review the STP Nuclear Operating Company (STPNOC) amendment request to the South Texas Project Operating Licenses NPF-76 and NPF-80 for revising various requirements denoted in or associated with Section 6.0 of the Technical Specification (TS), Administrative Controls. The proposed change, submitted in accordance with 10 CFR 50.90, updates the TS to be consistent with current industry standards and guidance.

The IOHS staff concludes that the STPNOC request is consistent with and meets the relevant review criteria and is acceptable. The staff's safety evaluation is attached.

The principal reviewer for this assessment was James P. Bongarra, Jr. If you have any questions he can be reached at 301- 415-1046. IOHS considers its efforts on TAC Nos.

MB3589 and MB3593 to be complete.

Attachment:

As stated Distribution:

Licensing Action/Admin Changes folder Generic Operator Licensing/License Eligibility J. Minns, K. Heck, R. Pederson, R. Moody, R. Pelton Accession No.: ML022770234 OFFICE IEHB/IOHS/DIPM IEHB/IOHS/DIPM NAME J. Bongarra D. Trimble DATE 10/21/02 10/30/02 OFFICIAL RECORD COPY

SAFETY EVALUATION REGARDING REVISING ADMINISTRATIVE CONTROL REQUIREMENTS DOCKET NOS. STN-50-498, STN-50-499

1.0 INTRODUCTION

By letter dated November 5, 2001, STP Nuclear Operating Company (STPNOC) submitted a proposed amendment to South Texas Project Technical Specifications to revise administrative control requirements of Section 6.0 of the TS, Administrative Controls. The proposed changes, submitted in accordance with 10 CFR 50.90, updates the TS to be consistent with current industry standards and guidance.

2.0 EVALUATION CRITERIA The NRC sets forth the requirements for the contents of Technical Specifications (TS) in 10 CFR 50.36, Technical specifications. Specifically, licensees must include those administrative controls necessary to assure operation of a facility in a safe manner in the TSs, as required by 10 CFR 50.36(c)(5), Administrative controls. In addition, the staff used used NUREG-1431, Standard Technical Specifications, Westinghouse Plants, and approved Generic Travelers, in its review.

3.0 TECHNICAL EVALUATION

The NRC IOHS staff reviewed the licensees safety analysis in support of its proposed license amendment which is described in Attachment 1 (Description of Changes and Safety Evaluation) of the licensees submittal. The detailed evaluation below supports the conclusion that the proposed changes to the TS are acceptable.

The proposed amendment revised specific Administrative Control requirements in Section 6.0 of the TS and associated Administrative Control requirements located in other sections of the TS. The proposed amendment included relocating specific TS Administrative Control requirements to licensee-controlled documents; updating specific management titles to more generic title positions; updating requirements to be consistent with current industry standards; and reformatting, renumbering and rewording existing requirements for improved readability.

STPNOC identified specific management title changes that effect the current TS and required the proposed license amendment request. The specific title changes were eliminated from the TS and replaced with generic titles consistent with current industry guidance. STPNOC also evaluated and incorporated other current industry guidance affecting Section 6.0 of the TS.

The proposed amendment, in part, revises the requirements of Section 6.0 of the TS to be consistent with the Improved Standard Technical Specifications (NUREG-1431, Standard Technical Specifications, Westinghouse Plants) and associated, approved, Generic Travelers, and with 10 CFR 50.36(c)(4).

STPNOC, in Table 1 of Attachment 1, provided the proposed changes with the technical analysis for each change. Four change categories were used:

Attachment

(1) Administrative (A), to identify non-technical changes to incorporate human factors principles into the form and structure of the TS for increased ease in use of the TS. These changes were editorial or involved reorganizing or reformatting current TS requirements without affecting the technical content or operational restrictions. To ensure consistency, the licensee used NUREG-1431 and associated, approved, Generic Travelers to the NUREG as guidance to reformat and make the administrative changes (2) More Restrictive (M), to identify technical changes to existing requirements that the licensee elected to make for consistency with current guidance and that are more restrictive than those in the current TS. These changes are additional restrictions on plant operation that enhance safety and have been found acceptable by the NRC.

(3) Less Restrictive (L), to identify deletions or relaxations to portions of the current TS requirements. These are consistent with generic relaxations that the NRC has approved and that are contained in the Improved Standard Technical Specifications.

(4) Relocated (R), to identify technical changes to requirements that have been shown to provide little or no safety benefit, and their relocation from the TS to other licensee-controlled documents may be more appropriate. In most cases, relocated information previously approved for individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new staff positions that evolved from technological advancements or operating experience, or (3) resolution of Owners Groups comment on Improved Technical Specifications.

The NRC has reviewed the generic relocations contained in the Improved Standard Technical Specifications and found them acceptable because they are consistent with current licensing practices and the Commissions regulations.

For changes included in the above four categories, the NRC IOHS staff verified the acceptability of these changes and determined that they are in accordance with specified requirements of 10 CFR 50.36(c)(5), Administrative controls and consistent with the NUREG-1431, Standard Technical Specifications, Westinghouse Plants.

Proposed changes and their accompanying technical analyses that were reviewed by IOHS are the following:

Section 6.1, Responsibility

  1. 4 (6.1.1) (R) - The licensee changed Plant Manager to plant manager,replacing the specific position title with a generic title. The description of this specific title is in the licensees OQAP and UFSAR. This change is consistent with NUREG-1431and is acceptable.
  1. 5 & #42 (6.1.1) (A), (R) - The licensee relocated one sentence from each of TS 6.5.3.3.b and 6.5.3.1.c and combined them to read, The plant manager or the plant managers designee shall approve, prior to implementation, each proposed test and experiment not described in the UFSAR, and each modification to systems or equipment that affect nuclear safety. This change is consistent with NUREG-1431 and is acceptable.
  1. 6 & #7(6.1.2) (A), (A) - The licensee changed Shift Supervisor to shift manager, replacing the specific position title with a generic title. The licensee indicates that personnel who fulfill this position are required to meet specific qualifications as detailed in ANSI N18.1-1971 as described in their Operations Quality Assurance Plan. This change is consistent with NUREG-1431 and is acceptable.
  1. 35 (6.1.2) (A) - The licensee relocated a paragraph identifying that during the absence of the shift manager from the control room while the unit is in MODE 1,2,3, or 4, an individual with an active SRO license shall be designated to assume the control room command function. This change is consistent with NUREG-1431 and is acceptable.
  1. 8 (6.1.2) (A) - The licensee deleted the sentence, A management directive to this effect, signed by the President and Chief Executive Officer shall be issued to all station personnel on an annual basis. This change is consistent with NUREG-1431 and is acceptable.

Section 6.2, Organization

  1. 9 (6.2.1) (A) - The licensee reformatted the previous subsection item, Offsite and Onsite Organizations, to have the title as a numbered item. This change is consistent with NUREG-1431 and is acceptable
  1. 10 (6.2.1.a) (A) - The licensee made grammatical improvements. This change is consistent with NUREG-1431 and is acceptable.
  1. 11 (6.2.1.a) (A) - The licensee made a grammatical improvements. This change is consistent with NUREG-1431 and is acceptable.
  1. 12 (6.2.1.a) (R) - The licensee provided additional information and clarification to the existing TS item, organization. This change is consistent with NUREG-1431 and is acceptable.
  1. 13 (6.2.1.b) (R) - The licensee changed Plant Manager to plant manager,replacing the specific position title with a generic title. This change is consistent with NUREG-1431 and is acceptable.
  1. 14 (6.2.1.b) (A) - The licensee made a grammatical improvements. This change is consistent with NUREG-1431 and is acceptable.
  1. 15 (6.2.1.c) (R) - The licensee provided additional information and clarification. This change is consistent with NUREG-1431 and is acceptable.
  1. 18 (6.2.2) (A) - The licensee changed the format to have a numbered item instead of a subsection title. This change is consistent with NUREG-1431 and is acceptable.
  1. 19 (6.2.2) (A) - The licensee provided additional information and clarification. This change is consistent with NUREG-1431 and is acceptable.
  1. 19a (6.2.2.a) (A) - The licensee deleted the sentence, Each on-duty shift shall be composed of at least the minimum shift crew composition shown in Table 6.2.1, and deleted Table 6.2.1.

This is an administrative change and is consistent with NUREG-1431 and is acceptable.

  1. 19b & 32 (6.2.2.b) (A) - The licensee relocated information from Table 6.2.1, deleted in the previous item. This is an administrative change and is consistent with NUREG-1431 and is acceptable.
  1. 20 (6.2.2.b) (A) - The licensee deleted an unnecessary sentence regarding operator and senior operator staffing requirements. This is an administrative change and is consistent with NUREG-1431 and is acceptable.
  1. 33 & #34 (6.2.2.d) (A), (A) - The licensee, deleted Table 6.2-1, and relocated information to TS 6.2.2.d related to shift crew composition. This change is consistent with NUREG-1431 and is acceptable.
  1. 24 (6.2.2.d) (A) - The licensee deleted TS 6.2.2.d, which stated that, All Core Alterations shall be observed and directly supervised by either a licensed Senior Operator or a licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation. This information redundant with10 CFR 50.54 (m)(2)(iv). This change is consistent with NUREG-1431 and is acceptable.
  1. 26&27 (6.2.2.f) (A), (A) - The licensee made editorial changes to incorporate plant-specific nomenclature. This change is consistent with NUREG-1431 and is acceptable.
  1. 28 (6.2.2.f) (A) - The licensee made an editorial change for clarity. This change is consistent with NUREG-1431 and is acceptable.
  1. 28a (6.2.2.f) (A) - The licensee replaced a paragraph with, The controls shall include guidelines on working hours that ensure adequate shift coverage shall be maintained without routine heavy use of overtime. This change is consistent with NUREG-1431 and is acceptable.
  1. 29 (6.2.2.f) (R) - The licensee changed Plant Manager to plant manager,replacing the specific position title with a generic title. This change is consistent with NUREG-1431 and is acceptable.
  1. 30 (6.2.2.f) (A) - The licensee made an editorial change for clarity. This change is consistent with NUREG-1431 and is acceptable.
  1. 30a (6.2.2.f) (L/A) - The licensee has eliminated the details specifying responsibility for reviewing the performance of overtime and for the frequency of reviewing overtime performance are controlled by plant procedures. Details of periodicity of overtime reviews and the personnel required to perform such reviews are outside the scope of information required to be the TS. This change is consistent with NUREG-1431 and is acceptable.
  1. 31 (6.2.2.g) (R) - The licensee replaced the list of required SRO or RO license holders with the statement, The individual to whom the shift managers directly report shall hold an SRO license. The licensee states that the intent of this replacement is for the first level of management above the shift managers to hold an SRO license. This change is consistent with NUREG-1431 and is acceptable.
  1. 35 (Table 6.2-1) (A) - The licensee changed Shift Supervisor to shift manager, replacing the specific position title with a generic title. The licensee indicates that personnel who fulfill this position are required to meet specific qualifications as detailed in ANSI N18.1-1971 as described in their Operations Quality Assurance Plan. This change is consistent with NUREG-1431 and is acceptable.
  1. 36 (Table 6.2-1) (A) - The licensee changed Shift Supervisor to shift manager, replacing the specific position title with a generic title. The licensee indicates that personnel who fulfill this position are required to meet specific qualifications as detailed in ANSI N18.1-1971 as described in their Operations Quality Assurance Plan. This change is consistent with NUREG-1431 and is acceptable.
  1. 37 (6.2.4.1) (A) - The licensee made editorial changes to incorporate plant-specific nomenclature. This change is consistent with NUREG-1431 and is acceptable.
  1. 38 (6.2.4.1) (A) - The licensee replaced the qualifications requirement for the STA making it consistent with NUREG-1431 referencing the Commission Policy Statement on Engineering Expertise on Shift. This change is consistent with NUREG-1431 and is acceptable.
  1. 39 (6.3.1) (M) - The licensee added the statement, Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971, as described in the Operations Quality Assurance Plan. This change is consistent with NUREG-1431 and is acceptable.
  1. 40 (6.4) (R) - The licensee relocated the requirements of TS 6.4, Training, to the license controlled TRM. The relocated details are not required to be in the TS. This change is consistent with NUREG-1431 and is acceptable.

4.0 CONCLUSION

The NRC IOHS staff has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be adverse to the common defense and security or to the health and safety of the public.

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