ML031350631
| ML031350631 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/15/2003 |
| From: | Colburn T NRC/NRR/DLPM/LPD1 |
| To: | Pearce L FirstEnergy Nuclear Operating Co |
| Colburn T, NRR/DLPM, 415-1402 | |
| Shared Package | |
| ML031360163 | List: |
| References | |
| TAC MB3844, TAC MB3845 | |
| Download: ML031350631 (35) | |
Text
May 15, 2003 Mr. L. W. Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT RE: REVISIONS TO THE ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATIONS (TAC NOS. MB3844 AND MB3845)
Dear Mr. Pearce:
The Commission has issued the enclosed Amendment No. 255 to Facility Operating License No. DPR-66 and Amendment No. 136 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 16, 2002, as supplemented by letter dated October 17, 2002.
These amendments modify various specifications in TS Section 6.0, Administrative Controls, to clarify existing requirements and make wording improvements. The proposed BVPS-1 and 2 Section 6.0 TSs provide clearer, more readily understandable requirements to ensure safe operation of the plant. The Nuclear Regulatory Commission staff has concluded that the proposed TSs discussed herein satisfy the guidance in the Commissions policy statement with regard to the content of the TSs, and conform to the model provided in NUREG-1431, Standard Technical Specifications for Westinghouse Plants, Revision 2, with appropriate modifications for plant-specific considerations.
A copy of our safety evaluation is enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosures:
- 1. Amendment No. 255 to DPR-66
- 2. Amendment No. 136 to NPF-73
- 3. Safety Evaluation cc w/encls: See next page
May 15, 2003 Mr. L. W. Pearce Vice President FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077
SUBJECT:
BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENT RE: REVISIONS TO THE ADMINISTRATIVE CONTROLS TECHNICAL SPECIFICATIONS (TAC NOS. MB3844 AND MB3845)
Dear Mr. Pearce:
The Commission has issued the enclosed Amendment No. 255 to Facility Operating License No. DPR-66 and Amendment No. 136 to Facility Operating License No. NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS-1 and 2). These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated January 16, 2002, as supplemented by letter dated October 17, 2002.
These amendments modify various specifications in TS Section 6.0, Administrative Controls, to clarify existing requirements and make wording improvements. The proposed BVPS-1 and 2 Section 6.0 TSs provide clearer, more readily understandable requirements to ensure safe operation of the plant. The Nuclear Regulatory Commission staff has concluded that the proposed TSs discussed herein satisfy the guidance in the Commissions policy statement with regard to the content of the TSs, and conform to the model provided in NUREG-1431, Standard Technical Specifications for Westinghouse Plants, Revision 2, with appropriate modifications for plant-specific considerations.
A copy of our safety evaluation is enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-334 and 50-412
Enclosures:
- 1. Amendment No. 255 to DPR-66
- 2. Amendment No. 136 to NPF-73
- 3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:
PUBLIC MO'Brien ACRS PDI-1 R/F TColburn BPlatchek, RGN-I OGC RGiardina RLaufer GHill (4)
RDennig DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML031350631.wpd
- See previous concurrence ACCESSION NO. ML031350631
- SE provided. No major changes made.
OFFICE PDI-1/PM PDI-1/LA RORP/SC PDI-1/SC OGC**
NAME TColburn MOBrien RDennig*
RLaufer SUttal DATE 05/13/03 05/13/03 01/02/03 05/14/03 05/01/03 OFFICIAL RECORD COPY
Beaver Valley Power Station, Units 1 and 2 Mary OReilly, Attorney FirstEnergy Nuclear Operating Company FirstEnergy Corporation 76 South Main Street Akron, OH 44308 FirstEnergy Nuclear Operating Company Regulatory Affairs/Performance Improvement Larry R. Freeland, Manager Beaver Valley Power Station Post Office Box 4, BV-A Shippingport, PA 15077 Commissioner James R. Lewis West Virginia Division of Labor 749-B, Building No. 6 Capitol Complex Charleston, WV 25305 Director, Utilities Department Public Utilities Commission 180 East Broad Street Columbus, OH 43266-0573 Director, Pennsylvania Emergency Management Agency 2605 Interstate Dr.
Harrisburg, PA 17110-9364 Ohio EPA-DERR ATTN: Zack A. Clayton Post Office Box 1049 Columbus, OH 43266-0149 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 J. H. Lash, Plant Manager (BV-IPAB)
FirstEnergy Nuclear Operating Company Beaver Valley Power Station Post Office Box 4 Shippingport, PA 15077 Rich Janati, Chief Division of Nuclear Safety Bureau of Radiation Protection Deparment of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Mayor of the Borough of Shippingport P O Box 3 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission Post Office Box 298 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station ATTN: M. P. Pearson, Director Services and Projects (BV-IPAB)
Post Office Box 4 Shippingport, PA 15077 FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mr. B. F. Sepelak Post Office Box 4, BV-A Shippingport, PA 15077
PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-334 BEAVER VALLEY POWER STATION, UNIT NO. 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 255 License No. DPR-66 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated January 16, 2002, as supplemented by letter dated October 17, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. DPR-66 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 255, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 15, 2003
ATTACHMENT TO LICENSE AMENDMENT NO. 255 FACILITY OPERATING LICENSE NO. DPR-66 DOCKET NO. 50-334 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert II II IX IX X
XI XII XIII XIV XIV XVII XVII XVIII XIX XIX 6-2 6-2 6-3 6-3 6-4 6-5 6-5 6-6 6-6
PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY DOCKET NO. 50-412 BEAVER VALLEY POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 136 License No. NPF-73 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by FirstEnergy Nuclear Operating Company, et al. (the licensee), dated January 16, 2002, as supplemented by letter dated October 17, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
2.
Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Facility Operating License No. NPF-73 is hereby amended to read as follows:
(2)
Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 136, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto are hereby incorporated in the license. FENOC shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA/
Richard J. Laufer, Chief, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: May 15, 2003
ATTACHMENT TO LICENSE AMENDMENT NO. 136 FACILITY OPERATING LICENSE NO. NPF-73 DOCKET NO. 50-412 Replace the following pages of Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert III III IX IX X
XI XII XIII XIII XIV XIV 6-2 6-2 6-3 6-3 6-5 6-6 6-6 6-7 6-7
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 255 AND 136 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 PENNSYLVANIA POWER COMPANY OHIO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY FIRSTENERGY NUCLEAR OPERATING COMPANY BEAVER VALLEY POWER STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-334 AND 50-412
1.0 INTRODUCTION
By application dated January 16, 2002, as supplemented by letter dated October 17, 2002, the FirstEnergy Nuclear Operating Company (FENOC, the licensee), requested changes to the Technical Specifications (TSs) for Beaver Valley Power Station, Units 1 and 2 (BVPS-1 and 2).
The supplement dated October 17, 2002, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the Nuclear Regulatory Commission (NRC) staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 29, 2002 (67 FR 66010).
The proposed changes would revise portions of the current BVPS-1 and 2 TSs, Section 6.0, Administrative Controls, (CTS) to conform with improved Technical Specifications (PTS). The conversion is based upon: NUREG-1431, Standard Technical Specifications for Westinghouse Plants, Revision 2, dated April 2001; Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (Final Policy Statement), published on July 22, 1993 (58 FR 39132); and Title 10 of the Code of Federal Regulations (10 CFR),
Section 50.36, Technical Specifications, as amended July 19, 1995.
Hereafter, the proposed or improved TSs for BVPS-1 and 2 are referred to as the PTS, the existing TSs are referred to as the CTS, and the improved standard TSs, such as in NUREG-1431, Revision 2, are referred to as the STS.
In addition to basing PTS 6.0 on STS 5.0, the Final Policy Statement, and the requirements in 10 CFR 50.36, the licensee retained portions of the CTS as a basis for the PTS. Plant-specific issues related to CTS which are being retained include requirements and operating practices.
These plant-specific deviations from the STS are reflected in the PTS. Consistent with the Final Policy Statement, the licensee proposed transferring some CTS requirements to licensee-controlled documents such as the Updated Final Safety Analysis Report (UFSAR) for BVPS-1 and 2, for which changes to these documents by the licensee are controlled by 10 CFR 50.59 and may be changed without prior NRC approval. NRC-controlled documents, such as the TSs, may not be changed by the licensee without prior NRC approval. In addition, human factors principles were emphasized to add clarity to the CTS requirements being retained in the PTS, and to define more clearly the appropriate scope of the PTS.
The overall objective of the proposed amendment, consistent with the Final Policy Statement, is to rewrite, reformat, and streamline portions of the Section 6.0 TSs for BVPS-1 and 2 to be in accordance with 10 CFR 50.36.
The NRC staffs evaluation of the application is presented in this safety evaluation (SE).
During its review, the NRC staff relied on the Final Policy Statement, 10 CFR 50.36 and the STSs, as guidance for acceptance of CTS changes. This SE provides a summary basis for the NRC staffs conclusion that the licensee has developed PTS 6.0 based on STS 5.0, as modified by plant-specific changes, and that the use of PTS 6.0 is acceptable for continued operation.
The SE also explains the NRC staffs conclusion that PTS 6.0, which is based on STS 5.0 as modified by plant-specific changes, are consistent with the BVPS-1 and 2 current licensing basis and the requirements of 10 CFR 50.36.
The NRC staff also acknowledges that it is acceptable that PTS 6.0 differs from the STS 5.0, to reflect the current licensing basis for BVPS-1 and 2. The NRC staff approves the licensees changes to the CTS as modified and documented in the licensees October 17, 2002, supplement which responded to the NRC staffs request for additional information (RAI).
For the reasons stated in this SE, the NRC staff finds that the PTS issued with these license amendments comply with Section 182a of the Atomic Energy Act, 10 CFR 50.36, and the guidance in the Final Policy Statement, and that they are in accordance with the common defense and security and provide adequate protection of the health and safety of the public.
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act requires that applicants for nuclear power plant operating licenses will state:
[S]uch technical specifications, including information of the amount, kind, and source of special nuclear material required, the place of the use, the specific characteristics of the facility, and such other information as the Commission may, by rule or regulation, deem necessary in order to enable it to find that the utilization...of special nuclear material will be in accord with the common defense and security and will provide adequate protection to the health and safety of the public. Such technical specifications shall be a part of any license issued.
In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TSs. In doing so, the Commission placed emphasis on those matters related to the prevention of accidents and the mitigation of accident consequences; the Commission noted that applicants were expected to incorporate into their TSs those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity, as set forth in Statement of Consideration, Technical Specifications for Facility Licenses; Safety Analysis Reports, (33 FR 18610, December 17, 1968). Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation:
(1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plants TSs.
NRC and industry representatives have developed guidelines for improving the content and quality of nuclear power plant TSs. On February 6, 1987, the Commission issued an interim policy statement on TS improvements, Interim Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (52 FR 3788). During the period from 1989 to 1992, the utility owners groups and the NRC staff developed improved STS, such as NUREG-1431, that would establish models of the Commissions policy for each primary reactor type. In addition, the NRC staff, licensees, and owners groups developed generic administrative and editorial guidelines in NEI 01-03, Writers Guide for the Improved Standard Technical Specifications (Writers Guide) for preparing TSs, which gives greater consideration to human factors principles and was used throughout the development of licensee-specific PTS.
In April 2001, the Commission issued NUREG-1431, Revision 2, which was developed using the guidance and criteria contained in the Commissions Interim Policy Statement. The STS in NUREG-1431, Revision 2, were established as a model for developing the PTS for Westinghouse plants in general. The STS reflect the results of a detailed review of the application of the interim policy statement criteria to generic system functions, which were published in a Split Report issued to the nuclear steam system supplier owners groups in May 1988. STS also reflect the results of extensive discussions concerning various drafts of STS, so that the application of the TS criteria and the Writers Guide would consistently reflect detailed system configurations and operating characteristics for all reactor designs. As such, the generic Bases presented in NUREG-1431, Revision 2, provides an abundance of information regarding the extent to which the STS present requirements that are necessary to protect public health and safety. STS Section 5.0 in NUREG-1431, Revision 2, applies to BVPS-1 and 2.
On July 22, 1993, the Commission issued its Final Policy Statement, expressing the view that satisfying the guidance in the policy statement also satisfies Section 182a of the Act and 10 CFR 50.36. The Final Policy Statement described the safety benefits of the STS, and encouraged licensees to use the STS as the basis for plant-specific TS amendments, and for complete conversions based on the STS. Further, the Final Policy Statement gave guidance for evaluating the required scope of the TSs and defined four guidance criteria to be used in determining which of the LCOs and associated SRs should remain in the TSs. The Commission noted that, in allowing certain items to be relocated to licensee-controlled documents while requiring that other items be retained in the TSs, it was adopting the qualitative standard enunciated by the Atomic Safety and Licensing Appeal Board in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979). There, the Appeal Board observed:
[T]here is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicants safety analysis report (or equivalent) be subject to a technical specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval. Rather, as best we can discern it, the contemplation of both the Act and the regulations is that technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
By this approach, existing LCO requirements that fall within or satisfy any of the criteria in the Final Policy Statement should be retained in the TSs; those LCO requirements that do fall within or satisfy these criteria may be relocated to licensee-controlled documents. The Commission codified the four criteria set out in the Federal Policy Statement in 10 CFR 50.36 (60 FR 36953), July 19, 1995. The four criteria are as follows:
Criterion 1 Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.
Criterion 2 A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 3 A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Criterion 4 A structure, system, or component which operating experience or probabilistic risk assessment has show to be significant to public health and safety.
Part 3.0 of this SE provides the basis for NRC staffs conclusion that the conversion of portions of Section 6.0 of the BVPS-1 and 2 CTS to PTS 6.0 based on STS 5.0 as modified by plant-specific changes, is consistent with the BVPS-1 and 2 current licensing basis and the requirements and guidance of the Final Policy Statement and 10 CFR 50.36.
3.0 TECHNICAL EVALUATION
The NRC staffs review evaluates changes to the CTS that fall into three categories defined by the licensee and includes an evaluation of whether existing regulatory requirements are adequate for controlling future changes to requirements removed from the CTS and placed in licensee-controlled documents.
In addition to the initial submittal of January 16, 2002, as supplemented, the NRC staff review identified the need for clarification and additions to the submittal in order to establish an appropriate regulatory basis for translation of current TS requirements into the PTS. Each change proposed in the amendment request is identified as a discussion of change (DOC) to the CTS. The NRC staff comments were documented as an RAI and forwarded to the licensee for response by letter dated August 16, 2002. The licensee provided a written response to the NRC staff request by letter dated October 17, 2002. The letter clarified and revised the licensees basis for translating CTS requirement into the PTS. The NRC staff finds that the licensees submittals provide sufficient detail to allow the NRC staff to reach a conclusion regarding the adequacy of the licensees proposed changes.
The license amendment application was organized such that changes were included in each of the following CTS change categories, as appropriate: administrative changes, technical changes - less restrictive (specific), and technical changes - less restrictive (generic):
(1)
Administrative Changes, (A), i.e., non-technical changes in the presentation of existing requirements; (2)
Technical Changes - Less Restrictive (Specific), (L), i.e., changes, deletions, and relaxations of existing TS requirements; and (3)
Technical Changes - Less Restrictive (Generic), (LA), i.e., deletion of existing TS requirements by movement of information and requirements from existing specifications (that are otherwise being retained) to licensee-controlled documents, including TS Bases.
These general categories of changes are discussed in more detail in the following subsections:
3.1 Administrative Changes Administrative (non-technical) changes are intended to incorporate human factors principles into the form and structure of the PTS so that plant operations personnel can use them more easily; making the TSs more easily understood through editorial changes, clarifications of TS requirements, and format changes, without changing the technical content. These changes are editorial in nature or involve the reorganization or reformatting of CTS requirements without affecting technical content or operational restrictions. The changed sections of PTS 6.0 reflect this type of change. In order to ensure consistency, the NRC staff and the licensee have used STS 5.0 as guidance to reformat and make other administrative changes. Among the changes proposed by the licensee and found acceptable by the NRC staff are:
(1) providing the appropriate numbers, etc., for STS bracketed information (information that must be supplied on a plant-specific basis and that may change from plant to plant)
(2) changing the wording of specification titles in the STS to conform to existing plant practices (3) combining related requirements currently presented in separate specifications of the CTS into a single specification of PTS (4) presentation changes that involve rewording or reformatting for clarity (including moving an existing requirement to another location within the TSs) that do not involve a change in requirements; and (5) wording changes and additions that are consistent with current interpretation and practice, and that more clearly or explicitly state existing requirements Table A lists the administrative changes proposed in PTS 6.0. Table A provides a summary description of the administrative change that was made, and CTS and PTS references. The NRC staff reviewed all of the administrative and editorial changes proposed by the licensee and finds them acceptable, because they are compatible with the Writers Guide and the STSs, do not result in any substantive change in operating requirements, and are consistent with the Commissions regulations.
3.2 Technical Changes - Less Restrictive (Specific)
Less restrictive requirements include changes, deletions, and relaxations to portions of current TS requirements that are not being retained in PTS. When requirements have been shown to give little or no safety benefit, their removal from the TSs may be appropriate. In most cases, relaxation previously granted to individual plants on a plant-specific basis was the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on STS. The NRC staff reviewed generic relaxations contained in the STS and found them acceptable because they are consistent with current licensing practices and the Commissions regulations.
In electing to implement the specifications of the STSs, the licensee proposed a number of less restrictive changes to the CTS. These changes are discussed below. The associated discussion change identified (e.g., L1) is provided for these unique less restrictive changes.
L.1 CTS 6.2.2.c is modified to add the requirement that, The position may be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.
The purpose of this new requirement statement is to provide wording consistent to that of the STS. The addition of this requirement statement provides the same accommodation for unexpected absences contained in other subparts of Section 6.2.2 of the CTS for radiation protection technicians. This proposed change is consistent with the NRC interpretation of implementation 10 CFR 50.54(m)(2)(i). This change is less restrictive because it provides an accommodation of absence up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> that did not previously apply to the radiation protection technician position. However, the proposed change does not result in technical changes to the CTS.
L.2 CTS 6.2.2.f. is renumbered to PTS 6.2.2.d and reworded to be consistent with the text of STS 5.2.2.d as follows:
Administrative procedures shall be developed and implemented to limit the working hours of personnel who perform safety related functions (e.g., licensed Senior Reactor Operators, licensed Reactor Operators, radiation control technicians, auxiliary operators, and key maintenance personnel).
The controls shall include guidelines on working hours that ensure adequate shift coverage shall be maintained without routine heavy use of overtime.
Any deviation from the above guidelines shall be authorized in advance by the plant manager or the plant managers designee, in accordance with approved administrative procedures, and with documentation of the basis for granting the deviation. Routine deviation from the working hour guidelines shall not be authorized.
Controls shall be included in the procedures to require a periodic independent review be conducted to ensure that excessive hours have not been assigned.
The purpose of this new requirement is to provide wording consistent to that of the STS.
Although the proposed change removes specificity regarding the time constraints contained in the CTS, it does retain the intent of the existing requirement. The requirements for the control of working hours for personnel performing safety-related functions is maintained through administrative procedures. This proposed change is consistent with the current licensing basis for the BVPS-1 and 2. This type of information is not necessary to be included in the TSs to provide adequate protection of public health and safety, because these types of procedural details are contained in controlled programs and maintained pursuant to 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated less restrictive because it removes the specificity regarding the work time constraints contained in the CTS. The proposed change does not result in technical changes to the CTS.
L.3 BVPS Unit 1 CTS 6.7.1.b states that The Safety Limit violation shall be reported to the and Commission within one hour and to the plant manager and to the ORC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
L.4 BVPS Unit 2 CTS 6.7.1.b states that, The Safety Limit violation shall be reported to the Commission within one hour. The Safety Limit violation shall be reported to the plant manager and to the ORC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. CTS 6.7.1.d for both units states that The Safety Limit Violation Report shall be submitted to the Commission, the ORC and the plant manager within 30 days of the violation. The safety limit violation reporting requirements are to be removed from the TSs. DOC A.7 provides the justification for the removal of the requirement to submit the report of the safety limit violation to the NRC within one hour since 10 CFR 50.72 reporting requirements are sufficient. DOC 8 provides the justification for the removal of the requirement to submit the report of the safety limit violation to the NRC within 30 days since the 10 CFR 50.73 reporting requirements are sufficient. DOCs L.3 and L.4 address the reporting requirements within the FENOC organization (plant manager and Office of Regulatory Compliance) that are to be removed from the TSs. This type of information is not necessary to be included in the TSs to provide adequate protection of public health and safety. The requirements for reporting a safety limit violation within the plants organization are a level of detail beyond what is required to be specified in the TSs or the UFSAR to ensure the plant is operated in a safe manner. This detail is administrative in nature and, therefore, does not affect the safe operation of the plant. Thus, these requirements can be removed from the TSs with no adverse effect on the safe operation of the plant.
This change is designated as a less restrictive change because information relating to reporting requirements for safety limit violations within the FENOC organization is being removed from the TSs.
L.5 CTS 6.2.2.b is replaced with the text of STS 5.2.2.b, modified for plant-specific TS subsection numbering to state, Shift crew composition may be less than the minimum requirement of 10 CFR 50.54(m)(2)(i) and 6.2.2.a and 6.2.2.f for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements.
The purpose of this change is to permit the removal of Table 6.2-1 from the CTS. This is accomplished by deleting, modifying, and moving existing requirements such that the PTS is consistent with the STS. The result is that 10 CFR 50.54(m)(2)(i) and TS 6.2.2.2 will then control shift-manning requirements.
One of the requirements for shift manning presently appears as Note # of Table 6.2-1.
This requirement is modified and then moved to TS 6.2.2.b. The first part of the modification is to remove one less from the requirement addressing the minimum control room staffing level.
Table 6.2-1 requires 2 Senior Reactor Operators (SROs), 2 Reactor Operators (ROs), 1 shift technical advisor (STA), and 2 non-licensed auxiliary operators for each of the BVPS control rooms whenever the plant is in Modes 1 through 4. The minimum staffing requirements of 10 CFR 50.54(m)(2)(i) require 2 SROs and 2 ROs to man the facility during Modes 1 through 4 for each unit. For staffing requirements, each BVPS unit is considered a single unit site with a single control room because the operators are licensed for a specific unit. The change is considered a less restrictive change since the temporary reduction in minimum staffing of SROs and ROs would not be limited to only one less than the required minimum. However, for the BVPS units, the reduction in the number of SROs and ROs would be limited to one because the requirements of 50.54(m)(2)(iii) apply, which requires an SRO and either an RO or an SRO to be present in the control room whenever the plant is in Modes 1 through 4. Adopting the proposed requirement thus results in a change that does not alter the SRO and RO minimum staffing requirements specified in CTS 6.2.2.b. The requirement to maintain at least one SRO and either one RO or SRO present at the controls provides adequate assurance that the plant will continue to be operated in a safe manner.
Proposed Sections 6.2.2.a and 6.2.2.f retain the requirements regarding the number of non-licensed auxiliary operators and STAs during Modes 1 through 4. Adopting proposed Sections 6.2.2.a and 6.2.2.b is a less restrictive change regarding the number of non-licensed auxiliary operators because a reduction in the number is not limited.
The proposed change is a temporary deviation (limited to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />). The restrictive time limit provides sufficient assurance that staffing levels will be promptly restored without adversely affecting the safe operation of the plant. Adopting proposed Sections 6.2.2.a and 6.2.2.f has no effect on the STA position, since the maximum possible temporary reduction for this position is one.
Therefore, 10 CFR 50.54(m)(2)(i) and Sections 6.2.2.a and 6.2.2.f will specify the minimum shift composition in Modes 1 through 4.
For Modes 5 and 6, Table 6.2-1 requires 1 SRO, 1 RO, 1 non-licensed auxiliary operator, and no STA. With the proposed change, staffing during these modes will be controlled by 10 CFR 50.54(k), which requires that either an SRO or RO be present at the controls at all times during operation of the plant, and proposed Section 6.2.2.a.
This is a less restrictive change, because adopting the proposed change eliminates the minimum staffing level specified in the CTS for SROs, ROs and non-licensed auxiliary operators during Modes 5 and 6. While in these Modes the plant is in an inherently more stable condition since the reactor is in cold shutdown. Therefore, the staffing requirements of 10 CFR 50.54(k) provide adequate assurance the plant will continue to be operated in a safe manner.
The second part to the modification consists of deleting the current exception to the requirement of 10 CFR 50.54 regarding an oncoming shift crewman being late or absent. The exception does not appear in the STS or the PTS 6.2.2.b requirement.
This exception is unnecessary since the revised requirement does not permit any shift crew position to be unmanned upon shift change due to an oncoming shift crew member being late or absent. The exception was present to provide clarification that the 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> permitted for an unexpected absence of an on-duty crew member can not be used for a late or absent oncoming crew member. The provision for an unexpected absence is specifically to cover those situations where an on-duty crew member falls ill, has a work-related accident that prevents completion of their duties, or some other emergency that prevents continuance of required duties. A crew member late, or absent for their shift, is not considered an on-duty shift crew member. Thus, the revised requirement does not allow any shift crew position to be unmanned upon shift change due to an oncoming shift crew member being late or absent. The CTS clarification is not necessary since the requirements of 10 CFR 50.54(m)(2)(i) and PTS 6.2.2.a and 6.2.2.f provide sufficient guidance as to when the 2-hour grace period can be exercised. Therefore, deleting the clarification does not change the effectiveness of the proposed requirement.
The final modification is to replace the reference to Table 6.2-1, with references to 10 CFR 50.54(m)(2)(i) and PTS 6.2.2.a and 6.2.2.f. The modified note is then moved to TS 6.2.2.b.
These proposed changes are consistent with 10 CFR 50.54(k), 10 CFR 50.54(m)(2)(i),
and the current licensing basis for the BVPS units. These changes are designated as a less restrictive change because staffing levels are reduced for some positions, during some modes of operation, and Table 6.2-1 is being removed from the CTS.
For the reasons presented above, these less restrictive requirements are acceptable because they will not affect the safe operation of the plant. The TS requirements that remain are consistent with current licensing practices, operating experience, and provide reasonable assurance that public health and safety will be protected.
3.3 Technical Changes-Less Restrictive (Generic)
When requirements have been shown to give little or no safety benefit, their removal from the TSs may be appropriate. In most cases, relaxations previously granted to individual plants on a plant-specific basis were the result of (1) generic NRC actions, (2) new NRC staff positions that have evolved from technological advancements and operating experience, or (3) resolution of the Owners Groups comments on the STS. The NRC staff reviewed generic relaxations contained in the STS and found them acceptable because they are consistent with current licensing practices and the Commissions regulations. Three of the changes to the CTS involved the removal of specific requirements and detailed information from individual specifications evaluated to be Types 1 and 2 that follow:
Type 1-Description of Plant Operation Type 2 -
Procedural Details for Meeting TS Requirements and Related Reporting Requirements The following discussions address why each of the two types of information or specific requirements are not required to be included in PTS 6.0.
Descriptions of Plant Operation (Type 1)
The plans for the normal and emergency operation of the facility are required to be described in the UFSAR by 10 CFR 50.34. CTS 6.8.1 requires written procedures to be established, implemented, and maintained for plant operating procedures including procedures recommended in Regulatory Guide 1.33, Appendix A, February 1978.
Controls specified in 10 CFR 50.59 apply to changes in procedures as described in the UFSAR. It is acceptable to remove details of plant operation from the TSs because this type of information will be adequately controlled in the UFSAR.
Procedural Details for Meeting TS and Related Reporting Requirements (Type 2)
Details for performing action requirements are more appropriately specified in the plant procedures required by CTS 6.8.1 and the UFSAR. Prescriptive procedural information in an action requirement is unlikely to contain all procedural considerations necessary for the plant operators to complete the actions required, and referral to plant procedures is therefore required in any event.
The removal of these kinds of procedural details from the CTS is acceptable because they will be adequately controlled in the UFSAR. This approach provides an effective level of regulatory control and provides for a more appropriate change control process.
Similarly, removal of reporting requirements from the CTS is appropriate because 10 CFR 50.36 and 10 CFR 50.73 adequately cover the reports deemed to be necessary.
Table RL lists the CTS specifications and detailed information removed from individual CTS 6.0 specifications that are relocated to licensee-controlled documents in PTS 6.0. Table RL includes: the discussion of change identifier (DOC LA.1); CTS reference; a summary description of the change; the name of the document that retains the CTS requirements; the method for controlling future changes to relocated requirements; and a reference to the specific change type, as discussed above, for not including the information or specific requirements in PTS 6.0.
The NRC staff has concluded that these types of detailed information and specific requirements are not necessary to ensure the effectiveness of PTS 6.0 to adequately protect the health and safety of the public. Accordingly, these requirements may be moved to the UFSAR for which changes are adequately governed by a regulatory requirement (10 CFR 50.59).
To the extent that requirements and information have been relocated to licensee-controlled documents, such information and requirements are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
Further, where such information and requirements are contained in CTS 6.0, the NRC staff has concluded that they do not fall within any of the four criteria in 10 CFR 50.36 (discussed in Part 2.0 of this safety evaluation). Accordingly, existing detailed information and specific requirements, such as generally described above, may be deleted from the CTS.
3.4 Summary Based on the above, the proposed BVPS-1 and 2 Section 6.0 TSs provide clearer, more readily understandable requirements to ensure safe operation of the plants. The NRC staff concludes that they satisfy the guidance in the Commissions policy statement with regard to the content of the TSs, and conform to the model provided in NUREG-1431, Revision 2, with appropriate modifications for plant-specific considerations. The NRC staff further concludes that these TSs satisfy Section 182a of the Atomic Energy Act, 10 CFR 50.36, and other applicable standards.
On this basis, the NRC staff concludes that the proposed BVPS-1 and 2 TSs are acceptable.
The NRC staff has also reviewed the plant-specific changes to the CTS as described in this evaluation. On the basis of the evaluations described herein for each of the changes, the NRC staff has concluded that these changes are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (67 FR 66010). These amendments also relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.229(c)(9) and (10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission 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 inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. Giardina Date: May 15, 2003