L-2007-039, License Amendment Request (LAR 190), Administrative Changes to Technical Specification 6.2.1.a and 6.8.1.a
| ML071360128 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  (DPR-031, DPR-041) |
| Issue date: | 05/04/2007 |
| From: | Jefferson W Florida Power & Light Co |
| To: | Document Control Desk, NRC/NRR/ADRO |
| References | |
| L-2007-039 | |
| Download: ML071360128 (14) | |
Text
MAY04A 200?
FPL L-2007-039 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn.: Document Control Desk Washington, D.C. 20555-00001 Re:
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request (LAR 190)
Administrative Changes to Technical Specifications 6.2.1.a and 6.8.1.a In accordance with the provisions of 10 CFR 50.90, Florida Power and Light Company (FPL) requests that Appendix A of the Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 be amended to modify the Turkey Point Units 3 & 4 Technical Specifications.
These proposed amendments would incorporate administrative changes to Technical Specifications 6.2.1.a and 6.8.1.a, which are related to the common Quality Assurance Topical Report that was approved by the Nuclear Regulatory Commission (NRC) on December 29, 2006. There are no substantive changes made in these proposed License Amendments.
A description and justification of the proposed License Amendments is provided in Enclosure 1.
The no significant hazards consideration determination and environmental impact analysis in support of the proposed Technical Specification changes are provided in Enclosures 2 and 3, respectively. Enclosure 4 provides the proposed marked up Technical Specification pages. provides a clean copy of the changed Technical Specification pages.
FPL has determined that the proposed Technical Specification changes do not involve a significant hazards consideration pursuant to 10 CFR 50.92. No new commitments are being made in this submittal.
The license amendments proposed by FPL have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board. In accordance with 10 CFR 50.91(b)(1), a copy of these proposed license amendments is being forwarded to the State Designee for the State of Florida.
FPL requests NRC review and approval in accordance with a normal NRC review schedule for this type of request. FPL requests a 60-day implementation period.
A6 ov an FPL Group companyq#$
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request Administrative Changes to Technical Specifications 6.2. 1.a and 6.8. 1.a L-2007-039 Page 2 Should there be any questions on this request, please contact James W. Connolly at (305) 246-6632.
I declare under penalty of perjury that the foregoing is true and correct.
Very truly yours, Executed on Turkey Point Nuclear Plant SM Enclosures cc:
Regional Administrator, Region II, USNRC Senior Resident Inspector, USNRC, Turkey Point Plant Florida Department of Health
Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 License Amendment Request Administrative Changes to Technical Specifications 6.2.1.a and 6.8.1.a L-2007-039 Page 3 TABLE OF CONTENTS
" ENCLOSURE 1
" ENCLOSURE 2
- ENCLOSURE3
- ENCLOSURE 4
- ENCLOSURE5 Proposed License Amendments
- 1. Introduction
2. Background
- 3. Description and Bases of the Current Requirements
- 4. Need for Revision
- 5. Description of the Proposed Changes
- 6. Justification for the Proposed Changes
- 7. Safety Summary Determination of No Significant Hazards Consideration Environmental Consideration Technical Specifications Pages: Proposed Markups Technical Specifications Pages: Clean Pages
L-2007-039 ENCLOSURE 1 PROPOSED LICENSE AMENDMENTS 1.0 Introduction In accordance with 10 CFR 50.90 Florida Power and Light Company (FPL) requests that Appendix A of Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Units 3 and 4 be amended to modify Technical Specification Sections 6.0 "Administrative Controls." The purpose of these amendments is to: 1) revise TS Section 6.2.1.a to correctly reference the recently approved common Quality Assurance Topical Report; 2) revise TS 6.8.1.a to delete reference to Regulatory Guide 1.33 and to specific sections of ANSI N18.7 and instead to reference the Quality Assurance Topical Report.
2.0
Background
As part of the ongoing Florida Power and Light Company (FPL) Fleet standardization efforts, FPL submitted to Nuclear Regulatory Commission (NRC) a common Quality Assurance Topical Report (QATR) to replace and consolidate the previously docketed site specific quality assurance (QA) programs for St. Lucie Units 1 and 2, Turkey Point Units 3 and 4, Seabrook Station and Duane Arnold Energy Center. The common FPL Fleet QA program described in the common QATR was approved by the NRC on December 29, 2006.
3.0 Description and Bases of the Current Requirements Technical Specification (TS) Section 6.2.1.a states that the lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to, and including all operating organization positions. Those relationships shall be documented and updated as appropriate in the form of organizational charts. These organizational charts will be documented in the Topical Quality Assurance Report and updated in accordance with 10 CFR 50.54(a)(3).
TS Section 6.8.1.a specifies that written procedures shall be established and implemented covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Section 5.1 and 5.3 of ANSI N18.7-1972.
4Property "ANSI code" (as page type) with input value "ANSI N18.7-1972.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..0 Need for Revision Technical Specifications 6.2.1.a and 6.8.1.a require revision due to the implementation of the common Quality Assurance Topical Report, which was approved by NRC on December 29, 2006.
L-2007-039 Enclosure I 5.0 Description of the Proposed Changes The Markups to the Technical Specification Pages are provided in Enclosure 4.
The following changes are proposed:
" Revise Technical Specification 6.2.1.a, to correct the reference from "Topical Quality Assurance Report" to "Quality Assurance Topical Report."
" Revise Technical Specification 6.8.1.a to delete "recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, Sections 5.1 and 5.3 of ANSI N18.7-1972" and to add "required by the Quality Assurance Topical Report."
6.0 Justification for the Proposed Changes TS 6.2.1.a is revised to simply correct the reference of the common QA program document as "Quality Assurance Topical Report" instead of the previously docketed document referred to as the "Topical Quality Assurance Report."
TS 6.8.1.a is revised to delete reference to the Appendix A of Regulatory Guide 1.33 Revision 2, February 1978 since FPL has established appropriate equivalent requirements consistent with the Regulatory Guide 1.33 within the QATR. The NRC approved common QATR includes a commitment to establish and implement, within the QATR, administrative controls for the operating phase activities that are consistent with the guidance of Regulatory Guide 1.33.
Also, TS 6.8.1.a is revised to delete the specific sections of the ANSI N18.7-1972. The applicable procedures recommended in Sections 5.1 and 5.3 of ANSI N18.7-1972 are included in the ANSI N18.7-1976. While FPL does not commit to compliance with the requirements of ANSI N18.7-1976, applicable provisions of ANSI N18.7 -1976 have been incorporated into the QATR. As part of the QATR evaluation, the NRC Staff concluded that FPL has "adequately incorporated ANSI N18.7-1976, as necessary into the proposed QATR."
Based on the above, the proposed changes are considered administrative in nature, and are consistent with the approved common Quality Assurance Topical Report.
7.0 Safety Summary The proposed TS changes are administrative in nature and will have no adverse effect on plant operations. Therefore, there will be no adverse impact on public health and safety.
L-2007-039 ENCLOSURE 2 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Pursuant to 10 CFR 50.92, a determination may be made that the proposed license amendments involve no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each consideration is discussed below.
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
No. The proposed changes are administrative in nature 1) correcting the reference of the Quality Assurance Topical Report in the Technical Specification (TS) Section 6.2.1.a; and 2) removing references to Regulatory Guide 1.33 and specific sections of the ANSI N 18.7 1972 from TS Section 6.8.1.a and instead referencing the Quality Assurance Topical Report. These changes do not involve a significant increase in the probability or consequences of an accident previously evaluated because they do not affect assumptions contained in plant safety analyses, the physical design and/or operation of the plant, nor do they affect Technical Specifications that preserve safety analysis assumptions. Therefore, the proposed changes do not affect the probability or consequences of accidents previously evaluated.
- 2. Does the proposed change create the probability of a new or different accident from any accident previously evaluated?
No. The proposed changes are administrative in nature 1) correcting the reference of the Quality Assurance Topical Report in the Technical Specification (TS) Section 6.2.1.a; and 2) removing references to Regulatory Guide 1.33 and specific sections of the ANSI N18.7 1972 from TS Section 6.8.1.a and instead referencing the Quality Assurance Topical Report. These changes do not introduce a new mode of plant operation and do not involve physical modification to the plant. No new failure is introduced since they do not involve the addition or modification of equipment nor do they alter the design or operation of plant systems, structures or components.
Therefore, the proposed changes do not create the probability of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
No. The proposed changes are administrative in nature 1) correcting the reference of the Quality Assurance Topical Report in the Technical Specification (TS) Section 6.2.1.a; and 2) removing references to Regulatory Guide 1.33 and specific sections of the ANSI N18.7 1972 from TS Section 6.8.1.a and instead referencing the Quality Assurance Topical Report. The operating limits and functional capabilities of the systems, structures and components are unchanged. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above, FPL concludes that the proposed amendments present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.
L-2007-039 ENCLOSURE 3 ENVIRONMENTAL CONSIDERATION The proposed Technical Specification changes are administrative in nature. The proposed license amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and no significant increase in individual or cumulative occupational radiation exposure. FPL concluded that the proposed amendments meet the criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and that, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment need not be prepared in connection with issuance of the amendment.
L-2007-039 ENCLOSURE 4 TECHNICAL SPECIFICATION PAGES: PROPOSED MARKUPS 6-1 6-13
ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant General Manager shall be responsible for overall unit operation of both units and shall delegate in writing the succession to this responsibility during his absence.
6.1.2 The Nuclear Plant Supervisor (or during his absence from the control room, a designated individual) shall be responsible for the control room command function. A management directive to this effect, signed by the Site Vice President shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION ONSITE AND OFFSITE ORGANIZATION 6.2.1 An onsite and an offsite organization shall be established for facility operation and corporate management.
The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear power plant.
- a.
Lines of authority, responsibility and communication shall be established and defined from the
-- e
- highest management levels through intermediate levels to, and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in) the form of organizational charts. These organizational charts will be documented in the(I 1
Quality Assurance Report and updated in accordance with 10 CFR 50.54(a)(3).
- b.
The Chief Nuclear-Of hall have corporate responsibility for overall plant nuclear safety, and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.
- c.
The Plant General Manager shall be responsible for overall plant safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
- d.
Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.
- e.
Although health physics individuals may report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the Health Physics Supervisor shall have direct access to that onsite individual having responsibility for overall unit management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures.
TURKEY POINT - UNITS 3 & 4 6-1 AMENDMENT NOS. 220 AND 214
ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures 0hall be established, implemented, and maintained covering the activities referenced below:
.4H QL W
- a.
The ap licable procedure recommended in Appendix A of Regulatory Guide 1.33, Revision 2, ebruary 1978 Sections 5.1 and 5.3 of ANSI N18.7-1972; C-
- b.
The emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Generic Letter No. 82-33;
- c.
PROCESS CONTROL PROGRAM implementation;
- d.
OFFSITE DOSE CALCULATION MANUAL implementation;
- e.
Quality Control Program for effluent monitoring using the guidance in Regulatory Guide 1.21, Revision 1, June 1974;
- f.
Facility Fire Protection Program;
- g.
Quality Control Program for environmental monitoring using the guidance in Regulatory Guide 4.1, Revision 1, April 1975; and
- h.
Diesel Fuel Oil Testing Program implementation.
6.8.2 Deleted 6.8.3 Deleted TURKEY POINT - UNITS 3 & 4 6-13 AMENDMENT NOS. 201 AND 195
L-2007-039 ENCLOSURE 5 TECHNICAL SPECIFICATION PAGES: CLEAN PAGES 6-1 6-13
ADMINISTRATIVE CONTROLS 6.1 RESPONSIBILITY 6.1.1 The Plant General Manager shall be responsible for overall unit operation of both units and shall delegate in writing the succession to this responsibility during his absence.
6.1.2 The Nuclear Plant Supervisor (or during his absence from the control room, a designated individual) shall be responsible for the control room command function. A management directive to this effect, signed by the Site Vice President shall be reissued to all station personnel on an annual basis.
6.2 ORGANIZATION ONSITE AND OFFSITE ORGANIZATION 6.2.1 An onsite and an offsite organization shall be established for facility operation and corporate management.
The onsite and offsite organization shall include the positions for activities affecting the safety of the nuclear power plant.
- a.
Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to, and including all operating organization positions. Those relationships shall be documented and updated, as appropriate, in the form of organizational charts. These organizational charts will be documented in the Quality Assurance Topical Report and updated in accordance with 10 CFR 50.54(a)(3).
- b.
The Chief Nuclear Officer shall have corporate responsibility for overall plant nuclear safety, and, shall take. any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the plant to ensure nuclear safety.-
- c.
The Plant General Manager shall be responsible for overall plant safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant.
- d.
Although the individuals who train the operating staff and those who carry out the quality assurance functions may report to the appropriate manager onsite, they shall have sufficient organizational freedom to be independent from operating pressures.
- e.
Although health physics individuals may report to any appropriate manager onsite, for matters relating to radiological health and safety of employees and the public, the Health Physics Supervisor shall have direct access to that onsite individual having responsibility for overall unit management. Health physics personnel shall have the authority to cease any work activity when worker safety is jeopardized or in the event of unnecessary personnel radiation exposures.
TURKEY POINT - UNITS 3 & 4 6-1 AMENDMENT NOS.
AND
ADMINISTRATIVE CONTROLS 6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
- a.
The applicable procedures required by the Quality Assurance Topical Report.
- b.
The emergency operating procedures required to implement the requirements of NUREG-0737 and Supplement 1 to NUREG-0737 as stated in Generic Letter No. 82-33;
- c.
PROCESS CONTROL PROGRAM implementation;
- d.
OFFSITE DOSE CALCULATION MANUAL implementation;
- e.
Quality Control Program for effluent monitoring using the guidance in Regulatory Guide 1.21, Revision 1, June 1974;
- f.
Facility Fire Protection Program;
- g.
Quality Control Program for environmental monitoring using the guidance in Regulatory Guide 4.1, Revision 1, April 1975; and
- h.
Diesel Fuel Oil Testing Program implementation.
6.8.2
-Deleted 6.8.3 Deleted TURKEY POINT - UNITS 3 & 4 6-13 AMENDMENT NOS.
AND