ML13316A869
| ML13316A869 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/15/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13316A865 | List: |
| References | |
| TAC-54700, TAC-54701, TAC-54893, NUDOCS 8510180323 | |
| Download: ML13316A869 (17) | |
Text
P'S REQGJO 0
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPOPTINIC AMENDMENT NO. 91 TO PROVISIONAL OPERATING LICENSE NO. DPR-13 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-206
1.0 INTRODUCTION
By letter dated April 12, 1985, as modified by letters dated July 1 and July 31, 1985, Southern California Edison Company (the licensee) proposed changes to the San Onofre Nuclear Generating Station, Unit No. 1. These submittals superseded the licensee's application dated May 1, 1984 and the supplemental information in letters dated August 16 and September 4, 1984.
These changes would modify the Appendix A Technical Specifications on Administrative Controls including reporting requirements, minimum shift crew composition, offsite organization, and the transfer of the Nuclear Audit and Review Committee responsibilities to the Nuclear Safety Group.
A Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on May 21, 1985 (50 FR 20991).
No comments or requests for hearing were received.
2.0 DISCUSSION AND EVALUATION Each of the proposed changes is discussed and evaluated in the following paragraphs.
2.1 Specification 6.1.1 The existing Specification states that the "Station Manacer shall be responsible for overall facility operation." The licensee proposes to revise this Specification to make minor editorial changes and to reflect an upgraded organization. The site organization has been upgraded such that a "Vice President and Site Manager, Nuclear Generation Site shall be responsible for design, construction, operation and maintenance of Unit 1 at San Onofre Nuclear Generating Station, and all site support functions."
The proposed change reflects a greater concentration of plant-support resources at the site and a stronoer involvement by senior management in site activities; therefore, the staff concludes that the proposed change is acceptable.
8510180323 851015 PDR ADOCK 05000206 P
2.2 Specification 6.1.2 This is a new Specification that would make the Shift Superintendent, which is the senior position in an operating shift crew, formally responsible for the control roon command function. To allow the Shift Superintendent to be absent for short periods from the "control room area" (defined as the control room and the Shift Superintendent's office), the Specification would allow another formally designated individual to assume responsibility for the control room command function. The acceptability of the "control room area" definition is evaluated in Item 2.5 below. Otherwise, the licensee's proposal conforms with the Standard Technical Specifications (STS) for Westinchouse Pressurized Water Reactors (NUREG-0452, Revision 4, Fall 1981) and therefore, the staff concludes that the proposed specification is acceptable.
2.3 Specifications 6.2.1 The licensee has renumbered the offsite organization chart'as Figure 6.2-1 and revised the text of Specification 6.2.1 such that the Figure applies to "unit" management and technical support rather than "facility" management and technical support. These are editorial changes and the staff concludes that they are acceptable.
2.4 Specifications 6.2.2 and 6.2.2.a Specification 6.?.2 establishes organizational requirements for the unit staff.
The licensee has renumbered the offsite organization chart as Figure F.?-3, and used the term "site" organization rather than "facility" organization.
These are editorial changes and the staff concludes that they are acceptable.
2.5 Specification 6.2.2.b The licensee proposes to (l) add a sentence to Specification 6.2.2.b to require that, in Modes 1 through 4, at least one licensed senior operator he in the control room area (defined as the control room and the Shift Superintendent's office) and (2) delete existing Specification 6.?.?.c, which establishes requirements pertaining to the presence of licensed operators in the control room. The Specifications following the existing 6.2.?.c would be renumbered accordingly.
At San Onofre Unit 1, the Control Room Supervisor (CRS) position fulfills the requirement for a senior operator in the control room. The primary location of the CPS is in the control room, where there is direct and prompt access to information on current unit conditions and where the operator at the controls car be directly supervised. The CRS also has the flexibility to be in the Shift Superintendent's office, which is within audible range of the control room annunciators. The licensee anticipates that the CRS will spend only a small percentage of his on shift duty time in the Shift Superintendent's office. Based on 10 CFR 50.54(m)(2)(iii) and guidance published in the Federal Pegister (48 FR 31611, July 11, 1983), the staff concludes that the licensee's proposal is acceptable.
-3 The deletion of the current Specification 6.2.2.c is also acceptable. The proposed change deletes outdated requirements on the number of reactor operators in the control room. Minimum requirements pertaining to licensed operators on shift are contained in 10 CFR 50.54(m), which the licensee proposes to accommodate by updating the Technical Specification table on minimum shift crew composition (see Item 2.8 below).
2.6 Specifications 6.2.2.c, 6.2.2.d, 6.2.2.e, and 6.2.2.f Existing Specifications 6.2.2.d, 6.2.2.e, 6.2.2.f and 6.2.2.g, are renumbered.6.2.2.c, 6.2.2.d, 6.2.2.e and 6.2.2.f, respectively.
Specifications 6.2.2.c, 6.2.2.d and 6.2.2.e are also revised to conform with the Westinghouse STS (NUREG-0452, Rev.4); therefore, the staff concludes that the proposed changes are acceptable.
2.7 Figures 6.2-1 and 6.2-2 The offsite and onsite organization charts have been renumbered as Figures 6.2-1 and 6.2-2, respectively. These are editorial changes and therefore the staff finds that they are acceptable.
Both Figures have been revised to reflect new organizational positions.
The new organization is described below:
Nuclear Engineering, Safety and Licensing Department (Offsite)
The Vice President-Nuclear Engineering, Safety and Licensing has overall responsibility for nuclear licensing, quality assurance, offsite nuclear engineering support, offsite health physics support, offsite emergency planning, and the independent safety review function. The Managers of Nuclear Licensing, Nuclear Engineering, Quality Assurance, and Nuclear Safety all report directly to the Vice President-Nuclear Engineering, Safety and Licensing. The independent Nuclear Safety Group, the Emergency Planning Group, and the Offsite Health Physics Support Group report through the Manager-Nuclear Safety. The new organization reflects a greater corporate commitment to offsite technical support of the San Onofre site.
Nuclear Generation Site Department (Onsite)
The Vice President and Site Manager (Nuclear Generation Site) has overall responsibility for design, construction and operations at the San Onofre site. The Station Manager and the Managers of Nuclear Generation Services, Nuclear Training, Budgets and Cost Control, and Material and Administrative Services all report directly to the Vice President and Site Manager. The new organization reflects a higher level of management involvement in site activities.
The sta f has revised the proposed Figures and finds them acceptable. The organization for the management and technical support of nuclear activities is adequately represented by Figure 6.2-1. The licensee's onsite operating organization is adequately represented by Figure 6.2-?.
Both Figures satisfy the guidelines of Sectior 3 of ANSI N18.1-1971, "Selection and Traininq of Nuclear Power Plant Personnel," and are acceptable.
2.8 Table 6.2-1 The Table specifying the minimum shift crew composition has been renumbered Table 6.2-1. This is an editorial chane and the staff finds that it is acceptable.
The Table has also been expanded to conform with the Westinghouse STS (NUREG-0452, Rev. 4) and to define the Control Poorm Area as the control room plus the Shift Superintendent's office. The staff finds that these changes are acceptable (see Item 2.5 above).
2.9 Specification 6.3.1 Specification 6.3.1 establishes unit staff qualifications requirements.
The licensee proposes to make minor editorial-changes and add a sentence to describe the functions of the Shift Technical Advisor. The revised Specification conforms with the corresponding Westinghouse STS (NUREG-0452, Rev. 4) and, therefore, the staff finds that it is acceptable.
2.10 Specification 6.4.1 Specification 6.4.1 establishes unit staff training requirements. The licensee proposes to (1) make minor editorial changes, (2) chanoe one title from "Training Manager" to "Manager, Nuclear Training" to conform with the revised organization charts in Figures 6.2-1 and 6.2-2 (see Item 2.7 above),
and (3) add a supplemental training requirement contained in a March 28, 1980 letter from the NRC to all licensees. The revised Specification conforms with the corresponding Westinghouse STS (NUREG-0452, Rev. 4) and therefore, the staff finds that it is acceptable.
2.11 Specification 6.4.2 Specification 6.4.2 establishes Fire Brigade training requirements. The licensee proposes to change the position responsible for Fire Brigade training from the "Training Manaper" to the "Manager-Station Emergency Preparedness." This change conforms with the site organization represented by the revised Figure 6.2-2 (see Item 2.7 above) and therefore, the staff finds that it is acceptable.
2.12 Specification 6.5.1.2 Specification 6.5.1.2 establishes the membership of the Onsite Review Committee (OSRC). The licensee proposes to revise three entries to make
-5 them conform with the revised site organization chart in Figure 6.2-2 (see Item 2.7 abovel.
The three revised entries are:
Plant Superintendent Unit 1 Sunervisor of Plant Chemistry Supervising Engineer (NSSS Engineering, Power Generation, Computers, or STA)
The proposed changes do not materially affect the OSRC membership and, therefore, the staff concludes that they are acceptable.
2.13 Specification 6.5.1.5 Specification 6.5.1.5 establishes quorum requirements for the Onsite Review Committee (OSRC). The minimum quorum for OSRC activities is changed from "the Chairman or his designated alternate and four members including alternates" to "the Chairman or his designated alternate and one-half the remaining membership including alternates" (there are currently ten members in addition to the Chairman). This chance would essentially require majority representation before OSRC business can be conducted, which the staff finds is acceptable.
2.14 Specification 6.5.1.6.a Specification 6.5.1.6.a establishes Onsite Review Committee (OSRC) responsibilities associated with Technical Specification violations. The licensee proposes to change the title of the independent review committee, to which the OSRC must send a report, from the "Nuclear Audit and Review Committee" to the "Nuclear Safety Group."
The change conforms with the organization represented by the revised Figure 6.?-1 (see Item 2.7 above) and, therefore, the staff finds that it is acceptable. The acceptability of using the Nuclear Safety Group to satisfy independent review and audit requirements is evaluated in Item 2.29, below.
2.15 Specification 6.5.1.6.b The existing Specification requires OSPC review of "events requirinq 24-hour written notification to the Commission."
The licensee proposed to change this review requirement to apoly to "all Reportable Events."
The proposed Specification uses the terminology in 10 CFP 50.73 (Licensee Event Report System) and, therefore, the staff concludes that the proposed change is acceptable.
2.16 Specification 6.5.1.6.d Specification 6.5.1.6.d establishes Onsite Peview Committee (OSRC) responsibilities for performing special reviews as requested by the Station Manager or the head of the independent review group. The licensee proposes
-6 to change the Specification by replacing the title "Chairman of the NARC" with the title."NSG Supervisor."
The change conforms with the organization represented by revised Figure 6.2-1 (see Item 2.7, above) and, therefore, the staff concludes that it is acceptable. The acceptability of using the Nuclear Safety Group (NSG) to satisfy independent review and aucit reouirements is.
evaluated in Item 2.29, below.
2.17 Specification 6.5.1.7.b Specification 6.5.1.7.b establishes the means of resolving differences between the Onsite Review Committee (OSRC) and the Station Manager. The licensee proposes to change the Specification in two places to make the Vice President and Site Manager responsible for resolving such disagreements.
These changes conform with the organization charts in Figures 6.2-1 and 6.2-2 (see Item 2.7 above) and reflect a hicher level of management involvement in site operations; therefore, the staff concludes that the changes are acceptable.
One additional title in Specifications 6.5.1.7.b has been changed to reflect the -act that the Nuclear Safety Group (NSG) is prepared to assume responsibilty for the independent review and audit function (see Item ?.?9, below). This is an editorial change and the staff finds that it is acceptable.
2.18 Specification 6.5.1.8 Specification 6.5.1.8 requires, in part, that Onsite Review Committee (OSPC) meetino minutes be forwarded to the independent review organization. The licensee proposes to change one title in this Specification to reflect the fact that the Nuclear Safety Group (NSG) is prepared to assume responsibility for the independent review and audit function (see Item ?.?9, below). This is an editorial change and the staff finds that it is acceptable.
2.19 Specification 6.5.2.1 Existing Specification 6.5.1.9, which establishes procedure review requirements, is renumbered as Specification 6.5.2.1.
The existing Specification makes the Station Manager responsible for assuring that safety-related procedures/programs, and changes thereto, are prepared by qualified individuals/organizations. The proposed change would place this respornibility with the Vice President and Site Manager. This change reflects a higher degree of management involvement in site activities and, therefore, the staff finds that it is acceptable.
A sentence is also added to Specification 6.5.2.1 to require that documentation of specified activities be provided to the Nuclear Safety Group (NSG). The staff concurs that the NSG should monitor procedure review activities; therefore, the staff concludes that the proposed change is acceptable.
-7 2.20 Specification 6.5.2.2 Existirn Srecification 6.5.1.10, which establishes Technical Specification review requirements, is renumbered as Specification 6.5.2.2. The licensee proposed to add a new sentence to the Specification to require that documentation of activities associated with proposing changes to the Technical Specifications be provided to the Vice President and Site Manager and to the Nuclear Safety Group (NSG).
The change reflects a higher degrpe of management involvement in site activities, and it also involves the NSG in monitoring Technical Specification change activities.
The staff concludes that the proposed change is acceptable.
2.21 Specification 6.5.2.3 Existing Specification 6.5.1.11, which establishes plant modification review requirements, is renumbered as Specification 6.5.2.3.
The existing Specification requires that safety-related modifications "be approved prior to implementation by the Station Manager; or by the Manager, Technical as previously designated by the Station Manager." The licensee proposes to transfer the designation function from the Station Manager to the Vice President and Site Manager. A sentence is also added to require that documentation of modification activities be provided to the Vice President and Site Manager and to the Nuclear Safety Group (NSG).
The proposal reflects a higher degree of management involvement in site activities and also involves the NSG in monitoring plant modification activities. The staff concludes that the proposed changes are acceptable.
2.22 Specification 6.5.2.4 Existing Specification 6.5.1.12, which establishes general technical review requirements, is renumbered as Specification 6.5.2.4.
References to existing Specifications 6.5.1.9, 6.5.1.10, and 6.5.1.11 are changed to 6.5.2.1, 6.5.2.2, and 6.5.2.3, respectively, to conform with the revised numbering scheme. These are editorial changes and the staff concludes that they are acceptable.
The existing Specification requires that individuals responsible for specified reviews be "designated by the Station Manager to perform such reviews."
The licensee proposes to transfer the designation function from the Station Manager to the Vice President and Site Manager. This change reflects a higher level of management involvement in site activities and, therefore, the staff concludes that it is acceptable.
2.23 Specification 6.5.2.5 Existing Specification 6.5.1.13, which establishes review requirements 'or Droposed tests and experiments, is renumbered as Specification 6.5.2.5.
-8 The existing Specification lists five site managers who are designated by the Station Manager as authorized reviewers of proposed tests and experiments.
The licensee proposes to replace the specific reviewer list with a general requirement to use "members of the site/station management staff previously designated by the Vice President and Site Manager." Although the proposed chance is not specific about who is authorized to do the safety review, it does require that reviewers be at the manager level and be formally designated by the senior management official at the site. The change also reflects a higher level of management involvement in site activities and, therefore, the staff concludes that it is acceptable.
A sentence is also added to Specification 6.5.2.5 to require that documentation of test/experiment review activities be provided to the Vice President and Site Manager and to the Nuclear Safety Group (NSG).
The change reflects a higher degree of management involvement in site activities and it also involves the NSG in monitoring test/experiment activities. The staff concludes that the proposed change is acceptable.
2.24 Specification 6.5.2.6 Existing Specification 6.5.1.14, which establishes administrative requirements.
pertaining to the station security plan and implementirc procedures, is renumbered as Specification 6.5.2.6.
The licensee proposes to differentiate between the plan requirements and the procedure requirements by adding a new clause to Specification 6.5.2.6 to require that implementing procedures be prepared and approved in accordance with Specification 6.8, "Procedures and Programs." The referencing of Specification 6.8 to establish reouirements for security plan implementing procedures is in conformance with the Westinchouse STS (NUREG-0452, Rev. 4) and, therefore, the staff concludes that it is acceptable.
The existing Specification also requires that recommended changes (to the security-plan and implementing procedures) be transmitted to the Manager of Nuclear Operations and to the Chairman of the Nuclear Safety and Review Committee (NARC).
The licensee proposes to revise the Specification to require that recommended changes (to the security plan only) be transmitted to the Vice President and Site Manager and to the Nuclear Safety Group (NSG). The changes reflect a higher level of management involvement in site activities and a transfer of responsibility from the NARC to the NSG (see Item 2.29 below). The administrative control of the security plan implementing procedures will be handled via Specification 6.8 (see Items 2.36, 2.37, and 2.38 below). The staff concludes that the proposed changes are acceptable.
2.25 Specification 6.5.2.7 Existing Specification 6.5.1.15, which establishes administrative requirements pertainino to the station emergency plan, is renumbered as Specification 6.5.2.7.
-9 Specification 6.5.2.7 is identical to Specification 6.5.2.6 except that it applies to the station emergency plan and implementing procedures rather than the station security plan and implementing procedures. The staff concludes that the proposed changes are acceptable for the same reasons as given in item 2.24, above.
2.26 Specification 6.5.2.8 Existing Specification 6.5.1.18, which establishes administrative requirements for the review and documentation of uncontrolled or unplanned releases of radioactivity to the environment, is renumbered as Specification 6.5.2.8.
The licensee proposes to revise the Specification to require that release reports be forwarded to the Vice President and Site Manager and to the NSG.
The change reflects a higher degree of management involvement in site activities, and it also involves the NSG in post-release actions. The staff concludes that the proposed change is acceptable.
2.27 Specification 6.5.2.9 Existing Specification 6.5.1.16, which requires the review of charges to radwaste treatment systems, is renumbered as Specification 6.5.2.9.
The existing Specification requires the Station Manager to ensure that changes to the Process Control Program, the Offsite Dose Calculation Manual, and radwaste treatment systems are properly reviewed. The licensee proposes to revise the Specification to allow the Station Manager to designate the approval of such changes and to require that documentation of these activities be provided to the Vice President and Site Manager and to the Nuclear Safety Group (NSG).
The revisions will (1) ensure that senior station management is aware of changes to radiological programs, which should help to achieve a more comprehensive and consistent treatment of radiological matters, (2) conform with the revised organization charts (see Item 2.7 above), and (3) reflect the transfer of responsibility from the NARC to the NSG (see Item 2.29 below).
The staff concludes that the proposed changes are acceptable.
2.28 Specification 6.5.2.10 Existing Specification 6.5.1.17, which establishes documentation requirements for technical reviews, is renumbered as Specification 6.5.2.10. Reference to existir Specifications "6.5.1.9 through 6.5.1.16" is changed to "6.5.2.1 through 6.5.2.9" This is an editorial change and the staff concludes that it is acceptable.
2.29 Specifications 6.5.3 and 6.5.3.1 Existing Specifications 6.5.2 and 6.5.2.1, which described the independent review and audit function, are renumbered as Specifications 6.5.3 and 6.5.3.1.
10 The licensee proposes to revise the Specification 6.5.3.1 to reflect the transfer of responsibility from the Nuclear Audit and Review Committee (NARC), which provides independent offsite review by means of periodic committee meetings, to the Nuclear Safety Group (NSG), which provides independent offsite review by means of a permanent offsite organizational unit. The use of an Proanizational unit functioning as an independent review body conforms with Section 4.3.3 of ANSI N18.7-1976/ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
The proposed Specification 6.5.3.1 also conforms with the corresponding Specification in the Westinghouse STS (NUREG-0452, Rev. 4).
The staff concludes that the licensee's proposal is acceptable.
2.30 Specification 6.5.3.2 Existing Specification 6.5.2.2 (NARC composition), 6.5.2.3 (NARC alternates), 6.5.2.5 (NARC meeting frequency), and 6.5.2.6 (NARC quorum) are replaced by a single new Specification 6.5.3.2. The new Specification reflects the transfer of responsibility from the NARC to the NSG (see Item 2.29, above) and establishes qualification and experience requirements for NSG members in conformance with Section 4.7 of ANSI/ANS-3.1-1981, "Selection, Oualification and Training of Personnel for Nuclear Power Plants."
The staff concludes that the proposed changes are acceptable.
2.31 Specifications 6.5.3.3. and 6.5.3.4 Existing Specification 6.5.2.4, which addresses the administrative control of consultants to the independent review body, is renumbered as Specification 6.5.3.3. Existing Specification 6.5.2.7, which establishes the responsibilities of the independent review body, is renumbered as Specification 6.5.3.4.
The licensee proposes to revise these two Specifications to (1) make minor editorial changes, (2) reflect the transfer of responsibility from the NARC to the NSG (see Item 2.29, above), and (3) conform with the corresponding Specifications in the Westinghouse STS (NUREG-0452, Rev. 4).
Specification 6.5.3.4 also incorporates the term "Reportable Events," which is codified in 10 CFP 50.73. The staff concludes that the proposed changes are acceptable.
2.3? Specifications 6.5.3.5, 6.5.3.6 and 6.5.3.7 Existing Specification 6.5.2.8, which addresses the scope of facility audits by the independent review body, is renumbered as Specification 6.5.3.5.
Existing Specification 6.E.2.9, which addresses the authority of the independent review group, is renumbered as Specification 6.5.3.6. Existing Specification 6.5.2.10, which addresses the documentation of independent review activities, is renumbered as Specification 6.5.3.7.
The licensee proposes to revise these three Specifications to (1) make minor editorial changes, (2) conform with the revised organization charts (see Item 2.7, above), and (3) reflect the transfer of responsibility from the NARC to the NSG (see,Item 2.29, above).
The staff concludes that the proposed changes are acceptable.
11 2.33 Deletion of References to the Nuclear Control Board Existing Specifications 6.5.3, 6.5.3.1, 6.5.3.2, 6.5.3.3, 6.5.3.4, and 6.5.3.5 pertain to the Nuclear Control Board, which is a group of Southern California Edison corporate officials that provides upper management over sight of sinnificant safety issues at the San Onofre Generating Station.
The licensee proposes to delete these Specifications even though the Nuclear Control Board will continue as an organizational entity.
Upper management oversight activities beyond those associated with the onsite review committee and the independent offsite review group (the OSRC and the NSG at San Onofre Unit 1) are not normally included as formal Technical Specification requirements and they are not a part of the Westinghouse STS (NUREG-0452, Rev. 4).
The staff concludes that the proposed deletions are acceptable.
2.34 Specification 6.6 The licensee proposes to add a new Specification to incorporate administrative actions to be taken in response to Reportable Events.
The proposed Specification addresses requirements in 10 CFR 50.73. The staff concludes that the proposed changes are acceptable.
2.35 Specification 6.7 Specification 6.7 specifies actions to be taken in the event a Safety Limit is violated. The licensee proposes to revise the Specification to (1) incorporate titles that conform with the revised organization charts (see Item 2.7, above), (2) reflect the transfer of responsibility from the NARC to the NSG (see Item 2.29, above), and (3) conform with the corresponding Westinghouse STS (NUREG-0452, Rev. 4).
The staff concludes that the proposed changes are acceptable.
2.36 Specification 6.8.1 Specification 6.8.1 lists the activities that must be covered by written procedures. The licensee has revised the Specification to conform more closely with the corresponding Westinghouse STS (NUREG-0452, Rev. 4).
The revised Specification also goes beyond the STS by requiring written procedures covering the Process Control Program, the Offsite Dose Calculation Manual, the QA program for effluent and environmental monitoring, and various fire protection administrative matters. The revised Specification retains the existinr requirement that procedures and administrative policies meet or exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1976, "Administrative Controls and Quality Assuran-e for the Operational Phase of Nuclear Power Plants." The staff concludes that the proposed changes are acceptable.
2.37 Specification 6.8.2 Specification 6.8.? establishes review requirements for procedures and procedure changes. The licensee has revised the Specification to (1) conform with the revised organization charts (see Item 2.7, above) and (2) conform with revised Specifications covering the technical review and control. nf procedures and programs (see !tems 2.21 through 2.25, above). The staff concludes that the proposed changes are acceptable.
2.38 Specification 6.P.3 Specification 6.8.3 establishes administrative requirements for making temporary changes to procedures. The licensee proposes to revise the Specification to conform more closely with the corresponding Westinghouse STS (NUREG-0452, Rev. 4) and to conform with the proposed Specification 6.8.2 (see Item 2.37, above). The staff concludes that the proposed changes are acceptable.
2.39 Specification 6.8.4 Existing Specifications 6.13, 6.14, and 6.15 which require that programs be established, implemented, and maintained for (1) reducing primary coolant leakage outside containment, (2) monitoring airborne iodine concentration in vital areas under accident conditions, and (3) monitoring the reactor coolant system subcooling margin, are renumbered 6.8.4.a,b, and c, respectively. A minor editorial change was made in the wording of the specification regarding the program for reducing primary coolant leakage outside containment; the frequency for conducting integrated leak tests for each system remains at least as frequently as refueling cycle intervals.
These changes are editorial and, therefore, the staff concludes that they, are acceptable.
New Specification 6.8.4.d incorporates the provisions of the secondary water chemistry monitoring program of existing license condition 3.1.
This addition groups this program together with the other required programs. With the incorporation of this program in new Specification 6.8.4.d, license condition 3.1 is redundant and therefore it is deleted. This is an editorial change and, therefore, the staff concludes that it is acceptable.
New Section 6.8.4.e adds a requirement for a program that will ensure the capability to obtain and analyze post-accident samples. This new program is in accordance with Generic Letter 83-37, "NIREG-0737 Technical Specifications,"
November 1, 1983.
Item (2) of Enclosure 1 of Generic Letter 83-37 states that an administrative program should be established to ensure the capability of post-accident sampling. The staff finds that this new specificatior complies with this quidance and, therefore, it is acceptable.
13 2.40 Specification 6.9.1 Existing precification 6.9.1, which specifies routine reports that must be submitted, has been reformatted. Existing Specification 6.9.1.a has been reformatted and renumbered 6.9.1.1, 6.9.1.2, and 6.9.1.3. In addition, the addressee for routine reports has been changed to the NRC Regional Administrator which reflects the current NRC organization. These charges are editorial and, therefore, the staff finds that they are acceptable.
Existing Specification 6.9.1.b has been reformatted and renumbered 6.9.1.4 and 6.9.1.5. In addition, the date by which the annual report on the tabulation of occupational exposures shall be submitted is chanced from March 31 to March 1 of each year. This change is not significant because it merely moves up the reporting date by 30 days. The staff finds that these changes are acceptable.
Existing Specification 6.9.1.d, which requires that an annual radiological operating report be submitted, has been reformatted and renumbered 6.9.1.6 and 6.9.1.7. In addition, the sampling locations are now being keyed to "the site reference point" instead of "from one reactor". This change provides consistency for reporting sampling locations among all three San Onofre units. The staff concludes that these changes are acceptable.
Existing Specification 6.9.1.d, which requires that a radioactive effluent release report be submitted semiannually, has been reformatted and renumbered 6.9.1.8 and 6.9.1.9. The reference to acceptable methods for calculating the dose contribution from liquid and gaseous effluents is changed from Regulatory Guide 1.109, Rev. 1, to the Offsite Dose Calculational Manual (ODCM). The ODCM has previously been accepted by the staff; therefore, the staff concludes that this change is acceptable.
The licensee originally proposed changing the dates for submitting the semiannual radioactive effluent release report from 60 days to 90 days after January 1 and July 1 of each year. The staff pointed out to the licensee.that 10 CFR 50.36a(a)(2) requires-that this report be submitted within 60 days of January 1 and July 1 of each year. Accordingly, by letter dated July 1, 1985, the licensee withdrew this proposed change.
As discussed in Section 2.44 of this SE, changes to the ODCM and licensee initiated major changes to radioactive waste treatment systems will be reported in the semiannual radioactive release report. For consistency, at the suggestion of the licensee, we incorporated reference to this reporting requirement in the last sentence of Specification 6.9.1.9. This change is not significant because it is only a cross reference to the reporting requirements contained in revised Sections 6.14 and 6.15 of the specifications. The staff concludes that this chance is acceptable.
Existing Specification 6.9.1.c has been renumbered 6.9.1.10. The licensee has added a statement that documentation of all challenges to pressurizer safety and relief valves shall be submitted in the monthly operating report.
This addition meets the guidance of Item II.K.3.3 of Generic Letter No. 82-16 (NUREG-0737 Technical Specifications), dated September 20, 1982. The staff concludes that this change is acceptable.
14 In the April 12, 1985 submittal, the licensee proposed that any changes to the ODCM and any major changes to the radioactive waste treatment system be reported in the monthly operating report rather than in the seniarrua radioactive effluent release report. As discussed in Section 2.44 of this SE, these changes will continue to be reported in the semiannual radioactivity release report; hence, the proposed paragraph relating to the reporting of these changes in the monthly operating report has been deleted.
2.41-Specification 6.9.2 Existing Specification 6.9.2, Reportable Occurrences, is deleted in accordance with Generic Letter 83-43, "Reportino Requirements of 10 CFR Part 50, Sections 50.72 and 50.73, and Standard Technical Specificaions",
(December 19, 1983).
As discussed in Section 2.34 of this SE, Specification 6.6 has been added to incorporate administrative actions in response to Reportable Events. The staff concludes that this change is acceptable.
Existing Specification 6.3, Unique Reporting Requirements, has been revised to be consistent with the Standard Technical Specifications and renumbered 6.9.2. This revised section, "Special Reports", states that special reports shall be submitted to the NPC Regional Administrator within the time period specified for each report. This section is referenced by various Specifications in Sections 3 and 4, as discussed below. In addition, the reporting recuirement for leak tests performed on sealed sources has been incorporated into Specification 4.12 as discussed below. The staff concludes that this change is acceptable.
2.42 Specification 6.10 Existing Specification 6.10, Record Retention, has been revised as follows.
The term "facility" has been replaced by "unit" to reflect the licensee's latest terminology. The term "reportable occurrences" has been modified to "reportable events" in accordance with Generic Letter 83-43. These are editorial changes and the staff finds that they are acceptable.
Existing Specification 6.10.1.e, which concerns records of reactor tests and experiments, has been renumbered 6.10.2.f. These records are to be retained
'or the duration of the operating license rather than for at least five years as stated in the existing specifications. Similarly, existing Specification 6.10.3.b, which concerns records of training of facility personnel, has been revised to include the records of qualification for current members of the unit staff and has been renumbered 6.10.2.g. These records are also to be retained for the duration of the operating license rather than for two years.
Specification 6.10.?.m, which concerns retaining records of secondary water sampling and water quality, has been added to the TS. The above three changes conform with the Westinghouse STS (NUREG-0452, Rev. 4); therefore, the staff concludes that these proposed chances are acceptable.
The licensee has requested that existing Specification 6.10.2.j. be deleted.
This specification concerns records for environmental qualification covered under the provisions of paragraph 6.12 o' the TS. As discussed in Section 2.43 of this SE, 10 CFP 50.49 supersedes section 6.12; therefore, the staff concludes that the deletion of this specification is acceptable.
Existing Specification 6.10.2.g, which concerns records of quality assurance activities, has been revised to exclude those quality assurance activities that are covered in Specification 6.10.1. This is an editorial change that recognizes that one or more items listed in 6.10.1 are also required by the OA Manual.
The staff finds that this change is acceptable.
The licensee has requested that existing Specification 6.10.3.a be deleted.
This specification concerns records of facility radiation and contamination surveys. The requirements to maintain records of surveys and monitoring is also specified in Section 20.401(c)(2) of 10 CFP Part 20. Because the licensee must maintain these records to meet the requirements of 10 CFR Part 20, the staff concludes that the deletion of existing Specification 6.10.3.a is acceptable.
Because existing Specification 6.10.3.a is to be deleted and 6.10.3.b is to be renumbered 6.10.2.g, there are no longer to be any specifications in Section 6.10.3; therefore, the staff concludes that it is acceptable to delete Section 6.10.3.
The specifications in Sections 6.10.1 and 6.10.? have been renumbered to take into consideration the above chanoes. These are editorial changes and the staff'finds that they are acceptable.
2.43 Specification 6.12 The licensee has reovested that existing Specification 6.12, Environmental Qualifications, be deleted. Section 50.49 of 10 CFR Part 50, "Environmental qualification of electric equipment important to safety for nuclear power plants," has superseded the provisions of existing Section 6.12. The licensee is required to meet the provisions of this rule with regard to environmental qualification of electric equipment important to safety. The staff concludes, therefore, that deletion of the existing, obsolete Specification 6.12 is acceptable.
Existing Specification 6.11.1 and 6.11.2 have been renumbered 6.12.1 and 6.12.2, respectively. This is an editorial change; therefore, the staff finds the change acceptable.
2.44 Specifications 6.13, 6.14, and 6.15 Existing Specifications 6.16, 6.17, and 6.18, which establish requirements for the Process Control Program (PCP), the Offsite Dose Calculational Manual (ODCM),
and major changes to radioactive waste treatment systems, have been renumbered
16 6.13, 6.14, and 6.15. The reference to the specification that provides for review and approval of chances to these specifications has been changed to 6.5.2.9 to reflect the renumbering of sections. These changes are editorial and, therefore, the staff finds that they are acceptable.
The existing Specifications 6.13, 6.14, and 6.15 all reouire that changes be reported in the semiannual radioactive effluent release report. The licensee's April 12, 1985 submittal requested that the reporting requirements be modified so that the changes required to be reported regarding the ODCM and the radioactive waste treatment systems would be included in the monthly operating report rather than in the semiannual radioactive release report; the reporting requirements for changes to the PCP would be unchanged; hence, they would be reported in the semiannual radioactive effluent release report. Based on discussions with the staff, by letters dated July I and July 31, 1985, the licensee withdrew the proposed changes with regard to the ODCM and major changes to the radioactive waste treatment systems. Therefore, any changes in these areas will continue to be reported in the semiannual radioactive effluent release report.
2.45 Specification 6.16 Existing Specification 6.19 has been renumbered 6.16. The reference in Specification 6.16.2 regarding submitting reports to the NRC is changed to Specification 6.9.? to be consistent with the changes made in renumbering the specifications. This is an editorial change and, therefore, the staff finds that it.is acceptable.
2.46 Other Editorial Changes The licensee has proposed to modify the references to reporting requirements in existing Specifications 3.15.2, 3.15.3, 3.16.2, 3.16.3, 3.16.4, 3.17, 3.18.1, 3.18.2, 4.16, 6.16.2, and in Table 3.5.10-1. In addition, the licensee has proposed adding references to reporting requirement Specification 6.9.2 in existing Specifications 3.1.1, 3.1.4 and 4.8, references to reporting requirement 6.6 in existing Specifications.3.1.1 and 4.2.3.1.c, and a reference to reporting requirement 6.9.1.4 in existing Specification 4.12. These editorial changes are necessary because of the renumbering of the applicable reporting requirements in Section 6, Administrative Controls, and to cross-reference the appropriate reporting section. The staff concludes that these editorial changes are acceptable.
3.0 ENVIRONMENTAL ASSESSMENT This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(r)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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4.0 CONCLUSION
The 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, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ACKNOWLEDGEMENT This Safety Evaluation has been prepared by M. Schoppman and W. Paulson.
Dated: October 15, 1985