ML14183A306
| ML14183A306 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/31/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML14183A305 | List: |
| References | |
| NUDOCS 9504070013 | |
| Download: ML14183A306 (5) | |
Text
\\P~P REG&j UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 160 TO FACILITY OPERATING LICENSE NO. DPR-23 CAROLINA POWER & LIGHT.COMPANY H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261
1.0 INTRODUCTION
By letter dated July 22, 1994, as supplemented March 6, 1995, Carolina Power &
Light Co. (CP&L) requested changes to the Administrative Controls Section of the Technical Specifications (TS) for the H. B. Robinson Steam Electric Plant, Unit 2 (HBR). These changes supersede the TS changes requested by letter dated September 15, 1993. The following is a brief description and our evaluation of the requested changes.
2.0 EVALUATION
- a.
Section 6.5.1.1 - Review and Audit - Procedures, Tests, and Experiments CP&L proposes to revise in subsection 6.5.1.1.7 the phrase "change to the FSAR" to "change in the facility as described in the UFSAR;" and in subsection 6.51.2.1 change "FSAR" to "UFSAR".
The NRC staff finds these changes acceptable as they are editorial in nature.
- b.
Section 6.5.1.2 - Review and Audit - Modifications CP&L proposes to change the reference in subsections 6.5.1.1.6, 6.5.1.1.7, 6.5.1.2.4, 6.5.1.2.5 and 6.5.1.4.1 from Nuclear Assessment Department (NAD) to Nuclear Assessment Section (NAS).
The NRC staff finds these changes acceptable as they reflect the proposed revised organization.
- c.
Section 6.5.1.6 -
Plant Nuclear Safety Committee (PNSC)
CP&L proposes to:
- 1.
Revise the description of the organizational provisions of the PNSC by deleting reference to members by position title, reformatting the subsections, and redefining the quorum and 9504070013 950331 PDR ADOCK 05000261 P
- __PDR,
-2 alternate requirements. The description of the PNSC membership would specify functional areas. Qualification requirements would specify organizational level and reference to an industry standard.
- 2.
Change the reference in subsection 6.5.1.6.6.b from Manager, Nuclear Assessment Department to Manager,Nuclear Assessment Section; and delete in subsection 6.5.1.6.6.g the requirement for forwarding of reports with respect to unplanned site release of radioactive material and subsequent corrective actions to the Manager, Nuclear Assessment Department.
- 3.
Delete the requirement in subsection 6.5.1.6.7 for notification of the Manager, Nuclear Assessment Department of disagreements between the Plant General Manager and the PNSC. In addition, the title Vice President - Robinson Nuclear Project is changed to Vice President - Robinson Nuclear Plant.
- 4.
Change in subsection 6.5.1.6.8 the distribution of PNSC minutes from the Manager, Nuclear Assessment Department to the Manager, Nuclear Assessment Section.
The NRC staff finds these changes acceptable as they meet the appropriate acceptance criteria of Section 13.4 of NUREG 0800, the Standard Review Plan, and they reflect the proposed revised organization.
- d.
Section 6.5.2 - Nuclear Assessment Section (NAS) Independent Review Program CP&L proposes to delete the Nuclear Assessment Department and replace it with a Nuclear Safety Assessment Independent Review Program. Therefore, this section has been retitled to NAS Independent Review Program and undergone a major rewrite. The numerous changes include:
- 1.
Redefining the preamble and moving it to a new section 6.5.2.1.
- 2.
Deleting the functions of the Manager, Nuclear Assessment Department with respect to approval of individuals conducting safety reviews, access to plant records, and the preparation and retention of records of reviews.
- 3.
Relocating the existing requirements of subsections 6.5.2.1.d.1, 6.5.2.1.d.3, and 6.5.2.1.d.5 to subsections 6.5.2.3.a, 6.5.2.3.c, and 6.5.2.3.e, respectively.
- 4.
Relocating the existing requirement of subsection 6.5.2.1.d.2 to 6.5.2.3.b and changing the phrase "changes in procedures" to "changes in procedures required by these Technical Specifications," moving the phrase "prior to implementation" to the first sentence, and deleting the last sentence.
- 5.
Deleting the existing requirement from subsection 6.5.2.1.d.4 as this requirement is included in the revised subsection 6.5.2.3.d.
- 6.
Deleting the requirement, subsection 6.5.2.1.d.6, that NAD review reports and minutes of the PNSC.
- 7.
Relocating the existing requirements of subsections 6.5.2.1.c and 6.5.2.2.a to subsection 6.5.2.4.a.
- 8.
Deleting the requirements of subsections 6.5.2.2.b and 6.5.2.2.c that require retention of copies of documented reviews in the NAD files'and submittal of recommendations and concerns to the Plant General Manager and Vice President, Robinson Nuclear Project.
- 9.
Relocating the existing requirement of subsection 6.5.2.2.d to subsection 6.5.2.2.7.
- 10.
Relocating the existing requirement of subsection 6.5.2.3.a to subsection 6.5.2.2.1 and modifying the list of disciplines by adding the area of "other appropriate fields."
- 11.
Relocating the existing requirements of subsections 6.5.2.3.b(1) and (2) to subsections 6.5.2.2.2 and 6.5.2.2.3, and changing the term "Bachelor of Science" to "bachelor's degree."
- 12.
Relocating the existing requirements of subsection 6.5.2.3.c and 6.5.2.3.e to subsections 6.5.2.2.4 and 6.5.2.2.6.
- 13.
Relocating the existing requirement of subsection 6.5.2.3.d to subsection 6.5.2.2.5 and redefining the requirement that atleast three persons shall review each item. The new requirement states that documents shall be reviewed by individuals meeting the appropriate qualifications, including multiple reviews where required to meet the applicable disciplines.
It should be noted that the NAS function will report to the Site Vice President rather than to the offsite position of Executive Vice President, Nuclear Generation.
The NRC staff finds these changes acceptable as they conform to ANSI N18.7 1976; have been previously approved for another CP&L plant; are required by other existing HBR TS; are included in the Quality Assurance (QA) program; incorporate the currently required functions; are editorial in nature; and reflect the.proposed revised organization. In addition, with respect to the new NAS reporting relationship, the NRC staff considers that the acceptability of this arrangement is, in part, based on the effectiveness of the Nuclear Services Department Performance Evaluation Section (PES) that provides an offsite check and balance to the onsite assessment function. The licensee provided a detailed description of the PES assessment activities with respect to the NAS in its March 6, 1995, letter. The NRC staff finds this description acceptable. The PES is described in Section 17.3.3.2 of the proposed revised Quality Assurance Program.
-4
- e.
Section 6.5.3 -
NAS Assessment Program CP&L proposes to retitle this section from the current title of Nuclear Assessment Department Audit Program to Nuclear Assessment Program. This changes the reporting of this function to the onsite Vice President Nuclear. The change deletes the specific audit frequencies and establishes a maximum frequency of 24 months. The change also alters the function from an audit-based to a performance-based assessment program. The change also deletes the specific details with respect to audit personnel that are addressed in the QA Program.
The NRC staff finds these changes acceptable as'they meet the acceptance criteria of Sections 13.4 and 17.3 of NUREG 0800, the Standard Review Plan, conform to the Improved Standard Technical Specifications, or are included in other existing HBR TS. With respect to the organizational arrangement see item d. above.
- f.
Sections 6.6 and 6.7 -Reportable Events and Safety Limit Violations The proposed revision of subsections 6.6.1.b, 6.6.2.b, 6,7.1 c and 6.7.1.e deletes the reference to the Manager, Nuclear Assessment Department and replaces it with reference to the position of Manager, Nuclear Assessment Section, changes the words "Robinson Nuclear Project" to "Robinson Nuclear Plant," and deletes the requirement for the Manager, Nuclear Assessment Department to receive a 24-hour notification of Safety Limit Violations.
The NRC staff finds these changes acceptable as they reflect the propoied revised organization.
- g.
Section 6.10.2.k - Records CP&L proposes to delete the recordkeeping for independent reviews performed by the previous Corporate Nuclear Safety (CNS) System, and to relocate the requirement to retain records of independent reviews performed by the Nuclear Assessment Department to a new Subsection m.
Records of the previous CNS reviews will be maintained by the NAS.
The NRC staff finds these changes acceptable as they will provide for the retention of NAD assessment activities, and require retention of NAS assessments.
3.0
SUMMARY
The NRC staff has found the changes requested by CP&L letter dated July 22, 1994, to the Administrative Controls Section of the TS for HBR acceptable, as they meet the appropriate acceptance criteria of Sections 13.4 and 17.3 of NUREG 0800, the Standard Review Plan, and conform to the improved ISTS.
-5
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of South Carolina official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment changes recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(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.
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 Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: F. Allenspach Date:
March 31, 1995