ML16138A796
| ML16138A796 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 12/01/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML16138A795 | List: |
| References | |
| NUDOCS 9512070166 | |
| Download: ML16138A796 (3) | |
Text
ptREG&4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.211 TO FACILITY OPERATING LICENSE DPR-38 AMENDMENT NO. 211 TO FACILITY OPERATING LICENSE DPR-47 AND AMENDMENT NO.208 TO FACILITY OPERATING LICENSE DPR-55 DUKE POWER COMPANY OCONEE NUCLEAR STATION. UNITS 1. 2. AND 3 DOCKET NOS. 50-269, 50-270, AND 50-287
1.0 INTRODUCTION
By letter dated January 12, 1995, as supplemented by letter dated June 29, 1995, Duke Power Company (the licensee), submitted a request for changes to.
the Oconee Nuclear Station, Units 1, 2, and 3, Technical Specifications (TS).
The requested changes would revise and clarify portions of TS Section 6.0, "Administrative Controls."
The June 29, 1995, letter provided clarifying information that did not change the scope-of the January 12, 1995, application and initial proposed no significant hazards consideration determination.
2.0 EVALUATION Some of the licensee's requested changes would relocate the requirements for the review functions from the Administrative Controls section of the TS to the respective licensee-controlled documents.
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TS as part of the license.
The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission has provided guidance for the contents of TS in its "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" ("Final Policy Statement"), 58 FR 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies §182a of the Act. In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co.
9512070166 951201 PDR ADOCK 05000269 PDR
-2 (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated 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."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether particular limiting conditions for operation are required to be included in the TS, as follows: (1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (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; (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; (4) a structure, system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. The Commission recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate these criteria. See Final Rule, "Technical Specifications," 60 FR 36953 (July 19, 1995).
The Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS.
The Commission's policy statement provides that many'of the existing TS limiting conditions for operation which do not satisfy these four specified criteria may be relocated to the Updated Safety Analysis Report (USAR), such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Other requirements may be relocated to more appropriate documents (e.g. Security Plan, Quality Assurance (QA) plan, and Emergency Plan) and controlled by the applicable regulatory requirement. While the content of the TS administrative controls is specified in 10 CFR 50.36(c)(5),
particular details of the administrative controls may be relocated to licensee-controlled documents where §50.59 or comparable regulatory controls exist.
Administrative controls in existing TS related to the review functions should be relocated to a licensee-controlled document that provides adequate control over changes to these provisions and which provides an appropriate change control mechanism. As such, these review provisions should be relocated to the Quality Assurance Program described or referenced in the facility's USAR and controlled pursuant to 10 CFR 50.54.
The licensee proposed to relocate some TS administrative control provisions to the Duke Power Company Quality Assurance Program Topical Report, Amendment 20.
These particular TS provisions are not necessary to assure safe operation of the facility, given that the requirements in the QA program implement the Commission's regulations pertaining to these aspects as set forth below. As documented in the Final Policy Statement, these aspects constitute
-3 requirements that can be relocated to the Quality Assurance plan and controlled by the applicable regulatory requirement. Such an approach would result in an equivalent level of regulatory authority while providing for a more appropriate change control process.
On this basis, the staff concludes that the relocated provisions are not required to be in the TS under 10 CFR 50.36 or §182a of the Act, and 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. In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.54 to adequately control future modifications to these provisions. Accordingly, the staff has concluded that these requirements may be relocated from the TS to the respective licensee-controlled documents.
Specific Change Evaluations
- 1. Section 6.1.2 - Technical Review and Control With respect to the review and approval of subjects within Section 6.1.2, Duke proposes to delete the titles of individuals where specified. The titles are to be replaced by a general statement that "Approvals shall be by the head of the appropriate site organization, the head of the appropriate station organization, the head of the appropriate site engineering organization, the head of the environmental organization, or an alternate as specified in other applicable regulatory documents or administrative controls." The Duke Power Quality Assurance Program Topical Report, Amendment 20 (QAP) provides amplifying details on the station organizational structure. QAP section 17.3.2.2 defines the final approval authority for station modifications. Section 17.3.2.14 of the QAP defines the approval authority for changes to station Technical Specifications and for station procedures. Future changes to the QAP are under the control of 10 CFR 50.54(a). Duke stated that there will be no decrease in the level of quality given to the review and approval activities. Further, personnel performing the reviews will continue to meet the same qualification requirements of ANSI N18.1-1971. The staff finds the use of generic titles in the TS acceptable as the QAP contains sufficient controls to ensure that the reviews are performed by equally qualified personnel.
Duke Power proposes to delete the requirement that the Manager, Safety Assurance shall assure that reports of Reportable Events are developed and transmitted to the Site Vice President, or designee, who approves such reports, and to the Director of the Nuclear Safety Review Board.
The requirement was replaced with a statement that "such reports shall be reviewed by a knowledgeable individual/organization other than the individual/organization which prepared the report."
The staff finds this change acceptable as we do not require that this subject be included in the TS.
Duke Power proposes to revise the statement that "The Manager, Safety Assurance shall assure the performance..." with a statement "A knowledgeable individual/organization shall review..." and delete