ML17164A513
| ML17164A513 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/22/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17164A512 | List: |
| References | |
| NUDOCS 9501110154 | |
| Download: ML17164A513 (4) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205554001 SA E
Y EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELAT D TO AMENDM 0.
>>7 TO CI TY OPERATING LICENSE NO. NPF-14 MENDMENT NO. 107 TO FACILITY OPERATING LICENSE NO. NPF-22 PENNSYLVANIA POWER 5 LIGHT COMPANY G
N ELECTRIC COOPERATIVE INC.
SUS UEHANNA STEAM ELECTR C STATION UNITS 1
AND 2 DOCKET NOS.
50-387 AND 388 1.0
~INTNOOOO TON By letter dated April 5, 1994, the Pennsylvania Power and Light Company (the-.=
licensee) submitted a request for changes to the Susquehanna Steam Electric
- Station, Units 1 and 2, Technical Specifications (TS).
The requested changes would relocate control over changes to the frequency requirements for a number of audits listed under Technical Specification 6.5.2.8 and also remove the audit requirements for the Emergency Plan and the Security Plan since these requirements are adequately controlled by existing regulations.
- 2. 0 EVALUATION
- 2. 1 Deletion of References to Specific Audit Frequencies Pennsylvania Power and Light Company (PPKL) proposes to delete the Susquehanna Review Committee (SRC) audit frequency for subsections a-d and h-n of 6.5.2.8 of the Susquehanna Steam Electric Station Units 1 and 2 TS as follows:
(a) delete "at least once per 12 months" for audits of unit operations compliance with Appendix A Technical Specifications and applicable license conditions, I
(b) delet'e "at least once per 12 months" for audits of performance,
- training, and qualifications of unit staff, (c) delete "at least once per 6 months" for audits of results of actions taken to correct deficiencies occur ring in unit equipment, structures,
- systems, or method of operation that affect nuclear safety, 9501110154 941222 PDR ADOCK 05000387 P
(d) delete "at least once per 24 months" for audits of the performance of activities required by the Operational guality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50, (h) delete "at least once per 24 months" for audits of the Fire Protection Program and implementing procedures, (i) delete "at least once per 12 months" for inspection and audits of an independent fire and loss prevention by either qualified offsite licensee personnel or an outside fire protection firm, (j) delete "at intervals no greater than 36 months" for inspection and audits of the fire protection and loss prevention by an outside qualified fire consultant, (k) delete "at least once per 12 months" for audits of the radiological environmental monitoring program and the results thereof, (1) delete "at least once per 24 months" for audits of the OFFSITE DOSE CALCULATION MANUAL and implementing procedures, (m) delete "at least once per 24 months" for audits of the PROCESS CONTROL PROGRAM and implementing procedures, (n) delete "at least once per 12 months" for audits of the performance of activities required by the guality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977.
The staff is still evaluating the proposed changes to audit frequencies listed in the TS relative to fire protection and loss prevention programs.
Specifically, these are the deletions of audit frequencies from items (h),
(i), and (j) of the current TS, (items (f) (g),
and (h) of the revised TS included in the amendment request).
The frequency deletions are not addressed in this safety evaluation, but will be addressed in a subsequent amendment.
The current amendment only reflects a re-lettering of the three items related to fire protection audits.
The licensee proposes that the review and audit functions specified in the existing technical specifications be relocated to the Final Safety Analysis Report (FSAR) on the basis that changes to the audit frequencies will be adequately controlled under the guality Assurance (gA) program.
Specifically, the licensee has proposed to incorporate these audit frequencies in Section 13.4.3 and Table 17.2-1 of the FSAR, which incorporates these provisions into the gA program by reference.
These TS provisions are not necessary to assure safe operation of the facility because Appendix 8 to Part 50 specifies broader requirements for all review and audit functions, except those associated with the security and emergency plans discussed below.
This approach will result in an equivalent level of control while providing for a more appropriate change control process under 10 CFR 50.54(a).
2.2 Deletion of Emergency Plan and Security Plan Audits PPKL proposes to delete TS 6.5.2.8 Subsection (e) which, identifies audits of the Emergency Plan and implementing procedures at least once per 12 months, and Subsection (f) which identifies audits of the Security Plan and implementing procedures at least once per 12 months.
The licensee proposes to relocate the requirements to establish, implement, and maintain procedures related to the Emergency Plan and Security Plan.
Since the Security Plan requirements are specified in 10 CFR 50.54, 73.40, 73.55, and 73.56 and the Emergency Plan requirements are specified in 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E,Section V, the staff recommended, in Generic Letter 93-07, that these requirements be removed from the technical specifications and relocated to their respective plans.
The staff concludes that the requirements for emergency planning in 10 CFR 50.47, 50.54, 10 CFR Part 50 Appendix E and for security in 10 CFR 50.54 and 73.55, for drills, exercises,
- testing, and maintenance of the program, provide adequate assurance that the objective of the previous TS for a periodic review of the program and changes to the program will be met.
Therefore, duplication of the requirements contained in the regulations would not enhance the level ~
of safety for the facility.
The staff concludes that other regulatory requirements provide sufficient control of these provisions and removing them from TS is acceptable.
The staff has concluded, therefore, that relocation of the audit requirements described above is acceptable because (1) their inclusion in technical specifications is not specifically required by 10 CFR 50.36 or other regulations, (2) these audit requirements are not required to avert an immediate threat to the public health and safety, and (3) changes to these requirements, as described in the applicable program description, will require prior NRC approval in accordance with 550.54(a),
Appendix E to Part 50, 550.54(p),
or 573.56(g),
as applicable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments.
The State
'official had no comments.
4.0 ENVIRONH NTAL CONSIDERATION The amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements.
Accordingly, the amendments meet 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 the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed
- above, that:
(I) 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
C. Poslusny, Jr.
Oate:
December 22, 1994