ML17229A510
| ML17229A510 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/31/1997 |
| From: | Stall J FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| L-97-271, TAC-M97209, TAC-M97210, NUDOCS 9711070107 | |
| Download: ML17229A510 (15) | |
Text
CATEGORY 1 REGULATO INFORMATION DISTRIBUTION +TEM (RIDE) t ACCESSION NBR:9711070107 DOC.DATE: 97/10/31 NOTARIZED: YES DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 50;389 St. Lucie Plant., Unit 2, Florida Power & Light Co. 05000389 AUTH. NAME AUTHOR AFFILIATION STALL,J.A. Florida Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to 971001 RAI re proposed license amend, providing for more efficient use of on-site mgt personnel in review &
approval process for plant procedures.
DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR I ENCL I SIZE:
TITLE: OR, Submittal: General Distribution-NOTES: E RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-3 LA 1 1 PD2-3 PD 1 1 NIENS,L. 1 1 INTERNAL: ACRS 1 1 1 1 NRR/DE/ECGB/A 1 1 NRR DE 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS3, 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 D
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Florida Power 5 Light Company, 6351 S. Ocean Drive, Jensen Beach, FL 34957 October 31, 1997 L-97-271 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re: St. Lucie Unit 1 and Unit 2 Docket Nos. 50-335 and 50-389 Proposed License Amendments: Onsite Facility Review Group (TAC Nos. M97209/M97210), Request for Additional Information Ref: (1) FPL Letter L-96-256, J.A. Stall to NRC (DCD): Proposed License Amendment, Onsite Facility Review Group; October 31, 1996.
(2) NRC Letter, L.A. Wiens to Thomas F. Plunkett (FPL): REQUEST FOR ADDITIONAL INFORMATION (TAC NO. M97209); October 1, 1997.
Reference 1 is an application for license amendment from Florida Power and Light Company (FPL) which will provide for more efficient use of on-site management personnel in the review and approval process for plant procedures. Specifically, changes were proposed for Technical Specifications (TS) 6.5.1, Facility Review Group (FRG), and 6.8, Procedures and Programs. Reference 2 forwarded a request for additional information (RAI) and clarification of certain items contained in Reference
- 1. The questions (shown in italics) and FPL's responses are contained in the Attachment to this letter.
Please contact us if there are any questions about this submittal.
Very truly yours, J.A. Stall Vice President St. Lucie Plant JAS/RLD Attachment cc: Regional Administrator, Region II, USNRC.
Senior Resident Inspector, USNRC, St. Lucie Plant.
Mr. W.A. Passetti, Florida Department of Health and Rehabilitative Services.
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St.,Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Page 2 Proposed License Amendments: Onsite Facility Review Group (TAC Nos. M97209/M97210), Request for Additional Information STATE OF FLORIDA )
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COUNTY OF ST. LUCIE )
J. A. Stall being first duly sworn, deposes and says:
That he is Vice President, St. Lucie Plant, for the Nuclear Division of Florida Power 8 Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information and belief, and that he is authorized to execute the document on behalf of said Licensee.
J. A. Stall STATE OF FLORIDA COUNTY OF <+ LO ~i Sworn to and subscribed before me this ~G dsy of 'Ittl&C(,19'rT by J. A. Stall, who is personally known to me.
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St., Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 1 of 7 (TAC Nos. M97209/M97210), Request for Additional Information
'Ihe evaluation for the proposed changes to the technical specijications I7Z) indicates that the changes are similar to those approved for other utilities. Identify the other utilities and provide a comparison ofthe proposed TS changes with those approved for the other utilities.
The fact that TS changes have been approved for other utilities similar to those proposed by FPL (Reference 1) has been previously discussed during a telecon between FPL (Weinkam, et al.) and NRR (Wiens, et al.) on 29 May, 1997. Taking into account plant specific differences in terminology and TS format, some of the proposed changes were constructed using the corresponding TS approved for North Anna Unit 1 (NA-1) as a model. A comparison of the applicable specifications follows:
6.5.1.6.a: The proposed requirement for the on-site Facility Review Group (FRG) to review only "new procedures required by Specification 6.8 and all procedure changes that require a wntten safety evaluation," will make the requirements of this specification the same as NA-1 TS 6.5.1.6.a (Page 6-6, Amendment 191).
6.5.1.7.a: The proposed authority for the FRG to "provide approval or disapproval ... as certified in writing by the FRG Chairman or his designated alternate" is equivalent to the authority vested in the Station Nuclear Safety and Operating Committee (SNSOC) and an Assistant Station Manager (the Assistant Station Managers serve as SNSOC Chairman and Vice Chairman) by NA-1 TS 6.5.1.7.a (Page 6-7, Amendment 140).
6.8.2: The revision proposed for this TS relocates the control for ~chan es to procedures listed in TS 6.8.1, except those for fire protection, to proposed TS 6.8.3; provides for FRG review and approval of new procedures only; and preserves the existing requirement for fire protection program procedures and changes thereto to be reviewed by FRG and approved by the PGM. The proposed revision will make this specification equivalent to NA-1 TS 6.8.2 (Page 6-13, Amendment 191).
6.8.3.a: The proposed TS 6.8.3.a requires that: (1) all procedure revisions be independently reviewed by an individual or group from the appropriate discipline(s); (2) all procedure changes that require a written safety evaluation be reviewed and approved by the FRG consistent with proposed TS 6.5.1.7.a; (3) changes to fire protection program procedures be reviewed by the FRG and approved by the PGM consistent with proposed TS 6.8.2, and (4) other procedure changes shall be approved by the PGM or personnel at the appropriate management level as designated in writing by the PGM. In comparison, the analogous NA-1 TS 6.8.3 requires (1) procedure changes that require a safety evaluation to be reviewed and approved by the SNSOC, and (2) all other changes to be independently reviewed and approved as programmatically discussed in the Updated Final Safety Analysis Report (Page 6-13, Amendment 191).
6.8.3.b: The proposed TS 6.8.3.b deletes the requirement for the FRG to review and the PGM to approve temporary changes to procedures within 14 days of implementation, and requires the post-implementation review/approval of such changes to be processed as all other procedure changes consistent with proposed TS 6.8.3.a. In comparison, the corresponding NA-1 specification for temporary procedures was deleted in its entirety
St.,Lucie Vnit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 2 of 7 (TAC Nos. M97209/M97210), Request for Additional Information (Amendment 191). The staff's safety evaluation related to NA-1 Amendment 191 found this change acceptable since processing the temporary changes as all other procedures and procedure changes "does not diminish the level of review and approval."
An independent assessment ofthe effectiveness ofthe onsite review committee is referenced as a basis for the TS changes. Please provide a copy ofthis assessment.
As stated in Reference 1, "...the requirement for FRG review and PGM approval of procedure changes that do not affect nuclear safety was identified in an independent quality assurance (QA) assessment of FRG efficiency as an item that should be considered for improvement.
This assessment included bench marking St. Lucie FRG practices against similar groups at other nuclear utilities." The assessment was conducted by the QA department in late 1995 (Inter-Office Correspondence JQQ-95-205, St. Lucie Facility Review Group Assessment, W.
Bladow to J. Scarola: December 18, 1995), and was performed in response to an observation previously made by a review team that had been formed earlier as part of the St. Lucie Plan to Improve Operational Performance, i.e., "The volume of Facility Review Group (FRG) material is burdensome and could detract from critical reviews."
The QA review included: (1) a study of TS and administrative procedures applicable to the conduct of on-site review committees at FPL's Turkey Point plant, Entergy Operation's Arkansas Nuclear (ANO) plant, and Virginia Power's Surty plant for comparison to St. Lucie plant requirements; (2) a visit to the Suriy plant during which a SNSOC meeting was observed; and (3) input and recommendations from the Plant Safety Committee Chairman at another utility who visited St. Lucie and attended several FRG meetings. The report of this review contained several recommendations, but relative to Reference 1, it was recommended that a request for license amendment be prepared which revises FRG review requirements such that changes that,do not have the potential for affecting nuclear safety need not be reviewed by the FRG, and'that the authority for approval of changes to procedures be changed from the PGM to the appropriate Department Head.
The QA assessment simply identified the need for a change in TS requirements that would accommodate improvements in the efficiency of the procedure review and approval process, and confirmed that such changes had been authorized for several licensees. As such, the review did not provide the technical basis for any specific TS change requested in Reference 1, and the staff agreed that a copy of the assessment would not be needed to continue their review of the proposed license amendment (telecon between NRR (Wiens, et al.) and FPL (Weinkam, et al.) on October 15, 1997).
St. Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 3 of 7 (TAC Nos. M97209/M97210), Request for Additional Information The evaluation notes that the proposed changes remain consistent with industry standards. Industry standards other than ANSI N18.7-1976/ANS-3.2, which is mentioned in the evaluation, should be identified ifapplicable. For example, ANSI/ANS 3. 1-1978 is applicable and it is referenced as a basis for the quality assurance (QA) program. Regulatory Guide (RG) 1.33, Revision 2, conditionally endorses ANSIN18.7-1976/ANS-3.2, and should be also addressed by the evaluation.
Appendix C of FPL's Topical Quality Assurance Report (TQAR) describes the documents that provide the basis for FPL's QA Program. ANSI N18.7-1976/ANS-3.2, as conditionally endorsed or otherwise modified by the regulatory positions stated in Part C of RG 1.33, Revision 2, is applicable to the changes proposed in Reference 1 for TS 6.5.1.6, 6.5.1.7, 6.8.2, and 6.8.3.
These changes meet or exceed requirements and recommendations provided in section 4.4, "Review Activities of the Onsite Operating Organization," section 5.2.2, "Procedure Adherence" as it applies to temporaiy changes to approved procedures, section 5.2.15, "Review, Approval, and Control of Procedures," and section 5.3, "Preparation of Instructions and Procedures," of the referenced standard.
ANSI/ANS 3.1-1978, "Standard for Selection and Training of Personnel for Nuclear Power Plants," addresses qualiTications, responsibilities, and training of personnel and is predicated on levels of responsibility rather than on a particular organizational concept. This standard also provides, in part, the basis for FPL's QA Program at St. Lucie and is included by reference in TS 6.3 for both St. Lucie plants, e.g., "Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS-3.1-1978, except for (1) the Health Physics Supervisor
..., and (2) the Shift Technical Advisor ... " Relative to the changes proposed in Reference 1, the PGM will be provided the flexibility to designate/authorize personnel at the appropriate management level to approve certain procedure changes pursuant to proposed TS 6.8.3.a.
Such personnel would typically have qualifications that meet or exceed those described for Managers in section 4.2 of ANSI/ANS 3.1-1978.
The evaluation notes that t/ie proposed revision ofTS 6.5.1 is compatible with existing document control measures piirsuant to the g4 program. The applicable sections oft/ie QA program description should be identified.
Applicable sections of the QA Program include: (a) Section 5.0, "Instructions, Procedures, and Drawings," and Section 6.0, "Document Control," of the FPL TQAR; (b) Section 5.2.15, "Review, Approval and Control of Procedures," of ANSI N18.7-1976/ANS-3.2; and (c) as described in the evaluation of proposed TS 6.5.1.6.a(1) contained in Reference 1, the quality instructions and administrative procedures that control the review and approval of procedures at the St. Lucie plant.
The onsite review committee currently reviews all procedures identified per TS 6.8 and changes thereto.
The submittal proposes that only procedures requiring safety evaluations be reviewed by the committee.
St.,Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 4 of 7 (TAC Nos. M97209/M97210), Request for Additional Information Confirm that reference to "safety evahiations" means conformance to the requirements of/50.59 ofTitle 10 ofthe Code ofFederal Regulations.
As described in the evaluation of proposed TS 6.5.1.6.a(1) contained in Reference 1, each proposed change to plant procedures, including any temporary change, is "evaluated by an individual trained in the screening process that is used to determine if an activity requires a written safety evaluation pursuant to 10 CFR 50.59." If a safety evaluation is required (in conformance to the requirements of f50.59 of Title 10 of the Code of Federal Regulations), then further review by the FRG will be performed.
- b. Address how each ofthe procedures identified per TS 6.8 is covered by $ 50.59.
10 CFR 50.59 provides, in part, for a licensee to make changes in the procedures as described in the safety analysis report, without prior Commission approval, unless the proposed change involves a change in the technical specifications incorporated in the license or an unreviewed safety question. Further, the licensee shall maintain records of changes in procedures made pursuant to f50.59 to the extent that they constitute changes in procedures as described in the safety analysis report, and these records must include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Provide additionaljiistification why the onsite review committee does not have to review procedures with respect to whether safety evaluations are necessary.
Each proposed change to facility procedures is required by St. Lucie Plant Quality Instruction (QI) 5-PSL-1 and Administrative Procedure ADM-17.11 to be screened for the purpose of determining if a 10 CFR 50.59 safety evaluation or a 10 CFR 50.90 license amendment is required prior to implementation of such change. The screening methodology, including definitions, screening criteria, and conservative guidance is provided in the ADM. The screening analysis and basis for concluding that a safety evaluation is or is not required are documented, reviewed by cognizant management as part of the procedure change request (PCR) process, and maintained as a QA record.
Only those individuals who have completed requisite training and have been designated in writing as a "Qualified Reviewer" are authorized to perform the 10 CFR 50.59 screening activity. The Site Engineering Manager is assigned the responsibility to ensure that the 50.59 screening program, implementing procedure, and policies are consistent with the latest industry and NRC screening requirements.
- d. Is a Qualified Reviewer program used to perform tt'50.59 reviews? Ifso, please describe the program requirements.
As discussed above, a Qualified Reviewer concept is used at the St. Lucie plant to ensure that 10 CFR 50.59 screening reviews are properly performed. Personnel currently selected for consideration as a Qualified Reviewer are provided classroom training and must demonstrate acceptable knowledge of the screening process. The Site Engineering Manager is responsible to ensure that individuals assigned these
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St.,Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 5 of 7 (TAC Nos. M97209/M97210), Request for Additional Information screening responsibilities have successfully completed the required training and are adequately qualified prior to adding their names to the Qualified Reviewers List. The Training Department maintains the master copy of this list and is responsible to ensure that the list and all revisions thereto are distributed.
The submittal proposes to implement an independent review fiinction to replace the review function providedby the onsite review coinmittee. The administrative requirements for theindependent review fimction should be specified by tlie technical specifications andlor QA program description.
Except for fire protection program implementing procedures, the TS revisions proposed in Reference 1 will eliminate (not replace) the FRG review of changes to procedures that do not require a written safety evaluation pursuant to 10 CFR 50.59, unless FRG review of such changes is otherwise required by the PGM pursuant to TS 6.5.1.6.a(3).
Proposed TS 6.8.3.a requires each procedure revision to be "independently reviewed" by an individual or group from the appropriate discipline(s). This review corresponds to document control measures required in section 5.2.15 of ANSI N18.7-1976/ANS-3.2, i.e., "These measures shall assure that documents, including revisions or changes, are reviewed for adequacy by appropriately qualified personnel ...," and, "Rules shall be established which clearly delineate the review of procedures by knowledgeable personnel other than the originator
. ." This independent review is required to ensure technical accuracy and occurs earlier in the
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PCR process than the presently required FRG review.
Quality Instructions governing the PCR process at the St. Lucie site currently require the subject independent review, referred to as a subcommittee review, and each department affected by the proposed procedure revision is provided the opportunity to "subcommittee" the change. Each review is documented and resolution of all comments is further reviewed by cognizant management, and the document(s) is maintained as a QA record. In addition to the subcommittee reviews, a f50.59 screening is performed by a Qualified Reviewer, and changes to Quality Instructions and Administrative Procedures must be reviewed for concurrence by the Quality Assurance Department as required by TQAR Section 5.2.
The sribmittal proposes that the onsite review committee approve procedures instead ofthe plant manager. This didefers froni current fimction ofthe review commit tee, which is to advise the plant manager. The plant nranager is responsible for administrative and quality program reqiiirements to assure plant safety; he is uniquely qualifiedfor this responsibili ty by compliance to ANSI/ANS 3.I-1978 requirements. Please provide additionalJustification as to why the reassignment ofthe approvalfunction from the plant manager to the review conuni t tee does not reduce assurance of plant safety, particularly with regard to the qualifications ofthe review committee membership and the responsibility oftlie plant manager.
TS 6.1.1 and 6.2.1.c specifically assign responsibility for overall unit safe operation, and control over those onsite resources necessary for safe operation and maintenance of the plant to the
St.. Lucie Unit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 6 of 7 (TAC Nos. M97209/M97210), Request for Additional Information Plant General Manager. The revisions proposed in Reference 1 do not alter or otherwise diminish these responsibilities and control of resources. The proposed TS changes will shift approval authority for certain items from the PGM to the FRG. However, this does not alter the function prescribed by Specification 6.5.1.1, i.e., the FRG will continue to " ... function to advise the Plant General Manager on all matters related to nuclear safety." The change proposed for TS 6.5.1.8 provides additional assurance that the PGM remains aware of all FRG activities, and existing TS 6.5.1.7.c clearly establishes the line of authority for resolution of any potential disagreement between the FRG and PGM.
The FRG Chairman, as well as the FRG members, are selected by and serve at the pleasure of the PGM. The minimum qualifications of the FRG are specified in TS 6.5.1.2, but the selection of specific members and the chairman is a function of the judgement exercised by the PGM. In general, the qualifications of the FRG chairman are well in excess of those specified for Managers in Section 4.2 of ANSI/ANS-3.1-1978.
Reassignment of the approval function for certain items to the FRG in conjunction with the flexibility to designate, as he/she deems appropriate, qualified personnel to approve certain procedure changes pursuant to proposed TS 6.8.3.a will relieve the PGM of a significant administrative burden that otherwise impacts the ability to focus on day-to-day safe power plant operations.
The submittal proposes to delete the current requirement for temporary procedure changes to be reviewed by Ihe onsite review conmiittee and approved by the plant manager within 14 days of implementation. Additionalj ustification should be provided for deleting this requirement, particularly with regard to the time constraint. PZ 6.8.3)
The post-implementation review/approval of temporary changes will be processed as all other procedure changes. The proposed TS 6.8.3.b is consistent with ANSI N18.7-1976/ANS-3.2, section 5.2.2, i.e., "Temporary changes which clearly do not change the intent of the approved procedure, shall as a minimum be approved by two members of the plant staff knowledgeable in the areas affected by the procedures. At least one of these individuals shall be the supervisor in charge of the shift and hold a senior operators license on the unit affected. Such changes shall be documented and, if appropriate, incorporated in the next revision of the affected procedure." The ANSI. standard does not impose a time constraint, and FPL has been unable to determine any reasonable basis for the existing 14-day requirement. Additional discussion of this issue is in RAI response 1, preceding.
At the St. Lucie plant, implementation of temporary changes (TC) to procedures is controlled by wntten instructions. These instructions (Ql and ADIVI) require review of and concurrence by the QA Department pursuant to Section 5.2 of FPL's TQAR. Specific guidance is provided to ensure that a proposed TC does not involve a change of intent of the affected procedure, and the proposed TC is required to be screened against 10 CFR 50.59 requirements by a Qualified Reviewer. If a TC is for "one time only" use, both the plant conditions and date of expiration must be specified. Other TCs expire when incorporated in the next revision of the affected procedure or within 90 days of the implementation date. The required reviews and approvals,
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St., Lucie Vnit 1 and Unit 2 L-97-271 Docket Nos. 50-335 and 50-389 Attachment Proposed License Amendments: Onsite Facility Review Group Page 7 of 7 (TAC Nos. M97209/M97210), Request for Additional Information including a change of intent evaluation and the 10 CFR 50.59 screening conclusion, are documented and maintained as a QA record.
The evaluaiion states that the Shift Supervisor approves temporary changes. TS 6.8.3 should be revised to ref?ect this requirement.
The Nuclear Plant Supervisor (NPS) is the senior licensed shift supervisor for the dual-unit St.
Lucie site, and an Assistant Nuclear Plant Supervisor (ANPS) is the licensed senior operator in charge of the shift at each specific unit. The NPS and the ANPS are both qualified to approve TCs at a specific unit. FPL believes that the existing specification requiring TCs to be " ...
approved by two members of the plant management staff, at least one of whom holds a Senior Operator's license on the unit affected" to be an adequate administrative control.
10 The submittal should address the general qualification requirements for personnel authorized to approve procedure changes. In addition, the qualifications ofthe individual designated by the plant manager to approve procedures should be specifically addressed. PZ 6.8.3)
Proposed TS 6.8.3.a states that, "Personnel authorized to approve procedure changes pursuant to this specification shall be at a management level appropriate for the activities affected by the procedure being revised." The proposed TS does not require the PGM to delegate the subject approval authority,'but provides the flexibility to do so as he/she deems appropriate. As recognized in RAI-7 preceding, the PGM is uniquely qualified for the responsibility for administrative and quality program requirements to assure plant safety. Therefore, FPL believes the PGM should be able to exercise his/her judgement, based on the type of procedures being changed, to select the proper designee. In general, the designee(s) would typically have qualifications that meet or exceed those described for Managers in Section 4.2 of ANSI/ANS-3.1-1978.
The submittal proposes to retain the requirement for the plant manager to approve temporary changes to fire protection program implementation procedures. Address the reasons for the uniqueness ofthe approval process forfire protection procedures. PZ 6.8.2)
FPL is not aware of any uniqueness associated with the review and approval process for fire protection procedures. The existing TS requirement for FRG review and PGM approval of such procedures and changes thereto is consistent with the TS used as a model for the changes requested in Reference 1 (see RAI response No. 1) as well as the TS for FPL's Turkey Point plants. Although no longer included in TS 6.5.1.6 and 6.8.1, it should be noted that both the Emergency and Security Plans also require FRG review and PGM approval of implementing procedures and changes thereto.