ML17311B059
| ML17311B059 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/07/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17311B058 | List: |
| References | |
| GL-93-07, GL-93-7, NUDOCS 9507210324 | |
| Download: ML17311B059 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055~1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
95 TO FACILITY OPERATING LICENSE NO. NPF-41 AMENDMENT NO.
83 TO FACILITY OPERATING LICENSE NO. NPF-51 AND'MENDMENT NO.
66 TO F'ACILITY OPERATING LICENSE NO. NPF-74 ARIZONA PUBLIC SERVICE COMPANY ET AL.
PALO VERDE NUCLEAR GENERATING STATION UNIT NOS.
1 2
AND 3 DOCKET NOS.
STN 50-528 STN 50-529 AND STN 50-530
1.0 INTRODUCTION
By letters dated April 6,
- 1995, and June 7,
1995, the Arizona Public Service Company (APS or, the licensee) submitted a request for changes to the Technical Specifications (TSs) for the Palo Verde Nuclear Generating Station, Units 1, 2,
and 3 (Appendix A to Facility Operating License Nos.
NPF-41, NPF-51, and NPF-74, respectively).
The Arizona Public Service Company submitted this request on behalf of i,tself, the Salt River Project Agricultural Improvement and Power District, Southern California Edison
- Company, El Paso Electric
- Company, Public Service Company of New Mexico, Los Angeles Department of Mater and
- Power, and Southern California Public Power Authority.
The proposed changes would implement recommendations contained in Generic Letter (GL) 93-07, "Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans," to TS Section 6.0, "Administrative Controls."
Additionally, changes are made to the Plant Review
- Board, along with personnel title and other, miscellaneous minor changes.
The June 7,
- 1995, supplemental letter provided additional clarifying information and did not change the initial no significant hazards consideration determination published in the Federai
~Re ister on May 23, 1995 (60 FR 27335).
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state technical specifications (TSs) to be included as part of the license.
The Commission's regulatory requirements related to the content of technical specifications 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 TSs.
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The Commission has provided guidance for the contents of TSs in its "Final Policy Statement on Technical Speci'fications 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 Section 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Company (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 a particular matter is 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 that 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. 's a result, existing TS requirements that fall within or satisfy any of the criteria in the final policy statement must be retained in the TSs, while those TS.requirements that do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
3.0 EVALUATION 3'. 1 Relocatin Audit Re uirements j
The licensee proposes to relocate the requirements to establish, implement, and maintain procedures related to the security plan (existing TS 6.5.2.6) and emergency plan (existing TS 6.5.2.7).
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
IThe Coamission recently prosuigated a proposed change to 5 50.36, pursuant to uhich the rule would be amended to codify and incorporate these criteria.
This proposed rule clarified the contents of the Bases in the improved standard technical specifications and'specified (STS) that only limiting conditions for reactor core isolation cooling, isolation condenser, residual heat removal, standby liquid.control, and recirculation psnp trip meet the guidance for inclusion in the TSs under Criterion 4.
In the proposed change to $ 50.36, the 'Comnission s'pecifically requested public caments regarding application of Criterion 4.
Until additional guidance has been developed, Criterion 4 vill not been applied to add TS restrictions other than those indicated above.
See Proposed Rute, "Technical Specifications,"
59 FR 48180 (September 20, T994).
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Section V,
GL 93-07 permitted removing the requirements from the STSs and relocating them to their respective plans.
The requirements in the existing TSs.for the review of the security program and'mplementing procedures, and for the review of the station emergency plan and implementing procedures, will be relocated to the respective plans and are included in the administrative procedures that implement the re'lated regulatory requirements.
Further changes in these review requirements must be made in accordance with 10 CFR '50.54(p) for the security plan and 10 CFR 50.54(q) for the emergency plan.
The staff concludes that the requirements for emergency planning (10 CFR 50.47, 50.54, 10 CFR Part 50 Appendix E) and for security planning (10 CFR 50.54 and 73.55), for drills, exercises,
- testing, and maintenance of the
- programs, provide adequate assurance that the objective of the previous TSs for a periodic review of the programs and changes to the programs will be met.
Therefore, duplication of the requirements contained in the regulations would not increase the level of safety for the facility.
The staff concludes that other regulatory requirements provide sufficient control of these provisions and removing them from the TSs is acceptable.
On this basis, the staff concludes that these requirements do not need to be controlled by TSs, and changes to the audit frequencies, which will be described in the Updated Final Safety Analysis Report (VFSAR), will adequately be controlled'y 10 CFR 50.54(p) or (q),
as applicable.
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) the audit requirements are not essential to avert an immediate threat to the public health and safety, and (3) changes to these audit requirements, as described in the applicable program description, wil.l require prior NRC approval in accordance with Appendix E to Part 50, Section 50.54(p), or Section 73.56(g).
The licensee's proposed changes are in accordance with GL 93-07 and are, therefore, acceptable.
3.2 Administrative Chan es to the Technical S ecifications 3.2. 1 TS Section 6.2.2.b:
Excludes the licensee's fire department as well as the shift technical advisors (STAs) from the working hour guidelines.
The licensee's fire department and a fire team advisor from the operating crew constitute the fire team.
The fire department personnel work a 24-hour schedule.
Although the 24-hour schedule does not fit the working hour guidelines, the fire department maintains a nominal 40-'hour work week.
3.2.2 TS Section 6.2.2.c:
Simplifies the statement delineating authority for deviating from the working hour guidelines.
Changing this specification by deleting specific titles and referring to an appropriate level of management significantly reduces the probability that
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further changes to this section would be needed for any future changes in personnel titles.
The director level is the level of management that the titles in the current specification represent.
The management level of the designees of the primary authorizing personnel does not change.
3.2.3 TS Section 6.5. 1:
Decrease the number of members who serve on the Plant Review Board from nine to seven, redefine the number of members to achieve a quorum, and substitute a designated alternate in lieu of a Vice-Chairman.
TS 6.5.1.2 specifies that the PRB comprises nine members.
Reducing the number to seven is consistent with the reorganization recently completed at Palo Verde Nuclear Generating Station (PVNGS).
Before the, recent
The plant manager position in each of the units has been eliminated.
The PRB functions performed by the plant managers are now fulfilled,by the Site Operations Director.
This change reduces the PRB membership by two.
The quorum requirements for the PRB are consistent with the current TS by requiring the Chairman or a designated alternate to be in attendance along with a majority of the members of the PRB.
Substitution of a designated alternate, in lieu of a vice-chairman, provides flexibilityfor the Vice-President, Nuclear Production to ensure that PRB meetings can be conducted if both the chairman and vice-chairman are away from the PVNGS site.
3.2.4 TS Section 6.5.2.4:
Remove the limitation that individuals responsible for performing reviews will be identified on1y in administrative procedures.
Allowing reviewers to be designated in procedures other than administrative procedures, provides the potential to eliminate some procedures.
Also, it would be more effective to designate reviewers in the implementing procedures.
3.2.5 TSs Sections 6.5.2.6 6.5.2.7 6.8. l.d and 6.8. l.e:
Delete these TSs sections which concern review of the security program and the emergency plan.
Deletion of these TSs sections is considered a line item improvement and is recommended in Generic Letter (GL) 93-07.
The requirements of 10 CfR Parts 50 and 73 contain provisions that are sufficient to address these requirements.
3.2.6 TS Section 6.5.2.9:
Delete this TS.
This TS is being deleted because the requirements of this specification are redundant to the requirements in other sections of the TSs.
The Process Control Program and the Offsite Dose Calculation Manual are the subject of their own specifications, i.e.,
TS 6.13 and TS 6.14, respectively.
Additionally, they are also controlled by the requirements in TS 6.5.2.1.
The Pre-planned Alternate Sampling Program is also controlled by TS 6.5.2. 1.
Changes to radwaste treatment systems are subject to the control specified in TS 6. 15.
TS 6.5.2. 1 designates the Vice-President, Nuclear Production as the responsible person to ensure that proper reviews are conducted of the items in TS 6.5.2.9.
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3.2.7 TS Section 6.5.2.10:
Delete this TS.
This TS is being deleted because TSs 6.5.2'. 1 through 6.5.2.8 provide appropriate review and control requirements to ensure that the activities performed under those specifications receive the oversight necessary for safe operation of the plant.
Records of those activities are maintained in accordance with TS 6. 10.1 and TS 6. 10.2.
TS 6.5.3.4.b provides for review of unreviewed safety questions associated with the activities described in TSs 6.5.2.1 through 6.5.2.8.
As noted', sufficient controls exist in the technical specifications to ensure that the activities described in TSs 6.5.2.1 through 6.5.2.8 receive the proper review.
Forwarding reports of these activities to the Vice-President, Nuclear Production and the off-site safety review committee (OSRC) does not provide additional meaningful review.
This change will allow the Vice President, Nuclear Production and the OSRC to focus their resources on more-safety-significant matters.
3.2.8 TSs Sections 6.7.l.a 6.7.l.c 6.8.4 and 6.10.2.k:
For TSs 6.7. l.a, 6.7. l.c, 6.8.4, and 6.10.2.k, the NRC issued Amendments 58, 45, and 31 to the Units 1, 2, and 3 operating licenses, respectively, on March 4, 1992.
These amendments replaced the Nuclear Safety Group (NSG) with the OSRC.
The changes to these sections were overlooked when APS requested these amendments.
These changes correct the technical specifications.
3.2.9 TS Section 6.8.4.
6 :
Change "of" to "or."
This is an administrative change to correct a typographical error.
The administrative controls, in TS Section 6.0, are the provisions relating to organization and management, procedures, recordkeeping, reviews, audits, and reporting necessary to ensure operation of the facility in a safe manner.
The most significant of the organizational changes are the deletion of the plant managers from the organization, and the addition of the Site Operations
- Director, who reports directly to the Vice President, Nuclear Production.
This change will unify the leadership of the operations staff of the three units, which will help to ensure comparable operation practices across the units.
Since the Site Operations Director and the Site Maintenance Director report directly to the Vice President, Nuclear Production, he is now designated as the individual who is responsible for the safe operation and maintenance of the units, as delineated in TS 6.2. l.c.
The changes requested in the composition of the Plant Review Board (PRB) reflect the deletion of the plant managers from the organization as a result of the reorganization.
A minimum seven members on the board is sufficient to provide expertise from the seven major functional areas in the organization concerned with safe operation of the plant.
The change also allows expansion of the PRB if it is deemed necessary.
Changing the quorum from the fixed number to state that a majority of the members constitutes a quorum ensures
- that, even if additional members are added to the PRB, issues will always be evaluated by a majority of the members.
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The proposed changes are administrative in nature and are not the result of any physical change in the 'licensee's units nor are they the result of changes in how the units will be operated.
The changes -eflect changes in titles and functions of certain members of the licensee's management.
team, line item improvements recommended in Generic Letter 93-07, and other miscellaneous administrative changes.
The staff has reviewed these TS administrative changes and they meet the requirements of SRP 13 and therefore are acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Arizona State official was notified of the proposed issuance of the amendments.
The State official had no comments.
- 5. 0 ENVIRONMENTAL CONS IDERATION These amendments relate to changes in r ecordkeeping, reporting, or administrative procedures or requirements.
Accordingly, the amendments meet 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 connecti'on with the issuance of the amendments.
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 i.suance of the amendment will not be inimical to the common defense and securi.ty or to the health and safety of the public.
Principal Contributor:
C.
Thomas Date:
Guly 7, 1995
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