ML17332A638
| ML17332A638 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/06/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17332A631 | List: |
| References | |
| NUDOCS 9503150319 | |
| Download: ML17332A638 (4) | |
Text
c<1'EGS
~o Cy p'
+>>**+
UNITED STATES NUCLEAR REGULATORY COMIVIISSION WASHINGTON, D.C. 20555<001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.
192 TO FACILITY OPERATING LICENSE NO. DPR-58 AND AMENDMENT NO.
178 TO FACILITY OPERATING LICENSE NO.
DPR-74 INDIANA MICHIGAN POWER COMPANY DONALD C.
COOK NUCLEAR PLANT UNIT NOS.
1 AND 2 DOCKET NOS.
50-315 AND 50-316
- 1. 0 INTRODUCTION By letter dated October 7,
- 1994, the Indiana Michigan Power Company (the licensee) requested amendments to the Technical Specifications (TS) appended to Facility Operating License Nos.
DPR-58 and DPR-74 for the Donald C.
Cook Nuclear Plant, Unit Nos.
1 and 2.
The proposed amendments would remove the audit of the emergency and security plans and implementing procedures from the list of responsibilities of the Nuclear Safety and Design Review Committee (NSDRC).
The proposed amendments also remove the requirements for Plant Nuclear Safety Review Committee (PNSRC) review of the emergency and security plans, their implementing procedures, and changes to the implementing procedures.
The proposed change would remove administrative controls for the emergency and security plans from the TS that duplicate the provisions in Parts 50 and 73 of Title 10 of the Code of Federal Regulations (10 CFR).
The TS provisions related to the review activities for the emergency and security plans would be relocated, respectively, to those plans.
The NRC issued guidance to all holders of operating licenses for nuclear power reactors on the proposed change by Generic Letter (GL) 93-07, "Modification of Technical Specification Administrative Control Requirements for Emergency and Security Plans," dated December 28, 1993.
In addition to the above proposed
- changes, the licensee proposed to revise the listed composition of the PNSRC and the NSDRC to reflect organizational changes and to revise the position of "Plant Manager" to "Site Vice President/Plant
- Manager, or his designee."
2.0 BACKGROUND
The NRC staff undertook efforts in the early 1980's to address problems related to the content of nuclear power plant TS.
These projects have resulted in the issuance of various reports, proposed rulemakings, and Commission policy statements.
Line item improvements became a mechanism for TS improvement as part of the implementation of the Commission's interim policy statement on TS improvements published on February 6,
1987 (52 FR 3788).
The final Commission policy statement on TS improvements was published July 22, 1993 (58 FR 39132).
The final policy statement provided criteria which can be used to establish,,
more clearly, the framework for TS.
The staff 9503i50319 950306 I
POR ADQCK 050003l5 P
has maintained the line item improvement process, through the issuance of generic letters, in order to improve the content and consistency of TS and to reduce the licensee and staff resources required to process amendments related to those ~ecifications being relocated from the TS to other licensee documents as a result of the implementation of the Commission's final policy statement Section 50.36 of Title 10 of the Code of Federal Regulations establishes the regulatory requirements for licensees to include TS as part of applications for operating licenses.
The rule requires that TS include items in five specified categories:
(I) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) survei)lance requirements; (4) design features; and (5) administrative controls.
In addition, the Commission's final policy statement on TS improvements and other Commission documents provide guidance regarding the required content of TS.
The fundamental purpose of the TS, as described in the Commission's final policy statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety by identifying those features that are of controlling importance to safety and establishing on them certain conditions of operation which cannot be changed without prior Commission approval.
The Commission's final policy statement recognized, as had previous statements related to the staff's TS improvement program, that implementation of the policy would result in the relocation of existing TS requirements to licensee-controlled documents such as the Updated Final Safety Analysis Report (UFSAR).
Those items relocated to the UFSAR would in turn be controlled in accordance with the requirements of 10 CFR 50.59, "Changes, tests and experiments."
Section 50.59 of Title 10 of the Code of Federal Regulations provides criteria to determine when facility or operating changes planned by a licensee require prior Comvission approval in the form of a license amendment in order to address any unreviewed safety questions.
In the case of this proposed amendment, changes would be controlled by the requirements of 10 CFR 50.54(p) and 10 CFR 50.54(q).
These regulations require NRC review and approval for changes which would decrease the effectiveness of the security plan, guard training and qualification plan, or the emergency plan.
NRC inspection and enforcemeot programs also enable the staff to monitor facility changes and licensee adherence to UFSAR commitments and to take any remedial action that may be appropriate.
3.0 EYALM7fON The licensee proposed modifying TS 6.5.1.6 by removing items i and j, which reference the security and emergency
- plans, respectively, and their implementing procedures under the review responsibilities of the PNSRC.
The licensee proposed modifying TS 6.5.2.8 by removing items e and f, which reference the security and emergency plans, respectively, and their implementing procedures under the audit responsibilities of the NSDRC, which are to be performed at least once every 12 months.
The licensee also proposed modifying TS 6.8.1 by removing items b, Security Plan implementation, and c, Emergency Plan implementation, fr om the list of activities for which this
specification requires that written procedures be established, implemented, and maintained.
The TS provisions related to the PNSRC review activities for the emergency and security plans, their implementing procedures, and changes to those procedures have been relocated, respectively, to those plans.
The licensee has proposed TS changes that are consistent with the NRC guidance in GL 93-07 and that eliminate TS provisions that duplicate the requirements in 10 CFR Parts 50 and 73.
The changes associated with the implementation of GL 93-07 involve the deletion of certain requirements related to procedures for security and emergency plan implementation and review responsibilities of the PNSRC and NSDRC for those plans and procedures.
These requirements are already adequately addressed in 10 CFR Parts 50 and 73 and are therefore, redundant.
Because the elimination of the procedure and review requirements from the TS do not alter the requirements for maintaining adequate procedures for the security and emergency plans or for the necessary reviews and audits to be performed, the staff has concluded that the proposed removal is acceptable.
The staff's determination is based on the fact that the removal of the specific requirements related to procedures for security and emergency plan implementation and review responsibilities of the PNSRC and NSDRC for those plans and procedures does not eliminate the requirements for the licensee to ensure that the security and emergency programs are capable of performing their required function.
Although the requirements are removed from the TS, the licensee must continue to evaluate any changes in accordance with 10 CFR 50.54(p), for the security plan, and 10 CFR 50.54(q), for the emergency plan.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, (3) a reduction in the margin of
- safety, or (4) a decrease in the effectiveness of the security plan or guard training and qualification program or the emergency
- plans, NRC approval and a
license amendment would be required prior to implementation of the change.
The staff's review concluded that 10 CFR 50.36 does not require the security and emergency procedures and review requirements to be retained in TS.
The security and emergency procedures and review requirements are considered to be an operational detail which are adequately controlled by the requirements of 10 CFR 50.54(p) and 10 CFR 50.54(q).
Therefore, the security and emergency procedures and review requirements do not constitute a condition or limitation Dn operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, in that the ability of the security and emergency programs to perform their safety functions are not adversely impacted by the deletion of the requirements from the TS.
These TS changes are consistent with the guidance provided in GL 93-07 and the TS requirements of 10 CFR 50.36.
The staff has determined that the proposed changes to the TS for the D.
C.
Cook Nuclear Plant, Units 1
and 2, are acceptable.
In addition to the above, the licensee proposed changes to Section 6
"Administrative Controls," of the TS to revise the listed composition of the PNSRC and the NSDRC to reflect organizational changes and to revise the position of "Plant Manager" to "Site Vice President/Plant
- Manager, or his designee."
The changes to the composition of the PNSRC and the NSDRC reflect organizational
- changes, are administrative in nature, and are therefore acceptable.
The change in the title of "Plant Manager" to "Site Vice President/Plant Manager reflects a title change for the position, is administrative in nature, and is therefore acceptable.
The addition of "or his designee" formalizes the responsibility designation which must take place when the Site Vice President/Plant Manager is unavailable to perform the function.
This change is also administrative in nature and therefore acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Michigan State official was notified of the proposed issuance of the amendments'he State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change recordkeeping, reporting, or administrative procedures or requirements.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51 '2(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'.0 CONCLUSION The staff 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 amendments will not be inimical to the common defense and security or to the health and safety of the public Principal Contributors:
Thomas G. Dunning, NRR William Reckley, NRR John B. Hickman, NRR Date:
Narch 6, 199S