ML17335A446
| ML17335A446 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/28/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17335A445 | List: |
| References | |
| NUDOCS 9901050223 | |
| Download: ML17335A446 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 205554001 SAFETY EVALUATIONBY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENTNO. 226TO FACILITYOPERATING LICENSE NO. DPR-58 ANDAMENDMENTNO. 210TO FACILITYOPERATING LICENSE NO. DPR-74 INDIANAMICHIGANPOWER COMPANY DONALDC. COOK NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-315 AND 50-316
1.0 INTRODUCTION
By letter dated June 11, 1996, as supplemented by letter dated March 26, 1997, 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, Units 1 and 2. The proposed amendments would relocate certain quality assurance (QA) related requirements from the TS to the licensee's Quality Assurance Program Description (QAPD) in accordance with NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specifications Administrative Controls Related to Quality Assurance," dated December 12, 1995.
By separate correspondence on August 1, 1997, the licensee submitted a proposed change to the QAPD showing how the TS would be relocated to the QAPD, to complement the proposed amendment.
On September 29, 1997, results of the NRC staff review of the July 1997 QAPD revision were forwarded to the licensee.
On October 29, 1997, the licensee submitted an updated July 1997 QAPD revision to address the NRC staff concerns.
The March 26, 1997, letter as well as all correspondence dealing with the QAPD serve to provide additional information and clarification to the June 11, 1996, application. The additional information did not change the conclusions reached in the licensee's no significant hazards determination contained in the June 11, 1996, application or expand the scope of the original Federal
~Re ister notice.
2.0 BACKGROUND
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 specific categories, including: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; 990i050223 98i228 PDR ADQCK 050003i5 P
PDR (3) suiveillance 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.
With respect to limiting conditions for operations (LCO), 10 CFR 50.36 provides four criteria to be used in determining whether particular safety functions are required to be included in the TS.
In adopting the revision to the rule, the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS (60 FR 36957).
Addressing administrative controls, 10 CFR 50.36 states that they "are the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The specific content of the administrative controls section of the TS is, therefore, that information the Commission deems essential for the safe operation of the facilitythat is not already adequately covered by other regulations.
Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from administrative controls.
Existing TS requirements, therefore, may be relocated to more appropriate documents (e.g. Security Plan, QA Plan, and Emergency Plan) and controlled by the applicable regulatory requirement.
Similarly, while the required content of TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details of administrative controls may be relocated to licensee-controlled documents where 10 CFR 50.54, 10 CFR 50.59, or other regulations provide adequate regulatory control.
3.0 EVALUATION 3.1 Review and Audit The proposed amendment would relocate the review and audit function specified in existing TS Section 6.5 to the QAPD. The requirements as currently delineated in Section 6.5 of the TS will
. - -- be placed in the QAPD, with the exception of the composition of the Nuclear Safety and Design --
Review Committee (NSDRC). The licensee has proposed to change the number of required members of (NSDRC) from 13 to 10. The staff has reviewed the proposed change and finds that the revised number of NSDRC members is acceptable.
The revised number and composition of the NSDRC does not impact on the authority or the qualification of the NSDRC members and a sufficient representation of senior managers and disciplines is maintained.
The QAPD will implement the Commission's regulations pertaining to the review and audit functions.
Inclusion of these particular provisions in the TS is not necessary to assure safe operation of the facility. The review and audit functions define an administrative framework to confirm that plant activities have been properly conducted in a safe manner.
The reviews and audits serve to provide a cohesive program that provides senior level utilitymanagement with -== ".---
assessments of facility operation and recommended actions to improve safety and reliability.
With the relocation of the review and audit functions to the QAPD, the staff finds that the functions are adequately addressed by the QAPD and existing regulations.
Audit requirements to satisfy 10 CFR Part 50, Appendix B, Criterion are specified in the QAPD. Audits are also required by ANSI N18.7, ANSI45.2, 10 CFR 50.54(p), 10 CFR 50.54(t) and 10 CFR Part 73.
, Changes to the QAPD are controlled in accordance with 10 CFR 50.54(a) and include requirements for prior NRC review and approval ifa change constitutes a reduction in the QAPD commitment.
The staff finds it is not necessary to include redundant or additional requirements in the TS Administrative Controls section.
Therefore, the staff finds that the relocation of the Review and Audit functions from Section 6.5 of the TS to the QAPD is acceptable.
3.2 Record Retention The licensee proposed to relocate the record retention requirements in Section 6.10 of the TS to the QAPD. Allthe existing TS requirements from Section 6.10 willbe placed in the QAPD.
The provisions in the QAPD willimplement the Commission's regulations pertaining to the maintenance of records related to activities affecting quality. The required controls related to record retention specified in various regulations and the addition of the TS requirements to the QAPD are considered redundant to the requirements currently in the TS. The staff has determined that the record retention requirements are adequately addressed by existing regulations and related commitments in the QAPD. Based upon the relocation of the record retention requirements to the QAPD it is not necessary to include redundant or additional requirements in the Administrative Controls section of the TS.
The staff finds that the regulatory requirements of 10 CFR Part 50, Appendix B provide sufficient control of plant records and sufficient regulatory controls for future changes to the QAPD pursuant to 10 CFR 50.54(a).
In addition, other regulations such as 10 CFR 20, Subpart L and 10 CFR 50.71 require the retention of records related to operation of the nuclear power plant.
The requirements in the QAPD along with the other regulatory requirements provide sufficient control of record keeping provisions. Therefore, the staff finds the relocation of the Record Retention requirements from Section 6.10 to the QAPD is acceptable.
3.3 Chan es to the QAPD By letter dated August 1, 1997, the licensee submitted a revision to the QAPD dated July 1997.
The July 1997 QAPD allowed the staff to evaluate how the licensee was going to relocate the TS requirement from the Administrative Controls section of the TS to the QAPD. The staff reviewed the July 1997 submittal and found concerns with proposed changes to the QAPD. By letter dated September 29, 1997, the staff issued the concerns to the licensee.
By letter dated October 29, 1997, the licensee responded to the concerns raised by the staff and proposed new changes to the QAPD. The staff reviewed the changes to the QAPD and found that the changes to the QAPD do not constitute a reduction in the commitments contained in the QAPD.
Therefore, in accordance with 50.54(a), the staff finds the proposed changes in the July 1997 QAPD as amended in the licensee s October29, 1997 letter, are acceptable.
4.0
SUMMARY
The staff has evaluated the.'icensee's proposal related to the revision of TS administrative controls associated with the relocation of the Review and Audit functions of TS Section 6.5 and the Record Retention requirements of TS Section 6.10 to the QAPD. Based on the above evaluation, the staff concludes that (1) the proposed QA-related administrative control provisions I
can be relocated from the current TS to the QAPD and, once relocated to the QAPD and controlled pursuant to 10 CFR 50.54(a), constitute the bases for the licensee's continued compliance with the requirements of Appendix B to 10 CFR Part 50; and (2) the July 1997 QAPD revision, as updated on October 29, 1997, continues to comply with the criteria of Appendix B to 10 CFR Part 50. Therefore, the staff finds the proposed changes to the TS'and the QAPD acceptable
5.0 STATE CONSULTATION
t In accordance with the Commission's regulations, the Michigan State officialwas notified of the proposed issuance of the amendments; The State official had no comments.
6.0 ENVIRONMENTALCONSIDERATION These amendments change the requirements with respect to administrative procedures.
The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (61 FR 40022). Accordingly, the amendments meet the eligibilitycriteria 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.
7.0 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 willnot be endangered by operation in the proposed manner, (2) such activities willbe conducted in compliance with the
-.. -....Commission's regulations, and (3) the issuance of the amendments will not he inimical to the ----
common defense and security or to the health and safety of the public.
Principal Contributor: Michael Bugg, NRR John Stang, NRR Date:
December 28, 1998
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