ML18010A715

Application for Amend to License NPF-63,implementing Functional Role & Responsibilities of Recently Created Nuclear Assessment Dept

ML18010A715
Person / Time
Site:	Harris
Issue date:	08/06/1992
From:	Starkey R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18010A716	List: ML18010A715 ML18010A717
References
NLS-92-189, NUDOCS 9208140207
Download: ML18010A715 (19)

Text

ACCELERATED DISTRIBUTION DEMONSTIIATION SYSTEM REGULA Y INFORMATION DISTRIBUTIO YSTEM (RIDS)

ACCESS/ON NBR:9208140207 DOC.DATE: 92/08/06 NOTARIZED: YES DOCKET FACIL:50-.400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION STARKEY,Q.B. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Application for amend to license NPF-63,implementing functional role a responsibilities of recently created Nuclear Assessment Dept.

DZSTR1BUTTON CODE: R001D TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution

/ ENCL / SIZE: / +/ 7 D NOTES:Application for permit renewal filed. 05000400

/

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 PD2-1 PD 1 1 D LE,N 2 2 D

INTERNAL: ACRS 6 6 NRR/DET/ESGB NRR/DOEA/OTSB11 1 1 NRR/DST/SELB 7E NRR/DST/SICB8H7 1 1 NRR/DST/SRXB 8E NUDOCS-ABSTRACT 1 1 OC/L OGC/HDS1 1 0 FILE 01 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 R

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D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE'CONTACT THE DOCUMENT CONTROL DESK.

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CIRL Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602 R. B. STARKEY, JR. SERIAL: NLS-92-189 Vice President Nuclear Senrtces Oepartment 10CFR50.90 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT - NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES Gentlemen:

In accordance with the Code of Federal Regulations, Title 10, Parts 50.90 and 2.101, Carolina Power & Light Company (CP&L) hereby requests a revision to the Technical Specifications for the Shearon Harris Nuclear Power Plant (SHNPP).

The proposed amendment would implement the functional role and responsibilities of the recently created Nuclear Assessment Department (NAD). The NAD performs internal evaluations and assessment activities. The fundamental role of the NAD is to assist management in identification of issues which may prevent CP&L's nuclear projects from achieving quality performance on a sustained basis as well as to ensure the effective correction of these issues. The NAD has also assumed the responsibilities for and the functions of administering the independent review program for nuclear facilities and the independent assessment of unit activity.

Enclosure 1 provides a detailed description of the proposed changes and the basis for the changes.

Enclosure 2 details the basis for the Company's determinat:ion that the proposed changes do not involve a significant hazards consideration.

Enclosure 3 details the basis for the Company's determination that the proposed changes require no environmental assessment.

Enclosure 4 provides the proposed Technical Specification pages for the unit.

CP&L is providing, in accordance with 10CFR50.91(b), the state of North Carolina with a copy of the proposed license amendment.

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i NLS-92-189 / Page 2 Please refer any questions regarding this submittal to Mr. D. C. McCarthy at (919) 546-6901.

Yours very truly, R. B. Starkey, r.

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Enclosures:

1. Basis for Change Request

2. 10CFR50.92 Evaluation

3. Environmental Consideration

4. Unit 1 Technical Specification Pages cc: Mr. Dayne H. Brown Mr. S. D. Ebneter Mr. N. B. Le Mr. J. E. Tedrow R. B. Starkey, Jr., having been first duly sworn, did depose and say that the information contained herein is true and correct to the best of his information, knowledge and belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

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ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES BASIS FOR CHANGE RE VEST

~Back round:

Carolina Power & Light Company (CP&L) has created a Nuclear Assessment Department (NAD) which performs internal evaluations and assessment activities. The department's fundamental role is to assist senior management in the early identification of issues which may prevent the Company's nuclear projects from achieving quality performance on a sustained basis and to ensure effective correction of deficiencies. The NAD has assumed the functions and responsibilities for (1) administering the Company's independent review program for nuclear facilities; and (2) the independent assessment of unit activity.

As CP&L continues to emphasize that quality is the primary responsibility of the line organization, the NAD uses more performance based methods to evaluate the attainment of quality. This proposed change is submitted to allow the NAD greater freedom to concentrate resources on performance issues and improvements.

The proposed change meets the CP&L commitments to Regulatory Guide 1.33, which endorses ANSI N18.7, as specified in Section 1.8 of the Final Safety Analysis Report (FSAR) for the Shearon Harris Nuclear Power Plant (SHNPP) ~ In addition, the proposed change will provide oversight consistency within CP&L.

In the area of independent review, the proposed changes will allow the NAD resources to be redirected for the identification and resolution of significant safety-related issues. The experience that CP&L has gained in the area of independent review has enabled the NAD to gain the expertise necessary to evaluate which items under review will yield significant safety-related issues. Many of the items that currently are independently reviewed are not complex, have little safety significance, and have already undergone an extensive review process encompassing the requirements of 10CFR50.59. A subsequent independent review of such items adds negligible safety value.

Refocusing available resources to areas that have historically produced significant safety-related issues will enhance the Nuclear Generation Group performance relating to nuclear safety, reliability, and quality.

The proposed change makes wording consistent with ANSI N18.7 by specifying the scope of independent reviews to include changes "to the facilit as described in the Final Safety Analysis Report." This change meets the requirements of ANSI N18.7 and expands the current Technical Specification (TS) requirements to review changes "to the Final Safety Analysis Report."

The proposed change modifies the wording for specific items requiring independent review to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change also El-1 (1383HHP ~ GLU)

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plant changes, tests,and procedures. This complies with the"requirements of ANSI N18.7. As applied to independent review, the term "significant plant changes, tests, and procedures" shall include changes in the facility as described in the Safety Analysis Report, tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10CFR50.59(a)(l), and changes in procedures as described in the Safety Analysis Report; any of the above which have or are likely to have an influence or effect on safety-related structures, systems or components.

The provisions of 10CFR50.54(a)(l) require implementation of a quality assurance program as described in the Safety Analysis Report. The recently submitted Quality Assurance (QA) program change describes the NAD assessment program. This proposed change removes specific details of the NAD audit/assessment program from the TS and makes reference to Section 17.3 of the FSAR for these details. This change eliminates inconsistency and duplication between the TS and the QA Program described in the FSAR.

The proposed changes modify the following specific sections of the TS as indicated:

Section 6.2.3: Project Assessment (PA) Section CHANGE: The proposed change deletes the existing Section 6.2.3. The functions in this section, related to oversight and assessment of unit operations and activities, have been combined into Section 6.5.4 (NAD Program). NUREG 0737, I.B.1.2 requires five dedicated engineers to staff this function. This specific requirement, for five engineers, is not being carried forward into Section 6.5.4. The intent of this commitment, to provide independent overview, will be met by the corporate and the site NAD Sections. Functions relative to operating experience feedback have been transferred into the line organization in the Regulatory Compliance Unit.

BASIS: Combining the oversight functions of the PA Unit into the NAD Assessment Program will provide consistency among CP&L facilities in the way these responsibilities are being implemented. Transferring the Operating Experience Feedback function into the line organization will allow these evaluations to be performed as a line function rather than as an oversight function. Deletion of the specific NUREG 0737 requirement is based on meeting the intent of this requirement with the Harris Nuclear Project Assessment Section. This Section is a multi-discipline group made up of engineers and technical specialists with experience in management, engineering, and technical specialties related to the operational activities of the Unit. The larger size of this group with a greater experience base in both line and staff functions and more diversity of discipline coverage than required by the previous commitment of five dedicated engineers provides a greater assurance that the intent of this commitment is met.

Section 6.5.1.4: Safety Evaluations and Approvals CHANGE: 6.5.1.4.5 Safety Evaluations and Approvals - The phrase "change in the Safety Analysis Report" is replaced with "change in the facility as described in the Safety Analysis Report."

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BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change makes wording consistent with ANSI N18.7 by specifying the scope of independent reviews to include changes "to the facilit as described in the Final Safety Analysis Report." This change meets the requirements of ANSI N18.7 and expands the current TS requirements to review changes "to the Final Safety Analysis Report."

Section 6.5.2: Plant Nuclear Safety Committee (PNSC)

CHANGE: 6.5.2.2 Composition - The proposed change deletes the position of Manager - QA/QC-Harris Plant from the list of members of the Plant Nuclear Safety Committee (PNSC) as this position no longer exists at the Shearon Harris Nuclear Power Plant (SHNPP).

BASIS: This position as a PNSC member was a holdover from original plant organizations where the QA Supervisor was part of the plant staff and reported directly to the plant manager at the H. B. Robinson Steam Electric Plant and the Brunswick Steam Electric Plant. Creation of the

'AD deleted this position and allows NAD to independently assess PNSC activities.

CHANGE: 6.5.2.6 Activities - The proposed change deletes the requirement for the PNSC to submit reports prepared in accordance with Item k of this section to the NAD.

BASIS: If the investigated event involves the safe operation of the nuclear power plant, the report will be submitted to the NAD per the requirements of the proposed Section 6.5.3.9.e.

Section 6.5.3: Nuclear Assessment Department Independent Review Program CHANGE: 6.5.3.1 Function - The proposed change modifies the function of the Nuclear Assessment Department to provide independent review of BASIS: This complies with the requirements of ANSI N18.7. As applied to independent review, the term "significant plant changes, tests, and procedures" shall include changes in the facility as described in the Safety Analysis Report, tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10CFR50.59(a)(l), and changes in procedures as described in the Safety Analysis Report; any of the above which have or are likely to have an influence or effect on safety-related structures, systems or components.

CHANGE: 6.5.3.2 Organization - The proposed change modifies the wording and list of discipline areas to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7.

Specifically the discipline area of "seismic and environmental" has been added.

BASIS: The proposed change modifies the wording and list of discipline areas to provide consistency among CP&L nuclear facilities and to comply with the disciplines listed in ANSI N18.7. "Seismic and environmental" is a specific discipline area requiring specialized training and/or El-3 (1383HHP.GLU)

experience in order to conduct Independent Reviews in this area if applicable.

CHANGE: 6.5.3.3 Organization - The proposed change modifies the qualification requirements to apply to the Manager - Safety Review Unit and complies with ANSI N18.7. The term "baccalaureate degree" is replaced with "bachelor degree."

BASIS: The proposed change provides consistency among CP&L nuclear facilities and compliance with ANSI N18.7 in regards to education qualification. Prior to Amendment 26, these requirements were applied to the Manager - Corporate Nuclear Safety Section. Until the NAD

,organization could be finalized, these requirements were applied to the Manager - Nuclear Assessment Department in Amendment 26. Under the current NAD organization, the position of Manager - Safety Review Unit is responsible for the independent review process. The proposed change maintains the same qualification requirements for the manager responsible for supervising this process.

CHANGE: 6.5.3.4 Organization - The term "baccalaureate degree" is replaced with "bachelor degree."

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change maintains the same qualification/education requirements.

CHANGE: 6.5.3.6 Organization - The proposed change modifies the review process to eliminate a specific number of reviews.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The basis for requiring three reviews in the existing TS is to ensure that applicable disciplines are encompassed. The proposed change specifically requires reviews in applicable disciplines by qualified individuals. Specifically requiring three reviews is unnecessarily restrictive and does not ensure appropriate reviews are performed.

CHANGE: 6.5.3.9.a Review - The phrase "all procedures and programs required by Specification 6.8 and other procedures that affect nuclear safety and changes thereto" is replaced with "significant changes in procedures as described in the Safety Analysis Report." The phrase "proposed tests or experiments" is replaced with "significant tests or experiments not described in the Safety Analysis Report." The phrase "proposed modifications" is replaced with "significant changes in the facility as described in the Safety Analysis Report." The modifying phrase "that are completed without prior NRC approval under the provisions of 10CFR50.59(a)(1)" has been added.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. This section also modifies the function of the Nuclear changes to the facility, changes in procedures, and tests or experiments. This complies with the requirements of ANSI N18.7.

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k that these reviews provide little or no real impact on improving or enhancing safety or reliability. As applied to independent review, the term "significant" (as applied to changes to the facility, changes in procedures, and tests or experiments) shall include changes in the facility as described in the Safety Analysis Report, changes in procedures as described in the Safety Analysis Report, and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10CFR50.59(a)(1); any of the above which have or are likely to have an influence or effect on safety-related structures, systems or components.

CHANGE: 6.5.3.9.b, c and g Review - Current Sections 6.5.3.9.b, 6.5.3.9.c and 6.5.3.9.g are combined under the proposed Section 6.5.3.9.b due to reformatting. The phrase "all procedures and programs required by Specification 6.8 and other procedures that affect nuclear safety and changes thereto" is replaced with "changes in procedures required by these Technical Specifications." The phrase "proposed modifications" is replaced with "proposed changes in the facility."

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change maintains the same degree of review.

Since the procedures required by the TS exist, only changes to these procedures require independent review. This is consistent with the other CP&L nuclear facilities and complies with ANSI N18.7.

CHANGE: 6.5.3.9.d Review - This existing requirement is contained in proposed Section 6.5.3.9.c due to reformatting. The requirement to conduct an independent review "prior to implementation" has been added.

ANSI N18.7 requires this independent review to be completed prior to implementation.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7.

CHANGE: 6.5.3.9.e Review - This existing requirement is contained in proposed Section 6.5.3.9.d.l and 6.5.3.9.d.2 due to reformatting.

Violations that require reporting to the NRC in writing will require an independent review.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. Consistent with ANSI N18.7, the proposed change will require an independent review by the NAD of CP&L self-identified violations, operating abnormalities or deviations reportable in writing to the NRC.

CHANGE: 6.5.3.9.f Review - This existing requirement is contained in proposed Section 6.5.3.9.d.3 due to reformatting. Since "REPORTABLE EVENTS" is a defined term in the TS, it is capitalized in the proposed Section 6.5.3.9.d.3.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change maintains the same degree of review.

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CHANGE: 6.5.3.9.h Review - This existing requirement is moved to proposed Section 6.5.3.9.e due to reformatting.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The proposed change maintains the same degree of review.

CHANGE: 6.5.3.9.i Review - The proposed change eliminates recognized indications of an unanticipated deficiency from formal review.

BASIS: The proposed change eliminates "unanticipated deficiencies" from formal review to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. "Unanticipated deficiencies" is presently covered by "other matters involving safe operation" (Item h) and is redundant. The proposed change covers i

existing Items h and under proposed Item e, "any other matter involving safe operation."

CHANGE: 6.5.3.9.j Review - Reports and minutes of the PNSC are eliminated from formal review.

BASIS: The proposed change eliminates PNSC reports and minutes from formal review to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7, Items of safety significance that are reviewed by PNSC will continue to be independently reviewed by the NAD. In accordance with TS 6.5.2.8, the PNSC will forward its minutes to the NAD so that the safety significant issues are identified.

CHANGE: 6.5.3.10, Review, and 6.5.3.ll.a, Records - Existing Sections 6.5.3.10 and 6.5.3.ll.a are combined under the proposed Section 6.5.3.10 due to reformatting. Any identified adverse conditions resulting from independent reviews are addressed in proposed Section 6.5.3.11.

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. Any identified adverse conditions resulting from independent reviews are addressed in proposed Section 6.5.3.11.

CHANGE: 6.5.3.11.b Records - This existing requirement is moved to proposed Section 6.5.3.11 due to reformatting. The proposed change modifies the response of independent reviews that identify potentially adverse conditions from "recommendations and concerns" to submittal "in accordance with the corrective action program."

BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and ensure continued compliance with ANSI N18.7. The corrective action program is a formalized program that identifies, prioritizes and responds to potentially adverse conditions that are identified by individuals or functional organizational units within CP&L.

CHANGE: 6.5.3.11.c - This existing requirement is moved to proposed Section 6.5.3.12 due to reformatting. The proposed change modifies the type of report to a presentation given to the Executive Vice President-Power Supply and the Senior Vice President - Nuclear Generation Group.

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The Vice President - Harris Nuclear Project and the Plant General Manager will receive a copy of the presentation. The Chairman/President:

has been excluded from this presentation.

BASIS: The proposed change modifies the wording to provide consistency among CPGL nuclear facilities and ensure continued compliance with ANSI N18.7. The NAD performs internal evaluations and assessment activities and serves as senior management's staff for the objective oversight of Nuclear Generation Group performance relating to nuclear safety, reliability, and quality. The department's fundamental role is to assist senior management in the early identification of those deficiencies which may prevent the Company's nuclear projects from achieving the desired level of performance on a sustained basis and to ensure effective correction of deficiencies. The Manager of the NAD is free at anytime to raise issues to the Chairman/President if he determines that additional emphasis or action is necessary.

Section 6.5.4: Nuclear Assessment Department Audit Program CHANGE: The proposed change replaces specific details in this section with reference to the QA Program in Section 17.3 of the FSAR which describes the Nuclear Assessment Department audit/assessment program.

BASIS: 10CFR50.54(a)(l) requires implementation of a quality assurance program as described in the Safety Analysis Report. This change eliminates inconsistency and duplication between the TS and the QA Program described in the FSAR. The QA Program description in the FSAR addresses the elements for an audit/assessment program identified in NUREG-0800, Section 17.3.

Section 6.5.5: Outside Agency Inspection and Audit Program CHANGE: The proposed change deletes specific details in this section and references the QA Program in Section 17.3.3.3 of the FSAR, which describes the NAD audit/assessment program.

BASIS: Generic Letter 88-12 allows the removal of Fire Protection Program requirements from the TS, provided that a periodic audit be conducted of the Fire Protection Program. The Generic Letter requested that the existing administrative controls related to Fire Protection Program audit requirements be retained in the TS. This change eliminates inconsistency and duplication between TS, the Generic Letter recommendations, and the QA Program described in the FSAR. The QA Program description in the FSAR addresses the elements for an audit/assessment program identified in NUREG-800, Section 17.3, and includes a requirement for a Fire Protection audit/assessment.

10CFR50.54(a)(1) requires implementation of a quality assurance program as described in the FSAR.

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Section 6.10.3 CHANGE: The proposed change deletes Item i from the list of records to be retained for the duration of the license. The specific records are regrouped to provide consistency among CPSL nuclear facilities.

BASIS: Retention requirements for QA activity records will be identified in the QA Program. With the exception of QA activity records, the proposed change maintains the same type of records and retention requirements.

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ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES 10CFR50.92 EVALUATION The Commission has provided standards in 10CFR50.92(c) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Carolina Power &

Light Company (CP&L) has reviewed this proposed license amendment request and determined that its adoption would not involve a significant hazards consideration. The bases for this determination are as follows:

Pro osed Chan e CP&L has created a Nuclear Assessment Department (NAD) which performs internal evaluations and assessment activities. 'he department's fundamental role is to assist management in the early identification of issues which may prevent the Company's nuclear projects from achieving quality performance on a sustained basis and in ensuring effective correction. The NAD has assumed the functions and responsibilities for (1) administering the Company's independent review program for nuclear facilities and (2) the assessment of unit activity.

The proposed amendment would implement the functional role and responsibilities of the recently created Nuclear Assessment Department (NAD).

Specifically, the changes affect the independent review program and the independent assessment of unit activity.

Basis The change does not involve a significant hazards consideration for the following reasons:

1. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated because it is programmatic and does not physically alter any safety-related systems, nor does it affect the way in which any safety-related systems perform their functions. The independent review function is being revised to provide program consistency between the nuclear units while maintaining compliance with ANSI N18.7. The independent assessment requirements for the NAD are being removed from the Technical Specifications (TS) and reference made to the Quality Assurance (QA)

Program for these details. Since the design of the facility and system operating parameters are not changing, the proposed amendment does not involve an increase in the probability or consequences of any accident previously evaluated.

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2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. As stated in Item 1, the proposed amendment is programmatic and does not physically alter any safety-related systems; nor does it affect the way in which any safety-related systems perform their functions. Since the design of the facility and system operating parameters are not changing, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. The proposed amendment does not involve a significant reduction in the margin of safety because it is a programmatic change. As stated in Item 1, the proposed amendment does not physically alter any safety-related systems; nor does it affect the way in which any safety-related systems perform their functions. Since the design of the facility and syst: em operating parameters are not changing, the proposed amendment does not involve any reduction in the margin of safety.

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ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES ENVIRONMENTAL CONSIDERATION 10CFR51.22(c)(9) provides criterion for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration; (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site; and (3) result in an increase in an individual or cumulative occupational radiation exposure. Carolina Power & Light Company (CP&L) has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9).

Pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment. This basis for this determination follows:

Pro osed Chan e CP&L has created a Nuclear Assessment Department (NAD) which performs internal evaluations and assessment activities. The department's fundamental role is to assist management in the early identification of issues which may prevent the Company's nuclear projects from achieving quality performance on a sustained basis and in ensuring effective correction. The NAD has assumed the functions and responsibilities for (1) administering the Company's independent review program for nuclear facilities and (2) the assessment of unit activity.

Basis This change meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9) for the following reasons:

1. As demonstrated in Enclosure 2, the proposed amendment does not involve a significant hazards consideration.

2. The proposed amendment does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site.

The proposed change is programmatic and only revises Section 6, "Administrative Controls," of the Technical Specifications to reflect changes in the review and assessment of CP&L due to the creation of the NAD. The proposed amendment does not introduce any new equipment, nor does it require any existing equipment or systems to perform a different type of function than they are currently designed to perform. As such, the change cannot affect the types or amounts of any effluents that may be released off-site.

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3. The proposed amendment does not result in an increase in individual or cumulative occupational radiation exposure. The proposed change is programmatic and only revises Section 6, "Administrative Controls," of the Technical Specifications to reflect changes in the review and assessment of CPSL due to the creation of the NAD. No additional surveillances or testing results from the amendment. Therefore, the amendment has no effect on either individual or cumulative occupational radiation exposure.

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