ML18011A170
| ML18011A170 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/15/1993 |
| From: | Habermeyer H CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18011A172 | List: |
| References | |
| GLS-93-161, NUDOCS 9309200105 | |
| Download: ML18011A170 (18) | |
Text
~ '., A'CCELERAT DOCUMEN'I'IS'I' UTION SYSTEM REGULA Y INFORMATION DISTRIBUTI SYSTEM (RIDS)
ACCESSION NBR:9309200105 DOC.DATE: 93/09/15 NOTARIZED: YES DOCKET ¹
- -FACIL
- 50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH.NAME AUTHOR AFFILIATION HABEYMEYER,H.W.
Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION, Document Control Branch (Document Control Desk)
SUBJECT:
Application for amend to, license NPF-63,requesting rev to TS allowing implementation of funtional role a responsibilities of nuclear assessment dept.
DISTRIBUTION CODE'OOID COPIES RECEIVED'LTR I
ENCL L SIZE'ITLE:
OR Submittal: General Distribution NOTES:Application for permit renewal filed.
05000400 I RECIPIENT ID CODE/NAME PD2-1 LA LE,N INTERNAL: ACRS NRR/DORS/OTSB NRR/DRPW NRR/DSSA/SRXB
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1 RECIPIENT ID CODE/NAME PD2-1 PD NRR/DE/EELB NRR/DRCH/HICB NRR/DSSA/SPLB NUDOCS-ABSTRACT OGC/HDS1 NSIC COPIES LTTR ENCL 1
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D NOTE TO ALL"RIDS" RECIPIENTS:
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ROOM Pl-37 (EXT. 504-20tiS) TO ELIMINATEYOUR NAME FROM DISTIRIIIU'I'ION LISTS FOR DOCUMENTS YOU DON'T NEED!
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Carolina Power & Light Company P.O. Box 1551 ~ Raleigh, N.C. 27602 SEP 15 1993 H. W. HABERMEYER,JR.
Vice President Nuclear Services Department SERIAL:
GLS-93-161 United States Nuclear Regulatory Commission ATTENTION:
Document Control Desk Washington, DC 20555 1
SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR LICENSE AMENDMENT NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES Gentlemen:
By letter dated August 6, 1992, Carolina Power 6 Light Company (CPGL) requested a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant (SHNPP).
That proposed amendment was to allow implementation of the functional role and responsibilities of the Nuclear Assessment Department (NAD).
Subsequent discussions with the NRC regarding that submittal provided valuable information in support of the requested changes.
This letter provides a
revised submittal incorporating the results of these discussions.
Enclosures 1A and 1B provide a summary of differences from the initial submittal and the revised description of the proposed
- changes, with the basis for the changes.
Enclosure 2 provides CPGL's initial basis for determination that the proposed changes do not involve a significant hazards consideration.
This determination remains valid for this revised submittal.
Enclosure 3 provides CPGL's initial basis for determination that the proposed changes require no environmental assessment.
This determination remains valid for this revised submittal.
Enclosure 4 provides the page change instructions.
Enclosure 5 provides the revised TS pages.
Carolina Power tx Light Company is providing, in accordance with 10 CFR 50.91(b),
the state of North Carolina with a copy of this revised license amendment request.
93092001,05,, 930915 PDR.". trrADOCK'5000400 P
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Ddcument Control D~
... GLS-93-161 / Page 2~
Please refer any questions regarding this submittal to Mr. R.
W. Prunty at (919) 546-7318.
Yours very truly, H.
W. Habermeye DBB/jbw Enclosures cc0 Mr. Dayne Mr. S.
D.
Mr. N. B.
Ms. B. L.
Mr. J.
E.
H. Brown Ebneter Le Mozafari Tedrow H.
W. Habermeyer, 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 6 Light Company.
C.
My commission expires:
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ENCLOSURE lA SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 NUCLEAR ASSESSMENT DEPARTMENT FUNCTIONAL CHANGES RESUBMITTAL CHANGE
SUMMARY
Four items are being withdrawn from the original submittal.
T.S.6.5.2.6 is being withdrawn.
This item will remain as is in the approved Technical Specifications.
2 ~
T.S.6.10.3 is being withdrawn.
This item relating to Quality Assurance (QA) records will remain as is in the approved Technical Specifications.
The list of records will be restructured for clarity.
3.
T.S.6.5.3.9.i is being withdrawn.
This item relating to independent review items will remain as is in the approved Technical Specifications.
4 ~
T.S.6.5.3.9.a has the word "significant" as a modifier to the list of items reviewed by the independent review group removed.
Three items comments by are being clarified based on organizational changes and/or NRC reviewers.
T.S.6.5.3.6 (proposed) has been clarified to state that multiple reviews will take place if necessary to ensure all applicable disciplines are covered when performing independent reviews.
2.
T.S.6.5.4 has been revised to include the list of areas that will be assessed by NAD.
Reference to Section 17.3.3 of the FSAR provides the details of the Assessment Program.
3.
T.S.6.5.3.12 (proposed) has been revised to show the current organizational titles applicable to this item.
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ENCLOSURE 1B 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 Backcaround Carolina Power 6 Light Company (CPGL) 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.
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, NAD uses more performance-based methods to evaluate the attainment of quality.
This proposed change is submitted to allow NAD greater freedom to concentrate resources on performance issues and improvements.
The proposed change meets the CPGL 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 CPGL.
In the area of independent review, 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 CPGL nuclear facilities and ensure continued compliance with ANSI N18.7.
The provisions of 10 CFR 50.54(a)(1) require implementation of a QA Program as described in the Safety Analysis Report.
The recently submitted 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 QA Program description in the FSAR addresses the elements for an audit/assessment program identified in NUREG-0800, Section 17.3.
E1B-1 (2039GLU)
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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 change reduces the Technical Specification requirement to three dedicated reviewers.
The current requirement for a bachelor degree has been changed to a bachelor degree or equivalent.
The intent of the NUREG requirement will still be met by the site NAD Section.
Functions relative to operating experience feedback that were performed by this group have been transferred into the line organization in the Regulatory Affairs Section.
BASIS:
Combining the oversight functions of the PA Unit into the NAD Assessment Program will provide consistency among CP6L 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.
Changing the requirement from five engineers to three reviewers is consistent with the Standard Technical Specification requirement in Section 5.5.2 and provides for greater flexibilityin staffing the site NAD PA Section.
This Section is a multi-discipline group of engineers and technical specialists with experience in management, engineering, and technical specialties related to the operational activities of the Unit.
The makeup of the site NAD PA Section provides a broad experience base in both line and staff functions and a good diversity of discipline coverage.
Allowing an equivalency for the bachelor degree requirement provides consistency and flexibilityin staffing as allowed in our personnel qualification requirements.
Since NAD staffing utilizes rotational assignments from the line organization, this change will allow rotations with Shift Technical Advisors and Technical Support Engineers whose educational requirements are a bachelor degree or equivalent for the Harris Plant.
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."
BASIS:
The proposed change modifies the wording to provide consistency among CPGL nuclear facilities and ensure continued compliance with ANSI N18.7.
The proposed change makes working 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."-
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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 gA 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 NAD deleted this position and allows NAD to independently assess PNSC activities.
Section 6.5.3:
Nuclear Assessment Department Independent Review Program CHANGE:
6.5.3.2 Organization The proposed change modifies the wording and list of discipline areas to provide consistency among CPGL nuclear facilities and ensure continued compliance with ANSI N18.7.
Specifically the discipline area of "seismic and environmental" has been
- added, and the words "associated with the unique characteristics" have been deleted from Item "k."
BASIS:
The proposed change modifies the wording and list of discipline areas to provide consistency among CPGL nuclear facilities and to comply with the disciplines listed in ANSI N18.7.
The discipline area of "seismic and environmental" is a specific discipline area requiring specialized training and/or experience in order to conduct Independent Reviews 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 CPGL nuclear facilities and compliance with ANSI N18.7 in regards to education qualification.
Prior to License 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'he proposed change modifies the wording to provide consistency among CPGL nuclear facilities and ensure continued compliance with ANSI N18.7.
The proposed change maintains the same qualification/education requirements.
E1B-3 (2039GLU)
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, b, c, and g Review Current Sections 6.5.3.9.a, 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.a and 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 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 the term "REPORTABLE EVENTS" is defined in the TS, it is capitalized in the proposed Section 6.5.3.9.d.3.
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BASIS:
The proposed change modifies the wording to provide consistency among CPEcL nuclear facilities and ensure continued compliance with ANSI N18.7.
The proposed change maintains the same degree of review.
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 CPQL nuclear facilities and ensure continued compliance with ANSI N18.7.
The proposed change maintains the same degree of review.
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 CPGL 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 NAD.
In accordance with TS 6.5.2.8, the PNSC will forward its minutes to NAD so that the safety significant issues are identified.
CHANGE:
6.5.3.10 Review and 6.5.3.11.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 CP6cL 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.ll.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 CPQL nuclear facilities and ensure continued compliance with ANSI N18.7.
The corrective action program is a formalized program that identifies, priorities and responds to potentially adverse conditions that are identified by individuals or functional organizational units within CPGL.
CHANGE:
6.5.3.1l.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 Nuclear Generation Group.
The Chairman/President has been excluded from this presentation.
The Vice President Harris Nuclear Project and the Plant General Manager will receive a copy of the presentation.
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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 modifies the list of assessments and 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:
10 CFR 50.54(a)(l) requires implementation of a QA 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.
10 CFR 50.54(a) (1) requires implementation of a QA Program as described in the FSAR.
Section 6.10.3 CHANGE:
The proposed change splits Item "k" into two separate
- listings, Item "k" and Item "p."
BASIS:
This change provides clarity to the types of records that will be retained.
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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 10 CFR 50.92 EVALUATION The Commission has provided standards in 10 CFR 50.92(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 6 Light Company (CPEcL) 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
Carolina Power 6 Light Company 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.
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 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 E2-1 (2039GLU)
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increase in the probability or consequences of any accident. previously evaluated.
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 systemsi 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 system 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 10 CFR 51.22(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 nots (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 has reviewed this request and determined that the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(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
Carolina Power 6 Light Company 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 10 CFR 51.22(c)(9) for the following reasons:
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 CPGL 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, E3-1 (2039GLU)
the change cannot affect the types or amounts of any effluents that may be released off-site.
The proposed amendment does not result in'an increase in individual or cumulative occupational radiation exposure.
The proposed change is programmatic and only'evises Section 6, "Administrative Controls," of the Technical Specifications to reflect changes in the review and assessment of CPGL due to the creation of the NAD.
No additional surveillances or testing result from the amendment.
Therefore, the amendment has no effect on either individual or cumulative occupational radiation exposure.
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