ML18011A508
| ML18011A508 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/22/1994 |
| From: | Orser W CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18011A509 | List: |
| References | |
| NL&RAS-94-050, NL&RAS-94-50, NUDOCS 9407290415 | |
| Download: ML18011A508 (35) | |
Text
REGULBTI INFORMATION DISTRIBUTIOI'ISTEM (RIDE) t ACCESSION NBR:9407290415 DOC.DATE: 94/07/22 NOTARIZED: YES FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH;NAME AUTHOR AFFILIATION ORSER,W.S.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET 05000400
SUBJECT:
Rev of 920806
& 930915 applications for amend to licen'se NPF-63,incorporating changes in nuclear assessment function
& results of NRC review of applications. Marked-up TS pages encl. Typed TS pages will be submitted later.
DISTRIBUTION CODE:'AOOID COPIES RECEIVED:LTR i ENCL J SIZE: gk++/
TITLE: OR Submittal:
General Distribution NOTES:Application for permit renewal filed.
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1 NOTE TO ALL"RIDS" RECIPIENTS:
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CPS'arolina Power & Light Company PO Box 1551 Raleigh NC 27602
~JUL 33 1984 W<lham S Ofsef Executive Vice President Nuclear Generation SERIAL: NL&RAS-94-050 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-PERFORMANCE BASED NUCLEAR ASSESSMENT PROGRAM
References:
1)
Letter dated August 6, 1992, from R. B. Starkey, Jr. (CP&L) to USNRC 2)
Letter dated September 15, 1993, from H. W. Habermeyer, Jr. (CP&L) to USNRC Gentlemen:
Carolina Power &, Light Company (CP&L) requested by the referenced letters a revision to the Technical Specifications (TS) for the Shearon Harris Nuclear Power Plant.
The proposed amendment would allow implementation of a performance based assessment program and corresponding functional and organizational changes in the Nuclear Assessment Department (NAD). In January 1994, CP&L requested that the NRC staff suspend their review of the proposed amendments pending further changes of the nuclear assessment function.
This letter provides a revised submittal incorporating the changes in the nuclear assessment function and the results of the NRC staff review of the referenced letters.
The major changes from the referenced submittals include the:
1)elimination of the NAD and the realignment of the Nuclear Assessment Section (NAS), reporting to the Vice President-Harris Nuclear Plant; 2) addition ofa two-year frequency cap on performance-based assessments; and 3) revised Independent Review and Independent Safety Engineering Group (ISEG) functions and organizations.
Although there are only a few changes, CP&L withdraws our previous submittals and provides this submittal in accordance with 10 CFR 50.90 and 2.101.
This submittal meets the criteria of a Cost Beneficial Licensing Action and represents a savings of approximately $ 1 million/year when fully.implemented at all of our nuclear plants
. Quality Assurance Program changes are being submitted by separate, letter (NL&RAS-94-049).
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p Document Control Des NL&RAS-94-050/Page The following enclosures are included with this letter:
Enclosure 1 - A summary ofthe proposed performance based assessment program and the corresponding organizational and f'unctional changes. - A summary of the proposed changes and the basis for each change. - CP&L's basis for determination that the proposed changes do not involve a significant hazards consideration. - CP&L's basis for determination that the proposed changes require no environmental assessment. -Marked-up TS pages. Typed TS pages will be submitted later.
CP&Lis providing, in accordance with 10 CFR 50.91(b), the state ofNorth Carolina with a copy of this license amendment request.
To allow orderly implementation of the proposed amendment, CP&L requests the amendments, upon approval by the NRC staff, be effective no later than 60 days from the issuance of the amendment.
Please refer any questions regarding this submittal to Mr. Gregg A. Sinders at (919) 546-7318.
Yours very tr ly, W. S. Orser GAS/ebc Enclosures c:
Mr. Dayne H. Brown (NC)
Mr. S. D. Ebneter (NRC-RII)
Mr. N. B. Le (NRR)
Ms. B. L. Mozafari (NRR)
Mr. J. E. Tedrow (NRC-SHNPP)
My commission expires:4/& QQ W. S. Orser, 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, and agents of Carolina Power &, Light Conggny>>
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ENCLOSURE I SHE<ARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 RE<QUE<ST FOR LICENSE AMENDME<NT PERFORMANCE-BASED NUCLEAR ASSKSSME<NT PROGRAM
SUMMARY
OF ORGANIZATIONALAND FUNCTIONALCHANGES Carolina Power and Light Company (CP&L) requests NRC approval of Technical Specification changes in order to implement the performance-based nuclear assessment program. Quality Assurance (QA) program changes are being requested by a separate letter.
This enclosure provides an informational summary of the functional and organizational changes.
Specific commitments are described in the Technical Specifications and QA Program description and not in this enclosure.
To improve the effectiveness and efficiency of the nuclear assessment (quality assurance/quality control) function, CP&L willmake both organizational and functional program changes.
Where no reduction in regulatory commitment is involved, CP&L will make the changes as allowed by 10 CFR 50.54(a)(3).
The majority of this submittal is similar to the original Teclmical Specification/QA program changes first submitted August 1992 and revised September 1993 after dialogue with NRC reviewers. CP&L withdraws the previous submittals.
The major changes from the previous submittals include:
- 1) elimination of the Nuclear Assessment Department (NAD) and realignment of the Nuclear Assessment Section (NAS) reporting to the Site Vice President; 2) addition of a 2 year frequency cap for performance based assessments; and
- 3) revised Independent Review (IR) and Independent Safety Engineering Group (ISEG) functions and organizations.
The purpose of the nuclear assessment reorganization is to:
Improve plant performance through strengthened self-assessment; Increase accountability for problem identification and effective corrective action within the plant organization; Strengthen the depth and scope of performance-based assessment; Improve translation of "lessons learned" throughout the Nuclear Generation Group; and Maintain senior management awareness of plant performance issues.
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p" Performance Evaluation Section A Performance Evaluation Section (PES), reporting to the Vice President - Nuclear Services Department (NSD), willbe established.
The PES willprovide a cadre of experienced assessment-trained, management-level, personnel to lead assessments and evaluate key areas of the plant and supporting organizations.
The primary functions of the PES are:
- 1) to independently assess the self-assessment and corrective action process of the line organization and the NAS; 2) to ensure that "lessons learned" are shared among the plants and support organizations; and 3) to facilitate the use of industry peer evaluators to identify industry best practices.
A PES-led self-assessment will be performed in each NRC Systematic Assessment of Licensee Performance (SALP) functional area once per SALP cycle. The PES evaluation teams will include peers from other CP&L plants and from the nuclear utility industry, as appropriate, to lend expertise to the self-assessment.
Self-assessment is a broad term, covering everything from self-checking to formal, documented evaluations of plant performance in a specific area, such as work control management.
PES-led self-assessments willbe documented evaluations. CP&L's three nuclear plants have adopted self-assessment as a way of doing business. The readiness for plant startup process is a good example of formal self-assessment.
CF&L seeks to improve the formal self-assessment process by means of PES-led evaluations. The technical expertise of peer assessors coupled with the assessment skills of the PES assessors is expected to provide solid evaluations. Equally important, the assessment training instilled in the peer evaluators during the course of an assessment and the knowledge gained of plant practices at other CP&L plants by the peers willbe most valuable.
The PES willby procedure evaluate the effectiveness of the site's self-assessment
- program, the site's ability to incorporate lessons learned from within CP&L as well as industry events, and the site's corrective action program.
In addition to traditional assessment reports, this program willbe facilitated by periodic peer group meetings between the PES Manager and each plant NAS Manager.
There willalso be periodic conference calls between these individuals during which operational experience and plant issues are discussed.
Written PES evaluations, including the results and recommended corrective actions, will be reported to plant and senior management.
The current Vendor and Equipment Quality function and the Quality Check (employee concern) program willbe reassigned from the NAD to the NSD, where it willreport to the Manager-PES.
The realignment of corporate functions and reporting relationships are shown in Attachment 1A.
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The benefits from the establishment of the PES include:
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Senior management willbe informed of plant performance issues by an organization outside the plant line chain of command.
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An independent check of the NAS performance will be provided.
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Peers from other CP&L plants and from the nuclear utility industry, as appropriate, will be used on evaluation teams.
The evaluation process willprovide an additional means of exchanging operational experience among CP&L plants and other utilities.
Evaluations will emphasize the key attributes of self-assessment, corrective action, and sharing of operating experience.
Nuclear Assessment Section The proposed reorganization eliminates the NAD and realigns the plant NAS, reporting to the Site Vice President. The assignment ofNAS as a direct report provides a valuable resource to the person held fully accountable for plant performance. The NAS will continue to conduct performance-based assessments to meet the 10 CFR 50, Appendix B, regulatory-required audits, and will assess to the Institute for Nuclear Power Operations (INPO) performance standards rather than minimum compliance standards.
The NAS Manager willreport to the most senior CP&L manager on site, the Site Vice-President. This will ensure independence from the plant production organization.
Other nuclear utilities have developed similar organizational arrangements for their quality assurance organizations.
The NAS has been aligned consistent with the current NRC Systematic Assessment of Licensee Performance (SALP) categories.
The NAS organization is provided for your information in Attachment 1B. The responsibilities for the Plant Operations and Plant Support Units are discussed below:
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Plant Operations - responsible for Operations, Maintenance, and Engineering and Technical Support.
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Plant Support - responsible for Environmental and Radiation Control and other support areas such as Emergency Preparedness, Security, Document Control, and Material Control.
This realignment willnot diminish the emphasis on engineering and technical support within the section. In evaluating the workload of assessors in conjunction with the reorganization, it was determined that having two Engineering/Technical Support Project Engineers in the Operations Unit, coupled with the other engineering and related science personnel within the NAS was sufficient to meet the needs of the assessment, ISEG, and IR functions.
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The NAS has highly qualified, experienced engineers at each plant.
Further, these NAS engineering positions are rotational.
The engineers and other NAS assessors are expected to rotate back into the line organization in two to five years.
Thus, the engineering, operations, and maintenance expertise willstay current.
The NAS assessment process willremain consistent with that presently performed by the plant NAD sections.
One benefit of the current process has been the use of peers from other plants during evaluations.
As described in the PES peer discussion, the NAS assessment process also facilitates the exchange of information among CP&L plants.
The NAS will use CP&L peer engineering personnel and, ifnecessary, outside consultants, where specialized expertise is needed to ensure engineering areas are properly evaluated.
Upon NRC approval, the IR function willbe reassigned from the NAD to the plant NAS. IR is currently performed by four engineers.
Normally, one of the four engineers is assigned to plant special assessments.
Effectively, there is one engineer per site performing IR. The reassignment would put one IR Project Engineer in each NAS, reporting to the Manager-NAS.
Documents requiring IR are currently reviewed by three separate engineers, through a three party review process, designed to ensure review by the appropriate discipline.
CP&L is proposing a revision to this process which is consistent with ANSI N18.7, which requires review by the appropriate discipline.
In the event the IR Project Engineer does not have the appropriate discipline background to review a specific document, he will obtain the required discipline expertise from within the NAS, and, ifnecessary, outside NAS to ensure the proper review is completed.
The Harris Nuclear Plant (HNP) has a requirement to have an ISEG. This function is presently met by the HNP NAD section.
CP&L is proposing to overlap the IR function with the ISEG and assessment/audit functions at the HNP. Combining these functions willprovide consistency among CP&L nuclear plants in the way these responsibilities are being implemented.
CP&L believes that individuals performing the 10 CFR 50, Appendix B assessment and IR functions can concurrently fulfill the requirements of the ISEG function. The NAS has experienced personnel, who have engineering or related science degrees to carry out the IR function.
The IR function will complement the ISEG function at the Harris Plant.
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The benefits of the NAS reorganization include:
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Provides an additional tool to the Site Vice President for assessing and improving plant performance; Provides greater plant accountability for improved performance;.
Closely links the nuclear assessment function to plant needs; Provides for an independent assessment of plant performance since the NAS is outside the normal plant manager line function chain of command; Promotes line self-assessment;
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Uses expertise from other CP&L plants;
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Facilitates plant personnel assignments to other CP&L assessment teams; and
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Enhances personnel development by facilitating and stimulating rotation with the plant organization.
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Significant Technical Specification/QA Program Functional Chan es Nuclear Assessment audits will be conducted at a frequency consistent with plant performance.
In no case willthe assessment (audit) cap of 24 months be exceeded.
CP&L willnot change its audit frequency limits until the 24 month cap is approved by the NRC in response to this request.
The bimonthly report ofNAD issues is proposed to be revised to a periodic briefing ofNAS issues to senior management.
This willbe normally done at the plant management review meeting.
Nuclear Assessment issues willbe discussed, including a review by the manager responsible for the corrective action.
The technical specification change details the transfer of the IR function from corporate NAD to the plant NAS. The IR function willbe integrated into the NAS organization, which at the Harris Nuclear Plant, is responsible for conduct of the ISEG function. The makeup ofNAS personnel provides a broad experience base and diversity of academic/engineering disciplines for ISEG, IR, and the 10 CFR 50, Appendix B assessment functions.
IR will be performed in the applicable discipline(s) by qualified reviewers per applicable ANSI N18.7 requirements instead of the current three party review now performed for each plant. Should the IR Project Engineer not have the required discipline background to review a specific document, he willobtain the required discipline expertise from other qualified NAS reviewers, including going outside NAS, ifnecessary.
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Proposed Nuclear Services Department Organization Nuclear Generation Group Vice-President Nuclear Services Department Manager Performance Evaluation Other Section Managers Manager Vendor&
Equipment Quality Principal Engineers Nuclear Assessment*
Quality Check Senior Specialists*
Tech Assistant I Senior Specialists/
Senior QA Engineers A
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HNP Proposed Nuclear Assessment Section Site Vice President Executive Vice President, Nuclear Generation Manager Nuclear Assessment Project Engineer (independent Review)
Secretary Manager Plant Operations Assessment Manager Plant Support Assessment QC Supervisor Project Engineer (Engffech Supt)
Principal Engineer Nuclear Assessment (Operations)
Principal Engineer Nuclear Assessment (E&RC)
Clerk QC Technicians project Engineer (Engffech Supt)
Principal Engineer Nuclear Assessment (Ops/Maintenance)
Project Engineer NDE Technicians Principal Engineer Nuclear Assessment (Maintenance)
Senior Engineer B Engineering Tech I 7/22/94
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E<NCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE< NO. NPF-63 REQUEST FOR LICE<NSE AME<NDMENT PERFORMANCE BASED NUCLEAR ASSESSMENT PROGRAM
SUMMARY
OF PROPOSED CHANGES AND BASIS FOR EACH CHANGE< RE<
UK<ST 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 6.2.3.
The Independent Safety Engineering Group (ISEG) functions described in the current section related to oversight and assessment of unit operations and activities, have been integrated into Section 6.5.4 (Nuclear Assessment Section Assessment Program).
NUREG-OS00, Standard Review Plan, paragraph 13.4 states the Independent Review (IR) and ISEG functions are to be performed by separate groups.
CP&L requests exception to this guidance to combine these functions into the Nuclear Assessment Section (NAS). The NAS willperform the 10 CFR 50, Appendix B assessments, the ISEG functions and will conduct Independent Reviews as required by ANSI N18.7.
NUREG-0737, Item I.B.1.2 requires five dedicated engineers to staff the ISEG function.
CP&L proposes'hat three individuals perform the ISEG function concurrent with other assessment functions.
The current requirement for a bachelor's degree in engineering or related science has been changed to a bachelor's degree in engineering or related science or equivalent.
BASIS: Combining the ISEG, Independent Review(IR) and the 10 CFR 50, Appendix B assessment functions willprovide consistency among CP&L nuclear plants in the way these responsibilities are being implemented.
CP&L believes that individuals performing the 10 CFR 50, Appendix B assessment and IR functions can concurrently fulfillthe requirements of the ISEG function.
Changing the requirement from five engineers provides for greater efficiency in staffing this function.
The NAS 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 plant.
The makeup of the NAS provides a broad experience base and good diversity of discipline coverage for performing ISEG, IR and 10 CFR 50, Appendix B assessment functions.
Allowing an equivalency for the bachelor's degree requirement provides consistency and flexibilityin staffing as allowed in our personnel qualification commitments for other equivalent positions.
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Section 6.5.1.4:
Safety Evaluations and Approvals CHANGE: The proposed changes to 6.5.1.4.3; 6.5.1.4.5; 6.5.2.6; 6.5.2.6.h; 6.5.3.1; 6.5.3.3; 6.5.3.4; 6.5.3.5; and 6.5.3.8 reflect the organizational title of the NAS.
BASIS: The proposed reorganization eliminates the Nuclear Assessment Department and creates the NAS reporting to the Vice President - Harris Nuclear Plant.
The changes to organizational titles reflect the proposed organization.
CHANGE: The proposed change to 6.5.1.4.5 revises the phrase "subject action involves a change in the Final Safety Analysis Report" to "modifications, procedures, tests or experiments which constitute a change to the facility as described in the Final Safety Analysis Report."
BASIS: The proposed change modifies the wording to provide consistency among CPAL nuclear plants and is consistent with ANSI N18.7.
This is also consistent with 6.5.3.9.a which identifies the scope of Independent Review.
Section 6.5.2:
Plant Nuclear Safety Committee (PNSC)
CHANGE: The proposed change to 6.5.2.6.e, and k revises the organizations to which the PNSC distributes reports of their reviews for the purpose of further review and/or information.
BASIS: The proposed reorganization includes the elimination of the Manager-Nuclear Assessment Department and creates the NAS, which reports to the Vice President - Harris Nuclear Plant.
The Vice President - Harris Nuclear Plant will continue to receive these reports.
Nuclear Assessment will continue to see these reports as a member of the PNSC.
CHANGE: The proposed change to 6.5.2.7.b deletes the Manager - Nuclear Assessment Department from receiving notification of disagreements between the Plant General Manager and the PNSC.
Also, the words Harris Nuclear Project are changed to Harris Nuclear Plant.
BASIS: The proposed reorganization includes the elimination of the Manager-Nuclear Assessment Department and creates the NAS, which reports to the Vice President - Harris Nuclear Plant.
The other change is an editorial change to reflect current organizational titles.
CHANGE: The proposed change to 6.5.2.8 modifies the distribution of PNSC minutes from Manager - Nuclear Assessment Department to the Manager - Nuclear Assessment Section.
BASIS: This is an editorial change to reflect the proposed organizational titles.
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Section 6.5.3:
NAS Independent Review Program CHANGE: The proposed change to 6.5.3.2 modifies the list of discipline areas.
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 CP&L nuclear plants and is consistent with the disciplines listed in ANSI N18.7. The current Independent Review process requires review in these areas.
CHANGE: The proposed change to 6.5.3.3 and 6.5.3.4 changes the term "baccalaureate degree" to "bachelor's degree."
BASIS: The proposed change provides consistency among CP&L nuclear facilities.
t CHANGE: The proposed change to 6.5.3.6 modifies the review process of the Independent Review function.
BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and is consistent 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 necessarily ensure appropriate reviews are performed.
CHANGE: The existing requirements of 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 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 changes modify the wording to provide consistency among CP&L nuclear plants and is consistent 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.
CHANGE: The existing requirement of 6.5.3.9.d is contained in the proposed 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 plants and is consistent with ANSI N18.7.
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CHANGE: The existing requirement of 6.5.3.9.e is contained in proposed 6.5.3.9.d.1 and 6.5.3.9.d.2 due to reformatting.
Violations that require reporting to the NRC in writing willrequire an Independent Review.
BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and is consistent with ANSI N18.7.
CHANGE: This existing requirement of 6.5.3.9.f is contained in the proposed 6.5.3.9.d.3 due to reformatting.
BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and is consistent with ANSI N18.7.
The proposed change maintains the same degree of review.
CHANGE: The existing requirements of 6.5.3.9.h and 6.5.3.9.i are moved to the proposed 6.5.3.9.f and 6.5.3.9.e, respectively.
BASIS: The proposed changes modify the wording to provide consistency among CP&L nuclear facilities and is consistent with ANSI N18.7.
The proposed change maintains the same degree of review.
CHANGE: The existing requirements of 6.5.3.9.j are being deleted.
This required that a formal Independent Review be performed of the reports and minutes of the PNSC.
BASIS: The proposed change eliminates PNSC reports and minutes from formal Independent Review to provide consistency among CP&L nuclear facilities and is consistent with ANSI N18.7.
In accordance with TS 6.5.2.8, the PNSC willforward its minutes to NAS so that the safety significant issues are identified.
CHANGE: The existing requirements of 6.5.3.10 and 6.5.3.11.a are combined under the proposed Section 6.5.3.10 due to reformatting.
BASIS: The proposed change modifies the wording to provide consistency among CP&L nuclear facilities and is consistent with ANSI N18.7.
Any identified adverse conditions resulting from Independent Reviews are addressed as part of the Corrective Action Program (CAP).
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CHANGE: The existing requirements of 6.5.3.11.b and c are deleted.
BASIS: The requirement of 6.5.3.11.b is deleted because any identified adverse conditions resulting from independent reviews are addressed as part of the CAP. The CAP is a formalized program that identifies, prioritizes, and responds to potentially adverse conditions that are identified by individuals or functional organizational units within CP8cL.
The CAP is required by the QA Program and does not need to be included in the Technical Specifications.
The reporting requirements of 6.5.3.11.c are part of the QA Program and do not need to be included in the Technical Specifications.
Section 6.5.4: NAS Assessment Program CHANGE: The proposed change to 6.5.4 describes the Performance Based Assessment Program of the NAS and incorporates the requirements of 6.2.3 (ISEG).
The change revises the existing frequency based assessment program to a performance based assessment program with a frequency cap of 24 months.
Also, the specific details of existing 6.5.4.2 through 6.5.4.8 have been deleted.
BASIS: The modification of assessment frequencies willallow assessments to be scheduled on the basis of plant performance.
This change is consistent with NRC guidance in Section 17.3 of NUREG-0800, Standard Review Plan.
The specific details of 6.5.4.2 through 6.5.4.8 are addressed in the QA program and are commitments to Regulatory Guide 1.144.
Section 6.5.5:
Outside Agency Inspection and Audit Program CHANGE: The proposed change deletes this section.
BASIS: The QA Program description in the FSAR addresses the elements of an Assessment Program identified in NUREG-0800, Section 17.3, and includes a requirement for a Fire Protection Assessment.
10 CFR 50.54(a)(1) requires implementation of a QA Program as described in the FSAR.
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Sections 6.6 and 6.7:
Reportable Events and Safety LimitViolations CHANGE: The proposed changes to 6.6.1.b and 6.7.1.a & c revises the Manager-Nuclear Assessment Department to Manager - Nuclear Assessment Section from distribution for Reportable Events and Safety LimitViolations.
The proposed change to 6.7.1.a deletes the Manager-Nuclear Assessment Department from 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification of Safety LimitViolations.
BASIS: The proposed changes to 6.6.1.b and 6.7.1.a & c are editorial changes to reflect proposed organizational titles.
The Manager - Nuclear Assessment Section is on distribution for the purpose of Independent Review.
The change to 6.7.1.a is proposed because the Manager - Nuclear Assessment Section receives a copy of the Safety LimitViolation Report per 6.7.1.c and willreview this information as a member of the PNSC.
Section 6.10.3 CHANGE:
The proposed change to 6.10.3 modifies the list of records to be retained for the duration of the license.
The proposed change splits Item "k" into two separate listings Item "k" and Item "p."
BASIS:
The proposed change maintains the same type of records and retention requirements.
This is an editorial change that clarifies the types of records that will be retained.
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ENCLOSURE 3 SHEARON HARRIS NUCLE<AR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE< NO. NPF-63 REQUEST FOR LICENSE AMENDMENT PERFORMANCE BASED NUCLEAR ASSESSMENT PROGRAM 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 ifoperation 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
The proposed amendment would implement a performance based assessment
- program, including the corresponding functional and organizational changes.
Specifically, the changes affect the Independent Review (IR) function, the independent assessment of plant activity, and the Independent Safety Engineering Group.
These functions will be performed by the proposed Nuclear Assessment Section (NAS).
The NAS, as proposed, would perform internal evaluations and assessment activities and serve as plant management's staff for the objective oversight of plant performance relating to nuclear safety, reliability, and quality.
The Section's fundamental role is to:
- 1) assist plant management in the early identification of issues which may prevent the Harris Plant from achieving quality performance on a sustained basis; and 2) ensure effective correction of deficiencies.
Basis The change does not involve a significant hazards consideration for the following reasons:
The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated because it is a programmatic and administrative change which 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 an increase in the probability or consequences of any accident previously evaluated.
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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 a programmatic and administrative change which 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.
The proposed amendment does not involve a significant reduction in the margin of safety because it is a programmatic and administrative change which provides assurance that plant operations continue to be conducted in a safe manner through the performance based assessment programs.
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 a significant reduction in the margin of safety.
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E<NCLOSURE 4 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKE<T NO. 50-400/OPERATING LICENSE NO. NPF-63 RE<QUEST FOR LICENSE AME<NDMENT PERFORMANCE< BASED NUCLEAR ASSE<SSMENT PROGRAM ENVIRONME<NTALCONSIDE<RATION 10 CFR 51.22(c)(9) provides criteria 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.
CPAL has reviewed this request and determined that the proposed amendment meets the eligibilitycriteria 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
The proposed amendment would implement a performance based assessment
- program, including corresponding organizational and functional changes.
Specifically, the changes affect the Independent Review (IR) function, the independent assessment of plant activity and the Independent Safety Engineering Group.
These functions will be performed by the proposed Nuclear Assessment Section (NAS).
The NAS, as proposed, would perform internal evaluations and assessment activities and serve as plant management's staff for the objective oversight of plant performance relating to nuclear safety, reliability, and quality. The Section's fundamental role is to:
- 1) assist plant management in the early identification of issues which may prevent the Harris Plant from achieving quality performance on a sustained basis; and 2) ensure effective correction of deficiencies.
Basis This change meets the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) for the following reasons:
1.
As demonstrated in Enclosure 3, 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.
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The proposed change is programmatic and only revises Section 6, "Administrative Controls," of the Technical Specifications to reflect changes in the review and assessment function of the proposed NAS. 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.
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 function of the proposed NAS. No additional surveillances or testing which could increase personnel exposure result from the amendment.
Therefore, the amendment has no effect on either individual or cumulative occupational radiation exposure.
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