ML20045E825

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Revised Selected Licensee Commitments Manual
ML20045E825
Person / Time
Site: Catawba  Duke Energy icon.png
Issue date: 06/23/1993
From: Nicholson K
DUKE POWER CO.
To:
References
PROC-930623, NUDOCS 9307060101
Download: ML20045E825 (13)


Text

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ll l Duke h>urr Cornparty (803)831-3000 Carmrba Nucieur Station 4M0 Concord Road f~ York. SC29745 kJ DUKEPOWER June 23, 1993 RE: Catawba Nuclear Station Selected Licensee Commitments Effective 06/23/93 Attached are revisions to the Catawba Nuclear Station Selected Licensee Commitments. Please revise your copy as follows:

Remove Insert LOEP Page 1 (01/01/93) Page 1 (06/23/93)

Page 7 (12/92) Page 7 (06/23/93)

Chapter 16.0 Page 16.0-1 (12/90) Page 1 (06/23/93) -

Chapter 16.1 Page 16.1-1 Page 1 (06/23/93)

Appendix Station Directive 3.1.5 Compliance Functional Area Manual, Section 3.8 (' ' "' ' ' o 2 )

(03/09/93) g Any questions concerning this revision should be directed to the undersigned at 803-831-3237.

Kay . Nicholson Regulatory Compliance i

Attachments 1 A

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4 DUKE POWER COMPANY O' SELECTED LICENSEE COMMITMENTS MANUAL ,

List of Effective Pages Page Revision Date ,

LOEP 1 06/23/93 I LOEP 2 12/29/92 LOEP 3 12/29/92 ,

LOEP 4 01/01/93  ;

LOEP 5 01/01/93 4 LOEP 6 01/01/93 LOEP 7 06/23/93 6

Tab 16.0 _

16.0-1 06/23/93 O Tab 16.1 9 16.1-1 06/23/93 Tab 16.2 16.2-1 11/91 16.2-2 11/91 16.2-3 11/91 Tab 16.3 16.3-1 11/91 i

16.3-2 11/91 Table 16.3-1 11/91 ,

Tab 16.4 O

Page 1 06/23/93 l

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  • i DUKE POWER' COMPANY.  !

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SELECTED LICENSEE COMMITMENTS MANUAL i List of Effective Pages ,

Page Revision Date  ;

Tab 16.13 16.13-0 12/90  ;

16.13-1 12/90 Tab 16.14  ;

Tab 16.15 ,

Appendix ,

t Compliance Function Area Manual, Section 3.8

" Selected Licensee Commitments" ,

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[~ CATAWBA NUCLEAR STATION

. FINAL SAFETY ANALYSIS REPORT SELECTED LICENSEE COMMITMENTS Table of Contents 16.0 Selected Licensee Commitments i 16.1 Introduction .

1 16.2 Applicability i 16.3 Definitions  ;

16.4 Commitments Related to Reactor Components 16.5 Commitments Related to Reactor Coolant System i

16.6 Commitments Related to Engineered Safety Features.

(Non-ESF Systems) l 16.7 Commitments Related to Instrumentation 16.8 Commitments Related to'~ Electrical Power Systems 16.9 Commitments Related to Auxiliary Systems

-O 16.9-1 Fire Suppression Water Systens 16.9-2 Spray and/or Sprinkler Systems 16.9-3 CO, Systems 16.9-4 Fire Hose Stations i

16.9-5 Fire Barrier Penetrations 16.9-6 Fire Detection Instrumentation i

16.10 Commitments Related to Steam and Power Conversion Systems 16.11

  • Commitments Related to Radioactive Waste Management l

16.12 Commitments Related to Radiation Protection l 16.13 Commitments Related to Conduct of Operations f 16.13-1 Fire Brigade 16.14 Commitments Related to Refueling Operations Appendix Compliance Functional Area Manual, Section 3.8

  • t CHAPTER 16.0 Page 1 06/23/93 1

i 16.0 S_ elected Licensee Commitments 16.1 Introduction COMMITMENT:

This chapter provides a single location in the FSAR where certain selected licensee commitments (SLC) are presented. The content of this chapter is based on the results of application of a set of criteria to determine. the content of technical specifications. For purposes of administrative ease, this chapter is maintained in a separate manual, The Catawba Nuclear Station Selected Licensee Commitment Manual. Those previous technical specification requirements which did not meet the criteria are relocated in this chapter. Catawba Technical Specification 6.8 (Procedures and Programs) requires written procedures to be established, implemented, and maintained on those selected licensee commitments. .

The control of the Catawba Nuclear Station SLC program and manual shall be accordance with Section 3.8 of the Compliance Functional i Area Manual, " Selected Licensee Commitments", and is included in  ;

I this manual as the Appendix. The manual is officially designated as Chapter 16 of the Catawba FSAR. The original issue and subsequent revisions of the manual are approved by the station manager. Administrative requirements of the manual are the responsibility of the site Regulatory Compliance section. l Changes to these SLC may be made, pursuant to 10 CFR 50.59, only i after the bases for the requirement have been clearly established and after a multi-disciplinary review by qualified reviewers, includiqq onsite operation's personnel (52FR3788, February 6,1987, Interim >7olicy Statement on Technical Specification Improvements for Nuclear Power Plants).

Additional operational related commitments, as selected by the station manager or designee may be located in this chapter. It is the intent of this chapter to provide information regarding systems ,

that are a part of the licensing basis, as described in the FSAR, but are not of such a level of importance that they need to be ,

under the rigorous control provided by technical specifications.

This chapter includes testing requirements for pertain systems, and '

remedial actions to be taken in the event the system is not fully capable of performing its design function. A bases for the  ;

commitment is also provided. Reference is also provided to specific sections of the FSAR where the information relative to the ,

commitment is further described.

O CHAPTER 16.1 Page 1 06.'23/93 l

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O DUKE POWER COMPANY COMPLIANCE MANUAL i

Section 3.8 Selected Licensee Commitments ,

i Revision Number Effective Date i O 3/9/93  !

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Approved By: ,

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, Regulatory Compliance Manager I 1

i MCGUIRE j f Neh. , Regulatory Compliance Manager

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[d O , Regulatory Compliance Manager NUCLEAR SERVICES S

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Compliance Functional Area Manual Rev.0 ,

3.8 SELECTED LICENSEE COMMITMENTS ,

3.8.1 Purpose .

The purpose of this section is to describe the organization, responsibilities, implementation, and documentation of the process used to control Selected l Licensee Commitments (SLCs) identified in Chapter 16 of each nuclear station's [

Final Safety Analysis Report (FSAR). During the initial licensing process and  :

during the operating life of a nuclear station, regulatory commitments are made to the~ Nuclear Regulatory Commission (NRC) by the licensee. Some of these '

commitments may involve activities which affect the safe operation of systems and  ;

equipment of the nuclear station. This program provides a process to identify and i implement selected licensee commitments which help ensure a high level of safety, operability and maintainability of a nuclear station. This program defines the l means used at Duke Power to ensure compliance with the Interim NRC Policy

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Statement on Technical Specification Improvements. Specifically, this program  ;

provides the means of' controlling those items removed from station Technical Specifications, but it may also be used to control other important operational commitments as deemed appropriate by station management.  !

3.8.2 References 3.8.2.1 Each Nuclear Station's Final Safety Analysis Report 3.8.2.2 Each Nuclear Station's Technical Specifications  ;

3.8.2.3 Nuclear Policy Manual 3.8.3 Description  :

3.8.3.1 SLCs are commitments to control important plant equipment and operating conditions not controlled elsewhere. Operational commitments ,

which are to be removed from existing station Technical Specifications ,

may be included in the Selected Licensee Commitment program. ' Also -

included in this program will be selected NRC commitments contained

~ i in licensing documents such as the station's SERs, LERs, violation  ;

responses, Generic Letter and Bulletin responses, submittal documents or other Duke letters to the NRC.

3.8.3.2 These commitments shall include the Commitment (corresponding to the Limitbg Condition for Operation), the . Applicability, the Remedial Action (or Action - ONS) (corresponding to the Action Statement), the O  :

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' Compliance Functional Area Manual - 3.8 Selected Licensee CommKments .

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Testing Requirements (or Surveillance - ONS) (corresponding to the -

Surveillance Requirements), a list of References, and a Bases.

3.8.3.3 The SLCs shall comprise Chapter 16 of each nuclear station's Final Safety Analysis Report. However, for user convenience, they will be i located in a separate binder. These documents are entitled Selected Licensee Commitment Manual, Final Safety Analysis Report, Chapter 16.0.

3.8.3.4 Station activities required by commitments identified under this program shall be carried out by approved procedures and/or directives. Some commitments may require a revision to the Nuclear Policy Manual (NPM). In either of these alternatives, the appropriate NPM provisions  !

shall be followed for completion of the activities.

3.8.3.5 A continuous update of the Selected Licensee Commitment program ..

shall be instituted to ensure that future commitment documents submitted to the NRC are reviewed for inclusion in this program. Selected licensee commitments selected for control, by station management,.

q under the program shall be identified, tabulated and discussed, as Q necessary. ,

3.8.4 Specific Responsibilities 3.8.4.1 The Regulatory Compliance Manager 3.8.4.1.1 The Regulatory Compliance Manager shall have the primary responsibility for coordinating and updating the-l Selected Licensee Commitments to reflect station activities described in FSAR Chapter 16. i a

3.8.4.1.2 The Regulatory Compliance Manager shall be responsible '

for coordinating any review activities associated with the a' SLCs.

3.8.4.1.3 The Regulatory Compliance Manager shall be responsible ,

for ensuring that other appropriate commitments are included in this program.

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I f', Compliance Functional Area Manual 3.8 Selected Licensee Commitments l A. Rev'. 0 3.8.4.1.4 The Regulatory Compliance Manager shall be msponsible for maintaining and controlling the ~ station's Selected ' .;

Licensee Commitment Manual.

3.8.4.2 The Station Manager l 3.8.4.2.1 The Station Manager shall be responsible for approval of SLCs.

3.8.4.2.2 The Station Manager shall ensure that the SLCs described j in this program are implemented at the s'ation. .

3.8.4.2.3 The Station Manager shall ensure ' that SLCs are accomplished in accordance with approved established  ;

schedule.

3.8.4.2.4 The Station Manager shall institute means to identify and iss.ue additional SLCs generated within the station or change (s) to existing SLCs within the station organization.

3.8.4 Documentation 3.8.4.1 Documentation associated with the activities described in this program  !

shall be maintained in an identifiable and retrievable manner. All documentation accompanying each SLC and changes thereto will be filed in Master File.

3.8.S Creating a New Selected Licensee Commitment  ;

3.8.5.1 New SLCs may be created for programmatic commitments by sending a written request to the Regulatory Compliance Manager. Details of different requests may vary widely. However, the request must include, .

but is not limited to, the following information.

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3.8.5.1.1 An exact . statement of the proposed commitment to be made to the NRC. 6 i

3.8.5 l.2 References where the commitment is documented. I 3.8.5.1.3 Justification as to why the commitment is to be made, and why it should be included in the SLC program.

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O . Con)pliance Functional Area Manual 3.8 Selected Licensee Commitments Rev.0 3.8.5.1.4 A detailed explanation of what is required to meet the -

l commitment. For example, what equipment is required -  ;

to be operable, and what surveillances must be done to ~

ensure operability.

3.8.5.1.5 Any required. or suggested remedial actions to be -l performed if surveillances fail, or commitments are not .

met. -

i 3.8.5.2 Any questions should be . addressed to 'the Regulatory Compliance  !

Manager, 3.8.5.3 A 10 CFR 50.59 evaluation should be completed on the proposed - i commitment. ,

i 3.3.6 Proposed Changes To Existing SLCs 1 3.8.6.1 Changes may be proposed by any person qualified to ensure that.the -

change is appropriate. This may be any NGD employee, an employee of another Duke department, or a vendor employee. The preparer is f~}~

k , responsible for providing a detailed justification _for the proposed 1 change, and for obtaining a review of a Qualified Reviewer. ,

3.8.6.2 A 10 CFR 50.59 evaluation should be completed for the revised commitment.

3.8.6.3 The basis of the existing requirement must be discussed in addition to the basis for the proposed change. The proposed change in the form for a mark-up showing the present SLC along with the rcquested changes will then be forwarded to the Regulatory Compliance Manager.

3.8.7 SLC Review / Approval Process -  !

3.8.7.1 The Regulatory Compliance Manager or designee will review the request  ;

for a new SLC or proposed change to an existing SLC, and resolve ,

problems if necessary, and send the proposal to all affected groups for review and comment.

j 3.8.7.2 Any proposed SLCs or proposed changes to existing SLCs shall be reviewed by the Regulatory Compliance Manager or designee against the Pige 4 of 5 e.g -

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i Compliante Functional Area Manual 3.8 Selected Licensee Commitments Rev.O Facility-Operating License to ensure that proposed changes do not l violate the subject license conditions. l 3.8.7.3 The Regulatory Compliance Manager or designee will ensure that GO i Nuclear Licensing Services is consulted on all matters which might be -

generic or which might impact other Duke nuclear plants. j 3.8.7.4 When all comments have been collected and incorporated or resolved, l the. Regulatory Compliance Manager or designee will submit the  ;

proposal to the Station Manager for approval. .i 3.8.7.5 All proposed new SLCs and any proposed change that directly affects I the COMMITMENT, APPLICABILITY, TESTING REQUIREMENTS  ;

(or SURVEILLANCE - ONS), or REMEDIAL ACTION (or ACTION -  !

ONS) sections of an existing SLC, will be forwarded by Regulatory -

Compliance to the Chairman of the NSRB for review. However, '

implementation need not wait on completion of this review. ,

3.8.7.6 - Upon approval by the Station Manager, the new or revised SLC (with' approval date, month and year at the bottom right hand corner of each i page) will be forwarded to Master File. A venical line in the right hand margin will indicate revisions. The approved SLC will become effective ,

when placed in the Control Room copy unless stated otherwise in the change itself. The Table of Contents in addition to the List of Effective Page (LOEP) will be updated to reflect the new or revised SLCs.

3.8.7.8 The Regulatory Compliance Manager or designee will notify each 3 affected group to inform them of the approved SLC. l 3.8.7.9 All documentation accompanying each SLC or change thereto will be ';

filed in Master File. .

3.8.8 Distribution 3.8.8.1 Copies of the SLCs are made single sided and three hole punched. A I cover letter indicating the proper procedure for updating the SLC listing  ;

the pages to be discarded and the replacement new pages must be included.

3.8.8.2 The Selected Licensee Commitments Manual is a controlled document and all new and revised SLCs will be distributed to all designated '

holders of this manual. i Page 5 of 5 r

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