ML20070Q368

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Safety Evaluation Supporting Amend 73 to License NPF-42
ML20070Q368
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 04/28/1994
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20070Q366 List:
References
NUDOCS 9405130154
Download: ML20070Q368 (4)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

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y sc c WASHINOTON D.C. 205 % 0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 73 TO FACILITY OPERATING LICENSE N0. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATIOR

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DOCKET NO. 50-482

1.0 INTRODUCTION

By application dated October 21, 1993, and supplemented by letters-dated March 14, 1994, and April 18, 1994, Wolf Creek Nuclear Operating Corporation (the licensee) requested changes to the Technical Specifications (Appendix A to facility Operating License No. NPF-42) for the Wolf, Creek Generating Station. The proposed changes would revise Technical Specification Sections 6.5.1, Plant Safety Review Committee (PSRC) and 6.8, Procedures and Programs, in order to allow implementation of a Qualified Reviewer Program for.the review and approval of new procedures and procedure changes.

2.0 EVALUATION The proposed changes relate to the review responsibilities of the PSRC described in Technical Specification 6.5.1.6 and the processes associated with the review and approval of procedures described in Technical Specification 6.8.

The current review responsibility of the PSRC includes all procedures and programs required by Technical Specification 6.8 and changes t. hereto.

The proposed change would reduce the number of PSRC procedure reviews to only those involving administrative control procedures and those requiring a 10 CFR 50.59 safety evaluation.

Changes.to Technical Specification 6.8 replace the current procedure review and approval process with the requirements needed for implementation of a Qualified Reviewer Program.

In addition, the proposed changes would delete items 6.5.1.6(i) and (j) related to PSRC reviews of the security plan and emergency plan.

The proposed Technical Specification 6.8.2 requires each new procedure or procedure change be reviewed by a Qualified Reviewer. A Qualified Reviewer is required to meet the applicable qualifications of ANSI /ANS 3.1-1978, " Standard for Selection and Training of Personnel for Nuclear Power Plants." The licensee's letter of March 14, 1994, provided a more precise reference to Section 4 of ANSl/ANS 3.1-1978 for the definition of the applicable qualifications for the Qualified Reviewers.

Certification as a Qualified Reviewer follows PSRC review of an individual's qualifications and is approved by the PSRC Chairman.

9405130104 940428 PDR ADOCK 05000482 P

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t Following review by a Qualified Reviewer, procedures, other than administrative control procedures, are approved by a responsible manager specified in the administrative control procedures. All required cross-disciplinary reviews of procedures or procedure changes are required to be completed prior to approval. Administrative control procedures and procedures requiring a 10 CFR 50.59 safety evaluation shall continue to receive PSRC review.

By letter dated March 14, 1994, the licensee provided additional information regarding the approval of procedures or procedure changes by the responsible manager or his designee.

The licensee stated that the proposed technical specifications would allow a manager to delegate the responsibility for approving procedures to a member of his supervisory staff directly responsible for the procedure.

The manager or designee approving a procedure or procedure change could not also be the initiator or reviewer of the procedure or procedure change.

The letter add essed the staff's concern that the use of the term "or his designee" could potentially result in a lack of management involvement in the procedural process.

The March 14, 1994, letter provided additional information and did not change the initial no significant hazards consideration determination published in the Federal Register on November 24, 1993.

The April 18, 1994, letter requested a change in the implementation period from 90 days to 120 days and did not change the initial no significant hazards consideration determination published in the Federal Register on November 24, 1993.

Temporary changes to procedures are governed by the proposed Technical Specification 6.8.3.

Limitations on the use of temporary changes include:

(1) the intent of the original procedure is not altered; (2) approval by at least two cognizant members of the licensee's staff, including at least one member of supervision, knowledgeable in the affected areas; (3) documentation, review and approval of the change as required by the proposed Qualified Reviewer process within 14 days of implementation.

Temporary changes to operations procedures will require at least one of the two approving personnel to hold a senior reactor operator license.

The above process differs from the recommendations of ANSI /ANS 3.2-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," Section 5.2.2, in that the standard does not exclude some temporary changes from requiring approval by a licensed senior reactor operator.

However, the proposed change basically maintains the requirements of the existing Technical Specification 6.8.3 related to the review and approval of temporary procedure changes.

Section 13.5.1, Administrative Procedures, of the Standard Review Plan (SRP) states that the staff should determine that:

"the applicant has described the program and procedures that provide administrative controls over activities important to safety.

These include the activities of the preparation, review, and approval of plant operating and maintenance procedures,..."

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The existing system at Wolf Creek which requires PSRC review of procedures and procedure changes was found to be acceptable during the initial licensing reviews documented in NUREG-0881, " Safety Evaluation Report Related to the Operation of Wolf Creek Generating Station, Unit No.1".

The implementation of a Qualified Reviewer Program is intended to allow improved utilization of managers serving on the PSRC and other members of the unit staff and expedite the procedure review process.

Details of the proposed Qualified Reviewer Program, including controlling administrative procedures and designation of personnel as qualified reviewers, will be reviewed and approved by the PSRC.

The PSRC will also continue to review other administrative control procedures and all procedures and procedure changes requiring an evaluation in accordance with 10 CFR 50.59.

Several nuclear facilities have implemented qualified reviewer programs similar to that proposed by the licensee.

The staff has determined that such programs may be adequate to provide administrative controls over activities important to safety related to the preparation, review, and approval of plant operating and maintenance procedures as required by applicable regulations and industry standards.

The licensee's proposed program has been determined to satisfy the requirements of ANSI /ANS 3.2-1976 as endorsed by Regulatory Guide 1.33, Revision 2, " Quality Assurance Program Requirements (Operation)." The proposed Technical Specification 6.8.3 related to temporary changes was determined to remain essentially the same as the original technical specification requirements approved in NUREG-0881.

The proposed changes to the technical specifications to allow implementation of a Qualified Reviewer Program are therefore acceptable.

In addition to the changes related to the implementation of the Qualified Reviewer Program, the licensee has proposed to delete the requirements for PSRC review of the security plan and emergency plan.

The NRC issued guidance to all holders of operating licenses for nuclear power reactors on the pro-posed change by Generic letter (GL) 93-07, " Modification of Technical Specification Administrative Control Requirements for Emergency and Security Plans" dated December 28, 1993.

The licensee proposed modifying Technical Specification 6.5.1.6 by removing items (i) and (j), which reference the security and emergency plans, respectively, and their implementing procedures under the review responsibilities of the PSRC. The licensee has proposed technical specification changes that are consistent with the NRC guidance in GL 93-07 and that eliminate technical specification provisions that duplicate the requirements in 10 CFR Parts 50 and 73.

The staff has reviewed this matter and finds that the proposed technical specification changes for Wolf Creek are acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Kansas State official was notified of the proposed issuance of the amendment.

The State official had no comments.

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4.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor:

W. D. Reckley Date:

April 28,1994 O