ML20077S565
| ML20077S565 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 01/18/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20077S557 | List: |
| References | |
| GL-93-07, GL-93-7, NUDOCS 9501240149 | |
| Download: ML20077S565 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION 5
I WASHINGTON, D.C. was -3
%.....j SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.222 TO FACILITY OPERATING LICENSE NO. DPR-59 POWER AUTHORITY OF THE STATE OF-NEW YQE JAMES A. FITZPATRICK NUCLEAR POWER PLANT
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QQQ(ET NO. 50-333
1.0 INTRODUCTION
By letter dated June 17, 1994, as supplemented December 2,1994, the Power Authority of the State of New York (the licensee) submitted a request for changes to the James A. FitzPatrick Nuclear Power Plant Technical Specifications (TSs). The requested changes would revise Section 6.5, " Review and Audit," and Section 6.8, " Procedures," of the TSs to establish a new review and approval process for nuclear safety-related procedures. The
. requested changes would also revise Section 6.5 to modify membership requirements for the Plant Operating Review Committee (PORC) and to delete review and audit responsibilities for the Emergency and Security Plans from the TSs consistent with Generic Letter (GL) 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans." The licensee also proposed several administrative and editorial changes to improve the human factors aspects of the TSs. The December 2,1994, letter provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
1.1 Procedure Review and Anoroval Process Chanaes i
The TSs currently require that procedures affecting nuclear safety, and changes thereto, be reviewed by the PORC and approved by the Resident Manager prior to implementation. The licensee has proposed changes to TS Sections 6.5 and 6.8 that would establish a new procedure review and approval process which shifts a portion of the responsibility for the review of nuclear safety-
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related procedures and procedure changes from the PORC to the line organizations. These danges are intended to reduce the administrative burden on the PORC and alter the scope of the PORC's review function to be more consistent with that of a safety oversight committee.
The proposed procedure review and approval program would be based upon a nuclear safety evaluation process. A new administrative procedure would be implemented to govern the 10 CFR 50.59 reviews of proposed procedure changes.
This procedure would meet the intent of the guidance contained in Electric Power Research Institute Report NSAC-125, " Guidelines for 10 CFR 50.59 Safety Evaluations." Safety reviews would be conducted in a two-step process consisting of:
(1) a nuclear safety and environmental impact screening and environmental impact evaluati6n.(10 CFR 50.59 safety evaluation) and/or an (2) a nuclear safety evaluation The screening process would utilize a series of questions the responses to which would determine whether or not a nuclear
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safety and/or environmental impact evaluation is required. The results of the screening process and safety and/or environmental impact evaluations would be documented in writing.
If a safety or an environmental impact evaluation is not required, the screening process alone would constitute a complete safety review.
If the safety review for a new procedure or procedure change concluded that a safety or an environmental evaluation is required, the evaluations would be prepared and subsequently reviewed by the PORC.
Personnel performing safety reviews would be appropriately qualified and trained to perform this function.
If qualified to do so, the same individual could perform the screening and prepare the evaluations.
l The licensee has stated that each completed procedure or procedure change package would be reviewed by two designated technical reviewers. The designated technical reviewers would be knowledgeable in the functional / technical subject matter related to the proposed activity.
Designated technical reviewers would be designated by the department managers and responsible for reviewing procedures or procedure changes for adequacy, completeness, and accuracy. The designated technical reviewers would also be responsible for determining whether cross-dhciplinary reviews are required.
A designated technical reviewer could also perform safety reviews if qualified to perform both functions. The licensee has stated that designated technical reviewers will meet or exceed the qualifications described in Section 4 of American National Standards Institute (ANSI) N18.1-1971, " Selection and Training of Nuclear Power Plant Personnel," for applicable positions.
If required, cross-disciplinary reviews would be performed by other appropriate designated technical reviewer (s) before a procedure or procedure change is forwarded to the approving authority. After all necessary reviews have been completed, a procedure or procedure change would be reviewed by the responsible procedure owner. The responsible procedure owner would be a member of the management staff having approving authority and responsibility for specific procedures. The responsible procedure owner would be responsible for ensuring that the proposed procedure or procedure change has been i
prepared, documented, and reviewed in accordance with the administrative procedure that will govern the procedure review and approval process.
If a safety and or environmental impact evaluation is not required, a new procedure or procedure change would receive final approval by the responsible procedure owner.
PORC review would not be required.
If, however, an evaluation is required, PORC would be responsible for reviewing the safety and/or environmental impact evaluation. Responsible procedure owners would be designated by the Resident Manager.
A temporary procedure change could be made under the new procedure review and approval process provided that the intent of the or%ai procedure is not altered, the change is approved by two members of p1 7.t man m ment, at least one of whom holds a Senior Reactor Operator's IMccns and tne cha Na is approved by the responsible procedure owner A hi ' 14 &
. 1.1 PORC Membershio Chanae The PORC was established to assist the Resident Manager in keeping abreast of general plant operating conditions in accordance with ANSI N18.7-1972,
" Administrative Controls for Nuclear Power Plants." The PORC's function is to advise the Resident Manager in matters related to nuclear safety and environmental impact. The licensee has proposed that TS 6.5.l(A) be revised to remove the Resident Manager from the PORC and establish the General Manager-Operations as the PORC Chairman. These changes are intended to strengthen the PORC's independent advisory role. The licensee has stated that the proposed changes woeld not adversely affect the level and quality of the PORC's reviews since diversity in educational background and work experience would continue to exist. The proposed changes would not diminish the quorum requirement.
The quorum would continue to be comprised of a Chairman and five members (a majority) of which no more than two are designated alternatives.
1.2 Removal of Review and Audit Reauirements for Emeroency and Security Plans The licensee has proposed changes to TSs 6.5.l(E) and 6.5.2.8, which list the review and audit responsibilities of the PORC and Safety Review Committee
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(SRC),respectively. The proposed changes would remove requirements to review and audit the Emergency and Security Plans from the TSs since these requirements duplicate the provisions of 10 CFR Part 50 and 10 CFR Part 73.
The review and audit requirements in the TSs would be relocated to the respective plans. The NRC issued guidance to all holders of operating licenses for nuclear power reactors on the proposed changes by GL 93-07.
2.0 EVALUATION 2.1 Procedure Review and Acoroval Process Chanaes The licensee has proposed changes to TS Sections 6.5 and 6.8 that would establish a new process for the review and approval of nuclear safety-related procedures.
The TSs currently require that procedures affecting nuclear safety and changes to such procedures be reviewed by the PORC and approved by the Resident Manager. As previously discussed, under the proposed review and approval process PORC would only review those procedures or procedure changes requiring a nuclear safety evaluation and/or an environmental impact evaluation.
Safety and technical reviews of proposed procedures and procedure changes would be performed by qualified individuals.
Procedures and procedure changes would be approved by responsible procedure owners who would be designated by the Resident Manager. The proposed changes are intended to reduce the administrative burden on the PORC and alter the scope of the PORC's review function to be more consistent with that of a safety oversight committee. The specific TS changes that have been proposed to support the new process for the review and approval of nuclear safety-related procedures are discussed below.
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TS Section 6.5 would be revised to read as follows:
Review requirements are accomplished by using designated technical reviewers / qualified safety reviewer and two separate review committees.
The Plant Operating Review Committee (PORC) is an onsite review group; the Safety Review Committee (SRC) is an independent offsite review and.
audit group.
A new Section 6.5.0 would be inserted into the TSs that would read as follows:
6.5.0 REVIEW AND APPROVAL OF PROGRAMS AND PROCEDURES 6.5.0.1 The procedure review and approval process shall be controlled and implemented by administrative procedure (s).
6.5.0.2 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall be reviewed by a minimum of two designated technical reviewers who are knowledgeable in the affected
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functional area.
6.5.0.3 Designated technical reviewers shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions, with the exclusion of the positions identified in Sections 4.3.2 and 4.5.
Individuals whose positions are described in Sections 4.3.2 and 4.5 may qualify as designated technical reviewers provided they meet the qualifications described in other portions of Section 4.
6.5.0.4 The designated technical reviewer shall determine the need for cross-disciplinary reviews.
Individuals performing cross-disciplinary reviews shall meet or exceed the qualifications described in Section 4 of ANSI N18.1-1971 for applicable positions.
6.5.0.5 Each program and procedure required by Specification 6.8 and other procedures that affect nuclear safety, and changes thereto, shall be reviewed from a safety perspective by a qualified safety reviewer. Safety and/or environmental impact evaluations, when required, shall be reviewed by PORC per Specification 6.5.1.6.a.
6.5.0.6 Nuclear safety related procedures and procedure changes shall be reviewed and approved, prior to implementation, by the appropriate member (s) of management.
A new TS Section 6.5.1.1 would be inserted that would read as follows:
6.5.1.1 Function PORC shall function to advise the Resident Manager on matters related to nuclear safety and environmental impact.
., TS 6.5.1(E)1. would be redesignated 6.5.1.6a and revised to read as follows:
Review of 10 CFR 50.59 safety and environmental impact evaluations associated with procedures and programs required by Specification 6.8, and changes thereto.
TS 6.5.l(E) would be redesignated 6.5.1.6 and the words "The PORC shall be responsible for:" would be inserted at the beginning of this section:
TS 6.5.1(F) would be redesignated 6.5.1.7 and changed to read as follows:
The PORC shall:
a.
Recommend to the Resident Manager approval or disapproval of those items reviewed under Specification 6.5.1.6.a through 6.5.1.6.d.
b.
Render determinations with regard to whether or not items considered under Specification 6.5.1.6.a through 6.5.1.6.e constitute an Unreviewed Safety Question as defined in 10 CFR 50.59.
c.
In the event of a disagreement between the PORC and Resident Manager, notify the Executive Vice President - Nuclear Generation and the SRC Chairman, or their designated alternates, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and provide written notification by the next business day. The Resident Manager shall have responsibility for resolution of stuch disagreement pursuant to Section 6.1.
TS 6.8(B) would be revised to read as follows:
Each procedure of Specification 6.8.(A), and changes thereto, shall be approved prior to implementation by the appropriate responsible member of management as specified in Specification 6.5.0.
TS 6.8(C) would be revised to read as follows:
Temporary changes to the procedures required by Specification 6.8.(A) may be made provided:
1.
the intent of the original procedure is not altered.
2.
the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's license.
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the change is documented, reviewed and approved by the appropriate member of plant management as required by Specification 6.5.0 within 14 days of implementation.
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^ Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation),"
references ANSI Standard N18.7-1976 and provides a guide to the types of procedures to be developed for nuclear facilities. Section 3.2 of this. ANSI standard states that: plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure; procedures shall be approved as designated by the owner organization before use; procedures shall be reviewed by knowledgeable personnel other than the originator; approval and changes shall be performed by authorized individuals; and changes to procedures shall be reviewed and approved by the same organization that originally reviewed and approved the procedure unless otherwise designated.
The NRC staff has determined that the proposed process for the review and approval of nuclear safety-related procedures is consistent with ANSI N18.7-1976. The staff has also determined that the transfer of procedure approval authority from the Resident Manager to the line organizations will permit the Resident Manager to better focus his attention on major safety issues and place approval authority with designated individuals more familiar with the affected procedures. The proposed changes in the procedure review process will provide for technical reviews by designated individuals and provide for-PORC involvement in the review of more safety significant procedures and procedure changes. The staff has also determined that the proposed process for the review and approval of nuclear safety-related procedures will relieve the PORC of an administrative burden and thereby allow this committee to better focus on its nuclear safety oversight role. The staff, therefore, finds the proposed related changes to TS Sections 6.5 and 6.8 to be acceptable.
2.2 PORC Membershio Chanae The licensee has proposed that TS 6.5.l(A) be revised to remove the Resident Manager from the PORC and establish the General Manager-Operations as the PORC Chairman. The proposed change is intended to strengthen the PORC's independent advisory role. The licensee has stated that the General Manager-Operations has the appropriate level of education and experience necessary to ensure that decisions made by the PORC will consider safety as the primary consideration. The licensee has also stated that the proposed changes would not adversely alter the level and quality of the PORC's review function in that diversity in educational background and work experience would continue to exist. The quorum requirement would not be diminished. The quorum would continue to be comprised of a Chairman and five members (a majority) of which no more than two are designated alternates.
The NRC staff has concluded that the proposed change to TS 6.5.1(A) is acceptable since it will enhance the PORC's abiljty to independently advise the Resident Manager in matters related to nuclear safety and environmental impact and should not adversely affect the level and quality of PORC reviews.
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2.3 Removal of Review and Audit Reauirements for Emeraency and Security Plans Part 50.36 of Title 10 of the Code of Federal Regulations established the regulatory requirements related to the content of TSs. The rule requires that TSs include items in specific categories, including safety limits, limiting conditions for operation, and surveillance requirements. However, the rule does not specify the particular requirements to be included in a plant's TSs.
The NRC developed criteria, as described in the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," (58 FR 39132) to determine which of the design conditions and as:-ociated J
surveillances need to be located in the TSs because the requirement is "necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety." Briefly, those criteria are:
(1) detection of abnormal degradation of the reactor coolant pressure boundary, (2) boundary conditions for design basis accidents and transients, (3) primary success paths to prevent or mitigate design basis accidents and transients, and (4) functions determined to be important to risk or operating experience. The Commission's final policy statement acknowledged that its implementation may result in the relocation of existing TS requirements to licensee controlled documents and programs.
The licensee has proposed modifying TS 6.5.1(E) by removing items 7 and 8, which reference the Security and Emergency Plans, respectively, and their implementing procedures under the review responsibilities of the PORC. The licensee has also proposed modifying TS 6.5.2.8 by removing items e. and f.,
which reference the Emergency and Security plans, respectively, and their implementing procedures under the audit responsibilities of the SRC. These reviews and audits are to be performed at least once every 12 months. The removed audit and review requirements would be relocated to the respective Emergency and Security plans. The licensee proposed these changes consistent with the guidance provided in GL 93-07.
The NRC staff has determined that requirements related to the review and audit of the Emergency and Security Plans do not satisfy any of the previously stated final policy statement criteria which would necessitate that they be included in the TSs. On this basis, the staff concludes that these requirements do not need to be controlled by the TSs.
In addition, as stated in GL 93-07, 10 CFR Part 50 and 10 CFR Part 73 include provisions that are sufficient to address these requirements. The staff has concluded that the proposed changes to TSs 6.5.l(E) and 6.5.2.8 are, therefore, acceptable.
2.4 Administrative and Editorial Chanaes i
The licensee has proposed various administrative and editorial changes to improve the human factors aspects of the TSs. These proposed changes are discussed below.
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. TSs 6.5.l(A) through 6.5.1(H) would be redesignated as 6.5.1.2. through 6.5.1.9, respectively.
The PORC responsibilities listed on page 249 that are currently designated "I through 13" would be redesignated as "a through j".
Current responsibilities "Il and 12" would combined to become item "i".
The format of TS 6.8.(A) would be changed from a paragraph to an outline form.
In TS 6.5.1.3 the words "however, no more than two alternates shall participate in PORC activities at any one time" would be removed.
In TS 6.5.1.5 a sentence would be added that would read as follows:
A quorum shall contain no more than two alternates.
TS 6.5.1.6.e would be revised to read as follows:
1 Investigation of violations to the Technical Specifications. The PORC shall prepare and present a report covering the evaluations and recommendations to prevent recurrence to the Resident Manager, who will then forward the report to the Executive Vice President and Chief Nuclear Officer, the Vice President Regulatory Affairs and Special Projects, and to the Chairman of the Safety Review Committee.
The NRC staff has concluded that these proposed changes are administrative in nature and will improve consistency within the TSs. The proposed changes are, therefore, acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the New York State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
This amendment changes 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 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
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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:
John E. Menning Date:
January 18, 1995
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