ML20082M860
| ML20082M860 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/18/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20082M858 | List: |
| References | |
| NUDOCS 9504240403 | |
| Download: ML20082M860 (5) | |
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' UNITED STATES j
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~ NUCLEAR REGULATORY COMMISSION l
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' WASHINGTON. D.C. 20066-0004
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$AFETY EVALUATION BY THE OFFICE OF NUCLEAR.BFACTOR REGULATION i
RELATED TO AMENDMENT N0c 177 TO FACILITY OPERATING LICENSE NO. DPR-71 AND AMENDMENT NO. 208TO FACILITY OPERATING LICENSE NO. DPR-62 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT. UNITS 1'AND 2 l
DOCKET NOS. 50-325 AND 50-324
1.0 INTRODUCTION
By letter dated July 22 1994< as supplemented March 6,1995, Carolina Power &
Light Company (CP&L or licensec) requested changes to the Administrative Controls Section of the Brunswick Steam Electric Plant, Units 1 and 2 (BSEP),
1 Technical Specifications (TS). These changes supersede the TS changes l
requested in the letter dated September 15, 1993. The following is a brief 6
description and our evaluation of the requested changes. The March 6, 1995 l
letter did not expand the scope of the original Federal Reaister notice or change the no significant hazards determination.
2.0 EVALUATION a.
Section 6.2.3 - Pro.iect Assessment Section CP&L proposes to delete this section from the TS as they are no longer j
required to maintain this function because the Brunswick Improvement Plan (BIP) order that requires the function has been rescinded.
However, CP&L states that this function will be integrated into the Nuclear Assessment Section (NAS) Assessment Program described in the revised Section 6.5.5.
The NRC staff finds this change acceptable because there is no NRC requirement i
for CP&L to maintain this function at BSEP.
b.
Sections 6.5.2.9. 6.5.3.8. 6.5.4. 6.5.4.3. 6.5.4.5. and 6.5.4.8
'CP&L 91ans to delete the reference to the Nuclear Assessment Department (NAD), because the NAD will no longer exist, and to replace the reference to it in these sections with the new Nuclear Assessment Section (NAS) that will report to the Vice President, Brunswick Nuclear Plant..
The NRC staff finds this change acceptable as it reflects the revised organization, c.
Section 6.5.3 - Plant Nuclear Safety Committee (PNSC)
CP&L proposes to make numerous changes to this section.
They include:
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1.-
Revising the description of the organizational provisions of the PNSC by deleting reference to members by position title. This' i
would be replaced by specifying functional areas and qualification requirements by organizational level.
2.
Reformatting the subsections.
Redefhning the quorum and alternate requirements.
3.
4.
Deleting reference to the position of Manager, Nuclear, Assessment.
Department with respect to the distribution of reports and PNSC minutes, and deleting the Vice President, Nuclear Services from receiving notification of disagreements between the Plant General Manager and the PNSC.
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The NRC staff finds these changes acceptable-as they provide consistency between the other.CP&L nuclear plants, and the changes meet the appropriate j
acceptance criteria of Section 13.4 of NUREG 0800, the Standard Review Plan, and they reflect the revised organization.
d.
Section 6.5.4 - Nuclear Assessment Section (NAS) Independent Review Proaram j
CP&L proposes to modify this description by:
l 1.
Changing the phrase "specified in technical" to " qualified in i
specific" areas of expertise required for individuals performing independent reviews, and deleting the phrase in Subsection 1.
" associated with the unique characteristics of the nuclear power plants."
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Changing the term " academic" to " bachelor's" degree.
3.
Revising the requirement that "at least three individuals shall i
review each item" to "the documents shall be reviewed by individuals meeting the requirements of 6.5.4.2 and 6.5.4.4 to ensure applicable disciplines are encompassed and that multiple j
reviews will be conducted on documents where required to meet applicable disciplines of 6.5.4.2."
l 4.
Reformatting'by combining subsections 6.5.4.9.a, 6.5.4.9.b and i
subsection 6.5.4.9.c under a revised 6.5.4.9.a and 6.5.4.9.b; and changing the phrase " changes to procedures required by Specification 6.8" to " changes in procedures required by these Technical Specifications."
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Relocating the requirements of subsection 6.5.4.9 d to subsection' 6.5.4.9.c and adding the' phrase " prior to implementation."
6.
Relocating the requirements of subsection 6.5.4.9.e to subsections-l 6.5.4.9.d.1 and 6.5.4.9.d.2, and modifying the wording to be 4
consistent with ANSI N18.7.
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7.
Relocating the requirements of subsection 6.5.4.9.f to subsection l
6.5.4.9.d.2.-
8.
Relocating the requirements of subsection 6.5.4.9.g to subsection 6.5.4.9.d.3.
9.
Deleting the existing requirement in subsection 6.5.4.9.h that l
" independent review be performed of the reports and minutes of the-PNSC."
10.
Relocating the requirements of subsection 6.5.4.9.1 to subsection-6.5.4.9.e.
11.
Combining the existing requirements of subsections 6.5.4.10 and 6.5.4.11 into subsection 6.5.4.10 and modifying the wording to be consistent with ANSI N18.7. Any identified adverse condition resulting from Independent Reviews are addressed as part of the Corrective Action Program (CAP),
12.
Deleting the requirements of. subsections 6.5.4.11.a & b.
Identified adverse conditions resulting from the Independent
'i review are addressed as part of the CAP as identified in the Quality Assurance program.
It should be noted that this function now reports to the Site Vice President l
rather than to the offsite position of Executive Vice President, Nuclear Generation.
The NRC staff finds these changes acceptable as they are editorial in nature, conform to the Improved Standard Technical Specifications (ISTS), meet the appropriate section of ANSI N18.7, and reflect the revised organization.
In addition, with respect to the new NAS reporting relationship.the NRC staff considers that the acceptability of this arrangement is,. in part, based on the effectiveness of the new Nuclear Services Department. Performance Evaluation Section (PES) that provides an offsite check and balance to the onsite assessment functions. The PES is described in Section 17.3.3.2 of the revised Quality Assurance program. The licensee provided a detailed description of the PES assessment activities with respect to the NAS, including the specific-
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l oversight function of assessing the NAS performance, in their Narch 6, 1995, letter.. The NRC finds this description acceptable.
e.
Section 6.5.5 - Nuclear Assessment Section (NAS) Assessment Proaram CP&L proposes to retitle this section from the current title of Nuclear f
Assessment Bepartment Audit Program to NAS Assessment Program. This l
changes the reporting of this function to the onsite Vice President Nuclear. The change deletes the specific audit frequencies and establishes ' maximum frequency of 24 months between assessments. The a
change also alters the function from an audit bases to a performance based assessment program. Subsection 6.5.5.2.k, with respect to the audit of activities required by the Quality Assurance program, and i
subsections 6.5.5.3 through 6.5.5.9 with respect to administrative provisions of the current audit program have been deleted.
The NRC staff finds these changes acceptable as they conform to the ISTS and Sections 13.4 and 17.3 of NUREG 0800, the Standard Review Plan. With respect to this function reporting to the Site Vice President see our conclusion with respect to Section 6.5.4.
3.0 SUt91ARY i
The NRC staff finds the changes requested by CP&L letter dated July 22, 1994, as supplemented March 6,1995, to the Administrative Controls Section of the Technical Specifications for Brunswick Units 1 & 2 acceptable as they meet the appropriate acceptance criteria of Sections 13.4 and 17.3 of NUREG 0800, the Standard Review Plan, and conform to the ISTS.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the State of North Carolina official was notified of the proposed issuance of the amendments. The State i
official had no comments.
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5.0 ENVIRONMENTAL CONSIDERATION
This amendment changes recordkeeping, reporting, or administrative procedures i
or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10
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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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6.0 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 amendments will not be inimical to the common defense and security or to the health and safety of the public, t
Principal Contributor:
F. A11enspach Date:
April 18, 1995 1
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