ML20086H644
| ML20086H644 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/06/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20086H622 | List: |
| References | |
| NUDOCS 9507180216 | |
| Download: ML20086H644 (5) | |
Text
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UNITED STATES j
S NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20555-0001
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SAFETY EVALUATION BY'THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.109 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS. INC.
WATERFORD STEAM ELECTRIC STATION. UNIT 3 DOCKET NO. 50-302
1.0 INTRODUCTION
By application dated August 9, 1994, Entergy Operations, Inc. (the licensee),
submitted a request for changes to the Waterford Steam Electric Station, Unit 3 (Waterford 3), Technical Specifications (TSs).
The requested changes would revise the Administrative Controls Section of the TSs for Waterford 3 by removing the functions under review and audit from the TSs and by relocating those items in the quality assurance program manual (QAPM).
In addition the proposed changes will remove the review and audit functions for the emergency plan and implementing procedures, and security plan from the list of responsibilities of the plant operation review committee (PORC) in the TSs.
These requirements wi.11 be retained in emergency plan or security plan as appropriate.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TSs to be included as part of the license.
The Commission's regulatory requirements related to the content of TSs are set forth in 10 CFR 50.36.
That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
However, the regulation does not specify the particular requirements to be included in a plant's TSs.
The Commission has provided guidance for the contents of TSs in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical
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. specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TSs, as follows:
(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient I
that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operatingexperienceorprobabilisticsa[etyassessmenthasshowntobe significant to public health and safety.
As a result, existing TS j
requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TSs, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, l
licensee-controlled documents.
3.0 EVALUATION The licensee has proposed the follwing changes in the TSs for Waterford 3:
a.
Section 6.5.1 - PORC - Licensee proposes to delete this section from the TSs and relocate the requirement for the PORC to the QAPM.
- b. Section 6.5.2 - Safety Review Committee (SRC) - Licensee proposes to delete this section from the TSs and relocate the requirement for the SRC to the QAPM.
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- c. Section 6.5.3 - Technical Review and Control Process (TRCP) - Licensee I
proposes to delete this section from the TSs and relocate the requirement for j
the TRCP to the QAPM.
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The Commission recently promulgated a proposed change to 10 CFR 50.36, l
pursuant to which the rule would be amended to codify and incorporate I
these criteria (59 FR 48180).
The Commission's Final Policy Statement specified that only limiting conditions for reactor Core Isolation Cooling, Isolation Condenser, Residual Heat Removal, Standby Liquid Control, and Recirculation Pump Trip meet the guidance for inclusion in the TS under Criterion 4 (58 FR at 39137).
The Commission has solicited public comments on the scope of Criterion 4, in the pending rulemaking.
- d. Section 6.8.1 - Procedures and Programs - Licensee proposes to delete
't subsections d. and e., security plan implementation and emergency plan implementation, respectively,
- f. Licensee has revised Sections 6.8.2, 6.8.10, Table 3.3-1, and Table 3.3.3 to delete reference to the deleted Sections 6.5.1, 6.5.2, and 6.5.3.
The staff finds these requested changes acceptable as they are editorial in nature.
REQUIREMENTS RELOCATED TO A QUALITY ASSURANCE PROGRAM MANUAL The licensee proposes that the review and audit functions specified in existing TSs 6.5.1, 6.5.2, 6.5.3 be relocated from the TSs on the basis that they are adequately controlled elsewhere.
These TS provisions are not necessary to assure safe operation of the facility, given the requirements in the QAPM implementing 10 CFR 50.54 and 10 CFR Part 50, Appendix B to control the requirements for all review and audit functions.
Such an approach would result in an equivalent level of regulatory authority while providing for a more appropriate change control process.
The level of safety of plant operation is unaffected by this change and NRC and licensee resources associated with processing license amendments to this administrative control may be used more effectively.
In addition, the following considerations support relocating these items from the TSs:
1.
The on-site review function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and records are all covered in equivalent detail in ANSI N18.7-1976.
These requirements are in the QAPM description and change control is provided by 10 CFR 50.54(a).
2.
The off-site review group is also addressed, although with less detail, in ANSI N18.7-1976.
The QAPM description include the requirements for the off-site review group.
Therefore, duplicating the review and audit function of the off-site review group in the TSs is unnecessary.
3.
Audit requirements are specified in the QAPM description to satisfy 10 CFR Part 50, Appendix B, Criterion XVIII. Auoits are also covered by ANSI N18.7, ANSI N45.2, 10 CFR 50.54(t), 10 CFR 50.54(p), and 10 CFR Part 73. Therefore, duplication of these requirements does not enhance the level of safety of the plant, nor are the provisions relating to audits necessary to assure safe operation of the facility.
On this basis, the staff concludes that the review and audit requirements do not need to be controlled by the TSs, and changes to the audit frequencies, which will be described in the QAPM, will adequately be controlled by 10 CFR 50.54(a).
The staff has concluded, therefore, that relocation of the review and audit requirements described above is acceptable because (1) their inclusion in technical specifications is not specifically required by 10 CFR 50.36 or other regulations, (2) the review and audit requirements are not required to avert an immediate threat to the public health and safety, and i
(3) changes to these audit requirements, as described in the applicable program description, will require prior NRC approval in accordance with Section 50.54(a).
REQUIREMENTS RELOCATED TO EMERGENCY PLAN OR SECURITY PLAN The licensee proposes to relocate the requirements to establish, implement, and maintain procedures related to the emergency plan (existing TS 6.8.1.e) and security plan (existing TS 6.8.1.d).
Since the security plan requirements are specified in 10 CFR 50.54, 73.40, 73.55, and 73.56 and the emergency plan requirements are specified in 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E, Section V, in Generic Letter (GL) 93-07 the staff removed the requirements from the Standard Technical Specificatios (STS) and relocated them to their respective plans.
The requirements in the existing TSs for the review of the security program and implementing procedures, and for the review of the station emergency plan and implementing procedures, will be included in the security plan and the emergency plan respectively.
Further changes in these review requirements must be made in accordance with 10 CFR 50.54(p) for the security plan and 10 CFR 50.54(q) for the emergency plan.
The staff concludes that the requirements for emergency planning in 10 CFR 50.47, 50.54, 10 CFR Part 50 Appendix E and for security in 10 CFR 50.54 and 73.55, for drills, exercises, testing, and maintenance of the program, provide adequate assurance that the objective of the previous TSs for a periodic review of the program and changes to the programs will be met.
Therefore, duplication of the requirements contained in the regulations would not enhance the level of safety for the facility.
The staff concludes that other regulatory requirements provide sufficient control of these provisions and removing them from TSs is acceptable.
On this basis, the staff concludes that these requirements do not need to be controlled by the TSs, and changes to the audit frequencies, which will be described in the emergency plan or security plan, will adequately controlled by 10 CFR 50.54(p) or (q), as applicable.
The staff has concluded, therefore, that relocation of the audit requirements described above is acceptable because (1) their inclusion in TSs is not specifically required by 10 CFR 50.36 or other regulations, (2) the audit requirements are not required to avert an immediate threat to the public health and safety, and (3) changes 1
to these audit requirements, as described in the applicable program description, will require prior NRC approval in accordance with Appendix E to Part 50, Section 50.54(p), or Section 73.56(g).
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4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes recordkeeping, reporting, or administrative procedures or requuirements. 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.
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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
F. Allenspach D. Barss Date: July 6, 1995 l
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