ML20087D053
| ML20087D053 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/07/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20087D048 | List: |
| References | |
| NUDOCS 9508100151 | |
| Download: ML20087D053 (4) | |
Text
E amou UNITED STATES -
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- j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2006H001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULAT10tj, RELATED TO AMENDMENT NO.181 1
TO FACILITY OPERATING LICENSE NO. DPR-16 GPU NVCLEAR CORPORATION AND JERSEY CENTRAL POWER & LIGHT COMPANY
-l OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219
1.0 INTRODUCTION
By letter of April 15, 1994, as supplemented by letters of May 20, 1994, and March 8,.1995, the GPU Nuclear Corporation (GPUN, the licensee) submitted a request for changes to the Oyster Creek Nuclear Generating Station (OCNGS) i Technical Specifications (TS). The requested changes would relocate the audit i
frequencies specified for the Quality Assurance (QA) program,-the Security Plan, the Emergency Plan, the fire protection program, the staff _ training program, and the Offsite. Dose Calculation Manual (ODCM) from the administrative controls sectica (Chapter 6) of the TS to the licensee-controlled corporate Operational QA (0QA) Plan. These frequencies would be located in Appendix E of the 0QA Plan.
In some cases, the audit frequency is being lengthened to 24 months. A minor editorial change has been incorporated into TS 6.5.1.14 correcting a reference in response to a finding in the Operational Safety _ Team Inspection (OSTI) report of December 23, 1993. The.
letters of May 20, 1994, and March 8, 1995, provided clarifying.information that did not change the initial proposed no significant hazards consideration-determination.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act of 1954, as amended, (the Act) requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's ' regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS 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 TS.
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The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (Final Policy Statement), published in the Federal Reaister on i
July 22, 1993 (58 FR 39132). The Commission indicated therein 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 TS 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 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 i
health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining ~whether particular limiting conditions for operation are required to be included in the TS, 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 4
primary success path and which functions or actuates to mitigate a design basis accident or transient 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 operating experience or probabilistic safety assessment has shown to be significant to public health and safety.
The Commission's policy statement provides that many of the existing TS limiting conditions for operation which do not satisfy these four specified criteria may be relocated to the Updated Final Safety Analysis Report (UFSAR),
such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Other requirements may be relocated to more appropriate documents (e.g. Security Plan, 0QA Plan, and Emergency Plan) and controlled by the applicable regulatory requirement. While the content of the TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details of the administrative controls may be relocated to licensee-controlled documents where 550.59 or comparable regulatory controls exist.
Administrative controls in existing TS related to the review and audit functions, including specified frequency provisions, may be relocated to a licensee-controlled document that provides adequate control over changes to these provisions aed which provides an appropriate change control mechanism.
As such, these review and audit provisions can be relocated to the Quality Assurance Program referenced in the OCNGS UFSAR and controlled pursuant to 10 CFR 50.54.
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. 3.0 EVALUATION The licensee proposed that the audit frequencies specified in existing TS (6.5.3.1.a to 6.5.3.2.b), including the frequency of fire protection system audits, be relocated from the TS to the GPUN 0QA Plan, Appendix E, such that future changes could be made pursuant to 10 CFR 50.54(4).
In addition, staff approval was requested to extend the audit frequency (maximum time between audits) from 12 months to 24 months in three cases and from 6 months to 24 months in one case.
Specifying audit frequencies in the TS is not necessary to assure safe operation of the facility, given that the requirements in the QA program implement the Comission's regulations pertaining to these review and audit functions as set forth below. The review and audit functions define an administrative framework to confirm that plant activities have been properly conducted in a safe manner.
The reviews and audits serve also to provide a cohesive program that provides senior level utility management with assessments of facility operation and recommends actions to improve nuclear safety and reliability. As such, the review and audit program does not include any elements that are delineated in the Final Policy Statement criteria, as discussed above, for determining which limiting conditions are required to be included in the TS. As documented in the Final Policy Statement, the review and audit functions constitute requirements that can be relocated to the 0QA Plan and controlled by the applicable regulatory requirement. Control of changes to the QA program description are governed by the provisions of 10 CFR 50.54(a).
Such an approach would result in an equivalent level of regulatory authority while providing for a more appropriate change control process and flexibility in scheduling audits.
Audit requirements, including frequencies, are specified (or are to be specified) in the QA program to satisfy 10 CFR Part 50, Appendix B, Criterion XVIII. The licensee has comitted to or relies upon the guidance in ANSI N18.7 and ANSI N45.2 to meet the requirements of Appendix B to 10 CFR Part 50.
Audits are also governed by 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 plant safety. Control of changes to the QA program description are governed by the provisions of 10 CFR 50.54(a).
The licensee will continue to implement a QA program in accordance with the requirements of 10 CFR Part 50, Appendix B, and comitments to ANSI N18.7, which provides appropriate controls for the approval of changes to the audit functions and frequencies.
Future changes to the 0QA Plan, including departures from the referenced ANSI standards, that constitute a reduction in comitment, require NRC approval pursuant to 10 CFR 50.54(a). The staff concludes that this regulatory requirement provides sufficient control for the audit frequencies, so that removing these requirements from the TS is t
acceptable. The staff has also concluded that, even with this minor reduction in comitment by reducing the frequency of four audits, other features of the 0QA Plan revision submitted with the TS Change Request result in an overall enhancement to the OCNGS audit program.
For example, an annual review would be required in all areas, using performance trend indicators including
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~4-Licensee Event Reports, Notices of Violation, and other independent observations, to determine if the audit frequency should be increased.
On the above basis, the staff concludes that these provisions are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threa t to the public health and safety.
In addition, the staff finds that sufficier,t regulatory controls exist under 10 CFR 50.54 to adequately control future nodifications to these provisions. Accordingly, the staff has concluded that these requirements may be relocated from the OCNGS TS to the GPUN OQA Plan.
In addition, with regard to the licensee's request for staff approval of reduced frequencies for four of the at:dits, the staff concludes that sufficient guidance will exist in the GNN OQA Plan to ensure audits are conducted on a performance basis and audits would be performed more frequently than the minimum specified of areas demonstrating poor or questionable performance. The staff finds, therefore, that these changes are acceptable.
The staff also agrees with the minor change in TS 6.5.1.14 which resolves a coment in the OSil report.
4.0 STATE CONSULTATION
In accordance with the Comission's regulations, the New Jersey State official was notified of the proposed issuance of the amendment. The State official had no coment.
5.0 ENVIRONMENTAL CONSIDERATION
The 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 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:
public w(1) there is reasonable assurance that the health and safety of the ill not be endangered by operation in the proposed manner, activities will be conducted in compliance with the Commission's reg (2) such
- ulations, and (3) the issuance of the amendment will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributors:
R. Gramm A. Dromerick Date:
August 7, 1995 i