ML20087G577
| ML20087G577 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/14/1995 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20087G575 | List: |
| References | |
| NUDOCS 9508170115 | |
| Download: ML20087G577 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION l
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i SAFETY EVALUATION BY-THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT N0.195 TO FACILITY OPERATING ' LICENSE NO. DPR-50 i
METROPOLITAN EDISON COMPANY j
JERSEY CENTRAL POWER & LIGHT COMPANY l
PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION. UNIT NO. 1 DOCKET NO. 50-289 i
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1.0 INTRODUCTION
l By letter on April-19, 1994, as supplemented by a letter on March 8, 1995, the GPU Nuclear Corporation (GPUN, the licensee) submitted a request'for chanes to the Three Mile Island Nuclear Station, Unit 1 (TMI-1) Technical Specifications (TS). The requested changes would relocate the audit frequencies specified for the Quality Assurance (QA) program, the Securii.y-
. Plan, the Emergency Plan, the fire protection program, the training program, and the Offsite Dose Calculation Manual (00CM) from the. administrative l
controls section (Chapter 6) of the TS to the-licensee-controlled Operational QA (0QA) Plan.- These frequencies would be located in Appendix E of the OQA i
Plan.
In some cases, the audit frequency is being lengthened to 24 months.
The March 8,1995, submittal provided clarifying information that did not change the initial proposed no significant hazards consideration determination.
1 2.0 MGKfaQLild!
Section 182a of the Atomic Energy Act of 1954, as amended-(the Act) requires I
applicants for nuclear power plant operating licenses to include TS as part of j
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 July 22, 1993 (58 FR 39132). The Comission 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 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 *"t is part of the primary success path and which functions or actuates t
" igate a design j
basis accident or transient that either assumes the f
.a 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 4 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 and 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 THI-l UFSAR and controlled pursuant to 10 CFR 50.54.
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_3 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 00A Plan, Appendix E, such that 1
future changes could be made pursuant to 10 CFR 50.54(a).
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 i
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 Commission's regulations pertaining to these review and audit functions as set forth below. The review and audit functions define an i
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 committed 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 commitments to ANSI N18.7, which provides appropriate controls for the approval of changes to the audit functions and frequencies.
Future changes to the 00A Plan, including departures from the referenced ANSI standards, ti;at constitute a reduction in commitment, 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 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 Oi)A Piih Fevision submitted with ths 15 Enangi llEqUest r sult in in ovsFill enhancement to the THI audit program.
For example, an annual review would be required in all areas, using performance trend indicators including
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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 I
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 imediate threat to the public health and safety.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.54 to adequately control future modifications to these provisions. Accordingly, the staff has concluded that these requirements may be relocated from the THI-l TS to the GPUN 0QA Plan.
In addition, with regard to the licensee's request for staff approval of reduced frequencies for four of the audits, the staff I
concludes that sufficient guidance will exist in the GPUN 0QA 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 l
questionable performance.
The staff finds, therefore, that these changes are acceptable.
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4.0 STATE CONSULTATION
l In accordance with the Comission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State
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official had no coment.
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5.0 ENVIRONMENTAL CONSIDERATION
I The 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 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 Comission 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 Comission's regulations, and (3) the issuance of the amendment will not be inimical to the comon
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defense and security or to the health and safety of the public.
I Principal Contributor:
R. Gram R. Hernan Date: August 14, 1995 l
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