ML20090K431
| ML20090K431 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/21/1987 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20090J504 | List: |
| References | |
| FOIA-91-170 02.1, 2.1, NUDOCS 9002130339 | |
| Download: ML20090K431 (17) | |
Text
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Appendix 1 CAROLINA POVER & LIGHT COMPAhT BRUNSWICK STEAM ELECTRIC PLANT UNIT 0 PROCEDURE TYPE:
REGULATORY COMPLIANCE INSTRUCTION (RCI)
PROCEDURE NLHBER:
02.1 PROCEDURE TITLE:
REQUEST POR AND PROCESSING OP OPERATING LICENSE Ah"J TECHNICAL SPECIPICATION CHANGES j
REVISION 4 5 - '
APPROVED BY:
M
)
General Manager / Q Da t a' Director - Regulatory Compliance O RCI-02.1 Rev. 4 Page 1 of 17 l
oo9/30339) %A
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i LIST 0F EFFECTIVE PAGES RCI-02.1 Page(s)
Revision 1-17 4
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Page 2 of 17 l O RCI-02.1 Rev. 4 n
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- 1. 0 I NTR00rCT
- 0N 1.1 Purp:se This instruction provides the method by which changes to the BSEP 1 and 2. operating licenses, including Technical Specifications, are requested, prepared, reviewed, approved, and transmitted to the Nuclear Licensing Section (NLS), Raleigh.
i 1.2 References 1.2.1 BSEP Units 1 and 2, Operating Licenses DPR-71 and DPR-62, respectively, including the Technical Specifications 1.2.2 RCI-03.1, Safety Evaluations 1.2.3 RCI-02.3, Technical Specification Interpretation Request.
Processing, and Maintenance-1.2.4 AP, Administrative Procedure 1
1.2.5 RCI-02.2 Operating License, including Technical Specifications, Amendment Issuance, and Imple:entation g
1.2.6 RCI-05.2, Regulatory Compliance Action Ite: Assignment and
Response
1.2.7 10CFR50.36. Technical Specificatiens 1.2.8 10CPR50.90. Application for Amendment of License or Construction Permit
-1,3 Responsibilities-1.3.1 The Director - Regulatory Compliance, or his designee, shall ensure operating license change requests are processed in accordance with this instruction.-
1.3.2 Personnel requesting and/or reviewing operating li-ense l
change requests shall follev this instruction.
2.0 INSTRUCTION 2.1 Request 2.1.1 A request for a change to the operating licenses, including the Technical Specifications shall be cade using Attachment 1, Re qu e s t for Operating License Change.
2.1.2 The originator of the required change shall co:plete the following items of Attach =ent 1:
Item 1 The unit (s) affected.
O RCI-02.1 Rev. 4 Page 3 ef 17
-Item 2 The operating license section (or Technical Specification number) and subject.
Item 3 A concise, detailed description of the change, including draft (marked-up) pages (with appropriate related operating license sections or Technical Specifications which may also be affected).
Item 4 A ceneise, detailed reason and justification for the required change (e.g., a plant modification.
increased safety margin, etc.) which specifically demonstrates the need for the change. provides guidance to develop sufficient reason and justification for the requested change.
Item 5 A safety evaluation prepared in accordance with RCI-03.1 shall be provided with the proposed change.
Person performing this evaluation shall be noted in-this space.
Item 6 A significant hazards consideration evaluation prepared in accordance with Attachment 7.
Person performir; this evaluation shall be noted in this space.
Item 7 Whether the requested change requires b'RC approval by a certain date.
Such requested changes are generally outage related or impact plant operations.
Item 8 The originator's signature and date.
Items 9 A first and second party Nuclear Safety Reviev
& 10 conducted in accordance with Volume I, Book I,-
Administrative Procedures.
2.1.3 The originator's supervisor shall review the requested
. change, indicate concurrence by signing Item 11 of, and forward the requested change to Regulatory Compliance.
2.1.4 Regulatory Compliance shall review the requested change for, but not limited to; the following:
2.1.4.1 Completeness, legibility, and adequate justification.
2.1.4.2 Comparison to the guidance provided by other available documents (e.g., GE/BWR-4 Standard Technical Specifications, Standard Review Plan, Updated TSAR, FSAR. Code of Federal Regulations
[CTR), etc.).
O RCI-02.1 Fev. 4 Page 4 ef 17
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2.1.4.3 The need of a Technical Specification interpretation (RCI-02.3)
... 5 If the Regulatory Compliance review determines additional l
justification, revised bases, etc., is required, the requested change shall be returned to the originator /
preparer for correction.
-l-2.2 Preparation 2.2.1 If the requested change is acceptable. Regulatory Compliance shall assign a tracking number.
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2.2.2 Regulatory Compliance shall forward a c:py of the requested change to NLS fort l
i 2.2.1.1 Preparation of a typed draf t version of the proposed operating license change (s).
2.2.1.2 Preparation of a draft submittal letter.
2.2.1.3 Development of a No -Sigt ificant Hazards Consideration determination (with interface with I
BSEP Regulatory Compliance personnel, as required).
f 2,2.3 NLS shall forward the typed draft operating license' change package to BSEP Regulatory Compliance.
2.3 Review j.
2.3.1 Regulatory Compliance shall distribute the draft operating license change package and a copy of Attachment 3 to appropriate units / subunits to be reviewed in a specified time frace.
As a minimum, distribution shall be made to the originating unit / subunit.
2.3.2 Each assigned unit / subunit shall review the draft change package for adequacy, accuracy, clarity, i= pact, and implementation requirements considering, but not limited j
to, the guidelines provided in Attachment 4 The results of the review should be provided within the time frame fientified by Regulatory Compliance unless an extension j
has been requested and approved by Regulatory Complianet l
The reviev'shall be documented on Attachsent.3. Sections A and B. as follows:
2.3.2.1 Section A - Co==ents Any comments and reco= ended revisions shall be documented in Section A on attached sheets as necessary.
O RCI-02.1 Rev. t Page 5 of 17 l
m 2.3.2.2 Section B - Implementation Requirements 2.3.2.2.1 Modifications, procedure revisions, etc.,
necessary to implement the draft change j
shall be identified in Section B on attached sheets as necessary. The assigned units / subunits should only identify these implementation require-ments for which they are responsible.
- .3.2.2.2 The listing provided shall clea
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state the nature of any required 1mplementation requirements in the description of the revision (Attachment 3).
2.3.2.2.3 Each implementation requirement shall l
be determined to be conservative or nonconservative with respect to existing requirements. This determination shall be reflected on Attachment 3.
If a 4
single procecure has revistor s that are conservative and nonconservative, then separate listings of the procedure and i
revisi ta shall be made (including a description of each type of change). describes conservative and nonconservative i=plementation requirements.
2.3.2.3 An independent review of the draft operating license change shall be perforced by another qualified staff member.
Concurrence with the findings af the first reviewer shall be noted by the signature of the second reviewer.
2.3.3 Following these reviews, the responsible superviser shall sign,-
indicating concurrence, and forward the draft operating license change to-Regulatory Compliance.
(The supervisor may also be either the preparer or independent reviewer.)
2.3.4 Reg'ulatory Compliance shall review the comments to determine if a revision to the draft change package is required.
[
2.3.5 If a revision 15 required, Regulatory Compliance shall forvard l-the revised package to NLS for revision.
2.3.6 As required-by the nature and extent of the revision, Regulatory Compliance will provide the af fected units /subur'ts with a copy of the Attachment 3 documenting their previous review and the revised pages with a new copy of Attachment 3 upon receipt of the revised pages from N1.S.
O RCI-02.1 Rev. 4 page 6 ef 17 l
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3 2.3.7
- he affected units / subunits shall review the revised package to Jetermine if any additions or deletions are required to the listings previously provided in accordance with Section 2.3.0 and shall forvard the new and previous review packages to Regulatory Compliance.
l 2.3.8 Regulatory Compliance sheuld review the units / subunits' review of the draf t operating license change documented on Attachment 3.
This review is to assure the units / subunits review identified 1 plenentation requirementt regarding new or deleted surveillances. Any apparent omissions shall be resolved with the responsible units / subunits and entered onto the appropriate Attacheent 3 as necessary. Procedure compliance with surveillance requirements is vested with the unit / subunit responsible for the implementing procedure, and this responsibility is not diminished by the Regulatory Compliance review of the Attachment 3.
2.3.9 Regulatory Compliance shall review the license change package for completeness and shall sign Item 12 of Attachment 1 1-indicating concurrence.
2.4 -Approval-2.4.1 Regulatory Compliance shall route the draft operating license change to appropriate managers / directors, or their designees.
l for their approval.
l 2.4.2 The proposed eperating license chanee package shall be 4
presented _to PNSC by Regulatory Compliance, or by an alternate group as the level of detail dictates, for approval (Item 13 of ).
l 2.4.3 The package.shall be routed to the General Manager for reviev l
and approval (Itec: 14 of - Atcachcent 1).
l 2.4.4 The package shall be routed to the Vice President - Brunswick 1
Nuclear Project for approval (Irem 15 of Attachment 1).
2.4.5 After approval by the Vice President - Brunswick Nuclear Project, a copy shall be sent to Corporate Nuclear Safety (CNS) for their independent review.
If major changes result from the CSS re' view, t!.1 appropriate section of this instruction shall be entered to assure proper review.
4 NOTE:
CSS concurrence may be obtained_after sub=ittal of the proposed change to the NRC at the discretion of the Director - Regulatory Cempliance (see Section 2.5).
However. CNS approval shall be verified upon the receipt of the resulting license amendment from the NRC in accordance with RCI-02.2.
O RCI-02.1 Rev. 4 Page 7 of l'
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2.4.f
'?pon notification _ af CNS concurrence, NLS shall be notified of the approved draft operating license change and any plant /CNS revisions.
2.5 Assign =ent of Action Items t
2.5.1 Regulatory Compliance shall, following submittal to the NRC, assign actions items in accordance with RCI-05.2 for impiscentation requirements based on the listings provided by l
Section 2.3.2 and, as applicable Sections 2.3.7 and 2.3.8.
A : c,,
- f the Atta:h:ent 2 :r etht: 3::ucentati:n, as applicable, shall be provided with the action item assignment.
2.5.1.1 The due dates assigned f or the conservative imple en-cation requirements shall be established consistent, with the earliest anticipated date for NRC approval.
2.5.1.2 For nonconservative implementation requirements, the i'
action item assignments shall clearly state implemen-tation after NRC approval. These action itets shall not be issued nor entered into <3a FACTS data base until after NRC issuance of the amendment.
(These action item assignments should be retcined in the appropriate license change file until the resulting license amendment-is issused by the NRC.)
i 2.6 E:ergency License Changes Emergency or exigent license changes (10CTR50.91) or other license changes that, at the discretion-of the Director - Regulatory Compliance, require expeditious handling may be processed independent of the sequence of steps presented by this instruction.
The above instruction steps shall ultimately be completed _in a manner and sequence consistent with the nature of the requested change. However, a safety evaluation, two nuclear safety reviews, and PNSC and CNS approval shall be completed prior to implementation of the license amendment consistent with-Technical Specification Section 6 and RCl-03.1.
j The ti e necessary to process am e=ergency or exigent license change may l
not be suf ficient to prevent a shutdown or delayed startup of the plant.
In these cases, relief from Technical Specification LCOs eay be requested. An outline of a method to obtain such-relief is provided by J.
2,7 Docu=entation 2.7.1 Regulatory Compliance should retain in the proposed operating license change package the following:
2.7.1.1 Request for Operating License Change (Attachment 1) 2.7.1.2 Safety evaluation O RCI-02.1 Rev. 4 Page 8 of 17 i
0.7.1.3 Draft eperating license change-
'l
- 7.1.4 Technical review documentation (Attachment 3) 2.7.1.5 CNS letter documenting concurrence, as appropriate 2.7.1.6 NRC submittal 2.7.1.7 TACTS action item assignments initiated per Section 2.3.14, or reference to the TACTS number 2.7.2 k' hen the license change package is ready to be closed out, the following as a minimum, should be sent to the vault to be filed with the applicable accendment; 2.7.*2.1 Request for operating license change (Attachrient 1) 2.7.2.2 Safety evaluation 2.7.2.3 Technical review documentatien (Attach ent 3) l l
l O RCI-02.1 F.ev.
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i ATTACRMENT l TSC 8 REOUEST TOR OPERATING LICENSE CHANGE TSI #
r (if applicable) l 1.
Unit (c) Affected: Unit 1 Unit 2 y
2.-
License Section or Specification Af fected:
No.
Subject 3.
Description of Change (attach marked-up pages of existing operating license or Technical Specification):
4 Reason and Justification for Change (attach additional pages as necessary):
5.
_Safetv Evaluation Completed and Attached:
6.
Significant Ha:ards-Consideration Completed and1 Attached:
7.
OutaBe Related orl Impact on Operations No __ Yes __ Required Due Date I
-t 8.
Originator / Preparer:-
Date:.
9.
First Party Nuclear Safety Reviewer Date:
10.
Second Party Nuclear Safety Reviewer:
Date:
11.
Supervisor:
_ Date:
12.
Regulatory Compliance Review Date:
13.
PNSC Review:
Date:
14 General Manaeer Approval:
Date:
15.
Vice President - 3runswick Nuclear Project Approval:
Date:
0 RCI-02.1 Rev.
Page 10 ef 17
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AT*AC W.ENT 2
' ':,0:CE TO JUSTIFY A TECHNICAL SPECIFICATION CHANGE (TSC)
The requested TSC should contain sufficient information and justification that could be extracted by the NRC to develop the safety evaluation accompanying the license amendment.
The draft TSCs are developed by the Nuclear Licensing Section (NLS) in Raleigh, it should not be assumed that NLS is familiar with any astect of the TSC including the need for the TSC, associated plant modifications, saf ety impact, etc.
In order to provide sutticient information to NLS f or development of an adequate draf t TSC. the requested change should l
include, as appropriate but not limited to, the followingt 1.
Description of the Requested TSC This should include marked-up pages of the Technical Specification with the specific wording requested.
2.
Description of the current system Configuration / Operation Instrument Se tpoints, Surveillance Intervals, Etc.
Reference should be made to appropriate Updated FSAR sections, system descriptions, etc. Copies of certain procedure pages and drawings may be useful.
3.
Description of the proposed System Configuration / Operation Instrument l
Setpoints. Surveillance Intervals Etc.
This' discussion should be specific to the changes required for the l_
Technical Specifications.
4
-Benefit of the Requested TSC This description should present the benefits CP&L vould receive from the i
requested TSC such as operational flexibility fer maintenance or l
modifications, reduction of critical path outage time and manpower-requirements, personnel does reduction, and clarification of Technical l
Specifications.
5.
Safety _ mpact' of Proposed TSC This should present why the current margin of safety at CP6L vould not be significantly reduced.
Examples weald be:
increased equipment reliability, minimized equipment degradation, minimized' plant shutdowns / transient-and no effect on equipment operability or setpoints.
6.
Date License Amen' ent Required Describe the date and reasons that require the requested license amendment to be issued by the NRC on a certain date.
O RCI-C:.1 Rev. 4 Page 11 of M j
ATTACHMENT 3 PROPOSED OPERATING LICENSE CRANGE TECHNICAL REVIEV
. Unit 1:l Date:
Unit 2:
TSC:
- Operating License Section or Technical Specification
Reference:
To:
Please' complete the required entries belov and return this form to Regulatory Compliance by A.
Cemments (Attach additional sheets as required.)
i B..
Ieplementation Recuirements (Attach additional shee's as required.)
c CONSERVATIVE _
TECH SPEC.-
PROC./
DESCRIPTION REVISION SECTION NO.
MOD NO.
TITLE
-OF REVISION YES/NO l'
Prepared By:
Date:
Reviewed By:
Date:
Supervisor:
Date:
0 RCI-02.1 Rev. 4 Page 12 of.7 l
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i ATTACEF.ENT 4 GUIDELINES FOR PERTCR. MING REVIEW OF PROPOSED CTIKATING LICENSE CHANCES INCLUDING TECHNICAL SPECIFICATIONS 1.
Is the proposed Technical Specification change technically accurate (i.e., does the proposed Technical Specification reflect the plant I
design *)?
2.
Does the proposed Technical Specification change address required changes in other related Technical Specification sections (Index, Surveillance Requirements, Basis, etc.)?
i 3,
Is the proposed Technical Specification change clear and unambiguous with respect to its requirements (including surveillances) and actions to be taken if requirements cannot be met?
4 Is the proposed change consistent with similar existing requirements?
i 1
5.
Are the discussions provided in the Applicable Basis secticn adequate?
l 6.
Have changes to surs-111ance procedures resulting from this Technical Specification change been identified and listed in the enclosure?
I 7.
Have changes to non-surveillance procedures resulting from this Technical Specification change request been identified?
I 6.
Have modifications which are required to imple:ent the Technical Specification change been identified?
- Actual installed configuration or post-modification configuration.
1 0 RCI-02.1 Rev. 4 Page 13 of 17 l
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-A ATTACEKENT $
CONSERVATIVE AND NONCONSERVATI.E A conservative implementation requirement is generally more restrictive than existing Technical Specifications, such as additional or more frequent surveillance requirements, and may be implemented prior to the FRC approval of the requested license amendment. A nonconservative implementation requirement is generally less restrictive than existing Technical Specifications, such as a lover tank volume, and say not be implemented prior to NRC approval of the requested license amendment. The following test can be used-to determine whether an imple:enting requirecent is conservative or nonconservative:
If the implementation requitecent was implemented prior to approval of the requested license amendment by the NRC. vould the existing Technical Specifications be violated?
If the ansver is yes. then the implementation requirement is nonconservative and Attachment 3. Section B. should b' marked "no."
If the answer is no, then e
the implementation requirement is conservative and Attacheent 3, Section B, should be marked "yes."
Implementation requirements vill generally be scheduled in accordance with RCI-02.2.
O ROI-02.1 Fev. 4 Fage N ef 17
'ATTACEMENT 6 RT :'!!R' YENTS FOR t*RCTNT RTLIET TROM TECHNICAL SPECITICATIONS A.
Init14. Requirements 1.
Must be in snort duration LCO action statement requiring shutdown or delaying startup.
l 2.
Must be oeyeno licensee's control and could not have reasonably been-anticipated.
{
3.
Energency T/S is to be requested.
8.
Precess for Requesting Relief l
1.
Must provide written submittal justifying operation / continued l
operation to NRR Assistant Director. Division of Licensing prior to l-LCO expiring.
a.
Provide a justification for continued operation from the expiration of the LCO action time until the issuance of i
emergency T/S change (two working days normally).
l 4
2.
Requires concurrence of Region 11 Regional Division Director.
l 3.
Vaiver vill be documented by NRR.
4.
NRR DOL to process energency T/S expeditiously.
5.
If a significant hazard consideration is determined to exist by NRA.
the vaiver vill be retracted ittediately and the requirements of LCO action statement taken.
i t
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O RCI-02.1 Rev. 4 Page 15 of 17
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ATTACKMINT 7 i
EXAPJLES OF AMENDMENTS TRAT ARE CONSIDERID LIKELY TO INVOLVE SIGNITICANT RAZARDS CONSIDERATIONS 1.
A significant relaxation of the criteria used to establish safety limits.
2.
A significant relaxation of the bases for lietting safety system settings or limiting conditiens for operaticn.
3.
A significant relaxatian in limiting conditions for operation not accempented by compensatory changes, cendittens. or actions that maintain a "mmensurate level of safety (such as allowing a plant to operate at full power during a period in which one or more safety systems are not operable).
4 Renewal of an operating license.
5.
For a nuclear power plant, an increase in authorized maximum core power level.
6.
A change to technical specifications or other NRC approval involving a significant unreviewed safety question.
7.
A change in plant operation designed to impreve safety but which, due to other factor, in fact allevs plant operation with safety margins signsficantly reduced from those believed to have been present when the license was issued.
EXAM 2LES OT AMINDMENTS THAT ARE CONSIDERED NOT 1.IKELY TO INVOLVE SIGNITICANT RAZARDS CONSIDERATIlNS, 1.
A. purely administrative change to technical specificationst for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature.
2.
A change that constitutes an additional limitation, restriction. or control not presently included in the technical specifications:
for example, a sore stringent surveillance requirement.
3.
For a nue ear power reactor, a change resulting from a nuclear t. actor core seloading, if no fuel assemblies significantly different from these fouuo previously acceptable to the NRC for a previous core at the i'
facility in question are involved.
This assumes that no significant changes are made to the acceptance criteria for the technical
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specifications, that the analytical methods useo to demonstrate 2
conformance with the technical specifications and regulations are not l
significantly changed, and that NRC has previously found such methods acceptable.
l 0 P.CI-02.1 Rev. 4 Page 16 of !!
ATTACHMENT 7 (Cont'd) 4 A relie: granted upon demenstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet detenstrated. This assures that the operating restriction and the criteria to be applied to a request for relief have been established in a prior review and that it is justified in a satisf actory way that the criteria have been met.
5.
'Jpon satzstactory completion of constructicn in connection vitt. an operating facility, a relief granted from an operating restriction that was impesed because the construction was not yet completed satisfactorily.
This is intended to involve only restrictions where it is justified that construction has been completed satisf actorily.
6.
A change which either asy result in some increase to the probability or consequences of a previously-analyzed accident or may reduce in sone way a safety margin but where the results of the change are clearly within all acceptable criteria with respect to the system or coepenent specified in the Standard Review Plant f or exatple, a change resulting f rom the application of a stall refinement of a previously used talculational model or design method.
7 A change to make a license conform to changes in the regulatiens where the license change results in very minor changes to facility operations clearly in keeping with the regulations.
A change te a license te reflect a miner adjusteent in evnership shares among co-owners already shown in the license, l
3 i
I O ECI-02.1 Rev, e rage 17 ef 17 i