ML20112D287
| ML20112D287 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/30/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20112D282 | List: |
| References | |
| NUDOCS 9606040197 | |
| Download: ML20112D287 (7) | |
Text
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,o UNITED STATES g
j NUCLEAR REGULATORY COMMISSION I
WASHINGTON, D.C. 20eedH1001
'*****/
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION BELATED TO AMENDMENT NO. 145TO FACILITY OPERATING LICENSE NPF-35 AND AMENDMENT NO. 1370 FACILITY OPERATING LICENSE NPF-52 DUKE POWER COMPANY. ET AL.
CATAWBA NUCLEAR STATION UNITS 1 AND 2 DOCKET NOS. 50-413 AND 414
1.0 INTRODUCTION
By letter dated January 12, 1995, as supplemented by letter dated June 29, 1995, Duke Power Company, et al. (the licensee), requested changes to the Catawba Nuclear Station, Units 1 and 2, Technical Specifications (TS).
The l
requested changes would revise portions of TS Section 6.0, " Administrative Controls."
A major feature of these revisions is to reflect the onsite Plant Operating Review Committee (PORC) in.the Catawba TS. This is accompanied by a program description of PORC activitWs in the Final Safety Analysis Report's (FSAR's)
Selected Licensee Commitment (SLC) Manual. These changes integrate the PORC activities, as discussed in Catawba regulatory documents, with the Qualified Reviewer Program (QRP) activities, corporate Nuclear Safety Review Board (NSRB) activities and the Quality Assurance Program (QAP).
Provision for appointment of the PORC have previously been made in the QAP Topical Report (Section 17.3.3.2.2), as have provisions for PORC recordkeeping (Section 17.3.2.15) and the PORC governing procedures (Section 17.3.2.14).
A second major feature of these revisions is to transfer certain other provisions of the Administrative Controls from the TS either to the FSAR's SLC Manual or to the licensee's Quality Assurance Program. The Quality Assurance Program commits to Regulatory Guide 1.33 t'iat endorses ANSI N18.7-1976,
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." ANSI N18.7 outlines administrative controls and quality assurance provisions for operating plants and similarly addresses the review and audit functions currently described in the TS. As discussed later in Section 2.3 of this evaluation, subsequent changes to these provisions would be made pursuant to 10 CFR 50.59 for FSAR SLC issues and pursuant to 10 CFR 50.54 for Quality Assurance Program (QAP) issues.
A third feature of these revisions is to make numerous editorial changes to clarify the language of the TS, to resolve inconsistencies, and to reformat TS sections.
9606040197 960530 PDR ADOCK 05000413 P
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. 2.0 EVALUATION l
2.1 Technical Review and Control Activities The licensee proposes to modify TS 6.5.1 to integrate the TS Administrative Controls with those matters that have been relocated to the SLC or to the QAP.
A new paragraph at the beginning of TS Section 6.5.1 establishes programs for "the preparation, review, approval and retention of documents required by the activities described in Specifications 6.5.1.1 through 6.5.1.11."
A new Section 16.13-2, " Technical Review and Control" has been added to the FSAR SLC Manual to accommodate the activities transferred to the FSAR SLC and a new Section 16.13-3, " Plant Operations Review Committee" has been added to the FSAR SLC manual to describe the PORC makeup, its functions and reporting relationships.
l The term " Qualified individual / organization" appears in six locations in TS i
6.5.1.
The licensee proposed to replace this with the term " knowledgeable individual / organization." The licensee characterizes this as an administrative change to avoid confusion with the licensee's Qualified Reviewer Program and, as such, it conveys no change in the required qualifications of those who perform these activities. Therefore, these changes are acceptable.
In addition, for TS 6.5.1.6 and TS 6.5.1.7, a-requirement for review of the subject report by " knowledgeable individual / organization" has been added.
This establishes consistency of the requirements for TS 6.5.1.6 and TS 6.5.1.7 with the other activity review I
requirements 'in TS 6.5.1. and is acceptable.
l Currently, both of the terms " individual / organization" and " individual / group" are used in TS 6.5.1.
The licensee proposes to replace the five usages of l
" individual / group" in TS 6.5.1 with " individual / organization." This is an l
editorial clarification of language to achieve consistency and is acceptable.
TS 6.5.1.1 on preparation of procedures and programs, TS 6.5.1.4 (formerly TS 6.5.1.2) on preparation of TS, and TS 6.5.1.2 (formerly TS 6.5.1.3) on preparation of modifications, require that the activity "be reviewed by an l
individual / organization other than the individual / organization which preparcd l
the change, [but who may be from the same organization as the individual / group.
b which prepared the proposed change)." The latter portion of this phrase within brackets is redundant to the preceding portion and is deleted to improve the clarity of the TS requirement.
This is an editorial clarification of language and is acceptable.
TS 6.5.1.1 is modified by the addition of the statement " Procedures or changes thereto, shall be approved in accordance with Specification 6.8.2 and 6.8.3."
l This provides emphasis that, among the documents subject to the newly added paragraph under the heading for TS 6.5.1, requirements for procedures are specifically addressed by TS 6.8.1 and TS 6.8.2.
Thus, this change is an editorial cross referencing to other applicable TS and is acceptable.
TS 6.5.1.3 (formerly TS 6.5.1.4) includes the phrase " site supervisory staff" which is changed to " supervisory staff assigned to the site." This is an 4
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editorial clarification of language and is acceptable.
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- Transferral of Reauirements from TS The first three sections of TS 6.5.1 address the preparation of procedures and programs (TS 6.5.1.1), proposed changes to the TS (formerly TS 6.5.1.2, now TS 6.5.1.4), and proposed modifications (formerly 6.5.1.3, now 6.5.1.2).
The next sequential TS section (formerly TS 6.5.1.4, now TS 6.5.1.3) then established requirements for individually accomplished reviews of these three activities. With the transfer of the requirement for NSRB review of TS changes to the QAP and the establishment of PORC review of proposed TS changes in the SLC, TS 6.5.1.3 has been modified to make it applicable only to procedures, programs, and modifications. The licensee's Qualified Reviewer Program applicable to the review of procedures, programs, and modifications is unchanged by this amendment. This is consistent with the establishment of PORC as reflected in the TS, in the FSAR SLC Section 16.13-3, and the QAP l.
Topical Report. The Duke Power Company QAP Topical Report, Amendment 20, provides amplifying details on the station organizational structure.
QAP Section 17.3.2.2 defines the final approval authority for station modifications.
QAP Section 17.3.2.14 defines the approval authority for changes to station TS and for station procedures.
Future changes to the QAP are under the control of 10 CFR 50.54(a). The licensee stated that there will i
be no decrease in the level of quality given to the review and approval activities.
Further, personnel performing the reviews will continue to meet the same qualification requirements of ANSI N18.1-1971. The staff finds these changes to be acceptable as the QAP contains sufficient controls to ensure that the reviews are performed by qualified personnel.
l TS 6.5.1.2 (previously TS 6.5.1.3) on the preparation of modifications' is modified by transferring the designation of the approval authority for implementation of modifications to the FSAR SLC Manual, specifically SLC Section 16.13-2b. The licensee attached a copy of SLC Manual Section 16.13-2 to its application dated January 12, 1995, for information. The SLC Section i
is maintained as Section 16 of the FSAR.
TS 6.5.1.4 (formerly TS 6.5.1.2) on changes to the TS is modified by l
transferring the requirement that " proposed changes to the TS shall be approved by the Station Manager," to the SLC, specifically SLC Section 16.13-2.b.
TS 6.5.1.5 on proposed tests and experiments, which affect station nuclear safety and are not addressed in the FSAR or the TS, has been modified in two l
respects.
First, it has been modified to require preparation and approval in a manner identical to that of TS 6.5.1.1.
This subjects these tests and experiments to the TS 6.5.1.1 requirement for preparation by a knowledgeable individual / organization and to the requirement for development of procedures pursuant to TS 6.8.1.
This is consistent with the requirements for Procedures and Programs previously established pursuant to TS 6.5.1.1 and is acceptable.
The second change is that the requirement for review of these proposed tests l
and experiments has been transferred from the TS to the SLC, specifically to SLC Section 16.13-2.e where it is assigned to the PORC. Also, the requirement for the PORC now established in SLC Section 16.13-3, establishes the Station Manager as a member and it also specifies the PORC in Section 16.13-3.a.1 as 9
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being responsible for the review of such test and experiments which affect nuclear safety and are not addressed in the FSAR or TS.
Reoorts The TS listed below have been modified to transfer, from the TS to the FSAR SLC Section, the requirements for the Manager of Safety Assurance to assure that certain activities are performed. The current and former TS item number, the issue, and the SLC to which the requirement is transferred are as follows:
TS 6.5.1.6 Reports on Reportable Events and TS violations, SLC 16.13-2.f TS 6.5.1.7 Special reviews and investigations, SLC 16.13-2.g l
TS 6.5.1.8/TS 6.5.1.10 Unplanned Onsite releases, SLC 16.13-2.h l
l TS 6.5.1.9/TS 6.5.1.11 Changes to PCP, ODCM and Radwaste Treatment Systems, SLC 16.13-2.1 TS 6.5.1.10/TS 6.5.1.12 Fire Protection Program SLC 16.13-2.j There is no regulatory requirement for the Manager of Safety Assurance, by specific title, to perform these functions. TS 6.5.1.11 will ontinue to l
require that all of these reports be prepared. The QAP Section 17.3.2.13 requires that for significant events which are or could be related to safety, reports are generated.
The QAP further requires that the Manager Safety Assurance approve such reports and provide them to the Site Vice President, I
the PORC, and to the NSRB. On this basis, the staff concludes that the former TS provisions for such reports have been replaced with equivalent provisions in the revised TS, the SLC, and the QAP and that these changes are acceptable.
'Reoorts to NSRB TS 6.5.1.6, 6.5.1.8, and 6.5.1.10 formerly required that reports developed as
-a result of these activities be provided to the Nuclear Safety Review Board (NSRB). With the transfer of these requirements to the SLC, such reports will now be transmitted to the PORC and to the Director, Organization Effectiveness. This reflects the establishment of the PORC and is consistent with the appropriate level of responsibility for corrective action and oversight of these issues and is acceptable, j
The'TS 6.5.1.11/TS 6.5.1.13 requirement for copies of reports developed on TS 6.5.1 activities to be provided to the NSRB has been transferred to SLC Section 16.13-2.k.
The NSRB, pursuant to TS 6.5.2.8.1, remains responsible to review reports generated as a result of all TS 6.5.1 activities. The NSRB continues to l
report to and advise the Senior Vice President, Nuclear Generation. As i
appropriate mechanisms will be implemented to perform independent reviews in j
accordance with ANSI N18.7, the staff finds these changes acceptable.
, NSRB Meeting Frecuency TSL6.5.2.6 is revise'd to change the NSRB meeting' frequency from at least once per 6 months to twice per year. The staff finds this change acceptable as it is consistent with that described in Section 4.3 of ANSI N18.7-1976,
" Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" that has been endorsed by Regulatory Guide 1.33.
NSRB Review of TS The TS 6.5.2.8.d on responsibility of the NSRB to review proposed changes in the TS is relocated to SLC 16.13-2.d.
The requirement that the PORC review proposed changes to the TS has also been added to SLC 16.13-2.d.
All other j
NSRB responsibilities in TS 6.5.2.8 are unchanged by this amendment.
The NRC staff's position is that such requirements should also be relocated to the Quality Assurance Program (QAP) in order that future changes would be governed in accordance with 10 CFR 50.54(a).
The basis for this position is that independent review functions, such as the NSRB function, are already described in the QAP via commitments to Regulatory Guide 1.33 and ANSI N18.7-1976, " Administrative Control and Quality Assurance-for the Operational Phase of Nuclear Power Plants." Changes to the QAP are governed by 10 CFR 50.54(a) that requires that QAP changes, which are reductions in commitment, are submitted for NRC review prior to licensee implementation.
NRC Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," further describes the logic for inclusion of these types of administrative controls into the QAP.
The licensee has included a statement in the QAP, Revision 20, Section 17.3.3.2.1, that the NSRB " reviews proposed changes to the stations' technical specifications and operating licenses..."
The staff finds this change acceptable as the requirement for the NSRB to review proposed changes to the TS and operating license will be relocated to 1
and remain in force in the QAP.
Future changes to the QAP will be controlled in accordance with 10 CFR 50.54(a).
Miscellaneous and Editorial Chanaes Several other miscellaneous editorial changes are made within TS Section 6.5 for clarification purposes, to renumber TS sections due to line item deletions and additions, and to spell out the acronym, ODCM, to Offsite Dose Calculation Manual. These are acceptable as they are editorial in nature and enhance the clarity of the TS.
2.2 Plant Operatina Review Committee (PORC)
TS 6.8.1 has been augmented with requirements that procedures shall be established, implemented, and maintained for the implementation of the Technical Review and Control Program and the functioning of the PORC. The licensee proposes to implement the site Technical Review and Control Program in accordance with procedures and the description in SLC Manual 16.13-2.
The licensee indicates that the establishment of a PORC at the site will be an
, enhancement to the review process for significant operational activities.
The PORC will serve to provide a structure to assemble licensee personnel from functional units, such as engineering, to assist with the Station Manager's decision making process. The PORC will also provide increased management involvement of nuclear safety matters. The PORC has been successfully employed by other nuclear utilities.
SLC 16.13-2 describes the functions of the PORC including the review of proposed TS changes, proposed tests and experiments, which affect station nuclear safety, reports of incidents reportable pursuant to TS and violations of TS, special investigation reports, and unplanned onsite release of radioactive material reports.
The staff finds this proposed addition acceptable as it should serve to enhance plant safety and is in conformance with ANSI N18.7-1976 that has been endorsed by NRC Regulatory Guide 1.33, 2.3 Evaluation of Transferred Reauirements The NRC staff has recently issued Administrative Letter (AL) 95-06,
" Relocation of Technical Specifications Administrative Controls Related to Quality Assurance" that discusses recent changes made to the Commission's Regulations in 10 CFR 50.36 and the Commission's associated Final Policy Statement. The Statements of Consideration of the Final Rule for 10 CFR 50.36 (60 FR 36955) states that "LCOs that do not meet any of the criteria, and their associated surveillance requirements, may be proposed for relocation from the technical specifications to licensee controlled documents, such as the FSAR."
It also states (60 FR 36957) that "When a licensee elects to apply these criteria, some requirements are relocated from technical specifications to the FSAR or other licensee controlled documents.... Changes made in accordance with the provisions of other licensee controlled documents (e.g.,
QA plan, security plan) are subject to those specific requirements." The specific change control requirement for QA program content is 10 CFR 50.54(a) that requires NRC approval before the licensee can implement QA program i
changes, which constitutes a reduction in commitment.
Based on these recent revisions to 10 CFR 50.36, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and which are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can,be-removed from administrative controls. On the basis discussed above for the specific changes, the staff concludes that the relocated provisions are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.54 and 10 CFR 50.59' to adequately control future modifications to these provisions. Accordingly, the staff has concluded that these requirements may be relocated from the TS to the respective licensee-controlled documents.
i The staff finds the requested changes acceptable as they meet the appropriate acceptance criteria of Section 13.4 of NUREG-0800, the Standard Review Plan, and conform to the Improved Standard Technical Specifications.
3.0 S_TAlf_CMSULTAT_10ff In accordance with the Comissions's regulations, the South Carolina State official was notified of the proposed issuance of the amendments. The State official had no coments.
4.0 ENVIRONMENTAL CONSIDERATION
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The amendments change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet 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 amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, i
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.
4 Principal Contributors: Robert Martin Robert Gramm Date:
May 30, 1996
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