ML20114A569

Safety Evaluation Supporting Amends 113,116,131,& 135 to Licenses DPR-19,DPR-25,DPR-29 & DPR-30

ML20114A569
Person / Time
Site:	Dresden, Quad Cities
Issue date:	07/24/1992
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20114A566	List: ML20114A563 ML20114A569
References
NUDOCS 9208120096
Download: ML20114A569 (5)

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NUCLEAR REGULATORY COMMISSION

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SAFETY EVALVATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION j

i RELATED TO AMEN 0 MENT-NO. 116 TO FACILITY OPERATING LICENSE NO. DPR-19.

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AMENDMENT NO. 113 TO FACILITY OPERATING LICENSE NO. DPR-25.

j AMENDMENT NO. 135 TO FACILITY OPERATING LICENSE NO. DPR-29.

AND AMENDMENT _NO. 131 TO FACILITY OPERATING LICENSE NO. DPR-30 i

COMMONWEALTH EDISON COMPANY l

AND t-IOWA-ILLIN0IS GAS AND ELECTRIC COMPANY-DRESDEN NUCLEAR POWER STATION. UNITS 2 AND 3 i

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OVAD CITIES NUCLEAR POWER STATION.' UNITS 1 AND 2 i

f DOCKET NOS. 50-237. 50-249. 50-254. AND 50-211

1.0 INTRODUCTION

By letter dated May 7,1992, Commonwealth Edison Company-(the licensee, Ceco) i proposed changes to the Technical Specifications (TS) for all twelve Ceco operating units (six nuclear stations). As a result of the staff's review, in i

a letter dated July 1, 1992, CECO provided clarifications-to information L

provided in the original submittal.' The proposed amendments consist of administrative changes which-revise the types of procedures that require i.

review by the Onsite Review and-Investigative Function (OnSR&IF), specifies the level of review and approval for procedures governed by the proposed Technical Review and Control process, and clarifies the authority assigned to the OnSR&IF.

In addition, editorial changes _have been proposed'to provide clarity, eliminate extraneous references to-specific organizational titles and provide conforining changes to the proposed administrative changes..Among the

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editorial changes is the relocation of' report distributions to_ station procedures. All six of the stations' Section 6 OnSR&IF descriptions: are being'.

standardized to the current Byron _and Braidwood descriptions, as modified by the licensee'.s submittal.

The. staff's review of-the acceptability of these proposed changes for Dresden Units 2 and 3 and Quad Cities Units 1 and-2 is addressed in this Safety Evaluation.

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-2.0-EVALUATION The OnSR&IF primary responsibility is to conduct a critical and thorough review of the items identified in Section 6 of the TS under the OnSR&IF.

Procedures review is one of the OnSR&IF areas of responsibility identified, l

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and one of the TS changes proposed by Ceco would limit the review of procedures by the OnSR&lF to the applicable administrative procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, and the Emergency Operating Procedures.

In addition, those procedure revisions which I

are determined to require a safety evaluation (10 CFR 50.59 review) would also be reviewed by the OnSR&IF.

RG 1.33, Revision 2, Appendix A, provides a listing of the typical safety related activities that should be covered by written procedures for pressurized water reactors and boiling water reactors.

9 e major categories identified in Appendix A which require procedures are:

g) administrative, (2) general plant operations, (3) startup, operation, and shutdown of safety related PWR and BWR systems, (4). abnormal, offnormal, or alarm conditions, (5) combating emergencies and other significant events, (6) control of radioactivity, (7) for control of measuring and test equipment and for surveillance tests, procedures and calibrations, (8) maintenance performance, and (9) chemical and radiochemical control procedures. Under each category specific types of equipment, instrumentation, systems, programs, and events are identified for which procedures are required. CECO has stated that limiting the scope of procedures reviewed by the OnSR&IF will result in:

(1) key station personnel assigned to perform 40nSR&IF having additional time to conduct review of issues that affect nuclear safety; (2) expediting of the procedure review process; (3) procedural enhancements being implemented sooner than is achievable under the current process; (4) a reduced man power burden to effect changes to procedures while i

maintaining adequate controls to assure an acceptable level of independent review is conducted, and (5) senior management having more time to devote to overseeing station operation and emergency issues that potentially could impact nuclear safety.

Procedures that do not require review by the OnSR&lf shall be subjected to review and approval under the proposed Technical Review and Control process.

The Technical Review and Control process consists of an independent review l

conducted by a qualified individual knowledgeable in the area affected other than the individual who prepared the procedure.

In addition to ensuring the procedure is technically correct, the technical reviewer will be responsible for determining if a cross-disciplinary review is required. The technical reviewer has the ability to increase discipline review requirements as-necessary to assure an adequate review is performed.

The requirements for a cross-disciplinary review ensures a comprehensive review is provided by qualified technical reviewers from other disciplines while not burdening these personnel with review requirements for which they can provide no added expertise. To assist the technical reviewer, Ceco has l

stated administrative controls will be established for determining if a cross-l disciplinary review is required.

Qualified reviewers to be used in the Technical Review and Control process -

will be designated by the Station Manager and will include the disciplines or.

i procedure category for which the individuals are qualified.

Each individual l

designated to perform these reviews will meet the appropriate experience 1

l qualifications of ANSI N18.1-1971, Sections 4.2 and 4.4.

CECO has also stated i

t that records will be maintained for procedure review performed in accordance with the Technical Review and Control Process-that are consistent with those established for existing procedure reviews.

In its July 1, 1992 submittal, Ceco stated that the overview of the Technical Review function will be provided through the Nuclear Quality Programs function and that the initial evaluation will be incorporated into the 1993 audit schedules.

The staff, as a result of its review of Ceco's May 7,1992 submittal, requested Ceco to provide clarifying information to adhess the issues identified by the staff.

Specifically, Ceco was requested to:

(1) identify in the TS the title of the individual that will receive copies of specified Onsite Reviews; (2) char terize the types of personnel involved in the investigation and review sr TS violations; (3) clarify the approval authority for the Technical Review function; (4) identify what organization provides the overview of the Technical Review function; (5) confirm that procedural controls governing the Technical Review function will be in place prior to implementation; (6) not delete the TS requirement limiting staff overtime for Dresden and Quad Cities Stations; and (7) not delete the Station Scurity Plan implementation from the TS for Dresden Station.

In its July 1,1992

/ submittal, CECO provided responses to the above issues that addressed the st.aff concerns. Ceco's response also modified the May 7, 1992, proposed TS submittal in areas the staff deemed were necessary to clarify the intent of the proposed TS change.

In addition, some editorial changes were included based on staff comments. The staff has reviewed Ceco's July 1, 1992, submittal and determined it adequately addresses the issues identified by the staff during its review of Ceco's original submittal.

The NRC staff has evaluated the proposed changes contained in Ceco's May 7, 1992 submittal and clarifications provided in its July 1,1992 submittal, related to the OnSR&IF procedures review function and the utilization of a Technical Review and Control process to review the remaining procedures. The staff has determined, based on our review, that the proposed changes are:

(1) consistent with the guidance contained in RG 1.33, Revision 2, Appendix A, (2) will decrease the workload of key station personnel assigned to the OnSR&IF, thus providing them more time to devote to safety related issues, (3) expedite the procedure review process which will be particularly beneficial for plants that have a significant procedures upgrade program backlog, (4) an acceptable method for the review of procedures that are not safety related that has been approved by the staff for other facilities (i.e.

River Bend, Clinton), and (5) the supplemental information provided by CECO in its July 1,1992, submittal adequately addresses the issues identified by the staff during its review and incorporates the appropriate changes into the proposed TS. On these bases the staff has determined these proposed changes are acceptable for the Dresden and Quad Cities Nuclear Stations.

The OnSR&IF descriptions in the TS are being standardized to the current Byron /Braidwood descriptions for all six nuclear stations.

As a result, editorial changes have been proposed to provide clarity, eliminate erroneous references to specific organizational titles, and to provide consistency (i.e., numbering, punctuation, wording) with the Byron /Braidwood TS.

Since

s 9 these are only editorial in nature, and do not result in substantive changes to-the TS, the staff finds them acceptable for the Dresden'and Quad Cities Nuclear Stations.

In addition, the following specific' changes have been proposeu by CECO to the Dresden and Quad Cities Stations' TS to-achieve greater consistency with the Byron /Braidwood TS:

1.

The requirement for offsite review of issues associated with noncompliance with NRC requirements is being expanded to include noncompliance with codes, regulations,-orders, technical specifications, and license requirements. This is an increase in the TS requiring offsite review involvements.

2.

A definition of Reportable Events is being included in Section 1.0 of the TS for Dresden that equates to Reportable Events associated with 10 CFR-50,73. This is-being added to clarify that.the involvement of the onsite and offsite review is limited to those-events associated with 10 CFR 50,73. This is consistent with the current Onsite and Offsite Review and Investigation Function requirements.

3.

The requirement for Offsite Review of " changes to the Fire Protection Program and implementing procedures" is unique to Dresden. The other five Ceco stations do not have this requirement. Generic Letters 86 and 88-12, which provide guidance on the removal of fire protection requirements from the -Technical Specifications,- require independent review and audit of the station fire protection program. CECO has stated these elements are adequately covered in other-Technical Specification requirements for Onsite Review (proposed Specification 6.2.G.2.b(5)), Nuclear Quality Program-Audit (Specification 6.2.G.1.b(8)), and independent fire protection and loss prevention audit (Specification 6.2.H).

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Part of-tne proposed TS revision for Quad Cities includes a provision which would-allow the delegation of the approval of audit agendas, checklist and-findings to. corporate staff or-supervision approved by the General Manager Quality Programs and Assessment. This provision is consistent with the current TS_ requirements at the other five stations.

5.

In a submittal dated August 9,1991, for-Dresden Units 2 and _3, Ceco-proposed-to revise Section 6,0 to incorporate a title change within Ceco's organizational _ structure. The title of Assistant Vice President (AVP) Quality-Programs and Assessment has been modified to General Manager (GM) Quality Pro; rams and Assessment. Ceco has stated this revision is necessary to. insure that Ceco's corporate organizational structure is-properly reflected in the Technical < Specifications and is-only administrative _in nature.and does not-affect' the secpe or-responsibility of the position. A similar change for Quad Cities and Zion has been proposed by Ceco in its May 7, 1992, submittal-which is the subject of this Safety Evaluation. As a result, this proposed

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f e change for Dresden is being included in the -staff's review of CECO's May 7, 1992, submittal which addresses Section 6.0 TS changes and more specifically similar changes for Quad Cities and Zion, rather than,as part of Ceco's August 9, 1992, submittal. Ceco incorporated this change into its May 7 1992, submittal since it had been previously requested and to maintair consistency with the submittals for the other stations.

The staff has reviewed these proposed changes and determined that item 1 results in an increase in requirements as currently stated in the TS and is, therefore, acce) table for the Drerden and Quad Cities Stations.

Item 2 results in no c1ange to the requirements as currently stated in t'e TS and is, therefore, acceptable. Since Item 3 is adequately covered in other sections of the TS there is no need for Offsite Review and the proposed deletion of this requirement for Dresden Nuclear Station is acceptable.

Item 4 will make the Quad Cities TS associated with this requirement consistent with the requirements currently in effect at the other Ceco stations and is, therefore, acceptable.

Item 5 is only administrative in nature since it results in no change to the function performed by the individual within the corporate organization and is, therefore, acceptable.

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3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the propc ed issuance of the amendments.

The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth ;n 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.

5.0 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 amendments will not be inimical to the common defer e and security or to the health and safety of the public.

Principal Contributor:

Byron L. Siegel Date: July 24, 1992

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