ML20117H632
| ML20117H632 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 08/26/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20117H625 | List: |
| References | |
| GL-83-33, GL-89-01, GL-89-1, GL-93-07, GL-93-7, NUDOCS 9609090346 | |
| Download: ML20117H632 (17) | |
Text
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UNITED STATES g
j NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. 20866 4001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 216 TO FACILITY OPERATING LICENSE NO. DPR-53 AND AMENDMENT NO.193 TO FACILITY OPERATING LICENSE NO. DPR-69 BALTIM0RE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT. UNIT NOS. 1 AND 2 DOCKET NOS. 50-317 AND 50-318 l
1.0 INTRODUCTION
By letters dated March 15, 1995, as supplemented by letters dated June 29, 1995, May 1, 1996, and May 15, 1996, the Baltimore Gas and Electric Company (the licensee) submitted a request for changes to the Calvert Cliffs Nuclear Power Plant, Unit Nos. I and 2, Technical Specifications (TSs). The requested changes would revise the TS Section 6.0, " Administrative Controls" to be consistent with the guidance provided in the Improved Standard Technical Specifications (STS) for Combustion Engineering Plants. Additionally, the amendments (a) allow the Shift Technical Advisor to perform dual roles, (b) establishes a TS Bases Control Program, (c) provides for a reduction in.the i
reporting requirements, and (d) provides an option for estimating occupational doses.
The June 29, 1995, letter provided the licensee's revised analysis of the issue of no significant hazards consideration that was evaluated by the NRC staff in its no significant hazards censideration determination. The May 1, 1996 and May 15, 1996, letters provided clarifying information that did not change the June 29, 1995, proposed no significant hazards consideration determination.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nucleer power plant operating licenses to state TS to be included as part of the license. The Commission's regulatory requirements related to the content of TSs 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 (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included-in the plant TSs.
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"), 58 Federal Register (FR) 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies f 182a of the Act.
In particular, the 9609090346 960826 PDR ADOCK 05000317 P
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l 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 safety functions are required to be included in the TS, as follows:
(1) installed instrumentation i
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) structure, system, or component that is part of the 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 j
accessment has shown to be significant to public health and safety.
The Commiss!cn recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate these criteria.
See Final Rule,
" Technical Specifications," 60 FR 36593 (July 19, 1995). As.a result, TS requirements which fall within or satisfy any of the criteria in the Final i
Policy Statement must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
10 CFR 50.36 provides that those existing TS LCOs 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, Quality Assurance (QA) Plan, and Emergency Plan) and controlled by the applicable regulatory requirement.
Similarly, while the required content of TS administrative controls is specified in 10 CFR 50.36(c)(5), particular details of administrative controls may be relocated to licensee-controlled documents where 550.54, 550.59, or other regulations provide adequate regulatory control.
While the criteria specifically apply to LCOs in adopting the revision to the rule, the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS, (60 FR 36958). Addressing administrative controls 10 CFR 50.36 states that I
they "are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure safe I
operation of the facility in a safe manner." The specific content of the l
___ __ administrative controls section'of the TS is that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 550.36(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 public health and safety, can be removed from administrative controls.
3.0 EVALUATION l
By letters dated March 15, 1995, as supplemented by letters dated June 29, 1995, May 1, 1996, and May 15, 1996, the licensee proposed changes to the Calvert Cliffs TSs that would:
(a) relocate and group specific requirements that are similar within the same TS section; (b) relocate specific requirements to other licensee-controlled documents; (c) remove or revise requirements that duplicate other regulations or specifications; (d) add new requirements to make TS Section 6.0 more consistent with the Improved STSs; (e) delete the requirements for submission of several reports; (f) replace.
film badge measurement with electronic personnel dosimetry; (g) permit a dual role for Shift Technical Advisor; and (h) make various editorial changes.
3.1 Relocation and Grouping of Similar TSs Requirements The licensee has proposed to relocate and group requirements of a similar nature in a manner that will facilitate an individual's use of the TSs. The licensee also proposed the modification of some requirements along with their 1
relocation. The proposed changes are as follows:
3.1.1 Relocation / Grouping Without Modifications (except minor editorial)
The staff finds the following changes proposed by the licensee to be acceptable since the changes reduce the duplication of requirements as currently specified in multiple TS sections or consolidate similar requirements to create a more concise format.
The proposed changes do not revise the actual requirements, l
a.
The requirements in TS 6.8.1.1 for procedures for implementation of the Offsite Dose Calculation Manual (0DCM) are relocated to new TS 6.4.1.c
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with reference to new TS 6.5.1.
b.
TS 6.9.1.5.b regarding the annual reporting of the results of steam generator tube inspections was deleted since the same requirements already exist in TS 4.4.5.5.b.
The specific reporting requirements are not changed.
c.
The reporting of a list of new locations for dose calculations identified 1
by the annual land use census pursuant to TS 3.12.2 was deleted from TS
1l 6.9.1.8.
This requirement for submission of new locations is already in TS 3.12.2.
Further, this information should be submitted in the Annual Radiological Environmental Operating Report as stated in TS 3.12.2.
d.
TS 6.9.2 requirements for submission of Special Reports pursuant to the requirements of other referenced TS sections were deleted.
The reporting requirements duplicated the requirements that already existed in TS Sections 3 and 4.
The proposed change does not revise the specific reporting requirements.
Due to this proposed deletion of TS 6.9.2, references to TS 6.9.2 in other sections were replaced by the controlling regulation,10 CFR 50.4.
The affected sections include: Table 3.3-6, Action 30; TS 3.3.3.4.a; Table 3.3-10, Actions 34 and 35; TS 3.3.3.7.b; TS 3/4.4 Bases; TS 4.4.5.5.a and i
c; Table 4.4-2; TS 3.4.9.3.d; TS 3.4.lla.3; TS 3.5.2.b; TS 3.5.3.b; TS 4.6.1.6.1.c; TS 4.6.1.6.4; TS 3.6.5.1.a.1; TS 3.7.11.1.a and b.2; TS 4
3.7.ll.2.a; TS 3.7.ll.,3.a; TS 3.7.11.4.a; TS 3.7.11.5.a; and TS 3.7.12.a.
e.
The requirements of TS 6.13, System Integrity, are relocated to new TS 6.5.3 and retitled, " Primary Coolant Sources Outside Containment" to be consistent with the wording in the specification.
f.
TS 6.15, Postaccident Sampling, and the associated footnote, relocated to new TS 6.5.2 to combine this requirement with other programs.
3.1.2 Relocation'With Other Changes The staff similarly finds the following changes proposed by the licensee to be acceptable since the changes reduce the duplication of requirements as currently specified in multiple TS sections or consolidate similar requirements to create a more concise format. The staff's evaluation of the other changes are discussed in the individual subsections below.
a.
TS 6.4.2 requires that Fire Brigade Training meet or exceed requirements of National Fire Protection Association (NFPA) Code 27, 1975 Edition (NFPA 27-1975) combined with proposed TS 6.2.2.e on fire brigade organization.
The statement that the training " meet or exceed" the NFPA 27 was changed to " meet" this Code and is acceptable since the staff only requires that the Code requirements be satisfied, b.
TS 6.7.1, Safety Limit Violation, is combined with action statements under both TS 2.1.1, Safety Limits - Reactor Core, and 2.1.2, Safety Limits -
Reactor Coolant System Pressure; thus, placing all necessary actions in one specification. Duplicated information was deleted and the actions reformatted. The abbreviation "0SSRC" (Offsite Safety Review Committee) was replaced by a more general term "offsite review function" to allow future name changes. The Safety Limit Violation Report is relocated to TSs 2.1.1 and 2.1.2.
d TS 6.9.1.4, TS 6.9.1.5.a, and Footnotes 1 and 2 are combined and relocated c.
to new TS 6.6.1 that is retitled, " Occupational Radiation Exposure Report." The submission date was also proposed to be changed from March 1 to March 31.
The staff finds this and the other editorial changes to be acceptable since the basic reporting requirements remain.
In this TS, the licensee proposed a change to electric personal dosimetry rather than current film badge measurements for estimating dose assignments to various duty functions. The staff finds the use of this type of dosimetry provides equivalent or better accuracy and the data is more easily attainable. Also, the licensee proposed replacing the word "shall" with "should" in the sentence regarding dose assignments to major work functions.
This dose assignment is an administrative function that is dependent on work activities, and the requirement provides only a guideline.
Thus, these changes are acceptable.
An additional change is a clarification in Footnote 1 indicating that the occupational dose from the independent spent fuel storage installation would be reported separately. This is also acceptable since this requirement is governed by the requirements of 10 CFR Part 72.
In Footnote 2, the reference to 10 CFR 20.407 was corrected to 10 CFR 20.2206.
d.
TS 6.9.1.5.c, regarding the reporting of failures and challenges to the pressurizer power-operated relief valves (PORVs) or safety valves, is relocated to new TS 6.6.6, Pressurizer PORV and Safety Valve Report.
For consistency with other annual reporting requirements, the licensee
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proposed the addition of words requiring the submission prior to March 1 of each year. The staff finds these. changes acceptable, since the 4
requirements remain the same, e.
TS 6.9.1.6, Monthly Operating Report is relocated to new TS 6.6.4 and the submission requirement is deleted. This is acceptable since it is adequately defined in 10 CFR 50.4.
f.
TS 6.13, System Integrity, is relocated to new TS 6.5.3 and retitled,
" Primary Coolant Sources Outside Containment." Footnote
- was,added to allow the licensee to maintain details of this program in plant operations manuals and procedures. The staff finds this an acceptable mechanism to control this program.
g.
TS 6.17.2, regarding licensee initiated char:es to the ODCM was reformatted and moved to new TS 6.5, Programs and Manuals.
Supplemental information was added to TS 6.5 to reference the controlling regulations and to conform with Generic letter 89-01. TS 6.17.1 will be deleted since the ODCM is already approved for implementation.
Since these changes do not reduce the current requirements and are consistent with NRC guidance, the staff fir.ds them acceptable.
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$ i h.
TS 6.18, regarding the inclusion of major changes to the Radioactive Waste Systems in the Radioactive Effluent Release Report was combined with other requirements from TS 6.9.1.8 for this report in new TS 6.6.3.
Additional TS 6.9.1.8 changes to the combined TS section are discussed in other sections of this evaluation.
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3.2 Deletion of Requirements That Duplicate Regulations or Are Not Required By Regulations a.
The licensee proposes to delete the requirement in TS 4.4.5.5.b for inclusion of the steam generator tube inservice inspection results in the Annual Operating Report since these results have no relation to the other information in the report and to change the submission date to March 1 of each year.
Since the licensee is not removing any requirement for 1
submission of information required by 10 CFR 50.4, the staff finds this change to be acceptable.
b.
Reference to the controlling regulation, 10 CFR 50.71(e), in TS 6.2.1.a for updating the organizational relationships and responsibilities was deleted to eliminate the potential for future changes should the i
regulation sections be renumbered. Also, the reference to the organizational relationships and responsibilities being documented in the Final Safety Analysis Report (FSAR) Chapter 12 was corrected to state the i
UFSAR. The chapter number was removed to facilitate future reformatting of the UFSAR. This change is acceptable in that compliance with the regulation is not altered and the organizational information'is controlhd i
under the UFSAR.
4 c.
Description and Requirements for Minimum Shift Composition 1.
The licensee proposes that the original TS 6.2.2.a and associated Table 6.2-1 be deleted from TSs since this duplicates 10 CFR 50.54(k), (1) and (m) requirements for shift complement for licensed reactor operators.
The regulations describe the minimum shift composition for operating modes, as well as for cold shutdown and refueling. The requirements in TS 6.2.2 reference the implementation of 10 CFR 50.54.
2.
A new general phrase that reads, "The unit staff organization shall include the following:" will precede the subsections in TS 6.2.2.
3.
Requirements for non-licensed operators in Table 6.2-1 are relocated to new TS 6.2.2.a.
4.
The qualification and duties of the Shift Technical Advisor (STA) found in note H to Table 6.2-1 along with the staffing requirement from Table 6.2-1 were rewritten as new TS 6.2.2.g.
In addition, the 4
i licensee has added a provision that allows an on-shift senior operating license holder who meets the Commission Policy Statement on Engineering Expertise on Shift to perform a dual role as the STA.
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1 The licensee's alternative position detailing the STA minimum education and training. requirements was replaced by a reference to TS 6.3.1.
The staff finds this acceptable since this information was already duplicated in original TS 6.3.1 and satisfies the
' Commission Policy Statement. The licensee has also clarified that the current note ## in the TS which allows an exception to the minimum STA educational requirements with certain manning conditions and plant operational mode conditions. The proposed TS 6.2.2.g reflects requirements that are currently within the Calvert Cliffs TS and requires NRC approval for individual exception to the minimum STA education requirements.
5.
The allowable period when the shift crew may be less than minimum requirements in Note #.to Table 6.2-1 was relocated to new TS 6.2.2.h.
Table 6.2-1 restated the minimum shift manning required by 10 CFR 50.54(m)(2)(1).. Since the Table is being deleted, the specific manning levels were replaced by a reference to the miniman requirements of 10 CFR 50.54(m)(2)(i) and references to TSs 6.2.2.a ar.d TS 6.2.2.g for non-licensed operators and STA, respectively.
6.
Note ** states that the licensed operator composition requirements in Table 6.2-1 assume that each individual is licensed on each unit.
This is modified to read, "Those licensed operators counted toward minimum shift crew composition required by 10 CFR 50.54(m)(2)(1) shall be licensed on both units," and relocated to new TS 6.2.2.1.
The intent of the basic requirement has not been changed and is acceptable. The modified requirement has been relocated as new TS 6.2.2.1, and is found to be. acceptable.
d.
Senior Reactor Operator (SRO) Supervision of Core Alterations i
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The licensee proposes that the requirement in TS 6.2.2.e and Note
- to Table 6.2-1 that an SRO be present during fuel handling and to supervise all core alterations not be retained in the TSs. This is required by i
10 CFR 50.54(m)(2)(iv) and need not be duplicated by TSs. The current regulation states:
"Each licensee shall have present, during alteration of the core of a nuclear power unit (including fuel loading or transfer), a person holding a senior operator license or a senior operator license limited to fuel handling to directly supervise the activity and, during this time, the licensee shall not assign other duties to this person."
This requirement is specified in the plant procedures which implement 10 CFR 50.54. The staff concludes that the regulatory requirements l
provide sufficient control of these provisions and removing duplication of j
them from TSs is acceptable.
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! The licensee proposes that the requirement in TS 6.6.1.a that the e.
Commission be notified of all reportable events not be retained in the TSs. The Code of Federal Regulations at 10 CFR 50.73(a)(2) provides requirements for the licensee to-submit an LER for all reportable events specified in 10 CFR 50.73.
The reports'are required to be submitted within 30 days and will contain the same type of information required by TS 6.6.
The above requirements are included in the licensee procedures I
which implement 10 CFR 50.72 and 10 CFR 50.73. The staff concludes that these regulatory requirements provide sufficient control of these provisions and removing duplication of them from TSs is acceptable. Also, the Plant Operations and Safety Review Committee (POSRC) review of these l
reports is included in the QA Policy.
l f.
TS Sections 6.8.1.b, 6.8.1.c, and 6.8.1.f with footnote
- regarding requirements for procedures on refueling operations, surveillance and testing, and fire protection are proposed to be deleted since they are l
. specified by NRC Regulatory Guide (RG) 1.33, Revision 2.
The reference to this RG remains in TS 6.8.1.a which would be renumbered as TS 6.4.1.a.
1 The staff has determined that the procedural requirements governing the implementation of these programs is adequately controlled by the regulations, NRC guidance, and the specific program plans.
g.
TS 6.9.1 and the title " Routine Reports" regarding the submission of reports to the Director of Regional Office of Inspection and Enforcement are proposed to be replaced with a statement that the reports shall be submitted in accordance with 10 CFR 50.4.
The staff concludes that the reference to the regulatory requirements is acceptable.
h.
Security Plan Implementation and Emergency Plan Implementation l
The licensee proposes to remove and relocate the requirements to establish, implement, and maintain procedures related to the Security Plan (TS 6.8.1.d) and Emergency Plan (TS 6.8.1.e).
Since the Security Plan requirements are specified in 10 CFR 50.54, 73.40, 73.55, and 73.56 and the Emergency Plan requirements are specified in 10 CFR 50.54 and 10 CFR Part 50, Appendix E, Section V, the staff in GL 93-07 recommended removal of these requirements from the STS and relocation to their respective plans.
Further changes in these review requirements r.:st be made in accordance with 10 CFR 50.54(p) for the Security Plan and 10 CFR 50.54(q) for the f.'mergency Plan. The staff concludes that, in conjunction with this change to the plans, the sufficient requirements for emergency planning in 10 CFR
!i0.47 and 50.54 and for security in 10 CFR 50.54 and 73.55 for drills, txercises, testing, and maintenance of the program, will be met.
The staff concludes that these regulatory requirements are sufficient and, j
therefore, removing these provisions from TSs is acceptable.
. 1.
Process Control Program Implementation The licensee proposes to relocate to plant procedures the requirements to establish, implement, and maintain procedures related to the Process Control Program (TS 6.8.1.h).
Plant procedure RP-2-100 implements the program and ensures compliance with the requirements for the transfer and disposal of licensed material and waste specified in 10 CFR Parts 20,'61, and 71. This program does not. fall within the criteria required by 10 CFR 50.36, and thus may be relocated. Since the regulations provide control over the program, the program is not being modified, and changes to the plant procedure are controlled under 10 CFR 50.59, the staff finds the relocation to be acceptable.
J.
The licensee proposed deletion of TS 6.11, Radiation Protection Program, that requires procedures for personnel radiation protection since the requirements are contained in 10 CFR Part 20. Specifically, the requirement to have procedures to implement 10 CFR Part 20 is contained within 10 CFR 20.1101(b). Periodic review of these procedures is i
addressed under 10 CFR 20.1101(c). The staff concludes that these regulatory requirements provide sufficient control of these provisions, the requirements are located in an approved program, and removing duplication of them from TSs is acceptable.
3.3 Relocation to Licensee-Controlled Documents
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t The provisions of the current TSs described below are not required by 10 CFR 50.36, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to public health and safety.
Further, they do not fall within any of the four criteria set forth in the Commission's Final Policy Statement. Accordingly, the staff has concluded that these requirements may be relocated from the TSs to the plant
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procedures, which implement the regulations, or the QA Policy, as applicable.
In addition, the staff finds that sufficient regulatory controls exist under 10 CFR 50.59 and 50.54(a) to control future changes and to assure continued protection of public health and safety.
The documentation for future changes to those provisions relocated from the TSs will be maintained by the licensee in accordance with the record retention requirements specified in their QA Policy. This approach ensures an auditable and appropriate control over the relocated requirements and future changes to these provisions.
Therefore, in accordance with the guidance in the policy statement, the licensee has proposed to relocate or reorganize all or portions of the following TSs to other licensee controlled documents:
a.
Inclusion in the UFSAR of plant-specific job titles for the personnel fulfilling responsibilities in the TS. Words to this fact will be included in TS 6.2.1.a and will allow other TS changes to make job titles more generic in the TS. The licensee proposed using the generic personnel titles as found in ANSI Standard N18.1-1971. TS Sections 6.2.1, 6.2.1.b, 6.2.2.g (changing to 6.2.2.f), and 6.17.2.b (changing to 6.5.1.c.2) will 1
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1 be revised to ch,ange: (1) the Plant General Manager'to Plant Manager, l-(2) Superintendent-Nuclear Operations to Operations Manager, and (3) General Supervisor-Nuclear Operations to General. Supervisor. These organizational relationships and responsibilities are documented, i
specified, and updated as appropriate in the UFSAR and the QA Policy.
Changes to the UFSAR and QA Policy are controlled by 10 CFR 550.59 and 4
j 650.54(a)(3),respectively.
Since the specific TS requirements for these positions are not changing and the titles are controlled in the UFSAR (QA Policy), the staff finds these changes to be acceptable.
1 b.
Removal of the statement from TS 6.4.2 (changing to 6.2.2.e) that Fire Brigade training be maintained under the direction of the Manager, Nuclear Safety and Plannino Department. Since the requirements for key personnel I
are included in the UFSAR (QA Policy), the staff finds this change 1
acceptable.
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c.
TS 6.5, Review and Audit The licensee proposed that the review and audit functions specified in TS 6.5, be relocated from the current TS on the basis that they are 4
adequately controlled by the QA program.
Similarly, the review and audit 1
functions for the security and emergency plans are relocated to their respective plans in accordance with Generic Letter (GL) 93-07,
" Modification of the Technical Specification Administrative Control Requirements for Emergency Security Plans." Additionally, NRC Administrative Letter, 95-06, " Relocation of Technical Specification Administrative Control Related to Quality Assurance, dated December 12, 1995, provides guidance for relocating TS administrative requirements.
The review and audit functions do not need to be controlled by TSs because an equivalent level of regulatory control can be achieved by the QA Policy while providing a more appropriate change control process.
Items in TS 56.5 relocated to the QA Policy, are items not necessary to assure safe operation of the plant. The level of safety of plant operation is unaffected by this change, and the NRC and licensee resources associated with processing license amendments pursuant to the existing administrative 4
controls may be used more effectively.
In addition, the following considerations support relocating these items from the TSs:
(1)
The onsite review function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and racords are all covered in equivalent detail in ANSI N18.7-1976. These requirements have been relocated without change to the QA Program, Addendum IB-1, and change control is provided by 10 CFR 50.54(a).
(2)
The offsite review group is also addressed, although with less detail, in ANSI N18.7-1976. The QA Program includes the requirements for the offsite review group, Addendum 18-1, therefore, duplicating the review and audit function of the offsite review group in the improved STSs is unnecessary.
These
_11 requirements have been relocated to the QA Program with an additional provision to permit the use of offsite review subcommittees. The subcommittee's membership will be comprised of selected offsite committee members. Change control for the offsite review committee require' ment is provided by 10 CFR 50.54(a).
(3)
Audit requirements are specified in the QA Program to satisfy 10 CFR Part 50, Appendix B, Criterion XVII. Audits are also covered by RG 1.33, ANSI N18.7, ANSI N45.2, 10 CFR 50.54(t), 10 CFR 50.54(p), and 10 CFR Part 73. Therefore, duplication of these regulatory requirements does not enhance the level of safety of the plant, nor are the provisions relating to audits necessary to assure safe operation of the facility. These audit requirements have been relocated to the QA Program and change control is provided by 10 CFR Part 50.54(a).
(4)
Although there are aspects of the fire detection and mitigation functions that have been determined to be risk significant, the minimum requirements for those functions are established in the regulations (10 CFR 50.48), with which the licensee must comply regardless of whether the requirements are restated in the TSs.
In addition, the staff has concluded that sufficient regulatory controls exist under section 50.54(a) for future changes to the review and audit provisions related to implementation of the fire protection program to assure continued protection of the public health and safety.
d.
Relocation of the TS 6.6.1.b requirements for review of Reportable Events by the POSRC and for submittal to the OSSRC and Vice President-Nuclear Energy to the QA Policy. The staff finds this change acceptable because future changes to the QA Programs are controlled under Section 50.54(a).
j e.
Relocate the description of the content of the Safety Limit Violation Report from TS 6.7.1.c to plant procedures. Since these procedures are controlled under 10 CFR 50.59 and the review requirements for this report is in the QA Policy, the staff finds this change acceptable.
f.
Relocate matters in TS 6.8.2, 6.8.3, 6.8.4, and 6.8.5 to the QA Policy for review, approval, and changes to procedures.
The licensee is proposing to relocate both the review and approval process (current TS 6.8.2) and the temporary change process (current TS 6.8.3) for procedures to the QA Program. This proposal is based on the existence of the following regulations and standards which duplicate TS 6.8.2-6.8.5 10 CFR 50.36 in these areas.
The requirements for procedure control are addressed in Criterion II and Criterion V of Appendix B to Part 50. ANSI N18.7-1976, as endorsed by NRC RG 1.33, is used in the development of licensee QA plans, also contains specific requirements related to procedures. The licensee has committed
i in its QA Program to follow ANSI N18.7-1976 as a means to comply with Appendix B to Part 50. ANSI N18.7-1976, Section 5.2.2 discusses procedure adherence. This section clearly states that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing.
ANSI N18.7-1976 also discusses' ten.porary changes to procedures, and requires review and approval of procedures to be defined. ANSI N18.7-1976, Section 5.2.15 describes the review, approval and control of procedures. This section describes the requirements for the licensee's QA Program to provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting quality.
The section further states that each procedure shall be reviewed and approved prior to initial use.
The required reviews are also described. ANSI N45.2-1971, Section 6, also specifies that the QA Program describe procedure requirements.
The licensee has proposed to relocate those provisions for review, approval and changes to procedures, that are not otherwise covered by regulatory requirements, to the QA Program. The TS requirements for controlling temporary changes have been relocated to the QA Program without change and include the following preexisting exception to ANSI N18-7. The SRO approving the temporary change is not necessarily the supervisor in charge of the shift. Also, the licensee is taking exception to the ANSI N18.7 biennial procedure review requirements and is utilizing the procedure review provisions provided in NRC Memorandum from Charles E.
Rossi to Distribution, " Biennial Procedure Reviews," dated December 21, 1992.
Items relocated to the QA Program are items not necessary to assure safe operation of the plant.
Future changes to the QA Program are governed by 550.54(a). The staff concludes that sufficient regulatory controls exist for the QA Program such that removing those provisions from the TSs and relocating them to the QA Program is acceptable, g.
The licensee proposes to relocate the details and submittal requirements in TSs 6.9.1.1 and 6.9.1.2 for the Startup Report to the UFSAR and plant procedures. The report is a summary of plant startup and power escalation testing following receipt of the Operating License, increase in licensed power level, installation of nuclear fuel with a different design or manufacturer than the current fuel, and modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the unit. The report provided a mechanism for NRC to review the appropriateness of licensee activities after-the-fact, but provided no regulatory authority once the report was submitted (i.e., no requirement for Commission approval).
The approved 10 CFR Part 50, Appendix B, QA Policy and UFSAR provide assurance that the listed activities are adequately performed and that approp:iate corrective actions, if required, are taken.
Given that the report was required to be provided to the Commission no sooner than 90 days following completion of the respective milestone, report completion and submittal was clearly not necessary to ensure operation of the facility in a safe manner for the interval between
I completion of the startup tssting and submittal of the report.
Additionally, given there is no requirenent for the Commission to approve the report, then the Startup Report is not necessary to ensure operation of the facility in a safe manner.
Based on these considerations, the Startup Report is being removed from TS and relocated to the UFSAR and plant procedures. Changes to these documents will be subject to the requirements of 10 CFR 50.59. This change is consistent with the Improved STS and is acceptable.
h.
The licensee propose.s to relocate to the ODCM that portion of TS 6.9.1.7 and Footnote * (changing to TS 6.6.2) that relates to the Annual Radiological Environmental Operating Report not covered by regulations.
In addition, the licensee proposes to add a statement that the material in this report shall be consistent with the objectives outlined in the 00CM and in 10 CFR Part 50, Appendix I, Sections IV.B.2, IV.B.3 and IV.C. The staff finds this to be acceptable since the 00CM controls the content of this report, the content of the report is not being changed, and the 00CM provides sufficient control of the recordkeeping. This is consistent with the guidance in Generic Letter 89-01, and the TS is not within the four criteria for safety of plant operation.
1.
The licensee proposes to relocate to the 00CM that portion of TS 6.9.1.8 (changing to TS 6.6.3) that relates to the content of the annual radioactive effluent release report not covered by regulations and change to an annual report.
In addition, the licensee proposes to add that the material in this report shall be consistent with the objectives outlined in the 00CM, the Process Control Program, and in 10 CFR~50.36a and 10 CFR Part 50, Appendix I, Section IV.B.1.
The staff finds this to be acceptable since the ODCM details the content of this report, the content of the report is not being changed, and the 00CM provides sufficient control of the recordkeeping. The change to an annual reporting period is also consistent with 10 CFR 50.36a. This material is not necessary for safe operation and its removal is acceptable. The staff also finds the addition of a reference to TS 6.5.1.c to be editorial and does not change this requirement.
J.
Record Retention The licensee proposes that the requirements in TS 6.10 on record retention be removed from the TS on the basis that they are adequately addressed by the QA Policy (10 CFR Part 50, Appendix B, Criteria XVII). These items relocated to the QA Program are items not necessary to assure safe operation of the plant. Change Control for the relocated TS record retention requirements is provided by 10 CFR 50.54(a).
Facility operations are performed in accordance with approved written procedures. Areas controlled by procedures include normal startup, operation and shutdown, abnormal conditions and emergencies, refueling, safety-related maintenance, surveillance and testing, and radiation control.
Facility records document appropriate station operations and
=
\\ activities. Retention of these records provides document retrievability for review for compliance with requirements and regulations. Post-compliance review of records does not directly assure operation of the facility in a safe manner, as activities described in these documents have already been performed.
In addition, numerous other regulations such as 4
10 CFR Part 20, Subpart L, and 10 CFR 50.71 require the retention of certain records related to operation of the nuclear plant. The staff concludes that these regulatory requirements provide sufficient control of these recordkeeping provisions and removing them from TSs is acceptable.
k.
The licensee proposes to relocate TS 6.12, High Radiation Area. This provides alternative methods for controlling access to areas in lieu of 10 CFR 20.203(c)(2) (revised to 10 CFR 20.1601 in current CFR). However, plant procedures control access to high radiation areas and reference 10 CFR 20.1601. Since the licensee must comply with this regulation and, j
specifically with 20.16Sitc) regarding Commission approval of alternative methods, the relocation of TS 6.12 to plant procedures is acceptable.
1.
TS 6.14, Iodine Monitoring, is proposed to be relocated to the UFSAR. The specific details for the program and its implementation are found in plant chemistry procedures, maintenance procedures, and ERPIPs with changes controlled under 10 CFR 56.59. This item is not necessary for safe plant operation and may acceptably be relocated to plant procedures.
j m.
TS 6.16, Process Control Program (PCP), is proposed to be relocated to plant procedures.
Since the PCP was previously approved by the staff and the licensee is required to describe any changes in the Annual Radioactive Effluent Releaie Report, the staff finds that adequate controls over the PCP exist. Further, changes to the plant procedure are governed by the requirements of 10 CFR 50.59. This item is not necessary for safe plant 4'
operation and removal from the TS is acceptable.
3.4 Additional requirements to Conform Section 6 to NRC Guidance a.
The licensee proposed a new TS 6.4.1.b that adds the requirement for establishing, implementing and maintaining emergency operating procedures to implement the requirements of NUREG-0737, including Supplement 1, as stated in Generic Letter 83-33.
b.
The licensee proposed the addition of new TS 6.4.1.c to require procedures for all programs specified in proposed TS 6.5, " Programs and Manuals."
c.
TS 6.17, ODCM, is deleted and replaced by proposed TS 6.5.1 covering the same subject. This new section incorporates the requirements found in current TS 6.17 while revising the wording for consistency with the Improved STS.
Further, an expanded discussion from the Improved STS was added concerning methodology and parameters used in calculation of offsite doses, radioactive effluent controls, radioactive environmental monitoring activities, the information for inclusion in the Annual Radiological Environmental Operating Report and Radioactive Effluent Release Report,
Q' and initiating changes to the ODCM. The changes also provide consistency f
with Generic Letter 89-01.
d.
The licensee proposed the addition of new TS 6.5.4, Technical Specifications Bases Control Program.
The information in this section is similar to that detailed in the Improved STS and is consistent with the change control process requirements in 10 CFR 50.36a and 10 CFR 50.59.
e.
The licensee proposed the addition of new TS 6.5.5, Radioactive Effluent Controls Program. The information in this section is consistent with that detailed in the Improved STS and the programmatic guidance provided in Generic Letter 89-01. These requirements provide additional programmatic controls not currently in the TS.
The staff finds that the proposed changes described in a-e above are acceptable since the changes clarify existing requirements by adding supplemental information, conform with NRC guidance, and provide additional controls that do not currently exist.
3.5 Editorial Changes A number of changes were also proposed for the TSs as a result of the restructuring of the Administrative Controls and other TS sections. Thes.e changes, as described in more detail below, are editorial in nature or involve the reorganization or reformatting of requirements without affecting technical content.
The following changes are acceptable because they are solely administrative:
a.
The Table of Contents was revised to accommodate the proposed changes within the TSs.
b.
Due to the reformatting of the TSs by the proposed changes, the following changes were necessary to correctly reference the applicable TS sections.
1.
In TS 1.11, Core Operating Limits Report, reference to TS 6.9.1.9 changed to 6.6.5.
2.
TS 6.2.2.g changed to 6.2.2.f.
3.
Renumbered TS 6.8 as TS 6.4 4.
TS 6.8.1.g changed to 6.4.1.d 5.
Renumbered TS 6.9 as TS 6.6 6.
Renumbered 6.9.1.6 as 6.6.4 7.
Renumbered 6.9.1.7 as 6.6.2 8.
Renumbered 6.9.1.8 as 6.6.3 9.
Renumbered 6.9.1.9 as 6.6.5 10.
TS 6.17 deleted after relocation of 6.17.2 and deletion of 6.17.1.
11.
TS 6.18 deleted after subsection 6.18.1 was relocated.
c.
In Bases 3.4 added the word "to" between the words " prior" and "the" to correct a grammatical error.
B' 1
i f '
d.
The phrase " pursuant to 10 CFR 50.4" was added to TS 4.7.9.1.3 regarding the required report to the NRC if removable contamination found from sealed source or fission detector leakage tests. This change is acceptable since it provides cpnsistency with the reporting requirements l
in other TSs.
4 e.
10 CFR 50.36a(a)(2) requires the radioactive effluent release report to be submitted to the Commission annually, rather than semiannually.
In order i
to conform to the regulation, the licensee has changed the reporting requirement of TS 6.9.1.4 to annually, in accordance with the guidance provided in GL 89-01, " Guidance for the Implementation of Programmatic j
Controls in the Administrative Controls Section of Technical Specifications and Relocation of Procedural Details of Radiological Effluent Technical Specifications to Offsite Dose Calculation Manual or to the Process Control Manual," as modified by NUREG-1431.
3.6 The licensee has proposed the deletion of the portion of the action i
statement in TS 3.4.8.d that requires the submittal of a Special Report related to exceeding the Iodine-131 equivalent activity limit for the I
primary coolant.
The Special Report in this TS is required under conditions not requiring a plant shutdown. The staff finds that there is no impact on health and safety due to the deletion of this report since the effluent reporting requirements under 10 CFR 50.73 provide sufficient controls. Thus, the staff finds that this special report is unnecessary for plant safety and can be eliminated.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Maryland State official was notified of the proposed issuance of the amendments. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment changes 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 this amendment.
N
6.0 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 defense and security or to the health and safety of the public.
Principal Contributors:
P. Milano i
D. Mcdonald L. Campbell J. Arildsen Date:
August 26, 1996 4
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