ML20126D243

Proposed Tech Specs Consisting of Proposed Change,Revising TS to Implement Qualified Reviewer Program for Conducting Reviews of Station Procedures

ML20126D243
Person / Time
Site:	Fort Calhoun
Issue date:	12/14/1992
From:	OMAHA PUBLIC POWER DISTRICT
To:
Shared Package
ML20126D226	List: LIC-92-0333, Forwards Application for Amend to License DPR-40,consisting of Proposed Change,Revising TS to Implement Qualified Reviewer Program for Conducting Reviews of Station Procedures ML20126D230 ML20126D243
References
NUDOCS 9212240101
Download: ML20126D243 (16)

Text

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U.S. Nuclear Regulatory Commission LIC-92-0333

-1 ATTACHMENT A-j 1'

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l I-9212240101 921214 5 PDR ADOCK 0500 P.

S.O ADMINISTRATIVE CONTROIS Responsibilities 1 5.5.1.6 The Plant Review Committee shall be responsible for;

a. Review of 1) all procedures required by Specification 5.8 and changes _theret@

2) any other proposed procedures nr changes-thereI6~iEFdetermined by the Miro~un Station to affect nuclear safety.

b. Review of all proposed tests and experiments that affect nuclear safety,

c. Review of all proposed change:; to the Technical Specifications,

d. Review of all proposed changes to the Core Operating Limits Report. l

e. Review of all proposed changes or modifications to plant systems or equipment l that affect nuclear safety.

f. Investigation of all violations of the Technical Specifications and shall prepare and l forward a report covering evaluation and recommendations.to prevent recurrence to the Division Manager - Nuclear Operations and to the Chairman of the Safety Audit and Review Committee.

g. Review of facility operations to detect potential safety hazards. l

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h. Performance of special reviews and investigations and reports thereon as l requested by the Chairman of the Safety Audit and Review Committee.

i. Review of the Site Security Plan and implementing procedures and shall submit recommended changes to the Chairman of the Safety Audit- an Committee.

J. Review of the Site Emergency Plan and implementing procedures and shall l submit recommended changes to the Chairman of the Safety Audit and Review Committee. j L k. Review of all Reportable Events. l l

Authority 5.5.1.7 The Plant Review Committee shall:

a. Recommend in writing to the Manager - Fort Calhoun Station approval or disapproval of items considered under 5.5.1.6(a) through (e) above. l 5-4 Amendment No. 9,F),84,99,115,141-I

. .'5.0 . ADMINISTRATIVE CONTROLS Responsibilities 5.5.1.6 The Plant Review Committee shall be responsible for:

a. Review of-(l) Administrative Controls Standing Orders and changes thereto, (2) procedures required by Specification 5.8 and requiring a 10 CFR 50.59 safety evaluation, and (3) proposed changes to procedures-required by Specification 5.8 and requiring a 10 CFR 50.59 safety-cvaluation;

b. Review of all proposed tests and experiments that affect nuclear safety. 4

c. Review of all proposed changes to the Technical Specifications. .;

d. Review of all proposed changes to the Core Operating Limits Report. j

c. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety,

f. Investigation of all violations of the Technical Specifications and shall prepare and forward a report covering evaluation and recommendations to prevent recurrence to the Division Manager - Nuclear Operations and to the Chairman of the Safety Audit and Review Committee.-

g. Review of facility operations to detect potential safety hazards,

h. Performance of special reviews and investigations and reports thereon as requested by the Chairman of the Safety Audit and Review Committee.

i. Review of the Site Security Plan and implementing procedures and shall submit recommended changes to the Chairman of the Safety Audit and Review Committee. q l

j. Review of the Site Emergency Plan and implementing procedures and shall submit recommended changes to the Chairman of the Safety Audit-and Review Committee.

k. Review of all Reportable Events.

Authority 5.5.1.7 The Plant Review Committee shall:

l a. Recommend in writing to the Manager - Fort Calhoun Station approval or L disapproval of items considered under 5.5.1.6(a) through (e) above.

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L 5-4 Amendment No. 9,49,84,99,

! 446,441, l

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$.0 ADNTINISTRATIVE CONTROLS 5.5.1.7 - b. Render determinations in writing with regard to whether or not each item considered under 5.5.1.6pf through (f) above constitutes an unreviewed safety l _

(. . question.' Lb

c. Provide immediate written notification to the Division Manager - Nuclear Operations and the Safety Audit and Review Committee of disagreement between the Plant Review Committee and the Manager - Fort Calhoun Station; however, the Manager - Fort Calhoun Station shall have responsibility for resolution of-such disagreements pursuant to 5.1.1 above.

Records 5.5.1.8 The Plant Review Committee shall maintain written minutes of each meeting and copies shall be provided to the Division Manager - Nuclear Operations and Chairman of the Safety Audit and Review Committee.

5.5.2 Safety Audit and Review Committee (SARC)

Function 5.5.2.1 The Safety Audit and Review Committee shall function to provide the independent review and audit of designated activities in the areas of:

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a. nuclear power plant operation

b. nuclear engineering

c. chemistry and radiochemistry l d. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engmeering

h. quality assurance Comoosition 5.5.2.2 The Safety Audit and Review Committee shall be composed of:

l Chairman: Division Manager - Nuclear Services Member: Senior Vice President Member: Division Manager - Nuclear Operations Member: Division Manager - Production Engineering

, Member: Manager - Fort Calhoun Station

l. Member: Manager - Radiological Services Member: Qualified Consultants as Required and as Determined by SARC Chairman i

l 5-5 Amendment No. 86,93,99, 4M,44-5,i 19,132,44+

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. 5.6 - ADMINISTRATIVE CONTRO~LS - ,

5.5;1.7 b. Render determinations in writing with regard to whether or not each item considered under 5.5.1.6(b) through (f) above constitutes an unreviewed ' l safety question,

c. Provide immediate written notification to the Division Manager - Nuclear .

Operations and the Safety Audit and Review Committa of disagreement between the Plant Review Committee and the Manager - Fort Calhoun Station; however, the Manager - Fort Calhoun Station shall have

- responsibuity for resolution of such disagreements pursuant to 5.1.1 above.

Records 5.5.1.8 The Plant Review Committee shall maintain written minutes of each meeting and copies shall be provided to the Division Manager - Nuclear Operations and Chairman of the Safety Audit and Review Committee.

5.5.2 Safety Audit and Review Committee (SARC)

Function 5.5.2.1 The Safety Audit and Review Committee shall function to provide the independent review and audit of designated activities in the areas of:

a. nuclear power plant operation

b. nuclear engineering l c. chemistry and radiochemistry

d. metallurgy

e. instrumentation and control

f. radiological safety

g. mechanical and electrical engineering

h. quality assurance Comoosition 5.5.2.2 The Safety Audit and Review Committee shall be composed of

l Chairman: Division Manager - Nuclear Services l

Member: Senior Vice President Member: Division Manager - Nuclear Operations L Member: Division Manager - Production Engineering Member: Manager - Fort Calhoun Station Member: Manager - Radiological Services Member: Qualified Consultants as Required and as Determined by SARC Chairman 5-5 Amendment No. 86,93,99, 4M,445,449,432,444, t

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$. 0 ADMINISTRATIVE QCNTRCLS

( 5.6 R'eportable Event Action 5.6.1 The following actions shall be taken in the event of a REPORTABLE EVENT:

a. The Comission shall be notified pursuant to the requirements of 10 CFR 50.72, if applicable.

b. Each Reportable Event shall be reviewed by the Plant Review Comittee and submitted to the Chaiman of the Safety Audit and Review Comittee and the Division Manager - Nuclear Operations. l

c. Submit reports of Reportable Ever.ts pursuant to the requirements of Specification 5.0.2.

5.7 Safety Limit Violttion 5.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The unit shall be placed in at least F0i SHUTDOWN within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,

b. The Safety Limit Violations shall be reported to the Division Manager - Nuclear Operations and the the Chairman cf the Safety l Audit and Review Comittee (SARC) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

(_ c. A Safety Limit Violation Report shall be prepared. The report shall be eviewed by the Plant Review Cemittee. This report shall describe (1) applicable circumstances preceding the viola-tion, (2) effects of the violation upon f acility components, systems or structures, and (3) corrective action taken to prevent recurrence. _

d. The Safety Limit Violation Report shall be submitted to the Chaiman of the Safety Audit and Review Comittee and the Division Manager - Nuclear Operations within 14 days of the violation. l 5.8 Procedures 5.8.1 Written procedures and administrative policies shall be established, implemented and~ maintained that meet or exceed the minimum requirements of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 except as provided in 5.8.2 and 5.8.3 below.

5.8.2 Each procedure and administrative policy of 5.8.1 above, an M age F thereto, shall be reviewed by the pw4emTttufand approved by the Manager - For otm-Station prior to implerrentation and p ex_todt , as set forth in each document.

5.8.3 Temporary changes to procedures of 5.8.1 above may be made provided:

4 5-9 Amendment Mo. 9,I9,32,2!,99,14+

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ADMINISTRATIVE CONTROIS l 5.6 Reoortable Event Action 5.6.1 The following actions shall be taken in the event of a REPORTABLE EVEITI':

a. The Commission shall be notified pursuant to the requirements of 10 CFR 50.72, if applicable.

b. Each Reportable Event shall be reviewed by the Plant Review Committee and submitted to the Chairman of the Safety Audit and Review Committee and the Division Manager - Nuclear Operations.

c. Submit reports of Reportable Events pursuant to the requirements of Specification 5.9.2.

5.7 Safety Limit Violation 5.7.1 The following actions shall be taken in the event a Safety Limit is violated:

a. The unit shall be placed in at least HOT SHUTDOWN within I hour,

b. The Safety Limit Violations shall be reported to the Division Manager -

Nuclear Operations and the Chairman of the Safety Audit and Review Committee (SARC) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

c. A Safety Limit Violation Report shall be prepared. The report shall be reviewed by the Plant Review Committee. This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon facility components, systems _ or structures, and (3) corrective action takea to prevent recurrence.

d. The Safety Limit Violation Report shall be submitted to the Chairman of the Safety Audit and Revit v Committee and the Division Manager -

Nuclear Operations within 14 days of the violation.

5.8 Procedures 5.8.1 Written procedures and administrative policies shall be established, implemented and maintained that meet or exceed the minimum requirements of sections 5.1 and 5.3 of ANSI N18.7-1972 and Appendix A of USNRC Regulatory Guide 1.33 except as provided in 5.8.2 and 5.8.3 below.

5.8.2 Each procedure of' Specification 5.8.1, and changes theretof and any other procedure or procedure change that the Manager - Fort Calhoun Station determines to affect nuclear safety, shall be reviewed and approved as described below, prior to implementation.

5-9 Amendment No.9,49,38,84,99,4+5,

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5.0 . ' ADMINISTRATIVE CONTROLS 5.8.2.1 Each procedure, or change thereto, shall be reviewed by a Qualified Reviewer (QR) who is knowledgeable in the functional area affected but is not the individual preparer. The QR may be from the same line-organization as the preparer. The QR shall render a determination in writing of whether or not cross-disciplinary review of a procedure, or change thereto is necessary. If necessary, such review shall be performed by appropriate personnel.

5.8.2.2 Each procedure, or change thereto, shall be reviewed by the Department Head designated by Administrative Controls Standing Orders as the responsible Department Head for that procedure, and the review shall include a determination of whether or not a 10 CFR 50.59 safety evaluation is required. If a 10 CFR 50.59 safety evaluation is not required, the procedure, or change thereto, shall be approved by the responsible Department Head or the Manager-Fort Calhoun

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Station, prior to implementation. Administrative Controls Standing Orders, the Site Security Plan and Implementing Procedures, and the Emergency Plan and Implementing Procedures shall be reviewed in accordance with Specification 5.5.1.6 and approved by the Manager-Fort Calhoun Station.

5.8.2.3 If the responsible Department Head determines that a procedure, or change thereto, requires a 10 CFR 50.59 safety evaluation, the responsible Department Head shall render a determination in writing of whether or not the procedure, or change thereto, involves an Unreviewed Safety Question (USQ) and shall forward the procedure, or change thereto with the associated safety evaluation to the PRC for review in accordance with Specification 5.5.1.6.a. If a USQ is involved, NRC approval is required prior to implementation of the procedure, or change.

5.8.2.4 Qualified Reviewers shall meet or exceed the respective qualifications for either Supervisors Requiring an AEC License, Professional-Technical Personnel, or Technical Support Personnel, as specified in ANSI N18.1 - 1971. Personnel recommended to be QRs shall be reviewed by the.PRC and approved and designated as such by the PRC Chairman. The responsible Department Head shall ensure that a sufficient complement of QRs for their functional area is maintained in accordance with Administrative Controls Standing Orders.

5.8.2.5 Each procedure of Specification 5.8.1 shall be reviewed periodically as set forth in Administrative Controls Standing Orders.

5.8.2.6 Records documenting the activities performed under Specifications 5.8.2.1 through 5.8.2.4 shall be maintained in accordance with Specification 5.10.

5-9a Amendment No.

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3.0 ACMINISTRATIVE CONTROLS

( ,.3.3 s. The intunt of the or iginal procedure is not altered,

b. The change is approvetl oy two members of the plant supervisory staff, at least one of whom holds a Senior Reactor Operator's License,e -the unit a&-

fecttd.

c. The change is documenteel, reviewed by the Plante view Com n i t te e a n6. ._agpr M-L-r tm'FMa n ag e r - Fo r t-

__w4hu n otatton--wit 5.n 14 hys of implementation. .

5.3.4 'iritten procedures approved per 5.8.2 above shall be im-i plemented which govern the selection of fuel assemblies '

to be placed in Region 2 of the spent-fuel racks (Techni- l e ii 3pecifteation 2.3///). These procedures shall re-luire an independent verification of initial enri.chment ce ruirements an! fuel burnup calculations for a fuel ,

b u nd le to assure the " acceptance" criteria for placement  :

in Region 2 are me t . This independent ve r i f ic a t ion shal1 l oe pertarmed ny ind tviduals or groups other than those  ;

wao performed the taittal acceptanco criteria anaessment, but who may oe from the same o r g a n i s.a t io n .

3.9 Repor ting Reau irements

( In add ; ton to tne applicable reporting requirements of T i. t l e .0, Code ]f Fede r a l Reg u la t ions , the following tde n t i t led reporta shall be submitted to the Director of the appropriate Regtonal Offtce of Inspectian an i Enforce-

,e n . inless a ne rw t:;e noted.

5.9.. :so u t i n e Peports

a. Startup Report. A sunmary report of plant startup and unse r e sc alation testing shall be s ub. nit ted fol-lasts, t1) receipt at an ope ra t ing license, ( 2) ameneent to tne license iavolving a planned in-r i,, t- ~ , ., . r level, (l' installation of fuel that nau a different de s ign or has been manu-

' x 2 r -d s 1 -li f f eren t %i supplier, and (4) modi-

tci'.an;  :,a ! ma. have s L::n t : icantly altered the nuclear, inermal, or hydraulic performance of the lon! TM- recort shall adIress each of the tests

.vn: L f t o-! in the USAR an: shall in Jener il include

d e s ; r i ,7 t t o n of the measured values of the operat-

ng c Sn l ; 5 ti)ns o r cl.d r 'tC" e r t 3 r ics ob ta i ned d u r i ng th.' "

s t :r0gc3n a ntl si e]99.trLSon af the90 Values

- ! *. ~ !U li - .25tonn i^ "OCtftJatl3n4 Any 3: - : t , /4 tJns " hat .b e *

• r e.iu i red to Obtlin sat ~~Tt** ,r' ' *: r ) ; t c ' n - ilsa 'o sle ic t . *?d .

in/ 3i itt.SqT1 9 0." C L f i C le a t 14 r e-iu ; r ed tn license

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f5.i- ADMINISTRATIVE CONTROLS

• oj 5.8.3- Temporary change ~s to procedures of 5.8.1' above may be made provided:-

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a. The intent of the original procedure is not altered. ; 1

.b.. 1 The change is approved by two members of the plant supervisory staff, at _ M least one of whom holds a Senior Reactor Operator's License,

c. The change is documented,' reviewed by a: Qualified Reviewer and:

approved by either the Manager - Fort Calhoun Station or the Department '

ifcad 1 designated by ' Administrative : Controls Standing Orders as the responsible Department Head for that= procedure withini 14 days.of a implementation. ,

1 5.8.4 Written procedures approved per 5.8.2 above shall be implemented which govern the selection of fuel assemblies' to be placed in Region 2 of the spent fuel racks 1 (Technical Specification 2.8). These procedures shall require an independent l [

verification ofinitial enrichment requirements and fuel burnup calculations for a ~

fuel bundle to assure the " acceptance criteria for placement in Region 2 are met.- ,

This independent verification shall be performed by individuals or groups other . <

than those who performed the initial acceptance ' criteria assessment, but who may .

be from the same organization.

l 5.9 Reoorting Reauirements ,

In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following identified reports shall be submitted to the Director ofn the appropriate Regional Office ofinspection and Enforcement unless otherwise -

noted.

5.9.1 Routine Reports .

a. Sigrtup Reoort. A summary report of plant startup and power escalationi testing shall be submitted following (1) receipt of an operating license, (2);

amendment to the license involving a planned increase in power level, (3) installation of fuel that has a different design or ha" been manufactured by ;

a different fuel supplier, and (4) modifications that may have significantly  :

altered._the nuclear, thermal, or hydraulic performance of the plant. .The report shall address each of the tests identified in the USAR and shall in t general include a description of the measured values of theLoperating' conditions or characteristics obtained during.the test program and =a'-

comparison of these values with design predictions and' specifications; Any corrective actions that were required to obtain' satisfactory operation -

shall also be described. - Any additional specific details required in license conditions based on other commitments shall be included in this report.

5 5-10 Amendment No. 9,49,15,75, i

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U.S. Nuclear Regulatory Comission LIC-92-0333 ATTACHMENT B -

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l DISCUSSION, JUSTIFICATION, AND NO SIGNIFICANT HAZARDS CONSIDERATION The Omaha Public Power District proposes to revise Fort Calhoun Station Unit.

No.1 Technical Specifications 5.5 and 5.8 to reflect the implementation of a Qualified Reviewer (QR) Program for the review and approval of new procedures, i and changes thereto, at Fort Calhoun Station.

The Change Request provides discussion and justification of the proposed TS changes, information supporting a-finding of No Significant Hazards Consideration, and information supporting an Environmental Assessment.

DISCUSSION AND JUSTIFICATION The Qualified Reviewer (QR) Program is a procedural review and approval process wherein qualified reviewers perform a review function and the designated Department Heads perform an approval function for new procedures, and changes thereto. This program has been previously approved by the NRC for other nuclear. facilities including the Philadelphia Electric Company, Limerick

. Generating Station and Peach Bottom facilities.

Issues of importance under the QR program are:

• The Plant Review Committee (PRC) will no longer be required to render.a determination as to whether or not a new procedure, or change thereto, constitutes an Unreviewed Safety Question (USQ) in accordance with 10

, CFR 50.59 and

• The PRC will no longer be required to review and recommend approval / disapproval of certain types of procedures or procedure changes to the Manager-Fort Calhoun Station.

The responsibility and authority to perform these functions will be transferred to the responsible Department Head designated by the Manager-Fort Calhoun Station.

A brief description of the development and implementation of this program at Fort Calhoun Station is provided below.

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• The PRC Chairman will approve plant personnel recommended to be Qualified Reviewers' (QRs)- for specific classes of procedures.

• - The QR will be an individual knowledgeable-in the functional area affected and may be from the same organization, but cannot be the l- individual preparer. Qualified Reviewers shall meet or exceed the l

respective qualifications for either Supervisors Requiring an AEC L License, Professional-Technical Personnel, or Technical Support L

Personnel as specified in ANSI N18.1 - 1971.

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DISCUSSION AND JUSTIFICATION (CONTINUE'D) e Selected Standing-Orders will 'be reclassified as Administrative Controls Standing Orders e An Administrative fontrols Standing Order will be develop 6d to implement the Qualified Reviewer Program - '

l e Standing Orders which are impacted by the adoption of the Qualified Reviewer Program will be identified and revised.

e The Manager-Fort Calhoun Station, as authorized by Administrative Controls Standing Orders, will appoint a Department Head to be responsible for approving classes of procedures. The a Department Head will be the individual responsible for,ppointed and cognizant of, the affected functional area.

• Each new procedure, or change thereto, will be reviewed by the-designated QR. The QF s,ll determine when a cross-disciplinary review by other personnel is necessary prior to approval. The new procedure, or change thereto, and accompanying 10 CFR 50.59 Review documentation r (i.e., evaluation of the-proposed change or new procedure in accordance with 10 CFR 50.59 will be reviewed by the responsible Department Head, including determi ing whether a 10 CFR 50.59 safety evaluation is required or not. If not, the new procedure, or change-thereto, will be approved by the responsible Department Head or d:e Manager-Fort Calhoun Station. If a 10 CFR 50.59 safety evaluation is required, the entire new procedure, or change package, including-the 10 CFR 50.59 safety evaluation, must be reviewed by the PRC.

• PRC will continue to be responsible for the review and recommendation for approval / disapproval of Administrative Controls Standing Orders, and any new procedure, or change thereto, that requires performance of an Unreviewed Safety Question determination (i.e., 10 CFR 50.59 safety evaluation).

• In addition-to Administrative Controls Standing Orders, the Manager-Fort Calhoun Station will continue to be responsible for the approval of Security Plan and Implementing Procedures, Emergency Plan and Implementing Procedures, and any new prnedure, or change thereto, that requires performance of an Unreviewed Safety Question determination (i.e., 10 CFR 50.59 safety evaluation).

Temporaryprocedurechanges{TPCs)bythedesignatedwill however, the TPC will be reviewed be implemented R (including a as before; cross-disciplinary review, if necessary) and approve by the Manager-Fort Calhoun Station or responsible Department Head, as appropriate, within 14 days of implementation.

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DISCUSSION AND JUSTIFICATION (CONTINUED)

The proposed changes are administrative in nature. The institution of the QR' Program will improve the cffectiveness of the PRC by concentrating on issues important to safety. There are no changes to plant equipment, plant design, limiting safety system settings, or plant system operation. The QR Program requires review prior to approval of any new procedure or procedure change by a qualified individual (other than the preparer) who is knowledgeable in the functional area affected. The program will be controlled by Administrative Controls Standing Orders which will continue to be reviewed by the PRC and; approved by the Manager-Fort Calhoun Station. The PRC will continue to review those new procedures, and changes thereto, for which an Unreviewed Safety-Question performed.determination'(he Therefore, t proposed administrative changes)will not decreasei.e., 10 CFR the safety oversight function which the PRC performs.

Administrative Chanagi The heading " ADMINISTRATIVE CONTROLS" is being added to page 5-9 for consistency with other pages within Section 5.0 of the Technical-Specifications.

Specification 5.8.4 is being revised to correct a_ reference to Specification 2.8(12) which is incorrect; the correct reference is 2.8(11). Specification-2.8 was renumbered in Amendment 133. It is proposed that this reference be revised to Specification 2.8.

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i BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION The proposed change to the Fort Calhoun Station Technical Specifications, which reflect implementation of a QR Program, does not constitute a Significant Hazards Consideration. In support of this conclusion, an-evaluation of each of the three standards as set forth in 10 CFR 50.92 is provided below. Operation of Fort Calhoun Station in accordance with the-proposed changes does not:

1) Involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change is administrative in nature and provides for (1)-

procedural reviews through the use of qualified personnel designated by the PRC Chairman and (2) procedural approval thronh the use of Department Heads designated by the Manager-Fort Ca houn Station, as authorized by Administrative. Controls Standing Orders upon their development and approval. As part of this program, the QR will be required to consider, document, and implement necessary cross-discipline review prior to approval. The program will be controlled by Administrative Controls Standing Orders which will be reviewed by the PRC and approved by the Manager-Fort Calhoun Station. The PRC will continue to review new procedures, and changes thereto, for which'an i.e.,-10 CFR 50.59-safety q Unreviewed evaluation) isSafety Question required determination (Implementing the proposed to be performed.

administrative change will not decrease the safety review function '

currently performed by the PRC. The proposed change requires review of any new procedure and procedure change by a qualified individual (other than the preparer The proposed chang)e does not affect any plant hardware, plant design,who is know limiting safety system settings, or plant systems, and therefore, does not alter or add any initiating parameters that would cause a significant increase in the probability or consequences of an accident previously evaluated.

2) Create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed Technical Specifications change will implement a procedural review and approval process and is strictly administrative in nature.

The QR Program Orders. will be controlled These Standing Orders willby beAdministrative reviewed by theContrcls PRC and Standing approved by the Manager-Fort Calhoun Station. The PRC will continue to review-those new procedures and changes thereto for which an Unreviewed Safety Question determination i.e., 10-CFR 50.59 is required to be performed.

Therefore, the proposed (administrative chan)ge does not reduce the safety review function performed by the PRC. The proposed change does not involve physical changes to .the plant, changes to setpoints, or operating parameters. There are no-potential initiating events that would result in the possibility of a new or different kind of accident from any accident previously evaluated.

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BASIS FOR NO SIGNIFICANT HAZARDS CONSIDERATION (CONTINUED)

3) _ Involve a significant reduction in a margin of safety.

The proposed change is administrative in nature and is limited to'(1) the transfer of procedure review responsibilities to designated Qualified Reviewers and (2) the transfer of procedure approval responsibilities to designated Department Heads.- The PRC will continue to review and the Manager-Fort Calhoun Station will continue to approve those new procedures, and chan es thereto, for which an Unreviewed Safety Cuestion determination i.e.,10 CFR 50.59 safety evaluation is requirec to be performed, it s therefore concluded that the propos)ed change does not involve a significant reduction in a margin of safety.

The Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing certain examples '(48 FR 14870) of amendments that are considered not likely to involve significant hazards consideration. Example (1) relates-to a purely administrative change to the Technical. Specifications.

The proposed change described above is-similar to Example (i) in that the proposed change.is strictly administrative in nature.

Therefore, based on the above considerations, it is OPPD's position that this proposed amendment does not involve a significant hazards consideration as defined by 10 CFR 50.92 and the proposed changes will not result in a condition which significantly alters the impact of the Station on the environment. Thus, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10) and pursuant to 10 CFR 51.22(b) no environmental assessment.need be prepared.

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