ML20128F715
| ML20128F715 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 02/05/1993 |
| From: | Barkhurst R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128F717 | List: |
| References | |
| W3F192-0503, W3F192-503, NUDOCS 9302120006 | |
| Download: ML20128F715 (8) | |
Text
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1 W3F192-0503 A4.05 QA February 5, 1993 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
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Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Technical Specification Change Request NPF-38-132 Gentlemen:
The attached description and safety analysis supports a proposed Technical 5pecification (TS) change.
The proposed change seeks to amend the Waterford 3 Technical Specifications by incorporating a Technical Review and Control process to supplement the onsite technical re'riew and approval of new procedures and changes thereto affecting nuclear safety.
The proposed changes have been evaluated in accordance with 10CFR50.91(a)(1) using criteria in 10CFR50.92(c) and it has been determined that the changes involve no significant hazards considerations. The bases for these determinations are described in the attached submittal.
Waterford 3 requests that the effective date for the changes be 90 days after NRC issuance of the amendment to allow for distribution and implementation of procedures governing the Technical Review and Control Process.
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USHRC Technical Specification Change Request NPF-38-132 l
W3F192-0503 Page 2 February 5, 1993 Should you have any questions or comments en this matter, please contact Paul Caropino at (504) 739-6692.
Very truly yours, hm W1b
R.P. Barkhurst Vice President, Operations Waterford 3 RP8/PLC/ssf Attachments:
NPF-38-132 cc:
J.L. Milhoan (NRC Region IV)
D.L. Wigginton (NRC-NRR)
R.B. McGehee N.S. Reynolds NRC Resident inspectors Office Administrator Radiation Protection Division (State of Louisiana)
American Nuclear Insurers
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UNITED STATES Of AMERICA i
NUCLEAR REGULATORY COMMISSION in the matter of
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Entergy Operations, incorporated
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Docket No. 50-382 Watorford 3 Steam Electric Station
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AfflDAVII R.P. Barkhurst, being duly sworn, hereby deposes and says that he is Vice President Operations - Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Technical Specification Change Request NPF-38-132; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
T ALM i R.P. Barkhurst Vice President, Operations Waterford 3 STATE Of LOUIS!ANA
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Subscribed and sworn to before me, a Notary Public in and for the Parish and State above named this S"
day of Fa s.tu n ev-f
, 1993.
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bo. I N, ew Notary PuTite My Commission expires u,r" cerc
DESCRIPTION AND SAFETY ANAL.YSIS OF PROPOSED CHANCE NPT-38-132 The proposed change modifies the Waterford 3 Technical Specifications (TS)
Administrative Control Section 6.0 to incorporate a technical review and control process for the review and approval of new procedures and changes thereto which affect nuclear safety.
EXillinLSMGif.iC31100 See Attachment A Pronosed Soecificatinn See Attachment B Backaround Currently the Waterford 3 TS implement the Combustion Engineering Standard Technical Specification (CE-STS) NUREG 0212 for review and approval of safety-related procedures.
This criteria requires the Plant Operating Review Committee (PORC) or a PORC sub-committee under the cognizance of PORC to review and recommend the approval or disapproval of the affected procedure (s) to the General Manager Plant Operations.
This criteria is based on the recommendations prescribed by ANSI N18.7/ANS 3.2, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants", Section 4, " Reviews and Audits". ANSI describes independent reviews of activities affecting plant safety which shall be performed during the operational phase. During the development of the Waterford 3 TS the standing committee a>proach as defined in the CE-STS NUREG 0212 was implemented to comply with tie preceding ANSI requirements.
This method assured that procedures and changes thereto would receive interdisciplinary reviews by experienced plant personnel and-approvals at a level commensurate with their importance to plant safety. This method was a)propriate for a nuclear facility which was beginning its operational plase.
The proposed change incorporates a Technical Review and Control Process which modifies the scope of procedures required to be reviewed by the PORC and approved by the General Manager Plant Operations. The change will continue to meet the intent of ANSI N18.7/ANS 3.2 and is structured to correspond to provisions allowed in the revised CE-STS NUREG 1432.
Similar review processes have been approved by the NRC for several facilities which include Limerick and Fort Calhoun. Waterford 3 feels that sufficient operational experience has been obtained to support this change and that its impicmentation will allow for the following benefits to be realf ted.
e The process will allow better utilization of the technical knowledge base of personnel in the affected area to effect changes to procedures, while providing adequate controls to ensure an acceptable level of independent review.
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e The use of individual technical reviewers will expedite the procedure review process by eliminating tne recuirement for PORC review of designated procedures. Timely procecure approval will allow procedural enhancements to be implemented in a more efficient manner, e The revised process will better enable senior management to focus on maintaining an overall cognizance of plant operation and more effectively deal with emerging issues having the potential of impacting nuclear safety.
- Key plant personnel assigned to perform the PORC review function will have additional time to conduct critical and thorough reviews of issues affecting nuclear safety.
Description TS 6.5.1.6 has been revised to aliminate the PORC delegation allowance.
15 6.5.1.6.a has been revised to read "Rev1w of (1) all plant administrative procedures required by Specif.ition 6.8 and changes thereto, (2) all programs required by Specitscation 6.8 and changes thereto,(3) changes to the Waterford 3 Emergency Operating Procedures required to impicment the requirements of NUREG 0737 and NVREG 0737, Supplement 1, as stated in of Generic Letter 82-33, and 4) any other proposed procedures or changes thereto as determined by the General Manager Plant Operations.
TS 6.5.1.6.1 no longer requires PORC review of the Security Plan Implementing Procedures.
TS 6.5.1.6.j no longer requires PORC review of the Emergency Plan Implementing Procedures.
TS 6.5.1.6.0 no longer requires PORC review of the Fire Protection Program Implementing Procedures.
TS 6.5.1.6.p is an added specification which reads " Review of proposed procedures and changes to procedures which involve an unreviewed safety question as defined in 10CFR50.59 "
IS 6.5.3 is a new specification which specifies the requirements of the Technical Review and Control Process.
TS 6.8.1.a has been revised to clarify those procedures required by NUREG 0737 and NUREG 0737, Supplement 1.
TS 6.8.2 has bee. revised to refer to TS 6.5.
TS 6.8.2.C has been revised to refer to TS 6.5.
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DlLCR1119D The proposed changes outlined above limit the scope of procedures required to be reviewed by the PORC and approved by the General Manager Plant Operations to the following:
o Plant Administrative Procedures recommended in Regulatory Guide
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1.33, Appendix,A, and programs specified in TS 6.8.
s Core Protection Calculator (CPC) Software procedures.
Emergency Operating Procedures required to implement the requirements of NUREG 0737 and Su>plement 1 to NUREG 0737 as stated in Section 7.1 of Generic.etter 82-33, o
Procedures involving a-Unreviewed Safety Question.
e Any other procedure or block of procedures as directed by the General Manager Plant Operations.
All other procedures specified in TS 6.8 will be subject to review and approval under the proposed Technical Review and Control Process (now TS 6.5.3).
The Technical Review and Control Process consists of an independent review conducted by a qualified individual knowledgeable in the affected area, other than the individual who prepared the procedure.
The designated j
technical reviewer will insure-that the procedure is technically correct and be responsible for determining if. a~ cross-disciplinary review is required and the extent of such reviews. Qualified technical reviewers shall be designated by the PORC and approved by the General Manager Plant Operations via administrative control.
Each individual designated to perform these reviews shall meet or exceed the appropriate qualifications of TS 6.3.
The new procedure or changes thereto and accompanying 10CFR50.59 review documentation is-forwarded to l
the group head responsible for the affected procedure for approval hs specified by administrative control.
Record keeping requirements will be arovided for procedure reviews I
conducted in accordance with the Tec1nical Review and Control Process consistent with the existing requirements.
The proposed changes are administrative in nature and incorporate an
-additional method for the technical review and approval of selected plant procedures. An independent-technical review performed by an individual whose qualifications and knowledge encortpass the area affected by the procedure, combined with an adequate cross-disciplinary review will provide
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for a level of review equivalent to that performed by the PORC.
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The approval of said protedures by the group head responsible for the affected procedure, after ensuring all necessary reviews have been completed, provides for a level of approval censistent with the responsibility of impicmentation. Thus, under the proposed change procedures will continue to be reviewed and approved commensurate with their importance to safety.
The Technical Review and Control Process will be controlled by administrative procedures which will continue to be reviewed by the PORC and approved by the General Manager Plant Operations.
The PORC will continue to review any procedure or change thereto which constitutes an unreviewed safety question. Therefore, based on the above the pro)osed change will not decrease the safety oversight previously provided )y the PORC.
Safety Analysis.
The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any of the following areas:
- 1. Will operation of the facility in accordance with the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?
Response: No The proposed change is administrative in nature and provides for 1) procedural reviews through the use of qualified technical review personnel designated by the PORC and 2) procedural approval through the use of grou) heads designated by the General Manager Plant Operations as authorized ay administrative controls upon their development. As part of this process, qualified technical reviewers will be individuals other than the preparer who will document and implement necessary cross-discipline reviews prior to approval. The process-will be controlled by administrative controls which will be reviewed by the PORC and approved by the General Manager Plant Operations.-
The procedures governing plant operation will continue to ensure that the plant parameters are maintained within acceptable limits..
Procedures and changes-thereto will be reviewed and approved at a level commensurate with their importance to safety. Therefore, the proposed changes will not involve a significant increase in the probability or consequences of any accident previously evaluated.
- 2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response
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The proposed changes *are administrative in nature. The proposed changes do not involve physical changes to the plant,- changes to set)oints, or operating parameters. The applicable procedures governing t1e o>eration of the plant will-receive reviews and approvals commensurate witi their importance to nuclear safety, and where appropriate cross-discipline review will be performed. Therefore, the proposed changes will not create the possibility of a now or different kind of accident from any previously evaluated.
- 3. Will operation of the facility in accordance with this propos?d change involve a significant reduction in the margin of safety?
Response!
No The proposed changes are administrative in nature..-The Waterford 3 safety margins are defined and maintained by the Technical Specifications in Sections 2-5 which are unaffected.
Therefore, the proposed change will not involve a significant reduction in a margin of safety.
s lafety and Sinnif' cant Hazards Determination Based on the above safety analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as-defined by 10 CFR 50.92; and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and(3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC' final environmental statement".
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