ML20129G935
| ML20129G935 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 10/25/1996 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20129G876 | List: |
| References | |
| NUDOCS 9610300268 | |
| Download: ML20129G935 (7) | |
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i UNITED STATES NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20086-4001 5
l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO Apmn4ENT NO.117 TO FACILITY OPERATING LICENSE NO. DPR-80 AlELAMENWlENT JEL_115_ TO FACILITY OPERATING LICENSE NO. DPR-82 1
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PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT. UNITS 1 AND 2 i
l DOCKET NOS. 50-275 AND 50-323 l
1.0 INTRODUCTION
By application dated December 19, 1995, as supplemented by letter dated August 8, 1996, Pacific Gas and Electric Company (or the licensee) requested changes to the Technical Specifications (Appendix A to Facility Operating License Nos. DPR-80 and DPR-82) for the Diablo Canyon Nuclear Power Plant, Units 1 and 2.
The proposed changes would revise the combined Technical Specifications (TS) for the Diablo Canyon Nuclear Power Plant, Unit Nos. I and 2 to revise Section 6.1, " Responsibilities," and relocate Technical Specification (TS) 6.5, " Review and Audit," 6.8, " Procedures and Programs,"
Sections 6.8.lc., 6.8.ld., 6.8.2, and 6.8.3, in accordance with guidance in an NRC letter dated October 25, 1993, from William T. Russell to the chairpersons of industry owners groups and the Commission's Final Policy Statement on TS Improvements for Nuclear Power Reactors on relocation of TS that do not satisfy the retention criteria. As part of the relocation of TS 6.8.2, TS 6.1.1 would be revised to require that proposed tests, experiments, or modifications that affect nuclear safety be approved by the plant manager or his designee prior to implementation.
The August 8,1996, supplemental letter provided additional clarifying information and did not change the initial no significant hazards consideration determination published in the Federal Reaister on January 22, 1996 (61 FR 1633).
2.0 EVALUATIQN 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 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 9610300268 961025 PDR ADOCK 05000275 P
PDR a
. 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.
2.1 Reviews and Audits The licensee proposes that the review and audit functions specified in existing TS 6.5 be relocated from the improved TS on the basis that they are adequately controlled by the QA program. These TS provisions are not necessary to assure safe operation of the facility, given the requirements in the Quality Assurance (QA) Program implementing 10 CFR 50.54 and 10 CFR Part 50, Appendix B to control the requirements for all review and audit functions except those associated with the security and emergency plans. The security and emergency plan review and audit functions are relocated to their respective plans in accordance with GL 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans." Additionally, NRC Administrative Letter, 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance,"
dated December 12, 1995, provides guidance for relocating TS administrative requirements.
Such an approach would result in an equivalent level of regulatory authority 6,hile providing for a more appropriate change control process. The level of safety of plant operaticn is unaffected by this change and NRC and licensee resources associated with processing license amendments to this administrative control may be used more effectively.
In addition, the following considerations support relocating these items from the TS:
a.
The Nuclear Safety Oversight Committee (NSOC) function, composition, alternate membership, meeting frequency, quorum, responsibilities, authority and records are all covered in equivalent detail in American National Standards Institute (ANSI) N18.7-1976.
Since the NSOC requirements will be relocated to Chapter 17 of the Final Safety Analysis Report (FSAR) Update, which defines the QA program requirement, changes to the requirements will be controlled effectively under 10 CFR 50.54(a).
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b.
The Plant Staff Review Committee (PSRC) is also addressed, although with less detail, in ANSI N18.7-1976.
Since the PSRC requirements will be relocated to Chapter 17 of the FSAR Update, which defines the QA Program requirements, changes to the requirements will be controlled effectivcly under 10 CFR 50.54(a). Therefore, duplicating the review and audit function of NSOC in the TS is unnecessary.
In relocating TS Section 6.5.2 to the FSAR Chapter 17.2, the responsibilities of the PSRC will be revised to permit qualified reviewers to perform reviews of procedure and program changes. All proposed changes are required to be evaluated by the qualified reviewers to determine if a 10 CFR 50.59 safety evaluation is required in order to make the change.
If a 10 CFR 50.59 safety evaluation is required, it will be reviewed by the PSRC. Qualified Reviewers will also be required to determine whether additional cross-disciplinary reviews are necessary.
If necessary, the cross-discipline reviews will be performed by appropriately qualified reviewers.
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c.
TS Section 6.5.4 requirements for the independent technical review function will be relocated, without change, to FSAR Section 17.2.5.
Since requirements of this program will be relocated to Chapter 17 of the FSAR Update, changes to the requirements will be controlled effectively under 10 CFR 50.54(a). Chapter 17 of the FSAR Update defines QA Program requirements. The revisions to Chapter 17 will include minimum qualification requirements of review personnel.
d.
Audit requirements are specified in the QA program description to satisfy 10 CFR Part 50, Appendix B, Criterion XVIII. Audits requirements are also covered by ANSI N18.7, ANSI N45.2,10 CFR 50.54(t), 10 CFR 50.54(p), and 10 CFR Part 73. Therefore, the audit requirements in TS 6.5 duplicate requirements contained in regulations and can be relocated. Since the audit requirements will be relocated to Chapter 17 of the FSAR Update, which defines the QA Program requirements, changes to the requirements will be controlled effectively under 10 CFR 50.54(a). Therefore duplicating of these 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.
TS 6.5.3.8 requirements for auditing plant activities has been relocated to Chapter 17 of the FSAR with the following audit frequencies changes 1.
The Frequency for the conformance of plant operation to provisions contained within the Technical Specifications and applicable licenses was changed from 12 months to 24 months.
2.
The Frequency for the performance, training, and qualifications of the entire plant staff was changed from 12 months to 24 months.
3.
The Frequency for the results of actions taken to correct deficiencies occurring in plant equipment, structures, i
systems, or method of operation that affect nuclear safety l
was changed from 6 months to 24 months.
4.
The Frequency for the Fire Protection and Loss Prevention Program will be performed in accordance with the annual (1 year) and biennial (2 year) audit and inspection i
requirements of NRC Generic Letter (GL) 82-21.
Further the i
audit for the Fire Protection and Loss Prevention Program will be performed in accordance with the annual and
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triennial (3 year) audit requirements of NRC GL 82-21.
5.
The Frequency for the Radiological Environmental Monitoring Program, its implementing procedures, and program results was changed from 12 months to 24 months.
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! i 6.
The Frequency for Non-radiological Environmental Monitcring Program was changed from 12 to 24 months.
e.
The requirements for record retention-in TS 6.5 are addressed in 10 CFR 50, Appendix B, Criterion XVII, and in Chapter 17 of the FSAR Update.
Since the requirements are specified in regulations and the QA Program, i
changes to the requirements will be controlled effectively under 10 CFR 50.54(a).
Facility operations are performed in accordance with approved written procedures. These and other records regarding plant operation are retained to allow for review compliance with procedure requirements and regulations. However, post-compliance reviews of records do not affect safe plant operation since activities described.in these documents have already been performed. Additionally, other regulations, including 10 CFR 20 and 10 CFR 50.71, require the retention of records related to plant operation.
Existing regulatory requirements provide sufficient control of record retention requirements.
The licensee has proposed to relocate the provisions that are not otherwise covered by regulatory requirements to the FSAR Update. The staff concludes that the sufficient regulatory controls exist for the FSAR Update such that removing these provisions from the TS and relocating them to the FSAR Update under the controls of 10 CFR 50.54 is acceptable.
i 2.2 Security Plan and Emeraency Plan Imolementation The licensee proposes to relocate the requirements to establish, implement, and maintain procedures related to the Security Plan (existing TS 6.8.1.c) and Emergency Plan (existing TS 6.8.1.d).
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 50.47, 50.54(q) and 10 CFR Part 50, Appendix E, Section V, the staff in CL 93-07 removed the requirements from the STS and relocated them to their respective plans.
The requirements in the existing TS for the review of the security program and implementing procedures, and for the review of the station emergency plan and implementing procedures, will be included in the FSAR Update.
Further changes in these review requirements must be made in accordance with 10 CFR 50.54(p) for the Security Plan and 10 CFR 50.54(q) for the Emergency Plan.
The staff concludes that the extensive requirements for emergency planning in 10 CFR 50.47, 50.54, 10 CFR Part 50 Appendix E and for security in 10 CFR 50.54 and 73.55, for drills, exercises, testing, and maintenance of the 4
program, provide adequate assurance that the objective of the previcus TS for a periodic review of the program and changes to the programs will be met.
Therefore, duplication of the requirements ccntained in the regulations would not enhance the level of safety for the facility.
The staff concludes that other regulatory requirements provide sufficient control of these provisions and removing them from TS is acceptable.
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II 4 2.3 Review and Acoroval Process l
The licensee is proposing to relocate the requirements of existing TS 6.8.2 i
for the review and approval process for procedures to the FSAR Update. This i
proposal is based on the existence of the following requirements which j
duplicate 10 CFR Part 50 Appendix B in these areas.
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The requirement for procedure control is mandated by 10 CFR Part 50, Appendix B, Criterion II and Criterion V.
ANSI N18.7-1976, which is endorsed by the NRC in Regulatory Guide 1.33, " Quality Assurance Program Requirements i
(Operations)," is used in the development of many licensee QA program descriptions, and contains specific requirements related to procedures. The licensee has committed to follow ANSI N18.7-1976 as a means to comply with 10 i
CFR Part 50, Appendix B.
ANSI N18.7-1976, Section 5.2.2 discusses procedure i
adherence.
Section 5.2.2 clearly states that procedures shall be followed, i
and the requirements for use of procedures shall be prescribed in writing.
ANSI N18.7-1976 also requires review and approval of procedures to be defined.
ANSI N18.7-1976, Section 5.2.15 describes the review, approval and control of 3
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procedures. The ANSI standard describes the requirements to provide measures to control and coordinate the approval and issuance of documents, including i
changes thereto, which prescribe all activities affecting quality. The ANSI standard further states that each procedure shall be reviewed and approved prior to initial use and describes the required reviews. ANSI N45.2-1971, j
Section 6, also specifies that the QA Program describe procedure requirements.
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In relocating TS 6.5.1, " Technical Review and Control," administrative controls for processing procedures to FSAR 17.5, " Instructions, Procedures, 4
i and Drawings," the licensee clarified the intent of the relocated TS text by i
identifying which types of procedures implement the activities referenced in i
The clarification, as described in FSAR 17.5, is that where reference is made to procedures in TS Section 6.8.1, the relocated TS 6.5.1.1 review and approval requirements only apply to procedures that are under the plant manager's control, affect plant operations, or affect the operating status of safety-related system, structures, or components. Also, in relocating TS 6.5.1.2 requirements to FSAR 17.5, the licensee has modified the relocated text to permit a responsible organization instead of a discipline qualified reviewer to be designated for reviewing and approving procedures.
The responsible organization would then assign a qualified reviewer of the appropriate discipline to perform the review activity.
The licensee will continue to implement a QA program description in accordance with the requirements of 10 CFR Part 50, Appendix B, which provides appropriate controls for the review and approval of procedure changes.
Changes to the QA program description that is incorporated in the FSAR Update by reference, including departures from the ANSI standard that constitute a reduction in commitment, will be governed by 10 CFR 50.54(a). The staff concludes that these regulatory requirements provide sufficient control of these provisions and removing them from the TS is acceptable.
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2.4 Temocrary Chanae Process j
The licensee proposes to relocate the requirements of existing TS 6.8.3 for the temporary change process for procedures to the FSAR Update. This proposal is based on the existence of the following requirements which duplicate 10 CFR Part 50, Appendix B in these areas.
The requirement for procedure control is mandated by 10 CFR Part 50, Appendix j
B, Criterion II and Criterion V.
ANSI N18.7-1976, which is endorsed by NRC in Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations),"
l 1s used in the development of many licensee QA program descriptions and
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contains specific requirements related to procedures. The licensee has t
committed to follow ANSI N18.7-1976 as a means to comply with 10 CFR Part 50, 4
Appendix B.
ANSI N18.7-1976, Section 5.2.2 discusses procedure adherence.
j Section 5.2.2 clearly states that procedures shall be followed, and the requirements for use of procedures shall be prescribed in writing. ANSI
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N18.7-1976 also discusses temporary changes to procedures. ANSI N18.7-1976, 1
Section 5.2.15 describes the review, approval and control of procedures. The 4
ANSI standard describes the requirements for the licensee's QA Program to j
provide measures to control and coordinate the approval and issuance of documents, including changes thereto, which prescribe all activities affecting j
_ quality.
The ANSI standard further states that each procedure shall be i
reviewed and approved prior to initial use, and describes the required reviews. ANSI N45.2-1971, Section 6, also specifies that the QA Program describe procedure requirements, j
In relocating TS 6.8.3, the licensee has modified its text to remove the l
requirement for an individual with a senior reactor operator license to approve certain temporary procedure changes. The existing TS requirement i
would be revised in FSAR 17.5 to specify that a senior reactor operator is only required to approve temporary changes for the following types of procedures:
(1) all operations section procedures, (2) surveillance test j
procedures, (3) emergency plan implementing procedures, and (4) any other procedure if the proposed change affects equipment of system operating status.
The licensee will continue to implement a QA program description in accordance i
with the requirements of 10 CFR Part 50, Appendix B, which provides appropriate controls for the review and approval of procedure changes.
Changes to the QA program description that is incorporated in the FSAR Update by reference, including departures from the ANSI standard that constitute a reduction in commitment, will be governed by 10 CFR 50.54(a). The staff concludes that these regulatory requirements provide sufficient control of these provisions and removing them from TS is acceptable.
I 2.5 Administrative Chanae i
As part of the relocation of TS 6.8.2, TS 6.1.1 would be revised to require j
that proposed tests, experiments, or modifications to systems or equipment that affects nuclear safety be approved by the plant manager or his designee i
prior to implementation. FSAR 17.5 has modified the relocated TS text to i
f permit the plant manager to designate individuals to approve plant procedures
. required by TS 6.8.1 on behalf of the plant manager. Designated approvers shall have an equivalent level of knowledge and experience to that of the plant manager. This change is an administrative change that incorporates information consistent with NUREG-1431, Revision 1, " Standard Technical Specifications Westinghouse Plants," dated April 7,1995, and the staff finds it acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
These amendments relate to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, 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 coinmon defense and security or to the health and safety of the public.
Principal Contributor:
S. Bloom Date:
October 25, 1996