ML20137E218
| ML20137E218 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 03/21/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20137E216 | List: |
| References | |
| NUDOCS 9703270109 | |
| Download: ML20137E218 (11) | |
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i UNITED STATES g
g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2006H001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 97 TO FACILITY OPERATING LICENSE NO. NPF-57 PUBLIC SERVICE ELECTRIC & GAS COMPANY ATLANTIC CITY ELECTRIC COMPANY HOPE CREEK GENERATING STATION DOCKET NO. 50-354
1.0 INTRODUCTION
By letter dated January 11, 1996, as supplemented by letters dated February 26, May 22, June 27, July 12, December 23, 1996, and March 17, 1997, the Public Service Electric & Gas Company (the licensee) submitted a request for changes to the Hope Creek Generating Station, Technical Specification (TS). The requested changes would revise Section 6.0 (Administrative Controls) of the Hope Creek TS to:
- 1) relocate the requirements of Section 6.5 (Station Operations Review Committee, Nuclear Safety Review and Audit, and Technical Review and Control) to the Quality Assurance Program (QAP), 2) replace specific management titles with generic management functional positions, 3) change Operating Engineer to Assistant Operations Manager, 4) j require a Senior Reactor Operator license be held by either the Operations Manager or one of the Assistant Operations Managers, and 5) correct some typographical errors in Section 6.0.
The supplements did not change the NRC staff's initial proposed no significant hazards consideration determination contained in the February 14, 1996 Federal Reaister notice (61 FR 5818). With regard to the supplements, only the supplements dated February 26, July 12, December 23, 1996, and March 17, 1997, actually address changes to the TS.
The remaining supplements dated May 22 and June 27, 1996, address the related issue of changes to the QAP.
In the course of reviewing the supplements to the application, the NRC staff noted that the licensee had made errors in the 1
associated draft TS pages. These errors were corrected by the licensee with a final set of draft TS pages.
In each case, the supplement correctly addressed the intended TS changes.
Relocation of the SORC and other review and audit requirements from the TS to the QAP is consistent with the processes described in Administrative Letter i
95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
2.0 DISCUSSION AND EVALUATION 2.1 Relocation of Selected TS to the QAP (Review and audit) 2.1.1 Discussion 9703270109 970321 DR ADOCK 05000354 PDR
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Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear 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 TS are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
Section 50.36 provides, that with respect to limiting conditions for operations (LCO), four criteria to be used in determining whether particular safety functions are required to be included in the TSs. While the 4 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 36957).
Addressing administrative controls 10 CFR 50.36 states that they "are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure safe operation of the facility in a safe manner." The specific content of the administrative controls section of the TSs is therefore 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
$50.36(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 the public health and safety, can be removed from administrative controls.
Existing TS requirements, therefore, 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, 650.59, or other regulations provide adequate regulatory control.
2.1.2 Evaluation By letter dated December 12, 1995, the staff issued NRC Administrative Letter (AL) 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance." AL 95-06 provided inforaiation regarding recent experiences involving the relocation of TS administrative controls related to quality assurance.
In AL 95-06, the staff compared the content of typical TS administrative controls related to quality assurance requirements, for those plants that have not converted to the improved Standard Technical Specifications (ISTS), with established staff positions and amendment requests. On the basis of this review, the staff provided several observations in order to assist those licensees considering amendment requests related to quality assurance requirements.
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- 1 The licensee's January 11, 1996, letter as supplemented on February 26, 1996, May 22, 1996, June 27, 1996, July 12, 1996, and on December 23, 1996, to the NRC, proposes to relocate the administrative controls related to the quality assurance review and audit requirements of TS 6.5, " Review and Audit," from the Hope Creek Generating Station TSs to the QAP. This change is in accordance with the guidance contained in NRC AL 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
The quality assurance program is a logical candidate for such locations due to the controls imposed by such regulations such as Appendix B to 10 CFR Part 50, the existence of NRC-approved quality assurance plans and commitments to industry quality assurance standards, and the established quality assurance program change control process in 10 CFR 50.54(a).
The licensee proposed that the review, investigative and audit functions and frequencies, including specific audit requirements for the fire protection program, specified in TS Sections 6.5.1 and 6.5.2 be relocated from the TSs to the appropriate sections of the QAP. The licensee has proposed to relocate these TS requirements to the QAP and control any subsequent changes in accordance with 10 CFR 50.54(a).
The licensee proposed to relocate the requirements in existing TS 6.5.1,
" Stations Operations Review Committee (SORC)," to Section 17.2.1.1.2.2 of the QAP with the following changes:
1)
PSE&G proposes to delete specific titles in TS 6.5.1 that describe the SORC membership by title, and replace that with a description of SORC membership that shall be chaired by the plant manager and composed of members having experience in each of the following areas:
a) plant operations, b) engineering, c) maintenance, d) chemistry, e) radiation protection, and f) quality assessment. The changes from specific membership titles are administrative in nature and the relocated SORC provisions continue to provide for members with the appropriate technical expertise to be on the SORC. The staff finds this change acceptable as it conforms to the Improved' Standard Technical Specifications (ISTS).
2)
In relocating TS 6.5.1 to the QAP, TSs 6.5.1.6.j and 6.5.1.6.k were deleted because they were previously relocated to the Facility Security Plan and the Facility Emergency Plan, respectively, upon the issuance of Licensing Amendment No. 95. This deletion is authorized by previous NRC approval of these amendments.
3)
PSE&G proposes to relocate existing TSs 6.5.1.7 provisions for using qualified reviewers to the QAP Section 17.2.1.1.2.1.
PSE&G further proposes to relocate the remaining TSs 6.5.1 to QAP 17.2.1.1.2.2.
The proposed QAP Section 17.2.1.1.2.1 continues to permit the use of qualified reviewers to perform reviews of procedures, programs, and changes thereto, on behalf of the 50RC.
Personnel performing as
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qualified reviewers will continue to meet the current TS 6.5.3.2 qualification requirements of Section 4.1 and 4.7 of ANS 3.1-1981.
i The current TS text addressing the use of qualified reviewers is in j
one section of the TSs. The relocation of TS 6.5.1 to various QAP sections is administrative in nature and acceptable to the staff.
The NRC staff notes that the provisions of Section 4.1 of 4
ANS 3.1-1981, as discussed in the sixth paragraph of the Foreword to i
ANS 3.1-1981, were added for the following specific reason:
i "A major addition was made to 4.1 which provides guidance for the j
i selection of those rare, exceptional individuals who have demonstrated outstanding management ability yet do not possess the
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formal education requirements specified in this standard. These individuals, however, have additional experience, training and i
education that is considered equivalent to that required to meet the j
qualifications of a particular position."
Based on the above discussion, the staff considers the use of Section 4.1 of ANS 3.1-1981, to be for rare, exceptional individuals that i
have outstanding management ability, but who do not possess the i
formal education requirements specified for their assigned position L
and should not be applied generically to non-supervisory personnel j
performing the qualified reviewer function.
The licensee proposed to relocate the requirements in existing TS 6.5.2, " Nuclear Safety Review and Audit," to various sections of the QAP with the following change:
- 1) The. independent offsite review functions (TS 6.5.2.4) currently performed by the Offsite Safety Review staff (OSR) under the cognizance of the Director, Quality Assurance and Safety Review, will be performed by a Nuclear Review Board (NRB) that reports to and advises the Chief Nuclear Officer (CNO). The change provides an equivalent independence for the offsite review function and the staff considers this administrative change acceptable.
Reference to "0SR" in the remaining TSs should be changed to "NRB".
- 2) The current TS 6.5.2.4.1 review and audit areas of nuclear engineering, metallurgy, mechanical engineering, and electrical engineering have been combined into one area that will be referred to as engineering. The licensee is committed to the requirements of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational-Phase of Nuclear Power Plants." Section 4.3.1 of ANSI N18.7 identifies the specific areas of engineering, including the mechanical, electrical, and metallurgy disciplines, that requires review by the offsite independent review personnel. The change therefore is administrative in nature and does not reduce plant safety.
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- 3) TSs 6.5.2.2 currently requires that the OSR staff shall meet or j
exceed the qualifications described in Section 4.7 of ANS 3.1-1981.
PSE&G proposes in Section 17.2.1.1.2.3 of the QAP to reduce the qualifications for a maximum of 2 personnel performing the offsite independent review function (the NRB) by permitting these NRB members to meet the following alternative qualification requirements:
a) a minimum of 20 years nuclear related experience, b) shall hold or have held a senior reactor operator license or certification, c) shall have served as a minimum in a nuclear vice-president or equivalent position.
Additionally, the Director-QA/NSR will approve and document the.
alternative qualifications for NRB members where exception to the ANS 3.1-1981, Section 4.7, qualification is necessary.
ANS 3.1-1981, Section 4.7, states, in part, that members of independent review committees shall have:
a)
Education:
Bachelor's Degree in Engineering or related science.
b)
Experience:
Five years of professional level experience in the field of specialty.
c) Training:
As required by Section 5.3.1, " Training for Managers and Supervisors."
The NRC staff finds that the proposed alternative experience qualification provides an equivalent level of knowledge, training, and experience for personnel performing the NRB function and the l
change does not reduce plant safety.
4)
PSE&G proposes in Section 17.2.1.1.2.3 of the QAP to appoint NRB subcommittees for the purposes of performing reviews or studies in areas requiring particular expertise or for performing special investigations. Additionally PSE&G proposes that NRB subcommittee members meet or exceed the qualifications described in Section 4.7 of ANS 3.1-1981 and that the chair person of an NRB subcommittee be an j
NRB member.
l The NRC staff finds that the proposed use of NRB subcommittees l-acceptable based on the fact that subcommittee members meet or exceed i
the qualification of NRB members.
- 5) TS 6.5.2.4.4.b presently requires that audit reports performed by an independent consultant be forwarded by the auditing organization to the Chief Nuclear Officer and President and to management positions i
L responsible for the area audited within 60 days after completion of l
the audit.
FSAR Section 1.8 currently indicates a commitment to ANSI l
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N45.2.12, " Requirements for Auditing Quality Assurance Programs for Nuclear Power Plants," as endorsed by Regulatory Guide 1.144,
" Auditing of Quality Assurance Programs for Nuclear Power Plants,"
Revision 1, which specifies that audit reports be forwarded by the i
auditing organization within 30 days after completion of the audit.
i PSE&G proposes to revise FSAR Section 1.8 to incorporate the current i
TSs provision for audits performed by an independent consultant to be j
forwarded within 60 days after completion of the audit by identifying this as an exception to RG 1.144.
The NRC staff finds that the proposed exception to RG 1.144 i
acceptable based on the fact that the current TSs permits audits performed by an independent consultant to be forwarded within 60 days after completion of the audit.
l1 The licensee proposed to relocate the independent safety engineering j
function requirements in existing TS 6.5.2.5, "On Site Safsty Review Group (SRG)," currently performed by the SRG to QAP Section i
17.2.1.1.2.4, "On Site Independent Review," with the following j
changes:
- 1) The proposed ch age would eliminate the independent onsite review function as a dedicated organization and reassign the function to the Quality Assessment Department.
- 2) Qualification changes j
TS 6.5.2.2 qualification currently requires that the SRG staff 4
l shall meet or exceed the qualifications described in Section 4.4 of ANS 3.1-1981.
PSE&G proposes in Section 17.2.1.1.2.4 of the QAP to reduce the qualifications for the review personnel j
performing the onsite independent review function by permitting i
these reviewers to meet the following alternative qualificatien i
requirements:
The personnel performing the onsite independent review shall i
have:
i a) at least 3 years related experience of which at least 2 years i
are nuclear related, and a Bachelor's Degree in Engineering or related field, or I
b) at least 8 years related experience, of which at least 5 years are nuclear related, or c) for the discipline of Operations, a senior reactor operator license or certificate may be used as an alternative qualification to having a Bachelor's Degree in Engineering or related field.
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Further, QAP Section 17.2.1.1.2.4 would require that at least 50 percent i
of the personnel performing the onsite independent review function have a
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Bachelor's Degree in Engineering or a related field.
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The NRC staff finds that the proposed alternative experience qualification provides an equivalent level of knowledge and experience
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for personnel perfoming the onsite review function.
4 The licensee proposed to relocate the technical review and control for procedure related documents and non-procedure related documents in existing TS l
6.5.3, " Technical Review and Control," to Section 17.2.1.1.2.1 of the QAP with the following change-i The TS 6.5.3.4 requirement that copies of program and procedure records shall be provided to the General Manager, SORC, or the OSR staff and/or the NRC as necessary when their reviews are required has been deleted in relocating this TS section to the QAP.
Because these reviews are maintained as records and are available for review upon request, the staff finds this deletion acceptable.
The NRC staff has reviewed the changes to the relocated TS sections and
~ determined that the incorporation of the changes into the QAP are acceptable in that the QAP continues to satisfy the applicable criteria of Appendix B to
-10 CFR Part 50 and NUREG 0800 (SRP Section 17.2).
Based on the considerations discussed above and the fact that any subsequent changes to the relocated TS provisions will be controlled in accordance with 10 CFR 50.54(a), the staff concludes that the revisions to the QAP, as proposed by letters dated i
January 11, 1996, as supplemented on February 26, 1996, May 22, 1996, June 27, 1996, and December 23, 1996, are acceptable.
Given that the requirements in the QAP implements the Commission's regulations pertaining to the review and audit functions, inclusion of these particular provisions in TSs is not necessary to assure safe operation of the facility.
The review and audit functions define an administrative framework to confirm that plant activities have been properly conducted in a safe manner. The reviews and audits serve also to provide a cohesive program that provides senior level utility management with assessments of facility operation and recommends actions to isaprove nuclear safety and reliability. However, the staff has determined that the review'and audit functions are adequately 2
addressed by existing regulations and the related QAP commitments.
Based upon the relocation of the review and audit provisions to the QAP, it is not necessary to include redundant or additional requirements in the TS administrative controls.
The licensee will continue to implement the QAP in accordance with the requirements of 10 CFR Part 50, Appendix B, and commitments to ANSI N18.7, which provides appropriate controls for the approval of changes to the audit functions and frequencies.
Changes to the QAP are controlled in accordance with 10 CFR 50.54(a) and include requirements for prior NRC review and
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approval if a change constitutes a reduction in a QAP commitment. The staff concludes that this regulatory requirement provides sufficient control for the audit and review functions, so that removing these requirements from the TSs is acceptable.
In conclusion, the above relocated requirements relating to administrative controls are not required to be in the TSs under 10 CFR Section 50.36 or Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
In addition, the Staff finds that the resulting new administrative controls provides all of the requirements needed to satisfy 10 CFR 50.36(c)(5), and sufficient regulatory controls exist under 50.54(a), or other applicable regulation to assure continued protection of the public health and safety. Accordingly, the staff has concluded that these requirements may be relocated from the TSs to the above specified docr ents.
2.2 Manaaement Titles The licensee has proposed to replace several specific management titles with generic management functional positions. This change is intended to preclude future amendment requests caused by changes to these titles. The specific positions affected are:
(1) " General Manager - Hope Creek Operations" changed to " plant manager" (2) " Chief Nuclear Officer and President Nuclear Business Unit" changed to " senior corporate nuclear officer" (3) " Director - Quality Assurance and Nuclear Safety Review" changed to
" senior management position with responsibility for independent nuclear safety assessment activities and quality program oversight" The specific titles and responsibilities of key organization positions, including those above, will be maintained in licensee controlled documents such as the UFSAR and the Quality Assurance Program.
Provided that the generic management functional positions adequately define the individuals responsible for the affected TS requirements, the proposed change is administrative or editorial in nature. The staff has determined that the proposed changes maintain an adequate delineation of the individuals responsible for the various activities and is therefore acceptable.
- .3 Assistant Operations Manager 2
The licensee has' proposed to change the title of the " Operating Engineer" to
" Assistant Operations Manager." Provided that the title change reflects organizational changes and maintain adequate assignment of responsibilities to individuals, the proposed change is administrative or editorial in nature.
The staff has determined that the proposed change is a straightforward title change and that the responsibilities for the position of Assistant Operations Manager (previously Operating Engineer) have not been changed. The changes i
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and Operations Manager are addressed below. The staff finds that the title j
change for the Assistant Operations Manager is acceptable.
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2.4 Qualifications for the Operations Manager j
2.4.1 Discussion With regard to qualifications for the " Operations Manager", 10 CFR 50.54(1) j requires the licensee to " designate individuals to be responsible for directing the licensed activities of licensed operators. These individuals shall be licensed as senior operators...." The licensee is committed to unit staff qualifications that meet American National Standards Institute (ANSI)
ANSI 3.1-1981 for Hope Creek. The qualifications for the Operations Manager, specified in Hope Creek TS 6.3.3, requires the Operations Manager to hold an I
SR0 license for the specific unit at the time of appointment to the active position, or have held an SR0 license at a similar unit.
In its submittal i
dated January 11, 1996, as supplemented by letters dated February 26 and July 12, 1996, the licensee proposes that the Operations Manager or Assistant Operations Manager hold an SRO license.
If the licensee chooses to have the i
Assistant Operations Manager hold the SR0 license, the minimum qualification j
for the Operations Manager would be for the manager to "...Have been certified at an appropriate simulator for equivalent senior operator knowledge."
2.4.2 Evaluation l
In their submittal dated January 11, 1996, as supplemented by letter dated i.
February 26 and July 12, 1996, the licensee requested a change in Section 6.3.1 of the Technical Specification that would permit an individual who does l
not have a current SRO license to hold the Operations Manager position. The licensee indicates that the proposed change would require the individual who l
serves as the Operations Manager to either hold an SR0 license, have held an i
SR0 at a similar unit, or have been certified at an appropriate simulator for equivalent senior operator knowledge.
To meet the requirements of 10 CFR i
4 50.54(1), the licensee further stated that if the Operations Manager does not hold an SR0 license, then the Assistant Operations Manager will hold an SR0 license and will also meet the qualification requirements of Section 4.3.8,
" Operations" of ANSI /ANS 3.1-1981, "American National Standard for Selection, Qualification, and Testing of Personnel for Nuclear Power Plants," for Hope Creek.
The staff notes that the on-shift operating crews must report directly to and receive overal1 ~ day-to-day guidance on plant operations from the individual holding the current license in order for the licensee to meet the requirements of 10 CFR 50.54(1). Additionally, in times of transition, that is, those times when the SRO-licensed manager leaves the position, a person with a current SR0 license must be made responsible for the crews in order for the licensee to continue to meet the requirements of 10 CFR 50.54(1).
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I i The staff concludes that the specification that either the Operations Manager or the Assistant Operations Manager hold an SRO license is consistent with the i
requirements of 10 CFR 50.54(1) and ensures that a licensed off-shift senior operator is directing the licensed activities of the licensed operators I
provided that the crews report directly to and receive overall day-to-day guidance on plant operations from the individual holding the current SRO license.
Requiring a qualified (ANSI /ANS-3.1-1981) and SRO-licensed Assistant Operations Manager when the Operations Manager does not hold an SR0 license is consistent with the requirements of ANSI N18.1-1981. Moreover, these requirements ensure that there is site-specific, detailed, relevant technical and systems knowledge, in a senior operations management position. Under conditions where the Assistant Operation Manager holds an SR0 license, the minimum qualifications for the Operations Manager, having "...been certified at an appropriate simulator for equivalent senior operator knowledge," is in accordance with ANSI /ANS-3.1-1987, and is acceptable.
Therefore, the staff concludes that the proposed change to Hope Creek TS 6.3.1, which allows either the Operations Manager or the Assistant Operations Manager to hold an SR0 license is consistent with and meets the intent of.the relevant review criteria. The proposed TS change is acceptable provided that the appropriate organizational reporting chain for the crews to the Assistant Operations Manager who holds an SR0 license, is in place.
2.5 Editorial Changes / Typographical Errors The licensee has proposed to correct typographical errors in the Table of Contents, TS Section 6.8.4.a and TS Section 6.13.2.1.
The staff concurs that these changes are appropriate editorial corrections and are acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the.New Jersey State Official was notified of the proposed issuance of the amendment.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
i The amendment relates 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 conjunction with the issuance of the amendment.
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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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
W. D. Reckley L. Campbell D. H. Jaffe Date: March 21, 1997 i
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