ML20140G420
| ML20140G420 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/13/1997 |
| From: | John Hickman NRC (Affiliation Not Assigned) |
| To: | Myers L CENTERIOR ENERGY |
| References | |
| TAC-M98474, NUDOCS 9706160223 | |
| Download: ML20140G420 (5) | |
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NUCLEAR RESULATORY COMMISSION
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t WASHlHGTON, D.C. 30666-0001 4
.... 4 June 13, 1997 (W
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Mr. Lew W. Myers Vice President Nuclear - Perry Centerior Service Company P.O. Box 97, A200 Peny, OH 44081
SUBJECT:
CENTERIOR ENERGY, PROPOSED REDUCTION IN SCOPE OF j
RESPONSIBILITIES FOR PLANT OPERATIOl:S REVIEW COMMITTEE i
UPDATED SAFETY ANALYSIS REPORT CHANGE (TAC M98474)
Dear Mr. Myers:
By letter dated April 16,1997 Centerior Energy (the !icensee) submitted a 10 CFR 50.54(a) letter which transmitted proposed revisions to their quality assurance program (QAP) for the Peny Nuclear Power Plant. Specifically, the proposed change modifies the requirements related to the Plant Operations Review Committee (PORC) currently described in Chapter 17.2," Quality Assurance During the Operations F-hase," of the Updated Safety Analysis Report (USAR). As stated in the letter, the licensee's basis for the proposed change is to allow the FORC to refocus on essential plant safety reviews and to eliminate existing review 1
functions that are redundant to other plant organizational reviews.
The staff has completed its review of the subject submittalin accordance with 10 CFR 50.54(a), and Sections 13.4 and 17.2 of NUREG-0800, the " Standard Review Plan" 1
l (SRP). Based on this review, it was determined that the proposed changes are unacceptable in that inadequate justification was provided to establish how the criteria of Appendix B to 10 CFR Part 50 would continue to be sa:sfied. A description of the staff's findings in this area is 4
provided below.
Prooosed Chanoes to PORC Provisions The licensee's submittal states that the function of the PORC is to advise the General Manager, Perry Nuclear Power ?lant Department (PNPPD), on all matters related to nuclear safety. Under the proposed change, this function would be altered and the various PORC reviews, which had " minimal safety impact" or that were duplicative of other plant reviews, would be deleted. In particular, the licensee proposed that the PORC no longer be required to: (a) review anc, commend approval of procedures, except fire protection administrative procedures; (b) revmW proposed changes to the Operating License, including Technical Specifications (TS), for the presence of unreviewed safety questions; (c) review and recommend approval of Emergency Plan and Security Plan changes; and (d) designate preparers and apprcvers for procedures and instructions.
Section 13.4, of the SRP stipulates that the organizational unit designated to perform the review and oversight function (in this instance, the PORC) should (a) include the review scope of Section 4.4, " Review Activities of the Onsite Operating Organization," of ANSI N18.7-1976 (ANS-3.2), as endorsed by Regulatory Guide (RG) 1.33; (b) have organizational COPY 9706160223 970613 h
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arrangements that provide for interdisciplinary reviews of subject matter; (c) include as members plant personnel that meet, as a minimum, the qualification levels described in Section 4.4 of ANSI N18.1, as endorsed by RG 1.8; and (d) have the results of its activities 4
property documented and forwarded to appropriate members of management. In particular, Section 4.4 states that "The onsite operating organization shall provide, as part of the normal duties of plant supervisory personnel, timely and continuing monitoring of operating activities to assist the plant manager in keeping abreast of general plant conditions and to verify that the day to day operating activities are conducted safely and in accordance with applicable administrative controls [ emphasis added). These continuing monitoring activities are considered to be an integral part of the routine supervisory function and are important to the safety of the plant operation". Additionally, Section 4.4 of ANSI N18.7 provides that, during its periodic reviews, the onsite operating organization should " screen subjects of potential concern to independent reviewers and perform prelimir.ary investigations (see 4.3.4)"
[ emphasis added). The staff notes that Section 4.3.4," Subjects Requiring independent Review," includes, but is not limited to, those items that the licensee proposes not be reviewed by PORC.
This acceptance criteria is based on satisfying the relevant requirements of 10 CFR 50.40(b) as it relates to the licensee being technically qualified to engage in licensed activities, and of Appendix B to 10 CFR Part 50 as it relates to the review and oversight functions reavired by the licensee's QAP. The licensee relies on its commitment to the provisions in RG 1.33 to satisfy the requirements of Appendix B to 10 CFR Part 50, including those related to the review and audit function. The licensee may modify the organizational means by which it fulfills the review and audit function by providing an attemative to its commitments to RG 1.33. However, the licensee must also provide adequate justification for such an attemative and, pursuant to 10 CFR 50.54(a)(3)(ii), the bases for concluding that the revised QAP incorporating the change continues to satisfy the criteria of Appendix B to 10 CFR Part 50 must also be included in the submittal. Accordingly, the proposed changes related to PORC provisions are unacceptable. Should the licensee continue to pursue this attemative, it would be necessary to provide the staff with specific examples of PORC activities which are "more appropriately focused on safety oversight," but not identified under Section 4.3.4 of ANSI N18.7-1976.
Review of Chanaes to the Emeraency and Security Plans As described in the licensee's submittal, the guidance provided in Generic Letter 93-07 (GL 93-07) allows TS changes to remove (1) the review of the Emergency and Security Plans from the list of responsibilities of the PORC, and (2) the requiremants for the PORC to review procedures and procedure changes for the implementation of the Emergency and Security Plans. The licensee's submittal also indicates that the basis stated in GL 93-07 for removing these items from the TS is that the requirement is redundant to the information contained within the individual programs and that the programs should control which groups perform the reviews in order to meet the requirements set forth in the regulation.
a.
L. Myers,
While the staff agrees that GL 93-07 provides an acceptable approach for removing TS provisions related to the Emergency and Security Plans, the licensee has not provided adequate justification for removing such provisions from the QAP description. Specifically, 10 CFR 50.54(a)(3)(ii) states, in part, that submittals that contain changes to the QAP that do reduce commitments must include 'The reason for the change, and the basis for concluding that the revised program incorporating the change continues to satisfy the criteria of Appendix B of this part and the Safety Analysis Report QAP description commitments previously accepted by the NRC." Based on the staff's review in this area, it was determined that the licensee's submittal contained insufficient information related to the proposed implementation of the Emergency and Security Plans review and audit functions required by the applicable regulations. Therefore, the proposed changes related to the Emergency and Security Plans are unacceptable.
l Contact me at 301-415-3017 if you have any questions.
Sincerely, Original signed by:
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John B. Hickman, Project Manager Project Directorate lll-3 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50 440 cc: See next page DISTRIBUTION:
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PUBLIC PD3-3 R/F OGC gg ACRS 1
JRoe EAdensam GMarcus
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GGrant, Rlli RLatta JHopkins
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DOCUMENT NAME: G:\\ PERRY \\M98474 To receive a copy of this document, indicate in the box-
"C" = Copy without enclosures "E" = Copy with enclosures *N" = No copy OFFICE PD33-LA l6 PD33-PM e
NAME CBoyle Q()
JHickman@ 7 DATE 06//p7
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06//397 #
OFFICIAL RECORD COPY 160072
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L. Myers While the staff agrees that GL 93-07 provides an acceptable approach for removing TS provisions related to the Emergency and Security Plans, the licensee has not provided adequate justification for removing such provisions from the QAP description. Specifically, 10 CFR 50.54(a)(3)(ii) states, in part, that submittals that contain changes to the QAP that do reduce commitments must include "the reason for the change, and the basis for concluding l
that the revised program incorporating the change continues to satisfy the criteria of l
Appendix B of this part and the Safety Analysis Report QAP description commitments previously accepted by the NRC." Based on the staff's review in this area, it was determined that the licensee'c submittal contained insufficient information related to the proposed implementation of the Emergency and Security Plans review and audit functions required by the applicable regulations. Therefore, the proposed changes related to the Emergency and Security Plans are unacceptable.
Contact me at 301-415-3017 if you have any questions.
Sincerely, Original signed by:
John B. Hickman, Project Manager Project Directorate lil-3 Division of Reactor Projects lil/IV Office of Nuclear Reactor Regulation Docket No. 50-440 cc: See next page DISTRIBUTION:
Docket File PUBLIC PD3-3 R/F OGC ACRS JRoe EAdensam GMarcus GGrant, Rill RLatta l
JHopkins l
DOCUMENT NAME: G:\\ PERRY \\M98474 To rocsive a copy of this document, indicate in the box:
"C" = Copy wh%ut enclosures
- E" = Copy with enclosures "N" = No copy OFFICE PD33-LA 6
PD33-PM e
NAME CBoyle Q()
JHickman@ 7 DATE 06/Q97 0
06//597 #
l OFFICIAL RECORD COPY j
l L. Myers Perry Nuclear Power Plant Centerior Service Company Units 1 and 2 cc:
Jay E. Silberg,Potts & Trowbridge Esq.
Donna Owens. Director Shaw Pittman, Ohio Department of Commerce 2300 N Street. N. W.
Division of Industrial Compliance Washington, D. C.
20037 Bureau of 0 erations & Maintenance 6606 Tussin Road Mary E. O'Reilly P.O. Box 40 9 Centerior Energy Corporation Reynoldsburg, Ohio 43068-9009 300 Madison Avenue l
Toledo Ohio 43652 Mayor, Village of North Perry North Perry Village Hall Resident Inspector's Office 4778 Lockwood Road U. S. Nuclear Regulatory Commission North Perry Village Ohio 44081 Parmly at Center Road Perry. Ohio 44081.
Attorney General
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Department of Attorney General i
Regional Administrator, Region III 30 East Broad Street i
U. S. Nuclear Regulatory Commission Columbus, Ohio 43216 801 Warrenville Road
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Lisle Illinois 60532-4531 Radiological Health Progra Ohio Department of Health i
Lake County Prosecutor P.O. Box 118
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Lake County Administration Bldg.
Columbus, Ohio 43266-0118 i
105 Main Street i
Painesville. Ohio 44077 Ohio Environmental Protection bmplianceUnit Sue Hiatt DE OCRE Interim Representative ATTN:
Mr. Zack A. Clayton 8275 Munson P.O. Box 1049 Mentor. Ohio 44060 Columbus Ohio 43266-0149 Terry J. Lodge. Esq.
Chairman i
618 N. Michigan Street. Suite 105 Perry Township Board of Trustees Toledo Ohio 43624 3750 Center Rd., Box 65 Perry Ohio 44081 Ashtabula County Prosecutor 25 West Jefferson Street State of Ohio Jefferson. Ohio 44047 Public Utilities Commission East Broad Street Henry L. Hegrat Columbus, Ohio 43266-0573 Regulatory Affairs Manager Cleveland Electric Illuminating Co.
Richard D. Brandt, Plant Manager Perry Nuclear Power Plant Cleveland Electric Illuminating Co.
P. O. Box 97. A210 Perry Nuclear Power Plant Perry, Ohio 44081 P.O. Box 97. SB306 Perry, Ohio 44081 James R. Williams Chief of Staff Roy P. Lessy, Jr., Es Ohio Emergency Management Agency Andrew G. Berg. Esq. q.
2855 West Dublin Granville. Road Akin, Gump. Strauss, Hauer &
Columbus, Ohio 43235-2206 Feld. L.L.P.
Suite 400 Mayor. Village of Perry 1333 New Ham3 shire Avenue. NW.
4203 Har)er Street Washington. ).C. 20036 Perry. 0110 44081
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