ML20149D836
| ML20149D836 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/15/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20149D834 | List: |
| References | |
| NUDOCS 9707180012 | |
| Download: ML20149D836 (5) | |
Text
__ _ _ _. _. _. _ _ - - _. _ _ _. - _.. _ _
f uy
[yu r
i UNITED STATES l
g j
NUCLEAR REGULATORY COMMISSION i
2
- WASHINGTON. D.C. 30006-0001
%.....+o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 211 TO FACILITY OPERATING LICENSE NO. DPR-32 5
AND AMENDMENT NO.211'TO FACILITY OPERATING LICENSE NO. DPR-37 i
l VIRGINIA ELECTRIC AND POWER COMPANY i
SURRY POWER STATION. UNIT NOS. 1 AND 2 i
DOCKET NOS. 50-280 AND 50-281 0
l.0
' INTRODUCTION i
By letter dated November 26, 1996, Virginia Electric and Power Company submitted a request for changes to the Surry Units 1 and 2 Technical Specifications (TSs).
The proposed amendments would eliminate the records retention requirements for the Administrative Section of the TSs in accordance j
with Generic Letter 95-06, " Relocation of Technical Specification i
Administrative Controls Related to Quality Assurance." The record retention 1
I requirements are currently located in both the TSs and in the Updated Final 3
Safety Analysis Report (UFSAR). Guidance on the proposed changes was l
developed by NRC,and provided in the Standard Technical Specifications for i
j Westinghouse Plants, NUREG-1431.
2.0 BACKGROUND
4 Section 182a of the Atomic Energy Act (the Act) requires applicants for i
nuclear-power plant operating licenses to state TSs to be included as part of the license.. The U.S. Nuclear Regulatory Commission's regulatory requirements j
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 (LCOs); (3) surveillance J
requirements; (4) design features; and (5) administrative controls. However, j
the regulation does not specify the particular requirements to be included in the clunt TSs.
}
The Commission has_ provided guidance for the contents of TSs in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power j
Reactors" (Final Policy Statement), 58 Federal Register (FR) 39132 (July 22, j
1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies i 182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TSs to licensee-controlled documents, consistent with the standard enunciated in Portland i
General Electric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
-In that case, the Atomic Safety and Licensing Appeal Board indicated that
" technical specifications are to be reserved for those matters as to which the 4
9707180012 970715 FM
^=
5
- =
m
I 2
imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether particular safety functions are required to be included in the TSs, as follows:
(1) Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure,.
system, or component which operating experience or probabilistic safety assessment has shown to be significant to public health and safety. The Commission recently adopted amendments to 10 CFR 50.36, pursuant to which the rule was revised to codify and incorporate these criteria.
See Final Rule,
" Technical Specifications," 60 FR 36953 (July 19,1995). As a result, TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TSs, while those TS requirements I
which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
10 CFR 50.36 provides that those existing TS LCOs which do not satisfy these four specified criteria may be relocated to the Updated Final Safety Analysis Report (UFSAR), such that future changes could be made to these provisions pursuant to 10 CFR 50.59. Other requirements 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, 550.59, or
. other regulations provide adequate regulatory control.
While the criteria specifically apply to LCOs, in adopting the revision to the l
rule the Commission indicated that the intent of these criteria can be i
utilized to identify the optimum set of administrative controls in the TSs (60 FR 36958). Addressing administrative controls, 10 CFR 50.36(c)(5) 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."
In other words, these provisions are ones that the Commission deems essential for the safe operation of the facility, and which are not already adequately covered by other regulations. Accordingly, the NRC 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.
l l
3
'3.0 EVALUATIOy By letter dated November 26, 1996, the licensee proposed changes that would delete the Surry TS requirements for record retention.
The relocation of l
those requirements to the Operational Quality Assurance Program (QAP) has been completed and they are contained in the Surry UFSAR.
The changes were I
reviewed in accordance with the guidance provided in NUREG-1431.
In addition, these changes were reviewed in accordance with the guidance provided in j
Administrative Letter 95-06, " Relocation of Technical Specification l
Administrative Controls Related to Quality Assurance" issued on December 12, 1995.
l 3.1 Record Retention l
l The licensee proposed that the requirements for record retention in TS l
6.5 be relocated because they are adequately addressed by the QAP (10 CFR Part 50, Appendix B, Criteria XVII). These items relocated to the QAP ere not necessary to assure safe operation of the plant. Change control for the relocated TSs record retention requirements is provided by 10 CFR 50.54(a).
Facility operations are performed in accordance with approved written procedures. Areas controlled by procedures include normal startup, operation and shutdown, abnormal conditions and emergencies, refueling, l
safety-related maintenance, surveillance and testing, and radiation control.
Facility records document appropriate station operations and activities.
Retention of these records provides document retrievability for review for compliance with requirements and regulations.
Post-compliance review of records does not directly assure operation of the facility in a safe manner, as activities described in these documents have already been perforned.
In addition, numerous other regulations such as 10 CFR Part 20,'Subpart L, and 10 CFR 50.71 require the retention of certain records related to operation of the nuclear plant.
The provisions in the QAP implement the Commission's regulations pertaining to the maintenance of records related to activities affecting quality.
The required controls related to record retention specified in i
various regulations and the provision incorporated into the QAP are considered to be redundant to the requirements currently in the TSs.
The NRC staff has determined that record retention requirements are adequately addressed by existing regulations and the related QAP commitments.
Based upon the relocation of the record retention provisions to the QAP, it is not necessary to include redundant or additional requiremants in the TS administrative centrols.
l The staff concludes that the regulatory requirements under 10 CFR Part 50, Appendix B provide sufficient control of the plant records, and sufficient regulatory controls exist for future changes to the program pursuant to 10 CFR 50.54(a), such that removing these provisions from i
the TSs is acceptable.
4 5
t
{
I
l l
4 In conclusion, the above relocated requirements relating to administrative l
controls are not required to be in the TSs under 10 CFR 50.36 or 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 provide all of the requirements needed to satisfy l
10 CFR 50.36(c)(5), and sufficient regulatory controls exist under l
10 CFR 50.59 and 50.54(a), or other applicable regulations to assure continued protection of the public health and safety. Accordingly, the staff has concluded that these requirements may be removed from the TSs since they currently exist in the above specified documents.
4.0 STATE CONSULTATION
1 l
In accordance with the Commission's regulations, the Virginia State Official was notified of the proposed issuance of the amendments.
The State Official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
These amendments change recordkeeping, reporting, or administrative procedures or requirements. Accordingly, these amendments meet 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 these amendments.
6.0 CONCLUSION
l The Commission hLs 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 l
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 Contributor: Tanya Eaton Date:
July 15,1997 l
l
i si siim uq LETTER DATED: July 15.1997 AMENDMENT NO. 211 TO FACILITY OPERATING LICENSE N0. DPR SURRY UNIT 1 AMENDMENT N0. 211 TO FACILITY OPERATING LICENSE N0. DPR SURRY VNIT 2 Distribution
'Bectet* File' PUBLIC PDII-1 Reading S. Varga, 14/E/4 D. Hagan, TWFN, 4/A/43 G. Hill (4), TWFN 5/C/3 C. Grimes, ll/F/23 ACRS J. Johnson, RII y
U