ML20195E255
| ML20195E255 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/17/1988 |
| From: | Matthews D Office of Nuclear Reactor Regulation |
| To: | Tucker H DUKE POWER CO. |
| References | |
| TAC-67354, TAC-67355, NUDOCS 8806230339 | |
| Download: ML20195E255 (4) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 3
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June 17, 1988 Docket Nos.:
50-369 and 50-370 Mr. H. B. Tucker, Vice President Nuclear Production Department Duke Power Company 422 South Church Street Charlotte, North Carolina 28242
Dear Mr. Tucker:
SUBJECT:
PROPOSED TECHNICAL SPECIFICATION CHANGES ON ADMINISTRATIVE CONTROLS -
MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 (TACS 67354/67355)
By letter dated February 22, 1988, you requested changes to Chapter 6 of the McGuire Technical Specifications (TSs), "Administrative Controls." The changes would involve training controls, technical review and audit controls, functions specified for the Nuclear Safety Review Board (NSPB), the level of reporting requireo for the Annual Radiological Environmental Operating Reports and consistency with 10 CFR 50.4.
In accordance with 10 CFR 50.36(c)(5), the Administrative Controls of McGuire TS Chapter 6 specify the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting "necessary to assure operation of the facility in a safe manner." We disagree with your 10 CFR 50.92 analysis that the changes are "purely administrative" or that because the proposed changes are all administrative in nature, they do not impact station operation. Moreover, we find insufficient support for your conclusions that the changes would not involve any significant hazards consideration.
TS 6.4.1 presently requires the retraining and replacement training program for the unit staff to meet or exceed the requirements and recommendations of Section 5.5 of ANSI N 18.1-1971 and Appendix A of 10 CFR Part 55, and the supplemented requirements specified in Sections A and C of Enclosure 1 to the March 28, 1980, NRC letter to all licensees, and to include familiarization with relevant industry operational experience identified by the Station Safety Review Group.
You propose to delete the reference to Section 5.5 of ANSI N18.1-1971 because you find it redundant to 10 CFR Part 55, issued March 25, 1987. We find, however, that Section 5.5 of the Standard describes training requirements for the entire unit stoff, while 10 CFR Part 55 deals with requirements for licensed operators. Additionally, we find no support in your submittal for celetion of the existing requirement that training for unit staff include familiarization with relevant industry operational experience.
You propose to change TS 6.5.2.8 to state "The NSRB shall be responsible for the review of" rather than "The NSRB shall review." You state that the NSRB carries out its responsibilities with the support of a "Nuclear Safety Assurance 8806230339 880617 I
PDR ADOCK 05000369 P
'Sb~26f Mr. H. B. Tucker staff" that reviews documentation of station activities, forwards to NSRB copies of documents requiring review, and provides NSRB with suncaries and trends of incidents and key results from the review of station activities perforraed by the NRC, INF0 and othe.r bcdies.
We find no description of this staff in your <;bmittal or FSAR or response to TMI concerns.
Without inforraation regarding the omposition and qualifications of this staff to perform these functions, we rind insufficient bases to relieve the NSRB of its existing requirements.
You also note, but do not identify, a new title for the person f
in charge of the NSRB.
Your request regarding the Annual Radiological Environmental Operating Report is primarily a repeat of your April 22, 1988, request with minor related additions.
Our denial of June 16, 1988, continues to apply and for th..,ame reasons.
Your proposed changes to the reporting requi.ements of TSs 6.9.1, 6.9.1.8 and 6.9.2 would change the NRC addressee and were requested in order to provide for consistency with 10 CFi! 50.4 We find this request to be unnecessary.
The regulation by its terrrs (50.5f) replaced the existing requirements and instructed licensees in the Stateraent of Consideration (51 FR 40303) to rnake pen and ink changes.
We find that expenditure of NRC resources tc process amendn.ents to this end is unwarranted.
Accordingly, we find your submittal of February 22, 1988, to be unacceptable and we plan to take no further action on it.
If you have questions regarding this denial, contact Darl Hood at (301) 492-1442.
Sincerely, Original signed by:
David B. Matthews, Director Project Directorate 11-3 Division of Reactor Projects I/II cc:
See next page DISTRIBUTION:
Docket-File NRC PDR-Local PDR PDII-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. flatthews 14-H-25 M. Rood 14-H-25 D. Hood 14-H-25 E. Joroon MNBB-3302
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McGuire Reading A
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UPDII-3 f(,Rbd{I-3 DHood:pw AGod DMatthews 6 //_3 /88 fy / lg88 6/ / 8 h / g/88 f
I Mr. H. B. Tucker staff" that reviews documentation of station activities, forwards to NSRB copies of documents requiring review, and provides NSRB with sumaries and trends of incidents and key results from the review of station activities performed by the NRC, INP0 and other bcdies.
We find no description of this staff in your submittal or FSAR or response to TMI concerns.
Without information regarding the composition and qualifications of this staff to perform these functions, we fino insufficient bases to relieve the NSRB of its existing requirements.
You also note, but 00 not identify, a new title for the person in charge of the NSRB, Your request regarding the Annual Radiological Environmental Operating Report is primarily a repeat of your April 22, 1988, request with minor related additions. Our denial of June 16, 1988, continues to apply and for the same reasons.
Your proposed changes to the reporting requirements of TSs 6.9.1, 6.9.1.8 and 6.9.2 would change the NRC addressee and were requested in order to provide for
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consistency with 10 CFR 50.4 We find this request to be unnecessary.
The regulation by its terms (50.5f) replaced the existing requirements and i
instructed licensees in the Statement of Consideration (51 FR 40303) to make pen and ink changes. We find that expenditure of NRC resources to process amendn.ents to this end is unwarranted.
Accordingly, we find your submittal of February 22, 1988, to be unacceptable and we plan to take no further action on it.
If you have questions regarding this denial, contact Darl Hood at (301) 492-1442.
Sincerely, Original signed by:
David B. Matthews, Director Project Directcrate II-3 Division of Reactor Projects I/II CC.
See :. ext page j
DISTRIBUTION:
Docket File NRC PDR Local PDR PDII-3 Reading S. Varga 14-E-4 G. Lainas 14-H-3 D. Matthews 14-H-25 M. Road 14-H-25 D. Hood 14-H-25 E. Joroan MNBB-3302 J. Partlow 9-A-2 ACRS(10)
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McGuire Reading i(MMA ?ql-3 PM:PDII-3 M PEB:
11-3 DHocd:pw AGod DMatthews 6 //.5/88
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w Mr. H. B. Tucker Duke Power Company McGuire Nuclear Station cc:
Mr. A.V. Carr, Esq.
Dr. John it. Carry Duke Power Company Department of Environrr. ental Health P. O. Box 33189 Mecklenburg County 422 South Church Street 1200 Blythe Boulevard Charlotte, North Carolina 28242 Charlotte, North Carolina 28203 County Manager of Mecklenburg County Mr. Dayr,e H. Brown, Chief 720 East Fourth Street Rou:ation Protection Ctanch Charlotte, North Ccrolina 28202 Division of Facility Services Department of Hurr.an Resources 701 Barbour Drive 11r. Robert Gill Raleigh, North Carolina 27603-2008 Duke Power Company Nuclear Production Department P. O. Box 33189 Charlotte, North Carolina 23242 J. Michael McGarry, III, Esq.
Bishop, Liberman, Cook, Purcell and Reynolds 1200 Sever.teenth Street, N.W.
Washington, D. C.
20036 Senior Resident Inspector c/o U.S. Nuclear Regulatory Comission Route 4, Box 529 hunterville, North Carolina 28078 Regional Administrator, Regico II U.S. Nuclear Regulatory Comission, 101 Marietta Street, N.h., Suite 2900 Atlanta, Georgia 30323 S. S. Kilborn Area Manager, Mid-South Area ESSD Projects Westinghouse Electric Corporation NHC West Tower - Bay 239 P. O. Box 355 Pittsburgh, Pennsylvania 15230 I
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