ML20195J974
| ML20195J974 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 06/16/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20195J971 | List: |
| References | |
| NUDOCS 9906210171 | |
| Download: ML20195J974 (4) | |
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UNITED STATES
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g NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20086-0001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION BEj,.ATED TO AMENDMENT NO.152 TO FACILITY OPERATING LICENSE NO. NPF-38 ENTERGY OPERATIONS. INC.
WATERFORD STEAM ELECTRIC STATION. UNIT 3 DOCKET NO. 50-382
1.0 INTRODUCTION
By application dated January 25,1999, as supplemented by letter dated April 16,1999, Entergy Operations, Inc. (the licensee), submitted a request for changes to the Waterford Steam Electric Station, Unit 3 (Waterford 3), Technical Specifications (TSs). The requested changes would remove certain administrative controls from the Waterford 3 Technical Specifications and would rely on the requi.rements of the new common "Entergy Quality Assurance Program Manual" (QAPM) and the change controls of Title 10 of the Code of Federal Reaulations (10 CFR), Section 50.54(a). A conference call was held on April 7,1999, to discuss the specific QAPM requirements that address the requested TS changes. As a result, additional
'information was provided from the licensee by letter dated April 16,1999, that did not change the scope of the original application and expand the initial proposed no significant hazards consideration determination as published in the Federal Bggi t.at notice.
t Relocation of ceratin administrative control requirements from the TSs to the QAPM is consistent with the processes described in Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
2.0 -
DISCUSSION AND EVALUATION 2.1 Relocation of Administrative Control Technical Specification Requirements to the QAPM 2.1.1 Discussion Section 182a of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to state the TSs tc De included as part of the license.
The Commission's regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in five specific categories, one of which being administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.
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4 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 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 certain 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 frohi administrative controls. Therefore, some existing TS requirements may be relocated to morg appropriate documents; in this case, the OAPM, and controlled by the applicable regulatory requirements of 10 CFR 50.54(a).
- 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 information regarding 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.
2.1.2 Evaluation The licensee's January 25,1999, submittal, as supplemented by letter dated April 16,1999, proposed to add a more restrictive requirement to TS 6.1.1 and to remove certain review and approva! requirements, which are addressed in the QAPM description. The licensee also submitted the relevant section of the QAPM, which was reviewed by the staff. AL 95-06 discusses the relocation of review and approval requirements related to reports and procedures that the staff finds acceptable. The specific changes are addressed as follows:
TS 6.1.1 The proposed revision will require the General Manager Plant Operations or his designee to approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety. This is a more restrictive addition and it is consistent with NUREG-1432, " Improved Standard Technical Specifications for Combustion Engineering Plants," Section 5.1.1. Therefore, this change is acceptable.
TS 6.6.1.b TS 6.6.1.b will no longer require each Reportable Event to be reviewed by the Plant Operating Review Committee (PORC) and will not require that the results of this review be submitted to the Safety Review Committee (SRC) and Vice President Operations. The requirement to review Reportable Events is addressed in the QAPM. Table 1," Regulatory Commitments,"
Section C.8, of the QAPM, requires that the on-site (PORC) and off-site (SRC) safety review committees review all Reportable Events (reports made in accordance with 10 CFR 50.73).
ANSI N18.7, Section 4.3.4(4), is referenced. Therefore, the staff finds, that the reportable event i
- 6 e review requirements are adequately addressed in the QAPM, and that the requirements may be removed from the TSs as discussed in AL 95-06.
TS 6.7.1.b TS 6.7.1.b will no longer require Safety Limit Violation Reports to be reviewed by the PORC.
This section will continue to describe the required content of the report. Safety Limit Violation Reports fall under the reporting requirements of 10 CFR 50.73. The requirement to review Reportable Events is addressed in the QAPM. Table 1, " Regulatory Commitments,"
Section C.8, of the QAPM requires the on-site (PORC) and offeite (SRC) safety review committees to review all Reportable Events (reports made in accordance with 10 CFR 50.73).
ANSI N18.7, Section 4.3.4(4), is referenced. Therefore, the staff finds that the Safety Limit Violation Report review requirements are adequately addressed in the QAPM, and that the requirements may be removed from TSs as discussed in AL 95-06.
TS 6.7,1.c 1
TS 6.7.1.c will no longer require Safety Limit Violation Reports to be submitted to the SRC.
Section 6.7.1.c will continue to require that the report be submitted to the Commission and the Vice President Operations. Safety Limit Violation Reports fall under the reporting requirements of 10 CFR 50.73. The requirement to review Reportable Events is addressed in the QAPM.
Table 1, " Regulatory Commitments," Section C.8, of the QAPM, requires the on-site (PORC) and off-site (SRC) safety review committees to review all Reportable Events (reports made in accordance with 10 CFR 50.73). ANSI N18.7, Section 4.3.4(4), is referenced. Therefore, the
. staff finds that the Safety Limit Violation Report review requirements are adequately addressed in the QAPM, and that the requirements may be removed from the TSs as discussed in AL 95-06.
TS 6.13.2.b TS 6.13.2.b will no longer require that licensee-initiated changes to the Process Control Program (PCP) be reviewed and accepted by the PORC prior to becoming effective. Section 6.13.2.b will continue to require approval by the General Manager Plant Operations. Table 1,
" Regulatory Commitments," Section C.9, of the QAPM, requires the on-site (PORC) safety review committee to review new and revised station administrative procedures. The PCP procedure, RW-001-210, " Process Control Program," is designated as an administrative procedure and therefore requires PORC review. ANSI N18.7, Section 4.3.4(5), is referenced.
Therefore, the staff finds that the PCP review requirements are adequately addressed in the QAPM, and that the requirements may be removed from the TSs as discussed in AL 95-06.
j TS 6.14.2.b TS 6.14.2.b will no longer require that licensee-initiated changes to the Offsite Dose Calculation Manual (ODCM) be reviewed and accepted by the PORC prior to becoming effective. Section 6.14.2.b will continue to require approval by the General Manager Plant Operations. Table 1, j
" Regulatory Commitments," Section C.9, of the QAPM, requires the on-site (PORC) safety review committee to review new and revised station administrative procedures. The ODCM procedure, UNT-005-014, "Offsite Dose Calculation Manual," is designated as an administrative procedure and therefore requires PORC review. ANSI N18.7, Section 4.3.4(5), is referenced.
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Therefore, the staff finds that the ODCM review requirements are adequately addressed in the J OAPM, and that the requirements may be removed from the TSs as discussed in AL 95-06.
3.0
SUMMARY
The administrative controls for review and approval are not required to be in the TSs under j
10 CFR Section 50.36 or Section 182a of the Act, 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.
The staff finds that the requirements being removed from the TSs are adequately addressed in the QAPM. In addition, sufficient regulatory controls for these QAPM commitments exist under 10 CFR 50.54(a). Accordingly, the staff has concluded that these requirements may be removed from the TSs as requested.
4.0 STATE CONSULTATION
in accordance with the Commission's regulations, the Louisiana State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes 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 amendment.
8.0 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 II) 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: R. Smith Date: June 16, 1999
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