ML20197J977
| ML20197J977 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/10/1997 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20197J974 | List: |
| References | |
| NUDOCS 9801050159 | |
| Download: ML20197J977 (5) | |
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t UNITED STATES g
,j NUCLEAR REGULATORY COMMISSION t
WASHINGTON, D.C. 30MH001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIOW RELATfD TO AMENDMENT NOS. 2no AND A7 TO FACILITY OPERATING LICENSE NOS. DPR-66 AND NPF-73 DUOVESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY THE TOLEDO EDISON COMPANY BEAVER VALLEY POWER STATION. UNIT N05. 1 AND 2 DOCKET N05. 50-334 AND 50-412
1.0 INTRODUCTION
By letter dated March 14, 1997, as supplemented July 29, 1997, and August 13, 1997, the Duquesne Light Company (the licensee) submitted a request for changes to the Beaver Valley Power Station, Unit Nos. I and 2 (BVPS-1 and BVPS-2), Technical Specifications (TSs). The requested changes would relocate certain administrative control TSs from the BVPS-1 and BVPS-2 TSs to the licensee's operational quality assurance program description, which is presented in Section 17.2 of the BVPS-2 Updated Final Safety Analysis Report (UFSAR).
Section 17.2 of the BVPS-2 UFSAR contains the quality assurance program descri) tion for both BVPS-1 and BVPS-2.
The following TSs ar being relocated to tie quality assurance program description.
BVPS-2 TS 6.2.3 (Independent Safety Evaluation Group)
BVPS-1 and BVPS-2 TS 6.5.1 (Onsite Safaty Committee)
BVPS-1 and BVPS-2 TS 6.5.2 (Offsite Review Committee)
BVPS-1 and BVPS-2 TS 6.8.2 (Procedures, Review and Approval)
BVPS-1 and BVPS-2 TS 6.8.3 (Temporary Procedure Changes, Review and Approval)
BVPS-1 and BVPS-2 TS 6.10.1 (Records Retention, At least C Years)
BVPS-1 and BVPS-2 TS 6.10.2 (Records Retention, Duration of Operating License)
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i 2-The July 29, 1997, and August 13, 1997, letters provided clarifying
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1raformation that did not change the initial proposed no significant hazards consideration detemination or expand the amedmont request beyond the scope of the May 7,1997, Federal Reatster notice.
2.0 BACKGROLNW i
Section 182a of the Atomic Ener nuclear power plant operating 1$y Act (the "Act") requires applicants forcenses to ini The Commission's regulatory requirements related to the content of TSs are set forth 'in 10 CFR 50.36.
That regulation requires that the TS include items in
- five specific categories: (1) safety limits, limiting safety system settings, and limiting safety settings; (2) limiting conditions for operations; (3) surveillance requirements; (4) design featurest and (5) administrative i
controls.. The regulation, however, does not specify the particular requirements to be included in the plant TSs.
t Section 50.36 provides, 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 "Ss.
While the four criteria j
specifically apply to LCO, 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 TSs (60 FR 36957).
4 Administrative controls 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 i
s)ecific content of the administrative controls section of the TSs is, tierefore, that information that the Commission deems essential for the safe operation of the facility that is not already covered by regulations.
Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 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 Plan, and Emergency Plan) and controlled by the applicable j
regulatory requirement.
Similarly, while the required content of TS of administrative controls may be relocated to licensee-(controlled documentsadministra!
4 where the provisions of 10 CFR 50.51, 10 CFR 50.59 or other regulations provide adequate regulatory ~ control.
NRC Administrative Letter 95-06 provides guidance to licensees requesting
- amendments that relocate the administrative controls within its NRC-approved quality assurance program description (QAPD), where subsequent
. changes are controlled by 10 CFR 50.54(a). Adatnistrative letter 95-06 provides specific guidance in the aress of (1) Independent Safety Engineering Group.(ISEG),-(2)dRetention. Reviews and Audits, (3) Procedure Review Process, and (4)
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- 3.0 EVALUATION The licensee proposes to relocate, from the TSs to the QAPD, certain administrative controls related to the four areas addressed below.
The QAPD is located in Section 17.2 of the BVPS Unit 2 UFSAR.
(Section A.2.2 of the BVPS-1 UFSAR references the Unit 2 UFSAR, Section 17.2 for the QAPD.)
Unless otherwise noted in the following evaluation, the licensee proposes to relocate administrative controls intact, with no changes in requirements. All editorial changes are nonsubstantive and are made either to clarify or to
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accommodate UFSAR text numbering and formatting conventions and are, therefore, acceptable.
3.1 Independent Safety Engineering Group The licensee proposes that the ISEG function (TS 6.2.3) be relocated to the QAPD with no changes in requirements, except for composition (TS 6.2.3.2).
The licensee proposes to reduce the ISEG permanent staffing level from five to three personnel; ISEG personnel qualification requirements remain unchanged.
The principal function of the ISEG, as stated in NUREG-0737, "is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other ap)ropriate sources of plant design and operating euerience information taat may indicate areas for improving plant safety.'
The BVPS ISEG has performed this function since 1987.. Since its inception, the BVPS ISEG has reviewed all NUREG-0737 issues for both units and has provided detailed recommendations to station management for revised procedures, equipment modifications, maintenance activities, operations activities, or other means of improving operational safety.
Although the ISEG contribution is recognized, the level of ISEG involvement depends on unit operating conditions and emergence of regulatory and industry issues.
In addition, many of the issues addressed by NUREG-0737 are now performed by other BVPS organizations.
Because many ISEG reviews are redundant, the requirement to maintain an ISEG staffig level of five dedicated engineers is burdensome in that it restricts station management's capability to utilize resources to their maximum advantage and does not result in an increase in the protection afforded to th6 health and safety of the public.
The BVPS ISEG will continue to perform its review function with the proposed reduction in staffing. The experience gained over the last 10 years through organizational chat.ges and process improvements has provided confidence that the ISEG function will continue to be fulfilled. At times when increased ISEG staffing may prove beneficial for evaluating issues and recommending plant safety improvements, the ISEG staffing will be increased, consistent with the efficient use of site resources to address both continuing and emergent plant issues.
The proposed change would provide flexibility to accomplish the ISEG function without compromising the overall ISEG purpose, scope, or thoroughness of reviews.
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. 3.2 Reviews and Audits The licensee proposes that review and audit functions specified in TS 6.5 be relocated to the QAPD intact, with no change in requirements. This includes both the onsite review function (TS 6.5.1) and the offsite review function (TS 6.5.2).
3.3 Procedure Review Process Plant operating procedures and administrative policies are specified by TS 6.8.1.
The licensee proposes that the process for review and approval of these procedures and administrative policies (TS 6.8.2) be relocated to the j
QAPD intact, with no change in requirements; the licensee further proposes i
that the process for controlling temporary changes to these procedures (TS 6.8.3) be relocated to the QAPD.
1 3.4 Records and Record Retention i
The licensee proposes that the record retention process specified by TS 6.10 be relocated to the QAPD intact, with no change in requirements.
4.0
SUMMARY
The NRC staff finds the reduction in ISEG staffing level to be acceptable.
With this exception, the proposed relocation of the TS administrative controls to the QAPD description has been acccmplished with no change in requirements or substantive editorial changes. Relocation is consistent with the guidelines provided by NRC Administrative Letter 95-06 and is, therefore, acceptable.
As part of the quality assurance prt, gram, subsequent changes to these administrative controls will be controlled pursuant to 10 CFR 50.54(a),
in conclusion, requirements related to the administrative controls described above, which the licensee proposes be relocated, are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, are not necessary to assure o)eration of the facility in a safe manner, and are not required to obviate tie possibility of an abnormal situation or event giving
'rlse to an immediate threat to public health and safety and are, therefore, acceptable.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and to
j significant change in the types, of any effluents that may be released i
offsite, and that there is no significant increase in individual or cumulative occupational radistion exposure. The Commission has previously issued a proposed findin consideration, g that the amendment involves no significant hazards and there has been no public comment on such finding The amendment also relates to changes in recordkeeping, repo(62 FR 24986).
rting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10).
Pursuant to 10 CFR 51.22(b, no environmental impact statement or environmental assessment need be prep)ared in connection with the i
issuance of the amendment.
7.0 CONCLUSION
The Comission 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 l
activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
K. Heck Date: December 10, 1997 l
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