ML20205Q324

Submits Addl Info Re TS Change Request NPF-38-215 for Administrative Controls TS Changes.Appropriate Pages from New Entergy Common QA Program Manual Provided as Attachment to Ltr

ML20205Q324
Person / Time
Site:	Waterford
Issue date:	04/16/1999
From:	Ewing E ENTERGY OPERATIONS, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
W3F1-99-0074, W3F1-99-74, NUDOCS 9904210165
Download: ML20205Q324 (7)

Text

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y Ent gy Oper ti:ns,Inc.

Killona. LA 70006 Tel 504 739 6242 Early C. Ewing, lil i

l Director J ear Safety & Regulatory Affairs l W3F1-99-0074

! A4.05 l PR i

April 16,1999 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 SES Docket No. 50-382 License No. NPF-38 Additional Information Regarding Technical Specification Change Request NPF-38-215 Administrative Controls Technical Specification Changes l

Gentlemen:

By Letter W3F1-99-0007, " Technical Specification Change Request NPF-38-215 Administrative Contrai: Technical Specification Changes" dated January 25,1999, Entergy provided for NRC Staff review a change to rnodify Section 6.0 of the Waterford 3 Technical Specifications (TS) to remove certain administrative controls and instead /

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! rely on the change controls of 10 CFR 50.54(a)(3) in response to a request from Mr.

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Ray Smith of your Staff, Entergy is hereby providing the following information l delineating where each requirement being deleted from the TS will be required. J l Appropriate pages from the new Entergy common Quality Assurance Program Manual I are provided as an Attachmert to this letter. This information augments Table 2 of

! W3F1-99-0007.

1. Technical Specifications Section 6.1.1 Proposed Revision i

l Section 6.1.1 will require the General Manager Plant Operations or his designee j to approve, prior to implementation, each proposed test, experiment or modification to systems or equipment that affect nuclear safety. j 9904210165 990416 PDR ADOCK 05000302 P PDR

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l l Additional Information Regarding Technical Specification Change Request NPF-38-215 l Administrative Controls Technical Specification Changes l l

W3F1-99-0074 -

l Page 2 April 16,1999 l

Relocation Since this is a more restrictive addition, consistent with NUREG 1432 Section 5.1.1, this change is not discussed in this letter.

2. Technical Specifications Section 6.6.1.b Proposed Revision l TS Section 6.6.1.b will no longer require each REPORTABLE EVENT be reviewed by the Plant Operating Review Committee (PORC) and will not require l that the results of this review be submitted to the Safety Review Committee l (SRC) and the Vice President Operations.

Relocation The requirement to review REPORTABLE EVENTS has been moved to the new i Entergy common Quality Assurance Program Manual (QAPM). The new QAPM l

! in Table 1, " Regulatory Commitments," Section C.8 requires the on-site (PORC) ?

l and off-site (SRC) safety review committees to review all reports made in .

accordance with 10 CFR 50.73. ANSI N18.7 Section 4.3.4(4) is referenced. I

3. Technical Specifications Section 6.7.1.b Proposed Revision TS Section 6.7.1.b will no longer require Safety Limit Violation Reports be I reviewed by the PORC. Section 6.7.1.b will continue to describe the required content of the report.

Relocation Safety Limit Violation Reports fall under the reporting requirements of 10 CFR l 50.73 and thus would be covered as in item 2 (above).

Additional Information Regarding Technical Specification Change Request NPF-38-215 Administrative Controls Technical Specification Changes W3F1-99-0074 Page 3 April 16,1999

4. Technical Specifications Section 6.7.1.c Proposed Revision TS Section 6.7.1.c will no longer require Safety Limit VicizMn Reports be submitted to the SRC. Section 6.7.1.b wi;i continue to require that the report be submitted to the Commission and the Vice President Operations.

Relocation Safety Limit Violation Reports fall under the reporting requirements of 10 CFR 50.73 and thus would be covered as in item 2 (above).

5. Technical Specifications Section 6.13.2.b Proposed Revision TS Section 6.13.2.b will no longer require the 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.

Relocation The requirement to review PCP changes has been moved to the new Entergy 1 common QAPM. The new QAPM in Table 1, " Regulatory Commitments,"

Section C.9 requires the on-site 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 I therefore requires PORC review. ANSI N18.7 Section 4.3.4(5)is referenced.

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Additional Information Regarding Technical Specification Change Request NPF-38-215 Acfministrative Controls Technical Specification Changes W3F1-99-0074 Page 4 l

April 16,1999  ;

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6. Technical Specifications Section 6.14.2.b Proposed Revision )

l TS Section 6.14.2.b will no longer require the licensee-initiated changes to the !

Offsite Dose Calculation Manual (ODCM) be reviewed and accepted by the l PORC prior to becoming effective. Section 6.14.2.b will co .tinue to require approval by the General Manager Plant Operations.

Relocation The requirement to review ODCM changes has been raoved to the new Entergy common QAPM. The new QAPM in Table 1, " Regulatory Commitments,"

Section C.9 requires the on-site 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 rc nw. ANSI N18.7 Section 4.3.4(5)is referenced.

Should you have any questions or comments concerning this information, please I contact me at (504) 739-6242 or Curt Taylor at (504) 739-6725.

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Very truly yours, j td5 E.C. Ewing Director, Nuclear Safety & Regulatory Affairs ECE/ CWT /ssf

Attachment:

Portions of QAPM (w/ Attachment) cc: E.W. Merschoff (NRC Region IV), C.P Patel (NRC-NRR), J. Smith, N.S. Reynolds, NRC Resident Inspectors Office, Administrator Radiation Protection Division (State of Louisiana), American l Nuclear Insurers 1 l

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l W3F1-99-0074 ATTACHMENT A i

4 PORTIONS OF QAPM )

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s e :: = 7 _

J Quality Assurance Program Manual Arkansas Nuclear One Units 1 & 2 Docket Nos. 50-313 & 50-368 License Nos. OPR-51 & NPF-6 Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 River Bend Station Docket No. 50-458 License No. NPF-47 Waterford 3 Steam Electric Station Docket No. 50-382 License No. NPF-38 Revision 0

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J QUALITY ASSURANCE PROGRAM MANUAL

-Entergy 1 Table 1 l Regulatory Cominitments l C. Regulatory Guide 1.33 (continued) l Clarification / Exception l 7- ANSIN18.Y Revision to proposed Technical Specification changes only require Section 4.3.4(3) review in accordance with this section when the revision involves a significant chance to the technical basis for the proposed change.

8. ANSI N18.7 In place of the requirements of this section, the on-site and off-site l Section 4.3.4(4) safety review committees shall review facility operations to detect l potential nuclear safety hazards and all reports made in accordance with 10 CFR 50.73.

9. ANSI N18.7 Examples of the matters reviewed by the on-site safety review Section 4.3.4(5) committee in accordance with this section are the following:

a. new and revised station administrative procedures and 1

b. changes to the Emergency Plan (except editorial changes).

10. ANSI N18.7 This section establishes minimum 2 year audit frequency for all Section 4.5 safety related functions. Entergy will perform audits at frequencies i as discussed in QAPM Section C.2 a instead of this section.

11. ANSI N18.7 The independent review body discussed in this section is the off-site Section 4.5 safety review committee.

12. ANSI N18.7 Instead of the requirements of this section to have a summary Section 5.1 document, a method of cross referencing these requirements to the I implementing procedures will be maintained.

13. ANSI N18.7 The person who holds a senior reactor operators license for the l Section 5.2.2 affected unit and approves a temporary change to a procedure is not required to be in charge of the shift.

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24 Revision 0 I i