ML20210G413
| ML20210G413 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/27/1999 |
| From: | Campbell G CENTERIOR ENERGY |
| To: | |
| Shared Package | |
| ML20210G387 | List: |
| References | |
| RTR-NUREG-1430 AL-95-06, NUDOCS 9908030091 | |
| Download: ML20210G413 (2) | |
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- Docket Number 50-346 I License Number NPF-3
) Serial Number 2607
' Enclosure 1 '
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APPLICATION FOR AMENDMENT L
l TO FACILITY OPERATING LICENSE NUMBER NPF-3 DAVIS-BESSE NUCLEAR POWER STATION UNIT NUMBER 1 Attached are the requested changes to the Davis-Besse Nuclear Power Station, Unit Number 1 Facility Operating License Number NPF-3. Also included is the Safety Assessment and
' Significant Hazards Consideration.
The proposed changes (submitted under cover letter Serial Number 2607) '
- concern
Appendix A, Technical Specifications (TS):
TS 6.4, Training, TS 6.5.2.8, Audits, l TS 6.10, Record Retention, TS 6.14, Process Control Program, and TS 6.15, Offsite Dose Calculation Manual.
l I, G. G. Campbell, state that (1) I am Vice President - Nuclear of the FirstEnergy Nuclear Operating Company, (2) I am duly authorized to execute and file this certification on behalf of i
the Toledo. Edison Company and The Cleveland Electric Illuminating Company, and (3) the statements set forth herein are true and correct to the best of my knowledge, information and belief
. By: O be G. G t Campbell, Wee-President - Nuclear Affirmed and subscribed before me this 27th day of July,1999.
"YY a Notary Public, State of Ohio - Nora L. Flood My commission expires September 4, 2002.
i 9908030091 990727 "
, .: s Docket Number 50-346 License Number NPF-3 Serial Number 2607 Enclospre 1 Page 2 The following information is provided to support issuance of the requested amendment to the Davis-Besse Nuclear Power Station (DBNPS), Unit Number 1, Operating License NPF-3, Appendix A, Technical Specifications (TS). The amendment request involves changes to (TS) 6.4, Training; TS 6.5.2.8, Audits; TS 6.10, Record Retention; TS 6.14, Process Control Program; and TS 6.15, Offsite Dose Calculation Manual.
A. Time Required to Implement: These changes are to be implemented within 120 days after NRC issuance of the License Amendment.
B. Reason for Change (License Amendment Request 98-0011): This License Amendment Request proposes removing TS 6.4 (Training), relocating TS Section 6.5.2.8 (Audits) and 6.10 (Record Retention) to the DBNPS Updated Safety Analysis Report (USAR)
Chapter 17 Quality Assurance Program, and making related changes to TS 6.14 (Process Control Program) and TS 6.15 (Offsite Dose Calculation Manual). In addition, an editorial correction is proposed to TS 6.8, Procedures and Programs.
These changes are proposed as line item TS improvements similar to the approach provided by the NRC in the improved " Standard Technical Specifications - Babcock and Wilcox Plants,"NUREG-1430, Revision 1, dated April,1995. Additionally, the propo, sed changes to TS 6.5.2.8, TS 6.10, TS 6.14, and TS 6.15 are consistent with the recommendation of NRC Administrative Ixtter 95-06," Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
C. Safety Assessment and Significant Hazards Consideration: (See Attachment).
.. 4 Docket Number 50-346 License Number NPF-3 Serial Number 2607
- Englosure 1 Page1
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SAFETY ASSESSMENT AND SIGNIFICANT HAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST 98-0011 (17 pages follow)
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- i l SAFETY ASSESSMENT AND SIGNIFICANT IIAZARDS CONSIDERATION FOR LICENSE AMENDMENT REQUEST NUMBER 98-0011 TITLE:
Remove Technical Specification (TS) 6.4, Training; Relocate Details of TS 6.5.2.8, Audits, and TS 6.10, Record Retention, to the USAR Quality Assurance Program; and Make Related Changes to TS 6.14, Process Control Program (PCP), and TS 6.15, Offsite Dose Calculation Manual (ODCM)
DESCRIPTION:
This License Amendment Request proposes removing TS 6.4 (Training), relocating TS 6.5.2.8 (Audits) and 6.10 (Record Retention) to the DBNPS Updated Safety Analysis Report (USAR)
Chapter 17 Quality Assurance Program, and making related changes to TS 6.14 (Process Control Program) and TS Section 6.15 (Offsite Dose Calculation Manual). In addition, an editorial correction is proposed to TS 6.8, Procedures and Programs.
These changes are being proposed consistent with NRC guidance on improving the content of TS. These proposed changes are discussed in detail below:
- Remove TS 6.4, Training, which states:
A retraining and replacement training program for the facility staff shall be maintained under the direction of the Manager - Nuclear Training and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1- i 1971 and of 10 CFR 55.59.
- Revise TS 6.5.2.8, Audits, to relocate the detailed listing of the required audits of facility activities to the Quality Assurance Program described in Chapter 17 of the DBNPS USAR. Revised TS 6.5.2.8 would state:
Audits of facility activities shall be performed under the cognizance of the CNRB.
l These audits are described in the USAR Chapter 17 Quality Assurance Program.
- Revise TS 6.10, Record Retention, to relocate the detailed list of the facility records required to be retained to the Quality Assurance Program described in Chapter 17 of the DBNPS USAR. Revised TS 6.10 would state:
Records of facility activities shall be retained as described in the USAR Chapter 17 Quality Assurance Program.
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Revise TS 6.14, Process Control Program (PCP), to reflect the proposed changes to TS 6.10 and reference the relocated records retention requirement contained in the USAR Quality Assurance Program. The revised TS would state, in part:
Changes to the PCP:
- a. Shall be documented and records of reviews performed shall be retained as required by the USAR Chapter 17 Quality Assurance Program.
- Revise TS 6.15, Offsite Dose Calculation Manual (ODCM), to reflect the proposed changes to TS 6.10 and reference the relocated records retention requirement contained in the USAR Quality Assurance Program. The revised TS would state, in j part: '
Changes to the ODCM:
- a. Shall be documented and records of reviews performed shall be retained as required by the USAR Chapter 17 Quality Assurance Program.
- Editorially revise TS 6.8.d to correctly identify the Industrial Security " Plan" (not
" Plant") as requiring implementation procedures.
The above changes are proposed as line-item TS improvements similar to the approach provided by the NRC in the improved " Standard Technical Specifications - Babcock and Wilcox Plants,"
NUREG-1430, Revision 1, dated April,1995. The NRC's " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," dated July 22,1993, recognized the benefit in allowing licensees to improve portions of their TS. This approach results in greater consistency in TS content and allows for the most efficient use of NRC and industry staff resources in processing TS changes. The proposed changes to the DBNPS TS will simplify the TS.
Additionally, the proposed changes to TS 6.5.2.8, TS 6.10, TS 6.14 and TS 6.15 are consistent with NRC Administrative Letter 95-06," Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995, (DBNPS letter Log Number 4661). These are also similar to changes previously approved by the NRC for the Donald C.
Cook Nuclear Plants, Units I and 2, Operating License Numbers DPR-58 and DPR-74, Amendment Numbers 226 and 210, dated December 28,1998 (TAC Numbers M95888 and M95889) and the James A. FitzPatrick Nuclear Power Plant, Operating License Number DPR-59, Amendment 251, dated February 8,1999 (TAC Number MA2131.)
Relocating the detailed listings from TS 6.5.2.8, Audits, and TS 6.10, Record Retention, to the USAR Chapter 17 Quality Assurance Program will be completed no later than the implementation of the NRC-approved License Amendment that allows for their removal from the TS. As described below, future changes to these listings will then be subject to the regulatory controls of !
LAR 98-0011 Page 3 SYSTEMS. COMPONENTS AND ACTIVITIES AFFECTED:
This proposed license amendment is administrative in nature and does not affect any plant systems, structures or components. The proposed license amendment would affect the TS description of: 1) the training requirements of TS 6.4; 2) the audit requirements of TS 6.5.2.8; and 3) the record retention requirements of TS 6.10, TS 6.14.a and TS 6.15.a.
FUNCTIONS OFTHE AFFECTED SYSTEMS, COMPONENTS AND ACTIVITIES:
The overall function of the Operating License, Appendix A, Technical Specifications is to impose those conditions or limitations upon reactor operation necessary to preserve the validity of the results of the USAR design bases accidents. The function of the TS Section 6.0,
" Administrative Controls," as stated in 10 CFR 50.36(c)(5) is to provide provisions relating to organization and management, procedures, record keeping, review, audit, and reporting necessary to assure plant operation in a safe manner.
The function of the present TS 6.4 is to ensure the requirements and recommendations of Section 5.5," Retraining and Replacement Training," in ANSI N18.1-1971," Selection and Training of Nuclear Power Plant Personnel," and 10 CFR 55.59, "Requalification," are met or exceeded by the facility operating staff.
The function of the present TS 6.5.2.8 is to ensure the audit program verifies that the operation of the DBNPS is being performed in a safe manner by auditing activities specified in TS 6.5.2.8.
The function of TS 6.10,6.14.a and 6.15.a is to ensure that records of specific facility activities are retained for specific time durations.
I The functions described in the individual TS are not affected by the proposed changes.
EFFECTS ON SAFETY:
The Nuclear Regulatory Commission's (NRC) regulatory requirements related to the content of TS are set forth in 10 CFR 50.35, 10 CFR 50.36(c)(5) states, in part:
Administrative controls 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.
I The NRC's " Final Policy Statement on Technical Specification Improvements for Nuclear Power l Reactors," dated July 22,1993, provides guidance regarding the required content of TS. The .
fundamental purpose of the TS, as described in the NRC's Final Policy Statement, is to impose those conditions or limitations upon reactor operation necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
This is accomplished by identifying those features that are of controlling importance to nuclear
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LAR 98-0011 Page 4 safety and establishing on them certain conditions of operation which cannot be changed without prior NRC approval.
The NRC's Final Policy Statement recognized, as had previous statements related to the NRC staff's TS Improvement Program, that implementation of the policy would result in the relocation of some existing TS requirements to licensee-controlled documents such as the Updated Safety Analysis Report (USAR).
Further guidance was provided to liciensees in Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995. This Administrative 12tter concluded that TS administrative quality assurance-related requirements may be relocated to licensee-controlled quality assurance programs. The quality assurance program is a logical candidate for such relocations due to the controls imposed by such NRC regulations as Appendix B to 10 CFR Part 50 and the established quality assurance program change control process in 10 CFR 50.54(a). The relocation of Technical Specification requirements in cases where adequate controls are provided by such other methods can reduce the resources expended by licensees and the NRC staff in preparing anu reviewing license 4
amendment requests. J Utilizing the above guidance, the proposed changes to the DBNPS TS Section 6.0, Administrative Controls, remove some quality assurance-related subsections and modify others to generally conform to the improved Standard Technical Specifications (NUREG-1430, I Revision 1) and NRC Administrative 12tter 95-06. The proposed changes are administrative in l nature and do not affect assumptions contained in the plant safety analysis, the physical design, and/or operation of the plant, nor do they affect TS that preserve safety analysis assumptions.
l The functions described in the individual TS are not affected by the proposed changes and will l continue to be performed. Specific discussion on the proposed changes and their effect on nuclear safety follows:
TS 6.4. Traininc:
The proposed change to remove TS 6.4, Training, is consistent with its absence from NUREG-1430, Revision 1. Retraining of the operations staff is required by 10 CFR 55.59, "Requalification," to be implemented and the DBNPS is committed to ANSI N18.1-1971 as described in the USAR Quality Assurance Program.
This change will have no adverse effect on safety because the requalification training program will continue to be controlled by the requirements of 10 CFR 55.59, and the DBNPS commitment to ANSIN18.1-1971 as listed in the existing US AR Chapter 17, Table 17.2-1 (item 12). Any future changes to USAR Chapter 17 are controlled by the requirements of 10 CFR 50.54(a). Furthermore, USAR Section 13.2.1, " Training Program - General," already describes the DBNPS replacement training and requalification training as meeting or exceeding the requirements and recommendations of ANSI N18.1-1971 and 10 CFR Part 55. Any future changes to USAR Section 13.2.1 are subject to the regule.g controls of 10 CFR 50.59. These
LAR 98-0011 Page 5 l
j pre specific regulatory controls that exist outside of the TS and require compliance similar to TS l l 6.4. Therefom, removing t:iis section from the TS will have no adverse effect on nuclear safety, TS 6.5.2.8. Audits:
L l This change proposes that TS 6.5.2.8, Audits, which identifies the audits required to be l performed under the cognizance of the Company Nuclear Review Board (ChRB), be relocated to the US AR Chapter 17 Quality Assurance Program consistent with NRC Administrative letter
! (AL) 95-06 which states, in part:
"The technical specification requirements related to review and audit requirements may be relocated to the quality assurance plan."
This change will have no adverse effect on nuclear safety because the audit function does not need to be centrolled by TS since an equivalent level of regulatory control can be achieved by the Quality Assurance Program pursuant to 10 CFR 50.54(a). The information contained in TS 6.5.2.8 involving audit requirements is described in USAR Sections 13.4.2,17.2.2.5 and 17.2.18.
The requirements of TS 6.5.2.8 will be added in its entirety to the DBNPS USAR Chapter 17 Quality Assurance Program. Future changes to the audit requirements will require an evaluation in accordance with 10 CFR 50.54(a) or 10 CFR 50.59. Audit requirements are also stipulated in 10 CFR Part 50, Appendix B, Criterion XVIII," Audits;" ANSI /ANS 3.2; ANSI N45.2; 10 CFR 50.54(t) (emergency preparedness program review); 10 CFR 50.54(p) (security plan, and guard and training program); and 10 CFR Part 73, " Physical Protection of Plants and Materials."
TS 6.8. Procedures and Programs:
The proposed editorial change to TS 6.8.1.d, " Industrial Security Plant implementation" corrects it to read " Industrial Security Plan implementation" and reflects, the current program being implemented at the DBNPS. This change is editorial and has no adverse effect on nuclear safety.
TS 6.10. Record Retention:
1 This change proposes that TS 6.10, Record Retention, be removed, consistent with NRC Administrative letter (AL) 95-06. NRC AL 95-06 states, in part:
i l "These sections [ Records and Record Retention] may be removed from the technical 1 l specifications and placed in the . quality assurance plan."
l Record retention does not need to be included in the Technical Specifications. An equivalent i level of regulatory control can be achieved by the Quality Assurance Program pursuant to 10 l CFR 50.54(a). Facility records document appropriate station operation and activities. Retention
. of these records provides retrievable documents for review of compliance with requirements and regulations. Post-compliance review of records does not directly assure operation of the facility 4 in a safe manner, as activities described in these documents have already been performed.
LAR 98-0011 Page 6 Recordsretention is described in DBNPS USAR, Section 13.6, Station Records and 17.2. The information contained in TS 6.10, which is relocated by this proposed change, will be added in )
4 its entirety to the DBNPS USAR Chapter 17 Quality Assurance Program and future changes controlled by 10 CFR 50.54(a). Funhermore, record retention is required by the QA Program (10 CFR Part 50, Appendix B, Criteria XVII;) 10 CFR Part 20, Subpart L; 10 CFR 50.71, and ANSI N45.2.9. Therefore, there will be no adverse effect on nuclear safety.
TS 6.14. Process Control Program UCP):
This change proposes revising TS 6.14.a to remove the reference to " Specification 6.10.2.p" (records of reviews performed for changes made to the Process Control Program) and replacing it with a reference to the USAR Chapte.r 17 Quality Assurance Program since TS 6.10, Record Retention, is being removed from the TS as described above. This change is administrative and has no adverse effect on nuclear safety.
TS 6.15. Offsite Dose Calculation Manual (ODCM):
This change proposes revising TS 6.15.a to remove the reference to " Specification 6.10.2.p" (records of reviews performed for changes made to the Offsite Dose Calculation Manual) and replacing it with a reference to the USAR Chapter 17 Quality Assurance Program since TS 6.10, Record Retention, is being removed from the TS as described above. This change is administrative and has no adverse effect on nuclear safety.
FENOC Ouality Assurance Program:
It may be noted that under a separate licensing action request being submitted to the NRC under letter Serial Number 2603 pursuant to 10 CFR 50.54(a), the DBNPS is requesting that the ,
1 DBNPS Quality Assurance Program in USAR Section 17 2 be replaced by the FirstEnergy Nuclear Operating Company (FENOC) Quality Assurance Program Manual (QAPM). The FENOC QAPM is designed to serve as the governing Quality Assurance Program for the nuclear facilities within the FENOC organization. Following NRC approval, the FENOC QAPM will be adopted as the USAR Section 17.2 DBNPS Quality Assurance Program replacing the current QA !
Program. The information being relocated from TS 6.5.2.8 and TS 6.10 will be incorporated in its entirety into the governing DBNPS Quality Assurance Program document, whether it is the current program contained in USAR Section 17.2, or the FENOC QAPM. Therefore, the adoption of the FENOC QAPM will not impact these changes being proposed in this License ;
Amendment Request.
i Summary:
These proposed TS changes do not affect assumptions contained in the DBNPS's safety analyses, the physical design, ar.d/or operation of the plant. These changes will maintain equivalent personnel training, procedures, record retention, review and audit, requirements to assure operation of the DBNPS in a safe manner. The relocated TS will be incorporated into the DBNPS USAR with the same content they possessed ar, part of the Operating License and no
LAR 98-0011 Page 7 tequirements will be eliminated during this transition. Future changes to these relocated administrative processes will be evaluated as required by 10 CFR 50.54(a) or 10 CFR 50.59, as applicable. The proposed changes are administrative in nature and consistent with guidance provided by the NRC. Accordingly, there is no adverse effect on nuclear safety as a result of these changes.
SIGNIFICANT HAZARDS CONSIDERATION:
The Nuclear Regulatory Commission has provided standards in 10 CFR 50.92(c) for determining whether a significant hazard exists due to a proposed amendment to an Operating License for a facility. A proposed amendment involves no significant hazards consideration if operation of the facility in accordance with the proposed changes would: (1) Not involve a significant increase in the probability or consequences of an accident previously evaluated: (2) Not create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Not involve a significant reduction in a margin of safety. The Davis-Besse Nuclear Power Station has reviewed the proposed changes and determined that a significant hazards consideration does not exist because operation of the Davis-Besse Nuclear Power Station, Unit Number 1, in accordance with these changes would:
l a. Not involve a significant increase in the probability of an accident previously evaluated because no accident initiators, conditions or assumptions are affected by the proposed changes to Section 6.0, Administrative Controls, of the Technical Specifications (TS).
The proposed changes to remove Section 6.4, Training, from the TS and relocate the detailed listings of TS Section 6.5.2.8, Audits, and TS Section 6.10, Record Retention, to the DBNPS Quality Assurance Program in Chapter 17 of the Updated Safety Analysis Report are consistent with NUREG-1430," Standard Technical Specifications - Babcock and Wilcox Plants," Revision 1 or NRC Administrative Letter 95-06 " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995. The proposed changes to TS Section 6.14, Process Control Program (PCP); TS Section 6.15, Offsite Dose Calculation Manual (ODCM); and TS Section 6.8, Procedures and Programs, are either associated administratively with the above proposed changes or are editorial corrections. These TS being removed or relocated will remain subject to the controls of regulations (e.g.,10 CFR 50.59,10 CFR 55.59, or 10 CFR 1 50.54(a)).
Ib. Not involve a significant increase in the consequences of an accident previously evaluated because no accident conditions or assumptions are affected by the proposed changes. As described above, these changes are consistent with the improved " Standard Technical Specifications - Babcock and Wilcox Plants" (NUREG-1430) or Administrative Letter 95-06 and are administrative changes. The proposed changes & not alter the source term, containment isolation, or allowable releases. The proposed changes, therefore, will not increase the radiological consequences of a previously evaluated accident.
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- 2. .,Not create the possibility of a new or different kind of accident from any accident previously evaluated because no new accident initiators or assumptions are introduced by the proposed changes, which involve only administrative controls. The proposed changes do not alter any accident scenarios.
- 3. Not involve a significant reduction in a margin of safety because the proposed changes are administrative and do not reduce or adversely affect the capabilities of any plant structures, systems or components to perform their nuclear safety function.
CONCLUSION:
On the basis of the above, the Davis-Besse Nuclear Power Station has determined that this License Amendment Request does not involve a significant hazards consideration. As this License Amendment Request concems a proposed change to the Technical Specifications that must be reviewed by the Nuclear Regulatory Commission, this License Amendment Request does not constitute an unreviewed safety question.
ATTACHMENT:
Attached are the proposed mark-up changes to the Operating License.
REFERENCES:
- 1. NUREG-1430, Revision 1, " Standard Technical Specifications - Babcock and Wilcox Plants," dated April 1995.
- 2. NRC " Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors,' *8 FR 39132, dated July 22,1993).
- 3. 10 CFR 50.36," Technical Specifications."
- 4. 10 CFR Part 50, Appendix B," Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants."
- 5. 10 CFR 50.54," Conditions of Licenses."
- 6. 10 CFR 50.71," Maintenance of Records, Making of Reports."
- 7. 10 CFR 55.59, "Requalification."
- 9. DBNPS Operating License, Appendix A Technical Specifications, through Amendment 232.
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- 10. ANSI N18.1-1971, " Selection and Training of the Nuclear Power Plant Personnel."
- 11. ANSI /ANS 3.2-1982," Administrative Controls and Quality Assurance for the Operaticnal Phase of Nuclear Power Plants."
- 12. ANSI N45.2-1977, " Quality Assurance Program Requirements for Nuclear Facilities."
- 13. ANSI N45.2.9-1974, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants."
- 14. NRC Administrative Letter 95-06," Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995 (DBNPS letterIog Number 4661).
- 15. Regulatory Guide 1.33," Quality Assurance Program Requirements (Operation),"
November,1972.
- 16. Donald C. Cook Nuclear Plants, Units 1 and 2, Operating License Numbers DPR-58 and DPR-74, Amendment Numbers 226 and 210, dated December 28,1998 (TAC Numbers M95888 and M95889.)
- 17. James A. FitzPatrick Nuclear Power Plant, Operating License Number DPR-59, Amendment 251, dated February 8,1999 (TAC Number MA2131.)
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