ML20210U088
| ML20210U088 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/13/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20210U084 | List: |
| References | |
| AL-95-06, NUDOCS 9908190228 | |
| Download: ML20210U088 (5) | |
Text
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@M y-t UNITED STAT 9S g,.
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NUCLEAR REGULATORY COMMISSION Ty(f C WASHINGTON, D.C. 2055A001 o.
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 239 AND 173 TO FACILITY OPERATING LICENSE NOS. DPR-65 AND NPF-49 NORTHEAST NUCLEAR ENERGY COMPANY. ET AL.
MILLSTONE NUCLEAR POWER STATION, UNIT NOS. 2 AND 3 DOCKET NOS. 50-336 AND 50-423
1.0 INTRODUCTION
By letter dated March 5,1999, the Northeast Nuclear Energy Company, et al. (the licensee),
submitted a request for changes to the Millstone Nuclear Power Station, Unit Nos. 2 and 3 Technical Specifications (TSs). The requested changes would relocate certain TS Section 6.0 administrative controls to the NRC-approved Northeast Utilities Quality Assurance Program (NUQAP) Topical Report in accordance with NRC Administrative Letter (AL) 95-06, " Relocation of Technical Specifications Administrative Controls Related to Quality Assurance," dated December 12,1995. Specifically, Sections 6.2.3, independent Safety Engineering Group (Unit 3 only); 6.5, Review and Audit; 6.6, Reportable Event Action (partial); 6.7, Safety Limit Violation (partial); and 6.10, Record Retention. The amendments would also delete parts of Section 6.6 and 6.7 because their requirements are duplicated in existing regulations or elsewhere in the TSs. In addition, the amendment would modify the table of contents and other TS sections to incorporate the aforementioned changes (e.g., correct references).
2.0 EVALUATION l
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The Commission's regulatory I
requirements related to the content of TSs are set forth in 10 CFR 50.36. That regulation requires that the TSs include items in specific categories, including: (1) safety limits, limiting l
safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.
With respect to limiting conditions for operations (LCOs),10 CFR 50.36 provides four criteria to be used in determining whether particular safety functions are required to be included in the TSs. 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). Addressing administrative controls,10 CFR 50.36 states that they "are the provisions 9908190228 990813 PDR ADOCK 05000336 1
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relating to organization and management, procedures, record keeping, 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 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 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, QA Plan, and the Emergency Plan) and controlled by the applicable regulatory requirement.
Similarly, while the required content of the TSs administrative controls is specified in 10 CFR 50.36(c)(5), particular details of administrative controls may be relocated to licensee-controlled documents where 10 CFR 50.54,10 CFR 50.59, or other regulations provide adequate regulatory control.
2.1 Independent Safety Engineering Group The proposed amendment would relocate the Independent Safety Engineering Group (ISEG) functions specified in the existing TS Section 6.2.3 for Millstone Unit 3 only to the NUQAP Topical Report. ISEG functions, responsibilities, and authority, as specified in TS Section 6.2.3, have been relocated intact to Appendix F of the NUQAP Topical Report.
Changes to the NUQAP Topical Report are controlled in accordance with 10 CFR 50.54(a) and include requirements for prior NRC review and approvalif a change constitutes a reduction in the NUQAP Topical Report commitment. The staff finds it is not necessary to include redundant or additional requirements in the TSs Administrative Controls section. Therefore, the staff finds that the relocation of the ISEG function from the Millstone Unit 3 TS Section 6.2.3 to the NUQAP Topical Report is consistent with the guidance provided in AL 95-06 and is acceptable.
2.2 Review and Audit The proposed amendment would relocate the review and audit function specified in existing TS Section 6.5 to the NUQAP Topical Report. The requirements as currently delineated in Section 6.5 of the TSs have been relocated essentially intact (only minor editolial changes were made that do not impact the requirements) to Appendix F of the NUQAP Topical Report.
Changes to the NUQAP Topical Report are controlled in accordance with 10 CFR 50.54(a) and include requirements for prior NRC review and approvalif a change constitutes a reduction in the NUQAP Topical Report commitment. Therefore, the staff finds that the relocation of the Review and Audit functions from Section 6.5 of the TS to the NUQAP Topical Report is consistent with the guidance provided in AL 95-06 and is acceptable.
2.3 Record Retention The licensee proposed to relocate the record retention requirements in Section 6.10 of the TS to the NUQAP Topical Report. All the existing TS requirements from Section 6.10 have been relocated essentially intact (only minor editorial changes were made that do not impact the requirements) to Appendix F of the NUQAP Topical Report.
n The staff finds that the regulatory requirements of 10 CFR Part 50, Appendix B provide sufficient control of plant records and sufficient regulatory controls for future changes to the NUQAP Topical Report pursuant to 10 CFR 50.54(a). In addition, other regulations such as 10 CFR 20, Subpart L and 10 CFR 50.71 require the retention of records related to operation of the nuclear power plant. The requirements in the NUQAP Topical Report clong with the other regulatory requirements provide sufficient control of record keeping provisions. Therefore, the staff finds the relocation of the Record Retention requirements from Section 6.10 to the NUQAP Topical Report is consistent with the guidance provided in AL 95-06 and is acceptable.
2.4 Other Changes to the Technical Specifications The licensee proposed other changes to the TSs to: (1) address requirements that are duplicated elsewhere within the TSs, in existing regulations, or portions of which have been relocated to the NUQAP Topical Report, and (2) to correct references to be consistent with the relocation of the administrative requirements to the NUQAP Topical Report.
For Unit 2 only, these changes include:
- 1. In specification 4.6.1.6.4, the licensee changed the reference to " Specification 6.6.1" to "Section 50.73 to 10 CFR Part 50." Specification 6.6.1 was deleted as discussed below.
- 2. In specification 4.7.8.g, the licensee changed the reference to " Specification 6.10.2.h" to
" Quality Assurance Program Topical Report," for consistency with thdrelocation of specification 6.10 requirements to the NUQAP Topical Report.
For Unit 3 only, these changes include:
- 1. In specification 2.1.1, the licensee deleted "and comply with the requirements of Specification 6.7.1,"in three locations. Specification 6.7.1 was deleted as discussed below.
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- 2. In specification 4.3.4.2, the licensee changed the reference to " Specification 6.5.1.6.j" to "the Quality Assurance Program Topical Report," for consistency with the relocation of specification 6.5 requirements to the NUQAP Topical Report.
- 3. In specification 4.7.10.i, the licensee changed the reference to " Specification 6.10.3" to "the Quality Assurance Program Topical Report," for consistency with the relocation of specification 6.10 requirements to the NUQAP Topical Report.
Changes applicable to both Units 2 and 3 include:
- 1. The licensee deleted specification 6.6," Reportable Event Action." Specification 6.6.1 referenced 10 CFR 50.73 for report requirements. Specification 6.6.1.a was deleted since it duplicated the NRC's requirement for the licensee to adhere to 10 CFR 50.73. Specification 6.6.1.b was deleted since it duplicated the requirements in Specifications 6.5.1.6.f and 6.5.1.8 that were relocated intact to the NUQAP Topical Report.
- 2. The licensee deleted specification 6.7, " Safety Limit Violation." Specification 6.7.1.a duplicates requirements in specification 2.1.1. Specification 6.7.1.b, in part, duplicates requirements of 10 CFR 50.36 and 10 CFR 50.72, with the remaining internal licensee notification requirements relocated intact to the NUQAP Topical Report. Specification
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' 6.7.1.c duplicates requirements of 10 CFR 50.36 and 10 CFR 50.73, or specification 6.5.1.6.f that was relocated to the NUQAP Topical Report. Specification 6.7.1.d was relocated intact to the NUQAP Topical Report. Specification 6.7.1.e duplicates the requirements of 10 CFR 50.36.
- 3. The licensee changed specification 6.8, " Procedures," to reflect that the review and approval of procedures or changes thereto, are conducted in accordance with the requirements of the NUQAP Topical Report for consistency with the relocation of specifications 6.5 requirements.
- 4. The licensee changed specification 6.15 (Unit 2) and 6.13 (Unit 3), " Radiological Effluent Monitoring and Offsite Dose Calculation Manual (REMODCM)," to reflect that the review and approval of changes to the REMODCM and record retention, are conducted in accordance with the requirements of the NUQAP Topical Report for consistency with the relocation of specifications 6.5 and 6.10 requirements.
The staff has reviewed the changes discussed in 2.4 above and determined that these requirements are adequately covered by other regulations, were duplicated in other sections of the TSs, or were appropriately relocated to Appendix F of the NUQAP Topical Report.
Changes to the NUQAP Topical Report are controlled in accordance with 10 CFR 50.54(a) and include requirements for prior NRC review and approval if a change constitutes a reduction in the NUQAP Topical Report commitment. The staff finds it is not necessary to include redundant or additional requirements in the TSs Administrative Controls section. Therefore, the staff finds that the TS changes discussed in 2.4 above are acceptable.
3.0
SUMMARY
The staff has evaluated the licensee's proposal related to the revision of the TSs administrative controls associated with sections 6.2.3, independent Safety Engineering Group (Unit 3 only);
6.5, Review and Audit; 6.6, Reportable Event Action (partial); 6.7, Safety Limit Violation (partial); 6.10, Record Retention; and the table of contents and other TS sections to incorporate the aforementioned changes (e.g., correct references). Based on the above evaluation, the staff concludes that: (1) the proposed QA-related administrative control provisions, as relocated from the current TSs to the NUQAP Topical Report constitute the bases for the licensee's continued compliance with the requirements of Appendix B to 10 CFR Part 50, and (2) the TS sections being relocated to the NUQAP Topical Report are not required to be retained in the TSs pursuant to 10 CFR 50.36. In addition, the staff has reviewed the NUQAP Topical Report and confirmed that the TS Sections have been relocated appropriately. Therefore, the staff finds the proposed changes to the TSs to be acceptable.
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Connecticut State official was notified of the proposed issuance of the amendment. The State official had no comments.
5.0 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 su veillance requirements. The NRC staff has determined that the amendment involves no
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5 significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (64 FR 17027). 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 prepared in connection with the issuance of the amendment.
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6.0 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 in 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: John A. Nakoski Date: August 13, 1999 i
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