ML20212J003
| ML20212J003 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/23/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20212H983 | List: |
| References | |
| NUDOCS 9906280271 | |
| Download: ML20212J003 (5) | |
Text
i ga taggk UNITED STATES
_ p NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 30056 0001
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' AAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 112 AND 99 TO y.
FACILITY OPERATING LICENSE NOS. NPF-76 AND NPF-80
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STP NUCLEAR OPERATING COMPANY. ET AL.
SOUTH TEXAS PROJECT. UNITS 1 AND 2 DOCKET NOS. 50-498 AND 50-499 -
1.0 INTRODUCTION
l By application dated March 9,1999, STP Nuclear Operating Company (the licensee) requested changes to the South Texas Project, Units 1 and 2, (STP) Technical Specifications (TSs). The proposed changes would remove the independent safety engineering group (ISEG) requirements from the TSs and the associated reference to the ISEG in Se STP Operations Quality Assurance Plan (OQAP). The ISEG requirements proposed to be withdrawn from the TSs are the function, composition, responsibilities, and records of the ISEG in Section 6.2.3, Administrative Controls, of the TSs.
- A conference call to discuss this submittal with the licensee was held on April 7,1999. Based on this call, by letter dated May 3,1999, the licensee revised its submittal to relocate the ISEG commitments, as modified and applied to other organizations, to the OOAP. The revised amendment request proposes to remove the requirement to have an ISEG from the TSs with
- relocation of the substantive requirements applicable to the ISEG to the OOAP as applied in the
' form of an independent technical review program. The functions now performed by the ISEG
("lSEG functions") would thus be performed by other organizations. The current TS requirements applicable to the ISEG that are proposed to be relocated, as modified, to the OQAP are shown in the attachment to the licensee's May 3,1999, letter. Relocation of the ISEG quality assurance-related requirements from the TSs to the OOAP is consistent with the
_ processes described in the staff's Administrative Letter (AL) 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
I The licensee's letter of May 3,1999, provided additional clarifying information within the scope of the original Federal Reaister notice and did not change the staff's initial propcsed no significant hazards consideration determination.'
2.0 JD/ALUATION
. 2.1 Discussion Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state the TSs to be included as part of the license. The Commission's 91il P
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p4 2-regulatory requirements related to the content of the TSs are set forth in 10 CFR 50.36,
" Technical Specifications," which requires that the TSs include items in five specific categories, one of which is administrative controls (it is the administrative controls category that applies to the proposed amendments). However, the regulation does not specify the particular requirements to be included in a plant's TSs.
j For administrative controls,10 CFR 50.36 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 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 regulatory requirements. Accordingly, the staff has determined that requirements that are not specifically mandated 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 from administrative controls. Therefore, some existing TS 1
requirements may be relocated to more appropriate documents, in this case the OQAP, and controlled by the applicable provisions of 10 CFR 50.54(a).
By letter dated December 12,1995, the staff issued AL 95-06, which 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 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.
Several observations in order to assist those licensees considering amendment requests related to relocation of TS ISEG requirements to the OOAP were included.
2.2 Evaluation The licensee proposed to relocate administrative controls related to ISEG to the OOAP description. Specifically, while there would no longer be a specific ISEG organization, the licensee proposed to remove the substantive ISEG commitments in TS 6.2.3 and relocate them, as applied to other_ organizations, to a new OQAP Chapter 16, Independent Technical Review. AL 95-06 discusses the relocation of TS ISEG requirements that the staff finds 4
acceptable. Relocation of this requirement to the OQAP was found acceptable. In addition, changes during this relocation were found acceptable as long as the OOAP contains a y
commitment related to the functions of ISEG, as applied to other organizations, to a level of
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detail comparable to that previously contained in the TSs.
l The staff has reviewed the relocation of the TS ISEG commitments to the independent
.3chnical review program of a new Chapter 16 to the OQAP. The commitments, as applied to other organizations, have been relocated as follows:
The TS commitment regarding ar is that ISEG examines is covered by OQAP e
' Chapter 16, Section 6.3.
j The TS commitment regarding making and reporting recommendations is covered by OOAP Chapter 16, Sections 6.6,6.7, and 7.0.
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3-The TS commitment regarding ensuring activities are performed correctly and that human errors are reduced as much as practical is covered by OOAP Chapter 16, Section 6.2. '
The TS commitment to have an independent ISEG group consisting of five dedicated e
full time engineers was eliminated in this relocation based on other commitments contained in the independent technical review chapter description. These include commitments regarding independence of reviewers, their qualification, and designation of responsibility for the program. The independence of personnel performing the independent technical reviews (the current ISEG functions) is covered by Chapter 16, Section 6.5, which specifically states that " Personnel performing independent technical reviews should be independent of performance function, signoff function, and the plant management chain while p.erforming this oversight activity." A different number of individuals with varied qualifications may be involved in the independent technical review program than were in the ISEG organization described in the TSs. However, Section 6.4 of OOAP Chapter 16 still requires that at least several personnel performing these reviews, as determined by quality assurance management, will have qualifications ec,ualing that previously required by the TSs for ISEG members. In addition, the Director, Quality & Licensing, is responsible for ensuring all the independent technical review commitments of Chapter 16 of the OOAP are accomplished. Having this responsibility specifically assigned helps alleviate the potential for loss of focus by not having a dedicated full-time ISEG organization. The independence of the quality assurance organization itself and its ability to report directly to the chief executive officer also helps maintain the independent nature of the ISEG functicas now contained in the OOAP independent technical review program.
2.3 Conclusion The staff has determined that the revised OQAP contains commitments related to the functions of the ISEG (proposed to be performed by other organizations) to a level of detail comparable to that contained in the TSs. Changes to the OOAP are controlled in accordance with 10 CFA 50.54(a) and include requirements for prior NRC review and approvalif a change constitutes a reduction in an OOAP commitment. The staff concludes that this regulatory requirement provides sufficient control for the ISEG functions as described in the independent technical review chapter of the OOAP.
The relocated requirements relating to ISEG administrative controls are not required to be in the TSs to meet the requirements under 10 CFR 50.36 or the Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety. The staff also finds that a comparable level of detail for commitments to ISEG functions is contained in the independent technical review chapter added to the OQAP concurrent with this amendment. The licensee stated in its letter of May 3,1999, that these changes to the OOAP will become efferive upon approval of the amendments. In addition, sufficient regulatory controls for this commitment exist under 10 CFR 50.54(a). Accordingly, the staff has concluded that these requirements may be relocated, as applied to other organizations, from the TSs to the OQAP.
Based on this, the staff concludes that the proposed amendments are acceptable.
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3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Texas State official was notified of the proposed issuance of the amendments. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendments change recordkeeping, reporting, or administrative procedures and requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51,22(c)(10). Pursuant to 10 CFR 51.22(b), no environmentalimpact statement or environmental ascessment need be prepared in connection with the issuance of the amendments.
5.0 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: R. J. Smith, Jr.
- Date: June 23, 1999 i
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DATED: June 23, 1999 AMENDMENT NO. 112 TO FACILITY OPERATING LICENSE NO. NPF STP UNIT 1 AMENDMENT NO. 99 TO FACILITY OPERATING LICENSE NO. NPF STP UNIT 2 iDocket File (50-46499)
PUBLIC -
PDIV-1 RF S. Richards (cover ltr only)
T. Alexion -
C. Jamerson G. Hill (4)
W. Beckner K. Brockman,RIV J. Hurley, RIV J. Kilcrease, RIV R. Scholl (e-mail SE)
R. J. Smith, Jr.
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