ML20236K391
| ML20236K391 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 07/06/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20236K394 | List: |
| References | |
| NUDOCS 9807090304 | |
| Download: ML20236K391 (7) | |
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION WASHINGTON, D.c. 30006 4001 lJ SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION AMENDMENT 23 OF THE QUALITY ASSURANCE (QA) PROGRAM TOPICAL REPORT DUKE ENERGY CORPORATION CATAWBA NUCLEAR STATION. UNITS 1 AND 2 l
DOCKET NOS. 50-413 AND 50-414
1.0 INTRODUCTION
By letter dated May 27,1997, Duke Energy Corporation (DEC/the licensee) submitted
- proposed license amendments (Reference 1) to convert the current Technical Specifications (TS) for the Catawba Nuclear Station, Units 1 and 2, to be consistent with the Improved.
Standard TS (ISTS) for Westinghouse nuclear plants (NUREG-1431) (Reference 2).
Consistent with the Commission's Final Policy Statement on Technical Specifications improvements for Power Reactors (Reference 3), many current TS requirements have been transferred from control by TS to control by other mechanisms (e.g., the licensee's l
NP" 9pproved quality assurance (QA) program). In support of the proposed amendments, the lics.isee has submitted Amendment 23 to the DEC Topical Report, Duke-1-A, Quality Assurance Program (References 4 and 5), which incorporates the relocated current TS requiremer.ts. This safety evaluation reviews the appropriateness and completeness of the
. current TS requirements that have been relocated to the licensee's QA program
2.0 BACKGROUND
Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TS as part of the license. The Commission's regulatory requirements related to the content of TS are set forth in Title 10 of the Code of Federal Regulations (10 CFR) Section 50.3E. That regulation requires that the TS include items in five specific categories: (1) safety liraits, limiting safety system settings, and limiting control settings; (2)
. limiting conditions for opeation (LCO); (3) surveillance requirements; (4) design features; and (5) administrative controls. Se regulation, however, does not specify particular items to be included in the plant TS.
i Section 50.36(c)(2) provides, with respect to LCOs, four criteria to be used in determining whether particular items are required to be included in the TS. While the four criteria apply l
specifically to LCOs, in adopting the revision to the rule (Section 50.36. Reference 6), the
. Commission indicated that the intent of these criteria can be used to identify the optimum set of TS administrative controls.
9807090304 900706 DR ADOCK 05000413 p
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. i Addressing administrative controls,10 CFR 50.36(c)(5) states that they *are the provisions l
relating to organization and management, procedures, recordkeeping, review and audit, and j
reporting necessary to assure safe operation of the facility in a safe manner." The particular administrative controls to be included in the TS, therefore, are the provisions that the Commission deems essential for the safe operation of the facility that are not already covered l
by other regulations.
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Accordingly, the staff has determined that administrative control requirements that are not specifically required under Section 50.36(c)(5), and that are not otherwise necessary to obviate the possibility of an abnormal situation or an event giving rise to an immediate threat to the public hee!th and safety, may be relocated to more appropriate documents (e.g., Security Plan, l
Quality Assurance Program (QAP), Emergency Plan), which are subject to regulatory controls.
Sirnilarly, while the required content of TS administrative controls is specified in 10 CFR 1
50.36(c)(5), particular details may be relocated to licensee-controlled documents where i
Sections 50.54, 50.59, or other regulations provide adequate regulatory control.
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NRC Administrative Letter (AL) 95-06 (Reference 7) provides guidance to licensees proposing amendments that relocate administrative controls to NRC-approved QAP descriptions, where subsequent changes are controlled by the established QAP change control process in 10 CFR l
50.54(a). AL 95-06 provides specific guidance in the areas of; (1) independent safety engineering group; (2) reviews and audits; (3) procedure review process; and (4) records and record retention. While AL 95-06 guidance is limited to these areas, the QAP may provide a reasonable choice for relocating other TS administrative cor, trol requirements that do not satisfy the intent of the criteria for TS inclusion, as discussed ;,reviously. The appropriateness of relocating other administrative controls from the TS to the QAP is evaluated on a case-by-case basis.
3.0 EVALUATION The licensee proposes to relocate certain administrative control requirements from the TS to its NRC-approved QAP description (Reference 8). The proposed relocated requirements are l
contained in Amendment 23 to the licensee's QA topical report (References 4 and 5), submitted i
as a nonreduction in commitment, pursuant to Section 50.71(e), in support of the proposed improved TS amendments. Information conceming the items to be relocated from the current TS to the QA topical report is contained in Attachment 2 of Reference 4; marked pages from the STS conversion packages, previously submitted (Reference 1), are included as. The scope of the staff's evaluation !:;;mited to the review of the appropriateness and completeness of the relocated requirements and does not address the adequacy of the QA topical report.
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.- 3.1 Safety Review Group 3.1.1 Relocation (item 61):' TS 6.2.3.1 through TS 6.2.3.4 to QAP Section 17.3.3.2.4 (Safety 1
Assessment) i Relocated Requirements: The Safety Review Group satisfies the independent safety engineering (ISE) orovisions of NUREG-0737 (Reference 9).
Evaluation: Safety Review Group function, responsibilities, and authority, as specified in the cu. Tent TS (Raference 1), have been relocated to the QAP. Safety Review Group
- composition, as revised by license amendments (Reference 11) issued subsequent to
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l submittal of Reference 1, has also been relocated to the QAP. Relocation intact of these l
requit Tients to the QAP, where subsequent changes would be controlled pursuant to 1
10 CM 50.54(a), is in accordance with the guidance of AL 95-06.
3.1.2 Relocation (itein 62): TS 6.2.3.5 to QAP Section 17.3.2.15 (Records)
Relocated Requirement: Safety Review Group records.
Evaluation: The requirement that these records be maintained has been_ relocated to QAP Section 17.3.2.15 (the requirement that monthly summary reports of activities be provided to the Manager of Safety Assurance has been relocated to QAP 1
Section 17.3.3.2.4). Relocation intact of these requirements to the QAP, where subsequent changes would be controlled pursuant to 10 CFR 50.54(a), is in accordance with the guidance of AL 95-06.
3.2 Technical Rcview and Control 3.2.1 Relocation (ltems 63,64,66,67,72,73): TS 6.5.1, TS 6.5.1.1, TS 6.5.1.3, TS 6.5.1.4, TS 6.5.1.9, TS 6.5.1.10 to QAP Section 17.3.2.14 (Document Control)
Relocated Requirements:
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Program establishment Preparation and review of station procedures (TS 6.5.1.1)
Individuals responsible for procedure review (TS 6.5.1.3)
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Preparation and review of proposed TS changes (TS 6.5.1.4)
Review of changes to the Process Control Program, Offsite Dose Calculation Manual, and Radwaste System (TS 6.5.1.9)
Review of the Fire Protection Program and implementing procedures (TS 6.5.1.10) i 3.2.2 Relocation (item 65): TS 6.5.1.2 to QAP Section 17.3.2.2 (Design Control)
' ltem numbers correspond to those used in Attachment 2 of the licensee's submittal (Reference 4).
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! Relocated Requirement: Review of proposed modifications.
3.2.3 Relocation (Item 68): TS 6.5.1.5 to QAP Section 17.3.2.10 (Inspection, Test, and Operating Status)
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i Relocated Requirement: Review of proposed tests and experiments.
l 3.2.4 Relocation (Items 69,70,71): TS 6.5.1.6, TS 6.5.1.7, TS 6.5.1.8 to QAP Section 17.3.2.13 (Corrective Action)
Relocated Requirements:
l Investigation of violations of TS, safety limit violations, and all other reportable l
l events (TS 6.5.1.6)
Performance of special reviews and investigations (TS 6.5.1.7)
Review and reporting of unplanned onsite release of radioactive material (TS 6.5.1.8) 3.'2.5 Relocation (item 74): TS 6.5.1.11 to QAP Section 17.3.2.15 (Records) l Relocated Requirement: Station records documenting activities performed under TS 6.5.1 through TS 6.5.10 shall be maintained.
Evaluation: Relocation intact of the requirements for procedure review (Items 63,64,66,67,72 and 73), review (Items 65 and 68) and records (Item 74) to the QAP, where subsequent changes would be controlled pursuant to 10 CFR 50.54(a), is in accordance with the guidance l
of AL 95-06.
Conceming the requirements for the performance and reporting of investigations (ltems 69,70, l
and 71), these administrative control requirements do not satisfy the intent of the criteria for TS inclusion (see Section 2) and are, therefore, candidates for relocation. Relocation intact of these requirements to the QAP description of the licensee's corrective action program is i
appropriate. Subsequent changes to these requirements would be controlled through the established QAP change control process in 10 CFR 50.54(a).
3.3 Nuclear Safety Review Board (NSRB) 3.3.1 Relocation (Items 75,77, and 78): TS 6.5.2.1 through TS 6.5.2.8, TS 6.5.2.10a,b to QAP Section 17.3.3.2.1 (NSRB)
Relocated Requirements: The NSRB satisfies the independent review provisions described in N18.7-1976/ANS-3.2 (Reference 10).
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3.3.2 Relocation (Items 76,79): TS 6.5.2.9 and TS 6.5.2.10c to QAP Section 17.3.3.2.3 l
(Intemal Audits) l 1
Relocated Requirements: Audits performed under the cognizance of the NSRB.
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Evaluation: The NSRB organization is already described in the licensee's approved QAP description'(Reference 8). Relocation intact of the NSRB review, records, and audit requirements to the QAP, where subsequent changes would be controlled pursuant to 10 CFR 50.54(a), is in accordance with the guidance of AL 95-06.
3.4 Reportable Events Relocation (item 80): TS 6.6.1b to QAP Section 17.3.2.13 (Corrective Action)
Relocated Requirement: Particular current TS details related to the licensee's intemal review process have been relocated to the QAP.
Evaluation: Relocation intact of this review requirement to the QAP, where subsequent changes would be controlled pursuant to 10 CFR 50.54(a), is in accordance with the guidance of AL 95-06.
3.5 Safetv Limit Violation Relocation (item 81): TS 6.7.1b to QAP Section 17.3.2.13 (Corrective Action)
Relocated Requirements: Safety limit violations are addressed by the Standard Technical l
Specifications, Chapter 2.2 (Reference 2). Subsequent deletion of the STS requirements for notification, reporting, and reactor restart have been approved by the NRC (Reference 12) on the basis that they are adequately addressed by existing regulations (Sections 50.36,50.72, and 50.73). Particular current TS details related to the licensee's intemal notification and review process have been relocated to the QAP.
Evaluation: These administrative requirements do not satisfy the intent of the criteria for TS
-inclusion and are, therefore, candidates for relocation. Relocation of these requirements to the QAP description of the licensee's corrective action program is appropriate. Subsequent changes to these requirements would be controlled through the established QAP change control process in 10 CFR 50.54(a).
3.6 Station Ooeratina Procedures
~ Relocation (items 82, 83, 84, 85, 86): TS 6.8.1e, h, J, TS 6.8.2, TS 6.8.3 to QAP Section 17.3.2.14 (Document Control)
Relocated Requirements:
Program implementation procedures for (1) Process Control Program; (2) Technical Review and Control Program; (3) Plant Operations Review Committee (TS 6.8.1e, h, j),
Review and approval of procedures (TS 6.8.2), and
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Temporary changes to procedures (TS 6.8.3).
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.. Evaluation: Relocation intact of these procedure review requirements to the QAP, where s
subsequent changes to these provisions would be controlled pursuant to 10 CFR 50.54(a), is in
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accordance with the guidance of AL 95-06.
i 3.7 Station Ooeratino Records Relocation (Items 87,88,89): TS 6.10 to QAP Section 17.3.2.15 (Records)
Relocated Requirements: Station records Evaluation: The QAP list of station records has been updated as necessary to include the records previously listed in the current TS. Retention times for quality assurance records are in accordance with corporate retention policies, which reflect industry codes and standards and regulatory requirements. The licensee's program for collection, storage, and maintenance of QA records conforms to Regulatory Guide 1.88 (Reference 13), with the NRC-approved alternative to the ANSI Standard N45.2.9 fire protection provisions, as described in Table 17-1
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of the QAP. Subsequent changes to these requirements would be controlled through the l
established QAP change control process in 10 CFR 60.54(a).
4.0 CONCLUSION
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The staff finds the proposed relocation of the TS administrative control requirements to the licensee's QAP to be acceptable. Subsequent changes to these requirements will be controlled through the established QAP change control process in 10 CFR 50.54(a).
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5.0 REFERENCES
'1.
Duke letter (M. S. Tuckman) to the USNRC, " Catawba Nuclear Station, Convusion to the improved Technical Specifications," May 27,1997.
2.
NUREG-1431, " Standard Technical Specifications, Westinghouse Plants," Revision 1, April 1995.
3.
Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, July 22,1993 (58 FR 39132).
4.
Duke letter (M. S. Tuckman) to the USNRC, " Duke Energy Corporation Nuclear Quality Assurance Plan, Amendment 23," April 8,1998.
5.
Duke letter (M. S. Tuckman) to the USNRC, " Duke Energy Corporation Nuclear Quality l
Assurance Plan, Supplement to Amendment 23," May 25,1998.
6.
Technical Specifications, July 19,1995 (60 FR 36957).
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Administrative Letter 95-06, " Relocation of Technical Specifications Administrative Controls Related to Quality Assurance," December 12,1995.
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" Duke Energy Corporation Nuclear Quality Assurance Program, Amendment 21,"
submitted by Duke letter dated June 6,1997, subsequently revised by letter dated August 13,1997.
9.
NUREG-0737, Supplement 3, l.B.1.2, " Clarification of TMI Action Plan Requirements,"
" Independent Safety Engineering Group," October 1980.
i 10.
ANSI N18.7-1976, Section 4.3, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," " Independent Review Program,"
February 19,1976.
11.
NRC letter (P. S. Tam) to Duke Energy Corporation (G. R. Peterson), ' issuance of Amendments - Catawba Nuclear Station, Units 1 and 2," April 27,1998.
12.
NUREG-1431, Rev 2, Technical Specification Task Force Proposed Change to the Standard Specifications TSTF-05, approved by the NRC on September 5,1995.
13.
Regulatory Guide 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance P.ecords, Revision 2, October 1976.
l Principal Contributor. K. Heck
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Dated:
July 6,1998 l
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