ML20247L460
| ML20247L460 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/24/1989 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20247L458 | List: |
| References | |
| GL-86-10, GL-88-06, GL-88-12, GL-88-6, NUDOCS 8908010254 | |
| Download: ML20247L460 (6) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 79 TO FACILITY OPERATING LICENSE NO. NPF-12 SOUTH CAROLINA ELECTRIC & GAS COMPANY SOUTH CAROLINA PUBLIC SERVICE AUTHORITY VIRGIL C. SUMMER NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-395
1.0 INTRODUCTION
This Safety Evaluation (SE) is divided into two parts. The first part addresses the portion of the amendment dealing with the deletion of the existing Technical Specifications (TS) on fire protection and the modification to the License Condition 2.C.(18). The second part addresses that portion of the amendment associated with the removal of the organiza-tional charts from the TS and various changes to titles in the Administra-tive Controls tection of the TS.
1.1 Fire Protection By letter dated March 31, 1987, South Carolina Electric & Gas Company, the licensee, requested an amendment to the Virgil C. Summer Nuclear Station TS.
In this request, the licensee proposed to remove all fire protection requirements from the Technical Specifications.
In addition, it was proposed that TS 6.5.1.6, Plant Safety Review Committee (PSRC) Responsibilities, be revised to include the fire protection program and its revisions.
Finally, it was proposed that a requirement be added to License Condition 2.C.(18) that would allow the licensee to make changes to the fire protection program only if the changes did not adversely affect the capability of the plant to achieve and maintain safe shutdown in the event of a fire. These changes were proposed as a result of the issuance of NRC Generic Letter 86-10, "Implementat',on of Fire Protection Requirements," and were noticeo in the Federif Register on July 29, 1987 (52 FR 28388).
On November 9, 1987 the sfatt provided comments on License Condition 2.C.(18) and on December 21, 1987 the licensee modified their proposed wording of the License Condition. A re-notice was issued in the Federal Register on Feb"uary 24, 1988 4
(53 FR 5496). On August 2, 1988 GL 68-12 "Remova7 of Fire Protection i
Requirements from Technical Specifications", was issued for the purpose of providing guidance for the preparation of a license amendment request to implement GL 86-10. The licensee made a submittal on January 31, 1969 in which they committed to incorporating the Fire Protection Evaluation Report (FPER) into Chapter 9 of the Final Safety Analysis Report (FSAR).
In addition, the licensee committed to retaining the existing Surveillance Test Procedures associated with the fire protection TS and converting them to the Preventative / Fire Test Procedures. The licensee 8908010254 890724 PDR ADOCK 05000395 P
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connitted to taking the limiting conditions for operation in the. TS and the remedial. action portions-of these sections of the fire protection TS, which were being removed from TS,-and placing them into an existing Station Administrative Procedure. The licensee also committed to having a level cf protection-equal to that currently existing in the TS.. This submittal did not affect the TS changes previously submitted nor the proposed change:
tothe.licensecondition2.C.(18).
11.2 Organization Charts By letter dated July 6,1987, South Carolina Electric & Gas Company (the licensee) submitted a re Station, Unit No. 1 (TS) quest for changes to the Virgil C. Summer Nuclear This letter proposed to delete the organization charts from Section 6.0 and to m ke changes to the training end requalification requirements of the TS. Specifically, the licensee
-proposed to:
(1) delete the reference to the Offsite Organization from Section 6.2.1; (2) delete Figures 6.2-1 and 6.2-2, which reflect the Offsite Organization and the Functional Organization, respectively; (3) renumber Sections 6.2.2 - 6.2.4 as the result of the deletion of.
Section 6.2.1; and (4) revise Section 6.4 to require the retraining and replacement training program to meet _or exceed the requirements of Sections 5.2 and 5.5 of ANSI 3.1-1981, " Qualification and Training of Personnel for Nuclear Power Plants," and 10 CFR 55.59, "Requalification."
The deletion of the Organization Charts from the TS was being handled by
-the NRC staff utilizing-the lead plant concept, with the Shearon Harris Nuclear Power Plant fulfilling the role of the lead plant for this item.
In December 1987, the licensee indicated in discussions with the staff that a reorganization was to occur in January 1988. Thus, on January 6, 1988 they proposed to change TS 6.2_in order not to differentiate between the offsite and onsite organizations. At this time, the entire nuclear staff for the licensee was moving cnsite.
In addition, the licensee provided a revised Figure 6.2-2 to detail the new functional organization.
This submittal also proposed to renumber Sections 6.2.2 - 6.2.4, as a result of the proposed change to Section 6.2, and proposed to modify Sections.6.5.1 and 6.5.3, as a result of the change in titles and constituency in makeup of the Plant Safety Review Committee (PSRC) brought 1
about as a result of the reorganization.
In their January 6,1988, letter the ifcensee stated that they preferred to have the organization charts deleted from the TS. However, they proposed this revised Figure 6.2-2 to be consistent with existing NRC staff policy until completion of the lead plant action.
l On January 27, 1988, an amendment was issued for the Shearon Harris Plant to delete the organization charts from the TS.
Followin the NRC staff issued Generic Letter (GL)g that action, on March 22, 1988, 88-06, " Removal of Organizational Charts from Technical Specification Administrative Control Requirements." This GL provided additional guidance on the removal of the organization charts from the TS.
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s t In a May 16, 1988 letter, the licensee followed the guidance of GL 88 and~ proposed to modify TS 6.2.1 by andressing both the offsite and onsite organizations.and by deleting the reference to TS Figure 6.2-2, but leaving the. remainder.of TS 6.2.2 unchanged.
In a July-18, 1988 submittal, the licensee proposed modifying Section.
6.1.1 to address another change in. title and to delete a statement in that-section which stated that other titles referenced, such as Plant Manager, Station Manager, or Manager, Virgil C. Sussner Nuclear Station would be synonymous with the new title. The incorporation of-that new. title was also proposed for TS 6.2.2, 6.5.1.1, 6.5.1.2, 6.5.1.7, 6.5.3.1, and
- 6.5.3.2.. TS 6.4_ was still to be changed as noted in the July 6,1987 submittal.
On December 22,-1988, a submittal was made to consolidate and to ensure the accuracy of the previously proposed changes resulting from the previous submittals.and to reflect title changes and to correct omissions.
This consolidation was administrative in nature and did not change the staff's previous no significant hazards determination.
2.0 EVALUATION 2.1 Fire Protection The staff has reviewed the licensee's submittals. The licensee has proposed to delete TS 3.3.3.7, Fire Protection Instrumentation; TS 3/4.7.9, Fire Suppression Systems; 3/4.7.10, Fire Rated Assemblies;-
and TS 6.2.2.e, Site Fire Brigade Requirements.
The requirements of each of these specifications are proposed to be incorporated into plant procedures. Technical Specification 6.5.1.6,' Plant Safety Review Commission (PSRC),-is also proposed to be revised to make specific reference to the requirement that the PSRC will review the Summer Fire Protection Program ano its revisions. The licensee. indicated that this reinforces the importance of the Fire Protection Program on plant safety and assures a multi-discipline review by the PSRC of proposed changes to those requirements that are removed from the TS. The licensee has also proposed to modify License Condition 2.C.(18) to state:
Virgil C. Summer Nuclear Station shall implement and maintain in effect all provisions of the approved fire protection program as described in the Final Safety Analysis Report for the facility, and as approved in the SER (Safety Evaluation Report) dated February 1981 (and Supplements dated January 1982 and August 1982) and Safety Evaluations dated May 22, 1986, November 26, 1986, and July 27,1987 subject to the following provisions:
The licensee may nake changes to the approved fire protection program without prior approval of the Comission only if those changes would not adversely affect the ability to achieve ard maintain safe shutdown in the event of a fire.
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- Since the fire protection program, as described in the Final Saiety Analysis Report (FSAR) and as approved in the NRC Safety Evaluation Report and its Supplements and as approved in various NRC Safety Evaluations, will be completely described and controlled through the FSAR/ Fire Protection Evaluation Report and Station Administrative procedures, the staff finds that the proposed changes to delete the fire protection requirements from the TS acceptable. The staff believes that the PSRC will exercise proper oversite to ensure that changes which are made to the fire protection program do not adversely affect the ability of the station to achieve and maintain safe shutdown in the event of fire.
2.2 Organizational Charts The staff has reviewed the licensee's submittals to delete the organizational charts and to modify various sections of the TS as a.
result of the change in titles resulting from the 1988 reorganization and the new constituency of the PSRC and modifications to training TS (6.4).
The licensee proposed to change the title Director, Nuclear Plant Oaerations, to General Manager, Nuclear Plant Operations.
In addition, 111s title change will no longer be synonymous with the titles Manager, Virgil C. Swiner Nuclear Station, Station Manager, or Plant Manager.
The licensee has proposed these changes in TS 6.1.1, 6.2.1, 6.5.1.1, 6.5.1.2, 6.5.1.7, 6.5.3.1, and 6.5.3.2.
The licensee has also proposed to change the titles of those members of the PSRC to reflect changes in titles resulting from the new organization and to increase the membership of the PSRC to reflect an appropriate constituency. The PSRC will now consist of the General Manager, Nuclear Plant Operations or GenerarManager, Operations and Maintanence; Manager, Operations; General Manager, Station Support; Manager, Maintenance Services; Manager, Core Engineering 8 Nuclear Computer Services; Manager, Chemistry and Health Physics; and Manager, Design Engineering. The PSRC will be chaired by the General Manager, Nuclear Plant Operations, or the General Manager, Operations and Maintenance. The licensee also proposed other changes to Section 6 of the TS to reflect changes in titles and organization resulting from the reorganization.
These changes include Group Manager, Technical Services to General Manager, Nuclear Safety (TS 6.2.3.4), and Technical Services to Engineering Services (TS 6.5.3.1).
The staff has reviewed these changes and finds that each of these changes proposed, as a result of the reorgani-f zation at the Summer Station, to be appropriate and acceptable because the change only involves a change in title and adequate controls will be maintained.
The licensee also requested that TS 6.4 be modified to indicate that the
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retraining and replacement training program for the unit staft shall be maintained and shall meet or exceed the requirements and recommendations of Section 5.2 and 5.5 of ANSI 3.1-1981 and 10 CFR 55.59 as connitted to in Appendix 3A of the FSAR. The proposed changes to TS 6.4 are dCCeptable because the change only involves a change in title and adequate controls will be maintained.
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i The licensee proposed to delete the organization charts from TS 6.2 l
through the deletion of Figures 6.2-1 and 6.2-2.
In addition, the licensee proposed to modify TS 6.2.1, Offsite and Onsite Organizations, and TS 6.2.2, Unit Staff, to be consistent with the recommendations of GL J
88-06.
The staff has reviewed these proposed changes which are consistent with GL 88-06 and are acceptable.
3.0 ENVIRONMENTAL CONSIDERATION
This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to a surveillance requirement. The staff has determined that the amendment involves no 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 indivfdual or cumulative occupational radiation exposure. The Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration, and there has been no public coment on such finding. Accordingly, this amendment meets the eligibilit criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9)y This amendment also changes recordkeeping, reporting or administrative procedures or requirements. Accordingly, this amendment meets the eligibility) criteria for a categorical exclusion set forth in 10 CFR 51.22(c)(10.
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this anendment.
4.0 CONCLUSION
4.1 Fire Protection 8ased upon a review of the licensee's amendment request to remove the fire protection requirements from the TS, to modify the responsibilities of the PSRC to include the fire p(18) so that changes to the fire rotection program and its revisions, and to modify License Condition 2.C.
protection program can only be made if they do not adversely affect the capability of the Station to achieve and maintain safe shutdown in the event of a fire; the staff has concluded that these proposed changes are appropriate and consistent with Generic Letter 86-10 and are, therefore, acceptable.
The Comission made proposed determinations that the amendment involves no significant hazards consideration which were published in the Federal Register on July 29,1987 (52 FR 28388) and on February 24, 1988 (53 FR 5496),
and consulted with the State of South Carolina.
No public coments were received, and the State of South Carolina did not have any comments.
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4.2 Organizational Charts-Based upon.a review of the licensee's amendment request to (1) delete the organizational charts from the TS.-(2) modify the titles in the AdministrativeControlssectionofthe-TS,and(3)reviewtheretraining and replacement training program; the staff has concluded that these proposed changes are. appropriate and consistent with GL 88-06.
The Commission made proposed determinations that the amendment involves-no significant hazards consideration which were published in the FEDERAL REGISTER on September 9, 1987 (52 FR 34019), May 4, 1988 (52 FR.15916),
August 10, 1988 (53 FR 30142), and August 24, 1988 (53 FR 32296), and consulted with the State of South Carolina. No sublic comments or requests for hearing were received, and the State of Sout1 Carolina did not have ccanents.
The staff has concluded, based on the considerations 'escribed 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, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of the amendment will nc; be inimical to the comon defense and security or to the health and safety
.of the public.
Principal Contributor:
John J. Hayes, Jr.
Dated:
July 24,1989 1
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.tj,f 4.2 Organizational Charts Based upon a review of the licensee's amendment request to (1) delete the organizational charts from the TS, (2) modify the titles in the Administrative Controls section of the TS, and (3) review the retraining and replacement training program; the staff has concluded that these proposed changes are appropriate and consistent with GL 88-06.
The Commission made proposed determinations that the amendment involves no significant hazards consideration which were published in the FEDERAL REGISTER on September 9, 1987 (52 FR 34019), May 4, 1988 (52 FR 15916),
August 10, 1988 (53 FR 30142), and August 24, 1988 (53 FR 32296), and consulted with the State of South Carolina.
No public comments or requests for hearing were received, and the State of South Carolina did not have comments.
The staff has concluded, based on the considerations described above that:
(1) there is reasonable assurance that the health and safety of the p(2) such activities will be conducted in compliance with theublic will not b and Commission's regulations, and 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 J. Hayes, Jr.
Dated:
July 24,1989
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