ML19341C717
| ML19341C717 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/04/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19341C715 | List: |
| References | |
| NUDOCS 8103040003 | |
| Download: ML19341C717 (10) | |
Text
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pf UNITED STATES
,', g NUCLEAR REGULATORY COMMISSION g
, t WASHINGTON, D. C. 20555 n.
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 23 TO PROVISIONAL OPERATING LICENSE NO. DPR-45 DAIRYLAND POWER COOPERATIVE DOCKET NO. 50-409
1.0 INTRODUCTION
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By letter dated August 6,1980, (LAC-7073), as supplemented September 16,1980 (LAC-7140) and November 18,1980 (LAC-7235, Dairyland Power Cooperative (DPC) (the licensee) requested an amendment to the Techni-cal Specifications (TS) for the La Crosse Boiling Water Reactor (LACBWR).
Tne amendment would change the Technical Specifications to (1) reflect changes in the DPC corporate management structure and the LACBWR staff, (2) convert Section 3.0 to the format and general wording of Section 6.0 " Administrative Controls" of the Standard Technical Specifications, (STS), and (3) eliminate duplication and make clarifying revisions in tne " General" requirements area of Section 4.0.
2.
C:SCUSSION inis evaluation is directed at assuring that the existing Technical Soecification requirements are adequately included in the revised Technical Specifications and that the proposed changes do not diminish tqe level of safety that is provided by the existing Technical Specifi-cations.
It was not directed at determining whether or not the revised administrative section of the Technical Specifications is in conformance with recently developed NRC criteria that have not yet been formally i.1 posed on DPC. We performed the eva'itation, to a large extent, by comparing the differences between the proposed wording and the wording of the Standard Technical Specification (DPC's Sept. 15, 1980 filing).
We have made a number of modifications to the proposed Technical Specifi-cation as submitted in DPC's August 6,1980 letter to the NRC.
- However, ea;h of these modifications was discussed with DPC's representative, who has agreed that these changes are acceptable to DPC.
Details about these cnanges are discussed in the following section.
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3.0 EVALUATION 1.
The NRC Standard Technical Specification (STS) includes a Section 6.1.2 with the following wording: "The Shift Supervisor (or during his absence from the control room, a designated individual) shall be responsible for the control room command function. A management directive to this effect, signed by the (highest) level of corporate management) shall 'be reissued to all station personnel on an annual basis." This requirement'has already been imposed on the LACBWR via the NRC letters concerning imple-mentation of the TMI-Lessons Learned Short Term Recommendation (NUREG-0578).
We have added this section to the proposed LACBWR Technical Specification (TS).
2.
We note that the STS included requirements in Section 6.2.2 for a Senior Reactor Operator (SRO) in the control room whenever the unit is in Modes 1, i
2 or 3 and for a Health Physics (HP) Technician to be onsite whenever fuel is in the reactor.
The requirement for the SRO in the control room is imposed by our July 31, 1980 letter to all licensees on Interim Staffing Criteria but is not required to be implemented at the LACBWR until July 1982. The require-ment for the HP Technician is one of two options listed in tne NRC Standard Review Plan for providing a person qualified in radiation protection on each operating shift.
The other option is the one selected by DPC in Section 6.2.2.a.
i.e., an individual qualified in radiation procedures.
3.
The proposed LACBWR TS states that a Fire Brigade of at least five members shall be maintained onsite at all times. The proposed TS also states that the Fire Brigade shall not include the two LACBWR plant operators necessary for safe shutdown of the unit or any other personnel required for other essential functions during a fire emergency.
However, Section 6.2.2 of the STS states that the Fire Brigade shall not include three members of the minimum shift crew necessary for safe shutdown of the unit.
The current i
requirement at LACBWR is that the two plant operators necessary for safe shutdown be excluded from the Fire Brigade.
This ' current requirement was i
established by the NRC as a result of a previous NRC review of the LACBWR fire protection provisions.
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On the basis that it is consistent with the current NRC requirement for the LACBWR plant, we conclude that the proposed TS is acceptable.
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we note that a new Appendix R to 10 CFR 50 which will become effective on Februa ry 17, 1981 will require that the adequacy of the fire protection, including the number of operating shift personnel exclusive of the Fire Brigade that are required, at LACBWR as well as other nuclear plants be
' re-eval uated.
4.
The proposed LACBWR TS includes the following footnote concerning the Fire Brigade:
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"The Fire Brigade composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unexpected absence of Fire Brigade members provided immediate action is taken to restore the Fire Brigade to within the minimum requirements."
The existing LACBWR TS does not provide a similar relief from the minimum composition.
In order to assure that the relief is consistent with the two hour relief allowed elsewhere in the STS, we have added an additional sentence to the proposed footnote that states "This provision does not permit any Fire Brigade position to be unmanned upon shift chance due to an oncoming Brigade member being late or absent."
5.
Org'anization Chart 3.2.1-1 was revised from that in the existing LACBWR TS to reflect changes in the corporate organization.
The changes add a Director of Environmental Affairs and two additional Assistant General Managers; one handles financial activities and the other handles an administrative services group. The title of the Assistant General Manager -
Chief Mechanical Engineer was changed to Assistant General Manager - Power Group and the title of the Assistant General Manager - Chief Electrical Engineer was changed to Assistant General Manager - Systems Engineering Group.
Organization Chart 3.2.1-2 was revised to reflect changes made to the LACBWR plant staff.
These changes include:
a) the addition of a Radiation Protection Engineer, a Technical Support Engineer and a Security Director b) the addition of an Assistant Operations Supervisor who handles training c) the elimination of the Administrative Assistant position from the plant staff d) the addition of an' Assistant Mechanical Engineer e) the addition of a Security Director Since no explanation of the organizational changes was provided by DPC in its submittal of proposed Technical Specification changes, we discussed the changes with DPC (the LACBWR Plant Superintendent) to learn more about them.
The changes in the corporate organization were made as a result of an evaluation of the DPC organization performed for DPC by a consulting firm.
' The LACBWR Plant Superintendent continues as before to report to the Assistant General Manager in charge of power plant operation. We conclude that the changes in the corporate organization have not diminished the capability for safe operation of the LACBWR and are, therefore, acceptable.
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-4 The Radiation Protection Engineer was added to the staff to upgrade the
' s adiation protection group qualifications.
This new position requires a technical graduate. A new employee with extensive work experience at another nuclear power plant has been assigned to this position. The other engineers and the Security Director that were added provide increased support for operation of the plant. The addition of the Assistant to the Operations Supervisor provides a backup for the Operations Supervisor who is also available to serve as an additional relief for shift supervisor watches. This Assistant to the Operations also oversees the LACBWR training activities.
The Administrative Assistant's function was moved to the corporate office as part of the corporate reorganization.
i Based on discussions, with DPC, we understand that an NRC inspection at La Crosse found the licensee's handling of security system matters to be in need of improvement. As a result, the Assistant Plant Superintendent l
was designated by DPC to monitor implementation of the security syst'em matters and act as the NRC contact for security matters. We understand that this change has resulted in added impetus for resolving security matters.
The changes to the organizational chart document the additional management that has been added to the security organization. We note that except for the Assistant Plant Superintendent and the Security Director, the plant security staff are contract personnel.
Based on our review of all of these organizational changes as discussed above, we have concluded that none of them diminishes DPC's capability to safely operate the LACBWR, that they will enhance this capability ano are, therefore, acceptable.
The existing LACBWR TS requires a minimum operating crew of four persons including one SR0 (Shift Supervisor), one R0 and two unlicensed operators.
It requires the same minimum crew size for all operating conditions in-cluding conditions 4 and 5 (cold shutdown an/ refueling).
In converting the shift manning requirements to the STS format (Table 6.2.2.1), DPS proposes to maintain staffing requirements of four persons during operating conditions 1, 2 and 3 (power operation, startup, and hot shutdown) but proposes to require one less person (1 A0) on the minimum crew during operating conditions 4 and 5.
It does, however, propose to add a require-ment that the SR0 supervising the refueling activities is not the SR0 (Shift Supervisor) that is included in the minimum crew of three persons.
We note that the minimum crew of four persons during operating conditions 1, 2 and 3 is smaller in number than the five persons (one shift supervisor /SRO, two reactor operators, and two auxiliary operators) that are currently required for most operating nuclear plants.
However, the current LACBWR TS requires only four persons and, therefore, the proposed crew size of four persons for operating conditions 1, 2, and 3 is acceptable at the present time. We note, however, that the NRC's July 31, 1980 letter to all licensees on Interim Staffing Criteria sets forth new staffing requirements that must be implemented i
at LACBWR by July 1982.
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' The proposed change from a minimum crew size of fcor persons during operating conditions 4 ind 5 to a minimum crew size of three persons together with the noted requirements that SRO supervising the refueling is in addition to the SR0 (Shift Supervisor) listed in the minimum crew size is consistent with the minimum staffing during conditions 4 and 5 currently required of other nuclear plants and with the July 31, 1980 Interim Criteria. On this basis, we conclude that the proposed char:ge is acceptable.
DPC has proposed to add a foot note to Table 6.2.2-1 that states:
" Shift crew composition may be less than the minimum requirements for a period of time not to exceed two hours in order to accommodate unex-pected absence of on duty shift crew members provided inmediate action is taken to restore the shift crew composition to within the minimum requirements of Table 6.2.2-1."
The STS allows plants to have one less crew member (other than the shift super-visor) than the total minimum shift crew requirement for up to two hours in such i
unexpected circumstances.
However, the minimum shift crew requirements for most plants are such that even with one less crew member, the crew will always have at least two licensed operators present.
In order to provide some relief as allowed by the STS, we have modified the proposed footnote to limit the number of minimum crew members who can be 4
absent under these circumstances for no more than two hours, to assure the presence of two licensed operators and to assure that this relief is not used to accommodate late or absent oncoming crew members.
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To be consistent with the STS, we have also added another footnote to Table 6.2.2-1 concerning assumption of the control room command function.
7.
The STS includes a statement in Section 6.3.1 concerning supplemental requirements on operator qualification that were required by the NRC March 28,1980 letter to all licensees.
19 make it consistent with the STS, we have modified Section 6.3.1 to read as follows:
6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions and the supplemental requirements specified in Section A and C of of the March 28, 1980 NRC letter to all. licensees,
I except for the (Radiation Protection Manager) who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
E.
DPC has proposed to modify the list of the Operations Review Committee (0RC) members in Section 3.5.1.2 to replace the individual staff engineer title (i.e., Reactor Engineer, Nuclear Engineer, Process Engineer, Mechanical Engineer, Electrical Engineer and Instrument Engineer) with the generic 1
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term " staff engineers." We understand that this change was proposed so that when staff engineer titles are added to or deleted from the plant staff, DPC will not have to modify its membership list. This change decreases the specificity of members and is unacceptable. We have added, based on oral discussions with DPC, the engineer titles currently listed in the existing Technical Specification plus several additional engineer titles listed in the new organization chart that DPC requested be added.
a DPC also dropped the QA Supervisor from this list. We understand this was_ done because DPC felt it would be a conflict of interest for the QA 4
Supervisor to audit the work that he might do as a committee member.
This change is not inconsistent with the STS which likewise does not '
include a QA person and does not diminish the effectiveness of the committee. We conclude that this change is acceptable.
2 9.
Items k,.1, and m of Section 3.5.1.6 of the existing TS and of Section 6.5.1.6 of the proposed revision deal with review and audit of the fire i
protection program.
The same requirements are also included in the proposed revision to Section 3.5.2.8 as.Jdit functions of the Safety Review Committee (SRC). Since these requirements are located under the Company Nuclear Review and Audit Group (Section 6.5.2.8) in the STS and since there is no need to have these functions performed by both the ORC and the SRC, we have deleted items k,1, and m of proposed TS Section 6.5.1.6.
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1C.. The quorum for the SRC as required by Section 3.5.2.6 of the existing LACBWR TS is the chairman and three members.
This same quorum has been sr'cified in the proposed TS (Section 6.5.2.6.
Since the proposed re-quirement is consistent with the existing requirement, we find that it is acceptable. We note, however, that it is one less member than the quorum specified in the STS which specified the quorum as being the chairman plus four members. We also note that the LACBWR plant superintendent has sug-gested that since most of the LACBWR SRC members are consultants whose offices are located in different parts of the country, it might be difficult, at times, to obtain a quorum of the SRC members when meetings are needed if a quorum requires a larger number of members, 11.
Paragraphs a and b of Section 3.5.2.10 of the existing TS on Records allows 20 days for forwarding SRC minutes and reports to the DPC General Manager.
DPC has proposed to retain this 20 day period rather than specify 14 days as does the STS. While we would prefer to have similar reporting
' periods specified in the TS for all plants, we cannot see any safety reason for requiring that DPC change its reporting period.
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12.
Paragraph b of Section 6.7.1 of the proposed TS calls for reporting safety limit violations to the Commission within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
This does not reflect the current requirements that have been imposed on LACBWR by the NRC. We require that paragraph b be modified to use the current STS wording which does reflect the current requirement. The current STS wording is:
"The NRC Operation Center shall be notified as soon as possible and in all cases within one hour. The Assistant General Manager - Power Group and the SRC shall be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />."
13e Paragraph d of Section 3.7.1 of the existing TS calls for submitting the (written) Safety Limit Violation Report to the Commission within 19 days.
1 The current STS requires that this report be submitted within 14 days.
DPC has proposed to use the STS reporting requirement in Section 6.7.1 of the proposed revision in order to allow itself four additional days over its current reporting limit. We allow other licensees 14 days to provide I
written reports to the Commission. We see no reason not to allow the same l
amount of time to DPC and conclude that the change is acceptable.
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- 14. Section 3.8.1 of the existing LACBWR TS has been modified substantially to reflect the current STS wording for the requirements for establishing writter, procedures. The proposed TS Section 6.8.1 is consistent with the current STS except that it does not include Item f Fire Protection Program Implementation. We have added Item f. to the
'st of items in proposed Section 6.8.1.
The principal difference in t-. existing and the proposed TS is that the proposed TS references the iquirements of t
the 1978 version of Appendix A to Regulatory Guide 1.~.2 rather than the i
1972 version of ANSI-18.7 and relies on the specifici y of the listing in i
Appendix A of items requiring procedures rather than the broader require-ment in the existing TS which came from referencing Sections 5.1 and 5.3 and ANSI-18.7-1972.
We conclude that proposed Section 6.8.1 with the addition of Item f. as noted, is consistent with current NRC requirements and is acceptable.
15', The first two words in proposed TS Section 6.9.1.2 are "The report."
l We have changed them to read "The startup report." This will add clari-
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fication and will be consistent with the STS wording.
16.
Footnote 1/ following the heading " Annual Operating Report" on page 6-13 of the proposed TS is not pertinent to a single unit station and has been
' deleted.
It follows that footnote 2/ has become footnote 1/.
17.
The current STS do not list the individual reports under Section 6.9.2 on Special Repor.ts as does the existing LACBWR TS and the proposed TS.
Listing these reports asks for errors of omission and requires continual updating of the list as reporting requirements are added or deleted. We have deleted the detailed listing of items a. through f. from this section of the proposed TS to be consistent with the STS.
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- 18. The retention period for records of reactor tests and experiments in the existing LACBWR TS is five years (Section 3.10.1).
The proposed TS changes this from five years to the duration of the operating license (Section 6.10.2). This is consistent with the current requirements as listed in the STS and is acceptable.
19.
Paragraph c of Section 3.10.2 of the existing TS requires that records of facility radiation and contamination surveys be retained for the duration of the Unit Operating License. The STS does not include this requirement and DPC has not included it in its proposed TS revision. Section 20.201 of 10 CFR Part 20 requires that these surveys be made and that Section 20.401 of '10 CFR Part 20 requires that reports of the surveys be retained for a period of two years.
We see no reason to require that the LACBWR retain these reports for a longer period than required by the regulation or than required by other utilities using the STS and agree that it is acceptable to delete the LACBWR requirement listing from the TS.
- 20. We have also used the STS nomenclature " Radiation Work Permit" to refer to the work permit required to work in a high radiation area rather than the "Special Work Permit" as in the existing TS and the proposed TS Section 6.12.1.
21.
DPC has proposed to delete the existing TS Sections 3.14.1 through 3.14.7 instead of carrying these words over in the proposed TS.
DPC's stated reasons for this deletion are:
i a.
The requirements listed. in Section 3.14.1 through 3.14.7 are addressed in Sections 6.1, 6.4, and 6.8 of the proposed TS.
b.
The requirements listed in Sections 3.14.5 through 3.14.7 are con-tained in approved written plant procedures.
We' note that the STS does not have Sections that are similar to these.
We agree that the requirements listed in Section 3.14.1 through 3.14.4 of the existing TS are adequately covered by Sections 6.3, 6.4 and 6.8 of the proposed TS and, therefore, find the deletion of Sections 3.14.1 j
through 3.14.4 to be acceptable.
With respect to deleted Sections 3.14.5 through 3.14.7, we note that these sections speci fy requirements for control of bypass keys, operation of locked valves and bypassing interlocks. We note that Section 6.8.1.a of the proposed TS requires that applicable procedures recommended in Appendix A to Regulatory Guide 1.33 be implemented.
Appendix A recommends
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-9 administrative procedures for equipment control (e.g., locking and tagging) and for bypass of safety functions and jumper control. We consider that these administrative procedures called for in proposed TS Section 6.8, when appropriately implemented, will require the control of bypass keys, locked valves and bypassing interlocks as presently required by existing TS Sections 13.14.5 through 13.14.7. We will rely on the Office of Inspection and Enforcement (IE) to assure that appropriate procedures for the control j
of locking and bypassing functions are implemented. On the basis that Section 6.8 requires the implementation of procedures covering the material being deleted from Sections 3.14.5 through 3.14.7 of the existing TS and that IE will assure that the required procedures are appropriately imple-mented, we conclude the deletion of existing TS Sections 3.14.5 through 3.14.7 is acceptable.
We note that the STS has no speci fic requirements similar to those in Sections 3.14.5 through 3.14.7 of the existing LACBWR TS but relies instead on Section 6.8's requirement for implementation of appropriate procedures that are listed in Appendix A to Regulatory Guide 1.33.
22.
DPC has proposed to delete Section 4.1.1 of the existing LACBWR TS on the j
basis that the requirements of this section are covered by paragraph 2C(2) of the LACBWR Provisional Operating License. We agree with DPC that Section 4.1.1 is redundant to paragraph 2C(2) of the License and should be deleted.
l 23.
Section 4.1.2 of the existing LACBWR TS requires that "At all times when i
the reactor is critical or when its controls are being manipulated with 4
fuel in the reactor, the control room shall be attended by a minimum of two persons, one of who shall have a valid Operator's License and shall l
have full responsibility for operation of the facility."
DPC has proposed to delete this section on the basis that the requirement is contained 4
in proposed TS. Table 6.2.2-1.
We do not agree that Table 6.2.2-1 contains this requirement. Table 6.2.2-1 specifies the minimum shift crew size while Section 4.1.2 of the existing TS specifies the minimum control room complement.
Because it relates solely to control room manning, we have moved the information in Section 4.1.2 of the existing TS to Section 6.2.2 of the proposed TS.
- 24. Section 4.1.3 of the existing TS describes requirements for manning the 4
control room and monitoring the nuclear instrumentation during periods when the reactor is shutdown.
DPC has proposed a revision to this TS
' section which deletes the reference to control room manning requirements and replaces a special definition of shutdown with the three shutdown conditions (conditions 3, 4, and 5) as defined in Section 4.0.1 of the TS.
DPC's stated purpose for the change is to remove the ambiguity that exists between the special definition and the shutdown conditions (condition 3, 4, and 5) as defined in Section 4.0.1.
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o The control room manning requirement is acceptably specified in Section 6.2.2 of the proposed TS, so deletion of the control room manning require-ment in Section 4.1.3 is acceptable.
The replacement of the special definition of shutdown with the three operating conditions, condition 3, 4, 4
and 5 clarifies the monitoring requirements but does not reduce them.
On the basis of this discussion, we conclude that the proposed change to TS Section 4.1.3 is acceptable.
We note, however, that this monitoring activity need not be specifically addressed in the TS.
It is an obvious requirement that nuclear instru-mentation will be monitored whenever there is fuel in the reactor.
Specific procedures to address these shutdown situations are required under Section 6.8.
The monitoring requirement should be specified in the implementing procedures. We also note that the STS does not include a section similar to 4.1.3.
l Based on the above, we find the proposed changes, as modified, acceptable.
4.0 EN'.'IRONMENTAL CONSIDERATION We have determined that the amendment does not involve a change in effluent types or total amounts not an increase in power level and will not result in i
any significant environmental impact.
Having made this, determination, we l
have further concluded that the amendment involves an action which is insignifi-car.t from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4) that an environmental impact statement or negative declaration and environmental im;act appraisal need not be prepared in connection with the issuance of this amendment.
5.3 CTCLUSION
'ne have concluded, based on the considerations discussed above, that:
'i', because the amendment does not involve a significant increase in
- ne probability or consequences of accidents previously considered anc does not involve a significant decrease in a safety margin, the amendment does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the bealth and safety of the
- utlic.
Date: February 4,1981 1
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