ML20010C042
| ML20010C042 | |
| Person / Time | |
|---|---|
| Site: | Salem |
| Issue date: | 07/31/1981 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20010C041 | List: |
| References | |
| NUDOCS 8108190055 | |
| Download: ML20010C042 (3) | |
Text
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UNITED STATES
'3 NUCLEAR REGULATORY COMMISSION
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E WASHINGTON. D. C. 20555
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AftENDMENT NO. 38 TC *.CILITY OPERATING LICENSE NO. DPR-70 PUBLIC SERVICE ELECTRIC AND GAS COMPANY, PHILADELPHIA ELECTRIC COMPANY, DELMARVA POWER AND LIGHT COMPANY, AND ATLANTIC CITY ELECTRIC COMPANY SALEM NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-272 Introduction By letter dated April 24, 1981, Public Service Electric and Gas Company request-ed a change to the Technical Specifications for Unit 1 of the Salem Generating Station.
fl.e wording of the cnange wu subsequently modified by a telecopy transmission of revised wording for Section 6.5.2.2 of the Technical Specifica-tions. By separate action, the licensee has also requested a similar change to the proposed Technical Specifications for Salem Unit 2.
Evaluation The requested change is administrative in nature and pertains to the composition of the Nuclear Review Board (NRB). The existing Salem 1 Technical Specifications specify a nine-member NRB, including the Chairman and Vice Chainnan, by position title within the company. The licensee proposes to change the designated NRB membership to specify personnel by qualifications and experience rather than by title.
In the course of this change, the functional areas of nondestructive testing and c:ner;ency preparedness will be aaded to the areas of expertise covered by NPA members. Qualifications of the NRB members will meet the require-ments snecifit d in Sections 4.7.1 and 4.7.2 of ANSI /ANS 3.1, 1973.
The staff's positions in regard to Reviews and Audits is described in Section 4 of ANSI N1F, 7-1976 (ANS 3.2 " Administrative Controls and Quality Asrurance for the Operational Phase Of Nucinar Power plants").
Thh standard has been endorsed by Regulatory Guide 1.33, Revision 2, February 1978, " Quality Assurance Program Requirements (Operations).
In regard to reviews and audits and the subject in question, Section 4.1 of ANSI N18.7-1976 states the following:
8108190055 810731 PDR ADOCK 05000272 P.
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' "The programs provided for reviews and for audits may take different form &.
For example, the owner organization may assign these functions to separate established organizational units independent of the onsite operating organization, or may appoint a standing committee comprised of _ individuals from within or outside the owner organization to perform reviews and to exercise overview of audits.
"liistorically, a committee approach was used to provide both review and audit capability for early commercial nuclear power plants. This approach was employed to make the most efficient use of personnel with pertinent experience and qualifications.
In the ensuing period, the availabilitv of competent personnel has significantly increased as the nuclear pov industry has expanded and the sources of trained manpower have responded to the resulting demand. This growing pool of talent in the aggregate, is sufficient to encourage alternative Epproaches to the review and audit committeer commonly used in the past.
"In general, the time required of fredividuals serving as members of inde-pendent review groups is a function of the number of nuclear power plants an owner organization has in operation.
For this reason, owner organiza-tions entemplating rapid growth and an expanding commitment to nuclear power saould. regard the use of coutittees to meet the independent review functions as an interim approach for effective utilization of available technical expertise.
In addition, such owner organization ~ should include s
in their expansion planning, provisions for early estcblishment of organiza-tional units to provide independent review, for recruitment of staff, and 4
for an orderly transition to such an organizational structurc in the event a committee approach has been used previously to meet the independent review function.
"An independent offsite organizational unit may be assigned review responsi-bilities including responsibility for reviewing audit reports provided by onsite staff members, or both functions may be assigned to an organizational unit that is independent of lirie responsibility for operating activities.
This Standard does not specify an organizational structure for meeting the review and audit functions, but in lieu thereof delineates essential elements of satisfactorily comprehensive prograus for review and for audit in the manner best suited to the owner organization involved."
The above stated position is being reaffimed in ongoing revisions to the above cited Standard and Regulatory Guide 1.33.
In regard to past practice, the staff has approved proposed alternates to the l
ccmmittee method of independent review.
Individuals parforming such review l
should have a bachelor degree in engineering or related science and five i
years of professionali level experience in his field. This requirement has been established as the staff's position in regard to qualification require-l ments for persons perfoming these reviews wherein position titles were not l
designated.
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" The early efforts to get senior management personne1'as members of a review
. committee was primarily because they were the only company personndl that had attained the technical expertise that we - a" ired to perform these functions.
In time, many utilities have developed in, a technical capability to perform this function and thereby relieve upper management of what in many cases has been an added burden resulting in their review becoming more perfunctory than the indepth review we believe is necessary. Therefore, we are of the opinion that the technical review can De better performed by well qualified technical staff.
Furthermore, in regard to the Salem change, the results of reviews done by the Nuclear Review Board will continue to be sent to the same levels of management as before the change.
In light of the above, we consider that the change to the Salem Technical Specifications in regard to qualifications of individuals has no generic impli-cations, is consistent with the staff's position as described in Regulatory Guide 1.33, is in effect at other operating reactors, and should not reduce the effective function of the Salem independent review function.
Therefore, as do not see it as either new, or a significant chmge from past experience.
Environmental Consideration We have determined that the-amendment does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. 'Having made this determination, we have further concluded that the amendment involves an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 551.5(d)(4), that an environmental impact statement or negative declaration and environ-mental impact appraisal need not be prepared in connection with the issuance of this amendment.
Conclusion We have concluded, based on the considerations discussed above, that:
(1) because the amendment does not involve a significant increase in the probability or consequences of accidents previously considered and 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 health and safety of the public.
JUL 31 1981 4
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