NL-02-141, Supplement to License Amendment Request (LAR-02-009) Regarding Administrative Changes to TS
| ML023100325 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/31/2002 |
| From: | Dacimo F Entergy Nuclear Northeast |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-02-141 | |
| Download: ML023100325 (4) | |
Text
Alk' Entergy Nuclear Northeast "Entergy Nuclear Operations, Inc Indian Point Energy Center Enter y 295 Broadway, Suite 1 PO Box 249 Buchanan, NY 10511-0249 October 31, 2002 Re:
Indian Point Unit No. 2 Docket No. 50-247 NL-02-141 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop 0-P1 -17 Washington, DC 20555-0001
SUBJECT:
Supplement to License Amendment Request (LAR-02-009)
Regarding Administrative Changes to Technical Specifications
REFERENCE:
- 1. ENO letter NL 02-071 to NRC; "License Amendment Request Regarding Changes to Facility Operating License No. DPR-26 to Reflect ENN/IPEC Reorganizations," dated May 30, 2002.
Dear Sir; Entergy Nuclear Operations, Inc. (ENO) submitted a request for amendment (Reference 1) to Section 6.0. "Administrative Controls" of the Indian Point 2 (IP2) Technical Specifications. The scope of the requested amendment includes changes that are the result of the adoption of a new quality assurance (QA) program document at IP2. During a conference call with the NRC staff on August 6, 2002 ENO agreed to provide additional information regarding these proposed changes.
The Technical Specifications currently refer to the 'Quality Assurance Program Document' (QAPD), which describes the IP2 QA program. ENO has developed the 'Quality Assurance Program Manual' (QAPM) that integrates the QA programs for other nuclear power plants owned and operated by Entergy, including IP2. The QAPM has replaced the QAPD as the QA program document for IP2 and the Updated Final Safety Analysis Report (UFSAR) has been revised to reflect this change. ENO evaluated and implemented the transition from the QAPD to the QAPM in accordance with 10 CFR 50.54(a). Since the Technical Specifications currently reference the QAPD, the request for amendment includes changes to replace references to the QAPD with references to the QA program described or referenced in the UFSAR, i.e., the QAPM. The amendment request does not propose to modify the existing requirements stated in Technical Specification Section 6.0. identifies the QAPM sections that implement the QAPD requirements pertaining to the subjects that are within the scope of the proposed amendment of the Technical Specifications. This information is provided to support NRC staff review of the proposed amendment.
NL-02-141 Page 2 of 2 The information provided in this supplement does not modify the requested changes to the Technical Specifications and does not alter the conclusions of the 'No Significant Hazards Consideration' evaluation previously provided in Reference 1.
There are no new commitments made in this letter. Should you or your staff have any questions regarding this submittal, please contact Mr. Kevin Kingsley at (914) 734-5581.
I declare under penalty of perjury that the foregoing is true and correct. Executed on ID 3
- 2ooL.
Fred Dacimo Vice President - Operations Indian Point 2 : Additional Information Regarding Amendment Request LAR-02-009 cc:
Mr. Hubert J. Miller Regional Administrator-Region I US Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Patrick D. Milano, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management US Nuclear Regulatory Commission Mail Stop O-8-2C Washington, DC 20555 NRC Senior Resident Inspector US Nuclear Regulatory Commission PO Box 38 Buchanan, NY 10511 Mayor, Village of Buchanan 236 Tate Avenue Buchanan, NY 10511 Mr. Paul Eddy NYS Department of Public Service 3 Empire Plaza Albany, NY 12223 Mr. William F. Flynn NYS ERDA Corporate Plaza West 286 Washington Ave. Extension Albany, NY 12223-6399
ATTACHMENT I TO NL-02-141 Additional Information Regarding Amendment Request LAR-02-009 Page 1 of 2 Tech Spec Subject Change Summary Discussion Section 6.2.1.a Requirement for Change from:
The subject requirement was stated in Section 3.2 of the establishing
.... shall be documented in QAPD. The requirement is now identified in Section A.7 and documenting the QAPD (Regulatory Commitments) of the QAPM by reference to organizational Regulatory Guide 1.33, Rev 2, which endorses ANSI relationships Change to:
N18.7-1976. ANSI N18.7 (Section 3, 'Owner
.... shall be documented in Organization) contains the subject requirement.
the QA program document referenced in the UFSAR 6.5.1 Review and audit functions Delete 6.5.1 from Tech The subject requirement was stated in Appendix B of the of the onsite and offsite Specs. Requirements are QAPD. The information is now identified in Sections review committees maintained in licensee A.2.f and A.7 of the QAPM. Section A.7 references controlled document; Regulatory Guide 1.33, Rev 2, which endorses ANSI QAPM N18.7-1976. Table 1 of the QAPM also lists clarifications / exceptions to ANSI N1 8.7 so that the QAPM reflects the information as previously listed in the QAPD.
6.6 Requirement for event Remove detail regarding The subject requirement is addressed in the QAPM by reporting in accordance internal routing and review reference to Regulatory Guide 1.33, Rev 2, which with 10 CFR 50.73.
of Licensee Event Reports endorses ANSI N18.7-1976 and as modified by clarification / exception number C.9 in Table 1 of the QAPM.
6.7 Reporting requirements for Remove detail regarding The subject requirement is addressed in the QAPM by safety limit violations internal routing and review reference to Regulatory Guide 1.33, Rev 2, which of Safety Limit Violation endorses ANSI N1 8.7-1976 and as modified by Reports clarification / exception number C.9 in Table 1 of the QAPM.
ATTACHMENT I TO NL-02-141 Additional Information Regarding Amendment Request LAR-02-009 Page 2 of 2 Tech Spec Subject Change Summary Discussion Section 6.8 Requirements regarding Replace reference to Section 5.2.15 of the QAPD addressed requirements written procedures QAPD with reference to regarding review, approval, and control of procedures.
the QA program, as These requirements are addressed in the QAPM by described in the UFSAR reference to Regulatory Guide 1.33, Rev 2, which endorses ANSI N18.7-1976 and as modified by clarification / exception numbers C.14 through C.26 in Table 1 of the QAPM.
6.10 Requirements regarding Replace reference to Section 5.2.12 of the QAPD addressed the subject record retention QAPD with reference to requirements. These requirements are addressed in the the QA program, as QAPM by reference to Regulatory Guide 1.33, Rev 2, described in the UFSAR which endorses ANSI N18.7-1976 and by reference to Regulatory Guide 1.88, Rev 2, which endorses ANSI N 45.2.9-1974. Clarifications / exceptions are noted in items J1 through J7 of Table 1 in the QAPM.
6.14 Process Control Program Delete 'by the SNSC' from As discussed for item 6.5.1, review and audit functions 6.15 Offsite Dose Calculation statements regarding of SNSC were stated in Appendix B of the QAPD. The Manual review or acceptance of subject requirement is now addressed by the QAPM 6.16 Radioactive Waste System changes to these items.
reference to Regulatory Guide 1.33, Rev 2 which endorses ANSI N18.7-1976.