0CAN029902, Forwards Response to NRC 990205 RAI Re Proposed AC TS Changes

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Forwards Response to NRC 990205 RAI Re Proposed AC TS Changes
ML20207B624
Person / Time
Site: Arkansas Nuclear  Entergy icon.png
Issue date: 02/25/1999
From: Vandergrift J
ENTERGY OPERATIONS, INC.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
0CAN029902, CAN29902, NUDOCS 9903080194
Download: ML20207B624 (20)
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Entergy Operations,Inc.

v,AR 72801 Tel 501858-5000 8

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February 25,1999

' OCAN029902 U. S. Nuclear Regulatory Commission Document Control Desk i

Mail Station OPI Washington, DC 20555 i

Subject:

Arkansas Nuclear One -Units I and 2 Docket Nos. 50-313 and 50-368 i

License Nos. DPR-51 and NPF-6 l

AdditionalInformation Concerning Proposed Administrative Controls Technical Specifications Changes Gentlemen-i By [[letter::0CAN119801, Application for Amends to Licenses DPR-51 & NPF-6, Implementing Consolidated EOI QA Plan Manual Submitted on 980430 & Approved by NRC in 981106 Se.Changes Also Clarify Responsibilities on STA Position on Shift|letter dated November 24,1998]] (0CANI19801), Entergy Operations requested changes to

. the Arkansas Nuclear One - Unit 1 (ANO-1), and Unit 2 (ANO-2) Technical Specification i

Administrative Controls section.

The proposed changes included changes n~~ery to

. implement the consolidated Entergy Operations Quality Assurance Plan Manual approved by i

the NRC in a Safety Evaluation dated November 6,1998 (CNRI-98/00005), and several other

' administrative changes to clarify the requirements and reduce the need for future amendment requests.

By letter dated February 5,1999, the NRC requested that Entergy Operations supplement our -

I November 24,1998, submittal with additional detail within 30 days in order to aid the review of the proposed changes. The attachment to this letter presents the additional information requested.

Although this submittal contains some new information and an additional level of detail of previously presented information, Entergy Operations has determined that the No Significant Hazards Considerations presented in our November 24,1998, submittal remain bounding.-

Very truly yours,

[)I I

j T

D. Vandergrift 12, Director, Nuclear Safety o

JDV/cws.

At*=chmants l

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'. U. S. NRC

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February 25,1999

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OCAN029902 Page 2 cc:

Mr, Ellis W. Merschoff I"

Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One J

P.O. Box 310 London, AR72847

. Mr. Nick Hilton NRR Project Manager Region IV/ANO-1 j

U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North i

11555 Rockville Pike Rockville, MD 20852 Mr. Chris Nolan NRR Project Manager Region IV/ANO-2 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 i

I s

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' " Attachment to OCAN029902 Page 1 of18 General information i

Enterav Opeigtions. Inc. (EOI) Ouality Assurance Program Manual (OAPM)

In a letter dated April 30,1998 (CNRO-98/00013), EOI proposed the consolidation of the quality assurance (QA) plans at Arkansas Nuclear One (ANO), Grand Gulf Nuclear Station, River Bend Station, and Waterford 3 Steam Electric Station into one consolidated quality assurance plan manual. The April 30,1998, letter provided proposed changes to the quality assurance plans and discussions to justify the changes.

Following submittal of the April 30, 1998, letter and several meetings, telephone conferences and a supplement, the NRC approved the requested consolidation in a Safety Evaluation dated November 6,1998 (CNRI-98/00005). The cover letter for the Safety Evaluation states that the QAPM review has resulted in the need to include certain information in the Final Safety Analysis Report (FSAR) for the individual plants due to dislocations from the QAPM; these include fire protection program commitments, Independent Safety Evaluation Group commitments, and any technical specification (TS) information previously relocated to site specific QA program descriptions.

Title Changes In a letter dated November 10,1994 (from C. I. Grimes (NRC) to Lee Bush (WOG),

Brian Mann (CEOG), Clinton Szabo (BWOG) and Andrew Maron (BWROG), the NRC responded to a request from the Boiling Water Reactor /6 (BWR/6) owners group which would allow the use of generic personnel titles as provided by ANSI /ANS 3.1 in lieu of plant specific personnel titles in Section 2.0 " Safety Limits" and Section 5.0

" Administrative Controls" of the improved Standard Technical Specifications (ISTS). The Staff reviewed the proposal and found that lower case titles in lieu of all titles in the ISTS are acceptable.

In response to the November 10,1994 letter, the NEI Technical Specification Task Force (TSTF) initiated a generic change (TSTF-65) for the four owners group ISTS NUREGs (NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, and NUREG-1434) to allow the use of generic titles. TSTF-65 differed from the NRC's proposal in one respect.

The November 10,1994, letter suggested using a bracketed phrase "a specified corporate executive position" to identify the utility corporate officer to be notified in case of a Safety Limit violation. TSTF-65 proposed to use the phrase "the corporate officer with direct responsibility for the plant" (not bracketed) in lieu of insening a plant specific title.

TSTF-65, Revision 1 was approved by the NRC on December 2,1997, for incorporation in Revision 2 of the ISTS NUREGs.

Changes between TSTF-65 and TSTF-65, i

l Revision I concerned the consistent use of brackets in the ISTS Section 2.0 bases and had no bearing on the use of generic titles.

TSTF-65, Revision 1 inserted a Reviewer's Note in the ISTS to clarify the use of generic titles. Titles for members of the unit staff shall be specified by use of an overall statement i

b

'. Attachment to OCAN029902 Page 2 of18 l

referencing an ANSI Standard acceptable to the NRC Staff from which the titles were obtained, or an alternative title may be designated for this position. Generally, the first method is preferable; however, the second method is adaptable to those unit staffs requiring special titles because of unique organizational structures. The ANSI Standard shall be the same ANSI standard referenced in Section 5.3, Unit Staff Qualifications (For the ANO-1 and ANO-2 TSs, this would be Section 6.3 which references ANSI N18.1-1971). If alternative titles are used, all requirements of the TSs apply to the position with the alternate title as apply with the specified title. Unit staff titles shall be specified in the Final Safety Analysis Report or Quality Assurance Plan. Unit staff titles shall be maintained and revised using those procedures approved for modifying / revising the Final Safety Analysis Report or Quality Assurance Plan.

Generic Letter 88-06 (GL 88-06), " Removal of Organization Charts From Technical Specifications," provided guidance to address amendments that might be proposed for removing organizational charts from the administrative control requirements of the TSs.

In GL 88-06, the Staff determined that with appropriate changes to the administrative control requirements, the onsite and offsite organization charts could be removed. The appropriate changes involved the addition of general requirements that captured the essential aspects of the organizational stmeture that was defined by the onsite and offsite organization charts. Enclosure 1 to GL 88-06 identified those requirements considered by the Staff to be important to safety, and not covered by other specifications, to be retained in the TS.

l The EOI consolidated QAPM submittal, dated April 30,1998 (CNRO-98/00013),

proposed replacing plant specific management titles and descriptions with functional titles and descriptions. In the QAPM submittal, EOI stated that the relationship of the QAPM functional position descriptions and the plant specific titles would be contained in procedures as required by QAPM Section A.2 and detailed position descriptions and organization structure would be controlled in accordance with commitments to ANSI N18.7, Section 3.2. The proposed use of functional descriptions was approved by the NRC in the Safety Evaluation dated November 6,1998 (CNRI-98/00005).

Changes in accordance with the guidance contained in GL 88-06 were submitted for Arkansas Nuclear One Units One and Two (ANO-1 and ANO-2) by letters dated June 10, 1988. The proposed changes were approved by the NRC in Safety Evaluations dated August 18,1988 (Amendment 112 for ANO-1 and Amendment 87 for ANO-2).

l The proposed changes from specific titled positions to functional descriptions, as discussed in the changes below, retain the requirements identified in Enclosure 1 to GL 88-06.

i Fire Protection GL 86-10, " Implementation of Fire Protection Requirements," was issued by the NRC on April 24,1986. Section F states, in part, "..each licensee should include, in the FSAR i

', Attachm:nt to 0CAN029902

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Page 3 of18 update required by 10 CFR 50.7)(e) that will fall due more than 6 months afler the date of this' letter, the incorporation of the fire protection program that has been approved by the NRC, beluding the fire hazards analysis and major commitments that form the basis for the fire protection program." Section F goes on to state, "Upon completion of this effort, including the cenification required by 10 CFR 50.71(e)(2), the licensee may apply for an amendment to the operating license which amends any current license conditions regarding fire protection.. " Section F also allowed the deletion of technical specifications that would then be unnecessary due to the inclusion of the Fire Protection Program in the FSAR and the revision to the Operating License.

GL 88-12, " Removal of Fire Protection Requirements from Technical Specifications," was issued by the NRC on August 2,1988. GL 88-12 provided guidance for the preparation of license amendments to implement GL 86-10.

Proposed technical specifications, prepa ed in accordance with GL 86-10 and GL 88-12, were submitted for the ANO-1 and ANO-2 TSs by "0CAN109102, Application for Amends to Licenses DPR-51 & NPF-6,revising Tech Specs to Add NRC Std OL Conditions for Fire Protection & Relocating Fire Protection Requirements from Tech Specs to Sars,Per [[generic letter" contains a listed "[" character as part of the property label and has therefore been classified as invalid. & 88-12|letter dated October 15,1991]] (0CAN109102), and were subsequently approved by the NRC in a Safety Evaluation dated March 31,1992 (ANO-1 Amendment No.158 and ANO-2 Amendment No.132).

Requirements for Plant Safety Committee review of changes to Fire Protect on Program i

and implementing procedures and audits of the Fire Protection Program and i nplementing procedures were proposed for relocation from the ANO-1 and ANO-2 TSs to the Quality Assurance Manual Operations by "0CAN069401, Application for Amends to Licenses DPR-51 & NPF-6,relocating Controls Associated W/Review & Audit Functions from TS to QA Program & Incorporating Guidance in [[generic letter" contains a listed "[" character as part of the property label and has therefore been classified as invalid., Mods of TS Administrative Controls...For Emergency & Security Plans|letter dated June 20,1994]] (0CAN069401) and were subsequently approved by the NRC in a Safety Evaluation dated April 25,1995 (ANO-1 Amendment No.179 and ANO-2 Amendment No.160).

Additional Discussion of Specific Changes Changes to Overall Facility Operation Responsibility

{ANO-1 TS 6.1.1 and ANO-2 TS 6.1.1)

ANO-1 and ANO-2 TSs 6.6.1 define the responsibility for overall facility operation and the delegation of this responsibility during absences. ANO-1 and ANO-2 TSs 6.1.1 currently places this responsibility with the Vice President, Operations ANO.

The requirement to designate a management position in the onsite organization that is responsible for overall unit operations and has control over those onsite activities necessary for safe operation and maintenance of the plant was required to be retained in the TS by GL 88-06, Enclosure 1.

ISTS 5.1.1 designates the [ Plant Superintendent] as the responsible individual for this function. TSTF-65, Revision 1 revised ISTS Specification 5.1.1 to refer to the plant l

superintendent (lower case functional description instead of a specific titled position as has been previously discussed).

ANSI N18.1-1971, Section 3.2 defines the operating organization of a nuclear power plant.

This standard recognizes the broad categories of: managers, supervisors, t

l

. Attachment to OCAN029902 Pcge 4 of18 professional-technical, and operators-technicians-repairmen. Section 3.2.1 defir.es the functional level of manager as those to which are assigned broad responsibilities for direction of major aspects of a nuclear power plant. This functional levei generally includes the plant manager (plant superintendent or other title), his hae ar,istants, if any, and the principal members of the operating organization reporting directly to thi. plant manager and having overall responsibility for operation of the plant or for its maintenance or technical service activities. The QAPM, Section A.2.d.2 describes this functional position. In the ANO organizational stmeture, the Unit 1 Plant Manager and the Unit 2 Plant Manager are currently the titled positions whose responsibilities most closely resemble the responsibilities of TS 6.1.1.

The ANO-1 and ANO-2 TS 6.1.1 have been revised to refer to the functional description of "ANO-1 plant manager" and "ANO-2 plant manager," as applicable This change is acceptable because the most recent NRC guidance allows the use of the functional level of plant superintendent in the ISTS (TSTF-65, Revision 1), ANSI /ANS 18.1-1971, Section 3.2.1 equates the plant superintendent function with the plant manager function, and the titled positions associated with the proposed functional description are responsible for the overall operation of their respective unit. Proposed changes to ANO-1 and ANO-2 Specification 6.2.1.a will ensure that the position responsible for overall unit operation is documented in the Safety Analysis Report (SAR).

One additional administrative change has been incorporated in ANO-1 and ANO-2 TS 6.1.1. Reference to " facility" has been revised to " unit." This change is made for consistency with the existing ANO site in that the ANO facility consists of two units, ANO-1 and ANO-2, and individual TSs apply to the respective unit. Each plant specific TS also incorporates those specifications that would be considered to apply on a facility basis, such as corporate responsibility).

Incorporation of Control Room Command and Control Function (ANO-1 TS 6.1.2 and ANO-2 TS 6.1.2)

Specification 6.1.2 has been incorporated in the ANO-1 and ANO-2 TSs. This new specification requires that an individual with an active senior reactor operator (SRO) license be designated as responsible for the control room command function while the unit is above the cold shutdown condition. When the unit is not above the cold shutdown condition, this functional requirement may be satisfied by an individual with an active SRO or reactor operator license.

ISTS 5.1.2, upon which the proposed ANO-1 and ANO-2 TS 6.1.2 are based, requires the

[ Shift Supervisor] to be responsible for the control room command function. TSTF-65, Revision 1 did not address this functional description. GL 88-06, Enclosure 1 required the designation of those positions in the onsite organization that require a senior reactor operator license (SRO) or reactor operator (RO) license.

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[ Attichment to OCAN029902 Page 5 of18 10 CFR 50.54(l) requires the licensee to designate individuals to be responsible for

. dire' ting the activities oflicensed operators. These individuals shall be licensed as senior c

operators pursuant to Part 55 of 10 CFR 50. 10 CFR 50.54(m)(2)(ii) requires that each licensee have at its site a person holding ~ a senior operator license for all fueled units at the site who is assigned responsibility for overall plant operation at all times when there is fuel in any unit. If a single senior operator does not hold a senior operator license on all fueled units at the site, then the licensee must have at the site two or more senior operators, who in combination are licensed as senior operators on all fucled units.

10 CFR 50.54 m)(2)(iii) requires that when a nuclear power unit is in an operational mode t

other than cold shutdown or refueling, as defined by the unit's technical specifications, each licensee shall have a person holding a senior operating license for the nuclear power unit in the control room at all times. In addition to this requirement, for each fueled nuclear power unit, a licensed operator or senior operator shall be present at the controls at all times.

At ANO, the individual with the responsibility for the control room command function is currently the Shift Superintendent, not the Shift Supervisor as specified in the ISTS. The proposed ANO specification requires EOI to designate the titled position responsible for fulfilling the' control room command function, preventing future changes to the specification due to organizational changes. 10 CFR 50.54(m)(2)(iii) requires an SRO to be present in the control room when the unit is in an operational mode other than cold shutdown or refueling. The current ANO operating crew control room organization consists of the Shift Superintendent (SRO licensed), the Control Room Supervisor (SRO licensed), the Control Board Operator, Turbine (SRO or RO licensed), and the Control Board Operator, Reactor (SRO or RO licensed).

In the absence of the Shift Superintendent, the Control Room Supervisor is designated as responsible for the control room command function.

Proposed Aanges to ANO-1 and ANO-2 TS 6.2.1.a will ensure that the position

. responsible for the control room command function is documented in the Safety Analysis Report (SAR). The combination of 10 CFR 50.54(m)(2)(iii), ANO-1 and ANO-2 TS 6.1.2, and documentation of the control room command function in the SAR will ensure that the appropriate individual with the appropriate qualifications is designated as responsible for the control room command function when the units are in an operational

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mode other than cold shutdown or refueling.

When the a unit is in cold shutdown or refueling,10 CFR 50.54, Table I specifies a minimum licensed operator staffing requirement of 1 SRO and 1 RO. The proposed ANO-1 and ANO-2 TS 6.1.2 requires that an individual with an active SRO or RO license be designated as responsible for the control room command function when the unit is in the cold shutdown or refueling conditions. The combination of 10 CFR 50.54, Table 1, ANO-1 and ANO-2 TS 6.1.2, and documentation of the control room command function in the SAR as required by the proposed ANO-1 and ANO-2 TS 6.2.1.a will ensure that the appropriate individual with the appropriate qualifications is designated a. responsible

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Attachment to OCAN029902

. Page 6 of18 for the control room command function when the units are in the cold shutdown or refu'eling conditions.

Channes to Ornanizational Descriotion Reauirements (AN -1 TS 6.2.1.a and ANO-2 TS 6.2.1i)

ANO-1 and ANO-2 TS 6.2.1.a currently require that lines of authority, responsibility, and communication shall be established and de6ned. These relationships shall be documented

- and updated, as appropriate, in the form of organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements shall be documented in the QA Manual Operations. This specification was required by GL 88-06,, which allowed the removal of onsite and offsite organization charts from the TS.

ISTS 5.2.1 also specifies this same requ'rement, with minor presentation changes. TSTF-65, Revision I revised the last sentence ofISTS 5.2.1 from; "These requirements shall be documented in the [FSAR]" to read; "These requirements including the plant speci6c titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications shall be documented in the [FSAR/QA Plan]."

EOI proposes to revise ANO-1 and ANO-2 TS 6.2.1.a to incorporate text similar to that inserted in ISTS 5.2.1 by TSTF-65, Revision 1, and to require the delineation of these requirements in the applicable SAR. - This requirement ensures that the ANO organizational stmeture is defined and that appropriate titled positions are assigned to fulfill the functional responsibilities required by the TS.

Placing this information in the replicable SAR was previously reviewed and approved by the NRC in the approval of the EOI consolidated QAPM in a Safety Evaluation dated November 6,1998 (CNRI-98/00005).

.Channes to General Mananer. Plant Operations Responsibility Rmuirements (ANO-1 TS 6.2.1.b and ANO-2 TS 6.2.1.b)'

'ANO-1 and ANO-2 TS 6.2.1.b currently require the General Manager, Plant Operations to be responsible for overall unit safe operation and shall have control over those onsite activities necessary for safe operation and maintenance of the plant. This specification was required by GL 88-06, Enclosure 1, which allowed the removal of onsite and offsite crganization charts from the TS.

ISTS 5.2.1.b specifies the [ Plant Superintendent] as responsible for overall safe operation of the plant and having control over those onsite activities necessary for safe operation and

- maintenance of the plant. ISTS 5.2.1.b was revised by TSTF-65, Revision 1, to replace the reference to the specific title of the position with the functional description of plant manager.-

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' Attachment to OCAN029902 Page 7 of18 EOI proposes to revise the ANO-l' and ANO-2 TS 6.2.1.b reference to the General Manager, Plant Operations with references to the functional description of the ANO-1 plant manager and the ANO-2 plant manager, as applicable. ANSI N18.1-1971, Section -

3.2 defines the operating organization of a nuclear power plant. This standard recognizes the broad categories of managers, supervisors, professional-technical, and operators-technicians-repairmen. Section 3.2.1 defines the functional level of manager as those to which are assigned broad responsibilities for direction of major aspects of a nuclear power plant. This functional level generally includes the plant manager (plant superintendent or other title), his line assistants, if any, and the principal members of the operating organization reponing directly to the plant manager and having overall responsibility for operation of the plant or for its maintenance or technical service activities. In the ANO organizational stmeture, the Unit 1 Plant Manager and the Unit 2 Plant Manager are currently. the titled positions whose responsibilities most closely resemble.the' responsibilities of TS 6.2.1.b.

The QAPM, Section A.2.d.2 describes this functional position.

This change is acceptable because the most recent NRC guidance allows the use of the functional level of plant manager in the ISTS (TSTF-65, Redsion 1), ANSI /ANS 18.1-1971, Section 3.2.1 equates the plant manager function to the direction of major aspects of a nuclear power plant, and the titled positions associated with the proposed functional description are responsible for the overall operation of their respective unit. Proposed

' changes to ANO-1 and ANO-2 Specification 6.2.1.a "ill ensure that the position responsible for overall safe operation of the unit is dor ented in the Safety Analysis Report (SAR).

Changes to Coroorate Responsibility Reauirements (ANO-1 TS 6.2.l.c and ANO-2 TS 6.2.1.c)

ANO-1 and ANO-2 TS 6.2.1.c define the corporate responsibility for overall plant nuclear safety. 'ANO-1 and ANO-2 TSs 6.2.1.c cuarently place this responsibility with the Vice President, Operations ANO. The requirement'to designate a corporate position that is responsible for overall plant nuclear safety was required to be retained in the TS by GL 88-06, Enclosure 1.

'ISTS 5.2.1.c requires that the [a specified corporate executive position] have this responsibility : In lieu of specifying a' titled position for this responsibility, TSTF-65, Revision ~ 1, revised this requirement to refer to the functional description of a specified corporate officer.

EOI proposes to revise ANO-1 and ANO-2 TSs 6.2.1.c to refer to a specified corporate executive. Although the proposed specification refers to a specified corporate executive instead of the specified corporate officer specified by the ISTS, the two requirements are Lconsidered to be equivalent. This function is currently performed by the Vice President, Operations ANO. The QAPM, Section' A.2.c.1 describes this functional position. This

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[ Attachment to OCAN029902 3

Page 8 of18 change is acceptable because the most recent NRC guidance allows the use of a functional level in lieu of a specific position title ISTS (TSTF-65, Revision 1), and the titled position l

associated with the proposed functional description is responsible for the overall plant nuclear safety. Proposed changes to ANO-1 and ANO-2 Specification 6.2.1.c will ensure that the position responsible for overall plant nuclear safety of the unit is documented in i

the Safety Analysis Report (SAR).

Changes to Facility Staff -

(ANO-1 TS 6.2.2 and ANO-2 TS 6.2.2) 1 An administrative change has been incorporated in the title for ANO-1 and ANO-2 i

TSs 6.2.2. Reference to " facility" has been revised to " unit." This change is made for ~

i consistency with the existing ANO site in that the ANO facility consists of two units,

{

. ANO-1 and ANO-2, and individual TSs apply to the respective unit. Each plant specific TS also incorporates those specifications that would be considered to apply on a facility basis, such as corporate responsibility.

Chsnges to Senior Reactor Operator Requirements for Facility Staff f

(ANO-1 TS 6.2 2 and ANO-2 TS 6.2.2.h) j ANO-1 TS - 6.2.2, in part, and ANO-2 TS 6.2.2.h currently require the Manager, l

Operations and Shift Supervisor to hold a senior reactor operator license.

The requirement to designate positions that require an SRO or RO license was required to be i

retained in the TS by GL 88-06, Enclosure 1.

i ISTS Section 5.2.2 does not contain a requirement for the Shift Supervisor to hold an SRO license. ISTS Specification 5.1.2 delineates the responsibility for the control room command function. 10 CFR 50.54(1) requires licensees to designate individuals to be responsible for directing the licensed activities oflicensed operators. 10 CFR 50.54(1) also i

requires these individuals to be licensed as senior operators pursuant to 10 CFR 50.55.

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~ Incorporation of a control room command function designation by an individual with an SRO license in ANO-1 and ANO-2 TS 6.1.2 has been previously discussed.

EOI proposes to delete the requirement for the Shift Supervisor to hold an SRO license from ANO-1 TS 6.2.2 and ANO-2 TS 6.2.2.h.

The combination of 10 CFR 50.54(1),

ANO-1 and ANO-2 TS 6.1.2, and documentation of the control room command function in the SAR as required by the proposed ANO-1 and ANO-2 TS 6.2.1.a will ensure that the appropriate individual with the appropriate qualifications is designated as responsible for the control room command function.

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'ISTS Specification 5.2.2.f requires the [ Operations Manager or Assistant Operations Manager] to hold an-SRO license. TSTF-65, Revision 1 revised this requirement to remove the references to specific titled positions ISTS Specification 5.2.2.f was revised to refer to the functional descriptions of the operations manager or assistant operations

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manager.

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l Attachmer.t to OCAN029902 :

Page 9 of18 EOI proposes to revise the ANO-1 TS 6.2.2 and ANO-2 TS 6.2.2.f requirements for the Operations Manager.to hold an SRO license from the specific titled position to a i

functional position description as implemented in ISTS 5.2.2.f by TSTF-65, Revision 1.

This proposed change also allows this requirement to be satisfied by the individual l

fulfilling an operations middle manager function. The functional level of manager is described in ANSI N18.1-1971, Section 3.2.1.

The flexibility provided by requiring either the operations manager or operations staff

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middle manager to hold an SRO license provides an alternative during periods when the operations manager position is temporarily vacant or staffed with an individual who is not d holder of an SRO license. Typically, the operations middle manager would be any supervisory position in the operations staff above the shift superintendent and below the operations. manager.

Currently, this functional description could be fulfilled by the Coordinator, Operations Support or the Supervisor, Operations Standards. Either of these individuals, when they are holders of an SRO license, can provide direct support to the operations manager as necessary to fulfill the operations manager's duties. This i

proposed change p'.nes assurance that an SRO licensed individual in the operations i

management organization is available to provide direction for the licensed activities of

' licensed individuals, per 10 CFR 50.54(1). The proposed ANO-1 and ANO-2 TS 6.2.1.a requirements ensure that the titled positions responsible for these functional requirements are delineated in the SAR.

Deletion of Shift Technical Advisor (STA) Oualifications (ANO-1 TS 6.! []

ANO-1 TS 6.3.1 currently specifies the minimum qualifications of the facility staff, the designated radiation protection manager, and the Shift Technical Advisor. EOI proposes i

to delete the qualification requirements for the STA from the ANO-1 TS. This deletion i

results'in consistency between the ANO-1 and ANO-2 TSs, as the ANO-2 TS does not contain a similar requirement. Also, the ISTS does not specify minimum qualification requirements for the STA. The minimum qualification requirements specified for the STA i

in ANO-1 TS 6.3.1 are provided in' ANO-1 SAR Section 12.2.2.2.C. Since the ANO-1

'SAR is maintained under the ANO 10 CFR 50.59 process, there is adequate assurance that the requirements will continue to be maintained.

Changes to STA Reauirements (ANO-1 Table 6.2-1 and ANO-2 TS 6.2.2.f and Table 6.2-1)

ANO-1 and ANO-2 Tables 6.2-1 currently contain requirements that the minimum shift crew composition includes one Shift Technical Advisor when the unit is above cold shutdown (ANO-1) or in Modes 1,2, 3, or 4 (ANO-2). The layout of the tables lead to the interpretation that the STA is a position on the shift crew in addition to the two required SROs. The STA function is currently performed by the Shift Engineers on both

' ANO units.

l Attachment to 0CAN029902

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Page 10 ofI8

GL'86-04, " Policy Statement On Engineering Expertise On Shift," dated February 13, j

1986, provided the NRC's position on implementation of engineering expedise on the

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operations shift crews. The Policy Statement offered licensees two options for meeting i

the' requirements for providing' engineering expertise required by NUREG-0737, item I.A.1,1 and meeting the licensed operator staffing requirements of 10 CFR 50.54(m)(2).

Option 1 provided for the elimination of the separate STA position by allowing licensees to combine one of the required SRO_ positions with the STA position into a dual-role (SRO/STA) position. Option 2 stated that a licensee could continue to use an NRC-j approved STA program while meeting licensed operator staffing requirements. Licensees were allowed to use either option on shW. In the Policy statement, the Commission encouraged licensees to move toward the dual-role (SRO/STA) position, with the i

eventual goal of the Shift Supervisor serving in the dual role.

t EOl proposes to revise the ANO-1 and ANO-2 TSs to allow the use of either option i

allowed by the Policy Statement. The requirement for the STA has been deleted from ANO-1 and ANO-2 Table 6.2-1.

The ANO-1 TS has been revised to incorporate a requirement (Table 6.2-1 Additional Requirement 5) that above the cold shutdown l

l condition, an individual shall provide advisory technical support for the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit. Proposed Additional Requirement 5 also requires t

this individual to meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift.

j The ANO-2 TS has been revised to incorporate a requirement (TS 6.2.2.f) that in Modes 1, 2, 3, or 4, an individual shall provide advisory technical support for the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with i

regard to the safe operation of the unit. The proposed TS 6.2.2.f also requires this individual to meet the qualifications specified by the Commission Policy Statement on i

Engineering Expenise on Shift.

I The proposed changes result in clarification, consistent with the guidance provided in the Policy Statement, in that they do not imply that the STA may not be one of the SROs

. required by Table 6.21 and 10 CFR 50.54(m)(2). However, the proposed ANO-1 and

_ ANO-2 TSs still require an individual to provide a function equivalent with the STA i

L position of the Policy Statement. Use of a general functional statement allows flexibility in J

the title of the position fulfilling the functional responsibility of engineering expertise.

i Proposed TS 6.2.1.a requires the delineation of the position title fulfilling the function of i

engineering expertise on shift in the unit's SAR. Since changes to the SAR are controlled under the ANO 10 CFR 50.59 process, there is adequate assurance that the requirements i

_ ill continue to be maintained.

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' b Attachment to OCAN029902 Page 11 of18 j

l Deletion of Retraining and Reolacement Trainina Pronram Requirements

' (ANO-1 TS 6.4.1 and ANO-2 TS 6.4.1) j

- ANO-1 and ANO-2 TSs 6.4.1 currently specify requirements for the retraining and replacement training program for the unit staff. The ISTS does not contain a similar 1

requirement for the retraining and replacement training program. EOI proposes to delete the ANO-1. and ANO-2 TS 6.4.1 requirements associated with the retraining and replacement training program.

)

1 A requirement to establish and maintain and implement traimng programs is contained m Section 5.b of the EOI QAPM. A description of the replacement training program is contained in ANO-1 SAR Section 12.2.2 and ANO-2 SAR Section 13.2.2. A description 1 of the retraining program is contained in ANO-1 SAR Section 12.2.3 and ANO-2 SAR Section 13.2.3. Since the EOI QAPM requires training programs to be established and maintained, and since changes to the ANO-1 and ANO-2 SARs are controlled under the i

ANO 10 CFR 50.59 process, there is adequate assurance that the requirements for the retraining and replacement training programs will continue to be' maintained.

l Deletion of Fire Briande Trainina Program Reauirements (ANO-1 TS 6.4.2) l i

ANO-1 TS 6.4.2 currently specifies the requirements for the maintenance of the fire brigade training program. The ISTS contains no similar requirement. EOI proposes to i

delete the ANO-1 TS 6.4.2 requirements associated with the fire brigade training program.

i GL 88-12 required the Administrative Controls section of the TS to be augmented by the inclusion of requirements for the'onsite review group to' review the Fire Protection Program and implementing procedures and the submittal of reccumended changes to the

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offsite review group; and a requirement to establish, impleme:S and maintain written j

. procedures that implement the Fire Protection Program was added However, GL 88 )

allowed the relocation of the fire brigade staffing requirements and did.not specifically

)

require the retention of fire brigade training requirements in the TS.

j

' ANO-1 SAR Section 9.8.3.2 provides a detailed description of the ANO fire brigade training program. ' ANO-1 SAR, Appendix' 9D Section 7.2 states that the Fire Brigade i

Training program shall be maintained under the direction of the Director, Training and.

Emergency Planning. - Since changes to the ANO-1 SAR are controlled under the ANO 10 CFR 50.59 process, there is adequate assurance that the requirements for the fire brigade training program will continue to be maintained.

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. Attachment to OCAN029902 Page 12 of18 -

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iDeletion ofReportable Event (Occurrence) Action i

(ANO-1 TS 6.6 and ANO-2 TS 6.6) i t

i 6

'ANO-1 and ANO-2 TSs 6.6 currently specify the reponing and review requirements for reportable events (occurrences).

The ISTS contains no similar requirement.

EOI l

proposes to delete the ANO-1 and ANO-2 TS 6.6 requirements associated with reportable event (occurrence) actions.

' 10 CFR 50.73 requires licensees ~to submit a Licensee Event Report (LER) for certain events. described therein within 30 days after the discovery of the event. The curret ANO-1 TS 6.6.1 requirement that a reportable event is any of those conditions specified in j

Section 50.73 to 10 CFR 50, is duplicative of the regulation. The current ANO-1 TS'.

~

6.6.2.a and ANO-2.TS 6.6.1.a actions to submit a report to the Commission pursuant to

' the requirements of Section 50.73 to 10 CFR 50, is also duplicative of the regulation.

The requirements for the review of each reportable event by the Plant Safety Committee (PSC) and submittal of the results of this review to the Safety Review Committee (SRC)._

and the Vice President, Operations ANO, specified by ANO-1 TS 6.6.2.b and ANO-2 TS i

6.6.1.b are also in the EOI QAPM. The QAPM, Table 1, Regulatory Commitment Item i

C.8, clarifies the ANO. commitment' to Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2, dated February 1978. ANSI N18.7, Section 4.3.4(4), requires review by the independent review body of violations, deviations, and reportable events, which require reporting to the NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The clarification states that in the place of the requirements of ANSI N18.7, Section 4.3.4(4), the on-site (PSC) and off-site (SRC) safety review committees shall review i

facility opentions to detect potential. nuclear safety hazards and all reports *nade in accordance with '10 CFR 50.73. The Vice President, Operations ANO serves as the 3

chairman of the SRC.

Since the existing regulations (10 CFR 50.73) contain requirements to submit an LER for j

- any reportable event, as defined within 10 CFR 50.73, the deletions of ANO-1 TSs 6.6.1 l

and 6.6.2.a and ANO-2 TS 6.6.1.a are considered to be administrative in nature. Since the

. EOI QAPM contains a clarification that all reports made in accordance with 10 CFR 50.73 l

must be reviewed by the.on-site and off-site safety review committees (PSC and SRC),

and since changes to the QAPM are controlled under the 50.54(a)(3), there is adequate assurance that the requirements will continue to be maintained.

Deletion of Procedure Channe Review Details (ANO-1 TS 6.8.2 and ANO-2 TS 6.8.2) i

(

ANO-1 and ANO-2 TSs 6.8.2 currently require that all procedures required by ANO-1 and ANO-2 TSs 6.8.1, and changes to intent thereto, shall be reviewed and approved as required by the QAMO prior to implementation and reviewed periodically as set forth in administrative procedures. The ISTS does not contain a similar requirement. EOI l

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i proposes to delete the ANO-1. and: ANO-2 TS 6.8.2 requirements associated with procedure review and approval.

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The: EOI.QAPM commits to Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 2, dated Februay 1978. Regulatoy Guide 1.33, Revision 2, requires compliance with the requirements of ANSI N18.7-1976. Section l

5.2.15 of ANSI N18.7-1976 discusses the review, approval, and control of procedures.

i The EOI consolidated QAPM, in Section B.14, requires that a program be established and l

implemented to control the development, review, approval, issue, use, and revision of documents.. This section also requires the review of revisions of controlled documents for l

I adequacy and the approval for release by the same organization that originally reviewed.

and approved the documents or by a designated organization that is qualified and i

knowledgeable.

The EOI QAPM commits to Section 5.2.15 of ANSI N18.7-1976 with two exceptions, j

discussed in Table 1 Regulatory Commitments. These two exceptions are: 1) the required j

procedure reviews following occurrences discussed in ANSI N18.7-1976 Section 5.2.15, i

. paragraph 3, sentence 3, are determined and controlled in accordance with the QAPM l

Section A.6, Corrective Action, instead of this section; and 2) instead of the review of j

plant procedures by an individual knowledgeable in the area affected by the procedure no -

l

- less frequently than every two years to determine if changes are necessary or desirable, the j

QAPM sta'es that controls are in effect to ensure that procedures are reviewed for j

possible revision upon identification of new or revised source material potentially affecting the intent of procedures. These exceptions were approved by the NRC in the QAPM i

Safety Evaluation dated November 6,1998.

i The deletion of the ANO-1 and ANO-2 TS 6.8.2 requirements for procedure review and j

approval prior to implementation and periodic review is acceptable since the EOI QAPM

requirements, and the requirements contained in ANSI N18.7-1976, provide adequate l

assurance that these requirements.will continue to be maintained.

Deletion ofInterim Anoroval Process for Procedure Channes (ANO-1 TS 6.8.3 and ANO-2 TS 6.8.3) i ANO-1 and ANO-2 TSs 6.8.3 currently provide the requirements for the implementation l

of procedure change, prior to obtaining the reviews and approvals required by the current ANO-1 and ANO-2 TSs 6.8.2. The ISTS contains no similar requirement. EOI proposes to delete the ANO-1 and ANO-2 TS 6.8.3 requirements.

l i

~ The EOI QAPM commits =to Regulatory Guide 1.33, Quality Assurance Program

)

Requirements (Operation), Revision 2, dated February 1978. Regulatory Guide 1.33, l

. Revision 2, requires compliance with the requirements of ANSI N18.7-1976. Section 5.2.2 of ANSI N18.7-1976 discusses procedure adherence, and methods by which temporay changes may be made to approved procedures. The EOI QAPM commits to 3

ANSI N18.7-1976, Section 5.2.2, with two exceptions, discussed in Table 1 Regulatory

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  • j Attachment to OCAN029902 Page 14 of18

]

Commitments. These two exceptions are: 1) the person who holds a senior reactor operators license for the affected unit and approves a temporary change to a procedure is

)

not required to be in charge of the shift; and 2) in addition to the temporary procedure l

change process described for changes which clearly do not change the intent of a procedure, temporary changes which may change the intent of a procedure may be made following the process described in ANSI N18.7-1976, Section 5.2.2, except that the person normally responsible for approving revisions to the procedure is the approval authority for the change. These exceptions were approved by the NRC in the QAPM Safety Evaluation dated November 6,1998.

The deletion of the ANO-1 and ANO-2 TS 6.8.3 requirements for the implementation of j

procedure changes prior to obtaining the reviews and approvals required by the cunent l

ANO-1 and ANO-2 TSs 6.8.2 is acceptable since the EOI QAPM requirements, and the requirements contained in ANSI N18.7-1976, provide adequate assurance that these requirements will continue to be maintained.

Deletion of Record Retention Requirements (ANO-1 TS 6.9 and ANO-2 TS 6.10) j ANO-1 TS Section 6.9 and ANO-2 TS Section 6.10 currently specify the requirements for the retention of records. Appendix B to 10 CFR Part 50 (Section XVII) requires that;

" Sufficient records shall be maintained to furnish evidence of activities affecting quality.

The records shall include at least the following: Operating logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and material analyses. The records shall so include - closely-related data such as qualifications of personnel,

_ procedures, and equipment. Inspection and test records shall, as a minimum, identify the l

inspector or data recorder, the type of observation, the results, the acceptability, and the j

action taken in connection with any deficiencies noted. Records shall be identifiable and l

retrievable.

Consistent with applicable regulatory requirements, the applicant shall-i establish requirements concerning record retention, such as duration, location and assigned responsibility." The ISTS does not contain similar requirements for record l

retention. EOI proposes to delete the ANO-1 TS Section 6.9 and ANO-2 TS Section - 6.10 requirements associated with record retention.

The EOI consolidated QAPM submittal letter dated April 30,1998, contained mark-up pages of the ANO-1 TS 6.9 and ANO-2 TS 6.10 requirements associated with record j

- retention showing their deletion from the ANO-1 and ANO-2 TSs. The proposed deletion j

of this information from the QAPM was discussed as a redaction in the level of detail.

Section B.15.a of the EOI QAPM requires the establishment and implementation of a

_ program to ensure that sufficient records of items and activities are generated and j

maintained to reflect completed work. Records associated with design, engineering, l

procurement, manufacturing, construction, inspection and test, installation, pre-operation, startup,. operations, maintenance, modification, decommissioning, and audits are

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controlled under this program. Section B.15.c of the QAPM states that additional details m

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, Attachment to OCAN029902

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Page 15 of18 concerning record requirements may be found in the Regulatory Guides and associated t

Staddards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guide 1.88,

" Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records"). Table 1 of the QAPM provides, under Regulatory Commitment Item J, clarifications and exceptions to Regulatory Guide 1.88, Revision 2, dated October 1976.

None of the clarifications and exceptions have any bearing on the types of records that are required to be retained.

Regulatory Guide 1.88, Revision 2, October 1976, states that the requirements and guidelines for ' collection, storage, and maintenance of nuclear power plant quality assurance records that are included in ANSI N45.2.9-1974 are acceptable to the NRC Staff and provide an adequate basis for complying with the pertinent quality assurance requirements of Appendix B to.10 CFR Part 50 with one condition that bears on documents required to be included. Subdivision 1.5 of ANSI N45.2.9-1974 states, "'Other documents that are required to be included as part of this standard are either identified at the point of reference or described in Section 8 of this standard.' The specific applicability or acceptability of these listed documents has been or will be covered separately in other L

regulatory guides or in Commission regulations where appropriate."

Section 3.2.7 of ANSI N45.2.9-1974 discusses retention of records. ANSI N45.2.9-1974 provides a list of the types of quality control records and their minimum retention periods l

in Appendix A. For records not listed in Appendix A, ANSI N45.2.9-1974 states that the type of record most nearly describing the record in question should be followed with respect to its retention period. In addition, Section 3.2.7 requires that the organization i

l responsible shall establish' in writing the retention times of records not listed in i

Appendix A.

l The deletion ~ f the ANO-1 TS 5.9 and ANO-2 TS 6.10 requirements for the retention of o

l records is acceptable since the EOI QAPM requirements, and the requirements contained 7

in ANSI N45.2.9-1974 provide adequate assurance that appropriate records will continue

[

to be retained.

Changes to High Radiation Locked Door Controls (ANO-1 TS 6.11.2 and ANO-2 TS 6.13.2)

ANO-1 TS 6.11.2 and ANO-2 TS 6.13.2 currently contain a requirement that access to locked high _ radiation levels,' in which the intensity of radiation is greater than l_

_1000 mrem /hr, shall be maintained under the administrative control of the Shift Supervisor on duty and/or the designated radiation protection ~ manager. ISTS Specification 5.7.2 l

contains a similar requirement that keys shall be maintained under the administrative control of the Shift Foreman on duty or health physics supervision. EOI proposes to F

replace _the reference to_ the specific titled position of " Shift Supervisor" with a more

~

generic functional description of " shift supervisor." In an SER dated June 21, 1989, ANO-1 TS Amendment 124 and ANO-2 TS Amendment 98, the NRC approved changes to ANO-1 TS 6.11.2 and ANO-2 TS 6.13.2 which replaced the specific title of " Health a

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- Page 16 of 18

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Physics Superintendent" with a reference to the functional description of " designated radiation protection manager."

' ANSI. N18.1-1971 Section 3.2.2 defmes supervisors as those persons principally responsible for directing the actions of operators, technicians, or repairmen. Those positions usually designated as intermediate and first line supervisors are included in this category. At ANO, this function is fulfilled by the Shia Superintendent or, in his absence, the Control Room Supervisor. The proposed changes to ANO-1 and ANO-2 TSs 6.2.1.a j

. will ensure that the titled position responsible for the shia supervisor function is delineated in the applicable unit's SAR.

l The proposed ANO-1 and ANO-2 TSs still require individuals to maintain administrative

control over access into locked high radiation areas. - Use of a general functional statement-allows flexibility in the title of the position fulfilling the functional responsibility of shift i

supervisor.

ANSI N18.1-1971 states that supervisors are usually designated as intermediate and first line supervisors. Proposed TS 6.2.1.a requires the delineation of the position title fulfilling the function of shift supervisor in the unit's SAR. Since changes to j

the SAR are controlled under the ANO 10 CFR 50.59 process, there is adequate t

assurance that the requirements will continue to be maintained.

i Changes to Monthly Operating Report (ANO-l TS 6.12.2.3 and ANO-2 TS 6.9.1.6)

On May 15,1997, the NRC issued GL 97-02, " Revised Contents of the Monthly j

Operating Report." In GL 97-02, the NRC requested the submittal ofless information in

{

the monthly operating report. Specific contents of the monthly operating repott (MOR) are provided in Attachment I to GL 97-02. The current ANO-1 description of the MOR j

requires the submittal ofinformation in excess of the information requested in GL 97-02.

Specifically, the current ANO-1 description r3 quires the submittal of average daily unit power level and power reductions. Neither of these pieces ofinformation are included in GL 97-02, Attachment 1.

lIn addition to revising the MOR description as a result of the implementation of GL 97-02, Entergy Operations proposes further revision to the MOR descriptions for ANO-1 and ANO-2. In addition to a specific list ofinformation to be supplied, the ANO-1 MOR~ description contains a requirement that the MOR be submitted to the Director, Office of Management and Program Analysis, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, with a copy to the appropriate Regional Office. The ANO-2 MOR description contains a requirement that the MOR be submitted to the Director, Office' of Resource Management, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555. with a copy to the Regional Office. The ISTS, specifically NUREG-1430 and NUREG-1432, do not contain this same level of detail.

The ANO-1 and ANO-2 MOR descriptions have been revised to implement the ISTS description. GL 97-02 provides guidance as to the information that must be provided to 1

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Page 17 of18 j

the NRC. ; Additionally,10 CFR 50.4(a) and 10 CFR 50.4(b)(1) provide requirements for l

l the ' distribution of reports.

Specifically,10 CFR 50.4(b)(1) requires repons to be submitted as follows:

the signed original to the Nuclear Regulatory Commission, i

(-

Document Control Desk, Washington, D.C. 20555, one copy to the appropriate Regional l

Office, and one copy to the NRC Resident Inspector.

The ISTS MOR description contains a bracketed phrase " including documentation of all challenges to the pressurizer power operated relief valves or pressurizer safety valves."

l Bracketed information is expected to be retained by licensees during the conversion process if the information exists in their pre-conversion TS. Neither the ANO-1 or ANO-2 TS require the submittal of this information on a monthly basis. ANO-1 TS 6.12.2.4 requires all challenges to the pressurizer electromatic relief valve (ERV) and i

pressurizer safety valves to be reported annually. ANO-2 TS 6.9.1.5.c requires the t

documentation of all challenges to the pressurizer safety valves on an annual basis (ANO-2 does not have a pressurizer power operated relief valve). These requirements are not revised by this submittal. Since the submittal ofinformation related to challenges to the pressurizer power operated relief valve and pressurizer safety valves on a monthly basis is not required by the current ANO-1 and ANO-2 licensing basis, this phrase is not i

incorporated.

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The proposed changes are consistent with the description of the monthly operating report contained in the ISTS. GL 97-02 provides sufficient guidance to ensure that the necessary j

level ofinformation is supplied to the NRC on a monthly basis. 10 CFR. 50.4 provides sufficient guidance to ensure proper distribution of the monthly operating report.

Therefore, the proposed changes are acceptable.

Deletion of Soecial Reports Concerning Inoperable Fire Detectionhstrumentation and i

Inoperable Fire Suppression Systems (ANO-1 TSs 6.12.5.'n. 6.12.5.i and ANO-2 TSs 6.9.2.e and 6.9.2.f.)

. ANO-1 Specification 6.12.5.h and ANO-2 Specification 6.9.2.e currently require the submittal of special reports in the event of inoperable fire detection instmmentation is inoperable for longer than allowed by the Fire Protection Program provisions which were removed from the TSs in accordance with GL 88-12 (ANO-1 Amendment 158 and ANO-

2. Amendment 132). ANO-1 Specification 6.12.5.i and ANO-2 Specification 6.9.2.f currently require the submittal of special reports in the event fire suppression systems are q

inoperable for longer than allowed by the Fire Protection Program provisions which were removed from the TSs in accordance with GL 88-12. The submittal of these special 1

repods is not required by the ISTS, and additionally, was not required to be retained in the TSs by Generic Letter 88-12. EOI proposes to delete the requirements to submit special j

reports. in the event fire' detection instrumentation or fire suppression systems are inoperable for longer than allowed by the Fire Protection Program.

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[ Attachment to OCAN029902 Page 18 of18 As indicated in Generic Letter 88-12; "In Generic Letter 86-10, licensees were reminded of their responsibilities to report deficiencies in the Fire Protection Program which meet the criteria of 10 CFR 50.72 and 10 CFR 50.73.

Other conditions which represent deficiencies of this program and are not encompassed by the above reporting criteria should be evaluated by the licensees to determine appropriate con ective action."

In association with this change, the ANO-1 and ANO-2 Safety Analysis Reports will also be revised to remove Special Reporting requirements from the Fire Protection System

. Operability, Surveillance, and Administrative Requirements (ANO-1 'and ANO-2 SARs, Section 9D). The following SAR sections: " Fire Detection Instrumentation," (ANO-1 SAR 9D.I.3.B and ANO-2 SAR 9D.I.l.C.2), " Fire Suppression Water Systems," (ANO-1 SAR 9D.2.3.B and ANO-2 SAR 9D.2.1.C), " Fire Suppression Sprinkler Systems," (ANO-1 SAR 9D.3.3.B and ANO-2 SAR 9D.3.1.C), and " Control Room and Auxiliary Control Room Halon Systems" (ANO-1 SAR 9D.4.3.b) require submittal of.special reports in the event an inoperable condition is not restored to operable status within a specified time.

These requirements will be modified from "or prepare and submit a Special Report...

outlining..." in each location where a Special Report is currently required to indicate "or document the deficiency in a condition report outlining.. "

The proposed changes will ensure that inoperable components that are not restored to service within a period of time specified by the ANO-1 and ANO-2 SARs are documented in the ANO Corrective Action Program. Each condition is evaluated for its effect on plant safety, and the appropriate corrective actions are developed. Any deficiency which is reportable under 10 CFR 50.72 or 10 CFR 50.73, is reported in accordance with these regulations.

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