ML18100B003
| ML18100B003 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/13/1994 |
| From: | Miltenberger S Public Service Electric & Gas Co, of New Jersey |
| To: | NRC/IRM |
| Shared Package | |
| ML18100B004 | List: |
| References | |
| LCR-94-05, LCR-94-10, LCR-94-5, NLR-N94051, NUDOCS 9404190197 | |
| Download: ML18100B003 (62) | |
Text
Public Service Electric and Gas Company Steven E. Miltenberger Public Service Electric and qas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4199 Vice President and Chief Nuclear Officer APR 13 1994*
NLR-N94051 LCR 94-05 LCR 94-10 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REQUEST FOR LICENSE AMENDMENT HOPE CREEK GENERATING STATION AND SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. NPF-57, DPR-70 AND DPR-75 DOCKET NOS. 50-354, 50-272 AND 50-311 This letter submits applications for Amendment to Appendix A of Facility Operating Licenses NPF-57, DPR-70 and DPR-75 for the Hope Creek Generating Station and Salem Generating station Units Nos. 1 and 2, respectively.
The applications for amendment are being filed in accordance with 10 GFR 50.90.
Pursuant to the requirements of 10 CFR 50.91(b) (1), a copy of the amendment requests have been sent to the State of New Jersey.
The proposed changes revise the Quality Assurance (QA) audit frequencies in the Hope Creek and Salem Unit Nos. 1 and 2 Technical Specifications.
These revisions permit a biennial audit frequency and transfer subsequent control over the audit program to the Updated Final Safety Analysis Report (UFSAR),
Section 17.2.18, "Audits."
In addition, a 25% extension to the biennial frequency is proposed so that the interval between audits may be extended up to a maximum of 30 months (i.e., a 6 month extension), if necessary.
These proposed changes will provide added flexibility in scheduling audits and facilitate resource allocation to areas with perceived weaknesses.
The proposed changes also remove Technical Specification review and audit requirements for the Emergency and Security Plans based on guidance provided by the NRC Staff in Generic Letter 93-07 "Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans."
Review and audit requirements for the Emergency and Security Plans are mandated by the Code of Federal Regulations and, in part, are currently contained within respective plans.
As such, these requirements are redundant and will be removed by the proposed changes.
Those requirements not currently contained within respective plans will be added upon approval of the proposed changes.
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Document Control Desk NLR-N94051 APR 13 1994*
In response to the NRC Cost Beneficial Licensing Action (CBLA) initiative, Public Service Electric & Gas (PSE&G) met with the NRR staff on November 12, 1993, to discuss our CBLA Program.
PSE&G considers this submittal a CBLA.
We have estimated that under optimal conditions, the proposed changes would yield a* cost savings of 92,000 $/yr at Hope Creek and Salem Unit Nos. 1 and 2.
Savings over the life of the plants is estimated to be
$ 2,484,000.
PSE&G notes that changes similar to those proposed herein have been approved by the NRC for Virginia Electric and Power Company in an SER dated March 1, 1994.
A description of the requested amendment, supporting information and analyses for the change, and the basis for a no significant hazards determination are provided in Attachments 1 and 2 for Hope Creek and Salem Units Nos. 1 and 2, respectively.
The Technical Specification pages affected by the proposed changes are marked-up in Attachments 3, 4 and 5 for Hope Creek, Salem Unit No. 1 and Salem Unit No. 2, respectively.
This amendment application also satisfies the requirements of 10 CFR 50.54(a) (3) which requires that changes to the Quality Assurance Description Program that reduce commitments be submitted for NRC approval prior to implementation.
The UFSAR pages affected by these changes are included as Attachments 6 and 7 for Hope Creek and Salem Unit Nos. 1 and 2, respectively.
Applicable sections of the Emergency and Security* Plans for Hope Creek and Salem Unit Nos. 1 and 2 are included as Attachments 8 and 9 respectively, for information.
NRC approval of the proposed changes to the Hope Creek and Salem Generating stations UFSARs is requested concurrently with the proposed changes to the Technical Specifications.
PSE&G requests that a letter lengthening the NRC Staff review of the QA program changes be issued if the Technical Specification changes are not approved within 60 days of this submittal.
This will ensure that the QA program changes are not approved prior to the Technical Specification changes.
Upon NRC approval of the proposed changes, PSE&G requests that the amendment be made effective on the date of issuance, but implemented within sixty (60) days to provide sufficient time for associated administrative activities.
Document Control Desk NLR-N94051 APR 13 1994* Should you have any questions on this submittal, please contact us.
Attachments (9)
Mr. T. T. Martin, Administrator - Region I
- u. s. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. J. stone, Licensing Project Manager U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. c. Marschall (S09)
USNRC Senior Resident Inspector Mr. Kent Tosch, Manager, IV NJ Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625
STATE OF NEW JERSEY COUNTY OF SALEM
)
)
)
REF:
NLR-N94051 SS.
S. E. Miltenberger, being duly sworn according to law deposes and says:
I am Vice President & Chief Nuclear Officer of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Hope Creek and the Salem Generating Stations, are true to the best of my knowledge, information and belief.
l<IMBERl y JO BROWN NOTARY. P~BLIC OF NEW JERSEY My Commission expires on ~~~-M_v_c_om_r_nrs_s1_on~E~xn~ire_s~A~pr-il~
21~,~lsme~a~
ATTACHMENT 1 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354 I.
DESCRIPTION OF CHANGES NLR-N94051 LCR 94-05 This amendment application will revise the Hope Creek Quality Assurance (QA) audit frequencies which are currently contained in Technical Specification (TS) 6.5.2.4.3.
In general, the various TS audit frequencies will be revised to a biennial frequency.
In addition, a 25% extension to the biennial frequency is also proposed.
Subsequent control over the current audits of TS 6.5.2.4.3 will be delineated in the Updated Final Safety Analysis Report (UFSAR), Section 17.2.18.
Proposed revisions to Section 17.2.18 to address the QA audit frequencies are included as part of this submittal in Attachment 6.
In addition, this amendment application will also remove the TS requirements for the annual audit of the Emergency and Security Plans.
Also, the changes will remove the requirements for the Station Operations Review Committee (SORC) to review the Emergency and Security Plans.
These changes are consistent with NRC guidance presented in Generic Letter (GL) 93-07 "Modification of the Technical Specification Administrative Control Requirements for
~mergency and S~cur.ity Plans."
II.
REASON FOR CHANGES A.
Audit Frequency Changes The minimum scope and schedules for the audit program have been specified by the Administrative Controls Section of the Hope Creek TS.
The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements from various sources (e.g., the Code of Federal Regulations and industry standards and guidelines).
The audits specified by these sources are meant to address programs which are deemed to be essential to the effective management of the facility.
However, the rigid schedules dictated by the TS do not allow management the flexibility to recognize exceptional performance by certain organizations.
Also, the current schedule does not effectively allow resources to be devoted to areas with perceived weaknesses since strong programs are also required to be audited at similar frequencies which are set forth in the TS.
Page 1 of 9
ATTACHMENT 1 AbDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 The proposed changes also add a 25% extension to the biennial audit frequency to provide added flexibility in scheduling audits.
Use of a 25% extension to the audit frequency is similar to provisions currently provided by TS 4.0.2. TS 4.0.2 permits allowable extensions to normal surveillance intervals to facilitate scheduling and to consider plant conditions.
Consistent with the intent of TS 4.0.2, the 25% extension provision is not intended to be used repeatedly to extend audit frequencies.
The 25%
extension will not be applicable to those audits with frequencies specified by t.he Code of Federal Regulations (i.e., Emergency Plan and Security Plan).
The proposed changes to remove the audit frequencies from TS 6.5.2.4.3 are consistent with the NRC Standard Technical Specifications (STS) (NUREG-1433, Volume 1 "Standard Technical Specifications General.Electric Plants," BWR/4).
The STS in Section 5.5 states that the combination of reviews and audits should be integrated "into a cohesive program that provides senior level utility management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability."
Therefore, these administrative tools (i.e., audits) should be sufficiently flexible to allow senior management direction of resources to focus upon areas requiring increased attention.
These proposed changes to TS 6.5.2.4.3 would provide this flexibility by removing the current rigid TS audit frequencies.
The proposed changes will not result in a loss of regulatory control and subsequent revision to the audit program will receive NRC review.
10 CFR 50.54(a) (3) requires that changes to the quality assurance description report which reduce commitments be submitted and approved*by the*NRC*
prior to implementation.
This will ensure NRC review of subsequent changes to the QA audit program.
Furthermore, the current changes in this amendment application are being submitted to satisfy the requirements of 10 CFR 50.54(a) (3).
As an additional change, Section 1.8.1.33 of the UFSAR will be revised to state that exception is taken to the audit frequencies described in Regulatory Guide (RG) 1.33, Revision 2 and ANSI N18.7-1976 as endorsed by RG 1.33.
The revision to Section 1.8.1.33 will refer to Section 17.2.18 for the audit program frequency.
Also, Section 13.4.2.1.2 will be revised to remove the list of TS 6.5.2.4.3 audits.
This change makes Section 13.4.2.1.2 consistent with the proposed changes to the audit frequency.
Finally, UFSAR Section 13.4.2.1.3 now provides clarification concerning audit reports which reflect the aforementioned changes.
The UFSAR pages affected by these changes are included as.
Page 2 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS B.
Generic Letter 93-07 Changes NLR-N94051 LCR 94-05 Generic Letter 93-07 provides guidance to relocate review and audit requirements of the Facility Emergency and Security Plans from the TS to the respective plans.
Parts 50 and 73 of Title 10 of the Code of Federal Regulations (10 CFR) include provisions that are sufficient to address these requirements.
T~erefore, inclusion of these requirements in the TS is unnecessary.
Currently, the requirements for reviews and audits of these plans, are in part, already incorporated in the Hope Creek Emergency and Security Plans.
The balance of requirements not currently contained within the respective plans will be added upon approval of the proposed changes.
III. JUSTIFICATION FOR CHANGES The proposed changes will revise TS 6.5.2.4.3 to remove the currently specified audit frequencies from the TS.
Subsequent control over the audit program will be provided by Section 17.2.18 of the UFSAR.
UFSAR Section 17.2.18 will be revised to address the audit program by permitting the required TS audits to be conducted on a biennial frequency.
Additional flexibility to the audit schedule will also be obtained by proposing a 25% extension to the biennial frequency.
Also, the proposed changes will remove TS requirements-for review and audit of the Emergency and Security Plans.
Similar changes to that proposed herein have been approved by the NRC Staff for Virginia Electric and Power Company in an SER dated March 1, 1994.
The specific changes to the TS are addressed as follows:
A.
Audit Frequency Changes TS 6.5.2.4.3 has been revised to remove references to specific audit frequencies.
A statement has been prepared for inclusion into Section 17.2.18 of the UFSAR to provide subsequent control over the audit schedule.
The proposed changes do not alter the function or diminish the quality of the audit program.
The Offsite Safety Review (OSR) group will continue to oversee the QA audit program.
With regard to the audit program, the proposed changes revise the audit frequencies in the TS to biennial frequencies.
In addition, a 25% extension is also proposed to provide increased flexibility in scheduling.
The 25%
extension would not be applicable to those audits required by the Code of Federal Regulations (i.e., Emergency Plan and Security Plan).
Page 3 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 The TS required audits and the affects of the proposed changes on these audits is addressed as follows:
TS 6.5.2.4.3.a, the conformance of facility operation to provisions contained within the TS and applicable license conditions.
Applicable portions of the TS and license conditions are assessed during each audit for the particular areas being audited.
Also, an annual audit is conducted to evaluate those areas which are not evaluated in other audits.
Reducing the annual audit frequency to biennial will not adversely impact compliance with those provisions of the TS, commitments in the UFSAR (i.e., Chapter 17 "Quality Assurance") or the effectiveness of the audits performed.
Compliance with the TS and license conditions is evaluated more often than the 12 month audit although not performed in a single TS audit.
TS 6.5.2.4.3.b, performance, training and qualification of the entire facility staff.
Audits of the facility staff's qualifications are conducted annually.
The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if necessary.
This added flexibility is not expected to adversely affect the training program or the the audit program.
Under the proposed changes, management will be permitted to increase or decrease the audit frequency based upon observed performance.
TS 6.5.2.4.3.c, results of actions taken~o correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
Results of actions taken to correct identified deficiencies are evaluated as part of each audit for the area being audited.
The proposed changes would not adversely affect the review of corrective actions in each audit.
Only the audit of programmatic controls will be affected in that management may be allowed the flexibility to adjust the frequency of the audit to be a maximum of 30 months, if necessary.
The adjustment in frequency would be based on performance indicators.
As such, the proposed changes will not reduce the effectiveness of either the Corrective Action Program or the oversight of that program.
TS 6.5.2.4.3.d, performance of activities required by Page 4 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50.
This audit is currently performed "at least once per 24 months."
The proposed changes do not alter this frequency except to provide added versatility of a potential 25% (i.e., 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4.3.e and f, the Emergency Plan and implementing procedures and the Security Plan and implementing procedures.
The proposed changes do not affect the frequency of these audits.
The audit frequency is mandated by Title 10 of the Code of Federal Regulations and in the NRC approved plans.
Also, the 25% extension proposed by these changes is not applicable to audits mandated by the Code of Federal Regulations.
TS 6.5.2.4.3.g, other areas of facility operation considered appropriate by the General Manager -
QA and Nuclear Safety or Vice President and Chief Nuclear Officer.
The proposed changes will have no affect on this item.
TS 6.5.2.4.3.h, the Facility Fire Protection Program and implementing procedures.
This audit is currently performed "at least once per 24 months."
The proposed changes do not alter this frequency except to provide added*versatility of a potential 25% (i.e., 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4.3.i, the annual audit of the fire protection and loss prevention program implementation utilizing either a qualified offsite licensee fire protection engineer(s) or an outside independent fire protection consultant.
An outside independent fire protection consultant shall be utilized once every three years.
The proposed changes will combine the annual and triennial audits which will be alternated with the biennial Fire Protection Program Audit (TS 6.5.2.4.3.h).
Hence, each year a fire protection audit will be performed, and a qualified outside consultant will be utilized in alternate years.
This will not adversely impact the effectiveness of either the Fire Protection/Loss Prevention Program or the Audited Page 5 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 Program, because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, "Technical Specifications for Fire Protection Audits," utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features.
TS 6.5.2.4.3.j, the radiological environmental monitoring program.
This audit is currently performed once every twelve months.
The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if necessary.
This added flexibility is not expected to adversely affect the radiological environmental monitoring program or the audit program.
Under the proposed changes, management will be permitted to increase or decrease the audit frequency based upon observed performance.
TS 6.5.2.4.3.k, Offsite Dose Calculational Manual and implementing procedures.
This audit is currently performed "at least once per 24.
months."
The proposed changes do not alter this frequency except to provide added versatility of a potential 25% (i.e.1 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4.3.l, Process Control Program and implementing procedures.
This audit is currently performed "at least* once per 24 months."
The proposed changes do. not alter this frequency except to provide added versatility of a potential 25% (i.e., 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4.3.m, the performance of activities required by the Quality Assurance Program for effluent and environmental monitoring.
This audit is currently performed "at least once per 12 months."
The.proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if necessary.
This added flexibility is not expected to adversely affect the performance of activities required by the Quality Assurance Program for effluent and environmental monitoring (i.e., radiological environmental monitoring) or the audit program.
Under the proposed Page 6 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 changes, management will be permitted to increase or decrease the audit frequency based upon observed performance.
B.
Generic Letter 93-07 Changes TS 6.5.1.6.j has been deleted.
Upon approval of the proposed changes, a provision will be added to the Facility Security Plan to incorporate the review currently required by TS 6.5.1.6.j.
As such, this proposed change complies with the guidance provided by the NRC Staff in GL 93-07.
TS 6.5.1.6.k has been deleted.
With the exception of the 10 CFR 50.54(q) review, the responsibilities for the SORC to review the Facility Emergency Plan as detailed in TS 6.5.1.6.k currently exists within the NRC approved Site Emergency Plan.
Upon approval of the proposed changes, an additional clarification to address 10 CFR 50.54(q) reviews will be added to the Facility Emergency Plan.
As such, this proposed change complies with the guidance provided by the NRC Staff in GL 93-07.
TS 6.5.2.4.3.e has been deleted.
This proposed change will have no affect on the audit of the Facility Emergency Plan and implementing procedures.
Audit frequency of the Emergency Plan and implementing procedures are mandated by 10 CFR 50.54(t).
Also, the audit frequency is currently contained in the NRC approved Facility Emergency Plan for the Hope Creek Plant.
TS 6.5.2.4.3.f has been deleted.
This proposed change will have no affect on the audit of the Facility Security Plan and implementing procedures.
Audit frequency of the Security Plan and implementing procedures are mandated' by Title 10 of the Code of Federal Regulations.
Also, the audit frequency is currently contained in the NRC approved Facility Security Plan for the Hope Creek plant.
TS 6.8.2 has been revised to remove TS references to SORC review of the Emergency and Security Plan implementation procedures.
These changes make TS 6.8.2 consistent with the proposed deletion of TS 6.5.1.6.j and 6.5.1.6.k.
IV.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed changes to determine whether our request involves a significant hazards consideration.
We have determined that the operation of the Hope Creek Generating Station in accordance with the proposed changes:
Page 7 of 9
ATTACHMENT 1 NLR-N94051 LCR 94-05 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS
- 1.
Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The likelihood that an accident will occur is neither increased or decreased by the proposed Technical Specification changes which affect review and audit frequencies.
The proposed changes will not impact the function or method of operation of plant equipment.
Thus, there is not a significant increase in the probability of a previously analyzed accident due to the changes.
Also, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR is not increased by the changes.
The proposed changes affect review and audit frequencies.
As such, the proposed changes have no impact on accident initiators or plant equipment, and thus, do not affect the probabilities or consequences of an accident.
The audit program verifies that functions and methods of plant operation have not been altered or degraded.
This verification process will continue, but on a more flexible basis.
The proposed changes will not alter the function or diminish the quality of the audits.
Frequency may only be decreased for those programs which demonstrate acceptable performance.
The changes provide added flexibility in scheduling audits and facilitate resource allocation to areas with perceived weaknesses.
In this regard, the proposed changes offer an opportunity for possible decreases in the likelihood that an accident would occur.
Therefore, we conclude that the proposed changes do not significantly increase the probabilities or consequences of an accident.
- 2.
Will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes do not involve changes to the physical plant or operations.
Since program audits do not contribute to accident initiation, changes related to audit functions cannot produce a new accident scenario or produce a new type of equipment malfunction.
Also, the change does not alter any existing accident scenarios.
The proposed changes do not affect equipment or its operation, and, thus, do not create the possibility of a new or different kind of accident.
Page 8 of 9
ATTACHMENT 1 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-05 The proposed changes revise the audit frequency to biennial and permit a 25% extension to this frequency.
However, audit frequency may only be decreased for those programs exhibiting acceptable performance.
The 25% extension is a provision to provide added flexibility in scheduling audits and is not applicable to the audits of the Facility Emergency and Security Plans.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident.
- 3.
Will not involve a significant reduction in a margin of safety.**
The proposed changes concerning conduct of reviews and audits do not directly affect plant equipment or operation.
Safety limits and limiting safety system settings are not affected.
The proposed changes will not alter the function or diminish the quality of the reviews and audits.
For the audit program, the changes propose a biennial audit frequency and a subsequent transfer of control over the audit program to the Updated Final Safety Analysis Report.
This will not result in a loss of regulatory control.
10 CFR 50.54(a) (3) requires that changes to the quality assurance description report which reduce commitments be submitted to the NRC prior to implementation.
In addition, the audit frequency may only be decreased for those programs which demonstrate acceptable performance.
The changes provide added flexibility in scheduling audits and facilitate resource allocation to areas with perceived weaknesses.
The proposed changes should result in a more effective audit program that will contribute to an improvement in plant safety.
Therefore, use of the proposed Technical Specification changes would not involve any reduction in the margin of safety.
V.
CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
Page 9 of 9
ATTACHMENT 2 PROPOSED CHANGES TO TECHNICAL SPECIFICATIONS LICENSE AMENDMENT APPLICATION AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS SALEM UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 I.
DESCRIPTION OF CHANGES NLR-94051 LCR 94-10 This amendment application will revise the Quality Assurance (QA) audit frequencies which are currently contained in Technical Specification (TS) 6.5.2.4.3 for both Salem Unit Nos. 1 and 2.
In general, the various TS audit frequencies will be revised to a biennial frequency.
In addition, a 25%
extension to the biennial frequency is also proposed.
Subsequent control over the current audits of TS 6.5.2.4.3 will be delineated in the Updated Final Safety Analysis Report (UFSAR), Section 17.2.18.
Proposed revisions to Section 17.2.18 to address the QA audit frequencies are included as part of this submittal in Attachment 7.
In addition, this amendment application will also remove the TS requirements for the annual audit of the Emergency and Security Plans.
Also, the changes will remove the requirements for the Station Operations Review Committee (SORC) to review the Emergency and Security Plans.
These changes are consistent with NRC guidance presented in Generic Letter (GL) 93-07 "Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans."
II.
REASON FOR CHANGES A.
Audit Frequency Changes The minimum scope and schedules for the audit program have been specified by the Administrative Controls Section of the Salem Unit Nos. 1 and 2 TS.
The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements **from various sources (e.g., the Code of Federal Regulations and industry standards and guidelines).
The audits specified by these sources are meant to address programs which are deemed to be essential to the effective management of the facility.
However, the rigid schedules dictated by the TS do not allow management the flexibility to recognize exceptional performance by certain organizations.
Also, the current schedule does not effectively allow resources to be devoted to areas with perceived weaknesses since strong programs are also required to be audited at similar frequencies which are Page 1 of 9
ATTACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS set forth in the TS.
NLR-N94051 LCR 94-10 The proposed changes also add a 25% extension to the biennial audit frequency to provide added flexibility in scheduling audits.
Use of a 25% extension to the audit frequency is similar to provisions currently provided by TS 4.0.2.
TS-4.0.2 permits allowable extensions to normal surveillance intervals to facilitate scheduling and to consider plant conditions.
Consistent with the intent of TS 4.0.2, the 25% extension provision is not intended to be used repeatedly to extend audit frequencies.
The 25%
extension will not be applicable to those audits with frequencies specified by the Code of Federal Regulations (i.e., Emergency Plan and Security Plan)-.
The proposed changes to remove the audit frequencies from TS 6.5.2.4.3 are consistent with the NRC standard Technical Specifications (STS) (NUREG-1431, Volume 1 "Standard Technical Specifications Westinghouse Plants,").
The STS in Section 5.5 states that the combination of reviews and audits should be integrated "into a cohesive program that provides senior level utility management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability." Therefore, these administrative tools (i.e., audits) should be sufficiently flexible to allow senior management direction of resources to focus upon areas requiring increased attention.
These proposed changes to TS 6.5.2.4.3 would provide this flexibility by removing the current rigid TS audit frequencies.
The proposed changes will not result in a loss of regulatory control and subsequent revision to the audit program will receive NRC review.
10 CFR 50.54(a) (3) requires that changes to the quality assurance description report which reduce commitments be submitted and approved by the NRC prior to implementation.
This will ensure NRC review of subsequent changes to the QA audit program.
Furthermore, the current changes in this amendment application are being
. submitted to satisfy the requirements of 10 CFR 50.54(a) (3).
As an additional change, Appendix 3A of the UFSAR will be revised to state that exception is taken to the audit frequencies described in Regulatory Guide (RG). 1.33, Revision 2 and ANSI N18.7-1976 as endorsed by RG 1.33.
The revision to Appendix 3A will refer to Section 17.2.18 for the audit program frequency.
The UFSAR pages affected by these changes are included as Attachment 7.
B.
Generic Letter 93-07 Changes Generic Letter 93-07 provides guidance to relocate review and audit requirements of the Facility Emergency and Security Plans from the TS to the respective plans.
Parts Page 2 of 9
ATTACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-10 50 and 73 of Title 10 of the Code of Federal Regulations (10CFR) include provisions that are sufficient to address these requirements.
Therefore, inclusion of these requirements in the TS is unnecessary.
Currently, the requirements for reviews and audits of these plans, are in part, already incorporated in the Emergency and Security Plans for both Salem Units 1 and 2.
The balance of requirements not currently contained within the respective plans will be added upon approval of the proposed changes.
III. JUSTIFICATION FOR CHANGES The proposed changes will revise TS 6.5.2.4.3 to remove the currently specified audit frequencies from the TS.
Subsequent control over the audit program will be provided by Section 17.2.18 of the UFSAR.
UFSAR Section 17.2.18 will be revised to address the audit program by permitting the required TS audits to be conducted on a biennial frequency.
Additional flexibility to the audit schedule will also be obtained by proposing a 25% extension to the biennial frequency.
Also, the proposed changes will remove TS requirements for review and audit of the Emergency and Security Plans.
Similar changes to that proposed herein have been approved by the NRC Staff for Virginia Electric and Power Company in an SER dated March 1, 1994.
The specific changes to the TS are addressed as follows:
A.
Audit Frequency Changes TS 6.5.2.4.3 has been revised to remove references to specific audit frequencies.
A statement has been prepared for inclusion into Section 17.2.18 of the UFSAR to provide subsequent control over the audit schedule.
The proposed changes do not alter the function or diminish the quality of the audit program.
The Offsite Safety Review (OSR) group will continue to oversee the QA audit program.
With regard to the audit program, the proposed changes revise the audit frequencies in the TS to biennial frequencies.
In addition, a 25% extension is also proposed to provide increased flexibility in scheduling.
The 25%
extension would not be applicable to those audits required by the Code of Federal Regulations (i.e., Emergency Plan and Security Plan).
The TS required audits and the affects of the proposed changes on these audits is addressed as follows:
TS 6.5.2.4.3.a, the conformance of facility operation to provisions contained within the TS and applicable Page 3 of 9
ATTACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS license conditions.
NLR-N94051 LCR 94-10 Applicable portions of the TS and license conditions are assessed during each audit for the particular areas being audited.
Also, an annual audit is conducted to evaluate those areas which are not evaluated in other audits.
Reducing the annual audit frequency to biennial will not adversely impact compliance with those provisions of the TS, commitments in the UFSAR (i.e., Chapter 17 "Quality Assurance") or the effectiveness of the audits performed.
Compliance with the TS and license conditions is evaluated more often than the 12 month audit although not performed in a single TS audit.
TS 6.5.2.4.3.b, performance, training and qualification of the entire facility staff.
Audits of the facility staff's qualifications are conducted annually.
The proposed changes will allow management to schedule the time b~tween specific audits to be a maximum of 30 months, if necessary.
This added flexibility is not expected to adversely affect the training program or the the audit program.
Under the proposed changes, management will be permitted to increase or decrease the audit frequency based upon observed performance.
TS 6.5.2.4.3.c, results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
Results of actions taken to correct identified.*
deficiencies are evaluated as part of each audit for the area being audited.
The proposed changes would not adversely affect the review of corrective actions in each audit.
Only the audit of programmatic controls will be affected in that management may be allowed the flexibility to adjust the frequency of the audit to be a maximum of 30 months, if necessary.
The adjustment in frequency would be based on performance indicators.
As such, the proposed changes will not reduce the effectiveness of either the Corrective Action Program or the oversight of that program.
TS 6.5.2.4.3.d, performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50.
This audit is currently performed "at least once per 24 months."
The proposed changes do not alter this frequency except to provide added versatility of a Page 4 of 9
ATTACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-10 potential 25% (i.e., 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4.3.e and f, the Emergency Plan and implementing procedures and the Security Plan and implementing procedures.
The proposed changes do not affect the frequency of these audits.
The audit frequency is mandated by Title 10 of the Code of Federal Regulations and in the NRC approved plans.
Also, the 25% extension proposed by these changes is not applicable to audits mandated by the Code of Federal Regulations.
TS 6.5.2.4.3.g, other areas of facility operation considered appropriate by the General Manager -
QA and Nuclear Safety or Vice President and Chief Nuclear Officer.
The proposed changes will have no affect on this item.
TS 6.5.2.4.3.h, the Facility Fire Protection Program and implementing procedures.
This audit is currently perforined "at least once per 24 months."
The proposed changes do not alter this frequency except to provide added versatility of a potential 25% (i.e., 6 months) extension, if necessary.
This proposed change would provide management increased flexibility in scheduling subsequent audits.
TS 6.5.2.4~3~i, the annual audit of the fire protection and loss prevention program implementation utilizing*
either a qualified offsite licensee fire protection engineer(s) or an outside independent fire protection consultant.
An* outside independent fire protection consultant shall be utilized once every three years.
The proposed changes will combine the annual and triennial audits which will be alternated with the biennial Fire Protection Program Audit (TS 6.5.2.4.3.h).
Hence, each year a fire protection audit will be performed, and a qualified outside consultant will be utilized in alternate years.
This will not adversely impact the effectiveness of either the Fire Protection/Loss Prevention Program or the Audited Program, because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21 "Technical Specifications for Fire Protection Audits," utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features.
Page 5 of 9
A'~TACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-10 TS 6.5.2.4.3.j, the radiological environmental monitoring program.
This audit is currently performed once every twelve months.
The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if necessary.
This added flexibility is not expected to adversely affect the radiological environmental monitoring program or the audit program.
Under the proposed changes, management will be permitted to increase or decrease the audit frequency based upon observed performance.
B.
Generic Letter 93-07 Changes TS 6.5.1.6.j has been deleted.
Upon approval of the proposed changes, a provision will be added to the Facility Security Plan to incorporate the review currently required by TS 6.5.1.6.j.
As such, this proposed change complies with the guidance provided by the NRC Staff in GL 93-07.
TS 6.5.1.6.k has been deleted.
With the exception of the 10 CFR 50.54(q) review, the responsibilities for the SORC to review the Facility Emergency Plan as detailed in TS 6.5.1.6.k currently exists within the NRC approved Site Emergency Plan.
Upon approval of the proposed changes, an additional clarification to address 10 CFR 50.54(q) reviews will be added to the Facility Emergency Plan.
As such, this proposed change complies with the guidance provided by the NRC Staff in GL 93-07.
TS 6.5.2.4.3.e has been deleted.
This proposed*change will have no affect on the audit of the Facility Emergency Plan and implementing procedures.
Audit frequency of the Emergency Plan and implementing procedures are mandated by 10 CFR 50.54(t).
Also, the audit frequency is currently contained in the NRC approved Facility Emergency Plan for Salem Units Nos. 1 and 2.
TS 6.5.2.4.3.f has been deleted.
This proposed change will have no affect on the audit of the Facility Security Plan and implementing procedures.
Audit frequency of the S~curity Plan and implementing procedures are mandated by Title 10 of the Code of Federal Regulations.
Also, the audit frequency is currently contained in the NRC approved Facility Security Plan for Salem Units Nos. 1 and 2.
TS 6. 8.. 2 has been revised to remove TS references to SORC rev~ew of the Emergency and Security Plan Page 6 of 9
A~TACHMENT 2 NLR-N94051 LCR 94-10 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS IV.
implementation procedures.
These changes make TS 6.8.2 consistent with the proposed deletion of TS 6.5.1.6.j and 6.5.1.6.k.
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION PSE&G has, pursuant to 10 CFR 50.92, reviewed the proposed changes to determine whether our request involves a significant hazards consideration.
We have determined that the operation of Salem Units Nos. 1 and 2 in accordance with the proposed changes:
- 1.
Will not involve a significant increase in the probability or consequences of an accident previously evaluated.
The likelihood that an accident will occur is neither increased or decreased by the proposed Technical Specification changes which affect review and audit frequencies.
The proposed changes will not impact the function or method of operation of plant equipment.
Thus, there is not a significant increase in the probability of a previously analyzed accident due to the changes.
Also, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR is not increased by the changes.
The proposed changes affect review and audit frequencies.
As such, the proposed changes have no impact on accident initiators or plant equipment, and thus, do not affect the probabilities or consequences of an accident.
The audit program verifies that functions and methods of plant operation have not been altered or degraded.
This verification process will continue, but on a more flexible basis.
The proposed changes will not alter the function or diminish the quality of the audits.
Frequency may only be decreased for those programs which demonstrate acceptable performance.
The changes provide added flexibility in scheduling audits and facilitate resource allocation to areas with perceived weaknesses.
In this regard, the proposed changes offer an opportunity for possible decreases in the likelihood that an accident would occur.
Therefore, we conclude that the proposed changes do not significantly increase the probabilities or consequences of an accident
- Page 7 of 9
A~TACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-10
- 2.
Will not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed changes do not involve changes to the physical plant or operations.
Since program audits do not contribute to accident initiation, changes related to audit functions cannot produce a new accident scenario or produce a new type of equipment malfunction.
Also, the changes do not alter any existing accident scenarios.
The proposed changes do not affect equipment or its operation, and, thus, do not create the possibility of a new or different kind of accident.
The proposed changes revise the audit frequency to biennial and permit a 25% extension to this frequency.
However, audit frequency may only be decreased for those programs exhibiting acceptable performance.
The 25% extension is a provision to provide added flexibility in scheduling audits and is not applicable to the audits of the Facility Emergency and Security Plans.
Therefore, the proposed changes do not create the possibility of a new or different kind of accident.
- 3.
Will not involve a significant reduction in a margin of safety.
The proposed changes concerning conduct of reviews and audits do not directly affect plant equipment or operation.
Safety limits and limiting safety system settings are not affected.
The proposed changes will not alter the function or diminish the quality of the reviews and audits.
For the audit program, the changes propose a biennial audit frequency and a subsequent transfer of control over the audit program to the Updated Final Safety Analysis Report.
This will not result in a loss of regulatory control.
10 CFR 50.54(a) (3) requires that changes to the quality assurance description report which reduce commitments be submitted to the NRC prior to implementation.
In addition, the audit frequency may oniy be decreased for those programs which demonstrate acceptable performance.
The changes provide added flexibility in scheduling audits and facilitate resource allocation to areas with perceived weaknesses.
The proposed changes should result in a more effective audit program that will contribute to an improvement in plant safety.
Page 8 of 9
ATTACHMENT 2 AUDIT FREQUENCY AND REVIEW SCHEDULE REVISIONS NLR-N94051 LCR 94-10 Therefore, use of the proposed Technical Specification changes would not involve any reduction in the margin of safety.
V.
CONCLUSION Based on the above, PSE&G has determined that the proposed changes do not involve a significant hazards consideration.
Page 9 of 9
LCR 94-05 LCR 94-10 NLR-N94051 TECHNICAL SPECIFICATION PAGES WITH PEN AND INK CHANGES The following Technical Specifications are affected by this requested amendment:
Facility Operating License No. NPF-57 (Hope Creek)
Technical Specifications
- 1.
- 2.
- 3.
6.5.1.6 6.5.2.4.3 6.8.2 6-8 6-11 and 12 6-15 Facility Operating License No. DPR-70 (Salem Unit 1)
Technical Specification
- 1.
- 2.
- 3.
6.5.1.6 6.5.2.4.3 6.8.2 6-9 6-12 and 13 6-17 Facility Operating License No. DPR (Salem Unit 2)
Technical Specification
- 1.
- 2.
- 3.
6.5.1.6 6.5.2.4.3 6.8.2 6-9 6-12 and 13 6-17
ATTACHMENT 3 LCR 94-05 NLR-N94051 MARKED UP PROPOSED TECHNICAL SPECIFICATION PAGES HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354
ADMINISTRATIVE CONTROLS procedures that require a 10 CFR 50.59 safety evaluation as described in Section 6.5.3.2.d.
- b.
Review of all proposed tests and experiments that affect nuclear safety.
- c.
Review of all proposed changes to Appendix 11A 11 Technical Specifications.
- d.
Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
- e.
Review of the safety evaluations that have been completed under the provisions of 10 CFR 50.59.
- f.
Initiation or review of investigations of all violations of the Tech-nical Specifications including the reports covering evaluations and reconunendations to prevent recurrence.
- g.
Review of all REPORTABLE EVENTS.
- h.
Review of facility operations to detect potential nuclear safety hazards.
- i.
Performance of special reviews, jnvestigations or an~lyses and reports thereon as determined by the SORC.
Review of the Facility Security Plan and implementing procedures and changes thereto that require a 10 CFR 50.59 safety evaluation, or involve a potential decrease in the effectiveness of.the plan, per 10 CFR 50.54(p).
Review of the Facility Emergency Plan and implementing procedures and changes thereto that require a 10 CFR 50.59 safety evaluation, or involve a potential decrease in the effectiveness of the plan, per 0 CFR 50.54(q).
- 1.
Review of the Fire Protection Program and implementing procedures and changes thereto that require a 10 CFR 50.59 safety evaluation.
- m.
Review of all unplanned on-site releases of radioactivity to the environs including the preparation of reports covering evaluation, reconmendations, and disposition of the corrective action to prevent recurrence.
- n.
Review of changes to the PROCESS CONTROL MANUAL and the OFF-SITE DOSE CALCULATION MANUAL.
REVIEW PROCESS 6.5.1.7 A technical review and control system utilizing qualified reviewers shall function to perform the periodic or routine review of procedures and changes thereto.
Details of this technical review process are provided in Section 6.5.3.
HOPE CREEK 9404190216 940413 PDR ADOCK 05000272 p
- PDR 6-8
--~
Amendment No. 52
ADMINISTRATIVE CONTROLS
- f.
All REPORTABLE EVENTS.
- g.
All recognized indications of an unanticipated deficiency in *some aspect of design or operation of structures, systems, or components that could affect nuclear safety; and
- h.
Reports and meeting minutes of the SORC.
AUDITS 6.5.2.4.3 Audits of facility activities shall be performe under the cognizance of the OSR staff. These audits sha 11 encompass:
-\\-~.+o\\\\Q1.1ol\\V\\~
- a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions~..a:t:
least eAee peP 12 meRtR&;
- b.
The performance, training and qualifications of the entire facility staft-at least eAee peP 12 MORths;
- c.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety. 1at least eRee pep 6 1ReAths;
- d.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50, at least oRee per 2~ moRtR&;
The Faeility EmergeRey PlaA aAe implementing pPeeeduPes at least eRee per 12 mgRtR~;,
The Faeility Secupity PlaA aAd implemeRtiRg procedwres at ~east oRce
~r 1.2 months;
- g.
Any other area of facility operation considered appropriate by the General Manager - Quality Assurance and Nuclear Safety or the Vice President and Chief Nuclear Officer*
h..
The facility Fire Protection Program and the implementing procedures.
at least enee per 2~ meRtRs; The fire preteetieA aAd less preveAtieA pregram implemeAtatieR at least eAce per 12 meAths ~tiliziAg either a ~~alifiea eff-site licensee fire preteetieA eR~iReer(s) eP. an outside iRdependent fire prateetieA eeRsultant.
AR Oijtside indepeRdent fire pPeteetie" co11 s~ltant sRall ee Ytilized at least eRee peF 36 mentRs; an~
- j.
The radiological environmental monitoring.program and the results thereof. -at. least or:ice per 12. 1i1ocths implementing procedures *.a-t-
ADMINISTRATIVE CONTROLS
- 1.
The PROCESS CONTROL PROGRAM and implerr~nting procedures for process-ing and packaging of radioactive wastes.at least eRee pep 24 meAtRs,
-af.lG.,
- m.
The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring.at least eRee pep 12 meRtRs.
The above audits may be conducted by the Quality Assurance Department or an independent consultant.
Audit plans and final audit reports shall be reviewed by the OSR staff.
RECORDS AND REPORTS 6.5.2.4.4 Records of OSR activities shall be maintained.
Reports of reviews and audits shall be prepared and distributed as indicated below:
- a.
The results of reviews performed pursuant to Section 6.5.2.4.2 shall be reported to the Vice President and Chief Nuclear Officer at least monthly.
- b.
Audit reports prepared pursuant to Specification 6.5.2.4.3 shall be forwarded by the auditing organization to the Vice President and Chief Nuclear Officer and to the management positions responsible for the areas audited (1) within 30 days after completion of the audit for those audits conducted by the Quality Assurance Department, and (2) within 60 days after completion of the audit for those audits conducted by an independent consu.ltant.
6.5.2.5 ONSITE SAFETY REVIEW GROUP (SRG)
FUNCTION 6.5.2.5.1 The~SRG shall function to provide: the review of plant design and operating experience for potential opportunities to improve plant safety; evalua-tion of plant operations and maintenance activities; and advice to management on the overall quality and safety of plant operations.
The SRG shall make recommendations for revised procedures, equipment modifica-tions, or other means of improving plant safety to appropriate station/corporate management.
RESPONSIBILITIES 6.5.2.5.2 The SRG shall be responsible for:
- a.
Review of selected plant operating characteristics, NRC issuances, industry advisories, and other appropriate sources of plant design and operating experience information which may indicate areas for improving plant safety.
- b.
Review of selected facility features, equipment, and systems.
- c.
Review of selected procedures and plant activities including main-tenance, modification, operational problems, and operational analysis.
HOPE CREEK 6-12 Amendment No. 52
ADMINISTRATIVE CONTROLS
- b.
A Safety Limit Violation Report shall be prepared.
The report shall be reviewed by the SORC.
This report shall describe (1) applicable circumstances preceding the violation, (2) effects of the violation upon unit-components, systems, or structures, and ( 3) corrective action taken to prevent recurrence.
- c.
The Safety Limit Violation Report shall be submitted to the Commission, the General Manager - Quality Assurance and Nuclear Safety and the Vice President and Chief Nuclear Officer within 30 days of the violation.
- d.
Critical operation of the unit shall not be resumed until authorized by the Commission.
6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:
- a.
The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
- b.
The applicable procedures required to implement the requirements of NUREG-0737 and supplements thereto.
- c.
Refueling operations.
- d.
Surveillance and test activities of safety-related equipment.
- e.
Security Plan implementation.
- f.
Emergency Plan implementation.
- g.
Fire.Protection Program implementation.
- h.
PROCESS CONTROL PROGRAM implementation.
i OFFSITE DOSE CALCULATION MANUAL implementation.
- j.
Quality Assurance Program for effluent and environment monitoring.
6.8.2 Each procedure and administrative policy of 6.c8.l above, and-changes thereto, shall be reviewed and approved in accordance with specification 6.5.1.6 or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures.
If\\se,'('-\\. ~
6.8.3 On-the-Spot changes to procedures of Specification 6.8.1 may be made provided:
- a.
The intent of the original procedure is no~ altered;
- b.
The change is approved by two members of the unit management staff, at least one of whom holds a Senior Reactor Operator license on the unit affected; and HOPE CREEK 6-15 Amendment No. 52
INSERT A Procedures of 6.8.1.e and 6.8.1.f shall be reviewed and approved in accordance with the Facility's Security and Emergency Plans or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures.
ATTACHMENT 4 LCR 94-10 NLR-N94051 MARKED UP PROPOSED TECHNICAL SPECIFICATION PAGES SALEM UNIT NO. 1 FACILITY OPERATING LICENSE NO. DPR-70 DOCKET NO. 50-272
AD~INISTRATIVE CONTROLS
===================================F=======================
QUORUM (continued) shall consist of the Chairman or his designated alternate and four members including alternates.
RESPONSIBILITIES 6.5.l.6
- a.
- b.
- c.
- d.
- e.
- f.
- g.
- h.
- i.
The Station Operations Review Committee shall be responsible for:
Review of: (1) Upper tier administrative procedures within the scope I of Regulatory Guide 1.33 (2/78), and changes thereto and (2) Newly created procedures or changes to existing procedures that require a 10CFR50.59 safety evaluation as described in Section 6.5.3.2.d.
Review of all proposed tests and experiments that affect nuclear safety.
Review of all proposed changes to Appendix "A" Technical Specifications.
Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
Review of the safety evaluations that have been completed under the provisions of 10CFR50.59.
Investigation of all violations of the Technical Specifications including the reports covering evaluation and recommendations to prevent recurrence.
Review of all REPORTABLE EVENTS.
Review of facility operations to detect potential nuclear safety hazard*.
Performance of special reviews, investigation* or analyses and report* thereon as requested by the General Manager - Salem Operation*.
Facility Security Plan and implementing procedure* and changes thereto that require a 10CFR50.59
- afety evaluation,.* or involve a potential decrease in the effectiveness of the plan, per 10CFR50.54(p).
Facility Emergency Plan and implementing rocedure* and changes thereto that require a 10CFR50.59 safety or involve a potential decrease in the effectiveness r 10CFR50.54
- 1.
Review of the Fire Protection. Program and implementing procedures and changes thereto that require a 10CFR50.59 safety evaluation.
SALEM -
UNIT 1 6-9 Amendment No. 133
ADMINISTRATIVE CONTROLS
- =*=z==z==~~==z*=*===============================================
REVIEW 6.5.2.4.2
- a.
- b.
- c.
- d.
- f.
- g.
The OSR staff shall review:
The safety evaluations fer changes to procedures, equipment, er systems; and tests er experiments completed under the previsions cf 10CFR50.59, to verify that such actions did not constitute an unreviewed safety question; Proposed changea to procedures, equipment, or systems, and tests or I experiment* that involve an unreviewed safety question aa defined in 10CFRS0.59; Propo*ed change* to Technical Specification* or to th*
Operating License; Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or inatructions having nuclear safety significance; Significant operating abnormalities or deviation* from normal and expected performance cf plant equipment that affect nuclear safety; All REPORTABLE EVENTS; All recognized indications of an unanticipated deficiency in
- ome aapect of design or operation. of structure*, *y*tems or component* that could affect nuclear safety;
- h.
Reports and meeting minutes of the Station Operations Review Committee.
APP ITS 6.S.2.4.3 Audit* of facility activitie* *hall be performed under the cognizance of the OSR *taff. _These audit* shall @ncompas*A ~
- a.
The conformance of facility operation to provision* contained within the Technical Specifications and applicable license condition*.ac leaes enee peE 12 mene~e.
- b.
The performance, training, and qualification* of the entire facility *taff. at leaat Qnse pas 12 mens~**
- c.
The result* of actions taken to correct deficienci** occurring in facility equipment, structure*, *y*tem*, or method of operation that affect nuclear safety. ~ l***t onge pa~ i mcRtRQ
- d.
The performance of activities required by th* Operational Quality Assurance Program to meet the Criteria of Appendix B to 10CFRSO. at lea*t QAQ& per 24 moatb*
SALEM -
UNIT 1 6-12 Amendment No.
133
ADMINISTRATIVE CONTROLS
===========================================================
AUDITS (continued)
TA8 VaQility Emer98AQY Plag ?Qd implemeAtiA9 p~ggQQW588 ac
'leae6 SRBe,eE ld ~QACA8 The Fac:iJ.ity sec 11rity Plan and implementing proc:edw.raa a't leaat eRee per 12 moAtba Any other area of facility operation considered appropriate by the General Manager - Quality Assurance and Nuclear Safety or the Vice President and Chief Nuclear Officer.
The Facility Fire Protection Program and implementing procedures.at lea&t QAQQ per 24 month*
~he fire preeeeeieA aRd loss prevention program implemeatatigR ae leas't QAee pe:ll' 12 moatba utiliziag eitber a qy.alif.i.arli effsiee lieeftsee fiEe p:Ec:Jio&Qio.i.GA aagiaeer(s) or aa 0 11tside iadepeRrlieRt fi~
p~e~eegien eenaulCaAC AA outside iadepeadeat firP protectica QQA&YltaAii *hall ge wiiiliaed at leaaio OAce per li moAtASu The radiological environmental monitoring program and the results thereo~at least QACe per 12 montbs The above audits may be conducted by the Quality Assurance Department or an independent consultant.
Audit plans and final audit reports shall be reviewed by the OSR staff.
RECORDS AND REPORTS 6.S.2.4.4 Records of OSR activities shall be maintained.
Reports of reviews and audits shall be prepared and distributed as indicated below:
- a.
The results of reviews performed pursuant to Section 6.S.2.4.2 shall be reported to the Vice President** and Chief* Nuclear* Officer at least monthly.
- b.
Audit reports prepared pursuant to Section 6.5.2.4.3 shall be forwarded by the auditing organization to the Vice President and Chief Nuclear Officer and to the management positions responsible for the areas audited (1) within 30 day* after completion of the audit for those-au~its conducted by the Quality Assura~ce Department, and (2) within 60 days after.completion of the audit for those audits conducted by an independent consultant.
6.s.2.s ON-SITE SAFETY REVIEW GROUP (SRG)
FUNCTION 6.5.2.5.l The on-Site Safety Review Group (SRG) shall function to provide:
the review of plant design and operating experience for potential opportunities to improve plant safety; the evaluation of plant operatic~s and SALEM -
UNIT 1 6-13 Amendment No. 133
ADMINISTRATIVE CONTROLS
===========================================================
6.8 PROCEDURES AND PROGRAMS 6.8.l Written procedures shall be established, implemented and maintained covering the activities referenced below:
- a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
- b.
Refueling operations.
- c.
Surveillance and test activities of safety related equipment.
- d.
Security Plan implementation.
- e.
Emergency Plan implementation.
- f.
Fire Protection Program implementation.
- g.
PROCESS CONTROL PROGRAM implementation.
- h.
- oFFSITE DOSE CALCULATION MANUAL implementation.
- i.
Quality Assurance Program for effluent and environmental monitoring.
6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed and approved in accordance with Specification 6.5.1.6 or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedure**~~
6.8.3 on-the-spot changes to procedures of 6.8.1 above.may be made provided:
- a.
The intent of the original procedure is not altered.
- b.
- The change i11 approved by two member* of the *plant management staff, at least one of whom holds a Senior Reactor Operator*s License on the unit affected.
- c.
The change is documented and receives the same level of rev~ew and approval as the original procedure under Specification 6.S.3.2a within 14 days of implementation.
SALEM -
UNIT 1 6-17 Amendment *. ~33
INSERT A Procedures of 6.8.1.d and 6.8.1.e shall be reviewed and approved in accordance with the Facility's Security and Emergency Plans or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures.
ATTACHMENT 5 LCR 94-10 NLR-N94051 MARKED UP PROPOSED TECHNICAL SPECIFICATION CHANGES SALEM UNIT NO. 2 FACILITY OPERATING LICENSE NO. DPR-75 DOCKET NO. 50-311
'ADMINISTRATIVE CONTROLS
===========================================================
RESPONSIBILITIES 6.5.1.6 The Station Operations Review Committee shall be responsible for:
- a.
Review of: (1) Upper tier administrative procedures within the scope of Regulatory Guide l.33 (2/78), and changes thereto and (2) Newly created procedures or changes to existing procedures that require a **
10CFR50.59 safety evaluation as described in Section 6.5.3.2.d.
- b.
Review of all proposed tests and experiments that affect nuclear safety.
- c.
Review of all proposed changes to Appendix "A" Technical Specifications.
- d.
Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
- e.
Review of the safety evaluations that have been completed under the provisions of 10CFR50~59.
- f.
Investigation of all violations of the Technical Specifications including the reports covering evaluation and recommendations to prevent recurrence.
- g.
Review of all REPORTABLE EVENTS.
- h.
Review of facility operations to detect potential nuclear safety hazards.
- i.
Performance of special reviews, investigations or analyse~ and reports thereon as requested by the General Manager -
Salem Operations.
Review of the Facility Security Plan and implementing procedures and changes thereto that require a 10CFR50.59 safety evaluation, or involve a potential decrease in the effectiveness of the plan, per 10CFR50.54(p).
Review of the Facility Emergency Plan and implementing procedures and changes thereto that require a 10CFR50.59 safety evaluation, or involve a potential decrease in the effectiveness of the plan, per 10CFR50.54(q *
- 1.
Review of the Fire Protection Program and implementing procedures and changes thereto that require a 10CFR50.59 safety evaluation.
- m.
Review of all unplanned on-site releases of radioactivity to the environs including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence.
SALEM -
UNIT 2 6-9 Amendment No. 112
ADMINISTRATIVE CONTROLS REVIEW 6.5.2.4.2 The OSR staff shall review:
- a.
The safety evaluations for changes to procedures, equipment, or systems; and tests or experiments completed under the provisions of 10CFR50.59, to verify that such action* did not constitute an unreviewed safety question;
- b.
Proposed changes to procedure&, equipment, or systems; and tests or experiments that involve an unreviewed safety question as defined in 10CFR50.59;
- c.
Proposed changes to Technical Specifications or to the Operating License;
- d.
Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance;
- e.
Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety;
- f.
All REPORTABLE EVENTS;
- g.
All recognized indications of an unantic~pated deficiency in some aspect of design or operation of structures, systems or components that could affect nuclear safety;
- h.
Reports and meeting minutes of the Station Operations Review Committee.
AUDITS 6.5.2.4.3 Audits of facility activities shall be performed cognizance of the OSR staff.
These audits shall encompass:
- a.
The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditiona.a-G leas~ enee pe~ 12 men~hea
- b.
The performance, training, and qualifications of the entire facility staf~ at lea*t QRse per 12 men6hs.
- c.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety. at leaat GRG& per 6 meAtRBo
- d.
The performance of activities required by the Operational Quality Assurance Program to meet the Criteria of Appendix B to 10CFR50. at leaat QRC8 per 24 moRtR&
SALEM -
UNIT 2 6-12 Amendment No. 112
~
l
.ADMINISTRATIVE CONTROLS
===========================================================
AUDITS (continued)
~he Faeiliey Smer~eaey Plaa aaa implemeRtiR§ preseaures at least eRse per 12 meRtae.
~Re Faeili~y Seeuriey PlaR aRd implemeR1"iR~ preeedwrea a:
ieas~ SRQa per 12 months V\\ CA\\Ali\\ O~
~~we
\\}'<o\\-et...t \\ ()V\\
- g.
- h.
Any other area of facility operation considered appropriate by the General Manager - Quality Assurance and Nuclear Safety or the Vice President and Chief Nuclear Officer.
The Facility Fire Protection Program and implementing procedures.a: least BRGe per 24 meathsa
()'4\\c\\ \\oss
-pve.-..ie.'4\\.\\-\\ ()V\\
The fi.Ee pl~'f"W\\
at least
\\ Mp~m'l\\.\\a.\\..,oV\\
U*h h ~ \\ Y\\j 'l'i\\
o\\A\\s\\ck
&Ree per 12 meAths utiliaiRg eithe~ a 1fYalified effa.ite lieeRsee
'PEGO'tegt.igR QQR&YltaRt 11R gyta.id.e iRd.ep&RQ&Rt fiEe prstestieR eeRsultaRt shall se utiliaed. at leas1o BRQ& per 36 mgRtR&
i nde.pe.'t\\dQ,V\\\\-
t we.
?l)~t.,t\\()V\\
- j.
The radiological environmental monitoring program and the results thereof. at 1°ast BRSe per 12 meRthsu
~..,\\,
audits may be conducted by the Quality Assurance Department or an independent consultant.
Audit plans and final audit reports shall be reviewed by the OSR staff.
RECORDS AND REPORTS 6.5.2.4.4 Records of OSR activities shall be maintained.
Reports of reviews and audits shall be prepared and distributed as indicated below:
- a.
The results of reviews performed pursuant to Section 6.5.2.4.2 shall be reported to the Vice President and Chief Nuclear Officer at least monthly.
- b.
Audit reports.prepared pursuant to Section 6.5.2.4.3 shall be forwarded by the auditing organization to the Vice President and Chief Nuclear Officer and to the management positions responsible for the areas audited (1) within 30 days after com2letion of the audit for those audits conducted by the Quality Assurance Department, and (2) within 60 days after completion of the audit for those audits conducted by an independent consultant.
6.5.2.5 ON-SITE SAFETY REVIEW GROUP lSRGl FUNCTION 6.5.2.5.1 The on-Site Safety Review Group (SRG) shall function to provide:
the review of plant design and operating experience for potential opportunities to improve plant safety; the evaluation of plant operations and maintenance activities; and advice to management on the overall quality and safety of plant operations.
SALEM -
UNIT 2 6-13 Amendment No. 112 I*
'ADMINISTRATIVE CONTROLS
===========================================================
6.8 PROCEDURES AND PROGRAMS 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:
- a.
The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.
- b.
Refueling operations.
- c.
Surveillance and test activities of safety related equipment.
- d.
Security Plan implementation.
- e.
Emergency Plan implementation.
- f.
Fire Protection Program implementation.
- g.
PROCESS CONTROL PROGRAM implementation.
- h.
OFFSITE DOSE CALCULATION MANUAL implementation.
- i.
Quality Assurance Program for effluent and environmental monitoring.
6.8.2 Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed and approved in accordance with Specification 6.5.1.6 or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures.~
6.8.3 On-the-spot changes to procedures of 6.8.1 above may be made provided:
- a.
The intent of the original procedure is not altered.
- b.
The change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
- c.
The change is documented and receives the same level of review and approval as the original procedure under Specification 6.5.3.2aMithin 14 days of implementation.
SALEM -
UNIT 2 6-17 Amendment No. 112
INSERT A Procedures of 6.8.1.d and 6.8.1.e shall be reviewed and approved in accordance with the Facility's Security and Emergency Plans or 6.5.3, as appropriate, prior to implementation and reviewed periodically as set forth in administrative procedures
- ATTACHMENT 6 LCR 94-05 NLR-N94051 PROPOSED REVISIONS TO THE HOPE CREEK UPDATED FINAL SAFETY ANALYSIS REPORT FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354
1.8.1.33 Conformance to Regulatory Guide 1.33. Revision 2.
February 1978: Quality Assurance Program Requirements (Operation)
HCGS complies with ANSI Nl8.7-1976/ANS-3.2, as endorsed and modified by Regulatory Guide 1. 33.
The contents of the plant operating procedures will comply with the applicable requirements of Section 5.3 of ANSI/ANS-3.2-1982.
See Section 17.2 for further discussion of quality assurance during plant operation.
Conformance to Re"1latory Guide 1.34. Revision 0.
December 28. 1972: Control of Electroslag Weld Properties Regulatory Guide 1.34 is not applic~hle to HCGS because the process is not used.
See Section 1.8.2 for the NSSS assessment of this Regulatory Guide.
1.8.1.35 Conformance to Regulatory Guide 1.35. Revision 2.
January 1976: Inservice Inspection of Ungrouted Tendons in Prestressed Concrete Containment Structures Regulatory Guide 1.35 is not applicable because HCGS. does not have a prestressed concrete containment.
1.8.1.36 Conformance to Regulatory Guide 1.36. Revision 0.
February 23. 1973: Nonmetallic Thermal Insulation for Austenitic Stainless Steel HCGS complies with Regulatory Guide 1.36.
See Section 5. 2. 3 for further discussion and Section 1. 8. 2 for the NSSS assessment of this Regulatory Guide,
~1.~0Y\\ \\s..\\u~'!.\\I\\ 4o ~e... aucl~-\\-
~reque.f\\c.\\e..s:
~s°'-h°" C-.4. Tu_ -pro'-f,~\\o'l\\s of +\\n.e. G'An\\\\*'t 4\\ssu'l~Y'\\le-Proe,'fClW\\
de51\\W \\V\\ ~.\\"lo~. \\1.'2.. \\'D \\'~ud\\~s' 1 ~o~e..'<V\\S -\\1re_ ~ud\\t tye.~u~nt\\~5.
- 1. 8-22 HCGS-UFSAR Revision 0 April 11, 1988
- 3.
Proposed test or experiments that involve an unreviewed safety question as defined in 10CFR50.59.
- 4.
Proposed changes to Technical Specifications or to
- the Operating License.
- 5.
Violations of
- codes, regulations,
- orders, Technical Specifications, procedures or significance.
license requirements, instructions having or nuclear internal safety
- 6.
Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.
- 7.
All reportable events.
- 8.
All recognized indications of an unanticipated deficiency in some aspects of design or operation of safety-related structures,
- systems, or components that could affect nuclear safety.
- 9.
Reports and meeting minutes of the SORG.
13.4.2.1.2 Audits Audits of facility activities that performed under the cognizance of OSR
- 1.
The conformance of facility operations to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
- 2.
The performance,
- training, and qualifications of the entire facility staff at least once per 12 months.
13.4-9 HCGS-UFSAR Revision 0 April 11, 1988
- 3.
The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems, or method of operation that affect nuclear safety at least once per 6 months.
- 4.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10CFR.50, at least once per 24 months.
- 5.
The Facility Emergency Plan and implementing procedures at least once per 12 months
- 6.
The Facility Security Plan and implementing procedures at least once per 12 months.
- 7.
Any other area of facility operation considered appropriate by the General Manager - QA and Nuclear Safety Review or the Vice President and Chief Nuclear Officer.
- 8.
The Facility Fire Protection Program and implementing procedures at least once per 24 months.
- 9.
An independent fire protection and loss prevention program inspection and audit shall be performed at least once per 12 months utilizing either qualified offsite licensee personnel or an outside fire protection firm.
- 10.
An inspection and audit of the fire protection and loss prevention program shall be.. performed by a qualified outside fire consultant at least once per 36 months.
- 11.
The radiological environmental monitoring program and the results thereof at least once per 12 months.
The above audits may be conducted by the Quality Assurance Department or an independent consultant.
reviewed by OSR prior to issuance.
13.4-10 Audit plans will be HCGS-UFSAR Revision 1 April 11, 1989
\\ittS Q~G-E. ":tN'ltNU:ONA\\...L'{ 'B\\..~~\\(_
_J
13.4.2.1.3 Records Records of OSR activities will be prepared and maintained.
Reports of reviews and audits will be distributed as follows:
~c..\\ \\:.\\c.~\\ ()V\\S
(<lV\\d +u'{~'('
de..~\\ \\e..d *,"'
UPS AR Se~-\\-\\ OV\\ \\1. 'l... \\ '6)
- 1.
The results of reviews performed pursuant to Section 13.4.2.1.1 shall be reported to the Vice President and Chief Nuclear Officer at least monthly.
b.'5. 2..4.?>
Audit reports prepared pursuant to Section ll.4.2.1.2 shall be forwarded by the auditing organization to the Vice President and Chief Nuclear Officer and to the management positions responsible for the areas audited
- 1) within 30 days after completion of the audit for those audits conducted by the Quality Assurance Department and
- 2) within 60 days after completion of the audit for those audits conducted by an independent consultant.
13.4.2.2 Onsite Safety Review Group The Onsite Safety Review Group (SRG) was established and functioning prior to initial fuel load.
The functions of the SRG include: the review of plant design and operating experience for potential opportunities for improving plant safety; the evaluation of plant operations and maintenance activities; and advice to management on the overall quality and safety of plant operations.
The SRG makes recommendations for revised procedures, equipment modifications, or other means of improving plant safety to appropriate station/corporate management.
13.4.2.2.1 Organization The SRG consists of the Onsite Safety Review Engineer and three dedicated, full-time engineers.
13.4-11 HCGS-UFSAR Revision 1 April 11, 1989
17.2.17 Quality Assurance Records Records necessary to demonstrate that activities important to quality have been performed in accordance with applicable requirements are identified and maintained in accordance with Regulatory Guide 1.88, as noted in Section 17.2.2.
Documents shall be considered valid records only if stamped or initialed or signed and dated by authorized personnel or otherwise authenticated.
Record types, as a
- minimum, comply with applicable technical specification requirements and include operating logs, maintenance and modification procedures and related inspection results and reportable occurrences.
Design and other QA records are replicated via microform and stored in record facilities at the generating station and at offsite locations.
The Nuclear Department is responsible for the permanent storage of station records.
The retention period for records; permanent storage location; and methods of control, identification, and retrieval are specified by administrative procedure.
Individual station department heads are responsible for submitting applicable de~~rtment records to the designated location for retention.
17.2.18 Audits udits of PSE&G and supplier organizations that implement the QA rogram are performed by QA to verify compliance with the applicable ortions of the program through personnel interview and review of pplicable documents and records, as required.
An annual audit schedule is prepared, identifying audits to be performed and their requency.
Audits are conducted by audit teams comprised of a certified lead auditor and certified auditors, and technical specialists (when deemed necessary).
17.2-42 HCGS-UFSAR Revision 5 May 11, 1993
Audits are conducted using preestablished written procedures and checklists.
Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner.
Required corrective action is documented and verified.
Followup action, including reaudit of deficient areas, is performed.
The audit program conducted by QA includes, but is not limited to, the following activities covered by the QA program:
- 1.
Operation, maintenance, and modification
- 2.
Preparation,
- review, approval, and control of design, specifications, procurement and requisition documents, instructions, procedures, and drawings
- 3.
Inspection programs
- 4.
Indoctrination and training
- 5.
Implementation of operating and test procedures
- 6.
Calibration of measuring and test equipment
- 7.
Fire protection The audit data is analyzed and a written report of the results of each audit is distributed to appropriate management representatives of the organization(s) audited, as well as other affected management personnel.
Included in the report is a statement of QA program effectiveness.
QA is audited by independent auditors at least every two years to verify implementation of the corporate QA program.
Reports of these audits are directed to appropriate PSE&G management personnel.
17.2-43 HCGS-UFSAR Revision 4 April 11, 1992
PROPOSED INSERT FOR UFSAR SECTION 17.2.18 Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records, as required.
An annual audit schedule is developed to identify the audits to be performed and their frequency.
A dominant factor in audit schedule development is performance in the subject area.
Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR.
Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that biennial (2 years) audits of safety related activities are performed.
A list of operational phase activities subject to the audit program is provided in the Technical Specifications and in Table 17.2-1.
To provide added flexibility in scheduling Technical Specification audits of operational phase activities, a 25% extension to the biennial frequency is permitted.
The biennial audit frequency and the 25% extension are not applicable to those audits who~e frequencies are mandated.by0 the.Code of Federal Regulations.
LCR 94-10 NLR-N94051 ATTACHMENT 7 PROPOSED REVISIONS TO THE SALEM UNIT NOS. 1 AND 2 UPDATED FINAL SAFETY ANALYSIS REPORT...
SALEM UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311
outside the range of 3
to 12 percent for E-308, E-309, and E-316 is considered rejectable.
- 6.
Production welding parameters are monitored on a
spotcheck basis by the field welding supervision and the Field Quality Control Group.
Regulatory Guide 1. 32 - USE OF IEEE STANDARD 308-1971. "CRITERIA FOR CI.ASS lE ELECTRIC SYSTEMS FOR NUCLEAR POWER GENERATING STATIONS" The Salem Station design satisfies the requirements of IEEE Standard 308-1971, thereby conforming with the intent of the Regulatory Guide.
The Salem Station Operational Quality Assurance Program conform with the regulatory position as set forth in Regulatory Guide.
will the Regulatory Guide 1.33 - QUALITY ASSURANCE PROGRAM REQUIREMENTS (OPERATION), 2/78 (endorses Nl8.7-1976/ANS 3.2)
The Salem Station Operational Quality Assurance Program will conform with the regulatory position as set forth i.n the Regulatory Guide.
CONTROL OF ELECTROSI.AG WELD PROPERTIES Electroslag welding of Nuclear Classes l and 2
components is confined to the area of reactor coolant piping elbows.
These are made from cast clamshells of ASTM A351 Gr. CF-8M joined together on longitudinal seams by the electroslag process.
Welding of these components was performed under specified weld procedure control monitored by Westinghouse.
PSE&G also established that the shop production welds were in conformance to the procedure qualification.
E )( c.e:p.\\-\\OY\\,*-:.
_:_-..\\u-..~-~-:<\\--\\o-~--~-._-----\\-~e.°'ue..n <.\\.S t~~\\ed \\>>~-\\.~ \\ Y\\ 'Yns\\\\.\\OV\\ C,.\\-...
"1Y'e. ?fO'l\\'S\\o't\\s ot- ""'e.. Q'-'~\\\\~ Assu'<'~1't.e.. ':p(~<etV'i\\ de.sc."'\\be..c\\ \\'f\\
"::ect\\t:M \\1.'L. \\'6 ~\\A~;\\5" 3A-16 ~o\\le.'l'l\\'S -tv-e. o.u.c\\;-\\-
~ve. \\Ae.inc.\\e...s.
SGS-UFSAR Revision 7 July 22, 1987
Design and other QA records are replicated via microform and stored in record facilities at the generating station and offsite locations.
The Nuclear Department is responsible for the permanent storage of station records.
The retention period for records; permanent storage location; and methods of control, identification, and retrieval are specified by administrative procedure.
Individual station department heads are responsible for submitting applicable department records to the designated location for retention.
17.2.18 Audits Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program through personnel interview and review of applicable documents and records, as required.
An annual audit schedule is prepared, identifying audits to be performed and their frequency.
Audits are conducted by audit teams comprised of a certified lead auditor, certified auditors, and technical specialists (when deemed necessary).
Audits are conducted using preestablished written procedures and checklists.
Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner.
Required corrective action is documented and verified.
Followup action, including reaudit of deficient areas, is performed.
The audit program conducted by QA includes, but is not limited to, the following activities covered by the QA program:
- 1.
Operation, maintenance, and modification.
- 2.
Preparation,
- review, approval, and control of design, specifications, procurement and requisition documents, instructions, procedures, and drawings. 17.2-40 SGS-UFSAR Revision 11 July 22, 1991
- 3.
Inspection programs.
- 4.
Indoctrination and training.
- 5.
Implementation of operating and test procedures.
- 6.
Calibration of measuring and test equipment.
- 7.
Fire protection.
activities delineated in Table The audit data is analyzed, and a written report* of the results of each audit is distributed to appropriate management representatives of the organization(s) audited, as well as other affected management personnel.
Included in the report is a statement of QA program effectiveness.
QA is audited by independent auditors at least every 2 years to verify implementation of the corporate QA program.
Reports of these audits are directed to appropriate PSE&G management personnel.
17.2-41 SGS-UFSAR Revision 10 July 22, 1990
PROPOSED INSERT FOR UFSAR SECTION 17.2.18 Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records, as required.
An annual audit schedule is developed to identify the audits to be performed and their frequency.
A dominant factor in audit schedule development is performance in the subject area.
Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR.
Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that biennial (2 years) audits of safety related activities are performed.
A list of operational phase activities subject to the audit program is provided in the Technical Specifications and in Table 17.2-1.
To provide added flexibility in scheduling Technical Specification audits of operational phase activities, a 25% extension to the biennial frequency is permitted.
The biennial audit frequency and the 25% extension are not applicable to those audits whose frequencies are mandated by the Code of Federal Regulations.
ATTACHMENT 8 INFORMATIONAL COPIES OF APPLICABLE EMERGENCY PLAN SECTIONS LCR 94-05 LCR 94-10 NLR-N94051 HOPE CREEK AND SALEM UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSE NOS. NPF-57, DPR-70 AND DPR-75 DOCKET NOS. 50-354, 50-272 AND 50-311
SECTION 17 EMERGENCY PLAN ADMINISTRATION 17.1 Responsibility General The Vice President and Chief Nuclear Officer has the overall responsibility for the development and updating of emergency planning and coordination of the plans with other response organizations.
The organization for coordination and direction of emergency planning matters is shown in Figure 17-1.
The Emergency Preparedness Manager has been delegated the authority to approve the Emergency Plan and Implementing Procedures for adequacy and consistency.
He is assigned the responsibility for ensuring that the Emergency Plan and Implementing Procedures are appropriately interfaced with the plans, procedures, and training of offsite support agencies as required to maintain suitable timely notifications and development of protective action recommendations.
Review and Approval of Emergency Preparedness Documents As appropriate, the applicable Station Operations Review Committee (SORC) reviews emergency plans and procedures as they relate to nuclear safety in accordance with Technical Specifications.
The General Manager.* of Station.. Operations approves plans and procedures applicable to his/her station in accordance with Technical Specifications.
The review and approval of the Emergency Plan, Implementing Procedures, Event Classification Guide, and Emergency Preparedness Administrative Procedures will be done in accordance with Table 17-1.
Training Procedures/Lesson Plans It is the responsibility of the Emergency Preparedness Manager to review and revise the Training Procedures/Lesson *Plans in accordance with the Nuclear Emergency Preparedness Training Program.
The Training Procedures/Lesson Plans are based on the approved Emergency Plan and Procedures.
17.2 Revisions Revisions to the Emergency Plan, and Emergency Plan Implementing Procedures are made whenever such changes are necessary to ensure that the Emergency Plan can be-implemented.
The details are contained in the Emergency Preparedness Administrative Procedures.
AIEP
- 17. 1 Rev. 2
Any holder of the Emergency Plan, and/or Emergency Plan Implementing Procedures may prepare revision(s) to any section or procedure.
Under normal circumstances, implementing procedure changes are coordinated by the department head responsible (Table 17-1) for the given procedure.
A revision request form is filled out by the person preparing the revision with a description of the revision requested by signing and dating the form.
A list of each section or procedure is maintained in front of the Emergency Plan and Emergency Plan Implementing Procedures indicating the latest revision number and effective date.
17.3 Distribution All revisions are distributed by the Document Distribution Group in accordance with Nuclear Department Administrative Procedures.
The document holder revises the document, signs a receipt form, and indicates the date revisions were received or entered.
The form is then returned to the Document Distribution Group.
17.4 Automatic Review The Emergency Plan and associated documents are reviewed at least once each year.
As part of the review, the Event Classification Guide is reviewed with the state and location governments.
The Emergency Plan and associated documents are updated and procedures are improved, based upon training exercises/drills, and changes onsite or i~ the environs.
Agreement letters from offsite agencies and local support groups are verified or updated biennially or when changes/revisions to the Plan are implemented which could affect their responsibilities.
Updating of telephone numbers is done quarterly.
The Emergency Preparedness Manager coordinates this review and requests that each person responsible for a controlled copy of each Emergency Plan submit revisions as necessary.
17.5 Independent Review The Emergency Plan and associated documents receive an independent review on an annual basis, by the General Manager -
Quality Assurance/Nuclear Safety Review.
Management directives provide instructions for evaluation* and correction of audit findings, training, readiness testing, and emergency equipment.
The results of the review and actions taken are forwaroed to the Station General Managers, the General Manager - Nuclear Services, the Emergency Preparedness Manager, and the reviewers.
The records of these reviews are retained for five (5) years.
AIEP 17.2 Rev. 2
TABLE 17-1
- REVIEW AND APPROVAL OF EMERGENCY PLAN DOCUMENTS DOCUMENT EMER PLAN ALL SECTIONS SGS ECG HCGS ECG ST*ATION QUALI.
Yes RESP.
MGR EP Mgr.
OM-SGS Yes
-OPS OM-HCGS Yes
-OPS EP MGR Yes Yes Yes
- GM QA/
SAFETY REV.
As req.
As req.
As req.
- STATION OPER REV COMM As required As required As required GM STATION OPS.
GM-SGS GM-HCGS GM-SGS
~GM-HCGS ARTIFICIAL ISLAND EMERGENCY PLAN IMPLEMENTING PROCEDURES SGS lOOS Yes OM-SGS-OPS Yes As As GM-SGS 200S Yes OM/TM/EPM-Yes required required GM-SGS 300S Yes As Yes GM-SGS required RP/C Mgr-so HCGS lOOH Yes OM-HCGS Yes As As GM-HCGS 200H Yes OPS Yes raquired requl.red GM-HCGS OM/TM/EPM-300H Yes As Yes GM-HCGS required RP/C Mgr-HC EOF GM-SGS GM-HCGS 400 Yes EP Mgr.
Yes As As Yes 500 Yes GM-E&PB Yes required required Yes 600 Yes Mgr.-Rad.
Yes Yes Pro. Serv.
700 Yes EP Mgr.
Yes Yes ENC Yes Pub. Info.
Yes As As GM-SGS 800 Mgr.
required required GM-HCGS Security As As GM-SGS 900 Yes Sec. Mgr.
Yes required required GM-HCGS EP Admin As As GM-SGS 1000 Yes EP Mgr.
Yes required required GM-HCGS Please see Notes on page 17.5 AIEP 17.4 Rev. 2
~I
TABLE 17-1 (cont)
NOTES:
Procedures undergoing revisions that are editorial will require approval of the Emergency Preparedness Manager ONLY.
Review required if 10CFR50.59 Safety Evaluation was performed.
AIEP 17.5 Rev. 2
ATTACHMENT 9 INFORMATIONAL COPIES OF APPLICABLE SECURITY PLAN SECTIONS HOPE CREEK AND SALEM UNIT NOS. 1 AND 2 LCR 94-05 LCR 94-10 NLR-N94051 FACILITY OPERATING LICENSE NOS. NPF-57, DPR-70 AND DPR-75 DOCKET NOS. 50-354, 50-272 AND 50-311
SAF&:..~l:ARDS INFORMA1'ION DETERMINATION Name 1JfvMJ.c{(J<ttuJ/
Tlllt "" k:f/JtJ,,#,qfkh,¢.;_
Orp.llratien r c ; a..
I Date Ecf\\11.CvED,.-- 3/ro/<1+
CILVTEK 13 SECU.Rl'IT AUDITS 13.1 Audits Polley A menagement auda Is conducted of the physical security program, with the exception of the Personnel Access Program, every 12 months by Individuals Independent of the security organization. Normally these audits are conducted by the QuaUty Assurance Department; however, the services of an outside organization may be used. The results of the audit and evaluation and recommendations for any corrections and Improvements are documented and reported to the Qeneral Manager - Nuclear Services. The reports are maintained for flve years r.md arc available for Inspection by authorized representatives of the U.S. Nuclear Regulatory Commission.
In accordance with the requirements of 10 LfR 73.56, audits of the Personnel Access Program are conducted every 24 months following an Initial audit within 12 months of program ltnplementatlon.
13 *.l Scope of Audits The management audit nonnally conducted by the Quality Assurance Department lncludes but is not llmf ted to the following:
(1)
Review and audit of the Security Plan, Contingency Plan, Training and QualificatJon Plan, and their implementing procedures.
(2) evaluation of the physical protection system and se(.urlty practices effectiveness (3)
Review and evaluation of the physical protection system testing and maintenance program.
(4)
Revtcw and audit of the LLEA response commitments..
(5)
Assessment of the effectiveness of Safeguards Information protection.
13.3 Audit Reports Audit reports address compliance with Security Plans and evaluation of the effectiveness of the physical protection system.
In instances where non~compllance exists or the SP Rev.4 Page 40 uf 43
L effecttveness Is In question, recommendations for corrections or Improvements wm be made.
13.4 Respunse to Audits Audlt ftndlngs are reported to the Qeneral Manager - Nuclear SeIVtces. The Manager
- Slte Protection Is directed to resolve any deftdencle.s In a tlmely manner.
SP SAFEGUARDS INFORMATION DETERMINATION Name ftlt(k/JIU/,c.£ Title Swl1~ ~+1 'Ke~ W,~ Jor, Oraaolzation.... ?_S'_,E..-4......
- G-__ r--r
__ ~-----
Date K'cMoyE'.D
- -sjio/q9.
Rev.4 Page 41of43