ML18152A048

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Proposed Tech Specs Deleting Requirement for Station Nuclear Safety & Operating Committee & Audit Frequencies
ML18152A048
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 07/20/1993
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
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ML18152A049 List:
References
NUDOCS 9307290103
Download: ML18152A048 (44)
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Text

e ATTACHMENT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES SURRY POWER STATION

g.
h.

e TS 6.1-8

9.

Deleted.

10.

Deleted.

11.

Review every unplanned onsite release of radioactive material to the environs exceeding the limits of Specification 3.11, including the preparation of reports covering evaluation, recommendations and disposition of the corrective action to prevent recurrence and the forwarding of these reports to the Vice President - Nuclear Operations and to the Management Safety Review Committee.

12.

Review of changes to the Process Control Program and the Offsite Dose Calculation Manual.

Authority The SNSOC shall:

1.

Provide written approval or disapproval of items considered under (1) through (3) above.

SNSOC approval shall be certified in writing by an Assistant Station Manager.

2.

Render determinations in writing with regard to whether or not each item considered under (1) through (5) above constitutes an unreviewed safety question.

3.

Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President -

Nuclear Operations and to the Management Safety Review Committee of disagreement between SNSOC and the Station Manager; however, the Station Manager shall have responsibility for resolution of such disagreements pursuant to 6.1.A above.

Records The SNSOC shall maintain written minutes of each meeting and copies shall be provided to the Vice President - Nuclear Operations and to the Management Safety Review Committee.

Amendment Nos.

5.

TS6.1-11 Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

6.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

7.

Events requiring written notification to the Commission.

8.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.

9.

Reports and meeting minutes of the SNSOC.

h.

Audits Audits of facility activities shall be performed under the cognizance of the MSRC. These audits shall encompass:

1.

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

2.

The performance, training and qualifications of the entire facility staff.

I

3.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

Amendment Nos.

e TS 6.1-12

4.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50.

5.

Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.

6.

The Fire Protection Program and implementing procedures.

7.

An independent fire protection and loss prevention inspection and audit shall be performed utilizing an outside qualified fire consultant.

8.

The radiological environmental monitoring program.

9.

The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.

10.

The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive waste.

Amendment Nos.

e e

TS 6.4-6 H.

Practice of site evacuation exercises shall be conducted annually, following emergency procedures and including a check of communications with off-site report groups.

I.

J.

K.

Deleted.

Deleted.

Systems Integrity The licensee shall implement a program to reduce leakage from systems outside containment that would or could contain highly radioactive fluids during a serious transient or accident to as low as practical levels.

This program shall include the following:

1.

Provisions establishing preventive maintenance and periodic visual inspection requirements, and

2.

Integrated leak test requirements for each system at a frequency not lo exceed refueling cycle intervals.

Amendment Nos.

TS 6.5-3

9.

Records of the service lives of all hydraulic and mechanical snubbers on safety-related systems, including the data at which the service life commences and associated installation and maintenance records.

10.

Records of the Station Emergency Plan and implementing procedures audits.

11.

Records of the Station Security Plan and implementing procedures audits.

12.

Records of reviews performed for changes made to the OFFSITE DOSE CALCULATION MANUAL and the PROCESS CONTROL PROGRAM.

Amendment Nos.

ATTACHMENT 2 DISCUSSION AND SIGNIFICANT HAZARDS CONSIDERATION EVALUATION SURRY POWER STATION

e Discussion of Changes Introduction Currently, the Administrative Controls section of the Standard Technical Specifications for Westinghouse Plants (NUREG-1431, Vol. 1) states that the combination of reviews and audits should be integrated "into a cohesive program that provides senior management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability." Therefore, these administrative tools should be sufficiently flexible to allow for senior management direction of resources to focus upon areas requiring increased attention.

The proposed changes to the Technical Specification administrative controls would provide such flexibility through the elimination of certain rigid audit frequencies.

Additionally, references to reviews and audits of the facility's Emergency Plan and Physical. Security Plan (and of their associated implementing procedures) would be removed from the Technical Specifications because those requirements presently exist within the individual Plans. This action reflects the guidance provided in an NRC proposed generic communication (58 FR 17293).

Background

The minimum scope and schedules for the audit program have been specified by tt,e Administrative Controls section of each facility's Technical Specifications. The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements from various sources including the Code of Federal Regulations (Physical Security Program, Fitness For Duty Program, etc.),

Standard Technical Specifications, NRC Generic Letters (annual, biennial, and triennial Fire Protection audits), industry guidelines and standards (Conformance to Technical Specifications and Operating License, Effectiveness of Corrective Actions, and Training audits). The audits specified by these sources are meant to address programs which are deemed to be essential to the effective management of each nuclear facility. However, the rigid schedules dictated by the Technical Specifications do not allow management the flexibility to recognize exceptional performance by certain organizations, and resources which could be devoted to areas with perceived weaknesses are diluted by the requirement to audit strong programs at the frequencies set forth in the Technical Specifications. The proposed changes would provide for decreasing the frequencies of certain audits, increasing the frequency of the triennial fire protection audit to biennial, and maintaining the frequency of those audits presently scheduled biennially. Additional flexibility would also be introduced by allowing a 25% extension to the frequency of most audits (presently defined in the Operational Quality Assurance Program's commitment to NRC Regulatory Guide 1.74, "Quality Assurance Terms and Definitions," as it endorses ANSI N45.2.10-1973). The exceptions to this frequency extension or "grace period" would be those audits which have frequencies specifically delineated by the Code of Federal Regulations (i.e.,

Emergency Plan and Implementing Procedures Audit, Physical Security Plan and Implementing Procedures Audit, and Fitness For Duty Audit).

Page 1 of 10

e On April 1, 1993, the NRC published a notice of opportunity for public comment for a proposed generic communication (58 FR 17293) which. provides guidance for relocating certain requirements (without reducing them) from the Technical Specifications to other NRG-approved program documents. The proposed generic communication specifically addresses the reviews and audits of the Emergency Plan and implementing procedures and the Physical Security Plan and implementing procedures. Currently, the requirements for these reviews and audits are incorporated into the Surry Emergency and Security Plans. The proposed changes would delete the redundant references in the facility's Technical Specifications to the requirements which originate in Title 1 O of the Code of Federal Regulations [1 O CFR 50.54(t) for Emergency Preparedness and 1 O CFR 50.54(p), 1 O CFR 73.40, 1 O CFR 73.55, and 1 O CFR 73.56 for Security].

Description Of Specific Changes The proposed amendment would eliminate the references to specific frequencies for each of the Technical Specification required audits and eliminate reference to reviews and audits of the Emergency Plan and Security Plan. Instead, a statement would be added to the Operational Quality Assurance Program specifying that the audits listed in the Technical Specifications would be accomplished on a biennial (2 years) frequency as defined by Operational Quality Assurance Program commitments to NRC Regulatory Guide 1.74 and as directed by administrative procedures and/or management.

The requirements for reviews and annual audits of the facility Emergency Plan and Security Plan (and their associated implementing procedures) are currently delineated within the NRG-approved Emergency Plans and Security Plans for Surry Power Station as provided for in the NRC's proposed generic communication.. Each of the proposed changes to the Technical Specifications is discussed by line item below:

Surry Unit 1 and Unit 2 Technical Specifications:

ADMINISTRATIVE CONTROL line item 6.1.C.1.f.9 has been deleted. The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Plant Security Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved site Security Plan and associated administrative controls. As such, this change complies with the proposed guidance provided in the NRC proposed generic communication (58 FR 17293).

ADMINISTRATIVE CONTROL line item 6.1.C.1.f.10 has been deleted. The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Emergency Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved Site Emergency Plan and associated administrative controls.

As such, this change complies with the proposed guidance provided in the NRC proposed generic communication (58 FR 17293).

Page 2 of 10

ADMINISTRATIVE CONTROL 6.1.C.2.h has been revised to delete the references to specific audit frequencies.

In accordance with the Standard Review Plan (SRP) Section 17.3 ("Quality Assurance Program Description")

guidance on planned and periodic assessments sch~duling and resource allocation, the following statement is being prepared for Section 17.2.18

("Audits") of the Operational Quality Assurance Program Topical Report:

The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications.

Audits of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner which assures that biennial (2 years) audits of safety related activities are completed.

The audits are regularly scheduled on a formal preplanned audit schedule.

The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management.* The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists.

This change neither alters the function nor diminishes the quality of the Audit Program.

The Management Safety Review Committee (MSRC) retains responsibility for oversight of the Quality Assurance Audit Program. The sole change to the process is associated with the audit frequencies, including the definition of those frequencies. Specifically, the definition of "biennial (2 years)"

is provided in the Operational Quality Assurance Program's commitment to Regulatory Guide 1. 74 and ANSI N45.2.10-1973.

Said definition allows an extension for time intervals not specified in the Technical Specifications of up to 25%.

Therefore, the maximum time between specific audits could be 30 months.

The extension would not be applicable to those audits with frequencies mandated by the Code of Federal Regulations (e.g., Emergency Plan, Security Plan, and Fitness For Duty audits). The Technical Specification required audits and the impacts of the proposed changes are listed below:

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

Applicable portions of the Technical Specifications and license conditions are assessed during each audit for the particular area(s) being audited, and an annual -audit is conducted to evaluate those areas which are not evaluated in other audits.

Reducing the frequency of the annual audit to biennial (2 years)

Page 3 of 1 O

will not adversely impact compliance with those provisions of the Technical Specifications, the commitments in the Operational Quality Assurance Program Topical Report to ANSI N18.7-1976, or the effectiveness of audits performed. Compliance with the, Technical Specifications and license conditions is evaluated more often than each 12 months although not in a single Technical Specification audit.

The performance, training, and qualifications of the entire facility staff.

Audits of the facility staff's qualifications ("Training Audits") are conducted annually.

The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if needed. This added versatility is not projected to adversely impact the effectiveness of eithe,r the Nuclear Training Program or the Audit Program, because management can increase or decrease the audit frequency based

  • Upon observed performance and importance to safety.

A statement is being added to clarify the Company's commitment to NRC Regulatory Guide 1.33 in the Operational Quality Assurance Program Topical Report. Specifically, the requirement to perform the Training Audit every 12 months is being clarified to use the biennial (2 years) frequency as stated in Section 17.2.18 of the Topical Report.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

The results of actions taken to correct identified deficiencies are evaluated as part of each audit for the specific area being audited, and currently, an audit is performed every 12 months to evaluate the programmatic controls which govern the corrective action process. The proposed Technical Specification changes would not negatively affect the review of corrective actions in each audit.

Only the annual audit of programmatic controls will be affected in that management will be given flexibility to adjust the audit's frequency based upon performance as evidenced through trends and other performance indicators. As such, the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program.

Page 4 of 1 O

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 1 O CFR

50.

This audit is currently performed "at least once per 24 months."

The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, if needed. This would allow the scheduli*ng of audits to be performance based.

The Emergency Plan and implementing procedures and the Security Plan and implementing procedures.

The proposed change would not impact these audits whose frequencies are mandated by Title 1 O of the Code of Federal Regulations and the NRG-approved plans.

Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.

There is no impact upon this Technical Specification line item.

The Fire Protection Program and implementing procedures.

This audit is currently performed "at least once per 24 months."

The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, if needed. This would allow the audit to be scheduled during the performance of activities which impact nuclear safety.

Hence, the only impact of the proposed change upon the biennial

  • fire protection audit would be to make it more performance based.

The independent fire protection and loss prevention inspection and audit utilizing either qualified offsite licensee personnel or an outside fire protection firm (annual audit) and an inspection and audit of the fire protection and loss prevention program by an outside qualified fire consultant (triennial audit).

The proposed changes will combine the annual and triennial audits into one biennial audit which will be alternated with the Fire Protection Program Audit (see above item). 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 Audit Program, Page 5 of 10

e because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features.

The radiological environmental monitoring program.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the radiological environmental monitoring program's performance to a maximum of 30 months, if needed.

The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. This flexibility is consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The Offsite Dose Calculation Manual (ODCM) and implementing procedures.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the program implementing the Offsite Dose Calculation Manual to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators.

The proposed frequency is consistent with the original Technical Specification requirement to audit the ODCM every 24 months.

Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e.,

refer to NRC response to NUMARC for question 118 in third set o'f Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

Page 6 of 10

The Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the Process Control Program to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. The proposed frequency is consistent with the original Technical Specification requirement to audit the PCP every 24 months. Also, the added versatility in the audit program will continue to be consistent with* guidance provided by the NRC relative to the forthcoming implementation of the revised 10 CFR 20.1101 (c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The purpose, scope, and thoroughness of QA audits will not be affected, management oversight of the audit process will not be diminished, and the audits will be performed at frequencies commensurate with safety significance and not less than biennially (as defined above). As such, these changes are

-consistent-with the intent of the regulatiGns and are an acceptable alternative.

Specific line item changes involving the audit process include:

ADMINISTRATIVE CONTROLS 6.1.C.2.h.1, 6.1.C.2.h.2, 6.1.C.2.h.11, 6.1.C.2.h.12, and 6.1.C.2.h.13 have been revised to delete the phrase "at least once per 12 months."

ADMINISTRATIVE CONTROL 6.1.C.2.h.3 has been revised to delete the phrase "at least once per 6 months."

  • ADMINISTRATIVE CONTROLS 6.1.C.2.h.4 and 6.1.C.2.h.8 have been revised to delete the phrase "at least once per 24 months."

ADMINISTRATIVE CONTROL 6.1.C.2.h.9 has been revised to delete the term "annually."

ADMINISTRATIVE CONTROL 6.1.C.2.h.10 has been revised to delete the phrase "at intervals no greater than 3 years."

ADMINISTRATIVE CONTROLS 6.1.C.2.h.5 and 6.1.C.2.h.6 have been deleted. The requirements for these audits (Emergency Plan and Security Plan) are specified within the Surry Power Station Emergency Plan and Surry Power Station Security Plan, respectively.

Additionally, Page 7 of 10

e ADMINISTRATIVE CONTROLS 6.1.C.2.h.9 and 6.1.C.2.h.10 have been combined into one line item. Subsequently, line items 6.1.C.2.h.7 through 6.1.C.2.h.13 have been renumbered to line items 6.1.C.2.h.5 through 6.1.C.2.h.10 as part of this change.

ADMINISTRATIVE CONTROL 6.5.B.10 has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

ADMINISTRATIVE CONTROL 6.5.B.11 has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

ADMINISTRATIVE CONTROL 6.4.H has been revised to delete the last sentence "An annual review of the Emergency Plan will be performed." Title 10 of the Code of Federal Regulations (CFR) Part 50.54(t) requires a licensee to provide for the development, revision, implementation, maintenance, and a review by an independent organization at least every 12 months of its emergency preparedness program and associated implementing procedures.

Since the requirements for these activities are stated in the CFR and are included in the Surry Power Station Emergency Plan (Section 8.9), this change does not diminish the effectiveness of the site's emergency preparedness, nor does it lessen the specific program requirements.

ADMINISTRATIVE CONTROL 6.4.1 has been deleted. Title 10 of the Code of

-Federal Regulations-(CFR) Parts 50.54(p), 73.40, 73.55, _and -73.56_ require a __ _

licensee to provide for the development, revision, implementation, maintenance, and review by an independent organization of its physical security plan, security contingency plans, and associated implementing procedures at least every 12 months.

Since the requirements for these activities are stated in the CFR and are included in the Surry Power Station Security Plan (Section 1.1.2.a), this change neither diminishes the effectiveness of the physical security program nor lessens the specific program requirements.

ADMINISTRATIVE CONTROL 6.4.J has been deleted. 10 CFR 50.48 requires the development, implementation, and maintenance of a Fire Protection Plan and revisions thereto in accordance with the provisions of 1 O CFR 50, Appendix R and the NRC's Safety Evaluation Report accepting the Fire Protection Plan for the Surry Power Station (which satisfies the provisions of Appendix A to Branch Technical Position BTP APCSB 9.5-1 ).

Additionally, Surry Technical Specification 6.1.C.1.f.1 requires SNSOC review *of procedure changes which affect nuclear safety. The Operational Quality Assurance Program commits to NRC Regulatory Guide 1.33-1978, which defines the Plant Fire Protection Program as safety-related (Regulatory Guide 1.33, Appendix A, Section 1.I). As such, the requirements for implementing the Fire Protection Program and for reviewing that program every two years are neither altered nor diminished.

  • Page 8 of 1 o

Significant Hazards Consideration The standards used to arrive at a determination that a Technical Specification change request involves no significant hazards consideration are included in the Commission's regulations, 1 O CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is addressed as follows:

(1)

Operation of the facility in accordance with the proposed technical specifications would 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 this Technical Specification change which only affects review and audit frequencies. This Technical Specification change 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 this change.

No systems, equipment, or components are affected by the proposed change.

Thus, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR are not increased by this change.

-The j:>rop*osed change only affects-*review and* audit frequencies: As such, -the *

  • 1 proposed change has no impact on accident initiators or plant equipment, and thus, does not affect the probabilities or consequences of an accident.

Therefore, we conclude that this change does not significantly increase the probabilities or consequences of an accident.

(2)

Operation of the facility in accordance with the proposed-technical specifications would 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, a change related to audit functions cannot produce a new accident scenario or produce a new type of equipment malfunction. Also, this change does not alter any existing accident scenarios.

The proposed change does not affect equipment or its operation, and, thus, does not create the possibility of a new or different kind of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident.

(3)

Operation of the facility in accordance with the proposed technical specifications would not involve a significant reduction in a margin of safety.

The proposed change concerning conduct of reviews and audits does not Page 9 of 10

directly affect plant equipment or operation. Safety limits and limiting safety system settings are not affected by this proposed change.

Therefore, use of the proposed Technical Specification would not involve any reduction in the margin of safety.

Based on the above, we have determined that the Technical Specification change request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this Technical Specification change request does not involve a significant hazards consideration.

Page 1 O of 1 O

e.

ATTACHMENT 3 PROPOSED TECHNICAL SPECIFICATION CHANGES NORTH ANNA POWER STATION

II e

ADMINISTRATIVE CONTROLS MEETING FREQUENCY 6.5.1.4 The SNSOC shall meet at least once per calendar month and as convened by the SNSOC Chairman or his designated alternate.

6.5.1.5 A quorum of the SNSOC consists of the Chairman or Vice-Chairman and two members including alternates.

RESPONSIBILITIES 6.5.1.6 The SNSOC shall be responsible for:

a.

Review of 1) all procedures required by Specifications 6.8.1, 6.8.2, and 6.8.3 and changes thereto, 2) all programs required by Specification 6.8.4 and changes thereto, 3) any other proposed procedures or changes thereto as determined by the Station Manager to affect nuclear safety.

b. Review of all proposed tests and experiments that affect nuclear safety.
c. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.
a. -Revievi of -all pr6posed changes to Appendix "A" Technical Specifications-and Appendix "B" Environmental Protection Plan. Recommended changes shall be submitted to the Station Manager.
e.

Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President - Nuclear Operations and the MSRC.

f.

Review of all REPORTABLE EVENTS and Special Reports.

g. Review of facility operations to detect potential nuclear safety hazards.
h. Performance of special reviews, investigations or analyses, and reports thereon as requested by the Chairman of the Station Nuclear Safety and Operating Committee or Station Manager.
i. Deleted.
j. Deleted.

NORTH ANNA - UNIT 1 6-6 Amendment No.

ADMINISTRATIVE CONTROLS

e.

Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

g.

Events requiring written notification to the Commission.

h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
i. Reports and meetings minutes of the SNSOC.

AUDITS 6.5.2.8 Audits of facility activities shall be performed under the cognizance of the MSRC. These audits shall encompass:

a. The conformance of facility operation to prov1s1ons contained within the Technical Specifications and applicable license conditions.
b. The performance, training and qualifications of the entire facility staff.
c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 1 O CFR 50.
e. Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.
f. The Fire Protection Program and implementing procedures.
g. An independent fire protection and loss prevention inspection and audit shall be performed utilizing an outside qualified fire consultant.
h. The Radiological Environmental Monitoring Program and the results thereof.

NORTH ANNA - UNIT 1 6-9 Amendment No.

ADMINISTRATIVE CONTROLS

i. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.

j. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.

AUTHORITY 6.5.2.9 The MSRC shall report to and advise the Senior Vice President - Nuclear on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.1 O Records of MSRC activities shall be prepared, approved and distributed as indicated below:

a. Minutes of each MSRC meeting shall be prepared, approved and forwarded to the Senior Vice President - Nuclear within 14 days of each meeting.
b. Reports of reviews with safety significant findings encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Senior Vice President - Nuclear within 14 days following completion of the review.
c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Senior Vice President - Nuclear and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.

NORTH ANNA - UNIT 1 6-1 0 Amendment No.

II ADMINISTRATIVE CONTROLS

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, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975.

6.8.2 Each procedure of 6.8.1 above, except 6.8.1.d, 6.8.1.e, and 6.8.1.f and changes thereto, shall be reviewed and approved by the SNSOC prior to implementation and reviewed periodically as set forth in administrative procedures. Procedures of 6.8.1.d, 6.8.1.e, and 6.8.1.f shall be reviewed and approved as set forth in the facility's Security Plan, Emergency Plan, and section 6.5.1.6.m of the Technical Specifications, respectively.

SNSOC approval shall be certified in writing by an Assistant Station Manager.

6.8.3 Temporary 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 supervisory staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
c. The change is documented, reviewed, and approved by the SNSOC within 14 days of implementation. SNSOC approval shall be certified in writing by an Assistant Station Manager.

6.8.4 The following programs shall be established, implemented, and maintained:

a.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the recirculation spray, safety injection, chemical and volume control, gas stripper, and hydrogen recombiners.

The program shall include the following:

( i } Preventive maintenance and periodic visual inspection requirements, and

( i i) Integrated leak test requirements for each system at refueling cycle intervals or less.

NORTH ANNA - UNIT 1 6-1 3 Amendment No.

II e

ADMINISTRATIVE CONTROLS

r. CONTAINMENT STRUCTURAL INTEGRITY.

Specification 4.6.1.6.

For any abnormal degradation of the containment structure detected during the performance of Specification 4.6.1.6, an initial report shall be submitted within 1 O days after the completion of Specification 4.6.1.6. A final report, which includes (1) a description of the condition of the liner plate and concrete, (2) inspection procedure, (3) the tolerance on cracking, and (4) the corrective actions taken, shall be submitted within 90 days after the completion of Specification 4.6.1.6.

6. 1 0 RECORD RETENTION 6.1 O.1 The following records shall be retained for at least five years:
a.

Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.
c.

ALL REPORTABLE EVENTS and Special Reports.

d.

Records of surveillance activities, inspections and calibrations required by these Technical Specifications.

e.

Records of changes made to Operating Procedures.

f.

Records of radioactive shipments.

g.

Records of sealed source leak tests and results.

h. Records of annual physical inventory of all sealed source material of record.
i.

Records of the Station Emergency Plan and implementing procedures audits.

j. Records of the Station Security Plan and implementation procedures audits.

6.10.2 The following records shall be retained for the duration of the Facility Operating License:

NORTH ANNA - UNIT 1 6-22 Amendment No.

II ADMINISTRATIVE CONTROLS MEETING FREQUENCY 6.5.1.4 The SNSOC shall meet at least once per calendar month and as convened by the SNSOC Chairman or his designated alternate.

6.5.1.5 A quorum of the SNSOC consists of the Chairman or Vice-Chairman and two members including alternates.

RESPONSIBILITIES 6.5.1.6 The SNSOC shall be responsible for:

a.

Review of 1) all procedures required by Specifications 6.8.1, 6.8.2, and 6.8.3 and changes thereto, 2) all programs required by Specification 6.8.4 and changes thereto, 3) any other proposed procedures or changes thereto as determined by the Station Manager to affect nuclear safety.

b. Review of all proposed tests and experiments that affect nuclear safety.
c.

Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

d.

Review of all proposed changes to Appendix "A" Technical Specifications and Appendix "B" Environmental Protection Plan. Recommended changes shall be submitted to the Station Manager.

e.

Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Vice President - Nuclear Operations and the MSRC.

f.

Review of all REPORTABLE EVENTS and Special Reports.

g. Review of facility operations to detect potential nuclear safety hazards.
h. Performance of special reviews, investigations or analyses, and reports thereon as requested by the Chairman of the Station Nuclear Safety and Operating Committee or Station Manager.
i. Deleted.
j. Deleted.

NORTH ANNA - UNIT 2 6-7 Amendment No.

II ADMINISTRATIVE CONTROLS

e. Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
f.

Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.

g. Events requiring written notification to the Commission.
h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.

i. Reports and meetings minutes of the SNSOC.

AUDITS 6.5.2.8 Audits of facility activities shall be performed under the cognizance of the MSRC. These audits shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.
b. The performance, training and qualifications of the entire facility staff.
c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B", 1 O CFR 50.
e. Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.
f. The Fire Protection Program and implementing procedures.
g. An independent fire protection and loss prevention inspection and audit shall be performed utilizing an outside qualified fire consultant.
h. The Radiological Environmental Monitoring Program and the results thereof.

NORTH ANNA - UNIT 2 6-1 0 Amendment No.

II ADMINISTRATIVE CONTROLS

i. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.

j. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.

AUTHORITY 6.5.2.9 The MSRC shall report to and advise the Senior Vice President - Nuclear on those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8.

RECORDS 6.5.2.1 O Records of MSRC activities shall be prepared, approved and distributed as indicated below:

a.

Minutes of each MSRC meeting shall be prepared, approved and forwarded to the Senior Vice President - Nuclear within 14 days of each meeting.

b. Reports of reviews with safety significant findings encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Senior Vice President - Nuclear within 14 days following completion of the review.
c. Audit reports encompassed by Section 6.5.2.8 above, shall be forwarded to the Senior Vice President - Nuclear and to the management positions responsible for the areas audited within 30 days after completion of the audit by the auditing organization.

NORTH ANNA - UNIT 2 6-1 1 Amendment No.

II e

ADMINISTRATIVE CONTROLS

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, using the guidance in Regulatory Guide 1.21, Revision 1, June 1974 and Regulatory Guide 4.1, Revision 1, April 1975.

6.8.2 Each procedure of 6.8.1 above, except 6.8.1.d, 6.8.1.e, and 6.8.1.f and changes thereto, shall be reviewed and approved by the SNSOC prior to implementation and reviewed periodically as set forth in administrative procedures. Procedures of 6.8.1.d, 6.8.1.e, and 6.8.1.f shall be reviewed and approved as set forth in the facility's Security Plan, Emergency Plan, and section 6.5.1.6.m of the Technical Specifications, respectively.

SNSOC approval shall be certified in writing by an Assistant Station Manager.

6.8.3 Temporary 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 supervisory staff, at least one of whom holds a Senior Reactor Operator's License on the unit affected.
c. The change is documented, reviewed, and approved by the SNSOC within 14 days of implementation. SNSOC approval shall be certified in writing by an Assistant Station Manager.

6.8.4 The following programs shall be established, implemented, and maintained:

a.

Primary Coolant Sources Outside Containment A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident to as low as practical levels. The systems include the recirculation spray, safety injection, chemical and volume control, gas stripper, and hydrogen recombiners.

The program shall include the following:

( i ) Preventive maintenance and periodic visual inspection requirements, and

( i i) Integrated leak test requirements for each system at refueling cycle intervals or less.

NORTH ANNA - UNIT 2 6-1 4 Amendment No.

II e

e ADMINISTRATIVE CONTROLS

6. 1 0 RECORD RETENTION 6.10.1 The following records shall be retained for at least five years:
a.

Records and logs of facility operation covering time interval at each power level.

b. Records and logs of principal maintenance activities, inspections, repair and replacement of principal items of equipment related to nuclear safety.
c.

ALL REPORTABLE EVENTS and Special Reports.

d.

Records of surveilfance activities, inspections and calibrations required by these Technical Specifications.

e.

Records of changes made to Operating Procedures.

f.

Records of radioactive shipments.

g.

Records of sealed source leak tests and results.

h. Records of annual physical inventory of all sealed source material of record.

i. Records of the Station Emergency Plan and implementing procedures audits.

j. Records of the Station Security Plan and implementation procedures audits.

6.10.2 The following records shall be retained for the duration of the Facility Operating License:

a Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.
c.

Records of facility radiation and contamination surveys.

d.

Records of radiation exposure for all individuals entering radiation control areas.

e.

Records of gaseous and liquid radioactive material release to the environs.

f.

Records of transient or operational cycles for those facility components identified in Table 5.7-1.

NORTH ANNA - UNIT 2 6-2 2 Amendment No.

ATTACHMENT 4 DISCUSSION AND SIGNIFICANT HAZARDS CONSIDERATION EVALUATION NORTH ANNA POWER STATION

e Discussion of Changes Introduction Currently, the Administrative Controls section of the Standard Technical Specifications for Westinghouse Plants (NUREG-1431, Vol. 1) states that the combination of reviews and audits should be integrated "into a cohesive program that provides senior management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability." Therefore, these administrative tools should be sufficiently flexible to allow for senior management direction of resources to focus upon areas requiring increased attention.

The proposed changes to the Technical Specification administrative controls would provide such flexibility through the elimination of certain rigid audit frequencies.

Additionally, references to reviews and audits of the facility's Emergency Plan and Physical Security Plan (and of their associated implementing procedures) would be removed from the Technical Specifications because those requirements presently exist within the individual Plans. This action reflects the guidance provided in an NRC proposed generic communication (58 FR 17293).

Background

The minimum scope and schedules for the audit program have been specified by the Administrative Controls section of each facility's Technical Specifications. The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements from various sources including the Code of Federal Regulations (Physical Security Program, Fitness For Duty Program, etc.),

Standard Technical Specifications, NRC Generic Letters (annual, biennial, and triennial Fire Protection audits), industry guidelines and standards (Conformance to Technical Specifications and Operating License, Effectiveness of Corrective Actions, and Training audits). The audits specified by these sources are meant to address programs which are deemed to be essential to the effective management of each nuclear facility. However, the rigid schedules dictated by the Technical Specifications do not allow management the flexibility to recognize exceptional performance by certain organizations, and resources which could be devoted to areas with perceived weaknesses are diluted by the requirement to audit strong programs at the frequencies set forth in the Technical Specifications. The proposed changes would provide for decreasing the frequencies of certain audits, increasing the frequency of the triennial fire protection audit to biennial, and maintaining the frequency of those audits presently scheduled biennially. Additional flexibility would also be introduced by allowing a 25% extension to the frequency of most audits (presently defined in the Operational Quality Assurance Program's commitment to NRC Regulatory Guide 1.74, "Quality Assurance Terms and Definitions," as it endorses ANSI N45.2.10-1973). The exceptions to this frequency extension or "grace period" would be those audits which have frequencies specifically delineated by the Code of Federal Regulations (i.e.,

Emergency Plan and Implementing Procedures Audit, Physical Security Plan and Implementing Procedures Audit, and Fitness For Duty Audit).

Page 1 of 15

e On April 1, 1993, the NRC published a notice of opportunity for public comment for a proposed generic communication (58 FR 17293) which provides guidance for relocating certain requirements (without reducing them) from the Technical Specifications to other NRG-approved program documents. The proposed generic communication specifically addresses the reviews and audits of the Emergency Plan and implementing procedures and the Physical Security Plan and implementing procedures. Currently, the requirements for these reviews and audits are incorporated into the North Anna Emergency and Security Plans. The proposed changes would delete the redundant references in the facility's Technical Specifications to the requirements which originate in Title 1 O of the Code of Federal Regulations [1 O CFR 50.54(t) for Emergency Preparedness and 1 O CFR 50.54(p), 1 O CFR 73.40, 1 O CFR 73.55, and 1 O CFR 73.56 for Security].

Description Of Specific Changes The proposed amendment would eliminate the references to specific frequencies for each of the Technical Specification required audits and eliminate reference to reviews and audits of the Emergency Plan and Security Plan. Instead, a statement would be added to the Operational Quality Assurance Program specifying that the audits listed in the Technical Specifications would be accomplished on a biennial (2 years) frequency as defined by Operational Quality Assurance Program commitments to NRC Regulatory Guide 1.74 and as directed by administrative procedures and/or management.

The requirements for reviews and annual audits of the facility Emergency Plan and Security Plan (and their associated implementing procedures) are currently delineated within the NRG-approved Emergency Plans and Security Plans for North Anna Power Station as provided for in the NRC's proposed generic communication. Each of the proposed changes to the Technical Specifications is discussed by line item below:

North Anna Unit 1 Technical Specifications:

ADMINISTRATIVE CONTROL line item 6.5.1.6.i has been deleted.

The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Plant Security Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved site Security Plan and associated administrative controls. As such, this change complies with the proposed guidance provided in the NRC proposed generic communication (58 FR 17293).

ADMINISTRATIVE CONTROL line item 6.5.1.6.j has been deleted.

The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Emergency Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved Site Emergency Plan and associated administrative controls.

As such, this change complies with the proposed guidance provided in the NRC proposed generic communication (58 FR 17293).

Page 2 of 15

ADMINISTRATIVE CONTROL 6.5.2.8 has been revised to delete the references to specific audit frequencies. In accordance with the Standard Review Plan (SRP) Section 17.3 ("Quality Assurance Program Description") guidance on planned and periodic assessments scheduling and resource allocation, the following statement is being prepared for Section 17.2.18 ("Audits") of the Operational Quality Assurance Program Topical Report:

The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications.

Audits of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner which assures that biennial (2 years) audits of safety related activities are completed. The audits are regularly scheduled on a formal preplanned audit schedule. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities.

Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists; This change neither alters the function nor diminishes the quality of the Audit Program.

The Management Safety Review Committee (MSRC) retains responsibility for oversight of the Quality Assurance Audit Program. The sole change to the process is associated with the audit frequencies, including the definition of those frequencies. Specifically, the definition of "biennial (2 years)"

is provided in the Operational Quality Assurance Program's commitment to Regulatory Guide 1.74 and ANSI N45.2.10-1973. Said definition allows an extension for time intervals not specified in the Technical Specifications of up to 25%.

Therefore, the maximum time between specific audits could be 30 months.

The extension would not be applicable to those audits with frequencies mandated by the Code of Federal Regulations (e.g., Emergency Plan, Security Plan, and Fitness For Duty audits). The Technical Specification required audits and the impacts of the proposed changes are listed below:

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

Applicable portions of the Technical Specifications and license conditions are assessed during each audit for the particular area(s) being audited, and an annual audit is conducted to evaluate those areas which are not evaluated in other audits.

Reducing the frequency of the annuai audit to bienniai (2 years) will not adversely impact compliance with those provisions of the Page 3 of 15

~)

Technical Specifications, the commitments in the Operational Quality Assurance Program Topical Report to ANSI N18.7-1976, or the effectiveness of -audits performed. Compliance with the Technical Specifications and license conditions is evaluated more often then each 12 months although not in a single Technical Specification audit.

The performance, training, and qualifications of the entire facility staff.

Audits of the facility staff's qualifications ("Training Audits") are conducted annually.

The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if needed. This added versatility is not projected to adversely impact the effectiveness of either the Nuclear Training Program or the Audit Program, because management can increase or decrease the audit frequency based upon observed performance and importance to safety.

A statement is being added to clarify the Company's commitment to NRC Regulatory Guide 1.33 in the Operational Quality Assurance Program Topical Report. Specifically, the requirement to perform the Training Audit every 12 months is being clarified to use the biennial (2 years) frequency as stated in Section 17.2.18 of the Topical Report.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

The results of actions taken to correct identified deficiencies are evaluated as part of each audit for the specific area being audited, and currently, an audit is performed every 12 months to evaluate the programmatic controls which govern the corrective action process. The proposed Technical Specification changes would not negatively affect the review of corrective actions in each audit.

Only the annual audit of programmatic controls will be affected in that management will be given flexibility to adjust the audit's frequency based upon performance as evidenced through trends and other performance indicators. As such, the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program.

Page 4 of 15

e The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 1 O CFR

50.

This audit is currently performed "at least once per 24 months."

The proposed change* does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, if needed. This would allow the scheduling of audits to be performance based.

The Emergency Plan and implementing procedures and the Security plan and implementing procedures.

The proposed changes.would not impact these audits whose frequencies are mandated by Title 1 O of the Code of Federal Regulations and the NRG-approved plans.

Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.

There is no impact upon this Technical Specification line item.

The Fire Protection Program and implementing procedures.

This audit is currently performed "at least once per 24 months."

The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, if needed. This would allow the audit to be scheduled during the perform*ance of activities which impact nuclear safety.

Hence, the only impact of the proposed changes upon the biennial fire protection audit would be to make it more performance based.

The independent fire protection and loss prevention inspection and audit utilizing either qualified offsite licensee personnel or an outside fire protection firm (annual audit) and an inspection and audit of the fire protection and loss prevention program by an outside qualified fire consultant (triennial audit).

The proposed changes will combine the annual and triennial audits into one biennial audit which will be alternated with the Fire Protection Program Audit (see above item). 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 Audit Program, Page 5 of 15

e e

because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features.

The radiological environmental monitoring program.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the radiological environmental monitoring program's performance to a maximum of 30 months, if needed.

The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. This flexibility is consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The Offsite Dose Calculation Manual (ODCM) and implementing procedures.

  • This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the program implementing the Offsite Dose Calculation Manual to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators.

The proposed frequency is consistent with the original Technical Specification requirement to audit the ODCM every 24 months.

Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e.,

refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

Page 6 of 15

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The Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the Process Control Program to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. The proposed frequency is consistent with the original Technical Specification requirement to audit the PCP every 24 months. Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 10 CFR 20.1101 (c) (i.e., refer to NRC response to NU MARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The purpose, scope, and thoroughness of QA audits will not be affected, management oversight of the audit process will not be diminished, and the audits will be performed at frequencies commensurate with safety significance and not less than biennially (as defined above). As such, we believe these changes are philosophically correct and acceptable.

Specific line item changes involving the audit process include:

ADMINISTRATIVE CONTROLS 6.5.2.8.a, 6.5.2.8.b, 6.5.2.8.k, 6.5.2.8.1, and 6.5.2.8.m have been revised to delete the phrase "at least once per 12 months."

ADMINISTRATIVE CONTROL 6.5.2.8.c has been revised to delete the phrase "at least once per 6 months."

ADMINISTRATIVE CONTROLS 6.5.2.8.d and 6.5.2.8.h have been revised to delete the phrase "at least once per 24 months."

ADMINISTRATIVE CONTROL 6.5.2.8.i has been revised to delete the term "annually" and reworded.

ADMINISTRATIVE CONTROL 6.5.2.8.j has been deleted since the requirements are now contained in ADMINISTRATIVE CONTROL 6.5.2.8.i.

ADMINISTRATIVE CONTROLS 6.5:2.8.e and 6.5.2.8.f have been deleted.

The requirements for these audits (Emergency Plan and Security Plan) are specified within the North Anna Power Station Emergency Plan and North Anna Power Station Se9urity Plan, respectively.

Additionally, Page 7 of 15

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ADMINISTRATIVE CONTROLS 6.5.2.8.i and 6.5.2.8.j have been combined into a single line item.

Subsequently, line items 6.5.2.8.g through 6.5.2.8.m have been renumbered to line items 6.5.2.8.e through 6.5.2.8.j as part of this change.

ADMINISTRATIVE CONTROL 6.8.2 has been revised to replace the phrase "and approved as per 6.5.1.6.i, 6.5.1.6.j, and 6.5.1.6.m" with "and approved as set forth in the facility's Security Plan, Emergency Plan, and section 6.5.1.6.m of the Technical Specifications, respectively."

ADMINISTRATIVE CONTROL 6.10.1.i has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

ADMINISTRATIVE CONTROL 6.10.1.j has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

North Anna Unit 2 Technical Specifications:

ADMINISTRATIVE CONTROL line item 6.5.1.6.i has been deleted.

The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Plant Security Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved site Security Plan and associated administrative controls. As such, this change complies with the guidance provided in the NRC proposed generic communication (58 FR 17293).

ADMINISTRATIVE CONTROL line item 6.5.1.6.j has been deleted.

The responsibility for the Station Nuclear Safety and Operating Committee (SNSOC) to "review the Emergency Plan and implementing procedures and submitting those changes to the Station Manager" currently exists within the NRG-approved Site Emergency Plan and associated administrative controls.

As such, this change.complies with the guidance provided in the NRC proposed generic communication (58 FR 17293).

ADMINISTRATIVE CONTROL 6.5.2.8 has been revised to delete the references to specific audit frequencies. In accordance with the Standard Review Plan (SRP) Section 17.3 ("Quality Assurance Program Description") guidance on planned and periodic assessments scheduling and resource allocation, the following statement is being prepared for Section 17.2.18 ("Audits") of the Operational Quality Assurance Program Topical Report:

The system of audits devised to verify compliance with quality related aspects of the power station is described in the station Technical Specifications.

Audits *of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a Page 8 of 15

.~..,.

j e

manner which assures that biennial (2 years) audits of safety related activities are completed.

The audits are regularly scheduled on a formal preplanned audit schedule.

The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities. Additional audits may be performed as deemed necessary by management. The scope of the audit is determined by the quality status and safety importance of the activities being performed. These audits are conducted by trained personnel not having direct responsibilities in the area being audited and in accordance with preplanned and approved audit plans or checklists.

This change neither alters the function nor diminishes the quality of the Audit Program.

The Management Safety Review Committee (MSRC) retains responsibility for oversight of the Quality Assurance Audit Program. The sole change to the process is associated with the audit frequencies, including the definition of those frequencies. Specifically, the definition of "biennial (2 years)"

is provided in the Operational Quality Assurance Program's commitment to Regulatory Guide 1.74 and ANSI N45.2.10-1973. Said definition allows an extension for time intervals not specified in the Technical Specifications of up to 25%.

Therefore, the maximum time between specific audits could be 30 months.

The extension would not be applicable to those audits with frequencies mandated by the Code of Federal Regulations (e.g., Emergency Plan, Security Plan, and Fitness For Duty audits). The Technical Specification required audits and the impacts of the proposed changes are listed below:

The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

Applicable portions of the Technical Specifications and license conditions are assessed during each audit for the particular area(s) being audited, and an annual audit is conducted to evaluate those areas which are not evaluated in other audits.

Reducing the frequency of the annual audit to biennial (2 years) will not impact compliance with those provisions of the Technical Specifications, the commitments in the Operational Quality Assurance Program Topical Report to ANSI N18.7-1976, or the effectiveness of audits performed. Compliance with the Technical Specifications and license conditions is evaluated more often then each 12 months although not in a single Technical Specification audit.

Page 9 of 15

i I

J

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,./

e The performance, training, and qualifications of the entire facility staff.

Audits of the facility staff's qualifications ("Training Audits") are conducted annually.

The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, if needed. This added versatility is not projected to impact the effectiveness of either the Nuclear Training Program or the Audit Program, because management can increase or decrease the audit frequency based upon performance and importance to safety.

A statement is being added to clarify the Company's commitment to NRC Regulatory Guide 1.33 in the Operational Quality Assurance Program Topical Report. Specifically, the requirement to perform the Training Audit every 12 months is being clarified to use the biennial (2 years) frequency as stated in Section 17.2.18 of the Topical Report.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

The results of actions taken to correct identified deficiencies are evaluated as part of each audit for the specific area being audited, and currently, an audit is performed every 12 months to evaluate the programmatic controls which govern the corrective action process. The proposed Technical Specification changes would not negatively affect the review of corrective actions in each audit.

Only the annual audit of programmatic controls will be affected in that management will be given flexibility to adjust the audit's frequency based upon performance as evidenced through trends

. and other performance indicators. As such, the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 1 O CFR

50.

This audit is currently performed "at least once per 24 months."

The proposed change does not alter this frequency except to provide the added versatility of a 25% (6 month) extension. This would allow the scheduling of audits to be performance based.

Page 10 of 15

]'

The Emergency Plan and implementing procedures and the Security plan and implementing procedures.

The proposed changes would not impact these audits whose frequencies are mandated by Title 1 O of the Code of Federal Regulations and the NRG-approved plans.

  • Any other area of facility operation considered appropriate by the MSRC or the Vice President - Nuclear Operations.

There is no impact upon this Technical Specification line item.

The Fire Protection Program and implementing procedures.

This audit is currently performed "at least once per 24 months."

The proposed change does not alter this frequency except to provide the added versatility of a 25% (6 month) extension. This would allow the audit to be scheduled during the performance of activities which impact nuclear safety. Hence, the only impact of the proposed changes upon the biennial fire protection audit would be to make it more performance based.

The independent fire protection and loss prevention inspection and audit utilizing either qualified offsite licensee personnel or an outside fire protection firm (annual audit) and an inspection and audit of the fire protection and loss prevention program by an outside qualified fire consultant (triennial audit).

The proposed* changes will combine the annual and triennial audits into one biennial audit which will be alternated with the Fire Protection Program Audit (see above item). 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 Audit Program, because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features.

The radiological environmental monitoring program.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the radiological environmental monitoring Page 11 of 15

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program's performance to a maximum of 30 months, if needed.

The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. This flexibility is consistent with guidance provided by the NRG relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The Offsite Dose Calculation Manual (ODCM) and implementing procedures.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the program implementing the Offsite Dose Calculation Manual to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators.

The proposed frequency is consistent with the original Technical Specification requirement to audit the ODCM every 24 months.

Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to the forthcoming implementation of the revised 1 O CFR 20.1101 (c) (i.e.,

refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

The Process Control Program (PCP) and implementing procedures for processing and packaging of radioactive wastes.

This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the Process Control Program to a maximum of 30 months, if needed. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. The proposed frequency is consistent with the original Technical Specification requirement to audit the PCP every 24 months. Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRG relative to the forthcoming implementation of the revised Page 12 of 15

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10 CFR 20.1101 (c) (i.e., refer to NRC response to NU MARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess.the effectiveness of the radiological protection program).

The purpose, scope, and thoroughness of QA audits will not be affected, management oversight of the audit process will not be diminished, and the audits will be performed at frequencies commensurate with safety significance and not less than biennially (as defined above). As such, we believe these changes are philosophically correct and acceptable.

Specific line item changes involving the audit process include:

ADMINISTRATIVE CONTROLS 6.5.2.8.a, 6.5.2.8.b, 6.5.2.8.k, 6.5.2.8.1, and 6.5.2.8.m have been revised to delete the phrase "at least once per 12 months."

ADMINISTRATIVE CONTROL 6.5.2.8.c has been revised to delete the phrase "at least once per 6 months."

ADMINISTRATIVE CONTROLS 6.5.2.8.d and 6.5.2.8.h have been revised to delete the phrase "at least once per 24 months."

ADMINISTRATIVE CONTROL 6.5.2.8.i has been revised to delete the term "annually" and reworded.

ADMINISTRATIVE CONTROL 6.5.2.8.j has been deleted since the requirements are now contained in ADMINISTRATIVE CONTROL 6.5.2.8.i.

ADMINISTRATIVE CONTROLS 6.5.2.8.e and 6.5.2.8.f have been deleted.

The requirements for these audits (Emergency Plan and Security Plan) are specified within the North Anna Power Station Emergency Plan and North Anna Power Station Security Plan, respectively.

Additionally, ADMINISTRATIVE CONTROLS 6.5.2.8.i and 6.5.2.8.j have been combined into a single line item.

Subsequently, line items 6.5.2.8.g through 6.5.2.8.m have been renumbered to line items 6.5.2.8.e through 6.5.2.8.j as part of this change.

ADMINISTRATIVE CONTROL 6.8.2 has been revised to replace the phrase "and approved as per 6.5.1.6.i, 6.5.1.6.j, and 6.5.1.6.m" with "and approved as set forth in the facility's Security Plan, Emergency Plan, and section 6.5.1.6.m of the Technical Specifications, respectively."

ADMINISTRATIVE CONTROL 6.10.1.i has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

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e ADMINISTRATIVE CONTROL 6.10.1.j has been revised to delete the phrase "of the annual audit" and to add the word "audits" at the end of the statement.

Significant Hazards Consideration The standards used to arrive at a determination that a Technical Specification change request involves no significant hazards consideration are included in the Commission's regulations, 1 O CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is addressed as follows:

(1)

Operation of the facility in accordance with the proposed technical specifications would 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 this Technical Specification change which only affects review and audit frequencies. This Technical Specification change 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 this change.

No systems, equipment, or components are affected by the proposed changes.

Thus, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR are not increased by this change.

The proposed change only affects review and audit frequencies. As such, the proposed change has no impact on accident initiators or plant equipment, and thus, does not affect the probabilities or consequences of an accident.

Therefore, we conclude that this change does not significantly increase the probabilities or consequences of an accident.

(2)

Operation of the facility in accordance with the proposed technical specifications would 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, a change related to audit functions cannot produce a new accident scenario or produce a new type of equipment malfunction. Also, this change does not alter any existing accident scenarios.

The proposed change does not affect equipment or its operation, and, thus, does not create the possibility of a new or different kind of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident.

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(3)

Operation of the facility in accordance with the proposed technical specifications would not involve a significant reduction in a margin of safety.

The proposed change concerning conduct of reviews and audits does not directly affect plant equipment or operation. Safety limits and limiting safety system settings are not affected by this proposed change.

Therefore, use of the proposed Technical Specification would not involve any reduction in the margin of safety.

Based on the above, we have determined that the Technical Specification change request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this Technical Specification change request does not involve a significant hazards consideration.

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