ML18153B062

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Revises 931227 TS Change Request Re Mgt Safety Review Committee & Station Nuclear Safety & Operating Committee Responsibilities to Resolve NRC Comments Discussed During 940614 Meeting W/Nrc.Revised Tech Specs for Plants Encl
ML18153B062
Person / Time
Site: Surry, North Anna  Dominion icon.png
Issue date: 09/06/1994
From: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18152A507 List:
References
94-367A, NUDOCS 9409150318
Download: ML18153B062 (11)
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 e

September 6, 1994 United States Nuclear Regulatory Commission Serial No. 93-367A Attention: Document Control Desk NL&P/GDM: R1 Washington, D. C. 20555 Docket Nos. 50-280 50-281 50-338 50-339 License Nos. DPR-32 DPR-37 NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 SURRY POWER STATION UNITS 1 AND 2 REVISED TECHNICAL SPECIFICATIONS CHANGE REQUEST MSRC AND SNSOC REVIEW RESPONSIBILITIES By our letter dated December 27, 1993 (Serial No.93-367), Virginia Electric and Power Company requested changes to the Technical Specifications for Operating License Nos. DPR-32 and DPR-37 for Surry Power Station Units 1 and 2 and NPF-4 and NPF-7 for North Anna Power Station Units 1 and 2, respectively. These changes to the Technical Specifications revise the 1) Management Safety Review Committee (MSRC) review responsibilities regarding safety evaluations and Station Nuclear Safety and Operating Committee (SNSOC) meeting minutes and reports, and 2)

SNSOC review responsibilities for procedure changes. However, the changes now also state that the MASC will review safety evaluations, and the SNSOC will review procedure changes, as programmatically discussed in the UFSAR. Discussions of the MSRC review of safety evaluations and the SNSOC review of procedure changes will be incorporated into the UFSAR upon NRC approval of the proposed Technical Specifications changes.

This letter revises and supersedes the previously proposed Technical Specifications change request to resolve NRC comments discussed during the June 14, 1994 meeting with the NRC staff.

A discussion of the proposed changes to the North Anna and Surry Technical Specifications is provided in Attachment 1. The revised Technical Specifications for Surry Power Station Units 1 and 2 are provided in Attachment 2, and the revised Technical Specifications for North Anna Power Station Unit 1 and Unit 2 are provided in Attachments 3 and 4, respectively.

It has been determined that the proposed changes to the Technical Specifications do not involve an unreviewed safety question as defined in 10 CFR 50.59 or a significant hazards consideration as defined in 10 CFR 50.92. The basis for our determination

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9409150318 940906 PDR ADOCK 05000280 P PDR

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, __(;. e that these changes do not involve a significant hazards consideration is provided in Attachment 5. The 10 CFR 50.92 significant hazards consideration provided in our previous submittal has not changed and remains bounding for the revised Technical Specifications change request. The proposed changes to the Technical Specifications have been reviewed and approved by SNSOC at each station and the MSRC.

If you have any questions or require additional information, please contact us.

Very truly yours,

~?.&Wrv-James P. O'Hanlon Senior Vice President - Nuclear Attachments cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power Station Commissioner Department of Health Room 400 109 Governor Street Richmond, Virginia 23219

e COMMONWEALTH OF VIRGINIA )

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COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by J. P. O'Hanlon, who is Senior Vice President -

Nuclear, of Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

0 Acknowledg-8d betore me this ~ ?JI day of ~iz;,,,Ju,.) , 19'lt:_.

My Commission Expires: ,~ 1 3/ , 19ilL.

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Notary :blic (SEAL}

Attachment 1 Discussion of Changes

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Discussion of Changes Introduction The North Anna and Surry Power Station Technical Specifications presently address the organization and responsibilities of both the onsite and offsite review groups, the Station Nuclear Safety and Operating Committee (SNSOC) and the Management Safety Review Committee (MSRC), respectively. The responsibilities of the SNSOC include the review of new procedures and changes to procedures that affect nuclear safety. The MSRC review responsibilities include the review of safety evaluations and SNSOC meeting minutes and reports. It is proposed that the extent of these review activities be revised in the Technical Specifications to ensure the two review groups are focusing on nuclear safety issues and not spending an unnecessary amount of time on administrative activities of minimal safety significance.

Background

SNSOC Review of Procedures and Procedure Changes North Anna and Surry Technical Specifications require SNSOC to review and approve new procedures to be used at the station. This ensures that each new procedure is evaluated for its impact on nuclear safety prior to implementation. These specifications also require SNSOC to review changes to these procedures as well as changes to any other procedures as determined by the Station Manager.

The purpose of the SNSOC review of procedure changes is to ensure that procedures currently in use at the station maintain nuclear safety. However, Technical Specifications do not differentiate as to safety significance and currently require procedure changes to be approved by SNSOC, whether the changes have the potential for affecting nuclear safety or not. As a result, SNSOC reviews numerous procedure changes that have no nuclear safety significance. The proposed changes to the Technical Specifications would delete the requirement for SNSOC to review procedure changes that do not have the potential for affecting nuclear safety.

The current program for upgrading and revising procedures involves numerous checks and balances to ensure the adequacy and accuracy of the procedures. The Page 1 of 7

  • y form used to generate a procedure change includes screening criteria the preparer must consider to determine if a safety evaluation is required for the proposed change.

Individuals trained on the purpose and preparation of activity screenings and safety evaluations must sign as the preparer or reviewer of the activity screening.

Furthermore, administrative procedures require cognizant management review of the procedure change prior to its implementation.

Procedure changes that do not require a safety evaluation, as determined by the screening criteria, receive adequate review in accordance with administrative procedures. Additional SNSOC review of such changes is unnecessary since these changes have already been determined as not affecting nuclear safety. Releasing SNSOC from the administrative burden of reviewing safety insignificant procedure changes permits SNSOC to focus on more safety significant plant activities.

The proposed Technical Specifications changes will require SNSOC to review and approve only new procedures and procedure changes that require a safety evaluation.

Procedure changes that are determined not to be safety significant by the screening criteria will be independently reviewed and approved by cognizant management as programmatically discussed in the Updated Final Safety Analysis Report (UFSAR) and in accordance with administrative procedures. The proposed changes also delete the existing requirements in the Technical Specifications that address temporary procedure changes. These procedure changes will be processed pursuant to the requirements for procedure changes in general as noted above (i.e., reviewed by SNSOC if they require a safety evaluation, and processed as programmatically discussed in the UFSAR and in accordance with administrative procedures if no safety evaluation is required).

MSRC Review of Safety Evaluations and SNSOC Meeting Minutes The MSRC serves as the offsite management review group for Surry Power Station and advises the Senior Vice-President - Nuclear on matters affecting nuclear safety.

The specific responsibilities of the MSRC are detailed in the Technical Specifications.

These responsibilities include the review of safety evaluations prepared pursuant to the requirements of 10 CFR 50.59, proposed changes involving unreviewed safety questions, proposed Technical Specification changes, significant operating abnormalities or deviations, violations of regulations having safety significance, events Page 2 of 7

' f requiring written notification to the NRC, SNSOC meeting minutes and reports, and recognized indications of an unanticipated deficiency that could affect nuclear safety.

The Technical Specifications require the MSRC to independently review the safety evaluations required by 10 CFR 50.59 for 1) changes to procedures, equipment or systems and 2) tests or experiments. This subsequent independent review is conducted to separately verify that the preparer's determination of whether an unreviewed safety question exists is accurate and thoroughly supported.

Safety evaluations have been reviewed by the MSRC since its formation approximately four years ago. The MSRC review is completed after the safety evaluations have been approved by SNSOC. These reviews have generally concurred with the conclusions of the individual safety evaluations and found them on the whole to be consistently implemented. Furthermore, an assessment of the entire safety evaluation program was performed by our independent review group to evaluate the effectiveness of the program and the quality of the safety evaluations being prepared. This assessment did not identify any significant concerns regarding the entire safety evaluation program or in any conclusions of the safety evaluations .

. - We have concluded that 100% review of safety evaluations by the MSRC is not necessary to assure adequate implementation of the safety evaluation program. We do consider it necessary to continue to provide an independent overview of the safety evaluation program to ensure proper implementation is maintained. However, to accomplish this task, we propose that the MSRC review safety evaluations on a sample basis. The sampling criteria will be reviewed and approved by the MSRC.

The sample size will be programmatically established by screening 100% of the safety evaluations for sample selection based on safety signifiqance and will be representative of the various safety evaluations being generated. The sample size will be subject to modification based on observed performance (MSRC findings and independent program review assessments). Should problems with safety evaluation program implementation be identified, a greater number of reviews would be performed and appropriate corrective actions would be initiated in accordance with programmatic requirements. Independent assessments will continue to be performed periodically to further ensure adequate program implementation, and the sample review program will be implemented as programmatically discussed in the UFSAR and administrative procedures.

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$imiiariy, it is proposed that the scope of the MSRC review of SNSOC activities be modified in the Technical Specifications. Specifically, it is proposed that SNSOC meeting minutes and reports be reviewed on a sample basis as part of the MSRC's plant overview function. The size of the sample and content of SNSOC meeting minutes and reports to be reviewed will also be programmatically established and subject to modification based on observed performance. Safety significant items reviewed by SNSOC will continue to be reviewed in total by the MSRC to verify nuclear safety issues are being properly considered.

The programmatic aspects of the review of safety evaluations and SNSOC meeting minutes and reports will be administratively defined in the appropriate charters and procedures. The MSRC's review of safety evaluations will be programmatically discussed in the UFSAR.

Specific Changes The proposed changes to the Technical Specifications will revise certain review responsibilities of the SNSOC and the MSRC provided in Section 6, Administrative Controls. The proposed changes to the Technical Specifications would modify the approval process for procedure changes that do not require a safety evaluation, and state that the MSRC will review 1) safety evaluations as programmatically discussed in the UFSAR and 2) a representative sample of SNSOC meeting minutes and reports.

Also, the Technical Specifications that discuss temporary procedure changes will be deleted and replaced with general wording for the review and approval of procedure changes.

Specifically, the Surry Technical Specifications are proposed to be revised as follows:

  • Technical Specification 6.1.C.1.f.1 is revised to state that only new procedures and procedure changes that require a safety evaluation or as determined by the Station Manager will be reviewed by SNSOC. For consistency with revised Technical Specification 6.1.C.1.f.1, Technical Specification 6.1.C.1.f.2 has the word "proposed" changed to "new" regarding SNSOC reviewed procedures.
  • Technical Specifications 6.1.C.2.g.1 and 6.1.C.2.g.9 are revised to state that the MSRC will review 1) safety evaluations as programmatically discussed in Page 4 of 7

e the UFSAR to verify that the safety evaluation program is being effectively implemented and 2) a representative sample of SNSOC meeting minutes and reports, respectively.

  • Technical Specification 6.4.C is revised to modify the requirement for SNSOC review and approval of procedure changes. Only those procedure changes that require a safety evaluation will be reviewed and approved by SNSOC. The remaining procedure changes will be independently reviewed and approved as programmatically discussed in the UFSAR.
  • Technical Specifications 6.4.E and 6.4.F are deleted. Temporary procedure changes would be processed pursuant to the requirements for procedure changes in general as noted above (i.e., reviewed by SNSOC if they require a safety evaluation, and processed as programmatically discussed in the UFSAR if no safety evaluation is required).

The North Anna Unit 1 and Unit 2 Technical Specifications are proposed to be revised as follows:

  • North Anna Unit 1 and Unit 2 Technical Specifications 6.5.2.7.a and 6.5.2.7.i are revised to note that the MSRC will review 1) safety evaluations as programmatically discussed in the UFSAR to verify that the safety evaluation program is being effectively implemented and 2) a representative sample of SNSOC meeting minutes and reports, respectively.

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.. North Anna Unit 1 and Unit 2 Technical Specification 6.8.3 is revised to delete the discussion of temporary changes to procedures. This Technical Specification has been rewritten to discuss the review requirements for procedure changes in general and now states that SNSOC shall review all procedure changes that require a safety evaluation. Procedure changes that do not require a safety evaluation will be independently reviewed and approved as programmatically discussed in the UFSAR.

Safety Significance The procedure change process is administratively controlled and ensures that qualified, trained individuals and cognizant management are involved in the preparation, screening and review of procedure change req~ests. New procedures and procedure changes that are safety_significant (i.e., require a safety evaluation) will continue to be reviewed by SNSOC. Procedure changes that are not safety significant will be reviewed and approved as programmatically discussed in the UFSAR in accordance with administrative procedures.

Safety evaluations currently receive a minimum of three reviews: 1) the designated reviewer, 2) the responsible supervisor and 3) SNSOC. A design authority review is also required for safety evaluations that affect core reactivity, facility design or the plant design basis. Therefore, the additional and subsequent independent review of safety evaluations by the MSRC on a sample basis as part of its plant overview function and as programmatically discussed in the UFSAR is adequate to ensure proper program implementation. SNSOC meeting minutes and reports will also be reviewed by the MSRC on a sample basis as part of the MSRC's routine plant overview. The sample sizes of the safety evaluations and the SNSOC meeting minutes and reports to be reviewed will be determined by performance and will be increased (or decreased) based on MSRC findings. Furthermore, the effectiveness of the safety evaluation program will be evaluated through periodic assessments by an independent review group. The Quality Assurance department also performs performance-based audits of the MSRC and SNSOC regarding implementation of their Technical Specification responsibilities and conducts informal observations of SNSOC meetings.

The proposed Technical Specifications changes do not increase the probability of occurrence or consequences of an accident because the Technical Specifications Page 6 of 7

being revised are administrative requirements which do not of themselves contribute to any accident precursor or accident consequences. UFSAR accident analyses remain unaffected and bounding. Likewise, the probability of equipment malfunction is also unaffected as these are administrative changes that do not affect any equipment. The administrative reviews which are being affected are adequately addressed by other activities.

A new accident scenario is not initiated since these changes have no direct effect on operations nor is any plant modification being made. Further, the independent review and assessment of safety evaluations and procedures are adequately performed through tiered reviews by cognizant personnel and management.

Since these changes are administrative in nature and have no impact on the UFSAR safety analyses, the margin of safety assumed in the Technical Specifications is not affected.

Therefore, eliminating SNSOC review of procedure changes that do not require a safety evaluation, revising the wording for approval of procedure changes, and modifying the MSRC's duties regarding their review of safety evaluations and SNSOC meeting minutes and reports, will not detrimentally affect nuclear safety. Adequate controls remain in place to ensure proper implementation of procedure changes and safety evaluations and overview of SNSOC activities.

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