ML19331E216

Application to Amend Licenses NPF-4 & NPF-7,transferring Independent Review Responsibility from Sys Nuclear Safety & Operating Committee to Safety Evaluation & Control Staff & Audit Responsibility to QA Dept.Received W/O Encl Check

ML19331E216
Person / Time
Site:	North Anna
Issue date:	08/28/1980
From:	Ferguson J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML19331E217	List: ML19331E216 ML19331E218 ML19331E219
References
731, NUDOCS 8009090344
Download: ML19331E216 (4)

Text

P. .

. ...- E THIS DOCUMENT CONTAINS P00R QURUTY PAGES N

VraoxxzA EI.ECTRIC AND Powen COMPANY Rtcaxown,VzmorazA 2026:

August 28, 1980 Mr. Harold R. Denton, Director Serial No. 731 Office of Nuclear Reactor Regulation LQA/WRM, N0/DWL Attention: Mr. Robert A. Clark, Chief Docket Nos. 50-338 Operating Reactors Branch No. 3 50-339 Division of Licensing License Nos. NPF-4 U. S. Nuclear Regulatory Commission NPF-7 Washington, D. C. 20555

Dear Mr. Denton:

AMENDMENT TO OPERATING LICENSES NPF-4 AND NPF-7 NORTH ANNA POWER STATION UNITS NO. 1 AND NO. 2 PROPOSED TECHNICAL SPECIFICATION CHANGE Pursuant to 10 CFR 50.90, the Virginia Electric and Power Company hereby requests an amendment, in the form of changs to the Technical Specifications, to Operating Licenses NPF-4 and NPF-7 f ar North Anna Power Station, Units No. I and No. 2. The proposed changes are enclosed.

The proposed changes will transfer the independent review responsibility from the existing System Nuclear Safety and Operating Committee (SyNSOC) to the Safety Evaluation and Control (SEC) staff and will transfer the System Nuclear Safety and Operating Committee audit responsibilities to the Quality Assurance Department.

The Safety Evaluation and Control staff will be composed of a Director and a minimum of three staff members. The Director, Safety Evaluation and Control will report to the Manager, Nuclear Technical Services, who will advise the Executive Vice President-Power on the activities of the Safety Evaluation and Control staff.- This organizational structure will assure that sufficient attention is directed towards examination and evaluation of safety concerns and that management is cognizant of the results of these Safety Evaluation and Control staff reviews.

The Safety Evaluation and Control staff will provide the independent reviews of station operational activities- required by ANSI /ANS 3.2 (Administrative Controls rad Quality Assurance Program for Operational Nuclear Power Plants),

which are presently provided by the System Nuclear Safety and Operating Committee. The advantages of this proposed change are threefold.

First, the Safety Evaluation and Control staff is composed of indi-viduals with direct nuclear experience in their respective technical disciplines. Presently, all ' Safety Evaluation and Control staff members meet or exceed the criteria for review " staff specialists" 09 090 %

Visorwtr EtzcTa:C AND Powra Conrawy to Mr. Harold R. Denton, Director established in ANSI /ANS 3.1 (Standard For Selection and Training of Personnel for Nuclear Power Plants). Additionally, the Director, Safety Evaluation and Control exceeds the criteria established by ANSI /ANS 3.1 for the Super'ri sor of an independent review staff.

Future Safety Evaluation and Control staff members may not meet the qualification criteria for " staff specialists" positions; however, such individuals will not be directly involved in the independent review function of Safe ~ty Evaluation and Control.

Secondly, the independent reviews of station operational activities by the Safety Evaluation and Control staff will be performed on a continuous basis as part of their routine responsibilities. This is in contrast to an intermittent or scheduled review approach commit-tee; therefore, the Safety Evaluation and Control reviews will be responsive to station time constraints while also providing a more comprehensive . review of items presently processed by the System Nuclear Safety and Operating Committee.

Finally, other Safety Evaluation and Control staff routine responsi-bilities require continuous review of industry-wide operational experience, technical information, and regulatory issues. This effort should maintain a high level of " state-of-the-art" expertise within Safety Evaluation and Control regarding operationa' activities and general industry concerns. It is anticipated that the Safety Evaluation and Control staff will provide the majority of the tech-nical input to independent review activities; however, technical consultants and in-house specialists will be utilized for special concerns when Safety Evaluation and Control review requires addi-tional expertise.

As a result of this change, safety will be enhanced by the proposed transfer '

of independent review responsibilities from the System Nuclear Safety and  !

Operating Committee to the Safety Evaluation and Control staff by upgrading the quality and. timely. processing of the independent reviews of station operational activities. 1 I

Specification 6.5.2.8 for North Anna Units .No. I and No. 2 requires the per-formance . of audits of station activities under the cognizance of the System ,

Nuclear Safety and Operating Committee. As a result of this proposed change, i the . audit responsibilities outlined in Specification 6.5.2.8, which are pre- j sently being performed under the cognizance .of the System Nuclear Safety and '

Operating Committee by the Quality Assurance Department, will be transferred to- the Quality- Assurance Department. Such a transfer will previde for appropriate organizational channels for the reporting of audit results, ensure the availability of appropriate technical expertise for the performance of these audits, and ensure that these audits are performed in an effective and timely manner.

- In our letter dated July 30, 1980 (Serial No. 487), we proposed changes to revise Section 6.0 ADMINISTRATIVE CONTROLS to reflect the addition of an-Assistant Station Manager position -at North Anna Pcwer Station. Those pro- l posed changes are included in this request.  ;

G-

visoix A hacTmc Awo Powan CoMPAxv to Mr.. Harold R. Denton, Director In our. July 30, 1980 letter, we proposed a change to the North Anna Unit No. 'I and No. 2 Environmental Technical Specifications which would revise the requirement for the Supervisor, Quality Assurance,' Operations .and Maintenance to . perform ' iriependent audits of the implementation of the Environmental Technical Specifications by transferring this responsbility to the Supervisor, Quality ' Assurance Engineering. This proposed change is being modified to reference the Quality Assurance Department as having responsibility for. the performance of the audits of the implementation of the Environmental Technical

-Specifications.

This request has been reviewed and approved by the Station Nuclear Safety and

. Operating Committee and the System Nuclear Safety and Operating Committee. It has been . determined that this request does not involve an unreviewed safety question.-

We have reviewed this request in accordance with the criteria in 10 CFR 170.22.

It has been determined that this request involves a single safety issue; therefore, a Class III license amendment fee is required for Unit 1 and a ,

Class I license amendment fee is required for Unit 2. Accordingly, a voucher check in the amo int of .$4,400.00 is enclosed in payment of the required fe'es. -

Very truly yours, i

J. H. Ferguson Exscutive Vice President-Power sur SC3 Attachments:

1. Proposed Technical Specification Change - Unit 1

2. Proposed Technical Specification Change'- Unit 2

3. Proposed Environmental Technical Specification Change 4 ~. Voucher Check No. 02822 for $4,400.00 cc: Mr. B. Joe Youngblood,_ Chief Licensing. Branch No. 1 Division of Licensing Mr. James P. O'Reilly, Director Office of Inspection and Enforcement Region Ti l-l-

N- .U

. o.

• COMMONWEALTH OF VIRGIhn )

) s. s.

CITY OF RICHMOND )

Before me, a Notary Public, in and for the City and Common-wealth aforesaid, today personally appeared J. H. Ferguson, who being duly sworn, made oath and said (1) that he is Executive Vice President-Power of the Virgfnia Electric and Power Company, (2) that he is duly authorized to execute and file the foregoing Amendment in behalf of that Company, and (3) that the statements in the Amendment are true

- to the best of his knowledge and belief.

D Given under my hand and notarial seal this fB4 day of Lud- , h-U My Consnission expires TMua4u \9. A R1 .

O LLiLvn 0h1Utus lh0Ach

- V 'totary Pdblic V

& L'C nustduim5 LLJ SULlHL u O k% :-.

4 (SEAL) a ,