ML19345A434
| ML19345A434 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 12/02/1975 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19345A435 | List: |
| References | |
| WYR-75-140, NUDOCS 8011210407 | |
| Download: ML19345A434 (3) | |
Text
Propos:d Change !!o.130 L sppitm:nt No. 1
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Attention:
Office of Nuclear Reactor Regulation
Reference:
(1)
License No. DPR-3 (Docket No. 50-29)
(2) USNRC letter dated September 17, 1975.
(3)
YAEC Proposed Change No. 130 submitted August 11, 1975.
Dear Sir:
In response to your letter, Reference (2), requesting revision of specific paragraphs of our Proposed Change No. 130 we submit the 4
following response:
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-' &'Cs (Oy Question No. 1
'q Theneededmodificationofyourproposedspecification6.5.j j
D involving either identification of position titles or specifying minimum qualifications of the persons assigned to the Nuclear Saf C M (, [f r
Audit and Review Committee.
T' Respense Uc. 1 We have added subparagraph "e" Qualifications, to 6.5.2.2 that j
incorpcrates the qualification requirement of a degree and minimum experience for Ccemittee membership. Additionally, we have provided l
a means to utill e non-degree parsonnel having extensive nuclear related experience.
In cur review of our original submittal we have concluded that we l
could have greater flexibility in obtaining a meeting quorum if we took l
advantage of 6.5.2.3 alternates, and have, therefore, included that section in this submittal.
We have also revised section 6.5.2.6 Querum, to inalude a limitation on the nur.ber of alternate members that may be part of a quorum.
Question No. 2 The needed revisions of your proposed specifications 6.5.2.7, 6.5.2.8 and 6.5.2.10 (Review, Audits and Records, respectively) relating to the 8011210YO7 13G08-
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United States Nuclear Regulatory Commission Dcctmber 2, 1975 Attn: ' Office of Nuclear Reactor Regulation Page Two activities of the Nuclear Safety Audit and Review Committee to conform with the like nwnbered requirements in our standard section 6 Technical Specifications; and Response No. 2 6.5.2.7, Review. We have incorporated a requirement for NSARC review of the implementing procedures for special tests and experiments.
We have not included 6.5.2.7.b of the Standard Technical Specifications (STS) since for our company much of the Facility Hazards Summary Report (FHSR) is incorporated by reference in the Technical Specifications, therefore, STS section "b" is redundant to STS "d".
For clarification we have added " Plant Information Report" to STS "f" (our "e").
6.5.2.8, Audits. We have revised this section to be in conformance with the STS insofar as is practical with our functional In-Plant Audit Sy= tem performed by the Operational Quality Control and Audit Department (OQCAD). Audits of facility activities are performed by OQCAD personnel.
These are Level 1 audits. The NSARC represents Corporate Management and in this capacity generally performs Level 2 audits. In order to evaluate the effectiveness of the QA Program it is absolutely mandatory that the NSARC be permitted unrestricted flexibility in the performance of its audits.
This flexibility is exercised by the NSARC as right of Management. To show the depth and adequacy of this functional system we describe below our justification for deleting each lettered sentence of STS, 6.5.2.8, Audits.
6.5.2.8.a.
NSARC reviews (not audits) this area twice a year (see 6. 5. 2. 7.d).
6.5.2.8.b.
The In-Plant Audit Program audits the Plant Training Program cnce a year and reaudits discrepancies monthly.
6.5.2.8.c.
A review is performed by the NSARC twice a year of items 6.5.2.7, d, e, f, g, h.
6.5.2.8.d.
The In-Plant Audit Program is completed annually with a monthly reaudit of any discrepancies.
6.5.2.8.e.
The Facility Emergency Plan will be added to the In-Plant Audit Program in 1976 and scheduled for audits on a two year cycle with a monthly reaudit of discrepancies.
6.5.2.8.f.
This area is audited annually under the In-Plant Audit Program with monthly reaudit of discrepancies.
6.5.2.8.g.
This area is covered by the summary at beginning of 6.5.2.8 as well as 6.5.2.7.h, Review.
6.5.2.10, Records. We have revised this section to reflect current procedures for the distribution of NSARC minutes and reports of reviews and audits. Each NSARC member receives a copy of all minutes and reports.
In addition, a copy is consecutively routed to all members for their review.
The routed copy is placed in the file after incorporating any recommendations by the review process.
If necessary, revised reports will be issued.
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United States Nuclear Regulatory Commission December 2, 1975 Attn:
- Office of Nuclear Reactor Regulation Page Three Question No. 3 The needed documentation, review and approval of temporary changes to procedures within seven (7) days instead of thirty (30) days as proposed in Specification 6.8.3.C.
Response No. 3 We have revised section 6.8.3.C to require temporary changes to procedures to be documented, reviewed by the Plant Operation Review Committee and the Plant Superintendent prior to the procedure being used again. We believe this to be the intent of the requested seven (7) days.
We have retained the outside limit of thirty (30) days to eliminate the
'need to call special PORC meetings solely for the review of temporary changes to procedures that are not scheduled for reuse.
We trust that these revisions will allow you to approve our Proposed Change at an early date.
We have. attached new pages incorporating the revisions for replacement in our submittal, Reference (3).
These changes have been reviewed by the Nuclear Safety Audit and Review Committee.
Very truly-yours, YANKEE ATOMIC ELECTRIC COMPANY VM UU&
Louis H. Heider Assistant Vice President CCMMCNWEALTH OF MASSACHUSETTS)
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COUNTY OF WORCESTER
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l Then personally appeared before me, Louis H. Heider, who being duly sworn, did state that he is Assistant Vice President of Yankee Atomic Electric Company, that he is culy authorized to execute and file the foregoing request in the name and on the behalf of Yankee Atomic Electric Ccepany, and that the statements therein are true-to the best of his knowledge and belief.
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Armand R. Soucy Notary Ptiblic My Cc:=ission Expires. September 9,1977
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