ML20024G500
| ML20024G500 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 04/06/1973 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Skovholt D US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 9102120571 | |
| Download: ML20024G500 (5) | |
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Mr. D J Skovholt
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Assistant Director for Operating Reactors
.j Directorate of Licensing g()kl United States Atomic Energy Commission 6
Washington, D c 20545 Dear Mr. Skovholt MONTICZLLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Reply to Request for Infomation on Managerial and Administrative Cont rols for Operation Northern States Power Company's letter of June 15, 1972 to AEC-DL presented "information pertaining to the managerial and administrative controls to be used to assure safe operation" as required under the regulations of 10 CFR Part 50, Appendix B.
Your January 2,1973 letter to NSP identified certain l
items that were not addressed or inadequately covered and requested further information on the management and administrative controls in response to the established requirements. Your letter further referenced Safety Guide 33, Quality Assurance Program Requirements (Operation) which was issued several months subsequent to our June 15, 1972 submittal.
The requirements of Appendix B of 10 CFR Part 50 govern a limited scope of op-l crating activities as contrasted with operating activities in general.
For operating facilities, the requirements established by Appendix B concern manage-ment and administrative controls for the operating activities affecting tha l
safety related functions of those structures, systems and components provided to prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.
Northern States Power Company proposed changes to the Technical Specifications in the form of a revised Section 6.0, Administrative Controls. This change was prepared using the guidance of ANS 3.2, Standard for Administrative Con-troh for Nuc1 car Power Plants, which was subsequently referenced in Safety Guide 33, and which provides an adequate basis for complying with the manage-
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i D J Skovholt j
April 6, 1973 Page 2 I
ment and administrative controls requirements of 10 CFR Part 50, Appendix B for operating plants. The proposed change to Technical Specification Section i
6.0, Administrative Controls was submitted to AEC-DL November 20, 1972. Cer-tain modifications to these proposed changes were made by AEC-DL and the re-1 i.
vised Section 6.0 was issued by AEC-DL as Change No. 6 dated April 3,1973.
The management and administrative controls program requirements in the April 3, W
l 1973 revision of Section 6.0, Administrative Controls are believed to properly address and adequately cover those items identified in your letter of January j
2, 1973. This information is referenced hereunder in response to your let-1 ter.
l Item
" Criterion 1 - A provision that those checking, auditing, or in-l specting have suf ficient independence of the line organization J
responsible for operation."
i l
Response: Section 6.2.A. of the revised Technical Specifications describes I
the Safety Audit Committee and assigns to it responsibility for review and audit of plant operation 1 activities.
Section 6.1.B.
I.
describes the corporate organizational structure relating to plant operation and illustrates that the Safety Audit Connittee is inde-pendent of the line organization responsible for operation.
Item:
" Criterion II - Special controls processes, test equipment, tools, and skills to obtain and verify quality."
Response: Section 6.1.D. establishes the qualifications of the plant person-nel, and Section 6.2. A.1.d. establishes the required capability of the Safety Audit Committee members.
Section 6.5.A.4. and Section 6.5.C. parts 1, 2, 4 and 5 set forth requirements of controlling procedures for surveillance and testing, routine testing, calibra-tion and testing of instrumentation, and special testing.
Section 6.6.A 3. sets forth related records requirements, and Section 6.5.
J establishes the review and approval authority for these processes.
Item:
" Criterion VI - 1. Procedures to cover review, approval, issuance, and use of both initial and revised documents.
- 2. Review and ap-proval of document revisions by the same organization that per-formed the original review and approval."
Response: Section 6.5. A., B. and C. establish the requirements for " Plant operating Procedures" documents.
Section 6.5. establishes the approval authority under which they are issued, including changes thereto.
Section 6.2.B.4.c. and h. establish the Operations Committee as the review authority and establish the requirements for Operations Committee conduct of such reviews.
.D J Skovholt April 6, 1973 Page 3 Item:
" Criterion XI - 1. Proof tests prior to installation, preopera-tional tests, and operational tests.
- 2. Test results documented and evaluated to assure that the test requirements have been satisfied."
Response: Section 6.5.C.1., 2. and 5. set forth the requirements for routine and special testing procedures and their approval, including spe-cial testing of changes to procedures or equipment.
Section 6.6.
A.3. establishes a requirement for records of tests, and Section 6.6. A.4. establishes a requirement for records of reviews of such tests.
Section 6.2.B.4.a. requires Operations Committee review of the results of tests.
Item:
" Criterion XIV - Measures to indicate the operating status of structures, systems, and components to prevent inadvertent op-eration."
Response: The detailed surveillance testing and minimum operability require-ments of the Technical Specifications establish the bases and intervals for demonstrating operability status of structures, sys-tems and components.
Section 6.5. A.4 and Section 6.5.C.1. and 2.
establish the requirements for apprcved detailed procedures gov-erning this surveillance, including appliccble check-off and instructions.
Item:
" Criterion XVI - 1. Measures to assure that the corrective action is sufficient to preclude recurrence of the unsafe operating con-dition.
2.
Procedures to aosure that the cause and corrective action are properly documented and reported."
Response: Section 1.0. A. defines abnormal occurrences or conditions, which may be regarded as unsafe operating conditions.
Sections 6.2.A.
4.g. and 6.2.B.4.e. and f. establish rcquirements for review of such occurrences including recommendations to prevent recurrence.
Section 6.3. A. sets forth actions to be taken in the event of an abnormal occurrence, including documentation and reporting re-quirements.
Item:
" Criterion XVII - 1. Records, such as operating logs, and results of reviews, inspections, tests, and audits.
- 2. Records which in-clude such items as completed procedures and the qualifications of personnel.
- 3. Inspection and test records which, as a minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the actions taken on noted deficiences.
- 4. Records which are identifiable and ratrievable.
- 5. The duration of record retention, and their location and assigned responsibility."
D J Skovholt April 6, 1973 Page 4 Response: Section 6.6.A. and 6.6.B. set forth in detail the nature and scope, including the retention periods, of recorde to be main-tained of logs, results of reviews, inspections, tests, staff qualifications, and all other essential recorda.
Yours verf truly,
- h. },
L 0 Mayer, P.E.
Direct r of Nuc1 car Support Services LOM/GilN/br cc: B 11 Grier G Charnof f Minnesota Pollution Control Agency Attn. K Dzugan
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AEC DISTRIBUTION FOR PART 50 DOCrET IGTZRIAL (TF.MPORARY 70iv.)
CONTROL NO:
2385 TITT
/ TROM DATE OF DOC:
DATE RF,C'D LTR EMO RPF UrXEst Northern S,tateo Power' Company Plhncapolio, Minn.
55401 L.
O. Ma ye r, h 6-73 4-11-73 X
'IO :
ORIG CC OIHER SIhT AIC FD3 X
SENT LOCAL ?!,a X
Mr. Slovholt 1 signed CLASS QgFROP INFO INPUI NO CYS REC'D DOCIT,7 EOs 40 50-263 DESCRIPIION:
ENCLOGURES:
.Ltr re their 6-15-72 ltr & our 1-2-73 ltr...,
furnishing requested info re unnaEerial &
administrative controle for operation.......
DoNo.t. Red)6y~e l
10KN00Q0Ea ptANT nA}.gs:
Monticello FOR ACTION /IN70RMATION 4-11-73 AB BUTLER (L)
SCHWENCER(L) v ZIEMANN(L)
YOUNGBLOOD(E)
W/ Copies W/ Copies W/9 Copies W/ Copies CIARK(L)
STOLZ(L)
ROUSE (FR)
REGAN(E)
W/ Copies W/ Copies W/ Copies W/ Copies GOLLER(L)
VASSALLO(L)
DICKER (E)
W/ Copies W/ Copies W/ Copies W/ Copies KNIEL(L)
SCHDEL(L)
KNIGIfPON(E)
W/ Copies W/ Copies W/ Copies W/ Copies I!ffERNAL DISTRIBtffION RDG TECH REVIEW DDTPON F&M WADE E
PDR HENDRIE GRIMES SMILEY BDOWN E
V OGC, ROCt4 P-506A SCHR0EDER GAMMILL NUSSBALMER G. WILLIAMS E V'MUITIZING/ STAFF MACCARY KASTNER SHEPPARD E
CASE KNIGHT BALIARD LIC ASST.
GIAMBUSSO PAWLICKI SPANGLER SERVICE L
A/T IND D0YD SHAO VIIBON L
BRAITMAN p V. MOORE-L(BWR)
STELIO ENVIRO G0JLBOURNE L SALTZFAN DEYOUNG-L(PWR)
FOUSTON MULLER SMITH L
v SKOVHOLT-L NOVACK DICKER GFARIN L
PIAN 3 P. COLLIIG ROSS KNIGHTON DIGGS L
MCDONALD IPPOLITO YOtTNGBIDOD TEEPS L
DUBE REG OPR TEDELCO REGAN LEE L
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