ML20059K163
| ML20059K163 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/14/1994 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-94002, TAC-M86712, NUDOCS 9402010371 | |
| Download: ML20059K163 (12) | |
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eab k NH 03874 Telephone (603)474-9521
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Facsimile (603)474-2987 Energy Service Corporation Ted C. Feigenbaum Senior Vice President and Chief Nuclear Officer NYN-94002 January 14,1994 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
References:
(a)
Facility Operating License No. NPF-86, Docket No. 50-443 (b)
North Atlantic letter NYN-94003, dated January 14,1994, " License Amendment Request 93-20: Administrative / Editorial Changes to Technical Specifications (TAC No. M86712)," T.C. Feigenbaum to USNRC
Subject:
Proposed Change to the North Atlantic Operational Quality Assurance Program (TAC No. M85712)
Gentlemen:
North Atlantic Energy Service Corporation (North Atlantic) provides in the Enclosure a change to the North Atlantic Operational Quality Assurance Program (OQAP) that deletes the requirement to perform a biennial review'of plant procedures. This change reduces an existing commitment in the OQAP description and is submitted for NRC approval pursuant to 10CFR50.54. The commitment revision does l
l not decrease the effectiveness of the OQAP. North Atlantic will implement this change to the OQAP upon NRC approval or on March 16,1994, whichever occurs first. North Atlantic has submitted a related revision to the Seabrook Station Technical Specifications [ Reference (b)).
Should you have any questions regarding this OQAP change please contact Mr. Terry L. Ilarpster, Director of Licensing Services, at (603) 474-9521.
Very truly yours,
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Ted C. Feigenbaut i Enclosure j
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PDR ADOCK 05000443 N
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a member of the Northeast Utilities system
()nited States Nuclear Regu!r. tory Commission January 14,1994 Attention:
Document Control Desk Page two j
cc:
Mr. Thomas T. Martm i
Regional Administrator i
United States Nuclear Regulatory Commission Region I i
475 Allendale Road i
King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager i
Project Directorate 1-4 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555
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Mr. Antone C. Cerne NRC Senior Resident inspector P.O. Box !l49 Seabrook, NH 03874 l
Mr. George L. Iverson, Director
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New llampshire Office of Emergency Management i
107 Pleasant Street Concord, Nil 03301 l
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North Atlantic January 14,1994 ENCLOSURE TO NYN-94002 CilANGE TO THE NORTil ATLANTIC OPERATIONAL QUALITY ASSURANCE PROGRAM
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Description of the Chance This change revises the North Atlantic Operational Quality Assurance Program (OQAP) by deleting the requirement to perform a biennial review of station procedures; taking exception to ANSI N18.7-1976/ANS 3.2, Section 5.2.15, Review. Approval and Control of Procedures with regard to the biennial review of procedures and by including the Station Qualified Reviewer Program for the review of selected procedures. The North Atlantic OQAP is described in the Seabrook Station Updated Final Safety Analysis Report (UFSAR), Section 17.2, Quality Assurance During the Operations Phase.
North Atlantic has submitted License Amendment Request 93-20, Administrative / Editorial Changes to Technical Specifications, via North Atlantic letter NYN-94003 [ Reference (b)] to request a revision of the Seabrook Station Technical Specifications to include the Station Qualified Reviewer Program.
+ UFSAR Section 17.2.6.4, Chances, Page 17.2-26 The third paragraph is deleted, thereby removing the requirement to perform the biennial review of station procedures.
UFSAR Section 17.2.10.2, Technical Specification Surveillance Tests, Page 17.2-29 The phrase "or review and approval per the Station Qualified Reviewer Program" is added to the third sentence. This change allows selected procedures to be reviewed per the Station Qualified Reviewer Program in lieu of review by the Station Operation Review Committee (SORC). This l
change will be fully implemen'ed after NRC approval of License Amendment Request No. 93-20.
+ UFSAR Section 17.2.11.2, Test Procedures, Page 17.2-32 The phrase "or are reviewed and approved per the Station Qualified Reviewer Program" is added to the first sentence. This change allows selected procedures to be reviewed per the Station Qualified Reviewer Program in lieu of review by the Station Operation Review Committee (SORC). This change will be fully implemented after NRC approval of License Amendment Request No. 93-20.
UFSAR Appendix 17A, Exceptions._ Alternatives. and Clarifications to Procram Standards. Industry Codes. Federal Reculations and Guides, Pages 17A-4 & 17A-5 A new paragraph (g) has been added to this Section. The new paragraph states:
"With regard to Section 5.2.15 of ANSI N18.7-1976 titled Review. Approval and Control of Procedures: NAESCO will comply with the requirements of this section with the exception of the requirement to review plant procedures no less frequently than every two years to determine if changes are necessary or desirable. Other programs in place at Seabrook Station make the biennial review redundant. The effectiveness of these programs in maintaining procedures current is verified by a system of periodic audits, surveillance, and/or inspections."
Paragraphs g. and h. are renumbered as paragraphs h. and i. respectively as a result of the addition described above.
The affected pages are provided in Attachment 1 as marked up pages.
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Reason 'for the Chance and Conclusion Renardine Satisfaction of Annendix B Criteria.
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The biennial review was meluded in the OQAP as a method of determining if changes to procedures are necessary or desirable. North Atlantic has detennined that the biennial review of station procedures requires a significant expenditure of resources, imposes a significant administrative burden and does not significantly contribute to the quality of station procedures.
North Atlantic has determined that most procedure changes are identified during the perfonnance of other activities, such as the preparation of a station design change, performance of work activities including the use of the procedures for plant evolutions, reviews ofindustry and Seabrook Station operating experience.
North Atlantic has implemented a procedure compliance policy that requires personnel to initiate the appropriate procedure change when a procedure is found to be unclear or in error. These existing procedure compliance requirements ensure that procedures are reviewed and revised when required, ensure that procedures are revised when necessary before they are used and make the biennial procedure reviews redundant and unnecessary, in many cases, personnel will be diverted from activities that are important to the safe operation of the plant to perform a biennial procedure review simply because the two year time period will expire. North Atlantic believes that resources are more appropriately and effectively utilized when procedure reviews are performed as required by the existing procedure compliance policy in conjunction with the plant design control program and the operating experience review program.
Therefore, North Atlantic proposes to delete the biennial procedure review requirement from the OQAP.
The deletion of the biennial procedure review requirement will not result in a degradation of station procedures necessary for safe operation of the plant. North Atlantic believes that a more effective procedure review is performed when the individuals involved are preparing to use the procedures, revise station equipment or are completing operating experience reviews. These activities provide more involvement with the procedure and contribute to a procedure review that is superior to that obtained because a two year period will expire. The purpose of the biennial review is to ensure that station procedures remain clear and accurate and the appropriate revisions are incorporated. In many cases, the only revisions incorporated are format related or are the aesults of previous operating experience evaluations which have been held for inclusion on the two year cycle. North Atlantic believes that the scheduling of procedure revisions, based upon the significance of the revision and its affect on plant safety, is the most effective method to obtain quality procedures.
The biennial review is being fulfilled by the ongoing station programmatic requirements that fully ensure the activities afTecting quality are prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and that they are accomplished in accordance with these instructions, procedures or drawings. Therefore, this revised OQAP will continue to satisfy the crheria of 10CFR50, Appendix B, Ouality Assurance Criteria for Nuclear Power Plants and Fuel Processine Plants.
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North Atlantic l
January 14,1994 9
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ATTAClii. LENT 1 to NYN-94002 MARKED UP PAGES UFSAR SECTION 17.2 I
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SEABROOK UPDATED FSAR REVISION 2 17.2.6.4 chances Procedures exist tc ensure that changes to documents are reviewed and approved by the same organizations that performed the initial review and approval or by i'
l other qualified responsible organizations designated by NAESCO.
In either case, the reviewing organizations have access to pertinent backgroun.d information upon which to base their review, and have an adequate understanding of the requirements and intent of the original document. This includes design and procurement document changes identified in other sections of the OQAP.
Documents that are made obsolete or are superseded as a result of changes are removed from the controlled distribution when replaced by the new revision.
For those documents which are not on controlled distribution, the required verification of revision status prior to each use results in purging outdated I
documents from the work areas.
Audits of document control assure the proper implementation and control.
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e a lea as.igofous st in' la pro edur rev'ev j 17.2.7 Control of Purchased Material. Ecuipment and Services 17.2.7.1 Planninc l NAESCO has the responsibility to implement appropriate measures to ensure that purchased material, equipment and services conform to procurement documents.
Appropriate measures are described in Subsection 17.2.4 and may include source evaluation and selection, source inspection, surveillance or audit, or receipt inspection. During the review of procurement documents, personnel following written procedures and guidelines, identify those characteristics and/or processes important to the quality of the item or service and specify inspection, audit or surveillance activities commensurate with the procurement scope.
17.2.7.2 Source Activities Inspection, surveillance and audit activities at the source are identified.in accordance with the plan developed for procurement. These activities are i
normally performed by YNSD-QAD personnel. Qualified personnel perform the l
activities using written procedures / checklists and forma lly report to the l NAESCO Staff on their quality findings, including problem areas of the procurement. Persohnel assigned these activities have the delegated authority to stop work if necessary. The Nuclear Quality Group maintains cognizance of the activities of YNSD to assure proper implementation of source activities.
17.2-26 i
i SEABROOK UPDATED FSAR REVISION 2 and specifications. Training and examinations are administered to determine the capability of each individual.
Qualification records of onsite personnel associated with special processes are established, filed and kept current.
The period of validity and criteria for requalification are in accordance with the applicable codes, specification and standards.
17.2.9.3 Process Performance Special processes are accomplished using written process sheets, procedures, checklists, travelers or equivalent. These documents provide for recording of evidence to indicate acceptance in accordance with the process requirements.
Acceptance of the results is performed by personnel qualified for acceptance i
of the special process.
Records which verify that the required activities were accomplished in accordance with qualified procedures and by qualified l
personnel are maintained and filed.
17.2.10 Insoection 17.2.10.1 Ceneral Inspections associated with normal operations of the plant, such as j
maintenance, surveillance, and tests, are performed by the Nuclear Quality Group unless delegated to another organization.
Inspectors are trained and
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certified to meet the requirements of ANSI N45.2.6 by the Nuclear Quality l
Manager prior to performing inspections.
Personnel performing nondestructive examination are certified to SNT-TC-1A.
The responsibility of inspectors is defined in appropriate procedures.
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17.2.10.2 Technical Soccification Surveillance Tests The Station Manager directs the preparation of Technical Specification Surveillance tests.
The program requires that surveillance be performed to assure that the rtation equipment operates in accordance with documented procedures, Technical Specifications, Updated FSAR and OQAP requirements. The original and subsequent revisions of the Technical Specification surveillance procedures require review by SORC and approval of the Station Manager. The Nuclear Quality Group performs surveillances of Technical Specificati n tests.
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17.2.10.3 Maintenance and Modification Inspection
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v.r_m b ase_ W Maintenance, modification, repair or replacement activities are inspeccea in accordance with the original inspection requirements or engineerin5-approved alternatives. Documents that provide instructions for performing the activities specify the inspection requirements and are selectively reviewed surveilled and/or audited by the Nuclear Quality and Nuclear Safety and Assessment Groups.
Inspection hold points are designated in the procedures or other documents when deemed necessary to inspect the quality of the item.
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SEABROOK UPDATED FSAR REVISION 2 Technical Specification Surveillance Tests:
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-Periodic tests performed on station systems and components to verify j
system and/or equipment operability requirements.
Modification Tests:
Tests performed on structures, systems and components by the Seabrook Staff or contractors after modification to assure compliance to operating requirements, codes and standards prior to returning the system to service.
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17.2.11.2 Test Procedures i m -oxx.- #M Nh5"*h'""
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Startup, Technical Specification surveillance, and modifications test procedures are reviewed by 'SORC and approved by the Station Manager (see Note in Subsection 17.2.11.1)W. In the case of contractor involvement, test procedures are submitted for approval as required by procurement documents.
Any proposed test or experiment which involves an unreviewed safety question, as defined in 10 CFR 50.59, is reviewed by SORC and NSARC.
Test procedures contain or provide the following, as required:
a.
Prerequisites such as environmental conditions, and test
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instrumentation requirements and accuracy b.
Provision for assuring that test prerequisites have been met c.
Instructions for performing the test d.
Incorporation or reference to appropriate requirements and acceptance limits contained in the applicable design and procurement documents e.
Acceptance or rejection criteria f.
Inspection hold points, where applicable g.
Methods of documenting or recording test data and results.
17.2.11.3 Conduct of Tests /Results Tests are performed by suitably trained, qualified or licensed personnel according to the written procedures. Test abnormalities discovered during testing are resolved before structures, systems or components are required to perform an intended safety function. Results of testing are documented and evaluated for acceptability by qualified personnel to assure that test requirements have been satisfactorily completed.
Documented test results are retained for the record.
17.2-32
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4 SEABROOK UPDATED FSAR REVISION 2 For modifications where these requirements are not considered practical, a review in accordance with the provisions of 10 CFR 50.59 l
vill be conducted and documented.
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Paragraph C.S.f of Regulatory Guide 1.33 (and Section 5.2.19 (2) of j
ANSI N18.7 which it references) will be implemented with the substitution of the word " feasible" for the word "possible" in the 8
last sentence.
d.
With regard to Section 5.2.7 of ANSI N18.7-1976 titled Maintenance and Modification: Since some emergency situations could arise which j
might preclude preplanning of all activities, NAESCO will comply with 3
an alternate to the first sentence in the second paragraph which reads: "Except in emergency or abnormal operating conditions where i
immediate actions are required to protect the health and safety of the public, to protect equipment or personnel, or to prevent the deterioration of plant conditions to possible unsafe or unstable level, maintenance and modification of equipment shall be preplanned and performed in accordance with written procedures.
Where written j
procedures would be required and are not used, the activities that i
were accomplished shall be documented after-the-fact and receive the same degree of review as required for temporary procedures."
With regard to Section 5.2.7.1 of ANSI N18.7-1976 titled Maintenance e.
l Procrams: NAESCO will comply with the requirements of this section with the clarification obtained by adding the phrase "Where feasible" before the first sentence of the fifth paragraph.
It is not always possible to promptly determine the cause of a malfunction.
In all
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cases, NAESCO will initiate proceedings to determine the cause, and vill make such determinations promptly, where it is feasible, f.
Uith regard to Section 5.2.10 of ANSI N18.7-1976 titled Housekeepinn and Cleanliness: Instead of the pre-closure cleanliness inspection specified in the second paragraph, a documented cleanliness verification will be performed prior to closure of any portion of safety-related systems.which may be subject to potential-contamination with foreign material. The personnel performing this verification will be qualified to the requirements of ANSI /ANS 3.1-1978.
Additionally, an independent pre-closure cleanliness g
inspection will be performed at a frequency commensurate with the safety significance of.the affected system or component.
h jf.
With regard to Section 5.2.16 of ANSI N18.7-1976 titled Enasuring and l
Test Eculpment: NAESCO will comply with the requirements of this section with the clarification that the first paragraph delineates the requirements for installed instrument and control devices. These installed Instrument and Control devices will be calibrated by the use of a transfer standard which meets the requirements of this section.
17A-4 l
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f INSERT A g.
With regard to Section 5.2.15 of ANSI N18.7-1976 titled Review. Approval and Control of Procedures: NAESCO will comply with the requirements of this section with the exception of the requirement to review plant procedures no less frequently than every two years to determine if changes are necessary or desirable. Other programs in place at Seabrook Station make the biennial review redundant. The effectiveness of these programs in maintaining precedures current is verified by a system of periodic audits, surveillances, and/or inspections.
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SE.*. BROOK UPDATED FSAR REVISION 2 k h.
With-regard to Section 5.3.9.3 of ANSI N18.7-1976 titled Procedures l
for Implementine Emerrency Plan: NAESCO has an NRC-accepted Emergency Plan for the nuclear facility which will be implemented instead of the requirements in this section.
Rerulatory Guide 1.37 Ouality Assurance Reauirements for Cleaning of 4Rev. O, 3/73)
Fluid Systems and Associated Comoonents of Water-Cooled Nuclear Power Plants Endorses ANSI N45.2.1-1973 During the operational phase, the Operational Quality Assurance Program includes and complies with this guide with the following clarification:
a.
Section 2 3 of ANSI N45.2.1-1973, last sentence, is revised to read,
" Test reports shall include an evaluation of the acceptability of inspection and test results and identify the individual who performed the evaluation."
b.
With regard to Section 2.4 of ANSI N45.2.1-1973, titled Cleanine of Fluid Systems and Associated Components Durine Construction Phase of Nuclear Power Plants: Personnel qualifications for individuals l
performing a pre-closure cleanliness verification shall be in-accordance with ANSI /ANS 3.1-1978.
Personnel performing an independent cleanliness inspection shall be qualified in accordance l
with ANSI N45.2.6-1978.
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Section 7.1 of ANSI N45.2.1-1973 requires, in the last sentence of the second subparagraph, that " Loose tools should be attached....
l with a lanyard." NAESCO will control loose tools by procedures or work permits. Precautionary measures such as barriers between work areas, and tool check-in and check-out controls may obviate the need for lanyards. Where not obviated, the standard will apply.
d.
Section 3.1.1 of ANSI N45.2.1-1973 requires Class A cleanliness to be applied to special items such as fuel elements, control rod drive mechanisms, delicate instruments and other close tolerances or carefully controlled surfaces or assemblies and maintained at the l
construction site.
Instead of Class A cleanliness, NAESCO will follow the recommendations of the manufacturer to maintain a required level of cleanliness during various construction, preoperational, j
test and operations activities.
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