ML20077A513

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Proposed Tech Specs,Deleting Audit Frequencies & Requirement to Perform Radiological Emergency Plan & Security Plan Audits
ML20077A513
Person / Time
Site: Browns Ferry, Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/15/1994
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20077A511 List:
References
NUDOCS 9411230267
Download: ML20077A513 (47)
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.g, i i ENCLOSURE 1' i PROPOSED TECHNICAL , SPECIFICATION CHANGES

  • l (MARKED PAGES)

BROWNS FERRY NUCLEAR PLANT LIST OF AFFECTED PAGES UNIT'1 6.0-14 i I 6.0-15 l UNIT 2 I 6.0-14 6.0-15 UNIT 3 l 6.0-14 l 6.0-15 9411230267 941115 PER ADOCK 05000259 P PDR

JUN 301988 AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB, These audits shall encompass:

a. The conformance of plant operation to provisions contained -

within the Technical Specifications and applicable license conditions, et--leee t once per 12 renths, 1

b. The performance, training and qualifications of the entire plant staff,at least One: per 12-monther
c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety, at laast- ence M mther-
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B,10 CFR Part 50x.at-4 east--ence-per-24-months,
e. -The-Site-Radiological- E=crgency Plan and implerenting precedurea at least ene cin y le montas. (10eie.LeM
f. Tha D1 =nt Phyoiral Security Pl an and implement 4ag-procedures at--least-once :::rj 12- muuGm. (@detth
g. Any other area of site operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power. j i
h. The fire protection programmatic controls including the implementing procedures, st-4 east on:: per 24-monthsv BFN 6.0-14 Unit 1 AMENDMENT N0.14 9 l

~

l. -

SEP 2 21993

1. An independent fire protection and loss prevention program inspection and audit shall be performed annuaMy- utilizing either q-14 #4 ed ef feite-14eumu versonnel vr-an outside fire protection firm.

J. L_ inepertian and and4* at the - fire-proteet4cn -"d-lese 

                    -prevent 4on--pro 8- ^=11 be perfer=:d by an-eutsite-pl iLied-fire--eonsultan t-a t-i nte rvale-no-g reater-th an- Jr
                    -yeom ( L0c.) ettec0
k. The Radiological Environmental Monitoring program and the results thereof,at le et enee per 12 nenthe.
1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 19754at le:st snee cverj 14 menti s.-
m. The-performance of activitia= required by the Sef+ guards Cvui.ingenef Piirn-to-eeet-the-cr4terie-of-10-GFR,74.40(dt at least-ence-every--itmvuilw. (10e.le6 M
n. The Offsite Dose Calculation Manual and implementing ~i procedures.at--leest- ^nes per months- l
o. The Process Control Program and implementing procedures for I solidification of wet radioactive wastes.at-4 east en:c per 24-monther-  ;
p. (Deleted)

BFN 6.0-15 ARENDMENT NO. I 9 9 i Unit 1 l l

I s APR 0.11993 6.5.2.8 Audits of unit activities shall be perfonned under the cognizance of the NSRB. These audits shall encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions,at les=t ene: per 12 n:nths-
b. The performance, training and qualifications of the entire plant staff.at leest ente per 12 ;;;tM .
c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety,at-44ast ene per4 months,
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B,10 CFR Part 50,,at-least enee pee 24 nenths,
e. The-Sit: "edielegfeel
  • cr==acy-P4en oud impi-ementing.

preesdv.c= a6 lesm6 vuuc every12moniim.(IOeIeded)

f. The-Plant @ical Security Pin =d implementitts-procedures-at-leasi vuce cry-43--mon'thr. (&led)
g. Any other area of site operation considered appropriate by i the NSRB or the Senior Vice President, Nuclear Power. 1 I
h. The fire protection programmatic controls including the -

implementing procedures,at.-leest One: pe r--34-months,  ! i BTN 6.0-14 AM DM E207 Unit 2 1

Fll .. 

   ..                                                                                                      j t

SEP 2 21993 i

1. An independent' fire protection and loss prevention program
                               -inspection and audit shall be performed --- r117-utilizing                   l
                              -either ;;elified effeite lie-- : perra_ 1 r-an outside fire protection firm.                                                       !
j. in 4- ;ectien --d
dit ^# tha # ira pret::tien -ad ler:

pr: ;; tion progres shall te perfere d by ;; e imide I q;;1ified fir: ::1:010;Lt et iLisavals av gAcaisi thau --3* l 

                               - (&teso)                                                                    !
k. The Radiological Environmental Monitoring program and the '

results thereof.=t irrrt :::: ;:: ?? renth:,  !

1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide v 4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 1975.,:0# 1;;;; :nc -.mi, 12-
^ . E
m. The per'ar=ance of activitie ::; ired by th; 3;;;g;;;g;_

Cestias uuy Plan uw ;;;t th: crit:ri: Of 10 CT: 70.40(d) :: { 

                ,.             1---t eaum  every 12 _esthe. (k)e(e.tecQ)                                  :

1 i

n. The Offsite Dose Calculation Manual and implementing .I procedures.:t-le::t ere per I? ---*h=- '

i

o. The Process Control Program and implementing procedures for i solidification of wet radioactive vastes, t' 'rrrt ;;ce per 24 -vuihm. I
p. (Deleted) ~

5 t 

                                                                                                            ?

BFN 6.0-15 Unit 2 AMENDMEIR NO. 216 l i i 1 i f l t 

                                                                                                   -        f

I' JUN 301988  ! AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license i conditions.ct leset One: per 12 =enthe,
b. The performance, training and qualifications of the entire plant staff.et le::: enco yor 12-months, 1

i

c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method ,

of operation that affect nuclear safety,a+ leiet ene; pcr 5 seu tim .

d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50.,,et 12 :t :::: per 2^ nenths.

i l'

e. h: Redieingie=1 T-crgens, Flan and impl: ;nting-
                    -peoceduces---at,- 14act once c;cr; 12 months. (6ejefeM)
f. ' rue riaru. F;gsical-Sees li, rien and i=p1 renting procedures at--least-;nce o v ati 12 months,(O d c N
g. Any other area of site operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power. i
h. The fire protection programmatic controls including the implementing procedures.at4eest--once per 24 =enthe.

BFN 6.0-14 Unit 3 i AMENDMENT NO.12 0

lt .. i i SEP 2 21993 I

1. An independent fire protection and loss prevention program inspection and audit shall be performed ennty Hy utilizing either.-que14414d.-ons144-414enac-perouuuci - er an outside fire protection firm.

l l

j. Ic in:;:: tion-and-sudiuf- the firc proteeden :nd less-1 prevention-progr== ahal' be p i f u d "uy au vui.ite-quali44ed41r :: :;1tet :: intervels-ne gieiiles- cuarr-3 yeere. (Oeje f.,eM
k. The Radiological Environmental Monitoring program and the resulta thereof. at-leest ent:--per-le--months,
1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Culde 4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 1975_,,4t-lee:t cn:c every M months. '
m. The-per-formwwe-of- =ctivitier requir d by the Safeguards Contingruuy Flan-'ttnneet-the cliics-i. of 10 CFR 73.40fd)- art least ence even- 1R 1nonther (Ce {e deck)
n. The Offsite Dose Calculation Manual and implementing procedures.at-4eest encc per 12 nenths, l (
o. The Process Control Program and implementing procedures for solidification of wet radioactive wastes.at--least-once per 24 neni'us.
p. (Deleted)

BFN 6.0-15 AMENDMENT NO.172 Unit 3

v 6 ENCLOSURE 2 DISCUSSION AND SIGNIFICANT HAZARDS CONSIDERATION EVALUATION BROWNS FERRY NUCLEAR PLANT l I

s Discussion of chances Introduction Currently, the Administrative Controls section of the Standard Technical Specifications for General Electric Plants (NUREG-1433, Vol. 1) states that the combination of reviews and audits should be integrated "into a cohesive program that provides senior management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability." Therefore, these administrative tools should be sufficiently flexible to allow for senior management direction of resources to focus upon areas requiring increased attention. The proposed changes to the Technical Specification administrative controls would provide such flexibility through the elimination of certain rigid audit frequencies. Additionally, references to reviews and audits of the facility's Radiological Emergency Plan, and Physical Security / Safeguard Contingency Plan (and of their associated implementing procedures) would be removed from the Technical Specifications because those requirements presently exist within the individual Plans. This action reflects the guidance provided in an NRC Generic Letter 93-07, dated December 28, 1993, and is similar to the Virginia Power submittal of July 20, 1993.

Background

The minimum scope and schedules for the audit program have been specified by the Administrative Controls section of the facility's Technical Specifications. The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements from various sources including the Code of Federal Regulations (Physical Security Program, Fitness For Duty Program, etc.), Standard > Technical Specifications, NRC Generic Letters (annual, biennial, and triennial Fire Protection audits), industry guidelines and standards (Conformance to Technical Specifications and Operating License, Effectiveness of Corrective Actions, and Training audits). The audits , specified by these sources are meant to address programs ' which are deemed to be essential to the effective management of each nuclear facility. However, the rigid schedules , dictated by the Technical Specifications do not allow l management the flexibility to recognize good performance by E2-1 I 1

r certain organizations, and resources which could be devoted to areas with perceived weaknesses are diluted by the requirement to audit strong programs at the frequencies set forth in the Technical Specifications. The proposed changes would allow for decreasing the frequencies of certain audits, increasing the frequency of the triennial fire protection audit to biennial, and maintaining the frequency of those audits presently scheduled biennially. Additional flexibility would also be introduced by allowing a 25% extension to the frequency of most audits. The exceptions to this frequency extension or " grace period" would be those audits which have frequencies specifically delineated by the Code of Federal Regulations (i.e., Radiological Emergency Plan and Implementing Procedures Audit, Physical Security Plan and Implementing Procedures Audit, and Safeguard Contingency Plan). On December 28, 1993, the NRC published Generic Letter 93-07 which provides guidance for relocating certain requirements (without reducing them) from the Technical Specifications to other NRC-approved program documents. The proposed generic communication specifically addresses the reviews and audits of the Radiological Emergency Plan and implementing procedures and the Physical Security / Contingency Plan and implementing procedures. Currently, the requirements for these reviews and audits are incorporated into the Browns Ferry Radiological Emergency and Physical Security / Contingency Plans. The proposed changes would delete the redundant references in the facilities' Technical Specifications to the requirements which originate in Title 10 of the Code of Federal Regulations [10 CFR 50. 54 (t) for Emergency Preparedness and 10 CFR 50.54(p), 10 CFR 73.40, 10 CFR 73.55, and 10 CFR 73.56 for Security). Description Of Specific Chances The proposed amendment would eliminate the references to specific frequencies for each of the Technical Specification required audits and eliminate reference to reviews and audits of the Radiological Emergency Plan,'and Physical Security / Contingency Plan. Instead, a statement would be added to the Nuclear Quality Assurance Plan (TVA-NQA-PLN89-A) specifying that the audits listed in the Technical Specifications would be accomplished on a biennial (2 years) frequency as defined in Section 12.2.E.2 of the NQA Plan and as directed by administrative procedures and/or management. The requirements for reviews and annual audits of the E2-2

- - . . ~ .-- - - 1 s facility Radiological. Emergency Plan and Physical - Security / Contingency Plan'(and their associated implementing i procedures) are currently delineated within the NRC-approved Radiolcgical-Emergency Plan and Physical Security / Conting,60y Plan for Browns Ferry Nuclear' Plant as provided for in k e NRC's generic communication. Each of the  : proposed changes to the Technical Specifications is , discussed by line item below: , prowns Ferry Unit 1. Unit 2. and Unit 3 Technical i Specifications:  ; ADMINISTRATIVE CONTROL Section 6.5.2.8 has been revised to delete the references to specific audit frequencies. In  ! accordance with the Standard Review Plan (SRP) Section 17.3 (" Quality Assurance Program Description") guidance on j planned and periodic assessments scheduling and resource allocation,'the following statement has been prepared for Section 12.2.E.2 (" Audits") of the NQA Plan and is included in Enclosure 5:  ; Auditing organizations shall ensure that audit procedures and instructions adequately cover applicable elements.of the Nuclear Quality Assurance Program. Audit subjects are specified in plant technical , specifications and regulatory commitments. Audit  ! 

                      -frequencies shall normally be biennially with an allowance of a 25-percent (six-months) extension at management's discretion. The audit frequencies for                        ,

programs involving each site's Radiological Emergency , Plan and Physical Security / Contingency Plan are as l required by the Code of Federal Regulations. Additionally, a proposal is being made in Enclosure 5 to l modify alternative number 6 of NRC Regulatory Guide 1.33 in  ! the NQA Plan. Specifically, audit frequencies will no i longer be specified in plant specific technical i specifications but specified as biennial (2 year) in Section 12.2.E.2 of the NQA Plan. This change neither alters the function nor diminishes the l quality of the Audit Program. The Nuclear Safety Review  ! Board (NSRB) retains responsibility for oversight of the Quality Assurance Audit Program. The sole change to the  ! process is associated with the audit frequencies.. 1 Specifically, audit frequencies are being specified generically in the NQA Plan. The revision allows an . i extension for time intervals not specified in the Technical Specifications of up to 25 percent. Therefore, the maximum  : time between specific audits could be 30 months. The  ! I E2-3 l l I i 

  -       ,- ~ -         , , - - , . , - .           -.   ,-       -   .-             ,      r.

extension would not be applicable to those audits with frequencies mandated by the Code of Federal Regulations (e.g., Radiological Emergency Plan, Physical Security / Contingency Plan.) The Technical Specification-required audits and the impacts of the proposed changes are listed below: The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions. Applicable portions of the Technical Specifications and license conditions are assessed during each audit for the particular area (s) being audited. Reducing the frequency of these audits to biennial (2 years) will not adversely impact compliance with those provisions of the Technical Specifications, the commitments in the NQA Plan to ANSI N18.7-1976, or the effectiveness of audits performed. Compliance with the Technical Specifications and license conditions is evaluated more often than each 12 months although not in a single Technical Specification audit. The performance, training, and qualifications of the entire plant staff. Audits of the plant staff's qualifications (" Training Audits") are conducted annually. The proposed changes will allow management to schedule the time between specific audits to be a maximum of 30 months, as evaluated. This added versatility is not projected to adversely impact the effectiveness of either the Nuclear Training Program or the Audit Program, because management can increase or decrease the audit frequency based upon observed performance and importance to safety. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety. The results of actions taken to correct identified deficiencies are evaluated as part of each audit for the specific area being audited, and currently, an audit is performed every six months to evaluate the programmatic controls which govern the corrective action process. The proposed Technical Specification changes would not negatively affect the review of corrective actions in each audit. Only the biannual audit of programmatic controls will be affected in that management will be given flexibility to adjust the audit's frequency based upon performance as evidenced through trends and other E2-4

performance indicators. As such, the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program.

  • The performance of activities required by the operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR 50.

1 This audit is currently performed "at least once per 24 months." The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, as evaluated. This would allow the scheduling of audits to be performance based.

  • The Site Radiological Emergency Plan and implementing procedures.

The proposed change would not impact those audits whose frequencies are mandated by Title 10 of the Code of Federal Regulations and the NRC-approved plans. This audit is specified in the BFN Radiological Emergency Plan.

  • The Plant Physical Security Plan and implementing procedures.

The proposed change would not impact those audits whose frequencies are mandated by Title 10 of the Code of Federal Regulations and the NRC-approved plans. This audit is specified in the BFN Physical Security / Contingency Plan. Any other area of site operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power. There is no impact upon this Technical Specification line item. The Fire Protection Programmatic controls including the implementing procedures. This audit is currently performed "at least once per 24 months." The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, as evaluated. This would allow the audit to be scheduled during the performance of activities which impact nuclear safety. Hence, the only impact of the proposed change upon the biennial fire protection audit would be to make it more performance based. E2-5

t The independent fire protection and loss prevention program inspection and audit utilizing either qualified offsite license personnel or an outside fire protection firm (annual audit) and an inspection and audit of the fire protection and loss prevention program by an outside qualified fire consultant (triennial audit). The proposed changes will combine the annual and triennial audits into one biennial audit which will be alternated with the Fire Protection Program Audit (see above item). Hence, each year a fire protection audit will be performed, and a qualified outside consultant will be utilized in alternate years. This will not adversely impact the effectiveness of either the FireProtection/ Loss Prevention Program or the Audit Program, because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features. The radiological environmental monitoring program and the results thereof. This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the radiological environmental monitoring program's performance to a maximum of 30 months, as evaluated. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. This flexibility is consistent with guidance provided by the NRC relative to the implementation of the revised 10 CFR 20.1101(c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program). E2-6

The performance of activities required by the Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December 1977 or Regulatory' Guide 1.21, Rev. 1, 1974 and Regulatory Guide 4.1, Rev 1, 1975. ' This audit is currently performed once avery 12 months. The proposed change would allow the time between audits to be adjusted based upon the performance of the implementation of the Quality' Assurance Program to a maximum of 30 months, as evaluated. The prcgrams performance will continue tc be assessed through self - assessments and audits, and other trend indicators. The performance of activities required by the Safeguards > Contingency Plan to meet the criteria of'10 CFR 73.40(d). The proposed change would not impact these audits whose frequencies are mandated by Title 10 of the Code of Federal Regulations and the NRC-approved plans. In addition, this audit frequency is specified in the BFN Physical Security / Contingency Plan. The Offsite Dose Calculation Manual (ODCM) and implementing procedures. This audit is currently performed once every 12 months. The proposed-changes would allow the time between audits to be adjusted based upon the performance of the program implementing the Offsite Dose Calculation Manual to a maximum of 30 months, as evaluated. The program's , performance is and will continue to be assessed through l self assessments,' management reviews, QA assessments and audits, and other trend indicators. Also, the added  ; versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to , the implementation of the revised 10 CFR 20.1101(c) (i.e., refer to NRC response to NUMARC (NEI) for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, ' internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program). The Process Control Program (PCP) and implementing - procedures for solidification of wet radioactive wastes. i This audit is currently performed once every 24 months.  ; The proposed changes would allow the time between audits , to be adjusted based upon the performance of the Process ' Control Program to a maximum of 30 months, as evaluated. E2-7 l 1 

   -   -                 -          -           __      _   _                   1

4 The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. Also, the added versatility in the audit program will continue to be consistent with guidance provided by the NRC relative to the implementation of the revised 10 CFR 20.1101(c) (i.e., refer to NRC response to NUMARC (NEI) for question 118 in third set of Questionc and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program). The purpose, scope, and thoroughness of QA audits will not be affected, management oversight of the audit process will not be diminished, and the audits will be performed at frequencies commensurate with safety significance and not less than biennially (plus 25%). As such, these changes are consistent with the intent of the regulations and are an acceptable alternative. Specific line item changes involving the audit process include: ADMINISTRATIVE CONTROLS 6.5.2.8.a, 6.5.2.8.b, 6.5.2.8.k and 6.5.2.8.n have been revised to delete the phrase "at least once per 12 months." ADMINISTRATIVE CONTROL 6.5.2.8.1 has been revised to delete the phrase "at least once every 12 months." ADMINISTRATIVE CONTROL 6.5.2.8.c has been revised to delete the phrase "at least once per 6 months." ADMINISTRATIVE CONTROLS 6.5.2.8.d, 6.5.2.8.h, and 6.5.2.8.o have been revised to delete the phrase "at least once per 24 months." ADMINISTRATIVE CONTROL 6.5.2.8.i has been revised to delete the term " annually" and to require an inspection and audit by an outside qualified fire consultant. ADMINISTRATIVE CONTROL 6.5.2.8.j has been deleted since the requirements are now contained in ADMINISTRATIVE CONTROL 6.5.2.8.i. l E2-8 l 1

1 . I ADMINISTRATIVE CONTROLS 6.5.2.8.e, 6.5.2.8.f, and j 6.5.2.8.m have been deleted. The requirements for these I audits.(Radiological Emergency Plan, Physical Security l Plan, and Safeguards Contingency Plan) are specified within.the Browns Ferry. Nuclear Plant Radiological Emergency Plan, and the Browns Ferry Nuclear Plant  ; Physical Security / Contingency Plan. Bionificant Hazards Consideration i TVA has concluded that operation of BFN units 1, 2, and 3 in accordance with the proposed change to the technical specifications does not involve a significant hazards consideration. TVA's conclusion.is based on its evaluation in accordance with' 10 CFR 50.91(a) (1) , of the three l standards set forth in 10 CFR 50.92(c). TVA's conclusion is I based on the following:

1. The proposed amendment does not involve a significant increase in the probability.or consequences of an accident previously evaluated.

The likelihood that an accident.will occur is neither 1 increased or decreased by this Technical Specification change which only affects review and audit frequencies. This Technical Specification , change will not impact the function or method of l operation of plant equipment. Thus, there is not a significant increase in the probability of a previously analyzed accident due to this change. No systems, equipment, or components are affected by the I proposed change. Thus, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR are not increased by this change. 1 The proposed change only affects review and audit frequencies. As such, the proposed change has no impact on accident initiators or plant equipment, and thus, does not affect the probabilities or < consequences of an accident. l I Therefore, we conclude that this change does not significantly increase the probabilities or consequences of an accident. E2-9 1 1

2. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed changes do not involve changes to the physical plant or operations. Since program audits do not contribute to accident initiation, a change related to audit functions cannot produce a new accident scenario or produce a new type of equipment malfunction. Also, this change does not alter any existing accident scenarios. The proposed change does not affect equipment or its operation, and, thus, does not create the possibility of a new or different kind of accident. Therefore, the proposed change does not create the possibility of a new or different kind of accident.

3. The proposed amendment does not involve a significant reduction in a margin of sarety.

The proposed change concerning conduct of reviews and audits does not directly affect plant equipment or operation. Safety limits and limiting safety system settings are not affected by this proposed change. Therefore, use of the proposed Technical Specification would not involve any reduction in the margin of safety. Based on the above, we have determined that the Technical Specification change request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this Technical Specification change request does not involve a significant hazards consideration. Environmental Impact Consideration The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR

51. 22 (c) (9) . Therefore, pursuant to 10 CFR 51.22 (b) , an environmental assessment of the proposed change is not required.

E2-10 

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l i ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT . i LIST OF AFFECTED PAGES > f UNIT 1 i 6-11 6.12 l APPENDIX B 5-2  ! i UNIT 2  ! 6-11 -! APPENDIX B 5-2 , i i E i 1

a D 1 ADMINISTRATIVE CONTROLS  ;

f. Significant operating abnormalities or deviations from normal and expected performance of unit equipment that affect nuclear safety.  ;
g. All REPORTABLE EVENTS. R62  !

i

h. All recognized indications of an unanticipated deficiency:in some  :

aspect of design or operation.of structures, systems, or components  ; that could affect nuclear safety. *

1. -Reports and meetings minutes of the PORC.

R182 l-. ( AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of l the NSRB. These audits shall encompass:  !

a. The conformance of unit operation to provisions contained within the  !

Technical Specifications and applicable license conditions.:t least- . ence per 12 months. l

b. The performance, training and qualifications of. the entire' facility R78 i

staff.at---! cast once per 12 months. '

c. The results of actions taken to correct deficiencies occurring in i unit equipment, structures, systems or method of operation that-  :

affect nuclear safety,at lec:t cacc per S months.  ?

d. The performance of activities required by the Nuclear Quality c Assurance Program to meet the criteria of Appendix "B", 10 CFR 50 . R182 l
                          +t-Jeest cace per 24 months.
e. The-Site-Radielegical Emergency D]33 nd 47p];7 nting p7gggjurc5-et-leset once per 12 months.(celete&) *
f. Ths41antWsical Seceity plan, the Sa4 guards Certingency Plan  !

aM 4mpicmcat4ng-presederes-at-4 east cace-pr 12 months,- OOeActres) 9 Any other area of unit operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power. -

h. The facility Fire Protection Program and implementing procedures.st- .

4 east once per-24 ranths i

i. An independent fire protection and loss prevention program inspection and audit shall be performed annually utilizing either qualifiat af-fsite licen:ce persernel er an outside fire protection firm.

J. An-inspectien and auditief the f4re protection and les: prevention progrr shall be performed by. n outside qualifie fire consultcnt St-ieteFMis--nc greater than 3 ycGM. ygg March 31, 1994 SEQUOYAH - UNIT 1 6-11' Amendment No. 68, 74, 178

ADMINISTRATIVE CONTROLS

k. The radiological environmental monitoring program and the results thereof,at--le n t once per 12 montt+.
1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.-at lesst-stcc per 24 months
m. The PR0:ESS CONTROL PROGRAM and implementing procedures for SOLIDIFICATION of radioactive wastes,at lesst once per 2' - + "
n. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, R46 Rev. 1, 1975 ,;at leest unce per 12 month s AUTHORITY 6.5.2.9 The NSRB shall report to and advise the Senior Vice President, Nuclear PowepthoseareasofresponsibilityspecifiedinSections6.5.2.7and6.5.2.8. R78 RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved and distributed as indicated below:
a. Minutes of each NSRB meeting shall be prepared, approved and forwarded to the Senior Vice President, Nuclear Power within 14 days following each meeting. R78 b,. Reports of reviews encompassed by Section 6.5.2.7 above, shall be prepared, approved and forwarded to the Senior Vice President, Nuclear Power within 14 days following completion of the review. R78
c. Audit reports encompassed by Section 6.5.2.8 above, shall be for-warded to the Senior Vice President, Nuclear Power and to the manage-ment positions responsible for the areas audited within 30 days after g73 completion of the audit.

6.5.3 THIS SPECIFICATION IS DELETED R182 l l 1 I l March 31, 1994 SEQUOYAH - UNIT 1 6-12 Amendment No. 42, 58, 74, 178 152

E. All nonroutine reports prior to submittal of the written report (described in Subsections 5.4.2.a, b, and c). F. Investigations of all reported instances of noncompliance with Environmental Technical Specifications, associated corrective actions, and measures taken to prevent recurrence. 5.2.2 Audit The licensee shall conduct an audit c=c per 18 =nths of the environmental monitoring program. The audits shall be conducted independently of the Rlli individual or groups responsible for performing the specific activity. Results of the audit activitics shall be maintained and made available for inspection. 5.3 Changes in Station Design or Operation Changes in station design or operation may be made subject to the following conditions: A. The licensee may (1) make changes in the station design and operation, and (2) conduct tests and experiments not described in this document without prior Commission approval, unless the proposed change, test or experiment involves a change in the objectives of the ETS and/or an unreviewed environmental question of significant impact. B. A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact SEQUOYAH-UNIT 1, APP. B 5-2 Amendment No.107 March 15, 1989 

  *                                                                                               \

1. ADMINISTRATIVE CONTROLS AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass:

a. The conformance'of unit operation to provisions' contained within the Technical Specifications and applicable license conditions. t least-once per 12 menths.
b. The performance, training and qualifications of the entire ~ facility R66 staff. at least cncc per 12 month:.
c. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety.at least cace per 0 months.
d. The performance of activities required by the Nuclear Quality Assur-ance Program to meet the criteria of Appendix "B",10 CFR 50 cat
  • R169 l least-cace per 24 months.
e. 3 at i The Site-Radiclcgical least-- Emcrgency Pl)n and implementing precedu,c:

cace per 12 mentAt.(toelete.4

f. %c Plent Physical Security Dhn, the Safeguards Contingency Pian and- mplementing 9eetedure; at-lcast once per 12 menths. 60,\eted
g. Any other area of unit operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power.

R66 hf The Facility Fire Protection Program and implementing' procedures,et-katt ence per 24 months,

i. An independent fire protection and loss prevention program inspection and audit shall be performed annual-1-y utilizing either qualified effrite licen:ce percennel or an outside fire protection firm.
j. h--impectier ud audit of the Hre protec-t4cn and less prevention program shall be perJormed by an nutside qucli-f4cd fire consultant at intervahr no-geeater than 3 yeam(K)elete&)
k. The radiological environmental monitoring program and the results thereof.at lea:t once per 12 month.
1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.at- '

kast once per 24 months 4

m. The PROCESS CONTROL PROGRAM and implementing procedures for SOLIDIFICATION of radioactive wastes.at-4 east once per 24 maths.
n. The performance of activities required by the Quality Assurance Pro- l gram to meet the criteria of Regulatory Guide 4.15, December 1977 or l Regulatory Guide 1.21, Rev. 1, 1974 and Regulatory Guide 4.1, Rev. 1, R34 l 197 5., et-4eest-enee--per-le^ ^

March 31, 1994 SEQUOYAH - UNIT 2 6-11 Amendment No. 34, 50, 66, 169

O 4 E. All nonroutine reports prior to submittal of the written report (described in Subsections 5.4.2.a, b, and c). F. Investigations of all reported instances of noncompliance with Environmental Technical Specifications, associated corrective actions, and measures taker, to prevent recurrence. 5.2.2 Audit The licensee shall conduct an audit once per 10 acr.ths of the environmental monitoring program. The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. R97 Results of the audit activities shall be maintained and made available for inspection.

5. 3 Changes in Station Design or Operation Changes in station design or operation may be made subject to the following conditions:

A. The licensee may (1) make changes in the station design and operation, and (2) conduct tests and experiments not described in this document without prior Commission approval, unless the proposed change, test or experiment involves a change in the objectives of the ETS and/or an unreviewed environmental question of significant impact. J B. A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns (1) a matter which may result in a significant increase in any adverse environmental impact SEQUOYAH-UNIT 2, APP. B 5-2 Amendment No.97 March 15, 1989 l I l 

                  -______-_--____________-____-___-_____--______________-_______________-___-___-_______-______Y

& , - .,~A4.J J aa & _.+i . u % a. - -m a m..o s. 4.m 6..u . _a#... 6 e-K s ENCLOSURE 4 DISCUSSION AND SIGNIFICANT HAZARDS CONSIDERATION EVALUATION SEQUOYAH NUCLEAR PLANT l e T i 1 1 i 

                                                                                                          )

l 1 

                                                      , .         ~ -, - . . ,,-          -,, -

L I i piscussion of chances Introduction ) Currently, the Administrative Controls section of the Standard Technical Specifications for Westinghouse plants (NUREG-1431, Vol. 1) states that the combination of reviews j and audits should be integrated "into a cohesive program 1 that provides senior management with an assessment of facility operation and recommends actions to improve nuclear safety and plant reliability." Therefore, these administrative tools should be sufficiently flexible to allow for senior management direction of resources to focus upon areas requiring increased attention. The proposed  ! changes to the Technical Specification administrative controls would provide such flexibility through the elimination of certain rigid audit frequencies. Additionally, references to reviews and audits of the site's Radiological Emergency Plan and Physical Security / Safeguard Contingency Plan (and of their associated implementing procedures) would be removed from the Technical Specifications because those requirements presently exist within the individual Plans. This action reflects the guidance provided in an NRC generic communication, Generic Letter 93-07 published December 28, 1993 and is similar to Virginia Power submittal of July 20, 1993. Backaround The minimum scope and schedules for the audit program have been specified by the Administrative Controls section of the facility's Technical Specifications. The specific audits and their associated minimum frequencies have been developed and implemented to comply with requirements from various sources including the Code of Federal Regulations (Physical Security Program, Radiological Emergency Plan, Standard Technical Specifications, NRC Generic Letters (annual, biennial, and triennial Fire Protection audits), industry guidelines and standards (Conformance to Technical Specifications and Operating License, Effectiveness of Corrective Actions, and Training audits). The audits specified by these sources are meant to address programs which are deemed to be essential to the effective management of each nuclear facility. However, the rigid schedules dictated by the Technical Specifications do not allow i E4-1

management the flexibility to recognize good performance by certain organizations, and resources which could be devoted to areas with perceived weaknesses are diluted by the " l requirement to audit strong programs at the frequencies set forth in the Technical Specifications. The proposed changes would allow for decreasing the frequencies of certain audits, increasing the frequency of the triennial fire protection audit to biennial, and maintaining the frequency of those audits presently scheduled biennially. Additional flexibility would also be introduced by allowing a 25% extension to the frequency of most audits. The exceptions to this frequency extension or " grace period" would be those audits which have frequencies specifically delineated by the Code of Federal Regulations (i.e., Radiological Emergency Plan and Implementing Procedures Audit, Physical Security / Safeguards Contingency Plan and Implementing ) Procedures Audit). On December 28, 1993, the NRC published Generic Letter 93-07 )j which provides guidance for relocating certain requirements (without reducing them) from the Technical Specifications to l other NRC-approved program documents. The proposed generic I communication specifically addresses the reviews and audits of the Radiological Emergency Plan and implementing i procedures and the Physical Security / Safeguards Contingency Plan and implementing procedures. Currently, the  ! requirements for these reviews and audits are incorporated into the sequoyah Radiological Emergency and Physical Security / Safeguards Contingency Plans. The proposed changes would delete the redundant references in the facility's Technical Specifications to the requirements which originate in Title 10 of the Code of Federal Regulations (10 CFR 50.54(t) for Emergency Preparedness and 10 CFR 50.54(p), 10 CFR 73.40, 10 CFR 73.55, and 10 CFR 73.56 for Security). 

                                                                                                                                                         .i l

Description of Specific chances The proposed amendment would eliminate the references to specific frequencies for each of the Technical Specification-required audits and eliminate reference to reviews and audits of the Radiological Emergency Plan and Physical Security / Contingency Plan. Instead, a statement would be added to the NQA Plan specifying that the audits listed in the Technical Specifications would be accomplished on a biennial (2 years) frequency as defined in the NQA Plan Section 12.2.E.2 and directed by administrative procedures and/or management. The requirements for reviews and annual 1 E4-2

. 1 1 I audits of the site Radiological Emergency Plan and Physical l Security / Contingency Plan (and their associated implementing procedures) are currently delineated within the NRC-approved Radiological Emergency Plan and Physical Security / j Contingency Plan for Sequoyah Nuclear Plant as provided for in the NRC's generic communication. Each of the proposed changes to the Technical Specifications is discussed by line item below: Seouovah Nuclear Plant Unit 1 and Unit 2 Technical Snecifications: ADMINISTRATIVE CONTROL Section 6.5.2.8 has been revised to  ! delete the references to specific audit frequencies. In accordance with the Standard Review Plan (SRP) Section 17.3 (" Quality Assurance Program Description") guidance on planned and periodic assessments scheduling and resource allocation, the following statement has been prepared for Section 12.2.E.2 (" Audits") of the NQA Plan (and is included in Enclosure 5): Auditing organizations shall ensure that audit procedures and instructions adequately cover applicable elements of the Nuclear Quality Assurance Program. l Audit subjects are specified in plant technical specifications and regulatory commitments. Audit frequencies shall normally be biennial with an allowance of a 25-percent (six-months) extension at management's discretion. The audit frequencies for programs involving each site's Radiological Emergency Plan and Physical Security / Contingency Plan are as required by the Code of Federal Regulations. Additionally, a proposal is being made in Enclosure 5 to , modify alternative number 6 of NRC Regulatory Guide 1.33 in t the NQA Plan. Specifically, audit frequencies will no longer be specified in plant specific technical ' specifications but specified as biennial (2 years) in Section 12.2.E.2 of the NQA Plan. This change neither alters the function nor diminishes the i quality of the Audit Program. The Nuclear Safety Review Board (NSRB) retains responsibility for oversight of the  ! Quality Assurance Audit Program. The sole change to the process is associated v; h the audit frequencies. Specifically, audit frequencies are being specified generically in the NQA Plan. The revision allows an extension for time intervals not specified in the Technical Specifications of up to 25 percent. Therefore, the maximum time between specific audits would be 30 months. The E4-3 l l l

extension would not be applicable to those audits with > frequencies mandated by the Code of Federal Regulations (e.g., Radiological Emergency Plan, and Physical Security / Safeguards Contingency Plan). The Technical Specification required audits and the impacts of the proposed changes are listed below:

  • The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions.

Applicable portions of the Technical Specifications and license conditions are evaluated during special assessments and selected audits. This change will not adversely impact compliance with those provisions of the Technical Specifications, the commitments in the NQA Plan to ANSI N18.7-1976, or the effectiveness of audits performed. Compliance with the Technical Specifications and license conditions is evaluated by multiple Technical Specification audits. The performance, training, and qualifications of the entire facility staff. Audits of the facility staff's qualifications (" Training Audits") are conducted annually. The proposed changes ' will allow management to schedule the time between specific audits to be a maximum of 30 months, if needed. This added versatility is not projected to adversely impact the effectiveness of either the Nuclear Training Program or the Audit Program, because management can increase or decrease the audit frequency based upon observed performance and importance to safety. The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety. l The results of actions taken to correct identified deficiencies are evaluated as part of each audit for the specific area being audited, and currently, an audit is performed every six months to evaluate the programmatic controls which govern the corrective action process as l well as the overall correction of deficiencies. The ' proposed Technical Specification changes would not negatively affect the review of corrective actions in j cach audit. Only the biannual audit controls will be l affected in that management will be given flexibility to adjust the audit's frequency based upon performance as evidenced through trends and other performance E4-4

M indicators. As such, the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR 50. This requirement is accomplished "at least once per 24 months." The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, as evaluated. This would allow the scheduling of audits to be performance based. The Site Radiological Emergency Plan and implementing procedures. The proposed changes would not impact those audits whose frequencies are mandated by Title 10 of the Code of Federal Regulations and the NRC-approved plans. The Plant Physical Security Plan, the Safeguards Contingency Plan and implementing procedures. The proposed changes would not impact those audits whose frequencies are mandated by Title 10 of the Code of Federal Regulations and the NRC-approved plans. Any other area of facility operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power. There is no impact upon this Technical Specification line item. The Fire Protection Program and implementing procedures. This audit is currently performed "at least once per 24 months." The proposed change does not alter this frequency except to provide the added versatility of a potential 25% (6 month) extension, as evaluated. This would allow the audit to be scheduled during the performance of activities which impact nuclear safety. Hance, the only impact of the proposed changes upon the biennial fire protection audit would be to make it more performance based. E4-5

  • I l

l

  • The independent fire protection and loss prevention inspection and audit utilizing either qualified offsite licensee personnel or an outside fire protection firm (annual audit) and an inspection and audit of the fire  !

protection and loss prevention program by an outside  ; qualified fire consultant (triennial audit). The proposed changes will combine the annual and triennial audits into one biennial audit which will be alternated with the Fire Protection Program Audit (see above item). Hence, each year'a fire protection audit will be performed, and a qualified outside consultant will be utilized in alternate years. This will not adversely impact the effectiveness of either the Fire Protection / Loss Prevention Program or the Audit Program, because the proposed alternate audit program continues to evaluate the areas addressed in NRC Generic Letter 82-21, utilizes the same recommended resources, and is comprehensive in its review of fire protection and loss prevention features. The radiological environmental monitoring program and the results thereof. This audit is currently performed once every 12 months. The proposed changes would allow the time between audits to be adjusted based upon the radiological environmental monitoring program's performance to a maximum of 30 months, as evaluated. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. This flexibility is consistent with guidance provided by the NRC relative to the implementation of the revised 10 CFR 20.1101(c) (i.e., refer to NRC response to NUMARC for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program). The Offsite Dose Calculation Manual (ODCM) and implementing procedures. This audit is currently performed once every 24 months. - The proposed changes would allow the time between audits ' to be adjusted based upon the performance of the program implementing the Offsite Dose Calculation Manual to a maximum of 30 months, as evaluated. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and , E4-6 l

l l l audits, and other trend indicators. Also, the added i versatility in the audit program will continue to be  ; consistent with guidance provided by the NRC relative to  ! the implementation of the revised 10 CFR 20.1101(c) l (i.e., refer to NRC response to NUMARC (NEI) for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program).

  • The Process Control Program (PCP) and implementing procedures for solidification of radioactive wastes.

This audit is currently performed once every 24 months. The proposed changes would allow the time between audits to be adjusted based upon the performance of the Process Control Program to a maximum of 30 months, as evaluated. The program's performance is and will continue to be assessed through self assessments, management reviews, QA assessments and audits, and other trend indicators. I Also, the added versatility in the audit program willcontinue to be consistent with guidance provided by the NRC relative to the implementation of the revised 10 CFR 20.1101(c) (i.e., refer to NRC response to NUMARC (NEI) for question 118 in third set of Questions and Answers which indicates that an integrated program of sampling, inspections, internal reviews, independent reviews, and QA audits could be used to assess the effectiveness of the radiological protection program). The performance of activities required by the Quality Assurance Program to meet criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev 1, 1974 and Regulatory Guide 4.1, Rev. 1, 1975. This audit is currently performed once every 12 months. The proposed change would allow the time between audits to be adjusted based upon the performance of the implementation of the Quality Assurance Program to a maximum of 30 months, as evaluated. The program's performance is, and will continue to be assessed through self-assessments and audits, and other trend indicators. I E4-7 , l I l l l

~ e' ' The. performance of activities required for environmental monitoring. This audit is currently performed once per 18 months. i The proposed changes will allow management to schedule i the time between specific audits to-be a maximum of 30 months, if necessary. This added flexibility will not adversely affect the performance of activities required l by the Quality Assurance Program for effluent and-  ! environmental monitoring or the audit program. . Under the i proposed changes, management will be permitted to l increase or decrease the audit frequency based upon - observed performance. i The purpose, scope, and thoroughness of QA audits will not be affected, management oversight of the audit process will  : not be diminished, and the audits will be performed at  ; frequencies commensurate with safety significance and not - less than biennially (plus 25%). As such, we believe these changes are correct and acceptable. , Specific line item changes involving the audit process l include: ADMINISTRATIVE CONTROLS 6.5.2.8.a, 6.5.2.8.b, 6.5.2.8.k, and 6.5.2.8.n have been revised to delete the phrase "at l least once per 12 months."  ! ADMINISTRATIVE CONTROL 6.5.2.8.c has been revised to  !' delete,the phrase "at least once per 6 months." ADMINISTRATIVE CONTROLS 6.5.2.8.d and 6.5.2.8.h,  ! 6.5.2.8.1, and 6.5.2.8.m have been revised to delete the phrase "at least once per 24 months." , ADMINISTRATIVE CONTROL 6.5.2.8.1 has been revised to [ delete the term " annually" and to require an inspection f and audit by an outside qualified fire consultant. l ADMINISTRATIVE CONTROL 6.5.2.8.j has been deleted since I the requirements are now contained in ADMINISTRATIVE CONTROL 6.5.2.8.i. ADMINISTRATIVE CONTROLS 6.5.2.8.e and 6.5.2.8.f have been i deleted. The requirements for these audits (Radiological [ Emergency Plan, Physical Security and Safeguards  : Contingency Plan) are specified within the Sequoyah l Radiological Emergency Plan and Sequoyah Physical ' Security / Safeguards Contingency Plan. i i E4-8 ) i f 2

Appendix B Environmental Technical Specification 5.2.2 I has been revised to delete the phrase "once per 18  ! months." An additional editorial line item change for the Unit 1 Technical Specifications on page 6-12 is as follows: AUTHORITY 6.5.2.9 has been revised to read " The NSRB shall report to and advise the Senior Vice President, Nuclear Power of those areas of responsibility specified in Sections 6.5.2.7 and 6.5.2.8." Environmental Impact Evaluation The proposed change request does not involve an unreviewed environmental question because operation of SQN units 1 and 2 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the staff's testimony to the Atomic Safety and Licensing Boards, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2. Result in a significant change in effluents or power levels.
3. Result in matters not previously reviewed in the licensing basis for SQN that may have a significant environmental impact.

Significant Hazards consideration The standards used to arrive at a determination that a Technical Specification change request involves no significant hazards consideration are included in the Commi"clon's regulations, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously , evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Each standard is addressed as follows: E4-9 H

a t

1. Operation of the facility in accordance with the proposed technical specifications would not involve a  ;

significant increase in the probability or  ; consequences of an accident'previously evaluated. l The likelihood that an accident will occur is neither

  • increased or decreased by this Technical Specification change which only affects review and i audit frequencies.. This Technical Specification j change will not impact the function or method of -

operation of plant equipment. Thus, there is not a  ! significant increase in the probability of a - previously analyzed accident due to;this change. No systems, equipment, or. components are affected by the proposed changes. Thus, the consequences of a 1 malfunction of equipment important to' safety previously evaluated in the FSAR are not' increased by l this change. , The proposed change only affects review and audit , frequencies. As such, the proposed change has no  ! impact on accident initiators or plant equipment, and l thus, does not affect the probabilities or  ; consequences of an accident. l Therefore, we conclude that this change does not l significantly increase the probabilities or i consequences of an accident. ,

2. Operation of the facility in accordance with the proposed technical specifications would not create the possibility of a new or different kind of .

accident from any accident previously evaluated. The proposed changes do not involve changes to the physical plant or operations. Since program audits do not contribute to accident initiation, a change related to audit functions cannot produce a new i accident scenario or produce a new type of equipment malfunction. Also, this change does not alter any existing accident scenarios. The proposed change does not affect equipment or its' operation, and, , thus, does not create the possibility of a new or i different kind of accident. Therefore, the proposed . change does not create the possibility of a new or l different kind of accident. l E4-10 I 

 .m.,--,--,

l i

3. Operation of the facility in accordance with the proposed technical specifications would not involve a significant reduction in a margin of safety.

The proposed change concerning conduct of reviews and audits does not directly affect plant equipment or operation. Safety limits and limiting safety system settings are not affected by this proposed change. Therefore, use of the proposed Technical Specification would not involve any reduction in the margin of safety. , l Based on the above, we have determined that the Technical Specification change request does not (1) involve a significant increase in the probability or consequences of' an accident previously evaluated,_(2) create the possibility , of a new or different kind of accident from any accident i previously evaluated, or (3) involve a significant reduction in a margin of safety. Therefore, this Technical Specification change request does not involve a'significant hazards' consideration. , 6 v l i I i E4-11 1 1

4

  • j

. l ENCLOSURE 5 PROPOSED NUCLEAR QUALITY ASSURANCE PLAN CHANGES AND JUSTIFICATION i 

 .                                     NUCLEAR QUALITY ASSURANCE PLAN        TVA-NQA-PLN89-A-REV. 4, 12/15/93 Proposed Change Page 65 of 109 12.2 -Program Elements A. An audit plan shall be prepared identifying the audits to be performed and their frequencies and schedule.

B. 2.UG',ts shall include: a determination of the effectiveness of QA program elements; evaluation of work areas, activities, processes, and items; review of documents and records; review of audit results with responsible management; and follow-up on corrective action taken for deviations identified during the audit. C. Audits shall be performed in accordance with written procedures or checklists by qualified, certified,.and appropriately trained personnel not having direct responsibilities in the areas being audited. D. Audited organizations shall provide access to facilities, documents, and personnel needed tc perform the audits. They shall take necessary action to correct deviations identified by the audit in a timely manner. E. Internal Audits

1. The scope of an audit shall be determined by considering such factors as work areas, activities, processes, or items and the specific organizations involved.
2. Auditing organizations shall' ensure that audit procedures and  ;

instructions adequately cover applicable elements of the NOAP. Audit subjects are specified in plant technical specifications and regulatory commitments. Audit frequencies shall normally y be biennially with an allcwance of a 25-percent (six-months) g, extension at management's discretion. The audit frequencies [y ; for programs involving each site Radiological Emergency Plan oj and Physical Security / Contingency Plan are as required by the NO Code of Federal Regulations. i i F. Contractor / Supplier Audits i

1. Audits of selected suppliers shall be conducted to verify l implementation and adequacy of specified QA requirements.
2. Contractors / suppliers to be audited shall be selected on the basis i of the importance of their products or services to safety, status l of contract activity, historical performance of the supplier, and potential QA problems that may be discoveredduring source surveillance inspection activities or earlier audits.
3. Audit schedules shall be prepared and audits shall be conducted in accordance with the schedules.
4. Audit reports shall be prepared and reviewed by the audit team, l approved by management, and. transmitted to the supplier and appropriate management within TVA.

I 

 'e NUCLEAR QUALITY ASSURANCE PLAN TVA-NOA-PLN89-A REV. 4,  12/15/93 Proposed Change Page 88 of 109 L

APPENDIX B Page 11 of 20 Table 2 REGULATORY GUIDE CONFORMANCE STATUS

b. For f acilities holding a construction permit where system (s) and/or components have been released to the operations organization, temporary changes to procedures, as described above, shall as astaff, at minimum be approved by two members of the plant management least one of whom shall be a designated member of the plant operations management staff.
3. Section 5.2.13.1 - The statement that changes made to procurement documents be subject to the same degree of control as was used in the preparation of the original documents is applied consistent Minor changeswith the to documents, requirements of ANSI N45.2.11, paragraph 7.2.

such as inconsequential editorial corrections or changes to commercial terms and conditions, may not require that the revised document receive the same review and approval as the original documents. Section 5.2.15 - The guidelines of this section are accepted with the 4. following alternatives:

a. Minor changes to documents are processed as delineated in Section 6.1.2.F3 of this plan, b, TVA has programmatic controls in place that make a biennial review process unnecessarily duplicative. These programmatic curtrols ensure procedures are periodically reviewed and maintained current wi.*n
  • pertinent source material is revised; the plant design changes; and/or any deficiencies occur. TVA has determined that this approach ^better addresses the purpose of the biennial revi.w process and that, from a  !

technical and practical standpoint, is better suited to ensure the validity of operational phase site procedures and instructions.

5. Section 5.2.17 - The statement that deviations, their cause, and any corrective action completed or planned shall be documented will apply to significant deviations. Other identified deviations will be documented and corrected. This interpretation is consistent with Appendix B to 10 CFR 50, Criterion XVI, " Corrective Action."

t i that audit frequencies j

6. TVA will comply with regulatory position C.4 except lggy, 1 are as specified in HQA Plan Section 12.2.E.2.

0$ mo EEC_ Regulatory Guide 1.37_ " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants," 3/73, endorses ANSI N45.2.1-1973. 3542R 1 I 1

2 Page1ofI TENNESSEE VALLEY AUTHORITY NUCLEAR QUALITY ASSURANCE PLAN (TVA-NQA-PLN89-A), REVISION 4 DESCRIPTION OF CHANGES' AND THEIR JUSTIFICATION SECTION NO. IN REV. 4 PROPOSED CHANGSS JUSTIFICATION (12/15/93) TO REVISION 4 . Section revised to specify - TVA Nuclear's plant technical specifications - 12.2.E.2 (page 65) that audit subjects are are being revised to remove audit frequencies. described in plant These frequencies are being moved to the technical specifications NQA Plan and are being changed to biennially and regulatory for most audits. The proposed change to audit commitments. In frequencies will provide added flexibility in addition, this section was scheduling audits and allow management to revised to show the audit redirect resources from programs with frequency for internal identified strengths to areas with perceived audits. weaknesses. Specificjustifications are also provided in the technical specification change - justification portion of this package. Revised to reference new Reference above justification. Appendix B, Table 2, Section NRC Reg. Guide location of audit 1.33, item 6 frequencies. (page 88).

l
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t I t E ENCLOSURE 6 , PROPOSED TECHNICAL ' SPECIFICATION CHANGES (REVISED PAGES) _l BROWNS FERRY NUCLEAR PLANT LIST OF AFFECTED PAGES UNIT 1-i 6.0-14

  • 6.0-15 UNIT 2 ,

1 6.0-14  ! 6.0-15 UNIT 3 6.0-14 6.0-15 b

i AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB. These audits shall encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions.
b. The performance, training and qualifications of the entire plant staff. d
c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety.
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50.
e. (Deleted) d
f. (Deleted) -]
g. Any other area of site operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power.
h. The fire protection programmatic controls including the implementing procedures.

J l l I l 1 BFN 6.0-14 l Unit 1 j I l 

 .          .~.   . - . .                            .     --.          -          . - . . .. - .  - -

J 1

1. An indepenaent fire protection and loss prevention program ]

inspection and audit shall be performed utilizing an outside - fire protection-firm. 

                                                                                                ~

J. (Deleted)  ! l

k. The Radiological Environmental Monitoring program and the- i results thereof. -
1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide  !

4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 1975. -

m. (Deleted) -{

t

n. The Offsite Dose Calculation Manual and implementing l procedures.

JI  ; i l

o. The Process Control Program and implementing procedures for
                                                                                                       .l solidification of wet radioactive wastes.                        -

l

p. (Deleted)

B BFN 6.0-15 Unit 1

e AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the NSRB. These audits snall encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions.
b. The performance, training and qualifications of the entire plant staff.
c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety. q
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50. d
e. (Deleted)
f. (Deleted) d
g. Any other area of site operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power.
h. The fire protection programmatic controls including the implementing procedures.

BFN 6.0-14 Unit 2

o

1. An independent fire protection and loss prevention program inspectionandauditshallbeperformedutilizinganoutsided fire protection firm.

J. (Deleted)

k. The Radiological Environmental Monitoring program and the results thereof.
1. The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 1975. -
m. (Deleted) l
n. The Offsite Dose Calculation Manual and implementing procedures.
o. The Process Control Program and implementing pracedures for solidification of wet radioactive vastes. -
p. (Deleted)

I l i I l 1 BFN 6.0-15 Unit 2 l

o. AUDITS 6.5.2.8 Audits of unit activities shall be performed under the cognizance of the N5aB. These audits sha11' encompass:

a. The conformance of plant operation to provisions contained within the Technical Specifications and applicable license conditions.
                                                                                     ]
b. The performance, training and qualifications of the entire plant staff. -
c. The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety. -]
d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50. -
e. (Deleted) _
f. (Deleted) ]
g. Any other area of site operation considered appropriate by the NSEB or the Senior Vice President, Nuclear Power.
h. The fire protection programmatic controls including the implementing procedures. -

BFN 6.0-14 Unit 3

1. An independent fire protection and loss prevention program inspectionandauditshallbeperformedutilizinganoutsided fire protection firm.

J. (Deleted)

k. The Radiological Environmental Monitoring program and the results thereof. -j
1. The performance of activities required by the Quality  ;

Assurance Program to meet the criteria of Regulatory Guide 4.15, December 1977, or Regulatory Guide 1.21, Rev.1,1974, and Regulatory Guide 4.1, 1975. -

m. (Deleted) -
n. The Offsite Dose Calculation Manual and implementing procedures.
o. The Process Control Program and implementing procedures for solidification of wet radioactive wastes. -
p. (Deleted) I i

i l BFN 6.0-15 I Unit 3}}

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