ML20080U069
| ML20080U069 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah  |
| Issue date: | 03/07/1995 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20080U059 | List: |
| References | |
| NUDOCS 9503140215 | |
| Download: ML20080U069 (45) | |
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ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGE 8 (MARKED PAGES)-
BROWNS PERRY NUCLEAR PLANT LIST OF AFFECTED PAGES UNIT 1 6.0-14 6.0-15 UNIT 2 6.0-14 6.0-15 UNIT 3 6.0-14 6.0-15 I
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9503140215 950307 PDR ADOCK 05000259 P
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e JUN 301988 1
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AUDITS y
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,st leae;. voce pu 12 i; nth:.
b.
The performance, training and qualifications'of the entire plant staff. n 1;;;; enc; per 12 s.enth;.
c.
The results of actions taken to correct deficiencies i
occurring in site equipment, structures, systems or method
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of operation that affect nuclear safety.:: ic-et anc= per 5
- 10.;.
4
- y d.
The performance of activities required by the Operational
(
Quality Assurance Program' to meet the criteria of Appendix
~~B, 10 CFR Part 50x.et icen ;;;; pcr 2t ;;;the.
- e. ' Oc :'ite "-diningia=1 Frergency Plen
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Any other area of site operation considered appropriate by
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the NSRB or the Senior Vice Dresident, Nuclear Power.
h.
The fire protection programmatic controls including the implementing procedures at least once per 24 months.
BFN 6.0-14 Unit 1 AMENDMENT N0.14 9
a
- h. -
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SEP 2 21993 1
o
'i..-An independent fire protection and loss prevention program _
inspection and audit'shall be performed annually-utilizing-either qualified offsite license personnel or an outside-fire protection firm.-
- j. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at' intervals no greater than 3 years.
j k.
The Radiological Environmental Monitoring program and the results thereof, et 1---t
- per 12 eoth..
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,:t 1:::: :::: ;vu, 12 g
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ef setivitic; requir;; ty thi ; icsuaras-C "-
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The Offsite Dose Calculation Manual and implementing procedures,st--1::;t :ne; ;:: 12 ::n *.
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The Process Control Program and implementing procedures-for solidification of vet radioactive vastes, t 1:::t :nce per
-24 svuihs.
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(Deleted) l i
BFN 6.0-15 AMENDMENT NO.19 9 Unit 1
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APR 0 i 1993 6.5.2.8 Audits of. unit activities shall be performed under the cognizance of the RSRB.- These audits shall: encompass:-
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The conformance of plant operation to provisions. contained within the Technical Specifications and applicable. license -
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- conditions.:t 1:::t ::: ;:: 12 :::the.
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b.
The performance, training and qualifications. of the entire; plant staff, t leert :::: p:: 12 monthes e
- c. 'The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or. method of operation that affect nuclear safety, t 1 :: esce yi- 0 months.
i 6
d.
The performance of activities required by the Operational Quality Assurance Program to meet the-criteria of Appendix B, 10 CFR Part 50x. + les-t ::: ;:: 2e rar**=-
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e.
Th:-Sit: Esdi:1;gie:1 ?--
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s ([de,leted) p, nr.. duce-e t 1...r. once ev.419 = anew l
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The 71.a;. Neical ::::rity ?!== and 4=rirrtin y/ooeduees-uvery 12..14. (,10e\\4tect) et 1 :: vuce i
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Any other area of site operation considered appropriate by j
the RSRB or the Senior Vice President, Nuclear Power.
h.
The fire protection programmatic controls including the implementing procedures at least once per 24 months.
AMENDMEN NO. 2 0 7 BFN 6.0-14 Unit 2,
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SEP-2 21993 1.
An independent-fire protection and loss prevention progra.m inspection and audit shall be performed annually utilizing either qualified offsite license personnel or an'outside fire protection firm.
J.
An inspection and audit of the fire protection and loss prevention. program shall be performed by.an outside qualified fire consultant at intervals no greater than'3 years.-
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The Radiological Environmental Monitoring program and the results thereof,at 1;eei. voea pe; 1; se;.'tr.
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.et leae;. vuu.
g o v i, 12-rer*h=_.
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n ; ;;;fersen;; ;f :.;tiviti;; r;;;ir;d D S S;f; ;;sde Centins;; '; Pirr t: ;;;;. ;.h. waiteria of 10 Ci. 70.40'd) ei.
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The Offsite Dose Calculation Mar.ual and implementing procedures,at leret :::: ;; 10 ::1^.
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The Process Control Program and implementing procedures for.
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solidification of wet radioactive wastes,;t 1;;;; ;;;; ;;r-2^. ::;th;.
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(Deleted)
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BFN 6.0-15 AMENDMENT NO. 216 Unit 2 l
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s 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,at leset cree pe"
=^"*ha 4
b.
The performance, training and qualifications of the entire plant staff,s* 'e==* ana-rer l' re"**=
c.
The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method or operation that affect nuclear safety. t 1:::t once re 5 ser*k.
d.
The performance of activities required by the Operational
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Quality Assurance Program to meet the criteria of Appendix
.B,_10 CFR Part 50. :t-- 1:::: ':::: per 24 :: nth:,
x e.
The Cit: " di:1 gic 1 Frer;:::y ?12: ::d ispler:: ting 12- :::th:. (Klele ted2)
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The i1::: Phyeical see--**y Plin :: i ;1::::tir2 rrreedurca
- e rj 12 ;;:the (Delet.eck) s*
1a==e naa-g.
Any other area of site operation considered appropriate by the RSRB or the Senior Vice President, Nuclear Power.
h.
The fire protection programmatic controls including the implementing procedures at least once per 24 months.
BFN 6.0-14 Unit 3 AMENDMENT N0.12 0
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SEP 2 21993
- i. An independent fire protection and loss prevention program.
inspection and audit shall be performed annually utilizing.
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either qualified offsite license personnel or an outside fire prott: tion firm.
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-J. An inspection and audit of the fire protection and loss prevention program shall be performed by an outside-qualified fire consultant at intervals no greater than 3 years.
k.
The Radiological Environmental Monitoring program and the
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results thereof.:t 1---'
- ;;; 12 a;;;h;.
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The performance of activities required by the Quality Assuranet 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.;; 1;;.L vuur eveu 12 x
monthh i
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The Offsite Dose Calculation Manual and implementing I
procedures,et 2 ::: ;;;; ;;r 12 ::: he.
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The Process Control Program and implementing procedures for solidification of vet radioactive vastes. : 1:::: :::: ;;r-U.~ol.
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(Deleted) 1 BFN 6.0-15 AMENDMENT NO.172 Unit 3 1
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ENCLOSURE 2 DISCUSSION AND SIGNIFICANT NAIARDS CONSIDERATION EVALUATION BROWNS FERRY NUCLENt PLANT I
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J Discussion of changes g).
Introduction Currently,Jthe Administrative' Controls.section of the' Standard Technical Specifications!for: General. Electric-
-Plants.(NUREG-1433, Vol. 1) states thatLthe.combinationfofe l
sreviews and audits should be. integrated "intoEa cohesive.
1 program that provides senior management'with:an assessmentf
'of' facility, operation and. recommends actions to improveL l
nuclear. safety and plant reliability."
Therefore,ntheseL d
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administrative. tools'should be sufficiently. flexible to:
allow for senior management direction of resources _to focus l
upon areas requiring increased attention.- The proposed; j
changes to the Technical Specification-administrative
-controls would provide such flexibility through the l
elimination of certain rigid audit frequencies.
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Additionally, references to reviews and audits of the
'l facility's Radiological Emergency Plan, and Physical l
Security / Safeguard contingency Plan'(and of their associated
-t implementing procedures) would be removed from the Technical j
specifications.because those requirements presently exist.
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within'the individual' Plans.
This action reflects the guidance provided in an NRC Generic Letter"93-07, dated j
December 28, 1993, and is similar to the Virginia Power i
submittal of July 20, 1993 j
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Background
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.1 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 j
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, industry' l
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guidelines and standards (ConformanceLto Technical
'l Specifications and Operating License, Effectiveness of i
Corrective Actions, and Training audits).
The audits 1
-specified by these sources are meant to address programs l
which are deemed to be essential to the effective management j
of each nuclear facility.
However, the rigid schedules dictated by the Technical Specifications do not allow management the flexibility to recognize good performance by 1
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-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 and maintaining the frequency of those audits presently.
scheduled biennially.
The exceptions to this frequency extension ~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) and audits' associated with fire protection as defined by the present technical specifications.
't 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 r
Specifications to the requirements which originate in Title 10 of the Code of Federal Regulations 1[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 SER2ific changes a
The proposed amendment would eliminate the references to.
specific frequencies for each of the Technical Specification required audits, except the fire protection related audits, l
and would eliminate reference to reviews and audits of the Radiological Emergency Plan, and Physical l
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.
The requirements for reviews and annual audits of the i
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ai facility Radiological' Emergency., Plan and Physical-Security / Contingency Plan (and their associated. implementing
. procedures)'are currently. delineated.within the'NRC-approved Radiological / Emergency Plan and Physical. security /
s Contingency Plan:for Browns Ferry. Nuclear Plant as'provided.
'foroin the NRC'sLgeneric communication.- Each of.the
.proposedLchanges to!the. Technical;Specificationa is-
. discussed by-line: item below:
- Browns Ferry ~ Unit"1. Unit 2.
and Unit 3' Technical' specifications:
ADMINISTRATIVE CONTROL Section 6.5.2.8 has been revised'to delete.the. references.to. specific _ audit frequencies.
Irr ek accordance with the Standard Review Plan (SRP) Section 17.3
(" Quality Assurance Program Description") guidance on1 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
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Enclosure:
5:
Auditing organizations shall ensure that audit.
procedures and instructions adequately cover applicable elements of the NQAP.
Audit subjects are specified in-plant technical specifications and regulatory commitments. ; Audit frequencies shall be biennially'
.with.the exception of fire. protection related audits which shall be in accordance with the plant technical specifications. The audit frequencies'for programs involving each site 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 GuideL1.33 in the NQA Plan.
Specifically, audit frequencies, with the exception of fire protection audits, will.no longer be specified in plant specific technical specifications but instead will be specified'as biennial (2 year) in Section 12.2.E.2 of toe.NQA Plan.
This change neither alters the function nor diminishes the 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.
Specifically, audit frequencies are being specified generically in the NQA Plan.
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- The TechnicalcSpecification-required audits and the impacts.
of'the proposed changes are listed below:
- l The-conformance of' plant operation to provisions o
containedtwithin the Technical-Specifications and applicable 111 cense conditions.
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, Applicable 1 portions of the. Technical-Specifications and..
j mJ license conditions.are assessed'during eachLaudit for the.
- particularLarea(s) being. audited. " Reducing.the frequency-
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of these audits to bienniali(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.-
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. compliance with the Technical Specifications andflicense j
conditions is~ evaluated more often than-each 12 months although not in a single Technical; Specification audit.
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The-performance,. training, and qualifications.of the-1 entire plant staff.
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Audits of the plant staff's qualifications,(" Training N
l' Audits")lare conducted annually.-
The proposed changes-1 will. allow. management to schedule the time between
.l' specific audits to be a maximum of 24 months, as s
evaluated.
This added versatility is:not projected to j
adversely. impact the effectiveness of.either the Nuclear-Training. Program or the Audit Program, because management
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can increase or decrease the audit frequency based upon observed performance and importance to safety.
j o The results of actions taken to correct deficiencies i
occurring in site equipment, structures, systemsEor-
'l method of operation that affect nuclear safety.
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.i The results of actions taken to correct. identified-d deficiencies are evaluated as part of each audit for the'
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specific area being audited, and currently, an audit is 1
performed every six months to evaluate the programmatic
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controls which govern the corrective' action process.
The proposed Technical Specification' changes would not negatively affect the review of corrective actions in
'l ear
- audit.
Only the biannual audit of programmatic 1
controls will.be affected in that management will be a
given flexibility to adjust the audit's frequency based i
upon performance as evidenced through trends and other i
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L performance indicators.' 'As such,'the proposed changes will not diminish the effectiveness of either the Corrective Action Program or the oversight of that program.
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.The performance of activities required by the Operational f
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Quality Assurance Program to meet the criteria of
_ Appendix B, 10 CFR 50.
This proposed change would not impact the performance.of audits on these activities since these audits are currently being performed "at least once per 24 months."
The proposed change does not alter this frequency.
The Site Radiological Emergency Plan and implementing o
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procedures.
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The proposed change would not impact those audits whose' L
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.
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The Plant Physical Security Plan and implementing l
o 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 l
o by the NSRB or the Senior Vice President, Nuclear Power.
l There is no impact upon this Technical Specification line item.
The radiological environmental monitoring program and the o
results thereof.
I This audit is currently performed once every 12 months.
l 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 24 l
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.,
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refer to NRC response to,NUMARC (NEI) for question 118 in
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third set of Questions and' Answers which indicates that n
.aut integrated program.of. sampling, inspections, internal i,
reviews, independent reviews, and QA audits could be used l
-to assess the effectiveness of the radiological 4
protection program).
l The performance of activities required by the Quality-i o
Assurance Program to meet criteria:of.
i 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 adjunted based upon the performance of the implementation of the Quality Assurance Program to a maximum of 24 months, as, evaluated.
The program's l
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performance will continue to be assessed through self-assessments and audits, and other trend indicators.
The performance of activities required by the Safeguards o
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 o
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 24 months, as evaluated.
The program's l
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) 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).
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-The Proces[s Control' Program.'(PCP) and implementing O
0' proceduresLfor: solidification of-wet radioactive wastes.
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I This-proposed: change wouldLnot11mpactithe performance'of:
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audits.on these activities since these:auditstare l
currently;being: performed "at;1 east.once=per-24Laonths'.",
g The proposed change.does not alter thisl frequency.
TheEprogram's performance is and will continueSto-be:
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assessed through?self assessments, management' reviews! QA' s
assessments and audits,~and other. trend indicators.
1 Also,~the added versatility in:thefaudit program:will1 1
continue to be consistent-with guidance providediby; thel f
NRC relative to ' the: implementation :of the revised 10: CFR 20.1101(c) '(i.e., refer ~ to' NRC - response to < NUMARC L (NEI) -
y for question:118 in. third set of QuestionsLand. Answers which indicates that'an integrated program of sampling, inspections, internal reviews, independent reviews,cand QA_ audits could be used~to assess the effectiveness of
.the radiological protection program).
l The purpose, scope, and thoroughness'of QA audits will not-l be affected, management oversight /of the auditLprocess will' l
not-be diminished, and the audits _will be: performed at i
frequencies commensurate withzsafety significance andinot'
'j less than biennially.
As such, these changes are consistent with the intent of the regulations _and are an acceptable j
alternative.
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- 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 j
and 6.5.2.8.n have been revised to delete the phrase."at j
least once per 12 months."
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ADMINISTRATIVE CONTROL 6.5.2.8.1 has'been revised'to
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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 and 6.5.2.8.o have been l
revised to delete the phrase "at least once per'24 months."
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. ADMINISTRATIVE: CONTROLS 6.5.2.8.e,:6.5.2.8.f,-and j
. 6.5.2.8.m have been~ deleted. JThe. requirements for these i
audits (Radiological Emergency. Plan,. Physical Security 1 i
Plan, and Safeguards Contingency: Plan)'areispecified.
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' within ; the L Browns. Ferry: Nuclear Plant ~ Radiological J l
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Emergency Plan, and the Browns Ferry Nuclear Plant i
- Physical-Security / Contingency-Plan.
airnificant Razards consideration j
i TVA'has concluded that operation of BFN unitsgl, 2, and.1 in
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accordance with the proposed change to the. technical specifications does not. involve a significant-hazards consideration.- TVA's conclusion is based ~on'its. evaluation j
'in accordance with 10 CFR150.91(a) (1), of the.three -
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standards set-forth-in'10 CFR 50.92(c).
TVA's conclusion is'
-j basedion the following:
V The. proposed amendment doesfnot' involve a significant i
1.
increase in the probability or consequences of"an accident'previously evaluated.-
The likelihood that an accident-will occur is neither
' increased or decreased by this. Technical Specification change which only:affects review and audit frequencies.
.This-Technical Specification 1
change will not impact the function or method of operation of plant equipment.. Thus, there.is not a
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significant increase in the probability of a previously analyzed accident due.to this-change.. No systems, equipment, or components are affected by the proposed. change.
Thus, the consequences of a malfunction of equipment important to safety previously evaluated in the UFSAR are not increased i
by this change.
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The proposed change only affects review and audit frequencies.
As such, the proposed change has no impact on accident initiators or plant equipment, and i
thus, does not affect.the probabilities or consequences of an accident.
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Therefore,.we conclude that-this change does not significantly increase the probabilities or-consequences of an accident.
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.The proposediamondment does not creat's the possibility _of.a new or different kind of accident-
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from any accident;previously_ evaluated.
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The proposed changes do notl involve changes to the
'l 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 l
malfunction.
Also, this change does not alter any existing accidentLscenarios...The proposed change j
'does not affect equipment or its operation, and,
- thus, does not create the possibility offa new or different kind of accident.
Therefore, the proposed
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change does not create the possibility of a new or i
different kind of accident.
3.
The proposed amendment does 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.
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. 2 2 (c) (9).
Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.
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i ENCLOSURE 3
.j PROPOSED TECHNICAL SPECIFICATION CHANGES i
SEQUOYAH NUCLEAR PLANT
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LIST OF AFFECTED PAGES UNIT 1 6-11 6.12 APPENDIX B 5-2 UNIT 2 6-11 APPENDIX B 5-2 j
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Signifisant! operatingiabnormalities:or ~ deviations 1 from normal' and -
4 i
4 expected performance of;unitJequipment that affect nuclear safety.
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-All? REPORTABLE EVENTS.
R62}
[,
~
h.
' Allfrecognized indicationsof an unanticipated deficiency Lincsome:.
c;
. aspect of design orLoperation'of: structures,1 systems,- or components 1
that could' affect nuclear safety.
ci r
~
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~ Reports and meetings minutes of the PORC.
LR182h N
- - AUDITS
[
j 6.5.2.8 ' Audits' of unit activities shall' be p'erformed under 'the~ cognizance of1 d
- the NSRB. These. audits shall' encompass:
j i
a.
The'conformance of unit operation to provisions contained ~within the j
Technical Specifications and. applicable license conditions,at least 4
cr e per 12 ;;;th;.
i The performance, training and qualifications of the entire' facility lR78' l
b.
staff,:t b ut ente per 12 ; nth:.
y The results of actions taken to correct' deficiencies occurring in c.
unit. equipment, structures, systems or method of operation that j
affect nuclear safety,:t 1 ::t :n : p:r S :::th:.
d.
The performance of activities required by the Nuclear' Quality Assurance Program to meet the criteria of Appendix "B", 10 CFR 50. 'R182 l at 1;; t ence per 24 u,enths.
y c
il e.
The Site h dfele p 1 rmor g p u r :nd i ; n d,intin; pr:::dar:: :t leest unuo 12 uivuuiu OS2efdI poi
~.
f.
Th: Plent Phy:ie:1 Security Pl:n, th;' 0;i=3u.rus cunungency nan 1
- nd %;h :ntin;'pr:: dcr:: et least ence pe, u. ioon 6ns. (,tod r6ek l
L j
g.
Any other area of unit operation considered appropriate by tn3 NSRB or the Senior Vice President, Nuclear Power.
R78
- l h.
The Facility Fire Protection Program and implementing procedures at' i
least once per 24 months.
j 1.
An independent fire protection and loss. prevention program inspection d
and audit shall be performed annually utilizing either qualified 1
offsite licensee personnel or an outside fire protection firm.
i j.
An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
4 March 31, 1994 iSEQUOYAH - UNIT 1 6-11 Amendment No. 68,174, 178'
]
~~ y c--7=--~---------
-- - = =
a f
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34g M
1 g"
' I is ADMINISTRATIVE CONTROLS >
a kh The radiologihal environmental monitoring program and the-results?
thereof.;t h;.;tl:::: ;:r 12 :: th:.
1 i. o.
'.1 ;
TheOFFSITE.DOSECALCULATION.MANUALandimplementingprocidures.4 i
f ~' 4 h;;t ym.e ym R a,e.,tt.3.
.l
.m.-
The PROCESS CONTROL, PROGRAM.and implementing procedures 1for:'.
/ SOLIDIFICATION of-radioactive wastes.
I
. he performance of activities required;by the Quality-Assurance I
.n.
T Program to meet the' criteria of Regulatory Guide 4.15L December 1977 J
'. ' or Regulatory Guide.l.21,i Rev.z l,1974 and Regulatory Guide 4.1,:
R46 g
5 Rev. 1, 1975 :t h ::t ;.;; p r 12 :: th:
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? AUTHORITY
'6.5.2.9. The' NSRB shall report to and-advise the: Senior Vice President, Nuclearl
. Power those areas. of responsibility 'specified 'in Sections 6.5.2.7 and. 6.5.2.8..
~
y R78:
- ' RECORDS 6'.5.2.10 -Records of'NSRB activities shall be. prepared, approved and distributed as indicated below:
i 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 bi Section 6.5.2.7 above, shall be prepared, approved and forwarded to the' Senior Vice' President, R73 Nuclear Power within 14 days following completion:of the review.
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 > g7, completion of the audit..
~
6.5.3 THIS SPECIFICATION IS' DELETED R182-c March 31, 1994 SEQUOYAH - UNIT 1-6-12 Amendment No. 42, 58, 74, 178 152
=
g-43
- E.
All nonroutine reports prior to submittal of the written report-
-(described in Subsections 5.4.2.a, b, and'c).
f F.
. Investigations of all reported instances of noncompliance with Environmental Technical Specifications, assbciated corrective actions, and measures taken to prevent recurrence.
p
- 5. 2. 2 Audit-l.
The licensee shall conduct an audit cnce pe" 1" =^"th; of the environmental i
monitoring ~ program.
The audits shall-be conducted independently of'the -
l R111 individual,or' groups responsible for performing the specific activity.
Results of the audit activities shall-be maintained and made available for t:
' nspection.
i 5.3 Changes in Station Design or Operation 1
i Changes in station design or operation may be made subject to the following conditions:
A.
The licensee may (1) make changes in'the r,tation design and operation, and (2) conduct tests and experiments net described in'this document without prior Commission approval,-unless the proposed change, test 'or experiment involves a change in the rejectives 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 l
g;
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( g INISTRATIVE 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 conditionsat 1::rt -
ence per 10 months.
. i b.
' The performance, training and qualifications of the entire facility R66 staff.:t le::t :nce per 12 montht.
The results of actions taken to correct' deficiencies occurring in
~
c.
unit equipment, structures, systems or method of operation that affect nuclear safety, at leset en:: per 5 m: nth:-.
d.
The performance of activities required by the Nuclear Quality Assur-l ance Program to meet the criteria of Appendix "B",10 CFR 50.-et-.
- R169 g
le::t :nce per 21 :: th;.
e.
The Sit: Radiciogical Emcr-- cy "lan and 4mplementing pre:dr:2 at-le::t One p;r 12 m nthr. [5elefe4')
f.
The Tiani. pivawai Scudrity D12n, th: Rfcgsards Ocntinger-" "lan.
W implementing pi vuedu.es at 1 ::t once per 22 month:. (Ee(Eted).
g.
Any other area of unit operation considered appropriate by the NSRB or the Senior Vice President, Nuclear Power.
R66 h.
The Facility Fire Protection Program and implementing procedures at least once per 24 months.
1.
An independent fire protection and loss prevention program inspection and audit shall be performed annually. utilizing either qualified offsite licensee personnel or an outside fire protection firm.
j.
An inspection'and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater ~than'3 years.
k.
The radiological environmental monitoring program and the results
~
ther~ eof.at least once per 12 months.
t 1.
The OFFSITE DOSE CALCULATION MANUAL and implementing procedures.-et-h::t r,c: per N E n Ga.
m.
The PROCESS CONTROL PROGRAM and implementing procedures for SOLIDIFICATION of radioactive wastes.ct 100 t once per 24 m:nths n.
The performance of activities required by the Quality Assurance Pro-gram to meet the criteria of Regulatory Guide 4.15, December 1977 or Regulatory Guide 1.21, Rev.1,1974 and Regulatory Guide 4.1, Rev.1, R34 1975, t le::t Ortec pcr 12 mcath:.
g March 31, 1994 SEQUOYAH - UNIT 2 6-11 Amendment No. M, M, 66.169 -
T
E~
.1 Y.
^
f E.
A11Lnonroutine 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,
-j
'and measures ~taken to prevent recurrence.
i t
- 5. 2. 2 Audit-j i
I The licensee.shall, conduct'an audit...
n.
_....... of the environmental l
monitoring prograrh. The: audits shall be conducted independently of the 1
I individual or groups responsible for performing the specific activity.
R97' Results of the audit activities shall be maintained and made available for i
inspection.
'5.3 Changes in Station Design or Operation.
i a
Changes-in station design or operation may be made subject to the following conditions i
f A.
The licensee may (1) make changes in the station design and operation ~,
and (2) conduct tests and experiments not descri. bed 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 l
unreviewed env,ironmental question of significant impact.
i 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 4
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EMCLOSURE 4 l
DISCUSSION AND SIGNIFICANT HAEARDS l
CONSIDERATION EVALUATION I
SEQUOYAH NUCLEAR PLANT l
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Discussion of changes s
Introduction kk
~
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- Currently,7the' Administrative Controls sestionlof.the' q
Standard Technical Specifications fortWesti_, house' plants-H (NUREG-1431, Vol.il) states that the< combination of reviews
~I andiaudits should beLintegrated "into;a; cohesive program that provides senior management,with anLassessment of:
facility operation and recommends' actions to-improve nuclear y
safety:and plant 1 reliability." =Therefore, these administrative tools should be sufficiently flexible tx>
s fallow for senior management direction of resources to focus upon: areas requiring increased attention. ; The: proposed changes to the Technica1' Specification administrative controls would provide such, flexibility:through the e
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 tho' guidance provided in.an NRC generic' communication,l Generic Letter 93-07 published December.28, ~1993 and is similar to 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, Radiological Emergency Plan, Standard Technical Specifications, NRC Generic Letters,. industry l
guidelines and standards (Conformance to Technical Specifications and Operating License,nEffectiveness of i
Corrective Actions, and Training audits).
The audits:
j specified by these sources are meant tx) ~ address programs
.l I
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 management the_ flexibility to recognize good performance by E4-1 I
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L
'certain organizations,-and resources'which could be devoted
- to areas.with perceived weaknesses are diluted by1the requirement to audit strong programs.at the frequencies set i
<forth in the Technical Specifications.- The proposed 1 changes
-would allow:for decreasing the frequencies of certain audits and maintaining.the. frequency of those: audits presently-s scheduled biennially.. The' exceptions?to:this frequency 1
extension 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) and audits-associated with~ fire protection as defined by the present.
technical specifications.
~
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 / Safeguards Contingency Plan and implementing-procedures.
Currently, the-requirements ~for these reviews and audits are, incorporated q
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 110 of the Code of Federal Regulations [10 CFR 50.54(t) for-Emergency Preparedness and 10 CFR 50.54(p), 10 l
CFR 73.40, 10 CFR 73.55, and 10 CFR 73.56 for Security].
Description Of Specific changes The proposed amendment would eliminate the references to
~
specific frequencies for each of the: Technical Specification required audits and eliminate reference to reviews and j
l audits of the Radiological Emergency. Plan and Physical-l Security / Contingency Plan.
Instead, a statement would be I
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 l
Section 12.2.E.2.
The requirements for reviews and annual l
l L-l E4-2
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1
\\
audits ofithe' site Ra'diologicalLEmergency P1hn'and' Physical
]
Security / Contingency Plan.(and their. associated implementing.
-procedures) are currently delineated within the NRC-approved.
j
^
' Radiological' Emergency Plan.and Physical Security /.
1 1
1-contingency' Plan for Sequoyah Nuclear Plant as provided.for cin.the NRC's; generic communication.- Each of1the proposed i
changes,toLthe. Technical Specifications is. discussed by line j
item below:'
Sequovah Nuclear' Plant Unit 1 and Unit-2'Tachnical.
Specifications:-
ADMINISTRATIVE CONTROL Section 6.5.2.8 has been revised.to ij 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.
i allocation, the following statement has been prepared for 1
Section 12.2.E.2 (" Audits") of the NQA Plan (and isLincluded 11 in Enclosure 5):
l i
Auditing organizations shall. ensure that audit 1
procedures and instructions adequately cover applicable j
elements of the Nuclear Quality Assurance Program.
l Audit subjects are,specified in plant technical l
specifications _and regulatory commitments.- Audit j
frequencies shall be biennially, with'the. exception of j
fire protection related audits which shall be in l
accordance with the plant technical. specifications.
1 The audit frequencies for programs involving each-i site's Radiological Emergency Plan and Physical l
Security / Contingency Plan are as required by the code l
of Federal' Regulations.
}
Additionally, a proposal is being made in Enclosure 5 to 1
modify alternative number 6 of NRC Regulatory. Guide 1.33 in the NQA Plan.
Specifically, audit frequencies, not associated with fire protection, will-no longer be specified i
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
~j quality of the Audit Program.
The Nuclear Safety Review.
1 Board (NSRB) retains responsibility for oversight of the Quality Assurance Audit Program.
The sole change to the i
process is associated with the audit frequencies.
i specifically, audit frequencies are being specified generically in the NQA Plan.
l
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The TechnicalcSpecification required; audits.and the impacts
~ f the proposed changes'are listed below:
o The conformance_of unit operation to' provisions contained:
within-the Technical Specifications:and applicable.
. license conditions.-
Applicable l portions of the Technica Specifications'and l
~
license conditions are evaluated during special.
assessments and selected audits..This change will not f
adversely impact. compliance with those provisions of the Technical' Specifications, the commitments in tha'NQA Plan to ANSI'N18.7-1976, or the effectiveness.of audits performed.
Compliance'with theLTechnical Specifications _
and license conditions is evaluated:by multiple Technical Specification audits.
The performance, training, and qualifications of the o
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
,l l
l specific audits to be a maximum of 24 months, as.
l-L evaluated.
This added versatility is;not projected to adversely impact the effectiveness of either the' Nuclear Training Program or.the' Audit Program,.because' management H
can increase or decrease the audit frequency based upon observed performance and importance to safety.
o 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 1
deficiencies are evaluated as part of each audit for the i
specific area being audited, and currently,.an audit is performed every six months to evaluate the programmatic l
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 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
)
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. performance' indicators.
As.such;Jthe proposed changes; will1not'diminishithereffectiveness ofreither.the Corrective.ActionLProgram or the' oversight.of'that-i F:
(program..
~
j 1
The1 performance of activities required.'by the Operational-o Quality Assurance Program to meet:the criteria'of-p'
-Appendix B,'10 CFR 50.
w This proposed' change would not-impact the performanceLof
' audits on.thesefactivities.since the. audits are currently-
.being performed "at.least once per 24. months."
The 3;
. proposed " change does not alter. this frequency.
The Site Radiological Emergency Plan.and implementing
~
d
'o l.
procedures.
]
a The proposed changes would,not impact.those audits whose
' frequencies are mandated by Title 10 of the Code of l
Federal Regulations and the NRC-approved plans.
l The Plant Physical Security. Plan,lthe Safeguards o
contingency: Plan and implementing procedures.
The proposed changes would-not impact those audits whose j
frequencies'are mandated by Title 10 of the code of Federal Regulations and the NRC-approved plans.
Any other area of facility operation. considered o
appropriate by the NSRB or the Senior Vice President, Nuclear Power.
I There is no impact upon this Technical Specification'line item.
l The radiological environmental monitoring program and the l
o results thereof.
This audit is currently performed.once every 12 months.
The proposed changes would allow the~ time between audits j
to be adjusted based upon the radiological environmental i
monitoring program's performance'to a maximum of 24 l
months, as evaluated.
The. program's-performance is'and will continue to be assessed through self assessments, 1
management reviews, QA assessments and audits, and other i
trend indicators.
This flexibility is consistent with guidance provided by.the NRC relative to the j
implementation of the revised 10'CFR 20.1101(c)
(i.e.,
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4 Lrefer to NRC response-to NUMARCLfor question 118 1n third?
set ~of Questions and AnswersLwhich indicates that ani integrated program of:. sampling,' inspections,. internal L.
reviews,Eindependent: reviews,.and QA audits could be used' to assers.the effectiveness of the radiological
'l protection program).-
1 I
o' The Offsite Dose Calculation Manual.(ODCM) and implementing procedures.
]
This proposed change would not impact 1the performance of:
audits on these activities since the audits.are_ currently'-
i being performed "at least once per 24 months."- The j
' proposed change does not alter this frequency.
i
[
The program's performance is1and will continue to be' l
~
assessed through self assessments, management reviews,.QA-a F
assessments and audits, and other trend indicators.
j Also, the added versatility.in the audit program;will.
continue to be consistent with guidance provided byJthe.
NRC relative to the implementation of theLrevised'10'CFR~
j 20.1101(c), (i.e., refer to NRC response to NUMARC'(NEI)'
a forEquestion-118Lin 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).-
a i
The Process Control Program-(PCP).and implementing o
procedures for solidification of radioactive wastes.
1 This proposed change would not impact the performance of audits.on these activities since these audits are~
~
currently being performed "at least once-per 24 months."
The proposed change does not alter this frequency.
j The program's performance is and will continue to be assessed through self assessments,;managementLreviews,: QA
-l 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
~d 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, j
inspections, internal reviews,. independent reviews,.and' QA audits could be used to. assess the' effectiveness of l
the radiological protection' program).
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- Assurance Program to meet" criteria:of Regulatory Guide-4
?4.15,? December.1977.or Regulatory (Guide 1.21,_Rev:1,11974 T
and' Regulatory Guidej4.1, Rev. 1,11975.
!This audit is currentlyLperformedionce'every[12 inonthsL LThe proposed change,would allow the~ time,between' audits-
+
~
to-be adjusted based.upon the performanceiof the-y' '
implementation of the Quality Assurance Program to-~a-p maximumlof-24 months,'.as evaluated.'. The program's
-l~
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-performance'ils,_ and will continue-to be assessed lthrough self-assessments and_ audits,:and other-trend indicators.
E o The performancefof activities required'for environmental H
monitoring.
1 This audit is1 currently: performed once per 18Laonths.
H
.The proposed _ changes will allow managementito schedule, theLtime between specific audits to-be:a maximum of.24J
'l_
months,.as, evaluated.
This added flexibility will not adversely. affect lthe performance of activities required-by the Quality _. Assurance Program for effluent and; ~
' environmental monitoring or:the audit program.' Under the proposed changes, management will be permitted:to; increase or decrease the audit frequency _ based ~upon:
' observed performance.
The purpose, scope, and thoroughness.of QA audits'will not be1affected, management oversight of the audit process'will b
not be diminished, and-the audits will be' performed at:
frequencies commensurate with safety significance and not less than biennially.
As such, we believe these? changes are l
correct and acceptable.
Specific-line item changes involving.the audit process include:
ADMINISTRATIVE CONTROLS 6.5.2.8.a,i6.5.2.8.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.c has been' revised'to delete the phrase "at least once per 6 months."
q
. ADMINISTRATIVE CONTROLS 6.5.2.8.d, 6.5.2.8.1, and l
6.5.2.8.m have been revised to delete the phrase "at least once per 24 months."
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/m ADMINISTRATIVE, CONTROLS.6.5.2.8.e1and~6.5.2.8.f have beeni i
deletedL The; requirements for'these audits (Radiological Emergency Plan,! Physical Security: ands afeguards' s
Contingency Plan)?are:specified within the Sequoyah Radiological' Emergency Plan and;Sequoyah Physical Security / Safeguards Contingency' Plan..
Appendix'B Environmental Technical Specification 5.2.2-y has:been. revised to' delete;the; phrase'"once per'18
. months."
j
^
An additional editorial line. item change for the Unit 1 1 Technical Specifications onLpage 6-12'is as follows:
l N-AUTHORITY.6.5.2;9'has'been revised to read " The NSRBs shall reportito and advise'the Senior.Vice' President, l
Nuclear Power of-those areas of responsibility specified e
in Sections 6.5.2.7 and 6.5.2.8."
Environmental Imnact' 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:.
3 I
l1.
Result in a significant~ increase in any adverse environmental impact previously evaluated inLthe-Final' Environmental Statement (FES).as modified by 1
the staff's testimony to the Atomic Safety.and i
Licensing Boards, supplements.to the FES, environmental. impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2.
Result in a significant change 11n effluents or power levels.
i 1
3.
Result in matters not previously reviewed in the licensing basis lfor SQN that may have a significant environmental impact.
')
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significant Ensards Consideration The standards:used'to' arrive at a determination that a' Technical; Specification change request involves no 1
significant hazards consideration are included in.the j
Commission's regulations, 10 CFR 50.92,1which_ states that no j
significant hazards considerations are= involved if tho' _.
. operation:of the facility in accordance with'the proposed.
amendment.would not:
(1)' involve.a significant' increase.in:
J the: probability or consequences of anJ accident previously 1
evaluated;'or-(2) create the possibility-.of a new or.
i different kind of'accidentifrom any accident ~ previously-I
- evaluated;_or (3)~ involve a'significant reduction in.a l
margin oftsafety..Each standard is addressed as follows:
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.
The likelihood that an accident will1 occur is neither i
increased or decreased by.this Technicalf 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 increasesin the probability _ofLa previously analyzed accident due to this change.
No systems, equipment, or components are affected by the j,
proposed changes._ Thus,.the consequences.of a' j
malfunction of equipment important to safety previously' evaluated in the FSAR are not increased by 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
~thus, does not affect the probabilities'or t
consequences of an accident.
t
. i Therefore, we conclude that this change does not significantly increase the probabilities or consequences of an accident.
h l
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-2.
Operation of the facility in accordance with the proposed technical specifications would'not create j
the possibility of a new or different kind of accident from any accident previously evaluated..
l l
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 i
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.
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.
i 9
Based on the above, we have determined that the Technical i
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 I
in a margin of safety.
Therefore, this Technical l
Specification change request does not involve a significant hazards consideration.
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ENCLOSURE 5 i
i PROPOSED NUCLEAR QUALITY ASSURANCE PLAN CHANGES AND JUSTIFICATION I
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' NUCLEAR-QUALITY ASSURANCE PLAN"
- TVA-NQA-PLN89-A'-
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g REV. ;4 /12/15/93 I
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LProposed Change d
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An; audit plan shallt be prepared. Identifying the audits ' to; be '
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3 B;. Audits shalliancludes?'a determination of the effectiveness of QA.
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program elements;' evaluation of. work areas, activities, processes, and items;' review of documents'and'recordss review of' audit results.
- f with responsible managements and follow-up on corrective action.
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taken for deviations identified during.the audit.
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.C. cAudits shall be performed in accordance.wlth written'procedureslor
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checklists-by-qualified, certified, and appropriately trained
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Audited organisations.shall provide access to facilities,.docoasnte,
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-and personnel needed to: perform the audits. -They shall-take j
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necessary action to' correct deviations identified by the: audit-in e
'i timely manner..
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Internal Audits m
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' factors'as work areas, activitiesJ~ processes, or items and the' j
specific organisations' involved..
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Auditing organisations shall ensure that: audit procedures and l
Instructions adequatelyLcover applicable elements'of the NQAP.
l Audit subjects are specified in plant technical specifications.
j and regulatory commitments. Audit frequencies shall be biennially with the exception of fire protection related
-l audits which shall be in accordance with the plant technical ~
j
- specifications. The audit frequencies for programs involving each site Radiological Emergency' Plan and Physical.
-l Security / Contingency Plan are as required by the Code of
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- Federal Regulations.
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Contractor / Supplier Audits i
1.
Audits of selected suppliers shall be conducted to verify 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 discovered.during source-surveillance inspection activities or earlier audits.
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3.-
Audit schedules shall be prepared and audits shall be conducted in i
accordance with the schedules.
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Audit reports shall be prepared and reviewed by the audit team, 4.
y approved by management, and transmitted to the supplier and appropriate management within TVA.
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s.c TVA..NOA-PLN89-A NUCLEAR' QUALITY ASSURANCE PLAN.
REV. 4,:12/15/93
~ Proposed Change Page 88 of 109 I
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 a-minimum be, approved by two members of the. plant management staff,;at-least one of whom shall be a-designated member of. the plant operations management staff.
'i 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 with the requirements of ANSI N45.2.11, paragraph 7.2.
Minor changes to documents, l
such as inconsequential ' editorial corrections or changes' to commercial
'I terms and conditions, may not require that the revised document receive the same review and approval'as the origine". documents.
l' 4.
Section 5.2.15 - The guidelines of this section.are accepted with the l
following alternatives:
Minor changes to documents are processed as delineated in Section-
' l a.
6.1.2.F3 of this plan.
I b.
TVA has programmatic controls in place that make a biennial review process unnecessarily duplicative. ' These programmatic controls ensure procedures are periodically reviewed and maintained current when pertinent source material is revised; the plant design changes; and/or
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any deficiencies occur. TVA has determined that this approaclY better addresses the purpose of-the' blennial review process and that, from a technical and practical standpoint,'is better suited to ensure the l
validity of operational phase site procedures and instructions.
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Section 5.2.17 - The statement that deviations, their cause, and any corrective action completed or plann.ed shall be: documented will apply to significant deviations.
Other identified deviations will be documented
.i and corrected.
This interpretation is consistent with Appendix B to 10 l
CFR 50, Criterion XVI, " Corrective Action."
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i TVA vill comply with regulatory position C.4 except that audit frequencies
- 6.
are as specified in N0A Plan Section-12.2.E.2.
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" Quality Assurance Requirements for Cleaning of
_l NRC Reculatorv Guide 1.37 Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants,"
l 3/73, endorses ANSI F45.2.1-1973.
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C" Page1ofI TENNESSEE VALLEY AUTIIORITY NUCLEAR QUALITY ASSURANCE PLAN (TVA-NQA-PLN89-A), REVI'SION 4 DESCRIPTION OF CHANGES AND THEIR JUSTIFICATION SECTION NO. IN REV. 4 PROPOSED CHANUSS JUSTIFICATION (12/15/93)
TO REVISION 4 -
12.2.E.2 (page 65)
Section revised to specify TVA Nuclear's plant technical specifications 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 regulato'ry 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 atidit 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.
Appendix B, Table 2, Revised to reference new Reference abovejustification.
Section NRC Reg. Guide location of audit 1.33, item 6 frequencies.
(page 88).
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ENCLOSURE 6 PROPOSED TECHNICAL l
SPECIFICATION CHANGES (REVISED PAGES)
BROWNS FERRY NUCLEAR PLANT j
LIST-OF AFFECTED PAGES i
i UNIT 1 6.0,
6.0-15
.l UNIT 2 I
6.0-14 6.0-15 i
UNIT 3 6.0-14 6.0-15 k
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AUDITS 4
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.
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conditione.
d b.
The performance, training ~and qualifications of the entire plant staff.
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c.
The results of actions taken to correct deficiencies occurring in site equipment, structures, systems or method of operation that affect nuclear safety.
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d.
The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50.
-j e.
(Deleted)-
")
f.
(Deleted)
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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 at least once per 24 months.
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BFN 6.0-14 Unit 1 I
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l'..An independent fire protection and loss prevention program j
inspection and audit shall be performed: annually utilizing-l
'either qualified offsite license personnel or an outside l
fire protection firm.
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I. An inspection and audit of the fire protection and loss
. prevention program shall be performed.by an outside qualified fire consultant et intervals no greater than 3 years.
l k.
The Radiological Environmental Monitoring program and the l
results thereof.
d l
1.
The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide I
4.15, December 1977, or Regulatory Guide 1.21, Rev. 1, 1974, and Regulatory Guide 4.1, 1975.
d m.
(Deleted) n.
The Offsite Dose Calculation Manual and implementing-procedures.
o.
The Process Control Program and implementing procedures for j
solidification of wet radioactive vastes.
d p.
(Deleted)
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BFN 6.0-15 Unit 1 l
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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.
_d 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 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)
.j.
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 at least once por 24 months.
l BFN 6.0-14 Unit 2
pg * -
- i. An independent' fire protection and loss prevention program inspection and audit shall be performed annually utilizing.
- j either qualified offsite license personnel or an outside-fire protection firm.
J.
An inspection and audit of:the fire protection and loss
.j prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.
k.
The Radiological Environmental Monitoring program and the results thereof.
'd.
1.
The performance of activities required by the Quality
'.ssurance Program to meet the criteria of Regulatory Guide:
4.15, December 1977, or Regulatory Guide 1.21,_Rev. 1, 1974, l
and Regulatory Guide 4.1, 1975.
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'(Deleted)
-l n.
The Offsite Dose Calculation Manual and impler.entAng I
procedures.
i o.
The Process Control Program and implementing procedures for l
solidification of wet radioactive wastes, d
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p.
(Deleted) i i
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t BFN 6.0-15
-Unit 2
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AUDITS.
1 l
6.5.2.8 Audits of unit activities.shal1~be performed under the j
cognir.ance of'the NSRB. These. audits shall encompass-i
.a.
The conformance of plant operation to provisions contained y
within'the Technical Specifications and applicable license-conditions.
N i
b.
The performance; training and qualifications of the_entirei i
plant staff.
f D
c.
The results of actions taken to correct deficiencies occurring'in site equipment, structures, systems or method i
of operation that. affect nuclear ' safety.
]:
d.
The performance of activities required-by the Operational; Quality Assurance Program to meet the criteria of Appendix.
-l B, 10 CFR Part 50.
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3 I
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(Deleted)
I v.
s 1
-f.
(Deleted) g.
Any other area of site operation considered appropriate by, the NSRB or'the Senior Vice President, Nuclear Power.
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!t h.
The fire protection prograsmatic controls including the implementing procedures at.least once per 24 months.
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i BFN 6.0-14 Unit 3 j
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.i.- An independent fire protection and loss prevention program-inspection and~ audit shall be performed annually utilizing
- p. >
either qualified offsite license personnel or.an outside
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fire protection'fira..
l J.
An inspection'and audit of.th'e fire protection and loss
([ '
prevention program shall be. performed by an outside i
qualified fire consultant at intervals no greater than 3 years.
l k.
The Radiological Environmental Monitoring program and the-i p
results thereof.
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1.
The performance of activities required by the Quality-j i
Assurance Program to meet the criteria of Regulatory Guide i
l 4.15, December 1977, or Regulatory Guide 1.21,- Rev.1,1974, and Regulatory Guide 4.1, 1975.
.]-
m.-
(Deleted).
O n.
The Offsite Dose Calculation Manual and implementing procedures.
L o.
The Process Control Program and implementing procedures,for solidification of wet radioactive wastes.
d p.
(Deleted)
I l
BFN 6.0-15 Unit 3 1
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