ML20082E111
| ML20082E111 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 07/26/1991 |
| From: | Woodard J ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9107310213 | |
| Download: ML20082E111 (11) | |
Text
_ _ _ _
AWma Poe Comruny 40 inewss Ceter Pn au Pos' 0" ce Bau 129f; B me ny am A:atia1a 35201 lOfchar,e.05 6C,8 fJ !;n m
J. D. Woodard
/ aballla power Vee Pts er1-No.e f ppy p, c 3
(4
\\ !"
C, t
July 26, 1991 Docket Nos. 50-348 10 CFR 50.54 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Biennial Reviews of Nuclear Plant Procedures Gentlemen:
Alabama Power Company hereby requests a change to the Quality Assurance and Security Programs as described in the Joseph M. Farley Units 1 and 2 Final Safety Analysis Report (FSAR), Sections 3A-1.33,13.5.1,13.5.S and 17.2.1.
Currently, the FSAR requires that safety-related and security procedures be reviewed on an interval not to exceed 24 months. The Security Plan also contains provisions for a periodic review of security procedures, although on a more frequent basis.
This procedure review process is controlled by internal plant procedures and was developed during original plant licensing to address the procedure review philosophy of ANSI N18.7-1972.
Based on the justification in Attachment 1, Alabama Power Company proposes to 3
delete the present FSAR requirement for biennial reviews of all safety related and security procedures.
ExLting plant programs independent of the biennial review program provide for adequate review and revision, if necessary, of plant procedures to ensure they remain technically correct and adequate.
Also, Alabama Power Company proposes to include a statement in the FSAR for the Safety Audit and Engineering Review staff to perform a biennial quality assurance audit of the plant procedural development and maintenance programs utilizing a representative sample of procedures.
Even though this would be a new FSAR provision, Alabama Power Company already performs the scope of this audit as part of the current quality assurance program. Attachment 2 provides the proposed FSAP, wording revisions.
Pursuant to the requirements of 10 CFR 50.54 (a) and (p), Alabama Power Company has concluded that there will be no reduction in commitments in the Quality Assurance Program and no decrease in the effectiveness in the Security Program as a result of this change.
However, as a conservative measure, Alabama Powcr Company is requesting NRC approval before imclementing this change.
Following NRC approval, Alabama Power Company will update its 91073102h w 910726,
gr PDR Apo n
ooon PDR Y
O
'l
U.S. Nuclear Regulatory Commission Page 2 i
internal procedures, the FSAR and the Security rian and transmit those changes to the NRC on schedules consistent with the regulations. The Plant Operations Review Committee has reviewed and approved this proposed change and the Nuclear Operations Review Board will review this proposed change at a future meeting. Alabama Power Company requests that this proposed change be approved by the NRC by October 1991.
Respectfuliy submitted, 1
i ALABAMA POWER COMPANY kh
. Woodard JDW/CRP:crp Attachments cc: Mr. S. D. Ebneter Mr. S. T. Hoffman Mr. G. F. Maxwell Mr. F. Jape l
0242 l
l
..=.
9 Justification for Deletion of Biennial Review of Procedures Introduction Currently, FSAR Sections 13.5.1 and 13.5.8 require that safety-related and security procedures be reviewed on an intervai not to exceed 24 months. This review process was developed during original plant licensing to address the procedure review philosophy of ANSI N18.7-1972.
Alabama Power Company his approximately 2,880 safety-related procedures which fall under the two yeat
'/ ew requirements.
Also, about 60 security i
procedures fall under '+ to year review requirements in the FSAR and the one l
year review requirem-. cs the Security Plan. A conservative estimate for the annua: rc.iew time these procedures is 10,000 manhours.
This includes the time required for a person to review and revise a procedure and prepare a.
10 CFR 50.59 evaluation, a qualified peer review, a supervisor review, a cross disciplinary review, a manager review / approval, Plant Operations Review Committee review, and Nuclear Operations Review Board review of any 10 CFR 50.59 evaluations for FSAR changes.
This also includes man-hours for word processing, copying, distribution, and record retention.
In addition, the documents supporting the review of each procedure are considered life-of-plant documents so that additional space must be allocated each year for storage.
Discussion ANSI N18.7-1972 provides for a static biennial review process but recognizes that the procedure review process may change as a plant reaches operational maturity.
Alabama Power Company believes that an ongoing dynamic process is inherently required in maintaining procedures in an accurate and useful condition. This proces: requires that Farley Nuclear Plant have in place orocedural controls which provide for procedure changes as plard design, regulatory, or operational requirements change.
In addition, most of _these procedures are used frequently by plant personnel.
As plant personnel use these procedures, problems are identified and resolved through various internal programs, some of which are discussed below.
Further, a significant portion of the emergency operating procedures are frequently used through various simulator training programs. Once identified, procedural issues are addressed in an expeditious manner.
Alabama Power Company continually evaluates its pr ocedure maintenance processes and has implemented controls to ensure that potential procedural impact is assessed and revisions are made based on input from a number of different programs. The following programs adequately provide input to procedure revisions and changes:
Page 2 (1)
Plant Personnel Feedback Plant personnel are trained and directed to report to management any procedural deficiencies or concerns which may prevent or impact procedure implementation.
Ar.y procedure discrepancies identified through the performance of the procedures are evaluated for the necessity of changes.
These changes may be required prior to continuation of the performance of the tests, or after completion of the tests, depending on the nature of the discrepancies.
(2)
Incident Investigation Feedback Significant unplanned plant events (e.g. operational occurrences, major equipment failures, significant maintenance rework, security incidents, radiation incidents, etc.) are investigated through the incident reporting and evaluation system.
Each incident is investigated to determine cause.
Procedural corra:tions and enhancements may result from the incident investigation.
(3) Design Modification Program The plant design modification program requires a review of all modifications by the potentially affected groups. This review requires that all procedures potentially affected by the modification be identified and changes and revisions be ready to be implemented upon completion of the modification. All group managers must indicate that revisions to plant procedures have been issued before the modification package can be considered complete.
(4) Operating Experience Evaluation Program The operating experience evaluation program requires the review of NRC bulletins, notices, and generic letters; Westinghouse Owner's Group information; INP0 significant operating event reports (SOERs),
significant event reports (SERs), and operation and maintenance reminders (0&MRs); Nuclear Network operating plant experience reports; controlled vendor technical information; unsolicited vendor technical information; vendor manuals and revisions to vendor manuals; and various internally generated reports such as incident reports. The review of this operating experience, in many cases, includes an evaluation of applicable procedures and the initiation of any required procedure changes, tl (5) Simulator Training Program As potential deficiencies and ennancements are identified in the emergency operating procedures during simulator and classroom training, formal processes are in place to identify and resolve them.
This includes procedure revisions, if appropriate.
Page 3 (6) Technical Specifications and FSAR Revisions Revisions to Technical Specifications and the FSAR require evaluation for impact on procedures and result in the initiation of procedure changes, if appropriate.
(7) Quality Assurance Program The Quality Assurance Program includes a review of procedures as part of the audit and surveillance process (which is based on a two year cycle).
The Quality Assurance Program assigns the responsibility to the Safety Audit and Engineering Review (SAER) group to audit the procedural process on a periodic basis. The Plant Operations Review Committee (PORC) also performs overviews that include a review of procedures.
Input into the procedure revision process may be provided by either group.
Conclusion As evidenced by the number of programmatic controls discussed above for procedure input and revision, Alabama Power Company considers the biennial review process to be unnecessary. The impact on plant resources of the biennial review reduces the site personnel's ability to concentrate on issues of greater significance to plant safety. Therefore, Alabama Power Company proposes to change the FSAR to delete the requirement for a biennial procedure review.
in addition, Alabama Power Company proposes to add a provision in the FSAR for biennial quality assurance audits of the plant procedural development and maintenance program utilizing a representative sample of procederes.
Audits consistent with the scope of this proposed FSAR statement are currently being conducted at the plant.
l l
e 5
k i'
4
- t.
Proposed FSAR Markups I'
f 1
F h.
i I
g.-
4
i FNP-FSAR-3A RequIntory Guide 1.33 -
QUALITY ASSURANCE PROGRAM REQUIREMENTS (OPERATION)
(SAFETY GUIDE 33, 11/3/72)
CONFOkPMOE This topic is addressed in section 17.2.
During original plant licensing, a 24 month review process for all safety related and security procedures was developed to meet the intent of Safety Guide 33 and ANSI N18.7-1972. Since the procedural process has now matured and adequate programs to assure procedural revisions consistent with plant design, operational, and regulatory requirements are in place, this original commitment has been modified to require biennial Quality Assurance audits of the procedural development and maintenance program utilizing a representative sampling process. Therefore, the 24 month review process discussed above is no l onger required.
3A-1.33-1
FNP-FSAR-13 after being reviewed and approved as specified in section 13.4.
It is the responsibility of the general manager-nuclear p; ant to ensure that required reviews are completed before procedures are issued.
Permanent changes to procedures follow the same review and approval route as a new procedure.
A permanent change is implemented only after formal approval.
C:f:ty ::1 t:d psecedure: ' fill he ::vi:11:d annually during et:rtup :nd :::1y ete; : :f pl:nt :p:::ti.- f:r :d:qu::; :nd :ppli :bility
(;_L; ti ca 13. 4. 2 ).
Aft:r th:
- 13 ph
- ::: cf plant p;r;ti:n, p;ri;di: ::vi:::: ch:11 h: ::nducted et interval n:t
- ::::::d O '. ;; nth.
-Temporary procedures and temporary revisions to procedures are issued to direct operations during testing and maintenance, to provide guidance in unusual situations, and to ensure orderly and uniform operations for short time periods when existing i
procedures do not apply.
These administrative procedures delineate the general responsibilities and authorities of the plant staff.
Instructions have been established to provide methods by which temporary changes to approved procedures can be made, including the dcsignation of persons authorized to approve such temporary changes.
In cases of emergency, personnel will be authorized to depart from approved procedures when necessary to prevent injury to personnel or damage to the facility in accordance with the provisions of 10 CFR 50.54 (x) and (y).
In all such ceses, changes will be documented and reviewed by the appropriate superintendent within 30 days.
If appropriate, it will then be in:orporated in the next revision of the affected procedure.
Mere detail on the review, approval, changes, revisions, and implementing of procedures is found in subsection 13.4.2.
Procedures are provided for control of equipment to maintain reactor and personnel safety and to avoid unauthorized operation of equipment.
These procedures delineate control measures and actions such as locking, tagging, notification, removal of tags, and identification of equipment.
Standard operating procedures are documented and disseminated to the plant staff.
They include such subjects as job turnover and relief, designation of confines of control room, definition of duties of operators and others, transmittal of operating data to management, filing and changing charts, maintaining operating log, and personal belongings carried onsite.
Also there is a mechanism for issuing special orders which have See short term applicability and which require dissemination.
Insert 1 l
A list of typical administrative procedures is found in l
table 13.5-1.
13.5-4
insert 1 Insert on Farley FSAR Page 13.5-4 A number of programs cre in place to ensure that plant procedures are adequate and applicable, and-to ensure that potential procedural impact is assessed and necessary revisions are made.
The following programs, which include, but are not limited to those listed below, adequately provide for procedure review and any necessary input to procedure revisions and changes:
Plant Personnel feedback Incident Investigation feedback-Design Modification Program Operating Experience Evaluation Program l
Simulator Training Program Technical Specifications and FSAR Revisions Quality Assurance Program Additionally, as a part of the overall quality assurance program, the SAER group performs various audits (described in Chapter 17.2) to assure that the procedural process _-is working and that procedures are being properly i
maintained.
'l l
l
FNP-FSAR-13 supervisor.
Procedures are subject to pee +3dte reviews by the security supervisor et tire intervele not te c.x:ced 2 y:cre or whenever a security threat or other security d.ncident makes such a review desirable.
Revisions to procedures are subject to the same review and approval as original procedures.
Revised or obsolete security procedures are destroyed and a l
certificate of destruction completed for the destroyed document.
Certificates of destruction are placed in security l
files.
Temporary security procedures and temporary revisions to procedures to cover unanticipated or emergency situations may be issued at the direction of the general manager-nuclear plant.
Temporary procedures shall reflect the purpose and limitations of their use.
Unless declared obsolete and l
destroyed, temporary procedures shall be prepared as permanent procedures as soon as practicable.
A list of typical security procedures is found in l
table 13.5-10.
1 I
13.5.9 SPECIAL NUCLEAR MATERIAL ACCOUNTABILITY PROCEDURES Special nuclear material procedures have been written to implement the special nuclear material accountability program.
These procedures delineate personnel responsibilities and autho~ri tie s, designate and describe item control areas, anc provide instructions for special nuclear material control records and reports, receiving and shipping of special nuclear j
material, internal transfers, physical inventories, special nuclear material element and isotopic calculations, and special i
nuclear material review and audit.
l A list of typical special nuclear material procedures is found in table 13.5-11.
1 l
13.5.10 ENGINEERING TECHNICAL PROCEDURES l
Engineering technical procedures provide instructions for the I
performance of tests or essential calculations which, because l
of their nature or technical content, are normally performed by plant engineers.
These procedures cover such subjects as reactor core physics tests, calculation of operating curves and data, component or systems perfori.ance evalua+. ions, developmental testing, and other related functions.
A list of l
typical engineering technical procedures and plant modifications procedures is found in table 13.5-12.
l 13.5-12 l
l
?
l 3
I 4
}
FNP-FSAR-17 will develop SAER procedures to be approved by the MSAER and utilized in the_ performance of his activities.. The'SSAER will l
serve as nonvoting member of the Plant Operations Review C6mmittee-(PORC),. which reviews and determines dispositions of Nonconformance. Reports, as discussed in subsection 17.2.15.
l The SSAER-has the responsibility and authority to identify problems, recommend solutions, and verify corrective actions.
The-SSAER will also provide input for an onsite operations QA indoctrination program as described in subsection 17.2.2.
Copies of all of his audits and verifications will be sent to the MSAER for distribution.
/ The SAER staff willkselectively audit those quality-related activities that are'within the scope of the OQAP, as described I
in section 17.2, to verify compliance with the requirements of the procedures listed in the OQAPIL..These consist of activities performed offsite in support of the FNP and those i
performed ensite, including the activities of the SSAER.
A representative list of activities to be audited and their frequencies is provided in table 17.2-2.
The results of all such audits will be reported to the organization audited and the vice president-nuclear.
17.2.1.3 Refueling Ooerations l
SAER'will devote particular attention to certain significant activities, such as refueling operations.
The l
MSAER will review and approve administrative procedures, which will provide guidance during all safety-related activities, including refueling, for the inclusion of policies and requirements of the OQAPM.
SAER will perform audits of i
selected refueling functions to-verify compliance with written procedures.
SAER will audit the refueling activities with particular attention being paid to certain aspects of the activity, such.as verification that inspection requirements are l
identified, scheduled, assigned, performed, documented, and-evaluated; corrective action is completed when nonconformances, deficiencies, malfunctions, or failures occur; required prerequisites for refueling are met; and refueling activities are carried out in.accordance with. approved written procedures.
SAER-will audit work procedures which affect refueling operations to verify that they incorporate the quality i
l requirements presented in the applicable procedures listed on
.the OQAPIL.
To assure that controls are in place to effectively maintain plant procedures, the SAEA staff will perform a biennial audit of the procedural develornent and maintenance program utilizing a representative sampling process.
17.2-7