ML20087H906
| ML20087H906 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/01/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20087H900 | List: |
| References | |
| NUDOCS 9505050109 | |
| Download: ML20087H906 (3) | |
Text
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' fl UNITED STATES j
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20556-4001
,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS.190 AND 171 TO FACILITY OPERATING LICENSE NOS. NPF-4 AND NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY OLD DOMINION ELECTRIC COOPERATIVE NORTH ANNA POWER STATION. UNITS NO. 1 AND NO. 2 DOCKET NOS. 50-338 AND 50-339
1.0 INTRODUCTION
By letter dated July 8,1993, as supplemented by letters dated July 12, 1994, and March 7, 1995, the Virginia Electric and Power Company (the licensee) requested a change to the Technical Specifications (TS) for the North Anna Power Station, Units No. I and No. 2 (NA-l&2). The proposed change would delete the requirement to periodically review cert &in administrative and technical procedures.
The letters dated July 12, 1994, and March 7, 1995, provided additional information and did not affect the staff's initial proposed determination of no significant hazards consideration as noticed in the Federal Reaister on August 4, 1993 (58 FR 41518).
An evaluation of the proposed change is provided below.
2.0 DISCUSSION Currently, TS 6.8.2 in the Administrative Controls section of the NA-l&2 TS requires that procedures "be reviewed periodically as set forth in administrative procedures." This requirement specifically excludes implementation procedures associated with the Emergency Plan, Security Plan, and Fire Protection Program which are required to be reviewed annually by the Code of Federal Regulations.
The proposed change deletes the TS requirement for routine periodic reviews of administrative and technical procedures, as justified by the controls established and effectively implemented for procedure upgrades and revisions.
Elimination of the TS 6.8.2 requirement for periodic reviews of procedures will only affect routine administrative and technical procedures; and necessary revisions and upgrades of those procedures will continue to be detailed and thorough.
Procedures which will not be affected include those used to control abnormal, offnormal, or alarm conditions and those used for 9505050109 950501 PDR ADOCK 05000338 P
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combating emergencies and other significant events which are governed by regulations, NRC-approved programs, and/or prior licensee commitments.
The proposed amendment would eliminate the NA-1&2 requirement to periodically -
review most administrative and technical procedures. Specifically, the NA-l&2 TS are revised as follows:
o NA-1 TS 6.8.2 is revised to delete the phrase "and reviewed l
periodically" in the first sentence.
o NA-2 TS 6.8.2 is revised to delete the phrase "and reviewed periodically" in the first sentence.
3.0 EVALUATION Regarding the proposed change dated July 8, 1993, a meeting was held on June 19, 1994 with the licenne where the staff outlined a means of implementing the requirement of the periodic review of procedures. This approach would include:
- 1) programmatic controls should ensure that applicable plant procedures are reviewed following an accident, unexpected transient, significant operator error, or equipment malfunction, 2) provisions for reviewing emergency operating procedures, off-normal procedures, procedures that implement the emergency plan every 2 years, 3) at least every 2 years the quality assurance organization should audit a representative l
sample of routine plant procedures, and 4) routine plant procedures that have not been used for 2 years should be reviewed prior to use.
The licensee provided additional information in letters dated July 12, 1994, and March 7,1995, to describe the controls that exist to ensure the technical integrity of the site procedures. The Operational Quality Assurance Program (0QAP) requires that applicable procedures be reviewed following unusual incidents such as accidents, unexpected transients, significant operator error, or equipment malfunction. The licensee will continue to periodically review Emergency Opcating Procedures, Abnormal Procedures, Emergency Plan Implementing Procedures, Annunciator Response Procedures, Fire Protection Plan, Security Plan Implementing Procedures, and Security Contingency Plan Implementing Procedures on a frequency as required by the Code of Federal i
l Regulations (CFR) and other licensee commitments. QA audits are performed to review procedures for the area being audited and to examine the adequacy of the procedures and their implementation. An independent group performs assessments'of the Procedure Upgrade / Revision Program when warranted based on plant performance. The licensee also stated that pre-job briefings are performed prior to significant work activities which include a review of the applicable procedures.
Other licensee mechanisms that provide for review of procedures include:
the use of Deficiency Feedback Forms or Procedure Action Requests for site staff to identify procedural deficiencies during the conduct of routine activities, the review of procedures affected by plant modifications and revision of the l
necessary procedures prior to completion of the modification, and the Licensed I-
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3 Operator Requalification Program formal processes to resolve procedural deficiencies identified during classroom or simulator training.
Therefore, the staff finds the comitments described in the letters dated July 8, 1993, July 12, 1994, and March 7,1995, acceptable as they provide for adequate periodic reviews of plant procedures to fulfill the intent of Regulatory Guide 1.33, " Quality Assurance Program requirements (Operation)"
that endorses ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
4.0 STATE CONSULTATION
In accordance with the Comission's regulations, the Virginia State official was notified of the proposed issuance of the amendment. The State official had no comment.
5.0 ENVIRONMENTAL CONSIDERATION
This amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
6.0 CONCLUSION
The Comission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Comission's regulations, and (3) the issuance of the amendments will not be inimical to the comon defense and security or to the health and safety of the public.
Principal Contributor:
Frederick Allenspach Date: May 1, 1995
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