ML20094D744
| ML20094D744 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 12/13/1991 |
| From: | Beck G PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9112240021 | |
| Download: ML20094D744 (30) | |
Text
1 10CFil50. 54 ( a ) ( 3 ) ( 1 )
PlitLADEl.I'lilA El.ECTRIC COMi%NY NUCLEAR GROUP llEADQUARTERS 955 65 CllESTERBROOK BLVD.
WAYNE, PA 19087 5691 (215) 640-6(XX)
December 13, 1993 NUCLEAR ENGINI ERING & $[ RYlCES [EPARIMLNT Docket Nos. 50-277 50-278 50-352 50-353 License Nos. DPR-44 DPR-56 NPF-39 NPF-85 U.S. Nuclear Regulatory Commission Attn Document Control Dark Washington, DC 20555
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Limerick Generating Station, Units 1 and 2 Request for Approval of a Change to the Quality Assurance Program Descriptions Gentlemen In accordance with 10CFR50.54(a)(3)(ii), this letter requests approval of a change to the Quality Assurance (QA) Program Descriptions incorporated in the Updated Final Safety Analysis Report s (UFSARs) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, and Limerick Generating Station (LGS), Units 1 and 2.
As described below, the proposed change would remove the commitment to perform scheduled periodic procedure reviews on the basis that other establiEhed programs and processes are equally effective in maintaining the affected proceduree up to date by providing adequate proceduro revision controls.
Accordingly, while this proposed change does reduce the commitment in the NRC approved PBAPS and LGS QA Program Descriptions, wu consider that the justification described below provides an acceptable alternative commitment in that, if the proponed change is approved, the PBAPS and LGS QA Programs will continue to meet the requirements of 10CFR50, Appendix B,
" Quality Assurance Criteria for Nuclear Pow r Plants and Fuel Reprocessing Plants."
Please note also that c equest is the same as proposed by South Carolina Electric & Gas
' for the Virgil C.
Summer Nuclear Station, and approved by in its letter dated
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November 29, 1990.
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l PDAPS Units 2 &-3 and LGS Units 1 & 2 December 13, 1991 Request.for Approval of a Change to Page 2 the. Quality-Assurance Program Descriptions In accordance with our commitment to ANSI Standard N18.7/ANS-3.2-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," for LGS Units 1 and 2, and to an earlier revision of the same standard for PBAPS Units 2 and 3 (i.e., ANSI N18.7-1972), the affected procedures are reviewed periodically, on either a two year or five year basis, as specified in the UFSARs or administrative procedures.
We have concluded that this periodic procedure review is redundant-to existing programs and processes that by their nature provide adequate procedure revision control elements.
The following is a description of the programs and processes that assure procedures are maintained current.
1)
The plant modification process requires an interface review by the groups which are potentially affected by a modification.
This interface review requires that procedures potentially affected by a modification be identified and changes or reviulons made prior to the closure of the modification package.
2)
Approved changes to the plants' Technical Specifications require evaluation for impact on potentially affected procedures and result in new or changed procedures.
3)
Various programs are in place which provide a mechanism for end users to identify, document, and initiate processing of procedure improvements as a revision to the affected procedure-(e.g., the Common Nuclear Group Procedure covering the process.f or requesting changes t.o procedures).
4)
Temporary procedure changes are generated during procedure use.
A-procedure discrepancy or a unique activity are two reasons why a temporary-procedure change would be generated.
A temporary procedure change used to correct a procedure discrepancy is turned into a permanent procedure revision.
5)
The Nuclear Quality Assurance organization includes a random review of procedures as part of their activities.
These reviews may result in recommendations and corrective action 1
requests.
As a result of such input, procedure changes and revisions may be performed.
6)
Our "In-House Event Investigation Program" requires that an investigation be conducted of events associated with-Licensee-Event Reports-(LERs),-NRC cited violations, and other types of occurrences (e.g.,
events which are considered to be outside of normal, expected operation).
These investigations include identification of causes and corrective actions.- The corrective actions specified by the event investigat.lons-may include procedure revisions or the development of.new procedures as appropriate.
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'PBAPS Unito 2 & 3 and LGS Unita_1 & 2 December 13, 1991 Rrqucot for_ Approval of a Change to Page 3 tho. Quality Assuranco Program Descriptionn 7)
The Operating Experience Assessment Program (OEAP) requires industry information issued by the NRC, the Institute of Nuclear Power Operation,_and the reactor vendor as well other equipment vondors be reviewed for applicability to the plants.
Actions taken as a result of those evaluations may
' include changes to appropriato proceduros.
8)
A revised Vendor Manual Program currently being implemented requires that vendor manual revisions and now vendor manuals be evaluated to identify proceduro revisions.
9)
A new process for tracking and trending the causes of procedure changes is currently being implemented.
This program will aid in identifying any of the abovo described proceduro change programs or process which may be ineffective.
Furthermore,-performance of periodic proceduro reviews during the course of each year results in the expenditure of a substantial number of man-hours that could be applied to other areas of procedural development.
Specifically, in the case of LGS, approximately 28,390 man-hours are-spent each year to complete periodic procedure reviews.
This.estimato is. based on a review of 2163 of the total 7559 LGS procedures per year, and accounts for approximately 13 man-hours of review, approval, and documentation processing activities completed for;each procedure reviewed.
Additionally, if this' proposed chango is~ approved, the Nuclear Quality _ Assurance organization will conduct a biennial audit of the procedural'davelopment program utilizing a representative sampling process.
Tnis' biennial audit will-provide a.high degree of confidence
-that the programs and processes described above are effective in maintaining procedures current.
.The proposed changes to the QA Program Descriptions and associated UFSAR sections for-PDAPS and LGS are provided in
- Attachments 1 and 2 respectively.
Sinco approval of this proposed change would permit us to rodirect the: man-hours that would be expended toLperform the next cycle of' periodic procedure reviews, we request the NRC's prompt attention to this matter.
If you have any questions or need additional information, please contact us.
L l
l Very truly yours, G.
J.
ock, Manager c
Licensing section a
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"PBAPS Units 2.'& 3 and LCS Unita 1 &-2 December 13, 1991 Roq'uent.for Approval of_a Change to Page 4
- the, Quality Atrurance Program Descriptions Attachments cc T. T. Martin, Ad.alnistrator, Region I, USNitC w/ attachments J.
J. Lyash, USNRC Sonf or flesident Inspector, PDAPS w/ attachments T. J. Kenny, USNRC Senior Resident Inspector, LGS w/ attachments
cx Proposed changes to the Quality Assuranco Program Description for
.. Poach Bottom Atomic Power Station Units 2 and 3 M
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a 's PBAPS hh 17.2.4.7 The Materials Section and Purchasing Department shall only
$ht process approved requisitions it,accordance with PECo prscurement procedures and policies.
17.2.4.7.1 The Purchasing Department shall not alter the technical information or quality assurance requirements on a requisition of any procurement classification identified as QS, QV, QD or HX item rithout, specifically requested prior, written approval of the requisitioning organization.
17.2.4.8 lhe procurement document for QS and QV items shall include a provision fo.' the right-of-access to vendor f acilities for inspection or audit purposes.
17.2.4.9 Procurement documents shall be maintained in accordance with Section 17.2.17.
17.2.5 Instructions procedures, and Drawings 2
17.2.5.1 Activities associated with the implementation of the Nuclear Quality Assurance Program shall be described and accomplished in accordance with appropriate instructions, procedures, and
- 1NSERT A' drawings.
- Administrative procedures shall be written for l
safety related activities and approved by the appropriate l
management. QA shall review and approved administrative procedures.
17,2.5.1.1
.rBAPS Administrative Procedures shall be written by the plant staff, reviewed by the PORC, approved by the Plant Manager or an appointed designee and the site Quality Manager - HQA, and distributed to predetermined personnel.
17.2.5.1.2 These Administrative Procedures shall contain provisions which clearly delineate the sequence of actions for the preparation, review, approval, and control nf activity impicmenting a
procedures, instructions and drawings. Exhibit XI delineates the manner in which the criteria of 10CfR50, Appendix B, are implemented for each plant activity.
D.11-27 Rev. 9,-07/91 Proposed i
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PBAPS ANSI N45.2.4, Section 6.2.1, Equipment Tests, installed items requiring e.
calibration are controlled through the preventive maintenance computer tracking system. Tags or labels are not affixed to the item to
h-indicate calibration status, v
- 4. R_egulatory' Guide 1.33 - November 1972, Quality Assurance Program Req 2rements(OperatToo).
PECo shall comply with Regulatory Guide 1.33,11/72, which endorses ANSI H46.2 - 1971 and ANSI N18.7 - 1972 exclusive of other documents referenced.
l
- 1NSERT B 4
- 5. Regulatory Guide 1.37 - 3/16/73, QA Requirements for Cleaning of fluid Systems and Associated Components of Water-cooltd HPPs. Endorses ANSI H45.2.1 - 1973.
Occontamination and cleanup of radioactive contaminated systems and components are not included in the scope of this response.
PECo shall comply with Regulatory Guide 1.37 - 3/16/73 and ANSI N45.2.1 -
1973Property "ANSI code" (as page type) with input value "ANSI N45.2.1 -</br></br>1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for those activities occurring during the operational phase that are comparable in nature and extent to related activities occurring during the initial design and construction phase except for the following alternate:
a.
ANSI H45.2.1, Section 3.2, Water Quality Requirements - pil measurements hj'j are not required for conductivity values of less than or equal to 1 W
umho/cm. PEco utilizes pil limits of 5.2 to 8.6 at 25 C, uncorrected for CO2 and may apply conductivity measurements in place of total dissolved solids.
- 6. Regulatory Guide 1.38 - 3/16/73, QA Requirements fo/ rackaging, Shipping, Receiving, Storage and Handling of items for Water-cooled HPPs. Endorses ANSI H45.2.2 - 1972.
PECo.shall comply with Regulatory Guide 1.38,3/16/73, and ANSI N45.2.2 -
1972Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. for those activities occurring during the operational phase that.are comparable in nature and extent to related activities occurring during the initial design and construction phese except for the following alternates:
Classification of items - PEco does not ANSI H45.2.2, Paragraph 2.7, T4) levels described in this Standard.
a.
classify items into the four However, the specific guidance and recomn.endations which are appropriate to each class are applied to those items packaged, shipped, 0.11-53 hoPOSed Rev. 9, 07/91
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'nsert A I
Programmatic controls are in place to assure that procedures are taaintained current.
These controls take the place of, and eliminate the need for scheduled periodic reviews and revisions.
Insert B Add except for the following alternates a.
programmatic controls and processes are used to assure that procedures are current.
These controls take the place of scheduled periodic reviews.
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Proposed Changes to the QualAty Assurance Program Description and Associated Updated Final Safety Analysis Chapter 13 Sections for Limerick Generating Station Units 1 and 2
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Nuclear Engineering procurement documents for modifications chal) be controlled in accordance with administrative procedures.
17.2.4.11 Procurement documents cht.ll be maintained in accordance with Section 17.2.17.
l'/.2.5 INSTRUOTIONS, PROCEDURES, AND DRAWINGD 17.2.5.1 Activitica af fecting goality shall be prescribed and accompliche in accordance with docunenteQ.
instructions, procedures, speciti' cations, and drawings wbl.:h are
- prepared, reviewed, approved, and controlled in accordance with the PEco QA Program.
17.2.5.2 The procedures for preparing the documents dircussed chove chall
~ include consideration of appropriate quantitative and qualitative acceptence criteria to verify that inportant activities have been satisfactorily accomplished.
The activity may be prescribed in job specifications, work instructions,-
shop
- drawings, job
- tickets, planning
- sheets, operating or proceduce manuals, test procedures, or any other type of written
- form, provided that the activity is adequately described.
Quantitative criteria, such as dimensions, tolerances, and operating limits, and qualitative criteria, such as comparative workmanship cauples, shall be specified, as appropriate, for determining satisfactory work performance and quality compliances.
The review and approval of station procedures.is doccribed in Section 13.5.
In addition, PORC, whose members are knowledgeable in quality requirements and administrative contiols, reviews the test and maintenance procedures that are developed in the modification process.
17.2.5.3 The Nuclear Quality Assurance Department shall review and approve the following and the revisions thereto:
a.
The Nuclear Quality Assurance Plan b.
Nuclear Quality Assurance Procedures
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ANSI N18.7-1976/ Alls 3.2,*
Section 5.2.13.1, Proq11roment nild_llqqument ContIQl, (second sentence)
QA Program requirements or alternato approved nothods will be used to ensure quality.
Examples of alternates for suppliers without QA programs
' include:
natorial analysis, sample testing, in-proccus inspection and nonitoring, and design review by PEco.
18.
ANSI N18.7-1976/ANS 3 3, Section 5.2.15, Beview.
Apprp,ynl._ntid_ppatrol _ of"ProcedilInn - The f requency of review of plant procedures is discussed in UFSAR l
- 1NSERT A
- Section 13.5.*
1 19.
ANSI N18.7-1976/ANS 3.2, Section 5.2.17, Inonectiong - The results of inspections are not always subject to a further evaluation.
For
- examplo, ovaluation beyond that given by inspection-lcycl personnel is not normally required for go/no-go and pass / fall type inspections.
20.
ANSI N18.7-1976/ANS 3.2, Section 5.3, Prenaration of Instru_gtionn__ nnd Proceduren (last sentonce)
The clarification regarding energency naintenance in Item 12, above, applies.
21.
ANSI N18.7-1976/ANG 3.2, Section 5.3.'0, Test and Insnection PrscednIRE, (first paragtaph)
The clarification regarding test result evaluations in Item 19, above, applies.
22.
ANSI N18.7-1976/ANS 3.2, Section 5.
'1, Test and InEpection Procedurca, (second paragraph, last These procedural aspects will be sentonce) included when appropriato.
For example, "as-found condition" is not applicabic to all test and inspection procedures.
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Reculatory Guide 1.37, March 1973, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated components of Water-cooled Nuclear _ Power Plants."
Endorses ANSI N45.2.1-1973.
Decontamination and cleanup of radioactively contaminated systens and components are not included in the scope of this responso.
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13.5 J%hMLPROCEDUltTQ
- &1 Safety-related activities performed by the plant staff chall be governed by written and approved procedures of a type appropriate to the circumotances and activity, and chall be carried out in accordance with thoce procedures.
Where appropriate for determining that important activitico have been naticfactorily accompliched, quantitative or qualitative acceptance criteria chall be included.
PEco utilizec the operating experience gained at PBAPS Unito 2 & 3 (BWR units similar to LGS) in the development of the procedurec.
Ac fully described below, PECo han implemented ANSI U18.7 (1976)/
ANS 3.2, Section 5 ao r.odified by NRC Regulatory Guide 1.33 (Rev 2), paragraphc C.1 and C.S.b through C.S.j, as thece documente apply to operating staff activitien, in the preparation, content, 2ItiSERT B and control of procedures.
l Sections 13.5.1.1 through 13.0.1.25 deceribe adminictrative proceduren.
Many of these cections deceribe how various procedure types (cuch as maintenance procedurec or preventive maintenance procedurec) are developed and controlled, whereas other cections doccribe an administrative procecc (cuch as purchasing).
Unless s t a t e d -o t h e rw i c e -i n-t h e-c e c t i o n a -wh i ch-d e s c r i bt--how -v a ri eu r-proc edure-type c-a re-devel oped-a nd -cont ro11 edr-t he-period ic-res iw o f-t h e-p r o c ed u r e c -w i l l-be-o n-a-2-yea r--ba c i o r-T h oc e-t h e t-w ill-im
..h reviewed-with-a-L-year-f requency-are-provided-wit h-rationale-to-cuppor t-th ic-pocit-ion.
v Ea ch-o f-t h e - r a t i o n a l e c-r e s t r-a t-l e a s t-i n-pa r t-u p on - t h e-p o s i t i o n th a t-t h e -mer o-pa c c a g e-o f-t ime -i n-not-cu f f-i c ie n t-renc on-to-r ev i ew-a procedure-for-adequacy, Thc-ANSI-standa rd-that-recom ends-the yea r-f req ue ncy-d oe c-not-prov i d ea-ba n i o-f c r-the-cel eati on-o f-4 yearcr-Somethi ng-muot-occur-dur i ng-the-pa ccage-of-t4 me that-vould m a k e-t h e-r ev i e w-o r-r e v i s i o n-o f-a - proced u r e-a n-a pp r op r-l a t e-a c t ion-t o
- take, I t-ch ou l d -- be - no t ed - th a t-co n t rol-l ed -rev i-owc-o f-eq u i pm e n t-or-system-modifications-result in-the-rev-iew-or-applicable-prc ocdurt.s f or-the-potent i a l-e f f oct-of-the-modi f-icationv
- I n-ed d i t-ion,
s t a nd a rd -pr a c t i c e c - rega rd i ng --rov i ow--a nd-recpon ce-to-document a-su ch a r.-N RC-Bu ll et i nc,-
Circula r s-and-Not icecr-I N PO-documents-and-industry-documents-that-are-scrooned-by-tha operating F.xperier.cc Ascecament-Program-and-f-orwarded-for act-ion--by-the-plant-staf f--a re i n-pl a c e-a n d -ca u se-p r oced u re c~to-bo-r av i ewed-a nd-r+ v i s ed-a n-app r opr-1 a t e-d n-r e l a ti on-to-t h e-rev i ew--o f-t h e so-i nd i-v i d ua 1-Moeuments.
Proposed 13.5-1
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Insert A Add "except for the following alternatives o) programmatic controls and procerses are used to assure that procedures are current.
These controls take the place of scheduled periodic reviews."
Insert B
" Programmatic controls are in place to assure that procedures are maintained current.
These. controls take the place of, and eliminate the need for, scheduled periodic reviews and rr. visions."
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For Information Only LGD UFSAR It is planned that mor^ administrative and operating procedures vill be in ef fect at leau six months prior to fuel loading of Unit 1.
The procedures will be implemented with sufficient lead time to ensure that operating personnel can become f amiliar with them.
pEco recognize's the benofits of using the preoperational testing phase to demonstrate the adequacy of operating procedures and, where practicabic, this will be accomplished.
The following paragraphs describe the types of procedures to be employed by station operating personnel in the conduct of safety-related activitics.
These procedures are normally prepared by the station operating staff.
However, organizations providing
' technical support and consultants may assist in procedure development.
The procedures and revisions thereto are reviewed by Station Qualified Reviewers (SQRs) who are approved and designated as such by the PORC Chairman to perform such reviews f or specific classes of procedures.
The SQRs determine i7 Writing if a cross-disciplinary review is required by the appropriate personnel prior to approval.
Procedures or revisions thereto are approved by responsible Superintendents who are designated as such for specific classes of procedures by administrative procedures.
PORC reviews administrative procedures and those procedureu or revisions thereto requiring a 10 CFR 50.59 safety evaluation be performed. The Plant Manager or his designated alternate approves administrative procedures, amergency plan implementing procedures, security plan implementing procedures, and any procedure or revision thereto requiring a 10 CFR 50.59 safety evaluation be performed.
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'J 13.5.1 ADMINISTRATIVE PROCEDURES j
Administrative procedures generally include those that establish station management policy, those that control activitics that involve interf aces among disciplines or groups supporting plant operations, and those that establish criteria for procedures and activitics implemented by the plant staff and support organizations.
Administrative procedures shall be prepared in sufficient detail so that tasks are performed in a consistent, officient manner and to ensure that the necessary reviews end approvels are performed.
The following paragraphs describe the administrative procedures expected to be employed.
The numbers of procedures and their specific content may be altered as the procedures are developed and experience is gained in their implementation.
13.5.1.1 Procedure for Preparation and C3.AtJ'ol of Administrative Procedures This procedure shall provide the measures to control and coordinate the preparation, review, approval, and issuar cc of administrative procedures.
This~ procedure' shall require that administrative procedures be distributed to appropriate personnel in accordance c-with current distribution lists to ensure that outdated or 13.5-2 Rev.1 July /91
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inappropriate procedures are not used.
The format and content of administrative procedures shall be defined ast a.
Descriptive title, revision number,'and date.
b.
Statement of applicability or purpose.
c.
References, including technical specifications or procedures as applicablo.
d.
Prerequisites when there are independent actions or procedures that must be completed prior to using the procedure.
c.
Procedure section.. The procedure shall provide the steps needed to perform the task in the degree of detail necessary to ensure
- correct, efficient performance without direct supervision or undue reliance on memcry.
This section may also provide criteria statements to be impicmented by other procedures.
Administrative procedures are written to provide direction for the efficient administration of plant business and reflect the station -
nanagement philosophy and to implement corporate policies regarding these functions. Because tihey-are-used-roubinelyr-theli-continuing-app 14'oabi44ty-is-demonstrated-through-use, 'Phese-procedures-vould-be# ooted-by-documento-suoh-as-NRC-Bu14st4ns -C4reu-lare-ond-Hot 4ces,-4m g
Pg aff r
' changes---in--coropa ny-po44ey,
or-INpO-documents.
Because---these d ocu m en t o-a re-reviewed-on-a n-ong oi ng-ba s-i n--a nd -fa c to red--in t o ad mi n is tra t4vo-procedures-who re--a ppropr4 ate-on-a-ca co-by-caso-
- basis, a
2-year rev4ow-would-not--be-neeessary.
Howevery
' recognia?ng-potent 4al-for-an-aocumulation-of-such-dooumonts-hav4ng-come-o f-fec t-on-ad mini st ra t-i-vo-req ui re m e n ts-fo r-o-nu c le e r-po wer-pla n t,-this-proc edu re-shatl=requiro-tha t-admini strative-procedures.
be-reviewed-a te-e-spool f4 cd-f-req uency-o f-no-les s-th a n-5-ye a rs-(e-procedure-revision-const-itutec a review)-and-fellowing-unusua4 1-noidents that r e f-leo t--ad ve reol-y-o n--the--a d oq ua cy- -o f-th o c o proceduses.
13.5.1.2 Procedure for Plant Operations Review Comei._ttee s
. This procedure shall define the requirements of membership, meeting
. frequency,' quorum, responsibilities, authority, and records for the PORC in implementation of technical specification provisions.
The PORC shall review significant conditions adverse to plant' safety to ensure that - the cause of the condition is identified, that corrective action is taken 'and ' documented, and(that appropriate subjects are referred to the Nuclear Review Board.
13.5.1.3 Procedure for Plant and Shift Operations f.
This procedure shall defiric tfe'Me's'ponsib'ifilles and authority of I
F plant operating personnel, including:
1 13.5-3 Rev.1 July /91 l
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Procedure section. : Tho' procedure shall provide lthe steps '.
iV needed tto perform' them ta_sk :in ?thej'degreo ;of ? detail;
- necessary to'= ensure = safety - 'and correct.: performance without undue ireliance 'on memory : or direct ' supervision -
and in consideration of the skills normally possessed by train'ed craf t, personnel.
-precautions c and ' reference documents important to specific ~ steps in' the procedure shall be ' identified or included at thoso steps.
This section shall also provide" instructions for performing and documenting the results of required inspections and tests and provides the necessary acceptance criteria.
When appropriate, checkoff lists shall be included in or appended to preventive maintenance procedures.
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'll. is section shall contain instructions au to the mode or condition in which the equipment is to be placed after completion,of the preventive maintenance action.
Maintenance and preventive maintenance procedures are proven to be correct through their use.
Because they are written for specific equipment, they are _not subject to intersystem ' changes that may affect other procedure types, -such as general plant procedures.
Maintenance and preventive maintenance procedures are reviewed when 3
-oquipment modifications
'are made':through-the_
controlled h'
- nodification program at the station.' In addition, when indicated by tho' review of NRC Bulletins, Circulers and Hotices, ;INPO documents and' industry documents, the procedures are revised if necessary.on a case-by-case basis.-
To : ensure syste-atic review-end feedback, tMs - procedures shall require that preventive maintenance procedures be reviewed 'at-a speoM-led-f-r-equeney--ef 'nc lec; than 5 yccra (a precedure revision eenst-itutec a revicv) cnd following unusual incidents that reflect adversely on the adequacy _of these procedures.
13.5.1.9: Procedure f_pr Adg.inistration of_ the_ Surveillance Testinc_Epocram.
This-procedure shall-establishes the administrative requirements and responsibilities for the surveillance testing program so that
= such testinn-is proplanned and performed in accordance with' written i
Lprocedures o' drawings appropriato to ~ the' circumstances,oand -in -
accordance with the technical specification requirements;;? Included in this program shall be the safety-related instruments and control:
devices and special -equipment-lasi defined' iny thei technical' 4
specificati_ons. ; The aspects ~of surveillance testing that shall be addressed in this procedure include:
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This
~ section
'shall contain instructions as to'_ the mode or condition 'in which the 4
equipment is to be placed af ter completion' of the surveillance test.
This procedure shall require recording the test date, corrective actions taken (if any), identification 01 those' performing the
-test, and identification of those evaluating the test results to ensure that requirements have been net.
surveillance tests and routine tests are performed on a periodic basis t this step-by-step use of the procedure demonstrates the adequacy of the procedures.
In addition, when changes in the plant Technical Specifications are received, the appropriate procedures are identified and revised.
Plant modifications, NRC Dulletins, and Information Notices also initiate procedure review and revision, if needed.
To ensure syctentio-twiew--ed-feedback, tMe procedure.5 shall require that surveillance test procedures be reviewed at---a.
speoLf-i+d-frequeney-of-no 1cas-bhan-5-years-ta p uuedut u t u vh. inn const4tutes-a-rev4ew)-and-following unusual incidents that reflect adversely on the adequacy of these procedures.
The surveillance test progran shall include procedures for monitoring performance of plant systems to ensure that engineered a
safety features and emergency equipment are in the required state Mc of readiness and that operating systems are performing properly.
The linits for significant parameters shall be identified as well as the nature and frequency of nonitoring.
13.5.1.10 Procedure for Administration of Plant Records This procedure shall establish the provisions and responsibilities for retention of plant records.
Preparation of records is discussed in procedures that cover the specific activities.
The responsibility for maintaining and storing records at specified location (s) shall be assigned.
This procedure shall ensure that retention times are established so that applicable statutory requirements are satisfied.
The significance of the event covered g
by the record-type and the contribution' of the record to the ability to reconstruct significant events shall also be. considered
-in establishing retention periods.
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W Proposed 13.5-14
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I This procedure shall establish the administrativo requirements and responsibilitics for the plant security program that is developed to implement the industrial security plan and to supplement features and physical barriers designed to control access to the plant and, as appropriato, to vital areas within the plant.
This procedure shall require that security procedures be distributed to i
appropriate personnel in accordanco with current distribution lists, which reflect the confidentiality of security provisions, to ensure that outdated or innppropriate procedures are not used.
This procedure shall define the format and content of security procedures as follows:
a.
Descriptive title, revision number, and date, b.
Statement of applicability or purpose of the procedure.
c.
prercquisites, vnen needed, including those independent actions or proceduros that must be completed prior to use of the security proceduro, d.
References, when needed.
c.
precautions to alert the individual performing the task h.h to those important acacures that should be used to protect equipment and personnel, including the public, or to avoid abnormal or emergency conditions, f.
Procedure noction. The procedure shall provide the steps needed -to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision.
Precautions and reference documents important to specific steps in the procedure chall be identified or included at those steps.
Acceptance criteria, where appropriate, shall be specified.
When appropriate, checkoff lists shall be included in or appended to the procedure.
To ensure syctematdo---revi ct' and fcedback,- thi+ procedurcs shall require that security procedures be - reviewed Lat-a. - c,poeified-f-requenoy-of-no-1-oss--than 2 years--(+-procedure-revisic-n constitutes a-revice)--and. f ollowing unusual-incidents that reflect. adversely
-on the adequacy-of those procedures, r
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13.5.1.13 Eroceduro for Prppara_ tion _of liaintenance Procedure _g -
This procedure shall establish the administrative requirements and
- responsibilitics for the preparation and control of maintenance
_proce uros that are developed to maintain safety-related equipment.
d Actual coordinption and' planning for maintenance actions shall be 2
accomplished through the procedure for controlling in-plant work.
The following aspects of maintenance work shall be addressed in this procedure:
a.
The need to perform maintenance activities in a nanner to ensure quality as specified in the original or approved modification design.
b.
Specification and performance of appropriate inspections and tests to attain a suitable icvel of confidence that the maintenance has been properly performed.
c.
Activitics that ensure the quality of maintenance shall be performed in accordance with documented drawings or instructions that are appropriate to the circumstances, that conform to the design requirements, and which provide for
. documentation of activities where appropriate.
Skills nornally possessed by trained craf t personnel may not requ!.re detailed step-by-step delineations in a written procedure.
s(s) d.
The status of inspections and testa performed on items shall be indicated by _the use of stamps, tags, labels, routing-cards,- procedural sign-offs, or other nethods that provido traceability between the record and the item (s).
Also, where necessary to preclude inadvertent bypassing of inspections and-tests, items that have
~
satisfactorily passed required inspections and tests shall be identified.
c.
Special control requirements for emergency naintenance that must proceed immediately to correct a degraded safety condition and for which a procedure does not' exist.
This-procedure shall require that the following aspects of housekeeping and cleanliness control be considered in development of naintenance procedures:
b 13.5-19
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Maintenance and preventive main _tenance proc dures are reviewed when -
equipment modif3 cations are made / through _ the
- controlled
~
.nodification program at the station.
'In' addition, when indicated
~
by the re' view of _hRC IE Bulletins, : Circulars "and Notices, INPO documents 7nd industry documents, the procedures are revised if
.necessary on a. case-by-case basis.
+
To ensure cyctc~atic revir and feedback, t-hie procedurcy shall require that maintenance procedures be reviewed at-e-speoi-E-ied
~ f-r+quoney-of-no-1+ss-t-har. 5 ycare-fa-precedurc rcvisien-const% tes a-rev-i-ct ) and= following unusual incidents that reficct adversely on the adequacy of these procedures.
This procedure shall also require that naintenance procedures be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.
12.5.1.14 Procedure for Preparation of Tra_p_sient Response Implementation Plan Procedures This procedure shall establish the administrative requirements and responuibilities for the preparation of Transient
Response
Implementation Plan procedures.
Transient Responsc Impl'ementation Phn procedures are symptom oriented decision tree -flow' charts for cperator actions based on c
recognition of critical symptoms and definition of actions to maintain key plant parameters within predetermined ranges.
The Transient
Response
Implementation Plan procedures have been developed from the BWROG EPGs.
To ensu.
s"cto:atic revic;' and feedback, 4his procedures shall IP procedures be reviewed at e cpeeiried-frcquency require tl.
t.
of nc 1ccs- <. 2 year-c (a procedure-r-ev-islon-constituten a r-ev4ew-)
-fme following unusual incidents that reflect adversely on the adequacy of these proccdures.
Response
Implementation Plan procedt res shall be distributed to appropriate personnel in-accordance with current distribution lists to ensure that outdated or inappropriate
-procedrres are not used.
13.5.1.15 Procedure for Preparation of Emercency Plan Procedures This procedure shall establish the aaministrative requirements and responsibilities for the preparation of emergency plan procedures that implement the emergency-plan.
This procedure shall establish.
the format and cettent of-emergency plan proceduresf as follows:
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plan, diawings,;and procedures as? applicable.t- :p d.-
prerequisites.
- When applicable,' thisEsection shall define or explain the conditions thar shoulrl exist prior to performing the procedure or certain proedural steps.
.e.
Symptoms. When applicable to the scope of the procedure, this section shall contain symptoms and obser rations, including a description of alarm signals, that aid operating personnel and others in determining procedures and actions to be implemented, f.
protective action,-levels.
. Criteria for performing i
specific actions'shall be provided when applicable to the scope of the procedure.
g.
Procedure, including immediate actions and subsequent
, actions..~ The procedure shall specify-the1 steps to bc taken 4neluding, as appropriate: L assignment of specific -
responsibilities and 1 authorities ifor pe formance~ of.
specific _ tasks to individuals and support groups; methods e
for : coordinating the.. activities ' ~of offsite ' agencies; W
precautions applicable to specific' steps;-. protective measufes
' outlined ifor the
- identified' emergency; 4
instructions -for.. medical : treatment - and ihandling ' of-contaminated personnel;;special equipment? requirements;
,' identification of emergency communication methods 'among participating' f organizations;:
and-instructions.for
. returning the plant ; to normal ' conditions Er to provide safo, stabilized conditione.following the emergency.:
This_ precedure shall also establish appropriate requirements and
- responsibilities - for preparation of 7 crating instructions for special equipment. _ Inspection and mal..v.tance of special equipment and: testing of procedures, cc vaunicaclons, and alarms ito ensure that: theyJ function properlyL shall bsl within: the7: scope of surveillance : tests or.- preventive maintenance asE appropriate.n To (ensure cycteratic re"ic'a ~and feedback, -this proceduresshall require ',
- that emergency procedures be ? reviewed 1at c ' frequency ciEnc lecc Jthen
.yecrc (a procedurc. rc'/icien 'conctit"tec 2 rs/ leg and ~
-l s
1following unusual incidents.that reflect adversely:on1the adequacy R
-_of these procedures.,
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Emergency plan procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate _ procedures are not used.
13.5.1.16 Procedure _for Preparation of General Plant "rocedurcq This procedure shall establish the adminis rative requirements and responsibilities for the preparation of general plant procedures that are written to provide integrated instructions for major plant evolutions such as plant startup or shutdown. This procedure shall establish the crite_-ia for general plant procedures, such as:
a.
Preparation of startup-procedures including reactor.
startup from cold and hot conditions, generator synchronization, and recovery from reactor trips. These procedures shall implement the authority and responsibilities of reactor operators as defined in other administrative procedures.
b.
Preparation of shutdown procedures including controlled shutdown and reactor trips to the establishment and maintenance of hot or cold shutdown conditions.
Preparation of procedures covering steady-statc and load c.
changing conditions and operations such as use of control
( rods, coolant flow control, and adjusting operating I Ce; -
parameters.
This procedure shall establish the format and content of general plLnt procedures as follows:
a.
Descriptive title, revision number, and date.
b.
Statement of applicability or purpose, c.
References, including technical specifications, drawings, or procedures as applicable, d.
Prerequisites, inclPding those inMpendent actions or procedures that must be completed and plant conditions that must exist prior to use of the procedure.
Prerequisites applicable to only certain sections of the procedure shall be so identified.
Startup procedures shall require documentation of completion of prerequisites such as confirmation that necessary instruments are operable and properly set; that necessary G
13.5-25
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tests, and calibrations ;have%been c.ompleted;fand that required approvals have been obtained. Checkof f lists can be used - for c the ; purpose of defining.and documenting completion of, prerequisites..
e, precautions, where necessary 'to'~ alert 1the individual performing the ' task. to those important ~ measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situatien.
f.
procedure section.
The proceiure shall provide the sequence and steps needed to perform the task in the degree of detail necessary to ensure safety and correct
=-
performance without undue reliance on memory or direct supervision.
Cautionary notes applicable to specific steps shall be identified and included.
System procedures or other detailed instructions not contained in the general plant procedure shall be referenced at the applicable steps.
Where ' appropriate, check off lists shall be included in or appended to the procedure for the purpose of assisting.the operator and/or confirm 3.1 completion 'of major steps in the proper sequence.
Limitations on parameters being controlled and appropriate corrective measures to return the parameter to the proper value shall.be specified where appropriate.
To' ensure cyct'ematic review and feedback, -th-ie procedures shall require that general plant procedures be reviewed at a cpeoi44ed f+equency-of-no-1ess-than 2 yearc (a precedurc revia-icn-constitutec
.a-revieu) an4. following unusual incidents that reflect adversely on the adequacy of these procedures.
When determined necessary by the PORC, tests shall be performed to confirm that significant changes to general plant procedures produce the expected results.
General plant procedures shall be distributed to appwpriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.
13.5.1.17 Procedure for Pyeoaration of System Procedures This procedure shall establis'h the administrative requirements and responsibilities for -the preparation of system : procedures =for safety-related systems.
The. procedure shall lreqdire system procedures to address normally expected operations:'such as energizing, filling, venting, draining, starting up,- shutting down, and changing modes of-operation as applicable to.tho' system.
It is not the intent of these proc'edures to cover actions, operations, or system conditions.that would be unique to a special operation, such as maintenance, and would be' covered in a special procedure written at the time the' operation is needed.
i roposed P
13.5-26
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This procedure shall" establish the format Dan'dlhontenti of Jsystem
- d procedures as follows:l
~
a.
Descriptive title, revision' number, and date.'
b.
State' ment of applicability or purpose.
c.
References including technical specifications, drawings, procedures, equipment manuals, and vendor documents as applicable, d.
Prerequisites, including those independert actions or proc'edures that must be completed and plant conditions that must exist prior to use of the procedure.
Prerequisites applicable to only certain sections of the procedure shall be so identified.
c.
Procedure section.
This section shall p, vide the steps to perform the various operations in the egree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision, and in consideration of the skills possessed by trained operators. Cautionary notes applicable to specific steps shall be identified or' included.
Limitations on parameters being controlled and appropriate corrective neasures to return the parameter-to the proper value
+ --).
(j shall be specified where appropriate. Where appropriate, check off lists shall be included in or appended to the procedure.
To ensure eyctemetic r ev ic'c cnd feedback, t4de procedures shall require that system procedures be reviewed at-a-specified frequency cf no--1ccc -t-han 2-yearc -(a precedure revision constihtes a revicw) ed following unusual incidents that reflect adversely on the adequacy of these procedures.
When determined - necessary by the PORC, tests shall be performed to confirm that significant changes to system procedures produce the expected results.
System procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures shall'be not used.
13.5.1.10 Procedure for Preparation of Operational Transient Procedures This procedure shall establish.the administrative requirements and responsibilities for the preparation of operational - transient procedures for tho restoration of normal, operating conditions following a perturbation.
This procedure shall ~ establish the format and content of. operational transient procedures as follows:
d-1 Proposed
'13.5-27 1
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c.
immediate actions for1 operation'of'controlsLto restore normal operating conditions.
d.
Follow-up actions.
e.
Verification of automatic actions. The automatic actions that are expected to occur as a result of the condition shall be identified.
To ensure 'cyrtematic review cnd feedback, tMs procedures shall require that _ operational transient procedures be reviewed et-e speci41-ed-f+equency-of-nc-- 1:cc t4mn - 2 years (a procedars -revieion eencrtitutec a reviou) cnd following unusual incidents that reflect
.a equacy of these ' procedures.. Operational d
- adversely on the
' transient procedures shall be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.
13.5.1.19 Procedure for-Preparation of - Alarm Response cards 2
This' procedure shall establish the administrative' requirements and responsibilities for the preparation of individual alarm response cards.- 'The procedure shall provide-_for' preparation of individual
~
alarm _ response cards to which operators refer. _ Alarm.- response cards shall be maintained in the control room and shall contain the following information:
a.-
Identification ~of the alarm b.
Alarm setpoint c.
Identification of the signal source instrument
- d.-
Automatic actions that are expected to occur Operator response (immediate and long-term) e.-
To ensure syrtematic re"ic" and l feedback,7 tMe-l procedures shalll require that safety-relatedialarm response cards?be; reviewed et-e
. -cpecified frequency of.nc leccithan 2 ycirc (c reyicien-constitutes a re"iew) and following1 u.nusual Lincidents/ that reflect? adversely.
on the adequacy of the alarm response: card.
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Alarm response H information" is' - retrieved by identifying the alarm number and referring to the corresponding alarm card or procedure number.
13.5.1.20 Procedure for Preparation of Fuel Handlino Procedures, This procedure shall establish the administrative requirements and responsibilities for the preparation of fuel handling procedures that shall specify actions for core alterations, accountability for
- fuel, partial or complete refueling operations, receipt and shipment of fuel, and such-specific procedures for each refueling outage as necessary to accomplish the required actions in a safe, efficient manner.
This procedure shall establish the format and content of fuel handling procedures as fol. lows:
a.
Descriptive title, revision number, and date.
Statement of applicability or purpose, c.
References, including technical specifications, drawings, or, procedures as applicable, d.
Prerequisites, including those independent actions or a..
procedures that must be completed =and plant = conditions di that must exist prior to use of the procedure.
Prerequisites applicable to only certain sections of the procedure shall be so identified.
e.
Precautions, where necessary, to alert the individual (s) performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation, f.
Limitations and actions.
Limitations on appropriate parameters and corrective action to return the parameter to the proper value or other appropriate action shall be specified.
CG:
13.5-29
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task inL the 'degre"e of "detai1Ynece'ssaryTto? ensuro* safetyX c
and correct performance without1 undue' reliance on1 memory or' direct supervision.t cautionaryinotes and-references-applicable 1 to"l specific istepsishallib'elideritified and '
included. !Where' appropriate Mcheck^off_-lists shall be included in ;or appended to the procedure for the purpose of assisting the - operator -and/or ' confirming completion of: appropriate. steps..
This procedure shall require documentation of ~ final fuel and-component serial numbers and locations' to _be developed and maintained.
To c ensure 'systentic rc"ic" and feedback, 4h-le-procedures shall require _that fuel-handling procedures be reviewed ct a specified frequency Of-nc lecc--than 2 ycars (a procedure revision constiLates c-re" ley) eM following. unusual incidents that treflect adversely on.the adequacy of thesei procedures.
Fuel L handling' procedures shall be_ distributed to appropriate personnel in;accordance with' current distribution' lists to ensure that _ outdated or inappropriate procedures are not used.1 13.5.1'.21 -Procedure for' Preparation'of-Health Physics Procedures i
This procedure shall establish the administrative requirements and
-($
s.
s,
responsibil t es for the preparat on_of health physics procedures
~
ii i
that implement-the_-radiation' protection program.., This procedure shall' require preparation of : health; physics 1 procedures)in the following areas:
a.
Monitoring exter_nal and internal exposures'of _ appropriate employees utilizing-accepted techniques.-
b.
Routine radiation surveys of work areas.
c.
Environmental monitoring within _the = scope of the operating staff responsibility.
d.
Radiation. monitoring of maintenance andfspecial _ vork activities.-
~
+
c
-, +
Maintenance ?of drecords 7 emoristrating. the indequacyj s '
~
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measures taken Eto icontroli; radiation:(exposures of employees and.Lother appropriate;personnelo '_ ;
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Control, receipt'ilandishipmentfof. rad _ioactive material.
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y-This precedure shall esitablish the formatt and !'coiste:C of' health d
physics procedures as follows:
i 1.a.
o a.
Descriptive _. title, revision number,Jand date, b.
Statement of app'licability or purpose'.
c.
References, including technica1 specifications, drawings, procedures, and operating manuals as applicable, d.
Apparatus, such as instruments or special equipnent, as applicable.
e.
Precautions, where necessa'ry, to alert the individual performing the task to those important measures that should be used to protect equipment and personnel, including the public, or to avoid an abnormal or emergency situation.
Routine precautions that a trained technician is expected to take need 1.ot be listed.
f.
Procedure section.
The procedure shall provide the needed steps to perform the task in the degree of detail necessary to ensure safety and correct performance without undue reliance on memory or direct supervision.
Precautions and references important to ' specific steps in the procedure shall be identified and included at 6k those steps.
When appropriate, check off lists shall be included in or' appended _to health physics procedures.
Health Physics procedures will normally be prepared by members of the ISS Services organization, knowledgeable in Health Physics; however, organizations 'providing technical support and consultants s
may assist in procedure development.
These procedures will be developed in consultation with the Director of the Radiation Protection Section and his staff and will be approved by the PORC.
The Health Physics procedures are primarily administrative and analytic.
They represent the mest ef ficient way to administer the Health Physics program.
.Many are based on either the type of equipment in use in the plant or, in the case of shipping radioactive materials, they are based on regulations.
When the regulations change, the Health Physics procedures would be revised if needed.
If new equipment for' analysis is obtaine'd, new procedures would be written for that new equipment.
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gg 13.5-31
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To -. ensure _ cycteratic f reviev 'and ~ feedback, $hleJprocedurcs shall t
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-require that health physics 1 procedures be' reviewed at a specMied
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-f-requ e ncy-of-n o-14s s-tha n-5--yea r4-(6porocedu re--r sv4slen-const4t-ute s a-revicu) and-following = unusua.1 ' incidents l that reflect ' adversely
!!calth physics " procedures on. the adequacy, of these ' procedures.. f u
-shall be distributed to appropriate personnelJin accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.
13.5.1.22 Procedure for PrepAr_ ALi._qn_nf Chemistry Procedures This procedure shall.cstablish the administrative requirements and responsibilities for the preparation of chemistry procedures that include chemical and radiochemical control activities.
This procedure shall establish the format, content, distribution, and periodic review requirements for chemistry procedures as described for health physics procedures.
13.5.1.23 Procedure for Temporary Chances to Approved _ Procedures This procedure shall establish the administrative requirements and responsibilities for making temporary changes to approved procedures.
The procedure;shall provide that. temporary changes, clearly not changing the intent of the' approved procedure, shall be documented and - approved by two members of the plant staff knowledgeable in the area (s). affected by the procedure.- At least one'of these individuals shall be a shift superintendent or shift supervisor (a. senior reactor operator on the unit affected).
= Temporary changes shall be incorporated in the next procedure revision if appropriate.
13.5.1.24 ' Procedure for Preparation of Of f-Normal Procedgres This procedure shall establish the administrative requirements and responsibilities for the preparation of off-normal procedures that are written to specify operator actions. following an operator observation of_ an off-normal (nontransient) conditicn which
- requires immediate -action to prevent degeneration of the existing condition.
This procedure shall establish the format and content' of off-normal procedures as follows:
a.
Descriptive _ title, re_ vision number, and date.
b.
Symptoms.
This'section shall include symptoms to aid in identifying or confirming the off-normal condition. Alarm conditions,. parameter changes, and.- other observations shall be considered.
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Proposed 13.5-32 1
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4 Operator actilons..This sectionishallispecify, actions'tof.
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1 be taken _.to;Lidentify, confirm,,.or correctithe cause.of
.the off-normal condition.-
To ensure cyctentic re'/ict-and-feedback, _ th44; procedures shall require that 6ff-normal procedures be-reviewed'at'a spccifica frequency-of-nc 1ecc thar 2 yearc (a pr-ocedur+rev-is-ion-const4tutes a-review}-and-following unusual incidents that reflect adversely i
on the adequacy of these procedures.
Off-normal procedures shall-be distributed to appropriate personnel in accordance with current distribution lists to ensure that outdated or inappropriate procedures are not used.
13.5.1.25 Procedu_re for Preparation of Event Procedures and Special Event Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of event procedures and special event procedures that are written to specify operator actions following an ciperator observation of an event of an emergency or unusual nature.
This procedure shall establish the format and content of off-normal procedures as follows:
a.
Descriptive title, revision number, and date.
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Pe pose.
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Syn;ptoms.
Symptoms shall be included to aid in the 5acntification of the plant condition.
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Inmediate operator action.
This section shall specify action to be taken as a result of the identified condition, e.
Follow-up action.
13.5.1.26 Procedure for Preparation of Radwaste Procedures This procedure shall establish the administrative requirements and responsibilities for the preparation of radwaste procedures. This procedure shall require administration o.f the. station radwaste program in the following areas:
a.
Control handling, packaging, - storage, - and shipment of radiorrtive material.
b.
Inspection,. installation, and use' of equipment-used to process and package radwaste.
j Proposed O
13.5-33