ML20203A695

Revised Rev 2,App B to Vermont Yankee Operational QA Manual (Voqam)

ML20203A695
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Site:	Vermont Yankee
Issue date:	02/04/1999
From:	VERMONT YANKEE NUCLEAR POWER CORP.
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ML20203A692	List: ML20203A688 ML20203A695
References
NUDOCS 9902100069
Download: ML20203A695 (29)

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VOQAM i TABLE OF CONTENTS /INDEX f l' Effective Current  !

~l Section No. Title Pace (s) Revision  !

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~l AMENDMENT / REVISION IV 2  ;

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POLICY STATEMENT 1-2 1 l f l: I ORGANIZATION' 1 - 26' 1 {

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l II QUALITY ASSURANCE PROGRAM 1-7 2 I 5

.l LIII. DESIGN CONTROL 1-4 1~ f l.

.l IV -PROCUREMENT DOCUMENT CONTROL 1-3 1 l' i j- V- INSTRUCTIONS, PROCEDURES, AND 1-2 1'  ;

l. DRAWINGS -1 l l l VI DOCUMENT CONTROL 1~- 4 1 I i l VII CONTROL OF PURCHASED MATERIAL, 1-3 1 l EQUIPMENT, AND SERVICES I

l VIII IDENTIFICATION AND CONTROL OF 1-2 1 l MATERIAL, PARTS, AND COMPONENTS I -

-l IX. CONTROL OF SPECIAL PROCESSES l' - 2 1 l

l X INSPECTION- 1-2 1 l

l XI TEST CONTROL 1-3 1 l -,

l XII. CONTROL OF MEASURING AND TEST 1-2 1 l EQUIPMENT I I

l XIII. HANDLING, STORAGE, AND SHIPPING 1-2 1-1.

-l- XIV INSPECTION, TEST, AND OPERATING 1-2 1 l STATUS I-  !

Title . Table of Contents Page: 1 of 2 l Rev.: 2 9902100069 990204" PDR ADOCK 05000271 P PDit

VOQAM TABLE OF CONTENTS /INDEX

l. Effective Current l Section No. Title Pace (s) Revision l

l XV NONCONFORMING MATERIALS, PARTS, 1-3 1 l AND COMPONENTS I'

l' XVI CORRECTIVE ACTION 1-2 1 l

l XVII QUALITY ASSURANCE RECORDS 1-3 1 I

l XVIII AUDITS 1-4 1 l

l APPENDIX A QUALIFICATION REQUIREMENTS 1 1

-l l APPENDIX B EXCEPTIONS 1 - 27 2

'l l ' APPENDIX C VY CLASSIFICATION 1 1

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Table of Contents Page: 2 of'2-l Rev. 2

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APPENDIX B Exceotions l

The sub-categories of this Appendix summarize the' exceptions noted in Section II of the Vermont Yankee Operational Quality Assurance Manual. .

1 Appendix B Sub-cateoorv  : Standard / Guide Title I. ANSI N45.2.3-1973 Housekeeping During the l Construction Phase of Nuclear 1 Power' Plants r 3 j

II. ANSI N45.2.9-1974 Requirements for Collection, 1 Storage,.and Maintenance of

-Quality Assurance Records for Nuclear Power Plants l l

III. ANSI N45.2.10-1973 Quality Assurance Terms and '

Definitions l

IV. R.G. 1.64, Rev. 2 Quality Assurance Requirements for l

the Design of Nuclear Power Plants  :

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V. ANSI N45.2.2-1972 Packaging, Shipping, Receiving, Storage and Handling of Items for j Nuclear Power Plants i

VI. ANSI N45.2.6-1978 Qualification of Inspection, )

I Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants

.VII. R.G. 1.26, Rev. 3 Quality Group Classifications and Standards for Water , Steam- and <

Radioactive-Waste-Containing Components of Nuclear Power Plants VIII. R.G. 1.29, Rev. 3 Seismic Design Classification IX .- ANSI N18.7-1976 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear-Power Plants l= ,

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Appendix B, Exceptions

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Appendix B Sub-cateaorv Standard / Guide Title i

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i X. R.G. 1.33, Rev. 2 Quality Assurance Program j Requirements (Operations)  !

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APPENDIX B (continued)

I. ANSI N45.2.3 - 1973, HousekeeDino Durino the Construction Phase of i Nuclear Power Plants A. EXCEPTION:

Subsection 2.1 - Plannino l The Vermont Yankee plant takes exception to the five-zone requirements specified in the subject standard ALTERNATIVE:

The Vermont Yankee plant shall establish as a minimum a three zone program as follows:

Zone III  !

Zone III criteria shall be applied to major portions of the reactor coolant system which are opened for inspection, maintenance or repair.

1. Access control over personnel shall be required.  ;

2. cleanliness shall be maintained, commensurate with the work being performed, so as to preclude the entry of foreign material to the Reactor Coolant System.

3. A documented cleanliness inspection shall be performed immediately prior to closure.

l Note: The Zone III requirements may be expanded for certain i maintenance repair activities if deemed appropriate by plant j management. In such instances applicable sections of Zones I & II shall be specified.

Title:

Appendix B, Exceptions l Page: 3 of 27 l Rev.: 2 l

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APPENDIX B (continued)

Zone IV Zone IV criteria shall be applied to the radiation control areas  :

of the plant.

1. Standard janitorial and work practices shall be utilized to maintain a level of cleanliness commensurate with company  ;

policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.

2. Additional housekeeping requirements shall be implemented as required for the control of radioactive contamination.

3. Smoking and eating shall be controlled consistent with good health physics practices and to maintain cleanliness.

Zone V Zone V criteria shall be applied to the remainier of the plant.

1. Standard janitorial and work practices shall be utilized to maintain a level of cleanliness commensurate with company policy in the areas of Housekeeping, Plant and Personnel Safety and Fire Protection.

B. EXCEPTION:

Subsection 3.2 - Control of Facilities The Vermont Yankee plant takes' exception to the control of tools, equipment, materials and supplies used in Zone III.

Title:

Appendix B, Exceptions Page: 4 of 27 l Rev.: 2

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APPENDIX B i 1

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! I ALTERNATIVE:

, The Vermont Yankee plant shall verify control for zone III as l

indicated in Exception A of this sub-category.

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p-APPENDIX B (continued)

II. ANSI N45.2.9 1974, Reauirements for Collection, Storace, and Maintenance of Quality Assurance Records for Nuclear Power Plants A. EXCEPTION:

Subsection 5.6(3) Facility i i

The vermont Yankee plant takes exception to " structures,- doors, )

frames, and hardware should be Class A fire rated with a I recommended four hour minimum rating."  !

ALTERNATIVE: l

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" Doors, structures, frames, and hardwcre shall be designed to j comply with the requirements.of a minimum two (2) hour fire

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rating, meeting NFPA No. 232 guidelines." .I JUSTIFICATION:

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The two (2) hour rating has been endorsed by the NRC Standard Review Plan NUREG-0800, Revision 2,. dated July 1981.

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_ Appendix B, Exceptions Page: 6 of 27

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l APPENDIX B f f i

(continued) '

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( III. ANSI N45.2.10 - 1973, cuality Assurance Terms and Definitions -l f

A. EXCEPTION:

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. gubsection 2 - Terms and Definitions _

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'The 'lermont Yankee plant takes exception to the definitions of I

" Certificate of Conformance" and " Certificate of compliance".  !

I ALTERNATIVE:

-The Vermont Yankee plant shall reverse the definitions of the >

l .above terms so our Program will be in complian:e- with the implied definitions in the ASME B&PV Code and Yankee specifications. t l

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Appendix B, Exceptions Page: 7 of-27 i -l Rev.: .2 l.

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l l APPENDIX B j (continued)

I IV. Regulatory Ouide 1.5?, Revision 2, "Ouality Assurance Recuirements for I the Desien of Nuclear Power Plants" A. EXCEPTION:

Subsection c.2 i

The Vermont Yankee plant takes exception to the regulatory guide  !

position on the exclusion of supervisors performing design l verification.

ALTERNATIVE:

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The Vermont Yankee plant will continue the accepted practices for  ;

independent design verification in accordance with the provisions  !

of ANSI N45.2.11-1974, Section 6.1.

1 JUSTIFICATION:

The exclusion of line supervision to perform design verification I has proven to be an unnecessary burden on the resources within the engineering organizations of the company, and counterproductive during heightened periods of engineering activities. ANSI i N45.2.11 contains specific limitations on the situations in which a supervisor is permitted to perform design verification. The standard states, "This verification may be performed by the (

i originator's supervisor provided the supervisor did not specify a singular design approach, or rule out certain design l considerations and did not establish the design inputs used in the design, or if the supervisor is the only individual in the  ;

organization competent to perform the verification." This control l was developed through realistic evaluation of the practicable .

1 limits that restrictions impose on engineering organizations by j the working group that developed ANSI N45.2.11.

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Appendix B, Exceptions l l Page: 8 of 27

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APPENDIX B l (continued) [

t V. ANSI N45.2.2 - 1972, Packmaina. Shiocina. Receivinc. Storace & Handlina of Items for Nuclear Power Plants l A. EXCEPTION: l t

Subsection 3.7.1 & A3.7.1 - Containers The Vermont Yankee plant takes exception to the specific requirements for containers. i ALTERNATIVE:

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l Containers shall be of suitable construction to assure material is received undamaged.

1 JUSTIFICATION:

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i containers shipped by closed carrier, stored inside and not I l

1 l subjected to a wet environment do not require weather resistant j fiberboard, therefore, this is an unnecessary expense. l Additionally, numerous vendors utilize shipping containers that do  !

not comply with the specific requirements of this section, i.e.,

I flaps overlap. The acceptance criteria for a shipping container should be established based on the capability of the container to maintain the component material in a safe condition. Technology has advanced beyond the standard.

I B. EXCEPTION:

. Subsection 3.7.2 - Crates and Skids The Vermont Yankee plant takes exception to the requirement that skids and runners shall be used on boxes with a gross weight of

100 pounds or more.

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Appendix B, Exceptions Page: 9 of 27 l Rev.: 2 i

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APPENDIX B (continued)

ALTERNATIVE:

Skids or runners shall be used on boxes with a gross weight of 100 pounds or more if practical.

JUSTIFICATION:

Storage methods and container design frequently are such that runners or skids are not feasible.

C. EXCEPTION:

Subsection 5.2.1 - Shionino Damage Insoection The Vermont Yankee plant takes exception to the requirement that a preliminary visual inspection or examination be performed prior to unloading.  !

l ALTERNATIVE: i The Vermont Yankee plant shall perform those required inspections after unloading. In special instances, preunloading inspections I

shall be performed.

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JUSTIFICATION: l Post unloading inspection is adequate to determine any damage that may have been incurred during shipping and handling, i

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Appendix B, Exceptions Page: 10 of 27 l Rev.: 2

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o APPENDIX B (continued) i l D. EXCEPTION:- [

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subsection 5.2.2 - Item Tnanection 'l 1

The Vermont Yankee plant takes exception to the requirement, that- i "The inspections shall be performed in an area equivalent to the f level of storage requirements for the item." l 1

I ALTERNATIVI:

The Vermont Yankee plant shall perform receiving inspection in a manner and in an environment which do not endanger the requisite

- quality of the items however, receiving area environmental j controls may be less stringent than storage environmental controls for that item. When inspections are performed.in-receiving areas l l

with environmental controls less stringent than storage area  !

environmental controls, a time limit shall be established on a case basis for retention of items in the receiving area.

l Retention time shall be such that deterioration is prevented and applicable manufacturer recommendations are addressed.

JUSTIFICATION:

Receipt inspection activities are for a much shorter duration and therefore should not be subjected to the same stringent requirements as required for storage.

E. EXCEPTION:

Subsection 5.2.3 - Snecial Tnanection 1

The Vermont' Yankee plant takes exception to attaching special  !

i inspection procedures to the item or container,

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Appendix B,~ Exceptions l Page: 11 of 27 l

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APPENDIX B (continued)

ALTERNATIVE:

Special inspection procedures shall be readily available to personnel performing inspections.

JUSTIFICATION:

Procedures are subject to less abuse and more stringent controls when maintained on file and not attached to the item. Inspection i status is maintained by tagging and procedure control.

F. EXCEPTION:

Egbsection 6.1.2 - Levels of Storace The Vermont Yankee plant takes exception to two specific requirements associated with fuel storage (classified Level A).

ALTERNATIVE:

The Vermont Yankee plant shall meet the requirements of Level A storage for new fuel with the exception of special air filtering; and temperature and humidity controls.

JUSTIFICATION:

The existing storage conditions at the Vermont Yankee operating plant are consistent with the protection provided to the fuel while in storage at the manufacturer (vendor) and/or while in transit to the plant site and are judged to provide adequate protection to the fuel assembly structure which is of highly corrosion resistant materials. We believe that the above listed requirements are intended for application at the manufacturing facility (vendor) where the uranium pellets may be exposed to the

Title:

Appendix B, Exceptions Page: 12 of 27 l Rev.: 2

l APPENDIX B (continued) atmosphere and not in its fully encapsulated, and therefore, fully protected form in a completed fuel assembly.

G. EXCEPTION:

Aooendix A-3 Subsection A3. 5.1(1) - Caos & Pluas The Vermont Yankee plant takes exception to the requirement that nonmetallic plugs and caps shall be brightly colored.

ALTERNATIVE:

Nonmetallic plugs and caps shall be of a contrasting color.

JUSTIFICATION:

The purpose of utilizing brightly colored plugs and caps is to assist in assuring obstructions are not inadvertently placed in operating components or systems. By using plugs and caps of a contrasting color this objective can be achieved.

H. EXCEPTION:

ADoendix A-3 Subsection A3. 9 (1) - Second Group, Markinos The Vermont Yankee plant takes exception to the requirement that container markings shall appear on a minimum of two sides.

ALTERNATIVE:

Containers shall be adequately marked to provide identification and retrievability.

Title:

Appendix B, Exceptions Page: 13 of 27 l Rev.: 2

APPENDIX B (continued) gg6TIFICATION:

Containers are tagged to provide identification and inspection status. Employment of two tags on small containers adds bulk and j confusion and does not provide for better. identification or j traceability, I

I. EXCEPTION:

Annendix A-3, Subsection A. 3. 9 (4) - Second Groun, Markina The Vermont' Yankee plant takes exception to the requirement that container markings shall be no less than 3/4" high, container permitting.

ALTERNATIVE: f

. container markings shall be of a size which permits easy recognition.

JUSTIFICATION:

Markings were intended to provide identification and instructions.

The criteria should be that the markings. clearly provide the same.

J. EXCEPTION:

Annendix A-3 Subsection A.3.9(6) - Second Groun. Markina l The Vermont Yankee plant takes exception to the information required for container marking.

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Appendix B,~ Exceptions Page 14 of 27

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e ETEBHATIVE: 3 Marking shall be adequate in each case to pronde identification, 1

traceability and instructions for special handling, as applicable. .

I JUSTIFICATION: }

The-information required is excessive. Cluttering a container  :

with excessive markings only reduces the main objectives, l maintaining identification and establishing special controls. )

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APPENDIX B (continued)

VI. ANSI N45.2.6 - 1978, Qualification of Insoection, Examination and Testina Personnel for Nuclear Pcwer Plants A. EXCEPTION:

The Vermont Yankee plant takes exception to the application of the Standard to all Vermont Yankee personnel performing inspection, examination and testing.  ;

ALTERNATIVE:

Vermont Yankee personnel identified in ANSI N19.1-1971 who perform inspection, examination and testing will be qualified to ANSI N18.1-1971.

-Vermont Yankee personnel not identified in ANSI N18.1-1971 who perform inspection, examination and testing will be qualified to ANSI N45.2.6-1978.

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APPENDIX B (continued)

VII. Regulatory Guide 1.26, Rev. 3, (2/76), Quality Groun Classifications and Standards for Water , Steam- and Radioactive-Waste-Containina ComDonents of Nuclear Power Plants A. EXCEPTION: l l

Vermont Yankee takes exception to the Regulatory Guide in its l entirety.

ALTERNATIVES:

l Vermont Yankee shall continue to classify structures, systems and l components in accordance with the safety classification provisions of ANS-22, Draft No.

4, Rev. 1, May 1973, " Nuclear Safety Criteria for the Design of Stationary Boiling Water Reactor Plants," as in j l the past, with the following specific' exception: l l l l l PUEL HANDLING EQUIPMENT I

l The fuel handling equipment is presently required to be Safety l l Class 3 by paragraph 4.14.5.1 of ANS-22, but i; is original plant l l equipment (designed and manufactured before 1973) that was not l designed, fabricated, erected or tested to Safety Class 3 l l criteria. Vermont Yankee will apply the Non-Nuclear-Safety l l criteria and additional " selected requirements" of ANS-52.1-1983, j l as delineated in paragraphs 4.13.1(1), 4 .13 .1 (3 ) , 4.13.1 (4 ) , I l 4.13.4, 3.3.1.4 including subsections (h) and (j) , 3.4.5.2, and l Table 3.5, except that in lieu of NQA-1-1979, quality assurance l measures shall be applied using the requirements of ANSI N18.7- l l 1976, excluding the provisions of 5.2.13.1 and 5.2.13.2. These i

l excluded provisions address, respectively, the requirement for j suppliers to have a QA program consistent with ANSI N45.2-1971 and l .the requirement to apply ANSI N45.2.2-1972 to the packaging and l shipping of purchased material and equipment.

Titles. Appendix B, Exceptions Page: 17 of 27

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APPENDIX B l (continued)  ;

i l Supplier QA program requirements for this equipment will be: [

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l established consistent with the complexity of the item or i

l. service to be supplied; .

l adjusted according to the ability of receipt inspection to ,

l. confirm product identity and quality; and i

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' subjected to source inspection as necessary. I I

l Packaging and ship;ing will be specified to standard commercial i l practices, subject to quality control inspection for satisfactory -

l physical condition upon receipt. On-site handling and storage at -

l Vermont Yankee will satisfy ANSI N45.2.2-1972 :riteria. '

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Appendix B, Exceptions  ;

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I APPENDIX B *

(continued)

VIII.l Regulatory Guide 1.29, Rev.' 3, (9/78), Seismic Desian classification  !

A. EXCEPTION:  ;

i The Vermont Yankee plant takes exception to the application of '

Regulatory Guide 1.29, Rev. 3, (9/78).

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i ALTERNATIVES: /

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Vermont Yankee  !

The seismic design classification of structures, systems, and l

components at Vermont Yankee shall be-as defined in the Vermont 1

Yankee FSAR. ,

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Appendix B, Exceptions Page 19 of'27 l Rev.:' 2

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APPENDIX B (continued)

IX. ANSI N18 .7-1976, Administrative Controls and Ouality Assurance for the Ooerational Phase of Nuclear Power Plants A. EXCEPTION i Subsection 4.5 - Audit Procram  ;

The Vermont Yankee Plant takes exception to the requirement that audits of all safety-related functions shall be completed within a period of two (2) years.

.Alternativer Audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed at least once within a three (3) year period, based upon the results of an annual Functional Area Assessment.

The Annual Functional Area Assessment is a documented analysis of functional areas important to safety. The purpose is to identify strengths and weaknesses (if applicable) to determine the level and focus of independent oversight activities for the upcoming year. The basis for the assessment shall include the results of QA Audits and Surveillance, NRC Inspections, Event Reports, Nonconformance Reports, Corrective Action Reports, and Self-Assessments. Other indicators such as Personnel Changes, change / increase in functional area responsibilities, Industry Findings, and INPO evaluations will also be considered. Each area will be assigned a rating with a comparison to previous years.

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Appendix B, Exceptions Page 20 of 27 l Rev.: '2 l

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APPENDIX B (continued)

This assessment will be reviewed and approved by QA and Plant Management. This document is considered a QA record and will be available for NRC review.

Justification:

To utilize quality oversight resources more effectively, senior ,

management desires the flexibility to direct r sources to areas which have perceived weaknesses. The' two-year audit cycle has not ensured that the frequency, scope and associated resources are based on the risk associated with the audit area.

l Vermont Yankee proposes to adjust the audit schedule based on empirical data and performance history to complete audits of safety-related functions within a period of three years. This modification meets the intent of published regulatory requirements involving activities important to safety.

B. EXCEPTION:

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Subsection 5.2.15 - Review, Acoroval and Control of Procedures I Vermont Yankee takes exception to the following paragraph;

" Plant procedures shall be reviewed by an individual

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knowledgeable in the area affected by the procadure no less frequently than every two years to determine it changes are l necessary or desirable".

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Appendix B, Exceptions Page: 21 of 27 l Rev.: 2

APPENDIX B (continued)

Alternative Plant procedures will be periodically reviewed in accordance with administrative controls. These controls will establish a schedule for these periodic reviews. All applicable plant procedures will be reviewed following an unusual incident, unexpected transient, operator error, or equipment failure (malfunction), and following a modification to a system.

Nonroutine procedures such as Emergency Operating Procedures, Emergency Plan Implementing Procedures, or other procedures whose use may be event driven, will be reviewed every two years.

However, if a nonroutine procedure is fully exercised and there is a detailed scrutiny of the entire procedure as part of a documented training program, this may serve as the biennial review of the procedure used.

At least every two years, the Quality Assuranco (or other independent) organization shall audit a representative sample of routine plant procedures that are used more frequently than every two years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revisica program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.

Routine plant procedures that have not been used for two years will be reviewed before use to determine if changes are necessary or desirable.

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Appendix B, Exceptions Page: 22 of 27 l Rev.: 2 1

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APPENDIX B l (continued)

Justification:

The current requirement to review each safety related procedure on a biennial cycle results in the expenditure of significant technical and administrative resources. Programmatic controls and practices are in place to provide adequate reviews, including the I following:

• The plant modification processes require that procedures affected by the modification be identiflid during the design change preparation, and revised prior to closure of the  ;

modification package.

e The Operating Experience Program involves the review of USNRC, INPO, and vendor supplied informatior. for applicability and determination of further action. This review includes an evaluation of applicable documents such as procedures and the initiation of required changes.

• Administrative controls currently exist requiring that if a procedure cannot be performed as written, a procedure change must be completed prior to continuation of the procedure.

• Temporary changes are occasionally generated during, or prior to procedure use. Current administrative controls require that those changes that are permanent shall be incorporated into the procedure via the procedure revision process.

• As part of the audit and surveillance process, procedures are evaluated as to adequacy, ease of use, proper technical content, and compliance with applicable plans and programs.

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Appendix B, Exceptions Page: 23 of 27 l Rev.: 2

I l L 1 APPENDIX B 'l (continued) l l

.i l e When procedures are identified-as contributing factors for ,

j plant events, violations and nonconformiag conditions, l changes are initiated.  !

e Changes to Technical Specifications and the FSAR are reviewed for potential impact on, and initiation of changes  ;

to plant' procedures.

i e Plant procedures are approved by appropriate personnel prior >

to initial use. Current administrative controls also require pre-job briefings for procedures identified as infrequent, j This modification meets the intent of published regulatory l requirements involving activities important to safety, i

C. EXCEPTION:

Subsection 5.3.9 I

Vermont Yankee takes exception to the requirements that detail

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Emergency Procedures be in accordance with Paragraph 5.3.9. l l )

Alternative l Vermont Yankee Emergency Operating Procedures are written in )

accordance with the Symptom / Function-Based Guidelines developed by the BWR Owners Group and accepted by the NRC. These I Symptom / Function Based Procedures, mandated by the NRC in l NUREG-0737, have format and content different from the Event-1

! Oriented Emergency Procedures described in ANSI N18.7-1976.  ;

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Appendix B, Exceptions Page 24 of 27

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i APPENDIX B j (continued) -

Justifications i i

L NUREG.0737 supersedes ANSI N18.7-1976 in the. area of Emergency.

l Operating Procedures. Changes to procedure format are required in l order to develop Symptom / Function-Based Procedures. l l

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APPENDIX B (continued)

X. Reculatorv Guide 1.33, Revision 2. Quality Assurance Reauirements (ODerational)

A. FXCEPTION:

Subsection 4.5 - Audit Program The Vermont Yankca Plant takes exception to the following:

• Section 4.5 states that aall audits of safety related functions are completed within a two (2) year period".

• Paragraph 4.a. "The results of actions taken to correct deficiencies that affect nuclear safety and occur in facility equipment, structures, systems. or method of operations - shall be audited at least once per 6 months".

• Paragraph 4.b. "The conformance of facility operation to provisions contained within the technical specifications and applicable license conditions - shall be audited at least once per 12 months."

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• Paragraph 4.c. "The performance, training, and l qualifications of the facility staff - shall be audited at least once per 12 months."

Alternative:

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Audits of selected aspects of the functional areas listed above, j shall be performed within a frequency commensurate with their l safety significance and will be completed at least once within a three (3) year period, based upon the results of an annual functional area assessment.

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Appendix B, Exceptions Page: 26 of 27 l Rev.: 2

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APPENDIX B (continued) i Justifications i

i To utilize quality oversight resources more effectively, senior i management desires the flexibility to direct resources to areas f which have perceived weaknesses. The two-yearraudit cycle has not i ensured that the frequency, scope and associated resources are I based on the risk associated with the audit area.

Vermont Yankee proposes to adjust the audit schedule based on  ;

empirical data and performance history to complete audits of safety-related functions _within period of three years. This i modification meets the intent of published regulatory requirements  ;

involving activities important to safety.

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