ML20212P532

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Proposed Changes to Tech Spec Section 6,reflecting Current Reorganization to Enhance Independence of QA Organization & Making Corporate & Station Title Changes
ML20212P532
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 08/29/1986
From:
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20212P522 List:
References
NUDOCS 8609030170
Download: ML20212P532 (15)


Text

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o AITACHMElfr 1 1

Proposed Technical Specification Changes l Unit 1 8609030170 860829 PDR ADOCK 05000338 PDR

ADMINISTRATIVE CONTROLS 6.2.3 NUCLEAR SAFETY ENGINEERING (NSE)

FUNCTION 6.2.3.1 NSE shall function to examine plant operating characteristics, NRC l 1ssuances, industry advisories, Licensee Event Reports, and other sources which may indicate areas for improving plant safety.

COMPOSITION 6.2.3.2 NSE shall be composed of at least five dedicated, full-time engineers l located onsite.

RESPONSIBILITIES 6.2.3.3 NSE shall be responsible for maintaining surveillance of plant l activities to provide independent verification

  • that these activities are performed correctly and that human errors are reduced as much as practical.

6.2.3.4 NSE shall disseminate relevant operational experience.

AUTHORITY 6.2.3.5 The NSE shall make detailed recommendations for revised procedures, equipment modifications, or other means of improving plant safety to the l

Assistant Station Manager (Nuclear Safety and Licensing).

6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shift Technical Advisor shall serve in an advisory capacity to Shift Supervisor on matters pertaining to the engineering aspects of assuring safe operation of the unit.

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  • Not responsible for sign-off function.

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I j NORTH ANNA - UNIT 1 6-la

z Figure 6.2-1 Offsita Organization for Fccility M:ntg m:nt and Technicti Support -

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> EXECUTIVE .

$ VICE PRESIDENT

> POWER

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--- Communications

' SENIOR SENIOR VICE PRESIDENT VICE PRESIDENT POWER ENGINEERING &

OPERATIONS CONSTRUCTION 1

l - - _ _ _ _ _ _ _ _ _ _ _ - - - - - - - -

1 1

VICE PRESIDENT l N CLEAR l MANAGER OPERATIONS

  • MAINTENANCE EXECUTIVE

& PERFORMANCE MANAGER i g QUALITY N SERVICES g  ;  ;

- - - - ASSURANCE MANAGER NUCLEAR NUCLEAR MANAGER NUCLEAR STATION STATION NUCLEAR OPERATIONS MANAGER MANAGER PROGRAMS AND ,

. OMHAWA U NSWG MANAGER POWERTRA NING SERVICES l l QUALITY l ASSURANCE J

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______ . _ _ _ _ _ _1 _ _ _ _ _ _J l DIRECTOR l

NUCLEAR l l _

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^ DIRECTOR '

DIRECTOR ^ ^

l DIRECTOR OPERATIONS & ADMINISTRATIVE flEALTH PHYSICS MAINTENANCE ^ '

l SERVICES PLANNING AND CONTROL SUPPORT i

SUPERINTENDENT NUCLEAR  !

TRAINING . Responsible for Corporate Fire Protection Program

Figurs 6.2-2 Facility Org;niz: tion - North Anna - Units 1 end 2 .

VICE PRESIDENT MANAGER NUCLEAR EXECUTIVE 2 MAINTENANCE & OPERATIONS MANAGER PERFORMANCE QUALITY g SERVICES ASSURANCE I I

> MANAGER

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y POWER TRAINING STAT 60N NUCLEAR

_ _ , _ _ STATION MANAGER MANAGER

, SERVICES SAFETY & OPER OUAUTY C l COMMITTEE ASSURANCE DIRECTOR NUCL E AR SUPERVISORS TRAINING QUALITY

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ASSISTANT ASSISTANT DIRECTOR STATION STATION NUCLEAR MANAGER MANAGER SECURITY (O & M) (NS & L) l I I 1 SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT SUPERINTENDENT NUCL E AR SUPERINTENDENT OPERATIONS MAINTENANCE TECHNICAL TRAINING SL PROJECTS EERVICEC

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I I I I SUPERVISOR SHIFT SUPERVISOR SUPERVISOR LICENSING SUPERVISOR COORDINATOR' SUPERINTENDENT SUPERVISOR (PLANNING & SUPERVISOR _ MECHANICAL ., CHEMISTRY _ COOfsDINATOR SAFETY EMERGENCY HEALTH ADMIN SUPPORT MAINTENANCE ENGINEERING- PLANNING PHYSICS

, SERVICES SERVICES) SL NUCLEAR I

ASST. SHIFT ELECTRICAL INSTRUMENT SUPERVISOR SHIFT SUPERVISOR BUSINESS SUPERVISOR _ SUPERVISOR _ SUPERVISOR __ INSPECTION TECHNICAL RECORDS SYSTEMS TESTS ADVISORS MANAGEMENT SUPERVISORS SL CONTROL RM SUPERVISOR SUPERVISOR SAFETY SUPERVISOR OPERATOR MAINTENANCE SURVEILLANCE COORDINATOR-- PERSONNEL 1 SERVICES AND TEST SERVICES OL ENGINEERING SL - Sensor License OL - Operator's Lcens*

CONTROL RM SUPERVISOR --- communmanons LOSS STATION OPERATOR / ._ PLANT -

PREVENTION - - - -

SECURtTY TRAINEE ENGINEERING COORDINATOR SUPERVISOR

ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANS 3.1-(12/79 Draft) for comparable positions and the supplemental requirements specified in the March 28, 1980 NRC letter to all licensees, except for (1) the Superintendent - Health Physics who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the Shif t Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

6.4 TRAINING 6.4.1 The Station Manager is responsible for ensuring that retraining and replacement training programs for the facility staff are maintained and that such programs meet or exceed the requirements and recommendations of Section 5 of ANS 3.1-(12/79 Draft) and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in the March 28, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry operational experience identified by the NSE.

6.5 REVIEW AND AUDIT 6.5.1 STATION NUCLEAR SAFETY AND OPERATING COMMITTEE (SNSOC)

FUNCTION 6.5.1.1 The SNSOC shall function to advise the Station Manager on all matters related to nuclear safety.

COMPOSITION 6.5.1.2. The SNSOC shall be composed of the:

Chairman: Assistant Station Manager (Nuclear Safety and Licensing)

Vice Chairman: Assistant Station Manager (Operations and Maintenance)

Member: Superintendent-Operations Member: Superintendent-Maintenance Member: Superintendent-Technical Services Member: Superintendent-Health Physics ALTERNATES 6.5.1.3 All alternate member shall be appointed in writing by the SNSOC Chairman to serve on a temporary basis; however, no more than one alternate shall participate as a voting member in SNSOC activities at any one time.

NORTH ANNA - UNIT 1 6-5

ADMINISTRATIVE CONTROLS

m. The PROCESS CONTROL PROGRAM and implementing procedures for process-ing and packaging of radioactive vastes at least once per 24 months.
n. The performance of activities required by the Quality Assurance -1 Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

AUTHORITY 6.5.3.2 The Quality Assurance Department shall report to and advise the Executive Manager-Quality Assurance, who shall advise the Senior Vice President-Engineering and Construction on those areas of responsibility l specified in Section 6.5.3.1.

RECORDS 6.5.3.3 Records of the Quality Assurance Department audits shall be prepared and maintained in the department files. Audit reports shall be disseminated as indicated below:

1. Vice President-Nuclear Operations
2. Nuclear Power Station Manager *
3. Manager-Nuclear Operations Support
4. Manager-Nuclear Programs and Licensing
5. Executive Manager-Quality Assurance
6. Director-Safety Evaluation and Control
7. Nuclear Power Station Manager Quality Assurance
8. Supervisor (s) of Area Audited NORTH ANNA - UNIT 1 6-11

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ATTACIDiENT 2 Proposed Technical Specification Changes Unit 2

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I ADMINISTRATIVE CONTROLS i

i 6.2.3 NUCLEAR SAFETY ENGINEERING (NSE) ,

l FUNCTION 6.2.3.1 NSE shall function to examine plant operating characteristics, NRC l issuances, industry advisories, Licensee Event Reports, and other sources which may indicate area for improving plant safety.

COMPOSITION 5.2.3.2 NSE Shall be composed of at least five dedicated, full-time engineers l located onsite.

RESPONSIBILITIES 6.2.3.3 NSE shall be responsible for maintaining surveillance of plant activities to provide independent verification

  • that these activities are l

performed correctly and that human errors are reduced as_much as practical.

6.2.3.4 NSE shall disseminate relevant operational experience. f AUTHORITY ,

6.2.3.5 NSE shall make detailed recommendations for revised procedures, l equipment modifications, or other means of improving plant safety to the Assistant Station Manager (Nuclear Safety and Licensing). .

6.2.4 SHIFT TECHNICAL ADVISOR 6.2.4.1 The Shif t Technical Advisor shall serve in an advisory capacity to Shift Supervisor on matters pertaining to the engineering aspects of assuring safe operation of the unit.

  • Not responsible for sign-off function.

NORTH ANNA-UNIT 2 6-la

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z Figure 6.2-1 Offsita Organization for Facility M:ntg: ment and Technical Support o .

2

> EXECUTIVE .

$ VICE PRESIDENT

> POWER C

--- communications

" SENIOR SEis:OR

, VICE PRESIDENT VICE PRESIDENT POWER ENGINEERING &

OPERATIONS CONSTRUCTION VICE PRESIDENT MANAGER NUCLEAR MAINTENANCE OPERATIONS EXECUTIVE

& PERFORMANCE MANAGER l

SERVICES QUALITY 7

w -- l l ASSURANCE MANAGER NUCLEAR NUCLEAR MANAGER -

NUCLEAR STATION STATION NUCLEAR OPERATIONS MANAGER MANAGER. PROGRAMS AND SUPPORT SURRY . NORTH ANNA LICENSING POWERTRA NING MANAGER SERVICES l l OUALITY ASSURANCE I I DIRECTOR NUCLEAR l l_ _ _ _ _ _ _1 _ _ _ _ _ _]

l l l TRAINING l ~ DIRECTOR DIRECTOR l DIRECTOR OPERATIONS &

ADMINISTRATIVE

^ ^

HEALTH PHYSICS MAINTENANCE SERVICES

^ ^'

- l SUPPORT PLANNING AND CONTROL

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SUPERINTENDENT NUCLEAR  !

TRAINING . Responsible for Corporate Fire Protection Program

Figura 6.2-2 F Cility Org nintion - North Anna - Units 1 cnd 2 ,

VICE PRES DENT ,

MANAGER NUCLEAR Z EXECUTIVE MAINTENANCE & OPERATIONS MANAGER O PERFORMANCE QUALITY k

I SERVICES ASSURANCE I

> MANAGER -------------

POWER STATION _ _ _ _ _ _ STATION y TRAINING NUCLEAR MANAGER MANAGER SERVICES SAFETY & OPER OUALITY

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l COMMITTEE ASSURANCE z i q DIRECTOR NUCLEAR SUPERVISORS N TRAINING OUALITY g

ASSISTANT ASSISTANT DIRECTOR STATION STATION NUCLEAR MANAGER MANAGER SECURITY (O & M) (NS & L)

I I I i SUPERIN1ENDENT SUPERINTENDENT SUPERINTENDENT SUPERINTEf4 DENT NUCLEAR SUPERINTENDENT OPERATIONS MAINTENANCE TECHNICAL TRAINING SL PROJECTS SERVICES i

o I i I 1 SUPERVISOR SHIFT SUPERVISOR SUPERVISOR LICENSING SUPERVISOR COORDINATOR SUPERINTENDENT SUPERVISOR l PLANNING & SUPERVISOR MECHANICAL CHEMISTRY COORDINATOR SAFETY EMERGENCY HEALTH

_ _ _ ADMIN SUPPORT MAINTENANCE ENGINEERING - PLANNING

, PHYSICS SERVICES SERVICES) SL NUCLEAR ASST. SHIFT ELECTRICAL INSTRUMENT SUPERVISOU SHIFT SUPERVISOR BUSINESS SUPERVISOR SUPERVISOR SUPERVISOR INSPECTION TECHNICAL RECORDS SY9TEMS .

TESTS ADVISORS MANAGEMENT SUPERVISORS SL CONTROL RM SUPERVISOR SUPERVISOR SAFETY SUPERVISOR OPERATOR MAINTENANCE SURVEILLANCE COORDINATOR

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PERSONNEL SERVICES AND TEST SERVICES OL ENGINEERING SL - senior Lcense OL - Operator's License CONTROL RM SUPERVISOR --- Communcations LOSS STATION OPERATOR / PLANT -

PREVENTION ----

SECURITY TRAINEE ENGINE'ERING COORDINATOR SUPERVISOR

ADMINISTRATIVE CONTROLS 6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANS 3.1 (12/79 Draft) for comparable positions and the supplemental requirements specified in the March 28, 1980 NRC letter to all licensees, except for (1) the Superintendent - Health Physics who shall meet l or exceed the qualifications of Regulatory Guide 1.8, September 1975 and (2) the shift Technical Advisor who shall have a bachelor's degree or equivalent in a scientific or engineering discipline with specific training in plant design, and response and analysis of the plant for transients and accidents.

6.4 TRAINING 6.4.1 The Station Manager is responsible for ensuring that retraining and replacement training programs for the facility staff are maintained and that such programs meet or exceed the requirements and recommendations of Section 5 of ANS 3.1 (12/79 Draft) and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in the March 29, 1980 NRC letter to all licensees, and shall include familiarization with relevant industry operational experience identified by the NSE.

6.5 REVIEW AND AUDIT 6.5.1 STATION NUCLEAR SAFETY AND OPERATING COMMITTEE (SNSOC)

FUNCTION 6.5.1.1 The SNSOC shall function to advise the Station Manager on all matters related to nuclear safety.

COMPOSITION 6.5.1.2 The SNSOC shall be composed of the:

Chairman: Assistant Station Manager (Nuclear Safety and Licensing)

Vice Chairman: Assistant Station Manager (Operations and Maintenance)

Member: Superintendent-Operations Member: Superintendent-Maintenance Member: Superintendent-Technical Services Member: Superintendent-Health Physics ALTERNATES 6.5.1.3 All alternate members shall be appointed in writing by the SNSOC Chairman to serve on a temporary basis; however, no more than one alternate shall participate as a voting member in SNSOC activities at any one time.

NORTH ANNA-UNIT 2 6-6

ADMINISTRATIVE CONTROLS

k. The radiological environmental monitoring program and the results thereof at least once per 12 months.
1. The OFFSITE DOSE CALCULATION MANUAL and implementing procedures at leas *. once per 24 months.
m. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.
n. The performance of activities required by the Quality Assurance Program to meet the provisions of Regulatory Guide 1.21, Revision 1, June 1974, and Regulatory Guide 4.1, Revision 1, April 1975 at least once per 12 months.

AUTHORITY 6.5.3.2 The Quality Assurance Department shall report to and advise the Executive Manager-Quality Assurance, who shall advise the Senior Vice President-Engineering and Constructions on those areas of responsibility l specified in Section 6.5.3.1 RECORDS 6.5.3.3 Records of the Quality Aseurance Department audits shall be prepared and maintained in the department files. Audit reports shall be disseminated as indicated below:

1. Vice President-Nuclear Operations
2. Nuclear Power Station Manager
3. Manager-Nuclear Operations Support
4. Manager-Nuclear Programs & Licensing
5. Executive Manager-Quality Assurance
6. Director-Safety Evaluation and Control
7. Nuclear Power Station Manager-Quality Assurance
8. Supervisor (s) of Area Audited.

NORTH ANNA - UNIT 2 6-12

. 1 AITACHMENT 3 Discussion of Proposed Changes I

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, DISCUSSION OF PROPOSED CHANGE The proposed amendment would modify Section 6, Administrative Controls, of the

North Anna Unit I and 2 Technical Specifications to:

(1) reflect a recent company reorganization in which the Quality As-surance organization will now report to the Senior Vice President

-Engineering and Construction, instead of the Senior Vice President

, -Power Operations, (2) change the title of the QC Supervisors reporting to the Manager, QA i from " Supervisors - Quality Control - Q.A. Activities" to "Supervi-sors - Quality,"

(3) change the title of " Supervisor Health Physics" to " Superintendent

- Health Physics,"

(4) change the title of " Director - Emergency Planning" to " Supervisor -

Corporate Emergency Planning", and (5) change the facility organization chart to reflect the recent admini-strative title changes

! The major emphasis of the company's nuclear program is on operations rather

than construction, it is approporate that the QA organization be realigned with construction. The first change is intended to enhance independence of the QA Organization. The remaining changes are purely administrative in
nature involving changes in nomenclature as well as a change to achieve
consistency with our NRC approved QA Topical Report.

10 CFR 50.92 Significant Hazards Review:

I The proposed amendment does not involve a significant hazards consideration because operation of North Anna Units 1 and 2 in accordance with this change would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated. The change of reporting for the QA organization will continue to assure adequate independence of QA from the line organizations responsible for the company's nuclear program. The remaining changes are purely administrative in nature as described above. Thus the change does not affect plant operations and would not result in a significant increase in the probability of consequences of an accident previously evaluated.

(2) create the posibility of a new or different kind of accident from any accident previously analyzed. The change does not involve any changes to plant systems or equipment and therefore would not create the possibility of a new or different type of accident.

(3) involve a significant reduction in a margin of safety. The change does not involve a change to the Technical Specifications Bases or

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to the results of accidents evaluated in the Updated Final Safety Analyses Report.. Thus the change does not involved a significant reduction in a margin of safety.

Further, the Commission has provided guidance concerning the application of the standards for determining whether a significant hazards consideration exists by providing examples (Federal Register, Page 14870, April 6, 1984) of amendments that are considered not likely to involve a significant hazards consideration. This proposed change corresponds to example (1); a purely administrative charge to the Technical Specifications... The changes reflect the current reorganization in the Quality Assurance Organization, to provide more emphasis on construction rather than operations and achieve consistency with the NRC approved Q. A. Topical Report, and to make administrative title changes to corporate and station organizations. Based on the above, we conclude that the proposed changes do not involve a significant hazards consideration.

10 CFR 50.59 Safety Review In accordance with the provisions of the Code of Federal Regulations, specifically 10 CFR ' 50.59 " Changes, Tests and Experiments", the proposed changes to North Anna Power Station Technical Specifications (Units 1 & 2) have been evaluated and the following conclusions determined:

1. The proposed changes do not increase the probability of occurence or the consequences of an accident or malfunction of equipment pre-viously evaluated in the safety analysis report; and
2. The proposed changes do not increase the possibility for an accident or malfunctions of a different type than any evaluated previously in the safety analysis report; and
3. The proposed changes do not reduce the margin of safety as defined in the basis for any technical specification.

These conclusions were formulated in the consideration that the proposed changes to the technical specifications are of an administrative nature, do not affect the operating organization and reflect changes already reviewed and approved by the Nuclear Regulatory Commission (ANSI /ANS Standard commitments).

Therefore, it is determined that no unreviewed safety question exists for the referenced changes.

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