ML20249B163

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Proposed Tech Specs Re Relocation of Safety Review Committee Review & Audit Requirements
ML20249B163
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 06/16/1998
From:
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:
Shared Package
ML20249B148 List:
References
AL-95-06, AL-95-6, NUDOCS 9806220125
Download: ML20249B163 (23)
v • d • e


Text

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l ATTACHMENT I TO JPN-98-026 l

PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS (JPTS-98-001)

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l NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59 1

9906220125 990616

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JAFNPP l

QUORUM 6.5.2.7 A quorum shall consist of at least a majority of the appointed individuals (or their alternates) and the Chairman (or the designated alternate). No more than two i

alternates may participate as SRC voting members at any one time. No more than a minority of the quorum shall have direct line responsibility for the operation of the plant.

REVIEW 6.5.2.8 The SRC shall review facility activities in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR.

I AUDIT 6.5.2.9 Audits of facility activities shall be performed under the cognizance of the SRC and in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR.

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l Amendment No. 50,00, SS,100,110,220,240, 252 l

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JAFNPP AUTHORITY 6.5.2.10 The SRC shall advise the Chief Nuclear Officer on those areas of responsibility specified in Section 6.5.2.8 and 6.5.2.9.

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Amendment No. 50, SO, SS, 78, 03, 04, 220, 222, 226, 252a i

JAFNPP RECORDS 6.5.2.11 Records will be maintained in accordance with ANSI 18.7-1972. The foilowing shall be prepared and distributed as indicated below:

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a. Minutes of each SRC meeting shall be prepared and forwarded to the Chief Nuclear Officer within 30 days after the date of the meeting.
b. Reports of reviews encompassed by Section 6.5.2.8 above shall be processed in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR.
c. Audit reports encompassed by Section 6.5.2.9 above, shall be processed in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR.

1 Amendment No. 03, 202, 220, 228, 252b l

ATTACHMENT ll TO JPN-98-026 I

SAFETY EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS (JPTS-98-001) l NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59

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Attachment il JPN-98-026 Page 1 of 4 SAFETY EVALUATION RELATED TO PROPOSED TECHNICA L SPECIFICATION CHANGES REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS Section 1 - Description of Changes This application for amendment seeks to revise Section 6 of Appendix A of the James A.

FitzPatrick Technical Specifications. These changes relocate the Safety Review Committee (SRC) review, audit, and related record keeping requirements from the Technical Specifications (TS) to Chapter 17 of the Final Safety Analysis Report (FSAR) (i.e., Quality Assurance Program). The relocation of these requirements is in accordance with the guidance contained in Administrative Letter 95-06. The following is a list detailing the revisions.

1. Technical Specification oages 252 and 252a Replace 6.5.2.8 with:

"The SRC shall review facility activities in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR."

Delete 6.5.2.8.a through 6.5.2.8.j.

Replace 6.5.2.9 with:

" Audits of facility activities shall be performed under the cognizance of the SRC and in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR."

Delete 6.5.2.9.a through 6.5.2.9.l.

2. Technical Specification oaae 252b Replace 6.5.2.11.b with:
  • Reports of reviews encompassed by Section 6.5.2.8 above shall be processed in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR."

Replace 6.5.2.11.c with:

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" Audit reports encompassed by Section 6.5.2.9 above, shall be processed in I

accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR."

Section ll-Purpose of Proposed Chanaes The proposed changes relocate the SRC review, audit, and related record keeping requirements from the TS to the FSAR. This allows changes to these requirements to be controlled by the 10 1

. 1 JPN-93-026 Page 2 of 4 CFR 50.54(a) process, rather than the TS amendment process. As stated in Administrative Letter 95-06, the relocation of TS requirements in cases such as this where adequate controls nre provided by other methods (i.e.,10 CFR 50.54(a), commitments to ANSI N18.7-1972, and 10 CFR 50, Appendix B) can reduce the resources spent by licensees and the NRC staff in preparing and reviewing license amendment requests.

1 Section 111 - Safety lmolications of the Proposed Chanaes Administrative Letter 95-06 (Reference 1) was issued by the NRC staff to provide information to I

licensees regarding the relocation of technical specification administrative controls related to Quality Assurance from the TS to the Quality Assurance Plan. In this letter, TS requirements related to the completion of SRC reviews, audits, and record keeping were specifically targeted for relocation.

Sections 6.5.2.6,6.5.2.9,6.5.11.b, and 6.5.11.c of the current JAF TS contain the requirements for SRC reviews, audits, and related record keeping. In accordance with the guidance found in l

Reference 1, this application removes these requirements from the TS and adds them to the Quality Assurance Program, found in Chapter 17 of the FSAR. Sections 6.5.2.8,6.5.2.9, 6.5.11.b, and 6.5.11.c of the TS still contain the requirements for SRC ta perform reviews and audits, and maintain records. However, these sections now state that the specific requirements for these functions, such as the areas to be reviewed / audited and the frequency of audits, are found in the FSAR.

A new section, Appendix E, was created in Chapter 17.2 (i.e., Quality Assurance Program) of the FSAR to include the relocated requirements. The text was reformatted to eliminate TS sections which referenced deleted material, but no changes were made to the actual requirements related to the reviews, audits, and record keeping. The Quality Assurance Program is a logical choice for the relocation of these requirements, as it is governed by controls such as Appendix B of 10 CFR Part 50, commitments to ANSI N18.7-1972, and the 10 CFR 50.54(a) change control process. Any future changes to these requirements which constitute a reduction in QA Program commitments must be submitted to the NRC for prior approval, in accordance with 10 CFR 50.54(a).

The relocat:on of the SRC review, audit, and record keeping requirements from the TS to the FSAR does not alter any existing requirements. These sections are being removed from the TS and relocated into the FSAR without any revisions to the areas, frequency or record keeping requirements associated with reviews and audits. Therefore, this amendment request is administrative in nature.

1 Section IV - Evaluation of No Significant Hanrds Consideration Consistent with the criteria of 10 CFR 50.92, the enclosed application is judged to involve no significant hazards based on the following information:

(1) Does the proposed license amendment involve a significant increase in the probability or consequences of an accident previously analyzed?

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Attachment ll JPN-98-026 Page 3 of 4

Response

This amendment application does not involve a significant increase in the probability or consequences of an accident previously analyzed. The relocation of the SRC review, audit, and related record keeping requirements from the TS to the FSAR does not alter the

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performance or frequency of these activities. Future changes to the QA program, located in Chapter 17 of the FSAR, which constitute a reduction in commitments, are governed by 10 CFR 50.54(a). Therefore, sufficient controls for these requirements exist and these changes do not involve a significant increase in the probability or consequences of an accident previously analyzed.

(2) Does the proposed license amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response

This amendment application does not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed changes involve the relocation of SRC requirements from the TS to the FSAR. Relocation of these seguirements does not affect plant equipment or the way the plant operates. The reviews, audits, and record keeping will continue to be performed in the identical manner as they are currently being performed. Therefore, the proposed revisions cannot create a new or different kind of accident.

(3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response

This amendment applitmtion does not involve a significant reduction in a margin of safety.

l The requested Teche '.al Specification revisions relocate SRC review, audit and related record keeping requirements from the TS to the FSAR. These requirements are not being altered by this relocation. The reviews, audits, and record keeping will continue to be performed in the identical manner as they are currently being performed. Any changes to i

these requirements which constitute a reduction in commitments will be processed in accordance with 10 CFR 50.54(a). Therefore, the proposed changes do not involve a significant reduction in a margin of safety, i

Section V -Implementation of the Proposed Channes i

This amendment request meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) as follows:

(i) the amendment involves no significant hazards consideration.

As demonstrated in Section IV of this evaluation, the proposed change involves no significant hazards consideration.

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Attachment ll JPN-98-026 Page 4 of 4 (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes do not involve a physical alteration to the plant or revisions to any plant operating procedures. The changes are administrative in nature and do not affect the amounts of any effluents that may be released offsite.

(iii) there is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not alter plant operating or sunteillance procedures, and therefore will not change individual or cumulative occupational radiation exposure.

Based on the above, it is concluded that there will be no impact on the environment resulting from the proposed changes and the proposed changes meet the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10 CFR 51.21 relative to requiring a specific environmental assessment by the Commission. Additionally, implementation of the proposed changes will not adversely alter or affect the ALARA program or the Fire Protection Program.

l Section VI - Conclusion Based upon the discussion in previous sections, the relocation of the SRC review, audit, and related record keeping requirements does not alter the performance of these activities and will not decrease the effectiveness of the review and audit process.

The Plant Operating Review Committee (PORC) and SRC have reviewed these proposed changes and have concluded that the changes do not involve an unreviewed safety question or a significant hazards consideration as defined in 10 CFR 50.92, and do not endanger the health and safety of the public.

Section Vil - References 1.

NRC letter, Administrative Letter 95-06, " Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12,1995.

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4 ATTACHMENT lil TO JPN-98-026 MARK-UP OF TECHNICAL SPECIFICATION PAGES REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS (JPTS-98-001)

(For Information Only)

NOTE 1: Deletions are shown in strlkcout, and additions are shown in bold.

NOTE 2: Previous amendment revision bars are not shown.

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l' NEW YORK POWER AUTHORITY JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50-333 DPR-59 l

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QUORUM 6.5.2'.7 A quorum shall consist of at least a majority of the appointed individuals (or their alternates) and the Chairman (or the designated alternate). No more than two alternates may participate as SRC voting members at any one time. No more than a minority of the quorum shall have direct line responsibility for the operation of the plant.

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AUTHORITY 6.5.2.10 The SRC shall advise the Chief Nuclear Officer on those areas of responsibility j

specified in Section 6.5.2.8 and 6.5.2.9.

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O JAFNPP RECORDS 6.5.2.11 Records will be maintained in accordance with ANSI 18.7-1972. The following shall be prepared and distributed as indicated below;

a. Minutes of each SRC meeting shall be prepared and forwarded to the Chief Nuclear Officer within 30 days after the date of the meeting.
b. Reports of reviews encompassed by Section 6.5.2.8 above shall be prcpared and ic;;;;rded to th; Ohici Nuclc;r 0";ccr v;; thin 30 d;ys fcCc;;;ng comp lction of the review-processed in accordance with the Quality Assurance Program, as described in Chapter 17 of the JAF FSAR.
c. Audit reports encompassed by Section 6.5.2.9 above, shall be forwarded 4e-the Ghtef-Nuclcor O";ccr and to the rnanagement poslticas rcapenslblc for the arcas auditcd vaithln 30 day; a'tcr comp lction of th; sudet processed in accordance with the Quclity Assurance Program, as described in Chapter 17 of the JAF FSAR.

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l Amendment No, 03,202,220,298, 252b

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O ATTACHMENT IV TO JPN-98-026 DESCRIPTION OF PROPOSED CHANGES TO THE QUALITY ASSURANCE PROGRAM REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS i

l NEW YORK POWER AUTHORITY JAMES A FITZPATRICK POWEP PLANT DOCKET NO. 50-333 DPR-59

Attachment IV JPN-98-026 Page 1 of 1 DESCRIPTION OF PROPOSED CHANGES TO THE QUALITY ASSURANCE PROGRAM REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS The relocation of the SRC review, audit, and related record keeping requirements from the TS to the QA Program results in changes to FSAR Section 17.2. Specifically, Appendix 17.2.E was created to include these requirements and a sentence was added to section 17.2.18 to refer to

. the new Appendix. These revisions to the QA Program are contained in Attachments V and VI.

The relocated requirements were removed from the TS, reformatted, and placed directly in the FSAR without any change to the required reviews, audits, or related record keeping. Therefore, in accordance with 10 CFR 50.54(a), these changes do not constitute a reduction in the QA Program commitments, but are administrative changes which follow the guidance found in Administrative Letter 95-06.

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ATTACHMENT V TO JPN-98-026 l

PROPOSED CHANGES TO THE QUALITY ASSURANCE PROGRAM REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS 1

l i

l-1 NEW YORK POWER AUTHORITY JAMES A FITZPATRICK POWER PLANT DOCKET NO. 50-333 DPR-59 l

JAF FSAR UPDATE periodic audits to be carried out by the Authority Quality Assurance organization to verify compliance with all aspects of the program. This audit system provides data for a continuing evaluation of the effectiveness of the program, in addition, surveillance audits are conducted routinely on an unscheduled basis of ongoing or day-to-day activities to verify satisfactory completion of the activity.

The Authority will perform planned and periodic audits of delegated organizations to verify program implementations in accordance with appropriate QA program requirements.

Specific program areas are subsequently audited, consistent with the project schedule or where quality concerns are noted, so that the total program is reaudited within a scheduled

)

period of time. The required reviews, audits, and related record keeping requirements are listed in Section 17.2, Appendix E.

Audits are performed in accordance with pre-established procedures, checklists, etc., and conducted by trained personnel not having direct responsibilities in the areas being audited.

The Authority's audit program requires audit results to be documented, reviewed by or with management responsible for the area audited, and appropriate action initiated to correct any deficiencies. The organization conducting the audit is responsible for conducting the i

follow-up actions including reaudit of deficient areas to assure correction of the

{

discrepancies. Results of audits are summarized in audit reports which are reviewed by Quality Assurance.

The Authority's audit program, as defined in the Authority's Quality Assurance Program, includes the following types of audits to provide a comprehensive, independent verification and evaluation of all quality related procedures and activities to assure they are in compliance with the Authotity's established program requirements:

1.

Audits of delegated organizations 2.

Audits of selected vendors and contractors 3.

Audits of plant operation activities 4.

Audits internal to the Authority Independently, or concurrent with the audits and inspections by delegated organizations, the Authority may conduct audits of vendors and contractors such as equipment fabricators, material suppliers, consultants and various contractors working on plant activities.

17.2.18.2 Authority Centrols The Director-QA, based on his review, reports audit findings and the actions to be taken to correct the deficient conditions to the VP-A&CS. These rgorts also serve as a 17.2-31 Rev.

I I

I

____________U

g JAF FSAR UPDATE Appendix E QA Reviews and Audits 17.2E.1 REVIEW The SRC shall review:

The safety evaluations for 1) changes to procedures, equipment or systems a.

and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.

b.

Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10 CFR.

c.

Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59,10 CFR.

d.

Proposed changes to Technical Specifications of this Operating License.

e.

Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.

f.

Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

I g.

All Reportable Events.

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems, or components.

l.

Reports and meetings minutes of the Plant Cl,erating Review Committee.

j Plant staff performance.

17.2E.2 AUDITS The following audits shall be performed under the cognizance of the SRC.

a.

The conformar.ce of facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 rnonths.

17.2E-1 Rev.

__u

JAF FSAR UPDATE b.

The training and qualifications of the entire facility staff at least once per 12 months.

c.

The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.

d.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 10 CFR 50, at least once per 24 months.

e.

Any other area of facility operation considered appropriate by the SRC or the Chief Nuclear Officer.

f.

The Facility Fire Protection Program and implementing procedures at least once per two years, g.

An independent fire protection and loss of prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

h.

An inspectie - ;nd audit of the fire protection and loss prevention program shall be p.

ed by an outside qualified fire consultant at intervals no greater tt J years.

i.

The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.

j.

The Offsite Dose Calculation Manual and implementing procedures at least i

once per 24 months.

j k.

The Process Control Program and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

l.

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.

17.2E.3 RECORDS a.

Reports of the reviews encompassed by 17.2E.1 shall be prepared and forwarded to the Chief Nuclear Officer within 30 days following completion l

of the review.

l b.

Audit reports encompassed by 17.2E.2 shall be forwarded to the Chief Nuclear Officer and to the management positions responsible for the areas audited within 30 days after the completion of the audit.

17.2E-2 Rev.

e

ATTACHMENT VI TO JPN-98-026 MARKUP OF PROPOSED CHANGES TO THE QUALITY ASSURANCE PROGRAM REGARDING THE RELOCATION OF THE SRC REVIEW AND AUDIT REQUIREMENTS (For Information Only) l l

l p

L NEW YORK POWER AUTHORITY JAMES A FITZPATRICK POWER PLANT DOCKET NO. 50-333 DPR-59 i '

i 1

JAF FSAR UPDATE l

periodic audits to be carried out by the Authority Quality Assurance organization to verify compliance with all aspects of the program. This audit system provides data for a 3

continuing evaluation of the effectiveness of the program. In addition, surveillance audits are conducted routinely on an unscheduled basis of ongoing or day-to-day activities to verify satisfactory completion of the activity.

The Authority will perform planned and periodic audits of delegated organizations to verify program implementations in accordance w;th appropriate QA program requirements.

Specific program areas are subsequently audited, consistent with the project schedule or where quality concerns are noted, so that the total program is reaudited within a scheduled l

period of time. The required reviews, audits, and related record keeping requirements are l

listed in Section 17.2, Appendix E.

Audits are performed in accordance with pre-established procedures, checklists, etc., and conducted by trained personnel not having direct responsibilities in the areas being audited.

The Authority's audit program requires audit results to be documented, reviewed by or with management responsible for the area audited, and appropriate action initiated to correct any deficiencies. The organization conducting the audit is responsible for conducting the follow-up actions including reaudit of deficient areas to assure correction of the discrepancies. Results of audits are summarized in audit reports which are reviewed by j

.' Quality Assurance.

l r

)

The Authority's audit program, as defined in the Authority's Quality Assurance Program, includes the following types of audits to provide a comprehensive, independent verification j

and evaluation of all quality related procedures and activities to assure they are in compliance with the Authority's established program requirements:

I 1.

Audits of delegated organizations 2.

Audits of selected vendors and contractors 3.

Audits of plant operation activities 4.

Audits internal to the Authority Independently, or concurrent with the audits and inspections by delegated organizations, the Authority may conduct audits of vendors and contractors such as equipment

' fabricators, material suppliers, consultants and various contractors working on plant ar.tivities.

17.2.18.2 Authoritv Controls The Director-QA, based on his review, reports audit findings and the actions to be taken to correct the deficient conditions to the VP-A&CS. These reports also serve as a

(

17.2-31 Rev.

L

JAF FSAR UPDATE Aopendix E QA Reviews and Audits 17.2E.1 REVIEW The SRC shall review:

The safety evaluations for 1) changes to procedures, equipment or systems a.

and 2) tests or experiments completed under the provision of Section 50.59, L-10 CFR, to verify that such actions did not constitute an unreviewed safety l

question, b.

Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59,10 CFR.

c.

Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59,10 CFR.

d.

Proposed changes to Technical Specifications of this Operating License.

Violations of codes, regulations, orders, Technical Specifications, license e.

requirements, or of internal procedures or instructions having nuclear safety significance.

f.

Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.

l g.

All Reportable Events.

l j.

h.

All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety related structures, systems, or components.

i.

Reports and meetings minutes of the Plant Operating Review Committee.

1' J.

Plant staff performance.

p l

17.2E.2 AUDITS The following audits shall be performed under the cognizance of the SRC.

1 a.

The conformance of facility operation to provisions contained within the l

Technical Specifications and applicable license conditions at least once per 12 months.

17.2E-1 Rev.

L

=

JAF FSAR UPDATE b.

The training.?nd qualifications of the entire facility staff at least once per 12 months.

The results of actions taken to correct deficiencies occurring in facility c.

equipment, structures, systems or method of operation that affect nuclear safety at least once per 6 months.

d.

The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix "B," 10 CFR 50, at least once per 24 months.

Any other area of facility operation considered appropriate by the SRC or the e.-

Chief Nuclear Officer.

f.

The Facility Fire Protection Program and implementing procedures at least once per two years.

g.

An independent fire protection and loss of prevention inspection and audit shall be performed annually utilizing either qualified offsite licensee personnel or an outside fire protection firm.

i 1

h.

An inspection and audit of the fire protection and loss prevention program shall be performed by an outside qualified fire consultant at intervals no greater than 3 years.

I 1.

The Radiological Environmental Monitoring Program and the results thereof at least once per 12 months.

J.

The Offsite Dose Calculation Manual and implementing procedures at least once per 24 months.

k.

The Process Control Program and implementing procedures for processing and packaging of radioactive wastes at least once per 24 months.

l 1.

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.

~ 17.2E.3 RECORDS a.

Reports of the reviews encompassed by 17.2E.1 shall be prepared and forwarded to the Chief Nuclear Officer within 30 days following completion of the review.

b.

Audit reports encompassed by 17.2E.2 shall be forwarded to the Chief

' Nuclear Officer and to the management positions responsible for the areas audited within 30 days after the completion of the audit.

17.2E-2 Rev.

l l

L___________________.___

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