NG-95-0538, Request for TS Change (RTS-275) to License DPR-49,deleting Audit Frequency Requirements from TS Sections 6.5.2.8 & 6.5.3.1.Requirements Being Added to QA Program Description Located in Updated Fsar,Section 17.2.18.2.2

Request for TS Change (RTS-275) to License DPR-49,deleting Audit Frequency Requirements from TS Sections 6.5.2.8 & 6.5.3.1.Requirements Being Added to QA Program Description Located in Updated Fsar,Section 17.2.18.2.2

ML20078R909
Person / Time
Site:	Duane Arnold
Issue date:	02/13/1995
From:	Franz J IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	Russell W NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML20078R911	List: ML20078R917 NG-95-0538, Request for TS Change (RTS-275) to License DPR-49,deleting Audit Frequency Requirements from TS Sections 6.5.2.8 & 6.5.3.1.Requirements Being Added to QA Program Description Located in Updated Fsar,Section 17.2.18.2.2
References
NG-95-0538, NG-95-538, NUDOCS 9502230193
Download: ML20078R909 (5)

Text

.. )

i IES  !

UTILITIES INC.. l John F. Fror c Jr.  ;

Vice President. clear ,

February 13, r;"5 NG-95-0533 Mr. William T. Russell, Director .!

Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission r

Attn: Document Control Desk Mail Station PI-37 Washington, DC 20555-0001

Subject:

Duane Arnold Energy Center  :

Docket No: 50-331 Op. License No: DPR-49 ,

Request for Technical Specification Change (RTS-275),

Proposed Technical Specification Change for Audit Program in Sections 6.5.2.8 and 6.5.3.1

Reference:

1) NG-94-4459, J. Franz (IES) to W. Russell (NRC), ,

Reporting of Changes to the Quality Assurance Pregram

' Description, UFSAR 17.2.18.2.2, dated December 5,1994  :

File: A-117 +

Dear Mr. Russell:

in accordance with the Code of Federal Regulations, Title 10, Sections 50.59 and 50.90,-

1 IES Utilities Inc. hereby requests revision of Operating License DPR-49 for the Duane Arnold Energy Center (DAEC).

The propowa change deletes the audit frequency requirements from the DAEC Technical Specifications, Sections 6.5.2.8 and 6.5.3.1. These requirements are being added to the  !

Quality Assurance Program Description located in the Updated Final Safety Analysis Report, Section 17.2.18.2.2 as indicated in submittal to NRC, dated December 5,1994 (Reference 1).

i This change has been reviewed by the DAEC Operations Committee and the DAEC 1 Safety Committee. Pursuant to the requirements of 10 CFR 50.92, a copy of this

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9502230193 950213 +

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ADOCK 05000331 PDR ,

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• P.O. Box 351

• Cedar Rapids. Iowa 52406

• 319/398-4411 An IES INDUSTRIES Company

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?. Mr William T. Russell February 13l 1995 )

NG-95-0538 )

Page 2 )

submittal, including the no significant hazards consideration analysis, is being forwarded to our appointed state official.

.We hereby request that this amendment be made effective 60 days aller issuance to allow adequate time for implementation.

No new commitments are made by this letter. -l This letter is true and accurate to the best of my knowledge and belief.

IES UTILITIES INC.

By John F. Franz Vice President, Nuclear State oflowa (County) of Linn Signed and sworn to before me on this fbdayo -lhdFM ,1995,  ;

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IT 5"g MARY MICHELE 0'NEAL >lic in dfo/i't e of10 wa j k* 9pDW1 E (blJ 0 l

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NilowaEI Acmingpp+94-4431 Attachments: 1) Evaluation of Change with respect to 10 CFR 50.92

2) Proposed Change (RTS-275) to the Duane Arnold Energy Center Technical Specifications l

3) Safety Assessmern ]

4) Environmental Consideration l cc: 11. Tran l L Liu L. Root B. Fisher G. Kelly (NRC-NRR)

J. Martin (Region 111)

S. Brown (State oflowa)

NRC Resident Oflice  !

Docu l

l l

. RTS-275 Attachment I to >

NG-95-0538 Page I of 3 EVAL IIAJION OF CliANGE WITli RESPECT TO 10 CFR SECTION 50.92 ihckgrpuad; c

Technical Specification (TS) Sections 6.5.2.8 and 6.5.3.1 currently contain requirements for the audit program. The areas to be audited and the frequencies of these audits are specified. This audit program implements the Duane Arnold Energy Center's (DAEC) commitments to Regulatory Guide 1.33, Revision 2 (February 1978) and ANSI N18.7-1976/ANS-3.2. These audits address programs deemed to be essential to the safe operation of a nuclear facility. Ilowever, the present audit schedules are specified in the TS and do not allow management the flexibility to adjust the audit frequencies, if appropriate, in view of the performance of the program or organization being audited.

The resources which could be devoted to areas which require more attention are currently expended in auditing strong programs (reactor water chemistry) in order to meet TS mandated frequencies. In addition, the lack of flexibility can require auditing an activity before corrective actions are completed although the audit could have better measured the effectiveness of corrective action if postponed a short time.

The proposed TS change deletes the frequency requirements from the DAEC TS Sections 6.5.2.8 and 6 5.3.1. They are being added to the Quality Assurance Program Description ,

(QAPD) located in the Updated Final Safety Analysis Report (UFSAR), Section 17.2.18.2.2. This proposed change will allow IES Utilities Inc. some flexibility to adjust the audit frequencies based upon the performance of the program or organization being audited per the guidance contained in 10 CFR 50.54(a)(3). We believe this will result in a ,

more elTective audit program which can focus resources on programs or organizations with perceived weaknesses and thereby contribute to an improvement in overall performance of the facility. Any audits required by NRC to be conducted at a specified frequency will continue to be performed at that frequency unless a specific exemption is or has been granted. DAEC has received no such approved exemptions to date.

The propo: s change is consistent with changes previously approved for Virginia Electric and Power Company's Surry Power Station, Amendment 188 (March I,1994),  !

and North Anna Power Station, Amendment 180,(March 1,1994).  !

IES Utilities IngmDscket No. 50-331. l Duime ADLold_lin. ergy Center. Linn County. Img Ilates.flmendmenLRtqunt: February 13,1995 l

l I

RTS-275 Attachment I to NG-95-0538 ,

Page 2 of 3 Dncription of Amendment Request:

The proposed License Amendment would delete the audit program frequency requirements from the DAEC TS Sections 6.5.2.8 and 6.5.3.1.

Ilni for 3 proposed No Significant llazards Consideration:

The Commission has provided standards (10 CFR Section 50.92(c)) for determining whether a significant hazards consideration exists. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or difTerent kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

Aller reviewing this proposed request for Technical Specification change, we have concluded:

1. The proposed amendment does not involve a change in the probability or consequences of an accident previously evaluated. No physical changes will occur as a result of this amendment. The change is administrative in nature and does not impact the operation of the plant or the plant's response to any accident. Because it will allow management the flexibility to adjust the audit frequencies based upon the performance of the program or organization being audited, the overall performance of the organization will be improved.

2. The proposed amendment does not create the possibility of a new or difTerent kind of accident from any accident previously evaluated. No physical changes will occur as a result of this amendment. The change ir administrative in nature and does not affect the operation or design of the plant; thervore, it does not create the possibility of a new or different kind of accident from any accident previously evaluated. The audits will continue to be performed to provide r.ssurance of conformance to the applicable requirements.

3. The proposed amendment will not reduce the margin of safety. No physical changes will occur as a result of this amendment. The change is administrative in nature and j does not affect the operation or design of the plant. Safety limits and limiting safety i system settings are not affected by this proposed amendment. The amendment removes requirements for frequency of audits from the TS, thus permitting more efTective scheduling of audits based on performance and the status of the activitics audited. This should result in a more effective audit program that will contribute to an improvement in the overall performance of the organization.

4'

RTS-275 Attachment I to NG-95-0538 Page 3 of 3 The audit fiequencies are being incorporated into the QAPD (UFS AR, Section 17.2.18.2.2). Ilased upon the above, we have determined that the proposed amendment will not involve a significant hazards consideration.

Losal Publig]qqument Room Location: Cedar Rapids Public Library,500 Firct Street SE, Cedar Rapids, Iowa 52401 Atto._rnnpy_for Licensee _; Jack Newman, Kathleen II. Shea; Morgan, Lewis and Ilockius, 1800 M. Street NW, Washington, D.C. 20036-5869

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