L-99-012, Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B

Forwards Proposed Change to Bvps,Units 1 & 2,operations QA Program Description,Per 10CFR50.54(a)(3)(ii),including Description of Proposed Change,Reason for Change & Basis for Concluding Revised Program Satisfy 10CFR50,App B

ML20211N532
Person / Time
Site:	Beaver Valley
Issue date:	08/30/1999
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-REGGD-01.058 L-99-012, NUDOCS 9909130016
Download: ML20211N532 (5)

Text

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g hp hve Valley Power Station Shippingport. PA 15077-0004 SUSHIL C. JAIN ugust 30, 1999 g ,g 3,3,33,,

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[-99-012 Fax (724) 643-8069 Nuclear Power Division U. S. N.iclear Regulatory Commission j Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Units No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. DPR-73 Quality Assurance Program Description Change In accordance with 10 CFR 50.54(a)(3)(ii), this letter forwards for NRC approval, a proposed change to the Beaver Valley Power Station (BVPS) Units 1 and 2 Operations Quality Assurance (QA) Program Description. ' This change would reduce the Program Description commitments for both Units by no longer requiring personnel in select job positions to qualify to the requirements of ANSI N45.2.6 - 1978, endorsed by Regulatory Guide 1.58, Revision 1, September 1980, " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel."

Attachment I further describes the proposed change, the reason for the change, and provides the basis for concluding that the revised program incorporating this change continues to satisfy the criteria of 10 CFR 50, Appendix B.

Attachment 2 presents the proposed wording changes to the Unit No. I UFSAR and the Unit No. 2 UFSAR to reflect this change.

If you have my question regarding this submittal, please contact Mark S. Ackerman, Manager of Safety and Licensing in the Nuclear Services Group, at (412) 393-5203.

Sincerely, Sushil C. Jam , f c: Mr. D. S. Collins, Project Manager  ; l Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator DEL 1Vl RING

' The Operations QA Program description for BVPS Unit I was deleted from the Unit 1 Updated Final Safety Analysis Report (UFSAR)in January 1988 and the program 00AMiY description for BVPS Units I and 2 is provided in Section 17.2 of the Unit 2 UFSAR. INER6Y 9909130016 990830 PDR ADOCK 05000334 P PDR

o ATTACHMENT 1 PROPOSED CilANGE DESCRIPTION Currently, personnel injob positions described within 10 CFR 50.120 and 10 CFR 55 are qualified to the requirements of ANSI N45.2.6 - 1978, which is endorsed by Regulatory Guide 1.58, Revision 1, September 1980, " Qualification of Nuclear Power Plant Inspection, Examination and Testing Personnel." These personnel may perform inspection, examination, or testing as part of theirjob responsibilities. Through this proposed change, the basis for training and qualification of personnel in these job classifications would be satisfactory completion of the training programs required by 10 CFR 50.120 and 10 CFR 55. For these personnel, the training requirements of the l subject ANSI and the Regulatory Guide would no longer apply.

However, this change would not affect the commitment for qualification ofinspection, examination and testing personnel in job positions not described in 10 CFR 50.120 or 10 CFR 55. These personnel (i.e., Quality Control Inspectors and Test Engineers),

would continue to be qualified in accordance with the above described ANSI and Regulatory Guide.

REASON FOR Tile PROPOSED CilANGE Benefits to be gained from this change would include elimination of the generation, maintenance, and oversight of redundant qualification procedures and records while continuing to provide comprehensive training through existing qualification programs.

BASIS FOR CONCLUDING TilAT TIIE REVISED PROGRAM INCORPORATING TIIE PROPOSED CIIANGE WOULD CONTINUE TO l SATISFY TIIE CRITERIA OF 10 CFR 50, APPENDIX B l With incorporation of this proposed change, the revised QA Program would continue to j satisfy the criteria of 10 CFR 50, Appendix B since the program would continue to provide for training and qualification of personnel performing activities affecting quality i as necessary to assure that suitable proficiency is achieved and maintained. Personnel who perform Quality Control Inspections and Test Engineer Testing would continue to be qualified in accordance with the requirements of ANSI N45.2.6-1978 and Regulatory Guide 1.58, Revision 1. Although there will be no reduction in training requirements, individuals in selectjob positions would no longer be qualified to the requirements of the subject ANSI and regulatory guide. The training and qualifications of these individuals as required by 10 CFR 50.120 and 10 CFR 55 would continue to be based on training programs derived from a systems approach to training as defined by 10 CFR 55.4. These training programs are developed, implemented and upgraded continually, based on

ATTACHMENT I (c:ntinued) analysis ofjob responsibilities, student and management feedback, industry good practices and the corrective action results of oversight activities. As such, the training programs are expected to remain effective in evaluating each individual's level of knowledge and skill. 'ihe combination of educational, capability demonstration and physical characteristics requirements would furthermore assure that individuals are qualified to perform their assignedjob functions. In addition, Quality Services would continue to provide oversight in this area, further ensuring that compliance with 10 CFR 50, Appendix B is maintained.

1

g ATTACHMENT 2 L

! BVPS-1_ UPDATED FSAR

, , Revision (TBD) 1.3.4.1 Regulatory Guides REGULATORY. GUIDE 1.58, REVISION 1, SEPTEMBER,1980: QUALIFICATION

. OF NUCLEAR POWER PLANT INSPECTION, EXAMINATION, AND TESTING PERSONNEL Qualification ofinspection, examination, and testing personnel at Beaver Valley Power Station (BVPS) follows the guidance of this regulatory guide with the following clarifications:

ANSI N45.2.6. Parauraoh 2.5:

ANSI N45.2.6-1978 recommends that organizations identify any special physical characteristics needed in the performance of each activity, and that personnel requiring these characteristics have them verified by examination at intervals not to exceed one year. At BVPS, examinations to verify personnel have the required physical characteristics will be scheduled on an annual basis with a maximum allowable extension of 90 days.

Regulatory Guide 1.58. Paranraoh C.6:

The initial qualifications ofindividuals to Levels I, II, or III will generally be to the education and experience recommendations of ANSI N45.2.6-1978. However, in cenain instances as determined by appropriate management, qualifications may ,

alternatively be determined through test results and/or demonstration of I capabilities. Individual requalification will meet or exceed the recommendation of )

the standard.

Paragraph 3.5.1 of ANSI N45.2.6-1978 lists recommended education and experience for qualification to Level L BVPS will also accept a 4-year college degree plus 1 month of related experience or equivalent inspection, examination, or testing activities.

Individuals in iob oositions described within 10 CFR 50.120 and 10 CFR 55. who perform inspection. examination or testine as can of pre-iob. iob and post-iob activities (i.e. maintenance technician parts inspections. pre-operational post-I maintenance testina. operational cost-maintenance testina. etc.) are aualified in i accordance with the reauirements of 10 CFR 50.120 and 10 CFR 55 in lieu of Regulatory Guide 1.58. Ouality Control Inspectors and Test Encineers will be cualified in accordance with Regulatorv Guide 1.58.

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ATTACHMENT 2 BVPS-2 UPDATED FSAR Revision (TBD)

Table 1.8-1 (Cont.)

'USNRC REGULATORY GUIDES RG No.1.58, Rev.1 l UFSAR Reference Sections 17.1, 17.2 OUALIFICATION OF NUCLEAR POWER PLANT INSPECTION. EXAMINATION.

AND TESTING PERSONNEL (SEPTEMBER 1980)

Qualification ofinspection, examination, and testing personnel at Beaver Valley Power i Station - Unit 2 (BVPS-2) follows the guidance of this regulatory guide with the following clarifications: 1 ANSI N45.2.6. Paragraph 2.5:

ANSI N45.2.6-1978 recommends that organizations identify any special physical characteristics needed in the performance of each activity, and that personnel requiring these characteristics have them verified by examination at intervals not to .

exceed one year. At BVPS, examinations to verify personnel have the required physical characteristics will be scheduled on an annual basis with a maximum allowable extension of 90 days.

Regulatory Guide 1.58. Paragraph C.6:

The initial qualifications ofindividuals to Levels I, II, or III will generally be to the education and experience recommendations of ANSI N45.2.6-1978. However, in certain instances as determined by appropriate management, qualifications may alternatively be determined through test results and/or demonstration of capabilities. Individual requalifications will meet or exceed the recommendation of the standard.

Paragraph 3.5.1 of ANSI N45.2.6-1978 lists recommended education and experience for qualification to Level I. BVPS-2 will also accept a 4-year college degree plus 1 month of related experience or equivalent inspection, examination, or l testing activities, i Individuals in iob oositions described within 10 CFR 50.120 and 10 CFR 55. who perform insocction. examination or testing as part of pre-iob. iob and post-iob activities (i.e. maintenance technician oasts inspections. pre-operational post- ,

maintenance testina. operational post-maintenance testing. etc.) are aualified in I

accordance with the reauirements of 10 CFR 50.120 and 13 CFR 55 in lieu of Regulatory Guide 1.58. Ouality Control Inspectors and Test Engineers will be analified in accordance with Regulatory Guide 1.58.

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