L-99-037, Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change

Forwards Proposed Change to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Attachment 1 Further Describes Proposed Change & Identifies Reason for Change

ML20211N599
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
L-99-037, NUDOCS 9909130028
Download: ML20211N599 (5)

Text

%e Beave Valley Power Stapon Shippingport, PA 15077 0004 SU$HIL C. JAIN (412) 393-5512 Pre seer [s'e'rvc sdent August 30, 1999 Fax (724) 643-8069 Ma' Poww W@n {-99-037 U. S. Nuclear Regulatory Commission 1 Attention: Document Control Desk )

Washington, DC 20555-0001 1

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 l BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-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. 3 The change would permit Quality Services Unit staff members to perform random reviews of lower tier administrative procedures for compliance with Quality Assurance Program requirements following  !

I implementation of these procedures or changes to these procedures. The current program requires that the Quality Services Unit perform this review prior to implementation of these procedures or changes to these procedures. Duquesne Light l Company has concluded that this change constitutes a reduction in commitment pursuant to 10 CFR 50.54(a)(3)(ii). Therefore, NRC approval is required prior to its implementation.

Attachment I further describes the proposed change, identifies 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 for the Beaver Valley Power Station Unit 2, Updated Final Safety Analysis Report to reflect this change.

If you have any questions regarding this submittal, please contact Mr. M. S. Ackerman, Manager, Safety and Licensing Department, at (412) 393-5203.

Sm.cerely, Y,

gwE Sushil C. Jain DELIVEllNG

' The Operations QA Program description for BVPS Unit I was deleted from the Unit 1 0 U A1B Y Updated Final Safety Analysis Repon (UFSAR) in January 1988 and the program description for BVPS Units I and 2 is provided in Section 17.2 of the Unit 2 UFSAR.

ENERGV 9909130028 990030 PDR ADOCK 05000334 P PDR i.

Beaver Valley Power Station, Unit No. I and No. 2 Quality Assurance Program Description Change L-99-037 Page 2 -

c: Mr. D. S. Collins, Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. M.ller, NRC Region I Administrator

ATTACHMENT 1 BACKGROUND The Operations Quality Assurance (QA) Program Description presented in the Beaver Valley Power Station Unit 2, Updated Final Safety Analysis Report (UFSAR) includes the following commitment:

"Duquesne Light Company personnel supporting the QA effort include the Nuclear Power Division, and Customer Operations. Personnel in the Nuclear Power Division, and others in Customer Operations who participate in the program, perform their duties in accordance with administrative procedures previously reviewed by the Quality Services Unit. .

The Quality Services Unit (QSU) currently reviews Nuclear Power Division Administrative Procedures (NPDAPs), lower tier administrative procedures identified in Attachment 1 of NPDAP 2.3, " Procedure Review and Approval," and other select QA related administrative procedures.

These reviews, which include thcse in Customer Operations, ensure compliance with QA Program requirements. The involved procedures are referred to as " site procedures" in current Section 17.2.1.2 of the Unit 2 UFSAR. These reviews are performed prior to implementation of these procedures or revisions to these procedures.

CHANGE DESCRIPTION The change would permit a random review oflower tier administrative procedures by the Quality Services Unit r,taff, for compliance with QA Program requirements, following the implementation of )

these procedures or revisions to these procedures.

REASON FOR THE CHANGE This change will result in more eflicient use of Beaver Valley Power Station personnel resources.

l BASIS FOR CONCLUDING THAT THE REVISED PROGRAM INCORPORATING THE CHANGE CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50, APPENDIX B l i

The revised program incorporating the change will continue to satisfy the criteria of 10 CFR 50, Appendix B since 1) the lower tier administrative procedure reviews will continue to be performed for compliance with the requirements of the Operations QA Program through biennial audits, surveillances, or assessments, and 2) the Quality Services Unit staff will continue to review higher tier Nuclear Power Division Administrative Procedures.

Although this change involves a reduction in commitment presented in the safety analysis report QA program description, justification for this change is supported by the results of QSU procedure reviews, which in 1996,1997, and 1998 found no items having nuclear safety significance. As such, the original intent and purpose of this review activity will continue to be fulfilled with no reduction in effectiveness. 1 i

l Based on the foregoing, the revised QA Program will continue to satisfy the criteria of 10 CFR 50 Appendix B, and the intent and purpose of the safety analysis report QA program description commitments

1 l

ATTACHMENT 2 I I

BVPS-2 UFSAR Rev. TBD 17.2 QUALITY ASSURANCE PROGRAM DESCRIPTION, OPERATIONS The following Quality Assurance Program (QAP) description applies to both Beaver Valley Power Station (BVPS) Unit 1 and BVPS Unit 2. The term BVPS as used in this QAP description applies to both BVPS-1 and BVPS-2. If a requirement applies to only one unit, the unit that it applies to is specifically identified.

Prior to the 1988 update of the BVPS-1 UFSAR, the QAP description was contained in Appendix A of the BVPS-1 UFSAR and the QAP description for BVPS-2 was contained in Section 17 of the BVPS-2 FSAR.

An Operations Quality Assurance (QA) Program is established by

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Duquesne Light company (DLC) for the operations phase of Beaver Valley Power Station (BVPS). The program is written to conform to the requirements of 10 CFR 50, Appendix B, " Quality Assurance criteria for Nuclear Power Plants and Fuel Reprocessing Plants," and U.S. Nuclear  !

Regulatory Commission (USNRC) Regulatory Guide 1.33, " Quality l Assurance Program Requirements (Operations)."

The purpose of the Operations QA Program is to assure that the installed quality of the BVPS is maintained throughout the life of both plants.

The Operations QA Program applies to all safety-related structures, ,

systems, and components throughout the life of the plant. i 17.2.1 Organization The Duquesne Light Company President and Chief Executive Officer; the President, Generation Group and Chief Nuclear Officer; the Vice  ;

President Customer Operations; and the Vice President Marketing &

Corporate Performance; the Division Vice President Nuclear Operations

& Plant Manager; the Senior Vice President Nuclear Services Group, and the Division Vice President Operations Support Group comprise those members of the Executive Management Group who have Nuclear responsibility.

The organizations which have responsibilities for performing activities affecting quality during the operations phase of BVPS are

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shown in the organization chart on Figure 17.2-1. The Operations QA Program identifies in detail the functional responsibilities of the organizations within DLC which participate in quality-related activities.

Duquesne Light Company personnel supporting the QA effort include the Nuclear Power Division, Marketing & Corporate Performance, and customer Operations. Personnel in the Nuclear Power Division, and l others in Customer Operations who participate in the program, perform their duties in accordance with the recruirement s of the Operations

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Ouality Assurance Procram;tini;tr;tiv; pre;;ir;; previc;;1y ;;vi;u;d by th; Qu;1ity :::vi;;; Unit. The Quality Services Unit also performs audits of groups participating in the program in accordance with UFSAR Section 17.2.18.

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ATTACHMENT 2 (Continued)

BVPs-2 UFsAR Rev. TBD 17.2.1.2 Quality r,ervices Unit ouality services Insonetion & Examination Quality services inspection and examination activities are directed by the Director, Quality services Inspection and Examination under the direction of the Manager, Quality Services Unit. These activities include implementing the quality control inspection program; implementing the non-destructive examination program; providing inspection and examination services;. reviewing station work for quality hold points; and identifying and documenting non-conforming conditions.

Quality Data Assessment

' Quality data assessment activities are directed by the supervisor, Quality Data Assessment under the direction of the Manager, Quality services Unit. These activities include implementing a quality data assessment information service, tracking audit deficiencies, providing trending and performance indicator information (including nonconformance trends), maintaining quality assurance program procedures, and performing quality reviews of nuclear oower division administrative croceduresehe-peeeedwese.

Quality Services Audit & Surveillance Quality services audit and surveillance (Quality Assurance) activities are directed by the Quality services Audit and surveillance supervisors under the direction of the Manager, Quality services Unit.

These activities include implementing the quality assurance audit program, implementing' the quality assurance surveillance program, performing source inspections at vendor facilities, evaluating qualified suppliers, reviewing procurement documents for services, and j providing identification and status of deficient materials. A random '

review of the imolementation of lower tier administrative crocedures will be conducted throuah OSU oversicht activities such as biennial audits, surveillances or assessments to assure comoliance with QA Procram recuirements.

Ombudsman I

Under the direction. of the Manager, Quality services Unit, the ombudsman develops and maintains a Beaver Valley site-wide program to review - and attempt to resolve, when appropriate, safety-related concerns and issues identified by Boaver Valley employees, contractors, or consultants who choose to report such concerns in a confidential environment.

ORC Coordinator Under the direction of the Manager, Quality Services Unit, the ORC Coordinator is responsible for the coordination of all activities related to the ORC. The ORC Coordinator is a non-voting member of the i ORC.-

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