L-99-098, Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods

Forwards Proposed Changes to Bvps,Units 1 & 2 Operations QA Program Description,Iaw 10CFR50.54(a)(3)(ii).Change Would Reduce Operations QA Program Description Commitments by Limiting Required Onsite Safety Committee Reviews of Mods

ML20211N743
Person / Time
Site:	Beaver Valley
Issue date:	09/02/1999
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-99-098, NUDOCS 9909130056
Download: ML20211N743 (8)

Text

...

Beav Valley Power Station Shippingport, PA 150774X)4 SUSHIL C. JAIN (41C WOM2 Senior vice er..ident September 2, 1999 Fax ; 2:,643-8069

$$7,$.*r*$ivi. ion L-99-098 U. S. Nuclear Regulatory Commission 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 Operations 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 I and 2 Operations Quality Assurance (QA) Program Description.* This change would reduce the Operations QA Program Description commitments by limiting required Onsite Safety Committee (OSC) reviews of modifications and changes of safety related and non safety related items and proposed tests and experiments to those items requiring a completed 10 CFR 50.59 safety evaluation.

Attachment 1 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 2 UFSAR to reflect this change.

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

Sincerely, ,/

.' 'I I

9909130056 990902 ,

PDR ADOCK 05000334 I P PDR Sushil C. Jain

(

DEllVERING I

' The Operations QA Program description for BVPS Unit I was deleted from the Unit I ggg(l7y Updated Final Safety Analysis Report (UFSAR)in January 1988 and the program description ENERGV for BVPS Units I and 2 is provided in Section 17.2 of the Unit 2 UFSAR.

130602

1 Beaver Valley Power Station, Unit No. I and No. 2  ;

Operations Quality Assurance Program Description Change I Page 2 v

Attachments -  !

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

l I

i j

t, k.1

ATTACHMENT 1 PROPOSED CHANGE DESCRIPTION Unit 2 UFSAR' Section 17.2.3 regarding design control, currently specifies (in-part) that the Operations QA Program requires that all design changes of safety-related items shall be reviewed by the OSC and ORC (Offsite Review Committee) in accordance with the quality assurance program description and the requirements of the Operations QA Program. As part ofits responsibilities, the OSC now reviews all modifications and changes to the facility involving safety related items (i.e. those items that require a 10 CFR 50.59 screening or involve a 10 CFR 50.59 evaluation). The proposed change to

- Section 17.2.3 would allow the OSC to limit reviews of modifications and changes of safety related and non safety related items to those requiring a completed 10 CFR 50.59 evaluation. A change will also be made to Section 17.2.1.3 which will require the OSC to review those proposed tests and experiments and modifications and changes which require a completed 10 CFR 50.59 evaluation. In addition, the ORC would continue to

, meet the requirement in Section 17.2.1.4, to review proposed and completed changes to equipment or systems, regarding a potential or actual unreviewed safety question, as defined in 10 CFR 50.59.

REASON FOR THE PROPOSED CHANGE 4

OSC reviews now include modifications and changes that do not require a completed 10 CFR 50.59 safety evaluation and are, therefore, outside the realm of what could constitute an unreviewed safety question. Limiting these reviews would improve the ,

OSC focus and effectiveness by better concentrating resources on issues important to j nuclear safety. Additional benefits would include improved utilization of management personnel and other members of the plant staff serving on the OSC.

BASIS FOR CONCLUDING THAT THE REVISED PROGRAM INCORPORATING THE PROPOSED CHANGE WOULD CONTINUE TO SATISFY THE CRITERIA OF 10 CFR 50 APPENDIX B.

The proposed change is considered to be a reduction in commitment to the NRC, as it would no longer require the OSC to review all proposed changes or modifications to the plant systems or equipment. However, with the proposed change the OSC will continue to review proposed modifications and changes requiring a completed 10 CFR 50.59 evaluation. As such, the proposed change will not reduce the effectiveness of the Operations QA Program. In addition, since no changes were made to the Operations QA Program description that affect our commitments to 10 CFR 50, Appendix B, the Program will continue to satisfy 10 CFR 50, Appendix B.

ATTACHMENT 2 l;

- .- BVPS-2 UFSAR Revision (TBD)

I The Operations QA Program provides measures to assure that changes or deviations from specified design requirements or quality standards are identified, documented, and controlled.  ;

Design changes at BVPS after release and acceptance of design documents are subject to design control measures commensurate with those originally applied to the design. The i Operations QA Program requires that, whenever practical, changes should be reviewed and approved by organizations that originally performed the review and approval of the design. In the event that it is not practical for the ariginal organizations to perform the required review and approval, other responsible organizations will be designated. The ]

designated organization shall have access to pertinent background information, have competence in the specific design area ofinterest, and have adequate understanding of the requirements and intent of the original design.

Design documentation, inclading design review reports, specifications, drawings, and revisions thereto shall be collected, filed, stored, and maintained in a systematic manner.

The Operation: QA Progra:n require; th:1: All design changes of safety-related and non-safety-related items that reauire a completed 10 CFR 50.59 safety evaluation shall be reviewed by the OSC and the ORC in accordance with this quality assurance program description and the requirements of the Operations QA Program. Safety ev !uction: are condue:ed, : required by 10 CFR 50.59. OSC and ORC review of desian channes is discussed in Sections 17.2.1.3 and 17.2.1.4 of the Operations Ouality Assurance Program desciiotion.

17.2.4 Procurement Document Control l

i

'. ATTACHMENT 2 (Continued)

BVPS-2 UFSAR Rev. (TBD)

' 17.2.1.3 Onsite Safety Committee (OSC)

The OSC shall function to advise the General Manager, Nuclear Operations on all matters related to nuclear safety and shall provide review capability in the areas of:

1. Nuclear power plant operations.

2. Radiological safety.

3. Maintenance.

4. Nuclear engineering.

5. Nuclear power plant testing.

6. Technical advisory engineering.

7. Chemistry.

8. Quality control.

9. Instrumentation and control.

The Onsite Safety Committee Coordinator is the OSC Chairman and shall appoint all members of the OSC. The membership shall consist of a minimum of one individual from each of the areas designated above. l OSC members and alternates shall meet or exceed the minimum qualifications of ANSI N18.1-1971 Section 4.4 for comparable positions. The nuclear power plant operations individual shall meet the qualifications of Section 4.2.2 and the maintenance individual shall meet the qualifications of Section 4.2.3.

All alternate members shall be appointed in writing by the OSC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in OSC activities at any one time.

The OSC shall meet at least once per calendar month and as convened by the OSC Chairman or his designated alternate. A quorum of the OSC shall consist of the Chairman or his designated alternate and at least one half of the members including attemates.

The OSC shall be responsible for:

1. Review of a) all procedures required by Technical Specification 6.8 and changes of intent thereto, b) any other proposed procedures or changes thereto as determined by the General Manager, Nuclear Operations to affect nuclear safety.

2. Review of all proposed tests and experiments that affect m:clea:-

safeef reauire a completed 10 CFR 50.59 safety evaluation.

3. Review of all proposed changes to the Technical Specifications.

l l '

l ,

ATTACHMENT 2 (Continued) l l

BVPS-2 UFSAR Rev. (TBD) l

4. Review of all proposed changes or modifications to plant systems or equipment that hmderr =fety reauire a completed 10 CFR 50.59 safety evaluation.

5. Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the '

l General Manager, Nuclear Operations and to the Chairman of the Offsite Review Committee. 1 l

l l

l l

l f

l l

l

y

". ATTACHMENT 2 (Continued)

BVPS-2 UFSAR (Copy of this section provided FOR INFORMATION ONLY) 17.2.1.4 Offsite Review Committee (ORC)

The ORC shall function to provide independent review and audit of designated activities in the areas of:

1. Nuclear power plant operations.

2. Nuclear engineering

3. Chemistry and radiochemistry

4. Metallurgy

5. Instrumentation and control

6. Radiological safety

7. Mechanical and electrical engineering

8. Quality assurance practices The Chainnan and all members of the ORC shall be appointed by the President, Generation Group and Chief Nuclear Officer. The membership shall consist of a minimum of five individuals who collectively possess a broad based level of i experience and competence enabling the committee to review and audit those i activities designated above and to recognize when it is necessary to obtain technical advice and counsel. An individual may possess expertise in more than one specialty area. The collective competence of the committee will be maintained as changes to the membership are made.

All alternate members shall be appointed in writing by the ORC Chairman or a ,

member of Beaver Valley Power Station executive management to serve on a temporary basis; however, no more than two alternates shall participate as voting members in ORC activities at any one time. Consultants shall be utilized as determined by the ORC Chainnan to provide expert advice to the ORC.

The ORC shall meet at least once per calendar quarter during the initial year of l facility operation following fuel loading and at least once per six months thereafter. A quorum of the ORC shall consist of the Chairman or his designated alternate and at least four members including nitemates. No more than a i minority of the quorum shall have line responsibility for operation of the facility.

The ORC shall review:

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

systems and b) 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.

A

i p

s

',.' ATTACHMENT 2 (Continued)

BVPS-2 UFSAR

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

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

4. Proposed changes in Technical Specifications or licenses.

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

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

I

7. All reportable events of the type described in 10 CFR 50.73.

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

9. Reports and meeting minutes of the OSC.

10. The results of the Radiological Environmental Monitoring Program i annual report provided in accordance with Technical Specification 6.9.1.10, prior to submittal.

.