ML032390528

Proposed Revision to Quality Assurance Policy Involving & Reduction in Commitment

ML032390528
Person / Time
Site:	Calvert Cliffs
Issue date:	08/20/2003
From:	Vanderheyden G Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML032390528 (17)

Text

George Vanderheyden 1650 Calvert Cliffs Parkway Vice President Lusby, Maryland 20657 Calvert Cliffs Nuclear Power Plant 410 495-4455 Constellation Generation Group, LLC 410 495-3500 Fax Constellation

. Energy Group August 20, 2003 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit No. 2; Docket No. 50-318 Proposed Revision to the Quality Assurance Policy Involving a Reduction in Commitment Pursuant to 10 CFR 50.54(aX4), Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP) hereby requests approval of a proposed revision to its Quality Assurance Policy (QAP) that involves a reduction in commitment as accepted by the Nuclear Regulatory Commission (NRC). The proposed revision eliminates the regulatory requirement in the QAP for an Off-Site Safety Review Committee (OSSRC) as an advisory group performing independent review and audit of quality-related activities and procedures.

We request that the NRC approve the proposed revision with a safety evaluation report to permit industry-wide adoption of this change pursuant to 10 CFR 50.54(aX3)(ii).

BACKGROUND The nuclear electric utility industry through the Nuclear Energy Institute Licensing Action Task Force is engaged with the NRC staff to prioritize and implement burden reduction initiatives identified in SECY-02-0081. The requirement to maintain the regulatory requirement for an offsite review committee in the QAP has been identified as one of the unnecessary regulatory burdens that can be eliminated through NRC approval of a pilot plant's application that can be adopted by other licensees without further NRC action. Calvert Cliffs Nuclear Power Plant is participating as the pilot plant for this initiative.

The basis for an OSSRC commitment in CCNPP's QAP is American National Standards Institute (ANSI)

N18.7-1976/ANS 3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" (the standard) which is endorsed by Regulatory Guide 1.33, "Quality Assurance Program Requirements." The specific reference to an offsite organization is contained in Section 4.3 of the standard, "Independent Review Program." Although the standard requires independent review of activities affecting plant safety during the operational phase, it does not specify a single organizational structure for meeting the review function. Instead it describes the essential elements of two programs that can be used to perform the independent review function. Calvert Cliffs Nuclear Power Plant's OSSRC is based on the program described in Section 4.3.2, "Standing Committees Functioning as Independent Review Bodies." The other program is described in Section 4.3.3, "Organizational Units Functioning as Independent Review Bodies."

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Document Control Desk August 20, 2003 Page 2 PROPOSED CHANGE We request NRC approve a reduction in commitment to the CCNPP QAP to eliminate the requirement for OSSRC to be an advisory group performing independent review and audit of quality-related activities and procedures. The detailed changes to the QAP are shown on the attached marked-up pages (Attachment 1).

REASON FOR PROPOSED CHANGE Since the issuance of ANSI N18.7-1976/ANS 3.2, that recommended use of standing committees to perform independent review and audit, the nuclear industry has gone through a significant evolution in the way it manages its safety culture. As described in Section 4.1 of ANSI N18.7-1976/ANS 3.2,

"[h]istorically a committee approach was used to provide both review and audit capability for early commercial nuclear power plants. This approach was employed to make the most efficient use of people with pertinent experience and qualifications." In the early 1970's, during which time the standard was being developed, overall onsite staffing levels at a typical nuclear plant site were less than a hundred.

Today, however, the typical onsite technical staff alone numbers in the several hundreds. The onsite technical staff has all the expertise needed to perform independent reviews. The improvements in implementing engineering functions, the 10 CFR 50.59 process, and the quality and standardization of License Amendment Requests have greatly enhanced the capabilities of the onsite staff.

Improvement in the nuclear power industry's self-assessment process, the emergence of robust corrective action programs and the continuing maturation of the NRC Regulatory Oversight Process render the over-sight/audit function of OSSRC redundant. In addition, the nuclear electric utility industry, through various well-established owners groups and the Institute of Nuclear Power Operations (INPO), addresses generic and programmatic issues. Therefore, the requirement to maintain the functions of OSSRC in the QAP is an unnecessary regulatory burden.

BASIS FOR CONCLUDING CONTINUED COMPLIANCE WITH 10 CFR PART 50, APPENDIX B The ANSI N18.7-1976/ANS 3.2 standard defines an independent review as a "[rieview completed by personnel not having direct responsibility for the work function under review regardless of whether they operate as part of an organizational unit or as individual staff members ..." With the exception of QA audits, CCNPP performs an extensive independent onsite review of all activities that are currently reviewed by OSSRC. As a minimum, each activity typically receives an independent review by engineering personnel with specific system or analysis background pertinent to the subject matter and an independent committee review by the onsite Plant Operations and Safety Review Committee (POSRC).

The Calvert Cliffs POSRC is composed of at least seven members, including the Chairman. The Members have experience and competence in the following areas:

Nuclear Operations Electrical and Controls Maintenance Chemistry Mechanical Maintenance Nuclear Engineering Radiation Safety Plant Engineering Design Engineering

Document Control Desk August 20, 2003 Page 3 The POSRC meets more frequently than OSSRC and the commitment for recordkeeping meets the standard's specification. Although the POSRC's primary function is to advise the Plant General Manager, its recommendations concerning the safety of the plant and written minutes for each meeting are provided to the Vice President-CCNPP. Therefore, the onsite reviews ensure that each activity receives a multidisciplinary independent review by qualified plant personnel. As such, the onsite review process fulfills the requirement for an independent review as defined in the standard.

Our self-assessment/corrective action program together with INPO's plant evaluation make the currently required review/audit of QA practices by OSSRC redundant. The regularly scheduled, performance-based operating plant evaluation has been a key activity to support INPO's mission since its beginning in 1979. In these evaluations, teams of institute and utility personnel compare plant performance to standards of excellence based on experience and best practices. Institute of Nuclear Power Operations also conducts review visits in selected areas to supplement the evaluation program.

Our self-assessment/corrective action program is very effective in identifying and evaluating actual or suspected conditions that are adverse to quality. In addition, INPO's events analysis programs identify and communicate lessons learned from other plant events so that we can take action to prevent similar events at our plant. Institute of Nuclear Power Operations also operates an extensive computer network through which members and participants electronically exchange information in areas such as plant operations, maintenance, operating experience, and equipment reliability. Institute of Nuclear Power Operations also helps members improve nuclear operations through assistance programs that continually evolve to meet the changing needs of the nuclear industry. Through assistance visits, working meetings, workshops, technical documents, and loan of personnel, INPO fosters comparison and the exchange of successful methods among members.

The independent review alternative, by highly experienced professionals with a wide range of expertise presented above, meets the requirement for independent review specified in ANSI N18.7-1976/ANS 3.2.

Therefore, the proposed elimination of the regulatory requirement for an OSSRC does not reduce the effectiveness of the CCNPP QAP and does not affect continued compliance with 10 CFR Part 50, Appendix B.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Ve tru GV/GT/bJd

Attachment:

(1) Marked-Up Quality Assurance Policy Change Pages cc: J. Petro, Esquire H. J. Miller, NRC J. E. Silberg, Esquire Resident Inspector, NRC Director, Project Directorate 1-1, NRC R. I. McLean, DNR G. S. Vissing, NRC W. D. Reckley, NRC

ATTACHMENT (1)

MLARKED-UP QUALITYASSURANCE POLICY CHANGEPAGES Calvert Cliffs Nuclear Power Plant, Inc.

August 20, 2003

QUALITY ASSURANCE POLICY Revision 56 LIST OF TABLES Table No. Page lB-i CALVERT CLIFFS NUCLEAR POWER PLANT'S POSITION ON ................................... 42 GUIDANCE CONTAINED IN INDUSTRY STANDARDS AND REGULATORY GUIDES LIST OF ATTACHMENTS Attachment Letter A BASES FOR QA POLICY REVISIONS (1) ....................................................................... 61 LIST OF FIGURES Figure No.

IB-L CONSTELLATION GENERATION GROUP CALVERT CLIFFS NUCLEAR POWER PLANT ..................................................................................................................................... ........................

63 LIST OF ADDENDA S Ik Addendum No.

lB-i REVIEW FUNCTIONS OF THE POSRC, PROCEDURE REVIEW COMMITTEE, r QUALIFIED REVIEWERS, E SsG ....................................................................... 64 Page 3 of 71

QUALITY ASSURANCE POLICY Revision 56 Corporate Organization and Specific Responsibilities The Corporate Organization Chart of Constellation Generation Group-Calvert Cliffs Nuclear Power Plant is shown in Figure IB-1. Persons responsible for the principal elements of the Company's Quality Assurance (QA) Program are as follows: (1)

President -Constellation Generation Group (CGG)

Senior Vice President - Constellation Generation Group - Technical Services (TS)

Vice President - Constellation Generation Group - Business Services (BS)

Vice President - Calvert Cliffs Nuclear Power Plant, Inc. (CCNPP)

Senior Manager - Engineering Services Plant General Manager-Calvert Cliffs Nuclear Power Plant Department (CCNPPD)

Manager - Nuclear Operations Department (NOD)

Manager-Nuclear Maintenance Department (NMD)

Manager - Integrated Work Management Department (IWMD)

Manager-Quality and Performance Assessment Department (QPAD)

Manager - CCNPP Engineering Services Manager-Procurement & Warehouse Services (PWSD)

Manager - Security/Emergency Preparedness Manager - CGG Information Technology Director -Nuclear Training Director - Licensing and Compliance Director -Nuclear Fuel Services Director - Project Management The management team listed above is committed to the successful implementation of theCalvert Cliffs QA Program.

Reporting to the above Vice Presidents/Managers/Directors are Directors, General Supervisors and Unit Supervisors.

H Vendors, contractors, or non-CCNPP personnel performing any maintenance/modification activities at

) CCNPP are responsible for performing these activities in accordance with applicable QA Program requirements. This can be accomplished by either developing their own QA Program procedures or by working to the QA Program through appropriate CCNPP personnel using CCNPP approved procedures.

(15)

)Two adviser) eroup quality related funmctios for plant opeations. These arc the Plant erfonn 6pet . mi Safety and recsnibilitiesare dersRc)ib dAthn dmfoy-Review 1dde-n C-emmitte1 (1SSR~G) Fthee makeup and responsibilities are described in Addendum lB-I. (19)

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QUALITY ASSURANCE POLICY Revision 56

2. OSSRC provides independent verification by review that CCNPP is operated with esa uiremnts. The OSSRC, which functions underarter approved by the President- uclear Officer), is corosite and off-site personnel knowledgeable of in-plant opert ,g eng, chemistry and radiochemistry, metallurgy, radiological safention an I s, mechanical and electrical systems, quali eand environmental factors. The of all meetings are d j nt sent to the President-CGG (Chief Nuclear Officer) Comi bers, and

tihers designated by the Committee Chairman.

The on-site POSRC reviews matters pertaining to nuclear plant safety.

I 1 C--H4iSn RRfoM lAAim R Ffinf h TinvtigatinA under the

{-9 rz ofdirectionthe Plant'eneral Maiinar gePOSRC memrSl an varegoverned by Addendum lB-1 and written procedures. (19) The results of all meetings are documented and sent to the mbeo athr the f OSSRC, and designatd by the CGmmittec Chairman.

4 £1,4 rsC/ tr AIPP The maintenance and repair of systems, c res QA Program are performed by personnel under the direction of the General Supervisors of Electrical & Controls MaintenanceHealth Physics, Mechanical Maintenance, Integrated Maintenance, Maintenance Services, chedu mg and Outage Management, and Planning and Document Management, according to written procedures and instructions prepared and approved as stated in QA Program documents. These rJ procedures:

1. Ensure that quality-related activities, such as inspections and tests, are performed with appropriate equipment and under suitable environmental conditions.

2. Indicate inspections and checks that must be made and records and data that must be kept.

3. Show where independent verifications of inspections or checks should be performed by specified personnel other than those performing the work.

When necessary, non-plant Company personnel or outside contractors are brought in to supplement the plant work force. In such instances, the approval of work procedures and the tagging of equipment are coordinated by a member of the CCNPP organization responsible for the performance of the work.

Controls are established in QA Program documents to ensure that materials and parts used in the repair, maintenance, and modification of SR and designated NSR portions of the plant are appropriate for the service intended. Written procedures are prepared for the storage and identification of materials and parts to ensure that they do not deteriorate in storage and can be correctly identified before installation or use.

Equipment manufacturers and contractors used for the repair, maintenance, and modification of SR and designated NSR structures, systems, and components are required to have quality assurance programs consistent with the importance of the end-product to safety.

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QUALITY ASSURANCE POLICY Revision 56 lB.17 QUALITY ASSURANCE RECORDS Controls have been established to ensure that quality assurance records are maintained to provide documentary evidence of the quality of SR and designated NSR items and activities. Applicable design specifications, procurement documents, test procedures, operational procedures, Technical Specifications, and other documents specify records that should be generated, supplied, or maintained by and for CCNPP.

Quality assurance records are classified as lifetime or non-permanent.

Lifetime records, maintained for particular items for the life of CCNPP, for particular items have significant value in relation to demonstrating capability for safe operation; maintaining, reworking, repairing, replacing, or modifying an item; determining the cause of an accident or malfunction of an item; and providing required baseline data for in-service inspection.

The following records shall be retained for the duration of the Facility Operating License:

a. Records and drawing changes reflecting facility design modifications made to systems and equipment described in the Final Safety Analysis Report.

b. Records of new and irradiated fuel inventory, fuel transfers and assembly burnup histories.

c. Records of facility radiation and contamination surveys.

d. Records of radiation exposure for all individuals entering radiation control areas.

e. Records of gaseous and liquid radioactive material released to the environs.

f. Records of transient or operational cycles for those facility components identified in Design Authority Program procedures.

g. Records of training and qualification for current members of the plant staff.

h. Records of in-service inspections performed pursuant to the Technical Specifications.

i. Records of Quality Assurance activities identified in this NRC approved QA Policy as lifetime records.

j. Records of reviews performed for changes made to procedures or equipment or reviews of tests and experiments pursuant to 10 CFR 50.59.

k. Records of meetings of the POSRCte Procedure Review CommitteeRC.

1. Records of the service lives of all safety related snubbers including the date at which the service life commences and associated installation and maintenance records.

Non-permanent records, which show evidence that a SR and designated NSR activity was performed in accordance with applicable requirements, are retained for periods sufficient to ensure CCNPP's ability to reconstruct significant events and to satisfy applicable regulatory requirements. Retention periods are based on requirements specified in QA Program documents. Retention periods shall be documented.

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QUALITY ASSURANCE POLICY Revision 56 1B.18 AUDITS Internal audits are performed by CCNPP's QPAD to ensure that activities and procedures established to implement the requirements of 10 CFR 50, Appendix B, comply with CCNPP's overall QA Program.

These audits'a 5040omad under the coan - f the Rovide a comprehensive independent yncation and ev at aity-re la procedures. Audits ensure the effective and proper implementation of CCNPP's QA Program. Audits of selected aspects of operational phase activities are performed with a frequency commensurate with their strength of performance and safety significance and in such a manner as to assure that an audit of all safety-related functions is completed within a period of two years. Audits and assessments may be conducted continuously (Audits specified in regulations are performed at the frequencies noted therein.) In addition to the audit subjects specified in Regulatory Guide 1.33 Revision 2 and ANSI N18.7-1976/ANS-3.2, audits performed within a period of two years shall also encompass: the Facility Fire Protection program and implementing procedures; an independent fire protection and loss prevention program inspection and audit utilizing either qualified offsite licensee personnel or an outside fire protection firm; the radiological environmental monitoring program and the results thereof; the Offsite Dose Calculation Manual and implementing procedures; the Process Control Program and implementing procedures for processing and packaging of radioactive wastes; the performance of activities required by the QA Program for effluent and environmental monitoring; and the performance of activities required by the QA Program to meet the criteria of 10 CFR 50, Appendix9 . Audits shall also encompass any other area of facility operation considered appropriate by theQS:RC er the Vice President -CCNPP. An inspection and audit of the fire protection and loss prevention program shall be performed by a qualified outside fire consultant at least once per 36 months. (19)

Vendor audits are performed to evaluate QA programs, procedures, and activities. Audits of major vendors are made early enough to ensure compliance with all aspects of CCNPP's procurement documents. Additional audits are performed as required to ensure that all requirements of CCNPP's QA Program are properly implemented according to procurement documents.

Audits are performed in accordance with pre-established written procedures or checklists by qualified QPAD personnel who have no direct responsibility for the work being audited. Technical specialists from other CCNPP departments and outside consultants may assist as necessary in performing audits.

Audits include objective evaluation of quality-related practices, procedures, instructions, activities, and items, as well as review of documents and records.

Reports of audits are analyzed and documented. Results that indicate the QA Program to be inadequate, ineffective, or improperly implemented, including the need for re-audit of deficient areas, are reported to the Manager and Supervisor of the audited activity. Controls have been established for verifying that corrective action is taken promptly to correct noted deficiencies.

To ensure that CCNPP's QPAD complies with the requirements of CCNPP's QA Program, an independent management audit of QPAD activities is performed annually by a Joint Utility Management Audit (JUMA) Team.

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QUALITY ASSURANCE POLICY QUALITY ASSURANCE POLICY Revision 56 ADDENDUM lB-1 (19)

REVIEW FUNCTIONS OF THE POSRC, PROCEDURE REVIEW COMMITTEE, QUALIFIED REVIEWERSrSAND ossc -a A 1.0 PLANT OPERATIONS AND SAFETY REVIEW COMMITITEE (POSRC) 1.1 FUNCTION The POSRC shall function to advise the Plant General Manager on all matters related to nuclear safety.

1.2 COMPOSITION The POSRC shall be composed of at least seven members, including the Chairman. Members shall collectively have experience in the following areas:

Nuclear Operations Electrical and Controls Maintenance Chemistry Mechanical Maintenance Nuclear Engineering Radiation Safety Plant Engineering Design Engineering Members shall be appointed in writing by the Plant General Manager. Members shall have a minimum of eight years power plant experience of which a minimum of three years shall be nuclear power experience. At least one member shall have a SRO license on Calvert Cliffs Units 1 and 2.

1.3 CHAIRMAN The Chairman and alternate Chairmen of the POSRC shall be appointed in writing by the Plant General Manager. Chairmen shall have a minimum of 10 years power plant experience of which a minimum of three years shall be nuclear power experience.

1.4 ALTERNATES All alternate members shall be appointed in writing by the Plant General Manager. Alternate members shall have a minimum of eight years power plant experience of which a minimum of three years shall be nuclear power experience.

1.5 MEETING FREQUENCY The POSRC shall meet at least once per calendar month and as convened by the POSRC Chairman or one of the designated alternates.

1.6 QUORUM A quorum of the POSRC shall include the Chairman or one of the designated alternate chairmen and shall consist of a majority of the members, including alternates. No more than half of the quorum shall be alternates, including an alternate chairman.

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QUALITY ASSURANCE POLICY Revision 56 1.7 RESPONSIBILITIES The POSRC shall be responsible for the following except for those items designated for review by the Procedure Review Committee or Qualified Reviewer in accordance with Addendum sections 2 and 3, respectively:

a. Review of 1) all procedures required by Technical Specifications 5.4 and changes thereto, and 2) any other proposed procedures or changes thereto as determined by the Plant General Manager to affect nuclear safety.

• Cross-disciplinary reviews of these procedures are conducted in accordance with administrative procedures in addition to the reviews conducted by POSRC, the Procedure Review Committee, or Qualified Reviewer.

b. Review of all proposed tests and experiments that affect nuclear safety.

c. Review of all proposed changes to Appendix A, Technical Specifications.

d. Review of all proposed changes or modifications to plant systems or equipment that affect nuclear safety.

e. Review of the Plant Security Plan and implementing procedures rccrnmmonded changes to the Off Site Safety Review Committe.)

f. Review of the Emergency Plan and implementing procedures shall uit

g. Review of changes to the Process Control Program and the Offsite Dose Calculation Manual.

h. Review of all 10 CFR 50.59 and 10 CFR 72.48 Evaluations that support procedures in 1.7.a and changes or modifications in 1.7.d above.

i. Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Plant General Manager, e Vice President - CCNPP

• j. Review of all Reportable Events. IM

k. Review of facility operations to detect potential safety hazards.

1. Review of any accidental, unplanned or uncontrolled radioactive release that exceeds 25% of the limits of Off We C alculation Manual (ODCM) 3.11.1.2, 3.11.2.2 or 3.11.2.3, including the p f reports covering evaluation. recomm dions and disposition of the con roedue caesent re whch ae sfetf. Mnucler Rpr to the-Pla2nt Glenfferfal M1an-ager. and the Q-ffT Sitee Safety Review oemiitcee POSRC is only required to review Fire Protection procedures and changes thereto which affect nuclear safety.

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QUALITY ASSURANCE POLICY Revision 56

<_ro uestd bythe hairan o theOffSite Safety RtidCmite

_, i. Review of Safety Limit Violation Reports.

1.8 AUTHORITY The Plant Operations and Safety Review Committee shall:

a. Recommend to the approval authority approval or disapproval of procedures considered under 1.7.a above.

b. Recommend to the Plant General Manager approval or disapproval of items considered under 1.7.b through h above.

c. Render determinations in writing with regard to whether or not each item considered under 1.7.a through h requires prior NRC approval.

d. Evaluate root causes and recommended actions to prevent recurrence for items considered under 1.7.i through I above.

e. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - CCNPP d Ch~iFMAP Fif. 4A Oa Rita 0 safau, Raviev, CQM;Rj~l~"of disagreement between the POSR and e=responsi e approva au on in e case of item 1.7.a above or between the POSRC and the Plant General Manager; however, the Plant General Manager shall have responsibility for resolution of such disagreements pursuant to ITS 5.1.1.

1.9 RECORDS The POSRC shall maintain written minutes of each meeting and copies shall be provided to the Vice President - CCNPPr;hairmah ofthe OWN Site Safety F."i Ge m Cd the Plant General Manager.

2.0 PROCEDURE REVIEW COMMITTEE 2.1 FUNCTION The Procedure Review Committee may fiuction to review items listed in 1.7.a above in lieu of review by POSRC or Qualified Reviewer as directed by the Plant General Manager.

2.2 COMPOSITION The Procedure Review Committee shall be composed of a Chairman and eight individuals who shall collectively have expertise in the areas contained in 1.2 above.

Members shall be appointed in writing by the Plant General Manager. Members shall have a minimum of eight years power plant experience of which a minimum of three years shall be nuclear power experience. At least one member shall be a POSRC member or alternate. The charter for the Procedure Review Committee shall include a description of membership, qualifications, functions, and reports and shall be described in plant administrative procedures.

The Procedure Review Committee may be dissolved at the discretion of the Plant General Manager.

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QUAIT ASUACEPLC QUALITY ASSURANCE POLICY Revision 56 2.3 CHAIRMAN The Chairman and alternate Chairmen of the Procedirie Review-Committee shall be appointed in writing by the Plant General Manager. Chairmen shall have a minimum -of eight years power plant experience of which a minimum of three years shall be nuclear power experience.

2.4 ALTERNATES All alternate members shall be appointed in writing by the Plant General Manager. Alternate members shall have a minimum of eight years power plant experience of which a minimum of three years shall be nuclear power experience.

2.5 MEETING FREQUENCY The Procedure Review Committee shall meet at least once per calendar month and as convened by the Chairman or his designated alternates.

2.6 QUORUM A quorum for the Procedure Review Committee shall consist of the Chairman or one of the designated alternate Chairmen and three primary or alternate members provided at least four disciplines are represented.

2.7 AUTHORITY - - - E The Procedure Review Committee shall:

a. Recommend to the Approval Authority approval or disapproval of procedures considered under 1.7.a above.

b. Render determinations in writing with regard to whether or not each procedure under 1.7.a above requires priorNRC approval.--

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - CCNPP ahaimann of the aff-Site Safet Reviewv Qgmmitsee~of disagreements between the roc re~ ev~iewommitte~e and the respo=nsie approval authority. The Plant General Manager shall have responsibility for resolution of such disagreements pursuant to ITS 2.8 RECORDS The Procedure Review Committee -shalt-maintain -written minutes of each meeting and copies shall be provided to the Plant General Manager.

3.0 QUALIFIED REVIEWERS 3.1 FUNCTION The Plant General Manager may designate specific procedures or classes of procedures described in 1.7.a above to be reviewed by Qualified Reviewers in lieu of review by POSRC or the Procedure Review Committee.

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QUALITY ASSURANCE POLICY Revision 56 3.2 AUTHORITY Qualified Reviewers shall:

a. Recommend to the approval authority approval or disapproval of designated procedures and changes considered under 1.7.a above and

b. Render determination in writing with regard to whether or not each procedure under 1.7.a above requires prior NRC approval.

c. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the Vice President - CCNP NPC &

r-Ch~i~an ME the Qf Sitp So~xh, £afe v~omw 2Mit of disagreements between the Qualifiedi Reviewer anid e approvaauthority. The Plant General Manager shall have responsibility for resolution of such disagreements pursuant to ITS 5.1.1.

3.3 CERTIFICATION Qualified Reviewers shall be nominated, trained, and certified in accordance with administrative procedures. Certification shall be by a department manager.

3.4 CERTIFICATION REQUIREMENTS Certification requirements of personnel designated as Qualified Reviewers shall be in accordance with administrative procedures.

Qualified Reviewers shall have:

a. A Bachelor's degree in engineering, related science, or technical discipline, and two years of nuclear power plant experience; OR

b. Six years nuclear power plant experience

- _OR

c. Equivalent combination of education and experience as approved by a Department Manager/Director.

3.5 RECORDS Review of procedures by Qualified Reviewers shall be documented in accordance with administrative procedures.

1.0 or SITS 9AFBTY RE'.qE". COMMITTEE (0SSRC) 4.1 FUNCTIO4N The 3ff-Site t Sety Review eviniiitte :hai4l faUntioU to piUvide, i c iretiview amiu audit f signat' atiitiecs. in the -to-, of-

&. nueleaf pewer-plant zpratn1s Page 68 of 71

QUALITY ASSURANCE POLICY Revision 56

b. nuclear engineering

c. c mistry and radiochemistry

d. mieta y and non-destructive examination

e. mstrume tion and control

f. radiological fety

g. mechanical and lectrical engineering

h. quality assurance p ctices 4.2 COMPOSITION The Off-Site Safety Review Co *ttee shall be composed o at least seven members, including the Chairman. Members of the -Site Safety Review ommittee may be from CCNPP or organizations external to CCNPP and hall collectively ye expertise in all of the areas of 4.1 above.

4.3 QUALIFICATIONS The Chairman, members and alternate membe f the Off-Site Safety Review Committee shall be appointed in writing by the President - (Chief Nuclear Officer) and shall have an academic degree in engineering or a physic sci ce, or the equivalent, and in addition shall have a minimum of five years technical ex rience i one or more areas given in 4.1 above. No more than two alternates shall partici te as vot members in Off-Site Safety Review Committee activities at any one time.

4.4 CONSULTANTS Consultants shall be utilized as termined by the Off-Site Sa ty Review Committee Chairman to provide expert advice to the if-Site Safety Review Committe 4.5 MEETING FREQUENCY The Off-Site Safety Reew Committee shall meet at least once per six nths.

4.6 QUORUM The quorum of e Off-Site Safety Review Committee necessary for the perfo ance of the Off-Site Safety Re ew Committee review and audit functions shall consist of more half the Off-Site Safety view Committee membership or at least four members, whichever i reater. This quorum sh 1 include the Chairman or-his appointed alternate and the Off-Site Sa ty Review Committ members, including appointed alternates, meeting the requirements of 4.3 above. No more than a minority of the quorum shall have line responsibility for operation of the plant.

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QUALITY ASSURANCE POLICY Revision 56 4.7 STCOMMITEES The hairman may establish subcommittees to perform reviews of selected items enumerated in 4.8 4.9 below. Each subcommittee shall be chartered in writing, have at least three membe /alternates, and provide reports to the full committee on the results of its reviews with any app nate recommendations.

4.8 REVIEW The Off-Site S ety Review Committee shall review:

a. The 10 FR 50.59 and 10 CFR 72.48 evaluations or changes to the facility or procedures d conducting tests or experiments competed under the provisions of 10 CFR 50.59 d 10 CFR 72.48 to verify that suchctions did not require prior NRC approval.

b. Proposed change in Technical Specifications the Operating License.

c. Violation of codes, gulations, orders, Te ical Specifications, license requirements, or of internal procedure or instructions hav g nuclear safety significance.

d. Significant operating ab ormalities o deviations from normal and expected performance of plant equipment that a ect nucl safety.

e. All Reportable Events.

f£ All recognized indications unanticipated deficiency in some aspect of design or operation of safety relate struc es, systems, or components.

g. Reports and meeting inutes of thPOSRC.

4.9 AUDITS Audits of facility ac vities shall be performe under the cognizance of the Off-Site Safety Review Committee/ese internal audits are disc sed in Section lB.18 of the QA Policy.

4.10 AUTHORITY The OSSR eports to the President-CGG (Chief Nucle Officer). This includes direct access to the CNO r any nuclear safety issues.

Oversi t of OSSRC activities is delegated to the Senior e President-CGG TS. The Senior Vic President-CGG TS will receive reports and meeting Mutes sent to the CNO and can p vide direction to the OSSRC Chairman regarding specific as for review. Additionally, the SSRC Chairman will periodically brief the Senior VP regardi OSSRC activities and issues.

The Senior Vice President will report any Nuclear Safety issues i ntified by the OSSRC to the Chief Nuclear Officer.

4.11 RECORD Records of Off-Site Safey Committee activities shall be prep d, approved and distributed as indicated below:

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QUALITY ASSURANCE POLICY Revision 56 Mintesof achOffSite Safety Review Committee meeting shall be prepared, ap pl t _ ded to the President - CGG (Chief Nuclear Officer) within Io in

b. Reports of reviews encompass l be prprd, approved and forwarded to the President-C G G_ fie)wti 4dy following 1 completion of the review.

c. Audit e passed by 4.9 above, shall be forwarded to the e - CGG ief Nuclear Officer) and to the management positions responsible for thea audited within 30 days after completion of the audit.

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