ML13316A269
| ML13316A269 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/06/1998 |
| From: | Rainsberry J SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML13316A270 | List: |
| References | |
| NUDOCS 9802110048 | |
| Download: ML13316A269 (3) | |
Text
SOUTHERN CALIFORNIA J. L. Rainsberry Manager, Plant Licensing An EDISON INTERNATIONAL" Company February 6, 1998 U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-206, 50-361, and 50-362 Quality Assurance Program Description San Onofre Nuclear Generating Station Units 1, 2, and 3
References:
- 1. SCE letter from J. L. Rainsberry to NRC Document Control Desk dated January 13, 1998,
Subject:
Quality Assurance Program Description, San Onofre Nuclear Generating Station Units 1, 2, and 3
- 2. NRC letter from Suzanne C. Black to Stephen D. Floyd (NEI) dated October 24, 1996,
Subject:
Review of Nuclear Energy Institute (NEI) Proposed Improvements to Quality Assurance Programs Enclosed for Nuclear Regulatory Commission (NRC) review and approval is Change Notice 43 to the Southern California Edison (SCE) Quality Assurance Topical Report SCE-1-A Amendment 19 dated December 1997.
Amendment 19 of the Topical Report was provided to the NRC by Reference 1. Change Notice 43 represents a reduction in the previously reviewed and approved commitments in Amendment 19.
In accordance with 10 CFR 50.54(a)(3), NRC approval of the change is required prior to implementation.
Description of Change Change Notice 43 is a request to use alternate criteria for certifying a lead Quality Assurance auditor instead of the criteria provided in ANSI N45.2.23 1978, "Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
Section 2.3.4, Audit Participation, of ANSI N45.2.23-1978 specifies that a lead auditor shall have participated in five quality assurance audits within the last three years, and one of those audits should be a nuclear quality assurance audit within the last year. The proposed change provided in Change Notice 43 bases the certification of a lead auditor on their ability to effectively implement the audit process and lead an audit San Onofre Nuclear Generating Station P. 0. Box 128 San Clemente, CA 92674-0128
.1 1l 71 A 7 O 0 A r-5 A
A 9802110048 980206 PDR ADOCK 05000206 p
- PDR,
Document Control Desk
-2 team. The lead auditor would also have participated in a nuclear quality assurance audit within the past year. Under this change, an individual does not have to wait until they have completed five audits prior to becoming a lead auditor.
Reason for Change This proposed change is one of the Nuclear Energy Institute (NEI) recommendations for quality assurance program improvements. This change will allow SCE to certify individuals who have demonstrated the ability to effectively implement the audit process and lead an audit team as lead auditor, without having to wait for them to participate in five audits. The individual would only be required to participate in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Therefore, this change will enhance the ability of SCE to rotate qualified personnel and broaden personnel experience through work in other areas, thereby making more effective use of SCE resources.
Basis for Concluding the Revised Program Satisfies 10 CFR 50 Appendix B and the Previously Accepted Quality Assurance Program Commitments As indicated above, this change is consistent with NEI's efforts to improve quality assurance programs within the nuclear utility industry. The results of the NRC's review of the NEI paper on Lead Auditor Qualifications were provided to NEI by Reference 2. In Reference 2, the NRC agreed in part with the NEI proposal for revised lead auditor qualifications and provided the following acceptable alternative to Section 2.3.4 of ANSI N45.2.23-1978:
"Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. The employer shall describe this demonstration process in written procedures or instructions and shall evaluate and document the results of the demonstration. Regardless of the methods used for the demonstration, the prospective lead auditor shall have participated in at least one nuclear quality assurance audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of Section 2.3 of ANSI N45.2.23-1978, the individual may be certified as being qualified to lead audits."
Document Control Desk
-3 This alternative provided by the NRC is the basis for Change Notice 43.
With this change, the ability to qualify as Lead Auditor based on demonstrated performance and skills provides an acceptable method of verifying that personnel are capable of implementing the audit process and leading an audit team. All other requirements of ANSI N45.2.23 regarding qualification of lead auditors will continue to be met. This approach assures that the candidate demonstrates competency prior to certification.
SCE considers this change to be a decrease in the commitments provided in the Topical Report Amendment 19 dated December 1997.
This change continues to require an individual to demonstrate their capabilities in order to be certified as a lead auditor and it provides SCE with the flexibility to certify the individual once these capabilities have been demonstrated and one nuclear quality assurance audit has been completed. Therefore, with this change the San Onofre Quality Assurance Program continues to satisfy 10 CFR 50 Appendix B and the commitments previously accepted by the NRC.
If you have any questions or need additional information on this subject, please let me know.
Sincerely, Enclosure cc:
E. W. Merschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV L. L. Wheeler, NRC Project Manager, San Onofre Unit 1 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 D. B. Spitzberg, Regional Project Inspector, San Onofre Unit 1 J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 S. S. Bajwa, Section Chief, Decommissioning Section