ML15112A376
| ML15112A376 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 01/05/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML15112A375 | List: |
| References | |
| NUDOCS 9901110287 | |
| Download: ML15112A376 (5) | |
Text
tptREG(, 4 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REVISED AMENDMENT 24 TO QUALITY ASSURANCE PROGRAM DUKE ENERGY CORPORATION CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 OCONEE NUCLEAR STATION, UNITS 1, 2, AND 3 DOCKET NOS. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270, AND 50-287
1.0 INTRODUCTION
By letter dated August 25, 1998, Duke Energy Corporation (DEC, the licensee) submitted Amendment 24 of its Quality Assurance (QA) Program, applicable to the Catawba, McGuire, and Oconee nuclear stations. Amendment 24 contains two changes identified by DEC as reductions in commitments under the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(a)(3). These changes are: (1) elimination of the time-based frequency requirement for the periodic review of station procedures; and (2) elimination of the description of self-initiated technical audits.
By letter dated October 26, 1998, the staff informed the licensee that proposed Amendment 24 did not contain enough information to permit an evaluation of the proposed controls based upon the staff's guidance for review of licensee-initiated changes to the requirements for frequency based procedure reviews. This guidance is set forth in a publicly available memorandum, C. E.
Rossi to M. W. Hodges, et al., dated December 21, 1992. The licensee resubmitted a revised Amendment 24, by letter dated November 19, 1998, which provided this information and revised the QA Program description accordingly.
The staff reviewed the licensee's November 19, 1998 submittal, and revised Amendment 24 against 10 CFR Part 50, Appendix B requirements. The results are set forth below.
2.0 BACKGROUND
The licensee follows the guidance of ANSI N18.7/ANS-3.2-1976, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." Regarding reviews of plant procedures, Section 5.2 of that standard states:
Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years in order to determine if changes are necessary or desirable.
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-2 The licensee's QA Program (Table 17-1) incorporates the following approved alternative to ANSI N18.7-1976 (Amendment 14, effective August 23, 1991).
Duke's program conforms to ANSI N18.7-1976 except...the frequency of review as described in Section 17.3.2.14, "Document Control," is based on ANSI N18.7/ANS-3.2 (1988) with appropriate review frequencies established not to exceed 6 years.
The applicable ANSI/ANS-3.2-1988 requirement states:
The frequency of subsequent procedure reviews (i.e., following initial review) shall be specified and may vary depending on the type and complexity of the activity involved, and may vary with time as a given plant reaches operational maturity. Review of procedures can be accomplished in several ways, including:
documented step-by-step use of the procedure (such as occurs when the procedure has a step-by-step checkoff associated with it), or detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity.
The licensee proposes to adopt the applicable requirement from ANSI/ANS-3.2-1994:
Review of procedures can be accomplished in several ways, including:
documented step-by-step use of the procedure (such as occurs when the procedure has a step-by step checkoff associated with it); or detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity. If periodic reviews are required by technical specifications, the frequency of procedure reviews shall be specified. This frequency may vary depending on the type and complexity of the activity involved and on the plant's operational experience.
The principal difference between the two revisions of ANSI/ANS-3.2 is that, whereas the 1988 revision requires that a review frequency be specified, the 1994 revision does not. (Note: The licensee's plant technical specifications have no such requirement.)
3.0 EVALUATION The licensee has identified two proposed changes to the QA Program that constitute reductions in commitments: (1) elimination of the time-based frequency requirement for the periodic review of station procedures; and (2) elimination of the description of self-initiated technical audits.
The scope of this evaluation is limited to the review of these two changes.
3.1. Review of Plant Procedures The licensee proposes the following alternative to the ANSI N1 8.7-1976 frequency-based requirement for procedure reviews:
Duke's program conforms to ANSI N18.7-1976 except...frequency for procedure review, as described in Section 17.3.2.14, "Document Control," is based on ANSI/ANS-3.2 (1994) with appropriate reviews performed when the need is
-3 identified by normal use, unusual incidents, modifications, or established quality programs. Review frequencies for Abnormal Procedures, Emergency Procedures, and Emergency Response Procedures shall not exceed six years.
Procedures that have not been used for six years shall be reviewed prior to reuse.
The licensee's August 25, 1998, submittal discusses numerous quality programs that are in place that effectively identify and initiate changes to plant procedures. These quality programs include: (1) station modification program, (2) in-house and industry operating experience program, (3) corrective action program, (4) revisions to license documents such as the Technical Specifications and the Updated Final Safety Analysis Report, (5) corrective actions for regulatory issues, and (6) administrative policy on procedures. The licensee also discusses management, supervision, and employee attentiveness to the correct use of procedures, technician training that exercises plant procedures, and quality assurance activities that include inspections, surveillances, and audits of procedures.
Staff guidance for the review of licensee-requested changes to procedure review requirements in quality assurance programs is contained in a publicly available memorandum, C. E. Rossi to M. W. Hodges, et al., dated December 21, 1992. Conformance of the licensee's alternative to ANS 18.7/ANS-3.2-1976, as submitted November 19, 1998, is evaluated in accordance with this guidance.
3.1.1 Staff Guidance (Element 1)
Element 1 - Programmatic controls should specify that all applicable plant procedures will be reviewed following an unusual incident, such as an accident, an unexpected transient, significant operator error, or equipment malfunction and following any modification to a system, as specified by Section 5.2 of N18.7/ANS 3.2, which is endorsed by Regulatory Guide 1.33.
Section 17.3.2.14 of the licensee's revised Amendment 24 states:
Procedures are reviewed for adequacy based upon: lessons learned from normal use, audits, unusual incidents (such as an accident, unexpected transient, significant operator error, or equipment malfunction), station modifications, the operating experience program, root cause analysis, or the corrective action program. The frequency of review for Abnormal Procedures, Emergency Procedures, and Emergency Response Procedures shall not exceed six years. Procedures that have not been used for six years shall be reviewed before reuse to determine if changes are necessary or desirable. Review of procedures can be accomplished in several ways, including (but not necessarily limited to) documented step-by step use of the procedure (such as occurs when the procedure has a step-by-step checkoff associated with it), or detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity. A revision of a procedure can constitute a procedure review.
-4 With reference to "applicable" procedures, as used in Element 1, a list of "applicable" procedures is provided in Section 17.3.2.14; Amendment 24 adds Abnormal Procedures and Emergency Response Procedures to the list.
Staff Evaluation: The proposed change conforms to Element 1 guidance.
3.1.2 Staff Guidance (Element 2)
Element 2 - Nonroutine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures that implement the emergency plan, and other procedures whose usage may be dictated by an event) should be reviewed at least every 2 years and revised as appropriate.
The staff has previously approved the licensee's exception to the 2-year review cycle (Amendment 14, August 23, 1991). "Nonroutine" procedures are identified by the licensee as Abnormal Procedures, Emergency Procedures, and Emergency Response Procedures; these procedures are explicitly included in the licensee's proposed alternative to ANSI N18.7-1976.
Staff Evaluation: The proposed change conforms to Element 2 guidance.
3.1.3 Staff Guidance (Element 3)
Element 3 -At least every 2 years, the Quality Assurance (or other "independent") organization should audit a representative sample of the routine plant procedures that are used more frequently than every 2 years. The audit is to ensure the acceptability of the procedures and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.
The licensee's internal audit program, as described in Section 17.3.3.2.3 of the QA Program description, requires audits to be performed on a cycle not to exceed 2 years. Amendment 24 explicitly includes a requirement to audit "the acceptability of a representative sample of station procedures, including the effectiveness of the procedure review and revision program." The licensee's corrective action program, as currently implemented, conforms to the guidance for root cause determination.
Staff Evaluation: The proposed change conforms to Element 3 guidance.
3.1.4 Staff Guidance (Element 4)
Element 4 - Routine plant procedures that have not been used for 2 years should be reviewed before use to determine if changes are necessary or desirable.
Amendment 24 conforms to this guideline, with the previously approved exception of a 6-year review cycle.
Staff Evaluation: The proposed change conforms to Element 4 guidance.
-5 3.1.5 Self-Initiated Technical Audits Self-initiated Technical Audits are performed to assess the operational readiness and functionality of a safety system, component, or structure at a nuclear station.
Input from appropriate Duke corporate departments is considered when establishing the annual audit plan. Consideration is given to problem systems and results of audits on other stations. The Manager, Nuclear Assessment and Issues is responsible for development of the audit plan and has the responsibility for organizing and directing the audits and providing audit team leaders.
Appropriate departments will supply audit team members who have the needed expertise and level of experience. Audit Reports will be distributed to the responsible management for review and appropriate action and the Nuclear Safety Review Board.
The description of self-initiated technical audits was added to the QA Program by the licensee (Amendment 11, November 12, 1987). The program is similar to the NRC-administered Safety System Functional Inspections and supplements the licensee's internal audit program described in Section 17.3.3.2.3. The licensee plans to restructure these audits to align them with similar, performance-based NRC-administered Safety System Engineering Inspections. To allow more flexibility in determining the scope and depth of future audits, the licensee proposes to eliminate the description from the QA Program.
Staff Evaluation: Since the licensee included the QA Program description of selfinitiated technical audits voluntarily and not to satisfy a regulatory requirement or concern, elimination of the description of self-initiated technical audits is acceptable.
4.0 CONCLUSION
The licensee's alternative to the frequency-based review requirement of ANSI N18.7-1976 conforms with staff guidance for such changes and is, therefore, acceptable. The program for self-initiated technical audit is neither a regulatory requirement nor implemented to satisfy a regulatory concern; elimination of the description from the QA Program is also acceptable.
Principal Contributor: Kenneth C. Heck Date: January 5, 1999