ML16342A010
| ML16342A010 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/02/1993 |
| From: | Perkins K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Rueger G PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 9303090398 | |
| Download: ML16342A010 (6) | |
Text
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UNITED STATES NUCLEAR REGULATORYCOMMISSION REGION V 1450 MARIALANE WALNUTCREEK, CAUFORNIA94596-5368 Pacific Gas and Electric Company MAR n o A
, 77 Beale Street, Room 1451 P.O.
Box 770000 San Francisco, California 94177 Attention:
Hr. Gregory H. Rueger Senior Vice President and General Hanager Nuclear Power Generation
Subject:
guali ty Assurance Program Description for Diablo Canyon We hav'e reviewed the proposed change you submitted on September 21, 1992 to Chapter
The proposed change takes exception to your commitment to conduct biennial reviews of plant procedures, as stated in your FSAR
- Update, Table 17.2, which endorses Regulatory Guide (RG) 1.33, "guali ty Assurance Program Requirements (Operational),"
and American National Standards Institute (ANSI) N18.7-1976/American Nuclear Society Standard (ANS)-3.2.
The justification you provided for this change was.that your current programmatic controls ensure that plant instructions and procedures are reviewed for.
possible revision when pertinent source material is revised.
ANSI N18.7-1976/ANS-3.2, endorsed by Regulatory Guide 1.33, states 'that the-frequency of subsequent biennial procedure reviews shall be specified and may vary depending on the complexity of the activity involved.
In addition, the standard requires that applicable procedures be reviewed following a modification to'a system and following an unusual incident such as an
- accident, an unexpected transient, a significant operating error, or an equipment malfunction.
These biennial reviews are necessary to determine the adequacy of current procedures and whether changes are necessary or desirable.
We have, therefore, reviewed your request using the fol=lowing criteria:
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 ANSI N18.7/ANS 3.2.
'I 2.
Non-routine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures which implement the emergency
- plan, and other procedures whose usage may be dictated by an event) should be reviewed at least every two years and revised as appropri ate.
3.
At least every two years, the guali ty Assurance (or other "independent")
organization should audit a representative sample of the routine plant procedures that are used more frequently than every two 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 si gnificant deficiencies should be determined and corrected.
9303090398
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4.
Routine plant procedures, that have not been used for two years should be reviewed before use to determine if changes are necessary or desirable.
Your request for exception to the biennial review of plant procedures that you
'reviously committed to in Table 17.2 of your DCPP FSAR Update, and as describ'ed in your September 21, 1992 PGEE Letter No. DCL-92-204, is approved with the following exceptions:
l.
Your letter lists seven programs or. mechanisms that provide input to procedure revision and change that compensate for the biennial reviews.
These should be similarly listed on your revised Table 17.2.
2.
All applicable plant procedures should be reviewed following an unusual
- incident, such as an accident, an unexcepted transient, significant operator error, or equipment malfunction, as specified by Section 5.2 of ANSI N18.7/ANS 3.2 which is endorsed by RG 1.33.
3.
Non-routine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures which implement the emergency plan,'nd other procedures whose usage may, be dictated by an event} should be reviewed at least every two years and revised as appropriate.
4.
Routine plant procedures that have not been used for two years should be reviewed before use to determine if changes are necessary or desirable.
Should you have any questions regarding our review, please contact me or W. P.
Ang at (510) 975-0298.
Sincerely, K. E. Perkins, Jr., Director Division of Reactor Safety and Projects
Qcc:
R.
'Branch Chiefs Central Files, RV RSB/Document Control Desk (RIDS)
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/3/~/93 REQUEST COPY REQUEST COPY REQUEST COPY YES 9( NO 0 YES NO 0 YES 0 NO 0 REQUEST COPY YES NO 0 REQUEST COPY YES NO 0 PERKINS 9
~j(/ A/93 REQUEST COPY YES NO 0 SEND DCS YE NO 0 SEND TO PDR YES NO 0 RECORD NOTE:
Bob Gramm, Section Chief NRR QA, agreed with our use of the NRR criteria addressed in this letter.
This was per telecon with Bill Ang and Bill Wagner on February 26, 1993.
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