ML17059A137
| ML17059A137 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/10/1993 |
| From: | Durr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sylvia B NIAGARA MOHAWK POWER CORP. |
| References | |
| NUDOCS 9312170035 | |
| Download: ML17059A137 (6) | |
Text
DEC I 0 l993 Docket Nos.
50-220 50-410 Mr. B. Ralph Sylvia Executive Vice President - Nuclear Niagara Mohawk Power Corporation 301 Plainfield Road
- Syracuse, New York 13212 9~
+orle Dear Mr. Sylvia;
SUBJECT:
OPERATIONAL AND FIRE PROTECTION QUALITYASSURANCE PROGRAM CHANGES AT NINE MILEPOINT, UNIT 1
Reference:
Letter dated July 22, 1993, from Mr. R. W. Cooper, Director, Division of Reactor Projects, Region I to Mr. S. A. Varga, Director, Division of Reactor Projects, I/II,NRR, "Request for Technical Assistance on Operational and Fire Protection Quality Assurance Program Changes at Nine Mile Point."
We have completed our review of the proposed change to the Nine Mile Point Quality Assurance (QA) Program contained in the 10 CFR 50.71(e) submittal, transmitted to us by the referenced correspondence.
The changes described in Revision 11 of the Unit 1 Updated Final Safety Analysis Report (UFSAR) involved the incorporation of the Quality Assurance Topical Report (NMPC-QATR-1) into the UFSAR as Appendix B and the combining of the Fire Protection Quality Assurance Program description (NMPC-FPQAP) into NMPC-QATR-1, The quality assurance program changes described in the subject submittal were reviewed in accordance with the requirements of 10 CFR 50.54(a) and the acceptance criteria specified in NUREG-0800, "Standard Review Plan," Sections 9.5 and 17.2.
Based on our evaluation of the Niagara Mohawk Corporation submittal, dated June 30, 1993, it was determined that these revisions continue to satisfy the requirements of 10 CFR Part 50, Appendix B and are therefore acceptable.
However, during the conduct of our review, the Senior Project Manager for Nine Mile Point, Mr. Don Brinkman, indicated that subsequent to their June 30 submittal, Niagara Mohawk had implemented significant changes within their onsite quality assurance organization.
PDR 93121ADOCK 05000220 70035 931210 PDR P
4
DEC I 0 1993 Niagara Mohawk Power Corporation As a result of several telephone conference calls, which concluded with a discussion between Mr. R. Latta of the Performance and Quality Evaluation Branch, NRR and Mr. M. McCormick of the Niagara Mohawk Power Corporation on October 4, 1993, it was ascertained that you had eliminated the position of Vice President - Quality Assurance (VP-QA) and had alternatively created the lower level position of General Manager Safety Assessment, Licensing and Training (SALT) to carry out the responsibilities previously assigned to the VP-QA. As described in Niagara Mohawk's letter to the NRC, dated October 13, 1993, the General Manager SALT currently has the Managers QA, Licensing, and Training functionally reporting to him.
Although you determined that this change in your quality assurance program did not represent a reduction in commitment as described in 10 CFR.50.54(a)(3), the NRC does not concur with this conclusion.
Specifically, the inclusion of line function activities, i.e.,
licensing and training under the General Manager SALT, would violate the necessary degree of independence between the personnel who perform verification activities in QA and those who perform the line functions. It is also our position that this condition would diminish the ability of the General Manager to focus full-time on quality-related activities and would thus have a negative safety benefit, Additionally, the current docketed UFSAR Revision 11, organization specifies a QA manager for each unit who reports to the Vice President - Quality Assurance and a manager of QA support (procurement, audits, and assessments) who also reports to the Vice President-Quality Assurance.
We have concluded that the alternative organizational structure where the Manager QA reports to the General Manager SALT, at a lower level than previously
- approved, has degraded the responsibility of the Manager QA and that this condition could adversely affect the ability of the QA organization to perform their safety verification function.
In conclusion, the above noted conditions represent an apparent reduction in commitment from the program description previously accepted by the NRC and willrequire modification in order to achieve compliance with 10 CFR Part 50, Appendix B. It is also noted that changes to the quality assurance program description that reduce commitments are required to be submitted to the NRC and receive NRC approval prior to implementation.
Sincerely, Jacque P. Durr, Chief Engineering Branch Division of Reactor Safety
OEC I 0 i993 Niagara Mohawk Power Corporation CC:
C. Terry, Vice President - Nuclear Engineering M. McCormick, General Manager, Safety Assessment, Licensing &Training K. Dahlberg, Unit 1 Plant Manager J. Mueller, Unit 2 Plant Manager D. Greene, Manager, Licensing J. Warden, New York Consumer Protection Branch G. Wilson, Senior Attorney M. Wetterhahn, Winston and Strawn Director, Energy & Water Division, Department of Public Service, State of New York C. Donaldson, Esquire, Assistant Attorney General, New York Department of Law Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York, SLO Designee bcc w/encl:
Region I Docket Room (with concurrences)
C. CowgiH, DRP L. Nicholson, DRP R. Fuhrmeister, DRP B. Norris - Nine Mile Point W. Dean, OEDO R. Capra, NRR J. Menning, NRR D. Brinkman, NRR S
RI:DRS Durr 11/
93 12//4/93 OFFICIALRECORD COPY A:NMCHANGE.QA
0