ML17138B624

Documents Util Organizational & Philosophical Concepts Re Independent Safety Assessment Function Outlined at 801014 Meeting W/Nrc.Formation of Nuclear Safety Assessment Group Proposed

ML17138B624
Person / Time
Site:	Susquehanna
Issue date:	12/08/1980
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
Shared Package
ML17138B625	List: ML17138B624 ML18030A522
References
PLA-585, NUDOCS 8012110415
Download: ML17138B624 (8)

Text

REG JLA TORY I.VFORHAT ION 9 IS TRI3UT IVV 8'TEH (RIOS)

ACCESS IQV V8%: 3012110415 ')QC OA l'E: 30/12/08 VQTA~I ZE3: VQ 33C<ET Electric Stations Jait ii Pennsylva

~

FACIL:50 387 Suszu nanna Steam 50-383 Svsiueha~na Steam clectri Stations Jnit 2i oennsylv 0500038 AUTH ~ VAHE 4 J T 1QR 4FF ILIAT IQV CURTIS~ V ~ 0 ~ pennsylvania Po~er 4 Lignt Co ~

RECIP ~ NA HE RECI~IEVT 4FF ILIATIOV YOUVGBLQQQr9.J. ,iiicensi~g Branch 1 SUBJECT'. Oocuments util organizational 5 ohilosopnical conceots re in9eoendent safety assessment function outlined at 801014 meeting ~/VRC Forwation of nuclear safety assessment grouo

~

orooo.sed.

OISTRI O'JTIQV "'3OE: 80013 COPIES RECEIVEn:LTR 3 =-.VCL JSIZE:

TITLE: PSAR/FS44 AH3TS and Re I ate d Corresoondence VOTES:Send ICE 3 cooies FS49 K all amends ~ 05000387 Send IC= 3 cooi s F34% 4 all amends. 05000388

~ECI~IEVT C3~IES ECIoIEVT COPIES r3 'fTR 5VCL CQQE/VAHE LTTR =VCL AC T Ior~: ~/O L t."E lS V- 1 0 YQJVGBLOJQi3 1 0 RJS99933<gH, 1 0 STAR'KgR ~ 04 1 IvTERNAL: ACCID Ev4 1 1 AUX SYS 3R 07 1 1 C~E i =VG 39 03 1 1 CQVT SYS 39 09 1 1 CORE ~ELF 9% lp 1 EFF TR SYS 3812 1 1 c Hc~G Plc? 22 1 0 EQUIP QUAL) 3%13 3 3 EOSC I =VC=S 14 1 1 HUH FACT EVG 1 1 iYQ/GE3 99 2 2 14" SYS 3R ib 1 1 ICE Qb 3 3 LIC GUIQ 3% 1 LIC QJAL, 38 1 1 NATL EVG 30 17 1 1 lECH =V" 3R 1 1 HPA 1 0 VRC P39 02 1 1 OE~ 9 0 OP LIC 3R 1 1 POHER SY3 3R 19 1 1 P "QC/TST i'd 20 1 1 QA BR 21 1 1 RA 3%22 1 1 RE4C SYS BR 23 1 1 EG ct Pl 1 1 SIT AVAL 3% 24 1 EVG 9925 1 1 SYS IVTERA" 3R 1 1 EXTER'VAL: 4CRS 27 ib 16 LP38 1 1 VSIC 05 1 1 OEO T g )98O TQTAl VUH9ER Qc. C3>~1=3 RE.3 JI REQ, LTTR ~

C,O EVCI

PPILL TWO NORTH NINTH STREET, ALLENTOWN, PA. 18)01 PHONEr (215) 821-5151 NORMAN W. CURTIS Vice President- Engineering C Ccnstrrrcticn- Nucrear 821-5381 December 8, 1980 Mr. B. J. Youngblood, Chief '

Licensing Branch No. 1 U.S. Nuclear Regulatory Commission Washington, DC 20555 SUSQUEHANNA SES NUCLEAR SAFETY ASSESSMENT PLANS DOCKET NOS.-

ER 100450 FILE 841-02 50-387 PLA- 585 and 50-388

Dear Mr. Youngblood:

On October 14, 1980, a meeting was held between members of our respective staffs to discuss, among other subjects, PP&L's intentions with respect to providing an independent safety assessment function. At that meeting, we presented our organizational and philosophical concepts on safety assessment including the independent safety engineering group function.

This letter serves to formally document those concepts as requested by Mr. R. Stark, your Project Manager for Susquehanna.

~Back ccucd In December 1979, PP&L initiated a program of changes designed to strengthen the Company's current and long term internal management of the construction and operating phases of the Susquehanna nuclear plant.

As a result of this program, a singular purpose nuclear department was formed and a new senior executive management position established. A current management organization chart is attached as Exhibit A.

Prior to the issuance of Mr. Denton's letter of May 13, 1980 (SECY 242), which described the concept of an Independent Safety Engineering Group (ISEG), PP&L had determined to establish an independent Nuclear Safety Assessment Group (NSAG). This group was invisioned as providing an independent evaluation of all of PP&L's nuclear activities with particular emphasis on assessing the effectiveness and quality of the Companyrs nuclear operations and related safety programs. Upon further PoO/

development of this concept, and giving consideration to Mr. Denton's letter and %JREG-0731, it was decided that NSAG would not replace or incorporate the functions of either the on-site or off-site review/audit groups nor would it relieve line management of any of its responsibilities.

Additionally, it was decided to include the ISEG function within the bounds of NSAG's charter. The NSAG organization, as shown in Exhibit B, was then formalized.

PENNSYLVANIA POWER 8 LIGHT COMPANY 8 o-,.~, 01>

0 Mr. B. J. Younglood December 8, 1980 Page 2 The following amplifications and clarifications are intended to aid in understanding PP&L's safety assessment and corporate management philosophy.

1. The Corporate Management Committee (CMC), with the exception of the Board of Directors, is the highest level corporate "governance" committee. The CMC, which normally meets one full day per week, overviews Company operations, reviews and/or makes major policy and financial decisions, critically examines all issues having significant public or regulatory impact and provides explicit direction as to the future course of Company activities. The Senior Vice President-Nuclear is a corporate officer and member of CMC.

2. This Senior Vice President-Nuclear position was created because of the need perceived by PP&L executive management to "bring a great depth of experience in nuclear plant operations and maintenance" to the Company's decision making bodies. The responsibilities of the Senior Vice President-Nuclear can be best understood by reiterating his CMC membership. It should be recognized that the Senior Vice President-Nuclear is charged with the same responsibilities for all concerns which touch the Company (e.g. financial, personnel, operations, etc.) as are all other CMC members and in turn, they provide a broad corporate overview of nuclear activities.

3. The Vice President-Nuclear Operations is the corporate officer in the direct management chain for nuclear power production.

The Superintendent of Plant Susquehanna reports to this position.

4. The Vice President-Engineering & Construction Nuclear is the corporate officer responsible for nuclear plant engineering, licensing and project construction.

NSAG Or anizational Structure In establishing the NSAG concept, PP&L executive management desired to charge a single manager with the sole task of assessing the totality of PP&L's nuclear activities. In order for this manager to be effective within PP&L's internal corporate structure, and to assure that NSAG reviews, assessments and recommendations are effectively presented and timely considered, an NSAG presence in the general office was deemed appropriate. Consequently, NSAG was structured with both on-site and off-site sections.

NUREG-0731 conceptualizes the Independent Safety Engineering Group and stipulates review functions. The relevant portion of those review functions are reproduced verbatum in Exhibit C.

Mr. B. J. Youngblood December 8, 1980 Page 3 Based upon PP&L's internal organization structure and the physical separation between the general office and plant, several of these functions can best be performed in PP&L's general office.

To cite some examples:

o An assessment of the timeliness, effectiveness and quality of the General Office's response to plant initiated requests.

o An evaluation to determine the extent to which relevant industry experience is being factored into design considerations.

o Comparison of Susquehanna operating experience with plants of similar design.

NSAG's general office section will be responsible for the conduct of administrative duties associated with NSAG's plant section. Thus, the on-site section will be able to devote its time to the conduct of its functions with minimum distractions. It is expected that the Shift Technical Advisors (STAs) and NSAG's on-site organization will mutually benefit from frequent exchanges of information and experience.

Giving consideration to the tasks accomplished in the general office and the benefit derived from interaction with the STAs, we believe that the organization shown in Exhibit B more than meets the intent of NUREG-0731. It should be further stated that although our on-site complement is somewhat smaller than that discussed in NUREG-0731 and subsequently in NUREG-0737, our total staffing is in excess of current Nuclear Regulatory Commission guidance.

NSAG Re ortin Structure In determining the reporting chain for NSAG, consideration was given to both NUREG-0731 guidance and PP&L's management structure with major emphasis on the goal of achieving an effective NSAG function. The selected reporting structure (Manager-NSAG to Senior Vice President-Nuclear) has NSAG reporting to a senior corporate officer not in the direct management chain for nuclear power production who has the experience and knowledge to timely evaluate proposals and who has been granted the authority to make and implement decisions. In view of the fact that the Senior Vice President-Nuclear position was specifically created to provide a depth of nuclear experience and knowledge to PP&L's senior executive management, we believe that any attempt to have NSAG report higher than this level would be detrimental to the safety assessment function. That is, nuclear safety assessment items submitted to a higher level would be referred back to the Senior Vice President-Nuclear at the cost of timely response. It should be noted that NSAG will prepare periodic reports providing a synopsis of their activities and an evaluation of their findings. These reports wi,ll be distributed to all members of the Corporate Management Committee to assure a broad corporate overview.

Mr. B. J. Youngblood December 8, 1980 Page 4 Conclusion Although we differ in exact implementation details, we believe NSAG, as described he'rein, meets or exceeds the intent of NUREG-0731 with regard to the ISEG function; therefore, we presume the above is responsive and acceptable. Accordingly, we plan to continue with the implementation of NSAG unless you inform us of the need for further clarification.

Sincerely,

/

Norman N. Curtis

EXHIBIT C NaZG-0731 ECZRACT

1. Evaluation for technical adequacy and clarity of all procedures important o the safe operation of the facility.

2. Evaluation of plant operations from a safety perspective.

3. Evaluation of the effectiveness of the quality assurance program.

4. Comparison of the operating experience of the plant and plants.

5. Assessment of plant performance regarding conformance to requirements related to safety.

6. Any other matter involving safe operation of the nuclear power plant that an independent review deems appropriate for con-sideration.

7. Assessment of plant safety programs.