ML17159A237
| ML17159A237 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/06/1998 |
| From: | Nerses V NRC (Affiliation Not Assigned) |
| To: | Byram R PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| TAC-M96327, TAC-M96328, NUDOCS 9804100079 | |
| Download: ML17159A237 (7) | |
Text
Mr. Robert G. Byram Senior Vice President-G~tion and Chief Nuclear Officer
'ennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18101 April 6, 1998
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION(RAI) REGARDING QUALITY ASSURANCE PROGRAM CHANGES, SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNITS 1 AND2 (TAC NOS. M96327 AND M96328)
Dear Mr. Byram:
By letter dated March 19, 1998, Pennsylvania Power and Light Company (PPBL) submitted its proposed changes to the Susquehanna Steam Electric Station, Units 1 and 2 (SSES), Quality Assurance (QA) Program.
The QA Program is contained in Chapter 17.2 of the SSES Final Safety Analysis Report (FSAR).
The U.S. Nuclear Regulatory Commission staff is reviewing the March 19, 1998, submittal along with the changes proposed in Revision B of the SSES Improved Standard Technical SpeciTication (ISTS) submitted on March 2, 1998. The staff has determined that additional information is required to complete its reviews. The information that is requested relates to the
'elocation of the administrative controls currently in the Technical Specifications to the FSAR.
The specific information requested is addressed in the enclosure.
The staff requests that the additional information be provided within 30 days of receipt of this letter in order to maintain the current schedule for reviewing the SSE*S ISTS.
I On the basis of this RAI, the staff requests that PP8L refrain from implementing the QA Program changes until the staff provides formal notification of approval.
'h Ifyou have any questions, please contact me on (301) 415-1484.
t Sincerely,
. /s/
Victor Nerses, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation Docket Nos. 50-387/50-388
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&4001 April 6, 1998 Mr. Robert G. Byram Senior Vice President-Generation and Chief Nuclear Officer Pennsylvania Power and Light Company 2 North Ninth Street Allentown, PA 18.10.1......
SUBJECT:
REQUEST FOR ADDITIONALINFORMATION(RAI) REGARDING QUALITY ASSURANCE PROGRAM CHANGES, SUSQUEHANNA STEAM ELECTRIC STATION (SSES), UNITS 1 AND2 (TAC NOS. M96327 AND M96328)
Dear Mr. Byram:
By letter dated March 19, 1998, Pennsylvania Power and Light Company (PP&L) submitted its proposed changes to the Susquehanna Steam Electric Station, Units 1 and 2 (SSES), Quality Assurance (QA) Program.
The QA Program is contained in Chapter 17.2 of the SSES Final Safety Analysis Report (FSAR).
The U.S. Nuclear Regulatory Commission staff is reviewing the March 19, 1998, submittal along with the changes proposed in Revision B of the SSES Improved Standard Technical Specification (ISTS) submitted on March 2, 1998. The staff has determined that additional information is required to complete its reviews. The information that is requested relates to the relocation of the administrative controls currently in the Technical Specifications to the FSAR.
The specific information requested is addressed in the enclosure.
The staff requests that the additional information be provided within 30 days of receipt of this letter in order to maintain the current schedule for reviewing the SSES ISTS.
On the basis of this RAI, the staff requests that PPSL refrain from implementing the QA Program changes until the staff provides formal notification of approval.
Ifyou have any questions, please contact me on (301) 415-1484.
Sincerely, Ql.
Docket Nos. 50-387/50-388
Enclosure:
RAI ccw/encl: See next page Victor Nerses, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Mr. Robert G. Byram Pennsylvania Power 8 Light Company Susquehanna Steam Electric Station, Units1 8 2 CC:
Jay Silberg, Esq.
Shaw, Pittman, Potts 8 Trowbridge 2300 N Street N.W.
Washington, D.C. 20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel- -- - - -, ~-
Pennsylvania Power & Light Company-2 North Ninth Street Allentown, Pennsylvania 18101 Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania l8I01 Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O. Box 35 Berwick, Pennsylvania 18603-0035 Director-Bureau of Radiation Protection Pennsylvania Department of Environmental Resources P. O. Box 8469 Harrisburg, Pennsylvania 17105-8469 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O. Box 1266 Harrisburg, Pennsylvania 17108-1266 Regional Administrator, Region I
U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 General Manager.
Susquehanna Steam Electric Station Pennsylvania Power and Light Company Box 467 Berwick, Pennsylvania 18603 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company Rural Route 1, Box 1797 Berwick, Pennsylvania 18603 George T. Jones Vice President-Nuclear Operations Pennsylvania Power and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Chairman Board of Supervisors 738 East Third Street Berwick, PA 18603
REQUEST FOR ADDITIONALINFORMATION CHANGES TO THE QUALITYASSURANCE PROGRAM SUS UEHANNASTEAM ELECTRIC STATION SSES UNITS 1 AND 2 General Comments:
Pennsylvania Power and Light Company (PPBL) has proposed to relocate'most of the current Technical Specifications (TSs) administrative controls to Chapter 13 of the Final Safety Analysis Report (FSAR). Future changes to the information in Chapter 13 are controlled under the provisions of 10 CFR 50.59.
Nuclear Regulatory Commission (NRC) Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance,"
dated December 12, 1996, identified the need to relocate the TS administrative controls to a
-document controlled in accordance with 10 CFR 50.54(a).. Thus, subsequent changes to1hese-relocated TS provisions would be controlled in accordance with 10 CFR 50.54(a).
By relocating several of the TS administrative controls to FSAR Chapter 13, PP8L willnot be controlling future changes to the relocated administrative controls in accordance with 10 CFR 50.54(a) as addr'essed in NRC Administrative Letter 95-06.
Although several sections of the Quality Assurance (QA) Program contained in FSAR Chapter 17.2 have been revised to reference proposed TS administrative controls relocated to Section 13 of the FSAR, the NRC staff believes that the TS administrative controls proposed by PP8L to be relocated to FSAR Chapter 13 need to be relocated to FSAR Chapter 17.2.
questions:
1.
In its March 2, 1998, submittal, PP8L proposed relocating the following current TS Sections to the QA Program.
However, the staff's review of the March 19, 1998, letter and attachments indicated that the TS Sections would be relocated to FSAR Chapter 13. Provide PP8L's basis for relocating the following items to Chapter 13 and how future changes willbe controlled per 10 CFR 50.54(a):
a.
Current TS 6.5.1, "Plant Operations Review Committee," has been relocated to FSAR Section 13.4.1.
b.
Current TS 6.5.2, "Susquehanna Review Committee (SRC)," has been relocated to FSAR Section 13.4.2.
Additionally, current TS 6.2.5.10.b does not appear to have been located to either Chapter 13 or Chapter 17.2.
FSAR Section 13.4.2.3 also contains a provision for the use
, of Susquehanna Review Committee (SRC) Sub-Committees but no guidance is provided for the qualifications of subcommittee members (e.g., ANSI N3.1-1981, Section 4.7) or the subcommittee chairman (e.g., must be an SRC committee member).
The use of SRC subcommittees is not contained in current TS 6.5.2.
Provide a discussion regarding the need to incorporate this information.
c.
Current TS 6.5.3, "Technical Review and Control Activities, has been relocated to FSAR Section 13.4.1.4.1.
'urther, in the proposed relocation, the scope of the technical review activities in Section 13.4.1.4.1 failed to address all of the current TS review requirements for all of the procedures and programs required by existing TS Section 6.8. Specifically, the proposed Insert B to FSAR Section 13.4.1.4.1 makes reference to the procedures and programs ENCLOSURE
Identified in FSAR Subsection 13.4.1.3.
However, PP&L failed to address in FSAR Section 13 4.1.3 the fact that certain types of procedures and programs should be subject to the technical review process (as presently required by current TS 6.5.3 by reference to existing TS Section 6.8): Current TS Section 6.8.1, Items b, c, d, e, g, and h, have not been relocated to FSAR Section 13.4 nor any other section In FSAR Chapter 13 or Chapter 17.2.
Provide a discussion regarding where these requirements willbe relocated and addressed.
Also, in proposed Insert B for FSAR Section 13.4.1.4.1, reference is made to Section 4.4 ofANSI/ANS 3.1-1993.
Current TS Section 6.5.3 requires that these individuals be qualified to ANSI N18.1-1971.
Provide the basis forthis change.
d.
Although current TS Section 6.8.2 has been relocated to the QA Program, portions are being relocated to FSAR Section 13.4.1.4.
Further, some portions of the existing Section 6.8.2 have not been addressed in FSAR Section 13. Provide the basis for deleting these requirements.
e.
Current TS Section 6.8.3 has been relocated to FSAR Section 13.4.1.4.
2.
Current TS Section 6.13, "Process Control Program (PCP)," is being deleted.
The staff believes that this should not be deleted but rather relocated to the QA Program.
Discuss any basis for not relocating this section.
3.
PP&L proposed to revise current TS Section 6.8.1 to conform with the provisions of NUREG-1433, Revision 1.
In complying with the NUREG, PP&L proposed to delete existing items 6.8.1b, c, d, e, g, and h. Although this deletion does not affect the TSs, it does affect other FSAR sections where review activities of certain programs and procedures are required.
Provide a description of how these other review activities willbe maintained.
4.
On page 2 of the March 19, 1998, letter. PP&L states the following:
Finally, be advised that other licensing actions are expected to impact these sections of the FSAR. Examples are described in the following correspondence:
Reference 2 describes FSAR/QA changes related to NSAG, in response to a Notice of Violation.
Reference 3 describes FSAR/QA changes related to the quality assurance organization and the qualifications of the quality assurance manager.
Provide additional information which Identifies any impact that resolution of the violations in Reference 2 may have on the relocated TS administrative controls, NRC Comment Not Re uirin a PPRL Res onse:
The staff feels that the changes in Reference 3, when processed, should reflect an exception to ANSI 18.1 by indicating that for the qualifications of the QA Manager, the provisions of Section 4.4.5 of ANSI 3.1-1978 may be used in lieu ofANSI N18,1-1 971. Ifthe QA manager is considered part of the Unit Staff, it appears that PP&L needs to also reflect this exception in new TS Section 5.3.1.