ML17164A881

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Safety Evaluation Accepting Proposed QA Program Change
ML17164A881
Person / Time
Site: Susquehanna  
Issue date: 11/12/1998
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML17164A880 List:
References
NUDOCS 9811170255
Download: ML17164A881 (5)


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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055&0001 V

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0-3 8 1.0 ODUCT 0 By letter dated August 18, 1997, as supplemented August 12, 1998, PP8L, Inc. (PP8L) submitted proposed changes in accordance with 10 CFR 50.54(a)(3) to the Susquehanna Steam Electric Station (SSES), Units 1 and 2, Quality Assurance Program (QAP) contained in Chapter 17.2 of the Final Safety Analysis Report (FSAR). The scope of the staff's review of these QAP changes was limited to those changes identified as reductions in commitments.

PP8L has proposed changes to its Quality Assurance organizational structure that would permit the Independent Safety Assessment Group function to report directly to the Senior Vice President-Generation/Chief Nuclear Officer, the Operational Experiences Services Group (i.e.,

deficiency management) function to report to the General Manager-SSES, and the Employee Concerns Group function and the Assessment Process Services functions to be integrated into the same functional unit as the Quality Assurance function. Further, PP8L has proposed to revise the qualifications for the Quality Assurance Manager.

The following sections provide the staff's evaluation of these proposed changes.

1.

Proposed Organizational Changes The NRC reviewed and approved the PP8L Quality Assurance and Independent Assessment functions in NRC Safety Evaluation Report (SER), NUREG-0776, and Supplement 1 to the SER. PP8L later implemented organizational changes to include the Independent Safety Assessment Function, the Employee Concerns function, and the Operational Experience Services (i.e., deficiency management) function in the same functional unit as the Quality Assurance function, and the resulting organization was named Nuclear Assessment Services.

Further, subsequent to the issuance of NUREG-0776, the qualification requirements for the Quality Assurance Manager was changed by PP8L. PP8L determined in 1997 that such changes were not properly processed.

This was documented in a PP8 L Condition Report.

PP8L proposed in its August 18, 1997, letter as supplemented in its August 12, 1998, letter to obtain NRC approval to have the Independent Safety Assessment Group function report directly to the Senior Vice President-Generation/Chief Nuclear Officer and the Operational Experiences Services Group (i.e., deficiency management) function to be incorporated into the organization reporting to the General Manager-SSES.

Further, PP8L has proposed 98iii70255 'F8iif2 PDR ADQCK 05000387 P

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that the Assessment Process Services function, a function which performs various assessments of the Nuclear Department and provides guidance and resources to other Nuclear Department groups for the conduct of self-assessments, be transferred and report to the Manager-Nuclear Assessment Services.

Additionally, PP8L proposes to have the Employee Concerns function report to the Manager-Nuclear Assessment Services.

PP8L has proposed that the organizations performing the quality assurance functions of audits, surveillances, and quality control continue to report to the Manager-Nuclear Assessment Services and that these functio'ns would continue to be performed by independent line organizations within the Nuclear Assessment Services organization.

NRC a

The Quality Assurance organization proposed by PP8L continues to ensure that the quality function will be performed independently and free from cost and schedule pressures; therefore, the proposed consolidation and transfer of responsibilities continues to meet the applicable requirements of Criterion I of Appendix B.

2.

ualifica 'o o

e ana er-uc ualit Assur PP8L presently has committed that the Manager of Nuclear Quality Assurance have 10 years experience with at least 5 years of active participation in nuclear-related quality assurance functions. PP8L has proposed the following alternative qualifications for the Manager of Nuclear Quality Assurance as provided for in ANSI/ANS 3.1-1978, "Selection and Training of Nuclear Power Plant Personnel," as endorsed in the regulatory positions in RG 1.8:

".. the responsible person shall have six years experience in the field of quality assurance, preferably at an operating plant, or operations supervisory experience.

At least one year of the six years experience shall be nuclear power plant experience in the overall implementation of the quality assurance program (this experience shall be obtained within the quality assurance organization).

I'cable e ula o e uire e

Criterion II, "Quality Assurance Program," of Appendix B requires, in part, that the QA Program shall provide for the indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Standard Review Plan 17.1, Item II (1C2), last paragraph, states "The qualifications of the QA Manager should be at least equivalent to those described in Section 4.4.5 of ANS/ANSI-3.1-1978, " Selection and Training of Nuclear Power Plant Personnel," as endorsed in the regulatory positions in RG 1.8.

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'o The qualifications for the Manager-Nuclear Assessment

[Manager-Nuclear Quality Assurance] proposed by the'licensee are acceptable as'they conform to the review guidance in Item II-1C2 of Section 17.1, "Quality Assurance During the Design and Construction Phase," of NUREG 0800, "Standard Review Plan."

The proposed changes to the QAP were reviewed in accordance with Section 17.2, "Quality Assurance During the Operational Phase," Section 17.1 as referenced in Section 17.2, and Section 13.4, "Operational Review," of NUREG-0800 and were found to continue to meet the applicable regulatory requirements.

Principal Contributor:

L. Campbell Date: November 12, 1998

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