ML17290A350

Forwards Addl Info to Suppl 930510 Application for Amend to License NPF-21,changing TS Section 6.0, Administrative Controls, to Clarify Commitments Re FSAR & NUREG-0737 Covering Proposed Realignment of QA Organization

ML17290A350
Person / Time
Site:	Columbia
Issue date:	05/21/1993
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 GO2-93-118, NUDOCS 9306010001
Download: ML17290A350 (9)

Text

ACCEI ERATF DOCUMENT DISTR UTION SYSTEM REGULAT INFORMATION DISTRIBUTIO SYSTEM (RIDS)

AG ESSION NBR:9306010001 DOC.DATE: 93/05/21 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PAEcRISH.,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Forwards addi info to suppl 930510 application for amend to License NPF-2l,changing TS Section 6.0, "Administrative Controls," to clarify commitments re FSAR 6 NUREG-0737 covering proposed realignment of QA organization.

DISTRIBUTION CODE: A003D COPIES RECEIVED:LTR  ! ENCL ( SIZED TITLE: OR/Licensing Submittal: Suppl 1 to NUREG-0737(Generic Ltr 82-33)

NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDV LA 1 1 PDV PD 1 1 CLIFFORD,J 2 2 INTERNAI': RR -DRCH/HHFB11 1 1 OC/LFMB 1 0 01 1 1 RES/DSIR/EIB 1 1 EXTERNAL: NRC PDR 1 1 NSIC 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTEI CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 10 ENCL 9

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352 May 21, 1993 G02-93-118 Docket No. 50-397 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:

Subject:

WNP-2 OPERATING LICENSE NPF-21 SUPPLEMENTAL INFORMATION, REQUEST FOR AMENDMENTTO TECHNICAL SPECIFICATION 6.0, ADMINISTRATIVECONTROLS, SUPPLEMENTAL INFORMATION

Reference:

Letter G02-93-107 dated May 10, 1993, J. V. Parrish (Supply System) to NRC, Same Subject As requested by Mr. J. W. Clifford on May 11, 1993, additional details are provided to supplement information presented in the referenced letter. The additional information clarifies how the commitments, relative to the ISEG, in the WNP-2 Final Safet'y Analysis Report (FSAR) and NUREG-0737 are satisfied in the proposed realignment of the Quality Assurance organization.

The attachment contains NUREG-0737 guidance and reference to specific commitments within Appendix B of the WNP-2 FSAR. Companion provisions within the WNP-2 Technical Specifications, and specific information on how our commitments are satisfied, are then presented.

We trust this additional information provides the details needed to complete your review.

Sincerely, J..

4,z Parrish Assistant Managing Director, Operations (Mail Drop 1023)

Attachment cc: - W Bishop, EFSEC (T-146) JB Martin, NRC RV JW Clifford, NRC NRC Site Inspector (901A)

NS Reynolds, Winston & Strawn DL Williams, BPA (399) 9'3060i000i 930521 PDR 'DOCK'5000397 L P PDR

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ATTACHMENT "The rinci al functi n f he I K i to examine lant o eratin characteristics NRC i ances Licensin Information ervice advi ori and ther a ro riate sources of lant desi n and o eratin ex erience information that ma indicate areas for im rovin lant afet ." AR I.B.1.2and NURE 0737 I 81 2 o i ion.

"The N AD hall fun i n t xamine unit o er,tin hara teri ti NR i ianc indust advi ori Li en Even R ort nd ther ur funitd i n ndo eratin ex erience inf rm i n in I i in unit. f imilar d i n whi h ma indicate areas for im rovin ini ft " T 23.1 Currently, these functions are performed by the Operating Experience Review (OER) function which is a portion of the Nuclear Safety Engineering organization within the Nuclear Safety Assurance Division (NSAD). Four technical staff perform this function. Under the proposed realignment, these functions will continue to be performed by the same staff. They will report directly to the Quality Support division manager. The only change is that this function will report to a higher management level under the proposed realignment.

"Where u eful im rovement. can be a hieved it i x c ed tha this rou will develo and r ent detailed recommendati n to cor orate mana ement for such thin s as revised rocedur r e ui ment modification ." F AR I.B 1.2 and E 0737 I.B.1.2 posit~in "The NSAD shall make detailed recommendations for revi. ed rocedures e ui ment and modification. maintenan e ac ivities o eration., tiviti or th r means of im rovin unit afet to the Direct r of u li A. ur,nce" T 231 The OER staff reviews industry events and other information for applicability to WNP-2 operation and develops recommendations involving revised procedures, equipment modifications, etc to improve WNP-2 nuclear safety. Management commitment to the recommendations is obtained and actions are tracked to completion. This function will continue to be performed in the same manner in the proposed realignment.

"The ISKG is to erform inde endent review and audits of lant activities includin maintenance activiti m dificati n o erati nal r lem nd o erational anal sis and aid in the establishment of ro rammatic re uirement for lan, ctivities." AR I.B.1.2 and NUREG-07 7 I B 1 2 osition "Another function of the ISE is to maintain surveillance of lant o erations and maintenance activiti t r vide inde endent verificati n hat th e activities are erformed c rrectl and that human errors are reduced as far a racticable. ISEG will then be in iti n dvi e u ilit m, na ement n he overall ualit and safet f o erations." FSAR I.B.1.2 and NURKG-0737 I.B.1.2 osition

The NSAD shall be r on. ible for maintainin surveillance of unit activities to rovide inde endent verification that these activities are erformed correctl and human errors are reduced a much as ractical." T.. 6.2.3.3 These requirements are currently being performed by five technical staff within the NSAD who perform and lead technical assessments for the Nuclear Safety Engineering (NSE) organization.

However, this function is also a responsibility of technical staff within the current Plant Quality Assurance organization (QA surveillances) and technical staff within the Programs and Audits organization (QA audits). The technical assessments performed by NSAD staff are performance-based. The surveillance and audit functions have become increasingly more performance-based over the past several years with increased technical capabilities of the staff and a performance-based focus within these QA organizations. To properly perform these functions in a cost effective, complete manner, it has become necessary to coordinate the activities of the three groups. Currently, they operate to a joint quarterly schedule. Activities covered in depth by NSE are credited by the QA organization and duplicate review is minimized. NSE reviews QA activities and likewise plans their reviews to avoid duplication. Personnel in all three groups are tasked with the responsibility to provide independent verification that activities are performed correctly and human errors are reduced, A key expectation for personnel in all three groups is to advise management on the overall quality and safety of operations of WNP-2, The above requirement will continue to be satisfied under the proposed organizational realignment. This will be completed by three departments within the Quality Assessments division. Functional area engineers (FAEs) within these departments will be responsible for performing audits, surveillances or technical assessments within their assigned functional area.

Fourteen functional areas have been established which include operations, maintenance, engineering, fuels, testing, training/qualifications, radiological programs, licensing and support programs and others. Nine staff positions are in NSE now. The proposed realignment will move the five staff members responsible for assessments into the Quality Assessment division.

The combined staff positions responsible for assessments does not change in this realignment (five NSE, plus five QA Programs and Audits, plus nine Plant QA = 19 QA Assessment engineer staff positions).

OER personnel, along with industry peers or plant personnel, have often been involved in performing technical assessments. This practice will continue. Additionally, the OER reviews have often sent issues to the Quality organization for assessment, and this will continue.

"Rather it i an additional inde endent rou of a minimum of five dedi ated foll-time en inee located on ite but re ortin off ite to a cor orate official who hold a hi h level e hni ll -orient iti n hat i n in he man em nt chain for ower r duction. Thel K willin reasetheavailabletechni alex erti elocated n iteandwill r vide c ntinuin ternati and inde endent ass ment of lant activities." FSAR I.B.1.2 and NURK -0737 I.B.1 2 clarification

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"The N AD hall be com o ed of at lea five dedica ed full-time en ineers wi h

~ minimum of three located on site. Each shall have a bachelor' ree in en ineerin or related cience or ualifications meetin ANS 3.1 Draft Revisi n dated March 13 1 81 Section 4.2 or 4.4 or e uivalent a d cribed in Section 4.1 and at least 2 ears rofessional level ex erience in his field at least 1 ear of which ex erience shall be in the nuclear field " T 6.2.3.2 As stated above, the OER staff currently consists of four dedicated technical staff. All four currently report to the Nuclear Safety Engineering organization within the Nuclear Safety Assurance division. This same staff of four will report directly to the Quality. Support division manager. The 19 technical staff within the Quality Assessments division will be performing assessments within the various functional areas described above. Individuals who perform ISEG assessment functions within the Quality Assessment technical staff will meet the Technical Specification qualification requirements. These assessments will be the same or better quality as that currently being performed by the Nuclear Safety Engineering organization. Performance-based surveillances and audits will also be performed by the Quality Assessments organization.

The Quality Assessments division will satisfy the role of the utility independent review and audit group. All Quality Assessments division personnel are located on-site. They willreport through a Quality Assessments manager who reports to the Director of Quality Assurance. The Director, Quality Assurance, is a corporate official that holds a high level, technically oriented position that is not in the management chain for power production. While he is located on-site, this is considered appropriate for a single operating nuclear unit organization.

Quarterly planning sessions are currently performed to determine specific areas for independent assessment of plant activities. This will be continued under the proposed organizational alignment. The quarterly assessment plan, produced as a result of these activities, will contain information that clearly indicates specific staff who will be performing the ISEG type of independent assessment activities. The four OER staff members are dedicated full-time to ISEG activities. Administrative controls within the Quality Assurance directorate will ensure there is at least an equivalent of one additional full-time staff member performing the ISEG activities meeting the above qualifications.

"It is ex ected that the ISKG ma interface with the ualit a surance A or anizafion but preferably should not be an inte ral art of the A or anization." FSAR I.B.1.2 and NVREG-0737 I.B.1.2 clarification Since the time NUREG-0737 was written, the Quality Assurance organization has improved its assessment approach to become more performance based. Personnel have become more technically competent and specialists are utilized as needed. The Quality Assurance organization's scope of review encompasses all the areas an ISEG is expected to assess. Both groups are responsible for verification, as well as recommending actions for improvement of safety and operational performance.

The Nuclear Safety Engineering organization performing the ISEG functions is currently

'contained within the Quality Assurance directorate. This will continue with the proposed realignment of the Quality Assurance organization. It has been, and continues to be, the position of the Supply System that performance of ISEG functions within the Quality Assurance directorate does not lessen the effectiveness of these functions from those contemplated by NUREG-0737. Our position is that the ISEG type of functions are effectively performed under the current organization and that these functions will be performed even more effectively withiq the new organization. The distinction between ISEG and QA Assessment activities is no longer needed. Maintaining separate organizational units with essentially the same function (assessment) can lead to duplicate work and unnecessary costs.

"The functions of theISE AD re iire, il nt c wi h h r in e onnel and continued access to lant facilities and records." FSAR I.B.1.2 and NURFG-0737 I.B.1.2 clarifica ion Staff performing the ISEG and Quality Assurance functions are currently located at the WNP-2 site. They have ready access to the operating personnel, including all plant facilities and records. This will continue with the proposed realignment as the Quality Assessment division.

"Records of activities erformed b the NSAD shall be re ared maintained and forwarded each calendar month to the Director of iialit Assurance." T.S. 6.2.3.4 .

Current reporting of ISEG activities will continue with the proposed realignment. Audit, surveillance and technical assessment reports will be prepared by the Quality Assessment organizations. Industry event evaluation reports, including corrective action recommendations, will be prepared by the OER staff. Monthly reports presenting a summary record of these activities will be developed for transmittal to the Director, Quality Assurance.

The above assessment reports will also be distributed to a number of senior and middle management for their review. In addition, the audit, surveillance and technical assessment reports will be transmitted to the CNSRB for their review.

Also, the Quality Assurance directorate currently develops an Annual Report which is presented to Supply System senior management. This report provides a summary performance assessment based on the results of internal quality verification and safety assessment efforts, analysis of plant and industry events, evaluation of performance indicators, trend data and reviews by external groups. The data for this summary performance assessment comes from both NSAD (ISEG) and QA organizations. Its main purpose is to identify areas for management attention that will lead to improved future performance and have not been identified or resolved previously. This report is also presented to the Corporate Nuclear Safety Review Board (CNSRB) and the NRC for their review. Issuance of this report will continue following implementation of the proposed realignment.