ML17291A626

Discusses Clarifications of NRC Approval of Proposed Changes to Oqa Program Description

ML17291A626
Person / Time
Site:	Columbia
Issue date:	01/26/1995
From:	Parrish J WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-95-017, GO2-95-17, NUDOCS 9502020342
Download: ML17291A626 (9)

Text

yPRIDRITY. jy COCCI:.I.I:.RXI'I'.0 Rl [)S I'ROCI:.SSIX(i REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION'NBR:9502020342 DOC.DATE: 95/01/26 NOTARIZED: NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRISH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION P Document Control Branch (Document Control Desk)

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SUBJECT:

Discusses clarifications of NRC approval of proposed changes to OQA program description.

I DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket/Utili 0 NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL CLIFFORD,J INTERNAL: ACRS DRS/RGN1 1 DRS/RGN2 DRS/RGN3 1 DRS/RGN4 FIZZ:CENTER& 01 2 NRR/DISP/IMS NRR/DOTS/TQMB 1 OC/LFDCB RGN4 FILE 1 EXTERNAL: DMB/OSS IHS NRC PDR D

0 C

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RECIPIENT'I'S:

iO'I'E I 0 AI.I. "RIDS" PLFASE I IF I.P I'S To REDI.'Ct'. KKS'I'l" .(.0%'I':i( I"I'IIE DOCL'itI!N"I (:ONTROI.

) 'I'0 I'.l.l) It i'Yl'I: )'()l'R XAifE I'l()) I DESV,. ROOXI Pl 37 (EX I: 304 2(ht3 l)IS'I'Rill("I'IOiI.IS'I'!2 I'OR I)()(:l') ll X'I'4 5()t t)()i "I'I NUMBER OF COPIES REQUIRED: LTTR 22 I'.I)'OTAL ENCL ~ l3

@~i WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352.0968 ~ (509) 372-5000 January 26, 1995 G02-95-017 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 REVISION TO THE OPERATIONALQUALITYASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004), RELATED TO ANSI N18.7-1976

Reference:

1) Letter, GI2-95-007, dated January 4, 1995, T.P. Gwynn (NRC) to JV Parrish (SS), "Operational Quality Assurance Program Description (WPPSS-QA-004), Related to ANSI N18.7-1976"

2) Letter, GO2-94-243, dated October 21, 1994, JV Parrish (SS) to NRC, "Revision To The Operational Quality Assurance Program Description (WPPSS-QA-004), Related to ANSI N18.7-1976" Reference 1 provided approval of the Supply System's proposed changes to the OQAPD as described in Reference 2. The NRC approval of the proposed changes included several clarifications as documented in Enclosure 2 of Reference 1. The Supply System sought additional explanation from NRC Walnut Creek Field Office (WCFO) staff regarding one of these clarifications. Reference 1 was developed in the WCFO.

The particular clarification discussed with the WCFO staff was for the last sentence of item two on Enclosure 2. Based on this discussion, it is the Supply System's understanding that the intent of this sentence is to require that complete reviews, not partial reviews of procedures, be required to be creditable as biennial reviews for routine procedures. Partial reviews, such as procedure deviations at WNP-2, where the entire procedure is not looked at and approved as would occur for a procedure revision, are not acceptable for crediting as a biennial review.

@502020342 905000~97 PDR ADOCK P

Page 2 REVISION TO THE OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004), RELATED TO ANSI N18.7-1976 The Supply System OQAPD will include restrictions to ensure that only a comprehensive procedure review, and not a procedure deviation, be acceptable for crediting as a biennial review. Other forms of biennial reviews identified in Reference 2, such as complete use of the procedure, detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity shall be acceptable as stated in Reference 2.

Completed procedures and/or training records shall serve as adequate documentation of performance of the biennial review. The last sentence of item 2 of Enclosure 2 was not intended to apply to these other methods.

Based on our understanding gained from clarification provided by the WCFO staff, the OQAPD will be revised to state the following for the last sentence of item two of Enclosure 2:

Routine plant procedures may be reviewed in several ways, in lieu of once every 2 years:

complete use of the procedure; detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise; or other such activity. A procedure deviation is not acceptable for crediting as a biennial review. Evidence of complete procedure use and/or training records shall serve as adequate documentation for performance of the biennial review.

Please notify the Supply System should our understanding of this issue as documented above require additional discussion. Should you have any questions or desire additional information regarding this matter, please call me or D,A. Swank at (509) 377-4563.

Sincerely, X. V. Parrish (Mail Drop 1023)

Vice-President, Nuclear Operations DAS/ml CC: LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office W Ang - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N

qA 1

,~

(ACCELERATED RIDS PROCESSING REGULATORY INFORMATION DXSTRXBUTION SYSTEM (RIDS)

ACCESSXON'NBR:9502020342 DOC.DATE: 95/01/26 NOTARIZED NO DOCKET FACIL:50-397 WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH. NAME AUTHOR AFFILIATION PARRXSH,J.V. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFXLIATION P, Document Control Branch (Document Control Desk)

SUBJECT:

Discusses clarifications of NRC approval of proposed changes to OQA program description.

I DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket/Utili p NOTES:

RECIPIENT COPIES RECXPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL CLIFFORD,J INTERNAL: ACRS DRS/RGN1 DRS/RGN2 DRS/RGN3 DRS/RGN4 NRR/DISP/IMS

~ICE CENTER 0~

NRR/DOTS/TQMB OC/LFDCB RGN4~FILE EXTERNAL: DMB/OSS IHS NRC PDR D

N NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE KVKSTE! COYTACT'I'IIE DOCL'iIEYTCONTROL DESK, ROOK! P 1-37 (EXT. 504-o083 ) TO I'.LIiIINATEYOl.'R %ANIL I'ROTI DISTRIBUTION LIS'I'S I'OR DOC!.'MEN'I S YOU DON"I'EI'.D!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 22 ENCL ,~ 0

J WASHINGTON PUBLIC POWER SUPPLY SYSTEM PO. Box 968 ~ 3000 George Washington Way ~ Richland, Washington 99352-0968 ~ (509) 372-5000 January 26, 1995 G02-95-017 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Gentlemen:

WNP-2, OPERATING LICENSE NPI'-21 REVISION TO THE OPERATIONALQUALITYASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004), RELATED TO ANSI N18.7-1976 h

Reference:

1) Letter, GI2-95-007, dated January 4, 1995, T.P. Gwynn (NRC) to JV Parrish (SS), "Operational Quality Assurance Program Description (WPPSS-QA-004), Related to ANSI N18.7-1976"

2) Letter, G02-94-243, dated October 21, 1994, JV Parrish (SS) to NRC, "Revision To The Operational Quality Assurance Program Description (WPPSS-QA-004), Related to ANSI N18.7-1976" Reference 1 provided approval of the Supply System's proposed changes to the OQAPD as described in Reference 2. The NRC approval of the proposed changes included several clarifications as documented in Enclosure 2 of Reference 1. The Supply System sought additional explanation from NRC Walnut Creek Field Office (WCFO) staff regarding one of these clarifications. Reference 1 was developed in the WCFO.

The particular clarification discussed with the WCFO staff was for the last sentence of item two on Enclosure 2. Based on this discussion, it is the Supply System's understanding that the intent of this sentence is to require that complete reviews, 'not partial reviews of procedures, be required to be creditable as biennial reviews for routine procedures. Partial reviews, such as procedure deviations at WNP-2, where the entire procedure is not looked at and approved as would occur for a procedure revision, are not acceptable for crediting as a biennial review.

02020~

PDR ADOCK 0 ~000~97 p

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Page 2 REVISION TO THE OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004), RELATED TO ANSI N18.7-1976 The Supply System OQAPD will include restrictions to ensure that only a comprehensive procedure review, and not a procedure deviation, be acceptable for crediting as a biennial review. Other forms of biennial reviews identified in Reference 2, such as complete use of the procedure, detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise, or other such activity shall be acceptable as stated in Reference 2.

Completed procedures and/or training records shall serve as adequate documentation of performance of the biennial review. The last sentence of item 2 of Enclosure 2 was not intended to apply to these other methods.

Based on our understanding gained from clarification provided by the WCFO staff, the OQAPD will be revised to state the following for the last sentence of item two of Enclosure 2:

Routine plant procedures may be reviewed in several ways, in lieu of once every 2 years:

complete use of the procedure; detailed scrutiny of the procedure as part of a documented training program, drill, simulator exercise; or other such activity. A procedure deviation is not acceptable for crediting as a biennial review. Evidence of complete procedure use and/or training records shall serve as adequate documentation for performance of the biennial review.

Please notify the Supply System should our understanding of this issue as documented above require additional discussion. Should you have any questions or desire additional information regarding this matter, please call me or D.A. Swank at (509) 377-4563.

Sincerely,

. V. Parrish (Mail Drop 1023)

Vice-President, Nuclear Operations DAS/ml CC: LJ Callan - NRC RIV KE Perkins, Jr. - NRC RIV, Walnut Creek Field Office" W Ang - NRC RIV, Walnut Creek Field Office NS Reynolds - Winston & Strawn JW Clifford - NRC DL Williams - BPA/399 NRC Sr. Resident Inspector - 927N