ML18022A913
| ML18022A913 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/01/1993 |
| From: | Mccarthy D CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| HNP-93-819, HO-930117, NUDOCS 9307070215 | |
| Download: ML18022A913 (28) | |
Text
ACCKI ERA~ D DOCUMENT DIST UTION SYSTEM II REGUL RY INFORMATION DISTRIBUTI SYSTEM (RIDS)
'ACCESSION NBR:9307070215 DOC.DATE: 93/07/01 NOTARIZED: NO DOCKET FACZL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION MCCARTHY,D.C. Carolina Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control, Branch (Document Control Desk)
SUBJECT:
Submits proposed alternative to Shearon Plant commitment to I perform biennial reviews of plant procedures per ANSI Standard N18.7-1976 re change in QA program.
DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: QA Topical Report, Change, Amendment, or Correspondence (Doc et Utili NOTES:Application for permit renewal filed. o5ooo4oo !
A RECIPIENT COP1ES RECIPIENT ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL INTERNAL: ACRS LE,N OC/LFDCB 1
8 1
1 8
1 IHS'OPIES REG FILE RPEB 01 1
2 1
2 D
RGN2 FILE 1 1 EXTERNAL: DMB/OSS 1 1 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE DOCUMENT CONTROL DESK, ROOM Pl-37 {EXT. 504-2065) TO ELIhIIYATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 17
I IJUL Oi t99S SERIAL: HNP-93-819 Letter Number: HO-930117 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR CHANGE IN QUALITY ASSURANCE PROGRAM Gentlemen:
The purpose of this letter is to submit, pursuant to 10 CFR 50.54(a)(3), a proposed alternative to the Shearon Harris Nuclear Power Plant commitment to perform biennial reviews of plant procedures as recommended by ANSI Standard N18.7-1976, Administrative Controls and Quality Assurance Requirements for Operational Phase of Nuclear Power Plants. In place of this review, Carolina Power & Light Company (CP&L) has existing programmatic controls that continually identify changes to and update procedures at the Shearon Harris Nuclear Power Plant. This change, as indicated in the attached 10 CFR 50.54(a) review, has been identified as a reduction to the commitments contained in FSAR Chapter 1.8, Conformance to NRC Regulatory Guides. Although this change has been identified as a reduction in commitment, the Quality Assurance Program continues to satisfy the criteria of 10 CFR 50, Appendix B.
CP&L believes that the proposed review process is equally as effective as that provided in ANSI N18.7-1976. In accordance with 10 CFR 50.54(a)(3)(iv), CP&L will begin implementation of the proposed change upon approval of the NRC staff or within 60 days from "the date of this letter.
Questions regarding this matter may be referred to Mr. L. S. Rowell at (919) 362-2287.
truly, gc-Yours very D. C. McCarth Manager, Regulatory Affairs RES/jbw Attachments cc: Mr. S. D. Ebneter Mr. N. B. Le Mr. J. E. Tedrow 9307070215 93070l PDR ADOCK 05000400 P PDR
ol TABLE OF CONTENTS BIENNIAL PROCEDURE REVIEW PROCESS REVISION Proposed exception to ANSI N18.7, 1976 commitments as stated in the FSAR,'Section 1.8 10 CFR 50.54 review
Attachment 1 Page 1 of 1 SHNPP FSAR Regulatory Guide 1.33 QUALITY ASSURANCE PROGRAM REQUIREMENTS (REV. 2)
(OPERATION)
Carolina Power 6 Light Company complies with this guide, which endorses ANSI N18.7-1976, with the following clarifications:
h) Paragraph 5.2.15, Review, Approval and control of Procedures: The third sentence in paragraph three is interpreted to mean: "Applicable procedures shall be reviewed following an accident, an unexpected transient or a significant operator error. Applicable procedures shall also be reviewed following an equipment malfunction which results in a reportable event.
Paragraph 5.2.15 states that, "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable. A revision to a procedure constitutes a procedure review."
In lieu of these requirements, the Shearon Harris Nuclear Power Plant has programmatic controls in place to continually identify procedure revisions which may be needed to ensure that procedures are appropriate for the circumstance and are maintained current.
Attachment 2 Page 1 of 3 10 CFR 50.54 .REVIEW PROPOSED REPLACEMENT OF BIENNIAL REVIEW OF PLANT PROCEDURES WITH PROGRAMMATIC CONTROLS FSAR Section 1.8: Descri tion of Chan es FSAR Section 1.8: Add an additional exception to the Shearon Harris Nuclear Power Plant commitment to ANSI N18.7-1976, Section 5.2.15, as endorsed by NRC Regulatory Guide 1.33, Revision 2.
Reason for Chan e Shearon Harris Nuclear Power Plant proposes deleting the recommendation for biennial review of plant procedures. Maintaining plant procedures current to preclude the use of outdated or inappropriate procedures is a continual process. The need for procedure changes may be identified at various times for different reasons. Changes are evaluated for revision and implementation at the time of identification. Shearon Harris Nuclear Power Plant has developed many programs which enhance the procedure revision process, providing assurance that procedures are appropriate for the cir'cumstance and remain current. These programmatic controls meet the intent of the biennial review process from both a technical and a practical standpoint because they constitute dynamic, rather than static, procedure review methodology. Thus, the biennial review process is redundant to the established programmatic controls and is no longer considered necessary. The existing controls are described below:
The document change program provides review assessment criteria that are applied to the procedure change process. These criteria address a number of categories, including design verification, technical adequacy, nuclear safety, system/component engineering, operations, human factors, and maintenance/1&C reviews. This program is in place to provide a mechanism for end users to identify, document, and initiate processing of procedure improvements as revisions to the affected procedure(s)".
The Nuclear Plant Modification process requires that procedures be reviewed to determine the effects of a planned plant modification.
Guidance is provided for the development of acceptance tests, requiring that tests be thoroughly reviewed for the effects on nuclear safety, and be approved by authorized personnel. Prior to acceptance of a completed modification for service, the plant operating organization verifies that the required plant procedures have been appropriately updated.
Ht The Corrective Action Program requires that an evaluation be performed for identified adverse conditions. The evaluation for adverse conditions includes the identification of procedural technical inadequacy. Root cause analysis is accomplished and corrective actions are taken for significant adverse conditions. Corrective actions may include recommended procedural enhancements, and require procedure revision. to preclude recurrence. In addition, the Corrective Action Program has in place methodology for trending procedure preparation and revision process.
l.
Attachment 2 Page 2 of 3 Administrative Procedures, the Operations Management Manual and the Maintenance Management Manual contain procedures for procedure preparation. These procedures include criteria for reviewing procedures for technical adequacy and written correctness.
The Operating Experience Feedback (OEF) Review Program ensures that operating information pertinent to the plant is supplied to various organizations as necessary for action. This process, which meets the requirements of NUREG-0737, Item I.C.5, includes NRC Notices; 10 CFR 21 reports; Significant Adverse Condition Reports; items initiated by other industry sources, such as NUMARC, AEOD, and NSSS/Vendor Service Bulletins; and INPO Significant Operating Experience Reports, Significant Event Reports, Significant by Others, Significant Event Notifications, and Operation and Maintenance reminders. This program includes provisions for ensuring appropriate corrective action is taken when an inadequacy is identified. These evaluations can have an impact on procedures and require procedure revisions to enable closure of the applicable report reviewed.
The Operating License amendment process requires that an interfacing document review be conducted and that procedures affected by the proposed Operating License amendment be identified and revised to be consistent with the amendment request. The necessary procedure revisions are tracked by the commitment tracking process discussed below.
The Commitment Tracking Program provides measures for ensuring that procedures which implement commitments made to regulatory agencies, including the NRC and INPO, are maintained current. In addition, administrative controls are in place to preclude the inadvertent negation of a commitment through the procedure revision process.
The Technical Manual/Vendor Recommendation Review Program provides specific recommendations for actions to be taken for reviewing a technical manual or vendor recommendation for applicability. Included in the review process are specific instructions for the reviewer to consider the impact of the manual/recommendation on operating and maintenance procedures, surveillance tests, and calibration procedures.
Actions resulting from these reviews are tracked until they are dispositioned as appropriate.
Management directives concerning procedure usage assign responsibility for procedure compliance and attention to detail in the performance of operational evolutions. Engineering processes include technical staff witness and assistance, as necessary, in conducting surveillance tests to ensure that tests as written work well in the field. Additionally, self-assessment is utilized as the primary means to ensure that the responsibility to maintain procedures current is properly retained by the line organizations that use the procedures.
Technical Specifications 6.5.1 and 6.8 require that the Plant Nuclear Safety Committee (PNSC) perform an overview of procedures, tests, and experiments to assure that processes are effectively maintained. This is accomplished through administrative controls that provide capability for the responsible manager to bring a procedure change to the committee's attention from a nuclear safety standpoint.
- 11. The Licensed Operator initial I Attachment Page 3 training and requalification program has formal processes in place to identify potential deficiencies of 2
3 in the emergency and adverse operating procedures and to resolve them. This includes procedure revisions, if appropriate. In addition, use of a procedure on the simulator is available as an option.to validate operational procedures.
- 12. The Emergency Drills and Exercises also have formal processes in place to identify potential deficiencies in procedures used to respond to an emergency, during periodic site scheduled and NRC required emergency drills and exercises, and to resolve them.
This also includes procedure revisions, if appropriate.
- 13. Infrequently used procedures that have a potential to cause a plant transient are reviewed prior to use to determine their adequacy. This process introduces management awareness and involvement in these evolutions. If necessary, prior to procedure usage, appropriate management responsibility is assigned, training and procedure pre-job briefings are accomplished, and temporary assignments of additional personnel are made. Utilization of these controls determines current procedure is adequate or whether changes are necessary or if the desirable prior to procedure usage.
- 14. The Nuclear Assessment Department (NAD) assesses the programs and processes identified above as part of the NAD assessment function.
These NAD evaluations are performance based to ensure their resources are properly allocated to obtain desired results. These assessments enable the NAD to focus on significant issues which may impact safety and reliability.
Based on implementation of the above programs, the recommendation contained in ANSI N18.7 - 1976 to provide for the review of procedures will continue to be met without requiring an additional biennial procedure review.
Effect of Chan e on Shearon Harris Nuclear Power Plane FSAR Cha ter 1.8 Conformance to NRC Re ulator Guides This change takes exception to a commitment previously accepted by the NRC, and changes the description of the Quality Assurance Program. Since the proposed change eliminates the biennial review of plant procedures represents a reduction in commitment.
it The basis for concludin that this chan e continues to satisf the criteria of 10 CFR 50 A endix B conformance to NRC Re ulator Guides reviousl committed to in the Safet Anal sis Re ort and the ualit Assurance ro ram reviousl acce ted b the NRC.
The requirements of 10 50, Appendix B, Criteria 5 and 6 continue to be satisfied as stated in FSAR Chapter 17. The proposed change provides an alternative method for ensuring that procedures remain current and appropriate for the circumstances'FR
'1 ACCELERA D DOCUMENT- DIST BUTION SYSTEM a,
'~ REGUL RY INFORMATION DISTRIBUT SYSTEM (RIDS)
ACCESSION NBR:9307070215 DOC.DATE: 93/07/01 NOTARIZED:,,NO' '. DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION
. MCCARTHY,D.C. Carolina Power 6 Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control .Branch (Document Control Desk) .-
SUBJECT:
Submits proposed alternative to Shearon Plant commitment to perform biennial reviews of plant procedures per ANSI Standard N18.7-1976 re change in QA program. D DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL 'IZE:
TITLE: QA Topical Report, Change, Amendment, or Correspondence (Doc et Utili NOTES:Application for permit renewal filed. o5ooo4oo / .
A RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LE,N 1 1 INTERNAL: ACRS 8 8 N /DR.IL~PEB 1 1 OC/LFDCB RGN2 FILE 1
1 1
1
~IZ,~ Ol 2 2, EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE AVASTE! 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 17 ENCL 17 m
~~ >>I V ~ 1 CME Carolina Power & Ught Company HNP 819 IJUL Oi ]99< SERIAL:
Letter Number: HO-930117 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 REQUEST FOR CHANGE IN QUALITY ASSURANCE PROGRAM Gentlemen:
The purpose of this letter is to submit, pursuant to 10 CFR 50.54(a)(3), a proposed alternative to the Shearon Harris Nuclear Power Plant commitment to perform biennial reviews of plant procedures as recommended by ANSI Standard N18.7-1976, Administrative Controls and Quality Assurance Requirements for Operational Phase of Nuclear Power Plants. In place of this review, Carolina Power & Light Company (CP&L) has existing programmatic controls that continually identify changes to and update procedures at the Shearon Harris Nuclear Power Plant. This change, as indicated in the attached 10 CFR 50.54(a) review, has been identified as a reduction to the commitments contained in FSAR Chapter 1.8, Conformance to NRC Regulatory Guides. Although this change has been identified as a reduction in commitment, the Quality Assurance Program continues to satisfy the criteria of 10 CFR 50, Appendix B.
CP&L believes that the proposed review process is equally as effective as that provided in ANSI N18.7-1976. In accordance with 10 CFR 50.54(a)(3)(iv), CP&L will begin implementation of the proposed change upon approval of the NRC staff or within 60 days from the date of this letter.
Questions regarding this matter may be referred to Mr. L. S. Rowell at (919) 362-2287.
Yours very truly, geD. CD McCarth Manager, Regulatory Affairs RES/jbw Attachments cc: Mr. S. D. Ebneter ~ 'I Mr. N. B. Le Mr. J. E. Tedrow 9307070215 930701 PDR ADOCK 05000400 P PDR
I t '
'LGPid
TABLE OF CONTENTS BIENNIAL PROCEDURE REVIEW PROCESS REVISION Proposed exception to ANSI N18.7, 1976 commitments as stated in the FSAR, Section 1.8 10 CFR 50.54 review
I Attachment 1 Page 1 of 1 SHNPP FSAR Regulatory Guide 1.33 QUALITY ASSURANCE PROGRAM REQUIREMENTS (REV. 2)
(OPERATION)
Carolina Power & Light Company complies with this guide, which endorses ANSI N18.7-1976, with the following clarifications:
h) Paragraph 5.2.'15, Review, Approval and control of Procedures: The third sentence in paragraph three is interpreted to mean: "Applicable procedures shall be reviewed following an accident, an unexpected transient or a significant operator error. Applicable procedures shall also be reviewed following an equipment malfunction which results in a reportable event.
Paragraph 5.2.15 states that, "Plant procedures 'shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable. A revision to a procedure constitutes a procedure review."-
In lieu of these requirements, the Shearon Harris Nuclear Power Plant has programmatic controls in place to continually identify procedure revisions which may be needed to ensure that procedures are appropriate for the circumstance and are maintained current.
Attachment 2 Page 1 of 3 10 CFR 50. 54 .REVIEW PROPOSED REPLACEMENT OF BIENNIAL REVIEW OF PLANT PROCEDURES WITH PROGRAMMATIC CONTROLS FSAR Section 1.8: Descri tion of Chan es FSAR Section 1.8: Add an additional exception to the Shearon Harris Nuclear Power Plant commitment to ANSI N18.7-1976, Section 5.2.15, as endorsed by NRC Regulatory Guide 1.33, Revision 2.
Reason for Chan e Shearon Harris Nuclear Power Plant proposes deleting, the recommendation for biennial review of plant procedures. Maintaining plant procedures current to preclude the use of outdated or inappropriate procedures is a continual process. The need for procedure changes may be identified at various times for different reasons. Changes are evaluated for revision and implementation at the time of identification. Shearon Harris Nuclear Power Plant has developed many programs which enhance the procedure revision process, providing assurance that procedures are appropriate for the circumstance and remain current. These programmatic controls meet the intent of the biennial review process from both a technical and a practical standpoint because they constitute dynamic, rather than static, procedure review methodology. Thus, the biennial review process is redundant to the established programmatic controls and is no longer considered necessary. The existing controls are described below:
The document change program provides review assessment criteria that are applied to the procedure change process. These criteria address a number of categories, including design verification, technical adequacy, nuclear safety, system/component engineering, operations, human factors, and maintenance/I&C reviews. This program is in place to provide a mechanism for end users to identify, document, and initiate processing of procedure improvements as revisions to the affected procedure(s):
The Nuclear Plant Modification process requires that procedures be reviewed to determine the effects of a planned plant modification.
Guidance is provided for the development of acceptance tests, requiring that tests be thoroughly reviewed for the effects on nuclear safety, and be approved by authorized personnel. Prior to acceptance of a completed modification for service, the p'lant operating organization verifies that the required plant procedures have been appropriately updated.
The Corrective Action Program requires that an evaluation be performed for identified adverse conditions. The evaluation for adverse conditions includes the identification of procedural technical inadequacy. Root cause 'analysis is accomplished and corrective actions are taken for significant adverse conditions. Corrective actions may include recommended procedural enhancements, and require procedure revision. to preclude recurrence. In addition, the Corrective Action Program has in place methodology for trending procedure preparation and revision process.
0 Attachment 2 Page 2 of 3 Administrative Procedures, the Operations Management Manual and the Ma'intenance Management Manual contain procedures for procedure preparation. These procedures include criteria for reviewing procedures for technical adequacy and written correctness.
The Operating Experience Feedback (OEF) Review Program ensures that operating information pertinent to the plant is supplied to various organizations as necessary for action. This process, which meets the requirements of NUREG-0737, Item I.C.5, includes NRC Notices; 10 CFR 21 reports; Significant Adverse Condition Reports; items initiated by other
, industry sources, such as NUMARC, AEOD, and NSSS/Vendor Service
'Bulletins; and INPO Significant Operating Experience Reports, Significant Event Reports, Significant by Others, Significant Event Notifications, and Operation and Maintenance reminders. This program includes provisions for ensuring appropriate corrective action is taken when an inadequacy is identified. These evaluations can have an impact on procedures and require procedure revisions to enable closure of the applicable report reviewed.
The Operating License amendment process requires that an interfacing document review be conducted and that procedures affected by the proposed Operating License amendment be identified and revised to be consistent with the amendment request. The necessary procedure revisions are tracked by the commitment tracking process discussed below.
The Commitment Tracking, Program provides measures for ensuring that procedures which implement commitments made to regulatory agencies, including the NRC and INPO, are maintained current. In addition, administrative controls are in place to preclude the inadvertent negation of a commitment through the procedure revision process.
The Technical Manual/Vendor Recommendation Review Program provides specific recommendations for actions to be taken for reviewing a technical manual or vendor recommendation for applicability. Included in the review process are specific instructions for the reviewer to consider the impact of the manual/recommendation on operating and maintenance procedures, surveillance tests, and calibration procedures.
Actions resulting from these reviews are tracked until they are dispositioned as appropriate.
Management directives concerning procedure usage assign responsibility for procedure compliance and attention to detail in the performance of operational evolutions. Engineering processes include technical staff witness and assistance, as necessary, in conducting surveillance tests to ensure that tests as written work well in the field. Additionally, self-assessment is utilized as the primary means to ensure that the responsibility to maintain procedures current is properly retained by the line organizations that use the procedures.
Technical Specifications 6.5.1 and 6.8 require that the Plant Nuclear Safety Committee (PNSC) perform an overview of procedures, tests, and experiments to assure that processes are effectively maintained. This is accomplished through administrative controls that provide capability for the responsible manager to bring a procedure change to the committee's attention from a nuclear safety standpoint.
I 0
Attachment 2 Page 3 of 3 ll. The Licensed Operator initial training and requalification program has formal processes in place to identify potential deficiencies in the emergency and adverse operating procedures and to resolve them. This includes proc'edure revisions, if appropriate. In addition, use of a procedure on the simulator is available as an option.to validate operational procedures.
- 12. The Emergency Drills'nd Exercises also have formal processes in place to identify potential deficiencies in procedures used to respond to an emergency, during periodic site scheduled and NRC required emergency drills and exercises, and to resolve them.
This also includes procedure revisions, if appropriate.
Infrequently used procedures that have a potential to cause a plant transient are reviewed prior to use to determine their adequacy. This process introduces management awareness and involvement in these evolutions. If necessary, prior to procedure usage, appropriate management responsibility is assigned, training and procedure pre-j ob briefings are accomplished, and temporary assignments of additional personnel are made. Utilization of these controls determines if the current procedure is adequate or whether changes are necessary or desirable prior to procedure usage.
- 14. The Nuclear Assessment Department (NAD) assesses the programs and processes identified above as part of the NAD assessment function.
These NAD evaluations are performance based to ensure their resources are properly allocated to obtain desired results. These assessments enable the NAD to focus on significant issues which may impact safety and reliability.
Based on implementation of the above programs, the recommendation contained in ANSI N18.7 - 1976 to provide for the review of procedures will continue to be met without requiring an additional biennial procedure review.
Effect of Chan e on Shearon Harris Nuclear Power Plant FSAR Cha ter 1.8 Conformance to NRC Re ulator Guides 1
This change takes exception to a commitment previously accepted by the NRC, and changes the description of the Quality Assurance Program. Since the proposed change eliminates the biennial review of plant procedures it represents a reduction in commitment.
The basis for concludin that this chan e continues to satisf the criteria of 10 CFR 50 A endix B conformance to NRC Re ulator Guides reviousl committed to in the Safet Anal sis Re ort and the ualit Assurance ro ram reviousl acce ted b the NRC ~
The requirements of 10 CFR 50, Appendix B, Criteria 5 and 6 continue to be satisfied as stated in FSAR Chapter 17. The proposed change provi'des an alternative method for ensuring that procedures remain current and appropriate for the circumstances.
4 4 ~ y ~
J A,
1 5