ML18030A079

Responds to NRC 920222 Ltr Re Violations Noted in Insp Repts 50-387/90-81 & 50-388/90-81.Corrective actions:AD-QA-101, Procedure Program Revised to Require Periodic Review of Procedure Format & Content & Industry Experience

ML18030A079
Person / Time
Site:	Susquehanna
Issue date:	05/15/1992
From:	Keiser H PENNSYLVANIA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
PLA-3766, NUDOCS 9205180284
Download: ML18030A079 (6)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

S ACCESSION NBR:9205180284 DOC.DATE: 92/05/15 NOTARIZED: YES DOCKET FACIL:50-387 Susquehanna Steam Electric Station, Unit 1, Pennsylva 05000387 50-388 Susquehanna Steam Electric Station, Unit 2, Pennsylva 05000388 AUTH. NAME AUTHOR AFFILIATION KEISER,H.W. Pennsylvania Power & Light Co.

RECIP.NAME ~

RECIPIENT AFFILIATION R Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC 920222 ltr re violations n'oted in Insp Repts 50-387/90-81 & 50-388/90-81.Corrective actions:AD-QA-101, D "Procedure Program" revised to require periodic review of procedure format & content & industry experience.

DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR i ENCL TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response

/ SIZE:

NOTES:LPDR 1 cy Transcripts. 05000387 LPDR' cy Transcripts. 05000388 D

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PDl-2 PD 1 1 RALEIGH,J. 1 1 INTERNAL: ACRS 2 2 AEOD 1 1 AEOD/DEIIB 1- 1 AEOD/DSP/TPAB 1 '

DEDRO 1 1 NRR 1 . 1 MORISSEAU,D'RR/DLPQ/LPEB10 NRR/DLPQ/LHFBPT 1 1 1 1 NRR/DOEA/OEAB 1 1 NRR/DREP/PEPB9H 1 1 NRR/DST/DIR 8E2 1 1 NRR/PMAS/I LRB1 2 1 1 NUDOCS-ABSTRACT 1 1 OMNI~ 1 1 OGC/HDS2 '. 1 1 IL 02 1 1 RGN1 FILE 01 1 EXTERNAL: EG&G/BRYCE,J.H. 1 1 NRC PDR 1 1 NSIC 1 1 NOTES:

D A

D D

NOTE TO ALL" "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

OTAL NUMBER OF COPIES REQUIRED: LTTR 24 ENCL 24

Pennsylvania Power 8 Light Company Two North Ninth Street ~Allentown, PA 18101-1179 ~ 215/774-5151

~y i5>992 Harold W. Keiser Senior Vice'resident-Nuclear 215/7744194 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Hail Station Pl-137 Washington, D.C. 20555 SUSQUEHANNA STEAN ELECTRIC STATION REPLY TO NOTICE OF VIOLATION DATED FEBRUARY 22, 1991 Docket Nos. 50-387 PLA-3766 FILE R41-2 and 50-388 Attached is Pennsylvania Power 8 Light Company's revised response to Violation Number 3 to the Notice of Violation dated 2/22/91 resulting from Inspection Nos.

50-387/90-81 and 50/388/90-81, Pennsylvania Power & Light Company has accepted the violation.

The notice required submittal of written reply within 30 days of the date of the letter. Our initial response was provided on Harch 28, 1991. As a result of a follow up inspection to the Haintenance Team Inspection conducted Harch 16-27, 1992, we have agreed to revise our response to Violation No. 3.

If you have any questions, please contact Hr. W.W. Williams at (215) 774-5610.

Very u y yours, H. W. Keiser Attachment

( l I /

'7205180284 920515 PDR ADOCK 05000387 6 PDR

FILE R41-2 PLA-3766 CC: NRC Document Control Desk (original)

NRC Region I Hr. G. S.Barber, NRC Sr. Resident Inspector Nr. J. J.Raleigh, NRC Project Hanager

AFFIDAVIT COMMONWEALTH OF PENNS YL VANIA)

SS COUNTY OF LEHIGH )

I, HAROLD W. KEISER, being duly sworn according to law, state that I am Sr. Vice President - Nuclear of Pennsylvania Power & Light Company and that the facts set forth on the attached response to Notice of Violation to NRC Combined Inspection Report Nos.

50-387/90-81 and 50-388/90-81 are true and correct to the best of my knowledge, information and belief.

Harold W. Keiser Sr. Vice President - Nuclear Sworn to and,sub~ed be or me this J5 Hay of , 1992.

Now~ Seal Martha C. Sedora, Notary PuMo AFentot'm, teh'gh Cotlty My Comrnasion Ex/res San. 15,1994 Memtxrr, Pennsylvania As".odatxm ol Nomas

REPLY T A N Tl E F VI LATION A. Kagathi~

Technical Specification 6.8.1 states: "Written procedures shall be established, implemented and maintained covering the activities referenced below:

a. The applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978."

Regulatory Guide 1.33 states "comply with the 'requirements'f ANSI N18.7-1976/ANS-3.2."

ANSI N18-7-1976/ANS-3.2, "Administrative Controls and Quality Assurance-for the Operational Phase of Nuclear Power Plants," paragraph 5.2.15, requires 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 ifchanges are necessary or desirable. Paragraph 3.2 requires persons or organizations performing functions of assuring'hat the administrative controls and quality assurance program is established and implemented or of assuring that an activity has been correctly performed shall have sufficient authority and organizational freedom to identify quality problems. Additionally, it requires that the verification of conformance to established program requirements is accomplished by a qualified person who does not have responsibility for performing or directly supervising the work, Contrary to the above, during the period October 1988 to October 1990, required procedural reviews and verification of approximately 2,000 Unit 1 and 2 procedures, including safety related maintenance procedures, surveillance procedures and checklists were conducted, but were not accomplished with independent personnel not having re'sponsibility for performing or directly supervising the procedure.

~Res nse

1. Rea on orth Vi ation Pennsylvania Power & Light Company agrees- that the periodic procedural reviews conducted during the period October 1988 to October 1990 were not accomplished in accordance with the intent of ANSI N18.7-1976. PP&L's practice of using step-by-step procedure performance to accomplish the periodic reviews represented only a review of the implementation of the technical aspects while other aspects (e.g., consistency with other new or revised procedures, industry events, etc.) were not considered.

Pennsylvania Power & Light Company believes that compliance with the requirements of Page 1

Paragraph 3.2 of ANSI N18.7-1976 is achieved by the Quality Verification function of the Nuclear Quality Assurance organization through the performance of audits and surveillances.

Quality Verification personnel are independent of the activity they are evaluating (i.e., they are qualified individuals who do not have responsibility for performing or directly supervising the work). PP&L does not believe that the independence provision of Paragraph 3.2 is to be extended to the periodic review requirement of Paragraph 5.2.15. Our periodic reviews are accomplished using a person "knowledgeable" in the area affected by the procedure being reviewed.

2. rr lv Which Have Been T k n nd heRe 1 Achi ved:

AD-QA-101, "Procedure Program", was revised to require that the periodic review include a review of procedure format and content, controls and hierarchy assuring consistency with applicable governing procedures and confirmation of correct scope, applicable industry experience, applicable SSES events, etc. The revision, issued 3/21/91, eliminated taking credit for accomplishing the periodic review solely on the basis of a step-by-step performance of the procedure. PP&L believes this position is consistent with the guidance of ANSI N18.7-1976, paragraph 5.2.15.

3. Corrective Ste s Which Will Be Taken to Avoid Further Violahons:

To further enhance the "Procedure Program" procedure and to ensure the performance of adequate technical and administrative reviews, the scope covered by the Periodic Review Form of the procedure will be broadened to include applicable industry and SSES events.

This revision will be completed by June 30, 1992.

4. Date o Full m liance:

PP&L has been in full compliance since AD-QA-101 was revised on 3/21/91.

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