ML18101B130
| ML18101B130 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 12/06/1995 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCR-94-05, LCR-94-10, LCR-94-5, LR-N95110, NUDOCS 9512130297 | |
| Download: ML18101B130 (12) | |
Text
Public Service Electric and Gas Company Louis F. Storz Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700 Senior Vice President - Nuclear Operations DEC 0 6 1995 LR-N95110 LCR 94-05 LCR 94-10 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
LICENSE AMENDMENT APPLICATION QUALITY ASSURANCE AUDIT FREQUENCY REVISIONS HOPE CREEK AND SALEM GENERATING STATION FACILITY OPERATING LICENSE NOS. NPF-57, DPR-70 AND DPR-75 DOCKET NOS. 50-354, 50-272 AND 50-311 By letter.dated April 13, 1994, Public Service Electric & Gas
- (PSE&G) submitted an amendment request to revise the Quality Assurance (QA) audit frequencies in the Hope Creek and Salem Unit Nos. 1 and 2 Technical Specifications.
Pursuant to the requirements of 10CFR50.91(b) (1), a copy of the amendment* request was provided to the State of New Jersey.
By letter dated June 27, 1994, the State of New Jersey Department of Environmental Protection and Energy Bureau of Nuclear Engineering (BNE) transmitted comments on the amendment request to the NRC.
This letter provides the PSE&G response to the BNE comments.
In, the BNE comments along with the PSE&G responses are provided.
In addition, Attachment 1 addresses a portion of the proposed changes which are being withdrawn.
Attachments 2 and 3 provide revisions to the April 13, 1994 submittal which reflect clarifications made in Attachment 1.
Should you have any questions regarding this response, we will be pleased to discuss them with you.
Sincerely,
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Document Control Desk LR-N95110 Attachments (3)
- C Mr. T. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 DEC 0 6 1995 Mr. L. N. Olshan, Licensing Project Manager - Salem U. S. Nuclear Regulatory Commission One White Flint.North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. D. H. Jaffe, Licensing Project Manager - Hope Creek U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. C. S. Marschall (S09)
USNRC Senior Resident Inspector - Salem Mr. R. W. Summers (S09)
USNRC Senior Resident Inspector - Hope Creek Mr. K. Tosch, Manager IV NJ Departmeht of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 95-4933
- ATTACHMENT 1 PSE&G RESPONSE TO BNE COMMENTS
- 1.
Resource Reallocation BNE Comment:
"We note that PSE&G's letter justifies this change on the basis that added flexibility in scheduling audits will be. gained so that resources can be allocated to areas with perceived weaknesses.
However, PSE&G includes this change as a Cost Beneficial Licensing Action.
PSE&G estimates that under "optimal conditions," the proposed change will yield a
$2.4 million cost savings.
From this, we conclude that, overall, PSE&G intends to reduce the resources committed to their audit program, not reallocate resources to weaknesses.
The purpose of this change should be clarified."
PSE&G Response:
The proposed changes do not represent a reduction in resources committed to the Quality Assurance (QA) audit program.
The proposed changes would allow Technical Specification audits to be reduced to a biennial frequency based on program performance.
The reduction in the Technical Specification audit frequency would result in a net increase in available resources within the QA audit program.
These resources could then be used for other QA program audits.
Public Service Electric & Gas (PSE&G) notes that the scope of the audit program is not limited to Technical Specification audits.
The cost savings figure was specific to the reduction in the Technical Specification audit frequencies.
This cost savings was provided to quantify the reduction in regulatory burden associated with the proposed changes.
It was not intended that a reduction in resources would result; flexibility in allocating resources was intended.
As noted above, the intent of the proposed changes is not to reduce resources.
However, this should not be interpreted to imply that PSE&G will never reduce resources.
Performance improvement is an expectation of PSE&G management.
This expectation is applicable to the QA audit program.
At some future date, performance improvement may be at a level where resources for the QA audit program could be reduced without adversely affecting performance.
Page 1 of 2
- ATTACHMENT 1 PSE&G RESPONSE TO BNE COMMENTS
- 2.
Audit Frequency Extension BNE Comment:
"In response to operating events, NRC violations and PSE&G's own initiative, reorganization of plant staff including numerous personnel changes are underway at Salem.
At this critical time, extending audits of Salem activities to a 2 year frequency is clearly not appropriate."
PSE&G Response:
The proposed changes do not merely extend Technical Specification audits to a biennial frequency.
The proposed changes would permit the frequency of Technical Specification audits to be determined based upon performance.
If management determines program performance is acceptable, audit frequency may be reduced.
Conversely, if performance does not meet management's expectations audit frequency would remain as currently specified or, possibly increased over current Technical Specification requirements.
In addition, the proposed ~nserts for the Updated Final Safety Analysis Report (UFSAR), previously submitted by our letter dated April 13, 1994, have been clarified to reflect the above.
The clarification indicates that Technical Specification audits will be performed "at least" biennially.
This clarification assures the proposed revisions to the UFSAR reflect the fact that audit frequency extension is based on performance.
The UFS.AR pages are re-submitted with this clarification for Hope Creek and Salem in Attachments 2 and 3.
- 3.
Withdrawal of 25% Extension The amendment request proposed a 25% extension to the biennial audit frequency.
PSE&G withdraws this proposed change from our supmittal dated April 13, 1994.
Revised UFSAR pages which reflect withdrawal of the 25% extension are provided for Hope Creek and Salem in Attachments 2 and 3.
Page 2 of 2
- ATTACHMENT 2 PROPOSED REVISIONS TO THE HOPE CREEK UPDATED FINAL SAFETY ANALYSIS REPORT FACILITY OPERATING LICENSE NO. NPF-57 DOCKET NO. 50-354
17.2.17 Quality Assurance Records Records necessary to demonstrate that activities important to quality have been performed in accordance with applicable requirements are identified and maintained in accordance with Regulatory Guide 1.88, as noted in Section 17.2.2.
Documents shall be considered valid records only if stamped or initialed or signed and dated by authorized personnel or otherwise authenticated.
Record types, as a
- minimum, comply with applicable technical specification requirements and include operating logs, maintenance and modification procedures and related inspection results and reportable occurrences.
Design and other QA records are replicated via microform and stored in record facilities at the generating station and at offsite locations.
The Nuclear Department is responsib1e for the permanent storage of station records.
The retention period for records; permanent storage location; and methods of control, identification, and retrieval are specified by administrative procedure.
Individual station department heads are responsible for submitting applicable department records to the designated location for retention.
17.2.18 Audits Audits of PSE&G and supplier organizations that intplement the QA program are performed by QA to verify compliance with the applicable portions of the program through personnel interview and review of applicable documents and records, as required.
An annual audit schedule is prepared, identifying audits to be performed and frequency.
Audits are conducted by audit teams comprised of a certified lead auditor and certified auditors, and technical specialists (when deemed necessary).
17.2-42 HCGS-UFSAR Revision 5 May 11, 1993
Audits are conducted using preestablished written procedures and checklists.
Areas of deficiency revealed by audits are reviewed with management and are corrected in a timely manner.
Required corrective action is documented and verified.
Followup action, including reaudit of deficient areas, is performed.
\\
The audit program conducted by QA includes, but is not limited to, the following activities covered by the QA program:
- 1.
Operation, maintenance, and modification
- 2.
Preparation,
- review, approval, and control of design, specifications, procurement and requisition documents, instructions, procedures, and drawings
- 3.
Inspection programs
- 4.
Indoctrination and training
- 5.
Implementation of operating and test procedures
- 6.
Calibration of measuring a~d test equipment
- 7.
Fire protection applicable activities delineated in Table The audit data is analyzed and a written report of the results of each audit is distributed to appropriate man~gement representatives of the organization(s) audited, as well as other affected management personnel.
Included in the report is a statement of QA program effectiveness.
QA is audited by independent auditors at least every two years to verify implementation of the corporate QA program.
Reports of these audits are directed to appropriate PSE&G management personnel.
17.2-43 HCGS-UFSAR Revision 4 April 11, 1992
LR-N95110 LCR 94-05 LCR 94-10 HOPE CREEK UFSAR INSERT Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview~ observation of activities. in process, and review of applicable documents and records as required.
An annual audit schedule is developed to identify the audits to be performed and their frequency.
A dominant factor in audit schedule development is performance in the subject area.
Audit.schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR.
Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that at least biennial (2 years) audits of safety related activities are performed.
A list of operational phase activities subject to the audit program is provided in the Technical Specifications and in Table 17.2-1.
LR-N95110 LCR 94-05 LCR 94-10 ATTACHMENT 3 PROPOSED REVISIONS TO THE SALEM GENERATING STATION UPDATED FINAL SAFETY ANALYSIS REPORTS FACILITY OPERATING LICENSE NOS. DPR-70 AND DPR-75*
DOCKET NOS. 50-272 AND 50-311
Design and other QA records are replicated via microform and stored in. record facilities at the generating station. and offsite locations..
The Nuclear Department is responsible for the permanent storage of station records.
The retention period for records; permanent storage location; and methods of control, identification, and retrieval are specified by administrative procedure.
Individual station department heads are responsible for submitting. applicable department records to the designated location for retention.
17.2.18 Audits Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program through personnel interview and review of applicable documents and records, as required.
An annual audit schedule is prepared, identifying audits to be performed and their frequenc Audits are conducted by audit teams comprised of a certifi~d lead auditor, certified auditors, and technical specialists (when.deemed*
necessary).
Audits are conducted using preestablished written procedures and checklists.. Areas. of deficiency revealed by audits are reviewed with management and are corrected in a timely manner.
Required corrective action is documented and verified.
Followup action, including reaudit of deficient areas, is performed.
The audit program conducted by QA includes, but is not limited to, the.following activities covered by the QA program:
- 1.
Operation, maintenance, and modification.
- 2.
Preparation, review,
- approval, and control of design, specifications, procurement and requisition documents, instructions, procedures, and drawings. 17.2-40 SGS-UFSAR Revision 11 July 22, 1991
- 3.
Inspection programs.
- 4.
Indoctrination and training.
- 5.
Implementation of operating and test procedures.
- 6.
Calibration of measuring and test equipment.
- 7.
Fire protection.
- 8.
Other applicable activities delineated The audit data is analyzed, and a written report of the results of each audit is distributed to appropriate management representatives of the organization(s) audited, as well as other affected management personnel.
Included in the report is a statement of QA program effectiveness.
QA is audited by independent auditors at least every 2 years to verify implementation of the corporate QA program.
Reports of these audits are directed to appropriate PSE&G management personnel.
- 17. 2-41 SGS-UFSAR Revision 10 July 22, 199"0
- SALEM UFSAR INSERT Audits of PSE&G and supplier organizations that implement the QA program are performed by QA to verify compliance with the applicable portions of the program, through personnel interview, observation of activities in process, and review of applicable documents and records as required.
An annual audit schedule is developed to identify the audits to be performed and their frequency.*
A dominant factor in audit schedule development is performance in the subject area.
Audit schedules are revised so that weak or declining areas receive increased audit coverage and strong areas receive less consistent with the audit schedule frequency requirements of the Code of Federal Regulations and the UFSAR.
Audits of the selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in a manner to assure that at least biennial (2 years) audits of safety related activities are performed.
A list of operational phase activities subject to the audit program is provided in the Technical Specifications and in Table 17.2-1.