ML18101B381

Submits Request to Change QA Program for Salem & Hope Creek Stations

ML18101B381
Person / Time
Site:	Salem, Hope Creek
Issue date:	05/22/1996
From:	Jamie Benjamin Public Service Enterprise Group
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML18101B382	List: ML18101B381 ML18101B383
References
LR-N96104, NUDOCS 9605280185
Download: ML18101B381 (9)

Text

. e PS~G Public Ser-Vice Electric and Gas Company P.O. Box 236 Hancocks Bridge, New Jersey 08038-0236 Nuclear Business Unit

• MAY 2 2 1996 LR-N96104

• united States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:

SALEM GENERATING STATION UNITS 1 AND 2 AND HOPE CREEK GENERATING STATION FACILITY OPERATING LICENSES DPR-70, DPR-75 AND NPF-57 DOCKET NOS. 50-272, 50-311 AND 50-354 REQUEST FOR APPROVAL OF CHANGES TO THE QUALITY ASSURANCE PROGRAM In accordance with 10CFR50.54(a) (3), Public Service Electric &

Gas Company (PSE&G) hereby submits for your approval a request to change the Quality Assurance (QA) Program for Salem and Hope Creek Generating Stations, as documented in Section 17.2 of the respective Updated Final Safety Analysis Reports (UFSAR).

This submittal consists of two changes: 1) incorporatibn of th~

Independent Safety Engineering Group (ISEG) functions into the QA Department, and 2) replacement of the Offsite Safety Review (OSR) organization with a standing committee, referred to as the Nuclear Review Board (NRB), to fulfill the offsite independent review requirements. The NRC has previously approved the restructuring of the ISEG functions into the QA Department for PECO Energy's Peach Bottom Nuclear Station and the proposed

.configuration and responsibilities of the_NRB are similar to PECO Energy's Limerick Generating Station NRB, as described in its UFSAR.

By letter dated January 11, 1996 (ref: LR-N95092), PSE&G submitted two license change requests (LCRS 95-13 and 95-06) to relocate the review and audit functions of Section*6.5 of the Salem and Hope Creek Generating Stations Technical Specifications (TS) to the PSE&G QA Program. This submittal covers the QA Program changes necessary to relocate TS Section 6.5.2 requirements. A separate letter will be submitted under 10CFR50.54(a) to cover QA Program changes for relocating TS Sections 6.5.1 and 6.5.3 requirements. Approval of the license change request as an amendment to the Salem and Hope Creek TS is required prior to implementing these changes.

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Documept Control Desk 2 MAY 2 2 1996 LR-N96104 Attachment 1 contains a description of the proposed changes, the reasons for the proposed changes, and bases for concluding that the revised QA Program continues to satisfy the criteria of 10CFR50 Appendix B. The proposed changes also continue to satisfy the criteria of NUREG 0737, Clarification of TMI Action Plan Requirements, with respect to ISEG functions, and ANSI NlB.7-1976 (ANS 3.2), Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, with respect to offsite independent review. Attachments 2 and 3 contain the changes to the Salem and Hope Creek UFSARs, respectively.

The proposed changes have the potential to enhance safety through improved resource allocation. Personnel resources can be better focused on safety significant and/or emergent issues. These changes will also avoid unnecessary duplication of work.

Therefore, PSE&G requests approval of these changes by June 30, 1996.

Should there be any questions regarding this submittal, please do not hesitate to contact us.

Sincerely,

~~ -

~Benjamin~

Director -

Quality Assurance/

Nuclear Safety Review

MAY 2 2 1996 Document Control Desk 3 LR-N96104 C Mr. T*. T. Martin, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. L. 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. Marschall {X24)

USNRC Senior Resident Inspector Mr. R. Summers {X24)

USNRC Senior Resident Inspector Mr. K. Tosch, Manager IV Bureau of Nuclear Engineering 33 Arctic Parkway CN 415 Trenton, NJ 08625 L____

LR-N96104 ATTACHMENT 1 SALEM AND HOPE CREEK GENERATING STATIONS FACILITY OPERATING LICENSES DPR-70, DPR-75 AND NPF-57 DOCKET NOS. 50-272, 50-311, AND 50-354 PROPOSED CHANGES TO THE QUALITY ASSURANCE PROGRAM BACKGROUND The proposed changes relocate specific review and audit functions from Section 6.5.2 of the Salem and Hope Creek Generating Stations Technical Specifications (TS) to the Quality Assurance (QA) Program. In addition to relocating the functions, the organizations responsible for performing the functions change and the scope and frequency of some of the functions are changed.

This submittal consists of two changes: 1) incorporation of the Independent Safety Engineering Group (ISEG) functions into the QA Department, and 2) replacement of the Offsite Safety Review (OSR) organization with a standing committee, referred to as the Nuclear Review Board (NRB), to fulfill the offsite independent review requirements. The NRC has previously approved the restructuring of the ISEG functions into the QA Department for PECO Energy's Peach Bottom Nuclear Station and the proposed configuration and responsibilities of the NRB are similar to PECO Energy's Limerick Generating Station NRB, as described in its Updated Final Safety Analysis Report {UFSAR) .

The proposed changes have the potential to enhance safety through improved resource allocation. Personnel resources can be better focused on safety significant and/or emergent issues. These changes will also avoid unnecessary duplication of work.

By letter dated January 11, 1996 (ref: LR-N95092), PSE&G submitted two license change requests {LCRS 95-13 and 95-06) to relocate the review and audit functions of Section 6.5 of the Salem and Hope Creek Generating Stations TS to the PSE&G QA Program. This submittal covers the QA Program changes necessary to relocate TS Section 6.5.2 requirements. A separate letter will be submitted under 10CFR50.54{a) to cover QA Program changes for relocating TS Sections 6.5.1 and 6.5.3 requirements.

Approval of the license change request as an amendment to the Salem and Hope Creek TS is required prior to implementing these changes.

INDEPENDENT SAFETY ENGINEERING GROUP (ONSITE)

DESCRIPTION OF THE PROPOSED CHANGES The proposed changes would eliminate ISEG as a dedicated organization and reassign the functions performed by the ISEG to the QA Department. The onsite independent review function will

Docum~nt Control Desk 2 Attachment 1 LR-N96104 use personnel who are independent of the line management organization responsible for power production. These individuals will report to the two Managers - Quality Assessment. The Managers - Quality Assessment will use the information obtained from assessment activities as input to advise line management on the overall quality and safety of operations.

REASONS FOR THE PROPOSED CHANGES At PSE&G, the ISEG functions are currently performed by* the Onsite Safety Review Group (SRG). The current Salem and Hope Creek staffing for the ISEG is four dedicated engineers. The proposed change requests that the onsite independent review function be performed by individuals reporting to the two Managers - Quality Assessment, not by dedicated, full-time engineers.

NUREG-0737, Clarification of TM! Action Plan Requirements, specifies the staffing requirements for an ISEG. This requirement for dedicated engineers restricts the capability to use resources to their maximum advantage and does not result in I an increase in the protection afforded to the health and safety of the public. The proposed change would improve resource allocation, allowing PSE&G to focus resources on safety significant and/or emergent issues and avoid unnecessary duplication of effort. It would optimize oversight activities in critical areas.

BASIS FOR THE PROPOSED CHANGES The ISEG and QA Department currently accomplish their onsite independent review functions separately from one another. The proposed change would integrate the two onsite independent review functions into one audit and review fun6tion under the direction of the two Managers - Quality Assessment. This would result in a more effective utilization of resources; The scope of the ISEG review function is not changed in the relocation from the TS to the QA Program and the independence of the review function is retained. The Managers - Quality Assessment report to the Chief Nuclear Officer & President -

Nuclear Business Unit (NBU) through the *Director ~ QA/Nuclear Safety Review (NSR) . The QA Department is independent of plant management.

Document Control Desk 3 Attachment 1 LR-N96104 The qualifications of personnel performing the onsite independent review function will meet the requirements of ANSI/ANS 3.1-1981, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants. Currently, TS Section 6.5.2.2 for Salem and Hope Creek commits PSE&G to Section 4.4 of ANSI/ANS 3.1-1981 for the ISEG function. We are proposing to remove the reference to Section 4.4. This will allow the use of experience to be evaluated in lieu of education requirements, as identified in Section 4.1 of ANSI/ANS 3.1-1981. This constitutes an alternate means of ensuring equivalent qualification. Performance of the onsite independent review function by non-degreed individuals has been approved for PECO Energy's Peach Bottom Atomic Power Station.

The program scope and thoroughness of onsite independent reviews will not be affected. Management oversight of the onsite independent review function will not be diminished. The Managers

- Quality Assessment will also satisfy the minimum professional level experience requirements stipulated in ANSI/ANS 3.1-1981.

The revised QA Program incorporating this change continues to satisfy the criteria of 10CFR50, Appendix B. Transferring the responsibility for the onsite independent review function to the Managers - Quality Assessment will have no adverse impact on this function.

OFFSITE INDEPENDENT REVIEW DESCRIPTION OF THE PROPOSED CHANGES The proposed change would eliminate the OSR organization and reassign these functions to the responsibility of a standing committee, the NRB. The NRB already functions at PSE&G to provide management oversight for Salem and Hope Creek. The role of the NRB will be expanded to include offsite independent review. The NRB is a standing committee composed of PSE&G management personnel and is supplemented by technical consultants from outside of the organization.

REASONS FOR THE PROPOSED CHANGES Currently, the responsibility for performing offsite independent review as required by ANSI N18.7-1976 (ANS 3.2), Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, is held by the Manager - Nuclear Safety

Document Control Desk 4 Attachment 1 LR-N96104 Review (NSR). This responsibility is implemented by the OSR Group which consists of four dedicated engineers for each station, Salem and Hope Creek. In addition, PSE&G has established an NRB to act as a standing committee which performs management oversight functions.

ANSI NlB.7-1976 (ANS 3.2) requires that offsite independent review be performed by either a standing committee (NRB) or an organizational unit (OSR). PSE&G proposes to eliminate the OSR organization by reassigning the responsibilities to the NRB.

Offsite independent review functions currently being performed by OSR will be accomplished by the NRB. The NRB consists of PSE&G management personnel and technical consultants from outside of PSE&G with a wide variety of experience and expertise.

Application of this background will enhance the offsite independent review and oversight of safety significant issues.

The change is consistent with the ANSI requirements, and does not result in a decrease in the protection afforded to the health and safety of the public.

BASIS FOR THE PROPOSED CHANGES The qualifications of the NRB members are such that the effectiveness of the offsite independent review function will not be reduced. The NRB members meet the qualifications of ANS 3.1-1981.

The NRB satisfies the requirements of ANSI NlB.7-1976 (ANS 3.2),

in that the board is composed of no less than five members and no more than a minority of these members are from either the Salem or Hope Creek operating organizations. A quorum shall consist of not less than a majority of the members, of which no more than a minority of those present shall have line responsibility for operating the plant. The Chairperson of the NRB will be appointed by the Chief Nuclear Officer (CNO) & President - NBU.

The PSE&G members shall be selected from PSE&G management personnel. In addition, a minimum of three external consultants shall be members of the NRB. Meetings are scheduled by the NRB Chairperson. A minimum of two meetings a year are conducted.

Minutes of the meetings shall be prepared and distributed to the CNO.

Document Control Desk 5 Attachment 1 LR-N96104 The NRB responsibilities will be expanded to provide oversight into the areas currently being performed by the OSR Group. These areas include: 10CFR50.59 safety evaluations, proposed changes to procedures and/or equipment which involve an unreviewed safety question, proposed changes to the Operating License or Technical Specifications, violations or deviations, reportable events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notice, oversight of selected audits, and any other selected issues involving safe operation or having safety significance.

Transferring the offsite independent review function from the OSR organization to the NRB will reduce the frequency for reports to the CNO. OSR is required by the TS to provide monthly reports.

The NRB will provide meeting minutes. PSE&G proposes to reduce the frequency of reports to the CNO to be consistent with the NRB meeting frequency. ANSI NlB.7-1976 (ANS 3.2) identifies twice a year meetings for operational plants as sufficient to provide offsite independent oversight. The NRB Chairperson will have the authority to assemble the NRB more frequently if it is deemed necessary. The reduction in reporting to the CNO will not result in a decrease in the effectiveness of the offsite independent review function.

The proposed changes reassign the responsibility for offsite independent review from the OSR Group to the NRB. The revised QA Program incorporating these changes continues to satisfy the criteria of 10CFR50, Appendix B. Transferring the offsite independent review function from the OSR Group to the NRB will have no significant adverse impact on safety, and is within the guidelines provided by ANSI NlB.7-1976 (ANS 3.2).

CONCLUSION In conclusion, PSE&G has determined that, while these changes have been evaluated as a reduction in commitment, the resultant revised QA Program continues to satisfy the criteria of 10CFR50, Appendix B. The proposed changes have the potential to enhance safety through improved resource allocation. Personnel resources can be better focused on safety significant and/or emergent issues. These changes will also avoid unnecessary duplication of work. Therefore, PSE&G requests the NRC's prompt attention to approve these changes.

LR-N96.104 ATTACHMENT 2 SALEM UFSAR CHANGES