ML18106A447
| ML18106A447 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/08/1998 |
| From: | Richard Ennis NRC (Affiliation Not Assigned) |
| To: | Keiser H Public Service Enterprise Group |
| References | |
| TAC-MA0883, TAC-MA0884, TAC-MA0885, TAC-MA883, TAC-MA884, TAC-MA885, NUDOCS 9804140417 | |
| Download: ML18106A447 (6) | |
Text
Mr. Harold W. Keise.
. Executive Vice Presi _
Nuclear Business Unit Public Service Electric & Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038 April 8,.8
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING CHANGES TO THE QUALITY ASSURANCE PROGRAM, HOPE CREEK GENERA TING STATION AND SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 (TAC NOS. MA0883, MA0884, AND MA0885)
Dear Mr. Keiser:
We have received the Public Service Electric and Gas Company's submittal dated February 13, 1998, which proposed changes to the Hope Creek Generating Station Quality Assurance (QA)
Program and the Salem Nuclear Generating Station, Units 1 and 2, QA Program contained in Chapter 17 ;2 of the respective Updated Final Safety Analysi.s Reports. The staff is currently reviewing your request for these changes. Enclosed is an RAI, which is required in order for the staff to complete its review of your request. The RAI also provides our preliminary evaluation of certain QA program changes submitted in accordance with 10 CFR 50.54(a)(3) that were identified as reductions in commitments in the j'Description of Proposed Changes" section of
. Attachment 1 to your letter.
Based on our need for the additional information; we have not determined if these changes are acceptable pursuant to 10 CFR 50.54(a)(3)(ii) and you should refrain from implementing them until you have been formally notified otherwise. The staff.requests that the additional information be provided within 60 days of receipt of this letter.
If you have any questions regarding this* matter, please contact -Patrick D. Milano at (301) 415-1457 or me at (301) 415-1420. * * *
- Docket Nos. 50-272, 50-311, and 50-354 Sincerely,
. Ric~~{d B. Ennis, Acting Project Manager Project Directorate 1-2 Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation I i
Enclosure:
Request for Additional Information I
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UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Harold W. Keiser Executive Vice President -
Nuclear Business Unit Public Service Electric & Gas*
Company Post Office Box 236 Hancocks Bridge, NJ 08038 WASHINGTON, D.C. 20555--0001 April 8, 1998
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) REGARDING CHANGES TO THE QUALITY ASSURANCE PROGRAM, HOPE CREEK GENERA TING STATION AND SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 (TAC NOS. MA0883, MA0884, AND MA0885)
Dear Mr. Keiser:
We have received the Public Service Electric and Gas Company's submittal dated February 13, 1998, which proposed changes to the Hope Creek Generating Station Quality Assurance (QA)
Program and the Salem* Nuclear Generating Station, Units 1 and 2, QA Program contained in Chapter 17.2 of the respective Updated Final Safety Analysis Reports. The staff is currently reviewing your request for these changes. Enclosed is an RAI, which is required in order for the staff to complete its review of your request. The RAI also provides our preliminary evaluation of certain QA program changes submitted in accordance with 10 CFR 50.54(a)(3) that were identified as reductions in commitments in the "Description of Proposed Changes" section of to your letter.
Based on our need for the additional information, we have not determined if these changes are acceptable pursuant to 10 CFR 50.54(a)(3)(ii) and you should refrain from implementing them until you have been formally notified otherwise. The staff requests that the additional information be provided within 60 days of receipt of this letter.
If you have any questions regarding this matter, please contact Patrick D. Milano at (301) 415-1457 or me at (301)415-1420.
Docket Nos. 50-272, 50-311, and 50-354 Sincerely,
-fJ5~
Richard B. Ennis, Acting Project Manager Project Directorate 1-2
- Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/encl: See next page
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- Mr. Harold W. Keiser Public Service Electric & Gas Company cc:
Jeffrie J. Keenan, Esquire Nuclear Business Unit - N21 P.O. Box236 Hancocks Bridge, NJ 08038 General Manager - Salem Operations Salem Nuclear Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038
- * - * * * *Mr. l*ouis*-storz* -** -* - *--*** * -* -- --- * -*- * ** * - * * *- * ** * -
Sr. Vice President - Nuclear Operations Nuclear Department P.O. Box 236 Hancocks Bridge, NJ 08038 Senior Resident Inspector Salem Nuclear Generating Station U.S. Nuclear Regulatory Commission Drawer 0509 Hancocks Bridge, NJ 08038 Dr. Jill Lipoti, Asst. Director Radiation Protection Programs NJ Department of Environmental Protection and Energy CN415 Trenton, NJ 08625-0415 Maryland Office of People's Counsel 6 St. Paul Street, 21st Floor Suite 2102 Baltimore, MD 21202 Ms. R. A. Kankus Joint Owner Affairs PECO Energy Company 965 Chesterbrook Blvd., 63C-5 Wayne, PA 19087 Mr. Elbert Simpson Senior Vice President-Nuclear Engineering Nuclear Department P.O. Box236 Hancocks Bridge, NJ 08038 Hope Creek Resident Inspector U.S. Nuclear Regulatory Commission Drawer0509 Hancocks Bridge, NJ 08038 Salem Nuclear Generating Station, Units 1 and 2, and Hope Creek Generating Station Richard Hartung Electric Service Evaluation Board of Regulatory Commissioners 2 Gateway Center, Tenth Floor Newark, NJ 07102 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King_l:)f_ ~ru_ssia! ~~ _
1_~~0~.. _. __
Lower Alloways Creek Township c/o Mary 0. Henderson, Clerk Municipal Building, P.O. Box 157 Hancocks Bridge, NJ 08038 Manager-Licensing and Regulation Nuclear Busienss Unit - N21 P.O. Box 236 Hancocks Bridge, NJ 08038 Mr. David Wersan,
Assistant Consumer Advocate Office of Consumer Advocate
. 1425 Strawberry Square Harrisburg, PA 17120 Manager - Joint Generation Atlantic Energy 6801 Black Horse Pike Egg Harbor Twp., NJ 08234-4130 Carl D. Schaefer External Operations - Nuclear Delmarva Power & Light Company P.O. Box 231 Wilmington, DE 19899 Public Service Commission of Maryland Engineering Division Chief Engineer 6 St. Paul Centre Baltimore, MD 21202-6806 General Manager - Hope Creek Operations Hope Creek Generating Station P.O. Box 236 Hancocks Bridge, NJ 08038
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REQUEST FOR ADDITIONAL INFORMATION CHANGES TO THE QUALITY ASSURANCE PROGRAM FOR HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 By letter dated February 13, 1998, the Public Service Electric and Gas Company (PSE&G) submitted proposed changes in accordance with 10 CFR 50.54(a)(3) to the Hope Creek Generating Station (HCGS) Quality Assurance (QA) Program and the Salem Nuclear Generating Station (SNGS), Units 1 and 2, QA Program contained in Chapter 17.2 of the respective Updated Final Safety Analysis Reports (UFSARs). The scope of the Quality Assurance, Vendor Inspection and Maintenance Branch's (HQMB's) review of these QA program changes was limited. to. those changes identified. as reductions in commitments.in the ~Description of Proposed-Changes* section of Attachment 1 to PSE&G's February 13, 1998, letter.
PSE&G proposed to consolidate the existing QA Material and Supplier Plant Support (MSPS)
Group and the Nuclear Procurement & Material Management (NP&MM) Department under a single manager. In this consolidation, the MSPS Group (which currently is part of the QA organization) would be named the Procurement Assessment (PA) Group and would no longer report to the QA organization, but would report to the NP&MM manager. PSE&G further proposes that the PA Group head report to the Manager-Quality Assessment if a conflict with the NP&MM Department occurred regarding the QA program. Additionally, the proposed change would assign the responsibility for monitoring the ability of the PA Group to continuously function with sufficient independence to the Manager, Quality Assessment.
Applicable Regulatorv Requirements:
50.34(b) "Final safety analysis report,* requires that each application for a license to operate a facility shall include a final safety analysis report, and requires that this report include information that describes the facility, presents the design basis and the limits on its operation, and presents a safety analysis of the structures, systems, and components and of the facility as a whole and shall include certain information, analysis, and descriptions among which is the following information concerning facility operation:
"50.34(b)(6)(ii) Managerial and administrative controls to be used to assure safe operation. Appendix 8, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," sets forth the requirements for such controls for nuclear power plants and fuel reprocessing plants. The information on the controls to be used. for a nuclear power plant or fuel reprocessing plant shall include a discussion on how the requirements of Appendix B will be satisfied."
Appendix B to 10 CFR Part 50 (Appendix 8) establishes qualify assurance requirements, for the design, construction, and operation of a nuclear power plant's safety-related systems, structures, and components. Criterion I, "Organization,* of Appendix B requires the establishment and execution of the quality assurance program which includes establishing and delineating in writing the authority and duties of persons and organizations performing activities affecting the safety-related functions of structures, systems, and components. These activities include both the performing functions of obtaining quality and the quality assurance functions. "The quality assurance functions are those of (a) assuring that an appropriate quality assurance program is established and effectively executed and, (b) verifying, such as by checking, auditing, and inspection, that activities affecting safety-related functions have been correctly performed.*
ENCLOSURE
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- Appendix B continues by stating that.the persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. **such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.*
NRC Comments:
Based on the above Appendix B requirements, it appears that the proposed consolidation of NP&MM Group and the existing MSPS Group may not fully comply with the requirements of Criterion I of Appendix 8. These apparent departures from Appendix B are based, in part, on the fact that Criterion I of Appendix B identifies certain quality assurance functions to be performed to ensure that the QA program is being effectively executed and the organization performing such activities is required to have sufficient authority and organizational freedom to identify quality problems and be independent of cost and schedules. To have the quality functions of vendor QA program review and vendor audits (to determine if the vendor is effectively implementing its Appendix B QA program) performed by an organization reporting to NP&MM does not appear to meet the intent of Appendix B. Further, it appears that the intent of Appendix B is to have these quality functions performed by an organization independent of cost and schedules which reports to a management level such.that authority and organizational freedom to identify quality problems clearly exists (i.e., the QA organization).
Additionally, it appears that the audits of fuel suppli.ers and the audits of the contractors installing fuel are quality assurance functions which need to be performed by an organization such as the quality assurance organization. It would be considered appropriate for NP&MM or any other organization having technical knowledge in this area to monitor these activities. However, the QA organization would have the lead responsibility to audit fuel suppliers and fuel installation activities (with audit teams appropriately supplemented with personnel possessing technical expertise in the fuels area) to ensure that the QA programs for these activities were being effectively implemented.
Based on the above discussion, the following are the NRC staffs evaluations and concerns regarding the proposed transfer of certain functions from the QA organization to NP&MM.
- 1. The review of the following activities can be performed by the NP&MM organization provided that the review activities are audited by the QA organization:
- a. Review engineering documents such as equipment specifications for inclusion of QA requirements.
- b. Review and approve specifications for Q-listed materials, equipment, and services.
- c. Review procurement documents for insertion of QA requirements.
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- 2. The responsibilities for the review of vendor QA programs and the auditing of the implementation of vendor QA programs, including the fuel fabricator, appear to be quality assurance functions that should remain within the QA organization.*
- 3. The auditing of fuel installation activities appears to be a quality assurance function that should remain within the QA. organization.*.
- 4. The approval of the QA program and its implementation for the Maplewood testing facility appears to be a quality assurance function that should be performed by the QA organization.*
The following information is required for the staff to complete its evaluation of other requested QA program changes.
The transfer of the responsibility for the review of procedures for special processes from the QA organization and the General Manager to a qualified specialist in the subject discipline or special process appears to be adequate; however, the term "qualified specialists* is not defined~ For example, for a given nondestructive examination {NDE) special process, would the qualified specialist have to be a Level Ill in that NDE discipline? If not, what is the basis for being a qualified specialist? The proposed QA program change appears to provide no guidance for the qualification provisions for this specialist. What are the qualification provisions for this specialists and where is this identified in the QA program?
The staff would like PSE&G to discuss the basis for the deletion of the HCGS requirement to perform site grading modification audits. What was the basis for the original commitment to perform this audit {was it associated with flooding conditions)? Was this a commitment to an NRC inspection or audit finding, or was it part of the licensing basis for HCGS? Is there something unique about the HCGS site when compared to the SNGS site that would require audits of grading activities?
- For the above Items 2,3, and 4, please provide additional information and discussion on how the referenced requirements of Appendix B regarding organizational independence would continue to.be satisfied if these proposed changes are implemented.