ML18106A778
| ML18106A778 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 07/23/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18106A777 | List: |
| References | |
| TAC-MA0883, TAC-MA0884, TAC-MA0885, TAC-MA883, TAC-MA884, TAC-MA885, NUDOCS 9807280278 | |
| Download: ML18106A778 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION QUALITY ASSURANCE PROGRAM DESCRIPTION CHANGE PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK AND SALEM GENERATING STATIONS DOCKET NOS. 50-354. 50-272. and 50-311 TAC NOS. MA0883. MA0884. AND MA0885 By letters dated February 13, 1998, and June 18, 1998, Public Service Electric and Gas Company (PSE&G) submitted proposed changes in accordance with 10 CFR 50.54(a)(3) to the Hope Creek and Salem Generating Stations Quality Assurance (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 letter dated February 13, 1998, as supplemented by the information in Attachment 1 to PSE&G's letter dated June 18, 1998. PSE&G has proposed changes that would address the use of qualified specialists for reviewing certain special process procedures and for having certain procurement assessment functions be performed by the procurement organization. The following sections provide the staffs evaluation of these proposed changes.
- 1.
Use of Qualified Specialists PSE&G proposed to transfer 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. Further, PSE&G has defined a qualified specialist as a person who has certified proficiency in the area of review (e.g., personnel reviewing NDE procedures are required to have Level Ill certification in the subject NOE area, and personnel reviewing other procedures or reports are required to be qualified in accordance with PSE&G's Engineering Support Personnel Program).
Applicable Regulatory Requirements Criterion IX, "Control of Special Processes," of Appendix B to 10 CFR Part 50 (Appendix B) requires, in part, that measures shall be established to ensure that special processes are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specification criteria, and other special requirements.
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Enclosure
.:. 2-NRC Evaluation The controls proposed by the licensee meet applicable Appendix B requirements and ensure that qualified personnel review procedures controlling special processes. Further, the control of special processes is subject to review and audit by the Quality Assessment Group. The staff considers that the proposed change to permit quality specialists to review special process procedures to be acceptable.
- 2.
Relocation of Procurement Assessment Functions 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 the PA Group would no longer report to the QA organization, but would report to the NP&MM Manager. PSE&G further proposed that the PA Group Manager have direct access to the Manager, Quality Assessment and report to the Manager, Quality Assessment if a conflict concerning the implementation of the QA Program exists within the NP&MM Department. The QA Program change has also added a description of the duties and responsibilities of the PA Manager to the QA Program.
Additionally, the proposed change assigns the responsibility for monitoring the ability of the PA group to continuously function with sufficient independence to the Manager, Quality Assessment. The Manager, Quality Assessment accomplishes this monitoring by performing audits and assessments, conducting interviews, performing surveys, and by
. directly observing procurement and procurement assessment activities.
Further, the PA activities of the Manager, MP&MM will take precedence over his non-PA activities and in the event of a conflict, the Manager, MP&MM will delegate all authority in the area of PA to the PA Manager.
Applicable Regulatory Reguirement Appendix B establishes quality 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.
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 the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
NRC Evaluation Based on the controls that PSE&G proposed to ensure that the PA Group will function independently and free from cost and schedule pressures, the consolidation of MP&MM Group and the existing MSPS Group meets the applicable requirements of Criterion I of Appendix B. Further, the Appendix B requirement that certain quality assurance functions be performed to ensure that the QA Program is being effectively executed, and the requirement that 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, will be met by the Quality Assessment oversight of the PA Group's activities. Additionally the reporting relationship controls that the licensee has proposed provide assurance that the PA Manager has access to and reports to a management level such that authority and organizational freedom to identify quality problems exists.
CONCLUSION The proposed changes to the QA Program were reviewed in accordance with Section 17.2, "Quality Assurance During the Operational Phase," of NUREG-0800, "Standard Review Plan,"
and were found to continue to meet the applicable regulatory requirements.
Principle contributor:
- L. Campbell Date: July 23, 1998