ML18107A179
| ML18107A179 | |
| Person / Time | |
|---|---|
| Site: | Salem, Hope Creek  |
| Issue date: | 04/15/1999 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML18107A177 | List: |
| References | |
| NUDOCS 9904200159 | |
| Download: ML18107A179 (5) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555--0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION CHANGES TO THE QUALITY ASSURANCE PROGRAM PUBLIC SERVICE ELECTRIC AND GAS COMPANY HOPE CREEK GENERATING STATION AND
- SALEM NUCLEAR GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-354, 50-272, AND 50-311
1.0 INTRODUCTION
By letters dated October 19, 1998, and February 10, 1999, Public Service Electric and Gas Company (PSE&G) requested approval of proposed changes to the Quality Assurance (QA)
Program for the Hope Creek and Salem Generating Stations, as described in Section 17.2 of the respective Updated Final Safety Analysis Reports (UFSARs), in accordance with 10CFR50.54(a)(3). The scope of the Quality Assurance, Vendor Inspection, Maintenance and Allegations Branch's (IQMB's) review of these QA Program changes was limited to those changes identified as reductions in commitments in PSE&G's letter dated October 19, 1998, as supplemented by the information in PSE&G's letter dated February 10, 1999. PSE&G has proposed changes that would: a) revise the responsibilities for corrective actions; b) permit QA Department assessments, reviews, and inspections to be performed on a selected basis; and c) modify the provisions for processing significant conditions adverse to quality.
2.0 EVALUATION The following sections provide the staff's evaluation of these proposed changes. Note, the strike out text identifies existing text that PSE&G proposed to delete and the bold text identifies text that PSE&G proposed to add. All references to UFSAR sections are applicable to the respective sections in both the Hope Creek and Salem UFSARs.
2.1 Proposed Changes to Revise Responsibilities for Corrective Action PSE&G proposed the following changes to UFSAR Section 17.2.1.1.1, "Quality Assurance:"
Responsibilities of the Manager - Corrective Action, Emergency Preparedness, and Instructional Technology (Manager - CA, EP & IT) include the following:
9904200159 990415 PDR ADOCK 05000272 P
PDR I
Enclosure I
- 1.
Administration of the Corrective Action Program.
- 2.
Manageffient direction and control of all collection and Overall management of the trending of Corrective Action reports related to human, organizational, and programmatic performance.
- 3.
Perforffiing statistical analysis Providing trend data reports ffif to management.
2.1.1 Applicable Regulatory Requirements Criterion II, "Quality Assurance Program," of Appendix B to 1 O CFR Part 50 requires, in part, that the status and adequacy of the quality assurance program shall be regularly reviewed and that the management of organizations participating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are executing.
2.1.2 NRG Evaluation In addition to the proposed changes to the responsibilities of the Manager-CA, EP & IT,
. PSE&G proposed to revise UFSAR Section 17.2.16, "Corrective Action," to state that Engineering and Maintenance are responsible for equipment failure trending and that department managers are responsible for identifying trends within their respective organizations. Further, PSE&G proposed to revise Section 17.2.16 to repeat the responsibility of the Corrective Action Group, and to further describe the trending of corrective action requests. The proposed changes meet applicable Appendix B requirements and with the proposed changes to responsibilities of the Manager - CA, EP & *1T, and Section 17.2.16, the individuals responsible for corrective action trending are fully described. The staff considers the proposed changes to the responsibilities for the Manager - CA, EP & IT, to be acceptable.
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2.2 Proposed Changes to Permit Assessments, Reviews, and Inspections to be Perfqrmed on a Selected Basis PSE&G proposed the following changes for the responsibilities of the Manager - Quality Assessment, in UFSAR Section 17.2.1.1.1, "Quality Assurance:"
+413. Perforffi Code related inspections, tests perforffiance, and revievv of Conduct performanced based inspections of selected Code related activities, observe and perform selected testing, and review selected weld procedures for inclusion of QA requirements.
t514. Perform design change package pre-implementation review and closure review for compliance with Inspection Hold Points (IHPs) requirements for selected design change packages by periodic assessment and inspection.
Also, PSE&G proposes the following changes to UFSAR Section 17.2.6, "Document Control:"
QA involvement in work activity includes review of selected work procedures prior to approval to assess the fef designation of independent inspection hold points (see 17.2.10), observation of selected work activities, and review of selected completed safety-related Work Orders on a samplin§ basis, and during periodic QA surveillance aftt:f assessments and inspections.
Additionally, PSE&G proposed changes to the nonconformance control program as discussed in UFSAR Section 17.2.15, "Nonconforming Materials, Parts, or Components," which would permit QA to verify the satisfactory resolution of nonconformances on a selected basis through its normal maintenance program assessment and inspection activities.
Further, in UFSAR Section 17.2.5, "Instructions, Procedures, and Drawings," PSE&G proposed a change that would permit QA to review selected documents affecting nuclear safety to ensure incorporation of quality requirements through periodic assessment and inspection
- activities conducted by QA personnel.
2.2.1 Applicable Regulatory Requirements Criterion I, "Organization," of Appendix B to 10 CFR Part 50 requires, in part, that the applicant shall be responsible for the execution of the quality assurance program and that 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 the safety-related.functions have been correctly performed.
2.2.2 NRC Evaluation In addition to the specific proposed changes described above, the PSE&G submittal proposes other changes to the QA Program that would permit the QA Department to perform certain activities on a selected basis. In its February 10, 1999, letter, PSE&G identified the following criteria to be used for the assessment selection process:
PSE&G plans to select areas for assessment, activities for inspection, and documents for review using a performance based methodology. This methodology will consider the following factors:
Risk significance (high risk significance equipment, Maintenance Rule risk significant systems, etc.)
Past performance (including results of program, equipment, and human performance trends)
Complexity of tasks Frequency of evolution Interfaces (between *groups, departments, contractors, etc.)
The staff considers the proposed changes and the identified selection methodology for the QA Department to be acceptable.
2.3 Proposed Changes to the Significant Condition Adverse to Quality (SCAQ) Process PSE&G proposed the following changes to UFSAR Section 17.2.16, "Corrective Action:"
Responses to SCAQ corrective action requests documents are required to include based on the four elements of corrective action, *v-o'hich are:
1.
Identification of the cause of the deficiency
- 2.
Action taken to correct deficiency and results achieved to date
- 3.
Action taken or to be taken to prevent recurrence
- 4.
Date when full compliance was or will be achieved
- 4.
Responsibilities and due dates for corrective actions Responses to CAQ corrective action documents are required to include:
- 1.
Identification of deficiency
- 2.
Action taken to correct deficiency Line management is responsible for dispositioning action* requests within their areas of responsibility.
For significant conditions adverse to quality, such as LERs and NRC/INPO/CMAP findings, plant management is responsible for ensuring timely response.* t The QA Corrective Action Group Department is involved in the review of selected SCAQs ffi such conditions and provides oversight to assure timely. follow-up and close out through assessment and inspection activities.
Items 3 and 4 are optional for conditions adveffle to quality.
2.3.1 Applicable Regulatory Requirements Criterion XVI, "Corrective Action," of Appendix B to 1 O CFR Part 50, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. The identification of the significant condition adverse to quality, the cause of the condition, and corrective action taken shall be documented and reported to appropriate levels of management.
2.3.2 NRC Evaluation The proposed changes meet applicable Appendix B requirements. Further, based on the discussion provided in its February 1 O, 1999, letter and in proposed UFSAR Section 17.2.16, the licensee's QA Department will continue to assess the effectiveness of the corrective action process. The staff considers the proposed changes acceptable.
3.0 CONCLUSION
The proposed changes to the QA Program for the Hope Creek and Salem Generating Stations, as discussed in this safety evaluation, were reviewed in accordance with 10 CFR 50.54(a) and meet the acceptance criteria contained in NUREG-0800, "Standard Review Plan, Section 17.2, "Quality Assurance During the Operations Phase." The proposed changes are acceptable in that the QA Program continues to meet the requirements of Appendix B to 10 CFR Part 50.
Principle Contributor: L. Campbell Date: April 15, 1999