ML19331B918

Forwards Response to NRC Request,Made During 800801 Meeting, Re Independent Safety Engineering Group

ML19331B918
Person / Time
Site:	Farley
Issue date:	08/08/1980
From:	Clayton F ALABAMA POWER CO.
To:	Schwencer A Office of Nuclear Reactor Regulation
References
NUDOCS 8008130529
Download: ML19331B918 (10)

Text

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s Alabama Power Company 600 North 18th Street Post Office Box 2641 E'0"n'"n'."2$$U.I'xil

THIS DOCUMENT CONTAINS POOR QUAllTY PAGES k

F. L CLAYTON, JR.

senior Vice President Alabama Power the Southerrt electrC System August 8, 1980 Docket fio. 50-364 Director of fluclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D. C.

20555 Attention: Mr. A. Schwencer Gentlemen:

Flip-2 Indeoendent Safety Engineering Group The NRC staff in the August 1,1980, meeting concerning the above referenced subject requested that Alabama Power Company address several questions. Alabama Power Company hereby submits the enclosed response concerning the independent safety engineering group.

If you have any questions, please advise.

Yours ver[truly, 1

'f-g/

v w F. L. Clayton, Jr.

RLG:de Enclosure I

cc: Mr, R. A. Thomas l

Mr. G. F. Trowbridge Mr. L. L. Kintner Mr. W. H. Bradford 30s

//

800813e 529 A

i I.B.1.2 INDEPENDENT $1FETY' ENGINEERING Position Establish an independent, dedicated, safety engineering group onsite that reports at high, engineering, management level offsite.

Sasoonse Based on discussions held on August 1, 1980, with NRC ;ersonnel including Mr. L. P. Cr::ker, Alabama Power Company has revised t. e concept of the Safety Audit and Engineering Review Group which was presented to the NRC Staff in our presentation of June 24,1980. Activities that the group will be involved in are specified in Attachment 1.

The major change in the responsibilities of this group is an increased empahsis on the review and assessment of items which affect plant safety. Alabama Power Company is in the process of adding additional manpower in order that this group be able to properly fulfill all assigned duties.

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PAGE 1 TABLE 1 - APC0'S SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE Systen Performance &

Plant Operations Review Operation Evaluation Safety Audit & Engineering REVIEW Planning Group (SPPG)

Consmittee (PORC)

Teams (OET)

. Review Group (SAERG)

REQUIREMENT (Reporting thru (Review Group Independent (Reporting Directly to the (Reporting Offsite to the Organtiational Structural of Operations Reporting to Vice President. Nuclear Manager-Safety Audit,1 Parallel to Operations.

the Plant Manager)

Generation)

Engineering Review) to the Plant Manager)

1. Review procedures and changes ts Reviews operation, main-Reviews administrative Reviews procedures

1. Reviews administrative procedures important to the safe tenance, survelliance procedures and changes to affecting areas under procedures and changes operation of the FNP test, and Emergency other procedures which evaluation for overall thereto and changes to Procedures for technical may involve an unreviewed plant safety, other procedures which accuracy and clarity and safety question (USQ) for may involve an USQ for as a part of operational advisability of the pro-advisability of the pro-assessment.

cedures or their changes cedures and their changes and to verify no USQ is and to verify no USQ is involved.

involved.

2. Verifies that adequate evaluation of technical l

accuracy and clarity of all procedures is per-formed.

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2. Review proposed tests and experiments Reviews all proposed -

Reviews proposed tests

1. Reviews proposed tests and tests and experiments and experiments which may experiments which may in-(except those related to involve an USQ to verify vgive an USQ to verify no corephysics)for no USQ actually exists.

.USQ actually exists.

technical advisability.

2. Verifles proper developmert l

NOTE: Technical Group and review process.

{f6 dependent of Opera-s tions) reviews core physics tests and experiments.

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f PAGE 2 TABLE 1 - APCO'S SYSTEM 0F INDEPENDENT R'. VIEWS REVIEW ORGANIZATIONS 1 REVIEW PURPOSE System Performance &

Plant Operatiaa< Review Operation Evaluation Safety Audit & Engineering REYlEW planning Group (SPPG)

Connittee (PORC)

Teams (CET)

Review Group (SAERG)

REQUIREMENT (Reporting thru (Review Group Ir. dependent (Reporting Directly to the (Reporting Offsita to the Crganizational Structural of Operations Reporting to Vice Proldent-Nuclear Manager-Safety Audit &

Parallel to Operations thePlantManager)

Generation)

EngineeringReview) to the Plant Manager)

3. Riview changes and modifications to Reviews all changes and Reviews changes and

1. Reviews changes and modi-Unit systems and equipment modifications to systems modifications which may fications which may armi equipment for involve an USQ to verify involve an USQ to verify ttchnical advisability, no USQ actually exists.

no USQ actually exists.

2. Verifies proper develop-ment and review process.

4. Rrview Safety Evaluations for changes Reviews safety evaluations

1. Reviews safety evaluations to procedures, equipment or systems, for changes to procedures, for changes to procedures, or tests and experiments to verify equipment, or systems, or equipment.' or systeas. or that actions do not constitute tests and experiments to tests and experiments to unreviewed safety. issues verify that USQ are not verify that USQ are not involved.

involved.

2. Verifles proper develop-ment and review process.

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5. Review changes, tests, or experiments Reviews changes, tests.

Reviews changes. tests, or

1. Reviews changes tests. or which involve unreviewed safety issues or experiments which may experiments which involve experiments which involve involve USQ for technical USQ for disposition.

USQ' for disposition.

advisability.

2. Verifles proper review process.

0 PAGE 3 TABLE 1 - APCO*S SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE Syster. Perfonnance &

Plant Operations Review Operation Evaluation Safety Audit & Engineering REVIEW Planning Group (SPPG)

Committee (PCRC)

Teams (OET)

Review Group (SAERG)

REQUIREMENT (Reporting thru (Review Group Independent (Reporting Directly to the (Reporting Offaite to the Organizational Structural of Operations Reporting to Vice President-Nuclear Manager-Safety Audit &

Parallel to Operations thePlantManager)

Generation)

Engineering Review) to the Plant Manager)

6. Review changes to technical Reviews changes to

1. Reviews changes to specifications technical specifications trchnical specifications for advisability.

for advisability.

2. Verifles proper review process.

7. Review violations of technical spect-Reviews violattens of

1. Reviews violations of fications, including reports and technical specifications, technical specifications.

recomendations to avoid recurrence including reports and including reports and recomendations for recommendations for adequacy of the reports adequacy of the reports and related reported and related reported actions.

actions.

2. Verifles proper review process.

8. Review reports of violations of codes.

Reviews reports of vio-

1. Reviews reports of vio-regulations, orders, technical lations cf codes, regu-lations cf code, regu-specifications license requirements, lations, orders, technical lations, orders, tech-and of internal procedures or specifications license nical specifications.

Instructions requirements, and of Itcense requirements, internal procedures or and of internal pro-instructions foe adequacy of the reports cedures or instructions for adequacy of the and related reported reported actions, actions.

2. Verifles proper review process.

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i PAGE 4 TABLE 1 - APC0's SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE System Performance &

Plant Operations Review Operation Evaluation-Safety Audit & Engineering-REVIEW Planning Group ($ PPG)

Committee (PORC)

Teams (OET)

Review Group (SAERG)

(Reporting Directly to the (Reporting Offsite to the REQUIRLMENT (Reporting thru o(ReviewGroupIndependent Organizational Structural f Operations Reporting to Vice President-Nuclear Manager-Safety Audit &

Parallel to Operations the Plant Manager)

Generation)

Engineering Review) to the Plant Manager)

9. Review reports of events requiring Reviews reports of events '

1. Reviews reports of events 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting to the NRC requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> repsrt-requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> re-ing to the NRC for porting to the NRC for adequacy of rep rt ara adequacy of report and repo.'ted action.

res,orted action.

2. Verifles proper review I

process.

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10. RIview unit operations Pmvides assessment of Reviews system operations Performs overall assess-

1. As part of DET performs plant operations and to detect potential ment of plant operations overall assessment of operation of plants of safety hazards, from nuclear safety plant operations from similar design regarding perspective.

nuclear safety per-L their confomance to spective.

requirements related to

2. Verifles proper review safety and provide dis-of unit operations by j

slaihatton of assessment tye SPPG.

results to appropriate plant staff personnel.

3. Reviews system operations i

to detect potential sarety nazards.

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TABLE 1 - APCO'S SYSTEM OF INDEPENDENT REVIEWS

,PAGE 5 REVIEW ORGANIZATIONS & REVIEW PURPOSE System Performance &

Plant Operations Review Operation Evaluation Safety Audit & Engineering REVIEW Planning Group (SPPG)

Committee (PORC)

Teams (CET)

Review Grouo (SAERG)

REQulREMENT (Reporting thru o(Rev!cw Group Independent (Reporting Directly to the (Reporting Offsite to the f Operations Reporting to Vice President-Nuclear Manager-Safety Addit &

Organizational Structural Parallel to Operations thePlantManager)

Generation)

Engineering Review) to the Plant Manager)

11. Review reports of significant Part of plant operation Reviews reports of Part of overall assessment 1. Reviews reports of sig-operating abnomalities, ce deviations assessment described significant operating of plant operations nificant operating ab-from nomal or expected perfonnance in 10 above.

abnormalities, or described in 10 above.

normalities ne deviations e

cf plant equipment deviations from nomal or from normal or xpected expected performance of perfomance of pid plant equipment to verify equipment to verify adequacy of reports and adequacy of reports and related reported action.

related reported action.

2. As part of OET overall assessment of plant operations described in 10 above.

3. Verifies proper review of unit operations by the SFPG.

12. Review unanticipated deficiencies in Part of plant operation Reviews unanticipated Part of overall assessment 1. Reviews unanticipated de-some aspect of design or operation assessment described in deficiencies in some of plant operations ficiencies in some aspect 10 $bove.

aspect of design or described in 10 abo <e.

of cesign or operation to operation to recomend verify proper problem problem resolution.

resolution.

2. Part of OET overall assess.

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ment of plant operations described in 10 above.

3. Verifies proper review by EPPG.

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PAGE I TABLE 1 - APC0'S SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE System Performance &.

Plant Operations Review Operation Evaluation Safety Audit & Engineering REVIEW Planning Group (SPPG)

Consmittee (PORC)

Teams (CET)

Review Group (SAERG)

REQUIREMENT (Reporting thru (Review Group Independent (Reporting 'Directly to the (Reporting Offsite to the Organizational Structural of Operations Reporting to Vice President-Nuclear Manager-Safety Afdit &

Parallel to Uperations the Plant Manager)

Generation)

Engineering Review) to the Plant Manager)

13. Review Security Plan and implementing Reviews Security Plan and

1. Reviews Security Plan and procedures and recomunend changes changes thereto for changes thereto for advisa-advisability.

bility.

2. Verifles proper imple-mentation of Security Plan and implementing procedures, i

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14. Review Emergency Plan and implementireg Review Emergency Plan and

1. Reviews Emergency Plan and procedures and recomunend changes changes thereto for changes thereto for advisab111ty.

advisability.

2. Verifles proper imple-mentation of' Emergency s

Plan and implementing 4

procedures, i

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15. Review reports and meeting minutes of Perfo wd by offsite Nuclear Operations the PORC and provide oversight Review Board (NORB).

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PAGE 7 TABLE 1 - APCD'S SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE Srsten Performance &

Plant Operations Review Operation Evaluation Safety Audit & Engineering REVIEW PlanningGroup(SPPG)'

Committee (PORC)

Teams (OET)

Review Group (SAERG)

REQUIREMENT (Reporting thru (Review Group Independent (Reportina Directly to the (Reporting Offsite to the Organizational Structural of Operations Reporting to Vice President-Nuclear Manager-Safety AL' lit &

Parallel to Operations-thePlantManager)

Generaticr.)

Engineering Review) to the Plant Manager)

16. Assure corrective action and Verifies implementation.

recanmendations are implemented

17. Other reviews as requested by the Performs other reviews Performs other reviews Performs other reviews and Nuclear Operations Review Board as requested by the as requested by the Vice verifications as requested (NORB)

NORB.

President-Nuclear by the Vice President -

Generation.

Nuclear Generation.

Part of overall

1. Part of the OET overall

18. Assess Plant Staff Performance assessment of plant assessment of plant operations and plant ogerations and plant staff functions, staff functions.

2. Conducts total and j

cooprehensive audits to i

Quality Assurance requirements.

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1 PAGE 8 TABLE 1 - APCO'S SYSTEM OF INDEPENDENT REVIEWS REVIEW ORGANIZATIONS & REVIEW PURPOSE System Perfonnance &

Plant Operations Review Operation Evaluation Safety Audit & Engineering PEVIEW Planning Group (SPPG)

Committee (PORC)

Teams (OET)

Review Group (SAERG) to the REQUIREMENT (Reporting thru

. (Review Group Independent (Reporting Directly to the (Reporting Offsite,it &

Organizational Structural of Operations Reporting to Vice Pr sident-Nuclear Manager-Safety Aud Parallel to Operations the Plant Manager)

Generation)

EngineeringReview) to the Plant Manager)

19. Evaluate effectiveness of QA Manac>r. Safety Audit and Engineerint Evaluation evaluates the effe ctiveness of the QA program by periodic audits by his program offsite staff, Joint Utility Manageient Audits, and an annual formal : unnary of the QA program per formance.

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20. Evaluate operating experience of Part of plant operations Veriffes proper evaluation the unit and units of similar assessment described in by SPPG.

design 10 above.

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