ML19355A067
| ML19355A067 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/22/1994 |
| From: | Latta R Office of Nuclear Reactor Regulation |
| To: | Zech G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9403310279 | |
| Download: ML19355A067 (4) | |
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. NUCLEAR REGULATORY COMMISSION
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March 22, 1994 5
MEMORANDUM FOR:
Gary G. Zech, Chief E
Performance'and Quality Evaluation Branch Division.of Reactor-Inspection and Licensee Performance, NRR THRU:
Robert A. Gramm, Chief P,
Quality Assurance Section Performance and Quality Evaluation Branch Division of Reactor Inspection n~
and Licensee Performance, NRR L
FROM:
Robert M. Latta Quality Assurance Section Performance and Quality Evaluation Branch Division of Reactor Inspection and' Licensee Performance, NRR
SUBJECT:
INFORMATION GATHERING TRIP TO VIRGINIA POWER CORPORATE-HEADQUARTERS TO SUPPORT NRR GRADED QA METHODOLOGY F
DEVELOPMENT.
This memorandum provides a summary of the key issues discussed during the meeting between members of.the Performance and Quality Evaluation Branch, Office of the Nuclear Regulatory Research, Region l III-~ staff, and representa-tives of the Virginia Power Company in their corporate headquarters in Insbrook, Virginia, on March 8, 1994.
The purpose of this meeting was to discuss both current quality: assurance (QA) program implementation processes and the' development of a; graded QA methodology.
The meeting, which was also attended by ~representati.ves of the Nuclear Utilities and Resources-Council.(NUMARC), focused on the. examination of current QA practices as they relate' to the proposed proportionate
. application of quality verification criteria commensurate with the relative safety significance and risk ranking.of systems, structures, and~ components:
(SSCs). The meeting resulted'in the effective translation of information~and' a follow-up information gathering trip is planned for March 18, 1994,3 at the-F North Anna site.
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A listing of the attendees is'provided in Enclosure -1 and.a description of the meeting agenda is~ included as Enclosure 2.
Specific topics which were discussed-during the meeting are provided'in.the following summary:-
l 1.
Concepts regarding the application of.a: graded QA methodology related
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to low risk safety-related SSCs and existing practices involving non -
safety-related_ SSCs were discussed. Within this area, it was' indicated
- that Virginia Power is-currently implementing many of the' elements associated with c graded QA approach.
Specifically, QA ' performs la -
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spectrum of verification activities ranging from informal surveillances and monitoring of in-process work activities, assessments, and-formal audits. Additional quality augmentation is afforded by voluntary procedural hold-points for non-safety-related wor.k efforts.. Relative to work controls, the utility stated that the.same procedures are used whether the activity is' safety-related or non-safety-related.
It was also stated that QA utilizes the safety significance of work activities to prioritize their verification efforts. The QA organization also evaluates. the critical attributes of proposed activities when they e
formulate their verification methodologies. Additionally, the Corporate Manager of QA discussed some burdens present in the ANSI standards relating to audits and the fact that the regulations require annual security, fire protection, and emergency preparedness audits that consume sevrral man-years (annually) with a marginal safety benefit.
Within this area, it was stated that-Virginia Power has a proposed rule-making to amend those regulations.
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2.
Virginia Power has used an expert panel to implement the 93-01 maintenance rule methodology to identify high-risk SSCs. This process resulted in the identification of 14 systems which were characterized as risk significant. The reactor protection system (RPS) and contain-
' ment structure were evaluated deterministically-since they were not L
treated by the PRA. The utility has developed an extensive on-line capability to retrieve information on equipment-availability / reliability-for performance monitoring. The expert panel was comprised-of 8 senior
. personnel, including several SR0s, who evaluated the SSCs.
Relative to the procedural guidance utilized for the panel conduct, utility representatives indicated that guidance is currently being prepared in-the form of a draft administrative procedure.
Based on the insights gained within this area, it was noted that Virginia Power had a well developed approach toward the implementation of the maintenance rule.
3.
As indicated by Virginia Power, the current practices for the control of design requirements are reflected in a detailed Q-list that designates safety-related components, associated requirements such as EQ/RG 1.97, critical safety functions, and sub-component bill of materials 'informa-tion. Their procurement program is structured to support safety func-tion and is not directed solely at safety classification. Additionally, a screening process is-conducted on plant modifications to determine whether a 50.59 evaluation is required.
Currently, the equipment database for Virginia Power's four units includes 256,303 items, of which 88,200 are designated as safety-related and 34,656 are non-safety-related with special regulatory significance (NSQ) (such as ATWS), and the remainder are non-safety-re hted (NSR).
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' During the final portion.of the meeting, Virginia' Power indicated :an' interest in using the: graded QA approach;in the ar %s ofzrecords' retention,;QA'. audits, procurement, and?on-site /off-Yite' reviews of 50.59s.. :They have' also submitted a proposed rulemakinglon' annual audit requirements fer EP/FP' and; physical protection / security v Significantly,l Virginia Power does not-.envisioncthe need for.either' technical-Specifi-p; cation or QA plan changes to embark on'a pilot : effort ~ for graded.QA' t ; As..
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stated by Virginia Power, sufficient flexibility exists.in their currenti W
1 commitments.to implement the approach. With respect to commitments:
tracking, North-Anna presently has' approximately 250 open' items comprised of both regulatory issues and internal-items which would '
require review for impact on the graded approach; ' Potentia 11 savings? for?
6 th:e utility!are envisioned in the procurement and warehousing areas-under a graded QA approach.
- In summary, it is apparent that Virginia Power has realized significanti progress toward the implementation of the Maintenance' Rule and that they have r
put a great deal of-thought into how to effectively implement their QA program in.a graded / performance based fashion. Their presentation was:very informative and~the staff were technically competent,
, _,y Original signed by:. Robert M. Latta s
Robert M. Latta Quality Assurance Section Performance and Quality, Evaluation Branch Division of Reactor -Inspectioni
<r and Licensee' Performance, NRR' a
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Enclosures:
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.USNRC-iMEETING ATTENDANCE LIST m
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- ORGANIZATION'-
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E. J. Wheeler Virgi$iaPower
~E. S. Grechech-Virginia Power W. W.-Wigley
. Virginia Power
. M. L. Bowling-Virginia Power L. N. Hartz Virginia Power b.-
Harry L.~ Miller Virginia 1 Power.
' Kerry L. Basehore Virginia Power L K. "D. Tul'ey Virginia Power-e Bob.Gwaltney Virginia Power.--
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Bob Myers
. Virginia ~Powet P. T. Knutsen Virginia Power.
'W. B. Rodill Virginia ~ Power-J
.Brice Shriver ~
Virginia Power:
b J..D. Hegner
. Virginia Power ~
Ji.y H.'.Leberstien Virginia Power E
'NUMARC--
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- Tony Pietrangelo
- A. P. Heymer.
NUMARC NRC/DRS/ RII-
- . Frank -Jape.
I NRC/DRIL/RPEB
.R. M.iLatta, L
Gary G. Zech
- NRC/DRIL/ RPEB4 yb NRC/DRIL/.RPEBf f
' Bob Gramm
- G.? C. Millman NRC/RES/DE-i k
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PROPOSED INFORMATION GATHERING PLAN N
(Virginia Power)
(1)
Examine current procedure (s) and practices for controlling safety related SSC's (0-list) and the implementation of Appendix 'B' requirements.
(2)
Determine how design requirements are translated to purchase specifications to evaluate where graded QA methodologies could be utilized.
(3)
Examine current Technical Specification requirements to evaluate extent of changes which would be required to accommodate the graded QA approach.
(4)
Examine current licensee practices with respect to scheduling inspections, surveillances, monitoring, and audits with emphasis towards safety significant work activities.
(5)
Examine licensee's current QA program controls and evaluate extent of authorized changes which would be required.under 10 CFR 50.54(a) (i.e., reduction in existing commitments) to accommodate the graded QA approach.
(6)
Evaluate existing / proposed processes (i.e., PRA, IPEs) which establish risk ranking of SSC's. (if available.)
(7)
Review existing company quality practices applied to non-safety related SSCs. Evaluate appropriateness of approach for' low risk safety related SSCs.
.(8)
Review recent modificat ons and evaluate the impact of i
proposed graded OA methodology.
(9)
Review licensee's approach for implementing the maintenance rule ~ including provisions for an expert panel. (if available.)
(10) Evaluate previous company programs associated with the implementation of a graded QA approach (i.e. safety-related, important to safety and non-nuclear safety categorization programs) w