ML20035C357
| ML20035C357 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/31/1993 |
| From: | Cross J, Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20035C358 | List: |
| References | |
| NUDOCS 9304070114 | |
| Download: ML20035C357 (9) | |
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(g Portland General Electric Company 1
James E. Cross Vice President and Chief Nuclear Officer I
March 31,1993 Trojan Nuclear Plant -
Docket 50-344.
I,icense NPF-1 i
U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sirs:
Nuclear Ouality Assurance Program. Revision 15 l
In accordance with the requirements of Title 10 to the Code ofFederal Regulations, Part 50.54(a)(3) [10 CFR 50.54(a)(3)] and 10 CFR 50.71(c), one original ofRevision 15 to the Trojan Nuclear Plant Nuclear Quality Assurance Program is enclosed. The Nuclear Quality Assurance Program [ Portland General Electric Company (PGE)-8010] comprises Chapter 17 of the Final Safety Analysis Report (FSAR).
Pursuant to 10 CFR 50.54(a)(3) these changes do not reduce the commitments contained in.
the Nuclear Quality Assurance Program description contained in Revision 14. Revision 15 represents changes made to PGE-8010 since the previous submittal.. Attachment I provides a description of the changes.
Attachment II provides the reasons for the changes, summaries of the bases for concluding that the revised progre.:n continues to satisfy 10 CFR 50, Appendix B and the Quality Assurance Program description commitments previously accepted by the Nuclear Regulatory Commission (NRC), and the bases for concluding that the Quality Assurance Program description commitments previously accepted by the NRC are not reduced.
Revision 15 changes are marked for identification in the Nuclear Quality Assurance Program text by a revision bar.
Sincerely, T. D. Walt hi-i for J. E. Cross 3
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l-9304070114 930331' 121 SW Salmon Street, Portland, OR 97204 DR ADDCK 0500 4-
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- Document Control Desk' y
'_ March 31,' 1993 l
Pace 2 Attachments -
Enclosure c:
Mr. John B.. :artin -
Regional Administrator, Region V U. S. Nuclear Regulatory Commission i
Mr. David Stewart-Smith State ofOregon Department ofEnergy Mr. Kenneth Johnston NRC Resident Inspector Trcjan Nuclear Plant e
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Trojan Nuclear Plant Document Control Desk j
Docket 50-344 March 31,1993 License NPF-1 Attachment I Pace 1 ofi 1
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Trojan Nuclear Quality Assurance Program i
Revision 15 Description of Changes
- 1. (Paragraphs 1.2.2,1.2.2.1,1.2.2.3 and 18.3.1, Figure 1.0-1) The Trojan Nuclear Operations Board now reports to the Vice President and ChiefNuclear Omcer per i
Amendment 187 to the Trojan Facility Operating License.
- 2. (Paragraphs 1.2.2,1.2.2.2.1,1.2.2.2.2.d,1.2.2.2.3.g and 1.2.2.2.4) The Quality Support Section (QSS) has been deleted. Duties of this section have been assumed by other parts of Nuclear Oversight.
- 3. (Paragraphs 1.2.3,1.2.3.1,1.2.3.2 and 1.2.3.2.1, Figure 1.0-1) Erwironmental Services reports to the Vice President, Public AfTairs, instead of the Vice President, Administration.
- 4. (Appendix A) Term " Standard Technical Specifications" changed to " Trojan Technical Specifications"
- 5. (Appendix E) Term " Department" deleted after Nuclear Security.
- 6. (Paragraph 6.2.1) Biennial reviews may be deferred for procedures supporting activities not anticipated to be performed provided the biennial reviews are current or -
completed prior to use of the procedures.
- 7. (Paragraph 8.2.1.2) Term " maintenance request" replaced by " work package" for recording the location of the installation of an item withdrawn from a storeroom.
- 8. (Paragraph 13.2.3) Corrected spelling.
- 9. (Paragraph 15.2.4) The Compliance Department instead of the cognizant supervisor notifies the Company omeer of the need for a 10 CFR 21 report.
- 10. (Glossary) Term " Reportable Occurrence" changed to " Reportable Event to agree with Trojan Technical Specification 1.7.
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p Trojan Nuclear Plant Document Control Desk Docket 50-344.
March 31,1993 License NPF-1 Attachment II Page 1 of 6 Trojan Nuclear Quality Assurance Program Revision 15 Changes item No.1
Title:
Trojan Nuclear Operation Board (TNOB) Reporting Description of Change The TNOB repons to the Vice President and ChiefNuclear Oflicer instead of the Vice President Nuclear.
Reason for Change Amendment 187 to the Trojan Facility Operating License revised the reporting relationship for the TNOB.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments Criterion I to 10 CFR 50, Appendix B requires that the persons and organizations performing quality assurance functions have sufficient authority and organizational freedom. The TNOB reporting to an officer of higher level increases the organizational freedom and so is not a reduction.
Item No. 2
Title:
Deletion of the Quality Suppon Section Description of Change Duties performed by the QSS will be performed by other organizations within Nuclear Oversight.
Reason for Change QSS performed clerical and internal budgeting suppon to Nuclear Oversight. It has been decided to have these functions performed by other organizations within Nuclear Oversight.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments 10 CFR 50, Appendix B, Criterion I requires that the authority and duties of persons and organizations performing activities affecting the safety related functions of structures systems and components be clearly established and delineated in writing. Since the duties previously performed by QSS will continue to be addressed by Nuclear Oversight, this does not represent a reduction in commitment.
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a Trojan Nuclear Plant Document Control Desk -
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Docket 50-344 March 31,1993 License hTF-1 Attachment II t
Page 2 of 6 Item No. 3 i
Title:
Emironmental Services Reporting to the Vice ' President, Public Affairs Description of Change Emironmental Senices repons to the Vice President, Public Affairs instead of the Vice President, Administration Reason for Change I
PGE has decided to change the reporting responsibility of this department.
i Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments 10 CFR 50, Appendix B, Criterion I requires that the authority and duties of persons and organizations performing activities affecting the safety related functions of structures systems and components be clearly established and delineated in writing. The activities performed by Environmental Senices are not safety related, and thus Appendix B is not applicable to this organization. Changing the reporting of the Emironmental Services Department involves no reduction in commitment.
Item No. 4
Title:
Term " Standard Technical Specifications" changed to " Trojan Technical Specifications" Description of Change This change replaces the terminology " Standard Technical Specifications" with " Trojan Technical Specifications" wi;h regard to auditing of the Fire Protection Program at Trojan.
Reason for Change This change is being made to define more clearly the specifications employed in audits of the Trojan Fire Protection Program.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, f
Appendix B, and Evaluation of Pertinent NRC Commitments There are no requirements in 10 CFR 50, Appendix B regarding fire protection or loss prevention audits. As the fire protection audit requirements specified in both Trojan Technical Specifications and the Standard Technical Specifications are equivalent, this '
change does not constitute a reduction in commitment.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 -
March 31,1993 License NPF-1 Attachment II Page 3 of 6 Item No. 5
Title:
" Department" deleted after Nuclear Security Description of Change This is a change in title only, deleting the word " Department" from Nuclear Security.
f Reason for Change This word change was made as part of Revision 14 to the Nuclear Quality Assurance Plan, but this item was inadvertently overlooked in this instance.
1 Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments There are no requirements in 10 CFR 50, Appendix B, concerning the titling of j
organizations. Since there are no changes in the responsibilities involved, there are no reductions in commitments.
Item No. 6 1
Title:
Deferral of Biennial Procedure Reviews Description of Change I
This is an administrative change whereby biennial reviews may be deferred for procedures supporting activities not anticipated to be performed provided the biennial reviews are current or completed prior to use of the procedures.
q Reason for Change This change is being implemented to reduce the number of superfluous biennial procedure reviews performed.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments The PGE requirement for biennial review of procedures is found in PGE-8010, Revision 14, pages x and xi, and commits PGE to follow the guidance in Regulatory Guide 1.33, Revision 2, February 1978, " Quality Assurance Program Requirements (Operation)" This.
regulatory guidein turn endorses ANSI N18.7-1976/ANS-3-2, " Administrative Controls i
and Quality Assurance for the Operational Phase ofNuclear Power Plants" l
ANSI N18.7-1976/ANS-3-2, page 16, states the following concerning biennial reviews:
't "Plantprocedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no lessfrequently than ever twoyears to determine if
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t Trojan Nuclear Plant Document Control Desk l
. Docket 50-344 March 31,1993 -
License hT F-1 1 Page 4 of 6 changes are necessary or desirable. A revision ofaprocedure constitutes a procedure review."
l The paragraph added to PGE-8010 describes the deferment of the biennial procedure j
reviews for certain procedures supporting activities not anticipated to be performed in the future. This will also ensure that prior to an activity being conducted, the associated procedure (s) will have undergone the required biennial reviews as specified by the above ANSI standard. At the same time, this will help reduce the number ofunnecessary biennial procedure reviews.-
In addition,10 CFR 50, Appendix B, Criterion VI requires that documents including changes be reviewed for adequacy. Performing the biennial review prior to use of the i
procedure meets this requirement. Therefore, this change does not constitute a reduction -
in commitment.
Item No. 7
Title:
Change in terminology of" Maintenance Request" Description of Change r
The term " maintenance request" is being replaced by " work package" for recording the location of the installation of an item withdrawn from a storeroom.
I Reason for Change This revision represents merely a change in terminology employed at Trojan for maintenance requests.
f-Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments 10 CFR 50, Appendix B, Criterion VIII requires control measures to prevent the use of incorrect or defective material, parts, and components.' This terminology change does not
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alter the controls for withdrawal ofitems from a storeroom. Hence, this does not constitute a reduction in commitment.
f item No. 8 i
Title:
Corrected Spelling Descriptio~n of Change This change corrects the spelling of the word " organization" in Section 13.2.3, "OfTsite Program".
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Trojan Nuclear Plant Document Control Deck
.c Docket 50-344 March 31,1993 License NPF-1 Attachment II Page 5 of 6 i
Reason for Change Correcting typographical error that occurred during document development.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments This is a change in sp_elling only, and does not constitute a reduction in commitment.
Item No. 9
Title:
Notification ofCompany Officers Regarding 10 CFR 21 Reporting Description of Change The Compliance Department instead of the cognizant supervisor notifies the Company
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Oflicer of the need for a 10 CFR 21 report.
Reason for Change This change is being made to better facilitate the internal notifications for 10 CFR 21 items.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments There are no requirements in 10 CFR 50, Appendix B concerning notification of Company OfIicers of the need for a 10 CFR 21 report. This change is being made to improve the internal notification process for 10 CFR 21 items. PGE commitments for notification of a Company Officer concerning a 10 CFR 21 item are not reduced.
Item No.10
Title:
Change in Definition of Licensee Event Report t
Description of Change Definition ofLER is being changed in the glossary of PGE-8010 to use the terminology Reponable " Event" in lieu of Reportable " Occurrence".
Reason for Change This change was made to afford terminology agreement with Trojan Technical Specification 1.7.
Basis for Concluding the Change Meets the Requirements of 10 CFR 50, Appendix B, and Evaluation of Pertinent NRC Commitments There are no requirements in 10 CFR 50, Appendix B, concerning reporting ofReponable Events. This change is being implemented to afford terminology agreement between
r, Trojan Nuclear Plant Document Control Desk
. Docket 50-344 March 31,1993
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License NPF-1 Attachment II
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Trojan Technical Cpecifications and 'the Nuclear Quality Assurance Program. ' As this is a terminology change only, this does not represent a reduction in commitments.-
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