ML20043F662

Requests for Change in QA Program 10CFR50.54 & FSAR Biennial Reviews of Plant Procedures Based on Justification Contained in Proposed Change to FSAR.SAP-139 Will Be Revised Immediately Following Approval of Request

ML20043F662
Person / Time
Site:	Summer
Issue date:	06/07/1990
From:	Bradham O SOUTH CAROLINA ELECTRIC & GAS CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9006150191
Download: ML20043F662 (5)

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l June 7, 1990 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. Jack Hayes

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 l Operating License No. NPF-12  ;

Request for Change in Quality Assurance Program 10CFR50.54 and FSAR Biennial Reviews of V. C. Summer Nuclear Plant Procedures Gentlemen:

This letter requests a change to the Quality Assurance Program as described im the Virgil C. Summer Nuclear Station Final Safety Analysis-Report-(FSAR),

Appendix 3A, Item 1.33. Currently, the FSAR, by reference to ANSI N18.7, and

! Station Administrative Procedure SAP-139 require biennial review of plant procedures based on the justification contained in Attachment 1. Attachment 2 contains the proposed change to the FSAR.

It is the SCE&G position that this change does not involve a significant reduction in commitment. SAP-139 will be revised immediately following approval of this request, and the change will be incorporated into the FSAR by our normal revision program.

If there are any questions, please contact us at your convenience.

Very truly yours,

$ 0 <

0. S. Bradham HID/0SB:1bs Attachments c: O. W. Dixon, Jr./T. C. Nichols, Jr. '

E. C. Roberts R. V. Tanner J. C. Snelson S. D. Ebneter NRC Resident Inspector J. J. Hayes, Jr. J. B. Knotts, Jr.

General Managers NPCF C. A. Price NSRC

.R. B. Clary RTS (IE 901201)

K. E. Nodland File (813.12-4) 9006150191 900607 PDR ADOCK 05000395 P PDC \

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ATTACHMENT 1 JUSTIFICATION FOR PROPOSED CHANGES

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JUSTIFICATION FOR CHANGE The Licensee considers a dynamic process to be a rcquirement in maintaining procedures in an accurate and useful condition. The static biennial review process specified by ANSI N18.7 does not meet this requirement.

Over the past years, we have effected controls to ensure that potential procedural impact is assessed and revisions are made based on input from a number of different programs.

The following programs adequately provide input to procedure revisions and changes:

1) The plant modification program requires an interface review of all modifications by groups which are potentially affected by the modification. This interface review requires that all procedures potentially affected by the modification be identified and changes or revisions made prior to closure of the modification package.

2) The non-conformance notice program requires engineering evaluation and disposition of all non-conformances. This includes consideration of procedure changes and revisions which may be required as a result of the disposition.

l 3) The Off-Normal Occurrence program requires documenting events which occur at the. station and are considered to be outside of normal, expected operation. These events are reviewed by management for determination of cause and corrective action. Corrective action specified for these events may include procedure revisions and changes.

4) The operator feedback program requires that procedure deficiencies or problems which prevent their implementation be formally documented and provided to the Operations Procedure Unit for evaluation and incorporation into procedure revisions and changes.

5) The surveillance test program requires that procedure problems, identified during the performance of the procedure, be documented as l test deficiencies and evaluated for changes to procedures. These changes may be required prior to continuation of the performance of the I tests, or after completion of the tests, depending on the nature of the I

problems and a determination that the problems do not preclude the completion of the tests.

6) The operating experience review program requires the review of HRCBs, ins, SERs SOERs as well as Vendor Bulletins and Notices for applicability to the Licensee's plant and for the determination of action required. This review includes an evaluation of applicable procedures and the initiation of any required procedure changes.

7) Revision to Technical Specifications and the FSAR require evaluation for impact on procedures and result in the initiation of procedure changes, as required.

8) Corrective actions as identified for regulatory issues address required procedure changes or revisions. This would include responses to violations, generic letters, and other regulatory concerns.

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9) The Quality Assurance Program includes a review of procedures as part of

, its audit and surveillance process (which is based on.a two year cycle).

The Independent Safety Engineering Group also performs overviews that include review of procedures. _ Input to procedure changes and revisions g Li s provided by these two avenues, f '

SJMMARY As is evidenced by the number of programmatic controls discussed above for procedure input and revision, the Licensee considers the biennial review  !

process to be redundant and unnecessary. The impactlDn plant resources of  !

- the biennial reviews-reduces the Licensee's' ability to concentrate on issues i of greater significance to plant safety. Therefore, it is recommended that '

this change be approved as an enhancement to plant safety. ,

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- SUGGESTED FSAR WORDING

. 1.33 OVALITY ASSURANCE PROGRAM RE0VIREMENTS (OPERATIONS)

(Revision 2: 2/78)

The Virgil C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.33 as discussed in Section 17.2 and Section 6.0 of the Technical Specifications with the following exceptions and clarifications:

The plant has programmatic control requirements in place'that make the biennial review process redundant. These programmatic controls were affected in an effort to ensure that plant instructions and procedures are reviewed for possible revision when pertinent source material is revised, therefore maintaining the procedures current. SCE&G believes that this approach better

. addresses the intent of the biennial review process and is more acceptable 1 from both a technical and a practical perspective than a static two-year review process.

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