ML20056D638

Provides Suppl Info Addressing Issues in Areas of Quality Assessment Section Responsibilities,Quality Svcs Section Responsibilities & Independent Safety Engineering Reporting Structure,Supporting Review of 930805 Changes to QA Program

ML20056D638
Person / Time
Site:	Davis Besse
Issue date:	08/10/1993
From:	Storz L CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
2170, NUDOCS 9308170235
Download: ML20056D638 (16)

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ENENCY Louis F. Sforz,

300 Madison Avenuc Vice President - Nuclear Toledo, OH 43652-0001 Davis-Besse (419)249-2300 l

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.i Docket Number 50-346

.i License Number NPF-3 i

i Serial Number 2170 j

i August 10, 1993

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United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.

20555

Subject:

Supplemental Information for 10CFR50.54(a)(3) Evaluation for

-l Proposed Reorganizat!.9n-l ll Gentlemen:

i This letter is submitted to address issues raised following your reviev of our request for approval of changes to the Davis-Besse Nuclear Pover.

Station'(DBNPS) Quality Assurance program, dated August 5, 1993 (Serial i

Number 2167). This letter provides supplemental information which j

f addresses these issues in the areas ~of Quality Assessment Section..

responsibilities,-Quality Services Section responsibilities, and the.

independent safety engineering (ISE) reporting structure.

j These clarifications are as follows:

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The Engineering Assurance responsibilities that vere transferred.to.

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t the Quality Assessment Section vere clarified in the Manager -

Quality Assessment responsibilities as being assessment activities-

-l of engineering and plant chemistry programs.

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The Quality Services Section (previously Plant Services) j responsibilities have been detailed in the attached 50.54(a)_

i evaluation.

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The responsibility for ISE functions has been clarified to show ISE ~

i' reporting to the Manager - Quality contre',

This:information has been incorporated-into the_ attached-marked-up Updated Safety Analysis Report (USAR)'pages and the 10CFR50.54(a)

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evaluation.

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Docket Number 50-346 License Number NPF-3 Serial Number 2170 Page 2 f

Should you have any questions or require additional information, please contact Mr. Dale R. Vuokko, Manager - Nuclear Licensing (Acting), at 3

(419) 249-2366.

l Very truly yours, j

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Attachments J

cc:

J. B. Hopkins, NRC Senior Project Manager l

J. B. Martin, Regional Administrator, NRC Region III r

S. Stasek, DB-1 NRC Senior Resident Inspector

• l Utility Radiological Safety Board

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' Docket Number-50-346 License Number NPF-3 Serial Number 2170 1

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Listing of Submittal Contents I

Davis-Besse Unit 1 USAR Section 17.2, Quality Assurance-Program for Station Operation, Pages Affected by Proposed Changes t

Evaluation of Proposed Quality Assurance Program' Reductions 7

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Docket Number 50-346 License Number WPF-3 Serial Number 2170 i

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Note l

The attached marked up USAR Section 17.2 includes several changes made prior to the proposed change of Quality Assurance to Nuclear Assurance.

j The elimination of the Manager - Quality Systems occurred in October 1992 (reference: USAR Change Notice (UCN)92-081). The responsibilities of the Manager - Quality Systems were divided among the remaining Quality Assurance Sections (Quality Verification and Quality Control). This change did not reduce commitments identified in i

the Quality Assurance Program.

Another change that was made eliminated the day-to-day, in-line quality review of specification and modification packages performed by the Engineering Assurance Unit of the Engineering Assurance and Services Section (reference: UCN 92-058). This change was approved by the NRC on October 30, 1992 l

(Toledo Edison Log 1-2721).

l The remaining Engineering Assurance Unit functions (assessment of engineering activities and products, and assessments of plant chemistry q

programs) have been assimilated into the Quality Assessment Section l

(reference UCN 93-044). The Services Unit functions of the Engineering l

Assurance and Services Section vere moved into Quality Services Section (previously Plant Services) and the Engineering Department. The

.l process administration activities (modification package and vendor manual processing) were transferred to Plant Services.' The technical l

evaluations (modification package development, budget administration, procedure control and engineering training) remain the responsibility j

of engineering (reference UCN 93-044). This change did not reduce commitments identified in the Quality Assurcoce Program.

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Docket Number 50-346 License Number NPF-3 Serin 1 Number 2170 t

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C OM o 17.?.1.4 Toledo Edison Nu,1Eear Group 5

tJUC. LEAR DIRECTOR - QUALITY ASSURANCE Noc car l1 The Director -.Que 4ty Assurance reports to the Vice President - Nuclear and is responsible for the development, maintenance, and monitoring of the Nuclear 14 l

Quality Assurance Program. The Director is also responsible for advising the l

Plant Manager and cognizant corporate manag,em nt,of the Quality Assurance Program's effectiveness. The Director - '" 4y Assurance is independent l14 from cost and scheduling considerations when opposed to safety considerations, 1

cnd is free of non-QA related duties 6 He is authorized to identify l9l1 quality problems initiate, recommend, or provide solutions, through designated channels: verify implementation of solutions: and verify l9 Q-.J.g8'Assurancehastheauthoritytosuspend(stopwork) c rmance to established quality requirements. The Director -

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7 any activity.

l14 except reactor operation, not in conformance with specified requirements 1

cnd/or provisions of the NQAM. Conditions adverse to quality that appear r

to warrant suspension of reactor operation, including startup or power g

at, ion are immediately reported to the Plant Manager. The Director p-Assurance is responsible for the adequate staffing of the 14

-Qua..ty Assurance Department to ensure that the requirements of the NQAM are effectively implemented.

1-g MANAGER - QUALITY CONTROL 9

The Manager - Quality Control repor'ts to the Director - Quality Assurance and l14 is responsible for managing the Quality Control staff in the quality review,

.l1 inspection, and examination of plant structures, systems, and components 14 within the scope of the Nuclear Quality Assurance Program to assure compliance to procedural, drawing, and engineerin6 specification requirements. This responsibility includes the inspection of welding to verify it meets ASME, National Board, and State of Ohio requirements in 1

addition to coordinating the activities of the Authorized inspection Agency to ensure Code compliance.

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~Inseri O 17.2-4 REV 16 7/92 i

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License Number WPF-3 Serial Number 2170 l

Page 3 P

Insert A The Director - Nuclear Assurance is also responsible for managing the activities of independent safety engineering, engineering assurance and l

the review of external information and plant operations assessments.

The Director - Nuclear Assurance is responsible for managing support i

services associated with procedure control, records management and

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document control.

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i Insert B The Manager - Quality Control is also responsible for development and j

maintenance of the ASME Quality Assurance Manual and Quality Control and selected Nuclear Assurance Department Procedures. The Manager -

l Quality Control is also responsible for review of all corrective action documents for close-out, review of selected site procedures, receipt inspections, vendor surveillances and review of vendor supplied documentation, and Ouality Control Staff training. The Manager -

Quality Control is also responsible for directing the activities of the l

independent safety engineering group in providing technical expertise onsite to allow for systematic and independent assessment of plant activities, surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are

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performed correctly, and investigation of plant incidents which.may-affect the underlying assumptions in the USAR Accident Analysis.

The Manager - Quality Control is also responsible for the review of all external information received in support of improved performance and reliability and for plant operations assessments.

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Docket Number 50-346 License Number NPF-3 D-B Serial Number 2170 Page 4 9

e A SSESSP1EA'7' 8

HANAGER - QUALITY */ P.!r!CATIOT 9

g ssessment thsSt*"'"

WM The Manager - Quality erificcticr. reports directly to[the Director --Ocality l14 Assurance and is responsible for managing the Quality.crificatica staff in the performance of internal and selected external OA audits, and for QA 8

surveillance of station operations.

l ][nserf C l "ASAGEn - GUALITY SYSTEMS 9

Th anag r - O ality stems r ports d rectly o the [ rector-Qual y

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uran and s resp nsible r supe vising e Qual ty Sys ms Sta f.

ctivi ies v' thin t - Qualit System anager s area f resp nsibil y inc de the evelo i.en t a revisi of th Nuclea and AS Qual y Assu nce H uals an Quali y Assu. nee De rtment rocedur s, Int -depar ent Pr cedur Reviev, 9

C rrect e Act n Docum it Clos e, Qua ty Ass ance partme Trai ng,

.uali Trend g and alysis, vendor udits/S rveill.ces, R viev a d Appr val of V dor 0 lity As urance P ograms rocedu s, mai tainin the A roved Ve sor Lis, Recei Inspec on, a Vendor uppli Docum tatio Revie.

Insert D

17.2-5 REV 14 7/91 I

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Serial Number 2170 Page 5 l

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l Insert C The Manager - Quality Assessment is also responsible for development f

and maintenance of Quality Assessment and selected Nuclear Assurance l

Department Procedures, review of inter-department procedures, selected site procedures, the review and approval of Vendor Quality Assurance Programs and Procedures, performance of vendor audits, review of selected procurement documents, and control of the approved vendors list. The Manager - Quality Assessment is also responsible for the development, maintenance and implementation of the trending and analysis program and Quality Assessment staff training. The Manager -

i Quality Assessment is also responsible for the independent assessment of engineering activities and products, and for assessments of the plant chemistry and radiochemistry programs.

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'f Insert D Manager - Quality Services The Manager - Quality Services reports to the Director - Nuclear Assurance and is responsible for the development and maintenance of the Nuclear Quality Assurance Manual, managing support services associated i

vith quality and non-quality records management, document control,. site vide procedure control and administrative services.

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Docket Number 50-346 License Number NPF-3 Serial Number 2170 Page 6 i

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d tW4AGER - p EPDJDDIT SdETY DJGJ EEIGtJG 19 The ager - Inde ent Sa Engin ring rep ts direct y to the ' ce 9

Pre dent - Nuc ar, and i responsi e for pr iding te iical eq tise 9

-site to al v for sys ematic an independ t assessm t of pla,

6 activities. Addition responsi ities i ude surv 11ance o plant 5

l operatio and main ance act ities to rovide in pendent chni-5 cal ve ication tJ at these tivities re perfo

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>s-5 tiga on of pl [ incidents 'hich ma affect th underlyir assumpt' ns in 5

th USAR Acci t Analys'. The I Departme functio inde ently from 8

l her Nucle Group ac - ities.

6 COMPA!U NUCLEAR FIVIEW BOARD i

The Company Nuclear Reviev Board (CBS) is responsible for providing an l

' independent review and audit of activities affecting quality to assure itself that Davis-Besse is being operated and maintained in compliance I

with the Nuclear Quality Assurance Program and the Operating License. The nature of C EB activities include the monitoring and review of functions 5

and problems pertaining to-nuclear safety. The Chairman of the O EB is responsible for providing a QEB Charter which meets the requirements of I

Section 6 of the Technical Specifications.

STATION FIVIEV BOARD The Station Review Board (SP3) is responsible for the reviev of Plant Admin-1 istrative procedures, data, and deficiencies related to nuclear safety as 1

identified in the' SRB Charter. The SRB may,'as it determines necessary 7

7 direct investigations by Station personnel of facility activities to assure 1

t that these activities have been, are being, and vill be performed in 1

accordance with approved vritten procedures.- Generally, the SRB is 1

i concerned vith the nuclear safety related aspects of facility operation and 7

coordinates its activities vith Quality Assurance to satisfy the OA 1

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requirements for facility operation. The Chairman of the SRB is responsi--

1 ble for providing an SRB Charter which anects the requirements of Section 6 1-1

.f of the Technical Specifications.

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^ Docket Number'50-346 ~ License Number NPF-3 Serial Number 2170 Page 1 10CFR50.54 EVALUATION FOR UCN 93-032, REVISION 02 (EVALUATION OF PROPOSED QUALITY ASSURANCE PROGRAM REDUCTIONS) PROPOSED CHANGES t The proposed changes to the Updated Safety Analysis Report (USAR) Chapter 17.2, Quality Assurance Program for Station Operation, are shown on the attached marked up pages of Section 17.2.1.4, including Pigure 17.2-1, (Toledo Edison Nuclear Group) and are revisions to I previous UCNs 93-028, 93-032 and 93-044. Description of Change 1 (Pages 17.2-4, 17.2-5 and 17.2-Ila and b) A. Modify the phrase "and is free of non-0A related duties..." by i adding the clarification of: ...except for those non-0A related functions of the Manager - Quality Services." B. Transfer the responsibilities for "the review of all external information received in support of improved performance and reliability and for plant operations assessments" to the the Manager-Quality Control (who reports to the Director - Nuclear Assurance) from the Manager - Regulatory Affairs. C. Change the title of Manager - Plant Services to Manager - Quality Services and shift reporting of the Manager - Quality (Plant) Services to the Director - Nuclear Assurance from the Director - Nuclear Services. Transfer the non-0A functions of " site-vide procedure control, records management, document control, and administrative services" to the position of the Manager - Quality' Services (who reports to the Director - Nuclear Assurance). Description of Change Number 2 (Pages 17.2-4 and 17.2-11c) i Shift the responsibilities for " independent safety engineering" to the position of the Manager - Quality Control (who-reports to the Director - Nuclear Assurance) from the deleted position of the Manager - Independent Safety Engineering presently reporting directly to the Vice President - Nuclear and presently functioning independently from other Nuclear Group departments. These responsibilities include "providing technical expertise onsite to allow for systematic and independent assessment of plant activities" and " surveillance of plant operations and maintenance activities to provide independent technical verification that these activities are performed correctly, and investigation of plant incidents which may affect the underlying assumptions in the USAR' Accident Analysis". l i l l

Docket Number 50-346-License Number NPF-3 Serial Number 2170 t Page 2 i Reason for Changes i To support the Centerior Energy reorganization. j To allow the Director - Nuclear Assutance to assume additional responsibilities for performing quality assurance functions, and some j non-quality assurance functions, as described above. i Effect of Change 1 A. ELIMINATION OF "NON-QA DUTIES" RESTRICTION ON OA DIRECTOR Under the proposed Davis-Besse Nuclear Power Station reorganization, the position of Director - Nuclear Assurance t (presently the position of Director - Quality Assurance) vill no l longer be " free of non-0A related duties" as stated in USAR Section l 17.2.1.4 of the Quality Assurance Program for Station Operation. The phrase "and is free of non-0A related duties" is not a requirement of 10CFR50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants, Criterion I - Organization. The requirements of Criterion I do not preclude persons and organizations performing quality assurance functions from performing non-quality assurance j functions when such functions do not affect the safety related functions of structures, systems, and components. The basis for concluding that the new position of Director - Nuclear Assurance, vith the modification of non-QA related duty restrictions, vill continue to satisfy the requirements of 10CFR50 Appendix B follows: Under provisions of 10CFR50 Appendix B, Criterion I, persons and organizations. performing quality assurance functions must have sufficient authority and organizational freedom to identify quality problems; to initiate,' recommend, or provide solutions; and to verify implementation of solutions. It also requires those persons and organizations performing quality assurance functions to report to a management level such that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided. ? The proposed changes and USAR 17.2.0, Policy, establish sufficient authority and organization freedom, and sufficient independence from cost and schedule when opposed to safety considerations for the quality assurance function and continue _to satisfy the provisions.of 10CFR50 Appendix B, Criterion I. B. TRANSFER OF "0PERATIONS EXPERIENCE ASSESSMENT (OEAP)" ACTIVITIES TO NUCLEAR ASSURANCE The Manager - Quality' Control (who reports to the Director - Nuclear Assurance) assumes the responsibilities for "the review of 1 all' external information received in support of improved performance and reliability and for plant operations assessments" i I i

^ Docket Number 50-346 License Number NPF-3 Serial Number 2170 Page 3 l from the Manager - Regulatory Affairs. The transfer of these OEAP activities with ISEG activities (See Effect of Change 2) to Nuclear Assurance (Quality Control) consolidates responsibility for similar overview activities. The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows: This additional responsibility provides activities which are considered to be an enhancement of quality assurance functions described in 10CFR50 Appendix B, Criterion I. The audit and surveillance activities of the Manager - Quality Assessment will remain independent of these functions just as they have in evaluating existing Quality Control functions. ^ C. TRANSFER OF " PLANT SERVICES" ACTIVITIES TO NUCLEAR ASSURANCE The Manager - Quality Services (who reports to the Director - Nuclear Assurance) assumes the following non-quality assurance functions from the deleted positions of Director - Planning and Support and Manager - Engineering Assurance and Services: 1. Process administration for site-vide procedures, records management including quality assurance and non-quality assurance records, and document control, including modification packages and vendor-manuals; and 2. Administrative office services including site tour program, library operation, word processing, duplicating and mailing. The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows: The non-quality assurance functions, described in items 1 and 2 l above, only involve administrative " flow, process and control" services which do not affect the safety related functions of structures, systems and components. The " technical content" of related activities (including site-vide procedures, quality-assurance records, modification packages and vendor manuals) vould continue to be performed by the responsible technical organization. The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of these non-quality assurance functions just as they have in evaluating existing Quality Control functions. Effect of Change Number 2 TRANSFER OF " INDEPENDENT SAFETY ENGINEERING (ISEG)" ACTIVITIES TO NUCLEAR ASSURANCE The Manager -Quality Control (who reports to the Director - Nuclear Assurance) assumes the responsibilities for " independent safety ] )

Docket Number 50-346 License Number NPF-3 Serial Number 2170 Page 4 engineering" from the deleted position of the Manager - Independent Safety Engineering presently reporting directly to the Vice President - Nuclear and presently functioning independently from other Nuclear Group departments. The transfer of these ISEG activities with OEAP activities (See Effect of Change 1B) to Nuclear Assurance (Quality Control) consolidates responsibility for similar overview activities. l The function of independent safety engineering is neither a Technical l Specification nor a 10CFR50 Appendix B requirement for Davis-Besse. Under the proposed change, the Manager - Quality Control, who vill report to the Director - Nuclear Assurance, vill have responsibility for the function of independent safety engineering. The independent l safety engineering function vill no longer be a separate area which reports directly to the Vice President - Nuclear, as previously described. The level of independence for independent safety engineering activities is established in USAR Section 17.2.0, Policy. To adequately fulfill assigned responsibilities of the Director - Nuclear Assurance, the Policy allows the Director - Nuclear Assurance l access to the Chairman (President and Chief Executive Officer) if the need for such access exists. The organizational freedom described is considered to be sufficient for independent safety engineering activities. The basis for concluding that this organizational change regarding the new position of Director - Nuclear Assurance continues to satisfy the requirements of 10CFR50 Appendix B follows: These additional responsibilities provide activities which are considered to be an enhancement of the quality assurance functions described in 10CFR50 Appendix B, Criteria I, and are appropriately organizationally structured for that purpose. The audit and surveillance activities of the Manager - Quality Assessment vill remain independent of these functions just as they have been in evaluating existing Quality Control functions. i BASIS FOR CONCLUSION THAT CHANGES CONTINUE TO SATISFY THE CRITERIA OP 10CFR50 APPENDIX B In summary, the Director - Nuclear Assurance vill have the following functional responsibilities in addition to the quality assurance responsibilities presently held: independent safety engineering, the review of external information, plant operations assessments, site-vide procedure control, records management, document control, and administrative office services. The basis for concluding that the organization changes, identified 1 above, continue to satisfy the requirements of 10CFR50 APPENDIX B, is as follows: 1. The proposed changes vill not diminish or reduce the effectiveness of the quality assurance functions as currently described.

J Docket Number 50-346 -License Number NPF-3 Serial Number 2170 Page 5 l i 2. The changes continue to provide sufficient authority and l organizational freedom of the quality assurance functions to j identify quality problems and sufficient independence from cost and schedule when opposed to safety considerations, j 3. The changes provide an independent organization to function in a j strong overview capacity, utilizing both compliance and j performance based approaches. j 4. The changes provide an overview function with a high level of i expertise and management involvement in areas such as: traditional quality assurance activities and overviews and assessments of engineering activities, operational activities, and industry experience. 5. The audit.and surveillance activities of the Manager - Quality Assessment vill remain independent of all these additional l ~ functions just as they have in evaluating existing Quality Control functions. l 6. The Quality (Nuclear) Assurance department is periodically 4 assessed by the Company Nuclear Reviev Board (CNRB) and by external organizations such as NRC, INPO, and the Joint Utility Management Assessment (JUMA) team. Similar assessment of these j additional Nuclear Assurance functions vill be periodically performed. This reorganization is perceived to enhance Toledo Edison's goals in providing safe _and reliable operation of the Davis-Besse Nuclear Power Station. j i i i t i i i ) ,}}