ML20077K225
| ML20077K225 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/31/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 1-957, NUDOCS 9108070122 | |
| Download: ML20077K225 (7) | |
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I CENTERDOR ENERGY Donald C. Shelton 300 Maison Avenue Vee Pie 2nl Nxlear foiedo, OH 43%20001 Dus Bene (419)249 2300 Docket Number 50-346 License Number NPF-3 Serial Number 1-957 July 31, 1991 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555 Subj ect :
Request For Change in Quality Assurance Program Biennial Procedure Reviev Gentlemen The Toledo Edison Company hereby submits, pursuant to 10 CFR 50.54(a)(3),
a proposed alternative to the requirement to perform biennial reviews of plant procedures in accordance with ANS/ ANSI 3.2-1982, Administrative Controls and Quality Assurance For Nuclear Power Plants.
In place of this reviev, Toledo Edison has existing programmatic controls that continually identify changes to and update procedures at the Davis-Besse Nuclear Power Station, Unit Number 1.
In addition to these programmatic controls, an annual quality assurance surveillance of randomly selected procedures vill be conducted following approval of this proposed change. This annual surveillance vill provide assurance that procedures are being maintained current.
This change, as indicated in the attached 10 CFR 50.54(a) reviev, has been identified as a reduction to the commitments identified in USAR Chapter 17.2, Qu.11ty Assurance Program for Station Operation.
Although this change has been identified as a reduction in commitment, the Quality Assurance Program continues to satisfy the criteria of 10 CFR 50, Appendix D.
Toledo Edison requests your approval of the proposed change by August 30, 1991. This expeditious reviev is requested due to the large number of man-hours that vould be utilized in performing unnecessary biennial reviews of procedures during the upcoming seventh refueling outage (7RFO).
Elimination of the static biennial reviev vould permit redirection of resources to procedure changes resulting from plant changes dut 1g the 7RFO.
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' License Number NPF-3 Serial Number 1-957 Page 2 If you have any questions concerning this matter, please call Mr. R. V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
Very truly yours,
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JCS/ach Attachment ecs. P. H. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC/NRR DB-1 Senior Project Haneger Utility Radiological Safety Board l
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TABl.E 00 CONTENTS DIENNIAL PROCEDURD REVIEW PROCESS REVISION Attachment, page-1
-Proposed exception to ANS/ ANSI 3.2-1982 Section 5.2.15 Attachment, page 2 10CTR$0,54 reviev
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ATTACilHENT, Page 2 10 CrR $0.54 Reviev July la, 1991 PROPOSED REPLACEMENT OF lilENNI Al. REVll:V OP phANT PROCEDllRES VITil PROGRAMMATIC CONTROLS AND YEARLY StlRVEILI.ANCE.
Change Number 1 Table 17.2-1, add item 4, Position 1.F, pcge 17.2-54a.
Description of Change F.
Section 5.2.15 requites that " Plant procedures shall be revieved by an indi-vidua knovledgeable in the aten affected by the procedure no less frequent-ly 'han every two years to determine if changes are necessary or desirable.
This requirement for routine follov-up review, cat be accomplished in sever-al vays, including (but not necessatlly limited to):
documented step-by-step use of the procedure (such as occurs when the procedure has a step-by-step checkoff associated with it), or detailed scrutiny of the procedute as part of a documented training program, drill, simulator exercise, or other such activity. A revision of a pr ocedute constitutes a procedute reviev."
In lieu of these requirements, Davis-Desse has many existing programmatic conttols, which identify the necessity for procedure alterations to ensute that procedures are appropriate for the circumstance and are maintained current.
Additionally, Davis-Besse performs an annual Quality Assurance surveillance of randomly selected plant procedures. The surveillance vill provide added assurance that existing programmatic controls provide for timely revision of ptocedures.
Reasonforchangcj Toledo Edison proposes deleting the requirement for a biennial review of plant procedures.
Maintaining plant procedures current to preclude the use of outdated or inappropriate procedutes is a dynamic process. The need for procedure changes may be identified at various times for various tensons.
Changes are evaluated for implementation at the time of identification.
Davis-Besse has developed many programs which enhance the procedure alteration process which provides assurance that procedutes nre approprlate for the circumstances and remain curtent/up-to-date. These programmatic controls address the intent of the static biennial re-view process and from both a technieni and a practical petspective, provides greater assurance that procedures vill be maintained current. The biennial re-view is redundant to the established programmatic controls and is no longer con-sidered necessary. These existing controls are described below:
1.
The Plant Hodification Program requites an interfacing document reviev and alteration of procedures affected by the modification be performed. The program provides additional measures for nesuring that all procedures aits i
I ted by the modification are updated to reflect the changes, prior to return-ing the modified system to service.
The Potential Condition Adverse to Quality Reporting and Management Correc-tive Action Reporting Programs require that an evaluation for disposition be performed and remedial action (s) be taken to fix or improve an identified condition adverse to quality.
These actions may identify procedural inade-quacies and requite a procedure (s) alteration to preclude recurrence.
Page 2 of 4
T ATTACilMl:NT.
H,enhon t or_ Change 1_(Cont inued)
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I 3.
The Test Conttol Ptogram tequites that test personnel ate qual!!ied to per-form the test procedute, and the use of apptoved and controlled test ptoce-dunes.
Deficiencies encounteted during the conduct of test procedures sie documented nad evaluated to dete mine if test procedute alteration is need-ed.
Hesolution is provided ptfor to final approval of the teet tesultn.
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4.
The Conduct of Openations and Maintenance Conttol Ptogtams tequi1e the use of apptoved and controlled procedutes by qualified petsonnel, and attiet ad-het ence to pt ocedures.
The ptogram also encourages uset Icedback on the adequnty of procedures and prompt identification and initiation of necessary procedure alterations and actions to be taken when procedules cannot be petionmed as vtitten.
P 5.
The Preparation and Control of Updated Safety Analysis Report (USAlt) Changes t
Program requires that when changes ate being made to the USAk an interfacing document review of pt ocedures be perf ortned.
Affected procedutes are alteted i
prior to issuing the USAR change.
6.
The Revision, Review and Control of Quality Assurance Hanuals requires that when changes ate being made to the Quality Assutance Manuals an interfacing document reviev of procedut es be perf oirned.
Affected procedures ate altered prior to issuing the manual tevision.
7.
Tho Vendot Hanual Conttol Program ptovides fet the ptocurement, teceipt, teviev, apptoval, change, contiol and distributton of vendor manuals and other vendot technical information.
The progtam requites apptoval of vendor manuals or vendor correspondence prior to use.
Subsequent revisions 1.
changes to vendor manuals and other vendor technical information ate also approved and ptocedures are revieved for impact and approval provisions ate made to ensute-that affected-procedures ate curtent.
8.
The Operating Experience Assesrment Ptogram provides measures for ensuring
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that NRC Notices, Significant Operating Experience Heports, Significant Event Reports, Significant_By-Other Notif! cations. Operating Plant-Expet1-ence Heports, Operations'and Haintenance keminders, Preliminary Safety Con.
cetns and Transient Assessment Ptogram Reports are evaluated to determine !!
programmatic _on technical _ inadequacies exist at Davis-Besse.
The progaam includes provisions for encuring apptopriate cortective action is taken when an inadequacy is identified. These evaluatiens can have an impact on proce-dutes and requite procedute altetations 'o enable closure of the applicable report.
l 9.
The Operating 1.icense Amendments Program tequires an interfncing document review and that ptocedures affected by the ptoposed licensing amendments ate l
identified and altered to be consistent with the amendment requitements.
10.
The Commitment Hanngement Program provides measures fot ensuring that pro-cedures which implement commitments made to segulatoly agencies ate main-tained current.
ATTACHMENT.
page 4
- ' Reason f or Change 1 (Continued) 11.
The specifications program tequires an interfacing document review to iden-tify ptocedures vhich may be affected by a ptoposed specification or speci-fication alterations. The program has ptovisions foi ensuting that altein-tions to the affected ptoredutes is made effective concuttently with the issue of the specification or specification alteration.
12.
The Contiol of ptocedures ptogram requires an interiacing document ieview to identify procedures which are affected by development or alteration of a procedure. The program also has provisions for ensuring that required al-tetations to affected procedutes are made effective concurtently.
13.
The Quality Assutante Audit and surveillance ptogsam ptovides added assur-ance that procedures ate adequate, approptiate to the circumstances and do not contain outdated information.
These attributes are verified during the performance of audits and surveillances.
14.
The Sotpoint Control program tequites an interfacing document reviev to identify procedures which are affected as a result of a setpoint change.
The program contains provisions fot ensuring aflected procedures are altered concurrent with the setpoint change.
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The Document Change hequest program provides measures tot ensuring that an interfacing document leviev be performed to identify procedures which may be aft'ected by changes to confi utation conttol documents.
It contains ptovi-E sions foi assuring that impacted procedures ate updated prior to effectivity and closcout of the Document Change Request.
Additionally, Davis-Besse vill perform an annual sutveillance of randomly selee-ted plant procedures to ensure that the existing programmatic controls are main-taining plant procedures cuttent.
Ef f ect of Change on the Davie-Hesse USAR Chapter 17.2_ Quality Assurance program Description Commitments This change reduces the Quality Assurance program description commitments ptevi-ously accepted by the NRC.
The proposed change is a change to a quality assut-ance program description.
Since the ptoposed change eliminates the biennial reviev of plant procedutos it represents a reduction in commitment.
NRC approval is required prior to implementing the proposed change.
The basis for concluding that this change continues to satisfy the criterla of Hii:itiiFo Appei2TFn and tlie Saf ety AnaljaEissort quidity description commitments prev}ously accepted I)y the NR(fls_ assurance progam as follows:
The requirements of 10CFR50 Appendix B Criterions 5 and 6 are still fully satis-I fled by USAR 17.2.5 and 17.2.6 vhich temains unchanged. The proposed change pro-vides an alternate method for ensuring that procedures remain cuttent and appto-priate for the circumstances.
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