ML20078G371

Corrects Mistake in 941014 Telcon Re Util Considering RPS to Be low-risk Significant, as Term Defined by NRC for Graded QA

ML20078G371
Person / Time
Site:	Grand Gulf
Issue date:	11/09/1994
From:	Meisner M ENTERGY OPERATIONS, INC.
To:	Milhoan J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GNRO-94-00132, GNRO-94-132, NUDOCS 9411160017
Download: ML20078G371 (5)

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1 M. J. Meisner l Mr. James L. Milhoan w, U.S. Nuclear Regulatory Commission wmNm= l Mail Station P1-37 Washington, D.C. 20555 November 9,1994 Attention: ' Ddcumint Control Deski

Subject:

Grand Gulf Nuclear Station Docket No. 50-416, License No. NPF-29 Graded QA initiative GNRO-94/00132

Dear Mr. Milhoan:

In your October 14,1994 letter to the Nuclear Energy institute (NEI) concerning the graded QA initiative, you express concern that one plant considered the reactor protection system (RPS) to be

" low-risk significant", as this term is defined by the NRC for graded QA. In discussions with NE!

and your staff, we were surprised to find that you were referring to Grand Gulf.

Normally, we would correct a mistake of this nature with a phone call. In this case, however, we thought it worthwhile to write to you because such mistakes have recurred and, in our opinion, seem characteristic of a lack of appreciation of the technical basis which underlies the graded QA initiative at Grand Gulf, in simple terms, there are two distinct tasks in graded QA: 1) determining the importance of SSCs, and 2) applying quality controls to SSCs based upon that importance in conjunction with an EPRI project Grand Gulf has focused its attention over the last two years on developing an approach and methodology which can be applied to the first of these tasks.

Last Spring, we provided a detailed briefing to your staff on the technical details necessary to determine SSC safety importance (a combined deterministic and probabilistic approach). With respect to the RPS, we explicitly informed the staff that it had been placed in our " safety-significant" category (or, "high risk significant" category, in the NRC's terminology)1f or the very reason you raised - the increased potential for common mode failure should the level of quality assurance be reduced. We were discouraged to find that despite these briefings and written handouts, the staff informed you to the contrary. In retrospect, we should not have been surprised because the focus and interest of the staff in our Spring,1994 meeting appeared to be restricted to determining the level of QA control to be applied to non-safety significant components, rather o than the technical approach to determining safety significance.

e-1 The NRc's use of the term high or low " risk significance

• in graded QA can be quite misleading. Both the RPs and the sLcs (discussed later) are properly termed " low risk significant" systems because they contribute little to plant risk in the Grand Gulf IPE. We confuse matters, however, when we use risk based terminology to encompass deterministic insights. For purposes of graded QA. both the RPs and sLCs are "high risk significant" systems - contradictory to the PRA terminology. What we really mean is that the RPs and sLCs are imoortant to uf.ety. They are important to safety, not from a risk perspective, but from a deterministic judgment by plant experts. Consequently. a more appropriate terminology is high or low " safety significance". (This confusion factor is more than just

a academic semantics As an example, Bill Rr .. visited Grand Gulfin August. Early in the visit he asked a shift supervisor what was I the most nsk-significant system at Grand Gutt The supervisor's response was the reactor protection system (because of its deterministic importance). Mr. Russell properly took us to task for not having sufficiently educated our personnel on the insights from our IPE. Using the NRC's favored graded QA terminology in this circumstance would have hopelessly confused the issue.) g I

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. GNRO 94/00132 Page 2 of 4 Similarly, in a July 21,1994 Senior Management Steering Committee meeting on graded QA the staff claimed that Grand Gulf had categonzed the standby liquid control system (SLCS) as " low risk significance". As with the RPS, our graded QA program had categorized the SLCS as " safety significant" based on the deterministic insights of our expert panel. This conclusion was also shared with the staff when they visited last Spring.

Overall, we have been concerned with the level of the staff's technical understanding associated with the initial graded QA task -i.e., determining the importance of SSCs. We have also noted misunderstandings of technical concepts beyond the mis-classified systems discussed above.

In our view, part of the difficulty in reaching agreement between the industry and NRC on graded QA initiatives has to do with a " cart before the horse" approach. The staffs primary attention has been on the QA controls to be applied to " low risk significant" components, rather than how we determine which SSCs are important. We believe that until the industry and staff understand and agree on the technical basis for determining which components are important to safety, we will continue to look with suspicion on any attempt to reduce the level of quality assurance for the less important components.

Si erely, s

L_ ' ^

. J. M 'ner MJM/be cc: see next page i

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GNRO 94/00132 Page 3 of 4 cc: Ms. S. C. Black (NRC)

Mr. A. Heymer(NEI)

Mr. H. W. Keiser Mr. R. B. McGehee Mr. R. N. Ng (NEI)

Mr. N. S. Reynolds Mr. W. T. Russell (NRC)

Mr. J. E. Tedrow Mr. H. L. Thomas Mr. Stewart D. Ebneter Regional Administrator U.S. Nuclear Regulatory Commission Region li 101 Marietta St., N.W., Suite 2900 Atlanta, Georgia 30323 Mr. P. W. O'Connor, Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Dr. Eddie F, Thompson State Health Officer State Board of Maalth P. O. Box 1700 Jackson, MS 39205

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. GNRO 94/00132 Page 4 of 4 bec: . Mr. D. G. Bost Mr. C. A. Bottemiller Ms. M. T. Crayton Mr. L. F. Dale Mr. L. F. Daughtery Mr. W. C. Deck Mr. J. G. Dewease Mr. M. A. Dietrich Mr. J. L. Ensley (ESl)

Mr. J. J. Fisicaro (RB)

Mr. J. O. Fowler Mr. C. C. Hayes, Jr.

Mr. L. W. Laughlin (W3)

Mr. M. J. Meisner Mr. D. C. Mims (ANO)

Mr. D. L. Pace Mr. R. L. Patterson Mr. J. C. Roberts Mr. F. W. Titus File (LCTS)

File (RPTS)

File (Hard Copy)

File (NS&RA)

File (Central) ( 4 )

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EDO Principal Correspondence Control t

FROM: DUE: / / EDO CONTROL: 0010630 DOC DT: 11/09/94 FINAL REPLY: '

M. J. Meisner Entergy Operations, Inc.

TO:

James Milhoan FOR SIGNATURE OF : ** GRN ** CRC NO:

DESC: ROUTING:

GRADED QA INITIATIVE AT GRAND GULF Taylor Milhoan Thompson Blaha DATE: 11/14/94 ASSIGNED TO: CONTACT:

NRR Russell .

SPECIAL INSTRUCTIONS OR REMARKS:

For appropriate action.

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