ML20078H446
| ML20078H446 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 11/10/1994 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TAC-M86712, NUDOCS 9411170280 | |
| Download: ML20078H446 (3) | |
Text
ik Pf J.S 1 Orth North Atlantic Energy Service Corporation T
n gy ne,300 (hyg((g Seabrook, Nil 03874
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(603) 474M21, Fax (603) 474 2987 The Northeast Utilitim Sptem Ted C. Feigenbaum NYN 94127 Senior Vice President &
Chief Nuclear Officer November 10,1994 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
References:
(a)
Facility Operating 1 icense No. NP'-86, Docket No. 50-443 (b)
North Atlantic letter NYN-94002, dated.lanuary 14,1994, " Proposed Change to the Nonh Atlantic Operational Quality Assurance Program (TAC No. M86712)"
Subject:
Supplemental Infonnation Regarding Proposed Change to the North Atlantic Operational Quality Assurance Program (TAC No. M86712)
Gentlemen:
The fbilowing supplemental infbrmation is provided to assist in your review of North Atlantic Energy Senice Corporation's (North Atlantic) proposed change to the Operational Quality Assurance Program [ Reference f b)].
The proposed change reduced an existing commitment by deleting the requirement to perfbrm a biennial review of plant procedures. This supplemental information specifically addresses the December 21,1992 intemal guidance provided by the Director of the Disision of Reactor inspection and Licensee Performance to the Regional Directors of Reactor Safety. The Nonh Atlantic implementation methodology for each of the four considerations in the NRC guidance is discussed below.
Consideration: Programmatic controls should specifi :at all applicable plant procedures will be reviewed following an unusual incident, such as an accident. an unexpected transient, significant operator enor, or equipment malfunction and following any modification to a system, as specified by Section 5.2 of ANSI N18.7/ANS 3.2 which is endorsed by RG 1.33.
Enponse: Unusual incidents such as an accident, unexpected transient, significant operator error, or significant equipment malfunction are evaluated as part of the North Atlantic Corrective Action Program. The Operating Experience Manual, which contains the implementing procedures fbr the Correctise Action Program, will be resised to include a requirement fbr a review of the applicable procedures following any unusual incident. 'lhe Design Control Program, which controls the modification of structures, systems and components, contains the rcquirement Ihr the review of the affected plant procedures and the desclopment of revisions concurrent with the development of a sptem modification.
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C/41 1170280 941110 PER ADDCK 05000445 h*
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United States Nuclear Regulatory Commission '
November 10,1994 i
Attcution:
Document Control Desk Page two Consideration: Non-routine procedures (procedures such as emergency operating procedures, off-normal procedures, procedures which implement the emergency plan, and other procedures whose i
usage may be dictated by an event) should be reviewed at least every two years and revised as j
appropriate.
Resoonse: North Atlantic does not intend to include non. routine procedures in the population of procedures that will be excluded from a biennial review. The Emergency Operating Procedures, Abnonnal Operating Procedures and the Emergency Plan Procedures will continue to be reviewed on a biennial basis. This biennial review requirement will be included in the administrative controls fbr these procedures.
Consideration: At least every two years, the Quality Assurance (or other " independent")
organization should audit a representative sample of the routine plant procedures that are used more frequently than every two years. The audit is to ensure the acceptability of the procedures i
and verify that the procedure review and revision program is being implemented effectively. The root cause of significant deficiencies is to be determined and corrected.
Response: North Atlantic Quality Programs will review plant procedures that are used more frequeritly than a normal plant fuel cycle (i.e. power operation, shutdown, refueling ou; age and subsequent startup), on a sampling basis, as part of routine audits and surveillaaces. These audits and surveillances will be used to ensure that existing programmatic controls, such as those specified in the the Design Control Program, Operating Experience Review Program, Corrective l
Action Program and the Proceduri Compliance Policy are effective in maintaining the quality of plant procedures. If concerns are noted the Quality Programs organization has the ability to address the issue and ensure the root cause is detenuined and corrected either through the audit and surveillance response process or the Corrective Action Program.
i Consideration: Routine plant procedures that have not been used for two years should be i
reviewed before use to determine if changes are necessary or desirable.
Itemonse: North Atlantic utilizes a pre-job briefing practice to ensure that personnel are aware of what is to be accomplished and what procedures will be used, prior to beginning a job. In addition, a rigorous Procedure Compliance Policy ensures that personnel know what actions are required if the procedures cannot be implemented as written. The Procedure Compliance Policy requires that thejob be stopped and the procedure be revised or the situation be resolved prior to work continuing. The pre-job brieling will address most procedures that are not used during a i
normal plant fuel cycle. The administrative controls for the procedure system will be revised to require that procedures that are scheduled to be used at intervals longer than a normal fuel cycle, which has e not been revised or reviewed since they were last used, to be discussed during the pre-job briefing.
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5
' United States Nuclear Regulatory Commission November 10,1994 Attention:
Document Control Desk Page three North Atlantic believes that this supplemental information should facilitate the review of the proposed change to the Operational Quality Assurance Program. Should you have any questions regarding this supplemental information or the proposed change please contact Mr. Terry L. Ilarpster, Director of Licensing Services, at (603) 474-9521, extension 2765.
e r
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Ver truly yours, pg,l T d 'C.Weigen-e I
TCF:JMP/act ec:
Mr. Thomas T. Martin Regional Administrator U.S Nuclear Regulatory Commission Region I l
475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate '-4
~
Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Richard Laura NRC Senior Resident inspector P.O. Box 1149 Seabrook, N}l 03874 Mr. George L Iverson, Director New llampshire Office of Emergency Management 107 Pleasant Street Concord, Nil 03301 l
.