ML20082T461
| ML20082T461 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 09/09/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109180264 | |
| Download: ML20082T461 (8) | |
Text
a CENTE*NVI M. Tcy Donald C. Shelton 300 Madison Avenue Vc Presdent Nuclear Toledo, OH 436520001 Davis besse (419)249 2 3 )
Docket Number 50-346 License Number NPF-3 Serial Number 1-962 September 9, 1991 United States Nu11 ear Regulatory Commission Document Control Desk Vashington, D.C. 20555 Subj ect :
Change in Quality Assurance Program Biennial Procedure Reviev Gentlemen:
The purpose of this letter is to provide additional information concerning Toledo Edison's request dated July 31, 1991, for change in the biennial procedure review. This additional information was requested during discussions with Mr. Fred Maura of your staff on August 23, 1991.
The additional information to be added to USAR Section 17.2 is indicated by the insert boxes (see attached).
As discussed in Toledo Edison's July 31, 1991 J e t te:, shim c;r e, as indicated in the attached 10CFR50.54(a) review, tias hen luen.ified as a reduction to the commitments identified in the l' CAR
...at ter 17.2, Quality Assurance Prtd.am for Stat.on speration.
Alti. ogh this change has been identified as e Laduction in cor..mitment, the Quality Assurance Program continnes to satisfy the criteria of 10CFR50, Appendix B.
If you have any questions concerning this matter, please contact Mr. R. V. Schrauder, Manager - Nuclear Licer sing at (419) 249-2366.
Very truly yours,
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ttachment cc:
P. M. Byron, NRC Region III, DB-1 Senior Resident II.rpector A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC/NRR DB-1 Senior Project Manager Utility Radiological Safety Board
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'i TABLE OF CONTENTS l
BIENNIAL PROCEDURE REVIEW PROCESS REVISION
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f Attschment, page 1 Proposed execp'.lon to ANS/ ANSI 3.2-1982 Section 5.2.15 i
-Attachment, page 4 10CFR50.54 reviev 5
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ATTAcilMENT.
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.17.2.5 INSTRUCTIO
N. PROCEDURE
S. AND DRAWINGS 17.2.3.1 General Activities af f ecting quality are prescribed by clear and complete docu.
mented procedures and instructions of a type appropriate to the circum.
stances,.and are-accomplished in accordance with these documents.
These 5
documents include the necessary operating limits and tolerances on materi-ale, equipment, processes and procedures for all activities from design through operation.
Also included are qualitative or quantitative accep-tance criteria to ensure that important operations have been satisfactorily completed.
Each department /section and group s1pport organization have developed 8
procedures that define _and control how they function.
9 These procedures have been developed to contain sufficient detail fer a 5
qualified individual to perform the required function without direct 5
supervision.
5 17.7.5.2 Review and Approval Procedures are reviewed by knowledgeab'. personnel other than the preparer and are approved by authorized individuals prior to implementation.
The procedures are reviewed to ensure their adequacy for the intended purpose, and that all necessary technical and quality requirements have been 5
included.
These procedures and changes thereto are reviewed to verify that all commitments (HRC. NQAH, USAR. Technical Specifications, etc.)
-affected by the procedure-are satisfied, and to ensure proper interface with other procedures or instructions that may be affected.
(SEE INSERT Procedures are approved by Department /Section heads responfible for the 8
interface or functions to be performed as described in each procedure, In 5
addition, the Director, Quality Assurance reviews and approves Pelected 9
procedures which implement the Nuclear Quality Assurance Program.
Provisions 9
have beer astablished to identify procedures requiring Quality Assurance 5
Department and Station _ Review Board (SRB) review and approval.
Changes to 8
procedures are reviewed and approved by the same organization that performed 8
the original review and approval unless designated to another qualified 8
organization.
5 Changes to the station administrative, work, operational or test procedures 9
are reviewed pursuant to the requirements of 10CFR50.59 to determine 10 if they involve an unreviewed safety questicn.
5 The summary of all safety evaluations -1re forwarded to the Licensing Manager _
8 for transmittal to the NRC in accordance with 10CFR50.59(b).
1 The review and approval of procedures required by the Technical Specifi-
-cations are petformed in accordance with Section 6 of the Technical i
specification.
t 1/.2.5.3 Training 1
User personnel are trained in the provisions of the procedures governing their activities prior to implementation.
17.2-24 REV 10 1/90
ATTACllMENT, Page 2 INSERT Davis-Besse has existing programmatic controls that continually identify changes to and update procedures. These controls are discussed in USAR Table 17.2-1, Page 17.2-54a.
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D-8 Table 17.2-1 (Continued)
_APPLICABI.E MRC PEGUIATORT GUIDES, ANSI STKCAPl25 AND INDUST *T CODES MRC PIGUIATORT GUI.2, INDUSTRY CODES ANSI ST;J!DAPl15 TCLEDO EDISON POSITION 4
ANSI /JaS 3.2-1982 F.
Section 5.2.15 requires that " Plant procedures shall be reviewed by an indi-
"Mainistrative controls vidual knowledgeable in the area affected by the procedure no less frequent-and Quality Assurance For ly than every two years to deterr.ine if changes are necessary or desirable.
Muclear Power Plant
- Itis requirement for routine follo w rev'ew, can be accomplished in several ways, including (but not necessarily limited to): documented ste W -step use of t*te proc Mure (such as occurs when the procedure has a step-by-step checkoff associated with it), or detailed s-rutiny of the procedure as part of a docu-mented training program, drill, simulator exercise, er other such activity. A revision of a procedure constitutes a procedure review.'
In lieu of these re-quirements, Davis-Besse has many existing programmatic centrols, which identify the necesrity for procedure alterations to ensure thet procedures are agropri-ate for the ciretastance and are maintained current.4 Additionally, Davis-Besse performs an annual quality Assurance -surveillance et randomly selected plant
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procedures. The surveillance will provide adied assurance thet existing pro-grammatic controls provide for tin-sly revis).on of proceeres.
_TJd 5 E R T Changes to procedures are identified chrough the following processes: plant modification: conditiers adverse to quality reporting and management corrective action; test control; conduct of operations and maintenance control; control of Updated Safety Analysis Peport (USAR) changes vendor manual contrel; operating experience assessment: Operating License Amendment; comualtment management; design specification changes control of procedu.e changes: Quality Assursace audits and surveillance; setpoint control and document change re7aest.
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.H 17.2-54a
ATTACHMENT, page 4 10 CFR 50.54 Reviev July 18, 1991 PROPOSED REPLACEMENT OF BIENNIAL REVIEV 0F PLANT PROCEDURES VITH PROGRAMMATIC CONTROLS AND YEARLL SURVElLLANCE.
Change Number 1 Table 17.2-1, add Item 4, Position 1.F. page 17.2-54a.
Description of Change P.
Section 5.2.15 requires that " Plant procedures shall be revieved by an indi-vidual knowled eable in the area affected by the procedure no less frequent-F ly than every two years to determine if changes are necessary or desirable.
This requirement for routine follow-up reviev, can be accomplished in sever-al ways, including (but not necessarily 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 procedure as part of a documented training program, drill, simulator exercise, or other such ac'. vity.
A revision of a procedure constitutes a procedure reviev."
In lieu of these requirements, Davis-Besse has many existing programmatic controls, which identify the necessity for proc dure alterations to ensure that procedures are appropriate for the c.ircumstance and are maintained current.,?titionally, Davis-Besse perfctms r.n annual Quality Assurance surveillance of randomly selected plant pron dures.
The surveillance vill provide added assurance that existing progran.matic controls provide for timely revision of procedures.
Reason for Change 1 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 procedures is a dynamic process.
The need for procedure changes may be identified at various times for various reasons.
Changes are evaluated for implementation at the time of identification.
Davis-Desse han developed many programs which enhance the procedure alteration process which provides assurance that procedures are appropriate for the circumstancas and remain current /up-to-date. These programmatic controls address the intent of the static biennial re-view process and from both a technical and a practical perspective, provides greater assurance that procedures vill be maintained current.
The biennial re-viev is redundant to the established programmatic controls and is no longer con-sidered necessary. These existing controls are described below:
1.
The Plant Modification Program requires an interfacing document review and altr-ation of procedures affected by the modification be performed. The l
Progr~n provides additional measures for assuring that all procedures af fec-l ted by the modification are updated to reflect the :hanges, Prior to return-ing the modified system to service.
2.
The Potential Condition Adverse to Quality Reporting and Hanagement Cotrec-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-l quacles and require a proceduce(s) alteration to preclude recurrence.
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l A1TACHMENT, Page 5 Reason ior Change 1 (Continued) 3.
The Test Control Pr ogr am r equites that test personnel are qualified to per-form the test procedute, and the use at approved and controlled test proce-dutes.
Deficiencies encountered during the conduct of test procedures nre documented and evaluated to determine if test ptocedure alteration is need-ed.
Resolution is provided prior to final approval of the test results.
4.
The Conduct of Operations and Maintenance Control Programs require the use of approved and controlled procedutes by qualified personnel, and strict ad-herence to procedures. The ptogram also encoutages user feedback on the adequacy of procedures and prompt identification and initiation of necessary ptocedure alterations and actions to be taken when procedures cannot be petfotmed as written.
5.
The Prepatation and conttol of Updated Safety Analysis Report (USAR) Changes Program requires that when changes are being made to the USAR an interfacing document review of procedures be performed.
Affected procedurca are altered ptfor to issuing the USAR change.
6.
The Revision, Revies and Control of Quality Assurance Manuals requires that when changes are being made to the Quality Assutance Manuals an interfncing document review of procedures be periotmed.
Aftected ptocedure.s are altered ptlor to issuing the manual tevision.
7, The Vendor Manual Contrel Program provides for the procurement, receipt, reviev, approval, change, control and distribution of vendor manuals and other vendor technical information.
The program requires approval of vendor manuals or vendor correspondence prior to use.
Subsequent revisions f.
changes to vendor manuals,nd other vendor tec hnical information are also approved and procedutes ate reviewed for impact and approval provisions are made to ensute that aflected procedures are current.
I 8.
The Operating Experience Assessment Program provides measures foc ensuring that NRC Notices. Significant Operating Experience Reoorts, Significant Event Reports, Significant By other Notifications. Operating Plant Expett-ence Reports, Operations and Mainter.ance Reminders, Preliminary Safety Con-cerns and Transient Assessment Ptogram Reports are evaluated to determine if programmatic or technical inadequacies exist at Davis-Besse. The program includes provisions for ensuring appropriate corrective action is taken vhen an inadequacy is identified. These evaluations can have an impact on proce-dures and require pr ocedut e alterations to enable closure of the applicable report.
9.
The Operating License Amendments Program requires an interf acing clocument teview and that procedures affected by the proposed licensing amendments are identified and altered to be consistent with the amendment requirements.
10.
The Commit nent Management Program provides measures for ensuring that pro-cedutes which implement commitments made to regulatory agencies are main-tained current.
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ATTACl! MENT,
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. Reason for Change 1 (Continued) 11.- The Specifications Program requires an interfacing document review to iden-tify procedures which may be affected by a proposed specification or speci~
fication alterations. The program has provisions for ensuring that altera-tio..s to the affected procedures is made effective concurrently with the issue of the specification or specification alteration.
- 12. The Control of Procedures Program requires an interfacing document reviev to identify procedures which are affected by development or alteration of a procedure. The program also has provisions for ensuring that required al-terations to affected procedures are made effective concurrently.
13.
The Quality Assurance Audit and Surveillance Program provides added assur-ance that procedures are adequate, appropriate to the circumstances and do not contain outdated information.
These attribut9s are verified during the performance of audits and surveillances.
14.
The Setpoint control Program requires an laterfacing document review to identify procedures which are affected as a result of a setpoint change.
-The program contains provisions for ensuring affected procedures are altered cor. current with the sotpoint change.
15.
The Document Change Request Program provides measures for ensuring that an interfacing document review be performed to identify procedures which may be af fected by changes to configuration control doc':ments.
It contains provi-sions for assuring that impacted procedures are updated prior to effectivity and closeout of the Document Change Request.
Additionally, Davis-Besse vill perform an annual surveillance of randomly selec-ted plant procedures to ensure that the existing programmatic controls are main-taining plant procedures current.
I Rffect-of Change on the Davis-Besse USAR Chapter 17.2 Quality Assurance Program Description Commitments
-This change reduces the Quality Assurance Ptogram description commitments previ-ously accepted by the NRC.
The proposed change is a change to a quality assur-ance program description.
Since the proposed change eliminates the biennial review of plant procedures 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 criteria of 10CFhb0 Appendix B cnd the Safety Analysis Report quality assurance program
-description commitments previously accepted by the NRC is as follows:
i The requirements of 10CFR50 Appendix B Criterions 5 and 6 are still fully satis-fled by.USAR 17.2.5 and 17.2.6 which remains unchanged. The proposed change pro-vides an alternate method for ensuring that procedures remain current and appro-priate for the circumstances.
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