ML20091C850
| ML20091C850 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 08/02/1991 |
| From: | Burski R ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| W3F1-91-0383, W3F1-91-383, NUDOCS 9108070247 | |
| Download: ML20091C850 (10) | |
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August 2. 1991 U.S. Nuclear llegulatory Comniission ATTN: Docunmut Control Desk Washington, D.C. "0555 Subject :
Waterford 3 SI:S Docket No. 50-3h2 License No. NPF-38 Quality Assurance Program Gentlemen:
This letter constitutes a request for change to the waterford 3 S.1:.S. Quality Assurance Program as described in our updated (December th,1990) Final Safety Aimlysis Iteport, Chapter 17, Table 17.2.1 Item (1). Currently the UFSAlt, by endorsing Regulatory Guide 1.33 Hovision 2,1978, refers to ANSI N18.7 which requires the biennial review of plant Procedures. We hereby request an exception to the biennial review commitment based on the ju.uification attached.
The proposed change establishes an alternative method of mahitalning procedures current in accordance with 10CFR50, Appendix B, in lieu of blennial reviews imposed by ANSI N18.7, Section 5.2.15, and stipulated in Waterford 3 S.E.S.
Administrative Plant Procedure UNT-001-003.
The alternativo inethod implements a dyluuale process for assessing procedural adequacy by initiating procedure review, change or revision, based on new or revised source material potentially affecting the intent of procedures. The change is considered necessary to promote the quality of procedure review and revision controls through the effective use of resources and does not conshler age as a requirement for procedure review.
The proposed change inchides an additional commitment to perform a bleimial Quality Assurance audit using a representative sampling process. This audit will provide verification that the inputs / feedbacks outlined in the enclosed justification are in compliance with existing programmatic controls used to maintain procedures current. contains the proposed change to the UFSAR. Attachment 2 contains the justification for change.
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W31'l 03 S 3 Quality Ansurance l'rognun l'nge 2 Au r,u s t 2,
1911 While initfully the change inny appent to be a lessoning of conunittnent, the attached justifiention supports tho alternative tuethod of innintaining procettureu current, as equivalent to or better than that prescribed by ANSI N18.7-1976. We will asstune that this propose <1 change is neceptable 60 days from tini date of this letter unless infortned otherwise us provided by 10CI'll 50.51.n.3(iv). U N T-001 -
003 will be revised iniinedintely thereaf ter und the elmnge will be incorporated into the UFSAlt by our normal UI' Salt submittal, if you have any questions concerning this luformation, please contact 18.1.. ('aropino ut (501) 739-6G92.
Very truly yours,
()r]{9f n.A It i'll /l't.C / ssf Attachments cc:
It.D. Martin, NitC 1(egion IV D.L. Wigginton, NiiC-Nitit 11.11. McGehee N.S. lleynolds NitC Ilesident inspectors Of fice
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Atttichttiotit 1 Affected FSAll Pago
Attachment I to W3F1-91-03S3 WSES-ESA R-UNIT-3 Table 17.2-1 (Sheet 5 of 9)
Comment Document 7.
ANSI N18.7, Section 5.2.15 states, 4.
Regulatory Guide 1.33, Rev. 2,
[ Plant procedures shall be reviewed February 1978 (continued.. )
by an individual knowledgeable in the area affected by the procedure no less frequently than every two years.1 l
Waterford 3 has programmatic control requirements in place that initiate precedure reviews upon identification of nede or revised source material that has a potential to affect the intent of the urocedure.
A biennial audit is performed by the l
Quality Assurance Department to verify compliance with existing programmatic controls used to maintain procedures current.
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. to W31?l-91-0383 page 1 of 5 j
1 JUSTlFICATION FOlt pHOpOSED CllANGE 4
ANSI N18.7, Section 5.2.15, prescribes the requiretaent ta perforta biennial
- review of plant procedures. The Intent is to ensure that existing procedures are periodically reviewed and revised as necessary to address the follmving elements whleh tauny have changed or come into existence.
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Technleal information Industry experience
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plant behavior 1.
Feedback based on une i
Programmatic controls have been effected at Waterford 3 whleh are equivalent to or more effective in meeting this requirement from a techuleul and practical i
standpoint than the static blennial review process. These controls assess the prwedural Impact of the above listed elements and other elements prew'ribed by ANSI N18.7, utilizing a dynamle process, and necount for the identification of the vast majority of revisions / changes to our procedures, performing biennial reviews in addition to these controls is considered an overall weakness in our program by allowing for.the postponement of required netton and Imposing a significant drain on plant resources withotit a comn.ensurate improvement in plant safety.
'-Thoreforo, Waterford 3 proposes that' the static bles.nlal review connaltment be replaced with an alternntivo commitment to review procedures upon identifleation of now or' rovised source material potentially affecting the intent of the procedu ro. Similar changes have been approved by the NRC for Virgil C.
Sunuaer Nuclear Station and Donald C. Cook Nuclear Planta, Units 1 and 2.
It is our beller that the dynamic process is necessary to maintahi procedures in an
- accurato and useful condition and la more responsive than the statie biennial review process specified by ANSI N18.7.
Listed below are procedurally controlled mechanisms that have been established at Waterford 3 which assesa procedural impact and determine the need for review or
- revision, 1) plant Design / Modification program The plant design / modification program requires an interface review of all modifications by groups which are potentially affected by the modification. This interfaco review requires that all procedures potentially affected by the modiffeation be identiflod and changes or revisions made prior to closure of the modifleution packago.
in addition, when a significant design change is necessary c
because of an incorrect design, the design process and verification procedures are reviewed and modified as necessary.
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Attnehinent 2 to W3F1-91-0383 I
pago 2 of 5 2)
Corrective Action program it is the responsibility of all Waterford 3 personnel to identify und document conditions adverso to quality, industrial sufoty, and plant reliability. The correctivo action program includes i
Quality Noticos (QN's), Security lucident Hoports (SlH's),
potential Heportable Events (pH10's), Licenseo Event Reports l
(1.EH's), Significant occurrenen Heports (SOH's), NHC i
inspettlon Reports (lH's), Nonconformanco Condition Identifientions (NC1's), and Outside Agency Heports.
Correctivo action for all the abovo listed items requires root cause identifiention. Shottid inadeqtuito procedures be Identified, they are promptly changed or revised.
1 3)
Off-Normal Occurreneo Hoot cause investigation threshold criterin has been
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ostablished to further investigation event' which occur at tho station and are considered to be outsido of normal expected operation including severo or unusual pinut transients, sufoty l'
system malfunction or.lmproper operation, Inajor equipment damage, events involving nuclear nnfety or plant reliability, j
deficienclos in design, analysis, operation, mnIntonanco procedures or training that enuso a significant event, fuel handling or storngo events, excessive radiation exposuro or severo personnel injury, and excessivo dischargo of radioactivity. Correctivo netion for these events requires approprinto procedures to be reviewod and necessary changes or revisions performed.
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User Feedback und proceduro Compliance All Waterford 3 personnel are required to notify supervision or management when procedural guidaneo ennnot or should not be followed. The proceduro la then ovaluated, and if required changed prior to the commencement of work. Individuals nasigned to a task are required to review the proceduro in its entirety prior to starting work.
i plant Operation Advisory Groups in the arens of Administrativo Services, Security, Technical Servlees, Operations, and Maintenanco have been established and are responsiblo for routinely identifying, reviewing and evaluating concerns or areas that need improvement or enhancement, in addition these groups provido the vehielo to receivo feedback from the work forco for hnprovements in all nrons. The abovo listed activities may result in formal recommendations to review or chango procedures.
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. to W3F1-Dl-03h3 page 3 of 5 5)
Operating 1:xperience Review Waterford 3 is an active participant in the Significant 1: vent Evaluation and luformation Network (SEl'-IN) program.
Operations Assessment and Information 1)issemination Group (QALlD) provides the necessary lustructions for evaluating material f rom the SEl:-IN program (e.g., Significant 1: vent Heports (SI:H's), Signifleant Operating 1:xperience Reports (Sol:H's), Operations and Maintenance Heminders (OkMH's),
Combustion 1:ngineering information llulletins (CI:lli's)) and for disseminating such luformation to plant guirsonnel. This evaluation includes the review of appilcable procedures.
Hecommenclations are made to resolve underlying problems and implementation may include changes to plant procedures.
Internal and external effectiveness reviews are performed to ensure the program is maintained.
Administrative procedures governing the Vendor 1:quipment Techuleal Information program (VETip) 1;rovide control of incoming equipment technical information (1:TI) whether it arrives directly from the vendor or from other industry or regulatory sources (i.e., Nuclear Network, NpHDS SEl:-IN, NHC llulletins, etc.) so it receiven the appropriate engineering / technical review evaluation, and distribution for the following:
prompt warnings to key personnel timely incorporation into mahitenance or operating procedures, equipment data / purchasing records and training programs future procedure review and revision cycles 6)
Licensed Document Change /50.50 Evaluation Changes to licensing doctunents such as the Techuleal Speellications and FSAR require an evaluation for impact on proceduces an<l may result in procedure changes as required.
All proposed changes to the facility or procedures and any new tests or experiments that have a potential to affect, either directly or indirectly, nuclear safety are reviewed for impact on procedures.
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Commitments Management System (CMS)
The CMS program at Waterford 3 is a comprehensive system, governed by administrative controls, utillred to humru that commitments / requirements and recommendations / good practices are tracked, included, and maintained in approprian implementing procedures. Correspondence to and from regulatory agencies (e.g., Generle 1,etters, NHC Information Notices, NHC Information llulletins, Security lucident Reports, NRC Inspection Heports, Heports to the NHC, l
Attnehment 2 to W3F1-01-0383 pago 4 of fi l'edend lleglster, Envlivnmental piutection Agency and j
o Waterford 3 responson to the forgoing) is reviewed for t
incluulon in the CMS system. Action items concerning procedures are tracked until the piveedutv la revised or changed.
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passive commitments (on going requirements) nro tied to the procedures which implement the stated requiremont. Passivo commitments are primarily those requitements which niv ivquired to bo addressed by prveeduro. Passivo commitments uro extrneted from soureo documents including the generic l
correspondenco listed above, CFil, lleensing documents (1.o.,
.Technlen) Speelflentions, Emergency Plan, Security Plan, FSAlt, and all endorsements to documents therein). Any chango to sourco criterin is updated and evnlunted ngninst the
-Implementing procedures. The need for ehnnge or revision is then formally transmitted to thu approprinto department / group.
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Plant. Tronding Progenm Events Annlyuls and lleporting, Operations, Maintenanco, l
pinnt Engineering, lludiation protection, Fire Proteellon, and i
plant System Engineering are groups whleh currently implement trending programs. The trending process includes the collection of trend data whleh la indleutive of equipment and personnel performanco, evaluation of that data, and identifiention of follow-up nettons necessary to improve equipment and/or personnel performance. Tronding follow-up i
i netton for adverso trends may result in proceduro changes und improvements.
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' Operator lletpintifiention Training bleensed opetutor training, a documented training program makes frequent use of procedures, llosolution of noted discrepaneles would result in proceduro revisions.
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Quality AssurancellSEU s
Tho Quality Assuranco Program includes a review of procedures as part of its audit und surveillanco process whleh is based on a two year cycle.
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The Independent Safety Engineering Group conducts reviews, surveillance and nsnessments of phtnt operating and maintenanco netivities in order to develop and present recommendations to management for resolution (e.g., revised procedures, equipment modifiention, maintonnneo netivities, operating netivities or any other monns of improving safety).
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Attnehment 2 to W31'l 01 0383 i
pago 5 of 5 a
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Security /l:mergency planning i
The security program and its implementing procedures are
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currently cov; owed annually in necordance with 10CFit 73.40 and 10CFil 73.55. The etnorgency preparedness progriun and i
its implementing procedures are reviewed aiutuntly in f
accordnuno with the Emergency plan. These periodle reviews nre not affected by the proposed UFSAlt chinigo and will bo continued.
in addition, Waterford 3 commits to perform a bleiniint Quality Assuranco audit to
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provhle verlflention ilmt the oxluting programs and netivities listed above are in compliance therefore, maintaining procedures curront. This audit will provido i'
udditional strength by ensurhig the input / feedback is being addroused vs.
ensuring that a document reflects a revision date within a speelfled timo frame.
CONet,11SION Our Quality Assurance Progrrun in conformanco with ANSI N18.7-1970, requires that plant procedures be reviewed no less frequently than overy two yours. As discussed, we have established additional procedurally controlled mechanisms that contain their own revision control elemor.ts when affected by changes in soureo material. Wo believe that these additional controls coupled with a blonnial Quality Assuranco audit of the programs and activities used to maintain our proceduros current, provides equivalent or better compliance with the intent of ANSI N18.7-1970. We further bellove that tho minor changes to our i
administrative controls necessary to implement the proposed change will enhanco both the technical and practical aspects of our proceduro review / revision control process by adequately addressing an identified neod or concern in a timely fashion.
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