ML20101T096
| ML20101T096 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 07/14/1992 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 2066, NUDOCS 9207200261 | |
| Download: ML20101T096 (7) | |
Text
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poneW C. Shelten 300 W A m gpg,w foiedo, OH 436524101 gg (419)249 2300 Docket Number 50-346-License Number NPP-3 Serial Number 2066 July 14, 1992=
1 United States Nuclear Regulatory Commission Document Control Desk Vashington, D. C.
20555
' Subj ec t :
Change in responsibilities of the Engineering Assurance Unit Gentlemen.
In accordance with 10 CFR 50.54(a)(3), Tolcdo Edison Company hereby submits its pla'ns regarding a change in the Engineering Assurance (EA)
Unit's responsibilities at the Davis-Besse Nuclear Power Station,
' Unit 1.
It.is proposed that the day-to-day, in-line quality review of
. specification and modification packages be eliminated.
These changes, as' indicated in the attached 10 CFR 50.54(a) review, have been identified as a reduction to the commitments identified in USAR.Chaptor_17.2, Quality Assurance Program for Station Operation.
'Although these changes have been identified as a reduction in commitment, the'0uality Assurance Program continues to satisfy the criteria of 10 CFR 50, Appendix B.
If you have any questions regarding this proposal,. please contact Hr. Robert V. Schrauder, Manager - Nuclear Licensing,'at (419).249 2366.
Very t y yours, j
-JMH/dle A.=B.' Davis, Regional Administrator, NRC Region III
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i J.!B. Hopkins, NRC Senior Project Manager V. Levis, DB-1 NRC Senior Resident Inspector g
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TABLE OF CONTENTS i
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ELIMINATION OF ENGINEERING ASSURANCE l
IN-LINE REVIEW OF TECHNICAL DOCUMENTS l
"O Attachment, page 1 Davis-Besse Unit 1 USAR Section 17.2, page 17.2-8 r
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l Attachment, page 2-Proposed revision to Engineering Assurance's responsibilities as described on USAR page'17.2-8 Attachment, page 3 Proposed revision to design package review as described on USAR page 17.2-21 i
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Attachment,'page 4 10 CFR 50.54 reviev t
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Att chm:nt Pene 1 D-B l9 DIRECTOR - DB ENGINEERING Th2 Director DB Engineering reports directly to the Vice President -
14 Nuclear, and is responsible for all engineering activity in support of d: sign control, plant modifications, and system performance requirements i
f:r the Davis-Besse Nuclear Power Station.
HANAGER - ENGINEERING ASSURANCE AND SERVICES Insed A Th] Manager - Engineering Assurance and Services reports directly to the Director - DB Engineering and is responsible for managing 4.he-independent- +'
-qulity-swiew.-of-procu r+me nt-doc umen t e engineering-spectil u tten:, and 14
-plat ulticatier.--on6 2"&ina 4*Partment self susta:asat ectivit!::-
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-swiew-sad-evalution-es-plant-e hes4et ry-and-r ad i : : W i+t-ey--inuetr
-easinoering--esppor4-eerv4see-aweh-se-design p ecee r--oontcelv-budget-cdm4al++eeti:n, p ::edurement-eel-end-edminisuat4en,-enginess4ag-trainingr-
- nd ::nder-deeument-preeeeeing.
HANAGER - NUCLEAR ENGINEERING l10 The Manager - Nuclear Engineering reports to the Director - DB Engineering 9
cnd is responsible for managing and coordinating u.partment function r0lating to reliability and risk assessment, nuclear reactor analysis, nuclear safety analysis, simulator engineering, reactor engineering, fuel performance and design, reactor refueling, Lore physics testing, and 14 installation, improvements and maintenance of computer monitoring and computer aided engineering systems.
HANAGER - DESIGN ENGINEERING r
Th? Hanager - Design Engineering reports to the Director - DB Engineering and is r:sponsible: for managing Davis-Besse procurement and modification engineering, and associated safety evaluations to assure safe designs and continued 14 ccnformance to design requirements. This includes the maintenance of design cngineering drawings, specifications, and calculations. Additional r;sponsibilities include engineering support to address non-routine technical issues related to the operation and maintenance of Davis-Besse.
HANAGER - SYSTEMS CNGINEERING l9 Th? Hansger - System Engineering reports to the Director - DB Engineering l9 cnd is responsible for minimiring Davis-Besse forced outage and lost 1
c:pacity by providing systems engineering services to ensure proper installation operation, preventive maintenance, testing, and problem r: solution for optimum system performance and reliability. Additional 14 r;sponsiblities include the formulation, inplementation, and periodic assessment-of the effectiveness of the fire protection program.
MANAGER -PERTORMANCE ENGINEERING l9 The Hanager - Performance Engineering reports to the Director - DB Engineering l9 and is responsible for managing the activities of the Performance l14 Engineering Section to provide direct day-to-day engineering support 8
in the areas of plant thermal performance monitoring, inservice inspection 5
17.2-8 PIV 14 7/91 g
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. e; 17.2.1.41 -Toledo Edison Nuclear Group MANAGER - ENGINEERING ASSURANCE AND SEPSICES Insert A e.. independent-assessments of Engineering activities and products, review and evaluation of plant chemistry and radiochemistry issues,
' engineering training coordination, and engineering support services such as design; process-control and vendor document processing, e
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" b'e' performed under the most adverse design conditions as determined by analy s is ~.
When alternate 1 calculations are performed to verify the correctness of the original calculations, they include provisions for verifying the
. appropriateness of assumptions.- input data, and code-or other calculation 5
method used. l The alternate method when used is required to. provide results which are consistent with~the original calculation or analysis.
-17.2.3.5~ Design Package Review 5
. Prior to reinse, the completed design package is reviewed by Nuclear 8
Group Departments af fected by-the design.- All review consnents are document--
ed and reeolved,-and in addition, analyzed for potential impact on safety.
5 evaluations and design verifications..
Nuclear Safety Related JQ) design 14 M age development is also monitored on a day to day basis by Engineer e to ensure the adequacy of engineering documents released,fer
-l9 Assur implementa Selected design modi hations, documented by one or e design packages, are l9' subjected to design evalua
- under the dire n of the Manager - Engineering 14-Assurance and Services to assest e effe eness of the design process and the l9l10 technical adequacy of. design product esign evaluations are conducted by Engineering Assurance personnel pplement a necessary.by engineering-department personnel havin echnical expertise, the areas to be evaluated.
Participating enginee g department personnel will n have responsibility 9
for the design cts to be evaluated, and their select is approved by the Manager ngineering Assurance-and Services.
In addition orrecting l14 identi deficiencies..significant or. recurring deficiencies-are pT ssed
.9 ccordance with=Eection 17.2.16.
j-5 l'7. 2. 4
' PROCUREMENT DOCUMENT CONTROL Q
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- 7.2;4.'1 Generali The. procurement of nu terials, components, equipment, consumables, spare 5
and_ replacement parts ' services, etc., necessary.for plant operation, refueling, maintenance, and. modification are controlled in accordance with approved procedures. These procedures specify measures:that-describe the-
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~ process for the preparation and control of procuremrvt documents, control-l8 e
of-supplier and contractor performance, source evalution and selection.
source verification,; receiving inspection and testing, and' item or service 5
? acceptance. The requirements - of ANSI N45.2.13-and ANSI N45.2.2 are
-incorporated into their procedures whenever the requirements are applicable.
10 Expe'ditious procurement activities are defined in procedures to support Lunanticipated requirements. These procedures contain provisions for material traceability and controls to prevent the declaration of operability of the 5
system until such time that the: activity and documentation' requirements specified in-the approved procurement document have been completed or l8
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evaluated by the Engineering Department for operability.
The-procurement of spare or replacement parts for structures, systems and 5
components within the scope of the Nuclear Quality Assurance Program are subject-to requirements-equal =tu'or greater than the original requirements.
17.2-21 REV 14 7/91 w
- Attachb nti s.
,Paga 4.
t ' z.,:10CFR50.54 REVIEV JULY:10, 1992.
PROPOSED ELIFINATION OF THE ENGINEERING ASSUPANCE DAY-TO-DAY (IN-LINE) OUALITY
= REVIEV 0F TECHNICAL DOCUMENTS (SPECIFICATIONS AND MODIFICATIONS)
CHANGE NUMBER'i
- Paragrr.ph 17.2.1 ORGANIZATION, page 17.2-8, subparagraph entitled MANAGER ~
(
_ ENGINEERING ASSURANCE ~AND SERVICES U
Description-Of Change
-1.- Change text from -
...~ responsible:for managing the independent quality review of procurement documents, engineering specifications, nd plant mcdifications, engineering W went self assessment activities, review and evaluation of plant
,5 and radiochemistry issues, engineering support services such'as icess control, budget administration, procedure control di
- tion,= engineering training, and' vendor document processing."
m e - asible for managing independent assessments of Engineering
,cies.and products, review and evaluation of plant chettistry and radiochemistry issues, engineering training coordination, and engineering support services such as design process control _and vendor document processing.
CHANGE NUMBER 2 Paragraph 17.2.3.5-Design Package Reviev, page 17.2-21 Description of' change Delete.allatext-after the second sentence of the first paragraph.
Beginning with " Nuclear Safety-Related...
Reason for Changes 1-and 2-The current responsibilities forLperforming in-line quality reviews of
-specifications-and modifications were established under Davis-Besse Course of Action, Revision 6 dated January 3, 1986 (Serial Number 1231). These
- responsibilities were subsequently transferred-from the Quality Assurance Department to'the Engineering Department-in accordance with a' letter from-Mr. D. C. Shelton to the NRC dated October 21, 1988-(Serial Number 1604).
?The commitment for doing an in-line review of-procurement documents was changed
'in.accordance with a letter from Mr. D. C. Shelton to the NRC dated May 28, 1991
.(Serial Number 1-950) vith NRC acceptance in June of 1991 (Log Number 1-2495).
. Pursuant to these commitments as identified in USAR-Chapter 17.2, Engineering Assurance has been performing an in line quality review of Nuclear Safety
- Related (NSR) specifications and modification-packages.
Collective significance reviews.of Engineering Assurance's assessment results since its formation in
-1988 continue to indicate that no significant programmatic or prevalent technical problems exist. This in effect confirms that the formal design i
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Attachment Page 5 verification process and inter discipline reviews inherent in the specification and modification development processes are working. Generally, Engineering Assurance's remaining issues deal with minor and administrative concerns which typically do not have safety implications and are generally identified and resolved as the products progress through implementation.
It is further concluded that having assurance personnel involved in an in-line review sequence tends to present a compromising position for assurance personnel to independently assess a process for which they have in-line review responsibilities.
It is in this regcrd that the above changes to eliminate Engineering Assurance's in-line quality review of specifications and modification packages are proposed.
Engineering Assurance vill continue to assess Engineering activities and products as before, however on a more selective basis. This vill allow management the flexibility to focus its self-assessment resources on issues of concern.
Effect of Change on the Davis-Besse USAR-
-Chapter 17.2 Quality Assurance Program Description Commitments These changes reduce the Quality Assurance Program description commitments previously accepted by the NRC. The proposed changes are to a quality assurance program description contained in docketed correspondence. The letter from
-Mr. D. C. Shelton_to the NRC dated October 21, 1988 (Serial Number 1604),. stated that the ncv Engineering Assurance organization vould assume from the Quality Assurance Department the day-to-day quality review of specifications and modification packages. This letter did not however, in any way, change Quality Assurance Department functional responsibilities as defined in 10CFR50, Appendix A Criterion I or program requirements as defined by 10CFR50, Appendix B.
Since these proposed changes eliminate Engineering Assurance's commitment to perform cay-to-day quality reviews of specificatians and modification packages, it represents a reduction in commitment.
NRC approval is required prior to implementing the proposed changes.
The basis for-concluding that this change continues to satisfy the criteria of 10CFR50 Appendix B and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC is as follows:
The proposed changes do not affect the assignment of quality assurance functions as defined in 10CFR50, A.ppendix A Criterion I.
The Quality Assurance Department retains complete responsibility for assuring that a quality assurance program is established and effectively executed, and for verifying (i.e., by audit, surveillance, or inspection) that activities affecting the safety-related functions have'been correctly performed.
Engineering specification and modification activities have and continue to be subject to audit and surveillance by the Quality Assurance Department.
Though the subject changes represent a reduction in commitment, it does not affect Davis-Besse's 10CFR50, Appendix B program conmitments and continues to meet the requirements of ANSI N45.2.11.
This change is being proposed to establish greater day-to-day accountability with the technical unit responsible for the product, for quality work while returning the assurance role to a more appropriate periodic overviev.
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