ML20107G746
| ML20107G746 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 04/22/1996 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO:96-00042, GNRO:96-42, NUDOCS 9604230324 | |
| Download: ML20107G746 (7) | |
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~- EN'TERGY eo ms8 Port Gbson.MS 39150 Tei C41437 2800 April 22,1996 C. R. Hutchinson VCr; Presdrf C J Nirlear StNon U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:
Document Control Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 Lisnse No. NPF-29 l
References:
- 1) GNRO-95/00119 dated November 6,1995 from EOl to NRC
- 2) NRC letter dated January 3,1996 (Beckner to Hutchinson)
- 3) GNRO-96/00009 dated February 12,1996 from EOl to NRC GNRO:
96/00042 Gentlemen:
Grand Gulf's implementation of a performance-based audit scheduling program has been the subject of various correspondence (reference list) and meetings with the NRC. Most recently, on April 3,1996, we met with the Staff and Mr. Ashok Thadani to appeal the Staffs position that our performance-based audit scheduling program represented a reduction in commitment as the term is used in 10CFR50.54(a).
While expressing discomfort over the lack of safety focus, Mr. Thadani upheld the Staff's position based on precedent and the difficulty in contradicting precedent on a single docket. However, as indicated during the meeting, the Staff would be directed to renew their review of the outstanding 10CFR50.54(a) petition for rulemaking which proposes to eliminate the concept of reduction in commitment, and, in the short term, consider issuance of a Generic Letter that would revise the Staffs position on what constitutes a reduction in commitment.
Regardless of the problems associated with interpreting and applying 10CFR50.54(a),
we continue to believe that our performance-based audit scheduling approach will
. result in safety improvement at Grand Gulf. We also believe that the Staff holds a similar view. Consequently, we are submitting the attached supplement to our quality assurance program description and requesting Staff approval.
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GNRO-96/00042 Page 2 of 4 The proposed change would require that audit subject areas previously included in the Grand Gulf Technical Specifications would continue to be audited on a frequency previously specified in the Technical Specifications unless sufficient basis was docurnented to preclude the need to audit. As we've discussed with the Staff, that basir, would consist of performance information coupled with expert judgment that derr.onstrates that the audit subject area's performance is acceptable. The proposed change also restores a prior commitment to audit an activity as early in life as practical to assure timely implementation of quality assurance program requirements. This commitment had been unintentionally deleted in the course of the audit program changes.
Based on various conversations with the Staff we believe that the attached supplemental change is sufficient to implement a performance-based audit scheduling program and addresses the issues raised by the Staff in Reference 2 and its attachment. Since the details of the proposed audit program have already been the subject of extensive correspondence and discussion we request prompt Staff approval of the quality assurance program change docketed in Reference 1 as modified by the attached change.
We would also like to express our appreciation for the opportunity to discuss, during the meeting on April 3, our concerns about the application of 10CFR50.54(a). As the Staff proceeds to re-examine the rulemaking petition and consider issuance of a Generic Letter, we would be happy to provide constructive dialogue to that effort.
Yours truly, jg d4 CRH/MJM:be
Attachment:
Proposed Grand Gulf Operational Quality Assurance Manual Changes cc:
(see next page)
GNRO-96/00042 Page 3 of 4 cc:
Ms. S. C. Black (w/a) (NRC/NRR)
Mr. A. Heymer (NEI)
Mr. R. B. McGehee (w/a)
Mr. N. S. Reynolds (w/a)
Mr. J. E. Tedrow (w/a)
Mr. H. L. Thomas (w/o)
Mr. J. W. Yelverton (w/a)
Mr. L. J. Callan (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. T. P. Gwynn Director, Division of Reactor Safety U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 Mr. A. C. Thadani Asociate Director for Technical Assessment Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555
i GNRO-96/00042 Page 4 of 4 bec:
Mr. D. G. Bost (w/a)
Mr. C. A. Bottemiller (w/a)
R. W. Byrd (w/a)
]
Mr. L. F. Dale (w/a)
Mr. L. F. Daughtery (w/a)
Mr. J. G. Dewease (w/a)
Mr. M. A. Dietrich (w/a)
Mr. J. J. Fisicaro (w/a) (W3)
Mr. J. J. Hagan (w/a)
Mr. C. C. Hayes, Jr. (w/a)
Mr. R. J. King (w/a) (RB)
Mr. M. J. Meisner (w/o)
Mr. D. C. Mims (ANO) (w/a)
Mr. R. L. Patterson (w/a)
Mr. J. C. Roberts (w/a)
Mr. G. A. Zinke (w/a)
File (LCTS/RPTS) (w/a)
File (Hard Copy)(w/a)
File (NS&RA) (w/a)
File (Central) (w/a) ( 7 )
t 6
v ee
(4tWimer0 9 fa @@@C3@!E3 Page 1 of 3 9PERATIONAL QUALITY ASSUPNICE MANUAL TITLE: AUDITS 18.5.6 (Continued):
18.5.6.1 Auditing shall be initiated as early in the life of an activity as practical to assure timely implementation of quality arsurance program requirements.
18.5.6.2 Audits shall be scheduled on the basis of the status and importance of the activities to be audited.
18.5.6.3 This section deleted in Revision 14.
18.5.7 Individual audits shall be pelformed in accordance with documented procedures, p.L a ns, or checklists whi-h describe the audit and provids for an objective evaluation of the status and sdequacy of the areas being audited.
The " objective evaluation" referenced is not to be confused with the evaluation statement in ANSI N45.2.12 to which the licensee has provided a clarification.
See Appendix A.
18.5.8 Audit results, including conditions adverse to quality detected during the audit, shall be documented and reviewed with the supervisor or manager naving responsibility in the areas audited.
Distribution of audit reports shall include management of the audited organization and appropriate licensee management.
18.5.9 Management of the audited organizations shall be responsible for correcting conditions adverse to quality identified during an audit.
They shall assure that corrective action is scheduled, accomplished as scheduled, and documented. The corrective action shall be designed to prevent the recurrence of significant conditions adverse to quality. (See also Appendix A, Regulatory Guide 1.144, Item 11.)
18.5.10 Deficient areas shall be reviewed or reaudited on a timely basis to verify implementation of corrective action.
18.5.11 Audit results shall be analyzed to detect adverse quality trends and to evaluate the effectiveness of the Operational Quality Assurance Program.
Results of such analyses which indicate adverse quality trends shall be reported to appropriate management for review and assessment.
18.5.12 Records shall be generated and retained for all audits, including individual audit plans, audit reports, written replies, and records of corrective action. (See also Appendix A, Regulatory Guide 1.144, Item 13.)
Page 3 of 4 Policy 18 Rev. 14 OQAMTST. DOC
Attaci) ment 1 to GNRO-96/00042' Pag 3 2 of 3 NRC Regulatory Guide 1.30 - Section 6 (Continued):
calibration and identity of person that performed the calibration, can be readily determined. Such information may also be contained on tags or labels which may be attached to installed instrumentation."
Section 7 - Data Analysis and Evaluation will be implemented as stated herein after a'. ding the clarifying phrase "where used" at the beginning of that paragraph.
Section 8 - Records will be implemented by conformance with Policy 17 of the Operational Quality Assurance Manual and ANSI M45.2.9 as set forth in Appendix A to the OQAM.
" Quality Assurance Program Requirements (Operation 1" (Rev.
2, 2/78) - Endorses ANSI N18.7 - 1976.
The 'sperational Quality Assurance Program complies with the requirements of this guide with the following clarifications:
1)
Paragraph C.3 of Regulatory Guide 1.33 (and Section 4.3.4 of ANSI N18.7 which it references) will be implemented as required by the UFSAR, Appendix 16B, which defines " Subjects Requiring Independent Review."
2)
Paragraph C.4
(" Audit Pr7 gram") of Regulatory cuide 1.33
'and Section 4.5 of ANSI N10.7 - 1976 which it references).
Audit frequencies will be implemented as required by the applicable Code of Federal Regulations, Updated Final Safety Analysis Report, and commitments by various correspondence to the NRC.
All other audit frequencies will be baced en per4ereance recultc and impcrtancc cf the activity relative to-eefet-yr determined in accordance with a performance-bcaed audit scheduling program. The scheduling program, through j
an expert panel, uses assessme.
indicators to identify and schedule audits based on perforyance results and importance j
of the activity relative to safcty.
Potential audit subject 3reas are periodically assessed against appropriate gerformance criteria.
From these reviews a determination is mate in ?.egard to the depth, score and scheduling of spe cif j e audits. Audit subject areas contained in Technical Specirications Section 7.4.2.8 prior to implementati sn of the.mproved Technical Specifice.tiona in ML ch, 1995 shall ccatirue to be audited on the tra gencies geviously designated in the Technical Spe:ifications acless expert panel judgment based on perfornance resu] cc determines such an audit to be unnecessary.
In c ter. cases the expert panel basis shall be documented.
3)
Paragraph C.S.a of Regulatory Guide 1.33 (and Section 4.4 of ANSI N18.7 which it references) will be implemanted with the clarification that the Plant Safety Review Committee shall perform this activity.
Page 5 of 36 Appendix A Rev. 14 OQAMTST. DOC to GNRO-96/C0042 Pag 13 of 3
.. +
t.
NRC Regulatory Guide 1.33 - (Continued) 4)
Paragraph C.S.d of Regulatory Guide 1.33 (and Section 5,2.7.1 of ANSI N18.7 which it references) will be implemented by adding the clarifying phrase "Where practical" in front of the fourth sentence of the fifth paragraph.
The regulatory guide's changing of the two uses of the word,'should" in this sentence to "shall" unnecessarily restricts the licensee's options on repair or replacement parts.
It is not always practical to test parts prior to use.
For modifications where these requirements are not considered practical, a review in accordance with the provisions of 10CFR50.59 will be conducted and documented.
I 4
1 l
l Page 5a of 36 Appendix A Rev. 14 OQAMTST. DOC