ML20133C241
Text
,,
~
.. =.
ar.m c.
.w:
Jgy k._g)., _ :c
- + :, :. m
- 3 e.r.i
- e
,'*- 43[9.!
cis.
..s u. s 2 5 m ;a July 8, 1983 MEMORA'iDUM FOR:
R. L. Spassa rd, Director, Division of Engineering FROM:
C. E. fiorelius, Director, Division of Project and Resident Programs
SUBJECT:
INSPECTIO.'i 0F QA PROSP.AM AT DAVIS-BESSE Since the last QA inspection by the PAS Team, the licensee has totally renritten t'.eir QA Manual.
In. this new revision, the licensee took numerous exceptions to ANSI Standards / Reg. Guides requirements where no previous exceptions were taken.
We are concerned that these changes may have weat en&d the licensee's Quality Program.
As you know, the licensee's recent subrittal under 50.54 is under revien-by DE.
Dring a, audit of their CA Frogram, the licensee found that their auditinc staf f car, r.ct.eet the audit workload.
We also question whether the auditing staff is 6f:;.ately trair.ed arid /or experienced to perfor. audits in all a reas recaired by ths CA F rogram.
Tne i,RC CA r.:-1,les a re c',erdue by more than 6 cor.ths.
In addition, oc lespe:tica findings indicate that the QA Frogram at Cavis-Eesse r.iy be deficient at identifying problems.
As a result of all of these concerns at Davis-Besse, we request your assist-ance in inspecting the QA Program at Davis-Sesse on a priority basis.
Ot2W C. E. fiorelius, Director Division of Project and Resident Programs e-so* $
_p - [. -
g
!d7!,bgyPg By ff4
, V, u~ gcp
- e'
- :::=W'
4,.
Docket No. 50-346 License No. NPF-3 Serial No. 964
",*"*""C"*
f July 18, 1983
.[
e<n w'
L N
Director of Nuclear Reactor Regulation y
Attention:
Mr. John F. Stolz o
Operating Reactor Branch No. 4 l
Division of Operating Reactors i
United States maclear Regulatory Commission i
Washington, D.C.
20555
- l !
x
Dear Mr. Stola:
4 i
-):.
n The purpose of this letter is to provide a status report on Toledo Edison's ongoing activities towards developing and implementing its Integrated 9
Living Schedule Program (II.SP) for the Davis-Besse Nuclear Power Station cil Unit No. 1.
The present letter is pursuant to our letter of May 10, 1983
@2 (Serial No. 940).
Ud j i.. ;..
h'p letterwehavep%;l-t! -
since our May 10. 1983 rogressed aggressively towards cup internalizing the ILSF into our normal ~ management programs and processes.
.h During this period we have been concentrating our efforts on developing f
the Fiscal Year 1984 Capital and Operating & Maintenance Budgets for Davis-Besse. In accordance with standard company practices, the budget 3
development'and approval cycle ~cosasaces during the late sprias and is
$.4 completed durtag the. winter of each" year.YThis year. ;the budget develop-
/O ment activities have been 'modifiedfto'incoiporate all'of the basic con-4 cepts that will constitute out.ILSP._i k ? J f!. ? %
~
Y h M
'7
& f W l N $ $Li % n h a N U -l N h W
We are currently prioritislag projects.~ planning their implementation
- 'yl; based upon,the relative' priorities and realistic planning constraints y,n
-ariteria, and propering detail d implementation schedules using our W
, Project /1~planninglandg % systesi.T While these ongoing activities
- - have provided'usfeitF valuable information on how to improve the implemen-tation'ef'many~of M I1SP concepts. they have also delayed the actual "9
'ia sobeiasias(faff the)lan? " dine'te the demands of our budget developmen embaission~e sur, M eraft' plan to the NRC. We;believe that the delay
'0 process and;the leseemsl learned during it, will definitely benefit the f)4
~
actual product'ultiastely_ submitted to the.NRC, As you will note from the j
~
subsequest.discussisef we~have clearly inititated internal implementation
't of the ILSF ~and have also identified a reasonable program for submitting a meani,ngful pisa to the NRC.
.: a;p m V y d 1
During'the' period 'sEb's4EntYo'our' May 10s '1983 letter, we finalized and Ij issued a Toledo Edison Nuclear Mission " Practices and Procedures" which j
incorporated the philosophy and concepts of the ILSP inta our standard d
management operating practices. The issuance of this specific " Nuclear Practices and Procedures" forms 11y established the ILSP as a pc Licy directive within Toledo Edison.
\\
THE TOLEDO ED860N COMPANY EDISCN Pt.AZA 300 MAD: SON AVENUE TCLEDO. CRO 43652 8307280330-830718
\\
PDR ADOCK 05000344 P
9
' Docket No. 50-346 License No. NPF-3 Serial No. 964 Page 2 E
L C
The Davis-Besse Work Scope Committee (DBWSC). which represents the manage-f ment entity in the Nuclear Mission responsible for recommending and ultimately managing our overall budget programs, has primary responsibili-e ty for directing the internal implemsstation of our ILSP. This committee
{
was initiated prior to ILSP development and we have expanded the charter j
to include operating and asistenance projects to be consistent with the ILSP philosophy., The D5WSC accomplished the_following pertinent activi-ties during the months of May and James $ 9 ? A J % #A-A "Prioritization Sebcommittee[$3Nk3;NMUN'
- :- if.
- MM'fpNQ'g 1.
to the DEWSC w W established. This ij subcommittee contaisis representatives from the following Toledo Edison Divisions ' 'Devis-Bessej Stattoo;. Nuclear Facility Engineering; i.;hj t
,f Nuclear Services (including Nuclear Licensing); Nuclear Projects; and l,gd Nuclear S&fety. This subcommittee.wae'.taaked with the responsibility to assign projects to specific prioritization categories as part of
'-]q
~
.r the ILSP..la addition..duringitbe development' of Fiscal Year 1984 7..
budgets, the subcouaitteelhas also beenlassigne ' the responsibility
. )].l to validate the planalag information,associatei with all projects
'M incorporated into thejl&SF#%;Mdg/W - c.m; Vf JO 3 99.iWOMf$24M!kkM b.,14J V
h 2.
A guidance assorandua' addressing;the'*Istegrated Living Schedule Program - Project Prioritisation: Actihties" was finalized and M.
~
isoned. This memorandums iri1Fand has'.siready been used by the d !-
~
Frioritization M ea==4tteaftalaccomp11.hio. its responsibilities.
'3
~
The~smidance offered by.the DENSC addresses the following prioritiza-ties factors:1.Ma)!sde nefT' i*.(b)isesslatorysignificance;(c)
- M]
plant _ reliability /availabilityg d)* practicality /econcales; ~(e)
'M,
.g.d personnel safetyc @M 4 @,T
%.sY hR g% 3:av N S Ma. %-M !s ;
~
'"~
2 - p w
4
,, e 2.,c t, N
~9.
y :::+
.z-
- 3(f4; -
.A guidance (',. e.a..e m.< 4,ymemoranden addres.,w n mstag tho' " Integrated 3
3.
t f
a Program - Seemario Development" ess;finalised and issued.. This
' amenoraades identifies the semeral' planning'_ constraints and evalua-
- #2ld 1
^;,yt$ans'thselshould'bi' performed'liaTdevelopingtheoverallProject/2 3'd schedule ~scenarieTforithe1LgP..The memorandum also discusses the Nt
.pim==ing review ~. add analyses that umst be prepared and presented to "c1 the DalsC sham "neum modified ta:the ILSP; projects are added to, or existing projects are M ':Bb9
-/
i
.:R %. W Q.Q M flw p W U ;., A' r j
i 4.
The Fiscal Year'1984.sedget development process (capital and operac-ing & maintenance' projects)' was commenced. As stated previously the y
l budgets are beias established with full cognizance and utilization of
~
the ILS? concepts.
~
i s.-
i In addition to the DSWSC activities identified above, we have also accom-
]
plished the following pertinent activities:
(
1.
Finalization and issuance of specific projects related procedures that address the following activities within the context of the ILSP; l
issuance of work authorizations; development of planning worksheet l
' Lkenne No. NPF-3 Serial No. 9o4 Page 3 4
f
\\
i inputs that are necessary for both prioritization and ItsP scenarie development activities; preparation of detailed project implementa-tion schedules; and modifications to the approved capital budget.
l
.I" 2.
The Research and Development Division in cooperation with Nuclear 1
Services. Nuclear Safety, and Davis-Besse Station has initiated a
, 7J j]y program to impreve our internal capabilities (tools, information.
expertise) for assesoing the safety related priorities for proposed capital and operating.4 maintenance projects at Davis-Besse. This T.A program wtll involve the use of existing PRA' analyses, coupled with
,4 available Davis-Besse specific PRA,related~information to improve our fj basis for assigning safety related prioritiess In' addition, we have Q
m retained a highly qualified consulting organisation experienced in W
developing and utilizing FRA's to work jointly with Toledo Edison personnel in order to help us' implement lthis program and to train
- QyW)
Toledo Edison personnel in PRA related techniques and uses.
M a
7 Asevidentfromtheprecedingkiscdssica;swohavemadesignificantpro-
- 1. ae.l.
gress in developing and internalizing our ILSP. ' When we initiated our L
ILSP activities late last year, we were only considering safety and
.Eyi regulatory factors in our prioritization process? This year we have 3
4 expanded the prioritization' effort to include plant perforrance charac-p teristics personnel safety cosiside'rationsraad practicality / economic
~
factors. This prioritiaation~ effort.~of'necissity, is'still primarily 9@9
'J using qualitative based criteria (.However, sk have formally internalized the process within which the'prioritisation ' activity occurs and we have
%;c specified a common set of critaria for each prioritization factor being
- .,ie considered.
In addition.;as indacated. e are working;towards an improved y
w and more quantitative approach'to ' assessing safety related priorities. We
~
- M expect results from this effort will be available for use as' a " technical
,, Q9pi validation" of the safety",related priorities',that will be assigned to the 6,ep Fiscal Year 1984 budgeted projects based.upon our current " critical safety I
e G
function" criteria.. CQ f, t.. j.; M M
e
- W
, n '9:3
'X
^
Civen our current status, we have identified 'a schedula'for finalizing and l,g
,w submitting a draf t IL5P plan toithe NRC. The oubmission schedule recog-($;
nises.the fact that'our internal budget' development process and the t 7,' -
scheduled July outag' ;for Davis-Besce represent real and significant Jf*,1 s
events af factimig the' timing for~ sabeission of the Plan to the NRC. In
~ 31 addition, our experiencelf*o"date 'indicatea that.the nose productive
-W dialogue with the NRC cone'erning the~ ?lan would occur af ter we have
\\W completed implementing many of the ILSP concepts during the preparation of
~
the Fiscal Year 1984 recommended budget. In this regard, we have estab-11shed an internal schedule that results in the submission of a draft ILSP
. ~.
Plan to the WRC by September 1.198';. We expect the Plan will contain the
-W types of information indicated previously in our May 10. 1983 letter.
i Furthermore, we anticipate the Plan would be incorporated as a license amendment and would be treated from a regulatory perspective in a similar manner as our security plan.
I l
i...-
'\\
6 Docket No. 50-346 License No. NPF-3 Serial No. 964 Page 4 s
i Shortly af ter September 1,1983 we expect to have the Imple.nentation f
il Schedule for the Fiscal Year Budget ~1984 activities available for present-
,b acion to the NRC. While we definitely intend to have our ILSP include all
'j of our known activities (beyond e., threshold, level of expenditures), we y
have separated the overa1LILSPJisteitvo' parts'. The first part extends j
over.approximately a:2 year; time" period and is' called an " Implementation
,l Schad=1=".? The "Implementattee Schedula" represents all.af the activitier that have been incled.d is am 7spproved bidget'.T This~is tie portion of the j
overall ILSP that would be available in September.f The second part of the
)-
i.
f.
ILSP is designated the "Long Range Plan". The "Long Range Pisa" will be f
4 scheduled by activity task and :is expected to extend from approx 1=tsly
(
't Year 2 through Year 5.
We do not' expect to have the complete "Long Range
~j Plan" part of our ILSP available by September 1,1983.
L id %..
I 4
I trust the information presented in this letter has been useful and
}~
j informative. We will continue our efforts toward the development and
{
j implementation of the ILSP and will' keep our NRC-Project Manager informed
- y of its status. Unless our schedule for submission of the draf t plan to l'
the NRC changes, we do not plan to formally submit additional status T'
information to you, prior to September 1,1983.
{.
?'
i,
- e s
4 Very truly yours, f
=='
RPC:MSF:1rh ec: DB-1 NRC Resident Inspector l
i
+c.,y%w-
-m--i---
m w w--
-.s-gww-w
--w--.m--%
w--,,-.me-mie--y-w wwwgaw---,-w-g-www-www.-..