ML20137F235

Summary of 970207 Meeting W/Listed Attendees in Rockville,Md to Discuss Nuclear Energy Inst Concerns Re Graded Quality Assurance Activities W/Volunteer Plants

ML20137F235
Person / Time
Site:	Palo Verde, Grand Gulf, South Texas
Issue date:	03/24/1997
From:	Malloy M NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9704010016
Download: ML20137F235 (32)

Text

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2 j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

'+,,.....p March 24, 1997 MEMORANDUM TO: David B. Matthews, Chief Generic issues and Environmental Projects Branch Division of Reactor Program Management [

Office of Nuclear Reactor Regulation FROM: Melinda Malloy, Project Manager Generic issues and Environmenta Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation

SUMMARY

OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) AND LICENSEE REPRESENTATIVES ON QUALITY-ASSURANCE-RELATED TOPICS On February 7,1997, representatives of the U.S. Nuclear Regulatory Commission (NRC) met with representatives of the Nuclear Energy Institute (NEI), Arizona Public Service Company's Palo Verde Nuclear Generating Station (PVNGS), and Houston Lighting &

Power Company's South Texas Project (STP) at the NRC's offices in Rockville, Maryland.

The purpose of the meeting was to discuss NEl's concems related to graded quality assurance (GOA) activities with volunteer plants (Grand Gulf Nuclear Station, PVNGS, and STP), performance-based QA activities, the potential impact on the volunteer plants of the draft regulatory guide (RG) on GOA, and the status of the staff's review of the petition for rulemaking on 10 CFR 50.54(a) which was filed by NEl on' behalf of the nuclear utilities.

These concerns were articulated in an October 10,1996, letter from Ralph Beedle to Ashok Thadani (NRC) (see Accession No. 9610230003 for this lett'er). The list of meeting attendees is provided in Attachment 1.

1. Performance-Based Reaulations and Graded QA NEl presented an outline of what the industry co1siders are necessary steps to improve the regulatory process for QA (Attachment 2). MI reiterated its concurrence with the staff position on policy issues discussed in SECY 96-218,=" Quarterly Status Update for the Probabilistic Risk Assessment (PRA) lmplementation Plan, including a Discussion of Four Emerging Policy issues Associated with Risk-informed Performance-Based Regulation," dated October 11,1996, as well as with the associated staff requirements memorandum from the Commission, dated January 22,1997. NEl stated that probabilistic safety assessment (PSA) techniques constitute an invaluable tool for implementing the maintenance rule. NEl also stated that while the risk-informed ,

approaches are similar for in-service testing (IST) and GOA, it acknowledged limitations I' in modeling the effect of GOA changes in the PRA model. Ofg 310048 NRC HLE CENTHi Wh

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D. Matthews -2 March 24, 1997  :

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The staff emphasized its continuing commitment to resolving the risk-informed,

. performance-based regulatory issues discussed in SECY-96-218. The staff indicated i that there are certain concerns related to PSA which must be addressed. Specifically, the staff is concemed that the industry has not yet developed or demonstrated a .

sufficiently sound process (i.e., scrutable and repeatable) that would guide the j consistent implementation of PSA technology in all suitable regulatory areas, while at l the same time maintaining the necessary regulatory and safety margins. Another .

remaining area of concem for the staff is the quality of the PRA models and the scope of their modeling. Despite these concems, the staff continues to encourage industry in ,

using PSA techniques for GQA; as well as for other regulatory applications (e.g., IST, '

Improved Standard Technical Specifications (iSTS), etc.).  ;

Although it intends to proceed cautiously with a risk-informed, performance-based ,

regulatory regime until all safety and regulatory implications are fully understood, the staff does not share the industry's perception that little progress has been made in  !

agency efforts aimed at increasing the use of PSA tools in regulatory decision-making l processes. As an example of progress in this area, the staff cited the amendment to  !

the STP Technical Specifications.  !

I NEl emphasized that in its opinion, the GQA initiative is a prime candidate to pursue for

- performance-based regulatory improvements. NEl outlined its conceptual framework for a performance-based monitoring approach. NEl also expressed its intent to meet i again with the staff in April 1997 to further discuss the approach and to develop plans  !

for a pilot implementation. '

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2. Staff Activities with Graded QA Volunteer Plants l

The Houston Lighting and Power (HL&P) Company representatives presented a brief synopsis of GOA activities at the STP site (Attachment 3). The presentation included i an historical summary, a description of the QA program changes needed to implement '

a GQA program at the STP, the status of current activities, and an account of safety  :

significance categorization of the first two systems. The HL&P representatives  !

expressed concems about their planned GQA approach in light of the uncertainties  !

associated with their perceptions on upcoming guidance from the draft RG on GQA. ,

The Arizona Public Service (APS) Company representatives discussed the GQA efforts at the PVNGS. Their presentation slides are provided in Attachment 4. Functional areas that the licensee has selected for application of GQA include procurement and  ;

audits. Other areas that have been identified for potential application include j environmental equipment qualification, commodities, and the critical vendors list. The l

APS representatives expressed an interest in continuing the dialogue with the staff in '

trying to resolve previous comments and concerns identified during past staff site visits.

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l March 24, 1997 D. Matthews The representatives from NEl and the GOA volunteer plants present at the meeting stated that the staff's expectations on the level of detail needed for an acceptable risk-ranking process for GOA remains unclear. Specifically, they stated they were unaware of the need to include quantitative PRA sensitivity analyses as part of the structures, systems, and components (SSCs) safety significant categorization process. The staff's initial thoughts on needed studies was discussed during the February 21,1997, briefing on the draft RG on GOA to the Advisory Committee on Reactor Safeguards (ACRS). The staff identified two types of studies; one involving changes in the PRA model to reduce the categorization dependence on highly uncertain PRA models (e.g.,

operator recovery and common-cause failures); and the other to investigate the aggregate risk impact of implementing GOA by simultaneously varying the failure probability of alllow-safety-significant SSCs.

The staff clarified that these were not new staff concerns and that requests for additional information (RAls) sent to HL&P (on the STP), as a graded QA volunteer, included questions regarding'such studies. HL&P's response to the RAls was that some model sensitivity studies were planned, but that the identified aggregate risk sensitivity issue would be controlled by the performance monitoring feedback loop.

Similar responses to similar RAls were also received from Entergy for Grand Gulf and the APS for the PVNGS. The staff reiterated the importance of satisfying technical issues in this area.

NEl stated that the industry remains concerned about staff expectations on GOA which it believes to be contained in the draft RG and which remain unknown to the volunteers plants. The staff acknowledged the concems and stated that in keeping with its commitments to the Commission, its goal is to issue all risk-informed RGs for public comment no later than April 1997.

3. Petition for Rulemakina on 10 CFR 50.54(a) and Performance-Based QA NEl emphasized that while the industry does not believe that changes in the provisions of Appendix B to 10 CFR Part 50 are necessary, a change to the provisions of 10 CFR 50.54(a) is needed if the industry is to be allowed to move forward on performance-

- based approaches to implementing OA programs. NEl presented its early concept of performance-based QA indicators (see Attachment 2) which would provide monitoring and trending data for utilities to identify degrading conditions and to take corrective actions as necessary. Such an approach rests on the assumption that licensees would have flexibility (not currently available under 10 CFR 50.54(a)) to change or re-arrange their QA program implementation without prior NRC approval. NEl reiterated its belief that the current GA program change process is too cumbersome and that more balance is needed.

l The staff agreed that it is appropriate to evaluate the 10 CFR 50.54(a) OA program {

change process to find objectively acceptable alternatives to the threshold for reporting l QA program changes requiring prior approval by the NRC. The staff emphasized, l i

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i . j D. Matthews 4 March 24, 1997 {

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however, that the outcome of the NEl petition should not prevent or inhibit progress in GQA activities at the volunteer plants. l At the conclusion of the meeting, both NEl and the staff agreed that progress can be made j; towards a more performance-based regulatory framework and agreed to meet to continue I the dialogue once the risk-informed RGs are issued for public comment.

j This summary was prepared with input provided by the staff of the Quality Assurance and ,

. Maintenance Branch, Division of Reactor Controls and Human Factors, Office of Nuclear i 1

- Reactor Regulation (NRR) and the staff of the Probabilistic Safety Assessment Branch l

Division of Systems Safety and Analysis, NRR. ,

i Attachments:

1. List of Attendees i

2. NEl's Briefing Slides  :

3. - HL&P's Briefing Slides

4. APS's Briefing Slides l l

Project No. 689 )

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cc w/atts: See next page 1

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D. Matthews 4 March 24, 1997 however, that the outcome of the Nt:1 petition should not prevent or inhibit progress in GOA activities at the volunteer plants.

At the conclusion of the meeting, both NEl and the staff agreed that progress can be made towards a more performance-based regulatory framework and agreed to meet to continue the dialogue once the risk-informed RGs are issued for public comment.

This summary was prepared with input provided by the staff of the Quality Assurance and Maintenance Branch, Division of Reactor Controls and Human Factors, Office of Nuclear Reactor Regulation (NRR) and the staff of the Probabilistic Safety Assessment Branch, Division of Systems Safety and Analysis, NRR.

Attachments:

1. List of Attendees

2. NEl's Briefing Slides

3. HL&P's Briefing Slides

4. APS's Briefing Slides Project No. 689 cc w/atts: See next page DISTRIBUTION: See attached page i

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1 Document Name: g:\mxm\MSUM0227.97

• SEE PREylOpS COrKUhRENCES OFFICE PGEB:DRPM BC:HQMB:DRCH BC:SPSB:DSSA SC:PGEB:1 C:PGh: PM 1

l NAME MMalloy:sw' SBlack' MRubin' FAkst icz DMatt DATE 03/11/97 03/14/97 o3/17/97 03p97 o3dh 97 i

OFFICIAL RECORD COPY l

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NRC-NEl MEETING ON QA-RELATED TOPICS February 27,1997 >

List of Attendees Name Oroanization Ralph Beedle Nuclear Energy institute MaryAnn Biamonte NRC/EDO Suzanne Black NRC/NRR/HOMB Larry Campbell NRC/NRR/HOMB Mike Cheok NRC/NRR/SPSB Stephen Dinsmore NRC/NRR/SPSB Jack Donohew NRC/NRR/DRPW Ed Ford NRC/NRR/HOMB Rosemary Fullner Arizona Public Service Co./Palo Verde Robert Gramm NRC/NRR/HOMB Owen Gormley NRC/RES/GSIB Dale Harmon Westinghouse Energy Systems Walter P. Haass NRC/NRR/HOMB Adrian Heymer Nuclear Energy Institute Lee Higgins NRC/OlG ,

Gary Holahan NRC/NRR/DSSA l Robert Jones NRC/NRR/SPSB Michael Knapik McGraw-Hill Donald Lamontagne Arizona Public Service Co./Palo Verde Robert M. Latta NRC/NRR/HOMB Richard P. Lynskey Tennessee Valley Authority Mark McBurnett Houston Lighting & Power Co./ STP Juan Peralta NRC/NRR/HOMB Tony Pietrangelo Nuclear Energy Institute Mike Polak Baltimore Gas & Electric Co.

Roy Rehkugler Houston Lighting & Power Co./ STP Mark Rubin NRC/DSSA/SPSB R. Lee Spessard NRC/NRR/DRCH l Donald Taylor NRC/NRR/HOMB l Ashok Thadani NRR/ADT ]

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1 Attachment 1

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i List of Attendees i Name Organization Roger D. Walker TU Electric H. Roy Woods NRC/RES/PRAB Altheia Wyche SERCH Licensing /Bechtel Abbreviations ADT- Associate Director for Technical Assessment Co. Company DRPW Division of Reactor Projects lli & IV DRCH Division of Reactor Controle end Human Factore DSSA Division of Systems Safety and Analysis EDO Office of the Executive Director for Operations GSIB Generic Safety leeues Branch HOMB Quality Assurance end Maintenance Branch NRC U.S. Nuclear Reguletory Commission '

NRR Office of Nuclear Reactor Regulation OlG Office of the inspector General PRAB Probabilistic Riek Analysis Branch RES Office of Nuclear Regulatory Research SPSB Probabilistic Safety Assessment Branch STP South Texas Project List of Attendees l

IMPROVING THE REGULATORY PROCESS FOR QA i

NRC - NEl Meeting February 27,1997 4

Attachment 2

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IMPROVING THE REGULATORY PROCESS FOR QA Clarify statements made in NEl letter 10/10/96

-Use of PSA

-QA Program for low safety significant SSCs Improved approach needed for assessing QA program effectiveness -- performance-based

-Monitoring plant (equipment, personnel, process)

- Precursors for declining plant performance Graded QA Draft Reg. Guide

- Uncertainty

-Status b'

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NEl LETTER ON GRADED QA 10/10/96 Industry uncertainty ,

- progress & industrywide benefit NRC - pilot project meetings

- RAls

-Industry perce ations Uncertainty over adequacy of QA program for low safety significant SSCs l ACRS briefings

- Apparent convergence at Nov.1996 briefing

-Uncertainty in Feb.1997 briefing e .g.

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GRADED APPROACH TO IMPLEMENTING .

QUALITY

A A High Safety-Significant (safety related &

non-safety related) Company Quality Regulatory Program meets  !

Scope -- App. B req'ts as Maint. Rule + necessary --

Low .

Safety-Significant Graded per i safety i (safety related & significance non-safety related) t V

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Other SSCs i u  !

Reg. Scope = Maint. Rule Scope + Other SSCs from Other Regs.

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.l PERFORMANCE-BASED QA_

i SCOPE  ! CATEGORIZATION i QA ELEMENTS i EFFECTIVENESS n n JL l

High Safety Significance (safety related &

non-safety related) Company Quality Regulatory Program - Assessment of Scope + Graded per program effectiveness safety via monitoring i Low Safety significance plant condition or Significance (Meets Regs) Performance (safety related &

non-safety related)  !

if ...... .............. .. .......... ............... ..... .......

1f ........

Other SSCs 1r

+ Reg. Scope = Maint. Rule SSCs + Other SSCs from Other Regs.

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PERFORMANCE-BASED APPROACH TO ASSESS QA PROGRAM EFFECTIVENESS Current assessment -- programmatic compliance

- Focus is on literal program implementation

-Limited focus on safety significance, results Improved approach -- performance-based

- Prime focus on results -- organizational functions

- Enhances feedback for graded QA

-Improved tool for management oversight e .g;.

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PERFORMANCE-BASED REGULATION  ;

1/22/97 SRM on SECY 96-218 recommendations on performance-based implementation of the regulations '

-Measurable parameters

-Objective criteria

-Licensee flexibility on how to meet criteria ,

-Fai ure to meet criteria will not result in an intolerable outcome QA - Plant management process

- Regulatory aspect -- provides reasonable assurance that safety functions will be performed z .g.

.l PERFORMANCE-BASED QA ASSESSMENT Monitoring plant { equipment, people, process}

Equipment -- level of monitoring very similar to that of the maintenance rule Process & people -- level of monitoring similar to that established in licensee management monitonng programs Performance-Based QA indicators provide earlier identification of declining plant performance

- Developing leading indicators

PERFORMANCE-BASED QA ,

Monitoring & trending indicators Failure to meet criteria ,

-Perform a cause determination  ;

-Focus on cause and correction before criteria are i violated --if necessary, through QA program changes Significant incentive to meet indicators

- Assures protection of public health & safety while focusing resources more effectively

-Consistent process for licensee /NRC assessment of plant performance l i 6

1. .

A EFFECTIVENESS ASSESSMENT PERFORMANCE-BASED QA LICENSEE (REGULATORY) CRITERIA .

CORRECTIVE ACTION MONITORING & TRhNDING PROGRAMS (e.g., plant, system, organizational,..)

A A A A

- - h- - - -  :-SUPPORTiNO-PROGRAMS-Y .

PLANT PROGRAMS & CRITERIA  ;

I (Vibration, oil analysis, erosion / corrosion, organizational functions, water chemistry, design, testing, procurement, calibration,  ;

employee concerns, industry guidelines, standards, etc..)

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REGULATORY CHANGES TO lMPLEMENT IMPROVED APPROACH 10 CFR 50.54(a)

Compatibility with SRM on SECY 96-218

-Licensee flexibility in meeting the criteria (Appendix B & monitoring criteria)

Options to NEl petition

-Discussed in April 30,1996 NEl - NRC meeting

-Summarized in NEl May 30,1996 letter to NRC .

Further dialogue would be beneficial

.g.

DRAFT PERFORMANCE-BASED QA PLAN Amend and improve the regulatory change process for QA programs - @50.54(a)

NRC involvement and endorsement of industry i guideline for the development of:

-indicators

-criteria

-assessment process Licensees implement performance-based QA per

! guideline recommendations

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GRADED QUALITY ASSURANCE AT STP

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HISTORY April 1995 -

Entered into agreement with NRC staff as volunteer (Pilot) plant March 1996 -

Sobinitted revised QA plan depicting Graded QA August 1996 -

Received NRC comments / questions i

January 1997 -

Submitted draft QA Plan revision (major format) i

GRADED QUALITY ASSURANCE AT STP SITE STATUS

- Implementing procedures, Expert Panel, GQA Working Group in place and '

working

- Two system reviews (essential cooling water, radiation monitoring) are completed and approved by Expert Panel t

- Third system (Emergency Diesel Generators) nearly completed Reviews of 24 additional systems will occur in 1997 i

. The GQA process has been frozen past the point of Expert Panel review / approval of system review packages

7 GRADED QUALITY ASSURANCE AT STP THREE LEVELS OF PROGRAM CONTROLS FULL: Highest possible levels of control / oversight - applied to safety related, high important items BASIC: Lesser levels of control / oversight - applied to other safety related items TARGETED: Select levels of control / oversight - applied to non-safety related, risk important items l

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GRADED QUALITY ASSURANCE AT STP FIRST TWO SYSTEMS REVIEW RESULTS ESSENTIAL COOLING WATER COMPONENTS Full QA - 6 Basic QA - 1,050 Targeted QA - 307 No QA - 43 I

RADIATION MONITORING COMPONENTS Full QA - 0 Basic QA - 388 Targeted QA - 1,131 No QA 303

GRADED QUALITY ASSURANCE AT STP GQA BENEFITS

- Increased Nuclear Safety

. Increased cost effectiveness (STP anticipates approximately $1.5 million '

savings per year in procurement costs alone) i i

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GRADED QUALITY ASSURANCE AT STP STP plans to proceed with GQA Program implementation June 1,1997 i

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Palo Verde Nuclear Generating Station 4

Graded Quality Assurance Presented by Donald Lamontagne February 27,1997 Attachment 4 i

,e Graded Quality Assurance Functional Areas l

+ Procurement l

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+ QA Audits and Evaluations

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Graded Quality Assurance Procurement Improvements Made In 1996

+ Selection and Documentation of Critical Verification Attributes

, + Post-Installation Testing

+ Equipment Failure Feedback Mechanisms 4

+ Seismic Qualification Si&L

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i Graded Quality Assurance 1997 Procurement Initiatives i

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+ Emphasize Increased Use of Graded QA i

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+ Equipment Qualification

+ Commodities

+ CriticalVendors List i

- m..o.,.,, - , m ,

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E  ;

, l NEl Project No. 689 cc: Mr. Ralph Beedle Mr. Thomas Tipton, Vice President i Senior Vice President Operations j and Chief Nuclear Officer Nuclear Energy Institute j Nuclear Energy Institute Suite 400 1 Suite 400 1776 l Street, NW l 17761 Street, NW Washington, DC 20006-3708 i

Washington, DC 20006-3708 )

Mr. Alex Marion, Director Mr. Jim Davis, Director .

Programs Operations i

Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1 1776 i Street, NW 1776 I Street, NW l Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. David Modeen, Director Ms. Lynnette Hendricks, Director Engineering Plant Support Nuclear Energy Institute Nuclear Energy Institute J Suite 400 Suite 400 1776 i Street, NW 1776 l Street, NW ,

Washington, DC 20006-3708 Washington, DC 20006-3708  ;

Mr. Anthony Pietrangelo, Director '

Licensing Nuclear Energy Institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 Mr. Ronald Simard, Director  :

Advanced Technology l Nuclear Energy Institute l Suite 400 1 1776 i Street, NW Washington, DC 20006-3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities Nuclear and Advanced Technology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 i

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r l-lI Distribution for Summary of Meeting w/ NEl on QA-Related Topics dated March 24, 1997 Hard Cooy Central Files PUBLIC PGEB r/f MMalloy SMagruder ACRS i E-Mail l

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MSlosson DMatthews FAkstulewicz SMagruder MMalloy BSheron TOMartin, RES PKadambi, RES l OGormley, RES )

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BBordenick, OGC MBismonte, EDO l WDean, EDO 1

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