ML20147J070

Summary of 970227 Meeting W/Nei & Licensee Representatives on quality-assurance-related Topics in Rockville,Md. Document Reissued to Correct Date of Meeting

ML20147J070
Person / Time
Issue date:	04/02/1997
From:	Malloy M NRC (Affiliation Not Assigned)
To:	Matthews D NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9704100132
Download: ML20147J070 (31)

Text

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UNITED STATES p

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NUCLEAR REGULATORY COMMISSION o,

8 WASHINGTON. D.C. 30006-0001

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REISSUED TO CORRECT THE DATE OF MEETING

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MEMORANDUM TO: David B. Matthews, Chief Generic lasues and Environmental Projects Branch j

Division of Reactor Program Management W

Office of Nuclear Reactor Regulation FROM:

Melinda Malloy, Project Manager 4

Generic issues and Environmental Projects Branch Division of Reactor Program Management Office of Nuclear Reactor Regulation l

SUMMARY

OF MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEI) AND LICENSEE REPRESENTATIVES ON OUALITY-ASSURANCE-RELATED TOPICS i

On February 27,1997, 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 graced quality assurance (GOA) activities with volunteer plants (Grand Gulf Nuclear Station, PVNGS, and STP), performance based QA activities, the potential impact on the volunMer 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 letter). The list of meeting ettondees is provided in Attachment 1.

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1. Performance Based Raoulations and Graded QA I

NEl presented an outline of what the industry considers are necessary steps to improve the regulatory process for QA (Attachment 2). NEl reiterated its concurrence with the staff position on policy issues discussed in SECY 96 218, " Quarterly Status Update for the Probabilistic Misk Assessment (PRA) Implementation 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 sssessment (PSA) techn!quas constitute an invaluable tool for 2

implementing the mainte.ipnce rule. NEl also stated that while the risk informed J) /

approaches are similar foi in ser/ ice testing (IST) and GQA, it acknowledged limitations I

in modeling the altect of GQA changes in the PR,,, model.

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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 that there are certain concerns related to PSA which must be addressed. Specifically, the staff is concerned that the industry has not yet developed or demonstrated a sufficiently sound process (i.e., scrutable and repeatable) that would guide the i.

consistent implementation of PSA technology in all suitable regulatory areas, while at the same time maintaining the necessary regulatory and safety margins. Another remaining area of concern for the staff is the quality of the PRA models and the scope of their modeling. Despite these concoms, the staff continues to encourage industry in usinD PSA techniques for GOA; as well as for other regulatory applications (e.g., IST, im9 roved Standard Technical Specifications (iSTS), etc.).

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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 4

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

NEl emphasized that in its opinion, the GOA initiative is a prime candidate to pursue for performance based regulatory improvements. NEl outlinsd its conceptual framework j

for a performance based monitoring approach. NEl also expressed its intent to meet again with the staff in April 1997 to further discuss the approach and to develop plans for a pilot implementation.

2. Staff Activities with Graded QA Volunteer Plants The Houston Lighting and Power (HL&P) Con'pany representatives presented a brief synopsis of GQA activities at the STP site (Attachment 3). The presentation included an historical summary, a description of the QA program changes needed to implement a GOA 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 j

expressed concerns about their planned GQA approach in light of the uncertainties associated with their perceptions on upcoming guidance from the draft RG on GOA.

i The Arizona Public Service (APS) Company representatives discussed the GQA efforts 4

at the PVNGS. Thair ore entation slides are provided in Attachment 4. Functional areas that the licensee has selected for application of GOA include procurement and sudits. Other areas that have been identified for potential application include environmental equipment qualification, commodities, and the critical vendors list. The 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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n. Matthews 4 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 l

process for GOA remains unclear. Specifically, they stated they were unaware of the need to include quantitatin MA sensitivity analyses as part of the structures, systems, and

- components (SSCs) selety significant categorization process. The staff's initial thoughts on needed studies was discussed during the February 21,19g7, briefing on the draft RG on GQA 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 i

failures); and the other to investigate the aggregate risk impact of implementing GOA by j

simultaneously varying the failure probability of alllow safety significant SSCs.

1 The staff clarified that these were not new staff concems end that requests for l

additional information (RAls) sent to HL&P (on the STP), as a graded QA volunteer, l

!ncluded 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 i

the APS for the PVNGS. The staff reiterated the importance of satisfying technical issues in this area.

NEl stated that the industry remains concemed about staff expectations on GQA which it believes to be contained in the draft RG and which remain unknown to the volunteers i

plants. The :taff 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 l

50.54(a) is needed if the industry is to be allowed to move forward on performance-based approaches to implementing QA programs. NEl presented its early concept of performance based QA indicators (see Attachment 2) which would provide monitoring i

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. NEi reiterated its belief that the current GA program change praess is too cumbersome and that more balance is needed.

The staff agreed that it is appropriate to evaluate the 10 CFR 50.54(a) QA program change process to find objectively acceptable altamatives to the threshold for reporting QA program changes requiring prior approval by the NRC. The staff emphasized, i

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April 2, 1997 g

l' however, that the outcomo of the NEl 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 i

towards a more performance based regulatory framework and agreed te meet to continue j

the dialogue once the risk informed RGs are issued for public comment.

This summary was propered 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, j

Division of Systems Safety and Analysis, NRR.

Attachments:

1. List of Attendees

2. N21's Brisfing Slides

3. HL&P's briefing Slides j

4. APS's Briefing Slides Project No. 689 1

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PUBLIC PGEB r/f MMalloy SMagruder

'ACRS E:: Mail Sco! lins FMiraglia RZimmerman JDonohew RAuluck-TAlexion FGillespie 5

AThadani BBoger LSpessard SBlack i

RGramm EFord LCampbell WHaass RLatta JPeralta DTaylor GHolahan RJones MRubin MCheok SDinsmore TTMartin MSlosson DMatthews FAkstulewicz SMagruder MMalloy BSheron TOMartin, RES PKadambi, RES OGormley, RES MCu1ningham, RES HWoods, RES ARamey-Smith, RES HBell, OlG LHiggins, OlG JMoore, OGC BBordenick, OGC MBismonte, EDO WDean, EDO r

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ppau! acid 7?j4 DN GA-RELATED TOPICS j

SAruary 27,1997 3

Aht of Attendees j

Name Organization 4

Ralph Boedle Nuclear Energy institute -

MaryAnn Bismonte NRC/EDO Suzanne Black NRC/NRR/HOMB Larry CampbcIl NRC/NRR/HOMB Mike Cheok

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Stephen Dinsmore NRC/NRR/SPSB Jack Donohew NRC/NRR/DRPW Ed Ford NRC/NRR/HOMB Rosemary Fullner Arizona Public Service Co./Palo Verd'e Robert Gramm NRC/NRR/HOMB Owen Gormley NRC/RES/GSIB Dale Harmon Westinghouse Energy Systems i

Walter P. Haass NRC/NRR/HOMB Adrian Heymer Nuclear Energy institute Lee Higgins NRC/OlG Gary Holahan NRC/NRR/DSSA Robert Jones NRC/NRR/SPSB Michael Knapik McGraw-Hill Donald Lamontagne Arizona Public Service Co./Palo Verde 2

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 Rohkugler Houston Lighting & Power Co./ STP Mark Rubin NRC/DSSA/SPSB M. Lee Spessard

' NRC/NRR/DRCH Donald toylor NRC/NRR/HOMB Ashok Thadani NRR/ADT a

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J Ust of Attendees Name Organization Roger D. Walker TU Electric H. Roy Woods NRC/RES/PRAB Altheia Wyche SERCH Licensing /Bechtel i

Abbreviations ADT Associete Director for Technical Aeoseement Co.

Company DRPW Division of Reector Projects Ill & IV DRCH Division of Rosetor Controle end Human Factore DSSA Division of Systems Sofety and Analysie EDO Office of the Executive Director for Operations GSIB Generic Safety loeuee Bronch HOM8 Quelity Assurance end Meintenance Branch NRC U.S. Nuclear Reguietory Commission NRR Office of Nucieer Reactor Regulation l

OlG Office of the inspector General j

PRAB Probabilistic Riek Analysie Branch RES Office of Nuclear Regulatory Research SPS8 Probabilistic Safety Asseeement Branch STP South Texas Project 1

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1 List of Attendees,.

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j NEl Project No. 689 1

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Mr. Ralph 8eedle Mr. Thomas Tipton, Vice President Senior Vice President Opera'tions l

and Chief Nuclear Officer Nuclear Eriergy institute t

Nuclear Energy institute Suite 400 t

Suite 400 1776 i Street, NW i

1776 l Street, NW Washington, DC 20006-3708 Washington, DC 20006 3708 Mr. Alex Marion, Director Mr. Jim Davis, Director Programs Operations i

Nuclear Energy instituto Nuclear Energy institute l

Suite 400 Suite 400 17761 Street, NW 1776 i Stroet, NW 4

Washington, DC 20006 3708 Washington, DC 20006 3708 i

Mr. David Modeon, Director Ms. Lynnette Hendricks, Director Engineering Plant Support i

Nuclear Energy institute Nuclear Energy institute '

1 Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW j

Washington, DC 20006 3708 Washington, DC 20006-3708 Mr. Anthony Pietrangelo, Director Licensing Nuclear Energy institute Suite 400 17761 Street, NW Washington, DC 20006 3708 Mr. Ronald Simard, Director Advanced Technology Nuclear Energy institute i

Suite 400 j

1776 i Street, NW Washington, DC 20006 3708 Mr. Nicholas J. Liparulo, Manager Nuclear Safety and Regulatory Activities i

Nuclear and Advanced To::hnology Division Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, Pennsylvania 15230 i

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NEl LETTER ON GRADED QA 10/10/96 l

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- progress & industrywide' benefit l

- NRC - pilot project meetings

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- RAls

-Industry perceptions Uncertainty over adequacy of OA program for low safety significant SSCs ACRS briefings

. Apparent convergence at Nov.1996 briefing I

-ijncertainty in Feb.1997 briefing 3

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GRADED APPROACH TO IMPLEMENTING

--QUALITY l

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W High Safety-Significant (safety related &

non-safety related)

Company Quality l

Regulatory Scope -

Program meets i

Maint. Rule +

App. B req'ts as necessary -

Safety-Significant Graded per i

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Other SSCs 1 r Reg. Scope = Maint. Rule Scope + Other SSCs from Other Regs.

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QA ELEMENTS ! EFFECTIVENESS t

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Company Quality Regdiatory Program -

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i Safety via monitoring Low Safety significance plant condition or j

Significance (Meets Regs)

Performance (safety related &

non-safety related) dther SSCs

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+ 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 l

-Limited focus on safety significance, results i

Improved approach -- performance-based

-Prime focus on results -- organizational functions l

MEnhances feedback for graded QA

-Improved tool for management oversight l

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PERFORMANCE-BASED REGULATION i

1/22/97 SRM on SECY 96-218 i

recommendations on performance-based l

implementation of the regulations l

-Measurable parameters

-Objective criteria 1

-Licensee flexibility on how to meet criteria

-Failure to meet criteria will not result in an intolerable outcome t

QA -- Plant management process

- Regulatory aspect -- provides reasonable assurance inat safety functions will be performed 1

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PERFORMANCE-BASED QA ASSESSMENT i

+ Monitoring plant { equipment, people, process}

- Equipment -- level of monitoring very similar to that of the maintenance rule l~

Process & people -- level of monitoring similar to-i that established in licensee management l

monitoring programs Performance-Based QA indicators provide earlier identification of declining plant performance

-Developing leading indicators he 8

PERFORMANCE-BASED QA i

Monitoring & trending indicators o

Failure to meet criteria

-Perform a cause determination

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

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

-Consistent process for licensee /NRC assessment of plant performance u

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j EFFECTIVENESS ASSESSMENT PERFORMANCE-BASED QA l

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LICENSEE (REGULATORY) CRITERIA

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

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'-SOPPORTiNG-PROGRAMS-a PLANT PROGRAMS & CRITERIA (Vibration, oil analysis, erosion / corrosion, organizational functions, water chemistry, design, testing, procurement, calibration, empioyee concerns, industry guidelines, standards, etc..)

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REGULATORY CHANGES TO IMPLEMENT IMPROVED APPROACH 10 CFR 50.54(a}

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Compatibility with SRM on SECY 96-218

-Licensee flexibility in meeting the criteria

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(Appendix B & monitoring criteria)

Options to NEl petition

-Discussed in April 30,1996 NEl - NRC meeting

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

Further dialogue would be beneficial II

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DRAFT PERFORMANCE-BASED QA PLAN 1

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' Aniend and improve the regulatory change proces~s for QA programs - @50.54{aj NRC involvement and endorsement of industry guideline for the development of:

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-assessment process j

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.. n GRADED QUALITY ASSURANCE AT STP:

L HISTORY l

April,1995 Entered into agreement with NRC staff as volunteer (Pilot) plarn q

March 1996 Submitted revised QA plan depicting i

Graded QA l

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August 1996 Received NRC comments / questions January 1997 Submitted draft QA Plan revision (major l

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7 GRADED QUALITY ASSURANCE AT STP SITE STATUS implementing procedures, Expert Panel, GOA Working Group in place and e

working Two system reviews (essential cooling water, radiation monitoring) are completed and approved by Expert Panel Third system (Emergency Diesel Generators) nearly completed o

Reviews of 24 additional systems will occur in 1997 a

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

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GRADED QUALITY ASSURANCE AT STP THREE LEVELS OF' PROGRAM CONTROLS 1

FULL:

Highest possible levels of control / oversight - applied to safety related, high important items BASIC:

Lesser levels of control / oversight - applied to other safety relatsd items TARGETED:

Select levels of control / oversight - applied to non-safety related, risk important items i

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1 GRADED QUALITY ASSURANCE ATSTP FIRSY TWO SYSTEMS REVIEW RESULTS ESSENTIAL COOLING WATER COMPONENTS t

Full QA - 6 Basic QA - 1,050 Targeted QA - 307 No QA - 43 RADIATION MONITORING COMPONENTS i

Full QA - 0 Basic QA - 388 Targeted O.A - 1,131 No QA 303 t

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GRADED QUALITY ASSURANCE AT STP GQA BENEFITS Increased Nuclear Safety i

increased cost effectiveness (STP anticipates approximately 815 million o

savings per year in procurement costs alone) 4 i

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GRADED QUALITY ASSURANCE AT STP STP plans to proceed with GOA Program implementation June 1,1997 I

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Palo Verde Nuclear Generating Station L

Graded Quality Assurance i

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Donald Lamontagne February 27,1997 i

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Graded Quality Assurance P

i Functional Areas

+ Procurement I

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+ QA Audits and Evaluations c

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+ Selection and Documentation of Critical i

Verification Attributes L

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+ Post-Installation Testing

+ Equipment Failure Feedback 1

Mechanisms

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+ Seismic Qualification d

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. 2-Graded Quality Assurance

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1997 Procurement Initiatives l

+ EmphasizeIncreased Use ofGraded QA I

+ Equipment Qualification j

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+ Commodities

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+ CriticalVendors List

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i NEl Project No. 689 cc:

Mr. Ralph Beedle Mr. Thomas Tipton, Vice President Senior Vice President Operations

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and Chief Nuclear Officer Nuclear Energy institute Nuclear Energy institute Suite 400 Suite 400 1776 i Street, NW 1776 i Street, NW Washington, DC 20006 3708 Washington, DC 20006 3708 Mr. Alex Marion, Director Mr. Jim Davis, Director Programs Operations Nuclear Energy institute Nuclear Energy Institute i

Suite 400 Suite 400 17761 Street, NW 1776 i Street, NW Washington, DC 20006 3708 Washington, DC, 20006 3708 Mr. David Modoen, Director Ms. Lynnette Hendricks, Director Engineering Plant Support Nuclear Energy institute Nuclear Energy Institute.

Suite 400 Suite 400 1776 i Street, NW 17761 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 Nuclear Energy institute Suite 400 l

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 N

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