ML20151J003

Discusses TIA 97-014 Catawba Frequency Requirements for Quality Assurance Audits.During Routine Insp of Catawba Facility,Inspector Noted Section 6.5.2.9 of TS Revised in 1992 to Eliminate Frequency Requirements for QA Audits

ML20151J003
Person / Time
Site:	Catawba
Issue date:	06/05/1997
From:	Jerrica Johnson NRC (Affiliation Not Assigned)
To:	Berkow H NRC (Affiliation Not Assigned)
References
NUDOCS 9708050065
Download: ML20151J003 (15)

Text

• I ' L % * < aj 1 JUNE 5, 1997 MEMORANDUM TO: Herbert N. Berkow, Director Project Directorate 11-2 Division of Reactor Projects 1/11 FROM: Jon R. Johnson, Director ORIGINAL SIGNED BY Division of Reactor Projects R. CRLENJAK IDR:

SUBJECT:

TASK INTERFACE AGREEMENT (TIA 97-014) CATAWBA FREQUENCY REQUIREMENTS FOR QUALITY ASSURANCE AUDITS During a routine inspection of the Catrvba facility, a Region ll inspector noted that Section 6.5.2.9 of the Technical Specifications (TS) had been revised in 1992 to eliminate the frequency requirements for QA audits.

The attachment (pages 2-7) to the I;censee's letter, dated December 18,1991, stated that audit frequencies were being deleted from the TS but the Duke CA Topical Report was to be revised to specify that audits of selected aspects of the operational phase activities were to be performed with a frequency commensurate with the safety significance and in such a manner that audits of all safety related functions would be completed within a period of two years.

NRC's letter dated May 7,1992, issued Amendment Nos. 96 and 90 for Catawba Units 1 and 2, respectively, and revised the TS to eliminate the audit frequencies p:eviously specified by TS, Section 6.5.2.9, of the specifications since these frequencies were to be addressed by the Duke QA Topical Report.

Subsequently, the QA Topier' Report was revised to specify an audit frequency of two years only for QA Condition 1 (safety related components and services). Audit frequencies were not specified for QA Conditions 2,3, and 4 functions.

TS, Section 6.5.2.9, identifies 13 activities requiring audits. Most of these activities are not Category 1 functions and do not meet the two year audit frequency requirements of the QA Topical Report. The audit frequencies for the Security and Emergency Programs are specified by other licensing documents. However, it appears that audits of the remaining functions will only be performed at the discretion of the licensee. We believe that the QA Topical Report change did not meet the intent of the justification provided in TS Amendment Nos. 96 and 90.

A review of the TSs for the other Duke facilities indicated that the audit frequency requirements at these two Mtes had also been removed from the TS. .

Attached are portions of the licensee's December 18,1991, submittal, NRC letter of Ma ,

1992, McGuire TS, Section 6.5.2.9, Oconee TS, Section 6.1.3.4, and Duke QA Topical Report, Sections 17.0 and 17.3.3.2.3.

9708050065 970605

, PDR ADOCK 05000413 I

i

Herbert N. Berkow 2 We request that NRR perform a technical review of the QA Topical Report for the Duke facilities to determine if, for Catawba specifically, but all Duke facilities in general, the changes to the report of only placing an audit frequency on Category 1 functions met the intent stated in the licensee's justification for removing all the audit frequencies from TS Section 6.5.2.9 by Amendment Nos. 96 and 90.

This issue has been discussed with Peter Tam, NRR/DRPE/PD 11-2, and Edward Ford, NRR/DRCH/HOMB. If you have any questions please contact Paul Fredrickson at (404) 562-4667 or Bill Miller at (404) 562-4673.

Attachments: 1. Duke's letter dated December 18,1991, Pages 6-10, 6-11, 2-6 and 2-7

2. NRC's letter dated May 7,1992, Pages 6-10,6-11 and 3

3. McGuire TS Section, Pages 3-10 and 6-11

4. Oconee TS Section, Page 6.1-5

5. Duke QA Topical Repert, Pages 17-1,17-42 and 17-43 cc w/ attachments:

G. Edison, NRR PM C. Hehl, RI G. Grant, Rll!

T. Gwynn, RIV J. Lieberman, OE J. Barnes, Ril

(*) SEE PREVIOUS PAGE FOR CONCURRENCFS OFFIM pff rDS D!f OPS Off-000 #1f 0D0 SIGNATURE NAME WMILLER PFREDRICK. SON CCasto JOHNS 01 DATE 06 / / 97 06 / / 97 06 / / 97 06/[/97 06 / / 94 06 / / 97 COPY? YES NO YE$ NO YES NO YES NO YES NO YE5 NO UrriCIAL RtCORD COPr uvQ# chi NAMr.: 5:\Dkis51bilNPuiS\CAIia00.0A

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l Herbert N. Berkow 2 Enclosed are portions of the licensee's December 18,1991, submittal, NRC let 'r of May 7, 1992, McGuire TS Section 6.5.2.9, Oconee TS Section 6.1.3.4, and Duke Q. opical Report Sections 17.0 and 17.3.3.2.3. l We request that NRR perform a technical review of U c QA Topict .; port for the Duke facilities to determine if, for Catawba specifically, but all Duke facil' 'es in general, the changes to the report of only placing an audit frequency on Cat ory 1 functions met the intent stated in the licensee's justification for removing all the udit frequencies from TS Section 6.5.2.9 by Amendment Nos. 96 and 90.

l. This issue has been discussed with Peter Tam, NRR/ PE/PD ll-2, and Edward Ford, l NRR/DRCH/HQMB. If you have any questions pie e contact Paul Fredrickson at (404) 562-4667 or Bill Miller at (404) 562-4673.

Attachments:

1. Duke's' letter dated December 18,19 , Pages 6-10, 6-11, 2-6 and 2-7 l

2. NRC's letter dated May 7,1992, P es 6-10,6-11 and 3

3. McGuire TS Section Pages 6-10 nd 6-11

4. Oconee TS Section Page 6.1-5

! 5. Duke QA Topical Report, Pa s 17-1,17-42 and 17-43 l

l cc w/ attachments: l G. Edison, NRR PM R. Cooper, RI W. Axelson, Rill J. Dyer, RIV l

J. Barnes, Ril j i

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, DATE 05 4 / 97 05 / / 97 M/ k / 97 0_5 / / 97 05 / / 97 03 / / 97 l l

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CM?@EE3020 @@0J D December 18, 1991 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: Document Control Desk

SUBJECT:

Catawba Nuclear Station Docket Nos. 50-413 and 50-414 Proposed Technical Specification Changes Gentlemen:

Pursuant to 10 CFR 50.4 and 50.90, attached are proposed license amendments to Appendix A, Technical Specifications, of Facility . Operating Licenses NPF-35 and NPF-52 for Catawba Nuclear Station Units.1 and 2, respectively.

Effective November 1, 1991 Duke Power Company implemented a reorganization that essentially decentralized the corporate management of nuclear activities to each of the nuclear sites.

In meetings with your staff on October 30, 1991, we discussed the new organizational structure and its resultant benefits on overall plant safety and efficiency.

At that time we also discussed our plans to revise the documents that assigned specific corporate responsibilities and functions. We are in the process of revising the Duke Quality Assurance (QA) Topical Report, using the guidance provided in Standard Review Plan (SRP) Section 17.3. We will soon be issuing as a special update to each FSAR, a revised Chapter 13,

" Conduct of Operations".

As soon as we have the revised FSAR, the revised QA Topical Report and the Technical Specification revisions in place, we can proceed with the revision of other administrative documentation. Your timely consideration of this request will certainly help us hasten the completion of this transition.

Attachment 1 contains the proposed Technical Specification changes. Attachment 2 contains,the summary and justification for the proposed changes. Pursuant to 10CFR 50.91, Attachment 3 provides the analysis performed in accordance with the standards contained in 10CFR 50.92 which concludes that the proposed amendments do not involve a Significant Hazards Consideration. Duke Pouer is forwarding. a copy of this amendment request application and No Significant Hazards Consideration analysis to the appropriate South Carolina state officials. The proposed amendments have been reviewed and have ATTACINENT 1

j ,

ADMXNISTRATfvE CONTROLS I

1 -

REVIEW 6.5.2.8 The NSRB shall bat responsible for the review of: Y

a. The safety evaluation for:

(1) changes to procedures, equipment, or systems, and (2) tests of Section 50.59, 10 or experiments completed under the provision tute an unreviewed safety question.CFR to verify that such actions die n b.

Proposed changes to procedures, equi'pment, or systems which invo an unreviewed safety question as defined in Section 50.59, 10 CFR:

c.

question as defined in SectionProposed tests or experiments w 50.59, 10 CFR; d.

Preposed License; changes in Technical Specifications or this Operating  !

e.

Violations of Codes, re~gulations, orders, Technical Specifications  !

license requirements, or of internal procedures or instructions , t having nuclear safety significance;  !

f. Significan operating abnormalities or deviations f rore. normal and f

expected performance of unit equipment that affect nuclear safety;

g. All REPORTABLE EVENTS; i

h.

All recognized indications of an unanticipated deficiency in some that cou_1d affect nuclear safety; aspect of design or operatio

i. Qualit e.cifica. % w l /

sMance Department audits relating to station operations and actions taken in response to these audits; and j.

N' Specifications 6.5.1.1 through 6.5.1.p.Reportsofact

{ AUDITS 1;L.#

l j 9td

6. 5. 2. 9 Audits of

)

tne HSR p These audits shall encompass: activities shall be performed under the a.

Technical on W .: nths; Specifications and applicable license ' c l' b.

The performance, training, and qualifications of the entire umt s+atio41 -

staf f at--4e's t ence per 12 .enW; y

) CATAWBA - UNITS 1 L 2 6-10 4

r

l .

l ADMfNISTRATIVE CONTROLS i l

AUDITS (Continued) l c. The results of actions taken to correct deficiencies eccurring in '

unit equipment, structures, systemy or method.of operation that l affect nuclear safety ath'g per 0 iaunihs; -

d.

The performance of activities required by the Operational Quality Assurance Pro at'eectc%gramtomeetthecriteriaofAppendixB,10CFRPart50, ci 24 i..ceths; y

e. ThefmergencyPlanandimplementingproceduresat'e

,12 po.ns ; r <"C' P" '

f. The Security Plan and implementing procedures at \ ic / '

12 % th:; u unce pe r . - i

,e /

\~

g. The Facility Fire Protection programmatic controls including the implemegngproceduresat-le::tcacPA . months bj quelified e l waare p percer-el; h.

ThefireprotectionequipmentandprogramimplementationapYst - I cacy(12mcnthsutilizingeitheraquali.fiedoffsitelicensee fire protection engineer or- an outside independent fire protection

} consultant. An outside independent fire protection consultant shall

w. . . be used at least every third year; ,

l i. TheRadiologicalEnvponmentalMonitoringProgramandtheresults thereof at kest q pci 12 month =; -

j. TheOFF5IT(OpSECALCULATIONMANUALandit..plementingprocedures-at. -

l aast cracg m u.un co, s ;

l k.

The PROCESS CONTROL PROGRAM and implementing proced g for gqcejsingandpackagingofradioactivewastesati encc per #

y ... m um, 1.

The performance of activities required by the Quality p urance '

Prograyenth-s; for effluentand and environmental monitoring at g t once per y/ .

d_5 t t cG j,-

m. Any other area of M operation considered appropriate by the NSRB or the Vic: President. Nuciccu Frouuction. m lE1ec.v W e \{ i e t-- ' & cM =L t n b. , Vc " c ~~ C ;' C * "* *\ ' o

• I

RECORDS

! 6.5.2.10 Records of NSRB activities shall be prepared, approved, and distributed l as indicated below:

Se n: o< Vice. 7 esid ent , w vel ea.c. C+emtioa 1 .-

a. Minutes of each SRB meeting shall be prepared, approved, and

,, forwarded to th Wce residcot, Nucicai P.0 % and to the Executive Vice President,,Pcxer C-cup-within 14 davs l following each meeting; O p ow ce Gr en e.x wh o m (/

CATAWBA - UNITS 1 & 2 6-11

4 1

the site. The number 12 is a typographical co I

i rrection.

and therefore should be considered accep strative 6.5.2.2 The naming of Generation Executive Vice President, reflects the realignment of Power authority for the NSRB reporting CNS This FSAR Chapter 13 and asindiscussed in draft the QA Topical re' vised Sectio change is administrative, n 17.3.

is philosophically correct and acceptable.the change l

The other, proposed change in this section would increase the pool of qualified individuals from which candidates could be appointed operational phase activities. to independently r'eview  !

those who operate the plant are The requirements at least this fl exible. for The appointment Executive would be subject to the approval of Vice President, the Power Generation, j

This propcsed change is not directly related to the 1

Duke reorganization documents. or the requisite revisions licensing If its to our i

~

we'would prefer todown the review of all other changes chapter, in this submittal. consider it separately in another 6.5.2.3 These

\

changes reflect realignment of authority or  !

responsibility as discussed above and described in proposed and the revised TS 6.2.1, draft revised QA Topical Report. CNS FSAR, Chaptrr 13 .

The independentuse of theofterm nature " site" assures the continued the NSRB. i 6.5.2.8 This change reflects the function of which the renaming is of the Department, unchanged. This administrative change should be considered acceptable The "12" .

editorial. corrects a typographical error and is purely \

5.6 5.2.9. .?

% , jall e are applying here the broader term " site" to reflect" ,,i i

thosethose activities associated with the station t

unit. that are only specific to the operation of, thenot

)

\

The term " station" Specification 6.2.2(f)in (b) and isimplies consistent with eitsinus '

'I

reporting to the Station Manager, responsible those people

! }

operation and maintenance of the unit. for are administrative and do not alter the function of theThese change 2-6 i

I l

l

. _ . . . . - - - . . . - - - . - . . . - - . . - . -- - . . - . . - ~ . , - - . - . .

NSRB organization and therefore should be considered i acceptable.

\

l

( Audit frequencies are ' being deleted here but in the' revised QA ' Topical se are preparing the following l statement, using SRP 17.3 guidance on planned and l periodic assessments scheduling and- resource i allocation:

"Abdits of selected aspects of operational phase activities are performed with a -

frequency commensurate with safety significance and in such a manner as t o' ,

. assure that an' audit of all safety,..related,/ 3 "

functions ..is complet'edisithin a period ofr - Ir ". *-

two (2) years., The audit system is reviewed -

periodically and revised as necessary to l assure coverage comniensurate with current l

! and planned a,ctivities."

l The naming of Executive Vice President, Power i Generation reflects the realignment of reporting authority for the NSRB as discussed in draft revised ,

CNS FSAR Chapter 13 and in the QA Topical Section 17.3. l l This change is administrative, since the functions of  ;

the NSRB are unaf fected but we also believe this change is philosophically correct and acceptable.

]

l 1

! These. changes do not alter the. function nor diminish '

l_

the' quality of the Audit Program. Therefore, they should be considered acceptable. ,

i

" 5.2.10 These

. changes reflect realignment of authority or responsibility as discussed above and described in proposed TS 6.2.1. These reporting requirements to Senior Management are also discussed in the revised QA Topical Report in Section 17.3.3 "Self Assessment".

These changes are administrative only and therefore are acceptable.

6.6.1 These changes reflect realignment of authority or responsibility as discussed above and described in proposed TS 6.2.1, and draft revised CNS FSAR, Chapter

. 13.

! The key supervisory titles have been revised to reflect l the: reorganization and their re-naming. The changes

are purely administrative and should be acceptable.  ;

i 6.7.1 The changes in (a) and (c) reflect realignment of

). authority or responsibility to the site as discussed

i i

^

above and described in TS 6.2.1, and draft revised CNS j e  !

' 2-7 1

i i

i 1

l

m. _.- _ __ ._ m_ . . _ _ .- . _ _ . . . _ . . . _ . . . _ . _ _ _ _ ._ _

t f ,j " ^

s UNITED STATES

^

e COMMISSION gggg g@@@,g

%7@V,8 May 7, 1992 Docke*t Nos. ~50-413 and 50-414 r

l Mr. M. S. Tuckman Vice President, Catawba Site-Duke Power Company 4800 Concord Road York, South Carolina 29745

SUBJECT:

i (TACS M82006/M82007) ISSUANCE OF AMENDMENTS - CAI '

l The Nuclear Regulatory Commission has issued the enclosed Amendme

! to Facility Operating License NPF-35 and Amendment No. 90 .

Operating License NPF-52 for the Catawba Nuclear to Facility Station, Units 1 and!

The amendments

. February response consist to'your application of changes to the Technical Specifications dated December 17, 1992. 18, 1991, as supplemented on The amendments revise the TS to reflect a reorganization of the Duke Company (OPC).

management of nuclear activities to each of DPC's three n facilities, including the Catawba Site.

A copy of the related Safety Evaluation is also enclosed.

Issuance will be included in the, Commission's. biweekly A Notice of Federal Renister notice.

Sincerely, .

c.

5 obe

/h(L '

E. Martin, Senior Project Manager r

} -

Project Directorate 11-3 l Division of Reactor. Projects I/II -

Office of Nuclear Reactor Regulation

Enclosures:

1. . Amendment No. 96 to NPF-35 2.

j Amendment No. 90 to NPF-52

3. ' Safety Evaluation '

j- .

cc w/ enclosures: .

See next page 1

i i

'l et 4

ATIACW R4T 2 y

4

~

,JNISTRATIVE CONTROLS _ _ ,

REVIEW l

! i 6.5.2.8 The NSRB shall be respo: ible for the review of:

a. The safety evaluation for: (1) changes to procedures, equipment, or  !

systems, and (2) tests or experiments completed under the provision of Section 50.59, 10 CFR te verify that such actions did not consti-tute an unreviewed safety question.

h- Proposed changes to procedures, equipment, or systems which involve

. an unreviewed safety question as defined in Section 50.59, 10 CFR, i i

c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR;

d. Proposed changes in Technical Specifications or thi: Operating License; j

e. Violations of Codes, regulations, orders, Technical SpecificE ienh, I lic.ense requirements, or of internal procedures or instructions l having nuclear safety significance;

f. Significant operating abnormalities or deviations from normal and j expected performance of unit equipment that affect nuclear safety; j

g. All REPORTABLE EVENTS;  ;

h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components '

that could affect nuclear safety;

i. Quality Verification Department audits relating to station operations l  ;

and actions taken in response to the.se audits; and j; ' Reports of activities performed under the provisions of i Specifications 6.5.1.1 through 6.5.1.12. l AUDITS 6.5.2.9 Audits of rite activities shall be performed undt.r the cognizance of l the NSPB. These audits shall encompass:

a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditions; l

b. The performance, training, and qualifications of the entire station staff; ,

i .

CATAWBA - UNITS 1 & 2 6-10 Amendment No. 96 (Unit 1) l Amendment No. 90 (Unit 2) r 1

t L '

,rffNXSTRATIVE CONTROLS

\  : '

l AUDITS (Continued) c.

The results of actions taken to correct deficiencies occurring in unit equipment, structures, systems, or method of operation that affect nuclear :afety; l

.' d.

The' performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR Part 50; l

e.

The Emergency Plan and implementing procedures; '

l f.

The Security Plan and. implementing procedures;

{

T' The Facility Fire Protection programmatic controls including the

implementing procedures; I.I

, b.

The fire protection equipment and program implementation uti-lizing ij either a qualified offsite licensee fire protection engineer or an out-side independent fire protection consultant. An outside independent  !

L.~. i fire protection consultant shall be used at least every third year; 1

,i .

The Radiological Environmental Monitoring Program and the results thereof; Ii

j. .

The DFFSITE DOSE CALCULATION MANUAL and implementing procedures; I4

k. i The PROCESS CONTROL PROGRAM and implementing procedures for proce and packaging of radioactive wastes; lj,

1.  !

The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring; and l m.

Any other area of site operation considered appropriate by the NSRB or the Executive Vice President, Power Generation.

RECORDS 6.5.2.10 Records of NSRB activities shall be prepared, approved, and distributed as indicated below:

a.

Minutes of each NSRB meeting shall be prepared, approved, and forwarded to the Senior Vice President, Nuclear Generation and to the Executive '

Vice President, . Power Generation within 14 days following each meeting; l

l t

i i

i CATAWBA - UNITS 1 & 2 6-11 Amendment No. 96 (Unit'1)

Amendment No.90 (Unit 2)

+ - + - - - na w y, s -.-,

We find these' changes acceptable as they reflect the revised organization and.the reassignment of responsibilities. The change in approval authority meets the appropriate acceptance criteria of Sr.ction 13.5.1 of NUREG 0800, the Standard Review Plan.

h. Section 6.5.2 - Nuclear Safety Review Board (NSRB) - The titles Vice President, Nuclear Production, Nuclear Production Department, Quality Assurance Department, and Executive Vice President, Power Group have been

. replaced to reflect the revised organization. In Subsection 6.5.2.2 the cualification requirements for NSRB members has been revised to allow, in- '

special cases, an individual with ten years experience in a specific technical area. In Subsection.6.5.2.9, Audits, the licensee has relocated the audit frequency from the audits require'd by this subsection. Audit frequency requirements are now addressed in the Duke Quality Assurance Topical and are performance based'on the safety significan:e and extent of the activities except those for the Emergency and Security Plans as discussed below.

We find these changes acceptable as they reflect the revised organization and reassignment of responsibilities, the appropriate acceptance criteria of Section 13.4 of NUREG 0800, the Standard Review Plan, and the commit-ment to performance based audits in their revised Quality Assurance Topical Report, a document controlled in accordance with 50.54(a).

i. Section 6.6 - Reportable Event Action - The review of reportable events has been revised to reflect the new titles in the revised organization.

We find these changes acceptable as they reflect the revised organization.

j. Section 6.7 - Safety Limit Violation - The titles in this section have been revised to reflect the revised organization.

'e W find these changes acceptable as the'y reflect the revised organization.

k. Section 6.8 - Procedures and Programs - The approval authority for proce-dures and temporary changes to procedures has been revised by deleting specific titles and specifying a predesignated level of management.

We find this change acceptable as it meets the appropriate acceptance criteria of Section 13.5.1 of NUREG 0800, the Standard Review Plan.

We find the above changes to the Administrative Controls Section of the Technical Specifications, as described in the DPC letter dated December 18, 1991, and as revised by letter dated February 17, 1992, acceptable.

t i

i

ADMINISTRATIVE CONTROLS REVIEW 6.5.2.8 The NSRB shall review:

a. The safety evaluations for: (1) changes to procedures, equipment, or systems, and (2) tests or experiments completed under the provision of Section 50.59, 10 CFR to verify that such actions did not constitute an unreviewed safety question; 4 1

b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR; l

l l c. Proposed tests or experiments which involve an unreviewed safety j

question as defined in Section 50.59, 10 CFR; .l 1 '

! d. Violations of Codes, regulations, orders, Technical Specifications, j license requirements, or of internal procedures or instructions

having nuclear safety significance; i

! .e. Significant operating abnormalities or deviations from normal and j

expected performance of unit equipment that affect nuclear safety; 1

i f. All REPORTABLE EVENTS;

} 1 j g. All recognized indications of an unanticipated deficiency in some i l aspect of design or operation of structures, systems or components ]

=

that could affect nuclear safety; "

4

h. Quality Assurance Program audits relating to station operations and  ?

actions taken in response to these audits; and _

i. Reports of activities performed under the provisions of J Specifications 6.5.1.1 through 6.5.1.10.

AUDITS 6.5.2.9 Acdits of site activities shall be performed under the cognizance of the NSRB. These audits shall encompass:

a. The conformance of unit operation to provisions contained within the Technical Specifications and applicable license conditiens;

b. The performance, training, and qualifications of the entire station staff; l-ATTACHMENI' 3

! ADMINISTRATIVE CONTROLS i

j  ;

AUDITS (Continued) l,

{ c. The results of actions taken to correct deficiencies cccurring in I unit equipment, structures, systems, or method of operation that affect nuclear safety;

d. The perfornance of activities required by the Operational Quality i

) Assurance Program to meet the criteria of Appendix !3,10 CFR Part 50;

! e. The Emergency Plan and implementing procedures;

f. The Security Plan and implementing procedures; l g. The Facility Fire Protection programmatic control.s including the implementing procedures; 4

h. The fire protection equipment and program implementation utilizing either a qualified offsite licensee fire protectico engineer or an outside independent fire protection consultant. An outside indepen-

! dent fire protection consultant shall be used at least every third a year;

! i. The Radiological Environmental Monitoring Program and the results i

thereof; j.

The 0FFSITE DOSE CALCULATION MANUAL and implementing procedtres; i

! k. The PROCESS CONTROL PROGRAM and implementing procedures for l

i SOLIDIFICATION of radioactive wastes; l 1. The performance of activities required by the Quality Assurance Program for effluent and environmental monitoring and;

~

m. Any other area of site operation considered appropriate by the NSRB i

1 or the Senior Vice President, Nuclear Generation.

AUTHORITY i

l 6.5.2.10 The NSRB shall report to and advise the Senior Vice President, 1

Nuclear Generation on those areas of responsibility specified in Specifications 6.5.2.8 and 6.5.2.9.

3  :

l l

l

l l

6.1.3 A Audits Audits of Site activities shall be performed under the cognizance of the NSRB. These audits shall encompass:

a.

De conformance of station operation to provisions contained within the Technical Specifications and applicable facility operating license conditions.

h.

The performance, training and qualifications of the station staff.

e.

The results of actioris taken to correct de0ciencies occurring in equipment, structures, systems or methods of operation that atfect nuclear safety.

.d .

The performance of activities required by the quality assurance program to meet the criteria of Appendix B to 10 CFR 50.

e.

The station emergency plan and implementing procedures.

f.

The station security plan and irmlementing procedures.

g.

Any other area of station eperation cnnsidered appropriate by the NSRB or the Senior Vice President, Nuclear Generation.

h.

He station Gre protection program and implementing procedures.

i.

The Offsite Dose Calculation Manual and implementing procedures.

j. De Radiological Environmental Monitoring Program and the results thereof k.

The Process Control Program and implementing procedures for solidi 0 cation of radioactive W astes, l.

The performance of activities required by the Quality Assurance Program to meet the criteria of Regulatory Guide 1.21 Revision 1, June 1974 and Regulatory Guide 4.1 Revision 1, April 1975.

ATTACINENT 4 Oconee 1. 2, and 3 6.1-5 Amendment Numbers 208, 208, 205 I

l . 17. QUALITY ASSURANCE INTRODUCTION l

Duke Power Company maintains full responsibility for assuring that its nuclear power plants are designed, constructed, tested and operated in conformance with good l engineering practices, applicable regulatory requirements and specified design bases and f I in a manner to protect the public health and safety. To this end Duke has established and implemented a quality assurance program which conforms to the criterla established in ]

Appendix B to 10CFR, Part 50, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" published June 27,1970 (35 F. R. 10499) and amended September 17,1971 (36 F. R.18301) and amended January 20,1975 (40 F. R. 3210D).

This topical report is written in the format of a Safety Analysis Report (SAR) Chapter 17,

! " Quality Assurance", in accordance with Revision 2 of the NRC's Regulatory Guide 1.70, j " Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants - LWR

! Edition': and subsequent NRC guidelines. The quality assurance program described herein ,

is applicable to ali Duke nuclear po.wer plants as referenced by Chapter 17 of the plants'  !

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. l This Topical Report describes the Quality Assurance Program for those systems, l components, items, and services which have been determined to be nuclear safety related j

(QA Condition 1). In addition, Duke's Quality Assurance Program provides a method of applying a graded Quality Assurance Program to certain non-safety ralated systems, components, items: and services. These are classified as QA Conditions 2. 3, or 4. This method involves defining a Quality Assurance " Condition" for each level of quality assurance required. These will be designated as "QA Condition "

. The quality of

systems, components, items, and services within the scope of QA Conditions 1,2,3, and 4 j is assured commensurate with the system's, component's, item's, or service's importance l

to safety. The following conditions have been defined.

QA Condition 1 covers those systems and their attendant components, items, and services which have been determined to be nuclear safety related. These systems are detailed in the Safety Analysis Report applicable to each nuclear station. The Topical Report applies in its entirety to systems, components, itens, and services identified as QA Condition 1.

QA Condition 2 covers those systems and their attendant components, items, and structures important to the management and containment of liquid, gaseous, and solid radioactive waste. <

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! QA Condition 3 covers those systems, components, items, and services which are j important to fire protection as defined in the Hazards Analysis for each station. The

! Hazards Analysis is in response to Appendix A of NRC Branch Technical Position APCSB l 9.5-1.

8 QA Condition 4 covers those seismically designed / restrained systems, components, and f structures whose continued functions are not required during and after the seismic event.

t The general scope of these systems, components, and structures, identified as Seismic j Category 11 (SCli) are defined in Regulatory Guide 1.29, Seismic Design Classification.

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17.3.3 SELF ASSESSMENT 17.3.3.1 Methodology

. The Self-Assessment process encompasses internal and corporate audits, independent i review committee activities, in-plant reviews, and other independent assessments. This l process is to corifirm to management that activities affecting quality comply with the quality assurance program and that the quality assurance program has been implemented effectively. These functions are directed by the Manager, Nuclear Assessment & Issues Division and the Managers of Safety Assurance. The assessment activities are performed in accordance with instructions and procedures by organizations independent of the areas being assessed. Organizations performing self-assessment activities are technically and performance oriented, wi.th the primary focus on the quality of the end product and secondary focus on procedures and processes.

17.3.3.2 Assessment 17.3.3.2.1 Nuclear Safety Review Board The Senior Vice President, Power Generation Group, appoints a Nuclear Safety Review Board (NSRB) to serve as a nuclear safety review and audit backup to the normal operating organization. The Nuclear Safety Review Board reviews proposed tests and experiments, proposed station modifications, and proposed changes to procedures, when such involve an unreviewed safety question. Also, the Board reviews reportable occurrences and violations of a station's technical specifications and makes recommendations to prevent recurrence. Functions, operations and responsibilities of the NSRB are detailed in Chapter 6 of the technical specifications for each station.

l 17.3.3.2.2 Plant Operations Review Committee l The Site Vice Presidoiit appoints a Plant Operations Review Committee (PORC) to review l selected nuclear safety related issues. The PORC is composed of specified senior j members of the site management team most responsible for the safe and reliable l operation of the station. The PORC also reviews the effectiveness of corrective actions l taken for specified reportable events.

17.3.3.2.3 Internal Audits Duke's Quality Assurance Program requires a comprehensive system of planned and periodic internal audits for all phases of station operations and supporting activities.

All organizational units conducting quality assurance activities are evaluated with a system l

of audits. These audits are performed to determine the effective implementation of all applicable criteria of 10CFR 50, Appendix B. Periodic audits of activities or records of l processes (e.g., welding, maintenance, development of design, record management, or I system testing), to verify compliance and effectiveness of the implementation of the Quality Assurance Program are performed. Internal audits are initiated under the direction of the Manager, Regulatory Audits. The Manager, Nuclear Assessment and Issues Division may initiate special audits or expand upon the scope of an existing audit. The scope of each audit is determined by the responsible Lead Auditor, under the direction of the Manager, Regulatory Audits Section. Additionally, the scope of audits performed under the cognizance of the Nuclear Safety Review Board (NSRB) are reviewed for compliance with NSRB requirements by the NSRB staff. The lead auditor directs the audit team in Amendment 19 17-42

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developing checklists, instructions, plans and in the performance of the audit. The audit shall be conducted in accordance with checklists; the scope may be expanded upon by the audit team during the audit, if needed. One or more persons comprise an audit team, one of whom shall be qualified lead auditor.

4 Audits of selected aspects of operational phase activities are performed with a frequency commensurate with safety significance and in such a manner as to assure that an audit of all QA Condition 1 functions is completed within a period of two (2) years. The audit system is reviewed periodically and revised as necessary to assure coverage commensurate with current and planned activities.

The audit team concludes with a post-audit conference between the audit team and responsible management. The conference includes a brief discussion of audit results, including any deficiencies and recommendations. The audit results are documented in a report.

Within thirty (30) days of the post-audit conference, a report is issued to the responsible management with copies sent to the Vice President of the audited Site or department and other management as appropriate. .

Within thirty days after receipt of the audit report, responsible management replies in writing to the Manager, Regulatory Audits Section, describing corrective action and an implementation schedule. The established electronic corrective action process may be used to convey this information. When necessary, after receipt of the management reply, a re-evaluation is made to verify implementation of corrective action. This re-evaluation is documented. The audit is closed with a letter to the responsible management. All pertinent correspondence, checklists, and reports related to the audit are fliled.

Audit data are analyzed and the resulting reports on the effectiveness of the QA program, including any quality problems, are reported to management through the Inte0 rated Safety Assessments, for review and assessment. This data is also used to modify the audit schedule as necessary to assess potential weaknest,es.

l 17.3.3.2.4 Safety Assurance I

Safety Assurance, through the Safety Review Group, and Regulatory Compliance, monitors the day to day and overall performance of each nuclear station.

The Safety Review Group investigates significant occurrences and problems to determine the root cause(s) and to identify actions necessary to prevent recurrence. The Safety Review Group also performs in-plant reviews including checking documents, records, and l work in progress to determine that quality assurance requirements are being properly l

implemented. Work in progress includes such activities as welding, maintenance, system testing, station operation, station modifications, refueling, and record management. These investigations and reviews are documented in reports and submitted to Management, NRC,

, and other authorities as appropriate. The Safety Review Group also coordinates the

development of corrective actions for significant occurrences and problems.

The Regulatory Compliance Group is responsible for the preparation, issue, and

, maintenance of all site licensing documents; providing site personnel with interpretations on the licensing documents, the preparation and submittal of violation responses, and coordination of NRC inspection activities on site.

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