ML20151K973
| ML20151K973 | |
| Person / Time | |
|---|---|
| Issue date: | 05/24/1985 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20151K612 | List:
|
| References | |
| FOIA-87-866 NUDOCS 8506270540 | |
| Download: ML20151K973 (5) | |
Text
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g) h May 24,1985 MEMORANDUM FOR:
James M. Taylor, Director Office of Inspection and Enforcement FROM:
J. Nelson Grace, Regional Administrator
SUBJECT:
ASSESSMENT OF REGION II QA PROGRAM REYIEWS i
An assessment of Region II activities associated with review and approva staff and documented in a memorandum to this office April 19,19B5.
John's personal knowledge and understanding of the NRC proces of approving licensee QA programs resulted in a highly professional a assessment of our activities.
Region 11 staff implementing the regulations and IE program guid The assessment refers to the License Fee Management Branch accounting for fee-bearable manpower expended on QA program (chang)es.
LFMB and methods of power expended on QA program revisions, this is a Even though i
Regulatory Information Tracking System (RITS) should be revised capture this time in a manner that can be used by LFNB.
spondence to each Regional Office indicates that fees v111..txttRecent LFMB j
time expended on licensee topical QA programs whereas license.pgggq(,fx.all program description in FSAR Chapter i
17 will nniv es having a QA In our view, be charoed for changes
'r.gguestino Drior NRC aoproval.
programs was intended to mean vendor topicals, not licensee topicalsthe r believe that fees should be charged for 411 QA program changes w We prior NRC approval.
or in FSAR Chapter 17 makes no difference in the effor be used as a basis for charging fees.
difficulties in the fee accounting system.take the lead in prom er The assessment identifies two areas where additional guidance is nee achieve better consistency.
We agree your effort to resolve these concerns.with these observations and fully support copies of all licensee QA program descriptions.FSAR upda We believe that high-quality assessments of this type are beneficial to Region 11 staff.
If we can be of further assistance, please contact me.
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, J. Nelson Grace '
III. Assessment Findings Region II's present review process is as follows:
Each QAPD change enters the Region II mail room where it is logged in and i
sent, with other docketed information, to the Division of Reactor Projects (DRP).
DRP sends all QA-related submittals to the QA Program Section where the reviews of QAPD changes are performed.
QA Program Section Chief assigns a prfacipal reviewer to review QAPD changes agains,t the latest NRC accepted QAPD.
Reviewer reviews and determines if any identified changes have reduced previously accepted QAPD controls.
Reviewer does not routinely review the revised QAPD to ensure that additional changes have not occurred beyond those identified by the licensee.
l However, if a major revision is submitted, a complete review i
usually takes place.
Reviewer prepares and issues a request for additional information to the licensee through phone calls, meetings, or formal letters.
Reviewer reviews additional information supplied by the licensee in response to the request.
Results of the reviews are discussed with the QA Program Section Chief to determine consistency and adequacy of the review.
Significant issues raised during reviews are usually discussed with the IE QA Branch.
IE QA Branch routinely requested to participate in meetings with the licensee where important QA concerns are to be discussed.
Reviewer prepares acceptance letter to licensee within 60 days of receipt of change unless delay is caused by the request for additional information.
Division of Reactor Projects issues acceptance letter to the licensee.
Adeouacy of Region II Review Process The overall review process of QAPD changes was found to be well organized and carried out in a timely and acceptable manner.
Each QAPD change was reviewed against the previously NRC accepted QAPD, Any reduction or deletion of previcus QA commitments were considered by Region II as a reduction to the QAPD.
Licensees were requested to justify all reductions and deletions before determining acceptability of the QAPD change.
The reviews were well documented with copies of letters to the licensee concerning requests
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J. Nelson Grace,
for additional information, results of meetings, extensions of review time beyond the 60 days, and final acceptance of the QAPD changes.
Most reviews that resulted in a request for additional information were interfaced with the IE QA Branch for comment.
Members of the IE QA Branch have participated in meetings with Region II and licensees to support Region II's positions and assist in the resolution of outstanding issues.
Timeliness of the Reviews Reviews were generally completed within the required 60 day time frame except where the QAPD required clarification or additional information.
The time expended in reviewing each QAPD change was uniquely identified by Region II, however, Region II does not, as yet, separate the accountability of the review between those that constitute a reduction to the QAPD (which would be fee recoverable) and those that do not.
The License Fee Management Branch (LFMB) memorandum of February 7,1985 (Enclosure 3), was discussed with Region 11 relative to the reporting guidelines of QAPD change reviews.
The Region II QA Program Section is considering an accounting method that would satisfy the LFMB memorandum concerning the review of QAPD changes.
Staffing The Region II QA Program Section is presently staffed with 10 reactor inspectors of which four senior members are involved in reviewing QAPD changes as needed.
Region II appears to be expending the necessary resources to effectively complete the review of QAPD changes in an acceptable manner.
Consistency and Need for A,dditional Guidance Region II reviewers are performing consistent reviews in regard to the depth of review and the degree and method of documenting the results.
Concerns raised in the Region I and Region III assessment were similarly found in Region II and it appears that further guidelines will be necessary to improve the review.
'These concerns are as follows:
1.
Changes to caterial referenced in the QAPD (i.e., Q-lists, etc. )
are not, in all cases, being reported to Region II as part of the QAPD. The intent of the QAPD change rule was to include this reference material.
An IE Information Notice may be necessary to correct this lack of reporting.
2.
Certain licensees are submitting QAPD changes in the annual FSAR updates and not separately reporting QAPD changes to the appropriate Regional Office.
It appears appropriate for the Regional Office to update their QA program review files by incorporating these QAPD ch6nges. This would provide a current reference of the QAPD against which future QAPD changes can be reviewed.
This will be addressed further in the summary report.
Region 11 expressed concern that the draf t Inspection Procedure 35001 "Inspection Procedure for Reporting of Changes to Quality Assurance Programs" transmitted to the Regional Offices in J. M. Taylor's memorandum of July 11, 1983 and February 29, 1984 had not been updated incorporating the comments provided by the Regional of fices and formally released.
Region II's comments on this procedure have been provided in their memorandum of August 5,1953
(
J. Nelson Grace
~% 4-(Enclosure 4).
The IE QA Branch will update the procedure after all Regions are assessed and incorporate all appropriate suggested changes before final release.
Conclusion Region II is currently performing an adequate and timely review of QAPD changes consistent with the 10 CFR 50.54 and 50.55 change rule and draft IE Inspection Procedure 35001.
Several areas of generic concern will be further enluated and discussed with other Regional Offices to determine the netd for and extent of any additional guidance for licensees or the Regional Offices.
Final recommendations will be provided in a Summary Report at the conclusion of the five Regional Office assessments.
i Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement
Enclosures:
1.
Assessment Plan 2.
Attendance at Entrance / Exit Meetings and QAP Packages Evaluated 3.
LMFB Reporting Guidelines 4.
Region II Comments on Ins;e-tion Procedure for Changes to QA Programs Distribution:
DC5 QAB Reading DQAVT Reading
'JMTaylor, IE RHVollmer, IE BKGrimes, IE GTAnkrum, IE JLMilhoan, IE JWGilray, IE WBelke, IE JGSpraul, IE
- For previous concurrences see attached ORC IE: QUAB IE:QUAB IE: QUAB I,
.0 IO /blR
'JWGil ray: hmc "JLMilhoan
- GTAnkrum Grimes R o,Imer JP ayfor 04/08/85 04/09/85 04/11/85 04/11/85 0 /g /85 04/y /85 l
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ENCLOSURE i j
ATTENDANCE AT ENTRANCE / EXIT MEETINGS AND QAP J. N. Grace Regional Administrator-(l) (2)
A. Gibson Operations Branch Chief C. Upright Quality Assurance Section Chief-(1) (2)
A. Belisle Reactor Inspector (3)
L. Jackson Reactor Inspector (3)
R. Wright Reactor Inspector (3)
L. Foster Reactor Inspector (3)
C. Smith Reactor Inspector (3)
(1) Entrance Meeting March 19 (2) Exit Meeting March 20 (3) Personnel Interviewed PACKAGES EVALUATED Duke Power QA Topical Florida Power and Light Company QA Topical Summer Hatch Crystal River
.