ML20151L028

Provides Response to NRC Request for Addl Info Re TS Change,Relocating Administrative Controls Related to QA to Ufsar,Per NUREG-0737

ML20151L028
Person / Time
Site:	Beaver Valley, Rancho Seco
Issue date:	07/29/1997
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 TAC-M98222, TAC-M98223, NUDOCS 9708060219
Download: ML20151L028 (5)

Text

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

vor Valley Power Station

, Stuppingport. PA 15077-0004 i

$$"NEssiani July 29,1997 rox$$lU$$

l E4ll::',Oehn

. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

Subject:

Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73

! Response to Request for Additional Information l Technical Specification Change to Relocate Admin Controls (TAC Nos. M98222 and M98223)

This provides our response to an NRC request for additional information dated July 1, 1997, concerning a technical specification change that would relocate l

administrative controls related to quality assurance to the UFSAR. The proposed change was submitted by our letter dated March 14, 1997. The NRC specifically requested i additional information on how the minimum Independent Safety Evaluation Group (ISEG) composition provisions of NUREG-0737 Iteia I.B.I.2 will be satisfied.

The attachment provides additional information on how Duquesne Light Company will satisfy the intent of NUREG-0737 for minimum ISEG composition provisions. If you have any questions, please contact Mr. J. Arias, Director, Safety & Licensing l Department, (412) 393-5203.

l Sincerely,

, x Sushil C. Jain

'x g i

i i

c: Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Adminisirator Mr. D. S. Brinkman, Sr. Project Manager

/d[

\

i g

! 9708060219 970729 j PDR ADOCK 05000334 DELIVERING

< P PDR gyg(;7y Q(',0 V J J

. fNERGV

N ((\,\$klkk!!!!kk$$ k! .

4

. Attmchment

. Additional Information for Technical Specification Chance -

To Relocate Administrative Controls Related to Ouality Assurance I I

Backaround  !

NUREG-0737 provided initial guidance and clarification in 1980 to implement a comprehensive and integrated plan 'to improve safety at power reactors following the accident at Three Mile Island Unit 2.

l NUREG-0737,Section I.B.I.2 provided a description of general guidance to establish an Independent Safety Engineering Group (ISEG). This new group was not to replace the  ;

plant operations review group (called Onsite Safety Committee for the Beaver Valley Power Station) and the utility's independent review and audit group (called the Quality l Services Unit for the Beaver Valley Power Station). Rather it would be an additional independent group which will increase the available technical expertise located onsite and will provide continuing, systematic, and independent assessment of plant activities.

As stated in NUREG-0737, "The principal function of the ISEG is to examine plant operating characteristics, NRC issuances, Licensing Information Service advisories, and other appropriate sources of plant design and operating experience information that may  ;

indicate areas for improving plant safety. The ISEG is to perform independent review i and audits of plant activities including maintenance, modifications, operating problems, and operational antlysis, and aid in the establishment of programmatic requirements for plant activities. Where useful improvements can be achieved, it is expected that this group will develop and present detailed recommendations to corporate management for l such things as rev' sed procedures or equipment modifications." NUREG-0737 also I states "The staff intends to review this activity ... to determine its effectiveness and to ,

see whether changes are required."

Justification for Proposed Channe to the Technical Specification Criteria on ISEG The Beaver Valley Power Station implemented an Independent Safety Evaluation Group in 1987, as per Beaver Valley Power Station Unit No. 2 Technical Specification 6.2.3.

Since this time, an ISEG has functioned to implement the ISEG concept required by l NUREG-0737 as described above. Beaver Valley Power Station ISEG has reviewed and

! evaluated unit operating characteristics, NRC issuances, industry advisories, Licensee

! Event Reports, and other sources of unit design and operating experience information which may indicate areas for improving safety. ISEG has reviewed all issues for both Beaver Valley Power Station units since their design and operation are very similar and has provided detailed recommendations to station management for revised procedures, equipment raodifications, maintenance activities, operations activities, or other means of

improvmg operational safety.

i 4

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

. ' Attachment

' Additional Information for Technical Specific.ation Change

,to Relocate. Administrative Controls Related to Quality Assurance Page 2 In the ten years since ISEG has been formed and functioning at the Beaver Valley Power  :

Station, Duquesne Light Company has recognized the usefulness of ISEG and will ,

continue to retain this function. Duquesne Light Company also recognizes that the need for ISEG actions and involvement will vary from time to time contingent upon the units' operating conditions and emergence of NRC and industry issues. The current criteria for ISEG is to maintain a staff of five dedicated, full-time engineers located on site. The i staffing requirements for five dedicated engineers is burdensome because it restricts the l

capability to utilize resources to their maximum advantage and does not continually  ;

l result in an increase in the protection afforded to the health and safety of the public L commensurate with the level of resources required by the current Technical Specification ,

i limit on staffing.  !

Duquesne Light proposes to maintain the ISEG function by retaining a core of dedicated ,'

full time ISEG engineers to provide continuing ISEG review and evaluation of plant l issues. Station management would also retain the capability to add temporary manpower  !

l 'at those times where increased ISEG resources would prove beneficial for evaluating '

l issues and recommending plant safety improvements. Thus ISEG manpower resources ,

l would vary consistent with the efficient use of site resources to address both continuing i j- and emergent plant issues. This proposed change would provide flexibility to i j accomplish the ISEG review function without compromising the overall ISEG purpose, l scope or thoroughness of independent technical reviews. A core group of three d-dicated full time personnel will continue to be utilized to accomplish the ISEG fenction, with the option for management to temporarily assign additional personnel to ,

ISEG during those times when additional ISEG review and evaluation is warranted. To I

assure independent findings, temporarily assigned personnel will report to the ISEG supervisor during their assignment.

The Beaver Valley Power Station I5EG has been evaluated to be conducting effective reviews and evaluations. Duquest e Light believes that the proposed ISEG staffing arrangements would meet the intent < f the NUREG-0737 criteria by continuing to retain the intended purpose and scope of the type of group described in NUREG-0737, while allowing personnel resource flexibility. The ten years experience that the Beaver Valley Power Station has accumulated with the ISEG organization is the' basis for determining l

that the alternative approach for the Beaver Valley Power Station ISEG staffing would l continue to be effective. Thus Duquesne Light Company believes that the proposed

! staffing arrangement would continue to provide an effective independent evaluation  !

l capability necessary for the protection of the health and safety of the public as described j- in NUREG-0737.

i 1

L i

i

I

.- i

' Attachment I

^

' Additional Information for Technical Specification Change

.to Rel'ocate Administrative Controls Related to Quality Assurance Page 3 Additional Assessments; Programs and Channes i i

The Beaver Valley Power Station site organization has undergone many changes smce j the ISEG was originally assembled in 1987. Many of the ISEG functions identified in l

__ NUREG-0737 are now redundant to functions performed by other groups in the Beaver -

Valley organization. Assessment processes have been implemented to review and l evaluate the design and configuration control programs and processes. These assessment ,

and oversight activities are in addition to the review and approval processes that are  !

incorporated as integral parts of the design basis control processes. Self-assessments are j initiated to identify enhancements intended to further improve general performance and  ;

efficiency. They are also performed as a result ofidentification of recurring findings or i adverse trends. The Condition Report Program provides a method for any employee to 1 promptly identify and document potential adverse conditions related to the design, l maintenance or operation of the plant.

In January of 1997, the operating experience review function was revised. Relevant i' industry experiences and issues documented in NRC generic communications, vendor supplied engineering and technical information, equipment quaiification data, and industry developed information became the responsibility of the Safety and Licensing Department with staff dedicated to the investigation of issues. The information is j reviewed and appropriate corrective actions are taken and programs, procedures and j processes are modified to address these industry issues and concerns.  !

I Since its formation in the first quarter of 1993, Engineering Assurance has been reviewing and evaluating design and configuration control activities to improve the  ;

overall quality of engineering processes and products. These reviews provide critical l assessments of unit organization and a review of selected area s for the identification of )

j- programmatic issues. l Quality Services performs audit, surveillance inspection, examination and assessment activities to independently evaluate design and configuration control programs, processes and activities. The oversight processes include review of major program activities j related to design, configuration control and evaluation of related programs, processes and activities. On December 2,1996, Quality Services implemented oversight responsibility for the self-assessment process. Quality Services determines whether the self-assessment

! process is being effectively implemented and, as necessary, that identified corrective ,

i actions for significant self-assessment findings are implemented and followed.  !

j A new Condition Report Program was implemented on January 1,1997, including a i procesF for investigation of the extent of the adverse condition and trending and analysis j of data. In addition, effectiveness reviews are performed to verify that the correct I

acticas have been instrumental in correcting the condition identified.

i a

, - - . . - , . . . _ _ - ,, , ,x, r_ - - - -- +

' Attachment

' Additional Information for Technical Specification Change j ,

to Relocate Administrative Controls Related to Quality Assurance Page 4 1 l

l The experience gained over tne last ten years through organizational changes and process improvements has resulted in confidence that the ISEG function will continue to be ,

fulfilled. Industry operating experience is receiving an increased level of review. Self- l assessments and-their effectiveness are the subject of ongoing review with Quality Services overview. Should the need arise, the staffing of the ISEG will be increased to  ;

accommodate any increase in the review and evaluation of pertinent issues at Beaver Valley Power Station. Based on the above, the proposed staffing arrangement will ,

continue to provide an effective independent evaluation capaouny for the protection of the health and safety of the public.

l f

i i I

I i

l l 4

1 1

l t

. . _ . , - . . . __ - . , - - . _ . _ _ _ _. . - _ .