ML20153B822

Safety Evaluation Accepting Changes to USAR Section 13.4.3, 17.2.1.3.2.2,17.2.1.3.2.2.3 & App 1A

ML20153B822
Person / Time
Site:	Perry
Issue date:	09/16/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20153B807	List: ML20153B803 ML20153B822
References
NUDOCS 9809230252
Download: ML20153B822 (3)

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j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001 4.....,o SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOUR CHANGES OF THE INDEPENDENT SAFETY ENGINEERING GROUP ElRST ENERGY (TAC NO. MA3325) i j

E2RRY NUCLEAR POWER PLANT DOCKET NO. 50-440

1.0 INTRODUCTION

i By letter datad July 22,1998 and supplemented on September 1,1998, pursuant to 50.54(a),

FirstEnergy submitted proposed revisions to the quality assurance program for the Perry 4

Nuclear Power Plant (PNPP). The proposed changes included (1) The reporting point of the Independent Safety Engineering Group (ISEG) will change from the Director, Perry Nuclear Services Department to the Manager, Quality Assurance Section; (2) the ISEG function to review and assess operation and maintenance audits will be transferred to the Company Nuclear Review Board; (3) ISEG membership will be reduced from five to four members; and l

(4) the ISEG qualifications wll be revised.

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.0 EVALUATION l

The transfer of the ISEG reporting point from the Director, Perry Nuclear Services Department 1

to the Manager, Quality Aswrance Section (QAS) modifies the Updated Final Safety Analysis Report (USAR) Section 17.2.1.3.2.2 which describes responsibilities of the Manager, QAS. The j

remaining changes alter the current descriptions of the functions and responsibilities of the ISEG made in USAR Appendix 1A, item I.B.1.2, and Sections 13.4.3 and 17.2.1.3.2.2.3.

2.1 Reoortina Point Transfer from the Director. Perry Nuclear Service Deaartment (oNSD) to the Manaaer. QAS In the current USAR, the ISEG reports to the Director, Perry Nuclear Serv.ces Department. However, in the proposal, ISEG will report to the Manager, Quality Assurance Section (QAS), who is also the manager of the Quality Assurance and Quality Control Units. As part of this organization, ISEG will still maintain a separation and independence from the o -site enginerring and technical organization. The QAS manager has a direct reporting relationship to the site Vice President. Although the staff wC report to the QAS manager, ISEG will not report to a supervisor responsible for quality assurance audits or surveillances. The reduction in commitnient is acceptable because ISEG will maintain a separate schedule and the full-time, dedicated ISEG staff has adequate freedom to perform the quality a:surance oversight function.

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! l 2.2 ISEG Function to Review and Assess Ooeration and Maintenance Audits USAR Appendix 1 A, item 1.B.1.2 states that the ISEG should perform independent review and assessment of plant operation and maintenance audits. This oversight function is l

being deleted as an ISEG function. There is no NRC requirements for 9EG to perform this function. However, the function will continue to be performed by an independent organization. USAR Section 17.2.1.3.5, " Company Nuclear Review Board (CNRB),"

states the review board is required to perform independent review and audit of plant operations, instrumentation and control (maintenance function), and other activities.

USAR Section 17.2.1.3.5.2 states the CNRB is required to audit various activities including conformance of unit operations to the provisions of the Technical Specifications (TS), and audit the results of actions taken to correct deficiencies occurring in unit equipment. The CNRB comprises eight members and reports directly to the site Vice President. A CNRB member (USAR Section 17.2.1.3.5) shall hold a bachelor's degree in an engineering or physical science field, or equivalent experience, and a minimum of five years of technical experience of which a minimum of three years shall be in one or more of the various engineering disciplines listed in USAR Section 17.2.1.3.5. The reduction in commitment is acceptable because the oversight audit function is being performed by another independent group composed of members that meet or exceed the qualifications for the ISEG personnel.

2.3 Reduction of ISEG Membershio NUREG-0737 states that ISEG will comprise five individuals. The licensee proposes to reduce the ISEG membership from five to four individuals to perform the requisite tasks described in USAR Appendix 1 A. Item 1.B.1.2, and Sections 13.4.3 and 17.2.1.3.3.2 '2.3.

Currently, the ISEG manager is considered one of the members, however, the proposal will not consider the QAS manager as cne of the members. As discussed in section 2.2 of this evaluation, the ISEG will no longer perform a review of plant operation and maintenance auditc. In addition to ISEG staffing expectations, one of ISEG's tasks is to obtain and evaluate " industry and regulatory information." However, since the issuance of NUREG-0737, computerized databases and websites have become more readily available. ISEG staff can now more readily access this information. Also, properly trained station personnel can perform their own review of " industry experience ar.d regulatory information" utilizing the same databases that ISEG uses. The use of modern information retrieval tools has reduced the need for routine retrieval of " industry experience and regulatory information" by an ISEG member. The four ISEG individuals will still perform the ISEG functions in NUREG-0737. The reduction in commitment is acceptable as the ISEG staff will continue to perform the ISEG functions described in NUREG-0737 b a more efficient manner.

2.4 ISEG Qualifications l

l The proposal requests that the USAR be changed to match the qualifications at stated in Perry's Operations Requirements Manual (ORM), Revision 0, Section 7.2.2.2. Tha ORM is controlled under 10 CFR 50.59 provisions. The ISEG qualifications were relocated from Perry's TS 6.2.3.2 to its ORM Section 7l2.2.2 by Centerior Energy's letter dated i

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l December 16,1993. Currently, the ISEG qualifications in the USAR state that the ISEG is l

staffed by engineers and other technically oriented personnel, all of whom have l

qualifications comparable to the requirements set forth in ANSI /ANS 3.1, Sections 4.1 and 4.2 (December 1981). However, the licensee proposes to ch.me the qualifications to the following -

i Each shall have either (1) a bachelor's degree in engineering or related science and at least 2 years professional experience in their field, at least 1 year of which experience shall be in the nuclear field, or (2) equivalent work expcrience as described in Section 4.1 of ANSI /ANS 3.1, December 1981. The evaluations of the equivalent work experience and its basis will be documented and approved by the Manager, Quality Assurance Section. At least half of the ISEG members shallpossess the qualifications described in item 1 above.

L The proposed qualifications are equivalent to the ORM Section 7.2.2.2 (formerly TS 6.2.3.2) requirements with the added restriction of at least half the ISEG having the L

qualifications described in Item 1. The reduction in commitment is acceptable because l

the proposed qualifications match the last approved ISEG qualifications in Perry's TS and the also match the current ORM ISEG qualifications.

3.0 CONCLUSION

The staff has reviewed the July 22,1998 and the September 1,1998 50.54(a) submittals,'in accordance with NUREG-0800," Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants" Chapters 13 and 17. The staff has determined that the changes to the USAR Section 13.4.3,17.2.1.3.2.2,17.2.1.3.2.2.3 and Appendir 1 A, item 1.B.1.2 continues to satisfy the criteria of Appendix B of 10 CFR 50 and, therefore, the changes are found to be acceptable.

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