ML20198K315

Discusses Graded QA Initiative for Plant,Unit 1.Interactions Between NRC & Licenses & Listing of Correspondence & Meeting Held Between NRC & Entergy Operations,Inc,Staff During Initiative Encl

ML20198K315
Person / Time
Site:	Grand Gulf
Issue date:	01/07/1998
From:	Donohew J NRC (Affiliation Not Assigned)
To:	Hagan J ENTERGY OPERATIONS, INC.
References
TAC-M92420, NUDOCS 9801140373
Download: ML20198K315 (5)

Text

, _ _ . . . .

t. - EMM t UNITED STATES

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} NUCLEAR RF.GULATORY CDMMISSION f WAB6tlNOToN, D.C. 2006H001

%~*****/e January 7, 1998 d Mr. Joseph J. Hage.n Vice President, Operations GGNS Entergy Operations, Inc. , '

P. O. Box 756 Port Gibson, MS 39150

SUBJECT:

GRADED QUALITY ASSURANCE INITIATIVE, GRAND GULF NUCLEAR STATION, UNIT 1 (TAC NO. M92420)

Dear Mr. Hagan:

The Nuclear Regulatory Commission (NRC) staff and the nuclear power industry have been interacting on the Graded Quality Assurance (GQA) initiative for over 3 years. Th s initiative included the following GQA volunteer plants: Grand Gulf Mclear Station, Unit 1 (GGNS), Palo Verde Nuclear Generating Station, and South Texas Project Electric Generating Station. The staffs pimary objective was to develop and document NRC guidelines for a GQA program at a plant, such as GGNS. During this period, your staff has worked with us as they have been developing the methodology for implementing GQA at GGNS. These interactions included meetings between your staff and the NRC staff, and letters that NRC sent to you. Our objectiva of the initiative was for NRC to develop draft guidance for GQA based '.n part on interactions with the volunteer plants.

A listing of the correspondence and meetings held between NRC and your staff dunng the GQA initiative is given in the enclosure.

On April 8,1997, the staff sent SECY-97-077," Draft Regulatory Guices, Standard Review Plans and NUREG Document in Support of Risk Informed Regulation for Power Plants," to the Commission. The SECY paper requested approval to publish four draft Regulatory Guides, three draft Standard Review Plan sections, and one draft NUREG document that support implementation of risk informed regulation, including GQA. The Commission approved the staffs recommended action and the draft Regulatory Guides, Standard Review Plan sections, and NUREG document were published for public comment on Me 25,1997. A public workshop was held on the draft Regulatory Guides on August 12,1997. The staff intends to issue these documents as final documents after the public comments have been evaluated.

On October 6,1997, the staff also sent SECY-97 229," Graded Quality Assurance /Probabilistic Risk Assessment Implementation Plan for South Texas Project Electric Generating Station," to the Commission. The SECY paper transmitted the staffs Cafety Evaluation regarding a proposed revision to the Operating Quality Aswrance Program that incorporated the methodology for implementation of GQA for South Texas Project. The Commission did not h

object to issuance of the proposed Safety Evaluation on South Texas Project, and it was issued to Houston Lighting & Power Company in a letter dated November 6,1997. ,j tt has been our understanding, as a result of the visits to GGNS and conversations with your staff, that you will apply GQA for the near future at GGNS on a limited basis with respect to the quality assurance requirements of 10 CFR Part 50, Appendix B. Specifically, it was cur.

understanding that GQA would only be initially applied in the area of procurement (i.e., expanded use of commercial grade dedication). The meeting summary of November 6,1997, concemed a

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Joseph'J. Hagen ,

trip by NRC to the site on November 21,1906, to discuss the implementation methodologies .

employed for GQA in the procurement area. The staff concluded in the trip report that you have initisted a conservative effort to establish a GQA process for procurement activities, it should be noted that the NRC staff, in its letters to you, has not made any conclusions with regard to the acceptability of either (1) the GQA process to be used at GGNS to determine the relauve safety significance of pierd equipment or (?) the resulting equipment categorization for GGNS. This is because you did not submitted your GQA process for our review as did South Texas. The staff has, therefore, tw 4 evaluated your responses to its request for additional '

irdormation (RAI) of July 15,1997, o n this GQA process. Oral responses 10 the RAI were p(ovided to the steff in the meeting of August 27,1996, and documented in the meeting summary issued December 18,1996.

Throughout our interactions with your staff, we leave stressed, as we stated in our letter to you of May 29,1996, the importance of making proper changes to the Quality Assurance (QA) plan for GGNS to enable the implementation of GQA in a manner consistent with the regulations (i.e.,10 CFR 50.54(a)). Any QA program changes involving the determination of the safety significance of plant equipment would require prior staff approval to be in accordance with 10 CFR 50.54(a). The above Safety Evaluation for South Texas documents the staff review and conclusions of a prototypical GQA program. We believe that similar provisions may be needed in your QA plan to enable this type of implementation of GQA at GGNS.

With the issuance of the above GQA Safety Evaluation and draft GQA documents, the staff has completed its work with your staff under the NRC/ Industry GQA initiative, and this letter closes out TAC M92420. If you have any questions, contact me at 301-4151307 or"JNDONRC. GOV" on the intemet.

Sincerely, 4.h 01, b (Jack N. Donohew, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects lilV Offica of Nuclear Reactor Regulation Docket No. 50-416

Enclosure:

Interactions Between the NRC and Licensee cc w/ encl: See next page  ;

o L

I Joseph J. Hagan .

trip by NRC to the site on November 21,1996, to discuss the implementation methodologies

, ornployed for GQA in the procurement area. The staff concluded in the trip report that you have

. Initiated a conservative effort to establish a GQA process for procurement activities.

1 it should be noted that the NRC staff, in its letters to you, has not made any conclusluns with regard to the acceptability of alther ('i) the GQA process to be used at GGMS to determine the e

' relative safety significance of plant equipment or (2) the resulting equipment categorization for < J GGNS, This is because you did not submitted your GQA process for our review as did South Texas. The staff has, therefore, not evaluated your re*ponses to its request for additional infermation (RAI) of July 15,1997, on this GQA process. Oral responses to the RAI were ,

~ provided to the staff in the meeting of August 27,1996, and documented in the meeting  !

. summary issued December 18,1996.

Throughout our interactions with your staff, we have stressed, as we stated in our Eter to you of May 29,1996, the importance of making proper changes to the Quality Assurance (QA) plan for GGNS to enable the implementation of GQA in a manner consistent with the regulations 0.e.,10 CFR 50.54(a)). Any QA program changes involving the detormination of the safety significince of plant equipment would require prior staff approval to be in accordance with 10 CFR 50.54(a). The above Safety Evaluation for South Texas documents the staff review and conclusions of a prototypical GQA program. We believe that similar provisions may be neeoed in your QA plan to enable this type of implementation of GQA at GGNS.

With the issuance of the above GQA Safety Evaluation and draft GQA documents, the staff has completed its work with your staff under the NRClinoustry GQA initiative, and this letter closes  ?

out TAC M92420. If you have any questions, contact me at 301-415-1307 or "JND@NRC. GOV' on the intemet.

Sincerely, .

Jack N. ohaw, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects ill/IV Office of Nuclear Reactor Regulation Docket No. 50-416 Enclosure; interactions Between the NRC and Licensee cc w/enci: See next page DISTRIBUTION:

Docket File PUBLIC PD<-1 r/f S. Black WHaass E. Adensam (EGA1) J. Donohew T. Gwynn, RIV R. Gramm JFlack ACRS OGC (15B18) C Hawes S. Dinsmore Document Name: GG92420,LTR *See previous concurrence c OFC~ PM/PO4O LA/PD4-1 BC/HQMB* BC/SPSE[ kk NAME JDorhwIsp CHawesUON SBlack f JFlack

-DATE I/7/98 l / i/98 12/08/97 h/h/97 O ,

COPY- t YES/NO YES/NG YES/NO hO l

OFFICIAL RECORD COPY I a

. _- _ _ _ _ . _ _ . _ _ ___.__s___ . _ _ _ - . _ . _ _ . _ _ ___

. Mr. Joceph J. Hagen Fntergy Operations, Inc. ,

Grand Gulf Nuclear Station -

oc: ,,

Executive Vice Pres 6 dent General Manager, GGNS

& Chief Operating Officer Entergy Opera *Jons, Inc.

Entergy Operations, Inc_ P. O. Box 756 P. O. Bex 31995 Po:t Gibson, MS 39150 Jackson, MS 39286 1995 Attomey General Wise, Carter, Child & Coraway Department of Justice .,

P. O. Box 651 State of Louis!ana [

Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Wmston & Strawn .

1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Govemor Resources State c' Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attomey General President, Asst. Attomey General Claibome County Board of Supervisors State of Mississippi ,

P. O. Box 339 P. O. Box 22947 Port Gibson, MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc. -

611 Ryan Plaza Drive, Suite 1000 P,0 Box 31995 Arlington,TX 76011 Jackson, MS 39286-1995 Senior Resident Inspector Director, Nudear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs Rcute 2, Box 399 Entergy operations, Inc.

Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 s.

g. e A

0 INTERACTIONS BETWEEN THE NRC AND LICENSEE ON GRADED QUALITY ASSURANCE INITIATIVE The meetings held between the Nuclear Regulatory Commission (NRC) and Entergy Operations, Inc. (the licensee) on the Graded Quality Assurar.co (GQA) initiative include the following:

(1) initia* aceting on May 4,1995; (2) site meeting on Juy 11 to 14,1995, to observe expert panel moeungs; (3) meeting at NRC headquarters on October 24,1995, on quality assumnce (QA) controls; (4) meeting at NRC Re96 on IV on November 16,1995, to discuss the GQA effort; (5) site meeting on November 17,1995, to again observe an expert panel meeting; (6) NRC-Nuclear Energy Institute (NEI) me:eting on April 11,1996, to ciiscuss the draft NRC evaluation gu8'Je; (7) meeting at NRC headquarters on August 27,1996, to discuss criteria developed by $

your staff to determine the safety significance of plant structures, systems, and components; and (8) site meeting on November 21,199G, to review the GQA for procurement. The summaries for there meetings were issued by the NRC in letters on the following dates: (1) May 8; (2) August 11; (3) December 11; (4) December 29; (5) December 19,1995; (CWJy 1; (7) December 18, 1996; and (8) November 6,1997.

The letters the NRC sent to the licensee on this initiative are the following: January 24, May 1, May 29, and Juh 15,1996. The letter of May 1,1996, provided the licensee with the summary of the staff's April 11,1996, visit to Palo Verde Nuclear Generatit,g Station.

There were also briefings of the Advisory Committee on Reactor Safeguards on GQA which the licensee participated in. These briefing were the following: February 27 and 28; April 11; JuY 18; August 7; Novembe* 22,1996; February 21; March 6; and March 17,1997.

ENCLOSURE

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