ML20199F842
| ML20199F842 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 01/19/1999 |
| From: | Chandu Patel NRC (Affiliation Not Assigned) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| TAC-M97674, NUDOCS 9901220074 | |
| Download: ML20199F842 (7) | |
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January 19, 1999 Mr. Charles M. Dugger Vice President Operations j
Entergy Operations, Inc.
P. O. Box B Killona, LA 70066
SUBJECT:
QUALITY ASSURANCE PROGRAM MANUAL UPDATE FOR WATERFORD STEAM ELECTRIC STATION, UNIT 3 (TAC NO. M97674)
Dear Mr. Dugger:
By letter dated December 19,1996, Entergy Operations, Inc provided a clarification of 10 changes in the update of their Quality Assurance Program Manual (OAPM). The Nuclear Regulatory Commission (NRC) staff had determined that those changes appeared to be reductions in commitment relative to the previously approved QAPM. The identification of these potential reductions in commitment was transmitted to you by a letter from Mr. Thomas P.
Gwynn to Mr. Michael B. Sellman dated June 20,1996.
In Part 1 of your December 19,1996 response, you indicated that three of the changes,
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involving the periodicity of assessment of the effectiveness of the Quality Assurance Picgram (staff comments 1,2, & 10), do represent reductions from previously accepted commitments.
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Consequently, modifications to the proposed changes along with justification or the changes were provided and resubmitted for staff review for acceptability. As noted in the Enclosure to this letter, we have found the reiised proposed changes to be acceptable. We are also in agreement with your commitment as described in Part 3 of your response to address premature implementation of the changes, under the Waterford 3 Corrective Action Program since they were made prior to receiving our approval.
In Part 2 of your response, further reasoning and justification for the remaining changes listed in our June 20th letter were provided. Based on the information provided, the NRC staff finds those changes to be acceptable as discussed in the Enclosure to this letter.
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o-D Charles M. Dugger l Also, in Part 2 of your response, the reasoning and justification for other changes not listed in our June 20th letter were provided. The changes are acceptable to the NRC staff.
Sincerely, ORIGINAL SIGNED BY:
Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects ill/lV Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/ encl: See next page l
l DISTRIBUTION:
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Docket File PUBLIC PD4-1 r/f OGC l
C. Pate!
J.Hannon C.Hawes T. Gwynn, RIV E. Adensam (EGA1)
ACRS Document Name: LTR97674.WPD f/
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b4-1 NAME CPate CHah JH nnon DATE l/19/99
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TFFICIAL RECORD COR-Y'
t Charles M. Dugger l l
Also, in Part 2 of your response, the reasoning and justification for other changes not listed in I
our June 20th letter were provided. The changes are acceptable to the NRC staff.
Sincerely, hf Chandu P. Patel, Project Manager Project Directorate IV-1 Division of Reactor Projects lil/IV I
Office of Nuclear Reactor Regulation Docket No. 50-382
Enclosure:
As stated cc w/ encl: See next page l
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t Entergy Operations, Inc.
Waterford 3 cc:
I Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington,TX 76011 l
Vice President, Operations Resident inspector /Waterford NPS Support Post Office Box 822 j
Entergy Operations, Inc.
Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parish j
Director P. O. Box 302 i
Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc.
P. O. Box B -
Executive Vice-President Killona, LA 70066 and Chief Operating Officer l
Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 General Manager Plant Operations Louisiana Public Servbe Commission Entergy Operations, Inc.
One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Vice President Operations Entergy Operations, Inc.
Entergy Operations, Inc.
I P. O. Box B P. O. Box B Killona, LA 70066 Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 i
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ENTERGY OPERATIONS, INC.
WATERFORD STEAM ELECTRIC STATION UNIT 3 STAFF EVALUATION OF RESPONSES TO REDUCTIONS IN COMMITMENT IDENTIFIED IN THE STAFF'S LETTER DATED JUNE 20,1996 Comment 1:
Deletion of the word " annual" from the previous commitment that the Vice President, Operations performs a review of the results of annual management assessments to evaluate the effectiveness of the Quality Assurance Program will be compensated for by the addition of the words " described in Chapter 2, Section 5.9.1" inserted after " assessments".
Assessment:
These changes in effect will result in a periodic review not to exceed 24 months (see Comment 2). This is acceptable to the Nuclear Regulatory Commission (NRC) staff.
Comment 2:
Deletion of the word " annually" from the previous commitment that the Vice President, Operations ensures that a management assessment is conducted annually will be replaced by the words " periodically (not to exceed 24 months)".
Assessment:
This is acceptable to the NRC staff.
Comment 3:
A new Section 5.10.2 was added to Chapter 2 that states NRC notification of changes to the Quality Assurance Program Manual (Special Scope) (QAPM)is not required. This portion of the quality assurance manual addresses several plant special scope programs which are not safety-related and, therefore, implementation of 10 CFR 50, Appendix B for these programs is not required. Programmatic changes to these special scope programs are reported to the NRC in accordance with other regulatory requirements.
Assessment:
This is acceptable to the NRC staff.
Comment 4:
Responsibility for the review, concurrence, and approval of changes to the Plant Operating Manual, Site Support Procedures, Design Engineering Procedures, Design Engineering Administrative Manual, Plant Modification and Construction Procedures, Nuclear Safety Procedures, and Nuclear Training Procedures was reassigned from the Plant Operations Review Committee (PORC) and Quality Assurance Management (OAM) to the responsible departmental managements. However, the PORC and QAM will continue to perform quality-related reviews for changes to the cited manuals and procedures. Quality related reviews are defined as reviews that are conducted to assure that the requirements of the OAPM are addressed. The latter definition will be added to Appendix C of the OAPM.
ENCLOSURE
2 Assessment:
This subdivision of responsibilities to assure that changes to the above cited manuals and procedures continue to satisfy the OAPM requirements is acceptable to the NRC staff.
Comment 5:
The previous responsibility of the OAM to review safety-related design change packages to assure that quhlity assurance requirements have been properly considered has been replaced with the responsibility to assure that quality reviews of safety-related design changes have been conducted. Design Engineering is now assigned the responsibility to perform the review of safety-related design changes to assure that quality assurance requirements are specified.
The licensee's justification in the response dated December 19,1996, modifies the OAM's role by indicating it "now is to ensure that the revieivs are being adeauately performed".
Assessment:
This is interpreted to mean that the OAM's reviews are not limited to whether the reviews were conducted, but now also include whether they are adequately performed. With this understanding, the licensee's change to the OAPM is acceptable.
Comment 6:
i The quality assurance inspection criteria review responsibility was reduced from " maintenance and modification work instructions, inspections and test plans" to " work authorizations". The licensee indicated that the new terminology, in general use at the plant, includes the previously listed items so that no reduction in OA scope results.
Assessment:
The licensee's change to the OAPM is acceptable. It is suggested that the definition of " work authorization" be included in the list of definitions in the OAPM.
Comment 7:
The quality assurance review to verify inclusion of attributes to be inspected in safety-related inspection procedures was deleted. The licensee indicates that this change is a part of placing the responsibility for quality related reviews with the department that prepares the procedures.
Assessment:
An independent check to verify the proper performance of this activity is accomplished through auditing by the OA organization and is acceptable to the NRC staff.
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Charles M. Dugger.
Comment 8:
The QAM previous responsibility to aoorove the sampling size and selection procedures was replaced with the OAM's concurrence of these functions as performed by the groups responsible for the work.
Assessment:
The staff believes that to satisfy Appendix B requirements, the OAM should be involved in the selection of sampling size and selection procedures, at least in an independent and oversight role. The licensee's change is acceptable.
Comment 9:
The PORC responsibility for the review and recommendation for approval of test procedures has been deleted. The licensee indicates that this function continues to be performed, but now by a Qualified Reviewer as approved by the NRC in Technical Specification Amendment 100.
The PORC reviews the candidates for qualified reviewer and he candidates are approved by the General Manager, P! ant Operations.
Assessment:
This is acceptable to the NRC staff.
Comment 10:
Deletion of the word " annual" from the previous commitment to perform annual assessments of the entire quality assurance program will be replaced with the words " periodic (not to exceed 24 i
months)".
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Assessment:
This is acceptable to the NRC staff.
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