ML20212G852
| ML20212G852 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 10/29/1997 |
| From: | Wigginton D NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9711070134 | |
| Download: ML20212G852 (22) | |
Text
,
-LICENSEE:
Entergy Operations, Inc.
Octobsr 29, 1997
',FACIllTIES:
Arkansas Nuclear One, Grand Gulf Nuclear Station, River Bend.
~
Station,. and Waterford Steam Electric Station e.
bOBJECT:
SUMMARY
OF MEETING HELD ON OCTOBER 22, 1997, WITH ENTERGY1 i
OPERATIONS, INC. TO DISCUSS THE DEVELOPMENT OF STANDARD ENTERGY QUALITY ASSURANCE PLAN t
_On Oct ber 22, 1997, the staff met with representatives of Entergy Services,.
r
. Inc. (representing Entergy Operations, Inc.) to discuss the development and implementation of a common or standard quality assurance plan for all sites.
The list of attendees is attached as Attachment 1.
'The Entergy presentation was made from the viewgraphs attached as Attachment 2.
Entergy will develop the "one plan" and seek Nuclear Regulatory Commission (NRC) approval for use at all sites.
It is expected that some site specific differences will occur and these will be detailed for each site.
It is also
. expected that some new requirements will be added for sites (to make the "one plan". concept work) and that some reductions in commitments will be identified.
The reductions in commitments will be submitted for NRC approval at the same time the "one plan" is submitted.
To make the transition easier to understaad, Entergy will mark up the old plan for each site to provide a road map from the old to the new plan.
Entergy expects to submit the revised plan by the end of the 1st quarter in 1998. The NRC review will follow with a best estimate for approval by the end of the 3rd quarter in 1998.
Entergy plans to implement the "one plan" at all the sites in the 1st quarter of 1999.
ORIGINAL SIGNED BY:
David L.
Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Docket Nos.
50-313, 50-368, 50-416, 50-382, and 50-458 Attachments: As stated cc w/atts:
See next page DISTRIBUTION:
Hard Cooy E-mail Docket File SCollins/FMiraglia (SJC1/FJM) RZimmerman (RPZ)
PUBLIC EAdensam (EGAl)
DWigginton (DLW)
PD4-1 r/f JHannon (JNH)
CHawes (CMH2)
/
- OGC WHaass (WPH)
RGramm (RAG)
ACRS JClifford (JWC)
TGwynn (TPG) l Document Name: RB102297.MTS OFC PM/Phile LA/PD4-1 DWi M n/vw CHawes d////
WR p?} p S'GQ @")$V NAME s
DATE /0/N97 IC /-M/97 hN0 YES/N0 COPY OFFICIAL RECORD COPY m,, 2 % M M a u 8 L lllll I.lli Ill. l.ll0ll t
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1 UNITED STATES NUCLEAR REGULATORY COMMISSION I
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WASHINGTON, D.C. 30666-0001 October 29, 1997 LICENSEE:
Entergy Operations, Inc.
FACILITIES:
Arkansas Nuclear One, Grand Gulf Nuclear Station, River Bend Station, and Waterford Steam Electric Station
SUBJECT:
SUMMARY
OF MEETING HELD ON OCTOBER 22, 1997, WITH ENTERGY OPLRATIONS, INC. TO DISCUSS THE DEVELOPMENT OF STANDARD ENTERGY QUALITY ASSURANCE PLAN On October 22, 1997, the staff met with representatives of Entergy Services, Inc. (representing Entergy Operations, Inc.) to discuss the development and implementation of a common or standard quality assurance plan for all sites.
The list of attendees is attached as Attachment 1.
The Entergy presentation was made from the viewgraphs attached as Attachment 2.
Entergy will develop the "one plan" and seek Nuclear Regulatory Commission (NRC) approval for use at all sites.
It is expected that some site specific differences will occur and these will be detailed for each site.
It is also expected that some new requirements will be added for sites (to make the "one plan" concept work) and that some reductions in commitments will be identified.
The reductions in commitments will be submitted for NRC approval at the same time the "one plan" is submitted. To make the transition easier to understand, Entergy will mark up the old plan for each site to provide a road map from the old to the new plan.
Entergy expects to submit the revised plan by the end of the 1st quarter in 1998. The NRC review will follow with a best estimate for approval by the end of the 3rd quarter in 1998.
Entergy plans to implement the "one plan" at all the sites in the 1st quarter of 1999.
n David L.
i ginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects III/IV Docket Nos.
50-313, 50-368, 50-416, 50-382, and 50-458 Attachments: As stated cc w/atts:
See next page
1 Entergy Operations, Inc..
Arkansas Nuclear One, Units 1 & 2 cc:
Executive Vice President Vice President, Operations Support
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc.
P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-5%7 Mr. C. Randy Hutchinson Vice President Operations, ANO Entergy Operations, Inc.
Winston & Stravi 1448 S. R. 333 1400 L Street, N.W.
Russellville, AR 72801 Washington, DC 20005-3502 Manager, Rockville Nuclear Licensing Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident Inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801
Entergy Operations, Inc.
Grand Gulf Nuclear Station l
cc:
Executive Vice President General Manager, GGNS
& Chief Operating Officer Entergy Operations Inc.
Entergy Operations, Inc.
P. O. Box 756 P. O. Bcx 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Winston & 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 Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attorney General President, Asst. Attorney General Claiborne 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.O. Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior-Resident Insp'ector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs Route 2, Box 399 Entergy Operations, Inc.
Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 Manager of Operations Bechtel Power Corporation
-P.O. Box 2166 Houston, TX 77252-2166 Mr. Joseph J. Hagan Vice President, Operations GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
Entergy Operations, Inc.
River Bend Station cc:
Winston & Strawn Executive Vice President and 1400 L Street, N.W.
Chief Operating Officer Washington, DC 20005-3502 Entergy Operations, Inc.
P. O. Box 31995 Manager - Licensing Jackson, MS 39286 Entergy Operations, Inc.
River Bend Station-General Manager - Plant Operations P. O. Box 220 Entergy Operations, Inc.
St. Francisville, LA 70775 River Bend Station P. O. Box 220 Director St. Francisville, LA 70775 Joint Operations Cajun 10719 Airline Highway Director - Nuclear Safety P. O. Box 15540 Entergy Operations, Inc.
Baton Rouge, LA 70895 River Bend Station P. O. Box 220 Senior Resident Inspector St. Francisville, LA 70775 P. O. Box 1050 St. Francisville, LA 70775 Vice President - Operations Support Entergy Operations, Inc.
President of West Feliciana P. O. Box 31995 Police Jury Jackson, MS 39286-1995 P. O. Box 1921 St. Francisville, LA 70775 Attorney General State of Louisiana Regional Administrator, Region IV P. O. Box 94095 U.S. Nuclear Regulatory Commission Baton Rouge, LA 70804-9095 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 Wise, Carter, Child & Caraway P. O. Box 651 Ms. H. Anne Plettinger Jackson, MS 39205 3456 Villa Rose Drive Baton Rouge, LA 70806 Vice President & Controller Cajun Electric Power Cooperative Administrator 10719 Airline Highway Louisiana Radiation Protection Division P.0, Box 15540 P. O. Box 82135 Baton Rouge, LA 70895 Baton Rouge, LA 70884-2135 Mr. John R. McGaha Vice President - Operations Entergy Operations, Inc.
River Bend Station P.O. Box 220 St. Francisville, LA 70775
Entergy Operations, Inc.
Waterford 3 CC' Adn..aistrator 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 Vice President, Operations Resident Inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc.
K111ona, LA 70066 P. O. Box 31995
-Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc.
P. O. Box B Executive Vice-Prer.ident Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service 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.
P. O. Box B P. O. Box B Killona, LA 70066 K111ona, LA 70066 Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502 I
ATTENDEES AT MEETING OF OCTOBER 22. 1997 WITH ENTERGY OPERATIONS. INC.
HAME AFFILIATIQH Steve Bethay ESI, Jackson Brian Ford ESI, Jackson Connie Wells ESI, Jackson Greg Pierce E01, Waterford Walt Haass NRC, HQMB/NRR Robert Gramm NRC, HQMB/NRR David Wigginton NRC, PDIV-1/NRR John Hannon NRC, PDIII-1/NRR ATTACHMENT 1 4
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N 1
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- \\
One Quality Assurance Plan i
i i
i i
[
Entergy October 22,1997
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5 i
5 a
5 m
Agenda
_ :0
-~~
l l
l m Meeting Goals i
i e Current QA Plans 1
m New QA Plan a Schedule l
O y
Meeting Goals i
m Discuss l
l
- why we are changing the plans i
- methodology for making the change
- schedule for the change
- NRC suggestions and feedback
Current QA Plans
____O i
l m 4 plans plus a corporate policy e Different companies m Construction phase a Different requirements due to plant ages and
~
experiences
Eneergy Nuclear Regulatory GuidesfANSI Standards Comparison Megulescry tluide i Neandard Arkansom Nuclear One Commhment GONS C.__
T C6ver llemi Noteen Comunemens Waterfewd a have t '__-
Regulesary Guede 1.39 Revision 2,907 Revnson 2,907 Revtsien 2,907 Reviseen 2.907 AN$t N43.2.3 1973 1973 1973 to7)
General
- (USAR)ConstnfGlace P9adaes -
- (F5AR) W3 parets the recomunende-guide with clarifacetsons as nosed in Comply tions of Reg Guide f 39. The sg GGNS. TOP-1 A, Rev.12 goede sutiect is dncussed in the QAPM
- (OQAM)The OQAP complies with Oncretion Positiors - Comply througi, and FSAR Sutnections 3 3J.93 I and the requirements of this guide with the the irnplemennesson of the following 14.2.7 followingclarifications Foroperatione clarifications and eherneses so (3 3J)Provides shis rug guide as a phase.- __._
= end modification ANSI N43.23 which is referenced by reference for Category I swucewe activieses, the lacernee shell ekher the reg. guide design.
(9J 1) Provides sMs reg guide se s control those activities under this
{
OQAP.
reference in the fire preescasen preysm.
(142.7) No excryssons to this guide i
for the Start-up tem preysm f
RG l.39-Paragraph C. Regulosary
-tedsnanistrative
.m
...; included therein (outiect
.f so the clarifications in ANSI N4323 i
below) shall app!y to these
=
I and enedification activities even though j
sisch..
e.....; may not have been in effect enginally. Technical requ -..-.; essociesed with the anointenance or snodefication shell be the original. _, _. ;...n or bener (e g,
code..y__.
..u.3, meeerial propes' ties, j
design margine. snenufacturing i
processes, and inspection.+ a.;..;).
A:Jsl N43.23 - General
- (QAMO) A;ternettve equivalent
- (USAR) Me.i. - and requirgements may be wihzed to cover modirecation activities 6...,2 in
(
those situssions not included in this nature end entent so sirnilar activitses standard; for exernple, situations in conducted during the construction phase which shoe covers endfor coverstis are are controlled under the Operational QA required but meterial ~.6Mity is proymen er en NRC secepoed not. Also, unes might be comb 6ned construction QA progreen, en applicable into the next more restrictive category in order to reduce total number of mones.
- (QAMO)1he standard identifies Regelmoory Guide 139, flousekeeping R,,.....; for Weser Cooled NFPs - Page I of 4 January 2.1997 l
)
Current QA Plans
___b 11 J
l i
a Makes working together as a company i
difficult.
i m Fosters different approaches to solving common issues m Requires the same change to be submitted and reviewed 4 times.
One QA Plan l
i e Apply one plan to all sites i
e Follow the format of SRP 17.3 DW@
i a Make the requirements the same for all sites
One QA Plan Benefits a
i
[
m Reduce burden of future changes to the plan l
(i.e., change it once vs. four times).
l m Implement the " lessons learned" from the years of plan implementation across all of the sites.
m Remove this block to solving issues consistently between sites.
m Allow sites to share resources.
Change Process e Develop draft new QA Plan m Develop justifications for the changes to each QA Plan 4
m Submit revised plan for XRC review and approval
Quatty Assurance M:nual DRAFT Rev. 0 yy A,
MANAGEMENT 1.
Methodology a.
This Quality Assurance Program Manual (QAPM) providos a consolidated overview of the quarrty program controls which govem the operation and maintenance of Enterg/s quality related items and activities. The QAPM describes the quatty assurance organizational structure, functional responsiblities, levets ci authorty, and interfaces.
b.
The requirements and cormutments contained in the QAPM are mandatory and must be implernented, enforced, and adhered by all individuals and organizations. Empkrpes are encouraged to actively participate in the continued development of the QAPM as well as its implementation. Changes should be promptfy communicated when identified.
c.
The QAPM appfies to all actmties associated with safety related structures, systems, and components to an extent commensurate with their importance to safety at Entergy Operabons. Inc locations, thereby, implementing 10 CFR 50, Appendix B. Appiimhaty is determoed on a case by case basis for items and activities not rneet:ng the 10 CFR 50.2 definition of safety related.
d.
The QAPM is implemented through the use of approved policies, directives, proced as, and instruebons which provide written guidance for the control of quality related actmties and provide for the development of documentation to provide ob}ective evxience of compliance with the QAPM.
2.
Organization The organizational structure responsible for implementation of the QAPM is described below. The speerfic orgare Gon tities for the quality assurance functions described is identified in procedures.
a.
The chief executNE of"cer is responsible for providing top level direction of all activities associated with the safe and reliable operation of Entergy's nuclear sites. The chief execubve officer provides guidance with regard to company quality assurance po5cy. The authonty for the accomplishment of this responsibility is Wad to the incumbent's staff, b.
The chief operating of5cer reports to the cheif excutive officer and is responsible for the implementation as activities associated with the safe and reliable operation of Entergy's nuclear sites. The chief executive officer provides guidance with regarti to company quality assurance policy. The authority for the accomplishrnent of this responsibaity is delegated to the incumbent's staff.
1
Quality Assurance Manual DRAFT m m Rev.o 10.
The manager responsible for suppIler evaluations has direct responsibility for performing supplier evaluations and source verifications for the procurement of materials, parts, components and services to be used in plant maintenance and modification activities, e.
The on site and off site safety review committees have been established as management tools to independently review activities in order to provide additional assurance that the units are operated and maintained in accordance with the Operating License and appfcable regulations which address nuclear safety.
3.
Responsibility a.
Entergy Operations, Inc. has the responsibility for the scope and implementation of an effective quality assurance program,
~
b.
E'*.
.-s
>, nc. -
~ mate part or all of the activities of planning, mNsMag ond impamentir,g Ge mality assurance program to others, but 7 Mains me roseni!R Pr me p*ts m's etiectiveness, i
e Tw 3,wa,.&. - J' % snriomr tation is assessed annually and reported a w.:ni. %wwae otiwr aN the sscciated executive for overall plant nudsr ofety Mr (wh da.
A r e4wi
.., rer ponsible for ensuring that the applicable portion (s) o, the, quamy assurano program is property documented, approved, and implemented (people are Pained and resources are available) before an activity within the scope of the QAPh* ls undertaken by Entergy Operations, Inc. or by others.
e.
Individual managers are to ensure that personnel working under their management cognizance are provided the necessary training and resources to accomplish their assigned tasks within the scope of the QAPM.
f.
Procedures that implement the QAPM are approved by the management responsible for the applicable quality function. These procedures are to reflect the QAPM, and work is to be accomplished in accordance with them.
4.
Authority a.
When Entergy Operations, Inc. delegates responsibility for planning, establishing, or implementing any part of the overall QA program, sufficient authority to accomplish the assigned responsibilities is delegated.
4
OPERATIONAL QUALITY ASSURANCE MANUAL DRAFT T m., Q m m,,, - P -
.,p
2.5.1 (continued)
N/
/*,p The Director, Quality is responsible for maintaining the h
pg*g manual and controlling its distribution, including revisions p'
n o
thereto, in ac_cordance with_.Agnroved quality assu_rance_
ocedures.fRentions thhe manNs.1 wilr%s prWseher q
5%(y 2.5.2 Isqplementing Policies, Directives, Procedures and Instructions g*g'g The operational Quality Assurance Program is implemented through the use of written, approved policies, directives, g' g *y procedures and instructions generated by prganisations, which are rannonsible for the performance o_f specific functions, as Qutlined ir mum.; : :"thM -ely _
A ity uranc roced Manu Q contai the imp n
g pr edures strue ons f A the qua t
~
'g uncti ns o forme y Que ity Pr rams._J gunaasy assurance procedures / instructions provide measures to assure that g8g8j quality-related activities are performed in a controlled manner and are documented to provide obiective evir!snee of -
liance with prograa requirements.fThe Director, Quality is responszois sor opptwvwv v olasy assurance procedures
- {
prior to implamentation. Quality Programs supervisors are responsible for approving quality assurance instructio prior to implementation. f
^
Quality-related functions performed by other organizations are controlled and documented in accordance with procedures A. 3.k prepared, approved and controlled by the organization performing the function. These procedures assure that the functions are accomplished in a controlled manner, with specified equipment, under suitable environmental conditions, and that prerequisites have been satisfied prior to inspection or testing.
( endix to this ual provide a matrix o ality as ance p edures c s-referene to the cri ia of Q,{
(Appen x 8 to FR50 whi they impi t.
2.5.3 Indoctrination and Training A.3. k Indoctrination and training programs are established for both Q, 3, q, onsite and offsite personnel performing quality-affecting activities by the organizations _ responsible for the activities. _1These programs are implemented by appropriate A, Q,,,,(Eraining plans and procedurefwllich asuse that 2.5.3.1 Fersonnel responsible for performing quality-ha3.D affecting activities are instructed as to the
(
purpose, scope and implemen'.ation of manuals, A,3,d procedures and instructions; Page 3 of 5 Policy 2 Rev. 15 e
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emn*~ +
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e
DRAFT l
L ADMINISTRATIVE CHANGES A.1 Information which contained no requirements related to the implementation of the quality assurance program or only provided a cross reference to other information available has been removed. Removal of this information results in no changes to the applicable requirements.
A.2 Plant specific management positions titles and descriptions in the current quality assurance program have been replaced with generic functional titles and descriptions.
+
The specific management position titles and associated position desaiption which futfill each of the functions will be identified in procedures as discussed in QAPM A.2.
This approach of removing the specific titles is consistent with the intent of Generic i etter 88-06 which recommended, as a line item improvement to the Technical Spacifications, relocation of the corporate and unit organization charts to licensee controlled documents. The intent of the Generic Letter, and of this proposed change, is to reduce the unnecessary burden ore NRC and licensee resources being used to process changes due solely to personnel titles and position description changes during reorganizations and to allow one set of requirements to apply to all of the EOl sites. Since this change does not eliminate any of the qualifications, responsibilities or requirements for these personnel or the positions, the change is considered to be a change in presentation only and is therefore administrative.
A.3 The soecific discussions of the polices that the functional position is responsible for approving is removed but the requirement remains in the QAPM. QAPM A.2 idt.,ntifes the position functional responsibilities while QAPM A.3.f states that " Procedures that implement the QA program are approved by the management responsible for the applicable quality function." Therefore, the appropriate review and approval requiremeMs will continue to be required by the QAPM and the specific management position responsible for approval will maintained in approved documents as required by QAPM A.1.
A.4 The manager responsible for quality assurance will no longer be responsible for controlling the QAPM but will remain responsible for approving changes and assuring the QAPM is adequate for assuring quality. The responsibility for control the QAPM ltself is transferred to the corporate executive responsible for operations support to allow for a single QAPM 'o be maintained for all four sites. Since the manager responsible for quality assurance remains responsible for approving changes and assuring the QAPM is adequate for assuring quality, this change does not have any significant affect on the quality assurance function.
A.5 The specific discussions of the polices that the functional position is responsible for approving is removed but the requirement remains in the QAPM. QAPM A.2 identifes the position functional responsibilities while QAPM A.3.f states that " Procedures that implement the QA program are approved by the management responsible for the applicable quality function." Therefore, the appropriate review and approval requirements will continue to be required by the QAPM and the speofic management position responsible for approval will maintained in approved documents as required GGNS Draft A
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Tentative Schedule
____n
___.U
.i m Snbmit revised plan end of 1st Qtr 1998 m NRC approval end of 3rd Qtr 1998 l
s Implement 1st Qtr 1999
XRC Feedback Z__0
~~~
i m Level of submittal detail i
l m Amount ofinteraction (e.g., meetings) u Schedule
~