ML20236M050

Summary of 980702 Meeting W/Entergy Operations,Inc to Discuss Review Status of Std QA Manual for All Entergy Sites.List of Attendees Encl

ML20236M050
Person / Time
Site:	Grand Gulf, Arkansas Nuclear, River Bend, Waterford
Issue date:	07/08/1998
From:	Wigginton D NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
NUDOCS 9807130280
Download: ML20236M050 (12)

Text

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', i July 8, 1998 LICENSEE: ENTERGY OPERATIONS, INC.

FACILITIES: ARKANSAS NUCLEAR ONE, GRAND GULF, RIVER BEND, AND WATERFORD

SUMMARY

OF MEETING HELD ON JULY 2,1998. TO DISCUSS REVIEW I

STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL l

l On July 2,1998, the staff met with representatives from Entergy Operaticns, Inc. to discuss the l status of review of the standard quality assurance (QA) manual!cr all the Entergy sites. The list of meeting attendees is attached as Attachment 1.

The staff presented the st#us from the 'ENTERGY OPERATIONS MEETING AGENDA" outline in Attachment 2. Undert,tandings were reached on a number of items and Entergy positions on others will continue to be considered in the staff's review. The licensee will provide additional wording in Section A.1.c. to clarify the applicability of the manual when considering "importance to safety". The licensee will consider the development of a functional chart, in lieu of an organizational chart, for use in the manual as a means to graphically display the functions and l separations of duties of the organizational units and the quality assurance manager. In addition, the functional chart and descriptions need to further clarify the duties and reporting )

responsibilities of any line organization QA functional responsibilities.

l The schedule for implementation of the new manual for all sites may be such that some updates of the old manuals may be required just prior to implementation of the new manual. The licensee will review the schedules and may seek exemptions to the regulations to allow the new manual j implementation without the old manual update. The licensee will also investigate and may -

request a single update schedule for the Entergy Standard QA Manual once approved.

The staff will continue the review of the manual and the conversion of each site's commitments.

The next meeting on review status will be scheduled for the week of August 10,1998.

ORIGINAL SIGNED SY: j David L. Wigginton, Senior Project Manager )

Project Directorate IV-1  !

Division of Reactor Projects lil/lV j Office of Nuclear Reactor Regulation l

Docket Nos. 50-313,50-368,50-416,  !

50-458, 50-382 Attachments: As stated cc: See next page

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DATE ~l/ 6 /98 7/h /98 /98 COPY I YE hNO YES/NO YEhNO

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%,*****/g July 8, 1998 LICENSEE: ENTERGY OPERATIONS, INC.

FACILITIES: ARKANSAS NUCLEAR ONE, GRAND GULF, RIVER BEND, AND WATERFORD

SUMMARY

OF MEETING HELD ON JULY 2,1998, TO DISCUSS REVIEW STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL On July 2,1998, the staff met with representatives from Entergy Operations, Inc. to discuss the status of review of the standard quality assurance (QA) manual for all the Entergy sites. The list of meeting attendees is attached as Attachment 1.

The staff presented the status from the "ENTERGY OPERATIONS MEETING AGENDA" outline in Attachment 2. Understandings were reached on a number ofitems and Entergy positions on others will continue to be considered in the staff's review. The licensee will provide additional wording in Section A.1.c. to clarify the applicability of the manual when considering "importance to safety". The licensee will consider the development of a functional chart, in lieu of an organizational chart, for use in the manual as a means to graphically display the functions and separations of duties of the organizational units and the quality assurance manager, in addition, the functional chart and descriptions need to further clarify the duties and reporting responsibilities of any line organization QA functional responsibilities.

The schedule forimplementation of the new manual for all sites may be such that some updates ,

of the old manuals may be required just prior to implementation of the new manual. The licensee l will review the schedules and may seek exemptions to the regulations to allow the new manual l

, implementation without the old manual update. The licensee will also investigate and may l request a single update schedule for the Entergy Standard QA Manual once approved. i The staff will continue the review of the manual and the conversion of each site's commitments.

The next meeting on review status wiu be scheduled for the week of August 10,1998. l e p David L. igginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-313,50-368, 50-416,50-458, 50-382 Attachments: As stated

j ..

DISTRIBUTION: Meeting Summary Dated HARD COPY Docket File-PUBLIC

' PDIV-1 R/F D. Wigginton l OGC I ACRS E-MAIL:

S. Collins /F Miraglia (SJC1/FJM)

B. Boger(BAB2)

E. Av sam (EGA1).

J. Hannon(JNH)

C. Hawes(CMH2)

T. Martin (SLM3) 1-T. Hiltz(TGH)

T. Gwynn(TPG) i i

I

~

l

, . Mr. C. Randy Hutchinson

!. Entergy Operations, Inc. Arkansas Nuclear One, Units 1 & 2 l

cc: )

Executive Vice President Vice President, Operations Support

& Chief Operating Officer Entergy Operations, Inc.

l Entergy Operations, Inc. P. O. Box 31995

! P. O. Box 31995 Jackson, MS 39286-1995 .

Jackson, MS 39286-1995 j

, Wise, Carter, Child & Caraway Director, Division of Radiation P. O. Box 651 Control and Emergency Management Jackson, MS 39205 j Arkansas Department of Health I l 4815 West Markham Street, Slot 30 l l Little Rock, AR 72205-3867 j f Winston & Strawn

! 1400 L Street, N.W.

! Washington, DC 20005-3502 l l Manager, Rockville Nuclear Licensing Framatone Technologies l 1700 Rockville Pike, Suite 525 l

Rockville, MD 208S2 l

l . Senior Resident inspector

j. U.S. Nuclear Regulatory Commission l P. O. Box 310 l London, AR 72847  !

l I

I Regional Administrator, Region IV U.S. Nuclear Regulatory Commission j 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 l

l l

ij .

Mr. Joseph J. Hagan Entergy Operations, Inc. Grand Gulf Nuclear Station cc:

Executive Vice President General Manager, GGNS

& Chief Operating Officer Entergy Operations, Inc.  !

Entergy Operations, Inc. P. O. Box 756 I P. O. Box 31995 Port Gibson, MS 39150 )

Jackson, MS 39286-1995 l Attomey General Wise, Caster, 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 Washing;on, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 l Division of Solid Waste Management Mississippi Department of Natural Office of the Govemor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 i Attomey General l' President, Asst. Attomey General Claibome County Board of Supervisors State of Mississippi P. O. Box 339 P. O. Box 22947 1 Port Gibson, MS 39150 Jackson, MS 39225 j 4

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 I Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident inspector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs P. O. Box 399 Entergy Operations, Inc.

Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 E-_ -_ - - - - - - _ - - - _ - - - - - - - - - - - _ - - - - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - _ - - - - - . - - - - - - - - - - - - -

Mr. John R. McGaha Entergy Operations, Inc. River Bend Station 1 1

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. 1 River Bend Station General Manager- Plant Operations i P. O. Box 220 Entergy Operations, Inc.

St. Francisville, LA 70775 River Bend Station P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 j P. O. Box 1050 '

St. Francisville, LA 70775 Director- Nuclear Safety Entergy Operations, Inc. I President of West Feliciana River Bend Station Police Jury P. O. Box 220 l P. O. Box 1921 St. Francisville, LA 70775 St. Francisville, LA 70775

. Vice President - Operations Support Regional Administrator, Region IV Entergy Ooorations, Inc.

U.S. Nuclear Regulatory Commission P. O. Box 31995 611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 ,

Arlington, TX 76011 '

Attorney General Ms. H. Anne Plettinger. State of Louisiana 3456 Villa Rose Drive P. O. Box 94095 Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 Administrator Wise, Carter, Child & Caraway Louisiana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205 Baton Rouge, LA 70884-2135 I

' Mr. Charles M. Dugger

,- Entergy Operations, Inc. Waterford 3 cc:

Administrator Regicnal Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drivo, Suite 1000 Baton Rouge, LA 70884-2135 Arlington, TX 76011 Vice President, Operations Resident inspector /Wate:Tord NPS Support Post Office Box 822 Entergy Operations, Inc. Killona, 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 President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.

Wise, Carier, 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 Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Winston & Strawn 1400 L Street, N.W.

Washington, DC 20005-3502 l

l l.

Enterav operations. Inc.

Meetina on Standard QA Manual List of Attendees Namt Oraanizatio_r1 David Wigginton NRR/DRPW/PD4-1 Walter P. Haass NRR/DRCH/HQMB Ray Smith NRR/DRCH/HQMB Bob Gramm NRR/DRCH/HQMB Bob Fretz NRR/DRPW/PD4-1 Bryan Ford Entergy Steve Bethay Entergy l

ATTACHMENT 1 l

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P:\EOPAGNDA July 2,1998 ENTERGY OPERATIONS MEETING AGENDA l

Programmatic requirements

- In section A.1.c. it is stated that "The requirements of the QAPM are applied to these items and activities to an extent commensurate with their importance to safety." How will this requirement be implemented?

- Section B. "PERFORMANCENERIFICATION" includes many statements and commitments that are verbatim repeats from SRP-17.3. In general consistent w;th the requirements of $50.34(b)(6)(ii), the staff is looking for additional explanatory information regarding the method the licensee will adopt to implement the commitment. Examples include:

- Section B.2.a.: What are the design control program provisions that assure that design activities are executed in a planned, controlled, and orderly manner?

- Section B.2.b.: What are the provisiens to control design inputs, processes, outputs, changes, interfaces, records and organizationalinterfaces?

- Section B.2.g.: What are the interface controls for the purpose of developing, reviewing, approving, releasing, distributing, and revising design inputs and outputs to be defined inprocedures?

- Section B.3.e.: Which are the individuals and groups responsible for design reviews or other verification activities? What are their autho'ities and responsibilities?

- Section B.4.b.: What are the provisions for evaluating prospective suppliers and selecting qualified suppliers?

- Section B.4.c.: What are the provisions for ensuring that qualified suppliers continue to provide acceptable products and services?

- Section B.S.a.: What are the provisions of the program to verify the quality of purchased items and services?

l These are examples of areas that require further amplifying discussions. There are many others in the various areas of the QAPM. All areas should be reviewed and expanded upon as appropriate.

Organization l

Difficult to determine reporting lines of responsibility for the QA function l

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ATTACHMENT 2

., n 2

- Lack of organization charts

- Maneger of QA responsit>le for establishing, controring and verifying implementation of the QAP (no mention of implementation); who reports to the Manager of QA7 What functions are carried out by staff reporting to Manager of QA?To whom does the Manager of QA report? (Question the validity of L26 due to an undefined layer of management between the executive position and the QA function position.)

- Discussion of Change L.1 eays "In all cases, the positions will maintain sufficient authority and organizational freedom to implement the assigned responsibilities." This general criterion is good, but we need further information that demonstrates how this done.

- Section A.2.d (pp 8/9); no mention of QA responsibilities for these managers

- Section B.12.a (p.15); it appears that !ine organization personnel perform inspections; not clear

- Executive responsible for operations and nuclear safety appears to have no responsibility for QAP implementation

- If the line organization personnel perform the inspections, how is independence maintained between doers and verifiers? Does the QAPM meet A.2.b of SRP 17.37 )

- is there a manager of maintenance?

• - QA functional responsibilities

- If line organization persosnel perform inspections, are personnel trained in QA technology?

- What is the extent of performance monitoring by the QA organization to assure proper QAPM implementation?

In the RBS QAP (see QAD-1, section 4.1.3), the Vice President, Operations maintains awareness of QA matters and QAP effectiveness by review of:

- audit and assessment results

- open item status reports

- NRC inspection reports

-independent management assessments / audits

- operating experiences

i o.

3 Are these responsibilities assigned to an executive in the new QAPD (see section l A.2.c)? The responsibilities of these executives should be further described with regard j to their management and guidance of plant activities through the managers that report I to thern. '

4

- Do the responsibilities of the executive for overall plant nuclear safety (Section A.2.c.1.) also include cognizance of NRC inspection activities, industry experiences, LERs, GLs, bulletins, and other in-house events (see ANO section 1.0 Organization, section 1.3.2, Director Nuclear Safety) ?

NRC requirements to demonstrate organizational acceptability:

The licensee's organization chart needs to demonstrate the QA Manager's freedom from undue cost and schedule pressures in the performance of QA responsibilities by showing appropriate reporting lines of authority to upperlevels of management. We are also interested in assuring that the QA Manager's ability to focus on QA matters is not  !

excessively diluted by the addition of other non-related responsibilities. So the organizational chart should also show the full complement of other functional areas.

The chart does not need to include specific titles, but should !ndicate general titles for each functional area; general descriptions of responsibilities for each title box can be delineated in the text. Of particular interest is an identification of what QA functions delineated in the QAPM are implemented by what organizational element. These are the general organizational factors that demonstrate conformance to Appendix B.

Previous commitments for implementation of QA functions not found in the QAPM:

- ANO: Executives / Directors and managers are responsible for QAP implementation; Director Quality responsible for implementation (pp.10/11); Section 2.3.2 states "that individuals responsible for verification of conformance are qualified and do not perform or directly supervise the work."

River Bend: Manager QA responsible for implemeritation of the QAPM (p.12/13)

- Grand Gulf: Director, Quality "provides" for implernentation of the QAP (See

" Organization", p.2 of 14 and Section 10.0, " Inspection", pp.1/2 of 5)

- Waterford: Director of Quality responsible for implementation of QAP (pp. 8-10);

inspections done by QA personnel, line organization personnel (peer maintanence), and contract personnel); QUESTION: A.1 rationale for deletion (p.111)???

Independent Review Proaram

- QAPD, Section A.2.e. provides a general statement of the purpose of the on-site and off-site safety review committees. Section A.2.c.1. states that the Executive, Overall Plant Nuclear Safety, is responsible for overseeing the activities of the off-site safety review committee. Section A.2.d.2.1. Indicates that the Manager, Piant Operations is functionally responsible for the on-site safety review committee. Table 1 indicates a

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commitment to RG 1.33 and ANSI N18.7 with an exception to Section 4.3.1 regarding the experience applicable to the on-site review committee, and the experience for the j l off-site committee (majority of areas). Please explain more specifically the requirements for members of these committees. What will be the membership composition of each j of these committees? In addition, an exception is taken to Section 4.3.2.3 whereby '

members with line responsibility for operation of the plant may now constitute a majority of the quorum for the on-site SRC (ses QAPM p.23). Please explain.

- ANO takes no exceptions to ANSI N18.7 in these areas.

- SRC has 8-12 members

- Qualifications satisfy all technical areas

- Meeting minutes within 14 days

- Meeting once per calendar month

- No exception to N18.7 f4.3.4(4)

- RBS

- Waterford

- Grand Gulf Lead Auditor Qualifications

- Table 1, RG1,146, item 2 (ANSI N45.2.23, section 2.3.4) should be supplemented by the following or words similar to the following::

"The process for demonstrating the ability to lead an audit team shall be documented in a procedure that requires evaluation and documentation of the results of the demonstration."