ML20237D977
| ML20237D977 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 08/21/1998 |
| From: | Krich R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20237D979 | List: |
| References | |
| NUDOCS 9808280093 | |
| Download: ML20237D977 (29) | |
Text
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l Commonwealth F.dison Company 1400 Opus Place
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Downers Grove, 11. 60515 5701
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August 21,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Byron Station, Units 1 and 2 Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 Dresden Nuclear Power Station, Units 1,2, and 3 Facility Operating License Nos. DPR-2, DPR-19, and DPR-25 NRC Docket Nos. 50-10. 50-237. and 50-249 Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374
Subject:
Clarification to Proposed Revisions to the Commonwealth Edison I
Company Quality Assurance Program dated April 23,1998
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Reference:
R. M. Krich letter to U.S. NRC, " Proposed Revisions to the Commonwealth Edison Company Quality Assurance Topical Report Uu([j xA (QATR), CE-1-A, Pursuant to 10CFR50.54," dated April 23,1998.
Pursuant to 10CFR50.54(a)(3) and 10CFR50.4(b)(7), Commonwealth Edison (Com Ed)
Company submitted actual and proposed changes to its Quality Assurance Topical Report (QATR) CE-1-A, Revision 66, as described in the above reference. The purpose of this letter is to modify the referenced submittal and to clarify certain of the changes to the QATR proposed in the April 23,1998, letter. These clarifications address the issues discussed during a telephone conference held between representatives of Comed and the NRC on June 4,1998.
9908280093' M 1 PDR ADOCK 05000010 W
PDR 1,
A Unicom Company
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August 21,1998 U.S. Nuclear Regulatory Commission i
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The Nuclear Safety Review Board (NSRB) will provide the oversight function previously performed by the Offsite Review and investigative Function. The NSRB will conduct reviews of each of the subjects delineated in revised QATR Section 20A.3.4. A separate group, under the auspices of the NSRB and independent of the organization responsible for the subject to be reviewed, may perform these reviews and report the results of its reviews to the NSRB. This group may also recommend full NSRB review of the subjects, as appropriate. Specifically, the previously proposed changes have been modified to require the NSRB to review written safety evaluations of changes to the facility or procedures, and tests or experiments that are completed under the provisions of 10CFR50.59. Tnis review will verify that such changes do not involve unreviewed safety questions and may be performed using a separate group, under the l
auspices of the NSRB, as described above. The modified NSRB review responsibilities are in conformance with Section 4.3.4, " Subjects Requiring independent Review," of American National Standards Institute (ANSI) Standard N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."
This change is consistent with the current commitments for review of safety evaluations and other review subjects and no longer constitutes a reduction in the level of commitment as previously described in the April 23,1998, letter.
This modification of the previous changes also proposes to eliminate the requirement to audit the NSRB. Consequently, the change includes a proposed reduction in the level of commitment as discussed in revised Attachment A-1. The proposed change to the QATR is shown in Attachment C on Page 5 of 6.
To facilitate your review, the changed pages from the April 23,1998, submittal are marked with revision bars and included in the attachments of this letter.
Respectfully, R. M. Krich l
Vice President - Regulatory Services I
Attachments cc:
Regional Administrator-NRC Region ill NRC Senior Resident inspector - Braidwood Station NRC Senior Resident inspector - Byron Station i
NRC Senior Resident inspector-Dresden Nuclear Power Station NRC Senior Resident inspector-LaSalle County Pation NRC Senior Resident Inspector - Quad Cities Nucinar Powuc Station l
NRC Senior Resident inspector-Zion Nuclear Porter Station
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ATTACHMENT A-1 General Description of Changes l
Nuclear Safety Review Board i
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Attachment A-1, Page 1 of 6 L
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Nuclear Safety Review Board /NSRB)
Description of the Change
" Administrative Controls and Quality Msurance for the Operational Phase of Nuclear Power Plants" (ANSI Standard N18.7-1976), hticle 4 recommends that l
an operating nuclear power plant to have programs in place to review activities l
that affect nuclear safety. The required revow activities are divided into two l main areas, independent review and operational review. The ANSI St adard suggests two organizational options for the per6rmance of the independent
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review function. The independent review function may be performed either by an established organizational unit, independent of the onsite organization, or it may be performed by a standing committee, in Comed's case, the Company has historically implemented the ANSI Standard N18.7-1976 recommendation l
through an offsite organization using a process entitled the Offsite Review and investigative Function.
This proposed revision to the Quality Assurance Topical Report (QATR) will eliminate the Offsitn Review and Investigative Function, for Comed's operating l plants, and implemant the offsite review responsibility using the other optio allowed by ANSI Standard N18.7-1976. These committees are collectively referred to as the Nuclear Safety Review Boards (NSRBs). The NSRBs will be l-comprised of senior corporate and site management personnel and consultants l
that will pe form a collegial, multi-disciplined review of site activities. The use of J
NSRBs is consistent with the industry approach to provide the independent offsite review function.
Comed will cudque to perform the independent safety review function using the historical Ofrxe Review approach for its permanently shutdown plants (i.e.,
Dresden Nuclear Power Station Unit 1, and Zion Nuclear Power Station Units 1 and 2).
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l Reason for the Change Comed is committed to improving nuclear station performance in meeting this commitment, the Company has critically examined many of its practices to determias where significant improvements could be made. When compared to the best industry practices, Comed's use of a consolidated corporate safety l
l review process was considered an outlier. By letter dated, February 17,1998, I
Comed outlined thirteen strategic reform initiatives. One of the initiatives is to j
realign the Nuclear Generation Group (NGG) oversight processes to ensure requisite checks and balances. To this end, the current Offsite Review and investigative Function is being transferred to the NSRB.
l' Attachment A-1, Page 2 of 6
1 As mentioned above, Comed has historically performed independent reviews through a Corporate department. The reviews were typically performed by two highly experienced individuals whose work was approved by the manager of the department (i.e., the Director of Safety Review). The reviews and approvals were performed sequentially. As part of the Corporate organization, the Safety Review group reported to the Nuclear Oversight Manager. The Nuclear Oversight Manager in turn reported to the President and Chief Nuclear Officer (CNO).
In transitioning to the NSRBs, the NSRBs become a more integral part of Comed's nuclear oversight process by independently and directly assessing the performance of the stations and advising the Chief Nuclear Officer (CNO) with respect to nuclear safety performance. Specifically, the Nuclear Safety Review Boards will advise the CNO on their assessment of facility operations and the adequacy and implementation of the Nuclear Generation Group nuclear safety policies and programs. Based on this assessment the NSRB will provide recommendations to the sites to improve nuclear safety and plant reliability.
The NSRB will function as a collegial body that uses the professional experience l
and expertise of its members in advising the CNO on matters related to nuclear i
safety. The NSRB is expected to add value to the nuclear safety system of checks and balances, and have a positive impact on the oversight function by effectively reviewing and integrating issues that come from all elements of the
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NSRB Additions to Commitment Several additions to the commitments in the Quality Assurance Program occur with the transition to the NSRBs. Each significant addition is described in the following text.
- 1. Current QATR Section 20, Article 3.1 transitions to Proposed Section 20A, Articles 3.1.1 and 3.1.3.
Addition: (1) NSRB is responsible for the Offsite Review and Investigative Function, (2) NSRB Chairperson is appointed by the President, NGG and Chief Nuclear Officer and (3) NSRB is independent and reports directly to the President, NGG and Chief Nuclear Officer on nuclear safety matters.
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- 2. Current QATR Section 20, Article 3.2 transitions to Proposed Section 20A, Articles 3.1.1, 3.1.2, 3.1.5, 3.2.1, 3.2.2, and 3.2.3.
1 Addition: The NSRB Chairperson will have responsibility for providing i
direction to the NSRB and assuring that the membership collectively possesses the backpound and qualifications in the subject matter under l
l Attachment A-1, Page 3 of 6
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review. The Chairperson reviews and approves the findings and l
recommendations developed by the NSRB.
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- 3. Current Section 20, Article 3.2.1.f transitions to Proposed Section 20A,
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Article 3.4.7.
1 Addition: This requirement has been expanded to include reviews of
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l significant operating abnormalities l
- 4. New commitments appear in Proposed Section 20A, Articles 3.3 inclusive.
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%ddition: This new Section provides detailed functions of the NSRB and
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describes the relationships of the NSRB to the CNO to advise and make l.
recommendations on issues that affect nuclear safety.
l 5. New commitments appear in Proposed Section 20A Articles 3.7 and 3.7.1.
Addition: The current Section 20 does not prescribe formal meeting ut the i
Offsite Review Function; reviews are conducted on an ongoing basis and reports are sent to the stations. The new Section 20A will implement formal NSRB meetings no less frequently than twice per year.
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NSRB Clarifications The following two editorial clarifications are made to help in the transition to the l
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- 1. Current Section 20, Article 3.2.1.J transitions to Proposed Section 20A Article 3.4.10.
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Clarification: The revised proposed text deletes the System Engineering Supervisor or the System / Component Engineering Manager. A site Engineering Representative will be a defined member of the PORC.
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Current Section 20, Article 3.2.2.a transitions to Proposed Section 20A, Article 3.6.1.
The minutes of the NSRB will include a discussion of reviews, audits, and l.
recommendations.
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l NSRB Reduction to Commitment The change to transition onsite review and offsite review to PORC and NSRB does not constitute a reduction in commitment except as detailed below.
l Attachment A-1, Page 4 of 6
Current Section 18, Article 3.1.2.e will be revised to be applicable to the Onsite I
and Offsite review functions for permanently shutdown plants, and PORC.
Present Commitment: Currently per Section 18, Article 3.1.2.e, audits of the Offsite and Onsite Review Functions are conducted on a planned and periodic frequency.
Reduction: As a result of changing the Offsite and Onsite review functions as l
j described in this submittal, audit of NSRB will not be conducted. Rather, NSRB activities will be periodically reviewed for effectiveness.
I Justification: ANSI Standard N18.7-1976 Section 4.1 states in part
" programs for review and audits shall, themselves, be periodically reviewed for effectiveness by management of the owner organization." The membership of the NSRB includes senior level management, and full voting members from the Nuclear Oversight and Regulatory Services Organizations.
The NSRB reports to and is accountable to the CNO, and also provides oversight of PORC activities. Participation at this level of management will ensure adequacy and effectiveness of the NSRB. Furthermore, the effectiveness of the NSRB functions will be demonstrated by the performance of the Sites as evidenced by Nuclear Oversight audits and assessments results, corrective action program and performance indicators. These oversight activities will provide alternative sources of performance information to alert senior management of weaknesses in NSRB reviews. In addition, rather than auditing the activities of the NSRB, a periodic review will l
be performed for effectiveness.
Audits of the Offsite and Onsite Review processes, at the permanently shutdown plants, and PORC will continue per revised Section 18.3.1.2.e.
l Bases for Compliance with 10CFR50, Appendix B L
Compliance with the 10CFR50, Appendix B, Criterion XVill, audit requirements as described in the Comed Quality Assurance Program have not changed. As noted above, ANSI Standard N18.7-1976 requires periodic review by management of review and audit programs for effectiveness. Comed chose to t
use the audit program to satisfy the requirement to review of Onsite and Offsite review functions.' Rather than performing audits, a periodic review of NSRB l
activities will be performed for effectiveness as required by ANSI Standard N18.7-1976. Thus, the audit program and compliance with 10CFR50, Appendix B, Criterion XVill, remains unchanged.
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Attachment A-1, Page 5 of 6 j
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1 ATTACHMENT A-2 General Description of Changes Plant Operations Review Committee i
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Attachment A-2, Page 1 of 4
Technical Review and the Plant Operations Review Committee Description of the Change The preceding Attachment A-1 primarily concemed the recommendations of l ANSI Standard N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," for the independent review process. This section primarily concems the recommendations for the operational review area. In this area, Comed has historically implemented the ANSI Standard recommendations through onsite organizations using a process entitled the Onsite Review and investigative Function. Each station has its own onsite organization, performing station specific operational reviews.
This revision to the Quality Assurance Program as documented in the Quality Assurance Topical Report (QATR) will replace the Onsite Review and investigative Function by implementing a Technical Review function and the Plant Operations Review Committee (PORC).
The Technical Review function is intended to provide a multi-disciplined, detailed technical review of an activity within the line organization. This l Technical Review function is included within the site work processes and departments. A strong Technical Review program is a critical element in the overall review program.
PORC will provide a collegial, in-line, multi-disciplined review of work products with an emphasis on nuclear safety and system interactions. The PORC will rely on having a detailed technical review being performed prior to a work product being submitted to the PORC for review.
Comed will continue to perform the operational review function using the historical Onsite Review approach for its permanently shutdown plants (i.e.,
Dresden Nuclear Power Station Unit 1, and Zion Nuclear Power Station Units 1 l
and 2).
I Reason for the Change As stated ~in Attachment A-1, Nuclear Generation Group (NGG) management is examining its oversight processes to ensure that they include all requisite checks and balances. One of the action items, resulting from the examination, is to transition Comed's current Onsite Review and Investigative Function to the Technical Review process and the use of PORC. The transition is consistent with generalindustry practices.
l Attachment A-2, Page 2 of 4
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Comed had previously implemented the PORC process, but maintained the Onsite Review and Investigative Function to meet review requirements in the Quality Assurance Program. In essence, the Onsite Review and the PORC l functions are both reviewing most of those activities prescribed in the QATR, l
Section 3.3. This practice resulted in a duplicity of effort and commitment of resources that is not required. The NGG management, therefore, has determined that the PORC function be established as the operational review 4
process at the operating sites and that the Onsite Review function be eliminated.
Technical Review and the PORC - Addition to Current Commitment Comed's operational reviews have been historically performed by the Onsite Review and investigative Function. Reviews were performed by a complement l
l of at least two highly experienced individuals and independently approved by the I
Station Manager. In general, the reviews and approvals were performed j
sequentially. As part of the station organization, the Onsite Review function l
j reports to the Station Manager / Plant General Manager who, in turn, reports to l
the Site Vice President.
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In transitioning to Technical Reviews and PORC, reviews become a more l~
integrated part of nuclear operations. The benefits of the Technical Review
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process include; (1) reviews are completed by the line organization that l
possesses the necessary technical expertise to perform a thorough review; (2) a I
l sense of ownership and accountability is established in the line organization for l
l the work processes; and (3) duplicate reviews are minimized.
l Once PORC has reviewed a product, the item will be submitted to the Station Manager / Plant General Manager for independent review and approval. PORC l members will be required to meet the same qualification requirements currently stipulated for Onsite Review members. However, the PORC process differs from Onsite Review in that the PORC upgrades the onsite review process by j
implementing a collegial, multi-disciplined review of issues. PORC will have a defined membership, quorum requirements, and a criterion for alternates, formal agendas and meeting minutes, and a comprehensive listing of responsibilities.
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. Overall, the Technical Review and PORC functions provide a substantive l
addition to the present processes instituted to meet the current QATR, Section 20 requirements. Furthermore, the PORC will provide an in-line management
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. review process that is consistent with current practices in the nuclear industry.
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l Bases for Compliance with 10CFR50, Appendix B l The Comed Quality Assurance Program, as is described in the QATR, complies with the regulatory position of Regulatory Guide 1.33, " Quality Assurance l Program Requirements (Operation)," Revision 2, February 1978. The regulatory position states, "The overall quality assurance program requirements for the l.
Attachment A-2, Page 3 of 4
operation phase that are included in ANSI N18.7-1976/ANS-3.2 are acceptable l
to the NRC staff and provide an adequate basis for complying with the quality assurance program requirements of Appendix B to 10 CFR 50...." Attachment D of this transmittal contains a matrix of ANSI Standard N18.7 requirements l
compared to the provisions of the Quality Assurance Program regarding operational and technical reviews. The matrix demonstrates that all of the i
recommendations of the ANSI Standard are included in the revised Quality Assurance Program, in summation, since the Quality Assurance Program provisions for the Technical Rewsw and PORC functions meet the applicable recommendations of the ANSI Standard, and the ANSI Standard is sufficient to l
meet 10CFR50, Appendix B, these processes continue to satisfy the applicable criteria of 10CFR50, Appendix B.
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l ATTACHMENT A-3 q
General Description of Changes Permanently Shut Down Plants i
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Attcchment A-3, Page 1 of 2
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Permanentiv Shut Down Plants Description of the Change For Comed's permanently shut down plants (i.e., Dresden Nuclear Power Station Unit 1 and Zion Nuclear Power Station Units 1 and 2), operational reviews will continue to be performed by the Onsite Review and investigative Function. Independent reviews will continue to be performed using the Offsite Review and investigative Function.
Section 200 has been revised to describe the Onsite and Offsite Review requirements as they apply to permanently shutdown plants. This revision also includes some editorial changes such as titles changes and deletion of redundant information that appears in other sections of the QATR. See Attachment E.
Bases for Compliance with 10CFR50, Appendix B The Comed Quality Assurance Program, as described in the QATR, has been reviewed and approved by the NRC, as meeting the requirements of 10CFR50, Appendix B. The description of the Onsite and Offsite Review processes was included in the QATR at the time of NRC approval. This revision reflects only those editorial and organizational changes necessary to tailor the processes to apply to the permanently shut down plants. Since only editorial and minor organizational changes are being made, the Quality Assurance Program remains in compliance with 10CFR50, Appendix B.
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Attachment A-3, Page 2 of 2 l
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l ATTACHMENT B i
QATR MATRIX l
Current Section 20 to Proposed Version 20,20A & 20B 1
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BACKGROUND Comed will transition the current Offsite Review process to the Nuclear Safety Review Boards and the current Onsite Review process to the Plant Operations Review Committee, for its operating plants. The current Offsite and Onsite Review processes are described in the QATR, Section 20. For the transition, the NSRB and PORC requirements have been incorporated into a revised Section 20. The revised Section will be made up of four parts; Section 20 (Base), Section 20A (NSRB), Section 208 (PORC) and Section 200 (Offsite &
Onsite Review). This matrix was prepared to document the differences between the current and proposed editions of the QATR, Sections 20,20A & 208. A line-I by-line review has been completed and the differences between the current document and the revised document are noted as being editorial or substantive.
Substantive changes are further classified as broadening a commitment (+) or reducing the commitment (-).
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l in consideration of some general changes, Nuclear Operations has been renamed the Nuclear Generation Group. Responsibilities of the Offsite Review and Director of Safety Review have been transferred to the NSRB. Likewise, the responsibilities of the Onsite Review have been transferred to the PORC and Technical Reviewers.
With the proposed changes to QATR Section 20, other QATR Articles must be revised to delete reference to Safety Review, Safety Review Board coordination, Director of Safety Review and Safety Review Board Liaison. Please refer to Attachment C.
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l 13.3.3.13
' 20B; 3.4.7.7 Editorial l
1.3.3.14 20B; 3.4.7.1.8 Editorial l
3 I3.3.3.15 20B; 3.4.7.9 Editorial l
l 3.3.4, all 208; 3.6, All Substantive +
l 13.3.5, Sentence 1 20B; 3.5, Sentence 1 Editorial l
l 3.3.5, sentence 2 20B; 3.5, Sentence 2 Same l
l3.3.5.a 20B; 3.5.1 Editorial l
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l3.3.5.b 20B; 3.5.2 Same I
j l3.3.5.c 20B; 3.5.4 Editoral l
1 l3.3.5.d 208; 3.5.34 Same I
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l3.3.5.e Satisfied by QATR Section 5, Editorial l
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Atticle 3.1 1
I 3.3.5.f 20B; 3.5.5 Same l
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3.3.6, All 20B; 3.4.1, Sentence 1 &
Editorial Article 3.4.1, All I
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l4 20, 4, all-Editorial l
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Attachment B, Page 5 of 5
l ATTACHMENT C Textural Changes to Other Sections of the QATR Required to Support NSRB and PORC transition l
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' introduction: To implement the proposed changes in the Onsite and Offsite review functions the following revisions to the QATR are required:
QATR Revision 65h, Section 1 does not currently contain a description of the reporting relationship between the NSRB Chairperson and the President and Chief Nuclear Officer, it also does not include a description of the NSRB Chairperson's responsibilities. The QATR will be revised to include these two provisions.
Section 1 will be revised to include the following text, The NSRB Chairperson reports directly to the President and Chief Nuclear Of6cer. The Chairperson is independent of operations. He is responsible for reviewing and approving the 6ndings and recommendations of the NSRB and l advising the President and Chief Nuclear OfRcer on the adequacy and implementation of Comed nuclear safety policies and programs. The l
Chairperson fulRIls these responsibilities through the activities of the Nuclear Safety Review Boards.
. - QATR Revision 65h, Section 1, Article 3.4.1.3.1.2.1 does not currently include a requirement for the Decommissioning Plant Manager to have responsibility for the Onsite Review process. The Article will be revised to include this provision.
The Article will be revised to include the following text, The Decommissioning Plant Manageris responsible for the permanently shut down plant's onsite review function.
QATR Revision 65h, Section 1, Article 3.4.1.3.2 currently states, in part, The Nuclear Oversight Manager manages the Quality Assurance Program and Safety Review...He is also has senior management responsibility for the it. dependent Safety Engineering Group Function, quality control, corrective
, action process administration, Safety Review coordination, and Employee Concerns Program.
With the implementation of the NSRB's, the responsibilities of the Nuclear o
Oversight Manager change, including his title. The Article will be revised to l
-state, The Vice President, Nuclear Oversight manages the Quality Assurance Program and Offsite Review (for the permanently shut down plants). He is also has senior management responsibility for the independent Safety Attachment C, Page 2 of 6 l
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_______________________________________________________________________________-._______________-.------------________________________._._________J
i Engineering Group Function, quality control, corrective action process administration, and Employee Concerns Program.
. QATR Revision 65h, Section 1, Article 3.4.13.2, also, currently states, in
- part, The Nuclear Oversight Manager fulfills his responsibilities through a staff that includes:
Director of Safety Review Safety Review Board Uaison The positions of the Safety Review Board Liaison and Director of Safety l
Review will be eliminated with the transition to the NSRBs. An Offsite l
Review senior participant will be assigned to function as the Director of Safety Review for activities involving Offsite Review for the permanently shut down plants. This Article will be revised to delete these positions and change the title of the Oversight Manager to the Vice President Nuclear Oversight.-
QATR Revision 65h, Section 1, Article 3.4.1.3.2.2, currently states, in e
- Part, The Director of Safety Review and his staff provide the independent safety review function for station activities on a routine basis.
The function of the Offsite Review senior participant will replace the Director l
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of Safety Review for the independent safety review process at the permanently shut down plants. This Article will be revised to state, i
The assigned Offsite Review senior participant coordinates the independent l
safety review function forpermanently shut down plants on a routine basis.
e ', QATR Revision 65h, Section 1, Article 3.4.1.3.3.1.1 currently states, in part, The Station Manager (Braidwood, Byron, Dresden, & Zion) or Plant General Manager (LaSalle) supervises the Station's onsite review function.
With the transition to PORCs at the operating stations, The Article will be revised to state, The Station Manager (Braidwood, Byron, & Dresden Units 2 & 3) or Plant General Manager (LaSalle) provides supervisory direction for the technical review program and the Plant Operations Review Committee.
l Attachment C, Page 3 of 6 l
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. QATR Revision 65h, Section 1, Article 3.4.1.3.3.1.1.a currently states, in
- part, The Station Manager (Quad Cities) supervises the Station's onsite review function.
For the same reason given above, the Article will be revised to state, The Station Manager (Quad Cities) provides supervisory direction for the l
technical review program and the Plant Operations Review Committee.
QATR Revision 65h, Section 1, Article 3.4.1.3.3.1.4.1 currently states, in
- part,
... [The System Engineering Supervisor and the System / Component Engineering Manager] or other comparably qualified individuals are designated as the senior participant to provide appropriate direction for the Onsite Review function.
The Article will be revised to eliminate the assignment of this responsibility to these specific positions. A new requirement will take its place. The l
requirements are included the newly proposed QATR Section 20B, Article 3.2 that states,
[The Station Manager / Plant General Manager shall] appoint an individual to l
provide appropriate coordination of PORC.
QATR Revision 65h, Section 5, Article 3.3.1.c currently states, Applicable Administrative Procedures recommended by Regulatory Guide 1.33, Plant Emergency Operating Procedures, and changes thereto shall be submitted to the Onsite Review and Investigative Function for review and l
prior to implementation.
Due to the transition to PORCs at operating plants, the Article will be revised to state, i
Applicable Administrative Procedures recommended by Regulatory Guide 1.33, Plant Emergency Operating Procedures, and char.qes thereto shall be submitted to the Plant Operations Review Committee (PORC) as applicable, for review prior to implementation. The PORC shall recommend approval or disapprovalbased on their review.
QATR Revision 65h, Section 5, Article 3.3.1.d currently states, in part, l
Attachment C, Page 4 of 6
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l Onsite Review, Offsite Review and Commission approval ofitems involving l
unreviewed safety questions shall be obtained prior to station approval for l
implementation.
With the transition to NSRBs and PORCs at operating plants, the Article will j
be revised to state, l
l The PORC and the Nuclear Safety Review Boards shall review and recommend approval ofitems involving unreviewed safety questions prior to station approval forimplementation. NRC approval shall also be obtained prior to station approval forimplementation.
l. QATR Revision 65h, Section 17 Article 3.10.2 currently states, in part, Minutes of meetings and results of reviews performed by the Offsite and Onsite Review and Investigative Functions [shall be retained for the life of the plant].
The Article will be revised to state, Minutes of meetings and results of reviews performed by the Nuclear Safety l
Review Board and the Plant Operations Review Committee [shall be retained forthe life of the plant].
. QATR Revision 65h, Section 18, Article 3.1.2 currently states, in part, Audits shallinclude the following safety-related functions:
1 e.
Onsite and offsite reviews.
l The Article will be revised to state, Audits shallinclude the following safety-related functions:
- e. Onsite Review and Offsite Review forpermanently shut down units only, and PORC.
l QATR Revision 65h, Appendix A / Definitions currently contains a definition for Offsite Review that states,
[Offsite review is] the offsite review and investigative function required by the l
Technica, Specifications.
The definition will be revised to state, i
l Attachment C, Pege 5 of 6 l
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4 Offsite review is the offsite review and investigative function required by the Technical Specifications. Offsite review requirements are satisfied by the Nuclear Safety Review Boards.
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QATR Revision 65h, Appendix A / Definitions currently contains a definition for Onsite Review that states,
[Onsite review is] the station review and investigative function required by the Technic.al Specifications.
The definition will be revised to state, Onsite reviewis the onsite review and investigative function required by the Technical Specifications. Onsite review requirements are satisfied by the Technical Review program and the Plant Operations Review Committee at the operating plants.
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Attachment C, Page 6 of 6 l
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i ATTACHMENT D Comparison Matrix NSRB and PORC Processes To l
ANSI Standard N18.7-1976 Recommendations i
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==
Introduction:==
The following matrix shows how the recommendations of ANSI Standard N18.7-1976 are satisfied by the NSRB and PORC processes. ANSI Standard recommendations are identified using their article, paragraph (Para.) and sentence (Sent.) numbers as they are found in the text of the Standard. The ANSI Standard recommendations are listed to the left of the vertical, dark gray band. To the right of the band is the location (section, article, paragraph and sentence) within the QATR, where the recommendation is satisfied. The " Comment" field on the far right is used to distinguish between two or more recommendations within one ANSI Standard sentence or provide clarification.
ANSI Standard 18.7 - 1976 OATR Revised Section 20,20A, or 20B
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1 W 20 1
1 1
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E l 4.1(1) 1 1
E 20A 3.1.2 1
1 ANSI Standard N18.7-1976 4.1(1) 1 1
E 20A 3.1.1 1
2 Implementation 4.1(2) 1 1
20A 3.4.1 1
1 Plant and Procedures
& 3.4.2 1
1 4.1(2) 1 1
20A 3.4.1 1
1 Tests
& 3.4.3 1
1 4.1(3) 1 1
E 20A 3.4.5 1
1 10CFR50.73 (Not 24 hrs) 4.1(4) 1 1
E 20A 3.4.7 1
1 4.1 2
1 20A 3.8.1 1
1 Review of NSRB 18 3.1.2 Audits 4.2 1
1 E 20A All All All 4.2(1) 1 1
E 20A 3.4 All All 4.2(2) 1 1
20A 3.1 All All Authority 3.3 All All 4.2(2) 1 2
E 20A 3.3.2 1
1 For finding problems 4.2(2) 1 2
E 20A 3.3.5 1
1 For verifying C/A 4.2(2) 1 3
- 20A 3.3.2 1
1 1
& 3.3.3 l
4.2(3) 1 1
5 20A 3.7.1 1
1 l
4.2(4) 1 1
5 20A 3.2.1 1
1 l
4.2(5) 1 1
E 20A 3.4 All All 4.2(6) 1 1
E 20A 3.6.1 1
1 l 4.2(7) 1 1
E 20A 3.3.3 1
1 4.2(8) 1 1
E 20A 3.5.1 1
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Attachment D, Page 2 of 4
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4.2(9) 1 1
- 20A 3.3.5 1
1 4.2(10) 1 1
_ 20A 3.5 All All um 4.3 1
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- 20A 1
1 All 4.3 1
2 N/A N/A N/A N/A Plant is already operational 4.3.1 1
1 20A 3.2.1 1
1 Includes all 10 disciplines
& 3.2.2 1
1 4.3.1 2
1 20A 3.2.2 1
1 4.3.1 2
2 20A 3.2.1 1
2 4.3.1 2
3 20A 3.2.2 1
1 4.3.2 N/A N/A N/A N/A N/A N/A Heading, not a requirement 4.3.2.1 1
1 E 20A 3.2.1 1
1&4 4.3.2.1 1
2 E 20A 3.2.3 1
1 4.3.2.1 1
3
- 20A 3.2.1 1
3 4.3.2.2 1
1 20A 3.7.1 1
1 4.3.2.2 1
2 E N/A N/A N/A N/A Plants are operational l
4.3.2.2 1
3 E 20A 3.7.1 1
1 4.3.2.3 1
1 20A 3.2.1 1
1,3,&
4 4.3.2.4 1
1 M 20A 3.6.2 1
1 l 4.3.2.4 1
2 m 20A 3.5.3 1
1 4.3.2.4 1
3 20A 3.6.1 1
1 Minutes include decisions and recommendations 4.3.2.4 1
4 E 20A 3.6.1 1
1 4.3.3 All All E N/A N/A N/A N/A Option not exercised 4.3.3.1 All All E N/A N/A N/A N/A Option not exercised 4.3.4 1
1 E 20A 3.4 1
1 4.3.4(1) 1 All E 20A 3.4.1 1
All 4.3.4(2) 1 All E 20A 3.4.2 1
1 Plant 4.3.4(2) 1 All 20A 3.4.3 &
1 1
Tests 3.4.4 1
1 Technical Specifications 4.3.4(3) 1 1
E 20A 3.4.4 1
1 4.3.4(4) 1 1
E 20A 3.4.5 1
1 10CFR50.73 (Not 24 hrs.)
4.3.4(4)(a) 1 1
E 20A 3.4.6 1
1 4.3.4(4)(b) 1 1
E 20A 3.4.7 1
1 4.3.4(4)(c) 1 1
E 20A 3.4.5 1
1 10CFR50.73 (Not 24 hrs.)
4.3.4(4) 2 1
E 20A 3.3.4 1
1 4.3.4(5) 1 20A 3.4.8 &
1 1
3.4.10 1
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Attachment D, Page 3 of 4 1
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20B 3.4.7.2 T"--"1 ests 3.4.7.3 I
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of 24 hrs) p 208
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4.1 p
20A 1
T---p NSRB Function 4.4 7
1 208 F
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208 gqwement 4.4 7
1 208
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1 3.4.7
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W p-1 208
_3.4.7 77 hp E
3 20A
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3 QATR ct
' AlI Audits
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208
_3.2.6 I'3 l
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5 208 3.2.6 & IF-
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~ ~ ~ - - ~ - ' - ~ ~ - - - - -
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I Attachment D, Page 4 of 4
ATTACHMENT E Description of the NSRB and PORC Processes Revised QATR Section 20 (Sections 20,20A,208, & 20C) l i
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