NRC-94-0053, Provides Comments on PRM-50-60 Re Emergency Preparedness Independent Audit Frequency

Provides Comments on PRM-50-60 Re Emergency Preparedness Independent Audit Frequency

ML20070C254
Person / Time
Site:	Fermi
Issue date:	06/24/1994
From:	Gipson D DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-94-0053, CON-NRC-94-53 NUDOCS 9407050147
Download: ML20070C254 (7)

Text

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Doupes R. Gipson I

Seno Vice President Nuclear Gene, anon Detroit Edison

~3t3)588-5249 6400 North Dis's High*ay

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June 24, 1994 NRC-94-0053

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U. S. Nuclear Regulatory Commission Attn: Document control Desk N,

4 Washington, D. C.

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References:

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Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43 g

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Federal Register, Vol. 59, No. 71, PRM-50-60,! dated April 13, 1994 L,

Subject:

Comments on Notice of Receipt of Petition for Rulemaking on Emergency Preparedness Independent Audit Frequency Detroit Edison agrees with the ideas expressed in Virginia Power's petition for rulemaking, but believes additional changes are warranted. This letter provides comments 'on auditing of emergency preparedness and also includes a discussion of audits of other areas.

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The area of emergency preparedness is especially appropriate for performance-based audit scheduling since periodic drills and exercises provide a clear indication of performance as well as the best

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opportunity for performance-based auditin'g.

It does not make much sense to audit emergency preparednesi during a refueling outage' f

because the 12 monta frequency is due'.

It would be a better use of resources to audit a refueling ontage activity, especially an area of weak or challenged performance d'uring the outage.

Also, a better emergency preparedness audit could be conducted if the audit was scheduled during performance of a drill or exercise so emergency respouse personnel performance could be assessed.

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The general weakness of a frequency-based audit program is that audits must be scheduled independent of when activities are being performed in the functional area.

In fact, a frequency'-based audit program can require auditing when no activities are being pe'eformed.

A truly perforeance-based audit program is based on both the quality of performance in the functional area and on when activities are being performed. Such a performance-based audit program requiring that periodic audits be scheduled based on performance provides for the most effective use of auditing resources.

Poor performing areas arc audited more often, areas of superior performance less often.

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audit schedules should be flexible so audits can be scheduled when

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USNRC June 24, 1994 NRC-94-0053 Page 2 activities are in progress. For these reasons, Detroit Edison believes the rule should require periodic review of the emergency preparedness progran rather than a review every 12 or 24 months. The description of the performance-based auditing program should be included in each licensee's Quality Assurance Program, i

Additionally, the same philosophy applies to other audit frequencies specified by rule. These include audits of the Safeguards Contingency Plan, Security Program, Access Authorization, Fitness for Duty Program, Fitness for Duty laboratory and other contractors, Environmental Protection and Radiation Protection.

The rules governing these audits should also be revised to require periodic audits versus 12 or 24 month audits or to eliminate covering audits so all audits could be addressed in the Quality Assurance Program rather than have requirements scattered across many rules and guidelines.

Since licensees cannot reduce commitments in the Quality Assurance Program without prior NRC review, the HRC would retain mandatory oversight over changes to the audit program that would reduce audit frequency.

This idea of providing flexibility to the audit program to better focus the efforts of audit and surveillance personnel on how to improve weak or declining performance areas was presented during the 1993 Public Workshop on NRC's Program for Elimination of Requirements Marginal to Safety.

Attached is an excerpt from that meeting's proceedings, published as NUREG/CP ' 129 s

In summary, Detroit Edison agrees with Virginia Power's request that the audit requirement for emergency preparedness be revised, but believes further rule changes should be made so that no audit frequencies are specified by rules and auditing can be based on This change would enable development of an improved performance.

audit program responsive to plant performance.

If you have any questions regarding these comments, please contact Ms. Lynne S. Goodman at (313) 586-4097 Sincerely, s

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Attachment cc:

T. B. Colburn J. B. Martin M. P. Phillips K. R. Riemer i

Quality Assurance Requirements questi The urpose is to receive in ut from,ons.

tudustry an any members of the public

'n attendance.

9. Quality Assurance Requirements Ap endix B to 10CFR Part 50 establishes qua$ity assurance requirements for the design, j

construction, and operation of structures.

systems, and c mp nents that prevent or 9.1 Ernie Rossi mitigate the consequences of postulated Nuclear Regulatory Commission accidents that could cause ur.due risk to the health and sarety of the public. There are a number of perceived problems with NRC The purpose of this session is to obtain input quality assurance requirements and with our from the panclists and audience on proposed practices in implementing them.

I will modifications to the NRC's requirements and rnention several of the more important ones practices in the area of quality assurance. We for you to think about dunng this session.

are also interested in supporting justification and bases for any proposed modifications that

1. As implemented, quality assor9cc people may have.

programs may emrhasize documentation over performance.

Particular issues for consideration include the t

burden, nature and extent of the regulatory's quality

2. Responsibility for quality is often including the cost impact of the NRC the gur.lity to lie in perceived assurance requirements and practices, and assurance, organization rather than the arguments that any specific requirement or line organization.

practice is marginal to safety.

3. The list of items to which quality We would like participants' input on the assurance requirements are applied is definition and use of performance-based assurance requirements, the risk far larger than was originally qual,ity contemplated.

significance of quality assurance requirements, and actual Appendix B requirements versus Having stated these possible problems with the the,NRC staff's interpretation of the NRC's approach tc, quality assurance-and requirements.

l'm sure there are mar.y other problems that may come up during this session-we,will now i

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The panel session has been orfst will make a ask our panelists to make their presentations.

anized in the 1

followmg sequence. Each panet 10 minute presentat on from the podium, i

1. .2 Lynne Goodman 9

using overhead slides if they wish. Members of t,he audience who had previously, indicate,dDetroit Edisor-their intention to speak will provide their remarks, taking no more than 10 minutes. We Improving Effectiveness of have only one member of the audience who Performance Based Audit Programs has asked to make f nul remarks at this by Reducing the Regulatory Burden

session, After the formal presenuties.n have been I'm going to'be talking about how to improve-not reduce, but improve-the made, the session will be open for other effectiveness of performance-based audit members of the audience to provide remarks, ask questions, and participate in discussions programs by eliminating some. of the I'm going to be talking regulatory burden.

with the panelists ar other members of the about the audit program. An audit is a look,at I ask that anyone speaking provide how the organization is performing,tts audience.

his or her name and organization / affiliation activities, how those activities are bemg very clearly, so that our transedber can take accomplished, and comparing them to that down, established requirements and also to our management expectations.

I would like to emphasize that the purpose of this workshop is not for the NRC to present or answer positions, defend pos'itions, W R M is0 119 septemt>er 1993 r---+-t

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Ott.ifily Anurance Requirements

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audit program more effective so that we're Audit actually looking at things at the time it makes sense to look at them.

A formal independent osamenation wiin intent to vene, conformance with esiaeir,ned >,quir.monis (Ansi Nie 7)

There are a number of requirements for audit programs. I am going to go over just a couple of them. One of the key ones is Section 6 of our tech specs. We have an environmental protection plan, Appendix B, and a number of We have a perfortnance based audit program, ther requirements for audit.

That means we watch people's performance at work as opposed to just looking at paper.

Requirernents for Perforrnance Audits I'd like to tell you about an audit of our (con tin u sed) emergency planning organization that we performed in February. We spent 220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> tocFR73 5s (g) (4)

• Secunt/ Program auditin,g our emergency preparedness. W Nuneo cn*4o simulata detenmned we did quite well We did a lousy audit.

nog culde 1,155 Station Drackout We did our audit in February of this year MS"cT*e' jtde'nT' "**" "' '*" " '

because the regulations require that we audit every 12 months. We could not wait until nog oum 4.1 Environmennt Protecten.

March, when we had a scheduled drill, because then we would have been out of compliance neg cuide t.a3 with the regul tions. So we did an audit, we n g ouide u44 got results. we met every regulatory requirement there ww But as I said, we did a ANsl N t 9.7 Y

ANSI /ASME N45.2.12 An* program as contained in updated Final Safray oA ys4 neport or oA Topear neport Requirements for Performance of Audits Lyw Oorxpan ska 3 Tecnnical Specifications Section 6 Environmental Protection Pian The Er,t goes on and on, including regulatory guides and NUREGs. There are a number of tocrnso wem places th:t have audit requirements. Some tocrnr3 se to) m. Access Autnorizat-n haee frequency requirements, some have just tocFnso $4 (t) Emergency Preparedrass iocrnri.iar. Environmeniai erotection nee > active Our other governing document is our QA piogram. For us, that's in our Updated Fir.al iocr n28. ritness io, outy Safety Analysis Report. For some plants, it's in a topical report.

toCrR26 80 citnest Si Outy Testing Lab The frequency of audits ranges from 6 raonths tocrnro i toi. nadiowu proiroon to 36 months, depending on the audit topic.

tocFnso s4 to). sareguards conimeency Pa W th very few exceptions, there is no f,exibility permitted for schedule extension. Tnat leads tocrnra 4o to). sa aguares contingency Pian r

to resource waste, as I mentioned 'vith our 4 aor.n:===

emergency planning audit; we got very little benefit from that audi other than meeting our t

technical specification regulatory requirement.

In March, we did a surveillance during the scheduled drill. That's the type of thing I want to talk about-how we can make oer September 1993 120 liUREG/CP-0129

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Qelity Assurance Requirements The frequency requirement can take resources Frequency of Audits por Flequirements and from non problem areas, if you have a Problem developing, it would make a lot more 6 me n ha 36 months sense to look at the problem area.

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ne s in N rnanntenance organir.atton that we{d like to With few exce[tions, no fiexibiltry permitted for schedule extension. eads to resource waste with no benefit.

explore, we have to balance the need to look at Perform audits when ave regardo.: of aci,v,i,e. in de, maintenance organization with any p'esa required audit and determine where to put our can lead to meaningies: austs resources-toward the required audit, so we can land to erica evoits. g io avo,o rerueiing o, can do a good audit, or toward an audit of the to catch 'e'u""9 problem area. Currently, we usually have to E!EOUonw*n"fUnQ'.'.irSE*c*EE", navechoose to do our regt, sired audit, and maybe put limited resources in the problem area. I o

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think our problem areas should get more c =c"v'acun attention-more audits and survi;ttlance's.

q Can daim resources for non problem aesas tnat would.$

That is what an efrective performance based l

be better used in monitanns and assessing weat are audit program would do.

l Lyvt GLW. thde 4 My proposal is that the licensees control the audit program, with NRC providing oversight We ha,ve to perform audits-regardless of what instead of control. The Great Lakes QA

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activities are in progress-based on wherv the.

M nagers also support this proposd.

1 audits are due. So we can have a meaninpless l

audit by looking at an activity when there is no work in progress.

Proposal i

We can perform extra audits. For example, if won

o. coni,oi suo,,,,ogram oiin sne we want to take a look at in-service inspection, oversight estead of NRC Control it makes sense to do that during a refueling outage, when we are actually doing in service i

inspect,on. Ilowever, if the audit is due when i

we re not in a refueling outage, we might have Thisdroposal would involve several actions. Itrequire l

to do an extra audit. That means we are double auditing, wot regulation changes, regulatory guidance

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On the other hand, we might want to avoid a changes, nr,d QA program changes.

l refueling outage. It doesn't make a lot of

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sense to do an emergency pit nning audit during a refueling outage; it makus a lot more Actions l

sense to use our resources to look at the work we're doing during the refueling outage.

Tecn Spec Cnanges The frequency regtdrement also can lead to neguut, n changes audits being perfouned before expected I

i neguiaior, cueance enange.

corrective action is complete. For example, we have an audit that's not nquired by regulation A Program Cnanges scheduled for June of this year. Corrective action is going to be done in June. Therefore, gm.

it makes more sense to audit in August to see how effective th corrective action is. That's We're looking at three options. We prefer the what,we are going to do. If that were an audit first one, but we are willing to purstie any required by technical specifications er a option that would be easier to license, and regulatory audit, we would not have that anything the NRC would be interested in flexibility, and we would be auditing at a time when we know our program is not yet approving, corrected.

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m Quality Assurance Requirements What this would do is provide more control to Tech Spec Changes QA management on audit and other oversight activities-such as surveillances, special rnres onons (opnen i pre erase) examinations, or inspections-in terms of r

applying the resources toward the activity want to pursu' option witn greatest enance of timely where we feel we have the problems and where we could really get more bang for the buck. It

,c would provide greater flexibility based on the plant performance and plant activities, and allow us to better improve our weak areas.

Option one is to remove the audits from This is also consistent with draft Standard Section 6 of the Technical Specifications. We Review Plan 17.3 would have the audits listed in the QA program. The frequency of core audits, such as mattienance, engineering, operations, rad Tech Spec changes (continued) protection, design change, and so forth, would also be listed in the QA program.

option 2. Tech Specs retain requirement to au+:QA organization activities under Offsite Review committee Tech Spec Changes (continued) cognizance (otherwise same as option 1)

Assures offsite Rev6ew comrmttee retains oversight o' oA actmties and this is not changeca by QA program Option 1. Remove Audits from Section 6 change Audits 16st in OA Program Sp'e'r"a' ions. u'aSe'nN's.ia'" a ^on"e*,'E*Ei;onf oes,gn The second option is very similar to the first,

"'Y cnange. correchva Action except we would leave one audit in the E

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OU Changes in Aud:t Coverage specihed in OA Program treated per tocrRso r i ta; the QA organ.ization. That would mean the Offsite Review Committee would continue ta Reduction in audit coverage requires NRC revie.

have control over that audit.

Audits required by rules conducted at specified frequency (unless rule enanges or exemptcn granted)

Provides more control to OA Management on audit and Tech Spt,c Changes (continued) ofler oversight activities '

Permits greater fleulb6hty based on pedormance and ptant activua*

Optbn 3. Recnove audit frequencies only from Tech Attows ucensees to better focus C# e' forts on how to spe-g improve weax or poor pedormanu areas Consistent witn draft Standard Review Plan t7.3 Provides some flexibaty to adjust frequency based on tp Ovirnao see 8 performance and piant activitier Changes in audit coverage would be handled

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like any other change m our QA program: It would be reviewed to determine whether it ty c e.a. m o reduces the commitments in the audit program and whether it nill mee.s Appendix B. NRC approval woWd still be needed for any The third option is to remove only the audit changes that resulted in a reduction in frequencies from the technical specifications, commitmente We would conduct audits Fat leave the audits in. This would give us a Uttle flexibility to change the frequency of our required by rules at the frequency required by schedule, bm :,t would not really give w as the rules, at least until we had a rule change or much flexibihty as we would like. This is an exemption. There are a lot of frequency requirements in some of the rules.

122 NURLG/CP-0129 September 1993 i

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Quahty Assurance Reedirements consistent with the new standard technical Actions that we would need to take as licensees specifications, include meeting with NRR to discuss the technical specification change options, submitting the first technical specification Regulation and Regulatory Guldance change and QA prog.am change, and Changes following up with the rest of us submitting technical specification changes. We would then submit additional techmcal specification cugyg+nts for avsts are centa**d "

changes as the rules or regulatory guidance allowed us to change.

Consohdate into or e requkement for Aud1t Program Revise Regulatory Guides NRC Actior2*

Convol over Audit Program in oA Program tp omanan, s.o i' Meet with hcansee on Yecti Mec changes now.. end soprove suommed reen spee nd or

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Currently, audit requirements are contained in Podorm review of ali tules and regulatory gume on multiple locations. We think they should be contained in one location in the regulation.

We should also look at the regulatory guides Propose ruie consoiidating ruies no or... nay be iusi and determine whether we could rev,ise and rev:sm to 10CFn Appendix 0 consolidate them, and put control of the audits propose en naes,o neguiatory cuid3, in the QA program.

Approve revised rule QA Program Changes Lyre orodman. ekte i4 oA Program revised t,o include hsting of audned areas and erequencies et co e audits e

h MC m 6 h Mp4 oA program change.*impiemeniing inis man, reuse

1. Meet with us to discuss' this QA m paranei itn Tecn spec togece;vegnc revi program change and the. technics!

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=2, n. ai it specification change; o

2. Raview and approve our submittals; L

The QA program would be revised to include a listing of the audited activities and

3. Review the rules and regulatiens that frequencies, and that first QA prcgram change cover the audit program; and would be reviewed at the same time the technical specification change wotild be 4.

Determine the best rule change and reviewed.

regulatory guidance changes to better consolidate the requirements, making them more usabic ai.d more nexible to Licenseo Actions licensees could have better, more effective QA audit programs.

Meet with NRR to discust Tech Spec change options I'm talking about how to improve, not reduce.

suoma nrst Tecn 3pec change and oA Program but how to improve the effeCliveness of j

l performance based audit programs by eliminating some of the regulatory burden.

otner neemees suoma Tech soec changes Subm+t further QA Program chances as appropriate tonoung rule changes and Regulatory ouide changes Ly v Goxean stee t3 i

September 1993 Ammuus

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