ST-HL-AE-5142, Discusses Info Re Control of Audit Frequencies
| ML20087G481 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/14/1995 |
| From: | Martin L HOUSTON LIGHTING & POWER CO. |
| To: | Thadani A NRC (Affiliation Not Assigned) |
| References | |
| ST-HL-AE-5142, NUDOCS 9508170021 | |
| Download: ML20087G481 (3) | |
Text
'08(15 '95 07:17 1D: NUCLEAR LlCENSING FAX:512-972-8298 PAGE 2
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The Light c o mp a n y south Tea.s Project Electric Cencrating Station P. O. Bua 289 Wadsworth, Texas 77483
,g August 14,1995 ST-HL-AE-5142 File No.:G09.19 Mr. Ashok C. Thadani Associate Director for Technical Review Office Of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 South Texas Project Units I and 2 Docket Nos. STN 50-498 & STN 50-499 Control Of Audj.LFr.sauencies
Dear Mr. Thadani:
In telephone conversations on August ist and 14th,1995, Mr. Lee Spessard of your staff raised a question about the control of certain audit frequencies. The question relates to the Tecimical Specification (TS) changes approved by the Nuclear Regulatory Commission j
(NRC) on December 27,1993, in response to the proposal submitted by Houston Lighting &
Power Company (HL&P) on October 21,1993.
This subject TS change removed from TS 6.5.2.8, the prescriptive frequency of the required audits. The submittal included justification for the change and stated our intention to submit an Operations Quality Assurance Plan (OQAP) change removing the same requirement. We stated that audit frequencies and schedule would be controlled in our Audit Plan process. The question raised by your staffis why these prescriptive audit frequencies should not be added to the OQAP, thereby requiring that changes be subject to the requirements of 10 CFR 50.54(a).
HL&P has considered this question and has concluded that the application of the restrictions of $50.54(a) to the audit frequencies would reduce the effectiveness of the QA program by reducing the ability of HL&P management to adjust audit schedules and resource allocation on a real time basis in response to empirical data and performance history. HL&P,
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08/15 '95 07:27 ID: NUCLEAR LICENSING FAX:512-972-8298 PAGE 3
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m Ilouston Lighting & Power Company South Texas Project Electric Generating Station ST-HL-AE-5142 File No.: G09.19 Page 2 in preparation for this TS change, developed a process for determining audit frequencies involving review of a number of inputs, including corrective action process and trending, QA surveillances, inspections and assessments, and effectiveness review of previous corrective actions. This review is performed by Nuclear Assurance supervision and approved by the Director of Quality and reviewed by the General Manager, Nuclear Assurance and Licensing and the Nuclear Safety Review Board. This review and decisions made, including justiGcations, are thoroughly documented.
In HL&P's view, the current NRC approved system of controlling audit scheduling and frequency at the South Texas Project is consistent with published NRC regulatory requirements and applicable guidance. The Standard Review Plan (SRP) does not require that audit frequencies be specified in the QA Program Description. Instead, the SRP states that this information be contained in an audit plan. The SRP also states that " audits should be regularly scheduled based on the status and safety importance of the activities" to be audited.
The current siystem also provides an adequate basis for NRC oversight of the program.
The OQAP includes a commitment to meet the intent of Regulatory Guide L33, which contains more speciGc guidance on audit schedule requirements. HL&P intends that audits of safety related functions will typically be completed within a period of 2 years. Any deviations from the Regulatory Guide audit schedule requirements will be based on an analysis of the status and safety importance of Project activities. This analysis will be documented and available for NRC review.
NRC's approval of this TS change is consistent with sound performance based regulation, and represents an important element of an appropriate graded quality assurance program. Requiring that audit frequencies be speciGed in the OQAP would reduce the effectiveness of the QA program, and therefore would not result in a substantial increase in the overall protection of the public health and safety. Consequently, HL&P believes it is appropriate to retain the current process for controlling the audit schedule in the QA Audit Plan.'
Please call me if you have any questions about this matter.
Sincerely,
./.sww I.. E. Mart' General
- anager, Nuclear Assurance & Licensing AHG/nl
- 08f15L'9507:18-ID:MJCIEAR LICENSING '
FAX:512-972-8298 PAGE 4-4 3.;.'. : '
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-i Houston Lighting & Power Company ST-HL-AE-5142 l
South Texas Project Electric Generating Station File No.:
G09.19 Pago 3 l
c:
l Leonard J. Callan
~ Rufus S. Scott Regional Administrator, Region IV Associate. General Counsel U. S. Nuclear Regulatory Commission.
Houston Lighting & Power Company.
611 Ryan Plaza Drive, Suite 400 -
P. O. Box 61067 l
- Arlington, TX. 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power i
Project Manager Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway
. Washington, DC 20555-0001 13H15 Atlanta, GA 30339-5957 David P. Loveless Dr. Joseph M.- Hendrie Sr. Resident Inspector 50 Bellport Lane c/o U. S. Nuclear Regulatory Comm.
Bellport, NY 11713
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P. O. Box 910 Bay City, TX 77404 0910 Richard A. Ratliff Bureau of Radiation Control J. R. Newman, Esquire Texas Department of Health Morgan, Lewis & Bockius 1100 West 49th Street 1800 M Street, N.W.
Austin, TX 78756-3189 Washington, DC 20036 5869 U. S. Nuclear Regulatory Comm.
K. J. Fiedler/M. T. Hardt Attn: Document Control Desk City Public Service Washington, D. C. 20555-0001 P. O. Box 177)
San Antonio, TX 78296 J. C. Lanier/M. B. Lee J. R. Egan, Esquire City of Austin Egan & Associates, P.C.
Electric Utility Department 2300 N Street, N.W.
721 Barton Springs Road Washington, D.C. 20037 Austin, TX 78704 C. A. Johnson J. W. Beck Central Power and Light Company Little Harbor Consultants, Inc.
P. O. Box 289, Mail Code: N5012 44 Nichols Road Wadsworth, TX 77483 Cohassett, MA 02025-1166 w