ST-HL-AE-5297, Submits Response to Addl Info Re Operations QA Plan Change QA-026
| ML20106G450 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 02/27/1996 |
| From: | Martin L HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ST-HL-AE-5297, NUDOCS 9603050115 | |
| Download: ML20106G450 (7) | |
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The Light company South Texas Project Electric Generating Station P.O. Box 289 Wadsworth. Texas 77483 Houston IJghting & Power February 27, 1996 ST-HIeAE-5297 File No.: G02.05 10CFR50.54(a)
U. S. Nuclear Regulatog Commission Attention: Document Control Desk Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50498, STN 50-499 AdditionalInformation Regarding Ooergions Ouality Assurance Plan Change OA-026 Reference 1:
letter from W. T. Cottle to the Nuclear Regulatory Comnussion Document Control Desk, dated December 13,1995.
Reference 2:
Letter fmm Thomas P. Gwynn, Nuclear Regulatory Commission, dated January 21,1996, and enclosure guidance from Charles E. Rossi, Office of Nuclear Reactor Regulation, dated December 21,1992, titled Biennial Procedure Reviews.
In Reference 1, the South Texas Project notified the NRC of a change to the South Texas Project Operations Quality Assurance Plan to renove the requirement that all safety-related pmcedures be reviewed no kss frequently than every two years. South Texas Project proposed to take credit for existing programmatic controls whi::h accomplish the intent of the biennial procedure review and therefore determined that it is not a reduction in commitment of the Operations Quality Assurance Plan per 10CFR50.54(a). In Reference 2, the Nuclear Regulatory Commission staff asked the South Texas Project to pmvide additional information oa the programmatic controls in place and how tirse controls satisfy the guidance provided in the enclosure to Reference 2. This letter is the response to those questions.
Reference 2 also straed that the deletion of the biennial procedure review is cansidered to be a reduction in commitment. A condition report has been generated to document the condition since the station has discontinued biennial reviews. Appropriate action will be taken based on the resolution of this issue. The South Texas Project is confident that further consideration of the programs in place at the station will enable the Nuclear Regulatory Commission to conclude that there is not a reduction in commitment to the Operations Quality Assurance Plan. Should the NRC staffcontinue to conclude that this change is a reduction, this letter and attachment should provide tie basis for deciding that tie I
change is appropriate.
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,3 f p f q g, Project Manager on > half of the Participants la the South Tesas Project 9603050115 960227 PDR ADOCK 05000498 p
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Houston IAghting & Power Campany South Texas Project Electric Generating Station i
Page 2 ST-HI AE-5297 The South Texas Project response is attached. If you have any questions, please contact Mr. R. J. Rehkugler at (512) 972-7922 or me at (512) 972-8434.
Sincerely,
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L. E.
in Gene alManager, Nucle ~ r Assurance & Licensing a
i RDP c: RMS/NSC
Attachment:
Response to Nuclear Regulatory Commission Questions 1
l M
Project Asanager en Sebalf of *be Participante is the South Torne Project
Houston I'ighting & Power Company ST-HL-AE-5297 South Texas Project Electric Generating Station File No.:
G02.05 Page 3 c:
Leonard J. Callan Rufus S. Scott Regional Administrator, RegionlV Associate General Counsel U. S. Nuclear Regulatory Commission Houston Lighting & Power Company 611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 Arlington, TX 76011-8064 Houston, TX 77208 Thomas W. Alexion Institute of Nuclear Power Project Manager Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555 @.01 13H15 Atlanta, GA 30339-5957 David P. Loveless Dr. Joseph M. Hendrie l
Sr. Resident inspector 50 Bellport Lane c/o U. S. Nuclear Regulatory Comm.
Bellport, NY l1713 l
P. O. Box 910 Bay City, TX 77404-0910 Richard A. Ratliff Bureau of Radiation Control l
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 1771 San Antonio, TX 78296 l
i J. C. Lanier/M. B. Lee J. R. Egan, Esquire 1
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 Central Power and Light Company J. W. Beck l.
A7TN: G. E. Vaughn/C. A. Johnson Little Harbor Consultants, Inc.
l P. O. Box 289, Mail Code: N5012 44 Nichols Ro l
Wadsworth. TX 77483 Cohassett, MA. 025-1166 l
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6 Houston IJghting & Power Company South Texas Project Electric Generating Station Attachment Response to Nuclear Regulatory Commission Questions
SUMMARY
South Texas Project is committed to Regulatoy Guide 1.33, " Quality Assurance Program Requirements (Operational)." Regulatoy Guide 1.33 endorses ANSI N18.7-1976/ANS 3.2,
" Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants,"
which contains a mquirement that safety-related procedures be myiewed no less frequently than even two years. In lieu of performing a biennial review of safety-related procedures, South Texas Project has taken credit for programmatic controls already in place which accomplish the intent of the biennial review. These controls assure that procedures are appropriately reviewed and revised to incorporate information based on plant operations, design changes, reculatory requirements, industy experience and other conditions that may impact plant procedures. These controls ensure that the guidance in the enclosure to Refemnce 2 concerning Biennial Proccine hi ws is met. Discussed below are the bases for the alternative, including the programmatic controls, and a description of how the guidance contained in the enclosure to Reference 2 is addressed.
BASES t
ANSI N18.7, Section 5.2.15, prescribes a biennial review of each safety-related plant procedure "to deternune if changes are necessary or desirable." The biennial review is intended to ensure that plant operating experience, industy experience and recent technical information, are factored into plant procedures. South Texas Project considers the requirement to maintain procedures in an accurate and useful condition to be a dynanuc process. Numerous programmatic controls have been established that 3
accomplish t!e intent of the biennial review, and satisfy the guidance set fonh in the enclosure to Reference 2.
These controls assure that procedures are appropriately reviewed and revised to incorporate infonnation based on plant operations, design changes, vendor recommendations, regulatory requirements, cormctive actions, industry experience and other conditions that may impact plant procedures. The controls are sufliciently responsive to ensure that required procedure changes are timely and accurate, regardless of how frequently those procedures am used. Performing biennial reviews in addition to these controls is redundant, and imposes an unnecessary drain on plant South Texas Project has completed two biennial review cycles since Unit I became resources.
operational.
The results of these reviews have confirmed the eTectiveness of the existing programmatic controls, and support the position that the biennial revie.
safety-related proceduresis not necessary. The programmatic controls described below are pan of dynamic processes that assure procedures are maintained in an accurate and useful condition consistent with the safety goals of the Regulatory Guide 1.33 and ANSI N18.7 requirements.
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Houston IJghting & Power Company South Texas Project Electric Generating Station Attachment Response to Nuclear Regulatory Commission Questions Descritx:d below are programmatic controls in place which require an assessment of the impact on plant procedures, and a description of how South Texas Project meets the guidance listed in the enclosure to Reference 2:
O Corre:tive Action Program Personnel are required to identify and document conditions found to be adverse to quality, safety and plant reliability. When inadequate procedures are identified requiring corrective action, they are changed or revised. The Corrective Action Program is a compmhensive system governed by adnunistrative controls utilized to ensure that commitments and requirements are tracked, included, and maintained in appropriate implementing procedures.
Any change to sourte guidance is updated and evaluated against implementing procedures.
The need for revision is detemuned and, if applicable, accomplished by the appropriate departarnt/ group.
In addition, criteria have been established to investigate events which occur at the station i
and are considered to be outside normal expected operation. These events include: sevem or unusual plant transients, safety system malfunctions, events involving nuclear safety or plant reliability, defriencies in design or analysis, operations or maintenance procedures that cause a signifrant event, fuel handline or storage event, excessive radiation exposure or severe personnel injury, and excessive discharge of radioactivity. Corrective action for i
these events mquire review and revision of appmpriate pmcedums as necessary.
The Corrective Action Program satisfies the guidance in paragraph 1 of the enclosure to Refemnce 2 concerning myiews following accidents, unexpected transients, significant operator errors, or equipment malfunctions.
O PlantModification Process Program The plant design modification program requires a review ofmodifrations by groups which are potentially affected by tle modifration.
This review requires that procedures potentially affected by the modification be identifed and revised as necessary prior to i
operation of the modification. The design modifration program, and the implerrenting procedures, satisfy the guidance in paragraph I of the eirlosure to Reference 2 concerning review of procedures following any modifration to a system.
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s Houston IJghting & Power Company South Texas Pro, ject Electric Generating Station Attachment Response to Nuclear Regulatory Commission Questions i
o Training and Requalification Programs Licensed operator, nonlicensed operator and technical staff training programs frequently utilize procedures.
Discrepancies noted during training or qualification result in appropriate procedure revisions.
In addition, the two year Licensed Operator Requalification cycle allows the Emergency Operating Pmcedures and Abnormal Operating Pmcedures to be either run on the simulator or extensively reviewed in training.
Errors identified are addressed using the condition reporting process. This use or review of the Emergency and Abnormal procedures satisfies the guidance in paragraph 2 of the enclosure to Reference 2 concening review of non-routine procedures.
The station also has an Emergency Response Organization drill cycle for determuung the effectiveress of the emergency plan and implementing procedures. The use and/or review of the Emergency Operating Procedures, Abnormal Operating Procedures and Emergency Plan implementing procedures during the planmng, preparation, training, and performance ofemergency plan drills satisfies the guidance in paragraph 2 of the enclosure to Reference 2 concerning inview of procedures which implement the emergency plan.
O QualityAssuranceActivities The Quality Assurance Program pmvides for independent overview activities such as audits, performance monitoring, evaluations, and assessments. These activities routinely verify the adequacy of procedures and verify that the process for controlling documents is effective. The audit program includes the performance of an admuustrative control audit which addresses the adequacy of procedures, and the effectiveness of the procedure revision process. The administrative control audit, and audits performed in the operations, maintenance, engineering, and other plant support areas satisfy the guidance in paragraph 3 of the enclosure to Reference 2.
O Infrequently PerfonnedEvolutions Infrequently perfortred evolutions and high risk activities require extensive planning, and a pre-activity briefing. This briefing allows personnel involved to review and discuss the procedures that govern the evolutions. If inadequacies are identifed in the procedures, they are revised prior to the performance of de evolution. This planmng and pre-activity i
briefing satisfes the guidance in paragraph 4 of the enclosure to Reference 2 concerning review of routine plant procedures which have not been used for two years.
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Houston IAghting at Power Conapany South Texas Project Electric Generating Station Attachment Response to Nuclear Regulatory Commission Questions In addition to the programs listed above which specifically meet the guidance listed in the enclosure to Reference 2, the following programs are utilized to add to the effectiveness of the overall site procedures program.
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User Feedback and Procedure Compliance Personnel are requimd to notify supervisors or managers concerning procedural guidance which cannot or should not be followed. The procedure is evaluated, and if required, changed prior to the commencement or continuation of work.
O Industry Events Analysis South Texas Project is an active participant in the Signifrant Evaluation and Infomiation Network. The Industry Events Analysis Program provides the necessary instruction for evaluating material from the network (e.g., Signifrant Event Reports, Operations i
Experience Reviews), and for dissminating such information to plant personnel. This evaluation includes the review of applicable procedums. Recommendations are made to resolve underlying problems, and implementation may include changes to plant procedures.
Internal and external effectiveness reviews are performed to ensure the program is maintained.
O Vendor TecimicalInformation Administrative procedures governing the Vendor Equipnent Technical Information 1
Program provide control of incoming equipment technical information and assure the appropriate engineering / technical evaluation and distribution for prompt attention to key personnel and timely incorporation of technical information into operating and maintenance procedures.
O Licensing Basis Documents Changes and 10CFR50.59 Evaluation Proposed changes to the facility or pmcedures and, any new tests or experiments that have a potential to affect nuclear safety, either directly or indirectly, are reviewed for impact on procedures and Licensing Basis Documents. Procedure changes are evaluated against the screening criteria of 10CFR50.59. Personnel who review these screenings have been trained in the requirements of 10CFR50.59.
O Trending South Texas Project trends data from areas such as Operations, Maintenance, Licensing, Engineering, Chemistry and Health Physics. The trending pmcess includes the collection of data and identifration of follow-up actions necessary to improve that perfomurre.
Follow-up action for adverse trends may result in procedure changes and improvenents.
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