View source for L-99-093, Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.5

{{Adams
| number = ML20209B414
| issue date = 06/25/1999
| title = Provides Response to RAI on Proposed Change to Operations QA Program Description.Attachment 2 Provides Revised Markup for Proposed Changes to Affected UFSAR Section 17.2.5
| author name = Jain S
| author affiliation = DUQUESNE LIGHT CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000334, 05000412
| license number = 
| contact person = 
| document report number = L-99-093, L-99-93, NUDOCS 9907060471
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 8
}}

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n or V) President                                      June 25, 630            Fax 724) 643-Do*0.**E,w. ion                                         L-99-093 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

==Subject:==
Beaver Valley Power Station, Unit No. I and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Response to Request for AdditionalInformation on Proposed Change to the Operations Quality Assurance Program Description                                                                       !
By {{letter dated|date=March 16, 1999|text=letter dated March 16,1999}}, Duquesne Light Company (DLC) submitted for NRC approval in accordance with 10 CFR 50.54(a)(3)(ii), a proposed change to the Beaver Valley Power Station (BVPS) Units 1 and 2 Operations Quality Assurance (QA) Program Description provided in                   i BVPS Unit 2 Updated Final Safety Analysis Report, (UFSAR) Chapter 17.2. In its letter, DLC stated that this change would reduce the program description commitments for both Units by               '
limiting required Onsite Safety Committee (OSC) reviews of procedures to those requiring a 10 CFR 50.59 safety evaluation.
Subsequently, in their review of this submittal, the NRC determined that additional information is required from DLC in order for the NRC to complete their review. By {{letter dated|date=May 14, 1999|text=letter dated May 14,1999}}, the NRC provided to DLC a request for additional information (RAI) concerning its proposed change to the QA Program Description. In their letter the NRC requested this response to the RAI be provided by July 13, 1999.
The BVPS response to the RAIis provided in Attaclunent 1.
Attachment 2 provides the revised markup for proposed changes to affected UFSAR 17.2.5, which supersede those previously proposed for this section in DLC's March 16,1999             /
submittal. In addition, Attachment 2 includes the markup of previously proposed changes to UFSAR Section 17.2.1.3, which remain unchanged by this submittal.                          ,
                                                                                                 &0vLf DEllVEllllG PJ7 ta =b                                                                              M P                         PDR                                                           [ ll [ g g y

1 iBeaver Valley Power St tion, Unit No. I and No. 2 Response to Request for Additional Infonnation on Proposed Change to Operations Quality Assurance Program Description Page 2 Following NRC approval of this proposed change to the Operations QA Program description, the transition from our current procedure review and approval process to the IQR process will be conducted in a deliberate and controlled manner. The fmal step in this transition will be implementation of the proposed UFSAR changes, as outlined in this subittal.
If there are any questions concerning this matter, please contact Mr. Mark S. Ackerman, Manager, Safety & Licensing Department at 412-393-5203.
Sincerely, Sushil C. Jain Attachment c:    Mr. D. S. Collins, Project Manager Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator

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                  .                            ATTACHMENT 1 Duquesne Light Company Beaver Valley Power Station Units 1 and 2 NRC Reauest for Additional Information. dated May 14.1999 NRC Request:
Duquesne Light Company (DLC) has proposed to limit required Onsite Safety Committee (OSC) reviews of new procedures, and procedure revisions, to those requiring a 10 CFR 50.59 safety evaluation. All other procedural reviews would be performed by an independent qualified reviewer (IQR) and approved by the responsible discipline manager or his/her designee. While this proposed procedural review alternative is not unprecedented, the existing QA Program for BVPS-1 and BVPS-2 does not explicitly define, in UFSAR Chapter 17.2 of the BVPS-2, the requisite qualifications, authority, and review responsibility of an IQR (as described in Attachment I to the {{letter dated|date=March 16, 1999|text=March 16,1999 letter}}). Additionally, the QA Program contains no discussion of how the population of designated IQRs is to be controlled or tracked. Please provide appropriate revisions of the QA Program which incorporate this information and support the QA Program change requested in your March 16,1999 submittal.
DLC Response:
Reauisite Oualifications of an IOR IQRs shall meet the applicable qualifications of ANSI /ANS 18.1-1971, for a Staff Specialist.
IQRs shall be qualified to perform 10 CFR 50.59 safety evaluations.
Authority and Review Responsibilities of an IOR Each procedure or revision thereto of Technical Specification 6.8 shall be reviewed and approved, as described below, prior to implementation.
Each procedure or revision thereto shall be reviewed by an IQR, who is knoveledgeable in the functional area affected. This IQR is not the individual who prepared the procedure or associated procedure revision. Required cross disciplinary reviews of new procedures and procedure revisions shall be completed prior to approval of the procedure. The responsible IQR shall ensure each procedure or revision thereto includes a determination of whether a procedure requires a 10 CFR 50.59 safety evaluation. If a procedure or revision thereto requires a 10 CFR 50.59 safety evaluation, the responsible Manager or his designee shall forward the procedure, with the associated 10 CFR 50.59 safety evaluation, to the OSC for review. Pursuant to 10 CFR 50.59, NRC approval ofitems involving unreviewed safety questions shall be obtained prior to approval of the procedure or revision thereto for implementation. Final procedure approval shall be by the responsible Manager or his designee as specified in administrative procedures.
Discussion of How the Population of Designated IORs is to be Controlled or Tracked Personnel reconunended to be IQRs shall be reviewed by the OSC and approved and documented by the Plant Manager as specified in administrative procedures. The responsible Manager shall ensure that procedures or revisions thereto are reviewed by an IQR knowledgeable in the functional area prior to approval.

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ATTACHMENT 2                                            )
Duquesne Light Company Beaver Valley Power Station Units 1 and 2 NRC Reauest for Additional Information. dated May 14.1999 i
BVPS-2 UFSAR                          Revision (TBD)   )
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17.2.1.3 Onsite Safety Committee (OSC)
The OSC shall function to advise the General Manager, Nuclear Operations on all matters related to nuclear safety and shall provide review capability in the areas of:
: 1. Nuclear power plant operations.
: 2. Radiological safety.
: 3. Maintenance.
: 4. Nuclear engineering.
: 5. Nuclear power plant testing.                                                        !
: 6. Technical advisory engineering.
: 7. Chemistry.
: 8. Quality control.
: 9. Instrumentation and control.                                                        '
The Onsite Safety Committee Coordinator is the OSC Chairman and shall appoint all members of the OSC. The membership shall consist of a minimum of one individual from each of the areas designated above.
OSC members and alternates shall meet or exceed the minimum qualifications of ANSI N18.1-         ,
1971 Section 4.4 for comparable positions. The nuclear power plant operations individual shall meet the qualifications of Section 4.2.2 and the maintenance individual shall meet the qualifications of Section 4.2.3.
All alternate members shall b: appointed in writing by the OSC Chairman to serve on a temporary basis; however, no more than two alternates shall participate as voting members in OSC activities at any one time.
The OSC shall meet at least once per calendar month and as convened by the OSC Chairman or his designated alternate. A quorum of the OSC shall consist of the Chairman or his designated alternate and at least one half of the members including alternates.
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ATTACHMENT 2 (continued)
Duquesne Light Company Beaver Valley Power Station Units 1 and 2 NRC Reauest for Additional Information. dated May 14.1999 BVPS-2 UFSAR                            Revision (TBD)
The OSC shall be responsible for:
: 1. ~ Review of newa) :1! precedures required by Technical Specif::: ica 6.8 =d ch=ge: cf int = i=etc, b) =y cder p cpc:ed procedures reauirina 10 CFR 50.59 safety evaluations ander changes to existina procedures deretc which reauire 10 CFR 50.59 safety evaluations. : det:nained by 6: C===! M= gn. Nu !:= Op= tion: to afrect nn:!:= safety-
: 2. Review of all proposed tests and experiments that affect nuclear safety.                   j
: 3. Review of all proposed changes to the Technical Specifications.
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: 4. Review of all proposed changes or modifications to plant systems or equipment that         i affect nuclear safety.                                                                    ]
: 5. Investigation of all violations of the Technical Specifications including the preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the General Manager, Nuclear Operations and to the Chairman of the Offsite Review Committee.
: 6. Review of all reportable events of the type described in 10 CFR 50.73.
: 7. Review of facility operations to detect potential safety hazards.
: 8. Performance of special reviews, investigations or analyses and reports thereon as requested by the Chairman of the Offsite Review Committee.
: 9. Review cfie Security P!= =d implementing precedure:.
: 10. Review ofie E==gency Pl= =d imp!cmenting procedures.
The OSC shall:
: 1. Recommend to the General Manager, Nuclear Operations written approval or disapproval ofitems considered under OSC responsibility 1 through 4 above.
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  .,. g ATTACHMENT 2 (continued)
Duquesne Light Company Beaver Valley Power Station Units 1 and 2 NRC Reauest for Additional Information. dated May 14.1999
!                                                  BVPS-2 UFSAR                           Revision (TBD) l l
i l           2. Render determinations in writing with regard to whether or not each item considered
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under OSC responsibility 1 through 5 above constitutes an unreviewed safety question. l 1
i            3. Provide written notification within 24 hours te die President, Generation Group and
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Chief Nuclear Officer and the Offsite Review Conunittee of disagreement between the     l l                OSC and the General Manager, Nuclear Operations; however, the General Manager,          ;
L                Nuclear Operations shall have responsibility for resolution of such disagreements       i pursuant to Technical Specification 6.1.1.
l       The OSC shall maintain written minutes of each meeting and copies shall be provided to the       I General Manager, Nuclear Operations and Chairman of the Offsite Review Committee.
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* ATTACHMENT 2 (continued)
Duquesne Light Company Beaver Valley Power Station Units 1 and 2 NRC Request for Additional Information, dated May 14.1999 BVPS-2 UFSAR                               Revision (TBD) 17.2.5 Instructions, Procedures, and Drawings The Operations QA Program requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and will be accomplished in accordance with these instructions, procedures, or drawings.
These instructions, procedures, or drawings include, as appropriate, the requirements for special tools, test equipment, processes, controls, or skills, in order to attain the required level of quality.
The instructions, procedures, or drawings will include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
The Beaver Valley Power Station Operating Manual includes instructions and procedures covering the requirements of NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operations)", Appendix A, as they apply to Pressurized Water Reactors. The Operating Manual is implemented, enforced, and maintained by the General Manager, Nuclear Operations Unit, and staff. These procedures and/or instructions include step-by-step procedures for operating and securing the various systems, actions to be taken in the event of abnormal or emergency conditions and precautions to preclude exceeding system or equipment design. The applicable requirements of NRC Regulatory Guide 1.33 were used as guidance in the development of startup, operating, emergency, maintenance, and testing procedures.
Maintenance, repair, modifications, testing, and refueling activities which affect the quality or        I safety of Category I items are prescribed by documented instructions, procedures, or drawings.           ,
These instructions, procedures, or drawings include, as appropriate, the requirements for special        I tools, test equipment, processes, controls, or skills, in order to attain the required level of quality.
Each procedure or revision thereto of Technical Specification 6.8 shall be reviewed and approved.
as described below. orior to implementation.
Each procedure or revision thereto shall be reviewed by an Independent Oualified Reviewer (IORL who is knowledaeable in the functional area affected. This IOR is not the individual who prepared the procedure or associated procedure revision. Reauired cross disciplinary reviews of new procedures and procedure revisions shall be completed prior to approval of the procedure.-
The responsible IOR shall ensure each procedure or revision thereto includes a determination of whether a procedure reauires a 10 CFR 50.59 safety evaluation. If a procedure or revision thereto I         reauires a 10 CFR 50.59 safety evaluation, the responsible Manauer or his desinnee shall forward the procedure. with the associated 10 CFR 50.59 safety evaluation. to the OSC for review.
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ATTACHMENT 2 (continued) 1
                                                                                                                                                                                                        )
Duquesne Light Company                                                                                          j Beaver Valley Power Station Units 1 and 2                                                                                        l l
t NRC Reauest for Additional Information. dated May 14.1999 l
BVPS-2 UFSAR                                                          Revision (TBD) l        Pursuant to 10 CFR 50.59. NRC approval ofitems involving unreviewed safety auestions shall be                                                                                                1 obtained orior to approval of the procedure or revision thereto for implementation. Final                                                                                                      I procedure approval shall be by the responsible Manager or his desinnee as specified in                                                                                                       l administrative procedures. IORs shall meet the applicable aualifications of ANSI /ANS 18.1-                                                                                                  I 1971. for a Staff Specialist. IORs shall be analified to perform 10 CFR 50.59 safety evaluations.                                                                                           I Personnel recommended to be IORs shall be reviewed by the OSC and aooroved and documented                                                                                                      I by the Plant Mananer as specified in administrative procedures. The responsible Manager shall                                                                                                   I ensure that procedures or revisions thereto are reviewed by an IOR knowledgeable in the functional area prior to aoproval.
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eppreved by a deig=ted == ger er diacter Temporary channes to procedures will be approved by two knowledaeable members of the Beaver                                                                                                 a l         Vallev staff prior to implementation. At least one of these will be a member of supervision. If the change affects operations procedures. at least one will be a person holding a senior reactor l         operator license for the unit affected. Prior to implementation, the OSC shall review and L         recommend approval of temporary channes to procedures which reauire a 10 CFR 50.59 safety evaluation. Within 14 days ofimplementation. temporary channes will be reviewed by an indeoendent aualified reviewer and approved by the responsible mananer or his desinnee.                                                                                                      .
1 l         T =per=y ch=ge'; to precedure of Techni=1 Spee!E=ti= 6.8.1 may be made provideo
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to whc= i: O=:=1 M=:ger, N=!=: Ope = tic = h= = sign:d in writing i:                                                                                               ,
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