ML20058L337

Rev 2 to Procedure Nragp 101-1, Nuclear Review & Audit Group Charter

ML20058L337
Person / Time
Site:	Clinton
Issue date:	07/10/1991
From:	ILLINOIS POWER CO.
To:
References
NRAGP-101-1, NUDOCS 9312160274
Download: ML20058L337 (9)

Text

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1.1 The purpose of this document is to establish guidelines for the operation of the Nucisar Review and Audit Group (NRAG) and to provide a written charter for the conduct of its activities in l

accordance with the Clinton Power Station (CPS) Technical Specifications.

2.0 APPLTCABILITY .. p 2.1 This procedure applies to all members, alternaces, subcomaittee members st4 staff of the NRAG.

3.0 REFERENCES

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7 ,)M2 3.1 ANSI N18.7-1976/ANS 3.2 -

$1l1 3.2 ANSI /ANS 3.1 - 1978 3.3 Corporate Nuclear Procedure 1.09, ' Nuclear Saf'ety Reviews" i

3.4 CPS Updated Safety Analysis Report (Chapter 13, Section 13.4,

' Review and Audit")  :

i 3.5 CPS Technical Specifications (Section 6, Subsection 6.5, ' Review ,

and Audit *)

3.6 NRAG Procedure 110-1, " Administrative Practices

• I 3.7 NRAG Procedure 170-1, " Training for NRAG Members, Alternates, Subco==ittee Members, and Staff". <

4.0 ATTACHMENTS .

None 5.0 DEFINITIONS 5.1 Nuclear Review and Audit Groun CRAG)

The NRAG is an independent committee responsible for performing senior management directed reviews of activities affecting nuclear safety. The NRAG reports to the Vice President-Nucisar of Illinois Power Company.

5.2 FRAG Mer.bershin Membership on this committee shall be comprised of senior, experienced 1111nois Power management and supervisory personnel augmented by competent consultants, as approved by the NRAG Director, capable of rendering expert jud 5ments in che areas of:

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• 443 =(td "10/26/9.5 11:19 NU. 40 ( We

.cf TNTON NUCLEAR REVIEW AND AIIDIT CROUP PRocent2nt - . NRACP 101-1 Para 2 of 9 Nucis. leview and Audit Group Charter DATE ISSUED

, JUL 1 A "?!

, REV. NO. 2 5.0 IEFINITIONS (Cont'd) 5.2.1 Nuclear Power Plant Operations 5.2.2 Nuclear Engineering 5.2.3 Chemistry and Radiochemistry 5.2.4 Metallurgy e

5.2.5 Nondestructive Testing 5.2.6 Instrumentation and control 5.2.7 Radiological Safety 5.2.8 ' Mechanical and Electrical Engineering 5.2.9 Administrative Controls and Quality Assurance Practices 5.2.10 other appropriate fields associated with the unique characteristics of CPS 5.3 FRAG Subcommittees NRAG subcommittees are composed of NRAG members and others as approved by the NRAG Director. Subconsittees shall always be chaired by an NRAG sember. Subcommittees may be formed for specific purposes such as performing studies, observing tests, investigating abnormalities or screening material for NRAC reviews. Written subcommittee reports are attached to the minutes of the meeting at which they were presented.

3.4 Line Rescensibility "Line responsibility" for the operation of CPS is vested in the Menager-CPS and those personnel who report to him.

6.0 EESPONSIBILITY 6.1 The KRAG shall be responsible for review of the following items:

a. Written safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments compleeed under the provision of 10CFRf 0.59 to verify that such actions did not constitute a change to the Technical Specifications or an unreviewed safety question.

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'CLINTON NUCLEAR REVIEU AND At!DIT conUP PROCEDURE NRACF-101;l Pare 3 ef 9 Nuclear Review and Audit Group Charter DATE ISSURD JUL to ml {

REV. NO. 2 I 6.0 RESPONSIBILITY (Cont'd)  !

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b. Proposed changes to procedures, equipment or systems which- )

involve a change to the Technical specifications or an ]

unreviewed safety question as defined in'10CFR50.59.

c. Prope w tests or experiments which involve a change to the  !

Tech. : 41 Specifications or an unreviewed safety question as j defined in 10CFR50.59. ,.

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d. Proposed changes to the Technical Specifications or the Operating 1.icense.

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e. Violations of codes, regulations, orders, Technicci I Specifications, license requirements, or of internal procedures or instructions having nuclear safety {

significance,

f. Significant operating abnormalities orjdeviations from  !

normal and expected performance of unit equipment that affect nuclear safety.

g. All Reportable Events.- *

h. All recognised indications _of an unanticipated deficiency in .

some aspect of design or op, ation of structures, systems, or componente that could affe:t nuclear safety.

1. Reports and meeting minutes of the Facility Review Croup (FRG) and the Independent Safety Engineering Group (ISEG). t

j. QA Department Audit Program and Schedule. (6.2 below)

k. Significant changes to the QA Program or QA Manual.

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1. Reports of audits conducted in accordance with paragraph 6.2  ;

below. -

a. Any other matter doomed appropriate for NRAG review by the NRAC Director. ~!

6.2 Audits of CPS activities shall be performed under the cognizance f of the NRAG. The Quality Assurance Department has overall  !

responsibility for the Quality Assurance Program and the audits '

that are conducted to verify compliance with the program. NRA0  :

cognirsace will be demonstrated by review of the QA Department j audit schedule and audit reports. The audits which shall be-reviewed include:

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a. The conformance of unit operation to provisions contained I within the Technical Specifications and applicable license i conditions at least once per 12, months, i B

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O/26/93 11:20 IL PWR CLINTON

• 443 N 1 E' # #

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CLINTON NUCLEAR RFVIEU AND AUDIT o#NP PROCEDIRE NRACP 101 1 j ' Page 4 of 9

c. lear Review and Audit Group Charter DATE ISSUED 1

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REV No. 2 j 6.0 RESPONSIBILITY (Cont'd) 4 l b. The performance, training and qualifications of the entire i .j unit staff at least once por 12 months.

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c. The results of actions taken to correct deficiencies  !

occurring in unit equipment, structures, systems or method '

i of operation that affect nuclear safety at least once por 6 i months. ~

a l d. The performance of activities required by the Operational j Quality Assurance Program to meet the criteria of 10CPR50, i Appendix 8. at least once per 24 months.

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{ e. The Emergency Plan and implementing procedures at least once i j . per 12 months.

f' j 2. The Security Plan and implementing procedures at least once per 12 months.

g. Any other area of unit operation considered appropriate by i

1 the NRAC, NRAG Director or the Vice President-Nuclear.

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j The Tira Protection programmatic controls including the  ;

imple7enting procedures at least once per 24 months by  :

qualified licensee QA personnel. .

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3 1. The fire protection equipment and program implementation at

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least once per 12 months utilising either qualified off site )

licensee fire protection engineer (s) or an outside independent fire protection consultant. (Note: For j; ,

clarification 'off-site' means non-plant staff personnel).

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j. An inspection and audit of the fire protection and loss *  ;

prevention program by an outside qualified fire consultant  ;

at intervals no greater than 36 months. '

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k. The radiological environmental monitoring program and the  ;

results thereof at least once per 12 months.

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4 The Offsite Dose Calculation Manual and implementing I procedures for solidification of radioactive vastes at least once por 24 months.

.4 i n. The Process Control Program and implementing procedures for

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solidification of radioactive vastes at least once per 24 i

' months. '

n. The performance of activities required by the Quality Assurance Program to meet the. criteria of Regulatory Guide 4,15 December 1977 at least once per 12 months.

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j 20/2643 22:28 IL PhR CLINTON

• 443 7968 NO.487 90-I.

z l gi.,I.NTON NUCLEAR REVIEW $ND AUDIT GROLtP PROCEDIRE MRAct 101 1 me 5 ef 9 Nuclear Review and Audit Group Charter

j. , DATE ISSUED j JUL 10 D91

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. REV. NO. 2 j 6.0 RESPONSIBILITY (Cont'd) i; 6.3 The vice Premu-nt.Nucinar shall appoint an individual in writing i l to be the NRAG Director. The Vice President Nuclear evaluates and j implements actions as appropriate in response to concerns  :

1 forwarded to.him by the NRAG. j i

j 6.4 The NRAG Directar, or his designated alternate, presides at all -

j meetings of the NRAG, and will review and approve the~following: ,

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j 6.4.1 N NRAG Charter and the NRAG procedures.

] 6.4.2 The minutes of all NRAC meetings.

I j 6.4.3 m appointment of all permanent and alternate members. -

j 6.4.4 h formation and membership of subcommittees.

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i 6.4.5 Proposed changes to Technical Specifications. l- l

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J 6.5 The Mananar. cps is responsible for providing the primary interface l l between the NRAG and the FRC. He will bring those items coming i  !

j from the FRC which require NRAC review to the attention of the j

NRAC for inclusion on NRAG agendas. j 1

1 j 6.6 The NRAF Executiva sacratary is responsible for implementation of l l l the administrative procedures detailed in section 7.0 of this  !

charter.  ;

l 6.7 NRAG Members are responsible for carrying out review functions as l l

specified in section 6.1 and 6.2 under the direction of the' NRAG ,

i Director.

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! 6.8 subcommittee chairmen are responsible for ensuring that docume*nts  !

assigned to their respective subconnittees are reviewed within the 1 1 time frame specified and that written responses are returned co'

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the NRAG Executive Secretary, if required. Subec mittee Chairmen I l

j . report to the NRAG Director, j l i

7.0 IPAGEDUP,ES  !

l l 7.1 NRAC Membershin - As a minimum, the NRAG shall be comprised of a 1 Director and four ptraanant members._ Additional permanent and alternate members shall' be appointed in writing'and approved by i

the NRAG Director. Current membership rosters approved by the  ;

NRAG Director shall be maintained by the NRAG staff.  !

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104MG 11:21 IL PWR CLINTON

• 443 7861 to.407 90 l* *

• fLINTON NUCLEAR REVIEW AITD AUDIT GROUP PROCEDURE NRAGP 101 1 l

Pan 6 of 9.

j Nuclear Review and Audit Group Charter DATE ISSUED i

JUL 10 W1 ,

I . REv, wo f 2 ,

! 7.0 PROCEDURES (Cont'd) l 7.1.1 Alternate Members are recommended to the NRAC Director by ,

the permanent member for whom they are acting as an i alternate. Alternate members are recognized by the NRAG i Director at the start of the NRAG meetings and this i recognition is documented in the minutes of ths meeting.

j It is the responsibility of the permanent member to fully

! brief his alternate on important matters pending before _

] the NRAG when the alternate will be acting in the #

permanent member's absence.

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7.1.2 The alternate for the NRAG Director shall be designated l

• i l in writing by the NRAC Director from among the membership l (eitb r permanent or siternate).

7.1.3 Motions brou5h t before the NRAG shall be decided by a l  ;

simple majority. l 7.1.4 The use of an alternate is restricted to the legitimate [

absence of the permancut member. An alternate member may -

perform the review of documents forwarded to the permanent NRAC member, but it is the responsibility of the permanar.c member to sign off the NRAG Document Transmittal / Review sheet unless the absence of the

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permanent member precludes a timely response of NRAC  ;

review documents.

7.2 Meetine Frecuenev . The NRAG shall meet at least once per wix months.  ;

7.3 FRAG Meetine Quorum . It is the responsibility of the NRAG memh r '

to attend scheduled meetings and to notify the NRAG Executive ,

Secretary when circumstances arise precluding attendance at a scheduled meeting. A quorum for formal meetings of the committee j held under the provisions of 7.2 shall consist of the NRAG i Director or his alternate and at least four NRAC members or l

. alternates and shall be subject to the following constraints:

7.3.1 No more than a minotity of the quorum shall have line responsibility for the plant. l 7.3.2 Consultants and other non-IP personnel may be utilized to provide expert advice to the NRAG as' determined by the NRAG Director. Unless having been appointed a permanent or alternate member as defined in paragraph 7.1, these individuals shall not participate as members in NRAC l deliberations. Their reports may be included in minutes of the meetings at the request of any permanent member.

(NRAGP)

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20/26/93 11:22 IL PlJR C1.INTON

• 443 7861 NO.407 D0'

• C11NTON NUCTRAR REVIEU AND AUDIT OROUP P10CEDURE NRAGP 101-1 -  ;

• . Para 7 ef 9 DATE ISSUED j

i. - Nuclear Review and Audit Group Charter JUL 10 *.21 j,

" ' REV. NO. 2

• I f.0 PROCEDURES (Cont'd) {

7.4 Authority ,

7.4.1 The NRAG shall report to and advise the Vice President - '

Nuclear on those areas of responsibility specified in paragraph 6.0. In fulfilling these 6tties NRAG members ,

are afforded the prompt and complete rapport of those l personnel responsible-for the areas < '

ng reviewed.  !

Should a situation arise where an A member cannot e obtain the necessary assistance or support requested, the  ;

particulars of the situation will be immediately brought to the attention of the NRAG Director or the NRAG i '

Executive Secretary for resolution. l 7.5 Proceduras  ;

i 7.5.1 Detailed procedures shall be developed to describe the operation of the NRAG. Such procedures shall be reviowed ,

by the NRAG and approved by the NRAG Director. ]

7.5.2 The NRAG Executive Secretary prepares and saintains the l NRAG Procedures.

7.6 WRAC Meetine Arenda .

7.6 *  % e NRAG Executive Sacratary: ,

s. prepares an agenda for each regular NRAG meeting, and l

b. transmits the agenda under cover of a memorandum to each NRAG permanent nomber, assigned alternate, and other personnel deemed appropriate approximately two weeks prior to the scheduled date of the NRAG meeting.

7.6.2 h1Ac nambers may add subjecti to the agenda by contacting the NRAG Executive Secretary prior to the scheduled meeting or by identifying the subject at the beginning of the meeting.

l 7.7 WRAC Meetine Minutes 7.7.1 The NRAC Executive Secretary preparr.s minutes of each i NRAG meeting as indicated below: i i

' a. NRAG meeting minutes shall be approved by the NRAG  !

Director and distributed to the Vice President.

Nuclear, all NRAG members, and other personnel deemed l appropriate within fourteen (14) days following each -

meeting. .

(NRAGP) , . .

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CLTFTON EUCLEAIL REVIEW AMD. AUDIT CROUP PROCEDURE - IRACP 101-1 Para 8 af 9

, Nucisar Review and Audit Group Charter DATE ISSUED JUL 10 EI

.

• REV. NO. 2 7.0 PROCEDURES (Cont'd)

b. All agenda items are addressed in the minutes.

Decisions and recommendations of the liRAC are documented in the minutes.

c. All documentary material for which the review has been completed since the previous NRAC meeting is identified in the body of the minutes and is included _

as an attachment to the meeting minutes. #

d. If the conclusion of MRAG action results in a minority or dissenting opinion, the dissenter may provide a written statement of the dissent to the NRAG Executive Secretary who includes it in the minutes, l

e. If an item under NRAC review requires further investigation or follow up, it is included in the llRAG -l minutes as an Open Action Item, and entered into the-CPS Centralized Commitment Tracking (CCT) System. _ The Action Item number is used in the description to l distinguish Action Item CCTs from other IRAG CCTs.

7.8 Urnent Review 7.8.1 In the event that unavoidabis time constrainta do not permit the regular distribution, review and administration of any document addressed by this procedure,'the NRAG Executive Secretary say schedule a l conference telephone call requesting the participation of committee members.

7.8.2 Th.s conference telephone call is considered an NRAC ,

meeting. The next meeting number is assigned and the NRAG Executive Secretary shall prepare and distribute minutes of the meeting in accordance with paragraph 7.7 above. -

7.9 Retention _of Records - NRAC meeting minutes, NRAG subcommittee reports and completed document reviews (attached to the meeting j minutes), procedures, training records, safety evaluation logs, '

and membership rosters shall be transmitted to the Records Management Croup for retention in accordance with Reference 3.6.

8.0 TRAINING AND OUALIFICATION 8.1 Traininn Upon receiving an appointment to the NRAG, members, alternates, subcommittee members, and staff are trained and indoctrinated into

.NRAC procedures per Reference 3.2 and 3.7. Records of training and indoctrination are maintained by the NRAG staff.

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(NRAGP)

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• 443 7861 NO.407 9 01

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• CLINTON NUCIhR REVTEU AND AlmIT CROUP PRouzuimE . NRAGP 101'-1

{

, Nuclear Review and Audit Group Charter Fame 9 of 9_

, . DATE ISSUED i ,

JUL 4 0 USI 8.0 REV. No. 2 M ININC AND OUALIFICATION (Cont'd) a 8.2 Oualification 4 Members, alternates and subcommittee members serving on the NRAG shall meet the experience and education requirements of Reference

, 3.2 Section 4.7.2 The NRAC Executive Secretary ensures the expertise requironents of USAR, Section 1.8, and Regulatory Guide 1

] 1.8, paragraph NRAG 6 are lacks technical met. Should expertise, a situation a competent arise technical for which the _ #

individual.

j either from within the company or a consultant, shall be retained j to render expert opinion.

j The NRAG Executive Secretary should meet the same experience and j education requirements as committee members, l s -

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Submitted by: _4404/

G Executive Secretary Date l <

Approved by: / e '

NRAGDpetor Date i

Approved by: 7 f T!T/

Vi(c3) Prosiden@uclear Date l l

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