HL-5233, Revision to Plant Organization & Responsibilities for Qa/Qc, Plant Procedures,Instructions & Drawings & Procedure Changes & Control
| ML20117K901 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/04/1996 |
| From: | GEORGIA POWER CO. |
| To: | |
| Shared Package | |
| ML20117K890 | List: |
| References | |
| HL-5233, NUDOCS 9609120226 | |
| Download: ML20117K901 (14) | |
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l j i Enclosure 1 1
Edwin I. Hatch Nuclear Plant Response to NRC Comments Concerning Ouality Assurance Program Change NRC Comment 1:
l An additional screening question should be added regarding whether or not the proposed l change can create an accident or malfunction of a different type than evaluated in the l FSAR.
1 GPC Response:
l The four screening questions which are answered by GPC personnel prior to the implementation of a program, procedure, or plant design change are expressly intended to l determine the applicability of 10 CFR 50.59 to the change in question. If the answer to all l
four screening questions is "NO", then evaluation of the change per 10 CFR 50.59 is not applicable. The subject question involving whether a proposed change can create an accident of malfunction of a different type than previously evaluated in the FSAR is only required to be evaluated per 10 CFR 50.59 if the screening review determines that the subject regulation is applicable to the change in question. By definition, if an intended 1 change to plant programs, procedures, or design is determined not to be applicable to 10 :
CFR 50.59, it cannot constitute an accident or malfunction of a different type than I previously evaluated in the FSAR. Therefore, the addition of a question of this nature to i the 10 CFR 50.59 screening criteria is not appropriate.
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NRC Comment 2:
Since the Qualified Reviewer (QR) is a single individual rather than a panel of PRB l
members, it is important that the QR be knowledgeable in all subject area:; of the proposed change requiring the 50.59 evaluation, or have access to other individuals with expertise in certain required review areas to assure that the necessary cross-disciplinary reviews are performed.
I GPC Response:
GPC agrees with the staff that the QA Program should ensure that adequate cross-disciplinary reviews, if required, are performed for each 10 CFR 50.59 applicability l screening. GPC previously addressed this issue in Enclosure 1 of the original submittal to the NRC (reference page El-2 of the June 12,1996 submittal) and provides this
- information in Enclosure 2 of the current submittal. In addition, GPC has initiated a
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revision to Section 13 of the FSAR to ensure that the requirement for cross-disciplinary review is identified in the licensing basis.
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Enclosure 1 Response to NRC Comments Concerning Quality Assurance Program Change GPC will also incorporate guidance to this effect into the applicable plant procedure governing the preparation and review of 10 CFR 50.59 screening reviews and evaluations.
Additional wording has been incorporated into the attached revised QA Program change submittal to address this issue.
NRC Comment 3:
Review of 50.59 changes by the QR must be limited to program and procedure changes only. Changes involving plant modifications must continue to be evaluated by the PRB.
GPC Response:
GPC believes that 10 CFR 50.59 does not distinguish between the applicability of the 10 CFR 50.59 screening and evaluation process to changes in plant programs, procedures, or design. As a result, GPC considers the review of changes in each area as being equally important with respect to ensuring continued plant safety. It should be noted that, upon initiation of the use of a Qualified Reviewer, modifications to plant design for which a screening question is answered positively and a full 10 CFR 50.59 safety evaluation is performed will continue to be reviewed by the Plant Review Board as will similar changes to plant programs or procedures.
NRC Comment 4:
The QR cannot be the originator of the proposed change.
GPC Response:
GPC agrees with the staff that it would be imprudent for the originator of a proposed change to plant program, procedures, or design to also act as the Qualified Reviewer for the 10 CFR 50.59 applicability screening of the proposed change. GPC will incorporate guidance to this effect into the applicable plant procedure governing the preparation and review of 10 CFR 50.59 screening reviews and evaluations.
NRC Comment 5:
Indhiduals responsible for approving documents affected by the proposed 50.59 change are responsible for ensuring that the qualification requirements of the QR have been met.
GPC Response:
GPC agrees with the staff that individuals responsible for approving documents affected by a proposed change to plant programs, procedures, and design should be responsible for HL-5233 El-2
I Enclosure 1 l Response to NRC Comments Concerning Quality Assurance Program Change l
ensunng that the qualification requirements of the Qualified Reviewer have been met prior i to an individual assuming the associated duties. GPC willincorporate guidance to this l effect into the applicable plant procedure governing the preparation and review of 10 CFR l 50.59 screening reviews and evaluations.
l NRC Comment 6:
The QR will meet the qualification requirements of Section 4.7.2 of ANSI /ANS 3.1-1981 which has been endorsed by Regulatory Guide 1.8 Revision 2.
GPC Response:
- GPC is not currently committed to ANSI /ANS 3.1-1981 as endorsed by Regulatory Guide 1.8 Revision 2. GPC is instead committed to ANSI N18.1-1971, as endorsed by l Regulatory Guide 1.8 Revision 1, for the selection and training of nuclear power plant l personnel. In contrast to ANSI /ANS 3.1-1981, ANSI N18.1-1971 does not prescribe qualifications for personnel acting in the capacity ofindependent review. In accordance l with Supplement 13.4A of the Hatch FSAR, GPC currently requires members of the Plant Review Board to be supervisory or higher level individuals from the plant functional area which they represent. In addition, alternate PRB members must be qualified to fill the l applicable supervisory position in accordance with plant administrative requirements. In l order to ensure that review of material by the Qualified Reviewer position is consistent l with the quality of review performed by members of the PRB, each QR will be required to l satisfy the same qualification requirements as a PRB alternate. With the exception of not l requiiing an individaal hold a Bachelor Degree in Engineering or related sciences, the
! Hatch criteria for QR qualification generally meet the standards prescribed in ANSI /ANS 3.1-1981.
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l- Enclosure 2 l
l Edwin I. Hatch Nuclear Plant j Description of and Justification for Proposed Changes to OA Program l
Description of Proposed Change:
Currently at Plant Hatch, the Plant Review Board (PRB) is responsible for reviewing all changes in safety-related plant design, procedures, and proposed tests and experiments. 1 i Georgia Power Company (GPC) is proposing a revision that provides a Qualified l l Reviewer who reviews safety-related documents for which the 10 CFR 50 '9 screening questions that GPC uses are answered NO. GPC's screening portion of the 10 CFR 50.59 evaluation establishes whether or not the activity to which the safety evaluation applies represents the following:
- 1. O Yes O No A change to the plant as described in the FSAR?
t 2. O Yes O No A change to procedures as described in the FSAR7 l 1
- 3. O Yes O No A test or experiment not described in the FSAR?
- 4. O Yes O No A change to the Technical Specifications as incorporated in the operating license?
If all the above questions are answered NO, completion of GPC's seven 50.59 unreviewed safety question criteria, which determine the increase in the probability of accidents, the increase in the consequences of such accidents, and the reduction in the margin of safety, is not required. Thus, the PRB will not review the documents. The Qualified Reviewer only reviews the answers for the screening questions and their bases. That is, if at least one of the questions in the screening portion is answered YES, the seven 50.59 questions must be completed and the PRB will review that safety evaluation and the accompanying documentation. Therefore, under the proposed system, all changes to safety-related plant design and procedures will not receive PRB review. However, all safety-related changes will be reviewed by either the Qualified Reviewer or the PRB.
Justification for the Proposed Change:
Eliminating the PRB review of safety-related changes that do not require completion of l the seven 50.59 unreviewed safety questions criteria ponion of the evaluation, will reduce the burden of the PRB. Furthermore, reducing the amount of review material will provide HL-5233 E2-1 l
Enclosure 2 Description of and Justification for Proposed Changes to QA Program more time for the PRB to focus on reviewing issues tmly important to safety, instead of spending time reviewing changes of no safety consequence.
Basis for Concluding OA Program Criteria Are Still Met:
The intent of the PRB review of safety-related plant changes is to ensure no unreviewed safety question exists. The proposed review strategy, as described above, using the Qualified Reviewer maintains that intent for the following reasons:
- 1. The Qualified Reviewer will be responsible for ensuring the responses to the 10 CFR 50.59 screening criteria listed on the previous page reach the proper conclusions and the bases for the answers are adequate such that an independent reviewer would reach the same conclusions. The Qualified Reviewer's signature on the 50.59 evaluation form will serve as an independent evaluation verifying that an unreviewed safety question does not exist. However, if the Reviewer believes a particular screening question was answered erroneously, the document will be returned to the originator for further evaluation. The Qualified Reviewer will also determine whether or not additional cross-disciplinary review is required or desirable.
If deemed necessary, the review will be performed by personnel of the appropriate discipline (s).
- 2. The Qualified Reviewer will be knowledgeable of plant operations and will satisfy the requirements of a PRB alternate.
- 3. Consistent with current practice, if any screening criteria question is answered YES, the PRB will review the document, the pertinent information, and the 50.59 safety evaluation.
Based on the above-listed reasons, adequate review for unreviewed safety questions will be maintained, and the criteria of the original QA program continues to be met.
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Enclosure 3 Edwin I. Hatch Nuclear Plant Revised Quality Assurance Program Change Submittal With Corresoonding Marked-Up FSAR Pages The following marked-up Unit 2 Final Safety Analysis Report pages are included in this enclosure:
17.2-6 and insert page 17.2-15 and insert page 17.2-17 and insen page 17.2-18 and insert page n
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HL-5233 E3-1 C
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, NNP-2-FSAR-17 systems. These activities are governed by appropriate QA program procedures. The SNC SAERM performs, or causes to be performed, l {
audits of these activities and procedures. l i
l 17.2.1.2 Plant Oraanization and Resnonsibilities for OA/OC 40 17.2.1.2.1 Nuclear Plant General Manager l 9
Cl The NPGM has the site responsibility for implementation of the QA l program at the plant site. He is responsible for compliance with O
the requirements of the Operating License and the Technical Specifications, and for the safe, reliable, and efficient '
C1 operation of the NNP. The plant operations assistant general d( manager (POAGM) and the plant support assistant general manager (PSAGM) report to the NPGM. The organizational structure, the interface with the general office, and the qualifications of plant personnel are discussed in chapter 13.
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17.2.1.2.2 Plant Review Board (PRB)
The PRB is comprised of the designated plant supervisory
---personnel-or alternates and has advisory duties to the NPGM. Th l Ptt revi;;; ps;p;;;d ;efeti ..l.L.J yl...L ym m.J .e; and chaz;;;
_ th r t pri r t: Oppr;T;l by plant ;;n;;;;;nt :nd r;vi:U: 211
pr ; : d th ; : t: f:ty-::1;t;d ;y;t:::, :::; nt te, trd ctr :tur::, 2nd pr ; ::d t::t :nd ;;p;riz:nts. The PRB reviews all reportable violations of the Technical Specifications and i also screens subjects of potential concern to the SRB. (See ,
p4 paragraph 13.4.2.1.)
17.2.1.2.3 Operations Manager l W
The operations manager reports to the POAGM and has the l
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. responsibility to ensure the plant operates in accordance with written, approved procedures and license requirements. He must ,
i 1C ensure operations personnel are trained and qualified and I; operations activities are governed by effective administrative controls. He is also responsible for the operation of the radwaste facility.
REV 1 7/83 l REV 2 7/84 '
REV 3 7/85 l CL REV 4 7/86 uJ REV 5 7/87 Qd RIV 7 7/89 REV 8 7/90 REV 9C 7/91 REV 10c 7/92 REV 11B 1/93 17.2-6 REV 14D 7/96
i INSERTl 17.2.1.2.2 Qualified Reviewer / Plant Review Board 17.2.1.2.2.1 Qualified Reviewer
- Qualified Reviewers are designated plant personnel. The Qualified Reviewer reviews j items which require screening for 10 CFR 50.59 applicability and for which the answers to l the screening questions indicate that the completion of a 10 CFR 50.59 safety evaluation is not required. All such items will be reviewed as described in Supplement 13.4A. I INSERT 2 l
l The PRB reviews items which require screening for 10 CFR 50.59 applicability and for I
! which an answer to at least one of the screening questions indicates that the completion of a 10 CFR 50.59 safety evaluation is required. All such items will be reviewed as described in Supplement 13.4A.
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HNP-2-FSAR-17 l'
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- f:terrin rh th r en unr:rirr:f r:fet; qur tirr j 30 0 2 00.00; in irr:lr:f. Unreviewed safety questions and i
safety evaluations for changes to the plant are reviewed by the SRB in accordance with SRB procedures. Design change requests j are forwarded to the NELM for evaluation. The detailed l engineering will be performed by an approved A/E organization l 09 using similar procedures developed and used in the original i design of the plant with audits being conducted under the j h- direction of the SAER department. Minor design changes are
! QC forwarded to the engineering support manager for evaluation. The l l
- scope of minor design changes is discussed with the A/E prior to implementation to determine whether A/E design involvement is 33 required. The responsible engineering organization establishes controls for the review, approval, release, distribution, and
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- 3C revision of documents involving design interfaces with j k; participating organizations. The completed detailed design is then forwarded to the NPGM, who uses the maintenance work order l 1 system for implementation. After implementation, as-built j
information for design change requests and minor design change gg requests is forwarded to the A/E for incorporation in plant l Q drawings and verification of design conformance.
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CL j y 17.2.4 PROCUREMENT DOCUMENT CONTROL i
! Corporate and site procedures describe the process by which 1
I materials and services are procured for safety-related systems, structures, and components.
2 17.2.4.1 Procurement Document Processing j A. Requisitions contain or reference sufficient information j to identify end-use of all ordered items.
i f' B. All procurement requisitions, with the exception of nonplant items, are reviewed, completed, and approved by materials engineering at HNP or the SNC engineering department at the corporate office.
mnt 2 7/84 REV 3 7/85 REV 4 7/86 REV 6 7/88 mnr7 7/89 REV 9C 7/91 REV 12A 10/93 REV 13B 1/95 REV 14B 1/96 17.2-15 REV 14D 7/96
INSERT 3 A Qualified Reviewer, or the PRB, as appropriate (See 13.4.2 and Supplement 13.4A),
reviews all proposed modifications to safety-related systems to determine whether an unreviewed safety question (10 CFR 50.59)is involved with the change.
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, HNP-2-FSAR-17 17.2.5.1 Plant Procedures. Instructions, and Drawinas The HNP procedures are used for periodic test and calibrations, special processes, modifications, maintenance, and other plant activities on safety-related systems, equipment, or structures.
New procedures and revisions to existing procedures are reviewed by plant personnel. This review is for compliance with provisions of the QA program, applicable codes, standards and regulations, inclusion of appropriate acceptance criteria, and process controls. r;11 ;-ing th: : ci:1, th: ;;;: furt: cr:
,,,r titerf by th: P"2 pri:: t: icing rign d by : 22 irr :f pl:nt Written administrative procedures ensure proper control of instructions such as temporary procedure changes, standing orders, and night orders. These instructions are of limited
+ scope and issued for limited time periods to ensure proper requirements included in the procedures are not bypassed or F- neglected.
T Plant drawings reflect the properly reviewed and approved configuration of the plant. Changes as a result of design 2k changes (subsection 17.2.3) or as-builts are controlled by written procedures the same as drawings until properly revised a- drawings are received. The design organization implements design
(,. control through written procedures.
3 17.2.5.2 Other Procedures Each organization performing quality-related activities has J properly reviewed and approved QA programs or procedures.
OL These programs or procedures are reviewed for quality W requirements and concurred with by the SAERM or his l O( representative.
Examples of procedures include corporate nuclear support procedures.
REV 1 7/83 REV 2 7/84 REV 3 7/85 REV 5 7/87 REV 6 7/88 REV 7 7/89 REV 9C 7/91 REV 12A 10/93
, 17.2-17 REV 14D 7/96
INSERT 4 Following this review, the procedures are reviewed by either a Qualified Reviewer or the PRB (see 17.2.1.2.2) prior to being signed by a member of plant management.
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, HNP-2-FSAR-17 l 17.2.6 DOCUMENT CONTROL 17.2.6.1 Procedure Chances and Control Changes to HNP procedures fall into two categories: permanent i
changes and temporary changes. ^n ;;;;;f;;;; th t f: :t ::;uir ~ l
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- nd:f ;;;;c;l b-j th rn;, the appropriate member of plant management gives written approval prior to the change being implemented and incorporated in the appropriate section of the procedure. The proposed temporary changes that require immediate action to protect the safety of personnel or provide for protection of plant equipment require that the change be written, L provided the intent of the original procedure is not altered and Q that the change is approved by two members of the plant management staff, at least one of whom holds a senior rec: tor Vi operator's license. The required action is taken as set forth in
}{ administrative procedures.
All other instructions, procedures, and drawings are revised and D! controlled in a manner consistent with the original issue of that
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{ procedure unless otherwise specified in this paragraph.
$3 The plant administration manager establishes a system ensuring l that the responsible supervisors receive current revisions of (d drawings, procedures, and other required documents and that superseded revisions or copies are removed and destroyed. The responsible supervisor is responsible for ensuring that the qg latest revision of appropriate documents is being used to perform (g safety-related activities. Documents controlled by offsite gg organizations receive comparable issue and control as site documents.
17.2.6.2 Einal Safety Analysis ReDort. Emeraency Plan. Security Plan. Technical Soecifications Chances and Control The NELM of the HNP nuclear support organization has l administrative control of the Final Safety Analysis Report REV 2 7/84 REV 3 7/85 REV 4 7/86 REV 5 7/87 REV 6 7/88 REV 7 7/89 l REV 9C 7/91 l REV 12A 10/93 i REV 13B 1/96 REV 14B 1/96 17.2-18 REV 14D 7/96
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' INSERT 5 On procedures that do not require immediate action, the change is prepared and j subsequently reviewed by either a Qualified Reviewer or the PRB (see 17.2.1.2.2). '
Following recommended approval by the QualiEed Reviewer /PRB (as appropriate),.. J
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