ML20204E953

Forwards Proposed Change to BVPS Units 1 & 2 Operations QA Program Description for NRC Approval,In Accordance with 10CFR50.54(a)(3)(ii)

ML20204E953
Person / Time
Site:	Beaver Valley
Issue date:	03/16/1999
From:	Jain S DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-99-015, L-99-15, NUDOCS 9903250181
Download: ML20204E953 (9)

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Beav Valley Power Station Shippingport, PA 15077-0004 4

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{.}"r}{. P{..jo.nt L- -015 Fax $ N E E Nudear Power Division U. S.-Nuclear Regulatory Commission l

Attention: Document Control Desk l Washington, DC. 20555-0001 i

Subject:

Beaver Valley Power Station, Units No.1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. DPR-73 I Quality Assurance Program Description Change In accordance with 10 CFR 50.54(a)(3)(ii), this letter forwards for NRC approval, a proposed change to the Beaver Valley Power Station (BVPS) Units 1 and 2 Operations Quality Assurance (QA) Program Description.

• This change would reduce the QA  !

Program Description commitments for both Units by limiting required Onsite Safety Conunittee (OSC) reviews of procedures to those requiring a 10 CFR 50.59 safety evaluation. Similar procedure review programs have received NRC approval for other nuclear facilities, including Limerick Generating Station, Peach Bottom Generating Station, and Wolf Creek Generating Station.

Attachment I further describes the proposed change, the reason for the change, and provides the basis for concluding that the revised program incorporating this change continues to satisfy the critena of 10 CFR 50, Appendix B.

Attachment 2 presents the proposed wording changes to the Unit No. 2 UFSAR to reflect this change.

1 If you have any question regarding this submittal, please contact Mark S.

Ackerman, Manager of Safety and Licensing in the Nuclear Services Group, at (412) 1 393-5203. ,

t Sincerely,

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9903250181 990316 7 PDR ADOCK 05000334.

d P PDR.L Sushil C. Jain VEllVERING

' The Operations QA Program description for BVPS Unit I was deleted from the Unit 1 0VALITY Updated Final Safety Analysis Report (UFSAR) in January 1988 and the program description for BVPS Units I and 2 is provided in Section 17.2 of the Unit 2 UFSAR. E @G Y

Geover Valley Power StItiono Unit No. I and No. 2 Quality Assurance Program Description Change Pagea i c: Mr. D. S. Collins, Project Manager l Mr. D. M. Kern, Sr. Resident Inspector Mr. H. J. Miller, NRC Region I Administrator i

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I ATTACHMENT 1 PROPOSED CHANGE DESCRIPfION t

1 Currently, with respect to permanent procedure changes, the Onsite Safety Committee J (05C) reviews all procedures required by Technical Specifications 6.8 and intent changes thereto, as part ofits responsibilities. These are subsequently approved by the General Manager of Nuclear Operations (GMNO). The proposed change would allow ]

substitution of a review by an independent qualified reviewer (IQR) and approval by the responsible discipline Manager or his designee when a 10 CFR 50.59 safety evaluation is {

not required. The OSC would review all new procedures requiring safety evaluations, and procedure revisions which require safety evaluations as dermed by 10 CFR 50.59.

At present, temporary changes to procedures are reviewed similar to permanent changes when a change ofintent is involved. Ifintent is not being changed, approval by two members of plant management (one holding an SRO license) is required prior to implementation. OSC review and GMNO approval may then be obtained up to 14 days following implementation. With the proposed change, when no safety evaluation is required, temporary changes to procedures would be approved by two knowledgeable ,

members of the plant staff, with at least one of these individuals a member of plant j supervision. One of these individuals must hold an SRO license if plant operations j procedures are affected. These changes would be reviewed by an IQR and approved by )

the responsible manager or his designee within 14 days ofimplementation.

IQRs would be qualified to perform 10 CFR 50.59 applicability determinations. IQRs would meet or exceed the qualified levels of a staff specialist, as described in ANSI N18.1-1971 and would be certified by the OSC and approved by the Plant Manager.

These reviewers could be from the same organization; however, they would not be the 1 preparer of the proposed procedure or procedure change. In addition, these reviewers would determine the necessity for and ensure a cross-disciplinary review, if necessary, prior to procedure approval. The qualifications of the IQRs and the review process employed would provide a level of expertise similar to that provided by the OSC.

Similar procedure review programs,' employing certified independent qualified reviewers, have received NRC approval for other nuclear facilities, including Limerick Generating Station, Peach Bottom Generating Station, and Wolf Creek Generating Station. Pending

'NRC approval of the IQR process, BVPS intends to commence implementation of this I process on June 30,1999.

The proposed change would eliminate OSC reviews of the security plan, emergency plan, and associated implementing procedures except as specified in the plans.

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! ATTACHMENT 1 (continued) i

, . j REASON FOR THE PROPOSED CHANGE This proposed change would improve OSC effectiveness by better concentrating the -

OSC focus on issues important to safety. This would improve utilization of management personnel serving on the OSC and other members of the plant staff. In addition, this would maintain the quality and efficiency of the procedure review process and thorough reviews ofissues with potential for affecting nuclear safety.

BASIS FOR CONCLUDING THAT THE REVISED PROGRAM INCORPORATING THE PROPOSED CHANGE WOULD CONTINUE TO SATIS 7Y THE CPITERIA OF 10 CFR 50, APPENDIX B l

With incorporation of this proposed change to the procedure review process, the revised j QA Program would continue to satisfy the criteria of 10 CFR 50, Appendix B. j Section VI, " DOCUMENT CONTROL" of the Appendix allows the licensee to t designate a responsible organization, other than the organization that performed the original review and approval, to review and approve proposed procedures and procedure

changes. With this proposed change, adequate controls will remain which ensure the i OSC will continue to review proposed procedures or proposed changes in procedures I which require safety evaluations. The proposed change is consistent with ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants,"/ANS 5.2.15, " Review, Approval and Control of Procedures," and NRC Generic Letter 93-07, " Modification of Technical Specification Administrative Control Requirements for Emergency and Security Plans."

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ATTACHMENT 2

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BVPS-2 UFSAR Revision (TBD) 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 be 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.

The OSC shall be responsible for:

1. Review of news) :!! preced :: required by Technical Specific tien 68-and ehange: cfintent i rete, b) any ci : prepc d procedures reauiring 10 CFR 50.59 safety evaluations ander changes to existina procedures i:retc which Page (TBD)

1 ATTACHMENT 2 (continued) l l

BVPS-2 UFSAR Rev. (TBD) reauire 10 CFR 50.59 safety evaluations.= d:::=ined by 1: O==:1 l

M=:ge, Nue!:= Op=:d=: tc ef*::: :::!:= ::fe:y.

2. Review of all proposed tests and experiments that affect nuclear safety.

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 l equipment that 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. Reviev/ cfi: S:: -ity Pl= =d imp!:== ting prc::d==.

10. Revi:v/ cf $e E==;=:y P!= =d !=p!:== ting preced==.

The OSC shall:

1. Recommend to the General Manager, Nuclear Operations written approval or disapproval ofitems considered under OSC responsibility 1 through 4 above.

2. Render determinations in writing with regard to whether or not each item considered under OSC responsibility 1 through 5 above constitutes an unreviewed safety question.

3. Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the President, Generation Group and Chief Nuclear Officer and the Offsite Review Committee of disagreement between the OSC and the General Manager, Nuclear Operations; however, the General Moager, Nuclear Operations shall have responsibility for resolution of such disagreements pursuant to Technical Specification 6.1.1.

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ATTACHMENT 2 (continued)

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BVPS-2 UFSAR Rev. (TBD)

The OSC shall maintain written minutes of each meeting and copies shall be provided to the General Manager, Nuclear Operations and Chairman of the Offsite Review Committee.

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ATTACHMENT 2 (continued)

"- S BVPS-2 UFSAR Rev. (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, e c 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 im.portant 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 l applicable requirements of NRC Regulatory Guide 1.33 were used as guidance in the I development of startup, operating, emergency, maintenance, and testing procedures.

Maintenance, repair, modifications, testing, and refueling activities which affect the quality or 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 tools, test equipment, processes, controls, or  !

skills, in order to attain the required level of quality, i Each procedure of Technical Specification 6.8 and changes thereto shall be reviewed by an independent analified reviewer and anoroved by the responsible manager or designee.

The independent reviewer shall also coordinate cross-disciplinary reviews. if necessarv.

Independent analified reviewers shall be selected based on knowledae of the pertinent functional area and analification is subiect to OSC review and plant manager aooroval.

Refer to Section 17.2.1.3 for a description of OSC review responsibilities related to procedure revisions.E=h preced: : =d einini:t=tive pclicy of T=hni=1 Spaifi= tion 6.8.1 =d d=g= cfint=1 i:retc, da!! b; =vieve:d by i: OSC =d approved by i:

O=:=1 M:=;;=, N=!=r Ope = tic =, p=deig=ted :!!:= :: cr a ped =ig :ted Page (TBD)

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ATTACHMENT 2 (continued)

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