L-86-363, Forwards Response to 860721 Request for Addl Info Re Rev 9 to Topical QA Rept FPL Tqar 1-76a
| ML17346B245 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 09/09/1986 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| L-86-363, NUDOCS 8610270455 | |
| Download: ML17346B245 (15) | |
Text
ACCESSION NBR:
FAC IL:50-250 50-251 AUTH. NAME WOODYi C. O.
REC IP. NAME REYESi L.
REQULATOR NFORMATION DISTRIBUTION S EN (RIDS) 8610270455 DOC. DATE: 86/09/09 NOTARIZED:
NO DOCKET ¹ Turkey Point Planti Unit 3I Florida Power and Light C
05000250 Turkey Point Pl anti Unit 4I Florida Potoer and Light C 05000251 AUTHOR AFFILIATION Florida Power i% Light Co.
RECIPIENT AFFILIATION Region 2> Office of Director
SUBJECT:
Forwards response to 860721 request for addi info re Rev 9 to Topical GA Rept FPL TGAR 1-76a.
DISTRIBUTION CODE:
0004L COPIES RECEIVED: LTR
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ENCLl SIZE:
TITLE:
GA Topical Report (Docket/Utility SpeciFic)
NOTES:
RECIPIENT ID CODE/NAME PNR-A PD2 LA INTERNAL: ADM/LFMB AL 01 EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
1 0
1 2
2 1
1 1
1 RECIPIENT ID CODE/NAME McDONALD> D AEOD/PTB IE/DGAVT/GAB RQN2 NRC PDR COPIES LTTR ENCL 1
1 1
2 2
1 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 13 ENCL 12
P.
X I4000, JUNO BEACH. FL 33408
~r I
'r FLORIDA POWER IIr LIGHTCOMPANY SEPTEMBER 9 1S86 L-86-363 Luis Reyes, Acting Director Division of Reactor Projects, Region II U.S. Nuclear Regulatory Commission Suite 3 l00 IOI Marietta Street, N.W.
Atlanta, Georgia 30323 t
Dear Mr. Reyes:
Re:
Turkey Point Plant Unit Nos. 3 and 4 Docket Nos. 50-250 and 50-25 I St. Lucie Plant Unit Nos.
I and 2 Docket Nos. 50-335 and 50-389 Topical Quality Assurance Report (FPL TQAR I-76a)
Res onse to Re vest for Additional Information Your letter dated July 2I, l986 transmitted NRC's Request for Additional Information (RAI) regarding Revision 9 to FPL TQAR l-76a.
The attached provides a complete response to your request.
Should you require any additional information, please contact us.
Very truly yours, C. O. Wood Group Vic resident Nuclear Energy CO W/GRM/cvb Attachment cc:
Dr. J. Nelson Grace, NRC Region II Harold F. Reis, Esquire 8610270455 860909 PDR
- DOCK 05000250 P
PDR QcQLI GRM4/004/I PEOPLE... SERVING pEOPLE
Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl-I Section l.2.3.2,'age 9 of 27 (of Revision 9)
Within this section, the duties, responsibilities, and authorities of each manager in the Quality Assurance Department are delineated.
ln Revision 9, an exception was made for the Quality Assurance Systems and Audits Group.
instead of assigning responsibility to an individual, the revised version assigns responsibility collectively to the group as a whole.
Explain the reason for this change.
FPL RESPONSE The title of Assistant Manager of Quality Assurance was removed from the responsibility for the Systems and Audits group and this responsibility was assigned in the Topical to the group as a whole.
The position of Assistant Manager of Quality Assurance has been eliminated for this grou', however, the individual supervising this group is the Supervising Engineer - QA Systems and Audits reporting to the Manager of QA Services.
This is described in the paragraph above on the same page.
I Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl-2 Section l.2.4, Page l7 of 27
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Revision 8 states that the QA Department has a representative assigned to each major
- project, who reports to the Director of Quality Assurance.
Revision 9 deletes this requirement.
Explain the basis for this deletion.
FPL RESPONSE This section was deleted as a result of modifying section l.2.3.2 on Page l3 of 27.
Each site has a Superintendant of QA who reports to the Director of Quality Assurance.
The project
. QA
~ Engineer reports to this Superintendent of QA.
I
Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment
RAI-3
Section? 2.2, Page 4 of 7 Revision 8 states that quality instructions shall be reviewed by the Quality Assurance Department.
Revision 9
states that these instructions shall be reviewed at each revision.
Explain the reason for adding "at each revision" to this statement and how it impacts other parameters governing the frequency of procedure review.
FPL RESPONSE It is the practice of the Quality Assurance Department to review not only the initial issuance of any department's Quality Instructions, but also any changes made to those Quality Instructions.
The frequency of this review is dictated by the individual department's need to change their instructions for more efficiency, effectiveness or to meet additional requirements which may arise.
Re:
Docket Nos. 50-250, 50-25 l 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl4 Section 2.2.0, Page 5 of l7 Revision 9 deletes three responsibilities of the QA Department dealing with the coordination of the QA program, the Topical Report, and the review of quality instructions written by other groups.
Explain the basis for the deletion.
FPL RESPONSE The statement of responsibility for the Quality Assurance Department was deleted because it was redundant with information already provided in section l.2.3.2.
This deletion prevents the future possibility of conflicting information.
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Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR l-76a L-86-363 Attachment
RAI-5
Section 2.2.5, Page 6 of l7 Revision 9 removes the commitment for the QA Department to be responsible for the indoctrination of supervisory personnel.
lt also deletes requirements for department heads to indoctrinate non-supervisory personnel.
Explain the basis for this deletion.
FPL RESPONSE This section still requires 'hat Quality Procedures delineate the requirements for an indoctrination program to assure that personnel responsible fo'r performing quality activities are instructed in the
- purpose, scope, and implementation of the quality related
- manuals, instructions,.and procedures and that compliance to these documents is a mandatory requirement.
The Quality Assurance Department has established and developed the program for quality assur'ance indoctrination of these personnel.
The Quality Procedures specify who is qualified to give this indoctrination.
Although these individuals are currently limited to our certified Lead Auditors and the personnel administering training for plant access, individuals qualified from other departments may be added in
'the future for efficiency
.and effectiveness.
Maintaining this detail of the indoctrination process in the Quality Procedure allows this management flexibility.
Re:
Docket Nos. 50-250,. $0-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl-6 Section 6.2.l, Page I of 3 Revision 8 states that quality procedures shall delineate the control measures for controlled documents including direction for the verification that changes are properly incorporated.
Revision 9 changes the wording to read "verification that changes are received".
Explain the reason for this wording change.
FPL RESPONSE The purpose of this section of Document Control is to specify examples of control measures that are to be included in the Quality Procedures.
The example was changed from verifying that changes are incorporated to verifying that they are received because receipt is the result of a receipt acknowledgement system.
The result of our audit system verifies the incorporation of changes.
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Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment
RAI-7
Section 7.L3, Page 3 of 3 Revision 8 lists six elements which shall be included in receiving inspections.
Revision 9 deletes one of these
- elements, dealing with identifying, segregating, and handling nonconforming items.
Explain the basis for this deletion.
The element dealing with nonconfirmng items was deleted after modifying the elements of receiving inspection that concern any outcome of both inspection instructions and the identification of the inspection status.
Details, of nonconformance control are specified in section I 5.0 of the Topical Report; these details address the identifying, segregating and handling of nonconforming items.
Re:
Docket Nos. 50-250, 50-251 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment j
.a
RAI-8
Section l3.2. l and l3.2.2, Page I of 2 The last paragraph of Section 13.2.1 and the entirety of Section 13.2.2, concerning the establishment of
- handling, storage, and shipping requirements, was deleted by Revision 9.
Explain the basis for this deletion.
FPL RESPONSE These paragraphs were moved to section 4.2.1 to avoid any future possibility of conflicting requirements regarding procurement documents.
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Re:
Docket Nos. 50-250, 50-25 l 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl-9 Section 7.2. l, Page l of 2 Revision 8 contains a list of six elements
- which, as a minimum, inspection and test records shall identify.
This list is deleted by
'Revision 9.
Explain the basis for this deletion.
FPL RESPONSE This listing was added to both sections l0.2.4 and I l.2.2 to avoid any future possibility of conflicting requirements for inspection and test records.
Re:
Docket Nos. 50-250, 50-25 I 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAI-IO Section l8.2.2, Page 3 of 5 In revision 8 of this section, letter "c", the scope of audit activities includes the request for proposals and evalution of bids.
Revision 9
revised this commitment to require audits only of the evaluation of bids.
Explain the basis for this change.
FPL RESPONSE The reason for the deletion is because this requesting document does not represent a binding offer to either the buyer or seller.
For this
- reason, the request for bid proposals are not considered to be record documents within the Purchasing Department files and are not audited.
Re:
Docket Nos. 50-250, 50-251 50-335 and 50-389 FPL TQAR I-76a L-86-363 Attachment RAl-II Section l8.2.5, Page 5 of l5 Revision 8 states that when implementation of corrective action cannot be verified by other
- means, a reaudit of deficient areas shall be performed to accomplish verification.
Revision 9
deletes this requirement.
Explain the basis for this deletion.
The last sentence of this section was deleted and verification requirement was added to the previous sentence.