ML042190353
| ML042190353 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 07/30/2004 |
| From: | Barron H Duke Energy Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Peters, S, NRR/DLPM/301-415-1842 | |
| Shared Package | |
| ML042220045 | List: |
| References | |
| TAC MB7166, TAC MB7167, TAC MB7168, TAC MB7169, TAC MB7170, TAC MB7171, TAC MB7172 | |
| Download: ML042190353 (17) | |
Text
{{#Wiki_filter:P July 30, 2004 U. S. Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555-0001
Subject:
Duke Energy Corporation Oconee Nuclear Station, Units 1, 2, and 3, Docket Not. 50-269, 50-210,50-287 McGuire Nuclear Station, Units I and 2, Docket Nos. 50-369, 50-{310 Catawba Nuclear Station, Units 1 and 2, Docket Nos. 50-413, 50-414 i Submittal of Duke Energy Topical Report, Duke A, Amendment 33 (TAC Nos. MB7166, MB7167, MB7168, MB7169, MB71790,IMB7171;,MB7172 By letter dated December 18, 2002, Duke Energy Corporation (Duke> submitted Amendment 32 to its Duke Energy Topical Report, Duke-1-A, on the Quality Assuranrce(QA) Program for the Oconee, McGuire, and Catawba Nuclear Stations. On both April 4, 4003 and July 10, 2003, the NRC requested additional information concerning this amendment. Duke responded to the two requests on April 24, 2003 and October 16, 2003, respectively. "That amendment and requests for additional Information primarily focused on the use of process monitoring for certain inspection activities. A meeting between Duke personnel and NRC Staff was held on April 8, 2004 to discuss Amendment 32 resulting in the NRC Summrary of the meeting dated April 16, 2004. Subsequently, on June 1, 2004, the NRC Staff held a conference call with Duke to discuss the status of the request to Implement Amendment 32 to the Duke QA Topical Report. The NRC staff requested this call in order to identify additional items resulting in the Telecon Summary of June 28, 2004. On June 3, 2004, Duke submitted the alternative Amendment 32 to Duke QA Topical which reflected organizational, administrative, and editorial changes. After consideration of the preceding interactions with the NRC staff and the submittal of Amendment 32 in June, Dukie has prepared Amendment 33 (attached) that revises the 2002 submittal content concerning Section 17.3.2.12 linspections of the QA Topical. In accordance with '10CFR50.54(a), Duke has completed detailed evaluations of each of the changes contained therein and has determined they are consistent with the requirements of 10CFR50 Appendix B and guidance established by Nuclear Regulatory Guide, 1.33 Rev. 2 - Quality Assurance Program Requirements (Operations). The evaluation of the December 2002 submittal concluded that the changes to the QA Topical contained a reduction In commitments. This evaluation was based on the comparison of the then current Duke QA Program to the requirements outlined in the proposed new program. On further evaluation, Duke has revised QA Topical Section 17.3.2.12 inspections" to align with the inspection requirements of 10CFR50 Appendix B and ANSI N18.7-1976/ANS-3.2. This alignment demonstrates Duke's compliance with the inspection requirements set forth in these codes and standards. Attachment 2
U. S. Nuclear Regulatory Commission July 30, 2004 Page 2 The summary results of the Duke evaluation for Amendment 33 are in Attachment 1 and provide a description, reason, and basis for each change. Attachment 2 contains Amendment 33. Changes are shown by the use of indicator bars in the margin of affected pages. Please direct any questions to R. L. Gill at 704 382-3339 or K. S. Isley at 704 382-5019 (E mail: ksisley@duke-energy.com). Very truly yours, Henry B. Barron Attachments
References:
- 1. Letter, M. S. Tuckman to USNRC, "Nuclear Quality Assurance Program Amendment 32,"
December 18, 2002
- 2. Letter, R. E. Martin to M. S. Tuckman, "Duke Energy Corporation Nuclear Quality Assurance Program Request for Additional Inforrnation," April 4, 2003
- 3. Letter, W. R. McCollum to USNRC, "Response to Request for Additional Information Letter Dated April 4, 2003," April 24, 2003
- 4. Letter, R. E. Martin to M. S. Tu6kman, 'Re: Nuclear Quality Assurance Program, Amendment 32," July 10, 2003
- 5. Letter, W. R. McCollumto USNRC, "Response to Request for Additional Information Letter Dated July 10, 2003," October 16, 2003
- 6. Letter, S. E. Peters to buke Energy Corporation, "Summary - Meeting with Duke Energy Corporation on Request to Modify the Quality Assurance Program for The Catawba, McGuire, 4And .Oconee Nuclear Stations," April 16, 2004
- 7. Letter, H. B, Barron tofUSNRC, "Alternative Submittal of Duke Energy Topical Report, Duke-1I-A,'Amendment 32," June 3, 2004
- 8. Telecon tumma'ry of June 1, 2004, "Conference Call Regarding Duke Power Company's TRequest to Modify the Quality Assurance Program for the Catawba, McGuire and Oconee Nuclear Stations, June 28, 2004 I
U. S. Nuclear Regulatory Commission July 30, 2004 Page 3 xc: (with attachments) W. D. Travers, Regional Administrator U. S. Nuclear Regulatory Commission, Region II 61 Forsyth St., SW, Suite 23T85 Atlanta, GA 30303-8931 S. M. Coffin (addressee only) NRC Acting Chief, Section 1, PD II Mail Stop 0-9 H6 Washington, DC 20555-0001 L. N. Olshan (addressee only) NRC Senior Project Manager (ONS) Mail Stop 0-8 H12 Washington, DC 200555-001 J. J. Shea (addressee only) NRC Senior Project Manager (MNS) Mail Stop 0-8 H12 Washington, DC 20555-0001 S. E. Peters (addressee only) NRC Project Manager (CNS) Mail Stop 0-8 H12 Washington, DC 20555-0001 M. C. Shannon NRC Senior Resident Inspector Oconee Nuclear Station J. B. Brady NRC Senior Resident Inspector McGuire Nuclear Station E. F. Guthrie NRC Senior Resident inspector Catawba Nuclear Station
U. S. Nuclear Regulatory Commission July 30, 2004 Page 4 bxc: (with attachments) J. J. Fisicaro - EC05R J. A. Kammer - MG01VP R. L. Sweigart - CN01 SA L. E. Nicholson - ON01VP R. L. Gill - EC05P P. W. Downing - EC05N R. K. Rhyne - EC05A L. A. Keller - CN01 RC B. G. Davenport - ON03RC C. J. Thomas - MG01 RC NCMPA-1 SREC PMPA NCEMC K. S. Isley, IlIl - EC05N P. D. Wright - EC05A L. B. Jones - ECO50 ONS Master File OS 801.01 - ON03DM MNS Master File OS 801.01 - MG01S2 CNS Master File OS 801.01 - CN04DM ELL
Attachment I Duke Energy Corporation Topical Report, Duke-1-A Quality Assurance Program, Amendment 33 Description of Changes PURPOSE The purpose of Amendment 33 to the Duke Energy Corporation Topical Report Duke-1-A, Quality Assurance Program is to rewrite Section 17.3.2.12 "Inspections" to more closely align with applicable codes and standards. This attachment provides an evaluation of the 66anges in Amendment 33 to the Duke QA Topical. This evaluation is based on the provisions co&tained in NRC regulation 10CFR50.54(a). BACKGROUND ) When Amendment 32 was submitted for approval in December 200?, Duke stated that after an evaluation in accordance with 10CFR50.54(a) Amendment.32 was a reduction in commitment. At the time, Duke based this decision on the fact that our OA Topical'Report and QA Program were more restrictive than requirements found in ANSI Ni8.7-1976 and IOCFR50 Appendix B. Duke's concern was the wording in the current QA Topical Report in the area of inspections could be misinterpreted to require original design and inspection requirements for every 'maintenance activity. Duke identified the changes as a reduction in commitments when our purpose for revision was to align the Duke QA Program with the necessary codes and standards. In Amendment 33, Duke is not reducing commitments below ANSI N 18.7-1976 or IOCFR50 Appendix B Criteria. As shown in the attached Comparison Table, Duke is outlining how the proposed QA Topical Report Section 17.3.2.12 uinspectionse satisfies the requirements of the standards and codes. Furthermore, Duke has revised the wording in the section to eliminate references to routine and non-routine maintenance that were In the original submittal. DESCRIPTION OF CHANGES Change 1: An editorial change Is made to Table 17-1 "Conformance of Duke's Program to Quality Assurance Standards, Requirements and Guides", page 17-5. For Regulatory Guide 1.58 Rev (1), "ANSI/SNT-CP-189" is added to the second sentence under Remarks to read, "Duke's nondestructive examination personnel will meet the qualification requirements of SNT-TC-1A-1 980 and ANSIISNT-CP-189." This standard was inadvertently left out of Table 17-1. Change 2: Section 17.3.2.12 "Inspections" has been rewritten and reformatted to reflect a closer alignment with ANSI N18.7-1976/ANS-3.2 and IOCFR50 Appendix B Criteria. The following table provides a comparison of the current wording found in Duke QA Topical Amendment 32 in Section 17.3.2.12 "Inspections' to the proposed wording found in Amendment 33 along with an evaluation of the basis for the proposed changes. Column 1 shows the current wording for Duke Topical Report Amendment 32 implemented on June 3, 2004. Column 2 shows the proposed wording for Duke Topical Report Amendment 33.
Column 3 lists the description, reason, and basis for the proposed changes as evaluated in accordance with 10CFR50.54(a) to ANSI N18.7/ANS-3.2 Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plantse and 10CFR50 Appendix B Criteria. CONCLUSION Based on the evaluation of the proposed changes to Amendment 33 in accordance with IOCFR50.54(a), Duke has determined the two changes are consistent with the requirements of 10CFR50 Appendix B and guidance established by Nuclear Regulatory Guide, 1.33 Rev. 2, Quality Assurance Program Requirements (Operations). The need for revision Qf the QA Topical Report was to closer align the Duke Energy QA Program with approved codes and standards, specifically ANSI N18.7-1976/ANS-3.2 and IOCFR5O Appendix B Criteria.
QA Program Amendment 33 Section 17.3.2.12 "Inspection" Comparison Table Column 1 Column 2 Column 3 Row Duke Topical Report Amendment 32 Duke Topical Report Amendment 33 Description, Reason, and Basis for the (current) (proposed) - Proposed Changes I In order to assure safe and reliable operation, a Inorder to assure safe and reliable operation, a
Description:
Two sentences are added in the first program of inspections for QA Condition 1 structures, program of inspections for QA Condition I structures, two paragraphs for proposed Amendment 33. systems and components isestablished at each systems, and components is established at each "i ,. nuclear station. If inspection of processed material or nudear station. Inspection procedures for Reason:expecations con e tivite to products is Impossible or disadvantageous, indirect those activities affecting QA Condition I specific expectarons concerning activities subject to control by monitoring processing methods, equipment, systems and components are Inspections performed, where necessary, to assure and personnel Isprovided. Both inspection and estabcturshe bysNucleardGenrmtonensae qaiy process monitoring are provided when conl Is establshed by Nuear Generation Basis: These changes are consistent with the inadequate without both. peronne requirements of N18.7 Section 5.2.7 and Section Independent Inspections, examinations, 5.2.17 and 10CFR50 Appendix B Criterion X. measurements, observations, or tests of materials, products or activities are conducted, where necessary, to assure quality. If inspection of processed material or products is impossible or disadvantageous, indirect control by monitoring processing methods, equipment, and personnel is provided. Both inspection and proces onitor gare provided when control is Inadequate without both. 2 The program addresses:
Description:
Inthe current topical, the sentence a) inservice inspections required by Section Xl of the` beginning The program addresses...' has been American Society of Mechanical Engineers BoHer and reformatted and moved to a later paragraph inthe Pressure Vessel Code proposed topical (see Row 5 inthis table). b) Inspections to verify compliancewith cleanliness Reason: This change ismade for clarification. criteria." - ' Basis: The basis for this is provided In Row 5 ihange c) Inspections to verify compliance qth dertain of this table. instrument and maintenance procedures. d) Inspections to verify conformande of materials, parts, and components received at anuclear Station with applicable specdfidations)nd requireients. e) Inspections to verify the integrity drlA Condition 1 structures, systems and components during/or after maintenance and modification.
Column I Column 2 Column 3 Row Duke Topical Report Amendment 32 Duke Topical Report Amendment 33 Description, Reason, and Basis for the (current) (proposed) Proposed Changes 3 Inspection procedures, instructions, and checklists
Description:
Inthe proposed topical, the sentence contain the following information or require this beginning Inspection procedures, instructions... has information on Inspection reports: been moved from a later paragraph inthe current a) Characteristics to be inspected topical (see Row 7 of this table). b) Method of inspection . Reason: This move is made for clarification. c) Measuring and test equipment information d) Responsibility for the Inspection Basis: No technical changes have been made. e) Acceptance or rejection criteria f) Identification of required procedures, drawings, specifications, etc. g) Signature or initials of inspector
. h) Record of results of the inspection 4 The personnel performing these inspections are The personnel performing these Inspections are No changes have been made.
examined and certified intheir particular category. examined and certified intheir particular category. Current qualification and certification files are Current qualification and certification files are maintained for each inspector. Nondestructive maintained for each inspector. Nondestructive examination Inspectors are certifed inaccordance with examination Inspectors are certified inaccordance with ANS/Ameican Society for Non-destructive Testing ANS/American Society for Non-destructive Testing (SNT-TC-IA, ANSVSNT-CP-189) recommended (SNT-TC-1A, ANSI/SNT-CP-189) recommended practice. Written procedures require the test and practice. Written procedures require the test and certification of Inspectors In other categories such as certification of Inspectors In other categories such as Mechanical, Electrical, and Structural as described in Mechanical, Electrical, and Structural as described in the appropriate quality assurance manual. For cases the appropriate quality assurance manual. For cases where Inspectors will perform limited functions within a where inspectors will perform limited functions within a category, they are tested and certified to those category, they are tested and certified to those limitations. These inspectors are only allowed to limitations. These inspectors are only allowed to perform Inspections specifically defined Inthis limited perform Inspections specifically defined in this limited certification. eartificafion. For inspections of concrete containments, personnel For inspections of concrete containments, personnel fulfilling the role of Responsible Engineer, shall be a fulfiling the role of Responsible Engineer, shall be a Registered Professional Engineer experienced In Registered Professional Engineer experienced in evaluating the In-service condition of structural evaluating the In-service condition of structural concrete and knowledgeable of the desin and concrete and knowledgeable of the design and construction codes and other criteria used in the construction codes and other criteria used inthe design and construction of the concrete containment design and construction of the concrete containment structure. The Respojnsible Engineer may also structure. The Responsible Engineer may also perform Inspections as discussed inthis section. perform Inspections as discussed inthis section. Certification procedures and certifications are Certification procedures and certifications are approved by Nuclear Generation Department approved by Nuclear Generation Department personnel responsible for these processes. These personnel responsible for these processes. These procedures comply with the requirements of applicable procedures comply with the requirements of applicable codes and standards. codes and standards.
Column I Column 2 Column 3 Row Duke Topical Report Amendment 32 Duke Topical Report Amendment 33 Description, Reason, and Basis for the (current) (proposed) Proposed Changes 5 The current paragraph has been revised In two areas. The inspection criteria for performing First: Inspections are established from codes,
Description:
In the proposed topical, the sentence specifications, and standards applicable to beginning 'The inspection aiteuia for performing the activity. Examples of activities subject to inspections..." is reformatted Information that was Inspection Include: found in the first paragraph of Section 17.3.2.12of the a) Activities specified by the ASME Code current topical (see Row 2 of this table). Section Xl Reason: This change is made for clarification. b) Special processes Basis: These changes are consistent with the c) Modifications requirements of N18.7 Section 5.2.7 and Section d) Maintenance 5.2.17 and 10CFR50 Appendix B Criterion X. e) Material Receipt Modifications, repairs and replacements are inspected Inspection requirements for maintenance or Second: in accordance with the original design and inspection modifications are equivalent to the original requirements, or acceptable altematives.
Description:
In the current topical, the sentence design and Inspection requirements, or beginning "Modifications, repairs and replacements acceptable alternatives. are inspected..." has been changed. Reason: The sentence In the current topical Is more restrictive than inspection requirements found in ANSI N18.7 and IOCFR50 Appendix B and could be interpreted to require original design and inspection requirements for every maintenance activity. In addition, the phrase "repairs and replacements Is changed to 'maintenance and the phrase in accordance with' is changed to 'equivalent to". Basis: These changes are consistent with the requirements of N18.7 Section 5.2.7 and Section 5.2.17. No comparable wording is found In 10CFR50 Appendix B. 6 Mandatory inspection hoEdpoints are included in the Mandatory Inspection hold points are Included in the No changes have been made. documents addressing the acfl*Hes being perforned, documents addressing the activities being performed, as necessary, and work does not proebed beyond as necessary, and work does not proceed beyond such hold points until satisfactory completion of the such hold points until satisfactory completion of the required Inspection, disposition of any item not required inspection, disposition of any Item not meeting the acceptance criteria, and any required meeting the acceptance criteria, and any required reinspection. reinspection.
Column I Column 2 Column 3 Row Duke Topical Report Amendment 32 Duke Topical Report Amendment 33 Description, Reason, and Basis for the (current) (proposed) Proposed Changes 7 Inspection procedures, instructions, and checkdists
Description:
In the current topical, the sentence contain the following information or require this beginning Inspection procedures, instructlons...' has Information on inspection reports: been moved to an earlier paragraph in proposed a) Characteristics to be Inspected topical (see Row 3 of this table). b) Method of inspection c) Measuring and test equipment Information Reason: This move is made for darfication. d) Responsibility for the inspection Basis: No technical changes have been made. e) Acceptance or rejection criteria f) Identification of required procedures, drawings, specifications, etc... g) Signature or Initials of inspector h) Record of results of the inspection. 8 After Inspection data is collected and reviewed by the After Inspection data is collected and reviewed by the No changes have been made. inspector, the reports are technically reviewed by inspector, the reports are technically reviewed by personnel designated to perform that quality personnel designated to perform that quality assurance assurance function. function. 9 Inspection acvities Involving the supplier quality Inspection activftes involving the supplier quality No changes have been made. assurance program are evaluated and approved by assurance program are evaluated and approved by the the Nuclear General Office, Procurement Quality Nuclear General Office, Procurement Quality section. section.
Attachment 2 DUKE ENERGY CORPORATION TOPICAL REPORT QUALITY ASSURANCE PROGRAM DUKE-1-A
Standard, Requirement or Guide Conformance Status Remarks Regulatory Guide 1.36 Rev. (0) - Nonmetallic Thermal Adopted Regulatory Guide is adopted for all Austenitic Stainless Steel Insulation for Austenitic Stainless Steel piping and components located outside containment Inside containment, reflective Thermal insulation is used. RegulatoryGuide l.37Rev(0)-QualityAssurance Conforms RG 1.37Rev(O)incorporatesANSIN45.2.1-1973 forboth Requirements for Cleaning of Fluid Systems and Associated construction and operation Components of Water-Cooled Nuclear Power Plants Regulatory Guide 138 Rev (2)- Quality Assurance Alternative RG 1.38 Rev (2)incorporates ANSI N45.22-1972. Duke's Reqirements for Packaging, Shipping, Receiving, Storage program conforms to ANSI N45.2.2-1972 except container and Handling of Items for Water-Cooled Nuclear Power muarlcngs shall be marked on at least one side (A.3.9(l)) and Plants shall be applied with waterproof ink or paint in characters of a legible size, and caps and plugs for pipe and fittings are required unless specified by Engineering, and off-site inspection, examination, and testing is monitored by personnel qualified to ANSI N45.2.12 in lieu of ANSI N45.2.6. Regulatory Guide 1.39 Rev (2) - Housekeeping Conforms RG 1.39 Rev (2) incorporated ANSI N45.2.3-1973 for both Requirements for Water-Cooled Nuclear Power Plants construction and operation Regulatory Guide L.S4 Rev (0) - Quality Assurance Alternative Catawba has adopted the Regulatory Guide. McGuire and Requirements for Protective Coatings Applied to Water- Oconee adopt portions of the Regulatory Guide and address Cooled Nuclear Power Plants alternatives which meet the intent of this Guide, in each respective Station FSAR. Regulatory Guide 1.58 Rev (1)- Qualification of Nuclear Alternative RG 1.58 Rev (1) incorporates ANSI N45.2.6-1978 for both Power Plant Inspection, Exainmation and Testing Personnel construction and operation. Duke's nondestructive examination personnel will meet the qualification requirements of SNT-TC-IA-1980 and ANSVISNT-CP-189. Duke's operational/functional testing personnel will meet the requirements of ANSI N18.1-1971 rather than ANSI N45.2.6. Also, Dke's Level I inspectors receive a minimum of 4 months experience as Level I before being certified as Level ILin lieu of one year experience reconmmended by ANSI N45.2.6. Inspectors are only assigned tasks for which they have been qualified. Amendment 33 17-5
17.32.11 Special Process Control The Nuclear Station Manager is responsible for directing the organization and performance of the station's program for the control of special processes, and for assuring the necessary qualified personnel are available. Nuclear Generation is responsible for furnishing qualified personnel, performance of and documentation of Non Destructive Examination (NDE). The operational quality assurance program contains or references procedures for the control of special processes such as welding, heat treating, non-destructive examination, coatings, crimping, and cleaning. The program requires that approved, written procedures, qualified in accordance with applicable codes and standards, be utilized when the performance of such processes affects the proper functioning of a station's QA Condition I structures, systems, and components. These procedures shall provide for documented evidence of acceptable accomplishment of special processes using qualified procedures, equipment, and personnel. Personnel performing such activities must be qualified in accordance with applicable codes and standards. Adequate documentation of personnel qualifications is required prior to performance of the applicable special process. Non-destructive examination personnel are certified to required codes and standards. 17.32.12 Inspection In order to assure safe and reliable operation, a program of inspections for QA Condition I structures, systems, and components is established at each nuclear station. Inspection procedures for those activities affecting QA Condition I structures, systems and components are established by Nuclear Generation persoanel. Independent inspections, examinations, measurements, observations, or tests of materials, products or activities are conducted, where necessary, to assure quality. If inspection of processed material or products is imnpossible or disadvantageous, indirect control by monitoring processing methods, equipment, and personnel is provided. Both inspection and process monitoring are provided when control is inadequate without both. Inspection procedures, instructions, and checklists contain the following information or require this information on inspection reports: a) Characteristics to be inspected b) Method of inspection c) Measuring and test equipment information d) Responsibility for the inspection e) Acceptance or rejection criteria f) Identification of required procedures, drawings, specifications, etc. g) Signature or initials of inspector h) Record of results of the inspection The personnel performing these inspections are examined and certified in their particular category. Current qualification and certification files are maintained for each inspector. Nondestructive examination inspectors are certified in accordance with ANSI/American Society for Non-destructive 17-30 Amendment 33
Testing (SNT-TC-IA, ANSV'SNT-CP-189) recommended practice. Written procedures require the test and certification of inspectors in other categories such as Mechanical, Electrical, and Structural as described in the appropriate quality assurance manual. For cases where inspectors will perform limited functions within a category, they are tested and certified to those limitations. These inspectors are only allowed to perform inspections specifically defined in this limited certification. For inspections of concrete containments, personnel fulfilling the role of Responsible Engineer, shall be a Registered Professional Engineer experienced in evaluating the in-service condition of structural concrete and knowledgeable of the design and construction codes and other criteria used in the design and construction of the concrete containment sucture. The Responsible Engineer may also perform inspections as discussed in this section. Certification procedures and certifications are approved by Nuclear Generation Department personnel responsible for these processes. These procedures comply with the requirements of applicable codes and standards. The inspection criteria for performing inspections are established from codes, specifications, and standards applicable to the activity. Examples of activities subject to inspection include: a) Activities specified by the ASME Code Section XI b) Special processes c) Modifications d) Maintenance e) Material Receipt Inspection requirements for maintenance or modifications are equivalent to the original design and inspection requircments, or acceptable alternatives. Mandatory inspection hold points are included in the documents addressing the activities being performed, as necessary, and work does not proceed beyond such hold points until satisfactory completion of the required inspection, disposition of any item not meeting the acceptance criteria, and any required reinspection. After inspection data is collected and reviewed by the inspector, the reports are technically reviewed by personnel designated to perform that quality assurance function. Inspection activities involving the supplier quality assurance program are evaluated and approved by the Nuclear General Office, Procurement Quality section. 17.3.2.13 Corrective Action Station personnel are responsible for the implementation of the quality assurance program as it pertains to the performance of their activities. Specific to this responsibility is the requirement for informing the responsible supervisory personnel and/or for taking appropriate corrective action whenever any deficiency in the implementation of the requirements of the program is determined. Procedures require that conditions adverse to quality be corrected. In the case of significant conditions adverse to quality, the procedures assure that the cause of the condition is determined and action be taken to preclude repetition. Performance and verification personnel are to: a) Identify conditions that are adverse to quality. b) Suggest, recommend, or provide solutions to the problems as appropriate. c) Verify resolution of the issue. Amendment 33 17-31
17.3.2.11 Special Process Control The Nuclear Station Manager is responsible for directing the organization and performance of the station's program for the control of special processes, and for assuring the necessary qualified personnel are available. Nuclear Generation is responsible for furnishing qualified personnel, performance of and documentation of Non Destructive Examination (NDE). The operational quality assurance program contains or references procedures for the control of special processes such as welding, heat treating, non-destructive examination, coatings, crimping, and cleaning. The program requires that approved, written procedures, qualified in accordance with applicable codes and standards, be utilized when the performance of such processes affects the proper functioning of a station's QA Condition 1 structures, systems, and components. These procedures shall provide for documented evidence of acceptable accomplishment of special processes using qualified procedures, equipment, and personnel. Personnel performing such activities must be qualified in accordance with applicable codes and standards. Adequate documentation of personnel qualifications is required prior to performance of the applicable special process. Non-destructive examination personnel are certified to required codes and standards. 17.3.2.12 Inspection In order to assure safe and reliable operation, a program of ins itons for QA Condition I structures, systems and components is established at each nuclear station. f inspection of processed material or products is impossible or disadvantageous, indirect control by monitoring processing methods, (/4Sel)t equipment, and personnel is provided. Both inspection and rocess monitoring are provided when control is inadequate without both. e program ad resses: 3 a) Inservice insp s required ection XI of the Ameri ociety of Mechanical ineer Bo l ssure Vessde / a >)_Sj/ b) Afetions to veri Hplance with cleanlip crteria. as er4H c) Inspections t fy compliance wih n instrument and mainte ncprocedues.- d) Inspecti s to verify conforma f materials, parts, and com nts received at a nuclear stati with applicable s ations and requirements. le) Inspections to verif eintegrity of QA Condition I ctures, systems and components dun and/or after main enance and modification. The personnel performing these inspections are examined and certified in their particular category. Current qualification and certification files are maintained for each inspector. Nondestructive examination inspectors are certified in accordance with ANSI/American Society for Non-destructive Testing (SNT-TC-IA. ANSIISNT-CP-189) recommended practice. Written procedures require the test and certification of inspectors in other categories such as Mechanical, Electrical. and Structural as described in the appropriate quality assurance manual. For cases where inspectors will perform limited functions within a category. they are tested and certified to those limitations. These inspectors are only allowed to perform inspections specifically defined in this limited certification. For inspections of concrete containments. personnel fulfilling the role of Responsible Engineer. shall be a Registered Professional Engineer experienced in evaluating the in-service condition of structural concrete and knowledgeable of the design and construction codes and other criteria used in the design 17-30 Amendment/, 33
//.,eS-ow iipYie mev; z's A'e vn 47//a V . or' and constructi n of the concrete containment structure. The Responsible Engineer may also perform
- inspections s discussed in this section.
Certifica on procedures and certifications are approved by Nuclear Generation Department personnel respo ble for these processes. These procedures comply wih _of applicable codes and / ',,, stan eards. H godification anre nIa tsyl a witthe original design and inspection reqirements, or acceptable alternatives. Mandatory inspection hold points are included in the documents addressing the activities being performed, as necessary, and work does not proceed beyond such hold points until satisfactory completion of the required insection, disposition of any item not meeting the acceptanc crit~era 'an ayrqired rins etio in~spec~ton proeur~esistructions, and cheklsts contain the following information or require this information on inspection reports: a) Characteristics to be inspected. b) Method of inspection. l'?Cocal ai5 c) Measuring and test equipment information 1J5er7t : Jt d) Responsibility for the inspection. e) Acceptance or rejection criteria. f) Identification of required procedures, drawings, specifications, etc. g) Signature or initials of inspector. lh) Record of results of the inspection. After inspection data is collected and reviewed by the inspector, the reports are technically reviewed by personnel designated to perform that quality assurance function. Inspection activities involving the supplier quality assurance program are evaluated and approved by the Nuclear General Office, Procurement Quality section. 17.3.2.13 Corrective Action Station personnel are responsible for the implementation of the quality assurance program as it pertains to the performance of their activities. Specific to this responsibility is the requirement for informing the responsible supervisory personnel and/or for taking appropriate corrective action whenever any deficiency in the implementation of the requirements of the program is determined. Procedures require that conditions adverse to quality be corrected. In the case of significant conditions adverse to quality, the procedures assure that the cause of the condition is determined and action be taken to preclude repetition. Performance and verification personnel are to: a) Identify conditions that are adverse to quality. b) Suggest. recommend. or provide solutions to the problems as appropriate. c) Verify resolution of the issue. Additionally. performance and verification personnel are to ensure that reworked. repaired. and replacement items are to be inspected and tested in accordance with the original inspection and lest requirements or specified alternatives. Amendment/ 17-31
.33
Insert # 1 Inspection procedures for those activities affecting QA Condition 1 structures, systems and components are established by Nuclear Generation personnel. Independent inspections, examinations, measurements, observations, or tests of materials, products or activities are conducted, where necessary, to assure quality. Insert # 2 The inspection criteria for performing inspections are established from codes, specifications, and standards applicable to the activity. Examples of activities subject to Inspection Include: a) Activities specified by the ASME Code Section Xl b) Special processes c) Modifications d) Maintenance e) Material Receipt}}