ML17265A263

Rev 25 to QA Program.

ML17265A263
Person / Time
Site:	Ginna
Issue date:	05/05/1998
From:	ROCHESTER GAS & ELECTRIC CORP.
To:
Shared Package
ML17265A261	List: ML17265A260 ML17265A263
References
NUDOCS 9805130098
Download: ML17265A263 (5)

Text

NAY-85-1998 14: 12 RGLE G INNA PROCURENENT '716 771 3987 P. 83i87

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ATTACHMENT 1 S o sis of Chan es 0 aniz ion "C an eB The following organization changes were made and are reflected throughout the text of the document and on the Figure 17.1.2-1 Organization Chart:

a The Supply Chain Management (SCM) Section was eliminated and has resulted in the following changes:

~ Responsibility for procurement was transferred from Supply Chain Management to the Department Manager, Nuclear Engineering Services.

~ Responsibility for inventory control and storage of material and equipment was transferred from Supply Chain Management to the Plant Manager, Ginna Station.

~ Section 17.2.5, Procurement Verification, was revised.

~ Organization Chart was revised to eliminate the SCM organization.

These changes are reflected throughout the revised document and are not'dentified at each occurrence in the following summary.

17. 1 KQMEMENT

17. 3. 7 to Commitments The second and third paragraphs were added to allow for applying a grace period to activities defined by the QA Program which are oonduotsd on s psrioBic basis.

The current QAPSO allows for only a literal interpretation of the requirements for performing activities on a periodic basis such as, "annually", "every three years", "every 24 months" etc.

Therefore, for example, the performance of an annual supplier evaluation or lead auditor recertification must be performed by.

the same calendar date as it was performed in the previous year.

Therefore, the application of a grace period is being requested which will allow flexibility in scheduling activities. The 25~

tolerance was selected to be consistent with Technical Specification SR 3.0.2 grace period requirements.

The details of implementation of this grace period will be incorporated into the Nuclear Policy Manual. The Nuclear Policy Manual will identify the specific activities for which the grace period may be applied.

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l%Y-85-1998 14: 12 ATTACHMENT 1 S o sis 'of Chan es The grace period will not be applied to activities for which a interval of performance is indicated by a limiting 'aximum adjective or phrase such as, "within a period of two years", "not to exceed three years", "at least quarterly" etc.

Additionally, the grace period will not allow the "clock" for a particular activity to be reset forward. For example, annual activity is due on June 15, 1998, but is not performed if an until August 13, 1998, the next due date for that activity will be June 15, 1999. However, the clock for an activity is reset backwards by performing the activity early.

Since the clock for an activity can not be reset forward, the average frequency at which an activity is performed will remain the same. Therefore, this QA Program change continues to satisfy the criteria of 10CFR50.Appendix B.

The following additional information was requested. by the NRC in Reference b:

A. Clarify which ecific per'iodic activities described in

~s QAPSO, Revision 24, Table 17.1.7-1, will be applied the +25%

"grace period~'or deferral.

RGB intends to apply the grace period to the following periodic activities initially:

Annual Supplier Evaluations (RG 1.144 Rev. 0 Sect.

C.3.b.2) '

Triennial Vendor Audits (RG 1.144 Rev. 0 Sect.

C.3.b.(2))

~ ANSI N45.2.23 Recertifications (Sections 3.2 and 5.3)

~ ANSI N45.2.6 Annual Evaluations (Section 2.3)

Examples of activities for which the grace period can not be applied are as follows:

~ Internal QA Audits listed on Table 17.3.2-1. Since ANSI N18.7-1972 Section 4.4 states that audits of safety related activities be completed "within a period of two years", the use of a grace period would allow for violation of this standard.

MRY-85-1998 14: 12 I RG8E GlNNA PROCVREMENT ATTACHMENT 1 716 771 3987 P.85i87 S o sis o Ch es

~ ANSI N45.2.6 Three Year Recertifications. Since ANSI N45.2.6-1978 Section 2.3 states that pexsonnel shall be reevaluated at periodic intervale "not to exceed three years", the use of a grace period would allow for violation of this standard.

ANSI N45.2.6 Physical Examinations. Since ANSI N45.2.6-1978 Section 2.5 states that special physical characteristics shall be vexified "at intervals not to exceed one year", the use of a grace period would allow for violation of this standard. * ~ 1 \ j ~

Nucleax Safety Audit and Review Board meeting frequency. Since ANSI N18.7-1976/ANS-3.2 Section 4.3.2.2 states that the meeting frequency shall not be "less than twice a year". The use of a grace period in this case would allow for violation of the standaxd.

~ Plant Operations Review Committee meeting frequency.

Since ANSI/ANS 3.2-1988 Section 4.3.4 states that meetings shall be held "at least quarterly". The use of a grace period in this case would allow for violation of the standard.

The list of activities for which the grace period is applicable wil3, be contained in a Nuclear Directive. This Nuclear Directive will also describe the rules for use of the grace period. Changes to this Nuclear Directive will be reviewed in accordance with 10CFR50.54(a) prior to implementation.

B. Describe the impact of such deferral on your audit activities and corresponding commitments to Regulatory Guide (RG) 1.33, Rev. 2 and RG 1.144, Rev. 1.

RG 1.33 R v 2 - RG&E conforms to Regulatory Guide 1.33 Rev.(2) Regulatory Positions 1 (including its Appendix A) and 3 (which invokes'nd modifies ANSI N18.7-1976/ANS-3.2 Section 4.3.4) and conforms to ANSI N18.7-1976/ANS-3.2 Section 4.3.1, 4.3.2 and 4.3.4 (as modified) for the off-site review function, excluding staffing. Ginna conforms to ANSI/ANS 3.2-1988 Section 4.3 for the requirements of the on-site review function.'

t NAY-85-1998 14: 12 RG&E GINNA PROCUREMENT 716 771 3987 P.86i87

~)c+T ATTACHMENT 1 S o sis of Chan s Based on these commitments, the impact of -applying the grace-period is as follows:

RG 1.33 Regulatory Positions 1 and 3 - No periodic activities are described.

2. ANSI N18.7-1976/ANS-3.2 Section 4.3.4 - No periodic activities are described..

3. ANSI N18.7-1976/ANS-3.2 Section 4.3.1 - No periodic activities are described. 8 4 ANSI N18.7-1976/ANS-3.2 Section 4.3.2 - The grace period will not be applied to the meeting frequency of the Nuclear Safety Audit and Review Board, since Section 4.3.2.2 of the standard states that the meeting frequency shall not be "less than twice a year". The use of a grace period in this case would allow for violation of the standard.

5. ANSI/ANS 3.2-1988 Section 4.3 - The gxace period will not be applied to the meeting frequency of the Plant Operations Review Committee, since Section 4.3.4 of the standard states that meetings 'shall be held. "at least quarterly". The use of a grace period in this case would allow for violation of the standard.

RG 1.144 Rev 1 - RG&E conforms to this regulatory guide.

The following periodic activities are affected as follows:

Internal Audits - Section C.3.a.(1) of RG 1.144 refers to RG 1.33 for requirements. Since RG&E is committed to RG 1.33, Rev. 0 except for Appendix A, ANSI N18.7-1972 requirements are invoked. The grace period will not be applied to the 24 month frequency for internal audits, since Section 4.4 of ANSI N18.7-1972 states that audits of safety related activities are completed "within a period of two years". The use of a grace period in this case would allow for violation of the standard.

2. Supplier Audits - Section C.3.b.(2) states that audits be performed on a "triennial basis". The grace period may be applied to this activity, but would be restricted to 90 days in accordance with QAPSO Section 17.1.7. Section 17.2.5 of the QAPSO is being revised to allow for application of the grace peri'od.

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NAY-85-1998 14: 13 RGB GINNA PROCUREMENT 716 771 3987 P.87i87

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ATTACHMENT 1 S o sis of Ch n es

3. Supplier Evaluations - Section C.3.b.(2) states that documented evaluations be performed "annually". The grace period may be applied to this activity.

No other periodic activities are described in RG 1.144, Rev.

l.

This change is considered a reduction in commitment and will not be implemented until NRC approval is received.

.2.5 Procurement Verification Revised requirement to perform vendor audits from "at least every three years" to "on a triennial basis" to be consistent with the wording used in RG 1.144, Rev 1, Section C.3.b.(2) .

The revised program, as described above, continues to satisfy the 10CFR50 criteria and does not reduce the scope of the Quality Assurance Program.

TOTAL P.87