ML17292B476

Provides Supplemental Info & Clarification of Proposed Rev 29 to Operational QA Program Description Submitted in 981023 Ltr

ML17292B476
Person / Time
Site:	Columbia
Issue date:	12/09/1998
From:	Coleman D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GO2-98-207, NUDOCS 9812170171
Download: ML17292B476 (8)

Text

CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9812170171 DOC.DATE: 98/12/09 NOTARIZED: NO DOCKET FACIL:50-397. WPPSS Nuclear Project, Unit 2, Washington Public Powe 05000397 AUTH.NAME e AUTHOR AFFILIATION COLEMAN,D.W. Washington Public Power Supply System RECIP.NAME RECIPIENT AFFILIATION Records Management Branch (Document Control Desk)

SUBJECT:

Provides supplemental info S clarification of proposed Rev 29 to operational QA program description.

DISTRIBUTION CODE: Q004D COPIES RECEIVED':LTR J ENCL i SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket/Utile NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL POSLUSNY,C 1 1 INTERNAL: ACRS 1 1 1 E CENTER 0 1 1 NRR/DIS /PIMB 1 1 C 1 1 NUDOCS-ABSTRACT 1 1 OC/LFDCB 1 1 RGN4 FILE 1 1 EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 D

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NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPZES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 12

WASHINGTON PUBLIC POWER SUPPLY SYSTEM P.O. Box 968 ~ Richland, Washington 99352-0968 December 9, 1998 G02-98-207 Docket No. 50-397 U.S. Nuclear Regulatory Commission Attn; Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

WNP-2 OPERATING LICENSE NPF-21 PROPOSED REVISION 29 TO THE OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004)-

SUPPLEMENTAL INFORMATION

Reference:

Letter G02-98-181, dated October 23, 1998, DW Coleman (SS) to the NRC, "Revision 28 and Proposed Revision 29 to the Operational Quality Assurance Program Description (OQAPD) (WPPSS-QA-004)"

The purpose of this letter is to provide supplemental information and clarification of the proposed Revision 29 to the OQAPD submitted in the reference letter. As a result of between NRR staff and the Supply System on November 19 and 23, 1998, Section 'iscussions 15.2.4 and Appendix II.12.4 were revised. Also, as you requested, additional information describing the changes made to Section 4.2.6 and Appendix III.2.1.1 is included in to this letter. The changes made to Section 15.2.4 and Appendix II.12.4 are provided as Attachment 2 and should replace respective pages provided in the original submittal dated October'23, 1998.

It is our understanding that you have no further questions concerning Revision 29 to the OQAPD. Accordingly, WNP-2 will be implementing Revision 29 as submitted on October 23, 1998 and modified by this letter, as allowed by 10 CFR 50.54(a)(3).

'PSi2i70i7i 98i209 PDR ADQCK 05000397 P PDR gp

PROPOSED REVISION 29 TO THE OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004) - SUPPLEMENTAL INFORMATION Page 2 Should you have any questions or desire additional information regarding this matter, please call me or DK Atkinson at (509) 377-4302.

Respectfully, DW Coleman Manager, Regulatory Affairs Mail Drop PE20 Attachments cc: EW Merschoff - NRC RIV GA Pick - NRC RIV C Poslusny, Jr. - NRR NRC Sr. Resident Inspector - 927N DL Williams - BPA/1399 PD Robinson - Winston Ec Strawn

OPERATIONAL QUALITYASSURANCE PROGRAM DESCRIPTION PROPOSED REVISION 29 - ADDITIONALINFORMATION Section 4 - Procurement Document Control Section 4.2.6 was revised to clarify how Quality Department personnel review procurement documents. The responsibilities of Quality personnel as related to Procurement Document Control are stated in Section 1.3.3.1.3. The review of procurement documents by Quality Department personnel will be on a sampling basis (not a 100% review). This change removes the Quality Department from in-line review so as to maintain independence. Procurement documents will-continue to be reviewed by independent Procurement personnel to assure quality requirements are correctly stated, that products or services be inspected and controlled, and that the vendor is on the current Supply System Evaluated Supplier List. Procurement personnel are trained for this review as stated in Section 2.2.5. Procurement personnel, through the use of the Corrective Action Program, have an avenue to report problems to the Manager, Quality.

Section 15 - Nonconforming Materials, Parts, or Components Section 15.2.4 was revised to clarify that Quality Department personnel review nonconformances on a sampling basis (not a 100% review). The purpose to this change is to remove Quality from in-line review so as to maintain independence. An additional clarification was added to state, "The organization responsible for the Corrective Action Program reviews nonconformance reports to assure dispositions have been evaluated and approved."

Appendix II - Position Statements Appendix II.12.4 was added to clarify how "Inprocess" Quality Assurance records may be maintained in temporary storage until transferred to the permanent plant file.

Appendix III - Additional Quality Program Requirements Appendix III.2.1.1, was revised to eliminate the Planning/Scheduling/Outage (PSO) representation on the Plant Operations Committee (POC). This position (PSO Manager) has been combined into the Maintenance Organization by a recent reorganization, This change is consistent with the WNP-2 Technical Specification Section 6.5.1.2 (prior to relocation of POC requirements from Technical Specifications to the OQAPD).

PAGE 4Q sUppLY SYSTEM 15-2 OPERATIONAL QUALITYASSURANCE PROGRAM DESCRIPTION 10 15.2.4 Nonconforming items shall be reviewed and accepted for use-as-is, rejected, repaired, or reworked in accordance with documented procedures/instructions. The Supply System Quality organization shall review nonconformances on a sampling basis, during audits or surveillances or other reviews to assure that dispositions have been evaluated and approved. The organization responsible for the Corrective Action Program reviews nonconformance reports to assure dispositions have been evaluated and approved.

15.2.5 Acceptability of repaired, reworked and replaced item shall be verified and documented by inspecting and/or testing the item in accordance with original inspection and/or test requirements or approved alternatives.

15.2.6 Where feasible, nonconforming items shall be segregated from other acceptable items and/or uniquely identified as nonconforming until properly dispositioned for use.

15.2.7 Reports of nonconformances shall be periodically analyzed by the Supply System Quality organization to identify quality trends. Significant results shall be referred to appropriate management for review and assessment.

968-25060 (4/92) SectinlS.P&A/OQAPDI

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PAGE WASHlNCCOM tllILICFOWRR 4N SUPPLY SYSTEM II-13 OPERATIONAL REV.

QUALITYASSU1U&lCE PROGIUJAI DESCRIPTION 14

4. Section 5.2 of ANSI N45.2.9 - 1974 is revised by adding a new second paragraph as follows; In process Quality Assurance records may be maintained in temporary storage with the originating organization until transfer to the permanent plant file.

Written storage procedures shall be prepared and a custodian designated with the responsibility to enforce the procedures. Storage procedures shall, at a minimum, address the following:

a. Identification of the records that may be maintained in temporary storage, the type of storage (single or dual) and the record storage location.

b. Use of lockable temporary storage containers with a minimum one hour fire rating and an Underwriters'aboratory (UL) label (or equivalent),

If the container does not have a fire rating label, the container should be certified by an individual competent in the field of fire protection.

C. Use of "out" cards or other similar methods to track records removed from the file, Designation of a custodian with the authority to enforce the storage procedures.

e. Provisions shall be made in the storage arrangement to prevent damage from condensation.

Records shall not be stored loosely. Records shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel file cabinets are preferred.

g. Provisions shall be made for special processed records (such as radiographs, photographs, negatives, and microfilm) to prevent damage from excessive light, stacking, electromagnetic fields, and temperature.

These provisions shall be delineated in procedures and/or instructions which will incorporate, or take into consideration, available manufacturers'ecommendations.

968-25060 (4/92) OQAPDAPP.WWAOQAPD

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