ML17292B491
| ML17292B491 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 12/21/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML17292B490 | List: |
| References | |
| NUDOCS 9812300029 | |
| Download: ML17292B491 (6) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 2055$ 4001 SAFETY EVALUATIONBYTHE OFFICE OF NUCLEAR REACTOR REGULATION UALITYASSURANCE PROGRAM CHANGE - REVISION 29 WASHINGTON PUBLIC POWER SUPPLY SYSTEM WNP-2 DOCKET NO. 50-397
1.0 INTRODUCTION
By letter dated October 23, 1998, Washington Public Power Supply System (WPPSS) submitted proposed Revision 29 to the Operational Quality Assurance Program Description (OQAPD) in accordance with 10 CFR 50.54(a).
Revision 29 identified reductions in commitment in the areas of Procurement Document Control; Document Control; Nonconforming Materials, Parts, or Components, and Planning/Scheduling/Outage representation on the Plant Operations Committee (POC). Conference calls between NRC and WPPSS staffs were held on November 19, 1998, and November 23, 1998, to discuss these changes.
By letter dated December 9, 1998, WPPSS submitted supplementary information and revised OQAPD pages to address NRC staff questions.
2.0 EVALUATION.
2.1 Section 4 - Procurement Document Control Changes Section 4.2.6 was revised to clarify how Quality personnel review procurement documents.
Procurement documents shall be reviewed by independent Procurement personnel to assure quality requirements are correctly stated, that they can be inspected and controlled, and that the vendor is on the current Supply System Evaluated Supplier List. Quality personnel shall review procurement documents on a sampling basis, either during visits to vendors'acilities, or during audits/surveillances, or at receiving inspections.
Standard Review Plan (SRP) Section 17.1, Acceptance Criteria 4A1, states that review of the adequacy of quality requirements stated in procurement documents should be performed by independent personnel trained and qualified in QA practices and concepts, and acceptance criteria 4B1 states that the involvement of the QA organization should be described.
OQAPD Section 4.2.6 clearly indicates that the review shall be conducted by independent personnel.
The qualification to perform this function is assured by OQAPD Section 2.2.5 which requires that the managers of Supply System organizations responsible for implementing the applicable provision of the QA Program shall assure that all activities are performed by personnel who have been indoctrinated and trained. The involvement of the QA organization in reviewing procurement documents on a sampling basis is also described in OQAPD Section 4.2.6.
In addition, the involvement of QA management is included in the description of the positions 98i2300029 98i22i PDR nDOCV OSOOoa97 P
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% I Manager-Quality, Supervisors-Quality Services, Supervisor-Quality Programs, and Lead-Supplier Quality. Furthermore, procurement personnel have an avenue to report problems to the Manager, Quality, through the Corrective Action Program.
The above describes arrangements for adequate independence, qualification and QA organization involvement. Therefore, the staff finds'this approach is acceptable, and that the requirements of 10 CFR Part 50, Appendix B willcontinue to be met.
2.2 Section 6 - Document Control Changes I
Currently, OQAPD Section 6.2.2.b requires that the Final Safety Analysis Reports (FSARs),
procurement documents, administrative procedures, and nonconformance reports be reviewed for inclusion of appropriate quality requirements and concurred with by qualified Quality
, Assurance personnel, prior to approval for release:
Revision 29 clarifies that Quality personnel review administrative procedures for this subsection.
Quality personnel review administrative procedures which address these and other areas to assure inclusion of appropriate quality requirements prior to implementation.
Review of procurement documents is covered in Section 4 of the OQAPD and review of nonconformance reports is covered in Section 15 of the OQAPD. Quality Assurance personnel willonly review the administrative procedures that control the FSAR, but not the FSAR itself, unless specified by the administrative control. This eliminates a drain on resources to review a large number of simple editorial changes to the FSAR or other changes which would not require a Quality personnel review, and changes that may have already received QA review through another function. For example, changes involving safety evaluations would receive a QA review by the participation of Quality personnel on the Plant Operations Committee.
Technical reviews of these types of documents by qualified individuals are still required by Section 6.2.2.a of the OQAPD, and as review for appropriate quality requirements are covered'by the administrative procedures reviewed under Section 6.2.2.b along with the specific requirements for procurement documents and nonconformance reports covered in Sections 4 and 15, respectively.
The staff finds this is an acceptable approach and that the requirements of 10 CFR Part 50, Appendix B willcontinue to, be met.
2.3 Nonconforming Materials, Parts, or Components Changes Section 15.2.4 was revised to clarify that Quality personnel review nonconformances on a sampling basis to assure that dispositions have been evaluated and approved.
In addition, the organization responsible for the corrective action program reviews nonconformance reports to assure dispositions have been evaluated and approved.
The qualifications to perform this function is assured by Section 2.2.5 of the OQAPD which requires that the managers of Supply System organizations responsible for implementing the applicable provision of the QA Program shall assure that all activities are, performed by personnel who have been indoctrinated and trained.
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'4 Section 17.1of the SRP, Acceptance Criteria 15.2, specifies that organizational responsibilities be described for the implementation of activities related to noncBRRPmdnce control. The staff finds that the above adequately describes these organizational r8fponsibilities and that the requirements of 10 CFR Part 50, Appendix B willcontinue'to be'lhdt.
2.4 Planning/Scheduling/Outage Representation On Plant OpdBBions Committee Appendix lll.2.1.1 was revised to eliminate the Planning/Schedulfhg/OLItage representation on the Plant Operations Committee (POC). This was done.becaCisd%
nning/Scheduling/Outage has been combinedinto Maintenance.
Appendixlll, Section%.1;1",
ow-describeseight functional areas that individuals on the POC may be experieHcBBR.aP5perations, Maintenance, Engineering, Quality, Administrative Service's, Radi ion%'rotection, Technical Services and Chemistry.
As Planning/Scheduling/Outage was combined into Maintenance, and since this is consistent with the positions described in the technical specifications before'Iey were previously relocated to the OQAPD, the staff finds this change acceptable.
2.5 Temporary Storage for In-Process Records Commitment to Section 5.2 of ANSI N45.2.9-1974 is,Revised by adding a second paragraph to address handling of "in-process" records until completefand traNRferred to the permanent plant file. The change'llows QA records to be maintained in temporal'storagehwith the originating organization until transfer to the permanent file, and also specifQQ riiinimum requirements for the storage procedures to address.
ANSI N45.2.9 - 1974 specifically states that this standarB is noFintended to cover the preparation of records, nor to include working documents not gbt designated as quality assurance records.
Therefore, the above clarification adds andddiffona1 leVel of control for documents not yet completed or transferred to the permanent'tant file. in addition, those storage and preservation requirements specified for the in-p'rocess documents are consistent with those used for permanent files. Therefore, the staff fin'dN6at thig;.change does not result in any reduction in commitment, and that the requirements"bf 10'CFR Part 50, Appendix B will continue to be met.
3.0 CONCLUSION
The staff has evaluated the above changes to the OQAPD as desgribHd Pi the licensee's submitta of October 23, 1998, as supplemented by letter dated-Decemb'e/9, 1998, and has determined that the proposed changes are acceptable and that tHd'r'efuirhNents of 10 CFR Part 50, Appendix B willcontinue to be met.
Principal Contributor: Ray Smith Date:
December 21, 1998
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