ML17311A792

Descriptions & Justification for Proposed Changes to PVNGS QA Program Description.

ML17311A792
Person / Time
Site:	Palo Verde
Issue date:	04/10/1995
From:	ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:
Shared Package
ML17311A791	List: ML17311A790 ML17311A792
References
NUDOCS 9504140155
Download: ML17311A792 (9)

Text

DESCRIPTIONS AND JUSTIFICATION FOR PROPOSED CHANGES TO THE PVNGS QUALITYASSURANCE PROGRAM DESCRIPTION PROPOSED CHANGE

'PS proposes to change UFSAR Section 17.2.4.2.1.7 from:

"Quality-related work authorizing documents shall be reviewed by the Quality Assurance organization to determine the need for and annotation of independent inspection to be performed by the Quality Control Department."

to:

"Selected quality-related work authorizing documents shall be reviewed by the Nuclear Assurance organization to determine the need for and annotation of additional attributes requiring independent inspection."

REASON(S) FOR THE CHANGE The reason for changing wording to "selected quality-related work" is to clarify this statement to reflect the program as defined in Section 17.2.4.3.1.3 which states in part

"...Documents that define programs or establish administrative controls...shall be reviewed and concurred with by the QA organization prior to implementation. Review of lower tier procedures and other documents shall be. performed on a graded approach...or on a sample basis." Making this change will remove conflicting wording between Sections 17.2.4.2.1.7 and 17.2.4.3.1.3 and allow Nuclear Assurance to implement a graded/sample basis approach when reviewing work control documents.

BASIS FOR CONCLUSION THAT THE REVISED PROGRAM CONTINUES TO SATISFY THE CRITERIA OF 10 CFR 50 APPENDIX B AND THE PREVIOUSLY ACCEPTED QUALITYASSURANCE PROGRAM COMMITMENTS The following is the basis for concluding that the revised program, incorporating the changes as described, continues to satisfy the criteria of 10 CFR 50 Appendix B and quality assurance program description commitments previously accepted by the NRC.

-Page 1 of 3 9504140155 950410 PDR ADOCK 05000528 P .

PDR

~ I~

P

A A comprehensive Quality Verification Program has been established at PVNGS and implemented to provide verification that Quality Plan requirements are implemented.

Although a clarification in wording has been made. within Section 17.2.4;2.1.7, the following requirements of the FSAR remain unchanged. Included is an explanation of how the implementation of these requirements will be conducted in the future.

17.2.4.2.1 - Requirements 17.2.4.2.1.2 The Engineering organization is responsible for the identification of attributes that require independent inspection. The Nuclear Assurance organization may elect to identify additional attributes requiring independent inspection based on quality history, .

trending, and quality engineering reviews that indicate the need for increased independent inspection.

Explanation: Currently Nuclear Assurance reviews qualify relafed correcfive maintenance work aufhorization documents to insert requiredinspection holdpoints (identified by other organizations) into work documenfs and to identify additional independentinspection as sfatedin 17.2.4.2.1.2 above. Nuclear Assurance resources have been used fo support acfivities fhat are more appropriately conducfed by organizations that perform work plan developmenf. As the responsibility forinserfion of inspection poinfsis fumed over to the organizafionsinitiating fhe work documents, Nuclear Assurance'will monitor fhe fransifion to assure compliance with regulatory and code requirements

'7.2.4.2.1.7- Independent Inspections Independent inspection is performed on activities in which a high degree of independence is desired to assure correct performance was accomplished or when required by code, standard, or regulatory commitment.

Independent inspection is performed by ANSI N45.2.6 certified inspectors, by individuals in organizations authorized by the Nuclear Assurance organization to perform those activities and who meet the requirements of ANSI N45.2.6, and by NDE personnel certified in accordance with ASNT Recommended Practice No. SNT-TC-1A.

Inspectors (including NDE personnel) shall be qualified in accordance with applicable codes, standards, and PVNGS training programs and their qualification and/or certification shall be maintained current and documented.

Page 2 of 3

4

~ ~ ~

~'

[Modifred stafement - Selected quality-related work authorizing documents shall be reviewed by the Nuclear Assurance organization to determine the need for and annotation of additional attributes requiring independent inspection.]

Explanation: Work authorizing documents are lower tier documents and may be reviewed using a graded approach as statedin Section 17.2.4.3.1.3 below. Nuclear Assurance willuse this gradedlsample basis approach as one of the means for monitoring successfulimplemenfation of Section 17.2.4.2.1.2.

When independent inspection hold points have been established, either contractually by procurement, or internally by plant procedures, work may not proceed beyond the hold point until either the inspection is performed satisfactorily or waived by Nuclear Assurance.

Explanation: Independent Inspections willconfinue to be performed as identified in the current program.

17.2.4.3.1.3- Document Reviews.

A program for reviewing documents that implement quality related activities shall be established to verify incorporation of the requirements of this Plan.

7 Documents that define programs or establish administrative controls (upper tier) shall be reviewed and concurred with by the Nuclear Assurance organization prior to implementation.

Reviews of lower tier procedures and other documents shall be performed on a graded approach as part of verification activities or on a sample basis.

Page 3 of 3

'I p

~ ~ ~

C ENCLOSURE 2 AFFECTED UFSAR PAGES FOR PROPOSED CHANGES TO THE PVNGS QUALITYASSURANCE PROGRAM DESCRIPTION

PVNGS UPDATED FSAR QUALITY ASSURANCE DURING

~ ~ ~,

I

'C THE OPERATIONS PHASE 17.2.4.2.1.7 Inde endent Ins ections Independent inspection is performed on activities in which a high degree of independence is desired to assure correct performance was accomplished or when required by code, standard, or regulatory commitment.

Independent inspection is performed by ANSI N45.2.6 certified inspectors, by individuals in organizations authorized by the Nuclear Assurance organization to perform those activities and who meet the requirements of ANSI N45.2.6, and by NDE personnel certified in accordance with ASNT Recommended Practice No. SNT-TC-1A.

Inspectors (including NDE personnel) shall be qualified in accordance. with applicable codes, standards, and PVNGS training their qualification and/or certification shall programs and aint Selected

'd current and documented.

be uality related work authorizing documents shall be reviewed by 7I the Nuclear Assurance organization to determine the need for and annotation of independent,,inspection.

7I additional attributes requiring 7I When independent inspection hold points have been es a z.shed, either contractually by procurement, or internally by plant procedures, work may not proceed beyond the hold point until either the inspection is performed satisfactorily or waived by Nuclear Assurance.

For modification and nonroutine maintenance, independent inspections shall be conducted in a manner similar (frequency, type, and personnel performing such inspection) to that associated with construction phase activities.

Where independent inspection is being performed on previously accepted lots, sampling inspection shall be representative and shall be applied only to the extent necessary to assure adequacy of control. The sampling plan shall be established by 7J the Nuclear Assurance organization. Inspection personnel shall March 1995 17. 2-76 Revision 7

i% ~

k I

I