ML18005A940
| ML18005A940 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/06/1989 |
| From: | Loflin L CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-89-062, NLS-89-62, NUDOCS 8906140056 | |
| Download: ML18005A940 (11) | |
Text
'CCELEP<TED l>lSOUEIt'TION DEM04STPel04 SYPTEyi REGULATORY INFORMATION DISTRIBUTION SYSTEM (RXDS)
ACCESSION NBR:8906140056 DOC.DATE: 89/06/06 NOTARXZED: NO FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina AUTH.NAME AUTHOR AFFXLIATION LOFLIN,L.I.
Carolina Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATXON Document Control Branch (Document Control Desk)
SUBJECT:
Requests approval of encl proposed rev to fire protection QA program.
DISTRIBUTION CODE:
A006D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: OR/Licensing Submittal: Fire Protection NOTES:Application for permit renewal filed.
DOCKET I 05000400 05000400 g
RECIPIENT ID CODE/NAME PD2-1 LA BECKER,D INTERNAL: ACRS NRR/DEST/ADS 7E NRR/DEST/PSB 8D OC/LFMB EXTERNAL: LPDR NSIC COPIES LTTR ENCL 1
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1 RECXPIENT ID CODE/NAME PD2-1 PD NRR WERMEIL,J NRR/DEST/CEB NUDOCS-ABSTRACT OGC/HDS1 NRC PDR COPIES LTTR ENCL 5
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PLEASE HELP US IQ REDUCE 'RASTER CXNZACZ IHE DOCUMVG'XÃZROL DESK RDCN Pl-37 (EXZ. 20079)
-TO EX33~ATB YOUR NAME HKH DISTIKBVZIGN LISTS FOR DOCUMENZS YOU DON'T NEED.'OTAL NUMBER OF COPIES REQUIRED:
LTTR 22 ENCL 18
Carolina Power & Light Company JUN 0 6 I89 SERIAL:
NLS 062 10CFR50.54 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 QUALITY ASSURANCE PROGRAM CHANGES Gentlemen:
Carolina Power 6 Light Company (CP&L) hereby submits for NRC approval, a proposed revision to the Shearon Harris Nuclear Power Plant (SHNPP) Fire Protection Quality Assurance Program.
Due to the nature of the revision, NRC approval is being requested prior to implementation.
Attachment 2 to this letter provides a
description and justification for the proposed changes.
The proposed changes
- 1) modify the means by which the Fire Protection Specialist performs his functions and responsibilities by replacing his surveillance activities with supervisory review and approval activities,
- 2) clearly separates the Fire Protection Specialist's functions and responsibilities from QA functions by moving his accountabilities from Chapter 17 to Chapter 13, and 3) eliminate redundancy in performing. surveillance activities.
The revised program continues to provide assurance that the procedures governing fire protection activities are implemented.
Therefore, the SHNPP QA program continues to meet the applicable
- 10CFR50, Appendix B criteria.
This QA program change will not be implemented until accepted by the NRC pursuant to 10CFR50.54(a)(3)(iv).
This program revision, if accepted, will be incorporated into the FSAR as shown in the attached markup (Attachment 1).
Please refer any questions regarding this submittal to Mr. Steven Chaplin at (919) 546-6623.
Yours very truly, LIL/SDC Attachments Leo rd I. L flin Manager Nuclear Licensing Section cc:
Mr. R. A. Becker Mr. W. H. Bradford Mr. S.
D. Ebneter 411 Fayetteville Street o P. O. Box 1551 o Raleigh.
N. C. 27602 8906i40056 890606
("I PDR ADOCK 05000400 F
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SHNPP FSAR
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A7tnrHjvg<7 j Pa k~~ Ã 4<~
py. X 17.2.19 FIRE PROTECTION A PROGRAM The General Manager - Harris Plant Operations Section is responsible, unless otherwise designated in this section, for the overall administration of the fire protection program and provides control for contingencies'.
40 T
G e
l an er H ri Pl t
per tio s
S cti n ll ir t do me te ro a
of ua xt ass ra e f x'm de gn ed s
re ro ec 'on 'te The program will accomplish the followxng:
a)
Inspection of the installation, corrective maintenance, modifications, and receipt of designated fire protection items.
pggv c
b) e of compliance with governing procedures of the Fire Protection Program.
I 40 c)
Provision for adequate contxols for designated fire protection items to ensure the maintenance of an effective fire protection program.
40 The Fire Protection Senior Specialist is responsible for.')
Coordination of fire protection program activities.
b)
Preparation/review of procedures and instructions which implement the Fire Protection Program.
[~o l~o
)40 c)
Ensuring the development and technical adequacy of the training materials and training sources related to the fire protection program, and assigning qualified Fire Protection instructors.
d)
Deleted.
40 e)
Periodic monitoring of fire protection activities.
f)
Deleted l4'0 g)
Coordination of the arrangements for off-site fire company support and training.
h)
Scheduling and implementation of the Fire Drills Pxogram.
i)
Establishing the minimum equipment for the Fire Brigade Teams.
17.2.19-1 Amendment No. 40
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SIMP FSAR 17.2.19.1 Desi n-and Modification Control and Documentation Design changes and modifications including procurement and controL of modification purchased items to Eire protection items will be prepared,
- reviewed, approved, accomplished, and documented in accordance with the approved plant procedures for design changes and modifications.
17.2.19.2 h
Control of Purchased Materials E ui ment, and Services Control of plant purchased materials, equipment, and services with respect to fire protection items will be accomplished in accordance with the following specific guidelines Eor procurement, receiving, and storage.
17.2.19.2.1 Procurement a)
Purchase requisitions for Eire protection items will be completed in accordance with approved plant procedures for purchase requisitions using the procedures Eor non safety-related items.
b)
Purchase orders for fire protection items will be completed in accordance with approved Plant Operating Procedures for purchase orders using the procedures for non safety"related items.
17.2.19.2.2 Receiving 27 Fire protection items will be receipt inspected in accordance with approved procedures for receipt inspections noting in particular.')
Any damage to the item.
b)
Item identification and marking.
c)
Any required Vendor supplied documentation.
d)
Conformance with purchase requirements/specifications.
A Receipt Inspection Report will be completed for received fire protecti,on items.
Any noted nonconformities wiLL be documented in accordance with approved procedures for nonconformance.
Fire protection items will be tagged in accordance with approved procedures for tagging of received materials.
17.2.19.2.3 Storage Fire protection items will be stored in accordance with approved plant procedures Eor storage of materials.
17.2.19.3 Fire Protection S stem Ta outs Fire protection system tagouts will be accomplished in accordance with approved procedures.
17.2.19-2 Amendment No.
27
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SHNPP FSAR
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ATNr&<aT4 1o @IS.gg -gyp, pal'3 17.2.19.4 Ins ection Test and 0 eratin Status The requirements stated in Section 17.2.14 will apply.
17.2.19.S Deficiencies and Nonconformance Items Deficiencies and nonconformances of fire protection system items will be identified, reported, dispositioned, and corrected in accordance with Section 17.2.15 17.2.19.6 Corrective Action The requirements of Section 17.2.16 shall apply.
Procedures shall be established for evaluating conditions adverse to fire protection to determine the necessary corrective action.
In the case of significant or repetitive conditions adverse to fire protection, the cause of the conditions will be determined and ana1yzed, and prompt corrective action taken to preclude recurrence.
With respect to fire protection systems or features which protect nuclear safety-related
- systems, structures, or equipment, a documented, program of inspections will be implemented when repairs or modifications to those systems or features are performed, or if the quality of the activity can impair the ability of the system, equipment, component, or installation to accomplish its intended function.
(- aZC'ZtEJ 17.2.19.8 0
Su veill ce fao
~,<<gr..~~u rs~w SfC77WV 134 o.~ ~'3 Gene al Ma ager Harris lant 0 eration Sectio is res onsibl for plem ting doc ented ogram perio c surve'ance hich v rifies compl ance th g erning procedu es Eor e foll ing f e prot tion acti ities c's Qfs+M~16Xf Soc A~>RIP <O~~I~~
G I + PovE~INJ'PRocE/U<E$ f'R P+ ZQ~Pgv a)
Housekeeping FiNPaalEcfjgp b) tests of the fire protection systems PERIQI c c)
Control of ignition sources d)
Use of Eire watches e)
Control of combustibles f)
Fire protection training documentation
@. p<><f<~ 1+s~rs>6vhf~s error PpERag,"~j Oggaapz~fiii x FIRE'iZofEcgiuiu Spr~a4$ 7.
g event've mai tenanc progr This rogram will b conduc ed by he Fire Protec ion Spe ialist in acc rdanc with approv d proc duress 17.2.19-3 Amendment No. 40
SHNPP FSAR 17 ~ 2, 19 ~ 9 ualit Assux'ance Surveillance Surveillance fox compliance with this program will be accomplished by the Director QA/QC Harris Plant ~
17.2.19.10 Preventive Maintenance A preventive maintenance program for designated fire protection system items will be established and implemented per plant procedures.
17.2.19.11 Post"Maintenance and Post-Modification Testin Corrective maintenance which repairs or replaces parts or components which affect the function of designated fire protection items requires post-maintenance
- testing, except where such testing would be destructive.
s Each modification of designated fire protection items requires testing to demonstrate that design criteria and the function of the modification are met.
The specific post-maintenance and postmodif ication test requirements will be delineated in accordance with approved procedures for post-maintenance hand post-modification testing.
17.2.19.12 Test Contxol The requirements stated in Section 17.2.11 shall apply.
17.2.19.13 Audits Audits will be conducted in accordance with Section 17.2.18 except as listed in Technical Specifications.
40 17.2.19.14 ualit Assurance Records Quality Assurance records generated by implementation of this Fire Protection System Quality Assurance Program will be maintained in accordance with Section 17.2.17.
17.2 '9-4 Amendment No 40
Attachment 2 to NLS-89-062 Page 1
FIRE PROTECTION A PROGRAM CHANGES The changes to the SHNPP Fire Protection Quality Assurance Program described below help to clearly separate the Fire Protection Specialist's functions and responsibilities from that of the Quality Assurance function in ensuring that the SHNPP Fire Protection QA Program is fully implemented.
This is accomplished by deleting the documented surveillance associated with remote interaction of the Fire Protection Specialist with his staff, and replacing it with statements of responsibility and direct involvement with his staff.
In addition, duplication of effort between the Fire Protection Specialist functions and QA functions is eliminated.
A Pro ram Chan e ¹1 The current SHNPP Fire Protection QA Program includes "Preventive Maintenance" as an activity covered by a documented program of periodic surveillance to be performed by the Fire Protection Specialist.
This change deletes "Preventive Maintenance" from the scope of surveillance activities that the Fire Protection Specialist performs.
Reason for the Chan e
The Fire Protection QA Program currently includes provisions in FSAR Sections 17.2.19.9, 17.2.19.10 and 17.2.19.13 for ensuring that preventive maintenance activities related to fire protection are subject to appropriate
The Program also includes "Preventive Maintenance" as an activity subject to periodic surveillance by the Fire Protection Specialist.
The maintenance activity surveillance performed by the Fire Protection Specialist is redundant to that required in the sections cited above.
This change would eliminate this duplication of effort without a reduction of assurance that activities affecting fire protection are properly verified.
Basis for Concludin that the Revised Pro ram Incor oratin the chan e
Continues to Satisf 10CFR50 A
endix B and The FSAR ualit Pro ram:
Although this change could be construed to be a reduction of program commitment, the revised program provides the necessary assurance that the proper preventive maintenance requirements are applied to fire protection items through reviews, QA surveillance and Corporate QA audits.
This change does not adversely affect the ability to achieve and maintain safe shutdown in the event of fire.
Attachment 2 to NLS-89-062 Page 2
A Pro ram Chan e P2 The current SHNPP Fire Protection QA Program requires the Fire Protection Specialist to conduct a documented program of periodic surveillances which verifies compliance with governing procedures for fire protection activities.
The change would replace the requirements for a documented program of periodic surveillances with a responsibility statement for assuring compliance with governing procedures for fire protection activities.
The responsibility statement would be incorporated into FSAR Section 13.1.2.2.3.3 which describes the Fire Protection Specialist's organizational functions and responsibilities.
Reason for the Chan e
When Section 17.2.19 of the FSAR was written, it was assumed that the Fire Protection Specialist would have his office located near the control room and would therefore be relatively remote from his personnel in the field. It was expected that he would have frequent but not constant contact with these personnel.
Therefore the program was envisioned, and written, to employ periodic surveillance by the Fire Protection Specialist of his staff to ensure the effective implementation of his responsibilities.
However, his office area was subsequently moved to the Fire House where he is in continuous contact with the field personnel.
In addition, as the details of the Fire Protection program were developed, documented supervisory review and approval steps were built into the process as routine activities.
The supervisory review and approval obviates the need for the periodic surveillance to ensure compliance with the procedures governing fire protection activities.
Specific examples are given below:
A.
The Fire Protection Technical Aides in their rounds cover housekeeping and control oE combustibles in,addition to other activities and their Logs go to the Shift Foreman for inclusion in the shift turnover packages.
Problems found are also reported to the Fire Protection Specialist.
B.
The Senior Specialist Fire Protection personally reviews and signs the following items:
1.
Revisions to every Eire protection procedure.
2.
Lesson plans used in fire protection training.
3.
The certification oE every performer of Fire Protection Periodic Tests (FPT's) or Operating Periodic Tests (OPT's).
4.
The certification oE every hot work approver.
5.
The performance appraisal of each Technical Aide - Fire Protection.
Attachment 2 to NLS-89-062 Page 3
6.
Fire protection related Plant Change Requests 7.
The qualification cards of each Fire Protection Technical Aide.
C.
Either the Senior Specialist or the Specialist
- Fire Protection reviews and/or signs the following.'.
Each completed OPT and FPT.
These procedures cover both surveillance testing and certain Preventive Maintenance such as hydrant and hose testing.
2.
Each fire protection related Significant Operational Occurrence Report.
3.
Each fire watch Log.
These also cover housekeeping and the control of combustibles.
4.
Hot work permits.
D.
The Fire Protection Senior Specialist reviews and signs the following on a quarterly basis:
1.
The training status of each Fire Brigade member.
2.
The training status of ea'ch fire watch.
In view of the close, continuous supervision by the Fire Protection Specialist of the fire protection program activities, a redundant surveillance program by the Fire Protection Specialist of his staff is not needed.
Program reviews, surveillance and audits will continue to be carried out by on-site QA, CP&L Corporate QA, or independent fire protection consultants.
Basis for Concludin that the Revised Pro ram Incor oratin the chan e
Continues to Satisf 10CFR50 A
endix B and The FSAR ualit Pro ram:
Although this change could be construed to be a reduction of a program commitment, the revised program provides enhanced assurance of compliance with governing fire protection procedures through the established supervisory review and approval process.
Independent program reviews, surveillance and audits will continue to be carried out by on-site QA, CP&L Corporate QA, or fire protection consultants.
This change does not adversely affect the ability to achieve and maintain safe shutdown in the event of fire.
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