ML18010A438
| ML18010A438 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/10/1991 |
| From: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| NLS-91-123, NUDOCS 9111200097 | |
| Download: ML18010A438 (4) | |
Text
October 10, 1991 Docket No. 50-400 License No.
NPF-63 Carolina Power and Light Company ATTN:
Mr. Lynn W. Eury Executive Vice President Power Supply P. 0.
Box 1551
- Raleigh, NC 27602 Gentlemen:
SUBJECT:
CHANGES TO YOUR QUALITY ASSURANCE (QA)
PROGRAM FOR SHEARON HARRIS NUCLEAR POWER PLANT The QA Program changes for the Shearon Harris Nuclear Power Plant which was submitted in your letter dated July 25,
- 1991, NLS-91-123, is continuing.
In order to complete our review responses to the questions in the enclosure to this letter is requested.
The questions are grouped in the five areas of your requested program changes.
We appreciate your cooperation with us and any questions you may have concerning this request should be directed to F.
Jape of my staff on 404-331-4182.
Sincerely,
Enclosure:
Proposed QA Program Change cc w/encl:
(See page 2)
Ori gi nal si gned by Albert F. Gibson Albert F. Gibson, Director Division of Reactor Safety 11 i 1200097 91 7i0i 0 PDR ADOCK 05000400 P
Carolina Power and Light October IO, 1991 cc w/encl:
R.
B. Richey, Vice President Harris Nuclear Project Box 165 New Hill, NC 27562 C. S. Hinnant General Manager Harris Nuclear Plant Box 165 New Hill, NC 27562 C.
S. Olexik, Jr.,
Manager Regulatory Compliance Harris Nuclear Project P. 0; Box 165 New Hill, NC 27562 H.
Ray Starling Manager - Legal Department P. 0.
Box 1551
- Raleigh, NC 27602 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health 5 Natural Resources P. 0.
Box 27687
- Raleigh, NC 27611-7687 c w/encl:
ocument Control Desk H. Christensen, RII B. Mozafari, NRR E. McKenna, NRR W. Brach, NRR
, F. Jape, RII NRC Resident Inspector U. S. Nuclear Regulatory Commission Route 1,
Box 315B New Hill, NC 27562 RII:DRS FJa e
10/. /91 RIIP C Julian 10/ (/91 RI 1+59 0Verrelli 10/
/91
O.
ENCLOSURE REQUEST FOR ADDITIONAL INFORNTION PROPOSED QA PROGRAM CHANGE SHEARON HARRIS NUCLEAR POWER PLANT, DOCKET NUMBER 50-400 Regarding proposed QA PROGRAM CHANGE NO.
1 - The revised FSAR commitment.
indicates that, when items are released from storage and waiting at a location prior to installation, responsible plant management will determine and document the "storage" requirements and the extent of inspection in accordance with plant procedures.
1.
Clarify whether the plant procedures that address this activity have been (or will be) developed and administered per Section 6.5.3.9b of the Technical Specifications.
4 2.
Clarify whether there is a minimum "storage" time (for example, one shift, one day, or one week) before a specific determination will be made and documented.
3.
Clarify whether. there is an independent in-line review of resultant "storage" and inspection requirements.
-Regarding proposed QA PROGRAM CHANGE NO.
2 - The revised FSAR commitment indicates that QA concurrence will no longer be required when a determination is made as to whether a particular type of document needs to be classified as a
QA record and its appropriate retention period.
If the proposed change is implemented, these determinations'will be made "in accordance with Records Management Procedures.
This change also deleted the definition of when a
document "has been completed" as when the document has received the final review performed by QA department personnel since documents will no longer require QA review prior to transmittal to Project Document Services for permanent storage.
1.
Clarify whether the Records Management Procedures that address this activity have been (or will be) developed and administered per Section 6.5.3.9b of th'e Technical Specifications.
2.
Clarify whether the Shearon Harris documents maintained as QA records includes at least the record types listed as QA records in Appendix A of ANSI N45.2.9-1974.
Regarding proposed QA PROGRAM CHANGE NO.
3 - The revised FSAR commitment indicates that separate technical and QA. reviews will no longer be conducted to verify the adequacy of the design effort. If the proposed change is implemented, these reviews will be conducted "by individuals knowledgeable in both technical and QA requirements."
The change request indicates these reviews currently include a review by QA Engineering.
e ENCLOSURE l.
Indicate the minimum education, training, and/or experience required to establish an acceptable level of knowledge of gA when the reviewers of gA requirements are no longer in gA Engineering..
2.
Clarify whether testing is done to ascertain whether an individual has such a level of knowledge.
3.
Clarify whether the reviews will be performed. in accordance with a procedure that has been,(or will be) developed and administered per Section 6.5.3.9b of the Technical Specifications.
Regarding proposed gA PROGRAM CHANGE NO.
4 - The revised FSAR commitment indicates that design changes will no longer be subject to -"the same controls" as were applicable to the original design but, rather, will be subject to "appropriate controls."
1.
Clarify who (by position title or by organizational entity) decides what controls are appropriate.
2.
Clarify whether there will be an independent verification of the appropriateness of the controls.
3.
Clarify whether the decision and its verification will be in accordance with a procedure that has been (or will be) developed and administered per Section 6.5.3.9b of the Technical Specifications.
Regarding proposed gA PROGRAM CHANGE NO.
5 - The revised FSAR commitment indicates that selected plant procedures (and their revisions) will no longer be reviewed by the gA group to ensure that required inspections,
- tests, and other critical operations are in the documents.
- Rather, these documents will "receive a separate technical review" to ensure these activities are specified.
1.
Clarify who (by position title or by organizational entity) will perform these reviews and indicate their independence from the originators.
2.
Indicate the minimum education, training, and/or experience required to establish an acceptable level of knowledge of gA for these reviewers when the reviews are no longer preformed by the gA group.
3.
Clarify whether the reviews will be done in accordance with a procedure that has been (or will be) developed and administered per Section 6.5.3.9b of the Technical Specifications.
HARRIS.RAI Septaaber 20, 1991