ML18010A463

Responds to Questions Re Changes to QA Program for Plant. Procedure MMM-001, Matls, Reviewed & Approved Per Tech Spec 6.5.1 Instead of 6.5.3.9b

ML18010A463
Person / Time
Site:	Harris
Issue date:	11/27/1991
From:	Floyd S CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NLS-91-316, NUDOCS 9112030197
Download: ML18010A463 (7)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9112030197 DOC.DATE: 91/11/27 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION FLOYD,S.D. Carolina Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to questions re changes to QA program for plant.

Encl to ltr contains response to staff request.

DISTRIBUTION CODE: IE43D COPIES RECEIVED:LTR ENCL SIZE: D TITLE: 50.54.a.3 6 50.55.f.3 Change to SAR QA Program S

NOTES:Application for permit renewal filed. 05000400

/

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 0 MOZAFARI,B. 1 1 D INTERNAL: ACRS 6 0 NBR/J3LPQ/LPEB10 1 "

1 D OC/LFMB 1 0 02 1 1 RGN2 FILE 01 1 1 EXTERNAL: NRC PDR 1 1 D

D NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 13 ENCL 5

~

Carolina Power R Light Company 0

Nuclear Services Department 411 Fayetteville Street Mall - P.O. Box 1551 Raleigh, North Carolina 27602 NOV37 >gP>

SERIAL: NLS-91-316 10CFR50.54(a)(3)

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:

The purpose of this letter is to respond to questions regarding changes to the Quality Assurance (QA) Program for the Shearon Harris Nuclear Power Plant (SHNPP).

Carolina Power & Light Company (CP&L) submitted a QA Program change on July 25, 1991, which proposed to remove the Corporate Quality Assurance (CQA)

Department from in-line review and approval of processes related to e ng 1 a'aI ' l. 'l.'I s j do cuno n L s ~

Subsequent to the requested change, the NRC requested clarification to issues within the proposed program. The enclosure to this letter contains CP&L's response to the staff's request.

Should you have any questions regarding this matter, please contact Mr. Dale Bates at (919) 546-6154.

Yours very truly, Manager Nuclear Licensing Section DBB/mbc (1408GLU)

Enclosure cc: Mr. ST D. Ebneter Mr. F. Jape Ms. B. L. Mozafari Mr. J. E. Tedrow

REQUEST FOR ADDITIONAL INFORMATION PROPOSED QA PROGRAM CHANGE SHEARON HARRIS NUCLEAR POWER PLANT, DOCKET NO. 50-400 A 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 (TSs).

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.

RESPONSE

HNP, procedure MM-001, "Materials," describes the controls of materials during maintenance activities.

F

1. This procedure is reviewed and approved in accordance with the requirements of TS 6.5.1 instead of TS 6.5.3.9b.

Plant procedures AP-005, AP-006, and AP-007 describe and control Plant Operating Manual Procedures and implement the review and approval requirements in Section 6.5.1.

2. There is no prescribed minimum "storage" time that affects items released for installation. Items that have been released and are awaiting installation are subject to inspection just prior to installation to ensure the quality of the product is maintained.

3. The responsible management is required to ensure the item, conditions, precautions, and follow-up inspections are performed to assure the quality of the product has been maintained. Any change to requirements requires a two-party review in accordance with CP&L's standard procedure change process.

(1408GLU)

A 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 the Technical Specifications.

2. Clarify whether the Shearon Harris documents maintained as QA records include at least the record types listed as QA records in Appendix A of ANSI N45.2.9-1974.

,RESPONSE'NP, Procedure RMP-007, "Project Required Records List Program," 'addresses the requirements for identification and classification of records'his procedure will be revised to reflect the new FSAR commitment once the FSAR change is approved.

1. This procedure will be reviewed and approved in accordance with TS 6.5.1 instead of TS 6.5;3.9b.,

2. The use of Appendix A to ANSI N45.2-9 is addressed in CP&L's position on Regulatory Guide 1.88 and is not affected by this change. This position is documented in FSAR Section 1.8.

(1408GLU)

A 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.

1. Indicate the minimum education, training, and/or experience required to establish an acceptable level of knowledge of QA when the reviewers of QA requirements are no longer in QA 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.

RESPONSE

1. Personnel performing these reviews are qualified per CPSL's position on ANS 3.1 - September 1979 (draft), which is documented in FSAR Section 1.8, Regulatory Guide 1.8. Responsible supervisors ensure individuals assigned are competent to perform these reviews.

2. Under the current process, QA Engineering personnel do not receive testing prior to performing these reviews. Specific testing is not planned for reviewers under the new process.

3. Current QA Engineering procedures are not required to be reviewed in accordance with TS 6.5.3.9b or 6.5.1. Nuclear'ngineering procedures governing these reviews are likewise not required to be reviewed in accordance with 6.5.3.9b or 6.5.1. Prior to the responsibility transition to the Nuclear Engineering Department (NED), these procedures were developed from commitments contained in the Corporate Quality Assurance Manual (CQAM). Nuclear Engineering procedures that are used to verify the adequacy of the design effort retain the same elements of control.

(140SGt.U)

A 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.

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 TSs.

RESPONSE'he July 25, 1991 request proposed to revise "the same controls which were applicable to the applicable to the original design." This was requested to permit the use of newer, acceptable standards when appropriate.

1. The Nuclear Engineering Department (NED) has responsibility for configuration/design control.

2. The design control process is accomplished in accordance with CP&L's position on Regulatory Guide 1.64, which includes design verification and is documented in FSAR Section 1'.8.

3. The design and verification process procedures are not governed by TS 6.5.3.9b or 6.5.1. They are reviewed and approved in accordance with commitments contained in the CQAM.

(1408GLU)

A PROGRAM CHANGE NO. 5 - The revised FSAR commitment indicates that selected plant procedures (and their revisions) will no longer be reviewed by the QA 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 QA for these reviewers when the reviews are no longer performed by the QA 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 TSs.

RESPONSE

As stated in CP&L's July 25, 1991 request, the proposed change is to delete redundant in-line reviews by the QA organization of procedures which already receive separate technical reviews by qualified individuals within the originating organization. The procedure/

procedure change originator typically performs the first technical review during the preparation of the document. A second technical review is performed by another qualified individual, which constitutes the "separate technical review." There is no restriction for the separate review to be "organizationally independent."

2. Reviewers are qualified in accordance with CP&L's position on ANS-3 '

September 1979 (draft), which is documented in FSAR Section 1.8, Regulatory Guide 1.8 for the applicable discipline involved.

Additionally, "Technical Reviewers" meet the requirements of TS 6 '.1 ~ 2.

3. The technical reviews are accomplished using procedure AP-006. This procedure is reviewed and approved in accordance with TS 6.5.1 instead of TS 6.5.3.9b.

(1408GLU)