ML18010A849
| ML18010A849 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/23/1992 |
| From: | CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML18010A832 | List: |
| References | |
| OST-1825-P09, OST-1825-P9, NUDOCS 9210280098 | |
| Download: ML18010A849 (105) | |
Text
ADVANCE CHANGE FORM (1) Vol. Part~ Procedure No.
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C ST ISZ6 Rev. 5 Change d l e'
- 3) eason or t e n a 4M- Rome, O
(4) escrxptxon o t e ange (5) um er o roce ure ages ttac e ~
(6) Verify that the Technical Specifications rocedure Cross Reference, ye FSAR Commitment Cross Reference and ANSI 18.7 Commitment Cross Reference (AP-005) have been reviewed and all discrepancies found have been submitted to Regulatory Complianc~ for resolution Date ~2~2. W (Name and SxgnatureJ If a revision is required to the Technical Specification Procedure Cross Reference, verify that a Task Change Request Form (PLP-103) has been submitted for Management Approval.
NA ote: not app xca Date ~Z2~
egu atory omp nance x e
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(7) Submitted for Approval.: {
rxginator s arne an signature Date ~~~~
(8) Technical Reviews:
1st Qualified Technical Reviewer ~2ggtv e an xgnature 2nd Qualified Technical Reviewer arne an ]gnat re ate (9) CPSL Safety Review: (Check One) required and attached not required Date ~7ry~Z ua x xe a ety evxewer s arne an signature (10) Required Reviewers'. (Circle all applicable) AA, CH, DS, E EP, FP, II>
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(Name an signature ate (ll) Approved By: EFFEGTlVE $ P 2 3 1992 h ae egaaac g i a. C Le J ate Remarks:
(Form AP-007-4-9)
PEP 23 199Z
( 92i0280098 921009 PDR ADOCN 05000400 HNP P .
HNP COt)TROLLEO COPY 8~ PDR DOCUME
P~ Zo(Z.
OST-1825 AC 5/1 Description of Changes
-Change note prior to pre-req 1 into a step. requiring SS-n Signature.
-Fix acceptance criteria to match steps of the procedure.
-Change Acceptance Criteria for Tech Spec 4.3.2.1 Table 4.3-2 Item l.a to check the SI Actuated Light on the BPLB and not a huge list of components.
-Open the Bkrs for the CNMT Spray Sump recirc valves to prevent them from opening if an RWST lo level signal is received with the pump in service.
-Fix SLB designations for HVAC dampers (8 & 10) and allowed the use of ERFIS and/or safeguards terminal to check.
-Changed the method of "determining required AFW discharge pressure. We will now record suction pressure with the AFW pump on.
-Isolated CCW pressure transmitters to block the low pressure starts
,(similar to OST-1316).
-Moved the stopping of the B-SB Chiller from 7.3.45 to 7.10.23 since B train equipment will be in service.
xnto ac ~amend. 'J'~
-Stopped using 1SP-216 to verify relay K603 to use 1BD-1.
-Added a check of the B FW isol relays (check valve closure with the a signal blocked) and add jumpers/lifted leads to block the a FW isol to 4 valves. Acceptance Criteria said this was tested.
-Corrected MCB section for phase A Isolation switch.
-Corrected Att 2 for ESW to match pre-reqs.
-Corrected Att 9 computer points.
-Corrected Att 10 computer points
-Fixed Surv Req on Att 11
-Removed incorrect and not needed step ll of Att 12.
-Added page 4a to Att 13 for Jumpers/leads to test FW valves.
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9208100315 ENCLOSURE 1 SHEARON HARRIS NUCLEAR POWER PLANT QUALITYASSURANCE PROGRAM CHANGE (1437HMP.CLU)
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.8 PAGE 1.8-9 Pro osed Chan e ¹1 The proposed change deletes reference to QA and replaces it with QC inspection.
Reason for Chan es This clarifies the organizational description of personnel..
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 Qualification of NAD personnel will be in accordance with Section 17.3.
)
Qualification of QC personnel will be in 'accordance with CP&L's commitment to Regulatory Guide 1.58 and Section 17.3.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.28 PAGE 1.8-36 Pro osed Chan e ¹2 The proposed change deletes reference to Section 17.2.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being deleted to prevent possible conflicts in references.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Deletion of references to Section 17.2 will not affect the implementation of the QA Program.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.30 PAGES 1.8-38 &
38a'ro osed Chan e ¹3 The proposed change revises the reference fro'm Section 17.2 to 17.3.
Reason of Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
A"PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.33 PAGES 1.8-41 42
& 42a Pro osed Chan e ¹4 The proposed change deletes the existing clarification "b" and replaces it with new clarifications "b & c" concerning CP&L's independent review and assessment programs. The new clarifications are provided to reference the plant Technical Specifications and Section 17.3 of the FSAR for the details of these programs.
Reason for Chan e These new clarifica'tions and references to the plant Technical Specifications and Section 17.3 of the FSAR eliminate duplication and potential misunderstandings; 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 CP&L's NAD will implement Independent Assessments as described in Section 17.3. Results of Independent Assessments and reviews of those results by Senior Management will be in accordance with Section 17.3 ~
CP&L's'ndependent Review Program will be implemented in accordance with the plants Technical Specifications.
Pro osed Chan e ¹5 The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
Pro osed Chan e ¹6 Addition of clarification "m" which provides a reference to Section 17.3 for a description of controls for Measuring & Test Equipment (M&TE).
Reason for Chan e Addition of this clarification does not change the manner in which business is conducted, but simply references where additional clarifications and control on M&TE are located in the FSAR. These were previously included in Section 17.2 but were
'ontrols/clarifications not referenced here. This provides a better description of where the controls for M&TE are located in the program.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Controls described in 17.3 contain the elements previously described in 17.2.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.37 PAGE 1 8-49 Pro osed Chan es ¹7 The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continue to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.38 PAGES 1.8-50 50a & 50d Pro osed Chan e ¹8 The proposed change deletes the work "operational" describing the QA Program.
Reason for Chan e Deletion of this work adds consistency to the method in which this program is written.
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 The deletion of the word "operational" does not alter the way that the QA Program described in 17.3 will be implemented. This simply adds consistency to the way,that Section 17.3 is written.
Pro osed Chan e ¹9, The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
Pro osed Chan e ¹10 The proposed change to clarification "z" deletes the responsibility for QA/QC personnel to witness load tests of rigging equipment and surveillance of operator maintenance inspections. This change clarifies that Quality Control (QC) personnel will continue to perform nondestructive examinations of rigging equipment.
Reason for Chan e This requirement was carried over from the construction program when most of the rigging inspections were performed by contractor personnel with little formal procedural controls and training. The plant maintenance procedures provide improved criteria for inspection and testing. The personnel are qualified under a formal program. The need for independent witnessing to assure quality is no longer needed. In addition the frequency of these type tests is much reduced since construction was completed. Most rigging is now purchased with certification of load capacity and does not require testing upon receipt.
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 This change places the responsibility for witnessing for load tests and surveillance of maintenance inspections at the appropriate level in the line organization.
Plant maintenance procedures have criteria for inspection and, testing which assures that quality in these activities is achieved.
In addition, The NAD will'independently evaluate the overall performance of inspection, testing, and nondestructive examinations.
Pro osed Chan e ¹10A The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are. being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.39 PAGE 1.8-51 Pro osed Chan e ¹ll The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e ~
Section 17.2 is being replaced with 17.3. The references're being revised accordingly.
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 Section 17;2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.54 PAGE 1.8-67 Pro osed Chan e ¹12 The proposed change ievises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.58 PAGE 1.8-71 Pro osed Chan e ¹12A
~
The proposed change eliminates the commitment to the Regulatory .Guide 1.58.
listed on page 1.8-71 of the FSAR.
Reason for Chan e The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because -it has become obsolete.
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 The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2.6-1978) endorsed by this regulatory guide is remaining in effect and CPSL will continue to comply with ANSI N45.2.6-1978.
Pro osed Chan e ¹13
- The proposed change deletes "Operating Plant QA" and identifies the Quality Control (QC) personnel are qualified per this standard as stated in this position.
r Reason for Chan e Clarify organization description of personnel.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Qualification of NAD personnel will be in accordance with Section "17.3.
Qualification of QC personnel will be in accordance with CP6L's commitment to Regulatory Guide 1.58 and Section 17.3.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.64 PAGE 1.8-79 Pro osed Chan e ¹14 The'roposed change eliminates the commitment to the Regulatory Guide 1.64 listed on page 1.8-79 of the FSAR.
Reason for Chan e The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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 The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2.11-1974) endorsed by this regulatory guide is remaining in effect and CPSL will continue to comply with ANSI N45.2.11-1974.
Pro osed Chan e ¹15 The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
Basis for Concludin That the Revised Pro ram Incor orat n the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Section 17.2. is being replaced in its entirety by Section 17.3, which describes the QA Program.
t A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.74 PAGES 1.8-93 & 94 Pro osed Chan e ¹16 The proposed change deletes two definitions that were used as part of the Audit Program.
Reason for Chan e.
These definitions are no longer needed with the description of the assessment process in Section 17.3.
Basis for Concludin That the Revised Pro ram Incor oration the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Section 17.3 describes the assessment process. Deletion of the definitions that. were part of the audit process 'does not effect the effectiveness of the Section 17.3 assessment process.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.88 PAGE 118 & 1.8-118a Pro osed Chan e ¹16A The proposed change eliminates the commitment to the Regulatory Guide 1.88 listed on page 1.8-118'of the FSAR.
Reason for Chan e The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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 The NRC provided notification for withdrawal 'of this Regulatory Guide (see 56 Federal Register at 36175) because 'it has become obsolete.
~
The ANSI Standard (N45.2.9-1974) endorsed by this regulatory guide is remaining in effect and CP&L will continue to comply with ANSI N45.2.9-1974.
Pro osed Chan e ¹17 The proposed change revises the responsibility for justifying, evaluating, and approving exceptions to the temporary storage of records requirements from the Manager - Corporate Quality Assurance to the Vice President -.
Harris'uclear Project Department.
Reason for Chan e The position of Manager - Corporate Quality Assurance no longer exists, therefore this responsibility has to be re-assigned.
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 1
This change places the responsibility for controlling exceptions to the temporary storage of records requirements at the appropriate level in the line organization.,
Pro osed Chan e ¹18 Addition of clarification "k" which provides a reference to Section 17.3 for a description of controls for QA records.
Reason for Chan e Addition of this clarification does not change the manner in which business is conducted, but simply references where additional clarifications and controls on QA records are located in the FSAR. These controls/clarifications were previously included in Section 17.2 but were not referenced here. This provides a better description of where the controls for QA records are located in the program.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Controls in 17.3 contain the elements previously contained in Section 17.2.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.116 PAGE 1.8-147 Pro osed Chan e ¹19 The proposed change revises the reference from Section 17.2 to 17.3.
Reason for Chan e Section-17.2 is being replaced with 17.3. The references are being revised accordingly.
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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.
r A PROGRAM - FSAR 1.8 REGULATORY GUIDE 1.123 PAGES 1.8-155 157 & 158 I
Pro osed Chan e ¹19A The proposed change eliminates the commitment to the Regulatory Guide 1;123 listed on page"1.8-155 V
of the FSAR.
Reason for-. Chan e The NRC provided notification for withdrawal of this Regulatory Guide,(see 56 Federal Register at 36175) because it has become obsolete.
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 ra'm The NRC provided=notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2.13-1976) endorsed by this regulatory guide is remaining in effect and CP&L will continue to comply with ANSI N45.2.13-1976.
Pro osed Chan e ¹20 The proposed change revises the reference from Section,17.2 to 17.3.
Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.
Basis for Concludin That the Re'vised Pro ram Incor oratin the Chan e continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17:3, which describes the QA Program.
Pro osed Chan e ¹21 The proposed- change deletes the specific reference to QA for evaluating QA program. The specific responsibility for this activity is a'upplier's now with the Quality Verification Section.
Reason for Chan e Section 13.1 of the FSAR includes this responsibility.
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 CP&L's reorganization of the Corporate Quality Assurance organization places this function in the Nuclear Services Department. Reorganization of this function has not changed the implementation of this function.
Pro osed Chan e ¹22 The proposed change deletes the specific phrase "for the operating phase".
Reason for Chan e Deletion of this work adds consistency to the method this program is written.
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 The deletion of the words "for the operating phase" does not alter the way that the QA Program described in Section 17.3 will be implemented. This simply makes this section consistent with to the way Section 17.3 is written.
Pro osed Chan e ¹23 The proposed change deletes the phrase -"technical and QA" describing overview of causes and corrective action relative to vendor deficiencies.
Reason for Chan e These words implied that two separate reviews were required in each case.
Deletion of this phrase does not reduce the end result. It states that CP&L will perform what ever type of evaluation is deemed appropriate, relative to causes and corrective action of vendor deficiencies, without inference to a specific organization unit.
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 The Quality Verification Section will continue to ensure the Vendors stay in compliance with their accepted QA Program commitments.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.144 PAGES 1.8-182 183 6 184 Pro osed Chan e ¹23A The proposed change eliminates the commitment to the Regulatory Guide 1.144 listed on page 1.8-182 of the FSAR.
Reason for Chan e The NRC provided notification for withdrawal of this Regulatory Guide .(see 56 Federal Register at 36175) because it has become obsolete.
Basis for Concludin That the Revised "Pro ram Inco oratin the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2 '2-1977) endorsed by this regulatory guide is remaining in effect and CP&L will continue to comply with ANSI N45.2.12-1977.
Pro osed Chan e ¹24 The proposed change replaces the current clarifications relative to the Regulatory Guide 1.144 Audit Program. External (vendor) audits will continue to be accomplished in accordance with this standard; Internal assessments will be accomplished in accordance with the'requirements .
outlined in Section 17.3.
Reason for Chan e There is no change for external audits. The internal assessment process included in Section 17.3 better describes the methods to be accomplished than this Regulatory Guide or Standard. Therefore no commitment is included to comply with this standard for internal assessments.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram Independent assessment of internal activities will be accomplished as outlined in Section 17.3.3.
A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.146 PAGE 1.8-186 Pro osed Chan e ¹24A The proposed change eliminates the commitment to the Regulatory Guide 1.144 listed on page 1.8-182 of the FSAR.
~
Reason for Chan e The NRC provided notification for -withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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 The NRC provided notification for withdrawal of this Regulatory Guide .(see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2.23-1978) endorsed by this regulatory'uide is remaining in effect and CP&L will continue to comply with ANSI'N45.2.23-1978.
Pro osed Chan e ¹25 The proposed change replaces existing clarifications relative to the lead auditor qualification. Qualification for external (vendor) auditors will continue to be accomplished'n accordance with this standard.
Qualification of internal independent assessment personnel will be accomplished in accordance with the requirements. outlined in Section 17.3.
A reference to Section"17.3 is being added to this page.
Reason for Chan e The qualification for internal independent assessment personnel included in Section 17.3 better describes the methods to be accomplished than this Regulatory Guide or Standard. Therefore no commitment is included to comply with this standard for qualification of internal independent assessment personnel.
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 Qualification of internal assessment personnel shall be accomplished as outlined in Section 17.3 based on education and experience needed to evaluate the activity being assessed.
Pro osed Chan e ¹26 The proposed change deletes paragraph "d" regarding record retention of qualification records.
Reason for Chan e Regulatory Guide 1.88/ANSI N45.2.9-1974 was revised to reference Section 17.3. This reference is being removed for consistency with the method to which the QA Pr'ogram is written. (S'ee Proposed Change 18)
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 Personnel qualification and training records will be maintained in accordance with Section 17.3. Deletion of this reference does not change the controls for record retention.
A PROGRAM CHANGE - FSAR SECTION 9.5 FIRE PROTECTION PAGE 9.5.1-56 Pro osed Chan e ¹27 The proposed change deletes references to the QA ogganization and specific responsibilities assigned to the QA organization relative to fire .
protection. Section 17.3 is referenced to address the NAD.
Reason for Chan e The specific responsibilities are being deleted from this section and included in Section 17.3 to eliminate duplication and possible conflicts.
Reference to the QA organization is deleted based on creation of the NAD.
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 Section 17.3 describes the QA Program. The operational fire protection QA elements are included in Section 17.3.
The NAD will evaluate the effectiveness of the Fire Protection Program through the use of independent assessment.
A PROGRAM CHANGE - FSAR SECTION 13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION PAGE 13.1.1-6 Pro osed Chan e ¹28 The proposed change changes the word "barriers" to "deficiencies",
Reason for Chan e The proposed change provides consistency and clarity to the way this section is written.
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 The word change, being made is not changing the intent of the responsibilities described here and therefore will not change the way the QA Program is implemented.
A PROGRAM CHANGE - FSAR SECTION 13.4.2 INDEPENDENT REVIEW PAGE 13.4.2-1 Pro osed Chan e ¹29 The proposed change deletes the details about the Independent Review Program from the FSAR and makes reference to Technical Specifications for these details.
Reason for Chan e Deletion from the FSAR eliminates duplication and possible conflicts.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satisf 10CFR50 A endix B and the FSAR ualit Pro ram The Independent Review Program is described in the Technical Specifications. Deletion of the program description from the FSAR does not change the program but simply eliminates duplication and potential confusion'.
A PROGRAM CHANGE - FSAR SECTION 13.4.3 AUDIT PROGRAM PAGES 13.4.3-1 13.4.3-2 & 13.4.3-3 Pro osed Chan e ¹30 The proposed change deletes the specific details of the Audit Program and references Section 17.3 for this information.
Reason for Chan e Deletion of the specific details from this section eliminates duplication within the FSAR.
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 Section 17.3.3 describes the independent assessment process which replaces the Audit Program described here.
The NAD will implement the independent assessment process. This"process will ensure an effective means of reviewing and evaluating the CP&L QA Program.
A PROGRAM CHANGE - FSAR SECTION 17.2 A PROGRAM DESCRIPTION PAGES 17.2.1-1 THROUGH 17.2.19-4 Pro osed Chan e ¹31 The proposed change deletes Section 17.2 in with Section 17.3 which describes the its entirety and replaces it QA Program.
Reason for Chan e F
The proposed Section 17 ' describes the use of performance-based assessment concepts which CP&L proposes to use in the NAD.and line organizations. The program content is the same as was in 17.2 except in the area of audit/asses'sment.
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 Section 17.3 replaces Section 17.2 in its entirety'. The program content is the same as was in 17.2 except in the area of assessments. These controls will ensure an effective QA Program at CP&L.
ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT FSAR PAGE MARK-UPS (1437HHP.GLU)
SHNPP PSAR
- 2) Paragraph 4.3.2 describes the qualifications for supervisors who are not required to hold an NRC license, but. who are associated with "systems, equipment, or procedures involved in meeting the Limiting Conditions for Operation, which are identified xn Technical Specifications". CP&L does not feel plant-.safety will be enhanced by requiring these supervisors to perform their duties under direct on-site supervision for a minimum of six months. Instead, CP&L proposes to select qualified individuals for these'ositions based upon past performance and experience.
- 3) Paragraph 4.5.1.1 describes the requirements for non-licensed operators. CP&L does not feel plant safety will be enhanced by, requiring non-licensed operators to have one year power plant experience. CP&L shall alternatively provide a training/qualification program conmensurate to the functions and responsibilities these employees will perform.
- 4) Paragraph 4.5.1.2 describes the requirements for licensed operators. CP&L takes exception to these requirements. Prior to operating the facility, licensed operators shall be qualified in accordance to 10CFR55 and the NRC letter dated March 28, 1980, "Qualification of Reactor Operators".
- 5) Paragraphs 4.5.2 and 4.5.3 describe the qualifications for technicians and maintenance personnel. CP&L considers these technicians and maintenance employees to be "in training or apprentice positions",
as described in paragraph 3.2.4. Therefore, CP&L shall comply with the requirements as stated in paragraph 3.2.4.
~948) CflG.AG C t g jgZp~( >Q Q 6 Members of the Qg staff will be trained and qualified in accordance 4d with Regulatory Guide 1.58, which endorses ANSI N45.2.6 ~ The SHNPP position on Regulatory Guide 1.58 addresses the SHNPP positions relative to ANSI N45 ~ 2 '
')
Various CP&L positions are not addressed in the Standard.
Therefore, CP&L lists these positions in Table 1.8-1 for reference, and CP&L will prescribe the training, responsibilities, and qualifications conmensurate to the job requirements.
- 8) The ALARA Specialist shall have a BS Degree or the equivalent and two years experience, one of which shall be nuclear power plant or the employee shall have an advanced degree and one year 'xperience, nuclear power plant experience.
- 9) The Project Engineer " On-Site Nuclear Safety shall have a BS Degree in Engineering or the equivalent and shall have a minimum of four years experience. These qualifications are required prior to preoperational testing or at position appointment, whichever is later.
1 ~ 8-9 Amendment No. 40
SHNPP FSAR Regulatory Guide 1.28 QUALITY ASSURANCE PROGRAM REQUIREMENTS (DESIGN AND CONSTRUCTION) (REV 0)
For those activities performed under operating license, SHNPP shall comply with the requirements of Regulatory Guide 1.33 as specified in CP&L's position on Regulatory Guide 1.33. Regulatory Guide 1.28 is not considered necessary and is not included as part of the Operational QA'rogram.
1.8-36 Amendment No. 41
SHNPP FSAR Regulatory Guide 1.30 QUALITY ASSURANCE REQUIREMENTS FOR THE INSTALLATION AND TESTING OF INSTRUMENTATION AND ELECTRIC EQUIPMENT (REV. 0)
Carolina Power & Light Company complies with the requirements of ANSI N45.2.4-1972 as it is endorsed by Regulatory Guide 1.30 with the following clarifications'.
a) Paragraph 2.1, Planning. Requirements, as determined by responsible plant management, will be incorporated into procedures.
b) Paragraphs 2.2 and 2.3; Prerequisites, Procedures, and Instructions'.
these control.s will be implemented as determined by responsible pl.ant management in- approved procedures.
c) Paragraph 2,4, Results, will be implemented as set forth in sectionpf 1.7. and by compliance with Regulatory Guide 1.33. ~
f' C au c.~x d) Paragraph 2.5, asuring and Test Equipment, will be implemented as set forth in Section 17.+rkQ- in lieu of the requirements set forth in this paragraph.
e) Paragraph 3,,Preconstruction Verification.'Approved instructions" are interpreted to include vendor manuals. These manuals are not normally approved by CP&L; however, CP&L does review the applicable portions of these manuals of acceptability towards the work being plannedldone.
f) Paragraph 4, Installation, will be implemented by inclusion of requirements in modification or maintenance procedures, where such procedures are used. Standard CP&L practices require that appropriate care be exercised whether a procedure is requir'ed or not.
g) Paragraph 5.1, Inspections, including subparagraphs 5.1.1, 5.1.2, and the first sentence in 5.1.3, will be implemented as set forth in Section 17.+&9 The remaining sentence in 5.1.3 is covered in equivalent detail by CP&L's co 'ent to Regulatory Guide 1.33, paragraph 5.2.6; the re'quirements as set fort 'hat commitment will be implemented in lieu of the requirements stated here. <<P~Q g <g~4g h) Paragraph 5.2, Tests, including suhpay5graphdi3.2.1 through 3.2.3, uill be implemented as set forth in Sections 17. . . The test program will consider the elements outlined in this paragraph when developing test requirements for inclusion in maintenance and modification procedures. In some cases, testing requirements may be met by post-installation surveil/.ance testing in lieu of a special post-installation test.
i) Paragraph 6, Post-Construction Verification, is not generally considered applicable at operating facilities because of the scope of .the work and the
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relatively short interval between installation and operation.
1.8-38 Amendment No. 41
SHHPP FSAR j) Paragraph 6.2.1 titled Equipment Tests: . The last paragraph of this section deals with tagging and labeling. Carolina Power & Light Company will corn Ly.with comp y. an alternate Last paragraph which reads.'Each safety-related component of process instrumentation is identified with a unique number. This number is utilized in instrument maintenance records so that current caLibration status, including data such as the date of the calibration and identity of person that performed the calibration, can*be readily determined. Such information may also be contained on tags or labels which II may be attached to instaLled instrumentation.
k) Paragraph 7, Data Analysis and Evaluation, will be implemented as stated with adding the clarifying phrase "When used" at the beginning of that paragraph. The plant shall have procedures, to the extent determined by 41( responsible plant management, for the performance of analyzing test data., but these procedures are not referred to as data processing procedures.
References:
Sections 8.3.1.2, 17. ~ ~ ~ ~
g ~ ~ 7 I ft I oSBL C488C.~3 1.8-38a Amendment No. 41
0 SllNPP FSAR
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Regulatory Guide 1.33 ASSURANCE PROGRAM REQUIREMENTS (REV. 2)
QUALITY ASS S
(OPERATION) rolina Power N18.7-1976, with
& L't t
ig he E o Company compl.ies with tthis llowing cl.arifrcations.
is gui guide, which endorses ANSI 41 e" recommends that this standard applies to P
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J 41 vit ith sa fe ty el t d t, a
ts of those associated g, 1 t'o ANSI N18.
th 10CFR50. Co f1 i t i
to account
}1 E }1 ll 1 ANSI N18.7-1976 only to thosee p lant a features addresse d in Section ec 3 2 of the FSAR that are classr f ie d as saEety-related andd un underer the control of the Q prog
+ ik u) lace resp onsible or Com an 's Performance Evaluation Unit is E h A dt ot'i 'db te the t 41
.Vice President Po~er uup llna Power & Light will use these management reviews, to satis atisf y thee requirements o "tion of paragraph 4.5.
Prr,as@ C.} ~~r;~ 4.'l ui ment Control: CP&L vil.l comply with the I 41 "independent verrification" ication requirements base d on the definition of this phrase as given under t he commitment to R egu latory a Guide 1.74.
Since escri tive names to designate equ'p e ui ment, the sixth paragrap re laced wrt : ui identification numbers or ot er descriptions v ic ar other s of the status of inspections and tests.
Th e first'entence 1r's in the seven venth p aragr'aph will be comp om lied with after clarifying "operating ersonnel" personne " to mean traine d emp loyees assigned to, or em under the contro 1 o E CP&L management at ann ooperating nuclear Eaci rty.
Paragrap nd Modification.'ince some emergency t41 situations cou ld arxse which preclude p re p lanning o f a l. ac ' '
ll comp 1 y wl'th an alternate to the h first irs se sentence in the secon rea s. enc or abnormal operating co nditions where immediate ac t'ons i are required to pro rotect the hea 1 t h an d E t of th bl protect equuipment u or personnelt1 or to preven t the deterioratron o "p a 'ant itions to a possibl.e unsa fee or unstable con ditions u eve , ma'intenance or modifica tion of equipment shal.l be prep re lanned and performeed in ac accordance with written prrocedures. Where wri tten p rocedures wou ld bee required and are. no t uused, the corn lished sha ll b e documented oc after the aItct and recex've the same degree of review as E t h ey h d b i 1 d Paragraph 5 2 7. 1 Maintenance Programs: ms: CP&L vill comply with the requirements o f the first sentence o E the Eifth paragrap h. This clarification 1.8-41 Amendment No. 41
Pro osed Chan e 4 Insert for Re . Guide 1.33 b.) Section 4.3 titled Inde endent Review Pro ram: CP&L will implement the independent review program outlined in the plant Technical Specifications. 6.5.2 an assessment program outlined Section 17.3.3 of the FSAR.
SHNPP FSAR is needed since it is not always possible to promptLy determine the cause of the malfunction. CP&L wilL initiate proceedings to determine the cause, and will make such determination promptly where practical. Determination of the term "promptly" and the term "practical" will be the responsibility of plant 4LI management and shall be based on the'effect of the condition on the immediate health and safety of the public.
4 I) 4+ Paragraph 5.2.8, Surveillance Testing and Inspection Schedule: In lieu of a "master surveillance schedule," the foLLowing requirement shall be complied with: "surveilLance testing schedule(s),shaLL be established reflecting the status of all planned in-plant surveillance tests and inspections."
II
/) i Paragraph 5 2 . 9, Plant Secur ty and Vi s i tor Cont ro 1, requi re's certain
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~ procedures and controls. In order to ensure that a conflict between LOCFR73 and ReguLatory Guide ). 17 and ANSI N18. 17 does not exist, CP&L shaLL not follow Paragraph 5.2.9. An NRC approved security plan shall be implemented prior to fu'el loading. Pi'pic C 0 6 ~S Paragraph 5.2.11, Correcti e Action, requires certain activities to be performed. In order to avoid c nflict between requirements, CP&L shall follow the requirements in Section 17. . . . , in lieu of 4 1 Paragraph 5.2.11 as additionally clarified in above paragraph (d).
Paragraph 5.2.15, Review, Approval and Control of Procedures: The third sentence in Paragraph three is interpreted to mean: "Applicable procedures shall be reviewed foLlowing an accident, an unexpected transient or a significant operator error. Applicable procedures shall also be reviewed following an equipment malfunction which results in a reportable event."
41 )g Paragraph 5.2.16, Measuring and Test Equipment - In order to properly address this paragraph, CP&L submits the following discussion of M&TE:
IEEE Standard '498-'1975 defines measuring and test equipment (M&TE) as follows:
Devices or systems used to calibrate, measure, gauge, test, inspect, or control in order to acquire research, development, test, or operational data to determine compliance with design, specifications, or other technical requirements. M&TE does not include permanently installed operating equipment or test equipment used for preliminary checks where accuracy. is not required; for example, circuit checking multimeters.
There is a key distinction between installed process instruments and measuring and test equipment. A piece of measuring and test equipment may be used a number of plant instruments. Thus, a calibration error could to'alibrate affect a wide variety of plant equipment. Process instruments, on the other hand, perform a single function and may be used to operate equipment, verify operabil.ity of equipment, or perform a single monitoring or trip function. In the case of measuring and test equipment, the key concern when a device is out of calibration is to identify other instruments to which this accuracy has been transferred and, secondLy, to prevent recurrence'. In the case of process instruments, the key emphasis is to prevent recurrence of the out-of-calibration condition.
1.8-42 Amendment No. 41
SHNPP FSAR In ANSI N18.7-1976 (and other documents), the distinction between measuring and test equipment and process instruments is not well defined. The requirements in the second and third paragraphs in Section 5.2.16 wilL be applied to measuring and test equipment and those in the first and third paragraphs applied to process instruments with the exception that process instrumentation shall be "suitably marked or tracked to indicate calibratio'n status" versus "suitably marked to indicate calibration status." In addition,'
review of out-of-calibration process instruments will be made to determine if action is required to prevent recurrence. Such action may include modification, procedural revision, or corrective maintenance.
- k. Q Paragraph 5.2.17, Inspections: As a general clarification, when inspections are not contained in a separate inspection report, inspection requirements wilL be integrated into appropriate procedures or other documents with the proc'edure or document serving as the record. Records of inspections will be identi:fiable and retrievable.
L'
. Paragraph 5.2.17, second to the last sentence in the last paragraph, "Deviations, their cause, and any . . .", to be consistent with Paragraph 5.2.11, the cause of the condition will be determined for only significant',
conditions adverse to safety.
~<on) 1 7 8 pc>< (Q~ o cjJ jfjQQ~ pt Ca dTz L
Co-lion+ 4o Pro Posecf Cha.QG 6' 1.8-42a Amendment No. 41
SHNPP FSAR Regulatory Guide 1.37 QUALITY ASSURANCE REQUIREMENTS FOR CLEANING FLUID SYSTEMS AND ASSOCIATED'COMPONENTS OF WATER-COOLED NUCLEAR POWER PLANTS (REV. 0)
Carolina Power & Light Company shalL compLy with the requirements of
'ANSI N45.2.1-1973, as it is endorsed by Regulatory Gu'ide 1.37-March 1973, with the following clarifications'.
a) Paragraph 2.5, Test Equipment, outlines control of inspection and test equipment. CP&L has addressed its position reLative to Measuring & Test Equipment (M&TE) in Section 17.~3 Pp~Pc,S~) ( 4.LKt. + 7 b) Paragraph 5, Installation Cleaning'The recommendation that local.
rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded provided other cleaning methods are not considered detrimental as determined by responsible plant management.
c) The guide and standard are applicable tn those areas of the Quality Assurance Program addressing on-site cleaning of materials and components, cleanness control, preoperation cleaning and layup of fluid systems.
d) With regard to Paragraph C.3 of ReguLatory Guide 1.37: Chromates or other additives, normally in the system water, will not necessarily be" added to the flush water.
e) With regard to Paragraph C.4 of Regulatory 'Guide ).37: Expendable materials, such as inks and related products; temperature. indicating sticks',
tapes; gummed Lables; wrapping materials; water soluble dam materiaLs; Lubricants, NDT penetrant materials and couplants, dessicants, which contact stainless steel or nickeL alloy surfaces shaLL be of commerciaL quality.
Levels for halogens, sulfur, chlorides, Low melting point metal, etc., for use on stainless steel and nickel alloy surfaces will be as determined by responsibLe technicaL group to limit or preclude intergranular cracking .and stress corrosion cracking.
1.8-49 Amendment No. 41
SHNPP FSAR Regulatory Guide 1.38 QUALITY ASSURANCE REQUIREMENTS FOR PACKAGING, SflIPPING, RECEIVING STORAGE, AND HANDLING OF ITEMS FOR MATER-COOLED NUCLEAR POWER PLANTS (REV. 2)
Carolina Power & Light Company shall comply with the requirements of ANSI N45.2.2"1972 as it is endorsed by Regulatory Guide 1.38 with the following clarifications:
Prc&~3 CLOV6C + Z a) Paragraph 2.1, Planning: (First sentence) the specific items to be governed by the Standard shall be identified. However, the Standard is part Q
those structures, systems, and components which are included in that Program.
b) Paragraph 2.3 Results The full requirements of this paragraph shall apply to the inspections and tests that are performed to determine the acceptability of product quality.
c) Paragraph 2.4 Those pers'onnel that perform inspection, examination, and testing activities for verification and acceptance/rejection purposes shall be qualified in accordance with Regulatory Guide 1.58.
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d) Paragraph 2.5 Measuring and Test Equipment (2.5.2) - That equipment which measures quality of the permanent plant items shall be under the calibration and control, program; whereas the equipment used to measure secondary conditions, such as warehouse temperature, humidity, etc., will be maintained in good working order and checked for proper functioning when accuracy is in doubt, but not maintained .under the calibration and control program. Traceability to calibration records will be provided when it is impractical (because of size, configuration, or application)'to physically mark calibration information on the item.
e) Paragraph 2.7, Classification of Items: CP&L may choose not to explicitly use the four level classification system. However, the specific requirements of the Standard that are appropriate to each class will be applied unless justified and documented.
1.8"50 Amendment 'No. 41
SHNPP FSAR f) Paragraph 2.7.1(3) requires special nuclear material (fuel) and sources to be classified as level A. Carolina Power & Light Company shaLL store new/used nuclear fuel and radioactive sources in storage locations as described in the Sections 9 and 12. Radioactive sources used by HP personneL shall be stored and controlled in accordance with HP practices and procedures.
g) Paragraph 3.2 " LeveLs of Packaging - Packaging for shipment o'fE-site will be equal to or exceed the original packaging by the vendor, as requi red to ass'ure the quality of the item is not degraded as a result of shipping or handLing.
h) Paragraph 3.4, Methods of preservation: (First sentence) CP&L will comply with these requirements subject to the clarification that the term "deleterious corrosion" means corrosion which cannot be subsequently removed and which adversely affects form, fit, or function.
i) Paragraph 3.6 " Barrier and Wrap Materials and Desiccants The use of clear plastic in warehouses will be minimized. The guide rule is that the
'clear plastic shall be used only where periodic visual inspection is necessary. Plastic wrap on items supplied in accordance with a vendor's approved QA/QC program wiLL be accepted and stored without rewrapping.
j) Paragraph 3.7, Containers, Crating and Skids. 'In lieu of the requirements of this paragraph, CP&L will use means as determined by responsible plant technical, personnel needed to provide adequate protection of the items in storage.
k) Paragraph 4 Shipping - Requirements of paragraph 4, Shipping, primarily applies to the vendor. Plant functions with regard to return shipments will meet or exceed the methods of the vendor for the item or approved alternatives.
- 1) Paragraph 5.2.1, Shipping Damage Inspection: Warehouse personnel will normally visually scrutinize incoming shipments Eor damage of the types listed in this paragraph; this activity is not necessarily performed prior to unloading. Since required items receive the Item inspection of Paragraph 5.2.2, separate documentation of the Shipping Damage Inspection is not necessary. Release of the transport agent after unloading and the signing for the receipt of the shipment may be all of the action taken to document completion of the Shipping Damage Inspection. Any nonconformances noted will. f'ra&34>t.
~ be documented and dispositioned as required by FSAR Section )7.~M The ~ugC person performing the visual scrutiny during unloading is not considered to be performing an inspection function as deEined under Regulatory Guide 1.74; therefore, while he will be trained and qualified to perform this function, he may not necessarily be certified (H45.2.6) as an Inspector.
m) Paragraph 5.2.2, Item Inspection'. The need and extent Eor inspection oE items wilL be determined by responsible plant technical personnel. Receiving inspections shall be performed in an area designated Eor receipt oE material and shall normally be performed in the receiving building.. The receiving building and the areas designated will provide adequate protection for the material, but may not comply with all of the specific requirements contained 1.8-50a Amendment No. 41
SHNPP FSAR
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areas I shall be recorded. Unloading or I pick-up of materiaL shall not be
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u considered "access," u t nor shall inspection by NRC or other regulatory agents,
~ ~
nor shall tours by non-CP&L employees who are accompanied by CP&L employees.
y) Paragraph 7.3 Hoisting Equipment - The load'chart for each crane includes the'odel number Eor that crane. This load chart is considered to by the manufacturer Eor that crane as required by be'Certification" paragraph 7.3.1. Likewise, Eorklifts are considered certiEied by the manufacturer's Literature giving maximum capacity as required by paragraph 7.3.2.
Paragraph 7.3, Hoisting Equipment: Rerating of hoisting equipment will be considered onLy when absoLutely necessary. Prior to performing any lift above the load rating, the equipment manufacturer will be contacted for his approval and direction. The manufacturer will be requested to supply a document granting approval for a limited number of lifts at the new rating and any restrictions invoLved, such as modifications to be made to the equipment, the
'number of'lifts to be made at the new rating, and the test lift Load. At all times, the codes governing rerating oE hoisting the equipment wiLL be complied withe If rerating of hoisting equipment is necessary and CP&L cannot or does not contact the equipment manufacturer as described above, the test 'weight used in temporarily rerating hoisting equipment Eor special lifts will be at least equal to 110 percent of the lift weight. A dynamic load test over the full range of the lift using a weight at. least equal to the lift weight will be FreL~e.) C.l v,ample z) Paragraph 7.4 ~h Inspection of Equipment and gigginp Nondestructive examinations, will be performed by ~/QC personnel qualified in accordance with Regulatory Guide 1.58 (except as amended by saEety analysis report position). Operators will be trained in the operation and maintenance inspections of their assigned equipment.
aa) Appendix A.3.5.1 Caps and Plugs; A.3.5.2, Tapes and Adhesives; and A.3.6.3, Desiccants Plugs, caps, tapes, a'dhesives, desiccants, markers and other temporary. items will be of commercial quality. Levels for halogens, sulfur, chLorides, low meLting point metal., etc., for use on stainless steel and nickel alloy surfaces will be as determined by the responsible technical group t'o 1'imit or'reclude intergranular cracking and stress corrosion cracking.
Reference:
Section 17 A-3 ProPoseJ Cfaa,a@F. IOo 1.8-50d Amendment No. 41
SHNPP FSAR Regulatory Guide 1.39 HOUSEKEEPING REQUIREMENTS FOR WATER COOLED NUCLEAR POWER PLANTS (REV. 2)
Carolina Power 6 Light Company complies with the requirements of ANSI N45.2.3-1973 as endorsed by Regulatory Guide 1.39, September 1977, with the following clarifications for.')
Paragraph 2;1, Planning.'he zone designations provided in the, standard will be used as a guide in developing plant procedures>
however, plant areas will not necessarily be divided into Zones I through V. Equivalent controls will be maintained as prescribed in approved procedures.
- 2) Paragraph 3'.5, Surveil.lance, Inspection, and Examinations:
Subparagraph (1) is not applicable during normal operations but will be implemented if large items are to be moved or handled.
FSAR Reference. 'Section 17.+3 PCohS~cf ( hnuCe +((
Amendment No. 41
SHNPP FSAR Regulatory Guide 1.54 QUALITY ASSURANCE REQUIREMENTS FOR PROTECTIVE COATINGS APPLIED TO WATERWOOLED NUCLEAR POWER PLANTS (REV. 0)
Regulatory Guide 1.54 endorses ANSI N101.4-1972. The SHNPP project complies with the requirements of ANSI N101.4-1972, as it is endorsed by thi's guide for protective coatings for containment surfaces (steel and concrete) and exposed surfaces of large equipment and pipe.
Reference:
Section 17K-3 1.8-67 Amendment No. 5
SHNPP FSAR PropmS4.ct Chmslt-E I 2g Regulatory Guide 1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, EXAMINATION AND TESTING PERSONNEL (REV. 1)
TI4 seer KPttc I tnp44 ~
carolina Power & Light Company shall comply with ANSI N45.2.6-1978, with the following clarifications:
a) With regard to Paragraph 1.2 of ANSI N45.2.6-1978 titled requirements of this guide to those personnel who are involved in the daily operations of surveillance, maintenance, and certain technical and support services whose qualifications are controlled by Section 6 of the Technical Specifications. or are controlled by other QA Program commitment requirements.'nly personnel in the following listed categories will be required to meet ANSI N45.2.6-1978 requirements'(1) Nondestructive Q
personnel.. Prof'< Chap = I:3 b) The fourth paragraph of Paragraph 1.2 requires that the Standard be imposed on personnel other than CP&L employees. The applicability of the Standard to suppliers and contractors will be documented and applied as specified in the procurement documents for each supplier and contractor.
c) With regard to Paragraph 2.5 of ANSI N45.2.6-1978 titled ~Ph sical:
Carolina Power & Light Company will implement the requirements of this Section with the stipulation that, where no special phys'ical characteristics are if
'C required, none will be specified. The converse is also true. no special physical requirements are stipulated by CP&L, none are considered necessary.
Carolina Power & Light Company employees receive an initial physical examination to assure satisfactory physical condition; however, only the following listed personnel will receive an annual examination'. (1) NDE personnel and (2) inspection personnel. This annual
- examination shall. consist of the near visual acuity using the standard Jaeger's type chart or equivalent test.
Prolapse/ Cha,~c E. {Z d) With regard to Paragraph 3 of ANSI N45.2.6-1978 titled s
will be grouped in levels o'f capability and certified for inspection, review, and evaluation of inspection data, and reporting of inspection and test =
results. Inspection personnel are qualified based on preestablished experience, education, on-the-job training, written examinations and proficiency tests associated with the specific activity. Proficiency tests are given to personnel performing independent %Pcs'QC inspections and documented acceptance criteria are developed to determine if, individuals are properly trained and qualified. Certificates of qualification delineate the functions personnel are qualified to perform. Qualification records are m'aintained and performance evaluations conducted at least on an every three year basis.
~Co Po5CJ C.)i~gr g l3 1.8-71 Amendment No. 41
tj Pro osed Chan e 12A Insert Attachment The NRC provided notification for withdrawal of this .
Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
SHNPP FSAR Pro PoS~J Chc Oar I'I Regulatory Guide 1.64 QUALITY ASSURANCE REQUIREMENTS FOR THE DESIGN OF NUCLEAR POWER PLANTS (REV. 2) muser+ hTTo.egmmv~ H Carolina Power 6 Light Company shall comply with ANSI Standard N45.2.11-1974 FSAR
Reference:
FSAR Section 17./ 3 Pro Fos~J Cha.~a~
1.8-79 Amendment No. 5
Chan e 14 Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
SHNPP FSAR Regulatory Guide 1.'74 QVALITX ASSURANCE TERMS AND DEFINITIONS (REV. O)
The SHNPP project complies with this guide as described below:
Regulatory Guide 1.74, Quality Assurance Terms and Definitions, endorses ANSI N45.2.10-1973.
Carolina Power & Light Company complies with the requirements of this guide with the following clarifications:
a) Carolina Power & Light Company reserves the right to define additional words or phrases which are not included in this Standard. Such additional definitions will be documented in appropriate procedure's, manuals, etc.
b) In addition to the Standard's definition of "Inspection," CP&L will use the following: "Inspection (when used to refer to activities that are NOT performed by quality organization personnel) Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel performing these functions are not necessarily certified to ANSI N4S.2.6."
When CP&L intends for Inspection to be performed in accordance with the QA Program by personnel certified as required by that Program and for activities defined by "Inspection" in ANSI N45.2.10, appropriate references to the plant quality organization which will perform the activity and/or to Quality Procedures to be used for performing the .activity will be made. Zf such references are NOT made, 'inspections are considered under the additional definition given above.
c) In addition to the Standard's definition of "procurement documents,"
CP&L will utilize the definitions given in ANSI N45.2.13 and in Regulatory Guide 1.74. The compound definition, Procurement documents Contractually binding documents that identify and define the requirements which items or services must meet in order to be considered acceptable by the purchaser.
They'nclude documents which authorize the seller to perform services or supply equipment, material or facilities on behalf of the purchaser (e.g.
contracts, letters of intent, work orders, purchase orders, or proposals and their acceptance, drawings, specifications, or instructions which define requirements for purchase).
ram Deficiencies" (Not defined in ANSI'45.2.10, but used and defined differently n re to de vel opp 'ment doc or implement effectively any applicable element of the Q rog e) "Quality Assurance Program Requirements" (Not defined in ANSI N45.2.10, but used and defined differently in ANSI N45.2.l3) Those individual requirements of the QA Program which, when invoked in total or in part, establish the requirements to the quality assurance program for the controlled. Although not specifically used in the Operational QA activity'eing Program, ANSI N45.2 may be imposed upon CP&L's suppliers.
f) "Independent Verification" Verification that required actions have been completed by an individual other than the person who performed the operation or activity being verified. Such verification will not require 1.8-93 Am('ndlll( ll l No ~
~
SHNPP FSAR confirmation of the identical action when other indications provide assurance or indication that the prescribed activity is in fact complete. Examples include, but are not limited to: verification of a breaker opening by observing remote breaker indication lights; verification .of a set point (made with a voltmeter or ammeter for example) by observing the actuation of status or indicating Lights are the required panel-meter indicated value; verification that a valve has been positioned by observing the starting or stopping of flow on meter indications or by remote valve position indicating lights.
"Audit" (Will be a modification of the word to allow the use of 41 ) subjec 'idence if available as defined in Paragraph 1.4 of ANSI N45.2.12-1 Paragraph 1.4.3 of ANSI N45.2.23-1978 as opposed to the definition given in ANSI 10-1973 A documented activity performed in accordance with written procedures cklists to verify, by examination and evaluation of objective evidence where avai that applicable elements of the quality assurance program have been developed, doc ed, and effectively implemented in accordance with specified requirements. An au 1 uld not be confused with surveillance or inspection for the sole purpose of contro product acceptance.
ProPoSel ('ham(~a+ l4 1.8-94 Amendment No. 41
SHNPP FSAR Proposed Chammy 14 +
Regulatory Guide 1.88 COLLECTION, STORAGE AND MAINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS (REV ~ 2)
Z serT Company shall comply with WT~'li(nag'arolina Power 6 Light ANSI N45.2.9-1974 with the following clarifications.
a) Appendix A of ANSI N45.2.9 is not considered to be a. mandatory, list.
This list will be used as a guideline for classifying those documents that need to be maintained as QA records. QA concurrence will be required when the determination is made as to whether a particular type of document need's to be classified as a QA record and its appropriate retention period.
b) Paragraph 1.4, Definitions: The phrase "when the document has been completed" is clarified to mean when the document has received the final.
review performed by the organizational element responsible for generating or collecting the records or by QA department personnel for those documents which require QA review prior to transmittal to Project Document Services for permanent storage. In the case of a record package (Plant Change Request, Equipment Qualification, etc.) made up of several individual documents, the .
package will be considered to be the document for the purpose of determining when the document is complete.
c) Paragraph 3.2.1,.Generation of Quality Assurance Records: The phrase "completely filled out" is clarified to mean that sufficent information is recorded to fulfill'he intended purpose of the record.
d) Paragraph 3.2.2, Index'The storage location will be delineated in procedures in lieu of in the Index. The specific location of a record "within a storage area" is del'ineated by a computerized indexing system plus a storage area labeling system which provides information by record type and storage medium.
e) Paragraph 4.2, Timeliness:- Carol.ina Power 6 Light Company's contract'ual agreement with its contractors and suppliers will constitute fulfillment of the requirements of this paragraph.
f) Paragraph 5.4, Preservation: The following clarification is substituted for the current subparagraph 5.4.2: "Records shall not be stored loosely.
They shall be secured for storage in file cabinets or on shelving in containers." The following clarification is substituted for the current subparagraph 5.4.3: "Appropriate= provisions 'shall- be made for-special processed records (such as radiographs, photographs, negatives, microfilm, and magnetic media) to prevent or minimize damage from excessive light, stacking, electromagnetic fields, temperature and humidity, etc. Manufacturer's recommendations will be considered as appropriate."
g) Paragraph 5 ~ 5, Safekeeping: Routine general office and,nuclear site security systems and access controls are provided. No special securi'ty systems are required to be established for record. storage areas.
"'h) Paragraph 5.6, Facility: This paragraph provides no distinction between temporary and permanent facilities. To cover temporary storage, the following clarification is added: "Complete records may be stored in one-hour fire 1.8-118 Amendment No. 41
Pro osed Chan e 16A Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
SHNPP FSAR rated file cabinets until transmitted for permanent storage. In general, records shall not be maintained in temporary storage for more than three months after completion. Any exceptions to this requirement must be justified, evaluated and approved by the and documented. A list of exceptions shall be maintained and available for NRC review. Exceptions may include records needed on a continuing basis for an extended period of time at the location of the work group responsible for 41 generating the records and records which are cumulative in nature and could best be turned over for storage for a designated period of time.
41 [ i) Paragraph 5.6, subparagraph 3, is clarified to require a two-hour minimum. fire rating to be consistent with the 1979 version of the Standard .and
- - NRC Criteria for Record Stora e Facilities (Guidance ANSI N45.2.9, Section 5.6) issued 7 1 80.
41 l j) Paragraph 5.6, subparagraph 9, is clarified to read: "No pipes or penetrations except those providing fire protection, lighting, temperature/humidity control or communications are to be located within the facility. All such penetrations shall be sealed or dampened to comply'ith a minimum two-hour fire protection rating." t
~) Add) fi'o~eL. g~ri f'i'cw~~'ou&kor Qp Wco+S Qf e. provided i~ M~f~'o4 ~1S 41 P(o Fbmcl ChagCg )'7 Proton@. Cl,~- (g I
ViCe. frest JeP-Po.re)5 Huclaa< Pmggc,~
>~ ~+~ewT o~ h'a desl~wee.
'1. 8-118a Amendment No. 41
SHNPP FSAR Regulatory Guide 1.116 ,QUALITY ASSURANCE REQUIREMENTS FOR INSTALLATION, INSPECTION, AND TESTING OF MECHANICAL EQUIPMENT AND SYSTEMS (REV. 0-R)
Carolina Power & Light Company complies with the requirements of ANSI N45.2.8-1975 as it is endorsed by Regulatory Guide 1.116, Revision O-R, June )976, with the following clarifications:
a) Paragraph 2.1, PLanning.'Requirements, as determined by responsible plant management, will be incorporated into procedures.
b) Paragraph Pca ~ C 2.3, Results, a) will be impl'emented as set forth in Sections 17 , , . and by compliance with R.G. 1.33.
9.
c) Paragraph 2.8, Measuring and Test Equipment - CP&L has addressed this 41
'requirement for the operationaL phase of the plant in Section 17.~
P Cfear~ + IQ d) Paragraph 2.9, Prerequisites, references requirements of other standards. Carolina Power & Light Company has addressed applicable standards in the appropriate sections of the FSAR in lieu of the requirements of this paragraph. The extent to,which this paragraph applies will be determined by responsible plant management based on end use and complexity of the item.
e) Paragraph 3.3, Processes and Procedures: "Approved instructions" are interpreted t'o include vendor manuals. These manuals are not normally approved by CP&L; however, CP&L does review the applicable portions of these manuals for acceptability'towards the work being planned/done. The applicabLe requirements of vendor manuals are incorporated into CP&L procedures.
f) Paragraph 4.6, Care of Items.'This wiLL be done as outlined in the )
position on Regulatory Guide 1.38. 4L')
Paragraph 5, including subparagraphs 5.1 through 5.4, Installed Systems, Inspections and Tests: Responsible plant management wiLL determine the extent 41 to which the elements in this- paragraph are. applied when developing test requirements for inclusion in modification procedures. In some cases, testing requirements may be met by post-instalLation surveillance testing in lieu of a special post-installation test.
1.8-147 Amendment No. 41
SHNPP FSAR ProPosed Cha~se i%A Regulatory Guide 1.123 QUALITY ASSURANCE REQUIREMENTS FOR CONTROL OR PROCUREMENT OF .ITEMS AND SERVICES FOR NUCLEAR POWER PLANTS (REV. 1)
Carolina Power & Light Company shall comply with the requi.rements of ANSI N45.2. 13-1976 with the following clarifications.'roPoS C4 a) Paragraph 1.2 ' urchaser's Responsibilities: Item c is one of the options which may used by CP&L to assure quality; however, any of the options given i OCFR50, Appendix 8, Criterion VII as implemented by
- 17. may also be used. Evaluation of supplier's QA
'epending
'ections program will be conducted on complexity. and end
% Pn Poseef Cha~az ~
b) .Paragraph 3.1, Procurement Document Preparation, Review and Control Change: The changed document may not always be as reviewed by the originator',
however', at least an equivalent level shall review and approve any changes.
c) ,Paragraphs 3.2.3, 3.2.4, and 3.2.6 - CP&L does not consider that these paragraphs or vendor qualifications apply for the procurement of off-the-shelf items. Off-the-.shelf items (which include original as well as spare end replacements) are commercial grade items which are'.
- 1) Not subject to design or specification requirements that are unique to facilities or activities licensed by the Nuclear Regulatory Commission; and
- 2) Used in applications other than facilities or activities licensed by the Nuclear Regulatory Commission; end descriptions
- 3) Ordered from the manufacturer, distributor, supplier or retailer on the basis of the manufacturer's catalog or product quality veri fication requirements shall be determined, as necessary, 'pecial by responsible technical group to assure accceptability of the item. The responsible technical organization will review purchase requisitions of items classified as "off-the-shelf" to assure proper application of the above
'criteria')
Paragraph 3.3 requires procurement documents to be reviewed prior to bid or award of contract. The documented review of procurement documents is provided through review of the procurement specification and purchase requisition by the responsible technical organization prior to bid or award of contract.
e) Paragraph 3.4, Procurement Document Control: Carolina Power & Light Company will meet the requirements of Sections 17. . . . in .lieu of the requirements specified in this paragraph.
ProFosec< Cha.AGE, 2,0 f) 'aragraph 4.2, Selection Measures, outlines certain methods acceptable for the selection of suppliers. Carolina Power & Light Company's history of using similar methods hes proven adequate in the procurement of items; therefore, CP&L wishes to replace paragraph 4.2(a), (b), and (c) with the following selection methods:
1.8-155 Amendment No. 43
Pro osed Chan e 19A Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
SHNPP FSAR g) Paragraphs 5.2 and 5.3 shall be applied to the extent determined by
. responsible plant management based on complexity oE the item and its end I use.a It is not intended that these paragraph's be applied to spares or replacement parts that do not change original design intent.
I t Pos ACUTE +22
) paragraph 6. i, General; outi ines methods for monitoring and eveiuating supplier performance. Carolina Power & Light Company wishes to replace paragraph 6.1(a), (b), (c), (d), and (e) with the following methods for moni toring and evaluating supplier performance'.
- 1) Reviewing documents generated or processed during activities fulfilling procurement requirements.
- 2) Reviewing LER's. f'r< @cd ( hnWC~G +2.D
- 3) Periodic, audits
- 4) . Annual evaluat,ions
+P-.~
3
- 5) Those controls specified in FSAR Section 17.
i) . Paragraph 6.4, Control of Changes in Items or Services: Since ANSI N45.2 does not apply to the operational phase, equivalent controls outlined in ANSI N18.7"1976 will'e used in lieu of the requirements of ANSI N45.2, Section 7.
pl'aPoECeh ChaQC~& + 2Q
.j) Paragraph 7.4, Heasuring and 'I'est Lqui pment, out l ines certain measures to be taken. Carolina Power 6 Light Company for the operating phase has addressed the topic of measuring and test equipment in Section 17.~ in lieu of the requirements in this paragraph.
k) Paragraph 8 provides guidance for purchaser review and disposition of vendor nonconformances. CPKL, as purchaser, requires as a minimum deviations to procurement documents and previously approved siippl ier documents that cannot be brought into conformance prior to shipment of the material to be submitted to CP6L for approval. Such deviations, when approved by purchaser, are required to be submi tt ed along with shipment of the material .
Additionally, paragraph 8.2, Disposition. the third sentence of item b is revised to read:
Nonconformances to =the contractural procurement requirements or Purchaser approved documents which consist of one or more of the folLowing shall be submitted to the Purchaser for approval oE the recommended disposition prior to shipment, when the nonconformance could adversely affect the end use oE a'-"module or shippable component relative to safety, interchangeability, operabil,ity, reliability, integrity, or maintainability:
I) 'I'echnical or material requirement is violated;
- 2) Requirement in Supplier documents, which have been approved by the Purchaser, is violated; 1.8-157 Amendment No. 43
SHNPP FSAR
- 3) Nonconformance cannot be corrected by continuation of the original manufacturing process or by rework; and/or
- 4) The item does not conform to the original requirement, even though the item can be restored to a condition such that -the capability of the item to function is 'unimpaired.
- A module is any assembly of interconnected components which constitute an identifiable device, instrument, or piece of equipment. A module can be disconnected, removed as a unit, and replaced with a spare. It has definable performance characteristics which permit it to be tested as a unit. A module could be a card or other subassembly of a larger device, provided it meets the requirements of this definition.
- 1) Regulatory Position,C.3 indicates that purchaser should verify the implementation of the supplier's corrective action systems when such a system is required, but this verification need not be included as part of the purchaser's corrective action measures. Carolina Power 6 Light Company interprets this statement to mean that once corrective action has been verified by purchaser on nonconforming vendor items, the items can be released for use in its intended application. The cause and action to preclude recurrence of deficiencies is the responsibility of the vendor, and independent verification of such vendor action by purchaser or vendor notification of such action to purchaser, is not required on the basis that the vendor's QA program has been accepted by the purchaser. The QA program provides for determining cause and action to preclude recurrence on significant deficiencies, and purchaser audits are conducted to ensure vendor's compliance with his accepted QA program commitments. In addition, CP6L will provide overview of those causes and corrective action activities associated with items of high volume and which are considered significant to s ety in cases where vendor's recent performance
-has appeared marginal. P(e f'~seel CLe~C ". 23 m) Paragraph '10.2a: CPSL will comply with this paragraph to the extent that for non-Code items, certificates of compliance will be traceable only to the purchase order and not to the specific item.
1.8-158 Amendment No. 5
SHNPP FSAR i'foPo~ecl Cl avae 236 Regulatory Guide 1.144 AUDITING 'OF QUALITY ASSURANCE PROGRAMS FOR
/
< SC.r NUCLEAR POWER PLANTS (REV. 0)
ATTo.C'4mB 6 I rolina Power & Light Company shall comply with requireraents of Regulatory Gu de 1.144, January 1979, which endorses ANSI N45.2.12-1977 with the fol wing clarifications.
a) 3.(b)(2): The concepts of when audits are required, i.e., annually, triennia ly, will be complied with; however, such audits would only be required the vendor if the vendor is involved with an active contract/pr curement document. This concept is as discussed in Paragraphs 3.5.3.1 and 5.3.2 of ANSI N45.2.12-1977.
b) Paragraph .3, Training: The training of CP&L audit personnel will be accomplished as scribed in CP6L's position on Regulatory Guide 1.14'6.
c) Paragraph 2.4, aintenance of Proficiency: The maintenance of of CP&L a it personnel will be accomplished as described in 'roficiency CP&L's position on Regu tory Guide 1.146.
d) Paragraph 3.2.2 indi tes that ob)ective evidence is to be examined and evaluated. Carolina Power 6 Light Company believes that the use of subjective evidence is also an important lement of the audit program. See Paragraph 4.3.2 clarifications below.
e) Paragraph 3.3, Essential Ele ents of the Audit System; Carolina Power &
Light Company will comply with subp agraph 3.3.5 as (subparagraph 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4:
it was originally written
~cu'if J
~hrradi "Provisions for reporting on the effecti eness of the quality assurance
~Posii'i d program to the responsible manageraent." r the auditing organization (CP&L),
effectiveness is reported as required by th Technical Specifications and by od Res. CP&L's Performance Evaluation Unit. Other t n audit reports, CP&L may not directly report on the effectiveness of the qu ity assurance programs.to the GLtlJ 9. audited organization, when .such organizations a outside of CP&L.
Subparagraph 3.3.7 requires verification of effecti e corrective action on a "tiraely basis". Timely basis is interpreted to mean ithin the period of time that is accepted by the organization. Each finding re uires a response and a corrective action. completion .date. These dates are sub ct to revision (with the approval of the quality organization) and must be esc lated to higher authority when there is a disagreement between the audited nd the auditing organization on what constitutes "timely corrective action."
f) Paragraph 4.3.1, Preaudit Conference: Carolina Power & Li ht Company will comply with the requireraent of this paragraph b'y inserting e word
. "Normally" at the beginning of the first sentence. This clarifica on is required because, in the case of certain unannounced audits or audit of a particular operation or work activity, a preaudit conference might in rfere with the spontaneity of the operation or activity being audited.
cases, persons who should be present at a preaudit conference may not al ys In't er be available. Such lack of availability should not be an impediment to beginning an audit. Even in the above examples,,which are not intended to 1,8-182 Amendment No. 5
Pro osed Chan e 23A Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
Pro osed Chan e 24 nsert for Re . Guide . 44 CP&L shall comply with the requirements of ANSI N45.2.12(1977) for external (vendor and supplier) audits.
Assessments of internal activities shall be accomplished as outlined in Section 17.3.3.
SHNPP FSAR all inclusive, the material set forth in Paragraph 4.3.1 will normally be vered during. the course of the audit.
Pr~POSC C4IJQL=
g) Paragraph'I 4.3.2, Audit Process:
'I Subparagraph 4.3.2.2 could be interpreted to limit auditors to the re iew of only objective evidence. Sometimes objective evidence may not be vailable; therefore, Carolina Power & Light Company will comply with an a ernate sentence which reads: "When available, objective evidence shall examined for compliance with quality assurance program requirem nts. If subjective evidence is used (e.g., personnel interview direct observations by the auditor), then the audit report or checklis must indicate how the evidence is obtained."
- 2) Subparagr h 4.3.2.4 is modified as follows to take into account the fact that s e nonconformances are virtually "obvious"-with regards to the needed cor ctive action. As a result of this, CP&L proposes the following alternate words: "When a nonconformance or quality assurance program deficiency i identified as a result of an audit, unless the apparent cause, exten and corrective action is readily evident,,
further investigations all be conducted by the audited organization in
'fan effort to identify the cause and effect and to determine the extent the corrective action r quired."
- 3) Subparagraph 4.3.2.5 con ins a statement "acknowledged by a member of the audited organization". is is clarified to mean that "a member of the audited organization has en informed to the findings.
Agreement or disagreement with a nding may be expressed. in the response from the audited organizat n."
- 4) Subparagraph 4.3.2.6 is modified follows to account for the fact that immediate notification is not alway possible: "Conditions requiring immediate corrective action (i. , those which are so severe that any delay would be undesirable) shall e reported as immediately as practical to management of the audited organ ation."
h) Paragraph 4.3.3, Post Audit Conference: Caroli Power & Light Company will substitute and -comply with the following paragraph : "For all external audits, a postaudit conference shall be held with manage nt of the audited organization to present audit findings and clarify misunde standings. Where no adverse findings exist, this conference may be waived by anagement of -the audited organization. Such waiver shall be documented in the udit report.
For all internal audits unless unusual operating or maintenanc conditions preclude attendance by appropriate managers/supervisors, a post udit conference shall be held with managers/supervisors.'f there are o adverse findings, management of the internal audited organization may waive he postaudit conference. Such waiver shall be documented in the audit port.",
'I i) Paragraph 4.4, Reporting:
- 1) This paragraph requires that the audit report shall be signed by>
the audit team leader which is not always the most expeditious route f the audit report to be issued as soon as practical. Carolina Power &
Light Company will comply with Paragraph 4.4 as clarified by the 1.8-183 Amendment No. 5
SHNPP FSAR following words: "An audit report, which shall be signed by the unit team leader, or his supervisor in the absence of the audit team leader shall provide:" In cases where the audit report is not signed by the Lead Auditor due to his absence, the record dopy of the report must be igned by the Lead Auditor'upon his return. The report shall not r uire the Lead Auditor's review/concurrence/signature if the Lead Aud or is no longer employed by CP&L at the time audit report is issue
- 2) Car ina Power & Light Company will comply with subparagraph 4.4.3 clarified read: "Supervisory level personnel with whom significant discussions re held during the course of preaudit (where conducted),
audit, and pos audit (where conducted) activities.
- 3) Audit report may. not necessarily contain an 'evaluation statement regarding the effec veness of the quality assurance program elements which were audited, a required by subparagraph 4.4.4, but they will provide an effectivenes summary of the audited areas." 7
- 4) Subparagraph 4.4.6 will determine the need for audit reports to include recommendations f corrective actions.
j) Paragraph 4.5.1, By Audited Orga will 'comply with the following ization: (hrolina Power & Light arification of this paragraph:
Company "Management of the audited organization o activity shall review and investigate all adverse .audit findings, as ecessary, (cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence. They shall respond, in wr ing, within thirty days after the date of receipt of the audit report. The re onse shall clearly state the corrective action taken or planned to prevent recu ence and the results of the investigation if conducted. In the event that c rrective action is not completed by the time the response is. submitted, the dited organization's response shall include a scheduled date for completion planned corrective action. A follow-up response shall be provided stating t corrective action was completed. If corrective actions are verified as satis actorily completed by the quality organization prior to the scheduled completion date or when completion of corrective action can be verified during a folio up audit, no follow-up response is required. The audited organization shall ke appropriate action to assure that corrective action is accomplishe as scheduled."
k) Paragraph 5 Audit checklists are not considered QA records. CP believes that. actual audit reports provide sufficient detail to substanti e the results of the audit, and the checklist is maintained as an audit "tool versus a QA. record. Additionally, the audit checklist need only document obgective evidence examined to support the audit findings.
1,8-184 Amendment No. 5
SHNPP FSAR ro Posecj Ch oQ < 6 Regulatory Guide 1.146 QUALIFICATION OF QA PROGRAM AUDIT PERSONNEL
/ FOR NUCLEAR POWER PLANES (REV. Op 8/80)
Z o='e.~T ATTa.mme,d t Carolina Power 6 Light Company shall comply with requirements of Regulatory 1.146, August 1980, <with the following 'uide clarifications.
d'or oxiorNcLL(Yscc*r ceo) SccppLior ocr' Paragraph 2.2, Qualification of Auditors: Subparagraph 2.2.1 references an I B45.2 (presumed to be N45.2); therefore, CP&L will comply with an alter'na subparagraph 2.2.1 which reads:
ProPoSCJ "Orientation to p ide working knowledge and understanding of the,CPSL QA Program, including th SI standards and Regulatory Guides included in the C)1a,AGE Program, and CP6 L's proce s for implementing audits and reporting results."
b) Paragraph 4.1, Organization Re nsibility: Carolina Power 6 Light Company will comply with this Paragraph the substitution .of the following sentence in place of the last sentence in the ragraph.
"The Manager Corporate Quality Assurance, Principal Specialist Performance Evaluation Unit or Lead Auditor shall, prior to mmencing the audit, assign personnel who collectively have experience or tra g commensurate with the scope, complexity, or special nature of the ac r ties to be audited."
Paragraph 5.3, Updating of Lead Auditor's Records: (hrolina Power 6 Light Company will substitute the following sentence for this Paragraph:
c "Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Paragraph 3.2.c
~ F'Pcosc g Choocso 0 o acraLck'icWiocJ oV cubi'c=c'uoL Nlo0orccloA'SsessrcceNY PoesoroasL Sho LL ioo aco corcc oL lshcc J os coQYLi NscI IN SeCTre 0 l7 3- B bCXSQ OIJ QOCdllbld O.k3CI CMPBCIBtJ CQ lieo>ooc to c.vocLu.ofe- the ooT'vlVv be'ccrc Cls e sed.
ProLse3 chute,e >
~S'.8-186 Amendment No. 5
Pro osed Cha e 24A Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) 'because it has become obsolete.
SHNPP FSAR e fire protection QA pt'ogram, which is under the management control of the ~ ",t QA o nization, has assured the satisfaction oE QA guidelines during the design, curement, installation and acceptance testing of fire protection equipment an stems provided for the plant and will assure their continued testa maintenance and administrative control after the plant 'nspection, becomes operational.
As part of their management con l, the QA organization has'$ <<P<ndcdecf
~ ""'"
e) Fire Protection Procedure The organization, training and equipping of all personnel who might be involved in adequate responses to fire emergencies at the plant, including operating personnel,.security forces, fire brigade members, visitors and local outside Eire department members, are described in detaiL in the Fire Protection Procedure (FPP). Salient features of the FPP are described below. Procedures providing for a Eire brigade, the 20 minimum equipment to be provided them, and necessary drilling of the brigades as per IAW BTP CMEB Section C.3 will be deveLoped.
The purpose of the FPP is to assure effective responses .to Eire emergencies can be made. To accomplish thi.'s, the FPP covers:
- 1) The periodic maintenance and testing of fire protection equipment and systems to ensure operational capability at all times,
- 2) The continuing fire response training, by instruction and drills of members of the fire brigade,
- 3) The fundamental Eire prevention and fire response education of all. members of each shift crew and of support plant personnel, 4)'he training, through joint drills with the fire brigade and plant operators, of the local fire department to develop both Eamiliarity with their role in a plant-Eire response and awareness of special precautions they may have to take within plant areas, and
- 5) The coordination of the efforts of the security forces during a Eire emergency response.
~ h 9,5.1-56 Amendment No. 20
SHNPP FSAR b) Fossil Generation and Power Transmission Group - The Senior Vice president - Fossil Generation and Power Transmission Group reports to the Executive Vice President - Power Supply and is responsible for managing the Company's fossil and hydro-generating facilities and the Company's transmission line facilities necessary to meet its bulk power requirements.
The Group consists of five departments which report to the Senior Vice President - Fossil-Generation and Power Transmission Group: (1) the Fossil Plant Betterment Department, (2) the Fossil Operations Department, (3) the System Planning & Operations Department, (4) the Transmission Department, and (5) Fossil Fuel Department.
c) Co orat alit As urance De artment - The Manager of the Corporate Quality Assurance Department reports to the Executive Vice President - Power Supply and is responsible for quality control, quality assurance engineering, and vendor qualifications. The Corporate Quality Assurance Department is organized as follows: (1) the Quality Verification Section, and (2) the Quality Assurance Engineering Units at each plant and the corporate office; Their responsibilities are summarized below:
- 1) The Quality Verification Section is'responsible for supporting CP&L's nuclear plants in the areas of Quality Control inspections and vendor qualification/surveillance.
- 2) The Quality Assurance Engineering units are responsible for supporting CP&L's nuclear plants and the Nuclear Engineering Department in the areas of reviews and assistance in ensuring quality requirements are included in engineering and procurement documents.
d) uclear As e sment De ar men - The Manager of the Nuclear Assessment Department reports to the Executive Vice President - Power Supply and is responsible for evaluating the effectiveness of the production organization, identifying deficiencies to desired performance, and the verification of actions taken to eliminate such - ' There are four sections and one un t in the Nuclear Assessment Department: 1) Nuclear Assessment Corporate Section, 2) Project Assessment HNP, 3) Project Assessment RNP, 4) Project Assessment BNP, and 5) Quality Check and Administration Unit. The responsibilities are summarized below:
cle~ici eH e i es 1), The Nuclear Assessment Corporate Section is responsible for planning, scheduling, and coordinating Functional Area, Site, and Pffpg-~~ssl~~J Corporate assessments. The Nuclear Safety Review Unit as part of this
~Ch~u e. - section accomplishes. the independent-review -requirements described in the plant Technical Specifications.
- 2) The Project Assessment Section at each nuclear project is responsible for performing day-to-day assessments of plant activities.
These assessments include direct observation of work activities reviews of plant documents, and interviews with plant staff to gather data to be analyzed to provide feedback to management.
- 3) The Quality Check and Administration Unit has direct management responsibility for implementation of the Quality Check Program as outlined in the approved Quality Check Procedure and for providing administrative support for the department.
13.1.1-5 Amendment No. 43
SHNPP FSAR
.4.2
~ ~ INDEPENDENT REVIEW /~pe~~ ~l t4 ATT(Lc.kg An f-sz,te independent review program that conforms to the criteria of ANSI N18. 1976 has been established. The objective of the program is to provide corpor te management with an independent review and assessment of those aspects f plant operations which affect nuclear safety. The Nuclear Safety, ~
Review Un t of the Nuclear Assessment Department is responsible for this function.
The Nuclear S ety Review Unit is comprised of experienced personnel who, in general, have t e collective expertise and technical competence to review problems in the llowing areas:
N lear Power Plant Operations Nu ear Engineering Chem try and Radiochemistry Metal rgy Instrum tation and al Safety Control'adiology Mechanical and Electrical Engineering Administrate. e Control Seismic and E vironmental Quality Assur e Practices Looking more at the details of the view function, the following specific items are evaluated:
Plant procedure changes meeting 1 FR50.59 .review criteria, Plant design changes meeting 10CFR5 .59 review criteria, Licensing actions, Test or experiments not described in t e facility FSAR, Plant operational occurrences (LERs),
Regulatory, violations, Technical Specification changes, Nuclear Safety Review Committee meeting minu es, Conformance to regulatory requirements, such Plant Security and Emergency response program changes which dec ease effectiveness of the respective program, Quality Assurance Audx s conducted on site, and Any item deemed appropriate for review relative to fe operation.
Should an item arise where sufficient expertise is not avail le within Nuclear Safety Review Unit, the organization .has-the flexibil'i and authority to call on appropriate personnel to supplement the independent view ensuring satisfactory resolution of the item. The Nuclear Safety Review it organizational structure is shown in Figure 13.4.2-1.
Written records of independent reviews are prepared and retained as are periodic reports to corporate management that address safety-relate issues.
Pn) P(.>s~g gQ pcs @ ZR 13.4.2-1 Amendment No. 43
Pro osed Chan e 29 13.4.2 Inde endent Review The description of the independent review, program is
'ontained in Section 6.5, "Review and Audit" section of the Plant Technical Specifications..
SHNPP FSAR
- Qt A s 5 0 ~ IA 13.4.3 ~~'F PROGRAM e .purpose of corporate operational audits is to ensure an effective* means of revi ing and evaluating plant operational activities. The implementation and effects ness of the continuing QA Program shall be regularly assessed for compliance 'th 10CFR50, Appendix B, NRC Regulatory Guide 1.33, ANSI N18.7, and N45.2.
The corporate organi tion responsible for independent audit is the Nuclear Assessment Department. e objective of the department is to assess functions involved in the operation o the Company's nuclear plants to assure all levels of management that commitments Regulatory Guides and applicable, are being carried out and re latory requirements are being met. The technical'odes function is described in ANSI N18.7 a comprehensive system of planned and documented audits to verify compliance o controls and quality assurance programs.
ll aspects of the administrative Carolina Power & Light Company's principal means o chieving an effective, 30 safe nuclear plant is the Company's Corporate Quality urance Program (CQAP). The CQAP addresses design, operation, maintenance, and modification for the plant life. It covers procurement, design, and opera 'on associated with the fabrication and control of nuclear fuel. The role of t Quality Verification Services Section in, these programs is to assure that p edures '
are developed to implement each program and that these procedures are b followed.
5,e igdePqucteA <sse~smek> Proof'nrA lg.3 aV the. FSPg The following criteria are addressed in developing the audit requirements for Nuclear Assessment Department audits:
Plant Operating Manual and Procedures.
Plant Technical Specifications including the following minimum requirements.
The conformance of .facility operation to provisions contained within the Technical Specifications and applicable license conditions at least once per 12 months.
13.4.3-1 Amendment No. 43
SHNPP FSAR he, training and qualifications of the entire facility staff at least o e per 12 months.
The suits of actions taken to correct deficiencies occurring in unit equipm nt, structures, systems, or method of operations that affect nuclear afety at least once per 6 months.
The verifi tion of compliance with and implementation of the requirements of the quality assurance program to meet the criteria of Appendix "B", OCFR50, at least once per 24 months.
The Emergency Pl and implementing procedures at least once per 12 months.
The Security Plan an implementing .procedures at least once per 12 months.
The facility Fire Protects n Program and implementing procedures at least once per 12 months Any other area of facility ope tion considered appropriate by responsible management.
Commitments made in the plant FSAR.
SHNPP will be audited three to five times yea y. Nuclear fuel activities are audited annually. (Fuel suppliers are also sub cted to audits.) Additional audits may be requested by line or corporate mana ement if special problems are encountered.
The organizational structure for the Nuclear Assessme Department is shown in Figure 13.4.2-1. When necessary to augment an audit te , outside consultants or qualified Company personnel independent of the operat n being audited may be utilized.
The areas audited and the minimum frequency of the audits are listed below:-
Nuclear Fuel Section - Once per year.
Nuclear Fuel Supplier - Once during applicable time period cov red by purchase order or once every three years, whichever is shorter.
Q-List Modifications Performed by Plant Staff - Once per year.
Radwaste Transfer, Packaging, and Transport Activities - Once per yea Pro I oaecl CL~gq.,~ + P 13.4.3-2 Amendment No. 43
SHNPP FSAR uclear Engineering Department - Once per year.
Harri lant Quality Control - Once per year.
Vendor Equip nt Quality - Once per year.
Other than audit report the Nuclear Assessment Department communicates to Senior Management by a mon y report of QA audits conducted during the month, including a status of the acta items and their resolution. The Manager-Nuclear Assurance Department repo s to the Executive Vice President - Power Supply which provides direct communi tion. Discussions involve an overview of the Company's various organizational its'fforts in maintaining an effective QA program. In addition to these eetings, the Manager - Nuclear Assessment Department meets on a regular basis ith Department personnel to review activities. In addition to the formal au activities, the Nuclear Assessment Department Section is often called on by er 'Company members for interpretations of codes, standards, or other QA requir nt's. This contact is .in an advisory role identifying acceptable modes of ope ion and does not compromise the unit's independence Chaotic from line activities.
Pro paseJ 13.4.3-3 Amendment No. 43
Pro osed Chan e 31 Section 17.2 is being deleted in replaced with the attached 17.3.
its entirety. it is
ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT QUALITYASSURANCE PROGRAM DESCRIPTION (1437HNP.GLU)
17.3 HNP UALITY ASSURANCE PROGRAM DESCRIPTION MANAGEMENT It is the policy of Carolina Power & Light Company (CP&L) to operate and maintain nuclear power plants without jeopardy to its. employees or to the public health and safety.
This Quality Assurance (QA) Program and revisions are approved by the Executive .
Vice President - Power Supply.
The QA Program and procedures ap'ply to 'activities affecting quality. (e.g.,
operation, maintenance, modification, and refueling.) This program applies to individuals and organizations responsible for operating and supporting the nuclear plants'he program and procedures define responsibilities and authorities, prescribe measures for the control and accomplishment of activities for the operation of safety related, fire protection and radwaste structures, systems, and components and requires appropriate verification of conformance to established requirements. A list or system identifying items and activities to which this program applies is maintained at each nuclear plant or work location.
Controls and responsibilities for maintaining this list or system are prescribed in procedures.
This QA Program and implementing procedures shall be used and updated as necessary to assure that the Company's nuclear generating units are managed such that they will be operated and maintained in a safe manner.
Deviations from this program shall be permitted only upon written authority from the Executive Vice President - Power Supply.
The QA Program is founded on the principle that the line organization is responsible for quality and safety. Self-assessment practices are used to ensure the desired levels of quality and safety are achieved and maintained. There are three levels of assessment in CP&L. The first level is the line organization and consists of each individual being involved with plant performance to ensure the plant is operated in a safe, reliable, and efficient manner. The second level consists of the Nuclear Services Department, along with the functional area line organization, monitoring the plant operation and processes to ensure that performance goals are set and achieved for the three nuclear projects. The third level consists of the Nuclear Assessment Department (NAD) independently evaluating the performance and effectiveness of plant programs, processes, personnel, and the line organization's self-assessment. These activities are to detect deficiencies in the desired levels of performance and quality, reporting these conditions to Senior Management, and ensuring adequate action is taken to correct and eliminate these conditions.
17.3.1-1
<The CP&L organization responsible for the safe plant operation is described in Section 13.1 of the FSAR and in implementing procedures. The term "line organization" used in this program refers to .the production organization reporting to the Senior Vice President - Nuclear Generation Group.
Procurement documents require suppliers to operate in accordance with QA progiams which are compatible with the applicable requirements of the CP&L's QA Program and procedures where their services are utilized in support of plant activities.
17.3.1.3 Res onsibilit The primary responsibility for quality performance, including the identification and effective correction of problems potentially affe'cting the safe and reliable operation of the 'ompany's nuclear facilities, resides with the line organization.
The managers of functions involving nuclear fuel, engineering, and operations shall'assure that their personnel are adequately trained for their jobs and they have the experience and education required to carry out their assigned responsibilities. These managers shall ensure that adequate resources and procedures are available for correctly implementing the work activities to support this program.
Independent .insp'ections are conducted to verify specific critical quality attributes. Individuals performing these inspections have access to necessary information to ensure that activities and equipment meet established acceptance criteria.
The NAD shall independently monitor and assess the Company's nuclear programs on a continuing basis. The NAD performs assessments 'which incorporate the previous "QA audits". These evaluations are performance based w'ith emphasis on quality of the end product.
The Kanager -'AD shall review with the senior operating officer in the Company on a regular periodic basis the overall effectiveness of the Company's QA Program. He shall have access to the corporate management up to and including the President/Chief Executive Officer to resolve any quality or nuclear safety related concerns management level.
if the concerns cannot be resolved satisfactorily at a lower The results and effectiveness of the assessment organization and processes .in accomplishing its assigned objectives will be evaluated annually.
17.3.1-2
t 17.3.1.4
~ ~ ~ A~tthorit
/The program and procedures require that the authority and duties of persons and organizations performing activities affecting quality be clearly established and delineated in writing and that these individuals and organizations have sufficient authority and organizational freedom to:
a) Identify quality, nuclear safety, and performance problems.
b) Order unsatisfactory work to be stopped and control further processing, delivery, or installation of nonconforming material.
c) Initiate, recommend, or provide solutions for conditions adverse to quality.
d) Verify implementation of solutions.
17.3.1.5 Personnel Trainin and uglification Both on-site and off-site personnel within the CP&L organization and contract personnel, who perform activities affecting quality (implement elements of the QA Program) shall be indoctrinated and trained such that they are knowledgeable and capable of performing their assigned tasks.
Training programs and reviews ensure that proficiency of personnel performing activities affecting quality is achieved and maintained by training (formal &
OJT), examining, and/or certifying, as appropriate.
Personnel training and qualification records are to be maintained by responsible, management to ensure qualified individuals are assigned to activities affecting quality.
Personnel within the Operating organization performing duties of a licensed operator are indoctrinated, trained, and qualified as required by 10CFR55.
17.3.1.6 Corrective Action The primary goal of the CP&L corrective action program is to improve overall plant operations and performance by identifying and correcting root causes of equipment and human performance problems. Part of'this effort is directed toward encouraging individuals to voluntarily report events, near misses, and potential problems. It is the policy of CP&L to seek improvement in each nuclear plant's performance as well as in the performance of supporting departments.
Management will emphasize to all levels in the organization the importance of identifying and effectively correcting situations that can adversely affect human and equipment performance. An important aspect of this program is the assignment of qualified personnel to accurately evaluate equipment/human performance problems, implement appropriate corrective actions, and verify corrective action adequacy.
Management is responsible for fostering a positive environment that encourages the self-identification of adverse conditions and trends.
The program requires that an evaluation of adverse conditions such as conditions adverse to quality, nonconformances, failures, malfunctions, deficiencies, deviations, and defective material and equipment is conducted to determine need "
for corrective action.
Conditions adverse to quality are identified through inspections, assessments, tests, checks, and review of documents.
The program requires corrective action to be initiated to preclude recurrence of significant conditions adverse to quality.
Procedures require follow-up reviews, verifications, inspections, etc., to be conducted to verify proper implementation of corrective action and to close out the corrective action documentation.
The program outlines the methodology for resolution of disputes involving quality and nuclear safety issues, arising from a difference of opinion between identifying personnel and other groups.
Significant conditions adverse to quality a'r e reported to appropriate management for review and evaluation.
Periodic review and evaluation of adverse trends ar'e performed by the Plant Nuclear Safety Committee (PNSC).
17.3.1.7 Re ulator Commitments The operation of nuclear plants shall be accomplished in accordance with'the U.S.
Nuclear Regulatory Commission (NRC) Regulations specified in Title 10 of the U.S.
Code of Federal Regulations.
The operation of the Company's nuclear power plants shall be in accordance with the terms and conditions of the facility operating license issued by the NRC.
The program and procedures are designed to ensure compliance with the NRC Regulatory Guides and ANSI Standards applicable to the operations phase, and to which HNP is committed. The commitment to comply or alternatives for CP&L to follow are presented in .Section. 1..8 in this,FSAR. Where ever the requirements of this section conflict with the commitments to regulatory guides and codes and standards, the requirements of this section shall govern.
The Nuclear Regulatory Commission shall be notified of changes to the QA Program description in accordance with 10CFR50.54(a)(3).
17.3.1-4
17.3.2
~ ~ PERFORMANCE/VERIFICATION Personnel performing work activities 'are responsible for achieving the acceptable level of quality. =
Personnel performing verification activities are responsible for verifying the achievement of acceptable quality.
Work is accomplished and verified using instructions, procedures, or appropriate means that are of a detail commensurate with the activity's complexity and importance to safety..
Criteria that'define acceptable quality are specified in procedures and/or other documents, and verification, when required is performed against these criteria.
17.3.2.2 Desi n Control Procedures define requirements for the control of design activities associated with modifications of items that are safety-related.
Design changes are subject to appropriate controls which were applicable to the original design. CP&L may designate an organization to make design changes other than the organization which prepared the original design. In any case, CP&L will assure that the organization has access to pertinent background information, including an adequate understanding of the requirements and intent of the original design, and that the organization has demonstrated competence in applicable design areas.
Care shall be taken to assure that the design selected to accomplish a necessary or desirable change does not create "new" problems in off-normal modes of operation or in adjacent inter-tied systems.
Design changes made to the plant are accomplished in a planned and controlled manner in accordance with written, approved procedures. These procedures include provisions, as necessary, to 'ensure that:
a) "
Design documents (such as specifications, drawings, procedures and instructions) reflect applicable regulatory, performance, quality, and quality verification requirements and design. bases. . These documents are checked for accuracy and completeness by qualified individuals and reviewed to assure that documents are prepared in accordance with procedures.
b) There is adequate review of the suitability of materials, parts, equipment, and processes which are essential to the safety-re'lated functions of structures, systems, and components.
c) Materials, parts, and equipment which are commercial grade items or which
'ave been previously approved for a different application are evaluated for suitability prior to selection.
17.3.2-1
d) Design documents and procedures are controlled to reflect design modifications and "as-built" conditions.
/e) Internal and external design interfaces between organizations participating in modification activities are adequately defined and controlled, including the review, approval, release, and distribution of design documents and revisions.
The above controls are applied as necessary to such aspects of design as reactor physics; seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials; and accessibility for inservice inspection, ~
maintenance, and repair.
Any errors or deficiencies found in the design process or the design itself are documented and corrected, as outlined in the applicable department's corrective action program procedures.
Following completion of the design change/modification, controlled design change information is made available to affected personnel.
Training, on design changes/modifications that affect the operation of the plant, is provided to affected plant operating personnel.
Controls are applied to the development, content and use of computer codes to ensure (1) the codes are developed, documented, verified and certified for use per approved procedures; (2) the codes are properly controlled to'preclude use of outdated or obsolete codes; (3) that proper instructions concerning the use of the codes are provided; and (4) adequate QA provisions are implemented for the procurement of computer codes.
17.3.2.3 Desi n Verification Procedures require that the adequacy of design changes be verified by the performance of design reviews, alternate calculations, or qualification testing.
The control measures specified in the plan for control of design verification activ'ities are as follows:
a) Personnel responsible for design verification do not include the original designer or the designer's immediate supervisor unless the immediate supervisor is the only one capable of verifying the design.
b) Procedures identify the positions or organizations responsible for design verification and define their authority and responsibility. Procedures also provide guidelines as to the method of design verification to be used. Unless otherwise specified, design verification is performed by the method of independent design reviews and includes verification that SAR commitments have been addressed.
c) Qualification tests, or analyses when appropriate, shall assure that all modes of operation are not adversely affected by the design change.
17.3.2-2
'd) Design changes are reviewed to assure that design parameters are defined and that inspection and test criteria are identified.
/
e) Design verification is completed prior to relying upon the component, system or structure to perform its function.
17.3.2.4 Procurement Control'rocedures define requirements for the control of procurement documents and ensure that purchased material and services are of acceptable quality.
Potential contractors and suppliers are evaluated by Vendor and Equipment Quality Unit personnel prior to award of a procurement document when needed to assure the contractor's or supplier's capability to comply with applicable technical and quality requirements.
Carolina Power & Light Company maintains a program for supplier evaluation, results of. supplier evaluation, surveillance of suppliers, supplier furnished records, certificates of conformance, effectiveness of supplier quality control, an'd the purchase of spare or replacement parts.
Procurement documents, such as purchase specifications, contain or reference the following:
Technical, administrative, regulatory, and reporting requirements, including material and component identification requirements, drawings,.
specifications, codes and industrial standards, test and inspection requirements, and special process instructions.
b) Identification of ,the documentation to be prepared, maintained, or submitted (as applicable) to CP&L for review and approval. These documents may include, as necessary, inspection and test records, qualification records, 'or code required documentation. ,n c)
'yIdentification of those records to be retained, controlled, and maintained the 'supplier, and those delivered to the purchaser prior to use or installation of the har'dware.
Receipt inspections are performed by qualified inspectors in accordance with procedures to assure that:
a) Materials, equipment, or components are properly identified and correspond with associated documentation.
b) Inspection records or certificates of conformance attesting to the acceptance of materials, equipment, and components are completed and are available prior to installation or use.
c) Materials, equipment, and components are inspected and judged acceptable in accordance with predetermined inspection instructions prior to
'nstallation or use.
17.,3 '-3
e /
d) . Items not meeting applicable requirements controlled until proper disposition is made.
are clearly identified Appropriate controls and provisions have been included in procurement procedures and for selection, determination of suitability for the -intended use, evaluation, receipt, and quality evaluation of commercial grade items to ensure that these items will perform satisfactorily in service.
17.3.2.5 Procurement Verification Carolina Power & Light Company procurement documents are prepared, reviewed, approved, and controlled in accordance with procedures to assure that requirements are correctly stated, inspectable, verifiable, and controllable, and there are adequate acceptance/rejection criteria. Procurement documents are reviewed by personnel knowledgeable in applicable technical and quality requirements, and documentary evidence of that review and approval is retained and available for verification.
17.3.2.6 Identification and Control of Items Procedures require spare or replacement parts to be subject to QA program controls, codes and standards, and technical requirements which ensure they are suitable for their intended service.
Items accepted or released are identified as to their insp'ection status prior to forwarding them to a controlled storage area or releasing them for installation or further work. (Bulk items will not require individual accept tags; however, status of unacceptable bulk items will be so indicated).
Procedures require that materials, parts, and components be identified and controlled to prevent the use of incorrect or defective items. These procedures also require that identification of items be maintained either on the item in a manner that does not affect the function or quality of the item, or on records traceable to the item.
Procedures implementing these requirements provide for the following:
a) Verification that items received at the plant are properly identified and can be traced to the appropriate documentation, such as drawings, specifications, purchase orders, manufacturing and inspection documents, nonconformance reports, or material test reports.
b) Verification of item identification consistent with the CP&L inventory control system and traceable to documentation which identifies the proper uses or applications of the item.
c) Verification of correct identification of material, parts and components prior to fabrication, assembly installation or use, and results documented.
Consumables utilized in safety-related structures, systems and components are subject to appropriate controls as described in procedures.
17.3.2-4
17.3.2.7
~ ~ ~ Handlin Stora e and Shi in procedures define requirements for the. control of the handling, storage, and shipping of safety-related items. These procedures require measures to be taken.
to ensure special handling, storage, cleaning, 'packaging, shipping, and
~
preservation requirements are established to control these activities in accordance with design and specification requirements to preclude damage, loss or deterioration by environmental conditions such as temperature or humidity.
Provisions are established to control the shelf life and storage of chemicals, reagents, lubricants, and other consumable materials.
17.3."2.8 Test Control Procedures define requirements for test programs when required and require that items be tested to demonstrate that they will perform satisfactorily in service.
k Modifications, repairs, and replacements are accomplished in accordance with the original design and testing requirements or acceptable alternatives.
Test procedures incorporate or reference the following, as required:
a), Instructions and prerequisites for performing the test, b) Use of proper test equipment, c) Mandatory inspection hold points, d) Acceptance criteria Test results are documented, evaluated, and their acceptability determined by a qualified, responsible individual or group.
When the acceptance criteria is not met, affected areas are to be retested or evaluated, as appropriate.
17.3.2.9 Measurin and Test E ui ment Control Procedures define requirements for the control of measuring and test equipment used. These procedures include requirements to establish procedures for the
,. calibration, technique and,frequency, maintenance, and control of measuring and test 'equipment.
Inspections and test devices are selected to assure accurate measurement (i.e.
to overcome inherent inaccuracies associated with environment, human error, equipment, etc.).
Measuring and test equipment (M&TE) is identified and traceable to the calibration test data.
17.3.2-5
t Measuring and test instruments are calibrated at specified intervals (or immediately before and after use) based upon one or more of the following:
/
a) Technical Specifications')
Required accuracy.
c) Intended use.
d) Frequency of usage.
e) Stability characteristics.
f) Other conditions affecting measurement.
g) Manufacturer's recommendations.
Status of calibration for measuring and test equipment is provided through of tags, stickers, labels, routing cards, computer programs, or other the'se suitable means. The status indicators indicate the date recalibration is due or the frequency of recalibration.
Portable measuring and test equipment is calibrated by standards which are at least four times as accurate as the portable measuring and test equipment, unless limited by the state of the art. In cases where the accuracy is not achievable or is limited, by the state of the art, an engineering evaluation or other appropriate justification is performed and documented to justify acceptability of the M6TE in question. The evaluation is reviewed in accordance with approved procedures.
Calibration of installed plant devices shall be against M&TE having sufficient accuracy, greater than the device being calibrated, to assure that the system containing the device is within the specified system tolerance. The basis for determining the "greater than accuracy" shall be documented.
Reference and transfer standards are traceable to nationally recognized standards; or where national, standards do not exist, provisions are established to document the basis for the calibration.
Measures are required to be taken and documented to determine the validity of previous inspections and test results, found to be out of calibration.
if the measuring and test equipment is 17.3.2,10 Ins ection Test and 0 eratin Status Procedures define requirements for the identification and control of the inspection, test, and operating status of safety-related structures, systems, and components'hese procedures include the application, removal, and veri'fication of inspection and welding stamps, or other status indicators as appropriate, 17.3.2-6
Measures are established for indicating the operating status of structures, systems, and components. These measures include the use of checklists, computer
~programs, logs, stickers, tags, labels, record cards, and test records to
'ndicate the acceptable operating status of installed equipment. Installed equipment which, if operated, could cause damage to other equipment/systems or to personnel- is tagged to indicate its non-operational status and to prevent inadvertent use.
Selected plant procedures and subsequent revisions receive separate technical review to ensure required inspections, tests, and other critical operations are included.
Altering the sequence of required tests, inspections, and other operations important to safety can only be accomplished by methods outlined in procedures.
17.3.-2.11 S ecial Process Control
(
Procedures. define requirements for the control of special processes, such as welding, heat treating, and nondestructive examination.
Procedures require that special processes be performed by qualified personnel using proper equipment and in accordance with written qualified procedures.
These personnel and procedures are to be qualified in accordance with applicable" codes, standards, and specifications as described in procedures. Qualification records of special process procedures and personnel performing special processes are maintained and ava ilable for verification.
~ ~
Procedures define requirements for an inspection program to verify conformance to performance and quality requirements specified for those activities and services.
Inspections are performed by personnel who are not directly responsible for performing or supervising the activity being inspected. Inspection personnel are quali'fied in accordance with applicable codes and standards, and their qualifications and certifications are maintained current.
Inspections are performed in accordance with procedures or other documents which provide for the following:
a) Identification of individuals or groups responsible for performing the inspections.
b) Identification of characteristics and activities to be inspected.
c) Acceptance criteria.
d) Inspection techniques e) 'ecording the results of the inspection, review of the results, and identification of the inspector.
17.3.2-7
f) Indirect control by monitoring of processing methods, equipment, and personnel when direct inspection is not possible.
/Procedures identify inspection holdpoints, beyond which work may not proceed until inspected.
When acceptance criteria are not met, the condition will be documented in accordance with the applicable department's corrective action program procedures and reinspected or evaluated, as appropriate.
17.3.2.13 Corrective Action Procedures define requirements for a corrective action program that charges personnel working at or supporting the nuclear plants, with the responsibility to identify adverse conditions (including conditions adverse to quality).
Procedures include requirements for verification of the acceptability of the rework/repair of items by reinspection and/or testing in accordance with the original inspection or test requirements or by an accepted alternative inspection and testing method.
Conditions that require rework/repairs are identified through the use of maintenance work request forms.
17.3.2.14 ~ ~ Control of Documents Procedures define requirements for the development, review, approval, issue, use, revision, and control of documents. These procedures define the scope of which documents are to be controlled.
Procedures require the identification of those individuals or organizations
.responsible for reviewing, approving, and issuing documents and revisions thereto'hanges to documents are reviewed and approved by the same organization that perfo'rmed the original review and approval or by other designated qualified responsible organizations.
Controlled documents are to be available at the location where the activity will be performed prior to commencing the work, except in a radioactive contaminated area where the documents will be 'readily available.
A document control system has been established to identify the current revision number of instructions, procedures, specifications, and drawings.
Superseded documents are controlled to prevent inadvertent use.
17.3.2-8
17.3.2.15
~ ~ ~ 'ecords
~The program requires that sufficient records be maintained to provide documentary evidence of the quality of items and the accomplishment of activities'affecting quality.
Procedures define requirements for the identification; collection, and storage of quality assurance records.
Records are identifiable and retrievable through the use of indexes and filing systems, which are required by the program.
Procedures are required to be developed to indicate responsibilities and retention periods.
Records are maintained within structures designed to prevent destruction, deterioration, or theft. These facilities ensure protection against destruction by fire, flooding, theft, and deterioration by the environmental conditions of temperature and humidity.
17-. 3 . 2-9
17.3.3
~ ~ ASSESSMENT
,17.3.3.1 The overall ob]ective at CP&L is to encourage 'wnership, involvement, and dedication by each individual. supporting the Nuclear Program. This involves continually and aggressively looking for ways to improve the overall performance and safety at each plant. This approach of identifying and correcting conditions early, requires active support by management and employees.
A process of assessment, is an attitude by personnel that the CP&L Nuclear Program is improving on a continual basis. This process, along with an effective corrective action program, ensures that conditions are identified early, corrected promptly and effectively before becoming significant quality'or safety problems.
Personnel responsible for carrying out the assessment functions, including safety committee activities, nuclear safety reviews, verifications, self-assessment and independent assessm'ents, are cognizant of day-to-day activities, events, and have necessary experience to act in a management advisory function.
Assessment activities are accomplished using processes or procedures of a detail needed to accomplish the function based on complexity and importance to safety.
The managers of functions that support the Nuclear Program are responsible for ensuring that self-assessment activities and processes are implemented within their functions on a continuing basis.
17.3.3.2 Self-Assessment It is the management expectation that individuals and organizations will self-assess their end product. Adverse conditions identified during self-assessment activities are reported and resolved in accordance with the corrective action program.
Line Or anization Each individual, work group, and manager should be alert and open for areas that may need improvement.
Members of the line organization are charged with the responsibility to continually evaluate their activities and use each opportunity to achieve higher standards of quality and improved performance.
Planned and periodic self-assessment activities focus on how well the integrated quality assurance program is working and is to identify conditions that hinder the organization from achieving its safety, quality, and performance goals and standards.
Nuclear Services De artment
,.The Nuclear Services Department shall monitor specific functional areas, along 17.3.3-1
with the line organization management, to determine that the desired levels of performance are being achieved. Individuals assigned these duties shall work
,with each nuclear project to improve implementation of'P&L's Nuclear Programs and processes to support safe and reliable operation.
17.3.3.3 Inde endent Assessment The Nuclear Assessment Department (NAD) is responsible for conducting independent assessments of functions and activities affecting the nuclear programs at CP&L.
Personnel performing independent assessment activities are organizationally independent of the function/area being assessed and generally have. no direct responsibilities in the area being assessed. However, on an exception basis, personnel in the NAD may provide assistance to the line organization by participating in ad hoc committees or analyzing specific technical issues, if such assistance is deemed to be in the overall best interest of safety and is approved by NAD management.
Selection of assessment personnel is based on experience and/or training that establishes that their qualifications are commensurate with the complexity or special nature of the area being assessed. The process for qualification of personnel to perform and lead assessments is established in procedures.
Personnel performing assessments shall have access to records, procedures, and personnel to gather data; Assessment. Process Elements A primary objective of the NAD is to assess the effectiveness of the line organization's self-'assessment processes..
The assessment process includes gathering data, analyzing data, focusing on selected issues and identifying deficiencies to desired performance. The results of assessments are communicated to management in a manner. that causes action to correct deficiencies and develop action to prevent recurrence. In addition, this process should evaluate corrective m'easures adopted to eliminate the deficiencies identified.
Data is gathered using performance'ased techniques during:
o Observations of work activities,-
o Interviews, o Reviews of documents to gather information (including the use of NRC, INPO, and other agency evaluations),
o Review of self-assessment data and reports (performance indicators, trend
'reports, etc.)
o Nuclear Safety Review activities, o Team assessments (functional, site/department, corporate),
o Analysis of plant data and reports (including adverse condition reports, etc.)
Planning activities identify the organizations to be evaluated, the ,
characteristics to be focused on during the assessment, and the applicable acceptance criteria. Assessment activities are selected with flexibilitybased on various factors'hese factors include but are not limited to: importance to safety and reliability, NAD assessments of site work activities, time since last assessment, plant management perspective, outside agency audits, and problem areas identified from industry and CP&L experience.
Preparation activities may include a review of performance data, relevant documentation,'revious assessment data, industry experience, team member experience, and management input. These activities enable the team to focus on" significant issues which may impact safety and reliability when analyzing data.
Assessments are scheduled on the basis of the status and safety importance of the activities or processes being performed. The schedule is flexible and dynamic to allow assessment to be changed depending on plant conditions, events, or issues raised by Senior management.
17.3.3-3
Functions/areas to be assessed include:
o Plant Operations o Maintenance o Radiological Controls o Chemistry o Environmental Monitoring o'ngineering/Technical Support o Fire Protection o Security o Emergency Preparedness o Nuclear Fuel o Outage Management o Other functions/areas requested by Senior Management Assessments of these functions/areas may include portions of:
o Conformance to provisions contained within the Technical Specifications and applicable license conditions o Operating experience o Procedures o Training and qualifications o Support activities o Corrective actions o Other activities deemed necessary to assure adequate performance Results Adverse conditions are reported in accordance with the applicable department's corrective action program procedure or by formal correspondence between responsible levels of management.
Independent assessment results are communicated to line management to allow for timely action,to address potential problems or recognize strengths and superior performance.
Independent assessment results are documented and reviewed with management personnel responsible for the areas assessed.
Results of assessments, special investigations, and analysis of'ata will be provided to the Nuclear Assessment Department (NAD) Management for review. A summation of assessment perspective, along with potential issues and recommendations shall be presented to the Executive Vice President - Power Supply and Senior Vice President - Nuclear Generation Group on an approximately bimonthly frequency.
Follow-up is accomplished to assure that corrective action is taken as a result of the assessment and that deficient areas are reassessed, when necessary, to verify implementation of adequate corrective actions.
17.3.3-4