ML18017A861

Rev 0 to Harris Fuel Pool Heatup Calculation.

ML18017A861
Person / Time
Site:	Harris
Issue date:	11/16/1998
From:	Aboye M, Rhex Edwards, Lundy J CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML18017A859	List: ML18017A858 ML18017A860 ML18017A861
References
SF-0041, SF-0041-R00, NUDOCS 9909100160
Download: ML18017A861 (137)

Text

ENCLOSURE 3 to SERIAL: BNP-99-129 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 RESPONSE TO NRC REQUEST FOR ADDITIONALINFORMATION REGARDING THE LICENSE AMENDMENTREQUEST TO INCREASE FUEL STORAGE CAPACITY Calculation SF-0041 Harris Fuel Pool Heatup Calculation 0III0910M60 O'II0+0>

PRR A00CK 05000400 p PDR

1 ~

~ ~ ~

~ ~

II ~

~

~

~ ~

~ '

~

~

~ ~ ~

~ ~

~

~ ~

~ ~ ~ ~ ~

~ ~

~

~

WNFE

~

Computed by: Date:

CAROLINAPOWER 8: LIGHT COMPANY Calculation ID: SF-0041 Jeff Lundy 10/26/98 Checked by: Date: Pg tof 5 Rcv.

0 Merid Aboye 10/26/98 Project No.:

CALCULATIONSHEET File:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Heatup Calculation List of Effective Pages PAGE PAGE PAGE Attachments A

Computed by: Date: Calculation ID: SF-0041 Jeff Lundy 10/26/98 CAROLINAPOWER Ec LIGHT COMPANY Checked by: Date: Pg ii of 5 Rev' Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Heatup Calculation Table of Contents Section LIST OF EFFECTIVE PAGES TABLE OF CONTENTS 1.0 PURPOSE

2.0 REFERENCES

3.0 ENGINEERING ANALYSISSOFTWARE 4.0 CALCULATION

5.0 CONCLUSION

S Attachments Subject Total Pages Calculation SF-0041, Revision 0, Design Verification Records M3 i

Computed by: Date:

CAROLINAPOWER & LIGHT COMPANY Calculation ID: SF-0041 Jeff Lundy 10/26/98 Checked by: Date: pg I or 5 Rev 0

Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Hcatup Calculation 1.0 PURPOSE The purpose of this calculation is to determine thc rates of temperature increase in the spent fuel pool for the heat loads associated with an assumed inventory of Spent Fuel Pool C which generates 1.0 MBTU/hr of decay heat. The times required to raise Spent Fuel Pool C bulk temperature from 105'F to 137'F, 105'F to 150'F and 105'o 212'F will also be calculated based on the above heat load. For this calculation, "spent fuel pool" shall mean pool C only.

2.0 REFERENCES

(1) Harris Nuclear Plant Calculation SF-0038 Revision 0, Spent Fuel Pool Heat Up Rate' Time to Boil Calculation, dated 2/21/97 (2) Harris Nuclear Plant Operating Procedure, OP-116 (3) Harris Nuclear Plant Calculation HNP-F/NFSA-0026 Revision 0, Maximum Decay Heat Load for Spent Fuel Pools A,B&CThrough the End of the Year 2001, dated 4/16/98 (4) ASME Steam Tables, Fifth Edition (5) Holtec International Drawing 1994, Revision I, "Pool Layout for Pool "C"- PWR & BWR Spent Fuel Storage Racks", dated 3/18/98 (6) Harris Nuclear Plant Drawing CAR 2165-G-411 Revision 9 3.0 ENGINEERING ANALYSIS SOFTWARE None Used.

4.0 CALCULATION This calculation willbe performed by:

1) Calculating the net water volume in Spent Fuel Pool C,

2) Calculating the fuel pool heat up rate associated with a fuel pool inventory generating 1.0 MBTU/hr and

3) Calculating the time to reach 137'F, 150'F and 212'F using the calculated heat up rate.

4.1 Assumptions 4.1.1 Water Densities for 137'F, 150'F and 212'F will bc used for conservatism.

p>>,=1/0.016279 = 61.43 Ibm/k for 137'F, Reference (4) p)~F 1/0.016343 61,19 Ibm/k for 150'F, Reference (4) p>>>> =1/0.016719 = 59.81 Ibm/ft'or 212'F, Reference (4)

Computed by: Date:

CAROLINAPOWER 8G LIGHT COMPANY Calculation ID: SF-0041 Jeff Lundy 10/26/98 Checked by: Date: i'g 2 of 5 Rev 0

Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Heatup Calculation 4.1.2 Only the volume of Spent Fuel Pool C willbe considered.

4.1.3 Evaporative heat losses to the Fuel Handling Building ambient and conduction losses through thc fuel pool liner are NOT credited for heat removal for this analysis.

4.1.4 Fuel Pool Water heat capacity (Cp) = 1.0 BTU/lbm-'F.

4.1.5 The spent fuel racks are constructed of 304 stainless steel with a specific weight of 0.29 ibm/ft',

Reference (1) 4.1.6 Pool C contains 539 BWR spent fuel assemblies, Reference (3).

4.1.7 The spent fuel assembly decay heat is 1.0 MBTU/lu for Spent Fuel Pool C, Reference (3).

4.1.8 The initial steady state pool equilibrium temperature is 105'F, Reference (2).

4.1.9 This calculation only considers Phase I of the Spent Fuel Pool C activation which includes fuel rack modules Al, A2, Bl, B2, Cl, C2, Dl, D2, El, E2, E3, Fl, F2, and F3 per CP&L Project Engineering direction.

4.1.10 This analysis assumes a total loss of SFP C cooling, therefore the heat removal by the SFP heat exchangers is 0 BTU/hr.

4.2 Estimate of Water Volume in Spent Fuel Pool C The volume for a BWR fuel assembly, 1.164 fr', is taken from Reference (1)

The volume for the fuel racks is calculated as follows:

Fuel Rack Specific Weight = 0.29 ibm/in', Reference (1)

Fuel Rack Volume = Empty Weight/Specific Weight/1728

Computed by: Date:

CAROLINAPOWER & LIGHT COMPANY Calculation ID: SF-0041 Jeff Lundy 10/26/98 Checked by: Date: Pg30f5 Rev 0

Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Hcatup Calculation Module Rack Rack Empty Weight Specific Weight Rack Volume ID Capacity (Ib) (lb/in') (A')

Al 11 x 9 (PWR) 14770 0.29 29.47 A2 11 x 9 (PWR) 15620 0.29 30.45 Bl 9 x 9 (PWR) 12250 0.29 24.45 B2 9 x 9 (PWR) 12940 0.29 25.82 Cl 8 x 13 (BWR) 9710 0.29 19.38 C2 8 x 13 (BWR) 9710 0.29 19.38 Dl 8 x 11 (BWR) 8460 0.29 16.88 D2 8 x 11 (BWR) 8460 0.29 16.88 El 13 x 13 (BWR) 15370 0.29 30.67 E2 13 x 13 (BWR) 15700 0.29 31.33 E3 13 x 13 (BWR) 15700 0.29 31.33 Fl 13 x 11 (BWR) 13380 0.29 26.70 F2 13 x 11 (BWR) 13380 0.29 26.70 F3 13 x 11 (BWR) 13380 0.29 26.70 Total Volume = 356.14 The minimum gross volume of the fuel pool is:

(Low Level Alarm - SFP Floor Elevation) x Pool Length x Pool Width where:

Low Level Alarm = 284 ft, Reference (1)

SFP Floor Elevation = 246 A, Rcfcrcnce (6)

Pool Length = 50 feet, Reference (5)

Pool Width = 27 feet, Reference (5)

Gross Volume = (284 ft - 246 ft) x 50 ft x 27 ft = 51300 ft'he net pool water volume is:

Net Pool Water Volume = Gross Volume - Fuel Assy Volume - Total Fuel Rack Volume Net Pool Water Volume = 51300 - 539 x 1.164 356.14 = 50316.5 Ag The nct pool water thermal mass is:

Net Pool Water Thermal Mass = pspp x Vspp x Cp Net Pool Water Thermal Mass at 137'F = 61.43 x 50316.5 x 1.0 = 3090942.6 BTU/hr-'F Net Pool Water Thermal Mass at 150'F = 61.19 x 50316.5 x 1.0 = 3078866.6 BTU/hr-'F Net Pool Water Thernial Mass at 212'F = 59.81 x 50316.5 x 1.0 = 3009429.9 BTU/hr-'F

Computed by: Date: Calculation ID: SF-0041 Jeff Lundy 10/26/98 CAROLINAPOWER & LIGHT COMPANY Checked by: Date: Pg 4 of 5 Rev 0

Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Heatup Calculation 4.3 Estimate of Transient Spent Fuel Pool Thermal Performance An estimate of the transient thermal performance of spent fuel pool C was performed to determine the time to various fuel pool temperatures during a loss of CCW cooling scenario. The transient analysis conservatively assumes a decay heat load of 1.0 MBTU/hr while only accounting for the net water volume of the fuel pool and neglecting changes in the water thermal properties.

In general, fuel pool heatup thermal transients are calculated from:

dT= Equation (1) p dt QDecayHeat QSFpHx where:

p = Pool Water Density (ibm/cuA) at the Specified Pool Temperature C = Pool Water Specific Heat (BTU/ibm/F) p V = Pool Net Water Volume(cuA) 1.0 MBTU/hr QD H DecayHeat

=0 QSFPHx

-Q SFPHx

= dT = QDecayHeat Heat UpRate Equation (2) dt PSFP.C .VSFP It is conservatively assumed that the fuel pool is at the maximum temperature limit of 105'F, Reference (2),

prior to the thermal transient. This analysis also assumes no operator action with respect to the fuel pools.

4.4 Estimate of Spent Fuel Pool C Heat Up Rates For the given parameters for Spent Fuel Pool C, the estimated heat up rates are:

'.324 The heatup rate at 137'F is:

Heat UpRate 3090942.6 BTU/hr F F/hr The heatup rate at 150'F is:

Heat UpRate 325 F/hr 3078866.6 BTU/hr F

(

Computed by: Date: Calculation ID: SF-0041 Jeff Lundy 10/26/98 CAROLINAPOWER & LIGHT COMPANY Checked by: Date:

5 o(5 Pg Rev 0

Merid Aboye 10/26/98 CALCULATIONSHEET File:

Project No.:

Project

Title:

Spent Fuel Pools C and D Activation Project Calculation

Title:

Harris Fuel Pool Hcatup Calculation The heatup rate at 212'F is:

1.0E6 BTU/hr 0.332 F/hr Heat UpRate>>,F 3009429.9 BTU/hr F 4.5 E<stimate of Time to Reach 137'F The time to reach 137'F is:

Time 137F

=, 137F-105F 0.324

= 98.8 hr 4.6 Estimate of Time to Reach 150'F<

The time to reach 150'F is:

150F -105F Time =138.5 hr 150F 0.325 4.7 Estimate of Time to Reach 212'F<

The time to reach pool boiling conditions of 212'F is:

212F -105F Time = = 322.3 hr 212F 0 332

5.0 CONCLUSION

S This analysis concludes that the estimated Spent Fuel Pool C heat up rate at 137'F, 150'F and 212'F is 0.324'F/hr, 0,.325'F/hr and 0.332'F/hr, respectively, for a maximum decay heat load of 1.0 MBTU/hr. The time to reach 137'F, 150'F and 212'F from the 105'F administrative limit is 98.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, 138.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and 322.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, respectively.

I

.....9407290410 ENCLOSURE g SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE< NO. NPF-63 QUALITYASSURANCE PROGRAM PERFORMANCE-BASED NUCLEAR ASSESSMENT PROGRAM

SUMMARY

OF ORGANIZATIONALAND FUNCTIONAL CHANGE<S Carolina Power and Light Company (CP&L) requests NRC approval of Quality Assurance (QA) program changes in order to implement the performance-based nuclear assessment program. Technical Specification changes are being requested by a separate letter. This enclosure provides an informational summary of the functional and organizational changes.

Specific commitments are described in the Technical Specifications and QA Program description and not in this enclosure.

To improve the effectiveness and efficiency of the nuclear assessment (quality assurance/quality control) function, CP&L will make both organizational and functional program changes. Where no reduction in regulatory commitment is involved, CP&L will make the changes as allowed by 10 CFR 50.54(a)(3).

The majority of this submittal is similar to the original Technical Specification/QA program changes first submitted August 1992 and revised September 1993 after dialogue with NRC reviewers. CP&L withdraws the previous submittals. The major changes from the previous submittals include: 1) elimination of the Nuclear Assessment Department (NAD) and realignment of the Nuclear Assessment Section (NAS) reporting to the Site Vice President; 2) addition of a 2 year frequency cap for performance based assessments; and 3) revised Independent Review (IR) and Independent Safety Engineering Group (ISEG) functions and organizations.

The purpose of the nuclear assessment reorganization is to:

Improve plant performance through strengthened self-assessment; Increase accountability for problem identification and effective corrective action within the plant organization;

~ Strengthen the depth and scope of performance-based assessment; Improve translation of "lessons learned" throughout the Nuclear Generation Group; and Maintain senior management awareness of plant performance issues.

2227nri.717 E1-1

"1 V

Qt ilk +

~ II

)(

I L%

I

'N

Performance Evaluation Section A Performance Evaluation Section (PES), reporting to the Vice President - Nuclear Services Department (NSD), will be established. The PES will provide a cadre of experienced assessment-trained, management-level, personnel to lead assessments and evaluate key areas of the plant and supporting organizations.

The primary functions of the PES are: 1) to independently assess the self-assessment and corrective action process of the line organization and the NAS; 2) to ensure that "lessons learned" are shared among the plants and support organizations; and 3) to facilitate the use of industry peer evaluators to identify industry best practices.

A PES-led self-assessment will be performed in each NRC Systematic Assessment of Licensee Performance (SALP) functional area once per SALP cycle. The PES evaluation teams will include peers from other CP&L plants and from the nuclear utility industry, as appropriate, to lend expertise to the self-assessment.

Self-assessment is a broad term, covering everything from self-checking to formal, documented evaluations of plant performance in a specific area, such as work control management. PES-led self-assessments will be documented evaluations. CP&L's three nuclear plants have adopted self-assessment as a way of doing business. The readiness for plant startup process is a good example of formal self-assessment. CP&L seeks to improve the formal self-assessment process by means of PES-led evaluations. The technical expertise of peer assessors coupled with the assessment skills of the PES assessors is expected to provide solid evaluations. Equally important, the assessment training instilled in the peer evaluators during the course of an assessment and the knowledge gained of plant practices at other CP&L plants by the peers will be most valuable.

The PES will by procedure evaluate the effectiveness of the site's self-assessment program, the site's ability to incorporate lessons learned from within CP&L as well as industry events, and the site's corrective action program. In addition to traditional assessment reports, this program will be facilitated by periodic peer group meetings between the PES Manager and each plant NAS Manager. There will also be periodic conference calls between these individuals during which operational experience and plant issues are discussed.

Written PES evaluations, including the results and recommended corrective actions, will be reported to plant and senior management.

The Vendor and Equipment Quality function and the Quality Check (employee concern) program will be reassigned from the NAD to the NSD, where it will report to the Manager-PES. The realignment of corporate functions and reporting relationships are shown in Attachment 1A.

2227nri.717 E1-2

I eel Yl 4

E, 4

The benefits from the establishment of the PES include:

~ Senior management will be informed of plant performance issues by an organization outside the plant line chain of command.

An independent check of the NAS performance will be provided.

Peers from other CP&L plants and from the nuclear utility industry, as appropriate, will be used on evaluation teams.

The evaluation process will provide an additional means of exchanging operational experience among CP&L plants and other utilities.

Evaluations will emphasize the key attributes of self-assessment, corrective action, and sharing of operating experience.

Nuclear Assessment Section The proposed reorganization eliminates the NAD and realigns the plant NAS, reporting to the Site Vice President. The assignment of NAS as a direct report provides a valuable resource to the person held fully accountable for plant performance. The NAS will continue to conduct performance-based assessments to meet the 10 CFR 50, Appendix B, regulatory-required audits, and will assess to the Institute for Nuclear Power Operations gNPO) performance standards rather than minimum compliance standards.

The NAS Manager will report to the most senior CP&L manager on site, the Site Vice-President. This will ensure independence from the plant production organization. Other nuclear utilities have developed similar organizational arrangements for their quality assurance organizations.

The NAS has been aligned consistent with the current NRC Systematic Assessment of Licensee Performance (SALP) categories. The NAS organization is provided for your information in Attachment 1B. The responsibilities for the Plant Operations and Plant Support Units are discussed below:

Plant Operations - responsible for Operations, Maintenance, and Engineering and Technical Support.

Plant Support - responsible for Environmental and Radiation Control and other support areas such as Emergency Preparedness, Security, Document Control, and Material Control.

This realignment will not diminish the emphasis on engineering and technical support within the section. In evaluating the workload of assessors in conjunction with the reorganization, it was determined that having two Engineering/Tecluucal Support Project Engineers in the Operations Unit, coupled with the other engineering and related science personnel within the NAS was sufficient to meet the needs of the assessment, ISEG, and IR functions.

2227nri.717 E1-3

~ ~

fs 'E 0

4

~.

~i

+

ll 1

1

The NAS has highly qualified, experienced engineers at each plant. Further, these NAS engineering positions are rotational. The engineers and other NAS assessors are expected to rotate back into the line organization in two to five years. Thus, the engineering, operations, and maintenance expertise will stay current.

The NAS assessment process will remain consistent with that presently performed by the plant NAD sections. One benefit of the current process has been the use of peers from other plants during evaluations. As described in the PES peer discussion, the NAS assessment process also facilitates the exchange of information among CP&L plants.

The NAS will use CP&L peer engineering personnel, if necessary, outside consultants, where specified expertise is needed to ensure engineering areas are properly evaluated.

Upon NRC approval, the IR function will be reassigned from the NAD to the plant NAS. IR is currently performed by four engineers. Normally, one of the four engineers is assigned to plant special assessments. Effectively, there is one engineer per site performing IR. The reassignment would put one IR Project Engineer in each NAS, reporting to the Manager-NAS.

Documents requiring IR are currently reviewed by three separate engineers, through a three party review process, designed to ensure review by the appropriate discipline. CP&L is proposing a revision to this process which is consistent with ANSI N18. /, which requires review by the appropriate discipline.

In the event the IR Project Engineer does not have the appropriate discipline background to review a specific document, he will obtain the required discipline expertise from within the NAS, and, if necessary, outside NAS to ensure the proper review is completed.

The Harris Nuclear Plant (HNP) has a requirement to have an ISEG. This function is presently met by the HNP NAD section.

CP&L is proposing to overlap the IR function with the ISEG and assessment/audit functions at the HNP. Combining these functions will provide consistency among CP&L nuclear plants in the way these responsibilities are being implemented. CP&L believes that individuals performing the 10 CFR 50, Appendix 8 assessment and IR functions can concurrently fulfill the requirements of the ISEG function. The NAS has experienced personnel, who have engineering or related science degrees to carry out the IR function. The IR function will complement the ISEG function at the Harris Plant.

2227nri.717 E1-4

The benefits of the NAS reorganization include:

~ Provides an additional tool to the Site Vice President for assessing and improving plant performance; Provides greater plant accountability for improved performance; Closely links the nuclear assessment function to plant needs;

~ Provides for an independent assessment of plant performance since the NAS is outside the normal plant manager line function chain of command;

~ Promotes line self-assessment; Uses expertise from other CPEcL plants; Facilitates plant personnel assignments to other CPEcL assessment teams; and Enhances personnel development by facilitating and stimulating rotation with the plant organization.

2227nri.717 E1-5

gl ~~

L 0

Significant Teclmical Specification/QA Program Functional Chan es Nuclear Assessment audits will be conducted at a frequency consistent with plant performance. In no case will the assessment (audit) cap of 24 months be exceeded. CPB'cL will not change its audit frequency limits until the 24 month cap is approved by the NRC in response to this request.

The bimonthly report of NAD issues is proposed to be revised to a periodic briefing of NAS issues to senior management. This will be normally done at the plant management review meeting. Nuclear Assessment issues will be discussed, including a review by the manager responsible for the corrective action.

The technical specification change details the transfer of the IR function from corporate NAD to the plant NAS. The IR function will be integrated into the NAS organization, which at the Harris Nuclear Plant, is responsible for conduct of the ISEG function. The makeup of NAS personnel provides a broad experience base and diversity of academic/engineering disciplines for ISEG, IR, and the 10 CFR 50, Appendix B assessment functions.

IR will be performed in the applicable discipline(s) by qualified reviewers per applicable ANSI N1S.7 requirements instead of the current three party review now performed for each plant. Should the IR Project Engineer not have the required discipline background to review a specific document, he will obtain the required discipline expertise from other qualified NAS reviewers, including going outside NAS, if necessary.

2227nri.717 E1-6

Proposed Nuclear Services artment Organization Nuclear Generation Group Vice-President Nuclear Services Department Manager Other Section Performance Managers Evaluation Manager Principal Engineers Vendor & Quality Check Tech Assistant I Nuclear Senior Specialists*

Equipment Quality Assessment*

Senior Specialists/

Senior QA Engineers

~ Located at plant A 7/15/94

n l ~

'I yl f

r'

HNP Proposed N r Assessment Section Executive Vice President, Nuclear Generation Site Vice President Manager Nuclear Assessment Project Engineer Secretary (Independent Review)

Manager Manager Plant Support QC Supervisor Plant Operations Assessment Assessment Principal Engineer Clerk Project Nuclear Principal Engineer Assessment QC Engineer Nuclear Assessment Technicians (Engffech (E&RC)

(Operations)

Supt)

Project Principal Engineer Project Engineer Engineer Nuclear Assessment (En JTech NDE (Ops/Maintenance)

Supt) Technicians Principal Engineer Senior Engineer Nuclear Assessment (Maintenance)

Engineering Tech I Attachment 1B 7/22/94

I a'f 4<

i'<

~+r

ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKI<'T NO. 50-400/OPERATING LICENSE< NO. NPF-63 QUALITYASSURANCE< PROGRAM CHANGE DESCRIPTIONS RK UIRING NRC APPROVAL INCLUDING REASONS/BASIS FOR CHANGE PROPOSED CHANGE NO. 1 - FSAR SECTION 1.8 REGULATORY GUIDE 1.33 PAGE 1.8- 41 The proposed change deletes the existing clarification "b" and replaces it with new clarifications "b and c" concerning CP8.L's independent review and assessment programs.

Reason for Chan e The proposed Nuclear Assessment Section (NAS) is responsible for independent review and assessment functions. By being a part of the same organization, a formal independent review of assessment reports will not be performed by the NAS. Periodic reviews of the assessment program will be changed from once every six months to a frequency not to exceed once every 24 months.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram An independent review of the NAS activities will be performed by the Performance Evaluation Section. In addition, management receives periodic briefings of NAS activities. This meets the 10 CFR 50, Appendix B requirement to have these assessment results reviewed by management. This change from six months to 24 months is consistent with our transition to a performance based assessment program with a 24-month frequency cap. This meets the 10 CFR 50, Appendix B requirement to regularly review the status and adequacy of the QA program.

2227nri.717 E2-1

Cy 4

J'

PROPOSED CHANGE NO. 2 - FSAR SECTION 1.8 REGULATORY GUIDE 1.146 PAGE 1.8-186 The proposed change adds a new clarification "4" to modify the criteria for qualification of Lead Assessors. Currently, Lead Assessors shall have participated in a minimum of five (5) nuclear industry type evaluations within a period of time not to exceed three (3) years prior to the date of qualification, one assessment of which shall be an assessment within the year prior to qualification. CP&L proposes to revise the requirement to participate in five (5) nuclear industry type evaluations without the three (3) year restriction. They may have previous assessment experience, but not in the last three (3) years due to other management assignments.

Reason for Chan e CP&L proposes to rotate experienced personnel from the line organization into the NAS. This change allows the NAS organization to utilize prior experience to qualify individuals as Lead Assessors.

Basis for Concludin that the Revised Pro ram Incor oratin the Chan e Continues to Satis 10 CFR 50 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. Qualified and experienced personnel used to perform assessments will continue to meet the qualification requirements outlined in our commitment to Regulatory Guide 1.146.

2227nri.717 E2-2

i~

yl A Y e

V t

t*

(

t Ql 4

PROPOSED CHANGE NO. 3 - FSAR SECTION 13.1 ORGANIZATIONALSTRUCTURE OF APPLICANT The Nuclear Safety Review Unit (Independent Review function) is being transferred from the Nuclear Assessment Department (NAD) to the Harris Nuclear Plant. The primary responsibility of the Nuclear Safety Review Unit was to perform the Independent Review function for all of CPEcL's nuclear units. The proposed organization transfers this function to the NAS at each plant. Individuals performing the Independent Review will also perform 10 CFR 50, Appendix B assessment and ISEG functions. This organizational change will be described in FSAR Chapter 13 and submitted in accordance with 10 CFR 50.71(e).

Reason for Chan e The proposed organization deletes the NAD and realigns this function reporting to the Vice President - Harris Nuclear Plant. The purpose of combining the independent review, assessment and ISEG functions is to:

1) improve plant performance through strengthened self-assessment.

2) increase accountability for problem identification and effective corrective action within the plant organization.

3) strengthen the depth and scope of performance based assessment.

4) improve translation of "lessons learned" throughout the Nuclear Generation Group.

5) maintain senior management awareness of plant performance issues.

Basis for Concludin that the Revised Pro ram Inco oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The proposed organization will allow CPEcL to implement a performance based assessment program that meets the requirements of 10 CFR 50, Appendix B. The NAS will be a multi-disciplined, experienced and qualified group of individuals to meet these requirements.

2227nri.717 E2-3

4

~

~

E r

r

/

4

'I I

T V

PROPOSED CHANGE NO. 4 - FSAR SECTION 17.2 A PROGRAM DESCRIPTION The proposed change deletes Section 17.2 in its entirety and replaces it with Section 17.3 which describes the proposed performance based assessment program. Changes which require NRC approval include: 1) implementation of a performance based assessment program with a 24-month frequency cap; 2) periodic reviews of the plant assessment function will be changed from once every six months to a frequency not to exceed once every 24 months; 3) deletion of the requirement from FSAR Section 17.2.15 to perform sample work request reviews for identification of QA hold points; and 4) the Manager - NAD had access up to and including the Chief Executive Officer. This is being revised to state that the Manager - NAS will have access up to and including the Executive Vice President - Nuclear Generation Group. NUREG-0800, Standard Review Plan, Section 17.3 was used to reformat the existing FSAR Section 17.2 to the proposed FSAR Section 17.3. Various editorial and format changes were made to provide consistency among CP&L nuclear plants for the QA Program description.

Reason for Chan e The proposed Section 17.3 describes the performance-based assessment program.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The modification of assessment frequencies will allow assessments to be scheduled on the basis of plant performance. The basis for the change in frequency of periodic reviews of the assessment program from once every six months to once per 24 months is described in Proposed Change No. 1.

The deletion of the requirement to perform sample work request reviews for identification of QA holdpoints is to provide consistency among CPAL nuclear plants.

The Manager - NAS will provide briefings to the Senior Nuclear Operating Officer, the Executive Vice President - Nuclear Generation Group, to ensure that- concerns are raised and addressed at the highest level in the Nuclear Generation Group. The Manager - NAS is free at anytime to raise issues to the Executive Vice President-Nuclear Generation Group if he determines that additional emphasis or action is necessary.

2227nri.717 E2-4

i~

i' 4,

C T

E II d'Y

PROPOSED CHANGE NO. 5 - FSAR SECTION 1.8 REGULATORY GUIDE 1.38 PAGE 1.8-50d Pro osed Chan e No. 5 The proposed change to clarification "z" changes the responsibility from QA/QC personnel to line organization 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. The plant maintenance procedures provide 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 reduced since construction was completed. Most rigging is now purchased with certification of load capacity and does not require testing upon receipt.

This change places the responsibility for witnessing for load tests and surveillance of maintenance inspections at the appropriate level in the line organization. QC personnel will continue to perform nondestructive examinations of rigging equipment. This is consistent with the guidance of Regulatory Guide 1.38.

Plant maintenance procedures have criteria for inspection and testing which assures that quality in these activities is achieved.

2227nri.717 E2-5

(j.

I

'sty

~u1

SHNPP FSAR Regulatory Guide 1.33 QUALITY ASSURANCE PROGRAM REQUIREMENTS (REV. 2)

(OPERATION)

Carolina Power & Light Company complies with this guide, which endorses ANSI N18.7-1976, with the following clarifications'.

41 a) Paragraph 1, "Scope", recommends that this standard applies to f41 activities other than those associated with safety related equipment, activities, and procedures. ANSI N18.7-1976 has not fully taken into account the requirements of regulations other than 10CFR50. Conflicts may exist between ANSI N18.7-1976 and those other regulations, such as OSHA, 10CFR19, 20, 21, 30, 40, 70, 71, 73, and ASME. Therefore, CP&L shall apply ANSI N18.7-1976 only to those plant features addressed in Section 3.2 of the FSAR that are classified as safety-related and under the control of the QA program.

Rep~~ with aft~ed Power & Light Company's Performance Evaluation Unit is responsible for conduction Each QA audit report is reviewed by the Executive Vice President Power Supply. Caro tn will use these i 4i management reviews to satisfy the requirements of the Last portion o paragraph 4.5.

g tj} Paragraph 5.2.6, Equipment Control: CP&L will comply with the f 41 "independent verification" requirements based on the definition of this phrase as given under the commitment to Regulatory Guide 1.74.

Since CP&L sometimes uses descriptive names to designate equipment, the sixth paragraph, second sentence is replaced with: "Suitable means include identification numbers or other descriptions which are traceable to records of the status of inspections and tests.

The first sentence in the seventh paragraph will be complied with after clarifying "operating personnel" to mean trained employees assigned to, or under the control of, CP&L management at an operating nuclear facility.

Paragraph 5.2.7, Maintenance and Modification. Since some emergency situations could arise which preclude preplanning of all activities, CP&L will comply with an alternate to the first sentence in the second paragraph which reads: "Except in emergency or abnormal operating conditions where immediate actions are required to protect the health and safety of the public, to protect'quipment or personnel, or to prevent the deterioration of plant conditions to a possible unsafe or unstable level, maintenance or modification of equipment shalL be preplanned and performed in accordance with written procedures. Where written procedures would be required and are not used, the activities that were accomplished shalL be documented after the fact and receive the same degree of review as if they had been preplanned. II Paragraph 5.2.7 ',

requirements of the Maintenance Programs'CP&L first sentence of the will comply with fifth paragraph. This the clarification 1.8-41 Amendment No. 41

I I

~1 l,

I 4 C

Pro osed Chan e 1 Insert for Regulatory Guide 1.33.

b.) Paragraph 4.5 Written assessment reports are not formally reviewed as part of the Independent Review function.

c.) Paragraph 4.5 The Performance Evaluation Section will perform periodic reviews of the assessment program at least once every 24 months.

2227nri.717

SHNPP FSAR Regulatory Guide 1.146 QUALIFICATION OF gA PROGRAM AUDIT PERSONNEL FOR NUCLEAR POWER PLANTS (REV. 0, 8/80)

Carolina Power & Light Company shall comply with requirements of Regulatory Guide 1. 146, August 1980, which endorses ANSI N45.2.23-1978 with the following clarifications.

1. Paragraph 2.2, gualification of Auditors: Subparagraph 2.2. 1 references an ANSI 845.2 (presumed to be N45.2); therefore, CP&L will comply with an alternate subparagraph 2.2. 1 which reads:

"Orientation to provide working knowledge and understanding of the CP&L gA Program, including the ANSI standards and Regulatory Guides included in the Program, and CP&L's procedures for implementing audits and reporting results."

2. Paragraph 4.1, Organization Responsibility: Carolina Power & I Light Company will comply with this Paragraph with the substitution of the following sentence in place of the last sentence in the Paragraph.

S<ati'og ~u JIt/

"The Manager - Nuclear Assessmenthor the"Assessment Team Leader shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."

Pos a. IV (see ~cZosare. 3g

3. Paragraph 5.3, Updating of Lead Auditor,',s Recor s: Carolina Power

& Light Company will substitute the following sentence for this Paragraph:

"Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Paragraph 3.2.

/5'see ~c&sure. p)

'i ll (I i'arayaph a.~.+ For Assessirieks the. prospeaOiie Level assessor sholJ have prtiaclf tx.al IQ a tlfilUimLvn oV Vive. QllcLeac gricfusfil/

type. evaLuafi'Ous ()e, MAC iitspeatiiiws Elope AssessrneiJ~> IJucLear .

A~essiiieiit ~0iiiu Assessir each> QA Audit's...) ONe oii'a4i c4 sh 'U. be. ~N iW the. yeo,i prtoc tb quali ricati ov' 1.8-186 Amendme. No. 44

E l

I

'P

Pro osed Chan e No. 4 Section 17.2 is being deleted in its entirety. It is being replaced with the attached Section 17.3.

2227nri.717

II 4 I

(

gt k)

I C'

17.3 HNP UALITYASSURANCE PROGRAM DESCRIPTION 17.3.1 MANAGEMENT 17.3.1.1 Methodolo It is the policy of Carolina Power Ec Light Company (CP8cL) 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 - Nuclear Generation Group.

The QA Program and procedures apply 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. The 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 - Nuclear Generation Group.

The QA Program is founded on the principle that the line organization has the primary responsibility for quality and safety. Self-assessment practices are used to ensure the desired levels of quality and safety are achieved and maintained. This consists of each individual being involved with plant performance to ensure the plant is operated in a safe, reliable, and efficient manner. The Nuclear Assessment Section (NAS) evaluates 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 the Vice President - Harris Nuclear Plant and ensuring adequate action is taken to correct and eliminate these conditions.

2227nri.717

l 7

1 r~

'\ ll h'jj, Tg P'c.

4 f

J l

17.3.1.2 Or anization The CP8cL 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 Executive Vice President - Nuclear Generation Group.

Procurement documents require suppliers to operate in accordance with QA programs which are compatible with the applicable requirements of the CPAL'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 affecting the safe and reliable operation of the Company'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 inspections 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 NAS shall independently monitor and assess the Company's nuclear programs on a continuing basis. The NAS performs assessments which incorporate the previous QA audits. These evaluations are performance based with emphasis on quality of the end product.

A periodic briefing of NAS activities, along with any potential issues and recommendations, shall be presented to the Executive Vice President - Nuclear Generation Group. The Manager - NAS shall have access to the corporate management up to and including the Executive Vice President - Nuclear Generation Group to resolve any quality or nuclear safety related concerns if the concerns cannot be resolved satisfactorily at a lower management level.

The Performance Evaluation Section is responsible to ensure that the results and effectiveness of the NAS organization and processes in accomplishing its assigned objectives will be regularly evaluated, but at a frequency not to exceed 24 months.

2227nri.717

V I p

~!

g 1

tl

(

C, ql P

V 1

t

17.3.1.4 ~Authorit 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 and OJT), examining, and/or certifying, as appropriate.

Personnel training and qualification records are to be maintained in accordance with plant procedures.

Personnel within the Operating organization performing duties of a licensed operator are indoctrinated, trained, and qualified as required by 10 CFR 55.

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.

2227nri.717

I 7

,p

,1

)4 J

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 are reported to appropriate management for review and evaluation.

Periodic review and evaluation of adverse trends are performed by management.

17.3.1.7 Re ulato 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 exceptions for CP&L to follow are presented in Section 1.8 in this FSAR. The requirements of this section (17.3) may provide additional exceptions to these regulatory guides and codes and standards.

The Nuclear Regulatory Commission shall be notified of changes to the QA Program description in accordance with 10 CFR 50.54(a)(3).

2227nri.717

h f (

4 P

CI k

lg

17.3.2 PERFORMANCE/VERIFICATION 17,3.2.1 M~dd I 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 1 2 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.

Measures 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-related functions of structures, systems, and components.

2227nri.717

I S

D I

1r

/V r

+ lk II,4

'L q

t

c) Materials, parts, and equipment which are commercial grade items or which have been previously approved for a different application are evaluated for suitability prior to selection.

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 cont'rolled, 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 activities 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.

2227nri.717

I

~'

U I

~1

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 Safety Analysis Report (SAR) commitments have been addressed.

c) Qualification tests to verify the adequacy of the design are performed using the most adverse specified design conditions.

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 CP&L maintains a program for supplier evaluation, results of supplier evaluation, surveillance of suppliers, supplier furnished records, certificates of conformance, effectiveness of supplier quality control, and the purchase of spare or replacement parts.

Procedures 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 contract when needed to assure the contractor's or supplier's capability to comply with applicable technical and quality requirements.

Procurement documents, such as purchase specifications, contain or reference the following:

a) 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.

c) Identification of those records to be retained, controlled, and maintained by the supplier, and those delivered to the purchaser prior to use or installation of the hardware.

2227nri.717

C h

4

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 installation or use.

d) Items not meeting applicable requirements are identified and controlled until proper disposition is made.

Appropriate controls and provisions have been included in procurement procedures 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 CP&L 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 inspection 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.

2227nri.717

PW 0P

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 CPEcL 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.

17.3.2.7 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.S 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.

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.

2227nri.717

l

~~

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.

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.

b) Required accuracy.

c) Intended use.

d) Frequency of usage.

e) Stability characteristics.

Other conditions affecting measurement.

g) Manufacturer's recommendations.

Status of calibration for measuring and test equipment is provided through the use of tags, stickers, labels, routing cards, computer programs, or other 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 M&TE in question. The evaluation is reviewed in accordance with approved procedures.

2227nri.717

(,

h F

t, Afl I,'I L

~

'I gj I

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, if the measuring and test equipment is found to be out of calibration.

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.

These procedures include the application, removal, and verification of inspection and welding stamps, or other status indicators as appropriate.

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 indicate 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 available for verification.

2227nri.717

4 4,

C-C I

I A

gk t

,g I 4

I

17.3,2.12 ~Ins ection 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 qualified 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) Recording the results of the inspection, review of the results, and identification of the inspector.

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.

Modification, repairs, and replacements are inspected in accordance with the original design and inspection requirements or acceptable alternatives.

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 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.

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).

2227nri.717

4 l

I

'y 1

'V I

I

~

't

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.

Changes to documents are reviewed and approved by the same organization that performed the original review and approval or by other designated qualified responsible organizations.

Controlled documents are to be distributed to and used by the person performing the activity in accordance with plant procedures.

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.

17.3.2.15 Records 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.

2227nri.717

I l t

17.3.3 ASSESSMENT 17.3.3.1 M~hd I The overall objective at CPEcL is to encourage ownership, involvement, and dedication by each individual supporting the Nuclear Generation Group. 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 CPS'uclear Generation Group is improving on a continual basis. This process, along with an effective corrective action program, ensures'hat 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 assessments, 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 Generation Group are responsible for ensuring that self-assessment activities and processes are implemented within their functions on a continuing basis.

17.3.3d2 Self-Assessment

'I 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.

Self-assessment activities are not necessarily a documented activity and personnel performing self-assessment do not require any special training and/or qualifications beyond that required to hold their present position.

Line Or anization Each individual, work group, and manager should be aware of 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.

2227nri.717

t kg

'd p.

k C,

'E

%f

Self-assessment activities focus on how well the 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 Performance Evaluation Section, in the Nuclear Services Department, shall monitor specific functional areas, along 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 plant to improve implementation of CPSs Nuclear Generation Group programs and processes to support safe and reliable operation.

17.3.3.3 Inde endent Assessment The NAS is responsible for conducting independent assessments of functions and activities affecting the nuclear plants at CPAL.

Or anization 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 NAS 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 NAS 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 The independent assessment process includes gathering data, analyzing data, focusing on selected issues and identifying deficiencies to desired performance.

The results of independent 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 measures adopted to eliminate the deficiencies identified.

2227nri.717

1A) 1 a',

~ 'g et

~

1 g'L

Data is gathered using performance based techniques during:

o Observations of work activities (including line organization self-assessment activities),

Interviews, Reviews of documents to gather information (including the use of NRC, INPO, and other agency evaluations),

Nuclear Safety Review activities, Team independent assessments 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 independent assessment, and the applicable acceptance criteria. Independent Assessment activities are selected with flexibility based on various factors. These factors include but are not limited to: importance to safety and reliability, NAS independent 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, previous assessment data, industry experience, team member experience, and management input. These activities enable the team to focus on 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.

NAS Assessment Pro ram Assessments of facility activities shall be performed by the NAS. Assessments will be performance based and will be scheduled based on plant performance and importance to safety but at a frequency not to exceed 24 months. These assessments shall encompass:

a. The conformance of facility operation to provisions contained within the Technical Specifications and applicable license conditions.

b. The performance, training and qualifications of the facility staff.

c. The results of actions taken to correct deficiencies occurring in facility equipment, structures, systems or method of operation that affect nuclear safety.

2227nri.717

d. The performance of activities required by the Operational Quality Assurance Program to meet the criteria of Appendix B, 10 CFR 50.

e. Any other area of facility operation considered appropriate by the Vice President - Harris Nuclear Plant.

f. The Fire Protection Program and implementing procedures.

g. The Radiological Environmental Monitoring Program and the results thereof.

h. The OFF-SITE DOSE CALCULATIONMANUALand implementing procedures.

i. The PROCESS CONTROL PROGRAM and implementing procedures for processing and packaging of radioactive wastes.

Assessments of activities prescribed by the Code of Federal Regulations will be performed at the frequencies prescribed by the applicable regulation. These assessments shall encompass:

a. Emergency Preparedness (per 10 CFR 50.54(t))

b. Security (per 10 CFR 50.54(p))

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 independent assessments, special investigations, and analysis of data will be provided to NAS management for review. A periodic briefing of NAS activities, along with potential issues and recommendations, shall be presented to the Senior Nuclear Operating Officer, the Executive Vice President - Nuclear Generation Group.

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.

2227nri.717

SHNPP FSAR areas shalL be recorded. Unloading or pick-up of material shall not be

~

considered "access,"u nor shall inspection by NRC or other regulatory agents,

~

nor shall tours by non"CP&L employees who are accompanied by CPSL employees.

y) Paragraph 7.3 - Hoisting Equipment - The load chart for each crane includes the model number for that crane. This load chart is considered to be "Certification" by the manufacturer for that crane as required by paragraph 7.3.1. Likewise, forklifts are considered certified 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 of hoisting the equipment will be complied with.

If rerating of hoisting equipment is necessary and CPSL cannot or does not contact the equipment manufacturer as described above, the test weight used in temporarily rerating hoisting equipment for speciaL lifts wiLL be at Least equal to 110 percent of the lift weight. A dynamic Load test over the full lift range of the lift using a weight at least equal to the weight will be performed.

z) Paragraph 7.4 Inspection of Equipment and Rigging Nondestructive examinations, will be performed by~QC personneL qualified in accordance with Regulatory Guide 1.58 (except as amended by safety 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, adhesives, 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 to limit or preclude intergranular cracking and stress corrosion cracking.

FSAR

Reference:

Section 173, P P ~ << > (sea euWs~r~ ~Q 1.8-50d Amendment No. 41

I ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 QUALITYASSURANCE PROGRAM CHANGE DESCRIPTIONS NOT RE VIRING NRC APPROVAL NFORMATION ONL INCLUDING REASONS FOR CHANGE PROPOSED CHANGE NO. 1 - FSAR SECTION 1.8 REGULATORY GUIDE 1.8 PAGE 1.8-9 The proposed change deletes "members of the QA Staff'nd replaces it with the words "personnel performing inspections."

Reason for Chan e This will allow any personnel, in addition to Nuclear Assessment Section (NAS) personnel, to be qualified to perform inspections in accordance with our commitments to Regulatory Guide 1.58. This supports our efforts to have material control personnel, not a part of the NAS, to perform receipt inspections. This is not a reduction in commitment in the QA Program because personnel performing inspections continue to meet the same qualifications.

PROPOSED CHANGE NO. 2 - FSAR SECTION 1.8 REGULATORY GUIDE 1.28 PAGE 1.8-36. REGULATORY GUIDE 1.30 PAGES 1.8-38 and 38a REGULATORY GUIDE 1.33 PAGE 1.8-42'SAR SECTION 1.8 REGULATORY GUIDE 1.37 PAGE 1.8-49'SAR SECTION 1.8 REGULATORY GUIDE 1.38 PAGES 1.8-50a and 50d FSAR SECTION 1.8 REGULATORY GUIDE 1.39 PAGE 1.8-51'SAR SECTION 1.8 REGULATORY GUIDE 1.54 PAGE 1.8-67 FSAR SECTION 1.8 REGULATORY GUIDE 1.64 PAGE 1.8-79 FSAR SECTION 1.8 REGULATORY GUIDE 1.116 PAGE 1.8-147 FSAR SECTION 1.8 REGULATORY GUIDE 1.123 PAGES 1.8-155 and 157 The proposed change deletes references to Section 17.2.

Reason for Chan e The requirements of the QA Program described in FSAR Section 17.2 have been relocated to FSAR Section 17.3. FSAR Section 17.3 is for descriptions of performance based QA Programs. The references are being revised or deleted as appropriate. This is an editorial change and does not reflect a reduction in commitment.

2227nri.717 E3-1

Es E.

e 1

lg

~1 C

PROPOSED CHANGE NO. 3 - FSAR SECTION 1.8 REGULATORY GUIDE 1.33 PAGE 1.8-42a Addition of clarification "m" which provides a reference to Section 17.3 for a description of controls for Measuring and Test Equipment (M&TE).

Reason for Chan e The clarification references where additional clarifications on controls for M&TE 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 M&TE are located in the program. This is an editorial change and does not reflect a reduction in commitment.

PROPOSED CHANGE NOS. 4 and 5 - FSAR SECTION 1.8 REGULATORY GUIDE 1.38 PAGES 1.8-50 and 1.8-50a Pro osed Chan e No. 4 The proposed change deletes the word "operational" describing the QA Program.

Reason for Chan e Deletion of this word adds consistency to the method in which this program is written.

This is an editorial change and does not reflect a reduction in commitment.

Pro osed Chan e No. 5 See Enclosure 2, Proposed Change No. 5.

PROPOSED CHANGE NO. 6 - FSAR SECTION 1.8 REGULATORY GUIDE 1.58 PAGE 1.8-71 The proposed change deletes the words "Operating Plant QA" and adds receipt inspection personnel to the list of personnel qualified per this standard as stated in this position.

Reason for Chan e To clarify exceptions to this regulatory guide based on organizational and functional changes. This does not reflect a reduction in commitment.

2227nri.717 E3-2

C 4

J gk l

4 y "h

4

~ t

PROPOSED CHANGE NO. 7 - FSAR SECTION 1.8 REGULATORY GUIDE 1.74 PAGE 1.8-93 The proposed change deletes a definition that was used as part of the Audit Program.

Reason for Chan e This definition is no longer needed with the description of the assessment process in Section 17.3. This is not a reduction in commitment.

PROPOSED CHANGE NOS. 8 and 9 - FSAR SECTION 1.8 REGULATORY GUIDE 1.88 PAGES 1.8-118 AND 1.8-118a Pro osed Chan e No. 8 The proposed change revises the responsibility for justifying, evaluating, and approving exceptions to the temporary storage of records requirements from the Manager - Nuclear Assessment to the Vice President - Harris Nuclear Plant or his designee. Also, the word "QA" is changed to "Nuclear Assessment Section" for certain records requirements.

Reason for Chan e The proposed organization deletes the Manager - Nuclear Assessment position. This change places the responsibility for controlling exceptions to the temporary storage of records requirements at the appropriate level in the line organization. The other changes reflect new organizational titles.

This is not a reduction in commitment.

Pro osed Chan e No. 9 Addition of clarification "k" which provides a reference to Section 17.3 for a description of controls for QA records.

Reason for Chan e This addition references where additional clarifications on controls for 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. This is an editorial change and does not reflect a reduction in commitment.

2227nri.717 E3-3

l, F

I

~ ~~>

gp gt P )'

PROPOSED CHANGES NOS. 10 11 and 12 - FSAR SECTION 1.8 REGULATORY GUIDE 1.123 PAGES 1.8-155 157 and 158 Pro osed Chan e No. 10 The proposed change deletes the specific reference to QA for evaluating a supplier's QA program. The specific responsibility for this activity is now with the Vendor &,

Equipment Quality Unit in the Nuclear Services Department.

Reason for Chan e Section 13.1 of the FSAR includes this responsibility.

The proposed organization places this function in the Nuclear Services Department.

Reorganization of this function has not changed the implementation of this function.

This is not a reduction in commitment.

Pro osed Chan e No. 11 The proposed change deletes the specific phrase "for the operating phase."

Reason for Chan e Deletion of this word adds consistency to the method this program is written. This is an editorial change and does not reflect a reduction in commitment.

Pro osed Chan e No. 12 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.

This is not a reduction in commitment.

2227nri.717 E3-4

l'.

P

'I sg l

I) i t

.i v A,%

PROPOSED CHANGE NO. 13 - FSAR SECTION 1.8 REGULATORY GUIDE 1.144 PAGES 1.8-182 183 and 184 The proposed change modifies clarifications "e," "g," "h," and "i" and adds new clarification "I" to Regulatory Guide 1.144.

Reason for Chan e There is no change for external audits. The proposed change reflects the use of the word assessment in place of the word audit for internal evaluations and provides an explanation of the terminology of the assessment organization.

Changing the terminology does not change the way these assessments are performed.

This does not reflect a reduction in commitment.

PROPOSED CHANGE NOS. 14 AND 15 FSAR SECTION 1.8 REGULATORY GUIDE 1.146 PAGE 1.8-186 Pro osed Chan e 14 The proposed change modifies the wording for clarification "2" to Regulatory Guide 1.146 to reflect the terminology of the assessment organization.

Reason for Chan e There is no change for external audits. The proposed change reflects the terminology of the NAS organization. Changing terminology and organizational titles to reflect the current organization does not affect the way that this Regulatory Guide will be applied.

This does not reflect a reduction in commitment.

Pro osed Chan e No. 15 The proposed change deletes paragraph "4" regarding record retention of qualification records.

Reason for Chan e Regulatory Guide 1.88'ANSI N45.2.9-1974 (see proposed change 9) was revised to reference Section 17.3. This reference is being removed for consistency with the method to which the QA Program is written. This is an editorial change and does not reflect a reduction in commitment.

2227nri.717 E3-5

J V

V A

"t I 4.

PROPOSED CHANGE NO. 16 - FSAR SECTION 9.5 FIRE PROTECTION PAGE 9.5.1-56 The proposed change deletes references to the QA organization and specific responsibilities assigned to the QA organization relative to fire protection. Section 17.3 is referenced to address the NAS organizational and specific responsibilities relative to fire protection.

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 NAS. This is an editorial change and does not reflect a reduction in commitment.

PROPOSED CHANGE NO. 17 - FSAR SECTION 13.1 ORGANIZATIONALSTRUCTURE OF APPLICANT The proposed change identifies the organizational changes created by the re-organization of the NAD and the creation of the Performance Evaluation Section in the Nuclear Services Department. This includes elimination of the NAD and realignment of the NAS reporting to the Vice President - Harris Nuclear Plant. This does not reflect a reduction in commitment. The changes to FSAR Chapter 13 will be submitted in accordance with 10 CFR 50.71(e).

Reason for Chan e These organizational changes are to improve plant performance through strengthened self-assessment and to increase accountability for effective corrective action within the plant organization.

The proposed organizational structure with the Manager - NAS reporting to the Vice President - Harris Nuclear Plant continues to provide access to a level of management sufficient to demonstrate independence.

PROPOSED CHANGE NO. 18 - FSAR SECTION 13.4.2 INDEPENDENT REVIEW PAGE 13.4.2-1 The proposed change deletes the details about the Independent Review function 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. This is an editorial change and does not reflect a reduction in commitment.

2227nri.717 E3-6

1 E

4 C

E

~ i C '>

C

PROPOSED CHANGE NO. 19 - FSAR SECTION 13.4.3 AUDIT PROGRAM PAGES 13.4.3-1 13.4.3-2 and 13.4.3-3 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. This is an editorial change and does not reflect a reduction in commitment.

2227nri.717 E3-7

SHNPP FSAR

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 in 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 positions 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 conaensurate to the fugctions and responsibilities these employees will perform.

4) Paragraph 4.5.1.2 describes the requirements for licensed operators.'P&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, "gualification 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.

6)

P~r'~y M@K p~r yn ge' H~

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 CP6L'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 Program.

j o Ba CAaQ 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:

as determined by responsible

'nd a) Paragraph 2.1, Planning'. Requirements, plant management, will be incorporated into procedures.

b) Paragraphs 2.2 and 2.3; Prerequisites, Procedures, and Instructions'.

these controls will be implemented as determined by responsible plant management in approved procedures.

c) Paragraph 2.4, Results, will be implemented as set forth in sections by compliance with Regulatory Guide 1.33.

]0 d) Paragraph 2.5, Measuring and Test Equipment, will be implemented as set forth in Section 17.~in lieu of the requirements set forth in this paragraph. 3 I

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 planned/done.

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 required or not.

g) Paragraph 5 ', Inspections, including subparagraphs 5 the first sentence in 5.1.3, will be implemented as set forth in

'.1, '.2, 5 and Section 17.krk8; '3The remaining sentence in 5.1.3 is covered in equivalent detail by CP&L's commitment to Regulatory Guide 1.33, paragraph 5.2.6; the requirements as set forth in that commitment will be implemented in lieu of the requirements stated here.

h) Paragraph 5 2, Tests, including subparagraphs 5.2.1 through 5.2.3, will be implemented as set forth in Sections 17. . . . The test program will consider the elements outlined in this3paragraph when developing test requirements for inclusion in maintenance and modification procedures. In some cases, testing requirements may be met by post-installation surveillance 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 relatively short interval between installation and operation.

1.8-38 Amendment No. 41

SHNPP 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 comply with 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 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 responsible plant management, for the performance of analyzing test data, but these procedures are not referred to as data processing procedures.

3 FSAR

References:

Sections 8.3.1.2, 17.

1.8-38a Amendment No. 41

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 4 1 I management and shall be based on the effect of the condition on the immediate health and safety of the public.

41)g g) Paragraph 5.2.8, Surveillance Testing and Inspection Schedule: In lieu of a "master surveillance schedule," the following requirement shall be

'n complied with: "surveillance testing schedule(s) shall be established reflecting the status of all planned in"plant surveillance tests and inspections."

4]) Q @ Paragraph 5.2.9, Plant Security and Visitor Control, requires certain O procedures and controls. In order to ensure that a conflict between 10CFR73 and Regulatory Guide 1.17 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 fuel loading.

8 P Q) Paragraph 5.2.11, Corre tive Action, requires certain activities to be performed. In order to avoid nflict between requirements, CP&L shall follow the requirements in Section 17 lieu of 4 1 Paragraph 5.2.11 as additionally clarified in above paragraph (d).

J Q 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( ~ Q 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 to calibrate a number of plant instruments. Thus, a calibration error could 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 operability 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

4 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 calibration status" versus "suitably marked to indicate calibration status." In addition, a review of out"of-calibration process instruments will be made to determine if action is required to prevent recurrence. Suchmaintenance.

action may include modification, procedural revision, or corrective 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 procedure or document serving as the record. Records of inspections will be identifiable and retrievable.

L Q 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.

Id Jm

~

cf'a" + + Prov t ae(d>l ioQcLL e~cpic gmsAz Sor C.etJT~L o0 foal +~ E GE 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 Guide 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 41 b) Paragraph 5, Installation Cleaning'The recommendation that local )41 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 to those areas of the Quality I41 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 )41 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 1.37: 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, SHIPPING, RECEIVING, STORAGE, AND HANDLING OF ITEMS FOR WATER-COOLED NUCLEAR POWER PLANTS (REV. 2)

Carolina Power 6 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:

a) Paragraph 2.1, Planning: (First sentence) the specific items to be governed by the Standard shall be identified. However, the Standard is part 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 personnel that perform inspection, examination, and testing activities for verification and acceptance/rejection purposes shall be qualified in accordance with Regulatory Guide 1.58.

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 properfunctioning 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: CPSL 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

v.

MO 4

SHNPP FSAR E) 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 Eor shipment off-site will be equal to or exceed the original packaging by the vendor, as required to assure the quality of the item is not degraded as a result of shipping or handling.

h) Paragraph 3.4, Methods of preservation'(First sentence) CPSL 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, CP6L 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 Eor 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 be documented and dispositioned as required by FSAR Section 17.~.5The person performing the visual scrutiny during unloading is not considered to be performing an inspection function as defined under Regulatory Guide 1.74; therefore, while he will be trained and qualified to perform this Eunc'tion, he may not necessarily be certified (N45.2.6) as an Inspector.

cr m) Paragraph 5.2.2, Item Inspection: The need and extent for inspection of items will be determined by responsible plant technical personnel'eceiving inspections shall be performed in an area designated for receipt of material and shall normally be performed in the receiving buiLding. The receiving building and the areas designated will provide adequate protection Eor the material, but may not comply with all of the specific requirements contained 1.8-50a Amendment No. 41

SHNPP FSAR areas shall be recorded. Unloading or pick"up of material shall not be

~

~ ~

considered "access," nor shall inspection by NRC or other regulatory agents, nor shall tours by non-CPSL employees who are accompanied by CP&L employees.

y) Paragraph 7.3 Hoisting Equipment - The load chart for each crane includes the model number for that crane. This load chart is considered to be "Certification" by the manufacturer for that crane as required by paragraph 7.3.1. Likewise, forklifts are considered certified by the manufacturer's Literature giving maximum capacity as required by paragraph 7.3.2.

Paragraph 7 ', 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 of hoisting the equipment wiLL be complied with.

If rerating of hoisting equipment is necessary and CPSL cannot or does not contact the equipment manufacturer as described above, the test weight used in temporarily rerating hoisting equipment for 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 performed.

z) Paragraph 7.4 Inspection of Equipment and Rigging - Nondestructive examinations, will be performed by-fgd'QC personneL qualified in accordance with Regulatory Guide 1.58 (except as amended by safety 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, adhesives, 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 to limit or preclude intergranular cracking and stress corrosion cracking.

FSAR

Reference:

Section 17.+

l <<> (see. eucksur~ s) 1.8-50d Amendment No. 41

SHNPP FSAR Regulatory Guide 1.39 HOUSEKEEPING REQUIREMENTS FOR WATER COOLED NUCLEAR POWER PLANTS (REV. 2)

Carolina Power & 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'.

1) Paragraph 2.1, Planning: The 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, Surveillance, Inspection, and Examinations:

Subparagraph (1) is not applicable during normal operations but will be implemented if large items are to be moved or handled.

SSAR Refetence: Section 17$ 3 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 '4 endorses ANSI N101.4-1972. The SHNPP project complies .

with the requirements of ANSI N101.4-1972, as it is endorsed by this guide for protective coatings for containment surfaces (steel and concrete) and exposed surfaces of large equipment and pipe.

FSAR

Reference:

Section 17+ 3

1. 8-67 Amendment No. 5

SHNPP FSAR Regulatory Guide 1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, EXAHINATION AND TESTING PERSONNEL (REV. 1)

Carolina Power & Light Company shall comply with NRC Regulatory Guide 1.58, Revision 1, which endorses 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 required to meet ANSI N45.2.6-1978 requirements:

Examination (NDE) personnel wad- (2) personnel> md (3) pece~pT gasped'eg pRgontH<L

'QC requirements. Only personnel in the folLowing listed categories will be (1) Nondestructive inspection C d 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) Mith regard to Paragraph 2.5 of Aggi N45.2.6-1978 titled ~ph eical:

Carolina Power & Light Company will. implement the requirements of this Section with the stipulation that, where no special physical. characteristics are required, none will be specified. The converse is also true: if no special physical requirements are stipulated by CP&L, none are considered necessary.

Carolina Power & Light Company employees receive an initial physical personnel ~ (2) 'QC examination to assure satisfactory physical condition; however, only the following listed personneL will receive an annual examination: (1) NDE inspection personnel examination shall consist of the near visual acuity using t Jaeger's type chart or equivalent test.

This annual standard aHd (N'5 Receipt X14epecIfthai 15ersthhiNNL 41 c/

With regard to Paragraph of ANSI N45.2.6-1978 titled 41 d) 3 [

twill be grouped in levels of 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 ~/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 maintained and performance evaluations conducted at least on an every three year basis.

1.8-71 Amendment No. 41

l

'I

) 1 p

SHNPP FSAR Regulatory Guide 1.64 QUALITY ASSURANCE REQUIREMENTS FOR THE DESIGN OF NUCLEAR POWER PLANTS (REV. 2)

Carolina Power & Light Company shall comply with NRC Regulatory Guide 1.64, Rev. 2, which endorses ANSI Standard N45.2.11-1974 with the following clarification:

Paragraph C.2(1): For the exceptional circumstance in which the designer's immediate Supervisor is the only technically qualified individual available, this review can be conducted by the Supervisor, provided that: i) the other provisions of the Regulatory Guide. are satisfied, ii) the, justification is individually documented and approved in advance by the Supervisor's management, and iii) quality assurance audits cover frequency and verifiers to guard against effectiveness of the use of Supervisors as design abuse.

FSAR

Reference:

FSAR Section 17.$ '3 1,8-79 Amendment No. 5

SHNPP FSAR Regulatory Guide 1.74 QUALITY ASSURANCE TERMS AND DEFINITIONS (REV. 0)

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 procedures, 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 organiza'tion personnel) Examining, viewing closely, scrutinizing, looking over or otherwise checking activities. Personnel "

performing these functions are not necessarily certified to ANSI N45 ~ 2e6 ~

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. If 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 include 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).

Q Deficiencies" (Nct defined in ANSI N45.2.10, but used end defined differently in o develop, document or implement effectively any applicable element of the QA Program.

e) "Quality Assurance Program Requirements" (Not defined in ANSI N45.2.10, but used and defined differently in ANSI N45.2.13) 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 activity being controlled. Although not specifically used in the Operational QA 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 Amendment No. 3

SHNPP FSAR Regulatory Guide 1.88'OLLECTION, STORAGE AND MAINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS (REV. 2)

Carolina Power 6 Light Company shall comply with NRC Regulatory Guide 1.88, Rev. 2, which endorses ANSI N45.2.9"1974 with..the foLLowing cLarification...')

Appendix A of ANSI N45.2.9 is not considered to be a mandatory list.

list will be This used as a need to be maintained as QA records.

determination is made as to whether

~

guideline for classifying those documents that concurrence wiLL be required when the particular type of document needs to be classified as a QA record and its propriate retention period.

H4QMAR 4SS~nbv7 SGcT(og (g AQ eh~A) b) Paragraph L.4, Definit' The phrase "when the document has been completed" is clarified mean when the document has received the final review performed b e organizationa lement responsible for generating or 41 require ~ review prior to.transmittal to Project Document Services for permanent storage. Ir 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 I41 "completely filled out" is clarified to mean that sufficent information is recorded to fulfill the intended purpose of the record. 41 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 delineated by a computerized indexing system plus a storage 41 area LabeLing system which provides information by record type and storage medium.

e) Paragraph 4.2, Timeliness.'arolina Power h Light Company's contractual )

41 agreement with its contractors and suppliers will constitute fulfillment of the requirements of this paragraph.

containers' 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

" The following clarification is substituted for the current 141 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 41 recommendations will. be considered as appropriate."

g) Paragraph 5.5, Safekeeping'. Routine general office and nuclear site I 41 security systems and access controls are provided. No special security systems are required to be established for record storage areas.

h) Paragraph 5.6, Facility.'his 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 I41 1.8-118 Amendment No. 41

I g 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 or an extended period of time at the location of the work group responsible r generating the records and records which are cumulative in nature and co ld best be turned over for storage for a designated period of time.

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 nd NRC Criteria for Record Stora e Facilities (Guidance - ANSI N45.2.9, Section5.6) issued 7/I/80.

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 with a minimum two-hour fire protection rating."

I Vice-Presi peony Harr is QacLeac I'laA" or his Jesigwec.

o Adcti'fiauaL i"larikicatioNs for ~p, records ore prov(ctoJ ig St eTtoH I'7.3 I.S-IISa Amendment No. 44

I 4

~ g I II V

I'l 0

l 4 4 4

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 1976, with the following clarifications.

a) Paragraph 2.1, Planning: Requirements, as determined by responsible plant management, will be incorporated into procedures')

Paragraph 2.3, Results, will be implemented as set forth in Sections 17 , . . . and by compliance with R.G. 1.33.

8 c) Paragraph 2.8, Measuring and Test Equipment CP&L has addressed this 41 requirement for the o~eratio al phase of the plant in Section 17.~

3 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 to 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.

g) 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 Regulatory Guide 1.123 QUALITY ASSURANCE REQUIREMENTS FOR CONTROL OR PROCUREMENT OF ITEMS AND SERVICES FOR NUCLEAR POWER PLANTS (REV ~ 1)

" shall comply with the requirements of Carolina Power & Light Company ANSI N45.2.13-1976 as it is endorsed by Regulatory Guide 1.123 with the following clarifications:

a) Paragraph 1.2.2, Purchaser's Responsibilities: Item c is one of the options which may be used by CP&L to assure quality; however, any of the options given in 10CFR50, Appendix B, Criterion VII as implemented by Sections 17. . may also be used. Evaluation of supplier's QA program will be conActed depending on complexity and end use of item.

P st Cl 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 and 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 N

2) Used in applications other than facilities or activities licensed by the Nuclear Regulatory Commission'and

3) Ordered from the manufacturer, distributor, supplier or retailer on the basis of the manufacturer's catalog or product description.

Special quality verification requirements shall be determined, as necessary, 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.

d) 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. 8 f) Paragraph 4.2, Selection Measures, outlines certain methods acceptable for the selection of suppliers. Carolina Power & Light Company's history of using similar methods has proven adequate in the procurement of CP&L wishes to replace paragraph 4.2(a), (b), and (c) with the items'herefore, following selection methods:

1.8-155 Amendment No. 43

! E SHNPP FSAR g) Paragraphs 5.2 and 5.3 shall be applied to the extent determined by responsible plant management based on complexity of the item and its end use. It is not intended that these paragraphs be applied to spares or replacement parts that do not change original design intent.

h) Paragraph 6.1, General, outlines methods for monitoring and evaluating supplier performance. Carolina Power & Light Company wishes to replace paragraph 6.1(a), (b), (c), (d), and (e) with the following methods for monitoring and evaluating supplier performance:

1) Reviewing documents generated or processed during activities fulfilling procurement requirements.

2) Reviewing LER's.

3) Periodic audits

4) Annual evaluations Those controls specified in 3

Section 17.

5) FSAR 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 be used in lieu of the requirements of ANSI N45.2, Section 7.

j) Paragraph 7.4, Measuring and Test Equipment, outlines certain measures to be taken. Carolina Power & 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. 3 k) Paragraph 8 provides guidance for purchaser review and disposition of vendor nonconformances. CP&L, as purchaser, requires as a minimum deviations to procurement documents and previously approved supplier documents that cannot be brought into conformance prior to shipment of the material to be submitted to CP&L for approval. Such deviations, when approved by purchaser, are required to be submitted 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 of the recommended disposition prior to shipment, when the nonconformance could adversely affect the end use of a -'module or shippable component relative to safety, interchangeability, operability, reliability, integrity, or maintainability:

1) Technical 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 & 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, action activities associated with items of high volume and which are considered significant to safety in cases where vendor's recent performance has appeared marginal.

m) Paragraph 10.2a: CP&L 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 Regulatory Guide 1.144 AUDITING OF QUALITY ASSURANCE PROGRAMS FOR NUCLEAR POWER PLANTS (REV. 0)

Carolina Power & Light Company shall comply with requirements of Regulatory Guide 1.144, January 1979, which endorses ANSI N45.2.12-1977 with the following clarifications.

a) C.3.(b)(2): The concepts of when audits are required, i.e., annually, tri.ennially, will be complied with; however, such audits would only be require'd of the vendor i.f the vendor is involved with an active contract/procurement document. This concept is as discussed in Paragraphs 3.5.3 ' and 3.5 '.2 of ANSI N45.2.12-1977.

b) Paragraph 2.3, Training: The training of CP&L audit personnel will be accomplished as described in CP&L's position on Regulatory Guide 1.146.

c) Paragraph 2.4, Maintenance of Proficiency: The maintenance of proficiency of CP&L audit personnel will be accomplished as described in CP&L's position on Regulatory Guide 1.146.

d) Paragraph 3.2.2 indicates, that ob)ective evidence is to be examined and evaluated. Carolina Power & Light Company believes that the use of sub)ective evidence is also an important element of the audit program. See Paragraph 4.3.2 clarifications below.

e) Paragraph 3.3, Essential Elements of the Audit System; Carolina Power &

Light Company will comply with subparagraph 3.3.5 as it was originally written (subparagraph 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4:

"Provisions for reporting on the effectiveness of the, quality assurance program to the responsible management." For the auditing organization (CP&L),

effectiveness is reported as required by the Technical Specifications and by CP&L's Other than audit reports, CP&L may not direc y report on the effectiveness of the quality assurance programs to the audi ed organization, when such organizations are outside of CP&L.

a,st esme~ f'~ceJ~~s Subparagraph P .. c 3.3.7 requires verification of effective orrective action on a "timely basis". Timely basis is interpreted to mean within the period of time that is accepted by the organization. Each finding requires a response and a corrective action completion date. These dates are subject to revision (with the approval of the quality organization) and must be escalated to higher authority when there is a disagreement between the audited and the auditing organization on what constitutes "timely corrective action.",

f) Paragraph 4.3 1, Preaudit Conference: Carolina Power & Light Company will comply with the requirement of this paragraph'y inserting the word "Normally" at the beginning of the first sentence. This clarification is required because, in the case of certain unannounced audits or audits of a particular operation or work activity, a preaudit conference might interfere with the spontaneity of the operation or activity being audited. In other cases, persons who should be present at a preaudit conference may not always 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 be 1.8-182 Amen at No. 5

SHNPP FSAR all inclusive, the material set forth in Paragraph 4.3.1 will normally be covered during the course of the audit.

Paragraph 4.3.2, Audit~Process:

/ASSeSSrnmi ./c /9

1) Subparagraph 4.3.2.2 could be interpreted to limit auditors to the review of only objective evidence. Sometimes objective evidence may not be available; therefore, Carolina Power & Light Company will comply with an alternate sentence which reads: "When available, ob)ective evidence shall be examined for compliance with quality assurance program requirements. If subjective evidence is used (e.g., personnel interviews, direct observations by the auditor), then the audit report or checklist must indicate how the evidence is obtained."

2) Subparagraph 4.3.2.4 is modified as follows to take into account fact that some nonconformances are virtually "obvious" with regards 'he to the needed corrective action. As a result of this, CP6L proposes the following alternate words: "When a nonconformance or quality assurance program deficiency is identified as a result of an audit, unless the apparent cause, extent, and corrective action is readily evident, further investigations shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the extent of the corrective action required."

3) Subparagraph 4.3.2.5 contains a statement "acknowledged by a member of the audited organization". This is clarified to mean that "a member of the audited organization has been informed to the findings.

Agreement or disagreement with a finding may be expressed in the response from the audited organization."

4) Subparagraph 4.3 ' ' is modified as follows to account for the fact that immediate notification is not always possible: "Conditions-requiring immediate corrective action (i.e., those which are so severe that any delay would be undesirable) shall be reported as immediately as practical to management of the audited organization."

h)

Q.SSCSSKQAT$

Paragraph 4.3 will snbstitnte

', Post Audit Conference:

and comply Carolina Power 6 Light Company with the following paragraphs: "For all external a s, a postaudit conference shall be held with management of the audited g organi on to present audit findings and clarify misunderstandings'here no adverse ings exist, this conference may be waived by management of the g

audited organiza on. Such waiver shall be documented in the audit report.

For all internal unless unusual operating or maintenance conditions

/

eetd~mtee shall be held with managers/supervisors. If there are no adverse findings, management of the internal organization may waive the Such waiver s ll be documented in the ~$ 44 report."

c,ssessmeff debei Q.SS~~pgg i) Paragraph 4.4, Reporting:

1) This paragraph requi s that the aud report shall be s ned by the audit team leader which s not always t e most expeditiou route for the audit report to be issued soon as pra tical. Carolina Power 6 Light Company will comply with P agraph 4.4 s clarified by the P oP C'A 1.8-183 Amend t No. 5

i P

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 copy of the report must be signed by the Lead Auditor upon his return. The report shall not require the Lead Auditor's review/concurrence/signature if the Lead Auditor is no longer employed by CP&L at the time audit report is issued.

2) Carolina Power 6 Light Company will comply with subparagraph 4.4.3 claxified to read: "Supervisory level personnel with whom significant discussions were held during the course of preaudit (where conducted),

audit, and postaudit (where conducted) activities.

3) Audit reports may not necessarily contain an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited, as required by subparagraph 4.4.4, but they will provide an effectiveness summary of the audited areas."

QLLcLeac hssgssglt g 5~N<aA Nab)tx~elAl'QT

4) Subparagraph 4.4.6 ~ will deteraKne the need for audit reports to include recommendations for corrective actions.

j) Paragraph 4.5.1, By Audited Organization: (hrolina Power 6 Light will comply with the following clax'ification of this paragraph:

Company "Management of the audited organization or activity shall review and investigate all adverse audit findings, as necessary, (cause, etc.) to determine and schedule appropriate corrective action including action to prevent recurrence. They shall respond, in writing, within thirty days after the date of receipt of the audit report. The response shall clearly state the corrective action taken or planned to prevent recurrence and the results of the investigation if conducted. In the event that corrective action is not completed by the time the response is submitted, the audited organization's response shall include a scheduled date for completion of planned corrective action. A follow-up response shall be provided stating the corrective action was completed. If corrective actions are verified as satisfactorily completed by the quality organization prior to the scheduled completion date or when completion of corrective action can be verified during a follow-up audit, no follow-up response is required. The audited organization shall take

. appropriate action to assure that corrective action is accomplished as scheduled."

k) Paragraph 5 Audit checklists are not considered QA records. CPGL believes that actual audit reports provide sufficient detail to substantiate the results of the audit, and the checklist is maintained as an audit "tool" versus a gk record. Additionally, the audit checklist need only document objective evidence examined to support the audit findings.

L) QP+L ~Coru5 44'dhruaL QA gjeraaL ~AS mS degtp+J zusx eqs.a.)a. Qe~e~ th~term assessrnedls ep~L)e~ 4 i~%rNK audits

~ ~

OP ~oC<osaL p>~ ocCivttieS md the.Car~"O.SSe swot S'pLl em

~

to IHdiv <J~g 4o perVorm ~sessm@P5 R %hase. nctlvitiEB.Xtnp+toep/fa~

~

procdll~ pcbvltZ~ s+cS'~c eppU<~ti'ogS oV those, CerraS.

p c4 J3 1.8-184 Ame~.: t No. 5

70 1

-t I

SHNPP FSAR 1

Regulatory Guide 1.146 QUALIFICATION OF gA PROGRAM AUDIT PERSONNEL FOR NUCLEAR POWER PLANTS (REV. 0, 8/80)

Carolina Power .& Light Company shall comply with requirements of Regulatory Guide 1. 146, August 1980, which endorses ANSI N45.2.23-1978 with the following clarifications.

1. Paragraph 2.2, gualification of Auditors: Subparagraph 2.2. 1 references an ANSI 845.2 (presumed to be N45.2); therefore, CP&L will comply with an alternate subparagraph 2.2. 1 which reads:

"Orientation to provide working knowledge and understanding of the CP&L gA Program, including the ANSI standards and Regulatory Guides included in the Program, and CP&L's procedures for implementing audits and reporting results."

2. Paragraph 4.1, Organization Responsibility: Carolina Power & )

Light Company will comply with this Paragraph with the substitution of the following sentence in place of the last sentence in the Paragraph.

Se.Ct1Og ~4 J> V "The Manager - Nuclear AssessmentAor the"Assessment Team Leader shall, prior to commencing the audit, assign personnel who collectively have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited."

P Pos u ~./0

3. Paragraph 5.3, Updating of Lead Auditor's Recor s: Carolina Power )

& Light Company will substitute the following sentence for this Paragraph:

"Records for each Lead Auditor shall be maintained and updated during the period of the annual management assessment as defined in Paragraph 3.2.

e1 II

<graph p.B+ 'For Assessmelvts thepros.pecIpve. Lead assessor shaLL have. pa<Oic.i~ates iu a iaiuimura aV Vive h1acLeac Iivdustry

~ype evaLuati ous ('ie. Wc ieapeatic us.J IHpo Asses".ra@Ts> MucLear

~

Assess>eut SeatiaN Amessroeii4> QA Audit>...) Oge. oV mhi c,h shaLL be. wi'thf< theyear . prior fo quaL',( icaTiou's~e euMosu~ g) 1.8-186 Amendmc" No. 44

SHNPP FSAR e fire protection QA program, wh' is under the management control of the QA anization, has assured the sat> action of QA guidelines during the design, rocurement, installation and ac tance testing of fire protection equipment systems provided for the plan and will assure their continued inspection, te ing, maintenance and administr ive control after the plant becomes operation o

s part of their managem t control, the QA organizatio as'.

1) Developed a fire p tection QA program, incorpora 'ng suitable quirements necessary for e provision of an effective 're Pro ction System,

2) Ver ied the acceptability of t fire protection QA program the managem t responsible for fire pro tion, and

3) Verified, t ough review, audit and surve ance, the effectiveness of th program for fire protectio

'Q3 QA Pi~ Pre%,~~im *

• eZmwts

' (u'e, ) geLudee The A 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 fire department members, are described in detail in the Fire Protection Procedure (FPP). Salient features of the FPP are described below. Procedures providing for a fire brigade, the 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 fire emergencies can be made. To accomplish this, 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 fire prevention and fire response education of all members of each shift crew and of support plant personnel,

4) The training, through joint drills with the fire brigade and plant operators, of the local fire department to develop both familiarity with their role in a plant-fire 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.

9.5.1-56 Amendment No. 20

t I N

l

SHNPP FSAR

. 4.~ 2

~ INDEPENDENT REVIEW

/

An f-site 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 tie collective expertise and technical competence to review problems in the llowing areas:

N lear Power Plant Operations Nuc ear Engineering Chem try and Radiochemistry Metall rgy Instrum tation and Control Radiologl. al Safety Mechanical d Electrical Engineering Administratl. e Control Seismic and E vironmental Quality Assuran e Practices Looking more at the details of the view function, the following specific items are evaluated:

Plant procedure changes meeting 10 R50.59 review criteria, Plant'design changes meeting 10CFR5 59 review criteria, Licensing actions, Test or experiments not described in t facility FSAR, Plant operational occurrences (LERs),

Regulatory violations, Technical Specification changes, Nuclear Safety Review Committee meeting minu s, Conformance to regulatory requirements, such a Plant Security and Emergency response program changes which dec ase effectiveness of the respective program, Quality Assurance Audi s conducted on site, BIld 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 flexibili and authority to call on appropriate personnel to supplement the independent view ensuring satisfactory resolution of the item. The Nuclear Safety Review 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.

Ad] Zos~C 13.4.2-1 Amendment No. 43

'h 4

INSERT FOR PAGE 13.4.2-1 13.4.2 Inde endent Review The description of the Independent Review program is contained in Section 6.5, "Review and Audit" section of the Plant Technical Specifications.

2227nri.717

SHNPP FSAR Asseasnea4 13.4.

~ ~ 3 'AtSR'ROGRAM The p ur p ose f cor p orat e operation 1 audits is to ensure an effective means of reviewing and valuating plant opera ional activities. The implementation and effectiveness o the continuing gA Pro ram shall be regularly assessed for compliance with 1 FR50, Appendix B, NR Regulatory Guide 1.33, ANSI N18.7, and N45.2.

The corporate organizat' responsible for in endent audit is the Nuclear essment Department. objective of the de rtment is to assess functions in lved in the operation o the Company's nuclea plants to assure all levels of ma agement that commitmen to Regulatory Guides nd applicable technical codes a e being carried out an regulatory requiremen are being met. The function 's described in ANSI Nl 7 as a comprehensive stem of planned and documented udits to verify compli ce of all aspects of e administrative controls and uality assurance progr s.

Carolina Power 5, ight Company's princip 1 means of achieving a effective, safe nuclear plant 's the Company's Corpo te guality Assurance ogram (CHEAP). The CHEAP ad esses design, operati , maintenance, and mo 'fication for the plant life. I covers procurement, d ign, and operation as ciated with the fabrication and ontrol of nuclear fue The role of the Nuc ar Assessment Department and e guality Verificatio Section in these prog ms is to assure that procedures re developed to imple nt each program and t t these procedures are being fol Wed.

tgz 'iggzpqPdqg assessme~J Prop~ i'l 3.S o7 <4~ FEAR The description of4au~Aaas for SHNPP is contained in Section&-.&, "Review and Audit," of the Plant Technical Specifications.

e following iteria are addre ed in developing th audit requirements for Nu ear Assessme Department audi P nt Operating nual and Procedu s.

Plant chnical Speci 'cations includin the following min um requirem ts.

The conforman of facility o ration to provis's contained wit 'he Technical Speci 'cations and ap icable license c ditions at least ce per 12 months.

13.4.3-1 Amendment No. 44

>/

'I l

SHNPP FSAR e training and qualifications of the entire facility staff at least e per 12 months.

The suits of actions taken to correct deficiencies occurring in unit equi t, 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 Appends "B", OCFRSO, at least once per 24 months.

The Emergency Pl and implementing procedures at least once per 12 months.

The Security Plan and lementing procedures at least once per 12 months.

The facility Pire Protect@ 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 vill be audited three to five times ye . 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 Asses Deparbnent is shcnm in

~ ~

Figure 13.4.2-1. When necessary to augment or qualified Company personnel independent an of audit the te, operat outside consultants-being audited may be utilized.

The areas audited and the minimum frequency of the audits are listed belier:

Nuclear Puel Section - Once per year.

Nuclear Fuel Supplier - Once during applicable time period c ed by purchase order or once every three years, whichever is shorter.

Q-List Eiodifications Performed by Plant Staff - Once per year.

Radvaste Transfer, Packaging, and Transport Activities - Once per ye 13.4.3-2 Amendment No. 43

1 4

SHNPP PSAR i% clear Engineering Department - Once per year.

Harris ant Quality Control - Once per year.

Vendor Equipm t Quality - Once per year.

Other than audit reports, he Nuclear Assessment Department communicates to Senior Management by a month report of QA audits conducted during the month including a status of the aetio 'tems and their resolution. The Manager-Nuclear Assurance Department repor to the Executive Vice President - Power Supply which provides direct communica 'on. Discussions involve an overview of the Company's various organizational 'ts'fforts in maintaining an effective QA program. In addition to these tings, the Manager - Nuclear Assessment Department meets on a regular basis Department personnel to review activities. In addition to the formal audit ctivities, the Nuclear Assessment Department Section is often called on by ot r Company members for interpretations of codes, standards, or other QA requirem s.' This contact is in an advisory role identifying acceptable modes of opera and does not compromise the unit's independence from line activities.

13.4.3-3 Amendment No. 43

4 C

~

0

~

h L

. ~