ML18022A818
| ML18022A818 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/25/1991 |
| From: | Floyd S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-91-123, NUDOCS 9107310053 | |
| Download: ML18022A818 (16) | |
Text
ACCELERATED D TRIBUTION DEMONS TION SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR: 9107310053 DOC. DATE: 91/07/25 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION FLOYD,S.D. Carolina Power & Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) R
SUBJECT:
Requests approval for change to QA program for facility.
Proposed change reflects adequacy of review processes being performed by originating organizations, elimination of redundant reviews 6 focuses on desired level of quality. D DISTRIBUTION CODE: Q004D TITLE: QA COPIES RECEIVED:LTR Topical Report, Amendment, or Correspondence I ENCL Q(Docket/Utz.lxty SIZE:
Speci 8
NOTES:Application for permit renewal filed. 05000400
/
A RECIPIENT COPIES RECIPIENT COPIES D ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD2-1 LA 1 1 MOZAFARI,B. 1 1 D
INTERNAL: ACRS 8 8 LPEB10 1 1 OC/LFMB 1 1 REG FILE 01 2 2 RGN2 FILE 1 1 EXTERNAL: IHS 1 1 NRC PDR 1 1 D
A D
D NOTE TO ALL "RIDS" RECIPIENTS PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 17
l Carolina Power R Light Company Nuclear Services Department 411 Fayetteville Street t!
Mall - P.O. Box 1551 Raleigh, North Carolina 27602 JUL 25 1991 SERIAL: NLS-91-123 10CFR50.54(a)(3)
United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50400/LICENSE NO. NPF-63 QUALITYASSURANCE PROGRAM CHANGES Gentlemen:
Carolina Power & Light Company (CP&L) hereby submits for approval a change to the Quality Assurance (QA) Program for the Shearon Harris Nuclear Power Plant (SHNPP).
This request is submitted in accordance with 10CFR50.54(a)(3) and is detailed in Enclosure 1.
The proposed change reflects CP&L's intent to remove the Corporate Quality Assurance (CQA) Department from in-line review and approval of processes related to the engineering documents. This proposed change reflects the adequacy of review processes being performed by the originating organizations, the elimination of redundant reviews, and focuses increased accountability on the organization performing the work to achieve the desired level of quality. The Nuclear Assessment Department will evaluate the overall performance of engineering activities on an ongoing basis.
Although the proposed change could be construed as reducing a program commitment, the revised program will continue to provide assurance that review and approval of processes related to engineering documents would be satisfied. Thus, the SHNPP QA Program would continue to meet the applicable 10CFR50 Appendix B criteria.
Enclosure 3 is being provided for your information only at this time. It describes related organizational changes that do not constitute a reduction in commitment to the QA Program. These changes have maintained an equivalent level of oversight/review to that currently described in the FSAR and, thus, have already been implemented.
These changes will be incorporated into the FSAR in accordance with the provisions of 10CFR50.71(e).
9107310053 9i0725 PDR) ~ADOCK 05000400
Document Control De g )
/
(NLS-91-123) Page 2 Should you have any questions regarding these changes, please contact Mr. Dale Bates at (919) 546-6154.
Yours very truly, S. D. Foyd Manager Nuclear Licensing Section DBB/jbw (1099GLU)
Enclosures cc: Mr. S. D. Ebneter Mr. F. Jape (Region II)
Ms. B. L. Mozafari Mr. J. E. Tedrow (NRC-SHNPP)
ENCLOSURE 1 SHEARON EhQuuS NUCLEAR POWER PLANT QVALI1YASSURANCE PROGRAM CHANGE (1099GLU)
A PROGRAM CHANGE NO. 1 Current Re uirement The FSAR Section 1.8 (Regulatory Guide 1.38) currently requires QA involvement in determining and documenting the extent of inspection and storage requirements for items released from storage and awaiting installation at an interim location.
The Site QA Engineering Subunit currently reviews procedures covering removal of items from storage to satisfy this commitment. This review is performed as part of the procedure approval cycle.
Pro osed Chan e The proposed change would remove QA from the formal in-line sign-of'f responsibilities during the procedure approval cycle. These procedures will continue to receive technical reviews within the originating organization.
Reason for Chan e This change is being proposed in order to 'delete redundant in-line review by the QA organization of procedures which already receive separate technical reviews by qualified individuals within the originating organization. This will place sole in-line review and approval responsibility with the originating organization and allow the independent oversight organization to move to a more appropriate sampling and monitoring (versus 100 percent in-line review) role.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satis 10CFR50 A endix B and the FSAR uali Pro ram Separate technical reviews by qualified individuals will continue to verify the technical and quality assurance program adherence.
The Nuclear Assessment Department will independently evaluate the overall performance of the engineering activities on an ongoing basis.
Based upon these considerations, the removal of the in-line reviews by the QA Engineering Subunit will not result in any degradation of the review. process.
(10996 LU)
A PROGRAM CHANGE NO. 2 Current Re uirement The current commitment to Regulatory Guide 1.88 discussed in FSAR Section 1.8 requires direct involvement by QA for determining QA records classifications. To fulfillthis commitment; a member of the Site QA Engineering Subunit is currently assigned to membership on the site committee (Records Task Force) which determines records classiGcation.
Pro osed Chan e The proposed change removes QA direct involvement in records classification determination. The site Records Task Force, in accordance with plant procedures, will continue to perform records classification determinations.
Reason for Chan e Plant procedures establish a Records Task Force, which currently includes a member of the site QA Engineering Subunit, to accomplish the responsibility of determining the classiGcation of QA records. This change would allow the removal of QA from membership on the Records Task Force and from any in-line review responsibility related to records classiGcation since there are other qualified individuals on the Records Task Force who will continue to determine records classiGcations. Therefore, this change will place responsibility for this activity with the line organization and allow the independent oversight organization to assume a monitoring and evaluation role.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satis 10CFR50 A endix B and the FSAR uali Pro ram The procedurally controlled records classification process will continue to assure the technical and quality assurance program adherence and adequacy of each record classification established in procedures.
In addition to the normal reviews and controls, the Nuclear Assessment Department will independently evaluate the overall performance of records classiGcation on an ongoing basis.
Based upon these considerations, the removal of the direct reviews by the QA Engineering Subunit will not result in any degradation of the records classiGcation process.
(1099GLU)
A PROGRAM CHANGES NO. 3 AND NO. 4 Current Re uirement The FSAR Section 13.5.1.3.d.2 currently requires that separate QA reviews be conducted to verify the adequacy of the design effort for plant modifications. Also, FSAR Section 17.2.3 currently requires that design changes be subject to the same controls that were applicable to the original design. These requirements are currently satisfied by including QA Engineering in the in-line review of plant modifications.
Pro osed Chan e The proposed change would remove QA from the in-line review of plant modifications. Separate technical reviews will continue to be performed by the originating organization in accordance with plant procedures.
Reason for Chan e This change is being proposed in order to delete redundant in-line review by the QA organization of procedures which already receive separate technical reviews by qualified individuals within the originating organization. This will place sole in-line review and approval responsibility with the originating organization and allow the independent oversight organization to move to a more appropriate sampling and monitoring (versus 100 percent in-line review) role.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satis 10CFR50 A endix B and the FSAR uali Pro ram Separate technical reviews by qualified individuals will continue to verify the technical and quality assurance program adherence and adequacy of each new modification.
In addition to the normal reviews and controls, the Nuclear Assessment Department will independently evaluate the overall performance of the engineering activities on an ongoing basis.
Based upon these considerations, the removal of the in-line reviews by the QA Engineering Subunit will not result in any degradation of the review process.
(1099GLU)
A PROGRAM CHANGE NO. 5 Current Re uirement The FSAR Section 17.2.14 requires that selected plant procedures and subsequent revisions be reviewed by the QA group to ensure that required inspections, tests, and other critical operations are inserted in the documents. This requirement is currently satisfied by including QA Engineering in the in-line review of plant procedures and procedure revisions.
Pro osed Chan e The proposed change would remove QA from the in-line review of procedures and procedure revisions. Technical reviews will continue to be performed by the originating organization in accordance with plant procedures.
Reason for Chan e This change is being proposed in order to delete redundant in-line review by the QA organization of procedures which already receive separate technical reviews by qualified individuals within the originating organization. This will place sole in-line review and approval responsibility with the originating organization and allow the independent oversight organization to move to a more appropriate sampling and monitoring (versus 100 percent in-line review) role.
Basis for Concludin That the Revised Pro ram Inco oratin the Chan e Continues to Satis 10CFR50 A endix B and the FSAR uali Pro ram Separate technical reviews by qualified individuals will continue to verify the technical and quality assurance program adherence and adequacy of selected procedures and revisions.
In addition to the normal reviews and controls, the Nuclear Assessment Department will independently evaluate the overall performance of the engineering activities on an ongoing basis.
Based upon these considerations, the removal of the in-line reviews by the QA Engineering Subunit will not result in any degradation of the review process.
(1099GLU)
ENCLOSURE2 SHEARON HARRIS NUCLEAR POWER PLANT FSAR PAGE MARK-UPS (1099GLU)
SHNPP FSAR rodents or other small animals wilL not be present. If any such evidence is detected, a survey or inspection will be utilized to determine the extent of the damage; exterminators or other appropriate measures shalL be used to control these animals to minimize possible contamination and mechanical damage to stored material."
u) Paragraph 6.3.3, Storage of Hazardous Material: The sentence is repLaced with the Eollowing'Hazardous chemicals, paints, solvents, and other materials of a like nature shall be stored in approved cabinets or containers which are not in close proximity to installed safety systems required for safe shutdown.
v) Paragraph 6.4.2, Care of Items: The Eollowing alternates are provided for indicated subparts:
(5) Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters ar not required."
(6)- "Large (greater than or equal to 50 HP) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not required."
(7) "Prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required; the resuLts of the evaluation shalL be documented. If rotation is required, it shall be performed at specified intervals, and documented. Parts wilL receive a coating of Lubrication where applicable, so that the shaft does not come to rest in the same position occupied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation after rotation shalL be specified and obtained."
(8) Other maintenance requirements specified by the manufacturer's instructions shall be evaluated by responsible plant personnel to determine applicability during storage of the item.
w) Paragraph 6.5, Removal of Items from Storage: Carolina Power & Light Company does not consider the last sentence of this paragraph to be applicable to the Operations Phase due to the relatively short period of time between installation and use. The first sentence oE the paragraph is replaced with:
"CP&L will'develop, issue, and implement a procedure(s) which cover(s) the removal of items from storage. The procedure(s) wilL assure that the inspection status .oE all material issued is known, controlled, and appropriately dispositioned." When items are released and waiting at a location prior to installation, responsible plant management~ will determine and document the extent of inspection and storage requirements ~opsy~
glen% PlÃCcdap4Q x) Paragraph 6.6, Storage Records: Carolina Power & Light Company will comply with the requirements of this Section with the clarification that, for record purposes, only the access of non-CP&L personnel into indoor storage 1..8"50c Amendment No. 41
SHNPP FSAR (f) Quantitative and qualitative criteria for determining important steps or functions have been satisfactorily accomplished.
Procedures utilized for maintenance of safety-related structures, systems, or components are reviewed as provided Eor in Section 6;0 of the Technical Specifications. This review ensures that the equipment is returned to a state of quality at least equivalent to that specified originally.
The detailed administrative control of plant maintenance is provided for under the CP&L Maintenance Management System. This system 'provides an accurate written record of all maintenance work performed, both corrective and preventative. This assures all maintenance and repair work needed is given proper and timely consideration; all such maintenance and repair work is clearly described so that proper investigation of the causes and corrective action may be made; the work priority established is based on urgency; and proper QA/QC considerations are given to work.
Che c >4 21 2) Modifications: Plant modifications and changes to setpoints defined in the setpoint document are developed in accordance with procedures. These procedur'es assure necessary activities 'pproved associated with the modifications are carried out in a planned, controlled, and orderly manner. For each modification, design .
documents'uch as drawings, equipment and material spec'ifications, and appropriate design analysis are developed or the as-built design documents are utilized. Based on the information in the design documents, a written safety evaluation is prepared in accordance with 10CFR50.59. This analysis contains the technical data, supporting evaluations, and the safety questions considered and analyzed as safe that form the bases for determining the modification does or does not involve an unreviewed safety question. Separate reviews are 'conducte to verify the adequacy of the design effort. The final modification package is reviewed in accordance with the provisions of Section 6.0 of the Technical Specifications. The purpose of this review is.to a assess the potential degradation of plant quality as a result of the proposed modification.
In particular, the safety analysis, conclusions, and any proposed procedure changes are checked and it is determined if the modification involves an'nreviewed safety question as defined in 10CFR50.59.
Proposed modifications which involve an unreviewed safety question or a change to Technical Specifications are handled in the Eorm of proposed license amendments.
e) Surveillance Testin : Surveillance testing at Shearon Harris is administratively controlled by the Surveillance Test Program in accordance 21 with the requirements of the Technical Specifications. The program has provisions for establishing a computerized data base from which will be scheduled.
surveillance'asks 6f Ih Jl>d~~s ghy&lcd'graf/g jn b 4A t+c" >ic+~ ~~~ ~~ >+9~
13.5.1-4 Amendment No. 21
SHNPP FSAR Regulatory Guide 1.88 COLLECTION, 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 clarifications.'/i~
a) Appendix,A of ANSI N45.2.9 is not considered to be a mandatory lis This list will be used as a guideline for classifying those documents that need to be maintained. as QA records.
whether a particular type of document needs to be classified as a QA record and its appropriate retention period< ' gecoAr
+all ba d'ef8'rnvrtcgl~ gcwgd~nce vs%
~gqcp O&WJ b) Paragraph 1.4, Definitions'The phrase "when the document has been ~
is clarified to mean when the document has received the finaL r~f/'ompleted" review performed by the organizational element responsible for generating or 41 collecting the records.
In the case of a record package (Plant Change Request, Equipment Qualification, etc.) made up of several individual documents, the package will be considered to be the document for the purpose of determining when the document is complete.
c) Paragraph 3.2.1, Generation of Quality Assurance Records: The phrase l41 "completely filled out" is clarifi'ed to mean that sufficent information is recorded to fulfill the intended purpose of the record.
d) Paragraph 3.2.2, Index: The storage location will be delineated in procedures in lieu of in the Index. The specific Location of a record "within 41 a storage area" is delineated by a computerized indexing system plus a storage area labeling system which provides information by record type and storage medium.
e) Paragraph 4.2, Timeliness'Carolina Power 6 Light Company's contractual (41 agreement with its contractors and suppliers will constitute fulfilLment of the requirements of this paragraph.
f) Paragraph 5.4, Preservation: The following clarification is substituted l41 for the current subparagraph 5.4.2: "Records shall not be stored Loosely.
They shall be secured for storage in file cabinets or on shelving in containers." The following clarification is substituted for the current f41 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.'outine general office and nuclear site l41 security systems and access controls are provided. No special security systems are required to be estabLished for record storage areas.
h) 'aragraph 5.6, Facility:, This paragraph provides no distinction between temporary and permanent faciLities. To cover temporary storage, the following clarification is added: "Complete records may be stored in one-hour fire 141
- 1. 8-118 Amendment No. 41
SHNPP FSAR 17 3 DESIGN CONTROL The Corporate gA Program establishes requirements for the control of design activities associated with modifications of safety-related structures, systems, and components.
Design changes, including those originating at the plant, are subject to +he <<pproPR~A
~ma-controls which were applicable to the original design. Carolina Power and Light Company may designate an organization to make design changes other than the organization which prepared the original design. In these cases, CPhL 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.
The program requires that 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 and drawings) and procedures and instructions reflect applicable regulatory requirements and design bases and are checked for accuracy and completeness by qualified individuals which are other than those who prepared the document and such reviews are documented. An independent review is conducted to assure that documents are prepared in accordance with procedures.
b) Design documents specify quality requirements or re'ference quality standards as necessary.
c) 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')
Haterials, parts, and equipment which are standard off"the"shelf items or which have been previously approved for a different application are evaluated for suitability prior to selection.
e) Design documents and procedures are revised to reflect design modifications and "as-built" conditions.
f) Internal and external design interfaces between organizations participating in design, modifications are adequately defined and controlled, including the review, approval, release, and distribution of design documents and revisions.
The above controls are applied as necessary to such aspects of design as reactor physics', seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials,'nd accessibility for inservice inspection, maintenance, and repair.
17 '.3-1 Amendment No. 40
SHNPP FSAR 17 ~ 2 ~ 14 INSPECTION~ TESTy AND OPERATING STATUS The Corporate QA Program establishes the requirements for the identification I 40 and control of the inspection, test, and operating status of safety-related structures, systems, and components.
Procedures are written to control the'arious methods of indicating status'.e., tags, markings, labels, stamps', routing cards, calibration data sheets, computer programs, or other suitable means. These procedures include the application and removal 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 nonoperational status and to prevent inadvertent use.
Selected plant procedures and subsequent revisions
~up- to ensure required inspections, tests, and other critical operations are inserted in the documents.
Altering the sequence of required tests, inspections, and other operations important to safety can only be accomplished by methods outlined in approved procedures. Procedure revisions reflecting such changes are subject to the same controls as the original revie~ and approval.
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17.2.14-1 Amendment No. 40
ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT RELATED ORGANIZATIONCHANGES (1099GLU)
RELATED ORGANIZATIONALCHANGES EFFECTIVE JANUARY 1 1991 0 erations A C Units On-Site The QA subunit of the Operations QA/QC Unit was deleted, with the surveillance functions of this subunit being assumed by the new Nuclear Assessment Department's Project Assessment Section (on-site). These surveillance functions are described in FSAR Sections 9.5.1 and 17.2.
A Services Section Co orate The Corporate QA Auditing Unit was deleted, with the 10CFR50 Appendix B audit requirements being assumed by the Nuclear Assessment Department's Nuclear Assessment Corporate Section. The audit functions are described in FSAR Sections 1.8, 9.5.1, and 17.2.
(1099GLU)