ML18022A918

Forwards Summary of Differences from Initial QA Program Description,Current Change description,marked-up FSAR Pages & New Program Description

ML18022A918
Person / Time
Site:	Harris
Issue date:	09/15/1993
From:	Habermeyer H CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GLS-93-168, NUDOCS 9309200146
Download: ML18022A918 (110)

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~', I-i ACCELERATE~'DOCUMEN'1'ISII U'l 1ON SYSTEM

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ACCESSION NBR:9309200146 DOC.DATE: 93/09/15 NOTARIZED: NO DOCKET .0 FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit , Carolina 05000400 I AUTH. NAME AUTHOR AFFILIATION HABERMEYER,H.W. Carolina Power & Light Co.

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

SUBJECT:

Provides revised submittal re QAP change on 920806 for Shearon Harris Nuclear Power Plant.

D DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket Utili NOTES:Application for permit renewal filed. 05000400

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RECIPIENT COPIES RECIPIENT COPIES A ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LE,N 1 1 INTERNAL: ACRS 8 8 RPEB 1 1 OC/LFDCB 1 1 01 2 2 RGN2 FILE 1 1 EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASLI COj INTACT TI IE DOCVMEN'I'ON'I'ROI DI~)V~

ROOM PI-37 (EXT. 504-20Ci5) TO ELIMINATEYOUR NAME FROM DIS'I'RIIIU'IION LISTS FOR DOCUMENTS YOU DON'T NEED!

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(c Carolina Power & Light Company P,O. Box 1551 ~ Raleigh, N.C. 27602 SEP 15 1993 H.W. HABERMEYER, JR.

Vice President Huetear Seniees Department SERIAL: GLS-93-168 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 QUALITY ASSURANCE PROGRAM CHANGES Gentlemen:

Carolina Power 6 Light Company (CPGL) submitted a Quality Assurance (QA)

Program change on August 6, 1992 for the Shearon Harris Nuclear Power Plant (SHNPP). That proposed change reflected CP&L's efforts to place the responsibility for quality at the appropriate level in the line organization and to make improvements in the assessment process. NUREG 0800, Section 17.3 was used for information and guidance to prepare the proposed changes.

Subsequent discussions with the NRC regarding that submittal provided valuable information in support of the requested change. This letter provides a revised submittal as a result of those discussions.

Enclosures 1A and 1B provide a summary of differences from the initial submittal and the current change descriptions, with the basis for the change.

Enclosure 2 provides the FSAR marked-up pages associated with the QA Program change.

Enclosure 3 provides the new proposed QA Program description.

Should you have questions regarding these changes, please contact Mr. R. W.

Prunty at (919) 546-7318.

Yours very truly, H. W. Habermeyer, DBB/jbw Enclosures cc: Mr. S. D. Ebneter Mr. N. B. Le Ms. B. L. Mozafari Mr. J. E. Tedrow 9309200146 930915 PDR ADOCK 05000400 (2049GLU)

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ACCELERAT DOCUMENT DIST 'UTION SYSTEM REGULA Y INFORMATION DISTRIBUTIO SYSTEM (RIDS)

ACCESSION NBR:9309200146 DOC.DATE: 93/09/15 NOTARIZED: NO DOCKET FACIL:50-400 Shearon Harris Nuclear Power Plant, Unit 1, Carolina 05000400 AUTH. NAME AUTHOR AFFILIATION HABERMEYER,H.W. Carolina Power & Light Co.

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

SUBJECT:

Provides revised submittal re QAP change on 920806 for I Shearon Harris Nuclear Power Plant.

D DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket Utili S NOTES:Application for permit renewal filed. 05000400 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL LE,N 1 1 D

INTERNAL: ACRS 8 8 N~RR S~R-XL/RPEB 1 1 OC/LFDCB 1 1 EG FILE 01 2 2 RGN2 FILE 1 1 EXTERNAL: DMB/OSS NRC PDR 1

1' 1 'HS 1 1 S

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUivlEN'I'ON'I'ROI. D)'SK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME Ff<OM DISTIRIUU'I'ION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 17 ENCL 17

0 CHAL Carolina Power & Light Company P.O. Box t551 ~ Raleigh, N.C. 27602 SEP 15 1993 H.W. HABERMEYER, JR.

Vice President Nuclear Services Department SERIAL! GLS-93-168 United States Nuclear Regulatory Commission ATTENTION: Document Control Desk Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-400/LICENSE NO. NPF-63 QUALITY ASSURANCE PROGRAM CHANGES Gentlemen:

Carolina Power E Light Company (CPGL) submitted a Quality Assurance (QA)

Program change on August 6, 1992 for the Shearon Harris Nuclear Power Plant (SHNPP). That proposed change reflected CPEL's efforts to place the responsibility for quality at the appropriate level in the line organization and to make improvements in the assessment process. NUREG 0800, Section 17.3 was used for infoimation and guidance to prepare the proposed changes.

Subsequent discussions with the NRC regarding that submittal provided valuable information in support of the requested change. This letter provides a revised submittal as a result of those discussions.

Enclosures 1A and 1B provide a summary of differences from the initial submittal and the current change descriptions, with the basis for the change.

Enclosure 2 provides the FSAR marked-up pages associated with the QA Program change.

Enclosure 3 provides the new proposed QA Program description.

Should you have questions regarding these changes, please contact Mr. R. W.

Prunty at (919) 546-7318.

H. W. Habermeyer, DBB/jbw Enclosures cc: Mr. S. D. Ebneter Mr. N. B. Le Ms. B. L. Mozafari 2GOG75 Mr. J. E. Tedrow 9309200146 9'30915 PDR ADOCK 05000400 (2049GLU)

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ENCLOSURE 1A SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO+ 50-400/OPERATING LICENSE NO. NPF-63 QUALITY ASSURANCE PROGRAM CHANGES RESUBMITTAL CHANGE

SUMMARY

Proposed changes to Regulatory Guide commitments related to NRC notification of obsolete Regulatory Guides (see 56 Federal Register at 36175) are being withdrawn. See proposed changes 12a, 14, 16a, 19a, 23a, and 24a of the original submittal.

Proposed changes to Regulatory Guide 1.144, Auditing of QA Programs for Nuclear Power Plants, and Regulatory Guide 1.146, Qualification of QA Program Audit Personnel for Nuclear Power Plants, are being revised to clarify the assessment versus audit function related to internal versus external audit functions. See proposed changes 24, 25, and 25a of the resubmittal.

Proposed change 31 describing the new Section 17.3 of the FSAR has been clarified/or updated as follows:

Sections 17.3.1.1, 17.3.1.2, and 17.3.1.3 have been revised to reflect current organizational titles.

Section 17.3.2.13 has been clarified to include human performance problems to be consistent with Section 17.3.1.6.

Section 17.3.3.3 under the heading, Nuclear Assessment Department Program, the List of Assessment Function/Areas, and the List of Assessment Elements have been clarified to address NRC reviewed comments.

Section 17.3.1.7 has been clarified to better describe the intent of exceptions to Section 1.8 of the FSAR.

Section 17.3.2.12 has been revised to include a statement. relative to inspection requirements and acceptable alternatives that is contained in our current QA Program commitment in Section 17.2.10.

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ENCLOSURE 1B SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO. 50-400/OPERATING LICENSE NO. NPF-63 QUALITY ASSURANCE PROGRAM CHANGE DESCRIPTION INCLUDING REASONS BASIS FOR CHANGE A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.8 PAGE 1.8-9 Pro osed Chan e No. 1 The proposed change deletes reference to QA and replaces it with QC inspectors.

Reason for Chan e This clarifies the organizational description of personnel.

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 Qualification of Nuclear Assessment Department (NAD) personnel will be in accordance with Section 17.3.

Qualification of QC inspection personnel will be in accordance with CPQL's commitment to Regulatory Guide 1.58 and Section 17.3.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.28 PAGE 1.8-36 Pro osed Chan e No. 2 The proposed change deletes reference to Section 17.2.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being deleted to prevent possible conflicts in references.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Deletion of references to Section 17.2 will not affect the implementation of the QA Program.,

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A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.30 PAGES 1.8-38 and 38a Pro osed Chan e No. 3 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.33 PAGES 1.8-41 42 and 42a Pro osed Chan e No. 4 The proposed change deletes the existing clarification "b" and replaces it with new clarifications "b and c" concerning CPGL's independent review and assessment programs. The new clarifications are provided to reference the plant Technical Specifications and Section 17.3 of the FSAR for the details of these programs.

Reason for Chan e These new clarifications and references to the plant Technical Specifications and Section 17.3 of the FSAR eliminate duplication and potential misunderstandings.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Carolina Power 6 Light Company's NAD will implement Independent Assessments as described in Section 17.3. Results of Independent Assessments and reviews of those results by Senior Management will be in accordance with Section 17.3.

Carolina Power 6 Light Company's Independent..ReviewProgram will be implemented in accordance with the plant's Technical Specifications.

Pro osed Chan e No. 5 The proposed change revises the reference from Section 17.2 to 17.3.

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Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

Pro osed Chan e No. 6 Addition of clarification "m" which provides a reference to Section 17.3 for a description of controls for Measuring and Test Equipment (MGTE).

Reason for Chan e Addition of this clarification does not change the manner in which business is conducted, but simply references where additional clarifications and control on MQTE 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 MGTE are located in the 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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Controls described in 17.3 contain the elements previously described in 17.2.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.37 PAGE 1.8-49 Pro osed Chan e No. 7 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continue to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

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II, A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.38 PAGES 1.8-50 50a. and 50d Pro osed Chan e No. 8 The proposed change deletes the word "operational" describing the QA Program.

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

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The deletion of the word "operational" does not alter the way that the QA Program described in 17.3 will be implemented. This simply adds consistency to the way that Section 17.3 is written.

Pro osed Chan e No. 9 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

Pro osed Chan e No. 10 The proposed change to clarification "z" deletes the responsibility for QA/QC personnel to witness load tests of rigging equipment and surveillance of operator maintenance inspections. This change clarifies that Quality Control (QC) personnel will continue to perform nondestructive examinations of rigging equipment.

Reason for Chan e This requirement was carried over from the construction program when most of the rigging inspections were performed by contractor personnel with little formal procedural controls and training. The plant maintenance procedures provide improved criteria for inspection and testing. The personnel are qualified under a formal program. The need for independent witnessing to assure quality is no longer needed. In addition the frequency of these type tests is much reduced since construction was completed. Most rigging is now purchased with certification of load capacity and does not require testing upon receipt.

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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 This change places the responsibility for witnessing for load tests and surveillance of maintenance inspections at the appropriate level in the line organization.

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

In addition, The NAD will independently evaluate the overall performance of inspection, testing, and nondestructive examinations.

Pro osed Chan e No. 10A The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.39 PAGE 1.8-51 Pro osed Chan e No. 11 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

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~ e A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.54 PAGE 1.8-67 Pro osed Chan e No. 12 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

Pro osed Chan e No. 13 The proposed change deletes "Operating Plant QA" and identifies the Quality Control (QC) personnel are qualified per this standard as stated in this position.

Reason for Chan e Clarify organization description of personnel.

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 Qualification of NAD personnel will be in accordance with Section 17.3.

'I Qualification of QC personnel will be in accordance with CPGL's commitment to Regulatory Guide 1.58 and Section 17.3.

A PROGRAM CHANGE Pro osed Chan e No. 14 VOIDED.

Pro osed Chan e No. 15 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

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A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.74 PAGES 1.8-93 and 94 Pro osed Chan e No. 16 The proposed changes 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.

Basis for Concludin That the Revised Pro ram Incor oration the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.3 describes the assessment process. Deletion of. the definition that was part of the audit process does not effect the effectiveness of the Section 17.3 assessment process.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.88 PAGE 118 and 1.8-118a Pro osed Chan e No. 17 The proposed change revises the responsibility for justifying, evaluating, and approving exceptions to the temporary storage of records requirements from the Manager NAD to the Vice President Harris Nuclear Project Department.

Reason for Chan e This change places the responsibility for controlling exceptions to the temporary storage of records requirements at the appropriate level in the line organization.

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 responsibility for controlling exceptions to the temporary storage of records requirements at the appropriate level in the line organization will ensure these exceptions are controlled by the individual who is held accountable for maintaining these records.

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Pro osed Chan e No. 18 Addition of clarification "k" which provides a reference to Section 17.3 for a description of controls for QA records.

Reason for Chan e Addition of this clarification does not change the manner in which business is conducted, but simply references where additional clarifications and controls on QA records are located in the FSAR.

These controls/clarifications were previously included in Section 17.2 but were not referenced here. This provides a better description of where the controls for QA records are located in the program.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program. Controls in 17.3 contain the elements previously contained in Section 17.2.

A PROGRAM CHANGE FSAR SECTION 1.8 REGULATORY GUIDE 1.116 PAGE 1.8-147 Pro osed Chan e No. 19 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

A PROGRAM FSAR 1.8 REGULATORY GUIDE 1.123 PAGES 1.8-155 157 and 158 Pro osed Chan e No. 20 The proposed change revises the reference from Section 17.2 to 17.3.

Reason for Chan e Section 17.2 is being replaced with 17.3. The references are being revised accordingly.

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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 Section 17.2 is being replaced in its entirety by Section 17.3, which describes the QA Program.

Pro osed Chan e No. 21 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 Quality Verification Section.

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

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Carolina Power 6 Light Company's reorganization of the Corporate QA organization places this function in the NAD. Reorganization of this function has not changed the implementation of this function.

Pro osed Chan e No. 22 The proposed change deletes the specific phrase "for the operating phase".

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

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The deletion of the words "for the operating phase" does not alter the way that the QA Program described in Section 17.3 will be implemented.

This simply makes this section consistent with to the way Section 17.3 is written.

Pro osed Chan e No. 23 The proposed change deletes the phrase "technical and QA" describing overview of causes and corrective action relative to vendor deficiencies.

Reason for Chan e These words implied that two separate reviews were required in each case. Deletion of this phrase does not reduce the end result. It states that CP&L will perform what ever type of evaluation is deemed appropriate, relative to causes and corrective action of vendor deficiencies, without inference to a specific organization unit.

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Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the'SAR ualit Pro ram The Quality Verification Section will continue to ensure the Vendors stay in compliance with their accepted QA Program commitments.

A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.144 PAGES 1.8-182 183 and 184 Pro osed Chan e No. 24 The proposed change modifies clarifications "e," "g," and "h" and adds new clarification "1" 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.

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 Independent assessment of internal activities will be accomplished as outlined in Section 17.3.3. Changing the terminology does not change the way these assessments are performed.

A PROGRAM CHANGE - FSAR SECTION 1.8 REGULATORY GUIDE 1.146 PAGE 1.8-186 Pro osed Chan e No. 25 The proposed change modifies the wording for clarification "2" to Regulatory Guide 1.146 to reflect the terminology of the assessment organization and delete titles which no longer exist due to organizational changes.

Reason for Chan e There is no change for external audits. The proposed change reflects the terminology of the Assessment organization.

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 Changing terminology and organizational titles to reflect the current organization does affect the way that this Regulatory Guide will be applied.

Pro osed Chan e No. 25a The proposed change adds a new clarification "5" to Regulatory Guide 1.146 to modify the criteria for qualification of "Lead Assessors."

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Reason for Chan e Individuals are assigned to the NAD organization on a rotational basis for a limited amount of time. These individuals may possess auditing/assessment experience from a number of different assignments gained over a period of greater than three years. This change allows the NAD organization to utilize this collective experience to qualify

.individuals as Lead Assessors.

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 Qualification of internal assessment personnel shall be accomplished as outlined in Section 17.3 based on education and experience needed to evaluate the activity being assessed.

Pro osed Chan e No. 26 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 was revised to reference Section 17.3. This reference is being removed for consistency with the method to which the QA Program is written. (See Proposed Change No. 18.)

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 Personnel qualification and training records will be maintained in accordance with Section 17.3. Deletion of this reference does not change the controls for record retention.

A PROGRAM CHANGE - FSAR SECTION 9.5 FIRE PROTECTION PAGE 9.5.1-56 Pro osed Chan e No. 27 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 NAD.

Reason for Chan e The specific responsibilities are being deleted from this section and included in Section 17.3 to eliminate duplication and possible conflicts. Reference to the QA organization is deleted based on creation of the NAD.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram Section 17.3 describes the QA Program. The operational fire protection QA elements are included in Section 17.3.

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The NAD will evaluate the effectiveness of the Fire Protection Program through the use of independent assessment.

A PROGRAM CHANGE FSAR SECTION 13.1.1 MANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION PAGE 13.1.1-6 Pro osed Chan e No. 28 The proposed change changes the word "barriers" to "deficiencies."

Reason for Chan e The proposed change provides consistency and clarity to the way this section is written.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The word change being made is not changing the intent of the responsibilities described here and therefore will not change the way the QA Program is implemented.

A PROGRAM CHANGE FSAR SECTION 13.4.2 INDEPENDENT REVIEW PAGE 13.4.2-1 Pro osed Chan e No. 29 The proposed change deletes the details about the Independent Review Program from the FSAR and makes reference to Technical Specifications for these details.

Reason for Chan e Deletion from the FSAR eliminates duplication and possible conflicts.

Basis for Concludin That the Revised Pro ram Incor oratin the Chan e Continues to Satisf 10 CFR 50 A endix B and the FSAR ualit Pro ram The Independent Review Program is described in the Technical Specifications. Deletion of the program description from the FSAR does not change the program but simply eliminates duplication and potential confusion.

A PROGRAM CHANGE FSAR SECTION 13.4.3 AUDIT PROGRAM PAGES 13.4.3-1 13.4.3-2 and 13.4.3-3 Pro osed Chan e No. 30 The proposed change deletes the specific details of'he 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.

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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 Section 17.3.3 describes the independent assessment process which replaces the Audit Program described here.

The NAD will implement the independent assessment process. This process will ensure an effective means of reviewing and evaluating the CP6L QA Program.

A PROGRAM CHANGE FSAR SECTION 17.2 A PROGRAM DESCRIPTION PAGES 17 2.1-1 THROUGH 17.2.19-4 Pro osed Chan e No. 31 The proposed change deletes Section 17.2 in its entirety and replaces it with Section 17.3 which describes the QA Program.

Reason for Chan e The proposed Section 17.3 describes the use of performance-based assessment concepts which CPGL proposes to use in the NAD and line organizations. The program content is the same as was in 17.2 except in the area of audit/assessment.

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 Section 17.3 replaces Section 17.2 in its entirety. The program content is the same as was in 17.2 except in the area of assessments. These controls will ensure an effective QA Program at CPGL.

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ENCLOSURE 2 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO ~ 50-400/OPERATING LICENSE NOi NPF-63 FSAR MARKED-UP PAGES E2-1 (2049GLU)

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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 commensurate to the functions 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",

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as described in paragraph 3.2.4. Therefore, CP&L shall comply with the requirements as stated in paragraph 3.2.4.

C iHSPBGWOr'S

6) iil b i d dq life di accordance with Regulatory Guide 1.58, which endorses ANSI N45.2.6. ,The SHNPP position on Regulatory Guide 1.58 addresses the SHNPP positions relative to ANSI N45.2.6.

7) Various CP&L positions are not addressed in the Standard.

Therefore, CP&L lists these positions in Table 1.8-1 for reference, and CP&L will prescribe the training, responsibilities, and qualifications commensurate to the job requirements.

8) The ALARA Specialist shall have a BS Degree or the equivalent and two years experience, one of which shall be nuclear power plant experience, or the employee shall have an advanced degree and one year nuclear power plant experience.

1.8-9 Amendment No. 44

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 CPEL'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.

1.8-36 Amendment No. 41

p SHNPP FSAR Regulatory Guide 1.30 QUALITY ASSURANCE REQUIREMENTS FOR THE INSTALLATION AND TESTING OF INSTRUMENTATION AND ELECTRIC EQUIPMENT (REV. 0)

Carolina Power 6 Light Company complies with the requirements of ANSI N45.2.4-1972 as it is endorsed by Regulatory Guide 1.30 with the following clarifications:

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

b) Paragraphs 2.2 and 2.3; Prerequisites, Procedures, and controls will be implemented as determined by responsible plant Instructions.'hese management in approved procedures.

c) Paragraph 2.4, Results, will be implemented as set forth in sections . .' . . . . and by compliance with Regulatory Guide 1.33. I'7-3 $ < A d) Patagtaph 2.5,/ensuring and Test Equipment, will be implemented as set forth in Section 17.~ in lieu of the requirements set forth in this paragraph. 3 s

e) Paragraph 3, Preconstruction Verification: "Approved instructions" are interpreted to include vendor manuals. These manuals are not normally approved by CPSL; however, CPSL does review the applicable portions of these manuals of acceptability towards the work being plannedldone.

f) Paragraph 4, Installation, will be implemented by inclusion of requirements in modification or maintenance procedures, where such procedures are used. Standard CP&L practices require that appropriate care be exercised whether a procedure is required or not.

g)

Section detail by CPSL's co 't Paragraph 5.1, Inspections, including subparagraphs 5 the first sentence in 5.1.3, will be implemented as set forth in 17.~. The remaining sentence in 5 requirements as set forth x the requirements stated here.

'.3

'.1, is covered in equivalent to Regulatory Guide 1.33, paragraph 5.2.6; the t commitment will be implemented in lieu of 5.1.2, and h) Paragraph 5 ',

implemented as set forth in Sections 17 ~ ~~.

Tests, including subpar)graphs 5+.1 through 5.2.3, and The test program will'e will consider the elements dutlined in this3paragraph-4hen developing test requirements for inclusion in maintenance and modification procedures'n some cases,. testing requirements may be met by post-installation surveillance testing in lieu of s

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'mendment No. 41

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SHNPP FSAR j) Paragraph 6.2.1 titled Equipment Tests: The last paragraph of this section deals with tagging and labeling. Carolina Power 6 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.

ft I~ cha~ e. 4p 1.8-38a Amendment No. 41

t SHNPP FSAR

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

(OPERATION)

Carolina Power & Light Company complies with this guide, which endorses ANSI N18.7-1476, with the following clarifications'.

41 a) Paragraph 1, "Scope", recommends that this standard applies to l41 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.

RqoLac,e a Power & Light Company's Performance Evaluation Unit is ) 41 responsible for con uc s. Each QA audit report is reviewed by the Executive Vice President Power Supply. Caro Li ht will use these [

41 management reviews to satisfy the requirements of the last portion pa agra h 4.5.

-e os<

J +"independent Paragraph 5.2.6, Equipment Control:

verification" requirements based CP&L will comply with the on the definition of this phrase f

41 as given under the<:c'ommitment'to t

Regulatory Guide 1.74.

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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.

pJ 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."

, Paragraph 5.2.7.1, Maintenance requirements of the first Programs.

sentence of the CP&L will comply with fifth paragraph. This the clarification 1.8-41 Amendment No. 41

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Pro osed Chan e No. 4 Insert for Re ulator Guide 1.33 b.) Section 4.3 titled Inde endent Review Pro ram: CPQL will implement the independent review program outlined in the plant Technical Specification 6.5.3.

c.) Section 4.5 titled Audit Pro ram: CPGL will implement an assessment program outlined in Section 17.3.3 of the FSAR.

(2049GLU)

t 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 411 management and shall be based on the effect of the condition on the immediate health and safety of the public. s 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."

41 I g)6 Paragraph 5.2.9, Plant Security and Visitor Control, requires certain 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 appxoved security plan shall be implemented prior to fuel loading.

c ae 41I h g Paragraph 5.2.11, Correctiv 'Action, xequires cextain activities to be performed. In order to avoid c flict between requirements, CP&L shall follow the requirements in Section 17 lieu of 41 Paragraph 5.2.11 as additionally clarified in above paragraph (d).

41l L gsentenceParagraph 5.2.15, Review, Approval and Control in Paragraph three is interpreted to mean:

of Procedures: The third "Applicable procedures shall be reviewed following an accident, an unexpected transient or a significan't operator error. Applicable procedures shall also be x'eviewed

. following an equipmen't malfunction which results in a reportable event."

41 I J p'J 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 preliminaxy 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

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SHNPP FSAR 4

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. Such action may include modification, procedural revision, or corrective maintenance.

k 3inspections Paragraph are 5.2.17, Inspections:

not contained in a As a separate general clarification, when 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.

Paragraph 5.2.17, second to the last sentence in the last paragraph, "Deviations, their cause, and any . . .", to be consistent with Paragraph condition will be determined for only significant 5.2.11, the cause of theProvident conditions adverse to safety.

m) Beati 0 u l 7. 3 o dd trio'0aL cLar i~i'cd(o wa to co8traLs Sos I P S halJ 1.8-42a Amendment No. 41

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SHNPP FSAR Regulatory Guide 1.37 QUALITY ASSURANCE REQUIREMENTS FOR CLEANING FLUID SYSTEMS AND ASSOCIATED COMPONENTS OF MATER-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 V(~Pos< Ch ~ +7 41 b) Paragraph 5, Installation Cleaning'The'recommendation that local rusting on corrosion resistant alloys be removed by mechanical methods is interpreted to mean that local rusting may be removed mechanically, but the use of other removal means is not precluded provided other cleaning methods are not considered detrimental as determined by responsible plant management. I 41 c) The guide and standard are applicable to those areas of the Quality I 41 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 l41 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 [41 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 & 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 clari ications'.

Po e. ~ 4Q a) Paragraph(2.1, Planning: (First sentence) the specific items to be governed by the)Standard shall be identified. However, the Standard is part Q

those structures, systems, and components which are included in that Program.

b) Paragraph 2.3 Results The full requirements of this paragraph shall apply to the inspections and tests that are performed to determine the acceptability of product quality.

c) Paragraph 2.4 - Those 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,'uch as warehouse temperature, humidity, etc., will be maintained in good working order and checked for proper functioning when accuracy is in doubt, but not maintained under the calibration and control program. Traceability to calibration records will be provided when it is impractical (because of size, configuration, or application) to physically mark calibration information on the item.

e) Paragraph 2.7, Classification of Items.'PSL may choose not to explicitly use the four level classification system. However, the specific requirements of the Standard that are appropriate to each class will be applied unless justified and documented.

1.8-50 Amendment No., 41

SHNPP FSAR f) Paragraph 2.7.1(3) requires special nuclear material (fuel) and sources to be classified as leveL A. Carolina Power & Light Company shall store new/used nuclear fuel and radioactive. sources in storage locations as described in the Sections 9 and 12. Radioactive sources used by HP personnel shall be stored and controlled in accordance with HP practices and procedures.

g) Paragraph 3.2 " Levels of Packaging - Packaging for shipment 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, CPSL will use means as determined by responsible plant technical personnel needed to provide adequate protection of the items in storage.

k) Paragraph 4 Shipping Requirements of paragraph 4, Shipping, primarily applies to the vendor. Plant functions with regard to return shipments will meet or exceed the methods of the vendor for the item or approved alternatives.

1) Paragraph 5.2.1, Shipping Damage Inspection'Warehouse personnel will normally visually scrutinize incoming shipments for 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.~.B The 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 function, he may not necessarily be certified (N45.2.6) as an Inspector.

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 for 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,

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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 the load rating, the equipment manufacturer will be contacted for his approval above 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.

Zf 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 lift weight. A dynamic load test over the full range of the using a weight at least equal to the lift weight will be c

a) Paragraph 7.4 -)Inepeotion of Equipment and Rigging Nondeatruttive examinations, will be performed by QA/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.$ 3 ProfbseJ Chwuee'a.

1.8-50d Amendment No. 41

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

Carolina Power 6 Light Company complies with the requirements of ANSI N45.2.3-1973 as endorsed by Regulatory Guide 1.39, September 1977, with the following clarifications for'.

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.

FSAR

Reference:

Section 17.$ 3 ProA ~e l ( ~Wee 1.8-51 Amendment No. 41

SHNPP FSAR Regulatory Guide 1.54 QUALITY ASSURANCE REQUIREMENTS FOR PROTECTIVE COATINGS APPLIED TO WATERWOOLED NUCLEAR POWER PLANTS (REV, 0)

Regulatory Guide 1.54 endorses ANSI N101.4-1972. The SHNPP project complies .

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

FSAR

Reference:

Section 173, 3

1. 8-.67 Amendment No. 5

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

Carolina Power 6 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 personnel. roPase

'QC requirements. Only personnel in the following listed categories will be required to meet ANSI N45.2.6-1978 requirements: (1) Nondestructive Examination (NDE) personnel and (2) nv 6+t inspection 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) Nith regard to Paragraph 2.5 of ANSI N45.2.6-1978 titled ~ph sical:

Carolina Power S 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 CP6L, none are considered necessary.

Carolina Power & Light Company employees receive an initial physical personnel and (2) . 'QC examination to assure satisfactory physical condition; however, only the following listed personnel will receive an annual examination. '(1) NDE inspection personnel. This annual examination shall consist of th near visual acuity using the standard Jaeger's type chart or equivalent est.

pro st ('-hadsF. 3 d) With regard to Paragraph 3 of ANSI 45.2.6-1978 titled s

will be grouped in levels of capability an certified for inspection, review, and evaluation of inspection data, and repo ting of inspection and test results'nspection personnel are qualified based on preestablished experience, education, on-the-job training, w itten 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

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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 effectiveness of the use of Supervisors as design verifiers to guard against abuse.

FSAR

Reference:

FSAR Section 17.$

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ProPos Cha.vc e ch are cumulative in nature and could est e 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 NRC Criteria for Record Stora e Facilities us ance - ANSI ies (Guidance ANS N45.2.9, Section5.6) issued 7/1/80.

j) Paragraph 5.6, subparagraph 9, is clarified to read: "No i es or penetrations except those providing fire protection li ec ion, ig ing,ht'/

umi i y control or communications are to be located within the acility. All such penetrations shall be sealed or dampenede too comp '

corn 1 y with a minimum two-hour fire protection rating."

coPoat C a Yance Pres(ctedf-Hams Mu<Lea.'r t'raised DeporftaeJ7 o~ h(s design ee k) AcLJltl ~a.l cLarI$4+lovs ~r W+ re~~ I

)A Sec~i"oH l7.3 IrcPoaeJ C a, GE'+ 8 1.8-118a Amendment No. 44

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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 incor'porated into procedures.

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

c) Paragraph 2.8, Measuring nd Test Equipment CP&L has addressed this 41 d) ro, requirement for the operational phase of the plant in Section CL Paragraph 2.9, Prerequisites, references requirements of other 17.~

3 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 [41 position on Regulatory Guide 1.38.

g) Paragraph 5, including subparagraphs 5.1 through 5.4, Installed Systems, Inspections and Tests.'esponsible 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

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

" Carolina Power & Light Company shall comply with the requirements of ANSI N45.2.13-1976 as it is endorsed by Regulatory Guide 1.123 with the following clarifications: 4 pQ P Q a) Paragraph 1.2.2, Purch er's Responsibilities: Item c is one of the options which may be used 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 conducted use of item.

.'epending on complexity and end h +Z 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

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

3) Ordered from the manufacturer, distributors 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.

1 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 the requirements specified in this paragraph.

os (h C'n QQ.-. 420 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 items>

therefore, CP&L wishes to replace paragraph 4.2('a), (b), and (c) with the following selection methods:.

1. 8-155 Amendment No. 43

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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:

~

C, QGC

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

2) Reviewing LER's.

3) Periodic audits

4) Annual evaluations

+7 .c~

5) Those controls specified in FSAR Section 17.

3 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.

Postal Ch WAG <2.0 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 of the requirements in this paragraph.

17.~ in lieu 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 requi red 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 6 Light Company interprets this statement to mean that once corrective action has been verified by purchaser on nonconforming vendor items, the items can be released for use in its intended application. The cause and action to preclude recurrence of deficiencies is the responsibility of the vendor, and independent verification of such vendor action by purchaser or vendor notification of such action to purchaser, is not required on the basis that the vendor's QA program has been accepted by the purchaser. The QA program provides for determining cause and action to preclude recurrence on significant deficiencies, and purchaser audits are conducted to ensure vendor's compliance with his accepted QA program commitments'n addition, action activities associ ed with items of high volume and which are considered significant to afety in cases where vendor's recent performance has appeared marginal.

m) Paragraph 10.2a: CPGL 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, triennially, will be complied with; however, such audits would only be required of the vendor if the vendor is involved with an active contract/procurement document. This concept is as discussed in Paragraphs 3.5.3.1 and 3.5.3.2 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 CP6L audit personnel will be accomplished as described in CP&L's position on Regulatory Guide 1.146.

d) Paragraph 3 '.2 indicates, that objective evidence is to be examined and evaluated. Carolina Power & Light Company believes that the use of subjective evidence is also an important element of the audit program. See Paragraph 4.3.2 clarifications below.

p e) Paragraph 3;3, Essential Elements of the Audit System; Carolina Power 6 Light Company (subparagraph will c mply with subparagraph 3.3.5 as 3.2.5) in ANSI N45.2.12, Draft 3, Revision 4:

it was originally written assessee,aiC for reporting on the effectiveness of the quality assurance Proceg~res'Provisions CP&L'ther ogram to the responsible management."

directly report on the For the auditing organization (CP&L),

effe iveness is reported as required by the Technical Specifications and by than audit reports, CP&L may not effectiveness of the quality assurance programs to the audited organization, when such organizations are outside of CP&L.

Subparagraph 3-3.7 requires verification of effective corrective 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 6 Light Company will comply with the requirement of this paragraph by 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~: lt 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.

g) Paragraph 4.3.2, Audit<Process: roPoseJ C4~<88 ~9 iAssess~M

1) Subparagraph review of only 4.3 '.2 could be interpreted to limit auditors objective evidence. Sometimes objective evidence to the may not be available; therefore, Carolina Power & Light Company will comply with an alternate sentence which reads: "When available, objective 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, CP&L 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 '.6 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."

assassme g'ts h) Paragraph 4.3.3, Post Audit Conference: Carolina Power & Light Company wil substitute and comply with the following paragraphs: "For all external audi , a postaudit conference shall be held with management of the audited organi ion to present audit findings and clarify misunderstandings. Where no adverse ndings exist, this conference may be waived by management of the audited organ ion. Such waiver shallassessed be documented in the audit report.

For all internal audi,ta unless unusual operating or maintenance conditions eouSacaace shall be held with managers/supervisors. If there are no adverse findings, management of the internal audQw4 organization may waive the Such waiver shall be documented in the ewW4 report."

~swssmevt'e,Gr l eg. a ssessrnqg 0 i) Paragraph 4.4, Reporting:

AudH'/Assess mePf')

This paragraph requires that he audit eport shal be signed by the audit team leader which is not ways the most exp itious route for the audit report to be issued as soon as pract cal. rolina Power &

Light Company will comply with Paragra 4' a clarif ed by the p cia~

1.8-183 Amend: t No. 5

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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 & Light Company will comply with subparagraph 4.4.3 clarified 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."

MAO Nauar~egT

4) Subparagraph 4.4.6 +Awill determine the need for audit reports to include recommendations for corrective actions. Ae< ~I

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ea C Paragraph 4.5.1, By Audited Organization: (hrolina Power & Light Company will comply with the following clarification of this paragraph:

"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. CP&L 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 QA record. Additionally, the audit checklist need only document oh)ective evidence examined to support the audit findings. p~

4) cp+L performs both Idttf'uaL earl ezkrtoaL audlk as de&peJ i< A<~

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1.8-1S4 Amen t No. 5

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SHNPP FSAR

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'i Regulatory Guide 1.146 QUALIFICATION OF QA PROGRAM AUDIT PERSONNEL FOR NUCLEAR POWER PLANTS (REtt. 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, Qualification of Auditors: Subparagraph 2.2. 1 references an ANSI B45.2 (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 QA 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.

/AD fAaua~rneNT audit/

or thehAssessment Team Leader shall, prior to commencing the audit, assign perry nnel who collectively have experience or training commensurate with th scope, complexity, or special nature of the activities to be audited." (.c 25 SB C

3. Paragraph 5.3, Updating of Lead Auditor's Records: 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.

Pos. C L~/~4 > I'or 'A ssessPledS~

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Qp pr cygpec4i'YB. LemJ AsseSS~< ShaLL have ~rt ci pote IQ a- Ynihrl mum oS'ivR Muebzee Xvdu.Sly type. eV~+o.b>WS. (ie. MRC luspefi'oOS IiiPo hssassiiiaist'si QA audits ...) ONo of cohioh shaU.

ba iuiLid tji year prior to his guaLi&cati ow' poseel GoHGG 25'a, 1.8-186 Amendme. No. 44

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SHNPP FSAR

~e.fire

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protection QA program, ch is under the management control of the QA o anization, has assured the sa 'action of QA guidelines during the design, ocurement, installation and a eptance testing of fire protection equipment a systems provided for the pla and will assure their continued inspection, te ing, maintenance and administ tive control after the plant becomes operation ProPoseJ Ch u86'.l As part of their managem t control, the QA organizati has'.

1) Developed a fire p tection QA program, incorpor ing suitable requirements necessary for he provision of an effective ire Protection System,

2) VeriEied the acceptability of t fire protection QA program o the management responsible for fire pro ction, and Verified, through review, audit and surve'ance, the P')

effectiveness of the QA program for fire protects Pr Act/oH ale,rae.gS O.~C l QCLu.d 9(i

'ire Q

e) Fire Protection Procedure - The organization, training and equipping of all personnel who might be involved in adequate responses to fire emergencies at the plant, including operating personnel, security forces, fire brigade members, visitors and local outside Eire department members, are described in detail in the Fire Protection Procedure (FPP). Salient features of the FPP are described below. Procedures providing for a 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 Eire 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 fire emergency response.

9.F 1-56 Amendment No.. 20

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SHNPP FSAR The primary purpose of the Nuclear Training Section is to ensure that the Company has highly qualified personnel available to maintain and operate its nuclear generating plants in a safe and efficient manner. These responsibilities and services are provided by an organization consisting of five units which support nuclear projects: the Harris Energy and Environmental Center (HENDEC) Training Unit, the Curriculum Development Unit also located at the HENDEC, and the three Training Units located at the respective nuclear plants.

(7) The guality Verification Section is responsible for supporting CP&L's nuclear plants in the areas of guality Control inspections and vendor qualification/surveillance.

f. The Nuclear Business 0 erations De artment has the primary responsibility for ensuring that the adminstrative services are provided within the Nuclear Generation Group in a professional, timely, and cost-effective manner. This includes oversight, functional direction, and .

leadership of such administrative activities as planning, financial management, materials management, information service, and records management.

The Department is also responsible for Group performance goals monitoring and for ensuring that Group performance standards are consistent with industry experience and the expectation of regulators.

g. Nuclear Assessment De artment. The Hanager of the Nuclear Assessment Department reports to the Senior Vice President - Nuclear Generation Group and is responsible for evaluating the effectiveness of the sections and one unit in the Nuclear Assessment Department:

~~

production organization, identifying deficiencies to desired performance, and the verification of actions taken to eliminate such a

There are four uclear Assessment Corporate Section, (b) Project Assessment HNP, (c) Proje Assessment RNP, (d) Project Assessment BNP, and (e) equality Check and Administration Unit. The responsibilities are summarized below: aV.iaeactes

a. The Nuclear Assessment Corporate Section is responsible for planning, scheduling, and coordinating Functional Area, Site, and Corporate assessments. The Nuclear Safety Review Unit as part of this section accomplishes the independent review'equirements described in the plant Technical Specifications. ~l e ~ ~28

b. The Project Assessment Section at each nuclear project is responsible for performing day-to-day assessments of plant activities. These assessments include direct observation of work activities, reviews of plant documents, and interviews with plant staff to gather data to be analyzed to provide feedback to management.

c. The guality Check and Administration Unit has direct management responsibility for implementation of the guality Check Program as outlined in the approved guality Check Procedure and for providing administrative support for the department.

2. Power Supply - The Executive Vice President, Power Supply, reports to the President/Chief Operating Officer and is responsible for the planning, engineering, modification, operation, and maintenance of the generating, transmission, and associated facilities, and for the fuel and materials management of the generating facilities. There is one group and three departments reporting to the Executive Vice President, Power Supply: (a) the Fossil Generation Group, (b) System Planning and Operations Department, (c) the Transmission Department, (d) the Technical Services Department. The responsibilities of each of these are described below:

13.1.1-3 Amendment No. 44

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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 Sa ety Review Unit is comprised of experienced personnel who, in general, have t collective expertise and technical competence to review problems in the llowing areas:

N lear Power Plant Operations Nuc ear Engineering Chemi try and Radiochemistry Metall gy Instrum tation and Control Radiologi l Safety Mechanical d Electrical Engineering Administrati e Control Seismic and E ironmental Quality Assuran e Practices Looking more at the details of the r view function, the following specific items are evaluated:

Plant procedure changes meeting 10 R50.59 review criteria, Plant design changes meeting 10CFR50 59 review criteria, Licensing actions, Test or experiments not described in th facility FSAR, Plant operational occurrences (LERs),

Regulatory violations, Technical Specification changes, Nuclear Safety Review Committee meeting minut 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 conducted on site, 8Ild Any item deemed appropriate for review relative to s e operation.

Should an item arise where sufficient expertise is not avail e within Nuclear Safety Review Unit, the organization has the flexibili and authority to call on appropriate personnel to supplement the independent r view ensuring satisfactory resolution of the item. The Nuclear Safety Review U organizational structure is shown in Figure 13.4.2-1.

t Written records of independent reviews are prepared and retained as are periodic reports to corporate management that address safety-relate issues.

13.4.2-1 Amendment, No. 43

Pro osed Chan e 29 13.4.2 Inde endent Review The description of the independent review program is contained in Section 6.5, "Review and Audit" section of the Plant Technical Specifications.

SHNPP FSAR hssessrn~g 13.4.3 WU&R PROGRAM The purpose of corporate operation l audits is to ensure an effective means of reviewing and evaluating plant opera ional activities. The implementation and effectiveness of the continuing gA Pro am shall be regularly assessed for compliance with 10CFR50, Appendix B, NR egulatory Guide 1.33, ANSI N18.7, and N45.2.

Th corporate organization responsible for in endent audit is the Nuclear Asse ment Department. The objective of the de rtment is to assess functions involv in the operation of the Company's nuclea lants to assure all levels of manag ent that commitments to Regulatory Guides nd applicable technical codes are ing carried out and regulatory requiremen are being met. The function is scribed in ANSI N18.7 as a comprehensive stem of planned and documented au s to verify compliance of all aspects of e administrative controls and qua ty assurance programs.

Carolina Power 5 Lig Company's principal means of achieving a effective, safe nuclear plant is e Company's Corporate guality Assurance gram (C(AP). The CHEAP addres s design, operation, maintenance, and mo ication for the plant life. It co rs procurement, design, and operation ass iated with the fabrication and con ol of nuclear fuel. The role of the Nuc r Assessment Department and the ality Verification Section in these prog s t t f"~

is to assure that procedures are eveloped to implement each program and these procedures are being followe .

+he )gdpcMd~ ~scsSMB P~'A )g p.P ckWe. PSALM Th d septi f EHIIPP i i d I S llowing criteria are addressed in developing the audit requirements for Nuclear ment Department audits:

Plant Operating a nd Procedures.

Plant Technical Specifications inc requirements.

'he following minimum The conformance of facility operation to provisions contai 'thin the Technical Specifications and applicable license conditions at leas e per 12 months.

Proposed cha.use +

13.4.3-1 Amendment.No. 44 .

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

The suits of actions taken to correct deficiencies occurring in unit equi at, structures, systems, or method of operations that affect nuclear afety at least once per 6 months.

The verifi tioa of compliance with and implementation of the requirements of the quality assurance program to meet the criteria of AppencHx "B", OCPRSO, at least once per 24 months.

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

The Security Plan an implementing 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 ation considered appropriate by responsible management,.

Commitments made in the plant PSAR.

SHNPP will be audited three to five times ye y. Nxclear fuel activities are audited annually. (Fuel suppliers are also sub ected to audits.) Additional audits may be requested by line or corporate emeat if special problems are encountered.

The organizational structure for the Nxclear Asses t Department is shown in

~

Figure 13.4.2-1.

~ ~ ~ When necessary to augment an audit tW, outside consultants-or qualified Company personnel independent of the operat on being audited may be utilized.

The areas audited aad the minianan frequency of the audits listed below:

Nuclear Puel Section- - Once per. year.

nuclear, Puel Supplier, - Once during applicable the period c red by

'purchase. order or once. every three years, whichever is shorter Q-List'Modifications Performed by Plant Staff - Once per year.

Radwastcv Transfer, Packaging, and Transport Activities -- Once per, ye Pro-o ChwdcF. +30 13:4.3-2 Amendment=,Ho;= 43

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SHNPP FSAR uclear Engineering Department - Once per year.

Harri lant Quality Control - Once per year.

Vendor Equipm Quality - Once per year.

Other than audit reports, e Nuclear Assessment Department communicates to Senior Management by a monthl eport of QA audits conducted during the month including a status of the action ms and their resolution. The Manager-Nuclear Assurance Department reports the Executive Vice President - Power Supply which provides direct communicatio Discussions involve an overview of the Company's various organizational unit efforts in maintaining an effective QA program. In addition to these meet s, the Manager - Nuclear Assessment Department meets on a regular basis with artment personnel to review activities. In addition to the formal audit acta ties, the Nuclear Assessment Department Section is often called on by other C any members for interpretations of codes, standards, or other QA recyxirements. is contact is in an advisory role identifying acceptable modes of operation an does not compromise the unit's independence from line activities.

13.4.3-3 Amendment No. 43

Pro osed Chan e 31 Section 17.2 is being deleted in replaced with the attached 17.3.

its entirety. it is

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ENCLOSURE 3 SHEARON HARRIS NUCLEAR POWER PLANT NRC DOCKET NO 50-400/OPERATING LICENSE NO. NPP-63 PROPOSED PSAR SECTION 17.3 UALITY ASSURANCE PROGRAM DESCRIPTION 17.3 HNP UALITY ASSURANCE PROGRAM DESCRIPTION 17.3.1 MANAGEMENT It is the policy of Carolina Power 6 Light Company (CPQL) 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 require 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 is responsible 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 Department (NAD) independently 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 Senior Management, and ensuring adequate action is taken to correct and eliminate these conditions.

E3-1 (2049GLU)

(~

17.3.1.2 Or anization The CPGL 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 CPGL'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 NAD shall independently monitor and assess the Company's nuclear programs on a continuing basis. The NAD performs assessments which incorporate the previous "QA audits." These evaluations are performance based with emphasis on quality of the end product.

The Manager NAD shall review with the Executive Vice President Nuclear Generation Group on a regular periodic basis the overall effectiveness of the Company's QA Program. He shall have access to the corporate management up to and including the President/Chief Operating Officer to resolve any quality or nuclear safety related concerns if the concerns cannot be resolved satisfactorily at a lower management level.

The results and effectiveness of the assessment organization and processes in accomplishing its assigned ob)ectives will be evaluated annually.

17. 3. 1. 4 A~uthortt 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.

E3-2 (2049GLU)

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 CPGL 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 by responsible management to ensure qualified individuals are assigned to activities affecting quality.

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

17.3.1.6

~ ~ ~ Corrective Action The primary goal of the CPGL 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 CPGL to seek improvement in each nuclear plant's performance as well as in the performance of supporting departments.

Management will emphasize to all levels in the organization the importance of identifying and effectively correcting situations that can adversely affect human and equipment performance. An important aspect of this program is the assignment of qualified personnel to accurately evaluate equipment/human performance problems, implement appropriate corrective actions, and verify corrective action adequacy.

Management is responsible for fostering a positive, environment that encourages the self-identification of adverse conditions and trends.

The program requires that an evaluation of adverse conditions such as conditions adverse to quality, nonconformances, failures, malfunctions, deficiencies, deviations, and defective material and equipment is conducted to determine need for corrective action.

Conditions adverse to quality are identified through inspections, assessments, tests, checks, and review of documents.

The program requires corrective action to be initiated to preclude recurrence of significant conditions adverse to quality.

E3-3 (2049GLU)

0 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 the Plant Nuclear Safety Committee (PNSC).

17.3.1.7 Re ulator Commitments The operation of nuclear plants shall be accomplished in accordance with the U.S. Nuclear Regulatory Commission (NRC) Regulations specified in Title 10 of the U.S. Code of Federal Regulations.

The operation of the Company's nuclear power plants shall be in accordance with the terms and conditions of the facility operating license issued by the NRC.

The program and procedures are designed to ensure compliance with the NRC Regulatory Guides and ANSI Standards applicable to the operations phase, and to which HNP is committed. The commitment to comply or exceptions for CPGL to follow are presented in Section 1.8 in this FSAR. The requirements of this section (17.3) 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).

17.3.2 PERFORMANCE/VERIFICATION Personnel performing work activities are responsible for achieving the acceptable level of quality.

Personnel performing verification activities are responsible for verifying the achievement of acceptable quality.

Work is accomplished and verified using instructions, procedures, or appropriate means that are of a detail commensurate with the activity's complexity and importance to safety.

Criteria that define acceptable quality are specified in procedures and/or other documents, and verification, when required is performed against these criteria.

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1 17.3.2.2

~ ~ ~ Desi n Control Procedures define requirements for the control of design activities associated with modifications of items that are safety-related.

Design changes are subject to appropriate controls which were applicable to the original design. Carolina Power 6 Light Company may designate an organization to make design changes other than the organization which prepared the original design. In any case, CPQL wi.ll assure that the organization has access to pertinent background information, including an adequate understanding of the requirements and intent of the original design, and that the organization has demonstrated competence in applicable design areas.

Care shall be taken to assure that the design selected to accomplish a necessary or desirable change does not create "new" problems in off-normal modes of operation or in adjacent inter-tied systems.

Design changes made to the plant are accomplished in a planned and controlled manner in accordance with written, approved procedures. These procedures include provisions, as necessary, to ensure that:

a) Design documents (such as specif ications, 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.

c) Materials, parts, and equipment which are commercial grade items or which have been previously approved for a different application are evaluated for sui.tability 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 controlled, including the review, approval, release, and.di.stribution 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; compatibi.lity of materials; and accessibili.ty 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.

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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 providedi 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.

b) Procedures identify the positions or organizations responsible for design verification and define their authority and responsibility.

Procedures also provide guidelines as to the method of. design verification to be used. Unless otherwise specified, design verification is performed by the method of independent design reviews and includes verification that SAR commitments have been addressed.

c) Qualification tests, or analyses when appropriate, shall assure that all modes of operation are not adversely affected by the design change.

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

Carolina Power 6 Light Company maintains a program for supplier evaluation, results of supplier evaluation, surveillance of suppliers, supplier furnished records, certificates of conformance, effectiveness of supplier quality control, and the purchase of spare or replacement parts.

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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 CPGL 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.

Receipt inspections are performed by qualified inspectors in accordance with procedures to assure thats 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 i.nstallation 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 clearly 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 Carolina Power 6 Light Company procurement documents are prepared,. reviewed, approved, and controlled in accordance with procedures to assure that requirements are correctly stated, inspectable, verifiable,. and controllable, and there are adequate acceptance/rejection criteria. Procurement documents are reviewed by personnel knowledgeable in applicable technical and quality requirements, and documentary evidence of that review and approval is retained and available for verification.

17.3.2.6 Identification and Control of Items Procedures require spare or replacement parts to be subject to QA Program controls, codes and standards, and technical requirements which ensure they are suitable for their intended service.

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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 i.ndividual accept tags; however, status of unacceptable bulk items wi.ll be so indicated).

Procedures require that materials, parts, and components be identified and controlled to prevent the use of incorrect or defective items. These procedures also require that identification of items be maintained either on the item in a manner that does not affect the function or quality of the item, or on records traceable to the item.

Procedures implementing these requirements provide for the followi.ng:

a) Verification that items received at the plant are properly identified and can be traced to the appropriate documentation, such as drawings, specifi.cations, purchase orders, manufacturing and inspection documentsf nonconformance reports, or material test reports.

b) Verification of item identification consistent with the CPGL inventory control system and traceable to documentation which identi.fies the proper uses or applications of the item.

c) Verification of correct identificati.on 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 sub)ect 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 handli.ng, storage, and shipping of safety-related items. These procedures require measures to be taken to ensure special handling, storage, cleaning, packaging, shipping, and preservation requi.rements are established to control these activities in accordance wi.th desi.gn and specification requirements to preclude damage, loss or deterioration by environmental conditions such as temperature or humidity.

Provisions are established to control the shelf life and storage of chemicals, reagents, lubricants, and other consumable materials.

17.3.2.8 Test Control Procedures define requirements for test programs when required and require that items be tested to demonstrate that they will perform satisfactorily in service.

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 equipmentf E3-8 (2049GLU)

al c) Mandatory inspection hold points, d) Acceptance criteria Test results are documented, evaluated, and their acceptability determined by a qualified, responsible individual or group.

When the acceptance criteria is not met, affected areas are to be retested or evaluated, as appropriate.

17.3.2.9 Measurin and Test E ui ment Control Procedures define requirements for the control of measuring and test equipment used. These procedures include requirements to establish procedures for the calibration technique and frequency, maintenance, and control of measuring and test equipment.

Inspections and test devices are selected to assure accurate measurement (i.e.

to overcome inherent inaccuracies associated with environment, human error, equipment, etc.).

Measuring and test equipment (M&TE) is identified and traceable to the calibration test. data.

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.

f) 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.

Calibration of installed plant devices shall be against M&TE having sufficient accuracy, greater than the device being calibrated, to assure that the system E3-9 (2049GLU)

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, logsi 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.

11 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.

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 E3-10 (2049GLU)

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.

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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.

Modifications, 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 CPGL 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 nucle'ar plants with the responsibility to identify adverse conditions (including conditions adverse to quality).

Procedures include requirements for verification of the acceptability of the rework/repair of items by reinspection and/or testing in accordance with the original inspection or test requirements or by an accepted alternative inspection and testing method.

Conditions that require rework/repairs are identified through the use of maintenance work request forms.

17.3.2.14 Control of Documents Procedures define requirements for the development, review, approval, issue, use, revision, and control of documents. These procedures define the scope of which documents are to be controlled.

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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 ori.ginal review and approval or by other designated qualified responsible organizations.

Controlled documents are to be available at the location where the activity will be performed prior to commencing the work, except in a radioactive contaminated area where the documents will be readily available.

A document control system has been established to identify the current revision number of instructions, procedures, specifications, and drawings.

Superseded documents are controlled to prevent inadvertent use.

17.3.2.15 Records The program, requi.res that suffi.cient records be maintained to provide documentary evidence of the quality of items and the accomplishment of activities affecting quality.

Procedures define requirements for the identi.fication, collection, and storage of QA records.

is 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 destructi.on by fire, flooding, theft, and deterioration by the environmental conditions of temperature and humidity.

17.3.3 ASSESSMENT The overall ob)ective at CP6L is to encourage ownership, involvement,.and dedication by each individual supporting the Nuclear Program. This involves continually and aggressively looking for ways to improve the overall performance and safety at each plant. Thi.s 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 CPGL Nuclear Program is improving on a continual basis. This process, along with an effective corrective action program, ensures that conditions are identified earl corrected p rom p tlY and effectivel Y before becoming significant quality or safety problems.

Personnel responsible for carrying out the assessment functions, including safety committee activities, nuclear safety reviews, verifications, E3-12 (2049GLU)

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 Program are responsible for ensuring that self-assessment activities and processes are implemented within their functions on a continuing basis.

17.3.3.2 Self-Assessment It is the management expectation that individuals and organizations will self-assess their end product. Adverse conditions identified during self-assessment activities are reported and resolved in accordance with the corrective action program.

Line Or anization Each individual, work group, and manager should be alert and open for areas that may need improvement.

Members of the line organization are charged with the responsibility to continually evaluate their activities and use each opportunity to achieve higher standards of quality and improved performance.

Planned and periodic self-assessment activities focus on how well the integrated QA Program is working and is to identify conditions that hinder the organization from achieving its safety, quality, and performance goals and standards.

Nuclear Services De artment The Nuclear Services Department shall monitor specific functional areas, along with the line organization management, to determine that the desired levels of performance are being achieved. Individuals assigned these duties shall work with each nuclear project to improve implementation of CPGL's Nuclear Programs and processes to support safe and reliable operation.

17.3.3.3 Inde endent Assessment The NAD is responsible for conducting independent assessments of functions and activities affecting the nuclear programs at CP&L.

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 NAD may provide assistance to the line organization by participating in ad hoc committees or analyzing specific technical issues, if such assistance is deemed to be in the overall best interest of safety and is approved by NAD management.

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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 A primary objective of the NAD is to assess the effectiveness of the line organization's self-assessment processes.

The assessment process includes gathering data, analyzing data, focusing on selected issues and identifying deficiencies to desired performance. The results of assessments are communicated to management in a manner that causes action to correct deficiencies and develop action to prevent recurrence. In addition, this process should evaluate corrective measures adopted to eliminate the deficiencies identified.,

Data is gathered using performance based techniques during:

o Observations of work activities, 0 Interviews, o Reviews of documents to gather information (including the use of NRC, INPO, and other agency evaluations)g 0 Review of self-assessment data and reports (performance indicators, trend reports, etc.)

o Nuclear Safety Review activities, o Team assessments (functional, site/department, corporate),

o Analysis of plant data and reports (including adverse condition reports, etc.)

Planning activities identify the organizations to be evaluated, the characteristics to be focused on during the assessment, and the applicable acceptance criteria. Assessment activities are selected with flexibility based on various factors. These factors include but are not limited to:

importance to safety and reliability, NAD assessments of site work activities, time since last assessment, plant management perspective, outside agency audits, and problem areas identified from industry and CPGL 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 significant issues which may impact safety and reliability when analyzing data.

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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.

Nuclear Assessment Department Program Assessments of the following Functions/Areas will be routinely performed:

A. Operations B Maintenance C. Engineering (Design/Modifications/Technical Support)

D~ EGRC (Chemistry/Radiological Controls/Environmental Monitoring)

E. Fire Protection F. Nuclear Fuels Assessments of two Functions/Areas will be performed at the prescribed frequencies:

G. Emergency Preparedness (PER 10 CFR 50.54 (t))

H. Security (PER 10 CFR 50.54 (p))

As part of the overall assessment scheduling activity, the following program elements will be considered and periodically included in the scope of functional assessments. When several assessments indicate potential problems in a program element, a special assessment of that element will be performed.

a~ Control of Measuring and Test Equipment

b. Control of Purchased Material Equipment and Services c ~ Control of Special Processes d0 Corrective Action

e. Document Control

f. Handling, Shipping, and Storage go Identification and Control of Materials Parts and Components

h. Inspection 1~ Inspection, Test, and Operating Status (Equipment Control)

Instructions, Procedures, and Drawings

k. Nonconforming Materials, Parts, and Components Organization

m. Outage Management

n. Procurement Document Control 0~ Records po Test Control

q. Training and Qualification

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

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.

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Independent assessment results are communicated to line management to allow for timely action to address potential problems or recognize strengths and superior performance.

Independent assessment results are documented .and reviewed with management personnel responsible for the areas assessed.

Results of assessments, special investigations, and analysis of data will be provided to NAD management for review. A summation of assessment perspective, along with potential issues and recommendations shall be presented to the Executive Vice President Nuclear Generation Group on an approximately bimonthly frequency.

Follow-up is accomplished to assure that corrective action is taken as a result of the assessment and that deficient areas are reassessed, when necessary, to verify implementation of adequate corrective actions.

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