ML19253A293

Responds to 790625 Ltr Re QA Reg Guides & ANSI Stds. Topical QA Rept Fpltqar 1-76A,proposed Revision 3,satisfies Requirements of 10CFR50.App B.Util Will Comply W/Reg Guides

ML19253A293
Person / Time
Site:	Saint Lucie, Turkey Point
Issue date:	08/13/1979
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Haass W Office of Nuclear Reactor Regulation
References
L-79-224, NUDOCS 7908210265
Download: ML19253A293 (2)

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FLORIDA POWER & LIGHT COMPANY August ll, 1979 L-79-224

!!r. Walter P. I!aass, Chief Quality Assurance Branch Division of Project Itanagemont U. G. Nuclear Pegulatory Co nission Wauhington, D. C. 20555

Dear Mr. Haass:

SUBJI:C P : Floridt Power & Light Company QA Tc ,ical Peport FPER l-76A, Pronosed Revision 3 Your letter of June 25, 1979, provided us . tith the NRC position that a clearer co .1itnent by PPL to the QA related regulatory guidt ; and ANSI standarda in ree rted. Y ou stated that " . . . the last paragraph on page 1 of Appendix C should be nodifj ed to indicate that FPL will co ply with the reJulatory positions of the regulatory guidm . Otherwise, FPL should state any exceptions to such regulatory positions and also state equivalent PPL alternativen for our al-uation".

It has always baen IPL's objective to have a round, comprehensivt Quality Assurance Progran that will raet 10CFR50, Appendix B, and provida adequate con-fidence t. hat safety related systems vill 1.erforn natisfactorily. He believe that our Topical (u111ty Assurance Report v currently written and inplenented natisfie , this objective. Our n.eeting th- intcut of the Occua mts listed in Appendix C (wi th several approved alternatives) is a major fact . r, but not the only facter, that provides the basis for our conclusion.

We had originally proposed the wording "meecs the intent of" due to the lack of spacificity and inconsistency among thc standards and to avoid dif fering inter-protationc of the wording of the standards by NRC inspectors. The I;nc approved that uording for our original Topicil OI Papert and its susse guent twc1 revisions.

To change the philonophy and the warding as you have directed will not, in oar opinion, provide a higher degree of assurance, nowever, the change will neces-nitate a aignificant increase in the number of alternative positions and some adjustr mta to PPL'a internal QA Progra.n dacumentation.

Accordingli. we have begun a systenatic co.parison of our QA Progran documenta-tion .piist the g:.cific '.:ording of CA rqulatory guides and ANSI standards.

(Your it.ntructions to change the wording in our Topical OA P.eport leads us to the conclusion that the enforcem nt of the ,to rd s " comply with the regulatory positions" vill be mare stringent and exacting than the enforcenent of the wording and philosophy of "umting the intent of" the docunents 1i.sted in Ap;endix C.) The developing of the clearer coraitrant to the exact wording of the regulatory guidee and standards will 11 an evolving process as addittonal alternative statemnts ace sub:1itted to the NRC as a res clt of our systematic comparison. When this proc ss is completed . we will change the last paragraph on page 1 of appendix C to show this clearer commitment. This comparison is scheduled to ba perforced in conjunction <;ith our regular two year audit cycle.

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Mr. Walter P. I!aann Page Two Should you have any queations regarding the above, please f,el free to contact Mr. Jack Vesnely on (305)552-3957.

Very truly your;,,

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Mcbert F. Uhrig V. ice President REU: AI:3 :pby cc: A. Schwencer, Operating Reactors " ranch !!1 J. P. O'Itoilly, Region II Robert I,owenstei n, IOquire a

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