ML19308D677

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Forwards Revised Comparison Matrix & Supporting Explanatory Proposed FSAR Revisions in Response to 770125 Ltr Re Facility Operational QA Program
ML19308D677
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/03/1977
From: Rodgers J
FLORIDA POWER CORP.
To: Stolz J
Office of Nuclear Reactor Regulation
References
NUDOCS 8003120780
Download: ML19308D677 (19)


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U.S. NOCLI. AR HEC.ULATOR Y CoF ,sioH CoCKET NU"f3C P. I T Penc , oru 195 *%

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, _50-301.

NRC DISTRIBUTION FoR PART 50 DOCKET MATERI AL l FHOM. DATE OF DOCUMENT 10: 3-3-77 11r J F Stolz Florida Pvr. Corp __j St Petersburg, Fla OATE RECEIVED J T Rodgers 3'7~77 +

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M Power co..o....o- March 3, 197/

t Mr. John F. Stolz, Chief N Light Water Reactors Branch No. 1 p; ,\

Division of Project Management / :';// (i .l f'c i'. ;- w

CM,.' (- h U.S. Nuclear Regulatory Commission '

Washington, DC 20555 Es

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In re: Florida Power Corporation y,( ;,3,4 ' . ,; .'

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Crystal River Unit No. 3 Docket No. 50-302 -

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Dear Mr. Stol:

C This submittal is in response to your letter of January 25, 1977, regarding the Crystal River Unit No. 3 Operational QA Program.

Appended to this letter is a revised comparison matrix and supporting explanatory proposed FSAR revisions. As you will recall, a comparison matrix with supportive notes was sub- ,

mitted with our September 22, 1976, letter. The enclosed  !

in fo rma tion , in addition to the proposed revisions which you found acceptable in our earlier transmittal of September 22, 1976, should provide a sufficient description for your staff to verify that our Operational QA Program does meet the re-quirements of ANSI N18.7-1976, and the Regulatory Guides (Nos. 1.8, 1.30, 1.37, 1.38, 1.39, 1.54, 1.58, 1.64-Rev. 1, 1.74, 1.88 and 1.94) which endorse the ANSI standards re-ferenced therein, except those areas for which alternative I controls are provided. I Please advise if additional discussion or information is desired.

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Very truly yours, ,(

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O Rodgers is;. M3/jf. N ~

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Asst. Vice President - - o,._

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,g Attachment -'

General Office 3201 Thirty-fourtn street soutn . P.O. Box 14042. st. Petersburg. Ficrida 33733 e 813-866-5151

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COMPARIS0N ANALYSIS MATRIX ANSI N18.7-1976 FPC FSAR NOTE REFERENCE TO REFERENCE SECTION REFERENCE SECTION DETAILED COMMENT (2)

(1) Sept. 22,1976 March 3, 1977 Note No. Note No.

1 1.7.6.7.1 and 13.4 1

2. 1.7.7 1 3.1 1.7.6.7.1 (last Paragraph, Page1-58q) 2 3.2 1.7.5.1.1, 1.7.5.1.2, 1.7.6.7.1.3, and 1.7.6.7.1.b 3.3 1.7.6.7.1.b 3.4.1 12.1 3.4.2 Appendix 12.A, Sections 12.1.3, 1?.2.4, 1.7.5.6.1.j 12 4.1 1. 7. 6. 7.1. r, 1. 7. 6. 7. 3, 1. 7. 6. 7. 4, and 1.7.6.7.5 4.2 1.7.6.7.1.r 4.3.1 1. 7. 6. 7. 2, 1. 7. 6. 7.4, and 1. 7. 6. 7. 5 3 4.3.2 1.7.6.7.5 3 4.3.3 1. 7. 6. 7. 3, 1. 7,6. 7. 4, 1. 7. 6. 7. 5, and 1.7.6.7.1.q 3 4.3.4 12.6 and 1.7.6.7.5 3 4.4 , 12.1.1 4.5 1.7. 6.7.1. r, 12.1.1 and 12.6 3

'5.1 1.7 5.2 12.1.2 and 1.7.6.7.2 5.2.1 12.1.2 and 1.7.6.7.1.a 5 5.2.2 1.7.6.7.1.e and 12.4 6 5.2.3 12 (all) 4 5.2.4 12.4 7 5.2.5 12.4 4 5.2.6 12.4 9 5.2.7 12.1.1, 1. 7. 6. 7.1. r and 1. 7. 6. 7. 2 10 12 5.2.7.1 1.7.6.7.1.j,1.7.6.7.1.k,and

1. 7. 6. 7.1 10 12.1.1 5 5.2.7.2 12.1.1, 1. 7. 6. 7.1. r , 1. 7. 6. 7.1. c ,

and 1.7.G.7.2 10 11 5.2.8 12.4 12 5.2.9 12.3 5.2.10 12.4 6 5.2.11 1.7.6.7.1.e 5.2.12 1.7.6.7.1.q 7 5.2.13 1.7.6.7.1 9 8 5.2.13.1 1.7.6.7.1.d,1. 7.6.7.1 (Page 1-58g, last paragraph) 5.2.13.2 1.7.6.7.1.g 5.2.13.3 1. 7. 6. 7.1. h 5.2.13.4 1.7.6.7.1.m 9 5.2.14' 1.7.6.7.1.o and 1.7.6.7.2 5.2.15- 1.7.6.7.lf and 12.4 5.2.16- 1.7.6.7.1.L 10

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5.2.17 1.7.6.7.2.b and 1.7.6.7.1.j 12 5.2.18 1.7.6.7.1.j 5.2.19 1.7.6.7.1.k and 13. (all) 5.2.19.1 13.4 l 5.2.19.2 13.4 l 5.2.19.3 1.7.6.7.1.k 5.3 1.7.6.7.1.e and 12.4

6. Not Applicable i

! Fcutnotes (1) This column shows the notes which were submitted in the FPC letter of September 22, 1976. and found acceptable as indicated in the NRC letter of January 25, 1977.

(2) These notes are proposed in response to the NRC letter of January 25, 1977 l

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! (Note: In places where both columns have been left blank, it is I

intended that adequate compliance with ANSI N18.7-1976 is met by the

! Florida Power Corporation Quality Program.)

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Noto 1 - Ratcr:nca ANSI N. 7-1976, Seet, ion 2,.

The terms and their definitions as presented within Section 2 of ANSI U18.7-1976 and the other terms and their definitions as contained within ANSI Nk5.2.10 have been compared with the glossary of terms as contained within FSAR Section 1.7.7 The following amendments to FSAR Section 1.7.7 vill be incorporated:

A. Page 1-62, Section 1.7.7 which currently reads: "The following glossary describes the terms used in Section 1.7 Quality Program."

will be amended to read:

"The following glossary describes terms used in the Quality Progra=

and specifically within Section 1.7 These terms and their definitions and others utilized throughout the Quality Program are endorsed by ANSI 18 7-1976."

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3. Page 1-64 which currently reads:

"Non-Cenformance: A condition of any article, material, or service in which one or more characteristics do not conform to requirements.

Includes failures, dicerepancies, deficiencies, defects, and malfunctions."

will be amended to read:

"Non-conformance: A deficiency in characteristic, docu=entation, or procedure which renders the quality of an item unacceptable or indeterminate. This includes physical d6fects, test failures, incorrect or inadequate documentation or deviation from prescribed processing, inspection or test procedures."

C. Page 1-64 which currently reads:

"Qualifica*. ion: Meeting required tests or examinations to show that a velder, inspector, or other personnel are qualified based upon specific requirements which state acceptance criteria for an adequate perfor=ance."

will bs amendsd to raad:

" Qualification: The characteristics or abilities gained through training or experience or both that enable an individual to perform a required function."

D. Page 1-65 Delete:

" Qualification Data: Specified requirements which state what constitutes performance."

Add:

" Qualified Procedure: A procedure which incorporates all applicable codes and standards, =cnufacturer's parameters, and engineering specifications and has been proven adequate for its intended purpose."

E. Page 1-65 Delete:

" Repair: Approved operations performed on a non-cenforming article to Add:

" Repair: HThe process of restoring a non-conforming characteristic to a condition such that the capability of an item to function reliably i

and safely is unimpaired, even though the item still may not conform to i the original requirer-ents."

F. Page 1-65 delete the paragraphs entitled SYSTDI and SYSTEMS INTEGRATION and replace with the following: l

" SUBSYSTEM: A. group of assemblies or components or both ccmbined to perform a single function.

SYSTEM: A group of subsystems united by some interaction or inter-d2pendence, performing many duties but functioning as a single unit.

(A' system may relate to hardware items or may be an organized and disciplined approach to acccmplish a task; e.g., a failure reporting system)." i i

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Note 2 - Reference ANSI N18.7-1976, Section 3.1 The last paragraph of Section 17 6.71 on page 1-58q will be amended to read as follows:

"The objective of the program is to maintain managerial and administrative control over operation of and action relative to safety-related structures, systems, equipment, and components through documenting the adherance to approved procedures without unnecessarily hindering the functioning of the plant. Florida Power Corporation is committed to comply with ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," with alternative controls identified in the program description which fulfill the requirements but which differ slightly in specific implementation. When the ANSI standards referred to in ANSI N18.7-1976 are superceded by a revision approved by ANSI, the revision vill be reviewed by Florida Power Corporation with alternate controls provided, or the standard vill be utilized as revised."

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Note 3 - Reference ANSI N18.7-1976, Sections h.3 and 4.5 Section 1.7.6.7.5 of the FSAR will be revised to read as follows:

"1.7.6.7 5 Independent Review Program The Nuclear General Review Committee (NGRC) is a standin6 committee within Florida Power Corporation which reports to the Senior Vice President, System Engineering and Operations. The NGRC is responsible for independently reviewing the operational activities of Crystal River Unit No. 3.

The NGRC is structured and performs its functions in accordance with the requirements of ANSI N18.7-1976."

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Note h - Reference ANSI N18.7-1976, Section 5.2.5 Section 12.h shall be amended to read:

" Procedures within the Plant Operations Quality Assurance Manual are permanently or temporarily amended via use of a Procedure Review Record (PRR) on which guidance is established and approved by an established approving authority. Temporary changes are designated for a prescribed time fraae. The change is documented, reviewed by the Plant Review Committee and approved by the Nuclear Plant Manager within fourteen (14) days of i=plementation."

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1 Note 5 .- Reference ANSI N18.7-1976, Section 5.2.7 1 i

Section 5.2 71 of AUSI N18.7-1976 requires'a preventive maintenance program. The following paragraph vill be added in FSAR Section 12.1.1, as a second paragraph on Page 12 h:

"Under the provisions of 10CFR50.55(a), Florida Power Corporation shall provide an Inservice Inspection Program. This program and a Preventive Maintenance Program are in compliance with the ASME Boiler and Pressure Vessel Code and the requirements of Section 5.2.'(.1 of ANSI U18.7-1976.

The program will encompass the nuclear plant systems required to meet safe shutdown criteria and to return the plant to service, folicving plant outages in a safe and expeditious manner. The Program contains mandatory examinations, testing and inspections to evidence adequate safety, as well as defines the frequency and type of naintenance to be performed."

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Note 6 - Reference ANSI N18.7-1976, Sectica 5.2.10 FSAR Section 1.7.6.7 1.e shall be amended to read:

" Detailed specific requirements for housekeeping and cleanliness controls are implemented throu6h procedures contained in the Plant Operating Quality Assurance Manual. This inplementation is in compliance with the requirements of ANSI N18.7-1976, Section 5.2.10."

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Nota 7 - Rafertnca ANSI N18.7-1976, Szetion 5 2.12 A.. Section 1 7.6.7 1.q of the FSAR shall be amended in the first paragraph to read:

" Florida Power Corporation has established and implemented a system for the collection, storage, and maintenance of Quality Assurance Records as required by the design documents, procurement documents, and Regulatory Guide 1.88. All records transmitted to the quality files shall be done so in accordance with established written pro-cedures. Florida Power Corporation, Quality Programs Department audits all quality activities to assure that records within their possession are kept in accordance with written procedures".

JB . Section 1 7.6.7 1.q shall be amended in the second paragraph to read:

" Florida Power Corporation's Quality Program centains provisions which require that:

1. Two categories of Quality Assurance Records are established as Lifetime and Non-permanent. (Non-permanent records are required to show evidence that an activity was performed in accordance with applicable requirements but need not be retained for the life of the item. Lifetime records are required to be maintained for the life of the particular ite while it is installed in the plant or stored for future use).

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2. Quality Assurance Records are those records that furnish documentary evidence of the quality of items and of activities affecting quality. (A document is considered a Quality Assurance Record when the document has.been completed). These records include the results of review, inspections, tests, audits, monitorin6 of work performance and material analysis, the qualification of personnel, procedures, and equipment, design drawings and subsequent modifications, specification reports,

. procurement documents, calibration procedures and reports, and nonconformance and corrective action reports. The records are identifiable and retrievable as defined in AHSI N18.7-1976, Section 5 2.12.

-3 The inspection and test records contain the following:

a) Description of the types of operation.

b) Evidence of completing and/or verifying a manufacturing

- inspection or test operation.

4. Records are stamped, initicled, signed, or otherwise authenticated and dated by authorized personnel.

5 Storage facilities are constructed, located, and secured to prevent destruction and minimize deterioraticn or loss of records. Florida Power Corporation maintains a duplicate set of microfilmed information at a remote facility."

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' Nota 8 - Rmfersnca ANSI N18.7-1976, Section 5 2.13 l A. The first paragraph in FSAR Section 1.7.6.71.g, page 1-58g will be amended to read:

" Vendor evaluation surveys to qualify potential bidders in accordance with established Florida Power Corporation written procedures and in compliance with the ANSI N18.7-1976, Section 5 2.13, are conducted by FPC Engineering and Quality Programs Department personnel or through qualified consultants. Florida Power Corporation's Quality Programs Department will audit purchasing activities to assure compliance with procedures. In addition, Florida Power Corporation will assure that all Quality requirements of the purchase document have been met, utilising random audits of the document files in accordance with established written procedures".

B. Delete the second paragraph under FSAR Section 1 7.6.7 1.g on page 1-58g and delete, also, Subparagraphs 1 7.6.T.l.g.1, 1 7.6.7.1.g.2 and'l.7.6.7 1.g.3

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. Noti 9 - Rafer:nca ANS1 W18.7-1976, Sectica 5 2.13.4 2 FSAR Section 1.T.6.7.1.m vill be revised to read as follows:

"m. Handling, Storage, and Shipping The Florida Power Corporation Material Systems & Stores (MS&S)

Department staff are responsible for material handling, storage, and shipping activities for plant spare parts and operating supplies in accordance with detailed written procedures contained within their MS&S Quality Operating Manual. These procedures provide full conformance with ANSI 318.7-1976, Section 5 2.13.h, with the'following exceptions:

a. Section 2.4 - Receiving and in-storage inspection vill be performed by experienced senior stores personnel trained and knowledgeable in the MS&S quality operating procedures,
b. Section 3 - Packaging of all stored material vill be in accordance with sound storage principles assuring the integrity of the stored item. Periodic in-storage f

( inspections vill be performed to assure proper condition of material packaging.

c. Section 5.2.2 - Receiving inspection for level A material vill be performed in the receiving area of the storeroom and assurances provided that the material meets the specifications of the Purchase Order (P.O.) or Requirement

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Outline (R.O.). Special electrical testing is conducted when specified.

The activities of 'the Material Syste=s and Stores Department associated with handling, storage and shipping of Crystal River Unit #3 material are audited by the Quality Programs Department."

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ilote 10 - Reference ANSI N18.7-1976, Section 5.2.16 The following paragraph will be added as the third paragraph of the FSAR Section 1.7.6.7.1.1:

" Calibration records and controls are provided for within the Plant Operations Quality Assurance Manual which complies with ANSI nl8.7-1976, Section 5.2.16."

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Nots 11 - Rafertnca ANSI N18.7-1976, Section 5.2.T.2.

A. FSAR Section 17.6.7.1.c, first paragraph shall be amended to read:

" Florida Power Corporation's Production Engineering Department vill provide an independent review for all safety-related modifications

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which f'volve development of, or changes to, design data or documentation.

This review will include verification of compliance with ANSI N18.7-1976, Section 5.2.7 2. Generally, all modifications vill undergo an Engineering review resulting in the establishment of a complete modification package. For non-safety-related modifications, an Engineering review may take place after the fact due to the necessity of getting the work acecmplished in a timely manner. The Plant Manager i

shall decide whether Engineering approval is required prior to installation. Florida Power Corporation's Quality Programs Department vill audit the design quality control function."

B. FSAR Section 1.7.6.7.1.c, delete the second paragraph and Subparagrc,hs 1.T.6.7.1.c.1 through 1.7.6.7.1.c.13 O

w f Note 12 - Reference ANSI N18.T-1976, Section 3.h.2, 5.2.7 and 5.2.17 FSAR Section 1 7.6.7 1.j, page 1-58j, shall~be-amended to delete the first'two paragraphs entirely as now written and replace with the following:

" Florida Power Corporation's Production Department Plant Staff and all participating contractors are required to provide written procedures for the performance of in-process inspection. Florida Power Corporation Quality Programs Department audits these activities to assure compliance to the procedures.

l Inspection personnel are qualified in compliance with ANSI N18.7-1976, Sections 3.h.2, 5.2 7, and 5.2.17, as follows:

1. On-site plant personnel including contractors and personnel filling temporary positions who are performing inspection and examination activities shall have appropriate experience, training, and retraining to assure competence as required by ANSI N18.1-1971.

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2. Quality Programs Department personnel or their contractors performing inspection and examination activites shall be qualified to ANSI Nh5.2.6-1973 with the following exceptions:

a, ' Personnel vill be qualified in accordance with the re- l quirements of individual FFC position descriptions in lieu of subsection 3.1 of ANSI Nh5.2.6-1973.

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b ~. Specific requirements as defined in Subsection 3.2 of j MiSI Nk5.2.6-1973 vill be met only in those areas found applicable by Quality Program procedures.

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c. Section h and Table I of MISI Nh5.2.6-1973 are not applicable within the FPC Quality Program as procedure approval and quality control functions may be performed by staff supervisory personnel.

f . 3. Other Florida Power Corporation support personnel performing inspection and examination activities vill be qualified through experience evaluation and by formal training programs. Imple-1 l mentation'of quality control functions is audited by the Quality Programs Department on a periodic basis."

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