ML19337B208

Forwards App Representing Complete Listing of Alternatives or Clarifications That Util Is Submitting for NRC Review & Subsequent Inclusion in Topical QA Rept,Fpltqar 1-76A

ML19337B208
Person / Time
Site:	Turkey Point
Issue date:	09/26/1980
From:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
To:	Haass W Office of Nuclear Reactor Regulation
References
L-80-321, NUDOCS 8010010537
Download: ML19337B208 (18)

Text

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ROR:OA POWER & LIGHT COPAPANY September 26, 1980 ,

} L-80-321 4

Office of Nuclear Reactor Regulation l Attention: Mr. Walt.ar P. Haass, Chief  !

Quality Assurance. Branch .

Division of Project Managemnt

U.S. Nuclear Reg.11atory Commission i Washington, D.C. 20555

Dear Mr. Haass Re Florida Power & Light Topical Quality Assurance l Report, FPLTQAR l-76A, Proposed Pavision i Our letter of April 30, 1980 stated that we intended to complete our [

, review of the FPL baseline QA documents by August 31, 1980 The review j

- has been accomplished and minor QA program changes have been effected 1' as a result. In addition, differences in methodology or implementation

., of certain requirements in Regulatory Guides and ANSI Standards versus ,

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the FPL QA program requirements were identified. The attached Appendix represents the complete listing of those alternatives or clarifications j that FPL is submitting for your review and subsequent inclusion in cur i Topical Report. t i

Very'truly yours, G y ,

C(RobertE.Uhrig kradb-<J Vice President

-Advanced Systems & Technology 4 REU:WW bt

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0 APPENDIX FLORIDA POWER & LIGHT COMPANY ALTERNATIVES / CLARIFICATIONS 1

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REGULATORY GUIDE 1.33 (DATED 11/3/72) CLARIFICATION Appendix A of Regulatory Guide 1.33 lists " typical safety related activities which should be covered by written procedures". Regulatory Guide 1.33 is invoked by the Technical Specifications at FPL Nuclear Plants.

l In order to avoid duplication cf requirements invoked in our licensing documents, the FPL Quality Assurance Program does not list those required operating pro-cedures specified in Appendix A.

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REGULATORY CUIDE 1.8, REV. 1, ANSI N18.1-1971 CLARIFICATION ANSI N18.1 describes the training and education requirements for plant staff positions and is endorced by Reg. Gitide 1.8 with an exception. That exception is the requirements for the Supervisor - Radiation Protection. ANSI N18.1 is invoked by Technical Specifications (Appendix A of the Facility Operating

License) at FPL nuclear plants. Reg. Guide 1.8 is also invoked by Technical Specifications at our St. Lucie plant and a license amendment has been approved for our Turkey Point plant to specify the Health Physics Supervisor qualifications '

addressed in Reg. Guide 1.8.

To avoid duplication of requirements, FPL will address Plant Staff Qualifications in only the Technical Specifications. .

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ANSI N18 7-1972 CLARIFICATIONS ANSI N18.7-1972, Sections 4.2.2.1, 5.3 and 5.5 requires that personnel performing the independent review and audit be specified in number and technical discipline.

This standard is invoked by the Technical Specifications (Appendix A of the Facility Operating Licenses) which have been approved for the FPL nuclear plants at St. Lucie and Turkey Point. Specifically this function is performed by the Company Nuclear Review Board (CNRB) identified in Section 6.5.2 of the Technical Specifications.

To avoid duplication of requirements, FPL will address the personnel and functions of this independent review and audit only in the Technical Specifications.

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ANSI N45.2.1 - 1973 ALTERNATIVES ANSI N45.2.1 - 1973 paragraphs 7.2.2, 7.2.3 and 7.3 address specific cleaning methods (Alkaline, Chelate, Acid) and make recommendations associated with several types of c1 caning methods.

delineate these paragraphs. FPL's QA manual does not specifically However, the procedure developed per paragraph 2.2 of ANSI N45.2.1 will ensure that any specific cleaning method chosen will be properly considered and controlled.

ANSI N45.2.1 - 1973 paragraph 5 states in part that, " Fitted and tackwelded joints (which will not be immediately scaled by welding) shall be wrapr ed with polyethylene completed "

or other non-halogenated plastic film until the welds can be The FPL QA manual shall require that the weld be covered to prevent entry of employed. moisture end contaminants but will not specify the material to be Materials employed to cover openings shall meet the requirements of Regulatory Guide 1.37, position 4.

ANSI N45.2.1 - 1973 paragraph 7.1 states in part, " Provisions shall be made to collect leakage and protect insulation from being wetted." FPL Quality Assurance Program includes the above requirement. However, FPL's Program allows the wetting of metalic type insulations which are not Adversely affected by wetting.

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ANSI N45.2.2 - 1972 ALTERNATIVES ANSI N45.2.2 - 1972 Sections 3.0, 4. 0, and the Appendix address all the requirements applicable to the packaging and shipping of material.

or ship material governed by this standard. Suppliers PPL in general does not package of material are required by Iurchase order to provide adequate packaging and shipping protection. Isolated cases of material packaging or shipping are treated on a case by case basis and receive protection comparable to that required by the manufacturer of that material. Loading, rigging and handling precautions identified in Section 4.3 are applied to material unloaded by FPL from a transport vehicle.

ANSI N45.2.2 - 1972 Section 5.2 requires that specific attributes of material and components received by FPL be inspected. For plants with operating licenses FPL verfies conformance to procurement documents during receipt inspections. Any of these attributes inspection.

identified in these procurement documents are verified during this ANSI N45.2.2 - 1972 Section 2.7 requires that items governed by this standard be classified into one of four levels by the buyer or the contractor. For plants with operating licences, FPL intends to consider what care is appropriate for each item individually rather than generically classifying the material into protection levels and providing care required of that level.

FPL considers this to be a more effective approach since the quantity of spare and replacement material, parts and components at an operating plant is limited.

Ultimately, material, parts and components governed by this standard will be afforded protection commensurate with the recommendations of Section 2.7 of this standard. -

ANSI N45.2.2 - 1972 paragraph 6.4.1 requires the periodic verification of such itens v

as identification and markings, protective covers, coating and preservatives, dessicante and inert gas blankets, etc. In lieu of addressing these specific items, FPL (at plants under construction) considers all the necessary preventation maintenance requirements for equipment and/or components on a case by, case basis.

ANSI N45.2.2 - 1972 Section 5.2, paragraph 5.2.1, requires certain preliminary inspections to be done " prior to unloading" of material which is received. We believe that the sequence specified in the standard is to facilitate commercial claims, and should these preliminary inspections occur "af ter unloading" that control of materials quality would not be degraded. Accordingly, rcquired shipping damage inspections may be performed after unloadirg.

ANSI N45.2.2-1972, Paragraph 7.4 requires that an inspection program be established for handling equipment and rigging, including methods for identifying acceptable and non-conforming items.

In lieu of having a program of periodic, documented inspections of rigging and handling equipment, FPL's practice is to have the individual user determine the equipment's acceptability prior-to each use. This prior-to-use inspection is exactly, the same as that required during periodic inspections, and uses criteria identified in ANSI N45.2.2-1972, Paragraph 7.4.

to indicate the acceptability of riggingThis practice also precludes the need for a system and handling equipment. Implementation of this prior-to-use inspection will be assured through periodic surveillances and audits performed by Quality Assurance and Quality Control. Cranes are inspected on a periodic 1 basis and will be subjected to this prior-to-use inspection.

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1 ANSI N45.2.3-1973 ALTERNATIVE POSITION For FPL's operating nuclear plants, alternative methods are followed to achieve 1973:

equivalent objectives for the below listed sections of ANSI N45.2.3-The zone designations of Section 2.1 of N45.2.3 and the require-ments associated with each zone are not consistent with the FPL Housekeeping requirements at our operating nuclear units. In lieu of the zone designation, cleanliness is maintained at a level con-sistent with the work being performed, so as to prevent the entry of foreign material into safety related systems. Documented cleanliness inspections are performed immediately prior to system closure.

Control of personnel, tools, equipment, and supplies is established when the safety function of a system, component, or item may be jeopardized and also while the reactor system is opened tor inspection, maintenance, or repair.

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ANSI N45.2.4-1972 CLARIFICATIONS ANSI N45.2.4-1972, Paragraph 2.3 addresses installation specifications and requires the inclusion of inspection and test objectives. FPL maintains that test values and inspection scope are inherently contained in the applicable procedures.

ANSI N45.2.4-1972, Paragraph 6.1.2 requires that the inspection of installed equipment verify that " good and proper workmanship" has prevailed. FPL .

maintains that acceptable parameter. compliance uith codes and standards along with company preference is the verification of " good and proper workmanship".

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ANSI N45.2.6-1973 ALTERNATIVE ANSI N45.2.6-1973, Paragraphs 1.1, 3.1, 3. 2.2 (a) and 4 (Table-1) identify requirements which apply to personnel who perform inspections, tests or non-destructive examinations or the or whocontrol participate in the and of scperts approval of procedures, the handling of data or test results, records.

FPL

1) theproposes approvalan of alternative procedures,to2)capability requirements for those who participate in:

of reports and records. the handling of data or test results and 3) the contro)

FPL accomplishes this by having personnel determined to be qualified and competent experie.sce. .-

by management through consideration of education, training, and t

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ANSI N4%2.8-1975 CLARIFICATIONS ANSI N45.2.8-1975, Paragraph 4.6 addresses care of items to the extent that temporary use of equipment or facilities to which the standard applies that are to become part of the completed project may be desirable.

The following clarification applies to the above statement. For FPL plants in the construction phase (to the point of plant operation license) temporary use of equipment and facilities may be used according to need and/or situation.

In this case, authorization for usage shall be provided along with all the j documemts,. conditions, aafeguards and evaluations to verify permanent plant i equipment adequacy.  ;

i In the operations phase all equipment, including temporary equipment, is subject to identical controls to preclude adverse effects on safety and suit-ability for use. l ANSI N45.2.8-1975, Paragraph 2.3, requires that Measuring and Test Equipment j (H&TE) used for inspection be identified on the Inspection Report. FDL may, j as an option, employ a M&TE issue log which provides traceability between i M&TE and the applicable inspections.  !

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! ANSI N45.2.9-1974 ALTERNATIVE ANSI N45.2.9-1974, Section 3.2.5 requires Quality Assurance records b e classified Section 2.2 of the Standard.as lifetime or non permanent and further defines li alternative to the above. FPL provides the following definitions as an Lifetime Records:

the NRC construction permit, applicable parts of 10 CFRRecords which are ,

commit.ments to be retained for the life of the plant.

, the FSAR, or other NRC Non-permanent Recorde:

license, the NRC construction permit, Records which are required by the NRC facility o applicable parts of 10 CFR, the FSAR, or other NRC commitments to be retained for periods of time less than the lif e of the plant.

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KISI N45.2.10 - 1973 id:ntifiss t2rms and thvir d2finitions i.aportant to tha uniform understanding of tha intrnt of rtquirrd quality assuranca practices for tha construc-tion of nuclear power plants. Regulatory Guide 1.74 (2-74) endcrses these terms and definitions and extends them through the operational phase and includes a clarification of procurement documents.

FPL has developed a glossary of terms and their definitions as part of the Quality Assurance Manual which is being used throughout its nuclear construction and operating plant activities. .

The following definitions are currently listed in our glossary and are alternatives or clarifications to those listed in the ANSI Standard and Regulatory Guide:

Assembly A com'bination of subassemblies or components or both, fitted together to form a workable unit.

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Audit A documented activity performed in accordance with written procedures or checklists to verify, by examina-tion and evaluation of objective evidence, that applicable

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elements of the quality assurance program have been developed, documented and effectively implemented

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in accordance with specified requirements. An audit does not include surveillance or inspection for the

purpose of process control or product acceptance.

Guidelines Particular provisions which are considered good practice but which are not mandatory in programs intended to comply with Standards. The term "should" denotes a guideline; the term "sha11" denotes a requirement; and the word "may" denotes permission, neither a requirement nor a recommendation.

Inspector (Owner 's or Installer's) A qualified in'spector employed by the Owner or Installer, whose duties include the verification of quality related

' activities on installations.

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, the c:nformanca cf mat riels, cupplics, compon:nt',

, 'part2, Eppurt:nancan, ayatema, procisses, er structures to predetermined requirements.

Procurement Documents, Contractually binding documents, including such documents as contracts, letters of intent, work orders, purchase orders or' proposals and their ac'ceptances which authorize tfiesellertoperformservicesorsupplyequipment, material, or facilities on behalf of the purchaser.

Qualification *

(Personnel) The characteristics or abilities gained through training or experience or both as measured against established requirements such as standards or tests tilat qualify an individual to perform a required function.

Quality Assurance

.All those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will' perform satisfactorily in service. Quality Assurance includes quality control.

Quality Control Those quality assurance actions related to the physical characteristics of a material, structure, component or system, which provide a means to control

, the quality of the material, structure, component or system to predetermined requirements.

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Stortga Thrt p2riod followJng tha ralessa of an ittm fcr shipment until turnover for start-up or preoperational testing. This would include in-place storage.

t System An kntegral part of a nuclear power plant comprised of electrical, electronic, or mechanical components (or combinations thereof) that may be operated as a

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separate entity to perform a specific function.

Testing Performance of those steps necessary to determine that

. systems or components function in accordance with predeter-mined specifications.

Not in glossary:

Report Standard Transit Carrior l

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" Requirements" Clarification for Glossary REQUIREMENT: A mandatory action, denoted by the word shall.

(See " Guidelines") Requirements are generally based on statutes or regulations, but may be internally generated within the company.

"Shall" is therefore used for both external, legally enforceable actions and internal requirements not enforceable under current NRC practices.

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ANSI N45.2.13 - 1976 CLARIFICATIONS ANSI N45.2.13 - 1976 Section 1.3 provides a definition of " procurement document" which is different from the definition contained in ANSI N45.2.10 - 1973 and Regulatory Guide 1.74. Tha Floride Power & Light (FPL) Quality Assurance Program uses the definition of " procurement document" contained in ANSI N45.2.10 - 1973 as modified by Regulatory Guide 1.74.

NISI N45.2.13 - 1976 Section 3.3.a requires .that procurement documents be reviewed prior to release for bid and contract award. The FPL Quality Assurance Program requires procurement document revicws prior to bid and contract award for all safety-related purchases with the exception of these accomplished by " Confirming Purchase Order." A " Confirming Purchase Order" is an order which is initially placed verbally with the supplier and then later confirmed with a written Purchase Order. A " Confirming Purchase Order" is only used when time restraints would pro-hibit the normal review and approval cycle. The following controls are provided in the FPL Quality Assurance Manual to assure that the intent of ANSI M45.2.13 is satisfied for " Confirming Purchase Orders."

(1) Quality Assurance must be contacted prior to contacting the supplier to place the order unless it is an emergency purchase after normal working hours in which case Quality Assurance is contacted the next working day.

(2) Prior to verbally placing the order, it must be verified that the intended supplier is on the FPL Quality Assurance Approved Supplier List.

(3) The verbal'.y placed order must be promptly followed up (confirmed) with a written procurement document which is subject to all reviews and approvals required for sefety-related purchases.

ANSI N45. 2.13 - 1976 Section 1.1 states that the extent to which the individual requirements of this standard will apply will depend upon the nature and scope of the work to be performed and the required quality of the items or services pur-chased. For commercial grade items, FPL has determined that certain of the indi-vidual requirements of ANSI N45.2.13 need not apply. Commercial grade items are those (1) not subject to design or specification requirements that are unique to facilities or activities licensed by the NRC, and (2) used in applications other than facilities or activities licensed by the NRC, and (3) to be ordered from the manufacturer / supplier on the basis of specifications set forth in the manufacturer's published product description. These commercial items are subject to varying degrees of control as indicated in the FPL Quality Assurance Manual.

As a minimum, an evaluation is performed by qualified personnel to assure that the commercial item satisfies the necessary technical and quality requirements and the item is checked upon receipt to assure that the item received was the one ordered, damage was not sustained during shipment, and documentation if required was received.

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o PLANNING CLARIFICATION ANSI N45.2.4-1972, Paragraph 2.1; ANSI N45.2.6-1973, Paragraph 2.1; ANSI N45.2.13-1976, Paragraph 7.2; ANSI N18.7-1972, Paragraph 5.1.6.3;

' ANSI N45.2.8-1975, Paragraph 2.1 and Paragraph 2.2 include plans and/or planning as required.

The terms plan and/or planning are included in FPL's activities as indicated in the following clarification:

Planning is considered to be a management process or analytical tool used as an aid to help develop identification and/or development of program' requirements, implementation activities, assignments and staffing, inspections, surveillances and audits, controls and other activities to assure completeness of the reuqircraents. Planning, as such, is not always documented nor addressed as an end-item and is considered to be an integral " process" within the developed item.

Plans which are considered to be end type or output type documents have the term " plan" in the title, such as ISI Master Plan, Audit Plan, Startup Plan, and others, which as such will reflect directly the requirement of these standards in the appropriate documents.

Plans which are not considered to be end type or output type documents do not have the word plan in the title. However, certain procedures, instructions, flow charts, schedules and checklists may be considered to be plans - reflecting planned actions which especially require step-by-step accomplishments. In these cases, the term plan may not appear in the title but considered to be a plan only in the indirect sense and identified as a procedure or other document. FPL considers the above practice to be in compliance with the " plan" requirements of these standards.

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