ML20003B872
| ML20003B872 | |
| Person / Time | |
|---|---|
| Issue date: | 02/04/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Robert E. Uhrig FLORIDA POWER & LIGHT CO. |
| References | |
| NUDOCS 8102260030 | |
| Download: ML20003B872 (4) | |
Text
-.- -
_ _ =
[....
h
'o, UNITED sT ATEs y
',g NUCLEAR HEGULATORY COMMISSION r,
j C WASmNGT ON, D. C. 20555 FEB 0 41981
. Mr. Robert E. Uhrig l
Vice President, Advanced.
Systems & Technology Florida Power & Light Company P.O. Box 529100 i
Miami, FL 33152 t' ear Mr. Uhrig:
SUBJECT:
OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (FPLTQAR l-76A) l i
We have evaluated Revision 3 to FP&L Topical Report FPLTQAR l-76A, " Topical j
i Quality Assurance Report," submitted with your December 17, 1980 letter to deter-mine its conformance with Appendix B to 10 CFR Part 50. The basis for our review was the SRP (NUREG-75/087, Rev.1) dated February 1979. In addition, we reviewed the alternatives / clarifications (ref. Appendix contained in Uhrig/Haass letter
- dated Septemebr 26,1980) to Regulatory Guides and ANSI Standards.
A request for additional.information relative to these documents is enclosed Your response to the enclosure should be submitted as an amendment (25 copies of affected page changes) to the original report by April 1,1981.
Should you have any questions or if you desire a meeting regarding our review, please feel free to contact Mr. James Conway on (301) 492-7741.
j Sincerely.
l' t,l s
we alter P. Haass, C ief Quality Assurance Branch Division of Engineering
Enclosure:
- Request for Additional Information.
k)),3 x.7 e
s d e b,3 g
FED 0 51981 M::'i
' O " % :l ll: : " '[
N 'W 8102200030 C_.;
FLORIDA POWER & LIGHT COMPANY (FPLTQAR l-76A, Revision 3)
Request for Additional Information 1.
Update TQR 1.0, " Organization," to be consistent with the organizational change noted in the Uhrig/Haass letter dated October 3,1980.
2.
The applicable figures in Appendix A should be revised to reflect FP&L's recent organizational change.
3.
Clarify the discrepancy between Figures 1-4 and 1-5 which show the QA/QC Coordi-nator reporting directly to the Manager of Environmental Tech Services and the Director of Licensing and Environmental Planning, respectively.
4.
Clarify the discrepancy between Figure 1-9 which does not show the Manager of Inventory Systems and Control and Figure 1-1 which shows this individual reporting to the Director of Purchasing and Inventory Resources.
5.
Describe the responsibilities of the Project QA Engineer (Figure 1-3) and the QA/QC coordinators (Figures 1-3, -4,
-6, and -9).
6.
Identify the position that is responsible for managing the onsite QA program.
7.
The qualification requirements in Appendix B for the Director of Quality Assurance are not satisfactory.
It is an NRC staff position that the qualifications and experience of the Director of Quality Assurance or Manager of Quality Assurance (Ref. Uhrig/Haass letter dated October 3,1980)'be at least equivalent to those described in Section 4.4.5 of ANSI /ANS 3.1-1978, " Selection and Training of Nuclear Power Plant Personnel."
In lieu of the above, we would accept a commitment to the education and experience described in the following Section 4.4.5 of ANS 3.1-1979:
EDUCATION:
Bachelor Degree in Engineering or related science.
EXPERIENCE:
Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experi-ence in a supervisory position preferably at an operating nuclear plant or a combination of the two. At least one (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program.
Six (6) months of the one year experience shall be obtained within a l
quality assurance organization.
Provide a description to satisfy this position.
8.
In Appendix C, a commitment is made to " follow the guidance" in WASH 1283, 1284, and 1309. : The '.ainbow series of quality assurance guidance, of which these docu-ments.are a part, was generated in 1973 and 1974. They contain a large number of NRC regulations, regulatory guides, and industry standards, some in draft form.
Although these documents reflected the best available body of guidance at that time, many of the components of the raihbow books have been superseded by later versions, and additional pertinent guidance has been developed through the ANSI consensus standards process.
Consequently, quality assurance program descriptions
i t.
, should reflect the degree of conformance to current regulatory and industry guidance; we will no longer accept descriptions that are keyed to conformance to the rainbow books.
Accordingly, FP&L's QA program description should be updated to reflect conform-ance with the regulatory positions provided by the f4RC in the following regula-tory guides for future operational activities including maintenance and modifi-cation:
1.8-Rev. 1-R (5/77); l.26-Rev. 3 (2/76); 1.29-Rev. 3 (9/78); 1.30 (8/11/72); 1.33-Rev. 2 (2/78); 1.37 (3/16/73); 1.38-Rev. 2 (5/77); 1.39-Rev. 2 (9/77); 1.58-Rev.1 (9/80); 1.64-Rev. 2 (6/76); 1.74 (2/74); 1.88-Rev. 2 (10/76);
1.94-Rev.1 (4/76); 1.116-Rev. 0-R (5/77); 1.123-Rev.1 (7/77); 1.144 (1/79);
and 1.146 (8/80).
Appendix C should be modified to address this position.
To preclude any mis-interpretation regarding the commitment statement, it is recommended that the following or a similar statement be used:
"The FP&L Quality Assurance Program complies with the Regulatory Position of the Regulatory Guides referenced in this appendix as modified by the exceptions stated on the following pages of this appendix."
9.
Identify those personnel authorized to approve changes to the "Q-list" (i.e.,
safety-related items covered by the QA program) and describe methods for con-trolling its distribution.
10.
Provide a commitment that the development, control, and use of computer code pro-grams will be conducted in accordance with the QA program and include a descrip-tion of how the QA program will be applied.
11.
Describe the guidelines or criteria for determining the method of design verifi-cation (design review, alternate calculations, or test).
12.
If the verification method is only by test, prototype, component, or feature test-ing should be performed as early as possible prior to installation of plant equip-ment, or prior to the point when the installation would become irreversible. Modify Section 3.2.4 to address this position.
13.
Procedures should be established to assure that verified computer codes are certi-fled and specified for a particular use. Modify TRQ 3.0 to address this position.
14.
Describe the organizational responsibilities, including the involvement of the QA organization, for (1) procurement planning; (2) the preparation, review, approval and control of procurement documents; (3) supplier selection; (4) bid evaluations; and (5) review and concurrence of supplier QA programs prior to initiation of activities affected by the program.
15.
Describe the provisions which assure that maintenance, modification, and inspec-tion procedures are reviewed by qualified personnel knowledgeable in QA disciplines (normally the QA organization) to determine:
a.
The need for inspection, identification of inspection personnel, and docu-mentation of inspection results.
b.
That the necessary inspection requirements, methods, and acceptance criteria have been identified.
4
. 16.
Describe the provisions which assure that suppliers' certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid.
17.
Describe the criteria for determining those processes that are controlled as special processes.
18.
Describe the provisions which assure that when inspections associated with nor-mal operations of the plant (such as routine maintenance, surveillance, and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls are met:
a.
The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item.
b.
The qualification criteria for inspection personnel are reviewed and 3
found acceptable by the QA organization prior to initiating the inspec-tion.
19.
Describe the provisions which assure that inspection results are documented, evaluated, and their acceptability determined by a responsible individual or group.
20.
Describe the organizational responsibilities, for establishing, implementing, and assuring effectiveness of the calibration progran.
21.
Describe the rovisions for the storage of chemicals, reagents (including control of shelf life, lubricants, and other consumable materials.
The following questions pertain to the Appendix attached with the Uhrig/Haass letter dated September 26, 1980, 22.
Page 5, third paragraph - Describe the criteria FP&L uses to determine the de-gree of " care... appropriate for each item individually...."
23.
Page 6 last sentence - After " established" add "with approved procedures."
- 24. ~ Page 8 - This alternative is not required with a commitment to Regulatory Guide 1.58-Rev. I which endorses the 1978 v:rsion of ANSI N45.2.6.
25Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>25" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Page 15, third paragraph - Describe the " degree of control" imposed upon com-mercial items.
4
- - - - - -.