ML20076D934
| ML20076D934 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 07/25/1991 |
| From: | Floyd S CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-91-121, NUDOCS 9107310109 | |
| Download: ML20076D934 (9) | |
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Carolina Power & Light Company Nuclear Senices Department
- 411 fayttinitie Street hf all ? P.O. Itos 1$51 1(alrigh, Norili Carolina 27M12 JUL 2 51991 SERIAL: NLS 91 121 i
10CFR50.54(a)(3) l i
IJnited States Nuclear Regula_ tory Commission A.TENTION: Document Control Desk Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PtANT, UNIT NOS.1 AND 2 DOCKET NOS. 50 325 AND 50 324/ LICENSE NOS. DPR 71 AND DPR 62 OUALITY ASSURANCE PROGRAM CilANGES Gentlemem f
Carolina Power & Light Company (CP&L) hereby requests approval for a change to thr Quality Assurance (OA) Program for the Brunswick Steam Electric Plant (IISEP), This request is submitted in accordance with 10CFR50.54(a)(3) and is detailed in Enclosure 1.
The proposed change reflects CP&L's intent to remove the' Corporate Quality Assurarce (COA) Departm:nt from in.line review and approval of processes related to the engineering documents. This proposed change reflects the adequacy of review processes being performed by the originating organizations, the elimination of redundant reviews, and focuses increased accountability on the organization performing the work to ach'. eve-the desired level of quality. The Nuclear Assessment Department will evaluate the overall performance of engine. ring activities on an ongoing basis.
The revised program will continue to provide assurance that review and approval of processes related to engineering documents would be satisfied. Thus, the USEP OA Program would continue to meet the applicable 10CFR50 Appendix B criteria. is being provided for your information only at this time. It describes related organizational changes that do not constitute a reduction in commitment to the QA Program. These changes have maintained an equivalent level of oversight / review to that currently described in the FSAR and, thus, have already been implemented.
These changes will be incorporated into the FSAR in accordance with the provisions of 10CFR50.71(c).
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l Document Control Desk (NIS91121) / Page 2 Should you have any questions regarding these changes, please contact Mr. Dale Dates at (919) 546-6154.
Yours very truly, YApt S. D. Flofd Manager Nuclear Licensing Section DilD/jbw (10980LU)
Enclosures ec:
Mr. S. D. Ebneter Mr. M. F. Jape (Region 11)
Mr. N. II. Le Mr.11. L Prevatte
I E N C I. O S U l( E 1 IlltUNSWICK STEAh! El.ECTitlC l'IANT QUAL.lTY ASSUl(ANCE l'ItOGRA51 CilANGE (10980LU)
OA PROGRAM CilANOli furrent Requirement The current FSAR (Section 9.5.1.3.5.g.1) requires Operations OA/OC in line review of modification packages to assure that post modification acceptance tests are specified. 'this review is redundant to procedurally required in line technical review within the originating engineering organization.
.Pwposed Change This proposed change deletes the redundant in line review by the OA staff. The originating engineering organization will continue to perform technical reviews in accordance with approved procedures.
.Benson for Change The change detailed in the transmittal reflects a removal of OA staff from in line review activities related to engineering modification documents. These documents receive separate reviews by qualified reviewers within the originating organization for technical and quality assurance program adherence and adequacy,in accordance with approved procedures. The OA in line reviews represent unnecessary redun-dancy and an undesirable dilution of responsibility for ensuring documet.t adequacy.
l JJigsis for Concludijjg "Ihat the Revised Program Incorporating the Change Continuego Satisfy 10CFR50 Aopendix 11 and the FSAR Ouality Prograin Technical reviews by qualified individuals will continue to verify the technical and quality assurance program adherence and adequacy of each new modification, in addition to the normal reviews and controls, the Nuclear Assessment Depart-ment will independently evaluate the overall performance of the engineering activities on an ongoing basis.
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13ased upon these considerations, the removal of the in line reviews by the OA l
Engineering Subunit will not result in any degradation of the review process.
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1 ENCL,OSURE 2 IIRUNSWICK STEAM EI,ECTRIC l'IANT FSAR l' AGE MARK UI'S (10980LU)
Operations QA/QC performs surveillances to assure that necessary test / inspect ions /surveillances by t he Fire Protection group of fire protection systems, emergency breathing and auxiliary equipment, emergency lighting, and communication equipment are being performed as required.
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Operations QA/QC performs surveillances of documentation to assure that the necessary test / inspections /surveillances of fire stops, seals, and fire retardant coatings are being performed.
g)
Test and Test Control Md 6 #I
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Operafions-qk7QC asanIs thaV ceptance'[entsa5.e'specifiedin ]
plant' modi fidt ionsE or to the equipenibgiggated operable l
v Post-maintenance tests for repairs / replacements are reviewed by QA following work completion.
2)
Corporate Quality Assurance includes fire protection periodic tests in the periodic audits of plant Operations to assure that the test schedule is being met.
3)
Acceptance test results are included in plant modifications and post-maintenance test results are attached to Work Request &
Authorization Forms (trouble tickets) when it is determined that tests are required.
Operations QA/QC review both packages for completed documentation.
h)
Inspection, Test, and Operating Status - Operations QA/QC includes in their inspections the review of tags, labels, or other temporary markings used to indicate completion of required inspections and tests, and operating status to assure compliance with procedures.
i)
Nonconforming Items - The requirements specified in the Corporate Quality Assurance Manual for nonconforming items are met for fire protection equipment.
j)
Corrective Action - Operations QA/QC assures that procedures are written to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible material, and nonconformances are promptly identified, reported, and corrected.
k)
Recotds - Those. records required to verify compliance with criteria of the Fire Protection Program are identifiable and retrievable and are assigned retention requirements.
1)
Audits - Audits are perf ormed by the Corporate Qualit y assurance Audit Section.
9.5.1.3.6 Training Training is an essential ingredient in developing and maintaining m effective fire protection program.
Depending on job responsibilitica, the intenwiry of training may range from a short introduction to fire safety to weeks of extensive training.
Three distinct types of training are providedt 9.5.1-13 Amendment No. 5
d The requirements stated in Section 17.2.11 shall apply.
(10f8AGLU)
ENCLOSURE 3 IIRUNSWICK STEAM ELEci'RIC PIANT RElATED ORGANI7AT10N CilANGES 1
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JWlAEDlllLOANIZA110NALOIANG!jS_llijBiC[lYlijANUABY L12U DestatinnLQAM2C_UnitLLon Site)
'the QA subunit of the Operations OA/OC IJnit was deleted, with the surveillance functions of this subunit being assumed by the new Nuclear Assessment I)cpartment's Project Assessment Section (on site). 'lhese surveillance functions are described in 1 Salt Sections 9.5.1 and 17.2.
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The Corporate OA Auditing lJnit was deleted. with the 10CFl(50 Appendix 11 audit requirements being assumed by the Nuclear Assessment I)epartment's Nuclear Assess-ment Corporate Section. The audit functions are described in 1 Salt Sections 1.8,9.5.1, and 17.2.
(1D98GLU)
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