ML20091A873
| ML20091A873 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/23/1992 |
| From: | Rhodes F WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ET-92-0013, ET-92-13, NUDOCS 9203300238 | |
| Download: ML20091A873 (7) | |
Text
,
f I
W8LF CREEK
~
' NUCLEAR OPERATING CORPORATION Forrest T Rhodes
- w. er..ns.ni Engmeering & Technical Services March 23, 1992 ET 92 0013 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station Pl-137 Washington, D. C.
20555'
Subject:
Docket No. 50-482:
Operational Quality Assurance Program Changes Pursuant to 10 CFR 50.54(a)(3) 1 Gentlemen:
The purpose of this letter is to provide, for review and approval, a change to the Wol-f Creek Nuclear Operating Corporation's (WCNOC) Operational j
Quality Assurance Program.
The proposed change provides for the development j
of Configuration Change Packages (CCP).
CCPs will be used to control and i
simplify a portion of the drawing-change process.
Pursuant to - 10 CFR 50.54(a)(3),
this change has been evaluated by WCHOC and determined to reduce commitments made in the approved Quality Assurance Program.
- Houever, the evaluation also determined the change does not reduce the Quality Assurance Program and the Quality Assurance Program continues to satisfy the criteria e'
'opendix B of 10 CFR Patt 50.
Pursuant to 10 CFR 50.54(a)(3),
a copy of the proposed change to Chapter 17 of the Updated Safety Analysis Report is attached for review (Attachment 1). !s an explanation and_ justification for the proposed change.
If you have any_ questions conceraing this matter, please contact me or Mr S. G. Wideman of my staff.
Very truly yours,
.A)/
j'/;s -
./'
//
{
Forrest T. Rhodes neo Vice President-
$o' Engineering & Technical Services OO r4 D O' o FTR/nem co x no cc:
A. T. Howell (NRC),_w/a-
$O R. D. Martin (NRC), w/a G. A. Pick (NRC), w/a W. D. Reckley (NRC), w/a-O' Q. Q.
<7 m q p, t O P.O. Box 411/ Burlington, KS 66839, Phone: (316) 364-8831 1 j
~'*
An Equal opporturvty Empoyer MMCVET -
.ad_
l l
. to ET 92-0013
- Page 1 of 5 WOLF CREEK Procedures identify the respansibilities of the verifier, the 4
features to be verified the pertinent considerations to be verified, and the documentation required.
Special reviews are performed when uniqueness or special design considerations warrant.
Design analyses are sufficiently detailed as to purpose, method, j
assumptions, design requirements, references and units to permit an independent review by a technically qualified person.
Computer codes are verified to be certified for use, and it is verified that their intended purpose is specified.
Additionally, the operating Agent performs reviews of selected design documents for sub-contracted design to become familiar with design features.
Actions are initiated to resolve errors found in the design process and to assure that changes are controlled.
Such actions i
are documented.
17.2.3.7 Desion/Confiouration Chancea l
Changes to plant design may be necessary to correct operational deficiencies, incorporate improvements, or to comply with new regulatory requirements.
[seeign changcs arc dcfined to mcan 1) p-lenad changc s in the basic plant design which modify the plant rcaponsc, gancral acsign criteria, and spccification requircmcats,
- 2) the substitution of c3uivalent hardwarc or thc substitution of nonsafety-r+1ated-tm ts or compares into safcty-rclatcd componcnts or systems; and 2) cey-aoncditorial changc to a dcsign document.
Changes in thc "CCC casic dcsign arc aincd at improving safety, performancc, maintainability, rcliability, or inspcctabiliti.
An cnginccring cvaluation assurcs that thcsc changes arc consistent with the pcrformance rcquircmcats spccificd p
in cxisting~deetgn documcats.
Ocsign changes arc revicwed-by cognituut organizations through thc riant Modification ncquest proccsu.]
Design changes are defined as changes to the design bases or the design function of a component or system.
(Example:
1.
Planned changes in the basic plant design which modify the plant response and general design criteria.
2.
The substitution of non-safety related parts or components into safety related components or systems except those parts or components that have been downgraded by parts classification program.)
Design changes are reviewed by cognizant organizations through the Plant Modification Request process.
Configuration changes are defined as changes to design documentation that do not affect the design bases nor the design function of a component or system.
(Examples:
1.
The substitution of egnivalent hardware into safety related components or systems; 2.
Any change to design documentation [ editorial or non-editorial) or hardware that does not modify plant response, general design criteria nor specification requirements.)
Configuration changes are reviewed by cognizant organizations through the Configuration Change Package process.
An engineering l
l evaluation assures that these changes are consistent with the l
l performance requirements specified in existing design documents.
w
. to ET 92-0013 l
- Pag <i 2 of 5 WOLF CREEK 4
Procedures specify requirements for the review and approval of design / configuration changes by the organizations that performed l
the original dr.ofgn, if appropriate.
Design activitics may be delegated to others provided they have access to background and technical information.
Design / configuration changes are l
communicated to appropriate plant personnel when such changes may affect the performance of their duties.
Temporary Modificutions, interim and short-term changes to the approved station design, are controlled in accordance with approved procedures.
17.2.3.8 Design Review Commitiesf'1 Independent of the responsibilities of.the design organi?.ation, the requirements of the Plant Safety Review Committee (PSRC) and the Nuclear Safety Review Committee (NSRC) are satisfied.
[Besign chaLgee.ehich invelve a edi&atien er a crsetten-ef haeic d eign criterie require a safety evaluatica and reviewr-and concurrence by-the 20nC. --Dodga-changes which invelvs the eahatitution of hardweze require e safety evals.atien by the 20nC and appresal hy the riant Manager, he.;ever, these changes which invelve-en unreviewed eafety questaen w. change in % whnical Cpecificatiene eles require a review and cencurrence hy the NORC.-] Proposed design /configurstion changes are screened to determine if safety ovauations are required.
Design / configuration changes which could involve an urreviewed safety question require a safety evaluation, and rev.iew and concurrence by the PSRC.
Those changes which invo'.ve an unreviewed safety question or change in Technical 3pecifications also require a review and concurrence by the NSRC.
When design is performed by an outside or3anization, Engineering and Technical Services performs or coordinates a review for operability, maintainability, inspectability, SAR commitment compatability, and design requirements imposed by plant equipment.
In adc'.ition, Engineering and Technical Services identifies and controls design interfaces and coordinates the design process between internal divisions and the outside organization (s).
When required, safety analyses which consider the effect of the design as described in the design documents may be performed by the Operating Agent.
These analyses provide the basis for the l
PSRC safety evaluations which are performed to determine that l
design changes do not involve an unreviewed safety question.
l Approved safety analyses or names of outside organizations performing the analyses are submitted to the PSRC.
The safety analyses for design changes involving the substitution of hardware assure that t!~ changes are consistent with and do not alter the performance requirements specified in existing design documents.
The engineering approval of design documents and safety analyses prepared by outside organizations is by the outside organization unless otherwise specified.
. to ET 92-0013 Page 3 of 5 WOLF CREEK 4
The PSRC performs safety evaluations and reviews design changes to determine whether or not they involve a change in Technical Specifications.
The PSRC reviews design documents as necessary to recommend final approval of design criteria, identify unreviewed safety questions, or identify needed changes to Technical Specifications.
Proposed changes to Technical Specificati.. s are forwarded to the NSRC for review and approval prior to submlutal to the NRC pursuant to 10 CFR 50.
The NSRC reviews appropriate material to verify that proposed modifications do not in fact involve an unreviewed safety question.
Design changes and test procedures are reviewed by the PSRC prior to implementation.
Records are maintained which reflect current design, including safety analyses, safety evaluations, design change installation procedures, material identification documents, procurement documents, special process documents, equipment and installation specifications, and as-built drawings.
l l
l l
L
Attachment i to ET 92-0013 Page 4 of 5 MOLP CREEK
)
procedural requirements which impact the quality of an item.
Nonconforming activities which have not re3ulted in hardware nonconformances (i.e.,
programatic or procedural deficiencies which do not impact the quality of an item), are corrected in accordance with Chapter 17.2.16, Corrective Action.
17.2.15.2 Hanconformance controls Nonconformances identified under the Ope:ating Agent's Operating Quality Program are identified, documented, controlled, dispositioned and corrected in accordance with approvef procedures.
These measures provide for the notification of affected parties and controls to prevent the inadvertent use of nonconforming items.
Nonconformances are controlled by report documentation, tagging, marking, logging, or physical segregation.
Nonconformances are documented on records which identify the nonconforming condition, record the disposition, and register the signature of an appropriate approval authority.
Nonconformances are reworked, rejected, repaired, or accepted.
Repaired and reworked items are reinspected / tested in accordance with applicable procedures to ensure that critical attributes possibly affected by the nonconforming condition remain acceptable.
These procedures are based on original inspection and test requirements or approved alternatives.
Reinspection results and operation 01. data, gathered subsequent to repair or rework, are documented or referenced on nonconformance, test or inspection documentation.
o b
Configuration Change Packages (CCPs) and Plant Modification l
Requests (PMRs) are used in the Nonconformance Program to carry out dispositions of "use-as-is" or " repair.
[The EMn pzccese]These two processes ensures that all aspects of plant operation are considered in light of the fact that the.
dispositioned item is now not exactly per original design.
These considerations in:lude revision of applicable drawings, possible revisions to operation, test, *aintenance and inspection procedures; training of affected personnel, changes to spare parts inventory; unreviewed safety questions; and review of licensing documents.
Measures have been established to control the conditional release of nonconformances for which correction is pending and a technical evaluation indicates that installation and/or testing will not adversely affect nor preclude identification and correction of the nonconformance.
A conditional release to proceed installation and/or with testing of a system or subsystem with outstanding nonconformances considers the nature of the nonconfermance, its effect on installation and/or testing and the need for supplemental tests or inspecticns after correction of the nonconformance.
Conditional release evaluations are documented.
Safety-related and special scope conditional releases are l
. to ET 92-0013 Page 5 of 5 WOLF CREEK reviewed and approved by the Operating Agent's Quality Department prior to implementation.
Nonconforming items required for Technical Specification Operability are only released for use through the completion of a Configuration Change Pachage (CCP) or a Plant Modification Request (PMR) and, thus, cannot be conditionally released for operations.
17.2.15.3 Reporting Methods Nonconformance Reports, Work Requests, and Deficient Document Notices are employed to document nonconformances.
Nonconformance Reports are used to document nonconforming materials, parts, or components under warehouse control.
Work Requests may be used to document nonconforming conditions identified after issue from the warehouse.
Nonconformance Reports and Work Requests requiring "Use-As-Is" or
" Repair" dispositions are reviewed and-dispositioned by the responsible design authority.
Deficient Document Notices are used to document minor documentation-related nonconformances which are identified at time of receipt inspection.
Documentation discrepancies identified after receipt inspection that render the quality of hardware indeterminate are documented using an NCR.
17.2.15.4 Disoosition Procedures prescribe the individuals or groups assigned the responsibility and authority to approve the disposition of nonconformances.
Nonconformance disposition categories are:
1.
" Reject" - the process by which a nonconforming item is rejected for use and either scrapped, returned to vendor, or downgraded to allow for use in a Non-Q Frstem.
2.
" Rework" - the process by which a nonconforming item is made to conform to a prior t:pecified requirement by completion, remachining, reassembling or other corrective means, i
1 i
' to ET 92 0013 Justification For Proposed Change The change involves the development of Configuratioa Change Packages (CCP) and their inclusica into the design change process.
This program change will be implemented to make the drawing change process more efficient by simplifying the review process. CCPs will be a form of design change.
They will not be used to changa design basis or design functions.
They will
- however, be used to change design information such as e uivalent hardware substitution or editorial and non-editorial changes that do not modify plant
- response, general des!ga criteria or specification requirements.
Configuration changes will be reviewed by cognizant organizations.
They will not receive the same level of review as design changes.
This modification of review responribilities has been determined to be a decrease in commito=nts made to WCNOC's approved Quality Program.
This program change continues to meet the criteria of 10 CFR 50 Appendix B.
- III,
" Design Control",
because the cognizant organization will review the change prior to issuance to ensure the design bases / function of the system or component is maintained.
If this review determinen that the design / function has been affected, the change will be proces3ed as a Plant Modification-Request, revised so ar not to affect the design / function, or cancelled.
The Plant Modification Request Program is part of the approved Quality Assurance Program, e
4
-