ML20094H402

Forwards Proposed FSAR Change to Remove Requirement for in-line,independent Review of Operations Notification & Evaluation Forms (Nonconformance Documents),Per Sser 22 (NUREG-0797)

ML20094H402
Person / Time
Site:	Comanche Peak
Issue date:	03/03/1992
From:	William Cahill, Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0797, RTR-NUREG-797 TXX-92064, NUDOCS 9203100163
Download: ML20094H402 (10)

Text

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Log # TX7-920f,4 Tile # 10010

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937 3 3 Ref. # 10CrR50.54(a)(3)

, TilELECTRIC Harch 3, 1992 Wilham J. CahHl. Jr.

nom no en,,b.o V. L lluclear Regulatory Commissior.

• Attn: Docume.it Control Desk.

dashingt on D.C. 20555 SUDJECT: COMAhCHE PEAK STEAM ELECTRIC STATION (CiSES) - UNIT 1 DOCKET NO. 50 445 PROPOSED FSAR CHANGE QUALITY ASSURAllCE (OA) ?ROGRAM CHANGL

• EllHINATION Of INLINE REVIEW of fiONCONf 0RHAf1CES BY NUCLEAR OVERVIEW REF: WUREG 0797, *Safet) Evaluatien Report." Supplem nt 22 (SSER 22)

Gentlemen:

Attached is a proposed FSAR change which remove', the requirement for an inline, independent reciew of Operations Notification and Evaluation (ONC) forms, the Unit I nonconformance documents. The independent review of ONE forms, wPich is performed by the Nuclear Overview Department (N00), has been determined to be redundar t of a review performed by the responsible line nanager. The CPSES OA Program, as revised by this change, will continue to satisfy the criteria of 10 CFR 50 Appendix B, This change only applies to the ONE form program in Unit 1 and does not affect the review of Unit 2 nonconformance documents.

This FSAR change is being submitted as a proposed change because TV Electric has determined that-this change is a reduction in commitment of the OA program description previously approved by the NRC in the referenced SSER. As such,

'hls change must receive NRC approval prior to implementation in ac;ordance 10 CFR 50.54(a)(3).

Currently, independent reviews of the disposition and closure cf OllE Forms are performed by NOD as an inline function of the nonconformance control process.

These reviews are performed at the closure of the ONE form to indeoendently deterndne whether the condition has been appropriately 1ddressed and all actions have been completed. In addition to review by N00, the disposition and closure review is also performed by the manager who is responsible f or the hardware or procadures against which the ONE form is issued. The revieu by the respon$1ble manager is performe<1 prior the review ty flop.

Elimination of the review by N0D will not reduce the level of quality of structures, systems and cc,mponents. An evaluation of the results of the

-closure revie's process has concluded that the ONE Form process, and control *,

adminijtered by the cognizant marager, have been effective in appropriately j

.9203100163 PDR I' ADOCK 06000445 090123 920303 N N' 8" 'D 83 N""J"u n20:

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In-90064 Page 2 of P correcting ideetified nonconformances. In additico, Technical Specification required audits of the nonconf ot mance anri corrective action programs have verified the effectiveness of the nonconformance control activities as recommended and implemented by the cognizant niananers. These resultt confirm t hat t h a line managers cro ensuring that Otil forms are arpropriately dispositioned and closed without the additions) inline review t,/ 1100.

Elimination of the inline review by NJD will not change the monitoring and oversight functions currently performed by NOD. fl0D will continue t o monit or the nonconformance proccss through the review of root cadse analysis results, audit deficiencies, prework review of work orders, design modification reviews, trending, audite and surveillances.

10 fccilitate NRC Staff review of these changes, the attachment is organized as follows:

. A trarked up copy of the revised it,AR page:S (additional pages immediately preceding and/or f ollowing t he r( vised pages ar e provided if needed tu understand the change).

2. A description / justification of each item involved.

3. A copy of related SSER sections.

A 10CIR50.r,9 evaluation was perf ormed f or the above change. The evaluation revealed that no unreviewed safety question is created as a result of the deletion of th'.s review. This change will be included in a future amendment to the FSAR.

If you have any questions regarding this submittal, please contact David Bize at (Eld) 81? 8879.

Sincerely,

• William il. Cahill dr.

s,. a. . t.w D. R. Woodlan '

Docket 1.icensing Manager Attachment DNB/dnb c Mr. R. D. Martin. Region IV Mr. 1. Barnes, Pegion IV Resident inspectors , 'f SE% t c >

Mr- T, A. Bergman ( f4RR )

Mr. M. B. Fields (NRR) s

Attachment to TXX 92064 Page 1 of 8 ATTACHHENT 10 TXX 92064

1. Marked up copy of revised FSAR pages pnges 2 and 3

2. Description / justification page 4

3. Related SSUt sections pages 5 through 8

Attachnant to TxX-92064 i h rf 2 of " CPM'$USM 4

16. e. Preparation of nonconformance documents which identify nonconforming items and describe the nonconformance, the disposition of the nonconformance, and the reinspection or testing performed to determine the acceptability of the item after the disposition has been completed.

76 I I, . R9 view of nonconformance documents written on installed plant 77 equipment to determine impact on operability. The administrative controls assure that nonconforming materials do not affect the opersbility of safety related equipment in violation of Technical Specification requirements.

l 77 $. Cunditional releases allow issuance of nonconforming items from the warehouse f or initial in';tallation and testing.

Conditional releases also allow operation of the item pending disposition of the nonconformance provided credit is not taken for Techncial Specification operability of the item. Each conditional relense also describes any limitations or special precautions required. Conditional releases are periodically evaluated as to their status and the results forwarded to management for their review.

6. Verification of the acceptability of rework / repair of items by reinspection or testing of the item as originally performed or by a method which is equivalent tt the original inspection and testing method.

7. Noacanformance reports which are dispositioned "use as is" or

" repair" are made part of the quality verification records associated with the items.

8. Periodic analysis of these reports to be performed and forwarded to tannagement h,toJ ow y al,ity trends. y ' "

0421.72 f 'A Snd N ~~~ W _f.oUtan and 'Y rva:D , .~.-

77 Responsibility for the implementation of activities related to nonconformance controitis assigned to the cognizant maneger of the area of concern. Nonconformances which are resolved by repair or k@ @

use as is dispositions are reviewed and approved by Engineering.

Amendment 77 17.2 34 l

';sptember 8, 1989

c t ta Txx-9 mc4

, CPS M SAR vor

. Ad scabon o f <( t h 4t[** fidulf< b NM m bo%t a y

• Independent review +f-nonconfomances>r-including--disposition-4ndl 81 com 4. d c c -closeout ris performed by appropriate Nuclear Overview personnel.

0421.7*

Marking and segregatior. of nonconforming items, when required, are 77 addressed in station procedures. Compliance with these administrative requirements is verified through the station 53 surveillance and audit program.

17.2.16 CORRECTIVE ACTION Requirements are established for the identification and correction of 71 conditions adverse to quality. These requirements are consistent with the provisions of Regulatory Guide 1.33 as discussed in Appendix 37 1A(B).

Conditions adverse to quality, such as failures, malfunctions, 71 deficiencies and deviations, identified through review of documents, surveillance, audits, or experience during operation, are documented and dispositioned. Significant conditions adverse to quality are evaluated to determine the cause of the condition and the corrective action to be taken to preclude recurrence.

Reports of significant conditions adverse to quality are reviewed by the 0paratlon Review Committee and that comittee's decisions and/or recomendations regarding coriective action are forwarded to appropriate management persunnel. Follow-up reviews to verify proper 81 implementation of corre:tive action are conducted by Nuclear Overview personnel.

17.2.17 QUAllTY ASSURANCE RECORDS Requirements are established for the identification, collection, and 71 storage of quality assurance records. These requiremente are 17.2-35 AMENOMENT 81 MAFICH 16,1991

CPSES IJ6R AHfNDMEN7 85 Attachment to TXX-92064 DETAILED DESCRIPTION Page 1 Page 4 of 8 f56R Page (As amended) Stopp Drittivt190

-17,2 34, 35 2 Remove tuline Review of Nonconformance Reports by Nuclear Overview Department Revision:

Currently, independent inline review of nonconformances is performed by the Nuclear Overview group. inis re- ,

view is performed at the closure of the nonconformance document to independently determine whether the docu-mentation reflects completion of the corective action ,

and that the form is properly completed. This is not a technical review and is redundant of actions performed by the Manager in whose area of responsibility the ,

nonconformance was identified. Ar. evaluation of the closure review process has concluded that the noncon*

formanco process and adminsitrative controls, adminis-tered by the. cognizant manager, have been effer.tive in appropriately correcting and documenting identified nonconf orinances .

FSAR Change Request Number: 91 191.01 SER/SSER impact: No t

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tachment t o TXX-920M 3 Page 5 of C 17 QUAlllY A5bURANCE 17.1 General The quality assurance (QA) program tor the operations phase of Comanche Peak St(am Electric Station (CPSES), Units 1 and 2 is described in Section 17.2 of the final Safety Analysis Report (F$AR). The staff based its evaluation of this OA program on a detailed review of this information through F5AR Amend-ment 77 and an advance FSAR amendment provided by a letter dated Decerrber 19, 1989 ing. which will be included in Amendment 78 to be issued before Unit 1 fue' load-The staff assessed the applicant's OA program for the operations phase to determine if it complies with the requirements of litle 10 of the Code of Fed-eral Regulations (CFR) Part 50, Appendix B, " Quality Assursnce Criteria for Nuclear Power Plants and fuel Deprocessing Plants"; with the regulatory guides and the American National Standards Institute (ANSI) standard listed in Table 17.1 of this supplement; and with the Standard Review Plan (SRP) (NUREG-0800)

Section 17.2, Revision 1, " Quality Assurance During the Operations Phase." The evaluation in this section and those that follow replaces the corresponding sections in the Safety Evaluation Report (SER) and its supplements, including the referenced table and figure, as well as prior evaluations included under Section 17.5, " List of Systers, Structures, and Components Under Control of the QA Program."

17.2 OrganizationfortheQAlrogram The structure of the organization responsible for the operation of CPSES and for the establishment and execution of the operations phase QA program is shosn in Figure 13.1 of this supplement.

The Executive Vice President-Nuclear Engineering and Operations (NEO), is responsible for the overall management and operation of CPSES, including the establishment of company nuclear policies. He also has overall responsioility for establishing and executing the CPSES QA program for operations. He has assigned to the Vice President-Nuclear Operations the overall responsibility fnr operating CPSES and for implementing the QA program for operations at CPSES.

The Vice President-Nuclear Operations is responsible to the Executive Vice President-PF.0 for cforating activities at CPSES. Duties and responsibilities of the Vice President-Nuclear Operations include technical and administrative direction of the Plant Manager, the Manager-Startup, the Manager of Nuclear Operations Support, the Plant Evaluation Manager, the Manager-Projects, the Manager-Nuclear Training, and the technical and administrative direction for implementing QA controls at nuclear plants operated by the applicant.

The Dire'. tor, QA, reoorts directly to the Vice President-Nuclecr Engineering, and is responsible to him for ensuring effective implementation of the QA pro-gram. This reporting relationship ensures that the Director, QA, has sufficient authority, organization freedom, and independence from undue influence of, or responsibility for, costs and schedules to effectively ensure implementation of and compliance with the CPSES operations QA requirements and controls.

Comanc a !ak SSER 22 17*1

At t arbnien t to TXX-92064 P a p,e 6 of 8 The Director, QA, communicates directly with NE0 supervisory and management personnel and with appropriate management levels in consultant and contractor QA organizations to identify quality problems; initiate, recommend, or provide solutions; and to verify implementation of solutions to quality problems. He has authority to "stop work" during the operations phase. Specific outies and responsibilities of the Director, QA, include the direction of QA Department personnel; technical and administrative direction of the Deputy Director of QA, the Manager, Quality Control (QC), and the Manager, QA; verification that procedures for the control of quality related activities comply with QA require-ments; verification of the implementation of the QA program within NE0; verifi-cation that consultants, contractors, and suppliers proviJing quality-related items or services have established and implemented an adequate QA program; and membership or representation on the Operations Review Coinmittee.

The Deputy Director, QA is responsible for the day-to-day management and operations of the QA Department. The QA Department functions to ensure effec-tive implementation of the QA program. The QA Departinent performs internal and external audits, surveillar.ces, and inspections. The audits, surveillances, and inspettions are performed by qual 1 fled individual 5 other than those who performed or directly supervised the work. Personnel report directly to the Manager, QC when acting in the capacity of QC inspectors.

17.3 Quality Assurance Program _

The QA program for the operation of CPSES is presented in the QA Manual, which establishes the QA policies, requirements, and controls to be implemented at CPSES. The QA Manual establishes the quality requirenients and controls to be implemented during station operations and defines the responsibilities, author-ities, and measures for the control and accomplishment of activities affecting the quality and operation of safety-related structures, systems, and components.

The Executive Vice President-NE0, is responsible fur approving the QA Manual.

On the basis of its review, the staff concludes that the CPSES QA Manual and Section 17.2 of the CPSES FSAR are structured in accordance with Appendix B to 10 ;FR Part 50 and with the provisions of the Nuclear Regulatory Cnmmission (NRC) regulatory guides and the ANSI standards shown in Table 17.1. These documents describe how the requirements of Appendix B to 10 CFR Part 50 are satisfied.

6 These documents control quality-related activities involving safety-related items to satisfy the requirements of Appendix B to 10 CFR Part 50.

The QA program requires that QA documents encompass detailed controls for (1) translating codes, standards, and regulatory requirements into specifications, procedures, and instructions (2) developing, reviewing, and approving procurement documents, including changes (3) prescribing all quality-affecting activities by documented instructions, procedures, or drawings (4) issuing and distributing approved documents Comanche Peak SSER 22 17-?

Attachment to TXX 92064 l'a ge T'of 8 4 .

Table-17.1 Regulatory guidance applicable to the QA prograr Document Revision Date Regulatoly Guide i

1.8* 1-R 5/77

-1.26' 3 2/76 1.29 2 1.30 2/76 0 8/72 1.33 2 1.37 2/78 0 3/73 1.38* 1 10/76 1.39 2 9/77 1.58 1,64 1 9/80 2 6/76 1.74 0 1.88* 2/74 2 10/76 1.04 1 4/76 1.116 0-R 5/77 1.123-1.146

-1 7/77 0 8/80 ANS! Standard N45.2.12* 2 (Draft 4) 1/76

• With comments acceptable to the NRC.

(5) purchasing items and services (6) identifying materials, parts, and compuneni.s (7) performing special processes (8) inspecting and testing material, equipment, processes, and services (9) calibrating and maintaining measuring and test equipment (10) handling, storing, and shipping items (11) identifying the inspection, test, and operating status of items

-(12) identifying and dispositioning nonconforming items (13) correcting conditions adverse to quality (14) preparing and maintaining QA records (15) auditing activities that affect quality The CPSES QA program' requires the establishment and continuous implementation of the QA indoctrination, training, and retraining program to ensure that.

Comanche Peak SSER 22 17-3 l

Alt'achmnt to TXX 92n64 l' age 8 of M person) involved in safety-related activities are knowledgeable in QA instructions and implementing procedures and that they demonstrate a high level of competence and skill in *.he performance of their quality related activities. '

Quality auditingisofverified through surveillance, inspection, testing, checking, and work activities. The QA program requires that quality verification activities be performed by qualified personnel who are not directly responsible for performing the work being verified. Verification is performed in accordance with procedures, instructions, and/or checklists by personnel who have been qualified and certified in accordance with codes, standards, and applicant training programs.

The Director, QA, is responsible for QA audits This includes planning, preparation, scheduling, performing, reporting, and verifying implementation of corrective and preventive action measures. The QA program establishes a compre- _

hensive audit system to ensure that the QA program requirements and related sup-porting procedures are offective and properly implemented during operations.

Audits include _an objective evaluation of QA practices, procedures, instruc-tions, work areas, activities, processes, and items; of the effectiveness of implementation of the QA program; ano of conformance with policy directives.

--The QA program requires documentation of audit results and review by the management personnel who have responsibility in the area audited to determine and take corrective action as required. Reaudits are performed to determine that nonconformances have treen ef fectivel action precludes repetitive occurrences. y corrected and that the corrective 17.4 Conclusion The steff review of the CPSES QA program description for the operations phase has verified that the criteria of Appendix B to 10 CFR Pert 50 have tieen addressed, On the basis of its review and evaluation of the QA program description contained in F$AR Section 17.2, the staf f concludes:

(1) Ine applicant's QA organization has (a) sufficient independence from cost and schedule (when opposed to safety considerations), (b) authority to effectively carry out the operations QA program, and (c) access tu management at a level necessary to perform the QA f un;tions.

(2) The QA program describes requirements, procedures, and controls that, when properly implemented, comply with the requirements of Appendix B to 10 CFR Part 50 and with the acceptance criteria contained in SRP Section 17.2.

The staff concludes that the applicant's description of the QA program is in compliance with applicable NRC regulations and is acceptable for the operation of CP5ES.

Comanche Peak SSER 22 17-4 l

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