ML20099F089
| ML20099F089 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/06/1992 |
| From: | Starkey R CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS-92-214, NUDOCS 9208120115 | |
| Download: ML20099F089 (49) | |
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fAUG 061992 SggIAu Nt,s.92 214 n u sunny,.a 10CFR50.54(a)(3)
' Vto Prowked.
. Nockar Services Deanmunt United States Nuclear Pegulatory Commission ATTENTION: Dacument Control Desk
. Washington, DC 20555 BRUNSVICK STEAM ELECTRIG PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50 325 AND 50 324/ LICENSE NOS. DPR 71 AND DPR-62
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QUALIT'i ASSURANCE PROGRAM C11AUGES Centlemen:
Carolina Power & Light Company (CP6L) hereby submits for approval a change to the quality Assurance (QA) Program for the Brunswick Steam Electric Plant (BSEP).. This request is submitted in accordance with 10CFR50.54(a)(3) and is, detailed ln Enclosure 1.
-Enclosure 2'prnvides the FSAR narked-up pages associated with the QA Program change.
The proposed changes reflect CP&L's efforts.to place the responsibility for quality at the appropriato level in the line organization and to make improvements in the' assessment process. These improvements include enhancements to the corrective action program, emphaals on line organization self-assessment, and new direction for the independent assessment group. The new QA Program description is provided in Enclosure 3.
- The revised program is-expected to provide increased assurance that activities
' at CP&L's nucletr projects are accomplished in a safe and controlled manner by allowing rore offective use of assessment resources.
The BSEP QA Progtam will hi' contiwac to meet the applicable 10CFR50, Appendix B criteria.
'Itese changes-will be incorporated into the FSAR in accordance with the
- pxovisions.of 10CFR50.71(c).
Should you have any questione regarding these changen, please cono et M r. - D. t'..McCarthy at (919) *246 6901, Yours v ry truly,
,J I
I R. B.-Starkey, Ur.
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Mr. S. D. Ebneter
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l-7 ENCLOSURE 1
- BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 QUALITY ASSURANCE PROGRAM CHANGE t
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OA PROGRAM CHANGE FSAR. SECTION 1.8. FECU1ATORY CUIDE 1. 33 PACE 1.8 14
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Pronosed Chanze #1 The proposed change deletes the existing clarification "a" and replaces it l
with new clarifications "a & b" concerning CP&L's independent review and assessment. programs.
The new clarifications are provided to reference the plant Technical-Specifications and Section 17.3 of the FSAR for details of j
,c these programs.;
Reason. Tor Chanres.
These new clarifications and references to the plant Technical
- Specifications and Section=17.3
- of the FSAR eliminate duplication and potential mtsunderstandings.
1 Basis for Concludine That the Revised Procram'Incor2oratine the Chance Continues to Satisfy 10CFR$0 Anoendix B and the FSAR Ouality Pr.pgram
{
CPhL's NAD will' implement Independent Assessments as described in Section J17.3.- Resulta of. Independent Assessments and reviews of those rosults by.
Senior " sagement will be in accordance with Section 17.3.
CP&L's Independent Review Program will be implemented in accordance with the plants Technical Specifications.
OA PROGRAM CRANCE PSAR. SECTION 1.8. REGULATORY CUIDE 1,58 PACE 1; 8-19' t
. Proposed Chgnee #1A The' proposed change eliminates the commitment to th'e Regulatory Guide 1.58
'liated'on page 1;8 19 of.the FSAR.
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Reason for-Chaneg The'NRC provided notification for withdrawal of this Regulatory Guide (see
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.56= Federal Register:at 36175) because it has.become obsolete, j
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Agsis--for Concludine That the-Revised Program Incorporating the Chance er
' Continues to Satisfv-10CFR$0 Appendix B and the FSAR Ouality Procram
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-~TheLNRC provide'd' notification for withdrawal'of--this Regulatory Guide (see Se l56 Federal Register at-36175).because it has become: obsolete; BThe' ANSI Standard 1(N45.2;6-1978). endorsed.by this;regulatary guide is-(,,
! remaining inLeffect and CP&L will-continue to. comply with ANSM N45.2.6-
- 1978-cfrpposed Chance #2.
The3 proposed. change deletes " Operating Pinnt QA" and = Identifies the Quality-Control (QC)fpersonnel are' qualified por this-standard as tated lin thisiposition.
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Reason for Chnnto Clarify organization description'of personnel.
Basis for Conclud!nr That the Revised prorram Incorporatine the chaDER Continues to Satisfy 10CFR50 Anvendix B and the PSAR Ouality Pror, nag a
Qualification of NAD personnel will be in accordance with Section 17.3.
Qualification of QC personnel will be in accordance with CP&L's commitment to Regulatory cuide 1.58 and Section 17.3.
OA PROGRAM CHANGE - FSAR. SECTION 1. 8. REGjnATORY CUIDE __.1,88 PAGE 1. 8-23 EE2ppsed Chance *2A The proposed change eliminates the commitment to the Regulatory cuide 1.88-listed on pagefl.8 23-of the FSAR.
Reaser {pr Chance The la provided notificetion for withdrawal of thin Regulatory cuide (see-56 Federal Registet ut 36175) because it has become obsolete.
, Basis for Conclucjinn Thnt the Revised Procram Incorporatine the Channe
-Continues to Satisfy 10CFR50 Annendix B and the FSAR Ouality Procrag i
The NRC provided notification for withdrawal of this Regulatory cuide (see
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'56 Federal' Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2,9-1974) endorsed by this regulatory guide is remaining-in effect and CP&L will continuo to comply with ANS1 N45.2.9-
,1974 Proposed Chance #3
[
.This proposed change adds a. reference to.Section 17.3.
Reason for Chance f
' Addition of.this clarification doe's not change the manner in which businass is conducted,-but' simply references where' additional clarifications and controls on QA. records are located in the FSAR.
These
- 6ontrols/ clarifications were previously included in Section-17.2 but were
' not: referenced here.
This provides a better description of where the controls for QA records are_ located in the program.
Basis-for Concludinn That the-Revised Pronram Incorporatine the Chance Centinues to Satisfy 10CFR50 Appendix B and the FSAR Ouality Progggg Section 17.2-is being replaced in its entirety by Section 17.3, which describes the QA-Program. Controls in 17.3 contain the elements previously contained in Section 17 2-2
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th OA PROCRAM CllANGE - FSAR. SECTION 1.8. REGUlfIDAY CUIDE 1.144 PAGE 1.8 31 Proposed Chance #3A l
The proposed change elitninates the commitment to the Regulatory Guide 1.144 listed on page 1.8 31 of the FSAR.
1 Reason for Chance-The NRC provided notification for withdrawal of this Regulatory Guide (st:
56 Federal Register at 36175) because it has becorne obsolete.
Basis for Concludine That the Revised Procram Incorporatine the Chance 99At;1mt.es to Satisfy 10CFR50 Appendix B and the FSAR Ouality Prontaja The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
The ANSI Standard (N45.2.12 1977) endorsed by this regulatory guide is remaining in effect and CP&L will continue to comply with ANSI N45.2.12-1977.
. Proposed Channe #4 The proposed change deletes the current clarifications relative to the Regulatory Guide 1.144 end replaces them with clarification statements to ANSI N45.2.12 197 Reason for Chance-There is no change for external audits. The' internal assessment process included in Section 17.3 better describes the methods to be accomplished than this Regulatory Guide or Standard.
Basis for Concluding That the Revised Procram Incorporating L:1'fonte
- Continues to Satisfy 10CFR50 Appendix'B and the FSAR Ouality Pronraa
' Independent assessment of. internal activities will be accomplished as outlined in FSAR Section 17.3.3.
" pA PROGRAM CHANGE - FSAR. SECTION li8. REGUIATORY GUIDE 1.146 PAGES 32 &
Lb33 iPronosed Channe #4A
/The. proposed' change-eliminates the commitment to the Regulatory Guide-
$1(146 listed on page 1.8 32 of the FSAR.
.B3ason-for Channe Thb NRC provided notification for withdrawal of this Regulatory Guide (see 56' Federal Register at 36175) because it has become obsolete. u
Basis for Concludine That the Revised Prorram Incorporatine the Chante Continues to Satisfy 10CFR50 Appendix B and the FSAR Ouality Program
- The NRC provided notification for withdrawal of this Regulatory Guide (s> e
~$6 Federal Register at 36175) because it has become obsolete.
1 The ANSI Standard (N45.2.23-1978) endorsed by this regulatory guide is remaining in effect and CP&L will continue to comply with ANSI N45.2.23-1978..
Proposed Chante #5 The proposed change replaces e,.isting clarifications relative to cudits and.tha lead auditor qualificacion. Qualification for External (vendor)
-auditors will continue to be accomplished in accordance with this standard. Qualification of internal independent assessment personnel will
.be accomplished in accordance with the requirements outlined in Section 17.3.
A. reference to Section 17.3 is being added to this page.
Reason for Chance TheLqualification for internal independent assessment persennel included in Section 17.3 better describes the methods to be accomplished than this Regulatory Guide or Standard.
Basis for Concludine That the Revised Prorram Incorporatint the Chance Continues to Satisfy 10CFR50 Appendix B and the FSAR Ouality Prorram Qualification of internal assessment personnel shall be accomplished as outlined in Section 17.3 based on education and. experience needed to evaluate the activity being assessed.
-OA PROGRAM CilANGE FSAR. SECTION 0.5.
FIRE PROTECTION PAGES 9.5.1-5. 7. 9.
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. conosed Chance #6 TheLproposed change deletes'the Corporate' Quality Assurance Department from-the organization that reports to the Execetive Vice President, Power Supply.
~ Reason for Chance CP&L reorganization of the Corporate Quality Assurance Department and
. creation"of-'the Nuclear Assessment Department has-resulted in the elimination ~of-this position.-,
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' Bania for Concludine That the Revised Procram incorporatine the Chance Continues to Satisfy 10CFR50 Appendix B and the FSAR Ouslity Procram The Nuclear Assessment Department'v111 implement a program of Independent Assessments in accordar e with Section 17.3.3 that will assess the effectiveness of the Ftre Protection Program.
I A summation of assessment reports, along with any potential issues and recommendations shall be presented to the Executive Vice President - Power Supply and Senior Vice President Nuclear Generation Group on an approximately bimonthly frequency.
- Proposed Chance #7
'The proposed change deletes the reference to Quality Assurance and deletes tlui words " surveillance of fire pretection activities."
Reason for Change The specific responsibilities are (qt, :,1/ cod fr em this section to eliminate-redundancy-and possible conist es.
Basis for Concludint That the_Pevised Pgggram incorporatint the Change Continues to Satisfy 10CFR50 Appendix B and the FSAR Ouali ty Procram s
-Section 17.3: describes the QA Program.
The operational fire protection QA elements are included in Section 17.3.
The 'Ndelear Assessmenc Department will evaluate the' effectiveness of the Fire Protection Program through the use of Independent Ass ssment.
Proposed Change #8 The proposed' change deletes the reference to the Corporate QA Manual.
Erason for Chance The deletion of these words does not affect the way that the QA Program will be implemented. They are'being deleted to eliminate redundancy and possible conflicts.
Basis for Concludint That the Revised Procram incorporatine the Chance continues to Satisfv 10CFR50 Appendix B and-the FSAR Ouality Procram 1SectionL17.2 is being replaced in its entirety-by Section 17.3, which
-describes the QA Program.
Deletion of. thin reference will not affect the implementation of 17,3.
-Proposed Chance #9 The proposed change deletes the reference to QA personnel performing
- receipt inspection of FPQ items.
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Ernson for_. Change This activity is performed by QC personnel and this reierence is redundant
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to Section 9.5.1.3.1.d which already addressed this.
Basis for Concludinn That the Revised Pronram incorporatinn the Channe Continues to Satisfy 100FR50 Apte dix B and the FSAR Ouality Pronram CP&L's reorganization of the Corporate Quality Assurance organization places the: responsibility of receipt inspection in the Quality Verification'Section in the Nucicar Services Department.
These functions have not changed as a result of this reorganization.
_ Proposed Chance a10 The proposed change deletes references to audit requirements and responsibilities contained in this section.
Reason for Chance This-change is being made to eliminate redundancy with the audit requirements of the Technical Specifications and the assessment function contained in Section 17.3.3.
Easis for Concly.dinn That the Revised Pronram Incorporatine the Channe Continues to Satisfy 10CFR$0 Appendix B and the PSAR Ouality Pronram Section 17.3.3 describes the Independent Assessment process which replaces the audit' responsibilities described here, The NAD will implement the Independent Assessment-Process.
This process will ensure an effective means of reviewing and evaluating the CP&L QA
. Program.
Proposed Chance oil The proposed change deletes roterences.to tho'QA organization and specific responsibilities assigned to the QA organization relative to fire protection. Section 17.3 is referenced-to addrews the NAD.
Reason for Channe
~The-specific responsibilities are being: deleted from this section.
-included in Section 17;3 to eliminate-duplication and possible conflicts.
lQA organization is deleted based on creation of the HAD.
-Basis for Concludinn-That the Revised Prontam Incorporetine the Chance Continues to Satisfy 10CFR50 Appendix B and the FSAR Ouality Pronram
-Section 17.3 describes the QA Program. The operational fire protection,QA 1
elements are included in Section 17.).
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The NAD will evaluate the effectiveness of the Fire Protection Program 1
through the-use of Independent Assessment, p
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k-OA PROGRAM CHANCE - FSAR SECTION 13.4. Pace 13.4.0 1 Proposed Chance #12 The proposed change deletes reference to the Review and Audit Program and references Section 17.3 for this information.
Reason for Chance Deletion of the specific details from this section eliminates duplication within the FSAR.
Bnnis for Concludine That the Revised Prorram_1ncorporating the Chance Continues to Satisfy 10CPR$0 Appendix B tirid the PSAR Ouality Prorrtim
-Section 17.3.3 describes the Independent Assessment process which replaces the Audit Program described in FSAR Section 13.4.
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.The Nuclear A'ssessment Department will implement the Independent
-Assessment' Process.
This process will ensure an offectivo means of reviewing and evaluating-the CP&L QA Program.
OA PROGRAM CHANGE PSAR SECTION 17.2. OA PROGRAM DESCRIPTION PAGES 17.2.0 1 THROUGH 17.2.R-1 Proposed Chance 13 The proposed change deletes FSAR Section 17.2 in its entirety and replaces
-it with FSAR Section 17.3 which describes the QA Program,
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'Reanon for Chance
'The proposed FSAR'Soction 17.3 describes the use of performance based assessment; concepts,which'CP&L is using in the NAD-and line organizations.
The program-content is the same as was in FSAR Section 17.2. except in the area of audit / assessment.
Pasta for Concludine That the Revised Procram Incormoratine the ChaDER f
Continues to Satisfy 10CfE50 Ar.nendix B and the FSAR Ouality Provrag FSAR Section 17.3 replaces FSAR Section 17.2 in its entirety.
The program content is the same as-was in FSAR Section-17.2, except in the area of assessments..These controls will ensure an-offective.QA Program at CP6L.
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ENCLOSURE 2 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS.1 AND 2 FSAR PAGE MARK-UPS I
(14388NP.GLU)
Regulatory Culde 1.33 QUALITY ASSURANCE PROGRAM REQUIREHENTS (OPERATION) (NOVEMBER 1972)
ANSI Standard N18.7-1976 ADMINISTRATIVE CONTROLS AND QUALITY ASSURANCE FOR THE OPERATIONAL PHASE OF NUCLEAR POWER PLANTS
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Comply with the provisions of Regulatory Calde 1.33, November 1972, and the requirements and recommendations for administrative controls described in ANSI N10.7-1976 except as stated belows pg pr,,,j ppgg ij hwII McW IhrnMcPh5
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a)
I Section-4,5r-next-to-last-paragraph-statee l' Peel + die-review-of-+he r
audibprogram-shall--be-performed by the independent--revice bedy er-by mana6ement-representative-et-44asbeam1= annually te se cure that audite see being-. accomplished in-accordence-with -requirements-of-Technien! Spe+444 eat 4+ne and-of-thie-Stendard.!'---CP&l,is-Performance-Evaluation Unibis 2n -- !ndependent-s e c t i on - t h a t--mon i t o r s-a l l-o t he r-s ec t i on s-w i t h i n-ou r-o r g a n i sa t4e n.
E::b medi-t r.eport. is-reviewed-by-the. Executive-Vice-President -Peuce Sep;4r-end En g i nee r i ng Con s t ru c t i on.--C P&L-fe el e-t ha t-t he se -a r ra n geme nt-r e viewe-4teted sa t-i s f-y-t he-req u i remen t s-o f4a-above-pan guph.
C. 'b)
Section 5.2.2 titled Procedure Adherence Temporary changes to approved procedures shall be approved by persons specified in the BSEP 1 & 2 Technical SpeeifIcatlons.
' d 's,)
The applicabic procedures reccanended in Appendix "A" of Regulatory Guide 1.33, November 1972, shall be established, impicmented, and maintained as specified in the BSEP 1 & 2 Technical Specifications.
E E)
Section.5.2.17, second to the last sentence in the last paragraph,
" Deviations, their_cause, and any.
" to be consistent with Paragraph 5.2.11 and 10CFR50, Appendix B, the cause of the deviation will be determined for only significant conditions adverse ~to safety.
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Section 5.3.9.1, titled Emergency Procedure Format and Content:
Emergency procedures shall be in the format as committed to in NUREG-0737, TMI.
5 Action Plan.
ANSI N18.7-1976, Section 5.2.16.
See FSAR Section 17.2.12 for clarification.
4 1.8-14 Amendment No. 5 b + -- - H -s.,,, - ~.----.., - - - _..
Proposed Changg__1 Japart_ f or Rect. Guide 1.33 a.)
Section 4.3 titled Indspendent Review PrqqrAE:
CP&L will.
implement the indopondent review program outlined in the plant Technical Specifications.
6.5.2.
b.)
Section 4.5 titled Audit Program:
CP&L will implement an assocoment progrum outlinod in Section 17.3.3 of the FSAR.
V.
Regulatory Guide 1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, fro Ikwd Cbor,C ih ANSI Standard N45.2.6-1978 QUALIFICATION OF INSPECTION, EXAMINATION, AND 11 k eTI' a h d n W k BSEP 1 & 2 shall comply with NRG-Reguletwy Cuide--4,4&r-80Pt-ember-1984r-whfeh endorses ANSI N45.2.6-1978, with the following exceptions
- a)
Section 1.2 titled Appilcabilityt CP&L elects not to apply the
-requirements of this guide to those personnel who are involved in the daily operations of survelliance, maintenance, and certain technical and support services whose qualifications are controlled by the Technical Specifications or are controlled by other QA Program commitment requirements. Only personnel in the following listed categories will be required to meet ANSI N45.2.6-1978 requirements (1) Nondestructive examination (NDE) personnell C h n. m, F (2) Operating-phant-QA/QC inspection personnel.
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b)
The fourth paragraph of Section 1.2 requires that the Standard be imposed on personnel other than CP&L employees.
The applicability of the Standard'to suppliers and contractors will be documented and applied, as appropriate, in the procurement documents for such suppliers and contractors.
c)
Section 1.4 titled Definitions Definitions in this Standard which are not included in ANSI N45.2.10 will be usedt definitions which are included in ANSI N45.2.10 will be used as clarified in CP&L's commitment to Regulatory Guide 1.74.
d).
Section 2.5 titled Physicalt CP&L will implement the requirements of this Section with the stipulation that, where no special physical characteristics are required, none will be specified. The converac is also truet-if no'apecial physical requirements are stipulated by CP&L, none are considered necessary.
CP&L cmployees receive an. Initial physical examination to assure satisfactory physical condition 1 however, only the following listed personnel will receive an annual:(.! 2 months) examinations (1) NDE personnel
-i (2) Operating-plent-QA/QC inspection personnel,
. This annual examination shall consist of the near visual acuity using the
-e andard Jaeger's-type chart-or-equivalent test.
4 e)-
Section 3 titled Qualificationst only personnel performing NDE (such
-as LP, T, UT, and RT) will be grouped in levels of capability and certified as such. -QA/QC' inspection personnel will be certified for inspection, review, and evaluation-of inspection data, and reporting of inspection and test results.
1.8-19 Amendment No. 4
- Proposed - Chanese 1 A Insert Attachment The HRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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BSEP 1 & 3 i
PilPh Cha,w G 2h Regulatory Guide 1.88 COLLECTION, STORACE, AND MAINTENANCE OF NUCLEAR POWER PLANT QUALITY ASSURANCE RECORDS (Aug t 19i4)
ANSI Standard N45.2.9-1974 COLLECTION, STORACE, AND MAINTENANCE OF QA RECORDS IHwir nThuhm off y*]
The requirements for collection, storage, and maintenance of QA records at N '"#
BSEP will be in accordance with ANSI N45.2.9-1974gwith the following specific 1
exceptions y p y-g.4 g p7, 3 The document control facility at the BSEP shall comply with the requirement of l4 Regulatory Cuide 1.88, October, 1976, Regulatory Position C.2 in that the facility will be constructed and maintained in accordance with NFPA 232-1975 as a four-hour facility, with the following exceptions /
alternatives / comments:
a)
Records are classified as Class 1 - Vital Records in accordance with NFPA 232-1975, Chapter 5, Section 5222; however, the records that meet this classifiration include those determined to be QA records as defined in ANSI N45.2.9-1974, paragraph 1.4.
b)
The. facility is constructed in accordance with NFPA 232-1975 requirements for a four-hour rated vault, ground-supported as defined in NFPA 232-1975, Chapter 2, Section 20258 however, due to the fact that the facility is to be used exclusively for the storage and handling of records and the interior volume, i.e., greater than 5,000 cu ft, the faellity is termed to be a " fire-resistive file room located within a non-fire-resistive building."
c)
Due to the construction of _ the f acility and other safety treasures described herein, the statement in NFPA 232-1975, Chapter 3, Section 3022(d),
" Class 1'.
.. records should not be subjected to these possibilities of destruction by fire" is deemed to be inappropriate, d)-
The freility is protected by a Halon fire extinguishing system, automatic door closures, and fire detection system.
4 e)
The floor of the file room is six inches higher than the floor areas outside the file room, f)
The walls are reinforced concrete, ten inches thick.
g)
The exterior walls are totally enclosed-and insulated from the outside-
-environment and elements.
h)
The fac'ility is constructed independently from the building.
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_NFPA 232-1975, Chapter 3, Sections 332 and 333 describe methods for heating and ventilation. The facility will have penetrations in the wall for
-the purposes of heating and_ven:llation.
The facility is equipped with a Heating, Ventilating and Air Conditioning system external to the file room with automatic closing dampera. The temperature and humidity _should be contro11eo between 65 and 75 degrees and 30 and 40 percent, respectively.
Amendment No. 4 1.0-23
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L Proposed Change _2A Insert Attachm2D1 The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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p-0 BSEP 1 6 2 UPDATED FSAR do Ibst.M CimiaGG 3/\\
Regulatory Guide 1.144 AUDITING OF QUALITY AESURANCF, PROGRAMS FOR NUCLEAR POWER PLANTS (JANUARY 1979)
I I
ANSI Standard N45.2.12-1977 REQUIREMENTS FOR AUDITING OF QUALITY ASSURANCE
+
PROGRAMS FOR NUCLEAR POWER PLANTS i
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Ca ro l i na -Powe r-&- L i g h t-Co mpa ny-wi44-fe l4 ew-t he-eequi+ement-e-and recoeur,endations-of-paragraph:- C.1, C. 2, - C. 3.av2, C.,3.by-and C.^.
Carol 4ea Power-&-Light-Company s-positierr-on-paragverh-Graverl-4+-es-fe14ews4 l
i A44Lts-of-+perational-phaseact4*lt ic:,
- Out44ned-In-rectier 6, 4ren a 3
Technical-6pecificetionsy-she11 be performed-et-the-f requenciee-et-eted In=the Techni+el Opccificetier.s.
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1.8-31 Amendment.No. 3-
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Pronosed Chance 36 Insert Attachment The NRC provided notification for withdrawal of this Regulatory Guide (see 56 Federal Register at 36175) because it has become obsolete.
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-p Proposed Chance.4 Insert for Rec. Guide 1.444 CP&L shall comply with the require.nents of ANSI N45.2.12(1977) for external (vendor and supplier) audits.
Assessments of internal activities shall be accomplished as outlined in Section 17.3.3.
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' I)ro. Pow <1 UPDAT!:D FSAR dwu.;G ri 4.h.-
i Regulatory Guide 1.14 QUALIFICATION OF QUALITY ASSURANCE PROGRAM AUDIT PERSONNLL FOR NUCLEAR POWER PLANTS (REV. 0)
(AUGUS1 1980)
ANSI Standard N45.2.23-1978 QUALIFICATION OF QUALITY ASSURANCE PROGRAM AUDIT luser1 c6h M1mm k BSEP 1 & 2 shall comply with NRC-Regulatory cui4e--LIM,- P. -icien- 0, hkh 3
-endeeses ANSI N45.2.22-1978,3with the following exceptions t k - Er e GremL koelbf mxl SufTlePN Wbub f
a )---Sec t i on--144-t i t l ed-De f i n i t i on s 3 -De f i n i t i on s-4 n-tMe-Standa r4-which-4 re not-included-4 n-ANFI-N4b2,10-wi41-be-uc edi "-AUDIT"-whieh-4e-inel<ded-in 3
ANSI-N45r2 v10-vi4+- be-us ed-as-el-a ri fied-in-GP4tr s-commi tment40-Hegu l a t o r y t
Culde-1,J4.
b)
Sec t i on -2. 2-t-i t l ed-Qua 14 f i ca t i on-o f - Aud i t or s t - Su bsect4+n-av3,4 l3 reierences.an ANSI 845.2-which-will-be-. assumed -te be N' 5.2.
CP&L-wi44-eempty with-an-alternate-subsection-21211= which reeds 1 Oriental 4en-to--provide-a-workin;; kneukadge-and.
Pr,Jr,ed und e r s t a nd i ng-o f--t he-CP & l,-Qua lit-y-Aaaveense-Scegeam, cim,m e ineluding-the-Reguletory-Cu44ee-and-AM&1--st-andard; inc1uded in-the-Program -and-CP&le-proceduree-fee-perf+cch -eudi-t-,
y and-reporti ng-ceeul-t-e.
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S e e t4 en-312-t-k4-ed-H a beene nee-o f-P ro flei+nep--CP &4,-v444-eompty-w kh l3 the-requi-rement4-of-thie-Sect 44n-by-def4ning !' annual-asses + ment" ne ene uhish takes-plac&4very 12 - montche, plus er minue--
- hr-se-monthe,-and-which uill use the-inh 441-dat-e-of-cert 4fice44+n-for-detrerminin;; uhen-annual-assee+ ment.-ie-dwe.
d )-Secti aa A ! tit!cd-or,34nh ati^n21 Respensibi.!ty*
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ith l3 thi-s se c tion-w i-t h-t he -su bs t-i t u t ion-o f-the--f+44+w&ng-een t e n c c !*-14 arc c f t he-last-sentence in the Ecctien.
The-Hanager-of-QA-Servi ces, "rincipal-Q.^ Opet!alict -
- Performance-Evaluatdonr-or L^d ^ =d i t r-he!!, prior-to 3
commencing-the-audi t y-cas4 n perscar:1 who collect ively t
have-experience er t raining c enrerete eith the recpe, complexity,-oespecie4-nat-uce-of t he act vit i c; t c bc eudhed.
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Section 5.3 titled Updating of Lead Auditors' Records!
CP&L will l3 substitute the following sentence for this Section Records for each Lead Auditor shall be maintained and updated during the annual management assessment as defined in Section 3.2 (as clarified).
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it has become obsolete.
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Section 5.4 titled Record Retentions CP&L will substitute the following
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e* SctIlop 11,3 Qualification recordt ' hall be rntained as required by -the pnp,,s. d ( Jnup F F "a
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Proposed chance 5
-Insert for ANSI Standard N45,L 23-1978 c.)
Qualification.of internal assessment personnel shall be accomplished as outlined in Section 17.3.3 based on education and experience nooded to ovaluate the activity being assessed.
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Fire Hose, NFPA-STD-1961-1974 x)
Fire Protection f or Nuclear Power i '. ant s, NFPA-STD-803-1978 9.5.1.2.4 Institute of Electrical and Electronic Engineers, Inc.
a)
Standard for Type Test of Class lE Electrical Cables, Field Splices and Connections for Nuclear Power Generating Stations, IEEE-STD-383-1974 b)
Standard Criteria f or Independence of Class lE Equipment and Circuits, IEEE-STD-384-1981 9.5.1.2.5 Nuclear Hutual Limited Property Loss Prevention Standards for Nuclear Generating Stations 9.5.1.3 Fire Prevention Program The fire prevention program at BSEP has an administrative organization which implements the procedural, technical, and training a 4 pects of the program.
This organization includes of f-site management, on-s t t e management, and on-site support functions. Specific responsibilities of organizations involved in the Fire Protection Program can be found in,the Fire Protection Program Document, PLP-01.
9.5.1.3.1 Off-Sir.e Organization and Responsibilities The organization of the various off-site personnel integral to the BSEP Fire Protection Program (FPP) is described in Chapter 13.1.
In addition, their l
responsibilities are described belows a)
The Senior Vice President - Nuclear Generation Group is responsible for the formulation and implementation of a FPP compatible with nuclear safety and the protection of property and personnel. The Senior Vice President is al so l
responsible for having the status and adequacy of the FPP periodically assessed. The Senior Vice-President has within his organization personnel who meet the requirements for Member Grade in the Society of Fire Protection Engineers.
b)
The Vice President - Brunswick Nuclear Project (BNP) is responsible for the generation of an ef fective and acceptable FPP by the nuclear plant.
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The-Hanager--Gorporate-Quanty4ssurance-ie-responsible for-de i-nd e pe nd en t l y-f o rmul a t-i ng-and-impl emen t i ng-p rog r ams-t o-pe r iod i ca l4 y-a s se s s4 he T
ef feet-ivanes s-of-the-plant FPP -The-results-of--thess independent-assessment s b
ed-t o-the-Senior-Enecutive-Vice-President- -Power-Supply 4--In l
.are-repe
. ad d i t-ica -t l>e-Ma na ger-Co rpora t e-Qu a l-i t y4ss u ra nc e-i s-a l s o-re s pon s i bl e-f o r r
ensning-that-independent-audits-are-conducted in-accordancs-with-approved procedures.
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The Hanager - Nuclear Engineering Department is responsible for providing engineering and design for fire protection services for Brunswick Nuclear Plant. This is done with both on-site and off-site personnel.
9.5.1-5 Amendment No. 9 A
BSEP 1 & 3 I
UPDATED FSAR fhfo9d IvtNRE U9
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The. Hanager - Quality A;eurence/ Quality Control, Brunswick plant, is responsible for material receipt inspection of FP Q-list items and-surveillance-of, fire protecticr. cethities.
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The Hanager - Haintenance is responsible for the general maintenance of fire protection systems and equipment and for the timely resolution of maintenance and/or equipment conditions adverse to fire protection as reported to him by the Hanager - Operations. In addition, the Manager
_Haintenance is responsible for ensuring that all plant maintenance is performed in accordance with established fire protection procedures and in a manner that minimizes transient combustible loads.
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The Manager - Regulatory Compliance is responsible for scheduling and
.teacking various fire protection periodic tests.
3 14 The Manager - Environmental & Radiation Control (E&RC) is responsible for providing assistance to the Fire Protection Support group during performance of periodic testing, providing dosimetry and decontamination services to of f-site fire department personnel during drill participation and r
actual fire emergencies, and providing personnel to assist the fire brigade as
'outilned in the pre-fire plans.
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'The Manager - Technical Support is responsible to the plant General Kanager for providing technical support and acting as Systems Engineers for l
the Fire. protection-Program.
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9.5.1-7 Amendment No. 9
Combustible Materials and Ignition Sources - The probability of the occurrence of fires at Brunswick can be minimized through the control of combustible materials and sources of ignition. The plant Operating Manual contains written instructions regarding the storage and use of combustible materialsi the use of welding, bun ing, and other open flame operations and routine fire inspections of the plant.
l6 Welding, flame cutting, grinding, and other operations which may constitute a source of ignition are controlled by a permit system. This permit system is in accordance with the genetal guidelines specified in NFPA 51B, cutting and Welding Processes. A multilevel structure of responsibility ensures that carelessness or omission of any step in the system does not compromise fire safety.
Control of combust %1e material is achieved by providing guidelines regarding the storage and use of flammable and combustible liquids, gases, and solids.
Specific guidelines for the control of flammable and combustible liquids generally follow the recommendations of NFPA 30, Flammable and Combustible Liquids Code.
Similarly, guidelines for the control of flammable gassea l
generally meet the intent of NFPA recommendations.
It is Brunswick's policy to use noncombustible material in the plant. When noncombustible materials l6 are not' suitable, a fire retardant material is typically selected.
Periodic inspections of all plant areas are performed and documented by the Fire Protection group in accordance with established procedures.
d).
Special Structures - The control of any special or temporary structures such as tents, trailers, construction shacks, and other enclosures not covered by a plant modification package require a special structure permit in accordance with the plant Operating Manual. The purpose of the permit is to ensure that the installation of any temporary structure will not result in an unacceptable hazard to any permanent equipment, systems, or structures.
Periodic inspections by the Fire Protection group assure that all such special structures have the required permits.
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Control of Maintenance and In-Plant Work Activitics - Inaccordanc-e with-the-Corporate-Que W y-Assuranee-Manual,As program of preventive maintenance has been established for appropriate fire protection items. These preventive maintenance requirements are met by either the preventive maintenance program established by the Maintenance Subunit or by the periodic testing activities performed by the Operations Subunit.
The plant Operating Manual contains procedures which describe the Maintenance
-Subunit preventive maintenance program.
Surveillance activities performed on fire protection items by Operations is done in accordance with-procedures in the plant Operating Manual.
Each procedure is_ specific with regard to frequency, acceptance criteria, and step-by-step instructions.
Corrective maintenance is controlled by procchres which specify the reviews needed to evaluate Fire Protection's involvetent. All maintenance work forms involving fire protection items are routed to the N rc Protection group.
9.5.1-9 Amendment No. 6
A special type of in plant maintenance is that regarding the removal, rapair, or modification of culating fire barrier penetration seals or the creation of new fire barrier penetrations.
Prior to performing any such work at Brunswick, a Fire Barrier Penetration Seal /Stop Work Permit or equivalent l'
control program is required. An inspection of the completed work in made by qualified inspectors, f)
Plant Hodification and Design Change Review - Plant modifications and design changes are controlled in order to ensure tha. plant structures, systems, and components continue to meet their performance / functional objectives. The plant Operating Hanus' includes written instructions that describe the modification process and the means for documenting the required changes and activities. As a part of this process, each engineer responsible for the plant modification is required to consider the effects of the modification on the fire protection program.
In addition, the modificatir-n package receives an independent fire protection review in accordance with the Nuclo~ Plant Hodification Program.
Specifically,'he fire protection review considers the type and quantity of t
combustibles introduced (both permanent and temporary) and any degradation of any fire protection features to determine if (1) additional fire suppression capability is required, (2) if a limiting condition of operation is involved, and/or (3) if special administrative controls are necessary.
g)
Fire Protection Quality 1.ist - Fire protectiva quality (FPQ) components are those which must perform their intended function when requireu or the loss of saf ety-related and safe shutdown equipment may result during a postulated fire.- FPQ components usually demand special ordering, material handling, installation, and/or testing requirements.
The FPQ list outlines boundaries to fire protection systems within which all FPQ components are contained and is maintained as part of the plant Operating
-l Hanual. Maintenance of the FPQ list is defined in the Plant Operating Manual.
h)
Procurement Activities - The plant Operating Hanual contains writter.
instructions concerning the procurement and storage requirements for-safety-and non-safety-related items. These instructions provide for differing levels of quality control depending o1 the quality classification of the item. For fire proter ; ion items, this classification is FPQ (see Section' 9.5.1.3.3g).
Upon receipt of fire protection items at the warehouse, a receipt-inspection is performed in accordance with the instructions provided in the purchase requisition.
In general, fire protection items are visually receipt inspected to ens'ure that the material-being delivered is tre type and quantity ordered, that-no shipping damage has occurred, that protective coverings and coatings are in place, and that any required documentation is received. Fit-items requl+e-4nepcc t. = by Qual i t-y-As4ureac+.pereonnM.
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Audita -The-plant-General-Manager-ie-responsible-for-eneurin;; the fo llowin g-aud i ts,t re-accomp14s hedt x
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9.5.1-10 Amendment No. 9 O
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BSEP 1 & 2
-UPDATED FSAR 1
3 )-- A-t r i e nn f a l+ au d i t~ by-o r. -ou t s i d e-- f i r o -c on s u l t an t-i n - a c c o rdanse-4t h Nnthd--
technicel-s pecificationer M LQ.-.
Th e-o bove-aud i t s-a re-c oo rd i n a t s d -e nd-c ondu c t e d-by -Co r po r at a-Qua144.y As s u ra nc e.-Th ey-e s t a bl i sh-the - f r ame wo r k..a nd - con t e nt-o f--t he-aud its.
9.5.1.3.4 Inspection and Testing Requirements Administrative controls are provided through existing Plant Administrative Procedures, Plant Operating Procedures, a.id the Quality Assurance Program to ensure that-the Fire Protection Program and equipment are properly maintained. Tho-includes-QA-audi te-of-the-prograawimplementation, c%c4-of en b remed i a l-a ct-lo n s-f or-s y stems-a nd-ba r41er.cre e t 9 resulco.
. periodi c-t4estsr All' fire protection equipment and systems are subject to an inspection and acceptance test in accordance with the NFPA codes and plant procedures af ter installation is complete. After t.he system is in operation, periodic inspections and tests are conducted as defined by the Fire Protection Program and NFPA codes, The following fire ~ protection features are subjected to periodic tests and inspections a)
Water Supply System b)
Barriers and Penetrations c)'
Alarm and Detection Systems d).
Manual Suppression Systems e)
Automatic Suppression Systems f)
Emergency 1.ighting g)
Communication Systems
. Equipment placed out of service in controlled th. cough the asiministrative program and eppropriate remedial actions are taken. The program requires all l impairments to fire protection systeres to bc identified and, if needed, appropriate notification given to Plant Fire Protection System Engineer.
l Depending on the condition, an engineering analysis may.be required to
' determine the extent of the impairment to safe plant operations. As conditions warrant reir.edial-actions include compensatory measures to ensure equivalent levels of-fire protection, in addition to timely efforts to repair and restore-the system to service.
- 9. 5.1. 3. 5.
- Quality Assurance
' I V.% c7 Uta f%ca ca rdet) Progeant-et-Brunswick-assures-that-the-f equiremente-.I-or (g The-Quality-As surance-designeprecuremont r--ins tallet-ionntes t-in8 rand-edmi ni-et-ra t i vea ont-r+1+-f or the-Mre -p rot ec t ion-prog re m-a r e-ap,-The-ro s pentr iM1 i t y -fon ens urdag-th qualitM -i-ite-prot ection-eet ivit ie a-at-Brunswi ok 41e e-wl : ' -the--plant Canacal f
Manager.
Podhwl N ycP VH 9.$.1-11 Amendment No. 9
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Roppsed Chqnce 11 1DAert ne*L oaracranh 9.5 1 M The Q'aality Ansurance program requirements applied to the fire protection program are outlined in FSAR Section 17.3.
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%1.,,escription of measures utilleed to satisfy the t.riteria f ollows:
a)
Design Control and Procurement Do:ument Cont r ol 1)
Op3 rations QA/QC reviews procurement documents and changes theret l
2)
A 1 plant modifications are reviewed t<
usure inclusion.of appropra te fire protection requirements and
.0 assure that the protectio of safe shutdown capabili. from tice is not compremi ed.
b)
Instructio
, Procedures, and Drawings 1)
Operations uality Assurance includes in their surve ance of BSEP such items as ind trination and training and associate documented
- ocedures, documen ed instructions, procedures, and d auings for fire protection activitiel 2)
The surveillances rformed by Operations QA C assures that installation or 'applicati o of penetration seal and fire retardant
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coatings is performed by qu lified personnel u ing approved procedures.
c.
Controls of Purchased Materi
, Equipmen, and Services - Operatio..s QA/QC performs receipt inspection of ire prot etion equipment whose quality cannot be verified after installation. Oper iona Quality As urance in concert with the plant Fire Protection
~ eer determines source evaluation requirements where materials are neither sted nor approved by a recognized testing au; 3rity, or specified by appl
- ab standards.
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Inspections 1)-
Quality control hold p nts are added t maintenance and mod *,fication procedures fo fire protection sy tems, emergency lighting, and communications. equip nt where appropriate.
- 2). -Personnel,.quali ted by training, inspect new enetration seals for proper installation Operations QA/QC inspect fire
'tardant coating installations to v ify satisfactory completion.
s 3)
New cable touting is inspected by Operations QA/QC t verify f
conformance with design requirements.
/
4)
The elisting Corporate Quality Assurance Program assures at ina ict iofn personnel are independent from the it.dividuals perfo ing the activi;ybeinginspected.
- 5),/ Operations QA/QC assures that procedures necessary for inspecti of f jre protection systems,. emergency lighting, and communication equipme t
^
are develope?.
9fnfes) Ohnen p Yll 9.5.1-12 Amendment No. 9 l
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\\0perationsQA/QCperformssurveillancestoassurethat necessary test / inh ections/surveillances by the Fire Protection group of fire p(otection systems, mergency breathing and au>:iliary equipment, emergency lighting, and communicat u equipment are being performed as required, f)
.Operatio QA/QC performs surveillances of documentation oa that the necessary t t/ inspections /surveillances of fire ; cops, s als, --
ire L
reta. dant coatin are being performed, g ).
Test and Test ntrol 1)
Operations
/QC assures that acceptance sts are specified in
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plant modificatio prior to the equipment be'ng declared operable.
3 Post-mainteaance te ts for repairs /replacem ts are reviewed by QA
- kPs,& OmM 2)
Corporate Quality urance inclu s fire protection periodic qq tests in the periodic au ts of plant perations to assure that the test schedule is being met.
3)
Acceptance test recults ge neluded in plant modifications and post-maintenance-test results a attached to Work Request &
Authorization Forms (trouble ck ts) when it is determined that tests are required. Operations QA C re 'ew both packages for completed documentation.
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Inspe.ction, Test,.nd 0 rating Status Operations QA/QC includes in their inspections the review f tags, labels, o other temporary markings used to indicate. completion of r u' ired inspections an te'sts, and operating status to. assure compliance with rocedures.
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Nonconforming I ms'- The' requirements specifi in the Corporate Quality Assurance Man al for nonconforming items are me for fire protection equipment, j)
Correctiv Action - Operations QA/QC assures that pro edures are written-to ensu e that conditions adverse to quality. such as ailures, mal f unc: ion s,
eficiencies, deviations, defective components, u controlled combustible.aterial, and nonconformances are promptly identifie
- reported,
-and.corre 4d.-
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Jt6 cords - Those, records' required to verify compliance with cri eria of the File Protection Program are identifiable and retrievable and are as igne'd rete ion requirements.
1)
' Audits - Audits are performed by the Corporate Quality Assuran,ce Aud &
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9.5.1.3.6 Training L
-Training is an essential ingredient in developin6 and maintaining an effective fire protection program.
Depending on job responsibilities, the intensity of training may range from a short introduction to fire safety to weeks of x
extensive trainin.
Three distinct types of t.aining are provided:
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9.5.1-13 Amendment No. 5
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-13.4 P?l!"> MT ^"DIT FSAK hilod l7,3.3 Jgsc3cmeh_5 The-~ description of plans for conducting re"letic end audits of operating phase activities that are important to' safety.is contained in eetion-614. ""-cir; and-Audit "-of-Plant--Technical--Speoff4 cations-issued-by -[the M uslecr e.eg ul e t ery Commission-as4ppend1*4--to-the-Jae14ity-operatiag-Licenee (".ef erenee 4-h4,M APoseJ chose 12 s
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- Pronosed Chance 13 Section 17.2-is.being deleted in its entirety.
It is replaced-with the attached 17.3.
6
ENCLOSURE 3
' BRUNSWICK STEAM ELECTRIC PLANT UNIT NOS 1 AND 2 QUALITY ASSURANCE PROGRAM DESCRIPTION 1
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- 172. 3-BNP OUALITY ASSURANCE PROGRAM DESCRIPTION 717.3.1-MANAGEMENT
- 17. 3'.1.1 Methodolory It is _ the; policy. of Carolina Power & Light Company (CP&L) to operate and maintain nuclear power plants-without jeopardy to its employees or to the public
. health and safety, U
This Quality Assurance (QA) rrogram and revisions are approved by the Executive Vice President - Power Supply..
The - QA Program and procedures apply toictivities affecting quality.
(e.g.,
j operation, maintenance, modification,.and refueling.) This program applies to 1
individuals and ' organizations-responsible for operating and supporting the nuclear plants.
Tho program and procedures define responsibilities and I
I authorities, prescribe measures for the control and accomplishment of activities for;the operation 'of-safety related, fire protection and radwaste structures, systems, and components and requires appropriate verification of conformance to L established ' requirements. A list or system identifying items and activities to which this program applies is maintained at each nuclear plant or work location.
. Controls!and_ responsibilities for maintaining this list or system are prescribed sin procedures.
This QA, Program and implementing procedures _ shall be used and updated as necessary to assure that the Company's nuclear generating units are managed such that.they_will be operated and maintained in a safe manner.
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DeviAtiens from this program shall be permitted only upon written authority from the Executive:Vice President'- Power Supply.
The 1 QA. Program is - founded-on the principle that. the line organization is responsible. for quality and safety. Self-assessment practices are used to ensure
.the. desired levels of quality and safety are achieved and maintained. There are
< three levels of assessment in CP&L. The first level is the line organization and consists of each individual being involved with plant performance to ensure the plant is operated in a' safe, reliable, and efficient manner.
The second level.
' consists _of the Nuclear Services Department, along with the functional area line
- or6anization,; monitorin5 ' the plant _ operation and processes to - ensure that
._ performance goals are set and achieved for the three nuclear projects..The third levell. consists ofE the Nuclear. Assessment Department (NAD) independently
- evaluatingi he performance and effectiveness of plant _ programs, processes, t
personnel, and the' lins organization's self-assessment. These activities are to detect deficiencies ir. the desired levels of performance and quality, reporting these conditions ' to 5'enior Management, and ensuring adequate action 'is taken to correct-and eliminate ' thes e conditions.
17.3.1-1
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-; s 17.3.1.2 Orranization
<The CP&L_ organization responsible for the safe plant operation is described in
.Section 13.1 of the ~ FSAR _ and' in implementing procedures.
The term "line organization" used in this program refers to the production organization reportin6 to the Senior Vice President - Nuclear Generation Group.
Procurement documents require suppliers to operate in accordance with QA programs which are compatible with the applicable requirements of the CP&L's QA Program and procedures where their services are utilized in support of plant activities.
17.3.1.3 Responsibility i
The primary responsibility for quality performance, ircluding the identification and effective correction of problems potentially affectin5 the safe and reliable operation of _the Company's-nuclear facilities, resides with the line organization.
-The managers of functions involving nuclear fuel, engineering, and operations shall assure that their personnel are adequately trained for their jobs and they have the -experience' and education required to carry out their assigned responsibilities.
These managers shall ensure that adequate resources and procedures are available 'for ' correctly implementing the work activities to support this program.
Independent - inspections - are conducted to verify specific critical quality attributes.
Individuals performing these inspections have access to necessary information to ensure that activities and equipment meet esta'olished acceptance criteria.
The NAD shall independently monitor and assess the Company's nuclear programs on a continuing basis. The NAD performs assessments which incorporate the previous "QA audits".
These evaluations are performance based with emphasis on quality of the end product.
. The Manager - NAD shall review with the senior operating officer in the Company s on. a regular periodic basis the overall effectiveness-of the Company's ' QA
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Program..He shall hsve access to the corporate management up to and including _
the President / Chief Executive Officer to resolve any quality or nuclear safety related concerns' if the concerns cannot he. resolved satisfactorily at a lower, management level.
The results and effectiveness of the assessment organization and processes in accomplishing its assigned objectives will be regularly _ evaluated.
-m 17.3.1-2
'.c 17.3.1.4-Authority
/The program and procedures require that the authority and duties of persons and
- organizations performing activities affecting quality - functions be clearly established and-delineated in writing and that these individuals and
! organizations have sufficient authority and organizational freedom to:
)
-a)
= Identify. quality,~ nuclear safety, and performance problems.
)
i b)~
-Order unsatisfactory work to be stopped and control further processing, I
delivery, or installation of nonconforming material.
c)
Initiate, recommend, or provide solutions for conditions adverse' to
- quality, d)
Verify implementation of solutions.
17.3.1,5 Personnel Traininn and Oualification
.Both.on site and'off-site personnel within the CP&L organization and contract personnel, who perform activities affecting quality (implement elements of the QA Program) shall be-indoctrinated and trained such that they are knowledgeable
=and capable of performin5 their assigned tasks.
Trainin5 programs-andLreviews ensure that proficiency of personnel performing activities: affecting quality is -achieved and maintained by training (formal & -
OJT) examining, and/or certifying, as appropriate.
Personnel training and qualification records are to be maintained by responsible management to ensure' qualified individuals are assigned to activities affecting quality.
Personnel within the Operating-~ organization performing duties of a licensed operator are indoctrinated, trained, and qualified as required by 10CFR55.
17.3,1.6 Corrective' Action laus. primary goal ~ of.the CP&L corrective action 1 program is to. improve overall plant operations. and performance by identifying and correcting root causes of
' equipment and human performance problems. Part of this effort is directed toward encouraging individuals to voluntarily report events, near misses, and potential problems. It 'is: the policy of CP&L to seek improvement in each nuclear plant's
~
performance.as well as in the, performance of supporting departments.
Management will emphasizeito.611 levels in the organization the importance of identifying and effectively corroc*ing situations that can adversely affect human and equipment performance. An important aspect of this program is the assignment of qualified personnel to accurately evaluate equipment / human performance problems,Jimplement appropriate corrective actions, and verify corrective action adequacy.
17.3.1-3
o Management is responsible for fostering a positive environment that encourages the self-identification of adverse conditions and trends.
The program requires that an evaluation of adverse conditions such as conditions adverse to quality, nonconformances, failures, malfunctions, deficiencies, deviacions, and defective material and equipment is conducted to determine need for corrective action.
Conditions adverse to quality are identified through inspections, assessments, tests, checks, and review of documents.
The program requires corrective action to be initiated to preclude recurrence of significant conditions adverse to quality.
Procedures require follow-up reviews, verifications, inspections, etc., to be conducted to verify proper implementation of corrective action and to close out I
the corrective action documentation.
The program outlines the methodology for resolution of disputes involving quality and nuclear safety. issues arising from a difference of opinion between ident' ying personnel and other groups.
Significant conditions adverse to quality are reported to appropriate management for review and evaluation.
Periodic review and evaluation of adverse trends are performed by management.
17.3.1.7 Rerulatory Commitments The operation of nuclear plants shall be accomplished in accordance with the U.S.
Nuclear Regulatory Commission (NRC) Regulations specified in Title 10 of the U.S.
Code of Federal Regulations.
The operation of the Company's nuclear power plants shall be in accordance with the terms and conditions of the facility operating license issusd by the NRC.
The program and procedures are designed to ensure compliance with the NRC Regulatory Guides and ANS1 Standards applicable to the operations phase, and to which BNP is committed.
The commitment to comply or alternatives for CP&L to
-follow are presented in Section 1.8 in this FSAR. Where ever the requirements of this section conflict with the commitments to regulatory guides and codes and standards, the requirements of this section shall govern.
The Nuclear Regulatory Commission shall be notified of changes to the QA Program description in accordance with 10CFR50.54(a)(3).
17.3.1-4 l
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17'3.2 PERFORMANCE / VERIFICATION u
417,3.2.1 Methodolorv
' Personnel performing work activities are responsible for achieving the acceptable level-of quality.
Personnel performing verification activities are responsible for verifying the achievement of acceptable quality.
- Work is. accomplished and verified using instructions, procedures, or appropriate Lmeans that are of a detail commensurate with the activity's complexity and importance to safety.
Criteria that define acceptable quality at specified in procedures and/or other.
documents, and verification, when required is performed against these criteria.
17.3,'2.2 Desien Control Procedures define requirements for the control of design activities associated with modifications of items that are safety-related.
Design changes are subject to appropriate controls which were applicable to the original design. CP&L may designate an organization to make design changes other than the organization which prepared the original design. In any case, CP&L will assure that the organization has access to pertinent background information, including an adequate understanding of - the requirements' and intent of the original design,: and that the organization has demonstrated competence in applicable design' areas.
Care shall be taken to assure that the design selected to accomplish a necessary or desirable change does not create "new" problems - in off-normal modes of
- operation or in adjacent inter-tied systems.
Design changes _mado;to the plant are accomplished in a planned and controlled manner in accordance with written, approved procedures. These procedures include l provisions, as necessary, to ensure that:
a)_
Design documents' (such as specifications, drawings, procedures and instructions) reflect applicable regulatory, performance, quality, and jquality.-_ verification requirements and design bases.
These documents are checked _ for accuracy: - and _ completeness-by qualified individuals and reviewed _ to assure that documents are prepared-in accordance with procedures.
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b)
There _is adequate review of the suitability of materials, parts, equipment,. and processes which_ are essential to lthe safety-related functions of structures, systems, and components.
c)
Materials, parts, and equipment which are commercial grade items or which have been previously approved for a different application are evaluated for suitability prior to selection.
17.3.2-1
d)
Design documerts and procedures.are controlled to reflect de61gn modifications and "as-built" conditions.
N e)
Internal and external design interfaces between organizations participating. in modification activities are adequately defined and controlled,~ including the review, approval, release, and distribution of design documents and revisions.
The above controls are applied as necessary to such aspects of design as reactor physics; seismic, stress, thermal, hydraulic, radiation, and accident analyses; compatibility of materials; and accessibility for inservice inspection, maintenance, and repair.
Any errors or deficiencies found in the design process or the design itself are documented and corrected, as outlined in the applicable department's corrective action program procedures.
Following completion of the design change / modification, controlled design change information is made available to affected personnel.
Training, on design changes / modifications _ that affect the operation of the plant,
.is provided to affected plant operating personnel.
17.3.2.3 Desien Verification Procedures require that the adequacy of design changes be verified by the performance of design reviews, alternate calculations, or qualification testing.
The control measures specified in the plan for control of design verification activities are as follows:
a)
Personnel responsible for design verification do not include the original designer or the designer's - immediate supe rvisor unless the immediate supervisor is the only one capable of verifying the design.
b)-
Procedures identify the positions or organizations responsible for design verification and define their authority and responsibility.
Procedures also provide guidelines as to the method of design verification ' to be used. Unless otherwise specified, design verification is performed by the method of independent design reviews and includes verification that SAR commitments have been addressed.
c)
-Qualification tests, or analyses when appropriate, shall assure that all modes of operation are not adversely affected by the design change.
~
d).
Design changes are reviewed to assure that design parameters are defined and that inspection and test criteria are identified, e)
Design verification is completed. prior to relying upon the component, system or structure to perform its function.
17.3.2-2
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'3 i-e 17.3.2.4L frocurement Centrol'l vProcedures define _ requirements for the control _- of procurement doc.iments and ensure that purchased material and services are of acceptable quali cy, Potential contractors and suppliers are evaluated by Vendor and Equipment Quality Unit personnel prior to award of a procurement document when needed to assure the contractor's or supplier's capability to comply with applicable tochnical and quality requirements.
Carolina Power & Light Company -maintains a program for - supplier evaluation.
-results of supplier evaluation, surveillance of suppliers, supplier furnished records, certificates of conformance, effectiveness of supplier quality control, and the purchase of spare or replacement ~ parts.
L Procurement documents, such as purchase specifications, contain or reference the l
'following; a).
= Technical, fadministrative, regulatory, and reporting requirements, including material and component identification requirements, drawings, specifications, -codes and : industrial standards, test and inspection requirements, and special process instructions.
b)
Identification irf Lthe documentation to be ' prepared, maintained, or submitted: (as - applicable) to CP&L for review and approval.
These documents l mayz; include,-
as necessary, inspection ' and : test records, qualification' records, or_ code required documentation.
c) 7 Identification ~of thon records to be retained, controlled, and maintained by the supplier, : and. those delivered to the purchaser prior to use - or installation of the hardware.
? Receipt inspections are. performed-by qualified inspectors in accordance:with
_ procedures.to assure <that:
a)
Materials, equipment, or_ components are properly identified and' correspond with associated-documentation.
.b)-
- Inspection-- records or -_ certificates of conformance-attesting to the
' acceptance of materials, equipment,'and componenta are completed and are available. prior to installation or use.
~
c)
Materials, equipment, and components are inspected and judged acceptable in accordance with predetermined inspection. instructions prior to installation or use, d)
Items :not meeting. applicable _ requirements are clearly identified and
-controlled until1 proper. disposition is made.
17.3.2-3 1
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- Appropriate' controls and provisions have _been included in procurement procedures 6
forf selection,- determination (ofi suitability for the intended use, evaluation; Dreceipt.and quality evaluation _ of commercial grade items to ensure that these m
items will perfora satisfactorily in service.
17.3.2.51 Procurement Verification
. Carolina Powar & Light - Company procurement documents. ara prepared, reviewed, approved. -and controlled in accordance with procedures to assure that requirements.are correctly stated, inspectable, verifiable, cad controllable, and there are ' adequate acceptance / rejection criteria.
=4 reviewed 1 by: personnel. knowledgeable in applicable. technical and quality requirements, and documentary _ evidence of that review and approval is retained Land available-for verification.
-17.3.2.6 Identification and Control of items c
Procedures - require. spare or replacement partr. 'to be subject to QA program controls, codes and' standards, and technical requirements which ensure they are suitable for their intended' service.
'. Items accepted or released are-identified as to their inspection status prict to forwarding them to_ a controlled storage area.or releasing them for installation or further work.
(Bulk items will not require individual accept tags; however, status of unacceptable bulk items will be so indicated).
Procedures. require' that ; materials, parts, and components. be identified and c controlled to prevent _the use of incorrect-or defective items. These procedures f also require that identification of items be maintained either on the item in a sanner that does not affect the function or quality of the item, or on records traceable.to the~ item.
' Procedures' implementing these requirements provide-for the following:
a)
Verification-that items received at the plant are properly identified and -
can be-traced to the. appropriate ; documentation,- such as Ldrawings, specifications, -purchase. orders, manufacturing and inspection documents, nonconformance reports,.or-material test reports.
- b);
Verification of item identification consistent with the CP&L inventory contro1' system and traceable to: documentation which identifies the proper usesior applications of the item.
! Consumables utilized in safety-related structures, systems tid components are N
subject to appropriate. controls as described in procedures.
17.3.2-4
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g; WProceduresTde' fine requirements for-the control! of the~ handling, storage, and 4
? shipping'of-safety-related ' items. These procedures requiro measures to be taken
> toJ ensuren spectall-- handling, : storage,. ' cleaning, -_- packaging. shipping,' tand a
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f preservation frequirements iare: established ' to control-these activities in.
L iaccordance with de_ sign and Lspecification: requirements to preclude: dainage,11oss ;
J or; deterioration _by: environmental conditions:such as' temperature or humidity.-
- Provisionsiare established.to control the shelf; life and storage of chemicals, 2
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N (reagents;ilubricants - and other consumable materials.
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I Test Control-N Procedures:definetrequirements for: tert programs when required and require that iltems be tested to dmenstrate that.they will perform satisfactorily in service.
. j eModifications, repairs,:and replacements are accomplished in accordance with the
~~
.originalLdesign and-testing requirements or acceptable alternatives.
Testiprocedures. incorporate or reference the following, as required:
1a)?
iInstructions and prerequisites for performing =the test, b)1 Use of proper test' equipment, r
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(c).
.Mandatoryfinspection hold points,
- d)7
' Acceptance criteria-
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iTest results are documented,- evaluated. and their acceptebility determined by a (qualified,0 responsible" individual or group, y
Whenithe acceptancelcriterialis'not met.faffectedJareastare to be retested or f' evaluated,J:asiappropriate.
-17.3.2.9'
?Measurine and Test Enuloment-Control-(Proceduresiddfine ; requirements for the' control of measuring andg test equipment
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tused; These proceduresi include ! requirements to establish procedures for the v
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" ; calibration 1l technique and frequency,; maintenance,- and control'of measuring'and-
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. Inspections 1and test devices are. selected to assure accurate measurement (i.e.
to V ove rc ome1 inh e re nt. l inac cura c ie s associated' with. onvironment,. human error,3
' equipment,.etc.)1 Measuringsand test iequipmentL 1(M&TE). is identified and traceable to :the (calibration test data.
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t iMeasuring ; and. test ' instruments ' are-calibrated at. specified intervals.(or immediately before ' and after. use) based upon one or more of the following:
fa)
Technical-Specifications; b)
Required; accuracy.
c)
Intended use.
.d)~
Frequency of usage.
e)
Stability characteristics.
- 3.
f)
Other conditions affecting measurement.
g)-
' Manufacturer!s recommendations.
-Portable measuring and test equipment are calibrated by standards at least four times'as'accar;.te_.as:the-portable. measuring and test equipment., unless limited by the state of the art.
e
' Status of-calibration for measuring and test equipment is provided.through the
. use f of tags,. stickers. labels, routing cards, computer programs, or other
- suitable means.. The status-indicators indicate the date recalibration is due or the frequency of recalibration.
. Special tools such as torque wrenches, calipers, and micrometers are calibrated to bezat least as accurate as the application (s) for which it is used, using
standr.rds which are-at least as accurate as the special tool being calibrated-.
Insta11edfmeasuring and test instruments are calibrated by instruments at least asJaccurate as the installed, unless limited by the' state of the art.
- Reference.and transfer ~ standards are
- traceable to nationally recognized
' standards;i or where national standards do' not exist, provisions are established
.to document the basis for the calibration.
Measures are - required to be taken and documented to determine the validity of previous-inspections and test results,zif.the measuring and test equipment is found to be out of calibration.
117.3'.2.10 : Inspection. Test. and overatine status
. Procedures define requirements. for the - - identification and control of the inspection.1 test, and operating status of safety-related structures, systems, and,
- components.
-These. procedures: include the application, removal, and verification of inspection and welding stamps', or other status indicators as. appropriate.
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' Heasures are _ established for in'dicating the operating status of structures, systems. and" components..These measures include the use of checklists, computer sprograms, ' logs, stickers, tags, labels,. record cards, and test records to
- indicate "the ~ acceptable operating status of installed equipment.
Installed equipment which, if. operated, could cause damage to other equipment / systems or to; personnel is_ tagged - to indicate its non-operational status and to prevent
-inadvertent use.
Selected plant proceduras and subsequent revisions receive separate technical
. review to-ensure required inspections, tests, and other critical operations are included.
-Altering the sequence of required tests, inspections, _and safety-related
-. operations can only be accomplished by methods outlined in procedures.
' 17.3.2.11~
Snecial Process Control Procedures define requirements for the control of special processes, such as welding, heat-treating, and nondestructive examination.
- Procedures' require that-special processes be performed by qualified personnel using proper equipment and in accordance with written qualified proceduros.
These personnel and procedures are to be qualified in accordance with applicable codes, standards,' and specifications as _ described in procedures, Qualification records of special process procedures and personnel performing special processes are maintained'and available for verification.
17.3.2.12L Inspection Procedures _' define requirements for an inspection program to verify conformance to. performance and quality. requirements specified for those activities and services.
Inspections 1 are performed.by personnel who are not directly responsible for performing or supervising the activity being inspected. Inspection personnel are qualified in accordance _ with<' applicable _ codes and standards, and their
_ qualifications and certifications are maintained current.
Inspections are performed in accordance with procedures or other documents which
-provide for'the following:
a)'
' Identification of individuals or groups responsible for performing the inspections.
b)I Identification of characteristics and activities to be inspected.
c)
Acceptance criteria.
d)
LInspection techniques e)
Recording the results of the inspection, review of the results, ano
. identification of_the inspector.
17.3.2-7
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f)
Indirect control by monitoring of processing methods, equipment, and
. personnel when direct inspection is not possible.
/
Procedures identify inspection holdpoints, beyond which work may not proceed until inspected.
When acceptance criteria are not met, the condition will be documented in accordance with the applicable department's corrective action program procedures and reinspected or evaluated, as appropriate.
17.3.2.13 Corrective Action Procedures define requirements for a corrective action program that charges personnel working at or supporting the nuclear plants with the responsibility to identify adverse conditions (including conditions adverse to quality).
Procedures include requirements for verification of the acceptability of the rework / repair of items by reinspection and/or testing in accordance with the original inspection or test requirements or by an accepted alternative inspection and testing method.
Conditions that require rework / repairs are identified through the use of maintenance work request forms.
17.3.2.14 Control of Documents Procedures define requirements for the development, review, approval, issue, use, revision, and control of documents. These procedures define the scope of which documents are to be controlled.
Procedures require the identification of those individuals or organizations responsible for reviewing, approving, and issuing documents and revisions thereto.
Changes to documents are reviewed and -' approved by the same organization that performed the original review and approval or by other designated qualified responsible organizations.
Controlled documents are to be available at the Incation where the activity will be performed prior to commencing the work, except in a radioactive contaminated area where the documents will be readily available.
A document control system has been established to identify the current revision number of instructions, procedures, specifications, and drawings.
Superseded documents are controlled to prevent inadvertent use.
17.3.2-8 1
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117.3.2.15 Records The program requires that sufficient records be maintained to provide _ documentary evidence.of the quality of items and the accomplishment of activities affecting.
quality.
ProceduresJdefine requirements for the identification, collection, and-storage of quality assurance records.
Records are identifiable and retrievable through the use of indexes and. filing
- systems, which are required by the program.
Procedures are required to be developed to indicate responsibilities and retention periods.
Records are? maintained within-structures designed to prevent destruction, deterioration or theft. These facilities ensure protection against destruction s
by fire, flooding,- theft, and deterioration by the environmental conditions of temperature and humidity.
17.3.2-9 l-
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17.3.3-
- ASSESSMENT il7. 3. 3.1 --
Methodolory e
The~ overall1 objective atc CP&L is to encourage ' ownership,. involvement, and v
- dedication.by.each.' individual supporting the Nuclear Program..This involves continually and aggressively looking for ways to improve the overall performance and safety at each plant. This approach of identifying and correcting conditions early, requires' active support by management and employees.
A process _of assessment is an attitude by personnel ' that the CP&L Nuclear
- Program is improving on a continual basis. This process, along with an effective corrective. ' action ' program, ensures. that conditions are identified - early, corrected promptly and effectively before becoming si nificant quality or safety 6
problems.
' Personnel responsible for carrying out the assessment functions, including safety committee activities, nuclear safety reviews, verifications, self-assessment and independent assessments, are cognizant of day-to-day activities, events, and have necessary experience to-act in a management advisory function, Assessment activities are accomplished using processes or procedures of a detail
- needed to accomplish the function based on complexity and importance to safety.
' Th. managers of functions that support the Nuclear Program are responsible for
- em..tring that self-assessment activities and processes are implemented within their functions on fa continuing basis.
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17.3.3.2 Self-Assessment-L
/It is the management expectation that individuals and organizations self assess their end - product.
-Adverse conditions identified during self-assessment activities 1are reported and. resolved in accordance with the coro.tive action program.
'Line Orranization
' Each individual, work ' group, and manager should be alert and open for areas that may need-improvement.
Members of; the line c,anization are.ch rged with the responsibility to continually evaluate their activities and use each opportunity to achieve higher standards of. quality and improved performance.
Planned and periodic self-assessment activities focus on how well the integrated L:
quality assurance program is working and is to identify conditions that hinder the organization from achieving its safety, quality, and performance goals and standards.
Nuclear Services Department The Nuclear Services Department shall monitor specific functional areas, along with the line organization management, to determine that the desired levels of performance are being. achieved.
Individuals assigned these duties shall work with each nuclear' project to-improve implementation' of CP&L's Nuclear Programs and processes to support safe and reliable operation.
17.3.3.3 Independent Assessment The Nuclear Assessment Department (NAD) is responsible for conducting independent assessments of functions and activities affecting the nuclear programs at CP&L.
Organization 1 Personnelf performing independent assessment, activities ' are organizationally independent of the. function / area being assessed and generally have no direct responsibilities in the area being assessed.
However, on an exception aasis,
- personnelfin the NAD may provide assistance to the line organization by participating in ad' hoc committees or analyzing specific technical issues, if such assistance is deemed to lus in the overall best interest of safety and is
~ approved.by NAD management.
= Selection of assessment personnel is based on experience,and/or training that establishes that their qualifications are commensurate with the complexity or special nature of the area being assessed.
The process for qualification of
- personnel to perform and lead assessments is established in procedures.
Personnel performing assessments shall have access to records, procedures, and personnel to gather data, 17.3.3-2
1":: '
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Assessment Process / Elements
, A primary objective of the NAD is to assess the effectiveness of the line organization's self-assessment processes.
The assessment process includes gathering data, analyzing data, focusing on selected issues and identifying deficiencies to desired performance. The results of assessments are communicated to management in a manner that causes action to correct deficiencies and develop action to prevent recurrence. In addition, this process should evaluate corrective measures adopted to eliminate the deficiencies identified.
Data is gathered using performance based techniques during:
' Observations of work setivities, o
-o Interviews, Reviews of documents to gather information (including the use of NRC, INFO, o
and other agency evaluations),
o Review of self assessment data and reports (performance indicators, trend reports, etc.)
Nuclear Safety' Review activities, o
4 Team assessments (functional, site / department, corporate),
o o Analysis of plant. data and reports (including adverse condition reports, etc.)'
~
Planning ' activities identify. the organizations to be evaluated. the i-characteristics - to be focused on during ' the assessment, and the applicable
. acceptance criteria.~ Assessment activities are selected with flexibility based on various= factors. These factors include but are not limited to:
importance to safety and reliability', NAD-. assessments of site work activities, time since last assessment,' plant management perspective, outside agency audits, and problem
. areas identified from industry and CP&L experience.
Preparatiog activities - may. include a review of performance data, relevant documentation, : previcus. assessment. data, industry experience, team. member experience, and management input. These activities. enable the team to focus on l
. significant-issues which may bcpact safety and reliability when analyzing data,
. Assessments are scheduled on the basis of the status and safety importance of the o
activities.or-processes being performed. 'The schedule is flexible and dynamic to. allow assessment to be' changed depending on plant conditions, events, or issues raised by_ Senior management.
17.3 3-3
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Functions / areas to be assessed include:
/o Plunt Operations o Maintenance o Radiological Controls o Chemistry o Environmental Monitoring o -Engineerin6/ Technical Support o-Fire Protection o Security o Emergency Preparedness o Nuclear Fuel o Outage Management Other functions / areas requested by Senior Management o
Assessments'of these functions / areas may include portions of:
Conformance to provisions contained within tbs Technical Specifications and o
applicable license conditions o Operating experience
-o Procedures o Training and qualifications o Support activities o Corrective actitna Other activities d-tered necessary to assure adequate performance o
Results Adverse conditions are reported in accordance with the applicable department's corrective action program procedure or by formal correspondence between responsible levels of management.
Independent assessment results are communicated to line management to allow for timely action to address potential problems or recognize strengths and superior performance.
documeEted and reviewed with management
' Independent assessment results are personnel responsible.for the areas assessed.
Results of assessments, special investigations, and analysis of data will be provided to the Nuclear Assessment Department (NAD) Man 1gement for review.
A summation of assessment perspective, along with potential issues and recommendations shall be presented to the Executive Vice President - Power Supply and Senior ' Vice President - Nuclear Generation Group on an approximately bimonthly frequency.
Follow-up is accomplished to assure that corrective action is taken as a result of the assessment and that deficient areas are reassessed, when necessary, to verify implementation of adequate corrective actions.
17.3.3-4 s
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