ML20108D385
| ML20108D385 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/05/1985 |
| From: | Jens W DETROIT EDISON CO. |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20108D387 | List: |
| References | |
| NE-85-0339, NE-85-339, NUDOCS 8503080347 | |
| Download: ML20108D385 (4) | |
Text
,
,. +-
Wayne H. ens Wo PrescWit Nuclear Operatxms Ed.f' on "erm&2 i
F 6400 North Dme Heghway is
= = "-"
mrch s 1985 NE-85-0339 Director of Nuclear Reactor Regulation Attention:
Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing it. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Youngblood:
References (1)
Fermi 2 NRC Docket No. 50-341 j
(2)
Detroit Edison letter to NRC-Region III, "FSAR Changes Relative to the Nuclear l
Safety Review Group", EF2-72792, dated September 12, 1984
Subject:
Clarifications of Operational QA Progran This letter documents information discussed with Mr. John W. Gilray of the NRC-NRR staff in telephone conver-
~,
sations on February 27 and March 5, 1985.
The conversations i
addressed the following two issues:
- 1) status of the NRR i
review of Reference 2; and 2) operation of equipment under conditional release.
Both issues are fully discussed below.
NSRG Review Scope
'l Reference 2 transmitted to Region III a proposed revision to the Fermi 2 Final Safety Analysis Report which dealt with a the off-site review committee identified as the Nuclear Safety Review Group (NSRG).
Edison had transmitted these 1
changes in compliance with 10CFR50.55(f).
In the. subject-i telecon, Mr. Gilray indicated that a letter transmitting i
this information to NRC-NRR for review only (in lieu of review and approval) is all that is required per the regula-I tions for NTOL facilities.
Therefore, Edison is providing Reference 2 for your information as Enclosure 1 to this letter.
Accordingly, Edison will proceed with implementing the reference (2) change in practice and in the FSAR unless we hear from you to the contrary.
\\
N&
yo
t i
l Mr. B.LJ. Youngblood 3'
March,5,-1985' NE-85-0339 Page 2 f'
Conditional ~ Releases A revision to FSAR~ Chapter 17.2.7 dealing with the _ condition-i al-releases of equipment was discussed with Mr. Gilray.
As
. reflected in FSAR Section 17.2.7, the conditional release process allows for the installation and testing of condition-
. ally released items, but does not allow the items to be.
placed into a system declared operable 1until the-releaseLis cleared (i.e.,
the documentation-lacking is received and-accepted.from the. vendor).. As reflected in the-draft FSAR change in Enclosure 2, the FSAR.is being revisedin a forth-coming _ amendment to allow an' item that has been conditional-ly released to be placed into a system declared operable if
~
1 Edison provides a documented technical evaluation including a safety evaluation, in lieu of or supplemental to vendor documents.
The safety evaluation criteria which must be satisfied are in accordance with the criteria.of 10CFR50.59.
This procedure cannot be'used for relief from Edison commit-ments to equiprent qualification in accordance 'with the requirements of 10CFR50.49.
Technical evaluations and 10CFR50.59 safety evaluations are performed in( Detroit l
Edison Nuclear. Engineering personnel using approved proce-dures.
Support from other internal or external' consulting i
organizat' ions i's used when necessary.
Detroit-Edison has been the architect / engineer for Fermi 2 and its engineers are qualified to perform these. evaluations.
Personnel per-forming the evaluation shall. be technically competent.in the disciplines appropriate to the evaluation-
. The procedures require the safety evaluations be; approved byLa cognizant-
~
engineering supervisor.
The Technical Specifications require, in addition, that if'it affects nuclear safety'the proposed action be reviewed Iz( the Onsite Review Organiza-l tion prior to placing the. item into a system declared' opera-j ble and be reviewed independently after-the-fact under;the cognizance of the Nuclear Safety Review Group.
Includedias Enclosure.(3) is a copy of the Nuclear Engineering. procedure for performing safety evaluations.
For those situations where a conditional. release is dispositioned in.the-manner' described above, a.
nonconformance document 'will be' ~ initiated to track the dispositioning process.
.The nonconformance document will specifically1 delineate.and refere'nce th'e technical basis and -
safety. evaluation.for. allowing the item to be placed into.a system declared operable.. In addition, nonconformance i
documents must;be approvedJ byc Nuclear Quality Assurance prior 1to im'plementation of dispositionjdecisions.-
L l
l-m.
Mr.
B. J. Youngblood March 5, 1985 NE-85-0339 Page 3 Conditional _ releases and the noncomformance documents (Devia-tion / Event Reports-DERs) are tracked on status reports which are distributed to Nuclear Operations management.
The proce-dure that will be written to combine together the various parts of the. process, i.e.,
conditional releases, DERs and safety evaluations-will be approved ~ by the' Manager-Nuclear Operationi; Accordingly, Edison will proceed to implement the above change as per our discussion unless we hear from you to the contrary.
Please direct any questions to Mr. O.
K.
Earle at (313) 586-4211.
Sincerely,
[
3ct fM4 cc:
(* with enclosures)
()
Mr.
P.
M.
Byron
- Mr. M.
D. Lynch
- Mr.
J.
W.
Gilray*
Mr. F. C. Hawkins (Region III)*
USNRC, Document Control Desk Washington, DC 20555 3
, - Edison to NRC Letter EF2-72792, Dated September 11, 1984 i
Coyn, M. Jens
..e
%cePs, M m..
5' 1
-Delrof,t '
- L,,,,,,,,
i d3 w.5m u.m.o.,i me
-%st pia m ino September 12, 1984 EF2-72,792 If Mr. James C. Keppler Regional Administrator Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Dear Mr. Keppler
Reference:
Fermi 2 NRC Docket No. 50-341
Subject:
FSAR Changes Relative to the Nuclear Safety Review Group Pursuant to 10CFR50.55(C), approval is requested to make two changes which would reduce stated or implied commitme'nts to the Quallity Assurance program description in the FSAR.
(
Both changes deal with the off-site review committee desig-nated the Nuclear Safety Review Group (NSRG).
The changes are as follows:
1.
FSAR Section 17.2.15 Description (See attached marked-up)
REMOVE LAST SENTENCE OF FIRST PARAGRAPH l
This change removes the implied requirement that the Nuclear Safety Review Group (NSRG) approval of l
proposed corrective action is required for noncon-l forming material considered to be a significant condition adverse to quality.
Rationale:
The NSRG is not structured to operate in such an inline fashion.
There are no NRC or standards requirements (Fermi 2 Technical Specifications; IOCFR50 Appendix B, ANSI N18.7-1976) that NSRG approval be obtained prior to implementing corrective actions except if an unreviewed safety question or Technical Specification revision is (1
involved.
Section 17.2.16 of S${GC W O100 W' i
Mr. Jamac G. Ksppler
~
Scptembsr 12, 1984 EF2-72,792 Pega 2
(
a the Fermi 2 FSAR, which deals with corrective action, already provides that corrective actions for significant conditions adverse to qp' lity be documented and reported to the NSRG chai~rnan as well e.s to the Superintendent - Nuclear I
Production.
2.
FSAR Section 17.2.15 Description (See attached mark-up FSAR page 17.2-28):
AT THE END OF THE LAST SENTENCE REPLACE "...and the NSRG for their review and assessment" WITH "for his review and assessment" This change removes the requirement that NSRG review all trend analysis reports generated by QA.
Rationales While the NSRG would likely review any such report of significance, as well as some of the base docu-ments such as audit and inspection reports, it
,([
should not be burdened with another all inclusive specific review requiremant adding to an already lengthy list.
This specific review requirement does not appear in 10CFR50 Appendix B, the Fermi 2 Technical Specifications or in the related standard, ANSI N18.7-1976.
Neither of these changes is considered to reduce the effectiveness of the Quality Assurance program.
Your prompt review and approval is requested.
Please direct any questions to Mr. O. Keener Earle at l
313-586-4211.
Sincerely,
\\
wd b*
47 cc Mr. P. M. Byron
- Mr. F. Hawkins*
Mr. M. D. Lynch
- USNRC, Document Control Desk
- Washington, D. C. 20555
- With Attachment
(
i
c earuvemo Correctiva action will be proposed by technically qualified l
crganizations and approved by supervisory parconnel having re-sponsibility for the nonconforming item.
If th acncenferm:nce _
is cencid : d te bc : eignificant ecaditien :dver::
t the p5epc: d :::::ctiv; ::tica vill 21:
te quality, l
05: ::vieu:d by it:
N6Aes 56 copies of completed nonconformance documents a're maintained in t
the plant files.
The acceptability of rework, repair, or replacement of mate-l 35 rials, parts, components, systems, and structures is verified by inspecting and testing the item for conformance with its original requirements or acceptable alternatives.
tion and test records are documented and become part of' theThe inspec-QA records for the item.
The Nuclear QA Department periodically analyzes quality data obtained from various reports,"such as nonconformance documents, inspection reports, and audit 56 The analysis is reported to the Sureports, to determine what qu trends exist.
l Nuclear Production 7:nd the MORC 'cr-their ::vic; :perintendent -
nd ::::::::::.
17.2.16
. Corrective Action
~
Measures are established to ensure that conditions adverse to quality, such as failures, malfunctions, deficiencies, devia-i tions, defective material and equipment, and nonconformances 1
are promptly identified and corrected.
i In the case of a sig-nificant condition adverse to quality, procedures require that the cause be determi preclude recurrence,ned and corrective action be taken to and that the significant condition, its cause, and the corrective action be documented and reported to the Superintendent - Nuclear Production and the N3RG chair-man.
The Nuclear QA Department reviews all nonconformance documents to determine whether the cause of the problem has been 56 identified and adequate action initiated.
The Superintendent -
Nuclear Production is notified of conditions requiring further action.
The OA requirements in procurement documents or con-l tracts require the vendor or contractor not only to identify j
material or parts that do not conform to the procurement require-i ments, but also to determine and correct the causes for the
'nonconformances.
35 When vendors furnish products that do not conform to the re-quirements of the applicable purchase contract, the Nuclear when appropriate.QA Department conducts a reappraisal of the vendor's QA pr Results of the reappraisal, together with a request for specific corrective actions, are transmitted to l
the vendor.
If the vendor does not products as requested, the Nuclear QA Department maimprove his QA program and 56 ], vendor removed from the list of approved suppliers.y have the I
17.2-23 Amendment 56 - April 1984
-w
- - FSAR Revision to Section 17.2.7 t
i i
EF 2-FSAR
' Tho plant section honda and suparvicore cro responsible for verifying that the correct revisions of necessary documents 35
.[
are available before work is begun.
The Nuclear QA Department
(
will independently conduct surveillance and audits of proce-dures, drawings, and other documents to verify that only up-to-date revisions are being used.
TheSupervisorofInformationSystemsisresponsiblefbrmain-taining and making available a document control system that identifies the current revision of procedures, specifications, 35 1
drawings, procurement documents, and other such quality-related documents.
The Nuclear QA Department independently conducts the surveillance and audits of procedures, drawings, and other documents to verify that only up-to-date revisions are being used.
The requirements for retaining and storing the quality-related documentation required above and other historical records are described in Subsection 17.2.17.
17.2.7 Control of Purchased Material, Equipment, and Services The Vice President - Nuclear Operations approves the placement of. contracts based on the analysis and recommendations of the support organizations.
The evaluation,of the QA capabilities 35 of such vendors and contractors is the responsibility of the Nuclear QA Department.
Two types of QA evaluation of a contractor or vendor are possi-(
ble.
Either or both may be used ai appropriate to the level 1
of quality required.
They are as follows:
a.
Desk Review - Evaluation of contractor or vendor QA capabilities accomplished by the review of pertinent information submitted by the contractor or vendor; quality history records of previous performance; or documented review of audit reports by other utilities, CASE Register, or other similar methods 35 b.
FacilitX Evaluation - Evaluation of a vendor's OA iisp'abflitTis56dducted at his tacility, including-- l35 1.
Preaward evaluation of vendor QA system and implementation 2.
Preaward surveillance of vendor products, proc-essing,"or service and related documentation in accordance with requirements of the applicable purchase contract 3.
Inprocess evaluations A notice of evaluation results is transmitted to the contractor or vendor by the Nuclear Procurement section of the Nuclear 35 56 Administration Department.
After evaluation, the approved a
1
)
FOR h PD 69 Mt PsAiL CHAME6 17.2-17 Amendment 56 - April 1984 o rd TH6 PAG 6 C
^
_ l*
EF 2-FSAR courceo are placsd on c current liot'of approved suppliors.
j 56 Additions and deletions to the list are submitted by the Nuclear QA Department.
(_)
t 35 To ensure that material and equipment fabrication is in accord-ance with procurement requirements, the Nuclear OA Department directs the surveillance of vendor activities, which includes witnessing significant fabrication check points, validitjl of vendpr-supplied documentation, and overall vendor performance as' appropriate to the purchased item.
The surveillance activ-ities are accomplished in accordance with approved vendor audit and inspection procedures.
After receipt and before the stcrage of a material, part, or component, inspection is accomplished by qualified personnel as necessary to ensure that the material, equipment, or service is adequately identified and complies with the specifications i
delineated in the associated procorement documents.
These i
inspections and subsequent identification of status are per-formed in accordance with material receiving and inspection procedures.
Documentation of the inspection will be made using a receiving inspection report.
A necessary condition for acceptance is the receipt of the QA records identified in the procurement documents verifying that the specified quality requirements have been met.
Documentation identifying any other procurement requirements that have not been satis-fied must be provided by the supplier.
An item is considered i
nonconforming until Lufficient quality documentation has been
~~~
(
provided.
The receivind'inspiction procedures permit the con-fl ditional release of material lacking the specified QA records, provided the item can be readily removed if necessary.
Func-35 tional testing may be performed on materials installed under l
conditional release; however, these materials are not to be placed in servica.
(
L hvssnr subsequent to a satisfactory inspection, the receiving inspec-tion report and required documentation of tests, certificates of conformance, and other specified requirements are retained to provido documontary eviduneo of compliancu.
If a nonconform-ing item is found during the inspection, the item is retained in a hold area pending resolution.
The procurement of spare or replacement parts for structures, systems, and components important to safety is subject to CA program controls, codes, and standards and to technical require-ments equal to or better than the original technical require-ments as necessary to preclude the repetition of defects.
17.2.8 Identification and control of Materials, Parts, and components 35l Saf'ety-related materials (including consumables), parts, and components (including partially fabricated subassemblies) are identified in a manner that allows traceability to the docu-
)
mentation that verifies the acceptability of the items to the 17.2-18 Amendment 56 - April 1984
INSERT Unless a technical evaluation has been performed and documented via a safety evaluation angest in accordance with both 10 CFR 50.59 and approved procedures.
(
t 9
i l
\\
.