ML20140C926
| ML20140C926 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 05/30/1997 |
| From: | Kuehn G TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C301-97-2017, NUDOCS 9706100136 | |
| Download: ML20140C926 (8) | |
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GPU Nuclear,inc.
A Route 441 South NUCLEAR Post office Box 480 Middletown, PA 17057-0480 Tel 717-944 7621 C301-97-2017 -
May 30,1997 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C 20555 Gentlemen:
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Subject:
Saxton Nuclear Experimental Corporation Facility Operating License No. DPR-4 Docket No. 50-146 SNEC Facility Response to the Request for Additional Information Regarding j
the Quality Assurance Program 4
Enclosed are the responses to the April 24,1997 Request for Additional Information regarding questions resulting from review of the SNEC Decommissioning Quality Assurance Program.
Sincerely,
. A. Kuehn e Present WK 9706100136 970530 PDR ADOCK 05000146 1
P PDR WGH 0000W li b hyl Attachment i
cc: Administrator, NRC Region I-Hubert Miller NRC Project Manager, NRR-Alexander Adams d
NRC Project Scientist, Region I-Thomas Dragoun ll!!!,!!!!!!,fllllllllllflf.!ll
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1.
Please address what the ex oectations are regarding how management will regularly review l
the status and adequacy of that part of the quality assurance program (QAP) which they j
are executing. The QAP plan should incorporate these expectations.
Response The first paragraph of section 3.1 of the QAP plan states in part,"The term
' Program' as used herein includes this Plan and the approved documents which are used to implement this Plan. This Plan is implemented through such approved documents."
Section 7.4 in discussing document control for procedures within the scope of this plan states in part, "These procedures shall be reviewed by a technically competent person other than the preparer, and shall be approved by a management member of the organization responsible for the prescribed activity." This management approval of procedures implementing the QAP plan for activities for which they are responsible is the mechanism for management's review of the implementation of the QAP plan. The QAP plan section 2.3, " Functional QA Responsibilities", delineates the areas of QA.P plan implementation required for senior level management.
Section 2.2 of the QAP plan states in part that the assurance that the QAP plan is effectively implemented relies on those who have no direct responsibility for managing or performing the activity. Since the dedicated management organization at the SNEC facility is relatively small, self assessment is difTicult to implement with the level of independence required by the QAP. The Radiation Safety Committee (RSC) provides a j
level of oversight with members both internal and external to GPU Nuclear, and the monitorings and audits of the Nuclear Safety Assessment (NSA) stafTprovide oversight internal to GPU Nuclear. These oversight groups both regularly supply SNEC facility management with information concerning the adequacy and status of program implementation.
No revision to the QAP is required to ensure that management understands the expectations for their review of program status and adequacy.
2.
The section entitled Procedures and Drawings (4.1-4.3) and Document Control (7.1-7.5) both omit references to the word " instructions" Will "instnuctions" be used to control work activities? Ifinstructions are used, the QAP should be modified accordingly.
Response Section 4.3, " Procedures and Drawings", of the QAP states in part, "A procedure shall be implemented to control and delineate the requirements for the review and approval of documents implementing the requirements of this plan. These documents typically include, but are not limited to, those termed plans, procedures, instructions, drawings, and specifications." Instructions, such as Station Work Instructions, will be utilized at the SNEC facility. They will be implemented and controlled by a procedure as required by QAP section 4.3. The controlling procedure implements the requirements of the QAP, and compliance to the requirements of the procedure ensures compliance to the QAP. The process is similar to that controlling Radiation Work Permits. They are also controlled by a higher tier procedure. The implementation ofinstructions at the SNEC facility without a controlling procedure would be a noncompliance to the QAP.
C301-97-2017 Page 2 of 7 Section 7.0, " Document Control", of the QAP supplies the controls for the implementing procedure to ensure the content, review, approval and control of the procedure complies with the requirements of the QAP.
No revision to the QAP is required to ensure the proper control ofinstructions.
3.
The QAP Section 12.1 " Test Control" reflects the following requirements; testing to assure satisfactory performance in service; testing performed using test procedures written to design documents; and proof tests as appropriate.
However, the following items were noted to be absent: procedural assurance that prerequisites were met; assurance of adequate test instrumentation; test performance under suitable conditions; and test documentation and evaluation.
Please discuss how these items are addressed for activities such as heavy lifting, and installation and operation of the radiation monitoring and air filtering systems, and modify the QAP accordingly.
Response We concur that these attributes are required for the Test Program however, Section 12.0, " Test Control", supplies the requirements which are unique for the SNEC facility test program. It was not the intent of this section of the QAP to repeat requirements which are contained in other sections of the QAP.
The last paragraph of section 3.2.2 of the QAP states, " Activities affecting quality shall be accomplished under suitable controlled conditions. Controlled conditions include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied." Section 4.2 of the QAP states, " Procedures and drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished." Since testing is an activity within the scope of the QAP as defined in the second paragraph of section 3.2.2 of the plan, the aforementioned requirements and controls apply to the test program. The examples in the question of heavy lifling, and installation and operation of radiation monitoring and air filtering system would be controlled by maintenance, modification, and operating procedures which would also need to comply with above requirements since those activities are also within the scope of the QAP.
No modifications to the QAP are required to ensure the proper control of the test program.
4.
The section entitled Quality Assurance Records (18.1-18.7) did not address QAP requirements to generate inspection records that would identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted. Please address whether these are relevant inspection attributes and modify the QAP accordingly.
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f Response GPU Nuclear agrees the attributes referenced in Question 4 are relevant, and should be addressed in the QAP. The following change will be incorporated in revision 1 of the QAP if the proposed change is acceptable to the NRC:
18.1 Suflicient records shall be maintained to furnish evidence of activities affecting quality (e.g. inspection reports, receipt inspection documents, engineering evaluations, monitoring reports etc.). These records shall document, when applicable, the identification of the individual generating the document or the data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
5.
Please discuss what standards will be utilized to implement the QAP and identify them in the QAP accordingly.
Response The following text will be incorporated as Appendix A in revision 1 of the QAP if the proposed change is acceptable to the NRC:
DEGREE OF REG. GUIDE ANSI STD.
COMPLIANCE REMARIG l.58 9/80, Qualifications of Nuclear N45.2.6 1978 Modified See Rev.1 Power Plant Inspection, attached Examination and Testing comments Personnel 1.88 10/76, Collection Storage and N45.2.9 1974 Modified See Rev.2 Maintenance of Nuclear attached Power Plant Quality comments Assurance Records 1.123 7/77, QA Requirements for N45.2.13 1976 Modified See Rev.1 Installation, Inspection attached and Testing of comments Mechanical Equipment and Systems.
1.144 1/79 Requirements for N45.2.12 1977 Modified See Auditing of Quality attached Assurance Programs for comments Nuclear Power Plants 1.146 8/80 Qualification of Quality N45.2.23 1978 Full Comply Assurance Program with Auditors for Nuclear Regulatory Power Plants Position.
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C301-97-2017 Attachment i Page 4 of 7
[b NRC Regulatory Guide 1.58. Rev.1. September 1980 Oualifications of Nuclear Power Plant Inspection. Examination. and Testing Personnel The SNEC Facility Decommissioning Quality Assurance Program complies with this guide with the following clarification:
1.
The guidance of Regulatory Guide 1.58 shall be followed as it pertains to the qualifications ofinspection personnel who verify conformance of work activities to quality requirements. The qualification of other GPU Nuclear personnel shall be in accordance with GPU Nuclear established requirements.
No operational requirements of Regulatory Guide 1.58 will be implemented due to the cessation of operation and defueled status of the SNU' Facility.
The qualification of nondestructive testing personnel shall be in accordance with the requirements and recommendations of ASNT Recommended Practice No. SNT-TC-l A,1980, Edition. In addition, SNT-TC-1 A shall be used in conjunction with the additional provisions of t9e applicable ASME Boiler and Pressure Vessel Code.
Later editions of SNT-TC-1 A may be utilized as referenced in Section XI of the Code provided that the edition of the Code has been incorporated by reference into Title 10 of the Code of Federal Regulations, Part 50.55a.
I Recertification of NDE Level III personnel shall be at an interval of every 5 years as noted by ASME Code Case N-341 and N356 rather than the 3 year interval recommended by SNT-TC-1 A,1980.
Qualification and subsequent requalification of personnel conducting visual examination activ. ties within the scope of the applicable ASME Section XI edition shall be performed consistent with that applicable ASME Section XI edition as fu.ther permitted and accepted by ASME Section XI Code Cases associated with qualification in visual examination endorsed by the curreni ravision of Regulatory Guide 1.147.
2.
Not all personnel who:
A.
Reviewed and approved inspection and testing procedures, B.
Evaluate the adequacy of activities to accomplish the inspection and test i
objectives, C.
Evaluate the adequacy of specific programs used to train and test inspection l
and test personnel, l
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l D.
Certify Level III individuals in specific categories or classes, will be certified as meeting the Level III capability requirements of ANSI N45.2.6-f 1978. Rather these personnel will be determined by management through evaluation 4
j' of their education, experience, and training to be fully qualified and competent to perform these functions. The basis for the determination will be documented.
[b NRC Regulatory Guide 1.88. Rev. 2. October.1976
'i Collection. Storage. and Maintenance of Nuclear Power Plant Availability Assurance Records
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GPU Nuclear will comply with the intent of this regulatory guide by compliance with the
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j requirements of ANSI /ASME NQA-1-1979, Supplement 17S and Appendix 17A-1 including l
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Appendix 17-1, NQA-1 A-1981.
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NRC Regulatory Guide 1.123. Rev.1. July 1977 f
Ib Ouality Assurance Requirements for Control of Procurement ofItems and Services for Nuclear Power Plants
'l The SNEC Facility Decommissioning Quality Assurance Program complies with this guide
' dth the following clarification:
1.
Section C.3. A corrective action system may, depending upon complexity and/or importance to safety of the item or service provided, be imposed upon the supplier.
When a corrective action is imposed on a supplier, the applicable elements of Section 9.0 of the standard will be included and its implementation will be verified.
2.
Section C.4. Applicable information concerning the method (s) of acceptance of an item or service will be made available to receiving inspection personnel.
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3.
Section 4.2a of ANSI N45.2.13-1976. When evaluation of a supplier is based solely on historical supplier data, these data will primarily include records that have been accumulated in connection with previous procurement actions. Data that includes experience of users ofidentical or similar products of the prospective supplier and product operating experience will be used if available.
4.
Section 4.2 of ANSI N45.2.13-1976. In the special case of " commercial grade _
i items" the supplier does not have to be evaluated by one of the methods identified; however, the procurement documents shall contain requirements specific to the item being procured.
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C301-97-2017 Attachment I l
Page 6 of 7 5.
Section 7.5. As a point of clarification, personnel who perform the audit (s) as described in Section 19.0 of this Plan will not be qualified in accordance with ANSI
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N45.2.0 Such personnel are qualified in accordance with Regulatory Guide 1.146, j
dated 8/80.
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6.
Section 10.2d of ANSI N45.2.13-1976. The requirements of this section are
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interpreted as follows: The person attesting to a certificate shall be an authorized and responsible employee of the supplier and shall be identified by the supplier.
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Section 10.2.1, Verification of the Validity of Supplier Certificates and the Effectiveness of the Certification System, is as follows: The verification of the
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validity of supplier certificates and the effectiveness of the certification are i
accomplished as an integral part of the total supplier control and product acceptance l
program, and no separate GPU Nuclear system exists that addresses itself solely to such verification. The degree of verification required will depend upon the type of item or service and their safety importance. The means ofverification may include source witness / hold points, source audits, and document reviews; independent inspections at the time of material receipt; user tests on selected commodities, such
_ as concrete components; and tests after installation on selected components and systems. All of these means verify whether or not a supplier has fulfilled j
procurement document requirements and whether or not a certification system is i
effective.
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fb NRC Regulatory Guide 1.144. January 1979 4-Auditing of Ouality Assurance Programs for Nuclear Power Plants GPU Nuclear is in basic agreement with the position set forth in the Regulatory Guide subject to the following comments:
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1.
Section C.3a (1) and C.3a(2) i i
The frequency of performance and minimal topical coverage ofinternal audits will be i
consistent with the plant technical specifications.
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2.
Section C.3.b(1) j i
Source surveillance will be utilized in lieu of or in addition to receipt inspection. As permitted, external audits of such procurement actions will typically not be scheduled.
3.
Section C3.b(2)
Exteinal audits of selected suppliers of services which are within the scope of this Plan will be scheduled and conducted at least once within the life of the activity or every three years.
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An annual evaluation of suppliers ofitems and services will be conducted. These evaluations will be conducted utilizing the results of source surveillance, source inspection, receipt inspection and/or audits; and, other factors. These evaluations will determine the need to conduct audits of suppliers ofitems, parts or materials; or, 1
increase the frequency of conducting audits of suppliers of services.
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As discussed in a weekly teleconference with the NRC, to address questions regarding the
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requirement for the NRC to review future changes to the QAP plan, and their approval of changes which are considered to be a reduction in commitment, the following will be added to the end of the last paragraph of section 3.1:
Revisions to this plan will be submitted to the NRC: prior to the implementation of changes which involve a reduction in commitments previously accepted by the NRC and after implementation of changes having no reduction in commitment.
This requirement is similar to those located in the proposed Technical Specifications section 3.6.2.4.
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