ML20151C332
| ML20151C332 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 03/29/1988 |
| From: | Anuje A BALTIMORE GAS & ELECTRIC CO. |
| To: | Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151C335 | List: |
| References | |
| NUDOCS 8804120336 | |
| Download: ML20151C332 (10) | |
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BALTIMORE GAS AND ELECTRIC CHARLES CENTER. P.O. BOX 1475 BALTIMORE, MARYLAND 21203 OUALITY ASSURANCE & STAFF SERVICES DEPARTMENT tsT."Ja%'# %s7'** "
March 29, 1988 Dr. P. K. Eapen Chief, Special Task Program Section U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406
Dear Dr. Eapen:
Enclosed is the information on the changes to QA program description submitted to the NRC in the Annual Update of the FSAR on August 28., 1987.
This information is being sent to you based on our telephone discussion on March 16,19_87W i 9i3 '
Also enclosed is a latest copy of our QA policy (QA program description).
I am adding your name to the controlled distribution list to receive all future changes to the QA policy, unless you indicate to us that you do not wish to receive these changes.
Please let me know if you have any questions.
Very truly yours, A. B. Anu].e Supervisor Quality Audits Unit (301) 260-4919 ABA:dh
Enclosures:
1.
Description of Changes 2.
QA Policy, Rev. 15 cc:
D. C. Trimble, NRC (w/ Enclosure 1)
J. A. Tiernan (w/ Enclosure 1)
R. M. Douglass (w/ Enclosure 1)
J. T. Carroll (w/ Enclosure 1)
W. P. McCaughey, Jr. (w/ Enclosure 1) k 8804120336 880329 3
DR ADOCK 05000317 i
DCD I
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PRF-0 No. 623 Before:
There was no discussion on issuing procurement specification to suppliers not having formal QA Programs.
(Both on pg. 1B-16 and 1B-21).
After:
Pace 1B-16 Procurement specifications may be issued to suppliers not having formal QA programs only when the quality requirements to be implemented are indicated in the procurement document and BG&E conducts surveillance of the supplier's performance.
1 Paae 1B-21 3.
Any suppliers recognized as being capable of suppling the service or product, but not having a formal QA program, may be utilized when the necessary controls to be implemented are clearly indicated in the procurement specification and surveillance is conducted on the supplier's performance.
Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 623, has been reviewed to determine if the proposed change would reduce BG&E's commitments described in the QA Policy (FSAR Section 18).
PRF-Q No. 623, proposed change to Paragraph 2.6, does not reduce BG&E's commitments described in the QA Policy because:
1.
Change is a clarification of method used to exercise control of supplit.r performance.
2.
Specific QA Program requirements are incorporated into procurement documents to ensure that adequate controls are clearly documented.
i 3.
Surveillance of supplier's performance ensures that supplier's activity adequately satisfies the requirements for the item or service being purchased.
\\
PRF-0 No. 632 Before:
Paae 18-18 QAPs are developed by one of the departments responsible for the subject activities.
Each procedure is given a technical review by a member of one these departments and a quality assurance review by a member of the QASD.
Each is approved by the Manager, QASD, and by the managers of departments to which responsibility is assigned or which are affected by the procedure.
After:
Paae 1B-19 QAPs are developed by one of the departments responsible for the subject activities.
Each procedure is given a compliance review by a member of the QASD, and technical review by a member of one of the responsible departments.
Each QAP is approved by all department managers who have responsibilities for activities governed by the QA program.
The QAP is then signed by the Manager of QASD.
Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 632, has been reviewed to determine if the proposed change would reduce BG&E's commitments described in the QA Policy (FSAR Section 18).
PRF-Q No. 632, proposed change to delete the requirement for a separate Quality Assurance Review when a Quality Assurance Procedure (QAP) is revised does not reduce BG&E's commitments described in the QA Policy because:
1.
When a Compliance Review is performed by Quality Assurance Personnel it is required that Quality Assurance requirements be reviewed.
2.
QAP revisions are sent to the Manager, Quality Assurance and Staff Services and to all department manager whose activities are controlled by the Quality Assurance Program for their approval.
PRF-0 No. 647 Before:
Pace 18-41 Resoonse-A Personnel of BG&E's QASD, NMD, and N00, who perform inspections, examinatine, and tests at the plant site during operational phases of the nuclear power plant are required to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
All other BG&E personnel who perform inspection, examination, and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.
Pace 18-42 Reason-A 2.
Some testing activities conducted during normal operation of the plant, such as surveillance testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.3 of ANSI N18.1 for technicians.
Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such testing.
After:
Paae 18-41 Resconse-A Personnel of BG&E's Quality Control Organizations within the QASD, NMD, and N0D, who perform inspections, examinations, and tests at the plant site during operational phases of the nuclear power plant are required to be qualified in accordance with Regulatory Guide 1.58 (which endorses ANSI N45.2.6).
All other BG&E personnel who perform inspection, examination, and testing functions associated with normal operations of the plant are qualified either to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) or to ANSI N18.1 - 1971.
Paae 18-42 Reason-A 2.
Some testing activities conducted during normal operation of the plant, such as surveillance testing, do not require that test personnel meet the requirements specified in Paragraph 4.5.2 of ANSI N18.1 for technicians.
Personnel qualified to Regulatory Guide 1.58 (which endorses ANSI N45.2.6) are adequately qualified to conduct such testing.
Page 2 of 2 PRF-0 No. 647 Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 647, has been reviewed to determine if the proposed change would reduce BG&E's commitments described in the QA Policy (FSAR, Section IB).
PRF-Q No. 647 proposed change does not reduce BG&E's commitments described in the QA Policy because:
1.
The proposed change will reinstate the reference to Quality Control personnel in the first sentence of Response-A to ANSI N45.2.6 (p. 18-41, Rev. 5).
The reference was omitted when the Policy was rewritten to reflect the organization of the Nuclear Energy Division.
2.
The proposed change will correct a typo in Reason-A.2 (p. 18-42, Rev. 4).
Paragraph 4.5.2 of ANSI N18.1 should be referenced instead of 4.5.3.
I i
PRF-0 No. 649 Before:
Pace 18-12 Alterations to the Operating License, including TSs, the FSAR, and the Emergency Response Plan (ERP), are subject to the same controls as are alternations to changes, tests, and experiments defined in 10 CFR 50.59.
After:
Paae 18-12 Alterations to the Operating License, including TSs and the FSAR, are subject to the same controls as are alterations to changes, tests, and experiments defined in 10 CFR 50.59.
Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 649, has been reviewed to determine if the proposed change would reduce BG&E's commitments described in the QA Policy (FSAR Section 18).
PRF-Q No. 649, proposed change does not reduce BG&E's commitments described in the QA Policy because:
1.
10 CFR 50.59 pertains to changes, tests, and experiments of equipment important to safety that may constitute an unreviewed i
safety question.
2.
Alteration to the Emergency Response Plan are subject to the following controls:
a.
Changes to the Emergency Response Plan and Implementing Procedures are submitted to the Plant Operations and Safety Review Committee for approval and reviewed by the Emergency Response Screening Subcommittee of the Off-Site Safety Review Committee.
j b.
10 CFR 50, Appendix E, requires any changes to the Emergency i
Plan or Procedures to be submitted to the appropriate NRC Regional Office.
c.
10 CFR 50.54 requires the NRC to approve changes to the Emergency Response Plan if the change decreases the effectiveness of the program.
A
4 PRF-0 No. 658 Before:
Pace 18-21' Purchase orders placed by BG&E personnel for SR and designated NSR items or services controlled by procurement specifications are not placed with a supplier unless documents sent to PMMD with the specification indicate that the supplier has been investigated as follows and found to have a satisfactory program or record:
i After:
Paae 1B-21 Purchase orders placed by BG&E personnel for SR and designated NSR items or services controlled by procurement specifications are not normally placed with a supplier unless documents sent to PMMO with the specification indicate that the supplier has been investigated as follows and found to have a satisfactory program or record.
- However, when required by operational considerations, an order may be placed prior to supplier approval; however, the approval of the supplier as follows must be completed prior to the installation /use of the item or service.
i Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 658 has been reviewed to dutermine if the proposed change would reduce BG&E commitments described in the QA Policy (FSAR Section 18).
PRF-Q No. 658, proposed change to Section 18.7, does not reduce BG&E's commitments described in the QA Policy because:
(
ANSI N45.2.13, "Quality Assurance Requirements for Control of I
Procurement of Equipment, Materials and Services for Nuclear j
Power Plants," requires the selection of suppliers be based on their capability to provide an item or service in accordance with the requirements of the procurement documents.
As long as the approval process is complete prior to the installation /use of the item or service, the intent of the standard is complied with.
a
PRF-0 No. 664 Before:
Paae 1B-10 ANSI N45.2.13 - QA Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants; Draft 2, Rev. 2, (10/73)
Pace 1B-50 There was no discussion on exception to the guidance in ANSI N45.2.13.
After:
Paae 1B-10 ANSI N45.2.13 QA Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants; Draft 2, Rev. 2, (10/73)***
Note:
- is defined as follows:
- BG&E takes exception to guidance offered and states alternatives.
Pace 1B-50 ANSI N45.2.13-1973 Reouirement ANSI N45.2.13 could be interpreted to mean that all requirements of this standard are applicable to all safety-related items or services.
Resoonse BG&E has four main approaches for safety-related and designated nonsafety-related procurement as described in Sections 18.4 and 18.7 (Specification Method, Verification Method, Catalog Method, and Commercial Quality Method).
Controls established for specification method correspond to the requirements of ANSI N45.2.13.
The extent to which the individual requirements of ANSI N45.2.13 are applied to other methods of purchase depends on the nature and scope of the work to be performed and the importance to nuclear safety cf the items or services purchased.
This approach is consistent with the introductory discussion in Section 1.3 of ANSI N45.2.13 - 1973.
Page 2 of 2 PRF-0 No. 664 Evaluation:
As required by 10 CFR 50.54, PRF-Q No. 664, has been reviewed to determine if the proposed change would reduce BG&E's commitments described in the QA Policy (FSAR Section 18).
PRF-Q No. 664, proposed change to Table 18-1, does not reduce BG&E's commitments described in the QA Policy because:
It states precisely the procurement methods utilized by BG&E which are described in the body of the QA Policy and are consistent with the requirements referenced in ANSI N45.2.13, "QA Requirements for Control of Procurement of Equipment, Materials and Services for Nuclear Power Plants," Draft 2, Rev.
2 (10/73).
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EDITORIAL CHANGES Paae IB-i Add Appendix 18 title 18-111 Lists page revision numbers 18-2 Add Manager, FESD to list of persons responsible for the principal elements of BG&E's QA Program (already included in text on page 18-6) 18-21 Abbreviate Quality Assurance (QA)
Figure 1B-2 Delete Fossil Quality Programs Unit from QASD organization chart