ML20155H393
| ML20155H393 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 11/02/1998 |
| From: | Wigginton D NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9811100113 | |
| Download: ML20155H393 (55) | |
Text
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LICENSEE: Entergy Operations, Inc. November 2, 1998 FACILITIES: Arkansas Nuclear One, Grand Gulf, River Bend, and Waterford I
SUBJECT:
SUMMARY
OF MEETING HELD ON OCTOBER 7,1998, TO DISCUSS l REVIEW STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL On October 7,1998, the staff met with representatives from Entergy Operations, Inc. to discuss the status of review of the standard quality assurance manual for all the Entergy sites. The list of meeting attendees is attached as Attachment 1 l
The meeting attendees discussed the status of review and specific review questions by using i the Entergy QAPM Review Matrix dated October 8,1998,in Attachment 2. A number of the questions were closed with acceptable responses by the licensee. The matrix will be updated to indicate those closed and with new questions as the staff's review continues. The revised matrix will be used to focus the final review.
ORIGINAL SIGNED BY:
David L. Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV ;
Office of Nuclear Reactor Regulation Docket Nos. 50-313,50-368,50-416,50-458,50-382 Attachments: As stated cc w/atts: See next page
- DISTRIBUTION
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} NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enana anni
- November 2, 1998 i
LICENSEE: Entergy Operations, Inc.
FACILITIES: Arkansas Nuclear One, Grand Gulf, River Bend, and Waterford
SUBJECT:
SUMMARY
OF MEETING HELD ON OCTOBER 7,1998, TO DISCUSS REVIEW STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL On October 7,1998, the staff met with representatives from Entergy Operations, Inc. to discuss the status of review of the standard quality assurance manual for all the Entergy sites. The list of meeting attendees is attached as Attachment 1.
The meeting attendees discussed the status of review and specific review questions by using the Entergy QAPM Review Matrix dated October 8,1998, in Attachment 2. A number of the questions were closed with acceptable responses by the licensee. The matrix will be updated to indicate those closed and with new questions as the staff's review continues. The revised matrix will be used to focus the final review.
e David gginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/lV Office of Nuclear Reactor Regulation Docket Nos. 50-313,50-368,50-416,50-458,50-382 Attachments: As stated cc w/atts: See next page
i l.
Entergy Operations, Inc. Arkansas Nuclear One, Units 1 & 2 cc:
Executive Vice President Vice President, Operations Support
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 Director, Division of Radiation Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Mr. C. Randy Hutchinson Vice President Operations, ANO Entergy Operations, Inc.
Winston & Strawn 1448 S. R. 333 1400 L Street, N.W. Russellville, AR 72801 Washington, DC 20005-3502 Manager, Rockville Nuclear Licensing Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident inspector U.S. Nuclear Regulatory Commission P. O. Box 310 London, AR 72847 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801
1 o
! Entergy Operations, Inc. Grand Gulf Nuclear Station i
1 cc:
Executive Vice President General Manager, GGNS
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 756 P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Governor Resources State of Mississippi P. O. Box 10385 Jackson, MS 39201 Jackson, MS 39209 Attomey General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi P. O. Box 339 P. O. Box 22947 Port Gibson, MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support U.S. Nuclear Regulatory Commission Entergy Operations, Inc.
611 Ryan Plaza Drive, Suite 1000 P.O Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident inspector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs P. O. Box 399 Entergy Operations, Inc.
Port Gibson, MS 39150 P.O. Box 756 Port Gibson, MS 39150 Mr. William A. Eaton Vice President, Operations GGNS Entergy Operations, Inc.
P. O. Box 756 Port Gibson, MS 39150
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0 Entergy Operations, Inc. River Bend Station cc:
( Winston & Strawn Executive Vice President and 1400 L Street, N.W. Chief Operating Officer Washington, DC 20005-3502 Entergy Operations, Inc.
P. O. Box 31995 Manager- Licensing Jackson, MS 39286 Entergy Operations, Inc.
River Bend Station General Manager- Plant Operations l
P. O. Box 220 Entergy Operations, Inc.
St. Francisville, LA 70775 River Bend Station P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 P. O. Box 1050 St. Francisville, LA 70775 Director- Nuclear Safety Entergy Operations, Inc.
President of West Feliciana River Bend Station Police Jury - P. O. Box 220 P. O. Box 1921 St. Francisville, LA 70775 St. Francisville, LA 70775 ,
Vice President - Operations Support Regional Administrator, Region IV Entergy Operations, Inc.
U.S. Nuclear Regulatory Commission P. O. Box 31995 611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 Arlington, TX 76011 Attorney General Ms. H. Anne Plettinger State of Louisiana 3456 Villa Rose Drive P. O. Box 94095 Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 Administrator . Wise, Carter, Child & Caraway Louisiana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205 Baton Rouge, LA 70884-2135 Mr. Randall K. Edington Vice President - Operations Entergy Operations, Inc.
River Bend Station P.O. Box 220 St. Francisville, LA 70775
l Entergy Operations, Inc. Waterford 3 cc:
Administrator Regional Administrator, Region IV Loulslana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884 2135 Arlington, TX 73011 Vice President, Operations Resident inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc. Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parish Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnville, LA 70057 Entergy Operations, Inc. .
P. O. Box B Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 Jackson, MS 39205 Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc. One American Place, Suite 1630 P.O.BoxB Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Vice President Operations '
Entergy Operations, Inc. Entergy Operations, Inc.
P. O. Box B P.O.BoxB Killona, LA 70066 Killona, LA 70066
'Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502
ENTERGY OPERATIONS. INC.
STANDARD QUALITY ASSURANCE PLAN )
l MEETING ON OCTOBER 7.1998: ATTENDEES l
W. Haass NRR, HQMB R. Smith NRR, HQMB D. Wigginton NRR, DRPW l B. Ford Entergy ,
C. Wells Entergy '
D. Wagner Entergy W. G. Kuppstein First Energy L. Spessard NRR,DRCH J. Arildsen NRR,DRCH R. Gramm NRR,DRCH ATTACHMENT 1
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_ Entergy QAPM review matrix _
Number Comment ." ; z Closed? Subadt? !
Q-1 The statement in QAPM A.1.c that "The requwements of the QAPM The statement in A.1.c is moddied to clanly that it is the CLOSED- Yes are applied to these items and actmtuss to an extent commensurate method ofimplementaten of the requwements of the with their importance to safety" and sanitar statements in other ' QAPM that changes dependmg on the safety referenced Standards could be rrusappled and result in " shah" significabon of the item or actMty and not the commitments inappropnately bypassed without the appropnate review requirements of the QAPM. ,
process.
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A.1.c The methods of ' . ,_' _ _ ofthe t' requwements of the QAPM are commensurale with the item's or activity's importance to safety.
8/27/98 Meetmg Staff indicated that they would go back and docuss.
Proposed words seemed to be acceptable and that the g concept was i x:luded in Appendix B and the endorsed U ANSI Standards Q-2 Need to clanfy the duties and reportmg for+vnid::Ja of any Ime The proposed QAPM currently has the followmg Yes organization QA funchonal rum;---E = The specific concem was requwements related to the dubes and responsitulities i related to the QC type funcbons. of personnel performmg the QC and the QA manager's ,
relabonship Sechon B.12.a (p.15); it appears that line organizabon personnel ,
perform inspections; not clear. QC ge1 -
If the line vivoia.aun personnel perform the inspechons, how is A.6.a independence maintained between doers and verifiers? Does the it is the responsitMisty of each indmdual to promptly QAPM meet A.2.b of SRP 17.37 idenbfy and repost conditions adverse to quakty.
Management at aN levels encourages the identwicason i of condibons that are adverse to quality .
B.12.a and N18.7 Sechon 5.2.17 The inspechon program may be implemented by or for the organization performing the activity to be inspected.
inspechons are performed by quahlied personnel other than those who performed or directly supervised the '
work being inspected B.12.d
- ,, inspechon results are to be documented by the i
O inspector and reviewed by quahfied personnel.
E rn z N18.7 Sechon 5.2.17 I The owner orgaruzation shaN evaluate anspechon I " results. Records shaN be kept in sufficier't detail:o Revision dated 10/08/98 I
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Entergy QAPM review matrix Number Comment Response Closed? Submit?
permit adequate confirmation of the inspechon program. B Deviation, their cause, and any correchve action completed or planned as a re* ult of the deviations shall be documented.
QA Manager A.2.d.1 The manager responsible for quality assurance has overall authority and responsibility for establishing, controlling, and venfying the implementation and adequacy of the quality assurance program as described in this QAPM.
C.1.c Personnel performing audits have no direct responsibilities in the area they are assessing.
N18.7 Section 4.5 Those performing audits may be members of the audited organization; however, they shall not audit activities for which they have immediate responsibility.
While performing the audit, they shall not report to a management representative who has immediate responsibility for the activity being audited.
Conclusion As evidenced by the guidance of ANSI N18.7, the regulatory intent of the funchonal relationship between the QC funchon and the QA management is to allow the QC function to be implemented by the line organiza: ion, the results documented, and the QA funchon (with independence) to audit the QC function performance. These sections of ANSI N18.7 were endorsed without exception in RG 1.33 R2. The proposed QAPM correctly reflects this intent without changes.
An editorial change associated with respect to this item is to add a cross reference to RG 1.33 in QAPM B.12 B.12.f Additional details conceming inspecbons may Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
be found in the Regulatory Guides and associated Standards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guide 1.33).
8/27/98 Meeting The Staff provided a conceptual functional organization chart which showed a special reporting relationship between personnel performing the QC function and the QA Manager. EOl indicated that as discussed above they do not feel that this special reporting relationship is necessary. Staff will consider the information provided.
Post 8/27/98 meeting in response to a later question and RG 1.58 to this insert. Newinsert:
B.12.g Additional details concerning inspections may be found in the Regulatory Guides and associated Standards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guides 1.33 and 1.58).
Although not required by the ANSI Standard consistent with the GGNS requirements the following will be added to the QAPM. As part of this change delete the last sentence of B.12.a and add it to the proposed new item.
B.12.a A program is established and implemented for inspections of activities in order to verify conformance to the documented instructions, procedures and drawings for accomplishing the activity. The inspechon program may be implemented by or for the organization performing the activity to be inspected. rae*3a==
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B.12.f l Inspections are performed by qualified personnel Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
other than those who performed or directly supervised the work being inspected. While performing the inspection activity the inspectors functionally report to the associated manager responsible for quality assurance or a manager [
responsible for materials, purchasing, and contracts as appropriate.
10/7/98 meeting Discussed the proposed changes. With the prosed ,
changes are acceptable but EOl is to provide information conceming the previous NRC review of the ,
procurement reporting responsibilities.
Q-3 Need to clanfy the duties and reporting responsibilities of any line A licensee's organization description needs to contain CLOSED organization OA functional responsibilities. One method may be a sufficient detail to provide reasonable assurance of funcbonal chart. managernent oversight in the performance of quality assurance responsibilities. Consideration from undue Additional NRC discussion- cost and schedule pressures by the preparation, review, and submittal of unwarranted determinations NRC requirements to demonstrate organizational acceptability- regarding reductions is aan...;Lnont for organizational ,
restructure is essential in today's environment.
The licensee's organization chart needs to demonstrate the QA Manager's freedom from undue cost and schedule pressures in the This assurance and consideration is accomplished by podcnn anc,e of QA responsebelebes by showing appropriate reporting showing only the appropriate reportog lines of authonty lines of authority to upper levels of management. We are also to upper levels of management. This provides a interested in assuring that the QA Manager's ability to focus on QA licensee with the opportunity to focus on matters matters is not excessively diluted by the addition of other non-related essential to safety, thereby providing for the safety of responsibilities. So the organizational chart should also show the full the general public, rather than on organizational make-0nvy;mnent of other functional areas. The chart does not need to up of plant personnel.
include specific titles, but should indicate general titles for each funchonal area; general descriptions of responsibilities for each title Therefore, organization charts should not include box can be delineated in the text. Of particular interest is an specific titles, but rather general titles for each identification of what QA funcbons delineated in the QAPM are functional area, with general desenptions of implemented by what organizational element. These are the general responsibilities for each title box delineated in organizational factors that demonstrate conformance to Appendix B. implementing pmcedures.
- Specific discussions The reporting line of authority is described in QAPM section A2. This section shows the line of authonty from the chief executive officer to the QA manager.
This described line of authority insures that the QA manager has an organizational functional level with a Revision dated 10/08/98
O Entergy QAPM review matrix Number Comment Response Closed? Submit?
high degree of authority by requiring that the QA manager either report directly to the associated VP or at most allows a single level of management between the VP and the QA manager. Having a level of management between the QA manager and the VP has been accepted by the NRC in the past Additiona!!y, QAPM A.2.d.1 states that the QA manager has the authority and responsibility to escalate matters directly to the chief executive officer when needed.
ANSI Standard N18.7 Section 3.4 in the last paragraph provides the NRC accepted guidance conceming other duties of the QA manager position. This standard will continue to be meet under the new plan.
8/27/98 Meeting The Staff provided a conceptual functional organization chart. EOl discussed that they did not feel that the chart was necessary since the applicable controls were in the proposed QAPM. EOl voiced the concem that the inclusion of the chart could result in the real organizational requirements being masked by the other information provided in the chart. Staff will consider the information provided.
Q-4 Table 1 A.1 General Qualification requirements for personnel will RG 1.8 is being used as a place holder in the QAPM meet ANSI /ANS 3.11978 except where exception to ANSI N18.1 (this is very consistent with the RBS requirements Ref.
or to this Standard is identified in the applicable unit's Technical RBS USAR Section 1.8 page 8). RG 1.8 R 1 indorses Specifications. ANSI N18.1 1971 without any clarifications except for the Radiation Protection Manager. Requirements for RG 1.8 R1(1975) does not address ANSt/ANS 3.1 at all. RG 1.8 the Radiation Protection Manager are in each of the R2(1987) does endorse certain portions of 3.1 (1981). W3 has units Technical Specifications and are not being positions where 3.1 (1978) applies and others where 18.1 applies. changed by this proposed QAPM revision. Entergy is GG uses section of the 3.1 (1979) draft plus some of 3.1 1978. More proposing to commit to meet ANS 3.1 1978 except for detail appears to be needed on what is covered under 3.1, what is still specific exceptions identified in the Technical under 18.1, which version of 3.1 should be used, and how the Specifications.
incorporation of TMI Action Plan Requirements which were gradually being incorporated into later versions of 3.1 will be considered when This is a significant increase in commitment for ANO an earlier version of 3.1 is used. Since 3.1 is being used, perhaps and GGNS since ANS 3.11978 has many consideration could be given to the requirements of RG 1.8 R2 (1987) requirements not contained in ANSI 18.1 1971.
as the more appropriate commitment at this time. How will future changes to Tech Spec exceptions to these standards be controlled? Future changes to the TS will be controlled in 50.59? 50.54? Both? accordance with 10 CFR 50.92 which requires prior NRC approval.
Revision dated 10/08/98
Entergy QAPM review rn;trix Number Comment Response Closed? Submit?
Post 8/27/98 meeting 8/27/98 Meeting The general qualification requirements suggested appear different Staff will consider the information provided. Staff from any currently used at any of the facilities and from any other past requested the EOl provide any information available exceptions that I am a' ware of. Therefore I am referring this to the conceming the current requirements including the other QA reviewers and the human factors section for there insights source (e.g., TS amendment). File sent to Staff too. Initial comments seem to be along the line of why not commit to showing requirements currently in QA plan and TS on the current version of the Reg Guide, the current version or currently 8/31.
approved exception for that plant, or something like this?
Post 8/27/98 meeting ANO U2 TS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for (1) the designed radiation protection manager, who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
GGNS TS 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions as modified by Specification 5.22.f. except for the radiation protection manager and the STA, who shall meet or exceed the education and experience requirements of ANSI /ANS 3.1-1981 as endorsed by Regulatory Guide 1.8, Revision 2,1987.
RBS TS 5.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for comparable positions, except for the radiation protection manager who shall meet or exceed the qualifications of Regulatory guide 1.8, September 1975.
W3 TS 6.3.1 Each member of the unit staff sha!! meet or exceed the minimum qualifications of ANSI /ANS 3.1-1978 for comparable positions except that
- a. The Radiation Protection Superintendent shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975.
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o Entergy QAPM review matrix Number Comment - Response Closed? Submit?
- b. Personnel in the Health Physics, Chemistry and Radwaste Departments shall meet or exceed the qualifications of ANSI N18.1-1971.
- c. The licensed Operators and Senior Operators shall also meet or exceed the minimum qualification of 7 10 CFR Part 55.
- d. Personnel in the Nuclear Quality Assurance Department, and other staff personnel who perform inspecbon, examination, and testing functions, shall meet or exceed the minimum qualifications of Regulatory Guide 1.58, Rev.1, September 1980.
(endorses ANSI N45.2.6-1978).
~
Proposed QAPM Qualification requirements for personnel will meet ANSI /ANS 3.1 1978 except where excepton to ANSI N18.1 or to this Standard is identified in the applicable unit's Technical Specifications.
Individuals filling positions who met the previous comrnitment at the time of implementation of this commitment can be considered to meet any more restrictive aspects of the requirements of this commitment for that position without further review and documentation.
Comparison of the proposed change with that previously approved None of the current TS commitment to the RG for as the base requirement. All of them commitment directly to the ANSI standard consistent with the proposed requirement. The proposed commitment matches the current RBS and W3 TS requirements and allows GGNS and ANO to upgrade their commd from ANSI N18.1 1971 to ANS 3.1 1978 as positions are filled in the future.
As an attemate to the proposed requirements, since the Revision dated 10/08/98
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- i Entergy QAPRI review instrix f Number comment m:x t h e? subnet? :
qualifications requwements are in the TS and therefore under NRC control, we could remove the commitments i from the QAPM.
- 10/7/98 meetmg
- Changes appear to be acceptable. EOl to rewsw the !
differences between the 1978 and 1981 versons of I ANS 3.1 for onsite and the off-site safety review I commdtees. If there are not any sagndicant ddlerences
- the item is ==eart_ [
, Q-5 Table 1 A.1 Individuals filNng positions at the time of The main problem with the addden is that many Closed Yes [
implementation of this commitment can be considered to meet possons did not have any qualifications in ANSI 18.1 the requirements of this commitment for that position without 1971. >
fur 1her review and documentation. i What about a change to: !
Include " fully qualified under existmg commdmentf in addmon to !
finns possonc. Does any considershon need to be given here for Individuals fiEng possons at the time of i recertdicahons or profiaency trarung requirement? WW these aR be implementahon of this commdment can be mnsidered [
law new commdments without exceptons? to meet any more restrictive ==pae*= of the i requrements of this commitment for that posibon '
wdhout further review and documentation
[
8/27/98 Moebng [
- i. The foRowmg words were agreed to:
[
Individuals firing poseons who met the previous commitment at the time of implementaten of this
- commstment can be considered to meet any more -
restrictive aspects of the requrements of this l commitment for that posson without further review and l documentabon. 5 Q-6 Table 1 A.2. General The following 7 ^~ E=e may be Sechon 4.1 of ANS 3.1 aRows other factors to be used YES l considered equivalent to a bachelor's degree: in place of degree requirements it provides a list that may be considered. Tfe clardicaten provides the '
- a. 4 years of formal schooHng in science or engineering, speciRc list which wW be apphed. -
b 4 years of applied experience at a riuclear faciNty in the area .
- c. 4 years of operational or technical eW _ mL _ _ ; in _
these requwements are considered equivalent to a nuclear power, or bachelor's degree. This was added to the UFSAR in i
- d. any combinahon of the above totaling 4 years. pre Operahng License Amendment 28 dated 3/79. i N18.1 1971 only idenhfies degree requirements for 2 This is an existing excepton from GG. See L20. possons as requwed.
l Revision dated 10/08/98 f
Entergy QAPM review matrix Number Comment Response Closed? Submit?
- 1) Are all the units' Tech Specs consistent with this? If tech specs 8/27/98 Meeting specify bachelor, is a bachelor degree required rather than this Staff expressed concemed that years of experience option? used to meet the education requirements as allowed by the exception should not be used to meet the NRC current attemate qualification guidance for ISEG requires more Standard's experience requirements.
experience to substitute for a bachelor's, as one example. How is this consistent? What about QA manager? Post 8/27/98 meeting 8/27/98 meeting /27/98 meeting
/27/98 meeting /27/98 meeting
- 3) Do these requirements apply to more than just QA positions? Staff position is consistent with practice. Add the NRC QA staff might have to get other groups involved if so. following to the bottom of clarification.
(licensing, rad protection, etc.), and Years of experience used to meet the education
- 4) When was this exception incorporated? What was the justification? requirements as allowed by this exception shall not be used to also meet the experience requirements.
10/7/98 meeting issue discussed if EOl can change the word 70rma!" to
" post secondary"in item A of the clarification the clarification is acceptable.
Q-7 Table 1 B.3. ANSI N45.2.4 Section 3 Documented routine it's implied by the section it is referencing. CLOSED inspections and audits of the storage area may be performed instead of the requirements of this Section. 8/27/98 meeting Discussed in the meeting issue resolved.
Requirements for initial receipt and storage are covered by another standard. Here only verification that items are in satisfactory condition for installation and have not suffered since initial receipt is being addressed. As such this is basically consistent with the current QAP approved by the NRC for ANO on page T1-10 of its discussion of compliance. "...to assure that stored items are maintainedin a satisfactory condition." might be added to the end as this was included in ANO's discussion, however, this might also already be considered implied based on the context of this section of the standard. See L16.
Q-8 Tabs 1 B.4. ANSI N45.2.4 QAPM Section B.12 will be complied Will remove the clarification. Ct.OSED YES with instead of the Section 5.1 requirements of Section 5.1.1, Section 5.1.2, and the first sentence of Section 5.1.3. 8/27/98 meeting Discussed in the meeting issue resolved.
The GG exception uses its Policy 10.0 " Inspection" to implement the above ANSI requirements. However, Policy 10 as written is more detailed than the new QAPM Sechon B.12 cited above. Moreover, since this was not an exception for the other sites, and since there are even more specific items in the standard than are contained in either the current GG exception or the new QAPM Section B.12, it seems Revision dated 10/08/98
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appropriate to ask why the applicable portons of 5.1 should not be 3 included in addshon to B.127 This seems more appropriate "on the "instead of* wording used above. This also seems to have t%a the intent of the cited GG excephon, as it says
- The inspecbon program ,
will incorporate, as applicable, those items listed in these ,
subsechons " See L20. !
Q-9 Table 1 C.1. Section C.1 Entergy will provide procedures for the W3 Att 6 page 43 item 6. Also, really just a statement CLOSED guide's Appendix A activities as discussed. However Entergy of fact.10 CFR 50.2 provides the definiten of safety '
does not consider all activities iisted to be safety-related" (e.g., related. We consider whatever meets that definition to activities in 7.e). be safety related. >
Did not see the discussen of this one. 8/27/98 meeting Discussed in the meeting issue resolved. l Q-10 Table 1 C. 3. ANSI N18.7 Section 1 Sentences 4 and 5 state, There is not really a difference I was just trying to CLOSED ,
"However, applicable sections of this standard should be used reference back to the actual cmev;;a.y document as they apply to related activities. Activities included are: Design which is the QAP Approval for Radioactive Material Changes, Purchasing, Fabricating " With regard to radioactive Packages. It provides restnchons on the achvibes material transportation activities, Entergy will only implement the Entergy can perform Listing the items in mulbple ;
requirements associated with those activities conducted in documents just adds to the chance that one gets accordance with the applicable NRC Quality Assurance Program changed without the other getting changed A copy of I Approval for Radioactive Material Packages. ANO's OAP Approval for Radioachve Material Packages can be found on At's.i.. eat 3 page 174.
Entergy states this is consistent with the current QAP for GG. Actual ,
GG exception to these sentences is worded "The licensee does not 8/27/98 meeting intend to fabricate, desigt', assemble, or modify any NRC licensed Discussed in the meehng issue resolved.
contamer to be used to transport radcactive material" is there a difference here? App A p11 of 36. See L20. ;
Q-11 Table 1 C. 4. ANSI N18.7 Section 4.3.1 The specific areas of The are 2 separate committees discussed in this CLOSED .
experience described in this section is not applicable to the sechon 1) the onsite safety review group and the offsite on-site safety review committee but the commettee must be safety review group.
comprised of site operating or engineering supervisorf ;
personnel. Additionally, the off-site safety review committee On-site safety review committee-site safety review l need contain experience in only a majority of the areas. committee-site safety review u,n-i.N ,; site safety -
review committee-site safety review committee Entergy states this is a cunehwihn of currently approved QAPs for ,
W3 and GG. The first sentence is said to be based on W3 QAP ANO Att 3 page 44 item 1.3.9.2.2.1 (a.k.a. PSC) l*
Chapter 1 section 4.10.2 which states " The PORC shall be composed GGNS Att 4 page 85 item 7.4.1.2 (a.k.a. PSRC) 3 of site nsuigermnt members as assigned, in wnhng, by the GMPO. RBS Att 5 page 20 item TR 5.8.12 (a.k.a. FRC)
The GMPO will also indicate, in writing, the PORC Chairman." This W3 Att 6 page 14 item 4.10.1 (a.k.a. PORC) l does not appear to completely address the ikst sentence here with regard to expenence. The second sentence actually appears to The first sentence is taking excepton to the expenence i comes from GG UFSAR p168.1-207, referenced in the OAP, which list for the on-site safety review committee. The states "In the aggregate, the membership of the committee shall current requirements at the sites basscally say that the i
Revision dated 10/08/98 -
Entergy QAPM review matrix Number Comment Response Closed? Submit?
provide specific prachcal expenence in the majonty of the discaphnes commdtee is compnsed of site management and do not of 7.4.2.1a through h." See L19 and 1.20 invoke the N18.7 expenence requrements. The wording is nearest the GGNS words. The documentation part is covered in the general requrement found in QAPM A.1.d.
Off-site safety review commdtee-site safety review commettee-site safety review commettee-site safety review commettee-site safety review committee ANO Att 3 page 44 item 1.3.9.1.2.1 and 13.9.13.1 (a.k.a. SRC)
GGNS Att 4 page 88 item 7.42.2.b (a.k.a. SRC)
Il RBS Att 5 page 23 item TR 5.8.32 (a.k.a. NRB)
W3 Att 6 page 13 item 4.92 & 4.93 (a.k.a. SRC)
The second sentence is addressing the requrements t for the off-site safety review committee. Allof the plants have an expenence list sunitar to the list in N18.7 but N18.7 items 7 and 10 are not on the current lists and RBS has 2 extra items (e.g.,8 and 10 items required). GGNS has the discussion that experience is only required for a maronty of the items (i.e.,4 items required). The proposed do -;Tn.4;06 requwes 5 of the 10 items. Addebonally, the last paragraph in the first column for N18.7 S 43.1 says you will add expenence .;
when needed The new item is slightly less restnchve for ANO. RBS, and W3 and slightly more restnchve for i GGNS but any potenbal problems caused by the ,
, experience difference is covered by last paragraph in the first column for N18.7 S 4.3.1. ;
8/27/98 Meeting i Staff will consider the informahon provided. ,
i 10/7/98 meetog Issue discussed and resolved.
Q-12 Table 1 C. 6. ANSI N18.7 Section 4.3.4(2) Reviews associated with The requirements of Section 43.4(2) could be CLOSED changes to the technical specifications will be performed in interpreted to requre that the conin-Zees review the ,
accordance with Section 4.3.4(3)instead of this section. procedures associated with the TS change in a way some how different than the review of the TS change.
This appears to come from GG UFSAR 7.42.7.e and proposed Also, I would have to clanfy the TS review requirements clanfication from RG 133 Sechon C3. This seems to be used as twice if I leave this sechon aM Sechon 4.3.4(3)
Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
basis but it is not clear why this should require an provides the needed guidance; therefore, exception to exception / clarification to 43.4(2). RG133 C3 merely states "Secten Section 43.4(2) was taken for clarity.
43.4,
- Subjects Requiring independent Review." item (3) states, in part, that char;ges to the technical specifications or license 8/27/98 meeting amendments related to nuclear safety are required to be reviewed by Discussed in the meeting issue resolved.
the independent review body prior to implementation. It should be noted that proposed changes to technical specifications or license amendments should be reviewed by the independent review body prior to their submittal to the Commission for approval.* Whatis the purpose of this item 6 clarification? Isnt commitment to the RG enough? See L20.
Q-13 Table 1 C. 7. ANSI N18.7 Section 4.3.4(3) This requirement is Letters which transmit a proposed technical CLOSED YES implemented by reviewing the no significant hazards specification or license change to the Commission considerations evaluation for the proposed change prior to have many parts (e.g., cover letter and background).
submittal to the Commission for approval. The section that provides the safety justification is the no significant hazards considerations evaluation for the This is a new change for all the facilities. It appears to be intended to proposed change. This is the section of the proposed focus the attention of the independent review on the above part of the change where the safety committees need to focus submittal. Guidance to focus the review here may be appropriate but their re~iews. This change is made to clarify that it should not necessarily be limited to this part of the submittal. RG revisions to a previously submitted proposed change 133 C.3 clarification information was also included for completeness. only requires review by the safety committees when the See A13. safety justification for the requested change has been modified by the revision.
Post 8/27/98 meeting /27/98 meeting /27/98 meeting /27/98 meeting Still considering but a combination of the original and most recent Having the safety review committees review the no wording might be closer. i.e.: significant hazards consideration is consistent with the way 10 CFR 50.59 evaluations are handled. The Revision to proposed Technical Specification or license changes committees review as a minimum the evaluation but not only require a complete review in accordance with this section necessary all of the other documents associated with a when the revision involves a significant change to the technical change (e.g., the markups of the SAR).
basis for the proposed change. Otherwise, this requirement is implemented by reviewing the no significant hazards 8/27/98 Meeting considerations evaluation for the proposed change prior to Staff was concemed that the changes to the No submittal to the Commission for approval. Significant Hazards may not the correct threshold for when reviews of revisions are needed. Significant changes to the technical basis may be a better threshold.
Post 8/27/98 meeting /27/98 meeting /27/98 meeting /27/98 meeting Revise the clarification to the following:
Revision to proposed Technical Specification changes only require review in accordance with Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
this section when the revision involves a significant change to the technical basis for the proposed change.
Questions /concems with NRC proposed wording:
What is meant by *a completa review"? Either they review the change again or they don't.
If there isn't a technical change in the proposed revision then what is the purpose of reviewing the No Significant Hazards again? They already reviewed the original submittal.
10/7/98 meeting issue discussed and resolved.
O-14 Table 1 C. 8. ANSI N18.7 Section 4.3.4(4) In place of the From what I understand, a long time ago there were 24 CLOSED requirements of this section the on-site and off-site safety review hour written reports as described in this section. These committees shall review facility operations to detect potential were deleted and 10 CFR 50.72 (one hour and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> nuclear safety hazards anel all reports made in accordance with calls) and 10 CFR 50.73 (30 day reports) replaced 10 CFR 50.73. them. I have never seen a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written report.
4.3.4(4) deals with review of various violations, deviations and AlI of the plants have a list of items to review with the reportable events, which require reporting to the NRC in writing within consistent theme being REPORTABLE EVENTS (i.e.,
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This clarification is said to be based on W3 QAP Chapter 1 10 CFR 50.73). The other requirements varied from Sechon 4.10.5. However 4.10 5 has more specific examples than plant to plant and the intent seemed to be to detect described above. Moreover, neither W3 or any of the other plants potential nuclear safety hazards. We have tried to specifically took exception to 4.3.4(4) before. It is unclear why this is identify the acceptance criteria for the review and move needed or desired. Does 50.73 alone cover everything under some of the details to procedures.
4.3.4(4)? See L19 and L4.
Also, GGNS (Att 4 page 92 item 11) took exception to this entire section and replaced it with the inserted UFSAR pages.
8/27/98 meeting Discussed in the meeting issue resolved.
Q-15 Table 1 C. 9. ANSI N18.7 Section 4.3.4(5) included in the matters This statement does not reduce the review CLOSED YES reviewed by the on-site safety review committee in accordance requirements of Sechon 4.3.4(5)it only adds with this section are the following: requirements. I tried to convey this with the words
- Included in the matters reviewed B" and not words like
- a. new and revised station administrative procedures and *in place of".
- b. changes to the Emergency Plan (except editorial changes). We will change the words to the fo!!owing:
4.3.4(5) deals with other matters involving safe operation of the Examples of the rnatters reviewed by the on-site Revision dated 10/08/98
d <p Entergy QAPM review matrix Number Comment "M:w Closed? Sutwnit? ,
nuclear plant which an independent rewewer might consuler safety review commdtee in accordance with this section appropnate for considerabon. This clanficahon is said to be based on are the following.
L W3 QAP Chapter 1 Sechon 4.10.5. These are items included under j 4.10.5 for W3. However, nedher W3 or any of the other plants 8/27/98 meetog j e specdically took excephon to 4.3.4(5) before. Therefore, so long as Discussed in the meebng issue resolved.
j the above statement is taken as an example and not an exclusive set, ,
this could be acceptable. Perhaps wordmg like " such as the following
- instead of
- are the following
- See L19. ;
Table 1 C 11. ANSI N18.7 Section 4.5 The ;r ' .- r f-d review Q-16 All of the sites required that the offsite review CLOSED body discussed in this -*iant is the off-site safety review commdtee oversee audds (ref. GGNS Att 4 page 89 ;
committee. item 7.42.8). The only potential confhet is that the on-site safety review commdtee is also an independent
} Sechon 4.5 includes a requirement for a penode review of the audit review body and that is not the body that should ,
j progra n be performed by the independent review body or by a perform this review management representabve at least semaannually This clanfication i is based on W3 QAP Chapter 1 Sechon 4.9.10.3 and Chapter 18 8/27/98 meebng Sechon 5.2. These Sechcas do indicate that audit actmbes are Discussed in the meebng issue resolved. j performed under the coy 4z w.e of the SRC, although specific h periodic review requwements are not addressed However, as far as j t the above clanficahon, there would not seem to be any reason within i 18.7 or RG 1.33 which would confhct with the above clanficahon. See i L19. I Q-17 Table 1 C.12. ANSI N18.7 Section 5.1 Instead of the E .ts This sentence was refemng to the fact that RBS does CLOSED !
of this section to have a summary documor.t. a method of cross not have a OA program implemenhng procedure list i
. "_ .e:r,ii these requirements to the implementing procedures with assocated responuble department in their QA will be maintained. manual, !
i Consistent with the QAP approved by the NRC forRB7 Where is this 8/27198 meebng in the RB OAP7 See L21. Discussed in the meebng issue resolved. !
Q-18 Tatde 1 C.13. ANSI N18.7 Section 5.2.2 The person who holds a GGNS Att 4 page 92 item 14 takes exception to all of CLOSED ;
senior reactor operators license for the affected unit and the temp. change requirements in N18.7 Sechon 5.2.2 approves a temporary change to a procedure is not and says GGNS will follow the TS and UFSAR. l required to be in charge of the shift. UFSAR pages 208 and 209 are the requwements (they }
previously were the TS requwements). Since GGNS The basis for this GG UFSAR page 16B.1-208 & 209. Here when took excephon to the all of the temp. change ;
requwernents they did not address the N18.7 Sechon i descnbang temporary approval and the two members of the plant management staff, it only adds that
- at least one of whom holds a 5.2.2. words of " supervisor in charge of the shift." ,
Senior Reactor Operator's License." However, this does not GGNS only specdied the person hold an SRO. Since !
l*m no longer taking excephon to the all of the temp. I specifically take excephon to 5.2.2 which may be viewed as an additional requwement on this operator? Is there anywhere else, such change requirements, I needed to address the words in !
as in the UFSAR excephons to RGs or other NRC N18.7 Section 5.2.2. Taking excephon to the words approvals /posdions, which spc.c&,a;;y exempts the requwement as is " supervisor in charge of the shift"is consistent with the I done above? See L20. current GGNS requirements. The revised requirements l Revision dated 10/08/98 l
Entergy QAPM review matrix Number Comment Response Closed? Submit?
provides sufficient controls to insure knowledgeable Post 8/27/98 meeting operabons involvement while allowing for the workload Should something be added to the end of this exception aiong the on shift personnel to be controlled.
lines of provided the SRO in charge of the shift is notified prior to approving the charge.? 8/27/98 Meeting
- Staff will consider the informahon provided.
Post 8/27/98 meeting The proposed dadTwisvu is consistent with the current GGNS excephon. QAPM B.14 requires that a process is in place to ensure that the SRO in charge of the shift !
and others use the correct procedure.
B.14
- d. Copies of controlled documents are distributed to and used by the person performing the activity.
- e. The distribution of new and revised controlled documents is in accordance with procedures.
Superseded documents are controlled 10/7/98 meeting issue discussed and resolved.
Q-19 Table 1 C.14. ANSI N18.7 Section 5.2.2 in addition to the This requirement adds an extra layer of conservatism CLOSED temporary procedure change process described for changes to the change process for changes potentially involving which clearly do not change the intent of a procedure, temporary intent changes. Like the temporary procedure changes procedure changes which may change the intent of a procedure which clearly do not change the intent, these temporary may be made following the process described in this section. procedure changes must have the remaining reviews Except that the person normally responsible for approving performed prior to beu.m.;..v permanent.
revisions to the procedure is the approval authonty for the change. 8/27/98 meeting Discussed in the rneebog issue resolved.
The basis for this GG UFSAR page 168.1-208 & 209. Here there is an additional option not covered in 5.2.2 for temporary changes, i.e.
those which may involve a change in intent. As this was previously accepted GG by the NRC, and as the person approving is the person normally responsible for approving the revision, and provided other normal requirements for procedure review are met, this appears to be ,
acceptable. Is additional comment on review requirements for this special case needed here? See L20.
Q-20 C.15. ANSI N18.7 Section 5.2.6 Instead of the requirements of The wording of the clarification is to broad. The intent CLOSED YES this section, non-conforming conditions will be evaluated and reas that the discussion conceming the control of controlled in accordance with the corrective action program. nonconforming conditions be taken exception to by this Revision dated 10/08/98
Entergy QAPM review matrix Number Comment R_;~. Closed? Submit? i clan 6caton. ;
Secten 5.2.6 deals with equepment control in general and goes '
beyond just control of nonu,nlOnn;cs c66d;;;00s. A justdicahon for Revise the G ;Ticat;06 to the fo80 wing not using these equepment controls in addebon to those which may be i
requwed by the conechve achon program has not been provided. "Instead of the requwements of this sechon concerning What is the purpose of this G ;r i;untexcephon? See L4. non-conforming conditions, non-w.ilormmg c66d;;;0ns will be evaluated and controlled in accordance with the corrective achon program." ;
a ;
This sechon in the ANSI Standard talks aboui decianng d systems inoperable Each plant has a program to meet ,
Gerseric Letter 91-18 to control the decision process for ;
determmeng if equipment is inoperable. If was considered p.Jerable to leave a8 of the detads in the GL 91-18 program. +
i- ,
8/27/98 meetmo ,
Discussed in the meeting issue resolved .
O-21 Table 1 C.16. ANSI N18.7 Section 5.2.6 The requirement of the The requwement that the actrvity be in accxprdance with CLOSED YES !
fifth paragraph of this section to have a log of the status of an approved procedure was considered to be a temporary modifications is not appbcable to ^z - ,+ .fy -
sufficient desu;p;;un of the types of tasks. The wordmg ,
modifications installed in accordance with procedures which of the exempbon is moddied to inssaa that the intent of
, provide assurance that approvals are obtained, temporary item (2)is maintained. The words are not moddied to i modification activities are verified, and that activities are match the words of item (3) since to proposed words
- '---- ^ "i documented to indicate the status of the temporary more accurately reflect the requwement as descussed in j modification. N18.7. N18.7 requwed "[a] log shall be maintamed of ,
the current status of such temporary moddicahons " t This is basically consistent with the current OAP approved by the The proposed words requwe the achvibes be f-NRC for ANO (ANO QAP Sechon 14.2.5). However, the ANO wording " adequately documented to indicate the status of the seems somewhat more restnctive. i.e."Additenally, temporary temporarymodsacahon modifications which constitute temporary changes to plant ;
i configuration due to routine tasks such as the additions of Moddy the excephon to state:
temporary jumpers or gauges as part of maintenance, calibration, or troubleshooting, may be instaNed and removed by The requirement of the fifth pr y ph of this sechon to i
- use of approved procedures or work plans, providing (2) and (3) have a log of the status of temporary moddicatons is above are satisfied. These changes are not mamtained on a status not applicable to temporary moddicabons installed in i
log since removal of the temporary change is controlled by the same icccid&,c6 with procedures. These procedures shall procedure or work plan which installed it." (2) above refers to provide assurance that approvals are obtamed, s
" Perform independent venfication of temporary modsficahons by an temporary rnedifw i.un activibes are ind-,ac i.^:i
- individual cognizant of the purpose and the effect of the temporary verified by an individual cognizant of the purpose l modificahon." (3) above refers to " Document temporary modificatons and the effect of the temporary modification, and
to assure the achons are taken to retum the equepment or system to that achvsbes are adequately documented to indscate
- its original operatog configuraten and status." See L4 and L16. the status of the temporary n=*remhnri. j i ;
Revision dated 10/08/98 i L
e 1
Entergy QAPM review matrix Number Comment Response Closed? Submit?
8/27/98 Meeting With the addsbon of "for roubne tasks" between
" modifications" and " installed" this item is acceptable Post 8/27/98 meeting 8/27/98 meeting /27/98 meeting /27/98 meeting /27/98 meeting Change the clarification to the following-The requirement of the fifth paragraph of this sechon to have a log of the status of temporary modifications is not applicable to temporary modifications for routine tasks installed in accordance with procedures. These procedures shall provide assurance that approvals -
are obtained, temporary modification achysbes are independently verified by an Individual cognizant of the purpose and the effect of the temporary i modification, and that activities are adequately documented to indicate the status of the temporary modification. '
Q-22 Table 1 C.17. ANSI N18.7 Section 5.2.7,1 This section will be QAPM A.1.d provides the documentation requirement. CLOSED .
Implemented by adding the words "Where practical" in front of the first and fourth sentences of the fifth paragraph. For 8/27/98 meeting modifications where the requirements of the fourth sentence are Discussed in the meebng issue resolved.
not considered practical, a review in accordance with the provisions of 10 CFR 50.59 will be conducted.
This is consistent with current QAP approved by NRC for GG in items (4) and (17) under exceptions to RG 1.33. However (4) also specifically requires the 50.59 review also be documented. See L20.
Q-23 Table 1 C.22. ANSI N18.7 Section 5.2.15 Required procedure 10 CFR 50.73(b) requires the identification and CLOSED reviews following the occurrences discussed in Section 5.2.15, correchon of procedures deficiencies which contnbute paragraph 3, sentence 3, are determined and controlled in to REPORTABLE EVENTS. QAPM A.6 requires that !
accordance with the QAPM Section A.6 instead of this section. the root cause of significant events be investigated and ,
corrective actions taken. Basically, exception was This is based on an current QAP approved by NRC for GG in item taken from this ANSI Sechon to reduce the number of ,
(22) under exceptions to RG 1.33. However, the reference to A.6 places that singlar requirements are discussed using above does not seem ppiepdate to direct!y address this Sechon, different words. The proposed requirements meet the Wording in current GG QAP that applies is:" Applicable procedures intent of the ANSI Standard while reducing the potential shall be reviewed following an accident. unexpected transient, for confusion caused by different words being used.
significant operator error, or equipment malfunction which results in a reportable occurrence The difference between this and 18.7 being 8/27/98 Meeting the added "which results in a reportable occurrence." Why notjust Staff will consider the information provided.
Revision dated 10/08/98
Entergy QAPM review rnatrix Numt er Comment Response Closed? Submit?
say that here? See L.20 and L4.
10/7/98 meeting issue discussed and resolved.
Q-24 Table 1 C.24. ANSI N18.7 Section 5.2.16 Sentence 2 of paragraph The additional words don't add to the clarity of the CLOSED Yes 3 states: " Records shall be made and equipment suitably marked requirement. The clarification proposed provides an to indicate calibration status."Instead of requiring the marking of adequate description of the QA requirements.
all equipment this statement is changed to require the equipment to be controlled to indicate the calibration status. In addition to the current RBS clarification. GGNS has a clarification allowing the use of a computerized This is basically consistent with the intent of the current QAP system (GGNS Att 4 page 96 item 30).
clarification approved by the NRC for RB for ANSI N.452.4 section 2.52. In a recent SER for Farley the NRC found attematives to 8/27/98 Meeting marking calibration status on equipment to be acceptable based on: Staff is concemed over the accessibility &
(1) unique instrument numbers are readable at the instrument, (2) information to the user of the equipment and whether the instrument numbers are traceable to calibration schedules and personnel will insure that they are using calibrated records. (3) the calibration schedules and records contain the same equipment. What in the QAPM requires that personnel information as required by ANSI N45.2.4(1972). (4) these schedules insure that they are using calibrated equipment no and records are readily accessible to personnel who are required to matter the difficulty in obtaining the information. EOI check calibration status as required by goveming procedures, (5) and wi!! provide additional information.
the above attemative to tagging or labeling instruments with calibration data is "otherwise contro!!ed" by its description in the Post 8/27/98 meeting requested change to the Quality Assurance Program Description. Do One of the items discussed in the NRC proposed words the " controls" as used here by Entergy cover these general criteria? is the amount of information available. EOl is not taking is more detail needed here, or is detail in contro!!ing procedures exception to the amount of information provided it is sufficient? Perhaps something like " . controlled to indicate the taking clarifying the requirement the statement that the cali'aration status to the same level of information as required by equipment be " suitably marked" (N18.7) and taking an N45.2.4 and N18.7 with equivalent clarity, and with ready exception to " tagged or labeled"(N45.2.4). GGNS and accessibility to those requiring information on calibration status of RBS already has a clarification allowing the use of equipment." See L8. identifying numbers and cross referencing system to maintain and retrieve the necessary information. In these systems, personnel using the equipment must take the number and look up the calibration status.
The acceptability of using attemate methods to perform the fJnClion is discussed in SRP 17.3 section b.9 wtiich states " labeled, tagged, or otherwise controlled".
The ease of use and therefore the cost of the system is purely an economic issue. Regardless of whether the information is easy or hard to retrieve EOI wi!! be i
rquired to have procedures to ensure ca!ibrated I
e' *inused.
CAPM B.9.a states:
Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
A program is established and implemented to control the calibration, maintenance, and use of measuring and test equipment.
QAPM B.9.a states:
Measuring and test equiprnent it calibrated at specified intervals or immediately before use .
SRP 17.3 and section QAPM B.9.d states:
Measuring and test equipment is to be labeled, tagged, or otherwise controlled to indicate its calibration status and to ensure its traceability to calibration test data.
10/7/98 meeting issue discussed and it was agreed that GGNS and RBS clarification a!!owmg the use of identifying numbers and cross referencing system to maintain and retrieve the necessary information was ailowed by the words in N18.7. But that N45.2.4 did require clarification. It was agreed to revise the N45.2.4 clarification Table 1 item B.6 to discuss " suitably marked" consistent with N18.7.
Make the following changes:
Delete Table 1 item C.24.
Modify Table 1 B.6 to state:
The last sentence of this section states:" Items requiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of the person that performed the calibration." Instead of requiring the tagging or labeling of all equipment this statement is changed to require the equipment to be suitably marked to indicate the date of the next required calibration and the identity of the person that performed the calibration.
O-25 Table 1 D.1. General Instead of using the cleanliness level RBS USAR Sechon 1.8 page 46 Item 2 at the bottom of CLOSED classification system of ANSI N45.2.1. the required cleanliness the page.
for specific items and activities is addressed on a case-by-case basis. Cleanliness is maintained, consistent with the work being 8/27/98 Meeting Revision dated 10/08/98
x-
. Entergy QAPRI review nielrix <
Number Comment .T.-- Closed? Sulunir?
t perfenned to prevent intr ==harma=i of"seet:po motortel. As a . StaN wW consador the informehon provuled, probably ,
minimum, cleanliness inspections are portenned prior to system OK. ; l closure and such in=timemanis are documented.
10/7/98 meet'no
. a This is described as being consistent with the wrrent QAP for RB. Issue earniaears and resolved.
We don't have a specdic table of excephons for RB. Were is this
- . excephon desenbed? See L10.
, Q-26 Table 1 D.3. SecGon C.4 Contamination levels in expendable Clanlicahon proposed is consistent with a RBS CLOSED YES
, products are bened upon safe practices and industrial clanlicahnn. Reference RBS USAR e=arhan 1.8 page - -
, avaanhauy. Conhuninant levels are contreRed such that 46, Paragraph C.4 clarillenhnn,last half of tie - i
!~ - h-aar - it removal by standard cleaning methods resuhs in paragraph. [
the achieweenent of anal mecare -ada levels which are not .i
- detrimental to the nietorials. 8/27/98 Meehng !
I Star will conssder the irdormation provided, prnhahiy i C4. eenana *Section 5 of ANSI N45.2.1-1973 =8=8a=. in part, that low OK. [
suNur, low fluonne, and/or low chionne compounds may be used on i asaetanitic stainless =eamie and that low suNur and low lead compounds cost 8/27/98 Meehng L
- may be used on nickel-base alloys. Chemical compounds that could ;
j cxminbute to intergranular cracking or stress-conosson cracidng Revise the clanlicahon to state: i should not be used wHh anasaarubc stawdess steel and tw*al-base _. ;{
anoys. Eva==an-- of such chemical compounds are those rW%g As an allemate to the requirements elf this section, ;
chlorides, fluorides, iead, zinc, copper, sulfur, or mercury a L mch contaminehon levels in expendable produds niey be t elements are leechable or where they could be ranamead by based upon sale practices and industrial availabety j breakdown of the compounds under expected enwwonmental wHh documented engineering evaksesons. j condsons (e.g., by radiabon). This Enutaten is not intended to prohibit Contamment levels are controbed such that the use ofInchlorotn8uorcelhane which meets the requwements of subsequent removal by standard cleerung methods !
Mihtary Specec=nnn Ms-c 81302b for cleanma or degressmo of results in the achievement of final arrapanham levels
[
> austonec stainless steel provided the prac=i anns of ==hrswision which are not delnmental to the meterials. *
- . 7.3(4) of ANSI N45.2.1-1973 are observed."
10mg8 mesung ,
The GG clarilicanan cited states in part " Expend =hla matenals Issue diacinaead and resolved. !
wtuch contact stamiess steel or nickel amoy surfaces shes not contain j
, lead, zinc, copper, mercury, cadnuum and other low meNing point l metals, their aNoys or comoounds, as basic and a=aantal chancal }
conshtuents. Prescribed r taxwnum levels of water leadiable 1 chlondes, total halogens, and suNur and its compounds shall be [
imposed on expendahia products- j It is unclear if the newly worded excephon is con =atant with either of
- these statements.' The "andusinal e ~ ^ ~^," basis does not address the safety issue. The cleanmg ophon to mantam acceptable levels,
. although a good pradice, is not addressed as a basis in either C4 or ,
l the referenced GG danficahon. This issue may need to be forwarded l l
y Revision dated 10/08/98 -!
Entergy QAPM review matri:
Number Comment Response Closed? Submit?
to the materials group for a technical determination. See L20.
Post 8/27/98 Meeting This item was discussed with the materials group and another QA staff rnember with experience in this area. Their position is that this item should be aceviable if the first sentence read more like this:
Altematives to these contamination levels in expendable products may be based upon safe practices and industrial availability with documented engineenng eva!uations.
This would mean, lacking any justification for a particuiar case, the standard would apply. Yet the licensee has the option of performing engineenng evaluations for those cases where they feel other controls are appropriate.
Q-27 Table 1 E.5. AMS! M45.2.2 Section 4.3. Inspections of packages This clarification is based on a clarification to in the CLOSED and/or preservative coatings are made immed!ately prior to RBS USAR. Reference USAR Sechon 1.8, page 48, loading rather than after loading. item 3.
The new clarification is said to meet the intent of the original The supplier verifes that the packaging is OK when it is Regulatory Guide or ANSI requirement and is consistent with a given to the shipper (Secbon 4.3) and the w :,rehouse discussion in the GG UFSAR. Where exactly is this GG discussion verifies that it is OK when it is received (Sechon 5.2.2).
located? Is the concem that some areas may not be accessib!e for You can not necessary inspect it while it is loaded.
inspection after they are loaded? Perhaps "during loading" (i.e. each item is inspected as it is loaded) may be closer to the intent. See 8/27/98 meeting L17. Discussed in the meeting issue resolved Q-28 Table 1 E.21. ANSI N45.2.2 Section A.3.6.2 The last sentence is RG 1.38 does address this issue and the words seem CLOSED YES considered unnecessary guidance and not an Appendix (A-3) more appropriate. This clarification can be deleted.
appropriate requirement since vapor barrier materials are usually brown, cream, or black in color. Delete E.21 and renumber remaining clarifcations.
The last sentence states "The barrier material should be brightly 8/27/98 meeting colored to preclude loss within a system." The above statement does Discussed in the meeting issue resoNed.
not necessarily seem to be consistent with this. Attemate wording such as " appropriately colored to prevent loss " might be acceptable. Justification given for this change is that the new clar fication meets the intent of the original Regulatory Guide.
However, C.1.e of the RG states " in lieu of this guideline, the vapor barrier material should be colored to contrast with the materials on which they are used." Therefore, why should any exception or clanfication to the RG be needed at all? See L17.
Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
Q-29 Table 1 E.22. ANSI N45.2.2 SH: tion A.3.7.1 in lieu of A3.7.1(3) This clarification is consistent with a clarification to in CLOSED and (4), Entergy will comply with the following: Appendix (A-3) the RBS USAR. Reference USAR Sechon 1.8, page Fiberboard boxes shall be securely closed either with a water 49, item 6.
resistant adhesive apg. lied to the entire area of contact between the flaps, or all seams and joints shall be sealed with not 'ess The intent of the ANSI seem to be that the box be weH than 2. inch wide, water resistant tape. sealed. Either on of these methods seem suffeient to meet that intent.
Stated reason for this clarification is that it meets the intent of the original RG or ANSI requerement and is consistent with a discussion in 8/27/98 Meeting the GG UFSAR. What specific references are used to arrive at this Discussed in the meehng issue resolved conclusion? The standard indicates that both adhesive and the tape are necessary for item 3 and item 4 indsates that strapping with reinforced tape is also necessary.
Q-30 Table 1 E.26. ANSI N45.2.2 The last paragraph of A.3.9 could be The proposed item removed some of the specirc CLOSED YES Interpreted as prohibiting any Appendix (A-3) direct marking on details, but ecs;.,cerirs evaluations control the bare austeniCc stainless steel and nickel alloy Section A 3.9 materials used, metal surfaces. As a altomate, paragraphs A.3.9. (1) and (2) may be used to control marking on the surface of austenitic stainless 8/27/98 Meebng steels and nickel base alloys as long as contamination levels in Staff win consider the information provided.
the material used for marking are controlled such that the marking is not detrimental to the materials marked. Post 8/27/98 Meeting This is bascally consistent with a clarification for RG1.38 on page T1- Revise the E.26 dadrico6. to state:
7 & 8 in the OAP approved by the NRC for ANO. However, the following specific corde= were included in the ANO exception: The last paragraph of A.3.9 could be interpreted as
" Marking materials containing sulfur, lead, zinc, mercury, copper, and prohibiting any direct marking on bare austenitic low rnelhng point aucys as basic chemical constituent shall not be stainless steel and nickel alloy metal surfaces. As a brought in contact. or shaR not be used on surfaces of corrosion attemate, paragraphs A.3.9. (1) and (2) may be used to resistant alloys. Low-sulfur, low fluorine and/or low chlosine control marking on the surface of austenitic stainless compounds may be used on austenitic stainless stee8s. the maximum steels and nickel base alloys based on documented limits for the above mentioned marking materials will be as follows: engineering evaluations. Contamination levels are (a) total inorganic and organic halogen content shan not exceed one ' controlled such that the material used for marking (1) percent. (b) The sulfur content shaR not exceed one (1) percent. is not detnmental to the materials marked.
What specific additional requirements are committed to in order to ensure that these limitations are observed, and where are they Wording of the clarification was modified the be closer located? See L16and L4. to the clarification discussed in O-26.
Post 8/27/98 Meeting 10/7/98 meeting issue discussed and resolved.
This item was discussed with the materials group and another QA staff member with experience in this area. Their position is that this Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
item should be acceptable if the last sentence had something like this added:
... based on docurrented engineering evaluations.
This would mean, lacking any justification for a particular case, the standard would apply. Yet the licensee has the option of performing engineering evaluations for those cases where they feel other controls are appropriate.
O-31 Table 1 F.1. ANSI N45.2.3 General The ANSI five level zone The statement "in the operations phaso" was removed CLOSED designation system may not be utilized, but the intent of the and is not needed since all of our units have completed standard will be met for the areas of housekeeping, plant and the construction phase. The original QA manuals were personnel safety, and fire protection. developed during the construction phase.
This is generally consistent with a clarification for RG1.39 item 7 on That the designations are controlled by procedures is page 42 in the OAP approved by the NRC for W3. However, to avoid required by QAPM A.1.d. QAPM A.3.f says that future confusion and to be completely consistent, the statement procedures are to reflect the QAPM requirements.
should be prefaced or followed by * .in the operations phase..." Also include a statement to the effect that procedure or instructions for The term " case by case basis" really didn't add any hot:sekeeping to include the applicable requirements of this standard thing to the exception. The requirement is that we will be developed on a case by case basis, as was included in the W3 procedurally ensure that the intent of the standard is case. See L19. met for all applicable plant areas.
8/27/98 meeting Discussed in the meeting issue resolved.
O-32 Table 1 F.2. ANSI N45.2.3 This section is not applicable. The statement"in the operations phase" was removed CLOSED Section 3.1 and is not needed since all of our units have completed the construction phase. The original QA manuals were This is basically consistent with an exception for RG1.39, item 2,7th developed during the construchon phase.
paragraph in the QAP approved by the NRC for GG. However, to avoid future confusion and to be completely consistent, the statement 8/27/98 meeting should be prefaced or followed by * .in the operations phase..." See Discussed in the meeting issue resolved.
L 20.
Q-33 Table 1 F.5. ANSI N45.2.3 Section 3.4 This section is not The statement "in the operations phase
- was removed CLOSED applicable. and is not need6d since all of our units have completed the construction phase. The original QA manuals were This is basica!!y consistent with an exception for RG1.39, item 2,12th developed during the construction phase.
paragraph in the QAP approved by the NRC for GG. However, to avoid future confusion and to be completely consistent, the statement 8/27/98 meeting should be prefaced or followed by with " in the operations phase..." Discussed in the meeting issue resolved.
See L20.
O-34 Table G.2. ANSI N45.2.6 Section 1.2 Paragraph 4 requires that the The first sentence of the last paragraph says that it CLOSED standard be imposed on personnel other than licensee applies to " personnel of the owners", The proposed Revision dated 10/08/98
- . . = - _ _ _ _ _ - - _ _ _ _
Entergy QAPM review matrix !
Number Comment Response Closed? Submit? ;
eriployees; the applicability of this standard to suppliers will be clanfication doesn't affect that requirement.
documented and applied, as appropriate, in procurement documents for such suppliers. 8/27/98 meeting Discussed in the meeting issue resolved.
This is consistent with ar* exception for RG1.58, item 2 in the QAP s approved by the NRC for GG. See L.20. However, perhaps the wording could be revised to speofically indecate that this standard remains -;--L-@ for licensee employees.
Q-35 Table G.3. ANSI N45.2.6 Section 1.2 The requirements of this I don't think there is any difference in the meanings but CLOSED YES standard do not apply to personnel using editions of ASNT we'll change the words to: '
contained within 10 CFR 50.55a approved ASME editions or addenda later than those listed in the standard. The requirements of this standard do not apply to persOnr.61 using later editions of ASNT contained t This is basically consistent with an excephon for RG1.58, item 6 in the within 10CFR50.55a approved ASME editions or !
QAP approved by the NRC for GG. However, for the above to be addenda.
correct, it should be clear that the standard is "not intended to apply to personnel who only perform inspechon, examination, or testing in 8/27/98 meeting a d .co with ASNT SNT-TC-1A." This is already stated in the Discussed in the meebng issue resolved.
standard. It seems the real question might be the edition of ASNT. r Perhaps the original GG exception wording is better (i.e. The licensee reserves the right to use later editions of ASNT contaened within 10CFR50.55a approved ASME edihons or addenda.) See L20 O-36 Table G.5. ANSI N45.2.6 Section 3.5 Entergy reserves the right to The attemate requirements will be as determined CLOSED use personnel who do not meet these experience requirements appropriate by the individual authority responsible for but have shown capability through training and testing or certifcation of these individuals. They could be capability demonstration. different depending on the ceridication being sought.
in accordance with OAPM A.1.d procedures will specify This is consistent with an excephon for RG1.58, item 5 in the QAP the requirements.
approved by the NRC for GG. See L20. What are the attemate training / testing / capability requirements for these levels? Were are the 8/27/98 meeting specified? Discussed in the meeting issue resolved.
Q-37 Table 1 J.1.RG 1.88 Section 4.4 Entergy will meet the The NOA-1 piece is on ANO Att 3 page 167. CLOSED YES requirements of ANSI / AS ME NQA-1-1983, Section C Supplement 17S-1 in lieu of N45.2.9 Section 5.6 or the discussions in this The penetrations piece, as indicated on the ANO section for Records Storage Facilities with the clarification that markup,is based on GGNS Att 4 page 115.
penetrations providing fire protection, lighting, temperature / humidity control, or communications are 8/27/98 Meeting acceptable. Requirements in the GGNS exception that the penetrations must have the required fire resistance is Where is the ANO excephon on which the paragraph is said to be needed . With that change it is act eptable.
based, and the RB exception on which the second paragraph is said to based? Post 8/27/98 meeting /27/98 meeting /27/98 meeting /27/98 meeting Revision dated 10/08/98
)
____- . ~ - - - _ _ - _ _ __ _ _ _ _ -_. . _ __ - . _ _ _ _ . _ _ - _ _ _ - _ - _
1 I.
. Entergy QAPM review matrix i Number Comment 7 g __ z Closed? Submit? [
Modify the J.1 clarificahon to the fotomng: .
Entergy win meet the requwanents of ANSU ASME f NOA-1-1983, Section C Supplement 17S-1 in lieu of .
- N45.2.9 Sechon 5.6 or the discussions in this sechon
i for Records Storage Frilities with the cianficahon that penetrations provxir:g fire protechon, hghhng, . y temperature /humedsty control, or communscahons are ;
acceptable as long as the penetration maintains the -
i, required fire resistance 4
Q-38 Table 1 J.5. ANSI M45.2.9 Section 5.4.3 Instead of the OK CLOSED YES !
.+, _.2 of this secuon, Entergy wel comply with the [
following: Provisions shall be made for special processed Change this exemphon to say- [
records such as radiographs, photographs, negathres, - 11 J^ _.
and magnetic media to prevent damage from excessive light, instead of the requrements of this section Entergy will ;
- j stacking
- ': _n . . ^;; fiesds, temperature, and humkNty as comply with the foNowing- Provisions shaN be made for
!l approp tate to the record type. special processed records such as radiographs, photographs, negatives, microfilm, and magnebc media
- This is consistent with an excephon for RG1.88, item 4 in the OAP to prevent damage from excessive light, staciong, ,
approved by the NRC for GG. However,it would seem appropriate to electromagnetic fields, temperature, and humedsty as !
i anclude" with 29p.vpiWe considerabon of packagmg and stonng appropnate to the record type with appropriate recommendahons as provided by the manufacturer of these consideration of packaging and storing ,
matenais. This would help ensure that the requrement from the recommendations as provided by the manufacturer I original standard is at least considered when appropnate. See L20 of these materials. !
i 8/27/98 meeting Discussed in the meetmg issue resolved. -+
Q-39 Table 1 J.7. ANSI N45.2.9 Section 5.6 Entwgy will meet the The NOA-1 piece is on ANO Att 3 page 167. CLOSED YES i
.+,+k.._.."., of ANSWASSAE NQA-1-1983, Supplement 175-1 [
3 Section 4.4 in lieu of this section for Records Storage Facilities The penetrabons piece, as indicated on the ANO !
with the clarification that penetrations providing fire p.- ^--:71- . markup,is based on GGNS Att 4 page 115. 1 lighting, " .-- -. dre/ humidity control, or commus*=8Easis are
^
I acceptable. Except that as an alternate to these . -_ , ' . .^ The somnd par y iA based on RBS USAR Sechon !
non-permanent records (e.g.,3 years retention records) rnay be 1.8 page 135 item c. j stored and maintained by the originating organization in i one-hour minimum fire rated file cabinets located in 8/27/98 Meehng l
4 environmentally controlled facilities that have sultable fire Staff win consider the informabon provided. i protection. Suitable fire protection is provided by either an .
t automatic sprinkler system or a combination of two or more of Post 8/27/98 meetmg /27/98 meeting /27/98 l the following: 1 ) automatic fire alarms 2) home stations, or 3) meetmg/27/98 meeting !
portable extinguishers. Modify the J.7 clanfication to the following- !'
The discussion of penetrations in the first p i y.p"i is consistent with Entergy wiH meet the requirements of ANSI / ASME i
a !
Revision dated 10/08/98 t
0 Entergy QAPWI review matrix Number Comment Response Closed? Submit?
an exception for RG1.88, item 6 in the QAP approved by the NRC for NQA-1-1983, Sechon C Supplement 17S-1 in lieu of GG. However, that excephon also states that"AH such penetratons N452.9 Sechon 5.6 or the discussions in this sechon shah be sealed or dampered to comply with a rrunimum two-hour fire for Records Storage Facilities with the clanfication that protechon rating." How is this addressed and where is the reference penetrations providing fire protechon, lighting, to NOA-1 made? See L20 and L16. temperature /humiddy control, or commurucahons are acceptable as long as the penetration maintains the RB is cited as the source for the second paragraph. How was this required fire resistance amved at? See L18.
As reflected in the current ANO &Tn. nun shown on i Post 8/27/98 Meetmg Attachment 3 page 167 the commitment is to NOA-1 l not RG 128 rev 3. I didn't see any excephons to the As was done for Q-37, need to add to the end of the first sentence fire protecten requirements in NOA-1 in RG 128 rev 3. !
discussing penetrations as long as the penetrabon maintains the required fire resistance. Also QA staff had the question if this was 10/7/98 meeting NOA-1 as endorsed by Reg Guide 128 rev 3? Issue discussed and resolved. !
Q-40 Table 1 K.6. ANSI N45.2.5 Section 5.5 Entergy will comply with NRC wiH know and approve welding code changes CLOSED inspection requirements of the applicable welding codes and any through the 10 CFR 50.55(a)(f) process. This is the exceptions instead of this section. method for later codes to be approved and their use authonzed for Nuclear Facchbes to use. EOl through This is basically consistent with an excephon for RG1.94, item 7 in the the 10 CFR 50.55 required updates of 10 Year ISI QAP approved by the NRC for GG. See L20. However, the GG Program will show which codes to use including original i exception states the apphcable weldmg codes are speofied in the constructen codes,where &;-;WA ,
tJFSAR. What is the control here to ensure that the NRC knows and approves of the codes being appised? 8/27/98 Meebng ;
Staff will consider the informabon provided probably '
OK. i i
10/7/98 meeting issue discussed and resolved.
O-41 Table 1 L1. ANSI N45.2.8 Sechon 3 Documented routine The first full sentence on ANO Att 3 page 151 (T1-10) CLOSED i inspections and audits of the storage area may be performed is this statement. The clarification begins on page 149 instead of the requirements of this section. (T1-9). The rest of the clarification is statog the basis or affect of the clanficabon and is not necessary in the This said to be based on an exception in the QAP approved by the QAPM.
NRC for ANO. However, the approved excephon for ANO on page T1-9 does not seem to explain this. Where are the appropnate 8/27/98 meeting .
references and how was the above excephon arrived at? See L16. Discussed in the meetog issue resolved.
Q-42 Table 1 M.2. ANSI N45.2.13 Section 1.2.2 Item c is an option GG 7.5.7 is covered by the clarification to RG 1.144 CLOSED which may be used to assure quality; however, any option given Secten C.3.b.(2) identified in Table 1 item N.3. This +
in 10 CFR 50 Appendix B, Criterion VII as implemented by the item and the associated RG requirements address the QAPM may also be used. evaluation of the suppher's QA program. The part i proposed for removal is the list of experience sources Revision dated 10/08/98 i
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Entergy QAPRA revleur metrix
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m -_ ____
This wordmg is haairacy Constatent with an exraphan for RG1.123, This clanAcaten is being modiand as thana==ad in [
item 2 in the QAP approved by to NRC for GG.- However, GG's Osnaahan 46 below. l existing paar3== 4 and 7 on gec a document control and control ..
of purchased matenal, equipment and services which are cited in the Notheng signdicant was removed from the QA rnenuel }
GG ewcaphart to this RG contam informaton speedicaNy on evaluation thanamman of GGNS Policsos 4 and 7 in the corwersson !
of the suppler's quatty assurance program that does not seem to be to the new QAPM. Items from the ANSI Standards just ;
drectly addressed in the new QAPM. For example, GG 7.5.7 were not rapamead. ;
speedcaBy requres evahaaharts of the Suppler's Quatty Assurance :
program (allhough this item was proposed for removal (see L4)). 8/27/98 Meeting ;
What items in the new QAPM are specdicany address St.2.2.c StaN win consider the informalen provided probably requrement for an ev= hamman of the supplier's QA program andfor the OK. ,
Cntena Vil requrements for the apphcant maeaaament of the j ellectiveness of the control of quality by contractors? Is evskashan of 10/7/98 meeting :
t the supplier's QA program specilicaey addressed or an anomalwe issue stena==ad and resolved. -l a specsRcaRy desenbed anywhere in this QAPM7 The apparent removal ,
T of the specdic requrement for evahammari of suppler's QA programs .
does not seem to meet the intent of the standard or App B. Critona 'f Vit. The only issus really seems to be the method of evaha=Mrig the QA program and not whetherit should be evahammart Therefore,is it '
ner===ary to take avrapten at all? If so perhaps a statement such as a " Details of the methods used to evahamaa the supplier's quality ~
assurance psogram as requred by this secten are implemented by the QAPM and assoramaad gecd . "~ See L20.
1 Q-43 Table 1 BB S. ANSI M45.2.13 The requirements of the QAPAR ulu - NRC place holder CLOSED 4 he implemented instead of Section 3.4 this section.
t This is baseca8y consistent with an aveaahart for RG1.123, item 4 in i the QAP approved by the NRC for GG. It should be arraptable here provided that the Entergy QAPM sechons on procurement document control and control of purchased matenal, equipment, and service are found arraptable with respect to GGNS's avaahng policies 4 and 7 which are cited in the GG excephon to this RG. See L20. -
Q-44 Tatdo 188 8. ANSI N45.2.13 taessag 8.2 Item b Non conformances OK YES are only required to be submitted to Entergy when the
] non-conformance coukt adversely aNect the end use of an item Change the wordmg to the fotowing:
reistive to sasety, interchangenbauty, operanduty, ram- y, i integrity or maintainaldItty. NorH:enformance noticos for conastions described -
+ in this section are only requred to be submitted to This is ha=rnay consistent with an excephon for RG1.123, item 3 in Entergy when the non-conformance could adversely the QAP approved by the NRC for GG. The GG excepten also lists aNect the end use of an item relative to safety,-
i the 4 norm:onformances contamed in the standard that the above interchangeaodity,operabdity, raainhaity,integntyor statement apphes to. Perhaps wording such as "Non-conformances maintamabehty e
a Revision dated 10M18/98
. t O
Entergy QAPM review matrix Number Comment Response Cfosed? Sutwnit?
conditions desenbed in this sechon are only " would remove any doutA. See L20. 8/27/98 rneetmo Discussed in the meetu.g issus resolved.
10/7/98 meeting Issue discussed Q-91 discusses whether or not this clanfication is needed. If this clanfication is kept as f part of the resolubon of Q-91 then the identified changes should be made is the issue is resolved.
Q-45 Table 1 N.1. RG 1.144 Section C.3.a.(2) This section is not The ongmal QA manuals were developed dunng the CLOSED applicable. construcbon phase. Statements like "in the operations
[ This is consistent with an excephon for RG1.144 item 13 in the QAP phase" were removed and are not needed since all of our units have c.,0irC;d the construchon phase.
i approved by the NRC for GG. Sechon C_3.a.(2) is for Design and Construchon Phase Actmties. Perhaps add " in the Operabons 8/27/98 meeting Discussed in the meebng issue resolved Q-46 Table 1 N.3. RG 1.144 Section C.3.b.(2) instead of the annual OK. But the procedures and documented part is CLOSED YES .
documented evaluation of suppliers discussed in this section, a covered by QAPM A.1.d.
review of the supplier's p.Joi . :.s is conducted in accordance "
with procedures. Modsfy the clarification to state:
This said to be consistent with an excephon for RG1.144, item 14, instead of the annual documented evaluation of ,
paragraph 3 in the QAP approved by the NRC for GG. This supphers discussed in this sechon, an ongoing poi &.iA actual says "A documented ongomg evaluabon of the evaluation of supplier performance is conducted suppEer should be performed." It also sta'.e. where apphcable, this which takes into account, where applicable, the review should take into account the same items Ested in this sechon other considerations of this section and paragraph and poi @as of the RG. Considerwording such as " documented of the Regulatory Guide.
ongoing evaluabon of suppEer performance is conducted in ,
accordance with crocedures wl* h take into account, where 8/27/98 meebng ,
applicable, the rnv consederabons of this sechon and paragraph of Discussed in the meebng issue resolved. l' the RG." See L'in.
i' Q-47 Table 1 N.4. ANSI N45.2.12 Section 4.3.1 Pre-audit and post-audit RBS USAR SectK,n 1.8 pege 204. CLOSED conferences may be fulfilled by a variety of communications, i such as t'W,. conversation. 8/27S8 Meebng i Staff will consider the informahon provided prc5 ably Sechon 4.3 does not appear to place any restnchons on the OK. i communication method and therefore this is @ (RB QAP '
was referenced here trt I did not see a reference to communecahons 10/7/98 meetmg method. Where did this come from?) See L18. Issue discussed and resolved.
O-48 Table 1 N.5. ANSI N45.2.12 Section 4.3.1 Pre-audit and post-audit if the quality assurance organization does not feel that CLOSED conferences are only held when deemed necessary by quality the audit and/or finding need a conferenca with the assurance or when requested by the audited organization. audited organization and the audsted organization does i i
Revision dated 10/08/98
A
^
.e enemw QAPRR review enatrix number comment - :; m cionarr sabert not feel a need for the meeting, what purpose is the This is conaidant with an exception for RG1.144, item 3 in the QAP conference achieving? The purpose of the W3 approved by the NRC for W3. However, could worthng such as " exemphon is to aRowjudgement be used to determine
, are normaRy conducted, except were they would interfere with the when a conference would achieve a useful purpoemd.
nature or schedule of the audit. e.g. unannounced audies, persons Having a conference just for the sake of having a ~
normally attending audit not avadahaa, etc " This wording might better corderence detracts resources from more important .{
capture the intent of the standard and that of the approved excepton tasks.
j] forGG. See L19. '
E 8/27/98 Meehng Staff win consider the information provided probably
> OK.
U i N' 10/7/98 meeting ji issue siamaaed and resolved Q-49 Table 1 N.7. ANSI M45.2.12 Section 4.3.3 Pre-eudit and post-audit if the quakty assurance organizahnn cioes not feet that CLOSED conferences are only held when deemed me==y by quanty the audit and/or finding need a mnference with the assurance or when requested by the amNeed orgar*=Hast. audited organizadon and the audited organization does j not feel a need for the meeting, what purpose is the ;
This is consistent with an excephon for RG1.144, item 3 in the Qt P - confer = ,,ce achieving? The purpose of the W3 ;
i anproved by the NRC for W3. However, could wording such as " exemphon !s to allow judgement be used to detemune I^
are normally conducted, except were they would interfere with the when a conference would achieve a useful purpose.
nature or schedule of the audit, e.g. unannounced mida, persons Having a conference just for the sake of having a normally attendmg audit not available, etc., or formally deemed as conference detracts resources from more important unnecessary" This wording might better capture the intent of the tasks. ;
standard and that of the approved excepton for GG. This is the same comment as the pre-audit comment above, only it would seem - 8/27/98 Meeting even more important in the case of post-audit as findings could be Staff wiu consader the informahon provided probably
. <iamaaed. See L19. OK. }
10/7/98 meeting issue discussed and resolved. >
Q-50 Table 1 N.8. ANSI N45.2.12 taa Maat 4.3.3 Pre-audit and post-eudit RBS USAR Sechon 1.8 page 204. CLOSED !
conferences may be fulflIIed by a varloty of communications t e such as telephone conversation. 8/27/98 mechng Discussed in the meeting issue resolved. !
I Sechon 4.3 does not appear to place any restrichons on the i communecahon method and therefore this is amwamhaa. (RB QAP
{ was referenced here but I did not see a reference to communicahons .}
- rnethod Where did this come from?) See L18.
Q-51 Table 1 N.10. ANSI N45.2.12 Section 4.5.1 The QAPRA Secnon A.6 ANO Att 3 page 163 provides the basis for the first CLOSED YES corrective action program may be used instead of these sentence. The only part of the ANO exempton that is
, requirements. Also, no additional documentation is not addressed is the 30 day requwement 1
t I
t Revisson dated 10/08/98 i
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Entergy QAPM review matrix Number Comment Response Closed? Sutunit?
necessary if needed cormctive actions are taken and verified prior to audit report issuance. Change the exempbon to the foHowing This does not appear to be completely consistent with the intent of the The QAPM Sechon A.6 corrective achon program may standard or the cited excephon to RG1.144 item 11 in the OAP be used instead of these requirements as long as the approved by the NRC for GG. The GG excephon merely states that appropriate time limits are applied to significant written response is not necessary if corrective achon is taken and conditions adverse to quality. Also, no addebonal venfied prior to issuance of the audit report. Therefore the second documentation is necessary if needed correchve sentence above is consistent, however, the first is not. If somettung actions are taken and venfied prior to audit report to the e8fect that ". to meet these requirements provided the same issuance type of follow-up ir fonnation and schedules are met." replaces" .
instead of these requerements.", then this might be acceptaole See 8/27/98 Meetmg L20. Staff win consider the informabon provided. s 10/7/98 meetmo i Issue discussed and resolved
~' '
Q-52 Table 10.2. ANSI N45.2.23 Instead of the requirements of this The documentation and procedure discussion in the CLOSED YES section, the following may be Section 2.3.4 implemented: SONGS SER is covered by OAPM A.1.d.
" Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and lead an audit team. The SONGG SER statement "and having met the other Upon successful demonstration of the ability to effectively lead provisions of Sechon 2.3 of ANSI /ASME audits, licensee management may designate a prospective lead N45.2.23-1978"is covered by the fact that this ,
auditor as a lead auditor." clanfication only applies to Sechon 2.3.4 which only discusses the number of audits requirement.
The basic concept of demonstrabon of skins for lead auditors was previously approved by the NRC for SONGS. The followmg excephon I li modify the clasification to discuss the one audit item '
was found %: from the SONGS SER.
" Prospective Lead Auditors shan demonstrate their ability to Prospective lead auditors shah demonst-ate their ability '
effectively implement the audit process and effectively lead an audit to effectively implement the audit process and lead an team. This process is desenbed in wntten procedures which provide audit team. They shall have participated in at least for evaluation and documentation of the results of this demonstration. one audit within the year proceding the individuars in addebon, the prospectiva Lead Auditor shah have participated in at effective date of qualification Upon successful least one Nuclear Oversight audit within the vaar ;r.* ceding the demonstration of the ability to effectively lead audits, i individuars effective date of quahlication. Upon successful licensee management may designate a prospechve demonstration of the ability to effectivel/ implement the audit process lead auditor as a lead auditor. ,
and effechvely lead audits, and havirr, met the other provassons of l Sechon 2.3 of ANSI /ASME N45.2.23 '978, the individual may be 8/27/98 Meeting certified as being qualified to lead aucits." Staff win consider the informahon provided.
The NRC determined that the attemati e for lead auditor qualificabon Post 8/27/98 meeting proposed by SONGS represents an e 'eptable attemative to item in some places the SONGS clanfication includes plant 1883 of SRP 17.1 which is referener.1 in the criteria for audits in SRP specific verbiage which is not appropriate for EOI ,
i Revision dated 10/08/98 j
Entergy QAPM review matrix Number Cr mment Response Closed? Submit?
17.2. This determination was based on the licensee *s proposed plants (e.g.," Nuclear Oversight audit"). Conceming qua!ity assurance program controls which require that 1) prospective the additional statements in the SONGS clarification, as lead auditors effective!y demonstrate their ability to implement the discussed above and in Q-77, the additional audit process and lead an audit team,2) this demonstration process statements in the SONGS clarification are be desenbed in written prncedures or instrucbons,3) the results of the unnecessary.
demonstration be evaluated and documented, and 4) regardless of the methods used for the demonstration, the prospective lead auditor 10/7/98 meeting shan have participated in at least one nuclear oversight audit within issue discussed and resolved.
the year preceding the individuars effective date of qualification. In addition to the above, the attemative also states that all other provisions of Sechon 2.3 of ANSI N452.23-1978 regarding qualifcation of lead auditors will be met prior to the individuars certifcation.
Post 8/27/98 meeting Initial discussion with other QA members indicates a need to keep the exact wording of the previously approved exception at SONGS to ensure consistency with current positioas. This wording should not change the intent of the EOI exception as discussed in the 08/27/98 meeting.
Q-53 Secbon B. *PERFORMANCENERIFICATION" includes many We feel that the level of detail provided in the proposed CLOSED statements and commstments that are verbatim repeats from SRP- QAPM in conjunction with the commitments to the 17.3. In general consistent with the requirements of $50.34(b)(6)(ii). Regulatory Guides and associated ANSI Standards the staff is looking for additionai explanatory information regarding the provide sufficient detail to meet the regulatory method the licensee will adopt to implement the coiminis-nt. requirements. In most cases the level of detail Examples include: provided in consistent with the level of detail previously accepted on the specife item of interest for at least one
- Sechon B.2.a.: What are the design control program provisions that of the Entergy plants.
assure that design acturbes are executed in a planned, controlled, and orderfy manner? If during the course of the review an item that was previously in the Entergy QA Plans and is needed to
- Secbon 8.2.b.: What are the provisions to control design inputs, meet a regulatory requirement is identified that is not processes, outputs, changes, interfaces, records and organizational included in the proposed QAPM, we will address it on a interfaces? case by case basis.
- Section 82.g.: What are the interface controls for the purpose of Specircally, what details have we removed from the developing, reviewing, approving, releasing, distributing, and revising plan that is required?
design inputs and outputs to be defined in procedures? .
8/27/98 Meeting
- Section B.3.e.: Which are the individuals and groups responsible Staff is performing a review of the proposed QAPM. I for design reviews or other verification activities? What are their Staff will identify any specific issues as part of the authorities and responsibilities? review. Items will be addressed when identified.
Revision dated 10/08/98
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Entergy QAPM review matrix l Number Comment F:;-: :: Closed? Submit? ?
- Sechon B.4.br What are the provisens for evaluabng prnhective !
supphers and selechng quahlied supphers? ,
i
~
j - Sechon B.4.cf What are the provisions for ensunng that qualdied suppbers conhnue b provide acceptable products and services?
Sechon B.S.a.: What are the provisens of the program to veniy the f
, quakty of purchased items and services? ;
I; These are examples of areas that requwe further empidying discussons. There are many others in the vanous areas of the j 3i QAPM. All areas should be reviewed and expanded upon as !
appropriale l j Q-54 Manager of QA responsible for estabbshmg, controlhng and venfying The staff who reports to the QA manager performs the CLOSED !
? wnplementabon of the QAP (no mention of implementaton); who funchons idenbfied As descussed in A.2 "The authonty ( i' reports to the Manager of QA? What functions are camed out by staff to accomplish the quahty assurance funchons reportmg to Manager of QA7 To whom does the Manager of QA desenbed is delegated to the incumbent's staff as report? (Queston Wie validity of L26 due to an undefined layer of necessary to fulfiu the idenhfied responsabshty."
11 nior+we between the execuhve possbon and the QA funchon Providing extensive detasis concommg the lower levels possbon.) of the viva uovun detracts from the clanty of the l
commstment. When the detasis of X number of l supervisors report to the manager and the supervisors t have Y responsebehbes are in the QA plan it is difficult to j odentdy the important charactensbcs of the commitment which must be protected. For example is going frr,m 2 I supervisors to three supervisors a reduction in commdment because you have deluted the authonty !
and scope of control of the 2 previous supervisors? :
Conversely, is going from 3 supervisors to 2 supervisors a reduchon in commdment because you !
have reduced management oversight of the individual ,
workers?
i 1 Allowing a single layer of. ,, between the QA i manager and the VP was prevously accepted in the j RBS QA plan. RBS had a director posden with i responsibehty for QA and EP funchons and a QA t i
Manager that reported to the dwector in the past the ;
, dwector also had Licensing as a report.
2 i
8/27/98 Meetmo i Staff will consider the informahon provided. [
Revision dated 10/08/98 !
Entergy QAPM review matrix Number Comment Response Closed? Submit?
10/7/98 meeting issue discussed and resolved.
O-55 Discussion of Change L1 says "In all cases, the positions will One way this is performed is by the QA8)M requirement CLOSED maintain sufficient authority and organizational freedom to implement conceming the organizationallevel of the managers the assigned responsibilities.* This general criterion is good, but we involved.
need further information that demonstrates how this done.
. For the QA manager's position additional information is contained in OAPM A.2.d.1 and A.4.b.
What previously implemented acceptance criteria for the positions is missing.
8/27/98 meeting Staff will consider the information provided.
10/7/98 meeting .
Issue discussed and resolved.
Q-56 Section A2.d (pp 8/9); no mention of QA responsibilities for these The responsibilities identified are the QA CLOSED managers responsibilities of the identified management position.
Additionally, "The requirements and commitments contained in the QAPM are mandatory and must be implemented, enforced, and adhered to by all individuals and organizations."
What specific responsibilities are not addressed?
8/27/98 meeting Discussed in the meeting issue resolved.
O-57 Executive responsible for operations and nuclear safety appears to A.2.c.1 states that the executive responsible for overall Ct.OSED YES have no responsibility for QAP implementation plant nuclear safety at each site is responsible for establishing policies, goals, and objectives of the quality assurance program at the respective site.
8/27/98 Meeting A2.c.1 and A2.c.2 need to identify that these positions are responsible for implementing the QAPM.
Post 8/27/98 meeting 8/27/98 meeting /27/98 meeting /27/98 meeting /27/98 meeting Modify A.2.c to the following:
- 1. The executive responsible for overall plant nuclear safety at each site is responsible for establishing the Revision dated 10/08/98
Entergy QAPM review matrix Number Comment Response Closed? Submit?
policies, goals, and objectives and the implementation of the quality assurance program at the respective site and overseeing activities of the associated off-site safety review committee.
- 2. The executive responsible for operations support is responsible for establishing the policies, goals, and objectives and the implementation of tFe quality assurance program of Entergy's corporate activities -
and maintaining this QAPM in accordance with regulatory requirements.
Q-58 is there a manager of maintenance? A.2.d2 CLOSED 8/27/98 meeting Discussed in the meeting issue resolved.
Q-59 QA functional responsibi!ities Table 1 Item G provides Entergy's commitments to CLOSED Regulatory Guide 1.58 " Qualifications of Nuclear
- If line organization personnel perform inspechons, are personnel Power Plant inspection, Examination, and trained in QA technology? Testing Personnel."
8/27/98 meeting Discussed in the meeting issue resolved.
O-60 QA funcbonal responsibilities QAPM Sechon C provides a identification of the audrt CLOSED program. QAPM A.3.c requires an annual assessment
- What is the extent of performance monitoring by the QA of the QA pmgram implemenktion.
organization to assure proper QAPM implementation?
8/27/98 meeting QAPM A.6.e also requires trending of significant conditions adverse to quality.
Q-61 QA funcbonal responsibilities As discussed in C%PM A2.c.1, the VP at each site is CLOSED responsible for ou seeing activities of the associated
- In the RBS QAP (see QAD-1, section 4.1.3), the Vice President, off-site safety review committee. In accordance with Operations maintains awareness of QA matters and QAP the commitments to ANSI N18.7 the off-site review effectiveness by review of: committee reviews this type of information. Additiona!!y QAPM A.3.c requires that the adequacy of the QAPM's
- audit and assessment results implementation is assessed annually by the manager (s) responsible for quality assurance and
-open item status reports reported to tb6 associated VP.
- NRC inspechon reports The current QA plans did not all provide the same level of detail in the discussion of the VP's fonction that RBS
- independent management assessments / audits had. The proposed QAPM provides sufficient detail.
Revision dated 10/08/98
Enterpy QAPM review matrix Number Comment Response Closed? Submit?
- operating experiences 8/27/98 meetg Q-57 provides a change which resolves this issue.
Are these responsibilities assigned to an executive in the new QAPD (see section A2.c)? The responsibilities of these executives should be further described with regard to their management and guidance of plant activities through the managers that report to them.
Q-62 Do the responsibilities of the executive for overall plant nuclear safety I don 1 understand the question. The executive CLOSED (Section A.2.c.1.) also include cognizance of NRC inspechon responsible for overall plant nuclear safety at each site activities, industry experiences, LERs GLs, bulletins, and other in- is responsible for establishing policies, goals, and house events (see ANO section 1.0 Organization, section 1.32, objectives of the quality assurance program at the Director Nuclear Safety) ? respective site and overseeing activities of the associated off-site safety review committee. Some of the specific items reviewed by the VP and his reports are described in the QAPM and associated commitments.
The current QA plans did not all provide the same level of detail in the discussion of the VP's function.
8/27/98 meeting Q-57 provides a change which resolves this issue.
O-63 Previous commitments for implementation of QA functions not found QAPM B.12.a "Inspechons are performed by qualified CLOSED in the QAPM: personnel other than those who performed or directly supervised the work being inspected."
ANO: Executives / Directors and managers are responsible for QAP implementation; Director Quality responsible for implementation (pp. 8/27/98 meeting 10/11); Section 232 states "that individuals responsible for QAPM A.1.b requires that all personnel are responsible verification of conformance are qualified and do not perform or directly for implementing the QAPM.
supervise the work."
Q-04 Previous commitments for implementation of QA functions not found QAPM A 2.d.1 "The manager responsible for quality CLOSED in the QAPM: assurance has overall authority and responsibility for establishing, controlling, and verifying the River Bend: Manager QA responsible for implementation of the implementation and adequacy of the quality assurance QAPM (p.12/13) program as described in this OAPM.*
8/27/98 meeting QAPM A.1.b requires that all personnel are responsible for implementing the QAPM.
O-65 Previous commitments for implementation of QA functions not found QAPM A2.d.1 "The manager responsible for quality CLOSED in the QAPM: assurance has overall authority and responsibility for establishing, controlling, and verifying the Revision dated 10/08/98
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i Entergy QAPRA review matrix i Nwnber Comment N: s Qcoed? Satunit?
Grand Gulf: Dwector. Quality "provides" forimplementation of the ir iplementaten and adequacy of the quakty assurance 7 QAP (See W", p.2 of 14 and Sechon 10.0,"Inspecten", program s desenbed in this OAPM * }
< pp.172of 5) J 8/27/98 meehng !
QAPM A.1.b requwes that aE personnel are responsble
] [
, for'unplemenung the QAeW l Q-66 Prevous commitments for implementahon of QA funchons not found QAPM A.2.d.1 "The manager responable for quauty CLOSED i in the QAPM: assurance has overaE authonty and responsibiEty for - ;
estabbshing, contreibng, and verifying the ,
- Waterford: Director of Quenty responsble for;. 4 ._ ^ =--. of - wnplementahon and adequacy of the quakty assurance i 1
QAP (pp. 8-10); inspechons done by QA personnel,line orgarminan program as desenbed in this QAPM.* i
, , personnel (peer maintenance), and contract personnel); QUESTION: ;
A.1 rahonale for dolehon (p.111)??? 8/27/98 mechng
, QAPM A.1.b requwes that all personnel are responsble ,
y forimplemenhng the QAPM. '
Post 8/27/98 meshng See Q-2. Q-88 and Q-89.
Q-67 Independent Review Program See Q-11 for a dimmian of the committee make ups. CLOSED j j: r
). - QAPD, Sechon A.2.e. provides a general statement of the purpose 8/27/98 meehng
. of the oresite and off-site salsty review committees Section A.2.c.1. Q-11 will track issues.
1- states that the Execubve Overall Plant Nuclear Safety,is responsble !
for overseeing the achwihes of the off-site safety review committee.
4
[
Sechon A2.d.2.1. Indicates that the Manager, Plant Operatens is l funchonally responsble for the orksite safety review committee. }
Table 1 indicates a commitment to RG 133 and ANSI N18.7 with an ,
excephon to Sechon 43.1 regankng the exponence applicable to the !
i on-site review committee, and the expef.ance for the off-site I committee (magority of areas). Please explain more specdicaEy the f requirements for members of these committees. What will be the j
- membership compombon of each of these committees? In additen, ;
an excepton is taken to Sechon 43.23 whereby members with line [
responabdity for operahon of the plant may now conshtute a masonty of the quorum for the on-site SRC (see QAPM p.23). OK. ,
l Q-68 Independent Review Program ANSI N45.2.12 along with Clanficahon N.9 requwe the CLOSED !
audit report to be issued within thirty working days after Per Sechon 432.4 of ANSI N18.7, meehng minutes wid be the last day of the audit. l disseminated prompty. i i
No commitment for timely submittal of audit reports (Standard is 8/27/98 meehng j l silent). Licensee is u..... ;;.g to the Standard. Not a big .;
i Revision dated 10/08/96
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Entergy QAPM review matrix Number Comment Response Closed? Submit?
issue.
O-69 Independent Review Program We're committing to AllSI N18.7 Sechon 4.32.2 as a CLOSED minimum meeting freqr .tncy. Any increased frequency No commitment on PORC meeting frequency per Secton 432.2 of t%t we require wiH tulentified in procedures.
ANSI N18.7 (per L4, wiH be in procedures).
8/27/98 meeting Licensee is commenting to the Standard. Not a big issue.
Q-70 Independent Review Program See Q-14. Sechon 43.4(4) was discussing volatons CLOSED
- that were reportable via a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report.
Table 1 takes exception to Sechon 43.4(4) of ANSI N18.7. WiH onsite and offsite SRCs review violations also? (Violations seem to be 8/27/98 meeting omitted in the clarification) Q-14 prevides additionai discussion. Licensee is commenting to the Standard.
O-71 Independent Review Program For the number of members we are commstung the CLOSED ANSI N18.7 Secten 4.3.2.1. The number is consistent ANO with the W3 requirements.
- SRC has 8-12 rnembers For a discussion on Qualifications see Q-11.
- Qualifications satisfy au techrucal areas For timeliness of meeting minu'es we are commethng to ANSI N18.7 Sechon 4.32.4. The specific number of
- Meebng minutes within 14 days days is a procedural detail not included in N18.7.
- Meeting once per calendar month SRC meeting frequency is once per 6 months per ANO 1.3.9.13.1. Frequency is maintained by ccarwa's, ant to
- No exception to N18.7 $43.4(4) N18.7 Secten 4.32.2.
8/27/98 meeting Licensee is commenting to the Standard.
Q-72 Independent Review Program QA program review. We are committing to the ANSI CLOSED Standard. The specrfics that you identified in the RBS current RBS program don't appearin all of the other programs. N18.7 provides sufficient description of the
- NRB is responsible for evaluating the scope, implementation and base requirements including the requirements of N18.7 effectiveness of the QA program (QAD-1, REV-14C, p.18 of23, top Sechon 4.5 which requires that audit reports be sent to bullet); ANSI N18.7 (Sechon 43.4(5)) is cited as a replacement in the the off-sito committee. Sechon 4.5 and the associated QAPM; but this sechon is very general. Table 1 should be more clarification also require the off-site safety review ,
specific as to the subgect matter to be addressed under this standard committee to review the QA program every 6 months.
provision.
For the number of members we are comnang the ,
- RBS takes no exceptions to ANSI N18.7 for 'he offsite independent ANSI N18.7 Sechon 432.1. The number is consistent review committee in the following areas [QAD-1, pp. (4), (5). & (6)]: with the W3 requirements.
+
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Entergy QAPRA review matrix Nwnner comment .:;:m- csesed? suenwrr !
I
- NRB has 9 to 13 members For a discussion on Quahncahons see Q-11. ;
i
- Quauncahons sabsfy aN technical areas For timehness of meebng nunutes we are commdhng to ;
ANSI N18.7 Sechon 4.32.4. The specdic number of ;
Meehng nunutes within 14 days days is a procedural detaH not included in N18.7. !
- Records'cf NRB reviews to VP-Ops in 14 days 8/27/98 meehng Ucensee is commenhng to the Standard. .,
- No excephons to ANSI N18.7 $4.3.4(4) [
4 Q-73 Iruhpondent Review Program For the nurnber of members we are commithng the - CLOSED !
i ANSI N18.7 Sechon 4.3.2.1.
RBS' f o We're commdhng to ANSI N18.7 Sechon 4.3.2.2 as a
- RBS takes no excephons to ANSI N18.7 for the onsde independent menemum maeting frequency. Any increased frequency s review committee in the following areas [QAD-1, pp. (1), (2), & (3)]: that we requse wiu be identdied in procedures.
. I
- FRC has 6 to 11 members 8/27/98 meehng !
Licensee is commenting to the Standard.
- Meehng frequency is at least once per month a
- - RW--W ~ ^ _ of the FRC [QAD-1, p.18(2), bottom of sheet] seem l
- to be transferred to the onsste operahng u.va u u.i under ANSI
- N18.7 64.4. OK based on idenhcal composit!on of the FRC. ,
Q-74 independent Revurw Program For the number of members we are committing the CLOSED ANSI N18.7 Section 4.32.1. The number is consastent j j Waterford with the W3 requirements. ,
i
-Waterford takes no exceptions to ANSI N18.7 for the SRC. We're commdhng to ANS3.1 1978 for au personnel !
- (Table 1 A.1). ;
~
- - SRC has at least five members l
We're commRting to ANSI N18.7 Sechon 4.3.22 as a
- - Qualificahons of members meet ANSI /ANS3.1-1978, Section 4.7 rninemum rneeting frequency (6 months).
1 t
! - Meet at least once per six months. For bmehness of meshng minutes we are commsthng to j ANSI N18.7 Sechon 4.3.2.4. The specific number of
- Meehng manutes within 14 days days is a procedural detail not included in N18.7. j l
- Minema! excephons taken to ANSI N18.7 in other areas. ANSI N45.2.12 along with Clanficahon N.9 requwe the j audit report to be issued within thirty worlung days after j
- - Audit reports forwarded to anected management within 30 days. the last day of the audil .
I
! Revision dated 10/08/98 i
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O Entergy QAPM review matrix Number Comment Response Closed? Submit?
- PORC reviews design changes and site nonconformance PORC review of design changes and site documents which have dispositioned as "use as is" or " repair" (See nonconformance documents which have dispositioned para. 4.3.13, page 4). Does the clarification to ANSI N18.7 Secton as "use as is" or " repair" is one way that W3 meets the 4.3.4(4) include these responsibilities for the on-site safety review clarification to ANSI N18.7 Secton 4.3.4(4).
committee? PORC rreets once per month.
For PORC meeting frequency we're Committing to ANSI N18.7 Secton 4.322 as a minimum meeting frequency. Any irx:reased 'requency that we requtre wiu be identified in procedures.
8/27/98 meeting Licensee is commenting to the Standard.
Q-75 A duty of the General Manager, Plant Operations is " analyzing The QAPM requires this to be performed by the CLOSED conditions for trends regarding equipment failure, and publishing a manager responsible for corrective action A.2.d.7 and quarterly trend report"(See para. 4.3.1.5 on page 4). How is this A.6.e.
responsibility handled in the QAPM7 According to para. 4.6.1.5 and 4.6.1.6 on p. 7 these funcbons fall under the manager for correchve 8727/98 meeting schon (A.2.d.7 of the QAPM). Suggest this be stated ir the OAPM. Discussed in the meeting issue resolved.
O-76 How are the respcasibilities identdied in para. 4.3.120 through A2.d.2 provides the necessary requirement. CLOSED 4.3.128 on p. 5 handled in the QAPM7 8/27/98 meeting Discussed in the meeting issue resolved.
O-77 Lead Auditor Qualifications See Q-52. CLOSED
- Table 1. RG1.146, item 2 (ANSI N45.2.23, section 2.3.4) should be 8/27/98 meeting supplemented by the following or words similar to the following : Staff feels that the discussion that the process for demonstrating the ability to lead an audit team shall be f I
"The process for demonstrating the ability to lead an audit team shall documented in a procedure that requires evaluation '
be documented in a procedure that requires evaluation and and documentation of the results of the demonstration documentation of the results of the demonstration." is needed.
EOl discussed that QAPM A.1 d requires that a!! of the requirements of the OAPM be implemented by procedures addressed this item and that it was inconsistent to repeat it for only this item. These kind of statements were removed from the rest of the OAPM to remove the potential for confusion on those specific l
items where this statement was not included (if it is said l on item A but not on item 8 does that mean procedures are not required foritem B7).
NRC and EOl to consider and discuss.
Revision dated 10/08/98
l i.
Entergy QAPRR review matrix Number Comment flesponse Cleeed? Submit? ;
10/7/98 meshng _ [
issue asan=aari and resolved i Q-78 Auddmg QAPM C.2.a.1 aNows the 6.,l_. J =-. of a CLOSED l performance based audit program as was previously [
- Item C.10. Table 1 of the QAPM takes excephon to ANSI N18.7, approved for GGNS.
4: '
Secnon 4.5 with respect to frequency of audds. However, both the standard and hrean C.2.a.2 seem to say that audits of the listed 8/27/98 meebng _ ;
- actvibes wiB be performed at least every two years. What is the Discussed in the meehng issue resolved j reason for talung the excepeon?
- , Q-79 River Bend was commetted to engaging *at least annuaNy, a quahhed Only RBS had this commdment QAPM A.3.c requires CLOSED .[
ij maarsaarig organezahon, independent of the organizahon being reviewed "The adequacy of the QAPM's L.6.. ' .-- is j h to -a REBS safety-related achvehes * (See QAD-1. REV-14C, assessed annuaNy by the manager (s) responsable for [
- page 17 of 23) The QAPM staana. (Item A.3.c., p.4) that *the artarynar y qualdy assurance and reported to the chief execudve _j i ?- of the QAPM's implementagon is ==aaaaarf annuaNy by the officer and the assocated executive for overau plant
- manager (s) respormiNa for quagty assurance ". How is the R/B ruariaar safety." The team makeup is a procedural i commitment for independent =sartion sausRed in the QAPM7 detail that was removed from the QAPM. .
!i 8/27/98 meeting !
j: Deens== art in the rnesting issue resolved Q-80 RBS Sechon 3.2.7 requeres that for records not listed in CLOSED
, Appendix A the type most nearty desenbing the record
- QAD-1, page 18(6), para. TR 5.9.1, items f g., h., and L don't seem in queshon should be followed.
to be irireartad in N 45.2.9, sechon 3.2.7 and Appendix A.
8/27/98 meebng Licensee is commenhng to the Standard. j Q-81 Quahlicahons: See O-6. CLOSED ,
- Equivalency for a bachekts degree is provided on page 21 of the 8/27/98 meehng QAPM (Table 1). This is identical to the commdment in GGNS, Discussed in the meehng issue Q4 is addressing this Appendix A, clanficahon to the provissons of ANSI /ANS 3.1 (R.G.1.8). i== aa.
i: 'What are the equnralency commitments for the remammg three p' ants? Also, I didn't see an equivalency statement in the standard.
j' in fact, sechon 4.4.5 of the standard requires a bachelor's degree Ale appropnate exponence, whereas the QAPM commstment requwes a bachekts degree OR certain levels of experience which appear to be rather nunsmal.
- Watedord 3 meets the ANSI standard (see sechon 4.7.1.1 on p. 8).
Q-82 QA Programs for Pnncipal Contractors and Supphers: QAPM A.3, B.4.a and B.4.e and the commdments to CLOSED N452.13 along with the reporbng requrements of
- Waterford (Sechon 5.10.3. page 32) est=Niahes controls for changes 10CFR50. W3 was the only unit to have this level of to the QA programs for pnncapal contractors and suppliers and their detail 4
Revision dated 1006/96
Entergy QAPM review matrix i
Number Comment Response Closed? Submit?
sutwruodw The QAPM referenced sections do not explicitly ,
identify such controls (A.3.a and A.3 b). 8/27/98 meeting Discussed in the meeting issue resolved.
10/7/98 meeting issue discussed and it was identified that ANSI N18.7 sechon 5.2.13.1 discusses this issue. Issue resolved.
O-83 is there a list of safety related SSCs in the site SARs? Summary level lists. Engineering documents are what 8/27/98 provide the component level information that feeds into the QAPM. A cross reference would not provide any :
additional clarity to the requirements.
10/7/98 meeting Issue discussed NRC would still like some kind of j reference. EOl considering. j Q-84 Per L34 EOl has elected to delete the requirement for an ISEG The intent was to relocate the ISEG requirements to funcbon imm the QAPM because it is solely an outgrowth of the TMI the FSAR and the controls of 10CFR50.59 consistent Action Plan and has no tie in to the requirements of Appendix B. with the controls approved for GGNS and RBS.
Further, not all plants are required to have an ISEG. Hows.ver, it is ;
noted that L34 makes a statement regardir:g the QAPM only, and 10/7/98 meeting does not address whether or not the ISEG funcbon is maintained in Issue discussed and the Staff would still like some kind the FSAR. of controls on ISEG in the QA Plan. EOl and NRC to '
- Consider.
t Q-85 INSPECTOR REPORTING: See the resolution to Q-2. CLOSED
- Which organizational group in the OAPM is responsible for 10/7/98 meeting ,
evaluating the qualifications of the inspection personnel and certifying issue discussed and resolved l them under N45.2.67 Q-86 INSPECTOR REPORTING: Table 1 Item G commits the N452.6 for applicable CLOSED YES inspectors.
Waterford 3: Chapter 10 of the QAPM. section 3.2, page 109 says that inspectors are certified to N45.2.6 and are normally assigned to Having personnel who are certified to N45.2.6 reporting i the line organization; however, during inspecbon actmties, these to the QA manager during the activity is one au,eralAu personnel report to the QA inspections unit. The assigned inspector method for providing the necessary independence.
is not directly responsible for, or supervisor of, the activity being N18.7 provides an NRC endorsed level of ,
inspected. andependence that is also acceptable. Regardless see the resolution to Q-2.
NOTE- In Chapter 10 of the QAPM, Secbon 4.0, page 110, the inspection responsibility for each line management position is noted. See Q-2 new insert The relocation of the inspecbon function to the various management positions in the EOl QAPM is also noted. However,in none of the B.12.g Additional details concerning inspections position functional descriptions in the EOl QAPM is a responsibility for may be found in the Regulatory Guides and inspections identified. associated Standards as ccmmitted to in Section Revision dated 10/08/98
-e, Entergy QAPRE review enatrix Stumber Comment Response Chried? Submit?
A.7 and Table 1 (e.g., Regulatory Md== 1.33 and NOTE- Sechon B.12 of the EOI QAPM should include a a shaarewwt 1.58).
that references Secten A.7 and Table 1 (e.g., Regulatory Guide 1.58).
There appears to be no clear statemerd that inspectors are quahlied 10/7/98 meehng to ANSI /ASME N45.2.6 in either Sechons A.5 or B.12. Issue dienmaad and resolved.
Q-87 INSPECTOR REPORTING: B.12.a and N18.7 Sechon 52.17 CLOSED River Bend: In QAD.10, edw*wi 6.5.1 page 6 of 9, specac cntens The inspechon program may be implemented by or for are a=*=e*=hed for the use of line orgamzahon personnel to perform the organization performing the schwity to be inspected.
ime=renn funchons inchusag- inspechons are performed by quanned personnel other
, than those wen performed or drecdy =g =M the
- i. - Operaung achvibes may be inspected by second.nne superwsory work being inspected.
ji personnel or by other qualified personnel not assigned first-line superwsory responsabshly for conduct of the work. When the inspector eof is committing to ANSI N18.7. Methods of meehng is from the same group as the indmdual performmg the work, the these requrements are procedural dotads.
- {. actmty to be inat=riad must be rouhne mantenance, normal plant i- operabon or salar4ad techrucal services;it may not irv4mia See the resolubon to O-2.
!i modiEcahons or nonrouhne maintenance. Also, the quality of the work can be demonstrated by a funchonal test when the acimty involves 10/7/98 mechne breaching a pressure retammg boundary. Issue dian=*ad and resolved.
. - Inspechon procedures trarung, queuscahon. and cerencahon
. cntena for inspechon personnel are rewswed and sound arraptable by the Manager-Quahty Assunmce.
- The independence of the inspechon personnel performmg inspecton of in-line funchons is rewswed and found =re=re=hia by N Manager - Quatty Assurance prior to ir=86aswwt of the inspechon process.
Q-88 INSPECTOR REPORTING: See the resolubon to Q-2. CLOSED YES Grand Gut:
- The VP. Operahons Support and Derector. Quakty are responsable Addshonally add the followmg clandicasian to RG 1.58 for assunng that work procedures include inspecnon requrements, (Table 1 item G) and for assunng that inspechons and exammahons are performed and ,
documented where necessary to assure quality (See OOAM. sechon Certification of 8 =pactars in accordance with this 10.4.1 on page 51). guide is --;-; _;;f by a manager. :;1-_r i for quality assurance except for inspectors performing
- The Drector, QuaEty is responsable for developmg and in'spections as part of the , -:s_V_ d process.
implemenhng procedures for the p6 kn.e.c6 of a5 quakty These inspectors may be approved by a enanager inspechons. The coordmahon of actmhes concemmg trarung and responsilde for materials, purchasing, and certdicahon of au quanty mspectors shall be accomplished by the contracts. .
Drector.Quakty (See OQAM sechon 10.4.2 on page 51/52).
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o Entergy QAPM review matrix Number Comment Response Closed? Submit?
Q-91 CORRECTIVE ACTION: Table 1 item M commits to RG 1.123 with endorses N45.2.13. N15.2.13 Sechon 8 addresses
- la the W-3 QAPM section 53 page144, a requirement for nonconfcnnances for purchased items. .
contractors to identify conditions adverse to quality is listed. Is this a requirement under the EOl QAPM7 The referenced secton is A.6.a W-3 page 144 is discussing contractors who are which does not address the matter. performing work in acco dance with the EO! QAPM.
Those contractors wiu meet section A.6.
10/7/98 meeting issue discussed EOl to consider and get back to the staff. The issue being reviewed is discussed in Q-104.
Q-92 REGULATORY COMMITMENTS: Providing a listing of the regulations would not provide CLOSED any additional clarity or requirements to the QAPM.
- Table 1 of the QAPM should include a listing of the regulations to The applicable regulations rnust be met unless there is which the EOl QAPM will comply (See item A.7.a., page 17.3-6 of the an exemption.
SRP).
10/7/98 meeting issue discussed and resolved.
O-93 REGULATORY COMMITMENTS: N18.7 defines should as a recenw.c-r4 bun. CLOSED
- Since extensive use is made of references to RGs and ANSI 10/7/98 meeting standards in lieu of more descriptive material in the QAPM to satisfy issue discussed and resolved.
5034(b)(6)(ii), what commitment is made relative to the "shoulds"in the standards? If no exception / clarification is made, can it be assumed that the "shoulds" will be implemented?
Q-94 REGULATORY COMMITMENTS: OK add the following information: CLOSED YES
- In Section B 6 of the QAPM, there is no commitment regarding RGs B.6.c Additional details concerning inspections and ANSI standards that are applicable to *Identif: cation and Control
. may be found in the Regulatory Guides and of items". Reference should be made to RG 133 and ANSI N18.7. associated Standards as committed to in Section A.7 and Table 1 (e.g., Regulatory Guide 1.33).
10/7/98 meeting issue discussed and resolved.
Q-95 ADDITIONAL ORGANIZATIONAL CONCERNS: ANSI Standard N18.7 Section 3.4 in the last paragraph CLOSED provides the NRC accepted guidance conceming other
- The manager responsible for QA should "Have no unrelated duties duties of the QA manager position. The NRC has or responsibilities that would preclude fuG attention to assigned previously accepted that the QA manager may have responsibilities"(See SRP 173, sechon A.2.d.(4), page 17.3-4). What more than just traditiona!"QA" responsibilities. Items assurance can be provided that this assignment of responsibility will such as membership on on-site and off-site safety not change without prior NRC review and approval in the light of review committees, human performance, corrective Revision dated 10/08/98
Entergy QAPhi review matrix Number Comment Response r%=ad? Submit? ;
QAPM section A.2.d which states that"These individuals may fulfill achon assessments, and employee concer is are not l
more than one funcbon described below "
can perfonn. The applicable comnutment for EOl is I that the QA managers duties will"... be such that the required attention can be devoted as required..." If ;
comphance with this statement was in bought into ,
question then EOl would request a change in :
accordance with 10CFR50.54.
I 10/7/98 meeting Issue discussed and resolved Q-96 QUALIFICATION OF INSPECTION PERSONNEL: Table 1 provides the necessary commetment cross CLOSED YES reference to this w.i ..L. wit is being added to QAPM ,
- The apphcability of RG 1.58 and ANSI N45.2.6. to inspechon B.12 as discussed in Q-86. The clanfication is !
personnelis not clear. -Wily. A.S.d does not includo RG 1.58 consistent with a current GGNS clanfication.
as an example. RG 1.58 is struck as a reference in sechon 6.6 of QAD-10. page 6 of 9 by A.1 (RBS), and item G.1 of Table 1 indicates 10/7/98 meeting that RG 1.58 may not apply if personnel <= d'- C-s are controlled issue discussed and resolved with the A.S.d changed by the Tech Specs or another QAPM ccmtrutment. to the following:
Additional details conceming Personnel Training and Quahfication may be found in the Regulatory Guides and associated Standards as commetted 10 in Sechon A.7 and Table 1 (e.g., Regulatory Guides 1.8,1.58, and ,
i 1.146).
i Q-97 Sechon B.12 lacks a cc.i...L. d to Table 1 regarding <= 2' *-s Added as discussed in O-86. CLOSED of inspechon personnel.
10/7/98 meeting issue discussed and resolved. l Q-98 MEASURING AND TEST EQUlPMENT: Procedures control. Since the equipment will be used CLOSED "for preliminary checks where data obtained will not be ,
- Sechon B.9.a of the QAPM states that the program for controlling used to determine acceptability or be the basis for measuring and test equipment does not include " permanently installed design or engineenng evaluation"it is not M&TE this operating equipment or test equipment used for prefirrunary checks clarif. cation is just pointing the fact out. It is consastent t where data obtained will not be used to determine acceptabshty or be with the W3 requirements ,
2 the basis for design or engineenng evaluation". How will this equipment be controlled? (It is noted in RBS. QAD-12, page 3 of 6, 10/7/98 meeting sechon 6.4 that control of this equipment is addressed.) Issue discussed and resolved. !
Q-99 AUDITING: Level of detail of the review. An auda or all areas wis CLOSED i be performed at least once every 2 years. The
'What is the difference between assessing annually the adequacy of available information, including any audits performed, t I
implementation of the QAPM (Sechon A.3.c), and auditinc will be reviewed once per year. We can put them both Revision dated 10/08/98 ,
W Entergy QAPM review matrix Number Comment Response Closed? Submit?
performance of activities required by the QAPM to meet Appendix B at on a 2 year schedule if that is preferred. A 2 year least once every two years (Seebon C2.a.2.)? schedule for the overall assessment was approved for Pilgram.
10/7/98 meeting issue discussed and resolved.
Q-100 TECHNICAL SPECIFICATIONS: The items are included in the package. CLOSED
- Need to review all the Tech Spec relocation information for RBS e.g .,
and GG. Transmittal letter indicates Tech Spec information for ANO and W-3 coming under separate cover letter. What's the status? Attachment 4 pages 85 through 89 and pages 112
'hrough 114 Attachmer:t 5 pages 21 through 26 and pages 73 and 74 10/7/98 meeting issue discussed and resolved. W3 and ANO submittals are in the review process.
O-101 In section A.6.d of the QAPM, is the review of the disposition of non- 10/7/98 mee'ing CLOSED conforming items performed on an " independent" basis? (See section issue discussed and resolved.
152.6., page 112 of the ANO QAM).
O-102 For procedure reviews, exceptions are taken to ANSI N18.7, sechon 10/7/98 meeting CLOSED 52.15 (See Table 1 section C. RG 1.33, items 22 and 23) regarding As discussed in Discussion of Change L7, the the reasons for and frequency of procedure reviews. Instead of the procedure penodic review requirements at the sites are provisions of the ANSI standard, OAPM section A.6 (Corrective made consisteni Each of the sites has a different Action) will be followed. Sechon A 6 does not address procedure description of the procedure penodic review reviews per se although their review as a result of a condition adverse requirements in the current quality assurance to quality is implied. It does not address use of procedures that have programs. The proposed QAPM has procedure e been dormant for some time, nor does it address procedure reviews periodic review requirements which are based on those related to plant rnodifications - ncne of which is related to corrective previously approved for ANO.
action. Please clarify. What has been the licensees
- experience regarding the need for procedure reviews over the years? Issue discussed and resolved.
NRC position on review of procedures is as follows:
- applicable plant procedures shall be reviewed fol!owing an unusual event or modification to a system (See ANSI N18.7, section 5.2.15),
- non-routine procedures shall be reviewed at least every two years.
- QA shall review a representative sample of routine procedures at least every two years, and Revision dated 10/08/98
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Entergy QAPM review matrix Number Comment Response Closed? Submit?
EOl said that they would consuler the changes and the ;
Staff said that they would consider whether their concems are valid. [
Post 10/7/98 meeting '
EOI will modifiy the QAPM to include the audits change C.2.a.2 as follows.
Audit schedules assure that the following areas are audited at the indicated frequencies, or more frequently as perfor'riance dctates
- a. The conformance of each unit's operaten to provisens wiiGsed within the Technical Specificatons and applicable license condsbons is r audited at least once every 24 months l
- b. The pc,fe.n>6 rice, training, and qualificabons of the entire staff is audited at least once every 24 months
- c. The results of acnons taken to correct deroencies ,
occumng in unit equipment, structure, systems, or ;
method of operation that affect nuclear safety is {
audsted at least once every 24 months. i
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- d. The perfomiance of achvebes required by the QAPM !
to meet the entena of 10 CFR 50, Appendix B is
- audited at least once every 24 months. ,
- e. The Offsite Dose Ch% Manual and Process Control Program and implemenhng procedures is
- audited at least once every 24 months.
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- f. The radological environmental monstonng program
- and the results thereof is audited at least once overy I 24 months !
- g. The fire protection program and implementing t i procedures at least once 12 months. l 1
- h. A fire protecticn and loss prevention program inspection and audit shall be performed using f either off-site licensee personnel or an outside fire [
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- Revision dated 10/08/98 L
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Entergy QAPM review matrix mmber comment nesponse tw-n sutwnri protection firm at least once 24 months.
L A fire protection and loss i,.;.x!a program inspection and audit shall be performed using an outside fire consultant at least once M rnonths.
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