ML20197A684
| ML20197A684 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/15/1997 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9712230127 | |
| Download: ML20197A684 (9) | |
Text
i-Dave Morey _
Southern Nuclear We Presdent Operating Company Iarley Propet R0 Bos 1295-thrmingham, Alatrama 35201 Tel 20; 992.5131 '
SOUTHERN COMFANY December 15. 1997 g
g,g,g Docket Nos.: 50-348 10 CFR 50.54(a)(3) 50-364 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Final Safety Analysis Report Quality Assurance Program Changes Cruiftcation of Nondntructive Testing Personnel 1.adies and Gentlemen.
Pursuant to 10CFR50.54(a)(3), attached is a change to the Farley Nuclear Plant (FNP) Final Safety Analysis Report (FSAR) Quality Assurance (QA) Program Description for your review and approval. The FNP FSAA QA Program description is located in Section 17,2 of the FNP FSAR.
The FSAR QA program description is being revised to remove the reference to Americati Society for Nondestructive Testing Recommended Practice No. SNT-TC-1 A August 1980 Edition for qualification and certification of personnel performing nondestructive testing at FNP, Details of compliance with SNT TC-l A are proposed to be relocated to another section of the FS AR (Section 3 A) which describes specific compliance with NRC Regulatory Guides and is capable of being changed under the regu!ations in 10CFR50.59. Later editions of SNT-TC-1 A are already approved by the NRC through updates to the regulations associated with new ASME Boiler and Pressure Vessel Codes in 10CFR50.55a. Therefore, removing the reference to SNT-TC-1 A from the FNP FSAR QA program description will eliminate the need for redundant NRC approval due to potential" reductions in commitments" which may be entailed when incorporating a new edition of SNT-TC-1 A.
SNC desires approval to use the 1984 Edition of SNT-TC-1 A, However, since the 1984 version allows increased flexibility in recertification of personnel, this change is considered an extremely small reduction in the QA program commitments. SNC has evaluated the impact of this change and has concluded that the later version of the standard meets the requirements of I
10CFR50 Appendix B and satisfies the intent of SNC's commitments to the NRC concerning qualification and certification of NDE personnel.
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9712230127 971215 PDR ADOCK 05000348 P
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j U.~ S. Nuclear Regulatory Commission -
Page 2 -
If there are any questions, please advise;
- Respectfully submitted,-
SOUTilERN NUCLEAR OPERATING COMPANY -
gh 91ve Dave Morey SOM: cit:sntclar2. doc.
- Attachments:
- 1. - 10 CFR 50.54(a)(3) Evaluation
-cc: - Mr. L. A. Reyes, Region 11 Administrator
' Mr. J.1. Zimmerman,' NRR Project Manager Mr T. M. Ross, Plant Sr. Resident inspector n
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O ATTACliMENT I Final Safety Analysis Report Quality Assurance Program Changes 10CFR50 54(aV3) Evaluation m..
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6 ATTACHMENT 1 Final Safety Analysis Report Quality Assurance Program Changes 10CFR50.54(a)(3) Evaluation AlkCICdhEn See attached FSAR pages 17.211,17.2-12 and 17.213.
flcsqIiption of the Changes The FSAR QA program description is being revised to remove the reference to American Society for Nondestructive Testing Recommended Practice No. SNT-TC-1 A August 1980 Edition for qualification and certification of personnel performing nondestructive testing at FNP Details of compliance with SNT-TC-l A are proposed to be relocated to another section of the FS AR (Section 3 A) which describes specific compliance with NRC Regulatory Guides and is capable of being changed under the regulations in 10CFR50.59.
SNC desires approval to use the 1984 Edition of SNT-TC-1 A. Since the 1984 version allows increased flexibility in recertification of personnel, this change is considered an extremely smal! reduction in the QA program commitments.
RCit$nttfor the Changes in the current FSAR QA program description, SNC is committed to the previous revision of SNT TC-I A which was issued in June 1980. The 1984 version allows increased flexibility in the recertification of NDE personnel. This change will also facilitate the procurement of verdor NDE personnel who are certified to SNT-TC-1 A 1984 under their own QA programs. Since the 1984 version allows increased flexibility in recertification of personnel, this change is considered an extremely small reduction in the QA program commitments. Later editions of SNT-TC-l A are already approved by the NRC through updates to the regulations associatet. with new ASME Boiler and Pressure Vessel Codes in 10CFR50.55a. Therefore, removing the reference to SNT-TC-la from the FNP FSAR QA program description will eliminate the need for redundant NRC approval due to potential" reductions in commitments" which may be entailed when incorporating a new editior of SNT-TC-1 A.
Basis for the Acceptability of the Changes SNC has reviewed SNT-TC-1 A 1984 and has concluded that it fully satisfies the intent of 10CFR50 Appendix D Criterion 11, _ Quality Assurance Program, and Criterion IX, Control of Special Processes.
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- Attachment 1:
10CFR50.54(a)(3) Evaluation
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SNC has compared SNT-TC-1 A 1984 with SNT-TC-l A 1980 and has concluded that the later version of the standard meets the requirements of 10CFR50 Appendix B and satisfies l'
-the intent of SNC's commitments to the NRC concerning qualificction and certification of LNDE personnel.
_ The NRC, via Regulatory Guide 1.147, ha; endorsed ASME Code Cases N-356 and N-445 which directly address the change from SNT-TC-1 A 1980 to SNT-TC-1 A 1984. The NRC has also endorsed the 1989 ASME Code in 10CFR50.55a which invokes SNT-TC-l A 1984 for_ qualification and certification of NDE personnel.
Moving the detail of compliance with SNT-TC-I A to section 3A of the FSAR is acceptable since changes to this section will still be controlled by 10CFR50.59.
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i ATTACHMENT 2 ESAR Mark-Uplages D
FHP-FSAR-17 FSAR section 17.2 are met and that adequate controls are included to ensure that the safety-related functions of existing plant structures, systems, or components will not be compromised or impaired by the construction of an MMA.
After initial acceptance, the appropriate QA programs will be reviewed by the MSAER at least annually a6
'ng as such work is being performed.
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APC pGS Department will also provide technical support for SNC, as required on matters other than MMAs.
Such services performed by APC PGS Department or SCS are under the cognizance of the OQAP.
l 17.2.3 QUALITY ASSURANCE PROGRAM The OQAP became fully effective when components or sy~ stems were turnsd_over from the APC Construction Department, at the completion of construction, to the APC startup staff for component /
preoperational testing, and it is in affect throughout the operational-life of the FNP.
The objective of the OQAp is to provide adequate assurance of quality during operation of the FNP by complying with the provisions described in the OQAPM and procedures listed in the OQAPIL which satisfy the criteria of 10 CFR 50, Appendix B.
This program applies to operational activities affecting the functioning of those safety-related structures and systems listed in section 17.3.
Subsection 17.2.1 deLcribes the functions and authorities of organizations that are responsible for performing activities which affect the quality of safety-related equipment.
These SNC l
organizations, SCS, and APC's PGS Department ensure that the l
safety-related activities for which they are responsible will provide adequate quality by developing, approving, and ensuring adherence to written approvad procedures as necessary.
Each organization is responsible for developing procedures that provide controlled conditions for activities within its scope.
All prerequisites-or environmental conditions necessary for performing an activity will be soecified in these procedures.
Within each procedure any special controls or conditions such-as required equipment, skills, inspection points, etc., will be delineated.
The plant staff will follow written approved procedures except as discussed in chapter 14 and section 13.5, which allow for procedura departure when_the safety of the_
plant or personnel is endangered.
There sections discuss the method of approving temporary and permanent changes-to previously approved procedures.
17.2-11 REV 10 6/92 l
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E FNP-FSAR-17 j
i The OQAPIL liets SAER procedures, FNP administrative-procedures, and nuclear support administrative procedures which have been written to comply with the applicable criteria of 10 CFR 50,-Appen6tx B.
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The OQAP shall provide for indoctrination and training of personnel performing safety-related activities to ensure that the individual attains quality in job performance and complies j
with APC quality policies and procedures.
Basically, this quality indoctrination and training is provided in two
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phases:
OQA orientation training, and qualification and i
l training for specific tasks.
The FNP OQA orientation training program was develop,ed with assistance from SAER.
Training in the OQAPM may be ;. resented by videotaped lectures.
This renual describes the spfety-related and nontifety-related activities, duties, and authorities of each group assigned OQA responsibility in the OQAP.
These presentatienn will encompans various types of safety-related operational activities, such as the QA filing system, receipt inspection, control of documents, inspection after maintenance, and approval of design changes.
There will be a list of required attendees for each lecture as dqtermined by the GMNS, GMNP, and MSAER.
Racords of_the orientation will be developed and retained
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as quality records.
This program will be repeated to serve as an annual refresher for those who previously passed the course and to provide indoctrination and training for new employees.
Each group involved in the OQAP is responsible for qualifying and requalifyjng its personnel, as required, to ensure that the required -level of competency is maintained.
This qualification includes proper selection of candidates for avrilable positions and successful. completion of training that will provide the required knowledge for performing assigned duties.
This training may be provided by preplanned lectures and/or on-the-job training.
Subsection 13.1.3 and section 13.2 discuss the qualifications s
maintained by and-the t;aining-program required for plant staff.
All plant staff who are assigned the responsibility and authority.to approve inspection and test procedures, implement these procedures,-and'evsluate and report the results of the tests and inspections shall be certified as to their levels of capability in compliance with the requirements of Regulatory Guide 1.58, Revision 1, dated September 1980, which references ANSI l N45.2.6-1978.
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17.2-12 REV 5 7/87
FNP-fSAR-17 0:' ; ;h ll 2::t th: :
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721: rrat; in 00:7 7; 1A The nuclear plant general manager shall l
determine the acceptance of experience @alifications, based on the guidelines presented 2n ANSI N45.2.6-1978, for capability levels in areas of testing and inspection other than NDE.
Any test and inspection work performed by contractors for the plant staff shall also be performed by personnel who meet the qualifications required in Regulatory Guide 1.58, Revision 1, dated September 1980.
The group responsible for performing the test or inspection, whether it is the plant staff or contractors, shall specify detailed methods or procedures for.these activities unless stated in contract documents.
Appropriate training and certification records will be maintained by the nuclear plant general manager for each person l
designated to perform inspection and testing functions.
.?ersonnel performance evaluations will be maintained et the General Office ar.d will not be a part of the certification records.
SAER is responsible for training its personnel to meet the requirements of the OQAP.
An SAER administrative procedure, listed in the OQAPIL, details educational and training requirements for each SAER staff member.
APC PGS Department, SCS, and SNC are responsible for the training of personnel within their organization that is required to assure that the individual attains quality in job performance and complies with the
. requirements of the OQAP and approved codes, specifications, and instructions for activities witain the scope of the OOAP.
The vice president is responsible for approving the OQAPM and any changes taereto.
The MSAER has the responsibility for making suggestions concerning the OQAP and the OOAPM to the vice president for his evaluation.
The vice president is responsible for regularly reviewing the status and effectiveness of the FNP OQAP.
He accomplishes this by reports from the MSAER, Corporate Headquarters Farley Project, the Plant Farley site organization, and-the NORB.
17.2.3 DESIGN CONTROL Heasures are established to assure that for design changes and/or modifications for the operating nuclear plant, applicable regulatory requirements, quality standards, and design bases are properly translated into specifications, drawings, procedures, and instructions.
17.2.3.1 -Quality Assurance (Other Than Nuclear Fuel Suppliers)
Design changes-and/or modifications during plant operations
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will be-handled in c - nner which will comply with the requirements of ANSI tw. 2.11-1974 and thereby maintain 17.2-13 REV 13 4/96
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