ML20206R900

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SER Accepting Nuclear Quality Assurance Program Changes for Point Beach Nuclear Plant,Units 1 & 2
ML20206R900
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 01/13/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20206R892 List:
References
NUDOCS 9901200443
Download: ML20206R900 (3)


Text

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ME:o UNITED STATES

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j NUCLEAR REGULATORY COMMISSION g

t WASHINGTON, D.C. 2066H001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO NUCLEAR QUALITY ASSURANCE PROGRAM CHANGES WISCONSIN ELECTRIC POWER COMPANY POINT BEACH NUCLEAR PLANT. UNITS 1 ANDJ, DOCKET NOS. 50-266 AND 50-301

1.0 INTRODUCTION

In letters dated November 16,1998, and November 30,1998, the Wisconsin Electric Power Company (WE), in accordance with requirements in 10 CFR 50.54(a)(3), submitted two letters transmitting revisions to Section 1.4 of the Final Safety Analysis Report (FSAR) for Point Beach Nuclear Plant, Units 1 and 2 (PBNP). Section 1.4 of the FSAR describes the current Nuclear Quality Assurance (OA) Program implemented at PBNP. The proposed changes consist of reassigning the reporting requirements of the Non-Destructive Examination (NDE) Services group from the Nuclear Assurance Manager to the Engineering Programs group in the corporate offices in Milwaukee. Another proposed change would revise Quality Verification's (OV) responsibilities for tracking deficiencies identified during audits, surveillances, and work monitoring reports to be required only for QA program deficiencies. FSAR page 1.4-4 and Figure 1.4-1 have already been changed from the current FSAR page 1.4-4 and Figure 1.4-1 because they were determined not to be a reduction in commitment by the licensee, and therefore were not submitted to the NRC for approval.

2.0 EVALUATION 2.1 Reassionina the Reportina Reauirements of NDE Services Group The proposed changes would consist of replacing the phrase "The OA section is divided into five groups (see Figure 1.4-1) three of which have specific OA responsibilities, summarized as follows:" on FSAR page 1.4-4 with the phrase "The Nuclear Assurance section organization is depicted in Figure 1.4-1." The proposed change would also delete the discussion of the NDE Services responsibilities of the Nuclear (Quality) Assurance Manager on FSAR page 1.4-6 and would revise FSAR Figure 1.41 to reflect that the NDE Services group no longer reports to the Nuclear Assurance Manager.

The changes would eliminate the engineering and administrative duties of the Nuclear Assurance Manager related to managing the NDE Services group. This change is a reduction in commitment because the NDE Services group would no longer report to the Nuclear Assurance section, which is independent of the line organization. The NDE Services group is ENCLOSURE 9901200443 990113 PDR ADOCK 05000266 P

PDR

2 currently identified as having' specific OA responsibilities on FSAR page 1.4-6. Although the NDE Services group is no longer organizationally independent of the line organization, the NDE Services group will still be independent of those groups actually performing or directly supervising the work being inspected. This is permitted by ANSI Standard N18.7-1976, j

Section 3.2, which states, "(2) Verification of conformance to established requirements is j

accomplished by a qualified person who does not have responsibility for performing or directly j

supervising work."

l Control of NDE services performed by the NDE Services group will continue to be described in FSAR Sections 1.4.9 and 1.4.10. FSAR Section 1.4.9, " Control of Special Processes," states, j

" Procedures and practices are established and documented to assure that special processes, such as welding, heat treating, and nondestructive examinations are controlled and i

accomplished by qualified personnel using qualified procedures or process sheets in accordance with applicable codes and standards." FSAR Section 1.4.10 " Inspection," states, j

"All nondestructive examination personnel are required to be qualified in accordance with the appropriate sections and editions of ASNT [American Society for Nondestructive Testing]

Recommended Practice No. SNT-TC-1 A." The Quality Verification group, under the Nuclear Assurance section, will continue to provide independent oversight of the NDE Services group as pad of the independent quality verifying activities prescribed by FSAR Section 1.4.

2.2 Trackina Deficiencies Another proposed change would consist of revising Quality Verification's (QV) responsibilities for tracking deficiencies identified during audits, surveillances, and work monitoring reports to s

i be required only for OA program deficiencies. This proposed change would consist of deleting j

the word " deficiencies" and replacing it with "QA program deficiencies" and deleting the word "not" and adding " including those initiated as a result of quality assessments which are not QA program deficiencies"in the first and second sentences respectively of the FSAR Section 1.4.1, Quality Verification (item 8). The proposed changes would also delete " deficient areas" and add "QA program deficiencies" under FSAR 1.4.18.

ANSI Standard N45.2.12-1977, to which WE is committed, defines, in part, in Section 1.4 a OA program deficiency as a " Failure to develop, document, or implement effectively any applicable element of the quality assurance program...." It then establishes in Section 3.2.4-5 that the objectives of QA assessments are to identify both nonconformances and QA program deficiencies, but to (only] verify correction of identified QA program deficiencies. ANSI Standard N45.2.12-1977 Section 4.3.2.4-7 states, "When a nonconformance or quai!ty assurance program deficiency is identified as a result of an audit, further investigation shall be conducted by the audited organization in an effort to identify the cause and effect and to determine the exterit of the corrective action required. Nonconformances or quality assurance program deficiencies should be acknowledged by a member of the audited organization.

Conditions requiring immediate corrective action shall be reported immediately to management of the audited organization. Specific attention should be given to corrective action on program deficiencies identified during previous audits." Also, ANSI Standard N18.7-1976, Section 5.2.14, " Nonconforming items," to which WE is committed, states in part, " Measures shall be provided to control items, services or activities which do not conform to requirements.

These procedures shall include as appropriate, instructions for identification, documentation, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented

3 procedures.' The responsibility and authority for the disposition of nonconforming items shall be defined. Repaired and reworked items shall be reinspected in accordance with applicable procedures."

3.0 CONCLUSION

The staff has reviewed the November 16,1998, and November 30,1998,10 CFR 50.54(a) submittals in accordance with NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapters 17.1 and 17.2, and determined that the changes to the FSAR Section 1.4 continue to satisfy the criteria of Appendix B to 10 CFR Part 50. PBNP states that the nonconformances discovered during the audit process will be entered into the corrective action program as a Condition Report and tracked or monitored by other Nuclear Power Business Unit groups to closure within the corrective action program. This is acceptable because (1) PBNP continues to fully implement ANSI Standard N45.2.12-1977 and ANSI Standard N18.7-1976, and (2) the QV organization will continue to audit the overall corrective action program under its Appendix B,10 CFR Part 50 QA program as described in FSAR Sections 1.4.16 and 1.4.18.

Principal Contributor: M. Bugg Date: January 13, 1999 i