ML20216H673

SER Accepting Quality Assurance Program Description Change for Joseph M Farley Nuclear Plant,Units 1 & 2

ML20216H673
Person / Time
Site:	Farley
Issue date:	03/17/1998
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20216H667	List: ML20216H663 ML20216H673
References
NUDOCS 9803230121
Download: ML20216H673 (3)

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UNITED STATES y

j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20066-0001

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SAFETY EVALUATION BY THE OFflCE OF NUCI FAR REACTOR REGULATIOh[

QUALITY ASSURANCE PROGRAM DESCRIPTION CtBNGE SOUTHERN NUCLEAR OPERATING COMPANY. INC.. ET AL.

l JOSEPH M. FARI FY NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-348 AND 50-364

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1.0 INTRODUCTION

i By letter dated December 15,1997, and as revised by letter dated March 10,1998, Southern Nuclear Operating Company, Inc. (SNC) proposed a change to the Farley Nuclear Plant (FNP)

Final Safety Analysis Report (FSAR) Quality Assurance (QA) Program Description pursuant to 10 CFR 50.54(a)(3). SNC requested approval to use the 1984 Edition of SNT-TC-1 A rather ,

than the 1980 version currently specified in its QA Program Description. In addition, SNC proposed relocating the details of compliance with SNT-TC-1 A to Section 3A of the FEAR.

2.0 EVALUATION 2.1 SNT-TC-1A-1984 Edition SNC's QA Program Description is contained in Section 17.2 of the FNP FSAR. SNC is presently committed in its QA Program Description to Regulatory Guide 1.59 Revision 1, j

, " Qualification of Nuclear Power Plant inspection, Examination, and Testing Personnel," dated l

September 1980, which references ANSI N45.2.6-1978 and SNT-TC-1 A-1975 for qualification of personnel performing nondestructive testing. Exception was taken to the use of SNT-TC-1 A-1975 in the current QA Program Description with SNT-TC-1 A-1980 t$aing specified instead for ,

persons performing nondestructive examinations. SNC requested approval to use the 1984 version as it allows increased flexibility in recertification of inspection personnel.

In addition to the very small reduction in commitment in allowing increased flexibility in recertification of inspection personnel, many requirements, which were worded as 'shail' in the i

1975 version, were changed to "shoulds' in the 1980 version and also in the 1984 version, which SNC requested approval to use. SNC proposed to include in its discussion of conformance with Regulatory Guide 1.58 contained in FSAR Section 3A a requirement that the "shoulds" contained in SNT-TC-1 A will be replaced with "shalls" where "shalls" occurred in the 1975 version.

The staff conducted its review in accordance with the guidance in Section 17.2, " Quality Assurance During the Operational Phase," of NUREG-0800, " Standard Review Plan" (SRP 17.2). The introduction paragraph of Section ll, " Acceptance Criteria," of SRP 17.2, l

Enclosum 9803230121 DR 980317 ADOCK 05000348 PDR

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l contains provisions for the use of attematives to the acceptance criteria provided they are evaluated by the staff and are considered to be in compliance with pertinent NRC regulations. j Based on the staffs review, !t was determined that the use of SNT-TC4A-1984 proposed by SNC is acceptable for use in meeting SRP 17.1.9.B.1, which is referenced by SRP 17.2.9.

. S_RP 17.1.9.B.1 states, in part, that " personnel associated with special processes are qualifed -  !

and are in conformance with applicable codes, standards, QA procedures, and specifications." i This determination was based on the facts that: (1) Regulatory Guide 1.58, Revision 1, .

endorses SNT-TC-1A-1975 for qualification of personnel performing nondestructive testing, )

(2) commitments to. Regulatory Guide 1.58, Revision 1, and ANSI N45.2.6-1978 are retained in  !

the QA Program Description, and (3) the above stated commitment regarding replacing i "shoulds" with "shall' makes any reduction in commitment from the 1975 to 1984 version of j SNT-TC-1A small and the requirements of 10 CFR Appendix B will continue to be met. j 2.2 Relocating Details of Compliance With SNT-TC-1 A To FSAR Section 3A l

SNC is presently committed in its QA Program Description to Regulatory Guide 1.58, Revision ';

1, which endorses ANSI N45.2.6-1978 and S'NT TC-1 A-1975 for qualification of personnel I performing nondestructive testing. Exception was taken to the use of SNT-TC-1 A-1975 in the )

current QA Program Description with SNT-TC-1 A-1980 being specified instead. SNC proposed  ;

to remove the description of this exception from the QA Program Description in FSAR l Section 17.2 and relocate it to Section 3A of the FSAR where conformance to Regulatory Guide 1.58 is discussed. The following statement regarding conformance to SNT-TC-1 A-1975 is i proposed to be included in the Section 3A discussion of conformance to this regulatory guide. l l

In lieu of this, the version of SNT-TC-1A or other similar document used for  !

_ qualifying personnel at Farley Nuclear Plant to perform nondestructive  ;

inspection, examination, or testing snall be in accordance with Section XI of the -

ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where specific written relief has been granted by the i NRC. The document used for the qualification of such personnel shall be j specifically identified in the Inservice inspection Program for FNP. In addition, FNP shall supplement these requirements by replacing the "shoulds" contained in SNT-TC-1 A with "shalls" where they occurred in the 1975 version.

There is sufficient regulatory control here to ensure that the correct version of SNT-TC-1 A is being used in addition, the basic commitment to Regulatory Guide 1.58, Revision 1, remains in the QA Program Description in Section 17.2 of the FSAR with regulatory control under 10 CFR 50.54(a)(3). Also, in accordance with SRP 17.1 Swction ll, commitments to comply with the regulatory positions presented in the appropriate issue of the regulatory guide are an integral part of the QA Program Description. Therefore, any changes to the above commitment would also be controlled under 10 CFR 50.54(a)(3), thereby maintaining regulatory control for the relocation of the details of the commitments to Regulatory Guide 1.58. However, it was noted that in SNC's evaluation of the acceptability of this change that a statement was made

which said, in part, " Moving the details of compliance with SNT-TC-1 A to section 3A of the FSAR is acceptable since changes to this section will still be controlled by 10CFR50.59...."

Although this statement veas included in SNC's evaluation, clarification was provided in a conference call with the licensee's staff on March 12,1998. SNC indicated that it is realized that 10 CFR 50.54(a)(3) requirements would also apply here for changes in commitments to this regulatory guide. Therefore, relocation of the details of conformance to SNT-TC-1A to Section 3A of the FSAR is acceptable, provided that any future changes are submitted in accordance with 10 CFR 50.54(a)(3) as required.

3.0 CONCLUSION

The staff has deterrriined that the proposed use of SNT-TC-1 A-1984, with the conditions as previously described, is acceptable for use in meeting SRP 17.1.9.B.1 criterion for ensuring personnel associated with the special process of nondestructive testing are qualified and are in conformance with applicable codes, standards, QA procedures, and specifications. In addition, relocating the details of conformance with SNT-TC-1A to Section 3A of the FSAR is acceptable, provided that changes to the QA Program Description contained in Section 3A are reported as required by.10 CFR 50.54(a)(3). Provided that the above described QA program controls are properiy implemented, the proposed changes are acceptable and continue to meet the pertinent requirements of Appendix B to 10 CFR Part 50.

Principal Contributor: R. Smith Date: March 17, 1998 l

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