W3P87-2528, Forwards Addl Info Re Changes to Util QA Program,Per Lj Callan 871119 Request

Forwards Addl Info Re Changes to Util QA Program,Per Lj Callan 871119 Request

ML20238C981
Person / Time
Site:	Waterford
Issue date:	12/21/1987
From:	Cook K LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20238C983	List: ML20238D009 ML20238D015 ML20238D025 ML20238D027 W3P87-2528, Forwards Addl Info Re Changes to Util QA Program,Per Lj Callan 871119 Request
References
W3P87-2528, NUDOCS 8801040022
Download: ML20238C981 (4)

Text

. - _ _ _ - _ _ _ _ _ _ _ .

L 3

e. o. sox e0340 LOUISI&ANA POWER LIGHT/ 317NEWBAnownesTaser - + (504) 595-3100 ORLEANS, LOUISlANA 70160

$20$Es$

December 21, 1987 W3P87-2528 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Waterford 3 SES Docket No. 50-382 Updated Quality Assurance Program

REFERENCE:

NRC Region IV letter dated 11/19/87 from L.J. Callan to J.C. Dewcase (LP&L)

Gentlemen Pursuant to the request in the referenced letter, please find attached the additional information concerning a change to the LP&L Quality Assurance Program, i Should you have any further questions regarding this matter, please contact P.N. Backes, Nuclear Quality Assurance Manager at (504) 464-3466.

Very truly yours,

/ dc K.W. Cook da Nuclear Safety &

Regulatory Af f airs Manager KWC/TJG/plm Attachments cc: E.L. Blake, W.M. Stevenson, J.A. Calvo, J.H. Wilson, R.D. Martin, NRC Resident Inspector's Office (W3) 0

&C 8801040022 871221 PDR ADOCK 05000382 II P pp(Maen.

"AN EQUAL OPPORTUNITY EMPLOYER"

LP&L RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Request: Provide evidence that LP&L has an approved procedure for trans-ferring records to permanent storage which addresses the time limits and controls placed upon the temporary storage of records.

Response: Attachment #1, LP&L procedure NOP-003, " Records Management System" provides general requirements for the interim storage of records to the LP&L Nuclear Operations Department as stipu-lated in the following excerpts:

Para: 1.1 This procedure establishes the responsibilities and requirements for the collection, storage, and retention of records generated during the operations phase of the Waterford 3 SES.

1.3 This procedure applies to records generated by or for Waterford 3 SES.

4.4 Senior Management is responsible for ensuring that the requirements of tnis procedure are met by their respective departmental procedures and instructions.

5.2.4 Specific records requirements shall be incorpo-rated into Waterford 3 SES procedures. These procedures or a procedure shall contain as a minimum (in part) 5.2.4.3 the frequency of submittal of the records to Waterford 3 Records Center for final storage.

5.3.1 At a minimum, quality assurance records stored on an interim basis shall be afforded the pro-tection of a one hour minumum rated facility or storage cabinet. Access shall be controlled when the records are not in locked cabinets.

The requirements of NOP-003 are further defined in the imple-menting procedures. Based on the recent NOP-003 changes which include the interim storage requirements and other substantial changes due to the recent reorganization of the Nuclear Opera-tions Department (reference letter W3P87-2060, QA Program Submittal dated October 1, 1987), procedure development is not yet complete. However, as shown on the cover sheet of NOP-003, the senior managers of the LP&L Nuclear Operations Department are cognizant of the interim storage requirements and are committed to implement and include the provisions in their respective organization's procedures.

Page 2 Attachments #2 through #4 provide examples of the inclusion of the interim storage requirements in the lower tier imple-menting procedures as follows:

Attachment #2 - QAP-010, " Quality Assurance Recorde",

Section 5.2; Attachment #3 - MD-1-008, " Collection and Transmittal of Maintenance Records and Documents", paragraphs:

4.6, 5.2 and 5.3; and Attachment'#4 - RW-1-200, " Record Preparation, Filing and Storage", paragraph 3.3, 3.6 and 5.2 As shown in these implementing procedures, the frequency of submittal may vary although the interim storage requirements are essentially the same. Variations in submittal frequency are based on the organizations' individual needs. For example, the QA Group retains certain records in interim storage because they are relative to an on going audit. The records may include audit plans or checklists, etc. When the audit is complete (may exceed 30 days) the package is assembled and transmitted to permanent storage, The required interim storage measures are implemented for the " completed" records while they await transmittal.

I Request: Provide certification that the lessening of commitment will I not result in the loss of records.

Response: It is LP&L's position that ANSI N45.2.9-1974,

" Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants" does not provide sufficient instruction for the interim storage of owncr records. Further, we consider the need for interim storage guidelines essential.

It is not feasible to incorporate into procedures the require-ment that records are immediately transmitted to permanent storage upon completion. Under normal circurostances certain record types are held for record package assembly or review.

The requested interim storage guidelines provide the managers with the flexibility to perform their required functions while prudently handling the quality assurance records under proce-dural control. LP&L can procedurally address each record type and its transmittal requirements as necessary to assure effective handling. LP&L feels that procedural control of records stored on an interim basis represents an improvement to the guidelines provided by ANSI N45.2.9 as written and pr ovides an acceptable approach for prohibiting the loss of records.

_ _ _ _ _ J

g e

ATTACHMENT 1 NUCLEAR OPERATIONS PROCEDURE NOP-003 l

l 1

I 1

I i

_ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _