View source for 3F0592-02, Forwards Proposed Change to QA Program Description,Fsar Section 1.7 Re Frequency of Procedure Review.Qa Program Commitment Will Be Reduced to Comply W/Reg Guide 1.33,Rev 2

{{Adams
| number = ML20096E702
| issue date = 05/14/1992
| title = Forwards Proposed Change to QA Program Description,Fsar Section 1.7 Re Frequency of Procedure Review.Qa Program Commitment Will Be Reduced to Comply W/Reg Guide 1.33,Rev 2
| author name = Beard P
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| case reference number = RTR-REGGD-01.033, RTR-REGGD-1.033
| document report number = 3F0592-02, 3F592-2, NUDOCS 9205190326
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 6
}}

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May 14 -1992 3F0592-02                                                                                             .-
U. S. Nuclear Regulatory Commission Attn: Document Control Desk                                                                           ;
Washington. D. C. 05C5

==Subject:==
Change to Quality Program Description - Procedure Review                               :
i

==Dear Sir:==
I ln accordance with 10 CFR 50.54(a)(3), Florida Power Corporation (FPC) is submitt'ing' for_ NRC approval:a proposed change to the Crystal River Unit 3. (CR-3)
Quality Program Description -(FSAR ;Section 1.7). FPC proposos to reduce the                          .
Quality Program commitment to comply with Regulatory Guide 1.33, Revision 2 for                         ,
                         -the two-year review cycle (or procedures.
                                                     ~
The proposal was evaluated' as           i involving a reduction in commitment because some procedures may_ qui be reviewed within a:two: year period.
FPC's evaluation of this change in Quality Program commitments is provided as an attachment to this: letter. The programs described in Evaluatin Item 4. Basis                         1 fur Determination, contain provisions to. assure that the CR 3 Emeaency Operating                     ,
7            Procedures [ Emergency- Procedures (EP), Abnormal Procedures (AP), Verification                       '
N              Procedures (VP), etc.) are revised wher, necessary.. Experience has shown FPC that these programs result in reviews more frequently than every two_ years.
Thel programs discussed in tne attachment contain reviei . that will assure that necessary changes are: incorporated into plant procedbres. . Quality. Assurance 4                   Program (QAP) audits conducted throughout the year assess procedural adequacy or                      >
                         -the affectiveness of the procedure revision process. No single audit:is relied-3                         on to assess this process for all Nuclear Operations Department organizations.                        ,
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U. S. Nuclear Regulatory Commission 3f0592-02 Page 2                                                                                            ,
As required by the regulations, FPC is attaching to this letter all FSAR pages affected by this change, and the reasons for this change. The established management controls for CR 3 describcd in the attachment lead FPC to conclude that the revised program incorporating the change continues to satisfy the                        ,
criteria of 10 CFR 50, Appendix B.
iincerely.
                       ,,,-Uwlk P. M. / Beard, Jr.
Senior Vice President Nuclear Operations PMB/JWT Attachmer' xc: Regional Administrator, Region 11 Senior Resident Inspector NRR Project Manager f-
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ATTACliMENT TO FPC LETTER 3f0592-02                                                                             PAGE 1 Of 4 PROPOSED CHINGE TO THE QUALITY PROGRAM DESCRIPTION FSAR SECTION 1.7                                                                                i
: 1.       Description of Proposed Change:
Clarification 33 to FSAR Table 1.3 was added to d: scribe florida Power Corporation's (fPC) interpretation of ANSI N18.7-1976, Section 5.2.15 regarding the f requency of procedure review.                                   This revised guidance eliminates the two-year review cycle for procedures.
: 2.       Reason for the Proposed Change:                                                                                                        ,
This change will allow a more -effective allocation of plant resources.
Rather than review procedure; which are used infrequently, or which are not likely to be used in the near term, simply to utisfy a two year review cycle, pit.nt resources can be more focused on supporting planned activities and addiassing a trent problems.
This change more clearly defines our program and expectations for procedure reviews. Maintaining procedures in an accurate and useful condition is t dynamic process.            The need for change may be iderntified at various t'mes for various reasons._ Requiring a static review process, in addition, is unnecessary _and may be counterproductive.
: 3.        The Proposed Change does involve a reduction in a FPC Regulatory Commitment                                                           ,
in that some procedures may not be reviewed within a two year period.
: 4.        Basis for.the Acceptability of the Reduction:                                                                                         .
FPC has established explicit management guidance on procedure changes.
This guidance includes a requirement that if the activity cannot be performed in accordance with the procedure, or the procedure governing the activity should not be followed, the activity must be stopped pending a procedure revision or supervisory guidance.
In addition, various other management controls exist which requiis knowledgeable personnel to review and modify plant procedures.                                              Scme examples are:
: 1.           The- plant modification program requires a review of the. proposed modification by affected groups. This review requires identification of procedures needing revision to support a return of the syst6m to operable status.         Such changes must be made concurrent with modification implementation and a,'e carefully tracked as part of the modification process.
                     . 2.           The corrective action program requires root causes for significant problems be determined and corrective action implevented. Review of affected procedures and subsequent revision, if needed, is an integral part of the corrective action process.
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f ATTACHMENT 10 FPC LETTER 3f0592 02                                     PAGE 2 Of 4
: 3. The operating experience review program includes reviews of items such as NRC regulatory changes, bulletins and notices, generic letters, and INPO Significant Event Reports, Significant Operating Event Reports and other NETWORK communiques for applicability and action. Actions include procedure revisions when appropriate.
: 4. Vendor bulletins, technical manual changes and netices are als~
evaluated for applicability and actions. Actions include procedu-revisions when appropriate.
: 5. Evaluation of changes to the License, Technical Specificat. ions, FSAR, or Quality Prog,am includes identification of ths need to revise procedures.      If necessary,   such procedure changes are issued concurrent with the source document revision.
: 6. Corrective actions for NRC inspections provide another opportunity for the evaluation and revision of procedures as necessary.
: 7. The procedure change process assures that reviewers from interfacing departments affected by procedure changes are assigned as inter-disciplinary Qualified Reviewers. This process assures related procedures are updated concurrently.
: 8. The Qualified Reviewer program assures that all procedures applicable to Regulato y Guide 1.33, November,1972., are reviewed by personnel who have bwn formally trained and certified.       Recurring training provides needed updates when changes dictate.
: 9. The Nuclear Operations Commitment System (NOCS) is used to track commitments and the procedures developed to implement those commitments. A step in the NOCS process requires a review of all procedures referenced in the NOCS database against : particular commitment. This process assures that a commitment :hange is reflected in plant pcocedures in a timely manner.

a ATTACHMENT TO FPC LETTER 3f0592-02                                       PAGE 3 Of 4 FSAR SECTION 1.7 TEXT CHANGES
      @R,C Reaulatory Guide 1.33 (Continued)
: 27) With regard to Section 5.3.9.3 of ANSI N18.7 - 1976 titled Procedures (nr Implementina Emeroency Plan: FPC's NRC accepted Emergency Plan for Crystal River Unit 3 shall be implemented in lieu of the requirements in this Section.
: 28) Paragraph C.1 and Appendix A of Regulatory Guide 1.33 shall be implemented as required by the Crystal River Unit 3 Technical Specification 6.8.a'.1,
             " Procedures."
: 29) With regard to Section 3.4.2 of ANSI hl8.7-1976 titled Reouite_m_gnts for the Onsite Operatina Org.anizations:           Some of FPC's technical support organizations are physically located at tb CR 3 site. Therefore, the second sentence of this section shall be impbmented as follows: " Initial incumbents or replacements for members of the onsite operating organization and onsite or offsite technical support organizations shall have appropriate experience, training, and retraining to assure that necessary competence is maintained in accordance with the provisions of nmerican National Standard for Selection and Training of Nuclear Power Plant Personnel, N18. i 1971".
For purposes of implementing Section 3.4.2 as clarified above, FPC also defines the FPC Relay Department Technicians who may perform safety-related activities at CR-3 to be members of an offsite technical support organization.
: 30) With regard to L ction 5.2.19.1 of ANSI N18.7-1976 titled _fre operational Tests:     This section will only apply in the event of major modification activities which are similar in nature and extent to those activities that occurred during initial construction of CR-3.
: 31) With regard to Section 5.2.10.2 of ANSI N18.7 1976 titled Tests Pripr Tg And Durino Initial plant Operatiqn: This period of operation has already passed ano therefore this section is not applicable.
: 32) With regard to Section 2.2 of ANSI N18.7-1976 titled Glossary of Terms:
Definitions in this Standard which are not included in ANSI N45.2.10 shall he used. All definitions which are included in ANSI N45.2.10 shall be used as clarified in FPC's commitment to Regulatory Guide 1.74.          The term "onsite operating organization," defined in general terms in this Standard, shall be synonymous with " Facility Staff" which is defined in FPC's commitment to Regulatory Guide 1.74.
33)"$th regafd to Section;5Z15~of ANSI"18.7?l976 titled Revief Apprpyal'and Control'of Procedures; in lieu of wording starting with the second sentence initiie third paragraph of;this~ section;jbeginning With iThe frequency.of 1-125                            (Rev. XX) l

ATTACHMENT TO FPC LETTER 3f0592-02                                                                                                                        PAGE 4 Of 4
                                                        ..., Tthrough  "
the end                    7 of'the fourth ~paragfaph, which ends "... a procedure review.",;FPC provides thel following . alternative guidant.c:
                                                                                                                                                                                       ~
                                                         " Pro ~c edJ r'e s 's h al 1 ~ tie " reVi s'ed 'a s~neif e s s 'a ry . Th'sse"reVisioniwillLgenerally be initiated through ' reviews conducted by personnel during routine                       .
perforr.ance-of activities. : Example of such reviews include evaluations of problems : encountered - during performance of a - procedure, evaluation - of                                ~~
corrective actions' for deficiencies or - events, evaluation ofi events occurring .at .other: plants,.L evaluation ofl procedure char.ges . necessary to implement' modificati6ns, evaluation .of procedure changes: necessary to implement License, Liechnical Specification, or FSAR revisions as- well as evaluations 1of changes necessary to . resolve Regulatory Issues.                                                                         Such thangest shal14 be : implemented as necessary.                                                                    'In some, situations, such implementation will Lbe!compir:p,7tiora.to completion' of the in process
                                                         ' activity .. Guidance on the nosi                                                                       ~@pDcedures. shal.1 bc provided in plant Qinistrative, controls; f,fth 1-125a                           (Rev. XX)2
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