ML17263A349

Forwards Rev 18 to QA Program for Station Operation, for Dec 1992.Rev 18 Includes Changes in Commitment for Sets of Responsibilities

ML17263A349
Person / Time
Site:	Ginna
Issue date:	08/05/1993
From:	Mecredy R ROCHESTER GAS & ELECTRIC CORP.
To:	Andrea Johnson NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation
Shared Package
ML17263A350	List: ML17263A349 ML17263A351
References
NUDOCS 9308110398
Download: ML17263A349 (9)

Text

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ACCESSION NBR:9308110398 DOC.DATE: 93/08/05 NOTARIZED: NO DOCKET FACIL:50-244 Robert Emmet Ginna Nuclear Plant, Unit 1, Rochester G 05000244 AUTH. NAME AUTHOR AFFILIATION MERCREDY,R.C. Rochester Gas a Electric Corp.

RECIP.NAME RECIPIENT AFFILIATION JOHSON,A.R. Project Directorate I-3

SUBJECT:

Forwards Rev 18 to "QA Program for Station Operation," for I Dec 1992.Rev 18 includes changes in commitment for 'sets of responsibilities. D DISTRIBUTION CODE: Q004D COPIES RECEIVED:LTR Q ENCL / SIZE: 0+ 2K.

TITLE: QA Topical Report, Change, Amendment, or Correspondence (Docket Utili NOTES:License Exp date in accordance with 10CFR2,2.109(9/19/72). 05000244 1 RECIPIENT COPIES RECIPIENT COPIES ZD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL JOHNSON,A 1 1 D INTERNAL: NRR/DRIL RPEB 1 1 OC/LFDCB E FILE Ol 2 2 RGN1 FILE EXTERNAL: DMB/OSS 1 1 IHS 1 1 NRC PDR 1 1 D

D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 504-2065) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 9 ENCL 9

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ROCHESTER GAS AND ELECTRIC CORPORATION o 89 EAST AVENUE, ROCHESTER N.Y. 14649-0001 ROBERT@ MECREOY TELEPHONE Vice Prerident AREA CODE 71B 546 2700 Gtnna Nudear Production Augus't 5I 1993 U. S. Nuclear Regulatory Commission Document Control Desk ATTN: Mr. Allen R. Johnson Project Directorate I-3 Washington, DC 20555

SUBJECT:

Revised Submittal of Quality Assurance Program R. E. Ginna Nuclear Power Plant Docket Number 50-244

Dear Mr. Johnson:

In accordance with 10 CFR 50.54 enclosed is a modified revision 18 to the Quality Assurance Program for Station Operation trans-mitted to you on December 30, 1992. This revised submittal provides information in response to questions raised during phone conferences with NRC Region I reviewer, Fred Bower. Revision 18 includes changes in commitment for two sets of responsibilities.

The first change is to remove the requirement for Quality Perfor-mance to concur on procedures directly implementing the quality assurance program. This change involves a change in commitment, but is not considered to be a reduction in effectiveness as the responsibility for Quality Assurance review of procedures still exists and Quality Performance assessment of these activities has increased due to the initiation of the Quality Assurance Surveil-lance program. The responsibility for procedure adequacy belongs solely to the responsible management of the associated activi-ties. This reinforcement of line organization responsibility for procedure adequacy is being adopted throughout the industry.

The second responsibility change involving a change to commitment removes Quality Assurance responsibility for reviewing corrective "

action reports to assure that the cause was determined and that adequate corrective action has been taken to preclude recurrence.

This activity is currently assigned to and is being performed by the Plant Operations Review Committee CAR subcommittee in addi-tion to Quality Assurance. Quality Assurance performs two audits annually of the corrective action program as required by Techni-cal Specification 6.5.2.8. In addition, this area is assessed by Quality Assurance surveillances, as items that are significant conditions adverse to quality are often Quality Assurance sur-veillance topics or have in process Quality Assurance involve-ment. Deleting Quality Assurance review and concurrence from what has been a redundant independent review will have no impact on the commitment for independently assuring the adequate identi-fication of actions being taken to preclude recurrence.

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These changes will not reduce the effectiveness of the Ginna Station Quality Assurance Program nor reduce any of our previous commitments. This is based on the following considerations:

The removal of Quality Performance from concurrence with procedures is compensated by assignment of that responsibil-ity to responsible management and and by audits and surveil-lances of procedure adequacy implementation by Quality Performance.

The removal of Quality. Assurance review and concurrence with corrective action reports cause determination and action to preclude recurrence is compensated by the Plant Operations Review Committee CAR Subcommittee performing this task and by audits and surveillance being performed of both the corrective action program and individual corrective action reports.

The other title and responsibility changes do not reduce any commitments but reflect organizational changes to improve Rochester Gas and Electric's ability to safely, legally and efficiently implement the Quality Assurance Program require-ments and intent.

Changes made to revision 17 of the Quality Assurance Program for station operation are denoted by a single revision bar in the left margin.

Very truly yours, Robert C. Mecredy RCMhlmch069 R1

~

Enclosures xc: Mr. Allen R. Johnson (Mail Stop 14Dl)

Project Directorate I-3 Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Mr. Fred Bower U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector

ATTACHMENT 1 Summar of Revision 18 Chan es Section 1 ualit Assurance Pro ram Quality performance no longer concurs with new procedures and changes but will assure procedure adequacy through review and through audits and surveillances of a sample of new procedures and procedure changes.

Clarification to location of detailed listing of structures, systems and components covered by the Quality Assurance Pro-gram.

The 4th Paragraph sentence was removed to allow controlled procedures to be maintained in any controlled environment, such as a computer database.

Section 2 Or anization Identified that Ginna Station in lieu of Quality Performance has a responsibility for assuring that significant condi-tions adverse to quality are identified and corrected.

Identified that Nuclear Engineering Services, and Quality Performance have a responsibility for tracking and providing report summaries for conditions adverse to quality. This responsibility was reassigned from the Manager, Quality Assurance.

Identified that Nuclear Engineering Services is responsible for providing Technical Support to Ginna Station.

Clarified the reporting relationships for the Manager, Material Engineering and Inspection Services.

Section 3 Desi n Control

~ Appropriate title and responsibility changes.

Section 4 Procurement Document Control

~ No changes.

Section 5 Instructions Procedures and Drawin s Quality Performance will no longer concur with new or re-vised procedures implementing the quality assurance program.

Through audits, surveillances and verification inspections, Quality Performance is responsible for verifying commitments are addressed.

Other editorial changes.

Section 6 Document Control

~ Quality Performance will no longer concur with new or re-vised procedures implementing the quality assurance program.

~ Minor clarifications and editorial changes.

Section 7 Control of Purchased Material E ui ment and Services

~ Minor responsibility changes, clarifications and editorial changes.

Section 8 Identification and Control of Materials Parts and Com onents

~ Removed one redundant sentence and clarified that the sub-ject activities are to be accomplished in accordance with approved procedures.

Section 9 Control of S ecial Processes

~ No changes.

Section 10 Ins ection Consolidated two mostly redundant paragraphs into one con-cerning inclusion of hold points and inspection requirements in instructions, procedures and fabrication processes.

Changed Nuclear Assurance requirement to do all inspections to Nuclear Assurance is responsible for assuring inspections are done by properly trained and certified personnel.

Section 11 Test Control

~ No changes.

Section 12 Control of Measurin and Test E ui ment

~ No changes.

Section 13 Handlin Stora e and Shi in

~ Added Nuclear Engineering Services responsibility for re-viewing engineering specifications on this subject.

Section 14 Ins ection Test and 0 eratin Status

~ No changes.

Section 15 Nonconformin Materials Parts and Com onents

~ Minor clarifications.

Section 16 Corrective Action Changes to definition of a condition adverse to quality and a significant condition adverse to quality were made to remove the list of potential causes of these conditions and replace them with a descriptive definition.

The responsibilities and processes for handling significant conditions adverse to quality were clarified and reassigned to those organizations currently responsible. The Plant Operations Review Committee CAR Subcommittee is replacing Quality Assurance as the independent review group assuring that adequate corrective action has been taken to preclude recurrence. Quality Assurance oversight of this process will be by audit and surveillance of the program and select-ed corrective action reports.

Section 17 ualit Assurance Records

~ Clarified that Production and Engineering Systems is solely responsible for maintaining and retaining quality assurance records.

Section 18 Audits

~ Minor correction to text inadvertently left out of revision 17 submittal.

Table 1-1 Tables'of De artmental Im lementin Procedures

~ Changes reflect significant procedure improvement activities for 1992. Production Division Training procedure manual has been issued and is reflected in the table.

Table 4-1 Procurement Document Re uirements

~ No changes.

Table 18-1 Audit List

~ No changes Fi ures 2-1 throu h 2-6

~ Minor changes; none which affect quality assurance program activities.

Miscellaneous

~ Typographical and editorial changes incorporated throughout the document where deemed appropriate.

All changes from previous revision 17 are identified with a vertical line in the left hand margin of each page. Each page will be identified as revision 18 since the entire document was reprinted in lieu of only the revised pages.

Tables and figures which contain changes are identified by a vertical line in the left margin next to their reference in the index, page ii.