ML17059A789

Proposed Change to QA Tr.

ML17059A789
Person / Time
Site:	Nine Mile Point
Issue date:	04/21/1995
From:	NIAGARA MOHAWK POWER CORP.
To:
Shared Package
ML17059A790	List: ML17059A789 ML18040A160
References
NUDOCS 9505010065
Download: ML17059A789 (26)

Text

ATTACHIVKNT A PROPOSED CHANGE TO THE QUALITY ASSURANCE TOPICAL REPORT NIAGARA MOHAWK POWER CORPORATION INZM MILE POIIVl" UNIT 1 AI'6)Ul.'GT 2

cri'P ban e Copies of the affected Quality Assurance Topical Report (QATR)pages, highlighted to reflect proposed changes, are included in this attachment.

A new organization chart is also included.QATR Section B.1.2.1.1,"Nuclear Division Responsibilities," item number 4 on page B.1-4', which describes the authority and responsibilities of the Manager Quality Assurance, is being revised to add three (3).tasks to those that the Manager Quality Assurance currently performs to fulfill his responsibilities.

Additionally, this same section is being revised to add, on page B.1-5, the position of Supervisor

-Quality Services and his responsibilities.

QATR Table B-l,"Quality Assurance Program Responsibility Matrix," is being revised to add document control and quality assurance records procedure responsibilities to Quality Assurance and to delete those responsibilities from Nuclear Engineering.

A Quality Assurance organization chart is being added to the QATR.The QATR is a single document that is located in both the Nine Mile Point Unit 1 (NMP1)FSAR (Updated)and the Nine Mile Point Unit 2 (NMP2)USAR as Appendix B.The changes proposed for the QATR will be made in both the NMP1 FSAR (Updated)and the NMP2 USAR.The reporting structure for the Manager Quality Assurance is incorrectly described in the second sentence of the first paragraph of item number 4 on page B.1-4 of the current QATR.Niagara Mohawk has corrected this by use of a"Licensing Document Change Request." The correct reporting structure is: "The Manager Quality Assurance reports to the Vice President Nuclear Safety Assessment and Support[NSAS]for administrative issues and QA activities outside the NSAS organization and reports directly to the Executive Vice President Nuclear for all QA activities relating to the NSAS organization." The Commission has been notified of this reporting structure by Niagara Mohawk's December 20, 1994 letter (NMPlL 0887).This correction to the QATR will be submitted to the Commission, per 10 CFR 50.71(e), in the periodic update of the Safety Analysis Report.

4.The Manager Quality Assurance has overall authority and responsibility for formulating and directing the QA Program.The Manager Quality Assurance reports directly to the Executive Vice President Nuclear on quality-assuring functions while reporting administratively to the Vice President Nuclear Safety Assessment-and Support.The Manager Quality Assurance's responsibilities include verifying that the policies and procedures associated with the overall quality of design, operation, maintenance, and m'odification of Unit 1 and Unit 2 are effectively implemented and result in safely-operated plants within design and licensing basis commitments.

Tasks performed to fulfill these responsibilities include:~Audits~Surveillances

~Inspections

~ISI and Erosion/Corrosion Examinations (Visual and NDE)~Procurement QA~Exercising Stop Work Authority~Coordinating and Reporting Internal and External QA Assessments

~Operations Experience Assessments

~Administering the Evaluation and Corrective Action Program for Deviation Event Reports (DERs)~DER Trend Analysis~Preparing and Processing QA Organization Documents.':4+$@gghr.Admi'n'i'::PiC,'i';;.'":8~ex:v.

cis'a~b.The Supervisor Quality Inspection reports to the Manager Quality Assurance and is responsible for activities that include, but are not limited to, inspections and examinations for product acceptance of modification and maintenance activities (safety related and nonsafety related), performing in-service inspection (ISI)examinations (visual and NDE), and performing erosion/corrosion examinations.

The Supervisor Quality Verification/Safety Assessment reports to the Manager Quality Assurance and is responsible for activities that include, but are not limited to, conducting performance-based surveillances,

ine Mile Point Unit 1 FS~~~~c~determining applicability of industry and in-plant, operating experience, assisting in root cause evaluations when requested, and DER trend analysis.The Supervisor Quality Assurance audits reports to the Manager Quality Assurance and is responsible for QA activities that include, but are not limited to, performing QA audits.d.The Supervisor Procurement Quality Assurance reports to the Manager Quality Assurance and is responsible for QA activities that include, but are not limited to, performing source surveillances of selected procurements.

ie.'c'orBi"+m'an'ag'ement~-'4'.;.:;d'o'curn ed~8'Ic onto@'ljj'.'~0 admih'i@tr'ativ'e@~siWices)%".;QA@cler'ical':.".support Xuiict:ions')~

B.1.2.1.2 Corporate Support Responsibilities Certain corporate departments provide support services in the areas of: (1)testing and maintenance of electrical power system protective devices and metering equipment; (2)calibration and maintenance of portable measuring and test equipment; and (3)fire protection and fire personnel training.These corporate support functions are described in Unit 1 UFSAR Section III.A.1 and Unit 2 USAR Section 13.1.1.UFSAR Revision 13 B.1-5 June 1995

TABLE B-1 QUALITY ASSURANCE PROGRAM RESPONSIBILITY-MATRIX Regulatory Requirements Industry Standards NMPC Policy/Directives and Zmplementing Organization Procedures 10CFR50 Appendix B BTP 9.5-1 Appendix A NQA-1 ANS-3.2 NMPC Management Policy and Directives NSAS NP Procedures TS NE NG NIP"'.Organization ZI.QA Program IIZ.Design Control IV.Procurement Document Control C.l C.l l,ls-l 2,2s-1 2s-2 2s-3 3,3s-l 4,4s-l 1 3.1 3.3 3.4.2 3.1 3.3 5.1 5.3 3.4.2 3.5 5.2.7.2 5.2.13.1 V.Instructions, Procedures

&Dwgs.C.2 5.2.7 5.3 VI.Document Control VII.Control of Purch.Matl.VIII.Ident./Contxol of Matl.ZX.Control of Special Processes X.Inspection XI.Test Control XII.Control of M&TE C.3 C.4, C.6 C.5 6, 6s-1 7,7s-l Ss-1 9,9s-1 10,10s-l ll,lls-l 12,12s-l 5.2.15 5.2.13.2 5.2.13.3 5.2.18 5.2.12 5.2.17 5.2.19 5.2.16 1 of 2

TABLE B-1 (Cont'd.)Regulatory Requirements Industry Standards NMPC Policy/Directives and Implementing Organization Procedures 10CFR50 Appendix B BTP 9.5-1 Appendix A NQA-1 ANS-3.2 NMPC Management Policy and Directives NSAS NP Procedures TS NE NG NIP"'IZZ.Handling, Storage and Shipping XIV.Inspection, Test, and Operating Status C.6 13,13s-l 5.2.13.4 5.2.6 5.2.14 XV.Nonconforming Materials, Parts, or Components XVI.Corrective Actions XVIZ.Quality Assurance Records XVIZZ.Audits C.j C.8 C.9 C.10 15,15s-l 16 17,17s-l 18,18s-l 5.2.14 5.2.11 5.2.12 Nuclear Interface Procedure (NIP)includes QA Organization as well as other nuclear organization responsibilities.

Functional positions and responsibilities within the NSAS organization are established and controlled by NSAS Administrative Procedure.

NMPC Or anizations NSAS-Nuclear Safety Assessment and Support, which includes: QA-Quality Assurance NL-Nuclear Licensing NP-Nuclear Procurement TS-Technical Services NT-Nuclear Training NE-Nuclear Engineering NG-Nuclear Generation, which includes: Operations, Maintenance, Chemistry, Radiation Protection, Technical Support, and Work Control Outage 2 of 2

Quality Assurance Vice President-Nuclear Safety Assessment

&, Su ort Executive Vice President-Nuclear (For all QA acti+ties relating to the NSAS organization)

Manager-Quality Assurance Supervisor

-Quality Assurance Audits Supervisor-Procurement Quality Assurance Supervisor

-Quality Veri6cation 2 Safety Assessment Supervisor-Quality Inspection Supervisor

-Quality Services

ATTACHME B 10 CFR 50.54(a)(3)

EVALUATION FOR THE PROPOSED CHANGE TO THE QUALITY ASSURANCE TOPICAL REPORT NIAGAID, MOHAWK POWER CORPORATION NENE MILE POINT UAT 1 A2'G)UNIT 2

Int ductio Reason orthe han e The Nuclear Engineering Department formerly included an Information Management Branch, which was responsible for the following functions:

Document Control/Records Management, which were jointly responsible for the receipt, indexing, and storage of plant records and the implementation and administration of the document control program (distribution, retrieval, and control).Software Development, which was responsible for the administration and control of business and nonprocess computer applications.

Since the Information Management Branch provides common support functions for the entire nuclear organization, the functions were relocated to the Nuclear Safety Assessment and Support (NSAS)Department, which is responsible to provide common support functions for the entire nuclear organization.

In anticipation of organizational changes after the Spring 1995 refuel outages at Nine Mile Point Units 1 and 2, an interim transition organization was established to allow for adequate preparation and for the changes required for establishment of a longer-term organization.

A new General Supervisor Document Control/Records Management has been appointed, who is responsible and accountable for all aspects of the Document Control/Records Management process.The Manager, Information Management serves as an advisor for the transition, and reports directly to the Vice President-NSAS.The functions performed by the Document Control/Records Management and Software Development groups are unchanged.

This organizational change was performed under the provisions of 10 CFR 50.59.Changes to the Quality Assurance Topical Report (QATR)that resulted from this organizational change will be submitted to the Commission, per 10 CFR 50.71(e), in the periodic update of the Safety Analysis Report.Niagara Mohawk now wishes to relocate the responsibilities of Records Management and Document Control to the Quality Assurance Branch of the NSAS Department (Software Development will continue to report directly to the Vice President-NSAS).The reason for this proposed change is that Niagara Mohawk anticipates improvements in the quality of services from Document Control and Records Management following their incorporation into the Quality Assurance organization.

The anticipated improvements will be a direct result of QA oversight of Records Management and Document Control, and the detailed knowledge and understanding of Quality Assurance Records, Appendix B criteria, and the Quality Assurance Topical Report that the Manager Quality Assurance possesses.

This proposed change necessitates a revision to the QATR.Before changing the QATR, an analysis was performed, which determined that the proposed change involves a reduction in commitment from the QATR previously accepted by the NRC.The reduction of commitment refers to the increased oversight responsibility of the Manager Quality Assurance following incorporation of Document Control and Records Management into the Quality Assurance Branch of the NSAS Department.

As these groups are added to the Quality Assurance Branch, the extent of oversight of existing groups is diminished.

Therefore, pursuant to 10 CFR 50.54(a)(3), Niagara Mohawk is requesting NRC review and approval of this QATR change.Page 1 f

Evaluation Niagara Mohawk wishes to relocate the responsibilities of Document Control and Records Management to the Quality Assurance Branch of the NSAS Department.

In support of this proposed reorganization, an analysis was conducted to determine if the change would continue to satisfy the criteria of 10 CFR 50 Appendix B.Five (5)of the eighteen Appendix B criteria were determined to be potentially affected.A review of these five criteria are as follows: m a t f r i i nal h e nA ndixB ri ri nI" r anization":

The Manager of Quality Assurance will continue to maintain responsibility for the execution of the Quality Assurance Program following the addition of Document Control and Records Management to the Quality Assurance organization.

The authority and duties of persons and organizations performing activities affecting safety-related functions of structures, systems, and components will not be impacted by the incorporation of Document Control and Records Management into the Quality Assurance organization.

Methods of oversight, audit, and inspection will remain the same.Concerning organizational freedom and independence of personnel to report safety considerations, nuclear personnel are responsible to initiate Deviation Event Reports (DERs)for conditions having adverse or potentially adverse effects on structures, systems, components, activities important to nuclear safety, industrial safety, plant reliability, or human performance.

This will remain in effect.Im c f r i i n 1 han eon A ndixB rieri nII" li A n~Pr ram" Niagara Mohawk has established a quality assurance program that complies with the requirements of 10 CFR 50 Appendix B.The program is documented by written policies and procedures and will be carried out throughout plant life in accordance with those policies and procedures.

As detailed in the Niagara Mohawk Power Corporation Quality Assurance Program Topical Report (NMPC-QATR-1), Niagara Mohawk has identified the structures, systems, and components covered by the quality assurance program and major organizations participating in the program, together with the designated functions of these organizations.

To maintain an accurate depiction of identified structures, systems, and components covered by the Quality Assurance Program and major organizations participating in the program, QATR Table B-l,"Quality Assurance Program Responsibility Matrix," is being revised to add Document Control and Quality Assurance Records procedure responsibilities to Quality Assurance and to delete those responsibilities from Nuclear Engineering.

A Quality Assurance organization chart is also being added to the QATR.Following the incorporation of Document Control and Records Management into the Quality Assurance Branch of NSAS, the above specified changes to the QATR will reflect the actual structures, systems, and components covered by the quality assurance program and major organizations participating in the program.Designated functions of Document Control and Records Management will remain as specified in the QATR (Section B.6,"Document Control," and Section B.17,"Quality Assurance Records")Page 2 C

and in 10 CFR 50 Appendix B (Criterion VI,"Document Control" and Criterion XVII,"Quality Assurance Records").The Quality Assurance Program will continue to provide control over activities affecting the quality of identified structures, systems, and components, to an extent consistent with their importance to safety.Activities affecting quality will remain accomplished under suitably controlled conditions.'ontrolled conditions will continue to include the use of appropriate equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanness; and assurance that all prerequisites for a given activity have been satisfied.

The Quality Assurance Program will continue to take into account the need for special controls, processes, test equipment, tools, and skills, to attain the required quality, and verification of quality by inspection and test.The program will continue to provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.

Niagara Mohawk regularly reviews the status and adequacy of the Quality Assurance Program.Concerning the status and adequacy of that part of the Quality Assurance Program executed by the management of other organizations participating in the Quality Assurance Program, reviews are regularly conducted by the management of those other organizations.

Im c f r anizati n I han e on A ndix B ri erion VI"D ument ntr l": All existent measures established to control the issuance of documents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality will remain in effect after the incorporation of Document Control and Records Management into the Quality Assurance organization.

Documents, including changes, will continue to be reviewed for adequacy, approved for release by authorized personnel, and distributed to and used at the location where the prescribed activity is performed.

In addition, changes to documents will continue to be reviewed and approved by the same organizations that performed the original review and approval.Im ac f r anizai nal h n n A ndix B rieri n XVII" uali Assurance~Rgrr,~i" As evidence of activities affecting quality, following the incorporation of Document Control and Records Management into the Q'uality Assurance organization, records of operator logs, results of reviews, inspections, tests, audits, monitoring of work performance, and material analyses will continue to be maintained.

These records will continue to include closely-related data such as qualification of personnel, procedures, and equipment.

Inspection and test records will, as a minimum, continue to identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with deficiencies noted.Records will remain identifiable and retrievable.

Previously established requirements concerning records retention, such as duration, location, and assigned responsibility will remain in effect.Page 3

m ac f r ani i n 1 han e nA ndixB riteri nXVm"A di Following the incorporation of Document Control and Records Management into the Quality Assurance organization, the present system of planned and periodic audits will remain in effect to verify compliance with all aspects of the Quality Assurance Program and to determine the effectiveness of the program.Audits will continue to be performed in accordance with written procedures and audit specific scoping sheets (check list equivalent) by appropriately trained personnel not having direct responsibilities in the area being audited.Audit results will continue to be documented and reviewed by management having responsibility in the area audited.Where indicated, follow-up action, including reaudit of deficient areas, will be taken.A review was also conducted to determine if the change would continue to satisfy the other QATR commitments previously accepted by the NRC.No other reduction of commitments in the QATR was identified.

However, as a result of this review, two (2)items discussed in Section B.18 of the QATR require clarification.

First, B.18.2.3 states"Audits are performed in accordance with established schedules." Applicable Quality Assurance Program elements are audited at least once every two (2)years.Quality Assurance Program elements, including Document Control (10 CFR 50 Appendix B Criterion Vl)and Records Management (10 CFR 50 Appendix B Criterion XVII), presently fall under the above QATR specified two (2)year audit requirement, and will not be impacted by the proposed organizational change.Additionally, audits are presently performed and deficiencies documented on individual groups within the Quality Assurance organization.

Methods of Quality Assurance organization internal audit will remain in effect following the incorporation of Document Control and Records Management into the Quality Assurance organization.

Second, B.18.2.5 states,"Regularly scheduled audits are supplemented by special audits when appropriate.

Conditions which may warrant special audits include significant changes...

in the Quality Assurance Program." Here, the Quality Assurance Program refers to the implementation of the Quality Assurance process and/or philosophy.

This will not be impacted by the incorporation of Document Control and Records Management into the Quality Assurance organization.

Therefore, significant Quality Assurance Program changes are not being made and no special audit will be required following reorganization.

The reduction in commitment, identified by the analysis to change the QATR, refers to the increased oversight responsibility of the Manager Quality Assurance following incorporation of Document Control and Records Management into the Quality Assurance Branch of the NSAS organization.

The Quality Assurance Branch now has fewer personnel than prior to rightsizing in February 1994.With the addition of Document Control and Records Management personnel to the Quality Services section of Quality Assurance, the total number of persons and the number directly reporting to the Manager of Quality Assurance will be approximately the same as before rightsizing.

Therefore, the Manager Quality Assurance will be able to oversee these additional functions as well as oversee the existing Quality Assurance organization.

Page 4

0~n~clu egg The proposed change to the QATR relocates the Document Control and Records Management functions to the Manager Quality Assurance.

Niagara Mohawk anticipates that this proposed change will improve the quality of services from Document Control and Records Management.

This proposed change entails a reduction in QATR commitment; however, the change continues to satisfy the criteria of 10 CFR 50 Appendix B and the other QATR commitments previously accepted by the NRC.Further, the increased management oversight responsibility of the Manager Quality Assurance is considered to have minimal impact because the number of people supervised is approximately the same as prior to rightsizing of the Quality Assurance Branch in February 1994.Page 5

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