ML060380561
| ML060380561 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie, Seabrook, Turkey Point, Duane Arnold  |
| Issue date: | 02/06/2006 |
| From: | Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation |
| Moroney B, NRR/DLPM, 415-3974 | |
| References | |
| TAC MC9450 | |
| Download: ML060380561 (10) | |
Text
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-i/4, By 1Nf %ev%f o Bob S>res and John Lqfie FP&L Ed Akrtin and Jim AMcllcr- S&L NRC Prteseatilon. February 6,J 20'06
QA Program Standardization Project Current QA Program Basis
- FPL and Seabrook based on ANSI N18.7, ANSI N45.2 and other Construction Era Standards. Duane Arnold is based on NQA-1 (1994)
- In some cases plants commit to different revisions of the basis documents
- Plants take different alternates/exceptions to many of the commitments contained in the QA Program standards
- Proposed QA Program Basis
- ASME NQA-1 (1994) based
- One QATR for the FPL Fleet containing all QA Program Commitments
- Simple reference to QATR in the FSARs
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- NRC approved alternates and exceptions , -q '.
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QA Program Standardization Project Why We Are Doing It Reasons for QA Program Standardization Project
- Remove a significant impediment to standardization of processes across the FPL Fleet
- Use of NQA-1 which is a supported and maintained standard
- Simpler and easier to understand program
- Reduced administrative burden
- Reduced organizational detail precluding the need for frequent QATR /
FSAR changes
- Facilitate further expansion of the FPL Nuclear Fleet 0E- .-
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QA Program Standardization Project How We Did It QA Program Standardization Stratecy
- Developed a Fleet QATR model (NMC NRC approved QATR modified to reflect organizational differences)
- Performed a detailed review of each plant's QA Program commitments against the Fleet QA I R model.
- Identified differences (both over and under commitments)
- Reviewed each proposed QATR section and matrix of differences using the QA Program review process
- Resolved differences and developed final Fleet QATR
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QA Program Standardization Proiect Proposed Submittal Package
- Documentation Package to be Submitted to NRC
- FPL QATR Request to NRC Letter
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- r^nciinn rATD n pa 11 '.j'.~L4 ~ I '%.gKI I I I I 1I VIQI'.JE I '.JL
- Enclosure 2 - QATR Comparison Matrices Enclosure 2-1 Duane Arnold Enclosure 2-2 Seabrook Enclosure 2-3 St. Lucie Enclosure 2-4 Turkey Point
- Enclosure 3 - List of QATR Exceptions/Alternatives to NMC-1
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NRC Submittal - QATR Contents
- Introduction - B.10 Inspection, Test and Operating Status
- A. Management
- B.11 Special Process Control
- A.1 Methodology
- B.12 Inspection
- A.2 Organization
- B.13 Corrective Action
- A.3 Responsibility
- B.14 Document Control
- A.4 Authority
- B.15 Records
- A.5 Personnel Training and Qualification - B.16 Plant Maintenance
- A.6 Corrective Action - 5.17 Computer Software Control
- A.7 Regulatory Commitments
- C. Assessment
- B. PerformanceNerification - CA Methodology
- B.1 Methodology - C.2 Self-assessment
- B.2 Design Control - C.3 Independent Assessment
- B.3 Design Verification
- Appendices
- B.4 Procurement Control - APPENDIX A - On-Site Review Group
- B.5 Procurement Verification - APPENDIX B - Procedures
- B.6 Identification and Control of - APPENDIX C - Definitions Items - APPENDIX D - Revision Summaries
- B.7 Handling, Storage and Shipping
- B.8 Test Control
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- B.9 Measuring and Test Equipment 19A Control FPL
NRC Submittal - Enclosure 2 Example becTIon 1; ASbtSMINTI I he worws in te current program wI IHU 1 a Is less mIanm111Im Vut um REVIEW AND AUDIT Appendix A On-SNe Review Group 'Regulatory Guide 1.33 and ANSI N18.7- program, It Is not a reduction in 1976/ANS 3.2 requirements for reviews commitments as defined in 10 CFR and audits form the basis for the program' 50.54(a)(3)(ii). The NRC and Is not in the proposed program. NMC have already determined that this meets 10 CFR 50, Appendix 8 as documented In NRC Safety Evaluations dated 911/05, 3/24/05 and 1/13/05 approving Revisions 1 and 0 of NMC-1 and In NMC transmittals to the NRC such as those dated 10131/03 and 6117/05.
13.4.1 Onsite Review Appendix A On-Site Review Group Note name difference between current See above.
program (SORC) and proposed program (ORG).
The current program details the R - #2 responsibility of the Station Operation Review Committee (SORC) and Company Nuclear Review Board (CNRB). The proposed program eliminates the CNRB and combines responsibilities under the Onsite Review Group (ORG).
13.4.2 Independent Review Appendix A On-Site Review Group R - #2 The current program details the See above.
(same as responsibility of the Station Operation earlier) Review Committee (SORC) and Company Nuclear Review Board (CNRB). The proposed program combines these into the Onsite Review Group. Many of the details contained in this section of the current program should be contained in lower tier procedures of the proposed program.
13.4.3 Independent Technical R - #3 The Technical Review Program described SER dated 8126199. Transmitted to Reviews In the current program is not in the Mr. J.A. Scalice (TVA} from .MH. N.
proposed program. Berkow (NRC).
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Note 1:
R - Reduction In commitment N - Not a reduction in commitment APL I - Increase in commitment
NRC Subinittal- Enclosure 3 Example AXRptI - .
Section B.4
- FPL may apply a 90-day grace period to a. FPL takes exception to Regulatory Position C.3.2 concerning a grace requirement to audit suppliers on a triennial basis. period for the triennial audits of suppliers. This meets Criterion XVIII of 10 When the grace period is applied, the next due date CFR 50, Appendix B insofar as audits of suppliers are still periodic.
for the activity is based upon the original scheduled Reference the SER contained in NRC letter from G. S. Vissing to R. C.
date. However, in all cases the periodicity shall not Mecredy. RG&E, dated July 22, 1998.
exceed three-year plus 90 days. This is an alternate to Position C.3.2.1 of Regulatory Guide 1.28, Revision 3.
- When purchasing commercial grade calibration b. FPL may accept of a supplier of commercial grade calibration services services from a supplier that has been accredited by other than by audit. This meets Criterion VII of 10 CFR 50, Appendix B a nationally recognized accrediting body (NAVLAP insofar as measures are established to assure that calibration services or other accrediting body rfuugnized by NAVLAP uonform Io the procurement documents by source evaluation and selection via a Mutual Recognition Agreement (MRA)), FPL and objective evidence of quality furnished by the calibration supplier, as may accept the accreditation in lieu of performing an appropriate. Reference the SER contained in NRC letter from D. S. Collins audit, accepting an audit by another licensee or to G. R. Overbeck, APS.
conducting a commercial grade survey. In order to accept the accreditation FPL will perform a documented review of the supplier's accreditation.
Section B.14 Temporary changes to procedures identified in FPL does not require that one of the two members of plant staff who approve Appendix B are approved by two members of plant staff temporary changes to procedures hold an active senior reactor operator knowledgeable in the areas affected by the procedure, license. Rather, the person's license may be inactive. While this may mean at least one of whom is a person holding a senior that the person's knowledge of current plant configuration is not as extensive reactor operator's license. as the holder of an active license, the approver does have an understanding of the operation of the plant as well as access to plant and other documentation.
This meets Paragraph 17.3.1l.B.14.c insofar as revisions to controlled documents are approved by qualified and knowledgeable personnel. It also meets Criterion VI of 10 CFR 50, Appendix B insofar as changes to documents are approved by authorized personnel.
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Project Goals Once documentation package is submitted to NRC*
- Informal working relationship - answer questions and resolve without a large number of Requests for Additional Information 6 month turnaround time to facilitate QATR implementation at each of the sites by year-end
- Ability to add any future units with minimal difficulty
- Goal for submittal is end of February 0__ ....
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FqPL QA ProgramPr Stnorizja Prject Discussion