ML18022A492
| ML18022A492 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 12/24/1986 |
| From: | Cutter A CAROLINA POWER & LIGHT CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML18022A493 | List: |
| References | |
| NLS-86-467, NUDOCS 8612290181 | |
| Download: ML18022A492 (22) | |
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ACCESSION NBR: 8612290181 DOC. DATE: 86/12/24 NOTARIZED: YES DOCKET 0 FACIL: 50-400 Shearon Harris Nuclear Power Plant. Unit i. Carolina 05000400 AUTH. NANE AUTHOR AFFILIATION CUTTER> A. B. Carolina Power Zc Light Co.
REC IP. NAI'lE RECIPIENT AFFILIATION DENTONi H. R. Office of Nuclear Rea tor Regulation. Director (post 851125 B@s~s l~/W
SUBJECT:
Forwards Amend 38 to ISA'. A nd provides follow up to 861126 ltr 8c includes onlg changes to Chapter 17 completing transition from preoperations G*/GC program. to operations GA/GC program.
DISTRIBUTION CODE: BOOID COPIEB RECEIVED: LTR Q ENCL Q BI ZE: Q ~lZ TITLE: Licensing Submittal: PSAR/FSAR Amdts 5 Related Correspondence NOTES: App licati on for permit renewal fi 1 ed. 05000400 RECIPIENT COPIES I REC IP ENT COP IES ID CODE/NANE LTTR ENCL ID CODE/MANE LTTR ENCL PMR-A EB 1 1 P MR-A E I C SB 2 2 PMR-A FOB 1 PMR-A PD2 LA 1 1 PMR-A PD2 PD 1 1 BUCKLEY> B Oi .2 2 PMR-A PSB 1 1 PMR-A RSB 1 INTERNAL: ACRS 41 6 6 ADN/LFNB 0 ELD/HDS1 1 0 IE FILE 1 IE/DEPER/EPB 36 1 1 IE/DGAVT/GAB 21 1 NRR BMR ADTS 0 NRR PMR-B ADTS 0 N
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@ME, Carolina Power & Light Company SERIAL: NLS-86-067 DEC 2 4 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT DOCKET NO. 50-000/LICENSE NO. NPF-53 FSAR AMENDMENT 38
Dear Mr. Denton:
Carolina Power k Light Company (CPkL) hereby submits Amendment 38 to the Shearon Harris Nuclear Power Plant (SHNPP) Final Safety Analysis Report (FSAR). This amendment is a follow-up to our letter of November 26, 1986, and as such includes only revisions to Chapter 17. These changes essentially complete the transition from a Pre-Operations QA/QC Program to an Operations QA/QC Program. Also included, are various title changes as welI as updates of other non-QA department positions referenced and/or discussed in this chapter so that they are consistent with recent Chapter 13 organizational description changes. Finally, references to some of the responsibilities associated with completed construction activities have been deleted. The above changes were part of our November 26, 1986, submittal to Region II notifying them of changes to the QA/QC Program. One additional change (correctton) has been incorporated into this amendment. In Figure 17.2.1-1 of our November submittal, the Manager of Nuclear Staff Support Section was changed to Vice President of that Section. That was an editorial error, and as such, the change has been deleted in this submittal. These changes have been reviewed in accordance with 10 CFR 50.59 and determined not to constitute an unreviewed safety question.
Each page bears the amendment number, and technical changes are indicated by a vertical bar in the page margin. Should you have any questions concerning this amendment, please contact me.
Yo s very t y A. B. Cutter Vice resident ABC/SDC/bmc (5089SDC) Nuclear Engineering R Licensing Attachment cc: Mr.'. C. Buckley (NRC) tgtta ~ Maxwell (NRC-SHNPP)
- r. g~ +n Grace (NRC-RII)
At 6..Cuter ff ~Jeen first duly sworn, did depose and say that the information 1:onnlin~H'Ahin~ tt;ue and correct to the best of his information, knowledge and belief; end the sourges oR hihinformation are officers, employees, contractors, and agents of garglina 554er R Light Company.
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0 My co&nissidh expires: 2/16/88 411 Fayettevilte Street ~ P. O. Box 1551 o Raleigh, N. C, 27602 8b122'tt0181 8bl224 PDR ADOCK 05000400~
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17.2.1 ORGANIZATION SV~R~
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/@~5/5 5 The CP&L organization responsible for the safe operation of the SHNPP is described in Section 13.1. Figures 17.2.1-1 and 17.2.1-2 depict the QA organizational relationships for the SHNPP operations phase. The s .. of the QA organization is based on CP&L's considerable experience in op ation of nuclear plants (i.e. Brunswick Plant Units 1 and 2 and H. 8. inson Plant Unit 2). QA/QC staffing for SHNPP will be adequate to pro de coverage of ongoing activities (approximately 15-20 people). Staff g levels will be based on evaluation of schedules to fulfillthe QA/Q commitments of the FSAR.
17.2.F 1 QA Res onsibilities and Author es Carolina Power & Light Company policy re rding implementation of the OA Program is documented and made mandato through the Corporate QA Program.
The Policy Statement is signed by th CP&L Chairman/President. The policy states in part:
"It is the policy of Carolina P wer & Light Company to design, construct, and operate nuclear power plants ithout jeopardy to the public health and safety or to its employees. Quali y assurance programs shall be developed, implemented, and updated necessary to assure that systems used to produce, use, treat, store, or tr nsport waste produced by the generation of nuclear steam are designed, co tructed, and operated in a safe manner. Deviations from these programs s ll be permitted only upon written authority from the corporate management osition which originally approved the program or implementing proced res.
The design and co struction of nuclear power shall be accomplished in accordance with e Nuclear Regulatory Commission (NRC) regulations specified in Title 10 of e United States Code of Federal Regulations. All commitments to the NRC Reg atory Guides and to industry codes and standards shall be effectively i lemented.
The operatio of nuclear power plants shall be in accordance with the terms and conditi s of the facility operating license issued by the NRC. Any changes in perating procedures or experiments at the facility, modifications to plant c mponents or systems, revisions to nuclear plant safety analysis reports, proposed changes to plant technical specifications shall be made in accord nce with the terms and conditions of the facility operating license.
The Hana <er Corporate Quality Assurance is responsible for effective impleme tation of the approved Corporate Qality Assurance Program and ASHE QA Progra, as each applies, at the Company's nuclear construction sites and operat ng plants. Quality assurance and quality control (QA/QC) activt.ties shall e independent from scheduling and production commitments. The 'managers of QA QC activities shall have sufficient authority and organizational freedom to id Otify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. The Nanager Corporate Qiclity Assurance shall monitor the effectiveness of the Company's nuclear pre gram on a periodic basis through a system of planned and implemented inspections, surveillances, and audits.
- 17. 2.1-1 Amendment No. 6
SHNPP FSAR 0 ~
The Manager Corporate Quality Assurance shall review the overall effectiveness of the Company.'s quality assurance programs on a regular basis with the Executive Vice President - Power Supply and Engineering &
Construction, who has the ultimate Company responsibility Eor the safe construction and operation of nuclear power plants. The Manager Corporate Quality Assurance shall communicate directly with corporate management up to and including the Chairman/President/Chief Executive Officer and, if appropriate,'ith the Board of Directors to resolve any quality assurance concerns which cannot be resolved satisfactorily at a lower management level.
The managers of all functions invol.ving engineering, construction, nuclear fuel, operations, nuclear safety, and quality assurance shall assure that their personneL are adequately trained for their jobs and have the specified experience and education required to perform their assigned responsibilities.
Personnel who habitually or willEully disregard or violate nuclear safety and quality assurance policies and procedures shall be subject to disciplinary action."
The Chairman/President is responsible for'etting QA pol.icies, goals,,and objectives. The Senior Executive Vice President Power Supply & Engineering
& Construction, who reports to the Chairman/President, is responsible Eor establishing the Corporate Quality Assurance Program. He provides'or Management, Engineering, Construction, Procurement, QA/QC, Operations, Health Physics and Nuclear Safety.
The Senior Executive Vice President Power Supply and Engineering and Construction has overall responsibility for the Corporate Quality Assurance Program including approval of the program and revisions thereto. He operates through the Senior Vice President Nuclear Generation,'enior Vice President Operations Support, and the Manager Corporate Quality Assurance.
The Senior Vice President Nuclear Generation is responsible for managing the design, construction, operation and maintenance of the Hart. is and H. B.
Robinson plants. He has assigned the responsibility Eor managing the design, construction, operation and maintenance of the Harris plant to the Vice President " Harris Nuclear Project. He has assigned the responsibility for licensing and engineering support of the Company's nuclear generating facilities to the Vice President - Nuclear Engineering and Licensing Department. He has assigned the responsibility for procurement and contracting support'or all nuclear generating facilities to the Vice President - Nuclear Plant Construction Department. He has assigned the responsibility for coordinating the implementation and maintenance of programs that require high technical knowledge of methods and procedures that should be relatively consistent among the plants and performing staff studies to the Manager Nuclear Staff Support Section.
The General Manager - Harris Plant Operations Section who reports to the Vice President Harris Nuclear Project, is responsible Eor all operational phases of plant management, including operation, maintenance, and technical support. He manages and controls the organization through personal contact with the Assistant General Manager and seven unit heads and through written 17.2.1-2 Amendment No. 26
0 SHNPP FSAR reports, meetings, conferences, andin-plant inspections. He is responsible for adherence to all requirements of the operating License, technical specifications, Corporate Quality Assurance Program, and Corporate Health Physics and Nuclear. Safety policies. He is responsible for the review of incoming and outgoing correspondence with the NRC Office of Nuclear Reactor Regulation and the Office of Inspection and Enforcement concerning the Harris Plant; the establishment and approval of qualification requirements for all Harris Plant Operations staff positions', the personal review of, the qualifications of specific personnel for managerial and supervisory positions in the Harris Plant Operations Section; and the review of and concurrence. in the plant radiation protection, industrial security, quality assurance, fire protection, training, operations, and maintenance programs.
The Senior Vice President Operations Support is responsible for the management of the materials and fuel needs of the generating and transmission facilities, the training of those personnel, and the management of the functions, of Corporate Health Physics, Corporate Nuclear Safety, and safety analysis review at the nuclear plants. He provides senior management, up to and including the Chairman/President and the Board of Directors, a continuing assessment of current nuclear safety programs. Additionally, should any nuclear safety or quality assurance issue require immediate attention, the Senior Vice President Operations Support has the authorized organizational freedom to contact anyone within the Company, up to and including the 26 Chairman/President and the Board of Directors, in order to resolve such concerns to his satisfaction. He has assigned the responsibility of managing fuel to the Manager Fuel Department. He has assigned the responsibility for corporate purchasing to the Manager Materials Management Department. He has assigned. the responsibility for supporting nuclear training, including operator training, to the Vice President Operations Training Department. He has assigned the responsibility for issuing contracts to the Manager Contract Services Section.
The Manager Corporate Quality Assurance is assigned overall authority and responsibility for the CPKL Corporate Quality Assurance Program. He reports directly to the Seni'or Executive Vice President " Power Supply and Engineering 6 Construction, is independent from cost and schedule responsibilities (other than Corporate QA departmental budget and schedule) and has no other duties or responsibilities that would prevent his full attention to QA matters.
Reporting to the Senior Executive Vice President Power Supply and Engineering 6 Construction at the same level as the Senior Vice Presidents of Nuclear Generation and Operations Support, the Manager Corporate Quality Assurance has open communication channels both oral and written to these senior management positions. The Manager Corporate Quality Assurance along with the Senior Vice Presidents of Nuclear Generation and Operations Support recommends the Corporate QA Program, including changes, for approval by the Senior Executive Vice President Power Supply and Engineering 6 Construction. The Manager Corporate Quality Assurance periodically reviews with the Senior Executive Vice President Power Supply and Engineering 6 Construction the overall effectiveness of the Company's quality assurance N
17.2.1-3 Amendment No. 26
~ ~ 0' SHNPP FSAR program. He has access to corporate management up to and including the Chairman/President to resolve any quality assurance related concerns if the concerns cannot be resolved satisfactorily at a lower management level. He has delegated the authority necessary for implementation of the Corporate Quality Assurance Program to the Manager Operations Quality Assurance/Quality Control, Manager Quality Assurance/Quality Control Harris Plant and to the Manager QA Services Section.
The Manager - Operations Quality 'A'ssurance/Quality Control has direct management responsibility for the QA/QC activities related to the start-up and operations of SHNPP. He has delegated the authority necessary for implementation of the Corporate Quality Assurance Program to the Director Harris Operations QA/QC.
The Manager Quality 'Assurance/Quality Control Harris Plant has direct management responsibility for the QA/QC activities related to the Engineering 6 Construction of the SHNPP. He has delegated the authority necessary for implementation of the Corporate Quality Assurance Program to the Director On-site Quality Assurance QA/QC Harris Plant, the Principal QA Engineer Engineering Unit, and the Principal QA/QC Specialist NDE Unit.
The Director Harris Operations QA/QC is responsible for conducting the onsite QA/QC activities during start-up and operation of the Shearon Harris Nuclear Power Plant in accordance with the Corporate QA Program and QA/QC procedures. The Corporate QA Program provides assurance that the Director-Harris Operations QA/QC has appropriate organizational responsibilities and authority to exercise proper control over the onsite Operations QA Program.
The Director Harris Operati'ons QA/QC has delegated the authority necessary for implementation of his portion of the Corporate QA Program to the Operations QA Supervisor, Operations QC Supervisor, and the Operations Principal QA Engineer. The Director Harris Operations QA/QC receives support from the Manager - QA/QC Harris Plant on an as-needed basis..
The Operations QA Supervisor and his staff, are responsible for:
'a) Providing QA services during start-up and operation of the plant.
b) Stopping maintenance and modification work which,does not meet requirements.
c) Reviewing selected plant procedures and instructions to assure that quality requirements are adequately prescribed.
d) Assuring timely resolution of concerns and identified nonconformances.
e) Ensuring holdpoints have been inserted in work control documents.
L f) Coordinating/conducting surveillance of ongoing plant activities.
P g) Providing procedures and instructions necessary for accomplishment of QA activities.
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[ h) Ensuring maintenance of records attesting to accomplishment of QA/QC activities.
17.2.1-4 Amendment No. 27
SHNPP FSAR i) Reviewing plant modification documents to assure that quality requirements are adequately prescribed.
The Operations QA Supervisor and his staff receive, on an as"needed basis support from Operations QA, Engineering in areas such as procedure rev'iew, modification package review, and interpretations of codes and standards.
I The Operations QC Supervisor and his staff are responsible for'.
a) Conducting inspections of maintenance and modification activities.
b) Stopping maintenance and modification work which does not meet requirements.
c) Reviewing maintenance documents to assure that quality requirements are adequately prescribed.
d) Reviewing procurement documents and performing receipt inspections.
e) Ensuring hold points have been inserted in work control documents.
f) Providing procedures and instructions necessary for accomplishment of QC activities.
.27 g) Conducting designated inspections of ongoing maintenance and initial hydrostatic testing activites.
The Operations QC Supervisor and his staff receive on an as-needed basis support from Operations QA Engineering in areas such as procurement document review and interpretations of codes and standards.
The Operations Principal QA Engineer and his staff are responsible for:
a) Developing and maintaining the Harris QA program to meet regulatory commitments.
b) Assisting the Harris project organizations in the development and implementation of procedures, review of specifications, and. modification packages to meet commitments.
c) Providing QA engineering support. to the Harris project organizations on QA problem reqolution.
The Operations Principal QA Engineer and his staff receive, on an as-needed basis, support from the off-site and on-site QA Engineering units in areas such as procedure review and interpretations of codes and standards.
17.2.1-5 Amendment No. 27
0 SHNPP FSAR The Manager QA Services Section is responsible for providing the off-site QA services support in areas of Engineering Quality Assurance, vendor surveillance, and training. He is also responsible for conducting an independent corporate audit program for all CP&L nuclear plants. He has delegated the authority necessary to fulfill his responsibilities to the Principal QA Engineer Off-site Engineering QA Unit, the Principal Specialist - Vendor Surveillance Unit, the Principal QA Specialist Training and Administration Unit and the Principal QA Specialist Performance Evaluation Unit.
The Principal QA Engineer - Off-site Engineering Quality Assurance Unit is responsible for:
a) Reviewing contracts and A-E and NSSS purchase orders for inclusion of applicable QA/QC requirements.
b) Maintaining liaison with the A-E and NSSS Supplier to keep up-to-date on project QA/QC activities and status and to assure timely resolution of quality-related problems.
c) When requested, conducting and/or participating in audits of quality-related activities of the A-E and the NSSS Supplier. H d) Reviewing A-E/NSSS Design Specifications and their revisions for QA requirements.
e) Ensuring timely resoluti'on of identified concerns and nonconformances.
The Off-site Engineering Quality Assurance Unit also provides QA/QC support to CP&L's other Nuclear & Fossil Plants.
The Principal Specialist Vendor Surveillance Unit is responsible for'.
a) Qualification of Suppliers'A programs'hen necessary, facility surveys are conducted. For procurement by the A-E, the actual function of conducting such surveys is performed by the A-E. When surveys are performed by the A-E, the Vendor Surveillance Unit will monitor and may participate in the survey. I b) , Conducting inspections and item acceptance activities (shop inspections) at Supplier facilities for procurement and ensuring timely resolution of identified concerns and nonconformances.
c) Evaluating Supplier's corrective action to prevent recurrence of nonconformances identified during shop inspections.
Amendment No. 21 17.2.1-6
SHNPP FSAR d) When requested, conducting or participating in audits of quality-related activities of Suppliers.
e) Providing Vendor Surveillance Quality Assurance Procedures (VQA) ~
The Vendor Surveillance Unit also provides QA/QC support in the above areas to CPSL's other Nuclear and Fossil Plants.
The Principal QA Specialist - Training and Administration Unit is responsible for: i a) Maintaining QA/QC procedures for corporate and/or field use, including document control and coordination of preparation of revisions.
b) Maintaining the Corporate QA Program, including document control -and coordination of preparation of revisions.
c) Assisting other CQA units in coordinating the development and implementation of training programs to qualify and upgrade QA/QC personnel.
The Training and Administration Unit also provides QA/QC support in the above areas to other COL nuclear and fossil plants.
The Principal QA Specialist Performance Evaluation Unit is responsible for conducting an independent corporate audit program for all CP&L nuclear plants. Peisonnel in this unit have no responsibility for quality achievement nor for quality assurance other than auditing. They are trained to prepare for audits, conduct and report audit's, and follow-up, as necessary, to 'assure timely correction of conditions, practices, and items that could degrade plant quality. The Principal QA Specialist Performance Evaluation Unit reports all audit results to the Chairman/President, Executive Vice President - Power" Supply and Engineering and Construction, and to the management of the function audited.
The qualification requirements of the Manager - Corporate Quality Assurance are equivalent to those described in Section 4.4.5 of ANSI/ANS-3.1-1978, as endorsed by Regulatory Guide 1.8. These are:
a) Must have a Bachelor's degree in engineering or the equivalent in practical experience.
b) Must have developed a high level of competence in the field of quality assurance or related technical areas associated with nuclear stations.
c) Must be innovative and have the ability to plan an effective overall quality assurance program for the Company.
d) Must have the ability to effectively coordinate the implementation, monitoring and modification of quality assurance programs among the several departments of the Company.
e) Must exhibit qualities of leadership and communication ability, both
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oral and written.
17.2.1-7 Amendment No. 27
QA/QC personnel routinely participate in plant meetings and review schedules in order to keep abreast of plant activities. Such action ensures that sufficient qualified QA/QC manpower and procedures are made available to provide the necessary QA/QC coverage for the scheduled activities.
li The appropriate requirements of the docketed QA program description and the regulatory guides are listed in Section 1.8 of the FSAR and are translated into procedures and instructions. These procedures and instructions are reviewed by qualified personnel for adequacy and are subject to surveillance and audit by QA to ensure proper implementation.
The General Manager Harris Plant Operations Section is responsible for ensuring that'SAR commitments such as technical specifications, regulatory guides, and codes and standards are correctly translated into procedures and instructions and that procedures and instructions are properly implemented.
Responsible plant and QA/QC personnel are required to be knowledgeable of the FSAR commitments with particular emphasis given to technical specifications, regulatory guides, and codes and standards. The General Manager Harris Plant Operations Section will develop a procedure that details accountability and defines the system for assuring that FSAR commitments and changes/additions to those commitments are correctly translated into implementation procedures and instructions. Proper implementation of this procedure and FSAR commitments will be subject to surveillance and audit by QA. As an additional check, QA will develop a matrix of technical specification commitments versus implementing procedures to provide a level of assurance that technical specification commitments are addressed in implementing procedures. Procedural compliance will be verified through QA surveillances and audits.
Quality Assurance is in the review and concurrence cycle for procedures which establish QA/QC holdpoints or which require action by the QA organization.
26 17.2.1-8 Amendment No. 26
SHNPP FSAR 17.2.2 QA PROGRAM 17.2.2.1 Quality Assurance Program during the Operations Phase
,The SHNPP QA Program during the Operations Phase is controlled by the policies and requirements of the Corporate Quality Assurance Program. (The Corporate Quality Assurance Program applies to all Nuclear Plants). These policies and requirements are implemented through the SHNPP Plant Operating Manual and other departmental/section procedures. The program is designed to ensure compliance with the NRC Regulatory Guides and ANSI Standards applicable to the operations phase of the SHNPP project. The commitment to comply or alternatives for CP&L to follow are presented in Section 1.8. The Corporate'A Program is divided into the following topics:
1 INTRODUCTION 1.1 CP&L Quality Assurance Program 1.2 Scope of Application 1.3 QA Program Implementation 1.4 Supporting Documents & Document Control 1.5 QA Program Control 1.6 CP&L Management Review of Corporate Quality Assurance Audit Activities 1.7 Corporate ALARA Program 1.8 Corporate Fmergency Plan 2 ORGANIZATION AND RESPONSIBILITIES
' Scope 2.2 CP&L Organization 2.3 Management Responsibilities 2.4 Quality Assurance Functions 2.5 Supporting Companies 3" DESIGN CONTROL' NEW PLANTS AND NUCLEAR FUEL 3.1 Scope 3.2 New Plant Construction and Nuclear Fuel 4 PROCUREMENT CONTROL 4 .'1 Scope 4.2 Contracts 4.3 Procurement by the Architect-Engineer 4,4 CP&L Purchases 4.5 Pre-Award Meeting 4.6 Purchase. Order 4.7 Verification of Vendor Activities 4.8 Nonconformances and Corrective Action 4 ' Final Acceptance 4.10 Plant Procurement Assistance Required 5 -MATERIAL & EQUIPMENT CONTROL 5.1 Scope 5.2 Receiving Inspection 5.3 Material in Storage 5.4 Material Released from Storage 5.5 Off the Shelf Items 5.6 Installed Plant Items Amendment No. 4.
17.2.2-1
S PP FSAR
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6 INSTRUCTIONS, PROCEDURES, AND DRAWINGS AND DOCUMENT CONTROL 6.1 Scope 6.2 Instructions, Procedures, and Drawings 6.3 Document Control 6.4 Responsibility 7 INDOCTRINATION AND TRAINING 7 ~ 1 Scope 7.2 Responsibility 7.3 General Requirements 7.4 Certification 7.5 Vendor and Contractor Required Training 8 CONSTRUCTION SITE WORK CONTROL 8.1 Scope 8.2 Construction Control Documents 8.3 Work Planning 8.4 Work Execution 9 CALIBRATION CONTROL 9.1. Scope 9.2 Responsibility 9.3 Calibration Program 10 SURVEILLANCE 10.1 Scope 10.2 Responsibility 10.3 " Surveillance--Requirements ll FINAL DOCUMENTATION 6 TURNOVER
- 11. 1 Scope 11.2 System & Structure Turnover 12 12.1 12.2
'cope PLANE OPERATIONS CONTROL Operational Control- and Responsibilities 12.3 Operating Logs and Records 13 ~
MAINTENANCE CONTROL 13.1 Scope 13.2 Responsibility 13.3 Maintenance Procedures and Instructions 13.4" Corrective Maintenance 13.5 Preventive Maintenance 13.6 Maintenance Assistance Required 14 ,OPERATING PLANT MODIFICATION CONTROL
- 14. 1 Scope
- 14. 2 Responsibility 14.3 General 14.4 Modification Preparation, Review, and Approval 14.5 Modification Installation and Final 'Documentation 14.6 Modification Development Assistance Required
- 17. 2. 2-2 Amendment No. 4
SHNPP FSAR 14.7 Setpoint Changes 14.8 Temporary Repairs/Modifications 15 NONCONFORMANCE CONTROL AND CORRECTIVE ACTION 15.1 Scope 15.2 Disposition and Control 15.3 Nonconforming Material Status 15.4 Nonconformance Documentation & Closeout
.16 "AUDITS 16.1 Scope 16.2 Internal Audits 16.3 External Audits 17 QUALITY ASSURANCE RECORDS
- 17. 1 Scope
- 17. 2 Requirements for Implementation 17.3". Types of QA Records
- 17. 4 QA Records Accumulation, Maintenance, and Retention 17.5 QA Records 18 QUALITY ASSURANCE PROGRAM FOR FIRE PROTECTION SYSTEMS
.18.1 Scope 18.2 General 18.3 New Plant Construction 18.4 Operating Plants 18.5 Material Upgrading 19 QUALITY ASSURANCE PROGRAM FOR RADIOACTIVE WASTE MANAGEMEÃZ SYSTEMS 19.1 Scope 19.2 General 19.3 Management Responsibilities 19.4 Design and Procurement Document Control 19.5 Control of Purchased Material, Equipment and Services 19.6 Inspection 19.7 and Storage
'andling 19.8 Inspection, Tests, and Operating Status 19.9 Corrective 19.10 Action'nstructions, Procedures & Drawings 19.11 Control of Measuring and Test, Equipment 19.12 Records 19.13 Document Control 19.14 Material Upgrading 20 (LATER)
.21 IF-300, IRRADIATED FUEL SHIPPING CASK 21.1 Scope 21 ~ 2 Responsibility 21.3 Procurement Control
- 21. 4 Operations Control 21.5 Maintenance and Repair 21.6 Quality Assurance Records 17.2 '-3 'Amendment No. 4
SUPP FSAR 0 ~
22 RADWASTE SHIPPING QA PROGRAM 22.1 Scope 22 ' General 22.3 Management Responsibilities 22.4 Instructions, Procedures, and Drawings 22.5 Document Control 22 ' ~
Inspection 22 ' Control of Measuring and Test Equipment 22.8 Handling, Storage,'and Shipping 22.9 Inspection, Tests, and Operating Status 22.10 Nonconforming Materialsp Parts, or Components 22.11 Corrective Action 22+12 Quality Assurance Records 22 '3 Audits Appendix I CROSS-REFERENCE to 10CFR50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants."
The Corporate QA Program and revisions thereto are approved by the Executive Vice President Power Supply and Engineering and Construction. The Corporate QA Program'nd its revisions are controlled by the Manager Corporate Quality Assurance.
The SHNPP QA Program during the Operations Phase applies to all activities affecting quality such as preoperational testing, startup power testing, operation, maintenance, modification, and refueling. The program defines responsibilities and authority, prescribes measures for the control and accomplishment of activities affecting quality for the operation of safety related, fire protection and radwaste structures, systems, and components and requires verification of conformance to established requirements be accomplished by individuals or groups'who do not have direct responsibility for performing the work being verified. Section 3.2 identifies those structures, systems, and components defined as being "safety-related", fire protection and radwaste and therefore under control of the Corporate QA Program. Corporate Quality Assurance and other responsible organizations participate early in the QA program definition stage to determine and identify the extent to which QA controls are to be applied to specific structures, systems, and components.
The program requires suppliers (i.e., an Architect-Engineer, Nuclear Steam Supply System and other Vendors, Contractors a'nd Consultants) to operate in accordance with QA Programs which are compatible with the applicable requirements of the Corporate QA Program where their services are utilized in support of plant operations. Sections 17.2.7 and 17.2.18 further describe the methods to assure that the supplier's program is compatible with the CP6L Corporate QA Program. To achieve the objective of ensuring'that activities affecting quality are performed in a planned and controlled manner, the Corporate QA Program requires that written, approved procedures or instructions be developed. These documents ensure that quality-related-activities are performed under suitable controlled conditions, with specified of these procedures
'l equipment, and that any prerequisites have been met. Sections 17.2.5, 17.2.6, 17 '.10, and 17.2 outline the requirements for the content and application and instructions.
Amendment No. 4 17.2.2>>4
SHNPP FSAR Management above and outside the QA organization regularly assesses the scope, adequacy and compliance of the QA Program to 10 CFR 50, Appendix 8, through (a) review of CP&L and NRC audit reports, (b) review of status of quality assurance at plant status meetings with CP&L and major contractors, (c) review of reports of quality problems, (d) participation in meetings concerning quality problems, and (e) review of semiannual preplanned and documented assessments of Corporate Quality Assurance audit activities performed by the CP&L Manager Corporate Health Physics. The Manager of Health Physics )6 provides a report of the .assessment to responsible management and corrective action is identified and tracked.
The CP&L Corporate QA Program requires that the authority and duties of persons and organizations performing QA functions be clearly established and delineated in writing and that these individuals and organizations have sufficient authority and organizational freedom to:
a) Identify quality problems.
b) Order unsatisfactory work to be stopped and control further processing, delivery, or installation of nonconforming material.
c) Initiate, recommend, or provide solutions for conditions adverse to quality.
d) Verify implementation of solutions.
i The CP&L Corporate QA Program identifies the persons and organizations with the above authority and describes how these actions are carried out.
The CP&L Corporate QA Program requires that an individual or organization assigned responsibility for checking, auditing, inspecting or otherwise verifying that an activity has been correctly performed shall be independent of the individual or group directly responsible for performing the specific activity.
The Corporate QA Program outlines the methodology for resolution of disputes involving quality arising from a difference of opinion between QA/QC personnel and other groups. Section 17.2.16, "Corrective Action," further outlines this methodology.
When changes are made to the QA program that deletes requirements or positions as presented in the FSAR, the, change will be reviewed and approved internally to ensure it meets applicable requirements If and then submitted to the NRC for from the NRC to submitted acceptance prior to implementation. a response changes is not received within 30 days, CP&L will consider the changes approved by the NRC and will proceed on that basis (Note: Format, editorial changes, or increase in requirements and/or positions will be provided with the normal FSAR update requirements).
The Corporate QA Program which addresses the QA program for operations will be implemented at least 90 days prior to fuel loading.
17 ' '-5 Amendment No. 6
SIINPP FSAR
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17.2.2.2 Both Indoctrination and Trainin on-site and off-site personnel within the CP&L organization who perform activities affecting quality shall be indoctrinated and trained such that
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/ they are knowledgeable in the applicable quality related procedures and requirements. Provisions to ensure that these personnel remain proficient shall be made. The indoctrination and training program assures that:
a) Personnel responsible for performing quality-affecting activities are instructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.
b) Personnel performing quality-affecting activities are trained and qualified in the principles and techniques of the activity being performed.
c) The scope, objective, and method of implementing the indoctrination and training program are documented.
d) Proficiency of personnel performing quality-affecting activities is maintained by retraining, reexamining, and/or recertifying.
e) Methods are provided for documenting training sessions including attendees, date, and the contents of the training session.
The CP&L position on Inspection, Examination, and Testing Personnel is contained in CP&L's position on Regulatory Guide 1.58 in Section 1.8.
Personnel within the SHNPP operating organization performing duties of a licensed operator are indoctrinated, trained, and qualiEied as required by 10CFR55. The NRC approved requalification program, submitted as required by Appendix A of 10CFR55, establishes the "requalification program" for licensed personnel.
Carolina Power & Light Company personnel permanently assigned to the SHNPP receive indoctrination in'.
a) General description of plant and facilities.
b) Job-related procedures and instructions.
c) Radiological Health & Safety Program".
d) Emergency actions.
e) Industrial Safety Program.
I f) Fire Protection Program.
g) Security Program.
h) QA Program.
Temporary personnel, both CP&L and/or contractors, are also trained in the above categories to the extent necessary to assure safe execution of their duties.
17.2.2-6 Amendinent No. 27
SHNPP FSAR Proficiency tests are given to personnel performing independent QA/QC inspection, and acceptance criteria are developed to determine Xf individuals areproperly trained and qualified. Certificates of qualification delineate the functions personnel are qualified to perform.
17.2.2.3 Startup QA Pro ram The description of phase out of design and construction, and takeovex of operations (provided in the Shearon Harris Startup Manual) is described in Chapter 14. The Corporate QA Program applies to preoperational and start-up test activities.
Schedules will be developed to assure that implementing procedures are pxepared prior to commencement of the activities which they are intended to control. Procedures which prescribe the methods by which preoperational and initial startup testing is accomplished and controlled are contained in the Startup Manual. These procedures provide for the orderly transition from design and construction to operations and, during this transitional period, prescribe the methods for control of management and technical interfaces between the Architect-Engineer, EBASCO, Inc.; the NSSS Vendor, Westinghouse; the constructor, Daniel; and CPGL. The conduct of the test program and the administrative controls to be implemented are described in Section 14.2.
Preoperational test procedures are reviewed by personnel knowledgeable in QA. The preoperational testing program will be monitored by QA/QC personnel.
The QA Program is applied to the development, content and use of computer codes to ensure (1) the codes are developed, documented, verified and certified for use per approved procedures; (2) the codes are properly controlled to pxeclude use of outdated or obsolete codes; (3) that proper instructions concerning the use of the codes is provided; and (4) adequate QA provisions are invoked for the procurement of computer codes.
17.2.2-7 Amendment No. 5
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SHNPP FSAR 17.2.16 CORRECTIVE ACTION The SHNPP QA Program, as controlled by the Corporate QA Program, requires the identification and correction of conditions adverse to quaLity.
The program requires that an evaluation of conditions adverse to quality, such as nonconformances, failures,'alfunctions, deficiencies, deviations, and defective materiaL and equipment is conducted to determine need for corrective action.
Conditions adverse to quality are identified through inspections, surveillances, audits, tests, checks, and review of ddcuments.
c-The program requires corrective action to be initiated to preclude recurrence of significant conditions adverse to quality.
The program requires folLow-up reviews,,audits, inspections, etc., to be conducted to verify,proper implementation of corrective action and to close out the corrective action documentation.
Significant conditions adverse po quality, the cause of the conditions, and the corrective action taken are reported to management, both on site and off site, including QA groups, for review and assessment.
Periodic review and assessment of quality trends is made by the General Manager - Harris Plant Operations Section, Director QA/QC Harris Plant, Manager QA/QC Harris Plant, and Manager Corporate QA.
In the event the plant staff and the QA/QC organization cannot agree on the corrective action or disposition, the QA/QC organization will escalate the matter through successive levels of management until a resolution is reached. The ultimate decision making authority is the Senior Executive Vice President Power Supply and Engineering & Construction.
17.2.16-1 Amendment No. 26
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0 0 SHNPP FSAR 17.2.19.4 Ins ection Test and 0 eratin Status
'lhe requirements stated in Section 17.2.14 will apply ~
17.2.19.5 Deficiencies and Nonconformance Items Deficiencies and nonconformances of fire protection system items will be identified, reported, dispositioned, and corrected in accordance with Section 17.2.15.
17.2.19.6 Corrective Action The requirements of Section 17.2.16 shall apply. Procedures shall be established for evaluating condtions adverse to fire protection to determine the necessary corrective action. In the case of significant or repetitive conditions adverse to fire protection, the cause of the conditions will be determined and analyzed, and prompt corrective action taken to preclude recuxrence.
17.2.19.7 alit Control Ins ections With respect to fire protection systems or features which-protect nuclear safety-related systems, structures, or equipment, a documented program of quality control inspections will be implemented by the Director QA/QC Unit/Fire Protection Specialist when xepairs or modifications to those systems or features are performed, or if the quality of the activity can impair the ability of the system, equipment, component, or installation" to accomplish its intended function.
17.2. 19.8 alit Control Surveillance The General Manager Harris Plant Operations Section is responsible for implementing a documented program of periodic surveillance which verifies compliance with governing procedures for the following fire protection activities:
a) -Housekeeping b) Surveillance tests of the fire protection systems II c) Control of ignition sources d) Use of fire watches e) Control of combustibles f) Fire protection training documentation g) Preventive maintenance program This program will be conducted by the Fire Protection Specialist in accordance
- with approved procedures.
17.2.19-3
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SHNPP FSAR 17.2.19 9 ualit Assurance Surveillance Surveillance for compliance with this program will be accomplished by the Director QA/QC Unit.
17.2.19.10 Preventive Maintenance A preventive maintenance program for designated fire protection system items will be established and implemented per plant procedures.
17.2.19.11 'ost-Maintenance and Post-Modification Testin Corrective maintenance which repairs or replaces parts or components which affect the function of designated fire protection items requires post-maintenance testing, except where such testing would be destructive.
Each modification of designated fire protection items requires testing to demonstrate that design criteria and the function of the modification are met. The specific post-maintenance and post"modification test requirements will be delineated in accordance with approved procedures for post-maintenance and post-modification testing.
17.2.19.12 Test Control The requirements stated in Section 17.2.11 shall'pply.
17.2.19. 13 Audits Audits will be conducted in accordance with Section 17.2.18 except as listed below.
a) The General Manager' Harris Plant Operations Section is responsible for ensuring the following audits are accomplished:
- 1) An annual independent fire protection and loss prevention 2O[ inspection and audit by qualified off-site personnel or an outside firm in accordance with Technical Specifications.
- 2) A biennial audit of the fire protection program and implementing 20 procedures by CP&L's QA organization.
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- 3) A triennial independent inspection and audit of the fire protection and loss prevention program by an outside qualified fire consultant in accordance with Technical Specifications.
17.2.19.14 ualit Assurance Records Quality Assurance records generated by implementation of this Fire Protection System Quality Assurance Program will be maintained in accordance with Section 17.2.17.
17.2.19-4 Amendment No. 20