ML20151X001
| ML20151X001 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf, Arkansas Nuclear, River Bend, Waterford  |
| Issue date: | 09/10/1998 |
| From: | Wigginton D NRC (Affiliation Not Assigned) |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9809160215 | |
| Download: ML20151X001 (36) | |
Text
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, . LICENSEE: ENTERGY OPERATIONS, INC. Septemb:r 10, 1998 FACILITIES: ARKANSAS NUCLEAR ONE, GRAND GULF, RIVER BEND, AND WATERFORD
SUBJECT:
MEETING
SUMMARY
OF AUGUST 27,1998 TO DISCUSS REVIEW STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL On August 27,1998, the staff met with representatives from Entergy Operations, Inc. to discuss the status of review of the standard quality assurance (QA) manual for all the Entergy sites. The list of meeting attendees is attached as Attachment 1.
The meeting attendees discussed the status of review and specific review questions by using the Entergy QAPM Review Matrix in Attachment 2. A number of the questions were closed with acceptable responses by the licensee. The matrix will be updated to indicate those closed and with new questions as the staff's review continues. The revised matrix will be used at the next scheduled review meeting currently planned for September 29,1998.
ORIGINAL SIGNED 8Y:
David L. Wigginton, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects lil/lV Office of Nuclear Reactor Regulation Docket Nos. 50-313,50-368,50-416,50-458,50-382 Attachments: As stated cc w/atts: See next page DISTRIBUTION HARD COPY E-Mall Docket File : SCollins/FMiraglia (SJC1/FJM)
PUBLIC 'BBoger (BAB2)
PD4-1 r/f EAdensam (EGA1)
OGC CHawes (CMH2)
ACRS TMartin (SLM3)
TGwynn, RIV JHannon (JNH)
WHaass (WPH)
RSmith (RJS6)
DWigginton (DLW)
.I Document Name: RB082798.MTS //
OFC PM/hh1/ LA/PD4-1 P/PD NAME DMg i n/vw CHawe JHann n DATE 7 // O /98 9 /10 /98 )/0/98 COPY h/NO YES/NO YES/NO l OFFICIAL RECORD COPY l
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9809160215 990910 PDR ADOCK 05000313
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[ ~4 UNITED STATES
( g ,j NUCLEAR REGULATORY COMMISSION g 'g WASHINGTON, D.C. 2066M001
% ,,,,, # September 10, 1998 LICENSEE: ENTERGY OPERATIONS, INC.
FACILITIES: ARKANSAS NUCLEAR ONE, GRAND GULF, RIVER BEND, AND WATERFORD
SUBJECT:
MEETING
SUMMARY
OF AUGUST 27,1998, TO DISCUSS REVIEW STATUS OF THE STANDARD QUALITY ASSURANCE MANUAL On August 27,1998, the staff met with representatives from Entergy Operations, Inc. to discuss the status of review of the standard quality assurance (QA) manual for all the Entergy sites. The list of meeting attendees is attached as Attachment 1.
The meeting attendees discussed the status of review and specific review questions by using the Entergy QAPM Review Matrix in Attachment 2. A number of the questions were closed with acceptable responses by the licensee. The matrix will be updated to indicate those closed and with new questions as the staff's review continues. The revised matrix will be used at the next scheduled review meeting currently planned for September 29,1998.
s David L. Wi in on, Senior Project Manager Project Directorate IV-1 Division of Reactor Projects Ill/IV Office of Nuclear Reactor Regulation Docket Nos. 50-313,50-368,50-416,50-458, 50-382 Attachments: As stated cc w/atts: See next page l
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1 Entergy Operations, Inc. Arkansas Nuclear One, Units 1 & 2 l
cc:
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Executive Vice President Vice President, Operations Support
& Chief Operating Officer Entergy Operations, Inc.
Entergy Operations, Inc. P. O. Box 31995 P. O. Box 31995 Jackson, MS 39286-1995 Jackson, MS 39286-1995 I Director, Division of Radiation - Wise, Carter, Child & Caraway Control and Emergency Management P. O. Box 651 Arkansas Department of Health Jackson, MS 39205 4815 West Markham Street, Slot 30 Little Rock, AR 72205-3867 Mr. C. Randy Hutchinson Vice President Operations, ANO Entergy Operations, Inc.
Winston & Strawn 1448 S. R. 333 1400 L Street, N.W. Russellville, AR 72801 Washington, DC 20005-3502
' Manager, Rockville Nuclear Licensing l Framatone Technologies 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Senior Resident inspector l U.S. Nuclear Regulatory Commission !
P. O. Box 310 i London, AR 72847 I l
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 County Judge of Pope County Pope County Courthouse Russellville, AR 72801 4
e- e Entergy Operations, Inc. Grand Gulf Nuclear Station cc:
Executive Vice President General Manager, GGNS
& Chief Operating Officer Entergy Operations, Inc.
l Entergy Operations, Inc. P. O. Box 756
! P. O. Box 31995 Port Gibson, MS 39150 Jackson, MS 39286-1995 l Attorney General Wise, Carter, Child & Caraway Department of Justice P. O. Box 651 State of Louisiana Jackson, MS 39205 P. O. Box 94005 Baton Rouge, LA 70804-9005 Winston & Strawn 1400 L Street, N.W. - 12th Floor State Health Officer Washington, DC 20005-3502 State Board of Health P. O. Box 1700 Director Jackson, MS 39205 Division of Solid Waste Management Mississippi Department of Natural Office of the Govemor Resources State of Mississippi l P. O. Box 10385 Jackson, MS 39201 l Jackson, MS 39209 !
Attorney General President, Asst. Attorney General Claiborne County Board of Supervisors State of Mississippi !
P. O. Box 339 P. O. Box 22947 I Port Gibson, MS 39150 Jackson, MS 39225 Regional Administrator, Region IV Vice President, Operations Support i U.S. Nuclear Regulatory Commission Entergy Operations, Inc.
611 Ryan Plaza Drive, Spite 1000 P.O. Box 31995 Arlington, TX 76011 Jackson, MS 39286-1995 Senior Resident inspector Director, Nuclear Safety U. S. Nuclear Regulatory Commission and Regulatory Affairs ,
P. O. Box 399 Entergy Operations, Inc.
Port Gibson, MS 39150 P.O. Box 756 ;
Port Gibson, MS 39150 Mr. Joseph J. Hagan
. Vice President, Operations GGNS i Entergy Operations, Inc.
j P. O. Box 756 Port Gibson, MS 39150 i
g a Entergy Operations, Inc. River Bend Station cc:
l Winston & Strawn Executive Vice President and 1400 L Street, N.W. Chief Operating Officer Washington, DC 20005-3502 Entergy Operations, Inc.
P. O. Box 31995 Manager- Licensing Jackson, MS 39286 Entergy Operations, Inc.
River Bend Station General Manager- Plant Operations P. O. Box 220 Entergy Operations, Inc.
St. Francisville, LA 70775 River Bend Station P. O. Box 220 Senior Resident inspector St. Francisville, LA 70775 P. O. Box 1050 St. Francisville, LA 70775 Director- Nuclear Safety Entergy Operations, Inc.
President of West Feliciana River Bend Station Police Jury P. O. Box 220 P. O. Box 1921 St. Francisville, LA 70775 St. Francisville, LA 70775 Vice President - Operations Support Regional Administrator, Region IV Entergy Operations, Inc.
U.S. Nuclear Regulatory Commission P. O. Box 31995
! 611 Ryan Plaza Drive, Suite 1000 Jackson, MS 39286-1995 Arlington, TX 76011 Attomey General Ms. H. Anne Plettinger State of Louisiana 3456 Villa Rose Drive P. O. Box 94095 Baton Rouge, LA 70806 Baton Rouge, LA 70804-9095 Administrator Wise, Carter, Child & Caraway Louisiana Radiation Protection Division P. O. Box 651 P. O. Box 82135 Jackson, MS 39205 Baton Rouge, LA 70884-2135 i
Mr. Randall K. Edington Vice President- Operations Entergy Operations, Inc.
River Bend Station P.O. Box 220 St. Francisville, LA 70775 l
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Entergy Operations, Inc. Waterford 3 cc:
Administrator Regional Administrator, Region IV Louisiana Radiation Protection Division U.S. Nuclear Regulatory Commission Post Office Box 82135 611 Ryan Plaza Drive, Suite 1000 Baton Rouge, LA 70884-2135 Arlington,TX 76011 Vice President, Operations Resident inspector /Waterford NPS Support Post Office Box 822 Entergy Operations, Inc. Killona, LA 70066 P. O. Box 31995 Jackson, MS 39286 Parish President Council St. Charles Parisn Director P. O. Box 302 Nuclear Safety & Regulatory Affairs Hahnviile, LA 70057 Entergy Operations, Inc.
P. O. Box B Executive Vice-President Killona, LA 70066 and Chief Operating Officer Entergy Operations, Inc.
Wise, Carter, Child & Caraway P. O. Box 31995 P. O. Box 651 Jackson, MS 39286-1995 l Jackson, MS 39205 i Chairman General Manager Plant Operations Louisiana Public Service Commission Entergy Operations, Inc. One American Place, Suite 1630 P. O. Box B Baton Rouge, LA 70825-1697 Killona, LA 70066 Licensing Manager Vice President Operations Entergy Operations, Inc. Entergy Operations, Inc.
P. O. Box B P. O. Box B Killona, LA 70066 Killona, LA 70066 '
Winston & Strawn 1400 L Street, N.W.
Washington, DC 20005-3502
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ENTERGY OPERATIONS. INC.
l STANDARD QUALITY ASSURANCE PLAN MEETING ON AUGUST 27.1998 l I
ATTENDEES W. Haass NRR, HQMB R. Smith NRR, HOMB D. Wigginton NRR, DRPW B. Ford Entergy C. Wells Entergy B. Killian Entergy, W-3 i
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ATTACHMENT 1
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Entergy QAPM review matrix Number Comment Response Closed? Sutedt?
Q-1 The statement in QAPM A.I.c that "The requirements of the QAPM The statement in A.1.c is moddied to danfy that R is the Yes are applied to these items and actrvihes to an extent commensurate method of implementahon of the requirements of tie with their importance to safety
- and semilar sk.:m.m. 6 in other OAPM that changes depending on the safety referenced Standards could be mesapplied and result in "shall" ssgnificahon of the item or activity and not the commements inappropriately bypassed wdhout the appropnate review requirements of the OAPM.
process.
A.1.c The rnethods ofimplementation of the requwements of the OAPM are commensurate wilh the i
Item's or activity's i iportance to safety Q-2 Need to clanfy the duhes and reporhng iewC:;, of any line The proposed QAPM cummey has the foGowmg Yes {
organization OA fundional i%C' i The specific cxmcem was requwements related to the duhes and % _-J_7-:-
related to the OC type functions. of personnel performmg the OC and the QA manager's relabonship Secton B.12.a (p.15); it appears that line organization personnel perform inspections; not clear. QC personnel N the une organization personnel perform the inspecticns, how is A.6.a independence maintained between doers and venigers? Does the It is the responsibility of each individual to prompOy QAPM meet A.2.b of SRP 17.37 idenhty and repo:t conditions adverse to quality '
Management at aR levels encourages the 16sngResuon of condihons that are adverse to quality.
B.12.a and N18.7 Sechon 5.2.17 The inspechon program may be ;. 6..~. AW by or for the organization performing the actrvity to be inspected Inspechons are pedormed by quanvied personnel other than those who performed or direc9y supervised tie work being inspected. ;
B.12.d i inspection results are to be documented by the inspector and reviewed by Wed personnel.
> t h
n N18.7 Section 5.2.17 The owner organization shall evaluele inspection 5 results B Records shall be kept in sufficient detaR to E
pemwt adequate con 6rmation of the inspec50n p program. B Deviation, their cause, and any compclive N achon w. 4 :J or planned as a result of the devinhons shan be documented t
Ok
. r Revision dated 08/25/98 .
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4 Entergy QAPM review matrix Number Comment Response Closed? Submit?
i AI.d.1 The ii.ai, responsible for quality assurance has overall authonty and ie.. e-do;;;^ifor estabbshmg, controlling, and venfymg the implementabon and adequacy of the quality assurance program as dem ;'oed in this OAPM.
C.1.c Personnel performmg audits have no direct responsibihbes in the area they are assessing N18.7 Sechon 4.5 !
Those performmg audits may be members of the audited organization; however, they shall not audit !
actrvibes for which they have immediate responsibility. ,
While performmg the audit, they shall not report to a management suv.eim ,;.. .; who has immediate responsability for the activity being audited ;
Conclusion -
As evidenced by the guidance of ANSI N18.7 the regulatory intent of the funcbonalic-loi;u J.;p between the OC function and the OA managemerd is to allow the OC funchon to be implemented by the line organization, the results documented, and the OA !
funchon (with independence) to audit the OC funciton performance These sections of ANSI N18.7 were endorsed without excephon in RG 1.33 R2. The prei; sed QAPM mrrectly reflects this intent without i charges.
An editorial change associated with respect to lhls item is to add a cross reference to RG 1.33 in OAPM B.12 B.12.f Additional details concoming inspections may be found in the Regulatory Guides and associated Standards as committed to in Section A.7 and Table 1 (e.g., Regulatory Gulde 1.33).
O-3 Need to clanfy the dubes and reporting responsibilities of any line A heensee's organization desenption needs to contain organization OA functionaliewisC: ;. One method may be a sufficient detail to provide reasonable assurance of Revision dated 08/25/98 i
Entergy QAPM review matrix Number Comment Response Cleoed? Sutedt?
funchonal diert. management oversight in the performance of quatty assurance responsstulibes. Consideration from undue A*ennnel NRC discussion cost and schedule pressures by the preparahon, review, and submdtal of unwarranted detemunations NRC requwements to demonstrale organizational acceptabinty- regardmg reduchons is commitment for organizational restructure is essenhal in today's environment.
The licensee's organization chart needs to demonstrate the QA Manager's freedom from undue cost and schedule pressures in the This assurarice and consideration is accomplished by performance of QA responsibilihes by showing appropriate reportng showmg only the appropnate reporkng lines of auterfly lines of authodly to upper levels of management. We are also to upper levels of management. This provides a Interested in assuring that the QA Manager's ability to focus on QA licensee with the opportundy to focus on matters matlers is not excessively diluted by tie addshon of other norHelated essenhal to safety, thereby providing for 9m safety of
.ew.ar:_. So the orgamzahonal chart should also show the fug the general pubhc, rather trian on organizational make-
- w. 4.. ..; of other funchonal areas. The chart does not need to up of plant personnel include speellic titles, but should indicate general titles for each functional area; general desenplions of . -,WM for each title Therefore, organization charts should not include box can be delineated in the text. Of particular interest is an specdic titles, but rather general INies for each identification of what QA functions delineated in the QAPM are functional area, with general descripilons of implemented by what organizallonel element. These cre the general .e4.u..AZ:; for each title box delineated in organizational factors Sist demonstrate conformance to Appendix B. implementing procedures.
Specific discussions The reporting line of authority is described in OAPM sechon A2. This sechon shows the line of authority from the chief executive officer to the QA manager.
This desenbed line of authority insures that the QA manager has an organizabonal functional level witi a high degree of authonty by requiring that the QA manager either report dwectly to the associated VP or at most allows a single level of management between the VP and the QA manager. Having a level of management between the QA manager and the VP has been accepted by the NRC in the past. Addihonally, QAPM A.2.d.1 states that the QA manager has the
, authority and .uw.a~;, to escalate matters direc9y to the chief executive ofilcer when needed ANSI Standard N18.7 Section 3.4 in the lost paragraph provides the NRC accepted guidance concoming other duhes of the QA manager position. This standard wE conunue to be meet under the new plan.
i Revision dated 08/25/98
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l Entergy QAPM review matrix Number Comment Response Closed? SubmM7 [
Q-4 Table 1 A.1 General QualHication n ,--- ...._. , for personnel wHI RG 1.8 is being used as a place holder in the QAPM meet ANSifANS 3.11978 except where exception to ANSI N18.1 (this is very consistent with the RBS .M. .. Ref.
or to this Standard is IdentNied in the appIIcable unit's Technical RBS USAR Sechon 1.8 page 8). RG 1.8 R 1 indorses EJW ^" _. ANSI N18.1 1971 unthout any clarificahons except for j the Radiahon Protechon Manager. Requwements for RG 1.8 R1(1975) does not address ANSI /ANS 3.1 at all. RG 1.8 the Radiation Protection Manager are in each of the i R2(1987) does endorse certam porhons of 3.1 (1981). W3 has units Technreal Specsficahons and are not being j posslions where 3.1 (1978) applies and others where 18.1 apphes. changed by this proposed QAPM revision. Entergy is ;
l GG uses section of tie 3.1 (1979) draft plus some of 3.1 1978. More proposing to commst to meet ANS 3.1 1978 except for detad appears to be needed on what is covered under 3.1 what is stHI specsfic exceptions identified in Sie Technical under 18.1,which version of 3.1 should be used, and how the Specificahons.
incorporation of TMI Action Plan Requwements which were graduaNy i being incorporated into later verssons of 3.1 win be <xmsidered when This is a signsficant increase in commitmerd for ANO l an earlier version of 3.1 is used. Since 3.1 is being used, perhaps and GGNS since ANS 3.11978 has many i consadorahon could be given to the requirements of RG 1.8 R2 (1987) reqG ;..~.O not contained in ANSI 18.1 1!)71. :
as the more appropnate commNment at this time. How wiR future ;
- changes to Tech Spec exceptions to Wiese standards be controlled? Future changes to the TS will be mntrolled in l 50.597 50.547 Both? accordance with 10 CFR 50.92 which requires prior !
NRC approval 1
Q-5 Table 1 A.1 Individuals fuling positions at the time of The main problem with the addition is test many i
- 1. f ._ _^ ^ _ . of this commitment can be considered to meet
__ positions did not have any quaRilcanons in ANSI 18.1 l the requirements of this commitment for that positlen without 1971.
further review and documentation. j What about a change to: l Include "fuey quagiled under existing commitments"in addihon to t
" fining posMions". Does any considershon need to be given here for Individuals filling positions at the time of remrtilicatons or proficiency training requirement? WIII these all be implementshon of this commitment can be considered low new commitments wlDiout exceptions? to meet any more restrictive aspects of the ,
requirements of this commitment for that posillon j without further review and documenta80n ;
Q-6 Table 1 A.2. General The fonowing qualifications may be Section 4.1 of ANS 3.1 anows other factors to be used !
considered equivalent to a hachelor's degree: In place of degree requirements. It provides a list that may be considered. The clarificanon provides the i
- s. 4 years of formal schoonne in science or engineering, specnic list which win be appued. !'
, b. 4 years of applied expedence at a nuclear facluty in the area for which quellfication Is sought, As identified in GGNS IJFSAR Appendix 3A page 1.81 r
- c. 4 years of operational or technical expertenceMraining in these requirements are considered equivalerd to a reoclear power, or bachelor's degree. This was added to the UFSAR in ;
- d. any combination of the above totaling 4 years. pre Opera 6ng L.icense Amendment 28 deled 3n9. !
N18.1 1971 only idenulle- degree requireme its for 2 !
This is an exisung excepuon from GG. See 1.20. positions as required I f
I Revision dated 08/25/96 t
u Entergy QAPM review matrix Number Comment R : _ - . .a Closed? Sutwnit? ;
- 1) Are aR the units
- Tech Specs consistent with this? If tech specs ;
speewy hechelor, is a bechelor degree required rather than this option?
NRC current attemale quelllicagon guidance for ISEG requires more expenence to subsstute for a bachelor's, as one example How is this consistent? What about QA manager?
- 3) Do these regt.:. .~..b apply to more than just QA posihons? !
NRC QA staff might have to get other groups irwolved N so. !
2 (licensing, rad protection, etc.), and
- 4) When was this excephon incorporated? What was the justificahon?
Q.7 Table 1 B.3. ANSI N45.2.4 Documented routine inspections and it's irr piled by the sechon R is referencing audits of the storage area may Section 3 he performed Instead of l' the ;- ,-_ " _.. _.."_ of this Section.
Requirements for initial receipt and storage are covemd by another standard Here only vertlicahon that items are in satisfactory condition for instaRagon and have not supered since initial rece'pt is being addressed As such this is basicalry consisterd with b.e cummt ,
QAP approved by the NRC for ANO on page T1-10 of its discussion of l compliance
- 00 assure that stored Mems cre mamtamed in a sa#sfactory condloon
- might be added to the end as this was included in ANO's discussion, however, this might also already be -
mnsidered impiled based on the context of this section of the .
standard See L16.
Q-8 Table 1 B.4. ANSI M45.2.4 QAPM Section B.12 wHI be compHod Will remove the clartftcation YES with Instead of the Section 5.1 s- ,_ " ..._.." of Section 5.1.1, Section 5.1.2, and the first sentence of Sectico 5.1.3. ,
The GG excepeon uses its Policy 10.0 "Inspecborf to implement the above ANSI requirements. However, Pohey 10 as wntien is more detailed than the new QAPM Section B.12 cited above Moreover, since this was not an excepton for the other sites, and since there are even more specific items in the standard than are contained in either i the current GG exception or the new QAPM Section B.12, it seems appropriate to ask why the appReable portions of 5.1 should not be !
included in addition to B.127 This seems more appropriate than the "Instead of* wording used above. This also seems to have been the intent of the cited GG exception, as It says " The inspection program will incorporate, as applicable, those items listed in hese subsections see L20.
Revision dated 08/25/96 .
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Entergy QAPil4 review matrix Number Comment Response Closed? Sutwnit? l O-9 TatWe 1 C.1. Section C.1 Entergy wHI provkte procedures for the W3 Att 6 page 43 item 6. Also, featy just a statement guide's .% -3 A activities as discussed. oowever Entergy of fact.10 CFR 50.2 prtmdes the definstion of safety i does not consider all activilles IIsted to be safety.related" (e.g., related We conssder whatever meets that definition to activilles in 7.e). be safety related Did not see the discussion of this one.
i O-10 Table 1 C. 3. ANSI N18.7 Section 1 Sentences 4 and 5 state. Tm is not really a difference. I was just trying to !
"However, appHcable sections of this standard should be used reference back to the actual controlhng document as they apply to related activities. Activities included are: Design which is the OAP Approval for Radioachve Malenal Changes, Purchasing, Fabricating " With regard to radioactive Packages. It provides restnchons on the actmties material ...;, ; --:-r. activities. Entergy will only implement the Entergy can perform. Listing the items in multiple
,: _.._..L associated with those activities conducted in documents just adds to the chance that one gets accordance with the applicable NRC Quality Assurance Program changed without the other gethng changed. A copy of
- Approval for Radioactive Material Packages. ANO's OAP Approval for RadioacSwe Material Packages can be found on Attachment 3 page 174. ,
Entergy states this is consistent with the cunent OAP for GG. Actual GG excephon to these sentences is worded "The licensee does not intend to fabricate, design, assemble, or modify any NRC licensed container to be used to transport radioactrve material." is there a difference here? App A p11 of 36. See L20.
O-11 Table 1 C.4. ANSI N18.7 Section 4.3.1 The specific areas of The are 2 separate committees discussed in this . I experience described In this section is not appHcable to the sechon 1) the onsste safety review group and the offsite on. site safety review committee but the committee must be safety review group.
c_. A :I of site operating or engineering supervisory {
personnel. Additionally, the off. site safety review committee On-site safety review comminee need contain expertence in only a melodty of the areas.
ANO Att 3 page 44 item 1.3.9.2.2.1 (a.k.a. PSC)
Entergy states this is a combination of curren8y approved OAPs for GGNS Att 4 page 85 item 7.4.1.2 (a.k.a. PSRC)
W3 and GG. The first sentence is said to be based on W3 QAP RBS Att 5 page 20 item TR 5.8.1.2 (a.k.a. FRC)
Chapter 1 section 4.102 which states
- The PORC shaR be composed W3 Att 6 page 14 item 4.10.1 (a.k.a. PORC) of nite management members as assigned, in wnhng, by the GMPO.
The GMPO will also indicate, in wnhng, the PORC Chairman
- This The first sentence is taking exception to the experience does not appear to w..W .., address the first sentence here with list for the on-site safety review committee The regard to expenence. The second sentence actuauy appears to current requwem$nts at the sites basscaRy say that the comes from GG UFSAR p168.1-207, referenced in the OAP, which committee is corrgmsed of site management and do not states"In the aggregate, the membership of the committee shaN invoke the N18.7 experierce reqL.~..G. The provide speellic prac8 cal experience in the majority of the disciplines wording is nearest the GGNS words. The of 7.4.2.1a through h.* See L19 and L20 documentabon part is covered in the general requwement found in OAPM A.1.d.
Revision dated 08/25/96
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Entergy QAPM review matrix Number Comment Response Closed? Sutwnit?
ANO Att 3 page 44 i'em 13.9.12.1 and 13.9.13.1 I (a.k.a. SRC)
GGNS Att 4 page 88 item 7.4.2.2.b (a.k.a. SRC) ' l RBS Att 5 page 23 item TR 5.83.2 (a.k.a. NR8)
W3 Att 6 page 13 item 4.9.2 & 4.93 (a.k.a. SRC) ' [
The second sentence is addressing the requkements !
for the off. site safety review commselee As of the ,.
plants have en expenence list semdar to the Est in l N18.7 IWI N18.7 items 7 and 10 are not on the cummt ,
lists and RBS has 2 extra items (e.g.,8 and 10 items requwed). GGNS has the discussion that experience i
,' ::: sney requwed for a mahnty of the items (i.e.,4 items j requwed). The proposed clarificahon requires 5 of the t
10 items. Addebonally, the last paragraph in she first
' column for N18.7 S 4.3.1 says you will add experience when needed. The new item is sligh6y less restrictive '
for ANO, RBS, and W3 and slightly more restrictive for i GGNS but any potenbal v.C.. caused by the ,
expenence difference is covered by last paragraph in !
the first column for N18.7 S 4J.1. l Q-12 Table 1 C. S. ANSI N18.7 Section 4.3.4(2) Reviews associated with The requirements of Sechon 4.3.4(2) could be f changes to the technical , _ A ^";..; will be performed In ;.a.,.a to requwe that the commillees review the !
procedures associated with the TS change in a way i accordance with Section 4.3.4(3)instead of this section.
some how cifferent than the review of the TS change.
This appears to awne imm GG UFSAR 7.4.2.7.e and proposed Also, I would have to clarify the TS review requirements ;
' clantication from RG 1.33 Secton C.3. This seems to be used as twice if Ileave this section app 5 cable. Section 43.4(3) basis but it is not clear why this should require an provides the needed guidan::e; therefore, excep8on to l exceptiordelarNicahon to 4.3.4(2). RG1.33 CJ merely states "Section Sec60n 4.3.4(2) was taken for clarity. t 4J.4,
- Subjects Requiring independent Review," Item (3) states, in part, that changes to the techmcal specdicahons or license ;
amendments related to nuclear safety are requwed to be reviewed by i the independent review body prior to implementahon. It should be i noted that proposed changes to techmcal specificabons or license !
- amendments should be reviewed by the independerd review body prior to their submittal to the Commissson for approval.* What is the [
purpose of this item 6 cion6cahon? Isnt commenent to the RG i enough? See L20.
Q-13 Table 1 C. 7. ANSI N18.7 Section 4.3.4(3) This requirement is Letters which transmet a proposed techmcal I implemented by reviewing the no significant hazards specification or license change to the Commission j considerations evaluation for the y, m z f change prior to have many parts (e.g., cover le#er and background) !
sutwns ttal to the Commission for approval. The sechon that provides the safety jus 9fication is the f a no signWicant hazards considerations evaluegon for the j I
Revision dated 08/25/98 .
L ct Entergy QAPM review matrix i Number Comment Response Closed? Submit? ;
I TNs is a new change for all the fachties. R appears to be intended to proposed change. This is the sechon of the proposed focus the anenhon of the Mependent review on the above part of the change where the safety commdlees need to focus submittal. Gaadance to lows the review here may be appropnale but their reviews. TNs change is made to clanfy that it should not necessar#y be limded to this part of the submdtal RG revissons to a previously submitted proposed change i 1.33 C.3 ciertlicallon information was also included for w.4L.a. only requires review by the safety committees when the l See A13. safety justificahon for the requested change has been moddied by the revision l
Having the safety review committees review the no segnificant hazards consideration is consistent with the '
way 10 CFR 50.59 evaluahons are handled. The commdtees review as a nwumum the evaluahon but not necessary aR of the other documents associated with a change (e.g.. the markups of the SAR). ,
Q-14 Table 1 C,8. ANSI N18.7 Section 4.3.4(4) Iri place of the From what I understand, a long time ago there were 24 qu ___ A of tNs section the on.sNe and off. site safety review hour written reports as desenbed in this sechon. These committees shall review facNity operations to detect potential were deleted and 10 CFR 50.72 (one hour and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ,
nuclear safety hazards and all reports made in accordance with cans) and 10 CFR 50.73 (30 day reports) replaced 10 CFR 50.73, them. I have never seen a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written report.
4.3.4(4) deals wilh review of vanous violations, deviations and AR of the plants have a list of items to review with the reportable events, which require reporhng to the NRC in wnhng within consisterd theme being REPORTABLE EVENTS (i.e., i 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. TNs clarification is said to be based on W3 QAP Chapter 1 10 CFR 50.73). The other requirements varied from ,
Sechon 4.10.5. However 4.10.5 has more specific examples than plant to plant and the intent seemed to be to detect .
described above. Moreover, nellher W3 or any of the other plants potential nuclear safety hazards. We have kied to i specificagytook exception to 4.3.4(4) before. R is unclear why this is identdy the acceptance enteria for the review and move needed or desired. Does 50.73 alone cover everything under some of the detaNs to procedures. ,
4.3.4(4)? See L19 and L4. !
i Also, GGNS (Att. 4 page 92 item 11) took excepilot. 3 this entire sechon and replaced it with the Inserted .
UFSAR pages j Q-15 Table 1 C. 9. ANSI N18.7 Section 4.3.4(5) Included in the matters TNs statement does not reduce the review YES ,
reviewed by the on. site safety review committee in accordance regi..~.e of Section 4.3.4(5)It only adds !
with this section are the following: .G..~.e. I tried to convey this with the words [
" Included in the maners reviewed Er and not words Eke ;
- s. new and revesed season administraeve procedures and in place or.
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- b. changes to the Emergency Plan (except editorial changes). We wNI change the words to the fonowing- !
4.3.4(5) deals with other matters involving safe opershon of the Examples of the matters reviewed by the on-slie [
nuclear plant which an independent reviewer might consider safety review committee in accordance with tiis section i appropnote for considershon. TNs clartlication is said to be based on are the foGowing: B l W3 QAP Chapter 1 Section 4.10.5. These are items included under ,
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4.10.5 for W3. However, neitier W3 or any of the other plants specifically took exception to 4.3.4(5) before Therefore, so long as the above statement is taken as an example and not an exclusive set, this could be acceptable. Pediaps wording like " such as the folloung
- Instead of * .are the fo110 wing
- See L19.
Q-16 Table 1 C.11. ANSI N18.7 Section 4.5 The independent review AH of the sites required that t% offsde review body discussed in this section is the off-site safety review committee oversee audds (ref. GGNS Att 4 page 89 committee. Item 7.42.8). The only potential conthet is that Die on-site safety review committee is also an independent Section 4.5 Includes a 6...~..; for a penodic review of the audit review body and that is not Bie body that should program be performed by the independerd review body or by a perfomt this review.
, management _.; ._.; at least semannuany This ciannesson is based on W3 QAP Chapter 1 Sechon 4.9.10.3 and Chapter 18 Sechon 5.2. These Sechons do indicate that audit actmties are performed under the cognizance of the SRC, although specdic pertotRc seview requirements are not addressed 1 a., as far as the above clarf6 cation, Store would riot seem to be any reason within 18.7 or RG 1.33 which would conlEct with the above clartlication. See L19.
Q-17 Tatdo 1 C.12. ANSI N18.7 Section 5.1 Instead of the requirements This sentence was referring to the fact that RBS does of this section to have a summary document, a method of cross not have a QA program implementing procedure list
._~_._.._-.g these requirements to the implomonung procedures with associated responsible department in tielr QA was be maintahwd. manual.
ConsWent wRh the Q4P approved by the NRC lbr RB7 Where is this
, in the HB 04P7 See (21.
Q-18 TatWe 1 C.13. ANSI N18.7 Section 5.2.2 The person who hokis a GGNS Att 4 page 92 item 14 takes exceptert to aR of senior reactor optrators IIconse for the affected urtit and the temp. change requirements in N18.7 Sechon 5.2.2 approves a ^_...py change to a procedure is not and says GGNS win follow the TS and IFSAR.
required to be in charge of the shift. LXSAR pages 208 and 209 are the requirements (they previously were the TS requirements). Since GGNS The basis for this GG tFSAR page 1G8.1-208 & 209. Here when took excephon to the mR of the temp. change i desenbing temporary approval and the two members of the plant requirements they did not address the N18.7 Secton management staff, it only adds that
- at least one of whom holds a 522. words of
- supervisor in charge of the shift *
- Senior Reactor Operator's License." However, this does not GGNS only specified the person hold an SRO. Since specslicaEy take excepten to 5.2.2 which may be viewed as an rm no longer taking exception to the aN of the temp.
additional requirement on this operator? Is there anywhere else, such change regtJ. ..~..^., I needed to address the words Iri l
as in the LFSAR excepeons to RGs or other NRC N18.7 Secten 5.2.2. Taking excepIlon to the words approvals /posi8ons, which specNicsWy exempts Sie requirement as is "supervisorin charge of the shilt"is consistent with the i done above? See L20. current GGNS requirements, The revised requirements provides sunicient controls to insure knowledgestde operations involvement whRe aNowing for the wortdood on shNt personnel to be contm5ed.
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t ., _.-p F-:- ; _"_. change process described for changes to the change process for changes potenhaty involving which clearly do not change the Intent of a procedure, temporary intent changes Like the temporary geced,... changes procedure changes which may change the intent of a procedure which clearly do not change Wie intent. these temporary may be made following the process described in this section. procedure changes must have the remaining reviews l Except that the person . .._ j n ; 1T_ for approving performed prior to beamung permanent. ;
revisions to the procedure is the approval ;^" ;i, for the i change.
The basis for this GG UFSAR page 168.1-208 & 209. Here there is an additional option not covered in 5.22 for lernporary changes, i.e. !
, those which may involve a change in intent As this was previously t accepted GG by the NRC, and as tie person approving is the person normaWy responsible for approving the revision, and provided other -
normal requirements for procedure review are met. ins appears to be i
acceptable is additional comment on review regisements for this specisi case needed here? See L20. i Q-20 C.15. ANSI N18.7 Section 5.2.6 Instead of the m_. _..._..^. of The wording of the clarificahon is to broad. The intent YES this section, .._.. L.." ...;. conditions will be evaluated and was that the discussion concoming the control of controlled in accordance with the corrective action program. nonconforming conditions be taken excepuon to by this cianacamon. i Secnon 5.2.6 deals wth equipment control in general and goes beyond just control of nonconforming conditions. Ajustificaton for Revise the clartlication to the following-not using tiese equipment amtrols in addition to those which may be required by the conoceve acGon program has not been provided. "Instead of the requirements of this sechon -:_---n.l...
Whatis Sie purpose of tile clarificationfonception? See L4. non<:enforming conditions, non-conforming
, condihons we be evaluated and contmeed in acmedance with the corrective acton program."
This section in the ANSI Standard talks about dedaring systems inoperable. Each plant has a program to meet Generic Letter 91-18 to control the decision process for J.L...a.s ll equipment is inoperable N was considered st.a to leave an of the detaRs in the GL 91-18 program.
Q-21 Table 1 C.16. ANSI N18.7 Sec9on 5.2.6 The .e@ _... ..; of the The requwemerd that the actMty be in accordance witi YES fifth paragraph of this section to have a log of the status of an approved procedure was considered to be a
- ..-.c _.-i modificanons is not appucable to temporary sunicientdesenpeonof thetypesof tasks. Thewon2ng modifications Installed in accordance with procedures which of the exemption is modified to insure that the interd of provide assurance that approvals are obtained, :_.. -y IIem (2)is maintained. The words are not modified to modification activities are verffled, and that activttles are match the words of item (3) since to proposed words adequately documented to ImNeste the status of the L..,_ -i more accurately re#ect the requirement as discussed in modHication. N18.7. N18.7 required *[a] log shaR be maintained of Revision deled 08/25/98
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me cupent status of such temporary modecagons."
This is basicasy consistent wNh 9e cupent QAP approved by the The proposed words require the acevees be NRC for ANO (ANO QAP Secton 14.2.5). However, the ANO wonNng W _ ^ f, documerded to indicate the status of the seems somewhat more resenctive. i.e.*Addshonany, temporary :....,~. i moddicamon
- modecatens which consieute temporary changes to plard
, amfigurabon due to rou#ne tasks such as the additions of Modify the excephon to state: ;
i :_..w p jumpers or gauges as part of maintenance, ,
I caNbrellon, or troubleshooting, may be installed and removed by The requirement of the fifth paragraph of this secIlon to use of approved y,-M. or work plans, providing (2) and (3) have a log of the status of temporary modi 6 cations is above are sabstied. These changes are not mamtained on a status not apphcable to temporary modscations installed in log since removal of Wie temporary change is controlled by the same accordance with procedures. These procedures shall
, procedure or work plan which installed it * (2) above refers to provide assurance tiat approvals are obtained,
! Perform independent verscahon of ^ ..~ f modmcamons by an temporary modecason acewines are independency
! individual cognizant of the purpose and the eNect of the temporary vertRod by an Indhridual cognizant of 9m purpose ,
modincation * (3) above refers to ' Document temporary modificabons and the effect of the temporary modNication, and
. to assure Sie acIlons are taken to retum the equepmerd or system to Sist activihes are %--- ^ ", documented to indicate lts original operaung configuragon and status
- See L4 and L16. the status of Wie temporary mo Riication. t Q-22 Table 1 C.17. ANSI N18.7 Seceon 5.2.7.1 This section wHI be QAPM A.1.d provides the documentation requirement.
impeemented by adding 9m words "Where practical"in front of i the first and fourth sentences of the fNth paragraph. For i modWicaHons where the requirements of the fourth sentence are not conshfored prac9eal, a review in accordance with the prowlsions of 1C CFR 50.SD w111 he conducted.
t
- This is consistent with cummt QAP approved by NRC for GG in llems l (4) and (17) under excepNons to RG 1.33. ii-.c, (4) also !
- specifically requires the 50.59 review also be documeresed See 1.20.
j Q-23 Table 1 C.22. ANSI N18.7 Section 5.2.15 Requked procedure 10 CFR 50.73(b) requires the identification and reviews fonowing the occurrences discussed in Section 5.2.15, conection of procedures deficiencies which contrtpute
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p . ,;. ^ 3, sentonce 3, are determined and controlled In
_ to REPORTABLE EVENTS. QAPM A.6 requires that t the root cause of segnmcant events be inveshgated and I ai.cordance with the QAPRR Secuen A.S Insteed of this section.
j corrective actions taken. BasicaNy, excep#on was This is based on an cummt QAP approved by NRC for GG in item taken from this ANSI Section to reduce the number of (22) under exceptions to RG 1.33. However, the reference to A.6 places that similar requirements are discussed using l above does not seem appropriate to direc8y address this Section dWererd words. The proposed requirements meet Wie ;
Wording in cummt GG QAP that appues is: *AppNcable procedures intent of the ANSI Standard while reducing the potential e
! sher be reviewed fotowing an acodent, unexpected transient, for confusion caused by dWorent words being used. [
l signincant operator enor, or equipment mosuncBon which results in a i reportable occummce The dWorence between this and 18.7 being !
the added 'Nuhich results in a reportable occummce." Why not just I say that here? See L20 and L4. [
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Q-24 TatWe 1 C.24. ANSI N18.7 Section 5.2.16 Sentence 2 of paragraph The add 40nal words donl add to the clanty of the 3 states: " Records shall be made and - ,_ ,-.-..; sultatAy marked requwement. The clanficahon proposed provides an ;
to indicate calibration status
- Instead of requiring the marking of adequate descriphon of the OA requwements.
all equipment this statomont is changed to require the : ,- ( ._..;
to be controlled to Indicate the calibration status. In addition to the cummt RBS c6Picahon, GGNS has a clanticahon allowing the use of a computertred !
. This is basica9y consistent with the intent of the cummt QAP system (GGNS Att 4 page 96 itens 30) clartlicahon approved by the NRC for RB for ANSI N.45.2.4 section 2.5.2. In a recent SER for Farley the NRC found attemahves to '
marking calibration status on equipment to be @ based on:
(1) unique instrument numbers are readable at the inshument, (2) the instrument numbers are traceable to calibrabon schedules and i l
remeds (3) the caRbration schedules and records contain the same information as required by ANSI N45.2.4(1972), (4) these schedules and records are readNy accessible to personnel who are required to i check calibration status as required by goveming procedures, (5) and the above allemative to tagging or labeling instruments with caRbrahon data !s *othennse contro5e# by its desenphon in the requested change to the QuaRty Assurance Program DesenpHon. Do the " controls
- as used here by Entergy cover these general criteria?
Is more detail needed here, or is detail in controRing procedures sullicient? Perhaps something like " controRed to indicate the calibration status to the same level of informahon as requwed by ;
N45.2.4 and N18.7, with equivalent clanty, and with ready accessibility to those requinng informahon on calibration status of equipment." See L8.
Q-25 Table 1 D.1. General Instead of using the cleanliness level RBS USAR Sechon 1.8 page 46 Item 2 at the bottom of classification system of ANSI N45.2.1 the required cleanliness the page.
for specific flems and activities is addressed on a case.by-case basis. Cleanliness is maintained, consistent with the work being performed to prevent introduction of foreign matedal. As a
.. .. __..., cleanIIness :.=g _ _^*_-.; are performed prior to system closure and such ".- . n"_._ are documented.
This is descrbed as being consistent with Wie cummt OAP for RB.
We don't have a specific table of excephons for RB. Were is this i exception described? See L10.
Q-26 Table 1 D.3. Section C.4 Contamination levels in expendatWe Clarification proposed is consistent with a RBS products are based upon safe practices and industrial clanfication. Reference RBS USAR Section 1.8 page availability. Contaminant levels are controlled such that 46, Paragraph C.4 clarification,last half of the i eubsequent removal by standard cleaning methods results in paragraph.
the achievement of final acceptalde levels which are not detrtmental to the materials.
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C4. States:"Section 5 of ANSI N45.2.1-1973 states. In part, that low -
suNur,leur fluonne, andor low chlortne compounds may be used on
- sustenitic stainless steels and that low suNur and low lead compounds may be used on nickekbese suoys. chenweal compounds that could contribute to intergranular cracking or stress-conosion cracking should not be used wNh austenite stamiess steel and nicke0 base i aRoys. Examples of such chemical compounds are those contaming
. chlorides, fluorides, leed, zinc, copper, suNur, or mercury where such elements are leechable or where they could be released by .
. breakdown of the compounds under expected erwwonmental !
conditions (e.g., by radiaton). This limitaton is not intended to prohlblt t the use of N which meets he requwements of Mistary SpeclRestion hW-C 81302b for cleaning or degressing of l austenluc stainless steel provided Rio precautions et subdivision ,
7.3(4) of ANSI N45.2.1-1973 are observed." i The GG clermeston emed states in pert:" Expendable metenals ;
which contact stainless steel or nickel aRoy surfaces shall not contain lead, zinc, copper, enercury, cadmium and otier low mellmg point metals,9 sir aseys or compounds, as basic and essential chemical
, consstuents. Prescrbed maximum levels of water leechable chlorides, total hologens, and sulphur and its compounds sher be .
Imposed on expendable products." j lt is unclear w the newly worded excepton is consistent wNh either of these statements. The hiustrial L - " 7," basis does not address ;
the safety issue. The cleanmg option to maintain acceptable levels, although a good practice,is not addressed as a basis in either C4 or l the referenced GG clarincation. This issue may need to be forwarded l to the materials group for a technical determination See L20.
Q-27 Table 1 E.5. ANSI M45.2.2 Section 4.3. Inspecnons of packages This clartReston is based on a clarificallon to in the !
anser preservanv. comungs are made knemmately prior to RBS USAR. Reference USAR Secmon 1.8, page 48, l loedne rather then aRorleedng. Nem 3.
f The new dortlication is said to meet the intent of the original The supplier vermes that the packaging is OK when R is Regulatory Guide or ANSI requirernent and is consistent with a given to the shipper (Section 4.3) and the warehouse discussion in Wie GG UFSAR. Where exacey is Wils GG discussion verfiles Wiet it is OK when R is recolved (Section 5.2.2). !
located? Is the conam tiet some areas may not be accessible for You can not riscossary inspect R while R is loaded.
inspection aner Wiey are loaded? Perhaps "during Iceding" (i.e. each ;
i leem is inspected as R is loaded) may be closer to Rio intent. See .
L17.
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Q-28 Table 1 E.21. ANSI N45.2.2 Section A.3.6.2 The last sentence is RG 1.38 does address this issue and the words seem YES considered unnecessary guidance and not an Appendix (A-3) more oppivp ;ote. This clanfication can be deleted.
appropriate requirement since vapor barrier materials are usually brown, cream, or black in color. Delete E.21 and renumber remaining clanfications.
The last sentence states "The bamer matenal should be brightly colored to preclude loss within a system." The above statement does not necessarily seem to be mnsistent with this. Altemate wordmg such as " appropriately colored to prevent loss " might be acceptable. Justificahon given for this change is that the new clo ;Ta;ui, meets the intent of the ongmal Regulatory Guide.
. L;;., C.1.e of the RG states " .In lieu of this guideline, the vapor bamer material should be colored to contrast with the materials on which they are used." Therefore, why should any exception or clanficahon to the RG be needed at aR7 See L17.
Q-29 Table 1 E.22. ANSI N45.2.2 Section A.3.7.1 In lieu of A3.7.1(3) This Ar.coi;ui, is consistent with a clanfication lo in and (4), Entergy will comply with the feL.J.,ii; Appendix (A-3) the RBS USAR. Reference USAR Section 1.8, page Fiberboard boxes shall be securely closed either with a water 49, item 6.
resistant adhochre as* plied to the entire area of contact between the flaps, or Mi sSams and joints shall be sealed with not less The intent of the ANSI seem to be that the box be well '
than 2-inch wide, water resistant tape. sealed. Either on of these methods seem sufficient to meet that intent.
Stated reason for this clanficahon is that it meets the intent of the ongmal RG or ANSI requirement and is mnsistent with a discussion in the GG UFSAR. What specific . "..e.vus are used to arrive at this conclusion? The standard indicates that both adhesive and the tape are necessary for item 3 and item 4 Indicates that strapping with reli. forced tape is also necessary.
Q-30 Table 1 E.26. ANSI N45.2.2 The last paragraph of A.3.9 could be The proposed item removed some of the specific iniwi,,,13 as prohibiting any Appendix (A-3) direct marking on details, but engineering evalua6ons control the bare austenttic stainless steel and nickel alloy Section A.3.9 materials used.
metal surfaces. As a alternate, paragraphs A.3.9. (1) and (2) may be used to control merking on the surface of austenttic stainless steels and nickel base alloys as long as contamination levels in the motorial used for marking are controlled such that the merking Is not detrimental to the materials marked.
This is basically consistent with a clarificahon for RG1.38 on page T1-7 & 8 in the OAP approved by the NRC for ANO. However, the following specille conditions were included in the ANO empi;ui,.
" Marking materials containing sulfur ',ead, zinc, mercury, copper, and Revision dated 08/25/98
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Entergy QAPM review enetrtz Number Conwnent "x i _ Cbeed? SutwnN7 km melbng point aAoys as basic chenweal constduent shall not be twought in contact. or shes not be used on surfaces of conosen resistant aRoys. Low-:;; ,,; a. tow fluonne and/orlow chionne cxwnpounds may be used on austendic stainless steels. the maximum limits for the above mentened merking materials wiR be as fonows:
(a) total inorganic and organic halogen content shaR not exceed one (1) percent. (b) The sulphur content shen not exceed one (1) percent.
What speclRc addhional requirements are commdted to in order to ensure that these Rmitations are observed, and where are they located? SeeL16and L4.
Q-31 Table 1 F.1. ANSI N45.2.3 General The ANSI thre level zone The statement "in the operahons phase
- was removed designation system may not be utNtzed, but the Intent of the and is not needed since all of our units have completed standard wlH be met for the areas of housekeeping, plant and the construction phase The original QA manuals were personnet sessty, and are protoceen. cM during the construcSon phase.
This is generany consistent wNh a ciarmcaten for RG1.39 item 7 on That the designations are controHed by procedures is page 42 in the QAP approved by the NRC for W3. However, to avoid requesd by QAPM A.1.d. QAPM A.3.f says that future confusion and to be completely ansistent. the statement procedures are to reGect the QAPM requirements, shouks be prefaced or fosowed by
- in the opershons phase " Also include a stalemord to the effect that procedure or instruchons for The term
- case by case basis
- raally <5dn't add any housekeeping to include the applicable .@.. ..:. of this standard thing to the exception. The requwemerd is that we wEl be developed on a case by case basis, as was included in the W3 proceduraRy ensure that the intent of Nw standard is case. See L19. . met for aR applicable pierd areas.
Q-32 Tatdo 1 F.2. ANSI N45.2.3 This seceon is not appNcable. ' The statement "m the operabons phase
- was removed Section 3.1 and is not needed since an of our units have .,/, ^J the constructen phase. The original QA manuals were This is basically consistent wth an exception for RG1.39, llem 2,7th developed during the construebon phase.
paragraph in the QAP approved by the NRC for GG. ; - .x, to avoid future confusion and to be completely w. -..: the statement shoukt be prefaced or sosowed by
- in the operagons phase " See L20.
Q-33 TatWe 1 F.5. ANSI N45.2.3 SocGon 3.4 This section is not The statement *In the operatens phase
- was removed appucaldo, and is not needed since mR of our units have comp >ted the construcuan phase. The original QA manuals were This is basicaNy consistent wNh an exception for RG1.39, Nem 2,12th developed during the consbuctan phase.
paragraph in the QAP approved by the NRC for GG. However, to ,
avoid future mnfusion and to be completely . :,,..: the statement should be prefaced or fotowed by wilh
- in the operations phase "
See L20.
Q-34 Tatdo G.2. ANSI N45.2.8 SecSon 1.2 Paragraph 4 requires that the The first sentence of the last paragraph says that it stamtard be imposed on personnel other than Ncensee appNes to
- personnel of the owners
- The proposed unpooyees; the appNcablNty of this standard to suppNors wlN be clarlRcation doesn't affect that requirement.
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documented and appued, as appropriate, in procurement documents for such suppliers. !
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This is consistent with an exception for RG1.58, item 2 in the QAP approved by the NRC for GG. See L20. R ;;; perhaps the wording could be revesed to speedically indcale that this standard ;
remams appleable for licensee m. A,cca. ;
Q-35 Table G.3. ANSI N45.2.6 Section 1.2 The requirements of this I don 1 think there is any dWierence in the meanings but YES standard do not apply to ,,.......- J using editions of ASNT wel change the words to:
contained within 10 CFR 50.55a approved ASME editions or addenda labor than those IIsted in the standard. The regi,;.e.. .L of this standard do not apply to -
personnel using later editions of ASNT contained This is basicapyconsistent with an exception for RG1.58, item 6 in the within 10CFR50.55a , .._ ASME edtions or QAP approved by the NRC for GG. L;;;i. for the above to be addenda.
mnect, it should be clear that the standard is "not intended to apply to i personnel who only perform inspection, examinahon, or teshng in accordance with ASNT SNT-TC 1A.* This is already stated in the t standard. It seems the real queshon might be the edihon of ASNT. '
Perhaps the ongmal GG excephon wordmg is better (i.e. The bcensee ,'
reserves the right to use later edihons of ASNT contamed within 10CFR50.55a approved ASME edihons or addenda.) See L20 Q-36 Table G.5. ANSI N45.2.6 Section 3.5 Entergy reserves the right to The attemale requirements will be as determned use personnel who do not meet these expertence 7: ,_ _ _..._ ^ -
appropriate by the individual authonty responsible for
. but have shown capablNty through training and testing or certificahon of these individuals. They could be capatdlity demonstration. different dependmg on the certification being sought.
In accordance with QAPM A.1.d procedures will specify i This is consisterd with an excephon for RG1.58, llem 5 in the QAP the requirements, appsowed by the NRC for GG. See L20. What are the allemale traming/ testing / capability requirements for these levels? Were are the specifimf?
Q-37 Table 1 J.1.RG 1.88 Section 4.4 Entergy wNI meet the The NOA-1 piece is on ANO Att 3 page 167. -
requirements of ANSt/ AS ME NQA-1-1983, Section C " - ._._ L ._ ."
175-1 In lieu of N45.2.9 Section 5.6 or the discussions in this The penetra60ns piece, as im5cated on the ANO section for Records Storage Facilitaes with the clartfication that markup,is based on GGNS Att 4 page 115.
...:._--- - proviens fire prosecuen, Nghung,
^ .,__. ^ s 1_..J ^-^, control, or communications are acceptable.
Where is the ANO excepdon on which the pi y..p. is said to be based, and Wie R8 excephon on which the second paragraph is said to based?
Q-38 Tatdo 1 J.5. ANSI N45.2.9 Section 5.4.3 Instead of the OK YES i; ; ' ;..__.. of this section, Entergy wNI comply with the
- ^
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Entergy QAPWI review niatrix stumner conwnent Nespones tw-cr S dnet? ,
fonowing: Provtssons se*as be made for species piecessed Change this exampGon to say:
records such as reeographs, photog'aphs, negaeves, micronem, i i
and magnenc mane to pmvent damese Ihnn excesseve acht. Instead of the requwements of this secmon Erdergy wM stacking, esectromagnose netds, temperstwo, and humidNy as cornply wMh the fotounng: Provissons sher be made for appropreste to the record type. special processed records such as radiographs, photographs, .M.s, micromm and magne8c mede t This is consistent wNh an excepton for RG1.88. Nem 4 in the QAP to prevent demoge from exceserve Eght, stacking, approved by the NRC for GG. However, N would seem appmpriate to eleckomagnetc Reids, temperature, and humidRy as include " wNh appmpriate consideraton of packaging and storing appmpnote b the record type wHh appropriate
. recommendegons as pmvided by Wie manutedurer of these considerasers of packaging and stortng meteriess. This womed help ensure that the . .. .; from the recommendogens as provided by the manuInsturer !
!. orighet stondent is at seest considered when appropriate. See L20 of those motorials, t
Q-39 Tehte 1 J.7. ANSI M45.2.9 Section 5.6 Entergy wlR meet the The NQA-1 piece is on ANO Att 3 page 167. t
'; requirements of ANSDASIAE NQA-1-1983, Supplement 175-1 Secmon 4.4 In Bou of this sec#en for Records Storage Facillnes The penetragons piece, as Indested nn the ANO wMh the ciertReagon that penetrailons provieng Bee , ^ 1., markup,is mmt e on GGNS AR 4 page 115.
IIghung, temperaturofhumidIty control, or communications are f acceptable. Except that as an afternate to these 4 - _..._.J-. The second paragraph booed on RBS 'J!iAR hremi
..... _...._- - ^ records (e.g.,3 years retenson records) nemy tus 1.8 page 135 Item c.
stored and molntained by the originating orgentemWon In one. hour nenemmn are rated fue cabinets located en
. ..". .. .._.J. "", controIIed facIII8es West have sultable fire
, _ u-"-
^
Sultshte Are protec9en is prowhlod try eNher an setomatic springder system er a combine 8en of two or more of i the following: 1 ) automeWe Are eierms 2) home stodons, or 3) t portable ousnguishers.
The escussion at penetramons in the Arst paragraph is ensistent wNh an excepuon for RG1.88. Nem 8 in the QAP appmved by the NRC for GG. However, that excep6on also states lhet *AN such penetrahons sher be sealed or dampered to comply wNh a minimum two-hour fire ,
pmtecton raung." How is this addressed and where is the reference !
to NQA-1 mode? See L20 and L18. [
RB is ched as the source for We second peregraph. How was this arrived at? See 1.18. !
Q-40 Table 1 n.s. ANSI N45.2.5 SecGon 5.5 EntergF we comply wNh NRC wM know and approve weteng code dienges i inspec9en requirements of Wie appIIcab8s wekRng codes and any through Sie 10 CFR 50.55(a)(f) process. This is Wie ;
excepeone Instood of this sec9en. method for later codes to be approved and Wisir use authortred for Nuclear FacAltes to use. EOI Swough j This is boolcapy consistent witi an excepgon for RG1.94,IIem 7 in to the 10 CFR 50.55 required updates of 10 Year ISI :
QAP approved by Wie NRC for GG. See L20. However, Wie GG Pmgram wlR show which codes to use inclueng original I
Revision deled OtW25198 f
-o l EnterWy QAPRI review matrix l Number Commerd Noeponse Closed? Sulmdt?
excepeon states Sie appecatWe wekting codes are spedNed in the constructon codes, where appar=M=
, UFSAR. What is the control here to ensure that the NRC knows and
- approves of tie codes being app 5ed?
Q 41 Tatdo 1 L1. ANSI N45.2.8 Sec9en 3 Documented rousne The first fur sentence on ANO Att 3 page 151 (T1-10) inspec9 ens and amets of the storage area may be performed is Weis statement. The clarWicagon begins on pogo 149 ;
instead of Wie requirements of this secIlon. (T1-9). The rest of Bie cierWicagon is sisEng Sie beeis
^
or a9ect of 9 e cierflicagon and is root notessary in Sie !
This said to be based on an exception in Wie QAP approved by Sm QAPM. I
! NRC for ANO. However, We approved excepton for ANO on page !
T1-9 does riot seem to explain this. Where are Wie appropnate referenas and how was Wie abovn exception arrived at? See 136.
Q-42 Tatdo 1 RR.2. ANSt N45.2.13 Sec9en 1.2.2 Item c is an op6on GG 7.5.7 is covemi by the clariRcabon to RG 1.144 ,
which may be used to assure quaIRy; however, any opgen ghen Secton C.3.b.(2)identWied in Table 1 Item N.3. This . !
in it cFR se Appenas a, cenerton we as septemented by the nem and the associated RG requirements address the i
, QAPM may stee be used. evalueuon of the suppser's OA program. The part t pmposed for removalis the estof 4 - sources.
t
. This wonSng is basicsNy consistent wifi en exception for RG1.123 This clerillestion is being moduled as sear == sd in item 2 in Wie QAP approved by Wie NRC for GG. However, GG's Quesson 46 below.
l existng po5cies 4 and 7 on procurement document entrol and contal i
of purchased ensterial, equipment and services which are clied in Sie Natung signlReant was removed from Sie QA menuel GG excepton to this RG contain information spe:$lically on evalueton se=rn==lan of GGNS POReies 4 and 7 in tio conversion of tie supplier's quegly assurance program that does not seem to be to the new QAPM. Items from to ANSI Standards just
speellicaNy requires evaluations of the Supp5er's Queilly Assurance program (altsough Weis IIem was proposed for removal (see L4)).
What items in tie new QAPM are speclResNy address St.2.2.c
. requirement for an evaluellon of the supplier's QA program andfor Bio creerie vil requkements for the appucant assessment of the e9ectiveness of tie control of queuly by contractors? Is evaluation of Wie supp5er's QA program speelResp y addressed or an allema#we speclRcoRy descrtied anywhere in Wils OAPM7 The apparent removal of Wie specNic . - ,_~._ ^ for evaluston of supp5er's OA programs does not seem to meet Wie intent of tie standard or App B. Cnterte VII. The only issue really seems to be the method of evaluating Bio QA prograrn and not whether it should be evaluated. Therefore, is it necessary to take excepson at aN? If so perhaps a statemord such as Totens of to motiods used to evaluate tie suppter's quality assurance pmgram as requesd by this secGon are implemented by the QAPM and associated procedures.* See L20.
Q-43 Tahde 1 M 6. ANSI N45.2.13 The requirements of the QAPRR will NRC ptoce holder be implemented instead of sec9en 3.4 Wes sec9en.
M
Entergy QAPM review matrix Number Comrrent Response Closed? Sutwnft?
This is basically consistent with an excepten for RG1.123, item 4 in the QAP approved by the NRC for GG. It should be acceptable here provided that the Entergy QAPM sechons on procurement document control and control of purchased matenal, equipment, and service are found acceptable with respect to GGNS's existing poloes 4 and 7 which are cited in the GG excephon to this RG. See L20.
Q-44 Table 1 M 8. ANSI M45.2.13 Section 8.2 Item b Mon-conformances OK YES are only required to be submitted to Entergy when the non conformance could adversely affect the end use of an item Change the wording to the following-relathre to safety, InterchangeablIKy, operatety, tellablWty, integrfly or maintainatHuty. Non-conformance notices for conditions descrfbed in this section are nnly requred to be suberutted to This is basically consistent with an exception for RG1.123, item 3 in Entergy when the non-conformance could .hC; the QAP approved by #m NRC for GG. The GG excephon also Ilsts affect the end use of an hem relative to safety, the 4 non-conlormances contamed in the standard that the above ireerchangeabay,operabay, rensbury,integreyor statemerd appres to. Perhaps wording such as l*mxmformances maintainabaty.
mnditions described in this sechon are only would remove any doitd. See L20.
Q-45 Table 1 M.1. RG 1.144 Section C.3.a.(2) This section is not The ongmal OA manuals were hw dunng the applicable. :enstructen phase Statements like *In the operations phase
- were removed and ans not needed since mR of This is consisterd with an exception for RG1.144 Item 13 in the QAP our units have w,4. J the construction phase.
approved by the NRC for GG. Section C.3.a.(2)is for Design and Construction Phase Achvihes. Perhaps add * .in the Operahons Q-46 Table 1 N.3. RG 1.144 Section C.3.b.(2) Instead of the annual OK. But the procedures and documented part is YES documented evaluation of suppilers discussed in this section, a covered by QAPM A.1.d.
review of the supplier's performance is conducted in accordance wfth p.-- : L Modify the clarification to state:
This said to be consistent with an e>cephon for RGt.144, item 14, instead of the annual documented evaluanon of p y.op;. 3 in the QAP approved by the NRC for GG. This suppliers discussed in this section. an ongoing povoy,4 actual says"A documented ongomg evaluahon of the evaluation of supplier performance is conducted suppher should be performed." It also states, where applicable, this which takes into account, where appNestWe, the review should take into acmunt the same items listed in this sechon other considerations of this section and paragraph and po..y,4, of the RG. Consider wordmg such as
- documented of the Regulatory Guide.
ongomg evaluation of supplier performance is mnducted in accordance with procedures which take into account, where appilcable, Wie other consideranons of this section and paragraph of r the RG.* See L20. l l
Q-47 Table 1 N.4. ANSI N45.2.12 Section 4.3.1 Pre-med!! wi post. audit RBS USAR Sechon 1.8 page 204.
conferences may be fulfmed by a variety of communications, such se tcisphone conversation.
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Section 4.3 does not appear to place any restrictions on the communicaton method and therefore this is acceptable. (RB OAP was referenced here but I did not see a .f .c..u. to communicahons method, Where did this come from?) See L18.
Q-48 Tah8e 1 N.S. ANSI M45.2.12 Section 4.3.1 Pre-audit and post-audit N the quahty assurance vigersua.v. does not feel that confetsnces are only held when deemed necessary by quaNty the audit and/or finding need a mnference with the assurance or when . : ,- _ "._ f by the audNed organization. audited orgaruzation and the audited organization does not feel a need for the meeeng, what purpose is Wie This is consistent wilh an excepson for RG1.144, item 3 in the OAP conference achieving? The purpose of the W3 approved by Wie NRC for W3. However, muld wording such as
- exemption is to allow W..~..; be used to determine are normally conducted, except wert= they would interfere with the when a conference would achieve a useful purpose, nature or schedule of the audN, e.g. unannounced audits, persons Having a conference just for Wie sake of having a normally attending audit not available, etc
- This wording might bener conference detracts resources from more important capture tie intent of Wie standard and that of the approved exception tasks.
for GG. See L19.
Q49 Table 1 N.7, ANSI M45.2.12 Sec9en 4.3.3 Pro. audit and post. audit W the quahty assurance organization does not feel Wiet conferences are only held when deemed necessary by quality the audit and/or finding need a conference with Wie assurance or when requested by the audNed __ ^~ -:- a. audited organization and the audned organizallon does not feel a need for the meeting, what purpose is Wie This is consistent wilh an exception for RG1.144, llem 3 in the OAP conference achieving? The purpose of the W3 approved by Wie NRC for W3. However, could wording such as " exempUon is to allow judgement be used to determine are fiormally conducted, except were they would interfere with the when a conference would achieve a useful pqrpose nature or schedule of the audit, e.g. unannounced audits, persons Having a conference just for the sake of having a normeNy auending audit not available, etc., or formally deemed as conference detracts resources from more important unnecessary
- This wording might better capture the intent of the tasks.
standard and that of the approved excephon for GG. This is the same mmment as the pre-audit comment above, only it would seem even more important in the case of post-audit as findings could be discussed See L19.
Q-50 Table 1 N.S. ANSI N45.2.12 Section 4.3.3 Pre-audit and post. audit RBS USAR Secton 1.8 page 204.
conferences enay be fuMIHed by a verlety of communications such as telephone conversallon.
Sechon 4.3 does not appear to place any restrk:thms on the communication method and therefore this is acce$. (RB QAP was referenced here but I did not see a reference to communications method. Where did Wils come from?) See L18.
Q.51 Table 1 N.10. ANSI N45.2.12 Section 4.5.1 The QAPRI Section A.S ANO Att 3 page 163 provides lhe basis for the first YES corrective acWon program may be used instead of these serdence. The only part of the ANO exempGon that is
.-,__..._.r Also, no addmonal documentauon is not addressed is the 30 day requirement.
necessary ll needed corrective actions are taken and vertfled Revision dated 08/25/96
Entergy QAPM review matrix Nurnber Comment Response Closed? Submit?
prior to audit report issuance. Change the exemphon to the followmg This does not appear to be w.6:J, mnsestent with the intent of the The OAPM Section A.6 conective action program may standard or the cilc t exception to RG1.144 item 11 in the OAP be used instead of these regi,;.s..me as long as the approved by the NRC for GG. The GG excephon merely states that appropriate time Ilmits are appfled to significant wntten response is not necessary if conective achon is taken and conditions adverse to quality. Also, no additional venfied prior to issuance of the audit report. Therefore the second documentation is necessary if needed coneckve sentence above is consistent, however, the first is not. If somethmg schons are taken and verflied prior to audit report to the effect that " to meet these requirements provided the same issuance type of follow-up infomtation and schedules are met." replaces "
Instead of these requirements.*, then this might be acceptable. See 120.
Q-52 Tath 10.2. ANSI N45.2.23 Instead of the requirements of this The documentahon and procedure discussion in the YES section, the following may be Section 23.4 Implemented. SONGS SER is covered by OAPM A.1.d.
T.;,_ .C.; lead auditors shall demonstrate their atWUty to effectively implement the audit process and lead an audit team. The SONGS SER statement *and having met the other Upon successful demonstration of the sollity to effectively lead provisions of Sechen 2.3 of ANSIIASME sudets,Ilconsee management may designale a ,,. _ m _ _ .. lead N45.2.23-197B* is covered by the fact that this suditor as a lead auditor." clarification only applies to Sec80n 2.3.4 which only discusses the number of audits requirement.
The basic concept of demonstranon of skins for lead audnors was previously approved by the NRC for SONGS. The follomng exception ill modify the clarificahon to discuss the one audit item was found acceptable from the SONGS SER.
" Prospective Lead Auditors shall demonstrate their ability to Prospectrve lead auditors shall demonstrate their ability
.~. ,0;f; implement the audit process and effectively lead an audit to ,.1.f..d, implement the audit process and lead an team. This process is described in wntten procedures which provide audit team. They shall have shall have participated for evaluation and documentation of the sesults of this demonstrabon. In at least one audit within the year proceding the in addihon, the prospective Lead Auditor shall have participated in at Individual's effective date of qualification. Upon least one Nuclear Oversight audit within the year precedmg the successful osmonstration of the ability to ;";i.fi indmdual's effective date of qualificahon. Upon successful lead audits Iicensee managemert may designate a demonstration of the ability to A ed implement i the audit process prospective lead auditor as a lead auditor.
and ;;;Z.di eadl audits, and having met the other provisions of Section 2.3 of ANSI /ASME N45.2.23-1978, the individual may be ,
cerillied as being quellfied to lead audits
- r The NRC determined that the aNemative for lead auditor qualif. cation :
proposed by SONGS ..,,.;at an acceptable allemabwe to item 1883 of SRP 17.1 which is referenced in the crMena for audits in SRP 17.2. This determinshon was based on the licensee's proposed quality assurance program controls which requwe that 1) prospective lead audNors sc;ci demonstrate their abety to implement the i
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Entergy QAPM revleur matrix leumber Comment L_z Closed? Satunit?
audR process and lood an audit team,2) Wiis demonstration process be descrbed in wrinen pmcedures ur instructions,3) em results of the demonstregon be evaluated and documented, and 4) regartNess of the methods used for the demonstragon, the prospecEwe lead auditor shsE have perucipaled in at leest one nuclear oversight audit wikin to year precedng me Individuars eNective date of qualificallon. In addlion to tie above,9m aRemative also states that all other provisions of Sec50n 2.3 of ANSI N45.2.23-1978 regarding queNRestion of lood susters wE be met prior to tie individuars argilestion.
Q-53 Section B. 'PERFORMANCENERIFICATION" includes many We feel met De level of detail provided in the proposed statements and commilments Wiet are verbatim repeats from SRP- QAPM in corjunction wlm the commmments to to 17.3. In general consistent w19 Die requirements of $50.34(b)(6)(5), Regulatory Guedes and assotteled ANSI Standenis to staN is looedng for addWones explanatory insormenon reavding me pmvide sumosent dessa to meet to reguissory method iho Econese um adopt to implement the commbreW requirements. In most cases the level of deteE Exemples Irw*=am: pmvided in consistent wNh We level of deleRm/M; accepted on to specnic item of interest for at enest one
- SecGon B.2.a What are tio design control program provisions Sist of Wie Entergy plants.
assure tiet design acSvites are executed in a planned, controlled, and orderly enanner? N during the course of Bie review an item Diet was previously in Sie Entergy QA Plans and is raseded to
- Secton B.2.b What are to prevlolons to mntrol design inputs, meet a reguistory .- _ _ ^ in idoneRed Wiet is not pecesses, outputs, changes, Interfaces, records and organizational included in the proposed QAPM, we we address R on a intertocos? case by case h==la
- Secilon B.2.g What are Sie interface contmis for the purpose of SpeclReasy, what delats have we removed from Die developing, reviewing, appeving, releasing, disertbuting, and revising plan tietis required?
design inputs and outputs to be delined in procedures?
- Section B.3.e.: Which are Wie indviduals and gmups responsible for design reviews or cWier verWicagon acNvlues? What are their autiortues and respors=Ihemi==?
- Secean B.4.b.: What are We provisions for evalueeng prospec8ve supp5ers and seleceng queglied suppg ers?
- Secean B.4.ca What are tio provisions for ensuring Wiet quenned suppners consnue to povide =rr=ptetse peducts and services?
Secuan 8.5.a.: What are the provisions of to program to verWy We queAly of ,, " - 1 Items and services?
These are ---*= of areas Wiet require further armputying Revision dolod 08/25/98 t
.e ,
Entergy QAPM review matrtx Number Comment Response Closed? Seabmit?
%_s== inns. There are many others in the vanous areas of the QAPM. All areas should be reviewed and expanded upon as appropriate.
Q-54 Manager of QA responsible for estatWeshmg. .u.ibA9 and venfymg The staff who reports to the QA manager performs the implementshon of the QAP (no menhon of implementahon); who funciens identdied. As discussed in A.2 "The autority reports to the Manager of QA7 What functions are camed out by staff to mw.m.;;di the quality ,ssurance funchons reporting to Manager of QA7 To whom does the Manager of QA desenbed is delegated to the incumbents staff as report? (Queston the validity of L26 due to an undefined layer of necessary to fulfill the idenhfied responsibility
- management between the executive position and the QA funchon Provedmg extensive details concemmg the lower levels postlion.) of the organization detracts from the clarity of the conmtment. When the details of X number of supervisors report to the manager and the supervisors have Y iespu.idr: ,; are in the QA plan it is ddficult to idenhfy the important d inimatics of the commitment which must be protected For example is going from 2 supervtsors to three supervisors a reduction in commitment because you have diluted the authortly and scope of control of the 2 previous supervisors?
Conversely, is going from 3 supervisors to 2 supervisors a reduction in commitment because you have reduced management oversight of the individual workers?
Allowing a single layer of management between the QA manager and the VP was previously accepted in the RBS QA plan. RBS had a director position with
.ewiA*:, for QA and EP functions and a QA Manager that reported to the director. In the past the director alsn had Licensmg as a report.
Q-55 Discussion of Change L1 says *In all cases, the posdens will One way this is performed is by the QAPM requirement maintain sufficient authority and organizational freedom to implement concemmg the organizahonallevel of the managers the assigned iew.rla." This general criterion is good, but we need furvier insormason that demonstraies how this done. M gg4Q ,8gMlo q what prevousey implemented acceptance ceneria for U %gg the posdens is messmg 4$9M M 2.d.I TQ ANJ Q-56 Sec00n A.2.d (pp 8/9); no mention of QA sespo..A::^.; for these The i@iA /. odenhfied are the QA managers sespo..,_ ~-_1.of the Henhfied management posillon.
Addshonally, % requirements and commitments contained in the QAPM are mandatory and must be implemented, enforced, and adhered to by all Individuals and organizamons
- what specnic .m- .a ; are not addressed? l Revision dated 08/25/98
. _ - -- _ _ .._ . _.- _ ____.._. - -. ~ - - _ - - - ~s .- . . - . . _ - - - - _ .. .-. . _ . m.
e
.e ,
=
Erstergy QAPRI revleur rnstrht Numisor Comment k_- Closed? Sutunit?
I Q-57 ExecuGwe responette for operseons and nuclear safety appears to A2A1 states that the execuirve responstie for overaR have no responalblAly for QAP implementatior, plant nuclear safety at each site is responsible for
, estat* stung poEcles, goals, and Mas of tie ,
quahty assurance program at Wie respective sne '
Q-58 is tiere a monocer of memeenance? A2.d.2 Q-59 QA functonal responsiteties Table 1 Hem G provides Entergy's commelments to Regulatory Guide 1.58 "Quahlications of Nuclear
- 9 une organiramon personnet pertem inspeceans, are personnel Power Plant inspechon, Examinellon, and ,
Irainedin QAtechnology? Testing Personnel." ,
Q-60 QA funceonsi responohulerc QAPM Seckon C provides a idenlificahon of Gie audit i program. QAPM A.3.d requires art annual mana= ament
- What is 9 e extent of perfonnance monitoring by Wie QA of Wie QA program .m.- ^1 ,.
i organization b assure proper QAPM implementagon?
Q-61 QA functional responstENios As discussed in QAPM A2.c.1, Wie VP at each sNe is responsible for overseeing acNvilles of the associated 2
- In the RBS QAP (see QAD-1, secBon 4.1.3), the Vice President, off-site safety review commillee In accordance wth '
Operagons maintains awareness of QA meners and QAP the commitments to ANSI N18.7 Wie off-slie review enoc 9veness by review of: committee reviews this type of informaton. AdiguoneNy
^
QAPM A.3.c requires fist Wie -- - --_ , - - of Wie QAPM's
-autSt and assessment results ;. 6.._^Z , is assessed annually by Wie manager (s) responsible for quegly assurance and i
-open llem status reports reported to tie associated VP.
- NRC inspecSon reports The cummt QA piens did not aR provide the same level i of deter in Wie tNor== inn of Bie VP's funcEon tiet RSS
-independent management sesseements/ audits had. The proposed QAPM provides suNicient detaR. t
- operaung experiences Are Wiese respomdelles assigned to an execuGwe in the new QAPD j (see secten A2.c)? The .---, _--JJ" _-- of these execuGwes should be furtier descrbod with regard to their management and guidance of plant acevilles twough the managers that report to them. j Q-62 Do the responsiblRhes of the executve for overall plant nuclear safety I don 1 understand the queshon. The execueve !
(SecIlon A.2ni.) also include cogmzance of NRC inspecten responsible for overall plant nuclear safety at each alle ac9villes, industry experiences, LERs, Gt.s. bulletins, and other in- is responsble for establishing poEcles, go.Is, and house events (see ANO secWon 1.0 Organization, secton 1.3.2 objec9ves of tie quaRty assurane program at Wie !
Director N=4==r Safety) 7 .;, ,,m.";se site and e - A-activi5esof tie [
associatedoff-snesafe'yreviewcommittee Someof l We specine nems reviewed by the VP and his reports i are described in 9m QAPM and associssed :
f
~
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Entergy QAPM review matrix Number Comment Response Closed? Sutmilt?
commtments.
The curnmt QA plans did not aR provide the same level of detaR in the discussen of the VP's funcbon.
O-63 Prevous commaments for implementabon of QA funcbons not found QAPM B.12.a "Inspechons are performed by qusWied in the QAPM: personnel other than tiose who performed or direc9y sw .Md the work being inspected.*
ANO: Execuuves/ Directors and managers are responsible for QAP implementaten; Director Quality responsable for implementabon (pp.
10/11); Section 2.3.2 states "that indhnduals responsible for verification of conformance are qualified and do not perform or direc9y supeevise the work.-
Q-64 Previous commitments for implementabon of QA funchons not found QAPM A2.d.1 "The manager responsible for quality in the QAPM: assurance has overall authority and responsbility for establishmg, controlling, and venfymg the River Bend: Manager QA responsible forimplementabon of the implementation and adequacy of the quellty assurance j QAPM (p.12/13) program as described in this OAPM.*
Q-65 Previous mmmaments for implementabon of QA funcbons not found QAPM A.2.d.1 "The nenager responsible for qualNy in the QAPM assurance has overaR wthonty and responsibMty for establishmg, controlling, and verifying the GrandGuN: Director Quagty"provides*forimplementa60nof the implementation and adequacy of the quaRty assurance QAP (See "Organizallovf p.2 of 14 and Section 10.0,"Inspecton*, program as described in this OAPM.*
pp.1t2 of 5)
Q-66 Previous commRments for implementaGon of QA functions not found QAPM A.2.d.1 "The manager responsible for quaNty in the QAPM assurance has overaR author;ty and responsiblRty for estabirshing, controlling, and verifying the
- waterford. Director of QuaRey responsible for implementaso i of implementagon and adequccy of the quaRly assurance QAP (pp. 8-10); inspections done by QA personnel, line organiza80n program as described in this QAPM
- personnel (poer maintenance), and contract personnel); QUESTION -
A.1 rationale for deleton (p.111)'P77 Q 67 independent Review Program See Q-11 for a discussion of the committee make-ups.
i'
- QAPD, Sechon A2.e. prt# des a general statement of the purpose of the on-site and off-sNe safety revsew committees. Sechon A2.c.1.
states that the Execubve OveraR Plant Nuclear Safety,is responstle for sva ~l,v Wie schwities of the off-site safety review commettee.
Sechon A.2.d2.1. Indicates that the Manager, Plant Operabons is functionally responsible for the on-site safety review committee.
Table 1 Indicates a commitment to RG 1.33 and ANSI N18.7 with an exception to Sec80n 4.3.1 regarding the expenence applicable to the on-site review mmmittee, and the experience for the off-site Revision deled 08/25/98
, . . . _. . ~
Entergy QAPM review rnatrix Number Comment Response Closed? SutmWt?
commdtee (magonty of areas). Please explain more specdically the requrements for members of these commdtees. What will be the membership composstion of each of these commdtees? In addition, an exception is taken to Sechon 43.23 whereby members with line responsibility for operston of the plant may now constdute a malonty of the quorum for the on-site SRC (see QAPM p23). OK.
Q48 Independent Review Program ANSI N452.12 along with Clanficaton N.9 require the audit report to be issued within thirty working days after Per Secton 43.2.4 of ANSI N18.7, meeting minutes will be the last day of the audit.
disseminated prompey i
No commitment for timely submittal of audit reports (Standard is silent). 6 Q-69 independent Review Program We're w....G .g to ANSI N18.7 Sechon 4.322 as a minimum meebng frequency. Any increased frequency No commitment on PORC meceng frequency per Sec50n 43.22 of that we require wW be identfied in procedures.
ANSI N18.7 (per L4, will be in procedures).
Q-70 Independent Review Program See Q-14. Sechon 4.3.4(4) was discussing vioingons that were reportable via a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report. ,
Table 1 takes exception to Saction 4.3.4(4) of ANSI N18.7. Will onsfle j and offsite SRCs review violations also? (Violations seem to be t omitted in the clartlication)
Q.71 Independent Review Program For the number of members we are commitbng the ,
i ANSI N18.7 Section 43.2.1. The number is consistent ANO with the W3 requirements.
- i
- SRC has 8-12 members For a discussion on Qualifica60ns see Q-11.
- QualificeGons satisfy all technical areas For timeliness of meehng minutes we are committing to ANSI N18.7 Sechon 43.2.4. The specific number of i
- MeeUng minutes within 14 days days is a procedural detail not included in N18.7.
- Mee5ng once per calender month SRC meetmg frequency once per 8 months per ANO 1.3.9.1.3.1. Frequency is maintained by l
- No exception to N18.7 $43.4(4) commdment to N18.7 Section 432.2. i Q 72 Independent Review Program QA program review We are commettmg to the ANSI Standard. The speedics that you identified in the RBS commt RBS program don't appear in all of the other programs. N18.7 provides sufficient description of the
- NRB is responsible for evalushng the scope, implementabon and base requirements indudmg the requwements of N18.7 ;
effm/:.; ess of the QA program (QAD-1, REV-14C, p.18 of23, top Section 4.5=Iusin requires that audit reports be sert to swr !
Revision dated 08f25/98
e s
O e e, ,
e +
Entergy QAPM review matrix [
Number Comment Response . Closed? _ Sutwnit? ;
bullet); ANSI N18.7 (Secton 43.4(5))is cited as a .w.. 4 in he off-g' w.*2.a.p**edWm +J M* M %$.E M g*
r QAPM; but his sedian is very general. Table 1 should be more specille as to he subject metter to be addressed under this standani For the number of members we are commitEng he St MM CN hk% ^
I provision. ANSI N18.7 Sechon 432.1. The number is consistent h teab -4be, with the W3 EG.~.a gg pe
- RBS takes no excepsons to ANSI N18.7 for the offsite independent review committee in the foRowing areas [QAD-1, pp. (4), (5), & (6)l: For a discussen on QuaNlications see Q-11. MD "g* !
l
- NRB hos 9 to 13 members For timeliness of meeting minutes we are commlWng to ANSI N18.7 Sedion 4.3.2.4. The specific number of
- QuoNilcations sagsly su technical areas days is a procedural detaB not included in N18.7.
- Meeting minutes within 14 days
- - Records of NRB reviews to VP-Ops in 14 deys
- No exmptions to ANSI N18.7 54.3.4(4) [
Q-73 Independent Review Program For the number of members we are committing the ;
I ANSI N18.7 Section 4.3.2.1.
RBS We're committing to ANSI N18.7 Section 4.3.2.2 as a l
- RBS takes no exceptions to ANSI N18.7 for the onslie independent minimum meetng frequency. Any increased frequency review committee in the fotowing areas (QAD 1, pp. (1), (2), & (3)l: that we require wlE be idenulled in procedures.
- FRC hos 8 to 11 members
- Meeeng frequency is at seest once per month
- R+,An of he FRC IQAD-1, p.18(2), bottom of sheet l seem to be transferred to the onsite operating organization under ANSI i N18.7 54.4. OK based on identical composition of the FRC.
Q-74 independent Review Program For the number of members we are commilling the j ANSI N18.7 Section 4.3.2.1. The number is consistent .
I Waterford with the W3,@._.L.
i
-Waterford takes no exceptions to ANSI N18.7 for the SRC. We're committing to ANS3.1 1978 for aR persornel !
(Table 1 A.1).
-SRC has at isost Sve members
- We're committing to ANSI N18.7 Section 4.3.2.2 as a
- Quelllica8ons of members meet ANSI /ANS3.1-1978, Section 4.7 minimum meeting frequency (6 months).
- Meet atleast once per six months. For timeliness of meeting minutes we are commluing to ANSI N18.7 Section 4.32.4. The specNic number of ,
l i
Revision daled 08/25/98 !
i
e c ** .
3 e
Entergy QAPM review metrix Number Comment Response Cleoed? Sutanft?
- Moseng minutes wiedn 14 days days is a pecedural detas not included in N18.7.
- Ranimal encepsons taken to ANSI N18.7 in oWier areas. ANSI N45.2.12 along wHh ClarWicagon N.9 require to audit report to be issued wNhm 9drty wortdng days aAer
- Audit reports forwarded to spected management wuNn 30 days. the lost day of the audR.
- - PORC reviews design changes and slie nonconformance PORC review of design changes and site documents wNch have dispochioned as "use as is" or " repair" (See nonconformance documents which havem y m maned pera. 4.3.1.3, page 4). Does the ciertRcagon to ANSI N18.7 Secean as "use as is"or" repair" is one way 9mt W3 rnoots Wie 4.3.4(4)lr=*=en Wiese responeMNies for Die on-site safety review ciertlication to ANSI N18.7 Secuan 4.3.4(4).
commutes? PORC rnoots once per mones.
For PORC meeting frequency weh commREng to l ANSI N18.7 Section 4.3.2.2 as a minimum meeeng frequency. Any increased frequency thpt we require win be identsted in procedures. tt.S Q-75 A duty of the General Manager, Plant Operamons is analyzing The QAPM requires this to be perfonsiby the manager condMons br trends regarding eqimpment faRure, and pub 5shing a responalbte for conetSve acGon A.2.d.7 and A.S.e.
quarterly trend report" (See pera. 4.3.1.5 on page 4). How is this responsMity handled in to QAPM7 According to pera. 4.6.1.5 and 4.6.1.6 on p. 7, Wiese functions fab under Wie manager for corrective acgon (A.2.d.7 of the QAPM) Suggest 9ds be stated in the QAPM Q-76 How are tio responsibilities identmed in pers. 4.3.1.20 through A2.d.2 provides 9:e necessary requirement.
4.3.1.28 on p. 5 handled in Wie QAPM7
- See Q-52 Q-77 Lead Ausstor Quenaceeons
- Table 1 RG1.146, Nem 2 (ANSI N45.2.23, secton 2.3.4) should be supplemented, by Wie foGowing or words simlier to to fogowing :
"The promes for demonstraling Wie ablEty to leed an autRt team shaR be documented Iri a procedure West requres evalusGon and documentagon of Wie results of Wie dernonstramon."
Q-78 Audieng QAPM C.2.a.1 aRows the implementagon of a performance based audit program as was previously
- Item C.10 Table 1 of the QAPM takes exception to ANSI N18.7, approved for GGNS Sechon 4.5 wRh respect to frequency of sucNts. However, both the standard and Sechon C.2.a.2 seem to say that audRs of the listed activities wiE be performed at loest every two years. What is Wie reason for teldng ihe exception?
Q-79 River Bend was commined to engaging "at least annuaAy, a qualiRed Only RBS had this commement. QAPM A.3.c requires audeling organiza8on, independent of the orgeriization being reviewed "The adequacy of the QAPM's imple.iiontation is to assess REBS . " .:,, .__J acSvNies." (See QAD-1. REV-14C, assessed annuaNy by the manager (s) responsRde for page 17 of 23) The QAPM states (ftom A.3.c., p.4) that "the adequecy quoNty assurance and reported to Wie chief execuGwe Revision dated 08125196
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