ML20216D650
| ML20216D650 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/10/1998 |
| From: | Dennis Morey SOUTHERN NUCLEAR OPERATING CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9803170175 | |
| Download: ML20216D650 (13) | |
Text
'.O Dave Morey Southern Nuclear Vice President Operating Company Tadey Project P.O. Box 1295 Birmingham. Alabama 35201 Tel 205 992.5131 March 10, 1998 SOUTHERN h COMPANY Energy to ServeYourWorld" Docket Nos.:
50-348 10 CFR 50.54(a)(3) 50-364 U. S. Nuclear Regulatory Commission ATTN: Dxument Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant Final Safety Analysis Report Quality Assurance Program Changes Resubmittal of Certification of Nondestructive Testina Perjonn_d Ladies and Gentlemen:
Pursuant to 10CFR50.54(a)(3), attached is a change to the Farley Nuclear Plant (FNP) Final Safety Analysis Repon (FSAR) Quality Assurance (QA) Program Description for your review and approval. The FNP FS AR QA Program description is located in Section 17.2 of the FNP FSAR.
His change is resubmitted to address changes from both the 1975 and 1980 versions of American Society for Nondestructive 7esting Recommended Practice No. SNT-TC-1 A " Personnel Qualification and Certification in Nonder tructive Testing" A previous submittal was made that addressed changes from the 1980 to the 1984 version. As requested by the NRC staff, a description of the history of the changes from the 1975 to the 1980 version is included in Attachment 3.
The FSAR QA program description is being revised to remove the reference to American Society for j
Nondestructive Testing Recommended Practice No. SNT-TC-1 A for qualification and certification of personnel performing nondestructive testing at FNP. Details of compliance with SNT-TC-1 A are i
proposed to be relocated to another section of the FSAR (Section 3 A) that describes specific compliance with NRC Regulatory Guides. Later editions of SNT-TC-1 A are approved by the NRC, i
for ASME code activities, through updates to the regulations associated with new ASME Boiler and Pressure Vessel Codes in 10CFR50.55a. SNC requests approval to use the edition of SNT-TC-1 A as specified by Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as i
required by 10 CFR 50.55a, except where specific written relief has been granted by the NRC. He current (1984) edition of SNT-TC-I A allows increased flexibility in recertification ofinspection g
personnel, and numerous requirements are changed from the verb "shall"to "should" from the 1975 version. SNC proposes to retain the usage of"shall" as specified. Therefore, this change is I
considered a small reduction in the QA program commitments. SNC has evaluated the impact of this change and has concluded that the 1984 version of the standard, with the exceptions specified in the proposed QA program change, meets the requirements of 10CFR50 Appendix B and satisfies the intent of SNC's commitments to the NRC cc:iccrning cualification and certification of NDE personnel.
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U. S. Nuclear Regulatory Commission Page 2 If there are any questions, please advise.
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Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY g
)M Dave Morey I
EWC:maf QARESUBM. doc Attachrnents: 1) 10CFR50.54(a)(3) Evaluation and
- 2) Marked-Up FSAR pages
- 3) History of Change to 1980 version of SNT-TC-1 A cc:
Mr. L. A. Reyes, Region II Administrator Mr. L 1. Zimmerman, NRR Project Manager
' Mr. T. M. Ross, Plant Sr. Resident Inspector l
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ATTACHMENT I Final Safety Analysis Report Quality Assurance Program Changes 10CFR50.54(a)(3) Evaluation
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4 A'ITACHMENT I Final Safety Analysis Report Quality Assurance Prograrn Changes 10CFR50.54(aX3) Evaluation Affected Pages See attached FSAR pages 17.212,17.2-13,3A-1.58-1 and 3A-1.58-1a Descnption of the Changes
'Ihe FSAR QA program description is being revised to remove the reference to American Socacty for Nondestructive Testing Reconwi.caded Practice No. SNT-TC-1 A' August 1980 Edition for qualification and cenification of personnel perfornung *ructive testing at FNP. Details of compliance with SNT-TC-1 A are proposed to be relocated to -
another section of the FSAR (Section 3A) which describes specific compliance with NRC Regulatory Guides. SNC desires approval to use the edition of SNT-TC-1 A as specified by Section XI of the ASME Boiler and Pre,sure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where specific written relief has been granted by the NRC. Since the 1984 version allows increased flexibility in recenification of personnel, this change is considered a small reduction in the QA program commitments. In addition, this change will allow changes to the NDE certification requirements as specified by the Section XI code to be applied to non code activities without future NRC approval.
Reason for the Channes In the current FSAR QA program description, SNC is committed to the revision of SNT-1 TC-1 A issued in June 1980. The 1984 version allows increased flexibility in the recenification of NDE personneli This change will also facilitate the procurement of -
vendor NDE personnel who are cenified to SNT-TC-I A 1984 under their own QA programs. This version is specified for use by the current version of the ASME code.
Since the 1984 version, with specified exceptions, allows increased flexibility in -
i recenification ofpersonnel, this change is considered a small reduction in the QA program commitments. Later editions of SNT-TC-1 A for ASME code activities are approved by the NRC through updates to the regulations associated with new ASME Boiler and Pressure Vessel Codes in 10CFR50.55a. Therefore, removing the reference to SNT-TC-1 A from the FNP FSAR QA program description will eliminate the need for redundant NRC approval due to potential " reductions in commitments" which may be entailed when incorporating a new edition of SNT-TC-1 A. This will permit the inspector cenification program to be uniformly applied at FNP.
Basis for the Acccotability of the Channes SNC has reviewed SNT-TC-1 A 1984 and has concluded that it fully satisfies the intent of 10CFR50 Appendix B Criterion 11, Quality Assurance Program, and Criterion IX, Control of Special Processes.
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F Final Safety Analysis Report Quality Assurance Program Changes 10CFR50.54(a)(3) Evaluation SNC has compared SNT-TC-I A 1984 with SIff-TC-1 A 1980 and 1975 and has concluded that the 1984 version of the practice, with the exceptions (shalls vice shoulds) specified by the prcposed FSAR change meets the requirements of 10CFR50 Appendix B and satisfies the intent of SNC's commitments to the NRC concerning qualification and certification ofNDE personnel.
The NRC, via Regulatory Guide 1.147, has endorsed ASME Code Cases N-356 and N-445 which directly address the change from SNT-TC-1 A 1980 to SNT-TC-1A 1984.
The NRC has also endorsed the 1989 ASME Code in 10CFR50.55a which invokes SNT-TC-1 A 1984 for qualification and certification of NDE personnel.
Moving the detail of compliance with SNT-TC-I A to section 3A of the FSAR is acceptable since changes to this section will still be controlled by 10CFR50.59 and NRC approval of the version of SNT-TC-1 A utilized will remain via ASME code requirements.
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s ATTACHMENT 2 FSAR Mark-Up Pages l
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i FNP-FSAR-17 The OQAPIL lists SAER procedures, FNP administrative procedures, and nuclear support administrative procedures which have been written to comply with the applicable criteria of 10 CFR 50, Appendix B.
The OQAP shall provide for indoctrination and training of l
personnel performing safety-related activities to ensure that the individual attains quality in job performance and complies with APC quality policies and procedures.
Basically, this l
quality indoctrination and training is provided in two phases:
OQA orientaticn training, and qualification and training for specific tasks.
The FNP OQA orientation training program was developed with assistance from SAER.
Training in the OQAPM may be presented by videotaped lectures.
This manual dascribes the safety-
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related and nonsafety-related activities, duties, and authorities of each group assigned OQA responsibility in the OQAP.
These presentations will encompass various types of safety-related operational activities, such as the QA filing system, receipt inspection, control of documents, inspection after maintenance, and approval of design changes.
There will be a list of required attendees for each lecture as determined by the GMNS, GMNP, and MSAER.
Records of the orientation will be developed and retained as quality records.
This program will be repeated to serve as an annual refresher for those who previously passed the course and to provide indoctrination and training for new employees.
Each group involved in the OQAP is responsible for qualifying and requalifying its personnel, as required, to ensure that the required level of competency is maintained.
This qualification includes proper selection of candidates for i
available positions and successful completion of training that will provide the required knowledge for performing assigned duties.
This training may be provided by preplanned lectures and/or on-the-job training.
Subsection 13.1.3 and section 13.2 discuss the qualifications maintained by and the training program required for plant staff.
All plant staff who are assigned the responsibility and authority to approve inspection and test procedures, implement these i
procedures, e.nd evaluate and report the results of the tests and inspections shall be certified as to their levels of capability in compliance with the requirements of Regulatory Guide 1.58, Revision 1, dated September 1980, which references ANSI N45.2.6-1978.
Persons - per-forming-nondest-ruet-i-ve-exam 4-nat lons l
17.2-12
n FNP-FSAR-17 idDS )-shal 1-mee t-the-requ iremen te-in-SNT-TG-1 A-fi-980-)-end applicable supplements.
The nuclear plant general manager shall determine the acceptance of experience qualifications, based on the guidelines presented in ANSI N45.2.6-1978, for capability levels in areas of testing and inspection other than NDE.
Any test and inspection work performed by contractors for the plant staff shall also be performed by personnel who meet the qualifications required in Regulatory Guide 1.58, Revision 1, dated September 1980.
The group responsible for performing the test or inspection, whether it is the plant staff or contractors, shall specify detailed methods or procedures for these activities unless stated in contract documents.
Appropriate training and certification records will be maintained by the nuclear plant general manager for each person designated to perform inspection and testing functions.
Personnel performance evaluations will be maintained at the General Office and will not be a part of the certification records.
SAER is responsible for training its personnel to meet the requirements of the OQAP.
An SAER administrative procedure, listed in the OOAPIL, details educational and training requirements for each SAER staff member.
APC PGS Department, SCS, and SNC are responsible for the training of personnel within their organization that is required to assure that the individual attains quality in job performance and complies with the requirements of the OQAP and approved codes, specifications, and instructions for activities within the scope of the OQAP.
The vice president is responsible for approving the OQAPM and any changes thereto.
The MSAER has the responsibility for making suggestions concerning the OQAP and the OQAPM to the vice president for his evaluation.
The vice president is responsible for regularly reviewing the status and effectiveness of the FNP OQAP.
He accomplishes this by reports from the MSAER, Corporate Headquarters Farley Project, the Plant Farley site organization, and the NORB.
17.2.3 DESIGN CONTROL Measures are established to assure that for design changes and/or modifications for the operating nuclear plant, applicable regulatory requirements, quality standards, and design bases are properly translated into specifications, drawings, procedures, and instructions.
17.2.3.1 Quality Assurance (Other Than Nuclear Fuel Suppliers)
Design changes and/or modifications during plant operations will be Sandled in a manner which will comply with the requirements of ANSI N45.2.11-1974 and thereby maintain 17.2-13
FNP-FSAR-3A Regulatory Guide 1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, EXAMINATION, AND TESTING PERSONNEL (Rev. 1, 9/80)
CONFORMANCE Personnel involved with examination of items on the site are qualified and certified in accordance "ith the requirements of ANSI N45.2.6-1978.
Personnel perfo ming inspection and testing were qualified for those specific tasks on the basis of experience and specific training (education or on-the-job-training or a combination of both). Compliance was verified by periodic audits by quality assurance personnel.
However, two exceptions have been taken to Regulatory Guide 1.58, Revision 1, and ANSI N45.2.6-1978.
A description and justification of these exceptions is presented below.
Regulatory Position C.2 of Regulatory Guide 1.5.8, Revision 1, endorses the 1975 edition of SNT-TC-1A as acceptable guidance for qualifications of nondestructive examination (NDE) personnel. However, the FNP ISI Program-has been updated-to-the-ASME-Gedersection-Xh-19-83-Edition-through summer-1983 Addenda, which specifico the 1980 Edition of SNT-TG-1At-therefere -FNP-le-committed--to-the-nondestruebi-ve r
test method listed in SNT-TC-1A-198G-with NDE qualification p r oced ures-for-th e se-method s-ba s ed-upon-th e-recomm enda blon e of SNT-TC-1A 1980.
Present-commi t-ment and requirement: f-or NDE-remain-unchanged-for-the-time-being.
They-are approprictcly rev.ced cc part of the code edition--update j
proce s s -required-by-10-GFR-Sh65a fg]-to-be-conducted-a t-the end of cach FNP 120 month incervice inspection intcival.
In lieu of this, the version of SNT-TC-1A or other similar document used for qualifying personnel at to perform nondestructive inspection, examination, or testing shall be in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50.55a, except where specific written relief has been granted by the NRC.
The document used for the qualification of such personnel shall be specifically identified in the Inservice Inspection Program for FNP.
In addition, FNP shall supplement these requirements by replacing the "shoulds" contained in SNT-TC-1A with "shalls" where they occurred in the 1975 version.
i Subsection 2.3 of ANSI N45.2.6-1978 requires that the job
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performance of inspection, examination, and testing personnel be reevaluated at least every 3 years and that any person who has not performed inspection, examination, and testing activities in his qualified area for a period of 1 year shall undergo requalification in accordance with subsection 2.2.
Inspection, examination, and testing activities are inherently integrated into the FNP staff's routine job responsibilities such that when a person holds a given position, he routinely performs those inspection, examination, and testing activities for which that position is responsible.
Therefore, an annual demonstration of
proficiency has no meaning under the FNP Quality Control Program.
Moreover, the requalification per ANSI N45.2.6-1978, paragraph 2.2, is based on the individual's education and experience.
Since each person's initial certification 3A-1.58-1 REV.
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FNP-FSAR-3A was also based on that individual's accumulated education and experience, and aince an individual's accumulated l
education and experience.cannot be revoked, there is no
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purpose in performing the requalification exercise simply because an individual did not perform or document an annual demonstration of proficiency in the inspection, examination, and testing activities for which he is certified (assuming, of course, that the individual's job performance of inspection, examination, and testing activities remained satisfactory).
For these reasons an annual demonstration of proficiency in inspection, examination, and testing activities is fruitless and exception is taken to this aspect of ANSI N45.2.6-1978.
The present practice, which is expected to be continued, of conducting job performance evaluations as a basis for recertification for inspection, examination, and testing personnel on a 2-year cycle satisfies the ANSI N45.2.6-1978 requirement that these evaluations be conducted at periodic intervals not to exceed 3 years.
On September 9, 1996 the NRC amended its regulations to incorporate by reference the 1992 edition with the 1992 addenda of Subsections IWE and IWL of Section XI, Division 1, of the ASME Boiler and Pressure Vessel Code with specified limitations in 10 CFR 50.55a.
The new rules require certain containment liner and concrete inspections / examinations to be performed prior to September 9,
2001 and to be repeated on a regular basis thereafter.
Containment repair and replacement requirements of the new rules including preservice examinations after repair or replacement were effective on September 9, 1996.
Relief from this effective date until March 15, 1997 was requested by FNP.
The 1992 edition with 1992 addenda of Section XI requires personnel performing NDE examinations to be qualified and certified using a written practice prepared in accordance with ANSI /ASNT CP-189.
However, current certification based on SNT-TC-1A remains valid until recertification is required.
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3A-1.58-la REV.
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a ATTACHMENT 3 1
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History of Changes to SNT-TC-1A at FNP i
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r History of Conmitment Changes frosa SNT-TC-1A 1975 Version to the 1980 Version at FNP As the result of a request by NRC staff, FNP is providing the following description of the changes associated with SNT-TC-1A-1975 to the 1980 version at FNP.
Prior to the second ten year ISI interval FNP was committed to the requirements of SNT-TC-1A-1975 for NDE personnel qualification. This was specified by position C.2.of' Regulatory Guide 1.5.8, Revision 1 which endorsed the '975 edition of SNT-TC-1A and was referenced by the FNP QA program in F&VL section 17.2.
After the second ISI program interval was submitted, FNP changed the QA program to designate compliance with SNT-TC-1A-1980 as specified by Section XI ASME Boiler.and Vessel Code-1983.
Section 17.2 of_the FSAR was changed along with section 3A to reflect the change in revision. This was not deemed to be a change in QA commitment since the ASME Boiler and Vessel Code-1983 specified compliance with the 1980 version of the practice for NDE qualification of personnel. The FNP position is that NRC endorsement, through SER approval, of the ASME code for ENP has the ef fect of approval of the documents referenced by the code u.:.ess otherwise specified.
Non Section XI work was not considered at the time.
In December 1997, FNP submitted a request for a reduction in commitment to change the applied version of SNT-TC-1A to 1984. This was viewed as a reduction due to changes that allowed NDE inspection personnel to be recertified on a five year basis versus a three year basis. During review of this request NRC staff concluded that the prior ENP change from the 1975 to the 1980 version of SNT-TC-1A was a reduction in commitment even though the change was specified by the ASME code change since the commitment change potentially impacted code as well as non code inspections.
It should be noted that the major differences between the 1975 and 1980 procedures is the substitution, in numerous places, of the I
word "should" for "shall" in the later version.
A review of this change has concluded that the impact on both code and non code inspector qualifications was insignificant since the FNP implementing procedures were not changed'to reflect the reduced commitments.
It is also the FNP staff position that requirements deemed appropriate for code inspector qualifications are adequate for non code activitiv.s.