AECM-86-0413, Forwards Response to 860731 Request for Addl Info on Unresolved Items Re Operation QA Manual & Revised Pages to Manual,Incorporating Changes to Items 1-7 & 9,for Concurrence

Forwards Response to 860731 Request for Addl Info on Unresolved Items Re Operation QA Manual & Revised Pages to Manual,Incorporating Changes to Items 1-7 & 9,for Concurrence

ML20215K165
Person / Time
Site:	Grand Gulf
Issue date:	09/08/1986
From:	Feith S MISSISSIPPI POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
AECM-86-0413, AECM-86-413, NUDOCS 8610280006
Download: ML20215K165 (11)

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MISSISSIPPI POWER & LIGH C MPANY

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' Helping Build Mississippi P. O. O X 16 4 0. J A C K S O N, MISSISSIPPI 39215-1640 d*.0 3 St.? b-QUALITY ASSURANIE DEPARTMENT September 8, 1986 Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N.W.

Atlanta, GA 30323 1

SUBJECT:

Granc' Gulf Nuclear Station Units 1 and 2 License No. NPF-29 Docket Nos. 50-416/417 File: 0260/0490/15020/15521/16694.4 Operation Quality Assurance Manual (MPL-TOP-1A) Revision 5 AECM-86/0413 Your letter dated July 31, 1986 (MAEC-86/0245) requested additional information to complete your review of changes in our Operational Quality Assurance Program transmitted on June 10, 1986 (AECM-86/0212).

Items 8, 10 and 11 were resolved during a telephone conversation conducted August 11, 1986, between members of your staff and members of MP&L QA. Attachment A provides your unresolved comments and the requested additional information. Attachment E provides the applicable revised pages of AECM-86/0212 which-incorporate the agreed upon changes relative to items 1, 2, 3, 4, 5, 6, 7 and 9.

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l You are requested to provide concurrencej s soon as possible to expedite l theissuanceofthiskevision. If you should have any questions, please contact the Programs QA Manager, Wenstrom E. Edge (601-969-2463).

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Yours truly, Dd p l p S. M. eith Director, Quality Assurance AKJ:1g ,

h Attachments: A. s & Resolution m i

NQAJ26AECM860413 - 1 Member Middle South Utilities System 1EO \ [g t

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cc: Mr. W. Cavanaugh, III, w/a [

Mr. T. H. Cloninger, w/a  :

Mr. O. D. Kingsley, Jr., w/a  !

Mr. L. F. Dale, w/a }

Mr. R. B. McGehee, w/a  !

Mr. H. L. Thomas, w/o (

Mr. R. C. Butcher, w/a Mr. Nichols S. Reynolds, Esq., w/a  !

Mr. James M. Taylor, Director, w/a Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission j

.W ashington, D. C. 20555 l Document Control Desk U. S. Nuclear Regulatory Commission ,

Washington, D. C. 20555  ;

Mr. George A. Belisle, w/a U. S.-Nuclear Regulatory Commission j Region II f 101 Marietta Street, N.W.  !

Atlanta, GA 30323 l

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rm d Attachmsn v to AECM-86/0413

1) NRC Comment:

i Paragraph 1.3.11(a), Attachment A, states that the new position of [

Manager, Contract Administration was addressed in letter AECM-85/0639. ~

This position is not described in Section 4.4.7 of Attachment B. Please provide information regarding the functional responsibilities of the .  :

Manager, Contract Administration, and the interface requirements with '

Manager, Purchasing and Stores. The Topical Report Section 1.3.11 refers to "they are responsible, etc." Attachment A refers to "he is  !

responsible, etc." Provide additional clarification of this issue. ,

Resolution: l t

The Manager, Contract Administration has been included in Section 4.4.7. [

See revised 4.4.7 (Attachment B).  !

2) NRC Comment: i Paragraph 1.3.14, Attachment B, deleted the Manager, Internal Auditing f position and his responsibility. Paragraph 18.4.3, Attachment B, j contradicts the justification or change stated in Attachment A. Clarify i if the subject audits were intended to meet requirements for Management {

Audits of the QA Program. Also, state present arrangements for  ;

conducting the annual management audits of the QA Program, where it is i described, and how it is administered.  !

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Resolution:

MSS and JUMA perform annual audits of the Operational Quality Assurance- ,

l Program. See revised justification (Attachment B). [

) 3) NRC Comment:

Paragraph 4.4.7, Attachment A, comments similar to that contained in Item No. 1.  ;

Resolution:

The Manager, Contract Administration has been included in Section 4.4.7.  !

See revised 4.4.7 (Attachment B).  !

4) NRC Comment:

t Paragraph 9.4.3(b), Attachment B, the first sentence excludes the l performance of nondestructive examination (NDE) from responsibilities  !

assigned to the Manager, Nuclear Site QA. However, paragraph 1.3.4 of  !

Attachment B states that he directs plant site QA staff in NDE  !

activities. Provide additional clarification of this issue.

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Resolution: l MSS or JUMA will perform annual audits of NDE activities. See revised justification (Attachment B) . j l

I J26AECM-86/0413A - 1

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• s- Attachmsd -_/to AECM-86/0413

5) NRC Comment:

4 Paragraph 14.4.3, Attachment B, previously stated that the Manager . . .

l by inspection. Deletion of this statement is inconsistent with Paragraph 10.4.2. Justify this deletion.

t Resolution:

This item was moved to paragraph 14.1.1. The words " test, and operating" were added to 14.4.1 for clarity. See revised paragraph i 14.4.1 (Attachment B).

6) NRC Comment:

! Paragraph 15.5.5, Attachment B, the words must be considered nonconforming have been deleted. Justify deleting the requirement for considering such items as nonconformances.

Resolution:

Paragraph 15.5.5 has been revised for clarity. See revised paragraph 15.5.5 (Attachment B).

7) NRC Comment:

Paragraph 18.4.4, Attachment B, comments similar to item 2.

Resolution:

See item 2 above.

8) No additional response required

9) NRC Comment:

Appendix B, item A, Operational Quality Assurance Manual, the approval column shows approval by Vice President, Nuclear Engineering and Support, and Vice President, Nuclear Operations. Page 1 of 1, Forward, requires approval by Vice President, Nuclear Operations, as shown by his signature. Justify omission of the Vice President, Nuclear Engineering and Support, signing the Operational Quality Assurance Manual.

Resolution:

Both Vice Presidents will approve / sign the official issuance of the OqAM.

10) To additional response required

11) No additional response required J26AECM-86/0413A - 2

\ Support Staff and Nuclear Licensing and Sef s,3,taff respectively, are procedurally controlled in accordance with the requirements of this Policy. This includes preparation, review, approval and issuance of procurement documents.

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4.4.5 Organizations supplying material, equipment or services are responsible for complying with the applicable requirements _of this Policy, as specified in the appropriate procurement-documents and for imposing them on their contractors and suppliers, as applicable. They are also responsible for I verifying, through surveillance or audits, that the requirements are being adequately implemented.

4.4.6 The Director, Quality Assurance is responsible for assuring l i

implementation of procurement document control measures and for  !

quality review of procurement documents and procedures. He is f

also responsible for carrying out an audit program, as described in Policy 18.0 of this Manual, to verify conformance with Operational Quality Assurance Program requirements, including the requirements of this Policy.

4.4.7 The Manager, Purchasing & Stores and the Manager, Contract j Administration are is responsible for performing procurement activities, in accordance uith the Operational Quality Assurance l Progran, as coordinated with the Director, Nuclear Support; the l Director, Nuclear Licensing and Safety; the Director, Nuclear f Plant Engineering end-Genservettent the GGNS OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 5 9/8/86  !

TITLE: PROCUREMENT DOCUMENT CONTROL [

Page 3 of 8 Policy 4 J0P250QAM.4 - 3

, 14.4 RESPONSIBILITY ,

r 14.4.1 Excepe-fee-preeperettenet-eeeeing-where-ehese-eeetviefes i t

ere-the-eesponsibility-ef-the-Menageer-Unte-2-Gensecueetent During the opemtional phase, responsibility and authority [

for identifying and controlling the inspeettent test and i

operating status of safety-related items ductag-ehe-eperettenal pheee,' excluding preopemtional testing, are delegated to the GGNS General Manager. The responsibility and authority }

for identifying and controlling the test and opemting ,

status of safety-related items involved in preopemtional phase testing programs are delegated to the Unit 2 Con- j struction Superintendent. The Director, Quality Assurance has the responsibility and authority for identifying and j controlling the inspection, test, and operating status of i i

safety-related items. He-teThey are responsible for assuring (

that procedures are developed and implemented to address [

the applicable requirements of this Policy.

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14.4.2 Organizations supplying safety-related material, equipment and services are responsible for complying with the appli-  !

t cable requirements of this Policy, as stipulated in the procurement documents, and for imposing them on their con-6 i

OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 5 9/8/86 i TITLE: INSPECTION, TEST AND OPERATING STATUS l Page 2 of 6 Policy 14

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15.5.5 Nonconforming items, services or cctivities chzll be rzview:d and dispositioned in accordance with documented procedures.

Items may be dispositioned in the following ways:

15.5.5.1 Accept-as-is; 15.5.5.2 Scrap; 15.5.5.3 Rework to conform to a drawing or specification; f

15.5.5.4 Repair in accordance with an engineering approved procedure.

Items received without the necessary documentationy-muse-be eensidered-neneenfermingr shall be controlled. Acceptance of such iteme vill be uithheld perding receipt of required documentation or the items vill be considered nonconforming.

15.5.6 The acceptability of rework shall be verified by reinspecting or retesting the item to the original requirements, or by an equivalent method which has been reviewed and approved.

The acceptability of repair shall be verified by reinspection, or retesting the item by an engineering approved method even though the item still may not conform to the original requirements. Inspection, testing, rework and repair shall be documented.

OPERATIONAL QUALITY ASSURANCE MANUAL Rev. 5 9/8/86 TITLE: NONCONFORMING MATERIALS, PARTS OR COMPONENTS Page 5 of 6 Policy 15 J0P250QAM.15 - 5

Page 5 of 41 DESCRIPTION OF PROPOSED CHANGES AND THEIR DISPOSITION ITEM ACTION REQUESTED BY JUSTIFICATION

9. Section 1.3.8 d) Third sentence: " Manager, Quality Assurance Letter to USNRC (Cont'd) Nuclear Plant Engineering" (S. M. Feith) AECM-85/0639 changed to " Director, Nuclear Dated November 15, 1985-Plant Engineering."

10. Section 1.3.11 a) First sentence: "Vice Quality Assurance Letter to USNRC President, Personnel & (S. M. Feith) AECM-85/0639 Administration" changed Dated November 15, 1985 to "Sr. Vice President, Personnel & Administration."

b) Second sentence to read: Quality Assurance Letter to USNRC "He is responsible for (S. M. Feith) AECM-85/0639 performing procurement Dated November 15, 1985.

activities in accordance Added reference to OQAP with the Operational Quality for clarification and Assurance Program, as added coordination with coordinated with the Site Manager, Unit 1 Projects Director GGNS; GGNS General to reflect responsibility.

Manager; Manager, Unit 1 Proj ects; the Director, Nuclear Licensing and Safety;.the Director, Nuclear Plant Engineering; the Director, Quality Assurance and the Director, Nuclear Support."

11. Section 1.3.14 Entire Section Deleted Quality Assurance Audits by Internal Auditing (S. M. Feith) are for Financial and with concurrence Management Policy considerati from Internal No Quality Assurance Program Auditing matters are involved.

(T. Y. Gunter) MSS and JUMA each perform at.dits of the Operational Quality Ascurance Program annually.

J25JL PROPOSED CHANGES - 5

Page 23 of 41 DESCRIPTION OF PROPOSED CHANGES AND THEIR DISPOSITION ITEM ACTION REQUESTED BY JUSTIFICATION

51. Section 9.4.3 b) In first sentence after Quality Assurance To clarify responsibility (Cont'd) "special process activities" (R. A. Courtney) of Director, Quality add ", excluding nondestruc- Assurance. MSS and/or tive examinations". JUNA perform audits of.

QA NDE activities annually, therefore QA vill not inspect NDE activitics performed by QA.

52. Section 9.4.5 Add new section 9.4.5 to read: Quality Assurance To incorporate respon-

"The Director, Nuclear Plant (R. A. Courtney) sibilities of Director, Engineering has the responsibility Nuclear Plant Engineering for assuring that special process standards and specifications are established to address the appli-cable requirements of this Policy.

He is also responsible for reviewing and approving all contractor special process standards prior to use at the Plant Site."

53. Section 10.4.1 a) Add second sentence to read: Plant Modification To incorporate respon-

"During the implementation Construction sibilities of the and testinF of design (D. W. Stonestreet) Manager, Unit 1 Projects changes and plant modifica- and Director, Quality tions, the Manager, Unit 1 Assurance Projects, in conjunction with the Directer, Quality Assur- Quality Assurance Letter to USNRC ance, is responsible for (S. M. Feith) AECM-85/0639 these activities." Dated November 15, 1985 b) Fourth sentence after "GGNS Plant Modification To incorporate responsi-General Manager" add "and & Construction bilities of the Manager, the Manager, Unit 1 Projects (D. W. Stonestreet) Unit 1 Projects (for implementation and testing of design changes Quality Assurance Letter to USNRC and plant nodifications)" ... (S. M. Feith) AECM-85/0639 Dated November 15, 1985 c) Third sentence change "is" Plant Modification Grammatical change to "are". & Construction (D. W. Stonestreet)

J25JL PROPOSED CHANGES - 23

Pag 2 30 of 41 DESCRIPTION OF PROPOSED CHANGES AND THEIR DISPOSITION ITEM ACTION REQUESTED BY JUSTIFICATION

68. Section 16.4.5 analysis of NRC and MP&L Quality '

(Cont'd) Assurance nonconformance documents to detect possible adverse quality trends; for reporting such items, if any, to the Vice President, Nuclear Engineering and Support and the Vice President, Nuclear Operations for further action".

69. Section 17.4.2 a) First sentence delete Plant Modification To incorporate respon-

"Startup Staff" & Construction sibilities of Manager, and add " Plant (D. W. Stonestreet) Unit 1 Projects Modification and Construction Section". Quality Assurance Letter to USNRC (S. M. Feith) AECM-85/0639 Dated November 15, 1985 b) Third sentence delete "the Quality Assurance Letter to USNRC Startup Manual" and add "the (S. M. Feith) AECM-85/0639 Plant Modification and Con- Dated November 15, 1985 struction Section Procedures".

70. Section 17.4.3 First sentence delete ", by Quality Assurance To provide a more inspection,". (S. M. Feith) accurate description of responsibility

71. Section 18.4.3 Delete " Operational". Quality Assurance Typographical error (S. M. Feith) from Rev. 4

72. Section 18.4.4 Entire section deleted Quality Assurance The subject management (S. M. Feith) with audits are not required concurrence from by 10CFR50, App. B.

Internal Auditing The required audits are (T. Y. Gunter) jarformed by outside organizations. (NSS or JUMA)

J25JL PROPOSED CHANGES - 30