ML16259A280

Forwards Request for Addl Info Re Licensee Concerning Changes to Plant Topical Rept, QA Program

ML16259A280
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	02/19/1992
From:	Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Tucker H DUKE POWER CO.
References
NUDOCS 9203030037
Download: ML16259A280 (10)

Text

February 19, 1992 Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414 License Nos. DPR-38, DPR-47, DPR-55, NPF-9, NPF-17, NPF-35, and NPF-52 Mr. H. B. Tucker, Senior Vice President Nuclear Generation Duke Power Company P. 0. Box 1007 Charlotte, North Carolina 28201-1007

SUBJECT:

REVISIONS TO DUKE POWER COMPANY'S QUALITY ASSURANCE (QA) PROGRAM The changes for the Duke Power Company Topical Report (Duke-i-A), "Quality Assurance Program",

which were submitted in your letter dated November 27, 1991, are currently under review.

In order to complete our review, please provide a response to the enclosed questions.

We appreciate your cooperation with us. If you have any questions concerning this request, please contact F. Jape of my staff on (404) 331-4182.

Sincerely, Original signed by Caudle A. Julian Caudle A. Julian, Chief Engineering Branch Division of Reactor Safety

Enclosure:

Questions to Proposed QA Program Changes cc w/encl:

A. V. Carr, Esq.

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 J. Michael McGarry, III, Esq.

Bishop, Cook, Purcell and Reynolds 1400 L Street, NW Washington, D. C. 20005 (cc w/encl cont'd -

See page 2) 9203030037 920219 PDR ADOCK 05000269 R

PDR

Mr. H. B. Tucker, Senior Vice 2

February 19, 1992 President (cc w/encl cont'd)

North Carolina MPA-1 Suite 600 P. 0. Box 29513 Raleigh, NC 27626-0513 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Richard P. Wilson, Esq.

Assistant Attorney General S. C. Attorney General's Office P. 0. Box 11549 Columbia, SC 29211 Michael Hirsch Federal Emergency Management Agency 500 C Street, SW, Room 840 Washington, D. C. 20472 North Carolina Electric Membership Corporation P. 0. Box 27306 Raleigh, NC 27611 Karen E. Long Assistant Attorney General N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602 Saluda River Electric Cooperative, Inc.

P. 0. Box 929 Laurens, SC 29360 Frank Modrak, Project Manager Mid-South Area ESSD Projects Westinghouse Electric Corporation MNC West Tower -

Bay 241 P. 0. Box 355 Pittsburgh, PA 15230 County Manager of York County York County Courthouse York, SC 29745 (cc.w/encl cont'd -

See page 3),

Mr. H. B. Tucker, Senior Vice 3

February 19, 1992 President (cc w/encl cont'd)

Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 R. L. Gill Nuclear Production Department Duke Power Company P. 0. Box 1007 Charlotte, NC 28201-1007 R. C. Futrell Compliance Duke Power Company P. 0. Box 256 Clover, SC 29710 County Supervisor of Oconee County Walhalla, SC 29621 Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division Suite 525, 1700 Rockville Pike Rockville, MD 20852 Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035 M. E. Patrick Compliance Duke Power Company P. 0. Box 1439 Seneca, SC 29679 J. Michael McGarry, III, Esq.

Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 (cc w/encl cont'd -

See page 4)

Mr. H. B. Tucker, Senior Vice 4

February 19, 1992 President (cc w/encl cont'd)

County Manager of Mecklenburg County 720 East Fourth Street Charlotte, NC 28202 Frank Modrak, Project Manager Mid-South Area, ESSD Project Westinghouse Electric Corporation MNC West Tower -

Bay 241 P. 0. Box 355 Pittsburgh, PA 15230 Dr. John M. Barry, Director Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, NC 28202 R. 0. Sharpe Compliance Duke Power Company 12700 Hagers Ferry Road Huntersville, NC 28078-8985 David Jenkins QA Technical Services P. 0. Box 1007 Charlotte, North Carolina D. L. Rehn, General Manager Nuclear Services P. 0. Box 1007 Charlotte, NC 28201-1007 W. M. Sample, Manager Safety Assurance P. 0. Box 1007 Charlotte, NC 28201-1007 bcc w/encl:

R. E. Martin, NRR J. Johnson, RH W. Miller, RII G. A. Belisle, RII A. R. Herdt, RII L. Wiens, NRR J. Spraul, NRR T. Reed, NRR S. Ninh, RH Document Control Desk (bcc w/encl cont'd -

see page 5)

Mr. H. B. Tucker, Senior Vice 5

February 19, 1992 President (bcc w/encl cont'd)

NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678 T. Reed, NRR J. Johnson, RII S. Ninh, RII J. Spraul, NRR NRC Resident Inspector U.S. Nuclear Regulatory Commission, 12700 Hagers Ferry Rd.

Huntersville, NC 28078-8985 RII:DRS RII:DRS R :DR RII MThomas:ser FJ CJ

'an Aendt 02//8/92 0 2//,Y/

9 2 2/

2 02/ /92

Mr. H. B. Tucker, Senior Vice, 5

February 19, 1992 President (bcc w/encl cont'd)

NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 179-N York, SC 29745 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678 NRC Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Rd.

Huntersville. NC 28078-8985

(*See previous page for concurrences)

RII:DRS RII:DRS RI:DRS RI:DRS MThomas:ser FJape CJulian AHerdt 02, 792 02/

/92 02/

/92 02/

/92

REQUEST FOR ADDITIONAL INFORMATION DUKE POWER COMPANY QUALITY ASSURANCE TOPICAL REPORT Amendment 15

1. Reference the Regulatory Guides found in NUREG-0800 in the text rather than in a footnote. Either eliminate or.

relegate to a footnote the reference to the "Rainbow Books."

The commitments to the quality assurance (QA) guides and standards have not been updated per Section 17.3 of NUREG 0800. For example, the topical report does not address the substitution of NQA-1 and NQA-2 for N-45.2 and its daughter standards. This should be clarified in the abstract of the topical report where it states that Section 17.3 of the topical report "follows the format" of Section 17.3 of NUREG-0800.

(A.7.b)l

2. The alternative to Regulatory Guide 1.58 in Table 17.0-1,.

states that Duke may certify inspectors as Level II after only four months experience as a Level I. Clarify that inspectors are only assigned tasks for which they are qualified.

(A.5.a)

3. In the clarification to Regulatory Guide 1.64 in Table 17.0 1, clarify that a supervisor will not provide the "independent design review" of the supervisor's input to (or work on) the design or justify not providing such a commitment. (A.7.b)

4. The alternative to Regulatory Guide 1.144 precludes the auditing organization from making recommendations for correcting program deficiencies and precludes reports of external audits from being given to the audited organization. Provide justification for these exceptions or delete them.

(A.7.b)

5. The first paragraph of Section 17.3.1.1 indicates that the Executive Vice President, Power Generation Group is responsible for establishing Duke's QA.policies. Briefly describe -the Duke quality (or QA) policy in the topical report. Also clarify that procedures and activities reflect the policy.

(A.l.a and A.3.f)

6. Section 17.0 indicates that the topical report describes the QA program for safety-related items and activities and that it provides a method of applying a graded QA program to some Alpha-numerics in parentheses refer to the acceptance criteria in Section 17.3 of the Standard Review Plan (NUREG-0800).

nonsafety-related items and activities. The nonsafety related items (listed as QA Condition 2, 3, and 4:

radioactive waste, fire protection, and Seismic Category II items) should also include items such as nonmetallic insulation for austenitic stainless steel (per RG 1.36) and protective coatings (per RG 1.54).

Clarify the scope of Duke's graded QA program. Provide a commitment to ensure the quality of items to an extent consistent with their complexity and importance to safety. Also in this regard, consider replacing "nuclear safety-related" and similar limiting terms in the topical report with "QA Condition" or some other term that better describes the scope of the Duke QA program.

(A.1.c, A.1.d, and B.1.c)

7. Describe (in Section 17.3.1.2.2b) the activities/

responsibilities of the Nuclear Services organization.

(A.2.a)

8. Identify the organizational entities that are on site and those that are off site. Also, include (in Section 17.3.1.2/Figure 17.3-1) the activities/responsibilities, location, and reporting relationships of the organizational entities first identified after Section 17.3.1.2. Examples include the Verification Manager, Suppliers; the Site Safety Assurance Manager; the Commodities & Facilities Management Group; the Regulatory Compliance Group; the Environmental Compliance Group; and the Emergency Preparedness Group.

(A.2 a)

9. Inspections and tests are verification activities, and Acceptance Criterion A.2.b of the SRP states there is to be independence between performing personnel and verification personnel. The criterion goes on to state that the degree of independence may be commensurate with the inspection or test's relative importance to safety. Since on site inspections and tests are not the responsibility of the Quality Verification Department, clarify Duke's position regarding the "independence" of on site inspectors and testers.

(A.2.b)

10.

Clarify whether management positions under the Manager, Quality Verification, have been established at the Duke nuclear power plant sites.

If not, discuss why such positions are unnecessary.

(A.2.d)

11.

Clarify whether the delegation of work (that has an importance to safety) to organizations outside Duke Power Company is controlled by the procurement controls described in the report.

(A.2.e, A.3.b, and A.4.a) 2

12.

Clarify whether Duke's corrective action program ensures that corrective actions are not inadvertently nullified by later actions.

(A.6.b)

13.

Section 17.3.1.6 and the last paragraph of Section 17.3.2.13 of the topical report address trend analyses. Clarify whether significant trends are reported to the appropriate levels of management.

(A.6.e)

14.

The topical report should include a commitment to comply with 10CFR21, Criterion 1 of Appendix A to 10CFR50, Regulatory Guide 1.26, Regulatory Guide 1.29, Regulatory Guide 1.152, Regulatory Guide 4.15, Regulatory Guide 7.10, and Generic Letter 89-02 as part of the overall QA program.

(A.7.a, A.7.b, and A.7.c)

15.

Clarify whether, for Section III ASME B&PV Code items, the Code QA requirements are supplemented appropriately with the guidance of the regulatory guides listed in Table 17.0-1 of the report.

(A.7.d)

16.

The fourth paragraph of Section 17.3.2.4 addresses the qualification of vendors using experience/historical data.

Clarify that, in accordance with Generic Letter 89-02, such vendor qualification is not used for commercial grade products used in safety-related application. Also, describe any special provisions required to verify the acceptability of product important to safety from a vendor so qualified.

(B.3.4.b)

17.

The fifth paragraph of Section 17.3.2.4 addresses the reevaluation of approved vendors. Clarify whether, in accordance with Regulatory Guide 1.28, vendors are audited triennially.

(B.3.4.c)

18.

Clarify whether procurements are subject to Duke's QA program requirements that are in effect at the time of purchase..(B.4.h)

19.

The seventh paragraph of Section 17.3.2.4 addresses the procurement of commercial grade items.

Discuss the determination and verification of critical characteristics of these items.

(B.4.i)

20.

Clarify Section 17.3.2.5 to indicate whether the quality of purchased items and services is verified at intervals and to a depth consistent with the item or service's importance to safety, complexity, and quantity and the frequency of procurement.

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21.

Clarify that traceability is maintained to an extent consistent with each item's importance to nuclear safety.

(B.6.b)

22.

Clarify that nondestructive examination equipment is also controlled in accordance with the commitments in Section 17.3.2.9 of the QA topical report.

(B.9.b)

23.

The last paragraph of Section 17.3.2.9 states that installed equipment, subject to Technical Specification requirements, is not subject to Duke's tagging commitments for other measuring and test equipment. Provide justification for this exception. (B.9.d)

24.

The first sentence of Section 17.3.2.10 states that items that are "in other than operable status" are so identified.

Clarify that this includes nonconforming items as well.

(B.10.a)

25.

The sixth paragraph of Section 17.3.2.12 limits the Quality Verification Department's evaluation and approval of inspection activities to those involving the vendor QA program. Clarify that these evaluations extend to in-house inspection activities as well or justify this apparent lack of program verification.

(C.2)

26.

Clarify whether personnel responsible for carrying out the self-assessment function are cognizant of day-to-day activities and that they act in a management advisory capacity.

(C.l.a)

27.

Duke's response to Standard Review Plan Section 17.3 acceptance criteria C.2.c, d, e, and f is given under some specific sections in Part 17.3.3 of the topical report.

Since these criteria should be generic to the assessment process, consider revising Part 17.3.3 of the topical report such that the response to these criteria applies to each of the assessment functions.

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