ML16341A579
| ML16341A579 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 05/09/1985 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Shiffer J PACIFIC GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8505140240 | |
| Download: ML16341A579 (12) | |
Text
MAY 9 1985 Pacific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention:
Mr. James D. Shiffer Vice President, Nuclear Power Generation
SUBJECT:
QUALITY ASSURANCE PROGRAM DESCRIPTION FOR DIABLO CANYON On March 29, 1985, you submitted changes to Chapter 17 of the Diablo Canyon Power Plant Final Safety Analysis Report (FSAR) Update.
As a result of our review, we have determined that additional information is needed addressing the following sections of Chapter 17:
Section 17.1 Or anization a.
Page 17.1-3, paragraph 6 defines the responsibilities of the Chief, Engineering Research.
His responsibilities for the development and qualification of any and all metallurgical process procedures (such as welding and heat treatment) and nondestructive examination procedures required by PG&E, has been deleted.
Please identify the person delegated this responsibility and where located in Chapter 17.
b.
Page 17.1-7 the last paragraph addresses the responsibilities of the General Office Nuclear Plant Review and Audit Committee.
The third sentence has been changed from "The Committee performs reviews and audits..." to "The Committee has the authority to have reviews and audits performed..."
This appears to be a reduction in your Quality Assurance Program commitments in that the change implies that review and audits are at the discretion of the Committee and, -therefore, may not be performed.
Section 17.2 ualit Assurance Pro ram a.
Page 17.2-1.
The third noted change states "The structures,
- systems, and components to be covered by the Quality Assurance Program described in the Quality Assurance Manual shall be identified".
A description as to what this statement applies to needs to be addressed.
As a minimum it should include those structures, systems and components classified as Design Class I given in Table 3.2-3 of Section 3.2 of the FSAR.
b.
Page 17.2-3.
This page appears to have been deleted.
The President's Nuclear Advisory Committee (PNAC)
QA Program functions are addressed on this page.
Please explain the reason for this deletion.
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MAY 9 198) c ~
Table 17.2, Sheet 3 of 4, exceptions to Regulatory Guide 1.64.
In order to take advantage of the "exceptional circumstances as described in NUREG-0800" we recommend that you add the words "and with the controls" after "circumstances."
Section 17.3 De'si n Control Page 17.3-1, third paragraph.
Deletion of quality control review of design drawings and specifications and the subsequent replacement of this quality assurance function by the design organization is an unacceptable reduction in the QA program commitments.
Justification based on the Company philosophy that procedural adequacy and the determination of quality aspects related to technical work are the responsibility of the design engineer does not meet the intent of Section 17.2.3 (3E2) of NUREG-0800 "Standard Review Plan."
This attitude, that the engineering organization is comprised of professionals capable of doing what is right without overlaying a stringent formal QA program beyond the normal controls considered part of good engineering practice, is identified in NUREG-1055, page A.16, as one of the contributing factors to the quality failures experienced by the licensee in the Case C
study.
Section 17.5 Instructions, Procedures and Drawin s The deletion of elements to be included in procedures or instructions represents a reduction in your QA program commitments.
Please provide justification for this change.
Section 17.7 Control of Material, E ui ment and Services In the first paragraph of page 17.7-1 the words "in accordance with implementing procedures" was deleted.
Please explain the reason for this deletion or leave as worded in the FSAR Update.
Section 17.9 S ecific Processes Additional justification is requested for deletion of "calibration, fluid flushing systems, application of protective coatings, and concrete batch plant operations" from the list of special processes.
These activities appear to fall under the definition of a special process addressed in the second paragraph of Section 17.9.
As a minimum it is expected that if any of these special processes have a safety-related function the applicable controls of this section would apply.
Section 17.12 Control of Measurin and Test E ui ment Page 17.12-1, the fifth paragraph, third sentence regarding calibration accuracy is being changed from "when this is not possible" to "when this is not practical."
Your justification that the four to one rato is in many cases
- possible, but may not be economically feasible and/or even desirable, is satisfactory.
However, the responsible management, by position or positions, that can authorize the basis of acceptance needs to be identified.
1 I
I
3'AY9 1985 The completion of our review will depend on the satisfactory responses to these items.
If your have any questions regarding this matter please contact W. J.
Wagner of my staff on (415) 943-3731.
/a/
D. P. Kirsch, Acting Director Division of Reactor Safety and Projects CC ~
H. E. Schierling, NRR J.
G. Spraul, SQUAB M. M. Mendonca, RV Section Chiefs Branch Chiefs Document Control Desk RV/jk
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UNITED STATES NUCLEAR REGULATORY COMMISSION
" REGIONV 1450 MARIALANE,SUITE 210 WALNUTCREEK, CALIFORNIA94596 MAY 9 1986 Pgcific Gas and Electric Company 77 Beale Street San Francisco, California 94106 Attention:
Mr. James D. Shiffer Vice President, Nuclear Power Generation
SUBJECT:
QUALITY ASSURANCE PROGRAM DESCRIPTION FOR DIABLO CANYON On March 29, 1985, you submitted changes to Chapter 17 of the Diablo Canyon Power Plant Final Safety Analysis Report (FSAR) Update.
As a result of our review, we have determined that additional information is needed addressing the following sections of Chapter 17:
Section 17.1 Or anization a ~
Page 17.1-3, paragraph 6 defines the responsibilities of the Chief, Engineering Research.
His responsibilities for the development and qualification of any and all metallurgical process procedures (such as welding and heat treatment) and nondestructive examination procedures required by PGRE, has been deleted.
Please identify the person delegated this responsibility and where located in Chapter 17.
b.
Page 17.1-7 the last paragraph addresses the responsibilities of the General Office Nuclear Plant Review and Audit Committee.
The third sentence has been changed from "The Committee performs reviews and audits..." to "The Committee has the authority to have reviews and audits performed..."
This appears to be a reduction in your Quality Assurance Program commitments in that the change implies that review and audits are at the discretion of the Committee and, therefore, may not be performed.
Section 17.2 ualit Assurance Pro ram a.
Page 17.2-1.
The third noted change states "The structures,
- systems, and components to be covered by the Quality Assurance Program described in the Quality Assurance Manual shall be identified".
A description as to what this statement applies to needs to be addressed.
As a minimum it should include those structures, systems and components classified as Design Class I given in Table 3.2-3 of Section 3.2 of the FSAR.
b.
Page 17.2>>3.
This page appears to have been deleted.
The President's Nuclear Advisory Committee (PNAC)
QA Program functions are addressed on this page.
Please explain the reason for this deletion.
MAY 9 1985 C ~
Table 17.2, Sheet 3 of 4, exceptions to Regulatory Guide 1.64.
In order to take advantage of the "exceptional circumstances as described in NUREG-0800" we recommend that you add the words "and with the controls" after "circumstances."
Se tion 17.3 Desi n Control t"
Page 17.3-1, third paragraph.
Deletion of quality control review of design drawings and specifications and the subsequent replacement of this quality assurance function by the design organization is an unacceptable reduction in the QA program commitments.
Justification based on the Company philosophy that procedural adequacy and the determination of quality aspects related to technical work are the responsibility of the design engineer does not meet the intent of Section 17.2.3 (3E2) of NUREG-0800 "Standard Review Plan."
This attitude, that the engineering organization is comprised of professionals capable of doing what is right without overlaying a stringent formal QA program beyond the normal controls considered part of good engineering practice, is identified in NUREG-1055, page A.16, as one of the contributing factors to the quality failures experienced by the licensee in the Case C
study.
Section 17.5 Instructions, Procedures and Drawin s The deletion of elements to be included in procedures or instructions represents a reduction in your QA program commitments.
Please provide justification for this change.
Section 17.7 Control of Material, E ui ment and Services In the first paragraph of page 17.7-1 the words "in accordance with implementing procedures" was deleted.
Please explain the reason for this deletion or leave as worded in the FSAR Update.
Section 17.9 S ecific Processes Additional 5ustification is requested for deletion of "calibration, fluid flushing systems, application of protective coatings, and concrete batch plant operations" from the list of special processes.
These activities appear to fall under the definition of a special process addressed in the second paragraph of Section 17.9.
As a minimum it is expected that if any of these special processes have a safety-related function the applicable controls of this section would apply.
Section 17.12 Control of Measurin and Test E ui ment Page 17.12-1, the fifth paragraph, third sentence regarding calibration accuracy is being changed from "when this is not possible" to "when this is not practical."
Your Justification that the four to one rato is in many cases
- possible, but may not be economically feasible and/or even desirable, is satisfactory.
However, the responsible management, by position or positions, that can authorize the basis of acceptance needs to be identified.
p
The completion of our review will depend on the satisfactory responses to these items.
If(your have any questions regarding this matter please contact W. J.
Wagner ofFmy staff on (415) 943-3731.
D. F. Kirsch, Acting Director Division of Reactor Safety and Projects Cce H. E. Schierling, NRR J.
G. Spraul, QUAB M. M. Mendonca, RV Section Chiefs Branch Chiefs Document Control Desk
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