ML17297A711
| ML17297A711 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/20/1981 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| ANPP-18717-JMA, NUDOCS 8108270274 | |
| Download: ML17297A711 (66) | |
Text
'1 REGULA r RY INFORMATION DISTRIBUTIO SYSTEM (RIDS)
ACCESSION NBR 810 827027 DOC,DATE: 81/08/20 NO ARIZED; YES DOC FACILi:STN 50-528 Palo Verde Nuclear Station~ Unit 1~ Arizona Publi 0 STN-50-529 Palo Verde Nuclear Station~ Unit 2i Arizona Publi 050005?9 BYNAME'AN SlN-50-530 Palo Verde."Nuclear Station~ Unit 3i Arizona Publi 05000530 AUTH AUTHOR AFFILIATION BRUNTgEi~ E, Arizona Public Service Co, REC IP ~ NAMEl RECIPIENT AFFILIATION TEDESCOgR,Li, Assistant Director for Licensing SUBJECT;. Forwards response to Quality Assurance Branch 810714 request for addi info re facility SER ~
DISTRIBUTION CODEI: B001S COPIES RECEIVED:LiTR ENCL 'IZE:" ~
TITLEt: PSAR/FSAR AMDTS and Re.lated Correspondence NOTES:Standardized Plant F 1 cy.'C, Grimes 05000528 Standardized Plant ~ 1 cy,'C Grimes 05000529 Standardized Plant, 1 cy:C Grimes 05000530 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMEt LTTR ENCL ID CODE/NAME" LiTTR ENCL-"
ACT'ION o A/D" LICENSNG 1 0 LiIC BR 03 BC 1 0 LIC BR 03~ LA 1 0 KERRIGANg J, 04 1 INTERNALi: ACC ID EiVAL BR26 1 1 AUX SYS BR 27 1- 1 CHEM ENG BR 11.- 1- 1 CONT SYS BR 09 1 CORE PERF BR 10- 1 1 EFF TR SYS BR12 1 1 EMRG PRP DEV 35 1 1 EiMRG PRP LIC 36 3 3 EQUIP'UAL BR13 3 FEMA REP DIV 39 1 1 GEOSCIENCES 28 2 2 HUM FACT ENG 40 1 1 HYD/GEO, BR 30. 2 2 I ac SYS BR 16 1 I8 E( 3 I L'I C GU 0 BR 33 1 1 32'- MATLi ENG BR 17 06IC QUAL BR 1 1 1 1 ~
MECH ENG BR 18 1 1 i4IP A 1 0-OELD 1 0 OP LIC BR f~
PO'HER SYS BR 19 1 1 PROC/TST REV 20 1 li QA BR 21 1 1 BR22 1 1 REAC SYS BR 1 1 01 1 ANAL BR 23'IT 24 1 1 STRUCT ENG BR25 1 1-EXTERNALi: ACRS 16 16 LPDR 03 1 1 NRC~ PDR 0 2u 1 1 NSIC 05 1 1 NTIS 1 1 SEP g iggy tu+
TOTAL NURBER OF COPIES REQUIRED'TTR 6 ENCL
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p IPK84IICI IKIIHWEtllla CKSHB%HW P.o. BOX 21666 - PHOENIX, ARIZONA 65036 August 20, 1981 ANPP-18717 JMA/KWG Mr. R. L. Tedesco 1 Assistant Director for Licensing Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Sub j ect: Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and 3 Docket Nos. STN-50-528/529/530 File: 81-056-026'.1.10
Reference:
Your letter of July 14, 1981: Request for Additional Information Palo Verde Nuclear Generating Station
Dear Mr. Tedesco:
Please find attached our responses to the Quality Assurance. Branch (260) questions transmitted in the referenced letter. We are providing this information in an effort to assist you in timely preparation of your SER.
If you have any questions, please contact me.
Very truly ou s, E. E. Van Brunt, Jr.
APS Vice President, Nuclear Projects ANPP Project Director EEVBJr/KWG/av Attachment cc: J. Kerrigan (w/a)
P. Hourihan (w/a)
A. C. Gehr (w/a) /DO~
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0 Mr. R. L. Tedesco August 20, 1981 ANPP-18717 JMA/KWG Page 2 STATE OF ARIZONA )
) st COUNTY OF MARICOPA)
I, Edwin E. Van Brunt, Jr. represent that I am Vice President Nuclear Pro)ects of Arizona Public Service Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority so to do, that I have read such document and know its contents, and that to the best of my knowledge and belief, the statements made therein are true.
Edwin E. Van Brunt, Jr.
Sworn to before me this%@ day of 1981.
Notary Public My Commission expires:
My Commission Fx '
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s s t RE UEST FOR RESPONSE TO ADDITIONAL INFORMATION PALO VERDE NUCLEAR GENERATING STATION UESTION 17A.50 (NRC Question 260.50) (17.2.2 and 3.2)
The response to NRC Question 260.10 states: "Item 16 in Table 3.2-1 indicates that 10 CFR 50 Appendix B does not apply to the fire protection system."
Clarify in. Table 3.2-1 that the pertinent requirements of Appendix B (i.e., those specified in BTP ASB9.5-1) do apply.
RESPONSE: The response is given in the amended response to NRC Question 260.10. (17A.10) (ctdheted)
UESTION 17A.51 (NRC Question 260.51) (17.2.2)
The response to NRC Question 260.12 is not responsive to the extent that it does not address notification of the QA Branch of QA program changes.
Clarify that the QA Branch will be so notified.
RESpONSE: The response'is included in amended section 17.2.2.5. (a')let)~)
UESTION 17A.52 (NRC Question 260.52) (17.2.2 and 1.8)
The APS'xception to position C.2 of Regulatory Guide 1.64 is acceptable only with the following additional controls:
e a) The justification (for, design verification by a designer's immediate supervisor) is individually documented and approved in advance, and b) Quality Assurance audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
Include these controls in the exception or describe other controls to assure that the exception does not become the norm.
RESPONSE: The response is included in amended section 1.8.
b (17.2.2 and 1.8)
The APS response to Part 14 of NRC Question 260.13 indicates that imple-mentation of Regulatory Guide 1.94, Rev. 1, is not required since the construction permit for PVNGS was docketed October 7, 1974. However, the application for an operating license was docketed on June 18, 1980; and, in accordance with Rev. 1 of the Standard Review Plan (NUREG-75/087), we require a commitment to Rev. 1 of'egulatory Guide 1.94 for operations phase activities that are comparable to activities during the construction phase. Provide such a commitment with any alternatives, exceptions or clarifications you believe are required, RESPONSE: The response is given in the amended response to NRC Question 260.13 ('17A.13) Part 'll; UESTION 17A.54 (NRC Question 260.54) (17.2.2 and 1.8)
The exceptions stated in response to Regulatory Guide 1.144 are acceptable if not abused. That is, auditing as described without an audit plan or without a pre-audit conference may occasionally be desirable. Describe controls that APS will provide to assure that the exceptions do not become the norm.
RESPONSE: The response is included in amended section 1.8.
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g (NRC Question 260.55) (17.2.3)
The response to NRC Question 260.19 is not responsive. Respond to the question which is slightly reworded below.
Describe how APS plans to differentiate between design documents which require formal design review by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual. Provide a list of typical examples of each. Include such documents as specifications, calculations, computer programs, system descriptions, SAR when used as a design document, and drawings including flow diagrams, piping and instru-ment diagrams, control logic diagrams, electrical single-line diagrams agrams, structural systems for major facilities, site arrangements, and equipment locations.
RESPONSE: Normally, documents such as specifications, calculations, computer programs, system descriptions, SAR when used as a design document, and drawings including flow diagrams, piping and instru-ment diagrams, control logic diagrams, electrical single-line diagrams, structural systems for. major facilities, site arrangements, and equipment locations will require interdisciplinary review by multiple reviewers. The responsible engineer or supervising engi-neer will determine the level of review required based upon the importance to safety of the items or systems under consideration, the complexity of the design and the similarity with previously proven designs. The Corporate Quality Assurance Department or the Operations Quality Assurance Department will verify the effective-ness of design control measures through periodic audits as described in Section 17.2.18.
(NRC Question 260.56) (17.2.6)
The response to NRC Question 260.25 lists a number of documents which are reviewed for conformance to QA program requirements by the Operations or Corporate QA Department. The list omits design specifications; design, manufacturing, construction, and installation drawings; as-built docu-mentation; test procedures; and design changes. Although the list is a "such as" list, the omission of these documents can be interpreted to mean that they will not be so reviewed by an APS QA organization. It is the staff position that they should be. Commit to meet this position or provide an alternative for our evaluation.
RESPONSE: The response is included in amended section 17.2.6.
~44d UESTION 17A.57 (NRC Question 260.57) (17.2.6)
The response to NRC Question 260.26 regarding the control of obsolete and superseded documents indicates that changes will be sent with instructions to holders of controlled copies. Describe the follow-up which will be done to assure the instructions are followed.
RESPONSE: The response is included in amended se'ction 17.2.6. In addition, the Corporate Quality Assurance Department and the Oper-ations Quality Assurance Department shall verify the effectiveness of document control measures through periodic audits as described in section 17.,2,18. a.~WJ, QUESTION 17A.58 (NRC Question 260.58 (17.2.6)
The response to NRC Question 260.27 is not responsive. If different types of documents and different originating organizations may have different methods of identifying the applicable document revision, describe the different methods and the documents to which they apply.
RESPONSE: The response is included in amended Section 17.2.6.
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It is the staff position that the procurement of spare and replacement parts should be subject to the latest pertinent QA program controls; i.e., the approved operational QA pxogram. Commit to meet this position or provide an alternative for our evaluation (see response to NRC Question 260.29).
RESPONSE: 'Response is included in amended section 17.2.4.3. a.HcAcLeg UESTION 17A.60 (NRC Question 260.60) (17.2.9)
The response to NRC Question 260.35 indicates the Operations QA Department reviews and approves special process procedures developed by APS. It is the staff position that an APS QA Department 'should also verify (at least on an audit basis) the determination of whether a process is or is not a special process. Commit to meet this position or provide an alternative for our evaluation, RESPONSE: Amended section 17.2.9 indicates that the Operations QA Department will verify the determination of whether a process is or is not a special process. Such verification will be accomplished through monitoring, inspection, checking, auditing or review as .
described in section 17.2.2.3.2. pH-aeM4 UESTION 17A.61 (NRC Question 260.61) (17.2.1)
Section 17.2.1.3.2 indicates the Operations QA Manager "receives functional and technical ~uidance direction from the Corporate QA Manager", and Figure 17.2-1 has a dashed line between these two positions which the legend indicates as "functional and technical guidance." (Emphasis added) It is the staff position that the organization shown is acceptable if "guidance" is eliminated from the first quotation and changed to "direction" in the second. Commit to meet this position or provide an alternative for our evaluation.
RESPONSE: The response is included. in amended sections 17.2.1.1.6 and 17.2.1.3.2 and F igure 17.2-1. These responses more correctly define Arizona Public Service CompanyCom an s Quality Assurance responsibilities. ~R'4
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Provide a commitment 'that the QA program will be applied to the development, control, and use of computer programs and describe its application.
E RESPONSE: Response is included in amended sec-tion 17.2.2.2.
Q" *' " ("" Q"" "" (17.2.2 and 3.2)
Table 17.2-1 indicates that the Fire Protection QA Program is met as part of the QA Program under 10 CFR Part 50, Appen-dix B. Item 16 in Table 3.2-1 of the FSAR indicates that the PVNGS QA Program does not apply to the fire protection system. Clarify.
RESPONSE: Amended table 17.2-1 indicates that, the quality assurance program during the operations phase. complies with the quality assurance program guidelines of Appendix A to (BTP) APCSB 9.5-1. Application of the quality assurance program to fire protection program activities is described fgmqn cf in amended section 47.2.2.2. .
Tabje 3.2-1 indi-p 'tl'0lIIen'f r et u I r e ~ e eTs o7 (<o4 to 4he fire protection ~~
cates thatg10 CFR 50, Appendix B pragva~ a ef~uih'es ~uvi~g %he oppress'ovg, pA~se.
Q" *' " ("" Q"" "" (17.2.2)
Provide a commitment that special equipment, environmental conditions, skills, and processes will be provided as necessary.
RESPONSE: The response is included in amended sec-tion 17.2.2.1.
Amendment 4 17A-4 May 1981
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l Table 3.2-1 QUALITY CLASSIFICATION OF STRUCTURES, SYSTEMS AND COMPONENTS (Sheet 36 of 36) /4
- 7. Letter of arentheses (continued)
(s) The gas stripper is designed and constructed to Seismic Category Z requirements; however, this portion of the CVCS is not required to be Seismic Category Z by Regulatory Guide 1.29.
(t) process solenoid valves will be constructed in accordance with manufacturer's standards.
(u) Since this system is not required to function during an SSE, the CHRS is designed to remain functional after an SSE but not during an SSE.
(v) Designed to appropriate industry standards.
(w) External to the diesel engine package.
!x) Seismic Category I applies to. cable trays and supports." Q.S-e pertinent y-cpu(rex en' of lo ('.FRs>~ Rppeiid4 8 (>.<.p Hiose spec ifieii'n k PPcd P 8 g ) pCS8 (v) c(ppfied fo opel a~ionS @has(.'(rivi tie5 assoc.iateot wife fire prokcfion syske~s 4J and e~~iprnent used or i'nsfoiled in areas housing sdaf)t retd'ecf eguipmei(f, o)Lev- ar ea s where +< un s wppress e~ Ar e ( OtI!Ol cianiaZe 0 adc ty rely'ed I potentially lA co ski ucA4l dJ 5) 5 / e~s Qf c onipahenfs ~
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PVNGS FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.2.5 Pro ram Documentation Operations Quality Assurance Program policies and practices are described in this section.
Prior to. receipt of the Operating License for the PVNGS, 4[ revisions to this operations quality assurance program description will be made in accordance with Nuclear 4[ projects Department procedures for control of the FSAR.
Following receipt of the Operating License for the PVNGS, revisions to section 17.2 will be made in accordance with the PVNGS Operating Organization procedures for control of the FSAR. Such procedures shall require (ec: QA Branch) r notification to the NRCpof changes to the QA program, as described in section 17.2, prior to implementation, and organizational changes within 30'days after announcement.
Editorial changes and personnel reassignments which are not substantive do not, require NRC notification.
Various other documents, including instructions, procedures, and manuals, delineate quality-related activities carried 'out by various organizations within APS. Requirements for preparation, review, approval, revision, issuance, and distribution are delineated in 4( controlling procedures. Table 17.2-2 is a cross-reference of the requirements of 10CFR50, Appendix B, to the procedures contained in the Operations Quality Assurance Program Manual.
Amendment A- 17.2-18 May 1981
PVNGS FSAR CONFORI&NCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.64: Quality Assurance Requirements for the Design of Nuclear Power Plants (Revision 2, June 1976)
RESPONSE
For operations phase activities that are comparable to activities occurring during the construction phase, the position of Regulatory Guide 1.64 is accepted with the following exception to position C.2 of the Regulatory Guide:
1 Supervisory personnel may perform design verification under exceptional circumstances as documented and approved by next level of supervisiony >F-'AS FRY APS interprets ANSI N45.2.11-1974 sections 3.1 a'nd 4.1 as follows:
A. Section 3.1. This section implies that all necessary design input (as listed in section 3.2) should be available prior to the start of a design activity. In practice, certain design activities are initiated before the. firm input requirements are available.
(For example, foundation designs prepared based on preliminary information or equipment. sizes and mount-ing and embedded conduit run based on preliminary
.estimates of circuit, requirements). The design phase QA program is structured to assure that all necessary design input is available before completion of final
'esign of the work affected by the input 'and that final design input is available for use in verifica-tion of the final design.
B. Section 4.1 Design Process General. Paragraph 3 implies traceability back from final design to the source of design input. 'n practice, a literal inter-pretation of this is not always possible. For exam-ple, final design drawings do not identify the related calculations. This paragraph is interpreted to mean 41 Amendmen t~ 1.8-49A Hay 1981
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Page 1.8-49A INSERT
- 1. The justification (for design verification by a designer's immediate supervisor) is individually documented and approved in advance, and
- 2. Quality Assurance audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
W PVNGS FSAR APPENDIX 17A (14) Regulatory Guide 1.144 - Include APS Position on Rev. 0, January 1979. (Note that this Reg. Guide references ANSI N45.2.12-1977 as listed in table 17.2-1.)
(15) Regulatory Guide 1.146 Include APS Position on Rev. 0, August 1980. (Note that this Reg. Guide.
references ANSI N45.2.23-1978 as listed in table 17.2-1.)
RESPONSE
(1) The response is included in amended section 1.8.
(2) The response is included in amended section 1.8.
(3) The response is included in amended section 1.8.
(4) The response is included in amended section 1.8.
(5) The response is included in amended section 1.8.
(6) The response is included in amended section 1.8.
(7) The response is included in amended section 1.8.
(8) The response is included in amended section 1.8.
(9) The response is included in amended section 1.8.
(10) The response is included in amended section 1.8.
7<c res ouse i5 inc.lu,etre ik awe Acct se @+I dR I y (11) e construction permr or PVNGS Units 1, 2 =-
and as docketed October 7, 1974. herefore implementa i n of Regulatory.-Guide 1.94, Rev. 1 is not required. he quality assurance require-ments for~in ta11ation, and testing inspection, of st~r natural concrete and structural steel during
~c n'ftruction and comparable activitxe uring the operations phase are discussed in Section 3.
Pay 1981 17A"7 Amendment ~
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES
RESPONSE
Information contained in Regulatory Guide 1.92 is utilized as discussed in sections 3.7 and 3.9.
REGULATORY GUIDE 1.93: Availability of Electric Power Sources (Revision 0, December 1974)
RESPONSE
The position of Regulatory Guide 1.93 is accepted (refer to section 16.3/4).
/g5 6, /PT REGULATORY GUIDE 1.95: Protection of Nuclear Power Plant Control Room Operators Against, an Accidental Chlorine Release (Revi-1l sion 0, February 1975)
RESPONSE
The position of Regulatory Guide 1.95 is accepted.
REGULATORY GUIDE 1.97: Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident
RESPONSE
PVNGS compliance with the recommendations of Draft Revision 2 to Regulatory Guide 1.97 (issued for public comment December 4, 1979) will be addressed subsequent to its issuance reflecting public comments.
REGULATORY GUIDE 1.99: Effects of Residual Elements on Pre-dieted Radiation Damage to Reactor Vessel Materials (Revision 1, April 1977)
March 1980 1.8-51 Amendment ~
I Page 1.8-61 INSERT:
REGULATORY GUIDE 1.94: Quality Assurance Requirements for Installation, Inspection and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants (Revision 1, April 1976)
RESPONSE: . For operations phase activities that are comparable to activities during the construction phase, 'the position of Regulatory 4
Guide 1'.94 is accepted. Refer to Section 3.8.
DESIGN OF CATEGORY I 'STRUCTURES Regulatory Guide 1.63, Electrical Penetration Assemblies in Containment Structures for K,ight-Nater-Cooled Nuclear Power Plants Regulatory Guide 1.64, Quality Assurance Reguire-ments for the Design of Nuclear Power Plants Regulatory Guide 1.69, Concrete Radiation Shields for Nuclear Power Plants Regulatory Guide 1.76, Design Basis Tornado for Nuclear Power Plants 1QS ER T xceptions to and interpretations of these regulatory guides are given in section 1.8.
o NRC (AEC) Publication TID 25021, Nuclear Reactors and Earthquakes, is used for computing hydrodynamic loads imposed on the refueling canal walls.
~ Industry Standards Nationally recognized industry standards, such as those published by American Society for Testing and Materials (ASTM), are used whenever possible to describe material properties, testing procedures,
'abrication, and construction methods.
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~ Bechtel Power Corporation Topical Reports (Applicable titles, dates, and revisions are provided in section 1.6.
BC-TOP-1 BC-TOP-3-A BC-TOP-4-A BC-TOP-5-A BC-TOP-7
.3.8-11
Page 3.8-11 INSERT Regulatory Guide 1.94, Quality Assurance Requirements for Installation Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants.
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TABLE 17.2-1 QUALITY ASSURANCE STANDARDS AND GUIDES COMPLIANCE MATRIX (Sheet 3 of 4)
NRC Regulatory Clarifications and Guides Standard Title Exceptions 1.64 ANSI N45.2.11 Quality Assurance Requirements Refer to section 1.8 for the Design of Nuclear Power Plants Initial Test Programs for Refer to section 1.8 Water-Cooled Nuclear Power Plants 1.68.2 Initial Start'Up Test Program Refer to section 1.8 to Demonstrate Remote Shut-down Capability for Water-Cooled Nuclear Power Plants 1.70 Standard Format and Content of Refer to section 1.8 Safety Analysis Reports for Nuclear Power Plants LWR Edition 1.74 ANSI N45.2.10 Quality Assurance Terms and Refer to section 1.8 Definitions 1.88 ANSI N45.2.9 Collection, Storage and Mainte- Refer to section 1.8 nance of Nuclear Power Plant Quality Assurance Records t.~9 Av~IQA> + ra(i t y AS54r~~ e< lPepur'rene ewe s ge4r fo Sec ~fo< I. 8 lns~a~~+~I~ INsplpcf b% a4g Trsf'ny oP St>uck~a f C~crefc a~q Sfrucfutc (
5'fee/ gus'(Hg f4 e C'o~s A ucfh e PA a s e oP blue(cay Iomev Plants
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES
RESPONSE
The position of Regulatory Guide 1.141 is accepted (refer to section 6.2.4).
REGULATORY GUIDE 1.144: Auditing of Quality Assurance Programs for Nuclear Power Plants (Revision 1, September 1980)
RESPONSE
The requirements of the referenced standard (ANSI N45.2.12-1977) as modified and interpreted in the position of Regulatory Guide 1.144 are applied to the APS quality assurance program for operations phase activities, with the following exception~
Section Section .2.1: A written individual audit pla a no pr'epared for each audit owe er, all informa-tion requz.r. 0-f- e written plan will be included in
~udice schedules, notifica on-1 ers, checklists, reports, procedures or other audit records.
&ection-4 '44~ A formal Pre-Audit Conference may not be required for some routine internal audits where informal pre-'audit communication is determined to be adequate.
/lvsER7 REGULATORY GUIDE 1.145: Atmospheric Dispersion Models for Potential Accident, Consequence Assessments at Nuclear Power Plants (August 1979) 4l Amendment ~ 1.8-.66B May 1981
Page 1.8-66B INSERT:
The manager of the auditing organization will monitor the performance of audits, through review of audit reports, to ensure that informal pre-audit communication is utilized only in cases where such informal commun-ication is adequate.
I PVNGS FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHASE o Design Changes o Nonconformance Reports o Audit Reports o Minutes of the Safety Audit Committ'ee Meetings desi H spccl I 04&J 5 H5 'c~ J~<> ~RAk3PAcA4l'isla> co<<Q'fructi'o+, a>a of related documents such as procurement documents; ie~kaltR~'uality quality assurance manuals; maintenance, modification, and operating procedures; selected sections of the FSAR; inspection an4 testing instructions; nonconformance reports; gg-kaa((j docun intaf'io~ g le f Prat,eAures ~ d es/ng c,ha~pcs~ 4 and audit reports shall be revxewe8 by the Operations Quality Assurance Department or the Corporate Quality Assurance epartmentX who~ necaioary to verif'y c.onfov~~~ce to guallhg ass~vance Proyvo ws v <<quit ewsev+4 o Changes to documents can be requested by any reviewing or using organization or individual. Such changes are subject to the same level of review and approval as the original E documents.
Approved changes are included in instructions, procedures, and drawings prior to implementation of the change. Changes to documents, with instructions, as appropriate, for destruction, marking, or return of the superceded doc shall be JV to holders of controlled copies. 5P'ssued neon rolled copies shall be marked to indicate their status.
Administrative procedures may prescribe measures to tempo-rarily change station procedures if the intent of the original procedure is not altered and the changes comply with require-ents of the Technical Specifications.
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nistrative controls assure that, documents are reviewed and approved prior to use, are used by the personnel performing the activity, that there are means for determining the status of a document, and that controls preclude the use of outdated or superseded documents.
May 1981 .17.2-39 Amendment 4
Pa e 17.2-39 INSERT 1:
Document control measures shall include provisions for holders of controlled copies to 'acknowledge receipt of changes and, when appropriate, indicate compliance with instructions for handling superseded documents.
INSERT 2:
The Nuclear Records Management System (RMS), maintained by APS Nuclear Projects, shall establish 'Control ~Lo s and Distribution Lists which shall be maintained to control issuance of documenta-tion such as Procedures, Instructions, Procurement Documentation, Technical Manuals, Specifications, and/or Drawings. These logs and lists shall identify the revision status of the applicable documents and the latest changes to the documents. These logs and/or lists shall be made available to the working locations for use in determining current document status. Procedures shall provide control measures which address obsolete, superseded or, unapproved documentation. In addition, control logs and lists shall be reviewed and updated periodically to maintain them in a current status.
. APS Manuals, such as the Operations Quality Assurance Program Manual, the Palo Verde Nuclear Generating Station Manual, and the Nuclear Projects Department Project Procedures Manual, contain Indexes, Table of Contents or Lists of Effective Pages, which are updated periodically to ensure the Manual's revisions are kept current.
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PVNGS FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHASE inspectable and controllable; there are adequate acceptance and rejection criteria; and, the procurement. document has been prepared, reviewed, and approved in accordance with Operations Quality A'ssurance Program requirements.
B. Quality-related procurement documents initiated offsite will be reviewed and approved by qualified Nuclear Engineering and Corporate Quality Assurance personnel. The review will cover the same areas as stated -in A. above.
C. Technical and quality changes to procurement documents are subject, to at least the same level of review and approval as the original document.
The review and approval of procurement documents are documented prior to contract award and are available for verification in accordance with section 17.2.17.
17.2.4.3 Control of Procurement Documents Procurement documents are controlled in accordance with the document control practices established in section 17.2.6, stored in accordance with section 17.2.17, and reviewed and approved in accordance with the minimum requirements established in this section.
The quality assurance program will ensure that. procurement documents for spare or replacement partslatest'si of safety-related structures, systems, and components contain technical and quality requirements at least equivalent to those used for the original equipment or acceptable alternatives~ an8 5<eh p poeure~e~'4 Rl'c 5u LJ'eel Po t'h e progra ~
co~ t.~ops.
May 1981 17.2-35 Amendment Ci-
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APPENDIX 17A (c) The interpretation regarding section 5.2.17 of ANSI N18.7 is acceptable with the understanding that all deviations are documented and corrected.
(5) Regulatory Guide 1.37 Reference to the Bechtel position during construction should be replaced by the APS position for comparable activities during the operations phase.
(6) Regulatory Guide 1.38 (a) Commitment should be to Revision 2, May 1977.
(b) Same as (5) above.
(7) Regulatory Guide 1.39 - Same as (5) above.
(8) Regulatory Guide 1.58 Commitment should be to Rev. 1, September 1980.
(9) Regulatory Guide 1.64-(a) Commitment should be to Revision 2, June 1976.
'b) Same as (5) above.
(10) Regulatory Guide 1.88 Commitment should be to Rev. 2, October 1976.
(ll-~egu atory Guide 1.94 Include APS Position on Rev. 1, April 1976.
(12) Regulatory Guide 1.116 ' Include APS Position on Rev. O-R, May 1977.
(13) Regulatory Guide 1.123 Include APS Position on Rev. 1, July 1977.
Amendment 4 '17A-6'ay 1981
PVNGS FSAR QUALITY ASSURANCE DURING THE OPERATIONS PHASE the equivalent.. Evidence of verification shall be documented.
For special processes not covered. by existing codes or stand-ards or where quality requirements exceed the requirements of established codes and standards, the procedures for qualifying personnel, procedures or equipment shall be defined in the procurement documents or shall be submitted for review prior to use.
Each department within APS shall be responsible for evaluating each of the processes it performs t AID rmine if they fall i under the controls of this section. ach department shall develop its own procedures and qualification requirements in accordance with this section. The Operations Quality Assur-ance Department sha3.1 review and approve special process pro-cedures developed by APS.
Documentation of procedures and personnel qualification shall be maintained current by the vendor. The Manager of Nuclear Operations shall be responsible for maintaining such docu-mentation for PVNGS personnel involved in performing'special process activities.
17 . 2. 10 INSPECTION 17.2.10.1 General The Operations Quality Assurance Program requires that an inspection program be developed and implemented to verify conformance of quality-related activities and activities affecting safety-related structures and components with the applicable requirements. This program is accomplished in accordance with written procedures, instructions, or drawings by qualified inspection personn l, when required, other than those performing or directly supervising the activity being inspected, and the results are documented.
The inspection program provides for indirect control by monitoring processing methods, personnel, and equipment when direct inspection is not possible.
Amendment~ 17.2-48 August 1981 7-7-81.
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Page 17:2-48 INSERT'he determination of whether a process is or is not a special process shall be verified by the Operations Quality Assurance Department.
PVNGS FSAR QUAIITY ASSURANCE DURING THE OPERATIONS PHASE where necessary. The Electric Operations Vice President has the authority to stop PVNGS activities which are not accom-plished in compliance with applicable license and/or regula-tory requirements. The Electric Operations Vice President's day-to-day responsibilities for the operation of the PVNGS has been delegated to the PVNGS Plant Manager, including the responsibility for proper implementation of the quality assurance program. The Electric Operations Vice President and the Nuclear Projects Management, Vice President jointly approve the Operations Quality Assurance Program Manual.
17.2.1.1.5 Safety Audit Committee (SAC)
The organizational structure, administrative requirements, responsibilities, and authorities of the Safety Audit Committee are detailed in section 16.6.
17.2.1.1.6 Corporate Quality Assurance Manager 4
The Corporate Quality Assurance Manager is responsible for development of the Operations Quality'ssurance Program and to verify effective implementation 'of the Operations Quality Assurance'rogram. He. reports directly to the Nuclear Projects Management, Vice President, but has access to the Electric Operations Vice President and the Operations Execu-tive Vice President for matters related to quality assurance.
The Corporate Quality Assurance Manager directs the activities of the Corporate Quality Assurance Department and provides oltrec+/on functionalgand technical guidance to the Operations Quality Assurance Manager. The Corporate Quality Assurance Manager has overall responsibility for the quality assurance program including audits and quality verification.
The Corporate Quality Assurance Manager has been given the authority, by the President and Chief Executive Officer, to maintain open lines of communication with individuals and groups having responsibilities related to the operation of Amendment 4 '17 '-4 may 1981
PVNGS FSAR QUAIITY ASSURANCE DURING THE OPERATIONS PHASE 17.2.1.3.2 Operations Quality Assurance Manager The Operations Quality Assurance Manager has been delegated the responsibility by the Plant Manager for verifying the effective implementation of the qnsite quality assurance d >reck]en program. He receives functionalgand technical guidance M~e-
~ from the Corporate Quality Assurance Manager. The Operations Quality Assurance Manager has sufficient authority and organizational freedom to identify quality problems, initiate, recommend or provide solutions, through designated channels; and verify implementation of solutions. He is free of non-QA duties such that he can give full attention to assuring that the onsite quality assurance program is being ef fectively implemented.
17.2.1.3.3 . Operations Quality Assurance Department The Operations Quality Assurance Department is directed by the Operations Quality Assurance Manager who reports directly to the Plant Manager. The Operations Quality Assurance Department ensures that the requirements of the Operations Quality Assurance Program are incorporated in the onsite quality .assurance program, and that, they are incorpo-rated into plans and procedures for activities affecting quality and are implemented properly. The Operations Quality Assurance Department is responsible for verifying, through inspections, monitoring, and audits, the conformance of quality-related activities to specified requirements and procedures and reports on the effectiveness of the QA program to the Plant Manager. The responsibilities of the Operations Quality Assurance Department include the following:
A. Verify that quality-related sta ion procedures conform to QA program requirements.
B. Verify the implementation of quality-related procedures through audits, monitoring, and inspection of station activities.
Ame..dment 4 17.2-10 May 1981
1 Page 17.2-10 INSERT:
The Operations Quality Assurance Manager reports directly to the Manager of Nuclear Operations, but has access to the Electric Operations Vice President and the Operations Executive Vice President for matters related to quality assurance.
0 OFFSITE ONSITE CORPORATE QUALITYASSURANCE PLANT MANAGER MANAGER OP E RATIONS QUALITYASSURANCE MANAGER SI=F ZNS'ER%
Pot io~~<<j V~E CONSTRUCTION QA/QC QUALITYSYSTEMS SUPERVISOR SUPERVISOR CONSTRUCTION QA/QC QUALITYSYSTEI'IS ENGINEERS EN G I NE E RS LEGEND:
LIMEAUT<IOBITY yggcjlblv UN F CT I ONAL~AN0 TECHNICAL GUIDANCE Palo Ver>le il>>clear Gc>>crati>>~ Statio>>
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