ML17298B668
| ML17298B668 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde |
| Issue date: | 12/10/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-31402-EEVB, NUDOCS 8412180097 | |
| Download: ML17298B668 (10) | |
Text
0 'ECEIVE Arizona Public Service Company mt ANPP-31402-EEVB/R'18/3 ItF(/J'/AD]f December 10, 1984 U.S. Nuclear Regulatory Commission Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects Region V
1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 itEGI (g )flpF
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Docket Nos.
STN 50-528/529/530
'Aj/ggfg Quality Program Description for Palo Verde Units 1, 2, and 3
File:
84-056-026 G.1.01.10
Reference:
NRC letter dated November 6, 1984
Dear Sir:
The referenced letter requested additional information as a result of the Region V review of proposed changes to Chapter 17 of the FSAR for Palo Verde Units 1, 2, and 3.
Attached for your review is the clarification pertaining to the reassignment of responsibilities as a result of the Quality Assurance Department reorganization.
Very trul youp.
EEVB/ATR/MAK/nj/mb Attachment E. E.
Van Brunt, Jr.
APS Vice President Nuclear Production ANPP Project Director cc:
A. C. Gehr R. P.
Zimmerman E. A. Licitra 8412180097 841210 PDR ADOCK 05000528 i
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COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Vice President, Nuclear Production of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, 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 1984.
Notary Public Hy Commission Expires:
My CottMnlssion Expires April 6, 1987
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ATTACHMENT A Question:
Cha ter 17.1 Section 17.3A.1.2.5.2 PVNGS Construction A/
C The second sentence to this section requires the PVNGS Construction QA/QC Department to review site engineering and inspection documents to ensure that APS quality requirements are incorporated into Bechtel's Quality Program for construction activities.
Also, the QA/QC Department plans and conducts audits of Bechtel's construction activities.
Since the proposed changes would delete the Construction QA/QC Department, please address what department has been assigned these responsibilities and where these responsibilities are addressed in Chapter 17.1.
~Res ones:
The responsibility for the review of site engineering and inspection documents has been assigned to the Quality Systems and Engineering Department.
This is accomplished through review of Bechtel Work Plan Procedures/Quality Control Instructions (WPP/QCI).
The responsibility is addressed in the revised section 17.1A.1.2.5.1 which states in part:
"...review and/or control programs and procedures required for the implementation of the APS Quality Assurance Program...
review quality documents as necessary for incorporation and adequacy of quality requirements."
The responsibility to plan and conduct audits of Bechtel's construction activities has been assigned to the Quality Audits and Monitoring Department.
This responsibility is addressed in the revised section 17.1A.1.2.5e3 which states in part:
"...responsibile for for auditing and/or monitoring the implementation of the...Bechtel Quality Program for construction activities....
~estlon:
Cha ter 17.2 Section 17.2.1.2.1 alit S stems and Pro rams Section The, proposed change would delete the Quality Systems and Programs Section.
However, the res'ponsibilities assigned to this section are still applicable to the QA Program and therefore needs to be addressed in Chapter 17.2.,
~Res ones:
The responsibilities assigned to this section have been reassigned as follows:
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Attachment A Page 2
a.
Assisting in the development and implementation of the Operations Quality Assurance Program has been assigned to the Quality Systems and Engineering Department and is described in the revised section 17.2.1.2.1 which states in part:
"...Develop, maintain, review,- issue and/or control programs and procedures for the implementation of the APS Quality Assurance Program'."
b.
Verifying the implementation of the Operations Quality Assurance Program by 'offs'ite organizations within APS performing quality-related activities has been assigned to the Quality Audits and Monitoring Department and is described in the revised section 17.2.1.2.3 which states in part:
"...Plan and conduct periodic audits of all aspects of the Quality Assurance Program and to conduct unscheduled audits as deemed necessary to appraise quality affecting activities."
c.
Responsibility for acceptance of vendor's QA programs and audits of vendor's activities has been assigned to the Procurement Quality Department and is described in the revised section 17.2.1.2.2 which states in part:
"...Review vendor quality programs and assure proper implementation in accordance with procurement documents...."
3.
~uestion:
3, d, and 5 of the referenced letter are presented and answered as follows:
Cha ter 17.2 Section 17.2.1.2.2 PVNGS Construction A/ C Section The department that has assumed this section's responsibilities for inspection, review, monitoring, verification, and audit of quality-related construction activities during major modifications is not clear and needs to be addressed.
Cha ter 17.2 Section 17.2.1.2.3 PVNGS Start-U A/
C The reassignment of this section's responsibilities covering Phase I start-up activities is not clear and needs to be addressed.
Cha ter 17.2 Section 17.2.1.2e4 PVNGS 0 erations A/
C Section The department that has assumed this section's responsibilities covering on-site quality-related activities during operations and Phase II through Phase IV startup is not clear and needs to be addressed.
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Attachment A Page 3
a.
The Quality Systems and Engineering Department has been assigned overall responsibility to develop, maintain, review, issue and/or control the programs and procedures required to implement the Quality Assurance Program.
Specifically, the Quality Systems and Engineering Department develops inspection plans for all activities requiring such plans as described in section 17.2.1.2.1; reviews prerequisite and Phase I startup activities (programs, procedures, and test results) as described in section 17.2.1.2.1; and reviews operations and Phase II through IV startup activities as described in section 17.2.1.2.1.
b.
The Quality Control Department has been assigned responsibility to perform inspections to verify conformance of installations to requirements.
Specifically, this includes inspection of quality-related construction activities performed during operations and major modifications as described in section 17.2.1.2.4, unless those activities are performed by a constructor with an approved inspection program.
In that case, the constructor is audited and monitored by the Quality Audits and Monitoring Department as described in section 17.2.1.2.3.
c.
The'uality Audits and Monitoring Department has been assigned responsibility to perform monitoring, verification and audits of all phases of the Quality Assurance Program.
Specifically, this includes prerequisite and Phase I startup activities as well -as operations and Phase II through IV startup activities as described in section 17.2.1.2.3.
d.
The Procurement Quality Department has been assigned overall responsibility to assure procurement quality-related activities comply with the requirements of the Quality Assurance Program.
Specifically, this includes the review of procurement documents for inclusion of quality requirements, reviewing vendor, quality programs to the requirements imposed by procurement documents, and performing inspections normally associated with procurement activities as described in section 17.2.1.2.2.
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