ML18031A150

Forwards Round 2 Questions Re QA Operations

ML18031A150
Person / Time
Site:	Susquehanna
Issue date:	06/11/1979
From:	Parr O Office of Nuclear Reactor Regulation
To:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
Shared Package
ML17138A662	List: ML17138A661 ML18031A150
References
NUDOCS 7907110704
Download: ML18031A150 (7)

Text

Distribution Doc et F

e NRC PDR Local PDR LMR 83 File R.

Boyd D. Vassallo c osure:

. l illiams

0. Parr S. [liner (2)

N. Rushbrook (2)

R. h1attson D. Ross J. Knight R. Tedesco DeYoung V. 'Moore R. Vollmer t1. Ernst

.R. Denise OELD

IE (3)

M. Belke J. Gilray W. Haass Docket Nos.

50-387 and 50-388 BuN i1 1979 BCC:

JBuchanan TAbernathy ACRS (16)

Nr. Norman M. Curtis Vice President - Engineering and Construction Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101

SUBJECT:

SUSQUEHANNA STEAM ELECTRIC-STATION UNITS NOS.

1 AND 2-REQUEST FOR ADDITIONAL INFORtSTION As a result of our review of, your application for operating licenses for the Susquehanna Steam Electric Plant, we find that we need additional information in the area of Quality Assurance.

The specific information required is listed in the Enclosure.

These are round 2 questions.

Please inform us within 10 days after receipt of this letter of the date when this requested additional information will be available for our review.

Please contact us if you desire any discussion or clarification of the information requested.

Sincerely, 0dglp& 8<gned by 0- l7-Paff Oman D. Parr, Chief Light Mater Reactors Branch No.

3 Division of Project Management

Enclosure:

As Stated cc w/enclosure:

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Mr. Norman W. Curtis JUN 11 1S79 cc:

Mr. Earle M. Mead

, Project-Engineering Manager Pennsylvania Power 5 Light Company 2 North Ninth Street Al 1 entown, Pennsyl vania 18101 Jay Silberg, Esq.

Shaw, Pi ttman, Potts 8

Trowbridge 1800 M Street, N.

W.

Washington, D. C.

20036 Mr. William E. Barberich, Nuclear Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Al lentown, Pennsyl vania 18101 Edward M. Nagel, Esquire, General Counsel and Secretary Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsyl vania 18101 Bryan Snapp, Esq.

Pennsylvania Power 8 Light Company 901 Hamilton Stre'et Al 1 entown, Pennsyl vani a 18 101 Robert M. Gallo Resident Inspector P. 0.

Box 52 Shickshi nny, Pennsylvania 18655 Susquehanna Environmental Advocates c/o Gerald Schultz, Esq.

500 South River Street Wi 1kes-Barre, PA 18702 John L. Anderson Oak Ridge National Laboratory Union Carbide Corporation Bldg. 3500,,P.

0.

Box X Oak Ridge, Tennessee 37830 Mr. Robert J. Shovlin Project Manager Pennsylvania Power and Light Co.

2 North Ninth Street Al 1 entown, Pennsyl vani a 18101 Alan R.

Yuspeh, Esq.

Shaw, Pittman, Potts 8

Trowbridge 1800 M Street, N.

W.

Washington, D. C.

20036 Dr. Judith H. Johnsrud Co-Director Environmental, Coalition on Nuclear Power 433 Orlando Avenue State College, PA 16801 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Coranonwealth of Pennsylvania P. 0.

Box 2063 Harr'isburg, PA 17120 Ms. Colleen Marsh Box 538A, RD¹4 Mountain Top, PA 18707 Mrs. Irene Lemanow'icz, Chairpersor The Citizens Against Nuclear Dangers P.

0.

Box 377 RD¹1

Berwick, PA 18503

ENCLOSURE RE VEST FOR ADDITIONAL INFORMATION SUS UEHANNA STEAM ELECTRIC STATION DOCKET NOS.

50-387 AND 50-388

421. 0 421.25 (i7.2.1) 421.26 (RSP)

(i7.2.2)

UALITY ASSURANCE OPERATIONS Paragraph 17.2.1.1.1.4.1.1.1 on page 17.2-6 states the guality Supervisor is assisted by equality Specialists and engineers without identifying their reporting relationship on the appropriate organizational charts in Section 17.2 of the FSAR.

The above paragraph implies there is more than one individual performing in these positions which appears to contradict the numbers specified in Figure 13.1-7; Please correct this discrepancy.

The response to f421.14 is not totally acceptable.

Provide a description of how management (above or outside the gA organization) regularly assesses the scope,

status, adequacy, and compliance of the gA program to 10 CFR 50 Appendix B.

These measures should include:

(1)

Frequent review of program status through reports, meetings and/or audits.

(2)

Performance of an annual preplanned and documented assessment.

Corrective action is identified and tracked.

421.27 (RSP)

(17.2.2) 421.28 (RSP)

(17.2.2).

Modify your gA'program accordingly.

The response to f421.15 is not acceptable.

The NRC has not endorsed N45.2.12 Draft 4, Revision 3 and therefore

,you should commit to comply with the provisions of ANSI N45. 2. 12 Draft 3, Revision 4, 2/22/74 or ANSI N45.2. 12 Draft 4, Revision 2, 1/1/76 as supplemented by regulatory position C.4. of Regulatory Guide 1.33, Revision 2 (2/78).

Any exceptions and/or alternatives to these controls should be described in sufficient supporting detail to allow for NRC evaluation and acceptance.

Modify your gA program accordingly.

The response to f421.16 requires clarification concerning the qualification requirements for individuals performing certain gA functions during the operational phas'e of your plant.

Our position is as follows:

(1) The individuals performing inspection, examination and testing functions associated with normal operations of the plant, such as surveillance testing, routine maintenance and certain technical reviews normally assigned to the onsite operation organization shall be qualified to ANSI.N18.1-1971.

421-2 421.29 (RSP)

(17.2.2) 421.30 (17.2.3) 421. 31 (17.2.6) 421. 32 (17.2.6) 421.33 (17.2.6) 42'l.34 (17.2.7) 421.35 (17.2.9)

(2)

Personnel whose qualifications are not required to meet those specified in ANSI N18.1 and who are performing inspection, examination and testing activities during the operational phase of the plant shall be qualified to ANSI N45.2.6-1973 except that the gA experience cited for Levels I, II, and III shall be interpreted to mean actual experience in carrying out the types of inspection, examination and testing activity being performed.

This position is consistent with ANSI N18.7-1976, "Administrative Controls and guality Assurance for the Operational Phase of Nuclear Power Plants,"

Section 3.4.2.

Modify your gA program accordingly to address this staff position.

The response to f421.20 is not acceptable.

Describe provisions to notify the NRC of changes (1) to the accepted SAR gA program description prior to implementation, and (2) to organizational elements within 30 days after announcement.

(Note - editorial changes or personnel reassignments of a non-substantive nature do not require NRC notification.)

Modify your gA program accordingly.

Describe measures to assure that responsible plant personnel are made aware of design changes/modifications which may affect the performance of their duties.

Clarify whether the Manager-Nuclear guality Assurance reviews and concurs with changes to the onsite gA program.

Describe provisions which assure that maintenance, modification and inspection procedures are reviewed by qualified personnel knowledgeable in gA disciplines (normally the gA organization) to determine that the necessary inspection requirements,

methods, and acceptance criteria have been identified.

Describe measures to assure that the gA organization or an individual qualified in quality assurance but other than the person who generated the document, reviews and concurs with the documents and changes thereto with regards to gA-related aspects to assure technical adequacy and inclusion of appropriate quality requirements prior to implementation.

Such documents as a minimum include:

design, procurement, as built drawings, gA/gC manuals, SAR, nonconformance reports and instructions and procedures for inspection and testing.

Describe the organizational responsibilities for the control of purchased

material, equipment, and services including the interface responsibilities of the gA organization relative to procurement.

Describe the criteria for determining those processes that are controlled as special processes.

As complete a listing as possible of special processes, which are generally those processes where direct inspection is impossible or disadvantageous, should be

421-3 421. 36 (i7.2.io) 421.37 (17.2.10) provided.

Some examples are welding, heat treating, NDT, and chemical cleaning.

Describe measures which assure that program procedures provide

'criteria for determining the accuracy requirements of inspection equipment and criteria for determining when inspections and tests are required.

Describe provisions to assure that inspection procedures, instructions, or checklists provide, as required, for the following:

(1) Identification of required procedures, drawings and specifications and revisions.

421.38 (17.2.io) 421.39 (17.2.12) 421.40 (17.2.13)

(2) Specifying necessary measuring and test equipment including accuracy requirements.

Describe measures which assure that inspection results are documented, evaluated and their acceptability determined by a responsible individual or group.

Describe the organizational responsibilities for establishing, implementing, and assuring effectiveness of the calibration program.

Describe the provisions established for the storage of chemical, reagents (including control of shelf life), lubricants, and other consumabl e material s.

421. 41 The responses to the 421 series of questions appear to be separated from Section 17.2 of the FSAR.

Incorporate or reference all responses to these QA questions in Section 17.2 of the FSAR. It is further requested that a statement be provided whereby the responses to Q421.1 and Q421.2 supersede previous submittals relative to QA for fire protection.