ML19242B178

Responds to 790724 Discussions W/Nrc.Forwards Addl Info Re QA Policy Document Amend 39,Section 8

ML19242B178
Person / Time
Site:	Cooper
Issue date:	08/02/1979
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Ippolito T Office of Nuclear Reactor Regulation
References
NUDOCS 7908070625
Download: ML19242B178 (5)

Text

.so- e f GENE R AL OF F ICE 67 fp; L j' Nebraska Publ.ic Power D.

is trict P. O. DO X 4 99, C O L U f.1 HUS. N E h N AS K A 68601 memONc son smeso La z -- - -

August 2, 1979 Director, Nuclear Reactor Regulation Mr. Thomas A. Ippolito, Chief Operating Reactors Branch No. 3 Division of Operating Reactors U.S. Nuclear Regulatory Commiss1Un Washington, DC 20535

Subject:

Request for Additional Infoi ation Cooper Nuclear Station NRC Docket No. 50-298, DPR-46

Dear dr. Ippolito:

Based on discussions with the Regulatory Staff on July 24, 1979 requesting additional information on Sections S.2 and 8.6 of Amendment 39 to the Cooper Nuclear Station Quality Assurance Policy Document, the exceptions noted in our submittal dated May 24, 1979 have been revised and are submitted as Enclosure I of this letter. Revisions to the submittal of May 25, 1979 are indicated by a bar .'.n the right hand margia.

Should you have any questions or require addi tional clarification regarding Section 3.0 to Amendment 39, please contact me.

In addition to one original, 39 copies of this information are also submitted.

Sincerely, h

M

-BD J a;. .. Pilant ,, I 's Director of Licensing C,'{ b and Quality Assurance J FEW/cl Enclosure 790807m>cG2s

Thomas A. Ippolito August 2, 1979 Paga ?

STATE OF NEBRASKA )

) ss PLATTE COU'ITY )

Jay M. Pilant, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements in said application are true to the best of his knowledge and belief.

W

\MM\ Pilant Subscribed in my presence and sworn to before me this [ day of August, u 79.

NOTARY PUBLIC

/

My Cocaission expires / h

& mtm mm. ms er seemte 5 MARLYN R. HOHNDORF kb afy Caeta. Esp. oct. 14,1980

_s ,

NRC REQUEST FOR ADDITIONAL INFORMATION RE: QA PROGRAM 7/24/79 Item 24A (Section 8.2)

Provide a commitment that work instructions are reviewed by the QA or QC organization to assure among other things the adequacy of cleaning requirements and access control, or provide an alternative for our evaluation.

Response to Item 24A See Enclosure I (; age D-9-81)

Item 29A (Section 8.6)

It appears that the second part of item 29 was r.at responded to.

Please specify the qualification and/or organization of the individual or indiviuuals who evaluate instrumentation, evaluate material accept-ability, specify design mixes, evaluate results of cylinder tests, and inspect batch plant controls.

Response to Item 29A See Enclosure I (page D-9-85) 522 302

Enclosure I of the overall work instructions. System cleanness is controlled at CNS by the followir.g methods:

1) Parts and components are checked for cleanness during receipt inspection and stored in a manner that will ensure adequate levels of cleanness are being maintained.

2) Work instruction will be reviewed by Quality Control to assura that adequate cleaning and access controls are incorporated into work instruction and associated safty-related activities.

3) Parts and components are inspected for cleancess prior to instal-lati t in accordance with CNS maintenance procedures.

4) The work area is maintained at a cleanliness level appropriate to the maintenance or modification activity being performed.

5) Quality Control inspections before, during and after safety-related maintenance or modification activities address system cleanness.

6) Random QA audit and surveillance of safety-related mair tenance or modification activities requires verification cf part, com-ponent and system cleanness.

Criteria for Cleaning (Section 3)

For cleanness classifications where the scope of plant modification work is such as to make application of the guidance provided by this standard practicable, the cleanness classifications and requirements thereof shall be evaluated and applied, as appropriate, as a part of the overall work requirements.

For most modification or maintenance work, hosever, involving only small portions or individual components of larger systems, it is not considered practicable to conduct cleanness tests with ASTM Ell-70 Series. Appropriate cleanness will be maintained during the work and preoperaticnal flushing will be conducted, consistent with t' e scope of the work performed and the original design requirements.

Flushing is an additional precaution to insure system cleanness.

Controlling the parts and components and the work area has provided CNS with reasonable levels of assurance that system cleanness will be maintained. In addition to the above, the Water Chemistry Depart-ment routinely samples and tests for system clec ,liness, corrosion, crud build-up etc.

8.3 ANSI N45.2.2 Packaging, Shipping, Receiving, Storage and Handling of Items fer Nuclear Power Plants. (During the Construction Phase)

(a) Scope and Applicability 522 303 The guidance provided by this standard and the associated Regulatory Guide 1.38 shall be applied to packaging, shipping, receiving, storage and handling activitiea associated with safety-related items except as noted below.

D-9-81

Personnel Qualifications (Section 2.4)

The Operational QA Program includes provisions for ensuring that qualified personnel are assigned to monitor work activities.

(Please refer to Section 8.7 of this document.)

Calibration and Control (Section 2.5.2)

The requirements of control and calibration of measuring and test equipment set forth by this standard shall be applied to all measur-ing and test equipment used by NPPD or their agents, test labora-tories and contractors. Such requirements, however, will not be imposeo on commercial batch plant facilities. Instrumentation at commercial catch plant facilities will be evaluated by CNS plant management to determine that sufficient accuracy can be obtained and will be verified by an independent QA audit.

Qualification Tests (Section 3.2.1)

For small quantities of concrete involved in modification work, all concrete must be purchased from commercial concrete batch plants.

For small quantities of concrete, it is unreasonable to expect cos-mercial facilities to shut down normal operations to provide cer-tified aggregate, cement, admixtures, fly ash, water, etc. In this respect, the qualification tests required by Table A for aggregate; cement; admixtures; fly ash and pozzolans; water and ice wi.ll not be required. Appropriate evaluations will be made to determine that good quality and generally acceptable materials are used. CNS plant management evaluation, coupled with slump tests, air entrainment teste and concrete cylinder strengths, will provide adequate control and qualification of the concrete. The results of evaluation will be verified by an independent QA audit.

Design mixes consistent with, or equivalent to, original requirements will be specified and the results of the cylinder tests will be evalu-ated by CNS plant management based on the acceptance criteria associated with the original design mix requirements and will be verified by an independent QA audit.

Protection of Materials (Section 4.2)

The inspection requirements of Section 4.2 will not generally be performed, as the small quantities of concrete involved in modifi-cation work will no doubt be mixed using materials already in the batch plant bins. Control of storage of materials would not be practicable.

Measuring, Mixing and Transporting (Section 4.3) 577 - "04 7

If available, appropriate certifications shall be obtained from the concrete suppiier which verify the adequacy of truck mixers per the requirements of ACI-304, ASTM C-94. Where certifications are not avail-able, two concrete test cylinders representing the first and last one-third of truck mixer contents shall be taken for evaluation of the mixer truck, over and above the normal concrete cylinders taken to evaluate the inplace concrete. The concrete batch plant facility shall be inspected by CNS plant management and the CNS QA staff to assure that reasonable controls are being exercised with reference to the inspection guidelines set forth by Section 4.3(1) and (2).

D-9-85