ML19261C771
| ML19261C771 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 03/13/1979 |
| From: | Ippolito T Office of Nuclear Reactor Regulation |
| To: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| References | |
| NUDOCS 7904020151 | |
| Download: ML19261C771 (7) | |
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UNITED STATES l',
NUCLEAR REGULATORY COMMisslON f,
,C 1 j WASHINGTON, 0. C. 20555 E
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MARCH 1 3 1979 Docket tio. 50-298 Mr. J. M. Pilant, Director Licensing & Quality Assurance fiebt aska Public Power District P. O. Box 499 Columbus, fiebraska 68601
Dear Mr. Pilant:
We have been reviewing your submittals of flovember 9,1978, December 21, 1 978, and January 9,1979, dealing with the quality assurance program of the Cooper tiuclear Station. As a result of our review, additional information is required with respect to exemptions you propose to take relative to NRC guidance on quality assurance.
This information is identified in Enclosure 1.
Your response to this letter is requested within 60 days of its receipt.
Sincerely, l! &/
m' homas A. Ip olito, Chief Operating Reactors Branch #3 Division of Operating Reactors
Enclosure:
Request for Additional Information cc w/ enclosure:
see next page 790402015/
v 6
Nebraska Public Power District CC Mr. G. D. Watson, General Counsel Nebraska Public Power District P. O. Box 499 Columbus, Nebraska 68601 Mr. Arthur C. Gehr, Attorney Snell 3 Wilmer 3100 Valley Center Phoenix, Arizona 85073 Coope; Nuclear Station ATTH: Mr. L. Lessor Station Superintendent P. O. Box 98 Brownville, Nebraska 68321 Auburn Public Library 118 - 15th Street Auburn, Nebraska 68305 4
RQUEST FOR ADDITIONAL INFORMATION COOPER NUCLEAR STATION (SECTION 8.0 0F FSAR AMENDMENT 39)*
20.
It appears that ' : tion 8.0 of FSAR Amendment 39 should address Regulatory Guide 1.33 (Safety Guide 33 per the Orange Book).
Also, unless the intent is to update to later cuidance, Section 8.10 should be addres;ed as ANSI N45.2.10-1973 (vice 1976) and Section 8.12 should be addressed as ANSI N45.2.12 Draf t 3, Revision 4, February 1974 (vice 1974).
Please clarify.
2'.
Please clarify the first sentence of the last paragraph on page D-9-80.
If, as it appears, a period belongs after Appendix B, explain what is meant by "To the extent that ANSI N45.2 parallels that NRC regulations (s),
the CNS QA Program conforms to this ANSI Standard." The introductory phrase appears to negate the commitment to confom.
22.
The performance of "First Level" inspection by individuals who report directly to the immediate supervisor responsible for the work being inspected is acceptable only under the controls noted in item 32, belcw.
The first paragraph on page D-9-81 should be revised to reflect this position.
23.
The statements listed below require clarification or expansion.
If they mean that because of the noted exceptions the detailed guidance is not addressed, they should be so clarified.
If, however, they mean there are additional exceptions, then they should be expanded to identify what these exceptions are.
a.
Existing program requirements do not necessarily address all of detailed quidance set forth in ANSI N45.2 (mid page D-9-81).
b.
It is not intended that the QA program requirements eJdress all of the detailed guidance set forth in ANSI N45.2.4 (lower page D-9-88).
c.
It is not intended that the QA program requirements address alJ of the detailed guidance set forth by ANSI N45.2.8 (top page D-9-96).
d.
It is not intended that the QA program address all of the detailed guidance set forth by this (N45.2.ll) standard...
(bottom page D-9-98).
Please clarify or' expand these statemenos.
Confomance is expected unless specific exceptions, modifications, or clarifications are presented.
- Questions 1 through 19 were transmitted by NRC letter to NPPD dated September 18, 1978
- 24. Describe measures which ensure that cleaning requirements and access control are considered during the preparation of overall work instructions as noted in the first paragraph on page D-9-82.
25.
The practicality of conducting ASTM Ell-70 cleanness tests for work involving small portions of systems is discussed under " Criteria for Cleanino" on r ge D-9-82.
If flushing is the only practical means of determini a fstem cleanness after such work, please describe how system cleanness is evaluated without using ASTM Ell-70.
26.
Under the heading " Implementation" on page D-9-84, please provide assurance that the specific review which is mentioned considers the need for any special packaging, shipping, receiving, storage, and handling which may be required per ANIS N45.2.2 for the item (s) being pur-chased and that such needs are incorporate in the purchase order documents.
d 27.
Under the heading " Implementation" on page D-9-85, please provide a completion date for the review and revision, where required, of main-tenance procedures regarding housekeeping. Also provide a statement that ANSI N45.2.3 will be the basis for determining housekeeping controls.
28.
It appears that the reference to Regulatory Guide 1.97 near the middle of page D-9-89 should be to Regulatory Guide 1.94 and the reference to Section 7.7 near the middle of page D-9-90 should be to Section 8.7.
Please clarify.
29.
Please indicate what specific requirements of Section 2.5.2 of ANSI N45.2.5 are not being imposed on commercial batch plant facilities.
Also, specify the qualification requirements of the individual (s) who evaluates instrumentation as noted at the bottom of page D-9-90, who evaluates material acceptability as noted in the first paragraph on page D-9-91, who specifies design mixes and evaluates results of cylinder tests as noted in the second paragraph on page D-9-91, and who inspects batch plants controls as noted in the first paragraph on page D-9-92.
30.
Under the heading " Implementation" on page D-9-93, please delete the words "the intent of" so that the commitment is auditable.
- 31. The scope and applicability of ANSI N45.2.6-1973 should be expanded to include maintenance, repair, and operation as well as modifications.
Please revise the sentence at the middle of page D-9-93 to so. indicate or provide an alternative for our evaluation.
32.
Regarding the " Specific Exceptions" taken to ANSI N45.2.6 (pages D-9-93 and D-9-94), the' staff position is as follows:
Verification (by inspection, surveillance, or witnessing) a.
associated with normal operations of the plant (such as routine maintenance and tests) may be performed by individuals from the same group as those who performed the work provided
- 1) The verifier did not perform or directly supervise the work,
- 2) The quality of the work will be demonstrated by a functional test if a pressure boundary has been breached, and 3)
The verifier's qualifications are reviewed and found acceptable by the QA organization prior to initiating the verification.
b.
Individuals performing verification functions associated with normal operations of the plant (including certain technical reviews assigned to the onsite operation organization) are qualified to ANSI N18.1-1971, c.
Individuals whose qualifications are not required to meet those in ANSI N18.1-1971 and who perform verification activities shall be qualified to ANSI N45.2.6-1973 except that the QA 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.
Please revise your " Specific Exceptions" to r,eet the above position or provide specific alternatives to specific requirements for the staff's evaluation.
Note that your response will probably cause some revision to tha " Implementation" sentence on the bottom of page D-9-94 as well as to the " Personnel Qualification" sentence at the middle of page D-9-90.
33.
It appears the middle paragraph on page D-9-95 should refer.to mechanical equipment instead of electrical. equipment.
Please clarify.
- 34. The description of the " Scope and Applicability" of ANSI N45.2.9 at the middle of page D-9-96 starts, " Consistent with the implementation date set forth below...." However, there appears to be no date given.
Please clarify.
35.
Please delete "the intent of" (2_plac.es) from.the last sentence on page D-9-97.
There should be agreement of definitions, but insignificant word changes are acceptable.
36.
Your audit scheduling which provides for applicable elements of the QA program to be audited at least once every two years (per mid page D-9-99) is unacceptable.
It is the staff position that audit schedules must meet Regulatory Position 4 of Regulatory Guide 1.33, Revision 2'.
Please revise Section 8.12 (b) accordingly.
37.
The restrictive po.rtion of the first sertence discussing the " Scope and Applicability" of ANSI N45.2.13:
"To the extent that the information set forth by this standard provides useful and practical guidelines...,"
(mid page D-9-100) is unacceptable because it implies that some of the
_4_
guidelines may not be useful and practical without identifying such guidelines.
Pleas.e revise this paragraph to indicate that the guide-lines of the standard will be applied except as noted.
Similar words:
"to the extent that these documents provide practical guidelines..,," appear at the top of page D-9-79, and they are unacceptable for the same reason.
Please revise the paragraph to indicate the guidance will be followed except as noted.
38.
It is not clear what is meant by "but on a much less restrictive basis,"
(upper page D-9-101) relative to procurement sour ;e evaluation.
Please describe measures which will be used to evaluate procurement sources under the circumstances noted.
39.
The staff position is that there be objective evidence of bid evaluation per Section 5.2 of ANSI N45.2.13.
Please revise the statement at mid page D-9-101 to dest.'ibe how this staff position is met.
Also modify the last paragraph on page D-9-100 to be consistent with the revised s tatement.
40.
It is not clear how Section 6.2 of ANSI N45.2.13 is being tied into Section 5.3 of ANSI N45.2.13 at the bottom of page D-9-101.
Please clarify.
For example, if the extent of preaward evaluation depends on the complexity or scope of the item or service, so state.
41.
At the top of page D-9-102, please include a description of which-criteria for certifications of confonnance from Section 10.2 of ANSI N45.2.13 will (may) not be used for the purchase of off-the-shelf items and simple spare parts. This should eliminate the need for the last sentence of the paragraph.
42.
With respect to ANSI N18.7 (top of page D-9-103), please revise the first sentence such that it provides a commitment to meet this standard except as noted.
Then identify any details of the standard which are not being met and describe how the operational QA program addresses the item.
The example given is acceptable, but the portion of the standard not being met as per the example should be identified.
That is, identify the source of the requirement for "a matrix which indexes documents to the requirements of N18.7."
- 43. On page D-9-94 provide a statement that all nondestructive examinations are performed by personnel who are qualified and certified per. SNT-TC-1 A.
44.
The applicability of most of the ANSI standards discussed in section 8 of the quality assurance program includes the caveat. "to the extent that such activities a're comparable in nature and degree to similar activities occurring during the design and construction phase."
With respect to this caveat, the staff position is as follows:
a.
Technical requirements associated with maintenance and modifications can be the original requirements or better, (e.g., code requirements, material properties, design margins, manufacturing processes, and inspection requirements).
b.
Programmatic / administrative quality assurance requirements contained in the standards shall apply to the maintenance and modification activities even tiisigh such requirements were not in effect originally.
Commit to meet this staff position or provide an alternative for our evaluation.
.