ML19263D008
| ML19263D008 | |
| Person / Time | |
|---|---|
| Site: | Millstone, 05000496, 05000497  |
| Issue date: | 03/09/1979 |
| From: | Counsil W NORTHEAST UTILITIES |
| To: | Haass W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19263D009 | List: |
| References | |
| TASK-17, TASK-RR QA-3071, NUDOCS 7903200421 | |
| Download: ML19263D008 (5) | |
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March 9, 1979 Mr. Walter P. Haass, Chief Quality Assurance Branch Division of Project Management U. S. Nuclear Regulatory Commission Washington, D. C.
20555 QA-3071
Dear Mr. Haass:
Subject:
Northeast Utilities Quality Assurance Progran Tonical Renort Northeast Utilities hereby submits 26 copies of Revision 3 to the Northeast Utilities Quality Assurance Program Topical Report HU-QA-1.
The Topical Report was originally submitted February 1, 1978, by letter, QA-2476; revised May 26, ]978, by letter, QA-2679, as Revision 1; and revised on October 23, 1978, by letter, QA-2868, as Revision 2.
The responses to the 13 questions in your letter of December 21, 1978, are stated in an enclosed separate document. Northeast Utilities position for each question is reflected in this document, which references, as applicable, the section of the Northe st Utilities Quality Assurance Topical Report which is affected by the response.
Revision 3 is being submitted as a complete replacement to the Northeast Utilities Quality Assurance Topical Report previously submitted. The changes in the Topical Report are indicated by a vertical line in the margin.
Very truly yours, I
9Il
}[ML William G. Counsil Vice President Nuclear Engineering & Operations Enclosures 7s03200 @
RESPONSES TO THE NUCLEAR REGULATORY COMMISSION LETTER OF DECEMBER 21, 1978 The enclosed is the response to the Nuclear Regulatory Commission letter containing the (13) questions from W. P. Haass, Chief Quality Assurance Branch Division of Project Management, to D. C. Switzer, NU Vice Chairman, dated December 21, 1978.
Question 1:
With regard to your response to question 6 of our August 3, 1978, letter, we understand that, thus far in your ongoing detsiled review of these later QA Regulatory Guides, you do not anticipate functional probls s in inplementing the regulatory positiens of these guides. We understand, hcVever, thst since sc=e of these may impact upon vork of your present agent (Stone & Webster) on Millstone Unit 3, you may or may not find it necessary to notify us of sc e excepticns. Should such be the case, please specify the exceptions and provide and justify alternate solutions in equivalent detail.
Response
We have revised the applicable sections and Appendix D to the Topical Report in order to reflect the cenrittent to the specific revisions of the regulatory guides as requested in your August 3, 1978, letter.
Question 2:
Your response to questien 17 is acceptable if the word
" designee" used in the phrase " Manager QA/ designee" in the third paragraph of the Introduction and elsewhere means that the designated person (designee) is a direct e=ployee of the Maneger of QA.
Re_spons e :
The word " designee" can either te an employee of the Manager of Quality Assurance, as well as, the respective NUPOO QA/QC Supervisors A definition of 'S!anager f QA/ Designee", has been included in Appen-dix E of the Topical Report to indicate this is the case.
Questien 3:
The staff's position on your respense to questien 20 is the same as that for question 6; namely, verk perforned after NRC acceptance of the topical report should meet the regulatory positions of the Regulatory Guides listed in question 6, as well as the requirements of the ANSI Standard listed in question c.
Respense:
The fifth paragraph of Section 3.1 in QAP 3.0, has been rodified to te consistant with the design review revision of Regulatory Guide 1.6h, Revision 2.
Question L:
Your response to question 25 is unacceptable.
It is the staff's position that the QA organization should approve procurement orders to any organization (e.g., supplier) that has not been previously approved by the QA organization.
Response
The second paragraph of Sectica L.2.3 in QAP h.0, has teen modified to indicate that the QA crganization does approve procurement documents issued to any organization (e.g.,
supplier) that has not been previously approved by the QA organization.
Question 5:
Your response to question 26 is acceptable except that the response should specify Appendix D in lieu of Appendix C.
Response :
Section h.2.2, Iter C as refered to in question 26, has been modified to specify Appendix D in lieu of Appeniix C.
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Caestion 6:
Your response to question 27 is satisfactory except for drawings.
It is the staff's position that the QA organization, or an independent organization qualified in quality arsurance, must review and concur with these documents with regard to QA-related aspects. Thus, with regard to design drawings or changes thereto on d7/awings generated by NUSCO and/or NUPOC, describe the controls implemented by NUSCO to ensure inclusion of proper quality requirements in drawings, e.g., provisions for accessability and inspectability.
Response
Section 5.2.2 in QAP 5.0 has been modified regarding NUSCO/
NUPOC review and concurring with design drawings or changes thereto.
Question 7:
Please clarify your response to question 36, i.e., What is meant by " qualified personnel representing NUSCO/NUPOC Quality Assurance?" Your response is acceptable if it means " qualified NUSC0/NUPOC Quality Assurance personnel."
Restonse:
The question of " qualified personnel representing NUSCO/NUPOC Quality Assurance", does indeed mean " qualified NUSCO/NUP0C Quality Assurance personnel in the QA Department.
Question 8:
Your response to part a of question h3 is acceptible.
- However, your response to part b is unacceptable inasmuch as it does not indicate any involvement of the QA organization in controlling the release of nonconfinning items and in the concurrence of dispositions. The only apparent involvement of QA is in an audit role. The staff's position is that the QA organization should (1) concur in disposition of nonconformances and in decisions relative to release of nonconforming items prior to their disposition; or (2) should provide acceptable alternatives.
If the latter, please describe.
Response
The second paragraph of Section 15.2.4 in QAP 15 0 has been modified to include the following, "to the NUSCO Site Manager or the appropriate NUFOC Superintendent and NUSCO/NUPOC QA organization, as applicable".
Question 9:
Your response to question hh appears acceptable except that the word " items" should be changed co " reports." Also, please clarify whether or not the " materials receipt records" constitute part of the inspection records.
Response
The second paragraph of Section 15.2.4 in QAP 15.0, has been modified to change the word " items", to " reports" and
" materials receipt records", to be changed to " material receipt inspection records".
Question 10:
Your response to question h6 needs clarification. Please delete the word " major" or otherwise clarify what is meant by " major".
Response
The word " major", proceeding modification, has been removed from Section 17.1 of QAP 17.0.
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e Question 11:
Your response to question 49 is not acceptable.
It is the staff's position that all internal elements of the QA Program be audited at least annually in accordance with the requirements of ANSI Nh5.2.12, Draft 3, Revision 4, February, 1974.
Resnonee:
Section 18.2.1.a of QAP 18.0, has been modified to include the following, "(Annual audits of the 18 Criteria of Appendix B 10CFR Part 50)".
Question 12:
Please correct the grammatical problems in the first paragraph, page 3 of QAP 2.0.
Response
1..e gra=matical problems in the first paragraph of Section 2.2.2 in QAP 2.0, has been revised to read., "These procedures are reviewed by the departments which are responsible for portions of these procedures. These procedures are approved by the departrents which initiate the procedure and are re-viewed and concurred with by the Manager of Quality Assurance for compliance with the NU QAP. Changes to procedures are subjected to the same degree of control as that utilized in the preparation of the original dccunent".
Question 13:
Please reinstate Appendix B to 10CFR Part 50 in the fourth paragraph of 2.2.h of the topical report or justify its revision.
Response
The fourth paragraph of Section 2.2.h in QAP 2.0 has been modified to reinstate the words, " Appendix B to 10CFR Part 50,"
after the words, " applicable requirements"; and after,
" alt ernative to".
References to NU QAP shall be deleted.
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