ML19305D475
| ML19305D475 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 03/18/1980 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8004150128 | |
| Download: ML19305D475 (5) | |
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Docket Nos.: STN 50-498 MAR 18 7980 STN.50-499 Mr. E. A. Turner.
Vice President Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001
Dear Mr. Turner:
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SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW 0F THE SOUTH TEXAS FINAL SAFETY ANALYSIS REPORT (FSAR)
As a result of our continuing review of the South Texas FSAR, we find that we need additional information to complete our evaluation. The specific information required is in the area of quality assurance and is listed in the Enclosure.
Please inform us when you plan to submit your responses to this request.
If you desire any discussion or clarification of the enclosed request, please contact us.
Sincerely, U. hn-an D. Parr, Chief Light Water Reactors, Branch No. 3 Division of Project Management
Enclosure:
As stated cc: See Next Page f
800.4150128
M4R 13 79gg Mr. E. A. Turner cc: Mr. D. G. Barker Mr. Troy C. Webb Manager, South Texas Project Assistant Attorney General Houston Lighting and Power Company Environmental Protection Div.
P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Capitol Station Austin, Texas 78711 Mr. M. L. Borchelt Central Power and Light Company Mr. R. Gordon Gooch, Esq.
P. O. Box 2121 Baker & Botts Corpus Christi, Texas 78403 1701 Pennsylvania Avenue, N.W.
Washington, D. C.
20006 Mr. R. L. Hancock City of Austin Director, Governor's Budget Electric Utility Department and Planning Office P. 0. Box 1088 Executive Office Building Austin, Texas 78767 411 W. 13th Street Austin, Texas 78701 Mr. J. B. Poston Assistant General Manager for Operations John L. Anderson City Public Service Board Oak Ridge National Laboratory P. O. Box 1771 Union Carbide Corporation San Antonio, Texas 78296 Bldg. 3500, P. O. Box X Oak Ridge, Tennessee 37830 Mr. Jack R. Newman, Esq.
Lowenstein, Newman, Axelrad & Toll Resident Inspector / South Texas NPS 1025 Connecticut Avenue, N. W.
c/o U. S. NRC Washington, D. C.
20036 P. O. Box 910 Bay City, Texas 77414 Mr. Melbert Schwarz, Jr., Esq.
Baker & Botts One Shell Plaza Houston, Texas 77002 Mr. A. T. Parker Westinghouse Electric Corporation P. O. Box 355 Pittsburgh, Pennsylvania 15230 Mr. E. R. Schmidt NUS Corporation NUS-4 Research Place Rockville, Maryland 20850 Mr. J. R. Geurts Brown & Root, Inc.
P. O. Box 3 Houston, Texas 77001
ENCLOSURE SOUTH TEXAS PROJECT (50-498 & 499) 421.40 Item 421.32 will be carried as an open item.
It is the staff position that programmatic changes by the Houston Lighting & Power Company to the South Texas Project quality assurance program are to be submitted to the NRC for review prior to implementation.
Organizational changes are to be submitted no later than 30 days after announcement.
421.41 The response to item 421.34 on pages 17.2-16 and 17.2-20b and amendment 9 on page 17.2-22 (part 17.2.10.1) indicates that maintenance personnel will perform " maintenance receipt inspection (dimensional checks, electrical checks, precalibration checks, etc....)" and inspections of modifications, repairs, and rep 1acements.
It is the staff position that these inspections be performed by the Plant QA Staff in order to assure sufficient independence of the inspector from the individual whose work is being inspected and from undue influence from cost and schedule.
Revise the FSAR to meet this position or provide an alternative for our evaluation. Note this position also af.fects pages 17.2-7, 17.2-8, 17.2-21, and 17.2-23 of amendment 9 relative to authority for inspection; therefore, revise these pages accordingly.
421.42 Item f on page 17.2-21 indicates that procedures require " Timely processing of receipt inspection (generally prior to installation or use)."
It is the staff position that timely processing of receipt inspection is inspection upon receipt, and the parenthetical words tend to contradict this position.
Revise this item to reflect the staff posi+, ion.
421.43 The response to item 421.36 on page 17.2-26 indicates that procedures will provide for administrative control of radiography inspection stamps, verification of the application of welding stamps, and admin-istrative control of reject and hold tags used in the plant. Clari fy the role of the QA organization in these activities. Also, limiting the first commitment to radiography inspection stamps could mean that these are the only inspection stamps used in the plant, or it could mean that other inspection stamps are not similarly controlled.
Clarify.
421.44 Describe the qualification prerequisites for Technical Section positions which provide confidence that this section is sufficiently independent and technically qualified to adequately perform an engineering evaluation of nonconformances which are recommended to be repaired or used-as-is by the cognizant plant supervisor.
(See response to questions 421.24, 421.28, and 421.37 on page 17.2-28.)
421.45 The second paragraph of the response to item 421.38 states:
"The Plant QA Supervisor is a member of the PORC; his presence is required for a quorum.
Since PORC re' views all safety-related procedures, adequate QA review is assured."
We disagree. First, we find nothing in the FSAR that indicates that the presence of the Plant QA Supervisor is required for a quorum of
the PORC. Section 13.4.1 indicates only that " Formal meetings of the PORC require a quorum of 5 (out of 8) members" in this regard.
Second, it is the staff position that the Plant QA Supervisor, individually or through his staff, review and approve all safety-related procedures independent of the PORC, where the Plant QA Supervisor has but one vote out of five-to-eight total votes. Revise the FSAR to meet this position or provide an alternative for our evaluation.
421.46 The third and fourth paragraph of the response to item 421.38 state:
1.
...the particular individuals responsible for review and evaluation of test data will be identified in the Plant Procedures."
2.
...the particular individuals responsible for periodic surveillance of stored items will be identified in Plant Procedures."
Identify these individuals. (by position title and/or reporting relation-ship) in the FSAR.
421.47 Regarding the fifth paragraph of the response to item 421.38, we do not agree that the FSAR comitment per Revision 2 meets item 2 of acceptance criteria 14 of the Standard Review Plan (SRP). The SRP requires that " Bypassing of required inspections, tests, and other critical operations is procedurally controlled under the cognizance of the QA organization." Revision 2 of the FSAR states, in this regard, that procedures will provide " Identification of inspections,
tests, and operations which may not be bypassed without the cognizance of the plant QA staff." While the two quotations could be interpreted to mean the same thing, we think they could also be interpreted dif-ferently in that the SRP addresses procedures for QA cognizance of bypassing whereas the FSAR addresses procedures for identifying l
activities which may not be bypassed without QA cognizance. While the differences may be slight, we require that the FSAR include a clear comitment to the SRP requirement.
421.48 FSAR Amendment 9 changed the comitment to Regulatory Guide 1.33 on page 17.2-6 from Revision 2 of the regulatory guide to Revision 1.
Since Revision 1 was issued "For Comment" and Revision 2 " reflects current (2/78) NRC practice," we require a commitment to Revision 2.
Revise the FSAR accordingly.
421.49 Replace or justify the deletion of "and approval" from item 4 on page 17.2-17 which, in amendment 4, stated "Af ter QA review and approval, the requisition is returned to the Plant Superintendent or the General Manager of the Generation Engineering Department (or their respective designees) for final approval."
In lieu of " approval,"
" documented concurrence" would be an acceptable alternative.
421.50 Explain the significance of deleting ", instructions, and drawings" from the paragraph preceding 17.2.7 on page 17.2-20A which, in amendment
3-4, stated:
" Safety-related plant procedures, instructions, and draw-ings are reviewed by the Plant Operations Review Committee prior to issuance for use."
421.51 On page 17.2-26a, the first sentence is not clear and the second paragraph appears to mix "offsite activities" with "Nonconformance in the Plant." Clari fy.
421.52 Explain the significance of the changes at the middle of page 17.2-29 which amendment 9 revised from: " Corrective action for problems identified by DN's are documented by the cognizant plant supervisor on the DN form. The plant QA staff verifies that satisfactory correction action has taken place by reinspection or audit.
Un-acceptable corrective action, as determined by the plant QA staff, requires further action by the responsible supervisor and may result in suspension of the deficient activity." to " Corrective action for problems identified by DN's are determined by the cognizant plant supervisor on the DN form! The plant QA staff verifies satisfactory completion of the corrective action by reinspection or audit.
Un-l acceptable completion of corrective action, as determined by the plant QA staff, requires further action by the responsible supervisor and 1
may result in suspension of the deficient activity." Also, it is the staff position that the QA organization concur with the corrective action.
Revise the FSAR to meet this position or provide an alterna-tive for our evaluation.
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