ML19309B300

Forwards Request for Addl Info to Complete Review of QA Program

ML19309B300
Person / Time
Site:	Wolf Creek
Issue date:	03/20/1980
From:	Parr O Office of Nuclear Reactor Regulation
To:	Koester G KANSAS GAS & ELECTRIC CO.
References
NUDOCS 8004040016
Download: ML19309B300 (6)

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Docket No.

STN 50-482 MAR 2 01980 Mr. Glenn L. Koester Vice President - Operations Kansas Gas & Electric Company 201 North Market Street Wichita, Kansas 67201

SUBJECT:

QA PROGRAM FOR DESIGN CONSTRUCTION AND FIRE PROTECTION We have completed our review of the Wolf Creek Plant specific quality assurance program description included in the SNUPPS submittal of December 20, 1979.

From our review we have determined that we need additional informa-tion as set forth in Enclosure 1.

Questions regarding the SNUPPS portion of the December 20, 1979 submittal were forwarded to SNUPPS (Mr. N. A. Petrick) by letter dated January 22, 1980.

Additionally, as a result of our review of your Fire Protection Quality Assurance Program also forwarded in the SNUPPS submittal of December 20, 1979, we find that we need additional information as set forth in Enclosure 2.

Please notify us as to when we can expect responses to this request for in formation.

If questions arise regarding this reqwt, please contact us.

Sincerely, b [A an

. Parr, Chief Light Water Reactors Branch No. 3 Division of Project Management

Enclosures:

As stated I

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Mr. Glenn L. Koester MAR 2 01980 cc: Mr. Nicholas A. Petrick Executive Director, SNUPPS Ralph Foster, Esq.

5 Choke Cherry Road Kansas Gas & Electric Cenpany Rockville, Maryland 20850 P. O. Box 208 Wichita, Kansas 67201 Gerald Charnoff, Esq.

Shaw, Pittman, Potts, William H. Ward, Esq.

Trowbridge & Madden NACEA 1800 M Street, N. W.

5130 Mission Road Washington, D. C.

20036 Shawnee Mission, Kansas 66205 Mr. Donald T. McPhee Ms. Treva Hearne, Assistant General Counsel Vice President Public Service Commission Kansas City Power & Light Company P. 0.' Box 360 1330 Baltimore Avenue Jefferson City, Missouri Kansas City, Missouri 64141 James T. Wiglesworth, Esq.

9800 Metcalf Suite 400 a

General Square Center Overland Park, Kansas 66212 Mr. William H. Griffin, Esq.

Assistant Attorney General State of Kansas State House Topeka, Kansas 66612 Mr. John M. Wylie II Energy Reporter Kansas City Star 1729 Grand Kansas City, Missouri 64108 Mr. Gary Haden Wichita Eagle & Beacon Box A Wichita, Kansas 67201

Ef4 CLOSURE 1 WOLF CREEK GENERA 7IfiG STATION (StiUPPS)

Request for Additional Information 1.

Reinstate or justify the deletion of "The committee shall prepare a response to the citation and initiate appropriate corrective action or verify that proper corrective action has already taken place" from the fourth paragraph in 17.1.1.1.3 (page 17.1-7).

2.

Since the QA program for the operations phase is described in the FSAR for Wolf Creek, delete the last sentence from 17.1.1.7 (page 17.1-8) which states:

"The Plant Staff will be risisted by at least one quality assurance engineer stationed at the plarc."

3.

The description of the QA program for the Wolf Creek Generating Station refers to PSAR Section 17.1.

(See the third paragraph on page 17.1-17 for example.) Since the SNUPPS submittal of December 20, 1979 includes the

" Quality Assurance Program for Design and Construction," which updates PSAR Chapter 17, change references to PSAR Section 17.1 to reference the appropriate sections of this later QA program description.

4.

The fourth paragraph on page 17.1-17 and the first and fifth paragraphs on page 178-9 refer to Table 3.2-1 of the Standard Plant PSAR for the identification of safety-related items.

However, page 17.1-10 of the Wolf Creek portion of the December 29, 1979 submittal also refe'rs to Section 3.8.4 of the Wolf Creek portion (or addendum) of the PSAR.

It appears that the three aforementioned paragraphs should also refer to Section 3.8.4.

Please c? srify.

5.

Reinstate or justify the deletion of " inspection trip repor u" from the records to be furnished by Bechtel and Westinghouse as per the last paragraph on page 17.1-56.

6.

Item (i) at the top of page 178-4 indicates that the Daniel Regional QA Manager is responsible to review and concur with the QA program of selected suppliers, while item (j) at the middle of page 178-8 indicates that the Daniel Quality Control Manager is responsible to review the QA/QC programs of suppliers.

Clarify that the QC Manager's review of QA programs of suppliers cut selected for review and concurrence of the Regional QA Manager includes the concurrence responsibili ty.

7.

Explain the deletion of procedures for controlling special processes from part 178.1.1.2 responsibilities of Technical Services.

8.

Discuss the significance of changing " decisions" to " problems" in part (d) at mid page 178-5 and part (g) at mid page 178-8.

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Explain the significance of deleting " certification of the assigned construction" from the responsibilities of the Daniel Quality Control Manager at the bottcm of page 17B-7.

10.

Explain the significance of the change to the second paragraph of 178.1.2 from " Prior to issuance, all procedures and instructions are fonvarded to KG&E for review and final approval." to " Prior to issuance, procedures are forwarded to KG&E for review and final approval."

11 Delete or justify the addition of ' inadvertent" to the second sentence on page 178-18 which states " Identification and control measures shall be provided to prevent the inadvertent use or installation of incorrect or defective material, parts, and ccmponents."

12.

The fire protection OA program for the Wolf Creek Generating Station is not clear. While providing a general commitment to selected portions of the over-all QA program (the reference to " Chapter 17.0 of this PSAR Addendum" should be changed to reflect the SNUPPS submittal of December 20, 1979 as in item 4 above), part 17C then limits the commitments such that the general commitment appears meaningless, and the limiting comitments do not appear to be completely responsive to Mr. Vassallo's letter of August 29, 1977.

Please clarify.

13.

Discuss how the QA program for non-Category I Seismic Systems provided in part 17C of the Wolf Creek submittal meets the pertinent QA requirements of Appendix B to 10 CFR Part 50.

ENCLOSURE 2 g

Callaway Plant &

'lolf Creek Generating Station Questions on Fire Protection QA Procram 1.

For design and installation activities after receipt of the Vassallo letter of August 29, 1977, include a connitment in the second paragraph of criterion 2 that these activities will be accomplished in accordance with documented instructions, procedures, and drawings.

2.

Provide a statement under the third paragraph of criterion 2 that " appropriate fire protection requirements" include such things as precautions, control of ignition sources and combustibles, provisions for backup fire protection if the activity requires disabling a fire protection system, and restriction on material substitution unless specifically permitted by design and confimed by design review.

3.

Ur. der criterion 4.0, " Inspection," provide a commitment that inspections related to the fire protection program include the energency lighting and communication equipment.

4.

The third paragraph under criterion 4 states that " Inspections are (or "will be") performed by individuals other than those who perfomed the activities being inspected."

It is the staff position that these inspections be per-formed by QA personnel 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.

Commit to meet this staff position or provide an alternative for our evaluation. Also provide a commitment that the inspection personnel are knowledgeable in the design and installation require-ments for fire protectien.

5.

Under criterion 4.0, " Inspection." provide a commitment that the QA program for fire protection includes ins,9ection procedures,

instructions, and check lists which provide for:

a.

Identification of characteristics and activities to be inspected; b.

Identification of the individuals or groups responsible for performing the inspection operation; c.

Acceptance and rejection criteria; d.

A description of the method of inspection; e.

Recording evidence of completing an/ 9tifying a manufacturing, inspec-tion or test operation; and f.

Recording inspector or data

• et yb ;nd the results of the inspection operation.

6.

Under criterion 4.0, " Inspection," include a ctc.mitment that periodic inspec-tions of fire protection systems, emergency breathing and auxiliary equipment, 1

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emergency lichtina and communication equipment '.1'.i t.i. m e t: assure tnc acceptable condition of these items.

7.

Under criterien 5, " Test and Test Control," pre.nds a.c.*zints to the f allowing :

A test prograa shall be established and implemented to assure that testing is performed ed verified by inspection and audit to demonstrate conformance with design and system readiness requirements. The tests are performed in accordance with written test procedures, and test results are properly evaluated and acted on. The test program includes a.

Installation Testing - Following construction, modification, repair or replacement, sufficient testing is performed to demonstrate that fire protection systems, emergency lighting and comunication equip-ment will perform satisfactorily in service and that design criteria are met. Written test procedures for installation tests incorporate the requirements and acceptance limits contained in applicable design documents.

b.

Periodic Testing - The schedules and methods for periodic testing are developed and documented.

Fire protection equipment, emergency lighting, and communication equipment are tested periodically to assure that the equipment will properly function and continue to meet the design criteria.

c.

Programs are established for QA/QC to verify testing of fire protection systems and to verify that test personnel are effectively trained.

d.

Test results are documented, evaluated, and their acceptability deter-mined by a qualified responsible individual or group.

8.

Under criterion 7. " Nonconforming Items," indicate that ncnconforming ener-gency lighting anc communication equipment is controlled as part of the QA program for fire protection.

9.

Under criterion 7, " Nonconforming Items," provide a comitment that procedures identify the individuals or groups delegated the responsibility and authority for the disposition and approval of nonconforming items.

10. Under criterion 10.0, " Audits," provide a comitment t*.at follow-up action is taken by responsible management to correct deficiencies revealed by audit.

11.

Under criteria 1, " Design Control and Procurement n cu ent Control," and 3, " Control of Purchased Material, Equipment, and Services," provide a commit-ment that the requirements of the corresponding criteria of the Vassallo l

letter of. August 29, 1977 have been met since receipt of the letter and will I

continue to be met as long as such activities are performed unless the NRC is notified otherwise.

l 12.

(Callaway Plant only) Replace or justify the deletion of " receipt" inspection under criterion 1.

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