ML19309E071
| ML19309E071 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway  |
| Issue date: | 04/14/1980 |
| From: | Seiken S STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM |
| To: | Haass W Office of Nuclear Reactor Regulation |
| References | |
| 80-18, NUDOCS 8004180352 | |
| Download: ML19309E071 (8) | |
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SNUPPS siendereiand wesen unit Power Plant Systern 5 Choke Cherry Road Rodville, Merytend 20050 (301)8064010 April 14, 1980 SLNRC 80- 18 FILE: 0541 SUBJ: SNUPPS QA Program for Design and Construction Walter P. Haass, Chief Quality Assurance Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket Nos.: 50-482 50-483 50-486 Ref: SLNRC 79-24 dtd. Dec. 20, 1979: Subj. as Above
Dear Mr. Haass:
The purpose of this letter is to respond to the NRC letter of Jan. 22, 1980, Haass to Petrick, SNUPPS, requesting additional information con-cerning the SNUPPS Standard Plant QA Programs for Design and Construction forwarded to NRC via the reference letter. The SNUPPS response to each f
of the 18 questions raised by the NRC are enclosed with this letter and reflect discussions with NRC (Haass, Parr, Gilroy, Licitra, Spraul) on Feb. 8th and again with Mr. Spraul on April 7th and 10th.
Please advise if SNUPPS can be of further assistance in this matter.
Very truly yours, b
l S. J. Seiken l
l QA Manager SJS:dck l
Enclosure:
SNUPPS Response to NRC 1/22/80 Request for Q 00)
Additional Information 5
cc:
J. K. Bryan UE w/ encl.
/[/
G. L. Koester KGE w/ encl.
N 8004180
s Enclosure to SLNRC 80-18 SNUPPS Response to NRC Jan. 22, 1980 i
Request for Additional Information re l
SNUPPS QA Procram for Design and Construction 1.
NRC Coment The commitment to ANSI N45.2.5-1974 on page 17.1-15 met include a comitment to supplementary NRC guidance. Revise the comitment to t
recognize Regulatory Guide 1.94 of April 1976 or revert to the ear-lier (Revision 3) comitment to draft 3 revision 1 of N45.2.5 including Regulatory staff coments and supplementary guidance from Section D of the " Green Book".
t SNUPPS Response i
SNUPPS comits to Regulatory Guide 1.94 with exception of the l
requirement of Section 5.4 of ANSI N45.2.5-1974 regarding methods of structural bolt tightening and requirements for the number of threads to be exposed beyond the nut of a tightened bolt assembly.
I Structural bolts are tightened per AISC Specifications for Struc-l tural Joints using ASTM A325 or A490 bolts using the direct-tension indicator. As a result, the requirement for acceptance of tightened bolt assemblies is that..."the length of the bolts shall be such that the point of the bolt will be flush with or outside of the face l
of the nut when completely installed".
The above exception will be reflected in a revision to Pages 17.1-15 and 17A-1 of the SHUPPS QA Programs for Design and Construction and l
will be further clarified in Appendix 3A of the SNUPPS FSAR.
The use of direct-tension indicators requires quality control inspec-tions to assure such indicators are properly installed including feeler gauge checks to determine bolt tightness. These provisions are reflected in applicable design specifications.
2.
NRC Coment The addition of the words "by the design organization" to tha fourth sentence of the first full paragraph on page 17.1-22 and to item g on page 17.1-24 implies that changes and revisions that affect the quality requirements of procurement documents may not he reviewed by the quality assurance organization. Clarify whether or not this im-plication is true in practice and, if it is true, provide justifica-tion.
SNUPPS Response Technical and quality requirements of procurement documents are establisned by the cognizant design organization. Changes to these procurement documents are reviewed by the same organization which prepared the original document or by other qualified organizations designated by the applicant. Quality Assurance organizational in-volvement is provided on an audit and surveillance basis.
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. 3.
NRC Coment The last two paragraphs on page 17.1-32 each reflect the concept of selective review and approval of bidders lists. Identify who (by position title) selects which bidders lists are reviewed and the bases of the selection.
SNUPPS Response Bidders lists are reviewed and approved by the SNUPPS Utilities or by other qualified organizations designated by the Utilities.
4.
NRC Comment Reinstate or justify the deletion of, " Certification of conformance or quality verification records will be transmitted to the plant site prior to or within sixty (60) days of shipment for safety-related products," from the middle of page 17.1-33.
SNUPPS Response This change is based on the fact that no need exists for comitment of shipment of quality records as long as such records are received at the construction site prior to installation. SNUPPS commitment to the latter is unchanged.
5.
NRC Coment r
Delete or justify the addition of " inadvertent" to the last sentence on page 17.1-35 which states: " Identification av control measures i
shall be provided to prevent the inadvertent use or installation of incorrect or defective material, parts, or compons; ts."
SNUPPS Response The addition of the word " inadvertent" is intended to provide the Owner with the opportunity to consider proceeding with installation of incorrect or incomplete materials and equipment items in instances where such installation or further processing will not preclude or inhibit later completion or correction of the items in question.
Further processing and/or installation of such items shall be subject to written and approved Utility Management controls.
6.
NRC Coment Reinstate or justify the deletion of: "Such persons shall not report
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directly to the immediate supervisors who are responsible for the i
work being inspected" from item a on page 17.1-39.
j SNUPPS Response The reference statement was removed on the basis that it was judged l
to be redundent with the preceding sentence on Page 17.1-39 that in-l spection personnel are independent from individuals or groups respon-sible for performing the activity being inspected. Compliance with this requirement is compatible with ANSI N45.2 requirements.
. l 7.
NRC Consnent Discuss the use of an " equivalent organization" to disposition non-conforming items as "use-as-is" or " repair" as allowed by the second paragraph on page 17.1-49.
SNUPPS Response The terms " equivalent organization" applies to technically qualified organizations designated by the SNUPPS Utilities to review and dis-position nonconfonnances.
8.
NRC Connent Item f on page 17.1-50 introduces the concept of significant noncon-formances. Identify who (by position title) determines which non-conformances are not significant and the bases of the determination.
Also describe how nonconformances which are not significant are han-died.
SNUPPS Response Responsibilities for the handling and processing of nonconforming items are described in approved Administrative Control and Utility QA procedures and provide for such nonconformances to be reviewed by i
the organization responsible for establishing the design basis or i
by an equivalent organization specifically designated by the SNUPPS Utilities. Nonconformances of a defined level of technical complexity or which impact safety criteria or SAR connitments are also subject to SNUPPS review and approval.
9.
NRC Comment Replace or justify the deletion of the sixth paragraph, eighth para-graph, and most of the ninth paragraph from Section 17.1.15 on pages i
17.1-50 and 17.1-51.
SNUPPS Response l
The deleted paragraphs were considered to be implementation details not normally provided in a quality assurance program description.
The reference paragraphs are reflected into applicable project pro-cedures and are available for NRC review and examination.
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10.
NRC Connent Replace or justify the deletion of " approvals of suppliers' QA pro-grams and shop inspection reports" from the list of records delivered to the site at the middle of page 17.1-57.
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l SNUPPS Response The " approval of supplier QA programs and shop inspection reports" are retained and controlled by the Lead AE and NSSS vendor as QA Records in accordance with ANSI N45.2.9 requirements. These records l
are not required at the construction jobsite since adequate means presently exist to infonn the site that vendor QA programs have been L
approved and required inspections satisfactorily perfonned. Speci-fically, the Supplier Print Control Register issued to the jobsites identifies the approval status of all supplier QA program manuals.
Satisfactory inspection completion is indicated by Lead AE inspection sign off of the Certificate of Conformance or, in the case of the NSSS vendor, by sign off of the Quality Release form.
11 NRC Comment Discuss the significance of deleting " independent" and "all" from the paragraph starting at about the middle of page 17.1-61. Also discuss the significance of adding "or assessments" to part a of the same paragraph.
SNUPPS Response i
The phrase " independent" was deleted on the basis of it being redun-l dent. Specifically, paragraph a) on page 17.160 comits to perfor-mance of audits by personnel not having responsibilities in the areas being audited. The word "all" was deleted on the basis of being un-necessary in that only those procedures which~ are~ current and impor-tant to safety are audited. The phrase "or assessments" was added to provide Management with an alternate means for reviewing the status and adequacy of the quality assurance program as specified in Criteria II of Appendix B, Quality Assurance Program.
i 12.
NRC Comment Discuss the significance of deleting the first paragraph from part 17A.l.2.4
" Personnel" on page 17A.1-18.
SNUPPS Response This deletion in the Bechtel QA program description was intended to be consistent with the Bechtel QA Topical previously approved by NRC.
13.
NRC Coment A waiver of audits has been added to part 17A.l.7.4 in the middle of the last paragraph on page 17A.1-26. Provide a comitment that when such waivers are made, the involved supplier will be audited at least l
once every three years. A similar comitment is required in the para-graph starting on page 17A.1.31 and concluding on page 17A.1-32.
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SNUPPS Response Existing Bechtel project procedures specify that when such waivers are made, the involved supplier will be audited at least once every 'two years vice at three year intervals requested by NRC. The SNUPPS QE Program for Design and Construction will be revised to reflect this existing comitment.
14.
NRC Coment Page 17A.1-26a which contains most of part 17A.1.8 is missing.
SNUPPS Response A copy of page 17A.1-26a is enclosed. SNUPPS regrets this inadver-tent omission.
15.
NRC Comment Discuss the significance of changing the solid line on Figure 17A.1-8 between the SNUPPS Procurement Manager and the Project Inspection Supervisor to a broken line.
SNUPPS Response The significance of this change is to reflect the fact that the In-spection Supervisor is responsible to the SNUPPS Procurement Manager only on an informal, coordination-type basis. Technical and management direction to the Inspection Supervisor is provided by the Division Inspection Manager. This change is necessary to assure inspection activities are " independent" of cost and schedular considerations.
16.
NRC Coment Replace or justify the deletion of receiving inspection from fire protection items 3 and 4 on sheet 3 of Table 17C.0-1.
SNUPPS Response Fire protection materials and equipment are largely comercial, off-the-shelf type of items whose quality and integrity can be assured in the course of installation and preoperational testing. For those items whose quality and integrity cannot be verified during installa-tion or preoperational tests, inspections will be performed, but in-spections may occur as receipt inspections or installation inspections or both, as appropriate.
17.
NRC Coment State whether or r.ot the SNUPPS' nonconfonnance control program and corrective action program for fire protection, described in the A/E's Project Engineering Procedures, meet sections 17A.1.15 and 17A.1.16 of the SNUPPS' QA program description. If not, list and justify the deviations.
. SNUPPS Response SNUPPS nonconformance control program currently described in the A/E's Project Engineering Procedures is in compliance with the second and third paragraphs of Section 17.A.l.15 of the SNUPPS QA Program des-cription and is applicable to fire protection systems.
Paragraphs one and four of Section 17.A.1.15 are not applicable to fire protec-tion systems on the basis that these systems incorporate standard, commercially-available equipment and materials which are verified by site inspection and/or performance testing. SNUPPS corrective action program currently. described in the A/E's Project Engineering Procedures and the Nuclear Quality Assurance Manual are in compliance with Section 17.A.l.16 of the SNUPPS QA Program description and is applicable to fire protection systems.
18.
NRC Comment i
Explain what is meant by: "The SNUPPS/ Utility QA organizational audit provisions satisfy the requirements of Paragraph d of Section 10.0, except that audit frequency may vary depending on the time span of the activity being audited." This is found in item 10 on Sheet 2 of Table 17C.0-2.
SNUPPS Response Fire protection activities will be audited on a current and on-going basis. Those portions of fire prote-tion activities which are complete need not be covered in subsequent aucits.
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Enclosure:
Page 17A.1-26a
SNUPPS i
17A.l.8 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND l
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COMPONENTS At the initial planning stages of the project, a list and a l
numbering system for specifications and drawings is prepared to provide proper identification of these documents.
A list and identification system for basic mechanical, electrical, and control systems is established.
A list and identification system for equipment is then established.
As the design pro-9resses, lists and identification systems for pipes, valves, instruments, electrical raceways, circuits, cables, structural members, etc., are established.
These documents are revised, as necessary, with the progress of the details of the design.
l The specifications and drawings identify the equipment and various components with the basic identification systems.
The equipment and material specifications require the suppliers to t
follow the identification system and to so mark the equipment and materials supplied by them.
During the normal checking of the specifications and drawings prepared by Bechtel and/or the supplier, the proper identifications are checked.
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Procurement documents provide the requ'irements for identifi-cation of purchased items in accordance with the program l
established by Bechtel for identification of equipment and I
major components.
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Parts, components, subassemblies and equipment, and partially I
fabricated items may be identified by stenciled or etched l
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l Revision 1 1
17A.1-26a 3/80 w
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