ML19317G963
| ML19317G963 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/22/1976 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Reid R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8004020623 | |
| Download: ML19317G963 (7) | |
Text
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July 22,1976 Mr. Robert W. Reid, Chief Operating Reactors Branch No. 4 m
Division.cf Operating Reactors f
U. S. Nuclear Regulatory Commission
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Dear Mr. Reid:
s This letter is submitted in response to your coFrespondence dated June 1,1976, in which you requested a revised description of the Quality Assurance Program for Rancho Seco Nuclear Generating Station, Unit No. 1.
It is the policy of the Sacramento Municipal Utility District to embrace a total ouality assurance approach to the management of all quality activities b. thin the District.
Every employee in the District has the responsibility to do quality work and each department manager is responsible for the quality functions within his organization. A Quality Assurance Director, who has the responsibility to coordinate specific activities related to quality assurance, has been appointed and individuals assigned the responsibility for checking, inspecting, or aud.iting quality affected activities will be other than the individual or organization responsible for performing the specific activity, The organization specifically charged with the design, modifi-cation and operation of Rancho Seco is under the direction of Mr. John Mattimoe, Assistant General Manager and Chief Engineer. Three depart-ments provide daily direction to activities unique to their area. They are:
1.
Nuclear Operations - Mr. R. J. Rodriguez, Manager, is responsible for day-to-day operation of Rancho Seco.
l 2.
Generation Engineering - Mr. D. G. Raasch, Manager, is responsible for design and modification of Rancho Seco.
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Quality Assurance
,:*. L. G. Schwieger, Quality Assurance Director, is responsible for direction of quality assur-(A) ance activities, k
A list of the duties are included in the Final Safety Analysis Report (FSAR) and are also detailed in the Quality Assurance Manual.
Within the framework of these specific duties lie the overall requirement
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AN ELECTRIC SYSTEM S E RVI N G MORE THAN 600,000 IN THE HEART OF C A LI F O R N I A
q Mr. Robert W. Reid July 22,1976 of 10CFR50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants. An organization chart has been included to illustrate the responsible groups associated with Rancho Seco Unit No. 1.
The District has prepared a Quality Assurance Manual for Nuclear Operations which is written to include the operational guidance provided by the WASH documents; i.e., WASH No.1284, " Guidance on Quality Assurance Requirements During the Operations Phase of Nuclear Power Plants," dated October 26, 1973, WASH No. 1283, " Guidance on Quality Assurance Require-ments During Design and Prccurement Phase of Nuclear Power Plants," Revi-sion 1 dated May 24, 1974 and WASH No. 1309, " Guidance on Quality Assur-ance Requirements During the Construction Phase of Nuclear Power Plants,"
dated May 10, 1974. The " umbrella coverage" approach to quality assurance outlined by the WASH documents meets the District's quality management's goals more closely than the project quality approach provided by ANSI Standard N18.7-1976. The District feels it is within the best interest of the public to continue with our policy of following the guidance provided by the WASH documents in lieu of altering our Quality Assurance Program to specifically state the guidance provided by ANSI Standard N18.7-1976.
We have reviewed the Rancho Seco program, both b directed by the Management Safety Review Committee (MSRC) y in-depth audits and have also used outside consultants to identify any weakness in our program. All suggestions by either route have been implemented. That the Quality Assur-ance Manual and its attendant program receives constant scrutiny and up-grading is attested to by the continual revision of various procedures.
All three organizations; Nuclear Operations, Generation Engineering, and Quality Assurance; participate in the review, upgrading and execution of the Quality Assurance Program.
The District's Quality Assurance Program has been closel tored on a continuing basis by the Nuclear Regulatory Commission (y moni-NRC)
Region V.
The District is pleased to note that at the annual review of our Quality Assurance Program made by the NRC in June of this year, no reportable deficiencies were noted. We think this shows a Quality Assur-ance Program that does meet the broad requirements of 10CFR50, Appendix B, plus the additional regulatory requirements which an operating facility must satisfy.
The NRC Region V inspector for Rancho Seco conducted an initial in-depth review of the Quality Assurance Program at its formula-tion and each Quality Assurance Procedure was discussed for impact, rele-vance, applicability and conciseness.
Any deficiencies detected by the NRC Region V inspectors since in.ept, m of the Quality Assurance Program at Rancho Seco have been cor-rected and the Quality Assurance Program updated to eliminate any recur-rences. Their review has covered the interworking relationships between the various departments involved at Rancho Seco.
The philosophy and con-trols established by the Quality AsSJrance Program has been discussed with the Region V inspectors. The comments by the NRC personnel have been both knowledgeable and informative and have resulted in modification to our i
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-Mr. Robert W. Reid July 22,1976 1
program.- The evolutionary aspects of a quality assurance program for opera-tion of-a nuclear power plant has required development of supplementary 4
philosophy documents and guidance memorandums.
Some ha've evolved into
-Quality Control Instructions (QCIs) which extend the Quality Assurance Manual where interpretation of policy / requirements of the NRC, ASME, ANSI, the State, or SMUD necessitate more detailed procedures. This approach is detailed in-the Quality Assurance Manual under.QAP No. 20, Ouality Control Instructions.
As noted early in this letter, we stated that our Quality Assur-ance Program provides " umbrella coverage" of all quality related activities within the District. The basic quality assurance policy for Rancho Seco is established by the Quality Assurance Manual for Nt -lear Operations, but many of the specific details which address the operational guidance found in the WASH documents are located within the following documents:
1.
Administrative Procedures 1
2.
Counting Room Manual 3.
Plant Maintenance - 3 volumes 4.
Process Standards 5.
Radiation Chemistry - 2 volumes 6.
Radiation Control 7.
Station Manual - 3 volumes 8.
Surveillance Manual - 3 volumes 9.
Technical Specifications 10.
Security Plan 11.
Emergency Plan 12 Test Procedures 13.
Management Safety Review Committee Charter 14.
Jiant Review Committee Charter 15.
Final Safety Analysis Report 16.
Engineering Configuration Procedure 17.
Purchasing Manual We are certain that our present Quality Assurance Program for g
Rancho Seco does meet the operational guidance provided by the WASH docu-ments, but we do not have a singleton document which can be forwarded to 3
your office for review as many documents are needed to provide the in-depth coverage needed to make-up an effective Quality Assurance Program for i
an operating nuclear power plant. We do have the required documents at the appropriate locations at Rancho Seco and we would be happy to have you i
visit our site for a review at your convenience. Additionally, we have a Management Safety Review Committee (MSRC) audit program that independently i
certifies overall operational compliance with the Rancho Seco Quality Assurance Program.
The MSRC is under the direction of the Assistant General Manager and Chief Engineer and reports to the General Manager. This committee is comprised of people knowledgeable in the operation of Rancho Seco and contains two members from the Quality Assurance organization.
It routinely h
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3 Mr. Robert W. Reid July 22,1976 reviews all activities connected with the operation of Rancho Seco and directs the Quality Assurance organization as to the scope of its acti-vitias.
It assigns the areas to be audited each quarter and reviews the findings of each audit conducted. The scope covered under the audit program entails 26 uniquely different areas encompassing the activities, organization, documentation, maintenance and modification activities, and personnel directly concerned with the nuclear safety related aspects of Rancho Seco Unit No. 1.
We cover such diverse subjects as the Emergency Plan and Security Plan to more routine subjects such as Configuration Control and the Maintenance Program.
Special audits are also directed by the MSRC as needed; as an example, an event that causes major damage to property or equipment.
Special attention is given the training and qualification of audit team leaders and audit team members.
Whenever practical, the Quality Assurance auditors are accompanied by supplementary technical specialists who are knowledgeable in the area to be audited.
The audits are conducted with appropriate checklists o. procedures and audit implementation includ-ing proper preparation, performance, reporting and followup of the audit is practiced.
Specific corrective action initiated by the organization audited is an integral and mandatory part of the program.
Copies of the audit report incciding the corrective action taken are distributed to management personne for review and comment.
A management audit conducted by one member of the MSRC (with assistance as needed) is made annually on Quality Assurance.
No member of Quality Assurance is a member of the team. This management audit reviews conformance to the "crange book" and its attendant documents.
The above outlined approach describes t ' policies, systems, and philosophy that govern the operation and maintenance, including redesign and modifications of Rancho Seco Unit No. 1.
The program must be followed by all Quality Assurance personnel and by other personnel who may have an effect upon or are responsible for determination or assurance of Rancho Seco plant quality.
We do not feel that a listing of the 10CFR50, Appendix B,18 point criteria together with an elaboration of how the District complies with each criterion or subcriterion is necessary for this response. Our Quality Assurance Manual addresses this aspect.
It is written around our needs and methods used to assure complience not only with 10CFR50, Appendix B, but with all pertinent ANSI docue nts, ASME and IEEE require-ments.
It does this by use of 27 separate ano distinct procedures cover-ing not only che range of activities of design control, nonconformances and inspection, but also includes activities such as clearance procedures and test control.
We recognize the need for a quality assurance program that encompasses not only design and modification activities but also controls areas covering activities connected with an operating plant.
This latter area requires methods and mechanisms to assure inspection and test
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5-July 22,1976 Mr. Robert W. Reid
. programs prior to and after returning systems to operating condition.
Our Quality Assurance Program directs the management resources of SMUD for the operation of the Rancho Seco Nuclear Geaerating Station in a manner characterized by optimum safety and reliability. The Quality Assurance Program lies as an umbrella over all activities to ensure this goal is reached. We feel we meet the requirements as outlined by all appli-cable Code of Federal Regulations and welcome your review for compliance.
If any additional information is needed to explain our Quality Assurance Program, please feel free to contact us.
Sincerely yours, hW L
y J. J. Mattimoe Assistant General Manager and Chief Engineer Attachment cc:
Region V
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