ML19323G060

Responds to 800320 Ltrs to Union Electric & Ks Gas & Electric Re QA Programs for Design Const & Fire Protection. Responds to NRC Questions Offered on Generic Basis

ML19323G060
Person / Time
Site:	Wolf Creek, Callaway, 05000484
Issue date:	05/27/1980
From:	Petrick N STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM
To:	Harold Denton Office of Nuclear Reactor Regulation
References
SLNRC-80-25, NUDOCS 8005300321
Download: ML19323G060 (7)

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o SNUPPS Stenderdized Nuclear Unit Power Mont System 5 Choke Cherry Road Nicholas A. Petrick Rockville, Maryfend 2005o Executive Director (301) 845 4010 May 27, 1980 SLNRC 80-25 FILE: 0542/0491.3 SUBJ: QA Programs for Design, Construc-tion and Fire Protection: Callaway and Wolf Creek Sites Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Re: STN 50-482, STN 50-483, STN 50-486 Ref: a) Letter 3/20/80, Parr, NRC to Bryan, Union Electric Co.: Subj.

as above b) Letter 3/20/80, Parr, NRC to Koester, Kansas Gas & Electric Co.:

Subject as above

Dear Mr. Denton:

The purpose of this letter is to respond to NRC questions concerning the Callaway and Wolf Creek QA programs for fire protection forwarded to Union Electric and Kansas Gas & Electric as Enclosure 2 to the reference letters. The Callaway and Wolf Creek responses to the NRC questions are enclosed with this letter and are offered on a generic basis. The en-closed responses have been discussed with NRC (Spraul) on May 6th and May 16th and are understood to be responsive to NRC questions and con-cerns. If further clarification should be required, please contact Mr.

S. J. Seiken, SNUPPS QA Manager, (301) 869-8010.

Responses to the NRC questions specific to Callaway and Wolf Creek site QA programs for design and construction forwarded as Enclosure 1 to the reference letters are being finalized and will be available for review with NRC within the next several weeks.

Ver truly yours,

-R M C Nicholas A. Petrick SJS:dek Encl: Response to Enclosure 2 to NRC letters of 3/20/80 Y \

j cc: J. K. Bryan, UE i G. L. Koester, KGE l D. T. McPhee, KCPL l

80053 003Al 7 l 1

Response to NRC Letter of 3/20/80, Enclosure 2 re Questions on Site Specific Fire Protection QA Programs -

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

SNUPPS Response The second paragraph of Criterion 2 will be revised to indicate design and installation activities will be accomplished in accordance with docu-mented instructions, procedures and drawings. For Callaway Unit 1, this commitment as it specifically relates to design activities to be effective as of June 1,1980. Design effort to date has been reviewed by American Nuclear Insurers (ANI). The design effort from the date of the Vassallo letter until June 1,1980 will be subject to an independent design review.

2. NRC Question Provide a statement under the third paragraph of criterion 2 that "appro-priate 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 i by design and confirmed by design review. )

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l SNUPPS Response The third paragraph of criterion 2 will be revised to indicate that

" appropriate fire protection requirements" include items such as pre- ,

cautions, control of ignition sources and combustibles and provisions j for backup fire protection. As previously discussed with NRC (Haass, 1 Spraul), Wolf Creek /Callaway procedures do not address restrictions on material substitution or other deviations; rather they are reviewed to assure compliance with applicable design requirements. including mate-rial requirements.

3. NRC Question l l

Under criterion 4 0, " Inspection," provide a commitment that inspections related to the fire protection program include the emergency lighting and communication equipment.

SNUPPS Response o A new paragraph will be added to criterion 4 indicating that periodic l inspections and/or tests of fire protection systems, emergency light-l l

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ing, communications equipment, emergency breathing and auxiliary equip-ment will be performed during the operating phases of the plants. Cr i-teria 4 and 5 presently commit to a program of inspections and tests to confirm design and installation acceptability of these items prior to plant operations; these commitments will be clarified to indicate emer-gency lighting / breathing, communications and auxiliary equipment are included in criteria 4 and/or 5, as appropriate.

4. NRC Question The third paragraph under criterion 4 states that " Inspections are (or "will be") perfonned by individuals other than those who performed the activities being inspected." It is the staff position that these in-spections be performed 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. Comit to meet this staff position or provide an alternative for our evaluation.

Also provide a commitment that the inspection personnel are knowledge-able in the design and installation requirements for fire protection.

SNUPPS Response Inspection activities at the SNUPPS jobsites involving safety-related Seismic Category I Structures, Systems and Components are performed by quality control personnel. Inspection activities involving non-Seismic Category I (II/I) Items, Quality Group D (augmented) Systems and Fire Protection Systems are performed by quality control and/or engineering personnel. Such personnel are independent of the work being inspected.

QA personnel are responsible for audit and surveillance of inspection act ivit ies .

A statement that inspection personnel are knowledgeable in the design and installation requirements for fire protection will be added to criterion 4 as requested.

5. NRC Question Under criterion 4.0, " Inspection," provide a commitment that the QA program for fire protection includes inspection procedures, instruc-tions, and checklists which provide for:

a) Ider,tification of characteristics and activities to be inspected; b) Identification of the individuals or groups responsible for per-forming the inspection operation; c) Acceptance and rejection criteria; d) A descrip+ ;an of the method of inspection; e) Recording evidence of completing and verifying a manufacturing, inspection or test operation; and f) Recording inspector or data recorder and the results of the in-spection operation. -

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l SNUPPS Response '

The third paragraph of Criterion 4 of the SNUPPS QA Programs for Fire Protection will be revised as follows:

" Inspections are performed by either quality control or engineering personnel other than those who performed the activities being inspected and who are knowledgeable of fire protection design and installation requirements. These inspections will be performed in accordance with procedures or checklists that shall include, as applicable, the follow-ing:

a) Identification of items / activities being inspected; b) Individuals / organizations responsible to perform inspections; c) Reference design documents and acceptance criteria; d) Identification of inspection method; e) Documentation requirements; f) Inspection results, inspector signoff.

6. NRC Question Under criterion 4.0, " Inspection," include a commitment that periodic inspections of fire protection systems, emergency breathing and aux-iliary equipment, emergency lighting, and communication equipment will be made to assure the acceptable condition of these items.

SNUPPS Response SNUPPS will comply. See response to Question 3, above.

7. NRC Question Under criterion 5, " Test and Test Control," provide commitments to the following:

A test program shall be established and implemented to assure that test-ing is performed and verified by inspection and audit to demonstrate ,

conformance with design and system readiness requirements. The tests l are performed in accordance with written test procedures, and test re- )

sults are properly evaluated and acted on. The test program includes: I a) Installation Testing - Following construction, modification, repair or replacement, sufficient testing is peformed to demonstrate that fire protection systems, emergency lighting and communication 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. --

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b) Periodic Testing - The schedules and methods for periodic testing are developed and documented. Fire protection equipment, energency 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 pro-tection systems and to verify that test personnel are effectively trained.

d) Test results are documented, evaluated, and their acceptability determined by a qualified responsible individual or group.

SNUPPS Response SNUPPS response to the NRC comments is as follows:

a) The commitment for inspections and/or tests of fire protection sys-tems after installation, modification or repairs will be addressed as indicated in SNUPPS response to Question No. 3, above.

A commitment stating that written test procedures for installat' n tests incorporate the requirements and acceptance limits contained in the applicable design documents will be added to the first para-graph of criterion 5.

b) The commitment to and scope of periodic tests is addressed in re-sponse to Question No. 3, above. Further commitment to periodic testing is reflected in the second paragraph of criterion 5.

c) The requirement for QA audit / surveillance of fire protection test activities is described in the third paragraph of criterion 5 and further addressed in criterion 10, Audits. Further clarification regarding training of test personnel will be provided in each site addendum, d) A statement indicating test results are documented, evaluated and their acceptability determined by qualified personnel will be indi-cated in criterion 5 as requested.

8. NRC Question Under criterion 7, " Nonconforming Items," indicate that nonconforming emergency lighting and communication equiment is controlled as part of the QA program for fire prote ion.

SNUPPS Response l

-d The requested clarification will be added to the first paragraph of criterion 7

9. NRC Question Under criterion 7, " Nonconforming Items," provide a commitment that procedures identify the individuals or groups delegated the responsi-bility and authority for the disposition and approval of nonconforming items.

SNUPFS Response The requested clarification will be added to the second paragraph of criterion 7.

10. NRC Question Under Criterion 10.0, " Audits," provide a cannitment that follow-up )

action is taken by responsible n.anagement to correct deficiencies revealed by audit. ,

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SNUPPS Response  ;

The requested clarification will be added to criterion 10.

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11. NRC Question Under criteria 1, " Design Control and Procurement Document Control,"

and 3, " Control of Purchased Material, Equipment, and Services," pro-vide a canmitment that the requirements of the corresponding criteria of the Vassallo letter of August 29, 1977 have been met since receipt of the letter and will continue to be met as long as such activities are performed unless the NRC is notified otherwise.

SNUPPS Response Criterion 1, " Design Control and Procurement Document Control" will be revised to reflect the guidelines of the corresponding criteria of the Vassallo letter of August 29, 1977. This commitment to be as of June 1, 1980. As indicated in the response to Question 1, the design effort performed to date for Callaway Unit I has been reviewed by ANI. Design effort from date of the Vassallo letter through June 1, 1980 will fur-ther be subject to an independent design review. Material and equip-ment procured to date are of a standard, commercially available nature which will be inspected or performance tested to verify conformance to procurement specification requirements.

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-c Criterion 3 will be revised to provide a commitment to the guidelines of the Vassallo letter of 8/29/77 [specifically item 3(a)] regarding 1

supplier evaluation and selection. The existing comnitment described in criterion 3 to perform inspections / tests to verify material and equipment acceptability is considered compatible with item 3(b) of the Vassallo letter.

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

SNUPPS Response See SNUPPS response to NRC comment 16 regarding Standard Plant QA Pro-gram for Design and Construction; reference SLNRC 80-18 dated 4/14/80.

As indicated in this earlier response, the acceptability of materials and equipment for fire protection systems will be determined either by installation or preop testing or, where necessary, by inspections.

Such inspections may occur as receipt inspections or installation inspections, or both, as appropriate. This clarification is applica-ble to both Callaway and Wolf Creek sites.

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