ML19343A387
| ML19343A387 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/12/1980 |
| From: | Nichols T SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8009170294 | |
| Download: ML19343A387 (8) | |
Text
SOUTH CAROLINA ELECTRIC a GAS COMPANY POST OFFrCE 802 784 CotunaA. Sours CAROUNA 29218 T.C. NicHoLs, JR.
v<r Persiosar ano caoup Dscut.ws (Nuclear Operations)L September 12, 1980 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.
20555 Subj ect: Virgil C. Summer Nuclear Station Docket No. 50/395 FSAR Questions - Quality Assurance Branch
Dear Mr. Denton:
South Carolina Electric and Gas Company, acting for itself and agent for South Carolina Public Service Authority, provides twenty five (25) copies of material providing responses to questions from*the Quality Assurance Branch.
This material will be incorporated in the next FSAR amendment. The first three pages are provided to correct a numbering problem with questions
-issued by the branch. The last four pages are provided to give information inadvertently omitted from the last amendment.
If you require additional informaiton, please let us know.
.Very truly yours, f c dA T. C. Nichols, Jr.
RBC:TCN:jw cc:
B. A. Bursey V. C. Summer G. H. Fischer W. A. Williams, Jr.
T. C. Nichols, Jr.
E. H. Crews, Jr.
H. T. Babb D._A.
Nauman O. S. Bradham O. W. Dixon, Jr.
T. B. Conner R. B. Clary
' Jack Skolds Bob Faas NPCF/Whitaker File 1800917029Y-g
1I 52 '. 78 (R)
Although you have addressed the ten specific quality assurance criteria in BrancN Technical Position APCSB 9.5-1, we find that your re sponse does not describe suf fi ci ent detail for these criteria.
In order for the Q p to fully evaluate these criteria, additional detailed description is necessary.. Examples of the detail we would expect South Carolina Electric and Gas provi r'ed in At tachment 6 of Mr.
Company to consider are D. B. Vassallo's letter of August 29, 1977.
I f, how-ever, you choose not to provide this detail, you may apply the same controls to each criterion that are com-mensurate with the controls described in your opera-
.tional QA program (after acce pt ance by NRC).
These controls would apply to the remaining construc tion activities and for the operations phase of Uni; No.
1.
If you select this method, a statement to this effect would be adequate for our review of the fire protection
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QA program.
RESPONSE
The same QA controls described in the Operational QA Program apply to the Operational Fire Protection Program with the exception of procure-ment, which will be commensurate with the original procurement con tr ol s.
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421.78-1(sd AMENDMENT ?S-T. #
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From a recent discussion with cur I&E personnel, we under-l11 stand that your wording in. the FSAR and your interprets-
- tion of the quality related regulatory guides described in Appendix 3A of the V. C. Summer FSAR may not necessarily n
mean'a total commitment to these quality related regula-tory guides. Wording such as " complies"with the recom-mendations", "follows the guidance of" and " essential recommendations are met" may Icad to misinterpretations of
'these quality related regulatory guides during the opera-tions phase. Therefore, to preclude any misinterpreta-tions in the future, it is' requested that you review the quality related regulatory guides in Appendix 3A of the V.
C. Summer FSAR and provide us with a clear commitment regarding your intentions to comply with them.
Should you elect to comply with a guide, potentially ambigous wording should be clarified.
Should you elect to take any excep-tions to these guides, provide us with sufficient descrip-tion and equivalent supporting detail.
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RESPONSE
The words " complies and recommendations" are used throughout Appendix 3A when SCE&C fully complies with the regulatory guide.
These words are derived from the fact that the guide contains the recommended practices deemed acceptable by the NRC for the subject of the guides, and that other practices / exceptions would need definition provided.
SCE&G
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believes this phase leaves no room for misinterpretation.
A survey of the following Quality Related Regulatory Guides with the following results, relative to other phrases felt' vague by the NRC which could' lead to misinterpretation.
l~v Reg. Guide 1.8
- no vague phrases Reg. Cuide 1.28 - no vague phrases
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.tb 421.78-1 k 1.1 2'
AMENDMENT U i
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' Reg. Guida 1.30 - word essential removed (See revised page APP 3A-36)
Reg. Guide 1.33 - no vague phrases, typo corrected (see revised page APP 3A-43)
Reg. Guide 1.37 90 vague phrases Reg. Cuide 1.38 - Jord essential removed (see revised page APP 3A-48)
Reg. Guide 1.39 - no vague phrases Reg. Guide 1.54 - no vague phrases Reg. Guide 1.58 - no v' ague phrases, typo corrected (see revised pages APP 3A-38 and 3A-89)
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Reg. Guide 1.64 - no vague words Reg. Guide 1.74 - no vague words Reg. Guide 1.94 - no vague words Reg. Guide 1.116 - no vague words Reg. Guide 1.123 - no vague words
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421.81 It is our understanding that' your intent of complying with Regulatory Guide 1.33, revision 1, January 1977, does.not
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j necessarily' commit you to comply with the guidance con-tained, in ANSI' N45.2.12. (Draf t 4, Revision 2, January
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1976); " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants."
It is our position
. that your commitment to comply with Regulatory Guide 1.33 (which endorses ANSI 18.7-1976) also co= nits you to ANSI N45.2.12.
Should your interpretation differ from our position, provide us with your rationale and explanation in equivalent detail.
RESPONSE
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throughout th test of 18.7.nd speci-Z.
All other.tandards are s fically list d.in Ch. ter 6, "Refere es" witsin the body o 18.7.
' Standard N45.2'12 's refered t i
the text by *he words '(ur her
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uidance on re
'rements for au ting of quality 1ssur-ce pro rams f
nuclear over lants exi in raft f o rm.2 "
^h SCE6 a li eves this i positive sta ement o fact an does not 2
re ec any require
'nt that the refere ce footnote be used; only o call attentio to its existance.
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SCE6G's content *on, therefore, s base on the act that date w' e, were are not commi te to addressing c liance to Reg latory Gui e 1. 44 and hence to'N'
.2.12 This may be a ot point, howeilr, in hat the recent visions to the SCE6G audit } ogram (see que t' ns 421.79 an 421.8 were utilizi, 45.
12 and Regt latory Guide 144.
Thus, SCE i
be reves our program c lies,with these documen but 's not committed o them.
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- 421.81-2 AMENDMENT T3 JCII, 1980 oc roho-
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421'.82 Paragraph 17.2.18.2 of the FSAR has been revised whereby external audits will be conducted on a triennial basis.
'4 It is our position that triennial audits will be accept-able if they are implemented in accordance with Section 4 i
of ANSI /ASME N45.2.12-1977.
The triennial period should begin with performance of an audit when suf ficient work is
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in progress to demonstrate that the organization is impic-menting a Quality Assurance Program having the required scope for purchases placed during the triennial pericd.
When a subsequent contract or a contract modification that significantly enlarges the scope of activities performed by the same supplier is executed, an audit should he con.
ducted to the increased requirements, thus starting a new triennial period.
II, at any time of the pre-award sur-vey, the supplier is already implementing the same quality assurance program for other customers which he proposes to use on the auditing party's contract, then the pre-award survey if it was conducted in accordance with Section 4 of ANSI /ASME N45.2.13-1977 may serve as the first triennial I
audit.
Therefore, when such pre-award surveys are
- employed as the first triennial audits, those surveys should satisfy the same audit elements and criteria as used on other triennial audits.
A documented evaluation of the supplier should be per-formed annually. Where applicable, this evaluation should take into account (1) review of supplier-furnished docu-ments such as Certificates of Conformance, Nonconformance f-(
Notices, and corrective actions, (2) results of previous source verifications, audits, and receiving inspection, (3) operating experience of identical or similar products
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furnished by the same supplier, and (4) results of audits from other sources, e.g., customer, ASME, or NRC audits.
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Modify your description to include the above position.
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421.82-1 AMENDMENT 19 JUNE, 1980 t
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RESPONSE
si' The wording that was missing - from page 17.2-50 which precluded the incomplete sentene,e en page 17.2-51.(as will be corrected in this amend-ment 19) states thht "the frequency of audits is scheduled commencurate with the item of service to be provided."
SCE6G contends that if a
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subsequent contract enlarged the scope of a contract, a subsequent audit would have to be performe1 if the previous area becomes no longer com-mensurate.
Implement.ing p*.ocedures define how these evaluations are made as described programmatically in Section 17.2.4.4 (note 17.2.4.4 also contains Amendment 19 changes).
In the SCE6G program, pre-award surveys are not conducted differently than any external audit.
The impicmenting QAP for pre-award surveys and external audits is one and the same.
Section 17.2.18.2 indicates this fact by stating "These preaward surveys are conducted and reports pre-pared, to criteria described in 17.2.18.3"; which is the paragraph on audit requirement.
h As stated in 17.2.18.2 on page 17.2-51, " vendors performing work over an extended period of time will be evaluated at least annually." This anaoal commitment and elements used in the evaluation is recently being defined in implementing QA Procedures in response to I&E concerns explained in 421.80.
Our procedure contains elements 1 thru 4 of your question in this area verbatum.
As with question 421.80, SCE6C believes the implementing procedure supplements the annual commitment given in 17.2.18.2 and need not be part of the program description, llowever, we again recognize the need for the NRC to be satisfied that the program descriptiens are adequately implemented and are willing to supply imple-r menting procedures to NRR in addition to I&E for evaluation, b alt -
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E&G s pr pared to mee and resen imple enti pr edur.s t ie F,R re iewer or 'l st t. revi er f - firs hand obse vati o the1
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421.82-2 2.I AMENDMENT l'!T 3t=r, 1980 oc ra er,
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