ML19350B693
| ML19350B693 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/16/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Koester G KANSAS GAS & ELECTRIC CO. |
| References | |
| NUDOCS 8103230345 | |
| Download: ML19350B693 (9) | |
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DISTRIBUTION:
MAR 161981 FS roeder gge,p' DEisenhut RTedesco O
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BJYoungblood RHartfield, MPA g,f Docket No.: STN 50-482 q, f
~ADromerick OELD Ab ' ; r. ' -)
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o Mr. Glen L. Koester D,
0 /Sg7 Dubenstein bec: TERA l
Vice President - Nuclear h
M/g,% {6JSchwencer A
NRC/PDR Kansas Gas and Electric Company cA
/JMiller L/PDR 201 North Market Street h
\\j RVollmer NSIC Post Office Box 208 m
TMurley TIC Wichita, Kansas 76201 WHaass ACRS (16)
HLevin
Dear Mr. Koester:
Dross
Subject:
Request for Additional Information for the Review of the Wolf Creek Generating Station, Unit 1 - Addendum As a result of our continuing review of the Wolf Creek Generating Station, Unit 1 Addendum,FSAR, we find that we need additional information to complete our evaluation. The specific infomation required is in the area of quality assurance and is presented in the Enclosure.
To maintain our licensing review schedule for the Wolf Creek Generating Station.
Unit 1 FSAR, we will need responses to the enclosed request by May 15, 1981.
If you cannot meet this date, please inform us within seven days after receipt of this letter of the date you plan to submit your responses so that we may review our schedule for any necessary changes.
Please contact Mr. Dromerick, Wolf Creek Licensing Project Manager, if you desire any discussion or clarification of the enclosed request.
Sincerely.
Original signed by Sobert L. Tedeces Robert L. Tedesco, Assistant Director for Licensing Division of Licensing
Enclosure:
As stated j
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_- - =__ - _ _ _. - -. _ _ _.
O Mr. Glenn t Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street P. O. Box 208 Wichita, Kansas 67201 1
4 cc: Mr. Nicholas A. Petrick Executive Director, SNUPPS Ralph Foster, Esq.
5 Choke Cherry Road Kansas Gas & Electric Company P. O. Box 208 Rockville, Maryland 20750 Wichita, Kansas 67201 Mr. Jay Silberg, Esquire Shaw, Pittman, Potts & Trowbridge Willian H. Ward, Esq.
MACEA 1800 M Street, N. W.
5130 Mission Road Washington, D. C.
20036 Shawnee. Mission, Kansas 66205 Mr. Donald T. McPhee Vice Presidnet - Production
.Ms. Treva Hearne, Assistant General Couns Public Service Commission Kansas City Power and Light Company P. O. Box 360 1330 Baltimore Avenue P. O. Box 679 Jefferson City, Missouri t
Kansas City, Missouri 64101 Mr. Tom Vandel James T. Wiglesworth, Esq.
Resident Inspector / Wolf Creek NPS 9800 Metcalf c/o USNRC Suite 400 P. O. Box 1407 General Souare Center Emporia, Kansas 66801 Overland Park, Kansas 66212 Mr. Michael C. Keener Mr. William H. Griffin, Esq.
Wolf Crock Project Director Assistant Attorney General State Corporation Commission State of Kansas State of Kansas State House Fourth Floor, State Office Bldg.
Topeka, Kansas 66612 Topeka, Kansas 66612 Mr. John M. Wylie, II Energy Reporter Kansas City Star 1729 Grand Kansas City, Missouri 64108 Mr. Gary Haden Wichita Eagle and Beacon Box A.-20 Wichita, Kansas 67201 e
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Enclosure Request for Additional Infomation Wolf ~ Cresk~ Generating Station, Unit 1 Docket No. STN 50-482 260.0 WC QUALITY ASSURANCE 8 RANCH 260.1 WC Table 17.2-3 and its referenced Appendix 3A should incorporate the (Table following:
17.2-3)
Requiatory Guide Re v.
Date Appendix 3A Table 17.2-3 1.8 1-R 5/77 OK OK 1.26 2
6/75 Missing Missing 1.29 3
9/78 Missing Missing 1.30 8/72 OK OK 1.33 2
2/78 OK OK 1.37 3/73 OK OK 1.38 2
5/77 OK OK 1.39 2
9/77 OK OK 1.58 1
9/80 8/73 8/73 1.64 2
6/76 OK OK 1.74 2/74 OK OK 1.88 2
10/76 OK OK 1.94 1
4/76 Missing OK 1.116 0-R 5/77 OK OK 1.123 1
7/77 OK OK 1.144 1
9/80 1/79 1/79 1.146 8/80 Missing Missing A comitment to 10 CFR 50.55a is also required.
The following is in reference to the KG&E discussion regarding the Regulatory Guide noted.
1.33 The discussion states that the recomendations of R.G.1.33 are met through the specific ANSI daughter standards listed in Table 17.2-3.
This could be construed to mean that the Regulatory Position of R.G.1.33 is not met. Clarify.
1.38 The discussion states that KG&E may prescribe protective measures, in lieu of manufacturer's standards or minimum requirements. The standard says that the manufacturer's docunented standard or minimum requirements shall be con-sidered when classifying items, and the point of the dis-cussion regarding this is not clear. Clari fy.
1.39 The discussion states that KG&E procedures require general housekeeping practices to be maintained at the station during normal operations. Describe what is meant by " gen-eral housekeeping practices."
1.74 It is the staff position that certificates of conformance and certificates of.conpliance.should be-signed by a-respon-sible party from.the certifier's organization. Comit to meet this position or submit an alternative for our evaluation.
. 1.144 a) The first discussion paragraph regarding the classiff-cation of certain audit personnel as lead auditors implies that all KG&E auditors meet the requirements for lead auditors. This may require clarification based on comitment to R.G.1.146.
b) The first sentence of the second discussion paragraph is unacceptable. The staff position given in Section C.3.b.(2) of R.G.1.144 is a minimum mquirement. More frecuent audits, based on status and importance to safdy, are acceptable. Clari fy.
260.2 WC Provide the qualification reqcfrements for the Manager Quality Assur-(17.2.1.4) anct Section 17.2.1.4.1 states that the qualifications of the Manager Quality Assurance (Site) are at least equivalent to those specified in ANSI /ANS 3.1.
Verify that this comitment is to the draft standard ANS 3.1 dated December 6,1979, and identify the applicable part(s) of this draft standard.
260.3 WC Describe the significance of the dashed line from the QC Supv. and (Fig.
the Health Physicist on Figum 13.1-1.
Provide the number of indi-13.1-1) viduals planned to be assigned to the QC Supv. shown on Figure 13.1-1.
260.4 WC Provide a commitment that the Manager Quality Assurance, the Manager (17.2.1.4 & Quality Assurance (Site), and the QC Supv. have no duties or responsi-13.1.2.2) bilities unrelated to QA that would prevent their full attention to l
QA matters. Where is the Manager Quality Assurance (Site) located?
260.5 WC Provide a commitment to notify NRC of changes (1) for review and (17.2.2.3) acceptance in-the accepted description of the FSAR QA program prior to _iglementation and (2) in organizational elements within 30 days j
after announcement.
l l
260.6 WC FSAR Revision 1 deleted the statement that Table 3.2-1 of the Standard (17.2.2.2)
Plant FSAR is maintained current by the Manager Nuclear Services with changes to the table approved by the Manager Quality Assurance and Manager Nuclear Plant Engineering.
Describe KG&E responsibilities mgarding this table and discuss how these responsibilities are met.
Also, it is not clear how Table 3.2-1 applies during the operations phase in regards to the column headed " Quality Assurance." While the Bechtel and Westinghouse QA programs were applicable during the design and construction phases, it is not clear how (or if) KG&E would use these programs during the operations phase. Clarify.
I 260.7 WC Item 2 on page 17.2-8 is headed " Operating Quality Assurance Program i
(17.2.2.4 & Manual." Although Table 17.2-1 is titled " Controlled Procedure Manuals,"
Table the Operating Quality Assurance Program Manual is not identified in the 17.2-1) table. Clari fy. Also discuss the Manager Quality Assurance's mspon-sibility regarding this manual.
260.8 WC Section 17.2.0.3 indicates that computer codes are controlled by the
[
(17.2.2) 00AP. Describe how the QA program will be applied.
Include a descrip-tion of related organizational responsibilities for internal and exter-nal efforts.
. 260.9 WC Section 17.2.2.6 of the Wolf Creek FSAR discusses verification of (17.2.2)
QA program implementation through audits. Provide a comitment that KG&E management above the QA organization maintains frequent contact with the QA program through meetings and reports, including review of audit reports. Verify that in this way, and through pre-planned and documented annual assessments, this management regularly assesses the scope, status, adequacy, and compliance of the QA pro-gram to 10 CFR Part 50 Appendix B.
260.10 WC The second sentence in Section 17.2.3.3 states that design changes (17.2.3)
Jell be communicated to appropriate plant personnel when such changes m'ay affect performance. Clarify that this means each individual's performance of his duties.
260.11 WC Provide a comitment that action to correct errors found in the design (17.2.3) process and action to assure control of changes are documented.
260.12 WC Clarify the first sentence of Section 17.2.3.3 which states: " Design (17.2.3) requirements and changes themto shall be...so that deviations from quality standards remain visible throughout the design process."
(Underline added.)
260.13 WC Section 17.2.3.5 indicates XG&E procedures will control design inter-(17.2.3) faces.
Describe the controls.
260,14 WC Section 17.2.3.6 of the Wolf Creek FSAR states:
" Design verification (17.2.3) shall be performed by personnel other than those who performed the original design and shall be accomplished prior to relying upon the corrponent, system, or structure to oerform its function." Concerning the personnel, provide a comitment that the verifier is qualified and is not directly responsible for the design or desi neither the designer nor his immediate supervisor)gn change (i.e.,
Concerning the timing, provide a comitment that design verificstion is normally completed prior to release for procurement, manufacture, or installa-tion or to another organization for use in other design activities.
Where this timing cannot be met, justification for deferral should be documented and the unverified portion should be identified and con-trolled. Include such a comitent.
260.15 WC In the area of design verification, clarify that procedures identify (17.2.3) the responsibilities of the verifier, the areas and faatures to be verified, the pertinent considerations to be verified, and the docu-mentation required. Also provide a commitment that specialized mviews are used when uniqueness or special design considerations warrant.
260.16 WC Clarify that design documents subject to procedural control include, (17.2.3) but are not limited to, specifications, calculations, cornputer programs, system descriptions, SAR when used as a design document, and drawings including flow diagrams, piping, and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems for major facilities, site arrangements, and equipment locations.
260.17 WC Provide a commitment that supplier QA programs are reviewed and found (17.2.4) acceptable by KG&E's QA organization before initiation of activities affected by the program.
260.18 WC Section 17.2.4.2 indicates KG&E's Quality Assurance Department is (17.2.4) responsible for quality requirements for procurement. Verify that the QA Department review of procurement documents determines that the quality requirements are correctly stated, inspectable, and control-lable; that there are adequate accept / reject criteria; and that the procurement documents have been prepared, reviewed, and approved in accordance with KG&E's QA program requirements.
260.19 WC Section 17.2.6.2 of the Wolf Creek FSAR identifies the types of docu-(17.2.6) ments which are controlled. Expand this list such that it includes the following:
a.
Other design documents (e.g., calculations and analyses) includ-ing documents related to computer codes.
b.
Instructions and procedures for such activities as fabrication, construction, modification, installation, test, and inspection.
c.
As-built drawings.
d.
Wolf Creek Project Policy Manual.
e.
Wolf Creek Generating Station Procedures Manuals.
f.
KC&E Procedures Manual.
g.
FSAR.
h.
Topical reports.
260.20 WC Discuss the role of the quality assurance organization in the review (17.2.6) of and concurrence with documents under the control of the quality assurance program regarding the QA-related aspects.
260.21 WC Provide a commitment that the quality assurance organization reviews (17.2.6) and concurs with instructions and procedures used for maintenance, modification, and inspection at Wolf Creek to determine a.
The need for inspection, identification of inspection personnel, 1
and documentation of inspection results, b.
That the necessary inspection requirements, methods, and accept-ance criteria have been identified.
260.22 WC Section 17.2.7.7 of the Wolf Creek FSAR addresses supplier monitoring (17.2.7) in accordance with procedures. Verify that the procedures are docu-mented, that they assure conformance to the purchase document require-ments, that they identify organizational responsibilities, and that
. they specify the characteristics or processes to be witnessed, inspec-ted, or verified, and accepted, the method of surveillance, and the documentation required. Clarify that the procedures am reviewed and approved by the quality assurance organization.
260.23 WC Provide a commitment that the bases of supplier selection is documented (17.2.7) and filed. Also clarify that when an LCVIP letter of confirmation or the CASE register is used to establish a supplier's qualification, the documentation will identify the " letter" or " audit" used.
260.24 WC Provide a consnitment that procurement of spare or replacement parts (17.2.7) for safety-related structures, systems, and components is subject to present QA program controls, to applicable codes and standards, and to technical requirements equal to or better than the original techni-cal requirements, or as required to pmclude repetition of defects.
260.25 WC Provide a commitment that suppliers' certificates of conformance are (17.2.7) periodically evaluated by audits, independent inspections, or tests to assure they are valid.
260.26WC Section 17.2.7.6 states that the extent of acceptance methods and (17.2.7) associated verification activities will vary as a function of the mia-tive importance ar.d complexity of the purcha ed item or service and the supplier's past oerformance.
It is the staff's position that the extent of quality verificetion should also reflect the item's or service's im-portance to safety or relative safety importance.
Section 17.2.7.6 then goes on to state that procedures will provide for the acceptance-of-simple, off-the-shelf items based exclusively on receiving inspection with no quality verification documentation require -
ments.
It is the staff's position that the involved design engineering organization and quality assurance organization should jointly determine the extent of inspection verification and the qu' ty verification docu-mentation requirements based on the item's end use.
Revise the FSAR to reflect this position.
l 260.27WC Describe the involvement of KG&E's QA and QC organizations in 'he l
(17.2.7) acceptance of items by post-installation test.
260.28WC Describe the involvement of KG&E's QA and QC organizations in the (17.2.7) final acceptance of services.
l 260.29 WC Describe the ir.volvement of KG&E's QA and QC organizations in the (17. 2.9)'
control of special processes.
1 I
260.30 WC
- Expand the list of special processes given in Sec. tion 17.2.9.1 of the l
(17.2.9)
Wolf Creek FSAR so that the list is as complete as possible.
(
260.31 WC Describe measures which assure the recording of evidence of acceptable (17. 2.9) accomplishment of special processes using only qualified procedures, i
equipment, and personnel.
I l
260.32 WC Identify the KG&E organization (s) responsible for qualifying special (17.2.9.1) process equipment and for maintaining the qualification of such equip-ment.
Discuss the records associated with qualifying special process equipment.
260.33WC It is not clear that KG&E personnel who perform inspections and process (17.2.10) monitoring are part of the QC organization under the QC Supervisor.
Clari fy. Since QA personnel do not perform inspections and process monitoring, provide a commitment that procedures, personnel qualifica-tion criteria, and personnel independence from undue pressure of cost and schedule are reviewed and found acceptable by the QA organization prior to initiating the inspection or monitoring.
260.34WC Section 17.2.10b of the Wolf Creek FSAR indicates that inspections and (17.2.10 &
NDE may be accomplished by "outside organizations." Describe how UE 17.2.11) assures acceptable inspection /NDE procec'ures, qualification of the inspection /NDE personnel, and independence from undue cost and schedule pressures for these outside organizations. Provide the same informa-tion for testing activities performed by outside organi ations.
260.35 WC Provide a commitment that procedures specify criteria for determining (17.2.11) when a test is required or how and when tests are performed.
260.36 WC The description of the control of measuring and test equipment in (17.2.12)
Section 17.2.12.2 of the Wolf Creek FSAR includes the following sen-tence:
" Permanently installed process instrumentation is not includ-ed in this listing" (of controlled equipment).
Describe the QA con-trols over permanently installed process instrumentation and discuss the differences between these controls and the controls described in Section 17.2.12.
260.37 WC Provide a conunitment that measuring and test equipment is labeled or (17.2.12) tagged to indicate the due date of the next calibration.
260.38 WC Discuss the documentation and management authorization required by (17.2.12)
KG&E when:
a.
M&TE cannot be calibrated against standards that have an accuracy j
at least four times the required accuracy of the M&TE.
b.
Calibrating standards do not have greater accuracy than star.dards being calibrated.
260.39WC Section 17.2.13.2 states that storage procedures may prescribe require-(17.2.13) ments "in lieu of" requirements contained in the manufacturer's recomen-l dations. It appears that " supplementary to" or "in addition to" would be more appropriate than "in lieu of".
Clarify.
260.40WC Describe provisions for the storage of chemicals, reagents (including (17.2.13) control of shelf life), lubricants, and other consumable materials.
. 260.41 WC Describe how KG&E controls the application and removal of inspection (17.2.14) stamps, welding stamps, and status indicators such as tags, markings, labels, and other stamps.
260.42 WC Section 17.2.14.4 states that KG&E will control the sequence of tests, (17.2.14) inspections, and other operations in accordance with administrative procedures. Describe the procedure for such control. Such actions should be subject to the same controls as the original review and appro-val.
260.43 WC Clarify what is meant by the statement in 17.2.14.3 that procedures (17.2.14) shall address methods for " initiating, maintaining, and releasing equipment control for maintenance, etc...."
260.44 WC Clarify Section 17.2.15.1 of the Wolf Creek FSAR that nonconformances (17.2.15) also include inoperative and malfunctioning structures, systems, and components.
260.45WC Describe QA controls over conditionally released nonconforming items.
(17.2.15)
Identify reinspection criteria for repaired and reworked items and indicate how reinspection requirements and performance are documented.
Identify individuals (by position title) or groups with authority to disposition nonconformances. Identify the individual (by position title) or group that performs the trend analysis discussed in Section 17.2.15.7.
260.46WC Provide a commitment that nonconformances are corrected or resolved (17.2.15) prior to initiation of the preoperational test program on the item.
260.47WC Discuss the timeliness of actions taken to close out CARS and the follow-(17.2.16) up action.
l 260.48 WC Discuss the " surveillance" portion of the KG&E audit system as mentioned (17.2.18) in Section 17.2.18.1 of the FSAR.
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