ML19350C163
| ML19350C163 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/26/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Ryan J UNION ELECTRIC CO. |
| References | |
| NUDOCS 8103310372 | |
| Download: ML19350C163 (7) | |
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MAR 2 61981 Dockat tio.: STfl 50-483 Mr. John K. Bryan Vice President Union Electric Company 1901 Gratiot Street P. O. Box 149 St. Louis, Missouri 63166
Dear Mr. Bryan:
Subject:
Request for Additional Information for the Review of the Callaway Plant, Unit 1 As a result of our continuing review of the Callaway Plant, Unit 1 FSAR, we find that we need additional information to complete our evaluation. The specific information required is in the area of quality assurance and is presented in the Enclosure.
To maintain our licensing review schedule for the Callaway Plant FSAR, we will need responses to the enclosed request by April 25, 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, Callaway Licensing Project Manager, if you desire any. discussion or clarification of the enclosed request.
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4 Sincerely, 8-e3
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tM@3q$BF -poo $/ Robert L. Tedesco, Assistant D t
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Enclosure:
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As stated cc: See next page 810saIo37L j
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Mr. J. K. Bryan Vice President - Nuclear Union Electric Company P. O. Box 149 St. Louis, Missouri 63166 cc: Mr. Nicholas A. Petrick Mr. William Hansen Executive Director - SNUPPS Resident Insoector/Callaway NPS 5 Choke Cherry Road c/o USNP.C Rockville, Maryland 20850 Steedman, Missouri 65077 Gerald Charnoff, Esq.
Shaw, Pittman, Potts &
Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 Mr. J. E. Birk Assistant to the General Counsel Union Electric Company P. 0. Box 149 St. Louis, Missouri 63166 Dr. Vern Starks Route 1, Box 863 Ketthikan, Alaska 99901 Ms. TrevaHearn, Assistant General Counsel Missouri Public Service Commission P. O. Box 360 Jefferson City, Missouri 65102 Mr. D. F. Schnell Manager-Nuclear Engineering Union Electric Company P. O. Box 149 St. Louis, Missouri 63166 A
Request for Additional Information Callaway Plante Unit 1 Docket No. STN 50-483 260.00 Quality Assurance Branch 260.52C Union Electric Company's comitment to meet the Regulatory Position of the Regulatory Guides listed in Item 260.1 is unclear in some cases because Appendix 3A in the Callaway FSAR Addendum is different from Appendix 3A in the SMUPPS Standard Plant FSAR. Resolve the differences noted below.
Reg.
Callaway SNUPPS Guide Addendum Standard Plant 1.8 Refers to 2/79 version Refers to 5/77 version 1.26 Not listed 1.29 Not listed 1.58 Refers to 9/80 version Refers to 8/73 version 1.94 Not listed 1.144 Refers to 9/80 version Refers to 1/79 version 1.146 Not listed Regarding the comitment to Regulatory Guides concerning quality assurance, the " Discussion" items noted below need clarification or revision.
1.8 The discussion refers to Site Addendum Section 17.1 and does not make it clear that Union Electric Company meets the Regulatory Position of the guide with the clarification noted in the second paragraph of the discussion. Clarify.
1.30 The extent to which Union Electric Company conforms to this Regu-latory Guide is not clear. Clarify.
1.33 The discussion states:
" ANSI 18.7-1976/ANS-3.2 references certain other standards which comprise the regulatory position of Regulatory Guide 1.33."
This requires clarification in that the regulatory position includes much more than the list of other standards.
Clarify. The extent to which Union Electric Company confoms to this Regulatory Guide also needs clarification.
1.38 Clarify the second paragraph of the discussion regarding manufac-turer's requirements by either (a) eliminating it (The standard only requires that the manufacturer's requirements "be considered.")
or (b) including the statement from the response to item 260.38 that:
"The relaxation of manufacturers' storage requirements involves an engineering evaluation and is justified when unrealistic storage requirements are recommended and such reconinendations are not reason-ably necessary to preclude equipment degradation." Also clarify the extent to which Union Electric Company conforms to this Regulatory Guide.
1.58 The discussion states that factors other than those stated in ANSI N45.2.6 may be considered for portions of the education and exper-ience requirements. Provide examples of what these factors might be.
1.64 Clarify the extent to which Union Electric Company confoms to this Regulatory Guide. NRC's position regarding design verification by
- the designer's immediate supervi-r is given below (cf. item 17.1.3E2.a of the SRP*).
In exceptional circumstances, the designer's immediate supervisor can perform the verification provided:
(1) The supervisor is the only technically qualified individual.
(2) The need is individually documented and approved in advance by the supervisor's management.
(3) QA audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
Comit to meet this position or provide an alternative for our evaluation.
1.74 It is the staff position that certificates of conformance and certi-ficates of compliance should be signed by a responsible party from the certifier's organization. Comit to meet this position or sub-mit an alternative for our evaluation. Clarify the extent to which Union Electric Company conforms to this Regulatory Guide.
1.88 Clarify the extent to which Union Electric Company conforms to this Regulatory Guide.
1.144 Clarify the extent to which Union Electric Company conforms to this Regulatory Guide. Also, the first sentence of the discussion is unacceptable. The staff position given in Section C.3.b.(2) of Regulatory Guide 1.144 is a minimum requirement. More frequent audits, based on status and importance to safety, are acceptable.
Comit to meet the staff position or provide an alternative for our evaluation.
260.53 C.The response to item 260.5 is unacceptable.
It is the staff position that Union Electric Company execute an agreement with an Authorized Inspection Acency to obtain the independent third-party inspection coverage of Code it 's which is normally supplied by an Authorized Inspector. Comit to meet this position or provide an alternative #or our evaluation. We do not accept the determination of insurability ',y American Nuclear Insurers as a viable alternative.
260.54 C Incorporate more of the response to item 260.7 into the FSAR. That is, include the statement that:
"Related consumables utilized in safety-related structures, systems, and components, although not listed in Table 3.2-1, are also under the control of the 0QAP." Also clarify in the FSAR that the OQAP is the governing quality assurance program during the operations phase for 4
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- SRP refers to revision 1'of the Standard Review Plan, NUREG-75/087.
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items in Table 3.2-1 which have a "Y" under the " Quality Assurance" head-ing and that the programs identified under this headina are those used during the design and construction phase.
260.55 C The response to item 260.10, regarding management overview of QA for the Callaway Plant, relies too heavily on the NSRB which is chaired by the Manager, Nuclear Engineering. The staff is more concerned with the invc(ve-ment of the Vice President Nuclear and his management in the Callaway Plant QA program. Describe how they maintain frequent contact with the QA program status.
260.56 C The meaning of the underlined words in item 260.11 is still unclear. Clarify or delete them.
260.57C Make the implicit intent to " document errors and deficiencies identified in approved design documents and to control (i.e., review and approve) the process of correcting any errors or deficiencies" explicit in the FSAR.
(See the response to item 260.12.)
260.58C The response to item 260.13 is unacceptable. Our position regarding design verification by the designer's immediate supervisor is given under Regula-tory Guide 1.64 in item 260.52. The response to item 260.52 should be reflected in the response to item 260.13. Otr position regarding the time-liness of design verification during the operations phase is given below (cf. item 17.1.3E2 of the SRP).
Design verification, if other than by qualification testing of a
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prototype or lead production unit, is completed prior to release for procurement, manufacturing, construction or to another organi-zation for use in other design activities.
In those cases where this timing cannot be met, the design verification may be deferred, providing that the justification for this action is documented and the unverified portion of the design output document and all design output documents, based on the unverified data, are appropriately identified and controlled. Site activities associated with a design or design change should not proceed without verification past the point where the installation would become irreversible (i.e., require extensive demolition and rework).
In all cases, the design verifi-cation should be complete, prior to relying upon the component, I
system, or structure to perform its function.
Comit to meet these positions or provide alternatives for our evaluation.
We do not accept a commitment to c.omplete design verification orfor to reliance on the safety-related component, sistem, or structure to perform its safety function as a viable alternative for the position stated above.
260.59 C Incorporate into the FSAR the clarification provided in the response to item 260.14 that an independent third-10iel review will be employed as an addi-tional verification when uniqueness or special design consideratio'ns make suchareviewappropriate4 i
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260.17, 260.23, and 260.48 into the FSAR.
260.60 C Incorporate the response ofsitems l
. 260.61 C The res;;ase to item 260.19 limits the QA Department's review of procure-ment documents to a verification that quality requirements as outlined in Section 3.2.3 of AfiSI f145.2.13-1976 have been incorporated, and Section 17.2.4 has been revised accordingly. The staff position regarding the review of procurement documents which the FSAR does not address is given below (cf. item 17.1.4Al of the SRP).
Procedures are established for the review of procurement docu-ments to determine that quality requirements are correctly stated, inspectable, and controllable; there are adequate accepta' ice and rejection criteria; and procurement documents have been prepared, reviewed, and approved in accordance with QA program requirements.
Comit to meet this position or provide an alternative for our evaluation.
If a commitment is made to meet this staff position, indicate who (by post-tion title) or what group performs the review.
Drawings, whether a part of a procurement document or for in-house use only, should also receive the kind of review noted in the aNve staff position and should also be addressed in the response to this item.
260.62 C Incorporate into the FSAR the fact that the approval of a procurement docu-ment by an individual with approval authority signifies the technical and quality reviews of the document have been completed.
(See the response to item 260.20.)
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260.63C The response to item 260.24 indicates that the QA Department only examines I
implementino proceduNs on an audit basis. The staff position regarding the review of maintenance, modification, an>' inspection procedures is given below (cf, item 17.2.6.3 of the SRP).
Maintenance, modification, and inspection procedures are reviewed by qualified personnel knowledgeable in QA disciplines (normally the QA organization) to determine:
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a.
The need for inspection, identification of inspection per-sonnel, and documentation of inspection results, b.
That the necessary inspection requirements,' methods, and acceptance criteria have been identified.
Commit to meet this position or provide an alternative for our evaluation.
If a comitment is made to meet this staff position, indicate who (by posi-tion title) or what group performs the review.
260.64 C On page 17.2-25, Revision 2 states that the extent of acceptance methods i
and associated verification activities will vary as a function of the rela-l tive importance and complexity of the purchased item or service and the supplier's past performance. Clarify that the "importance" mentioned is the item's or service's importance to safety or relative safety importance.
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Revision 2 then goes on to state that procedures will provide for the accep-tance of simple "off-the-shelf" items based exclusively on receiving inspec-tion with no quality verification documentation requirements.
It is the staff's position that the involved design engineering organization and quality assurance organization should jointly determine the extent of inspection veri-fication and the quality verification documentation requirements based on the item's end use. Revise the submittal to reflect this position.
260.65C The response to item 260.25 states that the originating organization (of procurement documents)makes judgements regarding verification activities and that the QA department will not review and approve specific suppliers moni-toring activities prior to implementation. Regarding such review and ap-proval, the staff position is given below (cf. item 17.1.6A2 of the SRP).
The QA organization, or an individual other than the person who generated the document but qualified in quality assurance, reviews and concurs with these (procurement) documents with regards to QA-related aspects.
Comit to meet this position or provide an alternative for our evaluation.
If a commitment is made to meet this staff position, indicate who (by posi-tion title) or what group performs this review.
If not the QA organization, discuss QA qualifications.
260.66C The staff position regarding quality assurance for the procurement of spare or replacement parts as reflected in item 260.27 is given below (cf. item 17.1.7A4 of the SRP).
Procurement of spare or replacement parts for structures, systems, and components important to safety is subject to present QA program controls....
Commit to meet this position or provide an alternative for our evaluation.
260.67 C Concerning the permanently installed instrumentation for the Callaway Plant, it is the staff position that this equipment should be under the QA program controls described in 17.2.12 of the FSAR. Comit to meet this position or provide an alternative for our evaluation.
260.68 C As discussed under Regulatory Guide 1.38 in item 260.52, above, clarify the basis for relax.' tion of manufacturer's storage requirements in Section 17.2.13 of the Callaway FSAR.
260.69 C Item 260.41 requests a consnitment that alterations of the sequence of required tests, inspections, and other operations important to safety are subject to the original review and approval controls. The response does not provide such a conunitment. Clarify.
260.70 C Clarify what is meant by the statement in 17.2.14 that procedures shall address methods for'" initiating, maintaining, and releasing equipment con-trol for maintenance....".(See item 260.42.)
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