ML19352A916

Forwards Addl QA Info,In Response to NRC 810326 Ltr. Responses Will Be Formally Incorporated Into Future FSAR Revisions

ML19352A916
Person / Time
Site:	Callaway
Issue date:	05/22/1981
From:	Bryan J UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
ULNRC-447, NUDOCS 8106020337
Download: ML19352A916 (27)

Text

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7gO UNION ELECTRIC COMPANY . / ,

1908 GRATIOT STREET .Q /

sT. Louis MissouR W

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JOHN s(, GRV AN o, me. ......."'

May 22, 1981 "'*"'**""'**'**

Mr. Harold R. Denton Director of Nuclear Reactor Regulation _.j US Nuclear Regulatory Commission d 1/

Washington, DC 20555 ULNRC '4 47

Dear Mr. Denton:

DOCKET NUMBERS 50-483 AND 50-486 CALLAWAY PLANT UNITS 1 & 2 FINAL SAFETY ANALYSIS REPORT

Reference:

NRC letter dated March 26, 1981 signed by R. L. Tedesco The referenced letter requested additional information concerning the Callaway Plant FSAR. The specific nature of the requested information was in the area of quality assurance. Trans-n'itted herewith are responses to the referenced letter's questions.

These responses reflect the consensus reached during an April 24, 1981 meeting of the NRC (Messrs. W. Haas, J. Spraul, and A. Dromerick) and Union Electric and SNUPPS Staff representatives; and subsequent discussions and reviews with J. Spraul on May 19 and 20, 1981.

We trust these responses are acceptable and therefore plan their formal incorporation into the FSAR in future revisions (Note- A complete incorporation of these responses requires a revision to the SNUPPS Standard Plant FSAR as well as the Callaway Addendum).

The information is hereby incorporated into the Callaway Application.

Should any questions remain regarding the acceptability of these responses please contact S. J. Seiken of the SNUPPS Staff.

Very ,ruly yours, i n,

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[' 'J(o n K. u 6 t\

Bryan s

JJS/jds 66 66 b

i. 8106020 3 3'7

STATE OF MISSOURI )

) S S CITY OF ST. LOUIS )

John K. Bryan, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belie f.

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y'*b By 1[% c-Aggp C6hn'K. Tryan

! ice President

!]'J Nuclear SUBSCRIBED and sworn to before me thig 22nd day of May, 1981 D~s . ? ' ~

Q . L'a .

l f/. 'OG AHLT S. HEID A fiOT A'If P'JSUC-STML OF MISSCURI ST. LO'JIS COUNTY MY C0'.' MISSION EAPihES JANUARY 2,1982

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cc: Glenn L. Koester Vice President Operations Kansas Gas & Electric PO Box 208 Wichita, KS 67201 John E. Arthur Chief Engineer Rochester Gas & Electric Company 89 East Avenue Rochester, NY 14649 A. V. Dienhart Vice President Plant Engineering and Construction Northern States Power 414 Nicollet Mall Minneapolis, MN 55401 Donald T. McPhee Vice President Kansas City Power and Light Company 1330 Baltimore Avenue Kansas City, MO 64141 Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1810 M. Street, N.W.

Washington, DC 20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Rd.

Rockville, MD 20850 W. Hansen Callaway Resident Office US Nuclear Regulatory Commission RR#1 Steedman, MO 65077 S. J. Seiken OA Manager Si;UPPS 5 Choke Cherry Rd.

Rockville, MD 20850

SNUPPS-C Item 260.13 Section 17.2.3 of the Callaway FSAR, on page 17.2-12, s t e.t e s : " Design verification shall be performed by.

personnel other than those who performed the original design and shall be accomplished prior to reliance on t the safety-related component, system, or structure to.

perform-its safety function." Concerning the personnel, provide a commitment that the verifier is

. qualified and is not directly responsible for the design or design change (i.e., neither the designer nor his immediate supervisor). Concerning the timing, provide a commitment that design verification is normally completed prior to release for procurement, manufacture, or installation 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 controlled. Include such a commitment.

Response: Section 17.2.3 will be revised to reflect the commitment that design- verification shall oe performed j by " competent" personnel; however, we consider it imperative that we maintain the option whereby an individual's-immediate supervisor may perform design l'

verification. Accordingly we have identified this exception in Appendix 3A of this Addendum. We forsee the necessity of utilizing immediate supervisors in i design review in cases when they are the only available  !

technically qualified individuals. In such cases, as well as in all other design reviews, the requirements ,

of Regulatory Guide 1.64, Rev. 2, June 1976, Section

! l C.2(2), (3) and (4) remain applicable. In addition the l need for design verification by the designer's l immediate supervisor will be individually documented  ;

I and approved in advance by the supervisor's management l and Quality Assurance Department audits will examine

l the frequency and effectiveness of use of supervisors

I as design verifiers. Points 1, 2, and 3 of the staff f l position presented under Regulatory Guide 1.64 in Item  ;

I 260.52C will be incorporated in Section 17.2.3.  ;

l In regard to the timing of the completion of design j, l Verification our commitment is delineated in response  ;

l to Item 260.58C.  ;

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260.13-1

s SNUPPS-C I

Item 260.52C: -Union Electric Company's commitment 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 SNUPPS Standard Plant FSAR.

Resolve the differences noted below. ,

Reg. Callaway SNUPPS Guide Addendum Standard Plant r

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 '

l.94 Not listed 1.144 Refers to 9/80 version Refers to 1/79 version  :

1.146 Not listed Regarding the commitment 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 1 of the guide with the clarification noted in the second paragraph of the discussion.

i Clarify.

1.30 The extent to which Union Electric Company l conforms to this Regulatory Guide is not clear. i Clarify.

l.33 The discussion states: " ANSI 18.7-1976/ANS-3.2 '

references certain other stande.rds 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  ;

conforms to this Regulatory Guide also needs c]arification.  !

l' 1.38 Clarify the second paragraph of the discussion [

regarding manufacturer's requirements by either i

, (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 f and is justified when unrealistic storage i

requirements are recommended and such recommendations are not reasonably necessary to

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~ . - . = . _ - - . - .

SNUPPS-C preclude equipment degradation." Also clarify the extent to which Union Electric Company conforms to this Regulatory Guide. '

l.58 The discussion states that factors other-than those stated in ANSI N45.2.6 may be considered for portions of the education and-experience r

requirements. Provide examples of what these factors might be.

1.64 Clarify the extent to which Union Electric Company conforms to this Regulatory Guide. l NRC's position regarding design verification by

! the designer's immediate rupervisor is given i below (cf. item 17.1. 3E2.a of the SRP* ) . .

I 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 j 4 and approved in advance by the  !

3 supervisor's management.

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(3) OA audits cover frequency and effectiveness of use of supervisors ,

as design verifiers to guard against abuse.

J Commit to meet this position or provide an f alternative for our evaluation.

1.74 It is the staff position that certificates of conformance and certificates of compliance should be signed by a responsible party from  ;

the certifier's orgas ization. Commit to meet I this position or submit an alternative for our

evaluation. Clarify the extent to which Union i

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Electric Company conforms to this Regulatory

] Guide.

l.88 Clarify the extent to which Union Electric Company conforms to this Regulatory Guide.

1 l 1.144 Clarify the extent to which Union Electric >

j Company conforms to this Regulatory Guide.

j Also, the first sentence of the disc"ssion is i unacceptable. The staff position given in

• SRP refers to revision 1 of the Standard Review Plan, NUREG-75/087. l 4 r j 260.52C-2

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SNUPPS-C 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. Commit to meet the staff position  ;

or provide an alternative for our evaluation.- i Response: i

, As you have noted the FSAR Standard Plant Appendix 3A refers to-the Addendum Appendix 3A for the specific regulatory commitment for certain regulatory guides; '

however, in the cases where a reference is not made to. .

the Addendum Appendix 3A the Union Electric commitment is as stated in the Standard Plant Appendix 3A and the  ;

same regulatory position is not repeated in the  ;

Addendum Appendix 3A. This format accounts for the i absence of the listing of regulatory guides 1.26,  !

1.29, and 1.94 in the Callaway Addendum Appendix 3A. t 4

i In the cases of regulatory guides 1.8, 1.58, and 1.144 [

the Standard Plant Appendix 3A reference will be s modified to reflect the same version as noted in the  !

Addendum Appendix 3A. 7 i r In regard to regulatory guide.l.146 the Standard Plant Appcndix 3A will be revised to include its listing and i a reference to the Addendum Appendix 3A. [

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" Discussion" Items l

RG 1.8 It is believed you intended to reference Section 13.1; 7 nevertheless, Appendix 3A of this Addendum will be revised  !

to state that UE complies with the recommendations of this

regulatory guide with the following clarification-

" Personnel responsible . . . not be certified."  !

, RG 1.30 Appendix 3A of this Addendum will be revised to state that

, UE complies with the recommendations of this regulatory [

guide with the following exceptions: "UE concurs . . .  !

j (ANSI N45.2.4, Section 6.2.1)."

l RG 1.33 Appendix 3A of this Addendum will be revised to state that l UE complies with the recommendations of this regulatory i guide with the following clarification and exception:  !

" ANSI N18.7-1976/ANS 3.2 references certain other standards I

! which comprise a portion of the regulatory position . . .

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. is not adopted." l 1

! RG 1.38 Appendix 3A of this Addendum will be revised to state that  ;

1 UE complies with the recommendations of this regulatory guide with the following exceptions: "UE takes exception .

. . (Section 6.6, ANSI N45.2.2)." In addition the second paragraph of the discussion will be deleted.

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4 SNUPPS-C RG 1.58 Appendix 3A of this Addendum will be revised to r, tate that l UE complies with the recommendations of this regulatory

, guide with the following clarification: "The qualification of UE OC . . . Section 3.4.2." In addition the second 4

paragraph of the. discussion will be revised to state, as .

permitted by the regulatory guide, that in instances where the. education ar.4 experience recommendations of ANSI N45.2.6-1978 are not met, UE will demonstrate by. documented results of written examinations and evaluations of actual ,

work proficiency that individuals possess comparable or equivalent competence. 1 I

RG 1.64 Appendix 3A of this Addendum will be revised to state that UE complies with the recommendations of this regulatory guide with the following exception: "UE maintains . . .

and 4 remain applicable." In addition points 1, 2 and 3'of

, the sta f f position will be adopted and incorporated in Section 17.2.3.

PG 1.74 Appendix 3A of this Addendum will be revised to state that

. UE complies with the recommendations of this regulatory ,

guide. It will be Union Electric's policy to require

, signed certificates of conformance and compliance or certificates accompanied by signed letters of transmittal.

! RG 1.88 Appendix 3A of this Addendum will be revised to state that  ;

UE complies with the recommendations of this regulatory guide with the following clarification: "Where the duplicate . . . temperature and humidity."

RG 1.144 Appendix 3A of this Addendum will be revised to state that

. UE complies with the recommendations of this regulatory guide with the following clari fications: It is Union

. Electric's intent to utilize audits performed by others ,

, (C.5) to fulfill triennial audit requirements. In '

addition, the need for a triennial eudit may be precluded upon evaluation and documentation by the OA Department that the results of mini-audits performed during source inspection and source surveillance activities confirm the i adequacy and implementation of the supplier's OA program.

Section 17.2.18 will be revised to reflect the staff I position outlined under Regulatory Guide 1.144 of Item i

! 260.52C.

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_.___. ._ _ . _ _,.~260 52C..4_ _ _ . _ . _ _ _ _ _ _ . . _ _ . . _

SNUPPS-C Item 260.53C The response to item 260.5 is unacceptable. It is the staff position that Union Electric Company execute an agreement with an Authorized Inspection Agency to obtain the independent third-party inspection coverage of Code items which is normally supplied by an Authorized Inspector. Commit to meet this position or provide an alternative for our evaluation. We do not accept the determination of insurability by American Nuclear Insurers as a viable alternative.

Response All Callaway Plant operating phase " code" activities will be performed in accordance with the ASME Code.

This compliance will include the independent third-party inspection coverage of " code" items by an Authorized Nuclear Inspector. Section 17.2.2 will be revised to reflect this commitment. ,

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260.53C-1

SNUPPS-C

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Item 260.54C Incorporate more of the response to item 260.7 into ,

the FSAR. That is,-include the statement that:  !

"Felated consumables utilized in safety-related structures, systems, and components, although not listed in Table 3.2-1, are.also under the control of the OOAP." Also clarify.in the FSAR that the OOAP is  ;

the governing quality assurance program during the  ;

operations phase for items in Table 3.2-1 which have a "Y" under the " Quality Assurance" heading and that the programs identified under this heading were those used  ;

during the design and construction phase.

• Response: Section 17.2.2 will.ima revised to include the statement that related consumables utilized in safety-  :

related structures, systems, and components, although

• 4 not listed in Table 3.2-1, are also under the control '

of the OOAP. The notes to Standard Plant FSAR Table  ;

3.2-1 will also be revised to clarify that the utility's operating quality assurance program is the governing quality assurance program during the operating phase for items in Table 3.2-1 which have a

! "Y" under the " Quality Assurance" heading and that tho  ;

programs identified under this heading are those used  ;

during the design and construction phase. '!

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SNUPPS-C 260.55C The response to item 260.10, regarding management overview of OA for the Callaway Plant, relies too l heavily on the NSRB which is chaired by the Manager,  ;

Nuclear Engineering. The staff is more concerned with

the involvement of the Vice President Nuclear and his management in the Callaway Plant OA program. Describe- ,

how they maintain frequent contact with the OA program status.

Response: The Vice President, Nuclear's involvement in the i Callaway OA Program is continuous. As the head of the Nuclear Function, he is a dedicated Vice President

] (i.e., his responsibilities are solely nuclear) responsible for the design, construction, and operation of the Callaway Plant. He maintains an i awareness of program activities through weekly  ;

meetings with his general managers and department  !

managers ar.d monthly reports provided him regarding function activities. A monthly report provided by the Manager, Quality Assurar.ce specifically concerns OA l Department activitjes and specific quality issues, and  !

is provided to all staff meeting-participants to keep them apprised of the OA program status. Exclusive of these scheduled meetings and reports, the Vice ,

President, Nuclear maintains frequent contact and [

communications with OA and other key management' l personnel in the course of routine daily interchanges  :

and remains directly accessible to OA management.

l In addition to the aforementioned involvement, it .

I should be noted that the NSRB reports its "1 dings and I recommendations to the Vice President, Nuc- ar for his action, as appropriate. Cumulatively, theoe actions i serve to maintain an awareness of the OA program (

status within the function management outside the OA t Department. I

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SNUPPS-C 260.56C The meaning of the underlined words in item 260.11 is still unclear. Clarify or delete them.

Response: The underlined words noted in Item 260.11 will be deleted from Section 17.2.3.

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260.56C-1

SNUPPS-C 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.)

Response: The response to Item 260.12 will be incorporated in Section 17.2.3.

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4 SNUPPS-C 260.58C The response'to item 260.13 is unacceptable. Our position regarding design verification by the designer's immediate supervisor is given under Regulatory Guide 1.64 in item 260.52. The response to  ;'

item 260.52 should be reflected in the response to item.260,13. Our position regarding the timeliness 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 prototype or Icad 4

production unit, is completed prior co release for procurement, manufacturing, construction or to another organization 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 x1 the unverified portion of the design outime 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 verification should be complete, prior to relying upon the component, system, or structure to  :

perform its function.

Commit to meet these positions or provide alternatives '

for our evaluation. We do not accept a commitment to [

complete design verification prior to reliance on the i safety-related component, system, or structure to I perform its safety function as a viable alternative i for the position stated above. I 1 r Response: The response to Item 260.52C under Regulatory Guide l.64 addresses the sta f f position regarding design l verification by the designer's immediate supervisor. '

The response to Item 260.52C will be incorporated in a i revision to the previous response to Item 260,13.

• Regarding the timeliness of design verification during  :

the operating phase, Union Electric endorses the staff i position identified in Item 260.58C and will l

, incorporate this position in Section 17.2.3.

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SNUPPS-C 260.59C Incorporate into the FSAR the clarification provided in the response to item 260.14 that an independent third-level review will be employed as an additional verification when uniqueness or special design considerations make such a review appropriate.

Response: The clari fication provided in response to Item 260,14 will be incorporated into Section 17.2.3 as follows:

An independent third-level review will be employed as an additional verification when Union Electric judges that the design involves unique or special design features.

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SNUPPS-C 260.60C Incorporate the response of items 260.17, 260.23, and 260.48 into the FSAR.

Response: The response to Items 260.17, 260.23, and 260.48 will be incorporated in Sections 17.2.3, 17.2.6, and 17.2.16, respectively.

j 260.60C-1

SNUPPS-C P

I 260.61C The response to item 260.19 limits the OA Department's review of procurement documents to a verification that quality requirements as outlined in Section 3.2.3 of ANSI N45.2.13-1976 have been incorporated, and Section 17.2.4 has been revised accordingly. The staff position regarding the review of procurement documents which the PSAR does not address is given below. (cf.

item 17.1.4A1 of the SRP).  ;

i' Procedures are established for the review of procurement documents to determine that quality i requirements are correctly stated, inspectable and controllable; there are adequate acceptance and rejection criteria; and procurement documents have l been prepared, reviewed, and approved in ,

accordance with OA program requirements.

Commit to meet this position or provide an alternative for our evaluation. If a commitment is made to meet this staff position, indicate who (by position title) '

or what group performs the review. i Drawings, whether a part of a procurement document or for in-house use only, should also receive the kind of i review noted in the above staff position and should r also be addressed in the response to this item. l t

Response: The Quality Assurance Department and the internal  ;

Union Electric organization originating the [

procurement document perform reviews of procurement documents in accordance with written procedures. .

Collectively, their reviews will address all the [

points of the staff position outlined in 260.61C, I above. The OA Department will review procurement [

documents to assure that the quality requirements are  :

, correctly stated and that they have been prepared, reviewed and approved in accordance with OA program requirements. Quality requirements are considered to 3 be those outlined in Section 3.2.3 of ANSI N45.2.13- t 1976. The originating organization will independently review procurement documents to assure requirements (

are correctly stated, inspectable and controllable and i that there are adequate acceptance and rejection  ;

criteria.

Drawings will be prepared under a drawing control system which provides for checking methods and review

, and approval requirements. Drawings will be subject to reviews by the originating organization for '

correctness, comoleteness, conformance to design [

criteria, and compliance with applicable codes and  !

standards. The OA Department examines drawings, on an t audit basis, for evidence that they have been i

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SNUPPS-C prepared, reviewed, and approved in accordance with OA program requirements.

In addition, as noted in our response to Item 260.65C, the QA Department's review of procurement documents ,

includes concurrence with the need for post award supplier monitoring; i.e., source inspection and/or source surveillance.

The FSAR will be revised to reflect this clarification.

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SNUPPS-C 260.62C Incorporate into the FSAR the fact that the approval of a procurement document 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.)

Response: Section 17.2.4 will be revised to state that the approval of a procurement document by an individual with approval authority signifies the technical and quality reviews of the document have been completed.

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260.62C-1

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i 260.63C The rcsponse to item 260.24 indicates that the OA Department only examines implementing procedures on an ,

audit basis. The staff position regarding the review of maintenance, modification, and 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 OA disciplines (normally the OA .

organization) to determine I,

a. The need for inspection,' identification of inspection personnel, and documentation of inspection results.

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, b. That the necessary inspection requirements, l

methods, and acceptance criteria have been l identified.

Commit to meet this position or provide an alternative for our evaluation. If a commitment is made to meet this staff position, indicate who (by position title) or what group performs the review.

Response: The staff position outlined in Item 260.63C is acceptable and is met in the following manner.

The OA Department reviews administrative procedures;

• the QC Group reviews maintenance and modification procedures; and the OC Group is responsible for_the  !

preparation of inspection procedures and/or checklists I j to support maintenance and modification activities.  !

Collectively, these reviews by the OA Department and i 4

the QC Group determine:

a. The need for inspection, identification of i inspection personnel, and documentation of  ;

inspections results; and [

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b. That the necessary inspection requirements, l methods, and acceptance criteria have been j identified. i t

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This commitment will be incorporated in Section 17.2.6 of the FSAlt .

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260.63C-1

SNUPPS-C 250.64C On page 17.2-25, Revision 2 states that the extent of 9 acceptance methods and associated verification ,

activities will vary as a function of the relative importance and. complexity of the purchased item or  !

, service and the supplier's past performance. Clarify l 1

that the "importance" mentioned is the items or i i service's importance to safety or relative safety importance. l t

Revision 2 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 requirements. <

It is the staff's position that the- involvel design engineering organization ard quality assurance j 1.

organization should jointly determine the extent of

' inspection verification and the quality verification i documentation requirements based on the item's end l use. Revise the submittal to reflect this position.

l Response: Section 17.2.7 will be revised to state that the -

extent of the acceptance methods and associated l-verification activities will vary and be a function of  !

the purchased item's or service's complexity and relative safety significance; as well as the  ;

supplier's past performanco. j In regard to the concern that the acceptance of "off-the-shelf" items will exclude a requirement for i

quality verification documentation, it should be noted that in these types of procurements it is our intent that supplier-generated verification documentation, only, will not be required. Documentation will be generated as a result of receiving inspection '

activities. Section 17.2.7 will be revised to reflect  ;

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A SEUPPS-C 260.65C The response to item 260.25 states that the originating organization (of procurement documents) makes judgements .regarding verificat lon activities and "

that the OA Department-will not review and approve specific supplier monitoring activities prior to implementation. Regarding such review and approval, the staff position is given below (cf. item 17.1.6A2 of the SRP).

The OA organization, or an individual other than the person who generated the document but

• qualified in quality assurance, reviews and ,

concurs with these (procurenent) documents with  ;

i' regards to OA-related aspects.

1 Commit to meet this position or provide an alternative i for our evaluation. If a commitment is made to meet this staff position, indicate who (by position title) i or what group performs this review. If not the OA

-organization, discuss OA qualifications. E i

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Response

The staff position outlined in Item 260.65C is  ;

j acceptable and Section 17.2.7 will be revised to state [

i that the OA Department will review procurement [

documents and concur with the originating j organization's determination of need for post award i supplier monitoring; i.e., source inspection and/or t source surveillance. l

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SNUPPS-C .

c 260.66C The staff -ition regarding quality assurance fer the procuremens ,i spare or replacement parts as reflected in item 260.27 is given below (cf. item 17.1.7A4 of the SRP). l Procurement of spare or replacement parts for structures, systems, and components important to safety is subject to present OA program controls .

Commit to meet this position or provide an alternative

.r our evaluation. j Response: The staff position of Item 260.66C is acceptable with the following clarification:

The procurement of spare or replacement parts for ,

safety-related structures, systems, and components is  ;

subject to present QA program controls, to codes and standards, and to technical requirements equal to or better than the original technical requirements, or as l'

required to preclude repetition of defects. This position will be incorporated in Section 17.2.4.

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t4' SNUPPS-C i

260.67C Concerning the permanently installed instrumentation i i

for the Callaway Plant, it 10 the staff position that this equipment should be under the OA program controls described in 17.2.12 of the FSAR. Commit to meet this position or provide an alternative for our evaluation. F l

Response Permanently installed safety-related process  ;

instrumentation will be afforded the control measures 1 described in 17.2.12 consistent with the surveillance i I

testing program and to the e< tent that the method and interval of calibration for rach installed instrument l and control device shall be defined and shall be based l on the type of equipment, stability, reliability l

. characteristics, required accuracies nnd other l

, conditions affecting calibration. As presently stated

! in Section 17.2.12 the calibration and control program l shall provide for "the calibration of M&TE against a  ;

i reference standard having an accuracy of at least four  ;

i times the specified tolerance of the M&TE. Reference standards of equal tolerance shall be accept'ble when ,

equipment to meet specified requirements is not  !

commercially available." In addition a special j calibration shall be performed when the accuracy of an j

installed process instrument is questionable. The l calibration accuracy ratio of M&TE to permanently ,

installed process instrumentation will be 1.0 or  !

better. Section 17.2.12 will be revised to reflect  !

this clarification.

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SNUFPS-C 260.68C As discussed under Regulatory Guide 1.38 in item 260.52, above, clarify the basis for relaxation of manufacturer's storage requirements in Section.17.2.13 of the Callaway FSAR.

Response: The response to Item 260.36 will be incorporated in Section 17.2.13.

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SNUPPS-C 260.69C Item 260.41 requests a commitment 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 commitment. Clarify.

Responne: Required safety-related inspections, tests, and operations and their sequencing are performed in accordance with plant level procedurec which are reviewed by the ORC and approved by the Plant Superintendent. Except in the case of temporary changes (non-intent changes), which are allowed by the Technical Specificationc nnd which are adrninistratively controlled, any deviations from procedural requirements will be subject to the original review and approval controls, (i.e., they will be documented, reviewed by the ORC, and apprc ed by the Plant Superintendent). Section 17.2.14 will be revised to reflect this clarification.

260.69C-1

f SNUPPS-C 260.70C Clarify what is meant by the statement in 17.2.14 that procedures shall address methods for " initiating, maintaining, and releasing equipment control for maintenance . . ." (See item 260.42.)

Response. This sentence is intended to address the need for controlling the release of equipment or systems for maintenance and the control of equipment to maintain personnel and reactor safety and thereby avoid the unauthorized operation of equipment. The referenced sentence will be revised to state that procedures shall address measures for the release and control of equipmant during periods of maintenance; thereby maintaining personnel and teactor safety and avoiding the unauthorized operation of equipment.

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260.70C-1 .

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