ML20003E847
| ML20003E847 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, Callaway  |
| Issue date: | 04/14/1981 |
| From: | Seiken S STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| SLNRC-81-24, NUDOCS 8104170387 | |
| Download: ML20003E847 (5) | |
Text
76 SNUPPS Standardized Nuclear Unit Power Plant System sc m. c % no.d April 14,1981 Rockville, Merytand 20060 mus e SLNRC 81-24 FILE: 0491.3.1 SUBJ: SNUPPS QA Program for Design and Construction Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Dockets: STN 50-482, STN 50-483, STN 50-486
Dear Mr. Denton:
In response to your letter of March 13, 1981 to Union Electric Company and Kansas Gas and Electric Company, we are providing as an enclosure, herewith, the additional information and clarifications requested con-cerning the SNUPPS design and construction QA program. As indicated, several of the enclosed responses and clarifications will be incorpor-ated into Revision 3 to the SNUPPS QA program document. We anticipate issuance of Revision 3 by May 31, 1981.
If there are any questions or need for further discussion regarding the enclosed response, please contact me directly.
Very truly yours, S. o. Seiken, Manager Quality Assurance SJS:dck:7a4
Enclosure:
Request for Additional Information-SNUPPS FSAR cc:
W. Haass, USNRC w/ encl.
J. K. Bryan, UE G. L. Koester, KGE D. T. McPhee, KCPL W. A. Hanson, NRC Callaway w/ encl.
T. E. Vandel,?!RC Wolf Creek w/ encl.
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I Enclosure to SLNRC 81-24 Request for Additional Information SNUPPS FSAR 1.
NRC Comment:
In several places (SNUPPS General page 17.1-30), Callaway Site Addendum pages 17.1-16 and 178.1-17, and Wolf Creek Site Addendum pages 17.1-34 and 178-16a), Revision 2 states that the extent of acceptance methods and associated verification activities will vary as a function of the relative complexity of the purchased item or service and the supplier's past performance.
It is the staff's position that the extent of quality verification should also reflect the item's or service's importance to safety or relative safety importance.
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 involved design engineering organization and quality assurance organization should jointly determine the extent of inspection verification and the quality verification dr "ntation re-quirements based on the item's end use.
Revise the submittal to reflect the above position.
SNUPPS Response:
The sections of the design and construction QA program document con-cerning acceptance of purchased items or services will be clarified to indicate that the acceptance methods and verification activities will vary as a function of the item's or service's complexity and relative safety significance as well as the supplier's past performance.
In regard to the statements contained in Revision 2 that acceptance of "off-the-shelf" items do not require quality verification documenta-tion, it should be noted that in these types of procurements, verifi-cation documentation from the supplier will not be required. Documen-tation will be furnished of the site's receiving inspection activities.
l This clarification reflects discussion of April 6, with Mr. Spraul, NRC QA Branch and will be incorporated in Revision 3 of the design and construction QA program document.
2.
NRC Comment:
In the last line on page 178.1-1 of the Callaway Addenda and starting at the bottom of page 178-1 of the Wolf Creek Addendum, clarify what is meant by " project quality personnel" and "the quality portion of the quality assurance program."
Encl. to $LNRC 81-24 Page 2 SNUPPS Response:
" Project Quality Personnel" at both Callaway and Wolf Creek refers to personnel assigned to the project to perform Quality Control (first line inspection / testing / documentation actions) and/or Quality Assurance (audit project activities for compliance to project require-ments) functions.
" Quality Portion of the Quality Assurance Program" refers to those activities which are specifically called out in the SNUPPS QA Program to be implemented by Quality Personnel.
3.
NRC Comment:
The Wolf Creek Addendum indicates on page 178-3b that the Project Quality Control Manager is responsible for preparation of QC Proce-dures and instructions to control the activities of QC Personnel.
Indicate who, by position title, has these responsibilities at Calla-way.
SNUPPS Response:
At the Callaway project, the Project Quality Control Manager is similarly responsible for preparation of QC procedures and instruc-tions to control the activities of QC personnel. This is so stated in the introductory paragraph of the Callaway Addendum which identifies the Project Quality Control Manager's responsibilities.
4.
NRC Comment:
'l Item d on page 178.1-5 of the Callaway Addenda and item e on page 178-3b of the Wolf Creek Addendum indicate that engineering and in-spection personnel " perform supplier / subcontractor audit, receiving, in-process, and final inspections." Discuss the specific responsi-oilities and the rationale for the use of engineering personnel to perform these QA/QC functions.
SNUPPS Response:
Engineering personnel, as referred to in paragraph "d" (Callaway) and "e" (Wolf Creek) under the sections on responsibilities of the Project Quality Control Manager, are in fact Quality (QA/QC) Engi-neers working in the Quality organization. This will be clarified in the next revision to the design and construction QA program docu-ment.
5.
NRC Comment:
The Construction Engineering Managers (CEM) for Daniel appear to have different responsibilities at the different sites. That is,
Encl. to SLNRC 81-24 Page 3 at Callaway (but not at Wolf Creek) the CEM is responsible for:
c) Generating contract packages in conjunction with the Purchasing function.
d) Coordinating engineering matters with the Design Engineer.
h) Establishing and implementing procedures for the collection and consolidation of as-built information.
At Wolf Creek (but not at Callaway) the CEM is responsible for:
e) Controlling fabrication and installation with a system of docu-mented procedures and instructions.
I Clarify these apparent anomalies.
SNUPPS Response:
The Daniel project organizations at the Callaway and Wolf Creek jobsites are separate and distinct management entities. As a result differences can be anticipated and do exist in the functional respon-sibilities of individuals and positions within the two site organ-izations. Although such differences exist, they do not detract from each applicant's licensing and quality program commitments.
6.
NRC Comment:
Revision 2 has modified or deleted several commitments in the ear-lier version of the Wolf Creek Site Addendum. Discuss the signifi-cance of the changes noted below.
a) The Manager Quality Assurance used to participate as a member of the SNUPPS QA Committee but now "provides a member" for the SNUPPS QA Committee (page 17.1-5).
b) The Quality Assurance Division no longer reviews vendor lists and bid selections (deleted from page 17.1-6 of Revision 0).
Apparently the Quality Assurance Division now only audits (per page 17.1-33 of Revision 2).
c) The Quality Assurance Division is no longer responsible for the storage and preservation of general office QA records (cf. pages 17.1-6 of Revision 0 and Revision 2).
d) Procedures which define the interfaces and define the boundary between common activities and the activities which are unique to each utility have been deleted from the "SNUPPS Standard Quality Assurance Procedures Manual (cf. pages 17.1-10 of Revi-sion 11/79 and Revision 2).
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Encl. to SLNRC 81-24 Page 4 SNUPPS Response:
a) The primary function of the SNUPPS QA Committee is to evaluate the QA program / activities of organizations external to the individ-ual SNUPPS sites (refer to Standard Plant Section 17.1.1.1), and address any concerns regarding these programs / activities. Within Kansas Gas and Electric Company, the responsibility for performing this function resides with the Project QA Coordinator who reports directly to and is under the administrative control of the Manager Quality Assurance. The Project QA Coordinator presently is the KG&E representative cn the SNUPPS QA Committee, replacing the Man-ager Quality Assurance in this role.
b) While Kansas Gas and Electric Company retains primary responsi-bility for ensuring the acceptability of its own vendors, each major contractor has been delegated this responsibility tu their respective scopes of work (refer to Section i7.l.7 of the Wolf Creek Site Addendum). Thus the deletion of the requirement for KG&E Quality Assurance Division reviews of major contractor ven-dor lists and bid selections does not result in a degradation of the overall QA Program. KG&E QA verifies through the audit system that the major contractors are procuring safety-related equipment, materials and services from approved and qualified suppliers.
c) Although the responsibility for maintaining the General Office QA Records has been reassigned outside the Quality Assurance Division, QA audits will be performed in this area to verify compliance with the records storage requirements.
d) The description of the "SNUPPS STANDARD QUALITY ASSURANCE PRO-CEDURES MANUAL" has been changed to more accurately reflect the present content of the manual. The "SNUPPS STANDARD QUALITY ASSURANCE MANUAL", rather than the standard procedures manual, defines the responsibilities among the organizations involved in SNUPPS (refer to Section 17.1.2 of the Wolf Creek Site Addendum).
The individual utilities, the SNUPPS Organization, and the major contractors incorporate the necessary interfaces into their own internal procedures based on this assignment of responsibility.
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