ML20004F948
| ML20004F948 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 06/23/1981 |
| From: | Colbert W DETROIT EDISON CO. |
| To: | Kintner L Office of Nuclear Reactor Regulation |
| References | |
| EF2-48-240, NUDOCS 8106260329 | |
| Download: ML20004F948 (7) | |
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.EF2-48,240-Mr.'L. L. Kintner H vision of Project Management Ot.' ice of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington,-D. C.
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Dear Mr. Kintner:
Reference:
Enrico Fermi Atomic Plant, Unit 2 NRC Docket No. 50-341
Subject:
Transmittal of Responses to Quality A.;sure.nce Questions 260.1 through 260.12 Attached herewith are responses to Questions 260.1 through 260.12
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of Quality Assurance.' Response to question 260.2 includes changes to FSAR text. Other responses provide the requested information.
Very truly yours,
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W. F. Colbert Technical Director Fermi 2 Project WFC/TAA/lsb
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cc: Mr. B. Little j
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1 Question 260.1
'The Manager - Quality Assurance identified in figure 17.2-1 has
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corporate responsibility for quality assurance on construction of fossil and nuclear plants.' He will not be responsible for the operational QA program for Fermi 2.
The Director-of Project QA has direct
-responsibility'for the QA program implemented on the Fermi 2 project-during construction..Four months prior to fuel load his responsibilities will be transferred to the Director of Nuclear Quality Assurance. He and his staff of Edison personnel are part of the corporate QA department.
The' only other ' element that is part of the department is a QA engineer
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assigned to a fossil project.
Question 260.2 The Director, Nuclear Quality Assurt; ice who reports to the Vice President -
Nuclear.0perations is the QA " manager" of the "offsite" organization. The Supervisor of Ope, rational Assurance directs the activities of the "onsite" QA organization and reports administratively and technically to the Director.
The positions of Director and Supervisor of Operational Assurance will require the education and experience qualifications described in Section 4.4.5 of ANS 3.1-19/9. The modified text for Section 17.2.1 is included as' Attachment A.
l Guestion 260.3-l l
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. Procedures will describe how changes to the "Q-list" will be made. The L,
final. approval will be by.the Director of the Nuclear Engineering Department with the concurrence of the Director-Nuclear Quality Assurance. The control of its distribution will be by the QA Department. The "Q-list" will be distributed to all recipients of the QA manual.
Question 260.4 i.
l Edisen's response to NRC Generic Letter 81-01 will indicate a commitment to meet the requirements of regulatory guides 1.58-Rev.1 (9/80)' and 1.146 (8/80). There also will be compliance with regulatory guide 1.144 (1/79).
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Question 260.5 QA program procedures will require that the development, control and use'of computer programs be conducted in accordance with-implementing procedures that incorporate applicable QA requirements that assure adequacy of design and use of programs.
Question 260.8
' Administrative procedures developed for the preparation, revision and control of the QA manual will have requirements that each proposed change to the manual must be reviewed to determine if the change is to the accepted QA program and, therefore, reportable to the NRC for review and acceptance prior to implementation. Also, the QA Department Staff group, which will have the responsibility for reviewing all matters-which may be reportable to the NRC, will include in their procedures the requirement to review all announced changes in organizational elements for reportability to the NRC within 30 days after announcement.
l Question 260.7 i
l The design control procedures adopted by organizations performing design work for the plant will be reviewed and approved by the QA ceganization.
Among the commitments for which the procedures will be reviewed is the j
incorporation of requirements on the qualifications of design verifiers as given in Section 17.2.3.
Thus assurance that design verification activities will be properly performed is provided by the QA organizations' involvement with the approval of the procedures and the subsequent audits performed l-to verify compliance with the procedures.
Included in the audits will be l
a' determination of whether there is any abuse of priveleges granted in the procedures regarding the use of supervisors as reviewers.
Question 260.8 The procedures of the Procurement QA group will include requirements-to determine periodically the' validity of suppliers' certificates of con-formance by appropriate methods. This.may include audits of the suppliers' records and/or independent verification of the quality of an item through inspection or test. Audits by the QA staff will verify that Procurement GA is complying with the requirements.
Question 260.9 Processes that will oe controlled as special processes will meet the following criteria:
a) Process is dc. pendent _upon the skill of personnel who are trained and qualified to the process procedure; b) Process must be performed in accordance with a procedure that has been demonstrated to give satisfactory results.
Procedure requires careful control of materials, work conditions and identified parameters; and j
c) Final inspection or testing alone is inconclusive regarding the' quality of the work without process control.
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Question 260.10 Since inspection personnel will be ass 4ned from the QA organization to perform inspections associated with normal operations of the plant, the required assurance for adequate control of inspection activities is provided.
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QUESTION 260,11 Selection of reference standards always gives preference to instrument accuracy. However, present state-of-the-art accuracy of M&TE approaches that of the test reference standards,' precluding the maintaining of a four-to-one ratio. Without exception,.the reference standard accuracy is equal to or better than the equipment being calibrated.
. Recommendations of the most suitable reference standards are normally stated in the orocedural directions given for the calibration.
In all cases the accuracy of both the M&TE and the reference standard selected are documented.
Question 260.12' The'QA program procedure on calibration and control of M and TE incorporates the requi.renents regarding the traceability of reference and
-transfer standards to nationally' recognized standards and, also, that when a national standged dods not exist, the basis for calibration must be documented. The implementing procedures, approved by QA, will have to incorporate these requirements. Audits by QA will verify compliance.
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ATTACHMENT A
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EF-2-FSAR l
Ie 17.2.1.2.1.1 Nuclear Production Department The Plant Superintendent and his staff are responsible for j
the operation and maintenance of the plant systems and compo-nents and for the implementation of QA procedures, including l
health physics and security.
A detailed description of the Nuclear Production Department, including responsibilities, l
authorities, duties, and qualifications for all key staff positions, is given in Subsection 13.1.3.
The Plant Super-intendent is a member of the Independent Review and Audit Group (IRAG) and the chairman of the Onsite Review Organiza-t.f on (OSRO).
In matters involving QA implementation for the ops ation of the plant, he is supported by the Supervisor of j
oper cional Assurance and his staff.
17.2.1.2.1.2 Nuclear Quality Assurance Department The Director - Nuclear Quality Assurance reports to the Vice President - Nuclear Operations and has administrative responsi-bilities'for all QA and QC personnel.
He is supported by the Supervisor of the ch staff.
Reporting to him administratively, but mat.rized to other departments, are four supervisors and their I ersonnel.
They are:
Supervisor of Construction and Mainternance QA, Supervisor of Procurement QA, Supervisor of operational Assurance, and Supervisor of Engineering Assurance.
The Director has overall-responsibility for ensuring the estab-35 lishment and effective implementation of the QA prograla and is given th'e authority to bring about compliance and corrective action as required.
He has the authority to initiate action yk g.S of Am 3.I-/979)
The following qualifications are prescribed for the position of Nuclear QA Department Director:
m EDUCAT ON: Bachelor Degree in Engineering or related science.
EXPERIENCE: Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position preferably at an operating nuclear plant or a combination of the two. At least one (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance Six (6) months of the one year experience shall be program.
obtained within a quality assurance organization.
j The structure of the QA organization is shown in Figure 17.2-2.
The QA staff and Supervisor support the Director in the per-formance of his duties.
These include the maintenance and control of the Operational QA Program Manual, the review of l
all implementing QA and QC procedures, the audit of other QA 17.2-2 Amendment 35 - May 1981 v-mw-
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and QC groups and their activities, the review of nonconform-ance and corrective action reports, the analysis of qual.Lty trends reports, the collection of quality data, problem anal-ysis, and the coordination of NRC reports and letters.
The Supervisor of Operational Assurance and his staff support the Planh Superintendent in providing the QA and QC functions necessary *cr the operational activities of Nuclear Production.
These include audits and surveillances of responsibility areas Nuclear Production.
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The Supervisor of Operational ssurance will meet the qual-I yXi/andbeamemberofthe ification requirements of
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OSRO.
He has the authority and t3e responsibility to initiate except reactor operation, if action to suspend any activity, deviation from the QA program he discovers or suspects that a has occurred or is developing; nonconformances that appear to warrant' suspension of reactor ' operation, including startup or Power generation, will be reported to the Superintendent l
immediately.
The Supervisor of Procurement Quality Assurance and his staff support the General Supervisor of Material Control in the Administration Department in providing the necessary QA and 35 QC functions.
Their principal duties include the review of procurement documents for QA requirements, vendor audits, planning and coordination of source inspection with the sup-port of the Inspection Division of the General Purchasing Department, receiving inspection, and review of vendor qual-ity documentation.
The Supervisor of Construction and Maintenance QA and his. staff support Outage Management, Nuclear Plant Nodifications, and the Maintenance Engineer by providing the required QA and QC func-Their principal duties include th' review of construc-tions.
tion and maintenance procedures, the inspection of construction and maintenance work, the performance of nondestructive-testing t
examinations or review of results, and audits of construction and maintenance activities.
The Supervisor of Engineering Assurance and his staff function within the engineering area in the Nuclear Engineering and the Generation Engineering Departments, as needed.
Their princi-pai, duties include auditing engineering and design activities, including those of architectural-engineering contractors, the the review review of specifications for engineered equipment, of design control procedures, and the review of design docu-ment packages.
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