ML20010B135
| ML20010B135 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/06/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Wells J DUKE POWER CO. |
| References | |
| NUDOCS 8108140081 | |
| Download: ML20010B135 (7) | |
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- AUG 0 61981 8ntral File NRC PDR LPDR NSIC QAB Projects QAB Chron. File WJohnston, DE Mr. J. Wells, Manager KJabbour, LB#4 Quality Assurance JSpraul, QAB Duke Power Company 422 South Church Street Charlotte, SC 28242
Dear Mr. Wells:
SUBJECT:
QA PROGRAM FOR OPERATION - CATAWBA NUCLEAR STATION In our acceptance letter for Amendnent 5 of DUKE-1-A, " Quality Assurance Program,"
we noted that we would compare Amendment 5 to Section 17.2 of Revision 1 of the Standard Review Plan (NUREG-75/087) for the Catawba Nuclear Station. We have com-pleted this review which resulted in the enclosed " Request for Additional Infor-mation."
Please respond to the enclosure on a schedule which is compatible with the review schedule for the Catawba Nuclear Station. An acceptable response is required to each item in the enclosure before a Safety Evaluation Report indicating the accept-ability of Chapter 17 of the Catawba FSAR can be issued.
If you have any questions regarding the above, call Jack Spraul of my staff or me on (301) 492-7741.
8 Sincerely, i
Originalsigned by l
Walter P. Haass Walter P. Haass, Chief Quality Assurance Branch Division of Engineering
Enclosure:
Request for Additional Infonna tion 4
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REQUEST FOR ADDITIONAL INFORMATION Duke Power Company - Catawba Nuclear Station For Catawba F5AR, the following questions resulted from reviewing Amendment 5 of DUKE-1 to Rev.1 of the SRP.
The number in parentheses under the question number refers to Section 17.2.X of the report.
1.
Appendix 17A of DUKE-1 lists the qualification requirements of the Corporate Quality Assurance Manager.
Provide a commitment that both the' Corporate Quality Assurance Manager and the Station Senior QA Engineer meet the quali-fication requirements of Section 4.4.5 of ANSI /ANS-3.1-1978.
2.
Describe how the Quality Assurance Program is applied to the development, con-(2) trol, and use of computer pro' rams.
g 3.
Identify the structures, systems, components, and consumables at Catawba cov-(2) ered by the QA program.
One way to do this would be to revise Section 17.2.of the Catawba FSAR to include a list of these items or make reference to other sections of the Catawba FSAR where sucn a list can be found.
Indicate who (by position title)'is authorized to approve changes to this list.
Finally, clarify that this list is controlled under Duke Power Company's document control pro-gram described in Part 17.2.6 of DUKE-1.
4.
Clarify that the fire protection system (per Section 9.5.1 of the Catawba FSAR)
(2) is covered by the pertinent requirements of the QA program described in DUKE-1.
l l
5.
Provide a commitment-that special equipment, environmental conditions, skills,.
l (2) and processes will be provided within the scope of the QA program as necessary.
I 6.
Describe provisions which make adherence to procedures mandatory.
For example, (2) has a policy statement or similar document been issued to that effect by_a responsible official? If so, indicate by position title who has issued such a document.
I 7.
Clarify the last paragraph of the introduction to include a commitment to noti-l (2) fy NRC-QAB of changes (1) for review and acceptance in the accepted description l
of the QA program in DUKE-1 prior to implementation and (2) in organizational i
elements within 30 days after announcement.
8.
Provide a commitment that Duke's QA program for operation will be implemented l
(2) at Catawba at least 90 days prior to fuel loading.
9.
For Catawba, update Table 17.0-1 commitment to Regulatory Guides as noted below.
(2) Clarify each alternative to identify the applicable guidance and the proposed alternative in detail.
l Regulation /
Listed Regulatory Guide Revision Revision Required 10 CFR 50 Appendix 8 OK OK 10 CFR 50.55a 1971 Code 1977 Code 10 CFR 50 Appendix A (Typo)
OK OK
. Regulation /
Listed Regulatory Guide Revision Revision Required R.G. 1.8 1
1-R 1.26 Missing 3
1.28 1
2
?.29 Missing 3
c 1.30 0
Same i
1.33 2
Same 1.37 0
Same 1.38 2
Same 1.39 2
Same 1.58 0
1 1.64 2
Same 1.70 2
Not Required in DUKE-1 1.74 0
Same 1.88 2
Same 1.94 1
Same 1.116 0-R Same 1.123 1
Same 1.144 0
1 1.146 Missing 0
BTP ASB 9.5-1 Missing Per SRP Rev. 2, Section 9.5.1 It may be advantageous to provide a table in DUKE-1 showing the applicable re-vision vs. plant.
10.
The third paragraph of Section 17.2.2 allows rected transfer subsequent to hard-(2) ware transfer. The staff's posicion is that the records should te transferred.
no later than when the hardware is transferred.
Commit to meet this position or provide an alternative for our evaluation.
l
- 11. The fifth and sixth paragraphs of Section 17.2.2 address personnel indoctrina-(2) tion and training.
Clarify the following:
a)
Documentation of formal training includes the objective, content of the program, attendees, and date of attendance, b)
Proficiency of personnel performing and verifying activities affecting quality is maintained by retraining, reexamining, and/or recertifying.
c) Who (by position title) certifies inspectors, testers, and examiners.
12.
Describe measures which assure that responsible plant personnel are made aware (3) of design modifications which may affect the performance of their duties.
13.
Describe how modifications are designed if it is determined that the station (3) is not adequately qualified to perform this function (reference the third para-graph of Section 17.2.3).
14.
Describe the controls applied by the Duke Power Company to the development and
-(3) use of computer programs. Discuss verification, certification, and use of com-puter programs.
4-
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,. 15.
Describe internal and' external design interface controls, procedures, and lines (3) of communication among participating design organizations and across technical disciplines for the review, approval, release, distribution, and revision of-modification documents involving design interfaces.
16.
Describe guidelines or criteria used by the Duke Power Company to determine (3) the method of verifying the design of plant modifications.
17.
Discuss the use of first-line' supervision as design reviewers '(verifiers) and i
(3) the timeliness of design verification of plant modifications. _ Clarify that Duke Power Company meets the criteria of item 3E2a.on page 17.1-11 of' Revision 1 of the-Standard Review Plan (NUREG-75/087) in.these eas if designs are ever-
" independently verified"' by the designer's immediate sapei /isor.
18.
Discuss the timeliness of design verification. Clarify that Duke Power Company (3) meets the criteria of item 3E2b on page 17.1-11 of Revision 1 of the Standard Review Plan.
19.
Provide a commitment that procedures differentiate between design documents
~
(3) that receive formal design verification by interdisciplinary teams and those that can be reviewed.by a single individual, and clarify that specialized reviews are used when uniqueness or special design considerations warrant. Al so -indi-cate the types of design d..uments that are. subject to' Duke' Power Company's procedural controls (speci'ications, calculations, computer programs, system.
descriptions, SARs, and drawings such as flow diagrams, P& ids, electrical single-line, diagrams,etc.).
- 20. When designs and design modifications are verified by design review, provide a (3) commitment that procedures identify the responsibility of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the documentation required.
l 21.
Describe measures which assure that the following provisions are included if (3) design verification method is by test:
a)
Procedures' provide criteria that specify when verification should be by-test.
b)
Prototype, component, or feature testing is performed as early as possible prior to installation of plant equipment, or prior to the point when the-installation would becume irreversible.
c) Verification by test is performed under conditions that simulate the most adverse design conditions as determined by analysis.
22.
The third paragraph of Section 17.2.4 of DUKE-1 addresses Quality Assurance De-
~
(4) partment review of purchase requisitions.. Verify that this review determines that quality requirements are correctly stated, inspectable, and controllable; there are adequate acceptance and rejection criteria; and procurement documents have been prepared, reviewed, and approved in accordance with QA program require-.
ments.
.. 23. Describe measures which assure that. procurement documents identify applicable (4) regulatory, technical, administrative, and reporting requirements; drawings;-
specifications; codes and industrial sts..dards; test and' inspection require-ments; and special process instructions that must be complied with by suppliers.
24.
The fourth paragraph of Section 17.2.6 indicates the drawing master index is (6) updated regularly.
Define " regularly."
25.
Expand Section 17.2.6, " Document. Control," to describe the control of as-built 4
(6) documentation, topical reports (such as DUKE-1), and SARs.
26.
Describe measures which assure that maintenance, modification, and inspection (6) procedures are reviewed by the QA organization to determine:
a) The need for inspection, identification of inspection personnel, and docu-mentation of. inspection results, b) That the necessary inspection requirements, inspection methods, and acceptance criteria have been identified.
27.
Provide a commitment that changes to documents are reviewed and approved by the (6) same ( jnizations that performed the initial review and approval or by other qualified responsible organizations delegated.by the Duke Power Company.
28.
Describe procedures which assure that obsolete or superseded documents are (6) removed and replaced by applicable revisions in work areas in a timely manner.
29.
The last paragraph of Section 17.2.6 addresses a master file and master index (6) which identifies current drawing revisions.
Discuss controls used to identify the current revision of instructions, procedures, specifications, and procure-ment documents.
I 30.
Describe the control of procurement of spare or replacement parts.
Such parts l
(7) should be subject to present (current) QA program controls, to applicable codes and standards, and to technical requirements equal to or better than the origi-nal technical requirements.
l 31.
Provide a commitment that suppliers' certificates of conformance are periodically (7) evaluated by audits, independent inspections, or tests to assure they are valid, 32.
Describe the organizational responsibilities for the identification and control i
l (8) of materials, parts, and components.
33.
Describe the criteria used to determine which processes are controlled as (9) special processes and provide as complete a list as possible.
34.
Identify organizational responsibilities for qualifying special processes and (9) related equipment and personnel.
35.
Clarify that procedures are established for recording evidence of acceptable (9) accomplishment of special processes using qualified procedures, equipment, and personnel.
,. 36.
Provide a commitment that inspection procedures, instructions, or checklists (10) provide, as required, for the following:
a) Identification of characteristics and activities to be inspected.
b) A description of the method of inspection.
c) Specifyinq necessary measuring and test equipment including accuracy I
requiremen_s.
d)
Identification of the individuals or groups responsible for perfc. ming the inspection operation.
e) Acceptance and rejection criteria.
f) Identification of required procedures, drawings, and specifications and revisions.
g) Recording inspector or data recorder and the results of the inspection operation. -
h)
Identification of the individuals or groups responsible for evaluating
~
and documenting the acceptability of the inspection results.
37.
Section 17.2.11 requires procedures for testing. Provide a commitment that (11) these procedures provide as required for the following:
a) The requirements and acceptance limits contained in applicable design and procurement documents, b)
Instructions for performing the test.
i c) Test prerequisites such as calibrated instrumentation, adequate test equipment and instrumentation including their accuracy requirements, completeness of item to be tested, suitable and controlled environmental conditions, and provisions for data collection and storage.
d) Mandatory inspection hold points for witness by owner, contractor, or inspector (as required).
e) Acceptance and rejection criteria.
f) Methods of documenting or recording test data and results.
g) Provisions for assuring test prerequisites have been met.
38.
Describe the organizational responsibilities for establishing, implementing, (12) and a:suring the effectiveness of the calibration program (include radiation measuring equipment).
39.
Describe provisions for the storage (including shelf life control) of chemicals,
- (13) reagents, lubricants, and other consumable materials.
.c-
?
- 40. Provide a commitment that special handling, preservation, storage, cleaning, (13) packaging, and shipping requirements are established and accomplished by suit-ably trained individuals in accordance with predetermined work and inspection 1
instructions.
- 41. A clearer commitment regarding the operable status of items would be substi-(14) tuting " identifiable" in the first sentence of 17.2.14 with " identified."
Clari fy.
(
- 42. Provide a commitment that reworked, repaired, and replacement item % are inspected (15) and tested in accordance with the original inspection and test requirements or acceptable alternatives.
- 43. It is not clear that Section 17.2.16, particularly with its reference to Sec-(16) tion 17.2.15, addresses that part of corrective action required to preclude repetition of conditions adverse to quality. Clarify that corrective action as discussed in 17.2 includes both the correction of conditions adverse to quality as we.ll as action required to preclude repetition. Also clarify that the requirements of Section 17.2.16 are described in procedures which require documentation of the actions.
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