ML20011A111
| ML20011A111 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/28/1981 |
| From: | Davidson D CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | Tedesco R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8110070272 | |
| Download: ML20011A111 (13) | |
Text
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THE CLEVELAND ELECTRIC ILLUMW ATING COMPANY P o Box 5000 m CLEVELAND oHlo 44101 e TELEPHONE (216) 622-9800 m ILLUMINATING BLDG e % PUBLtC SoVARE Serving The Best Location in the Nation Dilwyn R Davidson vtCE PF $0ENT SYSTEU ENG:NEERING AND CONSTAUCTION September 28, 1981
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Mr. Robert L. Tedesco Assistant Director for Licensing 9.! OCT 6 1981 % %
Division of Licensing u.s. w.... neun U. S. Nuclear Regulatory Commission cc -mn u Washington, D. C.
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Perry Nuclear Power P A$(/h Docket Nos. 50-440; 50-441' g Response to Request for Additional Information -
Quality Assurance
Dear Mr. Todecco:
This letter and its attachment is submitted to provide draft
- esponses to the concerns identified in your letter dated August 12, 1981, in regard to quality assurance.
It is our intention to incorporate these responses in a subsequent amendcent to our F'.nt.1 Safety Analysis Report.
Very truly yours, h
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g DalwynVR. Davidson Vice President System Engineering and Construction DRD:dlp Attachment cc:
M. D. Houston G. Charnoff hOO NRC Resident Inspector y
/ /
8110070272 810928 PDRADOCK05000g A
260.4 Identify the personnel authorized to approve changes to the list (Ref. Section 3.2 of the FSAR) of structures, systems, components, and related consumables covered by the QA program and describe the method for controlling the distri-bution of the list.
~ Response Major design responsiblity has been delegated by CEI to GA1 and GE as architect /
engineer and Nuclear' Steam Supply System supplier, respectively.
In these capacities GAI and GE now approve changes to the equipment classification list, Table 3.2-1.
Prior to fuel load the Perry Nuclear Power Plant - Oper-ational Nuclear Quality Assurance Program (ONQAP) will be in effect. At that time the PNPP design control procedures provide that the Manager, Nuclear Engineering Department will approve changes to the referenced list; or will delegate this responsibility to outside design organizations as provided in FSAR Section 17.2.3.2j, 17.2.3.3.2 and 17.2.3.4.
Procedures for controlling the distribution of the referenced list are presently the responsibility of GAI and GE in their above mentioned capacities. When the ONQAP is in effect, a CEI document control procedure for FSAR and Related Design Criteria (FSAR Section 17.2.6.2j) will provide the method of distribution.
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- Modify Table 17.2-1 to be consistent with current regulatory requirements as
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260.5 follows:
Delete reference.to Regulatory Guides 1.17, 1.28, 1.54, and 1.55 since (a) they are.either not applicable to operational QA programs or are cover-ed in other sections of the FSAR; Add Regulatory Guides 1.29-Rev. 3, " Seismic Design Classification,"
(b) dated 9/78 and 1.146, " Qualification of QA ProFram Audit Personnel for Nuclear Power Plants, dated 8/80; and (c) Update Regulat;ry Guides ~1.58 and 1.144 to Revision 1 which are both d
dated 9/80.
Response
The response to this question is provided in revised Table 17.2-1, Regul-atory Guide 1.29 - Rev. 3, is addressed in Table 1.8-1, which will also 1
be revised to reflect these changes.
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1 TABLE 17.2-1 OPERATIONAL QUALITY ASSURANCE PROGRAM COMPLIANCE MATRIX Clarifications and Exceptions NRC Reg. Guide ANSI Standard Subject 1.8 Rev. 1 N18.1 - 1978 Personnel Selection & Training PNPP conforms to this guide, with the clarification that the qualifications of personnel meet the requirements of ANSI N18.1-1971 and this guide as detailed in the resumes provided in Table 13.1-3, 5
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PNPP conforms to this guide to the extent a
1.30 8/72 N45.2.4 - 1972' Electrical Installation, Inspection & Testing required by ANSI N18.7 - 1976 1.33 Rev. 2 N18.7 - 1976 Administrative Controls &
CEI conforms to this guide Operationaf QA l
1.37 3/73
-N45.2.1 - 1973 Cleaning Fluid Systems &
PNPP conforms to this guide to the extent l
required by ANSI N18.7 - 1976 Components l
1.38 Rev. 2 N45.2.2 - 1978 Packaging, Shipping, Receiving, 2NPP conforms -to this guide to the extent Storage & }!andling required by ANSI N18.7 - 1976
TABLE 17.2-1 (Cont'd)
Clarificationa and Exceptions Subject NRC RcC. Guide ANSI Standard PNPP conforms to this guide with the following Cleanliness requirements for 1.39 Rev. 2 N45.2.3 - 1973 llousekeeping clarification:
Housekeeping activities shall be established on the basis three zone designations.
- 1) Zone A s
This designation applies'to major portions of the reactor coolant system and the nuclear steam supply system which are open for inspection, maintenance or repair.
Parsonnel accountability in Zone A and B or.Madiological Control Areas is controlled by Security and Health Physics requirements.
a
- 2) Zone 11 This designation applies to the Radiological The Control Areas of the Plant.
intermediate, fuel handling, containment, auxiliary, radwaste, off-gas heater bay, turbine power complex and turbine buildings are all in the Radiological Control Area (RCA) and are controlled by ifcalth Physics requirements in the areas of Ilousekeeping, Plant and Personnel Safety and Fire These requirements include Protection.
the movement of equipment, tools and material in and out of the RCA.
3)
Zone C This designation applies to the remainder.
of the plant.
TAELE 17.2-1 (Cont'd)
Clarificat. ions and Exceptions NRC Reg. Guide ANSI St.nndard Subject.
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l TABLE 17.2-1 (Cont'd)
NRC Reg. Guide ANSI Standard Subject Clarifications and Exceptions 1.58 gey, 1 N45.2.6 - 1978 Qualification of Inspection, PNPP conforms to this guide with the following (.
Examination & Testing Personnel cla rifica tions ;
Personnel who only handle test results or! perform document control activi'.ies will
- g not be certified.
1.64 Rev. 2 N45.2.11 - 197's QA for Design PNPP conforms to this guide with the following clarification: ANSI N45.2.11-1974, Section 6.1 1. If an exceptional circumstance, the designer's immediate supervinor is the only technically qualified individus1 available in the. organization to perform a design verification by design review; this review niay be conducted by the supervisor providing that: y 4 a. The justification is individually documented and approved in advance by oo by the supervisor's manskement. b. QA audits cover frequency and effectiveness of use of supervisors as design verifiers, to guard against abuse. 2. An individual who contributed to a g!een design may participate in a group verification of that design provided that the individual who contributed to the design; a. does not verify his contribution to the design, and b. does not. aerve as chairman or leader of the group verification activity. 1.74 2/74 N46.2.10 - 1973 QA Trrms & Definitions PNPP conforms to this guide
TABLE 17.2-1 (Cont'd) Clarifications and Exceptions NRC Reg. Guide ANSI Standard Subject Where duplicate records are not mainta:ned, 1.88 Rev. 2 N45.2.9 - 1974 Collection, Storage & records will be stored in a facility whose Maintenance of Records construction incorporates features recommended in ANSI N45.2.9 - 1974, with the following exception: Coor assemblies are Underwriter's Laboratory listed with a three (3) hour rating to provide fire protection in accordance with ASTM E-152. PNPP conforms to this guide to the extent 1.94 Rev. 1 N45.2.5 - 1974 Concrete E Structural Steel required by ANSI N18.7 - 1976 Installation, Inspection, & Testing PNPP conforms to this guide to the extent 1.116 Rev. 0-R N45.2.8 - 1975 Mechanical Installation, required by ANSI N18.7 - 1976 Inspection & Testing M The Fire Protection guidelinee fer PNPP were 7 Fire Protection Guidelines taken from BTP-APCSB 9.5.1 Appendix A. 1.120 Rev. I N/A for Nuclear Power Plants "Guidelinen for Fire Pertection for Nuc1 car Powe-Plants docketed prior to July 1, 1976." A detailed evaluation of this BTP is provided in Section 5 of the PNPP Fire Protection Evaluation Report. (See Reference 1) PNPP conforms to this guide with the following 1.123 Rev. 1 N45.2.13 - 1976 QA for Procurement of Items clarifications: & Services Section 8.2 of ANSI N45.2.13 - Control of Nonconformances Contrnctuni commitments have becn effected " which allow dispositions such as "use-ns-19. or " repair" decisions to be made on behalf of CEI by the qualified supplier. PHPP c6aforms to this guide. 1.144 Rev. 1 N45.2.12 - 1977 Auditing of QA Programs k 1.146 N45.2.23 - 1978 Qualification of QA Program PNPP conforms to this guide. jj Audit Perconnel 4 y v
260.6 Identify the existing or proposed QA procedures in a matrix to reficct r?:st each criterion of 10 CFR 50 Appendix B will be addressed. Rytponse The response to this questisc. is provided in revised section 17.2.5.1 and new Table 17.2-2. i n 1
for preparation, review, approval, issue and revision of procurement documents in ) accordance with the requirements of this sect hen. 17.2.4.3.2 Manager, NQAD The Manager, NQAL, shall ensure through review and t dit that CEI procedures and instructions for procurement document control comply with the policy and requirements of this section. 17.2.4.3.3 NQAD The Nuclear Quality Assurance Department shall review and approve all CEI procereme.nt documents, including contracts and special agreecents, for t,he acquisition of material, eqaipment, and services covered under the scope of this document. I 17.2.4.4 Delegated Authorities I An*, procurement document control activity covered under the scope of the PNPP QA I rogram performed on behalf of CEI if vendors, contractors, or agents shall be in accordance with procedures and instructions and with a quality assurance program which has received prior approval of the CEI Nuclear Quality Assurance Department. j 17.2.* INSTPUCTIONS, IROCEDURES AND DRAVINGS i 17.2.5.1 Policy The PNPP Quality Assurance Program for the operations phase requires that i activities covered under the scope of Section 17.2 are prescribed by documented procedures, instructions and/or drawings and that these activities are accomplished through the implementation of these documents. Table 17.2-2 identifies the proposed Operational Quality Assurance jrogram areas NS to be procedurally addressed with respect to each of the criteria of.10 CFR 50, 6 Appendix B. j $f 17.2-25 o l
8 1 X X 7 X X X X X 1 6 X X X X X 1 5 X X X X 1 4 1 X X X 3 1 X X 2 1 X X X 1 1 X X X 0 1 X X X SA E 9 X X X RA l' A 8., X X M I A R R E G T O I 7 X X X X X R R P C E B 6 X X X X X CN X A I R D 5 X X X X X U N S E S P A P 4 X X X X X A YT R I F 3 X X X L C A 2 U 0 Q 1 2 X X X X X 2 L 7 A 1 N 1 X X X X X O E I L T B A A R T E S P N E O O L C I A N D T U A T S E A N RS N S ES S ZL A UE E E CE O IA RM SR M GR IR P NR A SU T FU VU O AU EE AD R ID RD R GD LC E A RE EE P RE CN YC P EC SC OC UA TO E EO O O NR) IR D NR TR GR UE LP IP CP E NP LST A T G. T JT I ASA UT NS t TG NAR QN AE EN ON NN O O E LR E RE RI PU RI PM EIS IYP RS TTR AD D AD T IDIE AIO ER YE ER YR LUR RLC LA RC LA RA PQD EA( CP RO CP RP ED PU UE ER UE EE IDRA - OQ _ ND. PP ND PD i 4: jfl 1 I j
260.7 Describe the provisions which assure that verified computer codes are certified for use and that their use is specified.
Response
The response to this question will be provided in revisc3 Section 17.2.3.2 by adding the following item 1. 1. " Verified computer programs are certified prior to use and measures shall be provided to acsure that the program is appropriate for the particular application, that it ic used correctly, and the output is valid and correctly applied." I 1 i l l 1
260.8 Describe the provisions which assure that procutement of spare or replacement parts for structures, systems, and components important to safety is subject to present QA program controls, to esdes and standards, and to technical re-quirements equal to or better than the original technical requirements. 4
Response
J Prior to complete implementation of the Operational Nuclear Quality Assurance Program, Procurement Documents for spare or replacement parts are accorded the same review by the Perry Project Organization that the j original Procurement Documents receive. This includes reviews by Engineering, Quality Assurance and Purchasing groups. At present most spare and replacement parts are being procured from the vendors which supplied the original equipment, referencing original purchase specifications and contracts. In addition, j. certificates of r_uaformance are now required which not only state that parts meet the requirements of the procurement but that they will not alter current qualifications or equipr.ent performance when installed. In those cases where it is desirable to procure a part for s, piece of equipment which meets the definition of " commercial guide item" given in 10CFR21.3 (a-1) an Engineering evaluation is per'.ormed and i reviewed to substantiate this classification. 7ie qualification of vendors is reviewed to ensure that a sig-afficant lapse of time has not passed since the vendors cap-abi'.ity to provide quality items has been evaluated. Additionally Section 17.2.7.1 (page 17.2-31) presently states: " Procurement of spare or replacement parts for structures, systems, and components shall be subject to current QA Program controls, and to codes, standards, and technical requirements equal to the original i technical requirements, unless appropriate design evaluation determines j that other requirements are accpetable." I a I 'i t l 1 ,..,. ~., -.,..,--,-n -~..,,,
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