ML20028C208

Comments on Draft EGG-EA-6109, Identification & Ranking of Nuclear Plant Structures,Sys & Components & Graded QA Guidelines. Guidelines Conflict W/& Hinder Util & Contractor Efforts to Implement QA Program

ML20028C208
Person / Time
Site:	Wolf Creek, Callaway, 05000000
Issue date:	01/05/1983
From:	Petrick N STANDARDIZED NUCLEAR UNIT POWER PLANT SYSTEM
To:	Harold Denton Office of Nuclear Reactor Regulation
References
SLNRC-83-001, SLNRC-83-1, NUDOCS 8301070204
Download: ML20028C208 (2)

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SMUPPS Standardised Nuclear Unit Power Mont Systern 5 choke cherry nood Nicholas A. Petrick Rockville. Meryland 20eso Executive Director (301)8994010 January 5, 1983 SLNRC 83-001 FILE: 0491.3.1 SUBJ: Draft Document EGG-EA-6109, Identification and Ranking of Nuclear Plant Structures, Systems and Components, and Graded Quality Assurance Guidelines dated November, 1982 Mr. Harold R. Denten, Director Office of Nuclear Reactor Regulation US Nuclear Regulatory Commission Washington D.C. 20555 Deckets: STN 50-482, STN 50-483

Dear Mr. Denton:

The purpose of this letter is to provide, on behalf of the SNUPPS Utilities; Union Electric Company, Kansas Gas and Electric Company and Kansas City Power & Light Company, review comments concerning the subject document.

It is our understanding that the intent of the NRC document is to establish minimum " guidelines" for use in applying quality assurance controls to nuclear power plant itens which, under 10CFR50 Appendix A and Appendix B criteria, have some degree of safety significance. These guidelines appar-ently have been extracted from a number of regulatory documents and industry standards and would be applied in a prescriptive fashion to structures or systems judged to be of safety significar.ce. Consequently, the future estab-lishment of quality programs would be accomplished by following the pre-scriptions suggested in the NRC's " guidelines."

The SNUPPS Utilities recognize NRC interest in expanding the scope of nuclear power plant items subject to quality assurance controls, but have reserva-tions in the approach indicated in the subject document. The fundamental concern is that the detailed and prescriptive method offered in the form of

" guidelines" would conflict with and hinder utility and contractor management ability to implement a quality assurance program consistent with the safety significance of the specific work activity. By having available detailed guidelines which are to be followed in a prescriptive manner unless..."rea-sonable justification..." for departure is provided, the cognizant management has a reduced responsibility to put into place a meaningful quality assurance program consistent with the scope and complexity of the activity, and its importance to safety. The net result would be a weakening of management involvement in the quality assurance process contrary to Commission objec-tives as reflected in SECY-82-352 and similar policy declarations. A further E301070204 830105 Atol

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SLNRC 83-001 Page Two result would be detraction of the QA supervision and staff from the moni-toring and surveillance of ongoing work activity in favor of having to track and document the manner in which each specific guideline is disposi-tioned on every system, structure and component.

A second item of concerr, is the apparent intent of the subject document to extend significantly the scope of the quality assurance function to plant items and activities not presently covered. While selective extension may, in some cases be warranted, the level and scope of quality assurance appli-cation indicated will strain existing industry capabilities and resources such that there will be a lessening in the assurance of quality in areas of greatest safety significance.

Very truly yours, NAC Nicholas A. Petric SJS/dck/10a2 cc: W. P. Haass, USNRC G. L. Koester, KGE D. T. McPhee, KCPL D. F. Schnell, UE S. R. Phelps, EEI,0C T. L. Harpster, USNRC J. M. Taylor, USNRC

R. C. DeYoung, USNRC i

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