ML20041A141

Forwards Addl Info Re QA Program for Operation,In Response to NRC 810806 Request.Other Responses Will Be Submitted by 820315

ML20041A141
Person / Time
Site:	Catawba
Issue date:	02/12/1982
From:	Henry W DUKE POWER CO.
To:	Haass W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8202190158
Download: ML20041A141 (8)

Text

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DUKE POWER' COMPANY GENERAL OFFICES Ib b[l4 422 SOUTH CHURCH STREET P. o. sox ssies CH ARLOTTE. N. C. 28242 TELEPHON E: AREA 704 373. Sol 1 February 12, 1982 x g

6 4 Mr. Walter P. Haass p RECE!VED .g .,

Nuclear Regulatory Commission '- - i Washington, DC 20555 7 FEBI'819825 I

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Subject:

QA Program for Operation i g g Catawba Nuclear Station

Dear Mr.-Haass:

During your review of Duke-1 A, there has been a request for additional i nfo rma tion. Attached is the response to your letter dated August 6,1981.

Those responses indicated as (later) will be submitted by March 15, 1982.

Sincerely, W. O. Henry Quality Assurance Manager Technical Services WOH:GHB:Jcm Attachment 9

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5 REQUEST FOR ADDITIONAL INFORMATION DUKE POWER COMPANY ' CATAWBA NOCLEAR STATION ,

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1. Appendix -(a) of Duke-l A will incorporate qualifications of the: Station Senior

-QA Engineer during the next amendment change. Both the Corporate QA Manager and the Station Senior QA Engineer will meet Section 4.4.5 of

-ANSI /ANS 3.1 - 1978.

2. Computer programs are controlled in accordance with Design Engineering's and Steam Production's Quality Assurance Manual, whereby programs are

-certified to demonstrate the applicability and. validity. This certifi-cation is accomplished by one of the following methods:

a. The computer program is a recognized pr'ogram in the public domain and has a sufficient history'of use to Justify its applicability and validity.

b. The computer program's solution of the test problems shall be compared to other solutions as follows.

1. Solutions obtained from other computer programs are published in technical literature.

2. Closed form solutions found in standard textbooks.

3. Solved examples in standard textbooks.

4. Hand calculations for the test problems.

5. Comparison of computer program results to applicable well-defined experimental data.

The results obtained by the test progr am shall indicate good correlation, which demonstrates the applicability and validity of the computer program. The certification shall be documented.

3. Section 17.0.2 of the Catawba FSAR was revised in response to Question 260.2 to identi fy those safety-rela ted s tructures, sys tens,, and components under the control of the QA program. '

[ A more detailed listing of safety-related structures, systems, and components has ~ been prepared for use by station personnel. This document was jointly approved and issued by the Vice President, Design Engineering and Vice President, Steam Production. Revisions to this document ,are jointly. approved and issued by th6 above mentioned until issuance'of the operating IIcense for ~both units.

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2 After that time revisions would be approved and issued by the Vice President Steam Production. The Nuclear Safety-Related Structures, Systems, and Components document. is considered a controlled document.

4. Applicability of the QA program to the fire protection system is discussed in Duke's fire protection submittal for Catawba titled " Response to Appendix A to Branch Technical Position APCSB 9.5-1", which was submitted to H. R. Denton from W. O. Parker, Jr. on October 23, 1981.

5. All special equipment, environmental conditions, skills and processes that are determined to be nuclear safety related will be provided within the

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scope of the QA program' .

6. The- QA Policy Statement ' dated May 2,1978, was issued by the President I and Chief Operating Officer of Duke Power Company stating, "This '

program has my unqualified support and is to be followed at all times."

7. Based.on your review and evaluation of amendment (5) to Duke's Topical and your acceptance letter of :aly 14, 1981, we replaced your letter of June 29, 1978, in our Topical. This letter now becomes part of our commi tment to the NRC. Any programmatic changes by Duke will be-submitted for review prior to implementation. Also significant organi-zational changes will be submitted no later than (30) days af ter announcement.

8. The Duke Operational quality Assurance Program will be fully implemented at least (j0) ninety days prior to fuel loading at Catawba. This commitment will be reflected during the next change to Duke-1A.

!. 9 Regulation Regulatory Guide 10CFR 50.55a (Later)

Regulatory Guide 1.8 The revision listed in our Topical is revision (1).

Revision 1-R is identical to revision (1).

Regulatory Guide 1.26 You are correct in that Regulatory Guide 1.26 is not in our Topical; however, we commit to revision (3) of Regulatory Guide 1.26 in Volume (1) of our Catawba FSAR with the exceptions noted.

Regulatory 1.28 Revision (2) is listed in Table 17.0-1, which is the revision you require. The remarks listed in the remarks column will be deleted in the next revision.

Regulatory Guide 1.29 You are correct in that Regulatory Guide 1.29 is not in our Topical; however, we commit to revision (3) of Regulatory Guide 1.29 in volume (1) of our

, Catawba FSAR.

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3 Regulatrary Guide 1.58 Revision,(1) is listed in Table 17.0-1, which is the revision you require; however, we take exception and provide an alternative that Duke operational / functional testing personnel will meet the requirements of ANSI N18.1-1971 ra ther than ANSI N45.2.6 as stated in revision (1).

Regulatory Guide 1.144 Revision (1) is listed in Table 17.0-1, which is the revision you require; however, we take exception and provide an alternative that Regulatory Guide 1.144 incorportes ANSI N45.2-12, (1977). Duke Program conforms to ANSI N45.2-12,

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1977 except audits of suppliers are conducted in accordance with methods described in ANSI N45.2-13 (1976) in that these audits are conducted in accordance wi th es tablished methods.

Regulatory Guide 1.146 Revision (0) is listed in Table 17.0-1, which is the revision you require.

BTP ASB 9.5-1 See answer to question number (4) .

10. The third paragraph of 17.2.2 allows record transfer subsequent to hardware t ra ns fer. We agree with the NRC staff's position that the records should be transferred no later than when the hardware is transferred. The next change to the Topical will reflect this position.

1), a. Documentation of formal training is documented on the individual's training record maintained by Quality Assurance Manager, Administrative Services.

b. All quality control inspectors are recertified every three years by demonstrated proficiency or by formal examination.

c. The Quality Assurance Manager, Administrative Services handles certifications.

12. In accordance with the Steam Production Department Administrative Policy Manual, before a structure, system, or component which has been modified is declared operable and returned to service, all procedures governing the operation of such systems are reviewed to determine the effect of the modification on the procedure. Necessary revisions to affected procedures are approved before the system is returned to service. if the system has been significantly altered with respect to function, operating procedure, or operating equipment, then additional training is administered to the station personnel as appropriate.

13. If it is determined that the station is not qualified or staffed to design the mod i fi ca t ion , then the resransibility to evaluate and design the modification shall be transferred to the Manager, Project Coordination and Licensing, or his designee.

Af ter completion of design and prior to approval for implementation, each modification shall be reviewed by a qualified (as determined by h"

4 the station organization) reviewer. This review shall include a determina-tion of whether or not additional, cross-disciplinary review is necessary, if deemed necessary, such additional, cross-disciplinary review shall be performed by the appropriate qualified reviewer (s). The review by a qualified reviewer; the determination of whether or not additional, cross-disciplinary review is necessary; and any additional cross-disciplinary review shall be documented.

Prior to approval for implementation, the Superintendent of Technical Services, or his designee, shall verify that all necessary processing of the modifica-tion has been satisfactorily completed. This verification shall include, but not necessarily be limited to, verification that:

a. Design information necessary for implementation is available,

b. A safety evaluation has been performed for the modification.

c. A security evaluation has been performed for the modification, if required.

d. Station review has been completed.

e. Quality Assurance Department review has been completed, if required.

f. The Nuclear Safety Review Board has completed its review of the modification, if required.

g. The Nuclear Regulatory Commission has authorized the modification, if required.

h. Approved procedure (s) for implementation are available, if required.

Approval for implementation of a modification shall be granted by the responsible Station Manager. This approval shall be documented.

If at any point in the review / approval process the modification is rejected, or processing of the modification hal ted, then copies of the process record which clearly indicate such work stoppage should be distributed to those people who have previously signed the process record. This distribution shall be accomplished by the person responsible for the termination of the modification process, or his designee.

14. See answer to question number (2) .

15. (Later)

16. Design verification mar consist of design reviews, alternate calculations, and/or qualification testing. Design reviews are intended to verify the correctness of design inputs, logic, calculations, and analyses. Calcula-tions by alternate methods provide assurance that, for instance, computer codes are performing as expected, and that no systematic error in calcula-tional procedure exists. Qualification testing, when suitable, is guided by Duke Power's adoption of various reaulatory guides which deal with qualification testing.

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17. There are no restrictions on the use of the first line supervision,as design verif ters, except in the case of the designer's immediate supervisors, in that instance, provisions of item 3E4a are met.

The use of the originator's immediate supervisor for design verification (checker) shall be restricted to special situations where the immediate-supervisor is the only individual competent to perform the verification.

Justification for such use shall be documented and signed by the Chief Engineer.

18. (La ter) 19 Procedures do not exist to differentiate between design documents that do or do not receive cross-disciplinary review. Determination of the need for cross-disciplinary review is part of the design review process.

20. Appendix E of the Administrative Policy Manual of Steam Production delineates responsibilities, considerations and documentation of design verifiers.

21. When design verification is done by test, the test must meet all the requirements of the designed activity.

22. Design Engineering prepares specifications from the guidelines of codes and standards in accordance with Design Engineering's Quality Assurance Manual. These specifications are reviewed and approved by Design Engineering and Quality Assurance to assure Quality Assurance requirements have been established. Under Steam's QA Program, procurement of items may only be procured as identical replacement items. Any new design must be forwarded to Design as well as QA to satisfy all requirements.

23. Section 17.2.7 addresses control of purchased material, equipment and services. We feel this section adequately answers this. question.

24. The Master Index is distributed through Design Engineering General Service Division Quarterly. The Master index at each site is updated by the document control group as each revision to a drawing comes in from General Services.

25. Section 17.2.6 " Document Control", will be expanded in the next revision to include that the Topical and SARs are controlled in the same manner as the Administrative Policy Manual. As-built '

documentation is controlled-in accordance with 17.2.6.

26.' (Later)

27. This. commitment has been made in Duke's Topical in Section 17.1.3 Any changes to original design and procurement documents, including field

changes, must be reviewed, checked and approved commensurate with the original approval.

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28. All drawings are received from Design Engineering in accordance with their document control procedure. This procedure requires a return receipt within 20 working days. All superseded copies shall be destroyed or clearly marked superseded.

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6 29 All instructions, procedures, specifications, and procurement documents are identified by a sequentially numbered revision. These revisions can be verified against the applicable Master index for verification of the revision.

30. Control of materials, parts and components is addressed in the Steam Production Department Adminstrative Policy Manual. This program establishes controls to assure that items are:

a. Procured to specifications and codes at least equivalent to those applicable to the original equipment or those specified by a properly reviewed and approved revision.

b. Produced or fabricated under requirements at least equivalent to those applicable to the original equipment or those specified by a properly reviewed and approved revision.

c. Packaged and transported in a manner that will assure that quality is not degraded during transit.

d. Properly documented to show compliance with applicable specifications, codes, and s tandards.

e. Properly inspected, identified and stored to provide protection against damage or misuse.

f. Properly controlled to assure the identification, segregation, and disposal of nonconforming material .

This control of materials, parts, and components, in general, includes control of procurement, receipt, inspection, identification, storage, handling, packaging, shipping, issue, nonconforming items, use of repaired items, onsite certification of items and transfer of items from other Company locations, consistent with the importance of an item to nuclear safety.

31. Vendor evaluations and reevaluation are done in accordance with QA procedures to assure their certificates of conformance are valid.

32. General office control of materials, parts and components rests with the Manager, Materials Management, who reports to the Manager of Operations and Maintenance.

The Manager, Operations and Maintenance, reports to the Vice President, S team Production. Control of materials at nuclear stations is the ul timate responsibili ty of the Manager, Nuclear Production, with responsibilities delegated to each station through the respective Station Managers to the Superintendents of Maintenance.

! 33. In order to assure the continued integrity of a station's safety-related and controlled-designated structures, systems and components, each nuclear station establishes a program for the control of special processes such as welding, heat treating,and nondestructive examination. These activities are conducted in accordance with applicable codes and standards.

For special processes not covered by existing codes or standards, or where item quality requirements exceed the requirements of established codes or standards, the necessary qualifications of personnel, procedures, or equip-ment are defined.

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34. The. Maintenance Superintendent is responsible for directing the organization and performance of the station's program for the control of special processes, and for assuring that the necessary qualified personnel are available.

The Station Manager Manager shall have the final responsibility for the implementation.

35. Documenting records required by this section, shall be identifiable and retrievable, and shall be retained for six (6) years, or the service life of the particular item (s) for which the records are appilcable, whichever is greater.

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36. (La ter)

37. Section 17.2.11 covers our test program and we feel this adequately answers

. this question.

i 38. The Stacion Manager has the final responsibility for the implementation of the requirements for control of measuring and test equipment. This requirement is stated In Steam's Administrative Policy Manual.

39. Inspections and examinations are performed on a periodic basis to assure that recommended manufacturing shelf life of chemicals, reagents, lubricants, and other consumable materials are not exceeded. These items are stored in well' ventilated areas which are not in close proximity to safety

related structures, systems, or components.

40. (La ter)

41. We agree with your position that we could provide a clearer commitment by substiting " identified" in the first sentence of 17.2.14 instead of using l the word " identifiable". This change will be reflected in the next change to Duke's Topical, j 42. Reworked, repaired, and replacement items are inspected and tested in accordance with the original inspection and test requirements or acceptable alternatives. It shall be verified that the repaired item meets or exceeds the identified specifications. This commitment will be reflected l In the next change to the Topical.

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43. (Later) l