ML20045A688

Forwards Response to NRC 920521 Request for Addl Info on AP600 QA Program

ML20045A688
Person / Time
Site:	05200003
Issue date:	06/07/1993
From:	Liparulo N WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Borchardt R NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ET-NRC-93-3900, NUDOCS 9306110204
Download: ML20045A688 (3)

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Westinghouse Energy Systems b 355 Pittsburgh Pennsylvania 15230-0355 Electric Corporation ET-NRC-93-3900 NSRA-APSI 93-0202 Docket No.: STN 52-003 June 7,1W3 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ATTENTION: MR. R. W. BORCHARDT

SUBJECT:

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE AP600 OUALITY ASSURANCE PROGRAM

Dear Mr. Borchardt:

Enclosed is the Westinghouse response to NRC requests for additional information on the AP600 Quality Assurance Program, from your letter of May 21,1992. Please note that the documents on which the additional information is being sought (e.g., WCAP-13203 and WCAP-13053) have been superseded by the AP600 SSAR and WCAP-13054, Revision 1, respectively. The enclosed response makes reference to the most current information contained in the SSAR and WCAP-13054, Revision 1.

Please contact Brian A. McIntyre on (412) 374-4334 if you have any questions concerning this transmittal.

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N. J. Liparuto, Manager n

Nuclear Safety & Regulatory Activities

/nja Enclosure ec: T. Kenyon, NRC R. Hasselberg, NRC B. A. McIntyre, Westinghouse 110042 /

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Enclosure to Westinghouse Letter ET-NRC 93 3900, dated June 7,1993 Response to NRC Request for AdditionalInformation on Westingb(mse AP600 Quality Assurance Program NRC Request:

"Please' confirm our u.1derstanding that Westinghouse has applied (and will continue to apply) the NRC - approved version of WCAP-8370 which is in effect when performing activities within the scope of the quality assurance (OA) program."

Westinghouse Response:

Westinghouse has applied, and will continue to apply, the latest NRC-accepted revision of WCAP-8370, " Quality Assurance Program," (currently Revision 12A) when performing activities within the ,

scope of the quality assurance program. Refer to subsection 17.3 of the AP600 SSAR.

NRC Request:

"Please respond to the enclosed list of OA-related questions regarding WCAP-13053, "AP600 Compliance with SRP Acceptance Criteria."

Westinghouse Response:

The following OA-related requests for information are in regards to Westinghouse Topical Report WCAP-13053, "AP600 Compliance with SRP Acceptance Criteria." This report has been superseded by WCAP-13054 Revision 1, "AP600 Compliance with SRP Acceptance Criteria," which was submitted to the NRC via Westinghouse letter ET-NRC-93-3802, dated 3/1/93. Reference is made to WCAP-13054 Revision 1 in the following responses.

1. NRC Request:

Westinghouse takes exception to acceptance criteria A.2.a, stating that A.2.a: " Applies only to offsite organizational elements that penain to design and design certification." SRP criterion A.2.a states: "The OAPD is to contain an organizational description that addresses the organizational structure, functional responsibilities, levels of authority, and interfaces." It goes on to elaborate what is required in the OAPD. Please clarify the comment, what the exception applies to, and what is being proposed as an alternative.

Westinghouse Response:

WCAP-13054 Revision 1 lists this requirement as " Acceptable."

2. NRC Request:

Westinghouse indicates that acceptance criterion A.6.a is "N/A." We disagree. This acceptance criterion refers to management's fostering a "no-fault" attitude toward the identification of .

conditions that are adverse to quality. Although the criterion says " Plant management," it .

applies to a plant contractors' management (for example, Westinghouse) as well at to the management of the operating plant. Westinghouse should commit to meet this criterion or  ;

justify any exception. l l

Westinghouse Resp (mse:

WCAP-13054 Revision I lists this requirement as " Acceptable "  !

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d Enchisure to Westinghouse Letter I?P-NRC 93 3900, dated June 7,1993

3. NRC Request:

Westinghouse indicates its position regarding a commitment to Criterion 1 of Appendix A to 10 CFR Part 50 is "TBD." We note that this is a regulation, not guidance. It is applicable to any new plant, and the AP600 must be designed, constructed, and operated in accordance with Criterion 1. The Westinghouse position should be reconsidered.

Westinghouse Response:

The corresponding SRP acceptance criteria are in Section A.7.a. WCAP-13054 Revision 1 lists this requirement as " Acceptable."

4. NRC Request:

Most GA regulatory guidance documents are sht with the Westinghouse position "TBD."

All exceptions and alternatives to the Regulatory Positions provided in the guides must be described clearly in the AP600 SAR.

Westinghouse Response:

The AP600 SSAR fully describes all exceptions and alternatives to Regulatory Positions provided in the specified Regulatory Guides. Refer to subsection 1.9.1 of the AP600 SSAR.

5. NRC Request:

The Westinghouse position regarding Section III of the ASME Boiler and Pressure Vessel Code is that the Code is " Acceptable Except for the AP600 positions identified in Criteria Section A.7.b." Clarify what specific Code requirements will not be met and provide a justification for the exceptions.

Westinghouse Response:

The corresponding SRP acceptance criteria are in Section A.7.d. This section states, "For Class 1,2, and 3 items covered by Section 111 of the ASME Boiler and Pressure Vessel Code, the code QA requirements are to be supplemented by the guidance of the regulatory guides in Section VI.A [of the SRP]." The regulatory guides listed in Section VI.A of the SRP are 1.8, 1.26, 1.28, 1.29, 1.33, 1.152, and Generic Letter 89-02 (endorsement of EPRI NP-5652).

WCAP-13054 Revision 1 states that SRP criterion A.7.d is " Acceptable - Except for the AP600 positions identified in Criteria Section A.7.b." The positions in Criteria Section A.7.b apply to the above referenced regulatory guides and not to the ASME Code directly. Westinghouse takes no exceptions to the requirements of the ASME Code for items to which the Code applies.

6. NRC Request:

Westinghouse takes exception to SRP criterion B.14.e, stating: "New or revised documents available at the location where the activity will be performed prior to commencing work." It is not clear what this means. Please clarify and provide a justification for this exception.

Westinghouse Response:

The statement should read, "New or revised documents are made available .. "

SRP Criterion B.14.e states, "The distribution of new and revised controlled documents is to be in accordance with established timeliness guidelines " The statement in WCAP-13053 indicated how Westinghouse complies with the SRP requirement, and is not considered an exception.

WCAP-13054 Revision 1 states that SRP criterion B.14.c is " Acceptable."

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