ML20053B629

Forwards QA & Core Performance Branches Request for Addl Info Needed to Complete Review of OL Applications.Response Should Take Form of FSAR Amend

ML20053B629
Person / Time
Site:	South Texas
Issue date:	05/17/1982
From:	Miraglia F Office of Nuclear Reactor Regulation
To:	Oprea G HOUSTON LIGHTING & POWER CO.
References
NUDOCS 8206010082
Download: ML20053B629 (6)

Text

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Distribution:

MAY 171982

. Document. Control::50-498/499' NRC PDR L PDR Docket Nos.: 50-498 NSIC and 50-499 TERA TIC LB#3 File Mr. George W. Oprea, Jr.

FMiraglia Executive Vice President DSells Houston Lighting and Power Company JLee Post Office Box 1700 IE Houston, Texas 77001 EReis, OELD ACRS (16)

Subject:

Request for Additional Information - South Texas Project The Quality Assur.nce and Core Performance Branches have identified questions that must be addressed prior to completion of their review of your operating license applications. The specific questions are listed in Enclosures 1 and 2 to this letter.

The Quality Assurance Branch review that resulted in the SER input to the Partial Safety Evaluation Report dated April 1981 was based on Revision 0 i

(November 24,1975) of Section 17.2 of the SRP (NUREG-75/087). We have reviewed FSAR amendments submitted subsequent to March 1981 using Revision 2 (7/81) of Section 17.2 of the SRP (NUREG-0800). This review has resulted in the attached request for additional information.

Items which are asterisked l

reflect SRP Rev. 2 items which are not in SRP Rev.l.In accordance with NPR l

Office Letter No. 2 of April 28, 1982, these items can either be responded l

to or shown in the SER as aceeptable deviations from SRP Rev. 2.

The itens which are not asterisked require a response.

Your response to these questions should be in the form of an amendment to your FSAR.

In view of your current activities with regard to changing contractors, you are requested to provide us with a schedule within 60 days of receipt of this letter by which you plan to respond to this request for additional infonnation.

If you cannot supply a schedule within 60 days, v please advise us when it can be provided.

If you have any questions, contact D. Sells (301/492-7100), the Project

Manager, N

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Sincerely, p

9 Original signed by gECElVED Frank J. Miragua MAYg5199g,, s p-8206010099

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Frank J. Miraglia, Chief namurm I

Licensing Branch No. 3 M e~2x a I

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OFFIClAL RECORD COPY usoeo: mi-m m

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b SOUTH TEXAS i

Mr. G. W. Oprea, Jr.

Mrs. Peggy Buchorn Executive Vice President Executive Director houston Lighting and Power Company Citizens for Equitable Utilities, Inc.

P. O. Box 1700 Route 1, Box 1684 Houston, Texas 77001 Brazoria, Texas 77422 Mr. J. H. Goldberg.

William S. Jordan, III Esq.

Vice President - Nuclear Engineering Harmon & Weiss

& Construction 1725 I Street, N.W.

Houston Lighting and Power Company Suite 506 Washington, D.C..

20006 P. O. Box 1700

' Houston, Texas 77001 4

Mr. D. G. Barker Brian Berwick, Esq.

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Manager, South Texas Project Assistant Attorney General Houston Lighting and Powr Company Environmental Protection Division P. O. Box 1700 P. O. Box 12548 Houston, Texas 77001 Capitol Station Austin, Texas-78711 3

j Mr. M. L. Borchelt Central Powr and Light Company William M. Hill" P. O. Box 2121 Resident Inspector / South Texas Project 1

Corpus Christi, Texas 78403 c/o U. S. NRC 1

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P. O. Box 910 l

Mr. R. L. Hancock Bay City, Texas-77414

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City of Austin Electric Utility Department i

P. O. Box 1088 1

Austin, Texas 78767 l

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Mr. J. B. Poston Mr. Lanny Sinkin.

1 Assistant General Manager for Operations Pat Coy City Public Service Board Citizens Concerned About Nuclear Power I

P. O. Box 1771 5106 Case Oro

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San Antonio, Texas 78296 San Antonio, Texas 78233 f

Jack R. Newman, Esq.

Mr. Cloin Robertson-Lownstein, Newman, Axelrad & Toll Manager, Nuclear Licensing i

1025 Connecticut Avenue, N.W.

Houston Lighting and Power Company i

Washington, D. C.

20036 P. O. Box 1700 1

Houston, Texas 77001 l

Melbert Schwarz, Jr.,,Esq.

1 Saker & Botts Charles Halligan f

One Shell Plaza Bechtel Corporation Houston, Texas 77002 P. O. Box 2166 Houston, Texas 77001 1

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8 ENCLOSURE 1 REQUEST FOR ADDIT 0NAL INFORMATION 26C '

Quality Assurance 260.1*

Identify (on organization charts) the "onsite" and "offsite" HL&P organi-(1AS) zational elements which function under the cognizance of the QA program.

j 260.2*

Describe the criteria for detemining the size of the QA crganization (IAS) including the inspection staff.

260.3 Show that the Manager, Quality Assurance is at the same or higher organi-(181.a) zation level as the highest line manager responsible for perfoming acti-vities affecting quality.

Describe his independence from undue pressures of cost and senedule.

i 260.4*

Clarify whether personnel from the QA organization routinely attend and i

( 18 6) participate in daily plant work schedule and status meetings to assure i

they are kept abreast of day-to-day work assignments throughout the i

plant and that there is adequate QA coverage relative to procedural and i

inspection controls, acceptance criteria, and QA staffing and qualifica-tien of personnel to carry out QA assignments).

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260.5 Clarify whether the Plant QA Supervisor is free from non-QA duties.

Does (IC3) the staff of the Plant QA Supervisor perfom the quality control inspec-tions and NDE which is not subcontracted during the operations phase?

260.6 In the FSAR section 17.2.2.1 update the Regulatory Guide Comitments to (283) include:

a) Regulatory Guide 1.26. Rev. 3 b) Regulatory Guide 1.29, Rev. 3 c) Regulatory Guide 1.144, Rev.1

• Also in the FSAR, comit to comply with 10 CFR Part 50, 550.55a, to con-duct activities under 10 CFR Part 50, 550.55(e) in accordance with the QA program, and to comply with 10 CFR Part 50 Appendix A, General Design Cri terion 1.

For structures, systems, and components covered by ASME Code Section III (Classes 1, 2, and 3), commit to supplement the code QA requirements _by.the. specific guidance addressed in the regulatory positions of' the applicable Regulatory Guides.

260.7 The third paragraph of FSAR section 17.2.2.6 states: " Proficiency test-(2D.d) ing may be waived by the Plant QA Supervisor when the candidate for cer-tification has records of sufficient training, education and experience to warrant certification." Describe controls over the waiving of pro-ficiency testing.

260.8 Describe the significance of deleting "and approved" from the last sen-tence in Section 17.2.3.5 which stated:

...and the department proce-dures will be reviewed and approved by the Operations QA Manager or the Plant QA Supervisor as applicable."

260.9 Provide an organization chart which shows the relationship between the (38) various organizations which will perfom design work for STP during the l

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1 operations phase.

Describe the function (s) of the " Engineering Assur-

i ance" organization shown on Figure 17.2-3 (Amendnent 24).

Describe the interface relationships and division of responsibilities between Engin-eering Assurance and Quality Assurance. With each organization perform-

l ing "its own design verification" per section 17.2.3.4 describe how the lj independence of the verifier is assured.

j 260.10*

Describe controls for the review, approval, release, distribution, and (3D) ~

revision of documents involving design interfaces to assure that struc-tures, systems, and components are compatible geometrically, functionally.

[j and with processes and environment during the operations phase.

l 260.11*

Describe procedures for a documented check to verify dimensional accuracy

j (3E1) and completeness of design drawings.

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260.12*

FSAR section 17.2.3.3 indicates that the QA Department reviews desiga j

(3E2) documents to verify adequate acceptance criteria for inspection and tests.

Confirm that this review also assures that the documents are prepared.

.l reviewed, and approved in accordance with procedures and that the docu-j ments describe the extent of* documentation required.

260.13 Describe how HL&P differentiates between documents that mquire fomal (3E4.c) design verification by interdisciplinary or multi-organizational teams 1

and those which can be reviewed by a single individual.

260.14 Who (i.e., what organization) determines whether a requisition needs to (4A1) be reviewed by the QA Department? If not the QA Department, indicate the QA controls of this activity.

4 260.15 Clarify that as-built documents

• ana topical reports submitted to the NRC (6A1) are within the scope of the document contml program described in FSAR j

section 17.2.6.

!j 260.16 Describe measures which assure that changes to documents are reviewed L

(6A3) and approved by the same organizations that performed the initial review j

and ap$roval or by other qualified responsible organizations delegated by HL&P.

I 260.17*

Describe procedures which provide for the preparation of as-built draw-i (6C1) ings and related documentation in a timley manner to accurately reflect the actual plant design.

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260.18 FSAR section 17.2.7.1 states: "For each applicable purchase order, the i

need for a vendor surveillance plan is evaluated." Who (i.e., what organi-ration) perfoms this evaluation? If not the QA Department, indicate 4

the QA controls of this activity.

260.19 Provide a connitment that procurement of spare or replacement parts for (7A4) structums, systems, and components is subject to present QA program controls, to applicable codes and standards, and to technical require-ments equal to or bettar than the original technical requirements, or as required to preclude repetition of defects.

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260.20 Describe measures which assure that items accepted and released are iden-(782) tified as to their inspection status prior to forwarding them to a con-8 trolled storage area or releasing them for installation or further work.

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I 260.21 For commercial "off-the-shelf" items where specific quality assurance con-I (784) trols appmpriate for nuclear applications cannot be imposed in a prac-ticable manner, describe the special quality verification requirements to provide the necessary assurance of an acceptable item.

260.22 Expand the list of special pmcesses in FSAR section 17.2.4 to include (9A1) as complete a list as possible.

g 260.23 Describe the responsibilities of the various HL&P organizations (ir.clud-1 (9A2) ing the QA Department) in the qualification of special process procedures, I

equipment, and personnel.

O 260.24 Describe the qualification requirements of personnel who perfom surveil-lance. These personnel should be qualified in accordance with Regulatory Guide 1.58 (Rev.1) or Regulatory Guide 1.146.

260.25 Provide a conunitment that irispection results are evaluated and indicate h

(10C3) who (by position title) detemines the acceptability of the inspection y

results.

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260.26

-Describe-measures which assure that program proceduras provide criteria D

(11A1) for detemining the accuracy requirements of test equipment.

j 260.27*

Describe the responsibilities of the QA Department for establishing, imple-

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(12.2) menting, and assuring the effectiveness of the calibration program.

r 260.28*

Identify the organization (s) responsible for calibration, maintenance, (12.3) and control of measuring and test equipment.

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260.29 FSAR section 17.2.2 states: " Equipment shall be suitably marked to indi-

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(12.5) cate calibration status." Clarify this to show that the maaings indi-M cate the due date of the next calibration.

260.30*

Identify (by position title) the responsible management mentioned under (12.6) subheading (5) of FSAR section 17.2.12.

t 260.31 Clarify that an audit-plan is prepared which identifies and schedules p

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(18A2) audits to be performed.

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260.32*

Provide a commitment to continue implementation of the PSAR QA program if (17.2.2 for design and construction activities until these activities are com-i

-3) plete or the FSAR QA program is effectively assuring the quality of these activities.

o ENCLOSURE 2

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i REQUEST FOR ADDITIONAL INFORMATION 491.0 Core Performance 491.1 (4.3.2) The configuration of control bank D and the discussion in section 4.3.2.4.13 indicate that you intend to use an " improved load follow" system.

For Westinghouse reactors with twelve foot cores this has meant a changed (increased) CAOC offset band and a changed (expanded) set of calculational cases to define the offset limits and Fg.

Furthermore, it has been found necessary to restrict the wider offset band width during the first part of the first cycle. This type of information has not been supplied for the fourteen foot core.

If you are using an improved load follow system, provide a discussion of the expanded calculations, the offset band to be used and any e

necessary restirctions required in its use.

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