ML20209F947
| ML20209F947 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 04/24/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 NUDOCS 8704300431 | |
| Download: ML20209F947 (9) | |
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Duun POWER GOMPANY P.O. BOX 33189 CHAmLorrrE, N.C. 98949 HAL B. TUCKER Tatarmours M"
t April 24, 1987 i
U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555
Subject:
McGuire Nuclear Station Docket Nos. 50-369 and 50-370 Gentlemen:
l By letter dated March 16, 1987, Duke submitted proposed changes to the NkGuire Nuclear Station Technical Specifications for containment penetration conductor overcurrent protective devices. A part of this proposal seeks to transfer the i
table listing these devices (Table 3.8-1) out of the Technical Specifications into a Duke controlled document, the System Description. Discussions between the NRC j.
staff and Duke's staff have determined that additional information is needed by 4
NRC to address this proposal; first, additional information on the control, maintenance, and update of the system description; and secondly, utilization of the documents in'the field, i.e., how are the descriptions referenced, incorpor-l ated or otherwise utilized in station procedures.
The control and maintenance of the system descriptions is controlled in accordance with the Duke Power Company Topical Report, " Quality Assurance Program", Duke-1, l
which is incorporated by reference into the McGuire FSAR. The report speciffes that each safety-related design document is prepared by a qualified individual, includes appropriate codes, standards and commitments. This is discussed in detail in the Topical Report, Sections 7.1.3 and 7.2.3 (" Design Control"), which j,
are attached for convenience of review. This Topical Report also provides details of required reviews prior to modifications.
l The second item concerned the use of the system description in station procedures.
l It first should be noted that the Limiting Condition for Operation (LCO) remains the same as does the surveillance requirements for the circuit breakers. The i
proposed change to the surveillance requirements for fuses may be considered i
independent of the proposed transfer of the tables and is unaffected by that portion of the proposal. Technical Specification 6.8.la requires written pro-l cedures be established, implemented, and maintained covering activities recom-mended in Appendix A of Regulatory Guide 1.33, Revision 2. February 1978, which l
includes onsite electrical systems.
if' The test procedure for the fuses and breakers will reference the system descrip-tion.
(The procedure has been drafted, but will remain in draft form pending Ok
Document Control Desk April 24, 1987 Page 2 approval of the proposed relocation of the tables; the existing procedure is essentially identical except that it references the tables in the Technical Specifications.) The procedure itself will contain a table of the devices and will include a step to verify that all penetrations listed in the system de-scription are listed in the procedure. This step will identify for resolution any discrepancies. The procedure will also include a historical data sheet to indi-cate and record which circuits have been tested as to ensure that all circuits are tested on a rotating basis as required by the Technical Specifications.
As this submittal provides supplemental information to an earlier proposal, no license fees are enclosed.
If any additional information is needed to complete the review, please contact us through normal licensing channels.
Very truly yours, Hal B. Tucker JBD/187/jgm Attachment xc:
Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission i
101 Marietta St. NW, Suite 2900 l
Atlanta, Georgia 30323 l
Mr. Darl Hood l
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C.
20555 Mr. W.T. Orders NRC Resident Inspector McGuire Nuclear Station l
Mr. Dayne Brown, Chief
[
i Radiation Protection Branch Division of Facility Services Department of Human Resources
(
P.O. Box 12200 Raleigh, NC 27605 i
l t
. 4 ATTACHMENT DUKE POWER COMPANY TOPICAL REPORT
" Quality Assurance Program" Duke-1 7.1 Quality Assurance During Design and Construction 7.1.3 Design Control 7.2 Operational Quality Assurance 7.2.3 Design Control 4
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o 17.1.3 DESIGN CONTROL Duke has assigned overall responsibility for design of nuclear stations to its Design Engineering Department and responsibility for quality assurance of design to its Quality Assurance Department.
The relationships existing for interdepartmental design control, and procedures for control within the various departments and the NSSS supplier are discussed below.
The Engineering Quality Assurance Program contains procedures and instructions for implementation and assurance of design control during the various phases of design activities for nuclear safety related items.
These procedures and instructions assure the design is performed in accordance with approved criteria, and that deviations and nonconformances are controlled.
Each safety-related design document, such as a calculation, specification, purchase requisition, or drawing, is prepared by a qualified individual in Design Engineering who specifies and includes the appropriate codes, standards, and SAR commitments within the design documents. He notes any deviations or changes from such standards within the design documentation package.
Each design document is then checkec; by another individual qualified in the same discipline and is reviewed for concept and conformity with applicable codes and standards (as specified within the design documentation package).
The document is approved by the chief engineer or his designee having overall responsibility for the design function.
A review of each specification is made by the Quality Assurance Manager, Technical Services er his designee to assure incorporation of necessary quality assurance information.
The entire review process is documented.
During the check and review, 'particular emphasis is placed on assuring conformance with applicable codes, standards and SAR design commitments.
The individuals in Design Engineering and Quality Assurance assigned to perform the check and review of a nuclear safety related document have full and independent written authority to withhold approval of the document until every question concerning the work has been resolved.
If required, the matter can be carried up to the Vice-President, Design Engineering by individuals in Design Engineering or to the Corporate Quality Assurance Manager by individuals in Quality Assurance for resolution.
The checker verifies calculations by checking or by alternate computations. Analytical models, theories, examples, tables, codes, computer programs, etc., used as bases for design must be referenced in the design document and their application verified during check and review.
Model tests, when required, to prove the adequacy of concept or design are reviewed and approved by the responsible engineer.
The tests used for design verification must meet all the requirements of the designing activity.
6 Computer programs are controlled in accordance with the Design Engineering Quality Assurance Manual whereby programs are certified to demonstrate their applicability and validity.
Prior to the release of any safety-related design document, it is reviewed by the chief engineer of the sponsor division (i.e.
Civil-Environmental, Mechanical-Nuclear, Electrical) or his authorized representative. Additionally, the documents are reviewed by the chief engineers of the other division, or their authorized representatives, to assure coordination of disciplines.
If the document clearly involves no coordination with the other divisions, this review may be waived by the sponsoring chief engineer, with documented concurrence by the other chief engineers.
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Any changes to the original design and procurement documents, including field changes, must be reviewed, checked and approved commensurate with the original approval requirements as discussed above.
After drawings and specifications have been properly prepared, checked, and reviewed by the appropriate parties, the responsible engineer sends the document to the General Services Division which distributes copies of the document in accordance with the approved distribution code.
When required, each recipient of a design document verifies his receipt of such document in writing to the General Services Division.
The General Services Division after verification of distribution to the responsible engineer, maintains the required documentation in its files until such time as it is stored or turned over to the Quality Assurance Department for final storage.
When deficiencies are discovered in the construction phase which affect the design of safety-related structures, systems, and components, such deficiencies are noted on Nonconforming Item Reports sent by an engineer (originator) to the Vice-President, Design Engineering or his designee (recipient).
The report is logged in and is then forwarded for appropriate review to the responsible engineer, who coordinates further review of the problem and revises all design documents affected by the report as necessary.
Where required, the responsible engineer also forwards copies of the report to the chief engineers in other divisions, who coordinate any revisions to their documents affected by the report.
The responsible engineer and an individual in Quality Assurance, Technical Services Division then signoff the engineering portion of the report.
The responsible engineer returns one copy of the completed report to the recipient and sends copies to the appropriate engineering files.
The recipient then forwards the approved report to the originator.
Design interfaces are maintained by communication among the principals such as Design Engineering, Construction, Purchasing, Nuclear Production, NSSS supplier and 6
other vendors.
Methods by which this is accomplished include the following:
(a) Safety-related design documents are reviewed by the chief engineer of the applicable Design Engineering division or his authorized representative.
As appropriate, subsequent review or waiver of review by the other chief engineers is documented.
(b) Design review, project review and startup review meetings are scheduled to coordinate design, procurement, construction and preoperational testing of the station. These meetings provide a primary working interface among the principal departments.
l (c) Reports of variations and nonconformances (applicable to Construction j
Department and Design Engineering) are transmitted and controlled by procedures in the department quality assurance program manuals and as outlined in this section.
Quality Assurance approves resolution of all nonconformances.
All variations from Design Engineering documents must be approved by Design Engineering.
Design Engineering is required to evaluate the cause of the variation to determine if a
design nonconformance exists.
When a design nonconformance results it must be 6
submitted to Quality Assurance for review and approval.
Design Engineering is required to perform a trend analysis on all variation notices.
These trends and implementation of the entire variation notice process receive audits and surveillance by Quality Assurance.
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r (d) The NSSS supplier's quality assurance programs are reviewed and approved by the Quality Assurance Department and must include procedures that provide for the control of designs used in the production of safety-related items.
(e) Formal lines of communication are established between Quality Assurance, Technical Services and the NSSS supplier shortly after award of the NSSS contract.
The lines of the communication are established and documented through the project organization of both Design Engineering and the NSSS supplier, and through the quality assurance organizations of Duke and the supplier.
(f) Items designed by the NSSS supplier, other vendors or consultants are reviewed by Design Engineering to assure compatibility with Duke designed systems and compliance with applicable regulatory requirements.
Standard commercial
(" shelf hardware") items or previously approved items used in nuclear safety related designs are subjected to the same verification and checking process for suitability of application as other items.
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17.2.3 DESIGN CONTROL In order to provide for the continued safe and reliable operation of a nuclear station's nuclear safety-related structures, systems and components, design control-measures are implemented to assure that the quality of such structures, systems and components is not compromised by modifications.
A controlled listing of safety related structures, systems, and components is jointly approved and issued by the Vice -President, Design Engineering and Vice President, Nuclear Production.
Revisions to this document are jointly approved and issued until an operating license is issued.
The Vice President, Nuclear Production is responsible for approval and issuance after issuance of the operating license.
Prior to commercial operation, all design verification shall be completed on systems that are required for operations of the plant.
Design modifications, including field modifications are subject to design control measures commensurate with those applied to the original design and are approved by the organization that approved the original design unless another responsible organization has been designated.
'These design control measures assure that modifications are designed and implemented in accordance with applicable codes, bases, standards, specifications, etc.
Design verification may consist of reviews, alternate calculations, and/or qualification testing.
Design reviews are intended to verify the correctness of design inputs, logic, calculations, and analyses.
Calculations by alternate methods provide assurance that, for instance, computer codes are performing as expected, and that no systematic error. in calculational procedure exists.
Qualification testing, when suitable, is guided by Duke Power's adoption of various regulatory guides which deal with qualification testing.
Design verification shall be performed by qualified individuals in accordance with approved procedures which identify the responsibilities, features and pertinent considerations to be verified, and documentation requirements.
The use of the originator's immediate supervisor for verification shall be restricted and justified to special situations where the immediate supervisor is the only individual competent to perform the verification.
In order to assure proper interface control, the responsibilities of the various individuals / organizations involved in modifictions are formally identified.
The assignment of responsibility for the evaluation and design of a particular modification to a specific individual / organization is documented. Also, the written instructions addressing the control of modifications address the communication of information between involved individuals / organizations and, where appropriate, require documentation of such communications.
Each request for a modification is reviewed by a cognizant, designated individual at i
the station to determine if the station is adequately qualified to perform the necessary evaluation and design of the modification.
If it is determined that the
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station is not adequately qualified or staffed to design the modification, then the l 7 i
responsibility to evaluate and design the modification shall be transferred to the Manager, Nuclear Maintenance.
i For each proposed modification, the individual / organization assigned responsibility j
for evaluation and design of the modification considers the following in the design of the modification:
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(a) Necessary design analyses, e.g., physics, stress, thermal, hydraulic, accident, etc.
(b) Compatibility of materials.
(c) Accessibility for operation, testing, maintenance, inservice inspection, etc.
(d) Necessary installation and periodic inspections and tests, and acceptance criteria therefor.
(e) The suitability of application of materials, parts, components, and processes that are essential to the function of the structure (s), system (s) and/or component (s) to be modified.
The individual / organization assigned responsibility for evaluation and design of a modification performs a safety evaluation of the proposed modification.
This evaluation provides the bases for the determination that the modifiction does or does not involve an unreviewed safety question.
This evaluation is reviewed by an individual / group other than the individual / group performing the safety evaluation, but who may be from the same organization as the individual / group which performed the safety evaluation.
This evaluation and the review thereof are documented.
completion of design and evaluation of a modification, the responsible Following / organization provides a summary of the design of the modification and individual Information pertinent thereto.
This summary addresses such items as:
(a) A description of the modification.
(b) References utilized in the evaluation and design of the modification, and necessary for the implementation of the modification.
(c) Special installation instructions.
(d) Operational, test, maintenance and inspection requirements.
(e) Materials, parts and components required in order to implement the modification.
(f) Drawings revised and/or requiring revision.
(g) FSAR revision (s) and/or Technical Specifications amendment (s) necessary.
(h) Whether or not the modification involves an unreviewed safety question.
The design summary is reviewed by an individual / group other than the individual / group preparing the summary, but who may be from the same organization as the individual / group which prepared the summary.
The design summary is approved by a cognizant, responsible individual within the organization which prepared the summary.
The design summary and the review and approval thereof are documented.
Qualification testing of the design of a modification, including qualification testing of prototype units, is performed as necessary.
The Quality Assurance Department reviews the proposed modification, including applicable implementing procedures associated therewith, certifies that quality Carryover 17.2-7 Amendment 6
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assurance requirements have been met and determines inspection requirements prior to implementation of the modification.
For modifications which are evaluated and with l 7 designed by the station, the Nuclear Production Department General Office is forwarded a
description of the modification prior to or concurrent implementation.
Modifications which are determined to involve an unreviewed safety question are reviewed by the Nuclear Safety Review Board and must be authorized by the Nuclear Regulatory Commission prior to implementation.
Prior to a modification being declared operable and returned to service, all procedures governing the operation of the modification are reviewed and revised as necessary.
If the modification significantly alters the function, operating procedure, or operating equipment, then additional training is administered as necessary.
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Final approval of each station modification is the responsibility of the applicable station Manager.
Modifications are then executed in accordance with approved checklists, instructions, procedures, drawings, etc., appropriate to the nature of the work to be performed.
These checklists, instructions, procedures, drawings, etc. include criteria for determining the acceptability of the modification.
Errors and deficiencies noted in the design of a modification are corrected by means s
of a variation notice or a revision to the modification.
The control measures l 7 applied to each such modification revision or variation notice are equivalent to the control measures applied to the modification originally.
Each modification revision or variation notice'and the review and approval thereof, is documented.
Adequate identification and retrievable documentation of station modifications is retained for the life of the station.
Computer programs are controlled in accordance with Design Engineering's Quality Assurance Manual and Nuclear Production's Administrative Policy Manual, whereby programs are certified to demonstrate their applicability and validity.
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