ML20212N102
| ML20212N102 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 08/19/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | Martin R NRC OFFICE OF ADMINISTRATION (ADM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| KMLNRC-86-149, NUDOCS 8608280090 | |
| Download: ML20212N102 (11) | |
Text
_ _ _.
KANSAS GAS AND ELECTRIC COMPANY THE ELECTRC COMPANY August 19, 1986 GLENN L KoESTER v<t reassoggy mouctgan F.r. R. D. Martin, Regional Administrator U. S. Nuclear Regulatory Commission i
Region IV 611 Pyan Plaza Drive, Suite 1000 Arlington, Texas 76011 Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C.
20555 91LNRC t6-149 Re:
Docket No. STN 50/482 Ref XMLNRC 86-041 dated 3/11/86, from GLKoester, KG&E, to RINartin and Document Control Desk, NRC Subj:
Clarification to First Annual Submittal of Changes to Operating Quality Program Gentlemen:
The reference contained the annual submittal of changes to the Wolf Creek Generating Station Operating Quality Program as required by 10 CPR 50.54(a)(3).
In conversations between the NRC reviewer and Kansas Gas and Electric Company (KG1E) staff, KG&E agreed to modify portions of the Operating Quality Program described in the reference in order to better l
describe the program.
Attachment 1 identifies the reason for each modification and the basis for concluding that the revised program continues to satisfy Appendix B of 10 CPR 50 and the Final Safety Analysis Report (PSAR) Quality Assurance program comitments. contains marked up PSAR pages identifying the changes.
These changes will be included in the first submittal of the Updated Safety Analysis Report (USAR).
If you have questions concerning this matter, please contact me or Mr. O. L.
Maynard of my staff.
Yours very truly, fDO p
G enn L. Koester Vice President - Nuclear GLK:see Attachments s
) [C '2 [
oc: P0'Connor (2)
JCummins I
{
701 N. Market - Wichtta, Kansas - Mail Address: PO. Box 208 I Nchita, Kansas 67201 - Telephone: Area Code (316) 2616451
ATTACHMENT 1 Change Number 1
Reason Why Change Does Not Reduce Quality Commitments Throughout Chapter 17 and the remainder of the PSAR, KG&E is referenced by nama as being responsible for all aspects of WCGS.
These changes attempt to reduce the number of KG&E upecific references used in the first printing of the USAR.
The phrase "the Operating Agent" will replace KG&E in the Safety Analysis Report. The Operating Agent will be defined in Section 1.4 of the SAR.
KG&E recognizes that they have exclusive responaibility and control over the physical construction, operations and maintenance of the facility and any change in this status requires prior NRC appro val.
KG&E has requested permission to fccm an operating company to assume these responsibilities effective January 1, 1987.
This request was made via KMLNRC 86-06'3 dated 4/15/86.
Generalizing this text will save considerable time and money should the NRC grant this revision to the division of responsibility.
2 Reason Why Change Does Not Roduce Quality Commitments This change eliminates the need to include voluminous acceptance / rejection criteria in each purchasing document package if the information has already been provided to. the vendor.
The criteria remain unchanged and, thus, no reduction in the operating Quality program commitments have been made.
3 Reason Why Change Does Not Reduce Quality Commitments This change clarifies that orperience and records relating to standard plant design and procurement (SNUPPS or industry) may be considered when evaluating a procurement source.
Standard plcnt design factors are directly applicable to Wolf Creek.
No change in the operating Quality program has been made.
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Reason Why Changa Does Not Reduce Quality Commitments This change clarifies that the FSRC may review test procedures through one of its subcommittees.
Test procedures still undergo the same amount of review. This change allows a selected group of PSR: members to review these procedures.
These members can focus more attention on these changes, therefore, allowing a higher level of review.
No reduction in operating Quality program commitments is considered to occur.
'i Reason Why Change Does Not Reduce Quality Commitments This change is editorial. No operating Quality program change has occurred.
Attachmsnt 1 Page 2 of 2 Change Number 6
Reason Why Change Does Not Reduce Quality Commitments The text was originally containel in the response to NRC Queetion 260.49 and has been incorporated into Chr.pter 17. The word stored was changed to controlled to more clearly describe the material use and storage.
No operating Quality Program change has been made.
4 7
Reason Why Change Does Not Reduce Quality Commitments This change clarifies that other groups besides NPE (such as Procurement) may approve the recommended disposition of non-conformances relating to LG&E procurement requirements.
The recommended dieposition of these items is still required to be i
approved by the organization responsible for correcting the problem.
Operating Quality program commitments have not been reduced.
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O ATTAGMENP 2 SNUPPS-WC CHAPTER 17.0 QUALITY ASSURANCE 17.2 QUALITY ASSURANCE DURING THE OPERATION PHASE 17.
2.0 INTRODUCTION
17.2.0.1 Scope This chapter of the FSAR sets forth the requirements for establishing and maintaining an operating Quality ' program for the Wolf Creek Generating Station (WCGS) during.the operations phase.
The
- program provides control over activ-ities affecting quality as required by 10 CFR 50, Appendix B,,
and is structured to comply with NRC Regulatory Guide 1.33.
17.2.0.2 Corporate Policy
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1 The policy of develop, implement, and maintain the operating Quality program for the WCGS as regulated by provisions of the Nuclear Regulatory Commission (NRC) operating license and amendments thereto.
The program is applied to those activiti,es regarding structures,
- systems, and components necessary to assure:
1.
The integrity of the reactor coolant pressure boundary 2.
The capability to shut down and maintain the reactor in a safe shutdown condition 3.
The capability to prevent or mitigate the con-sequences of accidents which could result in offsite exposures comparable to the guideline exposures of 10 CFR 100 17.2.0.3 Program Applicability rrcuJ/y The activities
- controlled by the operating, Quality program include prcepcrational tccting, startup tcctint, operations, maintenance, refueling and modifications.
Also controlledjy the operating Opality program M88eTfa'In *c'o# 's,fri'f*ctT$rY com-n pletion activities such as compo
'. t st
- lushing, and hydrostatic tests performed by th rdu organization.
l 1 The extent of control over these activities as they affect quality is consistent with their importance to nuclear safety.
was Early implementation of the operating Quality program se not intended to require activities to be performed earlier than would be the case if they were performed under the Design and Construction QA Program.
When structures, systems, or com-ponents Aff& released by the construction forces to the I1 startup organization, of,,.
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Page 2 of 8 SNU PPS-WC 17.2.3 DESIGN CONTROL 17.2.3.1 Scope The design, modification, addition, and replacement of safety-related structures, systems, and components at the WCGS shall be controlled to assure that appropriate measures are imple-mented' and to assure that "as-built" quality is not degraded.
The plant design is defined by "CEE, MSSS and the 2'"
in selected supplier design drawings and specifications which illustrate the general arrangement and details of safety-related structures,
- systems, and components and define the requirements for assuring their continuing capability to perform their intended operational or snfety design function.
Design activities shall include the correct translation oN regulatory requirements and design bases into specifications,
- drawings, written procedures,,
and instructions.
(design output) that define the design.
Design analyses regarding reactor physics, stress, seismic, thermal, hydraulic, radia-tion, and accident analyses, used to produce design output documents, shall be performed when appropriate.
Design veri-fication shall be performed, and " reviews of design" will be done to fam111arize g R m c_c ocJ w'
de s i,gn features.l7 ea t. r Aje@ p.norend (a dsCo.J 4 Aken A */
Design activi les s a D Iso inc u e 1) reviewing the appli-cability of standards;
- 2) reviewing commercial or previously approved materials, parts, or equipment for suitability of application; 3) reviewing the compatibility of materials used in the design;
- 4) reviewing the accessibility of equip-ment and components for inservice inspection, maintenance, and repair;
- 5) specifying criteria for inspection and test; and
- 6) reviewing and approving procedures 'for special processes, and verification of computer codes used in the design process.
Procedures shall establish requirements, assign responsibili-ties and provide control of design activities to assure p'er-formance in a planned, controlled and orderly manner.
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17.2-11
Page 3 of 8 SNUPPS-WC Rev,iews of purchasing documents by Quality Branch personnel shall verify that quality requirements are correctly stated, verifiable, and controllable; that acceptance / rejection criter_iaA are i-cluded; and that the documisnts have been pre-l 2
- pared, reviewed, and approved in accordance with
.MCIS's l1 operating Quality program requirements.
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4 17.2-18a
Page 4 of 8 SNUPPS-WC Procurement source evaluation and selection involves the Quality Branch, Nucle'ar Plant' Engineering Division, Nuclear Services
- Division, the Purchasing Department and the WCGS staff.
These organizations participate in the qualification evaluations of suppliers in accordance with written procedures.
Measures for the evalua tion and selection of procurement sources shall be specified in procedures and shall vary 3
depending on the complexity and relative importance to safety of the item or service.
When procurement source evaluations are appropriate, the information to be considered shall i
include one or more of the following:
1.
Experience of users of identical or similar i
products of the prospective supplier.
NRC Licensee Contractor and Vendor Inspection Program (LCVIP) reports, ASMS Certificates of l
Authorization, Coordinating Agency for Supplier f.
Evaluation (CASE)
Register
- listing, M
rec l
in previous procurement ach,oyS s,aJcAmylated on%# anacWs(es product operating experience lJ q /, z r 7
may be used in this evaluation.
When an LCVIP
,,, A,r, y letter of confirmation or CASE register is used to establish a suppliers qualificafion, the documentation will identify the
" letter" or
" audit" used.
Supplier history shall reflect recent capability.
Previous favorable quality experience with suppliers may be an adequate basis for judgments attesting to their capa-bility.
2.
An evaluation of the supplier's current quality records supported by documented qualitative and quantitative information which can be objec-tively evaluated.
This may include review and evaluation of the supplier's QA Program, Manual, and Procedures, as appropriate, and responses to questionnaires.
3.
A source evaluation of the supplier's technical l
and quality capability as determined by a
direct evaluation of facilities and personnel (audit, surveillance, trip report) and quality assurance program implementation.
Procurement source evaluations involve a review of technical and quality considerations to an extent considered appropriate by each participant.
Technical considerations include the l
design or manufacturing capability and technical ability of suppliers to produce or provide the design, service, item, or component.
17.2-27
Page 5 of 8 i
SNUPPS-WC 17.2.11 TEST CONTROL 17.2.11.1 Scope _
Testing shall be performed at the WCGS to demonstrate that safety-related structures,
- systems, and components perform satisfactorily in service.
Test programs include preopera-tional tests, initial startup tests, surveillance tests, pump and valve tests, and special tests, including those associated with plant maint3 nance, modification, procedure
- changes, failure analysis, and the acceptance of purchased material.
17.2.11.2 Procedural Control ts~ n n.a nny shall be established by the Director Nuclear progrfms Test Operations to assure that tasting demonstrates item or system performance.
Testing shall be performed in accordance with written procedures which incorporate or reference the require-ments and acceptance limits contained in applicable Technical Specifications, drawings, instructions, procurement documents, specifications, codes, standards, and regulatory requirements.
Test program procedures shall control when a test is required and how it is to be performed.
l
't est administrative procedures, test procedures and checklists employed during tests shall include, as applicable, prerequi-site conditions; material and test equipment requirements; mandatory hold points; testing method instructions; limiting conditions and acceptance / rejection criteria; data collection method and test result approval requirements.
Where outside organizations are utilized for plant or plant-related tests, procurement document requirements shall impose test require-ments consistent with those described herein.
17.2.11.3 Personnel _ Qualifications rQjut
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o Personnel within the various M6e organizations or outside organizations shall perform testing activities, including implementing test procedures and the evaluatipn and reporting of test results.
The assignment of plantWesting personnel shall be under the direction of the Startup "anager for pre npa W 3n=1 taating and the Plant Manager for initial start.up teeting and ~ st plant acceptance tccting.
Qualified person-nel outside the plant organizations may be emplo e,d );o per-form testing activities.
Qualification of %
- p'e rsonnel shall be defined in levels of capability which are not limit-ing with regard to company position.
The number of levels established for each classification of test personnel shall be at least one but not more than three.
Testing assignments shall be consistent with the certification of an individual.
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Page 6 of 8 SNUPPS-WC A testing personnel procedure shall be established to assure test program activities are perform (d by qualified personnel.
Plant procedures and procurement documents shall prescribe the qualification requirements of testing personnel.
The Startup M
p r and th Plant Manager shall be responsible for assur-ing that test personnel are qualified for certification during the tes) programs for which they have responsibility.
They shall e2.nsure documented evidence is a'rallable of qualifica-tions of personnel performing plant test functions.
17.2.11.4 Test Results Test results shall be documented, reviewed, and approved by qualified individuals or groups.
Equipment found to be defi-cient shall be identified in accordance with Section 17.2.14.
Surveillance test results which fail to meet the requirement's criteria s all be documented and reviewed in CEEin.Mj'DS.
and acceptance Deficiencies identified as accordance with nonconforming shall be reviewed in accordance with Section 17.2.15.
17.2.11.5 Test Evaluations so. t res7 &~p
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Upon completion of syste pre rational testing, the test results 1Ee submitted to th TG for its review and subsequent l 5 recommendation for approval a the Startup "ana cr and. Plaat Sturp M t A y, m.
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.njp4 t<vw.7 p ur..,,, c. r, s.n a.n a, w ru ns The results of special tests pc rfc=cd after fuci 1 cad cha -l uc ha reviewed by the PSRC. Proposed teste to M performed by tha.
Ctartup crganinstien which involve an unreviewed safety ques-by the NSRC prior t@)@i esY.'gecifications shall be re -
change in the Techn. cal S tion or The NSRC shall'.'i~evice-viewed any test reports associated with such tests.
Tcct prccclurce perfor cd af ter fuel load arc reviewed by qualified p^reen"cl and the PCRC, and approved by the Plant "anager.
17.2.11.6 Preoperational and Startup Tests The Startup Manager ch N I 50 responsible for the administra-tion and conduct of the preoperational testing program.
The Plant Manager sh t he responsible for the administration and conduct of the initial startup testing program and all post plant acceptance testing.
Test procedures employed during th,e, preoperational and the initial startup test programs shal'"S preparedandapprovedundertherequirementsoftheWolfC{eg j
administrative procedures.
Preoperational test procedures ase-reviewed by qualified personnel and the JTG, and approved by Initial startup"etest procedures and post the Startup Manager.
procedures Be reviewed by qualified plant acceptance test personnel and the PSRC, and approved by the Plant Manager.
l 17.2-42 1
Page 7 of 8 SNU PPS-WC 17.2.13 HANDLING, STORAGE, AND SHIPPING 17.2.13.1 Scope Safety-related items including parts of structures, systems, and components shall be handled, stored, shipped, cleaned, and preserved to assure that the quality of items is preserved from fabrication until incorporation into the WCGS.
17.2.13.2 Procedural Control Generic procedures shall be prepared for application to these 7
activities; however, as appropriate, detailed procedures shall be prepared for the handling, cleaning, storing, maintaining while stored, packaging, or shipping of specific items of types of equipment or material. ce,va,uuc,. A /,hd,:. sfe r -re/.rts armt ro,,, syrnms <,,d compowKr a a e u s,.te,. we c.,,/,as J Na a,,.y G
ni: ny Procedures shall provide instructions for the storage of materials and equipment to minimize the possibility of damage or lowering of quality from the time an item is stored upon receipt, until the time the item is removed from storage and placed in its final location.
The manufacturers ' recommenda-tions are conside red and generally are incorporated into storage instructions,
- however, relaxation of manufacturers '
s torage requirements may be implemented if an engineering evaluation determines that relaxation is justified because of unrealistic storage recommendations which are not reasonably necessary to preclude equipment degradation.
Material and equipment shall be stored at locations which have a designated storage level.
The various storage levels shall be proce-durally defined and shall have prescribed environmental con-ditions. The storage conditions shall be in accordance with design and procurement requirements to preclude damage, loss, or deterioration due to harsh environmental conditions.
Items having limited calendar or operating life shall be identified and controlled to preclude the use of items whose shelf life or operating life has expired.
17.2.13.3 Special Procedures Procedures shall be prepared for all items that require special handling and shall be available prior to tne time items are to be moved.
Items not specifically addressed by procedures shall be handled in accordance with sound material handling practice.
The movement of fuel assemblies to and in the reactor core shall be handled in accordance with the technical specifications.
Other material handling activities may involve personnel from various plant organizations.
Oper-ators of special handling and lif ting equipment shall be expe-rienced or trained in the use of equipment.
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items which are identified by outside organizations as non-those nonconfor-
.ecifyEf approval of con.iorming.
the mances which shall be submitted to e recommended disposition.
Actions taken in response to these s.all require documentation and shall be fo r-h nonconformances
' accompanying warded, toTM'%Tdfig with the hardware and quality verification documentation.
"uc1 car Plant F gineer-7 seg shall approve the, recommyded disposition of nonconform-ances relating to EAGirb'MALTrated procurement requirements.
The Quality Branch staff shall be responsible for jdE?_ n; the processing of these supplier-recommended dispositions.
The disposition of a nonconformance which involves the design requirements shall be treated as a design change and, there-fore, approved by the responsible design authority.
17.2.15.6 Reportable Nonconformances Nonconformances shall be evaluated for reportability to the NRC under 10 CFR 21.
All nonconformances identified as re-portable shall be reviewed by the PSRC and NSRC.
17.2. 15.7 Trend Analysis Nonconformance documentation shall be analyzed by Quality Branch personnel for identification of potential unsatisfac-tory programatic quality trends and vendor performance.
The results of these analyses shall be reported to management.
Significant adverse quality program trends shall be handled in accordance with Section 17.2.16.
th ey m Ayu-r within bs.
Hardware malfunctions of equipment are reviewed by a nuclear plant reliability data system program.
The pro-gram will determine and evaluate the causes of hardware mal-functions / failures.
A review and evaluation of previous experiences (trending) for the equipment or component is made to determine whether the item is functionally reliable.
The program providea corrective measures prior to the repair /
replacement of components in safety-related systems which have i
been performed in a reliable manner.
17.2-52
.