ML20236K805
| ML20236K805 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/31/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Andognini C SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| References | |
| NUDOCS 8708100008 | |
| Download: ML20236K805 (6) | |
Text
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. f>g UNITED STATES NUCLEAR REGULATORY COMMISSION y ' ' v,(
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g 1450 M ARI A LANE, SUIT E 210 WALNUT CREE K, CAllFORNIA 94596
%..,*g July 31, 1987 Sacramento Municipal Utility District l
P. O. Box 15830 Sacramento, California 95852-1830 Attention: Mr. C. Andognini, CEO Nuclear i
Gentlemen:
Subject:
Quality Assurance Program Description for Rancho Seco On May 1, 1987, you submitted Revision 1 of the Rancho Seco Quality Manual (RSQM). The RSQM was written to replace the current QA program description contained in Appendix 12B of the Rancho Seco USAR entitled Nuclear Quality Assurance Program Manual (NQAPM). As a result of our review of tne RSQM, we I
have determined that additional justification or clarification is needed addressing the following areas of your QA program:
_ Policy No. I Organization a.
There are no organization charts identifying all the "onsite" and j
"offsite" organizational elements which function ander the cognizance of l
the QA program. The responsibilities of each of the organizational elements noted on the organization charts should be described in the QA program.
b.
The qualification requirements for the QA Manager should be addressed and be at least equivalent to those described in Section 4.4.5 of ANSI /ANS-3.1-1978 as endorsed by regulatory pcsitions in Regulatory Guide 1.8.
c.
The responsibilities assigned to the Nuclear Technical Manager contained in the NQAPM (page PSI-3) is not addressed in the RSQM.
d.
The geraral performance responsibilities of the overall Nuclear Plant 1
organizations contained in the NQAPM (pages PSI-3, 4, and 5) are not addressed in the RSQM.
e.
The responsibilities assigned to the Manager of Nuclear Engineering contained in the NQAPM (page PSI-7) are not addressed in the RSQM.
f.
The position and responsibilities of the Manager of Purchases and Stores as contained in the NQAPM (page PSI-10) are not addressed in the RSQM.
g.
The position and responsibilities for the Security Supervisor contained in the !!QAPM (page PSI-11) are not addressed in the RSQM.
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Mr. C. Andognini 2
July 31,.1987 Policy No. II Quality Assurance Program 1
a.
RSQM Section 4.3, the first sentence should be more specific in its applicability to safety-related structures. We recommend inserting the words " safety-related" after the words " quality of."
Also, the second sentence states that safety-related structures, systems, and components are identified in the Master Equipment List (MEL). The current QA program, described in the NQAPM, states that these safety-related items are identified in the Q-list.
Please provide an explanation for this difference along with historical information on the Q-list; such as, how developed, location in USAR, how deleted and replaced by MEL, and who is responsible for maintaining the official list of safety-related items, b.
Section 4.4 of the NQAPM (page PSII-2) states that the Nuclear Quality Manual additionally addresses the requirements that apply to the following programs: safeguards, radiological monitoring, environmental monitoring, and inservice inspection. These programs are not addressed in the RSQM.
c.
NQAPM Section 5.6 " Quality Control - Inspection / Test / Surveillance" is not addressed in the RSQM.
d.
NQAPM Section 5.7 " Inspection / Test Program" is not addressed in RSQM.
e.
NQAPM Section 5.8 " Surveillance Program" is not addressed in the RSQM.
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f.
NQAM Section 5.10 " Indoctrination and Training" is not addressed in the RSQM.
g.
NQAM Section 6.0 " Program Performance Reviews" is not addressed in the RSQM. With deletion of this requirement of your QA program, how would manaaement provide for an assessnent of the effectiveness of the QA Program?
h.
NQAPM Section 7.0 " Resolution of Differences" is not addressed in the RSQM.
i.
RSQM Exception No. 7 to Regulatory Guide 1.74, page 15 of 16.
Please provide additional clarification to support your position that independent verifications need not require confirmation of the identical action when other indications provide assurance that the prescribed activity is in fact complete. Your examples imply that remote indicators will suffice in place of certified QC personnel.
IE Inforir.ation Notice No. 86-29 addresses this potential problem by citing an example where two heat exchanger isolation valves could have been as nuch as 16 percent cpen while the control roon indication of their position showed closed.
1 Mr. C. Andognini 3
July 31, 1987
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Policy No. III Design Control I
a.
NQAPM Section 4 14 requiring design and/or test documentation from ASME suppliers is not addressed in the R$QM.
b.
NQAPM Section 5.2, the list of responsibilities assigned to the Manager of Nuclear Engineering is not addressed in the RSQM.
c.
NQAPM Section 5.4.4, the QA responsibility for monitoring purchase documents for appropriate quality (design) requirements not addressed in the RSQM.
d.
NQAPM Section 5.6, the responsibility for the Manager, Operations Department to review and approve design control procedures is not addressed in the RSQM.
e.
NQAPM Section 5.7 responsibilities assigned to the Manager of Licensing is not addressed in the RSQM.
f.
An apparent important design control activity appears to be missing from your QA Program.
Please explain why your program does not address treasures to assure that responsible plant personnel are made aware of design changes / modifications which may affect the performance of their l
duties.
If not currently addressed in your program, we strongly l
recommend you consider doing so.
I l
Policy No. IV Procurement Document Control a.
NQAPM Sections 5.1, 5.2, 5.3 and 5.4 describes responsibilities for I
management of various organizations including involvement of the QA Organization. Please provide information as to where in the RSQM these responsibilities are described or justification for their deletion.
b.
NQAPM Sections 5.6.a, d and e described quality requirements for i
procurement; where are these requirements described in the RSQM?
1 Policy No. V Instructions, Procedures and Drawings NQAPM Section 4.5 requirement for administrative procedures prescribing j
plant operation is not addressed in the RSQM.
i Policy No. VI Document Control l
a.
NQAPM Section 4.2.1 and k addressing the Q-list and Nuclear Administrative Procedures, respectively, are not addressed in the RSQM.
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e Mr. C. Andognini 4
July 31, 1987 b.
Section 4.2 of RSQM requires that procedures established for review, approval, issue, change and use of documents to include the organization responsible for this action.
However, no provisions are provided requiring the responsible organization to " develop and implement systematic methods" for control of this activity, nor does it address organizational interfaces currently addressed in Section 5.1 of the NQAPM.
c.
NQAPM Section 5.3, requirement for the identification of personnel responsible for final review and approval of controlled documents and revisions thereto are not addressed in the RSQM.
Policy No. X Inspection NQAPM Section 4.0 addresses a number of inspection programs to be established in order to meet the requirements of 10 CFR 50, Appendix B Criterion X, Inspection.
References to these programs appears to be missing from the RSQM. Specifically, the programs addressed in NQAPM are, a source inspection program, a construction inspection program, a maintenance inspection program, and an inservice inspection program.
The inservice inspection program appears to be an independent inspection of activities performed under the ASME Section XI Inservice Inspection and Testing Program.
Please provide information as to the status of these programs, and if applicable, why these programs are not addressed in the RSQM.
Policy No. XIV Inspection, Test and Operati_n3 RSQM Section 4.3 addresses application and removal of status indicators such as tags, markings and labels.
Do these status indicators also indicate the status of nonconforming, inoperative or malfunctioning structures, systems and components to prevent inadvertent use? If so, it i
appears that Sections 4.3 and 4.5 could be combined into one section addressing this item. Also, the organization responsible for this function should be identified or referenced.
Policy No. XV Nonconforming Materials, Parts or Components RSQM Section 4.4 addresses disposition and technical justification of all accept-as-is and repair dispositions.
Why does this section not address reject or rework dispositions?
Policy No. XVI Corrective Action RSQM Section 5.2 states that each department manager is responsible for assuring that the proposed corrective action is effective.
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Mr. C. Andognini 5
July 31, 1987 We would like to emphasize that the QA organization has an important role in this activity by providing independent verification regarding proper implementation of the corrective action, the adequacy of the corrective action, and that the corrective action is closed out in a timely manner.
Policy No. XVI does not address this as a QA responsibility; therefore, would you provide justification for not including these functions in this policy section.
Policy No. XVII Quality Assurance Records a.
RSQM Section 4.2 states that QA records shall be protected by interim (not to exceed 120 days) storage in one hour file cabinets.
This appears to be contrary to your exception to Regulatory Guide 1.28 (RSQM Section II, page 7 of 16) which states that records shall not be maintained in temporary storage in one hour fire rated cabinets for more than 90 days, b.
NQAPM Section 4.2 identifies the types of records, such as operating log, inspections, to be maintained. This is not addressed in the RSQM but should be along with the words "and other records required by Technical Specifications."
l Policy No. XVIII Audits NQAPM Section 4.9 addressing annual audits, and Section 4.10 eddressing audits conducted when significant changes are made to the QA program, are i
not addressed it che RSQM.
The majority of our comments are directed toward QA Program requirements currently existing in the NQAPM but are not addressed in the RSQM. These I
deletions represent a potential reduction in your QA Program as described in i
the Rancho Seco USAR Appendix 128. Therefore, please provide justification for these changes in accordance with 10 CFR 50.54 (a)(3)(1) prior to j
implementation.
l The Rancho Seco QA Program is addressed in the USAR in Volume VII, Appendix 18, i
and also in Volume VIII, Appendix 128. Normally, the QA Program is listed in a single section of the USAR; we would appreciate your comments on this.
The completion of our review will depend on the satisfactory responses to these items.
l Mr. C. Andognini 6
July 31, 1987 Please contact W. J. Wagner at (415) 943-3731 with any questions you have regarding this matter.
/5/
Dennis F. Kirsch, Director Division of Reactor Safety and Projects cc:
J. G. Spreul, QAB l
G. Kalman, NRR A. D'Angelo, RV i
W. Ang, RV A. Chaffee R. Zimmerman fDc_cumenyControtDesk) l RV/jk
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RICHARDS 6 FATE 5 KIRSCH 7/16187 7/h/87 7/p/87 7/}87 A