ML20245L268
| ML20245L268 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/26/1989 |
| From: | Malloy M Office of Nuclear Reactor Regulation |
| To: | Charemagne Grimes Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20245L266 | List: |
| References | |
| NUDOCS 8908220060 | |
| Download: ML20245L268 (37) | |
Text
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~, Enclosure 1
"? .[ '\,a g UNITE 3 STATES r,
l NUCLEAR REGULATORY COMMISSION wasmwoTow o.c.acees k...../
Docket Nos. 50-445 July 26, 1989 and 50-446 MEMORAND M FOR:
Christopher I. Grimes Director Comanche Peak Project Division Office of Nuclear Reactor Regulation THRU:
(hms J. WMson, Assistant Director p for Projects Comanche Peak Project Division Office of Nuclear Reactor Regulation FRON:
Melinda Malloy, Project Manager Comanche Peak Project Division Office of Nuclear Reactor Regulation
SUBJECT:
FORTHCOMING MEETING
- WITH TU ELECTRIC REG COMANCHE PEAX STEAM ELECTRIC STATION Date & Time: Tuesday, August 1, 1989 * !
8:00 an - 1:00 pm ,
Location:
One White Flint North 5 11555 Rockville Pike Rockville, MD 20852 Room 14B-13
Purpose:
To discuss TU Electric's responses to NRC's July 11 1989 request for additional information operations quality assurance program (see enclosure) o,n the for Comanche Peak.
Participants *: NRC M. Malloy TV Electric J. Sprawl D ceviney D. Ringle J. Ayres, et al i
) C Wh s90822no6oeggggk Melinda Malloy, Project Mana r PDR ABOCK O Comanche Peak Project Divisic A PDC Office of Nuclear Reactor Regulation
Enclosure:
RAI as agenda cc: See next page CONTACT (s): Melinda Malloy or Mel Fields (301) 492-0738 (301) 492-0765 for interested members of the public* Meetings between NRC technical petitioners, interveners, or other NRC Statf Policy," 43 Federal28058, Registerparties 6/28/78.
to attend as observers
Y c:
'~ cC*
Asst. Director for Inspec. Programs Comanche Peak Project Division Joseph F. Fulbright U.S. Nuclear Regulatory Commission Fulbright & Jaworski P. O. Box 1029 1301 McKinney Street
~
Granbury Texas 76048 Houston, Texas 77010 Regional Administrator, Region IV Roger D. Walker U.S. Nuclear Regulatory Commission Manager, Nuclear Licensing 611 Ryan Plaza Drive, Suite 1000 Texas Utilities Electric Company Arlington, Texas 76011 Skyway Tower 400 North Olive Street, L.B. 81 Lanny A. Sinkin Dallas, Texas 75201 Christic Institute 1324 North Capitol Street Texas Utilities Electric Company Washington, D.C. 20002 c/o Bethesda Licensing 3 Metro Center, Suite 610 Ms. Billie Pirner Garde, Esq. Bethesda, Maryland 20814 Garde Law Office 104 East Wisconsin Avenue William A. Burchette Esq.
Appleton, Wisconsin 54911 Counsel for Tex-La Electric Cooperative of Texas Susan M. Theisen Heron, Burchette, Ruckert & Rothwell Assistant Attorney General 1025 Thomas Jefferson Street, NW Washington, D.C. 20007 Environmental Protection Division P.:0. Box 12548, Capitol Station Austin, Texas 78711-1548 GDS ASSOCIATES, INC.
Suite 720 Mrs. Juanita Ellis, President 1850 Parkway Place Citizens Association for Sound Energy Marietta, Georgia 30067-8237 1426 South Polk Dallas, Texas 75224 Jack R. Newman Newman & Holt:inger E. F. Ottney 1615 L Street, NW P. O. Box 1777 Suite 10C0 Glen Rese, Texas 76043 hashington, DC 20036 George A. Parker, Chairman Public Utility Committee '
Senior Citizens Alliance of Tarrant County, Inc.
6048 Wonder Drive Fort Worth, Texas 76133 Mr. W. J. Cahill, Jr.
Executive Vice President, Nuclear Texas Utilities Electric Company 400 No. Olive Street, L.B. 81 Dallas, Texas 75201
from C.1.! Grimes (NRC) to W.J. Cahill, Jr.
7 .
(TU Electric) dated July 11, 1989, " Request For Additional Information Pertaining to FSAR i Chapter 17 Issues" ENCLOSURE r REQUEST FOR~ ADDITIONAL INFORMATION i . COMANCHE PEAK QA - FSAR AMENDMENT 76 1.
FSAR 1.38 comitment: Amendment 76 added the following exception to the Regulatory Guide For.standards and handling of items shall during operations phase, the following codes apply.
ANSI B30.9-1971 ANSI B30.2-1976 (1967 for Design and Fabrication)
ANSI B30.5-1968 i specify the guidance in Regulatory Guide 1.38 which will not be followed and the provisions in the listed ANSI standards which will provide an equivalent level of quality and quality assurance.
2.
The justification for deleting "nonroutinely" from page 17.2-7 indicates that the QA documents Department impose reviews procurement documents only when these QA requirements.
QA requimments are not omitted from other procurement documents?Hl 3.
FSAR Section 17.2.1.3 states that the Quality Assurance Section 'is responsible for an effective audit and suneillance program at CPSES.
Clarifythe during whether this responsibility operations phase. extends to suppliers and contractors 4
FSAR Section 17.2.1.4 addresses the Quality Control Section, but it does not address the Brown & Root Site QA Manager which Figure 17.2-1 shows re-porting to the Manager, Quality Control.
sibility of this position (organization) during the operations phase. Discu Section 17.2.1.4 states that the Quality Control Section is m sponsible forAlso, an effective inspection program, but it also states that personnel performing inspections may be from the same department that performed the work.
Clarify to whom personnel that perform inspections report. If these personnel report outside the Quality Control Section, clarify how the Quality inspectionControl program. Section fulfills its responsibility for an effective 5.
FSAR Amendment 71 (at the middle of page 17.2-11) included a commitment to perfom independent management audits of quality assurance activities as of the QA program.necessary to assess the scope, status, implementation, a FSAR Amendment 74 same location) changed this commitment to a connitment to perform an onn(ual independent a the audit program with periodic meetings of the Vice Presidents to assess and report on the status, adequacy, and overall effectiveness of the QA program.
Clarify the difference between the independent management audits of quality audit program. assurance activities and the independent assessments of the commitment in this Provide justification for what appears to be a decrease in regard.
Meetings do not generally satisfy the NRC perceived implementation need for an annual independt at assessment of the scope, status, licensee manage, ment above or outside the QA organization.an
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6.
FSAR page Amendment 17.2-13. 76 addresses:
This paragraph revised the two-sentence paragraph tow (a) the QA Manager's review of procedures and (b) QA review of procedure implementation.
Regarding (a), clarify the purpose of the QA Manager's review of procedures that require 50RC review, clarify that this purpose is documented, and clarify how TU Electric ensures that other proce submitted Regarding (b), SORC for review) the change should not have the same level o .
in Amendment 76 appears to place more responsibility "whether quality this assurance on line management requirements" are to ensureimplemented.
properly that procedures havin is the intent. If not, clarify the intent. Clarify If so, describe how line management is made aware of this increased responsibilit .
7.
FSAR Amendment 76 deleted the cosuittment at the top of page 17 Amendment 71 that procedures used to implement the QA program are .2 before the controlled activities begin. Justify this deletion. prepared
- 8. FSAR Amendment 76 changed page 17.2-21 regarding document Describe measures which ensure the independence of document review. rev document individual not in the NE0 QA Department. preparers when reviews fol
- 9. The description of the first FSAR Amendment 76 change on page 17.2-26 states inspection that it ispoints.
hold to clarify responsibilities / requirements for identifying mention inspection hold pcints. Neither the earlier version nor the new version Clarify the description of this change.
10.
inspection hold points are the only controls requ control procedures and instructions.
"and" to the revision such that it reads: Discuss the pros and cons of adding "In addition, administrative control procedures and instructions are reviewed by the QA Section to assure that required controls are included and to provide for the necessary reviews for the assignment of inspection hold points."
11.
The last sentence on page 17.2-3 of FSAR Amendment 76 sta and test equipment (M&TE) and reference standards are labeled or t indicate the next calibration with approved procedures. due date or othentise con Describe the method of "otherwise controlling" calibration schedules.
12.
Identify (by position title) TU Electric's management authorized to calibration M&TE and accuracy ratios of less that 4 to 1 for reference standards identify who not accepts better than " greater than" for other calibrations. Also, the bases for calibration recognized standard or natural physical constant exists.where no nationally
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e page 17.2-31 of FSAR Amendment 76 which of all inspection, tests, of measurement results...."
14 . - FSAR Amendment 76 the i at botton' of page 17.2-33, has "nonconformance nonconformance repo,rts" to "nonconformance documents." changed Clarify whether I
trending and analyses nonconformances regardless of where they are documented takes into account all
- 15. ;
vities related to nonconformance control from because this responsibility is "assi Nuclear Engineering and Operations...gned .
" to the executive Vice President.
is shown in the FSAR. Identify where this responsibility 16.
The controls associated with nonconforming item conditional release 1 last paragraph of Section 17.2.15 (pages 17.2-34 and 35 Engineering Department -evaluation and approval. eliminate These respo)nsibilities-and items responsibility are s now shown for reinstallation Operation, and use of nonconfor{
as Nuclear Operations.
controls of these actions which . assure safeDescribe gus11ty assurance '
operation. Also, ' "in violation ofthat connitment. Technical Specification requirements" has been added to t nonconforming materials are safety-related service. Justify this not relied upon for limitation.
17.
FSAR to TableAmendment 17.2-2. 76 added Regulatory Guides 1.68 and 1.68.2 (a (NUREG-C800), To bethese delete consistent with the Standard two Regulatory Guides andReview add Plan Regula 1.26 and I.29.
16.
The
- 76. following items refer to changes made in Table 17A-1 by FSAR Am (a) Boron Recycle System (sheets 9 & 10):
Justify changing components from Safety or ANSI 831.1;Class 3 to NNS; from ASME III to ASME VIII Mfrs Stds, from Code Class 3 to no Code Class; and f rom an Appendix during the B operations QA program during the operations phase to no QA prog phase.
Clarify whether TU Electr*c' as discussed in the last paragraph of FSAR 17 these components during the operations phase.
(b) The description of the chan Driven Pump Control Panel "ge to sheet 15 indicates that the Turbine has been deleted from the table.is now seismic and non-1E." and the pane panel during the operations phase. Clarify QA commitments for this (c)
Clarify why the quality assurance requirements of Branch Technical of the liquid waste processing system (shee equipment of the solid waste processing system (sheet 25). '
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(d) during the operations phase.For the following items, FSAR Amen Clarify what to these items during the operations phase.QA program will be applied i 1
Spent fuel handling tool Burnable poison rod assemblies Sheet 34 Primary source rods Sheet 37 Sheet 37 Plant vent stack monitors Sheet 42 High range area monitors Low range area monitors Sheet 42 Steam generator blowdown monitor Sheet 42 Condenser off-gas monitor Sheet 43 Sheet 43 Ventilation duct monitors Sheet 43 Turbine building drain monitors Sheet 43 Failed fuel monitors Sheet 43 Service water monitors Sheet 43 Boron recycle monitor Auxiliary steam condensate monitor Sheet 43 Spent fuel pool cooling Sheet 43 and sample monitors Steam generator blowdown Sheet 43 I
sample monitors Rod control equipment Sheet 43 Rod position indication Sheet 46 containment cabinets Sheet 46 Control board demultiplexes Sheet 46 (f) Justify the portion of Note 65 on sheet 56 which states:
" Tubing systems previously pressure tested as being satisfactory, which were later repaired or replaced, shall not require an additional pressure test prior to initial plant startup...."
(g)
Note 69 on sheet 57 does not appear to be referenced in Table 17A-1.
Specify where this note is referenced in the table or consider its deletion.
19.
The related following items refer to changes made in responses to earlier QA questions:
(a) The response address to Q421.4 only the has been changed in FSAR Amendment 76 to QA Manual.
Clarify the involvement of the QA organization also Q&R421.28.
in other manuals that include QA requirements. See (b) Question .
scope, 421.12 addresses an annual management assessment of the program. status, implementation, and effectiveness of the CPSES QA the FSAR. The response should be incorporated into Section 17.0 of We note that the activities of the Operations Review Comittee and the QA organization do not normally satisfy the NRC guidance for an independent assessment.
and Q&R421.50. See also question 5, above,
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5 (c)
R421.54 refers to Figure 13.1-4 which is now an affidavit.
theManager.
the approximate QA. number of technical onsite QA personnel reporting (d)
R421.79 to the sameindicates thatcontrol procedural "off the shelf" commercial items are " subject
( systems, and components." as all safety-related structures, address items from procurement suppliers withoutand subsequent inspections / tests a 10 CFR 50 Appendix B QA program.
(e)
Five FSAR references are given on page 387 of the Attachment to TXX-89201 45., regarding the removal of chlorine detectors from sheet the chlorine detectors have been determined to b sa fety.
Enclosure 2
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- r.- Enclosure 3 y'
m NRC Question 1:
DRAFI f- FSAR Amendment 76 added the following exception to the Regulatory Gu'de 1.38 commitment:
For handling of items.durin6 Operations phase, the following codes and standards shall apply.
I ANSI B30.9-1971 ANSI B30.2-1976 (1967 for Design and Fabrication)
ANSI B30.5-1968 Specify the guidance in Regulatory Guide 1,38 which will not be followed and the. provisions in the listed ANSI standards which will provide an equivalent level of quality and quality assurance.
TU Electric Response:
It was not our intent to take exception to Reg Guide 1.38. It is our intent to clarify the versior.s of these standards which would be employed at CPSES. These standards are employed in the following documents:
a) Procurement specs for cranes b.) Project response to NUREG-0612 (accepted by NRC staff 1984) c.) DBD ME-06, Control of Heavy Loads at Nuclear Plants Our clarification of the 1967 year of ANSI B30.2 for design and fabrication is a clarification of our commitment to Reg Guide 1.38. This clarification is necessary because the crane purchase orders were either issued or in the process of procurement prior to August 1976. The use of this version of B30.2 was reviewed and accepted by the NRC staff during their review of CPSES response to NUREG-0612.
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. The justification for deleting "nonroutinely" from page 17.2-7 indicates that the QA Department reviews procurement documents only when these documents impose QA requirements. How does the QA Department ensure that QA requirements are not omitted from other procurement documents?
TU Electric Response:
The deletion of "non-routinely" was intended to clarify the QA review responsibilities for procurement documents and eliminate the misleading corollary that " routinely" procured items and services do not receive a QA review. The QA Department reviews all procurement documents which are classified by' Engineering as having quality assurance requirements. The QA Departuent ensures that other procurement documents are being correctly classified by Engineering through the QA audit program. Also, the guidelines used by Engineering for classification of procurement documents are addressed in procedures which require QA Department review and concurrence.
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- v. NRC Quastion 3:
DRAFI FSAR Section 17.2.1.3 states that the Quality Assurance Section is responsible for an effective audit and surveillance program at CPSES.
Clarify whether this responsibility extends to suppliers and contractors during the operations phase.
TU Electric Response: ,
i The intent of this change was to identify the QA section responsible for the audit and r. surveillance programs, which was previously not stated in the organization section.
Requirements for extending the responsibility for suppliers and contractors to have an audit program during the operations phase are described in FSAR Sections 17.2.4, 17.2.7 and 17.2.18.
Requirements for performing audits and surveillance on suppliers and contrar: tors during the operations phase are described in FSAR Sections 17.2.1, 17.2.7 and 17.2.18.
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si- NRC Question 4:
DRAFT 4
FSAR Section 17.2.1.4 addresses the Quality Control Section, but it does not address the Brown & Root Site QA Manager which Figure 17.2-1 shows reporting to the Manager, Quality Control. Discuss the authority and responsibility of this position (organization) during the operations phase.
Also, Section 17.2.1.4 states that the Quality Control Section is responsible for an effective inspection program, but it also states that personnel performing inspections may be from the same department that performed the_ work. Clarify to whom personnel that perform inspections report. If these personnel report outside the Quality Control Section, clarify how the Quality control Section fulfills its responsibility for an effective inspection program.
TU Electric Response:
The B6R Site QA Manager will be deleted from Figure 17.2-1. This position was inadvertently shown when the same NEO organization chart was used for-17.1 and 17.2. FSAR Section 17.1 addresses this position's authority and responsibilities for the construction phase (as the ASME III NA Certificate Holder), and these responsibilities do not apply to this position during the operations phase.
FSAR Section 17.2.10 states that the Manager, QC is responsible for administering and implementing the CPSES quality control inspection program and that quality control inspectors, which may be selected from among any of the NEO departments, will report directly to the Manager, QC when acting in the capacity of quality control inspectors.
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[-NRC Question 5: DRA=T
. FSAR Amendment 71 (at the middle of page 17.2-11) included a commitment to perform independent management audits of quality assurance activities as necessary to assess the scope, status, implementation, and effectiveness of the QA: program. FSAR Amendment 76 (same location) changed this commitment to a commitment to perform an annual independent assessment of the audit program with periodic meetings of the Vice Presidents to assess and report on the status, adequacy, and overall effectiveness of the QA program.
Clarify the difference between the independent management audits of quality assurance activities and the independent assessments of the audit program.
Provide justification for what appears to be a decrease in commitment in this regard. Meetings do not generally satisfy the NRC perceived need for an annual independent assessment of the scope, status, implementation, and effectiveness of the operations phase QA program by licensee management above or outside the QA organization.
TU Electric Response:
This change was intended as a clarification to more accurately describe the two elements which comprise the assessment of the status and adequacy of the QA Program - i.e. , the Joint Utility Management Audit (JUMA) program and the Senior Management QA Overview program (QAOP). The JUMA program ,
provides an annual independent audit of the implementation and adequacy of j the TU Electric QA audit program, and any other aspect of the QA Program as requested by the Executive VP, NEO.
The QAOP provides a mechanism to keep NEO senior management advised of the overall adequacy and effectiveness of the QA Program through review of pertinent data; and provides a mechanism to perform, report, track and j follow-up elements of program assessment, j The QAOP also requires an annual written assessment, prepared by the Vice Presidents, of the overall effectiveness of the QA Program be provided to the Executive VP, NEO. This written assessment incorporates the results of the JUMA program along with information derived from the QA Overview Committee sneetings, the audit program, CARS, Quality trending, NRC Notices i of Violations and Deviations, and other sources of program evaluation to provide a qualitative and quantitative assessment of the effectiveness of the QA Program.
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k NRC Qunticn 6:
FSAR Amendment 76 revised the two-sentence paragraph towards the top of page 17.2-13. This paragraph addresses:
I i (a) the QA Manager's review of procedures and (b) QA review of procedure implementation.
Regarding (a), clarify the purpose of the QA Manager's review of procedures that require SORC review, clarify that this purpose is documented, and clarify how TU Electric ensures that other procedures (not submitted for SORC review) should not have the same level of review. Regarding (b), the change in Amendment 76 appears to place more responsibility on line management to ensure that procedures having no " quality assurance requirements" are properly implemented. Clarify whether tisis is the intent. If not, clarify the intent. If so, describe b w line management is made aware of this increased responsibility.
TU Electric Response:
The intent of the change in the first sentence was to clarify that not all procedures involving operation, maintenance, modification, inspection and testing during the operations phase are reviewed by SORC. The Manager. QA, as a SORC member, provides the QA Department review for those procedures which require SORC review. The purpose of this review, as stated in this sentence, is "for quality assurance requirements" and is intended to provide the quality assurance expertise to the SORC review function.
Operations procedures which do not require SORC review but which address systems, structures, components or activities identified as having quality assurance requirements still require QA Department review. This requirement is imposed through the administrative procedure controlling procedure preparation and review (STA-202), which itself requires SORC review and approval.
This change did not realign any responsibilities for ensuring that procedures are properly implemented. FSAR Section 17.2.5 still states that cognizant supervision is responsible for ensuring that activities are performed in accordance with the procedures and instructions governing the activities.
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o . DRAFT NRC Question 7:
FSAR Amendment 76 deleted the commitment at the top of page 17.2-14 of Amendment 71 that procedures used to implement the QA program are prepared before the controlled activities begin. Justify this deletion.
TU Electric Response:
The justification submitted to the NRC failed to address the deletion of the first sentence. The first sentence was deleted because this requirement is already, and more appropriately stated in FSAR Section 17.2.5 " Administrative' procedures and ir.structions are reviewed and approved prior to performance of the activity" and 17.2.6 " Documents, and changes thereto, are promptly distributed to ensure availability prior to commencement of work".
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NRC Question 8:
i FSAR Amendment 76 changed page 17.2-21 regarding document review. Describe I measures which ensure the independence of document reviewers from document preparers when reviews for QA-related aspects are made by an individual not in the NEO QA Department.
TU Electric Response:
The measures to ensure the independence of the reviewer are included in the administrative procedures which govern preparation and review of the
- applicable documents. These procedures are reviewed by the QA Department l to ensure the necessary controls are included.
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l .- . DRAFT NRC Question 9:
The description of the first FSAR Amendment 76 change on page 17.2-26 states that it is to clarify responsibilities / requirements for identifying inspection hold points. Neither the earlier version nor the new version mention inspection hold points. Clarify the description of this change.
TU Electric Response:
The justification submitted to the NRC for this change was incorrect. The justification is to clarify that the QA Department performs reviews of special process procedures versus just the' Manager, QC and to delete the reference to SORC as certain special process procedures do not require SORC review (e.g., NDE procedures generated by the QA Department).
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DRAFT NRC Question 10:
In FSAR Amendment 76, the last paragraph on page 17.2-27 indicates that inspection hold points are the only controls required in administrative control procedures and instructions. Discuss the pros and cons of adding "and" to the revision such that it reads: "In addition, administrative control procedures and instructions are reviewed by the QA Section to assure that required controls are included and to provide for the necessary revieus for the assignment of inspection on hold points."
TU Electric Response:
The "and" will be added to this sentence as propc. sed. The intent of the change as submitted was to clarify the review requirements within the context of FSAR Section 17.2.10, which deals with .tnspection. However, since the QA review does include assuring that required controls are included (i.e., quality assure.nce requirements are incorporated), the proposed change is acceptable.
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.. . DRAFT NRC Question 11:
The last sentence on page 17.2-30cf FSAR Amendment 76 states that measuring and test equipment (M&TE) and reference standards are labeled or tagged to indicate the next calibration due date or otherwise controlled in accordance with approved procedures. Describe the method of "otherwise controlling" calibration schedules.
TU Electric Response:
Application of labels / tags which indicate Calibration Due Date is the normal practice; however, there are exceptions.
In some instances, Calibration Due Date does not apply and would not appear on the label / tag. For example:
- a. The Celibrate Prior to Use status requires that the device be calibrated prior to each use, and the calibration expires when the device is returned after use. Post usage calibration may be requested at the discretion of the user.
- b. The Inactive status provides that the device is temporarily removed from the M&TE program and has to be calibrated prior to entry back into the program.
In other instances, size or functional characteristics of M&TE or reference standards make labeling / tagging impractical. In these cases, the CPSES program meets the intent of IEEE 498-1985 which states in part (section 5.5): "When size or functional characteristics of measuring and test equipment or reference st adards prevent the application of a label, an identifying code shall be applied to reflect status. When neither labeling nor coding is practical, the procedures shall provide for monitoring of records to ensure control."
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NRC Quastion 12: DRAFT Identify (by position title) TU Electric's management authorized to accept calibration accuracy ratios of less than 4 to 1 for reference standards to M&TE and not better than " greater than" for other calibrations. Also, identify who accepts the bases for calibration where no nationally recognized standard or natural physical constant exists.
TU Electric Response:
When reference standard to M&TE accuracy ratios of lest than 4 to 1 are used, the basis for calibration is documented and approved by the responsible discipline Engineering Manager.
In no case will the accuracy of a calibrating standard be less than the accuracy of the reference standard being calibrated. When calibrating standards with the same accuracy are used, che basis for calibration is documented and approved by the manager of the organization which is responsible for the calibration. The FSAR will be changed to clarify this requirement.
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, i . .. b d NRC Question 13:
Consider substituting "and" for "of" in the middle of the paragraph on paEe 17.2-31 of FSAR Amendment 76 which states "... determine the validity of all inspection, tests, of measurement results..."
TU Electric Response:
This is a typo error - the change submitted read "or" and not "of". This sentence will be corrected to read "and/or".
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.- . DRAFT NRC Question 14:
FSAR Amendment 76, at the bottom of page 17.2-33, has changed "nonconformance reports" to "nonconformance documents." Clarify whether nonconformance trending and analyses takes into account all nonconformances regardless of where they are documented.
TU Electric Response:
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.' . DFIAFT NRC Question 15:
The justif'ication given for deleting responsibility for definition of activities related to nonconformance control from the. cognizant manager is because this responsibility is " assigned to the executive Vice President, Nuclear Engineering and Operations..." Identity where this responsibility is shown in the FSAR.
TU Electric Response:
The intent of this change was to clarify that cognizant managers are only responsible for implementation of activities related to nonconformance control. Definition of the nonconformance control program occurs at the Executive VP, NEO level through the NEO procedure hierarchy. The Executive VP, NEO has approval authority for NEO level procedures / programs. This responsibility is generically addressed in the FSAR in paragraph 17.2.1.1.1 and is also described in the response to NRC Question 421.72.
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3 RAFT NRC Question 16:
C The controls associated with nonconforming item conditional release in the last paragraph of Section 17.2.15 (pages 17.2-34 and 35) eliminate
! Engineering Department evaluation and approval. These responsibilities and responsibility for reinstallation, operation, and use of nonconforming items are now'shown as Nuclear Operations. Describe quality assurance controls of these actions which assure safe operation. Also, "in violation of. Technical Specification requirements" has been added to the commitment that nonco"tforming materials are not relied upon for safety-related service. .lustify this' limitation.
TU Electric Response:
CPSES procedures specify that the Shift Supervisor shall review Conditional Releases and prescribe precautions or limitations for the installation, operation or use of nonconforming items which are conditionally released.
These reviews will be performed by the Shift Supervisor or an SRO to determine the impact on the safe operation of plant equipment.
The addition of the phrase "in violation of Technical Specification requirements" was intended to clarify the phrase " relied on for safety related service." It was not intended to be a limitation. The Shift Supervisor or SRO will review the Conditional Release to determine if the nonconformance effects the Technical Specification operability of equipment.
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s.. . 3RAF7 NRC Question 17:
FSAR Amendment 76 added Regulatory Guides 1.68 and 1.68.2 (among others) to Table 17.2-2. To be consistent with the Standard Review Plan (NUREG-0800),
delete these two Regulatory Guides and add Regulatory Guides 1.26 and 1.29.
TU Electric Response:
Table 17.2-2 will be changed to delete Regulatory Guides 1.68 and 1.68.2 and add Regulatory Guides 1.26 and 1.29, with reference to FSAR Appendix 1A(B) for the CPSES position on compliance.
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NRC Question 18(a):
The following items refer to changes made in Table 17A-1 by TSAR Amendment 76.
I (a) Boron Recycle System (sheets 9 & 10): Justify changing components from Safety Class 3 to NNS; from ASME III to ASME VIII, Mfrs. Stds, or ANSI B31.1; from Code Class 3 to no Code Class; and from an Appendix B QA program during the operations phase to no QA program during the operations phase. Clarify whether TU Electric's "specifically structured non-Appendix B quality assurance program," as discussed in the last paragraph of FSAR 17A.1, will be applied to these components during the operations phase.
TU Electric Response:
The Boron Recycle System was reclassified so that it is no longer ASME III, Code Class 3, and Safety Class 3. System reclassification was performed in accordance with Table A-1 of ANSI /ANS-51.1-1983. As a result of system reclassification, those portions of the Boron Recovery System that were originally ASME III, are now shown on the flow diagram as being within the Radioactive Waste Management System. The Operations Quality Assurance Program for Non-Safety Related Systems,/ Programs will be applied to these -
components during the operations phase. Table 17A-1 will be changed to add Note C to clarify this requirement.
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IMihEl NRC Question 18(b):
The following items refer to changes made in Table 17A-1 by FSAR Amendment 76.
(b) The description of the change to sheet 15 indicates that the Turbine
, Driven Pump Control Panel "is now seismic and non-1E," and the panel has been deleted from the table. Clarify QA commitments for this panel during the operation phase.
TU Electric Response:
The Turbine Driven Pump Test Panel is non-seismic and non-1E. No special quality assurance requirements during the operations phase are required.
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NRC Question 18(c):
{i fi['f The following items refer to changes made in Table 17A-1 by FSAR Arendment 76.
(c) Clarify why the quality assurance requirements of Branch Technical Position ETSB 11-1 are not required for the chemical drain tank pump of the liquid waste processing system (sheet 22) and for the handling equipment of the solid waste processing system (sheet 25).
TU Electric Response:
The requirements of Branch Technical Position ETSB 11-1 (Rev. 1) are not required for the chemical drain tank pump since this is considered to be part of the collection system (similar to sump pumps). The handling equipment for the solid waste processing system has been excluded because there are no specific quality assarance requirements in Branch Technical Position ETSB 11-1 for this equipment and the guideline does not appear to be applicable.
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NRC Question 18(d):
!- .The following items refer to changes made in Table 17A-1 by FSAR Amendment 76.
(d) -For the following items, FSAR Amendment 76 shows no quality assurance during the operations' phase. Clarify what QA program will be applied to these items during the operations phase.
Spent fuel handling rool Sheet 34
' Burnable poison rod assemblies- '
Sheet 37 Primary source rods Sheet 37 Plant' vent stack monitors Sheet A2 High range area monitors- Sheet 42 x Low range area monitors .
Sheet 42 Steam generator blowdown monitor Sheet-43 Condenser off-gas monitor Sheet 43 Ventilation duct monitors Sheet 43 Turbine building drain monitors- Sheet 43 Failed fuel monitors Sheet 43 Service water monitors Sheet 43 boron recycle monitor Sheet 43 Auxiliary steam condensate monitor' Sheet 43 Spent fuel pool cooling and sample monitors Sheet 43 Steam. generator blowdown sample monitors Sheet 43 RSd control equipment Sheet 46 Rod position indication containment cab'inets Sheet 46 Control board demultiplexes Sheet 46 TU Electric Response:
The notes for the individual items listed will be updated to reflect the Quality Assurance Program during the operations phase. The following items will require-the Operations Quality Assurance Program for Non-Safety
'Related Systems /Frograms (Note C) during the operations phase:
' Plant vent stack monitors High range area monitors Low range area monitors
. Steam generator blowdown monitor
, Condenser off-gas monitor Ventilation duct monitor Turbine building drain monitors Failed fuel monitors Service water monitors Boron recycle monitor Auxiliary steam condensate monitor Spent fuel pool cooling and sample monitors Steam generator blowdown sample monitors Y
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NRC Question 18(d) (Cont'd):
AN/b For these item Note 28 will be deleted. The following remaining items add or retain Note 8: ,
1 Spent fuel handling tool Burnable poison rod assemblies Primary source rods j Rod control equipment Rod position indication 1
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DRAFT l3 NRC Question 18(f):
s The following items refer to changes made in Table 17A-1 by FSAR Amendment 76.
(f) Justify the portion of Note 65 on sheet 56 which states: " Tubing systems previously pressure tested as being satisfactory, which were later repaired or replaced, shall not require an additional pressure test prior to initial plant startup..."
TU Electric Response:
The tubing sizes used for safety class 2 and 3 installations at CPSES are 3/8 inch and 1/2 inch outside diameter. The engineering basis for !
exempting repaired and replaced tubing from a repressure test is based on ASME XI, Articles IWA-4400, IWA-7000, IVB-7314, and IWC-7000, 1983 Edition Summer Addenda. These sections of the ASME XI code exempt component runnections, piping, and associated valves 1 inch nominal pipe size and smaller from requiring a system hydrostatic test after repairs. While the installations at CPSES are not code stamped (NA 8000) and not third party inspected (NA 5000), all safety related tubing, valves, and fitting are purchased to ASME III Class 2 requirements. See Note 41, Talte 17A-1. The assembly and installation of fittings is in accordance with the manufacturers recommendations. The replaced and repaired sections are ;
evaluated under a functional leak test.
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DRAFT NRC Question 18(g):
The following items refer to chanEes made in Table 17A-1 by FSAR Amendment 76.
(g) Note 69 on sheet 57 does not appear to be referenced in Table 17A-1.
Specify where this note is referenced in the table or consider its deletion.
TU Electric Response:
Sheet 47 references note 69.
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- h,W;-v-i h NRC Question 19(a):
The following items refer to changes make in responses to earlier QA related questions:
(a) The response to Q421.4 has been changed in FSAR Amendment 76 to address only the QA Manual. Clarify the involvement of the QA organization in other manuals that include QA requirements. See also Q&R421.28.
TU Electric Response: j 1
l The term " manuals" addressed by Q421.4 refers to the four previous QA )
manuals which have been consolidated into the CPSES QA Manual. These previous manuals were the Corporate QA Program, the CPSES QA Plan, the Startup QA Plan, and the Operations Administrative Control and Quality Assurance Plan. The question originally addressed review responsibilities j for these manuals in relation to the separate QA organizations at the I Corporate office and onsite. These separate QA organizations were subsequently consolidated into one QA Department. The changes in the response were intended to reflect the current organization and the consolidated QA Manual.
The reference to Q&R 421.28 is unclear. For QA involvement in the review of procedure manuals, refer to the discussion on question number 6.
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7 ? S'NRC ' Question 19(b): DRAFT The following items refer to changes made in responses to earlier QA related questions:
(b) Question 421.12 addresses an annual management assessment of the scope, status, implementation, and effectiveness of the CPSES QA program. The response should be incorporated into Section 17.0 of the
-FSAR. We note that the activities of the Operations Review Committee and the QA organization do not normally satisfy the NRC guidance for an independent assessment. See also question 5, above, and 06R421.50.
TU Electric Response:
The response to Q421.12 was not changed in Amendment 76 to reflect the annual assessment described in FSAR Section 17.2.2 because Q421.50 readdressed the question and this response refers to FSAR Section 17.2.2.
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. NRC'Qusstien 19(c);
R421.54 refers to Figure 13.1-4 which is now an affidavit. Identify the approximate number of technical onsite QA personnel reporting to the Manager, QA.
~TU Electric Response:
The approximate number of technical onsite QA personnel reporting to the Manager, QA is 35.
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l NRC Quest. ion 19(d):
R421.79 indicates that "off the shelf" commercial items are " subject to the same procedural control as all safety-related structures, systems, and components." Clarify the response and the FSAR text to address procurement and subsequent inspections / tests of commercial items from suppliers without a 10 CFR 50 Appendix B QA pro 5 ram.
TU Electric Response:
During the pror;urement phase of commercial grade (off the shelf) items, characteristics critical to the safety function of the item are identified by procurement engineering. These critical characteristics are subsequently verified by one or more of the following methods:
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- 1) suppliers quality assurance program approved by TU Electric
- 2) inspection / test by TU Electric at the supplier, upon receipt, or during post installation testing.
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l l- NRC Question 19(e):
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' Five FSAR references are given on page 387 of the Attachment to TXX-89201 regarding the removal of chlorine detectors from sheet 45. Clarify whether.
- there will not be chlorine detectors or whether the chlorine detectors have been determined to be not important to ss I.
TU Electric Response:
The chlorine detectors previously listed in Table 17A-1 have been removed from the design and are no longer required. The chlorination systems have been re-designed as described in FSAR Section 2.2.3.2.2.
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