NRC-88-3374, Forwards Response to NRC 880414 Questions 260.1-260.33 Re QA Program for RESAR-SP/90 Pda.Responses Reflect Discussions Between NRC & Westinghouse During Telcons & 880616 Meeting

Forwards Response to NRC 880414 Questions 260.1-260.33 Re QA Program for RESAR-SP/90 Pda.Responses Reflect Discussions Between NRC & Westinghouse During Telcons & 880616 Meeting

ML20205N357
Person / Time
Site:	05000601
Issue date:	10/25/1988
From:	Johnson W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Chris Miller Office of Nuclear Reactor Regulation
References
NS-NRC-88-3374, NUDOCS 8811040078
Download: ML20205N357 (18)

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Westinghouse Power Systems pin'3jgn p,nn,,,,ama is23ao3ss Electric Corporation October 25, 1988 NS-NRC-88-3374 Docket No. STN 50-601 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Charles L. Hiller, Director ,

Standardization and Non-Power Reactor Project Directorate

Subject:

Submittal of Westinghouse Response to Staff RAI (Q260.1 - Q260.33) on RESAR-SP/90 PDA Quality Assurance Program

References:

1) NRC RAI on RESAR-SP/90 PDA, lotter dated April 14, 1988, from Kenyon (NRC) to Johnson (W).

2) Letter No. NS-NRC-88-3373, Submittal of WLAP-8370/7800, Revision 11/7, Johnson (W) to Weiss (NRC), dated October 6, 1988.

3) NRC Draft Safety Evaluation Report Regarding RESAR-SP/90, Rubenstein (NRC) to Johnson (W), dated June 10, 1988.

Dear Mr. Miller:

Enclosed are ten (10) copies of the Westinghouse response to Staff questions 260.1 - 260.33 submitted in Reference 1, regarding the Westinghouse Quality Assurance Program relative to RESAR-SP/90 PDA. The responses reflect discussions between Westinghouse and Staff durino several telecons and during the Westinghouse /NRC meeting at the NRC Rockville office on June 16, 1988.

This submittal is made in conjunction with the recent submittal (Reference 2) of the revised Topical Report WCAP 8370/7800 "Westinghnuse Energy Systems Business Unit / Nuclear Fuel Business Unit Quality Assurance Plan".

Additionally, submittal of our responses in this matter addresses PDA open issue seven (7) identified in the Staff's June 10, 1988 Draft Safety Evaluation Resort (SER) on RESAR-SP/90 PDA. The Questions / Responses will also be sumitted as part of the final amendment to RESAR-SP/90 PDA Module 2, "Regulatory Conformance".

Very truly yours, i \r W hnson, Manager N des Safety Department

~ WhT/bek/02208 __.

Enciosure(s) cc: Thomas J. Kenyon - NRC (MS llH3) p 1revor Pratt - Brookhaven National Lab 8911040070 881025 \

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, REQUEST PtR ADDITICt&L INFORRTION RESAP SP/90 RESPChSE 'IO Q260.1 - 260.33 CH QUALITY ASSURANCE PSOGRAM i

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. F.ST FOR ADDITIONAL INFORMATION RESAR SP/90 260.1 Describe measures which ensure that Westinghouse retains and exe-c.ises responsibility for the overall quality assurance prog for the design and design related activities for RESAR-SP/90. (IA1)gm

RESPONSE

r W has added a transition sentence at the end of the first paragraph of Section 17.1.1 of WCAP 8370/7800 that describes quality assurance responsibility. Additionally it is noted that by definition and use of WCAP 8370/7800, W retains and exercises responsibility for the quality assurance program for RESAR-SP/90 design and design-related activities. Reference NUREG-0800 (1A1) 260.2 Identify and describe the criteria for determining the size of the '

organizat',on(s) responsible for design verification and other quality asswance activities of the RESAR-SP/90. (IA5)

RESPONE:

WCAP 8370/7800 as written provides that each Business Unit or subtier divis'en General Manager (as applicable) is responsible for establishing and implementing a quality assurance program that meets [

the re .. c '. t of the Quality Assuranca Plan. This plan,also states s'- ~

sponsibility for establishing and assuring the effective wplementation of commitments to the plan is assigned by  !

t! v Vice President and/or General Manager of ESBU and NFBU. Staffing for all the nreded disciplines including QA organizations and inspection staffs is included as part of nor mal commitment implementation and does not require any special procedures.

Reference NUREG-0B00 (if,5) 1/ Alpha-numeric indicators refer to acceptance criteria from Section 17.1

- f of the Sta,ndard Review Plan, NUREG 0600, July 1981.

WAPWR-QA 260-1 October 1988 825fm1d

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260.3 Describe provisions for resolving disputes involving quality which result from a difference of opinion between quality assurance personnel and personnel from other departments /diviaions. (189)

RESPONSE

A clarification regarling dispute resolution has been added to the '

third paragraph of Soction 17.1.1 of WCAP 8370/7800. These disputes, if any, are handled witnin the framework of the line organizations '

involved using normal good business practices. No special procedures are used swept for the provisions already existing in WCAP 8370/7800. Reference NUREG-0800 (185) 260.4 Dec.tthe masures which ensure that designtted quality assurance indive,als are involved in day-to-day SP/90 atti ities important to

, safety (that is, the quality assurance organizati... routinely attends and participates in work schedule and status meetings to assure they are. kept abreast of work assignments and that there is adequate quality assurance coverage re ative to procedural and inspection controls, acceptance criteria, and quality assurunce staffing and qualification of personnel to carry out quality assurance assignments). (186)

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RESPONSE

The subject of participation in work schedule ana status meetings has been addressed in the last paragraph of Section 17.1.1 of WCAP [

8370/7800. It should be notad however that the nature and frequency l

) of ptrticipation is dependent upon the practice at a particular '

location and may not be on a dail,e basis. ReferenceNUEG-0800(186) i 260.5 Describe the scope of the Wost h$ house quality assurance program.

(2A1)

WAPkR-QA 260 2 October 1988 sus. id

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RESPONSE

The scope of the W quality assurance program is as described in WCAP 8370/7800, Section 17.1.1 and 17.1.2. This was reviewed during the review meeting with staff on June 16, 1988, and found to adequately address the comitments of NUREG-0800 (2A1),

260.6 Provide a comitment in the RESAR-SP/90 SAR that Westinghouse will 4 met the latest NRC-accepted version of WCAP-8370. Also, update the comitment in Table 17.1 to the latest revision of Regulatory Guide 1.28. (283)

RESPONSE

RESAR-SP/90 SAR wi,11 be revised ta specifically address the latest approved revision of WCAP 8370/7800 and will include comitment to Revision 3 of U. S. NRC Regulatorv Guide 1.28. Reference NUREG-0800 (2B3).

260.7 Identify Westinghouse p: ocedures reflecting that quality assurance regulatory guides, general design criterion 1 of Appendix A to 10 CFR -

Part 50. 10 CFR Part 40 Subsection 50.55(a), and each criterien of 10 CFR Part 50, Appendix 8 will be met by documented procedures.

RESPONSE: .

It was agreed during the June 16, 1988 W/NRC meeting, after reviewing WCAP 8370/7800 as relates to NUREG-0800 (284), that the subject was adequatel.y covered within the various sections of WCAP 8370/7800.

WAPWR-QA 260-3 October 1938 sass.ad 1

260.8 Provide a summary description of how responsibilities and control of quality-related activities will be transferred from Westinghouse to the licensee during the phasecut of design. (2C3)

RESPONSE

WCAP 8370/7800, specifically Sections 17.1.1, 17.1.3, rnd 17.1.6 addresses the subject of this question for NUREG-0800 (2C3). For added clarification however, the last paragiaph of Section 17.1.17 has been r2 'med to show design document and quality assurance records maintenance. Transfer is handled on a case-by-case basis based on specific contract requirements.

260.9 In the area of personnel training and qualification, clarify that:

a. Proficiency tests ara given to those personn61 performing activities affectir.g quality, and acceptance criteria are drieloped to determine if individuals are properly trained and qualified;

c. Certificates of qualification clearly delineate (a) the specific functions personnel are qualified to perform and (b) the criteria used to qualify personnel in each function;

c. Proficiency of personnel performing activities affecting quality is maintained by retraining, reexamining, and/or recertifying.

(2D)

> RESPONSE:

The subject of thir question was found to be adequately addressed in Section 17.1.2 of WCAP 8370/7800 during the June 16, 1988 W/NRC meeting. ReferenceNUREG-0800(23) r WAPWR-0A 260-4 Octcber 1988 sass.1d 3

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9 260.10 Oeteribe internal and external design interface controls, procedures, and lines of communication among participating design organizations and across technical disciplines to assure that structures, systems, and components are compatible geometrically, functionally, and with processes and environment. (30)

RESPONSE

The third paragraph of Section 17.1.3 has been revised to more ,

clearly address the subject of this review question that relates to '

NUREG-0800(3D).

I 260,11 Describe measures which ensure a documented check to verify the  :

dimensional accuracy and completeness of design drawings. (3El)

RESPONSE

P The subjcet nf this question was found to be adequately addressed in Section 17.1.3 of WCAP 9370/7800 during the June 16, 1988 W/NRC '

meeting. Reference NUREG 0800, (3E1).

260,12 Describe measures which ensure that design drawings are reviewed by the quality assurance organization to assure that they are prepared, reviewed, and approved in accordance with company procedures and that

they contain the necessary quality assurance requirehents such as inspection and test requirements, acceptance requirements, and the extent of documenting inspection and test results. (3E2)

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RESPONSE

The subject of this questi'sn was previously covered in WCAP 8370/7800 Section 17.1.1. Clarification was added to tha fourth paragraph of l WCAP 8370/7800, Section 17.1.3. Reference NUREG-0800 (3E2) h i

WAPWR-0A 260-5 October l'J88 s2s6.a o

r 250.13 Describe measures which ensete that procedural control is estublished '

for design documents that reflect the commitments of the SAR; this control differentiates between documents that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual (a signature and date is acceptable documentation for personnel certification).

Design documents subject to procedural control include, but are not

, limited to, specifications, calculations, computer programs, system descriptions, SAR when used as a design dccument, and drawings including flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems formajor facilities, site arrangements, and equipment locations.

Specialized reviews should be used when uniqueness or special design considerations warrant. (3E4c) -

3 RESPONSE:

WCAP 8370/7800 Section 17.1.3 describes measures for procedural  ;

! control for design and verification. By definition a design document '

l is a committent to the SAR and it was agreed that revision of WCAP 8370/7800 is not necessary. It was further pointed out during the

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June 16, 1988 W/NRC meeting that Table 17-1 of WCAP 8370/7800 provides necessary clarifications to regulatory Guide 1.64 Rev. 2.  ;

Reference NUREG-0800 (3E4c) i L

260.14 When design verification is by test, describe measures which ensure that such testing is performed as early as possible prior to ,

installation of plant equipment, or prior to the poir.t when the instal?ation wruld become irreversible. (3ES)

RESPONSE

s WCAP 8370/7800 Sectiens 17.1.3, 17.1.7 and 17.1.8 address the i subjectofdesignverificationby test and procedures for tracking contingencies such as incomplete tests. Section 17.1.3, seventh

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paragraph, has been revised to add clarification related to this commitment. Reference NREG-C800 (3ES) f r

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260.15 The first paragraph of Section 17.1.3 of WCAP 8370/7800 uses the term

' quality standards." Clarify if this term includes s'ich things as codes and industrial standards, test and inspection requirements, and special process instructions. (4A2) 7 RESPONSE:  !

Clarification regarding this question has been provided by revising i

Section 17.1.3, first paragraph and Section '17.1.4, first paracraph.

ReferenceNREG-0800(4A2) 260.16 The second maragraph of Section 17.1.6 of WCAP 8370/7800 indici,tes I that Westingioube may use master lists to identify the current  ;

versions of documents. Clarify how such a list is updated and i 2

distributed. (6B2) i RESPONSE: l

. The second paragraph of Section 17.1.6 has been revised to indicate i updating. Referance NUREG-0800 (6B2) l 260.17 Clarify whether procedures for supplier verification specify the  :

characteristics or processes to be witnessed, inspected or verified, and accepted; the method of surveillance and the extent of i documentation required; and those responsible for implementing these procedures. (7A2)

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RESPONSE

k This question has been resolved by revision of the first paragraph of

( Section 17.1.7. The second sentence has been revised and an f additional ss e added innsdiately following that clarifies the

• commitment. Rs'annee NUREG-0500 (7A2)  ;

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260,13 Position 3 on Regulatory Guide 1.123 clarifies controls on Westinghouse procurement of standard hardware and catalog items.

Describe measures which ensure that, for such procurements, special quality verification requirements shTil be established and described to prov)we the necessary assurance of an acceptable item. (784)

RESPONSE

Table 17-1 of WCAP 8370/7800, Regulatory Guide 1.123 Rev. 1, paragraph 3 (Clarification) has been revised to include testing of the "item" as required. Reference NUREG-0800 (784) 260.19 Describe measures which ensure that the Westinghouse quality assurance organization is involved in the qualification activitivs of special process procedures, equipment, and personnel to assure they are performed satisfactorily. (981).

RESPONSE

A sentence clarifying Section 17.1.9 as relates to this review question, has been added. Reference NUREG-0800 (981) 260.20 Describe measures which ensure that the acceptability of inspection results is determined by a responsible individual or group. (20C3)

RESPONSE

The last paragraph, last sentence of Section 17.1.10 has been revised to address this review question. Reference NUREG-0800 (10C3)

WAPWR-0A 260-8 October 1988 azss.as

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260.21 The second paragraph of Section 7.1.11 of WCAP 8370/7800 lists some test prerequisites. Describe measures which ensure that test prerequisites have been met before doing the test. (11B1)

RESPONSE:  !

In response to this question it is noted that "test prerequisites" are completed prior to test by definition. It was agreed, during the June 16, 1988 review meeting, that WCAP 8370/7800 does not require revision to resolve this review question. Reference fiUREG-0800 (1181) 260.22 Describe quality assurance and other organizations responsibilities for the Westinghouse calibration program. (12.2)

RESPONSE

The first paragraph of Section 17.1.12 has been revised to clarify quality assurance responsibility. Additionally a sentence at the end of the second paragraph has been added to indicate the use of audits to verify the effectiveness of the calibration program. Reference NUREG-0800(12.2).

i 260.23 Describe the review and concurrence of calibration procedures and j identify the organization responsible for these activities. (12.3)

RESPONSE

The response to review question 260.22 above and the commitments provided in Section 17.1.5 of WCAP P370/7800 resolves this question.

Procedures identify the organizational responsibilittws for j calibration activities. ReferenceNUREG-0800(12.3) t WAPWR-0A 260.0 October 1988 sass..t o L, -

e 260.24 Clarify whether measuring and test equipment is labeled or tagged to indicate due date of the next calibration. If not, describe the method of control. (12.5)

RESPONSE

In Section 17.1.12, the last sentence of the first paragraph has been revised to clarify the subject of labeling, tagging, and etc. It should be noted that labels or tags are not always used to indicate when the next calibration is required. This is because it is not always practical depending on the nature and use of the tool or equipment being calibrated. There are always however, procedu.~es that are used for calibration control. Reference NUREG-0800 (12.5) 260.25 Identify the Westinghouse management (by position title, for example) authorized to:

a. aller calibration with less than four-to-one accuracy ratios.

(12.6)

b. allow calibrating standards to have the same accuracy as standards being calibrated. (12.7)

RESPONSE

In Section 17.1.12, the first paragraph of WCAP 8370/7800 has been revised to clarify the use and approvals of transfer ratios.

In place procedures at the various divisions and suppliers vary somewhat but do provide for appropriate and knowledgeable personnel to authorize smaller ratios and accuraciec if needed because of state of the art considerations or end use applications. Reference NUREG-0800 (12.6 and 12.7)

WAPWR-0A 260-10 October 1988 sass..ie

20.26 Describe measures which ensure that procedures for altering the sequence of required tests, inspections, and other operations require the same controls as the original review and approval. (14.3)

RESPONSE

i A clarifying sentence has been added to Section 17.1.14 regarding altering the sequence of required tests, inspections, and other operations important to safety. ReferenceNUREG-0800(14.3) 260.27 Identify the organization (s) responsible for documenting and preventing the inadvertent use of nonconforming items. (14.4)

RESPONSE

A clarifying sentence has been added to Section 17.1.15 regarding organizations responsible for dispcsitioning nonconforming items.

ReferenceNUREG-0800(14.4) 260.28 Describe quali;y assurance and other organizational responsibilities for the definition and implementation of activities related to nonconformance control. This includes identifying those individuals or groups with authority for the disposition of nonconforming items.

(15.2)

RESPONSE

The clarification for 260.27 above and an additional sentence added at the end of the first paragraph of Seet'on 17.1.15 of WCAP

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8370/7800 prowides resolution of this revise question regarding quality assurance and other organization ieconsibilities. As indicated in WCAP B370/7800 procedures describing responsibilities and activities related to nonconformance controi have been WAPWR-0A 260-11 October 1988 8256e.1d

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established at the various divisions and suppliers to address the broad. variety of products and services. Quality Assurance routine ~ly '

includes hardware and software nonconformance control during audit and surveillance activities. ReferenceNUREG-0800(16.2).

260.29 Describe quality assurance and other organizational responsibilities for the definition and implementation of activities related to quality assurance records. (17.2) l

RESPONSE

I As indicated in the June 16, 1988 W/NRC review meeting, WCAP ,

8370/7800 includes an adequate descriptior. of the W commitments regarding Criterion 17 for 10CFR50 App. B and NUREG-0800 (17.2).

Provided below is requested clarification of the information provided in WCAP 8370/7800 as already accepted by the U.S. NRC. The information provided relates to the quality assurance and other  ;

organizational responsibilities for definition and implementation of i activities related to quality assurance records.

W_ has in place a quality assurance records plan generated by Quality 1 Assurance that describes the overall records program and the ,

interface with W Corporate Records Center (CRC). The W CRC has been  ;

found acceptable as a records retention facility by the NRC as indicated in Table 17-1 of WCAP 8370/7800. As part of the [

requirements of this plan each department generates a records

• flow schedule that describes the specific nature, retention method and -

times, location, and any special instructions for quality assurance .

records generated by the department. The flow schedules are 3 maintained and kept current by responsible Department Managea.ent. In ,

I addition, departmental procedures describe the requirements for the

type of records requiring protection, retention, and/or transmittal I to the customer (applicant). The records requirements and methods of i

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the departments and CRC are audited by quality assurance in accordance with internal audit schedules and procedures.

Subtiei suppliers are also required to have quality assurance records protection and retention procedures. These procedures sre audited during normal audit and surveillance activities. Quality Assurance data packages that include records required by specifications and procurement documents, are reviewed at the suppliers facility as necessary. Depending on contract requirements quality assurance data packages are sent directly to the customer and/or H at the time of shipment of the item for input to the records retention program.

4 Suppliers are required to maintain all quality assurance records for periods specified by procurement documents, after which they must notifyHfordispositionirstructions.

Records retention times and procedures are determined from the criteria of standards ANSI N45.2.9, ASME Code Sections !!!-XI, ANS!/ASME NQA-1, Regulatory Guides 1.28 and 1.88, and any other specific requirement as indicated by the customer. The revisions of thesestandardstowhichMhascommittedarenoted in Table 17-1 of WCAP 8370/7800. Reference NUREG-0800 (17.2) 260.30 Describe measures which ensure that audit data are analyzed by the I

quality assurance organization and the resulting reports indicating any quality problems and the effectiveness of the quality assurance program, including the need for reaudit of deficient areas, are reported to management for review and assessment. (1881)

RESPONSE

As described in WCAP 8370/7800, y has procedures ensuring tnat audit data is analyzed by the quality assurance organization (who normally perform all audits) and that resulting reports indicating any quality problems and the effectiveness of the quality assurance program, yAPWR-0A 260-13 October 1988 aus.le

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including the need for reaudit, are reported to management for review and assessment.

Routine review and approval of internal and supplier audits is accomplished by management. Assessment of the quality assurance program is generated for and reviewed by division management. The assessment includes trending of previous audit data and recommenda-tions to correct recurring problem areas. WCAP 8370/7800 and supporting procedures adequately define the method for meeting this commitment. Reference NUREG-0800 (1881) 260.31 WCAP 8370/7800 should be revised to reflect the current Westinghouse organization and related quality / quality assurance responsibilities (see Westinghouse letter NS-NRC-87-3220, PA-87-519, dated April 29, 1987 for latest information received by the NRC).

RESPONSE

WCAP 8370/7800 has been revised to indicate the current Westinghouse organization and is reflected in Figures 17-1, 17-2, and 17-3.

l Notification of organizational changes was made to the NRC by W letter NS-NRC-88-3369 (PA-88-996) dated August 12, 1988. As required by Section 17.1.1 of WCAP 0370/7800 Westinghouse will provide notification should additional changes be made. 'This letter referenced above superceeded letter NS-NRC-87-3220 (PA-87-515) referenced in review question 260.31. '

260.32 The cend parr.oraph cf SAR Section 17.1 refers to a WAPWR Integrated PDA submittal. We understand there has not been and will not be an integrated PDA for RESAR SP/90, therefore this paragraph should be revised or deleted from the SAR.

WAPWR-0A 260-14 October 1988 s:ss.le

RESPONSE

This section will be modified to remove the reference to an integrated PDA submittal, and to reflect incorporating the latest revision of WCAP-8370/7800.

260.33 SAR Table 3.2-1, "Classification of structures, Systems, and Components for the Reactor System," has a column headed "Quality Assurance." This column shows either "WQCS-1" or "WQCS-2" for the i systems / components in the table, and it references a footnote which  :

states: "WQCS-1 and WQCS-2 satisfy the requirements of 10 CFR 50 f Appendix B." Clarification is needed since neither SAR Section 17 nor '

W CAP-8370 address the _WQCS documents.

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RESPONSE

WQCS-1 and WOCS-2 are preplanned quality systems requirements specifications that establish requirements for subtier supply quality j system used in the design and manufacture of equipment specified in procurement documents. In order to clarify the FSAR, Subsection 3.2.2

, of RESAR-SP/90 PDA Modules 4, 5, 7 and 6/8 ;s being revised to 1*dicate that the QA Program described in Chapter 17.1 is applied to SC-1. SC-2 SC-3 structures, systems and comporsnts.

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WAPWR-QA 260-15 October 1988 azuw ie

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TABLE 17.1 Regulatory Guidance Applicable to Quality Assurance Progran +

1. Regulatory Guide 1.26. "Quality Group Classifications, and Standards fc,r '

Water, Steam, and Radioactive Waste Containing Components of Nuclear Powerplants"(2/76) ,

( '

D. Regulatory Guide 1.28 "Quality Assurance Program Requirements (Design andConstruction)"(8/85)

3. Regulatory Guide 1.29, "Seismic Design Classification" (9/78) '

4. Regulatory Guide 1.30, "Quality Assurence Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment" (8/11/72) 4 5 Regulatory Guide 1.37, "Quality Assurance Requirements for Clear,ing of Fluid Systems and Associated Components of Water-Cooled Nuclear Power '

Plants"(3/16/73).

6. Regulatory Guid: 1.38 -

Revision 2 "Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Power Plants" (5/77)

7. Regulatory Guide 1.39 - Revision 2, "Housekeeping Requirements for Water-CooledNuclearPowerPlants"(9/77)

8. Regulatory Guide 1.58 - Revision 1, "Qualification of Nuclear Power Plant inspection, Examination,andTestingPersonnel"(9/80).

9. Regulatory Guide 1.64 -

Revision 2, "Quality Assurance Requirements for the Design of Nuclear Power Plants" (6/76)

10. Regulatory CJide. 1.74, "Quality Assurance Terms and Definitions" (2/74)

11. Regulatory Guide 1.8 - Revision 2. "Collection, Storage, and Maintenance ,

of Nuclear Power Plant Quality Assurance Records" (10/76). >

12. Regulatory Guide 1.123 - Revision 1. "Quality Assurance Requirements for Control (7/77), of Procurement of items and Services for Nuclear Power Plants"  ;

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13. Regulatory Guide 1.144, Revision 1 "Auditing of Quality Assurance l Programs for Nuclear Power Plants" (8/80).  :

14. Regulatory Guide 1.146, "Qualification of Quality Assurance Program Audit Persennvi for Nuclear Power Plants" (8/80).  !

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