ML19208C484

Forwards Ltrs Re Black & Veatch QA Program.Focuses on NRC 790430 Ltr to Black & Veatch Identifying 32 Potential Deficiencies in QA Program.Info Re Effect of Deficiencies on Black & Veatch Design Work Is Requested

ML19208C484
Person / Time
Site:	Black Fox
Issue date:	07/16/1979
From:	Farris J FELDMAN, HALL, FRANDEN, REED & WOODWARD
To:	Davis L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML19208C485	List: ML19208C484
References
NUDOCS 7909260493
Download: ML19208C484 (1)

Text

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HRC PUBLIC DQCUMM 309M g;M  %,,

FELDMAN, HALL, FRANDEN, REED & WOODARD ATTORNEYS AT LAW sutTE als (N,IPP4f GE SU4LDfMG TULSA, OKLAHOMA 74103

, ELE,MONE 543.,13s AREA CODE SIS AAYMONO G. ,tLDM AN WILLI AN $. H&G W. E. GREEN JEARY ARED "

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'[*'7 W. LO,','" July 16, 1979 /j (W 2 h73 7 ~Q

# g Mr. L. Dow Dav2.s b Y% $

Counsel for NRC Staff gf Nuclear Regulatory Commission N Washington, D. C. 20555 In re: QA Compliance - Black & Veatch (B&V)

Black Fox Construction Permit Docket Nos. STN 50-556 STN 50-557

Dear Dow:

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Enclosed please find a copy of two letters concerning Black & Veatch's QA Program which we obtained from the NRC's Public Document Room in Washington, D. C. You will note that the NRC's April 30, 1979, letter to Black & Veatch identifies 32 potential deficiencies in the Black & Veatch Program.

It would appear that the NRC's concerns and findings in this area support our QA contention and Board Questions 10-1 through 10-4. Could it be that a closer look at the QA Program by the Staff has resulted in a change in its position on scme of these issues? In addition, what effect do these deficiencies identified in the Black & Veatch Quality Assur-ance Program have on the Black & Veatch design work, equipment ordered, etc. which has already taken place?

Shouldn't we have received this correspondence by normal service on all parties to the Black Fox proceedings?

Your earliest comments in response to these questic would be appreciated.

Very truly yours, A.

Joseph R. Farris 1013 057 For the Firm JRF:fj Encls.

cc: Black Fox Mailing List (Attached) 7909260 9 7 )

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DISTRIBUTION: #

APR 2 71979 Central File N'A.C- Ol QAB Projects

. QAB Chron. File

. NRR Reading File

.. . DJSkovholt, OPM JSpraul,' QAB

.JGilray,,QAB

! MEMORNIDUM FOR: Halter P. llaass, Chief, Quality Assurance Branch, l Division of Project Management FROM: Jack.Spraul, Quality Assurance Branch, Division of Project Management

SUBJECT:

SUfMARY OF MEETING WITH BLACK & VEATCH i

On Wednesday afternoon, April 25, 1979, HRC QA Branch personnel met with i personnel from Black & Veatch Consulting Engineers, Kansas City, Missouri.

The meeting was held in Room P320-D, and a list of attendees is attached.

i The purpose of the meeting was to discuss staff questions generated during the review of the Black & Veatch topical report number BVTR-1-0, " Quality Assurance Program Description." There appeared to be a mutual understanding of our concerns when the meeting ended.

The questions are being formally' transmitted to Black & Veatch for response.

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@ N^ AttOment 6 to NRC Letter to s

Utilities " Fire Protection '

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.. a:Qm Functional Responsibilities" I

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N- OUALITY ASSURANCE

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The quality assurance (QA) program should assure that the requirements for design, procurement, installation, testing, and administrative controls for the fire ~ protection program for safety related areas accreved by NRC are satisfied. The Quality Assurance provisions for fire protection should apply to activities performed after the effective '

date of the adoption of said provisions: The QA program should be under the management control of the QA organization.. This control consists of (1) formulating and/or verifying th.at the fire protection QA program incorporates suitable requirements and is acceptable to the management responsible for fire protection and (2) verifying the ef fectiveness of the QA program for fire protaction through review, surveillance, and audits. Performance of other QA program functions for meeting. the fire protection program requirements may be perforced by personnel outsidc of the QA organization. The QA program for fire protection should be. : art of the overs 11 plant QA program. These QA critaria a: ly to those items within t'ha scoce of *.he fire protection program, such as fire protection systans, emergencyblighting, communication and emergency breathing acparatus as well as the fire protection requirements of applicable -

safety related equi;: ment.

Applicants / licensees can meet the fire protection quality assurance (QA) ,

program criteria of Appendix A to BTP 9.5-1 or Regula tory Guide 1.120 by ei ther: .

1) imolementing those fire protection QA criteria as part of their -QA program under 10 CFR Part 50 Appendix 3, where such a cemitment

,is made, it is not necessary to submit a detailed description of the .q fire protection QA program or its implementation for NRC review; or '

2) providing for NRC review a description of the fire protection OA R M program and the measures for implementing the program. Supplemental guidance is provided below on acceptable measures for implementing b 3i i each of the fire protection ~QA program criteria of Appendix A :

STP 9.5-1 or Regula tory Guide 1.120. O LG*

l.0 Design Control and Procurement Document Control - Measures should

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be established to assure that the applicable guidelines of the y Regulatory Guide 1.120 or approved NRC' alternatives are included in design and procurement documents and that deviations therefrem are cen trol led. These measures should assure that:

a. Design and procurement document changes , including field chances and design daviations are subject to the same level of reviews , and approvals that were applicable to the crip t3'IS a'l document.

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b. Quality standards are specified in. the design documents such as appropriate fire. protection codes and standards, and deviations and changes from these quality standards are controlled.

c. New designs and plant modifica~tions, including fire protection systems, are reviewed by qualified personnel to assure. inclusion of appropriate fire protection requirements. These reviews should include items such as:

(1) Design reviews to verify adequacy of wiring isolation and cable separation criteria.

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(2) Design reviews to verify appropriate requirements for room isolation (sealing penetrations, floors, and other fire -

barriers).

d. A review and concurrence of the adequacy of fire protection requirements and quality requirements stated in procurement documents are performed and documented by qualified personnel.

This review should deternine that fire protection requirements and quality requirements are correctly stated, inspectable anc controllable; there are adequate acceptance and rejection ,

criteria; and the procurement document has been, prepared , re-viewed, and approved in accordance with QA program requirements.

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2.0 Ins tructions , Procedures , and Drawing - Inspections , tes ts , admin-istrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instruccions, procedures or drawings and should be accomplished in accordance wi th these documents. The follcwing provisions should be included. d

a. Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with documented Q b procedures. cm

b. Activities such as design, instillation, inspection, tes t, b maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with documented in-structions , precedures , and drawings.

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c. Instructions and precedures for design installation, inspec-tien, test, maintenance, modification and administrative controls are reviewed to assure that proper inclusion of fire protection requirements, such as precautions, control of ignition sources and ctmbustibles, provisions for backup fire protection of tha activity requires disabling a fire pr-atection ;ystem, and re-striction on material substitution unless specifically pennitted by design and confimed by design review. - .,

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d. The installation or application of penetration seals and'~ fire '

. retardant coatings is performed by trained personnel using

• approved procedures.

3.0 Control of Purchased Material, Equipment, and Services - Measuies s hall be estat ~ ished to assure that purchased material, equipment and services conform to the procurement documents. These measures should include:

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a. Provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor, inspections at suppliers, or receiving inspections.

b. Source or receiving inspection, as a minimum, for those items whose quality cannot be verified af ter installation.

4.0 Inspection - A program for independent intpection of activities affecting fire protection should be established and executed by, or for, the organization performing the activity to verify conformance ,

to cocumented installation drawings and test procedures for acc ::alishing activities. This program should include:

. Inspections of (1) installation, maintenance and modification of '

fire protection systems; anc (2) emergency lighting and communica-tion equicment to assure conformance to design and installation requirements. ,

b. Inscection of penetration seals and' fire retardant coating q installations to verify the activity is satisfactorily completed.

c. Inspections of cable routing to verify conformance with design %

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d. Inspeciions to verify that accropriate requirements for room ,

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- isolation (sealing penetrations, floors, and other fire barriers are accomplished during construction.

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e. Measures to assure that inspection personnel are independent from M

the individuals performing the activity being inspected and are b 9 knowledgeable in the design and installation requirements for fire protection. . .

f,. Inspection procedures, instructions, and check lists which provide for the following:

(1) Identification of characteristics and activities to be inspected (2) Identification of the individuals or grou::s responsible for ,

performing the inspection operation <-

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(3) Acceptance and rejection criteria 013 061

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(4) A description of the metho,d of inspection (5) Recording evidence of completing and verifying a manu-

. facturing, inspection or test operation (6) Recording inspector or data recorder and the results of the inspection operation

g. Periodic inspections of fire protection rystems, emergency breathing and auxiliary equipment, emergency lighting, and communication equip-ment to assure tha acceptable condition of these items. i

h. Periodic inspection of catarials subject to degradation such as fire steos, seals, and fire retardant.ccatings to assure these items have not detariorated or been damaged.

5.0 Test and Test Control - A test program should be established and implemented to ensure that testing is performed and verified by inspectic.i and audit to demonstrate conformance with design and system readiness requirements. 'The tests should be performed in .

acc:rdance with written test procedures; test results should be pr :erly evaluated and acted on. The test program should include the ,f oll: wing: ,

a. Installation Test.ing - Follcwing construction, modificition,' repair or replacement, sufficient testing is performed to demonstrate that fire protection systams, emergency lighting and communication equip- .

ment will perform satisfactorily in sarvice and that design criteria are met. Written test procedures for installation tests incorporate LJ n

the requirements and acceptance limits c:ntained in applicable design documents.

b.' Periodic testing - The schedules and equi; methods for periedic c~~3 testing {y are developed and documentad. Fire protection cent, emergen lighting, and c:mmunication equipment are tested periodically to g 1 assure that the equipment will orcoerly function and c:ntinue to b meet the design cri . aria. 4LJ@3

c. Pr0 grams are established for QA/QC to verify testing of fire pro *ection systems and to varify that test personnel are effectively trained.

d. Test results are documented, evaluated, and their accaptability determir.ed by a qualified responsible individual or group.

5.0 Inscection, Test, and Operating Status - Measures should be established to provide for the identification of items that have satisfactorily passed required tests and inspect;ons. ihese =easures should include previsions for: ,.

a. Identification by means of tags, labels, or similar temporary' markings to indicate c:mslation of required inspecticns and '

\ tests, and operating status. I

( r 5 7.0 Nonconforming Items - Measures should be established to control items that do not conform to specified requirements to preverit inadvertent use of installation. These measures should include provisions to

             , assure that:

a. Henconforming, inocerative, or malfunctioning fire protection systems, emergency lighting, and ccmmunication equipment are apprceriately tagged or labelled.

b. The identification, documentation, segregation, review dis-position, and notification to the affectad organization of nonconforming materials, parts, c:mponents, or services are procedurally controlled,

c. Occumentation identifies the nonc:nformir.g item, describes the nonc:nfermance and the disposition of the nonc:nferming item and includes signature appr: val of tha disposition.

d. Provisiens are established identifying those individuals or groups dalegated the responsi'cility and authority for the ,

disposition and aporoval of nonc=nforming items. 8.0 Corrective Action-Measuresshallbeestablishedtee'nsurethatchr-ditions adverse to fire protection such as failures, malfunctions, deficiencies, devia'tions, defective c:mponents, uncontrolied c:mous-tible ' material and nonconformances are promptly identified, reported and correctad. These measures should assure: . 9

a. Procadures are established for evalu tion of conditions adver to fire protection (such as nonc=nformanca, f ailures, mal-g, N-functions, deficiencies, deviations, and defective matarial ,

and equipment) to detarmine the nacessary corrective a

b. In the case of significant or repetitive conditions adverse 4 L-.J to fire protection, including fire incidents, the cause of the canditions is determined and analyzed, and prcmot c rrective Q

actions are takan to preclude recurrence. The cause of the 8 c:ndi tion and the corrective action taken are prem:tly reported to cogni: ant levels of canagement for review and assessment. 9.0'Rocords - Records should be prepared and maintained to furnish evidence that the criteria enumerated above are being met for a:tivities affecting the fire protaction program. The following provisions shculd be included:

a. Recorcs are idantifiable and retrievable and should Nhonstrate ,

c:nformance to fire protection requirements. The records should 1013 063

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BLACK & VEATCH O

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Request for Additional Information b

1. The " Explanation of ' Quality Assurance'" on page 2.1 is unacceptable.

To limit the definition of quality assurance in the program description to "the separate quality verification effort by Quality Assurance Group personnel..." is inconsistent with the 10 CFR Part 50 Appendix B definition . (not fully reflected in the Black & Veatch definition on page 2-1) that quality assurance " comprises all those planned and systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service." A quality assurance program, as noted on page 2.1, is not an alternative to good technical work nor does it relieve line management of any responsibility. It - includes, it is based upon, good technical work and good line management. Tnat is, good technical work under good line management is a prerequisite of a good quality assurance program. Therefore, either delete the

                " Explanation of ' Quality Assurance'" or revise it to agree with the 10 CFR Part 50 Appendix 8 definition of quality assurance.

2. Part 2.4 of the topical report describe [ the relationship between the topical report, the Quality Assurance Program-Nuclear, and the B&V Project Instruction Manual, and Part 6.2 states that specific reviews .

are performed to assure that appropriate quality requirerents are included in these documents. Describe the Quality Assurance Manager's role in the review of the B&V Project Instruction Manual (s) and other - listed documents to assure consistency with the topical report. When only " selected" documents are reviewed as noted in tha last sentence of Part 6.2, indicate who performs the selection and on what basis.

3. Part 2.2 of the topical report states that Table 2.1 defines the q applicability of QA related regulatory guides to B&V. Please include '

Regulatory Guides 1.26 and 1.29 in Table 2.1. Please update the Regulatory Guide 1.88 commitment to Revision 2 dated October 1976 d and 1.94 to Revision 1, April 1976. The Black & Veatch Positions Q given in Table 2.1 are acceptable except as noted below. 8i r

a. Regulatory Guide 1.28, Position 5: Explain the sigr.ificance of b 3 "as necessary." b,

b. Regulatory Guide 1.29, Position 6: It is the staff position y) that deficient areas must be corrected and correction must be independently verified. Please revise the Black & Veatch Position to meet this staff position or provide some alternative for our eval ua tion.

c. Regulatory Guide 1.37, Position 1: Please add a corrinitment that adequfte controls will be applied to preclude harmful effects of the removal process.

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d. Regulatory Guide 1.38, Position 1: Please add a corraitment that the protection level selected will not be less restrictive than .

noted in Article 2.7.

e. Regulatory Guide 1.38, Position 4: In order to minimize potential  !

damage during shipment, the staff position is that Section 4.3.4 should be followed. The stated Black & Veatch Position is unacceptable. , Please delete or revise. .

f. Regulatory Gu.ide 1.38, Position 5: It appears the reference rhould be to Appendix Section A3.4.1, (4) and (5). -

g. Regulatory Guide 1.38, Position 6: It is not clear whether or not the Black & Veatch Position relative to heat exchangers or tanks containing carbon steel meets the requirement of the last sentence of A.3.4.2(3) . Please clarify.

h. Regulatory Guide 1.38, Position 7: Please provide justification for this position for our evaluation or delete it.

i. Regulatory Guide 1.64, Position 2: Please indicate what specific ~

requirements and reccmmandations of Section 11 will not be met (if any) and provide specific alternatives for our evaluation.

j. Regulatory Guide 1.94: Please provide justification for this position for our evaluation or delete it.

k. Regulatory Guide 1.123: Please provide justification for this position for our evaluation or delete it.

i 9 The last ANSI Standard listed in Table 2-1 is N45.2.12-1977. This is acceptable only"For Guide 1.144 issued as Comment" clarified in byJanuary the regulatory positien 1979. Othenvise, weof Regulatory b requi p a commitment to Revision 3, Draft 4, dated February 1974 which is g g'- ' included in Revision 1 of WASH-1283 (" Gray Book"). Please revise Table 2-1 accordingly. Uh Finally, reference to speciNc ANSI standards in the text of the topicab report (ree pages 15-1,17-1, and 18-1) should be to the referencing - Regulatory Guide listed in Table 2.1, and the words "the applicable provisions of" should be deleted or explained. U

4. Part 1.4 of the topical report indicates the QA Group reviews quality assurance manuals. Clarify whether these are S&V manuals, vendor manuals, or both.

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5. Describe measures which assure that verified computer codes are certified for use and only certified codes are used. Also, provide a commitment that the development, control, and use of computer codes will be done in accordance with the QA program and describe how the QA program will be applied.

6. Part 2.3 of the topical report indicates the QA program is applicable to items so identified in " project essential items listed." Please provide a commitment that the project essential items lists will show Appendix B applied to each item so identified in applicant's Safety Analysis Reports. Aiso identify personnel autherized to approve changes, to these lists and describe methods cor. trolling its distribution. Also, note that the lists will incluG related consumables in addition to the structures, systems, and components that come under the Appendix B QA program.

7. The project essential items lists should identify fire protection as a system covered by the QA program (with such a commitment in the topical report) or the topical report should identify the QA controls for fire protectior.. (

Reference:

Attachment 6 to NRC letter to utilities " Fire Protection Functional Responsibilities," August 29, 1977 Lattached_J)

8. Provide a corciitment in the topical report to comply with 10 CFR Part 50.55a. Also, for items covered by Section III of the ASME Code (Classes 1, 2, & 3) provide a commitment that the Code quality -

assurance requirements will be supplemented by the specific guidance addressed in the regulatory positions of the applicable Regulatory Guides. 9.

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Provide a summary description on how responsibilities and centrol of quality-related activities are transferred from Black & Veatch I to the plant owner during phasecut of Black & Veatch design and Q procurement activities. b

10. Indoctrination and training of personnel is discussed in part 2.6, 6==0 &

page 2-4, of the topical report. Clarify that the indoctrination and training program is such that: bwg-

a. Personnel responsible for performing quality-affecting O activities are instructed as to the purpose, scope, and implementation of the quality-related manuals, instructions, and procedures.

b. Personnel verifying activities affecting quality are trained in the principles, techniques, and requirements of the activity being performed.

c. For formal training programs, documentation includes the objective, content of the program, attendees, and date of attendance.

d. Proficiency of personnel performing and verifying activities affecting quality is maintained by retraining, reexamining, 1013 0 and/or recertifying as determined by management or program commitment.

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11. Briefly describe the activities associated with the preparation and l ical review of Indicate report. design documents mentioned the organizational in part 3.1 of for responsibilities theptop'reparing, i reviewing, approving, and verifying design documents such as system i descriptions, design input and criteria, design drawings, design  !

analyses, ccmputer programs, specifications, and procedures. [

12. Describe measures which assure that deviations from specified quality standards are identified and procedures are established to ensure i their control .

13. In part 3.6, briefly describe the internal and external design inter- '

face controls, procedures, and lines of communication among participating design organizations and across technical disciplines for the review, approval, release, distribution, and revision of documents involving design interfaces.

14. Describe measures which assure that design verification by design '

review and/or alternative calculations is completed prior to release for procurement, manufacturing, construction or to another organiza-tion for use in other design activities. Note that when this timing cannot be met, the design verification may be deferred providing that the justification for this action is documented and the unverified portion of the design output document and other design output documents based on the unverified data are appropriately identified and controlled. .

15. Briefly describe controls for design documents that reflect the ccm-mitments of the SAR. The controls should differentiate between docu-ments that receive formal design verification by interdisciplinary or multi-organizational teams and those which can be reviewed by a single individual. Design documents subject to procedural control should include specifications, calculations, computer programs, system descriotions, SAR when used as a design document, and drawings such as

          , flow diagrams, piping and instrument diagrams, control logic diagrams, electrical single line diagrams, structural systems for major facilities,       ~

site arrangements, and equipment locations. Clarify whether specialized reviews are used when uniqueness or special design considerations warrant.

16. Clarify whether procedures identify the reponsibilities of the design verifier, the areas and features to be verified, the pertinent considera-tions to be verified, and the documentation required.

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17. When design verification requires testing, describe how Black & Veatch ,

assures that testing is perforr.ied as early as possible.  !

18. Clarify whether the procedures mentioned in part 4.1 of the topical report require applicable inspection and test requirements as well as special process instructions in procurement documents.

19. Please expand the list on page 6-2 to include:

a. Design documents (e.g., calculations, drawings, specifications, l analyses) including documents related to computer codes.

b. Procurement documents.

c. "As-built" documents.

d. Topical reports.

e. Nonconformance reports.

or indicate why these documents should be omitted. Also show who (or what organization) reviews and concurs with the QA-related aspects of the documents listed on page 6-2. If other than QA, describe the qualification requirements.

20. Describe measures which assure that procurement documents prepared by Black & Veatch reouire the supplier to furnish the following records to the purchaser:

a. Documentation that identifies the purchased item and the specific procurement requirements (e.g. , codes , standards, and specifications) met by the item. ,

b. Documentation identifying any procurement requirements that have not been met.

c. A description of those nonconformances from the procurement

            .           requirements dispositioned " accept as is" or " repair."           ,

21 . Describe the Black & Veatch organizational responsibilities and inter-faces between desian, procurement, and QA for procurement document prepar: tion, selection of suggested bidders, and review of information submitted by contractors.

22. Describe the criteria for determining processes that are contrclied as special process and provide a more comprehensive list of processes that will be treated as special processes.

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23. Describe measures which Black & Veatch uses during its review of .

suppliers' special process procedures to assure: l

a. Special processes are appropriately identified and controlled.

d. Organizational responsibilities are described for qualifi-cation of special processes, equiament, and personnel.  !

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c. Procedures, equipment, and personnel associated with I special processes are qualified and are i'n conformance j with applicable codes, standards, QA procedures, and i specifica tions .

d. Procedures are established for recording evidence of acceptable accomplishment of special processes using qualified procedures, equipment, and personnel .

e. Qualification records of procedures, equipment, and personnel associated with special processes are established, filed, an,d kept current.

24. Identify the in dividuals or groups with authority to evaluate ana recommend disposition of Procurement Deviation Requests. ,

25. Briefly describe the procedures used to disposition "nonconformances which do not affect original design." .

26. Discuss Black & Veatch involvement in and corrective action taken as the result of construction difficulties and field failures of Black & Veatch designed items.

27. . Describe the involvement of Black & Veatch management in the corrective action system. -

28. Section 17 of the topical report should be expanded to address the following:

a. Describe Bl.'ck & Veatch organizational responsibilities for activities related to records.

b. Describe record storage facilities.

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(, t) l i l 29 Describe measures which assure that an audit plan is prepared which identifies audits to be performed, audit frequencies, and audit i schedules, assuring effective QA throughout the activities important to safety.

30. The list of audit areas on page 18-1 appears to be too limiting. So, too, is the sentence that says, "The procedures or .crecklists will identify the records and design activities to be evaluated."

(Emphasis added.) Provide a commitment that audits will be performed in all areas where 10 CFR Part 50 Appendix B is applicable and revise g the list and sentence accordingly.  ;

31. Describe measures wnich assure that audits are conducted by trained personnel having no direct responsibility in the area being audited.

32. Provide a description that emphasizes how the docketed QA program description, particularly the Regulatory Guides and ANSI standards listed in Table 2-1, will be properly carried out.

Editorial Comments:

p. 3-2: delete "only"

p. 6-1: change "are" to "is"

p. 8-1: change " provide" to " require" .

p. 8-1: change "or" to "and" -

p. 13-1: delete "as guidance" Note: Black & Veatch position On Sections 3.7.1(1) and 3.7.2 of ANSI N45.2.2-1977 (Topical page 2-9) is under review.

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