ML19209A642
| ML19209A642 | |
| Person / Time | |
|---|---|
| Site: | Black Fox |
| Issue date: | 07/02/1979 |
| From: | Blaisdell R BLACK & VEATCH |
| To: | Haass W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19209A637 | List: |
| References | |
| 25.9000.21, NUDOCS 7910050096 | |
| Download: ML19209A642 (36) | |
Text
PUBLlC bucyq, s
VEATC[QB ce#i cc BLACK p
TEL. (9136 967 20C0 TELEX 42 6263 CONSULTING ENGINEERS f///
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KANSAS CITY. WS50Um 64H4 3
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Black & Veatch g
B&V Project 0001 x
Quality Assurance N
,A QA File 25.9000.21 Topical Report BVTR-1-0
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July 2, 1979
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United States Nuclear Regulatory Co==ission 1720 Norfolt Avenue 3ethesda, '.aryland 20014 Attention: Mr.
- w'. P. Haass, Chief Quality Assurance Branch Division of Project Manage =ent Gentlemen:
The purpose of this letter is to transmit four copies (4) of the revised topical report on Quality Assurance (SVTR-1-0).
Also, attached to this letter are respenses to the 33 requests for clarification transmitted by NRC letter of April 30, 1979.
The attached revised pages of the topical report have been annotated with a bar nark on the right hani margin where changes have been incorporated.
For the convenience of reproduction, all pages of the topical report have been included in this transmittal.
A specific list of those pages that have been changed is included.
The dates on all pages have been changed for the ccnvenience of Black & Veatch record purposes.
It is Black &
Veatch's intent af.er approval cf the topical report that the right hand
=arzin b
= arks and questions numbers would be removed; and the appropriate
- aistrative coatrol of Epplying the suffix A to the reuort number and the page designators would be accomplished.
For the corvenience of response to the request for clarification all questions have been retyped on a single page. The response to each query is included on the single page.
These page numbers are identified as Q-1, Q-2, etc. in he enclosed caterial.
If you have any questions concerning this submittal, please contact R. E.
Blaisdell at your earliest convenience.
Very truly yours, BLACK & VEATCH 1084 008 R. E. Blaisdell sr
Enclosures:
Responses to requests for clarification (4)
Modified topical report (4) 79/0060096
eLACK a VEATCH
,,--mlanatgon c:. 'Ouality Assurtnce'" en page 2.1 is unacceptable.
3
-.ne c linit the cerini:'.cn of quality assurance in the program descriptica
-c ne scrarate quali:y verification effort by Cuali:
Assurance Group V
cersennel...
is i,consisten: with the 10 CFR Par: 50 hppendix 3 ce: nitic (nct :ully reflected in the Black & Vea:ch definition en FaIe
-1) that quality assurance "cceprises all those planned and systematic actions necessary to provide adecuate confidence that a structure, sys en, or component will perfern satisfactorily in Service.
A quaity assurance progran, as noted en c.are 2.1, 4 s..c -
=rnat,ve to scoc technical work nor does i: relieve line canacemen:
i 3 *n 7, responsibility.
1; includes, it is based upen, good technical
~- j.
,,c A ano good line management.
That is, good technical work under good ine management is a prerequisite of a good quality assurance I
{rogram.
Therefore, either delete the " Explanation of Ouality Assurance'"
-='.se.
o agree witn the 10 CFR Par 50 Appendix 3 eefinition
-- cu}alityassurance.
- escense:
[hedefiniticnofqualityassuranceasprevio included in pararra'h
_.-..as seen deie:ec.
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1084 009
SLACK & VEArCH 2.
Part 2.4 of the topical report describes the relationship between *he topica report, the Quality Assurance Prograt-Nuclea-and *h specd.'? e B5V r roj ect Instruction Manual, and Part 6.2 states that
.c.eviews arep]e"*o~';.ed*oassure:5.at appropriate quality requircrents are
... hese documents.
Describe the 0'ua14 v. esurance.!anage",s s
~
" ele 4.n ne review of tne B&V Proj ect Ins tructicn' Manual (s ) and other oct. ents o assure consistency with' 'he ' ed --'" ' " '
.n
- EC wne c,.l'
,'selec:e'" documen:s are reviewed as no:ed 1" "'ne 'cs sentence o* Pa*
6.',
<.ndicate who perfor s the selection and On what basis.
?esconse:
The last sentence of paragraph 6.2 has been modified - pr vi'e specific co==1 =ents f or *"h. e doct~en,es tnat require exaninatien bv the p,.oject Qua,ity Control Engineer (s) to assure censistench v -5 e d
14-.
^
assurance program recuirements and quali:V rrovisions
- d d ' 4
~ ^'^
^
~
.. ave been incorporated in the revised text.'
I.l.
l[M}MO uV!Ab Q-2 1084 010
SLACK & VEATCH 3.
Part 2.2 of the topical report states that Table 2.1 defines the 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.SS connitment to Revision 2 dated October 1976 and 1.94 to Revision 1, April 1976.
The Black & Vea:ch Positions given in Table 2.1 are acceptable except as noted below.
a.
Regulatory Guide 1.25, Posi: ion 5:
Explain the significance of "as necessary."
5.
Regulatory Guide 1.29, Position 6:
It is the staff position that deficient areas must be corrected and correction must be independently verified.
Please revise the Black & Vea:ch Position to meet this staff position or provide some alternative for our evaluation.
c.
Regulatory Guiae 1.37, Position 1: Please add a cc mitment that adequate controls will be applied to preclude harmful ef fects of the re= oval process.
d.
Regulatory Guide 1.38, Positica 1: Please add a centi =ent that the protec:1cn level selected will no: Le less restrictive than noted in Article 2.7.
e.
Regulatory Guide 1.35, Postion 4:
In order to minimize pcten:ial damage during shipment, the staff pcsition is that Section 4.3.4 should be followed.
The stated Black & Veatch Position is unacceptable Please delete er revise, f.
Regulatory Guide 1.35, Posi:1cn 5:
It appears the reference should be to Appendix Section A3. 4.1 (4) and (5).
g.
Regulatery Guide 1.38, Position 6:
I: is not clear whether er noi the Black & Vea:ch Position relative to heat exchanges or tanks containing carbon steel meets the requirement of the last s2n:ence of A.3.4.2(3).
Please clarify.
h.
Regulatory Guide 1. 38, Posi: ion 7 -
Please provide justification for this position fer our evaluation or delete it.
1.
Regulatory Guide 1.64, Position 2:
Please indicate what specific requirement and reccamendations of Section 11 will not be met (if any) anc provide specific alternatives for our evaluation.
j.
Regulatory Guida 1.94: Please provide justification for this position for our evaluation er delete it.
k.
Regulatory Guide 1.123: Please provide justification for this position for our evaluation or delete it.
Q-3 1084 011
8 LACK & VEATCH The las: ANSI Standard listed in Table 2-1 is N45.2.12-1977.
This is acceptable only as clarified by the regulatory position of Regula: cry Guide 1.144 issued "For Comment" in January 1979.
Otherwise, we require a cccci::ent to Revision 3, Draft 4, dated February 1974 which is included in Revisien 1 of WASH-1238
(" Gray Sock").
Please revise Table 2-1 accordingly.
Finally reference to specific ANSI standards in the text of the :cpical reper: (see pages 15-1, 17-1, and 18-1) should be to the referencing Regula:ory Guide listed in Table 2.1, and the words "the applicable previsicas of' id be deleted er explained.
Resconse:
Regulatory Gride 1.26 and 1.29 have been added to Table 2-1.
The positions to be adopted by Black & Vea:ch have been incorporated.
Tpdates have been defined for Regulatory c ide 1.S8 and 1.91 u
The reasen for including the statement "as necessary" in Ite: 3A is
- c take clear tha: aucits are to be performed in a timely canner based uper the work being performed.
With the understanding tha: the Nuclear Regulatory Cornission always has in urpreted tha: the requirements are to be applied in a timely canner in associatien with the activities, the clarifying statement ic ne lenger needed.
Therefore, positien No. 5 fer Regulatory Guide 1.28 has been deleted.
?csi:ica No.
en Regulatory Guide 1.2S was incluced c allow for provisions fer grality assurance personnel to nake reccamendaticns to canagement for sl:ernative methods of accc plishing an activity The clarification was not attended to imply that deficiencies were net to be corrected.
Because this position was not needed, the ite: has been deleted fr the Tepical Report.
The con =ents on Ite: 3C of Regulatory Guide 1.37 requested that Elack &
Vea:ch add a ec==1:=ent tha: there would be no harmful effect based en the cleaning processes.
This ce mitment has been added to Table 2-1.
I:ers 3D-H are in relationship to Regula:ory Guide 1. 35.
This Regulatory Guide relates to ANSI standard N45.2.2 concerning the quality assurance requirements for packaging, shipping, receiving, s:crage, and handling.
The Nuclear Regulatory Co==ission indicated in :neir correspondence that additional evaluation was being done on the Black & Veatch positions cencerning this regulatory guide.
Since this information has not been received, no change has been made to a Topical Report concerning the positions on Regulatory Guide 1.38.
Therefore, responses to items 3D-3H will be supplied later.
Ite: 3I concerns the auditing aspect. in relationship to Regulatory Guide 1.64.
Previous positio.. No. 2 Table 2-1 has been deleted.
Ite= 3J concerning Regulatory Guide 1.94 has revised wording contained in Table 2-1.
Q-3.1 1U 4
012 8
a'ACK a v E Aff C H 1
Far: 1.4 of the tcpical report indicata.. the QA Group reviews cuality assurance manuals.
Clarify whether these are Siv canuals, vendor nanuals, or both.
Easrense:
The requirements defined in paragraph 1.2.2 (2) specifically charge the Black & Vea:ch Quality Assurance Manager wi:h responsibility fer.he development, revisien, and review of the Quality Assurance Progrc= for Black & Vea:ch.
It is the specific responsibility of the Quality Assurance Manager or persens assigned to him to provide to the Head of the Power Division for his approval the quality assurance program docurents contained within the Black & Veatch Quality Assurance
?regra - Nuclear.
ine requirenents for obtaining specialized technical censulting services in the Quality Assurance Program review f or these censultants is centained in pa: agraph 7.2 of the Tc7 cal Eeport.
The 4
uali y assurance activities associated with the support of detailed technical services to Elack & Veatch, when such is required, are a::stined by :he Black & Vaa:ch Quality Assurance group.
As included in the introduction to the Topical Report, contrac:cr evaluatica and selection is a specific ite that nust be included under an an lica:icn cr :his Topical Repert. As indica:ed in parat :ph 7.1. f specific applica:icns concerning the evaluation, review and st lecticn ci sources of supply including the review of their Ouality Assurance
- anual cust be par: of :he specific applicatier that veuld adop: this reper: in conjuncticn with the Owner (applicant) program.
The general descriptien of the functicns and responsibilities of the l' ack & Vestch Quality Assurance group contained in paragraph 1.4 has nc: been modified.
Under a specific applica icn the functicn of evaluating renders or contracters Quality Assurance Frograms uculd be assigned to personnel withir the quality assurance group and the descriptien centained in paragra.k 1. - would apply.
1084 013 Q-4
9 LACK & VEATCH 3.
Describe measures which assure that verified computer codes are certified fer use and only certified codes are used.
Also, provide a ec==itnent that the development, con:rol, and use of computer codes will be done in accordance with the QA prograr and describe hev the QA frogra= will be applied.
Kasconst:
Table 2-3 describes the standard procedures contained within the Quality Assurance Prograr - Nuclear.
Standard Procedure 3.S Compu:er Progra: Verification, describes the methods utilized by Black & Vearch for computer program verification.
Unverificd programs or programs under levelopment are specifically " flagged" such that the resultant calculatiens will not be utilized for plant design.
The Administrative centrols defined in 5:anda.! Procedure 3.8 have beer effectivelv incler.nted b:- 3&V for control of the ec=puter codes, revisions :o codes an'd versiens cf codes.
Modifica:icns nave been made to the rey: cf the Tecical Report.
Q-3 1084 014
SLACK & VEATCH 6.
Part 2.3 of the topical report indicates the QA program is applicable to iters so identified in "proj ect essential items listed." Flease provide a co==itment that the proj ect essential iters lists will show Appendix 3 applied to each ite so identified in applicant's Safety Analaysis Reports.
Also identify persom'el authorized to at.oreve chances to these lists and describe methods centrollin~ its s
distributicn.
Also, note that the lists vill include related censumables in addition to the structures, systers, and compenents that come under the Appendix 3 QA prograr.
Rescense:
Paragraph 2.3 of the Topical Report has been codified to include a ec= ittent that the Project Essentials Items List shall include as a mini =un all items included in the Owner's Safety Analysis reports.
31ack & Vea:ch does not purchase or use censumables associated with systen structures and cc penents.
Appropriate provisions in procurement documents prepared by 3'.acx & 'Jeatch require these who are manufac:uring or assembling the cc=penents to have Qualit Assurance Programs that comply with the applicable per: ions c-10CFR50 Appendix 3 and supple =entar: recuirements defined by the cc i: ents in this Icp. cal Repor:.
084 015 Q-6
BLACK & VEATuH 7.
The project essential iters lists should identify fire protection as a system covered by the QA progra= (with such a commitment in the topical report) or the topical report should identify the QA centrols fr-fire protection.
(
Reference:
Attachment 6 to NRC letter to utilities
" Fire Protection Functional Responsibilities," August 29, 1977 [ attached])
Resocese:
~ ble 2-5 has been added to :he Topical Report thoring :he Standard Pro-a cedures from the 3&V Quality Assurance Program - Suelear that will be applied to "special" plant systems.
Q-7 1084 016
SLACK & VEATCH S.
Provide a ec =itrent in the cpical reper: to ec: ply with 10 CFR Part 50.35a.
Also, f or items covered by Section III of the AS:E Code (Classes 1, 2, & 3) provide a ccarittent that the Cece quality assurance requirements will be supplemented by the specific guidance addressed in the regula: cry positions of the applicable Regulatory Guides.
Rescense:
Faragraph
'.1 of the Tepical Repert has been e. edified :c include a requirement that the pertinent procurement specifications will cc= ply with the requirements of 10 CFR 50 Part 50.55a.
Also, the requirements of the Regulatory Guides applicable to design, shipping, handling, s:crage, records, erc. will be added to the precurement specifications.
Q-8 1084 017
BLACK &
EATCH 9
Provide a summary description en how responsibilities and control of quality-related activities are transferred frca Black & Veatch to the plant owner during phasecut of Black i Veatch design and procurecent activitie.
Rescense:
A description has been included in the pa-graph 3.6 of the Tcpical Report showing that the plant Owner receives the quality assurance records for utilitation in future censiderations.
This transfer of information to Owner of design documents, drawings and calculations are made as Black & Veatch efforts phase out.
Q-9 1084 018
BwACK & VEATCH 10.
Indoctrination and training of personnel is discussed in part 2.e, page 2-4 o' the topical report.
Clarify that the indoctrination and training program is such : Sat; Persennel responsible for performing quality-affecting a.
activities are instructed as c the purpose, secpe, and implementation of the quality-related manuals, ins: ructions, and procedures, b.
Persent.el verifying activities affecting quality are trained in the principles, techniques, and require:ents cf the activity being performed.
c.
For formal : raining programs, documentation includes the objective, content of the program, attendees, and date of attendance.
d.
Proficiency of persennel performing and verifying activi:ies affecting quality is maintained by retraining, reexaning, and/or recertifying as determined by management er prograr concittent.
Rescense:
The description above of the ninimum requirements for providing indoc-trina:icn and training are the points involved in 31ack & Vea:ch Standard Precedure 2.2.
Q-10 1084 019
9 LACK & VEATCH 11.
Sriefly describe the activities associated with the prepar.ation and review of design docu=ents centioned in part 3.1.i the :opical report.
Indica.e the organizational responsibilitics for preparing, reviewing, approving, and verifying design docunents such as syste descriptions, design input and criteria, design drawings, design analysis, corpu:er pregrams, specifications, and procedures.
Kesconse:
Each of the standard procedures included in Table 2-3 is for a specific activity.
For example, Standard Procedure 3.1 governs the requirenent for the prepara:1cn of syste= analysis reperts; Standard Procedure 3.2 covers the preparation of Project Design Manual., etc.
Each of these standard precedures includes a specific responsibility for the implementatien of :be precedure and specific defined responsibilities for preparing, check, reviewing, approving, and verifying documents.
Q-11 1U84 020
8 LACK & VEATCH 12.
Oescribe measures which 4sure that deviatiens frcr specified quality standards are identified and procedures are established to ensure their control.
Reseense:
Included in Table 2-3 is a descriptien cf Standard Procedure 16.2.
This procedure is for the handling of nonconforming items
- -ithin Black & Vea:ch.
This procedure authorizes all employees of Slack 5 Vea:ch to prepare and submit nonconferring iter reports for any deviations, problers, or any other matter concerning the quality cf a document.
The standard procedure requires the precessing of a nonconforming ites repcrt through the Proj ect Quality Control Engineer for evaluatien and the obtaining of corrective action.
The Nonconforming Item Report procedure 16.2 is the identified mechanism by which deviations can be identified and corrective actions taken to centrol the work.
Q-12 1084 02I
BLACK & VEATCH 13.
In part 3.6, briefly describe the internal and external design it. er-face controls, procedures, and lines of cc==unication among participating design organizations and across technical disciplines fer the review, approval, release, distribution, and revisien of documents involving design in:erfaces.
Rescense:
The exchange of information by various discipline groups wi1:hin Black & Veatch and crganizations external to Black & Veatch are centrolled in a similar =anner.
The ce==unication of requiremen:s is accceplished by controlled distribution of design centrol drawings or construction drawings.
These two techniques require that the individual organization prepare a design control drawing or construction drawing :o adequately define the interface criteria in terns of loads, phys'. cal arrangement, pressure, temperature, arperage, voltage, etc. to assure t 1: the responsible manuf ac:uring, design, or cons:ructica organization has the information.
The design centrol drawings are also utilized for the ec==unication of tech.ical requirenents te organizaticas such as the Nuclear Steam Syster Supplier.
The exchange of informacien is dene by formal distributien of documents.
Document centrol aspects associated with drawingo for distribution lists, reviews, appreval, and updates en revisions are applied.
Q-13 1084 022
S '. A C K & VEATCH 14 Describe seasures which assure that design verification by design review and/or alternative calculations is ccepleted prior to release fer procurement, canufacturing, construction er to another crganiza-tica for use in other design activities.
Note that when this timing cannot be net, the design verificatien may be deferred providing that
-he justification for this action is documented and the unverified pcrtion of the design cutput document and other design output documents based en the unverified data are apprcpriately identified and controlled.
Kescense:
The scheduling techniques employed by Black & Vea:ch Consulting Engineers utilize the Critical Path Method.
The design verification activities are an ident_ ied activity that is apprcpriately interfaced en the Critical Path Me: hod.
The Critical Path Method as employed by Black i Vea:ch Consulting Engineers includes an acticn update report provided conthly to the Prcject Manager, 'ianager - Design,
? reject Engineers, and Prcject Design Engineers such the the activities are identified and shown for the current conths and the subsequent two ren:hs.
Each of the standard procedures included in the Quality Assurance Trogra: - Nuclear require checking, reviews, verifications as the individual documents are cc pleted.
To assure that the overall systers of a power plant cceply with the design inputs and re"xuir~erent s, 5:.,nderd Precedure 3.C as described in Table 2-3 requires the Manager -
JeLign to have verifica:icn activities ccepleted prior Oc ccnstructicn.
Fartial verifica:icas are necessary as the design and precurement process continues.
Partial verifica:icns are important because early activities fe: the procurement of pumps, tanks, and valves ultimately ef fect the design of piping configuraticns.
The final electrical systems are greatly influenced by the specific equipment that is purchased f or
- he power plant.
The sequencing of activities for design inputs and the collection of recuirements in the project design manual and systen design activities and :he subsecuent producticn of drawinFs, calculations, rocurement docu:ents, and so fcrth are controlled in an interfaced sequence to provide control and c assure verification prior to construction activities.
Q-14 1084 023
BLACK & VEATCH 15.
Eriefly describe controls for design documents that reflect the cc -
tittents of the SAR.
The controls should differentiate between docu-cents that receive for:al design verification by interdisciplinary er culti-organizational teams and those which can be reviewed by a single individual.
De~ sign documents subje : to procedural control should include specifications, calculatiens, cc puter programs, systen descri-
,_icns, SAR when used as a design docu:ent, and drawings such as flow diagrams, piping and instrument diagrams, control legic diagrams, elec-trical single line diagraer, structural systems for major facilities, 21:e arrangements, and equipmen: locations.
Clarify whether specialized reviews are used when uniqueness or spec:_1 design considerations warrant.
_Resconse:
Standard Precedure 3.2, 3.3, 3.4, 3.5, 3.6, i.1 and 5.2 described in
, a... ale,-; are O.ne coitro,l,ng procedures,.or tha var,eus,Kincs c:. cocu-cents such as specifications, calculations, computer progra s, flew dia-grams, and piping :nd nstruzent diagrams.
Each of the procedures contains a pu nose, scope, responsibilities for implementation and verificarica, forno: controls, review and approval steps, recuirements for records and change centrol.
Each of the stan'ard procedures has been fermatted specifically to con:rel the preparation of a specific class of documents.
To provide additional clari:y for the Nuclear Regulatory Cc==ission, additional descriptive material has been added to the description of the precedures in. ble
-a.
ta Q-15 1084 024
8 LACK & VEATCH 16.
Clarify whether procedures identify the responsibilities of the design verifier, the areas and features to be verified, the pertinent conside-rations to be verified, and the documentation required.
F. esc ens e :
S:andard Procedure 3.9 as define Table 2-3 is the ESV procedure that defines design ve:ification.
The content of this procedure defines specific responsibilities for the inplenentaticn, responsibilities for c:ncurrence of the independence of the verifier and specific instruc-tions to the verifier and/or verification tear fer the responsibill:1es for design verification.
Further, it identifies the documentation of the design verification action to be done and required status reports.
Also, refer to the response to query number 14 Q-16 iU84 025
SLACK & VEArCH 17.
Inen design verification requires testing, describe how Elack & Veatch assures that testing is performed as early as possible.
Response
31ack & Vea:ch is not an organization that accomplishes testing.
All such qualification testing for design verification us: be accomplished hrough other orstnizations.
The identification of qualification testing designs is includec. in the specifications for the procure 2ent of various c:
pieces or equipment and co penents of :he plan:.
Schedule consideratiens cittate the appropriate lead time for the procurement and verification testing as appropriate.
4 Q-17 1U84 026
BLACK & VEArCH 18.
Clarify whether the procedures mentioned in par: 4.1 of the tcpical repor: require applicable inspection and test requirenents as well as special process instructions in procurement documents.
Resconse:
The =inimum centent of a procurement document is defined in Black &
Veatch Standard Procedures 4.2 as defined in Table 2-3 cf the Tepical Report.
Standard Procedure 4.2 minimum centent requirements for qualt-ficatien testing, examination and inspectier special process ins:ruc-tiens, quality assurance programs, codes, at.d standards.
The specific intent of Standard Procedure 4.2 is to collect in a single place those ce==itments of Black & Veatch that must be incorporated into procurement dCCUCents.
Q-18 1th84 027
SLACK & VEATCH 19.
Please expand the list on page 6-2 to include:
a.
Design documents (e.g., calculations, drawings, specificat;ces,
analyses) including cocu=ents related to computer cedes.
b.
Procurement documen:s.
c.
"As-buil " documents, d.
Topical reports.
e.
Nenconfo-ance reports.
er indicate why these documents should be crittad.
Also show who (or what organi:atien) reviews and concurs with the QA-related aspects of the documents listed on page 6-2.
If other than QA, describe the qualificate.cn requirements.
Rescense:
The various types of design documents, inclucing cc:puter ccdes, are covered by :he Standard Procedures incorporated in the Black i Vestch Ouality Assurance Progra: - Suelear (see Table 2-3).
In referring to this table, you will notice that calculatione are divided into two categories, Standard Procedure 3.5 for hand calculatien and Standard Procedure 3.6 for computer calculations.
In addition, :here is a procedure S? 3.8 for co:puter code verification.
Each of these stan-
.ard procedures con;ain specific responsibilities for :he review of the documents.
Also, additional'information about the recuired reviews and approvers of dccuments has been added to Table 2-3.
Please refer to notation concerning query nu=ber 25.
Q-19 1084 028
8 LACK & VEATCH 20.
Describe measures which assure that procurement documents prepared by 31ack & Veatch require the supplier to furnish the following records to the purchaser:
a.
Documentatice that identifies the purchased ite and the specific procure =ent requirements (e.g., codes, standards, and specifications) te: by the iter.
b.
Documentation iden:ifying any precuremen: requirements : hat have not been re..
c.
A description of those nonconformances frc: the precurement requirements dispositioned " accept as is" or " repair."
Resconse:
Standard procedure 4.2 requires the procurement decurent :o include specific sections concerning :he quality assurance program to be ap-
- lied by the supplier.
Q-20 1084 029
8 LACK & VEATCH 21.
Describe :he Black & Vea:ch organizaticnal responsibilities and inter-faces betueen design, precurement, and QA for procuremen document pre-para:1ca, selection of suggested bidders, and review of informatien submit:ed by contrac:crs.
Rescense:
The 31V organiza:1cn is configured such tha: the engineering persennel assigned to any given project are respcnsible for :he design, the pre-paration of the procuremen: documents, the recertenda:icn of bidders, and the review of informatien submitted by contrac:crs.
The individual discipline groups mus: be responsible to complete the design, prepare the procurement douc ents, and review the submittals frc: the contracters.
Reviews by Quality Assurance include (1) sys:e design specification, (2) procure en: documents pric: to release, (3) excep:icas to precurement J:cumen:s proposed :o bidders, (4) nondestructive tes:ing procedures, (f) cuali:y inspection procedures, (6) velding precedures, and (7) where appropria:e ether cuali:y assurance documents submitted by centrac: ors.
The processing of contrac:crs infer:stien is controlled S:andard Procedure 7.6 as defined in Table 2-3.
4-2 1084 030
9 LACK & VEATCH 22.
Oescribe the criteria for de:erming processes :ha: are centrolled as special process and provide a =cre comprehensive list of processes that will be treated as special processes.
Resectse: Many manufac:uring processes may need special controls when applied c safe:y-related sys:e s, structures er components.
The applica:icn to a specific part or cc penent must be of concern.
For example, welding is considered a special process when used en safety-related itens and specific controls are es:ablished; while velding of me:al effice par:i:icns would not receive the same atten:1cn :o detailed centrols.
The actual velding processes (i.e.
Shielded Metal Arc 'ielding) may be the same for the two applications.
10 CFF 50, Appendix 3, Criteria IX specifically includes velding, nendestructive tes:ing and hea: :reatrent when used on safety related applica:1on.
In addition to those three items, 36V censiders manual bra:ing, furnace bra:ing, stud welding, and hot ferring (after material canufacture) c be special processes when used en safety related systems structures er compenents.
The procure =en specifications prepared by 3&~/ will be previde centrels for these precesses.
Paragraph 9.0 has been modified.
Q-22 1084 031
BLACK & VEATCH 23.
Describe measures which Black & Vea:ch uses during its review of suppliers' special process procedures to assure:
a.
Special processes are appropriately identified and controlled.
b.
Organi:ational respensibilities are described for qualifi-cation of special processes, equipment, and personnel.
c.
Procedures, equipment, and persennel associa:ed with special processes are qualified and are in confermance with applicable codes, standards, QA procedures, and specifications, d.
Procedures are established for recording evidence of accep:able acce=plish=ent of special processes using qualified procedures, equipment, and personnel.
e.
Qualifica:icn records of procedures, equipment, and personnel associated with special processes are established, filed, and kept current.
Rescense:
The requirements for the control of special processes are established in Black & Veatch procure =ent specifications by reference te national codes, standards, or inccrporation of specific supplementary requirements.
Each of the procure =ent specifica:icns for safety related materials require that suppliers subri: certain documents :o 31ack & Vea:ch.
These documents normally include drawings, load diagra s, and the procedures fer special processes.
Additional submit:als are defined concerning quality assurance records such as certified caterial test reports, procedure qualifica icn records, inspection reports, and so forth.
In accordance with Black & Veatch S:andard Procedure 7.6 (see Table 2-3) all data submitted by the Contractor is processed and reviewed.
The results of these reviews are documented and provided rn the suppliers.
The procedures within Black & Vea:ch require cetailed examination of the docu=en:s sub=itted by the suppliers to assure that they co= ply with the procurement documents and the references in the procure =ent documents to national codes, standards, and the specail requirements.
Q-23 1084 032
BLACK & VEATCH 2'.
Identify the individuals or groups with authority to evaluate and recommend disposition of Procurement Deviation Requests.
Resten:a:
Precurement deviation requests are acted upon by the responsible design group and cuality assurance personnel in all cases.
Seth parties must concur before any procurement deviatien is approved.
Q-24 1084 033
S '. A C K & VEArCH 23.
3riefly describe the procadures used :o disposition "nonconferrances which do not affect original design."
Reseense:
- en-conformances are handled in a uniforn :.anner within Elack 6 Veatch vhe:her they affect original design, do no: affect criginal design, er inpact any c:her aspect.
Fcr the purposes of unifor:-ity, the design disci > lines,
?roject Managenen: and Quali y Assurance are involved in non-confor::.ance processing.
Q-25 1084 034
eLAcK a vcATcH 26.
Discuss 31ack & Vea:ch involv=en: in and corrective action taken as :he resul: af construe: ion difficulties and field failures of Black & Veatch designed ite=s.
Response
The involvement of Black & Vea:ch in corrective action concerning field failures, construe: ion difficulties, or other =atters is dependent upon the individual Project involvement of Black & Veatch.
As discussed in
- he in:reductic: to this tcpical report, Black & Vea:ch eay or =ay not be involved in cons:ruction management activities.
The specific interface with the construction organization and the utilization of this topical report on any licensing application =ust be discussed in a specific application.
Q-26 1084 035
8 LACK & VEATCH 27.
Describe the involvemen; of Black & Yeatch =anagement in the corrective action system.
Response
The Head of the Power Division receives a quarterly report concerning the ac:1vities of the cuality assurance organication including information about non-conformances, corrective action, audits both internal and ex-
- etnal.
This informa:ica is provided to :he Head of the Fever Divisien en a quarterly basis such that he may exa=ine it for managenent action.
Also, in accordance with Standard Procedure 2.4, the Head of the Power Power Division conducts the annual management review of the Quality Assurance Program.
Q-27 1084 036
S '. A C K & VEATCH 25.
Section 17 of the topical report should be expanded to address the following:
a.
Describe Black & Veatch organi:ational responsibilities for activities related to records.
b.
Describe record s:orage facilities.
Response
The standard procedures described in Table 2-3 include Stancard Fro-cedure SP 6.2 and 6.3.
These two standard procedures concerning project filing and document centrol are designed as "en-line" controls of quality assurance records.
The specific responsibilities for identifying, indexing and storing of quality assurance records are identified in these StaiJard Procedures.
The accumulation of quality assurance records is done on a " day to day basis" to assure tha: the documents are not tis-placed, lost or forgo::en.
The standard procedures require that dupli-care storage be maintained for the recorcs.
The day-c-day working file is caintained in the controlled access condition in retal filing cabinets in main office.
A duplicate file is maintained in a separate building located remotely fro :he rain office in retal storage cabinets.
On a routine basis the security file (i.e. the remote file) is exanined for accuracy, clarity, uniformity, double checked for index entries and cor=itted to microfiln.
Q-28 1084 037
SLACK & VEATCH 9.
Describe neasures which assure that an audit plan is prepared which identifies au it.= to be perfern-d. audit frecuencies, and audit schedules, assuring effecti-e QA throug cc activities inpertant to safety.
F.e sc ens e :
The Qua'ity Assurance "
gar is charged xith the responsibility of pre-paring s',i schedule.
I: is usual prtctice to have a six nonth schedule prepared.
Aucits are scheduled such una: all of the activities effecting quality are audited.
The do.u=ent centrol, design ac:ivities, training activites, corrective actio a procedures, etc. are subject to audit on an annual basis.
Further, audits are scheduled to appl:, the design of pcuer plant systens.
The assigned lead auditors then have the responsi-bility for developing a detai.'.ed audit plan.
Once the detailed plans are approved the lead auditor proceeds to execu:e the audit.
Q-29 1084 038
SLACK & VEATCH 30.
The listuof audit areas en page 16-1 appears to be too li=iting.
So,
- co, is the sentence that says, "The procedures or checklists will identify the records and desien activi:ies to be evaluated."
(Emphasis added.)
Provide a ce==itment that audits will be performed in all areas where 10 CFR Par: 50 Appendix 3 is applicable and revise the list and s'entence accordingly.
Resconse:
As explained in :he introdue:icn to this tcpical report, Elack & Veatch does not perform construction or manufacturing activities.
For the purpose of clarity the sentence on pagt: 15.1 has been codified.
Q-30 l084 039
BLACK & VEATCH 31.
Describe reasures which assure that audits are conducted by traine.
personnel h1ving no diret: resonnsibility in the area being audited.
F.e so cns e :
The assignnents for lead audi: ors are made fron the quality assurance group.
The quality assurance greu; does not have direc: responsibilities for any activi:ies asso dated with power plant designs.
The Quality Assurance Manager is responsible for making :he assignments cf lead auditors.
1 hose specific assignnents are always carefully reviewed to assure tha:
the auditor is not an individual who has been involved in an ac:ivity.
The qualifications to be an auditor are defined in Standard Procedure 2.5 as described in Table 2-3.
Q-31 4
1084 040
BLACK & VEATCH 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 preperly carried out.
Reseense:
The Quality Assurance Progran docketed as Topical Report SVTR-1-0 is carried out through the 3&V Quality Assurance Program - Nuclear.
The Icpical Report is.n accurate summary description of the Qualit:- Assu-rance ?rogram - Vuclear.
The Quality Assurance Program - Nuclear contains the policies as provided by the head of the Power Division.
It also contai.s specific standard procedures for the implementation of the Quality Assurance Program.
Those Regulatory Guides and ANSI documents applicable to the activities within the Black & Vestch Organi:ation are incorporated in the procedures as method.s for accomp]ishing the activities.
The imple-centation of those Regulatory Guides that eust be accomplished by c:hers will be incorporated as recuirements in procurement docustnis.
The minitur content of procurement documents is addressed in u.ie Standard Pro-cedure 4.2.
Since each and every procurement document for safety related activi:ies is reviewed by the project management organization as well as the Quality Assurance Organization, there will be a double check on the implementation of the ANSI documents and regulatory guides.
Q-32 l004 041
t 8 LACK & VEATCH b.
33.
Editorial Cerments:
- p. 3-2:
delete "only"
.p.
6-1:
change are" to "is"
- p. 5-1.
change " provide" to " require"
- p. S-1.
change "or" to "and"
- p. 13-1:
delete "as guidance" Note:
Black & Vearch position On Sections 3.7(1) and 3.7.2 of ANSI N45.2.2-1977 (Topical page 2-9) is under review.
Reseense:
Editorial co==ents indicated above have been corrected within the body of the Topical Report.
Q-33 1084 042