ML19259C463
| ML19259C463 | |
| Person / Time | |
|---|---|
| Issue date: | 05/21/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Violette J BECHTEL GROUP, INC., BECHTEL POWER CORP. |
| References | |
| NUDOCS 7906220126 | |
| Download: ML19259C463 (4) | |
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/t our 1.ieting of Pay 0, 1979, uc discus.ed a nur' er of :r mnts tenerate durinn our reviev.
'le have enclosed a cooy of the cuestions ' hich Uc l elinve should I e fer:. ally responed to.
Please sul nit vc.ur r'sponse nithin 55 days frca roccint of this lette.r.
If you have any cuestions, please contact Jack Spraul of nv staff on (301) G2-7/41.
Since rely, 9]
5 'a $.. a ss Waltcr P. Haass, Chief quality /.ssurance Cranch Civision of Project Panagetent
Enclosure:
Questions on Bechtel Topical SQ-TOP-1, revisien 3 2282 102 cc u/ enclosure:
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l.
Terms appear inconsistent a)
Division Quality Program Policies (pp. vi and 23) b)
Division Quality Policies (pp. 4 and 7) c) Quality Program Policies (p. 23) d) Quality Policies (p. 20) e)
Division QA Policies (p. 60) 2.
Whatever the proper title for the above policies, the fact that they "are governed by the program described in this (topical) report" should not be deleted from page 4.
3.
Page 5a defines " Quality Policy Statenent" as " Corporate management direction provided in the foreword to this docua,ent." Based on this definition, we suggest page i be titled:
" Foreword and Quality Policy Statement."
4.
The terms on pages 3-5a should be alphabetized.
Also, consider the desirability of defining " authorize" (see pages 6 and 10).
5.
On page 6, identify (by position title per figure) the " Sponsoring Of ficer for Quali ty Assurance. "
Specify the periodicity of the reports he makes to the BPC president.
6.
Per Revision 2A, the l'anager of QA had " access to the President and other members of Thermal Powe r Management.... " We L,elieve the QA staff specialist should have the same access capability stated in the topical (p. 7).
7.
Who is now responsible to coordinate the M&QA quality program for power projects? See page 9.
8.
A " typical" organization chart is acceptable if it is typical of more than one organization.
A " typical" organization chart is not acceptable for a given organization.
(See pages 9 and 10 and Figures 1, 3, 4 etc.)
9.
We do not agree with the deletion of " Project, department, and division quality practices are subject to audit by Cuality Assurance" from page 20.
10.
We do not agree with the changes to the first 2 paragraphs on Management Review on page 26.
That is, we object to the deletion of the sentence on meetings and the deletion of the commitment that annual reviews are performed "by individuals outside the involved QA organization."
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11.
In his overall report on the QA Program implementation (page 26), does tie QA Specialist - TP0 no longer consider audit reports from clients and IE? This consideration should be included in the first paragraph of Section 2.7.
Al so,
as discussed in the June 78 meeting (see page 3 of Bechtel July 78 remo), we believe that 50.55e reports should be considered in the preparation of the overall report on the QA program.
12.
Figure 10 shows Chief Engineers as part of a project organization, but page 30 indicates they are involved in the preparation of generic docun,ents vhich are applied to several projects.
Are the Chief Engineers part of the TP0 (as opposed to Division) organization? Clarification is needed.
13.
The new paragraphs at the bottom of page 34 address a) procedures prepared by Construction and b) procedures prepared by Field Engineering.
Where are these procedures shown in Table l?
(They should have QA review.)
14.
The last words on page 39 are " source qualification programs." What are source qualification programs? Does Bechtel meet Regulatory Guide 1.123 in this area of supplier evaluation?
15.
We do not agree with the deletion of "by quality control personnel as a part of receiving inspection" from the middle of page 42.
We do not object to the personnel being part of the Procurement Supplier QC organization.
16.
We are concerned with the new words at the bottom of page 42.
We believe that the verification of interface capability should be accomplished significantly ahead of installation in order to help prevent schedule censiderations over-riding quality considerations.
We also believe that item operability should generally be verified before preoperational tests for the same reason. The refore,
we believe the new paragraph should not be included in the topical report.
ll.
The identification of Quality Control as the organization which checks quality verification records at the construction site should not be deleted from page 43.
As in item 19 above, we do not object to the personnel bcing part of the Procurement Supplier QA organization.
18.
Project Engineering approval prior to " acceptance" rather than prior to "implenentation" (page 53) indicates repairs can be made and nonconforming items can be permanently installed before Project Engineering review We do not agree with this concept.
- 19. We do not agree with the deletion of "the Manager of QA-TP0" from the bottom of page 57 without the additiori of ".he QA specialist-TP0" (see item 7).
Same comment applies to the top of page 58.
- 20. On page A-9, Bechtel has inserted a sentence relative to Section 2.2.3 of ANSI N45.2.6.
The bottom of page 4 of the Bechtel July 78 memo indicates that "Bechtel will re-evaluate their position and propose an appropriate modi fi ca ti on. " This does not appear to have been done.
An acceptable conmitment would be as follows:
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2.2.3 Evaluation of Performance The job perforrance of inspection, examination and testing personnel shall be re-evaluated at periodic intervals not to exceed three years.
Re-evaluation shall be by evidence of continued satisfactory performance or re-determination of capability in accordance with Subsection 2.2.
If, during this evaluation or at any other time, it is determined by the responsible organization that the capabilities of an individual are not in accordance with qualifications specified for the job, that person shall be removed from that activity until such time as the required capability has been demonstrated.
Any person who has not perforced inspection, examination or testing activities in his qualified area for a period of one year shall be re-evaluated by a re-determination of required capability in accordance with Subsection 2.2.
21.
Bechtel position 4 concerning Section 10 of /NSI N45.2.11 (page A-15) needs cl ari fica tion.
Please clarify Bechtel's position on the requirement that "The documentation shall include... records of the important steps including sources of design inputs, which support the final design."
22.
The first Bechtel position on page A-16, relative to " completely filled out" forms, is acceptable with the following clarification:
" Portions which are not applicable will be so noted." Also, we believe the words "has finished full processing and" should be deleted because the sentence is clearer without them.
23.
As noted in our letter of May 2,1979, item 1 on page A-19 is not acceptable.
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