ML19263F605
| ML19263F605 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/04/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Silver H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111090060 | List:
|
| References | |
| FOIA-80-515, FOIA-80-555 NUDOCS 8002190005 | |
| Download: ML19263F605 (10) | |
Text
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!!EMORANDUM FOR:
Harley Silver, Project Manager, Light Water Reactors Branch No. 4 Division of Project Management FROM:
Walter P. Haass, Chief, Quality Assurance Branch, Division of Project Management
SUBJECT:
TMI-l RESTART REVIEW We have partially completed our review of the TMI Operational Quality Assurance Plan (0QA Plan) submitted with J. Thorpe's letter of January 25, 1980 to H. Dcc. ton. We have identified areas for which additional infomation (see the enclosure) is required to complete our review. Also, we are continuing our review, with technical groups outside QAB, with regard to those exceptions and modifications of the regulatory guides described in Appendix C to the 0QA Plan; this effort may necessitate further questions or positions.
The 00A Plan contains a well structured and acceptable QA organization and provides well thought out QA concepts. However, in order to enhance our under-standing of how certain portions of the 0QA Plan wfll be implemented and by whom, this additional request for information is necessary.
It is requested that the GPU response be provided within twc weeks of receiving the staff's letter in order to assure adherence to the hearing sch".du?e.
Original signed by Walter P. Haass Walter P. Haass, Chief Quality Assurance Branch Division of Project Management
Enclosure:
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REQUEST FOR ADDITIONAL INFORMATION TMI-l OPERATIONAL QUALITY ASSURANCE PLAN 1.
Section 2.2.4.3 (pg. II-10) of the Operational Quality (2.2.4.3)
Assurance Plan (0QA Plan) briefly describes the function of the Nuclear Safety Evaluation Department which reports to the Director of Reliability Engineering. The organization chart (Figure 1) and Section 1.2-6 does not identify this department.
Revise the organization chart and Section 1.2-6 identifying this department.
2.
a.
Provide the projected staff size for each of the organizational (1.2.6.1) units identified in Figure 2 of the 0QA Plan that report to the Manager of Quality Assurance.
b.
Describe management policies to assure that the need for QA activities in support of the TMI-2 recovery program and Oyster Creek will not detract from the need for QA activities for operation of Ti1I-1.
3.
Describe the qualification requirements for the Quality Assurance (1.2.6.1)
Manager position which provide assurance that the individual filling this position possesses QA experience in reactor design, construction, and operations, and is knowledgeable in QA regula-tions, policies, practices and standards.
4.
Throughout the 0QA Plan the terms Plan and Program are used (general) interchangeably. Revise the 0QA Plan substituting Plan for Program thus precluding any misinterpretation.
M 25
. 5.
Increase the scope of the 0QA Plan and the Quality Classification (2.1.2)
List (QCL) to include those items addressed in Regulatory Guide 1.29 and 1.26.
6.
Provide a representative QCL of those items and activities that (2.1.2) fall under the control of the 0QA Plan.
7.
Describe the involvement of the QA organization in the review (2.0 &
3.0) and documented concurrence of the QCL to assure that this list is established in accordance with the 0QA Plan and has been properly reviewed and approved.
8.
Identify who will be respor.sible for determining the degree to
'(( 2.1. 3) pg. II-3) which the requirements of the 0QA Plan and its implementing pro-cedures are applied to items and activities important to safety and describe in more detail how this will be accomplished. Of particular interest is the extent of the QA organization's involvement in this area.
9.
Describe in more detail the methods for determining how and to (2.1.3) what extent each of the three level approach will be applied to specific items.
10.
Qualify the term "significant" used in Section 2.2 to the extent (2.2.1) one can determine and distinguish between those changes and revisions of the 0QA Plan requiring high level management approval and NRC notification.
11.
Delete or qualify those ambiguous terms such as "ze applicable "
(general)
"as appropriate," etc. used throughout the 0QA Plan to preclude any misunderstanding as to interpretation of these terms.
3
, 12.
Identify who will be authorized to determine the classification (2.2.2) of spare and replacement parts and the need for identifying these parts on the QCL. Of particular interest is the extent of the QA organization's involvement in this area and the extent of docu-menting the decision process.
13.
Describe how those personnel involved in QA and plant operations, (2.2.2) maintenance and modifications differentiate between those parts, including spare and replacement parts, that are important to safety and fall under the control of the 0QA Plan and those that do not.
14.
Provide a statement in Section 2.2.3, " Regulatory Commitments,"
(2.2.3) that Appendix C of the 0QA Plan describes those Regulatory Guides and Standards, including acceptable exceptions, clarifications, and modifications to these documents, that must be complied with in conjunction with the 0QA Plan.
15.
Provide a commitment to comply with 10 CFR 50.55a, and clarify (2.2.3) that for those structures, systems, and components covered by the ASME Code Section III (Classes 1, 2 & 3), tne quality assur-ance code requirements will be supplemented as specified in those regulatory guides in Appendix C of the OQA Plan.
16.
(2.2.5)
Within the indoctrination and training Section 2.2.5, describe the qualification program for on-site and off-site personnel performing activities important to safety.
e p
. 17.5 Describe those provisions which assure that acceptance criteria (2.2.6) will be established and documented to determine the level to which individuals will be properly trained and qualified and that proficiency tests will be given these personnel to demonstrate that they are properly qualified and trained.
18.5 Describe those provisions which assure that, for those personnel (2.2.6) responsible for performing inspections, examinations, tests, and special processes, certificate of qualification will be documented and maintained which clearly delineates the specific functicns he is qualified to perform.
19.
Throughout the 0QA Plan the activities of approval, acceptance, (general) and concurrence are described. Provide a general statement that the completion of all the approval, acceptance, and concurrence activities described in the QA Plan will be ducumented and filed for reference.
20.
Provide a statement in Section 3.1.2b stating that Appendix B (3.1.2) identifies organizational responsibilities for the preparation, review, approval, concurrence, and issuance of documents impor-tant to safety.
21.
Describe the extent of QA involvement in the review and documented (3.1.3.3) concurrence with instructions, drawings, and procedures associated with the administrative controls, operation, fuel handling, inservice inspection, calibration, maintenance, modifications, repair and operational testing of structures, systems, and components important to safety.
a_wl 353
. 22.
Describe the extent that as-built drawings and specifications (3.2.2) will be maintained up-to-date.
23.
Clarify Section 3.2.2 item i describing the approval responsi-(3.2.21) bilities of the maintenance, modification, and inspection proce-dures prior to implementation.
24.
Provide an additional control in Section 3.2.2 item i which (3.2.2i) requires the QA organization to verify that the procedures have been prepared, reviewed, and approved in accordance with established policy and program controls.
25.
Expand Section 3.3.2 item (a) to include such records as test, (3.3.2a) inspection, and verification procedures.
26.
Expand Section 3.1.2 to require instructions, procedures and (3.1.2) drawings which prescribe the performance of activities important to safety to be in accordance with the TMI 0QA Plan.
3 27.
Delete the words, " major participating organizations," in item (a)
(3.3.3.la) of Section 3.3.3.1 or provide sufficient clarification to this statement to preclude any misunderstanding as to its meaning.
28.
(4.0)
Describe in detail the purpose and use of engineering change memorandums and include in the description the review, approval, and control of this document.
29.
Describe those provisions which assure that in those cases where (4.2.11) the design is authorized to be released for use prior to ver iiica-23Gi 364 tion, a justification for this action is documented and approved by management and the unverified portion of the design output document and all other design output documents and items based on the unverified data, are identified as such and controlled.
30.
Identify the design and engineering documents that are reviewed (4.3.6) and approved by the QA organization prior to use.
31.
Provide a statement in item h of Section 5.1.2 requiring procure-(5.1.2h) ment of spare and replacement parts for structures, systems, and components to be subject to the current Quality Assurance program controls.and to codes and standards.
32.
Describe the involvement of the QA organization in the review, (5.1.2.3c) concurrence, and control of vendor's nonconformances dispositioned "use as is," or " repair," and the corrective ac.tions associated with these nonconformances.
33.
Describe the controls for identification, including the maintenance (5.2) of identification, of materials, parts, and components important to safety during the maintenance and operations phase.
34.
Modify item c2 of Section 5.2.2 to include "As Built Drawings."
(5.2.2c) 35.
Describe who is responsible for (a) determining the extent (6.2.1 &
6.2.1.1) necessary for performing independent verifications (i.e., inspec-tions, monitoring, surveillance, reviews and audits) are performed; (b) determining the extent stations work functions are controlled 36 236
. consistent with their importance to safety and; (c) determining the program for inspection of activities affecting quality.
Describe the QA organization responsibilities in these areas relative to review and concurrence.
36.
In regards to individuals perfonning inspections, describe those (6.2.1.1) provisions which assure that they are sufficiently independent from those individuals responsible for cost and schedules.
37.
Describe those provisions which assure that work authorization (6.2.1.1) documents rel. ting to work considered important to safety are concurred with by the QA organization prior to start of work.
38.
Explain in more detail the criteria to be used in determining (6.2.1.1) statistically valid sampling plans.
39.
Expand the test program to cover tests associated with technical (6.2.1.3 item 4) specifications and inservice inspection.
40.
Describe those responsible for the control of measuring and test (6.2.1.4) equipment and describe the involvement of the QA organization in this area.
41.
Describe who will be responsible for the independent verification (6.2.1.6) activities described in item e and f of Section 6.2.1.6.
In addition describe the QA organization's involvement in the inspection and surveillance of the activities associated with the inspection, test, and operating status of items important to safety.
366 p3 (, i
. 42.
Describe the involvement of the QA organization in the area of (6.2.1.6 &
6.2.1.8) fire protection and plant security.
43.
Describe the involvement of the QA organization in the area of (6.2.1.10) equipment control associated with independent verifications, con-trol of temporary modifications, and the control of inspection and test status on individual items.
44.
Describe the involvement of the QA organization in the following areas:
(6.2.1.11)
(a) the assurance of quality for maintenance, modification, and construction activities, (b) the corrective maintenance program, and (c) the preventative maintenance program.
45.
Identify through a representative list those documents requiring (6.2.1.12) a review by the QA organization and describe those provisions which assure that the QA organization approves these documents prior to use.
46.
Describe the involvement of the QA organization in the control of (6.2.1.13) surveillance testing and inspection including the independent verification of these activities.
47.
Describe the involvement of the QA organization in radiation control.
(6.2.1.14) 48.
In the second paragraph of Section 7.1, provide a specific commit-(7.0) ment that the applicable sections of the 0QA Plan will be implemented to satisfy the criteria (Appendix E to 10 CFR 71) for the packaging and transportation of radioactive material.
.23 h I
-9_
49.
Describe those provisions which assure that the QA organization will (8.0) concur through documentation in tF, disposition of nonconforming items, corrective action, and close out of nonconformance reports.
50.
Describe the extent that errors, malfunctions, and deficiencies to (8.0) regulations, the FSAR, and QA and specification requirements will be reported on the nonconformance report form.
51.
Expand item c of Section 9.2 to include technical specifications.
(9.2,c)
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