ML19276G324
| ML19276G324 | |
| Person / Time | |
|---|---|
| Issue date: | 04/30/1979 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Blaisdell R BLACK & VEATCH |
| References | |
| BVTR-1, BVTR-1-0, NUDOCS 7905240337 | |
| Download: ML19276G324 (14) | |
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':'. R. E. Blaisc' ell JGilrcy, QAB C.ality "n uc.wa I:3nar;e r h"laa ss, QAB ialcck a '.'ca tch Co.nul t.i.ig Digincars SBryan, IE I
P.O. Nx &iOS Ape, 2nich, IE i'aasas City, Missouri 04114 UPotapovs, Reg. IV l
Dear :
- r. Blaisdall:
6 SUBiECT:
REQUEST FOR /sEDITIO.' AL II'FC.T.1 TION
'!a have reviewed the Black & 'leatch topical. repo-t nur'aer BYTR-1-0, " quality i
Assurance Prograu Descripticn," subnittad by lei.ter dated February 20, 1979.
'Ic find that..c need additional infonaation before uc can complete our revie'<.
'!a have enclosed a r; quest for additicnal infon:ation which ua discussed with you at our meeting of April 25, 1979.
i
!!ithin 30 days fro:n receipt of this letter, please respond to the enclosure.
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'lc require 4 copies of your response, i
If you have any questiens, please call Jack Spraul of my staff on (301) 492-7741.
Sincerely, C.-iginal s';ncd r,.
bY2CetP.Haas3 l
l THIS DOCUMENT CONTAINS t? alt r P. Hanss, Chief i
POOR QUAUTY PAGES Quality isasurance ocench t
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BLACK & VEATCH Request for Additional Information 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 gcod technical work nor does it relieve line management of any respcnsibility.
It includes, it is based upon, good technical work and good line management.
That is, good technical work under good line m2nagement 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 B definition of quality assurance.
2.
Part 2.4 of the topical report describes the relationship between the topical report, the Quality Assurance Program-T!uclear, and the B&V Project Instruction Manual, and Part 6.2 states that specific reviews are performed to assure that appropriate quality requirements 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 the 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 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 1.38 commitment to Revision 2 dated October 1976 and 1.94 to Revision 1, April 1976. The Black & Veatch Positions given in Table 2.1 are acceptable except as noted below.
~
3.
Regulatory Guide 1.28, Position 5:
Explain the significance of "as necessary."
b.
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 & Veatch Position to meet this staff position or provide scme alternative for our eval ua tion.
c.
Regulatory Guide 1.37, Position 1: Please add a ccamitment that adequate controls will be applied to preclude harmful effects of the removal process.
, d.
Regulatory Guide 1.38, Position 1:
Please add a cormi L ant that the protection level selected will not be less restrictive than noted in Article 2.7.
e.
Regula tory Guide 1.38, Posi tion 4:
In order to niniuize 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 Guide 1.38, Position 5:
It appears the reference should 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 tan'Ks 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 recommendations 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 nosition for our evaluation or delete it.
k.
Regula tory Guide 1.123:
Please provide justificaticn for this position for our evaluation or delete it.
The last ANSI Standard listed in Table 2-1 is fl45.2.12-1977.
This is acceptable only as clarified by the regulatory position of Regulatory Guide 1.144 issued "For Comment" in January 1979. Otherwise, we require
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a commitment to Revision 3, Draft 4, dated February 1974 which is included in Revision 1 of WASH-1283 (" Gray Book").
Please revise Table 2-1 accordingly.
Finally, reference to specifTc AtlSI standards in the text of the topical report (see 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.
4.
Part 1.4 of the topical report indicates the QA Group reviews quality assurance manuals. Clarify whether these are B&V manuals, vendor manuals, or both.
. 5.
Cescribe measures which assure that varified cmputer codes are certified for use and only certified cedes are used. Also, provide a cc mitmant that the development, control, and use of co nuter codes will be dene in accordance uith the QA program and describe how the QA program will be applied.
6.
Part 2.3 of the topical report indica tes te QA program is applicable to items so identified in " project essentii items lis ted."
Please provide a commitment that the project esse,.uial items lists will show Appendix B applied to each item so identified in applicant's Safety Analysis Reports. Also identify personnel authorized to approve changes to these lists and describe methods controlling its distribution. Also, note that the lists will include related consumables in addition to the structures, systemc-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 coconitment in the topical report) or the topical report should identify the QA controls for fire protection.
(Re ference: Attachment 6 to NRC letter to utilities
" Fire Protection Functional Responsibilities," August 29,1977/~ attached _7) 8.
Provide a commitment in the topical report to ccmply 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.
Provide a summary description on how responsibilities and control of quality-related activities are transferred from Black & Veatch to the plant owner during phasecut of Black & Veatch design and procurement activities.
10.
Indoctrination and trair,ing of personnel is discussed in part 2.6, page 2-4, of the topical report.
Clarify that the indoctrination and training program is such that:
Personnel re:ponsible for performing quality-affecting a.
activities cre 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.
For formal training programs, documentation includes the c.
objective, content of the program, attendees, and date of attendance.
d.
Proficiency of cerscnnel performing and verifying activities affecting quality is maintained by retraining, reexamining, and/or recertifying as determined by management or program commitment.
11.
Criefly describe the activities associated with the preparation and review uf design docun. cots mentioned in part 3.1 of the topical report.
Indicate the organizational responsibilities for preparing, revicaing, approving, and verifying design documents such as system descriptions, design input and criteria, design drawings, design analyses, cerputer programs, specifications, and procedures.
- 12. Describe measures which assure that deviations from specified quality standards are identified and procedures are establisiied to ensure their control.
13.
In part 3.6, briefly describe the internal and external design inter-face controls, procedures, and lines of ccmmunication 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 ccmpleted 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 un/erified data are appropriately identified and controlled.
15.
Briefly describe controls for design documents that reflect the com-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 descriptions, 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 arrangaments, 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.
. 17. ':han design verification requires testing, descrite i cu Black & '.' hatch assures that testing is performed as early as possible.
18.
Clarify whether the procedures mentioned in part d.1 of the topical report require applicable inspection and test requirer.cnts 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, analyses) including documents related to computer codes.
b.
c.
"As-built" documents.
d.
Topical repo-ts.
e.
Monconformance r; ports.
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 requireme:.ts.
- 20. Describe measures which assure that procurement documents prepared by Black & Veatch require the supplier to furnish the following records to the purchaser:
a.
Documentation that identifies the purchased item and the specific prncurement requirements (e.g., codes, standards, and specifications) met by the item.
b.
Documentation identifying any procurement requirements that have not been met.
A description of those nonconfontances from the procurement c.
requirements dispositioned " accept as is" or " repair."
21.
Describe the Black & Veatch organizational responsibilities and inter-faces between design, procurement, and QA for procurement document preparation, selection of suggested bidders, and review of information submitted by contractors.
22.
Describe the criteria for determining processes that are controlled as special process and provide a more comprehensive list of processes that will be treated as special processes.
23.
Describe measures which Black ?. Veatch uses during its review of suppliers' special process proccdures to assure:
a.
Special processes are appropriately identified and con trol led.
b.
Organizational responsibilities are described for qualifi-cation of special processes, equipment, and personnel.
c.
Procedures, equipment, and personnel associated with special processes are qualified and are in conformance with applicable codes, standards, CA procedures, and s peci fica 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, and kept current.
24 Identify the individuals or groups with authority to evaluate and recommend disposition of Procurement Deviation Requests.
25.
Briefly describe the procedures used to disposition "nonconformances which do not af fect original design."
26.
Discuss Black & Veatch involvement in and corrective action taken as the result of construction dif ficulties 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.
29 Describe measures which assure that an audi' cla is prepared which identifies audits to be perfor: :-d, audit i< !quencies, and audit schedules, assuring ef fective QA througio.. 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 checklists will identify the records and design cctivities to be evaluated."
(Emphasis added.) Provide a cimitment that audits will be performed in all areas where 10 CFR Part 50 Appendix 8 is applicable and revise the list and sentence accordingly.
31 Describe measures which assure that audits are conducted by trained personnel having no direct responsibility in the area being audited.
32 Provide a description that eraphasizes how the docketcJ OA 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" co "is"
- p. 3-1: change "provi de" 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.
ittachmant 6 to NRC tetter to Utilities
" Fire Protection Functional Respcnsibilit.ies" August 29, 1977 jC ALIT'r A$5UoANCE The ;uality assuranc: (CA) progrn shculd assure that the recuirements for design, procurement, instailation, testing, and administrative controls for the fire protection program for safety related areas a;;reved by NRC ara satisfied.
The Quality Assurance previsiens for fire protection should apply to activities performed af ter the ef fective date of the ad:ption of said previsicas.
The QA program should be under the management control of the QA organization.. This control consists of (1) formulating and/or verifyir.g that the fire protection CA program incorporates suitable requirements and is acceotable to the -anagement res;:ensible for fire protection and (2) verifying the ef fectiveness of the QA program for fire protecticn through review, surveillance, and audits.
Performance of other QA program functions for meeting the fire protection program requirements may be performed by personnel cutsidc of the QA organization.
The QA program for fire protection shculd br. Part of the overall plant QA program.
These QA criteria a;;:ly to these items within t'he scope of the fire protaction program, such as fire ::rotection systems, emergency: lighting, communication and emergency breathing ac;:aratus as well as the fire protection requirements of a;:plicable 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 Regulatory Guide 1.120 by either:
1) implementing those fire protection QA criteria as part of their QA program under 10 CFR part 50 Appendix B, where such a cer.itent is made, it is not necessary to sucmit a detailed description of the fire protection QA program or its implementation for NRC review; or
- 2) providing for NRC review a descripticn of the fire protection QA program and the measures for implementing the program. Supplemental guidance is provided below cn acceptable measures for implementing each of the fire protection ~QA program criteria of Appendix A to BTP 9.5-1 or Regula tory Guide 1.120.
1.0 Design Control and Procurement Cocument Control
. Measures should be established to assure that the applicable guidelines of the Regulatory Guide 1.120 or as;: roved NRC altarnatives are included in design and procurement documents and that deviaticns therefrca are controlled. These measures should assure that:
Design and procurement document changes, including field changes a.
and dasign deviations are subject to the same level of controls, reviews, and approvals that were applicable to the original document.
2 b.
Quality standards are specified in the design documen:s such as appropriate fire protecti^n codes 'and standards, and deviaticns and changes from these cuality standards are controllec.
c.
New designs and plant modifications, including fire protecticn systems, are reviewed by qualified personnel to assure inclusica of appropriate fire protection requirements.
These reviens should include items such as:
(1)
Design reviews to verify adequacy of viring isolation and cable separation criteria.
(2)
Design reviews to verify apprcpriate requirements for reca isolation (sealing penetrations, ficors, and otner fire barrie rs ).
d.
A rc riew 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 determine that fire protecticn requirements and quality requirements are correctly stated, inspectable and controllable; there are adequate acceptance and rejection criteria; and the procurement documen; has baen, prepared, re-viewed, and approved in accordance with QA program require: ants.
2.0 Ins tructions, Procedures, and Drawing - Inspec tiens, te's ts, admin-istrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructicas, procedures or drawings and should be acccmplished in accordance wi th thesa documents.
The follcwing provisions should be included, a.
Indoctrination and training programs for fire preventior and fire fightina are implemented in accordance with documented procadures.
b.
Activities such as design, installation, inspecticn, test, maintenance, and modificaticn of fire protection systes are prescribed and accomplished in accordance with documented in-structions, procedures, and drawings.
c.
Instructicns and preceduras for design installation, inspec-tien, test, :aintenance, modification and administrative controls are reviewed to assure that proper inclusien of fire protection requirements, such as precautions, control of ignition sources and c0mbustibles, provisiens for backup fire protecticn of the activity requires disabling a fire protection system, and re-striction en material substitution unless specifically per.aitted by design and confi: red by design review.
3 d.
The installation or application of penetration seals and fi re retardant coa tings is cerfanned by trained personnel using approved procedures.
3.0 Central of Purchased Material, Equipment, and Services - Measures s hall be es tab!ished to assure tha t purchased material, equipment and services conform to the procurement documents.
These measures should include:
~
a.
Prcvisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the ccntractor, inspections at suppliers, or receiving inspecticns.
b.
Source or receiving inspection, as a minimum, for these items whose quality cannot be verified after installation.
4.0 Inspection - A program for independent inspection of activities affecting fire protection should be established and executed by, or for, the organization performing the activity te verify conformance io documented installatien drawings and test procedures for acccmplishing activities.
This program shculd include:
a.
Inspections of (1) instaliation, maintenance and mcdification of fire protection systems; and (2) emergency lighting and cc.:unica-tion equi: ment to assure confermance to design anc installation requirements.
b.
Inspection of penetration seais and fire retardant c5ating installations to verify the activity is satisf actorily cc pletad.
c.
Inspections of cable routing te verify conformance with design requirc ents.
d.
Inspections to verify that accropriata requirements for reca isolation (sealing penetrations, ficers, and Other fire barriers) arc acccmplished during construction.
e.
Measures to assure that inspection perscnnel are independent frca the individuals parforming the activity being inspected and are kacwledgeable in the design and installatien requirements for fire protection.
f Inspection precedures, instructions, and check lists which provide for the folicwing:
(1)
Identification of charactaristics and activities to be inspected (2)
Identificatien of the individuals or greu:s respcasible for performing the inspection c;eration (3) Acceptance and refection criteria
4 (4) A description of the method of inspection (5)
"tecording evidence of ccmpleting and verifying a manu-facturing, inspection er test operation (6)
Recording inspector or data recorder and the results of the inspection Operation 9
Peri:dic ins;ections of fire protectica systems, emergency breathing and auxiliary ecuipment, emergency lighting, and c:nunicatica equip-ment to.:sure the acceptacle c:ndition of these items.
h.
Pericdic inspection of materials subject to degradati:n such as fire steos, seals, and fire retardant c:atings to assure these ite,ms have not deteriorated or been damaged.
5.0 Test and Test C:ntrol - A test program should be established and im:lemented c ensure that testing is performed and verified by inspectiN and audit to damenstrate conformance with design and system readiness re;uirements.
The tests should be perf rmed in accordance with written test precedures; test results should be pre:erly evaluated and acted on.
The test program shculd include tha,fcil: wing:
a.
Installation Testing - Folicwing construction, modificitien, repair or replacement, sufficient testing is performed to dem:nstrate that fire protecticn systems, emergency lighting and c:mmunication equi;-
ment will perform satisf actorily in service and that design criteria are met. Written test precedures for installation tests inc:racrate the requirements and acceptance limits contained in applicable design documents.
b.
Periodic testing - The schecales and methcds for periedic testing are developed and documented.
Fire protection equi: cent, emergency lignting, and communication equi; ment are tested ;ericcically to assure that the equipment will Drecerly functi:n and c ntinue to meet the design cri*.arla.
c.
Programs are established for CA/QC to verify testing of fire protection systems and :: verify that tast persennel are eff ectively trained.
d.
Test resuits are documented, evaluated, and their acce tability detarminad by a qualified res;casible individual or group.
6.0 Ins:ection, Test, and Operating Status - Measures should be established to pr: vide for the identification of items inat have satisfactorily passad re;uirec tests and inspecticas.
These measures sh:uld include pr: visions for:
a.
Identificaticn by means of tags, labels, or similar tem;0rary markings to incicate c:moletion of recuired ins;ecti:ns and tests, and Operating sta'.us.
5 7.0 Nanconforming Itaas - Measures should be established :: contrei items that do not conform to specifica requirements to prevent inac>ertent use of installation.
These measures shoule include previsions to assure that:
a.
Nanc:nforming, incearative, or calfunctioning fire protection systems, emergancy lighting, and cc:munication equipment are appr:griately tagged or labelled.
b.
The identification, documentation, segregation, review dis-position, and notification to the affected crqani:ation of nonc:nforming =aterials, parts, cc penents, or services are precedurally controlled.
c.
Occumentation identifies the ncnconforming item, describes the nonc:nformance and the dispositicn of the noncenferning iten and includes signature approval of tha disposition.
d.
Provisions are established identifying those individuals or groups dalegated the responsi'oility and authority for the disposition and approval of nonconforming items.
8.0 Corrective Action - Measures shall be established to e'nsure that cin -
ditions adverse to fire protection such as failures, malfunctions, deficiencies, deviations, def active c:: cnents, uncontrolled combus-tible ~matarial and conconfermances are pec=0tly identified, reported and corrected. These ceasures should assure:
a.
Procedures are established for evaluatien of c nditions adverse to fire protection (such as nonconformance, f ailures, mal-functions, deficiencies, deviations, and defective material and equi; ent) to determine the necessary corrective action.
b.
In the case of significant er repetitive conditi ns adverse to fire protectico, including fire incidents, the cause of the conditions is determined and analyzed, and prompt corrective acticns are takan t preclude recurrence.
The causa of the condition and the corrective action taken are pree;;1y reported to c:gnizant levels of management for review and assessment.
9.0 Records - Rec:rds should be prepared ar.d maintained to furnish avicence that the critaria enumeratad above are being met for activities affecting the fire pr: taction pr gr:m.
The following pr: visions shculd be included:
a.
Rec:rds are identifiable and retrievable and shculd demonstrate c:nf:rmance to fir 2 protaction requirements.
The racerds should
6 include results of inspections, tests, reviews, and audits; non-confor:2nce and corrective action reports; c nstruction, maintenance and =cdification records; and certified manufacturers' data.
b.
Record retention requirements are estaclished.
10.' Audi ts - Audits should be conducted and documented to verify ccepliance 0
with the fire pr:tection pr: gram, including desi.;n and procurement documents, instructions, proceddres, ar.d drawings, and inspection and test activities.
The following provisions should be included:
a.
Audits are periodically performed to verify c =plianca with the administrative controls and implementation of quality assurance criteria including design and procurement, instructions, procecures and drawings and inspection and test activities.
These audits are performed by QA personnel in accordance with preestablished written procedures or check lists and conducted by trained personnel not having direct responsibilitie.< in the arees being audited.
b.
Audit results are documented and then reviewed with management having responsibility in the ares audited.
Folicwup action is taken by res;cnsible management to correct the c.
deficiencies revealed by the audit.
d.
Audits are annually performed to provide an overall assessment of conformance to fire protacticn requirements.
.