ML19308E086
| ML19308E086 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/04/1974 |
| From: | US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19308E084 | List: |
| References | |
| NUDOCS 8003200813 | |
| Download: ML19308E086 (8) | |
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CRYSTAL RIVER UNIT 3 NUClfAR GENERATING PIAVr SAFETY EVALUATION REPORT QUALITY ASSURM!CE GENERAL The description of the Quality Assurance (QA) Program for CIystal River Unit 3 Nuclear Generating Plant (Crystal River #3) is contained in Section 1.7 of the FSAR, a3 amended. Our evaluation of the description of the QA Program is based on a review of this infomation and detailed
- discussions with the applicant to determine the ability of Florida Power Corporaslon (FPC) to comply with the requirements of Appendi: B to 10 CFR Part 50.
ORGANIZATION According to the FSAR, the Senior Vice President of Systems Engineering and Operations (see Figure 1) has the total responsibility and authority to plan, organi:c, staff, execute and control the Quality Assurance Progran affecting Crystal River #3.
Reporting directly to him are the Assistant Vice President - Generation Engineering and the Assistant Vice President -
Systems Operation.
The authority to plan, organize, staff, execute and control the FPC's total QA Program has been delegated to the Assistant Vice President -
Generation Engineering. He reviews and approves all sections and subsequent revisions of FPC's QA Manual. The Director - Generation Quality and Standards (Director) reports directly to the Assistant Vice President -
Generation Engineering and is assigned the management of the QA Program.
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The Director is responsibic for:
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assessing that all QA functions are being impicmented, 2.
conducting audits to verify and evaluate the QA Programs effectiveness, 3.
the revieu, updating and co-approval for all sections of the QA Manual for FPC, and 4.
reporting to FPC management on the effectiveness and imple-mentation of the QA Program.
FPC has delegated to the Director the authority and responsibility to stop work which, in his opinion, adversely affects the end use of safety related structures, systems, and component. during the operation of Crystal River #3.
The Director reports to a management level that has broad responsibilities in the areas of design, procurement and operation and that is independent of the organization directly responsible for operati nal costs and schedules for Crystal River #3. Therefore, we conclude that sufficient independence and authority exists in the QA organization to establish an effective QA-Program for Crystal River #3 and to assure, through audits, that the program is carried out in accordance with Appendix B to 10 CFR Part 50.
The Assistant Vice President - Systems Operation is responsible for the inplementation of the.QA functions associated with operation, maintenance, repair and refueling. The Superintendent' of Crystal River #3 reports and '
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- receives technical direction from the General Plant Superintendent who reports thru the Production Superintendent to the Assistant Vice President - System Operations. The Superintendent is directly respensible for implementing the k
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QA Program as defined in the QA4!anual-by the Director of Generations Quality and Standards.
Reporting directly to.the Plant Superintendent is the Compliance Engin' er, who has responsibilities for verifying that quality e
-related' activities perfomed at Crystal River #$ comply with the QA Program.
He participates in the control of nonconformance and corrective action reports; the control of quality records; and the review of mainte.unce and modification procedures to assure that adequate quality and inspection re-quirements and qualified inspection personnel are identified.
The Corpliance Engineer is. organizationally independent from the operation and maintenance departments thus precluding undue influence on his activities based on operational costs and schedules.
Based on our evaluation of FPC's organizational assignments and responsibilities, we find that sufficient separation exists between the positions responsible for quality assurance and those responsible 'for operational costs and schedules. We find that attention to quality problets and to their resolution should not become subordinated. Therefore, we con '
clude that FPC's QA personnel, both at the offsite. office and at the plant operating level, have sufficient authority and organi2:ational freedom to perfom their QA functions effectively and without reservation and that the requirements of Criterion I of Appendix B are met.
QA PROGRN1 FPC's QA Program, described in the'FSAR, encompasses procedural controls
'necessary to_ satisfy each of the eighteen criteria of Appendix B to 10 CFR Part 50.
It provides for the involvement of all partidipants in quality.
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b*y 4-1 activities in a controlled and systematic manner during the operation of Crystal River #3. The QA Program provides for the verification and inspection of quality requirements of safety related structures, systems, and components by individuals or groups independent of those who perfomed the work being verified or inspected.
Provisions in the QA Program require indoctrination and training programs to be established and conducted for those personnel performing quality related activities. H is training is to assure that they are knowledgeabic of the requirements of the QA Program and procedures, and that they become proficient in implementing them.
Design activities, including design changes, are procedural]ycontrolled in FPC's QA Program. The program requires that applicable regulatory requirements and design bases are correctly translated into specifications,'
drmeings, procedures and instructions; that design verification or checking is performed; and that the individuals or groups responsible for design verification or checking are other than those who perfomed the design activity. He FPC's Generation Engineering Department participates in tJte design activity, providing independent reviews of design and drm<ings changes. He Quality and Standards Department audits the design activity, including the design documents, to assure they are in compliance with the QA Program requirements.
For procurement activities, the QA Program provides for the Compliance Engineer to review procurement documents, prior to purchase, to assure that i
i all quality requirements are addressed. Both the Generation - Engineering 1
and the Generatien - (pality and Standards Departments conduct vendor i
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r V-evaluation surveys of potential bidders to deternine the ability of suppliers to provide acceptable quality products. Audits and surveillance.of suppliers during fab'rication, inspection, testing, and shipment of materials, equipment, and components will be detemined in advance and perfomed by FPC in accordance with written procedures. The Generation - Quality and Standards Department and a delegated qualified QA consultant will participate in the surveillance and audit activities of suppliers of safety related equipment for Crystal River #3.
FPC's QA Program also provides measures to assure that special processes are perfomed by qualified personnel and accomplished by written procedures.
These procedures require recorded evidence of verification and, if applicable, inspection and process results.
Inspection operations are perfomed by inspection personnel who are independent from those performing the l
activity being inspected, and in accordance with predetemined inspection procedures.
FPC states that testing activities will be conducted at the Crystal River #3 during the operations phase to verify the compliance of components with design requirements. The QA Program requires that such testing be. identified, documented, and accomplished in accordance with written, _ controlled procedures and that the inspection, -test and operating
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QA Program also provides ' measures tio control the identification, documentation, segregation,. review and disposition of nonconfoming materials, parts, components or services, incluhing the initiating and verification of
- correctivp action. FPC states that a system for pennanent retentien of records,in the Quality Files has b en established which contain results of A
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- reviews, ' inspections, -tests, and audits; the qualifications of personnel, procedures and equipment; drawing specifications, procurement document, calibration procedures, calibration reports and nonconfoming and corrective action reports.
The QA Program requires comprehensive documented audits of all quality related activities at Crystal River #3 and at suppliers facilities which are required for plant modifications. These audits are to be conducted by,the Generation - Quality and Standards Department or by a delegated qualified QA consultant to assure compliance with all aspects of the QA Program.
FPC states that qualified QA consultants having specialized skills will play a significant role in the audit activity. However, consultant activities will be audited by the Generation - Quality and Standards Department for confomance to FPC's overall QA policy.
The audit activity will include an objective evaluation of quality related practices, precedures, and instruction; the effectiveness of implementation, and the conformance with policy directives.
FPC states that audit results will be documented and reviewed by management having responsi-bility in the, area audited. Deficient areas are required to be re-audited until corrections have been adequately accomplished.
Based on our review of the QA Program description for Crystal River #3,
.as contained in the FSAR, we conclude that the program provides for sufficiently detailed quality requirements and centcols to fully comply with the requirements of Appendix B to 10 CFR Part-50.
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7-(DNCLUSION We have perfomed a detailed review and evaluation of FPC's QA Program
- description, and conducted a series of discussions an'd meetings with FPC.
Based on these, we conclude that the FPC organization provides sufficient -
independence and authority to effectively carry out the QA Program for Crystal River #3 without undue influence and pressure from those ' organization -
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elements responsible for cost and schedules. We further conclude tint the QA Program description in the FSAR contains adequate QA provisions, require-ments and controls deconstrating compliance with 4 pendix B of 10 CFR Part 50 throughout the operational phase, which includes the maintenance modification and repair activities, of Crystal River #3.
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Asst.' Vice President -
Asst. Vice President.-
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Director -
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Standards Superintendent
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Compliance Engineer.
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Figure 1.
Florida Power Corporation Orr,anization Chart n