ML19310A162
| ML19310A162 | |
| Person / Time | |
|---|---|
| Issue date: | 05/14/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Davis W BECHTEL GROUP, INC., BECHTEL POWER CORP. |
| References | |
| NUDOCS 8006060209 | |
| Download: ML19310A162 (2) | |
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MAY l 41980 Mr. W. K. Davis, Vice President Planning & Quality Assurance, TP0 Bechtel Power Corporation P.O. Box 3965 San Francisco, CA 94119
Dear Mr. Davis:
SUBJECT:
INTERDISCIPLINARY REVIEW DOCUMENTATION In an inspection report dated September 24, 1979, NRC's Region IV issued a report of the August inspection of the Gaithersburg Power Division of Bechtel. One of the unresolved items of that inspection was:
" Exception No. 4 to R.G. 1.64, Revision 2, contained in Topical Report BQ-TOP-1, Revision 2A, appears to allow the dis-carding of records of internal interface reviews and may oe a deviation from the record retention requirements of ANSI N45.2.9."
We have recently developed a position statement on the subject (enclosed), and it is not clear that Bechtel's topical report on quality assurance, BQ-TOP-1, meets this position. Please revise BQ-TOP-1 Section 3, " Design Control," such that it is clear that the Bechtel Power Corporation does meet the enclosed position.
In order to further clarify Bechtel's design control program as described in BQ-TOP-1, we suggest that Section 3 include a flow chart that identifies each step of the design process from the establishment of the design requirements / criteria to verification of the design including subsequent design changes. Points at which a quality assurance function is performed should be identified on the chart.
We appreciate your attention to this subject and look forward to the further revision of BQ-TOP-1.
If you have any questions on this or would like to meet to discuss it, please call Mr. Jack Spraul of my staff on (301) 492-7741.
Sincerely,
($
W Walter P. Haass, Chief Quality Assurance Branch Division of Engineering
Enclosure:
QAB Interpretation No. 12 cc w/ enclosure:
J. Amaral 800606006]
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QAB INTERPRETATION Statement No. 12
Subject:
INTERDISCIPLINARY REVIEW DOCUMENTATION Inquiry:
Criterion III of Appendix B to 10 CFR Part 50 requires that measures be established "for coordination among participating" sufficient records design organiza-tions." Criterion XVII of Appendix B requires that shall be maintained to furnish evidence of activities affecting quality."
We have been asked the extent to which n,A records must be maintained to reflect the review comments from disciplines other than the originator's discipline. The inquiry referred to documenting interdisciplinary reviews conducted during the development of a design (per part 5 of ANSI N45.2.ll-1974) and not to reviews which may be made as part of design verifica-tion (per part 6 of ANSI N45.2.ll-1974).
Discussion: A meeting of NRC personnel was held on December 6,1979, to discuss the above subject. Attendees represented IE (R. Brickly, Reg. IV and M. Wilbur, DROI), SD (W. Campbell, DES), and NRR (W. Haass, QAB; J. Gilray, QAB; F. Liederbach, QAB: and J. Spraul, OAB). The concensus of the meeting attendees is reflected in the following response.
Response
There must be documented evidence of the acceptability of design docu-ments or portions thereof, prior to release, by organizations (material, stress, physics, mechanical, electrical, concrete, etc.) providing inter-disciplinary reviews. The signature or initials of those who determine the acceptability of the design relative to their respective disciplinary area of concern should be on the document or on a separate form traceable to the document. A document that indicates the reviewers' comments need not be retained. The interdisciplinary review record (and records of other reviews, such as external interface reviews) must be retained for the life of the item for each revision of the design document. The need for interdisciplinary review is a function of the complexity and degree of involvement of other disciplines and must be specified in written proceduras.
Design verification may also involve design review by more than one discipline. Documentation of this design review should be in accordance with parts 6 and 10 of ANSI N45.2.11-1974.
May 13, 1980
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