ML19312E274
| ML19312E274 | |
| Person / Time | |
|---|---|
| Issue date: | 05/20/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Mills L TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8006040120 | |
| Download: ML19312E274 (5) | |
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';ucicar Regulation and Safety
~.u.essee Valley Autharity 400 Chestnut Street Te..er II Chattanooga, TN 37401 Jaar 'tr. Mills:
SJ3 JECT:
PROPOSED REVISIC.'l 4 TO TVA-TR75-1A Your letter of April 1,1980 pecpesed Ravision 4 to TVA-TR75-1 A, TVA's tcpical report, " Quality Assurance Frc; ram Description."
'..'e have revie..cd the prcposed rnisicn and require additional information before we can ccmplete our review.
Our raquest for additional infonnation is enclosed.
Your response should be submitted directly to me.
Please contact !!r. Jack Spraul of my staff on FTS 392-7741 if you have any questions regarding our request. A meeting may be desirable after you have had a chance to review the enclosure.
Sincerely, 0
0 Sn 6, ? p d 6.r: -
h' alter P. Haass, Chief Quality Assurance Branch Division of Engineering Encicsure:
Request for Additional Infcrmation cc w/ enclosure:
S. Kammer, TVA 8006040\\
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TVA-TR75-1 recpesed Revisicn a 3
j Recuest for Additional Information
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1.
The proposed revision to TVA-TR75-1 includes a new term, " fuel-related ccepcnents."
The QA responsibilities for these cceponents are assigned to the Division of Fuels which tpparently has no QA organization, per se.
Idantify what items fall within the category of " fuel-related crpor.ents," and discuss the involvement (or justify 4
the lack of same) of TVA's QA organization (s) in the QA program for these items.
Also, page 17.2-7 assigns the responsibility for " qualifying vendors for supply-i ing nuclear fuel and fuel-related compenents" to the nuclear Fuels Planning Branch.
Discuss as above the involvement of TVA's QA organization (s) in this activity.
2.
The paragraph which ends at the top of page 17.2-11 indicates that the Chief, QA Staff reviews and concurs with plant standard practices which "implament the re-i quirements of the 0QAM." Item V of Table 17.2-2 is similar. Howa,er, the TVA
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letter of January 30, 1930, indicates he reviews and concurs with plant standard practices which " affect qualitv." Discuss the difference, if any, in these ccmmit-ments.
3.
Withcut an organization chart of the Nuclear Power Quality Assurance Staff, it is not clear whether the Chief, Quality Assurance Staff mentioned at the top of page i'
17.2-11 is or is not the same as the Supervisor, Quality Assurance Staff mentioned in the next paragraph.
Please clarify.
4 TVA-TR75-1 states that the Plant Quality Assurance Staff is responsible for certi-i fying plant personnel who perform receiving inspection.
The preposed Revision 4 states that they may either certify or verify certification (page 17.2-13).
It is the staff position that personnel outside quality assurance who perform QC j
functions be certified by quality assurance.
Indicate that TVA meets this position l
or provide an alternative for our evaluation.
See also part 17.2.7.4 concerning certificaticq of tho.,a performing receipt inspection.
Discuss the involvement of the Manager of Power and the Assistant Manager of Power in the operational quality assurance program.
6.
Discuss the s1591ficance of the second change indicated on page 17.2-18 of Rev. 4 i
which states that NUC PR is responsible for " reviewing inspection and testing requirements" whereas Rev. 3 stated the P PROD is responsible for " reviewing verification inspecticn and testing."
7.
Discuss the significance of the third change indicated on page 17.2-18 of Rev. 4 which states that "CSSC modificatiens shall be received by the PORC" whereas Rev.
3 states that "all modifications shall be reviewed by the PORC." Also, in the
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last paragraph, discuss the change to "or approved documents" from " equipment manuals, or vendor drawings" which require a DCR or FCR for prcposed modifications.
8.
Discuss the significance of the change on page 17.2-23 of Rev. 4 which states that an affected organization shall "cencur with the proposed procedure or instruction" nhareas Rev. 3 states it shall " review and evaluate the proposed procedure or in-struction and submit in writing their connents and/or concurrence to the originating organizatien before issuance and approval."
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. 9.
The fcurth naragraph on cage.17.2-24 of Rev. 4 indicates that "docu: rents are 2.ailacle at de location during perfcreance vf the wark."
Clarify that the Rments will be at the legaticn where the activity will be perfor. ed prior to c - sncing t's. sri.
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'i".h pc.a;: xh cn ;ge 17.? ?
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- indicates that '.4 FR receins u-
..:ilt drL.irgs frm CC';57 n;m rec 3f;t of the cpara ting licen:e.
Mscribe h<.
W C FR verifies the 5ccuracy of th2se den ings.
Rev. 4 implies that EN DES is not responsible for as-built drawings af ter tha cperating license has been re-caived. Clarify shether this is indeed the case.
Describe in more detail hcw as-built drawings are naintained currant and the checks and balances on this activity, 11.
Cescribe the centrols.~hich prevent the use of an itan which is installed befcre receipt of associated docu::antation.
12.
Indicate the involva: ent of the ';UC FR quality assurance personnel in the approval of contractors' quality assurance programs as specified in the fourth paragraph on page 17.2-34 13.
Discuss the significance of the rewrite of the first paragraph of part 17.2.14 14.
Discuss the significance of limiting tests performed per instructicns reviewed by the PORC and approved by the plant superintendent to " operational" tests as was done at the top of page 17.2-40.
15.
Discuss the significance of the new and revised exceptions to ANSI N45.2.12 (Craft 3, Rev. 4 - February 1974) given on shcet 5 of Table 17.2-5.
16.
Define " active records" as used on sheet 6 of Table 17.2-S.
- 17. Numerous deleticns from the operations portien of the NRC approved version (Rev.
- 3) of the TVA topical report on quality assurance have been nade.
In total, these deletions appear to weaken the ccmmitments. Please reinstate or justify the dele-tions quoted below:
Rev. 4 Page Deletion 17.2-1 "The Manager of Power has overall responsibility for quality assurance during startup and operation of the plant."
(If this responsibility is assigned to someone else, indicate to whom by position title.)
17.2-4 The QA Manager develops, coordinates, and maintains the "Cpera-tional Quality Assurance Program."
(item k) 17.2-5 The Quality Audit Secticn is responsible for conducting "preaward surveys."
17.2-5
" Reviewing supplier and contractor quality assurance programs."
17.2-6 Section 4 Training.
_?ev. 4 Fage Deletion 17.2-11 The Supervisor, Quality Assurance Staff's primary respcnsibility is to assure that the " quality assurance program for operaticn and maintenance of TVA nuclear plants fulfills the NRC and the Office of Pcwer requiremants for quality assurance."
17.2-13 List of responsibilities of the FORC.
17.2-14 The plant quality assurance staff's responsibility to advise the plant superintendent of "'ailure of plant equiprent to meet tech-nical specification requirements or other" ncnccnforming aspects of cperations.
17.2-16 "The requirements of the Office of Pcwer Quality Assurance Program also apply to instruments and devices used in the measurement of the official perscnnel radiaticn dose and to the equipment used to calibrate them."
(Top of page 17.2-17 of Fev. 3.)
17.2-16 "This training program shall provide seminars to present TVA's quality assurance program internally and industry-sponsored training courses or schools to train and maintain the proficiency of quality assurance personnel."
17.2-16 Proficiency is maintained "by retraining, reexamining, and/or rece rti fyi ng. "
(item d) 17.2-16 Reference to part 17.:^
.n part 17.2. 3. 3.
17.2-22 "Frocedures shall be...itten to provide a un' form method within the Office of Power for preparing, reviewing, changino, and approv-
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ing procedures and instructions."
17.2-22 The plant superintendent approves, issues, and controls " changes to plant instructions and drawings."
17.2-22 "The plant quality assurance staff supervisor prepares and imple-ments site quality assurance instructions for the performance of his assigned functions."
17.2-24 The recipient of revised documents shall " discard" obsolete copies.
17.2-26
" Proposals (bids or quctations) by suppliers are reviewed to ensure that no exceptions are taken which would violate safety or quality requirements."
l 17.2-27
" Additionally, the Quality Assurance and *udit Staff may independently conduct inprocess inspections of suppliers of major CSSC items."
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Rev. 4 osce Deletion i
17.2-27 All inspections and audits are conducted "in accordance with accepted standards for this activity."
i 17.2-32 Control of the " calibration" program.
17.2-33
" Additional conitoring of plant activities is provided by audits i
of the Office of Power Quality Assurance and Audit Staff cn a
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periodic basis."
j 17.2-33 "The U_uclear Fuels Quality As;urcnce Manual documents the require-j r.ents for surveillance inspections at vendor facilities during
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fuel procurarent."
I 17.2-35 The plant quality assurance staff "shall review to ensv ~ the incorporaticn of ce reference to the proper requirement Jud acceptance limits."
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17.2-36 Controlled measuring and test equipment is to be used on CSSC items "or supporting items" of TVA's plants.
17.2-45 The recceds control system " meets applicable codes and standards" and includes a records checklist designating the required quality assurance records "(those records sufficient to furnish objective evidence of activities affecting quality)."
i 17.2-47 The Quality Audit Supervisor is responsible to analyze audit data "for quality trends and effectiveness of quality assurance."
17.2-48 Audit procedures " require evaluation of work areas, activities, processes, goods, services, and the review of documents and records for quality-related practices, procedures, and instructions to determine the effectiveness of the implementation of the Office of Pcwer Quality Assurance Program and compliance with 10 CFR 50, Appendix B."
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17.2-48 A designated leader shall be responsible "to assure that unsatis-factory ccnditions are resolved."
i Table 17.2-5 The TVA operations division would " refer to the construction I
(Sheet 6) division for actual work performance."
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