ML19341B390
| ML19341B390 | |
| Person / Time | |
|---|---|
| Site: | Columbia, Washington Public Power Supply System, Satsop  |
| Issue date: | 01/14/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| References | |
| NUDOCS 8102020030 | |
| Download: ML19341B390 (5) | |
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QAB Projects Mr. G. D. Bouchey QAB Chron. File Nuclear Safety Director VNoonan, DE Washington Public Power SBryan, IE y
Supply System JConway, QAB
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P.O. Box 968 3
i Richland, WA 99352
Dear Mr. Bouchey:
SUBJECT:
OPERATIONAL QUALITY ASSURANCE PROGRAM DESCRIPTION (WPPSS-QA-004)
We have evaluated Revision 4 (Drafts 2 and 3) to WPPSSr Topical Report WPPSS-QA-004, " Operational QA Program Denription," submitted with your December 1,1980 letter and the Renberger/Haass Scptember 2,1980 letter to determine its con-formance with Appendix B to 10 CFR Part 50. The basis for our review was the SRP (NUREG-75/087 Rev. 1) dated February 1979.
A request for additional infornation relative to this report is enclosed. Your response to the enclosure should be submitted as an amendment (25 copies of affected page changes) to the original report by March 1,1981.
Should you have any questions or if you desire a meeting regarding our review, please feel free to contact Mr. James Conway on (301) 492-7741.
Sincerely.
Originalsigned by Walter P.Hasse Walter P. Haass, Chief Quality Assurance Branch Division of Engineering
Enclosure:
Request for Additional Information
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WASHINGTON PUBLIC POWER SUPPLY SYSTEM (WPPSS-QA-004, Revision 4)
Request for Additional Information 1.
The qualification requirements in Appendix I for the Director Quality Assurance are not satisfactory.
It is an flRC staff position that the qualifications and experience of the Director, Quality Assurance be at least equivalent to those described in Section 4.a.5 of ANSI /ANS 3.1-1978, " Selection and Training of fluclear Power Plant Personnel." In lieu of the above, we would accept a com-mitment to the education and experience described in the following Section 4.4.5 of ANS 3.1-1979:
EDUCATION: 8achelor Degree in Engineering or related science.
EXPERIENCE:
Four (4) years experience in the field of quality assurance, or equivalent number of years of nuclear plant experi-ence in a supervisory position preferably at an operating nuclear plant or a combination of the two. At least one (1) year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program. Six (6) months of the one year experience shall be obtained within a quality assurance organization.
Provide a description to satisfy this position.
2.
It is an NRC staff position that qualified individuals in the QA organization, either onsite or offsite, shall be responsible for performing reviews and concurrina in documents (e.g., procedures / instructions addressing maintenance, calibration, testing, etc.; drawings, specifications, etc.) affecting quality and safety, including changes thereto, prior to issuance. Modify Section 1.3 to address this position.
3.
In Section 1.3.6.1, describe the responsibilities of the Project Quality Assur-ance Manager.
4.
A commitment is made in Section 2.2.1 that "The QA Program... structured to be consistent with... Regulatory Guides as documented in Appendix II...." Quality assurance programs should reflect the degree of conformance to current regulatory and industry guidance. Accordingly, WPPSS's QA program description should be updated to reflect conformance with the regulatory positions provided by the NRC in the following regulatory guides for operational activities including maintenance and modification:
1.8-Rev. 1-R (5/77); 1.26-Rev. 3 (2/76); 1.29-Rev. 3 (9/78);
1.30 (8/11/72); 1.33-Rev. 2 (2/78); 1.37 (3/16/73); 1.38-Rev. 2 (5/77); 1.39-Rev. 2 (9/77); 1.58-Rev.1 (9/80); 1.64-Rev. 2 (6/76); 1.74 (2/74); 1.88-Rev. 2 (10/76); 1.94-Rev.1 (4/76); 1.ll6-Rev. 0-R (5/77); 1.123-Rev.1 (7/77); 1.144 (1/79);and1.146(8/80).
Section 2.2.1 should be modified to address this position. To preclude any mis-interpretation regarding the commitment statement, it is recommended that Section 2.2.1 be revised as follows: Replace "the adopted... documented in..." with
I t i
" comply with the Regulatory Position in the below listed Regulatory Guides.as i
modified in."
In addition, mcdify Appendix II to be in agreement with the above commitment and under the Supply System Position replace " intends to implement the provisions" with " complies with the Regulatory Position " for each respective guide.
5.
Identify those personnel authorized to approve changes to the "Q-list" and describe l
methods for controlling its distribution.
6.
Provide a commitment that the development, control, and use of computer code pro-grams will be conducted in accordance with the QA program and include a descrip-tion of how the QA program will be applied.
1 7.
Give a brief summary of WPPSS's corporate QA policies.
8.
Provide a matrix of existing or proposed QA procedures cross referenced against each criterion of 10 CFR 50 Appendix B.
9.
Describe the organizational responsibilities for preparing, reviewing, approving, and verifying design documents such as system descriptions, design input and cri-j teria, design drawings, design analyses, computer programs, specifications, and procedures.
10.
Describe the provisions which assure that errors and deficiencies in approved design documents that could adversely affect structures, systems, and components important to safety are documented; and action is taken to assure that all error; and deficiencies are corrected.
11.
Describe the guidelines or criteria for determining the method of design verifica-tion (design review, alternate calculations, or test).
12.
The responsibilities of the verifier, the areas and features to be verified, the pertinent considerations to be verified, and the extent of documentation should be identified in procedures. Modify Section 3 to address this position.
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13.
If the verification method is only by test, prototype, component, or feature test-ing should be performed as early as possible prior to installation of plant equip-ment, or prior to the point when the installation would become irreversible, flodify j
Section 3 to address this position.
14.
Procedures should be established to assure that verified computer codes are certi-fied and specified for a particular use. Modify Section 3 to address this position.
15.
Describe the organizational responsibilities, including the involvement of the QA organization, for (1) procurement planning; (2) the preparation, review, approval, and control of procurement documents; (3) supplier selection; (4) bid evaluations; and (5) review and concurrence of supplier QA programs prior to initiation of activities affected by the program.
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_ 16.
Describe the provisions which assure that maintenance, modification, and inspection procedures are reviewed by qualified personnel knowledgeable in QA disciplines (normally the QA organization) to determine:
a.
The need for inspection, identification of inspection personnel, and docu-mentation of inspection results.
b.
That the necessary inspection requirements, methods, and acceptance criteria have been identified.
17.
Describe the organizational responsibilities for the control of purchased material, equipment, and services including interfaces between design, procurement, and QA organizations.
18.
Describe the provisions which assure that the supplier furnishes the following records to WPPSS:
a.
Documentation that identifies the purchased item and the specific procurement requirements (e.g., codes, standards, and specifications) met by the item, b.
Documentation identifying any procurement requirements that have not been met.
c.
A description of those nonconformances from the procurement requirements dis-positioned " accept as is" or " repair."
The review and acceptance of these documents should be described in the purchaser's QA program.
13.
Describe the provisions which assure that suppliers' certificates of conformance are periodically evaluated by audits, independent inspections, or tests to assure they are valid.
20.
Describe the criteria for determining those processes that are controlled as special processes.
21.
Describe the organizational responsibilities for qualification of special processes, equipment, and personnel.
22.
Describe the processes which assure that when inspections associated with normal operations of the plant (such as routine maintenance, surveillance, and tests) are performed by individuals other than those who performed or directly supervised the work, but are within the same group, the following controls are met:
a.
The quality of the work can be demonstrated through a functional test when the activity involves breaching a pressure retaining item.
b.
The qualification criteria for inspection personnel are reviewed and found acceptable by the QA organization prior to initiating the inspection.
23.
Describe the organizational responsibilities for establishing, implementing, and assuring effectiveness of the calibration program.
,- 24.
Describe the provisions for the storage of chemicals, reagents (including control of shelf life), lubricants, and other consumable materials.
25.
Identify those individuals or groups responsible for the disposition of nonconform-ing items.
26.
Describe the provisions which assure that nonconformance reports are periodically analyzed to show quality trends, and the significant results are reported to management for review and assessment.
27.
Describe the organizational responsibilities for the implementation of activities related to QA recor ds.
28.
Page II.1-3, item 2 - Describe the criteria used in distinguishing between major and minor modifications.
29.
Page II.1-4, item 3 - WPPSS's position is not satisfactory.
It is the NRC staff position that verification activities be conducted to assure that items are identifiable and traceable to appropriate documents prior to use. Delete the exception or describe an acceptable alternative.
- 30. Page 11.1-16, item 1 - WPPSS's position regarding the qualifications of individuals responsible for preoperational and startup testing is not consistent with that given in Section 14 of the FSAR (Amendment 7 dated November 1979). Revise item 1 to be consistent with the information, which meets the staff requirements, in Section 14 of the FSAR.
31.
Page II.1-17, item 2 - WPPSS's position is not satisfactory.
It is the NRC staff position that SNT-TC-1A-1975 applies to qualification of personnel performing leak tests.
Delete the exception or describe an acceptable alternative.
32.
Page II.1-18, item 4 - The second sentence is not clear.
It is an NRC staff posi-tion that all individuals performing inspection, examination, and testing activities must be qualified to ANSI /ASME N45.2.6-1978. Delete the exception or describe an acceptable alternative.
33.
Page II.1 The exception should be deleted since the staff has not yet endorsed the 1979 version of ANSI N45.2.9.