ML19347E550
| ML19347E550 | |
| Person / Time | |
|---|---|
| Issue date: | 04/29/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19347E545 | List: |
| References | |
| IAEA-SM-253-33, NUDOCS 8105120594 | |
| Download: ML19347E550 (8) | |
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IAEA-SM-251/33 UPGRADING OF QUALITY ASSURANCE PROGRAMM\\ TIC REQUIREMENTS FOR OPERATING NUCLEAR POWER PLANTS ABSTRACT As a result of analysis of the TMI accident and experi-ence at several construction sites for nuclear power plants, the NRC staff has concluded that certain quality assurance programmatic modifications relative to presently existing requirements should be made. These modifications are direct-ed toward upgrading and strengthening the quality assurance function at operating nuclear power plants to improve its effectiveness in icentifying and correcting operational de-ficiencies to protect the public health and safety.
Spect-fic areas of QA programatu upgrading include:
1.
Improving management attitudes toward quality a:surance.
2.
Expanding the category of structures, systems, and cTiponents to which the QA program applies to include all items that affect safety.
3.
Improving the organizational independence of the QA function from the performing functions.
4.
Increasir.g QA staffing levels and qualification requireraents for QA personnel.
5.
Increasing the involvement of the QA organization in the inspection and verification of operational activities.
6.
Increasing the involvement of the QA crganization in the review and approval of quality-affecting documents.
The NRC has developed new requi ements in the above areas and has initiated implementation on TMI-l (Restart) and several other operational units at sites located near high population density areas.. It is ultimately planned to require implementation of these new requirements for all nuclear plants under design and construction as well as in opera tion. These and other new requirements are also con-templated for implementation on new plants under design and construction.
8105120N'
t IAEA-SM-253/33 As a rasult of the analysis of both the TMI-2 accident and recently found quality assurance deficiencies at con-struction sites for new nuclear power plants, the NRC staff has identified several areas of programatic requiremer.ts needing upgrading to provide greater confidence in the effec-tiveness of quality assurance (QA) programs for operating nuclear power plants. The areas of upgrading are intended to provide oveall strengthening of the QA program by expand-ing its formal cover' age to additional items and activities, by improving its organizational independence, by improving staffing levels and qualifications of personnel, and, last but certainly not least, by emphasizing the need for licen-see management to recognize the value of, create, and main-tain an effective QA program. Because of the rather general nature of the criteria of Appendix B to 10 CFR Part 50, none of the upgradings require revision to the Regulations other than a clarification of certain language regarding the struc-tures, systems, and components to chich the QA program ap-plies.
The specific areas of upgrading for QA programs have been identified in Task I.F. of the TMI Action Plan (NUREG-0660) for nuclear plants under design and construction as well as operational. Several of the more significant areas have been selected for earlier application to specific fa-cilities than is otnerwise called for by the Action Plan schedule.
Manaoement Attitude Toward Quality Assurance The attitude of the licensee's management toward quality assurance is Sf utmost importance to the success or failure of the QA Progra.
Only with a clearly positive attitude toward quality issurance transmitted from top management can an cf4ctive QA program be created and im-plemented. Too many utilities still view quality assurance as a costly and overdone " paper-mill" rather than a neces-sary and cost-effective management control tool. A properly formulated and implemented QA program can assure a highdr degree of plant safety and reliability than would otherwise exi s t.
Quality assurance should permeate all 'evels of management including their active involvement ar.d should enjoy a strong commitment from above to provide the maximum potential for full effectiveness. The key activity areas l
where top management involvement should occur are as follows:
a.
Formulating the company's basic quality assurance policies, goals, and objectives.
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Establishing a highly qualified quality assurance organization with the necessary authority, organi-zational freedom, freedom from cost and schedule pressures, staffing levels, and management backing.
Backing by management should confirm to all company personnel that the tenets of the QA program will be enforced.
c.
Periodically assessing the scope and implementation of the QA pmgram to assure it is satisfying com-pany objectives.
The QA program, including the organization for its im-plementation, must have the unqualified support and backing by all levels of management, and this attitude must be clearly demonstrated to the plant working level personnel.
Extension of the QA program to All items Affecting Safety Up to the present time, the applicability of the QA program conforming to Appendix B requirements was limited to those structures, systems, and components needed to pre-vent or mitigate the consequences of postulated accidents that could cause undue risk to the public health and safety.
Other items in the plant that had a lesser significance to safety were subjected to the provisions of General Design Criterion 1 of Appendix A to 10 CFR 50. Until now, the NRC staff has not developed specific guidance regarding the quality assurance requirements for the latter grouping of i tems.
However, given the impetus of the TMI-2 accident in which several plant systems and components not subjected to the Appendix B QA program played an important role in the accident scenario, it became clear that such gt'idance is needed and could be readily made available by simply expand-ing the applicability of the QA program to include all items affecting safety. These items have a regulatory base in that they can be derived from the General Design Criteria given in Appendix A to 10 CFR 50 and from other pertinent regulations and include Regulatory Guide 1.29 (Positions 1 through 4) plus spare and replacement parts, and consumables and expendables needed for the various activities performed in connection with those items.
Initiating such a require-ment at the operating license stage means that the opera-tional QA program would be applicable to all future activi-ties (t ackfit not required) conducted in connection with these items such as maintenance, modification, repair, per-fonnance testing, surveillanc2 testing, and replacement.
As required by Criterion II, " Quality Assurance Program" of Appendix B to 10 CFR 50, the QA program shall provide con-trol over all activities affecting the quality of the iden-tified items to an extent consistent with the item's impor-tance to safety.
In this regard, it is expected that the
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extent of applicability of the 18 criteria of Appendix B and related requirements given in the SRP, Regulatory Guides, and endorsed standards to a specific item shall be determined
~ through a technical evaluation conducted by the Engineering and QA functions. - In this way, a meaningful and efficient QA program can be established whose purpose is to assure that the specified design requirements and subsequent acti-vities affecting safety for an item are properly implemented.
Extension of the QA program to all items important te safety should provide greater assurance of the proper atten-tion to all safety ' aspects of the plant thereby contributing to improved operational safety.
Oroanizational Indeoendence In the past, _ organizational relationships for operating plants have been found acceptable in which the onsite quality assurance (QA) and quality control (QC) personnel functioned in separate portions of the organization and re-ported either directly or indirectly to the Plant Manager.
While the QA and QC functions were accomplished by person,
nel other than those who perfomed the work, there is con-cern regarding whether sufficient independence exists from the pressures of cost and schedule attendant in maintaining a plant in an operational mode. To alleviate this concern, the independence of the QA/QC function has been strengthened by requiring the QA organization to assume responsibility for all onsite QA activities through implementation of the necessary review, inspection, surveillance, and audit func-tions. The quality control function would, therefore, be the responsibility of the QA organization.
Further, the onsite QA organization should report technically and adminis-tratively to offsite QA management, and pe.sonnel responsi-ble for performing the QA/QC functions should in turn report both technically and administratively to the QA organization.
To assure that the QA organization performs its function in a timely manner, close communication ties (e.g., daily staff meetings) shall be mair.tained with the Plant Manager and his s taff. We believe that such an organizational arrangement can materially assist in establishing a stronger and there-fore more effective QA function.
1 QA Staffing and Qualification Requiremen~cs One of the reasons for the lack of proper implementa-tion of QA programs as determined through analysis of QA 4
deficiencies at several construction sites, and discussions with some licensees and IE inspectors is an inadequate staff in terms of both manpower levels i.nd qualification require-ments for personnel. For this reason, necessary QA tasks may be left undone or done in an inadequate manner.
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~o response to this weakness in implementation, greater empha-sis is being placed on the need for identifying specific tasks be to performed, the level of qualification and certi-fication required for the assigned tasks, and the staff size necessary to perform the tasks. Special operational activi-ties such as maintenance, modifications, refueling and inser-vice inspection will require augmented staffing levels. As mentioned above, close communication between the QA organi-zation and the operating staff must be established through frequent meetings and coordinated advance planning to assure the timely availability of the required number of properly qualified QA personhel at the job site. Greater emphasis is alsu being placed on the qualifications and training for QA personnel to assure appropriate educ tional levels including the need for an engineering degree, certified professional engineer in QA, certified ASQA-QA engineer, or other related formal and on-the-job training.
Training would also encom-pass instructions in the specific activities to which indi-viduals are assigned such as knowledge of the governing docu-ments; the performance of inspections, examinations, and tests; and familiarity and knowledge of the instructions for the various areas affecting quality such as instrumentation and calibration control, control rocm operations, radiation, technical specifications, electrical and mechanical systems, fuel handling, etc. Proficiency of QA personnel should be determined by appropriate testing and the level of qualifi-cation maintained by retraining and/or reexamining or recer-ti fying. The overall intent of these requirements is to assure that QA personnel are not only available, but also fully qualified and knowledgeable to perform the ne:essary QA functions.
Involvement of QA Orcanization in_ Ocerational Activities
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Both onsite and offsite elements of the QA organization should be actively involved in all the operational aspects of a nuclear power plant that affect safety. Up to now the QA involvement has been at best inconsistent and minimal in certain areas with the result that the effectiveness of the QA program has not attained desired standards. The extent of involvement should vary as determined by the licensee's technical and QA personnel in accordance with the specific activity and its effect on plant safety and the complexity of the related QA requirements. Respe.sibilities of the QA organization should include the follching:
a.
Surveillance and verification of pre-operational, startup, and operational, tests, maintenance, modi-fications, and quality activities' to assure con-formance with tachnical specifications, and inser-vice inspection and testing requirements.
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Review of procurement documents to assure the necessary QA requirements are specified, ar.d inspection of received items.
c.
Training and indoctrination of r.lant personnel responsible for performing quality-affecting acti-vities involving safety to assure demonstrated pro-ficiency and capability to perform assigned tasks (not including plant operators).
d.
Surveillance and verification to assure that in-strument c'alibration programs are conducted in accordance with procedures and specification requi rements.
e.
Over-view of the inservice inspection program.
f.
Active involvement (e.g., frequent visits to the plant site) by the offsite QA Manager to monitor the implementation of the QA program and to assist in the resolution of quality-related problems.
g.
Participation by the onsite QA/QC personnel in daily staff meetings (e.g., operation, maintenance, modification) associated with planning the work and schedules for the plant to assure proper QA and QC staffing levels and quality-related proce-dures for operational, maintenance, modification, and inservice inspection activities.
h.
Performing an overall assessment of the effective-ness of the QA program which involves developing and evaluating trend analysis, and promulgating and modifying QA policies and procedures as neces-skry.
Involvement of the QA organization to accomplish the i
above functions is fundamental and essential to gain confi-dence and credibility in assuring plant safety through pro-per implementation of operational activities.
0A Involvem9nt in the Review /Acoroval of Documents Affecting Safety, Qualified individuals in the CA organization, either onsite or offsite, should be held responsible for perfonning reviews of documents affecting operational safety of plants and for granting approval of these documents relative to QA requirements. Again, up to now, the QA involvement in this regard has been at best inconsistent and minimal with the result that the application of QA controls tu many activities
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i affecting safety has not reached desired levels. Examples of documents that should be subject to QA review and approval include administrative directives and procedures addressina operations, maintenance, technical specifications, inservice inspection and testing,.nodification, calibration, testing, fuel handling, and procurement; design change notices; drawings; spec 4fications; and nonconformance and corrective action reports. 'Each document should be reviewed to a depth sufficient to assure that applicable QA requirements (e.g.,
the necessary inspection requirements, final documented veri-fication of implemented procedures and check lists, methods, and acceptance criteria) have been identified and specified therein. Evidence of the review shall be documented by approval of the QA reviewer.
Involvement of the QA organization in the review and approva' of all operational documents that have an affect on safety should provide greater assurance that activities addressed by these documents are subject to appropriate QA controls and are properly perfomed.
QA for Desian and Construction With regard to nuclear plants under design and construc-tion, the NRC staff is also engaged in u;, grading the appli-cation of QA requirements similar to that discussed above.
Many of these improved requirements stem from detailed analysis of programmatic and implementation deficiencies recently identified at construction sites.
Areas that will receive particular attention inc~.ude:
a.
Expanding the category of structures, systems, and components to which the QA program applies to include all items affecting safety.
b.
Ensuring improved independence of the organiza-tion perfoming checking functions from the per -
fanning organization.
c.
Improving management control of the QA function at construction sites by requiring appropriate management levels to be full time at the site.
d.
Participation of QA personnel in the review anc approval t.f quality-related procedures fer design, ccnstruction, and installation.
e.
Establishing criteria for assigning QA require-ments to specific classes of equipment.
f.
Establishing minimum qualification requirements for all QA and QC personnel.
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Assuring the availability of sufficient staffing levels commensurate with duties and responsibilities.
h.
Establishing procedures for preparation and main-tenance of "as-built" documentation in a timely manner.
- i. Defining in a clearer manner the role of QA in design and analysis activities.
Summary and Conclusion NRC staff analysis of the TMI-2 accident and of defi-ciencies noted at construction sites for new nuclear plants
- has resulted in the identification of several QA program-matic areas that should be emphasized and upgraded to im-prove the effectiveness of QA programs. Areas-of improve-ment have been identified for operational nuclear plants and for those new plants under design and construct on.
i The' process for implementation of these requirenw s has been initiated for :everal selected operational p ants, for the several near term CP plants, and for the one licensee-to-manufacture application for which approval was delayed as a result of the TMI-2 accident.
The NRC views quality assurance as an extremely vital management tool to assure the proper implementation of design, construction, and operational requirements and activities to protect the health and safety of the public.
It is, therefore, necessary that an effective QA program be established and implemented to accomplish this objective.
The NRC believes that the areas of QA pregrammatic involve-ment discussed herein will materially assist in strengthen-ing the QA program to achieve this objective.
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