ML20003F880
| ML20003F880 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Mills L TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8104230812 | |
| Download: ML20003F880 (3) | |
Text
.
o 4
s DISTRIBUTION:
~
vCentral File NRC PDR APR 141981 LPOR NSIC QAB Projects QAB Chron. File CUpright, RII MPeranich, IE Mr. L. M. Mills, Manager JSpraul, QAB
, :, j Nuclear Regulation and Safety
[
/
Tennessee Valley Authority N
//
T'c 400 Chestnut Street Tower II Chattanooga, TN 37401
/ g @g V
7
&.8xJ' 0 C'
v c-
Dear Mr. Mills:
a^
e
SUBJECT:
PROPOSED REVISION 5 TO TVA-TR75-1 A 1>
b, Your letter of March 4,1981 proposed Revision 5 to TVA-TR75-1A, I
report, " Quality Assurance Program Description." We have reviewed the proposed revision and require additional information before we can complete our review.
Our request for additional information is enclosed. Your response should be submitted directly to me. Please contact Mr. Jack Spraul of my staff on FTS 492-7741 if you have any questions regarding our request.
A meeting may be desirable after you have had a chance to review the enclosure.
Sincerely, Original signed by l
Walter P. Haass Walter P. Haass, Chief Quality Assurance Branch Division of Engineering
Enclosure:
Request for Additional Information cc w/ enclosure:
S. Kaniner, TVA
.. G
') y
- ~cn[CE:CAS
.. II ) \\
r g
~ r> JSpraul:cg WPHaass
- <:)
4,/ / A/81 4/ /81
.m.
.. ~
1
=-.:s_=.z::=.: c
=.
E 104 2'A0
REQUEST FOR ADDITIONAL INFORMATION TVA-TR75-1, Rev. 5 1.
The top of page 17.0-4 has a new sentence that states: "TVA may unilaterally delete, add, or renumber those (interdivisional) procedures (in Table 17.0-1) without revising Chapter 17 of the SAR, but will maintain the same overall pro-gram coverage." We do not advocate revising Chapter 17 of the SAR merely to reflect changes in Table 17.0-1, but it is the staff position that Table 17.0-1 should be updated when TVA-TR75-1 is revised (as has been done in the past).
Commit to meet this position or provide an alternative for our evaluation.
2.
The last paragraph of 17.l A.l.l.1 states that the Manager of EDC receives reports relating to quality assurance (underline added).
Indicate what is done with these reports.
3.
Revision 5 deleted the excerpt from the Manager of OEDC's QA Manual regarding the objective of TVA's QA program for design and construction. Replace the deletion or provide a brief summary of TVA's QA policies, goals, and objectives. Note that the last sentence on page 17.0-2 still refers to the deleted excerpt.
4.
In Section 17.lA.l.l.2, Revision 5 appears to have eliminated the QA Manager's functions listed in items 7, 8,10,12,13,14,19, 20, and 21 of the accepted version of the topical report.
Discuss. Also discuss the significance of the word " selected" in item 4 in Section 17.l A.l.l.2 which states that the QA Manager reviews and approves " selected procedures...."
5.
In Section 17.l A.l.l.3, Revision 5 appears to have eliminated the Quality Require-ments Section Supervisor's responsibility to maintain a quality trend analysis program and evaluate division QA training programs.
Discuss.
The first paragraph of 17.l A.l.l.4 states that the Supervisor, Quality Compliance 6.
Section, is responsible for " reviewing divisions' actions for correcting repeated significant deficiencies" (underline added).
It appears this position should review corrective actions for all significant deficiencies without waiting for them to be repeated. Clarify.
7.
Justify the apparent dissolution of the OEDC QA Committee. (See 17.lA.l.l.4 of the approved topical report.)
Section 17.lA.1.1.l(2) states that the Manager of Engineering Design is respon-8.
sible for " engineering, design, and procurement...," while Section 17.lA.l.2 states that the Division of Engineering Design is responsible for the quality assurance program for only " design and procurement." Clari fy.
Discuss the significance of the word " selected" in items 6 and 8 of Section 17.1 A.l.2 9.
which state that EN DES reviews " selected" manufacturer's drawings, procedures, and test results...and that EN DES reviews " selected" construction test results.
Clarify to whom (by position title) the EN DES QA Emch Chief and the EN DES QE 10.
The staff position is that these positions should report at Branch Chief report.
th same or higher organization level as the highest line manager directly respon-siale for performing activities verified by these branches (by review of proce-dures and other controlling documents such as purchase orders, drawings, and specifications; by audits; by surveillance; etc.). The clarification should meet this position or provide justification for the proposed alternative.
. 11.
Item 3 on page 17.l A-6 of the proposed revision states that the EN CES Quality Assurance Branch audits EN DES "(except where conflict of interest may exist...)."
Clarify in the parentheses what organization is responsible to audit where such conflicts exist. Also clarify what is meant by "EN DES O_A procurements" and A
"CONST 0_A_ procurements" found in item 4 on this page (uncerline added).
- 12. Section 17.lA.l.2.3 refers to figure 17.lA-4 and speaks of a " central quality sur-veillance staff." The figure shcus a " central quality control staff " Clarify.
Also discuss the effect of eliminating quality centrol inspections at suppliers, eliminating stop work authority at suppliers, and apparently relying solely on surveillance and audits for supplier control.
- 13. The approved topical report states that the EN CES Quality Engineering Branch is responsible to assure that "an adequate quality control records system and records are maintained to meet quality assurance and technical requirements...." Identify what organization has this responsibility now.
14 In revising Section 17.lA.l.2.2.1 of the approved topical report to Section 17.1A.I.2.2 of Revision 5, it appears that items 4, 5, 6, 9, and 13 of the QA organization's responsibilities have been eliminated. Discuss.
15.
Clarify which T/A anization now has the responsibility, previously assigned to the Nuclear Plant
- ensing on page 17.lA-14 of Revision 4, to distribute "NRC regulations, regtJ.atory guides, reports of incidents at operating reactors, and other documents centaining NRC requirements and guidance to organizations within OEDC wnich may be affected by those requirements."
- 16. Section 17.lA.1.3.1.7 is headed, " Supervisor, Quality Assurance Unit," while Figure 17.A-8 has a block titled " Supervisor Site QA Unit." Clarify. Also explain the significance of the dashed line between the "Proj. Mgr. Site" block and tne
" Supervisor Site QA Unit" block on this figure.
17.
Identify the organization responsible for perfonning site quality control activi-ties (inspection / verification) during the construction phase and discuss the func-tioning of this organization in this regard.
18.
Discuss the stop work authority of Site Quality Assurance Unit perscnnel.during the construction phase.
- 19. Show the Quality Engineering Branch on Figure 17.lA-1 or justify not doing so.
20.
Provide a commitment to notify NRC-QAB of changes (1) for review and acceptance in the accepted QA pecgram description in T/A-TR75-1 prior to implementation and (2) in organizational elements described in T/A-TR75-1 within 30 days af ter an-nouncement.
(Nonsubstantive personnel reassignments and editorial changes do not require NRC-GA3 notification.)
i l
21.
By letter of Decemoer 9,1980, T/A infor:ud us of a change which you plan to in-corporate into T/A-TR-1A. The propcsed change is accectable provided that P PRCD l
concurs with "the detailed construction test pro:cdures" before they are implemented.
Since construction tests are perfomed as prere?. '3ites for the preoperational l
testing program and since preoperational tests ce conducted under the direction of P PROD, the P DROD concurrence should assure that the construction tests do i
actually satisfy the prerequisites for the preccerational tests. When revising
- ne topical report in this regard, incorporate tnis position or provide an alternative for our evaluaticn.
_