ML20038A955
| ML20038A955 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/20/1981 |
| From: | Spraul J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20038A943 | List: |
| References | |
| NUDOCS 8111240515 | |
| Download: ML20038A955 (23) | |
Text
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n t { 2ul &' L UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of TEXAS UTILITIES GENERATING
)
Docket Nos. 50-445 COMPANY, ET AL.
)
50-446 (Comanche Peak Steam Electric 4
Station, Units 1 and 2)
)
NRC STAFF TESTIMONY OF JOHN G. SPRAUL REGARDING OPERATING QUALITY ASSURANCE (B0ARD QUESTION NO. 2)
Q.1. State your name and occupation.
A.I. My name is John G. Spra> 1.
I am employed by the U.S. Nuclear Regulatory Commission as a Senior Quality Assurance Engineer (Nuclear) in the Quality Assurance Branch, Office of Nuclear Reactor Regulation.
Q.2. Please describe the nature of the responsibilities you have had with i
I respect to quality assurance programs of applicants for nuclear facility licenses.
A.2. During the past 7 years, I have been responsible for the review and i
I evaluation of quality assurance programs for the design, construc-tion and operation of numerous nuclear power plants as proposed and j
submitted by the applicants for each such facility.
Q.3. Have you prepared a statement of professional qualifications?
A.3. Yes. A copy is attached to this testimony, i
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PDR ADOCK 05000g4
o 4 Q.4. Have you reviewed and are you f&niliar with the Applicants' quality 4
assurance program and the provisions for quality assurance audits, and with the NRC Staff's evaluation of these issues as set forth in Section 17 of the Staff's " Safety Evaluation Report Related to the Operation of Comanche Peak Steam Electric Station, Units 1 and 2" (NUREG-0797, July 1981) (SER) and in Section 17 of the Staff's
" Safety Evaluation Report Related to the Operation of Comanche Peak I
Steam Electric Station, Units 1 and 2" (NUREG-0797/ Supplement No.1, j
October, 1981) (SSER)?
A.4. Yes. A copy of Section 17 of the SER and Section 17 of the SSER is attached to this testimony.
Q.5. To the best of your knowledge and belief, are the statements set forth in Section 17 of the SER and Section 17 of the SSER true and correct?
1 A.S. Yes.
l Q.6. What is the purpose of this testimo~ny?
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A.6. The purpose of this testimony is to respond to Board Question No. 2 related to the Applicants' quality assurance program and provisions I
for quality assurance audits.
$0ardQuestionNo.2readsas i
follows:
Applicant and Staff should describe in detail the operating quality assurance program for CPSES.
A description of the provisions for conduct of QA audits should be provided, l
including a description of how reactor operations and reactor
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operator training will be audited.
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Q.7. Please describe the operating quality assurance progro., for the Cunanche Peak Steam Electric Station.
A.7. The quality assurance program far the Comanche Peak Steam Electric Station (CPSES) is set forth in the Applicants' Corporate Quality Assurance Program Manual, which establishes the general quality assurance policies and requirements to be implemented at the facility.
These policies and requirements are implemented by the CPSES Operations Administrative Control and Quality Assurance Plan, which is reviewed end approved by the Manager, Quality Assurance and by the Manager, Plant Operations. The plan establishes the quality requirements and controls to be implemented during station opera-tions and defines the responsibilities, authority, and measures for the control and accomplishment of activities affecting the quality and operation of safety-related structures, systems, and components.
It is structured to be in accordance with Appendix B to 10 C.F.R. Part 50 and with the provisions of the NRC regulatory guidance shown in Table 1, attached hereto.
The plan, coupled with the quality assurance program description in the Applicants' Final Safety Analysis Report (FSAR), forms the foundation upon which the overall quality assurance program is formulated and describes how the requirements of Appendix B to 10 C.F.R. Part 50 are satisfied.
These documents control quality-related activities involving safety-related items to satisfy the requirements of Appendix B to 10 C.F.R. Part 50.
Procedures which implement the requirements of the plan are to be reviewed by the Operations Quality Assurance Supervisor and approved by the Station Operations Review Committee.
The plan requires that quality assurance documents encompass detailed controls for: (1) translating codes, standards, and regulatory requirements into specifications, procedures, and instructions; (2) developing, reviewing, and approving procurement documents, including changes; (3) prescribing all activities which affect quality by documented instructions, procedures, or drawings; (4) issuing and distributing approved documents; (5) purchasing items and services; (6) identifying materials, parts, and components; (7) perfonning special processes; (8) inspecting and/or testing material, equipment, processes, or services; (9) calibrating and maintaining measuring and test equipment; (10) handling, storing, and shipping of items; (11) identifying the inspection, test, and operating status of safety-related items; (12) identifying and dispositioning any nonconfoming items; (13) correcting conditions adverse to quality; l
(14) preparing and maintaining quality assurance records; and (15) auditing activities which affect quality.
l The plan requires the establishment and continuous implementation of the quality assurance indoctrination, training, and retraining program to assure that persons involved in safety-related activities are kn6dledgeable in quality assurance instructions and implementing procedures and that they demonstrate a high level of competence and skill in the perfonaance of their quality-related activities.
Quality is verified through surveillance, inspection, testing, checking, and audit of work activities. The plen requires that quality verification and inspections be perfonned by qualified qt ality control inspectors who are not directly responsible for performing the actual work activity.
Inspections are performed with t
procedures, instructions, and/or checklists by inspectors who have been qualified and certified in accordance with codes, standards, or company training programs.
l The performance of quality assurance audits is an integral part of the quality assurance program. The requirements for the Comanche Peak quality assurance audit program are set forth in the CPSES i
Operations Administrative Control and Quality Assurance Plan.
Q.8. Please describe the provisions for conduct of quality assurance audits, including a description of how reactor operations and reactor operator training will be audited.
A.8. As noted above, the CPSES Operation't Administrative Control and i
I Quality Assurance Plan establishes requirements for an audit pro-gram. These requirements are consistent with the provisions of i
l Regulatory Guides'1.28 and 1.33 and ANS! Nd5.2.12.
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The plan requires that planned and periodic audits be performed in accordance with written reocedures to verify compliance with all i
aspects of the quality assurance program. The Manager, Quality Assurance is responsible for quality assurance audits. Activities l
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l
4 i involved in auditing include planning, preparation, scheduling,
- l performance, reporting, and verifying implementation of corrective and preventive action measures. These audits are perfonned with written procedures or checklists by qualified personnel of the offsite Quality Assurance Division, who do not have direct respons-ibility in the areas being audited. These audits include examina-tion of quality-related activities such as reactor operations and reactor operator training.
Organizations that are subject to 4
audit include the CPSES operations, maintenance, engineering, quality assurance, and support organizations.
i The quality assurance program establishes a comprehensive audit system to ensure that the quality assurance program requirements and related supporting procedures are effective and properly implemented during operations. Audits are to include an objective evaluation of quality assurance practices, procedures, and instructions; work j
areas, activities, processes, and items; the effectiveness of i
implementation of the quality assurance program; and conformance with policy directives.
Audit findings, which indicate quality i
trends and the effectiveness of the quality assurance program, are reviewed by the M' nager, Quality Assurance and are reported to the j
a Executive Vice President and General Manager on a regular basis.
The quality assurance audit program includes the following elements:
l 1.
It utilizes an audit planning document which defines the organizations and activities to be audited and the frequency of the audits.
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2.
It requires that auditors be familiar with the type of activities to be audited and have no direct responsibilities in the are; 151ng audited.
3.
It provides auditing checklists or other objective guidelines i
to identify those activities wt-ich affect quality.
4.
It requires examination of the essential characteristics of the activities which affect qullity.
5.
It requires that an niii. report be prepared which notes the extent of examination and the deficiencies found.
6.
It requires that the audit report be sent to management responsible for the area audited far review and corrective I
action for deficiencies.
7.
It requires that corrective action be taken as result of the audit being reported.
8.
It requires reauditing of deficient areas when it is considered necessary to verify implementation of required corrective
[
actions, to preclude repetitive occurrences.
9.
It requires that results of au'dits be periodically examined to detennine any trends that may develop in areas being audited.
The Applicant has'tommitted to audit all aspects of the quality assurance program annually, in accordance with the provisions described above. Details have not yet been made available for NRC review as to how any given portion of the CPSES quality assurance program (including reactor operations and reactor operator training)
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i will be audited by the Applicants' quality assurance organization during the operations phase. As the design and construction phase nears coapletion, such infonnation will be submitted to the NRC in the fonn of procedures which will then be reviewed by inspectors from the NRC's Office of Inspection and Enforcement (I&E). The Staff expects the Applicants' audits of reactor operator training and reactor operations to be similar in fonn to the NRC audits of these activities as described in the I&E Inspection Manual.
Implementation of these procedures will be verified in the field on a sampling basis by NRC inspectors.
In summary, audits of reactor operations and reactor operator train-inri are to be perfonned by qualified, independent personnel using checklists or other guidelines in accordance with procedures to be approved by the NRC's Office of Inspection and Enforcement.
A separate program for review and audit of activities affecting station safety during the operational phase has been established, which augments the audit program described above. This additional program involves the Station Operations Review Committee (SORC), the Operations Review'bommittee (0RC)', and the Independent Safety Engineering Group (ISEG).
It provides a systera to ensure that operational activities are performed in accordance with company policy and rules, approved procedures, and license provisions. This program will provide review of safety-related plant changes, tests, and procedures.
It will verify that reportable events that require
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i reporting to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are properly investigated and corrected so as to reduce the probability of recurrence, and it will detect trends which may not be apparent in daily observation.
The Station Operations Rntiew Committee is composed of station supervisory and technical personnel and is charged with reviewing the items listed below and advising the Manager, Plant Operations on the disposition of these items:
1.
Proposed physical charges to nuclear-safety-related systems.
2.
Proposed nuclear-safety-related procedures or changes to nuclear-safety-related procedures.
3.
Proposed tests and experiments or changes to existing tests and experiments affecting nuclear-safety-related systems.
4.
Proposed changes to the Technical Specifications, Emergency Plan, Security Plan and NRC licenses.
5.
Investigations of violations of Technical Specifications, NRC license requirements, and nuclear-safety-related security provisions.
6.
Abnomal occurrences and unusual events.
7.
Emergency Plan activities.
8.
Indications of deficiency in design or operation of nuclear-safety-related systems.
9.
Any other nuclear-safety-related matter determined to be appropriate by the Manager, Plant Operations.
I The Operations Review Committee is to be an independent body assigned primary responsibility for the review of safety-related station matters.
It will report its findings and recommendaticas to the Executive Vice President and General Manager of Texas Utilitics Generating Company (TUGCO) for his action, as appropriate. The ORC l
will periodically conduct an independent review of the audit program to assure that audits are being conducted in accordance with the applicable criteria and procedures.
It will review the subjects listed below (as well as other subjects as requested by the ORC Chairman, permanent ORC members, the ISEG, or the TUGC0 Quality Assurance Division):
1.
Safety evaluations of design changes, procedural changes, tests, or experiments to verify that they do not involve unreviewed safety issues.
2.
Proposed design changes, procedural changes, tests, or experiments which involve unreviewed safety issues.
3.
Proposed changes to Tvchnical Specifications or license amendments relating to nuclear' safety.
4.
Deviations and reportable events which require reporting to the NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
5.
Reports of audits conducted by the NRC, TUGC0 Quality Assurance Division, and station Quality Assurance personnel to detect trends that may be detrimental to safe station operation.
6.
Selected report; and documentation of the SORC or the ISEG to verify the adequacy of the onsite review process.
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7.
Other matters deemed appropriate by ORC members or referred to the ORC by the S0RC or the ISEG.
The Independent Safety Engineering Group is to perfona independent reviews of plant operations including the review of activities i
affecting station safety occurring during the CPSES operational phase.
It will review plant activities and make recommendations to management on ways to improve the overall quality and safety of operations.
It will also review matters referred to it by the 50RC and the ORC and present its findings to the referring committee.
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TABLE 1 REGULATORY GUIDANCE APPLICABLE TO QUALITY ASSURANCE PROGRAM 1.
Regulatory Guide 1.8 (Revision 1-R - May 1977), " Personnel Selection and Training."
2.
Regulatory Guide 1.28 (Revision 0 - June 1972), " Quality Assurance Program Requirements (Design and Construction)."
3.
Regulatory Guide 1.30 (Revision 0 - August 1972), " Quality Assurance Requirements for Installation, Inspection, and Testing of Instrumen-tation and Electric Equipnent."
4.
Regulatory Guide 1.33 (Revision 2 - February 1978), " Quality Assurance Program Requirements (0peration)."
f 5.
Regulatory Guide 1.37 (Revision 0 - March 1973), " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants."
6.
Regulatory Guide 1.38 (Revision 1 - October 1976), " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants."
7.
Regulatory Guide 1.39 (Revision 2 - September 1977), " Housekeeping Requirements for Water-Cooled Nuclear Power Plants."
8.
Regulatory Guide 1.58 (Revision 1 - September 1980), " Quality Assur-ance Requirements for the Design of Nuclear Power Plants."
9.
Regulatory Guide 1.64 (Revision 2
' June 1976), " Quality Assurance Requirements for the Design of Nuclear Power Plants."
10.
Regulatory Guide 1.74 (Revision 0 - February 1974), " Quality Assur-ance Terms and Definitions."
- 11. Regulatory Guide l'.B8 (Revision 2 - October 1976), " Collection, 1
Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records."
12.
Regulatory Guide 1.94 (Revision 1 - April 1976), " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants."
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- 13. Reg;1atory Guide 1.116 (Revision 0-R - May 1977), " Quality Assurance Requirements for Installation, Inspection,'and Testing of Mechanical Equipment and Systems."
14.
Regulatory Guide 1.123 (Revisi>>n 1 - July 1977), " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants."
15.
Regulatory Guide 1.146 (Revision 0 - August-1980), " Qualification of Quality Assurance Program Audit Personnel For Nuclear Power Plants."
16.
ANSI N45.2.12 (Draft 4, Revision 2 - January 1976 as supplemented by Regulatory Position 4 of-Regulatory Guide 1.33 - Rev. 2 - Fe' ruary o
1978), " Requirements for Auditing of Quality Assurance Programs for l
Nuclear Power Plants."
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l JOHN G. SPRAUL PROFESSIONAL QUALIFICATIONS QUALITY ASSURANCE BRANCH 4
0FFICE OF NUCLEAR REACTOR REGULATION I am a Senior Quality Assurance Engineer (Nuclear) in the Quality Assurance Branch in the Office of Nuclear Reactor Regulation, U.S.
Nuclear Regulatory Commission.
In this position, I am responsible for the review and evaluation of applicants' descriptions of quality assurance programs proposed for the design, construction, and operation of nuclear power plants as assigned to me.
I received a Bachelor of Chemical Engineering degree from the Georgia Institute of Technology in 1951.
In 1971, I completed the i
requirements for the Professional Designation in Quality Control at the i
University of California, Los Angeles. My nuclear experience prior to joining the NRC includes 2 years of engineering work in gaseous diffusion with the Goodyear Atomic Corporation and 12 years of nuclear fuel and nuclear power plant conponent design, manufacture, and testing with the Ato:aics International Division of Rockwell International.
My quality assurance experience prior to joining the NRC includes 2 years as Chief Inspector and 4 years 'as Director of Quality Assurance at Atomics International, where I was responsible for managing the entire quality i
assurance program.
l I joined the Quality Assurance Branch of the NRC in 1974.
Since-joining the NRC, I have reviewed the quality assurance program descriptions for 26 nuclear power plants as well as 19 topical reports on quality assurance submitted by utilities, architect-engineers, NSS suppliers, and constructors.
I am a member of the Anerican Nuclear Society and a senior member of the American Society for Quality Control.
In 1972, I was certified as a l
Quality Engineer by the American Society'for Quality Control.
This certification was last renewed in 1980, and excires on Decenber ??,1982.
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NUREG-0797 Safety Evaluation Report re ated to t7e operation of Comanc,e Peak Steam Electric Station, Units 1 and 2 l
Docket Nos. 50-445 and 50-446 Texas Utilities Generating Company, et al.
ij.S. Nuclear Regulatory 1
Commission l
Office of Nuclear Reactor Regulation July 1981 I
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17 QUALITY ASSURANCE 17.1 General The description of the quality assurance (QA) program for the operations phase of Comanche Peak Steam Electric Station Units 1 and 2 is in Section 17.2 of the FSAd.
The staff evaluation of this QA program is based upon a detailed review of this information and discussions with representatives of Texas Utilities Generating Company.
The staff assessed Texas Utilities Generating Company's QA program for the operation phase to determine if it complies with the requirements of 10 CFR 50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants"; with the applicable QA-related Regulatory Guides and ANSI standards listed in Table 1; and with SRP Section 17.2, Revision 1, " Quality Assurance During the Operations Phase."
17.2 Organization for the QA Program The structure of the organization responsible for the operation of Comanche Peak and for the establish'r.ent and execution of the operations phase quality assurance program is shown in Figure 17-1.
The Executive Vice-President and General Manager is responsible for the overall management and operation of Comanche Peak, including the establishment of company policies.
He aisc has overall responsibility for the establishment and execution e
of the Comanche Peak QA program for operations.
Reporting to the Executive Vice-President and General Manager is the Vice President, Nuclear, who has overall responsibility for station operation and the operational QA program.
Reporting to the Vice President, Nuclear, is the Manager, Quality Assurance, who is respcnsible for ensuring effective implementation of the corporate QA program and for performing offsite quality assurance activities in support of station operations. The Quality Assurance Division, under the direction of the Manager, Quality Assurance, ensures effective implementation of the QA program by performing audits of onsite and offsite quality related activities and The Manager, Quality Assurance evaluating vendors' QA programs and procedures.
is responsible for regularly assessing the status and adequacy of the operational QA program and for reporting the results of these evaluations to the Vice President, Nuclear.
The Manager, Plant Operations reports to the Manager, Nuclear Operations, for all station activities.. He is directly responsible for the safe and reliable operation of Comanche Peak and for the implementation of the QA requirements and controls.
He is also responsible for developing, approving, and implementing the station Operations Administrative Control and Quality Assurance Plan.
located onsite and reporting to the Manager, Plant Operations, is the Operations supervised by the Operations Quality Assurance Quality Assurance Section,ible to thn Manager, Plant Operations for ensuring He is respons Supervisor.
effective implementation of the qualit.y assurance / quality control program at the station and for surveillance and review of station quality related activities to ensure compliance with applicable quality requirements.
The e
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PRESIDENT EXECUTIVE VICE I
PRESIDENT AND GENERAL MANAGER VICE PRESIDENT, NUCLEAR MANAGER.
- HANAGER, NUCLEAR OPERATIONS QUALITY ASSURANCE e
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- MANAriER, i
i PLANT OPERATIONS
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OPERATIONS QUAllif 8
ASSURANCE SUPERVISOR
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Audit responsibility and s
QUALITY QUALITY comunication channel, n
ASSURANCE CONTROL TECHNICIANS INSPECTORSg Figure 17,1 Comanche Peak Quality Assurance Organization 17-2
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i Operations Quality Supervisor maintains a working interface and a direct line of communication with the Manager, Quality Assurance to advise him of the status of the station QA program and any significant conditions adverse to quality.
Both the Quality Assurance Division and the Operations Quality Assurance Section have the authority to (1) identify quality problems; (2) initiate, recommend, i
or provide solutions; (3) verify implementation of solutions; and (4) stop j
unsatisfactory work or further processing, delivery, or instal'.ation of unsat-isfactory material.
The Quality Assurance Division is responsible for (1) verifying through surveil-lance and audit that procedures for quality-relcted activities comply with the quality assurance program; (2) performing vendor quality assurance prequalific-ations; (3) ensuring that procurement documents contain quality requirements which can be inspected and controlled; (4) surveillance and auditing of offsite contractors and suppliers; (5) documenting and reporting to management nonconformances discovered during surveillance or auditing; and (6) auditing of maintenance, modification, and operation activities.
The Operations Quality Assurance Section is responsible for (1) surveillance, reviewing, and administering inspection activities to ensure compliance with applicable quality requirements; (2) reviewing all procedures involving operation, maintenance, modification, inspection, and testing for QA require-ments; (3) performing independent review of nonconformances, including disposition of closeout; and (4) surveillance of onsite contractors.
Inspections are performed by qualified and certified quality control inspectors who are independent of the individuals performing the activity being inspected.
Quality control inspectors may be selected from any Texas Utilities Generating Company departments or contract personnel and will report directly to the Operations Quality Supervisor when they are acting in the capacity of a quality Disputes and unresolved issues between QA personnel and control inspector.
other organizations are brought to the Vice President, Nuclear, for resolution.
17.3 Quality Assurance Program The QA program for the operation of Comanche Peak is presented in the Texas Utilities Generating Company Corporate Quality Assurance Program Manual, which 1
establishes the general QA policies and requirements to be implemented at the l
l These policies and requirements are implemented by the Comanche Peak station.
Steam Electric Station Operations Administrative Centrol and Quality Assurance Plan (Quality Assurance Plan), which.is reviewed and approved by the Manager, The Quality Assurance Plan Quality Assurance, and'Hanager, Plant. Operations.
establishes the quality' requirements and controls to be implemented during station operations and defines the responsibilities, authority, and measures for the control and accomplishment of activities affecting the quality and operation of safety-related structures, systems, and components.
On the basis of its review, the staff concludes that the Quality Assurance' Plan for Comanche Peak is structured in accordance with Appendix B to 10 CFR Part 50 and with the provisions of the NRC Regulatory Guidance shown in Table 17.1.
These documents, coupled with the QA program description in the FSAR, form the foundation for the overall QA program and describe how the requirements of These documents control quality-related Appendix B to 10 CFR 50 are satisfied.
17-3
I Table 17.1 Regulatory guidance applicable to quality assurance program 1.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.28 (Revision 0 -
. June 1972), " Quality Assurance Program Requirements (Design and 2.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.30 (Revision 0 -
August 1972), " Quality Assurance Requirements for Installation, Inspection,!
and Testing of Instrumentation and Electric Equipment."
3.
U.S. Nuclear Re January 1977), gulatory Commission, Regulatory Guide 1.33 (Revision 1 -
Quality Assurance Program Requirements (Operation)."
4.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.37 (Revision 0 -
March 1973), " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants."
5.
U.S. Nuclear Re October 1976), gulatory Commission, Regulatory Guide 1.38 (Revision 1 -
Receivin Quality Assurance Requirements for Packaging, Shipping, Plants."g, Storage, and Handling of Items for Water-Cooled Nuclear Power 6.
U.S. Nuclear Re September 1977)gulatory Commission, Regulatory Guide 1.39 Plants."
7.
U.S. Nuclear Re September 1980)gulatory Commission, Regulatory Guide 1.58 (Revision 1 -
" Quality Assurance Requirements for the Design of Nuclear Power Plants.",
8.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.64 (Revision 2 -
June 1976), " Quality Assurance Requirements for the Design of Nuclear Power Plants."
9.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.74 (Revision 0 -
February 1974), " Quality Assurance Terms and Definitions."
10.
U.S. Nuclear Re October 1976), gulatory Commission, Regulatory Guide 1.88 (Revision 2 -
Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records."
11.
U.S. Nuclear Regul'atory Commissioh, Regulatory Guide 1.94 (Revision 1 -
April 1976), " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants."
12.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.116 (Revision O-R -
May 1977), " Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems."
13.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.123 (Revision 1 -
July 1977), " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants.
17-4
Table 17-1 (Continued) 14.
U.S. Nuclear Regulatory Commission, Regulatory Guide 1.44 (Revision 0 -
August 1980), " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants."
15.
ANSI N45.2.12 (Draft 4, Revision 2 - January 1976 as supplemented by Regulatory Position 4 of Regulatory Guide 1.33 - Rev. 2 - February 1978),
" Requirements for Auditing of Quality Assurance Programs for Nuclect Power Plants."
activities involving safety-related items to satisfy the requirements of t
Appendix B to 10 CFR 50.
Procedures which implement the requirements of the Quality Assurance Plan are reviewed by the Operations Quality Assurance Supervisor and approved by the Station Operations Review Committee.
The Quality Assurance Plan requires that quality assurance documents encompass detailed controls for (1) translating codes, standards, and regulatory requirements into specifications, proceduras, and instructions; (2) developing, reviewing, and approving procurement documents, including changes; (3) prescribing all quality-affecting activities by documented instructions, procedures, or drawings; (4) issuing and distributing approved documents; (5) purchasing items and services; (6) identifying materials, parts, and components; (7) perforning special processes; (8) inspection and/or testing material, equipment, processes, or services; (9) calibrating and maintaining measuring and test equipment; (10) handling, storing, and shipping of items; (11) identifying the inspection, test, and operating status of safety-related items; (12) identifying and dispositioning nonconforming items; (13) correcting conditions adverse to quality; (14) preparing and maintaining quality assurance records; and (15) auditing of activities which affect quality.
The Comanche Peak Quality Assurance Plan requires the establishment and con-tinuous implementation of the QA indoctrination, training, and retraining program to ensure that persons involved.in safety-related activities are
[
knowledgeable in QA instructions and imp'lementing procedures and that they demonstrate a high level of competence and skill in the performance of their quality-related activities.
Quality is verified through surveillance, inspection, testing, checking, and auditing of work activi. ties.
The Quality Assurance Plan requires that quality verification and inspections be performed by qualified quality control inspec-tors who are not directly responsible for performing the actual work.
Inspections are performed with procedures. instructions, and/or checklists by inspectors who have been qualified and certified in accordance with codes, standards, or company training programs.
U The Manager, Quality Assurance is responsible for QA audits, which include planning, preparation, scheduling, performance, reporting, and verifying implementation of corrective and preventive action measures.
These audits are performed with written procedures or checklists by qualified personnel not having direct responsibility in the areas being audited.
The QA program establishes a comprehensive audit system to ensure that the QA program 17-5 h-====om.,
requirements and related supporting procedures are effective and properly implemented during operations. Audits will include an objective evaluation of QA practices, procedures, and instructions; work areas, activities, processes and items; the effectiveness of implementation of the quality assurance progra,m; and conformance with policy directives.
The QA program requires documentation of audit results and review by the management personnel who have responsibility in the area audited to determine and take corrective action as required.
Reaudits are performed to determine that nonconformances have been effectivel action precludes repetitive occurrences. y corrected and that tha corrective Audit findings which indicate quality trends and the effectiveness of the QA program, a,re reviewed by the Manager, Quality Assurance and are reported to the Executive Vice-President and General Manager on a regular basis.
17.4 Conclusion The staff review of the Texas Utilities Generating Company's Quality Assurance Program description for the operations phase has verified that the criteria of Appendix B to 10 CFR Part 50 have been addressed.
Based on its review and evaluation of the QA program description contained in Section 17.2 of the FSAR the staff concludes:
(1) The QA organization of Texas Utiitties Generating Company provides sufficient independence from cost and schedule (when opposed to safety considerations), authority to effectively carry out the operations QA program, and access to acnagement at a level necessary to perform the QA functions.
(2) The QA program, with the exception of the outstanding issue described in Section 17.5 of this report, describes requirements, procedures, and controls that, when properly implemented, comply with the requirements of Appendix B to 10 CFR 50 and with the acceptance criteria contained in SRP Section 17.2.
Accordingly, the staff conclufes that the applicant's description of the QA program, with the exception of the outstanding issue noted below, is in l
compliance with applicable NRC regulations.
17.5 Outstanding Quality Assurance Issue for Coaanche Peak Steam Electric Station, Units 1 and 2
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l The staff has reviewed 'the list of systems, structures, and components which are under the control of the QA program and notified the applicant of some shortcomings of the list.
The applicant has not responded to this open item.
The staff will discuss the resolution of this matter in a supplement to thl,s report.
17-6 t
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NUREG-0797 Supplement No.1
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Safety Evaluation Report related to the operation of l
Comanche Peak Steam Electric Station, l
Units 1 and 2 Docket Nos. 50-445 and 50-446 Texas Utilitios Generating Company, et al.
U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation October 1981
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17 QUALITY ASSURANCE 17.5 List of Systems, Structures and Components Under Control of the QA Program Section 17.5 of the SER stated that the applicant had not responded to shortccaings identified by the staff in the list of structures, systems, and components under the control of the QA program.
By FSAR Appendix 17A (revised) and response to staff Question 260.1, differences between the staff and the applicant regarding the list have been resolved to the staff's satisfaction.
The list has been expanded to include safety-related items reflected in NUREG-0737, " Clarification of THI Action Plan Requirements," November 1980.
Therefore, the staff has no open issues concerning the quality assurance program for operations or as to the items to which the program applies.
Accordingly, the staff concludes that the applicant's description of the QA program is in compliance with applicable NRC regulations.
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Comanche Peak SSER #1 17-1 l
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