ML20039E440
| ML20039E440 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/30/1980 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Silver H Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111090060 | List:
|
| References | |
| FOIA-80-515, FOIA-80-555 NUDOCS 8201070295 | |
| Download: ML20039E440 (13) | |
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APR 3 01980 DISTRIBUTION:
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NRRlReading File Docket No. 50-289 JGilray, QAB WHaass,QA,B I
i HE!10RANDU!! FOR:
Harley' Silver, Operating Reactors Branch No. 4,
' Division of Licensing FROM:
Walter P. Haass, Chie'f, Quality Assurance Branch, Division of Engineering
SUBJECT:
QUALITY ASSURANCE SER SUPPLEMENT FOR TMI-1 In. item 6 of the Comission Order dated August 9,1979, the Metropolitan Edison l
Company (Met-Ed) was asked to address the adequacy of the operational Quality Assurance program for Three Mile Island Station, Unit No. 1.
We have evaluated i
Met-Ed's response to this particular item provided in their docketed submittal (Amendment 15, Section 5.4) dated March 28, 1980, and sumarized our findings in the enclosure. (We find the upgraded QA program to be acceptable with the excep-tion of the listing of those items and activities that will be controlled by the QA progrart.') Met-Ed has indicated their plan to submit this listing by May 5,1980 for our review.
The enclosed SER supplement is intended to replace the SER supplement included in the Status Report for the TMI-1 restart dated January 11, 1980.
Original signed by Walter P. Haass Walter P. Haass, Chief
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l Division of Engineering
Enclosure:
SER Supplement for TMI-1 cc:
R. Vollmer
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V. Noonan cc w/o enclosure:
W. Pike enII
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Operational Quality Assurance Program -
The description of the quality assurance (QA) program for the operations phase of TMI-1 is addressed in Section 5.4 and Amendment No.15 (Operational QA Plan for the TMI Nuclear Station) of the Restart Report. The Met-Ed submittal addresses the QA organization and its reporting level and provides a description of how each of the criteria in Appendix B to 10 CFR 50 will be implemented.
Based on our evaluation of this information and discussions with the NRC's Office of Inspection and Enforce-ment and the licensee's QA personnel, we find that the proposed QA program for operations for TMI-l will satisfy the requirements of Appendix B to.10 CFR 50 and provides QA controls improved significantly beyond those'in use prior to the TMI-2 accident.
However, the licensee has not as yet provided a listing of the structures, systems, and components and activities to which the QA program will apply. This listing will be provided by June 1980, and the results of our review will be reported later.
The major areas where the QA controls have been improved are:
(a)involvementof the QA organization in the review and approval of quality-related aspects of proccdures for operations, maintenance, inservice inspection, modifications and procurement; in the performance of inservice inspections, non-destructive examinations, routine inspec-tions, verification, surveillance, and audit activities; in the day-to-day operations and maintenance staff meetings to keep abreast of ongoing activities; and in determin-ing adequate close-out of corrective actions; (b) expansion of the applicability of the QA program to include all structures, systems, components, and activities that are important to safety as defined by Appendix A to 10 CFR 50; and (c) better control 1
l of as-built drawings.
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, Organization The overall QA organization and staffing established for TMI-1 has been restructured and improved since the TMI-2 accident to include responsibility for implementation of the QA controls required in day-to-day activities and for involvement in the review and concurrence of procedures associated with these activities.
The authority and responsibilities of the QA organization have been expanded to include all the important activities that occur during the operation of the plant.
The QA staff has been increased in size and its qualifications relative to education and experience have been improved.
The Senior Vice-President
- of Met-Ed is ultimately responsible for the proper imple-mentation of the QA program to assure the safe operation, maintenance, and modification of TMI-l as shown in Figure 1.
The responsibility and authority for assuring that the QA program is properly carried out has been delegated to the Director of Nuclear Assurance.
The Director of Nuclear Assurance is responsible for quality assurance, nuclear safety assessment, training and operational safety support and radiological systems control.
The Manager of the Quality Assurance Department reports directly to the Director of Nuclear Assurance and has the functional authority, independence, and responsibility to implement the QA program in an effective manner. The independence of this Quality Assurance Department from those organizations responsible for design, procurement, manufacturing, construction, operations, and maintenance, combined with t
the reporting level of the department, assures sufficient freedom from the pressures of cost and schedule to permit effective implementation of the QA program.
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0 The titles'of certain positions addressed in the docketed QA program are based on the planned formation of GPU Nuclear Corporation and are not the same as the organization l
presented in Section 5.0 of the Restart Report.
The functions and positions are con-sistent, however, despite the difference in titles.
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. The Quality Assurance Department consists of five Sections: Methods, Operations, and Audit; Materials Technology; Design and Procurement Assurance; Manufacturing Assurance; and Modification / Operations.
The Methods, Operations, and Audit Section is responsible for coordinating activities associated with department procedures and with indoctrination and training of QA personnel. Additionally, this section is responsible for implementing a comprehen-sive system of planned and documented audits to verify compliance with all aspects of the QA program. Assisting in this assessment is a full-time audit group, also located at the plant site and reporting independently to the Manager of Quality Assurance through the Section manager.
The Materials Technology Section is responsible for the establishment of requirements for welding, inservice inspection, materials, and materials evaluations.
This section provides non-destructive examination, inservice inspection, and materials engineering and welding engineering services.
The Design and Procurement Assurance Section provides technical support for establish-ing quality program and inspection requirements in support of design and procurement activities. This effort includes the review and acceptance of design and engineering documents, procurement documents, and contractor and vendor QA programs.
The Manufacturing Assurance Section is responsible for performing quality-related l
i activities to assure that the vendor's product is designed, manufactured, and tested in accordance with the specified quality requirements.
i The Modifications / Operations Section consists of two sub-sections, Quality Control and Operational Quality Assurance. The Quality Control group is responsible for receiving inspection, and the inspection and surveillance activities related to maintenance, modi-
. fications, installation, and new construction. The group also has a welding engineering capability to review contractor's procedures and to survey the control of special pro-cesses.
The Jperational Quality Assurance group is responsible for monitoring functional testing and performing surveillance of all plant operational activities.
The latter includes monitoring and surveillance of plant operations, preventive maintenance, radiation protection, and the processing, packaging and shipping of contaminated products and radioactive wastes.
This group is also responsible for inservice inspec-tion and monitoring the performance and results of pump and valve testing to the applicable requirements of ASME Section XI.
Quality Assurance Program The TMI-l QA program describes a comprehensive QA system to be implemented during all phases of the operation, maintenance, and modification of TMI-1. This program satisfies the requirements of Appendix B to 10 CFR 50 and the provisions of the regulatory guides addressed in Table 1 with certain clarifications and modifications which are acceptable. Het-Ed has committed to apply the QA program to all items and activities important to safety as addressed in 10 CFR 50 Appendix A, " General Design Criteria for Nuclear Power Plants," in Regulatory Guide 1.29, " Seismic Design Clas-sification," and 10 CFR 71 Appendix E, " Quality Assurance Criteria for Shipping l
Packages for Radioactive Material." Howe.ver, as noted previously, the licensee has not as yet provided a list of the items and activities to which the QA program is applicable.
The Met-Ed QA Manager is responsible for the development of the policies and procedures to be used to implement the QA program and for assuring that l
the program is effectively implemented.
To accomplish this, the QA organization l
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. reviews and concurs with implementing procedures to assure the necessary QA require-ments have been incorporated; and inspects, monitors, and audits implementing activi-ties to assure they are consistent with the policies and procedures of the QA program.
The effectiveness and implementation of the QA program is independently reviewed by three Met-Ed technical review groups - the Generation Review Committee, the Plant Operations Review Conmittee, and the Nuclear Safety Assessment Department to gain -
further confidence that the QA program meets NRC requirements and company policy.
The QA program for the operational phase of TMI, including maintenance and modifica-tions, provides functional QA controls in accordance with the requirements of Appendix B to 10 CFR 50 in the following areas:
control of documents and records, design control, procurement and material control, control of station activities, control of radioactive waste, control of corrective actions and nonconformances, and audits.
Control of Docu_ments and Records: The QA program requires that activities be pre-scribed by and accomplished through implementation of documented procedures, instruc-tions, and/or drawings.
Criteria and individuals responsible for review, approval, issuance, and control of documents are to be specified in documented procedures.
Maintenance, modification, and inspection procedures are to be reviewed and con-curred with prior to implementation by the QA organization to detemine (a) the need for inspection, the identification of inspection personnel, and the documentation of inspection results; (b) that the necessary inspection requirements, methods, and acceptance criteria have been identified; and (c) that procedures have been prepared, l
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reviewed, and approved in accordance with QA policy and program controls.
QA records for items and activities under the control of the QA program are to be identified, reviewed, retained, and controlled by the QA organization and the Manager of Adminis-i tration and Services.
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. Design Control: The QA program assures that design requirements (i.e., design bases, regulatory requirements, codes and standards) are correctly translated into specifi-cations, drawings, procedures, or instructions.
This includes provisions to assure that quality standards are identified and included or referenced in design documents.
Designed materials, parts and processes are to be reviewed to assure that they are suitable.for the intended application, including compatibility of materials, accessi-bility for inservice inspection, maintenance, and repair, and suitability with regard to human factors.
Design and engineering documents are to be reviewed and concurred with by the QA organization to assure that quality requirements have been adequately considered.
Procurement and Material Control: The QA program requires the QA organization to be responsible for the approval of TMI procedures for the control of purchased equip-ment, material, and services; the approval of suppliers' QA programs; and the review and acceptance of supplier record packages.
The QA organization is also responsible for establishing and implementing an adequate program of source inspection, surveil-i lance, and receipt inspection to assure supplier compliance with contract requirements.
In regard to material control, the QA organization is responsible for the review and concurrence of procedures, performance of receipt inspection, and for monitoring, inspection, and audits to verify conformance to material control requirements.
Control of Station Activities: Acceptable QA controls are described in the QA pro-gram for station activities including design changes, procurement, fabrication, i
handling, shipping, storage, cleaning, erecting, installing, inspecting, testing, I
operating, fire protection, plant security, radiation control, and maintaining, repairing, refueling, and modifying items during the operation phase of TMI-1. The
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- QA organization is responsible for inspection, monitoring, surveillance, review, and audits of these activities to independently verify conformance to the QA pro-gram and implementing procedures. Work authorization documents relating to accomplish-ing these station activities are required to be reviewed and concurred with by the QA organization to determine the need for:
(a) inspection, (b) identification of in-spection organizations, (c) identification of inspection witness and holdpoints, and (d) documenting inspection results. QA monitoring of activities is required to obtain additional confidence that activities are being performed in accordance with the QA program.
The QA program provides measures to ensure that the required inspections and tests are performed and that the acceptability of items with regard to inspection and tests is known throughout the manufacturing, installation, and operational phases.
Control of Radioactive Waste: The QA program is structured to meet the requirements of Appendix E to 10 CFR 71 which involves controls for the processing of radioactive wastes including the collection, handling, and preparation for shipment of radio-active liquids and solids.
Control _of Corrective Actions and Nonconformances: The QA program requires the QA organization to be responsible for the prompt identification and correction of con-l ditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances.
To this end, the QA organiza-tion is involved in the review and concurrence decisions relating to corrective actions, dispositions of "use as is" or " repair," and to the acceptable close out of nonconformances and corrective actions.
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. Audits: The QA organization is responsible for implementing a comprehensive system of planned and documented audits to ensure that (a) the QA requirements are adequate, and effective, (b) nonconformances and QA deficiencies are identified and corrected, and (c) all activities are performed in compliance with the QA program.
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Conclusion:==
Based on our detailed review and evaluation of the QA program for the restart of TMI-1, we conclude that:
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Sufficient independence from the pressures of cost and schedule is provided to assure proper consideration for safety requirements; sufficient authority is vested in the QA organization to permit effective implementation of the QA program, and sufficient access to management is provided at a level necessary to perform the 0A function in an effective manner.
We, therefore, fi~nd the QA organizational arrangement to be acr.eptable and an improvement over that which existed prior to the TMI-2 accident, particularly relative to reporting level, assigned authority, and scope of responsibilities.
2.
The quality assurance program describes requirements, procedures, and controls that, when properly implemented, comply with the requirements of Appendix B to 10 CFR 50 including the applicable regulatory guides, endorsed codes and standards, and the criteria contained in SRP Section 17.2.
3.
The quality assurance program has been extended to apply to all structures, systems, components, and activities important to safety as identified in Regulatory Guide 1.29, Appendix A of 10 CFR 50 and Appendix E of 10 CFR 71.
Accordingly, the staff concludes that the applicant's description of the quality I
assurance program with the exception of the outstanding item noted below, is in
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compliance with applicable NRC regulations and represents a significant improvement relative to the program in effect prior to the THI-2 accident.
The staff has not reviewed these structures, systems, components, and activities to be placed under the control of the QA program since Met-Ed has not as yet sub-mitted this information. Therefore, this area of review remains an open item.
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TABLE 1 Regulatory Guidance Applicable to Quality Assurance Program for TMI-l 1.
Regulatory Guide 1.8 (Revision 1-R - May 1977), " Personnel Selection and Training."
2.
Regulatory Guide 1.26 (Revision 3 - February 1976), "QA Classification and Standards for Water Stream and Radioactive Waste Containing Components of Nuclear Power Plants."
3.
Regulatory Guide 1.28 (Revision 2 - February 1979), " Quality Assurance Program Requirements (Design and Construction)."
4.
Regulatory Guide 1.29 (Revision 3 - September 1978), " Seismic Design Classification."
5.
Regulatory Guide 1.30 (August 11, 1972), "QA Requirements for the Installation, Inspection, and Testing of Instrumentation and Electrical Equipment."
6.
Regulatory Guide 1.31 (Revision 3 - April 1978), " Control of Ferrite Content in Stainless Steel Weld Metal."
4.
Regulatory Guide 1.33 (Revision 2 - February 1978), " Quality Assurance Program Requirements (Operation)."
5.
Regulatory Guide 1.37 (March 16,1973), "QA Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants."
6.
Regulatory Guide 1.38 (Revision 2 - May 1977), "QA 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."
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Regulatory Guide 1.54 (June 1973), "QA Requirements for Protective Coatings Applied to Water Cooled Nuclear Power Plants."
9.
Regulatory Guide 1.58 (Proposed Revision 1 - July 1979), " Qualifications of Nuclear Power Plant Inspection, Examination, and Testing Personnel."
- 10. Regulatory Guide 1.63 (Revision 2 - August 1978), " Electric Penetration Assemblies in Containment Structure for Light Water Cooled Nuclear Power Plants."
- 10. Regulatory Guide 1.64 (Revision 2 - June 1976), " Quality Assurance Requirements for the Design of Nuclear Power Plants."
- 11. Regulatory Guide 1.74 (February 1974), " Quality Assurance Terms and Definitions."
12.
Regulatory Guide 1.88 (Revision 2 - October 1976), " Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records."
13.
Regulatory Guide 1.94 (Revision 1 - April 1976), "Qk Requirements for Installation, Inspection, and Testing of Structural Concrete and Steel During Nuclear Power Plant Construction."
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Regulatory Guide 1.116 (Revision 0-R - May 1977), "QA Requirements for Installa-tion, Inspection, and Testing of Mechanical Equipment and Systems."
15.
Regulatory Guide 1.123 (Revisior 1 - July 1977), "QA Requirements for Control of Procurement of Items and Services for Nuclear Power Plants."
16.
Regulatory Guide 1.144 (January 1979), " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants."
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RELIABILITY FNGINEERING QUALITY ASSURANCE DEPARTMENT Senior V.P.
Director of Nuclear Assurance Manager of Quality Assurance s
Methods, Operations Materials Technology and Audit Section Section Design and Manufacturing Modifications /
Procurement Assurance Operations Assurance Section Section Section FIGURE 1
.