ML20040E044
| ML20040E044 | |
| Person / Time | |
|---|---|
| Issue date: | 12/15/1981 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Mills L TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8202030023 | |
| Download: ML20040E044 (5) | |
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DEC 151981s D_ISTRIBUTION:
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. Mr. L. M. Mills, Manager Nuclear Regulation and Safety
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SUBJECT:
PROPOSED REVISION 5 TO TVA-TR75-1A Having completed several interactions on the above subject, we are once again at 'a point of requiring additional infomation or clarification before we can find Revision 5 acceptable.
In lieu of another round of questions and answers, we have proposed to Dave Larchert-that a meeting be held here in Bethesda to resolve the areas of difference. We have tentatively arranged for such a meet-ing at 8:30 a.r.1. on January 12,1982. The attachment to this letter should be considered the agenda for the meeting. We picture the meeting as a working meeting which will result in a draft of the topical report which is acceptable to both the NRC and TVA.
We will be in contact with you regarding the specific location for the meeting.
If you have any questions in the meantime, please call Jack Spraul of my staff on FTS 492-9495.
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' Sin cerely,
s original signed by Walter P. Haass Walter P. Haass, Chief Quality Assurance Branch Division of Engineering Attactment:
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Agenda 42.
TVA reply number 20 (Mills to Haass letter of May 28,1981) indicates that section 17.0 Quality Assurance, Introduction will include a commitment to notify NRC of organization changes.
This has not been included.
Amend the introduction to include this commitment.
43.
Discuss the involvement of NUC PR in preoperational testing.
Cover such activities as procedure development; procedure review; performing, witnes-sing, or observing the tests; and reviewing or analyzing test results.
44.
The notes in Table 17.1A-3A should be referred to in the body of the table.
45.
Regarding Regulatory Guide commitments:
a)
Provide alternatives to the exceptions in Table 17.1A-4A, -4B, and -4C to Regulatory Guide 1.94.
b)
The application of Regulatory Guide 1.88 to " permanent record storage only" for Watts Bar (Table 17.1A-48) and Sequoyah (Table 17.1A-4C) is unacceptable as presented.
Cla rify.
46.
Justify the deletion of or replace the following:
a)
"and quality affecting" from 17.1A.2.1.2(2) and (4) 7 b) the last paragraph under ENDES under 17.1A.2.1.2 c)
"PSAR and FSAR" in 17.1A.2.2.1 d) the fact that design controls apply to activities such as seismic, stress, thermal, hydraulic, radiation, and accident analysis; com-patability of materials; reactor physics, and accessibility for maintenance, repair, and inservice inspection of the first para-graph of section 17.1A.3 i
e) the fact that design reviews assure the design provides for a com-pleted product to be controlled, inspected, and tested as required to assure that the product will meet all requirements in the second paragraph of section 17.1A.3.3.1 f) the fact that the scope of each design review assures coverage of all safety-related aspects of the design in the third paragraph of section 17.1A.3.3.3 g) the fact that design drawings (in addition to being checked by experi-enced design engineers other than those who prepared the original) are reviewed by qualified engineers other than those who check the design drawings in the fif th paragraph of section 17.1A.3.3.1 h) the second and third paragraphs in section 17.1A.3.3.3 i) the commitment the OEDC QA Manager's staff audits procurement acti-vities in the fourth paragraph of section 17.1A.4.1 V V t
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PSAR's and design change requests from the list of controlled documents in section 17.1A.6 k) the timeliness (prior to implementation) of review and approval of dJcument changes in th e second paragraph of section 17.1A.6 1)
"in like manner" from the last paragraph of 17.1A.6.3 m) the fact that TVA representatives determine the " Deviation Notices have been prepared, if applicable," per the list in the eighth paragraph of section 17.1A.7.3 n)
" Quality Control" in the Construction Unit (Quality Control) Supervisor's title in the second sentence of section 17.1A.10.2 o) requirement for CONST QA to review and approve Code controlling docu-ments in the third paragraph of section 17.1A.14 p) the paragraph on page 17.1A-69 of Revision 4 titled " Determining and Reporting NCR-0IE Reportable Conditions." The paragraph should cover the reporting of supplier, EN DES, and CONST nonconformances.
q) the fact that TVA NCR's identify the nonconforming item, descrioes the nonconformances, and describes the disposition of the nonconformance in the second paragraph of section 17.1A.15.5 r) a monthly notification to the Construction Engineer of any NCR's that have not been resolved in the last paragraph of section 17.1A.16.2 s)
" Evaluate" in the first sentence of the third paragraph of section 17.1A.18 t) the fact that audit staffs reaudit as necessary to assure that corrective action has been successfully taken and issues a quarterly report on the corrective action status of auditt from the last paragraph of section 17.1A.18 u) the statement in the fif th paragraph of section 17.1A.18.1 that the area to be audited include: activities within engineering design, pro-curement, manufacturing, hr.ndling, storage, shipping, and construction, including preoperational testing.
v) the sixth paragraph of section 17.1A.18.1 which states:
"Whenever procedures are found to be inadequate or unavailable by the auditor, or auditing team, this information is reported to the EN DES Quality Assurance management, who will determine and implement the corrective action required."
47.
The new second paragraph in section 17.1A.2.2.1 indicates that some specific documents are not "QA records."
Clarify that superseded (outdated, revised)
. versions of these documents will be maintained as required.
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48.
Clarify what is meant by " program oriented procedures" in the third paragraph of 17.1A.2.2.1.
4 49.
Clarify in section 17.1A.4 that the QA organization's review of procurement documents (both EN DES and CONST) assures that quality requirements are cor-rectly stated, inspectable, and controllable; there are adequate acceptance and rejection criteria; and procurement documents have been prepared, re-viewed, and approved in accordance with QA program requirements.
50.
Identify what organization is responsible to maintain " complete records of all procurements" as noted in the last paragraph of section 17.1A.4.1.
51.
The latter portion of the EN DES section 17.1A.5 states that each design docu-ment receives approval by its independent reviewer and that all EN DES nuclear plant requisitions and safety-related changes thereto are approved by EN DES QAB prior to release.
The connection between these two statements is unclear.
Clarify what organization is responsible for the QA review of each type of design document such as test procedures, calibration procedures, special pro-cess procedures, drawings, and specifications.
52.
The list of documents controlled by CONST QC procedures at the end of section 17.1.6.4 should include "as-built" documentation.
53.
The proposed Rev. 5 of the topical report refers to TVA EN DES QAB "representa-1 tives" while Rev. 4 referred to TVA referred to apparently the same personnel as QC " inspectors."
This is acceptable if the " representatives" meet the pro-visions of Revision 1 of Regulatory Guide 1.58 as conmitted to in Table 17.1A-4.
Provide such a commitment or an alternative for our review.
54.
In section 17.1A.9, either spell out HTN and PBN or include these abbreviations in the List of Abbreviations.
55.
The review of test procedures should assure adequate provisions for recording and reviewing test results as well as the other items listed in the second paragraph in section 17.1A.11.
56.
Delete or justify the addition of "when requested by NUC PR" in section l
17.1A.11.5(2).
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57.
The revision to section 17.1A.15 does not address the involvement of the OEDC QA Manager in nonconformance control.
It appears that EN DES and CONST each make their own trend analyses with little or no overview from the office of the OEDC QA Manager.
Describe the involvement of the OEDC QA Manager in this area.
- 58. Delete or justify the inclusion of "significant" in the last sentence of sec-tion 17.1A.16.1 and in the second paragraph of section 17.1A.16.2.
59.
Discuss the timeliness of transfer of 0EDC QA records to NUC PR in section 17.1A.17.3.
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o 60.
Section 17.1A.18.3 states that the Supervisor, Site QA Unit, is responsible to audit construction activities.
However, the construction organizations (Figures 17.1A-8A through 17.1A-8E) do not all show a Supervisor, Site QA Unit.
Clari fy.
Also, this section indicates that such audits will not be performed where a conflict of interest exists.
Discuss what conflicts of interest are contemplated and identify the organization that audits these activi ties.
61.
TVA's operations phase alternative to Regulatory Position 3 of Regulatory Guide 1.33 is acceptable if, when TVA's independent body review is concurrent with submittal to the NRC, this fact is transmitted and justified in the trans-mi ttal. Provide such a commitment.
(Reference Sheet 2 of Table 17.2-5.)
- 62. Show the " Plant Compliance Staff" (page 17.2-14) on the organization chart.
63.
The response to question 23 indicates that the Nuclear Safety Review Board performs independent reviews of the QA program.
Incorporate this fact as a commitment in the topical report.
64.
Incorporate the first sentence of TVA's response to question 34 and the last sentence of TVA's response to question 37 into the topical report.
65.
The apparent lack of involvement of NUC PR in construction tests and in the assessment of preoperational test results in unacceptable.
(See questions 21 and 41 and the corresponding responses.)
It is the staff position that NUC PR review the construction test results to assure that the preoperational test prerequisites have been met and the preoperational test results to asrure that the operational prerequisites have been satisfied.
These reviews can be in addition to those performed by EN DES.
Provide such a commitment or pro-pose an alternative for our evaluation.
The alternative provided in response to question 41 - that EN DES performs these functions - is unacceptable.
W
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