ML20137L274
| ML20137L274 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1986 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Youngblood B Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8601270378 | |
| Download: ML20137L274 (12) | |
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4 UNITED STATES K,,, a[})yl
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S NUCLEAR REGULATORY COMMISSION WASHING TON, D. C. 20555 JAN 2 3 1986 MEMORANDUM FOR:
B. J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing-A Office of Nuclear Reactor Regulation FROM:
Brian K. Grimes, Directnr Division of Quality Ass"r-Vandor, and Technical Trai.ng Center Programs Office of Inspectic.i and Enforcement
SUBJECT:
ALLEGATION NO. NRR-85-A-0022 ON TVA QUALITY ASSURANCE PROGRAM Your memorandum dated December 13, 1985 on the subject above requested our review of and input to close the allegation.
The allegation is described in the Alle-gation Management System as follows:
TVA'S QA ORGANIZATION OFFSITE AND ONSITE LACKS THE INDEPENDENCE REQUIRED THE NRC.
QC IS UNDER CONSTRUCTION AT CONSTRUCTION SITES AND IS UNDER THE PLANT MANAGER AT OPERATING SITES.
NRC's position regarding the independence of QA/QC is reflected in part 1 of section D of WASH-1284, " Guidance on Quality Assurance Requirenents during the Operations Phase of Nuclear Power Plants," October 26, 1973 (the "0 range Book").
A copy is enclosed as Enclosure 1.
The figures enclosed illustrate the accepta-bility of having QA either report onsite with a communication link offsite (Figs. 2 & 4) or report offsite with a communication link onsite (Figs.1 & 3).
Since mid-1976, TVA has described its organization for QA in its topical report TVA-TR75-1, "QA Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants." This report includes organization charts, a description of the organization, and the QA responsibility assignments.
As the TVA organiza-tion for 0A is revised, the NRC is so informed.
Numerous organizational changes have been made, and the second sentence of the allegation is true, i.e., QC is under construction at construction sites and is under the plant manager at operating sites.
However, each organizational setup reported to date has been reviewed by the NRC and found acceptable (in some cases after corrections of deficiencies identified by the review).
Acceptance letters have been issued which indicate the staff's position that the organizations and persons performing QA functions within TVA have the required independence in a structural sense. provides typical acceptance letters for TVA's QA topical report.
0601270370 % h PDR TOf RI PDR C
We believe the information presented herein is adequate to formally close out the subject allegation.
If more information is needed or if there is any question, contact Jack Spraul on x24530.
Original signed by Brian K. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs Offi of Inspection and Enforcement 56 - DS9 cc:
C. Stahle, NRR
Enclosures:
As stated Distribution:
DCS 016 PDR QAB Reading DQAVT Reading JMTaylor, IE RHVo11mer, IE BKGrimes, IE GTAnkrum, IE JLMilhoan, IE JLGilray, IE JGSpraul, IE OIA (1
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/85 12/23 /85 12/43 /85 2/,p(/85 1/
B. J. Youngblood 2
We believe the information presented herein is adequate to formally close out the subject allegation. As you know, extensive NRC review is ongoing to evaluate the adequacy of the implementation of these approved programs.
If more information is needed or if there is any question, contact Jack Spraul on x24530.
Original signed, by-Brian K. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement cc:
C. Stahle, NRR
Enclosures:
As stated Distribution:
DCS 016 PDR QAB Reading DQAVT Reading JMTaylor, IE RHVollmer, IE BKGrimes, IE GTAnkrum, IE JLMilhoan, IE JLGilray, IE JGSpraul, IE LSpessard, IE OIA hI
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O B. J. Youngblood 2
We believe the information presented herein is adequate to formally'close out the subject allegation. As you know, extensive NRC review is ongoing fo evaluate the adequacy of the implementation of these approved programs.
If.more information is needed or if there is any question, contact Jack Spraul on x24530.
~
s Brian K. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement cc:
C. Stahle, NPR
Enclosures:
As stated s.
}!Nc L C Sue? si l Pau.e / or S D.
Regulatory Staff Coments and Supplementary Guidance Section C contains AEC regulations, reguletory guides, and 4xtracts from a draft standard that provides requirements and guidance on the quality assurance program during the operations phase. In addition to the guidance presented in Section C, the AEC Regulatory staff has provided herein additional coceents and supplementary guidance in the areas of organization and training of personnel.
1.
Organization Criterion 1 of Appendix B to 10 CFR Part 50 requires that the authority and duties of persons and organizations performing quality assurance functions shall be clearly established and delineated in writing.
Section 3 " Organization," of ANSI N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants" (endor'ed by s
Regulatory Guide 1.33), which is consistent with the requirements of Appendix B to 10 CFR Part 50, requires that the organizational structure, functional responsibilities, levels of authority, and lines of internal and external communication for management, direction, and execution of the quality assurance program be documented.
ANSI N16.7-1972, " Administrative Controls for Nuclear Power Plants,"
states in Section 4.1:
" Review and audit programs shall be established and periodically reviewed by the owner organization to verify that operation of the plant is performed in a safe manner and is consistent with company policy and rules, approved operating procedures, and license provisions: to review important proposed plant changes, tests, and procedures; to verify that unusual events are promptly investigated and corrected in a manner that reduces the probability of recurrence of such events; and to detect trends that may not be apparent to a day-to-day observer."
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FM&E 2 Section 4.1 of N18.7-1972 further states:
"The means provided for review and audit may take' different forms.
For example, the owner-organiza-tion may assign review and audit function to an established organizational unit independent of*the unit having direct responsibility for operation of the plant, or may appoint a standing committee comprised of individuals from within or outside the owner-organization. The review and audit functions may be performed by separate groups, with a review group reviewing audit reports provided by individuals independent of the review organization.
This standard does not specify an organizational structure for meeting the review and audit functions, but in lieu thereof delineates essential elements of satisfactorily comprehensive review and audit programs for implementa-tion in the manner best suited to the nuclear power plant involved."
Subsection 4.2.2.1 of N18.7-1972 s ta tes :
" Independent review and audit may be assigned to one or more specific organizational units in the owner organization, or to a committee struc-ture.
The independent review and audit group shall be composed of no less than five persons of whom no more than a minority are members of the operating organization."
It has been the practice of many utilities to establish a
" safety review committee" (sometimes referred to as their independent review and audit group) to review the following items delineated in Section 4.3 of N18.7-1972:
Evaluations of proposed changes to procedures, a.
equipment, or systems completed under the provisions of $50.59(b), Part 50, Title 10, Code of Federal Regulations to verify that such proposed changes do not constitute unreviewed safety questions.
b.
Proposed tests and experiments, and their results, when such. tests or experiments may constitute an unreviewed safety question as defined in 850.59(c).
Part 50, Title 10, Code of Federal Regulations.
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P oposed changes in procedures, equipment, or systems c.
which may involve an unreviewed aafety question as defined in 550.59(c), Part 50 Title 10, Code of Federal Regulations, or changes which are referred by the operating organization.
d.
Proposed changes in Technical Specifications or licenses.
Violations of applicable statutes, codes, regulations, e.
orders, Technical Specifications, license requirements, or internal procedures or instructions having safety significance, f.
Significant operating abnormalities or deviations from normal and expected performance of plant equipment.
Abnormal occurrences, as defined in Subsection 2.2.2 g.
of N16.7-1972.
h.
Any indication of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components.
Although the safety review committee may perform necessary quality assurance functions, it should be recognized that the requirements of Appendix B to 10 CFR Part 50 or N45.2-1971 related to establish-ment of a quality assurance organization involve more than the establishment of the safety review committee. The responsibilities of the quality assurance organization extend beyond the review anh audit functions specified in Section 4 of N13.7.
Quality assurance organizations should be established both onsite and offsite. Section 3 of ANSI N45.2-1971 states: " Persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to (1) identify quality problems; (2) initiate, recommend, or provide solutions through de'ignated channels; s
(3) verify implementation of solutions; and (4) control further processing, delivery, or installation of a nonconforming item, deficiency, or unsatisfactory condition until proper dispositioning has occurred."
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(2,1(,c T Section 3 of ANSI 1;45.2-1971 further states that the person or organization responsible for defining and measuring the overall effectiveness of the quality assurance program shall be designated, shall be sufficiently independent from the pressures of production, shall have direct access to responsible management at a level where appropriate action can be required, and shall report regularly on the effectiveness of the program.
Examples of acceptable organizations are shown in Figures 1, 2, 3, and 4 Specifically related to onsite quality assurance activities, the quality assurance supervisor should be responsible for assuring that the quality assurance program at the nuclear power plant site is being effectively implemented. The quality assurance supervisor should be knowledgeable and experienced in nuclear power plant operations phase activities and should have no other duties or responsibilities so that he can direct his full attention to this effort.
The activities of the onsite quality assurance supervisor should be audited by offsite personnel to determine the effectiveness of these activities.
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Di s t ri bu ti on_:,
' Cent ratti l e AUG 141979 QAB Projects QAB Chron. File NRR Reading File M POR LPDR Mr. L. H. Ilills, Manager NSIC '
Nuclear Regulation & Safety JSprael Tennessee Valley Authority WBelke 400 Chestnut Street Tower II JGilray Chattanooga, Tennessee 37401 WHaass SBryan
Dear Mr. Mills:
HSilver
SUBJECT:
NRC ACCEPTANCE OF THE WA QA TOPICIL REPORT (REVISION 3)
.We have evaluated Revision 3 of TVA's Topical Report TVA-TR75-1, " Quality Assurance Program Description." submitted with your letter of June 22. 1979. Revision 3 reflects organizational, procedural, and editorial changes. We find that this report, as revised by your letter of August 2,1979, describes a quality assurance program that meets the criteria in Appendix B to 10 CFR Part 50 and is therefore acceptable. You may implement it upon issuance.
I For the TVA quality assurancr. program, you need only reference this topical report in Chapter 17 of your license applications. We do not intend to repeat our review i
i of this topical report when it is referenced in an application.
l Should regulatory criteria or regulations change such that our conclusions about this top' cal report are invalidated, we will notify you. You will be given.the opportunity to revise and resubmit it should you so desire. P.Vgram.atic changes i
by TVA to this topical report are to be submitted to NRC for review prior to i
implemen ta tion. Organizational changes are to be submitted no later than 30 days ',
af ter announcement.
t Please enclose a copy of this letter and the enclosed Topical Report Evaluation in each report revision, renumber the report TVA-TR75-1A, Revision 3 date the eport August 1979, and transmf: 40 copies to the NRC.
In your transmittal letter, indicate to which plants Revision 3 will be applicable.
Should you have any questions regarding our review or if we can provide assistance, please contact Mr. Jack Spraul or Mr. Bill Belke on (301) 492-7741.
Sincerely, orgset sgnas bp s.
Walter P. Haass. Chief Quality Assurance Branch 9 Division of Project Manarc.hent,
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/bc 2 T0PICAt. REPORT EVAL.UATION Report Numt,er:
TVA-TR75-1A. Revision 3. Nonproprietary Report
Title:
Quality Assurance Program Description Report Date: August 11. 1977 Revised August 1979 Originating Organization:
Tennessee Valley Authority Reviewed by: Quality Assurance Branca
SUMMARY
OF TOPICAL.
Topical Report TVA-TR75-1A. Revision 3. describes the quality assurance program which the Tennessee Valley Authority applies to those design, procurement, construction, preoperational testing, and operations phase activities involving safety-related structures, systems, and components of nuclear power plants within the Tennessee Valley Authority scope of work.
TVA TR75-1A, Revision 3. comits the Tennessee Valley Authority to comply with the requirenents of Appendix 8 to 10 CFR Part 50.
It also comits the Tennessee Valley Authority to follow the NRC Regulatory Guidas and ANSI standards listed below or has provided alternatives which the staff has found acceptable.
Jesign &
Construction Opera tion Regulatory Guide 1.8 KA 9/75 1.28 6/72 3/78 1.30 B/72 8/72 1.33 NA 2/78 1.37 3/72 3/73 1.38 10/76 5/77 1.39 10/76 9/77 1.58 8/73 8/73 1.64 6/76 6/76 1.74 '
2/74 2/ 74 -
1.88 10I76 10/76 1.94 4/76 4/76 1.116 6/76 6/76 1.123 10/76 7/77 ANSI N45.2.12 (D3 R4) 2/74 2/74 The Tennessee Valley Authority has.orovided fur our evaluation a detailed organi-zational description of those individuals anc' groups involved in carrying out activities required by the quality assurance program and a delineation of duties, responsibilities, and authority of those organizational alemNts involved in the quality assurance program.
Revision 3 of TVA-TR75-1A contains a description of the measures used to arry out the Tennessee Valley Authority quality assurance
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Pm 3 program activities and describes how applicabi1 requirements of Appendix B to
-10 CFR Part 50 will be satisfied by the administration and implementation of these measures.
SUMMARY
OF REGULATORY EVALUATION AND POSITION We have evaluated the quality assurance prcgram and the organizat'ons responsible for quality assurance functions described in Revision 3 of TVA-TR75-1A.
We find that quality assurance policy and direction originate at an acceptably high management level and are effectively communicated to other parts of the organization.
Those performing quality assurance functions have responsibility and authority commensurate with their duties in implementing the program. We also find that measures have been established to be implemented by written procedures and instructions, which address each of the criteria of Appendix 8 to 10 CFR Part 50 in an acceptable manner.
Based on our review and evaluation of TVA-TR75-1A, Revision 3, we conclude that:
1.
The organizations and persons performing quality assurance functions within the Tennessee Valley Authority have the required independence and authority to affectively carry out the quality assurance program without undue influence from those directly responsible for costs and schedules.
2.
The Tennessee Valley Authority quality assurance program contains requirements and controls which, when properly implemented, comply with the requirements of Appendix 3 to 10 CFR Part 50.
3.
The Tennessee Valley Authority Topical Report TYA-TR75-1A, Revision 3, " Quality Assurance Program Description." is acceptable for use in the design, procurement.
coastn;ction, preoperational te:: ting, and operations phase activitics of TVA's nuclear power plants.
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NRC PDR LpDR QAB Projects QAB Chron File Mr. L.M. Mills. Manager R. Digg. LFM8 f' rau(".'
Huclear Licensing Tennessee Valley Authority 400 Chestnut Street Twer II W. Johns ton. DE Chattanooga, TN 37401
Dear Mr. Mills:
StEJECT:
HRC ACCEPTANCE OF THE TVA QA TOPICAL REPORT (REVIS Your letter of May 7.1982 transmitted Rovision 5 to the TVA topical mport TVA-TR75-1 " Quality assurance Program Description for the Design. IDnstruction and Operation of TVA Nuclear Power Plants."
1ha TVA topical report, through Revision 4. was previously reviewed and accepted by the NRC for referencing in license appiteations as indicated in our letter of August 18,1980.
Revision 5 reflects quait ty assurance program, organization, and editorial changes.
Based on our review and evaluation of Revision S. we find that the c Appendix B to 10 CFR Part 50 are met.
acceptable, and you rny imple:mnt it upon issuance.Your amended topical report is, th The QA program interface with the offsite radiological hygiene function will require msolution in the next revision of the report.
For new license applications, we will coccare Revision 5 to the latest Revision of the Standard Review Plan (NUREG-0800). The msults of t will be forwarded to you upon coepletion.
Should regulatory criteria or regulations change such that our conclusions about this topical report are invalidated, we will notify you.
You will be given the opportunity to revise and resubmit it should you so desire, i
l l
please enclose a copy of this letter in the report, renumber the report TVA-l TR75-1A. Revision 5. and transmit 36 copies to the NRC.
letter indicate to which plants Revision 5 will be appifcable.In your transmittal Should you have any questions regarding our review or if we can provide assistance, please contact Mr. Jack Spraul on (301) 492-9489.
N Sincerely.
Original afgned by Walter P.Haass
/b Walter P. Haass. Chief
" pod TOPRP EUTTV Qual 1ty Assurance Branch 47 c.,n,30^,n 820706 R
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[NCloc cdygfk r% c' S October 12, 1984 8 '# U Tennessee Valley Authority ATTN: Mr. H. G. Parris
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Manager of Power and Engineering 500A Chestnut Street Tower Il Chattanooga, TN 37401 Gentlemen:
SUBJECT:
TV4 QUALITY ASSURANCE PROGRAM Your letter dated July 11 quality assurance program,(TVA-TR75-1A) as required by 10 CF Su.55(f).
Additional clarification was provided in TVA letters dated May 18, n
1984 and August 31, 1984, in response to questions transmitted by my letters dated December 30, 1983, and July 3,1984. Our review of this information indicates that the TVA quality assurance program continues to satisfy 10 CFR 5 Appendix 0 requirements and is therefore acceptable.
Please contact us if you have any questions concerning this letter.
appreciate your thely submittal and prompt responses to our questions regar We the information required by 10 CFR 50.54(a) and 50.55(f).
Sincerely.
(Original signed by RClewis)
Richard C. Lewis, Director Division of Reactor Projects J. W. Anderson, Manager cc:
Office of Quality Assurance L. M. M'..ls, Manager Nuclear Licensing R. J. Mullin, Manager Division nf Quality Assurance m :;;;0277 041012 PDR ADOCK 05000259 p
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d We believe the information presented herein is adequate to formally close out the subject allegation.
If more information is needed or if there is any question, contact Jack Spraul on x24530.
Original signed by Brian K. Grimes, Director' Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement cc:
C. Stahle, NRR
Enclosures:
As stated Distribution:
DC5 016j POR QAB Reading DQAVT Reading JMTaylor, IE RHVollmer, IE BKGrimes, IE GTAnkrum, IE JLMilhoan, IE JLGilray, IE JGSpraul, IE OIA r '
/
QAB:0QAVT:IE B':DQAVT:IE QABj QAVT:IE C B:DQAVT:IE D:0QAVT:IE fiJGSpraul: art 91Gilray JLMi hoan GT rum BKGrimes fj 12/23 /85 12/33/85 2/d/85 1/
'/85 12/
/85
B. J. Youngtlood 2
We believe the information presented herein is adequate to formally close out the subject allegation. As you know, extensive NRC review is ongoing to evaluate the adequacy of the implementation of these, approved programs.
If more information is needed or if there is any question, contact Jack Spraul on x24530.
Original signed, by-Brian K. Grimes, Director Division of Quality Assurance, Vendor and Technical Training Center Programs Office of Inspection and Enforcement cc:
C. Stahle, NRR
Enclosures:
As stated Distribution:
DCS 016 PDR QAB Reading DQAVT Reading JMTaylor, IE RHVollmer, IE BKGrimes, IE GTAnkrum, IE JLMilhoan, IE JLGilray, IE JGSpraul, IE LSpessard. IE OIA h
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