ML20138H487

Intervenor Exhibit I-CCANP-124,consisting of 810121 Memo Forwarding Auditor Handbook on Deficiency Reporting,

ML20138H487
Person / Time
Site:	South Texas
Issue date:	08/06/1985
From:	Fite B AFFILIATION NOT ASSIGNED
To:	Ulrey R AFFILIATION NOT ASSIGNED
References
OL-I-CCANP-124, NUDOCS 8510290053
Download: ML20138H487 (19)

Text

{{#Wiki_filter:b* f fb$ 'Y$ l -{. ! q 3 q~, f ~ I CFFICE MEMORANDUM (( (( /~~/, pe [ To R.L. Ulrey January 21, 1981 NSL -027 From B.J. Fite Subject Auditor's H d ook on Deficiency Reporting) d ~ Enclosed are twenty-five copies of the Auditor's' Handbook on Deficiency Reporting. This manual was prepared by the Nuclear Licensing Acministration Section to assist your auditors in evaluating the reportability of defects and noncompliances as requred by 10 CFR 50.55(e) and 10 CFR 21. Additional copies are available upon request. BJF/dmh cc: J.R. Sumpter R.A. Frazar -..mn. u.. ..a.,,,Sido-flBOLna,,,,,...etn>ip/M

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2 AUDITOR'S HANDBOOK ON DEFICIENCY REPORTING Prepared by Licensing Administration Section Nuclear Safety & Licensing Houston Lighting & Power Company October 22, 1980 L

TABLE OF CONTENTS 1. QA Criteria II. Condition of Construction Permit III. Reporting of Defects IV. Guidance - I&E Inspection Manual V. NUREG 0302, Rev. 1 VI. STP Procedure for Deficiency Reporting 4 i h g g ql s , e 1 8 fI. 1

1 a I. QUALITY ASSURANCE CRITERIA FOR NUCLEAR POWER PLANTS AND FUEL REPROCESSING PLANTS l Every applicant for a construction permit is v2 quired by the provisions of paragraph 50.34 to include in its preliminary safety analysis report l a description of the quality assurance program to be applied to the design, i i fabrication, construction, and testing of the structures, systems and components of the facility. Every applicant for an operating license is required to include, in its final safety analysis report, information pertaining to the managerial and administrative controls to be used to assure safe operation. Nuclear power plants and fuel reprocessing plants include structures, systems and components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public. This appendix establishes quality assurance requirements for the design, construction and operation of tnose { structures, systems and components. The pertinent requirements of this l appendix apply to all acitivities affecting the safety-related functions of those structures, systems, and components; these activities include designing, purchasing fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling and modifying. 4 A. Organization 1 1 l 1. The applicant shall be responsible for the establishment i l and execution of the quality assurance program, j l I While the term " applicant" is used in these criteria, the requirements are, of course, applicable after such a person has received a license to i construct and cperate a neuelar power plant or a fuel reprocessing plant. l These criteria will also be used for guidance in evaluating the adequacy of quality assurance programs in use by holders of construction permits and operating licenses. 1 I i, . - -,.. ~ - -. _ _. ,.m ,,,,_y

2. The applicant may delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall ,r retain responsibility therefor. 3. The authority and duties of persons and organizations performing - i activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated i. i. in writing. 4. These activities include both the performing functions of i l attaining quality objectives and the quality assurance funct, ions. 5. The quality assurance functions are, those of: i a. Assuring that an approporate quality assurance program is 4 1 .e. + established and effectively executed, and i i. .h b. Verifying, such as by checking, auditing, and inspection, that t 1 ( e activities affecting the. safety.related funcitons have,been correctly performed. ii tun l 6. The persons and organizations performing quality assurance J ~ functions shall have sufficient authority and organizatio,nal .u,i. i. i-a r,. l freedom: i i a. To identify quality problems; b. To initiate, recommend, or provide solutions; and a .a To. verify implemer.tation of solution,s. c. i 7. Such persoils and organizations performing quality assurance i,.. t functions shall report to a management level such that this required authority and organizational freedom, incl,uding sufficient independence from cost and schedule when opposed j l to safety considerations, are provided.

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'l B. Because of the many variables involved, such as the number of personnel, the type of activity being performed, and the location or locations where activities are perfonned, the organizational structure for executing the quality assurance program may take ~ various forms provided that the persons and organizations assigned the quality assurance functions have this required authority and organizational freedom. 9. Irrespective of the organizational stru'cture, the' individual ('s) assigned the responsibility for assuring effective execution ) of any portion of the' quality assurance program at any location i where activities subject to.this Appendix are being performed shall { have direct access to such' levels of management as may be necessary to perform this function. B. Quality Assurance Program 1. The applicant shall establish at the earliest practicable " ^ time, consistent with the schedule for ' accomplishing' the activities, a quality assurance program which compiles with the requirements of this appendix. 2. This program shall be: a. Documented by written policies, procedures, or instructions and shall be b. Carried out throughout pla'nt life in accordance with those I policies, procedures, or instructions. 3. The applicant shall"' identify: i i... ...i.1 t. 4 i a. The structures, systems, and components to be covered by 6t. + l .the quality assurance program and b. "The major organizations participating in the program, i i together with the designated functions of these organizations. l -~_.

4. The quality assurance program shall provide control over activities affecting the qualityof the identified structures, systems, and components,.to an extent consistent with their importance to safety. 5. Activities affecting quality.sha)) be accomplished under suitably controlled conditions., 6. Controlled conditions include: a. The use of,approporate equipment; i. ) b. Suitable environmental conditions for accomplishing the. .actjvity, such as adequate. cleanness; and c. Assurance that all prerequisities.for the given activity.have. i l .been satisfied... i, :. 3 7. The: program shall take i.nto account the need for: 4 e ,a. Special controls, b. Processes, > ,;i, c. Test. equipment,- j d. . Tools, and, t :,. e. Skills to attain the required quality, and the need for 1 l f. Verif.ication of quality by inspection, and test. j S. Tne program shall provide for indoctrination and training of,, personnel performing activities affecting quality as i necessary to. assure that suitable. proficiency.is achieved and. I 1 maintained. n,_, 9. The applicant sh,al.1 regu.lacly review the status and adequacy of 1 ) the quality assuran,ce, program... . i,: 1 l

10. Managemen,t. of other. organizations participating in the l

quality assurance, program.shal.1 : regularly review the status I i and adequacy of,that part.of the, quality.assurence. program which l .they are executing. 1 l

C. Design Control 1. Measures shall be established to assure that applicable regula-tory r.equirements and the design basis, as defined in Paragraph 50.2 and as specified in the license applitation, for those structures, systems, and components to which this appendix applies are correctly trapslated into specifications, drawings, procedures, a,nd.. instructions.,, 2. These measures shall,1,nc.1,ude prpvisions to assure that appropriate qua',ity standards,are specified,and included in design documents and that deviations frpm such standards are controlled. 3. Measures shall, also be established for the selection and review for suitabi.lity of, appl,1, cation of materials, parts, equipment, and processes t' hat are essential to the safety-relate! functions of the structures systems and components. 4. Measures shall be. established for the identification and contro* of design 1,nterfaces and for coordination among participating design,orgapizations. 5. These measures shall include. the establishment of procedures among participating. design; o,rganizations; for the reylew, approval, releases,distribu,tjon,,andrevisionof,documentsinvolving design interfaces, g,,,, g ,,, 3 6. The design control measures shall provide for verifying or checking the adgguacy,of. design,,suc{, ape y the(performance,of design b i reviews, by the use of alternate or sirrplified calculational methods, or by, the performance.of a suitable _ testing program. 7. The verifying or checking process shall.be perfomed by individuals or groups,.other th,an those who perforty the original design,but who may,be from,th,e same organization. 8. Where a test program is used to verify the adequacy of a specific

i design feature in lieu of other verifying or checking processes, it shall include suitable qualification testing of a prototype unit under the most adverse design conditions. 9. Design control measures shall be applied to items such as the' j following: reactor physics, stress, thermal, hydraulic, and accidental analyses; compatibility of materials; accessibility j i for inservice inspection, maintenance,'and repair; and delineation i l of acceptance criteria for inspections and tests. 1 10. Design changes, including field changes, shall be: 1 a. Subject to design control measures commensurate with i j with those applied to the original design and be' li b. Approved by the organization that perfonned the original i l

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design unless the applicant designates another responsible 1 i u....., organization. O. Procurement Document Control i, 1. Measures shall be established to assure that applicable l regulatory requirements, design bases, and other' requirements which are suitabl'y' included or referenced in the documents for f t procurement of material', equipment, and services, whether 4 purchased by the applicant or by its contractors or' subcontractors. f 2. To the extent necessary, procurement documents shall require t t j contractors or subcontractors to provide a quality assurance j program consistent with the pertin'ent provisions of this appendix. n.. E. Instructions, Procedures, and Drawings-j 1. Activities affecting quality shall be:'ii, o. l a. Prescribed by documented instructions, procedures, or j drawings, of a type appropriate to the circumstances and i .. ni.

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b. Accomplished in accordance with these instructions, procedures, or drawings. 2. Instructions, procedures or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have,been. satisfactorily accomplished. F. Document Control 1. Measures shall be established,to control.the issuance of documents,.such as, instructions,. procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. 2. These. measures shall, assure.that, documents, including changes: a. Are. reviewed for, adequacy and approved for release by authorized. personnel and are b. Distributed to and used at the location where the prescribed activity is, performed. 3. a. Changes to documentsishall be.rev, jewed and approved by the, same organizations,, that performed the original review and approval, i. .c b. Unless the applicant designates another responsible organization. i G. Control-of Purchased Materi.al, Equipment, and Services 1. Measures shall berestablished to assure that purchased material, equipment,iand: services,.whether purchased directly. or through, contractors,,and;. subcontractors, conform to the procurement documents.. i,:, 2. These, measures shall include provisions., as, appropriate, for: a. Source evaluation and selection, 4 b. Objective evidence of quality furnisted by the contractor I or subcontractor

i c. Inspection at the contractor or subcontractor source, and d. Examination of products upon delivery. 3. Documentary evidence that material and equipment confonn to the procurement requirements shall be available at the nuclear power-plant or fuel reprocessing plant site prior to installation or use of such material and equipment. 4. This documentary evidence Shall be retained at the nuclear powerplant or fuel a. i.- reprocessing plant site, and Shalibesufficienttoidentifythespecificrequirements,such b. as codes, standards, or specifications, met by the pure.hased ,..i material and equipment. 5. The effectiveness of the control of quality by contractors 7, i. ,o i and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services, I. Indentification and Control of Materials, Parts, and Components 1. Measures shall be established for the identification and control of materials, part's, and components, including partially fabricated assemblies. 2. These measures shall assure that identification of the item is ~ maintained by heat number, part number, serial number, or t, other appropriate means, either on the item or on records ,q, ie-traceable to the item, as required throughout fabrication, erection, installation and use of the item. 3. These identification and control measures shall be designed to prevent the use of incorrect or defective material, parts, and i r- [ i ' + componenets.

J. Control of Special Processes 1. Measures shall be established to assure that special processes, including welding, heat treating, and nondestructive testing are: l

a. ' Controlled, and i

b. Accomplished'by qualified p'ersonnel using qualified procedures ' in accordance with applicable codes,' standards, specifications, criteria, and other special requirements. K. Inspection l. A progr'ain for inspection of activities affecting quality shall be: a. Established and b. Executed by or for the organization performing the activity to verify conformance with the documented instructions, l. ' procedures, and drawings'for~accompiishing the activity. 2. Such inspection shall be performed by individuals other than those who performed the activity'being' inspected. 1 3. Examinations, measurements,'or~ tests of material or products processed'shall be performed for each work operation where c necessary'to assure qualityi "' 2-4. If inspection of processed material-or products is impossible or disadvantageous, indirect control by monitoring processing methods, equipment, and personnel shall'be' provided. 5. Both inspection and process; monitoring shall be provided when control'is inadeq'uate without'both'.i l 6. If mandatory insp'ection' hold po'ini!sO which require witnessing f or 1'nspecting by'the' applicant's ' designated representative and 'beyon'd which work shall not proceed'without the consent of its designated representative are required, the specific hold i 2 points'shall be indicated in appropriate documents. i i m_. ..c

L. Test Control 1. A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is:

a...ldentified and b.

Performed in accordance with written test procedures which incorporate the requirements and acceptance limits I contained in applicable design documents.

2. " The test program shall include, as appropriate:

i a. Proof tests prior to installation, b. Preoperational test:, and i,i s c. Operational tests during nuclear power. plant or fuel i* reprocessing plant operation, of structures, systems, and 4 ...,. i.i i components. 3. Test procuedres shall include provisions for assuring that: All prerequistes for the given test have been met, that a. b. Adequate test instrumentation is available and used, and i o .s i i. c. The test is perfor,ed under suitable environmental conditions. 4 Test results shall be: i a. Documented, and .. r, u. i b. Evaluated to assure that test requirements have been satisfied. M. Control of Measuring and Test Equipment 1. Measures shall be established to assure that tools, gauges .as + ,/ instruments, and other measuring and testing devices used in 1i activities affecting quality are properly: .i , t a. Controlled, ll b. Calibrated, and adjusted at specified periods to maintain j accuracy within necessary limits. ~ s .--s ,-e , - -. - - - +., .,,.r ,e,n~

v N. Handling, Storage and Shipping 1. Measures shall be established to control the handling, storage, shipping, cleaning, and preservation of material ano equipment in accordance with work and inspection instructions to prevent damage or deterioration. 2. When 'necessary for particular products, special protective environments, such as inert Jas atmosphere, specific moisture ~ content -levels,' and temperature levels, shall be: a. Specified and t' b. Provided. 0. Inspection, Test and Operating Status 1. Measures shall be established'to indicate'by the use of markings'such as stamps, tags,' labels,. routing cards, or other suitable means, the status of inspections and test performed upon individual items of the* nuclear power plant or fuel reprocessing plant'. h* t-2. These measures shall provide for the identification of items, which have satisfactorily passed required inspections and tests, where necessary to preclude'inadvertant bypassing of such inspections- .and tests.' i' ' 3. Measures shall also be established for indicating the operating status of/ structures, systems, and components of the nuclecr f power plant or fuelIreprocessing plant, such as by tagging valves and switches'to; prevent inadvertent operation.. +n

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e P. Nonconforming Materials., Parts, or Components 1. Measures shall be established to control material, parts, or components which do not conform to requirements in order to prevent their inadvertent use of installation. 2. These measures shall include, as appropriate, procedures for: a. Identification, 'b. Documentation, c. Segregation, d. Disposition, and e. Notification to affected organizations. 3. Nonconforming items sh'all be: a. Reviewed and accepted, b.

Rejected, c.

Repaired or reworked in accordance with documented procedures. Q. Corrective Action I. Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances.are promptly identified and corrected. 2. In the case of signifcant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition. 3. The identification of the significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be: a. Documented and 4 b. Reported to appropriate levels of management.

r R. Quality Assurance Records 1. Sufficient records shall be maintained to furnish evidence of activities affecting quality. 2. The records shall include at least the following: ? Operatinglop,s,andthe a. b. Results of reviews, c. Inspections, d.

Tests, e.

Audits, f.

Monitoring of work performance, and g. Mat,erials analyses... 3. The records shall also include closely-related data such as e qualifications of personal, procedures, and equipment. 4. Inspection and test records shall, as a minimum: a. Identify the inspector or data recorder, i b. The type of observation, c. The results, i d. The' acceptability, and 4 e. The action ta en in connection with~ any deficiencies noted. 5. Records shall be identifiable and retrievable. 6. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such i as: ) o 64.i a.

Duration,

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( s. Audits 1. A conprehensive system of planned and periodic audits shall be carried out to: a. Verify compliance;with all aspects of the quality assurance program;and to b. Determine +the-effectiveness of the program. 2. The audits shall be performed: a. In.accordance with the written procedures or check lists b. By. appropriately trained personnel not haveing direct responsibilities.in,the areas.being audited. 3. Audit results shall be: a. Documented and. reviewed

b. :By. management having. responsibility in,the area. audited.

4. Fol,lowup action, including.reaudit of de,ficient areas, shall be taken where indicated. , e i. s s ,8 e I 6 e I 1. . I ! l,. .i5 .. at

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( e **.. II. 10 CFR 50.55 CONDITIONS OF CONSTRUCTION PERMITS Each construction permit shall be subject to the following terms and conditions: (e) (1) If the permit is for construction of a nuclear power plant, the holder of the permit shall notify the Commission of each deficiency found in design and construction, which, were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant, and which represents: (i) A significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B; or (ii) A significant deficiency in final design as approved and released for construction such that the design does not conform to the criteria and bases stated in the safety analysis report or construction permit; or (iii) A significant deficiency in construction of or significant damage to a structure, system, or component which will require extensive evaluation, extensive redesign, or extensive repair -to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function; or (iv) A significant deviation from performance specifications which will require extensive evaluation, extensive redesign, or extensive repair to establish the adequacy of a structure, system, or component to meet the criteria and bases stated in i

4 the safety analysis report or construction permit or to otherwise establish the adequacy of the structure, system, or component to perform its intended safety function. (2) The holder of a construction permit shall within 24 hours notify the appropriate Nuclear Regulatory Commission Inspection and Enforcement Regional Office of each reportable deficiency. (3) The holder of a construction permit shall also submit a written report on a deficiency within thirty (30). days to the appropriate N'RC Regional Office shown in Appendix D of Part 20 of this chapter. Copies of such. report shall be sent. to the Director of Inspection and Enforcement, U.S. Nuclear, Regulatory Commission, Washington, D.C. 20555. The report shall. include a description'of the deficiency, an analysis of the safety, implications and,the corrective action ~ taken,.and sufficient information to permit analysis and evalutaiton of the-de.ficiency and of the corrective action. If sufficient infor-mation.is not.available for a definitive report to be. submitted within 30 days,.an interim report containing all available a )), information shall be filed,itogether with a statement as to when a. complete report will be -filed. (4) Remedial action may be taken both prior to and after notification of the Division of. Inspection and. Enforcement subject to.the risk of subsequent disapprovaloof such. action by the Commission. I0* ,fI 4 4 e g i s' 3; .5 a e e' s.. et 1 e --}}