ML20150D845

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Ack Receipt of 781114 Response to NRC Questions Re Proposed Revision 2 to TVA-TR75-1A, QA Program Description for Design,Constr & Operation of TVA Nuclear Pwr Plants. Forwards List of Unacceptable Responses
ML20150D845
Person / Time
Issue date: 11/28/1978
From: Haass W
Office of Nuclear Reactor Regulation
To: Gilleland J
TENNESSEE VALLEY AUTHORITY
References
NUDOCS 7812070085
Download: ML20150D845 (3)


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DISTRIBUT10:1:

h Entral File QAB Projects NOV 8 81978 A FChron. File IRC PDR DJSkovholt, DPf1 Dross, DPfl HSilver, LWR #4' Mr. J. E. Gilleland Cllale, IE Assistant Manager of Power JSpraul,QAB Tennessee Valley Authority WBelke, QAB 830 Power Building JGilray, QAB Chattagooga, Tennessee 37401

Dear Mr. Gilleland:

SUBJECTi REVISION 2 TO TVA'S TOPICAL REPORT TVA-TR75-1A Your letter of fiovember 14, 1978 responded to questions which we had asked about the proposed Revision 2 to TVA's Topical Report TVA-TR75-1A, " Quality Assurance Program Description;for Design, Construction, and Operation of TVA flu'. lear Power Plants." While the responses are generally acceptable, there are several which do not appear to be so. Please respond to the attac. ca positions of the staff.

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Should you have any questions regarding our review. or if we can provide any assistance, please feel free to contact'me or Mr. Jack Spraul at ' -

(301) 492-7741 S

Sincerely, '

.Originaliigned by Walter P. Haass 1

I Walter P. Haass, Chief Quality Assurance Branch Division of Project Management l

Attachment:

l Regulatory Staff Position .

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Regulatory Sta ff Position TVA Topical Report on QA 1A. The respanse to item 1 is unacceptable. It is the staff position that, when QA/QC organizations do not report to the QA Manager, the QA Manager must a) review and approve the procedures of the QA/QC organization, b) be responsible for training the QA/QC personnel, and c) audit these QA/QC organizations to assure proper functioning.

Please reinstate the commitment to item b which has been deleted by the proposed Revision 2.

3A. The submittal of November 14, 1978, without calling it to our attention, added the following words on page 17.2-28:

"These files will be utilized in determining the accept-ability of vendor QA programs. If inadequate vendor information is available, a QA program evaluation will be performed."

and deleted the following words:

l "As a minimum the survey team shall consist of a representative from either a plant quality assurance staff, PRP (for nuclear fuel and related components), or the central office Quality Assurance and Audit Staff. The survey team may include representatives from both plant and central office quality assurance staffs and other qual. vied specialists as needed.

"The Quality Assurance and Audit Staff shall review purchase documents for nuclear safety-related services and items not purchased by pa t numbers or specific standards or whose failure would violate the reactor pressure boundary (except nuclear fuel) and shall provide for any additional vendor pre-award surveys or QA program reviews that may be required. Items purchased by 0EDC shall be handled in accordance with its quality assurance program."

It is not obvious that the commitments are comparable. Please explain (What is a QA program evaluation? What organization performs same?

etc. ) and justify these changes.

1 . . . -

l 4A. The response to item 4 is unacceptable. As noted in item 5 under t

criterion 17.2.5 of the Standard Review Plan (p.17.2-11), it is the staff position that the QA organization review and concur with test procedures. By TVA's having QA represented on the PORC and by having the PORC review test procedures, the staff believed that TVA was meeting our acceptance criteria. By deleting PORC review of test procedures, TVA no longer appears to be meeting the Standard Review Plan acceptance crit.erion noted. Please clarify how TVA meets the noted criterion or provide some alternative for the staff's evaluation.

SA. The response to item 5 is unacceptable. The following words are still missing from part 17.2.15 of the topical report:

"It (the Nonconforming Material Report) contains sufficient information to identify affected equipment, identify type of nonconformance, and permit quality assurance evaluation. They shall be periodically reviewed by the plant QA L aff to identify generic problems and trends. Generic problems and trends as determined from these reviews will be reported to the plant superintendent."

Please replace these words or justify not doing so.

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