ML20199G897
| ML20199G897 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/17/1997 |
| From: | Polston S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-7001-97-09, 70-7001-97-9, GDP-97-1043, NUDOCS 9711250330 | |
| Download: ML20199G897 (23) | |
Text
UAd Stasi i mnliment formatam n'adianh Mr Offac 7
j l'O lus 1410 PaJxah. AY 420ul Tel s02 441-5km ist 502 441.$K01 November 17,1997 l
United States Nuclear Regulatory Commission SERIAL: GDP 97-1043 Attention: Document Control Desk Washington, D.C. 20555-0001 Paducah Gaseous DlKusion Plant (PGDP)
Docket No. 70-7001 Response to inspection Report (Ill) 70-7001/97009 Notice of Violation (NOV) and Unresolved item (URI)
The Nuclear Regulatory Commission's (NRC) letter dated October 17,1997, transmitted the subject IR which contained one NOV and requested a respor.se to one URI. The United States Enrichment Corporation's (USEC) response to this violation and the URI is provided in Enclosures 1 and 2, respectively. Enclosure 3 lists the commitments made in this repon.
If you have any questions regarding this submittal, please contact Bill Sykes at (502) 441-6796.
Sincerely, Steve Polston General Manager Paducah Gaseous Diffusion Plant SP.DCil:mlg Enclosures (3) bl cc:
NRC Region 111 NRC Senior Resident inspector, PGDP 9711250330 971117 PDR ADOCK 07007001 C
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ENCLOSURE 1 UNITED STATES ENklCllMENT CORPORATION (USEC)
REPLY TO NOTICE OP VIOLATION (NOV) 70-7001/97009-02
.blati0lLCittd 10 C: A 76 93," Quality Assurance," requires that the certificatee establish, maintain and execute a Quality Assurance Piogram (QAP) satisfying each of the applicable requirements of ASME NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities," or satisfying -
acceptable alternatives to the applicable requirerrents.
Section 2.2.3 of the Quality Assurance Program," Program Implementation," requires, in part, that procedures are established to ensure the Quality Assurance Program is implemented, and that these procedures are consistent with the requirements of the QAP.
Item 8 of Section 2.17.3 of the Quality Assurance Program," Quality Assurance Records,"
requires, in part, that quality assurance records are stored in facilities which meet the requirements of Supplement 17S-1, Section 4.4 of ASME NQA i-1989, except as noted in Appendix C of the Quality Assurance Program.
Appendix C of the Quality Assurance Program," Technical Justifications.or Exceptions to the Quality Assurance Program," requires, in part, that storage cabinets or shelving used in the vault be placed on a base tha' will give a minimum of six inches of clearance to the bottom of the first shelf or drawer, in ordwr to protect records from potential water damage.
Contrary to the atove, from March 3 through September 10,1997, the certificatee f4' " a store quality assurance records (drawings) in the vault with a minimum of six inches of clearance to the bottom of the first shelf drawer. In addition, the records management procedures implementing the Quality Assurance Program did not include this requirement.
1.
Beason for Violation PGDP quality assurance records in the C-100 Records Storage Vault were not stored with a minimum of six inches of clearance from the floor, and records management procedures implementing the Quality Assurance Progtam (QAP) did not include the subject requirement, due to a management oversight. That is, cognizant management failed to identify and, therefore, implement this provision of the QAP.
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11.
, Corrective Actions Taken and Fesults Achieved Responsible management took the following corrective actions to assure that the records storage provisions of the QAP were being fully implemented:
l 1.
Records located in the C-100 Records Storage Vault were elevated to provide a minimum of six inches of clearance from the floor. This action was completed on September 11,1997.
2.
Records Management / Document Control personnel were briefed to assure their awareness of the requirement to store quality assurance records in the C-100 Records Storage Vault a minimum of six inches from the floor. This a: tion was completed on September 12,1997.
3.
All drawers and shelves in the C-100 Records Storage Vault below the subject minimum (six-inch) level were labeled "Not for Records Storage." This action was completed on September 12,1997.
4.
Section 2.17, Section 2.17 of Appendix A, and Appendix C of the QAP, and Basic Requirement 17 and Supplernent 17S-1 of NQA 1-1989, were reviewed and it was confirmed that applicable requirements thereof have been identified and are being implemented (with the exception ofincluding the C-100 Records Storage Vault minimum level specification in records management procedures). This action was completed on November 6,1997.
These actions are intended to preclude recurrence of the subject violation, Ill.
Corrective Action to be Taken Ily December 5,1991, the PGDP procedure for storage and inspection of stored records (UE4-TO RM4203) will be revised to reflect the requirement to store quality assurance records in the C-100 Records Storage Vault a minimum of six inches from the floor.
IV.
Lble of Full Compliance USEC will achieve full compliance with the s.ibject requirements by December 5,1997.
El-2
ENCLOSURE 2 UNITED STATES ENRICHhiENT CORPORATION (USEC)
REPLY TO UNRESOLVED ITEh! (URI) 70-7001/97009-01 6
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[T]he inspectors identified that some of the supplementary requirements of AShG NQA 1-1989, for which an exception or alternative was not approved, may not be included in the procedures implementing the QAP [ Quality Assurance Program). Ilowever, a final determination could not be made during the inspection because of the inconsistencies in the QAP and the volume of procedures implementing the QAP. The apparent failure to implement those supplementary requirements of AShiE NQA-1-1989 for which the QAP did not specifically identify exceptions or acceptablL alternatives is an Unresolved item (URI) requiring further review by the NRC (URI 70-7001/97009-01) (IR 97009, Details, Section Ql.l.b, Page 4)
[T]he NRC requests a response to Unresolved item (URI) 70-7001/97009-01... Your response should provide the United States Enrichtunt Corporation'= cosition as to which supplementary requirements of AShiE NQA 1 1989 it has implementes, slo a with any supporting documentation, and which supplementary requirements are currently not be'ng implenunted at either of the Gaseous Diffusion Plants. The response should not include those supplements for which specific exceptions or alternatives have been approved in the Quality Assurance Program (for example, Sections 2.2.4 and 2.17.3.8 of the Quality Assurance Program specify an acceptable alternative and an exception with a technicaljustification, respectively). The response should include the rationale for not implementing any supplementary requirements for which an exception or alternative has not been approved. (IR 97009, Cover Letter, Page 1)
Besponse:
USEC has implemented a Quality Assurance Program (QAP) meeting NQA-1-1989 Basic Requirements and Supplements. Each of the NQA-1-1989 Supplements "I General" section state sat "It supplements the requirements of Basic Requirement of this standard and shall be used in conjunction with that Basic Requirement when and to the extent specified by the organization invoking this standard". USEC's interpretation was that if an NQA 1 Supplement requirement
.was omitted from the QAP, USEC did not commit to the item since it was not "specified" as allowed by the standard. Selected portions of the NQA-1-1989 supplements were omitted from the QAP as allowed by the standard in the statement above. USEC now understands that it is NRC's position that unless an exception or alternative was identified, then USEC committed to all the NQA 1 Supplement requirements, even if not specified in the QAP.
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In response to URI, USEC performed a review of the NQA-1-1989 Supplement requirements to the Quality Assurance Program. Based on this review, USEC concluded that the omissions did not impact the overall effectiveness of the QAP because they were: geaerally minor in nature;
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prosided details of commitments already made in the QAP; were already included in procedures; or did not apply to Gaseous Diffusion Plant operations. Attachment A provides a matrix of the NQA 1 1989 Supplement requirements omitted from the QAP. Additionally, this matrix provides a reference to procedures that implement the NQA 1 1989 Supplement requirements at both GDPs or provides a brief comment concernind the omission. Furthermore, the matrix includes a ref:rence to the QAP section that, when revised, will include the commitment, alternative or exception.
1 in order to clarify our commitments and avoid future misunderstandings ofinterpretation, USEC -
will revise the QAP to include a commitment, alternative or exception, including appropriate i
justification for each omission identified in Attachment A The QAP revision will be submitted to the NRC by January 30,1998.
Additionally, pursuant to a discussion between hir. Krsek of NRC, and hir. Robert Lawton and i
hir Russ Wells of USEC, it is our understanding that the NRC is not requiring USEC to provide the documentation demonstrating which requirements of AShiE NQA-1-1989 we have implemented. This documentation is available at the GDPs for NRC review.
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NQA-1 vs QAP vs Procedures Comparison PGDP NQA-1 Supplements NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 35-1 Design documents shall be adequate to support 233.2.1 Essentially in QAP Section 23.1.
3 Design Process facility design, construction, and cperation llowrver will provide an para. I alternative and add "for design documents generated after NRC regulation" to the NQA-1 words.
Supplement 3S-1 reasons for the changes 233.2.2 included in QAP Section 3 Design Process 233.13 forinputs which para. 2 includes standards.
Applicable information derived from experience, as 233.2.4 May provide an exception or set forth in reports or other documentation, shall be alternative.
made available to cognizant design personnd.
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NQA-1 vs QAP vs Procedures Comparison PGDP NQA-1 Supplements NQA-1 Words Omitted To beIncluded Couuuents -
Omitted from QAP in QAP Section
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Supplement 35-1 The results of design verification shall be clearly 233.4.1 Implemented in the following 4 - Design Verification documented with the identification of the verifier procedures:
para I clearly indicated.
UE2-TO-EG1031 (6.7 & Note) para. 2 CP3-EG-EG1075 (6.2,6.4, App.
...or provided the supervisor is the only indhidual in 23 3.4.2 A) the organization competent to perform the CP3-EG-EG1075 (6.2,6.4, App.
veri 5 cation. Cursory reviews do mt satisfy the intent A) of this standard.
Verifice. tion shall be performed in a timely manner.
233.43 Design verification, for the level of design acthity accomplished, shall be performed prior to release for procurement, manufacture, construction, or release to another organization for use in other dr. sign acthities except in those cases where this timing cannot be met, such as when insufficient data exist. In those cases, the unverified portion of the design shall be identified and contrtilled.
E2-5
NQA-1 vs QAP vs Procedures Comparison PGDP NQ/.-l Supplements NQA-1 Words Omitted To beIncluded Comments Omitted from QAP in QAP Section 4.1 Extent of Design Ver.
Where the design has been subjected to a verification 23 3.4.4 Implemented in the following process in accordance with this Standard, the procedure-verification process need not be duplicated for UE2-TO-EGIO31 (6.6.6 Note) identical designs. However, the applicability of stand rdized or previously proven designs, with respect to meeting pertinent design inputs, shall be verified for each spplication. Known problems afTecting the standard or previously proven designs and their effects on other features shall be considered.
The original and associated verification neasures shall be adequately documented and referenced in the files of subsequent application of the des.gi.
.4.2.1 The words have not been duplicated due to the extent 233.4.5 Implemented in the following of the text.
procedure:
CP3-EG-EGIO75 (App. A, C) 4.2.2 The words have not been duplicated due to the extent 233.4.5 Implemented in the following of the text.
procedures:
CP3-EG-EG1075 (6.2.4)
CP3-EG-EGIO78 4.23 The words have not been duplicated due to the extent 233.4.5 Implementedin the following of the text.
procedure-CP3-EG-EG1075 (6.2.5)
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4 NQA-1 vs QAP vs Procedures Compariscn PGDP-l
[
. NQA-1 Supplements NQA-1 Words Omitted To be Included Comments j'
Omitted from QAP in QAP Section i
1 j.
6-Inte: face Contrc.1 Tr.ns.uittels shall identify the status of:ae design 233.63 Li@med in the foBowing
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para. 2.
information or document presided and, where procedure-necessary, identify incomplete L uns which require UF2-TO-EG1031 (6.11)
[
further evaluation, review, or approv::1. Where it is i
necessary to initially transmit design information _
i orally c by other infornwl means, the transmittal shall l
be confund promptly by a controlled document.
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1 7-Documents and Records The documentation shall include not only final design 23.3.7 hoplementedin the following i
documents, such as drawings and specificatiocs, and procedure:
revisions thereto but also documentatic,n which UE2-TO-EG1031 (6.4.2, App. I) identifies the important steps, mcluding sources of 1.
design inputs that support the final desigrt l
Supplement 4S A statement of the scope ofwork to be performed by 2.43.1.1 Implementedin the fouowing 4
2.1-the supplier shall be in the procurement docuraents.
procedures:
UE2-US-PC1035 (6.11) i UE2-EG-EG1051 l
3 Supplement 4S-1 The time ofst.c nittal shall be established.
2.43.1.5 hi=Hyin QAP Seedon 2.5 2.73.5.
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NQA-1 vs QAP vs Procedures Comparison PGDP NQA-1 Supplements NQA-1 Words Omitted To beIncluded Comments Omitted from QAP in QAP Section Supplement 75-1 These verification activities shall be conducted as 2.73.4 Verification activities are 5 - Supplier Perf. Eval.
early as practicable. The Purchaser's verification included in specifications or aethities, however, shall not relieve the Supplier of other procurement documents.
his responsibilities for verification of quality achievement.
Supplement 7S-1 Prior to offering the item or senice for acceptance, 2.73.6 Essentially imbedded in 8.1 the supplier shall verify that the item being furnished 2.73.7 implementadon of NQA-1 complies with the procurement requirements. VTere Supplement 7S-1,8.2, QAP required by code, regulation, or contract requirement, Sections 2.43.1.1, 2.43.1.2, documentary evidence that items conform to 2.73.4.1-3,2.73.6.1.
procurement documents shall be available at the Will proside an alternathe for facility site prior to installation or use.
" prior to installation or use". W l d
commit to " prior to relying on theitem foritsintended function".
Supplement 7S-1
...whose function and position is described in the 2.73.6.1.d QAP Section 2.73.6.1.d 8.2.1.d Purchaser's or Supplier's quality assurance program.
required person responsible for quality assurance function and would review the remainder under Section 1, " Organization".
1 E2-8
NQA-1 vs QAP vs Procedures Comparison PGDP NQA-1 Supplements NQA-1 Words Omitted To be Included Commeres Omitted from QAP in QAP Section t
Supplement 7S-1
...and it shall be implemented to monitor, witness, or 2.73.6.2 Thisis a rest:tement ofthe S.2.2 observe activities.
obvious reason for the source verification activity.
Supplement 8S-1 This identification shall relate an item to an applicable 2.83.1 May provide an exception or 2.1 design or other pertinent specifyir.g document.
altemative.
Supplement 9S-1 These means shall assure that process parameters are 2.93.1.2 Codes or standards would 2 Process Control controlled and that specified emironmental conditions contain proper requirements.
are maintained.
Supplement 95-1 Conditions necessary for accomplishment of the 2.93.1.4 Codes or standards would 3.1.2 process shall be included in p ocedures or contain proper requismuus.
instructicus. These conditions shall include proper QAP Sections 2.93.1.2,2.93.2, equipment, controlled parameters of the process, and and 2.123 for M&TE essentially calibration requirements.
cover this.
Supplement 9S-1 For special processes not covered by existing codes 2.93.1.5 This presides an optionif 3.4 and standards or where quality requirements specified outside a code or standard. GDP for an item exceed those ofexistmg codes or process requirements, other than standards, the necessary requirements for welding, heat treating and qualifications ofpersonnel, procedures, or equipment ncndestructive testing, are shall be specified or referenced in the procedures or addressed in the SAR. Procedure instructions.
UE2-QA-QI1032 implements this requirement.
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NQA-1 vs QAP vs Procedures Comparison
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PGDP NQA-1 Supplements NQA-1 Words Omitted To beIncluded Comments.
' Omitted from QAP in QAP Section Supplement 105-1 Inspections by persons du:ing on-the-job training for 2.103.2 QAP Section 2.2.4 commits to 2.2, para. 2 qualification shall be performed under the direct the q=E% tion requirements for observation and supervision of a qualiSed person and irtworsin accordance with verification ofconformance shall be by the qualified.
NQA-1. Supplement 2S-1.
i i
person until certification is achieved.
Procedure UE4-QA-Qll101 I
implements the additional requirements of 2.2, para. 2.
Supplement 10S-1 A combination ofinspection and process monitoring 2.103.4 QAP Section 2.103.4 included i
5.2.1 methods, when used, shall be performed in a the commitment for a systematic manner to assure that the speci6ed amui. tion ofinspection and -
i requirements for control ofthe process and quality of monitoringin Supplement 10S-1, the item are being achieved throughout the duration 5.1. However, the details of I
of the process.
SuWca 10S-1,5.2.1 and p
5.2.2 were not included.
5.2.2 Controls, where required, shall be established and l
documented for the coordination and sequencing of these activities at established 'mspection points dunng successive stages of the conducted process or construction.
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Supplement 10S-1 The acceptance ofan item shall be documented and 2.103.9 Essentially required by QAP I
63 apprtwed by authorized personnel.
Sections 2.103.9 and 2.103.11.
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NQA-1 vs QAP vs Procedures Comparison PGDP NQA-1 Supplements NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 10S-1 Words not restated here.
The GDPs are not required or 7 - Inservice Inspection committed to Insenice 7.1,7.2 Inspection to the ASME Code (QAP 2.103.6)
Section XI and is not app 5 cable.
(NRC Question QAQ9)
Covered adequately by TSRs, calibrations, PMs, etc. Take 1
exception in QAP, Appendix C.
T Supplement 12S-1 The method and interval for calibration for each i:em 2.1233 Cahhation intervals were 3.2 shall be defined, based on the type of equipment established mamj yrars ago at the stability characteristics, required accuracy, intended GDPs. Calibration Program use, and other conditions affecting measurement improvement efforts are control.
ongoing.
Supplement 17S-1 Documents shall be considered valid records only if 2.173.2 Includedin SAR Section 23 stamped, initialed, or signed and dated by authorized 6.10.13.
personnel or otherwise authenticated.
Supplement 18S-1 Audit personnel have sufficient authority and 2.18.1 Included in SAR Section 6.1.
3.2 organizational freedom to make the audit process meaningful and effective.
E2-11
l NQA-1 vs QAP vs Procedures Comparison PORTS NQA-1 Supplemer.s NQA-1 Worrs' Omitted To be Ixiuded Comments in QAP S.x: tion Omitted from QAP 2.33.2.1 Essentially in QAP Section 2 3.1.
Supplement 3S-1 Design documents shall be adequate ie supoort However will perside an 3 Design Process facility design, construction. =d operation.
alternative and add "for design para. I documents generated after NTC rtgulation" to the NQA-1
)
words.
j Supplement 3S-1
... reasons for the chang:s 2.3.3 2.2 Included in QAP Section f
2.3.3.13 for inputs which 3 Design Process includes standards.
l para. 2 Applicable information derived from experience, as 2.3.3.2.4 May prmide an exception or alternative.
set forth in reports or other documentation, shall be made available to cogninnt design personnel.
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NQA-1 vs QAP vs Procedures Comparison -
PORTS NQA-1 Supplements NQA-1 Words Omitted To be faciuded Comments Omitted from QAP in QAP Section Supplement 3S-1 The results of design verification shall be clearly 233.4.1 Implemented in the following 4 - Design Verification documented with the identification of the verifier p ocedures:
para.I clearly indicated.
UE2-TO-EG103i (6.7 & Note)
XP3-EG-EG1079 (6.2,6.4, or provided the supervisor is the only individual in 233.4.2 App.B) the organization competent to perform the XP3-EG-EG1079 (6.2, 6.4, verification. Cursory reviews do not satisfy the intent App.B) of this Standard.
para. 2 Verification shall be performed in a tirr.ely manner.
233.43 Design verification, for the level ofdesign actisity accomplished, shall be performed prior to release for procurement, manufacture, construction, or release to another organization for use in other design activities except in those cases where this timing cannot be met, such as when insufficient data exist.
In those cases, the unverified portion of the design shall be identified and controlled.
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NQA-1 vs QAP vs Procedures Comparison PORTS NQA-1 Supplements NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section 4.1 Extent of Design Ver.
Where the design has been subjected to a verification 233.4.4 Implemented in the following process in accordance with this Standard, the procedure:
verification process need not be duplicated for UE2-TO-EG1031 (6.6.6 Note) identical designs. However, the applicability of standardized or previously proven des;gns, with respect to meeting pertinent design inputs, shall be verified for each application. Known prcblems affecting the standard or previously preven designs and their effects on other features shall be considered. The original and associated verification measures shall be adequately documented and referenced in the files ofsubsequent application of the design.
4.2.1 The words have not been duplicated due to the 23 3.4.5 Impleraentedin the following extent of the text.
procedure:
XP3-EG-EGIO79 (App. B, C) 4.2.2 The words have not been duplicated due to the 23 3.4.5 Implemented in the following extent ofthe text.
procedures:
XP3-EG-EG1079 (6.2.4)
XP3-EG-EG1080 4.23 The words have not been duplicated due to the 23 3.4.5 Implemented in the following
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extent of the text.
procedure:
XP3-EG-EG1079 (6.2.5)
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2 NQA-1 vs QAP vs Procedures Comp:.rison PORTS NQA-1 Supplements NQA-1 Words Omitted To leduded Comments OmitL:d from QAP in Q AP Section 6 -Interface Control 1 ransmittels shall identify the status of the design 2.3.3.63 Impkmented in t;.e following para. 2 information or document provided and, v;here 7 procedure:
necessary, identify incomplete items which require UE2-TO-EG1031 (6.11) further evaluation, review, or approval. Where it is necessary to initially transmit design information orally or by other informal means, the transmittal shall be confirmed promptly by a controlled document.
7 - Documents and Records The documentation shall include not only fmal design 23.3.7 Implemented in the folloicing i
documem: ;uch as drawings and specifications, and procedure:
revisions thereto but also documentation which UE2-TO-EG1031 (6.4.2, App. I) identifies the important steps, including sources of design inputs that support the final des:;n.
Supplement 4S-1 A statement of the scope of work to be performed 2.43.1.1 Implemented in the following 2.1 by the supplier shall be in the procuremert procedures:
documents.
UE2-US-PC1035 (6.2.1)
UE2-EG-EG1051 Supplement 4S-1 The time of submittal shall be established.
2.43.1.5 Essentially in QAP Section 2.5 2.73.5.
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L NQA-1 vs OAP vs Procedures Comparison PORTS NQA-1 Supplements NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 7S-1 These verification activities shall be conducted as 2.7.3.4 Verification activities are 5 - Supplier Perf. Eval.
early as practicable. The Purchaser's verification included in specifications or activities, however, shall not relieve the Supplier of other procurement documents.
his responsibilities for verification of quality achievement.
Supplement 7S-1 Prior to offering the item or service for acceptance, 2.7.3.6 Essendallyimbedded in 8.1 the supplier shall verify that the item being furnished 2.7.3.7 implementation of NOA-1 complies with the procurement requirements. Where Supplement 7S-1, S.L QAP rcquired by code, regulation, or contrsct Sections 2.4.3.1.1, 2.4.3.1.2, requirement, documentary evidence that items 2.7.3.4.1-3,2.73.6.1.
conform to procurement documents shall be Will provide an alternative for available at the facility site prior to installation or
" prior to installation or use". Will l
I connait to " prior to relying an use.
the item foritsintended function".
Supplement 7S-1
...whose function and position is described in the 2.7.3.il.d QAP Section 2.73.6.1.d 8.2.1.d Purchaser's or Supnlier's quality assurance program.
required person responsible for quality assurance function and would review the remainder under Section 1, " Organization".
E2-16 i
NQA-1 vs QAP vs Procedures Comparison PORTS NQA-1 Supplements NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 7S-1 and it shall be implemented to monitor, witness, or 2.73.6.2 This is a restatement of the 8.2.2 observe activities.
obvious reason for the source verification actisity.
Supplement 8S-1 This identification shall relate an item to an 2.83.1 May provide an exception or 2.1 applicable design or other pertinent specifying alternative.
document.
Supplement 9S-1 These means sha'l assure that process parameters are 2.93.1.2 Codes or standards woulJ 2 Process Control controlled and that specified environmental contain proper requirements.
conditions are maintained.
Supplerrrert 9S-1
' Condities necessary for accomplishment of the 2.93.1.4 Codes or standards would 3.1.2 process shall be included in procedures or contain proper requirements.
instructions. These conditions shall include proper QAP Sections 2.93.1.2,2.03.2, equipment, controlled parameters of the process, and and 2.123 for M&TE essentially calibration requirements.
cover this.
Supplement ')S-1 For special processes not covered by existing codes 2.93.1.5 This provides an option if 3.4 and standards or where q,tality requirements outside a code or standard. GDP specified for an iterr. exceed those of existing codes process requirements, other than or standards, the necessary requirements for welding, heat treating and -
qualifications of personnel, procedures, or equipment nondestructive testing, are shall be specified or referenced in the procedures or addressed in the SAR. Procedure instructions.
UE2-QA-QI1032 implements this requirement.
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NQA-1 vs QAP vs Procedures Comparison PORTS NQA-1 Suppleme::ts NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 10S-1 Ospections by persons during on-the-job training for 2.10.3.2 QAP Section 2.2.4 commits to 2.2, para. 2 qualification shall be performed under the direct the qualification requirements for observation and supervision of a qualified person and inspectors in accordance with verification of conformance shall be by the qualified NQA-1, Supplement 2S-1.
person until certification is achieved.
Procedure UE4-QA-QIl101 implements the additional e
requirements of 2.2, para. 2.
Supplement 10S-1 A combinatio:' ofinspection and process monitoring 2.10.3.4 QAP Section 2.10.3.4 included 5.2.1 methods, when used, shall be performed in a the commitment for a systematic manner to assure that the specified combination ofinspection and requirements for control of the process and quality monitoringin Supplement 10S-1, 5.2.2 -
of the item are being achieved throughout the 5.1. However, the details of duration of the process.
Supplement 10S-1,5.2.1 and 5.2.2 were not included.
Controls, where required, shall be established and documented fbr the coordination and sequencing of these activities at established inspection points during successive stages of the conducted process or construction.
SuppRment 10S-1 The ecceptance of an item shall be documented and 2.10.3.9 Essentially required by QAP 6.3 approved by authorized personnel.
l Sections 2.10.3.9 and 2.10.3.11.
E2-18
NQA-1 vs QAP vs Procedures Comparison PORTS NQA-1 Supplement.=
NQA-1 Words Omitted To be Included Comments Omitted from QAP in QAP Section Supplement 10S-1 Words not restated here.
The GDPs are not required or comn-itted to inservice 7 -Inservice Inspection Inspection to the ASME Code j
7.1,7.2 Section XI and is not applicable.
}
(QAP 2. iO3.6)
I (NRC Question QAQ9)
Cavered adequately by TSRs, calibrations, PMs, etc. Take exception in QAP, Appendix C.
Supplement 12S-1 The method and interval for calibration for each item 2.123 3 Calibrs' ion intervals were 3.2 shall be defined, 'oased on the type of equipment establishui many years ago at the l
I stability characteristics, required accuracy, intended GDPs. Calibration Program l
use, and other conditions affecting measurement improvement eiTorts are control.
ongoing.
Supplement 17S-1 Documents shall be considered valid records only if 2.173.2 Includedin SAR Section 23 stamped, initialed, or signed and dated by authorized 6.10.1 3.
personnel or otherwise authenticated.
Supplement 18S-1 Audit personnel have suflicient authority and 2.15' 1 Included in SAR Section 6.1.
3.2 organizational freedom to make the audit process meaningful and effective.
E2-19
ir ENCLOSURE 3 i LIST OF COMMITMENTS
_By December 5,1997, the PGDP procedure for storage and inspection of stored records (UE4--
- TO-RM1203) will be revised to reflect the requirement to store quality assurance records in the C.100 Records Storage Vault a minimum of six inches from the floor.
Ene'osum 2 -
In order to clarify our commitments and avoid future misunderstandings ofinterpretation, USEC
- will revise the QAP to include a commitment, alternative or exception, including appropriate.
justification, for each omission identified in Attachment A. The QAP revision will be submitted to the NRC by January 30,1998.
2 d
ELI -
p
.