ML20207D487
| ML20207D487 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/24/1986 |
| From: | Mason C TENNESSEE VALLEY AUTHORITY |
| To: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| RTR-REGGD-01.038, RTR-REGGD-1.038 NUDOCS 8612310033 | |
| Download: ML20207D487 (21) | |
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- TENNESSEE VALLEY AUTHORITY CHATTANCOGA. TENNESSEE 37401 6N 38A Lookout Place DEC 241986 Mr. Brian.K. Grimas, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Grimes:
Enclosed is Draft 3 of Revision 9 to TVA's Topical Report, TVA-TR75-IA, " Quality Assurance Program Description for Design, Construction, and Operation of TVA Nuclear Power Plants." This revised draft is in response to the December 12, 1986 conference call between J. Gilray of NRC and David Lambert of TVA and supplements TVA's November 14, 1986 response to your letter dated August 1, 1986 to R. L. Gridley requesting additional information on Revision 9 to TVA-TR75-1A.
Enclosure 1 provides a justification for Regulatory Guide 1.38 exception.
Enclosure 2 provides revised responses to specific NRC questions. Enclosure 3 provides revised pages reflecting each response incorporated into the Topical Report and is submitted as Revision 9, Draft 3.
Since implementation of Revision 9 is a startup item for Sequoyah Nuclear Plant, expeditious completion of your review is requested. Pursuant to 10 CFR 50.54(a)(3)(iv) and 10 CFR 50.55(f)(3)(iv) an approval of Revision 9, with any exception, is requested.
If you have any questions concerning this matter, please get in touch with D. L. Lambert at (615) 751-2733.
Very truly yours, TENNESSEE VALLEY AUTHORITY C. C. Mason Acting Manager of Nuclear Power Enclosures (2) cc (Enclosures):
Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 U.S. Nuclear Regulatory Commission (5)
Region II Attention: Dr. J. Nelson Grace, Regional Administrator
. la a, org 3b3 4
I r612310033 B61224 7 1 DR ADOCK 0500 An Equal oppodunity Employer
Enclosure 1
'I. Provide justification for the-exception added for RG 1.38 for marking stainless steel.
RESPONSE: ANSI N45.2.2-1972 makes provisions for materials ~such as caps, plugs, vapor barriers, dessicants, tapes, etc. to come in contact with stainless steel and nickel alloy items, provided.the chemical content of the materials is controlled to reduce the effects of halogens and other contaminants. This same logic was expanded to include marking materials'which have their chemical content controlled by internal.TVA procedures.
m Enclosure 2 TVA OA TOPICAL REQUEST FOR ADDITIONAL INFORMATION (D. L. Lambert /J. Gilray)
- 1. (17.0-4)
What are QA items and how do these relate to CSSC of Revision 8?
RESPONSE: "QA items" have been changed to "CSSC items".
(17.0.6.3, #5)
- 2. ENCLOSURE 2 How does the Site Quality Manager interface with the corporate Quality Systems and Technical Support Groups in the Quality Control Program't RESPONSE: The Quality Systems Branch develops and documents in the NQAM the programmatic requirements for the quality control / inspection activities and the certification requirements for personnel performing these quality-related activities. The Technical Support Branch ensures that training programs are developed, personnel are trained and qualified to perform the inspection activities, and that sufficient personnel are located at each nuclear facility depending on workload and schedules. The Site Quality Manager implements the inspection program using inspection procedures developed from upper-tier guidance in the NQAM and trained and qualified personnel assigned to him by the Technical Support Branch. As needs change and work loads fluctuate, these needs are conveyed to the appropriate DNQA branch and adjustments made as needed.
- 3. How does the Site Quality Manager interface with Power Stores on receipt inspection material as to deficiencies and inspector qualification?
RESPONSE: Power Stores personnel perform an initial check of all items being received by TVA to determine if quantities are in complicance with the purchase order and that there is no evidence of shipping damage. For QA level 1, 2 and 3 items, personnel from the Site Quality Manager's organization perform the detailed receipt inspection to determine item acceptability. Any deficiencies noted during the receiving process are documented by the Site Quality Manager's organization.
CHAPTER 17.1
- 1. (17.1.2.1, 5th Para.)
Refer to Engineerlag Procedure "Soll and Rock investigations."
It now states, "an interfacing quality assurance procedure contained in the NQAM." Are these documents equivalent?
RESPONSE: The described documents are equivalent.
RESPONSE: PORC will review all modification packages for safety-related modifications. This package includes the drawings, specifications, ECN, and USQD. When required by Plant Technical Specifications, PORC will also review the resulting work plan. All work plans will receive an independent technical review and a review by the Site Quality Manager's organization.
(17.2-10) 6 Revision 8, the sixth subparagraph under 17.2.6 (first on the page) indicates "Fleid drawings and sketches ... the original issue."
Revision 9, the fif th and sixth subparagraphs under 17.2.6 (page 17.2-9, third and fourth paragraph) which replace the above subparagraph now delineate a difference between field drawings and sketches.
- 1. Was the difference always clear between the two?
- 2. Are the field drawings just more detailed as-builts?
- 3. Are field drawings formally reviewed against existing as-builts?
- 4. When would a NCR be written against a field drawing anomaly?
RESPONSE
- 1. The difference was clear to the extent that neither field drawings or sketches were to conflict with engineering specified requirements, but were intended to clarify or provide supplemental detail to such requirements.
- 2. Field drawings provide details not specified by the design drawings.
- 3. If " existing as-builts" are intended to mean engineering drawings, the answer is no because the scope of these documents differ.
- 4. A NCR would not normally be written against these documents since they do not establish engineering requirements. Field drawings are used to provide details not specified by the design drawings. If discrepancies are encountered while using the field drawings they are noted on the fleid drawing and provided back to the responsible engineer. If the marked-up field drawing is consistent with the design drawing, no other action is required. If the marked-up field drawing is not consistent with the design drawing,'a NCR would be written.
(17.2-13)
- 7. Revision 8, the last subparagraph reads " Required documentation
... resolves before items are issued for plant use or installation and declaring components or systems operable."
Revision'9, the second (equivalent) subparagraph on page 17.2-13 and paragraph 17.2.15 do not contain " operability" requirements.
- 1. Justify /give reasons for change.
~
- 22. Revision 8, under ANSI N45.2.12~(Draft 3, Rev. 4-February 1974), TVA took exception to paragraphs 2.3, 3.4.2, 4.3.3 and 5.2.
Revision 9 under ANSI N45.2.12-1977, TVA now takes exception to paragrapns 2.3, 3.5.2, 4.5.2 and 5.2
- 1. Why is there no change bar for the change in standard revision level?
- 2. Justify /give reason for the change.
- 3. The exception to paragraph 4.3.3 is no longer necessary due to the 1977 revision easement in requirement; is the 1977 revision a reduction in commitment?
RESPONSE: The change bar was omitted by oversight and has been corrected. This change was made to provide a commitment to the edition of ANSI N45.2.12 currently endorsed by Regulatory Guide 1.144. The information contained in paragraph 3.4.2 of the 1974 edition is now found in paragraph 3.5.2 of the 1977 edition. Therefore, this exception reference was changed. The exception to 4.3.3 was deleted since the 1977 requirement
. corresponds to the previous exception for this paragraph. The exception to 5.2 was deleted since it made reference to maintaining records according to the 1977 edition, which is now the commitment. An additional exception to 4.5.2 was added to state that equally qualified personnel (lead auditors) would perform follow-up actions. This is not a reduction in
- commitment since the program coverage is equivalent.
(Table 170-3 Sheet 9)
- 23. Revision 8, under remarks for RG 1.88, there is some clarification to NFPA-1975 and ANSI N45.2.9-1974 (this revision is endorsed by the RG.)
Revision 9, under remarks for RG !.88, there is now some clarification to NFPA-1980 and ANSI N45.2.9-1979. The remarks now allow temporary storage of QA records for 60 days.
- 1. Justify /give reasons for this change (potential reduction; see Tables 170-1 and 17D-2 for RG 1.88).
RESPONSE: This question is partially addressed in the response to question 9 of enclosure 1. The response to question 9 now shows the commitment to ANSI N45.2.9-1974 with exceptions. In addition to that response it should be noted that TVA is only using that portion of N45.2.9-1979 that has to do with fire protection storage vaults, which require 2-hour rated vault doors and equipment. All other portions of 1974 edition are still used. The temporary storage of records discussion is to help microfilming operations. Consideration is taken for recreatable (multiple cooles) and fire-resistive construction of buildings prior to allowing temporary storage.
Enclosura 3 TVA QA TOPICAL REVISION 9, DRAFT 3 TVA-TR75-1A Rev. 9 Draft 3 17.1.1 Organization The TVA organizations participating in the establishment and implementation of the TVA quality assurance program applicable to design and construction are described in Section 17.0 of this report.
I 17.1.2 Design and Construction Quality Assurance Program 1 The quality assurance program is defined by the requirements ~
detailed in the Nuclear Quality Assurance Manual (NQAM) maintained and controlled by the Division of Nuclear Quality 9 Assurance.
17.1.2.1 Scope The quH ity manuals and procedures listed in Table 17E-1 comprise tr documented quality assurance program of the Divisions c' Nuclear Engineering and Nuclear Construction. These documents are implemented during design and construction to assure that the resulting TVA nuclear plant can be safely operated. These requirements are mandatory as established by the Division of Nuclear Quality Assurance. 9 General summaries of the assignment of design and procurement responsibilities between TVA and NSSS supplier and the responsibility for design review of these structures, systems, and components are given in the Appendix C tables listed below for the indicated plants:
Nuclear Plant Table No.
Bellefonte (BLN) 17C-1 Watts Bar (HBN) 17C-2 9
Chapter 3 or Chapter 17 of the SAR for each of the nuclear plants listed above identifies the structures, systems, and components to which this section applies.
The quality assurance program controls over quality related activities pertaining to design and procurement initiated before submitting the PSAR are described in this topical report.
Quality assurance program controls over safety related site preparation are provided by an interfacing quality assurance procedure contained in the NQAM which distributes !
responsibilities among the various TVA organizations involved.
9
TVA-TR75-1A Rev. 9 Draft 3 Procurement documents for spare or replacement parts during design and construction are subject to the current QA program, I applicable codes and standards, and technical requirements which are equal to or better than original technical requirements or as required to preclude repetition of defects.
The organization originating the requisition is responsible for ensuring that the corporate records management system receives a complete set of records of the procurement excluding supplier records. DNQA/PQAB is responsible for supplier quality control records on contracts requiring source surveillance.
Other supplier quality control records and all receiving records 9 are the responsibility of the construction project.
Specifications are an integral part of each procurement document.
When the contract has been made, copies are distributed by Purchasing. These records are transferred to the corporate records management system for entering in the corporate records management system to provide current access and for storage. In the initial stages of a project, procurements for major equipment and long lead items are scheduled. Later all known procurements are placed on a schedule which is periodically updated and distributed. Numbers are cross-referenced to the procurement i filing system so that determination can be made of the status of any item of procurement at any time. DNE's procurement schedule is issued to DNC and periodically revised and updated. DNE originates purchase requisitions, including specifications, and 9 makes appropriate distribution. Purchasing converts (without altering technical or quality assurance requirements) the requisition to an Invitation to Bid form and issues to the same 3 organizations at time of advertisement.
17.1.4.2 Procurement by DNC '
DNC procures permanent plant items or services in accordance with DNE approved procurement specifications. Specific 9
guidelines for the control of DNC procurement have been established. These guidelines are incorporated in quality assurance procedures. Procurements are initiated, reviewed, and approved by the CEO. In addition, they are reviewed and approved by the Site Quality Manager's organization.
9 17.1.5 Instructions, Procedures, and Drawings i Activities affecting quality are prescribed by documented instructions in the form of drawings, specifications, and procedures which include identification of any special equipment and environmental conditions required to perform the activity, 9 and appropriate quantitative and qualitative acceptance criteria to verify that important activities have been satisfactorily accomplished. These documented instructions are followed for all
TVA-TR75-1A Rev. 9 Draft 3
' activities affecting quality. :The preparation, review, approval, and~ control of such procedures are in accordance with the.
requirements of the DNC procedure for instructions, procedures and drawings, or the DNE procedures applicable to the type.of instruction, procedure, or drawing being prepared.
9 4
Measures to assure that documented instructions are provided for.all activities affecting quality are described in the following paragraphs.
- 17.1.5.1 DNE Instructions, Procedures and Drawings Drawing and procurement schedules identify required drawings 2 and procurement specifications. -Where changing requirements indicate that additional drawings or specifications are- 9 g necessary. they are added.to the schedules.
Construction specifications prepared and approved by DNE provide for control of processes and for control of the quality necessary for~the construction of safety-related items to meet engineering design requirements and constraints. These specifications identify (as applicable) the materials and
- requirements of the material to be used, the procedures, equipment, and details necessary for the construction or installation; and any special requirements for handling and 9
storage of expendables or consumables or equipment for construction, modification, and maintenance activities. .
Construction specifications also include applicable quality
, control inspection,. test, and records requirements. DNC may impose additional requirements as appropriate for control-of .
, construction processes or activities.
- Each design document including procedures, drawings, and
- specifications involving nuclear safety-related structures, systems, or components is independently reviewed by a quallfled person other than the preparer who is qualified in quality '
program requirements applicable to the area being reviewed. '
9 l '17.1.5.2 DNC Instruction, Procedures, and Drawings l t DNC procedures for tests and special processes are inaependently reviewed by a person, other than the preparer, who 9
[ Lis knowledgeable in quality assurance. The procedures are i approved.by appropriate levels of management before issue.
17.1.6 Document Control The preparation, review, approval, and issue of documents such as those listed below are controlled by means of procedures
] listed in Appendix B of this topical report to assure they are adequate and the quality requirements are stated.
~
)9 i
I i
TVA-TR75-1A Rev. 9 Draft 3
. modifications by review of workplans and revises test procedures as necessary. Retests are conducted and results handled in the same manner as original tests.
17.1.12 Control.,,of Measuring and Test Equipment (M&TE)
Tools, gauges, instruments, and other measuring and testing devices used in site construction activities are controlled, calibrated, and adjusted according to written procedures. These procedures establish the responsibilities and methods for control of this equipment and provide for the means by which periodic calibration and adjustment schedules are established. They also provide for the generation and maintenance of records that document these activities. Detailed procedures define the methods of calibrating and adjusting each item of this equipment and the standards to which they will be made.
Procedures require that calibration standards be traceable to the National Bureau of Standards, nationally recognized standards, or to accepted values of natural physical constants.
Procedures also require that in the event test equipment is found to be out of calibration an evaluation will be made on work previously inspected with this equipment as appropriate to assure correctness of inspection results. Logs are maintained to document the use of measuring and test equipment.
The procedure for control of measuring and test equipment requires that: (a) measuring and test equipment be identified with a unique identifier and that this identifier be recorded on 9 the calibration record for the equipment; (b) all measuring and test equipment be tagged to indicate date next calibration is due; (c) project procedures delineate calibration frequency based on the required accuracy, purpose, degree of usage, stability cnaracteristics, and other conditions affecting the measurement; and (d) calibration standards have an uncertainty (error) requirement of no more than one fourth of the tolerance of the equipment being calibrated, with a greater uncertainty being acceptable when limited by the state of the art. Deviations from specified tolerances, along with the basis for acceptance, are documented and approved by the Site Quality Manager.
If necessary, the Site Quality Manager coordinates with DNE to assure design tolerances are not exceeded.
Written procedures require that procurement documents 9 identify the applicable requirements of-ANSI N45.2, " Quality Assurance Program Requirements for Nuclear Power Plants," using the methods defined in Section 6 of the Appendix to ANSI N45.2.13 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants."
TVA-TR75-1A Rev. 9 Draft 3 parts, components, systems, and structures be verified by reinspecting the item as originally inspected or by a method which is at least equal to the original inspection method; and inspection, rework, and repair procedures are documented.
17.1.15.5 DNC Trend Analysis Designated upper management at the nuclear projects routinely reviews reports documenting significant and nonsignificant conditions adverse to quality, audit and evaluation reports, and NRC violations, and direct trend analysis to be performed on activities selected on the basis of ongoing activity and the amount and types of problems being encountered.
Trend reports provide statistics representing overall quality levels for operations trended. Action taken to address unacceptable trends are included in the trend reports.
Additionally, information on the nature, cause of deviations, and corrective action initiated is included where unacceptable trends are indicated. Trend reports are distributed to appropriate DNC management.
17.1.16 Corrective Action Adverse conditions may be reported to management by any TVA employee. These adverse conditions are documented, evaluated, 9 and corrected in a timely manner consistent with their effect on safe operation. As necessary, adverse conditions are. escalated to successively higher levels of management for resolution. A centralized system tracks the adverse conditions to ensure timely resolution. Each significant adverse condition is individually analyzed to determine the root cause of the condition, the corrective action necessary to prevent recurrence, and the applicability to other TVA nuclear plants. Each CAQ is then placed in various categories, such as group responsible for causing the condition, type of condition, type of item cr matter which is deficient, and the immediate cause of the condition. An analysis is then performed periodically to identify any adverse trends. Any trends are evaluated to determine the root cause and to recommend action to prevent recurrence.
A single computer program has been selected for trending adverse conditions. The analysis of trend data supplied by the computer program is performed by line management. DNQA identifies QA trend indicators and performs corporate-wide QA trend analysis to support its QA assessment responsibility on an ongoing basis. Corporate trend reports are issued periodically to assist in identifying areas where increased management attention is needed.
17.1.16.1 DNE Corrective Action Corrective action measures for errors and deficiencies identified in design activities, approved design documents, or l
17.1-37
__.,y- _ _ _ . _
TVA-TR75-1A Rev. 9 Draft 3
- Each of the 18 criteria of 10 CFR 50, Appendix B, is addressed.in this quality assurance program. The requirements of these criteria are implemented throughout the operating life of each TVA' nuclear plant and are implemented through written procedures and instructions. The quality assurance source requirements during operation are in accordance with the design and construction codes and standards applied during the 9 construction phase or acceptable alternatives approved by DNE.
Chapter 3 or Chapter 17'of the SAR for each of.the nuclear 9 plants identifies the structures, systems, and components to which this section applies.
17.2.2.2 Quality Assurance Program Documentation 1
The quality assurance program is documented by written procedures. Table 178-2, Appendix B, contains a list of 9 procedure subjects addressed in the NQAM and the criteria of Appendix B to 10 CFR 50 which they implement. This is a list of present or planned procedures and will not be kept. current. TVA may unilaterally delete, add, or renumber the procedures without revising this report, but will maintain the same overall program coverage. The list of procedures will be reviewad with each revision of this topical. report and will be revisec if required to reflect the current program. DNQA is respcasible for assuring '
that these procedures are updated to reflect changes in this 9 Topical Report.
TVA will follow the guidance of NRC Regulatory Guides as described in. Table 17D-2, Appendix D.
17.2.2.3 Indoctrination and Training Indoctrination and training practices of the Office of Nuclear Power for the operations phase of TVA's nuclear plants are described in the following paragraphs. Other divisions and staffs outside the Office of Nuclear Power supporting the operations phase conduct indoctrination and training as required to assure personnel are adequately trained to perform assigned quality related activities.
DNQA establishes upper-tier requirements for a quality 9 assurance training program for site staff and central office employees performing quality assurance activities. The program covers quality assurance program requirements applicable to the respective employee's area of responsibility.
I
TVA-TR75-1A Rev. 9 Oraft 3 verifles that plant activities between initial transfer and final transfer are authorized, approved, and carried out in accordance c' with procedures and instructions. He ensures that information is provided to the project engineer to be included in the as-built (as-configured) drawings and that objectives and performance criteria are not degraded during subsequent maintenance activities.
17.2.3.3 Modification Controls are established to ensure that proposed
. modifications to CSSC are subjected to design control measures commensurate with those applied to the original design and to the applicable provisions of 10 CFR 50, Appendix B. Proposed modifications (except nuclear fuel) are reviewed and approved by DNE. DNE's design control program is described in section 17.1.3 of this report.
Proposed modifications to nuclear fuel, which includes certafn fuel-related components and fuel-related services, are 9 reviewed and approved by the Division of Nuclear Services, Nuclear Fuel Branch.
CSSC modifications are reviewed by PORC and approved by the Plant Manager before implementation. Changes necessary to implement an approved modification are approved by PORC, by the project engineer, and by the Plant Manager prior to declaring the structure, system, or component operable. j Procedures and instructions are developed and implemented to assure that the design, construction, installation, inspection, and testing of modifications to the CSSC meet quality assurance standards at least equal to those of the original installation.
The testing assures system integrity and provides for evaluation of performance before system operation. Procedures and instructions related to equipment or systems that are modified are reviewed and updated to reflect the modification.
Responsible plant personnel are provided revised drawings and procedures describing modifications which may affect the performance of their duties. ;
?
Modification work is controlled by the Nuclear Site Director I in accordance with established policies and requirements. All work plans receive an independent technical review and a review by the Site Quality Manager's organization. All work that affects a licensed facility is subject to the requirements of 9 Section 17.2. Modification work is performed by DNC or by outside contractors with oversight by DNC. Work may be accomplished using DNC procedures as an acceptable means of meeting the requirements of this section. DNC procedures which affect work control or CS5C items receive concurrence by tne Nuclear Site Director.
TVA-TR75-1A Rev. 9 Draft 3 17.2.12 . Control of Measuring and Test Equipment Measuring and test equipment utilized in or related to operation of.CSSC equipment is controlled in accordance with written procedures or instructions. Procedures or instructions for calibrating and controlling measuring and test equipment include identification of the test equipment, calibration techniques, calibration frequencies, maintenance control, and storage requirements. Equipment to be included in this program includes measuring instruments, test instruments, tools, gauges, reference standards, transfer standards, and nondestructive test equipment which are to be used in the measurement, inspection, and monitoring items on the CSSC list for TVA's plants.
Permanently installed plant process instrumentation is not to be included in this category.
Control of measuring and test equipment shall require:
- 1. That each item of measuring and test equipment be assigned a specific interval for recalibration.
Interval selection shall depend on past experience, inherent stability of equipment, its intended purpose or use, and the accuracy required. Historical records shall be maintained which contain sufficient experience data for evaluating calibration intervals.
- 2. Unique identification of each item of test equipment.
- 3. Traceability to calibration test data and tagging (when practical) to show due date of calibration.
- 4. Traceability of reference standards to national standard and periodic revalidation of reference standards.
- 5. Records to be maintained which indicate the complete status of each item of test equipment, including its maintenance history, calibration results, abnormalities, and last and future calibration dates.
- 6. Control of the purchase requirements and acceptance tests for new or replacement test equipment. '
- 7. M&TE are calibrated against a working standard having a tolerance not greater than 1/4 the specified tolerance of the M&TE. Tolerances greater than 1/4 will be acceptable when equipment to meet these requirements is not commercially available. Deviations from the 1/4 ratio, along with the basis for acceptance, are documented and approved by the organization using the M&TE. If necessary the user organization coordinates 9 with DNE.to assure design tolerances are not exceeded.
TVA-TR75-1A Rev. 9 Draft 3 license, technical specifications, procedures, instructions, or regulations; and deficiencies in approved design documents, 9
design activities, or design methods (including use of computer codes). Significant conditions adverse to quality are those which represent gross or widespread noncompliance with procedural requirements which negates the effectiveness of quality assurance controls; or any condition which has recurred with such a frequency that it indicates past corrective action (if any) has been ineffective.
Adverse conditions may be reported to management by any TVA employee. These adverse conditions are documented, evaluated, and corrected in a timely manner consistent with their effect on safe operation. As necessary, adverse conditions are escalated to successively higher levels of management for resolution. A centralized system tracks the adverse conditions to ensure timely resolution. Each significant adverse condition is individually analyzed to determine the root cause of the condition, the corrective action necessary to prevent recurrence, and the applicability to other TVA nuclear plants. Each CAQ is then placed in various categories, such as group responsible for causing the condition, type of condition, type of item or matter which is deficient, and the immediate cause of the condition. An analysis is then performed periodically to identify any adverse trends. Any trends are evaluated to determine the root cause and to recommend action to prevent recurrence.
These corrective action reports become part of the plant quality assurance records. For significant conditions adverse to quality the Site Quality Manager's organization reviews and concurs with the proposed corrective actions as a member of PORC, 8 makes followup reviews for implementation of the corrective action, and reviews any reports generated by the action before i the corrective action report is closed.
The corrective action for significant conditions adverse to quality is reviewed by the members of PORC and approved by the 8 Plant Manager. The Plant Manager has the authority to cause immediate temporary corrective action to be taken.
Contractors performing modifications to the nuclear safety-related portions of the plant are required to comply with TVA approved procedures which require conditions adverse to quality to be identified, corrected, and reported.
A single computer program has been selected for trending adverse conditions. The analysis of trend data supplied by the computer program is perfcrmed by line management. DNQA ,
identifies QA trend indicators and performs corporate-wide QA 9 trend analysis to support its QA assessment responsibility on an ongoing basis. Corporate trend reports are issued periodically to assist in identifying areas where increased management attention is needed.
TVA-TR75-1A Rev. 9 Draft 3 11.2.17 . Quality Assurance Records Quality assurance records are those completed records which
' furnish documentary evidence of the quality of CSSC items or of activities affecting the quality of the CSSC and those records required by the administrative section of each nuclear plant's technical spectfications. Quality assurance records include but are not limited to the following:
- 1. Records compiled during the design and construction of the plant, including design drawings, construction logs and results of reviews, inspections, tests, audits, monitoring of work performance, materials analyses, and other similar documents.
- 2. Documents and records compiled during operation, including operating logs; maintenance records; 9 modification records; reportable occurrences; results of reviews, inspections, tests, audits, and material analyses; monitoring of work performance; qualification of personnel, procedures, and equipment; specifications; procurement documents; calibration records; and nonconformance reports and corrective action.
Inspection and test records contain, where applicable, a description of the inspection, date, results, inspector identification, conditions adverse to quality, and actions taken to resolve any discrepancies.
DNQA establishes quality assurance requirements for the collection, classification, and storage of QA records generated during the design and construction phases including requirements pertaining to the transf.er of records to the Nuclear Site 9
Director. In addition, DNQA establishes requirements for the collection, classification, retention and storace of operation phase QA records including those construction and design QA records transferred from the construction phase.
DNQA establishes requirements for a records control system which requires: (1) a records checklist designating the required l quality assurance records, (2) a record of quality assurance records received, (3) procedures for receipt and inspection of incoming quality assurance records, (4) provisions for a current and accurate assessment of the status of quality assurance records, and (5) establishment of records storage facilities to ensure records availability and protection. The Nuclear Site Director coordinates the transfer of required quality assurance 9 records from other offices to the site operating organization.
. . - , . _ _ , . , __ . ~ ~ , c ,-.. .- _ -- , - - - . - - . _c, , .. _
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3 .
TVA-TR75-1A Rev. 9 Draft 3 Each nuclear site and organization within Nuclear. Power that has responsibility for quality assurance records: provides 9 storage, preservation, and safekeeping of the required quality assurance records in accordance with TVA-established requirements and regulatory requirements. Each site or organization designates personnel who have access to the files, implements a 9 retrieval method, establishes an index before receipt of the records, and provides written instruction for distribution, transfer, and handling of quality assurance records.
17.2.18 Audits
. The audit program consists of internal audits and supplier 9 audits to determine and assess the adequacy and effectiveness of the program. The system of planned and periodic audits is carried out in accordance with written procedures. Procedures require that, as applicable, audits include: a determination of 9 the effectiveness of the QA program, evaluation of work areas, activities, processes, and items; review of documents and records; review of audit results with management having [
responsibility in the audited area; and, followup on corrective action taken on audit deviations. The audit program provides for 9 the reaudit of deficient areas when audit data and resulting reports indicate quality problems.
Each audit organization conducts follow-up verifications or .
9 reaudits as necessary to assure that corrective action has been successfully taken. A periodic status report is prepared by the l8 responsible organization which gives the status of corrective i actions on their respective audits. 19 17.2.18.1 Internal Audits The scope of an audit is determined by considering such factors as work areas, activities, processes, or items and the specific organizations involved. The scope is approved by the respective Manager. Schedules of audits by subject and date are prepared, approved by management, and issued to affected organizations. DNQA is responsible for assuring that its audit 9 programs adequately cover applicable e?ements of the TVA nuclear quality assurance program each year and are regularly scheduled based upon the status and safety importance of the activities being performed and are initiated early enough to assure effective quality is achieved. In the case of operating plants, the technical specification Regulatory Guides, and standards establish audit frequency. These audits are conducted by a technically-oriented audit staff which is trained and qualified to perform both results-oriented as well as programmatic audits and evaluations. Full-time auditors possessing engineering and g technical degrees, or equivalent experience in disciplines -
i
TVA-TR75-1A
, Rev. 9 Draft 3 such as civil, mechanical, electrical, nuclear, chemical, and I engineering physics are used on appropriate audit teams along with construction and operations support auditor specialists such as senior reactor operators, health physicists, security, radiological emergen'cy, welding, non-destructive examination, 9 civil-structural, and instrumentation and control audit personnel. This level of technical expertise is typical of the audit staffing that.is maintained for the purpose of nuclear program auditing and QA program assessment. DNE's Engineering Assurance organization is responsible for ensuring that its audit program' adequately covers the applicable elements of the DNE QA program and organizations performing quality-affecting activities on.a timely basis.
Copies of audit reports are distributed to cognizant management. Audit reports direct management attention to problem areas and may contain recommendations to eliminate noncompliances and to increase the effectiveness in such areas.
Based on these reports, the respective manager takes appropriate actions to correct deficiencies that exist.
17.2.18.2 Supplier Audits DNQA also plans and conducts audits of selected suppliers to 5 verify implementation and adequacy of specified quality assurance requirements. Suppliers to be audited are selected on the basis of importance of their products to safety, status of contract activity, historical performance of the supplier, and potential quality assurance program problems that may be discovered during normal product inspection visits or earlier audits. Audit schedules are prepared and audits are conducted in accordance with the schedule. DNQA personnel are supplemented by personnel !9 selected from the TVA line organizations to form specific audit 3, teams based on the type of audit and the complexity of the product. Suppliers of only engineering services are audited by the DNE Engineering Assurance organization. Suppliers of nuclear 9
fuel and fuel-related components and services are audited by the Nuclear Fuel organization in DNS.
Audit reports are prepared and approved by the audit team and transmitted to the supplier and cognizant management within 8 TVA.
._ . . _ , - _ ~ _. _ _ _ . _ _ _ _ _____ _ _. _ __ _ _ - - -
TVA-TR75-1A Rev. 9 Draft 3 TABLE 170-1 QUALITY ASTURANCE STANDARDS FOR DESIGN AND CONSTRUCTION
) (REGULATORY GUIDANCE)
! APPLICABLE TO THE BELLEFONTE AND WATTS BAR NUCLEAR PLANTS (Sheet 6)
. TOPIC CONFORMANCE STATUS AND/OR REMARKS a
j 5. Medical eye examinations for inspection, i testing, and examination personnel (other l than NDE personnel) are made in accordance 1
with TVA medical examination polices rather than annually.
)
1 Regulatory Guide 1.116 (Revis. m 0), Conforms fully.
June 1976 - Quality Assurance Rt.,uirements for the Installation, Inspection, and Testing of Mechanical Equipment and Systems (endorses N45.2.8-1975)
Regulatory Guide 1.88 (Revision 2), Conforms fully except as noted: DNC October 1976 - Collection, Storage, and classifies records as " Life of Plant" (LOP)
! Maintenance of Nuclear Power Plant Quality and " Duration of Construction" (DOC). LOP Assurance Records records include all Lifetime" records and (endorses N45.2.9-1974) those " Nonpermanent" records with retention period of other than zero. DOC records are those "Nonpennanent" records with retention of .
zero years. " Lifetime" and "Nonpennanent" records are defined by DNC in accordance with ANSI N45.2.9-1974.
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T/A-TR75-1A Rev. 9 Draft 3 TABLE 17D-2 REGULATORY GUIDANCE FOR QUALITY ASSURANCE DURING STATION OPERATION 4
(Sheet 4)
TOPIC CONFORMANCE STATUS AND/OR REMARKS Austenitic stainless steel and nickel alloy 4
items may have markings applied directly to the bare metal surfaces, provided the
- requirements of TVA internal procedures which I
control the chemical content of the marking
] nuterials and the niethod of litarking, are met.
i The TVA procedures are consistent with the j requirements of ANSI N45.2.2-1972 regarding d
other materials which contact stainless steci and nickel alloy items.
- 2. TVA takes exception to the requirement i (ANSI N45.2.2, Section 6.2.4) that salt-tablet dispenser in any storage area c shall not be pennitted. TVA Power Stores l Unit stores salt-tablet dispensers in sealed containers for use outside of the storage area only.
- 3. TVA takes exception to the requirement
- (ANSI N45.2.2, Section 6.5, last sentence)
! due to the relatively short time between j installation and use during the operations j phase. TVA's alternative to this j exception is as follows: TVA develops, issues, and inplements procedure (s) which
} cover (s) the removal of items from a storage. 'Such procedure (s) will ensure-j that items released from storage and
] awaiting installation will be stored in a l
manner to minimize the possibility of 4 damage or lowering of quality due to l corrosion, contamination, deterioration.
i or physical damage,
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. 4 TVA-TR75-14 Rev. 9
-TABLE 17D-2 9 REGULATORY GUIDANCE FOR QUALITY ASSURANCE DURING STATION OPERATION
( TOPIC (Sheet 7)
CONF 0RMANCE STATUS AND/OR REMARKS ltegulatory Guide 1.64, (Revision 2), June 1976 - Changes in plant design resulting from
" Quality Assurance Requirements for the Design of modifications or repairs during the operating Nuc1 car Power Plants" - (Endorses N45.2.11-19N) phase are referred to the responsible TVA division to be handled in accordance with the nonnal design control system as described in j Section 17.1.3 and 17.2.3. TVA takes no l l
exceptions. !
Regulatory Guide 1.70, (Revision 2) Septend>cr 1975 - No exceptions for Quality
" Standard Fonnat and Contents of Safety Analysis . Assurance Topical Report.
Reports for Nuclear Power Plants," Revision 2 Regulatory Guide 1.74, february 1974 " Quality No Exceptions.
Assurance Tenns and Definitions" (endorses N45.2.10-1973)
Regulatory Guide 1.116, (Revision 0-R), June 1976 - TVA takes no excceptions to those requirements
" Quality Assurance Requirements for Installation, acnts of N45.2.8 that are applicable to Inspection, and Testing of Mechanical Equipment and plant modifications or repairs during the Systems" (Endorses N45.2.8-1975) operating phase.
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. ~Rev. 9 1 Draft 3 TABLE 17D-2 REGULATORY GUIDANCE FOR QUALITY ASSURANCE DURING STATION OPERATION
' (Sheet 8)
TOPIC CONFORMANCE STATUS AND/OR REMARKS Regulatory Guide 1.144 (Revision 1)
- Conforms fully, with exceptions to.the-Septent>cr 1980 - Auditing of Quality following paragraphs:' 9 i Assurance Programs for Nucle c Power 4
Plants (endorses ANSI K5.2.12-1977) 2.3. Training - Technical specialists who assist in perfoming audits in their area of special expertise will not be trained in auditing techniques; however, they will always be acconpanied by a trained, qualifled auditor.
3.5.2 - Scheduling - The applicable elements of the operational quality assurance progrun will be audited in accordance with the requirum:nts of position C.4 I
l 4.5.2 By Auditina Oroanization - DNQA will
- 9 use lead auditors to conduct follow-up action.
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