ML20207R889

Overview Quality Team Program for Comanche Peak Response Team Activities

ML20207R889
Person / Time
Site:	Comanche Peak
Issue date:	02/20/1986
From:	Artuso J, Chockie L, Wells J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20207R884	List: ML20207R883 ML20207R889
References
FOIA-87-89 NUDOCS 8703180258
Download: ML20207R889 (20)

Text

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COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 OVERVIEW QUALITY TEAM PROGRAM FOR COMANCHE PEAK RESPONSE TEAM ACTIVITIES FEBRUARY 20, 1986 i

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s R. Wells, Chairman CPRT-0QT LarWj C)fockfe7 CPRT-007 0& 5 AN W /}A J W Joseph F. Artuso. CPRT-0QT J et' V. Ngel, CPRT-0QT TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY 5

TrcA-87-99 M7 8703180258 870313 MA

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OVERVIEW QUALITY TEAM TABLE OF CONTENTS 1.0 Charter & Objectives 2.0 General Description of Methods 2.1 Interviews 2.2 Procedure Review 2.3 Record Review 2.4 Direct Observation of Work in Progress 2.5 Additional Audits or Inspections 2.6 Final Analysis 3.0 Typical Checklist Approach 4.0 Task Definitions 4.1 Personnel Qualification Verification 4.2 General Administrative Procedure Review 4.3 QA Procedure Review 4.4 QA Activity Review 5.0 Reports 5.1 Progress and Status Reports 5.2 Task Reports t

5.3 Final Report t

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OVERVIEW QUALITY TEAM PROGRAM CPhT 1.0 Charter and Objectives An Overview Quality Team (0QT) was established to provide assistance to TUcen management to assure that the QA/QC vesign Adequac3 Quality Assurance Programs ar

_enu um adequatery implemented.

glhe OQT will report directly to the Chaiman. SRT, and will submit copies of the OQT Progres,s and. Status Reports and 0QT Task Reports concurrently to the Chairman, SRT, and the Executive Vice President of TUGCO.

The objectives of the 00T are to review the components of the Quality Assurance Program to a depth and frequency as determined by the OQT to assure that QA program objectives are met.

The charter of the Overview Quality Team is to develop a program plan and method of implementation.

Included in the charter of 0QT is the responsibility to identify any quality assurance issues that may come to their attention during the conduct of their interviews, reviews and inspections, and to report these to the appropriate level of TUGC0 management.

2.0 General Description of Methods 2.1 Interviews interviews will be held with various members of th M staff to discuss each group's responsibilities and the means used to achieve the quality assurance objectives.

Interviews may include but not necessarily be limited to the following individuals or groups:

CPRT Program Director r

Ngeam leaderL Issue Coordinators CPRT Advisors i

Inspectors

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_ Procedure Review Procedures and checklists developed to implement the QA program be reviewed to determine if procedures a@re comprehensive and when the properly implemented will achie the objectives of the QA program.

Verification will be made to assure that all of the quality assurance program commitments for each action plan are adequately addressed in the procedures.

2.3 Record Review Records generated by each QA group for each action plan covered shall be reviewed to determine if the objectives are achieved, and to establish confidence that the appropriate attributes are checked.

2.4 Direct Observation of Work in Progress Direct observations of the reinspection activities

@be performed as they occur during the reinspection process as required for selected Action Plans.

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The observations specific @ Action include the identification of the Plan reinspection, identification of the inspector and the inspection attributes that are veri fied.

The results of any such direct observations ihaill be c@ W ret 3Tsd~ resul ts ~~f rom the ~QA program activities as part of the overall valuation of QA program implementation.

They ill be done solely to validate the effectiveness of the QA Program, and only when the QA activities are in question.

2.5 Additional Audits or Inspections

-g During the review process, evaluations M be made regarding the effective ess of the QA program J11achievin its objectives.

it is deemed prudent, the 0QT equire that qualified inspectors / auditors be furn d

5 to perform additional and corprehensive inspections or audits of any specific procedure or Corporate QA activity.

These audits and e

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"ir.spections will be done only when the QA activities

.y fare in question. They will be done solely to validate

'he effectiveness of the QA Program.

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2. 6, Final Analysis - Cv'

'dk A, final analysis of the Quality Assurance Program I

3 applicable to the o

CPRT. M will include

~p evaluation of the 7 imp ementation 4 -

Assurance Program relative to achievement of the of the Quality ff following objectives:

s - -W' a)

C Adequate training and qualification of personnel

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involved 1,n the auditino and surveillance process.

f b)

Adequacy and completeness of Quality Assurance procedures necessary to accomplish the overall

' Quality Assurance Program objectives.

e c)

Adequacy, frequency, timeliness and depth of Quality Assurance surveillance and audits necessary to assure that both the form and 7"

substance of Quality Assurance Program elements

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r are fully evaluated during the audit process.

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Verifica tion that Quality Assurance activities g

are conducted in accordance with applicable j

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industry standards and good Quality Assurance practices.

3.0

_ Typical Checklist Approach 4

i It is expected that ost evaluations by the Overview Quality Team (0QT) will be erformed using checklists which are developed from the Quality Assurance Program Plan and i

.from supplemental sub-tier implementing procedures.

Before proceeding with work on a particular task, it will be necessary to determine the status of the work being

- s done.

l The. basic approach to be taken is as follows:

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Select elements to be examined b)

Select specific sub-elements to be examined c)

Review Quality Assurance program and procedures for details d)

Develop checklist for use in OQT review e)

Perform reviews, interviews, audits and inspections according to checklist f)

Identify findings and ope _n_ite_ms k

g)

R view findings and open items with responsible A

anager w G A h)

Obtain acknowledgement and preliminary action commitments on findings and open items i)

Prepare task report j)

Submit task report (contents per 5.2)

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Follow-up_on resolution of findings and open items k

lhe completed checklist will be included as an attachment to the related task report, as described in Section 5.2.

s 4.0 Task Definition and Assignment In keeping with the charter and objectives of the Overview Quality Team, elements and sub-elements of the work gerformed by the Ouality Accieranca grnuns will be saineted for examination by the 00T.

In general the 0QT reviews b Qh T will include evaluation of QA personnel qualifications, evalution of QA implementing procedures, and evaluation of the QA group work product.

A brief description of the approach to be taken for each type of evaluation is given in the paragraphs which follow.

r 4.1

_ Personnel Qualification Verification OQT members will identify selected QA personnel whose records will be reviewed to verify that t

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personnel are adequately qualified and trained to perfom their assigned tasks, and that they can perfom them objectively and without influence from prior organizational affiliations.

OQT members may interview selected personnel as a further means of evaluating qualifications and objectivity.

4.2 QA Administrative Procedure Review OQT members will obtain a complete listing of the administrative QA procedures which have been prepared tn implement the requirements of the QA Program.

OQT members will review the list and will select some or all of these administrative procedures for review.

The 0QT will examine the QA administrative procedures to assure that they adequately provide for or specify the necessary organizational structure, interfaces, record requirements, work processes, review and approval processes, document control, file content i

and retrievability requirements.

The objective of this review is to confirm, with a high degree of confidence, that the QA procedures enable the accomplishment of the overall intent of the QA Plan, that the records are maintained in auditable form, and that the record identification and filing system permits retrievability for various

purposes, including resolution of questions from the licensing process.

4.3 QA Procedure Review For purposes of this 0QT Task, the CPRT is recognized as being divided into the following sub-groups, with Team Leaders as indicated; j

a)

Design Adequacy (Review Team Leader:

Mr.

l Howard A. Levin) b)

Quality of Construction (Review Team Leader:

v Mr. John L. Hansel) t l

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c)

QA/QC Program Adequacy (Review Team Leader:

Mr. John L. Hansel)

The 0QT members will obtain lists of the procedures applicable to the above programs, and from those lists may select certain procedures or groups of procedures for review.

The 0QT review will entail comparisons between the QA procedures and the stated objectives of the QA Program.

The objective of this review is to confirm, with a high degree of confidence, that the procedures prepared by the Review Team enable the accomplishment of the overall intent of the QA Program.

4.4 QA Activities Review The QA Programs applicable to the CPRT activities include commitments to review, perform surveillance and conduct audits.

Within the framework of the QA Programs and their implementing procedures,. the 0QT will examine in detail the work product from I

the OA activities.

The scope, de F ano ievel of detail of each such QA activity will be examined and evaluated.

Sampling plans will be reviewed for adequacy, both as to sample sizes and methods of selection.

Where appropriate, CPRT activities examined by QA Qma be further examined by 0QT as necessary to validate the effectiveness of the QA review, surveillance and audit activities.

5.0 Reports 5.1

_ Progress and Status Reports A consensus report summarizing the interim progress and status of the Overview Quality Team's effort, reviews, observations and_ conclusions will be prepared (periodidaji ly,

@proximat@ monthly basis, on an and submitted to the Executive vice President of TUGC0 and the Chairman, SRT.

The e reports may be considered interim since re iminary 3 results may dictate the need for further interviews, reviews, or inspections which may revise the conclusions stated in the interim progress and status reports.

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5.2 Task Reports Reports shall be made on each of the 0QT tasks that have been completed. The reports shall include:

a)

Identification of the task.

b)

Major objectives of the task.

c)

Description of each phase that was reviewed and identification of any phase not reviewed.

d)

Review of documentation generated by any of the responsible parties and identification of each participant's role and responsibilities, e)

Procedures, checklists, and sampling plans reviewed.

f)

Participants interviewed and inspections witnessed.

g)

Results of review of the applic~able QA reports.

I h)

Analysis of results to verify:

(1)

That corrective actions have been identified and defined for any OQT

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(2)

That actions -have been identified and defined to preclude occurrence of similar problems in the future.

(3)

That the corrective actions have been implemented by the affected organization.

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Any completed checklist used by 0QT in performing its evaluation will be included as an attachment tto the report, h

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5.3

_ Final Report A final report will be prepa red by the Overview Quality Team summarizing the results presented in the Progress and Status Reports and the Task Reports and submitted to the Executive Vice President of TUGC0 and the Chairman, SRT at the conclusion of the 0QT program.

This Final Report will present the results of the entire overview effort to support the objective of providing additional assurance

.tigt each OA_ organization has adequately implemented their respective QA program.

The final report shall include a compilation of the Task Reports with a

matrix showing the C

k'T identification of each QA activity that was reviewed and evaluated for compliance with the specific requirements.

An evaluation shall be included which identifies the extent to which 00T has verified that the CPRT QA Program has achieved the overall objectives stated in Section 2.6.

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13As O. Y](l{-47{Q FILE NO. 10068 TEXAS UTILITIES GENERATING COMPANY g

h0(YW AY TOWER. 400 NOIRTit OtJVE srTREET.1 B. e t

• D Atl.AM. TEX A,5 7 5 30 R February 28, 1986

.M%51.*SE."EA CPRT-279 Mr. Vincent S.

Noonan Director, Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

20599

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION COMANCHE PEAK RESPONSE TEAM OVERVIEW QUALITY TEAM

Dear Mr. Noonan:

Appendix G to the CPRT Program Plan, Revision 3, describes the Quality Assurance Program applicable to CPRT Third-Party activities.

Appendix G is a re-statement, in much greater detail, of the Policy on Quality Assurance included with our letter of August 16, 1985 (TXX-4538).

As noted in Appendix G, the Senior Review Team shall remain cognizant of, and have overall responsibility for, the quality of CPRT activities. To support the Senior Review Team in fulfilling its responsi-bilities, the Overview Quality Team (OOT) has been established to provide further assurance that the Design Adequacy and Quality of Construction Quality Assurance Programs are effectively implemented.

The OQT is composed of senior third-party personnel to the reporting Chairman of the Senior Review Team.

The OQT will support the Senior Review Team by reviewing the results of all audits of CPRT activities, as well as, the corrective actions taken in response to those audits.

Such audits include all planned and periodic audits conducted by the Quality Assurance organizations of the DAP and QA/QC Review Teams, as well as any audits of CPRT activities conducted by the NRC or TUGCO.

The OQT may also conduct special audits, as directed by the Senior Review Team Chairman.

Such audits will be performed to directly evaluate CPRT quality assurance activities routinely or as significant problems with the CPRT quality assurance activities are identified.

By performing these overview and audit functions, the OQT supplements CPRT quality assurance efforts and provides further assurance that CPRT quality commitments are implemented.

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Mr. Vince Noonan February 28, 1986 Page No. 2 The OQT shall ' issue periodic reports including, when appro-priate, summaries of results of major 00T tasks.

The OQT shall also issue a final report to present the results of its entire overview effort and its corresponding conclusions regarding the adequacy of Quality Assurance Program implement-ation by the DAP and QA/QC quality assurance organizations.

The OQT periodic and final reports will be submitted concur-rently tq the Senior Review Team Chairman and the TUGCO Executive Vice President, thereby ensuring that TUGCO senior management is kept fully informed of the status of CPRT quality assurance implementation.

The attached Figure 2 of Appendix G to the CPRT Program Plan, Rev.

3, which was inadvertantly omitted from our January 27, 1986 submittal, illustrates the flow of information to. the Senior Review Team resulting from CPRT quality assurance activities.

This figure should be inserted immediately behind Figure 1.0 in Appendix G, Rev.

3.

I am satisfied that the additional level of quality assurance provided by the 00T will ensure the continued effective implementation of the DAP and QA/QC Quality Assurance Programs. If you have any questions regarding this letter, please contact John W. Beck or myself.

Very truly yours, W)L W.

G.

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Zesn'nnudM T k W. 6. Counsil Texas Utilities Generating Company Skyway Tower 400 North Olive Street, LB81 Dallas, TX 75201 FROM:

Vincent J. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A Office of Nuclear Reactor Regulation

SUBJECT:

COMANCHE PEAK QA PROGRAM In our licensing review of the QA program for the CPRT activities, we deemed it In this regard eembers of the QA Branch visited the Com with members of the NRC Region IV inspection staff to evaluate the results of their inspection of the CPRT QA program implementation.

We were particularly which is addressed in your letter of Februaryconcerned with the rev 28, 1996.

from our conclusion that your February 28 letter gave only a generaliaedThis conce description of the 0QT and its ultimate acceptability would be found in the implemating details.

As a result of the recent NRC Region IV inspecticr.cf the OQT activities, we have some concerns over the pecceduaal ccr.trols and dccu-mented responsibilities of the 007 and the tireliness of SRT responses tc OQT.

The NRC is relying on the OQT to provide a.ssurance that the CPRT progra: la perly implemented and is therefore a key instrument for regularly reviewing the status and adequacy of the CPRT program, as required by 10CFR y0 Ap ndix E.

d The specific concerns we have are (1).the lack _.oLa.yeiinitivetpacceduR.uJ describino the re5ponsibilities and a' thattty_Vf6 revies ansh rear-MFv fof4!!% tie:cf AQ gthe lack of~ cine a

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team leaders, (3) the lack of procedural controlssnose TRT~ISAPs 6/[

schedule of acWTBi[LidehtifRdZdef.icieicIE._f5r_the Senior Rev for thelyItsolution o

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and (4) the lack of a master

_related t.o OQT_ reviews and auditJ.

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While the OQT has developed substantive findings as a result of reviews alre conducted, we want to make you awsre of our concerns, realizing you alread, have had some feedback from Region IV.

We therefore request that you take the necessary action to ensure that the OQT responsibilities and authority are defined to cover all pertinent activities, are carried out in a vigorous and SRT response and appropriate corrective action to OQT fi Your response to this letter is requested within fourteen days frc:

this letter.

receipt of Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A Of fice of Nuclear Reactor Regulation ENCLO5URE

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Log # TXX-4931 File # 10068 TEXAS UTILITIES GENERATING COMPANY SKYWAY TOWER

• 400 NORT,9 OtJVE STREET. L.B. 5 8

• DALLAa, TEXAS 78308 July 23, 1986

.thiRMf?JaTA Director of Nuclear Reactor Regulation Attention: Mr. Vince S. Noonan, Director Comanche Peak Project U.S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

COMANCHE PEAX STEAM ELECTRIC STATION DOCKET NOS.

50-445 AND 50-446 CPRT OVERVIEW QUALITY TEAM (0QT)

Dear Mr. Noonan:

This is in response to your June 9,1986, letter to me regarding activities of the CPRT Overview Quality Team (0QT).

Your letter requested we take action on four items. Those items and our associated actions are as follow:

1.

You requested that the CPRT Senior Review Team (SRT) establish and implement a detailed audit program for the Technical Review Team (TRT) issue-specific action plans (ISAPs). On June 18, 1986, the SRT directed that the TERA and ERC CPRT audit programs be expanded to encompass the TRT ISAPs. Consequently, the TERA audit program was expanded to cover ongoing TRT ISAP implementation activities in the Civil, Structural, Mechanical, and Miscellaneous areas and the ERC audit program was expanded to cover ongoing TRT ISAP implementation activities in the Electrical and Testing areas. One audit has already been conducted in the Testing area and plans for future audits of TRT ISAP implementation are reflected in the attached OQT schedule (Attachment 1).

These as well as other CPRT audit activities are designed to be in-process activities; therefore, unless specific audit findings indicate a need to audit l

completed TRT ISAP activities, audits will not be conducted of the implementation of a TRT ISAP after its Results Report has been l

submitted to the SRT for review and approval. Our actions taken in response to this matter complement measures previously instituted by the SRT which are described in Appendix G of the CPRT Program Plan to ensure the quality of implementation of TRT ISAPs.

• /1 A Dl%'IRION OF TEEAR UTitJT1ES E12CTn1C COMPANY

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2.

You requested a caster schIdule for 0QT review activities. During th2 period of time that 00T is functioning, each type of CPRT activity subject to 0QT review will be reviewed at least once.

Additional reviews will be scheduled for those activities that warrant additional OQT attention. Attachment 1 is a current three-month schedule of 0QT review efforts.

At this state of CPRT Program Plan implementation it is difficult to accurately project a schedule beyond a three-month period.

You will note that the review areas are commensurate with the 0QT review responsibilities delineated in the program document, " Overview Quality Team Program for Comanche Peak Response Team Activities" (Attachment 2). This schedule will be updated during each formal monthly 0QT meeting.

3.

You requested procedural controls be established for timely resolution by SRT of matters identified by the 0QT. Section 3.7 of describes the normal process utilized by the 0QT to

. resolve problems identified by the 0QT.

That section also describes the 00T responsibility to refer to the SRT those problems that the 0QT cannot resolve with the Review Team Leaders. Section 3.11 of describes how 0QT tracks all 0QT open items, which include those items referred to the SRT for resolution, to assure they are resolved.

Recommendations by the 0QT to the SRT will likewise be tracked on the 0QT open item list.

The SRT has delegated to the 0QT the responsibility to track 0QT open items and to notify the SRT when timely resolution is not forthcoming. We believe these controls assure that 0QT problems are resolved in a timely fashion.

4.

You requested a procedure describing the responsibilities and authority of the OQT. Attachment 2 is a recent revision of the 0QT program document. The 0QT is not a line organization and does not have the authority to direct any CPRT activities.

It is a review and advisory body. Attachment 2 delineates the review responsibilities of the 0QT and describes its responsibility to resolve 0QT identified problems directly with the Review Team Leaders. We believe Attachment 2 accurately describes the responsibilities and authority of the OQT.

Should you have any questions, please do not hesitate to call either me or John Beck.

Very truly yours W. G. Counsil RSB/gj Attachments i

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COMANCHE PEAK STEAM ELECTRIC STATION UNITS 1 AND 2 OVERVIEW QUALITY TEAM PROGRAM FOR COMANCHE PEAK RESPONSE TEAM ACTIVITIES JULY 23, 1986 I

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John Y. Streeter, Chairman CPRT-0QT A

a eph F.' Artuso, CPRT-0QT Larry V W6ckie,'CPRT-0QT C%m v

L 2.WA6 Jame's V. Neely, CPRT-0QT

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.es R. Wells, CPRT-0QT TEXAS UTILITIES GENERATING COMPANY A DIVISION OF TEXAS UTILITIES ELECTRIC COMPANY PAGE 1 0F 7 REVISED 7/23/86 440&902tt 7pf,

e 1.0-Purpose and Objectives The purpose of the Overview Quality Team (0 !) is to support the Senior Review Team (SRT) by supplement.ng the Comanche Peak Response Team (CPRT) quality assurance efforts to provide further assurance that the CPRT Q.ality Assurance Program as described in Appendix G of the CPRT Program Plan is effectively implemented.

The 0QT will function until such time that the SRT concludes that the level of CPRT activities no longer justifies tre need for the OQT.

The OQT will accomplish its purpcse by providing an evaluation of the implementation of the CPRT QA Program relative to achievement of the following ob,*ectives:

Adequacy and completeness of QA procedures necessary to accomplish the overall QA Program objectives.

Adequacy of training and, qualification of personnel involved in the auditing and surveillance processes.

Adequacy of frequency, timeliness and thoroughness of QA surveillance and audits necessary to assure that both the form and substance of QA Program elements are fully evaluated.

Conduct of QA activities in accordance with applicable industry standards and practices.

The quality of the following activities is assured by other measures instituted by the SRT and these activities are not within the scope of the OQT:

SRT activities, Technical review of Results Reports, Assessment of CPRT program adequacy.

The OQT overview of the implementation of : SAPS and DSAPs is intended to be an in process review of ongoing implementation activities, including the ongoing files review efforts of the Results Report and Working Files Review Committee.

Therefore, the OQT will not conduct reviews of the implementation of an ISA7 or DSAP after the Results Report has been submitted to SRT for review and approval unless such reviews are directed by the SRT.

PAGE 2 0F 7 REVISED 7/23/86

2.0 Relationship of OQT and SRT The OQT will receive direction fron the SRT.

Direction will be given in the form of memoranda, oral instructions given during meetings between the OQT and SRT, and through correspondence and discussions between the Chairmen of the SRT and OQT acting in behalf of their respective teams.

For administrative ease, during periods between formal OQT meetings the direction from the SRT will generally be of the latter form.

3.0 General Description of OQT Program The activities and methods utilized by the OQT to accomplish its purpose are identified in the following sections.

During the period of time OQT is functioning, each type of activity subject to OQT overview will be overviewed at least once.

Those activities deemed by the SRT or OQT to warrant increased attention will receive more overview from the OQT.

3.1 Interviews and Reviews of Personnel Records Interviews of selected members of the CPRT staff will be conducted to discuss their responsibilities and the means used to achieve the quality assurance objectives.

Interviews will include, but will not necessarily be limited to, the following individuals:

CPRT Program Director.

Review Team Leaders, Issue Coordinators, Inspectors, QA Managers, and QA Auditors OQT will also review the records of selected personnel, and interview if necessary, to determine if they are adequately qualified and trained to perform their assigned casks, and that they can perform them objectively and without influence from prior organizational af filiations.

PAGE 3 OF 7 REVISED 7/23/86

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3.2 Procedure Reviews Selected procedures will be reviewed to determine if the procedures, when properly implemented, will achieve the objectives of the QA Program.

Such reviews will determine if commitments in selected action plans are adequately addressed in the procedures, and whether the procedures adequately provide for or specify the necessary organizational structure, interfaces, record requirements, work processes, review and approval processes, document control, file content and retrievability requirements.

3.3 Audit Plans and Record Review OQT will review selected audit plans for the purpose of assessing the adequacy of audit frequency, timeliness, and thoroughness.

OQT will discuss any desired additions or changes with the Design Adequacy Program (DAP) and Quality of Construction (QOC) Program Review Team I.eaders and QA Managers.

Any areas of disagreement will be referred to the SRT for resolution.

Records generated for all audits conducted by the QA organizations of the DAP and QOC Program review teams will be reviewed by the OQT to determine if the audit objectives were

achieved, and if the responses and corrective actions taken in response to those audits are complete and adequate.

3.4 Supplemental Auditors or Inspectors Should OQT concerns develop relative to the adequacy of the frequency, timeliness, or thoroughness of the audits. OQT will provide additional auditors and inspectors to serve as members of selected audit teams.

Those inspectors and auditors will work under the direction of the DAP and QOC Program audit team leaders.

3.5 Observation of Audits OQT members will participate as observers of selected audits conducted by the QA organizations of the DAP and QOC Program review teams to obtain direct knowledge of the quality of the conduct of the audits.

PAGE 4 OF 7 REVISED 7/23/86

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-E 3.6 Direct Observation of Overview Inspection Activities OQT will perform direct observations of selected overview inspection activities to obtain direct knowledge of the quality of the conduct of those activities.

The results of those direct observations will be compared to any related QA audit or surveillance results to assess the effectiveness of the QA Program audit and surveillance activities.

3.7 Problem Resolution OQT will directly interface with Review Team Leaders to discuss and to achieve resolution of problems.

Whenever resolutions are not achieved, such issues will be referred to the SRT for resolution.

Whenever timely resolution of Audit Action Requests, Corrective Action

Requests, Corrective Action

Reports, and OQT problems is not forthcoming, such issues will also be referred to the SRT for resolution.

3.8 NRC Inspection Report Review Available reports of all NRC inspections of CPRT QA activities and the responses and corrective actions taken which relate to those inspections will be reviewed by the OQT to identify information regarding the implementation of the CPRT QA Program.

3.9 Special Reviews Special reviews of CPRT activities will be conducted by the OQT as requested by the SRT.

3.10 Conduct of QA Activities OQT will review the work products of QA activities to determine if those activities are conducted in accordance with applicable industry standards and practices.

Such sork products include the products of

audits, overview inspections, resolutions to problems as discussed in preceding sections.

PAGE 5 0F 7 REVISED 7/23/86

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3.11 Open Item Tracking e

Each OQT open item will be tracked by OQT to closure.

This will be accomplished by including a tabulation of all open items in each OQT periodic progress and status report which will indicate the action parties and due dates.

Recommendations by the OQT to the SRT will likewise be tracked on the OQT open J

item list.

q 3.12 Exit Interviews I

OQT exit interviews will be conducted with members -

of the SRT, or SRT appointed representatives, and z.

Review Team

Leaders, or their appointed representatives, to present the OQT observations and recommendations.

The exit interviews will normally be held at or near the end of each formal meeting period.

3.13 Schedule A schedule of OQT activities will be prepared for the upcoming three month period.

This schedule will be reviewed and updated monthly and a copy

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will be attached to each OQT periodic progress and status report.

P 4.0 Periodic Progress and Status Reports Reports summarizing the progress and status of the OQT

effort, reviews, observations and conclusions will be prepared periodically, approximately on a monthly basis, and will be submitted to the Chairman of the SRT with copies to the other SRT members, the Review Team Leaders, and the TUCCO Executive Vice President, Nuclear Engineering and Operations (NEO).

The periodic progress and :tatus reports will include an executive summary highlighting the important observations and recommendations, plus a tabulation of all open items and a copy of the updated OQT schedule.

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At the conclusion of the OQT program, a final report will 4

be ' prepared by the OQT summarizing the results presented in the periodic progress and_ status reports and will be submitted to the Chairman of the SRT with copies to the

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,' other SRT, members, Review Team Leaders, and the TUCCO

' Executive Vice President, NEO.

The final report will

'present the results of the entire OQT effort in providing enditional assurance that all QA organizations have i

', d e q'u a t e ly implemented their respective QA programs.

j;,' The final report will include an overall evaluation of the effectiveness of the CPRT QA Program implementation based on an OQT assessment of the degree of achievement of the four objectives stated in Section 1.0.

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PAGE 7 0F 7 REVISED 7/23/86 l /

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Docket Nos.:

50-445 k~

Mr. Willias. Co I

Executive Vice President j..'

Texas Utilities Generating Company A

Skyway Tower,l..B. 81 400 North Olive Street Dallas, Texas 75201

Dear Mr. Counsil:

This concerns the CPRT Overview Quality Team (00T) discussed in SSER 13 in M

Section 4. CPRT Quality Assurance Program.

In that section, we stated that the overview provided for the TRT issue-specific action plans (! SAPS) does not

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include a detailed audit program, and requested that an audit program be established and implemented by the Senior Review Team for the TRT ISAP t

program. We would like to settle this matter promptly.

In addition, the NRC staff has identified other areas where improvements should be made." These are:

(1) A master schedule for 007 reviews and audits.

1 (2) Procedural controls for timely resolution by l

SRT of matters identified by the 007.

(3) A procedure describing the responsibilities and authority of the 00T.

You are requested to respond to these matters within forty-five days of this request.

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Sincere 1y, p

Vincent S. Noonan Director PWR Project Directorate #5 Division of PWR t.icensing-A Cc:. See nfXt pa9e Distribution:

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[ August 16, 1985 Mr. Vincent S.

Noonan Director, Comanche Peak Project Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

20555

SUBJECT:

COMANCHE PEAK RESPONSE TEAM / QUALITY ASPECTS

Dear Mr. Noonan:

This letter is to transmit overview of the CPRT activities asthe essence of a quality assurance some other aspects of our CPRT program.a whole and to clarify We have taken action to.e.stabli_sh an overview Quality Team (OOT)

E6Ts'sE7th$t ^t'fie"C6tnanch'e Peak Response Teamto provide assi (CPRT) meets their three objectives:

1)

Evaluate each of the specific external source issues relating to installed hardware, design adequacy or testing.

2)

Determine the root cause of each safety-significant deficiency and analyze the generic implications to determine the ev.ent of any additional construction, design.or testin may be deficient for the same g efforts that reasons (or trend of non-safety-significant a

reasons).

3)

Conduct self-initiated evaluations of the quality of CPSES construction and the adequacy of its design.

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The OQT will provide TUGCO management with additional assurance that the CPRT has properly responded to and resolved (or provided recommendations for resolution to be accomplished under another program) the open issues' identified in the TRT, ASLB, SSER, SIT, CAT and Region IV reports.

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The 00T will report directly to the Executive Vice President Of TUGCO.

This will insure that all activities and. staff of the CPRT, including the Senior Review Team (SRT),

will come under this surveillance.

This rep.orting J.eyel will assur_e. tha.t..all policies and procedures, results reports,. personnel qualifications, objectives,- methodology, independence, integrity and a commitment to quality are maintained.

The OQT will be composed of third party, senior individuals and the TUGCO Director of Quality Assurance (who is a Duke Power Company employee on contract to TUGCO).

The members shall collectively be qualified to cover the areas of design, construction and QA/QC.

The team shall be selected based on experience in nuclear plant design, construction, operation, and assessment of programs similar to the CPRT program.

A team leader shall be designated.

The components of the CPRT program shall be reviewed to a depth and f requency as determined by the OQT to assure that all of the program objectives are met.

All procedures, programs, results, documents, working papers, reference documents and personnel qualifications shall be available to the 00T as needed.

Their review may consist of informal meetings, formal meetings and document reviews.

They shall have available to them inspectors / auditors as needed from the Quality of Construction Team to perform additional audits that may be required.

The Comanche Peak Response Team Program Plan and Issue-Specific Action Plans, Rev.

2, June 28, 1985 and all subsequent revisions will be used as the source document by the 00T.

The OQT shall issue additional documents as necessary to implement this programs.

The CPRT Program Plan states the charter, principles, structure, methodology, process and other elements of the plan.

Attached to this letter is a CPRT policy statement on quality which will be included in the upcoming Revision 3 of the Program Plan and Issue Specific Action Plans.

Turning now to some other fundamentally important features I

of the CPRT programs, we have established the following provisions and either have or will on a timely basis.

be implementing them 1)

The CPRT effort will be open to NRC audit or overview on an as-needed basis.

We would 4

request that NRC contacts with CPRT personnel -

the site be coordinated through Mr. Terry at Tyler, the CPRT Program Director.

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It is our intent to formally present CPRT progess on a monthly basis to the NRC.

We suggest that this be accomplished by public briefings in the Arlington, Texas vicinity commencing in late September with the initial presentation.

3), We shall, when the final Issue Specific Results Reports are filed with the NRC, make available at the site for public perusal the report and the CPRT files which support it.

It is our view that these steps and the 00T, taken together with the carefully structured, third-party nature of the CPRT program itself, provide a vigorous and open process which meet the requirements of 10CFR50, Appendix B, and essentially guarantees its integrity and that of the final product and conclusions.

Should you have any questions regarding the content of this letter or the attachment, please contact either myself or Mr. John W.

Beck.

Very truly yours, l

W.

G. Counsil WGC:JWB: tis Attachments e

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t COMANCHE PEAK RESPONSE TEAM POLICY ON OUALITY ASSURANCE The Comanche Peak Response Team (CPRT) is, committed to assuring the quality of CPRT Program activities and results.

The TUGCO and SRT commitment to quality is manifested in a series of program principles that are detailed in the CPRT Program Plan.

The CPRT has and will continue to monitor and evaluate the activities and results of the CPRT Program against these principles and CPRT Policies and Guidelines.

The Overview Quality Team will be responsible for providing additional assurance that.

the CPRT meets their objectives.

t The CPRT will not perform inspections, calculations, or designs of record.

CPRT activities and results will not form any of the bases for the design or construction of the plant nor will the CPRT activities have a direct impact on the plant as it physically exists.

For this reason, the CPRT does not fall under the normal Comanche Peak QA Program established by TUGCO as specified in the FSAR.

The CPRT has been set up to consist of independent, third party experts who will advise TUGCO management of existing plant conditions, and who will make recommendations for the resolution of any problems which may exist.

~_

Although third party CPRT activities are not subject to the normal TUGCO-QA Program requirements, the importance of the CPRT activities is recognized; and the CPRT Program Plan has been establishoo to define and control CPRT activities.

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This Plan, which has been developed and approved by the CPRT Senior Review Team, defines responsibilities, objectives, organization, personnel qualification requirements, interfaces, and procedura] and documentation requirements which are necessary to ensure that CPRT activities occur in an orderly and controlled manner and that CPRT objectives are achieved.

The CPRT has conducted a review of the 18 Criterion contained in Appendix B' to 10CFR50 to determine those criterion that may apply either in part or totally to the CPRT program.

The SRT has required the Design Adequacy and Quality of Construction Review Team Leaders to develop procedures, using Appendix B as a guide, to control their operations.

These procedures supplement the CPRT Policies and Guidelines and are identified in Attachments 3 and 4 to this policy.

Requirements for the selection ;# personnel in terms of experience, qualifications, independence, and objectivity are specified in the CPRT Program Plan and the evaluations for compliance with these requirements are documented.

Additionally, all inspection personnel used in the CPRT effort are required to be certified Level II and Level III in accordance with ANSI N45.2.6 and Regulatory Guide 1.58.

The QA/QC Review Team Leader is responsible for verifying that the qualifications of all inspectors utilized in the CPRT effort meet these requirements.

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Investigative activities and evaluations are controlled by Issue-Specific Actic.n Plan (ISAP's) which require Senior Review Team approval.

These ISA P 's ar e sup[.lemented by detailed instructions and procedures, and all implementation activities and results are documented and controlled in the CPRT central files.

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ISAP-results reports are subject to Senior Review Team review and approval to assure completeness and validity of results.

Procedures have been established by the CPRT which require the documentation and disposition of all deviations and deficiences which are identified during CPRT activities.

In addition to the review conducted by the CPRT to assess safety significance, procedures require that these documented deviations and deficiencies are formally transmitted in a timely manner to TUGCO so that they may be evaluated and resolved in accordance with the requirements of the Comanche Peak QA Program.

In summary, adequate controls have been established to ensure the completeness, validity, and documentation of all CPRT results.

_ Equally important, have been established pr,ocedural controls to assure that CPRT activities considered to fall under Appendix B, in part or fully, have been considered and controlled by precedures The following documents supplement and implement-the requirements of this policy:

CPRT Policies

- Attachment 1 CPRT Guidelines

- Attachment 2 DAP Procedures /Instructio'ns

- Attachment 3 QA/QC Procedures / Instructions p

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