ML20209B682
| ML20209B682 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/15/1982 |
| From: | Haass W Office of Nuclear Reactor Regulation |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML16340C148 | List:
|
| References | |
| FOIA-86-151 NUDOCS 8210060015 | |
| Download: ML20209B682 (2) | |
Text
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aj Docket No. 50-275 MEMORANDUM FOR: Richard H. Vollmer, Director Division of Engineering THRU:
William V. Johnston, Assistant Director ($ \\'h Materials & Qualifications Engineering FROM:
Walter P. Haass, Chief Quality Assurance Branch
SUBJECT:
QAB CO MENTS ON IDVP FOR DIABLO CANYON - PHASE II We have reviewed Teledyne Engineering Services' submittal of June 18, 1982,
" Independent Design Verification Program, Phase II Program Management Plan" and have the following comments:
1.
The first paragraph of section 3.3 on page 18 of the plan needs to better define the acceptance criteria for the quality assurance program and implementation. This paragraph states that evaluation shall be " relative to the criteria of 10 CFR 50 Appendix B as they are understood at the present time, but not including the contents of implementing standards approved subsequent to perfomance of the work as requirements applicable to the work." The phase I plan (section 2.2 on page 6) simply indicated review "for compliance with the requirements of 10 CFR 50, Appendix B, applicable to design control and the related criteria (e.g...NRC Regulatory Guides, NUREGS, ANSI, etc.)..'.," with reference elsewhere (section 3.1 on page 10) to 10 CFR 50 Appendix B only.
We believe that the acceptance criteria for the IDVP review should reflect commitments made by PG&E to the NRC covering the time frame during which the design activities were conducted and the documented QA policies and procedures meeting these commitments which were in effect during the same time frame.
These commitments would clearly include Appendix B plus any subsequent upgrades adopted by PG&E, but would clearly not include all the current staff requirements for meeting Appendix B as presently understood.
2.
The change in scope relative to field verification needs to be addressed in the plan.
The plan apparently covers field verification of the hardware items which undergo design verification, but we understand that PG&E has proposed to expand the field verification scope during the status meeting held the week of August 30, 1982. This should be reflected in the plan unless the additional work is not to be done under the TES program.
The plan should also clarify which organization (s) will be responsible for the field verification activities.
The plan presently indicates that both SWEC and RLCA will perfom some field verification (per section 3.7 and 4.7 of the phase II plan), although the SWEC scope does not include system instal-lation requirements or as-built configurations (per section 2.4 of the plan
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3.
The purpose of the field design. verification (per the third paragraph of sections 3.7 and 4.7 of Appendix D of the phase II plan) is to gain reasonable sssurance "that the characteristics used in the verification process have been properly established and utilized.... the intent is to apply the criteria on configuration which were intended to be used during the licensing process." It is not clear what this means. We believe that it should mean that the hardware will be checked to see that it has been installed as designed, and this should be clarified in the plan.
4A f1 s-w Walter P. Haass, Chief Quality Assurance Branch Division of Engineering cc:
J. Knight T. Novak F. Miraglia B. Buckley H. Schierling r
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