CNL-22-019, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Reduction in Commitment
| ML22035A183 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah, Clinch River  |
| Issue date: | 02/04/2022 |
| From: | Polickoski J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| CNL-22-019 TVA-NQA-PLN89-A | |
| Download: ML22035A183 (18) | |
Text
1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-019 February 4, 2022 10 CFR 50.54(a)(4)
ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, 50-296, and 72-052 Clinch River Nuclear Site Early Site Permit No. ESP-006 NRC Docket No.52-047 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327, 50-328, and 72-034 Watts Bar Nuclear Plant, Unit 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390, 50-391, and 72-1048
Subject:
Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Reduction in Commitment In accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) 50.54(a)(4), Tennessee Valley Authority (TVA) hereby requests approval of a revision to the Nuclear Quality Assurance Plan (NQAP). The proposed changes are considered to be a reduction in commitment, which require approval by the Nuclear Regulatory Commission prior to implementation. Specifically, TVA is proposing to revise the NQAP to eliminate the Vice President, Nuclear Oversight (NOS) position and reflect the reporting relationship of the General Manager (GM), Quality Assurance (QA), to the Chief Nuclear Officer. Additionally, the education and work experience requirements for QA management will be consistent with industry standards.
The proposed change to the NQAP applies to the above listed docket numbers. It should be noted that while the NQAP also addresses the Bellefonte Nuclear Plant (BLN), Units 1 and 2
[(Construction Permit (CP) Nos. CPPR-122 and CPPR-123)], the CPs for BLN Units 1 and 2
U.S. Nuclear Regulatory Commission CNL-22-019 Page 2 February 4, 2022 have expired.1 TVA plans to revise the NQAP at a later date to remove the references to BLN Units 1 and 2.
The enclosure is included pursuant to 10 CFR 50.54(a)(4) and includes a description of the change, justification for the proposed change, and provides a basis for concluding the revised NQAP will continue to satisfy the criteria of 10 CFR 50 Appendix B. Attachments 1 and 2, to the Enclosure, provide markup and retyped pages, respectively, of the TVA NQAP.
Approval of the change is requested within the 60 days identified in 10 CFR 50.54(a)(4).
The NQAP will be revised within 10 days of approval to support fleet activities.
There are no new regulatory commitments in this letter. Please address any questions regarding this request to Stuart L. Rymer, Senior Manager, Fleet Licensing, at slrymer@tva.gov.
Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs
Enclosure:
Description and Justification of Proposed NQAP Changes cc: (with Enclosure):
NRC Director, Office of Nuclear Reactor Regulation NRC Senior Project Manager, Office of Nuclear Reactor Regulation, Division of New and Renewed Licenses NRC Project Manager - Bellefonte Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant 1 TVA letter to NRC, CNL-21-082, Bellefonte Nuclear Plant, Units 1 and 2 - Withdrawal of Request for Extension of Unit 1 and Unit 2 Construction Permits (CPPR-122 and CPPR-123), dated September 10, 2021 (ML21253A243)
Digitally signed by Carla Edmondson Date: 2022.02.04 14:08:02 -05'00'
ENCLOSURE Description and Justification of Proposed NQAP Changes CNL-22-019 E1 of 5 1.0 Introduction In accordance with the requirements of Title 10, Code of Federal Regulations (10 CFR) 50.54(a)(4), Tennessee Valley Authority (TVA) hereby requests approval of a revision to the Nuclear Quality Assurance Plan (NQAP). The proposed changes are considered to be a reduction in commitment, which require approval by the Nuclear Regulatory Commission (NRC) prior to implementation. Specifically, TVA is proposing to revise the NQAP to eliminate the Vice President, Nuclear Oversight (NOS) position and reflect the reporting relationship of the General Manager (GM), Quality Assurance (QA), to the Chief Nuclear Officer (CNO).
Additionally, the education and work experience requirements for QA management will be consistent with industry standards. The proposed change applies to the Browns Ferry Nuclear Plant, Units 1, 2, and 3, the Sequoyah Nuclear Plant, Units 1 and 2, the Watts Bar Nuclear Plant, Units 1 and 2, and the Clinch River Nuclear Site.
2.0 Description of the Changes The proposed changes to the TVA NQAP will firstly, eliminate the Vice President, NOS position and reflect the reporting relationship of the GM, QA to the CNO. Secondly, the education and work experience requirements for QA management will be consistent with industry standards (References 1 and 2). The changes will be placed in NQAP Sections 4.1.9, 4.1.10, Appendix B, Table 2, Regulatory Guide Conformance Status, and Appendix I, TVA NQAP Organization Chart. Further detail on the proposed changes to the NQAP is provided in Tables 1 and 2 to this enclosure.
provides the marked-up pages of TVAs NQAP showing the proposed changes, and provides the retyped pages.
3.0 Justification for the Proposed Changes The proposed change to eliminate the Vice President, NOS position is based on industry benchmarking, review of currently accepted standards, and the reevaluation of the QA role and TVA fleet needs. The proposed change reflects the reporting relationship of the GM, QA to the CNO. Assigning the GM, QA as a direct report to the CNO preserves QA independence. Similar to the Vice President, NOS position, the GM, QA reports directly to the CNO and will continue to manage the TVA NQA organization. It should also be noted that the roles and responsibilities of the Vice President, NOS are not described in the NQAP.
The proposed change to the QA management education and work experience requirements aligns the requirements with currently accepted industry standards. The existing requirements were recognized as cumbersome with a negative impact on TVA management long-term succession planning. The criteria proposed were adopted from the latest revision of American National Standards Institute/American Nuclear Society (ANSI/ANS) 3.1 (Reference 1) and endorsed by the NRC in Regulatory Guide 1.8, Revision 4 (Reference 2). The use of these criteria does not imply a commitment to ANSI/ANS 3.1-2014 or Regulatory Guide (RG) 1.8, Revision 4.
Further detail on the justification for the proposed changes to the NQAP is provided in Tables 1 and 2 to this enclosure.
ENCLOSURE Description and Justification of Proposed NQAP Changes CNL-22-019 E2 of 5 Table 1 - Elimination of Position of Vice President, Nuclear Oversight NQAP Section Current Text Revised Text Justification for Change 4.1.9 Nuclear Oversight The management position responsible for nuclear oversight reports to the CNO and manages the TVA Nuclear Quality Assurance organization.
The management position responsible for quality assurance reports to the CNO and manages the TVA Nuclear Quality Assurance organization.
Alignment of GM, QA responsibilities with 4.1.10.A, 1st paragraph below.
4.1.10, Quality Assurance, Section A, 1st paragraph The General Manager, QA, reports to the management position responsible for nuclear oversight.
The General Manager, QA has an independent reporting relationship to the CNO on quality issues.
The General Manager, QA is the management position responsible for quality assurance. The General Manager, QA has an independent reporting relationship to the CNO on quality issues.
Elimination of VP, NOS position was a business decision based on benchmarking and reevaluation of QA role and TVA fleet needs. Assigning the GM, QA as a direct report to CNO preserves QA independence.
Appendix I, TVA NQAP Organization Chart Elimination of VP, NOS position, designates GM, QA as direct report of CNO.
ENCLOSURE Description and Justification of Proposed NQAP Changes CNL-22-019 E3 of 5 Table 2 - Revision of Education and Experience Requirements for Quality Assurance Management NQAP Section Current Text Revised Text Justification for Change 4.1.10, Quality Assurance, Section A, 4th paragraph The General Manager, QA, is required to have a bachelors degree in an engineering or related science, or equivalent related experience. The General Manager, QA, shall have at least 10 years experience in a senior managerial capacity with five years experience in nuclear quality assurance related activities. At least one year of experience shall be nuclear power plant experience in the implementation of the quality assurance program.
The General Manager, QA is required to have a bachelors degree in engineering or related science. The General Manager, QA shall have at least four years related experience which shall include: two years nuclear power plant experience, one year supervisory or management experience and one year in the performance of quality verification activities.
Aligns the education and experience requirements for the GM, QA with Senior Manager level requirements as described in ANSI/ANS 3.1-2014 (Section 4.2.6, pg. 11) as endorsed by RG 1.8 R4 4.1.10, Quality Assurance, Section B, 2nd paragraph The management position responsible for corporate QA is required to have four years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position, preferably at an operating nuclear plant or a combination of the two. At least one year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program.
The management position responsible for corporate QA is required to have a high school diploma or equivalent and one year of related experience.
Aligns the education and experience requirements for the management position responsible for corporate QA with middle manager level requirements as described in ANSI/ANS 3.1-2014 (Section 4.3.5, pg. 13) as endorsed by RG 1.8, R4.
4.1.10, Quality Assurance, Section D, 2nd paragraph The management positions responsible for site QA are required to have a bachelors degree in an engineering or scientific discipline, or equivalent related experience. They shall have at least nine years experience in plant design, construction, power plant operation, or maintenance, including five years experience in QA-related activities.
The management positions responsible for site QA are required to have a high school diploma or equivalent and one year related experience.
Aligns the education and experience requirements for the management position responsible for site QA with middle manager level requirements as described in ANSI/ANS 3.1-2014 (Section 4.3.5, pg. 13) as endorsed by RG 1.8, R4.
ENCLOSURE Description and Justification of Proposed NQAP Changes CNL-22-019 E4 of 5 Table 2 - Revision of Education and Experience Requirements for Quality Assurance Management NQAP Section Current Text Revised Text Justification for Change Appendix B Table 2, Alternatives to RG 1.8 R2, para. F In lieu of the one year of experience in the implementation of the quality assurance program for the management position responsible for site QA (ANSI/ANS 3.1-1981, Section 4.4.5.b), TVA requires five years experience in QA-related activities.
For QA manager positions, individuals who do not possess the formal educational and experience requirements specified may be considered acceptable when other factors provide sufficient demonstration of required abilities. These other factors are to be evaluated on a case-by-case basis and approved and documented by senior management.
Temporary appointments of an unqualified QA manager shall be limited to one year in duration. During the temporary appointment, an unqualified QA manager shall be provided a single, directly-reporting staff member who meets the QA manager qualification position requirements to assist in decision-making.
Deletes existing paragraph F as no longer applicable after revision. Replaces with two new paragraphs based on ANSI/ANS 3.1-2014 (Section 4.2.6, pg. 11 and Section 4.3.5, pg. 13) as endorsed by RG 1.8, R4. Paragraphs are modified to be specific to QA management positions only.
Requirement for temporary middle manager appointments is based on RG 1.8, R4, Part C., Staff Regulatory Guidance, Section 1.1, Section 4.3, Middle Level Manager
ENCLOSURE Description and Justification of Proposed NQAP Changes CNL-22-019 E5 of 5 4.0 Basis for Concluding that the Revised Program Continues to Satisfy the Criteria of 10 CFR 50 Appendix B and the Previously Accepted Quality Assurance Program Commitments The proposed changes, though considered a reduction in commitment, continue to satisfy the Criteria of 10 CFR 50 Appendix B. Specifically:
x Elimination of the Vice President, Nuclear Oversight position. The individual responsible for assuring effective execution of the quality assurance program, where activities subject to 10 CFR 50, Appendix B are being performed, will continue to have sufficient authority, organizational freedom and independence, and direct access to the levels of management necessary to perform this function.
x QA management education and experience requirements. The reduction in education and experience requirements for QA managers is consistent with an accepted and endorsed industry standard. QA management can reasonably be expected to continue to provide (1) assurance that an appropriate quality assurance program is established and effectively executed; and (2) verification that activities affecting safety-related and quality-related functions have been correctly performed. QA management shall continue to have sufficient authority, organizational freedom, and independence to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
5.0 Conclusion The proposed change is compliant with, and continues to satisfy, the criteria of 10 CFR 50 Appendix B, as incorporated in the TVA NQAP.
6.0 References
- 1. American National Standard, ANSI/ANS-3.1-2014, Selection, Qualification, and Training of Personnel for Nuclear Power Plants
- 2. Regulatory Guide 1.8, Qualification and Training of Personnel for Nuclear Power Plants, Revision 4, June 2019 Proposed NQAP Changes (Markups)
CNL-22-019
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev. 0039 Page 40 of 154 4.1.8 Clinch River Nuclear A.
See Appendix K and L for SMR Project roles and responsibilities at the Clinch River Nuclear site.
B.
The General Manager, Quality Assurance administers QA responsibilities for CRN through the management position responsible for quality services.
C.
The management position responsible for quality services is responsible for invoking appropriate NQAP requirements on vendors that provide services for quality-related programs and features.
D.
The management position responsible for quality services shall ensure an audit of CRN, to the applicable criteria of 10CFR50 Appendix B, is performed on an annual basis in accordance with NQAP Section 12.0, Auditing, and shall arrange for the assessment of the CRN QA organization by an independent organization on an annual basis.
4.1.9 Nuclear Oversight The management position responsible for nuclear oversight reports to the CNO and manages the TVA Nuclear Quality Assurance organization.
4.1.10 Quality Assurance (QA)
A.
The General Manager, QA, reports to the management position responsible for nuclear oversight. The General Manager, QA has an independent reporting relationship to the CNO on quality issues.
The quality organization has direct access to appropriate levels of management and sufficient independence and organizational freedom to be able to effectively assure conformance to quality assurance program requirements.
The General Manager, QA, administers quality assurance responsibilities through the management positions responsible for corporate QA, site QA and quality services.
The General Manager, QA, is required to have a bachelors degree in an engineering or related science, or equivalent related experience. The General Manager, QA, shall have at least 10 years experience in a senior managerial capacity with five years experience in nuclear quality assurance related activities. At least one year of experience shall be nuclear power plant experience in the implementation of the quality assurance program.
The General Manager, QA has responsibility for the administration of TVAs NQAP requirements for projects being implemented on operating units by other organizations.
The General Manager, QA has responsibility for NQAP implementation for BLN Construction Permit status under guidance of GL-87-15 and RG 1.2 and other organizations.
The General Manager, QA administers QA responsibilities for CRN through the management position responsible for quality services.
quality assurance is quality assurance four years related experience which shall include: two years nuclear power plant experience, one year supervisory or management experience, and one year in the performance of quality verification activities.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev. 0039 Page 41 of 154 4.1.10 Quality Assurance (QA) (continued)
B.
The management position responsible for corporate QA reports directly to the General Manager, QA, and manages the development and maintenance of TVA Nuclear quality assurance programs to ensure compliance with regulations, commitments, and policies, including those Quality Assurance programs that govern activities performed by site Quality Assurance organization personnel. The management position responsible for corporate QA also manages the training program for TVA Nuclear QA personnel and the quality audit program.
The management position responsible for corporate QA is required to have four years experience in the field of quality assurance, or equivalent number of years of nuclear plant experience in a supervisory position, preferably at an operating nuclear plant or a combination of the two. At least one year of this four years experience shall be nuclear power plant experience in the implementation of the quality assurance program.
C.
The management position responsible for quality services reports directly to the General Manager, QA. The management position responsible for quality services:
- 1.
manages TVAs review and qualification of suppliers to ensure final acceptance of all safety-related material for all nuclear plants to comply with applicable specifications and requirements.
- 2.
manages the vendor audit program.
- 3.
develops and implements the nuclear Quality Control (QC) program which includes the QC inspection program, and the QC training program.
- 4.
ensures an audit of CRN, to the applicable criteria of 10CFR50 Appendix B, is performed on an annual basis in accordance with NQAP Section 12.0, Auditing and shall arrange for the assessment of CRN QA program by an independent organization on an annual basis.
D.
The management positions responsible for site QA report directly to the General Manager, QA, and are responsible for the quality assurance functions and oversight of quality control performance at the site. The management positions responsible for site QA provide oversight of day-to-day plant activities important to safety (for example, the QA organization routinely attends and participates in daily plant work schedule and status meetings to assure they are kept abreast of day-to-day work assignments throughout the plant and that there is adequate QA coverage).
The management positions responsible for site QA are required to have a bachelors degree in an engineering or scientific discipline, or equivalent related experience. They shall have at least nine years experience in plant design, construction, power plant operation, or maintenance, including five years experience in QA-related activities.
E.
TVA Nuclear Quality Assurance is responsible for:
- 1.
Developing and administering the NQAP and the QA organization procedures required to ensure that TVA activities provide the required degree of safety and reliability.
a high school diploma or equivalent and one year of related experience.
a high school diploma or equivalent and one year of related experience.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev. 0039 Page 110 of 154 Appendix B (Page 10 of 29)
Regulatory Guide Conformance Status Table 2 REGULATORY GUIDE CONFORMANCE STATUS NRC Regulatory Guide 1.8 - "Personnel Selection and Training," Revision 2, 4/87, endorses ANSI N18.1-1971 and ANSI/ANS 3.1-1981.
The Nuclear Quality Assurance Plan (NQAP) follows this Guide with the following alternatives:
A.
TVA will meet the requirements of Regulatory Guide 1.8, Revision 2 (4/87) for all new personnel qualifying on positions identified in regulatory position C.1 after January 1, 1990. Personnel qualified on these positions prior to this date will still meet the requirements of Regulatory Guide 1.8, Revision 1-R (5/77). As specified in regulatory position C.2, all other positions will meet the requirements of ANSI/ANS N18.1-1971.
B.
Section 4.3.2 - There may be occasions where TVA will utilize a composite crew (multidiscipline) during operations phase activities to efficiently perform a task. As such, a foreman may not have the experience required in one of the disciplines he supervises. In these instances, the foreman will meet the requirements of ANSI N18.1 in at least one of the disciplines, and additional technical support, procedure support, and/or discipline support will be available to the foreman for the task period.
C.
In lieu of the training guidelines endorsed by Regulatory Guide 1.8, Revision 2, specified in Regulatory Position Sections C.1.b and C.1.f, TVA shall comply with the requirements of 10 CFR 55.31(a) (4) and 10 CFR 55.59 as they apply to training programs based on a Systems Approach to Training (SAT) as defined in 10 CFR 55.4 and using a plant-referenced simulator as required by 10 CFR 55.45.
D.
TVA uses the methodology for equating education and experience contained in ANSI 3.1-1987 for guidance to evaluate equivalent related experience for a degree.
E.
In addition to the training guidelines in subsections 5.3.2, 5.3.3, 5.3.4, and 5.5 of ANSI N18.1-1971, TVA shall comply with the requirements of 10 CFR 50.120 as it applies to training programs based on a systems approach to training.
F.
In lieu of the one year of experience in the implementation of the quality assurance program for the management position responsible for site QA (ANSI/ANS 3.1-1981, Section 4.4.5.b), TVA requires five years experience in QA-related activities.
NRC Regulatory Guide 1.28 - "Quality Assurance Program Requirements (Design and Construction),"
Revision 3, 8/85, allows continued implementation of ANSI N45.2-1971 as previously committed.
The NQAP follows this Guide.
For QA manager positions, individuals who do not possess the formal educational and experience requirements specified may be considered acceptable when other factors provide sufficient demonstration of required abilities. These other factors are to be evaluated on a case-by-case basis and approved and documented by senior management.
Temporary appointments of an unqualified QA manager shall be limited to one year in duration. During the temporary appointment, an unqualified QA manager shall be provided a single, directly-reporting staff member who meets the QA manager qualification position requirements to assist in decision-making.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev. 0039 Page 142 of 154 Appendix I (Page 1 of 1)
TVA NQAP Organization Chart Proposed NQAP Changes (Final Typed)
CNL-22-019
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev.
Page 40 of 157 4.1.8 Clinch River Nuclear A.
See Appendix K and L for SMR Project roles and responsibilities at the Clinch River Nuclear site.
B.
The General Manager, Quality Assurance administers QA responsibilities for CRN through the management position responsible for quality services.
C.
The management position responsible for quality services is responsible for invoking appropriate NQAP requirements on vendors that provide services for quality-related programs and features.
D.
The management position responsible for quality services shall ensure an audit of CRN, to the applicable criteria of 10CFR50 Appendix B, is performed on an annual basis in accordance with NQAP Section 12.0, Auditing, and shall arrange for the assessment of the CRN QA organization by an independent organization on an annual basis.
4.1.9 Nuclear Oversight The management position responsible for quality assurance reports to the CNO and manages the TVA Nuclear Quality Assurance organization.
4.1.10 Quality Assurance (QA)
A.
The General Manager, QA, is the management position responsible for quality assurance. The General Manager, QA has an independent reporting relationship to the CNO on quality issues.
The quality organization has direct access to appropriate levels of management and sufficient independence and organizational freedom to be able to effectively assure conformance to quality assurance program requirements.
The General Manager, QA, administers quality assurance responsibilities through the management positions responsible for corporate QA, site QA and quality services.
The General Manager, QA, is required to have a bachelors degree in an engineering or related science. The General Manager, QA, shall have at least four years related experience which shall include: two years nuclear power plant experience, one year supervisory or management experience, and one year in the performance of quality verification activities.
The General Manager, QA has responsibility for the administration of TVAs NQAP requirements for projects being implemented on operating units by other organizations.
The General Manager, QA has responsibility for NQAP implementation for BLN Construction Permit status under guidance of GL-87-15 and RG 1.2 and other organizations.
The General Manager, QA administers QA responsibilities for CRN through the management position responsible for quality services.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev.
Page 41 of 157 4.1.10 Quality Assurance (QA) (continued)
%
The management position responsible for corporate QA reports directly to the General
Manager, QA, and manages the development and maintenance of TVA Nuclear quality
assurance programs to ensure compliance with regulations, commitments, andpolicies,
including those Quality Assurance programs that govern activities performedby site
Quality Assurance organization personnel. The management positionresponsible for
corporate QA also manages the training program for TVA Nuclear QApersonnel and
the quality audit program.
The management position responsible for corporate QA is required to have a high
school diploma or equivalent and one year of related experience.
&
The management position responsible for quality services reports directly to theGeneral Manager, QA. The management position responsible for quality services:
manages TVAs review and qualification of suppliers to ensure final acceptance of
all safety-related material for all nuclear plants to comply with applicable
specifications and requirements.
manages the vendor audit program.
develops and implements the nuclear Quality Control (QC) program whichincludes the QC inspection program, and the QC training program.
ensures an audit of CRN, to the applicable criteria of 10CFR50 Appendix B, is
performed on an annual basis in accordance with NQAP Section 12.0, Auditing
and shall arrange for the assessment of CRN QA program by an independent
organization on an annual basis.
'
The management positions responsible for site QA report directly to the General
Manager, QA, and are responsible for the quality assurance functions and oversight of
quality control performance at the site. The management positions responsible for site
QA provide oversight of day-to-day plant activities important to safety (for example, the
QA organization routinely attends and participates in daily plant work schedule and
status meetings to assure they are kept abreast of day-to-day work assignments
throughout the plant and that there is adequate QA coverage).
The management positions responsible for site QA are required to have a high school
diploma or equivalent and one year related exSerience.
(
TVA Nuclear Quality Assurance is responsible for:
Developing and administering the NQAP and the QA organization procedures
required to ensure that TVA activities provide the required degree of safety and
reliability.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev.
Page 113 of 157 Appendix B (Page 11 of 30)
Regulatory Guide Conformance Status Table 2 REGULATORY GUIDE CONFORMANCE STATUS NRC Regulatory Guide 1.8 - "Personnel Selection and Training," Revision 2, 4/87, endorses ANSI N18.1-1971 and ANSI/ANS 3.1-1981.
The Nuclear Quality Assurance Plan (NQAP) follows this Guide with the following alternatives:
$
TVA will meet the requirements of Regulatory Guide 1.8, Revision 2 (4/87) for all new personnel
qualifying on positions identified in regulatory position C.1 after January 1, 1990. Personnel
qualified on these positions prior to this date will still meet the requirements of Regulatory Guide
1.8, Revision 1-R (5/77). As specified in regulatory position C.2, all other positions will meet the
requirements of ANSI/ANS N18.1-1971.
%
Section 4.3.2 - There may be occasions where TVA will utilize a composite crew (multidiscipline)
during operations phase activities to efficiently perform a task. As such, a foreman may not have
the experience required in one of the disciplines he supervises. In these instances, the foreman
will meet the requirements of ANSI N18.1 in at least one of the disciplines, and additional
technical support, procedure support, and/or discipline support will be available to the foremanfor the task period.
&
In lieu of the training guidelines endorsed by Regulatory Guide 1.8, Revision 2, specified in
Regulatory Position Sections C.1.b and C.1.f, TVA shall comply with the requirements of 10 CFR
55.31(a) (4) and 10 CFR 55.59 as they apply to training programs based on a SystemsApproach
to Training (SAT) as defined in 10 CFR 55.4 and using a plant-referenced simulator asrequired
by 10 CFR 55.45.
'
TVA uses the methodology for equating education and experience contained in ANSI 3.1-1987
for guidance to evaluate equivalent related experience for a degree.
(
In addition to the training guidelines in subsections 5.3.2, 5.3.3, 5.3.4, and 5.5 of ANSI N18.1-1971, TVA shall comply with the requirements of 10 CFR 50.120 as it applies to training
programs based on a systems approach to training.
)
For QA manager positions, individuals who do not possess the formal educational and
experience requirements specified may be considered acceptable when other factors provide
sufficient demonstration of required abilities. These other factors are to be evaluated on a case-by-case basis and approved and documented by senior management.
Temporary appointments of an unqualified QA manager shall be limited to one year in duration.
During the temporary appointment, an unqualified QA manager shall be provided a single,
directly-reporting staff member who meets the QA manager qualification position requirements to
assist in decision-making.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev.
Page 114 of 157 Appendix B (Page 12 of 30)
Regulatory Guide Conformance Status Table 2 REGULATORY GUIDE CONFORMANCE STATUS NRC Regulatory Guide 1.28 - "Quality Assurance Program Requirements (Design and Construction),"
Revision 3, 8/85, allows continued implementation of ANSI N45.2-1971 as previously committed.
The NQAP follows this Guide.
NRC Regulatory Guide 1.30 - "Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment," 8/72, endorses ANSI N45.2.4-1972.
The NQAP follows this Guide with the following alternatives:
A.
ANSI N45.2.4 states that the Appendixes are not a part of the standard; therefore, TVA does not consider the Appendixes to be mandatory.
B.
Section 2.1, "Planning" - The intent of this section shall be met in different forms depending on magnitude and scope of work.
C.
During the operational phase, tests are performed as determined by the site engineering organization, modification, or maintenance engineers, as appropriate, based upon the equipment or system functions that could be impacted by the work performed.
D.
TVA's alternative to the tagging of in plant process instruments for calibration status (ANSI N45.2.4, Section 6.2.1) is that each item of process control instrumentation is uniquely identified with an instrument number. This number is utilized in an instrument maintenance record so that the current calibration status and data attesting to the status of each item are documented along with the identification of the person performing the calibration. In addition, this record system provides a mechanism for evaluating equipment performance and adjusting calibration frequencies to ensure quality performance.
E.
Section 6.2.2 - For modifications, TVA interprets this section as not requiring that an entire system be retested after modifications. Testing will be performed on equipment that has or could be impacted by the modification in accordance with applicable design and testing requirements to verify that operability requirements are met and that interfacing components and equipment functions have not been degraded.
F.
TVA implements the requirements of N45.2.4 Sections 5.1 and 6.1 with a performance-based graded QA verification program consisting of quality control inspection, line verification, and quality assessments.
TVA Quality Assurance Program Nuclear Quality Assurance Plan (NQAP)
(Quality Assurance Program Description)
TVA-NQA-PLN89-A Rev.
Page 145 of 157 Appendix I (Page 1 of 1)
TVA NQAP Organization Chart