ML20205Q548
| ML20205Q548 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/23/1986 |
| From: | Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20205F644 | List: |
| References | |
| FOIA-87-79, FOIA-87-89 NUDOCS 8605300576 | |
| Download: ML20205Q548 (10) | |
Text
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MEMORANDUM FOR: Vincent S. Noonan, Director PWR Project Director #5 Division of PWR Licensing-A Office of Nuclear Reactor Regulation ,
FROM: Brian K. Grimes, Director Division of Quality Assurance, Vendor, and Technical Training Center Programs Office of Inspection and Enforcement
SUBJECT:
SER INPUT FOR THE COMANCHE PEAK RESPONSE TEAM (CPRT) l PROGRAM PLAN QUALITY ASSURANCE In accordance with discussions with your staff and ELD, we have enclosed a revised SS'2R input regarding QA for the CPRT program.
1sy questions concerning the enclosed SSER input should be directed to John Gilray at X.27242.
Original alsned by Brian K. Grimes, Director Division of Quality Assurance, Vendor. (
and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
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4.0 CPRT QUALITY ASSURANCE PROGRAM _. _
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TheCPRTqualityassurance(QMprogramisdescribedintheCPRTProgramPlan[
. The objective of the CPRT QA program is to assure the quality of CPRT program activities and results. The CPRT Senior Review Team (SRT) directed that the
, QA program be developed based on appropriate criteria in 10 CFR Part 50, Appendix B.
The CPRT QA program is structured to govern 3 categories of CPRT activities:
o Technical Review Team (TRT) issue-specific action plans (ISAPs) that address concerns in the areas of electrical, QC inspector qualification, civil, structural, testing programs, mechanical and miscellaneous (ISAP
, series I through VI). The program established to govern this activity is referenced as the TRT ISAP QA program in the ensuing discussion. ~
o Quality of Construction (QOC) Program ISAPs that address QA/QC concerns raised by the TRT and other external sources, and that include the CPRT self-initiated actions related to CPSES quality of construction (ISAP series VII). The program established to govern this activity is referred to as the QOC QA Program in the ensuing discussion.
o Design Adequacy Program (DAP) discipline-specific action plans (DSAPs) that address design concerns raised by external sources and that include the CPRT self-initiated actions related to CPSES design adequacy (DSAP series VIII through XI). The program established to govern this activity is referred as the DAP QA Program in the ensuing discussion.
To support the Senior Review Team (SRT) in fulfilling its rerponsibilities, an Overview Quality Team (0QT) is established to assure that the QOC QA and DAP QA programs are being effectively implemented.
04/18/86 4-1 CP SSER 13 SEC. 4 1
The OQT supports the SRT and supplements CPRT QA activities 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 a,ll planned and
- periodic audits conducted by the organizations managing the QOC QA and DAP QA 3 programs, as well as any audits of CPRT activities conducted by the NRC and Texas Utility Generating Company (TUGCO). The OQT may also conduct special audits, as directed by the SRT Chairman.
4.2 Staff Evaluation
- , The staff's evaluation of the CPRT QA program is based on a review of the QA-program description to determine that
- (1) it provides a means to control the quality-related activities of the CPRT program, and (2) it meets the appropriate provisions of 10 CFR Part 50, Appendix 8. Based on the scope of the CPRT pro-gram discussed in previous sections of this SSER, the staff has determined that
- the criteria in 10 CFR Part 50, Appendix B, that the CPRT QA program should address are: Criterion 1, Organization; Criterion 2, QA program; Criterion 3, Design control; Criterion 4, Procurement document control; Criterion 5, Instruc-tions, procedures, and drawings; Criterion 6, Document control; Criterion 7, s
Control of purchased material, equipment, and services *; Criterion 10, Inspec-tion; Criterion 12, Control of measuring and test equipment; Criterion 15, -
Nonconforming materials, parts, or components; Criterion 16, Corrective action; Criterion 17, QA records; and Criterion 18, Audits. Conversely, the staff has determined that Criterion 8, Identification and control of material, parts, and components; Criterion 9, Control of special processes; Criterion 11, Test control; Criterion 13, Handling, s u rage, and shipping; and Criterion 14, Inspection, test, and operating status are not applicable to the CPRT program since these provisions of 10 CFR Part 50, Appendix B are applicable to activities which the CPRT is not responsible for and/or does not intend to perform.
j "That portion of Criterion 7 relating to control of purchased material and equipment is not applicable to the CPRT, since the CPRT does not intend to perform this activity.
04/18/86 4-2 CP SSER 13 SEC. 4
The staff has evaluated the CPRT QA program described in the CPRT Program Plan to determine the QA program's acceptability based on the above listed provisions of 10 CFR Part 50, Appendix B. The result of our evaluat, ion is discussed below.
o Criterion 1, Organization. We find the CPRT organization acceptable based on the following organization and responsibilities described in the CPRT Program Plan. The CPRT organization for QA is shown in Fig-ure 4.1 of this report. The CrRT responsibility for the quality of CPRT
, activities rests with the SRT which consists of the Vice President of TUGCO, the Vice President of International Technology Corporation (consult-
, ant), the Vice President of Management Analysis Company (consultant), the Manager of Nuclear Safety and Licensing, TERA Corporation (consultant),
the President of Nyer Incorporated (consultant), and Dr. John H. Buck, Consultant.
The SRT responsibilities are to:
develop and maintain the CPRT Program Plan
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establish standards for personnel qualification and obje::tivity select and assign Review Team Leaders (RTLs) who will repo:t to the SRT review and approve action plans and their revisions review and approve determinations of safety significance, root causes, and generic implications monitor the status of CPRT program implementation review and approve reports of action plan results review and approve collective significance evaluation reports receive the results of all audits of CPRT a:tivities 04/18/86 4-3 CP 55ER 13 SEC. 4
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receive corrective action response to audit findings perform, or have performed for them, audits to ,directly evaluate CPRT QA activities SRT fulfillment of these responsibilihprovides the management f gove view of the TRT-I;AP QA program. '.;;.1 .. .. . i . ..,/. . m. , o m @
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The Energy Nsearch Corpor% tion (ERC) under the direction *of the QA/QC RTL is responsible for managing and directing the implementation of the QOC. Reporting to this RTL is the Supervisor of Procedures and Project Assurance. The Supervisor of Procedures and Project Assurance also reports to the ERC Division Manager of Quality Assurance since this supervisor is the on site representative of the ERC Manager of Quality Assurance. The responsibilities of the Supervisor of Procedures and Project Assurance include the surveillance and audits of QOC activities
) and reporting the status of the QA program to the QA/QC Review Team Leader and the ERC Manager of Quality Assurance. The ERC Manager of Quality Assurance has the authority to issue corrective action requests or stop work orders for ERC activities should major problems arise.
TERA Corporation, under the direction of the DAP RTL, is responsible for managing and directing the implementation of the DAP. Reporting to ti.e DAPRTListheDAP-QAManager$hoisresponsiblefordevelopingtheQA program and ensuring its proper implementation throughout the DAP activities.
This responsibility include; the review and concurrence of procedures, purchase orders, and corrective actions and conducting audits of DAP activi-ties to verify proper implementation of the QA program.
04/18/86 4-4 CP SSER 13 SEC. 4
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- The organizations responsible for assuring that the CPRT QA program controls are effectively executed have the authority and organization freedom to identify quality problems and assure that, corrective actions i
are identified and properly carried out. The independence of these organizations from the pressure of cost and schedules is acceptable since they do not report to the line management directly responsible for the work. '
o Criterion 2, QA Program. We find the CPRT Program Plan meets the require-ments of this criterion by establishing a QA program for CPRT activities
. in accordance with the elements in Criterion 2. QA activities are re-quired to be carried out using documented, controlled procedures. Techni-cal and QA personnel involved in implementing and verifying, respectively, the CPRT program are required to be qualified in the areas of their assigned responsibilities and are to be trained as necessary on the provisions of the CPRT Program Plan. The SRT is required to regularly review the status and adequacy of the CPRT program through the review and approval of action plan rest:lts, the review of audit results identified by 7h internal audits and by outside agencies, and the review of corrective actions resulting from audit findings.
o Criterion 3, Design Control. We find the CPRT design controls acceptable based on the following measures described in the CPRT Program Plan.
Design verifications are required to be performed in accordance with written procedures by qualified, trained personnel other than those who performed the original design. The verification activities include the preparation of checklists and criteria lists, calculation review, input review, alternate calculations, and review of quality and QA requirements.
Further, design activities are required to be controlled in accordance with the design controls described in ANSI N45.2.11, "QA Requirements for the Design of Nuclear Power Plants," which is a consensus industry standard.
o Criterion 4, Procurement Document Control. We find the CPRT procure-ment document controls acceptable based on the following measures described in the CPRT Program Plan. Procurement documents for services 04/18/86 4-5 CP SSER 13 SEC. 4
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2 relating to CPRT activities are required to include appr;priate QA require-ments and to be reviewed by either the QA Manager responsible for QOC or DAP and by a CPRT RTL. .
.o Criterion 5, Instructions, Procedures, and Drawings. We find the CPRT use of. instructions, procedures, and drawings acceptable based on the following measures described in the CPRT. Program Plan. Procedures or checklists are required to be used in the performance of CPRT activities ,
such as inspections and record reviews. The CPRT Program Plan includes the format and procedures for preparing specific action plans and results
, reports. ' Acceptance criteria are included in the specific action plans.
In addition, implementing procedures and instructions have been estab-lished and are included or referenced in the CPRT Program I'lan.
-o Criterion 6, Docucent Control. We find the CPRT program for document control acceptable based on the following measures described in the CPRT Program Plan. Procedures to control the review, approval, and issue of documents are required. These procedures require that the SRT review and
.. ,l approve action plans and revision to action plans, corrective action recommended by RTLs, action plan result reports, and corrective evaluation reports. Personnel performing CPRT activities are required f.c use the latest revision of documents. Changes to CPRT documents are required to receive the same level of review as the originals.
o Criterion 7, Control of Purchased Services. We find the CPRT program for the control of purchased services acceptable based on the following measures described in the CPRT Program Plan. Procurement of services by DAP participants will require that the procured services be performed under the total requirements of the CPRT QA program. Procurement of services by QOC are required to be made only from organizations on ERC's Approved Source List. An ERC procedure requires that pre-award surveys be conducted and personnel qualifications be reviewed.
o Criterion 10, Inspection. We find the CPRT controls of the CPRT inspec-
- tions acceptable based on the following measures described in the CPRT 04/18/86 4-6 CP SSER 13 SEC. 4 1
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d Program Plan. The inspec; ion system is required to be defined by proced-ures and instructions. 4nspectors must be provided the necessary draw-ings, inspection inst:uctions, accept / reject criteri,a, checklists, and forms for document ~ng the inspection. An ERC procedure requires the use of calibrated inspection equipment supplied by the CPSES project.
Further, CPRT_ inspectors are required to be qualified in accordance with ANSI N45.2.6, " Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants," which is a
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consensus' industry tandard.
o Criterion 12, Control of Measuring and Test Equipment. Although the CPRT Program Plan does not specifically address the control of measuring and test equipment, discussions with Region IV personnel show that measur-ing and test equipment used by QOC personnel is under the control and calibration program of the CPSES QA Program. The CPRT Program Plan indicates that a procedure addresses requirements for using calibrated inspection equipment. Therefore, we find the CPRT control for measuring N
j and test equipment acceptable.
o Criterion 15, Nonconforming Materials, Parts, or Components. We find the controls for nonconformances acceptable based on the following measures described in the CPRT Program Plan. Nonconformances such as deviations and deficiencies that are identified during the conduct of CPRT activities are required to be documented, evaluated, classified, and trended by the CPRT.
i o Criterion 16, Corrective Action. We find the CPRT controls for corrective action acceptable based on the following measures described in the CPRT Program Plan. The CPSES Project is responsible for evaluating, determin-ing, and implementing the corrective action of nonconformances identified by the CPRT and for performing the 10 CFR Part 50.55(e) reportability studies. All actions for which the CPSES Project is responsible are carried out under the CPSES QA Program.
04/18/86 4-7 CP SSER 13 SEC. 4
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s The CPRT may recommend proposed corrective actions to the CPSES Project with approval by the'SRT. The CPRT RTL's are responsible for determining the adequacy of the corrective actions defined by the CPSES Project. The-CPRT must satisfy itself that the CPSES Project's correcthe actions will correct the specific nonconforming conditions identified by_the CPRT and, if applicable, will preclude the recurrence of similar nonconforming conditions in the future. The CPRT RTLs are required to perform documented confirmatory overviews of the implementation of selected corrective actions.
o Criterion 17, QA Records. We find the CPRT controls-for QA records acceptable based on the following measures described in the CPRT Program Plan. QA records such as action plan working files, results of analyses, SRT meeting minutes, result reports, and personnel qualifications gener-ated as a result of the CPRT Program Plan are required to be maintained at the CPRT central file by the CPRT Program Director.
o Criterion 18, Audits. We find the CPRT controls for audits of QOC and DAP D activities acceptable based on the following measures described in the CPRT Program Plan. Audits are required to be performed to verify compliance with the implementation of the CPRT's QOC and DAP. Personnel performing the audits must be qualified and must not have direct responsibilities in the areas being audited. Checklists are required to be used in conducting the audits, and audit results must be & cumented and reported to the management having responsibility for the audited areas. Followup reviews are required to be made to assure the proper close-out of identified open items. The Overview Quality Team will support the SRT by reviewing the results and corrective actions associated with audits performed under the DAP and QOC s/
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, , QA program and those performed by NRC.4 ' '---" dx-owni.ed audit Mregre., Athe TRT-ISAP program provides an overview of activities and docu-ments through (1) checks of activities by the RTLs to ensure that action plans within their areas of responsibility are being properly implemented, (2) review, verification, and approval of the results of implementing the ISAPs by the CPRT Results Report and File Review Committee, and (3) review and approval of Result Reports by the SRT. & ' 4d this ::rvicu cf the M -
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TRT-ISAP program lacks the ailed audit approa scope, schedule, rective action) norma found in QA progr . In this regard e staff
[ requires that a udit program be est ished and implem ed by the SRT for the TRT- AP program or just~ cation should b rovided for not doing so. T . staff will review s matter period
- ly during the implemen-ion phase of the program.
The CPRT Program Plan does not specifically address that portion of Criterion 7
, relating to control of purchased equipment and material; nor does it specifically address Criterion 8, Identification and control of material, parts, and compo-
. nents; Criterion 9, Control of special processes; Criterion 11, Test control; Criterion 12, Control of measuring and test equipment; Criterion 13, Handling, storage, and shipping; and Criterion 14, Inspection, test, and operating status.
This is acceptable to the staff, with the exception of Criterion 12, since these provisions are not applicable to CPRT activities. However, if activities which normally come under the control of these provisions are initiated by the CPRT, there is a commitment in the CPRT Program Plan that these provisions will be incorporated as appropriate. The NRC staff will review and inspect these activi-ties if initiated during the implementation phase of the CPRT Program. Q0C -
control of measuing and test equipment is discussed under Criterion 12, page 4-7.
4.3 Conclusion The CPRT QA program associated with implementing the CPRT Program Plan describes adequate QA controls and QA organizational responsibilities. The organizations and persons performing QA functions have sufficient defined responsibilities and authority to carry out the elements of the QA program.
l The QA program describes requirements, procedures, and controls that, when properly implemented, meet the appropriate provisions of Appendix B to 10 CFR Part 50, cxcept ::-ceted 2cve in the ree of cuditing cf thc TRT ISAF p.ugrc .
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