ML20203L245

Assessment Rept of Engineering & Technical Work Process Utilized at De&S Bolton Ofc

ML20203L245
Person / Time
Site:	Yankee Rowe
Issue date:	02/23/1998
From:	Stringer J DUKE ENGINEERING & SERVICES
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ML20203L159	List: ML20203L155 ML20203L162 ML20203L193 ML20203L227 ML20203L245 ML20203L269
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l Assessment Report of Engineering and Technical Work Processes Utilized at DE&S' Bolton Office yr 2./t3!W

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e L. 5tringer, Team Leader 'Dite'

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l Assessment Report of Engineering and Technical Work Processes Utilized at DE&S' Bolton Office I

Table of Contents IA Introduction 2.0 Purpose 3A Scope 4.0 Results 5.0 Conclusions

. Appendices A. Review Team Membership B. Information Sources C. Completed Criteria and Review Approach Document (CRAD) Worksheets

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Assessment Report l

of Engineering and Teclutical Work Processes Utilized at DE&S' Bolton Office 1.0 Introduction This repon provides the results of an assessment conducted Feb. 2 6,1998 of the engineering and technical work processes utilized at the DE&S' Bolton office. The overall objective was to confirm the adequacy of management, work practices, work products and qualification of personnel performing work.

The assessment was performed by a DE&S team independent of the line organization at the Bolton location. The review team consisted of the Team Leader, a Quality Assurance (QA) expert, and three technical specialists, including an engineering manager consultant. The review team member assignments were made consistent with each member's area of expertise and experience. Team members and their areas of expenise are summarized in Appendix A.

An assessment plan, which was d veloped in accordance with the review team Charter, was approved Jan 30,1998 and used as the base document for the assessment. Criteria and review approach document worksheets were utilized to systematically conduct and document results of the assessment of selected work processes and associated focus areas. These worksheets provided overall and specific acceptance criteria for each topical area reviewed based on the performance issues stated in the review team charter.

Specific acceptance criteria were utilized as a means for determining if the overall acceptance criteria had been met.

2.0 Purpose DE&S' management initiative was to assess the adequacy of engineering and technical work processes, deliverables, and the competence of the personnel associated with these activities. In addition, the assessment evaluated compliance with accepted industry practices and regulatory requirements.

3.0 Scope This assessment targetr.d engineering and technical support activities other than the loss of coolant accident (LOCA) analysis work which has been completed in the past three years. The review team used a combination of engineering and technical document reviews and personnel interviews to obtain information for the evaluation. After reviewing the current organization at the Bolton office the team identified several organizations to focus evaluations based on the work performed in each area, the time

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l available for the assessment and the focus of the evaluation (compliance with NRC requirements and safety related work). Organizations included:

• Nuclear and Fuel Services

• Decommissioning

• Automation Technology

• Environmental Heahh and Safety

• Quality Assurance Work processes were assessed with a focus on performance of calculations, analyses, and computer code validations. Work processes included:

• Design and Design Changes

• Design Document Control

• Organization and People Deployment

• Training

• Performance hianagement 4.0 Results The review team identified change over the past several years to be pervasive and as a result set the context for much of its interaction with perwnnel and review of work practices. The former Yankee Atomic Electric Company (YAEC) organization matured with well defined, comprehensive responsibilities for the plants in its family. This organization maintained a strong project management function, performed the design engineering necessary to support the operation of these units, performed the licensing with the NRC and, at one time, held the operating licenses for these units. The interface with the clients was well understood and handled efficiently by the project management organization.

Costs were addressed satisfactorily in the budgeting process. Work was performed in accordance with the YAEC procedures, and this organization was clearly responsible for its work and for maintenance of the design basis. In the execution of these responsibilities, the YAEC organization developed strong talents, a rich base of experience, and a culture of pride and ownership ofits work, all of which remain evident today.

The curient work environment, even before the acquisition by DE&S, is much different. In the case of the Yankee Rowe plant, the Bolton office still has relatively well defined responsibilities, including use of its own procedures with clear rmonsibility for approval of work products. However, in the case of hiaine Yankee, the organization functions in an engineering support role, hiaine Yankee defines the scope of the work, sets the schedule, approves the work, and is responsible for the interface of new work to the existing design and maintenance of the design basis. Work for other clients generally falls between the two extremes of Yankee Rowe and hiaine Yankee.

As a result of these changes, work within the Bolton office is initiated by different methods, done to different procedures, subject to different QA requirements, and performed to different levels of responsibility for the work, all depending on the client. The pressure of scheduling was a common theme in our review throughout the organization. In the absence of the former project management organization, current methods of addressing schedule concerns both internally and externally are

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immature. However, the commitment to work product quality in the face of schedule pressure was also a common theme.

The resiew team interviewed 32 managers and engineers, and reviewed approximately 60 documents, such as procedures, calculations, analyses, technical repons, drawings, memorandums, training records and audits. The list ofindividual sources ofinformation is provided in Appendix B. Based on the assessment, the review team concluded that the acceptance criteria were satisfactorily met. Appendix C contains document worksheets that address the .%11cwing assessment topics:

Topic #1 Engineering Process and Adherence to Applicable Procedures, and Industry and NRC Requirements

• Topic #2 - Design Controls, including Engineering Documentation and Quality of Work Products

• Topic #3 - Management Control of Safety-Related Activities Topic #4 - Design Engineering Training; Particularly, QA Program Training Topic #5 - Management Control of Safety-Related Activities; Adherence to Applicable Procedures, and Industry and NRC Requirements; and Quality of Work Products These document worksheets provide results of the assessment against specific review criteria and a conclusion at the end of each worksheet. Following is an overview of each organization evaluated, and conclusions and observations for each.

Nuclear and Fuel Senices:

Fuel Mr.nagement Services responsibilities include fuel materials procurement, fuel management analyses, and other related activities which are primarily commercial. This group has a focused work scope which has remained relatively unchanged during a period of other significant changes for the Bolton office. In general, the work of this organization is not safety-related, although it has an important oversight role.

Any safety related calculations or analyses are performed in accordance with WE-103. A Procedure and Guideline Manual provides an a'dministrative framework for a number ofits activities. As an example, it provides s. ystematic process for conducting and documenting the review of core component design changes. Work scope and work processes are well-defined and followed based on review of documentation. Engineering work products were found to be intact.

Nuclear Engineering responsibilities include reactor physics, core reload design, thermal hydraulics analysis, probability risk assessment and rdiability ant. lyses, fluid systems engineering and special projects. Approximately 80 percent of the work is safety-related, and WE-103 and WE 108 are the principal procedures applicable to their work. However, in response to previous audits, they have developed supplementary procedures to assist personnel in application of these WE procedures. As with other groups in the Bolton office, loss of the former process in which the project manager controlled work coming in has resuhed in several methods for work initiation, including formal service requests, work orders, contracts, verbal requests and initiative for routine budgeted work.

The primary concern of the group is the schedule pressure associated with their work. Several techniques are employed to address control of in house work and schedule concerns. They are negotLting with the plants to prioritize projsets. They meet with the clients once a month to ensure control of work, and quarterly meetings are held with the plant reactor engineers mostly on core reload woik. Aa internal mumm m F-5

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t L immature. However, the commitment to work product quality in the face of schedule pressure was also a common theme.

The review tean bterviewed 32 managers and engineers, and reviewed approximately 60 documents, such as procedure. calculations, analyses, technical reports, drawings, memorandums, training records and audits. The list ofindividual sources ofinformation is provided in Appendix B. Based on the assessment, the review team concluded that the acceptance criteria were satisfactorily met. Appendix C contains doeurnent worksheets that address the following assessment topics:

• Topic #1 - Engineering Process and Adherence to Applicable Procedures, and Industry and NRC Requirements

• Topic #2 - besign Controls, including Engineering Documentation and Quality of Work Products

• Topic #3 - h:anageraent Control of Safety Related Activities

• Topic #4 - Design Engineering Training: Particularly, QA Program Training

• Tcpic #5 - Management Control of Safety-Related Activities; Adherence to Applicable Procedures, and Industry and NRC Requirements; and Quality of Work Products These document worksheets provide results of the assessment against specine review criteria and a conclusion at the end of each worksheet. Following is an overview of each organization evaluated, and conclusions and observations for each.

Nuclear and Fuel SenIces:

Fuel Management Services responsibilities include fuel materials proct rement, fuel management analyses, and other related activities which are primarily commercial. This group has a focused work scope which has remained relatively unchanged during a period of other significant changes for the Bolton office in general, the work of this organization is not safety-related, although it has an important oversight role. '

Any safety related calculations or analyses are performed in accordance with WE-103. A Procedure and Guidelines Manual provides an a'dministrative framework for a number ofits activities. As an example, it provides a systematic process for conducting and documenting the review of core component design changes. Work scope and work processes are well-defined and followed based on review of documentation. Engineering work products were found to be intact.

Nuclear Engineering responsibilities include reactor physics, core reload design, thermal hydraulics

. analysis, probability risk assessment and reliability analyses, fluid systems engineering and special projects. Approximately 80 percent of the work is safety-related, and WE-103 and WE 108 are the principal procedures applicable to their work. However, in response to previous audits, they have developed supplementary procedures to assist personnelin application of these WE procedures. As with other groups in the Bolton office, loss of the former process in which the project manager controlled work coming in has resulted in several methods for work initiation, including formal service requests, work orders, contracts, verbal requests and initiative for routine budgeted work.

The primary concern of the group is the schedule pressure associated with thir work. Several techniques are employed to address control of in house work and schedule concerns. They are negotiating with the

_ plants to prioritize projects. They meet with the clients once a month to ensure control of work, and '

m quarterly meetings are held with the plant reactor engineers mostly on core reload work. An internal smtmoa F5

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tracking system is used for all work and is renewed weekly. Work is planned so that reviewers, indepenoent verifbra and approvers are available to meet schedules. Memorandums are used to formally transnut information to the client. Scoping meetings are held with the client to define product and determine how the product will be used. Based on review of documentation overall in the Nuclear Engineering Department, safety related work is performed in accordance with appropriate procedures, and industry and regulatory requirements.

Decommissioning:

l Within the decommissioning organization there is one main engineering support aroup, Decommissioning Engineering & Services led by Jane Grant. This group was the focus of the assessment for the Decommissioning Department. Generally, the Decommissioning Engineering & Services Group provides engineering and licensing services for decommissiomng of Yankee Rovre, Connecticut Yankee and Maine  ;

Yankee. Other projects are ongoing, but the focus of work at this time is the three listed plants / projects.

The responsibilities from a management and project controls standpoint vary for each project.

Based on its past relationship with the Yankee Rowe plara, the DE&S Bolton group generally serves as the lead organization for engineering support work and project management. Working togcher with plant management, verk tasks are identified and agreed upon by both parties. A Decommissioning Services Agreement between Yankee Atomic and DE&S provides contrr.:t terms and responsibilities for all work.

A comprehensive procedure, AP-0103, provides details for completion of Decommissioning Work Packages (DWPs) and all associated tasks. The procedure covers the steps for initiating and completing work. Overall, work is defined in a service request and task description. A complete listing of current and completed tasks was provided for information.

For Connecticut Yankee, primary project responsibility is at the plant and tasks are completed utilizing a service request process, much like Yankee Rowe. Generally, work can be described as engineering support since most tasks are very specific in nature, compared to complete project responsibility at Yankee Rowe. Tasks are completed within a defined engineering support organization within the Decommissioning Enginering and Services group. Service requests are completed and signed initiating specific tasks. The service request also indicates if QA is needed. If so, then a Task QA Plan is completed, providing specinc QA procedures and processes. Completion of work activities is clearly

, -documented in memos to the client, Connecticut Yankee Atomic Power Company.

The work at Maine Yankee can be generally described as providing engineering support. Tasks such as WO# 00082.00.0009.01.00000 re described as Providing General Engineering for Deconunissioning.

, The overall project respons:Sility is in a project organizetion lead by Em:.gy. We received a project organization dated Jan 20,1998, which shows Bob Fraser of Entergy as the Director of Engineering.

Work is performed within and under the direction of tne project organization. This relationship and DE&S current work scope were clearly explained by Bruce Holmgren, Manager of Decommissioning Enginee. :ng, and Bill Henries, Project Engineer for the SNF Island DWP and lead mechamcal engineer for Maine Yankee.

l.: -vork activities for the three projects focus on tasks associated with decommissioning the various systems, structures and components at the plants. Examples of ongoing engineering and design activities include design of the spent fuel poolisland at Maine Yankee and various compon:nt removal activities at wwow.ms F-6

Connecticut Yankee. Review of specific work packages and interviews indicated personnel understood the scope of work, what QA procedures apply and had a clear technical understanding of the work in the mechanical / structural, electrical /l&E and systems engineering disciplines.

In reviewing work scope, schedules and deliverables with variNs personnel, it became clear that there are multiple clients and needs. The available resources do not adequately meet the project needs, leading to challenges in maintaining quality. Personnel interviewed clearly understood the need for ma:ntaining quality. In one instance, based on client insistence for completion of a deliverable or schedule, signincant open items were identified within the document. When asked how the open items would be cleared, personnel explained a reasonable solution in accordance wi'h existing procedures. Resource allocatica among multiple clients seems to be creating some unnecessary challenges. Work products are sound and are being performed in accordance with appropriate procedures, and industry and regulatory requirements.

Automation Technoloev:

The Automation Technology Department provides support to the engineering groups on software development and revision, administers the software library, performs computer runs to test software, and prosides electronic data management and computational services. Veri 0 cation and validation are performed for each code, each revision and each platform. Work is performed under Procedure WE-108 when safety-related work is involved. A review of untrolled computer codes was provided and based on selective review it appears all applicable procedures are followed.

Envimnmental Health and Safetv:

The Enviro,miental Health and Safety Department is responsible for radiation protection and health pl.; sics services at the site, environmental / radiological laboratory services, radiological engineering and environmental services. This review focused on the two latter organizations since their activities primarily involve the performance of design calculations and analyses. The Radiological Engineering Group performs radiological analysis in support of plant Final Safety Analysis Report (FSAR) maintenance, radiological and non-radiological assessments, meteorological dispersion analysis and radiation shielding analysis. The Environmental Services Group provides analysis in support of the Individual Plant Evaluations (IPE) extreme events analysis, Goods, airline crashes and seismic events and potential consequences. They also provide non-radiological environmental services in support of permits and hazardous waste disposal. The coordination and business processes used to deal with budget and schedule type issues with the client have changed. In the past, these groups interfaced with the Projects Group at the Bolton ofnce who in turn would interface with the client. Now this has changed and interfacing with the client is somewhat unclear. However, the technical interfaces with counterparts at the client locations have not changed. Work is initiated through multiple methods such as service requests, verbal requests that are followed up with service requests, and routine work. Results of their work are normally transmitted formally via memorandum. A signincant number of analyses performed use computer codes. These are originated and maintained in conformance with the WE-10S QA procedure.

Based on selected reviews of documentation and interviews with department personnel, work was found to be sound and in accordance with applicable procedures.

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Ouality Assurance:

The QA organization provides QA program requirements for the DE&S' Bolton office. They ensure QA requirements are integrated into work procedures and appropriately followed based on the conduct of audits. The role of QA in procedures and audits both within DE&S' Bohon office and with the sponsor plants,i.e., Maine Yankee, Vermont Yankee, Yankee Rowe, and Northeast Utilities (Millestone, l

Connecticut Yankee, and Seabrock) appears to be evolving. The QA function is currently transitioning to DE&S' QA Manual which is governed by NQA 1,1989 versus the Yankee QA program which is governed by ASME N45.2.11,1974. Some work is performed to the Bolton office procedures, others are performed by the procedures of the chent. The mechanism by which QA requirements are defined for work tasks is handled differently depending on the client. Many of the Yankee sponsor plant procedures refer to the Bolton of0cc procedure set. Interviews with QA personnel and review of QA documentation demonstrate that the QA department effectively supports the Bolton office in achieving its goals.

5.0 Conclusions The overall conclusions of the review team are :

• Procedures are effectiu and correctly implemented.

Pecole t.re appropriately trained, qualified and knowledgeable.

• Management control of safety-related activities is evident.

Engineering and technical work products are sound and in accordance with industry and regulatory requirements.

In addition, the : view team identified a number of strengths. They are as follows:

A strong culture exists that is conscious of safety and quality requirements, demonstrating clear evidence of pride and ownership of work.

Personnel have in-depth technical knowledge.

Client interface is strong and close.

Initiatives are ongoing to improve the engineering work control process.

Three areas for potentialimprovements were identified:

A. DE&S Trnreition Plan The review team discovered that a plan had not been finalized for transitioning from the Yankee organization to an approach that utilizes the best practices of Yankee and DE&S. Several activities were on hold awaiting issuance of the Transition Plan (e.g. enhanced training and self-assessments, as identified in Condition Reports). In addition, the plan needs to address existing contracts with clients and integration of QA program requirements, clear understanding of organizational and functional responsibilities, and administrative procedures and processes. The review tea n acknowledges that ar. effort is underway to develop and implement a transition plan which should address these issues.

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B. Work Proceues i-A number of work process-related opportunities for improvement were identined during the assessment, it was found that different processes are used to initiate work and that the vehicle by l which QA requirements are denned for work tasks is handled differently. It was also discovered l that different levels ofinvolvemnt in development of task schedules exist and that different methods for tracking work and progress are used. Unreasonable requests for resources were also perceived to have some impact on work process performance, it is recommended that the implementation of the project controls methodology be included in the Transition Plan.

C. Roles and Resnonsibilities Severalissues were found to exist involving manager and engineer roles and responsibilities.

Roles an1 responsibilities are evolving and are currently different for each project / plant. 4 Configuration management methodology is not clearly documented. It was not evident that there was a good understanding of roles and responsibilities at alllevels of the organization. This appears to be a result of change and the organization's desire to comply with client demands.

6.0 Appendices A. Review Team Membership B. Infonnation Sources C. Completed Criteria and Review Approach Document (CRAD) Worksheets

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APPENDIX A Assessment Report of Engineering and Technical Work Processes Utilized at DE&S' Bolton Office Review Team

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'embership i

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Review Team Membership Name Company Areas of Expertise Team leader Joe Stringer DE&S - Charlotte Office

• Nuclear and hydro facility system design and startup Equipment procurement

• Project management Engineering assessments Radioactive waste management design and licensing ,

Team Membe s Robert Bonisolli DE&S - Boihn nffice

• QA program and procedures Internal and external audits / assessments a

QC inspections Training Vendor qualification Tom Wyke Engineering Manager

• Nuclear facility and systems design and Consultant startup Nuclear engineering and licensing support

• Civil, environmental and electrical design Nuclear relations with external organizations (e.g. NRC, INPO, WANO, EPRI, etc.)

Bob Eble DE&S - Vienna Office

• Nuclear facility design Nuclear analysis QA procedures NRC licensing criteria Bob Futrell DE&S - Charlotte Office

• Process reengineering Nuclear safety & event analysis Safety review and assessment QA audits Radiation protection Operational readiness reviews and i assessments wemw ms F-11

APPENDIX B Assessment Report of Engineering and Technical Work Processes Utilized at DE&S' Bolton Office Information Sources

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i APPENDIX B Perman Intenlewed/Denarinwnt:

I. Stephen Schultz / Nuclear and Fuel Services

2. - James Chapman / Nuclear Engineering

,n 3.; Michael Kennedy / Safety Assessment i

4. . Paul Bergeron/ Thermal Hydraulics & Safety

5. Fred Carpenito/ Thermal Hydraulics & Safety

6. Dick Cacciapouti/ Reactor Physics

.7. Rudolph Grube/ Fuel Management

8. John Rivera/ Core Components

9. Francis Quinn/ Fuel Procurement, Managemer.t & Economic Analysis

10. Jane Grant / Decommissioning Engineering & Services I1. Bruce Holmgren/ Decommissioning Engineering

12. Don LeFrancois/ Mechanical & Electrical Decommissioning Engineering

13. Bill Henries / Mechanical Engineering Decommissioning Engineering -

14. John Bonner/ Electrical /I&C Decommissioning Engineering

15. Joe McCumber/ Decommissioning Support Services

16. Peter Guglielmino/Vice President Northeast Region

17. Andy Roudenko/ Automation Technology

18. Gary McCormick/ Automation Technology

19. Rocky Marcello/ Environmental Health & Safety

20. Pete Littlefield/ Radiological Engineering ,

21.

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Tom Thomas / Radiological Engineering

22. John DiStefano/ Radiological Engineering

23. Andrew Hodgdon/ Radiological Engineering

24. Jaxe Jacobson/ Environmental Services

25. George Harper / Environmental Services

26. Frank Sabadini/ Quality Assurance

27. Cam DiNunzio/ Quality Assurance

28. Kathy Bocon/ Human Resources, Training smemw. F-13 I "

APPENDIX B t

29. Jackie Copeland/ Records Management Services

30. John Gallo/ Automation Technology

31. Dean Huggins/ Records Mannement Services

32. Robin Riel / Records Management Services Documents Reviewed:

1. Nuctor and Fuel Services Organizational Chart

2. Decommissioning Organizativ.ial Chart

3. Automation Organizational Chart

4. Environmental Health & Safety Organization Chart

5. QA Organizational Chart

6. Procedure WE-103, Engineet.ng Calculations and Analysis

7. Procedure WE-108, Computer Codes

8. Procedure WE-100, Design Change Request

9. SBC-794, Cycle 6A Loss of Flow Accident Analysis, dated 5/17/97

10. Memorandum, SB Cycle 6 Core Reload Safety Evaluation (Rev 2), dated 10/16/97

11. SB Cycle 6 Core Reload Safety Evaluat!on, dated 10/14/97

12. SBC-819. Cycle 6 Nuclear Design Report, dated 6/13/97

13. SBC-804, Revised Probable Maximum Hurricane (PMH) Flood Levels

14. VYC-1745,IPEEE Roof Snow Levels

15. Memorandum, MYC-1996 Maine Yankee Post Plant Shutdown Offsite and Control Room Doses for a Fuel Handling Acc!Jent dated 9/30/97

16. YC-386, Consequence Evaluation of Vermont Yankee Class 1 Piping in Support of ASME Code Case N-560, dated 1/26/98

17. MYC-1995, Maine Yankee Post Plant Shutdown Maximum Fuel Assembly Radionuclide Inventories dated 9/12/95

18. 97-ENG 01920-C2, Sizing of MP2 Roof Scuppers

19. VY-1627, Diesel Generator Rooms Tornado Venting Analyses, dated 3/7/97

20. Memorandum, ESG50/91, SBP 91-0682

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i APPENDIX B l 21. Procedures YA ATD-001,002, and 003, Customer Support for Software Procedure Development

22. SBC-835, Spent Fuel Thermal Hydraulic Analysis, dated 12n/97

23. SBC-714, Cycle 5 Nuclear Design Report, dated 11/22/95

24. SBC-718, Cycle 5 RPC Underfrequency LOFA Analysis

25. Procedure NU 3, Work Process

26. NU-i l. Task Initiation & Organization

27. W.O. #3010, Structural Evaluation of the Yard Crane & Fuel Building

28. CYC-003, Yard Crane & Fuel Building- Amplified Response Strectra, dated 12/16/97

29. DCP Np. 97-42, Spent Fuel Pool isolation, dated 12/17/97

30. LPC1/RHR System Notebook NonQ Memorandums, System Descriptions, Event Trees Consequence Analysis 31, Memorandum, S AVY95 020, Review of Diesel Generator CCO Maintenance Plan - No QA Designation, dated 8/25/95

32. SAV'.96-010, Methods for Setting Reliability Performance Criteria for Maintenance Rule, dated 4 4/30/96

33. Memorandum, S AVY95-015. Risk Importance VY Systems, dated 6/29/95

34. VY-386, Rev 1, Consequence Evaluation of VY Classification, Piping in Support of ASME Code Case N-560

35. Procedure RMS-12, Records Retrieval Indexing / Data Entry ,

36. QA DYA, Version 3.0/PC Computer Code Modification and Procedure WE-108 Documentation Package - YC-303, Rev 1, dated 4/5/95

37. Computer Code QADUE Migration to IBM PC & Procedure WE-108 Validation, YC-180, dated 6/10/91

38. YRC-1026, Radic ogical Consequences of a Loss of Shielding Water in the STC

39. Vessel Plasma Cutting Operations Dose Rate to the EAB, Yankee Rowe

40. Memorandum, YAEC Fuel Quality Verification Plan for Vermont Yankee Reload 19. dated i10/97

41. Fuel Fabrication Technical Assessment Program for Vermont Yankee Cycle 20/ Reload 19. dated 10/97

42. Specification for Nuclear Fuel Assemblies for Maine Yankee Atomic Power Co., dated 2/92

43. Fuel Management Department Procedure and Guideline Manual sumo m F-15

APPENDIX B

44. hiechanical Design Review (hidr) (formerly Engineering Design Review (EDR)) Log,1996 to Present

45. hiechanical Design Notice (hiDN) (formerly Engineering Design Notice (EDN)) Log,1990 to Present

46. YRC-1062, Reactor Pressure Vessel Shipping Cask

47. YRC-Il40, Verification of Stardyne 4.4 for RPV Transportation Calculations

48. WE-008, Standard hiemorandum

49. Engineering Instruction No. WE-003, " Indoctrination of Personnel", Re. vision 13 dated 6/27/97

50. Engineering Instruction No. WE-004, " Training", Revision 12 dated 6/27/97

51. Fuel hianagement Department Personnel Training Records

52. Appendix R Root Cause Analysis Task Force for Vermont Yankee Report dated September 22, 1995

53. Audit Report No. NSD-96-02 dated December 16,1996 Functional Area Audited: Vermont Yankee Design Engineering

54. Audit Report No. VY-96-25 dated June 17,1996 Functional Area Audited: Environmental Qualification (EQ)

55. NRC Integrated Inspection Report 50-271/96-06 dated August 8,1996, Facility: Vermont Yankee Nue' Power Station

56. Technical Services Agreement Between hiaine Yankee and DE&S,1/2/97

57. Decommissioning Engineering and Services Department Procedure Number 11, Task Initiation and Crganization

58. YAEC Records Retrieval Indexing / Data Entry, Records hianagement Services Procedure RhtS-12

59. Decommissioning Work Packages, Procedure No. AP-0103

60. Decommissioning Ser ices Agreement Between YAEC and DE&S,12/1/97

61. YAEC Technical Administrative Guideline, No., Revision 5, Group Charters sumoomr.s F-16

APPENDIX C Assessment Report of Engineering and Technical 1 York Processes Utilized at DE&S' Bolton Office j

Completed Criteria and Review Approach Document (CRAD) Worksheets smemunr4 F-17 1

Engineering Proces%ssissmeritutlDE&S' EstionVMeeN Criteria and Review Approach Document Worksheet Assessment Topic No.1: Engineering Process and Adherence to Applicable Procedures, and Industry and NRC Requirements Business Process Name: Design Systems, Structures, and Components Sub-Process Focus: Develop Conceptual Design Develop Preliminary Desigr Develop Final Design Control SSC's Design / Design Basis Changes Overall Acceptance Criteria:

Engineering analysis and design processes / activities / products and changes thereto are in accordance with engineering procedures, accepted industry practices, and NRC requirements.

A. Specific Acceptance Criteria:

1. Project task respor:sibilities are adequately identified.

2. The design products are developed and documented in accordance with procedures.

3. The acceptance criteria are incorporated in the design dccuments sufficient to allow verification that design requirements have been satisfactorily accomplished.

4. Design requirements are clearly stated.

-5. The design product has been adequately verified and

6. Inputs are correctly selected and iner.rporated into the design.

7. Assumptions are identified and irdioted as requiring verification (if needed) when the detailed design activities are completed.

8. Applicable codes, standards and regulatory requirements, including issue and addenda, are properly identified; and requirements for design art. met.

9. Past experience with similar designs has been considered.

10. Applicable construction and operating experience are considered.

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I1. Impact on othar design disciplines has been considered.

12. SSC Design interface requirements have been satisfied.

13. Provisions are in place for developing new and revising existing computer models in compliance with regulations

14. An appropriate design method is used.

15. Computer programs are properly used (capabilities, modeling, techniques, program verification).

16. Output is reasonable compared to the inputs.

17. Specified parts, equipment, and processes are suitable for the required application.

18. Specified materials are compatible with each other and the design environmental conditions to which the material will be exposed.

19. Accessibility and other design provisions and features are specified and adequate fn Miformance of needed ma'ntenance and repair, including Inservice Inspection (ISI).

20. The design has properly considered radiation exposure to the public and plant personnel in accordance witt ALARA goals and objectives.

21. Adequate pre-operational and subsequent periodic test requirements are appropriately specified.

22. Specifications and other procurement documents adequately specify handling, storage, cleaning and shipping requirements, f

23. SSC Identification requirements are adequately specified.

24. Problems or deficiencies that affect work performed in other divisions or sections are considered.

25. A process for initiating . nd developing design and design basis changes is established, including provisions for reviewing and updating design products.

26. The design product meets design requireinents.

27. Revised engineering products have been reviewed and approved by the same organization which reviewed and approved the original documentation.

4 28. The reason (s) for the revision are clearly and completely stated.

29. All document revisions comply with the same criteria as the ociginal.

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30. The design package is complete.

31. The design products are correct.

32. Sufficient review criteria exists and is properly used.

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33. Controls are adequate at various design stages.

B. Review Approach:

1. Interview managers responsible for engineering and technical work

2. Interview personnel responsible for producing calculations, analyses and other enginecting and technical work products

3. Review pertinent engineering work processes and procedures 3

4. Review randomly selected engineering and technical work products C. Results:

The engineering process and adherence to applicable procedures and industry and NRC requirements were found acceptable. Discussion with a number of managers and engineers, review of procedures. and review of a number of engineering work products were performed to substantiate this result. These reviews confirmed that, for example, design requirements, inputs, assumptions, and code and standard tequirements were incorporated in analyses; that appropriate design methods were used; that computer software is properly verified and controlled; and that revisions are properly reviewed and approved.

Where appropriate, supplementary work place procedures were developed to assist personnel in implementation of mandatory procedures. Responsibilities were generally well understood.

D.

Conclusions:

Procedures were found to be effective and cor,ctly implemented. Engineering and technical work products were also determined to be sound, defensible and in accordance with industry and regulatory requirements. There was clear evidence of a strong culture that is conscious of safety and quality requirements. Pride and ownership of work were also demonstrated. Several ongoing initiatives are targeted on improvement in engineering work processes.

A plan for transitioning from the Yankee organization, work processes and procedures to that of DE&S was not found ready and available for implementation. This has created some deferrals of work, uncertainties in how work will be contracted, and how QA program requirements will be integrated.

. mmmu.. r.s F-20 CRI-Design

3i.

Engincedas(Psnoess AssessmentstDE&S';BottdWOHice A8CEllM9WIREl!ElB' The existence of different methods for initiating work and defining QA requirements for work tasks appears to present unnecessary challenges to meeting client expectations. Likewise, different levels of involveirr:nt in development of task schedules and in methods for tracking work and progress result in additional unwarranted challenges. There is some indication that unreasonable requests for resources have also had an impact on work process performance.

Specific objective evidence in support of the conclusions include:

1. DE&S Bolton organization chart

2. Technical Services Agreement between Maine Yankee and DE&S dated 1/2/97

3. Decommissioning Work Package Procedure No. AP-0103

4. Decommissioning Services Agreement between YAEC and DE&S dated 12/1/97

5. Nuclear 'ingineering Department Procedures 1-8

6. Yankee Atomic Teci.nical Administrative Guideline No.10, Group Charters smmmms F-21 cai.oesign

Criteria and Review Approach Document Worksheet ,

ammme - m e a Assessment Topic No. 2: Design Controls, Including Engineering Documentation and Quality of Work Products Business Process Name: Design Systems, Structures, and Components Sub-Process Focus: Control Design Products Overall Acceptance Criteria: >-

Design document controls are applied to work products in accordance with design procedures and QA requirements, including engineering documentation.

A. Specific Acceptance Criteria:

1. Process describes how design documents are controlled in the work place, including documentation of design changes.

2. Requirements for record preparation, review, approval, distribution, retention, etc., are adequately specified.

3. The design product has been entered into the document control system.

4. The design package is complete.

5. The design products are accessible and being used.

B. Review Approach:

1. Review pertinent engineering work processes and procedures.

2. Review randomly selected engineering and technical work products.

C. Results:

Overall, internal work proc edures are thorough, mature and contain appropriate industry and regulatory requirements providing good design control methods. Engineering work products have been prepared in accordance with these precedures and are technically correct and judged to be of high quality. Work smtnoswim m F-22 CR2 DesignControls

packages reviewed were complete including acceptance criteria. A standard memorandum is typically used to transmit engineering work products which summarizes the scope, inputs, results and potential impacts of the deliverable. Some confusion was observed regarding control of engineering work products. This appears to be partially due to the multiple changes in organization, responsibilities and method ofinterface with the client. A documentation control process was evident which ensures that when work products such as drawings, calculations and analyses are revised, owners of affected documents are notified to enable them to determine any impact and need for appropriate revisions.

f D.

Conclusions:

Documents are accurate, complete and in accordance with procedures. Procedures adequately describe requirements for review, verification, approval, distribution and records including software development, verification and application. The process for controlling new and revised engineering documents is adequate.

The process used for transmitting engineering work products is an effective tool for formally transmitting the deliverable to the client.

Specific objective evidence in support of the conclusions include:

1. Yankee Atomic Electric Company Operational (YAEC) QA hianual, YOQAP-t-A, Revision 27

2. Decommissioning Engineering and Services Department Procedure No I1

3. YAEC Records Retrieval Indexing / Data Entry, Records hianagement Services ,

, Procedure RhtS-12

4. Review of hiaine Yankee design package for spent fuel pool island

5. Review of numerous analyses such as YRC-1026, YRC-1062 and validation of QADUE which provide clear requirements, proper analysis and compliance with applicable procedures

6. Review of standard memorandums providing deliverables to clients in accordance with procedures such as hiemorandum htYC-1996, hiaine Yankee Post Plant Shutdown Offsite and Control Room Doses for a Fuel Handling Accident, and hiemorandum Seabrook Cycle 6 Reload Safety Evaluation, Revision 2 waven m, F-23 CR2-DesignControls

EngthJering Process Assessment at DE&S' Battsn O!DeeWM W15EDEMBt Criteria and Review Approach Document Worksheet Assessment Topic No. 3: Management Control of Safety Related Activities ,

Business Process Name: Manage People Sub-Process Focus: Organize Human Resources Deploy People Overall Acceptance Criteria:

Engineering and technical organizations are structur:d and organized to provide the required skills and abilities to perform safety-related work; and personnel are assigned work based on job knowledge and required training and qualifications.

A. Specific Acceptance Criteria:

1. Organizational responsibilities and lines of authority are defined and understood.

^

Personnel possess the required qualifications, knowledge and skills for the work assigned. ,

4"

3. The number of personnel in the organizat on is appropriate for the work load.

4. The organizational structure facilitates conduct of the work.

5. Clear communication lines with clients and regulators are established and adequately maintained as appropriate for the work task.

B. Resfew Approach:

1. Interview managers responsible for engineering and technical work.

2. Interview personnel responsible for producing calculations, analyses and other engineering and technical work products C. Results:

The organization is designed to provide engineering and technical support in the a;eas of nuclear engineering and fuel services, decommissioning, environmental health & safety and QA to the sponsor

.mmomms F-24 CR3-Org& Deployment 0

)

plants; that being Maine Yankee, Vermont Yankee, Yankee Rowe, and Northeast Utilities (Millstone, Conn:cticut Yankee, and Seabrook). Managers and engineers were very knowledgeable of their technical responsibilities but some appeared to be less clear of their functional roles and responsibilities and interface with the sponsor plants. However; roles and responsibilities appear to be evolving with company and client or3 r.Ntional and ownership changes and are different depending on the client. Personnel typically have 20+ years of experience in their engineering disciplines which provides depth for required independent review and verification of work products. The number of personnel in the organization appeared to be marginally adequate for the work load. Concerns over workload and schedule pressures were prevalent through much of the organization. The use of outside resources has been necessary on I occasions in order to meet deliverable schedules.

A close working relationship was found to exist between engineering groups and their clients. These relationships in many cases have existed for many years and are very strong. Depending on the plant, some groups are more formal than others in dealing with the client on work requests and applicable QA requirements. In some groups work is initiated with little or no documentation. However; these relationships are now evolving due to the company and plant organizational changes. As one example, the Projects group use to provide support between the clients and the engineers relative to project assignments. However, now they are located at the site and no longer provide direct support. This has led to some confusion as to how work is formally initiated.

D.

Conclusions:

The organizational structure is appropriate for the engineering functions performed for the sponsor plants. Staffing levels appear to be marginally adequate. Outside support is occasionally used to meet schedules. Personnel are professional and very knowledgeable of their job. Roles and responsibilities from a business point on view (i.e. budget and schedule type issues) are evolving and are different for each project / plant. Consequently, not everyone appears to have a good understanding of these. Interfaces and lines of communication between the engineering groups and the plants are likewise changing and not clearly documented.

Specific objective evidence supporting the above conclusion was found in the following documents:

1. DE&S Bolton organization chart

2. Yankee Atomic Electric Company Operational (YAEC) QA Manual, YOQAP-1-A, Revision 27

3. Yankee Rowe Station Decommissioning Engineering Status dated 1/9/98

4. EH&S Task / Status List dated 2/2/98

5. Nuclear Engineering Project List Status List / Biweekly report dated 2/2/98

6. ATD Work Status List dated 1/21/98

7. Client Status Reports:

1/26/98 Status / Letter to WR Carr/NU 11/21/96 Status / Letter to JE Kmietek 11/13/95 Status / Letter to EA DeBarba

/

mam,.m F-25 CR3.Org& Deployment l

l 1

Engincering Ikx:ess Assess:sent at 'DE&S' Bolton'OITre' t ?3*F422 MEW Criteria and Review Approach Document Worksheet Assessment Topic No. 4: Design Engineering Training; Particularly, QA Program Training Business Process Name: Manage People Sub-Process Focus: Train People Overall Acceptance Criteria:

Personnel assigned work are trained and qualified based on training needs assessments to perform required tasks in accordance with design procedures and QA requirements.

A. Specific Acceptance Criteria:

1. An employee training needs assessment process is established and utilized.

2. There is a capability and process to develop and provide employee training.

3. There is a process for keeping up with the training achieved by employees and the associated training records.

. There is a process for identification of periodic training needs of employeer.

5. There is a process to evaluate training effectiveness which is provided to the organization.

6. On-the-job training (OJT) is adequately integrated into the overall approach to training.

B. Review Approach-

1. Assess the adequacy and effectiveness of implementation of the Indoctrination and Training Program.

2. Interview responsible department and training personnel.

3. Review Indoctrination and Training Records for randomly selected individuals.

t

. mm.,m F-26 CR4-Training

l

~

l .

Enginecrmg NceWAssessment at DE&S' BoltonDfhoe . ' i i ; 'N' l

C. Results:

Indcctrination of engineering personnel is governed by Engineering Instruction (EI) No. WE-003,

Indoctrination of Personnel". The purpose of this document is to:

1. provide a program for the indoctrination of engineers who are responsible for accomplishing engineering activities in accordance with the Engineering Manual. This procedure is also used for the indoctrination of contractors working under YAEC's Quality Assurance Program.

2. establish how the content and completion of the indoctrination program for engineers is documented.

Documentation of the program is accomplished by the use of the Indoctrination of Personnel Form (WE-003-1). Based on a review of the Indoctrination Records for the individuals identi6ed below, this procedure is being effectively implemented. In particular, it was verified that El Nos. WE-103,

" Engineering Calculations and Analysis" and WE-108," Computer Codes" were reviewed in detail and i that the Project, Engineering or Group Manager reviewed the completed checklist.

Emnioyee Name Organi7ation R. Cacciapouti Nuclear Engineering A. Fyfe Nuclear Engineering J. Distefano Environmental Health & Safety J. Gorski Nuclear Engineering J. Hamawi Environmental Health & Safety G. Harper Environmental Health & Safety P. Littlefield Environmental Health & Safety E. Spinney Nuclear Engineering M. Tremblay Nuclear Engineering However, the Indoctrination of Personnel Form for G. McCormick from Automation Technology could not be located in the Document Control Center. When this was brought to the attention of the Responsible Manager, immediate corrective measures were taken. Specifically, the Indoctrination of Personnel Form was completed, provided evidence of an appropriate level of understanding of WE-103 and WE-108, and tumed over to Records Management Services for proper filing and storage. It was concluded that this was an isolated case based on the absence of similar findings.

In addition to Indoctrination Records, the Training Records for these individuals were also reviewed and found to be in accordance with the requirements of El No. WE-004, " Training". These records demonstrated that the training program ensures that employees and contractors receive periodic updating in the requirements of the program and the experience accrued in the implementation of the Engineering Manual. In particular, the Education Profile Forms, which are maintained by the Training Department, were reviewed. This form documented the internal and extemal training courses, sessions, etc. that were attended. Updates to this document were based on input from the Fur.ctional Manager.

wawm.ucs F-27 CR4-Training

Engineering Prowss Assessment at DE&S'lloltonOffief 7.uts W6 D.

Conclusions:

Based on a review of El Nos WE-003," Indoctrination of Personnel" and WE-004," Training",

interviews with responsible department and training personnel, and a review of the Indoctrination and Training Records for randomly selected individuals, the Indoctrination and Training Program was found to be adequate.

However, Condition Report (CR) No. 97-0077 dated July 25,1997 Action Item No. 08 required that an assessment be perfonned by each department to evaluate if the read and sign training performed was appropriate to assure adequate understanding of material. The response to Action Item No. 08 was that the read and sign training was not an appropriate method of training and would no longer be used.

Further, to ensure that employees unable to attend training receivad adequate training, a review packet containing a quiz would be developed as part of a Lesson Plan. Based on discussions with the Training Department, it was learned that the Functional Managers identified selected El and Technical Administrative Guidelines (TAG) for this type of training. Presently, CR No. 97-0077 remains open.

Although enhanced training was completed for TAG No.14. " Policy for Control of Safeguards Information" on December 17,1997, no additional training has occurred to date. This initiative has been placed on hold pending completion of the YAEC/DE&S transition. ,

woum, mms F-28 CR4-Training

Enginee'rint Process Assessment at DE&S* Bolton Ofhce - - ". .% : 02Ma Criteria and Review Approach Document Worksheet l

l l

l Assessment Topics No. 5: Management Control of Safety-Related Activities; Adherence to Applicable Procedures, and Industry and NRC Requirements; and Quality of Work Products I

Business Process Name: Manage Performance Sub-Process Focus: Monitor / Review / Assess Performance Act on Performance Results Overall Acceptance Criteria:

Performance is monitored, assessed and appropriate actions taken based on results.

A. Specific Acceptance Criteria:

1. Acceptable standards of performance are established.

2. The organization understands the acceptable standards of performance.

3. There is a process for collecting and evaluating performance.

4. Corrective actions are prompt and adequate.

5. Management control and oversight of safety-related activities are adequate.

B. Review Approach:

!. Interview managers responsible for engineering and technical work.

2. Review randomly selected internal and external assessments (audits, analysis and inspections).

Assess the results of these oversight activities with respect to the significance and impact of the issues identified, corrective actions taken and their closure.

smwom F-29 CRS PerformanceMgmt

, Engineenna Process Asrcssment at DE&S' Bolton'Ofhoe " % '41MilDD94 C. Results:

Management control of safety-related activities. adherence to applicable procedures, and quality of work products were found acceptable. Interviews with a number of management persounel indicated good knowledge of the work in house and the challenges facing the organization. The review of work products and discussion at' all levels in the organization showed that work is adequately controlled and is prepared in accordance with accepted standards. Consequently, based on the evidence of satisfactory work before it and the motivated, experienced work force which we found, the team did not find reason to pursue some of the traditional aspects of performance management in detail. For example, acceptance criteria 1-3 were not evaluated for these reasons.

In a number of interviews, the review team discussed with management its perspective regarding protecting the acceptable standards of work performance from the pressures of schedule. In all cases, management held out work product quality as the number one priority. The review team did not discover any instances in which work product quality had suffered based on the review of the specific deliverables.

u was also evident that the Bolton office is developing methods to address the concerns over schedule pressure. Managers in all departments assessed were found to be aware of work assignments and directly involved in many cases as the approver for safety related work, in addition, a review was conducted of randomly selected internal and external assessments such as audits, analysis and inspections. Four oversight activities were chosen from twenty-five potential audits / assessments performed by Quality Assurance of YAEC/YNSD Engineering activities. The results of these oversight activities were assessed with respect to the signincance and impact of the issues identified, corrective actions taken and their closure. The results of this review are documented below:

• Appendix R Root Cause Analysis Task Force for Vermont Yankee Audit Dates: August 28 - September 15,1995 4

The Task Force performed a root cause analysis on six Vermont Yankee (VY) event reports involving the VY fire protection program and compliance to Appendix R requirements. Several recommended corrective actions were implemented and assigned for plant commitment tracking.

An aggressive Task Force was established by the VY Plant which addressed the identified wide range ofissues. Five of the se'.en items have been satisfactorily closed. The two remaining issues are being tracked to closure through Licensee Event Report (LER) No. LER9514 05. The plant and YNSD Project Engineering have re-organized the Fire Protection / Appendix R coordination, and greatly improved and continues to improve the Appendix R Program in meeting all of the established federal requirements.

Audit No. NSD-96-02, Functional Area Audited: VY Design Engineering Audit Dates: Movember 4-8, Il-13, and 22,1996 The Audit Team verified the imp'ementation of the Quality Assurance Program for design and design change controls and confirmed the adequacy of the program in meeting regulatory wusoom F-30 CRS-PerformanceMgmt

Engineerinz Erocess Assessment at DE&S' Bolton OfTre 1_1 C 8%=MERt l

requirements and internal YNSD engineering procedures. It was concluded that design activities performed by the VY Desi Fn Engineering Group were considered adequate. Engineerlag Design Change Requests (EDCRs) and calculations reviewed by the audit technical specialists in the electrical / mechanical disciplines identified no immediate design or operability issues. However, programmatic issues were identified by the audit team, which required VY Engineering Management attention. Thineen findings were identified and five recommendations for improvemer.t were offered. Nine of the thirteen findings have been satisfactorily closed. The four remaining findings are being tracked to closure through ER Nos. 96-1074,96-1083,96-1088 and 96-1090. In addition, all five recommendations were satisfactorily closed.

• Audit No. VY-96-25, Functional Area Audited: Environmental Qualification (EQ)

Audit Dates: April 22 - May 10,1996 and May 16,1996 The EQ Design Basis Audit Team verified that a solid design basis was established and maintained for the VY EQ Program, and that it met the requirements of 10CFR50.49 and guidance provided by Regulatory Guide 1.89. The audit consisted of the review of EOPs, calculations regarding High Energy Line Breaks (HELBs) outside containment, specifically large circumferential breaks (double-ended), and small break analysis for the Reactor Water Clean Up (RWCU) System and steam tunnel, Loss-Of-Coolant Accidents (LOCAs) inside containment, procurement of EQ equipment, EQ manuals, NRC generic letters and bulletins, prior submittals to the NRC (SERs),

NRC Memorandum and Orders (M&Os), radiation dose calculations and analysis associated with the DB As, extensive interviews, configuration control, and review of FS AR for EQ applicability.

The audit concluded that the EQ Program at VY was supported by an adequate basis. However, the audit team determined that although the documentation reviewed was technically adequate, increased management attention was wairanted in the level of detail needed in certain EQ Program basis documentation and configuration control within the EQ Program (control of EQ changes affecting operations and EOPs). As a result of the audit, five findings were identified and five recommendations for improvement offered for consideration. Two of the five findings have been satisfactorily closed. The three remaining findings are being tracked to closure through ER Nos. 96-0277,96-0293 and 96-0292. In addition, four of the five r :ommendations have been satisfactorily closed.

NRC Integrated Inspection Report No. 50-271/96-06 dated August 8,1996 Inspection Dates: May 12 - Jujy 13,1996 Licensee: Vermont Yankee Nuclear Power Corporation Facility: Vermont Yankee Nuclear Power Station The NRC performed an Integrated Inspection at the Vermont Yankee Nuclear Power Station.

This Integrated Inspection included aspects of Licensee Operations, Enginering, Maintenance and Plant Support. The report covered a nine week period of Resident Inspection and the results of announced inspections by a Regional Specialist and a Regional Projects Inspector.

,mmoona F-31 CRS PerformanceMgmt

The NRC Integrated Inspection Team concluded that the conduct of activities at the Vermont Yankee Nuclear Power Station were geners!h characterized by safety-conscience operations, i sound engineering and maintenance pracdees and careful radiological work controls. It was noted that the Vermont Yankee staff continues to demonstrate a questioning attitude in identifying program discrepancies and/or old design problems such as the Appendix J Valve Testing Oversight and the Emergency Diesel Generator Room Differential Prctection Inadequacies discovered during the NRC Integrated Inspection. In the area of Plant Support, the NRC Inspection Team found that Vermont Yankee continued to implement overall effective Radiological Environmental Monitoring and Meteorological Monitoring Programs. Lastly, no Notice of Violations (NOVs) or Nonconformances were issued by the NRC as a result of the Integrated Inspection nor was a reply to the NRC Integrated Inspection Report No. 50-271/96-06 s required.

D.

Conclusions:

Based on interviews with management, reviews of engineering work products and reviews of audits, it was concluded that management control and oversight of safety-related work is acceptable. No significant quality or technical issues were identified.

Specific objective evidence in support of these results include the Yankee Atomic Electric Company Operational (YAEC) QA Manual, YOQAP-1-A, Revision 27. These QAP's provide management with necessary controls in accordance with NiiC criteria for assurin : Msign control.

s uansoom m F-32 cR5.PerformanceMgmt I

4 APPENDIX G QUALITY ASSURANCE ASSESSMENT C

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