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NQA AUDITING
National E&E Division ConferenceSeptember 17, 2008
C. H. Moseley, Jr.Senior Executive Consultant
• Chronology of Nuclear Standards Development
• Structure of ASME NQA-1
• Auditing using ASME NQA-1
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NQA Chronology
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1980sDOE O 5700.6, 6A, 6BANS 3.2-1982ASME NQA-1-1983(N45.2.1, 2.2, 2.3, 2.5, 2.8, 2.15, 2.20)
REG Guide 1.28, Rev 3ASME NQA-2-1983ASME NQA-1-1986ANS 3.2-1988ASME NQA-1-1989ASME NQA-3-1989
1970s10 CFR50 Appendix A10 CFR50 Appendix BANSI N45-2-1971AEC Safety Guide 28ANSI N18.7(ANS 3.2)ANSI/ASME N45.2-1977ASME N45.2.9 – 2.23NRC Rainbow seriesANSI N46.2-1978ASME NQA-1-1979(N45.2.6, 2.9, 2.10, 2.11, 2.12, 2.13, 2.23)
1960sMIL-Q-1958A10 CFR50 APPENDIX AAEC>DOE RDT F2-2T
1950sAEC SFO QC-1MIL-Q-1958
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NQA Chronology2000s
DOE O 414.1BDOE O 414.1CDOE 10CFR Part 830
(sub-part 830-122)
ASME NQA-1-2000ASME NQA-1-2004ANS 3.2-2006ASME NQA-1-2008
1990sNRC Standard Review Plan
(NQA-1 & NQA-2)
DOE O 5700.6CDOE 10CFR Part 830
(sub-part 830-122)
ASME NQA-1-1994ANS 3.2-1994ASME NQA-1-1997DOE O 414.1A
Layout of NQA-1
Part I - Requirements for QA Programs for Nuclear Facilities (Formerly NQA-1)
Part II - QA requirements for Nuclear Facility Applications
Part III – Non-mandatory Appendices (From former NQA-1 and NQA-2)
Part IV – Non-mandatory Appendices – Positions and Application Matrices
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Underlying NQA-1 Principles
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Senior management:Defines policies and objectivesEstablishes and communicates expectations for quality and continual improvementIdentifies and allocates resources to achieve expectationSpecifies roles, responsibilities and authoritiesEnsures NQA principles are understood, accepted and followed
Quality of work is:Achieved and maintained by performersVerified by those not directly responsible for performing the work
Basic RequirementBR 1Organization
NQA-1
Underlying NQA-1 Principles
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Management:Ensures proper development and implementation of the organization’s QAPEnsures people are competent to perform their assigned quality-affecting workProvides training to achieve and maintain worker proficiency and qualificationsAssesses QAP and management systems to ensure compliancy, adequacy effectiveness and efficiencySeeks and uses relevant experience
BR 2QA Program
NQA-1
Underlying NQA-1 Principles
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Work processes are planned and controlledActivities are performed in accordance with prescribed documentationManagement ensures the right people have the right information at the right time
BR 5Instructions, procedures and drawings
Items and services are purchased, accepted and controlled to specified requirements
BR 4 & 7Procurement
Items are designed and changes controlled using sound engineering practices, analyses and configuration managementDesigns are analyzed and verified
BR 3Design Control
NQA-1
Underlying NQA-1 Principles
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Special processes for achieving quality are performed under controlled conditions to specified requirementsUse of correct materials, tools and processes and control changes is assured
BR 9Process control
Items are identified and controlled during shipping, handling, installation or use to assure their quality and prevent damage, loss or deterioration
BR 8 & 13Item identification and control
Quality documents and records are developed, identified and controlled in accordance with specified requirements
BR 6 & 17Documents and records
NQA-1
Underlying NQA-1 Principles
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Item inspection, test and operating status are identified to ensure required activities have been performed successfully
BR 14Inspection, test and operating status
M&TE used for activities affecting quality are controlled to specified accuracy requirements
BR 12Measuring and test equipment control
Items are inspected and tested to verify conformance to specified requirements
BR 10 & 11Inspection and test control
NQA-1
Underlying NQA-1 Principles
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The QAP is assessed using compliance and performance-based methods
BR 18Audits
Conditions adverse to quality are identified, controlled and corrected to prevent recurrence, and reviewed for lessons learned
BR 16Corrective action
Items that do not meet specified requirements are identified and controlled
BR 15Control of non-conforming items
NQA-1
Part I Introduction Purpose - QA Requirements for Nuclear facilities
Applicability - Part I Applies to activities that could affect quality of nuclear material applications, structures, systems and components of nuclear facilities
Activities to which it applies listed
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IntroductionApplication of Part I or portions thereof to be invoked
by written contracts, policies, procedures, specifications or other appropriate documents
Responsibility
Organization invoking shall specify which requirements or portions related to specific items and services
Organization implementing responsible to comply with requirements to achieve results
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NQA-1 Part IIQA requirements for planning and conducting of
fabrication, construction, modification, repair, maintenance and testing of systems components or activities for nuclear facilities (i.e., requirements for “work practices”)
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Types of QA Audits• Adequacy Audit
• Implementation Audit
• Effectiveness Audit (Performance-Based)
• Full Scope
• Partial Scope
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Requirement 18 – Audits• Audits Shall be Planned and Scheduled to Verify Compliance
and Effectiveness with all Aspects of the QA Program
• Performed per Procedures by Personnel Independent of the Activities being Audited
• Audit Results are Documented and Reported
Objective:To determine by Independent Investigation Examination, or Evaluation of Objective Evidence the Adequacy, Implementation and Effectiveness of a Process
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Audit PreparationAudit Preparation shall include:
• A review of background information, procedures and technical documents so that audit team members are familiar with the work being audited.
• A review of past audit results to determine the nature of corrective action that have been taken and determine whether the corrective actions were effective in preventing recurrence.
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Requirement 18 – AuditsAudit Elements:• Scheduling• Preparation (Audit Plan, Personnel Selection,
Checklists, Logistics, etc.)• Performance (Interviews, Observations and Records
Review)• Reporting• Response to Corrective Actions• Follow-Up Actions• Records
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Requirement 18 – AuditsAuditor Qualifications (Requirement 2, Training)• Technical Specialists• Auditors• Lead Auditor
– Background – Communication– Examination – Certification
Why Do We Perform Audits?
Why is It Required that Auditor Independence be Maintained?
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Summary – Audits• The Auditee, responsible for the performance of
activities, implements a program of surveillances and audits using Qualified Personnel.
• The Assessment program shall be planned, documented and include both routine surveillance of activities and audits to verify compliance with all aspects of the QA program and to determine adequacy and effectiveness.
• Assessment Results shall be Documented.
• Audit QA Records shall be Retained and Maintained