IR 05000416/1981055

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IE Insp Repts 50-416/81-55 & 50-417/81-24,on 811207-11.No Noncompliance Noted.Major Areas Inspected:Licensee QA Program,Review of IE Bulletins 80-23 & 80-06 for Design Input & Procurement Activities & Audits
ML20040E633
Person / Time
Site: Grand Gulf  Entergy icon.png
Issue date: 01/05/1982
From: Debbage A, Merriweather N, Upright C, Wright R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20040E627 List:
References
50-416-81-55, 50-417-81-24, IEB-80-06, IEB-80-23, IEB-80-6, NUDOCS 8202050190
Download: ML20040E633 (14)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION 8' A o

REGION 11 $g 101 MARIETTA ST., N.W., SUITE 3100 [[ o,. ATLANTA, GEORGIA 30303 Report Nos. 50-416/81-55, 50-417/81-24 Licensee: Mississippi Power and Light Company P. O. Box 1640 Jackson, Mississippi 39205 Facility Name: Grand Gulf Docket Nos. 50-416, 50-417 License Nos. CPPR-118 and CPPR-119 Inspection at licensee corporate offices in Jackson, Mississippi V [d $2 ' Inspectors:

- ' R. W. W i h1/ at Signed __ fh v _ / - O'- Q A. G. Debbage Date Signed ? ? sm ek -_! ^ 5 ~ & N. Merri eather Date Signed [ _-4-4 ', _[M. Uprigh, S' tion f iief / d[ Approved by: C.

te 61 gred Engineering In's.ecti ranch Engineering aVd Technical Inspection Division SUMMARY Inspection on December 7-11, 1981 Areas Inspected This routine, announced inspection involved 90 inspector-hours at licensee headquarters in the areas of the licensee's quality assurance program, design control, procurement activities, and audits.

Results Of the four areas inspected, no violations or deviations were identified.

8202050190 820107 PDR ADOCK 05000416

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

  • J. P. McGaughy, Assistant Vice President Nuclear Production
  • T. E. Reaves, Manager of QA
  • J. E. Reaves, Procurement & Supplier Quality Coordinator
  • A. T. Ramey, Quality Reporting & Nonconformance Control Coordinator
  • J. W. Yelverton, QA Field / Operations Supervisor
  • J. C. Bell, QA Representative (Field)
  • W. A. Ruhlman, QA Consultant, Theophilus, Inc.
  • W. E. Edge, Program & Audits Coordinator

C. W. Heard, QA Representative (Audits) R. Brown, Project Engineering Staff , S. Hobs, Supervisor Nuclear Safety

  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on December 11, 1981 with those persons indicated in paragraph 1 above.

3.

Licensee Action on Previous Inspection Findings Not inspected.

4.

Unresolved Items l ' Unresolved items were not identified during this inspection.

5.

Quality Assurance Program (35060B) a.

QA Program Changes.

The GGNS PSAR Chapter 17, R1 (dated 5/2/77) and MP&L's letter to NRR , dated 11/13/78 that officially dissolved the Quality Assurance ' Committee describe the licensee's QA program as last reported to the NRC.

This program complies with the requirements of 10 CFR 50,

Appendix B, as amended January 20, 1975, and ANSI N 45.2 - 1971, ' Quality Assurance Program Requirements for Nuclear Power Plants.

MP&L has incorporated some changes to the above mentioned QA program which have been documented in the GGNS Construction QA Manual (CQAM), R7 (1/30/80) and the Topical Report Number MPL-TOP-1A, R2, Operational QA Manual (0QAM).

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Currently (in accordance with MPL-TOP-1A, R2) the licensee's manager of QA (MQA), nuclear plant manager, and manager of nuclear services report ' to the assistant vice president (VP) nuclear production who in turn reports to the senior VP nuclear production who reports to the president of MP&L. Formerly under the PSAR, R1 (reference Fig.17.1.1)

' the above managers reported to the VP nuclear production who reported _ to a senior VP who in turn reported to the president of MP&L. Although QA now reports functionately to a lower level (Asst. VP versus VP level) the number of reporting tiers to the president of MP&L has not changed and it appears that QA independence has been retained.

CQAM, Policies 9 and 10, R6, (5/4/79) state that MP&L's QA program for compliance, for corrective action, and for audits of construction will comply with Policies 16 and 18 respectively contained in the 0QAM with the exception of paragraph 18.5.11.

This MP&L policy change is viewed as beneficial in that MP&L now has the same compliance program for construction and operations in these areas and by adopting the 00AM the licensee has envoked various ANSI daughter standards (such as N45.2.12, N45.2.23) which strengthen and more clearly define the construction j program in these areas.

J The MP&L GGNS QA staff has continued to increase in personnel since the time of its conception.

Expanded work loads, new responsibilities undertaken by MP&L and additional NRC requirements placed upon the licensee have resulted in continued QA growth. The current (12/7/81) MP&L GG QA Section Organization chart revealed twenty-nine active QA personnel.

Twelve of the twenty-nine are assigned to the General Office and the remaining seventeen are in residence full time at the GG construction site.

Current staffing appears to be meeting assigned responsibilities.

Various MP&L corporate procedures contained in the QA Procedures Manual govern activities of the QA section in implementation and management of the MP&L QA program for both operations and construction.

The QA procedures listed below were examined for changes (revisions) to verify that these changes were approved at appropriate management levels and to ensure that document control (distribution) requirements had been effectively complied with as specified by QAP 5.10, Drocedure Preparation, Procedure and Manual Revision, Distribution, and Control: QAP 18.10,R6 QA Audits QAP 18.12,R1 Supplier QA Audits QAP 18.14,R0 QA Monitoring Audits QAP 4.20, R4 Procurement Quality Requirements The inspector verified that controlled manual holder copies Nos. 5,6,8 and 23 of MP&L's Internal Procedures Manual had been updated to the latest procedural revision. Additianally, controlled copies Nos. 6 and 17 of the MP&L Nuclear Services Administrative Procedure Manual were examined and found current.

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b.

Licensee Review of QA Program Effectiveness The assistant VP nuclear production maintains a continuing involvement in QA matters and assesses the scope, status, implementation and effectiveness of the program through a system of annual management audits and semi annual status reports prepared by the MQA.

The inspector examined the following QA effectiveness reviews for compliance to procedural requirements, reconmendations, and disposition of these recommendations: Management Internal Audits Nos.1, 9,10 conducted 10/4/73, 2/18-25/80, and 12/5-11/80 respectively.

QA Semi-Annual Status Reports to Management for the Periods 1-6/80, 7-12/80, and 1-6/81 In addition to the above mentioned reviews, Middle South Services (MSS) has been actively involved in conducting various audits of MP&L QA activities to verify that these activities are being performed and documented in accordance with applicable MP&L QA Program requirements and implementing procedures.

The inspector examined MSS audits of MP&L's QA activities conducted on 5/19-21/81, 6/2-5/81 and 6/16-20/80.

c.

Corporate QA - Site QA Interface Discussions with the MQA revealed that a copy of every audit report which is generated by the site QA field supervisor's (QAFS) representatives is transmitted to both management and corporate QA.

Likewise, any audit generated by corporate QA is transmitted to corporate management and the site.

Each Corrective Action Request (MP&L nonconformance) is handled in the same manner.

The MQA and QAFS share weekly reports of the QA organization's activities as well as any special reports on any serious deviations which are prepared by the MQA and submitted to MP&L management.

Within this area, no violations or deviations were identified.

6.

Design Review - External A/E (350608) a.

Documents Examined Grand Gulf Nuclear Plant PSAR, Chapter 17, R0 and R1 Construction Quality Assurance Manual (CQAM), R7 Operational Quality Assurance Manual (0QAM), R2 Internal Procedures Manual (IPM), R6 Quality Assurance Manual (QAM), R1 Quality Assuance procedure Manual (QAPM), R15 .

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b.

QA Program Requirements The licensee's QA program for design and construction described in the Grand Gulf PSAR, Chapter 17, Revision 0 was modified by Revision 1 to the PSAR and subsequently modified in the Construction Quality Assurance Manual and Operational Quality Assurance Manual. During this inspection the inspector reviewed QA program revisions in the area of design control to determine if the changes were reviewed and approved by appropriate management and that the changes did not weaken the effectiveness of the QA Program.

Within this area, no violations or deviations were identified.

c.

Design Assurance The objective of this inspection was to determine the licensee /AE organizational responsibilities for design assurance.

The inspector reviewed the Mississippi Power and Light Company (MP&L) organization to understand the internal and external interfaces for design control. The inspector determined that Policy 10 of the Construction Quality Assurance Manual requires the licensee to audit Bechtel (AE/ Constructor) at least annually to evaluate the effectiveness of the design assurance activities performed by Bechtel.

The QA Program requirements for auditing are described in Policy 18 of the 0QAM which invokes the requirements of ANSI Dra f t Standard N45.2.12-1976, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants.

The licensee performs management reviews of specific Q-listed documents to revision 0 (such as Main Single Line and Single Line Meter and Relay Diagrams, Specifications, Piping and Instrumentation Diagrams and Instrument Installation Details).

The primary means of determining the effectiveness of A/E design assurance activities is by auditing.

Within this area, no violation or deviations were identified.

d.

Design Assurance Audits i The inspector reviewed the licensee's Master Audit Plan and Master l Audit Schedule to assure that an audit plan was documented and that the j frequency and scope of audits was sufficient to assure that l representative design groups and safety functions are included. The Program and Audits Coordinator is responsible for scheduling audits and assigning the audit team leader and audit team members.

Audit team l members are selected from a list of qualified auditors and audit team i leaders are selected from a list of qualified lead auditors. Technical specialists, observers, and auditors-in-training are assigned as required.

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The MP&L audits of Bechtel for alendar year 1981 were reviewed to determine that the objective and scope established in the audit plan was accomplished, that followup on audit findings was timely, and that corrective action was adequate.

The auditors' qualifications were reviewed and found acceptable.

The following QA Procedures were reviewed to determine compliance with regulatory requirements and the QA program.

QAP 18.00, R1 Quality Assurance Audits Planning and Scheduling QAP 18.10, R6 Quality Assurance Audits Within this area, no violations or deviations were identified.

e.

Design Inputs The inspector reviewed the interfaces between MP&L and Bechtel for handling NRC bulletins, circulars and information notices to assure that the NRC requirements and positions transmitted to the licensee are reviewed by the A/E for design input.

The Manager of Safety and Licensing receives the bulletins, circulars and information notices from the Nuclear Project Manager. The Manager of Safety and Licensing is responsible for having the bulletins, circulars or information notices entered into the Bulletin / Circular /Information Notice Log. The log is used to track the status of the bulletins, circulars and information notices until they are closed out.

The Manager of Safety and Licensing coordinates the evaluation by the A/E or NSSS and acts as liaison with the NRC on all formal r.ommunications relating to NRC bulletins, circulars and information notices.

The inspector examined the tracking log and applicable correspondence between MP&L and Bechtel (A/E) for NRC bulletins 80-23 and 80-06 to determine compliance with requirements of procedure IPM 6.3, R12, Evaluation of IE bulletins, circulars and information notices.

Within this area, no violations or deviations were identified.

7.

Procurement (350608) a.

Procurement Organization Controls Bechtel Power Corporation, Los Angeles (Bechtel) is the architect-engineer for Mississippi Power and Light Company (MP&L) Grand ,i Gulf nuclear plant, with General Electric being the NSSS supplier.

Bechtel performs vendor audits, maintains a Bechtel evaluated supplier list, prepares proposed supplier evaluation lists and procurement bidder lists for MP&L, and provides engineering and quality assurance controls in procurement of safety related items and services. The . - . _ _ - -.. --

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manager of quality assurance (MQA) reports to the Assistant Vice President, Nuclear Production.

The procurement and supplier quality cordinator reports directly to the MQA and is supported by two quality assurance representatives to cover the supplier evaluation and supplier audit activities. MP&L plans to participate as observers in a joint audit with Bechtel in January 1982.

Middle South Service conducts audits of the MP&L QA program both at the Jackson general office and at the Grand Gulf project.

Bechtel activities are audited by MP&L QA staff.

Procedures controlling the above activities were reviewed to determine that they contained essential controls for procurement activity.

The procedures reviewed included the following: QAP 7.10, R3 Supplier Pre-award Evaluation QAP 7.16, R0 Supplier Evaluation by Record Review QAP 7.20, R3 QA Source Inspection Program QAP 7.30, R0 QA Source Inspector Certification Program 01-S-03-3, R5 Administrative Procedure Material Nonconformance Reports, Safety Related 01-S-09-1, R8 Procurement of Material, Equipment and Services 01-S-09-2, R4 Materials Receipt, Handling and Storage Control, Safety Related 12-S-01-1, R2 Quality Section Procedures and Instructions, Safety Related 12-S-01-8, R3 Plant Quality Inspection, Safety Related Manual #9645 Bechtel Project Procurement Procedures Manual b.

Procurement Document Control Procurement documents were reviewed to determine that the following elements had been included: - Applicable regulatory requirements, design basis, and other requirements were included or referenced - Procurement document changes were subjected to the same level of control as used in the original preparation - Scope of work to be performed by the vendor identified

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- Technical requirements referenced the appropriate documents - Test, inspection, and acceptance criterf a identified - Vendors had a documented QA program and were required to incorporate QA requirements in subcontract documents - Special instructions / requirements were included for activities such as designing, identification, fabrication, cleaning, erecting, packaging, handling, shipping, and extended storage - Documents identified which were to be sent to MP&L for review and approval - Nonconformance reporting and control specified

Access to the vendor s facilities and records for inspection or - audit incorporated All specifications, purchase orders and revisions to these were available on m*o afiche which had been submitted to MP&L by Bechtel.

Subjects selected for review were the procurement of nuclear service valves 2h" and larger, and containment structure electrical penetration assemblies; these were selected because of substantial revisions to both the purchase orders and technical specifications.

In accordance with established procedures, specifications are submitted to MP&L by Bechtel for review and approval.

The MP&L project manager has responsibility for their evaluation. The engineering section reviews the specification for content and nuclear plant engineering performs a technical review.

Precedures exist for these reviews and the reviews are documentad.

Nuclear service valves technical specification 9645-M-242.0 was issued in August 1973. The first page identified that the specification was for Q items. The specification listed the environmental conditions and radiation levels for valves located both inside and outside the containment building; a 40 year integrated exposure was specified.

Seismic conditions were to Category I with 3.0g in any direction and forcing frequency greater than 33 cps.

The ferrite content for the austenitic stainless steel was to be limited to 8-25%. Wall thickness was to be verified to ANSI B16.5 and weld ends radiographed in accordance with NC-2571.

For valves in the pressure bouncary, ASME code case 1388 was to apply and for those in the nonpressure boundary, heat treatment was to be in accordance with ASTM A 564-71 table 2 with specified limitations.

Impact tests on materials were required to i NB-2300, liquid penetrant tests to NB-5000 or NC-5000 as applicable.

' Seats and discs were to be of hard surface materials to AWS. AS.13.

Other standards included the standard practices (SP) of the manufacturers standardization society of valves and fittings industry (MSS); the specification listed MSS-SP-25, 45, 55, 61 and 66.

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Radiographs and certified material property reports were also required.

Various appendices to the specification included manual operator loads, electric motor operators, air cylinder operators, and specification of the welding process including post heat treatment. This specification was incorporated into purchase order 9645-M-242.0 issued December 1973.

Revisions to the specification and purchase order were examined.

Appendix N (electric motor operators) was revised to identi fy the operator manufacturer LIMIT 0RQUE, specify the horsepower to control runaway thrust and add information supplied by the seller. Revision 1 of the purchase order incorporated revision 1 of the specification in March 1974. Various revisions were concerned with addition or deletion of items, revision of equipment number, delivery dates, price revisions and cancellation charges.

Revision 21 of the purchase order incorporated Revision 13 of the specification in November 1977.

Revision 22 implemented the requirements of 10 CFR part 21.

Purchase order revision 48 incorporated specification 34 in November 1980.

Revision 34 was compared to the original specification.

A specification checklist had been incorporated showing the FSAR commitment and location of its incorporation into the specification.

Section III of the ASME code was specified to be 1971 edition with addenda up to and including Winter 1972. ASME section IX for welding qualifications specificd code cases 1516-1, 1567, 1580-1, 1622 and 1388-2. Included was the requirement for review and certification of stress reports and providing two copies of the stress reports for Class I components as required by NA-3352.

The remainder of the specification, including the seismic frequency and 'g' loading was unchanged. The most recent purchase order revision 57 dated 10/8/81 incorporated specification revision 38.

The supplier of the service valves was the William Power Company.

Technical specification 9645-E-035.0 for containment and drywell structures electrical penetration assemblies was incorporated into purchase order 9645-E-035.1 revision 0 in March 1974. The first page of both specification and purchase order identified that they were for Q items.

The specification listed the environmental conditions and radiation levels inside and outside the containment wall; a 40 year integrated gamma dosage was specified. Seismic Category I was required in accordance with technical specification 9645-C-1960, Appendix R.

ASME code requirements were to 1971 edition with addenda through 1972.

A nitrogen supply system for instrumentation was specified. Tests were required for flammability of self supporting plastics, dielectric strength, insulation resistance and short circuit characteristics.

Codes and standards included the IEEE 317-1972 standard for electrical penetration assemblies in containment structures; IEEE standards 51-1955, 323-1971 and 394-1971; NEMA standards WC3-1969 and WC7-1971; IPCEA standards P-32-382 (short circuit characteristic of insulated cable), IPCEAS-19-81, S-66-524 and S-68-516.

Temperature measurement thermocouples was covered in ANSI specification C96.1-1964 and test for flammability in K65.2-1969 and ASTM D635-8. Revisions to the .. - - --_

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specification and purchase order were examined.

Revision 1 was to specify that the seals be made of cast Feraloy material ASTM A48, Class 30A and Crouse Hinds catalogue number EYS014 was referenced for the condulet conduit seals.

Subsequent revisions were principally concerned with prices, types, quantities and delivery dates.

Revision 7 implemented the requirements of 10 CFR Part 21 in March 1978. Purchase order revision 16 incorporated specification revision 12 on June 5, 1981.

Revision 12 was compared with the original specification.

The specification check list was incorporated referencing the FSAR commitment to the specification paragraph. The code and standard were unchanged except for the ASME code which required compliance with subarticle NA-3700.

The supplier of the electrical penetration assemblies was Westinghouse Electric Corporation.

c.

Vendor Evaluation Bechtel maintains an Evaluated Supplier List which is updated monthly; the most recent copy at MP&L dated November 9, 1981 and therefore current.

It lists all Bechtel suppliers of Q-list sa fety related engineering equipment or ASME section III materials.

The date, results, and type of most recent survey of the supplier is given. ASME certification stamps and date of expiration are shown and other information detailed to indicate the status of supplier quality.

Audit schedules of suppliers for Grand Gulf Nuclear Station are prepared by Bechtel two months in advance of the date due and cover a three month audit plan.

MP&L approves the audit list and Bechtel conducts the audits.

For the months of July, August and September 1981, the number of vendors proposed were 28, 29 and 25 respectively, indicating an approximate audit rate of 320 suppliers annually.

Other vendor evaluation documents used were the CASE register which had an expiration date of December 1981 and the Licensee Contractor Vendor Inspection Report dated March 31, 1981.

d.

Audits of Bechtel Power Corporation Audits conducted by MP&L Quality Assurance personnel with support from Middle South Services (MSS) were reviewed.

The QA program being applied at the Bechtel Gaithersburg office was audited during January 5-9, 1981. The team consisted of four auditors and two technical specialists from MP&L and one auditor from MSS. In addition to other QA program elements, the audit covered the following procurement activities: PSQM 3.1 Post-Award Quality Surveillance Planning PSQM 3.1 Quality Surveillance Assignments PEPM 4.2.13 Quality Surveillance Reports . - _. . .-.

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PEPM 4.2.16 Review of Supplier Survey Reports and Supplier Quality Program Audits QGG 7.2 Supplier Surveillance Inspection QGG 3.0 Quality Program Verification PSQM 4.0 Supplier Program Verification PEPM 4.2.17 Supplier Deviation Requests PSQM 1.2 and 1.3 Supplier Nonconformances The checklists used for these activities ( ATR-22 thru 27, 46, 31 and 34 respectively) were satisfactory.

The audit identified

nonconformances, eleven of which were corrected during the course of the audit and required no further action. One nonconformance was that a few c,uppl i e r quality program audits had not been reviewed by specified individuals and another stated' that there was no procedure providing for QA review of surveillance plans as required by Bechtel manual NQAM policy QGG-72.

A nine member team conducted the audit July 13-17, 1981.

The audit report stated that the Bechtel supplier quality area had not been completed to the depth planned but that this would be undertaken in a subsequent audit. Three nonconformances were identified for corrective action and an additional 59 were corrected during the audit for which the audit team required no further action. One nonconformance was that review of quality surveillance reports had not assured the description of tests witnessed by the supplier quality representative.

During August 1981, a three man team conducted audits in the procurement supplier quality department, San Francisco and the departments of materials and quality services, and codes and standards, Walnut Creek, California.

The audit at San Francisco was performed to verify compliance to commitments selected from the project supplier quality manual using fifteen checklists. The team found the overall implementation of the program to be adequate. Five nonconformances were identified, two of which were corrected during the audit. One concerned failure to impose l a shipment release hold on Continental Disc Corporation when two audit l finding reports had been documented on the contract activity.

l The audit at Walnut Creek was also to verify compliance to commitments for the Grand Gulf Project.

Five nonconformances were found, two being corrected during the audit.

One found that Pacific Calibration Services had not been audited and there was no programmatically controlled method to verify compliance with the purchase order requirements.

The audit report dated November 2,1981 covered the area omitted during < the July audit. The audit was to verify compliance of the procurement supplier quality department with the Bechtel procedures.

The four j member audit team identified seven nonconformances, four of which were . . * . .

! corrected duri1g the audit.

One nonconformance CAR 412, pointed out that a prime supplier, EXXON, authorized a fabricator, Portland Engineering, to use revisions to special process procedures that had not been approvad by Bechtel; although this deficiency had been identified by Becntel, the audit team found that the corrective action had not included an engineering evaluation of work performed to those unapproved procedures.

The qualifications of audit personnel were reviewed.

They were well qualified and their records of training and audit participation were all up to date.

e.

Audits of Mississippi Power and Light Company Audits are conducted by Middle South Services periodically on MP&L both at the Grand Gulf Nuclear Station and at the general office. The scope of the audit is primarily a review of documentation to verify that MP&L quality assurance activities are being performed and documented in accordance with the applicable QA program requirements and implementing procedures. Audit reports by Middle South Services were examined. The most recent audits had been conducted at Grand Gulf May 19-21, 1981 and at the general office June 2-5, 1981.

The team consisted of three auditors and a quality assurance representative from MP&L.

The audit team conclusion was that MP&L QA program is being satisfactory implemented and appeared to be effective in the areas audited.

Five deficiencies were identified; one was that MP&L has no QAP which addressed performance of procurement source inspection by MP&L personnel.

This source inspection is now conducted by the QA Field / Operations supervisor who reports directly to the Quality Assurance Manager. The procedures governing source inspection QAP7.20 and 7.30 are now in effect.

Within this area, no violations or dev.ations were identified.

8.

Audits (350608) a.

Audit Program The inspector examined the following controlling PSAR, QAM section; corporate QA procedures; and American National Standards: PSAR, R1, Section 17.1.18 Audits CQAM, R6, Policy 10 QA Audits 0QAM, R2, Section 18.0 Audits QAP 2.40, R5 Indoctrination & Training of QA Personnel QAP 18.00, R1 QA Audits Planning & Scheduling QAP 18.10, R6 QA Audits QAP 18.12, R1 Supplier QA Audits

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ANSI N45.2.12 Requirements for Auditing of QA Procrams for Nuclear Power Plants ANSI N45.2.23 Qualification of QA Program Audit Personnel For Nuclear Facilities MP&L QA program provides for audits to assure effective implementation of the program and prompt correction of deficiencies. The licensee has an active QA group with representation in their general office and at the construction site to monitor and audit the various participant's activities as well as those of their subcontractors and vendors. MP&L audits Bechtel for compliance with their own QA programs, applicable criteria, and requirements.

Bechtel as MP&L's agent similarly audits General Electric and participating contractors, subcontractors, and vendors on a selective basis.

The contractors and General Electric, in turn, have responsibility for regularly scheduled audits of their subcontractors and vendors.

, l Audit schedules (projected and completed) for the year 1980 and 1981 were examined and the Program and QA Audits Coordinator (P&A() was interviewed to ascertain that the licensee's audit program encompasses all internal and external organizations and extends to all elements of ( the QA program at a reasonable frequency.

This discussion revealed l that MP&L's QA section has recently written CAR #396 against itself for I failure to audit some line items (called MAP References) that were f missed by MP&L auditors for some reason or another within the scheduled time frame. To prevent recurrence the licensee has revised QAP 18.00, paragraph 3.e.2, requiring a feedback mechanism or notification to the P&AC of missed MAP References no matter what the reason. A new audit schedule was reissued and the missed MAP References have been rescheduled for the first quarter of 1982.

The audit team size, composition, and use of specialists routinely assigned from other organizations was discussed with QA management. The inspector examined the auditor training, experience, and certifications of MP&L auditors who participated in the audits examined in paragraph 8.b and found the auditors all qualified to applicable procedure and ANSI N45.2.23 requirements.

b.

Audit Reviews The following audits and respective audit plans were examined to determine applicability to the QA element audited, qualification of audit team members, that audit findings were reported to upper management and the organization audited, that corrective actions as required are being initiated, and that there is followup and re-audit by QA as necessary:

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MAR 80/99 Bechtel Field Procurement MAR 80/42 Bechtel QA Audit Schedules and Audit Reports MAR 80/67 Pittsburg Testing Laboratory MAR 80/73 Bechtel Field Engineers Control of FCN's/FCRS - Instrumentation Audit No.19 Bechtel Construction Implementation Audit - Checkout and Turnover Organization Audit E80-6 General Electric Co., Wilmington N. C.

(Conducted by MP&L and MSS) Within this area, no violations or deviations were identified.

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