IR 05000445/1985014
| ML20238A343 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/10/1986 |
| From: | Barnes I NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Johnson E NRC |
| Shared Package | |
| ML20237K807 | List:
|
| References | |
| NUDOCS 8708200454 | |
| Download: ML20238A343 (2) | |
Text
.
.
.
..
- _ _ -.
'
- ** " * %
UNITED STATES y-
$
NUCLEAR REGULATORY COMMISSION i
I neckm av
'%,,,,, /
t 011 RYAN PLAZA ontVL SUITE 1000 f_
ARUNoToN,TEXA8 Mn1 i
'JLDI I o fM6 l
NEMORANDUM FOR: Eric H. Johnson, Director, Division of Reactor Safety
-
/
& Projects
,.
,
T. F. Westerinan, Chief. ReactorInfety Branch Y THRU:
FROM:
Ian Barnes Chief, RIV Comanche Peak Task Group SUBJECT:
WELD ROD CONTROL FINDING -- NRC INSPECTION REPORT l
50-445/85-14,50-446/85-11(APPENDIXD)
/
It was brought to y attention by Tom Westeman that Shannon Phillips had asserted that someone other than the inspectors had dropwd a violation regarding weld rod control from paragraph 7 of Appendix ) of the subject report. In that I was the reviewer apparently alluded to in this assertion, I believe it is appropriate that I respond relative to the actual circumstances that led to the dropping of the citation.
1.
On review of the report submitted by Shannon Phillips, I noted that he had closed out a previous unresolved item on weld rod control (446/8502-01) based on (a) extensive review of the subject by the NRC Technical Review Team, and (b) a Region IV inspection in the
-
report inspection period which identified no violations or deviation.
See document identified by Shannon Phillips as 3.b. page 57. When I reached paragraph 7 in y review. I noted that a violation was identified regarding loose and missing labels on canisters of Sandvik electrodes. See page 81 in document identified by Shannon Phillips as 3.b.
2.
I contacted Shannon Phillips and informed him that the report was unacceptable on this subject; 1.e., closing out an unresolved item on weld rod control based in part, on a current Region IV inspection showing no findings and then having a proposed violation on the same subject in the very same report. During this conversation. I told.
Shannon Phillips that either his unresolved itas be left open if a violation was truly believed to exist, or the violation be dropped.
In addition, I inforined Shannon Phillips that I believed the proposed tolation w somewhat questionable in that the Region IV inspector tated in the report that the material was still S annon Phillips informed me that he would discuss
,
.
the matter wit bnd would then get back to me.
U
.
l 8708200454 070312 PDR ADOCK 05000445 G,
,
-
-
-
)
. _ _ _
_ _ _ _ _ _ _ _ _.
___
,
.
l-2
!an Barnes 3.
Shannon Phillips contacted ater stated that he had discussed the subject with nd that they had decided to drop the violation. I han Phillips at that time that I did not want the subject dropped, in that labels should not be coming loose from electrode canisters. I reconnended that the matter be referred to Brown and Root Welding Engineering (
for followup. This referral was then documented in the report.
Subsequent to issue of the report I checked with Shannon Phillips
-
l to assure sayself that he had contacted Brown and Root on the subject.
'
+-
He answered in the affirmative.
-
4.
In sunmary, the violation was not dropped by "someone other than the inspect er by Shannon Phillips with the apparent
"
'
I personally did not discuss the subject agre with t any me.
!
/m Sw-H i
fan Barnes, Chief RIV Comanche Peak Task Group
\\,
.
l l
l l
l l
\\
I l
l l
l l
l'
,
I
. -.
.....
....-
........
...u vsa
I, E[goass, g
.
UNITsD STATES
<
NUCLEAR MEGULATORY COMMISSION
.
$
.
WA8MH,07oh, o, C,3e666
\\....
JAN 15 1935
-
.
.
Docket Nos. 50 445 50-446
,
,.
MEMORANDUM FOR: Vincent 5. Noonan, Directed ~
Comanche Peak Project Division of Licensing Office of Nuclear Reactor Regulation FROM:
Srian K. Grimes Director Division of Quality Assurance, Vendor, and Technical Training Center Programs
.
Office of Inspection and Enforcement
SUBJECT:
QUALITY ASSURANCE REVIEW, COMANCHE PEAK
,
Your memorandum of September 30, 1985, on the subject above, requested the following IE actions to confire the adequacy of the Cananche Peak QA program:
,,
'
,'
1.
Review the cur' rent quality assurance program description delineated in Section 17.1 of the FSAR to detemine its adequacy in meeting the NRC quality assurance requirements which were in effect at the time of CP
.
issuance.
2.
Determine what actions 7U0C0 has recently taken to assure themselves of the adequacy of the quality assurance program.
' Discuss with Region IV personnel (and review pertinent inspection reports)
3.
the scope and detall with which the region has implemented the IE con-struction inspection modules to determine the adequacy of faplementation of the TU0C0, quality assurance program.
~
,
'4, Review of the third party CPRT Umbrella QA program.
This memorandum is in response to your request. Each of the four items requested in your September 30, 1985 assoran6um is discussed below.
Item 1 requested that It review the current QA sregras description (QAPD) for Comanche Peak (found in FSAR Section 17.1 through Amendment 55 of July 19,1985)
to determine its adequacy in meeting the NRC QA guidance in effect when the CP was issued.
Prior to receipt of your request, It was alrea$ comparing the
.
,
e' '
.
_ _ _
_
a
_ _ ___
.
-
...
...
.
.
,
f
.
Vincent S. Noonan-2-
,
.
current 0APD with acceptance criteria of the latest NRC Standard Review Plan
.(NUREG-0800, July 1981, Section 17.1, Revision 2). This review.was conducted against the latest $RP in accordance with NRR Office Letter No. 2 of April 28,
' 1982; however there is no NRC requirenrnt that the QAPO be upgraded to meet these additional controls. $1nce the F5AR states that the Gibbs & Hill and Brown & Root GA programs conform to the overall TUGC0 QA program, the review focused on the TUGC0 QA program and did not provide an essessment of the principal contractors.
,
048 took the following actions in response todtin 1 of your September 30, 1985 memorandum:
'-
1.
The current QA program description for CPSE3 desi n and construction in FSAR Section 17.1 (through FSAR Amendment 55 dated Jul 19,1985) was reviewed-against the guidance in effect at the time the R was docketed (October 3 1973 draft guidance). The review showed that the pmsent QA program description compiles with this guidance except for 18 items.
- These 18 items were not unexpected in that, at the time of review for
-
.
CP, the October 3,1973 draft guidance document was used by the QA Branch reviewers to assess the QA program description in a " balanced approach;"
i.e., there was no requirement that each item specf fied in the guidance be addressed specifically by the applicant and each of its principal contractors.
[
2.
In addition, the current QA program description for CPSES design and
%,
construction in FSAR Section 17.1 (through FSAR Amendment 55 dated July 19, 1985) was reviewed against the current guidance of the NRC Standard
.
Review Plan (NUREG-0800, July 1981, Section 17.1 Revision 2). The review showed that. the present GA program description complies with this guidance except for 65 items.
3.
As a result of the items addressed in paragraphs 1 and 2 above, the QAB staff extended the evaluation to a review of the controls in quality-related regulatory guides and ANSI standards coenitted to in the CPSES FSAR and in implementing procedures to determine if additional controls exist in these comitments that would resolve these items. This effort included reviewing the QA implementing procedures at the site and discussions with
.
Region IV and CPSES personnel at the Aegion IV office and the CPSE5 site.
The results of these actions. including the identification of the 18 and 65 ftems, have been documented and are on file at the QA tranch. Based on i
this review we find that these items (respectively 18 against prior guidance
'
.
and 65 against current guidance) are adequately resolved by the added con-trols in CPSES implementing procedures and FSAR commitments to regulatory guides and AN5! standards, with the exception of Act completely meeting Id quality assurance regulatory guides which were issued after the construction docketed date.
,
There is no NRC requirement to coenit to these quality assurance regulatory
'
guides since the CPSES construction application was docketed prior to issuance of these guides. However, there is a TUGC0 comitment to meet earlier versions of eight of these regulatory guides which were in effect
at the time of docketing.
.
We.
.
.
..
,.
. _
.
...
....
.....,.
_...
_____________.____ _ - _ _ _ _ _ _ _-_-
'
.
.
.-. ::
. n..
r.. -c :. m i %
%, a i
/
.
'
The six other regulatory guides, which are not comitted to by TUGCO are:
1.37 (endorses Na5.2.1
"QA Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants") 1.38 (endorses N45.2.2
"QA Requirements for Packaging. Ship!,fng. Receiving. Storage, and Handling of Items for Water-Cooled Nuclear Power Plants").1.39 (endorses N45.2.10 - Requirements for Water-Cooled Nuclear Power Plants"),1.74 (endorses N45.2.30
" Quality Assurance Tems and Definitions") 1.9,4 (endorses N45.2.-
" Quality Assurance Requirements for Installation, Jespection, and Testing of Structural Concrete and $tructual Steel duringrthe Construction Phase of Nuclear
'
Power Plants"). and 1.116 (endorses N45.2.8'
"QA-Requirements for Installation.
Inspection, and Testing of Mechancial Equipment and systems *).
Five of these l
sin guides are more oriented toward the technical controls of structures, systems.
components.and disciplines normally addressed in other sections of the SAR. In the development of these six regulatory guides, it was determined that the endorsed controls were not of such significance snat backfitting should be required. It is worthwhile to point out, however, that the more important QA programmatic controls
-
l described in these five regulatory guides, including most of the definitions in regulatory gutde 1.74, are provided in the Comanche Peak QA Program.
,
'
Item 2 of four memorandum requested that IE determine what actions TUGC0 has recently taken to assure itself of the adequacy of the CPSES QA program. A sumary of these actions is provided in Enclosure 1.
'
Item 3 requested that IE discuss with Region IV personnel the scope and detail j
with which the region has implemented the IE construction inspection modules to i
'
determine the adequacy of implementation of the TUGC0 QA program. (Wewerein-
-
formed through your office that your consvitant is reviewing the pertinent
inspectionreports.) Region IV construction inspection activities were discussed at Region 1Y and the results of its coverage of Comanche Peak were l
presented in the form of viewgraphs. This material is provided in Enclosure 2.
i
'
A separite andum will be forthcoming from Region IV addressing this subject in r Mt414.
~~
'
~'
Item 4 requested our review of the third party CPRT Umbrella QA program.
We have completed this review and the results have been documented in my memorandum to you dated January 6.1986.
.
.
2-
_
%
Brian K. Grimes. Ofrec r Division of Quality Assurance, vendor, and Technical Training Center Programs Office of Inspection and Enforcement
faclosures: As stated I
.-
.
I
_
__ _ _ _ _ _ _ _ _. _ _ ___________-___________
____
_ _ _ _ _ _ _ _ _ _ _ _
.4
. --
.::.:
'*.-E-i *. E I T u l it.cc; 004
.
.
.
-
Distribution DC5 QA8 Reading
QAVT Reading I
RVollmer. IE
.
SKGrimes, IE GTAnkrum, IE TWesterman, RIV
/
,-
JLMilhoan, IE
-:
J0011 ray, IE
"-
-
J5prawl, IE DEisenhut MRR
STreby, ELD 1, Chandler, ELD j
!
AVietti-Cook, NRR
-
JCalvo, NRR
<
1.Shao, NRR.
.
-
HLivermore NRR
CHale, RIV
-
j
.
ELJordan IE
,
.
ENJohnson,, RIV RFHeishman,' IE E8elke,IE r
-
.
u
!
l
.
.
85ee previous concurrence d
g
- QA8:QAVT
- QA8:QAVT I'
,fM4 *C:RCP8:DI
- QAVT JG11 ray JLM11hoan TWesterman RFNetshman nkrum
'
1/ /86 1/ /86 1//L/46 1/ /44 Y86
/86
,
&&
e 3 me p6e
- _ _ - _ _ _ _ -
__.
.
I
. _.
.
.......
12';~ 56 15:16
' A*-EAIT 1 JEST-L'1 10.001 005
l
.
'
.
4
)Istributien
)C5 QA8 Reading
,
Q4VT Reading
RVollmer, IE BKGrimes, IE GTAnkrun, IE
/
i TWestatsan, RIV
.
'
,,,
JLMilhoan, IE s_
-
.
JGGilray, IE
J$praul, IE l
DEisenhut. NRR 5freby, ELD LChandler, ELD AVietti-Cook, NRR JCalvo, NRR L5hao, NRR
.
HL{vefmore,NRR CNale, RIV
ELJorden, IE
.
4tGen4ee, RIV g RFHeishman' IE
-
,
"s.rt Chseg
.
t i
i
.
l l
l
<
s
,
J, $n RIV C:RCPB:0!
C:QAs:QAVT 0:QAVT VT flhoen TWestersan RFHeishman GTAnkrum SKGrimes JGilray 1/;./46
/86 1/ /S6 1/ /86 1/ /86 1/ /86
--
_ -- -
-
-
---
_
_. - - _ _ _ _ -- __-
k
..
..
....
..,.._..
.... -
e..
.
..
Enclosure 1
,
,
.
W.'O. Counsil. TUCC0's Executive V.P., Nuclear Engineering /85 action and Operations, described to the NRC Staff at the Region IV office on 10/3 initiated to assure the adequacy of the QA program at Comanchs peak. TUGC0 advises us that they intend to develop and implement these actions on the ongoing Cp5ES project. Highitghts of these actions are,es follows:
Evaluated the current QA program which'filuded reviewing the FSAR Chapter -
17 QA program, the taplementing QA p1'an and QA programs of the major contractors and identified where improvements are warranted.
- Emphasized the vender surveillance program by increasing the inspection efforts in this area.
'
Streamlined the QA orgenlaation to make it more effective.
'
Increased the Dallas audit staff by 3.
.
A'esigned 5 technical personnel to the Quality Engineering Department
"
,
Reorganized the Dallas QA office.
'~
Improved the control of procurement.
I
'
"
'
Established a single point of contact in purchasing for conducting vendor audits.
Consolidated the vendor shop inspection activities seking them acre effective.
- Established improvements in the training of auditors which include:
"
A 2 week hands on training course in maintenance
A 2 week hands-on training course in instrumentation and controls
A 3-to 4-week training course at an operating plant
Established a training program that crosses lines of technical expertise to allow an interchange of job assignments.
- -
!aproved the effectiveness of procedures and revisions thereto through consolidation and streamlined the method of review and approval.
- Increased the emphasis and importance of the correct 1ve action system.
Upgrade.1 the Level ! inspectors to Level II and required certifications to be performed by e Leve) !!!.
.
_ _ _ - _ _ - _ _ - - _ _ _ _ _. -
.
.. -. :-:..< :.
w,ee.
ce
.....
.....
.
':
'
.
.
.
.
t
Enhanced the training program for QA personnel.
"
Coguterize questions to be randomly selected for tests.
Formalize lesson plans.
"
"
Verify experience and education of new employees within 30 days.
Placed additional emphasis on the preparation and c' ntrol of startup
o
'
activities.
,
,,,
'
Modified the trending p m gram.
-
"
Changed free quarterly to monthly reporting.
,,
"
Top management actively involved in use of trending reports.
Improved method of identifying and reporting trends.
"
.
Initiated developpunt of QA topical report for CPSES operations.
,
,
'
~
Modeled after Northeast QA topical which has been tested and proven
"
to be effective.
,
Will provide improvements in the hierarchy of procedures, design
"
change controls, and the cross indexing of procedural controls and
-
(.
policy statements.
- Topical will be submitted after Unit 1 is licensed.
"
.
.
O
.
.
ea
.
....:
.e.t.
we: :...
w.ea en "-
,_. __
-
,
.
.
..
,-
..
Enclosure 2
'
'
a:
.,
-
-0A/0C INSPECTIONS PERFORMED CONSTRUCT 10N/ TESTING
.
'
THERE HAVE SEEN MORE THAN 274 INSPECTIONS SY REGION IV W THE APPLICANTS CONSTRUCTION / TEST]NG PROGRAM. THESE INCLUDED IRILTIPLE DISCIPLINE INSPECTIONS OF THE FOLLOWING ACTIVITIES:
)
/
04/0C PR00mM j
-
,.
.
.-
'
- CIVIL.5TWCTURAL CONSIRUC[1DN
!
IECMANICAL CONSTWCTION
-
ELtCTRICAL CONSTRUCTION
.-
.
- TESTIM Pt00 RAM.
-
3,
-
..
A REVIEW OF THE MC2$12 IN5PECTION REPORT 766 OATA INDICATES APPROXIMATELY 905 0F THE IE PRESCRIBED PAGORAM WAS COPPLITED ON
-
.
UNIT 3.. THE UNIT 2 MC 2$12 PROGRAM l$ STILL IN PROGRESS.
_
.
THERE ARE 4.196 $PECIAL INSPECTION HOUR $ IN EXCESS OF SC2512-REQUIREMENT 3.
THESE SPECIAL INSPECTIONS INCLUDE THE RIV 200M
-
TURNOVER !@ECTIONS, RlY REGIONAL ASSES $MDfT TEAM 04/0C INSPECTIO
"
IE CONSTRUCTION ASSESSMENT TEAM INSPECTION AND THE SPECIAL REG
-
CONSTRUCTION INSPECTION. THE TRT EFFORT l$ EXCLUDED FROM THl$ TOT A REVIEW 0F THE 766 DATA FROM 19T/ TO THE PRESENT INDICATES OVER
.
30.000 NOUR$ F INSPECTION WERE PERFORMED ST REGION IV 0F THE APPLICANTS CON $TRUCTION/ TESTING PROGRAM.
{
.
s.
WRm8 O
e
.
'
.
)
i
.
.
'
- 1 ; H
- n-n-:-Eeit uEi
.z.
-
rc.ocI 002 l
,
'
'
..
,.
,,
,,
-
.
'
..
.
WRC (CONSTRUCTION) INSPECTIONS PERFORMED MC 2511 AN02512
,
'
.
a 1973 - 1974 (MC3511)
$
PRICMSTRUCTION PERM 11 (IHITIAL CA INSPECTION)
.
. :
.
FOLLOWUP I G ICTIONS
, ' "l,,,
.
1975 - PE$ENT
'
SUBJECT PROCEDURE INSPECTIONS PERFORMED
,
.
CONTRACTOR SURVE!LLANCE 35020 1978. 1984, 1985 $CHEDULED
"*
REVIEW OF @ MURIAL 35100 M INSPECTIONS $!NCE 1973
MID TERM QA' INSPECTION 35200 1974 - COPFLETED
-
.
\\
0A 92501PLINE-
.
INSPECTIONMODULES(20)
$0+ INSPECTIONS PERFORMED
.
.
D($1GN CHANGE 40NTROL 37996 1980. 1982 $1T
.
D($19NINSPECTION 37995 TWICE IN 1982 and 1982 $1T ONS!TE DESIGN ACTIVITY 37055 TWICE IN 1981. 1982 SIT ONCE IN 1984
,
AS-SUILT YtRIFICATION 37051 1964
' PROCUREMENT RECE!VING 35065 NO 766 RECORD OF INSPECTION BUT WA$ COVERED IN:
-
.
AND 1964 R]! $PECIAL INSPECTION. SCHEDULED -
1985 RIV
'
ENGINEERING SERVICE 35960 1982 5IT ORGAN!!Afl0NS EVEUAfl0N TWlCE IN.8884
-
SCHEDULED 1965 MANAGEMENT OF @ ACTIVITIE$
35060
, 1984 RIV INSPECTION 85 32/11
,
A S ALjp INSPECTED IN:
1963 85 44f 1983 RIV RAT.
AND1984R!l$PECIAL IMPECfl0N.
1N. DEPTH QA INSPECTION 35061 1964 RIV C0petETED THl5 Pa0CEDURE; HOWEVER. ALSO
)
COVERED IN 1983 IE CAT.
{
1983 RIV RAT AND
134RI!sPEE!ALINSPECTlot
-
i it8s sCNroutro
-
.
-. - _ - _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _
. = * *.
4 L*
....
..'.
'
+..
e gg, wwg.
Us' r
..,
...._.....
.
.
..
..
,..
,
-
..
,
'
~
5PECIAL INSPECT 10NS OF THE APPLICANT'S QA PROGRAM
.
THE NRC PERFOINED SEVERAL SPECIAL PROGRAP9% TIC QA INSPECTION $ A$ FOLLOWS:
)
1982 SPECIALINSPECTIONTEAM(REPORT 82-26/14)
l
)
e 1983 EPECIAL ICE INSPECTION (REPORT 85-15/09),.
l
1983 CAT CONSTRUCTION ASSESSMENT TEAff(REPORT 83-18/12)
'
1983 RAT-REGIONAL ASSESMNT TIM (REPORTR3-23)
'
1963 RIV CAT FOLLOWUP (83-24/J5; 84-28/14)
'
1964
$PECIAL ltEGION II IllSPECTION (REQUESTED BY 80tR)
)
-
M 1964 TRT-NRC TEOct! CAL REVIEW TfAM (WREG 0707.. SUPPLEMENT $ 7-11),
)
,
,
.
-
,_
,
NO CREDIT WAS TAKEN IN THE 766 SYSTEN FOR THE$E $PECIAL INSPECTIONS UNDER
THE IE QA MANUAL CHAPTER $. THEY AL$0 SATI5FY IE MANWAL QuPTER REQUIREMENTS
'
,_
IN 1982,1983. AND 1964. AND ARE LISTED ABOVE UNDER APPROPRIATE 15tC INSPECTION
.
PROCEDURES. 90MIT WAS TAKEN FOR TRT.NRC TECHNICAL REVIEW TEAM (NUREG 0797,
- -
suPPLEntwr711) Err 0RT.
O e
e
S J
..
._
-
-
.
e
'
t
.
.
,
i
.
_.
_
-
--
-
-
.-
-
g
es.-E.:.i uEi m.;
'C.002 E
,,,
'
..
....
.,,
'.
'
.
...
,.
' ',
- .
,,
t
,
.
SIRC PREOPERAT20NAL AND TEST INSPEsiiONS
'
.
It NC 2532. 2314. PPI-25.5
.
TME POLUMINC INSPECTION NDDULE8 EAVE BEEN 00ftPLETED POR 'C
,. -
.
.
A.
18HC 33301
. y,- -
tlUALITY A8803ANCE'FOR)R20PERAT10 MAL TESTINC 5.
IBMC 33740
- PROGRAN - E /QC ADN1NISTRAT10N c. ItWC 35741
- > pt003AN - AgDIT8 W
!
D.
E mc 35746 4A PageRAM 730CRIMENT CONER01,
!
2.
IBMC 35747 44 PROGRAW - Rect!PT, 3203A03, AND RANDLing
!
0F 9llR N Brr AND sultar4Ls
.
'
P.
1 ENC 35748 4A P300RAN - R3005D8
)
4A PROGR M = DOCEBSNT 00WTRdL
{
9.
Imc 35742
-
,
~
44 7800RAN - MAINTEN S CE
)
5.
1EMC 33743.i
-
I
.
1.
IENC 337A4
- .
4A P900 BAN = 95810N CR2028 AND 4WOIFICAT10N J.
1 ENC 33745 4A PROGRAN - SURTE1LLANCE TR$ TING l
E.
1 ENC 35749
.
4A PROGRAN * TESTS AND EEPER!pSNTS
'
"*
L.
1 ENC MT50
-
44 PROGRAN - Tttf AND ISASURAMENT SQUIPMENT llOTES:
,
1.
ITDts 8. TIRD L. ARE D0ctaSNrED IN 3RRC INSP2CT10N REPORT 30-445/84-31 3.'
ITDI A. R$ DOCUMENTED IN NRC INSPECTION REPORT SA45/83 42 AND 84-15,
AND WAs A171gWED ST TER TRT ($tt SER 87)
3.
THE IMPLDitNTATION OF TB %/QC PROGRAN 11A8 ALSO CONTINDO
!
THROUCMOUT Tut IDic 2313' PROGRAN DUR150 PtoCtDURE REv i
AND RESULTS EVALDATION.
.
O
- 8
.M I
j e
I
,
{
.
l
)
.
!
,
a
{
f5-n FS-$'
Arcs 7
)
-_ _ _ _ _ _.. _ _ _ _ _
__ _- _ _ ___-__ _ __-_-_ - _ - - _
--
- l t
t
-
CPSES/FSAR
,
17.1.17 QUALITY ASSURANCE RECORDS The TUGC0 Quality Assurance program establishes procedures and 50 -practices'to assure that TUGC0 and its contractors have a quality a
records system'which provides documentary evidence of the performance of activities affecting quality. Procedures assure or shall require:
/
,.
1.
That records that are' required to be ma htained show evidence of
,
performance of activities affecting quality. Typical records maintained include quality assurance programs and plans,' design data and studies, design review reports, specification.
e f
procurement documents, procedures, inspection and test reports, material certifications, personnel certification and test reports, audit reports, reports of nonconformances and corrective actions, as-ouilt drawings, operating logs, calibration records, maintenance data, and failure and incident reports.
2.
'That inspection and test records, as-a minimum, identify the date of the inspection or test, the inspector or data recordf.r the type of observation, the results, the acceptability, and the
,
. 50 l action taken in connection with any deficiencies noted.
3.
That records are protected against deterioration and damage.
4.
The criteria for determining'the classification of the record as well as the length of the retention period.
5.
The method of identification and indexing of records for ease of retrievability.
6.
Responsibility for record keeping during design, fabrication,
'
construction, preoperational testing and commercial operation.
l-l 7.
The method of transfer of records between organizations.
L 17.1-40 l
' JULY 19, 1985
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ -
._ __-__ _ _ _
_
l
-
'
.
CPSES/FSAR
.
TUGC0 verifies conformance to the record requirements by reviewing contractors' quality assurance methods for record keeping, by auditing contractors' systems when functional, and by selective review of quality records for completeness and accuracy.
The permanent on-site record storage f acility is constructed of i
reinforced concrete, concrete block, masonry 3 or equal construction. A concrete floor and roof with sufficient sloiHr-for drainage is provided.
j A sealant is applied to walls, floor, and foundation. All entrance and exit doors are fire retardant type. A closed loop forced air l 50 I
i circulation system to control temperature and humidtty is provided.
.i Dry chemical or gas fire extinguisher:; are provided.
k Standard steel cabinets and metal shelving are used inside the storage f acility to contain records and files. Access to the records facility is kept controlled so that only authorized personnel have access to the records area.
17.1.18 AUDITS
]
TUGC0 requires that planned and periodic audits be performed to verify j
compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. TUGC0 QA performs such
,
'
audits on Westinghouse, Gibos & Hill, Brown & Root, other TUGC0 organizations, and others as necessary to provide an objective
,
evaluation of the effectiveness of their programs; to determine that their programs are in compliance with established requirement, methods,
'
and procedures; to determine quality progress; and to verify implementation of reconsnended corrective action. The TUGC0 audits,
!
Doth internal and external, are conducted primarily by members of the Quality Assurance staff. Consultants will be utilized by TUGC0 on audits as required.
As part of the Quality Assurance program TUGC0 QA:
l29
17.1-41 JULY 19, 1985 i
.
-
_ _ _ _ _
_
J
- FS-/4 FS-o A TC // 0 t
,
.
- -, - -, - - - - - - - - -,----------,-- - - - ----- ------ - - - - ----,- --.. ---,--------------------- - - - - - - - --- ---- -------,---
-
s M
'
i
~
___..