IR 05000461/1985037
| ML20134A079 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 08/08/1985 |
| From: | Jablonski F, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20134A054 | List: |
| References | |
| 50-461-85-37, NUDOCS 8508150176 | |
| Download: ML20134A079 (32) | |
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-461/85037(DRP)
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Docket No. 50-461 License No.~CPPR-137 Licensee: . Illinois Power Company 500 South 27th Street Decatur, IL .62525 Facility Name: .Clinton Power Station, Unit 1 Inspection At: Clinton Site, Clinton, IL Inspection Conducted: July 10-12, 1985 Inspector: 9.).hlonskid M ia F. 8@ 6 Date Approved B k* ief 8- f- PJ Reactor Projects Branch 1 Date Inspection Summary Inspection on July 10-12, 1985 (Report No.50-461/85037(DRP))
Areas Inspected: Routine, unannounced inspection concerning allegations and resolution of open items.~ The inspection involved a total of 20 inspector-hours onsite by one inspector.
Results: No items of noncompliance were identified. No items significant to plant safety were identified.
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8508150176 850812 PDR ADOCK 05000461-G PDR
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, DETAILS
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1. Persons Contacted Illinois Power (IP)
- D. Hall, Vice President
- W. Connell, Manager of QA
- H. Daniels, Project Manager
- J. Loomis, Construction Manager
- J. Perry, Manager of Nuclear Programs
- F. Spangenberg, Director of Nuclear Licensing
- J. Sprague, Licensing Project Specialist
- R. Weber, Supervisor of Quality Systems Baldwin Associates (BA)
- L. Osborne, Manager of Quality and Technical Services
- J. Thompson, Supervising Quality Engineer Other personnel were contacted during the inspection as a matter of routine.
- Designates those who attended the exit meeting on July 12, 1985.
2. Followup on Open Items (92701)
(Closed) Open Item (461/84037-03): Criteria for termination of over-inspection not defined. During the management meeting held in October 1984 between IP and RIII, IP proposed the termination of piping and mechanical supports from the ongoing overinspection program. During the meeting it was stated by RIII overinspection was intended by IP to be a continuing activity. IP had never defined the criteria for terminating overinspection of any commodity. IP responded to RIII with criteria, 1 data, and answers to RIII questions. RIII reviewed IP's input and concluded in a letter to IP on July 2, 1985, that the pre-established i criteria proposed by IP was not suitable for terminating overinspection of a commodity on a generic basis. RIII agreed to review termination of commodities on a case by case basis. Other documentation relevant to this matter includes IP letters U-0828 dated March 29, 1985; U-600008 dated April 19, 1985; U-600163 dated June 14, 1985; and RIII letter dated April 11,1985.
" This matter is closed.
The inspector reviewed other open items and Part 21 reports; however, the documentation was not complete or otherwise ready for closure.
3. Followup on Allegations (99014)
(Closed) Allegation (RIV-83-A-0072) (#100): Qualification screening for MATSCO was inadequate and personnel were sent to sites before their qualifications were verified. This allegation was previously discussed l
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O in reports 461/84040 and 461/85018. During the previous inspection it was unclear to the inspector how MATSCO subcontractor personnel could have their previous employment and education records verified by meeting the requirements of (sic) NRC Rules 73.56 and ANSI /ANS 3.3. Verification of employment and education is necessary to meet certification require-ments of ANSI N45.2.6. It was also unclear to the inspector if MATSCO was an approved vendor (provider of testing services). During this inspection it was learned by the inspector that MATSCO does not have to be an approved vendor because IP qualifies and certifies testing personnel to an IP procedure. IP startup acceptance procedure SAP-7 requires that education and work experience of testing personnel be verified by a background check performed by IP or a subcontractor organization. IP dispatched a person to the MATSCO main office to verify that the MATSCO personnel on site had background checks completed. It was verified by IP that 17 of 18 MATSCO Clinton site personnel had been verified in accord-ance with Multi-Amp procedure MHR-105 " Security Screening of MATSCO Field Personnel". The eighteenth person's high school education could not be verified for a three month period and his GED could not be located from the school which granted it more than 20 years ago. The person has since retaken.the GED test and successfully passed. The inspector selected three of the seventeen records, which are now on site, and determined that an independent subcontractor to MATSCO had verified those education and experience backgrounds.
This matter is closed.
(Closed) Allegation (RIII-84-A-0189) (#111): An anonymous note was delivered to the Clinton site resident inspector's office on' December 20, 1984. The note read "To whom it may concern: Some people still care about the work they do and still care about safety. These people are tired of being intimidated by upper management. Signed: a concerned but scared BA employee". The note had three attachments including BA memorandum PHS-45-84, page 1 of Sargent & Lundy Form 30-B, and page 2-12b of Sargent & Lundy specification K-2882. Those documents indicated that the person was probably employed in the BA drafting department.
RIII notified IP of the allegation by letter dated April 2, 1985, and requested IP to make necessary audits and reviews to determine the validity of the allegation. IP notified RIII by letter on June 12, 1985, that their review was completed and the results were ready for RIII's review. Results of RIII's review are documented below.
The inspector noted that the allegation was simultaneously received by IPQA and SAFETEAM. IPQA did not conduct an extensive investigation; however, SAFETEAM did. The scope of the SAFETEAM investigation was broader than stated in the above allegation; however, specific SAFETEAM concerns appeared to be directly related to the allegation. The specific items were SAFETEAM Concerns 11535-A, 11749-A, and 11749-C, which are included as Enclosure 1 to this report. The inspector reviewed the concerns and verified that drafting supervisory personnel had been interviewed by SAFETEAM. SAFETEAM confirmed that the purpose of the memorandum was to avoid excessive review time of previously reviewed work. The inspector also verified that drafting personnel were inter-viewed by SAFETEAM to determine if they had been forced or pressured
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(intimidated) to sign drawings which they had not adequately reviewed.
None of those persons interviewed by SAFETEAM stated that they had been forced or pressured to sign drawings which had not been adequately reviewed.
IP documented the results of their investigation in memorandum Q-03516, R. E. Campbell to D. P. Hall, dated June 10, 1985, which is included in Enclosure 1 to this report. Based on the review of the SAFETEAM investigation the inspector concurs in IP's conclusion to close this matter because the anonymous allegation was not specific in nature and the SAFETEAM's investigation showed that personnel in the BA drafting department had not been intimidated.
This matter is closed.
(Closed) Allegation (RIII-84-A-0196-07) (#113): There is and will continue to be the vaulting of BA safety related piping and mechanical documentation with major technical deficiencies that do not comply with code, specification, or procedural requirements.
This allegation was originally inspected and closed out in Inspection Report 461/85008 wherein it was concluded that safety related documenta-tion was being placed in the vault without major technical deficiencies.
That conclusion was based on information provided by BA identified as attachments 1 and 2 to Inspection Report 461/85008. RIII received a letter from the alleger on March 11, 1985, wherein the alleger challenged the technical merits of BA's evaluations of his concerns. RIII notified IP of the new allegation by letter dated May 7, 1985. IP was requested to have BA resolve the technical issues and then review and approve BA's work. IP notified RIII by letter on June 26, 1985, that their review and approval was completed and the results were ready for RIII's review.
Results of RIII's review are documented below.
The inspector reviewed the results of BA's technical review and IP's review and approval of BA's efforts as documented in Enclosure 2 to this report. There were no substantive changes to BA's original position on the technical issues raised by the alleger. All of the changes made to the revised response were minor. The Document Review Group (DRG) has identified over 130,000 documentation deficiencies, that is, nonconform-
! ance with a code, standard or procedure. IP has determined that none of the deficiencies, including those which were hardware related, would have had a detrimental effect on the health and safety of the public even if l the deficiencies were not corrected. NRC inspections, including those
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conducted independent of Region III, have not found any significant deficiencies with piping and mechanical installations. Results of those independent inspections are documented in Inspection Reports 50-461/84035 (Independent Measurements - Nondestructive Testing of Welds), 50-461/84039 (Independent Design Review), and 50-461/85030 (Construction Appraisal Team). There is no reason for Region III to believe that piping and mechanical components and systems will not satisfactorily perform their intended safety function because of deficient documentation. It is therefore concluded that the original conclusion documented in Inspection .
Report 50-461/85008 is unchanged; safety related documentation is being i placed in the vault without major technical deficiencies.
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s Enclosure 2 is comprised of:
Memorandum to IP file from R. Weber dated July 12, 1985 (Technical Review)
Memorandum Q-00046 to L. Osborne from W. Connell dated June 21, 1985 (Review and Approval of NRC Identified Techncial Issues)
Letter LWO#23985 to W. Connell from L. Osborne dated June 4, 1985 (DRG Allegations - Response to NRC - Clarification and Resolutions)
Letter LW0#23085 to W. Connell from L. Osborne dated May 29, 1985 (DRG Allegations - Response to NRC)
Matrix of Concerns and Responses This matter is closed.
4. . Exit Meeting (93702)
The inspector met with licensee representatives (denoted in the Persons Contacted paragraph) at Clinton on June 12, 1985. The inspector summarized the scope and findings of the inspection and discussed the quality of open items and Part 21 reports presented for closure. The probable contents of the report were discussed with licensee personnel and no proprietary information was identified.
Enclosure 1 Reference of Allegation RIII-84-A-0189 Enclosure 2 Reference for Allegation RIII-A-0196-07
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Q-03516 June 10, 1985 TO: D. P. Hall, V-275 Vice President FROM: R. E. Campbell, V-92 3 -
f-Director - Quality Systems & Audits -
SUBJECT: Anonymous Allegation On April 2, 1985, the USNRC, in a letter from Mr. C. E.
Norelius to Mr. W. C. Gerstner, forwarded to Illinois Power Company an anonymous allegation. The NRC letter described the allegation as follows:
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"To Whom It May Concern:
Some people still care about the work they do and still care about safety. These by your management." people are tired of being intimidated
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Reference: 1. BA Memorandum PHS-45-84 2. S&L Form 30-B, Section 1.3 3. S&L Specification K-2882, Section bl.414 Upon receipt of the NRC letter, IP Quality Assurance initi-ated a review of the issue. Our initial review revealed that IPQA and SAFETEAM had received the same anonymous allegations on or about December 20, 1994. Due to the nature of the allegation, in that no specific concern is stated nor is there any stated concerns identified in the three (3) references, an extensive investigation was not conducted by IPQA. However, SAFETEAM informed IPQA that a recent concernee had raised a concern with the BA Memorandum PHS-45-84 and that this may be related.
Subsequently, IPQA's investigation focused on a detailed review of the SAFETEAM investigation and response. '(
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The conclusions of the IPQA review are as follows:
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The anonymous allegation is too general and could not be substantiated.
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Of the concerns received by SAFETEAM, only one item related to one of the reference documents was substant-iated.
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This matter should be closed based on the SAFETEAM investigation and response.
The documents supporting the SAFETEAM investigation and IPQA review are contained in the attached binder.
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Attachment cc: W. Connell, V-923 (w/o attachment)
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ILLINDIS POWER COMPANY IP CLINTON POWER STATION. P.O. sCX 678. CLINTON. ILLINOIS 61727 Dear Concern No. 11535?
You took the opportunity for a Clinton Power Station Safety Concern Review and shared your concern with the Clinton Power Station SAFETEAM. We looked into your concern and here is what we have found. In keeping with our promise to do our best to preserve confidentiality, we are using the concern number of your interview to address this letter. The computer produced your name and address. so only myself, the interviewer and the SAFETEAM accreta ry can match your concerns with your name.
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Concern No. Il535-A states: "Baldwin Associates (BA) isometrics a re not receiving an adequate review, and that people are being
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forced to sign isometrics without reviewing them."
SAFETEAM perf ormed a very indepth invest igation into this concern.
Numerous were people, including those mentioned in your concern, interviewed in trying to find out if anyone had been pressured or signed.
be forced into signing isometrics that they felt should not BA's Lead Design Review Engineer was interviewed and he said that he had never been pressured or forced to sign any isometric that had not received what he felt was an adequate review.
Baldwin Associate's (BA) Senior Field Engineer, Piping, was also interviewed and he also said that he had never been pressured or forced to sign isometrics before they had received an adequate review.
S e pa ra te interviews were conducted with BA's Assistant Resident Engineer and BA's Manager-TPRF/ Design Review /DELS and both stated that they had isometries. never forced or pressured anyone into signing BA's Resident Engineer and BA's Manager-TPRF/ Design Review /DELS were also asked about isometries not receiving an adequate review by the Design Review Engineers.
the majority of isometries did not Both require individuals an indepth saidreviewthat 3 i
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by Design Review Engineers because of the reviewBA's performed Assistant by the draftsman Resident andsaid Engineer the review of the that unless thechecker.
isometric was extremely difficult he only wanted a cursory review from the Design Review Engineers.
During the investigation, SAFETEAM found out that Procedure BAP 1.18 " Drawing Preparation" was being revised. SAFETEAM reviewed the procedure and realised that it was not definitive in specifying requirements and also did not reference BA Fora JV-1365 (4/84) which is utilised during the R. isometric Campbellreview. (IP-QA)
SAFETEAM brought this to the attention of Mr.
who said he would have someone in his review group look at the revision and make sure that the procedure is adequate prior to being approved.
In reviewing isometric RH-958 rev-3, which was mentioned in
your concern, no FCR's were referenced, Revision 3 was made on i1/8/84 per "K" drawing and BA review. Revision 4 was made on 11/13/84 per FCR's 30126 and 28593 and NCR 23739. FCR 28593 was written requesting a welding detail for an end closure plate and FCR 30126 was written concerning spec break differences which were resolved by Sargent & Lundy.
Thanks for sharing your concern with us. Your interest in helping Tilinois Power Company assure that Clinton Should Power you Station have any operatesfurther
safely and reliably is appreciated.
- questions about your concern or any other concerns you wish to share, please write me at thetoll The above address ornumbers free telephone call Clinton for l
Power Station SAFETEAM.
the SAFETEAM are 1-800-637-9231 if you are in Illinois and f
,j 1-800-637-9232 if you are outside T111nofs. You will reach
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our answering machine so please leave your concern number and telephone number so we can get back to you.
Sincerely
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! C. D. Clenn Director, SAFETEAM cc: Concern No. 11535-A STGTf00291 i
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DATE: January 7, 1985 STGTl 00393 To: T. Kubiak Coordinator, SAFETEAM (NAME REMOVED TO PROTECT IDENTITY)
FROM: W. Breeden Investigator, SAFETEAM SUBJECT:
SAFETEAM Concern No. 11749-A In talking with the concernee and showing him a copy of the letter written by Mr. Seidel concerning and his reason for leaving, did not have a concern. the concernee stated that he really was a f riend of his and when The he concernee quit it really upset stated him that M (concernee)
and he just needed someone to talk to.
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DATF- Ja nita ry 7, l ') R S STCT8 00416 TD- C. D. Clenn Director, SAFETEAM FROM: W. Breeden investigarnr. SAFETEAM SURJECT:
Response to SAFFTEAM Concern No. Il744-C Concern No. Il749-C states:
personnel have been instructed "Baldwin Associates by sup.rvision ro (RA) drafrine incorporare the Sargent & Lundy (S&L) comments associated with RA isometric *
without verffying the validity of the comments."
SAFETEAM interviewed the BA Drafting Supervisor and five (5)
drafting rating S&Lpenple, commentsrespnnsible onto the RA forisomet reviewing, rics. checking, and incorpo-The Draf t ing Supervisor said he wero not had to benot instructed his penpla that the S6L comments checked. The five (5) drafting people said that they had never been told nor to check S&L comments.
If you could supply SAFETEAM with additional information or speci fic f acts in t his and pursue your concern. a rea , S AFETEAM will re open t he inves t iga t ion
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July 12, 1985 TO: File -
FROM: Roger D. Weber Supervisor - Quality Systems This memo is to document conversation held between C. E.
Calhoun, IP, and myself regarding the technical review of allega-tions made by M C. E. Calhoun stated that a review of technical issues was performed by qualified Illinois Power Quality Assurance personnel in the Record Review Group.
This review generated several technical points of a minor nature.
These questions were later investigated and answered. This review resulted in no technical issues that required further investigation.
RDW/j sp (NAME REMOVED TO PROTECT IDENTITY)
E nc.)a.s u e e 2. PP. I-2'l A ileg. A Ill - 84 -o 196 - o'7
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) Q-00046 June 21, 1985 TO: L. W. Osborne, V-900 Manager - Quality & Technical Services Review and Approval of NRC Identified Technical Issues REFERENCES: 1. L. W. Osborne letter to W. Connell, LWO #23085, dated May 29, 1985 2. L. W. Osborne letter to W. Connell, LWO #23985, dated June 4, 1985 Illinois Power Quality Assurance has reviewed your response, contained in Reference 1, and the resolution to our comments, contained in Reference 2, associated with the subject issue.
As a result of this review, the Baldwin Associates resolu-tion to these issues is approved by Illinois Power Quality Assurance. .
f usef0&$ onnell Wi ager - Quality Assurance CEC /jsp I cc: D. P. Hall, V-275 R. E. Campbell, V-923 l
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. O b ALDWIN A S S O CI AT E S
- A JOINT VENTURE OF FRUIN-COLNON CORPORATION McCARTIN-McAULIFFE MECHANICAL CONTRACTOR, INC.
KEL50-BURNETT COMPANY POWER SYSTEMS, INC.
1211 EAST TOWER ROAD, SCHAUMCURG, ILLINOIS 60172 LWO#23985 June 4, 1985 REPLY TO1 P.O. BOX 306 cuMToN, M. 61727 Mr. W. Connell PHON E: 217 937-1111 Manager of Quality Assurance Illinois Power Company Clinton Power Station Clinton, IL 61727
Dear Mr. Connell:
Subject: DRG Allegations - Response to NRC - Clarification and Resolutions Reference: Letter LW0#23085, dated 5-29-85, Osborne to Connell Baldwin Associates has reviewed the comments to the referenced letter and our response is enclosed as Attachment #1.
If any additional information is required, please contact me.
Very truly yours, BALDWIN A L .IATES M
L. W. Osborne Manager of Q&TS
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LWO/JW/mac Attachment (1)
cc: QE Correspondence Q&TS Correspondence
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i ATTACHMENT'#1 ,
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.; IPQA Comments BA Resolution .
Item 3 - Last paragraph difficult to follow Replace last paragraph with: " Design Specification K-2882 classified Aug. D as non-safety related, subjected to the quality
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j "The evaluation does conflict with QA Manual."
i' requirements referenced in Section 113. Although the drawings
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indicated non-safety, through bas traveler program all work
' received the necessary minimum quality controls."
l Item 6 - Fifth paragraph first line Change to read: "It is assumed in Paragraph 5, Item 6 of the i " Paragraph 5 of what". ~ Reference 2 enclosure letter that . . ."
i Item 7 - Note "Could not find 4 of the orifices Brian Weaver provided Mike Winter a complete explanation with
, they must still be in the field." appropriate records (resolved).
Item 12 "If subsequent procedure revisions Add note after last sentence of second paragraph " Note: There is no I
were made to BAP 2.10 and BAP 2.6 what is the impact on pipestand installations prior to the deletion of j impact on the equipment (pipe stands) installed references to BAP 2.6. Pipestands were fabricated in accordance j prior to these changes." with BAP 2.14 and installed and inspected in accordance with.BAP
2.10."
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Item 13 - Second paragraph, second sentence At the suggestion of IP the last two sentences have been deleted h "Where are these special evaluations." and replaced with: "The Nonconformance Program (BAP 1.0) has undergone extensive reviews and revisions and continues to be under close scrutiny to assure NCRs are properly initiated, reviewed, dispositioned and implemented."
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i j Item 13 - Fourth paragraph " rewrite needed - Add the following sentence to the paragraph: "As a further note, all QA/QC personnel have the right to identify all QA/QC personnel have the right to identify problems."
j j problems."
i Item 13 "Put back the closing sentence in the Add the following as the last paragraph: "The Clinton Power l
! draft but leave out reference to NRC." Station is being constructed in accordance with Codes, Standards and Specifications with an approved Quality Program to monitor
! handled w th pa ch a d r sol ed o a t me y bas s CPS sa 2 quality project."
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J B ALDWIN A SSOCI ATE S
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- A JOINT VENTURE OF FRUIN-COLN0N CORPORATION McCARTIN-McAULIFFE MECHANICAL CONTRACTOR, INC.
KELS0-BURNETT COMPANY POWER SYSTEMS, INC.
1211 EAST TOWER ROAD. SCHAUMBURG, ILLINOIS 60172 LWO#23085
Ma7 29, 1985 "' " .*0.80X P 306 CLINTON, ILL. 61727 !
PHONE: 217 937-1111{
Manager of Quality Assurance Illinois Power Company Clinton Power Station Clintor, IL 61727
Dear Mr. Connell:
Subject: DRG Allegations - Response to NRC Reference: 1. Letter #CA-1276-85, dated 2-25-85, Anderson to Osborne 2. Letter Docket #50-461, dated 5-7-85, Norelius (NRC) to Gerstner (includes enclosure letter dated 3-7-85)
Baldwin Associates has reviewed Reference 2 with enclosure letter dated 3-7-85, and stands by the earlier evaluations and decisions presented in Reference 1.
The enclosed attachments (1 through 13), identified with the items in the Reference 2 enclosure letter, are provided as clarifications and supplements.
If any additional information is required, please contact me.
Very truly yours, BALDWIN ASSOCIATES h&/^
L. W. Osborn.
Manager of QsTS LWO/ DSS /JW/mac Attachments (13)
cc: QE Correspondence Q&TS Correspondence
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ATTACHMENT #1 Item 1
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Disposition in Reference 1 is acceptable by Reference 2 enclosure letter.
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ATTACHMENT #2 Item 2 Disposition in Reference 1 is acceptable by Reference 2 enclosure letter.
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ATTACHMENT #3 l
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Item 3
Reference 2 enclosure letter is in disagreement with R6ference 1; the following supplement to Reference 1 is provided:
The evaluation provided in Reference #1 does not contradict the BA QA Manual, Section 0, Page 3, Paragraph 1. Thisparagraphfullysitates: "For the purposes of this QA Manual, Augmented D/ Fire Protection, Pressure Boundary items, materials, or services shall be considered " safety related" with the exception of Sections 8, 9,12 and 13 for Fire Protection and Sections 8 and 12 for Augmented D. The program described herein requires systems that are planned to document and verify activities that will provide evidence of adequate quality that is in compliance with the ASME Code, Regulhtory and Technical Standards requirements, Design Specifications for the cAde classes specified, and the FSAR, as a minimum." ,
The BA QA Manual is the basic governing document that de! scribes the QA Program. This manual has been prepared in accordance with the provisions of Section III, Division 1,1974. Edition, Summer 74 Addendal of the ASME Boiler and Pressure Code, and with the requirements set forth in Title 10, Code of Federal Regulations, Part 50 - Appendix B and various ANil Standards.
TheS&LK-SpecsdonotrelieveBAfromfollowingtheQANanual;theydo, however, specify the QA requirements for various classifikations of hardware which effectively determine those portions of the QA Manual that are applicable.
For instance, the BA QA Manual, Section 9C, provides controls for performance of nondestructive testing. If based on Code and design specifications, NDE is not required, then Section 9C of the QA Manual obviously dyes not apply.
In response to the DEL Item concerning purge not being verified, the following is provided.
The Aug. D piping in question, as specified by Design Specitication K-2882, paragraph 117.2 shall be fabricated, erected, examined and tested in accordance with ANSI B31.1; 1973 Edition, Summer 1974 Addenda. The requirement '
for inspection of the welds is a visual inspection for all sizes and thicknesses.
Procedure BAP 3.6.5 (formerly BTS-405) " visual Inspection of yeldments" states:
"In cases where only a weld complete inspection is required, the in-process inspection shall be made on a random basis." It is therefore concluded that the BA QA Manual has been adhered to.
In response to the item concerning Non-Safety D-only being indicated on the design drawing; the following is provided.
Design Specification K-2882 classifies Augmented D as non-safety. The non-safety designation on the drawing is, therefore, appropriate since the drawing is an element of the design.
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ATTACHMENT #4
.. ,f Item 4 Reference 2. enclosure letter indicates "No comment" but at the same time the following is listed:
" Concern:
That bas final document review program is set up in such a way as to mask suspected noncompliances rather than to ' document' and ' resolve' them."
To clarify this issue the following definition of final QA (DRG) review is provided from BAP 2.1.1, Section 2.2:
2.2 FINAL QA (DRG) REVIEW - A program established to examine all ASME, Safety related, Fire Protection, and Augmented D records for the purpose of verifying they are complete, in compliance to code, standards, specifications and procedures and are, therefore, acceptable as a quality record prior to transfer to Illinois Power Company.
The DRG program is only a part of the total effort required to verify the quality of CPS. The determination of acceptable quality is made by a review of many functions beginning with design and continuing through final acceptance by Quality Control. The Document Review and Field Verificatin programs have been implemented to provide verification that the other elements of the program functioned properly._ There is no intent to mask noncompliances in the DRG. The definition of Final QA (DRG) Review describes the review as an examination of records to verify that the records are complete and acceptable. The quality of the hardware cannot be evaluated through this single element of documentation
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review. The documentation review does however verify that the program has been complied with by reviewing the records for proper signof fs, records traceability, etc.
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ATTACHMENT #5 y
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- Item 5 Disposition in Reference 1 is acceptable by Reference 2 enclosure letter.
'Ihe concern expressed in Item 4 appears again' here in Item 5 as a reference.
Refer to Attachment 4 Item 4, for an explanation.-
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ATTACHMENT #6 Item 6 Reference 2 enclosure letter is in disagreement with Reference 1.
The response for item 6 as provided in Reference 1 has been reviewed again and remains acceptable. However, since the time of the initial response, stand alone NCR copies are no longer inserted into the travelers.
In response to Item 6 as discussed in Reference 2 enclosure letter, the following is provided.
The requirements of an NCR disposition with exception of stand alone NCRs, are incorporated into a traveler. Stand alone NCRs by procedure act as a traveler for those minor nonconformances described in the procedure.
It is assumed in paragraph 5 that the subject is stand-alone NCRs and not traveler NCRs. Taking this into account, the travelers may be closed and any necessary additional work accomplished on a Stand-Alone NCR. The final stand-alone NCR then will be reviewed. Additionally, all ASME NCRs (including stand-alone NCRs) receive two reviews by the ANI. The first review is accomplished prior to disposition implementation, the second review is af ter completion of work. Therefore, the ANI is involved prior to DRG review.
In these cases where travelers are closed, and Stand-Alone NCRs exist, the ANI has the option of reviewing the associated traveler.
Additionally, NCRs 17399 and 26969 along with the supporting documentation were reviewed and found to be satisfactory.
In response to the concerns associated with NCR 70620, the following is provided.
NCR 70620 reported that ID numbers were incorrect on headfitting IMC-45. The NCR referenced two travelers MS-3-D which is a hanger traveler and MS-3-B which is a piping traveler. The travelers were appropriately reviewed by the DRG and the piping traveler reviewed by the ANI. Hanger travelers are not reviewed by the ANI as per the 1974 ASME Code. NCR 70620.as a stand-alone NCR,was reviewed by the ANI on 1-29-85. The processing of these travelers and the NCR is in compliance with the review program, i
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ATTACIIMENT #7
- ) Item 7 Disposition in Reference 1 is questioned in Reference 2 enclosure letter.
The following supplement is provided.
NCR 70270 addresses 31 orifice plates. Twenty five of these were removed, retagged per BAP 2.23 and PO C-16149 had a rider issued to downgrade 25-orifice plates. The six remaining orifice plates were dispositioned use-as-is per ECN 4543. The six orifice plates are identified as: OFE-VC008, OFE-VC108, 1E21-N552, lE02N564, lE51-N599 and lE12-N556.
In response to the concern relating to the use of a later code edition the following is provided.
Sub-subarticle NA-1140, paragraph (g) of ASME Section III, Subsection NA, 1974 Edition states: " Caution is advised when using Addenda or Cases that are less restrictive than former requirements without having assurance that they are acceptable to the enforcement authorities having jurisdiction at the nuclear plant site." The 1974 edition does not address code rules concerning orifice plates. The guidance provided by the 1980 edition of the ASME Code, as provided in ECN-4543, provided clarification with respect to orifice plates. It has been determined that based on NA-ll40, that the later edition (1980) is not less restrictive than the former requirements presented in the 1974 edition.
Therefore, acceptance by the jurisdictional authorities is not required in this Case.
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ATTACIIMENT #8 i Item 8
'J Disposition in Reference 1 is acceptable in Reference 2 enclosure letter, but there is a concern, i.e., "Ref. NA-4000, certification holder responsibilities regarding subcontractors QA program and implementation thereof (Audits)."
BA conducted the following surveys and surveillances with NDT Consultants, a subcontractor nerforming counterbore examinations:
I Manufacturer Survey 5-25-83 Supplier QA Activity Report 6-6-83 ES-038 Supplier Program Surveillance 6-25-83 EPS-008 Supplier-Program Surveillance 7-10-83 EPS-010 Supplier Program Surveillance 7-23-83 EPS-012 Supplier Program Surveillance 8-10-83 EPS-016 Site Surveillance Report 1-28-84 S-805 On-Site QA Activity Report 2-19-84 C-41734.1 l l
Quality Survey and Surveillance of Subcontractors plant, equipment and personnel are properly administered within program requirements.
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ATTACHMENT #9 d Item 9 Reference i did not list an Item 9 (response number not used by Reference 2 enclosure letter).
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ATTACHMENT #10 d
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Item 10
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Reference 2 enclosure letter is in disagreement with Reference 1.
The response provided for item 10 in Reference 1 above was re-reviewed and found acceptable. The alternate WPS (N-1-1-BS) that was utilized does not i' require the use of an inert gas purge. Therefore, no traveler entry is required. The disposition to NCR 70715 was evaluated and found acceptable.
The disposition did not address the issue of purge requirements, as no purge i
- ' requirement oxists. (Reference WPS-N-1-1-BS and Specification K-2882, Article 304.3),
i Item 10(D) of Reference 2 Enclosure letter has apparently confused the
! requirement for a shielding gas versus an inert gas purge. i i
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ATTACilMENT #11-d Item 11 Reference 2 enclosure letter is in disagreement with Reference 1.
The response for item 11 provided in Reference 1 was re-reviewed and found acceptable. Welder qualification records for F. D. Short (F#191) were on file in the Document Records Center. (Reference attached Welder Qualification Record for S. D. Short, Attachments 11-1, 11-2 and 11-3).
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06 484 f/ANtli AC10RiF'S El CORD OF VtLDIE Or wILOING OPERA 10.. OUAtlFICAllON TES15 .
(See OW 301.Section IX.1974 ASME Boiler and Pressure Vessel Code) ;
CLOCK NO. !
S. D. Short OlydtAtto; 9-2883 Stamp No. M191 .
Welder Name
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Welding Process GTAW ' Type MANUAL
_
l N-1-1-B-S I In accordance with Welding Procedurc Specification (WPS)
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i B acking (QW-402) NONE Material (QW-403) Spep A-106,,5 A-106,g p go, j ,, p g ,, j Thickness Range 3/16" .688" Dia. Range VER 1" Filler Metal (QW-404) Spec'. No. 5.18 y go, 6 Other NA Position (Qw-405) 6G - 2" sch. 160 (.344)
(lG,2G.6G)
UC Polarity 5TRAIGHT Eleerrica! Charse. eristics (QW-409) Current Weld Progression (QW 410) VERTICAL UPHILL FOR INFORMATION ONLY Flux for Submerged Arc or Gas for inert Gas Shielded Arc Filler Metal Diameter and Trade Name LINDE E-705-2 - 3/32" - 1/8" Welding GUIDED BEND TEST RESULTS OW462.2(e),QW.462.3(a),QW462.3(b)
Type and Type and Figure No. Result Figure No. Result
' N/A
'
N/A N/A N/A N/A N/A N/A N/A_
Radiographic Results: For alternative qualification of groove welds by radiography in accordance with Qw.304 and QW.305 ACCEPTABLE Test Ct,rceted by BALDWIN ASSOCIATES t.aboratory-Test No. .ET 5156
' Per O$f HLLET WELD TEST RESULTS (See QW482.4(a),hWQQgg g Fracture Test (Describe the location, nature and size of any crack or tearing of the specimen)
inches %
Length and Per Cent of Defects _
Maero Test-Fusion in. X in. Convexity or Coocavity in. 1 Appearance-Fillet Size Test Conducted by Laboratory-Test No.
l per We certify that the statements in this record are corteet and that the test welds were prepared, welded and tested in accordaner with the requirements of Sections IX of the ASME code.
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f DA'E OF EMPLOYMEM 3 /9 nna signed BALDWIN ASSOCIATES
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Date - 1/?4/R4 By
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tl't 1 c' re. erd of tests a.c illar,tise orly snf may be .W.ed te cor.for . to the t%Te and num
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' " 'd '"" " #" i t > u.. Coe . ' /7 TRANSMITTAL WTSA / 4 9/-
h% la nddaim as dhee obove shdi be recorded.
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(S:e OW-301, Srcti:n Ix,1974 ASME Peil:r and Fr ssure Vessel Coda) BTSF 05D
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No. 9 ?RR1 St2mp No$101 ,
Wel' der Name S. D. Short Clock i
.SMAW _,_ Type _ Manua1 ro H >'
Welding Process e :-
fi-I-1 - A-1M , g in accordance with Welding Procedure Specification (WPS)
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' Backing (QW-402) I Msterial(QW-403) Spec.SA36 to SA36 of P No. I to P No. I $j E H
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Thickness Range I/16" - 3/4" Dia.Ranse _Lifnited to P1a te *
%S U Filler Metal (QW-404) Spec. No. 5. l - uf .- N o. _ 4 Other *PiDe *
.- G'reater Ths n W O Qin h$
2G: 3G: 4G: 3/8" Plate {O Position (Qw-405) *p (IC,2G,6G) 5 D.C. Po'arity Reverse ,,_
Electric:l C.dracteristics (QW 4C9) Current Weld ProgresGn (QW-410)
Stringers - Vertical Uphill {
~
FOR INFOR.MTION ONLY Flux for Submerged Arc or Gas for I:.crt Gas Shielded Are E
Filler Metal Diameter and Trade Name -s 1/8 E7018 Welding Manva'r 2 3/32: 5.
~5..
GUIDED BEfiD TEST 3G RESULTS QW42.2(at QW452.3(a).4G0W462.3(b)
_
2G Type snd g Type and
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Type and Resul:
Figure No. Result Figure No. Rerult . , Figure No. ,
{
0.K. Face Bend 0.K. @
Face Bend 0.K. Face Bend ._
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Root Bend 0.K. Root Bend 0.K.
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Root Tand 0.K. i s
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Radiographic Resu'Its: For alternative qualification of groove welds r: -
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by radiography in accordan QW-3% and QW-305 NA Laboratory-Test No.,
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Test Conducted by Baldwin Associates per NA NE.N2 @W ' $
E-s g-FILLET WELD TEST RESULTS (See QW432.4(P), CW462.4(b)) -
- t Fracture Test ".;
(Describe thelocation, nature and size of any -rack o' tearing of the spec %en)- .,.
"*
inches %
Length and Per Cer. of Defects r.ncro Test-Fusion BALDWIN ASSOCIATES e"
__ in. X in. Convexity or ConREGEDIEDn. if '
Appearance-Fillet Size Test Conducted by Laboratory-Test No.
per OCT 001981
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We certify that the statementsin this record areA S.'.tE cntreet c o c.
and that the test wedgCBM
.ind tened in acconlance with the re.luirements oiSe tions IX of th:
Signed __ Raldain Associates Date of Employ:nent Date 9-22-81 9-29-81 By gg rgantation)
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'5 (Detail of record of tests are illus:rative only and m:y be modified to conform to th: type and n.:m-
- ber of tests rec;uired by the Ccdc.)
NOTE: Any essential uria * ales in addition to those above shdi be recorded. toca r 2ne it. i g-o .. , u em...o e..wi c.. As . : o a r o~rn.. m s t. 47 si.. n w voes. s..v.
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ATTACHMENT 11-3
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OW-484 MANUFACTURER'S RECORD OF CELDER OR WELDING OPERATOR QUAT.lFICATION TESTS
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(See OW 301,Section IX.1974 ASME Boiler and Pressure Vessel Code) BTSF-050 9-2883 Stamp No.h191 h
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welder Name _
S. D. Short Check No.
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SMAW Type MANUAL
, welding Proce,,
N11A11 l In accordance with Welding Procedure Specification (WPS) -
B acking (QW-402) Yes Material (QW 403) Spec. hoSA1068,gpg ,, 3 - t, p g,. }
Thickness Range 3/16" - Unlimi tedo;,, g,nge 2 7/8 and Over 5.1 F No. 4 Filler Metal (QW-404) Spec. No.
Other None Position (QW 405)
6G-6" XX STG Pipe (0.864)
(IC,2G,6G)
Electrical Characteristics (QW-409) Current O' C* Polarity REVERSE Weld Progression (QW-410)
Vertical-Uphill & Strincers FOR INFORMATION ONLY Filler Metal Diameter and Trade Name Flux for Submerged Arc or Gas for Inert Gas Shielded Are E7018, 3/32, 1/e, 5/32 Welding Mar.ua l GUIDED BEND TEST RESULTS QW462.2(a), QW462.3(a), QW462.3(b)
Type and Type and Figure No. Result Figure No. Result
- NA NA NA
"$A NA NA NA NA Radiographic Results For alternative qualification of groove welds by radiography in accordance with QW 304 and QW 305 Actertable BaldWin Ass 0ciates Laboratory-Te*t No FT-5165
. Test Conducted by Pct NYb f' H&
TRANSMITTAL. #fd
._
FILLET WELD TEST REStILTS (See QW462.4W,, Wtw QW462Altd). ERI.-[*Ity.
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Fracture Test (Des,: ribe the location, nature and size of any crack or tearing of the specimen) .-
Length and Per Cent of Defects inches %
Macro Test-Fusion in. x in. Convexity or Concavity in.
Appearance-Fillet Size Test Conducted by Laboratory-Test No.
_
per
We certify that the statements in this record are correct and that the test welds were prepared, welded and tested in accordance with the requirements of Sections IX of the ASME code.
Date of employment 3-27-84 Signed BALDWIN ASSOCIATES Date 3-30-84 gy
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(Detail of record of tests are illustrative only and may be modified to conform to the type and num-ber of tests required by the Code.) /9 NOTE: Ang essential variables in addition to those above shall be recorded.
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ATTACHMENT #12
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Item 12 Reference 2 enclosure letter requested evaluation in addition to that provided in Reference 1.
The response to Item 12 provided in Reference 1 was re-reviewed and determined to be acceptable. However, since the time of that response, subsequent procedure revisions were made to BAP 2.10 - Equipment Installation and BAP 2.6 -
Instrumentation. BAP 2.10 was revised to address traveler numbering and location verifications for pipe stands and all references to pipestands have been removed from BAP 2.6.
Baldwin Associates concludes that the installation of pipestands is performed in accordance with BAP 2.10.
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ATTACHMENT #13
. Item 13 J
The following is provided as a response to the " Notes" and " Summation" section of Reference 2 enclosure letter.
NCR 17399 has a correct disposition. Subsequent NCRs were written to further justify and clarify the disposition however those NCRs did not change the bottom line disposition on NCR 17399. Several special evaluations have been conducted on the Nonconformance Program (BAP 1.0). The results of these evaluations conclude that NCRs are properly initiated, dispositioned, reviewed and implemented.
The final documentation processed through the Document Review Group is an actual and accurate reflection of the status and quality of the hardware in the field. Over 130,000 Document Exception List items have been identified by the DRG. They have been evaluated and it has been determined that none of the potential hardware-related nonconformances resulting from the record reviews are safety-significant. That is, if the nonconforming conditions were lef t unidentified by the Record Verification Program, no adverse effect on plant safety would have resulted.
It is true that the reviewers are required to follow the prescribed review program and checklists. However, the quality of the hardware is not in question as a result of this program because the review program is a supplement to the QA program which among other aspects, involves first line QC and QA audits.
Determination of the actual quality of hardware and supporting documentation is made by first line inspection.
It is recognized that the documentation is not perfect. However, since the evaluation of the 130,000 DEI items revealed that none represented a safety significant problem, there is adequate confidence in the acceptability of the CPS Construction QA Records.
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SA Rerpons3 to New .x'
original Response New Concern (NLR Concern Including 8A Response to IP 5h3 ,
Original (CA-12 76-85 Anderson Letter, kesolution of IPQA Comment s * Original BA *
Concern to Osborne) Dated May 7 1985) Comments (LWO #23985) Position Chanae Item 1: s i
NCR 17399 Preht/ Int NCR 27309 addresses Resolved (Ltr. None required. None required. -NO- #hC4
, Pass Temp. not ver- REP to LWO ified 2/28/85)
Item 2:
DEL h051296 K-2841/ BAP 2.10 Accept at gtated None required. None required. -NO-a. Res. #3(QC) Atc. 5 These bolts CA-1276-85. Act. #2 Cover Bolt Torque - only required snug item 2 No Documentation tight b. Res. #5 (PE) No Tank hold down brac- Acc ept au stated None required, hone required. -hu-t raveler requirement ket assembly incl. CA-1276-85. Att. #2 to maintain trace- all thread studs /- Item 2 i ability of manvey nuts wired to cover-bolts & nuts (orig- verified by QE/-
inal material re- . System Engr. No inst, or new nuts /- torque or material bolts) verificatics re-quired.
I f(j Item 3:
[gy DEL F045001 Res. #1 CR 13 R/2 Res. A Aug Contradicts BAQA Hopiace last 1:
Last two (2) 1 - a. No - But the (TS) Purge not ver- D requires only manual for Aug K-2662 classified difficult to follow original pusition 111ed (H/P deleted final visual. De- D/Safet y-rela ted. Aug D as non-safety & the BAQE evalu- (CR 13) was expanded 12-28-81) termined af ter Allegation of ques- related. subject to ation does socilict to include BAQAM &
traveler prepara- tions controlling quality requirements with EAQAM. The S&L K-Spec require-tion. H/P deleted. documents for site of Sec. 113. BA te rm "Aug D. non- ments for Aug D CR13 R/2 Res. A1C K-Specs. GRs. ASME traveler ghT progr(w,'Ipf k work" is the sat ~ety
'74. 10CFk50 6 all work rec'd issue.
PSAR/FSAk regardirig necessary r.inimum QC Aug D? BAQAM in- - even t hough draw- 'm f poses Sect 9 - Purge ing indicated non-was required. safety.
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BA Response to New Original Response New Concern (NCR i Concern including BA Response.to IP e original - (CA-12 76-63 And e rson Letter.
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Resolution of-IPQA Comments . original BA C.>ncern to osborne) Dated May 7 1985) Comments (tWo #f3985) Poaition Change
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Item 3 (Continued):
'BES #2 (PE) Dug. K-2882. Sec. !!3 con-safety, D unty Aug D is non-safety (HAP 2.26. Aug D. related.
safety related)
(IOCFR 50. App. B.
Criterion !!!)
Item 4:
NCR 70488 - Do not' Base sacerial on ho comment - con- None required. Nor.e required. ho ' - But definition agree with dispost- cr.seler incorrect - cern: -bA/DRG pro-tron.
. of BA/DRG & other WPS specified incor- gram to mask sus- existing verifica-rect. kPS used pectcJ noncompli- tion activities were h-i-1-N & N-1-1-A-Y ances rather than provided. NCR 17399 same variables. NCk " document & re- & supporting docu-states and corrects solve". Ref: Item mentation reviewed &
this. 5. evaluation, rep acceptable.
letter of position 1-13-85. NCR 17399 re solut ion.
Where dcca it state ECR dispo evalua-k) NCR dispo beyond ' tion / accept is be-
- kAJ scope of DRG7 yund DRG scope, hot proceduraitted. PAD
& stand alone NCRs reviewed by DRG per review checklist -
C8 for presence &
completeness of back-up documenta- .
tion to support NCR closure. Traveler NCR dispos not re-viewed by DRC.
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EA Retponse to New Original Response New Concern (NCR Concern Including BA Response to IP e
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Original (CA-12 76-85 And er son Letter. Besciution of IPQA Comment s Original BA Concern to Osborne) __ Dated May 7. 1985) Comeents (Lko #23985) Position Chanae item 5:
DEL E044218 #1 In- NCR should not have Accept evaluation as Non e Non e -NO-sufficient instr. & been stand alone, stated concern Ref.
documentation to BAP 1.0 R/14. Chg. 8 Item 4 - definition indicate scope of requires all docu- of total veritica-rework activities mentation necessary tion program pro-to support bCR dispo vided.
be attached. Cqp y of completed NCR will be placed in traveler.
Item 6:
DEL 10 54895. RES hCR 70620 was identi- Disagree: NCR 7C620 Insert reference ..s fP request one minor ho - however RAP 1.0
- 1: Can't close out fled Stand Alore. refers to hgr. noted. clarification of a t revised, stand alone traveler with NCR kork will be docu- traveler MS-3-D; rei. NCR copies are not which requires mented and attached disp refers to pip- put in traveler.
QA/DRG final review, to NCR. Sep ara t e ing traveler. NCR 70620 ANI re-DRG review of hCR to MS-3-8. Bo t h viewed 1-29-85. ANI checklist OBC. NCR travelers finalized review associated ocpy in traveler by DRG 2-1-85, travelers at his IkJ betore AN! review. MS-}-8 does not con- option.
.pg tain copy of NCk 70620.
Item 7:
DLL B045658 #7 & 2: hCR 702J. states Evaluation question- BA provided LP a iP svuld not find 4 So - Explained code NCR 70234. Blk 18, this item cannot be able - Ech 4543 coeplete explaration of the plates - requirement for use item 3. not complied complied with; NCR invokes NCA-1273. S with apprcpriate "must weill be in of later code edi-with - no traceabil- 70270 generated - '60. Cannot verify. records (resolved). f ie ld" . tion.
try CMIR to orifice downgraded all but 4 BA can invoke p la t e s. plates to Class D. h CA-12 7 3. QC/lR '
These 4 accepted per 84-292 identifies ECN 4543. orifice plates in field - contradicts with plates ident-ified on ECN-4543.
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BA Rerponse to New Original Response New Concern (NCR Concern including BA Response to IP *
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Original (CA-1276-85 And er son Letter. Resolution of IPQA Comments Original BA Concern to Osborne) Dated May 7, 1985) Comments (LWO #23985) Position Chanae
.,a Item 8:
DEL F043263 #3(TS): BAP 2.5 not applic- Accept as stated. hone required. No IP coements. No - SA provided Counterbore reports able, subcontractor Concern: Ref. listing of surveys.
- Calibration due (NDT Cons.) records NA-4000 Cert. Holder etc., of NDT Consul-date not recorded. verify calibration, resp. for subcon- tant.
(RAF 2.5) See 50.55e, tractors QA program 55-83-02. (audits).
item 10 (Was item 9):
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DEL CO24627 #3 & 4 NCR 70715 identified Disagree (Ref. Nor.e required. ho IP comments. No - NCR dispo did (TS): WPS WPS entry af ter weld Traveler RT-27). not address purge -
N-i-1-BA-M violated, complete. NCR 70715 DEL ltem 3 still no purge required, alternate WPS entry reviewed by QE NRG valid, resolation
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made af ter weld com- and closed 2-6-85. unacceptable. hCR plate no purge as dispo unacceptable required. as written - purge-requirement not addresmed.
Item 11:
i p) DEL 2240181 #3: S.D. Short through Aut hent ica t ed Nc:.e required. No IP comment. No - copies of Welder not certified qualification & use recorom tor this welder qualitication
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(Il to GTAW F*I91, S.D. of process was qual- welder could not be records have been S ho r t , for welding itted CTAW through found on file. provided.
on 5-23-84. 10-19-84.
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BA Re ponse to New Original Response New Concern (NCR Concern including BA Response to IP e ,
Original (CA-12 76-85 Anderson Letter, Resolution of IPQA Comments Original BA Concern to Osborne) Dated May 7, 1985) Comannes (LWo #23985) Positiose Change O
Item 12:
Traveler BA/RE classified N guest NRC to Clarification added What is impact on -NO-ISPS-RT032-56 (Cont. instrument pipe evaluate intent of for procedure ap- equipment - (pipe-Bldg.) Instr. Pipe stands as equipment RC 129 & 10CFR50. V plicability to stands) installed Stand, S-I, Inst. & - use BAP 2.10 for with respect to BAP fabrication /- prior to revisions Welding: Reference installation. No 2.6 as related to installation. of BAP 2.10 and 2.6.
procedures not surveyor verifice- traveler.
rpplicable to scope tion required.
of work. JV-522(QC) JV-522 covers neces-improper inspection sary inspection at-criteria; no survey- tributes. DRC cre verification of checklist MAF is location (BAP 2.6); satisfactory for JV-339 initiates use final review.
of improper final '
QA review checklist ~ U*
(MAG vs. IDC)
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BA Response to N1w Original Response New Concern (NCR Concern Including BA Response to IP 8 .
Original (C A-12 76-65 And erson Letter. Resolution of IPQA Comments Original BA Concern to Osborne) Dated May 7 1985) Comments (LWO #23985) Position Change Item 13: O Notes & Sumation Determination of the Mm e - the Not es & IP conments Put back closing N/A - this item is quality of hardware Summation were pri- incorporated. statement in the Notes & Summation a. Validity of all and supporting docu- marily to the NRC by dratt, but leave out and did not receive vaulted "No excep- eentation is made by this individual. reference to NRC, any initial BA tion" NCRs. first line inspec- 3rd 1 rewrite needed evaluation or b. Reviewer cannot tion. The final - all QA/QC person- response.
render an " accurate" documentation re- nel have right to assessment of the viewed by DRG is an identify problems.
quality of the dacu- accurate reflection centation versus of field hardware, ectual hardware. Over 130.000 DEL c. Prescribed items have been review program & evaluated and none checklista leaves of the potential quality of hardware hardware-related in question. nonconformances g d. Quality of CPS resulting from the la question - record reviews are
" actual status" of safety-significant.
hardware.
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