ML19344F271
| ML19344F271 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/07/1974 |
| From: | US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19344F268 | List:
|
| References | |
| 50-445-73-02, 50-445-73-2, 50-446-73-02, 50-446-73-2, NUDOCS 8009150051 | |
| Download: ML19344F271 (8) | |
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SUMMARY
OF VIOLATIONS l
i Texas Utilities Generating Company Docket Number 50-445 and 50-446 Certain of your activities appeared to be in violation of' Appendix B to 10 CFR 50 and are considered to be of Category II severity.
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Criterion II requires the applicant's quality assurance prog am to comply with the requirements c,f Appendix B.
Contrary to the above, the following had not been included:
1 a.
Requirement: Criterion I o'f Appendix B to 10 CFR 50 requires that the authority and duties of persons and organizations performing quality assurance functions be clearly established and delineated in writing.
i Findine:
Neither the Corporate Quality Assurance Program E
nor the CPSES Quality Assurance Plan clearly establishes the authority and duties of the TUSI staff QA engineers or p
the TUSI engineers working under the CPSES Project Engineer.
Both groups of engineers are or have been engaged in the review of design and procurement documents.
b.
Requirement:
Criterion II of Appendix B to 10 CFR 50 requires that activities affecting quality shall be accom-plished under suitably controlled conditions. Controlled conditions include the use of appropriate equipment; i
suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all prerequisites for the given activity have been satisfied.
Finding:
Neither the Corporate Quality Assurance Program nor the CPSES Quality Assurance Plan address this requirement.
l c.
Requirement:
Criterion III of Appendix B to 10 CFR 50 specifier the requirements for design control. In addition,
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AEC guidance pertaining to Criterio 1 III, given in i
paragraph 2.1. of ANSI N45. 2.11 (dratt), states in part:
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(1)
"A quality assurance program for design shall be established and documented to comply with the requirements of this standard. "
(2)
Program documents shall identify the items and services and the specific activities to which this standard is applied. "
i Additional requirements for the quality as surance program covering design are described in paragraphs 3. 2., 4.1.,
- 4. 2., 4. 3., 4. 4., and 4. 5.. of ANSI N45. 2.11. (draft).
Finding:
Neither the Corporate Quality Assurance Program nor the CPSES Quality Assurance Plan clearly requires compliance with ANSI N45. 2.11., nor do they clearly identify the items and services to which ANSI N45. 2.11. is applicable, nor do they describe the quality assurance program for E:
design as required by paragraphs 3. 2., 4.1., 4. 2., 4. 3.,
- 4. 4., and 4. 5. of ANSI N4 5. 2.11.
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d.
Requirernent:
Criterion III of Appendix B to 10 CFR 50 specifies the requirements for design control. Additional AEC guidance pertaining to Criterion III, given in ANSI.
N45. 2.11. (draft), paragraph 2. 2., states in part:
" Procedures shall be employed to assure that design activities are carried out in a planned, controlled, orderly and correct manner. " Paragraph 2. 2. then lists 17 i
categories o,f procedures that need to be considered.
Finding: The CPSES Quality Assurance Plan does not i
contain procedures which cover the following:
1 I
(1)
Management review of status and adequacy of program.
(2) Necessary training of personnel (concerning design).
(3) Preparation of design documents.
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(4) Specifying quality levels, acceptance standards, and record requirements.
(5) Making experience reports available to cognizant p
design p,usbnnel.
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c.
Requirement:
Criterion IV requires measures to be established to control procurement documents. AEC guidance, contained in paragraph 5. of ANSI N45. 2.,
requires that changes in procurement documents be subject to the same degree of control as was utilized in the preparation of the original document.
t Finding:
Procedure 2. 4., " Procurement Administration",
of the CPSES Quality Assurance Plan does not address changes in procurement documents.
I f.
Requirement:
Criterion IV states that procurement i
documents shall require contractors or subcontractors '-
to provide a quality assurance program which is j
consistent with Appendix B.
AEC guidance contained j
in paragraph 5. of ANSI N45. 2. requires that procurement p.-
documents include provisions, as applicable, for supplier QA program, basic technical requirements, source
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inspection and audit, documentation requirements, and lower tie.r procurement.
Findine:
Procedure 2. 4., " Procurement Administration",
does not include specific instructions to inform the responsible reviewing engineer how or by what guidelines he is to determine the adequacy of the five basic provisions of ANSI N45. 2., paragraph 5, which are contained in paragraph 5.1. of Procedure 2. 4.
Criterion V of Appendix B to 10 CFR 50 g.
Requirement:
state s: " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for detcrmining that important activities have been satisfactorily accomplished. "
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Finding:
Although paragraph 1. 2. (V) of the Corporate Quality Assurance Program says that TUSI has established measures to require compliance with Criterion V, the CPSES Quality Assurance Plan does not contain a procedure l
which addresses or implements this requirement.
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There was no procedure in the CPSES Quality Assurance Plan to give guidance to those conducting QA reviews of design or procurement documents. There were no written instructions to give guidance to those conducting management rev ews of the quality assuiance program.
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h.
Requirement:
Criterion VI of Appendix B to 10 CFR 50, requires in part that document control measures shall assure that documents, including changes, are distributed to and used at the location where the prescribed activity 0
is* performed.
m Finding :
Although paragraph 1. 2. (VI) of the Corporate
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Quality Assurance Program indicates that measures have been established to assure that documents are actually utilized at the locations where the quality related activities are being performed, the CPSES Quality Assurance Plan does not contain a procedure which addresses or implements this requirement.
i.
Requirement:
Criterion VII of Appendix B to 10 CFR 50 sta tes in part: " Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement document. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor,.... "
and that "The effectiveness of the control of quality by contractors and subcontractors shall be assessed by the applicant or de.signece at intervals consistent with the I
importance, complexity, and quantity of the product or services."
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Additional AEC guidance contained in ANSI N45. 3.13.
(draft),- paragraph 2. 2., states in part: " Objective evidence shall be available for audit which substantiates
.a supplier's approval as an acceptable source of equipment,-- materials or services.- Procurement source evaluation and selection measures shall provide for:
i (1)- Identification of organizations responsible for 9
determining supplier capability.
i (2) ' Establishing criteria for placement on an approved supplier source list or lists.
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(3)'~ Identification of methods to be utilized in evaluation I
of supplier sources.
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e (4) Establishment of a supplier source list or lists.
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(5) Identification of documentation to provide objective evidence of supplier source capability and qualifications.
~ Establishment of. methods for updating source supplier (6) list or lists. "
Finding:
The CPSES Quality Assurance Plan does not contain an implementing procedure which addresses the above requirements..
j.
' Requirement:
Criterion XVII of Appendix B to 10 CFR 50 requires that records be maintained to. furnish evidence of activities affecting quality and that requirements concerning record retention be established.
i Additional AEC guidance contained in ANSI N45. 2. 9. (draft),
paragraphs 5. 5. and 5. 6., states in part: " Provisions shall-be established to prec1dde the entry of unauthori. zed I
I personnel into the storage area and to guard against
. larcency and vandalism. Record storage fa~cilities shall
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be so constructed and located as to protect contents from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents, and from possible deterioration by a combination of extreme
- variations in temperature and humidity conditions. "
Finding:
Although procedure 2.11., " Microfilm Processing", provides written instruction for records after they are microfilmed, there is no comparable written instruction (addressing the above requirements) for records that have not been microfilmed.
k.
Requirement:
The additional AEC guidance pertaining-to Criterion XVIII, " Audits", contained in ANSI N45. 2.12 (draft), paragraphs 2. 2. ', 2. 3., 2. 4., and 5. 3. s tate s m part:
(1)
" Management shall establish the audit personnel
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qualifications appropriate to the auditing of the p==
quality assurance programs. "
(2) " Auditing personnel shall have, or be given, appropriate training or. orientation to assure their competence for performing required audits. "
(3) " Auditors shall maintain their proficiency.... "
(4) " Records shall be maintained for all per sonnel actively performing audits as well as those who have previously performed audits within the same project or activity. "
In addition, paragraph 5. 7. of ANSI N45,2. 9. (draft) states in part: "An audit system shall be established to assure that the quality assurance records storage system is effe ctive. " And that periodic audits shall be performed "to assure that the facilities are in good condition and that the temperature / humidity controls and protective devices are functioning properly. "
i Finding:
Although TUSI has a viable audit program and two audits have already been conducted, the implementing procedure in the CPSES Quality Assurance Plan (4. 0. )
does not address the above requirements.
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t 2.
Criterion II requires the quality assurance program to be established at the e -liest practicable time, consistent with the schedule for accomplishing the activities.
Contrary ta the above:
a.
The procedures contained in the CPSES Quality Assurance
-Plan were still in draft fu rm.
None of the procedures in the Plan cSrried a signature b.
of approval.
Most of the Plan manuals in the offices contained only c.
two or three procedures although five procedures were -
reported to be fully implemented.
p d.
Documentation pertaining f.o the formal implementation of the procedures was not available for inspection.
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The "Licensind'and" Record Retention" procedures had c.
only been partially implemented.
f.
The " Design Change Control", " Quality Assurance Deviation Administration", and " Interface Control" procedures had not been impicmented.
g.
Other quality related instructions or procedures were not provided, or were inadequate.
3.
Criterion Il requires the quality assurance program to be documented by written policies, procedures, or instructions and carried out in accordance with those pol'cies, procedures, instructions. Contrary to the above, the Quality Surveillance Committe e, Design was not functioning as described in paragraphs 17.1.1. 3. of the PSAR and 2. _3. 2. of the Co rporate Quality Assurance Program, in that:
a.
No committee meetings had been held.
b.
The committee had not reviewed the QA/QC programs of the architect-engineer, the NSSS supplier, or the safe shutdown impoundment dam designer-constructor.
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M (RO In'spection' Report Nos. ' 50-445/73-02 and 50-446/7,3-02
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. DISTRIBUTION:
l Thornburg,. RO:HQL(21)
RO:HQ '(5)
' NSIC (1)
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-DTIE (1)
State of Texas, Department of Health (1)
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