ML19344F272

IE Insp Repts 50-445/73-02 & 50-446/73-02 on 731203-06. Noncompliance Noted:Qa Program Did Not Comply W/App B & Not Carried Out Per Written Policies

ML19344F272
Person / Time
Site:	Comanche Peak
Issue date:	01/07/1974
From:	Madsen G, Peranich M, Warnick R US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML19344F268	List: IR 05000445/1975012 IR 05000445/1976001 IR 05000445/1976008 IR 05000445/1978005 IR 05000445/1978011 ML19344F267 ML19344F270 ML19344F271 ML19344F272 ML19344F273 ML19344F275 ML19344F276 ML19344F277 ML19344F279 ML19344F282 ML19344F284 ML19344F286 ML19344F289 ML19344F292 ML19344F294 ML19344F295 ML19344F296 ML19344F297 ML19344F298 ML19344F301 ML19344F305
References
50-445-73-02, 50-445-73-2, 50-446-73-02, 50-446-73-2, NUDOCS 8009150055
Download: ML19344F272 (20)

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U. S. ATOMIC ENERGY COMMISSION l'

DIRECTORATE OF REGULATORY OPERATIONS

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REGION IV s

i RO Inspection-Report Nos. 50-445/73-2 and 50-446/73-2 Applicant:

Texas Utilities Generating Company Docket Nos. 50-445 & 50-446 i

1506 Commerce Street Dallas, Texas 75201 Facility:

Comanche Peak Steam Electric Station License No.

None Location:

Sormrvell County, Texas Category A Type of Licensee:

W, PWR,1161 MW(e)

Type of Inspection: Special, Announced Dates of Inspection: December 3-6, 1973 Dates of Previous Inspection: February 15, 1973

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Principal Inspector:

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//?/fy R. F. Warnick, Reactor Inspector, RO:IV Date l-Accompanying Inspector:

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M. W. Peranich, Reactor Inspector Da'te Specialist, RO:HQ s

S Other Accompanying Personnel: None Reviewed By:,

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////7 Y G. L. Madsen, Chief, Reactor Construction and Date Operations Branch g,

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SUMMARY

OF FINDINGS

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- Enforcement Action -

A. ' Violations -

- 1., ' Criterion II of Appendix B appears to have been violated in that:

a TUGCO's' quality assurance. program does not comply with all the a.

requirements of Appendix B. (Details I, paragraph 4a, and

' Details II,; paragraphs 5d,.'and 6f) b.

Certain written procedures or instructions were not established at a time consistent with the schedule for accomplishing design, procurement, and PSAR development activities. (Details I, paragraph 4b, and Details II, paragraphs 3, 4, 5a,,5b, 5c, 5e,

- Sf, 6d,.- and 6e) c.

Part.ri the quality assurance program (the Quality Surveillance

~ Committee, Design) is not being carried out as described by -

written policies. -(Details I, paragraph 3b, and Details II, paragraph 6a)

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B.-

Safety Items None~

II. ; - Licensee Action on Previously Identified Enforcement Matters.

None ' outstanding.

III. ~ New' Unresolved Items None

. IV.

Status of Previously Reported Unresolved Items -

None outstanding.

V. >

Design Chances -

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VI. -Unusual Occurrences P

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A.? Contracts have been awarded to Gibbr & Hill, Inc., for architect-engineering services,' to; Westinghouse for the NSES, to Brown & Root, Inc., for construction'of:the facility, to Freese and Nichols Consulting Engineers for

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the design and construction of the safe shutdown impoundment dam and a -

- larger non-safety related dam,~ and.to EDS Nuclear for QA consulting services. -De_ sign,' procurement,- and PSAR-development activities, which are subject to the QA program, are in progress.

VIII. Managenn nt Interview On December 6,1973, at the conclusica of the inspection, a management interview -

- was held to discuss the results of the inspection. The following individuals were I

h1 attendance:

-Texas Utilities Services, Inc. (TUSI)

H. C. Schmidt, Manager,' Quality Assurance R. W. Caudle, Project Manager, Nuclear Plants R. H. Hickman, Project Engineer, CPSES A. H. Boren, Quality Assurance Engineer-

, 'u A.'Vega, Quality Assurance Engineer

- Atomic Energy Commission (AEC) '

R. F. Warnick,. Reactor Inspector M. W. Ibranich,. Reactor Inspector Specialist

- The inspectors described the purpose of the inspection and then discussed their findings with those in attendance. (Details I'and II)

The inspectors inquired whether or not other objective evidence existed which would resolve or further clarify identified areas _of concern. The inspectors.

- were informed that none existed.

Due to other commitments and. schedule limitations, it was not possible to hold

= the post-inspection management interview at a time when members of the applicants top management could be in attendance. The inspectors requested

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-that management not in atteu,ance be informed of the results of the inspection.-

The Inspectors were informed eat the results would be communicated to top.

management..

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DETAILS I-

. Prepared by: R. F. Warnick cof 1.

_ Persons Contacted -

T<.xas lhtilities GeneratineCompany (TUGCO)

P. G. Brittain,' Executive Vice President DJ. L.- Forbis, Vice President,- Design and Construction H. C. Schmidt, Manager, Quality Assurance 1R~. W. Caudie, Prdject Manager, Nuclear Plants Texas Utilities Services, Inc. (TUSI) t P. G. Brittain,.-President.-

J. L.' Forbis,. Vice President, Design.and Construction H. C. Schmidt, Manager, Quality Assurance R. W. Caudle, Project Manager, Nuclear Plants-

- R. H.. Hickman,. Project Engineer, CISES A.' H. Boren, Quality Assurance Engineer A. Vega, Quality Assurance Engineer A. L. Bellringer, Assistant Coordinator Office Services

' S. J. Maddux, File Clerk 2

Purpose of Inspecion and Status of Project

~ The Comanche Peak Steam Electric Station (CPSES) Units 1 and 2 were docketed on July 20,1973. - TUGCO did not receive a predocketing inspection of quality assurance activities.as is required for applications submitted after September 1, 1973. Therefore, a special, announced inspection was conducted on

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. Decemb;r 3-6, 1973, for the purpose 'of determining whether or not TUGCO had (a) performed the necessary planning and scheduling to assure the timely.

development.and implementation of the~ quality assurance program, and

'(b) established and implersented those aspects.of the quality assurance program concerning ISAR development, design, and procurement which are consistent with AEC requirements and the status of the project.

At the. time of the. inspection, contracts had been signed with Gibbs &' Hill,- Inc.,

for architect-engineering services,:with Westinghouse for the NSSS, with Brown & Root,' Inc.,< for construction of the facility,.with Freese and Nichols

. Consulting Engineers for the design and erection of the safe shutdown impoundment -

' dam and a larger non safety-related dam, and with EDS Nuclear for QA consulting.

scrvices. Other contracts for environment and soils work had also been let.

Procurement specifications for the condenser, the circulating water pumps,.

the turbine generator,.-the containment liner, the containment personnel airlock,

and the containment equipment hatch had been or were being re~!ewd..

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Quality Assurance Organization TUGCO has designated TUSI to provide quality assurance services for design, engineering, procurement, fabrication, and construction of the nuclear plants.

TUSI in turn has a contract with Gibbs & Hill, Inc., the Architect-Engineer, to provide engineering, design, procurement, and quality assurance surveilhnce j

services,

t According to PSAR Figure 17.1-2, the TUSI quality assurance organization consists of the Manager, Quality Assurance, Quality Survelliance Committees, QA staff engineers, and QA site surveillance. These are discussed in detail below.

a.

Manager, Quality Assurance Minimum qualifications, duties, and responsibilities for the position have been established and were reviewed by the inspector; however, these requirements have not been included in the Corporate Quality Assurance Program or the CPSES Quality Assura. ice Plan. The Manager, Quality Assurance is a graduate engineer, and a registered professional engineer. He has 18 years experience in power plant engineering, construction, and operation, and two years experience as manager af quality dssurance. He reports directly to the TUSI president to provide independence from the construction

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and engineering organizations.

The CPSES Quality Assurance Plan requires the Manager, Quality A'ssurance to review the status of the quality assurance program with the TUSI president at least quarterly. The first review meeting was held on October 10, 1973.

The agenda of the meeting was available for the inspector's review. The next meeting is scheduled for January,1974.

b.

Qualhy Surveillance Committees The inspector examined the makeup and operation of the Quality Surveillance Committees and determined that the Quality Surveillance Committee, Design is not functioning as described in the PSAR and the quality assurance manuals.

Paragraph 17.1.1.3. of the PSAR and paragraph 2.3.2. of the Corporate Quality Assurance Program both state that the Quality Surveillance Committees for both design and construction act to ensure that adequate quality measures are being taken during plant design and construction.

In addition, the paragraphs state that both committees review plaut designs and specifications; that the Quality Surveillance Committee, Design, h-the responsibility to review the QA/QC programs of the A-E, the NSSS

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supplier, and other equipment vendors and provide sufficient surveillance to assure proper implementation of these programs; that the Quality Surveillance Committee, Construction, has a similar task with respect (continued)

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to tha Constructor and the various subcontractors; and that the committees will meet at least quarterly.

Tlie inspector determined that no committee meetings had been inld and that the committees had not reviewed the QA/QC programs of the A-E.

Gibbs & Hill, Inc., the NSSS supplier, Westinghouse, or the constructor, Brown and Root, Inc. The lack of implementation of part of TUSI's quality assurance program (the Quality Surveillance Committee, Design) appears to be contrary to Criterion II of Appendix B to 10 CFR 50, since design and procurement work are in progress.

A TUSI consultant,' EDS Nuclear, had reviewed the Westingtouse "PWR Systems Quality Assurance and Reliability hlanual"; the Gibbs & Hill, Inc.,

" Quality Assurance Manual for Nuclear Power Plants"; and portions of the Brown and Root, Inc., " Quality Assurance / Control Manual for Nuclear Projects, Construction Phase, Volume II". Although EDS Nuclear submitted approximately 19 general and 200 specific comments to TUSI, the comments had not been discussed with the three contractors.

c.

Quality Assurance Staff Engineers Minimum qualifications, duties, and responsibilities for these positions have been established and were reviewed by the inspector; however, the requirements have not been included in the Corporate Quality Assurance Program or the,CPSES Quality Assurance Plan.

There are two QA, staff engineers and they have been in their present positions since July,1973. Both are graduate engineers with 6 to 10 years experience in engineering and power plant operation. Both have completed the NUS Corporation video tape self training course, " Introduction to Nuclear Power",

which required between 150 and 200 manhaurs. In addition, each has participated in other training courses and experiences. The inspector verified that the training and qualifications of each staff engineer were documented in t'.ir personnel folders. Training programs for 1974 had not been formulated.

d.

Quality Assurance Site Surveillance Since site construction has not begun, the QA site surveillance staff has not been hired.

4.

Quality Assurance Program a.

Quality Assurance Instructions Accordit,g to paragraph 17.1.1.2. of TUGCO's PSAR, the Corporate Quality Assurance Program and the Comanche Peak Steam Electric Station Quality Assurance Plan are the primary documents by widch TUSI assures effective (continued)

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control of all project quality-related activities. Tne Program specifies the quality requirements to which the CFSES,QA Plan will comply, and the Plan is the document by which the requirements of the Program are transformed into specific procedures, methods, and techniques.

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Paragraph 1.4.1. of the Program indicates the Plan will be specifically

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tailored to the characteristics of the projects A-E, NSSS Supplier, and

. Constructor, and will provide detailed information in the form of procedures to assure compliance by all involved individ*.lais, j

Prior.to the inspection of December 3-6, 1973, the inspector examined both j

'the Corporate Quality Assurance Program and the CP3ES Quality Assurance

' Plan and compared them against Appendix B of 10 CFR 50 and AEC Guidance.

During this in-office examination, the inspector determined that although most of the requirements had been included, certain AEC requirements and guidance had b2en o_mitted. - The omis'slons were confirmed during the inspection of December 3-6. These omissions, which are described below, appear to be contrary to Criterion II of Appendix B to 10 CFR 50 which states in part:

i'The applicant sha11 establish at the earliest practicable time,

. consistent with the schedule for accomplishing the activities, a quality assurance program which complies ivith the requirements of this appendix. This program shall be documented by written p 31icles, procedures, or instructions and shall be carried out throughout, plant life in accordance with those policies, procedures, or instructions."

The AEC requirements a'nd the im pectors findings are as follows:

(1) Reautrement: Criterion I of Appendix B to 10 CFR 50 requires that the authority and darles of persons and organizations performing quality assurance functions be clearly established and delineated in writing.,

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Finding: Neither the Corporate Quality Assurance Program nor the CPSES Quality Assurance Plan cicarly establishes the authority and

. duties of the'.TUSI staff.QA engineers or 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.

(2) Requirement

Criterion II of Appendix B to 10 CFR 50 requires that activities affecting quality shall be accomplished under suitably controlled conditions. Controlled conditions include the use of appropriate.

equipment; suitable environmental conditions for accomplishing the activity, such as adequate cleanliness; and assurance that all -

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prerequisites for.the given activity have been satisfied.

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. control of all project quality-related activitiec. Tne Program specifies y

the quality requirements to which the CPSES QA Plan will comply, and the Plan is the document by which the requirements of the Program are

' transformed into. specific procedures, methods, and techniques..

' Paragraph IM.I. of the Program indicates the Plan will be specifically _

tailored to the characteristics of the projects A-E, NSSS Supplier, and Constructor, and will provide detailed Information in the form.of procedures to assure compliance by all involved individuals.

l Prior to the inspection of December 3-6, 1973, the inspector examined bath

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the Corporate Quality Assurance Program and the CP3ES Quality Assurance Plan and compared them against Appendix B of 10 CFR 50 and AEC Guidance.

.During this in-office examination, the inspector determined that although most of the requirements had been included, certain AEC requirements and

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guidance had b2en omitted. The omis'sions were confirmed during the

' inspection of December 3-6. These omissions, which are described below, appear to be contrary to Criterion II of Appendix B to 10 CFR 50 which states in part:

" The applicant shall establish at the earliest practicable time,

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consistent with the schedule for accomplishing the activities, a quality assurance program widch complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions ~. " -

The AEC requirements and the inspectors findings are as follows:

'(1) Requirement: Criterion I of Appendix B to 10 CFR 50 requires that the

. authority and darles of persons and' organizations performing quality assurance functions be clearly established and delineated in writing.

Finding: Neither the Corporate Quality Assurance Program nor the CiSES Quality. Assurance Plan clearly establishes the authority and duties of the TUSI staff QA engineers or 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.

(2) Requirement: ! Criterion II o'f Appendix B to 10 CFR 50 requires that activities affecting quality shall be accomplished under suitably controlled conditions. Controlled conditions include the use,f appropriate.

- cquipment; suitable environmental conditions for accomplishing the activity such as adequate cleanliness; and assurance that all

. prerequisites for the given activity have been satisfied.

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Neither the Corporate Quality Assurance Program nor the FincEng:

. CF3ES Quality' Assurance Plan address this requirement.

- (3) Requirement: Criterion III of Appendix B to 10.CFR 50 specifies the requirements for design control. In addition, AEC Guidance pertaining f

to Criterion III, given in' paragraph 2.1. of ANSI N45.2.11 (draft),

7 states in part:

(a)

"A quality' assurance program for design shall be established and documented to comply with the. requirements of this standard."

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(a) '" Program documents shall identify the items and services and the -

'8 specific activities to which this standard is applied."

Additional requirements for the quality assurance 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).

s Finding: Naither the Corporate Quality Assurance Program nor the CP5ES Qual!ty 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 design as required by paragraphs 3.2., 4.1.,

j 4.2., :4.3., 4.4., and 4.5. of A19SI N45.~2.11.

i (4) - Recuirement: Criterion III of Appendix B to 10 CFR 50 specifies the

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- requirements for design control. Additional AEC Guidance pertainingto

. Criterion III, given in ANSI N45.2. II.(draft) paragraph 2.2., states in

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part: "Procedtzes shall be employed to assure that design ac.tivities are carried out in a plamied, controlled, orderly and corre.t manner."

r-Paragraph 2.2. then lists 17 categories of procedures that need to be ll considered..

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L Finding:. The CPSES Quality Assurance Plan does not contain procedures

which cover the following-i' P

(a) s Managentent review of status and adequacy of program.

I(b). Necessary training of personnel (concerning design).

. c) ' Preparation of design documents.

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(d) Specifying quality levels, acceptance standards, and record

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L (e) Making experience. reports available to cognizant design personnel.

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r (5) Recuirement: Criterion IV requires measures to b2 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.

i Finding:_ Procedure 2.4., " Procurement Administration", of the CPSES Quality Assurance Pian does not address changes in procurement documents.

(6) Recuirement: Criterion V of Appendix B to 10 CFR 50 states:

" 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 l-include appropriate, quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished."

Finding: Although paragraph 1.2.(V) of the Corporate Quality Assurance Pr> gram says that TUSI has established measures to require compliance with Criterion V, the CPSES Quality Assurance Pian does not contain a procedure which addresses or implements this requirement.

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 reviews of the quality assurance program.

(7) R _ quiremen t: Criterion VI of Appendix B to 10 CFR 50 requires in part that document control measures shall assure that documents, including

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changes, are distributed to and used at the location where the prescribed cctivity is performed.

Finding Although paragraph 1.2.(VI) of the Corporate 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 perforn:ed, the CPSES Quality Assurance Plan does not contain a procedure which addresses or implements this requirement.

(8) Reauirement: Criterion VII of Appendix B to 10 CFR 50 states in part:

"hleasures 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 (continued)

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control of quality by contractors and subcontractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services."

Additional AEC Guidance contained in ANSI N45.2.13 (draft),

paragraph 2.2., states in part: " Objective evidence shall be available for audit which substantiates a suppliers approval as an acceptable source of equipment, materials or services. Procurement source evaluation and selection measures shall provide for:

(a) Identification of organizations responsible for determining supplier capability.

(b) Establishing criteria for placement on an approved supplier source list or lists.

(c) Identification of methods to be utilized in evaluation of supplier sources.

(d) Establishment of a supplier source list or lists.

(e) Identification of documentation to provi$le objective evidence of p=

supplier source capability and qualifications.

(f) Establis'hment of methods for updating source supplier list or lists."

Finding: The CPSES-Quality Assurance Plan does not contain an implementing procedure which addresses the above requirements.

(9) Beauirement: 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.

Additional AEC G61 dance contained in ANSI N45.2.9.(draft),

paragraphs 5.5. and 5.6., states in part: " Provisions shall be established to preclude the entry of unauthorized personnelinto the storage area and to guard against larcency and vandalism. Record storage facilities shall 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., "hlicrofilm 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.

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a (10) Requirement-The additional AEC Guidance pertaining to Criterion XVIII,

" Audits", contained in ANSI N.45.2.12.(draft), paragraphs 2.2., 2.3.,

2.4., and 5.3. states in pa*t:

(a) " Management shall establish the audit personnel qualifications appropriate to the auditing of the quality assurance programs."

(b) " Auditing personnel shall have, or be given, appropriate training or orientation to assure their competence for performing required audits. "

(c)

Auditors shall maintain their proficiency...."

(d) " Records shall be maintained for all personnel actively performing audits as well as those who have previously perfor~ ed audits within m

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 effective." 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 "

Findin<n 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.

b.

Distribution and Implementation of Quality Assurance Instructions The Corporate Quality Assurance Program was approved by the TUSI President (TUGCO Executive Vice President) and the TUGCO/TUSI Manager, Quality Assurance prior to the inspection. Copies had been distributed and the program had been lmplemented. Accorciing to class attendance rolls, which were reviewed by the inspector, 23 individuals (all but three engineers and one file clerk) haci received approximately three hours training in the meaning and implementation of the Program.

During the inspection at the corporate headquarters, the inspector determined that the procedures contained in the CPSES Quality Assurance Pian were still in draft form, that none of the procedures carried a signature of approval, and that most manuals in the offices contained only two or three procedures (usually 2.1., 2.3, and/or 2.4.). The Manager, Quality Assurance indicated that the followlsg procedures had been fully implemented:

s 1.f. " Organization" e 1. " Correspondence, Drawing, Document, and File Control" 2.3. " Design Verification" (continued)

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-12 2.4. " Procurement Administration" 4.0. " Auditing" He also indicated that the following procedures had been partially implemented:

2.5. " Licensing" 2.10. " Record Retention" In addition, he indicated that the following procedures had not been implemented 2.7. " Design Change Control" 2.9. " Quality Assurance Deviation Administration" 2.12. "Interf ace Control" According to the Manager, Quality Assurance, procedure 2.1., " Correspondence Drawing, Document, and File Control", had been reviewed with the TUSI clerical staff, but not the TUSI engineers.

I The lack of approved procedures and the inadequacies in distribution and full implementation of the existing pro:cdures appears to be contrary to Criterion II of Appendix Il to 10 CI R 50 which states in part:

"The applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the activitics, a quality assurance program which complies with the requirements of this appandix.

This program shall ba documented by written policies, procedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions. "

5 Document Control The document control system was examined and found to be functioning as described in the CPSES Quality Assurance Plan..

EDS Nuclears' comment letter dated July 3,1973, concerning the procurement specifications they had reviewed, was selected to test the effectiveness of the document control system.

the receiving book and given the number EDT-28 (shorthand cod 28th piece of correspondence from EDS Nuclear to TUSI). In the document storage room, the file clerk looked up EDT-28 in the computer printout and was referenced to File No. 5214, " Containment Liner". 'Ib inspector verified that the file contained the comment letter, TUSI's letter transmitting their comments partaining to the procurement documents to Gibbs & Hill, Inc., (TUSI's comments incorporated EDS Nuclears' comments), and the response received from Gibbs & 11111, Inc., dated August 7,1973.

response letter was still being actively pursued.The inspector was informed that the G-H (continued) k

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'13-From the document storage room, the inspector obtained and then examined two contracts for services (one with Freese and Nichols Consulting Engineers for the safe shutdown impoundment dam, and the other with Brown and Roor, Inc.,

for the construction of the plant) and twc purchase specifications (for the circulatir, water pumps and the condenser). The inspector also examined the comments which had been generated by EDS Nuclear for TUSI during quality assurance reviews of purchase specifications for the containment liner, the

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containment personnel air lock, and the equipment hatch. The inspector found that TUSI had conducted QA reviews of the procurement documents and that QA requirements had been incorporated into the procurement documents; hovmver, documentation of the QA reviews was not in the files in the document storage room, but was held by the particular engineer who conducted the review.

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Audits TUSI has prepared and implemented a procedure for auditing. Proadu re 4.0.,

" Auditing", which is a part of the CPSES Quality Assurance Plan, describes the audit system and contains checkUsts for performing internal audits, design and engineering audits, vendor manufacturing audits, and construction audits.

TUSI conducted one internal audit e lugust 30, September 5, and 6,1973, of their project management, document control, and record files. They also conducted one audit of their NSSS supplier, Westinghouse, on September 24-28, 1973 An audit of their A-E, Gibbs & Hill, Inc., is scheduled for the week of pasa December 10-l?, '.973 Two internal audits and five external audits are presently scheduled for 1974.

The inspector reviewed the audit schedules for 1973 and 1974 and the docutmntation of the completed audits which included work sheets, checklists, reports of the results, and responses (of the internal audit only) to the audit results. Additional details of the audits are as follows:

Internal Au_dit a.

The internal audit revealed one deficiency in project management, three deficiencies with drawing and document control, and twelve deficiencies with correspondence and files control. The Project Manager-Nuclear Plants

' responded to the audit on October S,1973, in rather general terms and then submitted a supplemental response during November in which each audit finding and all examples of deficiencies were addressed. At the time of the inspection, the supplemental response w_s still being reviewed for acceptability by the QA staff engineers.

b.

Westinghouse Audit The audit of the NSSS contractor (actually three Westinghouse Divisiors and one subcoatractor) was conducted to determine compliance of the NSSS

. suppliers quality assurance manuals with Appendix B of 10 CFR 50 He adit (continued)

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identified 55 violations of /sppendix B. Tn: audit was conducted by the Manager, Quality Assuraace, two staff QA engineers, and a QA consultant from EDS Nuclear. The breakdown of the audit is as follows: On September.'.4, tia manufacturer of the reactor internals, Westinghouse -

Pensacola Divisior;, was audited and sixteen violations of Appendix B were 1 lentified. On September 25, the reactor vessel manufacturer, Combustion Engineering, was audited and ten violations of Appendix B were identified. On September 26, the Westin;; house-Electro-Mechanical Division was audited and eleven violations of Appendix B were identified.

And on September 27 and 28 the team audited the Westinghouse PWR Systems Division and eighteen violations were identified.

The results of the audit were documented and the inspector reviewed the repo rt, West'nghouse had been asked to respond to each of the 35 apparent violations of Appendix B, but TUSI had not received Westinghouses' response at the time of this inspection.

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' DETAILS 11 Prepared by: M. W. Peranich l

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Persons Contacted-Texas Utilities Generating Company (TUGCO)

• P. G. Brittain,' Executive Vice President J. L..Forbis,. Vice President, Design and Construction H. C. Schmidt, Manager, Quality Assurance i

R. W. Caudle, Engineer-in-Charge Texas Utilities Services. Inc. (TUSI)

P. G. Brittain, President J. L. Forbis, Vice President, ~ Design and Construction H. C. Schr'dt, Manager, Quality Assurance R. W. Cau.

Project Manager, Nuclear Plants L

R. H. Hickm.

')roject Engineer, CPSES W. E. Garrisot end Electrical Engineer

, T, D. L..Keating, Ls.d Nuclear Engineer i

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B. J. Murray, Lead Civil Engineer l

A. H. Boren, Quality Assurance Engineer A. Vega, Quality Assurance Engineer

-r-S. J. Maddux, File Clerk.

l-2 1 Scope of the Inspection

. The scope of the inspection included the selective examination of Project Engineering Activities, and to a' lesser extent, rela'ted activities of the QA L

organization. Examinations included a review of the status of development and implementation of the applicant's_ Q A program pertaining to the TUSI organization

' performance, or control, of activities for P3AR Development, Engineering-Dasign, and Procurement. The acceptability of the QA program was measured against the requirements of Appendix B to 10 CFR 50, tLe requirements of AppendLx B as further clarified by "AEC Guidance _on QA Reciuirements During the Design &

Procurement Phase of Nuclear Power Plants"' dated June 7,1973,(AEC Guidance),

_ and PSAR Section 17, '" Quality Assurance".

-For those activities selected for examination particular attention was given to:

(1) establishment and execution of the program, (2) training of personnel, (3) review of program by management,;and (4) organization.

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Project Engineering Organization i

The Project Engineering organization was found to be generally consistent with' that described by Figure 17.1-2 of Section 17 of the PSAR. Assignments _had been A

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-17 which appears to provide acceptable control of external and internal response responsibility for PSAR changes generated as a result of Licensing questions.

At the present time, Proccoure 2.5 and followup instructions required by the procedure have not been implemented for on going activities. Sufficient program documentation does not exist in TUSI files to confirm that:

a.

PSAR data, originated either internal or external to TUSI, is reviewed in accordance with regulatory requirements; b.

Original organizations responsible for the preparation, review and approvals of P3AR data are identified and documented; and c.

Changes to the PSAR in addition to those initiated by Licensing questions are also: identified; documented; and controlled in a manner which will assure their timely incorporation in the PSAR and distribution to those performing design activities that may be affected by these changes.

In addition, it was observed that TUSI performed reviews of the A-E's Project Procedures Manual did not determine that the A-E had acceptable procedures to control A-E initiated changes to the PSAR.

5.

Design Activities As further clarified by the applicant's organization, design control and design committee activities discussed in the application do not include direct design responsibilities. The primary function of the Project organization, in matters of QA, is to assure that contractor design documents contain adequate technical and quality requirements. Instructions regarding this activity are contained in Procedure 2.3, " Design Verificat'on". Assignments, for each document to be reviewed, are made by the Project Engineer to the engineer (s) most technically knowledgeable regarding the subject.

Selective examhtations of the project engineering design control activities resulted in the following findings:

a.

Draft Procedure 2.3 has not been implemented nor is it being utilized by lead discipline engineers during the performance of their design review activities. The inspector observed that one part of the instruction, the Drawing / Document Review Sheet. was being utilized by some of the

" Responsible" engineers,

b.

FSAR Section 17.1.1.1.2(1) includes a commitment to establish and/or review design criteria. AppendLx A of Procedure 2.3 is intended to satisfy this commitment. The. Responsible electrical engineer was proceeding with the further development of the worksheet referenced by Appendix A.

However, Procedure 2.3 does not include instructions of sufficient detail (continued)

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8 to inform the engineer preparing the "worksheet", especially those that are less experienced regarding the activities of the project, how to establish a " List of all design criteria... the system (or document under review) is to satisfy". 'Ih Instructions provided outlines, in general terms, data and documents that must be considered but does not discuss where and when the information can ba obtained and who, as appropriate, should provide it.

Measures have not been implemented to identify the safety significance of I

c.

cach " Tickler List" entry assigned to Responsib1' engineers for design verification purposes. The Project Engineer sta ed that since all items reviewed by the Responsible engineer will receive a review equal to that required for "Q" list items, specific identification of safety class for each document was not necessary.

Th2 scope of Procedure 2.3 stat:s that the purpose of the procedure is to l

establish and implement a system of Design Verification of "Q" items.

P3AR Section 17.3 ("Q" List) states: "The list identifies those items within the scope of the Nuclear Quality Assurance Program established to meet the requirements of Appendix B to 10 CFR 50" -

The inspector's selective examination indicates that neither the instructions of Section 17 of the PSAR or the CFSES Quality Assurance Plan provide clear and detailed instructions that would be required should a system be initiated to implement " equal" Design Verification measures for safety or non-sucty related items.

In addition, without identifying the safety significance of documents by some means, it is not readily apparent just how TUSI would determine which records would be retained in accordance with AEC-Guidance of N45.2.9.

"AEC-Guidance"in N45.2.ll notes that instructions should be prepared in d.

regard to " industry experiences".

The CP3ES Quality Assurance Plan did not include instructions which would provide TUSI with a means to be informed of nuclear power plant experiences or require that the impact ef such information be appropriately considered during the design, or other phases of the nuclear project.

Procedure 2.3 requires that a Design Verification List be developed.

e.

A draft of this document, not presently included in the manual, was made available for inspection.

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Measures which transmit TUSI-originated review comments to G&H,

.or other contractors, do not presently provide a means to readily assure appropriate response to and resolution of such comments.

-Records examined included File #5410, Electric Motors for Specification No. 2323-GSI,' dated 8/27/73, and present use of the Drawing / Document Review Sheet.

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Examination of File #00125 observed that Design Review Committec meetings have been implemented; however, the meeting records examined did not identify the safety significance of the documents reviewed by the committee.

h. - Examinatloa of the Responsible civil engineers facilities and available reference library revealed that only personal and outdated ACi code reference documents were ava"able for Design Verification Reviews..

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' Procurement Activities The status of project procurement initiated by the applicant was discussed with r

members of the TUSI organization. Examination included a selective review of applicant-awarded procurement documents and preliminary engineering

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specifications bsing prepared by contractors that had been trans'mitted for TUSI review and comment. Documents reviewed and discussed with the TUSI organization included those prepared for, or by, the Nuclear Steam System Supplier, the Architect-Engineer, the Safe Shutdown Impoundment Dam Design Consultant; and the soils consultant.

Members of the applicant's organization acknowledged that contractors ivere proceeding with activities of P3AR Development and Engineering-Design. Not included in this inspector's examination was the procurement document awarded to constructor (Brown & Root).

The inspection of the activities of the' applicant's staff. or related project documents, prepared by the applicant or by the applicant's engineering contractors, confirmed that the applicant and his contractors had initiated project activities subject to the provisions of AEC QA regalations in the areas of P3AR Development,

- Engineering-Design, and Procurement (for applicant's pro:.urement of contractor

' services and NSSS procurement of the reactor pressure vessel).

Procedure:2.4, " Procurement' Administration" contains the instructions developed by the applicant to control project pro'curement activities.

Selective examinations' of the procurement activities resulted in the following findings:-

lThe applicant had completed an audit of the NSSS corporate QA programs.

a.

Reviews of the A-E QA program (Project Procedures, Manual and Procurement Manual)'were stated by the applicant to be 5076 complete. The QA program y

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of the dam designer and' constructor' had not been submitted for applicant review.. Observations confirmed that TUSI had not yet ascertained the.

acceptability of the A-E and dam designer and constructors' QA programs for on-going activities. The applicant did have an audit of the A-E scheduled for the week following oar inspection.,

b..

Examination of the NSSS_ contract document disclosed that the delegation of

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TUSI, NSSS, an'd interface responsibilities with,other organizations had l

,been identified in the procureinent document..

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' c..

Tn' e A-E had prepared two preliminary specification documents (" Electric

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Motors" and '* Containment Liner") having safety significant applicabili y; however, final A-E prepared procurement documents of this type had not -

been submitted to 'IUSI for contract award.

d.

Procedure 2.4 did not include instructions which clearly defined the seqeence l

.of " interface events" between the applicant and the A-E in regard to the preparationi review, approval, final preparation by A-E, award of the contract by the applicant's organization, and subsequent control of changes' to awarded procurement documents.

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c.

Procedure 2.4 does not provide instr"ctions regarding the control of' y

documentation for TUSI-performed reviews and approvals of applicant-originated procurement documents.. Examinations of the TUSI File folders

for contracts awarded to major contractors did not disclose documentation pertaining to TUSI reviews and approvals of those procurement actions.

However, examinations ofaselec'ted procurement documents for specifications '

m of QA program requirements did not disclose' any substantive deficiencies.

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- Procedure 2.4 does not inclusic specific instructions to inform the Responsible reviewing engineer how, or by what guidelines, he is to determine the

. adequacy of the'f_ive basic provisions of Section 5.1 (also of N45.2,, Part 5)

. which are to be addressed in each procuremen: document.

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