ML19344F277
| ML19344F277 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/11/1974 |
| From: | Crossman W, Madsen G, Stewart R US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19344F268 | List:
|
| References | |
| 50-445-74-02, 50-445-74-2, 50-446-74-02, 50-446-74-2, NUDOCS 8009150066 | |
| Download: ML19344F277 (10) | |
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m U. S. ATO!IC ENERGY C0?CIISSION DIRECTORATE OF REGULATORY OPERATIONS REGION IV i
RO Inspection Report Nos. 30-445/74-2 and 50-446/74-2 Applicant:
Texas Utilities Generating Company Docket No. 50-445 and 1506 Commerce Street Docket No. 446 Dallas, Texas 75201 a
Facility:
Comanche Peak Steam Electric Station License No.
None Loca. ion:
Somervell County, Texas Category A Type of Licensee:
Type of Inspection:
Special, Announced, QA Inspection Dates of Inspection: June 27-28, 1974 Dates of Previous Inspection: March 13-14, 1974 Es6-7/8/7k Reactor Inspectors:
W. A. Crossman, Senior Re tor Inspector.
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W. G. Hubacek, Reactor Inspector
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Reviewed By:
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L. Madsen, Chief, Reactor Construction and Date Operations Branch, RO:IV 8009150 18.*u
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ms1 RO Inspection Report No. 50-445/74-2 and 50-446/74-2 DISTRIBUTION:
H. D..Thornburg, RO:HQ'(1).
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RO:H entral. Files-(1)-
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.L:HQ (13) 1ji PDR:HQ Local.PDR NSIC DTIE.
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fi StP.O!ARY OF FINDIUCS I.
Enforcement Action None II.
Licensee Action on Previously Identified Enforcement !!atters The CPSES Quality Assurance Plan has been revised and issued.
The previous concerns have been resolved.
(Details, paragraph'C)
I III. New Unresolved Items None IV.
Status of Previously Reported Unresolved Items None outstanding.
V.
Design Changes None VI.
Unusual Occurrences None VII. Other Significant Findings O
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A'.
The A/E's QA policy and procedures are not adequate for the
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status of the project.
(Details, paragraph D) l B.
The Plant Constructor's QA Manual is currently being revised
.to incorcarate applicable portions of 10 CFR 50, Appendix B requirements.
(Details, paragraph F) s VIII. Management Interview On June 28, 1974, at the conclusion of the inspection, a management j
meeting was held tofdiscuss'the results of the inspection.
The following' individuals were in attendance.
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. Texas Utilities Services, Inc. (TUSI)
R. U. Caudle, Project Manager, Nuclear Pl' ants R. H. 'Hickman, Project Engineer, CPSES A.~Vega, Quality Assurance Engineer Atomic Energy Cocmission (AEC)
- 11. A. Crossman,-Senior Reactor Inspector W. G. Hubacek, Reactor Inspector R. C. Stewart, Reactor Inspector R. F. Warnick, Reactor Inspector i
The inspectors described the purpose of the inspection and then discussed the following findings:
A.
Actions' to correct previously identified violations were examined.
and implementation was verified. This item is closed.
(Details, paragraph C)
B.
The Gibbs & Hill (G&H) QA documents are not adequate for the
' status of the project.
The inspectors cited the following reasons:
1.
The PSAR and the "G&H Project Guide" are not consistent in the definition of the approved QA policy and procedures.
2.
.The G6H QA policy.and procedure documents do not commit G&H to the ANSI Standards contained in the "AEC Guidance".
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-t 3.. -The requirements of the R9SI Standards have not been addressed in the G&H QA procedures.
TUSI representatives indicated.they would obtain clarification of which G6H QA policy and procedure documents are applicable.
They'also indicated that G&H has committed themselves to the ANSI Standards specified in the "AEC Guidance" and that TUSI expects G&H to incorporate implementing procedures in G6H.
yQA policy and procedures manuals.
(Details,. paragraph D)
.C.
The Brown &' Root, Inc. ' (B&R) QA/QC Manual for.Muclear Projects,
. Construction Phase, Volume II, was found to be unacceptable to TUSI'in that'the Manual was-deficient in meeting applicable
- portions of'10 CFR 50, Appendix B.
TUSI representatives stated that the-manual is currently being revised.
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The inspector observed, that the B&R Document 5" Procedure For
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Procurement, Repair and Disposal of Small Tools and Construction Equipment", dated August 8, 19 4, does not-
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identify QA requirements for-this category of items or
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equipment to be used'on safety related systems or components. ^
.(Details, paragraph F).
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3 E.
The inspectors briefly reviewed the Project Echedule with the TUSI representatives and emphasized the neeT for timely
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development and implementation of the contrYctor's QA plans 2-and procedures relative to the pending Limited Work Authorization.,
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F.
Warnick stated that effective this inspect'iifts, he would no O
longer be the principal inspector for Comanche Peak, but that W. A. Crossman' will be the principal 'cihi, tact in RO:IV.
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3 32 DETAILS A.
Persons Contacted Texas Utilities Services, Inc. (TUSI)
R. W. Caudle, Project Manager, Nuclear Plants R. H. Hickman, Project Engineer, CPSES A. Vega, Quality Assurance Engineer Brown & Root, Inc. (BER)
T. Gardner, QA Engineer B.
Scope of Inspection This special, announced inspection was a followup-examination and review of the applicant's QA Program in order to verify, through objective evidence, whether the applicant and the applicant's contractors, subcontractors, and vendors have:
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1.
Implemented the Comanche Peak Steam Electric Station (CPSES)
Quality Assurance Plan consistent with the project status.
2.
Established a means to evaluate and document the effectiveness 7:g:
of the program.
3.
And performed the necessary planning and scheduling to assure timely development and implementation of the QA Program, including engineering, procurement, vendor and construction surveillance.
r In addition, the CPSES QA Plan was examined and reviewed to determine if the areas of RO concern, identified during the previous inspection 1/,
were resolved.
C.
Previously Identified Violations 01 of the previously unresolved deficiencies identified during the iaspec cions conducted December 3-6, 1973 and March 13-14, 1974 have been resolved.
For each of the unresolved previously identified violations of Appendix B, the current findings are described below.
The numbers correspond to those used in the letter to Perry G. Brittain from E. Mortis Howard, dated January 7, 1974, advising TUCCO of the violations.
1/ RO Inspection Report Nos. 50-445/74-01, Details, paragraph C, and 50-446/74-01, Details, paragraph C.
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Section'2, " Project Engineering" of the.CPSES.QA Plan was revised to make the> requirements of ANSI Standards, Appendix B to 10 CFR 50, and.TUSI QA requirements applicable to all safety related activities.. This item is closed.
Item 1.h.
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Paragraph 2.1.5.7.2has been added to Procedure 2.1.
It states, "QA documents, including changes, such'as the QA Program and QA Plan willibe distributed to and used at work locations cnd controlled according to Section 1.3. of this Manual".
This-item is closed.
Item 1.1.
- Step 1 of paragraph-2.4.5.2. has been revised to state that
" Vendor qualifications for the bidders list will be judged on the j-basis of the criteria listed in Section 2.4.5.6. of this
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procedure." This item is closed.
Items 2.c.,
d.,
e.,
and f.
All procedures except Section 3 have been implemented.
Section 3 pertains to project construction' surveillance and is not needed for the present status of the project. Documentation pertaining to the distribution and implementation of Revision 1 of the QA Program and QA Plan was reviewed. No deficiencies were noted.
These. items are closed.
Item 2.g.
The first paragraph'of procedure 1.5. has been revised to include duties, responsibilities, and reporting functions for all personnel involved in quality related activities.
This paragraph references the. minimum job. qualification. requirements for all project engineering and-QA personnel.
Procedure 1.8. has'been revised and now specifies the minimum
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training requirements-for QA and project personnel..The inspe'ctors revicued'the training folders of two_QA engineers..
No' deficiencies in'the-training program or documentation were noted.
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' Paragraph 2.1.5.8., " File Access Control" has been added to procedure 2.1.
It; specifies the procedure to be followed to remove documents from the file'and to return removed documents to the file.
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e p r Paragraph 2.10.5. of procedure 2.10. " Record Retention" has been revised to specify the procedure for removing documents from storage and for returning removed documents to storage.
Procedure 1.0. and 2.4. have been revised to clarify TUGC0 and TUSI involvement in the procurement process.
The QA plan was reviewed and frequencies were specified to replace the general term " periodically".
For example:
the canual will be reviewed " annually".
This item is closed.
i Items 3.a. and b.
Design Review Committee minutes indicated that monthly meetings vere held in February, March, April, and May.
The June Committee meeting was cancelled because of absence of pe.rsonnel.
t Quality Surveillance Committee minutes indicated that meetings were held in January, March, and April, thus co= plying with the requirement that the Co=mittee meet at least quarterly during the design and construction phases of the CPSES project.
The QA/QC programs of the architect-engineer, the NSS supplier and the' safe shutdown impoundment dam designer-constructor have been reviewed by the TUSI QA staff.
QA staff work was reviewed by the Quality Surveillance Committee.
These items are closed.
D.
A/E's QA Program and Procedures The three members of TUSI's QA staff and one QA consultant conducted an extensive audit on January 15-17, 1974, of their A/E's QA program and procedures. They examined G&H's Quality Assurance Manual, " Project Procedures Manual", and PSAR Chapter 17.1.2. and the implementation of these manuals, and compared them against Criteria I, II, III, IV, V, VI, VII, XVI, and XVIII of Appendix E to 10 CFR 50, and the ANSI Standards specified in AEC's " Guidance on Quality Assurance Requirements During Design and Procurement Phase of Nuclear Power Plants", (AEC Guidance).
The TUSI audit identified deficiencies in G&H's QA manuals (34 deficiencies) and their implementation (18 deficiencies).
TUSI received G&H's responses to the identified deficiencies and found 18 of them inadequate.
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The inspectors examined the TUSI' audit results and,then made a cursory. review of the following C&H QA documents:
- 1.. " Quality Assurance Manual for Nuclear Power Plants",
II General Revision 2,- dated December 1973.
2.
" Project Procedures Manual", dated March' 1972 including General Revision dated Dece=ber 1973.
3.
"G&H Project Guide Job No. 2323".
4.--PSAR, Chapter'17.1.2.
The inspectors _noted the following general deficiencies during their. review of the manuals:
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The definition of G&H's QA policy and procedures is not clear.
- PSAR Chapter 17.1.2. indicates the " Project Procedures
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Manual" and PSAR, Chapter 17.1.2. constitute the approved
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QA policy and procedures. The "G&H Project Guide" indicates a
the " Project Procedures Manual", Quality Assurance Manual for Nuclear Power Plants", PSAR Chapter 17.1.2., and an internal memo dated April 25, 1973, all govern the conduct.
of QA services provided by G6H.
2.
The C&H policy and procedure documents mentioned above do not commit G&H to-the requirements contained in AEC guidance.
3.
The requirements of the ANSI Standards contained in the AEC guidance.are not included or addressed in the G&H procedures.
Based on.the. inspectors' review of the QA documents and TUSI's audit, it_ appears that the G&H QA program documents are not adequate for the ~ status of the project.
l-E.
TUSI QA Organization QA activities of the TUSI organization were reviewed to determine j
that measures of. making management aware of the status and
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accuracy of the program were effective and being implemented.
a.
Quarterly-Review of the OA Program
-The activity of the quarterly review of the QA program is a mechanism whereby the QA-Manager reviews the performance of the.QA program and plan with the President of TUSI on a quarterly basis.
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. Quarterly reports were examined by the inspector and observed
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to fulfill Section 2 of N45.2 in this area.of management.
It was pointed out, however, that the activity does not appear to be properly addressed in the plan.
The responsibility for this function is defined for the QA Manager, but is not-described as to its-function.
b.
. Quality Surveillance Co=mittee (QSC) 1 The QSC has been reorganized and its charter redefined so that it is a more effective tool by which.TUSI management may review the status and adequacy of the QA program.
Quarterly meeting minutes examined reflected the member's evaluation of the program for which he has implementing responsibility.'
c.
Design Review Committ_e (DRC) 1 Examination of.the DRC's review of the component cooling water system (CCW) specification represented implementation in th:.s
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area commensurate with design specification progress.
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F.
B&R QA Program and Procedures
- 1. B&R QA Program Manual A followon review of the B&R Quality Assurance Program,
.as described in the CPSES PSAR, was conducted.
During the review of the B&R "QA/QC Manual for Nuclear Projects, Construction Phase, Volume II", it was observed by the inspector that as a result of a QA audit review conducted on June 6, 1974 by members'of the TUSI QA organization, the B&R QA/QC Manual was found to be deficient in that the manual does not contain sufficient detailed requirements
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that reflect the applicable criteria requirements of 10 CFR 50, Appendix B.
In discussing the matter with the TUSI representatives, the inspector was informed that the B&R QA/QC Manual is currently being revised to reflect the ANSI 45.2 Standards as committed to by TUSI in Section 17 of the CPSES PSAR.
The inspector informed the TUSI representatives that the. revised BLR QA/QC Manual will' be. reviewed during a subsequent RO inspection..
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<2..lB&R Procedures
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~The'B&R_ Monthly Activities' Report CP-1001, dated June 18, 1974
- indicates activities during the. month of May included the development'of the-format and instructions for construction procedures.. ~In addition,'nine'B&R QA i
procedures were submitted to TUSI'for review and ccmment.-
Based _on'the inspector's review of the draft procedures and TUSI' review comments, it appears that the icplementation
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~ development, is consistent with the project schedule.
During 'the procedure review, the inspector observed that the FJ.R Procedure entitled, " Procedure for Procurement, Repair, and Disposal of Small Tools of Construction Equipment", dated August 8,-1973, does not pre.ecribe
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the QA control requirements, for items or equipment purchased within the~ described category, that may be-installed or used on a safety related system.
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In discussing the matter with the TUSI-representatives, the inspector was informed that the procedure is intended as n' general _ procedure for field purchases of small_.it, ems within a limited _cr t value;_ however, the matter will be reviewed in order ensure that applicable QA controls are established witt, the described procurement category.
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