ML19344F284
| ML19344F284 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/19/1974 |
| From: | Dickerson M, Madsen G, Stewart R US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19344F268 | List:
|
| References | |
| 50-445-74-04, 50-445-74-4, 50-446-74-04, 50-446-74-4, NUDOCS 8009150075 | |
| Download: ML19344F284 (11) | |
Text
{{#Wiki_filter:m;;;+ p. w x 1,g.,' U.E S. ATOMIC ENERGY COMMISSION si?T DIRECTORATE OF REGULATORY OPERATIONS REGION IV v? RO Inspection Report Nos. 50-445/74-04 and Docket Nos. 50-445 and 50-446/74-04 50-446 Applicant: Texas. Utilities Generating Company License No. None 1506 Commerce Street Dalla s. Texas 75201' Category A Facility: Comanche Peak Steam Electric Station - Units 1 and 2 Location: Glen Rose, Texas 1 Type of Licensee: W, PWR,1161 MW(e) Type of Inspection: Special*, Announced ( i Dates of Inspection: Novembe r 7-8, 1974 Dates of Previous Inspection: July 18-19,1974 = Principal Inspector: h_ _M
- !' O' R. C. Stewa'r"t,/ Reactor Inspector Date Accompanying Inspector:
[{.), h //-/ 9-7 f-fVI. W. Dickerson, deactor Date Inspector Other Accompanying Personnel: None Reviewed'B : (/ ////F,h/ G. L. Madsen, Chief, Reactor 'Da te Construction and Operations Branch
- Quality Assurance Program implementation for Limited Work
~ Authorization (LWA-2) r5 Nh m w___.,______.
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SUMMARY
OF FINDINGS F I. Enfo rc ement-Action ' p, -None II.' Licensee Action on Previously Identified Enforcement Matters None outstanding i III. New Unresolved Items 74-04/1 B&R Procedural Control 1 1i Brown & Root (B&R) Quality Control Procedures are not being adequately controlled. Three procedures reviewed by the inspector contained either error, QCP-33, incorrect reference to i work which is to be accomplished in accordance with a different procedure, QCP-12, or were not revised, QCP-4, in accordance with the require-N ments of QAP-7 ~and QAP-8. (DETAILS, para-0,= ~" graph 3. b) 74-04/2 Freese & Nichols (F&N) Procedural Control Section 1. 0 through 8. 0 of the F&N QA progra'm manual has no apparent procedural ( 'ntrol for changes,- revision, or addition, whether they are current or if changes have been made and approved. (DETAILS, paragraph 4. c(1)) 74-04/3 F&N Status of " Corrective Action" F&N procedure Appendix G " Corrective Action", paragraph 6. 5 contains an indefinite statement relative.to determining the status of corrective action. (DETAILS, pa ragraph 4. c(2)) 74-04/4' FLN Procedure Development 'F&N is developing a procedure for inspection and testing' to accompany an SSI Shutdown Dam inspection and test schedule. (DETAILS, paragrap{ y-
- 4. c(3))
- (continued) K 4 4 mmm ev.h
' 74-04/5 FLN Audit Procedures t? Review of a FLN report of an internal audit -conducted October 14-15, 1974 revealed that the timeliness of report submittal and requirements of paragraph 8.26 of the FLN QA program L relative to corrective action were deficient. (DETAILS, paragraph 5) 74-04/6 Mason-Johnston (M 's) Testing / Inspection Procedures The Mason-Johnston & Associates (M-J) QA Manual identifies the requirements for written procedures for on-site testing and inspection ~ activities. The procedures have not been fully developed. (DETAILS, paragraph 7) IV. Status of Previously Reported Unresolved Items 74-03/A TUSI has provided a QA plan supplement which includes SSI dam interface responsibilities. The matter is considered resolved. (DETAILS, paragraph 2) 74-03/ B An additional F&N QC procedure, Appendix B, "SSI Dam Project External Interface Control" required to meet and facilitate commitments associated with interface activitiet and respon-sibilities has been written and app. oved. This matter is considered resolved. (DETAILS, paragraph 4a) 74-03/C F&N Procedure, Apperidix I, " Conduct of Audits", , has been revised to clarify areas regarding corrective action, action required by designated responsible personnel, and to provide an audit s che dule. This matter is considered resolved. (DETAILS, paragraph 4(b)) 74-03/D The newly developed TUSI QA Plan Supplement provides specific surveillance activities during ~ construction of the SSI dam. This matter is considered resolved. (DETAILS, paragraph 2) (continued) ~
g w ..y 4 .74 -03 / E The Brown & Root (B&R) on-site construction ij _ procedures have not been fully developed. This - - matter ~ remains open. (DETAILS, paragraph 3.a) V. Design Changes None VI. Unusual Occurrences -- No ne V II. Other Significant Items i A. Project Status l i-Site preparation, within the scope of the Limited W, rk l Authorization (LWA), ' began October 18. Construction of [ i the access road and clearing / grading of the plant area has been initiated; however, recent rains have delayed this activity. The cognizant B&R site representative stated that as a result of the inclement weather, work on the Safe Shutdown Impoundment Darn (SSI) will not '=~ start until the first week in December. There are approximately 75 contractor personnel on-site. VIII. Management Interview - At the conclusion of the inspection on November 8, a management interview was held with the following licensee representatives in attendance: ~ Texas Utilities Service. In c. (TUSI) J Mr. H. C. ~Schmidt, QA Manager Mr. A.' Vega, QA Engineer Mr. R'. G. Tolson, QA Engineer M r.' R. wi. Kis sing e r, Civil. Enginee r Mr. C. H. Gatchell, Resident Manager ~ 1 Freese L-Nichols (F&N) Mr. :-L. B. Freese, QA Manager M r. 'J. M. Dodson, Resident QA Manager Mr. - W. H. Galbraith,- Assistant Resident GA Manager Mr. J. R. Humphrey,' QA Coordinator (continued) -
o= ,cu- ' y f: + -5': ' gg.? B rown - h -Root.. InE(B & R)- s0 "
- M r. c C. ' E. : B3nin,:.- Assi-tant' Project Manager lMr. C4 H. Ivey. Chief Project Engineer Mr. : L.1A ? Ashley, Construction Manager 1Mr.,D. _ L. Hansford, Od/QC Engineer, Structural i
.The inspectors describ'ed the purpose'of the inspection and briefly g ' outlined RO inspection practices'and. reporting of inspection find- . tng s. The inspection fin' dings, contained in Section III of the summary and ' Report Details of this report', ~ were described and discussed. In : view of the inspection findings-regarding incompleted procedural development,' the inspecto s emphasized the requirement that-prescribed implementing procedures, or instructions, must be established and issued prior to the commencement of the related -work activity. - The TUSI representatives concurred with the RO inspectors' findings. k and stated that corrective action would be initiated in the specific areas identified. OS S h O G (co ntinue d) ' E-iiEi' i L T j 4-l, 1
j V m l ) REPORT DETAILS List of Persons Contacted Texas Utilities Services. Inc. (TUSI) Mr. H. C. Schmidt, Q A Manager Mr. A. Vega, QA Engineer Mr. R. G. Tolson, QA Engineer Mr. R. M. Kissinger, Civil Engineer Mr. B. W. Carter, Civil Engineer Mr. C. H. Gatchell, Resident Manager Freese & Nichols (FLN) M r. L. B. Freese, QA Manager Mr. J. M. Dodson, Resident QA Manager M r. W. H. Galbraith, Assistant Resident Manager Mr. J. R. Humphrey, QA Coordinator [ Mr. W. L. McGrath, SSI Dam QA Administrator s Mason-Johnston & Associates, Inc. (M-J) p=== Mr. W. T. Cromeans, Resident Chief Technician Report of Subjects Inspected 1. Scope of Inspection l The scope of the inspection was limited to a follow-on review and examination of the LWA-2 QA Program Control Procedures, and Procedure Implementation, regarding on-site work activity involv.- ing the SSI Dam. l f'" 2. _TUSI LWA-2 QA Program Control Interface The document, " Comanche Peak Steam Electric Station Quality Assurance Plan Supplement, Safe Shutdown Impoundment Dam, " dated September 3,1974, Revision 1, describes the areas of responsibilities and interfacing requirements during the design and construction of the SSI Dam. The TUSI QA organization is responsible for the development, implementation, management, surveillance and auditing of the Q A Program for the SSI Dam. The QA Plan Supplement provides (continued) S- _=. A
{ } m m -a. specific surveillance activities to be performed by TUSI during U the design and construction of the SSI Dam. Areas of responsi-bility delegated by TUSI include the following: (a) The F&N organization has been delegated the respon-m sibility for the SSI Dam design, QA/QC activities, and acceptance criteria. In addition, FLN responsi-bilities including defining the QA Documentation Requirements and directing the M-J QC activities in monitoring construction activities being performed by B&R. (b) The M-J organization has the responsibility for field and subsurface exploration services. In addition, the M-J resident chief technician has site responsi-bilities for performing all QC tests on the SSI Dam as directed by FLN. (c) BLR is responsible for constructing the SSI Dam in f accordance with FLN design drawings and specifications. 3. Brown and Root, Inc. (BLR) (a) BLR construction procedures CCP-2, 3, 4, 5 and 9 ~ are at the construction site and have been approved for use. However, these procedures were not available for review by the inspector since they were in storage and had not been issued on-site. Additionally, two procedures CCP-6 and 8 are yet to be issued by B&R for review by TUSI on November 15, 1974. A list of the B&R procedure applicable to the SSI Dam are as follows: CCP-2 Excavation and Ocanup for SSI Dam Foundation. CCP-3 Selective Quarrying of Material for SSI Dam. CCP-4 Rock Processing for SSI Dam. CCP-5 Pneumatically Placed and Dental Concrete for SSI Dam. CCP-6 Embankment Core Material Borrowing and Placing for SSI. CCP-7 Filter Material Procuring and Placing for SSI. CCP-8 Shell Placement for SSI. CCP-9 Field Surveys. (continued) ~ 4
m f* .m. 8 m s During review of the BLR and FhN procedures 'the source of the dental concrete to be used for the SSI e dam could not be determined. A discussion relative. - to this matter with representatives of the licensee indicated that either an acceptable ofSsite source of' concrete would have to be established or the on-site - 7- ' batch plant would have to be in operation. In case of the latter alternative, the batch plant itself and procedures for the batch plant, now scheduled for issuance February 1,1975, may have to be expedited. (b) The inspector reviewed B&R QC procedure CP-QCP-33, " Safe Shutdown Impoundment-Dam Excavation, Soils Backfill, and Compaction Documentation and' Surveil-lance," issued August 8,1974. This procedure is intended for use on the SSI dam and replaces CP-QCP-12, " Excavation, Soils Backfill and Embankments, " issued July 1,1974. CP-QCP-12 is intended for all other site work (except the SSI dam). CP-Q CP-33 'desc ribes B&R QA involvement through audits, including the required frequency. During review of this document it was noted that the procedure improperly references QCP-24 instead of QCP-4, " Project Quality Assurance Control Records and Field". =i- - A review of QCP-4 established that the procedt$re contained revisions which were not made in accord with quality assurance procedure QAP-7, " Control of QA/QC Manuals," issued December 30, 1973, and QAP-8, " Preparation and Control for Project Procedures," issued November 16, 1973. Contrary to the require-ments of these procedures, revisions to QCP-4 had been made. improperly,1. e. ; (1) revised pages not indicated by revision number and date, (2) no vertical r line indicating the change in the right margin, and (3) only the revised pages should have been issued instead o' the enbre QCP. It was also noted during review of procedure QCP-12 that it still contains reference to site inspection organizational authority relative to the SSI dam.. This duplication provided for potential confusion with QCP-33 requirements. (continued) w R m y - 4 m__
9 m Th: dcficicnciac found during review of the foregoing procedures were discussed with the licensee who indicated that resolution of the deficiencies by DhR was already underway. However, the inspector emphasized that these errors were indicative of a deficiency in the BLR control of changes to and iss.ance of QA/QC procedures and that these matters would be reviewed during a subsequent inspection. 4. Freese and Nichols (FLN) (a) Review of Appendix B, "SSI Dam Project External Interface Control, " Rev. 0, issued September 6,1974, by the inspector, established that the proced6re had been written to facilitate commitments associated with interface activities as described in Section 6. 0., " Construction Control" and Section 4. 0 ' Design Control". This matter is considered closed. (b) A review of Appendix I, " Conduct of Audits", Rev. O, I dated September 6,1974, established that the procedure had been revised to include a reference to Appendix G, "Carrective Action", assign the action required by designated responsible personnel and to provide an audit schedule. This matter is considered closed. (c) The inspector reviewed the FLN document " Quality Assurance Program, Comanche Peak Steam Electric Station". The document includes a statement of manage-ment policy, dated July 12, 1974, Section 1. 0 through 8.0 which described the quality assurance program and Appendices A through I which are the implementing - procedures. As a result it was determined that: (1) , there is no apparent procedural control for changes, revisions, or additions to Section 1. O through 8. O although a procedure for the control of the Appendices does exist (Appendix A " Preparation, Approval and Control of Administrative Control Procedures, " Rev. O, issued September 6,1974). The individual pages do not carry a date or revision number, nor do they bear signatsry approval. (continued)
p 3 = a. m m (2) Appendix G, " Corrective Action, " paragraph n
- 6. 5 contains an indefinite statement relative to corrective action that after a reasonable period
~ of time the QA coordinator shall send a status requesi memo to th e P. E or QA' manager with ., n, ,2 a copy to the project manager. (3) F&N is in the process of developing a procedure for inspection and testing to accon.pany the SSI ' Shutdown Dam inspection and test schedule. This procedure is expected to instruct the inspector on the details of conducting or having conducted the appropriate inspection or test in accordance with the proper test procedure, acceptance criteria, frequency and specification requirement. (d) Discussion with the licensee's representative relative l-to items 4. c(1) and 4. c(2) above indicated that corrective ~ action to rectify these deficiencies would be initiated. l These matters will be reviewed during a subsequent inspection. l
- 5. -
F&N Audits - g The inspector reviewed a F&N draft report of an internal audit con-ducted on October 14-15, 1974. The. audit was performed to assess the implementation and effectiveness of the F&N QA program for the ' Safe Shutdown Impoundment Dam Project. The audit conducted by 7 FLN, utilizin~g a team leader from Nuclear Services Corporation, utilized an appropriate checklist. The repart contains a number of "Nonconformances", 'which have already been corrected. However, it was noted by the inspector that the report had not been issued formally. Issuance is required two weeks after the audit. In addition,- contrary to the requirements of F&N QA Manual, paragraph 8.2-6, the audit report did not conclude with a request that those personnel responsible for corrective action respond in writing, within two weeks, indicating-the action which will be taken and the schedule for_ accomplishment; unless,- such action and schedule were. agreed upon and are documented in the-report. The. licensee's representative stated that the report had not' been formally ~ issued but that proper adherence to th.e procedure would be provided. 1 (Continued) A a 4- E m -O
^ G 11 r - )
- ~T~ 6.
FLN Specification " Safe Shutdown Impoundment Dam" F&N specification " Safe Shutdown Impoundment Dam", Contract Document No. FN SSI-1, dated September 1974, Rev. 2, issued -{i October 21,1974, :was reviewed by the inspector. The specification contains acceptan'ce criteria and defines the acceptance testing methods. '7. Mason-Johnston & Associates. Inc. (M-J) (a) The ~M-J organization has established their on-site testing laboratory south of the proposed main dam site. Laboratory and testing equipment is being set up to accomplish the majority of all necessary testing on-site. (b) The M-J QA program requirements are contained in the document, " Corporate Quality Assurance Manual, Mason-Johnston & Associates, Inc., MJA Corporation, " dat' d l e Augus t. 22, 1974. During the inspectors review of the M-J QA program manual it was observed that QAP's contained in the manual identified requirements for implement pro-cedures or instructions. =r In discussing the matter with the cognizant M 'J representative the inspector was informed that, at the present time, there are no implementing procedures on-site; however, a schedule is being established to develop all remaining procedures prior to the activity involved. This matter remains outstanding and will be reviewed during a subsequent RO inspection. e 6 9 De te 'EF' s
A m .j s i _11 o r t 6. FLN Specification " Safe Shutdown Impoundment Dam" FLN specification " Safe Shutdown Impoundment Dam", Contract Document No. FN SSI-1, dated September 1974, Rev. 2, issued October 21, 1974, was reviewed by the inspector. The sp,1fication contains acceptance criteria and defines the acceptance testing methods. 7. Mason-Johnston & Associates, Inc. (M-J) (a) The M-J organization has established their on-site testing i-laboratory south of the proposed main dam site. Laboratory and testing equipment is being set up to accomplish the majority of all necessary testing on-site. (b) The M-J QA program requirements are contained in the do cum e n', " Corporate Quality Assurance Manual, Mason-Johnston & Associates, Inc., MJA Corporation, " dated l August 22, 1974. During the inspectors review of the M-J QA plogram manual it was observed that QAP's contained in the manual identified requirements for implement pro-cedures or instructions. In discussing the matter with the cognizant M-J representative the inspector was informed that, at the present time, there are no implementing procedures on-site; however, a schedule is being established to develop all remaining procedures prior s to the activity involved. This matter remains outstanding and will be reviewed during a subsequent RO inspection.
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