ML20003D807
| ML20003D807 | |
| Person / Time | |
|---|---|
| Issue date: | 01/27/1981 |
| From: | Breaux D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20003D796 | List: |
| References | |
| REF-QA-99900502 NUDOCS 8104010042 | |
| Download: ML20003D807 (22) | |
Text
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AV U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900502/81-01 Program No. 51200 Company:
Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Iaspection Conducted: January 5-8, 1981
- !I I Inspector:,:
- 0. F. Fox, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch
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- 0. G. Breaux, Inspector l
Date Program Evaluation Section Vendor In.Jection Branch k,
/ 'b74 f Approved by:
m C. J.(I1al), Chief Date Progr!!m 7_ valuation Section Vendor Inspection Branch i
Summary Inspection on January 5-8, 1981 (99900502/81-01)
Areas Inscected:
Implementatic: c' Title 10 CFR 50, Appendix B and Topical Report B&R-002A, including fo'. low-Jp on previous inspection findings, design document control, procureren' w sce selection, and supplier nonconformance and corrective actions.
The inspection involved seventy (70) inspector-hours on site by two (2) USNRC insp.ectors.
Results:
In the four (4) areas inspected, three (3) deviations from commitment were identified in two (2) of the areas.
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2 Deviations:
Follow-up on Previous Inspection Findings:
Corrective action committaa in a Brown and Root response to a previous deviation had not been completed as scheduled (See Notice of Deviation, Item A).
Design Document Control:
Unapproved Technical Reference Documents were contained in the Design Manual (See Notice of Deviation, Item B).
The Engineering Document Control Center did not publish a document status list as committed (See Notice of Deviation, Item C).
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l OETAILS SECTION I l
(Prepared by D. F. Fox)
A.
Persons Contacted "K. M. Broom, Senior Vice oresident, Power Group H. S. Cameron, Assistant Engineering Project Manager "J. R. Childers, Houston QA Coordinator
- H. T. Faulkner, Project Coordinator
- A. H. Geisler, Manager, Nuclear Licensing G. L. Gibson, Discipline Project Engineer, Piping Engineering J. F. Halsey, Manager Special Problems Group 4
- J. L. Hawkes, Manager, STP Engineering
- S. J. Kelley, Training Coordinator
- H. W. Overstreet, QA Supervisor, Houston Lighting and Power J. E. Padden, Manager, Engineering Documentation "R. W. Peverley, Assistant Engineering Project Manager "J. C. Shuckrow, STP Project Coordinator, STP Project
- R. J. Vurpiliat, Manager, Quality Assurance, Power Group G. H. Watkins, Supervisor, Engineering Document Control Center
" Denotes those present at the exit meet 1.ig.
3.
Action on Previous Inscection Findings 1.
(Closed) Followup Item (Report 80-01,Section III.B.3.g).
Deter-mine if the apparent breakdown of the Brown ar.d Root Vendor Surveil-lance Program was generic.
The inspector verified that a Brown and Root task force, the " Vendor Control Program," reviewed seven (7) procurement files and identified nine (9) generic areas of concern in the overall South Texas Project procurement cycle for safety related equipment.
These concerns were reported to NRC, Region IV on July 14,.980, and a new task force, the " Vendor Control Evaluation and Correction Program" was established by Brown and Root.
The task force will resolve these concerns and assure that all safety related purchase orders are sufficiently accurate and complete so as to result in the final acceptance of safety related equipment, and its documentation, by Houston Lighting and Power, for use on the South Texas Droject.
We will inspect the results of this activity during our normal inspec-tion program.
4 2.
( losed) Followup Item (Report 80-01,Section III.3.3.c.(1)).
Determine if the apparent lack of effectiveness of the Brown ar.d Root Vendor Surveillance Program was reportable under 10 CFR Part 21.
The inspector verified that the generic concerns related to the breakdown of the Vendor Surveillance Program were identified and evaluated by Brown and Root.
The generic concerns were subsequently reported to NRC Region IV as a potentially reportable deficiency by Houston Lighting and Power Co. in their letter ST-HL-2-AE-494 dated July 14, 1980 ir accordance with the provisions of 10 CFR Part 50.55(e).
Separate reporting of this breakdown in the Brown and Root Quality Assurance Program by Brown and Root under the provisions of 10 CFR Part 21 is not required.
3.
(Closed) Followup Item (Report 80-01,Section III, 3.3.h) Determine if the Brown and Root purchase order for Reactor Vertical Supoorts reflected all safety related requirements identified in the South Texas Project FSAR.
The inspector verified that this purchase order was scheduled for indepth review for inclusion of all acplicaole engineering, quality and regulatory requirements as part of the Brown & Root " Vendor Control Evaluation and Correction Program' prior to Novemcer 15, 1981.
4 (Closed) Deviation (Report 80-02, deviation 3).
Brown and Root has not implemented the overall Quality Assurance / Control Program for the South Texas Project that is described in section 17.1 of the PSAR.
The inspector verified the corrective action, generic considerations and preventive measures described in the Brown & Root letter of response dated August 8, 1980.
Specifically, differences between the PSAR and the operating QA program were identified and resolved.
A revised Houston Lignting and Power and Brown and Root " Quality Assurance Program for the South Texas Project" was submitted to NRC (NRR) on October 31, 1980.
Brown and Root commitment to implementing the revised QA Program was contained in a memorancum dated January 8, 1981, from the Group Vice Presicent, Power Group, to the Quality Assurance Manager.
5 5.
(Closed) Followup Item (Report 80-02, section I.S.6.b.(:
Determine if the Brown and Root design for the personnel airlock with inflatable seals meets applicable requirements.
a.
With respect to the acceptability of the inflatable seal personnel airlock by NRR, Brown and Root management stated that the single active failure criteria and redundancy require-ments of the Brown and Root door seal design meet, or exceed, those of the McGuire door seal design which was accepted by NRR.
Significant differences between the two (with respect to the above, only) noted by the inspector are as follows:
(1) Air lines to the STP seals do not penetrate into the containment as do the McGuire air lines.
(2) Solenoid valves in the air lines to the STP seals are designed to fail open as do those in the McGuire air lines.
Brown and Root stated that they would evaluate the design to determine if the valves should be changed to fail closed to prevent bleedback through tne instrument air supply system should an air line check valve fail.
(3) STP will use Class lE pressure switches to detect seal deflation in addition to incorporating a seal leak rate detection system rather than only decend on a control room annunciator wnich will actuate whenever any of the seals deflate as McGuire does.
(4) STP plans to incorporate two independent backup air supply systems to maintain seal inflation in the event of the loss of the instrument air system rather than the singular reserve air tank system for the McGuire seals.
(5) The STP design does not provide for test coupons of the saal material to be located in close proximity to the air-lock as does the McGuire design.
(6) The Brown and Root crocurement documents did not include the requirement for a certificate of compliance for each door seal with respect to the ability of the seal material to withstand post accident beta radiation exposure.
Brown and Root stated that this requirement will be incorporated into the next revision of the design specification (2C269 5506) for the airlock.
6 b.
With respect to the adequacy of the Brown & Root inflatable seal airlock design, the inspector determined that design specification was verified in accordance with established procedures.
The design was also evaluated using a Failure Mode and Analysis Technique which identified several potent, Al deficiencies that were subse-quently corrected.
However, the inspector identified several technical conceens with respect to door and seal pressure reten-tion capability.
As a result of these and other unanswered ques-tions, Brown and Rout management stated that they would conduct a documented formal multidisciplined design review of the personnel air lock design during the first quarter of 1981.
6.
(Closed) Followup Item (Report 80-02,Section I.D.3,c.(1)).
Verification of design inputs to stress calculations that are taken from stress iso-metrics could not be confirmed.
Brown and Root management stated that a stress isometric drawing is only a transcription (reprc- ; tion) of a certain portion of a piping system taken from a cesign verified ccmcosite piping drawing and is only used to aid in visuali:ing the piping system layout wnen stress calculations and hanger locations are determined for the system.
Stress isometric drawings are checked for completeness and correctness against the comoosite piping drawing by a checker in accordance with procedure STP-DC-002.
The inspector verified that the Stress Analysis Group (which is now part of the Support Design Group) did verify the accuracy of the type and location of supports shown on stress isometric drawings generated by them.
7.
(Closed) Followup Item (Report 80-02,Section II.B.1.a) Evaluation of the Consequences of the potential misuse of uncertified personnel for performing vendor surveillance activities.
Brown and Root management stated that they have found no evidence to date that unqualified (as distinct from uncertified) individuals performed particular inspections.
8.
(0 pen) Followup Item (Report 80-02,Section II.C.3.e) The status of the Brown and Root Vendor Control E/aluation and Correction Program will be evaluated.
The program consists of seven phases which implement the Brown and Root Management commitment to NRC to define (and subsecuently execute) a program that provides for a complete and thorough review and audit of the procurement documents, vendor control and surveillance activi-ties, and release of safety related equipment and material to the site tnat is in full comoliance with ali Brown and Root anc Houston Lignting and Power commitments to NRC.
7 The phases, approximate status, and revised initiation and completion dates provided to, or determined by, the inspector are as follows:
a.
Establish Priorities and Schedule - June 15 thru January 31, 1981
- 85% Complete versus 41% projected.
b.
Generate "PO Baseline Requirements" - November 3, 1980 thru June 30, 1981 - 15% Complete versus 54% projected.
c.
Independent NUS Audit - Septe:ber 1,1980 thru September 15, 1981 -
- 10% Complete versus 38% projected.
d.
Resolution of Audit Fird#r.;. - February 15, 1981 thru Septemoer 30, 1981.
e.
Update Purchase Orders - March 1, 1981, thru October 15, 1981.
f.
Correct Vendor Deficiencies - March 15, 1981, tnru Octooer 31, 1981.
g.
Release of Equipment & Materials - February 15, 1981 thru Novemcer 15, 1981.
Procurement of safety related equipment and materials will be closely monitored by NRC during future inspections.
9.
(Closed) Violation (Report 80-03).
Failure to meet 10 CFR Part 21 posting requirements in the facility where safety related piping stress analysis and pipe hanger design activities were being con-ducted.
The inspector verified the corrective action and preventive measures described in the Brown & Root letter of response dated Decemcer 16, 1980.
Abbreviated notices containing Section 206 of the Energy Reorganization Act and that describe the content and location of the 10 CFR Part 21 Regulations and procedures, as well as the individual to whom reports may be made, were posted in a conspicuous position at all locations were safety related activities were being conducted.
Quality Assurance Management committed to verify the posting at all locations on at least a quarterly basis.
10.
(Closed) Deviation (Report 30-03, deviation A) Qualification records of engineering personnel conducting safety related activities were not being maintained.
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8 Brown and Root did not update the qualification record files of all engineering personnel conducting safety related activities on the South Texas Project by the committed date of December 31, 1980.
This is a deviation from commitment.
See Notice of Deviation, Item A.
Brown and Root updated all qualification and training record files of engineering personnel during the inspection.
The files were less than 18% complete at tne time the ceviation was issued and were approximately 65% complete by December 31, 1980.
Brown and Root Design Quality Engineering reportedly did not sign off or approve any documents for issue since January 1,1981, that were originated or signed by any individual whose qualification or training record was incomplete or inadequate.
The inspector verified that a full time Training Coordinator was assigned to Engineering, the Engineering Procedure For Training (STP-PM-006) was revised, and that the files are currently being maintained in the access controlled office of the Training Coordinato.
11.
(Closed) Deviation (Report 80-03, deviation 3).
Training records of engineering personnel conducting safety related activities were incomplete or non-existant.
Brown and Root did not update the training record files of all engineering personnel concucting safety related activities on the South Texas Project by the committed date of December 31, 1980, See Notice of Deviation, Item A.
Refer to item 10 above for additional details.
12.
(Closed) Deviation (Report 80-03, deviation C) Hanger design and fabrication drawings were design verified and accroved with cuplicate identification numcers.
Pipe fabrication isometric drawings were revised and issued without using the next sequential revision number.
The inspector verified the corrective action and preventive measures described in the Brown and Root letter of response dated December 16, 1980.
Specifically:
a.
With respect to drawings being approved with duplicate identi-fication numoers:
(1) all affected drawings were corrected; (2) the potential for duplicate numcers being affixed to more than one drawing acpeared.to be restricted to the Support Design Group in that their drawing numoers convey intelligence (ie, the actual location of the support or hanger) whereas drawings issued by other Brown and Root design activities do not; (3) the pro-cedure for Orawing Control (STP-CD-002) will be revised by January 31, 1981 to require the Discipline Project Engineer to
9 verify that the drawing number is both correct and ;nique prior to his signing the drawing; (4) The Engineering Document Control Center Computer Program for logging in newly issued design documents will not accept a new entry if the total identifica--
tion number is a duplicate of an already existing listed number.
b.
With respect to pipe fabrication drawings being revised to indicate the type and location of pipe supports and issued without using the next sequential revision number, the title block of all such drawings issued in support of, or as part of, a calculation package will be crossed out to prevent subsequent inadvertant use of the wrong revision of the drawing by the contractor.
The original drawing will then be revised to reflect the type and issued as the next sequential revision of the drawing.
13.
(Closed) Unresolved Item (Report 80-03,Section I.O.3.b(1)).
Docu-mentation made available during the inspection did not appear to substantiate that significant safety hazards were evaluated, documented, and reported in accordance with the provisions of 10 CFR Part 21.
The inspector determined that during the first quarter of 1981:
a.
Existing files on safety concerns will be reviewed for inclusion of pertenent data relating to tne safety concern.
Sufficient information will be retained in the file Uch that the nistory and status of the safety concern will be clearly definec and that will assure meeting the record retention requirements of Section 21.51 of 10 CFR Part 21.
b.
The Engineering Document Control Center will retain all files on safety concerns.
c.
The Procedure for Evaluating and Recorting of Defects, Noncom-pliances and Deficiencies, STP-PGM-022, is being revised.
d.
Quality Assurance will audit for compliance with 10 CFR Part 21 requirements on a quarterly basis for at least the next year and annually thereafter.
14.
(0 pen) Unresolved Item (Report 80-03,Section I.D.3.b.(2)) An acparent violation exists in that Brown and Root was not adhering to their procedure for implementing 10 CFR Part 21 requirements.
The matter has been forwarded to NRC headcuarters for evaluation to determine the appropriate enforcement action to be taken.
15.
(Ocen) Followup Item (Report 80-03,Section I.B.4) Verify implementation of a management plan to assure that Commitment to NRC will ce performec as stated and be effectively implemented.
~
)
1 10 Brown and Root developed a routine system and a followuo form (NRC Action Item Commitment List) which was implemented on inspection 80-03.
In view of the reccurance of Brown and Root management not meeting one of their commitments for the last (80-03) inspection, Brown and Root Power Group executive management issued two memoranda to Quality Assurance on January 8,1981, which contain provisions for preventing reccurance of the failure to complete corrective action as committed.
The memoranda state that:
a.
All Brown and Root commitments shal. be met in the performance of our responsibilities on the project.
b.
Each NRC identified deviation, unresolved item, or other out-standing item will bc listed (as well as the individual respons-ibile for action thereon) and distributed accordingly.
c.
An internal commitment date is to be estaolished whicn is earlier (generally two weeks) than the date committed to NRC.
d.
Quality Assurance is responsible for following the imolementation and completion of corrective actions.
e.
f rior to the commitment date to NRC, Quality Assurance is to indepencently verify, by review of oojective evicence, that the corrective actions have been c:moleted.
The senior vice presi-dent is to be notified for eacn specific failure to comolete corrective action.
f.
The status of open B&R commitments to NRC will be reported at the regular STP - QAMRB meetings.
The effectiveness of these measures will be closely followed during future inspections.
16.
(Closed) Followup Item (Report 80-03,Section I.C.3.b(1)).
Objective evidence was not available that the education and experience listed on the qualification / resume sheet of all NPS (Nuclear Power Services) and ATI (Associated Technologies Incorporated) personnel who were conducting safety related activities for the Brown and Root Support Design group was in fact verified by either Brown and Root or NPS/ATI.
The inspector verified that Brown and Root recuested written confirm-ation from both NPS and ATI that the alleged education and experience for all present and future emoloyees assigned to the STP be verified.
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11 NPS and ATI provided a list of their employees whose alleged education and experience had been verified along with a copy of their procedure for Employee Verification and one sample of a complete verification package.
No misrepresentations were apparently uncovered to date.
However, verification of the alleged education and experience for six (6) of the twenty one (21) ATI employees currently assigned to the STP had not been completed as of January 7, 1981.
Brown and Root management thereupon requested on January 7,1981 that ATI complete the verification process for these employees and advised ATI that the verification must be done in accordanc; with the intent of NRC circular IEC 80-22.
The manager of the Support Design Activity which deploys these six (6) ATI employees stated that only verified and qualified personnel will be permitted to perform safety related activities on the STP.
17.
(Closed) Followup (Report 80-03,Section I.C.3.b(2)).
Objective evidence that an approved 10 CFR 50 Appendix B quality assurance program was imcosed on NPS and ATI personnel who were conducting safety related activities for STP.
The insoector verified that on Jaruary 7,1981, the manager of the Suoport Design Group notified the on-site (STP project) NPS and ATI management in writing that all work done in the Brown and Root offices (on STP) is to be done under the Brown and Root Quality Assurance Program via the use of (STP) Engineering Procedures and for them to assure that their personnel are complying with the procedures.
18.
(Closed) Followup (Report 80-03,Section I.C.3.b(3)).
Procedures which require that sufficient records be maintained for engineering and management personnel assigned to safety related nuclear projects to furnish objective evidence of their qualification to perform their assigned duties and respcnsibilities were not available during the inspection.
Brown and Root Power Division Procedere OL 035 dated June 10, ICC0 (Procedure for Verification of Education and Experience) defines the process for verifying the educational background and prior job eroeri-ence of new Brown and Root employees.
The Grouc Vice President, Power Grouc, stated in his memorandum of October 28,1980 that:
a.
The Power Group will assume the responsibility for checking (verifying) each new Power Group professional as they are hired (using procedure OL 035) beginning May 21, 1980.
12 b.
Letters were mailed on Septemoer 15, 1980, requesting documented evidence of the educational background and prior job experience for each STP engineer, designer and project control professional employed prior to May 21, 1980.
c.
Most of the responses have been returnad, examined, and placed in the individual's file.
d.
Adherence to Power Group Procedure JL-035, and surveillance of contract companies, will assure trat every professional person working on any Power Group job will have documented evidence of his or her education and work experience.
This item completes an Inspection of emplofment practices at Brown-and Root in that:
(1) tne education and w3rk experience infor-mation contained in employees' job applicat ons are being verified i
cy the employing organization; and (2) there is objective, docu-mented evidence /recorcs that attest to the education and experience of both permanent and contract employees.
C.
Design Document Control 1.
Obiectives To determine if approved procedures have been established and are being implemented for the control and distribution of design documents that provide for:
a.
Identification of personnel, positions, or organizations responsible for preparing, reviewing, approving, and issuing design documents.
b.
Identification of the proper documents to be used in performing the design.
c.
Coordination and control of design (internal and external) inter-face documents.
d.
Ascertaining that proper documents, and revisions thereto, are accessible and are being used.
e.
Establishing distribution lists which are updated and maintained current.
2.
Methods of Accomolishment The preceding objectives were accomclished by:
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13 a.
Review of the following documents to determine if procedures have been established to control design document generation, review, approval, distribution, and use in the areas identified in objectives a. through e. above:
(1) Sections 17.3,17.5, and 17.6 of the NRC accepted (Brown and Root) Tooical Recort 3&R-002A (Quality Assurance Program for Nuclear Power Plants) Revision 3, including cnanges made thru March 24, 1980, to determine the Brown and Root Corporate programmatic commitments relative to the control of design documents.
(2) Sections 3, 5, and 6 of the S&R STP (South Texas Project)
Quality Assurance Manual to determine if tne corporate commitments relative to control of design documents were correctly translated into quality assurance requirements and procedures.
(3) Thirteen (13) applicable procedures contained in the ST?
Engineering Procedures Manual to determine that the STP cuality assurance program requirements and procedures were correctly translated into a viable engineering program for control of design documents.
h.
The folicwing documents were reviewed to detarmine if the cuality assurance program for control of design cocuments was being effectively imolemented on current design activities affecting quality by the B&R engineering organizations:
Six (6) Calculations, Three (3) Design Manuals, Three (3) Design Verifications, Twenty (20) Internal & Foreign Drawings, Two (2) Procurement Files, One (1) Recort, Three (3) Specifications, Two (2) System Design Descriptions, and Nine (9) Technical Reference Documents.
3.
Findings a.
Deviations from Commitment Two (2) deviations from commitmant were identifiec in tnis area of the inspection.
See Notice of Ocviation, Items 3 & C.
(1) With respect to Deviation 3:
a.
The STP Design Manual (CM) is control'ed assemblage of acproxi,ately 200 5ystem Design Descriptions (300)
14 and design criteria documents such as Technical reference Documents (TRD).
The Manual describes the salient features of the STP design; defines the require-ments for its structures, systems and components; pro-vides design criteria, specifications, procedures, analyses and guidance; and identifies directly, or through references, the design inputs that provide the point or origin for the system discriptions con-tained therein.
(b) Two (2) issued TRDs examined by the inspector and five (5) additional TRDs subsequently found by the STP Design Quality engineer in each of the three cms examined did not exhibit evidence of the required review and approval signatories.
These TRDs were issued through the official Brown and Root Engineering Document Control Center.
Although six (6) of the seven (7) TRDs contained a statement in their abstract that they were issued for review and comment, no such discitimer appeared in the " body" of the document that would be used or referenced by the designer.
One such documents was 3L369RC014 - A, dated July 5, 1978, and entitled
" Typical Pipe Supports for 6" Nominal Diameter Pipe and Under." This TRD was contained in the Design Manual located at the pipe hanger and support activity.
While there is no evidence that this unapproved pro-cedure was used to actually provide guidance and/or input to the design of safety related pipe supports, its very presense in the facility where the design activity was ongoing offers the potantial for its inadvertant misuse.
(2) With respect to Deviation C:
(a) Section 6.0 of the STP Quality Assurance Manual states that a comprehensive document status list shall be published at least every two months by the ECCC (Engineering Document Control Center) to ensure that the responsible engineering personnel are working to the latest revision or issue of an Engineering cocument.
(b) Contrar/ to this procedure, the responsibility for issuing an engineering document status list has been assigned to a different activity, the Comouter Support Grouo, that does not provide the same controls for the amurt / of their data base as does the EDCC.
15 0.
Exit Meeting An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on January 8,1981.
In addition to those individuals indicated by an asterisk in the Details Sections of this report, the meeting was attended by:
W. M. Rice, Group Vice President, Power Group K. A. Swartz, Senior Engineering Manager P. S. Jordan, Nuclear Licensing Staff Manager K. R. Cock, Deputy Project General Manager J. R. Orlando, QA Coordinator, Vendor Surveillance R. P. Negri, Assistant Quality Assurance Manager C. E. Singman, Assistant Manager, Vendor Surveillance The inspector discussed the scope of the inspection and the details of the findings identified during the inspection and the form and content of letters of response to NRC inspection reports.
Management comments were generally for information only or for acknowlecgement of the stata-ments of the inspector with respect to the deviations presented.
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-DETAILS SECTICN II (Prepared by D. G. Bresca)
A.
Persons Contacted "P. J. Bulten - VCP QA Task Force Leader R. G. Burnette - B&R/HL&P Lead Coordinator "J. R. Childers - QA Coordinator H. T. Faulkner - Project Coordinator E. J. Manning - Supervisor QA Manual Review R. C. McMahill - Senior Engineer T. J. Ries - Regional Coordinator Vendor Surveillance
" Denotes those present at the exit meeting.
B.
Procurement Source Selection 1.
Obfectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, parts and comoonents that provide for:
a.
Recuirements for evaluation of the potential supplier's capa-bility to provide items or services in accordance with the technical and quality assurance specifications of the prccurs-ment documents.
b.
Methods of evaluating potential suppliers that are consistent with applicable regulatory, code and contract requirements and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA program, manual and procedures.
c.
Consideration of the comolexity, inspectability.ana safety significance of purchased items or services when selecting the metnod of source evaluation.
d.
Performance of source evaluation audits that incluce acoropriate checklists or instructions for systematic review of the crospective supplier's QA system.
17 e.
Qualification requirements for personnel performing source evaluation audits, f.
Source selection being based on historical product performance that includes review of past procurement and operating experience with identical or similar items and is limited to relatively simple services or off-the-shelf items.
g.
Periodic re-evaluation of suppliers and that an up-to-dtte listing of the evaluation status is being maintained.
h.
Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to ccmpanies desig-nated in these documents.
i.
Measures to assure that the supplier's Did conforms to the pro-curement document requirements and that resolution of unaccept-able conditions identified during bid evaluation are corrected before the contract award.
2.
Metnod of Accomolishment The preceding objectives were accomplished by reviewing the following coc?.ments relative to the Brown and Roots Quality Assurance Pro 3 ram.
a.
The appropriate sections (policies and procedures) of the recently revised, (as of October 31, 1980) " Brown and Root, Inc. Quality Assurance Program Description During Design and Construction of the South Texas Project Electric Generating Station" were reviewed to determine tnat commit-ments to quality were reflected in the area of procurement source selection.
b.
The ollowing procedures were reviewed in the South Texas Project Quality Assurance Procedures Manual to assure that quality related commitments were being procedurally implemented.
(1) ST-QAP-4.2, " Houston Purchasing Activities" (2)
ST-QAP-7.1, " Vendor Surveillance Organization" (3) ST-QAP-7.2, " Vendor Surveillance and Houston Coordinatic.i Activities" (4) ST-QAP-15.4, " Trend Analysis"
18 (5) ST-QAP-18.1, " Audi t Program" c.
To assure that the previously reviewed quality commitments were being properly and effectively performed with respect to procure-ment source selection, the following documents were reviewed:
(1) Four (4) South Texas Project procurement files on selected purchase orcers from the Purchasing Department were shown to contain Pre-Award procurement activities such as:
(a) QA Department Quality Assurance Vendor Questionaire (b) Engineering Capability and Experience Questionaire (c) Pre-Award Facility Survey (d) Commercial, Technical, and Quality Assurance evaluations (e) Final recommendation of award for license acproval.
(2) South Texas Project Approved Vendor List, dated Decemoer 23, 1980 was checked for proper distribution and timely updating.
(3) Five QA Manual Review reports conducted by the QA Audit Section were reviewed for content and proper 2snual status follow-up.
(4) Three (3) Vendor Pre-Award Survey's conducted by the QA Audit Section were reviewed for content and proper review.
(5) The Aunit Deficiency Report (AOR) Trend Analysis System was examined to see that Quality Commitments are being met and that the system is in place and functioning.
(6) Occuments being gathered by the Vendor Control Program Task Group, in the area of Quality Assurance evalua-tion of the Vendor's quality program and its implementation, are listed on the QA Support Documentation List and the Vendor Control Program (VCP) Vendor History Matrix.
The Document :ist and History matrix were reviewed for content and proper procedural imolementation.
Quality Assurance Suoport Occumentation comoilation that was committed to in the Vendor Control program was reviewed for content of the following document types:
(a) Vendor QA Manual Reviews and associated documentation.
(b) Preaward Survey Reports and associated documentation.
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'(c) Correspondence justifyir.g waiver of preaward evalu-ation activity.
(d) Quality Assurance bid evaluation correspondence.
(e) Vendor Audits and associated documentation.
(f) Correspondence changing QA Vendor approval status.
(7) Five (5) Audit Deficiency Reports (ADR) were examined for content and proper review and approval.
3.
Findings a.
Deviations In this area of the inspection no deviations from commitment were identified.
b.
Unresolved Items or Follow-uo Items None were identified.
c.
Ccmments It was observed during this inscection that the thrust of Pre-award Survey's and subsequent annual Supplier Quality Assurance Evaluation has been shifted from the responsibility of Vendor Surveillance to the Quality Assurance Audit Section.
Procedures defining and reflecting this change have been issued, or in their final draft stages, at the time of inspection.
A concerted effort by the audit section to control previously undispositioned audit findings in the area of s'ipplier Quality Assurance Programs is in process.
The use of the recently implemented Audit Ceficiency Report (ADR) Trend Analysis System should aid in this area of control.
To expedite the process of closing out audit findings, the audit section is working with vendor surveillance.
Instead of possibly waiting (1) year for the annual Supplier Quality Assurance Program re-evaluation to verify that supplier corrective action to audit findings had been implemented, vendor surveil-lance can assist in this area by verification of supolier action curing their more frequent in process source inscections.
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20 C.
Sucolier Nonconformance and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for:
a.
Disposition of nonconformances that provide for:
(1) Measures by the purchaser and supplier #or identification, control, review, and disposition of itams or services that do not meet procurement document requirements.
(2) Submittal of nonconformance notice to purchaser by supplier which shall include recommended disposition and technical
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justification.
(3) Submittal to the purchaser for approval of dispositions containing one or more of the following nonconformances:
(a) Technical or material requirement violated.
(b) Violated requirement in supplier document accroved by purchaser.
(c) Nanconformance cannot be corrected by continuation of tne original process or by rework.
i (d) Original requirement is not met but the item can be restored so that its function is unimpaired.
(4) Purchaser disposition of supplier recommendations, verifi-cation of disposition, and maintenance of records of noncon-formance.
b.
Corrective action that provides for:
(1)
Identification of and timely corrective action for conditions adverse to quality which occur during the procurement process that are the responsibility of the purchaser.
(2) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(3) Recorting these conditions and the corrective action to management.
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21 (4) Assuring that corrective action is implemented and maintained.
(5) Verification of supplier's corrective action system.
2.
Method of Accomolishment The preceding objectives were accomplished by review of the following documents relative to Brown ar' Root Quality Assurance Program.
a.
The appropriate sections of the recently revised (as of October 31, 1980) Brown and Root, Inc. " Quality Assurance Program Description During Design and Construction of the South Texas Project Elec tric Generating Station" were reviewed to determine that commitments to quality were reflected in the area of Supplier Nonconformance and Corrective Action.
b.
The following procedures were reviewed in the South Texas Project Quality Assurance Procedures Manual to assure that quality related commitments were being procedurally implemented.
(1) ST-QAP-7.1, " Vendor Surveillance Organization" (2) ST-QAP-7.2, " Vendor Surveillance and Houston Coordination Activities" 1
(3) ST-QAP-15.1 " Nonconforming Items" (4) ST-QAP-16.1 " Corrective Action" (5) Vendor Surveillance Policy Notes VSPN-012 "Nonconformances."
c.
Review of the following documents to assure that the quality commitments are being properly and effectively performed with respect to Supplier Nonconformance and Corrective Action.
(1) Five (5) Vendor Surveillance Plans (2) Five (5) Vendor Surveillance Reports (3) Two Vendor Control Program packages that contained Surveillance / Inspection History such as:
(a) Vendor Surveillance Reports and Surveillance / Inspection Reports.
22 (b) Certificates of Conformance (c) Nonconformance Reports (4) Five (5) Vendor Surveillance Work Folders (5) Six (6) Nonconformance Report (NCR) and their accompanying correspondence.
(6) Five (5) Nonconformance Report (NCR) closure notifications to supplier.
(7) Nonconformance Report (NCR) Status Report dated Decemcer 31, 1
1980.
3.
Findings a.
Deviations In this area of the inspection no deviations from commitment I
were identified.
f b.
Unresolved I'cems or Folicw-co Items None were identified.
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