ML20038C063

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Testimony of a Vega Re Provisions for Conduct of QA Audits on Reactor Operations & Reactor Operator Training.Described Audit Program Assures Effective Audit Program Assuring Safe & Reliable Plant Operation.Prof Qualifications Encl
ML20038C063
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 11/20/1981
From: Vega A
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
Shared Package
ML20038C053 List:
References
NUDOCS 8112090537
Download: ML20038C063 (18)
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  • . ' Ek 4 DOCHETED USNRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

'81 NOV 23 Pl2:i2 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '~

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,In the Matter cf ) *-

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TEXAS UTILITIES GENERATING ) Docket Nos. 50-445 "

COMPANY, g al. 50-446 (Comanche Peak Steam Electric )

Station, Units 1 and 2 )

TESTIMONY OF ANTONIO VEGA

REGARDING THE PROVISIONS FOR CONDUCT OF QA AUDITS ON REACTOR OPERATIONS AND REACTOR OPERATOR TRAINING Q. Please state your name, residence, educational and professional qualifications.

A. My name is Antonio Vega. I reside in Garland, Texas. A statement of rqy educational and professional qualifications is included as Attachment A.

Q. What is your current assignment?

A. I am the Quality Assurance Services Supervisor in the TUGC0 l

l Quality Assurance Division in Dallas. I report to the Manager Quality Assurance and am responsible for QA audits.

Q. What is the subject of yo w testimony?

A. My testimony concerns the provisions for conduct of QA audits on reactor operations and reactor operator training.

Q. How will these audits be conducted?

8112090537 01112'O PDR ADOCK 05000445 G PDR

A. Audits of reactor operations and reactor operator training will be conducted in accordance with approved audit procedures by

. qualified audit personnel.

'Q . Please describe the pro::edures by which these audits will be conducted.

A. The primary audit procedure is TUGC0 procedure CQI-CS-4.6 entitled, " Conduct of Internal, Prime, and Sub-Contractor Audits". A copy of that procedure is attached hereto as Attachment B.

This procedure defines the requirements applicable to the following:

1. Preparation for the audit, including requirements for preparing the audit checklist and making personnel assignments for activities to be examined;
2. Conduct of the audit;
3. Reporting of audit findings to appropriate levels of management;
4. Evaluation of proposed corrective actions;
5. Follow-up activities, including re-auditing if necessary; and
6. Close out.

j The audit procedures are in compliance with industry standard ANSI 45.2.12 entitled, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants".

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3-Q. How do you prepare the audit checklists which you discuss in item 1, above?

A. The checklists will extract the detailed technical specification

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. requirements, and detailed operating and training procedure requirements to be examined during the audit. Activities examined during the audit will include ongoing and historical activities.

Q. What qualifications are required for the audit personnel?

A. The personnel performing these audits will be certified in accordance with a certification program which evaluates their education, experience, training and demonstrated capability.

This certification program is consistent with NRC Regulatory Guide 1.146 and ANSI N45.2.23 entitled, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants".

Q. Do you feel that the audit program described above is effective and will accomplish its objective?

A. Yes. The above described audit program, comprised of detailed procedures and highly proficient audit personnel, assures an effective audit program which in turn assures a safe and reliable plant operation.

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. () ) Attachment A ANTONIO VE'iA, P.E.

STATEENT OF EDUCATIONAL AND PROFESSIONAL EXPERIENCE POSITION: Quali ty Assurance Services Supervisor FORMAL EDUCATION: 1961-1967, B.S. Electrical Engineering, University of Texas EXPERIENCE:

1977 - Present Texas Utilities Generating Company (TUGCO), Dallas, Texas, Quality Assurance Services Supervisor, Quality Assurance Division. Activities include program and procedure development, and independent compliance evaluation via surveillance and audit of safety related activities performed by TUGCO, Texas Utilities Services Incorporated (TUSI), the Architect Eng.neer, the Constructor and safety related equipment seppliers.

1973-1977 Texas Utilities Services Incorporated, Dallas, Texas, Quality Assurance Senior Engineer, Quality Assurance Division.

Activities included involvement in developing the QA program, procedures, instructions, and conducting audits and inspections on TUSI, the 'rchitect Engineer, the Constructor, and safety related equipneitt suppliers.

1970-1973 Dallas Power & Light Company, Dallas, Texas, Power Plant Design Engineer, Power Plant Division, Engineering Department. Activities included conceptual and detail design of power plant power and distribution systems, protection systems, control systems and communication systems.

Performed related construction inspections.

1967-1970 Dallas Power & Light Company, Dallas, Texas, System Protection and Controls Engineer, System Protection Section, Substation and Transmission Division, Engineering Department.

Activities include conceptual and detail design of substation, transmission, and switchyard facilities, including power systems, protection systems, telemetering and

. control systems and communication systems. Performed related construction inspections.

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Attachment B PROCEDURE /

TEXAS UTILITIES GENERATING CO. INSTRUCTION ISSUE REVISION PAGE NUMBEp DATE c CQI-CS-4.6- 1 of 13 1 11/3/81 CONDUCT OF INTERNAL, PRIME, AND PREPARED BY:

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SUBCONTRACTOR AUDITS DA *-

APPROVED BY: 4[w Je/~ //~N/

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DATE

1.0 INTRODUCTION

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1.1 Purpose To establish the metho s ich TUGC0 Quality Assurance Services Audit Personnel will conduct audits of TUSI, TUGC0j subcor. tractors, the A-E and the NSSS Supplier.

1.2 Scope This instruction addresses scheduling, preparation, reporting and follow-up activities necessary to conduct the required audits of TUSI,

y. TUGCO, Subcontractors, the Architect-Eng4neer and the NSSS Supplier.

1.3 Definitions - None 1.4 References 1.4.1 CQP-CS-4 " Procedure to Establish and Apply a System of Pre-Award Surveys, Audits and Surveillances."

2.0 RESP 0"SIBILITIES 2.1 TUGCO, Vice President, Nuclear - Takes management actions as necessary to assure that corrective actions to deficiencies are accomplished in a timely manner.

2.2 Manager, Quality Assurance - Provides assistance as required to assure

.- that corrective actions are promptly addressed and implemented. Reviews signs and transmits reports and evaluations. This authority may be l

delegated in writing.

2.3 Quality Assurance Services Supervisor - Initiates follow-up actions to assure that corrective actions are addressed and implemented in a timely manner. Reviews and initials audit reports and evaluations.

I 2.4 Coordinator, Vendor Evaluation Audits - Schedules audits and issues notifications. Assigns team leaders and members.

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CQI-CS-4.6, R;v. 1 Page 2 of 13 Attachment B

2. 5 Audit Team Leader - Responsible for orientation of team members and for tne preparation, conduct, reporting and follow-up activities required for

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an au di t. .

3.0 INSTRUCTION 3.1 Scheduling 3.1.1 Audits will be scheduled as required in Reference 1.4.1.

3.1.2 The Coordinator, Vendor Evaluation Audits will notify responsible management at least two weeks prior to the audit date. A formal notification memo should be issued; however, a telephone conversation record is acceptable. (Example 1)

a. The notification should include:
1. audit date
2. audit team members / team leader
3. scope
4. time for the pre-audit meeting 3.1.3 The Coordinator Vendor Evaluation Audits will assign the audit team leader and team members and notify them accordingly.

3.2 Preparation

,.' 3.2.1 The Audit Team Leader will prepare.for the audit hy compildng and

.,_ reviewing the following documents as appropriate:

a. previous audit reports
b. applicable procedures 3.2.2 A checklist shall be prepared using previous audit results and procedures as appropriate.
a. A sample size should be selected where applicable.
  • b. The checklist shall be approved prior to use by the Quality Assurance Services Supervisor or Quality Assurance Manager.

3.2.3 The Audit Team Leader will prepare an audit plan (Example 2) and will discuss the plan with audit team members prior to the audit.

a. The audit plan shall address the following:

. . 1. audit scope

2. requirements
3. activities / organizations to be audited
4. audit schedule
5. checklist and/or procedures
6. applicable documents

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CQI-CS-4.6, Res. 1 Page 3 of 13

, ,, Attachment B 3.3 Performance 3.3.1 The Audit Team Leader shall conduct a pre-audit conference at the audit site with cognizant organization management.

a. The following should be addressed during the pre-audit

. conference:

1. obtain signatures of attendees
2. . introductions
3. present the audit scope an'd plan
4. discuss the audit sequence
5. establish channels of communication 3.3.2 The au'ditors shall use checklists and/or procedures to conduct the au dit.
a. Checklists are intended to be used as a guideline. Should the audit results warrant, auditors may deviate from the checklist requirements to assure adequate control of the activity,
b. Additional notes may be used as necessary to supplement the checklist.

. 3.3.3 When an auditor identifies a deficiency, the auditor shall conduct

,. further investigation in an effort- to identify the cause and eff.ect of the deficiency.

3.3.3.1 The auditor shall exercise judgment to determine if the deficiency involves a nonconformance which requires immediate corrective action. These shall' be reported to responsible management immediately.

3.3.4 For items where no direct violation of a requirement exists, but the auditor has noted a potential problem or item requiring some clarification; the following categories may be used.

a. Concerns - Items which could potentially develop into a deficiency mAy be listed as concerns.
1. The auditor will determine if action is recommended and a response required or if bringing it to nenagement's

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attention is all that is necessary.

b. Canments - This category mAy be used if the auditor feels the need to document questions which may have surfaced during tne audit, emphasize or record cannitments made, provide clarification of an audit item, etc.
1. No response is required.

(, 3.3.5 The Audit Team Leader shall report the results of the audit during a post-audit conference with responsible management personnel.

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CQI-CS-4.6, R;v.1 Pag 2 4 of 13 Attachment B

a. The following should be addressed during the post-audit meeting. *
1. deficiencies, concerns, and comments identified and recommendations as applicable
2. clarify misunderstandings
3. establish a tentative course and schedule of corrective actions
4. any holds which may be put in place as a result of deficiencies identified
  • Sc obtain signatures of post-audit attendees 3.4 Report 3.4.1 Upon completion of the audit, the Audit Team Lender shall assemble the audit package. It should contain the following:

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a. list of attendees of the pre- and post-audit meetings
b. completed checklists
c. auditor's notes, including deficiencies, concerns, and comments identified 3 4.2 The Audit Team Leader is responsible for defining any necessaty format for the report. Each individual team member is responsible for their input in the proper format.

- 3.4.3 The Audit Team Leader shall prepare, sign and issue the audit s_ report, preferably within 15 days but not later than 30 days from the post audit meeting.

. a. The audit report shall contain the following:

1. identification of audit team members, personnel contacted, and attendees of the pre- and post-audit meetings
2. audit scope
3. date of audit
4. audit summary, including an evaluation of the effectiveness of the QA program elements audited
5. status and evaluation of corrective action commitments to previous audit findings, if applicable
6. deficiencies, concerns, recomnendations, and comments as applicable

. 7. schedule for corrective action implementation, if possible

8. Request response within 33 days 3.4.4 The Quality Assurance Services Supervisor shall review and initial the report. The Manager, QA shall review and approve the report.

3.4.5 The report shall be cistributed to cognizant management of all involved organizations. Additional internal distribution may be s- indicated.

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CQl-CS-4.6, Rev. 1 Page 5 of 13 Attachment B 3.L Foll ow-Up 3.5.1 The Audit Team Leader shall evaluate the response and prepare an

, evaluation letter.

a. If the response has not been received within the allotted time frame, the following steps will be initiated.
1. The QAS Office Assistant or ' Audit Team Leader will contact the responsible person by phone and determine the reason for the delay. A new response date will be agreed upon within a reasonable amount of time.
2. If the response has still not been received at the end of the agreed upon time, items a - d (below) will be initiated for site responses. For prime contractors / subcontractors, the QAS Supervisor and Manager, QA will be involved and actions taken as appropriate to resolve the problem.
a. a memo will be issued by the Manager, Quality Assurance.'(See Example 3)

,. b. the memo will be telecopied to the responsible person

c. three (3) additional days response time will be allowed
d. copies of the memo will be distributed to the following management, as applicable:
1) TUGC0 Vice President, Nuclear
2) TUGC0 Executive Vice President and General Manager
3) TUGC0 Manager, Nuclear Operations
4) TUSI Executive Vice President
5) TUSI Vice President and Project General Manager - CPSES
3. At the end of the three days, if the response has still

. . not been received, the TUGC0 Vice President, Nuclear will be involved and appropriate actions will be taken.

4. All telephone conversations regarding the overdue response will be documented and placeo in the audit file.

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CQI-CS-40 6, Rev. 1 Page 6 of 13

. , Attachment E 3.5.2 The evaluation should address responsiveness and adequacy of corrective actions.

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a. If the response'is satisfactory, an evaluation letter (Example 4) shall be prepared.
b. If the response is unsatisfactory, the evaluation letter

, should include the reason the response is unacceptable and assign a new response due date (Example 5).

3.5.3 The evaluation letter _ shall be reviewed and initialed by the OAS Supervisor and reviewed and approved by the Manager, Quality Assurance.

- 3. 5. 4 Distribution shall be in accordance with paragraph 3.4.5 above l 3.6. Verification of Corrective Action 3.6.1 Verification of implementation of corrective actions shall be accomplished by appropriate means.

3.7 Audit Records 3.7.1 The following records shall be maintained in the applicable audit file by the OAS Office Assistant or QA Secretary:

a. notification letter

, b. completed checklists and/or procedures -

c. auditor's notes
d. audit report
e. request for response memo, if applicable

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f. response
g. evaluation and closeout

. Example 1 -

Audit Notification Letter Example 2 -

Audit Plan Exemple 3 -

Request for Response Example 4 -

Evaluation Letter - Acceptable Response Example 5 -

Evaluation Letter - Unacceptable Response

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CQI-CS-4.6,'Rev. 1 EXAMPLE 1 Page 7 of 13 QTN..396 Attachment 8

. TEXAS UTILITIES GENERATING COMRihT OTTICE MEMOR ANDUM J. C. Kuvkendall Dallas, Texas June 1. 1981 hTo

- Subjes Comanche Peak Steam Electric Station TUGCo QA Audit Notification TUG-5 Startup Activities June 22 - July 2, 1981 QA Audit File: TUG-5 This will document the telephone conversation between George Smith and Debra Anderson on May 27, 1981 with regard to an audit of Startup Activi ties . The audit has been scheduled for June 22 - July 2,1981.

The audit scope wil.1 include, but not be limited to, the following:

1) Compliance with FSAR Chapter 14
2) Review of Reactor Operating /Startup Experiences
3) Personnel Training / Qualifications
4) Release from Construction to TUGCo
5) Custody Transfer Tagging
6) Safety Tagging
7) Work performed on equipment in Startup Custody B) Maintenance
9) Design Changes The audit teams will be organized as follows:

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$ Items 1 - 3: Debara Paris V Tony Valdez Bobby Shoemake - Acting Team Leader Items 4 - 9: Debra Anderson .

l Bailey Campbell

! Richard Curtis - Acting Team Leader We plan for the pre-audit meeting to begin on Monday, June 22 at 9:30 a.m.

Please arrange for a conference room fo- this meeting.

Should you have any questions, please contact Debra Anderson at - -

214/653-4882. .

.' C a Manager, Quality Assurance W -

DNC/AV/DLA:kh cc: B. R. Clements R. E. Camp R. A. Jones

% D. E. Deviney l C.E J. T. Merritt .

R. G. Tolson

CQI-CS-4.6. Rev. 1 Page 8 of 13 EXAMPLE 2 I

t 'TUGC0 OA AUDIT PLAN VEND 0R/0RGANIZATION: TUGC0 STARTUP ADDIT NO.: TUG-5 .

AUDIT DATE: June 22 - July 2. 1981 -

- Y-AUDIT SCOPE: The following Startup Activities:

Team 1 - Compliance with FSAR Chaoter 14 Team 2 - Release from Construc-

- Review of Reactor Operating / tion to TUGC0 Startup Experience Custody & Safety Tagging

- Personnel Training /0ualification - Work perfomed on Eauip-ment in Startup Custody

- Maintenance Design Changes

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s AUDIT REQUIREMENTS: Comoliance with FSAR Chapter 14 & Startup Administrative Pr.ocedures APPLICABLE DOCUMENTS: FSAR Chapter 14, Startup Administrative Procedures, Operations OA Plan AUDIT SCHEDULE: Monday, June 22, 1981, 9:30 am - Pre-audit meeting

! June 22 - July 1, 1981 - Audit t

l Thursday, Julv 2, 1981, 10:30 am - Post-audit meeting CHECKLIST AND/0R PROCEDURES: ATTACHED

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, DISTRIBUTION: AUDIT TEAM MEMBERS: Team 1 - B.Shoemake(Acting Team Leader)

AUDIT FILE: TUG-S D. Paris T. Valdez Team 2 - B. Campbell (Acting Team Leader)

D. Anderson e-HNM6** -MW hwmM6 *** *N N ee eis ,,w e me w h . -e a e.. 4 , , , , ,

CQI-CS-4.'6, RW. 1 -

EXAMPLE 3 P-Page 9 of 13

.', TEXAS UTILITIES GENERATING COMPANY Attachment B

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OFFICE MEMOR ANDUM To Dallas, Texas

(' Subim Comanche Peak Steam Electric Statiore Request for Immediate Response TUGC0 QA Audit /Surveillaner. No.

0A Audit / Surveillance File.

TUGC0 QA Audit / Surveillance No. was transmitted to you via (log number) dated . In accordance witn ANSI N45.2.12, your response was due by (oue date) . As of the date of this memo, no response has been receivec. .

Your response must te received by TUGC0 OA Dallas no later than (3 days from date of memo) . Failure to respond by this date will result in this matter being turned over to the TUGC0 Vice President - Nuclear for

._ resol ution'.' ,

D. N. Chapman -

Manager, Quality Assurance DNC/AV/  :

cc: Thu Vice President, Nuclear n As Applicable: .. .

(J 1 TUGC0 Executive Vice President & General Manager TUGC0 Manager, Nuclear Operations . .

TUSI Executive Vice President TUSI Vice President and Project General Manager - CPSES l

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^*' #* Pa e 30 of 13 TE}@ UTILITIES GENERATING CO'}&NY Attachment B OFFICE MEMOR ANDUM To J. T. Merritt Daums Texas December 8. 1980_ .

(g Subim Ccmanche Peak Steam Electric Station ~

Evaluation of Audit Response TCP-15 OA Audit File: TCP-15 Your response to the deficiency identified during our a;dit TCo-15 has been evaluated by TUGC0 QA. Based on your corrective action, please -

consider all items to be closed. No further response is required at this time.

Thank you for your cooperation. .

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D.N.thapma Manager, Quality Assurance DNC/AV/ JAY:1jf cc: B. R. Clements R. G. Tolson R. F. Curtis

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,.CQI-CS-4.6, R.v. 1 EXAMPLE'5 6 age 11 og 13, .

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TEXAS UTILITIES GENERATING COMPAhT Attachment B OTTICE MEMORANDUM .

J. T.' Merritt Dallu. Texe

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[2 ' gog, COMANCHE PEAK STEAM ELECTRIC STATION s Evaluation of Audit Response TCP - 12 Follow-Up QA Audit File - TCP-12 Follow-Up Your response to our audit TCP-12 Follow-Up has been evaluated by the TUGC0 QA staff.

Attachment A to this report contains an evaluation of each finding. An f

additional response to Deficiency Nos.1, 2 and 3 is required by July 14, 1981. In your response please provide the information requested in the evaluations.

- Should you have any further questions, please contact J. Antonio Valdez at 214-653-4894.

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1. N. Chap an

' Manager, Quality Assurance

  • J DNC/ AV:md

.m. cc: B. R. Clements - -

- R. G. Tolson W. G. Parry 1 -

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CQI-CS-4.6. Riv. l ' EXAMPLE 5 (Cont'd) Page 12 of 13

. Attachment B e

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EVALUATION OF . .

TCP-12 FOLLOW-UP

RESPONSE

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@ Deficiency No.1: *

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Finding No.1.

. As you stated, the cause of this finding was that the fabrication drawing had solid lines rather than phantom lines for one of its structural members. An additional response describing what was done to determine and to prevent recurrence of the underlying cause of this finding is required.

Also, please include the attendance record of personnel that attended the training session.

Finding No. 2.

TUGCo QA acknowledges that CE-11039, Revision 2 was issued to reflect the as-built condition. However, the cause of this finding was that a traveler was not issued for CK 11039, Revision O. An additional response describing what was done to determine and to prevent recurrence of the underlying cause of this finding is required.

Also, please include the attendance record of personnel that attended

, the training session. .. -

Deficiency ic. 2:. -

TUGCo QA acknowledges the issuance of IRN No. 118567 and the commitment to replace the affected cable connection cards. -

An additional response is required. The response is to consist of the attendance record of personnel that attended the training session.

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Deficiency No. 3:

TUGCo QA acknowledges the correction of the affected Megger Cards.

An additional response is. required. The response is to consist of the attendance record of personnel that attended the training session.

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