ML20127B048
| ML20127B048 | |
| Person / Time | |
|---|---|
| Site: | 07100122 |
| Issue date: | 01/07/1993 |
| From: | James Shepherd J.L. SHEPHERD & ASSOCIATES |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301120151 | |
| Download: ML20127B048 (30) | |
Text
-
^
SHE34ERC b ASSOCIATES
~
1010 ARROYO AVE, $AN FERNANDO. CALIFORNIA 91MO-1822 818-898-2361 FAX 818-361-8095 january 7,1993 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555
Reference:
A Reply to a Notice of Nonconformance, Docket No. 71-0122 Additional submittals as referenced in our letter of December 3,1992.
Per the above referenced Notice of Nonconformance, the two notice of nonconformances -
are addressed below.
B. 10CFR71.137 " Audits."
J.L. She 3 herd and Associates admits incompletion of alleged nonconformance.
Reply: As we went on line with a new computer system, we were trying _ to -
work out " bugs" and incorporate each applicable area into the QA Program Plan, with specific audits. We started this process, with documentation (see the enclosed Audit) but did not comp ete the process formally in -
accordance with our Program Plan.
Corrective Steps: we have had a Preaudit Conference (results enclosed),
and are in the process of completing our internal audit. We will be pleased to forward reports as the Audit is completed. (RESULTS ENCLOSED.)
l
/}h/p,
/*
J:LTShepherd, President JLS/mfs CC: Branch Chief, Transportation Branch, Office of Nuclear Material Safety & Safeguards (NMSS) 110081 i
1 f
QAM/QP # S, Audits, QA-RM001 A, Rev. 3,10/10/90
,1 DECEMBER 30,1992 JLS&A YEARLY INTERNAL AUDIT POSTAUDIT CONFERENCE Postaudit Time: 2:30 PM.
Attendees:
JL Shepherd, MF Shepherd, DC Shepherd, JS Shepherd, Q Pho, D. Tran, V Towne, M Pauls, L Weiss, K Ihoune, RN Donelson, P Shepherd, J fuzzell, B Peabody, N Pho Working Groups & Postaudit Review Synopsis:
- 1. Organization Cha-t:
MF Shepherd, reviewer K Thoune, head of audit review group Audit showed that the following are current:
organizational chart job descriptions training documentation resumes Audit showed that all QC/QC personnel have reportability to upper management.
The computer program does not directly effect QA/QC personnel or job descriptions, payroll reflects all personnel.
- 2. QA Program Plan:
Mf Shepherd, reviewer Q Pho & M Pauls, heads of audit review group Audit of QA Program Plan for discrepancies, nonconformances, changes needed.
No discrepancies found in our commitment - all 18 points.
The Program Plan appears in Wordstar word processing, not the RealWorld program, and does not impact the QA/QC program. Program Plan, with curmnt revisions -
is stored in the Network, on floppy disks and appears on Network back-up tapes.
The Program Plan is currently approvec until 1995,
- 3. Design Control:
JL Shepherd, reviewer V Towne, head of audit review group Procedures for design documentation & changes seem to be adequate & pertinent de-partments are made aware of changes.
No pertinent changes have been made which involve licensing authorities this year, past changes & notifications to the State of California re. devices seem adequate.
A random audit of vellum file; and 20 closed &/or open jobs showed that vellums are cor rectly filed & current drawings are part of job files.
The Autocad system operates the same as manual drawings - all are reviewed & signed off, as are all revisions & changes.
- 4. Procurement Document Cnntrol:
Q Pho, reviewer L Weiss, head of audit review group A random audit of 30 PO's showed that references & specifications appeared when necessary, Subpart H criteria & right of access clause stamp.s appeared on PO's, drawings, specs, etc, were referenced & sent with PO as required, Bills of Materials contained proper references & request for certs, etc.
- DECEMBER 30,1992 JLS&A YEARLY INTERNAL AUDIT - POSTAUDIT CONFERENCE Page 2.
changes were reviewed by appropriate departments incoming purchases are checked for certs & verification of specs from PO, nonconforming parts are sent back to vendors reason for vendor mess up is reviewed the computer system does not change the QA/QC requirements for PO's -
those are hand stamps carried over from manually typed PO's & past computer -
generated PO's.
- 5. Manufacturing Control:
JL Shepherd, reviewer JS Shepherd & N Pho, heads of audit review group Areas of audit covered:
Random spot checks of different manufacturing procedures (welding, machining, assem bly) showed that procedures are followed.
Review of manufacturing procedures, instructions & drawings showed that they are prepared, approved, reviewed & controlled. Some did not have the new QAM/QP info - a revie v of our commitments showed that we are only revising documents
& instructions, etc., as the need arises - these were previously approved under -
past program approvals & we did not' commit to unilateral revision of documents.
Audit of important to safety items procedures, instructions, drawings. etc., include tolerances & workmanship.
Audit of QA/QC inspection reports showed that tolerances, etc. have been documented
& met. Acceptance criteria called out also.
A review of Job Entry (previously audited in 1991 for QA/QC applicability) was checked.
The computer program itself does not impact QA/QC documentation - signoffs &
lists are added by acetate copy to the computer information sheet, subject to new QAM/QP review & ap 3rovals.
Audit showed that 10CfR71 proce(ures are part of manufacturing procedures & followed during manufacturing.
Audit showed that shipping container packages had proper unloading / loading & DOT procedures and that they are followed.
The computer program does not effect this section at all
- 6. Document Control:
MF Shepherd, reviewer D Tran & L Weiss, heads of audit review group Review showed that QA/QC documents & revisions are subject review & approval by the appropriate dept's. Note - previously approved QA documents which have not been revised with new QAM/QP matrix info, will be revised as changes occur.
- we only have one plant. f or field work, All JLS&A QA/QC documents are on site already /or procedures are sent as pa copies of pertinent QA/QC documents &
package.
All current QAM/QP documents are in the word processing program, floppies & on hard disk backup tapes.
- 7. Control of Purchased Materials, Parts & Components:
Q Pho, reviewer D Shepherd, head of audit review group Vendor selection process reviewed -is controlled by the ap 3ropriate dept.
Designated vendor QA programs have been audited or we lave audit approvals by other companies / gov't. agencies on file. In 1993, we need to review whether these approvals have expired & obtain current copies. No new vendors requiring audits
DECEMBER 30,1992 - Jl.S&A YEARLY INTERNAL AUDIT - POSTAUDIT CONEERENCE Page 3.
in 1992.
No visits to vendors for QA compliance were required in 1992.
Receivers for PO's are kept on file with certs, etc.
Material Rejection forms are kept on file for purchased parts.
Repair or replacement documentation on purchased parts is kept as part of the Receiver (Hes. Note: p'r FDA, we now track timers by SN in a log.
Items that are improperly ider, ified or that don't correspond to PO description are held aside by the appropriate dept. until dispositioned.
Certs of conformance are acceptance tags at JLS&A & are attached to items.
Nonconforming items are held in a separate location from approved inventory.
PO's, receivers & certs are kept in specifi files.
The computer program doesn't effect QA/QC in this section.
- 8. ID & Control of Materials, Parts & Components D Tran, reviewer V Towne, head of audit review group We have established procedures for part 1.D.
A random spot check of approx. 40 received &/or fabricated showed I.D. &/or marking to QA.
Nonconforming parts are kept separate form inventory.
Noninspected parts are kept separate from inventory.
The receiving & inspections areas do not hurt or interfere with items, inventory items are checked for proper job before release - they are marked with job #
when taken from inventory & put into work in process.
Inventory items are not put into computer untilinspected & accepted - so QA/QC functions are not really effected.
- 9. Special Processes:
RN Donelson, reviewer JS Shepherd, head of audit review group Special processes are controlled & current personnel & procedures are on file.
- 10. Inspection Control:
J Fuzzell, reviewer radiological Q Pho, reviewer nonradiological B Peabody, head of radiological audit review group N Pho, head of nonradiological audit review QA/QC inspections are documented, usually by checklists.
Woik was found to be held for inspections.
On important to safety items, inspections, wipe tests, rad. surveys, log entries & docu.
ment evaluations are performed & documented. note: audited quarterly by outside HP, per St. of CA license.
If direct control of processing methods isn't possible, forms, lists, etc., for radiological must be approved by senior personnel, final inspections - check integrity thru review of specs, PO's, records & inspections.
Competed items are stored in such a manner as to protect them from physical or envir. -
onmental damage.
A review of inspectors training file shows that inspectors are qualified per jlS&A's criteria.
The computer programs do not effect this section - documents on word processing - with backups as listecl above.
l
DECEM13ER 30,1992' JLS&A YEARLY INTERNAL AUDIT - POSTAUDIT CONFERENCE Page 4.
- 11. Test Control:
RN Donelson, reviewer Q Pho, head of audit review group Prototype testing is performed according to regulatory and/or ANSI criteria & documented, files reviewed.
A random check of 10 files showed that repairs & replacements met original specs.
Testing procedures per regulatory or ANSI guidelines includes specs as called out in QA Program Plan.
A review of all shipping container files shows that applicable NRC, DOT & IAEA criteria, including certificates, are current.
Under our State of CA license & NRC approval-containers remain free of contamination
& radiation, as documented by wipe test logs & certs.
The computer program has no direct effect on this section.
- 12. Calibration Equipment:
D Shepherd, reviewer P Pho, head of audit review group A check of radiation survey instruments show that they are calibrated & certified quarterly, with S.N. & date of next calibration.
A check of other measuring & test equipment show that they are calibrated yearly, with S.N.& date of next calibration.
Certs with NIST, ANSI etc., traceability kept on file.
No instruments found to be out of calibration within 1991-1992 time frame.
PO's for outside vendor calibration were examined & found to meet all PO requirements.
PO's are the only computer interface with this section.
- 13. Handling, Shipping & Storage:
J Fuzzell, reviewer radiological Q Pho, reviewer nonradiological P Peabody, head radiological audit review group P Shepherd, head nonradiological audit review group A review of personnel & their qualifications who do special handling, storage & shipping shows that they are qualified & trained.
A review of finalinspections show that they are 3erformed & documented per NRC, DOT
& IAEA (when applicable) specs before slipment.
All shipping paperwork is reviewed & verified by management.
10CFR21.6 posting has been accomplished.
The computer program does not effect this section, except for word processing.
- 14. Inspection, Test & Operating Status:
D Tran, reviewer N Pho, head audit review group A review of files showed that documentation conceming, inspection test & operating e
status of shipping containers is sent to the appropriate departments, customers &
other organizations, as required.
Inspection tags & l.D. are noted & checked when removed.
The computer program doesn't effect this section.
- 15. Control of Nonconforming Material, Parts or Components:
D Shepherd, reviewer V Towne, head audit review group Procedures for receiving & inspection were reviewed - nonconforming parts are kept i
DICEMUIR 30,1)92 JLS&A YEARLY INTERNAL AUDIT. POSTAUDIT CONF [RENCE Page 5.
t rparate from inventory & the appropriate departments are notified.
A reviev of 10 files showed that reworked / repaired items were re inspected to the original t riteria.
10Cf R21.6 postings requirement have been met.
Purchased parts are traced thru the computer system, rejected parts are sent back - before the inventory process is started, thru purchasing.
- 16. Corrective Action:
JL Shepherd reviewer Q Pht,, head audit review group Material rejections are submitted to the proper departments so returns to vendor or production rework can be accomplished.
Audit corrective actions cre reviewed in oostaudits.
The computer program doesn't cifect this section.
- 17. QA Records:
RN Donelson, reviewer J funell, head radiolo};ical audit review group P Shepherd, head nonradiological audit review group the following; records were reviewed for quality & safety:
drawin;;s, specifications, PO's, operating logs, reviews, tests, audits, mat'l. analy sis, personnel qualifications, procedures, nonconformances & corrective actions.
Permanent records are legible & complete & documents are retrievable.
Records are preserved & liled in metal cabinets some special records are controlled directly by departments.
- 18. Audi;s:
Mr Shepherd, reviewer M Pauls, head audit review group T his audit was conducted in the prescribed manner - except that we didn't meet at a local cantina, everyone was disappointed.
Lead auditor & auditor qualifications have been established & are on file.
Preaudit conference was scheduled.
Postaudit conference was scheduled.
Audit was performed in a timely manner.
Audit results are in work processing, with backups.
All agree that we should audit sections on a monthly basis, it has been determined that the review groups for the year be established at the next Preaudit meeting. All agreed that the next Preaudit meeting will take place on Jan 15,1993, at 3:00 pm.
Nctes taken by M Pauls.
MIP/mp 1/5/93 i=M
e
' flNAL COMPLETION Cil[CKLIST FOR INTERNAL AUDITING Of JLS&A'S QA/QC PROGR 10Cf R $UDPART 11 ILIAD Of AUDIT MANACIM[NT DA'I[ COMPLfi[D CRillRIA TITLE RIVilW CROUP RivilWIR
- 1. Organization Chart it. THou u t.,
m.r. Sue pgno
/MA h/E.L
- r. Job Descriptions
.2 N[/g$
- 2. QA Progsam Plan hd.P us..
ryt r. CHEPHGO
/
v h/A kk
- 3. Design Control M. meos...
ert sHepace
//-/9-U N
_e., o e rss o.
Pso Control J.S. S HCPHCQ D S. Manufacturing Control
. o. PH O JL SHE PH EDD
./b,f{AM M[
- 6. Document Control D.3$fu m n snE Dnf gD 11-t 1-9u d$<f //M.,,,S
'l
/8 N*'f*'dv N
- 7. Control of Purchased
_. Q PMo
!% SHEPH6h13 Mat'Is, Parts & Comp.
' o7 8.10 & Conteol of C TOWM D.rrtA0 I
h Mat'Is, Parts & Comp.
- 9. Controf of Special 3 5. 6+iF Ph6e.b n.o.rx,0 Fosc o S NNME-- [
Processes J. Fut'EELL ' R$g/
O. PEAbcD9 - RAD.
fj g //- N - 6
/M a
- 10. Inspection Control O. P+10 pe,o n An, c. P an. ocaho.
w
- 11. Test Control a. Pao
_R n f5 cort %0
/bD
. Aq
- 12. Calibration fquipment
,p. P Ho D.SaspHm1O
//h7/d "f d M
- a. rassocoy a %
- r. et.cr.xett.- ano.
//-/m ' o yp
- 13. flandhng, Shipping &
,4.1,9tonenS. g ci. Pro De,o RAo
//-//-92
./M{
g Storage
/M,Q k,
- 14. Inspection, Test &
- o. Oso
_ D. Tr( A o nT Operating Status
- 15. Controf of Nonconform.
V. -toe os
. D.
% H EFH6P.D Mfa
~~[D Mat'l, Paris & Comp.
I
- 16. Corrective Action
. O, PM6 3 L S H F D M Q.D A
5.rancu Rao
/8404 II@h O
- 17. QA/QC Records
_ p.
snEPHFan. x,a no idcetsoo
// h 02 Oy RNO
- 18. Audits m PAu Ls er nw=rw reb
/M7N.?M/ /g PREAUDIT RIVi[W DATE: lola C l'99:L AUDIT COMP ((llON DAT[: 8M01 IIM.
- POST AUDIT RIVl[W DAll: /2/3Ob W A-W d d)w//
POSTAUDIT MANAGEMENT REVl[W DATE: / V4 9 _
fL SilfPil[RD,fPSidGT [
QAM/QP 18.0 Audits, implementing Procedure, QA RM 001 A, Rev. 3,10/10/9V
)
Rev. O, Appr.Qlfj 10/1/92, location: Mf 5 Wordstar, QA18AUDL 1
- QAM/QP 6.0'b,ocument Control Any revision to this document must be numbered, dated & approved.
I i
L
- j
4 INDIVIDUAL CRITf RIA ClifCKLIST (18 TITLES)
TOR INTIRNAL AUDITING Of JLS&A'S QA/QC PROGRAM
- 1. ORGANIZATION CilART & JO!! DESCRIPTIONS HIAD Of AUDIT RIVitW GROUP:
V., THo ueJE, d Met 6 MANACIMINi RIVilWIR:
M. F.
S H E PH E RD _ MSt _ JdlL n DAlf COMP 111tD:
I C> /2 */ /e :r-
/
QUISTIONS:
YIS NO COMMIN15
- 1. Is the Orpnization Chart curient?
- 2. Are all QA/QC personnellistedf V
- 3. Are responubihties listed?
/
- 4. Is there sepoi.abihty to upper management?
- 5. Are resumes & trainirig records on file?
/
- 6. Does the computer program effect this section?
/
t l
l QAM/QP 18.0 Audits, implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 Rev. O, Appt.:JLS 10/1/92, location: MI5 Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
INDIVIDUAL CRITEHlA Cil[CKLIST (18 TITLES)
TOR INTIRNAL AUDITING Of JLS&A'S QA/QC PROGRAA1
- 2. QA/QP PROGRAAt PLAN.
/
lilAD Of AUDIT R[VilW CROUP:
o D 40 % m. PA uA%
Mb hhNACIMt NI RIVIIWI R:
rw F.
% e pH t An m, m, DATE COMPLITID:
/// 2q M./
Ih-y-J V
\\
QU[STIONS:
Yl5 NO COMM[N1S
- 1. Is Plan apptoval curtent?
V' _ __
2.15 approval resubmittal due next year?
- 3. Does the computer program effect this section? _
__/
()
(_ //H&/
- W W HS ag; c.d wu.ec. All /8f a
//fD
. QAM/QP 18.0 Audits, implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 Rev. O, Appr. JL S 10/1/92, location: Mf S Wordstar, QA18AUDL QAM/Ql' 6.0 Document Control. Any revision to this document must he numbered, dated & approved.
INDIVIDUAL CRITIRIA Cil[CKLIST (18 TITLES)
IOR INT [RNAL AUDITING OF JLS&A'S QA/QC PROGRAM
- 3. DISICN CONTROL,
ll!AD Of AUDIT RIVi!W CROUP:
ar rmaer
/. //
fgt W /
MANACI MI NI' RIVilWi k:
1 L.
S HE D H F AA M 2 N/._.
11All COMPT 11t D:
//,/ 9,/'lft 7
e QUISilONS:
Y[S NO COMMLNTS
- 1. Are the procedures adequate for ensonng that all documentation has all pertinent info e
gj
& conforms to pertinent regulations?
/\\
- 2. Are desigri change procedures adequate?
[
- 3. Are all appropriate departments notified of changes?
- 4. Rev ew of c hanges are they documented?
M
- 5. Are thanges checked & approved before
^/
x release?
- 6. Are bcensing authorities notified when pertinent (hanges occur?
O [N l/ft'l.
.,)a
) A.tvc W.W "
- 7. Arc design control change procedures controlled?
- 11. Are vellums (died correctly?
- 9. Do job files have current drawings?
A
- 10. Does the Autocad system have any irnpact
\\/
on design procedures?
/\\
a QAM/QP 10.0 Audits, implementing Procedure, QA-RM-001-A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, location: MI5 Ward 5 tar, QA10AUDL QAM/QP 6.0 Document Control Any revision to this document must be numbered, dated & approved.
hu i
._=
.=
gl INDIVIDUAL CRIT [RIA ClifCKLIST (18 TITLES)
IOR INilRNAL AUDITING OF JLS&A'S QA/QC PROGRAM
- 4. PROCUREMENT DOCUMENT CONTROL
)
HIAD Of AUDIT RIVilW CROUP:
L.
tareiss V
// / /
nE 7
MANACIAtlNI RIVitW1R:
n.
Pan Ah d DAlf COMPitilD:
I /- / O - er-i QULSilONS:
YES NO COMMLNTS
- 1. Are purchasing dept, procedures adequate?
- 2. Are the appropriate references & specifications
/
appearing on PO's?
t/
- 3. Is Subpart H criteria appearing on PO's?
/
- 4. Are source inspection 'right of access
- clauses
/
included on PO's?
v
- 5. Do PO's contain the appropriate references,
/
drawings, specifications, procedures, etc?
t/
- 6. Do Dalls of Materials include appropriate records, certs or test results to accompany order or be retained by vendor?
- 7. Are changes to PO's reviewed by the appropriate departments?
- 8. Are incoming purchases checked on delivery for
/
verification of specifications?
v/
- 9. Are nonconforming parts returned to vendor?
- 10. is the offending vendor resiewed?
- 11. Does the Realworld computer system effect or change any pari of QA/QC Program?
l QAM/QP 10.0 Audits, implementing Procedure, QA-RM-001-A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, location: MfS Wordstar, QA18AUDL QAM/QP 6.0 Document Conte 01. Any revision to this document must be numbered, dated & approved.
=-.
INDIVIDUAL. CRITERIA Cil[CKLIS) '18 TITLES)
IOR INTIRNAL AUDITING OF JLS&A'S QA/QC PROGRAM
- 5. MANUIACTURING CONTROL M.PHo k //-
1 llIAD Of AUDIT HIVl!W GROUP:
IS. SHOs ts y MANAGEMINT RtVitWIR:
TL SHEPHF#_B //M7L. / "
DATI COMPLIII D:
74W h92 --
[f '
QUfSfiONS:
YES NO COMMLNTS
- 1. Are manufacturing procedures being adhered to in accordance with procedures, instroctions inspections A/or drawings?
- 2. Are manufacturing procedures, instructions, inspections A/or drawings prepared, approved, reviewed & conteolled?
- 3. In reference to irnportant M safety iterns, do the procedures, instruction &/or drawings include tolerances, operating limits A/or workmansipp?
- 4. In reference to important to safety items, does the inspection & acceptance cratesia serify that tolerances, operating limits & Workmanship have been met?
- 5. Do the QA and Radiological Dept's. review in-section plans, test, calibration and special pro-cess procedures, drawings A/or specifications
/
and alternates thereto?
/
- 6. What areas are effected by the computer pro-gram & have adequate measures been taken to
/
- JJ> (M 'bc o 'r * ' I
incorporate the program into the QA Program?
V q'r-i
- 7. Are 10Cf R71 procedures for packages incorpor-aled into manufacturing?
V,
- 8. Are repair, rework &/or maintenance of packages
/
established & prescobed to before work begins?
Mtm mykWv-i
- 9. Are package loading / unloading procedures (rad.
surveys, contamination wipe tests, temp. A pres.
measurements, package venting, rigging & rnove-ment as applicable) establishedt
- 10. Are package procedures established for proper DOT transport (in good condition, adequately secured, identified properly)?
- 11. Does the computer program effect this section?
l I
st a QAM/QP 18.0 Audits, Implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, location: Mf S Wordstar, QA18AUDL QAM/QP 6.0 Document Contrni. Any. revision to this document must be numbered, dated & approved.
INDIVIDUAL CRIT [RIA CllECKLIST (18 TITLES)
FOR INTIRNAL AUDITING OF JLS&A'S QA/QC PROGRAM
- 6. DOCUMENT CONTROL h
th >
A/4 l.
Il[AD Of AUDIT RIVl[W CROUP:
r>. TTA o + L nwSR MWs MANAGtMI N T RIVILWI R:
____ m p.
D4EPHErm m.1. l O_
DAll COMPLIllD:
n - / 7-e>--
QUESTIONS:
YES NO COMMENTS
- 1. Are all QA/QC documents & revisions subject to review & concurrence by appropnate deparInwnts?
- 2. Are issuance of QA/QC documents & revisions
/
procedurally controlled?
V
- 3. Does the department which makes a revision to documents super 4e the processing of the change or revidon?
- 4. Are revisier made on all appropriate documents?
- 5. Are all pertinent QA/QC documents available j
at the site where they are to be implemented?
v
- 6. Are revisions current & do they appear on the appropriate documents?
,V
- 7. Does the computer program effect this section?
QAM/QP 18.0 Audits, Implementing Procedure, QA RM-001-A, Rev. 3,10/10/90 Rev. O, Appr.-)LS 10/1/92, location: MIR WardStar, QA18AUDL QAM/QP 6.0 Document Contrai. Any inision to this document must be numbered, dated & appioved.
~ _ _ _ _ _ _ _. _ _. - -
t INDIVIDUAL CRl1[RIA Cil[CKLIST (18 TITLES)
IOR INTfRNAL AUDlilNC Of JLS&A'S QA/QC PROGRAM
- 7. CONTROL OF PURCilASID MATERIALS, PARTS & COA ONEN1F, HIAD Of AUDIT RIVilW GROUP:
m DH6 C'M MANACIMINT RIVilWI R:
(b S ev-_ Ai u nli
' X b.. &
DAl[ COMPlillD:
// - M
'/V QUlS110NS:
YES NO COMMENTS
- 1. Is vendor selection contsolled or approved by Ingineering, Radiological or QA/QCf
- 2. Have designated vendor QA programs been
/ # U # I' # M '0 # f # "'-'
- auditedf GYPPjEO /PPMAl5 INj3
- 3. Do designated vendors QA Programs comply with pertinent elements of 10Clk71, Subpart H or
]'
10CRi?1?
Y
- 4. Are vendor records reviewed before purchase
/
of sitnitar types of articles?
v S. If required, are vendors selected on the basis of bids & evaluation of 10Cl R71, Subpart H com-
[
pliance?
- 6. Do the appropriate department representatives visit a designated vendor to assure QA/QC com-
/
pliance during fabrication, testing, etc ?
1 1'
- 7. Is documentation kept which identifies the pur-chased part, mat'i., etc., and that pertinent standards, codes, etc. have been met ?
- 8. Is documentation kept which desenbes noncon-formances of purchased items?
- 9. ;! e emoforming item has been repaired or re-placed,is..., opptopriate documentation kept?
- 10. Are on-site vendor inspections subject to in house QA/QC standards?
- 11. Is material which is not properly identified or does not correspond to the purchase descoption controlled by QA or Radiological, until disposition is ascertained?
- 12. Are certificates of conformance, concerning acceptance of materials, distributed with item?
- 13. Are nonconforming items held separate unit a review and disposition of item has been per-formed?
__.. _.. _ _ _. _ _ _ _ _ _ _ -.. _ _. _. ~... - _ _ _. -..._... - _ _ _ _.-_._. _.. _.......___.. _..
3
- 7. CONTROL Of PURCHASID MAT [ RIALS, PARIS & COMPONENTS.
PAC [ 2,
- 14. Are records identifying the itern, s.ith specific PO requirements & cerlifications & any noncon-formances and resolutions thereof kept in job or other files as permanent records?
- 15. Are results of supplier / vendor evaluations kept on file?
/
- 16. Does the computer program effect this section?
r 1
. QAM/QP 18.0 Audits, implementing Procedure, QA-RM 001-A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, location: Mf 5 Wordstar, QA18AUDL -
QAM/QP.6.0 Document Contrcd. Any revision'to this document must be numbered, dated & approved.
r#
W'"W wrv- ' -
.'s T",'
-t M-
-rg'pi'i e
'n--
4 e
a-pm-
--rr r-M-m s--+-
e
=+-$
rv-w m-y-
o-er T
atswe--4--u-i set-T--e--
se ry e
INDIVIDUAL CRIT [RIA Cil[CKLIST (18 TITLES)
IOR INT [RNAL AUDITING 01 jlS&A'S QA/QC PROC'/AM 8.1.D. & CONTROL Of MATERIALS, PARTS & COMPONENTS.
llIAD Of AUDIT RLVilW CROUP:
_V. Tnta DC
/
AMNAClMlNI RIVilWlR:
D.
Trt 80
/Jou L i DAlf COMPL1TLD:
I /,/ 7 7,/ '/1 QUISilONS:
Y[S NO COMMENTS l
- 1. Are there standard procedures for identifying g h y
part, etc., either as received or fabricated?
,)f) t18U56c C'
/
- 2. Are received of fabricated parts inspected, identified & marked?
Y
- 3. Is the identification & marking traceable to QA/QC records?
- 4. Ate nonconforming or nonenspected parts kept
[b(f leW TA65 g g veh separate frorn approved inventoryf
- 5. Are important to safety items identified & marled
& traceable to QA/QC records?
K
- 6. Does the receiving area & method of identification for received or fabricated parts in any way interfere with fit, function or quality of an stern?
- 7. Are inventory items verified that they are the proper item for a job before release for fabrication, assembly or installation?
- 8. Are partial releases of nonconforming or non-
/
bp7)c'Lf>tS6 inspected items conteolledt
- 9. Does the computer program effect this section?
g 9 A cap IIhm %+
^
l l
QAM/QP 18.0 Audits, implementing Procedure, QA RM-001-A, Fsev. 3,10/10/90 Rev. O, Appr. JLS 10/1/92, location: Mf S Wordstar, QA10AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
INDIVIDUAL CRITERIA CHECKLIST (18 TITLES)
IOR INT [RNAL AUDlilNC 01 JLS&A'S QA/QC PROGRAM
- 9. CONTROL Of SPECIAL PROCESSES.
litAD Of AUDIT RIVIIW CROUP:
.<. sHFPHEr(B Oaa b MANACIMINI RtVilWIR:
I?. O. OCO ELSC O //[f k[b Nm DATI COMPLL1[D:
/5 Ahe'9e QUESllONS:
Y[S NO COMMENTS
- 1. Are special processes (welding, heat treating, cleaning, nondestructive testuig, etc.) procedurally controlled by the foreman in house and by QA at vendor facilities?
t
- 2. Does the equipment, personnel & procedures in-volved in special processes meet all appheable codes, standards, etc.?
- 3. Are records concerning equipment, personnel & -
processes current & on hie?
\\
- 4. Does the computer program effect this section?
X QAM/QP 18.0 Audits, implementing Procedure, QA RM.001-A, Rev. 3,10/10/90 Rev 0, Appr.:JLS 10/1/92, Location: Mf S Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & apptoved.
-J
m INDIVIDUAL CRIT [RIA Cil[CKLIST (18 TITLLS)
[OR INTERNAL AUDITING Of JLS&A'S QA/QC PROGRAM
- 10. INSPECTION CONTROL - 0 20 IM NML.
It[AD Of AUDIT RLVl[W CROUP:
O. PM 6 A
MA %
MANACLM[NI' REVi!WL R:
D.
PHO (A / /
7 I
DAl[ COMPL11tD:
11 /lo / v>
i
(
g QUESTIONS:
YES NO COMMLNTS
- 1. Are QA/QC inspections documented by written &
controlled procedures, instructions or checklists?
k
- 2. Is work held for inspections at appropriate phases?
- 3. Do receiving inspection venly the integrity of important to safetyitems,i.e inspections, wipe tests, radiation surveys, log entries & document evaluation?
- 4. On reusable shipping containers, are inspections g
performed & are snaintenance items identifiedt
\\
S. On reusable shipping containers, if replacement items are required, is a specific job tile established
& are design evaluations, purchasing, inspections &
aCCeplanCe criteria perfonned before rerelease of the container?
g//
I V
- 6. Do procedures ensure that indirect control of processing methods, equipment & personnel is verified by documentation if direct supervision g /'
is impractical?
U
- 7. Do final inspections verify item integrity thru operational check out, reassessment of allidetifi-able & traceable records, documents & inspections?
D Are completed items protected from physical &
envuonmental damage prior to shipment?
I.
- 9. Do inspectors inspect items, including modifications, repairs or replacements in accordance with original g.
design specifications & are inspections documented?.
\\.
- 10. liave inspectors been qualified to applicable codes, standards &/or training programs and are their certifications & qualifications current 1
and on file?
\\
- 11. Does the computer program effect this section?
/
- QAM/QP 18.0 Audits, implementing Procedure, QA RM 001 A, Rev. 3,10/10/90 Rev. 0, Appr.:JLS 10/1/92, tocation: Mf 5 Wordstar, QA18AUDL QAM/QP 6.0 Document Contr01, Any revision to this document must be numbered, dated & appt L.
__p.
p
,p
. +. _ -..
y yr-y----
m---- - - -
-,r
.mn-w,,m.-w-Tm T-w 1
1 lNDIVIDUAL CRIT [RIA Cil[CKLIST (18 TITLES)
FOR INT [RNAL AUDITING OE JtS&A'S QA/QC PROGRAM
- 10. INSPECTION CONTROL - QNot-cGiCA L
\\
//,I HEAD OF AUDIT RLVilW CROUP:
R.
PGATbC^l MANACIMINT RIVIIWL R:
1 Ftet2 Et A l
DAlt COMPLLTLD:
u o 4 - 9p M
yi QUESTIONS:
YES NO COfAMENTS
- 1. Are QA/QC inspections documented by written &
y controlled procedures, instructions or checkhsts?
- 2. Is work held for inspections at appropriate phases?
[
- 3. Do receiving inspection verily the integrity of important to safety items, i.e. inspections, wipe tests, radiation surveys, log entries & document evaluation?
/
- 1. On reusable shipping containers, are inspections performed & are maintenance items identified?
/
- 5. On reusabic shipping containers, if replacement items are required, is a specific job file estabbshed
& are design evaluations, purchasing, inspections &
acceptance cnteria performed before rerelease of the container?
y
- 6. Do procedures ensure that indirect control of processing methods, equipment & personnel is venfied by documentation if direct supervision is innpractical?
7
- 7. Do final inspections verify item integnty thru operational check out, reassessment of all idetifi-
[
able & traceable records, documents & inspections?
- 8. Are completed items protected from physical &
7 environmental damage prior to shipment?
l
_ 9. Do inspectors inspect items, including modifications, repairs or replacements in accordance with original design specifications & are inspections documented?
- 10. Have inspectors been quahfied to applicable codes, standards &/or training programs and are their certifications & quahlications current and on file?
7 u muu
- 11. Does the computer program effect this section?
OA dr4 A in<-
n ea essa g %
QA/qc QAM/QP 18.0 Audits, Implementing Procedure, QA-RM-001-A, Rev. 3,10/10/90 Rev. O, Apprejl510/1/92, Location: MIS Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
y.
4,,
y
INDIVIDUAL CRIT [RIA CH[CKLIST (18 llTLES)
IOR INT [RNAL AUDITING OF JLS&A'S QA/QC PROGRAM
- 11. T[ST CONTROL HEAD OF AUDIT RIVl[W CROUP:
& Pao Ar#
MANACIMLNI RIVilWLR:
RO boOEL500 b Nch 1 -
DAl[ COMPL[IlD:
ll %-9V QUESTIONS:
YES NO COMMENTS '
- 1. Are test programs (prototype, licensing, etc.)
established, documented & perfonned?
- 2. Are modifications, repairs or replacements to the original design meet the original specihcations or acceptable altematives?
- 3. Do established procedures identify test criteria, mcluding instrument calibration & condition, monitoring, hold points, environmental conditions methods of physical 1.D., documentation &
acceptance enteria?
- 4. Are test programs evaluated & determined to be acceptable by engineering, QA, radiological &/or ollicers of JLS&A as apphcable?
- 5. Do shipping containers meet acceptance criteria (applicable NRC or DOT certificates are current, physicalinspection of container completed &
documented) prior to shipment?
C. Is there an established program to ensure that containers remain free of excessive contamination &
radiation by wipe test?
/
- 7. Does the computer program effect this section?
QAM/QP 18.0 Audits, implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 Rev. O, Appr.:jlS 10/1/92, location: MfS Wordstar, QAlflAUDL
- QAM/QP 6.0 Document Control Any revision to this document must be numbered, dated & approved.
y
---7-.,-7w-y-
7 7
-,,,,-w..
,-p7y
-,g.y p
y y-y n..s.
g-
,.yp.
INDIVIDUAL CRITERIA Cll[CKLIST (18 TITLES)
FOR INTIRNAL AUDITING Of JLS&A'S QA/QC PROGRAM
- 12. CONTROL Of MEASURING & TEST [QUIPM[NT.
HEAD Of AUDIT RIVi!W CROUP:
.d.
PHn h/Alef//AMC MANACIMIN T RLVi[WI R:
D.
SweDHERA Y M la [ l'. 0 UAll COMYLETLD:
tI/Q9 /92,
~
! /
QUESTIONS:
YES NO COMM[N15
- 1. Are radiation survey instruments calibrated at 3 month intervals?
i
- 2. Are other measuring & test equipment cahbrated l
at yearly intervals?
\\
- 3. Do all test & measuring equipment have serial numbers?
- 1. Is the serial number referenced on test data?
\\
- 5. Is the equipment tagged as to the next date of calibration?
- 6. Does the cabbration of equipment meet apphcable standards, NIST, etc.?
.\\
- 7. Are cahbration records kept on file?
\\
- 8. If equipment is found to be out of cabbration, are new ti'st or measurements taken to vahdate previous measurements?
- 9. Does the computer program effect this section?
I I?b brh hhb y.ktA prcc 4 QAM/QP 18.0 Audits, implementing Procedure, QA RM 001-A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, Location: Mf 5 Wordstar, QA18AUDL QAM/QP 6.0 Document Cont 01. Any revision to this document must be numbered, dated & approved.
~ --. _ _ _ -
INDIVIDUAL CRITf RIA Cil[CKLIST (18 TITLES)
TOR INTIRNAL AUDITING 01 JLS&A'S QA/QC PROGRAM
- 13. IIANDLING, STORACE & SillPPINC. - DOO IMDIOLO&lE il[AD Of AUDIT HIVIIW CROUP:
P SHE/>HE(2 /
MANACLMLNT RIVitWIR:
o.
PH &
V 6'
DAl[ COMPLillD:
/l" /O 'y 2, QUI 5110NS:
YES NO COMMENTS
- 1. Do quahfied employees perform work related to special handhng, preservation, storage, clearung, packaging & shipping requirements to preclude physical or environenental damage?
_J.
- 2. Are hnalinspection perforrned & documented, j
per NRC A/or DOT requirements, before ship-
/
ment is made?
i/
- 3. Is shipping paperwork verified that it has been properly prepared?
1
- 4. is shipment time consistent with safe transporta-tion time?
_ _ s..
S. Has 10Cf R21.6 posting requirements been established?
_/v
- 6. Does the computer program effect this section?
p-l QAM/QP 18.0 Audits, implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 L
Rev. O, Appr.:Jl S 10/1/92, t ocation: Mf S Wordstar, QA18AUDL
. QAM/QF 6.0 Document Control. Any revision to this document must be numbered, dated & appr n
4 g
m u---
m-
r 1
I l
INDIVIDUAL CRIT [RIA CllECKLIST (18 TITLES)
FOR INTERNAL AUDITING Of JtS&A'S QA/QC PROGRAM i
- 13. IIANDLING, STORAGE & SHIPPINC. - RAbtotoG/ CAL, il[AD Of AUDIT RIVilW GROUP:
f3. Pf AfeBV 2
MANAGEMENT RLVIEWlR:
-T. rutteLL (1h DAl[ COMP 111iD:
W- // - 9L F'
QUESTIONS:
YES NO COMMLNTS
- 1. Do qualified employees perform work related to special handling, preservation, storage, cleaning, packaging & shipping requirements to preclude physical or environmental damage?
- 2. Are final inspection performed & documented, per NRC &/or DOT sequirements, before ship-
/
ment is made?
- 3. Is shipping paperwork verified that it has been
[
properly prepared?
4, is shipment tirne consistent with safe transporta-tion time?
- 5. Has 10CfR21.6 posting requirements been
[
establishedf ser ekt*de
- 6. Does the computer program effect this section?
hlf
@,/09..& raty QAM/QP_18.0 Audits, implementing Procedure, QA RM-001-A, Rev. 3,10/10/90' Rev. O, Appr.:JLS 10/1/92, location: MIS Wordstar, QA18AUDL QAM/QP 6.0 Document Contrnt. Any revision to this document must be numbered, dated A approved.
= - = -
. - - - - - - - =
ee w
' ' - ' ' ' ' ' ' ' " ' *~
' ^
t INDIVIDUAL CRIT [RIA Cll[CKLIST (18 llTLES)
IOR INT!RNAL AUDITING Of JLS&A'S QA/QC PROGRAM
- 14. INSPECTION, TEST & OPERATING STATUS.
IIEAD Of AUDIT R[VllW CROUP:
o.
PHO dh 144/f&
D MANACLMENT RIVilW[R:
O, rPJs o
' bh !%d' '
DATI COMPLITID:
ff / F/v?
i1 7
QUESTIONS:
YIS NO COMMENTS
- 1. Is the appropriate documentation (& id of inspections, tests & operating status) of ship-ping containers forwarded to the appropriate departments or organizations (shipping agents, custorners, etc.) and receipt acknowledgedt
- 2. Is the removal of inspection or i.d. indicators g[
l checked at time of removal?
v
- 3. On controlled stems, is the removal of inspection
$'[
or i.d. indicators checked & documentedt
- 4. Are nonconforming parts identified and are they g/
kept in a separate location?
V l
- 5. Does the computer program effect this section?
\\[
I l
i I
l l
du QA RM 001 A, Rev. 3,10/10/90 W 0 Appr hts
/9, L a1 r: I y
^
Ul l
QAM/QP 6.0 Document Conteof. Any revision to this document must be numbered, dated & approved
INDIVIDUAL CRil(RIA ClitCKLIST (18 itTLLS)
IOR INi[RNAL AUDITING Of JIS&A'S QA/QC PROGRAM
- 15. CONIROL Of NONCONIORMING MATIRIALS.
h
/ - '
lilAD OF AUDil RIVILW GROUP:
d. Tot 0 0r?
( &M TE'yM. -
MANAGIMINI HlVilWik:
D. rar t p rt t reA -j Q,.m_.dl4 DAf t COMPililD:
/2[R,/y/1 x
QUISTIONS:
YLS NO COMMLNTS
- 1. Are there estabhshed procedures Iur receiving &
rnspection to assure that the i.d., documentatiori, segregatuen of review disposition of norKonform-G ing enaterials?
A d
<R 6%
v
- 2. Are the appropriate depiirtrnents riotified so that the repair or replacernent of nonconforening items can be achkved?
<y
- 3. Are all reworked, repaired or replaced items subject to the onginalinspection A/or test procedures?
- 4. Are nonconformance reports evaluated to deterrnine qualdy trenah or problem areas?
S. lias 10CIR21.6 posting requirements been met?
- 6. Does the computer program effect this section?
Au %d aubs A Ole- 06 w*
9 QAM/QP 18.0 Audits, implementing Procedure, QA RM 001-A, Rev. 3,10/10/90 Rev. O, Appr/jlS 10/1/92, location: Mf S Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
r-INDIVIDUAL CRIT [RIA Cil[CKLIST (18 TITLES)
[OR INI(RNAL AUDillNG OI JLS&A'S QA/QC PROGRAM L
- 16. CORR [CTIVE ACTION.
I I
Il[AD OF AUDil RIVilW CROUP:
n. PMo MANACIMINI RIVi[WIR:
.T L Snc PMQ & <_7 %d _..
DAll COMPL11t D:
/2. @. </2 -
/
~'
QUESilONS:
Y[S NO COMMENTS
- 1. Are corrective actions evaluated and reported to the appropriate departments?
/
- 2. Are corrective action proceedings followed up with
/
reviews to detennine effectiveness?
V
/
- 3. Does the cornputer program effect this section?
l l
QAM/QP 18.0 Audits, implementing Procedure, QA RM 001 A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, Lecation: Mf S Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any reusion to this document must be numbered, dated & approved.
INDIVIDUAL CRITERIA Cll[CKLIST (18 TITLES)
IOR INTERNAL AUDITING OI JLS&A'S QA/QC PROCRAM
IIIAD OI AUDIT RlVllW CROUP:
.p c,nEPHF/s t'>
- fMZ MANACLMINI RIVi!Wik:
it.o tecetr.ou 06/thA L L-DATI COMPLITt D:
//-Go #77 QU[SllONS:
Y[S NO COMMINTS
- 1. Do the following QA records furnish docurnentation concerning the quality & safety of items?
/
Drawings:
_sf,
Specifications:
./
l'urihasing Docurnerits:
//
Operating Logs:
'/
Reviews:
/,
'Iests:
./ /
Audils:
/,
Materials Analysis:
,/
Personnel Qualifications:
_,/,
~
ProCodures:
)[
Calibration procedures:
f, Nonconformances:
/,
Corrective Actions:
,/
/
( re cow.s&d)
- 2. Are :ecords legible & complete?
/
F/ntz NmW G*AW'
- 3. Are required records indexed & classified?
- 4. Are QA :ecords & documents identifiable & re-trievable?
)
v
- 5. Are QA records subject to storage, preservation
& safekeeping?
/
4 1
QAM/QP 18.0 Audits, implementing Procedure, QA KM-001-A, Rev. 3,10/10/90 Rev. O, Appe.:jts 10/1/92, location: Mf 5 Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
..... =_
. ~-
4..
INDIVIDUAL CRITfRIA CHECKLIST (18 TITLES)
IOR INT [RNAL AUDlIING Of JLS&A'S QA/QC PROGRAM
- 17. QA R[ CORDS. - EADr owNL HEAD Of AUDIT REVi!W CROUP:
T Fur.7 6LL MANACIMLNT RLVilWIR:
P_ o. Ceoc Led /EnM -%%
DATE CDMPLLTLD:
//- O W 95 a2)
QUESTIONS:
YES NO COMMENTS
- 1. Do the following QA records furnish documentation concerning the quality & safety of items?
Drawings:
/
Specifications:
/
Purchasing Documents:
7 Operating Logs:
/
Reviews:
/
Tests:
/
Audits:
/
i* #1 *7 UN Materials Analysis:
/
Personnel Qualifications:
c' Procedures:
,/
Calibration procedures:
/
Nonconformances:
Corrective Actions:
/
- 2. Are records legible & complete?
/
- 3. Are required records indexed & classified?
/
- 1. Are QA records & documents identifiable & re-trievable?
/
S. Are QA records subject to storage, preservation
& safekeeping?
/
I QAM/QP Ifl.0 Audits, implementing Procedure, QA-RM-001 A, Rev. 3,10/10/90 t
Rev. O, Appr.:JLS 10/1/92, location: Mf 5 Wordstar, QA18AUDL QAM/QP 6.0 Document Control. Any revision to this document must be numbered, dated & approved.
k
O' INDIVIDUAL. CRITERIA Cit [CKLIST (18 TITLES)
FOR INTERNAL AUDillNG Of JLS&A'S QA/QC PROGRAM
- 18. AUDITS.
tilAD OF AUDIT RIVIEW CROUP:
m.f%uiA k
- 8/
MANACLMLNT RLVILWlR:
evs i-S H F PH G/?_A
/M. s DATE COMYLl1L D
/3/7/02.
QUESTIONS:
YES NO COMMENTS
- 1. Are audits conducted in a prescribed rnanner?
/
- 2. Arc audits scheduled?
/
- 3. llave qualifications for lead auditors & audit
~
personnel been established?
/
- 4. Are preaudit conferences scheduled?
/
- 5. Are post audit conferences scheduled?
/
- 6. Is audit reporting & response subject to time restraints?
/
- 7. Are timely responses & followup actions as a result of audits verified?
/
- 0. Does the computer program effect this section?
/
QAM/QP 10.0 Audits, implementing Procedure, QA RM-001 A, Rev. 3,10/10/90 Rev. O, Appr.:JLS 10/1/92, location: Mf S Wordstar, QA18AUDL QAM/Ql' G.0 Document Control. Any revision to this document must be numbered, dated & approved.
e---
QAM/QP # 5, Audits, QA RM001 A, Rev. 3,10/10/90 NOVEMil[R 9,1992. JLS&A YEARLY INT [RNAL AUDIT AUDIT CHECKLIST CONFERENCE Postaudit Time: 2:30 PM.
Attendees:
JL Shepherd, Mr Shepherd, DC Shepherd, JS Shepherd, Q Pho, D. Tran, V Towne, M Pauls, L Weiss, K Thoune, RN Donelson, P Shepherd, j fuzzell, B Peabody, N Pho Audit Step 1. Due Nov. 9,1992, all head reviewers for each of the 18 point criteria sections will have evaluated their Audit inspection List to determine if changes need to be made, for the list to be effective in an internal audit.
No objections or changes were submitted. 3" Sections had been completed.
Suggestion of Preaudit Conference: A yearly on going audit, alternating 1 per month,2 per month to be determined at postaudit conference.
Notes taken by M Pauls.
MIP/mp 11/9/92 l
L.-