ML20128G843

Insp Rept 99901300/96-01 on 960709-12.Deviations Noted. Major Areas Inspected:Implementation of Selected Portions of QA Program

ML20128G843
Person / Time
Issue date:	09/25/1996
From:	NRC (Affiliation Not Assigned)
To:
Shared Package
ML20128G749	List: ML20128G745 ML20128G786 ML20128G843
References
REF-QA-99901300 99901300-96-01, 99901300-96-1, NUDOCS 9610090149
Download: ML20128G843 (12)

Text

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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF NUCLEAR REACTOR REGULATION Report No: 99901300/96-01 j Organization: Framatome Technologies, Incorporated

Integrated Nuclear Services i Lynchburg, Virginia l

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Contact:

Emily Mayhew, Acting Quality Assurance Director

, (804) 832-3331 4

Nuclear Industry Supplier of eddy current nondestructive Activity: examination (NDE) related training, nuclear power plant steam generator tubing eddy current examination and analysis and NDE personnel l j services. l l

i Dates: July 9-12, 1996

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Inspectors: Joseph J. Petrosino, Team Leader l John K. Ganiere, Electrical Engineer l Michael J. Morgan, Reactor Engineer Phillip J. Rush, Materials Engineer Michael E. Waterman, I&C Engineer Approved by: Gregory C. Cwalina, Chief Vendor Inspection Section Special Inspection Branch Division of Inspection and Support Programs Office of Nuclear Reactor Regulation  !

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• 9610090149 960925 PDR GA999 ENVFRAMA 99901300 PDR

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l 1 INSPECTION

SUMMARY

During this inspection, the NRC inspectors reviewed the implementation of selected portions of the quality assurance (QA) program which is being implemented by the Integrated Nuclear Services Department of Framatome Technologies Incorporated (FTI) and activities associated with FTI's nuclear power plant steam generator (S/G) tube eddy current (EC) testing services.

The inspection bases were as follows:

• Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," to Part 50 of Title 10 of the Code of Federal Reaulations (10 CFR Part 50) i 10 CFR Part 21, "Reparting of Defects and Noncompliance" l 4 During this inspection, The NRC inspection team (team) identified three instances where FTI failed to conform to NRC requirements imposed upon them by  ;

NRC licensees which are discussed herein.

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2 STATUS OF PREVIOUS INSPECTION FINDINGS This was the first inspection of EC nondestructive examination services that

. is managed by FTI's Integrated Nuclear Services facility, formerly operated by Babcock & Wilcox, Incorporated.

3 INSPECTION FINDINGS AND OTHER COMMENTS l

3.1 Ouality Assurance Proaram '

l The NRC inspectors selectively reviewed FTI's Quality Assurance Program Manual ,

(QAPM), Revision 2, dated January 1,1996, and its implementation for safety- '

related activities concerning NRC licensee nuclear power plant S/G tube  !

inspections using nondestructive EC testing methodology. The team also reviewed selected departmental work instructions for the Service and EC l Departments.

The team found that FTI's QAPM encompasses its safety-related products and

' services supplied to NRC licensees under NRC and other nuclear industry requirements, American Society of Mechanical Engineers (ASME) Boiler and Pressure Code items and its non-safety related products and services. In its review, the team found that FTI was satisfactorily implementing its QAPH in

, the EC testing area, with the exception of some areas in which FTI did not have adequate instructions for controlling safety-related activities using written procedures or instructions. The team found that FTI was generally

, performing the required activities in these areas and had been typically

! performing additional activities which were not reauired procedurally, but i enhanced or improved the particular process. That is, the team found that FTI had not established procedures to control these additional activities (further

discussion in Section 3.2). As a result of its review, the team concluded i that the implementation of FTI's QA program as it related to EC tn ting was 2

appropriate, except as discussed later in the report.

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l 3.2 Data Analysis Procedures and Acauisition Techniaues i I

The team reviewed the vendor's processes and controls for developing site-specific EC data analysis guidelines. Requirements for analysis guidelines are specified in FTI's " Administrative Procedure for Control of Inservice I Inspection Procedures and Procedure Qualifications," ISI-1, Revision 8, dated 1

July 8, 1991. The team noted that additional requirements may be imposed on I the vendor by a utility.

The team evaluated the vendor's processes and controls on the development of site-specific procedures through discussions with FTI Nondestructive Examination (NDE) staff and also by reviewing previous FTI NDE inspections.

Analysis guidelines undergo numerous changes before inspections based on input l from the utility and other vendors involved in the inspection. ISI-1, l Revision 8, required a requalification of an inspection procedure if essential variables are altered. By a review of a sample population of site-specific examination guidelines developed by FTI, the team verified that changes to the guidelines were clearly documented. Overall, FTI's process for developing site-specific guidelines and the controls on changes to these procedures appear to be satisfactory. A Level III Examiner stated that FTI generally proposes the use of industry-qualified inspection techniques (Appendix H of the Electric Power Research Institute [EPRI] Guidelines), when possible. The team verified this information through a review of acquisition technique sheets incorporated into plant-specific S/G inspection guidelines.

The team concluded that FTI appeared to maintain good procedural controls for the development of S/G examination guidelines and that changes to the guidelines were satisfactorily incorporated in accordance with the vendor's procedures.

3.2.1 Control of Data Analyst Activities The team reviewed the vendor's measures to control data analyst activities related to S/G tube examinations. Industry guidance related to S/G inspections is described in EPRI NP-6201, "PWR Steam Generator Examination Guidelines," which made recommendations on analyst activities. The team verified that the vendor's program appeared to be generally developed in accordance with current industry practice.

However, the team found that FTI did not have any overall procedures, instructions or written guidance for controlling EC data analyst activities.

Rather, the vendor relied on the requirements imposed by the different utilities for the particular S/G tube inspection. Utilities generally require all data analysts to pass a site-specific examination before they can begin analyzing data for an inspection. In the absence of any formal procedures, such examinations are typically admini:tered, at the FTI facility, as close to the actual inspection as possible, but the examination could occur while the analysts are still performing work for other inspections. As a result, analyst activities between the time of the examination and the inspection could diminish the analyst's knowledge of the site-specific details emphasized 3

in the examination. Industry guidelines state that these examinations should be administered just before the start of the plant outage. FTI's program allowed this guidante to become more subjective than the industry guidance.

Further, because of the lack of procedures for the control of analyst activities, the team believed it to be possible for both primary and secondary data analysis activities to2 have occurred at the same location. This would not be desirable during an inspection and analysis of acquired EC test data.

FTI staff stated that they typically split their activities between offices in

. Lynchburg, Virginia and Benecia, California (Rockridge); however, no specific requirements appeared to be imposed by FTI to ensure that the two parties would remain in separate locations for the activi+y. The team concluded that FTI had not established adequate written guidance nor specificity in this area and it was considered as a weakness.

Although FTI had not established formal procedures governing the control of data analysts, it appeared to have implemented effective practices for managing its analysts, and the team found that goaa communication existed between the NDE staff and its supervision. Consequently, the team concluaed that this area appears to be effectively implemented. The benefit of having established FTI procedures to ensure continued effectiveness was discussed l with FTI staff. l 3.2.2 Computer-Assisted Data Analysis The team reviewed the vandor's controls for computer data screening (CDS) techniques used in the analysis of EC inspection data to assess whether FTI adequately managea Mivities involving the use of CDS. The team found that i FTI is often contracted to supply EC data analysis using a CDS algorithm.

These computer algorithms use specific criteria which was inputted by an FTI data analyst before a particular utility customer S/G tube EC inspection to identify expected EC indications. The individual responsibility is significant for the data analyst because they must develop these criteria based on expected modes of tube degradation for each different utility S/G tube EC examination. The team identified that FTI did not have a written procedure for controlling or establishing any specific process that is to be used by its data analysts for developing these criteria. As a result, the screening criteria developed by one analyst may be significantly different from that of another analyst.

To establish the parameters for identifying indications in the EC data, a data analyst must independently develop the screening logic. Before FTI starts its EC inspection at a particular nuclear power plant site, CDS is typically subjected to a site-specific examination, which it must pass in order to be used in an inspection. The team's review identified that when developing CDS criteria, analysts will typically address known degradation modes. However, 2

It is desirable to have the primary and secondary analyses for the same acquisition EC data to be located in different locations and performed by different analysts.

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l because of the different experience levels of the analysts, a variance in the effectiveness of the developed criteria can occur. This can allow types of degradation previously undetected by a particular analyst to be missed by the ,

CDS algorithm. Therefore, some type of parameters, or range, need to be delineated to ensure that the widest spectrum of degradation modes will be identified. This aspect was not addressed in FTI's program which was used in the CDS criteria development.

The team also recognizes that FTI's data analysts all appear to have a much wider knowledge of degradation mechanisms and may adapt to any new degradation mechanisms that appear during inspections. The team observed that although FTI analysts have not been working with written procedures or instructions regarding written guidance and instruction for the development of these criteria, FTI was only using experienced analysts for developing CDS criteria.

The team concluded that the lack of such procedures could lead to differing performance capabilities for CDS techniques under actual inspection conditions and as a result, the potential exists that the CDS program may fail to identify defective tubes containing new or different modes of degradation during the actual inspections. The team identified the lack of written guidance to govern the development of CDS criteria as Nonconformance 99901300/96-01-01.

3.3 Eddy Current Test Personnel Oualification/ Certification The team reviewed FTI's Nuclear Services Group Procedure FTI 54-ISI-24,

" Written Practice for Personnel Qualification in Eddy Current Examination,"

Revision 20, to understand FTI's procedures and process for FTI's eddy current NDE personnel qualification and certification.

The team found that trainees must follow the directions of certified personnel, and they are not allowed to collect or interpret test data unless permitted to do so by certified supervisors. Trainees are not allowed to independently conduct tosts or interpret, evaluate, or report on any test results. Trainees are typically upgraded to an NDE level I only after completion of a recommended 40-hour American Society for Nondestructive Testing (ASNT) training program and after accumulation of a minimum of 175 hours0.00203 days <br />0.0486 hours <br />2.893519e-4 weeks <br />6.65875e-5 months <br /> of " hands-on" experience.

FTI's Level I personnel perform specified setups, calibrations, and tests in accordance with written instrut.tions, and unlike trainees, they are allowed to record data. Level I personnel are authorized to perform test instructions only under the guidance of higher certified personnel, and Level I personnel are not allowed to independently evaluate or accept results.

FTI's Level I personnel are typically upgraded to Level II after complecion of a recommended ASNT training program and a minimum of 1,750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br /> (approximately 9 months) of hands-on experience. They perform setups and calibrations and interpret applicable codes, specifications, and standards.

They also note whether all data acquisition equipment functions properly and whether such equipment requires replacement. They prepare written 5

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instructions, are familiar with the scope and limitations of the testing method and provide on-the-job training (0JT) for all Level I and trainee personnel.

FTI's Level IIA personnel perform the same activities as Level II personnel and they undergo documented training in the analysis of nonferromagnetic tubing EC testing data. As data analysts, they also accept or reject testing data and interpret, evaluate, report, and disposition the data. FTI's Level II and IIA personnel are upgraded to Level III only after completion of a recommended ASNT training program. They establish examination techniques and procedures, analyze data, and interpret codes / standards and procedures / specifications and evaluate examination results based upon recognized codes and standards. Level III personnel specify exaeination methodologies, techniques, and procedures and they have experience in other forms of NDE.

Overall, the team concluded that this area appeared to be well controlled and straightforward, with only one exception where the team believed more attention to detail coulo be added. The taam noted that FTI's delineation of activities which could satisfy the required 1,750 hours0.00868 days <br />0.208 hours <br />0.00124 weeks <br />2.85375e-4 months <br /> of hands-on experience for the site-specific and S/G specific training appeared weak and vague.

However, FTI's routine methodology of practice and the performance of supplemental S/G inspection training was strong and appeared to compensate for the team's concern. For example, the team found that supplemental training, such as documented on-site training and OJT, appeared to adequately address different site requirements and unique S/G tube characteristics regarding variety and the accumulation of documented ASNT-recommended experience hours.

In summary, the team concluded that FTI's overall training appeared to be

, solid and well established, and the team found that FTI's EC personnel have an adequate basis for their qualification and certification, as measured by FTI's NDE Procedure 54-ISI-24. The team also concluded that this procedure appeared to be acceptable when compared to that of EPRI NP-6201, Appendix G. The procedure also appears consistent with the guidance in ASNT Recommended Practice SNT-TC-1A, 1984, the requirements of ASME Section XI, 1989, and the requirements of 10 CFR Part 50, Appandix B, Criterion IX.

3.4 Vendor Self-Assessments and Third-Party Audits 3.4.1 Sel f- As sessments In the area of internal audits and self-assessments, the team reviewed the methodology that FTI had adopted to implement the provisions of Appendix B to 10 CFR Part 50 and other industry guidance.

The team found that FTI's internal auditing was accomp', shed using Procedure 1719-21, " Quality Assurance Audits of Ir.ternal Activities," Revision 10, May 1996. This procedure requires in-house auditing of EC functions, that is, safety-related or ASME Code Sections III and XI, activities, on at least a once-per-calendar-year basis. In the past two years, internal QA audits ;'

FTI's NDE/EC testing group were performed on two different occasions, as discussed in Framatome/BWNT Report 94-08, August 1994, and 95-09, July 1995.

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l A review of these reports showed that FTI generally took appropriate ,

corrective action to respond to identified problems and to preclude their  !

recurrence. 1 For example, one of four remote data acquisition units (RDAUs) identified in a Crystal River EC examination report was misidentified by FTI's EC technician.

As an immediate corrective action, a memorandum that stressed the importance of entering correct serial numbers in data summaries was distributed to all EC technicians. To preclude similar problems, FTI now requires two-party verification of all entries, and this verification is stressed in current FTI activity control documents. The team also noted that supplemental training for EC Level IIA and Level III analysts was to be performed on at least an annual basis. For some of the analysts, no evidence of this required training was found for 1994. As an immediate corrective action in December 1995, FTI routinely scheduled supplemental training for every December-January time period. To preclude similar problems, FTI scheduled its subsequent training within 12-to-15 month intervals, as recommended in EPRI NP-6201, Appendix G.

The team found that all issues were satisfactorily dispositioned. The team concluded that FTI's self-assessment program was adequate, and the team noted that FTI's QA/ internal audits were acceptable and appeared to meet the guidance in EPRI NP-6201, Section 2.

3.4.2 Third-Party Audits The NRC inspection team reviewed selected third-party audits of the FTI organization to assess the scope of the audits and to review any identified I weaknesses. The inspection team's review of audit reports of FTI's program found that some third-party assessments of FTI's EC testing program functions are periodically performed by the Nuclear Procurement Issues Committee (NVPIC)  !

and nuclear power plant utilities.  !

1 The team reviewed two recent NUPIC audits of FTI's NDE group that were made in 1 July 1994 and June 1996. During its review of these audits, the team noted that the audit results were generally satisfactorily, with a few exceptions. (

For example, NUPIC noted some weakness in the areas of " starting the clock" for Level III recertification and the calibration of one RDAU, which was used on a Davis-Besse S/G inspection. The team also reviewed a limited-scope audit performed by Baltimore Gas & Electric Company (BG&E) Report in May 1995. The BG&E audit report stated that the implementing procedures and activities of FTI, (formerly BWNT), were appropriately performed and complied with FTI's  :

QAPM. The BG&E report also indicated that FTI's QA Program was adequately implemented and effective in the areas evaluated. The team's review concluded that FTI adequately resolved any findings and performed appropriate corrective action. No concerns were identified in this area.

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3.5 Eddy Current Software 3.5.1 Receipt J

4 The team assessed FTI's process relating to the receipt of the Eddynet software3 . It appeared that the supplier, Zetec, continues to update their Eddynet 95 software versions after customer receipt in response to customer requests and to improve man-machine interface characteristics of the software.

As a result, new versions, version updates, and prototypes have been received by FTI. The team found that Zetec typically supplied FTI with new versions of its software on optical disks and FTI returned old versions to Zetec upon

, receipt of new versions. The team found that the optical disk typically

contained " read me" files which described the changes or additions that were made in the new version. Upon receiving the optical disk from Zetec, FTI stated that it performs a check-out of the acquisition and analysis software and this process was reviewed in detail by the team.

4 FTI documents receipt of new Zetec software versions in its quality control

, inspection reports (QCIRs). Each QCIR is assigned a unique QCIR number, which <

is maintained in the FTI quality assurance system. Interviews with FTI personnel revealed that there is no governing procedure for performing this l function. The staff reviewed two QCIRs: QCIR 96-00339 (Document 1237552A-00) 4 and QCIR 96-00340 (Document 1222845A-2), both dated April 1996, under Calvert

Cliffs (BG&E) Contract Number 1010441. QCIR 96-00339 documented completion of i check out activities for Eddynet acquisition software, Zetec Eddynet 95

, Software Version 2.0, Patch E95-2.1. QCIR 96-00340 documented completion af

Eddynet 95 System Check-out Procedure, Zetec Eddynet 95 Software Version 2.0, Patch E95-2.1. The team saw that the Eddynet analysis program that FTI used I for its check out utilized a set of QA-controlled test data, which had been i verified to produce known analysis results. The procedure provided unambiguous guidance for setting up the tests and test data and for protecting the original set of test data. The procedure required a verification that the software analysis results agreed with the baseline results. Additionally, the functional testing verified the correct transmission of data between a work j station and a server. These functions were verified by the test personnel and i FTI management.

4 The inspectors found that although FTI's NDE manager expected his staff to validate new or upgraded Eddynet software using an attribute sheet which

contained special data and outlined confirmatory analyses as described above, i

FTI had not established any procedure to require the validation process to be completed in a consistent, repeatable manner. The team concluded that this process appeared to be satisfactory in practice, except FTI had not required 4

3 FTI's Approved Supplier List showed that Zetec is an approved Appendix B supplier for NDE equipment and as a source of NDE personnel for on-

! site EC testing but does not list Eddynet. Appendix B to 10 CFR Part 50 is 2

not imposed by FTI for procurement of Eddynet nor will Zetec accept Appendix B q for Eddynet. The Eddynet 95 software is a commercially available product.

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s. .s the process to be completed by instruction or procedure. As a result, the team concluded that there was no assurance that future versions or version updates will be validated using the existing validation process.

The team was concerned that FTI had not established written controls for the Zetec software receipt inspection activities considering the importance of the S/G tube eddy current test activities utilizing this software. The team notes that this concern would have been identified as a nonconformance had Appendix B been imposed by FTI; however, Zetec does not accept Appendix B to 10 CFR Part 50 for its Eddynet. Consequently, the receipt of Eddynet would be as a commercial item by FTI.

3.5.2 New Version Releases FTI indicated that in addition to its internal check out of new Eddynet software versions, Zetec validates all new version releases, version update releases, and prototype releases of the Eddynet software product.

Specifically, FTI referenced three Zetec work instructions that have been developed for the software validation of new versions, version updates, and prototypes. The inspectors reviewed the following three Zetec work instructions: (1) New Version Product Disk Validation Work Instruction, dated June 29, 1994; (2) Version Update Disk Validation, dated September 19, 1994; and (3) Prototype Disk Validation, dated September 1994. The team's discussions with FTI staff indicated that Zetec implemented these work l instructions to ensure that new version releases of the Eddynet software would perform correctly by conducting check outs and tests of new software products.

The inspectors review of a sample of these version check out procedures indicated that the procedures appear comprehensive and demonstrates that Zetec performs software validation before releasing Eddynet software products.

3.5.3 Software Chance Reauests The inspectors reviewed the process for reporting and resolving Eddynet software deficiencies. FTI indicated that there is no formal mechanism to internally report and track software problems or recommended changes.

However, FTI indicated that Zetec developed a Software Change Request (SCR) form for customers to report apparent problems or to suggest recommended changes and enhancements to the Eddynet software. The inspectors reviewed the SCRs completed by FTI.

The inspectors raised a question about how FTI tracked the disposition of each SCR. Specifically, upon reviewing the SCRs, the inspectors noted that the SCRs do not have unique identifiers to facilitate tracking and closure. In addition, FTI did not have any information on file as to the status of the l SCR. FTI indicated that Zetec assigns an SCR number to each SCR when it i receives the SCR from the customer. Zetec classifies each SCR as an error or a request for change and makes the final determination as to how to process i the SCR. Typically, enhancements or corrections to the Eddynet software are listed in an Eddynet bulletin that is sent to customers by Zetec when new versions of the software are distributed. In addition, tracking disposition of the SCRs is performed by the Eddynet Users Group. This group meets semiannually to assign priorities to SCRs from all customers. The team 9

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recommended to FTI that it consider establishing a formal mechanism to internally report and track software problems or recommended chang a that it identifies or is transmitted to Zetec.

3.5.4 Audits of Zetec's Software Development Process The team reviewed the FTI supplier audit records of Zetec, focusing on whether FTI's supplier audit documentation reflected a critique of Zetec's Eddynet software development process that would provide an adequate confidence level for FTI to continue procuring Zetec's software. The team found that FTI's Approved Supplier List showed that Zetec is an approved Appendix B supplier for NDE equipment and as a source of NDE personnel for on-site EC testing.

FTI staff stated that it doe.; not impose Appendix B to 10 CFR Part 50 for procurement of Eddynet 95 software from Zetec because Zetec will not accept the Appendix B requirement for Eddynet because Zetec's Eddynet software is a J

commercially available product.

The team assessed FTI's basis for procurement and use of the software. FTI provided the team with a copy of its Administrative Procedure No. 1719-22,

" Quality Assurance Audits of FTI Suppliers," May 1, 1996, and two audit report, of Zetec for 1991 and 1994, which were conducted by others.

Administrative Procedure 1719-22 contained requirements for evaluating and auditing quality assurance programs of FTI suppliers. The 1994 audit of Zetec was performed by the Nuclear Industry Assessment Committee (NIAC), and the lead NIAC member was Asea Brown Boveri-Combustion Engineering (ABB-CE). The stated purpose of the inspection was to evaluate the effectiveness of implementation and the adequacy of the Zetec QA program to the applicable criteria of 10 CFR Part 50, Appendix B. Software quality assurance processes were included in the scope of the audit and were found in the NIAC audit checklist.

As a result of the audit, ABB-CE provided FTI with a Supplier Audit Summary Report 94-013, dated April 22, 1994, as well as the NIAC Audit Checklist.

ABB-CE concluded that Zetec was effectively implementing the Zetec QA program in accordance with Zetec's QAM, Z-QA, Revision 12, and related procedures.

The supplier audit report stated that Zetec is approved to supply quality class 1 (safety-related) NDE personnel, equipment, services, calibration of equipment, manufacture of EC test standards and EC testing related computer software [Eddynet]. By memorandum dated August 8, 1994, the FTI Manager for QA audits documented review ind acceptance of the ABB-CE audit. Specifically, the memorandum approved NDE personnel and NDE equipment, services, equipment calibration and manufacture of EC test standards and EC testing related computer software.

The team reviewed the ABB-CE audit report and observed that no deficiencies were noted in the software area checklist and that all audit inspection attributes that were in the software area checklist were marked

" satisfactory." It appeared to the team that the audit report lacked sufficient detail to make an assessment of the adequacy of Zetec's establishment and implementation of its software controls. Instead, the audit report and checklist only indicated that, Zetec had a software development procedure, Zetec staff performed a validation for version 24, and that the 10

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NIAC auditors reviewed three Zetec SCNs and a Zetec " bug" list. Therefore, the team did not believe that narrative or adequate objective evidence existed in the checklist or audit report package for one to reach the conclusion stated in the NIAC Audit Report. For example, the s9ftware area checklist section made the following statement:

PDP-1, Revision 9, Software Product Development Procedure, is Zetec's procedure for design and development of EC analysis and acquisition software; Final validation of Eddynet Version 24 was performed in January 1994; Reviewed Software Change Notice (SCN) numbers 404, 407 and 372. SCNs were in accordance with PDP-1, Revision 9; Reviewed Eddynet Version 24 known bug list for dispositions."

The inspectors also reviewed the December 1991 audit of Zetec performed by FTI, which focused on the qualification of Zetec as a supplier of personnel for EC testing and analysis and calibration services. Software development and quality assurance processes were not included in the scope of this audit.

Therefore, the 1991 audit of Zetec was not applicable to its software product.

Subsequently, the NRC inspection team conducted an inspection at the Zetec facility on July 15 through 18, 1996, and did not reach the same conclusions as did the NIAC audit report regarding software. The NRC inspectors at Zetec identified some concerns in Zetec's software program. For example, Zetec did not establish a documented software requirement specification for its Eddynet software, nor had it performed a formal verification of its software to confirm that a given phase of the software development life cycle fulfilled the requirements imposed by the previous phase. Although software verification attributes were included in the NIAC checklist for verification, the audit assessment checklist did not identify that Zetec's software verification was not performed by Zetec. Based on the above information, the team concluded that FTI's NIAC audit report supporting the adequacy of Zetec's Eddynet did not appear to provide adequate specificity for a FTI's confidence level as a stand-alone document.

On the basis of the above discussion and circumstance, the team concluded that adequate objective evidence was not presented in the NIAC 1994 Audit Report on Zetec to conclude that Zetec's control of its software process was effectively impleniented. FTI indicated to the team that the next Zetec evaluation is scheduled for December 1996, and the next audit is scheduled for March 1997.

Although some concern is noted by the team for this area, no nonconformances were identified.

3.5.5 Review of Software Purchase Orders The staff reviewed the following four purchase orders (P0s) for materials and/or services from Zetec: P0 32640, South Texas Project, October 6, 1995, P0 38231, Crystal River, April 26, 1996, P0 42533, Salem, May 28, 1996, and P0 42800, South Texas Project-Unit 1, June 12, 1996. Although Zetec was audited as an Appendix B supplier and listed in the FTI approved supplier list, FTI indicated that the Eddynet software is procured as non-safety grade software 11

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and is not dedicated as a basic component. This was substantiated by the team by review of the above-listed P0s, which were placed as orders for non-safety-grade equipment.

In its review of the FTI Supplemental Checklist for Software Development,Section IV, " Procurement," (Figure 5), the team found that Zetec EC equipment and calibration standards were purchased on April 10, 1996, under P0 41215 and P0 34868; the item descriptions are MIZ-30-4, VH-4606, P-006. The supplier evaluation audit was performed in March 1994 and the acceptance documents were 56496 and 55929. No concerns were identified in this area.

3.6 Entrance and Exit Meetinas .

In the entrance meeting on July 9, 1996, the NRC team discussed the scope of the inspection, outlined the areas to be inspected, and established FTI staff l contacts for interaction. In the exit meeting on July 12, 1996, the team discussed its findings and concerns.

PERSONS CONTACTED Lyle Bohn Executive VP, Nuclear Services Charles England Vice President, Outage Services Dick Gill Director, Quality Assurance Emily Mayhew Manager, Quality Assurance Audits Todd Richards Manager, NDE Technology Nicholas Simile Supervisor, Quality Control ,

Scott Wilson Manager, S/G Service Products '

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