ML20128N338
| ML20128N338 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/29/1985 |
| From: | Wooldridge R WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#285-226 OL, NUDOCS 8506030240 | |
| Download: ML20128N338 (36) | |
Text
dQ(o quAnocommo**P WORSHAM. FonsvTHE, SAMPELs 6e WOOLDRIDGE tw.mtv.r,vt .umo..o toos ..v.m tow..
6 m o ..u..s. DALLAS.Tinxas 75eos see .......
":Ml." * *.".'3". m e..o.cw.n....>..
- ' * "" *0 . .
"".*. "."".~.'.:g" o s g,,.g;,,,
55$5$*35355".. ""TS5ff"* * "
'" "'* !. r'.T" 55.5E'5"55
. * '85 MY 30 All:55 Y, '.'",'o". * :. " " ,*,". . . . . . . .
".$ U "'e".I.'E",'s" May 29,1985 0FF!CE OF SEQ e 7".,'s*.".".,v",.',.*.'"'"- 00CafJiHG & SEPW.
c.c.u . BRANCH Peter B. Bloch, Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Walter H. Jordan Administrative Judge 881 W. Outer Drive Oak Ridge, Tennessee 3f 830 Dr. Kenneth A. McCollom Administrative Judge Dean, Division of Engineering, Architecture and Technology Oklahoma State University '.
Stillwater, Oklahoma 74078 4i Re In the Matter of Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 and 2)
Docket Nos. 50-445-1 and 50-446-1 Supplementation of Applicants' Response to CASE's Request for Production
Dear Administrative Judges:
This is to notify you and all parties to the above dockets that Applicants have identified a document which we believe to be within the scope of item 10 of CASE's Interrogatories and Requests to Produce dated July 7,1980, as clarlfled on August 4,1980. Applicants submitted their response to item 10 on September 8, 1980 and supplemented their response by letters dated December 22,1980, March 5,1982, and April 19, 1982. The document, a copy of which is enclosed with this letter, is a report prepared in May of 1978 by Management Analysis Company (MAC) following a management review and audit of the quality assurance program of the Comanche Peak Project.
O) 8506030240 050529 PDR g
ADOCK 05000445 PDR
(}h .
Administrative Judges May 29,1985 Page Two Recently, in gathering data for a prudence audit being performed for TUEC, a search was made by TUGCO personnel of inactive and closed corporate files located in TUGCO's Dallas office. In the course of such search, the enclosed report was found. A memorandum dated July 11, 1978, which details TUGCO resolutions to the findings and recommendations made by MAC, is also enclosed.
TUGCO management is evaluating the failure to produce this document at an earlier time and will advise the Board and parties of the results of this evaluation in the near future.
Respectfully submitted, Robert A. Wooldridge Counsel for Applicants RAW /kiw Enclosures cc: Service List N
G l
l l
J
, . I [,, y,,,
rTEX).s UTILITIES GENERATING COlh .uNY OFFICE MEMOR ANDUM l gELAUD_
To$ Perry Ge RN a d
- DaHw T.... uly 11 1o72
- n. , ,
O' ' Subjen Manacement Oualf tv Assurance Audit RECETVED JUL 12197' P. G. BRITTAIN Attached are our resolutions to the findings and reconinendations madEMETED by Management Analysis Company as a result of their audit in May. USNRc Our analysis of the audit results has been discussed in general terms with John Jackson, and we see no need to respond fonnally to tg gig C bfr.tb,"g ;l-l^ '
/ :.u Ncq R.g. Gary /
_..._ee.. .. e._ . _ . . _ . _- o . _.._..e .. -e. e 4
r bl
/,,
/
- e O .
- ee-e ee emeee amm *ae * ** eemme aan esp e n e .e . e.- e mueo.ee. w .....,,e-. . . . .
FINDINGS (APPENDIX A)
- 1. Finding Summary: Our QA Plan and Procedures do not reflect current authority delegations to BAR and to G4H.
Response: At the time of the audit we were operating under properly approved deviations. These deviations were incorporated into a pemanent QA Plan Manual revision on July 1,1978.
- 2. Finding Summary: The current practice of after-the-fact design change review provides significant risk of error and is in noncompliance with 10 CFR 50 Appendix B.
Response: We disagree on both counts. The G4H Resident Engineer has exercised extremely good judgment in implementing the authority delegated to him. Of the approximately 2000 changes /devia-tions/ clarifications issued under the system, we are aware of none that have provided exposure to a significant risk of error. To' provide greater visibility of the design change function, a system was implemented on May 25, 1978 that provides an analysts of all chan
__..._ __-..-This.ges and pensits.
systest continuing is current evaluation for ongoing of at activities thethe field present efforts.
time and will be completed for past activities on or before July 15, 1978. Our belief that we are in fact in compliance with 10 CFR 50, Appendix E is. supported by internal audits by TUGC0 QA personnel and fndependent audits by two separate NRC Inspectors. We propose to Teave the design change system as is.
- 1. Finding Sununary: TUGC0 QA does. not review all procurement doctments and changes thereto prior to release.
$[ Response: We disagree that this is a requirement. A separate QA t requirement section, approved by TUGC0 QA, is included with each purchase order and is. applicable to all supplements, Changes to these requirements are authorized only by Quality Osurance.
- 4. Finding Sunnary- The current array of QA manuals and procedures is comp 1ex and difffcult to maintain, Response: We agree. The new. Plan manuai was issued July 1,1978.
The corporate QA Progran Manual is currently under study with the goal of streamlining it.
- 5. Finding Surinary: Records do not reflect the as-poured configuration clearly.
Response: Configuration has always been made visible to inspectors,
4 and steps have been takett to improve the visibility for the record.
O 6. Finding Summary: Markings for in-service NDE inspections were not always distinct.
Response: We agree that_such markings should be legible. QC will inspect special process ISI markings prior to turnover.
7 ~. Finding Summary: We are using the DC/DOA (design change) program to i
bypass the nonconforisance system.
l Response: This is not true. If construction identifies and corrects a. defect or obtains an approved engineering change prior to-i QC inspection,. no NCR. is, required.
! 8. Finding Summary: The records storage facility does not have internal fire protectiore during off-duty hours. ,
Resoonse: An inert gas fire protectiort system is ort order by TUSI.
Target date for installation is. August I.,1978.
~i
- 9. Finding Summary: Approximately 245 of audits scheduled by Dallas staff have not been conducted. Audits by TUGCG and,84R. should be combined frt one overali effort.
Response: Our audit scheduie is constantly being revisst to reflect changing manufacturing status and to allow us to use audits to investi arise. gate Weproblem areas believe we cartofdefend the most our immediate concern audit program, as they and are leaving-it as it is,j G
.,,,,---ye-a e-~
. . P 3
{ *
,. . b .
1
, CBSERVATIONS AND REC (MMENDATIONS- (APPEN0!X 8)
O I Ornanization Recomu mdation: Separate inspection from Quality Engineering
- (p' ann'ng) -
Re_sponse: We had begun work on this before the audit. Our product
- assurance group has taken responsibility for Quality Engineering.
Recommendation: Re-evaluate the charter of the Quality Surveillance Committee i
R n : We have decided to discontinue the Quality Survet11ance 4
. Instead, TUGCQ QA Manager wili issue a. report quarterly to keep top management apprised of the status of QA matters including quality trends. The first such report will be issued by August 15, 1978.
I Recommendetion: Hire more ssasonse inspectors. Hire any future -
engineers from outside the company uitir experience in nuclear plant construction.
i
- Resonnse- We are on the lookoet for weli qualffied. personnel and cont nue ts review applicants frour outside the company. The 1 relatively young inspectors. wil-1 be strengthened best and quickest 1 by taking from them the responsibility for inspection pianning and providing them witir adequate, but concise instructions and checklists. This has beert done and is effective.
i II Quality Assurance Program l
- Recommendation
- Revamp our present QA manual system.
Response: We agree. TUGC0 QA issued a. revised QA Manual on July 1, 1978.
]
Coinfon: Obtaining our ASME Code stamp will be difficult if all the work s done by others.
Resconse: We know f t wili be difficuie, but it can be done. The i report does not accurately record our stated. reason for obtaining an N-stamp.
III Desian Control Reconnendation: Abandon our present system of expediting field j .
-,--r,, _--,-o,- , -- - . - - - , _ . - , . _ _
v . v~
e changes.
- O R.t n : We <it ie ve it => <= <=-
IV Procurement Document Control Recommendation: All proc'urement documents should be reviewed by QA.
Response: We disagree for reasons stated on Page I.
V Instructions Reconnendation: Streamline inspection planning and checklist preparation.
Response: We agree, and have been active in this effort since January.
Reconnendation: Discontinue mapping individual standard imbeds.
- - - .- - Response: Mapping has been discontinued, but we have retained a --" - - - -
reasonable degree of traceability on embedded items.
Recommendationt Combine construction and-QA procedures.
Response: Sfnce January we have been doing this for new procedures and when revising old procedures.
Reconnendtion: Otscontinue requiring BAR Houston approval of prococures.
Response: All procedures except those involving ASME Code work are now approved at the site.
Observation: All applicable DC/D0A's are not included in supporting documentation.
Response: Refor to Page 1, Appendix A, Iteur 5.
Recommendation: Estabitsh a fomal site procedure for planning-construct < on work.
Response: This planning is. being done. We don't intend to create' a fomal procedure for it.
O
. amm. . ease 6** man e e === emmes.se e e an e a. . e.o . . am.no e, m . e emme , *
- es e e ano ao - now e a . . * *
. . p -
1 VI Document Control O Observation: The ARMS system should be backed up by a manual system I
, stated verta11y in exit management interview).
l Ressonse: The auditors'. lack of confidence in ARMS was the result of insufficient familiarization with the system on their part. l VII Control of Purchased Material. touissent. and Services Observation: The @ plan is not up to date in this area.
l
[ggglg: Manual revision was completed on July 1. i i
t
- . Souri:e inspectors. (TUE0 Q4) appear to be at the mercy l e supplier in determining what changes have base incorporated. ;
- This is not true. Ide (TUE0 04) prepare our own l c sts after searching the appropriate files. Ide agree with the ,
auditors' (verbal) consents that this method places an additional ...
~-'" burden on ourselves; however, the original (and, logical) approach of depending upon San to prepare the checklists did not work.
VIII Identification and Control o'f Materiefs. Parts. and Commonents i No observations IX Saecial Processes Recon nndation: The use of Iridium 192 should be replaced by x. ray I for a' shop welds and for field welds where practicai.
Resoonse: Brown & Root is studying this recommendation., and is !
committed to have e report for TUE0/TU5I by July 15. :
t Reconnendation: Reduce the number of individuais reviewing, ,
redtographs and establish the policy that Code-acceptable i indications be recorded. but not repaired. l l Resnonse: This had been accomplished prior to the audit, but !
) apparently the auditor talked with someone who wasn't aware of it. l 3
d Recomendation: Clarify the responsibility of the NOE supervisor i l- re' at we to code work. '
l O \
l
- . .m ,
s...
The auditors were confused in C;is area. Our only Level site is in civil work, not ASIE Sec. III Div. I wort.
O y
Included here was a re-statement of observations covered elsewhere in the report.
XI Test Control Recommendation: Existing nonconformance control systems should be uses dur<ng startup.
R : The new QA Manuai, with input from TUGC0 Operations, will ss. nonconformance contrei systems.
XII Gentrol of Measurint and Test tenfanent 1 : Equipment should not be recalibrated on the due s not.been used.
- The recommendation has been adopted for items whose ce ra ion is not subject to change while not in use.
Implementation date was July 1. -
XIII Insoection. Test and Goeratine Status No observations 5i XIV Wandline. Sternes and Shionine Recensendation: Exterior storage a protection practices should be reviewed.
Resannse: We had previously reviewed the storage practices an'k have ,
ne reason to bef feve that a problan exists. Various NRC inspectors have else inspected this activity However,, Westinghouse is l reviewing this,, and their metallurgist will report by July 15.
XV Control of Nonconformances (
Observation: This is a restatement of concern over nonconformance contre' .
Resoonse: W reject the inference t' hat problems are circumvented rather than corrected at CP5ts.
o . o i
.s..o
. XVI Corrective Action No specific findings.
XVII Records Recommendation: This section restated the need for fire protection system.
Response: The inert gas system will be installed by August 1,1978.
XVIIIAudits ,
Rectussendation: The audit (Deilas) and survelliance (site) acte.vities, should be combined.
Respontr: We intend to leave our audit progan separate from sf te survet' ance.
.... . .. .. -. _ . . . . . . ----- - --- -- = --- - - ~ ~ ~ ~ -
b e
- i b) a D
0
...g '
1".'t"o*"la'te.'*NTK an'aconse sens O
May 17,1978 MAC-JPJ-471 Uu $.Sc"
$;,${8'i***'" '85 liAY 30 All ;55 Texas Utilities Generating Company 200T Bryan Tower errer r n u .
Dallas TX 75201 hocoggEh <
Dear Mr. Brittain:
Enclosed is the report of the Management Quaitty Assurance Audit conducted for Texas Utilities Generating Company.
The audit disclosed that, in general, the Quality Assurance activities were effective, that there is good team spirit between TUGC0/TUSI personnel and the Architect / Engineer and the Constructor. The audit resulted in the identification of some failures tar comply with regulatory requirements, the Quality Assurance Pian or the PSAR. These deficiencies are identified in an Audit Report as Appendix A. The audit aiso identified areas of potenttaffy improved practice. These are identified as Observations and Reconnendations and Appendix 5 to this letter. As you know, MAC participated in art audit of the Comanche Peak site and significant improvement is noted since that audit.
Management Analysis Company received full cooperation from ali personnel con-
'l tacted during the audit, TUGC0/TUSI, Brown & Root, and Gibbs & Hill. The6t i general openness of personnel and their frank discussion not only enhanced the conduct of the audit, but exemplifies an attitude conducive to correctiert of any deficiencies.
We appreciate the opportunity to be of service to 1"exas Utilities Generating Company and Texas Utilities Services, Inc. and hope to do so irr the future.
If there are any connents or questions regarding this work, please contact Mr. J. M. Norris or me at (714) 452-1391. -
/
< John P. Jac'kson Principal Partner JPJ:bew
, Enclosures! Appendix A Appendix B
~ .
l
. . o p i I -
i t '
APPEN0!X A TEXAE UTILITIES. GENERATIM COMPANY l AUDIT REPORT .
l
( l
[
1 t
i e
I.
.g .
l
- I L
,e 6)
, ., it ,6 i I '
t i
i' e
i I r i
I f ?
I r r
i 1
i r
I
n AUDIT REPORT
Subject:
Audit of Texas Utilities Generating Company, Dallas Offices and Comanche Peak Steam Electric Station Construction Site Date of Audit: May 1-12,19[8 -
Audit Scope: A management audit was conducted of the Quality Assurance Program of Texas Utilities Generating Company during the weeks of May I and May 8 1978. The purpose of the audit was to.detensine the adequacy of the Quality Assurance Program es related to Nuclear Regulatory Commission require-monts and the effectiveness of implementation ta1neet program requirements and authority delegations. Activities were audited at bothe the TUGC0 offices in Dallas and at the I Comanche Peak construction site. Activities of the Architect /
Engineer and Constructor were audited only at the construction site. The scope of the audit included connitments made in the PSAR.; the Corporate Quat"ty Assurance Mr.nuai, the Comanche Peak Quality Assurance Pian,, the Project Procedures Manual and the 3rown & Root Quality Assurance Manuals and Procedures relatet. to the Comanche Peak site.
Auditors: Dallas office,May T-3.,19/8
.!d P. Jackson, MAC Audit Tear Leader J. M. Norris , MAC Auditor 1
Comanche Peak Construction Site, May 4. & f, May 812.,1978 J. P. ,1acksoti.,16C Audit Team Leader J. M. Norris, Mi,C Auditor J. A. Hendron,, AAC Auditor (May 8-i2 only)
Personnel NAME COMPANT TITI.E fn"a*rv' t O. N. Chapman T1)GC0 QA Manager, *-1-2 R. G. Tolson TU0CO . Mgr, Sita Surveillance. *-1-2 b R. Y. Fleck TUCCD/Galt Civ. Inspec. Supv., *-1 J. V. Hawkins TUSC0/GAH Pred. AssJrance (QA), *-1
-A
TUGC0 AUDIT REPORT .
Personnel MAME COMPANY TITLE gatag:4;g
,e J. B. George TuSI Pros. Gener.i Mgr., *-i-2
! J. T. Marrit TUSI Resident Manager, *-1 E. G. Gibson- TUSI Project Engineer, *-1-2
, E. J. Murray TUSI Engineering Supv., *-1 J J. Moorhead GAN Resident Engineer, *-1-2 B. C. Scott B&R Site QA Manager. *-1 J. P Clarke B&R Site QC Manager *-1 R'. Mann BAR QA Records Coordinator,,
- R. @. Kirkland BAR Prof. General Mgr,. *-1 l ,
tt. D'. Douglas BAR Project Manager,, *-1
- D. C. Frankus BAR Asst. Project Mgr. *-1 I P. Foscolo Prof. Chief Engineer, *-T h
BAR L. Hancock B&R Mat'I Procurement, Con-struction Branch, *-I A. Boren TUGC0 Vendor Compliance,.
- A. Vegs , TUGCQ QA Central Staff Function. *-ic
,, C. Beggs TUGCO' Systems Compliance,. *-i-Z R'. Gary TUGCQ V.P. Operations, *-1 L. Ffker TUSI V.P'. Design & Procurement,*-f P. Brittain TUGCO/TUSI President,.1
- Interview I Pre-audit meeting-Z Post audit meeting Audit Method: The audit was conducted through a series of interviews with responsible management and supervision and examination of quality Assurance manuais, procedures, records and work operations both at the Dellas headquarters of Texas Utilities Generating Company and Texas Utilities Services, Incorporated and at the Comanche Peak construction site.
Q Sumary: The audit disclosed that recent changes. in authority dels-gations had been generally we1T accepted and that morale fiiEii!
TUGC0 AUDIT REPORT
}Q 1
Sunmary (Cont'd): and team spirit were good. However, the changes had not yet been fonralized in revisions to the PSAR and the l Comanche Peak Quality Assurance Plan. The audit also i disciosed that present practices in the control of design
, changes and of certain nonconformances do not provide the I requisite level of review by the original designer. In other instances it was evident that design changes were being used in Tieu of nonconformance reports. Except for the areas noted herein and below,. there was generally good adherence to existing procedures.
t Findings: T. The current activities of TUGC0 Quality Assurance per-sonnet are not consistent with the authority delegations to: Brown & Root and to Gibbs & Hill as defined in the PSAR and Conanche Peak Quality Assurance Plan.
1 SimilarTy,, the Qua'Tity Assurance Pian and Procedures are not consistant with current a'nd pTanned revisions in authorfty delegations' to the Architect / Engineer and the .
Constructor,. and is not complete in addressing all eighteen criterie of 10CFRSO Appendix B. The lack of a weTT fdentified plan of reorganization and responsibility causes uncertainty in carrying out some activities..
There needs to be a plan for revising the Quality Assbr-ance Programt such a plan should include the establishment
.. of art architecture of procedures to show how other TUSU TUGCG and contractor manuais inter-relate with the QuaTity Assurance Manuar. The TUGC0 QA Manager should establish a schedule and assign responsibilities for completion of the necessary procedures. The-schedule should be suppie-mented with a. management effort to monitor adherence to the plan and achievement of the schedule.
h Z. The current site DC DDA system of after the fact coordi-
~
nation of design changes with the original designer l
,c----y- - - - - - - - r---,--e- w - v- --- er-- , - --- --g-- -,ie- - - - - - - - - - --yw- --m
{.
Findings: provides a. s.ignificant risk of design error and does (ontd) not meet the requimments of 10CFR50 Appendix B, nor g of ANSI N45.2.IT, " Quality Assurance Requirements for i the Design of Nuclear Power Plants".
f A systent for expediting and documenting Gibbs & Hill home office approvals. should be established using telephone, telecopier or telex as. a means of speeding
, connunicatiorr.
- 2. The Comanche Peak Quality Assurance Plan does. not provide g for a Quality Assurance review of procurement documents E
and changes thereto prior to- purchase order placemept.,
, except for site originated procurements. Such a review is identiffed in 10CFR50 Appendix B., Criterfon IV and is a requirement of ANSI N45.2.13. It should be requir'ed l on aTT safety related procurements.
- 4. The- current conbination of Chapter-17 of the PSAR, the TUGC0 Corporate Quality Assurance ManuaT, the Comanche Peak Quality Assurance' Plan,, Profect Procedures and Browrt & Root Manuals. and Procedures pmvides a complex r array of procedures which is difficult to maintain current and consistent.
l l
g . S. The current system of providing inspection instructions or checkTists to inspectors is too generic, placing an
-[ undue burderr ort the inspector in attempting to determine l applicable drawings and. specifications and applicable )
f revisions thereto. A review of records. of concrete pours incidates that configuration reflecting the as-poured condition is. not clearly defined. Applicable DC DDAs are not 'noted in inspection documentatiort.
Configuration needs to be clearly identified to
- inspectors on a> current basis, including all applicable
,----,-,--,--,,-.m,...~4.- --, ., . , , , , , . , - - , , - - - - - - , , - , - . - . - .-.~+.-m-, .-----.-m. - .-- . - .-__ - - - _ _ _
TUGCU AUDIT REPORT , . .
Findings: DC 00As and completed documentation must reflect the (Cont'd) status of the appTicabTe changes.
- 6. Special, processing markings for Tatar in-service inspections.are carelessly appifed. The circle and f arrow used for such marking is sometimes incomplete and not recognizable-for its intended purpose. In one instance only a: portion of the circle resembling th8e Tetter "C" was. discernible. FaiTure to properly marie these Tocators now wtIT cause delay and. possibTe I error when: in-service inspections are made in highTy irradiatet areas.
7 Disposition of nonconfonning items does not always f achieve the requisite review by appropriately qualified design personneT. A procedure, Timited to. defects in g concrete,. was recentTy issued.which bypasses. the estab-Ifshed: nonconfornance control system. and, thus,. vioTates reguTatory requirements ire this regard. In other instances,. the DC DOK progrant has been used to bypass g the nonconfonnance reporting systent. The nonconformance-R controT systent should be the meansNor maintaining in-spector integrity, identifying problem areas and provide f a driving force for their correction.
- 8. The records storage facility does not currentTy have any
{ ,
means of internat fire protectiort during hours it is.
. unmanned',. although it is understood some method is pTanned. Quaifty Assurance records, such as personnel g quaTifications,. are not maintained in the Records Center,,
I but are maintained in fireproof file cabinets in a trailer under the cognizance of Brown & Root training coordinator.
- 9. Approximately twenty-four percent of Central Staff audits f have not been conducted as scheduTad. Combining Central i Staff audits,. site audits and site survei11ance activities
TUGC0 AUDIT REPORT )
l .
Findings: by TUGC0 and by Brown & Root into a single, cohesive (Cont'd) progra wuTd provide improved visibility to the overall i audit and survef1Tance effort and permit evaluation and I ajustment to the audit schedule to attainable and yet effective frequencies.
e m
O i .
I 1
h
[
'a e
l l
O
. l r i
-O e
t APPENDIX B
! TEXA5IRILITIES GENERATING COMPANY l
- OBSERVATIONS AND RECOMENDATIONS a
f
.. '5 t
D e
O e
h L_ _
j-
- TUGC0 AUDIT OBSERVATIONS AND RECOMENDATIONS 10 I. OaGAuruT10.
. A. General ~
TUGC0 Quality Assurance has undergone considerable reorganization in the
- j. past year. The general thrust of this effort has been the assumption of I i
greater direct involvement in the management and supervision of the Comanche Peak Quality Assurance Program. It is to be noted that important shifts in responsi5ility were- being made at the time of MAC's review.
As e part of this assessment, MAC evaluated the reactions of key managers, i
supervisors and inspectors ter the overal_T changes that have taken piace to date -
y.
t It was. generaT1y observed that those interviewed thought that with few l exceptions the changes were for the better. There appeared to be a team effort orr the part of QA and Construction with excellent TUST executive management and project management support of the QA progrant. There was no noticeabTe problem witir organizational prejudice brought about by the l organizationai intersnixing of iUSr,. Browrr & Root or Gibbs. s Hill work l forces and supervisfort.
l B. Organization 1 I
During the course of the audit MAC discussed the value of a revised- l t
organizational structure with the TUGC0 Quality Assurance Manager and the Manager Site Surveillance.
\
.It is reconsnended that TUGCG adopt art organizational realignment of activities as set fortir irr Exhibit I, whereby Quaif ty Engineering and Inspection report to the Site QA Supervisor as two separate sub-organizational entities with responsibilities as defined in Exhibit T.
Such an organization wili better supplement the existing Construction l organization and will permit better organization for handTing day-to-day l site problems as well as implementing recommendations of this report.
This is particularly so in the area of inspection planning.
l M
r - - - --e y.y-----g 9 y. g --.--,--,-,9,,,, , - . -
, , , +c-.-.w -, , _-,, . . . * , m,-,.,,4,, - - ,, , , ---.,,,,,.*,,...,,-,p.*w,w, y, - . .w.,w-. , -p-
M OBSERVATIONS & RECOMMENDATIONS ,
C. Quality Surveillance Comittee Ali minutes of meetings of the QSC since its inception were reviewed. <
I
{ It is noted that the QSC was established as a mechanism for providing d top TUGC0 management with a periodic update on such matters as " schedules e
and miTestones" or " audits and corrective actions".
/
/
r It was noted that recent meetings dealt with ' tracking on the status of /* i action ftems as set forth in the Outstanding Surevillance Report Items
, or the QuaTity Assurance Items of Concern Report. In such instances it #
appeared' the Quality Surveillance- Comittee was. taking on the role of a-task force or probTem solving group. The problem that exists if the QSC 7
" assumes suctr e role is that problems would tend to await the three month meeting cycle before the necessary management attention is effected.
It is. recommended that TUGCG re-evaluate the charter of the' QSC and serious i consideration given as. to .its value to the project recognizing that:
T. 1 AT.T action ta resolve problems. should be handled on. a day-to-day basis !
through the functioning organization, and Z.
The primary objective of maintaining management awareness of Quality ti l
Assurance status might be accomplished more efficiently, effectively and on a; more timely basis through a monthly Quality Assurance !
progress report distributed to the TUGC0/TUSI executives.
Dr. Qualificatierr of Personnel i
MAC reviewed the qualifications of all TUGC0/TUSI and Gibbs & Hill Qua.lity Assurance personnel and many of the Brown & Root personnel. It was observed that most of the TUGCO/TUSI Quality Assurance personnel have gained their Quality Assurance experience through Comanche Peak activities only. ATthough the project has provided valuable experience, it is rec-omended that any future assignments in Quality Assurance be filled with
{ quality engineers hired from outside the company with broad nuclear ex-perience,. preferably in construction. Such experience added to the existing staff will serve TUGCO/TUSI well in accomplishing the important
,_ ,,,,,%, . - * - = . + = = = * " * * - * ' * * * ' ~ ~ " ' ' ~
~
TUGC0 OBSERVATIONS'& REC 0fcENDATIONS .
piping, electrical and startup activities ahead.
MAC had occasion throughout the audit to assess the qualifications and experience of 20-30 inspectors throughout the construction site. These r observations are worth mentioning: '
I l. The inspectors are generally young and inexperienced with many having h as little as six months experience in inspection. p
{
2'. There was an obvious need; for more seasoned inspectors to work with the novice inspectors on a day-to-day basis,
. e
- 3. Too much responsibiTity is piaced on the inspectors with respect to preparation of inspection planning, resolutiert of site problems and
-determinatfort of the- design configuration base for performance of inspections.
I II. QUALITY ASSURANCE PROGRAW The Quality Assurance Progrant is deffned in three basic documents:
The Corporate Quality Assurance Manual P Chapter 17 of the- PSAR The Comanche Peak QuaTity Assurance Plan /
/
These documents are not irt total agreement with one another. Since there is no- other nucTear plant currently planned and since the authority dele-l gations identified in the Corporate Manual are not irt consonance with practices on Comanche Peak, TUGCQ should consider discontinuance of the 5 c=raor ** " "" ' ""'e== ** r r a*" r ar#3 ct= *= **'c" 't 4* == "-
appTied. If a. Corporate Manual is required at a Tater date, a new one could be prepared based ort Comanche Peak ' experience and the requirements of any new projects to which it would be applied.
The Comanche Peak Quality Assurance Plan addresses only the- folTowing criteria of the eighteen identified in 10CFR50 Appendix B.
i -
L TUGC0H5BSERVATIONS & RECOPfENDATIONS !
l l'C l
organization Desigrr Control i
l Procurement Administration Inspectiorf Nonconfonnance Controi Doctment Control l
l Records ,
)
Audits '
With the expanded responsibfl.ities of the TUGCU Quality Assurance Depart-ment, the pian needs to be expanded to address all. eighteen criteria to I refTect the creation and functions of the Procurement Department and to be consistent with the authority deTegations. and functions stilt resting
!i with Gibbs & Hili and with Brown & Root.
l There needs to be e pTan for procedurai identification and development and a schedule and assigned responsibilities for their completion,. including l l a complete architecture of Quality Assurance procedures, project procedures ;
l and interfacing procedufes of the Architect / Engineer and Constructor. The effort shouTd be to: minimize the number of precedures. required and to i eliminate duplicating or overlapping procedures through consolidation of ;
detafT and joint approvais of the organizations involved. It is reconnended j l
that the Quality Assurance Manager use his organization as. the driving force to achieve required procedural coverage on schedule.
It was noted that TUGCU is planning on obtaining its own Code manual.
The stated reasort for this was the fear that Browrr & Root would not' achieve '
Code acceptance. The auditors feel that the Browrr i Root manual would be '
acceptable to the Code Survey Team and that its weTd practices as exempli-ffed in. the Weid. Shop are very acceptable. The auditors. are of the ;
opinion that obtaining a Code Stamp wi1T be difficult where all the work of implementing the progrant is perfonned by others.
i III. DESIGN CONTROL The present system of expediting field changes. by referring design changes to the orfginai design organization for approval after the fact does not
TUGC0 OBSERVATIONS & RECONNENDATIONS . >
i O
>4 \
' ee ta. $at at or tocraso ^apeadix a aar or Anst "45 2 11. watch reautr-l that field changes be subject to design controls comensurate with those exercised on the original design. TUGC0 audits have already disclosed v that the Architect / Engineer has not been reviewing field originated changes on a concurrent basis, thus the design engineerfs coments may be rec
' after the specific construction work is complete resulting in possible A
(
loss of design integrity, undue pressure on the designer to justify what
! has been done, loss of designer responsibiTity or possible extens.ive t
repairs. It.is recommended that a system for expediting review and l approval by the'originaT designer be established on aff safety related t
changes using teTephone,. telecopier or teiex as necessary to coordinate and document change approvais.
IV. PROCUREMENT DOCUMENT CONTR0j.,
Except for site procurements,. the Comanche Peak Quality Assurance PTan
. does not provide for a review of. procurement documents and their changes prior to placing- a purchase order. This is contrary to requirements of 10CFR50 Appendix B,. Criterion IV and ANSI N45.2'.T3, " Quality Assurance Requirements for ControT of Procurement.....*. There is a review of pro-curement documents by Quality Assurance during- Design Review, but is was l asceH:ained that this was a- review of the drawings and specifications and not the purchase order or contract.
l Procurement document review by Quality Assurance shouTd assure that all j
necessary requirements for access. to the supplier's facilities are provided and that necessary controis and documentation have been specified and that the appropriate configuration has. been defined. The~ review shouTd mise assure that requirements imposed are appropriate to the procurement and that there are no excessive requirements for quality program develop-ment or for the delivery of unnecessary documentation. Some of the pro-curement packages reviewed appeared to have both blanket requirements for Quality Assurance programs and excessive requirements for documentation.
O
- j fnoc i
r
F + 1
- \
V. INSTRUCTIONS A. Inspection Planning The current system of providing inspection instructions or checklists to the inspectors is too generic in nature. In the case of concrete inspection planning the inspector filis. out a simple pour card with an attached Concrete Placement Checklist, a Reinforcing Steel, ETectrical, Mechanical and Embedded Item Placement Checklist and a Stainless Steel Liner Checklist,
( the combination of which:
- 1. Provides no. information with respect to unique, embedments or penetrations to be incorporated. in the pour. i
- t. Piaces an undue burderr on the inspector in attempting;to determine-appTicable drawings., specifications,, applicable revisions and y
, k appitcable DC D'0A's. Much of this input should be prbvided by clericai support under the direction and subsequent approval of
[g
(, ,
- a. quality engineer g Inspectors estimated that 45-70% of their time is spent on docu-mentatfort rather than physical inspection activ.ity. WelI thought out pTanning could do much to alleviate- this situation.
I ,
Ei Traceability It was cbserved that Cr unche Peak has established a program of unnecessary material traceability which, based on one estimate, consumes
( at least a three-man TeveT of effort and perhaps as high as a six man leveT of effort if one considers aTi the support functions; required te implement the program. ATT anchor bolts and B series cadwelds are
{.
fully traceable to heat numbers such that through an elaborate and extensive system of mapping aII installations, the capability exists.
of identifying each embedded anchor bolti,. B series cadwelds and other standard embeds. to its heat number. There exists no such NRC or industry requirement for this degree of traceability. It is inter-esting to note that rebar does not require traceability on Comanche Peak (and shouTdn't) ."!tc. knows. of no other project that imposes this require-
[
E
W-
,g.
1 ment and could not identify a Comanche Peak specification or procedure ;
requiring it. Accordingly, it is recomended that this practice be g dropped imediately. Such a move would enhance inspector morale as E those involved are aware that the practice serves no useful purpose.
f C. Procedure Simo11fication Newly established procedural systems are such that Construction and
. Quality Assurance issue procedures on similar subject matter jointly, for example,, the recencTy issued. procedure on shop travelers was.
{ jointTy prepared by Construction and Quality Assuran~ce. It is recom-n(
mended. that important procedures such as those related to concrete be
{ revised and fssued. as a single ' procedure approved by Construction and Quality Assurance. Similarly,. those procedures related. to piping and eTectricaT shouTd be revised and fointTy issued as a single Comanche Peak procedure.
D. Procedures. Endependent at' Houstort The present systent of obtainingt Browrt & Root. Houston office approval on construction procedures shouId be modified. Guidelines shouTd be worked out witfr the Houston office whereby they approve only top levei k procedures, permitting the site fuiT fTexibility in revising detailed site procedures. Perhaps the Brown & Root, Houston office could retain approval authority on those top Tevel documents that establish Brown &
Root policy,. controT the necessary type of forms, etc. However,.
detailed operating procedures should be changed with site approval onTy.
Perhaps the Houston office wouTd agree to a retroactive review procedure.
E. Conffguration Contrai A review of records for completed concrete pours indicates that the configuration refTecting the as-poured condition is not property defined. It was noted that the inspectors record the particular drawing number and revision Tetter, however, all applicaole DC 00As are not C noted. anywhere in the- inspection supporting docurrentation.
g fHiiii w w m - - - - ,,
cg_
p F. Preplanning of Construction Work In discussions with construction management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for a detailed material takeoff on ali Gibbs & Hill drawings which provides detailed instructions to the crafts as to the civil, mechanical and electrical items to be included in each segment of work. This formalized approach of taking material takeoffs in the
, office and providing this infonnation to the field forces on an approved materiaT takeoff Tist will do. much to: improve the quality of the work. ,
Since the materitI takeoff is a formai process accomplished by construction engineers. welt in advance of the work it provides a significant measure of propianning,, including the processing of necessary design changes to accompTfsh the work. Such an effort wiTT de much to minimize fieTd errors with respect to. Taft out embedments or inability to complete work as a result.of design errors It is reconnended, however that this effort beQ3
, formeTized inte a Comanche Peaje site procedure. As such,, it wi1T be
[ recognized as part of the systent and will da much to assure that Gibbs &
H11T drawings are forwarded: ta the site on a timeTy basis to accomplish this preplanning effort.
VI. DOCUMENT CONTROL P
While there appeared to be some problems with bringing the Automatic
' Records Management System on Tine,. the manual system backing it up appe'ared to be functioning satisfactoriTy. The auditors found no f deficiencies. in document centrol.
VII. CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES The QuaTity Assurance Pian is not up to. date in regard to TUGCO's responsibfifties for procurement,. source evaluation and source sur-veilTance. TUGCQ has developed a progran for rating supplier perform-ance and shows evidence of actions when reatings are unsatisfactory.
The Tist of suppliers requiring evaluation and source surveiTlance is not kept up to date by the Architect / Engineer. The list in use is over
.g.
.E...
four months old, but is maintained manually by the TUGC0 Supervisor of Supplier Compliance.
There does not appear to b'e any method. of assuring that the latest con-figuration is supplied to the personneT performing source inspection prior to shipment of procured. ftems. The source inspector appears' to be at the mercy of the supplier in determining what changes have been identified and incorporated. Thus,. it f5 conceivable that items wilt be shipped to, the site that de not meet the desired configuration- even g though requirements of the purchasing document have been met. Suc!t receipts can cause delays. and unwarranted costs frt meeting the proper '
configuration.
I. .
It is recomended that a practice be estabTished of identifying and ,
confinning required configuratiort prior to procurement and prior to shipment of purchased materiais and components.
. s
~
VIII. IDENTIFICATION AND' CONTR00. OF MATERIALS, PARTS AND COMPONENTS k No deficiency noted. MateriaT reviewed irt the warehouse, in opert storage and irr the weld shop appeared to be adequately identified.
Y IX. SpECIAL PROCESSES l A. Radiography i
Iridfunt 192~ is. being used as the radiatiort source for all radiography l at the site. This isotope has its optimum capabil.ity at about 1.5 inch j thickness of steer and is not reconsnended by the Code below .75 inches i l
l It is permitted for lesser thicknesses wherr the use of other radiatiorr sources- is not practical and whert resoTutiorr of the outline and 4T hoTe g
size of the penetrameter can be demonstrated. The energy levels of fridium isotopes are higher thart optimunr for materiais 375 inches or thinner, resulting in a flat image and Tack of contrast. Because exposure I time relates to distance, the isotope is nonnally placed against the pipe
~
opposite the film. . With a .100 inctr source size, this causes blurring of the image. Lack of contrast and; a blurred image makes it unlikely f
l l
~~ ~~
- Tuuw UUstKVATION5 & RECOPMENDATIONS ,7g_
that hairline cracks will be seen and difficult to accurately define large indications. The use of fridiunr 192 meets the minimunt requirements of the Code, but by not providing optimum identification of observed anomolies it does three undesirable things. First it causes unnecessary removal and repair of indications that can be seen but not properly identified; secondly, it masks narrow cracks, tight Tack of weld pene-tration and non-fusion which can be detrimental to service 11fe; thirdly, l it does not provide art adequate base Tine for in-service inspections performed. after the plant has gone into operatfort. Faf Ture to have cTear identification of the originaT' indications at that point can cause deTays , l the cost of which greatTy exceeds the cost of providing better identiff-n j cation and necessary repair of defects found irt the constructiert phase.
Recomendation -It is reconsnended that TUGC0 require x-ray for shop welds, and consider its use where practical for construction weids. X-ray machinas irt the range of thirty pounds of weight are avafiabTe and are nearly as portable as the isotope.. Because of its smeTier focai spot.
size and: variable voltage,. x-ray cart gtve superior radiography. The feedback of informatfort to.weiders can improve the quaTity of welds and minimize the potentfal' for defects. The abfTity to discriminate betweerr indications having roundness or sharpness at the ends can eliminate repair.
The ability to positively identify in the constructiert phase those indf-cations which have a potential for growth and faiTure can permit economical .
~
repair without radiation hazards that are inherent if found later fit the operating phase. 1 B Weiding '
No causes for concern and no procedural noncompliances were found. frr review of the weld. shop. There seemed to be a general opiniorr that after radiography repairs- are being required that are acceptabTe within l the Code. A review of a smell quantity of rejected film indicates this generaTization may be valid. It was disclosed during the audit that radiographs may be reviewed by as many as five individuals. Such ex-cessive review leads to supercritical evaluatiert of filar and to excessive repair. As previously stated,. better radiography permits better
... TUGC0 OBSERVATIONS & REC 0fcENDATIONS
-lf-E identification. of conditions acceptable within the Code. Unnecessary
=
repairs increase cost and reduce pipe reliability.
Reconnendations - Have radiographs which have been rejected for defects reviewed by TUGC0 Level III radiographer. If a reasonable statisticai l sample shows that excessive repair of weids has been required, establish the policy that Code acceptable indications shall remain untouched,. but l g shall be recorded on the reports. -
As an econony, consider reducing the number of persons. performing sequentfaT review of radfographs.
C. NDE Quaiiffcatfons.
~
The site NDE LeveT III situation is unclear. Only LeveT II certification by- Brown & Root was avafiable for the NDE Supervisor;. however, it is understood that TUGC0 has issued a Tetter identifying his 'as LeveT III.
Reconnendation - CTarify the authorfty and responsibtif ty of the NDE l -
supervisor in administering tests and evaluating and certifying per-sonnet.
This is very important as reTated to Code work, since ty
{ Level III wf1T be working under the authority of the holder of the Code stamp. -
X. INSPECTION-
' There were nor deficiencies noted relative to inspection; howev'er, it was noted that a large number of inspection personneT are receiving their first nuclear construction experience on the Comanche Peak site.
As a consequence, it is necessary to improve the quality of inspection planning and to increase the TeveT of supervision- and quality engineering-support.
Inspection planning should fdentify the required configuration including applicable DC DDAs,. the features to- be verified, the inspection method and acceptance criteria in order to minimize possible confusion h and. error.
, . TUGC0 OBSERVATIONS & REC 0ttENDATIONS
-12 XI. TEST CONTROL A review was made of the TUGCG startup administrative procedures, with l the following observation:.
1.
( The procedures. appear to be written around the old organization; that is, in several instances they refer to the Brown & Root QA/QC input required in the preparation of "startup work requests".
I Z. It was noted that an unique system is being established to- handle I nonconformances during the startupt phase.
~
It is recommended that wherever possibTe existing schemes utilfred in construction be used during the startup process. This is important since most personnel involved in dispositioning such items as nonconformances and design changes wiTT be the same persons. involved in construction.
XII.
CONTROL OF MEASURING & TEST EQUIPMENT It was observed that out of 5kinstruments sampled which are utilized in civil , structural,. mechanical and. eTectrical work, approximately 50 i
percent had not been withdrawn from the caTibration laboratory since its Tast caTibration date. This 1s particularTy significant when it is
{
recognized that the present system is such that if a calibratipn date.
becomes due, the instrument is reca11brated whether or not it has been
, issued for use. It is recomended that consideration be given toL simply changing the calibration date rather than going through a calibration cycle if the toot has not been used.
It was noted that many construction tools are calibrated. It is-important to. note that calibration of construction toots is not necessary with respect to 10CFR50 Appendix E. Although calibration and maintenance is extremely important on construction tools, it may be that frequencies may be relaxed.
XIII. INSPECTION, TEST AND OPERATING STATUS No deficiencies. were noted in this area. Material and equipment observed in receiving inspection, in the warehouse and outside storage
area appeared to be adequately identified. No tests wore observed.
XIV. HANDLING, STORAGE AND SHIPPING I :
Exterior storage practices ~should be reviewed. The protective coverings p of many items are damaged; some reported on monthly surveillance reports L
have not been corrected. Large temporary structures, such as those over the emergency diesel engines, require wind bracing to prevent further damage Because of soil chemistry, rain and humidity, the current prac-tice of aITowing Targe stainless steel piping to remain uncovered should b .
4 be reviewed. Sensitized. stainless is. extremely sensitive to chloride,.
fluoride and~ suTphide contamination which with water as a couplant can i
- {
cause intergranular corrosion and pnemature failure.
)
j XV. CONTROL OF NONCONFORMANCES-There appears to be an effort to reduce the number of documented non-conformances. ,
It was noted that DC DOAs were being utiTfzed for nonconformance reports.
Although this was observed onr a small percentage of DC DDAs issued during the month of Aprf T, it is. recomended that this practice be stopped imediateTy. The TUGC0 systeg is correctTy established whereby non-conformances are written after. the fact and DC DDAs are reserved for - ~
design changes before the fact. It is important that this practice be enforced since DC DDAs. prepared after the fact necessitate that workers.
be directed verbally to .vioTate the drawing since the deviation will be handTed after the fact with DC DDAs. This is a poor Qualit;y Assurance practice.
Procedure CPQT-AB, Rev. 0, dated 5-5-78 was issued for the purpose of providing expedient disposition of concrete discrepancies. The procedure infers that discrepancies of 72*F versus 70*F or 6.2% air content versus 6.0% maximum is perfectly acceptable when it is signed off by the field engineer. Such a system shortcuts the established nonconforming material controT system as defined in Brown & Root and TUGC0 procedures and should l l
.. .-- _ ___-_ - _x
L
-tRd Q be discontinued. If tolerances are unrealistic such that the 71*F is acceptable, then the desigrr specification should be changed to se indicate.
It is recommended that good. inspection planning be provided inspectors, identifying the characteristics te be inspected, the method of inspection and acceptance criteria and that inspectors. identify nonconfonnances to such criteria. Th,is will maintain the integrity of inspectors and provides identification of problent areas and provides a means for their correction.
It is reasonable te assume that orr a profect as. Targe as Comanche Peak there will be severai thousand nonconformance reports. The number does not reflect adversely ort the quaTity of construction, but the failure to identify nonconfonnances does refTect adverseTy err the integrity of f.
inspectors and leaves unknown the quaTity of the plant.
XVI. CORRECTIVE ACTION There were ne deficiencies noted reTative te corrective action ort hard-ware. The SuppTier Compliance Supervisor has established a method of tracking vendor performance and 'shows positive results front actions taken L
te correct supplier quality probTems. A review of reports of site sur-veiTlance conducted by TUGC0 showed corrective action responses. were being promptly received. A review of reports of survei1Tance actions by Brown & Root showed generally adequate response and resolution of corrective action except for e period of four months when survet11ance personnel were assigned to other tasks.
1 Irr general,. corrective action appears te be adequate and timely on vendor and site related problems,. but some deffefencies identified frt audits of major contractors sti1T persist. Some of the changes in authority dele-gation to major contractors appears te be actiort takert te correct inadequate or untimely response by those organizations;. however,, other actions. taken, such as handling of field changes and nonconfonnances, appear to be those
. of circumventing the problem rather thart correcting it.
.* XVII. RECORDS-Except for Tack of internal fire protection,. the quality records area is considered to be satisfactory. Some Quality Assurance records, such as personnei quaiffications, are not stored in the records center but are maintained separately by the Brown & Root training coordinator.
There is not currentTy a catalog or Tfsting of required records although it is being prepared. A review of a' selection of Quality Assura.ne records, showed the docuents in them to have been properly completed an'd fit the correct order.
Reconinendatfort - The installation of an inert gas fire extinguishing \
systant or the identfficatfort of geographicaTTy separate duplicate records j should be expedited. TUGC0 shouTd review the fire protection capabilities /
of storage facfTitfes. frr the training supervisor's trailer and consider a dupTicate set of such records ta be ma.intained in the records center.
~
XVIII. AUDIT 5 Thenr are severat audit and; surveiTTance programs in effect. Audits by the Quality Assurance Department Central Staff are performed on site activities, major contractors and suppTiers. Site surveillance actions are perfonned under the directiert of the TUGC0 QA Site Supervisor. Similar ki survefilance activities are carried out under the direction of the Brown &
Root Site Quality Assurance Manager. Whfie catted surveilTance actions, the surveillance programs are fonnaITy planned and scheduled, utilize checkTists to guide the activity and record resuits,. and issue reports of deficiencies and require correctiert. Except for formal and documented pre-audit and post-audit meetings,. aTT the elements of an audit program are irr place. It was reported that the reason for calling the activity "surveiTTance'* was te avoid outside auditors finding the program deficient because it did not incTude the documented pre- and post-audit meetings, yet the auditors found. that such meetings were conducted, but on an informal basis.
Recommendation - The auditors consider the present program to be an effective tool which could be further improved. TUGC0 should consider
. __ ___ .- . _ _. _ . _ . . ~ _ _ . -
ImAmmmmaamm%__
- n s
combining the audit and surveillance activities into a s. ingle, cohesive Q
effort. Such an integrated effort could cover required areas more' efficiently, without duplication and at a frequency that can be main-t tained. Such an audit progrant should be described in written procedures.
and include a description of both the fonnai audit and the continuous audit plan (survef1Tance) and tha method of conducting pre- and post-audit meetings. should be described to preclude later criticisms by outside organizations. The resulting audit program should be a superior tool for management assessment of progrant impTementation and effectiveness.
i o
k j
i a
6 l
1 l
l 1
, J r
l
m m N m vaa9 , wome amme ammus sugg guyg pee sques pgms umme um m g.
l i
SITE SUPERyls0R ; -
4 4
i I
QUALITY PROCEDURES ENGINEERING !NSPECTION AUDITS .
- .. ~
TRAINING l ,
i DESIGN REylEW QUALITY VERIFICATION SITE FROCFOURES i PROC. DOC'i 'REV. HONCONFORMNCE SURVEILLANCE /
INSPECTION PLAN'G, IDENT, & CONT'L, AUDITS INSP. METHODS INDOCTRINATION QUALITY STOS.- TRAINING NONCONFOR$NCE QUALITY RECORDS
! DISPOSITION i
l CORRECTIVE ACTION I 1, 1
EXNIBIT 1 1