ML20136B238
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U. S. ATOMIC ENERGY COMMISSION
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DIRECTORATE OF REGULATORY CPERATIONS
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Wh-RO Inspection Report No. P-506/74-01 Project No. 506 Ib.-[I Licensee: Houston Lightins and Power Co=pany Category A 1
$[$h E5 Location: Houston, Texas Facility: South Texas 1 and 2 leEM te*?(;
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Type of T.icensee: Two 1250 MWe PWR(W) hud Type of Inspection: SpeciaI*, Announced.
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$.G-Dates of Inspection: June 5-7, 1974
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Si Yht Dates of Previous Inspectiona September 18-19, 1973 h.2h T.:e.
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Principal Inspector:
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Rolfert C. Stewart, REdctor Inspector
'Date Accompanying Inspectors:
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' Ramon E. Hall, Reactor II&pector
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William A. Cross =an, Senior Reactor Iospector Date "Ul
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Other Acco=panying Personnel: None p "d A' d$$4
, Reviewed By: f<
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'G len Li hadsen, ChAef, Reactor Construr: tion and Date yp' l Cperations Branch h, i.J7
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SUMMARY
OF FINDINGS Inspection Findings - Significant Items O
laplementation of the quality assurance" program for design and procurement
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1.
Procedures for ent;ineering and design h tivitiew have not all been
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3 forma!1 zed. Some have been issued in preliminary form, and some as yet remain unissued for work in which South Isxas Project activities g i:
have not as yet been initiated..'(See Management Interview) g3; 2.
Procedures do not' exist'for design changes which originate as a
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(See Management Interview)
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The procedures developed for use by the Civil Engineering Division 7/My w
do not sppear to contain provisions for design change control.
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-(See Management Interview)
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Paragraph 17.1.5.a of the Preliminary Safety Analysis Report (PSAR)
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procedures developed by-the engineering and design organizaticus.
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g The wording of thi.s paragraph requires clarificati;,n.
(See Management W
Interview)'
5.
Proc.euure; for indoctrination, training and qualification of personnel
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MA' do not include requirements for maintenance of records of personnel
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external to the QA department.
(DETAILS, Par. 4.F.)
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l Status of Previouslyjeport.sd Uniresolved Iteris My':
liot applicable.
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_ Management Interview l5" e M
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t An exit interview was conducted by the inspectors with Mr. Oprea, Group Vice President, and members of his South Texas Project staff on June 7.
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The following significant topics were discussed.
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The inspector stated that he observed thst the procedures for engineerdug and design activities have not all been formalized.
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Some have been issued in preliminary form, and some as yet remain Gyp unissued for work in which South Texas Project activities have not Nd r
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", :V as yet been initiated. The applicant's representative stated that
$'d* h this was a matter known by Houston Lighting and Power (HL&P)
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management and that emphasis is being placed it. completing the required procedures on a timely basis.
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The inspector stated that he observed that procedures exist for ps:.:
assuring that design changes which are orig',nated as a result of
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ByC internal engineering review are incorporated; however, it appears that procedures do not exist for design changes which originate as M[Tf; u.a part of the licensing review.
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The applicant's representative stated that the matter will be ccrrected.
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The inspector stated that the procedures developed for use by the
$'-f4 Civil Engineering Division do not appear to contain provisions for design change control. The applicant's representative stated that gg-M,Q
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The inspector stated that Paragraph 17.1.5.a of the PSAR can be interpreted to require review by the DRC and the QAPRC of all procedures 7f g
developed by the enginerring and design organizations.
Interpretation a
by HL&P is that only the end results, i.e., the completed review packages need be reviewed by these groups, and that'the intent of f.- f the quoted paragraph was to assure the proper, functioning of the
'W above noted procedures rather thar. to require their review.
The applicant's representative stated that the PSAR will be revised
@b to clarify the intent that only the compl'eted packager are to be M
reviewed by the DRC and QAPRC.
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The inspector stated that procedures for indoctrination, trainiug E3*C and qualification of personnel do not include requirements for M'
maintenance of records of personnel external to the QA department.
l Record requiraments for persennel external to the QA department who are k1 utilized in audit or QA training activities should be established MV to fuliill N45.2.12 record requirements.-
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The applicant's representative stated that the matter will be reviewed
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and that a' mechanism for maintaining personnel records for personnel V !
external to che OA department will be develeped.
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t a-REPORT DETAILS
'a, List of Personnel Contacted
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- G. W. Oprea, Jr., Group Vice President-Operations
- E. A. Turner, General Manager-Power Plant Engineering and Construction
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- R. M. McCuistion,' Vice President' Engineering
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- A. R. Beavers, General Manager-Purchasing and Stores f : j..
J. R. Sumpter,' Supervising Engineer, Nuclear Safeguards and Licensing
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E. M. Riddle, Manager of Construction,
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C. B. McPherson, Project Engineeri South Texas Project J
J. P. Roberts, Supervisor-Purchasing 54 M. T. Thornton, Purchasing-Buyer EJ
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.J. W. Hanson, Supervising Engineer-Engineering Design, Nuclear Programs ned A. J. Granger, Engineer-Nuclear Program D. T. Hall, Engineer-Nuclear Program p.A.
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- D. G. Barker, Manager-Quality Assurance
.F. W. Stoerkel, Supervising Engineeri Quality Assurance g
1 m-R. A. Frazer, Supervising Engineer, Quality Assurance Wdr W. N. Phillip's, Supervisor, Quality Assurance 3%
W S. A. Viaclovsky, Quality Assurance Department L. D. Wilson, Quality Assurance Department D.?
F. J. Miller, Quality Assurance Department Qvl i
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.F. G. White, Quality Assurance Department h
Report of Sub_iects Inspected yw 1.
Scope of In'spection The scope of this inspection was limited to the review and examination 5t.w:,
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$r:l of the quality assurance program established by Houston Lighting
~E and Power Company (HL&P) for the South Texas Project (STP), Units 1 M
n --.... and 2, related to design and procurement activities in progress.
Md Within this scope.the inspection was performed to, determine whether
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substantive deficiencies exist relative to the requirements of c c::c:. -Appendix B to 10 CFR 50 as further clarified by the AEC document,
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- n.;r...u" Guidance on ~ Quality Assurance Requirements During Design and
'Msj Procurement Phase of Nuclear Power Plants", dated June 7, 1973.
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- Attended Management Exit Interviev' L
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Preinspection Documentation Review d
i i'.m n-:W Prior to the visit to HL&P, a tabular comparison was made between the requirements of the applicable ANSI Standards contained within y,'.1
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the Guidance, the statements nade in Section 17 of the Preliminary
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Safety Analysis Report, and the commitments contained within the Houston Lighting and Power Corporate Quality Assurance Manual and
- p?(Gi the South Texas Project Quality Assurance Plan. There were no 6W significant deficiencies observed during this review.
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Engineering-Design M;d q
A., General g'Q.
Eru The. design activities of the Houston Lighting and Power Company Stp3
~. relative to the South Texas Project are restricted to design Primary design will be performed by the architect / engineer, QSp review.
?q Brown and Root, and by the nuclear steam supply system supplier,
$f Westinghouse. This' inspection, therefore, concerns itself W
primarily with the design review activities which would be D-TI performed of those design items completed by the other design agencies preparctory to release for procurement.
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' Requirements The activities of the Houston Lighting and Power Company were inspected against the following requirements:
MA4 na (1) 10 CFR 50, Appendix B, Quality Assurance Criteria for W
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Nuclear Power Plants and Fuel Reprocessing Plants
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(2) Preliminary Safety Analysis Report, S,ection 17. South M
Texas Project QW. l
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'(3) ANSI-N45.2-1971, " Quality Assurance Program Requirements
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for Nuclear Power Plants" e---
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(4) ANSI-N45.2.9, " Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power
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Plants" (Eleventh Draft)
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(5) ANSI-Nk5.2.ll, " Quality Assurance Requirements for the Design of Nuclear Power Plants" (Draft No. 2, Revision 2)
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(6) ANSI-N45.2.12, " Requirements for Auditing Quality Assurance L -;.
. Programs for Nuclear Power Plan'ts" (Draft No. 3) i
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(7) Guidance furnished by the Atomic Energy Commission in N '-
Regional Meetings of June 1973.
J The requirements of the above noted references were reviewed
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activities.
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Procedures x
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The following HL&P procedure documents were reviewed for i
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consistency with the above references:
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. (1) Quality Assurance Department Procedures l-d
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(2) Nuclear Program Department Procedures A4' W
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(4) Systems Engineering Division Procedures
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(5) Engineering Department Procedures-Mechanical D.
Procedure Implementation h..,
Through discussions with personnel in the various engineering
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groups, the implementation of the above noted procedures was g@
evaluated.
Since only a small percentage of the design had been completed for the South Texas Project, the implementation of if/N(
the above procedures was reviewed with respect to the initial
~g issuance of the Prel4=inary Safety Analysis Re~ port, to generation E,
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of the design review requirements-list, and to selected wotk ik-packages which were in preliminary states of review. Design review work sheets were evaluated for systems for which preliminary e
~ design packages have been received by Houston Lighting and Power 4
and they were judged to be consistent with the status of the 7.E.i proj ect.-
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Design Review Committee
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Minutes of the Design Review Committee (DRC) were reviewed for
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in Preliminary Safety Analysis Report, Section 17. Minutes of
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the meetings conducted'on July 6, 1973. February 28, 1974, p.? '
March 29, 1974, and May 6, 1974, were reviewed. Activities of
..U this Committee were found to be consistent with their charter.
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Audits Audits of the Brown and Root, Westinghouse, and General Electric Company engineering functionc as well as internal audits of engineering and design departments within HL&P have been performed 3.
by HL&P quality assurance department. Reports of these audits M
were inspected. These audits were found to provide adequate W!
depth of penetration into work activitie;, deficiencies were h
' identified and a means was provided for their resolution, and kys9' the audits provided management visibility of deficiencies detected.
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4.
Quality Assurance Program QT i A.
General a.-ys s,.u HL&P's quality assurance program for design, procurement and construction of the South Texas Project is contained.in two basic manuals. The manual, " Quality Assurance Manual - Nuclear Power Plants", defines corporate policy regarding quality dIc$$
assurance and 'outlirles authority and, responsibilities of HL&P and 7G its contractors, vendors and other associated organizations gg performing quality activities. The, Project Quality Assurance A'
Plan contains procedures by which to implement the commitments cgl.
1 contained in the program manual.
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Review of Program by Management
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.of F45.2 and Part D, Paragraph 1.c of the Gray Book is provided f?h
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by the " Quality Assurance Program Review Connaittee", and directly, by Monthly Activity Reports and Audit Summaries from the Manager,
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Quality Assurance, to the Group Vice President, Operations.
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Quality Assurance Program Evaluation Committee i
a The charter an'd description of this Committee is found in L-Section 17.1.1.A.3.1.3 of PSAR, Chapter 17.0.
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Minutes of three committee meetings were reviewed. Topics f'[,).[
included audit review, AEC inspection activities, and status of E'"
i QA manuals. The frequency of the meetings was observed to h,..,
be on a quarterly basis.
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Audit Summaries
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The Group Vice President-Operations is informed of each audit Q
performed. Susmaries of the' audit deficiencies are forwarded g
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to him by the, Manager of QA to apprise him of the discrepancies identified during each audit. He is also kept informed of corrective action required for the resolution of thess deficiencies.
We Be is made aware of " loop closing" activities, especially when ki au -
difficulty is encountered in agreement as to the adequacy of h,
resolution. Audit sumanaries were reviewed and-distribution to g4 responsible management was observed.
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Activity Reports N,-
QA department activity reports for April and May, 1974, were g
examined. The QA Manager apprised the Vice Ps.esident-Operations
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of PSAR development, engineering and procurement QA activities, training and audit activities.
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It was determined that EL&P has established a system to monitor the p'
effectivehess of the QA program which appears to meet the above.
wf Gray Book requirements.
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Indoctrination and Trainina h.
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Commitments.for. indoctrination and training required by Criterion II. Appendix B, and defined in Section 2 of N45.2,
. gj Section 2 and Paragraph 5.3 of N45.2.12, and Part D, Paragraph 1.b.
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are outlined in the QA Manual-Nuclear Power Plants, Section 1.6 and PSAR, Section 17.1.2.A. page 17.17. Procedural requirements to fulfill the EL&P training program are outlined in internal b,g;,
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QA Procedure, QAP-2, " Procedures for QA Personnel Indoctrination, J'
Training and Continuing Education".
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Records of training and indoctrination of new employees, inter-l a.
and intra-training courses and sessions, on-the-job training
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and reports of industry se.r.inars were reviewed by the inspector.
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QA department intradepartmental documentation of each employee's f '
qualifications and ongoing training and participating activities Ehl for maintenance of proficiency were observed to be documented
)?h-and filed for record. Each individual in the QA department is 4
charged with maintenance of his own training record in order to
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l demonstrate qualification for specific tasks such as aulits, fSC!
class instruction, etc, i
Activities relating to interdepartmental training and indoctrination were awa=4nad.
A program has been initiated by the QA department M
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for indoctrination and training of personnel in other HI,&P 355 departments. The program schedule and details of the smainar
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agenda were reviewed. Ermaination of records revealed extensive h,
j training s==inars for the PPE&C, Purchasing and Civil and 1
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' Systems Divisions.
Sa=innes included familiarization of personnel L
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with the HIAP QA program, basic philosophy of QA (including i
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discussion of mandatory criteria imposed by Appendix B, 10 CFR 50) 1 and application of codes and standards.
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j Personnel axternal to the QA department are utilized for their j
e:pertise in both training and audit accompaniment. Procedures for indoctrination, training and qualification of personnel do h
Wi not include requirements for maintenance of records of personnel external to the QA department. Record requirements should be established on an individual basis for personnel external to the
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QA department who are utilized in QA. training activities, and
< 4i for those participating in audit activities to fulfill N45.2.12
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record requirements.
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Quality Assurance Organization A.
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The inspector +wa=4=ed Houston Lighting and Power Company's.
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with N45.2, Section 3, and for consistency with Part D Paragraph y* '; i 1
1.d, "Organisation".
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Selective examinations were based on stated requirements of Chapters 13.0 and 17.0 of the PSAR, Section 2.0 of the QA Manual g.f.
and Section 1.0 of the South Texas QA Plan.
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Authority and Responsibility The inspector discussed with members of the E&P Quality Assurance Department their duties-and responsibilities and examined records generated in' implementation of their assigned duties.
In addition
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the E&P QA department.
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Experience and Qualification W
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- I'ha experience ard qualifications of the E&P QA Manager and EfA l
the Supervising Engineer for the South Texas Project were
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g.7 Functions, zasponsibilities and authority of corporate personnel 6,.A.
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are outlined in Chapter 13.0, " Conduct of Operations" of the PSAR.
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Details of duties and responsibilities are contained in Chapter jf.9 v
17.0 of the PSAR.
s The QA Manager and his staff report directly to the Group Vice Y ,
President, Operations. At this level, there appears to exist, l',$
the required independence of the QA personnel from the pressures hs of the construction organization.
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It was determined during this review that the authority and h
responsibility of the quality assurance group are clearly 3
established and the QA Hanager has direct access to responsible management at a high level.
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Staffing M
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Revisions to the Quality Assurance Department organization Ak
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include promotions to fill supervising engineer positions and b',f' to staff the functional positions reporting to these supervisory M.
positions. Revisions to the Quality Assurance Program and Plan will reflect the extension of the organization plus the assigned
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^r duties wit!.in the scope of responsibility for each position.
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3 Included in the above are extensions to the site organization for site quality surveillance which better define the responsibilities of the personnel assigned to site activities. Expansion of the
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site quality surveillance organization for the South Texas Project
[; lam includes staffing of four engineers and eight technicians by 1976.
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n Present staffing of the E&P QA organization for quality activities g-
. appears to be commensurate with the project.
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Procurement
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concerning procurement document control were inspected and
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compared with applicable requirements of ANSI N45.2-1971, 4i g
" Quality Assurance Program Requirements for Nuclear Power Plants",
E ff and ANSI N45.2.13 (draf t), " Supplementary Quality Assurance M
i Requirements for Control of Procurement of Equipment, Materials, and Services for Nuclear Power Plants". No deficiencies were observed in the portions of the procurement document control L 3 program which have been implemented to date by the licensee.
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-B.[ProceduresReview Q'-
E&P has developed a power plant procurement procedures manual which currently contains ten written procedures. The procedures N
were reviewed relative to the above referenced requirements M
and current project procurement activities; however, because e-of the limited number of procurement documents that were available
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for review, verification of the implementation of the procedural f"
requirements was limited to the " containment vessel" procurement package. Through discussions with the cognizant purchasing personnel and the documentation presented, it appears that the 5,G" current procurement activities were b'eing implemented in accordance 4,4.
with the STP QA plan and the applicable E&P procedures.
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Audits
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The E&P audit records were reviewed and compared with the applicable 14*
s e c.AEC requirements, ANSI guides, the E&P QA manual, and the STP QA
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- r. : plan. In addition to the areas avamined and identified in paragraphs
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a.
Audit Schedule, dated 5/30/74 1
b.
Audit E-4, dated 3/21/74 (audit of nuclear program, FT-i power plant engineering and construction department) l Audit E-3, dated 3/14/74 (audit on purchasing department
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QA implementation)
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d.
QA Activities Report, dated 5/31/74 c.p.
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QA Discrepancy Status Report, dated 5/29/74
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It was 'ehserved by the inspector that a total of 39 QA audits (complate'd and/or planned) are identified on the Faster Audit Schedule oc, i Plan. The Plan reflects QA audit activities through July, 1974.
There were no deficiencies observed in the areas of'QA audit
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