ML20138H485

Intervenor Exhibit I-CCANP-123,consisting of 790927 & 1001 Ltrs Forwarding QA Audit Rept BR-28 on 790904-07.Ltrs & Feb 1980 Also Encl

ML20138H485
Person / Time
Site:	South Texas
Issue date:	08/06/1985
From:	Frazar R HOUSTON LIGHTING & POWER CO.
To:	Gamon T BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
References
OL-I-CCANP-123, NUDOCS 8510290052
Download: ML20138H485 (11)

Text

nuustoShY96 8'7 QL c

Z'OC S P-M3 d.vi Lighting pg, pf j

r

& Power September 27, 1979 COm3any ST-HL-eR-4374 0 07

/

SFN:

Q-5000 4

l Electric Tcwer l 'I PO Box 1700 j #f' hli k 1

Houstorticxas77001

• d5 L,,, 1()

Mr. T. H. Gamon All l/ 7 Quality Assurance Manager

"{~4/qq[EIR.1 c F;. p i

Brown 6 Root, Inc.

P. O. Box 3 N

Houston, TX 77001

SUBJECT:

AUDIT OF BR0hN 6 ROOT ENGINEERING AUDIT NO. BR-28

Dear Mr. Gamon:

~

c

' Transmitted herewith is the report of the Quality Assurance audit of Brown 6 Root Engineering performed on September 4-7, 1979 at the Clinton Drive offices. The purpose of the audit was q

to review the Brown 6 Root Engineering Quality Assurance Program l

for the South Texas Project and verify the implementation to the to requirements of 10CFR50 Appendix B, ANSI N45.2 and the Bro *m 4 Root Engineering Procedures.

A The Audit Team identified' several problem areas which are 7

documented on the attached Audit Deficiency Reports. The major g

problem areas identified were shielding design calculations, ALARA Review and Supplier Deviation Requests.

It is felt that 6

these areas are not adequately controlled and a thorough review should be performed.

It is requested that Brown 6 Root respond j

to the identified Audit Deficiencies by October 26, 1979.

l

J

.Very truly yours,

/

t'

,f j

0 b/f

(

g~

,R.A.Fra:l$r,[htanager Quality Assurance Depart:nent HUM a% 4tLUL ATcht COWattulun PAF :pab

+-*st No.I M-U

/N erfi:ial to, we Attachment sa tu auttu et m a m ito _ [ _ _ _ _

cc:

Liessrs. D. G. Barker W. N. Phillips

~ J" ' a ' ---- --

n ctivro_._.

T. D. Stanley

'c u me r - -- --

- - asactro D. R. Valley w : ofra

/

fJ Audit File (BR-28)

,timte r_

nye RMS m,, _ _

%,,,_ _ ~ '

'=r e n t l

0510290052 050006 PDR ADOCK 05000498 Q f [l0 O

PDR

((

..w...

ww.

muy

\\.

I

. OFFICE MEMORANDUM Octob3r 1, 1979

.To Mr. D. G. Barker ST-HL-13870 1

SFN: Q-5000 from Mr. T. D. Stanley Subicci Quality Assurance Audit of Brown-6 Root Engineering Audit No. BR-28 pf3 RE:' ST-HL-13847, ST-HL-BR-4374 f,8 The Quality Assurance Department, with technical assistance from the Health Physics Group, performed an audit of the Brown 5 Root Engin-eering Department. An extensive review of the shielding design calcula-tions, ALARA review and Supplier Deviation Requests was performed during the audit. The auditors identified numerous deficiencies that indicate a breakdown'of the BGR engineering program in these areas.

Due to the significance of these audit deficiencies, we recommend that you require B6R to perform a complete engineering review of the shielding design and ALARA review documentation to assure no regulatory requirements have been violated. Ne also recommend that B5R be required to review all past SDRs to assure no~ quality requirements were eliminated or violated.

i

~

If there are any questions, please contact myself or the Audit Team Leader,'Pr. D. R. Valley, for further explanations.

s

-. i o

, i TDS:pab

t

..ti, cc: Messrs. E. A. Turner R. A. Fra:ar W. N. Phillips Audit File (BR-25)

PJ15 r

E o t >.

71, p

i I

e v

!)I.

.t

=

u.

A v.. v4 vv4 vuuJ 4.

f

~.e.. 44 3 q>

\\

WW

~

OFFICE MEMORANDUM Octobe: 1, 1979 f/

}

To Mr. E. A. Turner.

ST-HL-13847 Mr.R.A.Fra:arjl k

SFN:

Q-5000 From o

626 Subicer Quality Assurance Audit o Brown 6 Root Engineering Audit No. BR-28 RE:

ST-HL-B R-4 374 Transmitted herewith is the report of the announced Quality Assurance audit of Brown 6 Root Engineering that was conducted on September 4-7, 1979 at the Clinton Drive offices. A copy of the report will be transmitted via the referenced letter to the Brown 6 Root Quality Assurance Manager.

The purpose of the audit was to review the Quality Assurance Program for the engineering and' design for the South Texas Project and verify its implementation to the requirements of 10CFR50 Appendix B, ANSI N45.2 and the Brown 5 Root Engineering Procedures. There were seventeen audit findings A

identified during the audit; eleven were classified as discrepancies and six as concerns. The audit findings indicated two major problem areas.

The first problem area is in the shielding design calculations and ALARA review because of the following deficiencies.

First, there was no sub-contract issued to NUS Corporation (NUS) to give NUS the requirements for performing the shielding design calculations. Also, Brown 5 Root has no re-cuirements for review or approval of the shielding design calculations received from outside organications such as NUS. The auditors could find not documentary evidence that Brown 5 Root had approved any shielding desi;;n calculations as being final. The shielding design calculations performed by Brown 6 Root had no computer models in sufficient detail to allow an adequate review.

Flux-to-dose conversion factors were not used to give area dose rates.

Ceiling and floor shielding design calculations could not be found.

References

)

and drawings in,the design calculations were not dated or identified by revision number.

Finally, the computer printouts of Brown 6 Root and NUS design calculations are not being maintained in the Engineering Document Control Center for turnover documentation.

l The second problem area is the handling of Supplier Daviation Pequests (SDRs).

The deficiencies indicate that Brown 6 koct is not fo11cring their j

procedure for SDRs.

Because of the significance of the deficiencies identified during the audit, the Quality Assurance Department has recommended -bat the M? nager, South Texas Project request that Brown 6 Root perform a complete engineering review of the shielding design and ALARA review document;. tion (ST-HL-13370),

and that Brown & Root review past SDRs to assure that no quality requirements

~

were eliminated or violated.

The deficiencies identified as a result of this audit must be corrected

u.-

?u OFFICE MEMOR A.NDUM To Emm 000cS67 Subject Quality Assurance Audit of Brown & Root Engineering, page two in a timely manner in order to ensure that the quality program is not com-promised to an unacceptable level.

.n.

RAF:pab Attachment cc: Messrs. R. M. McCuistion

. i A. R. Beavers J.;H. Ferguson g

W. M. Menger J. W. Arlitt W. B. Little' s

D.'R.

Betterton D. G. Barker

-L. B. Horrigan.

~

R. E. Fulghum 1

W. N. Phillips 8

T. D. Stanley D. R. Valley

.c Audit File (BR-28)

RMS I

e

.*g g

(

8 6

g P

8 t

9 8 8 j

J g

e 6

e 4

- t 6

\\

(

HJUSTON LIGHTING 6 P0h3 COFANY (HL6P)'

AUD1T hlNBER BR-28 0000b08 AUDIT DATE 9/.2 7/79 AUDIT TYPE External ORGANIZATION AUDITED:

Brown 6 Root Encineerine Houst on, Texa s (Nare)

(Adciress)

PRODUCT / SERVICE:

South Texas Proiect Desien Encineerine PRDE CONTACT:

(Na.e)

(11tle)

(Phone)

AUDIT D 1

.WE ORGANIZATION D. R. Vallev HLT,P OA (1ca:n Leacer)

~'

M. L. Abbe HL6P OA P. W.

Ratter HL6P OA R. L. Baron (Technical Asst.T HLF,P Health Phvries K..T. "cles (Technical Asst.)

HLT,P Health Pbveies

)

3 PERSONNEL CO'.TACTED

~

NA5E '>

ORGANI:'ATION TITLE i

0* T. D. Stanley HL6P OA Proiect GA Supervisor 3

0* R. W. Peverley B6R Encineering AEPM Eng. Support O

J. E. Paden B6R Enrineerinc Ouality Engineer 3..,

0* R. W.

Bass B6R Ouality Assurance Audit Section 'lansger 0* D. W. Janecke B6R Ouality Assurance Houston OA Coordinator O' J. R. Childers BT,R Ouality Assurance OA Coordinator

• R.A.

Witthauer BT,R Enrineerine AFP'l Ener. Production 0* J. W. Crimes

.BfR Engineerinn A!_ ARA Reviewer

• R. G. Helms BCR Encineering Proj. Quality Encineer

_ R.Mitchell_

, Bf,R Encine_cring, Proj. Quality Encincer m

I

(

h N4tE ORGANT".ATION T2TLE

• V. Derryberry BLR Encineering EDCC Supervisor

• J. C. Shuckrow B';R Encineering Proieet Ouality Engineer

• L. H. Solis BSR Engineering Disp. Proiect Engineer

• G. Millas BSR Engineering SAEPM Engineer 0

K. A. Swarts BSR Engineering Sr. Engr. Manager C. Brister BSR Engineering Mat. Con. Coordinator L. Lilleux BSR Engineering EDCC G. Smith BSR Engineering Principle Engineer R. Witte BSR Engineering EDCC P. Painter BSR Engineering Engineer 0 = Fre Audit Briefing

• = Exit Interview PUTSC5E:

To verify the implementation of the Brown G Root Engineering Procedures of the Engineering Design for the South Texas Project.

7 DEFINITIONS:

HLEP audit deficiencies are categoriced 'as follows:

CONCEPd A deficiency which, if not corrected, could lead to a dis-crepancy. A response as to corrective action taken is required.

I DISCREPRO' A deficiency in characteristics, decmentation, or procedure wnich renders the quality of an activity unacceptable or indeter-inate, and requires corrective action and follow up to close cut. Recurrence control is required.

SICNIFICANT DISCREPMQ' - A discrepancy which, due to its repetition er sericus nature, requires 1.nediate corrective actien and follow up to close cut. Recurrence control is required.

)

l

\\

(

a s

i h

' DISCUSSION:

I l

The audit team examined ob,iective evidence to verify compliance with the Brown 5 Root Engineering Procedures.

The following areas l

were examined for compliance with the 95R procedures:

i i

r i

j 1.

Document Change Notices 2.

Supplier Deviation Requests r

i i

3.

ALARA Review j

4 Specification preparation and control S.

Design verification 6.

Processing Nonconformance Reports 7.

Document and drawing control 8.

Document Review process 9.

Personnel training.

i i

j There were seventeen (17) audit deficiencies identified during l

}.,y the performance of the audit. E'even (11) deficiencies were cate-

!A gori:ed as discrepancies and the remaining six (6) were categorited t

as concerns. These audit deficiencies are documented on the attached

},,

Audit Deficiency Reports.

i 1

i l

I t

StatttRY:

i Due to the significance of the deficiencies identified in the f

areas of ALAPA Review, shielding design calculations and Supplier Deviation Requests (SDRs), t,he B6R engineering program needs strength-1 ening to assure quality requirements'are not violated. The audit' team recon, ends a complete engineering review of shit:1 ding design and ALARA Review. Also, it is recommended that BCR perform a complete review 4

l of past SDRs to assure that no quality requirements were eliminated I..

i or voided.E I

a' i

in.

t,,'t..

i u

i

,e i

t o

+'

l J a n a', d c s w i-9-u-n

,, r, i.

t>

4k 4

e-i j

Autit Tenn Leader

/

Pate I

i 1

1 l

1 i

I t

l 4

i. i y t.,e Houston C

+I

.w 4

ta Light.ing

!;, j

& Power i

'"** " 2 6 ' 2 "

Jb "l

COm)3DJ s T. Hi.- E n.i s u

(

i tj /

p

{j# j ]i

{

sin: Q-5000 t

Electnc Tower 05);;6900 i

HJ.

RO Sos 1700 r!? W ll 0

HousfortTeus 7/001 l

i Mr. T. H. Cam n Quality Assurance Manager i

Brown 6 Root. Inc.

1 P. O. Box 3 Houston, TX 77001 I

i i

SUBJECT:

AUDIT OF BROWN & ROOT ENGINEERING j

AUDIT NO. BR-28 i

j

Dear fir. Camon:

t.e have received and reviewed the Brown & Root corrective action responses to the Audit Deficiency Reports (ADRs) Audit

}

)

BR-S of BLR Engineering.

On several ADRs, the BGR corrective l

action responses are unsatisfactory.

These ADRs are listed on i

Attach ent I with a brief description of why the BLR response i4 is unsatis factory.

It is requested that BLR submit revised l

corrective action responses on the attached for:.s by Janusry 18, 7

.)

1950.

1 l

l The responses to the ADRs not listed en Attachment I are l

considered acceptable.

Corrective action will be sertited after acceptable responses are received on all ADRs from BLR.

l

)

j If there are any further questions in resolving the A0Rs, please contact myself or !!r. T. D. Stanley.

l

)

j Respectfully yours, f

l )

l l3 c.dL%)

fy~...

Y b fr4 tunager-I Quality As urance Department j

PAF pam i

At'.a chme nt i

t cc: Nessrs. E. A. Turner R. E. Fulghum

{

R. H. McCuis tion W. N. Phillips i

A. R. Icavers T. D. Stanley i

4 J. H. Ferguson D. R. Valley

)

W. H. Nenger R. Baron

)

J.

h'. Arlit t Audit Flie (BR 28) i W. B. Little PJ!S D. R. Bettertoa i,

D. C. Barker L. B. Horrigsn I

i i

)

(

ATTACICtENT 1 a 'mgqq 1)

BR-OS-D-03 The corrective action response does not completely answer the deficiency.

The deficiency is the Engineering Mate-rials Control Coordinator is not getting the suppliers to return the completed Supplier Deviation Requests (SDR) nth-in the time required by the BGR Procedure STP-DC-024-F.

2) BR-28-D-04 The corrective action does not address the original deficiency, that the SDR form Block 19 has not been completed on at least 32 SDRs.

It is recommended that these SDRs be reviewed and the justification for approval of the SDR should be attached to these SDRs.

If a Document Change Notice (DCN) has been issued because of the SDR, then at a mir imum, the DCN should be referenced in Block 19.

3) ER-28-D 05 Again, the corrective action response does not address the original deficiency, which is, any drawings, specifi-cations, requisitions, etc. changed by the SDR were not I

referenced in Block 19.

It is recommended the 0?R review the SDRs to assure any document requiring change by the SDAs be referenced in Block 19 of the SDR's.

)

4)

BE 2! D 06 1

The corrective action response is not acceptabic, ne Eik QA Manual requires that SDRs be reviewed by the same S

organi:stion that approved the oririnal docu.cnt.

A re-view of all SDRs should be completed and B5R QA will re-view the SDRs if 2LR QA reviewed the original document and B!R QA will continue reviewing SDRs until a formal QA Manual change is made and ipproved by the ASMS, D '*

5) BR-25 D 07 The corrective action response is not acceptable, ne Hl.tP Auditor should have used the B&R QA Manual to identify this deficiency but the deficiency still exists.

BGR QA Manual Section 3.10 Engineering Consultants states, "All docu ents prepared by a censultant will be sub.itted to the responsible B&R Project Engineer for review and appro-val."

First, the NUS Shielding Calculations were not approved by a BGR Project Engineer.

Second, there is no procedure on how B6R will handle such a review and appro-val of Engineering Consultant Documents.

[

(*

.e 6)

B R-2 8-D-08 The corrective action response is not acceptable.

There must be son.e backup design calculations to prove that the area radiation limits set by the STP FSAR are not being exceeded by the B5R design.

The auditors could not find nor obtain such backup design calculations.

7)

BR-28-C-04 The corrective action response is unacceptable..The Auditor requested the MCC to define the B4R term " timely manner" and he gave the ten day time limit.

If this is an unacceptable time frame in which to review and dis-position SDRs, then define a time limit in which SDRs will be dispositioned.

The deficiency identified SDRs that were still awaiting dispostion after four months; thus, a specified time limit for SDR disposition needs to be procedurali:ed. * '

I i

)

I m.

ll 6%

e

,, i t

I

==

t 4

I

(

l e

i g,

l I *.*.

t l

e i

l 8

' I e

.I I

i I

.-e*----g-*--

--a w

p.

uvaug'uy a i v u.a u

"*banan6 u.

Aunu OFFICE MEMOR ANDUM February 31, 1980 To tir. T. D. Stanley from h!r. D. R. Valley L Sub/cet Resolution of Audit Findings of Bf,R Engineering 0006S33 Audit No. BR-28 REF: ST-llL-BR-4 564 A meeting, called by Ftr. R. W. Peverly, was held on January 31, 1980 to discuss the resolution of Audit Deficiency Reports (ADRs) to Audit BR-28.

In our evaluation of BGR original responses to the ADRs, (see letter ST-ill-BR-4564) we rejected seven of their ADR responses.

!!r. Peverly presented the BSR proposed revised audit responses and stated he would have the formal ADR responses to llLGP by February 8, 1980.

Below is a brief description, by ADR, of the BT.R revised ADR responses as presented in the meeting, BR-28-D-03 B5n has removed the ten day return of SDRs by g

suppliers from procedure STP-DC-024-F 3

BR-28-D-04 BLR has reviewed all SDRs since June 1, 1479 and has connleted all SDR forms block 19.

Procedure STP-DC-024-F will be revised to instruct engineering to J

reference DCNs in block 19.

BR-28-D-05 BSR reviewed all SDRs since June 1,1979 and if the SDR required a chanEe to another document, this document will be referenced in block 19.

)

BR-28-D-06 BGR has revised the QA !!anual to define exactly what SDRs the QA Department must review and approve.

BR-28-D-07 B5R engineers will review all design calculations t **:

received from outside organi:ations and document their review.

BR-28-D-0S BGR has compiled a partial listing of the design calculations requested. Those areas missing the required design calculations are being evaluated and new calculations will be performed and for-warded to llLGP.

BR-28-C-04 BGR has developed a new system and the resnonsible engineer will be assigned a response due date by which the SDR will be evaluated and accepted or rejected. Procedure STP-DC-024-F will be revised to reflect this new system.

DRV:rer cc: Flessrs. R. A. Fra:ar W. N. Phillips P. W. Ratter Audit File (BR-28)