ML20138H581

Intervenor Exhibit I-CCANP-125,consisting of 801024 Memo Forwarding Audit BR-35 of Brown & Root,Inc Engineering Organization -26

ML20138H581
Person / Time
Site:	South Texas
Issue date:	08/06/1985
From:	Ulrey R HOUSTON LIGHTING & POWER CO.
To:	Vurpillar R BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.)
References
OL-I-CCANP-125, NUDOCS 8510290087
Download: ML20138H581 (11)

Text

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m s,,ar,,e n.,,,,,g,,,,,,a o m, m.,o October 24, 1p,8_0 D Ci ill,m ;; 5 ST-HL-BR-5464' Q-5000.. lCE OF ~=:cp,h.7. -

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we GEMETjgGgSg d, DdhN Mr. R. J. Vurpillat Quality Assurance Manager Brown 6 Root, Inc.

P. O. Box 3 Houston, TX 77001

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION AUDIT OF EROWN 6 ROOT, INC. ENGINEERING ORGANIZATION AUDIT NO. BR-35

Dear Mr. Vurpillat:

Enclosed you will find Audit Report BR-35 of Brown 6 Root, Inc. Engineering organization, conducted on September 22-26, 1980. The purpose of the audit was to evaluate the implementation of Brown 6 Root's engineering program for the South Texas Project Electric Generating Station.

Twenty-one deficiencies and five concerns were identified as a result of the audit and are attached for your review and Engineering's response.

It is imperative that a complete and thorough evaluation be completed on each item prior to submittal of responses. The corrective action responses are to be documented on the attached Audit Deficiency Reports and submitted to me by November 28, 1980.

A response to the identified concerns should also be ad-dressed in the narrative portion of' your transmittal letter.

All items that will not be completed by the required response date must include the scheduled completion date.

If you have any questions or comments, please contact _me.

2. 2.

Ve7y truly yours, N

R. L. Ulrey Houston QA Manager RLU/PWR:rka Attachments

-cc: Me:;srs. R. A. Fra:ar S. H. Grote (B6R)

D. G. Barker J. R. Geurts (B6R)

A. J. Granger J. L. Hawks (B6R) 4 H. G. Overstreet-Audit File BR-35 P. W.

Ratter STP RMS, W. M. Rice (B6R) h

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• l 1;lgfllllig E TOWt f LUI i tiQ OFFICE MEMORANDUM October 24, 1980 To Mr. G. W. Oprea, Jr.

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ST-HL-17363

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Q-5000 Fham Mr. R. L. Ulrey Subject Quality Assurance Audit of Brow i 6 Root, Inc.

Engineering Organi:ation South Texas Project Electric Ge:.erating Station 00 3*'C22 Audit No. BR-35 RE: ST-HL-B R-5464 Attached you will find a copy of the announced audit of the Brown G Root (BGR)~ Engineering organization conducted on September 22-26, 1980.

A copy of the report will be transmitted via the referenced letter to the B5R Quality Assurance Manager.

The purpose of the audit was to review BSR's engineering program and verify its implementation to the requirement.s of 10CFR50 Appendix B, ANSI N45.2, the STP Preliminary Safety Analysis Report, and the BSR programmatic documents established for.STP.

As a rest it of the audit, there were twenty-one deficiencies and five concerns. identified to the BGR organization.

As identified in BR-31 (audit of B5R Quality Assurance) and BR-34 (audit of BGR STP Electrical Discipline),

an overall program evaluation indicates a failure in the ability of the BGR organization to adequately control and document their current method of ope ration. The organization is in such a state ot fluctuation that program-matic, organizational, and responsibility assignments are often indeterminate.

Contin"al procedural revisions have caused a state of confusion in determin-ing required responsibilities of and by individuals.

In addition, a review of several previous audit deficiency reports issued to B6R engineering during BR-28 (September 1979), indicates tha: committed actions by B6R never materialized.

It should be noted that the time frame in which this audit was conducted was not conducive to normal auditing' conditions for the following reasons:

1.

The priorities established by B5R to issue variour engineering procedures by October 1,1980 (per the commitments to the STP Order to Show Cause), forced the auditors to review a program in transition.

2.

During the week of the audit, BSR was performing training sessions for their personnel; this hindered the availability of key per-sonnel.

3.

The audit should have been extended into the next week to adequately review all areas; however, the NRC commenced an audit of BGR Engineering on September 29, 1980. The continua-tion of BR-35 after the NRC audit would have proven to be ineffective due to the issuance of new procedures without an implementation period.

t OFFICE ' M EM O R ANDUM October 24, 1980 To ST-HL-17363 SFN: Q-5000 p

1. E Subject Audit No. BR-35 (Continued)

It will be necessary t.o re-audit B6R Engineering in the near future after a procedural implementation period has been allowed to pass.

BSR has been requested to perform an indepth and thorough evaluation of each identified deficiency prior to submitting responses for corrective action and recurrence contro.l. The response due date is November 28,-1980.

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RLU/PWR:rka Attachment cc: o'essrs. E. A. Turner R.' M.'McCuistion A.'R.' Beavers

i W. M. Menger J. W. Arlitt W. B. Little D. R. Betterton D. G. Barker t

I L. B. Horrigan R. E. Fulghum' R.

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i H. G. Overstreet F. W. Stoerkel I ' ' l '

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- Audit File BR-35 STP RMS

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003?se3 HOUSTON LIGHTING & POWER COMPANY (HL&P)

AUDIT.NUfi3ER BR-35 AUDIT.DATE 9/22-26/80

.. AUDIT TYPE External OECA!iI"ATION AUDITED:

Brown 5 Root, Incorporated (Name) 4100 Clinton Drive Houston, Texas Address

?RODUCT/ SERVICE: Architect / Engineer for the South Texas Project PRI::E CO;; TACT:

Mr. R. W. Peverley Assistant Engineering Proiect Manager 676-7432 (Name)

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(Phone)

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SCOPE:

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AUDIT TEAM P.

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Ratter HLSP Quality Assurance (Tea = Leader)

'3 G. C. Rhoden HLSP Quality Assurance B.

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Gregory HLSP Quality Assurance W. J. Blazek HLSP Quality Assurance l

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PERSONNEL CONTACTED NAME ORGANIZATION TITLE O

J. L. Hawks BSR Engineering Engineering Project Man ater 0*

R. h. Peverley BSR Engineering Asst. Engineering Proj ect Manager 0* J. E. Paden BSR Engineering Manager Engineering Documentation 0* J. C. Shuckrow BSR Engineering Project Quality Engineer 0* G. H. Watkins BSR Engineering Manager EDCC D. Watkins BSR Engineering Asst. Manager EDCC D. Hill BSR Engic ecring SDR Coordinator E. McNair BSR Engineering' Project Ouality Engineer 0* J. R. Childers BSR Quality Assurance Houston QA Coordinator o

L. Savage BSR Quality Assurance Lead Auditor S. S. Mittal BSR Quality Assurance Auditor s

• H. G. Overstreet HLSP Quality Assurance Project QA Supervisor o

R. M. McDaniel HLSP Quality Assurance QA Specialist

• J. L. Blau HLSP Engineering Supervising Project Engineer

• = Exit Interviev 0 - Pre-Audit Briefing

Audit No. BR-35 Discussion BR-35 commenced with a pre-audit meeting with the audit team and the representatives of Brown 6 Root (BGR) Engineering Department. The audit team leader described the scope and purpose of the audit; the objective was to verify' the irplementation of B6R Engineering's compliance to the established programma-tic documents and implementing procedures.

A time frame for the documents tc be' reviewed was also established; the period subsequent to the previous HLSP audit of B6R Engineering, BR-28 (Septemb'er 1979).

During the BSR Engineering sepresentative's presentation on the status' of the engineering program and organi:ation, attention was drawn to the fact of changes cur'rently being made to both e'ngineering procedures and organization.

In specific, documentation was presented relative to interim nonconformance and FREA (Field Request for Engineering Action)' systems, design change control sys-tem revisions, and other engineering items related to the STP Order to Show c

Cause. The audit team leader emphasized the importance of making an evaluation of the. current program implementation and the necessity of documenting items of d

' l noncompliance.

The primary areas reviewed-during~ the audit were:

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Organi:ation 2.

Engineering Program 3.

Indoctrination and T*aining_'_

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Document Control 5.

Design / Change Control' 6.

Instructions, Drawings, and Procedures 7.

Nonconformances T'

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Quality Records t,.

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Findincs and Recommendations 4

As a result of tha audit there were twenty-one deficiencies identified and documented on the attached Audit Deficiency Reports (ADRs). The ADRs were dis-cussed with B5R personnel at the end of each audit day and at the exit critique on September 26, 1980.

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The following is a summary of the identified audit deficiencies. and. recommended I

corrective action.-

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Recommended ADR Descrip2 ion Corrective Action BR-35-1 Documents not submitted Implement requirements of STP-DC-015.

for required design re-Establish controls to assure documen-views.

tation for exemptions to design review requirements.

BR-35-2 Comments not always~

Supplement STP-DC-014 with controls received from required to assure required reviews are re-reviewers.

ceived.

BR-35-3 Client comments not Adhere to requirements of STP-DC-014; resolved in required-

-cstablish tickler system for late itime frame.i responses.

B R-35-4 Verifier records not avail -

Consolidate all Project Quality able in EDCC.

Engineering records in EDCC files.

Re-instruct EDCC clerical staff BR-35-5 Request of reviewer responses not in proper to requirements of STP-DC-014.

time frame.

Adhere. to requirements of STF-DC-014.

BR-35-6 Review comments from out-side agencies not pr)perly transferred.

i-BR 7 Supplier Deviation Adhere to requirements of STP-DC-024.

Requests not dispositioned Re-instruct responsible individuals in a timely manner.

of time element requirements.

BR-35-8 Nonconformance Reports Adhere to requirements of bTP-DC-022.

submitted to supplier outside required timeir frame.

B R 9 Incident Review Committee Revise STP-PMO-022 to clarify current items not recorded on operating practices.

Ncnconformance Reports.

7-BR-35-10 Engineering Design Defi-Adhere to requirements of STP-DC-021.

ciency Reports not tracked in a timely manner; EDDs.

not tracked against docu-ments violated.

BR-35-11 Engineering Design Defi-Revise STP-DC-021 to reflect current ciency Reports concerning method of operation.

interface problems identi-fied during model construc-tion not distributed to the Engineering Project Manager.

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1 Recommended ADR Description Corrective Action BR-35-12 Nonconformance Reports Adhere to requirements of STP-DC-022.

not processed in a timely manner.

BR-35-13 Houston Coordinator not Establish required communications being notified. of poten-with Houston Coordinator.

tially, reportable deficien-cies.'

Establish system to assure, prop,er '

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B R-35-14

. Corrective action not com-pleted for previously close out of commitments.

identified deficiency.

En' ineering evaluation not Establish system to assure p, roper BR-35-15 g

completed for previously close out of commitments.

identified deficiency.

, ersonnel not completing Adhere'to requirements'of B5R QA P

BR-35-16 required QA indoctrination.

Manual.

BR-35-17 No, evidence to substantiate Revis'e 'STP engineering procedures' to performance of'Proj ect" 'l remove Project Quality Engineering

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Quality Engineering audits; audit requirements, no procedural coverage for j

performance of such activi-ties; no evidence tb'sub I

stantiate Project Quality Engineering qualifications d

to perform audit.s.

BR-35-18

. Correspondence missing from Ad' tere to requirements of STP-DC-005;

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retrain EDCC clerical personnel.

BR-35-19 Engineering procedures not Adhere to requirements of STP-DC-014 processed through required review' and' co'mment ' cycles.

~.s BR-35-20 Current engineering organi-Revise STP-GR-002 to' reflect actual

ation not reflected in organi:ation and assigned responsi-bilities.

f proc,edures.

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.. Cit-BR-35-21

' Engineering procedure Re-instruct personnel on proper manuals not properly procedure updating.

i updat ed.

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b Concerns i

In addition to the above. identified ADRs, several concerns were identified I

to the Engineering organization.

1.

STP-DC-015, Revision G, paragraph 2.3.1, delineates how preliminary data.

and design input is identified, tracked, and re-verified through the use of Form 200.73.

Revision F of DC-015. required this preliminary data to l

be listed on Form 200.40A.

Several 200.40As were reviewed without the i

. preliminary data listed as required.

2.

STP-DC-002,, Revision J, paragraph 2.5.10 and 11, requires drawings to be

' listed on an aperture card. file.

Drawing 1-A-1008 was listed revision 1 on the computer index and revision 0 on the aperture card.

In addition, the drawing transmittal order for 1-A-1008 was,not available in the EDCC files.

Drawing 1-S-1557, Revision 4, ' aperture card was not available upon request.

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STP-DC-011 requires the. Engineering Document. Control Center (EDCC) to issue a list of current system design descriptions (SDDs) every other month.

This listing of SDDs does not reflect.the approved date as shown on the SDD.

i 5.

STP-DC-001 requires that all-engineering procedures are. effective on the date they are signed by the Engineering Project Manager (EPM); however, STP-PM-006 allows. thirty days. for training after the issuance of the pro-cedure. The procedure cannot be effective on the date signed by the EPM when training is inot completed.until thirty days later.

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An overall program evaluation of BSR's engineering activities indicates,an, inability to adequately control the method of operation. The organization is l

in such a state.of fluctuation that programmatic,' organi ation,,and responsi-bility assignments are changed prior to revisions to governing procedures.

For example: of forty-two; procedures indirectly relating to the STP Order to Show Cause (Item 7), twenty-six procedures require revision. Often the method of i

l imple=entation is.not.as-currently delin,eated in: procedures but as it is.soon

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As identified in the previous HLSP audit of BSR Engineering (BR-28), the l

items of document review comment resolution and '.' timely response" are reoccur i ring problems. There appears to be an abundanceiof varying status reports in existence which,only-compounds responsibility for item tracking and resolution.

It is imperative'to establish a central point of information dissemination and orientate all personnel to its proper usage and areas of responsibility.

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O It should be noted that the time frame in which this audit was conducted was not conducive to normal auditing conditions.

The priority of issuing various engineering procedures by October 1,1980, forced the audit team to review a program in transition.

The training of perr.onnel in the new procedures during the audit week further hindered the audit performance in the availability of key personnel. Finally, the audit process should have been extended into a second week to adequately cover all areas; however, the audit was terminated on September 26, :19S0, due to the commencement of an NRC audit of the Engineer-ing organization on September 29, 1980, The continuation of BR-35 after the NRC audit would have proven to be ineffective due to the issuance of new proce-dures on October 1, 1980. Therefore, it is recommended that a procedural imple-mentation period be allowed to pass, the response to BR-35 ADRs be provided and evaluated, and a re-audit of the B6R Engineering organization be performed.

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