ML20198D479
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- 1. Allegation Category: QA/QC SD, Nonconformance Reports
- 2. Allegation Number: AQ-30, -31, -32, -34, -35, -36, -37, -80, -85, -86, -87,
-95, -96, -97, -106, -109, -114, -116, -120 and -124
- 3. Characterization: It is alleged that nonconformance reports (NCRs) were
-initiated, processed, controlled, and dispositioned improperly. (Similar allegations, related to specific NCRs for electrical work and protective coatings, were reported in Electrical and Instrumentation Category 6 and
. Protective Coatings Category 5b.)
- 4. Assessment of Safety Significance: In assessing these allegations, the NRC Technical Review Team (TRT) reviewed applicable procedures, NCRs, component modification cards (CMCs), design change authorizations (DCAs), inspection
. reports-(irs), and N-5 data reports. In addition, interviews were held with both Texas Utilities Electric Co. (TUEC) and Brown & Root (B&R) per- -
sonnel in engineering, QA,-QC, accounting, scheduling, and document control. .
The results of the TRT findings for specific allegations are discussed below.
AQ-30 and AQ-31 alleged that interoffice memos (IMs) were used to void NCRs and make other unauthorized changes;-no specific examples were identified.
Texas Utilities Generating Company (TUGCO) procedure CP-QP-16.0, "Non-conformances," and B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," allowed NCRs to be voided under specified conditions. In assessing these allegations, the TRT interviewed TUEC and B&R QC, engineering, QA, and document. control personnel. The TRT also reviewed 154 NCRs, of which 64 had been voided. Three NCRs (82-0005, 82-0006, and M-12354) had been dispositioned by IMs, and one (M-83-02847) had been voided by an IM.
(NCRs can 'also be voided by writing " VOID" in the disposition block and adding the appropriate justification.)
All NCRs that had been dispositioned or voided by IM had the IM attached to the NCR as supplementary information for the disposition or voiding of the NCR. This practice was consistent with procedure CP-QP-16.0, which required that "any pertinent supporting documentation shall be attached to the NCR and referenced in the reason and justification statements."
Voided NCRs required, and had the approval of, the quality engineering (QE) supervisor. Therefore, these allegations were not substantiated.
AQ-32 alleged that corrective actions were not being implemented; speci-
' fically, that 35 NCRs identified in corrective action request (CAR) S-41 had not been cleared as of September 10, 1980.
- The TRT reviewed CARS S-41 through S-57. CAR S-41, related to hanger NCRs, referenced 36 NCRs. All 36 NCRs had been closed, with closing dates rang-
- ing from May 14, 1980, to February 19, 1981; 19 of the 36 referenced NCRs j had been closed by September 10, 1980.
Other CARS reviewed by the TRT indicated that the required corrective actions had been completed. For example, CAR S-48, relating to arc
! strikes, resulted in 419 welders being given reindoctrination for the pre-vention of arc strikes, plus additional equipment protection measures, i
l coam a s-e,._.. s m ... .... _ .
Welder attendance was verified by signed attendance sheets. Allega-tion AQ-32 was not substantiated. (See allegation AQ-116, below, which discusses implementation of the corrective action system.)
AQ-34 alleged that NCRs were disapproved and destroyed, but no specific examples were identified.
The disapproval (voiding) of NCRs by use of IMs is addressed in the assess-ment of allegations AQ-30 and AQ-31, above. The destruction of NCRs was previously reviewed by the NRC in September and November of 1980. The re-sults of that review, published in Region IV Inspection Report 50-445/80-22, indicated that up.to that time some NCRs were voided and those NCR numbers
-were then reassigned, which was considered to be a poor practice. The re-port also indicated that new procedures, issued in August 1980, required voided NCRs to be forwarded to the records vault and prohibited the reis-suance of their NCR numbers.
The TRT initially reviewed 131 NCRs (dated between 1980 and 1984), of which the NCR log indicated that 41 had been voided. The voided NCRs were avail-able in the records vault, except for six originated by TUEC, which were not available. Additional interviews with the TUEC open records vault co-ordinator indicated that, at times, an NCR number was assigned, then sub-4 sequently was not used because the individual obtaining the number decided that an NCR was not required. The open records vault coordinator stated that the six missing NCRs had never been written. This approach is con-sistent with procedure CP-QP-16.0, which stated: "NCRs may be voided at any time if it is determined that nonconforming conditions do not exist, the nonconformance was previously reported on another NCR, or other similar conditions exist." Additional research by the permanent plant records vault personnel disclosed that, of the six missing NCRs, one duplicated the subject of a preceding NCR, and two others duplicated the subjects of preceding inspection reports. The three other NCRs (E-81-00024, E-80-00143, and E-80-00228) could not be located. The three missing NCRs occurred.in approximately the last quarter of 1980, shortly after issuance of the re-vised NCR procedure. The TRT reviewed 23 additional NCRs which were voided in the last quarter of 1983; all were available in the vault.
A TRT review of NCR procedures verified that B&R procedure CP-QAP-16.1 re-quired voided NCRs to be transmitted to the records vault. TUGC0 procedure CP-QP-16.0 stated that, "The original voided NCR will be forwarded to the (PFG) NCR Coordinator," but gave the NCR coordinator no additional instruc-tions for handling voided NCRs. The TRT found that the NCR log books lis-ted all NCRs, including those that were later voided, and that the numbers of voided NCRs were not reissued. These changes to the procedures, in addition to the NCR coordinator's understanding of the NCR process, appear to have adequately corrected the handling of voided NCRs, although TUGC0 procedure CP-QP-16.0, Rev. 14, should have contained explicit instructions to the NCR coordinator for handling voided NCRs.
The TRT concluded that allegation AQ-34 was substantiated in that there l were instances of poor practice in handling voided NCRs prior to the end of 1980; however, the practice has been corrected.
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AQ-35, AQ-37 and AQ-80 alleged that a B&R QC manager issued oral and writ-ten instructions stating that irs were to be used to document deficiencies in lieu of NCRs, and that deficiencies were. reported on irs rather than on NCRs. No specific examples were identified. The reasons given were that:
(1) irs could be "dispositioned by anyone," and (2) items reported on irs might not be reinspected. Also.it was alleged that inspectors were under
" pressure" not to write NCRs.
As' identified in B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," the intended use of an IR was to document conditions that did not conform to drawing requirements and that could be repaired using existing procedures. If a drawing change would. resolve the condition, a DCA or CHC
- was issued. If engineering disposition was required or the deficient item required a hold tag or if the "UNSAT" IR was not resolved within 2 weeks, an NCR was issued. According to the B&R representatives interviewed, irs were never intended to replace NCRs, but were initiatory documents comple-ted by inspectors that led to an NCR, if required; however, non-inspection personnel would continue to document deficiencies on NCRs.
The TRT reviewed 63 irs for various items that initially had been deter-
- mined to be unsatisfactory. The irs did not appear to have been written against items that should have been written as NCRs. (However,during
. review of 22 TUEC irs associated with the post-construction verification program, QA/QC Category 8, Allegation AQ-135, the TRT did find that appar-ently identical conditions were described on NCRs in some cases and on irs
! in others.) In those cases where the IR required engineering disposition, the appropriate documents were prepared. For example, the following irs
- resulted in the preparation of the listed CMCs or DCAs:
IR I-1-0043092 resulted in CMC-66621 4
IR ME-1-0043113 resulted in CMC-99152 IR I-1-0043118 resulted in CMC-66646'
- IR ME-1-0043054 resulted in DCA-16947 -
IR ME-1-0043055 resulted in DCA-16947 The 63 closed irs had been reinspected after repair and were signed off by qualified QC inspectors as satisfactory. The signature of a certified QC
- inspector was required to close an unsatisfactory IR, as defined in pro-
- cedure CP-QAP-16.1, not the signature of "anyone" as alleged. The TRT noted no misuse of this requirement. The procedure also requires that a quarterly report of unsatisfactory irs be sent to the QE supervisor for assessment and trend analysis in accordance with the corrective action '
,- system. The TRT found that these quarterly reports were prepared as required.
J.
The TRT located a B&R memo that was apparently intended to apply specifi-cally to QC inspectors, which stated, in effect, that only items that could not be resolved with an IR, DCA, or CMC were to be written as NCRs.
These memos were consistent with the above procedures; however, some inspectors may have interpreted this memo as instructions to write irs, rather than NCRs.
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TRT interviews with QC inspectors and management personnel revealed no evidence of pressure not to report nonconforming conditions, only the need to report defic'iencies on the appropriate form in accordance with pro-cedures. The TRT reviewed the QA/QC orientation film, " Introduction to Quality Assurance and Quality Control" used in the training of all CPSES QC inspectors. The film made many references to the organizational inde-pendence of QA/QC from construction. Additionally, the training emphasized the establisnment of good working relationships with craft personnel to avoid personality conflicts.
Allegations AQ-35, AQ-37, and AQ-80, related to misuse of th' B&R e IR ' system, were not substantiated.
AQ-36 alleged that DCAs were being used to " cover-up a condition for which an NCR should be written," since the DCA does not receive QA/QC review, as does the NCR. No specific examples were identified. ~
TUGC0 procedure CP-EP-4.6, " Field Design Change Control," Revision 10, stated that changes must be approved by the " original designer's designated site representative." In April 1983, the Gibbs and Hill (G&H) site represen-tative approval function was supplemented by a G&H site design review team, as described in CP-EP-4.6 and CP-EP-4.7, " Control of Engineering / Design Review of Field Design Changes." TRT interviews with the TUEC engineering manager indicated that DCAs and CMCs were used by TUEC to change design documents (drawings,etc.). Drawings were originally prepared by Gibbs &
Hill (G&H), the architect-engineer for Comanche Peak Stream Electric Sta-tion (CPSES). The original drawings were signed by a professiona*. engineer and were not signed by QA/QC personnel. The TRT determined that the appli-cable procedure did not require approval of drawings or DCAs by QA/QC personnel.
Procedure CP-QP-16.0, Rev. 14, defined a nonconformance as "a deficiency in characteristic, documentation, or procedures, which renders the quality of an item unacceptable or indeterminate." Because this definition is so all-encompassing, it may have been difficult to determine when a noncon-formance which required an NCR existed, or when a CMC or DCA was adequate.
(A similar concern related to irs and NCRs is described in QA/QC Category 8, Allegation AQ-135.) Certainly, all CMCs or DCAs were not prepared as a result of an NCR. Also " tracking NCRs" were frequently written, in which the NCR was not used to describe a nonconforming condition, as defined above, but was used to record removal of a part from equipment on a perma-nent equipment transfer (PET). The purpose of the NCR, in this case, was to ensure eventual replacement of the removed parts. This usage does not appear to be consistent with the definition of nonconformance.
Procedure CP-QP-16.0, Revision 14, was not entirely clear on nonconformance reporting. Specifically, paragraph 2.1 stated, "It is the responsibility of all site employees to report items of nonconformance to their supervisors or to the TUGC0 Site QA Supervisor," and paragraph 3.1.2 required using the NCR form for that reporting. However, paragraph 3.2.1 states that non-QA/QC personnel should transmit the NCR to the Paper Flow Group (PFG)
NCR Coordinator, who in turn would transmit the NCR to the " appropriate" 0-180
QE, who was neither the individual's supervisor nor the Site QA Supervisor, as required by paragraph 2.1.
Additionally, the NCR form had no form number or revision date, indicating that the form may not have been adequately controlled. The TRT identified two versions of the TUEC NCR form, one having a space for ANI review. This version apparently was not used. The TRT also noted that the form currently in use has no space to identify the cause of the nonconformance and the steps taken to prevent its recurrence, and that there is no provision for quality assurance review, as described in allegation AQ-116. -
DCAs and CMCs may be prepared as a result of NCRs and inspection reports, as described in the assessment of AQ-35, AQ-37, and AQ-80, above, and the possibility for overlap exists. Following the previously noted procedural guidelines, the 90 CMCs and 82 DCAs reviewed by the TRT did not appear to have beei written for items that should have been the subject of NCRs.
While the TRT noticed some weakness in the procedures, allegation AQ-36 was not substantiated.
AQ-85 alleged that the use of test deficiency reports (TDRs), irs, and maintenance action requests (MARS) was being abused in that these forms were used for conditions that warranted NCRs. Specific examples were not identified.
TUGC0 procedure CP-SAP-16, " Test Deficiency and Nonconformance Reporting,"
defines the use of TDRs and NCRs. Specifically, TDRs were used to describe deficiencies in operating characteristics, test documentation, startup pro-cedure compliance, or any other deficiency identified by startup personnel.
NCRs were used to describe deficiencies in physical characteristics, vendor documentation, or construction documentation.
The TRT reviewed 42 TDRs which were originated from July 1983 to May 1984.
All TDRs described items in the categories appropriate for TDRs.
The TRT reviewed a listing of MARS issued in March 1980, and March 1981, since_ there was a relatively larger quantity of MARS compared to TDRs. The MARS described normal maintenance work and did not cover material that should have required an NCR.
The use of irs versus NCRs has been described in allegations AQ-35, AQ-37 and AQ-80, above. Procedure CP-SAP-16 also required that the Startup Qual-ity Specialist and lead Startup Engineer identify trends adverse to quality and initiate corrective action.
The TRT found no examples of abuse of the MAR, TDR, or IR system; there-fore, allegation AQ-85 was not substantiated.
AQ-86 alleged that QC supervisors made it difficult for QC personnel to do followup inspections of NCRs. Specific examples were not identified.
B&R procedure CP-QAP-16.1, required that: "The applicable QC Superintendent /
QCE shall ensure that the work activities required by the NCR disposition 0-181
are verified and/or witnessed by qualified inspection personnel. The in-spector shall document the completion of the NCR disposition by:
- a. Assuring documentation is available to verify that the disposition has been satisfactorily implemented. This documentation shall be attached to or referenced on the NCR; and
- b. Signing the verification block on the NCR. The signature provides objective evidence that the hold tag has been removed.
QE will coordinate obtaining ANI concurrence. Should any dis-crepancies arise, they will be referred to the QCG [ Quality Control Group] and/or QEG [ Quality Engineering Group] super-visors for resolution. Following ANI concurrence, the QE will review the NCR and applicable supporting documentation for legibility, clarity, and specificity and then sign for ' Closure' of the NCR.
TUGC0 procedure CP-QP-16.0 contained similar language.
The TRT noted that there was no requirement stating that the original inspector was required to follow up the NCR disposition implementation.
Such followup would have advantages, as would the forwarding of a com-pleted NCR to the originators, but this was not a requirement.-
In assessing this allegation, the TRT reviewed 154 NCRs. Required rein-spection had beer completed and signed off by a QC inspector on inspection documents attached to, or referenced in, the NCRs. The TRT aisc compared inspector signat.ures on a representative sampling of these NCRs with signa-tures maintained in a card file, and could not identify any discrepancies.
Quality engineering had also signed the NCRs separately for closure.
The TRT found no examples of QC difficulty in performing followup inspec- .
tions for closing NCRs; therefore, allegation AQ-86 was not substantiated.
AQ-87 and AQ-124 alleged that craft personnel rather than QC personnel have been signing off NCRs that QC refused to sign, and that some NCRs were dispositioned "inaccurately."
The TRT reviewed 154 NCRs, as noted in AQ-34 above, and found no evidence l of incorrect or falsified signatures. Falsification of signatures is very l
difficult to substantiate unless specific individuals voluntarily dis-close that specific signatures are not theirs, or the signature handwrit-ing is widely different from their usual handwriting. The TRT identified no cases of this kind for NCRs.
l The TRT determined that the QA staff, or the QE who signed an NCR for clo-sure, reviewed previous signatures. The signatures of the QE, engineer, l and addressee on the NCR typically are very familiar to the QA staff or QE. One QE stated that there had been instances in which he had refused 0-182
to sign an NCR because of an unfamiliar signature; however, in each in-stance the question was resolved, and he then signed the NCR for closure. ,
Part of this allegation referred to NCRs for flanges on 12-inch piping
.shown in isometric dr:wir; VA-2-AB. There are two isometric drawings in that series: BRP-VA-2-!w J01, and BRP-VA-AB-002. Both of these drawings show only 3/4-inch piping without flanges.
-Another part of this allegation referred to NCR M-13932, in that the NCR was incorrectly dispositioned by voiding. This NCR specified that the only requirement violated was B&R procedure CP-QAP-11.1, Revision 4, para-graph 2.3.2. The TRT roted that the only paragraph 2.3.2 contained in that procedure was in Attachment 1, which did not relate at all to the subject of NCR M-13932. After a review of the NCR, the TRT determined that the NCR was properly voided by the QC supervisor.
The TRT review did identify specific cases of improper dispositioning of NCRs. One such case is described in Electrical Category 1, Allegation AQE-36. Another, in which the description of the nonconforming condition was changed by two successive revisions that changed the meaning of the NCR, is described in QA/QC Category 6, Allegation AQ-55. A third case is described in Mechanical and Piping Category 33, Allegation AH-3, and a fourth is described in Protection Coatings 5b, Allegation AQO-7.
Improper dispositioning of NCRs by B&R was also investigated by the Authorized Inspection Agency, Hartford Steam and Boiler, in Citizens Associated for Sound Energy (CASE) Exhibit No. 1050, dated October 21, 1983, with responses thereto by B&R, which was considered in this assess-ment by the TRT.
. Allegation AQ-87 was not substantiated. The TRT concludes that there were instances of improper NCR dispositioning, and therefore allegation AQ-124 was substantiated.
AQ-95 alleged that NCRs were misused in that an NCR'was written to apply to more than one traveler. Specific examples were not identified.
The TRT found that there were a number of NCRs that were used as " generic" NCRs, i.e., each NCR applied to a common type of problem identified in a number of locations. For example, NCR M-83-01162, " Stairway Framing,"
, listed 17 affected travelers. Each traveler applied to a specific stair-way and each individual traveler had QC sign-off for repair of that stair-
- way. All travelers were attached to the NCR for closure. Procedure
- CP-QP-16.0 had no requirement that prohibited the use of multiple travelers
? in NCRs.- The TRT found no examples of generic NCR misuse, and consequently, l allegation AQ-95 was not substantiated.
' AQ-96 alleged that the use of open-ended field job orders (FJ0s) made work appear to have been pre-approved. Specific examples were not identified.
' The TRT reviewed the FJO files. The FJO was an accounting mechanism only; it was not a construction document and craft personnel could not do work
- to an FJ0. Approximately 330 FJ0s were written for repair work to vendor
! . equipment. Of these, two were open: No. 49, for Allis Chalmers, and
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No. 261, for ITT Grinnell. The two were open because of continuing re-pair work required for equipment supplied by those companies. FJ0s were used as financial documents to backcharge the vendors for repair to vendor equipment rather than returning the equipment to the vendor. ,
Allegation AQ-96 was not substantiated.
AQ-97 and AQ-116 alleged that permanent documentation was pulled out of the records vault and NCRs were written because the documentation did not match the " log book" (AQ-97), and that B&R procedural changes have resulted in the violation of procedures for document review of ASME documentation and manipulation of safety-related documentation (AQ-116). Specific examples were not identified.
The TRT reviewed 32 B&R NCRs that had been written against items after acceptance of the isometric N-5 data report. The 32 NCRs noted the lack of ANI sign-off on flange travelers related to the N-5 data reports. The 32 NCRs were dated between January and April of 1984. Eighteen of the NCRs resulted in " cosmetic repair" that did not require any change in the N-5 data report; 14 of the NCRs resulted in repair that caused an amendment
. of the N-5 data report, with QA sign-off and ANI concurrence. B&R estab-lished an N-5 data report documentation checklist, which required checking for the latest flange traveler.
Review of the B&R NCR log indicated that 50 NCRs, related to incorrect docu-mentation, were issued during August 1984. The TRT attributed part of this increase to an increase in the amount of documentation being transmitted to the records vault. The issuance of that many NCRs would seem to war-rant the preparation of a CAR; however no CAR was written.
The TRT noted other instances in which specific nonconformances were cor-rected, but programmatic corrective action was not taken. The TRT noted from the CAR log that no CARS were issued between June 11, 1980, and January 14, 1982, but that four separate CARS (22, 27, 32, and 43) were issued relating to hold point violations. This lack of issuance of any CARS for 19 months, plus repetitive issuance of four CARS for the same subject, indicated to the TRT that this portion of the QA program (as dis-tinguished from QE and QC) was not effective. Indeed, the NCR form did not identify any review of NCRs by an element of the QA organization. The QA review identified in TUGO procedure CP-QP-16.0, paragraph 3.2.6, was in reality a QE review, and the only reference to QA review in B&R proce-dure CP-QAP-16.1 was to a managerial review.
Allegation AQ-97 was substantiated; however, the alleged occurrences were conducted according to procedure. The TRT noted a weakness in the CAR system.
The TRT found that hanger packages may continue to be modified (by NCR) to add revised drawings that require adjustment rather than structural modification, e.g., snubber loading or adjustment of spring cams. The TRT did not consider this to be an abuse of procedures. (The lack of or untimely documentation review by the ANI is addressed in QA/QC Category 2, AQ-134.)
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The TRT reviewed B&R procedure CP-QAP-12.1, "ASME Section III Installation Verification and N-5 Certification," which was revised and reissued as Revision 11 on June 11, 1984. The TRT noted that at least 14 other quality assurance procedures were revised and reissued on June 11, 1984, apparently as part of an overall procedure updating.
A TRT interview with the N-5 lead QA/QC engineer indicated that the intent in issuing Revision 11 of CP-QAP-12.1 was (a) to incorporate detailed in-structions for preparing N-5 data reports, which had been contained previ-ously in a separate, informal document; and (b) to require documentation for recently completed activities to be sent directly to the N-5 group, who assembled the complete N-5 report package and transmitted it to the 1 ANI for review and approval. The previous revision of the procedure re-quired that the documents be sent from the field to the records vault, which required the ANIS to wait until the documents were processed and indexed by vault personnel before obtaining a copy to add to the N-5 report package, and then proceeding with their review. This change may appear to be a violation of earlier procedures; however, the revised pro-cedure made no change in the review required for the report package nor in the use of the N-5 documentation checklist. T5e change involved the sequence for transmitting documents to the vault. The N-5 QA/QC lead engi-neer indicated it was a more satisfactory process. Allegation AQ-116 was not substantiated.
AQ-106 alleged that NCRs were written against startup work authorizations F5WAs),whichareauthorizationsforworkrelatedtostartupactivities (rather than construction), to correct uncontrolled design change documents that were released for use with the SWAs. The implication was that unau-thorized design changes were being made by SWAs. Specific examples were not identified.
The TRT conducted a computer search of the entire SWA file to locate the SWAs that had resulted in NCRs. Three were found (NCRs 83-0083, 84-0111, and 84-0066). These three NCRs were not related to the use of uncontrolled design change documents. The TRT found no evidence that NCRs were wr;tten against SWAs to correct uncontrolled dengn changes; therefore, allegation AQ-106 was not substantiated.
A_Q-109 alleged that the dismissal of a QC inspector had a negative (chill-
! ing) effect on the preparation of NCRs.
This allegation was previously investigated by NRC personnel in Region IV.
That investigation concludes (Reference 25):
In summary, a total of 76 past and present QC inspectors were inter-vi ew::d. None of the 76 inspectors indicated they had ever failed to l report a deficiency or document a nonconforming condition. Only one assented that there were attempts to intimidate him. No one indi-cated that knowledge of [the discussed QC inspector's] termination j had caused them to improperly perform inspections, but three inspec-
! tors did state that as a result of [the inspector's] termination, they l were more careful in their inspections and in writing NCRs.
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'4 4 5 The TRT interviewed two cf the' three ind'1viduals onsite that knew the dismissed inspector, as well as other QC1 inspectors. None of those inter-viewed indicated any reluctance to write NCRs because of fear of dismissal.
Therefore, the TRT concurs with the report conclusion, and this allegation was not substantiated.
AQ-114 alleged generally that, instead of writing NCRs, B&R inspectors kept personal logs of " problems"<they discovered, then.obtained their disposition and that " keeping such logs is in accordance with Construc-tion Procedures in the section on procedures fo.r nonconformance reports."
Specific examples were not identified.
The TRT reviewed both TUGC0 and B&R NCR procedures and found no reference 4 to inspectors keeping personal logs of problems. Lead B&R QC inspectors did maintain a log of unsatisfactory irs, according to B&R procedure CP-QAP-16.1, " Control of Nonconforming Items," which provides that each QC group be preassigned a block of IR numbers, which they used as unsatis-factory irs were written.
Interviews conducted by the TRT with two QC inspectors and three QC super-visors disclosed that, during the first few years of the CPSES project, QC inspectors kept logs of all the jobs they inspected. Such logs supposedly are no longer maintained; some inspectors do maintain an informal log of jobs worked in case supervision questions the amount of work they have completed.
The TRT discovered a personal QC log book with the following entries:
Date Entry '
12-18-81 Night shift personnel (paint) have been verbally directed by to violate paint 9I and inspect via 3 part memo - (who's on first?)'-
program violation."
03-02-82 " Duplicate hanger numbers on supports to phantom steel - how to inspect, how to as-built, how to code certify."
05-20-82 " Talk to on spread room:
- 1. Bolt torquing
- 2. Coping by 05-24
- 3. As-Built train [ing]
- 4. 100% reinspection" 07-08-82 " Overtime for As-Built denied by and for budget considerations. 35 problem backlog."
Inspectors may keep informal logs if they desire; however such logs should
.not be used in place of the formal nonconformance or deficiency reporting system. It appeared that some of the above items should have been the sub-l Ject of irs or NCRs, but the TRT could not locate irs or NCRs related to i
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the entries. The TRT was unable to locate additional logs of this r.ature; however, if the use of such logs was common, it could imply a breakdown in this area of the QA/QC program. Based on the log book found, the TRT considers the allegation was substantiated.
AQ-120 alleged that "during the time Reactor Building Unit I was starting to be turned over, there were a number of NCRs written, the disposition of which was questionable." Specific examples were not identified.
The TRT interviewed engineering and scheduling personnel to identify the turnover process. Turnover is accomplished as a specific subsystem or area is completed, not by turnover of the Reactor Building as a complete e unit. The first system at the site to be turned over by B&R was system 85-01, Turbine Building Unit I and 2 Cathodic Protection, on September 19, 1978.
The TRT reviewed the B&R NCR log for the period around September 1978.
There was no apparent reduction in the time required to disposition NCRs immediately before September 1978. Some NCRs issued in the first half of September required over a year to disposition, which also does not indicate a rush to complete disposition of NCRs. The NCRs issued during the period of August to October 1978 related to a wide variety of systems (not just system 85-01). TRT review of a number of these NCRs indicated they were dispositioned satisfactorily.
Inspection of the B&R Open NCR Status Report of July 18, 1984, indicated that, of typical open NCRs listed, approximately 83 percent were to be closed by hardware work of some kind, and approximately 17 percent were to be closed by revision of paperwork.
Of 423 areas and 331 subsystems listed for the Unit 1 Reactor Building, 317 areas and 323 subsystems had been accepted by TUEC as of July 20, 1984.
Turnover of the Unit 1 Reactor Building is still in process; consequently, the implication of a rush to complete its turnover is not supported by the actual schedule. Allegation AQ-120 was, therefore, not substantiated.
- 5. Conclusion and Staff Positions: Allegations AQ-30, AQ-31, AQ-32, AQ-36, AQ-85, AQ-86, AQ-87, AQ-95, AQ-96, AQ-106, AQ-109, AQ-116, and AQ-120 were not substantiated and have no generic implication. Although allegations AQ-35, AQ-37, and AQ-80 were not su'bstantiated, the TRT review did identify some concerns. The generic significance of these concerns is discussed in QA/QC Category 8, allegation AQ-135. Allegation AQ-34 was substantiated; however, the occurrences have been corrected, and the allegation has no generic implication. Allegation AQ-97 was substantiated; however, the occurrences were conducted according to procedure, and have no generic implications. Allegation AQ-114 was partially substantiated, and allega-tion AQ-324 was substantiated, and both allegations may have generic i implications of a partial QA/QC breakdown.
The initial NCR process was deficient in some areas; however, a number of audits have resulted in revisions to correct those deficiencies. Current procedures are generally adequate, with some weaknesses noted as indicated in AQ-34, AQ-36, AQ-97, AQ-114, and AQ-124.
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In a meeting with the allegers on Decen.ber 10, 1984, the TRT presented the result's of its assessment of allegations AQ-31 and AQ-80, including the TRT conclusions. A brief discussion followed. There were no major disagreements or concerns, and no new allegations were identified. Addi-ionally, the results of allegations AQ-95, AQ-114, AQ-116, and AQ-120 were transmitted by letter to the allegers. Other allegations in this category were obtained from sources other than allegers, and a closecut meeting was not required.
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- 7. Attachments: None.
Reference Documents:
- 1. Procedures: (a) TUGC0 CP-QP-16.0, Revs. 2, 12, and 14, "Nonconfor-mances"; (b) B&R CP-QAP-16.1; Rev. 21, " Control of Nonconforming Items"; (c) TUGCO, CP-QP-17.0, " Corrective Action"; (d) TUGC0 CP-QP-18.0, Rev. 19, " Inspection Report"; (e) TUGC0 CP-EP-4.6,
" Field Design Change Control," Revision 10; (f) TUGC0 CP-SAP-16,
" Test Deficiency and Nonconformance Reporting," Revision 8; (g) TUGC0 CP-EP-4.7, " Control of Engineering / Design Review of Field Design Changes"; (h) TUGC0 CP-EP-16.4, " Protective Coatings Exemption Log";
(i) B&R CP-QAP-11.1, " Fabrication and Installation Inspection of Com-ponents, Component Supports, and Piping"; (j) B&R CP-QAP-12.1, "ASME Section III Installation, Verification, and N-5 Certification."
- 2. B&R NCR Log.
- 3. TUGC0 letter TXX-4180, dated May 25, 1984.
- 4. NRC Inspection Reports 80-22, 83-34.
- 5. N-5 Data Reports: VA-1-34A, SF-1-38A, DD-1-45A, CH-1-05A, CH-1-27A, CC-1-58A, and related flange travelers.
- 6. CMCs: 5301 through 5343, 57051 through 50775, and 86551 thronob 86575.
- 7. DCAs: ' 10763 through 10775, 11620 through 11645, and 16301 through 16342.
- 9. B&R NCRs ( ASME) (Ref. CAR-541):
M-2234 M-2239 M-2316 M-2318 M-2248 M-2263 M-2322 M-2324 M-2265 M-2277 M-2325 M-2326 M-2281 M-2283 M-2334 M-2338 M-2289 M-2292 M-2341 M-2346 M-2294 M-2296 M-2347 M-2352 M-2297 M-2298 M-2354 M-2359 0-189
M-2300 M-2303 M-2361 M-2362 M-2308 M-2312 M-2365 M-2366 M-2840 M-14222 M-12163 M-2846 M-2658 M-12354 M-13788 M-2627 M-2577 M-12305 M-12306 M-2523 M-12382 M-2837 E-1905 M-11652N through M-11681N M-1135N and M-11687N
- 10. TUGC0 NCRs (Non-ASME):
E-81-01573 E-81-01536 E-81-01483 82-0001 E-81-01456S E-81-01393 E-81-01286 82-0002 E-81-00061 I-84-00378 I-84-00341 82-0003 I-84-00284 E-84-01688 M-84-01602 82-0004 I-84-014425 C-84-01374 E-84-01339S 82-0005 E-81-00027 E-81-00024 E-81-00144 81-0001 E-81-00178 E-81-00195 E-80-00086 81-0002 E-80-00143 E-80-00162S E-80-00228 81-0003 M-82-02395 M-82-02399 M-82-02385 81-0004 M-82-02360 E-82-02347 M-82-022755 81-0005 E-82-02203S E-82-02153 M-82-021385 E-83-03152 M-82-02113 E-82-02078 M-82-01131 E-83-03128 M-8201055 M-82-00953 M-82-00910 E-83-03075 M-82-00807 E-83-02730 E-83-03036 E-83-03003 M-83-02736 E-83-0265L E-83-03005 M-83-02738 E-83-02652 E-83-03008 M-83-02725 E-83-02653 E-83-02902 E-83-02732 E-83-02654 I-83-02853 E-83-02703 E-83-02628 M-83-02847 E-83-2692 E-83-02620 i
E-83-02830
- 11. TUGC0 Memorandum TUQ-1559, " Documenting Nonconforming Conditions."
- 12. B&R Memo to all Foremen, dated Feburary 23, 1983.
- 13. 63 Unsatisfactory Inspection Reports.
- 14. 42 Test Deficiency Reports.
- 15. TUGC0 Turnover Status Report for week ending July 20, 1984.
- 16. A-47 Affidavit, p.15 and 16, July 16,1984 (AQ-114).
- 17. A-5 letter, dated March 7, 1984 (AQ-31).
- 18. GAP letter, dated March 19, 1984 (AQ-30) (AQ-80) AQ-85) (AQ-86)
(AQ-87) (AQ-95) (AQ-96) (AQ-97).
- 19. Region IV Report 4-83-001, p. 20, dated August 24, 1983.
- 20. A-5 Interview, p. 28 through 31, May 18, 1984 (AQ-120).
- 21. A-1 Statement #2 (AQ-116).
- 22. A-1 Interview, August 1, 1984, pp. 71-79 (AQ-116).
- 23. Region IV Report 4-84-006, dated March 7, 1984 (AQ-37 and AQ-35).
- 24. Region IV Report 4-83-013, dated November 3, 1983 (AQ-109).
- 25. Special Review Team Report of July 13, 1984 (AQ-124).
- 26. Transcript of TRT A-1 and A-5 interviews, dated December 10, 1984, beginning on pages 139, 148, 154, and 161.
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- 8. This statement was prepared by: As M Owid
'T. Curry, TRT U
/e[6.[,PS Date /
Technical Reviewer Reviewed by:
H. Livermore 44A S 1[
Date Group Leader Approved by:
V. Noonan Date Project Director t
9 1
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