ML20198D627

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Partially Withheld Assessment of Allegation AQ-132 to Allegation Category Qa/Qc 7, QA Implementation Re Util QA Audits & Auditors Not Independent of Area Being Audited & Audit Rept Changed to Reflect Mgt Wishes
ML20198D627
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 06/07/1985
From: Livermore H, Wenczel V
NRC, NRC - COMANCHE PEAK PROJECT (TECHNICAL REVIEW TEAM)
To:
Shared Package
ML20198C597 List: ... further results
References
FOIA-85-59 NUDOCS 8605230339
Download: ML20198D627 (4)
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Text

1. Allegation Category: QA/QC 7, QA Implementation

2. Allegation Number: AQ-132
3. Characterization: It is alleged that Texas Utilities Electric Company (TVEC) QA audits and auditors are not independent of the area being audited and that the audit reports are changed to reflect what management wants them to state.
4. Assessment of Safety Significance: In assessing this allegation, the NRC Technical Review Team (TRT) compared the TUEC quality assurance (QA) manual, Section 19, " Audits," against the Final Safety Analysis Report (FSAR) com-mitments in Chapter 17 for establishing an audit program for Comanche Peak Steam Electric Station (CPSES). The TRT also reviewed 6 implementing pro-cedures (Reference 1), which were established to ensure the independence of the TUEC auditors from direct responsibilities in the area being audited, and 23 TUEC QA audits of CPSES construction activities (Reference 2).

The TRT was able to identify audit TCP-66 as the original basis for the allegation. The alleger had referred to a " God Squad" which ir,vestigated an audit. The term " God Squad" was used to identify a TUEC special review team that was directed to investigate audit TCP-66.

The TRT reviewed the report of the TUEC special review team. The indi-viduals on the TUEC special review team were from TUEC engineering and administrative services; they were not QA auditors. This special review team was requested by the vice president of nuclear operations to act as an independent third party to investigate rumors of a coverup in QA activities. They were directed to review the TCP-66 audit file and inter-view the personnel involved. The TRT reviewed the special review team's report, " Report on Allegations of Cover-u'p and Intimidation by TUGC0 [ Texas Utilities Generating Company] Dallas Quality Assurance," which evaluated the conduct of TCP-66 and its final published audit report. Included in this report were methods of review, the history of TCP-66, and the results of the review. Based on TUEC's special review team assessment, the report concluded that there was "no evidence to support either an allegation of coverup or intimidation" for changes made to TCP-66 by QA management.

The TRT reviewed the audit file for audit TCP-66, which was performed by two TUEC QA auditors from February 7 through March 22, 1983. The audit file contained the final audit report (May 3,1983), the initial audit report (April, 1983), which was prepared by the acting team leader, with comments by the QA supervisor, and a copy of the acting team leader's dissenting opinion memo (April 29, 1983). In the dissenting opinion, the team leader stated that major revisions made by the QA supervisor resulted in a different representation of the findings than that identified by the audit team.

The TRT reviewed the initial audit report, which contained errors and redundant and subjective comments. The TCP-66 subject, " Radioactive Waste Management Systems," was audited using the incorrect requirements, which contributed to the confusion of the audit team and led to the poorly written initial audit report. Although the TCP-66 audit team members were quali-fied to existing TUEC procedures (Reference 1), a review of their past

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experience (Reference 3) showed that one had only minimal technical experi-ence in the activities being audited. Under these circumstances, the TRT found that the revisions made by the QA supervisor were justifiable and appropriate. Rewriting of audit reports by management in cases of disagree-ment is permitted according to the guidelines defined in TUEC memo QTQ-435, dated September 9, 1983.

The audit TCP-66 team members were unavailable for TRT interview during the time the TRT was on-site, because both had voluntarily terminated their employment with TUEC 4 months after the audit. TRT members participated in an interview with one of these auditors on November 28, 1984. This interview did not alter the TRT's conclusion concerning the revisions to the audit made by the QA supervisor.

As noted above, the TRT reviewed 23 audits of CPSES construction activities.

The TRT noted that at the time of peak site construction there were only four QA auditors. A further TRT review of personnel records revealed that only one of the four had a bachelor's degree in a technical field.

The job functions of audit team members, other than QA auditors, were

, reviewed by the TRT to determine their independence from the activities they 4

audited. The results were inconclusive because the extent of participa-tion of the various members, particularly the contributions made by tech-nical advisors or observers, was not well-defined; specifically, no pro-cedures defined participation guidelines, nor were guidelines or explana-tions provided in audit files. For example, TUEC audit teams frequently included quality engineering site surveillance personnel. A TUEC QA super-visor admitted that site surveillance personnel could be on TUEC QA audits of areas where they had previously performed surveillance.

The TRT reviewed TUEC organization charts which indicated that the QA func-tion was independent of construction activities. However, TRT interviews with TUEC QA management and reviews of audit reports prod 0ced no evidence of independent management audits of the TUEC QA function. Such audits assessed the site QA program including QA organizational independence from construction. TUEC QA management has recognized the need to meet require-ments for independent audits by membership in the Joint Utility Management Assessment (JUMA), a group established to assess the QA programs of member nuclear power plant owners. TUEC's first JUMA review is scheduled for the spring of 1985.

5. Conclusion and Staff Positions: The TRT substantiated the allegation to the extent that a QA supervisor had rewritten TUEC audit report TCP-66.

However, after an in-depth review of the report, the TRT concludes that the basis for the rewrite was appropriate.

The TRT finds a weakness in the qualifications of the TUEC audit personnel in that they had only minimal technical education and experience.

Based on interviews with TUEC QA management and reviews of QA audit reports, the TRT concludes that no independent management audits of TUEC's QA program at CPSES were conducted.

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In a meeting with the alleger on December 10, 1984, the TRT presented the results of the assessment of the allegation and the TRT's conclusion.

No new concerns or allegations were identified.

7. Attachments: None.

Reference Documents:

1. Procedures: DQP-CS-4, Rev. 10; CP-QP-19.0, Rev.2; CP-QP-15.7, Rev. 2; DQI-CS-4.6, Rev. 7; CQP-CS-1, Rev. 1 and Rev. 2; and CP-QP-3.0, Rev. 15. .
2. TUGC0 QA audits TCP-1, 2, 3, 4, 6, 17, 23, 24, 34, 39, 40 41, 43, 46, 56, 66, 67, 68, 74, 81, 97,101, and 111.(inprocess).
3. Training records for selected individuals.
4. AQ-132: A-5 interview, August 2, 1984.
5. TUGC0 office memorandum QTQ-435, dated September 9,1983.
6. A-5 closeout interview, December 10,,1984, pp 173-176
7. In camera deposition, Docket No. 50-445/50-446, Exhibit 39-1, dated July 10, 1984.
8. TUEC QA Manual and procedure CP-QP-19.0, Rev. 2, " Audits."
9. FSAR Chapter 17.
10. Manuscript of interview with TCP-66 auditor, November 28, 1984.
8. This statement prepared by: [I V. L. Wenczel, TRT Date Technical Reviewer Reviewed by: v MDLua46 b E [

. H. Livermore, Date

  • Group Leader Approved by:

V. Noonan, Date Project Director 0-255

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