ML20205C568
| ML20205C568 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 09/16/1985 |
| From: | Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY |
| To: | Bloch P, Johnson E, Mccollom K Atomic Safety and Licensing Board Panel |
| References | |
| CON-#385-545 OL, NUDOCS 8509230036 | |
| Download: ML20205C568 (133) | |
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Y WOasHAx,FORSYTHEe SAMPELS & WOOLD h ""
TwsnTv-Two MyNongo 2000 emVAN TOWEm M.o.SAwatLS DALLAS. Texas 75201 g g atA.WomS~AM mos Enf A. wooLCatDat , iISM *8976 NEIL O. ANDEmSON UbbSC ENCEm C acLTEA TELEPMQNC (214) 979 3000 J. DAN SOMAN N AN JoS. imlCN WCmSM AM WD TM m. JCMas so -
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TIMOYMW A. MACn ORANCH wee StraMtmo sovD e*An n n, WAS EM ChmisTonMgm m MikTENegnogn "U'"SC swAO!" Septeraber 16,1985 EICManD o eeoont CECEuaJ.BaumEn Peter B. Bloch, Esquire Dr. Kenneth A. McCollom
- Chairman Dean, Division of Engineering, Atomic Safety and Licensing Board Architecture and Technology U.S. Nuclear Regulatory Commission Oklahoma State University Washington, D.C. 20555 Stillwater, Oklahoma 74074 Elizabeth B. Johnson Dr. Walter H. Jordan Oak Ridge National Laboratory 381 West Outer Drive P. O. Box X, Building 3500 Oak Ridge, Tennessee 34830 Oak Ridge, Tennessee 34830 Re: Texas Utilities Electric Company, et al.
(Comanche Peak Steam Electric Station, Units 1 and 2); Docket Nos. 50-445 and 50-446 db
Dear Administrative Judges:
This will advise the Board and parties that Applicants have learned of three documents which appear to be withiri the scope of CASE discovery requests.
Applicants are providing these documents as a supplement to their responses to those requests. These documents are reports prepared in 1976,1977, and 1978 by the Management Analysis Company (MAC) for Brown & Root concerning the Brown
& Root quality assurance program. Only portions of these reports concern Comanche Peak. Discovery requests which Applicants believe apply to these reports are item 10 of CASE's first set of interrogatories, filed July 7,1980, and items 8 and 9 of CASE's tenth set of interrogatories, filed April 20,1982.
Applicants first learned of these reports following a recent interview of MAC by the NRC Office of Investigations on the subject of additional work by MAC relating to Comanche Peak (other than the 1978 report commissioned by Texas Utilities and previously produced). Upon learning of the existence of the reports, Applicants promptly contacted Brown & Root and obtained copies of the attached documents last month. From our review, it appears that Applicants had no prior knowledge of the reports and did not have copies of the reports within their possession, custody, or control.
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vy- Administrativa Judg:s
- September 16,1985 Page Two Applicants are fully cognizant of their obligation to provide full and comptete answers to discovery requests and to supplement their responses when new information within the scope of those request comes to their attention. As the Board is aware, as a result of the discovery in Applicants' files of the M AC report commissioned by Texas Utilities, Applicants have underway an extensive program to review past discovery requests and to search company files for responsive materials which may not have been produced previously.
Sincerelyh ,
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- Robert A. Wooldridge For the Applicants RAW /kiw Enclosures cc: Service List 4
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June 25, 1976 MAC-JPJ-0035 Mr. T.H. Gamon, fianager Quality Assurance Brown & Root, Inc. .
P.O. Box 3 "
Houston, Texas 77001
Subject:
Diagnostic Audit of Brown & Root -
Quality Assurance Program
Dear Tom:
, I am pleased to forward the Management Analysis . Company fonnal -report on the subject audit. The attached report includes a management surmfary /
which highlight: :he major audit findings.
As noted in the sunrnary, it is MAC's position that Brown & Root has a (
C Quality Assurance system in general compliance with regulatory require-ments. It is obvious from the existing system that there has been con-siderable hard work on the part of all Brown & Root management to bring the Quality Assurance program to its present state. The attached findings, however, represent . additional modifications to the program or areas that require greater emphasis in implementing existing procedures.
It is MAC's opinion that.the management and personnel at Brown & Root are very capable and knowledgeable with regard to the Quality Assurance task before them. Ilowever, a strong management program to resolve the major findings of this report will contribute significantly in minimizina the potential for design and construction problems. ,
I wish to again extend my .thanks for the opportunity to perform this ser-vice for you. I am greatly appreciative of the overall cooperation extended by Brown 1, Root. My special thanks to the assigned audit team who during the period they were assigned to this effort had to perform their regular tasks af ter hours.
Please let me know if there are any questions on the report or if I can be of further service.
Yours truly, /
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, John P. Jackson Vice President Quality Assurance Systems JPJ/djh -
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.. FINAL REPORT -
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DIAGNOSTIC AUDIT OF BROWN & ROOT
- 3 QUALITY ASSURANCE PROGRAM S
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s DIAGNOSTIC AUDIT 0F BROWN & ROOT QUALITY ASSURANCE PROGRAM SCOPE: The audit was conducted in the Brown & Root Corporate Offi'ces, Houston, Texas in accordance with the Audit Plan, Exhibit A and was set forth in a management preaudit meeting, Exhibit B.'
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AUDITORS:
Team Leader: John P. Jackson, Management Analysis Company Auditors: J. Whitworth, D&R Quality Assurance W. Strickland, B&R Construction
,0. Hanlen,.B&R. Engineering , , , ' . . . . .: . ,, _
A. Geiser, B&R Licensing G. Gibson', B&R Purchasing R. Whita, B&R Operations MANAGEMENT
SUMMARY
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Brown & Root is in general compliance with NRC requirements. There were exceptions noted, however, and these are set forth as audit deficiencies.
In addition to auditing for compliance, MAC was asked to go a step further and make observations on the effectiveness of the overall controls.
Exhibit C represen'ts a detailed report of the audit deficiencies and observa-tions. Those items identified as deficiencies are considered violations to 10CFRSO, Appendix B, NRC regulatory guides or ANSI standards set forth in the Brown & Root QA Topical Report as a connitment. -
Following is a brief synopsis of the significant items which were noted during the audit:
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Site OA Organization: It is reco inended that the ite quality assur-
'ance. organization be restructured to establish three separate QA func-u tiuns, Qnalitv Fngin,eering, inspection and Quality Systems. The present system of having quality eng'incers res' pons 1ble f6r the inspec-
._,.__,, tion activity had short term advantages in initially setting up the site QA program from the standpoint of generating procedures, instruct-
', ing inspectors and so forth, flowever, nuw that construction is under-j4 ', , - way a separation of the quality engineering function will improve the
'( effectiveness of the site QA programs in implementing a more rigorous s
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preplanning effort (see item 4 below).
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Theconstruction system of conrnunicating design information to all involved /
in plant such as suppliers, constructors, engineers, quality engineers, inspectors and purchasing agents, is now conrnuni- i
- c. 2 cat.ed on a .bi-weekly basis. This is not sufficiently current. The jd
\ proposed CRT computtrizeo" system presently underway, but not defined b[s j// iniplementa procedurally, tion.looks promising and'should be given top priority for i
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),y. N fB. Engineering is presently consnunicating engineering changes via
. ./ meetings of minutes and correspondence to and from suppliers. A p review of the system should be made with the objective of formally
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changing released design documents with approved chance notices only.
! O A well disciplined design change system will assure that two impor? [
f,f)/ f[i-tant design control objectives are realized. First, that the design p change receives sufficient review, i.e., licensing, interface, quality [4 U engineering and so forth. Secondly, that the design change is cornnun'
(# D cated on a timely basis to all that need to know.
' 3. Procurement Control:
h A.f A. Inspection planning documents which are intended to specify Brown l.
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& Root source inspection requirements are too general leaving much to
- '/ the judgment of the inspector.' <., g .,. I r.A i O B. There was no evidence of a clearly defined procedure or program for maintaining supplier inspection planning documents current with released design documents including change notices.
(- C. The present system is such that Purchasing does not formally
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.- transmit engineering change agreements to the supplier unless there
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exists a costInipit~tMt-is-recommended that. final configuration of gh k* {N 8 all procured items be as defined by contract thereby requiring formal purchasing transmittal of finalized engineering design information. #y
\ 4 it is noted that AfiSI f145.2.13 specifies that design information' and 4-$(
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design changes are to be a requirement of procurement documents. .D g,y 4 Instructions and Procedures:
A. Brown & Root has developed good procedural documents describing the methods to be used during construction. They describe how such activities as batch plant operation, cadwelding, rebar ' control, welder qualification and so forth, will be handled. These are certainly necessary to establish good control, liowever, an additional step
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will greatly improve the overall effectiveness of the construction ,,
e f fort. It is recoinnended that Brown A Root start preparation of k()b- r.'
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detailed construction and inspection planning documents unique to
// / g each segment of the work. The planning referred to is characterized ' ) "
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'1. Construction lift drawings which fully detail the design require-\'" .
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- 2. Material takeoff listings which specify all structural, electrical -
or mechanical items by drawing number, mark number and applicable revision letter to be included in a given cnnstruction lif t.
These are prepared in advance of the work and take into account , ,
such items as blockouts for equipment shortages, material substitu- '
tions, current change nutices and su forth. They are. approved by ,/
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construction engineering and quality engineering and represent. l b"'.
the inspection checklist for material acceptability. #
- 3. Detailed inspection checklists covering the specific work involved.
f The checklist makes reference to applicable drawings and specific- '
procedures to be followed. It will define clearly what is to be inspected, the method of inspection and the sequ,ence of inspection, i It specifies the accept / reject criteria for each characteristic to'- 7 be inspected and is approved by quality engineering and construction
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engineering. The completed inspection plan represents the objective
- evidence that the work was inspected.
/ The planning effort as described above is performed as a teant effort by d
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/ k the construction engineer'and quality engineer to released design docu- ,
ments a month or so ahead of the work and is updated to inenrporate latest
( design changes inmediately prior to assigning the work to the crafts.
i B. Procedural planning is not accomplished with sufficient lead time to _
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\/\ properly train and orient site personnel. This was noted 16 the' W e'a' e of piping installation, implenentation of ANSI cleaning procedures and imple-mentation of- ANS! Good llousekeeping procedures.
- 5. flonconfonning Material Control: Brown & Root presently handles procedural problems as well as design departures on the sane form utilizing the same
< general control system. This can be a problem since the design related review and approval cycles inclu. ding PSAR and flRC.r. elated concerns are, s j usually separate from tilose associated with' QA~ system deficiencies, it is therefore recommended that the nonconforming material control system
, be restricted to: '
]' ( A. Limit the DDR ~systein to design configuration departures or design
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j [0g specified process deviations only, as opposed to the present practice of listing QA system deficiencies or breakdowns on Deficier.cy and Disposi-( tion Reports (DDR's).
i m B. To redesignate the approval requirements of 00R's to the construc-l M tion- engineer, cognizant design engineer and quality engineer level as r
opposed to the current management approval chain.
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- 6. Audits: It is reconmended that Brown & Root revise their present internal j
audit systems to assure that formal reports to management state the problem g ~
and lower level management conmitment to corrective. action as opposed to the
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present system of connunicating the problem only followed by a correction action detennination at a later date. *
! 7.
' General Observation Relative to Brown & Root Procedures: ThepresentpSe-I cures read well and generally achieve an acceptable level of detail. They are defined in the Quality Assurance Manual, Quality Assurance Procedures 7
] Manual, Site Quality Assurance Manual, Project Engineering Procedures, Con-struction Procedures and Purchasing Manu.11 It was noted throughout the i audit that many procedures overlap and could be consolidated. This would 3
j aid considerably in simplifying and providing workers with a better undor-standing of the system, i t is reconmended, however, that before additional l procedures are written, that Brown /. Root top management:
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! y ; N . A. Fonnally define and establish the overall architecture for the system .
j i of p'roccdire,s and level of procedural detail that is to be established in t
the company. Such a ducument was not in evidence,
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a vehicle for policing the generation of additional This could
( be accomplished by the OM1RB or a procedural review board.
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BROUN & ROOT CORPORATE QUAL (TY ASSURANCE AUDIT PLAN
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- 1. Audit Element : Organization & Quality Program
, Objective - To review organization and Quality Program for effectiveness and compliance to the Topical Report and QA flanual, QP fi0.1 & j!
Method: A. Review total organization with T.ll. Gamon. -
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O. Interview functional managers thru audit period. s C. Review minutes of QAMRB.
Assigned to: J.P. Jackson Q.j O
- 2. Audit Elenent : Design Control p (f .
5 Objective - To review overall adequacy, effectiveness and compliance with Brown & Root Engineering and QA procedures, i Method: Randomly select five (5) design docunents from each discipline and verify the following:
A. . Classification of hardware per STP-0C-010C
- 0. Design verification per STP-0C-0080,,014B.and,015C ,
s C'. ' Interface Control per STP-DC-002C and 005F D. Design Release per STP-DC-002C and 005F
- i E. Change Control per STP-0C-012-B and 013A 1
F. Cunfiguration Management per STP-0C-004C
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Assigned to:
G. Foreign Document Control per STP-0C-004C L.A. Ashley i
A. Geisler
- 3. Audit Element : Procurement Control Objective - To review the syst.em for procurenent docunent control and con-trol of suppliers furnished materials to assure cost effective compliance with QP Nos. 4 & 7.
Method: Randomly select ten (10) purchase orders and give (5) subcontracts t and verify the following: :
A. QA. Evaluation of Supplier per QP 7
) 8. QA Review of Purchase Orders / Subcontracts p'er QP 4 '
l' C. Engineering release of drawings / specs, associated with procurenent O. Approved survey checklist for supplier per QAM 7 E. Approved Bidders List per QA!! 7 T. Formal letter from VSC per QAft 7 G. Vendor Surveillance Plan por QAf17
- 11. Source Audits (1 per year or contract interval)
Assigned to: D. Ilanlen D. Whfte
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- 4. Audi.t Element: Instructions, Procedures and Drawings ~
Objective - To detennine whether instructions and procedures or i
engineering documents exist for implementing 'the
{ requirements of Reg. Guides and AtiS! Standards.
! Method: Through review of Brown & Root procedures verify that
. AftSI and f145.2.3, H45.2.4 and fil01.4 and N45.2.5 are being implemented. -
Assigned to: G. Gibson i
J. Ilhttworth
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- 5. Audit Element: Control of Special Processes
, Objective - To verify that special process controls set forth in )
i QAM 9 are being implemented.
Method: Review QA records for.the 'following: ,,
i A. Qualifications of NDE personnel to ASilT-TC-iA *
- 8. Qualifications of Welders and Weld procedures i to ASME Sec. 9 1
I C. Procedures list for implementing cleaning require-ments set forth in Reg. Guide 1-37 & N45.2.1 *
! Assigned to: D. llanlen J. Whitworth
- s 6. Audit Elemen't
- ~ Examin'atfon, " Test'and Inspic't' ion
Objective - To verify qualification of inspection personnel per H45.2.6
, . Method: Review QA procedures to assure implementation of Reg, j
' ( Guide 1.58 and ANSI N45.2.6. Check qualification records of personnel assigned to South Texas Site j
(minimum of five (5) inspectors)
- Assigned to: D. White i
- 7. Audit Element: Control of Measuring and Test Equipment .
- Objective - To verify existance of adequate procedures to implement 2
site calibration program.
Method: Review site calibration procedures to assure system adequacy
- Assigned to: D. Hanlen
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- 8. Audit Element: llandling, Storage, Shipping and Preservation
! Objective - To determine whether procedures generally implement conmitments in the Topical Report, specifically Reg. '
Guide 1.38 and AtiSI N45.2.2 Method: Review Brown & Root systems as follows:
A. Verify in each engineering discipline that systems 4
exist for classifying hardware per ANSI (145.2.2 B. Octennine compliance to existing procedures C. Through review of procurement specifications' and
' procurement documents verify that suitable controls are imposed on supp1fers relative to shipping and preservation i
D. Verify thrnuyh review of site procedures that suitable
' contrnis exist for handling (Reference 1145.2.15).
Assigned to: D. lihite
! J. !!bitworth ..
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S. Audit Element: flanconfonning Haterial Control t
Objective - To verify that suitable controls exist to assure that f nonconforming materials are properly controlled.and dis-positioned.
Method: Auditor to randomly select ten (10) DDR's and verify:
A. Proper description of defect
, D. Determination of cause and corrective action C. Disposition of auterials is clearly defined
- D. Proper approval on each DDR 4
E. Inspection buyback of rework and repair propetly -
executed
, Assigned to: A. Geisler i J. Whitworth
- 10. Audit Element: Corrective Action
- 1 Objective - To determine if corrective action system as presently- '
- described is being implemented. And verify if separate j
' systen for corrective action beyond that set forth through nonconfonnance reporting and audits is necessary.
Method: Review corrective action system as defined in QAM 17 and 4
verify implementation. Review with responsible nanagement
. to verify if separate system is warranted.
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- 11. Audit Element: Quality Assurance Records
(' Objective - To review the QA records system as defined in D&R procedures and detennine if it effectively implements.
AfiS! il45.2.9 as required by Reg. Guide 1.88 Method: Procedural review and verify implementation compared with requirements of N45.2.9 -
Assigned to: L. Ashley '
- 12. Audit Element: Audits Objective - To verify effectiveness of audit system and compliance i i
- with f145.2.12 Method
- Review audit system and randomly select ten (10) audits to: -
A. Verify qualifications of lead, auditor and auditor _
i per D&R qualification requirements
- 0. Verify compliance of selected audits with guide-
, lines of f345.2.12 C. Verify dates of audits relative to planned audit sr.hedule D. Review effectiveness and timeliness of corrective action responses.
E. Evaluate effectiveness of overall systen, make recomendations as applicable Assigned to: G. Gibsun i
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MINUTES OF EXECUTIVE PRE-AUDIT MEETING
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MAY 3, 1976 ATTENDEES: J.K. Bishop - Sr. Vice President. Operations L.A. Ashley - Sr. Construction Manager D.II. Hanlen - Engineering 0.E. tiewton Vice President, Purchasing '
T ll. Gamon -
Quality Assurance tianager R.A. Romeo - Quality Assurance J.B. Loth -
Quality Assurance R. White - Operations O!SCUSSION:
Mr. Gamon introduced John P. Jackson of Management Analysis Company to the attendees. lie pointed.out that the purpose of this audit was two fold:
A. To perform an in-depth review of the Brown & Root Quality s Assurance Program to determine adequacy with respect to- '
neeting the requirements of NR' and industry regulations.
B. To evaluate effectiveness from the standpoint of producing
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quality work at a reasonable cost.
Mr. Gamon further indicated that Mr. Jackson would.be working with.a team of Brown & Root Auditors selected from Engineering, Purchasing, Construction. Operations and Quality Assurance.
Mr. Jackson spoke briefly indicating his general plan to perform the audit as follows:
- A. Review the Brown & Root Procedures in detail initially.
B. Based nn the review and discussions with cognizant persor.nel,,
develop an audit plan.
C. Briefly indoctrinate personnel on audit methods and conduct.
D. Conduct audit.
E. Provide an initial exit interview.
F. Submit fonral report.
The n:ecting conclueled with all present expressing their intent to fully cooperate in the perfurmance of the audit effort.
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EXil! BIT C
. AUDIT DEFICIEfiCIES. 00SERVATI0ftS Af10 REC 0ftiCNDATI0llS
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AUDIT EU.f1EtiT: Organizatian f. Quality Program
--AUDITOR: John P. Jackson SCOPE OF AU0lT: The Brown & Root organization was evaluated against existing regulatory requirements for Quality Assurance organization and for compliance with Quality Procedures 1 and 2 of the Brown 1. Root Quality Assurance Manual and the Topical Report. The audit consisted of a review of existing organiza-tion charts and procedures and interviews with the following personnel:
- 1. T.H. Gamon, QA lianager -
- 2. F. Knapp, Procurement Manager, Power Purchasing Department
- 3. D. Olver, Nuclear Plant Engineering Manager
- 4. L.A. Ashley, Senior Manager, Nuclear Construction
- 5. J. Loth, QA Spec.ialist Supervisor 2
- 7. M.W. Hudson, Vendor Surveillance Supervisor
- 9. R.A. Romeo, QA Staff Engineer-
- 10. 11. Sampson, Civil QA Specialist
- 11. J. McKee, Hech. QA Specialist
- 12. F. Anderson, Elect. QA Specialist
- 13. D. Hanlen, Staff Engineer (Engineering) 14 G. Bulcken, Audit Supervisor . , , .... e. ,,. ,,
AUDIT DEFICIEtiCIES: fione OBSERVATIONS & RECCMitENDATIONS':
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- 1. QAMRD: Define the purpose of the QAMRB. There seems to be inconsistency between statenents in the Topical Report concerning the QAliRB Reference ~ .
17.3 and 17.2.2.7. It is recouinended that the Board function as an advisory or informational type board for the. purpose of creating executid A-awareness of QA status or problems. Such a board should have minimum '
involvement in decisions on hardware, corrective action, procedural chanors and so forth. These are best handled through direct line managenent cont rol
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[ to assure rapid fire action. The need to move quickly on such decisions will be of prime importance in the' day to day construction of a nuclear f,f plant. .
respect to inspection personnel reporting to Quality Engineers would strengthen the Quality Assurance planning effort. In the manufacturing industry as well as at many nuclear construction sites it has been demon-strated that a more effective QA program can be realized if the inspecten .
are in a separate organization from Quality Engineers. The advantages or having the inspection and quality engineering functinns independent are
- a. Inspectors will have greater freedom to challenge unclear accept /
reject criteria established by an ambiguous design requirement.
A quality engineer will frequently recognize a prnblem but due to s
the press of schedule nr his personal desire not to push a claritii i (y' tinn type chanue notice thru the desiqn engineer will prefer to I.s e
, ,y, g the easy way out by passing the prublem on to inspection. A strom
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- t independent inspection force under an inspection supervisor will generally result in greater engineering involvement in construt -
tion problems resulting in better inspection planning and greater s
( conformance of work to .the design,
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- b. An additional value is the versatillty of being able to shif t inspectors from one discipline to the other depending on the work. load. A mechanical inspector can be used on such work as rebar cadwelding and conversely a civil / structural could of ten be used 1.n the receiving inspection or installation of mechanical components. -
- 3. There appear to be a few gray areas as to the role of the hone office quality engineering specialists. Opinions of three interviewed varied with respect to prine responsibilities for site inspection planning, vendor inspection planning, interface with engineering on desigu ..
matters, interface with suppliers or subcontractors on quality engineer-ing problems and so forth. The. following division of responsibility between site quality engineers, hone office quality engineering spe-cialists, vendor surveillance personnel and others in QA is probably intended but perhaps needs to be reiterated.
- a. Site quality engineers be given full authority to generate
, change requests and coordinate directly with design engineers on all aspects of^$ite~ activity -that rdlate to QA. They would further be responsible for preparation and approval of all site
-inspection planning docunents with only the following restric-(
tions:
- l. They must use standard Brown & Root forms.
- 2. The basic approval cycle set forth in the,QA Manual must
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be followed as a minimum - additional approval dictated by the customer 'are, of course, mandatory. ,
- 3. Unique site planning documents such as tendon installation procedures, rebar control, concrete controls, etc., shnold be distributed to either sites for infonnation only. Other
. sites should be permitted flexibility within the restraints of I and 2 above.
- b. Hone office quality engineering specialists be responsible for:
' 1. Front end quality engineering input to design documents.
. After documents are released for construction, the site.OC in conjunction with construction origineering and design engi-neers has cognizance over approval of changes and nonconfur-mance reports.
- 2. All quality engineering associated with procured hardware and engineered equipnent. This wonid include review of desion documents, review of supplier bids, QA review and approva l along with engineering of supplier change requests and non-roninrmances.
- 3. Preparation of all inspection planning documents associated with procured hardware.
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- c. The supplier inspection organization would be responsible for:
- 1. Inspecting to planning generated by the Quality Engineering
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specialist.
Performing all routine preaward supplier evaluation. ,
- 3. Review and final acceptance of all QA records prior to shipment when source inspection is specified.
- d. Retain a Quality Systems Organization responsible for: ,
- 1. flaintenance of QA flanuals, Topical Reports, etc. k
- 2. Control of Ilome Office record retention
, \M p rf 4 All-QA Training 7
l
- e. Retain the present organizational alignment whereby Qualit~y System *.
auditing reports directly to the QA Manager. 1
- f. Retain home office project engineers who report functionally '?
to the Site QA Manager but act in an interface and coordinatio,n ,
role at the home office. Primary customer contact for the pur-pose oi policy setting, corrective action, IIRC audits or licensing must be through the Site QA Manager and Brown & Root Corporate QA Manager. It should be clearly understood that the home office project engineers use the line organizati.on, i.e n a customer.
problem related to proc' ured hardware should be coordinated and resolved by the cognizant engineering specialist.
- 4. Brown & Root has defined their QA program in many procedural documents -
( the QAM (ASME) the QAP, Site QA Manual, Project Engineering procedures.
Construction Procedures, and Purchasing Manual. It is recommended that Brown & Root freeze for the time being all procedure writing and establis:
at area tohigh be level of management, utilized in the conductthe overall architecture of business. This' policyofdocument manuals that , 'pi -
should address' the allowable level of detail and pro'cedui~al3Gance that is to be formulated within the company with tight controls to assure that the policy is enforced.
It was the opinion of the audit team thac many procedures were too detail
^
and often duplicated procedural guidance s'e,P, t forthA-in other manuals.
- 5. It was generally observed in discussionswith QA En'ingering g Specialists that there existed a lack of awareness'of overall status of the nuclear jobs with respect to Brown & Root's contracts, type of subcontractor QA programs, schedule status, staffing plans at the work sites and so forth.
It is recognized that many of the employees are new - 3 months to a year However, even within a few months they should be generally knowledgeabh of the construction status regarding contractors, schedule and general planning. Such knowledge will make them more schedule consciuus, feel a part of the team and in general create a thinking envirunment of plane action, rather than reaction to site problems.
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l AUDIT ELEMENT: Design Control '
. -AUDITORS: A. Geisler, W.C. Stickland i
SCOPE OF AUDIT: Approximately five design docunents were selected from each p discipline and reviewed against the requirements of procedures STP-DC-002C,
-004C, -005F, -0080, -101C, -012B, -013A, -0140 and -015C.
P i -
AUDIT DEFICIENCIES:
bip,
- 1. Section 3.3 of the QA Plan specifies that the design input d0cument t is the System Design Description (S00). ANSI N45.2.ll.74, Sec. 3.2, specifies the areas of consideration for design inputs. STP - OC-007f, I / g )s Procedure for Preparation and Control of S00's, does not provide suffi- {
cient description of 500 content requirenents to assure that the design i
, input criteria of AHSI N45.2.ll-74 are adequately documented in the 50ll'r. *
- 2. Section 5 of ANSI N45.2.ll-74 requires external and internal interface
! control of design documents. This standard requires that interfaces be
=
, identified in writing, that responsibilities of organizations be defined and documented, that nethods be established for cousnunicating desian in_
formation, and that procedures be established to control the flow of desi information between organizations. The QA Plan and the existing STP engi s neering procedures assign the initiative for. def.ign interface-control'to
- the cognizant discipline Project Engineers'. No STP procedures exist rega-j ing methods of controlling design interfaces etener internniy between di
- plines or externally with the clienthaa venmu , equipnent vendors or
- , g
+ [ con tractors. This is of primary concern in assuring.that 500's, specifica !l tions, drawings and other design documents receive a timely, complete and !
controlled inter-discipl'inary review both inte.rnally and externally.
- 3. Codification as described in STP-0C-010C Procedure for Codification is no' being unifonnly followed on numbering of SDDs. Addit'f onally numbering of drawings is not in accordance with the drawing codification system as spc-fled in STP-DC-010C and req'uired by STP-DC-0020, Drawing Control. The problem was noted largely in the area of Quality classification.
4 One of the key elenents of a good design control system, that is essentia; in implenenting the Quality Assurance program is a well . disciplined sys te'-
of consnunicating the current plant configuration to all , concerned functit.-
! To accomplish this there must exist a system for readily ascertaining the 2
current drawing revisions and applicable changes. The present scheme of issging a ljstino every two weeks is inadequate as the number of design changes, 3 to 6 per day, will reTiTdF3uch a listing obsolete the day it. i
{
, received. The enrrent system of utilizing the CRT computer generated con '
trols holds great promise if properly developed. Future developmen t e.hou-take into accnimt suitable indenturing (Christmas tree breakdown) of *,r.1- I
- assembly and subassemblies to some workable level of detail.
~
c It was noted that DCN's against construction drawings issued as early .n 4 27-76 and 5-10-76 were not entered into the computer control system on the day of the audit 5-19. failure to conmunicate design changes to all persons associated with the project on a day to day basis will assuredly result in cnnstruction or manufacturing errors.
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- 5. Topical Report HAR-002, Qnality Assurance Program, Section 17.3.2, speci-fi'es that routine design reviews are perfonned on design activities and perfonnance trends. This type of design review is interpreted as being
( a coumitment over and above the normal design review, coinnent and verifica 1 tion' process directed at industry wide design problems or B&R experiences.
No documented evidence of this type of design review appears to be availab i Additionally, ANSI N45.2.ll-74 Section 2.2 (14), requires that procedures be employed for assuring operating experience reports are available for cognizant design personnel. Operating experience is a valuable tool in designing a current and reliable nuclear plant. B&R engineering subscribe
- to the. Nuclear Power Experience Report and receives monthly Npdates descr ing recent operating plant occurrences. No fonnal procedure exists withi- gg engineering to assure that they. systematically review these operating oci
- g ences to determine corrective actions for the design of the B&R plants to assure against similar occurrences in their operation. .: ,
- 6. A review of two safety related specifications indicate that changes tn tb design are. made by nemo from the project engineer to the supplier. There was no evidence of approved change notices. This is in violation to AUSl N45.2.13 para. 3.2.2 which requires all technical changes to be contrarto ~
g requirenents of the purchase order. It is reccianended that B&R initiate i disciplines within Engineering to assure that all released design documen {;
are changed with approved DCN's in lieu of internal and external memos.
~
OBSERVATIONS & REC 0l'NENDATIONS:
- 1. During the course of the audit in Document Control Center, too of ten doce
(. ments which the auditors were interested in reviewing were at microfilmio The microfilming process can cause docunents to be out of DCC for approxi /
mately two weeks. Consideration should be given towards retaining a duplicate copy of documents sent -to microfilm in DCC to assure their recn.
are complete at all times.
i 2. Existing design control procedures, in the aggregate, read quite well and exhibit continuity in describing the B&R system. In many cases, however, design documents reviewed during the audit were not in compliance with the existing procedures. Ilowever, they-were in complianc3 with procedures as they existed at the time the design document was generated. This is t.on-i fusing to an outside auditor (whether it be this audit t.eam, the Client or the NRC) and causes difficulty in attempting to trace the development of design documentation. In discussions regarding procedures with project' engineering personnel, the largest conanent received was that the proceduie-were " moving targets" which were continuously being revised and in son.e cases backfitted to existing design documentation. Consideration should !"
given towards freezing the present design control system and chanqing only 'f if a cost / benefit or value/ impact study dictates that major procedure ,
revisions are necessary for the South Texas project.
- 3. The functions of preparation, issuance, distribution, storage and control of original engineering drawings are assigned tu each engineering discipli.
Supplementary procedures to Srp-DC-0020 describing the necessary controls he imposed un each discipline are necessary to a*.sure unifnnuity in handlit n desinn documents. Unifonn draf ting standards for all discription<, shnnld imp len.cn ted. . - . . . .
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44 The following items are procedural problems:
'" a. Many of the STP Cngineering Procedures are issued for " interim
( use". The " interim use" designation should be avoided if the procedures are issued and are in use on activities of a safety 3, related nature. This is particularly so in the absence of a definition for " interim use",
- b. Many of the STP Engineering Procedures are issued without effec-tive dates. #
- c. Drawing Acknowledgement Fonn (Figure 1 of STP-DC-002C) has been superceded by Form 200.57 (Figure 6 of STP-DC-011A).
- d. The following connents specifically relate to STP-DC-005F, Procedure for Preparation and Control of Specificationsh .
- 1. Proje'ct Licensing Engineer should be specifically defined as a required reviewer and conmenter on all safety-related specifications during the internal review process and prior to release to the client.
- 2. All specifications should receive an interdisciplinary review at B&R prior to release to the client; i.e. client should be removed from distribution of preliminary specifications.
~. '
3 .. Procedure requires that Completed, Form 20049 Purchase.0rder
' Special' Claus's e Dbcumentation' and Drawing Requirements, accom-pany the specification during the review, connent, verifica-tion and approval process. This apparently is not being done.
( 5. Procedure STP-DC-013A, Document .Ch'ange Notice Control, describes the methods for controlling changes to design documentation. Form 200.29 Document Change Notice, requires a listing of "other documents affected" by the described change. The form should be revised to require a specific evaluation of all docunent change notices against the PSAR J and construction permit conenitments not only by the cognizant engineer /3 but also by including.l.icensing on approval of such changes. -
- 6. Procedure STP-DC-023A, Field Requests for Design Chang'es, describes the nethods for controlling design changes requested from the construc-tion site. Form 200,61, Field Requested Design Change, is initiated by Construction and transmitted to engineering for action. Engineering receives Fonn 200.61 and transfers the infornation to ronn 200.29 Docu-nent Change flotice. Both fonns appear to re. quest similar. information, y, The process could be expedited by climinating Form 200.61 and requiring a construction to initiate Fonn 200.29 for Field Requested Design Changes.
- 7. The Engineering functions for STP appear to be following a well estab-lished set of procedures for design s.ontrol. Ilowever, other engineerio functions are nccuring within the nuclear department on generic /
standardized designs which require equal design control neasures as the STP engineerinq functions. Assurance is necessary so that this generic / /h standardized engineering desfgii IuTictions are aceting the AriS! tMS.2.ll."
requirements for design control. WIthout appropriate design control measures now, the ability of using this design effort on future applica tions nuy be limited due to lack of traceable design control documentati<
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8.1 Brown 3. Root presently use a docunient ' change notice fonn to change procedural documents as well as design docunents. Since the coordina-tion, revit:w, approval, NRC safety considerations and type of usage
. I and schedule demands are usually quite different for procedural changes than they are for design changes, it is recornnended that a unique fonn be used for all design changes. By using a unique change
, fonn all design documents which relate to plant configuration and ,
cone under ICCFR50 Appendix 8 and ANSI N45.2.ll.will be readily recog-nizable as design docunents and can be covered under the same system of controls and distribution.
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AUDIT ELEMENT: Procurement ' Con trol
( - -AUDITORS: D. llanlen, D. White SCOPE OF AUDIT: Approximately 5 P.O.'s and 5 subcor'1 tracts were selected and Y.
viewed to determine compliance with Quality Assurance Procedures Nos. 4 and gf AUDIT DEFICIENCIES:
- 1. The inspection planning d'o ctmients do not define the specific inspections
'b to be accomplished at a suppliers plant. This appears to be the intent I' of the' procedure. The inspection plans for the liner and tendons, howevei left important. inspection decisions to the judgement of the inspector. >
This can result in safety related characteristics being missed byvinspec- i --
tion since it often happens that the safety related design characteristic are obscure to one not familiar with the safety functions of the equipmen'
- 2. It was detennined in interviews with those responsible for preparation of inspection planning documents, that safety related characteristics will be sampled (example; review of liner radiographs). Random selec-tion or sampling of safety related characteristics should be accomplished
'. only upon well-documented quality history and approved sample plans. Thi-was not the case ~as verbally st'ated or as specif~i'ed in th'e' approved liner inspection plan. . It is to be noted, however, that the inspector h'as reviewed the few radiographs to date.
( 3. .There was no program written or in operation to assure that inspection planning documents are maintained current with design. changes. This can 4 g,(
result in hardware shipped to the site to an obsolete configuration.
OBSERVATION & RECOMMENDATIONS.
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- 1. It was detennined tha't designers frequently communicate "no cost" changes to suppliers Purchasing as directly. Suchcontractual a subsequent changeschange.
are normally not controlled throughIt is design drawings and specifications or changes thereto be handled between 's B&R Purchasing and the supplier so that the end product can be defined in a drawing list as part of the final purchase order. "No cost" changes fr.
.. a supplier standpoint could represent significant cost to B&R at a constri tion site, as in the case of a modified weld prep angle or equipment wi U modified hole mounting geometry. Proper controls dictate that final prod-configuration should be defined by contract.
- 2. It does not appear that there is a central filing system which provides effective access to the major elements of procurement activity. Signi fic h
.s portions (overlappings) were found in U?.R Purchasing, South Texas Project Document Control Center, and in BAR Quality Assurance. Each filing systei is different, including acccess logic, general orgaaization, and control.
As a result considerable difficulty was encountered in developing infunna tion on suggested and approved bidders, in establishing the responsibilit' for Source inspections.
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- 3. Approyed Bidders File: QAM-7.2 states that B< purchasing maintains such a file which includes a suppliers list approved by Engineering, Purchasing, QA and Construction (subcontracts). In fact, bidders are -l
( approved on 'an ad hoc basis for each procurement item. Little diffi-culty was encountered in establishing approved bidders' identification although there was no approved bidders list, as such.
- 4. Per QAM-7.3, Page 3 of 6, the Vendor Surveillance Coordinator is responsi-ble for the source inspection of all material or subcontractors per the manual. However, the field is really responsible for those subcontracts s Oh located at the field site. This should be clarified.
- N'# q~.
- 5. Specification 7R309 NSO46-A (Liquid Waste Processing System) was found 5 to have careful documentation of-suggested bidders. .The Quality Assur-ante file, however, did not have the complete resolutions of conments package, and in particular, did not contain the resolution of the 'com- "
ments of the Quality Assurance reviewer. The resolutioas were found in STP Document Control, but there acceptable to Quality Assurance.{s ,It no evidence that that is reconsnended theyeach weredocument found to be reviewer be made aware of the resolution of any coninents that he made.
- 6. It is reconm!nded that a Brown & Root connitment be made to a centrally le organized, controlled, and codified Lile system for each nuclear project wherein all elements of the. project can be'identifjed, traced and retrieved
~
9 with reaso'nable ease. ~This is' not a reconin~endation to disconfiriue necessary peripheral files, but rather to ensure that the peripheral files are not a necessary part of the docunentation specified by regulatory and licensing agencies.
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- 7. It is recoumended that the sources of the numerous policy and procedural requirenents related to procurement be carefully and intensively reviewed to remove ambiguities of responsibility. This activity can be separately accomplished, but it would be integral to the implenentation of a general /
reconmendation to develop a documentation plan, as previously mentioned, from a top tier generic policy through detailed standards and standard procedures for project operations.
8.
The PG1 liner file for STP was most difficult to review. Because of the importance of this item relative to future audits it is reconmended that j the file for PDM in STP-DCC be reviewed and organized to ensure that it meets regulatory and ANSI requirements.
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AUDIT ELEMErlT: Nonconforming Material Control
'( - - AUDITORS: A. Geisler, J. Whitworth l
SCOPE OF AUDIT: A randem selection of 10 Deficiency and Disposition Reports (DDR's) was reviewed to determine coinpliance with QAM 15.
t AUDIT DEFICIENCIES:
- 1. Honconfonnance reports dispositioned accept as'is or'repaif are not approved by the cognizant design engineer. Accept as is or repair
, disposition do in fact represent departures from design requirements and require coninensurate controls. It is noted that a future issue of I
j an engineering procedure STP-DC-022 will require cognizant ip engine approval, however, other documents should be revised to reflect tihis "I l requirement.
OBSERVATIONS & RECOMMENDATIONS:
I
Engineer. This approval should be relegated to a lower working level of 8
,l engineers since the day to day dispo!!ition of DDR's is most of ten a tin.e .
consuming investigative. process. By being on; distribution ,f.or. DDR's- and .
' _ receiving simanary deficiency tien'd reports, managers can be made sufficiently aware of the quality status and job problem areas without being in the
- approval chain. -
( 2. Doth QA and the group responsible for resoiving a DDR problem, should make
~
- l i every effort to expedite the fermal close-out of the DDR. Many of the STP DDR's appeared to require an u.nreasonably..long. time to ,close-out. Some 6 .,
.' current examples are: -
jn.
a.
! Report on H-7 and 10/10/75 and H-9 11/20/75, are presently respectively; open over DDR's. These ago.
6 months DDR's were issued p
- b. Report 5-6 is presently an 'open DDR. Armco Steel delivered a shipment &
i of rebar to the site on 3/15/76. Fif t.een pieces of the shipment ,t exceeded fabrication tolerances of + 1". On 3/19/76, those 15 pieces l were returned to Annco Steel and the following week, replacement rebar was delivered which met the fabrication- tolerances. .Thus, the material deficiency was corrected within ten days of idientification, yet the DDR l remains open for over two. months. -
1
' l 3. It is reconnended that the present methnd of including system and documenta-tion deficiencies on DDR's be eliminated or clearly distinguished from defi-ciencies that represent technical. configuration or process departures frr l
iF5_i Sn includ.specified ing PSARrequirements.
and URC related concerns are usually separate from thos associated with QA system deficiencies. '
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AUDIT ELEMEllT: , Control of Measuring and Test Equipment
- -AUDITOR:- D.- Hanlen
, (
SCOPE OF AUDIT: To review applicable procedures and verify that the Brown &
Root calibration program is adequately defined and is conducted in accordance with QA 11anual Procedure flo.12 and ancillary dncuments.
AUDIT DEFICIENCIES: None
- CBSERVATIONS & RECOMMEND'ATIONS
It appears that Brown'& Root calibration system is too complex. Site calibra-tion procedures are set forth in two docunents - Comanche. Peak General Calibra-tion Procedure 35-1195-lCP-1 and South Texas General Calibration Proceddt e -
A040KPGCP-5. These procedures relate to Comanche Peak Procedure QCP 1.3 Tool and Equipment calibration and Control and 5,outh Texas Procudure QCP 7.1 Tool and Equipnent calibration. All of these procedures are subordinate to QNil2 Control of Measuring and Test Equipment.
1 i
It is reconmended that 3rown & Root broaden QN412 to explain the Brown & Root system of calibration and simply indicate that each project will have a project
' - s calibration manual that maintains a listing of equipment and description of.how j the equipment is' calibrated. -The"other four procedural'documenti could then be eliminated. '
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AUDIT ELEMErlT: llandling Storage Shipping and Preservation
-AUDITORS: D. White, J. Whitworth i
SCOPE OF AUDIT: A review was made of existing Brown & Root Procedures to determine design if the requirements Procurement of AtlSI N45.2.2 were being implemented through and Construction AUDIT DEFICIEtlCIES:
1.
Early procurement specifications and documents did not impose suitable controls on suppliers in regards to shipping and preservation. A look p at four recent nuclear safety related specifications indicated that each one reference ANSI fl45.2.2 in regards to Packaging and Shipping.
It l's recoimended that Brown & Root review all purchase orders issued to date to assure that all procurement packages implenent the require- g .,
ments of AllSI N45.2.2 J,/
2.
The following construction procedures which implement the requirements of ANSI N45.2.2 are not yet released: 3
- a. MCP-10 Receipt, Storage and Maintenance of Hechanical Equipment - M .
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- b. ACP-3 General Haterial Receiving Storage and llandling issued L,_ I 12/2/74 dnes not have supplenentary data covering Pipe and Valve , "'
Warehousing which was scheduled for incorporation 1-10-76.
( OBSERVATIONS & RECOMMENDATIONS: flone O
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AUDIT ELEMENT: Instructions, Procedures and Drawings
-AUDITORS: G.Gibson, J. Whitworth
( .
SCOPE OF AUDIT: To review the Drown & Root instructions, procedures and drawings to determine specifically whether or not the commitments to specific s.tandards set forth in the topical report are heing implemented. Specifically audited were N45.2.3 Good Housekeeping, N45.2.4 Installation, inspection and Testing Requirements for Instrumentation and Electrical Equipment, fl45.2.5 Structural Concrete and Steel and N101.4 Quality Assurance for Protective Coatings Applied to Nuclear Facilities. ' '
AUDIT DEFICIENCIES: ,[
- 1. AflSI fl45.2.3 Housekeeping: No procedures have been prepared by either " ,*
the STP or Conunche Peak Projects. The STP QA procedure is currently scheduled fer release on September 1,1976. STP construction claims to be satisfying the requirements of this standard, at least in part, due to certain incorporation'of requirements in other procedures such as Warehousing and Fire Protection, g Detailed instructions and procedures, according to the sta' nard, should have been in practice for as long as construction has' been at the site. \#I *
~
- 2. Structural'Concret'eanhSteelANSI45.2.5:
- a. Cons truction procedure STP CCP-4 Para. 3.1.1 s tates: "For concrete placements of 4000 cubic yards. or greater, or where in the judgement
( of the Chief Project Engineer ---- a placement plan will be developed
and approved by the Project QA Manager before implementation."
The intent of the procedure is to assure that adequate consideration has been given to mitigate the possibility of cold joints, honeycombs or improperly consolidated concrete. The procedure as stated in. plies that on all other pours these factors can be disregarded. Since most safety related concrete will be in lifts less than 4000 cubic yards, the procedure should be modified to include ail concrete. g _
i
- b. Characterisites to inspect during placement require (LC, Inspectoi to d make many. subjective evaluations, e.g. Construction Procedure CCP-4 Para. 5.2.2 item k states: Supervision: The ()C Inspector shall ensu-that adequate Construction Department Supervision. exists on all enners placements" or Para. 5.1.2 "The following characteristics shall he in-spected before each concrete placement: Planning --- ".
- c. For safety-related concrete po.urs CP-QCP-2.4 does not address AllSI ff45.2.5 items 4 and 5 of Para. 3.'s related to preplacement require- .'
ments for concrete.
Construction Procedure 39-1195-CCP-11 " Concrete Placement" doce, not provide fur written plans or instructions which would facilitate i accomplishment of items 4 and 5: further, CCP-11 does not provide
- for advance (or post) documentation of items 2, 3, and 4 of Para. 4 '
related to many detailed inspection points for concrete placement.
- d. Sunmary Conclusinn: I! nth CPSES !. 5TP Construrtion and inspectinn Procedures detail a pour card signnf f to release a pour for concrete placement. This in itself is insuf ficient detail to meet the intent '
nf an inspectinn plan or pour plan as r"quir ed by Arn! I!45./.L. Sec.
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- 3. In addition to the lack of front end. planning on Civil Structural work
- as noted in 1 and 2 above, it was obsdeved that a similar problem exisi in the case of piping fabrication and installation. There did not ext:
( for review any procedures that define the scheme for unking isometric 1
piping drawing which indicate the compilation of vital code data such at.
assignment of weld numbers, pipe traceability and radiographic results.
It was further determined that Ccmanche Peak would start fabrication of spool pieces within the month.
- 4. Para. 2.4 of ANSI 45.2.5 requires QC Inspectors to be certified for Level I capability and on-site supervisors to be certified for Level II capa-bility, both in accordance with AflSI N45.2.6. On Comanche Peak, lesson 1
plans and examinations required to certify inspectors have not been impl. - ,
mented.
OBSERVATI0flS & REC 0tNENDAT10flS: 't **
- 1. With regard to implementation of AflSI fl45.2.4 Installation, Inspection and Testing Requirements for Instrumentation and Electrical Equipment, due to the early stage of construction existing at STP, no work is cur-rently being performed that would fall within the requirements of this standard. Both QA and Construction have scheduled the implementing procedure for issue for April,1977 and March,1977, respectively. \/
' ~
- 2. AllSI 101.4 Quality Assuran~ce fbr Protective Coatihgs AppNed* to fluc15ar Facilities CPSES Construction Procedure and the draft ZCP meet the AflSI standard '.
requirements. Coating work will not start for six months. The STP t construction procedure and inspection procedure covering protective coatings are in work.
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, e AUDIT ELEMEf4T: Quality Assurance Records
-AUDITOR: W. Strickland
(
SCOPE OF AUDIT: A review was made of the system for review, filing, microfilmin and storage of records to determine compliance with requirements of AflSI f145.2.!
and Regulation Guide 1.88.
AUDITDEFICiEriCIES:
- 1. ProceduresST-QAP-2.3,ST-QAP-6.1andST-HAP-6.2have.beendrittenand are presently used to control QA record sysum in the Houston Office and at the Construction site. These procedures require that certain records be microfilmed and stored in a remote locked location. Currently,. this is not being done due to the problems associated with the collection and '
storage of documents in the interim period awaiting. access to microfilmie -
equipment in another building. Microfilming. equipment is on order to be set up in the file area in the Houston QA Office so that records can be 4
microfilmed daily. At that time all microfilm will be stored at a reniot:
location (project constructio.n site).
- 2. All site records are stored in a locked fire proof vault constructed in accordance with t145.29 and ST-QAP-2.3.
. o -
Currently a deficiency exists in the storage facility in the Houston 13 ,,
office. Records are being stored in standard steel filing cabinets (n t i fire proof) in an open area. Access tn the files in controlled by a !ile
() clerk who sits near the files. When the clerk is absent from the pos' 4 ,
j (on this date no file clerk was on duty) the files are open to anyone in the ruom.
- 3. ST-QAP-6.1 Section 4.62 states that surveillance of access is through ,
intermittent patrolling by Brown & Root security forces. There is no ',
evidence that.this is being.done and there would appear to be a question in regard to the practicality of this.
f Plans are being made to isolate the storage area and to, establish bet ter 9 control. The files are being reviewed periodically to assure that all W"
, records are available and properly filed but no documentation of the M' review is made as required by the procedure (ST-QAP-G.1,Section 4.6.4).
- 4. ST-QAP-6.1 Section 4.7 Audits requires that the-QA file system be audited in accordance with ST-QAP-7.1 Reference 5-E. Review of ST u" QAP-7.1 failed to reveal Reference 5-E.
OBSERVATI0fl5 & RECUtt9Cfl0ATIOilS:
- 1. It is recenmended that Brown A Root retain their existing records pro-
. grani but correct the above problems and establish controls to prevent recurrence.
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h AUDIT ELEMENT: Audi ts 4
-AUDITOR: G. Gibson
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SCOPE OF AUDIT: A review was trade of selected audits to determine adherance to l audit schedule, timeliness of corrective action and effectiveness of follow-up audits.
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j AUDIT DEFICIENCICS: , , ,
- 1. QA is not adheristg to the establisi.ed audit schedule. Althougir the f :
schedule is designed to allow some flexibility, no actual control exists. In one instance, a scheduled audit has slipped by 2 to 3 months. Also of concern is the fact that there has been minimum attention directed to auditing by llouston of the site facilities. i Only one audit of each site has been made this year. Since both ',
I Comanche and STP are in an early construction phase frequent audits 6' t are essential to assure that all systems are being implenented. '
OBSERVATIONS & REC 0fEENDATIONS: j
- l. Several audits were checked and verification was made as to the qualle i a- i tions of the lead auditors and auditors. The personnel files were conplete
, .- ,. and well naintained. , . , .. .
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- 2. Corrective action responses are consistently allowed 30 days by QA. Ihis f shuuld be reduced to one or two weeks for response but, allow flexibility 9 ,
'in,the corrective acGon coiiipTeftM date. i
- 3. The present audit system results in consnunicating audit findings to top managenent prior to resolving corrective action conmitments. It is ree.nm- [
monded that corrective action be formally conunitted by a designated level t
of management, or higher if the situation warrants, prior to distribution l of the formal audit report. Top managenent will then review findings and 1 corrective action connitments together. This scheme will eliminate the .- I potential problem of top managenent inmersing themselves in the solution 8 j of a low level problem prematurely and without necessity. It is recomnende L that the audit system be modified to permit corrective action conmitnents ?
l from supervision only. A level of responsible management should he esiib- I' lished as the miiiimum level that can comnit corrective action with the audi l supervisor empowered to go to higher levels of managenent if 'the deficiency warrants.- . -
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! [ FINAL REPORT MANAGEMENT AUDIT OF THE BROWN & ROOT l 1
QUALITY ASSURANCE PROGRAM
! MAY 9 THRU MAY 20, 1977 ;
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i I MAC-77-66 June 3, 1977 l
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INTRODUCTION (b
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This management audit was conducted at the request of the 0 own 8 Root Quality Assurance Management Review Board. Its purpose was to provide an independent evaluation of the B&R Quality Assurance Program from the standpoint of compliance with regulatory requirements as mil as cost effectiveness in implementation. It is 88R's policy that such audits be conducted utilizing B&R personnel to the maximum extent practical. To this end the audit was conducted with two Management Analysis Company representatives and six Brown & Root personnel representing such organt-zations as Engineering, Licensing, Quality Assurance, Purchasing, Construction and Operations. The audit consisted of a one week audit of home office activities at Houston and one week at the Comanche Peak Nuclear Project Construction site. Additionally, two members of the audit team conducted a two day audit of Engineering interface activities **
at the South Texas Nuclear Project. construction site:
AUDITORS -
Lead Auditor -
J. P. Jackson, Management Analysis Company Auditors -
W. B. Williams, Management Analysis Company J. C. Shuckrow, BAR Quality Assurance
' A. H. Geisler, B&R Licensing -
J. H. Hobbs B&R Licensing (Part tjae)
D. F. Hanlen, BAR Engineering 7 G. A. Tell. BAR Subcontracts s' J. E. Roscoe, BAR Construction J. T. Wilbur BAR Operetions MANAGOE:NT SUP9tARY
- 1. It is recommended that 88R move ahead immediately with the establish-ment of site Quality Engieering organizations at STP and CP which are independent of Inspection but reporting along with inspection directly to the site Q. A. Manager. Abandon the proposed organizational concept whereby inspectors are assigned to the construction organization.
Reconuend that the B&R Q. A. Manager realign the present organfration i
i such that the site Q. A. Managers report directly to him with total responsibility and authority for all Q. A. functions related to a project.
, 2. Estabitsh a task force of key representatives from Engineering, Construction Purchasing, Operations and Q. A. with full management support to embark on a program with an approximate three month completion date to
! consolidate and simpitfy the structure of the Quality Assurance Manual l
(currently defined in 12 separate manuals). The target should be to arrive at a single Corporate Q. A. Manual which describes the key elements of l control utilized by 88R in implementing their Quality Assurance Program.
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consistent with the top manual thereby providing a single B&R system i
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.a(. for all projects relative to such things as design document control, purchasing control, special process control, work instructions, manu-L
, facturing control, calibration, audits, records control, etc. The
- only additional manuals required would be a Corporate Special Process Procedures Manual. ,
l 3. Q. A. Procedures, although coordinated with affected organizations, i are issued unilaterally with Q. A. approval. It is reconenended that i all future Q. A. procedures be issue 1 only with the prior approval of all organizations affected by the procedure. This policy should apply
- to all levels of procedures at the hw office and sites.
- 4. The entire area of Engineering records control and implementation --
of the CRT design information system lacks adequate discipline relative to procedural definition, maintenance of controlled input and proper raintenance of files. The net result is an engineering records control
{ system that does not adequately perform its intended function. As a i
result, the STP site has out of necessity, established an independent j system that is based on s,ite input as received from the home office, j 5. The FREA system of requesting engineering infonnation is being -
abused to permit changes / deviations without generating thg necessary DCM's. Based on the established 8&R system for design document change, formal approval of changes should be accomplished only through an approved DCN to the drawing or specification. Steilarly, the SDR j
system is abused in that they are used as approved c.hanges in Iteu of generating the necessary change notices and/or DCN's.
i 6. Two engineering procedures were observed to be deficient in that one i was expired and the other was in an "interin use" status for the past j three years.
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- 7. Changes to vendor specifications are not being transmitted to and i
acknowledged by the supplier and/or incorporated into the purchase
! order.
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, 8. A more visible and clearly identified system of defining release of design documents for fabrication or construction should be established as a universal Brown & Root system. It is reconsnended that such a l
system incorporate a readily recognizable controlled 8&R release stamp on all design documents.
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- 9. As yet no procedure exists which defines the all important function of communicating design information. If the CRT system is going to represent B&R's official design data base, it should be defined
- l procedurally.
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- 10. Checklists for the performance of source inspection by the Vendor
'. \ Surveillance Specialist (VSS) are prepared in generic fashion by the i j -
VSS. It is recomunended that checklists identifying specifically what l 1s to be inspected be prepared by the home office quality engineers in !
4 cooperation with design engineers so that important design characteristics !
j' can be identified. t i
- 11. Average turnaround time for obtaining Houston approval on STP !
construction discrepancies was 26 days for the first quarter 1977. This i
! excessive turnaround time will create difficult control problems on '
defective hardware and work as the amount of construction increases.
j 12. ' The Houston audit program as presently conducted is ineffectica.
Eight out of the 14 audits conducted during the past year are still open. .
j Some Audit Deficiency Reports are 6 to 12 months old.
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The audit program should be revamped to combine the findings and corrective action on a single audit report. Additionally, internal j system audits shculd utilize a single auditor rather than audit teams for increased effectiveness.
i 13. It is recommended that both construction and quality assurance start
] s a vigorous, fonnalized preplanning effort characterized by lift drawings.
- material takeoff lists and inspection planning unique to each Ilft or ;
p segement of work.
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- 14. The design change system of Comanche peak is extremely difficult to
- work with. The seven different change mechanisms should be replaced by one simple fonn. ,
i The failure to incorporate changes into design specifications and drawings !
- is making their intelligibility impossible. This situation if it continues !
j will most assuredly result in construction errors, i
! Average turnaround time for FI/CR's to Gibbs & Hill is averaging a month l or more.
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- i j 15. The site audit program is ineffective , i L .
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. OBSERVATIONS AND REC 0!@iENDAT10NS HOUSTON a
i Orcanization and Quality Assurance Program
- 1.
It was perceived by key' managers in the Quality Assurange organfration that salaries for Quality Assurance Engineers are too low. In support of '
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this contention, it was noted that. difficulty is being encountered in
' attempting to hire key personnel such as a level 3 NDE Engineer and a level 3 C'vil Engineer. It is MAC's experience that the 84R salary scale ;
! is low by as much as 15 to 20 percent based on today's market for expert- ;
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enced quality engineers. This situation can result in attrition amongst i present 84R Quality Engineers or increased difficulties in hiring qualified engineers. I l
j 2'. It was perceived by sever'al line su i ment response time to solving problems,pervisors thatprocedures notably in the 84R seniorarea manage-i was slow. This was supported by the fact that many of the problems noted i'
in MAC's previous audit were still not acted upon even though the managers involved supported the fact that system changes indicated in the audit were in order. Additfonally, the findings set forth under Design Control >
indicate that key procedures are still in an interim status; a further
! s indicator of slow response time on correcting system problems. As one ' !
t supervisor put it, "tw managers are too involved in day-to-day construc-tion systems."
and and engineering problems to place sufficient emphasis on procedures l
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j During this audit MAC was made aware of a change in 84R management direction reflected in the revised Topical Report whereby inspectors would be organized under site construction management rather than the
! Present arrangement whereby they report into the site Q. A. organization.
In MAC's opinion such a move would, in the long haul, prove ineffective.
This i practice was in vogue in many manufacturing companies a decade ago,
- wheresy inspectors reported to the manufacturing manager as opposed to >
the quality Assurance (Quality control) Manager. In most instances, i ;
i the inspection force, due to a lack of strong management support due to i the conflicts of schedule, cost and quellty, was rendered virtually in-j effective in implementing the necessary objective controls of acceptance, i i rejection add documenting nonconformances required to monitor quality compliance.
! As a result, one rarely sees such an orqanization today j
even in consumer oriented product companies because t simply doesn't result in good inspection. ;
88R made a progressive move amongst Architect Engineers when they assi MAC'gned the inspection function to the Quality Organization. It is s opinion that the effectiveness of the inspection is diminished '
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considerably, however, due to the lack of a separate site quaifty
( engineering function independent of inspection. This was pointed out e+- in last year's audit as a move that would greatly enhance the effective-ness of 84R site Q. A.; and although generally agreed upon by the B&R Quality Assurance Manager, was never acted upon. MAC strongly mcom- '
mends that such action be taken immediately at STP and Comanche Peak in lieu of the proposed reorganfration scheme set forth in the pending topical report.
- 4. The Quality Assurance Program as presently described in 12 different Q.A./Q.C. manuals is too complex. Serious effort should be put forth to consolidate into one manual the key elements of control for each element of 10CFR-50 Appendix 8. This can be done by noting in a single corporate Q. A. manual the procedural requirements, organizational .*
responsibilities and in many instances the key foms utilized in implement-ing the B&R Q. A. program. '
'Perfoming such a consolidation would do much in the way of eliminating redundant procedures, permitting rapid mechanisms for procedural change.
providing system visibility to all workers and providing a single '
corporate focal point for control of the quality Assurance Program.
s 5. It was observed that Quality Assurance can unilaterally issue -
procedures that can have an impact on organizations other than Quality Assurance without formal approval by the effected organization. A fN system should be established whereby fome1 approval signoff is mandatory ly all organizations outside of Quality Assurance if they am in any way effected ty the procedure. Such a system will provide the necessary dialogue and discussions between organizations and force resolution of differences prior to the issue of procedures. Such resolution may have to take place at the emoc'utive levels of management on occasion. This is, however, desirable since the final outcome represents a genuinely unified approach of all management with respect to necessary controls.
DesignandDeedmentControl
- 1. STP Engineering Procedure- STP,0C 001-0, Section 2.5; recognizes the necessity for instructions and guides issued by the Discipilne Project '
Engineer or Supervisor for intradiscipline use that serve as further explanation of the existing STP Engineering Procedures. Such instruc-tions or guides would be extremely valuable in the Engineering Document Control Center to define the functions of each clerk and the flow through OCC of each type of document. Examples of such DCC guides would be the priority of inputs into the CRT system and the utfifration of CRT system output.
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.~.~. function as document controllers not just document distributors. 1he .
l site DCC is the controlling focal point for all documentation on site.
! They control the initiation, receipt, acknowledgement, maintenance, i
distributton, superseding, dostroying, etc., of all site documentation.
. They know who initiates documents, who has documents and who needs i documents. They effectively utilize the CRT system to monttor status j
and control distribution of documents. It is recomended that lead mrsonnel from Engineering DCC review and implement (where appitcable) ;
l 4he site methods for monitoring and controlling documentation, and '
j utilizing the CRT system.
J j . 3. Design change documents will often bear identifying dates such as
- 2Y06055033-C/DCN/3-14-77, however, this date appears to bear no relation- . . .
! ship to the dates of origin or approval, 3-23-77 and 4-1g-77 in this I i case. It is recomended that design changes be identified by consecu- t j tive numbering of the change notices to the docu:nent.
I 4. Recommend establishing a single means of identifying the formal release of all design documents issued for construction or fabrication. ,
4 This method should be comunicated to all concerned. Personnel l s
authorized to release documents should be identified, i 5. Recomend that suppliers request changes or deviations for design l'
f documents by some established means. Engineering approved changes /
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( deviations be incorporated and communicated through a Change Order to the Purchase Order. This method should serve the followf.ng advantages: (
- s. The request format becomes simply a request eliminating '
any distribution or tracking problems encoun,tered by 50R's.
- b. Supplier becomes legally bound to furnishing the product as approved by BAR Engineering. (
! c. All concerned parties become knowledgeable of the design
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1 configuration through established P. O. change distribution.
l 6. Engineering Procedure STP-DC-023-D and Construction Procedures l GCP-21. Rev. 2 Fleid Request for Engineering Action, both specify i 5
that the Construction Chief Engineer may deviate from construction requirements contained in safety related documents without engineering ;
] approval provided he can substantiate such deviation and provided such j
deviations do not violate SAR comf teents. Again, this appears to be r t
another abuse to the FREA System. All changes / deviations to safety '
j related documents should be reviewed, approved and design verified by
- the same organization that originated the design. i l
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.. ; .,. i i Indoctrination and Training It was noted that there is an imediate need for a level !!! Electrical and Instrumentation Inspector at Comanche Peak; and while there is a man in training, the need for this. inspector may occur sooner than his availability since the preplanning of electrical work is imminent.
Procurement Control ,
The latitude allowed the Vendor Surveillance Specialist to estabitsh his own inspection checklist from the General Vendor Surveillance Plan i
should be discontinued in favor of a detailed and definitive checklist issued by the Q. A. Department. This will return control of vendor i
surveillance to the home office (Houston) where there is personnel **
3 much more knowledgeable of the. total requirement picture than the VSS 1
- out in the field. In keeping with greater attention to specifying
- detailed inspection plans, there should also be a mandatory review and i
update of theplan each time a drawing or specification effecting any
' purchased item is revised. It was also noted that the ability to retrieve and track information regarding a given vendor package appears
', unwieldy. A great deal of time was consumed locating appitcable
' documents as there are different files in different locations, each i
containing only a portion of the total package. *
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Audits
} The present audit system should be revised to require corrective action i
commitment prior to the issuance of the audit report. This would give top management visibility of the problem, the solution and the date it' will be implemented. A further follow up of slipped corrective action
' dates to successively higher management would dramatically reduce the lag in getting ADR's closed out and make the audit program an effective management tool.
i It is the opinion of MAC that the total of 14 audits for a year with 3 auditors available is inadequate. In MAC's experience 3 auditors should
' be able to perform 50 to 75 audits per year. These 14 audits covered 5 i at Houston (home office) 4 at the South Texas Project and 5 at Comanche Peak. It is recommended that the teams be reduced to one-man audits '
and the scope of each audit be reduced so that many smaller audits of shorter duration can be accomplished giving greater flexibility and concentration in potential troublo spots.
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- d:= COMANCHE PEAK Organfration and Quality Assurance Program .
- 1. It is recommended that the BAR Quality Assurance Manager establish i the Project Quality Assurance Organfrations such that the site Quality Assurance Manager has total Q. A. responsibility for the project. He '
should be assigned the responsibility and authority to represent BAR Q. A. to the owner on all Q. A. matters related to the project.- This j would include the realignment of certain activities assigned to the ,
home office such as Quality Engineering Planning of source inspections, design review Q. A. problems, resolving owner andits of the home office ..
etc. He would report directly to the 84R Q. A. Manager and would, of course, work with the home' office Q. A. organization in performing his :
total Q. A. function. The Houston coordinators would report functionally to the site Q. A. Manager. The site would be responsible for the pre- ,
paration of source inspection checklists in the case of Comanche Peak procurement and site quality engineers would resolve some inspection problems related to CP haniware.
s In establishing such an organization the site Q. A. Manager becomes the .
prime laterface with the owner's Q. A. Manager on day-to-day problens.
He involves the 84R Q' A. Manager only as necessary on slgnificant
(- problems of a policy nature. He would have full authority to change or modify procedures affecting his project within the restraints of the 84R Quality Assurance Manual. Such a move would provide the B&R ,
Quality Assurance Manager with a direct channel of communication to the
- one individual who has total knowledge and control of a project's Q.A.
program. This is a valuable asset as existing projects increase in complexity or other project are added. -
- 2. As indicated in last year's review and mentioned above under the Houston Observations and Recommuindations, the site Q. A. organization shou'Id establish a separate quality engineering function. It would be .
their task to handle all preplanning of work in close cooperation with the Construction Engineers. Additionally, they would initiate design i change requests, disposition and approve nonconformance reports, handle '
technical problems resulting from source inspections, assist on NRC audits and so forth. It is recossended that such an organization report '
at the same level as the inspection organization to the site Quality Assurance Manager. ,
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.,; .,i It was generally observed that construction and qualf ty assurance do not
~~ ~ issue work instructions and procedures jointly. Historically, construction has gone down a path of establishing procedures and work instructions which require Q. A. approval whiIc Q. A. has gone down a simif ar path preparing parallel instructions which are issued unilaterally. It was stated by one Q. A. engineer that he opposed an approach whereby construction signs off on a Q. A. procedure because construction often disagrees with the degree of control set forth in the. procedures. It is for this very reason that it would be desirable to issue a single set of work instruc-tions under joint approval of construction and Q. A. Such an effort would result in the resolution of differences prior to the issue of procedures and greater cooperation between the two organizations.
- 3. It is reconnended that Q. A. Issue a single site Q. A. manual that is -
consistent with the B&R Q. A. manual and includes a level of procedural detail that requires no supplementary docanents to describe the system for implementing each element of the Q. A. program. The single manual should be jointly reviewed and approved by the site Q. A. Manager and Project Manager. It would be the single document utilized by all site personnel in implementing the site Q. A. program. The only additional procedures needed would be the B&R Special Process NDE procedures.
4.
It was observed by several Q. A. personnel interviewed that procedures
- do take an unduly length of time to get changed due to the coordination r required with the owner, the site personnel and Houston personnel. Every
(- effort should be made to reduce turnaround time on procedures to a few days. Changes will occur and.the pmsent system (witch based on open audit mports is 'taking. months to change a procedure) must be expedited.
! 5. It was observed that littic is being done with respect to fornalized 1 preplanning of work. 84R has no requirement, for example, to issue i
material dents. takeoff lists for each lift of concrete to the craft superinten-Such itsts prepared by construction engineers and supplemented by detailed inspection planning prepared by quality engineers and jointly i operations.by both would aid considerably in the conduct of construction approved If B&R were formally connitted to such a program, it would force earlier release of design drawings to the site.
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e Design and Change Control '
, 1. Design Chan_ge Control. An abundance of methods' for changing design documents exists. Design documents can be changed by: DC/DD's, FI/CR's, FP/AR's, DE/CD's, GUF letters. TUF letters and FDCR's. This system of design change authorization is perceived by supervision and workers to be very complex, confusing and difficult to work with. A system should be established utilizing a single form which would be utilized as a change request and with subsequent approval would represent the change authorization. -
- 2. Timeliness of Design Change Approval. The average time required to '
process FDCR's written during the month ~of Fetruary was 30 days with 3 l
still open. Civil Section FI/CR's for April averaged 14 days for pro-cessing and 28 FI/CR's from April still remaining open. Inability to process changes on a timely basis results in severe schedule pressure l to work in advance of authorizations.
- 3. Limit on Changes to Design Documents. A maximum Ifmit should be g
placed upon the number of design changes accumulated before a mandatory '
document revision must be initiated. This limit should address to quantity as well as a maximum time over which design changes can be accusula ted. A single design change format should also be implemented that is readily recognized by all organizations as the one document initiating design change requests. Also, a single highly visible identifier should be initiated which would be initiated and dated by the user.
A significant problem identified by many persons on site is the poor legibility of design dncuments. This problem is primarily concerned with Gibbs and Hill reproductions.
action has been requested by B&R personnel.
It is understood that corrective Indoctrination and Training It is understood that at peak manpower there will be in excess of 2,000 separate personnel training records. 'With the availability of a CRT network on site, it would be well to consider putting these records in it for fast retrieval and reduction of clerical labor.
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f Audits
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- U= There is a need for a positive corrective action system with rreaningful commitments to scheduled dates of completion. Unless the audit program 1
is revised to involve management in reviewing corrective action slippage, little improvement can be expected. It is recommended that corrective i action dates be committed to and published at the same time as the audit i reports with successively higher mandatory management review with each i slippage. It was noted that the site auditors are assigned the task of l
{ coordinating answers to all external audits such as 88R Houston audits L j and TUGC0 audits. This measurability reduces the time that is available t l' for auditing at the site.
Construction Activities
- i 1.
I The method of cylinder storage for concrete testing by stacking in the " fog" room appears hazardous as well as possibly being difficult to ;
j control as the nuder of cylinders increases. - '
l i
, 2. The only documentation noted at Comanche Peak of witness of sechanical and chemical testing of rebar at the vendors plant in s Steelton, Pa., was done in October 1976. If true, this appears to be
- 4 i
too infrequent a schedule of source inspection to maintain proper control ,
- p of'the supplier's activity.
) 3. In order to properly review the welding procedure in QCP3.4. 21 references had to also be reviewed. It is suggested that the format of i l procedure writing be revised so that references remain references and j are not a specific part of the. procedure.
1 j 4. Not all the electrical construction procedures have been written and
- neither has the QCP for electrical requirements. Electrical work has ;
i already consnenced without issue of these procedures. This has resulted i
- in temporary QCI's being issued without tm QCP document as backup. i
! 5. The responsibility er NDE is not clearly defined by QAP 9.1. It '
! appears that control of NDE is listed under 84R Construction and the *
!' verification of performance only is a 84R Q. A. responsibility. !
CP-QCP-3.4' indicates NOE is performed by QC Engineers / Inspectors, i
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.g....'.. . . . . HOUSTON AUDIT RESULTS SCOPE '
The Houston audit was conducted during the period of May 9 through Hay 13, 1977. A pre-audit meeting was held per Attachment A, an. audit plan developed per Attachment 8 and an exit interview held per Attachment C.
AUDITORS J. P. Jackson, MAC Audit Team Leader '
W. 8. Williams, MAC Audttor J. T. Wilbur, BAR Auditor ..
G. A. Tell "
J. E. Roscoe "
- 0. F. Hanlan' . " ,
J. C. Shuckrow "
A. H. Geisler "
- 5. H. Hobbs "
s AUDIT RESULTS '
I. Audit Element: Organization and Quality Program .
Auditor: John P. Jackson Scope of Audjj;,:
1.
Reviewed Q. A. Manual, Section 1, and 2 and BAR Topical Report.
- 2. Coordinated interviews with the following personnel:
Quality Assurance Croanization:
T. H. Gamon, Q. A. Manager P. J. Kornoski, Nuclear Q. A. Section Mana P. Bulten, Fossil Q. A. Section Manager. .ger .
G. Sulcken Q. A. Audit Section Manager J. P. Clarke, Q. A. Specialist Section Manager R. A. Romeo, Technical Assistant M. Meyer, Houston Ccordinator, STP D. Horton, Houston Coordinator, CP Engineerino J. Mooney, STP Project Engineer J. Paden Engineering Q. A.
( Construction L. Ashley, Manager - Construction '
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- Deficiencies. ,
! fn . - Quality Classification. Brown & Root uses a system of qual'ity classi-
! " fication based on STP DC 010 Procedure for Codifucation. Since 10CFR50 Appendix 8 Criterion 2 Quality Assurance Program requires a system of ;
i identifying safety related structure systems and components. the B&R Quality Assurance Manual, Section 2. Quality Assurance Program, should
{ give visibility to such a system.
I II. Audit Element: Design Control and Document Control Auditors: A. H. Geisler, J. C. Shuckrow, S. H. Hobbs I. .
Scope of Audit: Reviewed Topical Report B+R002A, Revision 1. June 1976, ..
Sections 17.3, 17.6 STP PSAR, Sections 17.1.38 and 17.1.68, 8+R
! Quality Assurance Manual Sections 3.0 and 6.0 and STP Quality Assurance i
Program, Sections 5.3 and 5.6.
Audit Deficiencies: ,
- 1. Engineering Department is responsible for the official Q. A. records of purchasing orders and change notices. These files are not being main-i s ,
tained current. New documents have not been filed for the past six weeks.
i No apparent control system is being implemented for signout of documents from these files. Responsibility within Engineering Department for main-
- tatning these files has not been clearly defined.
I 2. At present, no documented system exists whereby the field can be l assured that they are pmceeding based on the latest design documents and changes. Examples: ,
i I a.' Engineering CRT system is currently inputing based on a !
j 6-8 week backlog.
j :
- b. 8f-monthly document status lists are prepared from CRT i system records; thus, they are not current. , l g c. SDR's are not inputed into the CRT system. !
- d. FREA's are, not consistently inputed into~ the CRT system.
i f
- e. Control Data Cards are not accurately being maintained, i
- 3. Changes to vendor specifications are not being transmitted to and acknowledged by the suppifer and/or incorporated into the purchase t,
order. Examples: i i
i a. No documented evidence that American Bridge was transmitted 1
Rev. 0/DCN/12-1-76; Rev. D/DCN/1-14-77; Rev. 0/DCN/2-7-77:
i Rev. E/DCN/3-2-77; and Rev. F/DCN/4-29-77 to Spec. JA01055012. '
j b. No documented evidence that Ameron is aware of the requirements of three DCN's and four FREA's which substantially changed t
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Attachment C to Spec. 2C26955006E which is the reference document to P. O. 35-1197-0133 (0138) and change notice dated
, 4/5/77.,
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- 4. Engineering Procedure STP-DC-009-E, Section 2.9 states that "the EDCC
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. .. shall maintain the files such that a document or its equivalent copy can .
be produced upon request". T:1e EDCC files are not current or complete.
Examples: * ,
- a. ST-BR-A8 correspondence file *had 15 out of 83 letters missing, i
- b. ST-AB-BR correspondence file had 52 out of 97 letters missing. #
- c. ST-A8-BR and ST-8R-A8 correspondence files were only current I through 3/22/77 on day of audit (5/11/77).
- d. 2Y060SS033C/DCN/9-13-76 and DCN/10-13-76 not available in EDCC.
The EDCC files should be audtted for completeness and, where necessary, updated. Duplicate copfes should be maintained within EDCC while docu- i ments are being micrifilmed, t
5.
There is no documented evidence that approved FREA's are resulting in change notices to the drawings or specifications. The FREA system is being abused to perief t changes / deviations without generating the necessary DCN's.
Engineering procedure STP-DC-023 should be changed
' to specify that the FREA form is only a vehicle to request a change /
- deviation (notanapprovalmechanism). Formal approval release should i 7 only be provided by a DCN to the drawing or specificatfon. i
( 6. FREA's are not receiving proper review and approval. Examples: '. -
a.
FREA0-C-0169(4/6/77) requested waiver of Q. A. approval !
regarding containment liner coatings. Waiver wan granted '
without Q. A. approval of FREA. Additionally, design verification was not performed to this FREA and client '
approval not provided.
- b. FREA's 0-C-0120.1-C-0164. 0-C-0169 were approved without Q. A. and client signature. .
- 7. There is no documented evidence that approved SDR's are resulting in change notices to the purchase orders and DCN's to the speciffcations.
The SOR system is being abused to permit change's/ deviations without generating the necessary change notices and/or DCN's. Engineering procedure STP-0C-024 should be changed to specify that the SDR form * !
1s only a vehicle to request a change / deviation (not an approval l mechanism). Formal approval release should only be provided by a i' change notice to the purchase order and/or DCN to the spectfication.
- 8. Copies of approved SDR's are not being distributed to holders of i applicable spect ffcations.
l l 9.
! Completed purchase order. SDR's are not being filed with the specification and
, f( correspondence file. Completed SDR's are only being filed with the vendor ;
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. r. 10. Revisions are being made to requirements contained within'specifica- .
(( _ tions and drawings without receiving proper design verification. .
- p .. Example
- *
- a. SDR approval does not include design verification l ,
- b. FREA's 0-C-0103, 0-C-0110, 0-C-0120 ,
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- c. 3A010SS012F/DCN/4-29-77
- d. 2Y060SS033C/DCN/3-14-77 l
i 11. Engineering Precedure STP-PM-005-0, Interface Control, had an j effectivity expiration date of March 13, 1977. This proceduie needs to be i revised to become effective for the remainder of the project. --
i
, 12. Engineering Procedure STP-0C-011-A, Document Distribution, har i been issued for " Interim Use" since July 1974. The distribution lists j provided in Figures 1 through 4 are extremely obsolete based on the present organizations. This procedure needs major revisions to update and simplify the STP document distribution pro' gram.
l 13. The means of identifying certain documents are released by .
) authorized personnel was not observed in any effective dpcument. This i l was observed for foreign documents issued to Construction and field generated sketches. Engineering Procedure STP-DC-004-C defines means
- for handling alternate methods of processing foreign documents, however, j objective evidence was not available in EDCC as described.
I
- 14. The specific method for maintaining the status of all design docu-
! ments (and changes thereto) and communicating the current design
- configuration is not defined in any effective document. It is '
recommiended that the specific method or system be estabitshed, documented j and maintained to identify the current approved design configuration
- and consnunicate this vital information to all concerned -- construction,
- inspectors, vendor surveillance personnel, purchasing, vendors, etc.
j III. Audit Element: Procurement Control
! Auditors: Donald F. Hanlen, James T. Wilbur. . . .
Scope of Audit: Review of the procurement docunent control system as i set forth in the audit plan.
! Deficiencies:
l 1. The Vendor Surveillance Specialist (VSS) is required to make his I own check list for inspection from a general Vendor Surveillance Plan i which is not specific enough to assure all regulatory requirements will l be sufficiently monitored. As an example, the Vendor Surveillance Plan f for Purchase Order 4019/8019 was found to be unacceptable in identifying exactly what characteristics were to be inspected by the VSS.
- 2. There was no evidence that a plan or requirement existed to keep the !
- VSS check list or inspector current with the latest drawing revisions.
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.D nT IV. Audit Element: Indoctrination and Training .
, %'" Auditor: James T. Wilbur
- Scope of Audit: Review of indoctrination and training procedures and progn.as as set forth in the audit plan.
- Deficiencies: No deffetencies ide,ntified. ,
Y. Audit Element: Instructions, Procedures and Drawings Auditors: D F. Hanlen, J E, Roscoe .
~
i ScopeobAudit: Review manuals for proper maintenance, ..
Deftciencies:
) A review of Quality Assurance Manuals revealed that 14 of 61. manual j
holders have not acknowledged receipt of update transmittals, organt-
! zational charts in 5 of 61 manuals are out of date, the list of manual
! holders is grossly in error and proper snatntenance of manuals by manual holders is generally poor. ,While a program is curr:ently underway by 1
Quality Assurance to reytew maintenance of manuals, a controlled index of anual holders and a stronger p gram of follow up to* assure continu-ing matntenance and update of a 1 ssued manuals is recommended, yg, _ Audit Element: Nonconforming Material Control Auditor: John P. Jackson l Scope of Audit: Review of applicable procedures and determine turnaround time on home office approval of STP nonconformances. !
j Deficiencies: It was observed that the average turnaround time for obtain- '
ing Houston office approval.on nonconfonnances for the first quarter,1977 L
,i was 26 days. It is noted that 795 of the nonconformances exceeded the j site specified need date by an average of 35 days. This is cited as a deficiency inasmuch as prompt resolution of nonconforming items is of
- paramount importance in maintaining control of defective material at a construction site. As the complexities of construction at STP increase, the number of undispositional nonconformances "in float" awaiting disposi-
- tion must be controlled or most assuredly defects will be inadvertently
{ bypassed or covered up resulting in extensive rework or repair.
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VII. Audit Element: Quality Assurance Records '
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l ;1. . - - ' Auditors: Wesley B. Williams, Gerry A. Tell Scope of Audit: Review of the' quality records system and document ,
, control as outlined in the audit plan. l i
Deficiencies:
- 1. Them has been no monthly review of the Q. A. records system as specified in ST-Quality Assurance Procedure 6.1 Section 5,7. The first and only documented review was conducted February 2.1977.
- 2. The security system does not meet the requirements of ANSI N45,2,9 as there were occasions observed when no attendant was in the area to --
prevent unauthorized personriel free access to the storage area. This was noted particularly during the noon lunch time, VIII. Audit Element: Audits l Auditor: Wesley B. Williams, Gerry A. Tell
' Scope of Audit: Reviewed procedures set forth in the audit
- Reviewed all audits accomplished during.the past 12 months, plan 2 Deficiencies:
j 1.
Q. A. is not.using the established audit schedule. While there is a plan to revise the fonnat and method of audit scheduling nothing has been formally issued to correct this finding from the p,reytous audit, 2.
A total of 14 internal audits'were conducted during the year of which 8 are still open awaiting for one or more Audit Deficiency Reports (ADR) l to be satisfactorily closed out.
~ on how long an ADR may remain o While there is no documented time limit between 6 months and one year. pen, some of these ADR's haye'been open is definitely a violation of 10CFR50 Appendix B requirements,This lack of con .
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ATTACHMENT A -
MINUTES OF PRE-AUDIT MEETING HOUSTON, TEXAS MAY 9, 1977 l ATTENDEES -
G. A. Bulcken - Audit Section Manager !
j N. E. Erickson - Operations Manager T. H. Gamon - Manager, Quality Assurance - Part time
- W. Green - STP Purchasing Manager 4 J. P. Jackson - MAC Team Leader -
W. 8. Williams - MAC - Audit Team .
J. E. Roscoe - B&R
- G. A. Tell - B&R "
J. Wilbur - B&R "
J. Shuckrow - 8&R S. Hobbs -~BAR A. Geisler - 8&R "
- , D. Hanlen - B&R "
1 1
DISCUSSION Mr. G. A. Bulchen, standing in for Mr. Gamon, introduced John P. Jackson of Management Analysis Company. He outlined the purpose of the audit as being a review of Brown and Root's adherence to comunitments in the P$AR as well as NRC regulations. He explained that the audit team was chartered '
l with the responsibility of an in-depth review of Brown and Root's overall 4
Quality Program in the same manner as was carried out a year ago.
i Mr. Jackson then introduced the audit team, briefly explaining each of the team assignments, and assured each of the attendees that the area super- !
- vision would be contacted prior to initial entry into any area chosen for audit.
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, ATTACHMENT 8 .
AUDIT PLAN FOR .
BROWN & ROOT'Q. A. MANAGEMENT REVIEW HOUSTON OFFICE PURPOSE- .
To determine (1) confonnance of Brown & Root Q. A. Program implementing procedures to 10CFR50 Appendix 8 and ANSI N 45.2, and (,2) compliance of existing practices to released procedures. .
ELEMENTS REVIEWED -
I. Organization and Quality Program A. Objective ,
Review organization and Quality Program for effectiveness and compliance to the Topical Report and Q. A. Manual.
- 8. Method "
f '
- l. Review total organization with T. H. Gamon.
- 2. Interview functional maangers throughout the audit period.
- 3. Review sanuals and procedures for adequacy of program coverage.
C. Applicable: Procedures 1.
B&R Q. A. Manual section 1 and 2 revised March 1977
- 2. B&R Topical Report 002A revision 1 June 1976 II. Design Control & Document Control - . --
A. Objective Review systems and procedures to assure design verification, changes, interfaces and quality requirements have been addressed.
B. Method
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- 1. Verify comformance to design change control system.
re "- 2. Verify foreign document control.
- 3. Review interface control and design verification, i
C. Applicable Procedures
- 1. Engineering Procedures' listed below: *
- a. STP-DC-001-D, Preparation and (bntrol of Project Procedures
- b. STP-DC-002-G, Drawing Control
- c. STP-DC-004-C, Foreign Document Processing
- d. STP-DC-005-G, Preparation and Control of Specifications
- e. STP-DC-009-E, Filing and File Storage "
- f. STP-DC-Oll-A, Document Distribution
- g. STP-DC-013-8, Document Change Notice Control
- h. STP-DC-015-C, Design Verification
- 1. STP-DC-023-D, Field Requests for Engineering Action J. STP-DC-024-C, Supplier Deviation Requests
, k. STP-PM-005-D, Interface Control
- 1. STP-GR-003-8, Design Quality Program s .
j 2. Construction Procedures listed below-
- a. STP DCP-1, Rev. 3, DCC's General Procedures
- b. STP DCP-2, Rev. 3. Receiving Documents
- c. STP DCP-3, Rev.1 Distribution of Documents
- d. STP DCP-4, Rev. O. Reproduction of Documents
- e. STP DCP-5, Rev.1, Recovery and Destruction of Superseded Documents
- f. STP DCP-6, Rey, 1. Central File System
- g. STP GCP-21, Rev. 2. Field Requests for Engineering Actions III. Procurement Control A. Objective Review the system of procurement document control for supplier furnished materials to assure effective , communication of design changes and quality requirements.
B. Method
- 1. Assess adequacy of vendor surveillance checklists.
- 2. Verify Q. A. input to procurement documents,
- 3. Verify Q. A. review of all design changes and transmittal to supplier and Vendor Surveillance Specialist.
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C. Applicable Procedures. '
$,-..'" 1. B&R Q. A. Manual, Revision 3/8/77. * *
- 2. B&R Quality Surveillance Procedure Manual, January 1977.
- 3. STP-AD-003-D, Preparation of Inquiry Package.
- 4. STP-AD-004-B Bid Evaluitions.
IV. Indoctrination and Training -
i A. Objective Review the adequacy 'of the total training program including qualification and training records of personnel performing tasks in various crafts as well as auditor qualifications.
B. Method
- 1. Interview training supervisory personnel.
- 2. Review Q. A. Manual and Q. A. Personnel Traiqing Manual.
Or 3. Review personnel training files for qualifications of
( personnel and accuracy of infonnation.
. C. Applicable Procedures
- 1. B&R Q. A. Manual Section 2.0, issued October 1976.
- 2. B&R Q. A. Personnel Training Manual Parts I & II, issued July 1976.
4
- 3. STP-PM-006-B Personnel Training, issued April 1977..
V. Quality Records A. Objective - ~
To verify compliance of the B&R procedures with ANSI H45.2.9 as required by Regulation Guide 1.88.
B. Method
- 1. Review implementation of QAP for violations of ANSI N45.2.9.
- 2. Review file content for completeness. ,
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C. Applicable Procedures - '.
' I" " ' '
- 1. Quality Assurance Procedure ST-QAP Section 6.1 rev. January 1977.
- 2. Quality Assurance Piocedure CP-QAP Section 17.1 VI. Audits .
A. Ob.fective Review the BAR audit program for compliance to ANSI 45.2.12, 10CFR50 Appendix 8 and Topical Report B&R'-002, and its effectiveness in measuring and controlling the overall B&R ..
Quality Program. .
- 8. Method
- 1. Review audit schedule for compliance to plan.
- 2. Review all audits from' previous year.
- 3. Verify qualifications of all auditors. '
- 4. Review effectiveness and timeliness of corrective actions.
C. Applicable Procedures
- 1. B&R Q. A. Manual, section 2.5, revised September 1975,
- 2. Quality Assurance Procedure ST-QAP section 7.1 revised September 1975.
- 3. Quality Assurance Procedure (P-QAP section 18.1 revised July 1975.
- 5. ' Quality Assurance Procedure ST-QAP section 5.18 revised - -
September 1975.
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ATTACHMENT C s ,
MINUTES OF P'0ST-AUDIT MEETING 1 HOUSTON l
l TIME 11:30 a.m., May 13, 1977 ;
ATTENDEES ,
i T. H. Gamon - Manager Quality Assurance G. W. Bulcken - Audit Section Manager J. T. Mooney D. J. Oliver R. W. Peverley W. T. Green "
N.. Erickson Audit Team Mr. Jackson of Management Analysis Company opened the meeting explaining that the presentation would cover 'the highlights of the findings by each team and invited comments during the presentation.
s . -
Each team then presented an overview of their findings and discussed the y .
backup information supporting their report.
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Mr. Jackson then thanked the attendees for their cooperation and that of all Brown & Root personnel audited and the meeting was adjourned at 1:10 p.m.
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EXHIBIT 3 COMANCHE PEAK AUDIT RESULTS s .
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l]52 COMANCHE PEAK AUDIT RESULTS '
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SCOPE The Comanche Peak audit was conducted during the week of hay 16 through May 20,1977. A pre-audit meeting was held per Attachment A, an audit plan developed per Attachment 8 and an exit interview held per Attachment C.
AUDITORS J. P. Jackson, MAC Audit Team t.eader W. B. Williams, MAC Auditor "
G. A. Tell, B&R Auditor J. E. Roscoe.,
- 0. F. Hanlon "
J. C. Shuckrow "
AUDIT RESULTS
!. Audit Element: Organization.
- Auditor: J. P. Jackson Scope of Audit:
, Reviewed procedures set forth in the audit plan and interviewed the following site personnel:
P. Bussolini, Site Quality Assurance Manager R. Scott, Quality Assurance Engineering Supervisor H. C. Dodd, Project Manager W. E. Childress, Project Engineer E. Kotowski, Purchasing Manager J. Smith, Inspector R. Tolson, TUSI Site Q. A. Manager R. Fleck, Gibbs & Hill Q. A.
Audit Deficiencies: None . . .. -
II. Audit Element: Design Control and Document Control Auditor: Gerry A. Tell, Donald F. Hanlen Scopeplan.
audit of Audit: Reviewed systems and procedures as set forth in the Deficiencies:-
D( 1. Inadeqisate Configuration Control. There is an unacceptable number of unincorporated changes and clarifications to specifications to the extent the specification requirenents could not be determined. As an example, specification SS-9 had 86 unincorporated changes and clarifica-tions, SS-10 had 22 and SS-11 had 16
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. ;;. . . . . .:.v-2 d..% The same deficiency was found on drawings. Drawing SI-0505 had 23
.b- unincorporated changes and clarifications, SI-0501 had 8 and SI-0502 !
had 6. !
As a result of this situation, personnel performing the day-to-day work experienced great difficulty in comprehending the design requirements.
Personnel who have infrequent need to review the design requirements impossible. set forth in these documents would find the task virtually It is MAC's opinion that in viewing this problem in terms of 10CFR-50 Appendix B Criterion 5 Instructions, Procedures and Drawings, the
! present situation repre,sents a violation in that " quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished", is simply not being effectively .
communicated to the workers.
2.
Desion Document Release Status. The release of Design Documents is poorly defined on Comanche Peak procedures.
CPQAP section 6.1 requires documents to be marked " Released for Construction." Procedure 35-1195-DCP-3 Rev. 5 states that documents are to be stamped " Approved by TUSI" by the Document Control Center.
1 In actuality, the inspectors in the field is started. wait for a TUSI letter verifying approval before inspection ,
" Approved with the exception ofThere are also drawings released to Construct '
Revision".
f lack of a clearly defined release system represents a violation of
( Appendix B criterion 3 Design Control.
III. A'udit Element: Procurement control
- l
- Auditor: John P. Jackson Scope of Audit:
i Reviewed procedures set forth in the audit plan, Fourwere:
They purchase ~ order packages were selected and reviewed for adequacy .
Bethlehem Steel - Rebar -
P. O, 35-1195-0147 Sandvik - Weld Rod -
P. O. 35-1195-6814 Chemetron - Weld Rod -
AFC0 Steel - Misc, Metals P. 0. P. -
35-1195-8870.
O, 35-1195-6806 i
Audit Findino_s :
1.
Procedures GCP-4 and GCP-21 controlling the procurement of hardware design documents to suppliers.are not sufficiently definitive with respect to t established for handling of design information with suppliers. ANSI N
- 2.
{ 35-1195 (a safety related purchase onicr' for miscellane determined that:
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- a. The purchase order 'did not specify the current dFaifngs and specifications that the supplier was fabricating to.
- b. The site document center had no record of drawings sent or received from this supplier, c The construction engineer. involved had cognizance over the drawings sent to the supplier but ha'd forwarded one drawing which was noted " Approved with the exception of rev. 3" (drg. 2323-SI,0560 Rev. 21 and another drawing (2323-SI-0559 rev. 3) stamped "not for construction."
It was indicated that the supplier was working to these - '
drawings. It is to be noted that the practice of for-warding any preliminary drawings to a supplier should be avoid unless strict contractual provisions exist for formal " release for fabrication".
- d. A P. O. change order processed on 4-22-76 did indicate two preliminary drawing numbers and stated that future 4
s revisions and issues would be forwarded by P. O. revision. ,
, Such action was never taken on subsequent revisions. -
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\ IV. Audit Element: Indoctrination and Training j - Auditors: Wesley'8. Williams, John E. Roscoe i
Scope of Audit: Reviewed training methods and records as set forth in the audit plan.
Deficiencies: No deficiencies identified:
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- V. Audit Element
- Measurement and Test Equipment
! Auditors: Wesley B. Williams, John E. Roscoe Scope of Audit: Review of calibration laboratory, calibration personnel and procedures as stated in the audit plan.
j Deficiencies': No deficiencies identified in the area reviewed.
VI. Audit Element: Receiving inspection s
Auditors: Gerry A. Tell, Donald F. Hanlen l
Scope of Audit: Review B&R and CBI receiving activities as stated in
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- Deficiencies
- No deficiencies identified in the areas reviewed, i -
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[VII.AuditElement: Q. A. Records -
- Auditor: Gerry A. Tell, [bnald F. Hanlen Scope of Audit: Review documentation adequacy and security as stated in the audit plan.
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Deficiencies: A review was made o'f the record file of subcontract
- 35-1195-0225 (R. W. Hunt subcontract for site testing). It was determined that the file was missing Change Order #1 and Change Order
- 2. Since purchase order and subcontract files are considered Q. A.
records in accordance with ANSI N45.2.9, this does represent a deficiency.
VIII. Audit Element: Nonconformance Control .
Auditor: J. Shuckrow Audit Scope: Review of procedures and systens for nonconformance.
Deficiencies:
Timeliness of Disposition. A total of 101 DDR's were issued during -
the first quarter of 1977. Of those dispositioned, the Average time lapse was 26 days from time of initiation until approval of disposition was made. This does not include time to implement the disposition.
28% of these 10100R's still have not been dispositioned. This number of open DDR's will, as the job progresses, most assuredly result in lack of control over deficient work operations. Timely resolution of nonconformances (1 to 2 day turnaround) is mandatory to maintain proper control of work operations.
i IX. Audit Element: Audits Auditor: Wesley B. Williams Scope of Audit: Review audit procedures and compliance to procedures as stated in the audit plan. _. , . .. , , ,_
Deficiencies:
Corrective Action Delay. As also stated in the flouston home office report, time to answer Audit Deficiency Reports (ADR's) and close of of audits is excessively long. Of the total 20 audits completed in the last 12 months, 12 are still open. In most cases this delay can be attributed to required procedural changes with ADR's open as long as one year, r -
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c: # - '* MINllTES OF PRE-AUDIT MEETING COMANCHE PEAX
- MAY 16,1977 ATTENDEES ,
P. L. Bussolini - 88R Project Q, A. Manager B. C. Scott - 88R Q. A. Supervisor ;
J. Dodd - BAR Project Manager W. E. Childriss - B&R Chief Project Engineer E. P. Kotowski - B&R Purchasing Supervisor "
R. O. Taylor - 88R DCC Systems C oordinator J. P. Jackson - MAC Team Leader W. 8. Williams - MAC Auditor J. E. Roscoe - B&R Auditor G. A. Tell - B&R Auditor
! D. E. Hanlen - B&R Auditor s DISCUSSION
- The meeting was opened by John P. Jackson from Management Analysis who introduced the audit team and briefly explained the purpose of tt.e audit
' was to review Brown and Root's adherence to comitments in the PSAR and NRC regulations as well as checking any of the contracted functions under the responsibility of Brown and Root. He explained the audit team was
- chartered with the responsibility of an in-depth review of the overall construction site Q. A. Program.
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g AUDIT PLAN FOR BROWN & ROOT Q. A. MANAGEMENT REVIEW COMANCHE PEAX PROJECT PURPOSE To determine, (1) conformance of Brown & Root Q. A. Program implementing procedures to 10CFR50 Appendix B and ANSI N45.2, and (2) compliance of existing practices to released procedures for systems and construction operations. -
ELEMENTS TO BE~ REVIEWED ,
I. Organization & Quality Program A .- Objective Review organization and Quality Program for effectiveness and compliance with A. Q. Manual and PSAR.
B. Method ,
- l. Review Comanche Peak organization with P. Bussolini.
- 2. Interview functional managers throughout audit period.
- 3. Interview owner Q. A. representatives and architect engineering representatives.
- 4. Review manuals and procedures for adequacy of program coverage.
d C. Applicable Procedures
- 1. B&R Quality Manual Section 1 and 2 revised March 1977,
- 2. ~B&R Topical Report 002A revision f ' dun'e 1976.
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- 4. " Auditors: As noted below.
Audit Scope: Review individual construction tasks as stated in the audit plan.
Deficiencies: .
- 1. Concrete Testino. G. A. Tell. No deficiencies noted.
- 2. Rebar. W. B. Williams. Receiving inspection is not tracking the requirement of ASME Code III section CC-2331 of testing one tensile test bar from each bar size each 50 tons from each heat. A method not ..
- defined procedurally was started in receiving inspection of maintaining accountability on heat numbers, certifications and tonage of rebar and lasted several months. This effort was arbitrarily dropped with a change in personnel.. As a result, there is no means of demonstrating control of this requirement.
- 3. ASME Code Piping.
J. E. Roscoe. No deficiencies noted.
s 4. Electrical. W. B. Williams, J. E. Roscoe. No deficiencies noted. '
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- 5. Nondestructive Examination. J. Shuckrow. Procedure CP-NDEP-001 Rev. 4-1974 para. 5.8 requires the NDE procedure qualification records to be part of the applicable procedures. These records have not been included in CP-NDEP-100. CPNDEP-101. CP-NDEP-200 or CP-NDEP-300.
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- ^r' . .. . . . I I . Design Control & Document Control y: . .
L '-~ ~ A. Objective -
- Review systems and procedures to assure design verification, changes, interfaces and quality requirements have been addressed.
B. Method
- 1. Review method of effecting design changes.
2.. Review configuration control method and timeliness of implementing and distributing changes.
- 3. Review operation of Document Control Center.
- 4. Review method of determining acceptable configuration of incoming supplier material.
C. Applicable Procedures
- 1. Quality Assurance Procedure CP-QAP 6.1 and 6.2 July 1975.
- 2. Quality Assurance Instruction CP-QAI 17.1-2 tevision 2' April 1977.
- 3. 35-1195-DCP-1 thru 9.
- 4. 35b95-GCP-2 revision 4 January 1977.
- 5. 35-1195-DEI-04 thru 0/.
III. Procurement Document Control A. Objective Review the procurement system for compliance with 10CFR50 Appendix B and ANS145.2.13.
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B. Method .
- 1. Review procurement procedures for compatibtitty and compliance with 10CFR50 Appendix B.
- 2. Review four purchase orders for adherence to D&R procedures.
C. Applicable Procedures
- 1. 35-1195-GCP-04 revis fon 2 October 1975.
( 2. 35-1195-CCP-21 revision 5 March 1977, i
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Indoctrination and Training
- d. e. _ IV.
vm A. Objective '
To determine the acceptability of the training program for completeness and thoroughness 'of the training program and control of personnel training records and certifications.
B. Method
- 1. Interview site training coordinator.
- 2. Review personnel record files. -
t 3. Review follow-up method for required recertifications and **
follow-up training requirements.
C. Applicable Procedures
- 1. Quality Assurance Procedure CP-QAP 2.1 July 1975
- 2. Quality Control Procedure CP-QCP 8.2 August 1975
- 3. Quality Control Procedure CP-QCP 1.3 August 1975
- 4. Quality Assurance Training Manual revision 1 July 1976 V. Measurement i Test Equipment A. Objective Review the controls and methods for calibration of all on i site instrumentation and measurement equipment.
B. Metfiod
- 1. Review lab environmental controls.
- 2. Verify traceability of reference standards and disposition of nonconforming equipment.
- 3. Review serialization and recall schedule of equipment.
- 4. Verify qualifications of calibration personnel.
- 5. Review controis and storage of all calibration records.
- 6. Verify a calibration manual is available and specific instructions exist for calibration of each piece of l
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M- 1. Quality Assurance Instruction CP-QAI 12.1 and 12.2 '
revision 1 April 1977.
- 2. Quality Control Procedure CP-QCP 1.3 August 1975.
- 3. Quality Assurance Procedure CP-QAP 12.1 July 1975..
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- 4. Quality Assurance Procedure CP-QAP 15.1 July 1975.
- 5. Quality Assurance Procedure CP-QAP 4.1 July 1975.
- 6. Construction Procedure 35-il95-lCP-1 revision 2. ..
VI. Receiving Inspection A. Objective Review the receiving function for control of all supplier material and adequacy of the inspection activity.
s B. Method -
- 1. Interview receiving inspection supervision.
- 2. Observe inspection activity and closely review the documentation control.
- 3. Review the inspection and storage facility for adequacy.
C. Applicable Procedures
- 1. 35-1195-ACP-3 revision 4 October 1976.
- 2. 35-1195-CCP-10 revision 3 October 1976.-
- 3. Quality. Assurance Procedure CP-QAP-7.3 revision October 1977. ;
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VII.
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Q. A. Records A. Objective Review the Q. A. Records vault to assure adequate controls of security, completeness and accuracy of filed documents and ease of document retrieval and that systems are in compliance with requirements of 10CFR50 Appendix B and ANSI 45.2.9.
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Select at random a construction activity and verify that all documen,tation related to that activity is available and accurate.
- 2. Observe security and documentation controls throughout audit period. ,
- 3. Verify that safety related items and processes have adequate documentation support.
'C. Applicable Procedures *
- 1. Quality Assuranc.e Procedure CP-QAP-6.2 July 1975. **
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- 2. Quality Assurance Manual section 17 October 1975
- 3. Quality Assurance Instruction QAI 17.1-5 April 1977.
VI!!. Nonconformance Control
, A. Objective
- Review the procedures for documentation of noncon'formances and the implementation and followup of corrective actions request.
B. Method
- 1. Review the nonconfonnance reporting system and procedures adequacy.
- 2. Review records of Deficiency and Disposition Report (DDR) for timeliness of response.
- 3. Review the new system of Deficiency Report (DR) and Non-conformance Report (NCR) for implementation and timeliness of response.
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AppItcable Procedures
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- 1. Quality Assurance Procedure CP-QAP 15.1 and 16.1 July 1975
- 2. Quality Control Instruction CP-QC1 15.1-1 April 1977 p(
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IX. Audits *
.,-- p' . . . . A.' 0bjective Review of BAR site audit program for compliance to procedures, adequacy of coverage and corrective action effectiveness.
B. Method
- 1. Review records of all audits completed during the last -
twelve month period for compliance to procedure and 4
completeness of documentation.
- 2. Verify compliance to audit schedule.
- 3. Verify auditor q'ualifications.
j 4. Review effectiveness and timeliness of corrective actions.
C. Applicable Procedures
- 1. Quality Assurance Procedure CP-QAP 18.1 and 18.3 July 1975, ,
- 2. Quality Assurance Instruction CP-QA1 18,3-1 April 1977
- 3. Quality Assurance Procedure CP-QAP 18,2 July 1975, X. Construction-Activities -
A. Objective Review the following site activities for adequacy of procedures and disciplines, configuration control and attention of construc-
, tion personnel to procedures and documentation.
- 1. Concrete testing.
- 2. Rebar
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- 3. ~ASME Code Piping
- 4. Electrical i
- 5. Non-Destructive Examination (NDE) f O
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- 1. Review construction procedures and' site quality manuals to verify compatibility. .
- 2. Verify records are properly completed and files,
- 3. Observe ea:h'of the construction activities listed and verify through observation or objective evidence that the issued procedures are being followed. ,
.C. Applicable Procedures
- 1. All pertinent site procedures issued by Construction or .
Quality Assurance.
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Jyr y QUALITY ASSURANCE MANAGEMENT REVIEW BOARD QAMRB AUDIT NO. 3 0F THE BROWN & ROOT QUALITY ASSURANCE PROGRAM SOUTH TEXAS PROJECT COMANCHE PEAK PROJECT INTRODUCTION The third audit of the Brown & Root Quality Assurance Program was conducted for the Quality June 23, 1978. Assurance Management Review Board during the period of June 5 through The scope of the audit included a compliance with Nuclear Regulatory Comission '
quality assurance requirements and industry guidance as it applies to the design, procurement and construction activities relating to the South Texas Project (STP) and to compliance with Section III of the ASME Boiler and Pressure Vessel Code as it applies to Brown & Root activities on the Comanche Peak Project (CPSES).
The audit team was led by Alfred H. Geisler, Manager, Nuclear Licensing, Brown &
Root. Team members were selected from various organizations as follows:
R. M. Klimist B&R Engineering I. Tribuch, B&R Operations * -
L. W. Crowe, B&R Construction ~
R. J. Kingcaid, B&R Procurement N. W. Pressler, B&R Quality Assurance R. A. Romeo, B&R Quality Assurance
- J. M. Norris, Management Analysis Corp. (MAC)
Prior to the audit, all Brown & Root audit team members participated in an audit training program conducted by the Brown & Root Quality Assurance Department Audit Section.
The audit was conducted by the team members in accordance with an audit plan and schedule (See Appendix A). The auditors used both standarized and specialized checklists, and interviews in performing the audit. Specialized checklists con-sisted of questions famed by the team members from referenced documents assigned as part of the audit plan. The audit checklists, which consisted
' of nearly one thousand items, are available from the Audit Team Leader. The week of June 5 was spent auditing the Brown & Root Home Office activities for the STP project. The week of June 12 was spend auditing activities at the STP Site. The week of June 19 was spend auditing activities at the CPSES site and verifying findings at the Brown & Root Home Office.
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- R. Romeo substituted for I. Tribuch during the audit of the STP and Comanche Peak site due to a conflict of assignments for I. Tribuch.
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l A pre-audit meeting was held at the Brown & Root Home Office on June 5,1978 in l the sixth floor conference room of the Engineering Southwest building. In addi- l tion to the audit team, the following persons were in attendance:
G. H. Bulcken, B&R Quality Assurance W. T. Greene, B&R Purchasing T. H. Gamon, B&R Quality Assurance L. E. Hayden, B&R Engineering J. E. Paden, B&R Engineering H. Paperno, B&R Quality Assurance R. W. Feverley, B&R Engineering R. A. Sanford, B&R Project Management K. A. Swarts, B&R Engineering Separate pre- and post-audit meetings were held at the STP site on June 12 and June 16, respectively, with the following persons attending in addition to the audit team:
Name Organiza tion Pre-audit Pos t-audi t Dean Mooney B&R Quality Assurance x
- Jack Purdy B&R Quality Control x
- Sid Rasnick B&R Construction Eng. *
- Jim Salvitti B&R Construction Mgmt. *
- Tom Warnick B&R Quality Assurance *
- C. W. Vincent B&R Quality Assurance
- R. A. Helivert B&R Quality Assurance
- Gary Euert B&R Quality Assurance
- Briefings were held separately with T. H. Gamon and L. E. Hayden to discuss the results of the audit.
A pre-audit. meeting was held at the CPSES Site on June 20. In addition to the audit team, the following persons were in attendance:
H. Kirkland B&R Project Management U. D. Douglas, B&R Construction Management R. Scott, B&R Quality Assurance i P. Clarke, B&R Quality Assurance A briefing was held with R. Scott at the conclusion of the CPSES audit.
SUMMARY
OF FINDINGS The audit resulted in the generation of 33 Audit Deficiency Reports (ADR's),
i all pertaining to activities on the South Texas Project. Such reports repre-l sent noncompliances with requirements, whether imposed by the Nuclear Regulatery Commission Industry Standards, or by Brown & Root manuals and procedures. The ADR forms are included as Appendix B to this report. The use of these forms has been instituted to provide a convenient means of closing out individual 1
audit deficiencies on a timely basis.
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The deficiencies were ranked as to the nature of noncompliance, the frequency of occurrence and the potential severity of consequence resulting from such
' defi ciency. The more significant deficiencies are as follows:
- 1. ADR-1; Control of' Identification and Changes to Design Inputs
- 2. ADR-2; Control of Design Manuals
- 3. ADR-8; Record Retention Systens'
- 4. ADR-16; Internal Audit Progren-
- 5. ADR-19; Control of QA Program and Procedure Changes'
- 6. ADR-20, 21, and 22; Indoctrination and Training Records'
- 7. ADR-26; Designation of Storage Area Levels
- 8. ADR-32; Designation of Housekeeping Zones ,
Appendix C to this report provides a listing of concerns and recommendations as a result of the team members' observations during the course of this audit.
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h APPENDIX C QUALITY ASSURANCE MANAGEMENT REVIEW BOARD .
1 '
i j QAMR8 AUDIT NO. 3
.i j 08SERVATIONS, RECOPMENDATIONS, CONCERNS 6
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OBSERVATIONS, RECOMMENDATIONS, CONCERNS
- 1. A cross-exchange of information between the South Texas Project and the Comanche Peak Project would be desirable. Many Quality Assurance and Construction programs are similar at both sites, thus a cross-review of procedures, instructions and specifications would be beneficial toward standardizing the B&R implementation of the Quality Assurance Program.
Scheduled coordinationmeetings and site visits between Project, Construc-tion and Quality Assurance management of the two sites would provide 4
opportunity to discuss coninon conditions and problems. -
- 2. The Procurement Department should assign a full-time " Project Purchasing Representative" for the South Texas Project to coordinate all procurement activities. At present, the Power Purchasing Department Manager also is assigned as the " Project Purchasing Representative".
- 3. Although some procedure simplification and consolidation has occurred, ... .
considerably more should be considered. At present, there are approxi-mately'250 STP procedures describing the Brown & Root implementation of the 18 Criteria of 10CFR50, Appendix B. Project procedures covering all departments' activities regarding specific subjects could be developed.
For example, the 5 existing department procedures for initiation, review, approval and implementation of field changes could be consolidated into one cohesive project procedure, thus eliminating the problems of duplication of responsibility and assuring accurate interfaces which exist with the j present system.
, 4. Matrices should be developed to provide a cross-reference indexing between
- the 18 Criteria of 10CFR50 Appendix B; the Quality Assurance Manual; the ANSI N.45.2.xx series of industry standards; and the Brown & Root pro-1 cadures. This cross-reference indexing would provide assurance of pro-cedural coverage of quality program requirements and also highlight those
, areas of procedur2 duplication.
- 5. Training courses should be developed on the requirements and method of i
implementation for each of the ANSI N.45.2.xx series of standards. Attend-i ance at these trainings programs should be those personnel required to i
perform the functions of the standard (f.e., a training program on require-ments and implementatic.1 of ANSI N.45.2.11. " Quality Assurance Requirements for the Design of Nuclear Power Plants", would be attended by all project engineering personnel).
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, 6. On South Texas Project, there is a lack of formal definition of the require-i 1
ments for a specific placement of concrete and of formal coordination be-tween the crafts, quality control engineers, field engineers, and area engineers. The result of this is a redundant review of drawings, speci-fications, and procedures by each of the organizations to determine the parameters of the pour, pre-requisites including engineered compactions, vapor barriers, rebar placement, penetrations, block-outs, embedments and curing requirements. '
i i On a single placement the review of five procedures, four standards and .
two or more drawings / specifications are required to assure that current acceptance criteria, methods and standards are being implemented. These 1-1 1
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, reviews are not coordinated in any formal manner. fn addition, there is a l lack of evidence of effective coordination with design engineering, since '
changes are received at site after concrete placement has been completed.
While the B&R procedures can be. interpreted as meeting the literal require-ments of ANSI N.45.2.5 relative to instructions and procedures, they do not provide a well coordinated plan for concrete placement. i
- 7. The STP concrete construction specification, CS-028, should be revised and reissued by Engineering incorporating all applicable DCN's and FREA's.
The present revision of this document currently has 13 DCN's and 38 FREA's.
This document is frequently used by Construction Engineering and Quality Control. The current state of this document does not provide for ease of locating and verifying current requirements.
- 8. Numerous concrete blockouts are located throughout STP Unit 1 Mechanical-
. Electrical Auxiliary and Fuel Handling Buildings. The blockouts were made on Unit 1 to assure access into cubicles for piping, conduit and ductwork which had not been routed at the time of construction of these areas. -
1 Unit 2 is apparently making the same blockouts, in the same locations and of the same size as Unit 1 even though the definition of need and size on Unit I has been finalized. In some cases there are 12 inch by 12 inch blockouts with 3 one-inch conduits routed through. This could easily be corrected on Unit 2 by providing 3 one-inch sleeves. However, as stated to the auditor, these blockouts are being made so that the drawings would not require revision or change. Engineering should consider a simplified means of revising the drawings such that construction would not be required to spend the additional time necessary to fonn and place concrete around unnecessary Unit 2 block-outs. - A similar situation exists with the number "and location of embedd ed plat se.
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- 9. A program should be established between Vendor Surveillance or Expediting and Construction or Quality Control Receiving personnel whereby receiving personnel are notified of shipments from the vendors such that they can l plan in advance for receipt inspection of the material and assure appro-priate storage area, i
- 10. Westinghouse needs to provide to Brown & Root a complete list identifying storage levels for the NSSS equipment. Presently the list that exists is
- incomplete thus requiring Brown & Root to obtain from Westinghouse after receipt inspection storage levels for the unidentified equipment on a case -
by case basis. In some cases, this has required up to one month.
I
- 11. In approximately two months, the Brown &. Root Audit Group should perfonn a complete audit of design calculations and computer code verification (ANSI N.45.2.11, Section 4.2; and Engineering Procedures STP-0C-008 and
, STP-0C-017) including work performed by structural, stress analysis and
- nuclear analysis groups. These were areas which the QAMRB Audit Team 1
was to review, however, immediately prior to the audit, the Project Quality Engineer had performed a review and discovered significant deficiencies.
- Since Engineering was aware of their problems and were in the process of providing corrective action, it was detennined inappropriate for the QAMR8 Audit to repeat.
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- s e ',. C ; 7 "% % @ f f M j[* C QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: UNIT: PAGE: I OF 3 its nuestso omeasessaTaon talawos7 mo. ist aca me. is ana cops }
B&R Engineering QAMRB-3 1 (SlotSCuSSao of7Ma tag mapomTso BY gifl oaTas i., CAf sGo my L. Hayden. R. Peverley A. Geisler, J. Norris 6 /19 / 78 Osii O i>> O isi i
j ieloccunsaser veosarso ano pamaemares ictrals '
(see attachment) l TI. 7..T. vTr ioT. . ~ - - -- - - - - - - - - - - -- -- ~~ - - - - -- -- --
y (seeattachment)
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o is t, povantina. mspoetae6s caricasacy -
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ii., Provide required identification, documentation, approval and control of design inputs and changes thereto prior to translation of these inputs into design output documents (i.e., specifications, drawings, calculations, etc.). Expeditously update design input documentation for existing final design and re-verify that design to assure com-pliance with design inputs.
i i s e . s.po.= a. m so vs. i ii.i a, oveo v.
L. E. Hayden I.....w f * *) .= ous / A.W. Q6ah pi.i oars.
'T /11/ '18 f
{ To be completed by audited organization ists comescTave acreose mespoussaisanctues acwsoutso ceaseksteese caTal i
i i
it s sweesatt so o v e 'in es oavs.
ines p.svassf arsvs acTsessi tasocbuos scusoukso conectarsom oars l / /
I case suonseT7so era j isai mars.
! / / j l To be completed by B& R Quality Assurance
(
- naves. or ...po. . is. navis.so ev.
D Satisfactory
- issimars, j D Unsetisfactory l / /
i . .s.u r. ., v s.... car... . i. ,, v s . ,,s o . v . ps.ionrs.
O Satisfactory Unsetisfactory l / /
is ei ===.. .. inesc6osso ev. isisears, ca.ees a
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ADR 1 Page 2 of 3 Document Violated and Paragrach (Cite): -
ANSI N45.2.ll, " Quality Assurance Requirements for the Design of Nuclear Power Plants" i A. Section 2.2 " Procedures shall be egloyed to assure that design activities
) are carried out in a planned, controlled, orderly and correct manner. Pro-gram procedures shall cover the following as applicable:
- 8. Identifying appropriate design inputs."
B. Section 3.1 " Applicable design inputs, such as design bases, regulatory requirements, codes and standards, shall be identified, documented and their selection reviewed and approved. Changes from specified design inputs including the reasons for the changes shall be identified, approved, documented and controlled. *'
The design input shall be specified on a timely basis and to the level of detail necessary to pennit the design activity to be carried out in a correct manner and to provide a consistent basis for making design deci-sfons, accomplishing design verification measures, and evaluating design changes."
C. Section 4.1 " Design activities shall be prescribed and accomplished in accordance with procedures of a type sufficient to assure that applicable design inputs are correctly translated into specifications, drawings, procedures or instructions."
, D. Section 6.1 " Measures shall be applied to verify the adequacy of design.
Design verification is the process of reviewing, confiming, or substan-tiating the design by one or more methods to provide assurance that the design meets the specified design inputs."
The following definitions apply to the cited paragraphs:
A. Design - Technical and management processes which comence with identifi-cation of design input and which lead to and include the issuance of design output documents. -
- 8. Design Input - Those criteria, parameters, bases or other design require-ments upon which detailed final design is based.
C. Design Output - Documents such as drawings, specifications and other documents defining technical requirements of structures, systems and components.
D. Final Design - Approved design output documents and approved changes thereto.
i Observations:
Design inputs and changes to design inputs are not being identified, approved, documented and controlled in a planned, orderly and correct manner as required by the cited sections of ANSI N.45.2.ll.
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ADR 1 Page 3 of 3 The B&R Q.A. Manual and Engineering Procedure STP-DC-007-F define the System Design Descriptions (SDD's) as the documents containing the design inputs and their sources. The SDD's are defined as the basis for developing the design output documents (i.e., Purchase Specifications, Construction Speci-fications, Calculations and Drawings).
However. Engineering Procedure STP-DC-007-F additionally establishes procedural acceptability of making significant modifications to design bases within the design output documents without revision to the corresponding " design inputs" in the SDD's, those documents from which the design output documents were originally developed. Further the procedure defines the design output docu-ments as being the design basis and the source of design inputs until such time that the SDD's can be revised to reflect the design inputs of the final design. This is essentially allowing design to be finalized (approval of design output documents and changes thereto) without proper approval, docu- ...
mentation and control of the design inputs.
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QUALITY ASSURANCE DEPARTMENT AUDIT CEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I 2 OF (Il Auo8Tso omG ANIZ ATIoM tal Awolf No. [35 Aos seo. tal Aom Coos B&R Engineering QAMRB-3 2 telossCussen weTn: top maronTso ov e tel Catssomy gtF3 OATS.
R. W. Peverley, J. Paden J. Norris, R. Kinocaid ' 6 / 9 / 78 Oti Oi>> Oi3 tel ooCutesNT veoLAf ro Ano PAR AGm APM (CETals (see attachment)
=
-=====-=============-===============-====--===----t g (see attachment)
't!
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Q It I) PIlBTsMT8AL msPonTAmbs osPICa# NCY O vas G -o Is a3 msCoMMaho ATeoMs
- j If the SDD's and ancilliary documents constitute the Interim Design Manuale rigorously enforce its definition and maintenance within each discipline such that a complete and up-to-date description of design bases can be provided for members of the discipline and interfacing disciplines.
l taat masposess Asseenso To: jttas massomos ous stel Apenovao evi jttel OATS
- L. E. Hayden ' * *") / A.IJ. 0a>,% i
'7 / 12/ 78 .
To be completed by audited organization it?! CommsCT8vs ACTIose maseosess:teseckuos scusoukso comertavsom o ATE I f
~
(t el sweassTTso ev - 'ts op OATat .
taal P80sysMTATava ACThoNs (INChuos oCManukso CoesPLaTBoM o ATal f / / s i
taspsumasTTse avs j (333 oATE: i
' / / l To be completed by B&R Quality Assurance taas navesw or masponses taal navsswso ove {taaloAras 1 Q Satisfactory C Unsatisfactory taal mesukTs or vansPICAvsom e l // _,
(171 vanlPlso eva j tael OAT %:
D Satisfactory Unsatisfactory tasi nameAmsts:
l //
tseeCLosso evs (3:3 oats l
o A..e s.:
- . . - _ yr.-
._ ,.__:= - - . - - -
= - -. -
=.=-.:_..
ADR 2.
Page 2 of 2 Document Violated and Paracraoh (Cite):
l STP-DC-007-F, paragraph 2.8 "The STP Design Manual is the composite of all the completed and approved SDD's. This is inclusive of those ancillary docu-ments (specifications, calculations, drawings, etc.) that have been approved and controlled during the interim. . . . Each DPE will maintain a complete controlled copy of the STP Design Manual in a place that is readily accessible to members of his discipline."
STP-0C-007-F, paragraph 2.1 "Each 500 is the STP source document in which the design bases for a structure, system or component are described and their design inputs / origins described."
Observations:
The STP Design Manuals including interim ancillary documents are not being con- --
trolled and maintained by the disciplines as required by the cited procedure.
SDD's are being maintained and controlled within the discipline; however, design bases changes from the SDD's which are contained in the ancillary documents 4
(specifications, drawings, calculations, etc.) are not being controlled and maintained as part of the STP Design Manual. As the result of discussions with various DPE's, it became evident to the auditors that the definition of design bases existed in various documents in multi-locations and it was doubtful that a clear, concise, complete and up-to-date description of a system's design bases could be provided from these various documents in a reasonable time. In one instance, these design bases were said to be " scattered in bits and pieces throughout the department" and "would be more trouble to consolidate in one place and maintain up-to-date than maintaining the 500 's current." While all disciplines indicated their confidence that the design bases was under control, it was not evident to the auditors that there was established clearly defined control mechanisms being used consistently within the engineering discipline.
l l .
_ ~ .
- - . _ . . . . - . u- --
' 1 6 TOWN &ROOtJCC. !
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF I ii) AWo f?E. . NG AMiE AT).M 8:e AW..? me. ial AOR N., gel Ao# CODE B&R Engineering QAMRB-3 3
- i. . co.=. sva, i . .. .v . .
R. Peverley iiri o Ava. i.i cave.o-v. ,
J. Norris, R. Kinocaid ' 6 / 7 / 78 Oi'i Oi=> Oi>> l
- i. O.CUMENT V 6 Art. AND P A A AG R APue iCiTEls Attachment to A040KPGCP-21, Revision 5, " Interim Procedure Civil-Structural FREA's" (Revised 5-18-78), paragraph 3.8 "Upon receipt of an FREA that has been approved as a deviation to a safety-related drawing by the PSE, the required signature cycle
_ii through the EPM _(in_clu_d_in_g the .d_esign verifierl m_us t_be_co_mpl.e.te.d_. "__ _ __ _ __ __
.i ..=.v av 6. ..
3 Following review of the Civil-Structural FREA's for May,1978, there was no y objective evidence of timely compliance with the cited requirement on site- {
e approved deviations to safety-related drawings. Examples are the following 2 FREA's:
W l-C-1021, 1-C-1025, 2-C-1029, 2-C-1030, 1-C-1034, 1-C-1035, 1-C-1036, ...
i 2-C-1050, 1-C-1052, 1-C-1057, 1-C-1059.
iii p.Ta mfi A6 map.mT A.6a caricaancy O vs. E ==
ii., .... - - ...Ari. ..
- 1. Review previously site-approved FREA's and provide required signatures.
- 2. Revise procedure to require timely signature approval of FREA's.
- 3. Comply with the procedure.
6 insi.. .= An ... v.. i
' ii. Am.v . . . . iii.ioArs.
L. E. Hayden ! . *== *' *) . /... A.lL N > -
! 7 / 2.f 18 '
1 i
To be completed by audited organizatiori si.. . . . . . A .. . .. .... .. .._.... ......A.,
j i
i,.i.......
- ii. .Ar.. 1 is.: P.5vS.sTAfivE ACT Ns is C6U.S .CMEOU6SD C. esp 6ET l / / .
M .A fel i
i inie .ue-streo evi pui oAra.
! / / !
t To be completed by B&R Quality Assurance innnavis..,as =u, ts.: as vie = =. . v . ps.: oars.
Q Satisfactory C Unserisfactory }
i inei . .uur. ., vani,6cAri ..
f // '
intevennessoav. ps.i = Ara.
' O Satisfactory C Unsetisfactory
. ne= Anm..
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. . _ . . . . . . . . . . . - . . . . - - - - . . - ~ > - - - - - -
". - f' Brown &RcotJnc.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF I sti Auoiran cas AnazArion lisi Avoir No. i3 Aom No. ial Aom Coat B&R Engineering lQAMRB-3 +
ist oiscussao wirM s ses maronras sv gati OArts its cArasomy.
R. Kinocaid, J. Norris ' 6/9 /78 Otii Oisi O:28 ,
i9: occu MEMr vt.6ArEn AM. PAN AG a Apoe iC8vEis i
STP-DC-023-F, paragraph 2.2 " Field requests . . . that fall within the criteria of Table I require fonnal engineering approval prior to implementation."
STP-DC-015-E, paragraph 2.3.5 "FREA's require verification to the same degree as the original documen t. " _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
iets oestavArsams 3 The following sampling of FREA's were not doctsnented as having had a design u
z verification:
h 1 - E-0001, 1 - E-0002, 1 - E-0006, 1- E- 0009, 1 - E-00l l , 1 - E-0012 , 1 - E- 0098 ,
b 1-C-1026, 1-C-1035, 2-C-1050, 1-C-1052, 1-C-1057.
o iiis porEMrt Ab R EPo #r A 0 6E .E riC&EMc, O v== @ ao ii ..co--.~oA1 ...
i Comply with the procedure.
=
I in si .ons Ass.oaanro, ; iia ass.oassaus ioniAe,=ovso ev. iii. oAra, ,
L. Hayden ! * * * *) / M QO.L'st h ! "7 /12/%
To be completed by audited organization isti commscvsys Action a sseemss.iinchuos scoesou6so conspustion o Arsi l
1 i
j isen su.. trao ev. ;ii oArm,
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l / /
..sv==r Ariv e Acreon. iiacuuos scasousso com i.svio- o Arai l
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l :::su =strao .v. ;inni o Ars.
! / / -
r To be completed by B&R Quality Assurance ~
- anview or nas,onsa, is. newes. .ev. ;issa oAra. l O Satisfactory C Unsatisfactory l / /
inei nesuwen or vani,icArion, inri veneriso me, ;iseioArs.
O Satisfactory Q Unsatisfactory l / /
is : as- Anus. :. cLosso . . isis o Arc, e
o A +4 5 3
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF 2 1:3 Awortso omeamsgavion tal auosv mo. t3l kom me. 448 aos coor l B&R Engineering / Quality Assurance / Construction QAMRB-3 5 t,8 osscussen wsTai tal mapomTso ev glig cats. 188 carssoev R. Peverley J. Norris, R. Kinocaid '
6 / 7 / 78 Dess Oili Oili (98 occu-sm? vio6ATso ano PanaGmara (CITsgs B&R Quality Assurance Manual STP Supplement Section 15.3 "Upon identification of a nonconfomance . . . the DDR shall be originated by B&R Quality Assurance for such findings."
4:08 oessavafsons, d FREA's are being utilized for disposition of nonconfomances. Examples are the 2 following FREA's from May,1978:
O 5 0-C-10l8, 0-C-1025, 0-C-1033, 1-C-1034, 1-C-1038, 2-C-1040, 1-C-1051, 2-C-1055, o 1-C-1057, 1-C-1063, 2-C-1064.
te st povamTsa6 mapomvaeLat carscasacy is a, esco--EmoaTsons, O vas dno (see attachment) 4:33 assponsa asssenso To: i te st aremovso av s L. Hayden/H. Pacerno/ !' stat *
- assoonsa
") / ous kWOn'N J. Monroe
'T DATas
!'ts el / t1/ 78 To be a2mpleted by audited organization is71 commscTevs acTsom asseemss e tencLuos scmsousso conseksrson oaTap (s ee sweessTTso o v e jtses cats, tael omsysmvaveva acTaons lanc6uos Scusou6so comeP6stson oaTal
! / /
taspsuenesTTao ove j taap cays f / / !
To be completedby B&R Quality Assurance taal Ravesw or masponssa tas arveswso avs itses cava l O Satisfactory D Unsatisfactory r
taal mesu6ts or vanartcargosee 1 //
D Satisfactory (273 ventreso ey, (taal cars, 1 D Unsatisfactory 1 //
i teos mansaasts, 1
taes c60eso ov e tall cats.
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. . . . . ~ . . . . _ - -- , . - _ _ . - - -. -
ADR 5 Page 2 of 2 Reconsnendations:
' Discussions revealed that the FREA is used in lieu of 00R's because of built in delays in the initiation and processing of the DDR's. It is reconinended that the procedure for disposition of nonconformances be simplified to provide rapid initiation and disposition of nonconformance of all items. It is also reconsnended that the FREA procedures be revised to remove "nonconfonnance" as a form of FREA disposition and instead provide a mechanism for Construction to identify non-confonnances to Site Quality Assurance for initiation of DDR's.
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JO8 NO.: UNIT: PAGE: 1 OF l tel AUoITso o nG AN8E ATI.M lal AuolT No. (3)Aom Mo. (at Aon Coos B&R Quality Assurance (site) QAMRB-3 6 ist oescusseo wrTwi gesesponTso sy:
gt:3 marsi (s) CAf sGomyt J. Norris, R. Kinocaid ' 6 /14 / 78 Osii tel occuassmr vio6ATso Ano PAN Asm Apee (cavals Oisi Cin' B&R Q.A. Manual. Section 17.4 "All Q.A. Records, after being stamped; shall be !
reviewed for validity, legibility, completeness, and traceability . . ." !
7,g,,,g,,------------------------ 1
> The following FREA's are examples of FREA's filed in the site Q.A. Vault as l g completed but lack formal approval through the complete signature cycle:
w E l-C-0792, 1-C-0793, 1-C-0796, 1-C-0802, 1-C-0814, 1-C-0830, 1-C-0834.
b l C
te et povanTt An. maromT Amt.a ospicassocv (t al esComeM sMo4 T3. Mas O ves 6aa Only maintain records in the Site Q.A. Vault that are complete. Site Q.A. Vault personnel should be instructed to reject records that are incomplete.
A s... . s o T. , . I
...,A,.oovso .v.
....EEsWncent j...mesmo-aus
- An; ,
Ay qcini Ay 7 / l2./78 l... oats.
To be completed by audited organization (173 commsevevs AcTiose assoones s tesecLuos scusou6ao connesstsoes o4Tal t
toep sumaseTTse eve ;(sos oavse
' / /
lati pesve8eT ATivs ACTB.Ms itMCa.uos sCMsDubso ComerksTeose O Arsl l
last suomesTTso ev j L333 omvai
! / / -
To be completed by B&R Quality Assurance last mavesw or masronses taal navsswso evs Q Satisfactory D Unsetisfactory itatto47si j taal assus.Ts or venspecATaoase 1 / /
1333 vsmarsso e?. jtael cars.
O Satisfactory D Unsatisfactory tapp mensamaass / /
(sel c60sso ov e (3:3oAvea l
o A*48 3 a
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. _ . . . - _ _ - . . . . . . . . ..- . . - = - - . . . . . . . _ _ . . _ . .
- WhW M ^ Brown &Rootke.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: 1 Op 1 ,
gel Avoitto one AssetAvion tal Auot? No. (33Aom me. tal aose Coo s B&R Engineering QAMRS-3 7 telossCussan wsTMs tog mapomTso eve g(73 D ATas (el CATsao my, J. E. Paden J. Norris, R. Kinocaid Oti 898 coCumsMT vlakATao AMD PAm AGa APM (C8Tsje
' 6 / 9 / 78 Oisi Oisi ANSI N45.2 Section 7 "Those participating in an activity shall be made aware of arrd use proper and current instructions, procedures, drawings and engineering requirements for performing the activity."
,,,,,g,,-----------------------
STP-DC-023, Attachment A "STP-PMO-021, Rev. 3, GUIDELINES FOR FIELD REQUESTS FOR D ENGINEERING ACTION." The attachment to this procedure is stated to be Rev. 3; 5 where in fact the cover page noted Rev. 2. All following pages, however, are Q titled Rev. 3. However, when these pages are compared with the actual procedure e in the PMO manual (STP-PMO-021, Rev. 3), it is noted these are two different c procedures.
(s eg poTamTs A6 maromf aeLa persCasmCv s i a, a s Co-- sa o A Tio-..
O vas G -o g
Revise procedure to provide correct attachment. '
~
ta al mesmosess Asseeseso Tot l
'88 86 mesmonsa ous (s el Aremovao ev, jttet DATai L. Hayden * *' *) AH Qm,.olau
! f
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! 7 / l 2f "I8 To be completed by audited organization (1TI ComasCTIva ACYaon museonss a (INChuos SCMacubso COMPbsTeoM o ATs]
toes suoustino ove 'gs el oats, (ael P80sysseT ATiv e ACTeosos llMCbuos CMsoukso ConspsgrooM O ATs) f / /
I (3:3susestTTso ove l1333 O ATsi
! / / }
To be completed by B&R Quality Assurance casi envia= o, mas,o os, in i envis-so ev.
O Satisfactam iiasioATs. l Q Unsatisfactam f / /
taet assuLTS or venertCAveon e (373 vamePtso ev s
[tast oATE:
O Satisfactom O Unsatisfactam l / /
(ase asManus, taen C6osso ove taas o Avs, l
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF 4 ist AustTso onG AMesATton tal Auos? me, talAom mo- tel Ann Coos B&R Q.A./Engrg./ Procurement / Construction QAMRB-3 8 '
tes orscussao wrTm (s)asPomTuo svi (t78 O ATs lescATseonvt R. K11 mist. L. Crowe ' 6 /14 / 78 Disi Oi=> Oi>>
(9) occu Me m? Vpo bATso Amo P Am A4m AP*e (CsTals t
(seeattachment) tie) oessav ATsons: _
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Is s) Pof anTBAb asPomTAmbs osFBCasmCv O vas O ma ta al macomusmeATsons:
I (seeattachment) ta as assposess Assiemso vo 'iset mesponsa ous I t e s t Appm veo evs '4ses OATss '
N.Paperrto * *) h 8
/
~
8 7 /12./78 To be completed by audited organization is78 CommeCTev a ACTfoes maseemsse (seec6uos scronou6so consessrson o ATs i
t (ses susessTvro svi l(ses OATS l l / /
tase PaavseeTAveva AcTsons tsackwos scrosoutso connessTsoas oats 3 (a s s suomesTrao ev, jtaatoAvss
! / / J To be completedby B&R Quality Assurance tasi maverw or maseonssa (see asysawso sys C Satisfactory C Unsatisfactory itasicaTai l taet mesukTs or vsmsreCATaosee
/ /
tatt vansreso sv. tsenDATs O Satisfactory Q Unsatisfactory g tast massanus, 1 / /
taesc6ossoove (3:3 oATsi e
e 1 G A*4s 3 2 wwe-w + m a en*= * *
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ADR 8 Page 2 of 4 Document Violated and Paracraoh (Citeh 10 CFR 50, Appendix B, Criterion XVII " Sufficient Records shall be maintained to furnish evidence of activities affecting quality. . . . Records shall be identifiable and retrievable. Consistent with applicable regulatory requirements, the applicant shall establish requirements concerning record retention, such as duration, location and assigned responsibility."
Observations:
At present, there is no defined, comprehensive and correlated records retention system for the South Texas Project required by 10 CFR 50, Appendix B and ANSI i N.45.2.9.
During the course of this audit, it was revealed that there are nine major filing *-*
, agencies; e.g. , Engineering DCC, Site DCC, Q.A. Houston, Q.A. Site, Vendor 4
Surveillance, Procurement, HL&P Purchasing, Subcontracts, and Site Subcontracts.
Satellite files are too numerous to count. Of the nine systems, there is no cohesive approach to the necessary referencing and records retention system.
As of June 5,1978. Engineering Procedure STP-DC-009 and Quality Assurance Procedure ST-QAP-6.2 retention matrices were in conflict as to which organiza-tion was responsible for retention of what documents.
With the recent change to the Quality Assurance Manual, no system and no identi-fied retention responsibilities or locations are defined. Vendor Surveillance was of the opinion that QA records were retained at 4100 Clinton Drive. QA
'. Audits was of the opinion that Engineering retained QA records. Q.A. project personnel assured the auditors that the retention area for all QA records was at the Site QA Vault.- The QA Vault Supervisor says they have only site-generated QA records in the vault for retention. And Engineering says it keeps only " quality documents".
To compound this further, official procurement documentation is already at j HL&P, designated as the primary file. Site Subcontracts says official records j are at 4100 Clinton, Bldg. 03. Purchasing says it is Building 01.
Each organization has its own filing methodology. Purchasing does not micro-film; QA microfilms (2 copies) by reel and frame identification; Engineering microfilms and identifies reel number only which slows retrievability.
Purchasing files by purchase order numbar; Engineering files by TPNS number and vendor documents are assigned a TPNS number. Quality Assurance uses a forin of a TPNS number and vendor documents are not renumbered but are filed by vendor code. The site QA Vault files by docunent type and does not cross
! reference.
l This is only a sampling of the findings. l i
l
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ADR 8 Page 3 of 4 Reconenendations:
The records problem for South Texas Project does not, at present, lend itself to an orderly turnover of documents to the owner. This will, if lef t unchecked, very likely have impact on the acquisition of the operating license. Were sufficiently decisive actions taken ininediately, this problem could be routinely solved, but would involve a number of manhours in order to assure physical presence of the necessary documentation. To delay in this effort will prove costly.
One of the most difficult aspects of turnover is the various possible encodes being used:
o TPNS - Engineering and vendor documentation o TPNS (varies somewhat from Engineering TPNS) - QA documentation o Vendor codes - Vendor Surveillance docunentation o General Memoranda (and filing technique)
QA Engineering Construction Procurement o Correspondence (and filing technique - alpha pair acronym access)
QA Engineering Construction o Purchase / Subcontract Number - Procurement / Subcontracts o Subject File Code - HL&P A second aspect is that each STP organization has set up its own filing technique without real consideration given to same function being performed by a sister organization. Example: ODR's; Engineering files by GM number; QA by 00R number. Example: Weld Procedures; Engineering files by GM number; QA could not retrieve; Construction by GM number.
Document locations are indeterminate. Responsibilities for retention must be detennined so that backfitting can be done successfully to assure presence and completeness of documentation. Frequently, necessary data are attached to correspondence or memoranda (as noted above). This of itself is not a problem, but computer entries in the " subject" field do not show a relevant document number of any kind, only an abbreviated or "first" word entry. This means that unless one knows the correspondence or memorandum number or can guess at the date (which is not too likely several years later), the data cannot be retrieved without expending considerable manhours, or worse they cannot be retrieved at all.
F WW 89 6 ##**
- 4 mit e6 e sa = .4 .p 4 4 _w , p,,
eeg=- De pove t g Gene w .we e 4 - #W4 @- W G h+ ge.p ee e a me-.e-# eDeee e.4 w* *&&*.c4
. i ADR 8 Page 4 of 4 Cross-referencing of documentation in the QA vault was not in evidence during this audit. The vault supervisor indicated that this practice was not done since theirs was a repository function only. However, this should not be the case since ANSI N45.2.9 requirts visibility, traceability and retrievably.
A matrix of the various codes used on relative documentation should be developed in order to successfully pull together the necessary data packages from all sourCts.
Texas Utilities' Comanche Peak Station is well into a significant records turn-over program. Retrievability is excellent. Tracking through matrices to data package location is done .through computer with a manual backup. It is a rele-vant and simple system being pulled together by knowledgeable persons in an orderly and sensible manner. Currently, the turnover program is about five months behind the actual construction effort; the program was started in --
January 1978.
Serious consideration of this turnover method for application to STP should be given.
Further, it is recommended that the STP microfiche be properly indexed and housed in cartridges to fit into readers located in DCC areas as well as in the field.
This provides a better control of documentation to assure that current data are being implemented across the board. Again, Comanche Pead DCC uses this technique and it is proving very useful and appears to be easier to control the access and
~
use of control-led documentation.
At present STP QA and Engineering documentation is being microfilmed. This micro-film is indexed by reel number only. This means that in order to locate the document within that reel, the entire reel must be run since the microfilm copy is not indexed by frame number as well. Unless the microfiche or the microfilm is adequately indexed, use of the design documents for replication in future work will be a tedious task, if possible at all.
s i
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_ _ . . _ _ _ _ _ _ . . . _ --- ..~- _. _.-- -- -- - -
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF l sie AWoiTso one AMigArgoM i2:AWoiT Mo. ile AoR Mo. sai Aom Coos B&R Engineering QAMRS 3 9 iSl os.CWSSao wlTM s iso mePoRTso sv s g(7 oATsa iSiCAfseenvi J. Paden J. Norris,R. Kingcaid ' 6 / 9 / 78 Oin Dia Oisi its ooCuessMT vioLATeo Amo PAR AoR Apoe iCITss.
STP-DC-024, paragraph 2.3 and Figure 1 " Form 200.60 is submitted by the supplier to the Engineering Project Manager (EPM). Engineering, with the assistance of Purchasing, is responsible for the review and disposition of SDR's in a timely manner consistent with the engineer _ing,, and constry.ctj9n sc.h_edu]e " _ __ __
ii .: ..s .v Ar M..
b There was no objective evidence presented to docunent that Purchasing is involved 3 in the review of Supplier Deviation Requests (SDR's) for cost impact. Further, O the SOR Form (200.60) does not contain an approval spot for Purchasing as required 5 by STP-DC-024, Figure 1.
C i::: Po T MTI Ak m Po 4T a gus os PiCasMC, O vas O Ma ilai AsCowas sMo ATaoMS:
Comply with the procedure and revise Form 200.60 to include a place for the
- approval signature of purchasing.
l' in s asseoMSs Ass.oMan to, ; ties ass oNes aus insi Apenoveo ev. jasosoAts. ,
L. E. Hayden ! " ' ' '; f AM Goubo ! 7 f2 i f Ts i To be completed by audited organiistion i n n Co = = sCriv e ACrio M asseoNes siMC6uos sCNeou6so Come6stioM o Ava I ii. .u...r1 v.
!'ii.i o A / r s/ , I i303 PRawsNT ATsys ACTBoMs i MC6uos SCManuuso Coup 6sTBoM o ATs '
inni suomittso ev. ,inat o Ars.
- 1 / / .
To be completed by B&R Quality Assurance
- naves. on es oNes, is. aa view s. .v. ;issi oAv ,
C Satisfactory C Unsatisfactory l / /
ta.:assuursorve=arCAri M. inn vsairiso evi ;iasi o Ava, O Satisfactory C Unsatisfactory l / / ,
is. a s = A.=.. : . C6..so s v . ::: o Avs, 1 i
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. . . _ ___m.__.._ _.. m .. ._ ._ ._ _. ._ .
> w4 - % Brownf5RootJrr.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas ProieCt JOB NO.: UNIT: PAGE: I OF l sin AWO T.O OmO Ama2 AfiOM ial AuOs? MO. :::AOm NO, ialAOR COOS B&R Engineering QAMRS-3 10 a t: D eSCUSS O miT M s is, msPOmTs0 Sv t gati O ATes i01 C AT sGO N Y A. Geisler i 6/15/78 Orii Giu Oin i., OOCu meMT vtObAT s0 AMO P AN AOR APM iC Tsj e STP-DC-001-F, paragraph 2.7.1 " Review drafts may be issued simultaneously for interim use and review. The expiration date of the interim use will be shown on the cover sheet, and is usually 60 days from the date of approval."
g Engineering Procedure STP-DC-017-B. " Computer Program Documentation", has been w issued for " Interim Use and Review" since 2/13/78. No expiration date of the y interim use is shown on the cover sheet.
W C
iiii ,O T MT Ab 2 PO RT ASba O P.C4 MCY ,,
O vs= 0 "O assi asCO==saOAT:Cas.
Revise procedure STP-DC-017-B.
1 s i s i . s . O -. . .... - s 0 TO , -
.. Oo s A,..OveO.v.
iii.i O A r s. i L. Hayden li . .""'s..O *J f AWQanuoo -
i "I / L2./ I B To be completed by audited organization tire CO = =sCTev s ACTiO, ass,0=es, o=C6vOs eCnsOv6:0 CO.,bs? O O ATai l
~
n ei ove=iTTs0 ev.
l'siei O. /T s/,
(30. Pe sv NT Afiv e ACT80Mi ssMCbwOs . cms OWbs0 CO Pbs f aOM O AT isii swe=sTTs0 o v e j i 41 Cars.
! / / j To be completed by 88 R Quality Assurance in n a svi s O, . ..,0 a . ii.,aeviams0. . ;ines OATa>
l C Sotisfactory C Unsetisfactory t / /
is.i assu67. O, v s r CAT O., seri veniresO ev. ;iseiOATs.
O Satisfactory Q Unsetistsetory t / /
is. . s A .. . . ii.e C60.s0 e v , inn OATS, t
g OA......
Ae .'O e em e awmyo W == e W*d 4 '=+-em-ea-o a6 * * *
- %***-W'E * **
y-- - i,-- __ - --. ,,e - , .-w w- --,--.-
p1 6fCWTl@RCOtJCC.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: UNIT: PAGE: I l OF til AUo4 Tao o#G A888EATIo8e (St Avol? No. (3) Ao st eso. talaos Coos B&R Construction QAMRB-3 11 (Sl otSCu..so wtTMs 16lMsPomTso .Ts g(7P O ATs (4)CATsGomy:
R. Tavlor L. Crowe, R. Klimist i 6 /15 / 78 Om Om Oi>>
t.l coCuassNT wao LAT ao Amo PAR AG R APM (C87 l3 ANSI N45.2, Section 7 "Those participating in an activity shall be made aware of and use proper and current instructions, procedures, drawings and engineering recuirements for performing the activity."
ii. ...s v A 7.o . . .
There is no objective evidence that any continuity exists for the fabrication and/or D installation of pipe; i.e. , 45 ft. long by 30 in. diameter aluminum-bronze pipe is 5 moved to the pipe fabrication shop where it is being double joined to a total length 5 of 90 ft. by the use of powered turning rolls and automatic weld equipment. The b shop foreman stated that he was fabricating pipe in accordance with construction o procedure A040KPMECP-4, which he had at his work station. The pipe superintendent stated that this pipe was being installed because there is no cost code for fabri-
- cating pipe over 21s in. diameter. The Senior Mechanical Engineer stated that this pipe was being installed and the work was being performed in accordance with con-struction procedure A040KPMCP-2. This procedure was not available in the pipe fabrication shop. , , , , ,, , s ,, ,, ,,, ,, s ,o . , , s u o s , , C , s ,, c v O van d ~o
( 33 m:Co me se McAT8o8eSe Provide the correct procedures to the working level personnel. Assure that the involved supervision understand the process and procedures which apply to work being performed in their areas.
iise mes,oa n A n.Gaso To, ..aaus aowso ev. J
- ii. .. sie, A
- ti.e o Ars.
J. Monroe ! * ^ ' ') f AH 0di % ! 7 / 7./1 7E To be cornpleted by audited organization lif t ComasCTave ACreo8e maspomes. Is8eckuos sC8esoukso comerkatsom O Afs3 1
insisu - TTeo v. ;ii.i oats,
! / / ,
(See P#sVsNT ATIV: ACTeoma (tMCI.uo SCMaoukso ComerksTeoM o ATal (til SU.eeITT ao .v s (1333 O ATat
! / / j To be cornaleted by B&R Quality Asairance
- navis or.. ..s. in i navis-so evi ;ia oats. l C Satisfactory Q Unsetisfactory l / / i la. mesukTs or vener:CAfsome tarp vsmsreso ev, jtsat OATS. j Q Satisfactory Q Unsatisfactory l / / ;
. as=A... : .. C ous ev . :: o ATs, o
G A-. 54
= - - ~ ~ - = .
. . . . . . . . . . _ .. - . - - - = -
l --- - -
- . Cmrf -
.i BrownURccUnc.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOs NO.: UNIT: PAGE: I OF l it) AussTso ong AMIEAYeoM tal Awolf Mo. (3)Aan No. tel Aos Coos 88R Quality Assurance (Site) QAMRB-3 17.
nio Cuws wn-s nimenomvs. sv. ,ni Avs. ni Carsoomv.
J. Norris, R. Kingcaid e 6 /15 / 78 Oso Oisi Oni (9) ooCunesMT viobA7so AMo PAR AGa APet (CsTsjs ANSI N45.2.5, Section 4.8 " Pumped concrete must be sampled from the pump line discharge."
iisi o.= mvAr.0-s, 3 During the placement of concrete for lifts CI-1-W28, 28A and 33, the PTL y inspector was taking samples at the truck discharge (i.e., the pump line e intake).
2 5
o to si poTanTaA6 marom7 Asks otrocasmCv O ves d Mo il33 esCoasassme ATioms:
Comply with the requirements of ANSI N.45.2.5.
=
18 38 maspones Asseemso To 1 jtsee assoonse ous tissAnemovso ove . jtsel oATas j C. Vincent ! * * ") / M % ^E ! T /l"2/ 78 To be completed by audited organization ~
(8 71 Co##sCT8vs ACTeo's asseomets temCLuos sCwsoukso consykstson oats Isopsusass77so ave taas rasvamT Aveva ACTsona tanchuos sCMapukso Conspss7som 0 A783
!'isen oAve.
/ / ~
tastsusasertso ove j taas o ATE.
! / / l To be completed by B&R Quality Asatrance taas msvesw or esseomos, O Satisfactory Q Unsatisfactory taas navesuso evs itasiOArt. }
iasi assui.r or vener8Carion, f / /
O satisfactory lativensrise .ve .jisesoArs.
D unsatisfactory ! / /
no, as- Amme,
- n. C 6. .so . . . ne, oars.
e A 403 8
.. - ~~
g g e m.D # 0*.M' 9t' G h6'O**
- - - - - -- , . , - . . -- , ..-m- -. - - . - - - - , , . - , - .
.:=== - . . . .
--=.:..
? t as~ :- T' W W C d . W.C.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF 2 til AUoeTE. O ne Ante A T60M (3) AuOlT reO. (3) Ao m peo. (.B Aon Coo t B&R Quality Assurance (site) 0AMR8 3- 13 (88otsCWSSs. wlTMs (.) mapO RTeo av i g(?l . ATE: lS)CATEGOmv4 R. Parrish R. Kingcaid, J. Norris '
(et OCuessMT veO6ATED Ano PAR AOm Apoo (CETala 6 / 15/78 Oro Oiu Cini ANSI N45.2.5, Section 4.8 "In-process tests shall be performed during the course of construction . . . A list of the required in-process tests is contained in Table B . . .
Material Requirement Test Methods Test Frecuency u Concrete Compressive ASTM C39 Two cylinders for 28-day test from
$ Strengths each 100 cu. yd. or a minimum of u
one set / day for each class of b concrete C _
____g____.______.______....____________________.__.___________.____________ ...
A review of the daily compressive strengths register as maintained in the Quality Assurance Vault gave no objective evidence of compressive strengths test performed on concrete for the days of May 1, 2, 4 and 5. Pours were verified as being made on these days and are listed on the attached sumary. ,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,,
..., m.CO _ . MOAT . ..
O v== C3"a Ccmply with the requirements of ANSI N.45.2.5. l i . , e s ..O ..s . ..,0 - s o TO ,
- ..,m..,0..eoo. ,,,,.mov.eV,
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- ..,oA7..
C. Vincent * * ' ') 6y(bielau
! f ! 7 f afl TB To be completed by audited organization (171 Co mmeCTivs ACTIOm mas >Osess, gaseChuos sCeesowLao conseksTIO*e D ATE 8 i
teel sweessTTeo evi l(top OATas I (306 Pm Ev f MT Af tv t ACTDOM s (488CbWo t sC8eEou kEo Cone rkgTIOfe o A Ts)
\ / /
tailsuomelTYso ev ltaal o ATs.
t / / _
To be completed by B&R Quality Assurance tsat utvesw Or asseOsesas (a.t paveswap eve gtasl cATss 1 Q Satisfactory D Unsatisfactory inei musuwTs or veni,iCATion, l / /
inn vsmiriso T.
D Satisfactory D Unsatisfactory (insioAfza lass asseAmuse
/ /
tael CLosso ev a tast oATas
. A... .
h ean a wetw
- 8' e e.$ m.g> M mMeeme 1
. . . _ .~ .- ..
ADR 13 Page 2 of 2
SUMMARY
During a review of documents contained in the QA Vault, it was noted that com-pressive strengths tests, as required by ANSI N45.2.5, Section 4.8 Table B, were missing for the days of May 1, 2, 4 and 5. Test records were witnessed to be satisfactory for the period preceding these dates and for May 3 and 8.
R. Kingcaid phoned the B&R Q.C. Subcontract Surveillance Inspector for Pittsburgh Testing Lab, Russell Parrish, on June 14, 1978 and called this to his attention.
Parrish stated he would review this to determine if in fact these tests were performed and the writer was to phone back later the same day. When the writer phoned Mr. Parrish, he was advised that there were tests performed and these tests were submitted to the Q.A. Vault for storage and that they were probably misplaced by the clerks. Mr. Parrish stated the writer should speak to Teresa Vengler, Q.A. Vault Supervisor, the next day to locate these missing documents. ..-
On June 15, 1978, the writer again reviewed the file and advised the clerk that Mr. Parrish indicated these test reports were in the vault. The vault clerk phoned Mr. Parrish to determine what the appropriate reference number was to enable her to locate these missing tests. Mr. Parrish advised the clerk that there were no pours made on the days in question and due to this no tests would have been performed. The previous day, June 14, Mr. Parrish advised the writer there were pours and tests for these same days.
The writer reviewed the Q.C. Civil reports with Mr. Allan Hammons and determined the following pours were made for the days in question:
Date Pour Number 5/1/78 ME2MM1-PS 5/2/78 ME2 MMS-PS 5/2/78 FH2W12-C 5/2/78 FHIS2RL 5/2/78 MEWOO7-03 5/2/78 MEl-W001-100 5/4/78 MEl-WO12-06 5/4/78 MEl-W0ll-01 5/5/78 NEl-WOO 4-04 5/5/78 MEl-W001-04C 5/5/78 RVS-1 (Grouting) 5/5/78 RVS-2 5/5/78 RVS-3 5/5/78 RVS-4
,. - _ , - - ~ -
3 , . - -
=
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Brown &RootJnc.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT
! PROJECT: South Texas Project Jos NO.:
4 ist avosyso oceanizarson UNIT: PAGE: I OF 2 isi Avos7 seo. I:3^'"ao- <*l 'o " Coo s B&R Construction QAMRB-3 14 iio co so =,va. . . . s,. .e so . v . .
iin ants, ies cars.. v.
R. Kinocaid ' 6 /16 / 78 Oso Oisi O:28 l : oeCuaseMT veOLATso AM. para 4RaPUG ictTalt l A040KPCPP-1, paragraph 3.1.1 " Prior to qualification testing Journeyman l
l Applicators will attend an application school provided by those paint manu-facturers specified for containment and other safety related areas."
TT.i ..e .wrr..Ts, - - - - - --- - - - - - - - - - - " - - - - - - - - ' - - - - -
U Applicator's qualification records provided in the Q.A. Yault contained no objective evidence that P. Rackowitz or E. Longoria were qualified by Ameron for either
! Dimetcote 6 or Amercoat 90. Appifcators Coating Reocrds for RCB #1 - Shell Liner g -(Amercoat 90) dated 3/27/78 indicated P. Rackowitz was applicator. Applicators o Coating Records for RCB #1 shell (Amercoat 90) wall dated 3/28/78 indicated E. Longoria was applicator. Applicators Coating Records for RCS #1 - Shell Liner (Dimetcote 6) dated 3/19/78 indicated E. Longoria was applicator. '"
I i
ille PGTsNTlab NsPORTaG6s osPICasmC,
- is as escoasseamoaTeone.
O vse (3aa i
l Comply with the procedure. '
i i o ss assme=os aseeenso vo. poiamenevso ev.
J. Monroe joesoats.
l'tian * *messomos
- *) f ous A W Ilm e, is i 7/ t'Af 76 To be completed by audited organization z on comescTsus acTsem asesomsse esmC6uos sensou6so coasassveese eatsi ,
I t
i i
oss susana77so ove ;isei saves i
j inei svaaravive acri =,onc6uos seasovuse c . 6stion oarsi
/ / ,
i l
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! l iso eu rvso v. pass oats,
! ! / / i
- To be completed by B&R Qaality Assurance can navis. ., s ..s.
O Satisfactory is. navis-se av. pies ears.
Q Unsetisfactory g i isei assu6ta er vsenrication.
l // .
een vsminise se, jise, oars.
O Satisfactory Q Unsatisfactory '
sa nessanas, t //
ines c6eese evi isn onts, e
Ga 448 a
- ==-a-
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- W- * * " * * * * " * * * * " '
m ., .-,%. ._w.,.,_+e,._.mm._.v.7_ p w-,, -- q '
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,7, . . . _. . . .- , _ ___ .; _. __
.' t ADR 14 Page 2 of 2 RELATED CONCERN The QA Vault contained a record of applicators attendance and certification from Ameron (Dimetcote 6 and Amercoat 90). However, this certification by 12, 1976 for Dimetcote 6 and a duplicate Ameron list (by name wasdated by)a August list dated27, October 1977 for Amercoat 90. The names contained on these lists (9) were the same. A concern is expressed that these original nine names (applicators) have not stayed on this project since August 1977 and if any replacement personnel have been hired (obviously the case as referenced by Rackowitz/Longoria), these new personnel have not been qualified in accordance with the procedure mentioned above.
f 1
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.= . - . _ _ - . . - .
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: UNIT:
(t) AvatTso o #e AM13 ATaoM PAGE: 1 OF 2 (38 Avog? No. (3) Aom No. tal Aom Coos B&R Quality Assurance QAMRB-3 15 tot osscussso w TMs unespontso ave girl oafs: tot CAT sonv.
A. Holbrook R. Klimist, L. Crowe . 6/9 f 78 Oiii (9) coCuMsMT V806ATso AMD PA A ASR Apoe (CITals O ni O ni (see attachment) n . o.ss .v A 7.oM.,
Adequate measures have not been established to assure that conditions adverse to U quality are promptly corrected.
z u.s G
On the date of the Audit. June 9,1978, twenty-one (21) open 00R's were listed on the 5 Houston 00R Log. Of these 21 DDR's, fourteen (14) had been open for a period longer c than 60 days, with two (2) open for 9 months.
In the May Monthly Progress Report . . .
(dated June 6,1978), forty-six (46) open 00R's were listed on the Site 00R Log. Of these 46Overdue".
position 00R's, twenty-three (23) DDR's stated that the resolution status was " Dis-(t 43 poTsNTI Ab RsPQ NT Aaks osF041s MCv O ves ($Mo (183 RsCo MM sMc A r8 CMS:
provide procedural requirements for prompt response and resolution of 00R's.
Assure upper management involvement in DDR's which are not resolved expeditiously.
t nai.ss,oM.s A.s. oms. ... -
ous H. paoerno n i A ,..ove .v. jo. oars, i ln. .s..o M.* i * ' *} M Goh s w ! T f12/TE To be completed by audited organization (erl commscTeva ACTsose nas poM.s e (sMcLuos scManukso courssYeoM O ATel i
l teel suom TTao ove ;ts.) oA rs 4303 PWsvsMrAfiva ACTeoM4 (IMChuos sCManukso ComphsTIoM o4Ts)
! / / ,
l I
l ca n su s=iTT eo .T . pass oArsi ,
! / / l To be completed by B& R Quality Assurance
! u n msvis= or esseoMes. taas msvisuso sv. DiesoArs. '
O Satisfactory D Unsatisfactory nei assu6ts or vs=iricAfioM.
l / /
- O Satisfactory sin vsaarino sv. pass oars.
C Unsatisfactory n..sA..., l / / l neic6an==av, ou oars.
.A..s-a y 4 ..,.m.s e~ ' "~ #'
- , . w. - . _ _ - . - - -_g- w : ...--.,.-%_.-w- , - .-- -
= . ....;- .. .- .-.. .
I :
ADR 15 Page 2 of 2 Document Violated and Paracraoh (Cite):
10 CFR 50, Appendix B, Criterion XVI " Measures shall be established to assure that conditions adverse to quality, such as . . . are promptly iden-tified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is deter-mined and corrective action taken to preclude correction action."
1 J
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- E*"4 * '*-* '9 * ** * - * ' ' * *** " " ' ' * " '"'* '*
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_ _ . , _ . . _ . . . ~ . . . ,. ---.-.~w c.---- -
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PRoJtcT: South Texas Project JOS NO.: UNIT: PAGE: 1 OF 2 ili .W.i7 8. . .M .E.TI. M is i .u.67 m.. i 3i .Q . M. i. ...C..E B&R Quality Assurance (Audits) 4AMAB-3 16 isi .uven. . v-, _
i . . . . r .. . . . ,i,i.. ., i.i ca va.....
G. Bulcken R. Kiimist '
6 A6 /78 Oi'i 0 :: O'>i
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(seeattachment)
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iii.. .. e s .
T. H. Gamon ! * * ") f ii. .k...(Gniw
. U. ! 7 /l2/76 b To be competed by audited or$nization is, c...scriv s .cre.= es =es. iinc6 wee oc=e.wi.s. comai.srs. ..ves i
k ii.: ev. meets. e.,
i isei . eat.riv e .cre.a. i aci.v.s une.vi.e. c. sere.= ..rsi l's...es. / / i in n e ove=stres e,. pase..,s,
! / / ]
To be completed by B& R Quality Assurance inne . vie. ., .es au. is. .e v ie... e v . pani.. .. I C Satisfactory Q Unserisfactory
. . . . . .. r s . , . . . . . . r e. . .
l / / i i.,e........,, p.. . 1=,
Q Satisfactory Q Unsatisfactory \
is......... l / /
iseic6....... iiii .es. i
. ....i .
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- / I -
AOR 16 Page 2 of 2 Document Violated and Paragraph (Cite):
ANSI N.45.2.12, Section 4.3.2.1 " Checklists or procedures shall be used to ensure depth and continuity of audits. The audit checklist is intended for use as a guide and should not restrict the audit investigation when findings raise further questions that are not specifically included in the checklist."
ANSI N.45.2.12. Section 4.3.2.3 " Selected elements of the quality assurange program shall be audited to the depth necessary to determine whether or not they are being implemented effectively."
Observations:
- Audits are not being investigated to the depth necessary to determine the effectiveness of the Quality Assurance Program ard its implementation. In reviewing the checklists, findings and concerns from audit reports BR-15, BR-18 BR-21, 8R-26 and BR-28 there is a clear indication that the audit ...
checklists have been prepared with a minimum of investigation, that the checklist items have not been thoroughly reviewed by the section manager for relevancy, that in several cases more items have been listed as "not audited" or "not applicable" on the checklist than were audited and that there is, from the nature of the audit findings cited, only a cursary audit performed.
Recommendatiens: '
Detailed management review should be performed of the effectiveness of our audit program. This review should include evaluations of audit management; schedule and frequency of audits; scope and depth of audits; qualifications of auditors not only in auditing techniques but also in knowledge of reguia-tions, standards and implementing procedures relative to the areas being audited; and adequacy of manpower within the audit group in order to provide a complete and effective audit program.
6 f
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. - _ - - - - _, . . _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ - . _ - _ _ . _ _ - . _ ~ _ _ _
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.:
s ii .W..T.. . .m i..Ti.es UNIT: PAGE: I OF l iti .u it M. ill ... M. .a ...Co..
B&R Quality Assurance (Audits) QAMRB-3 17
.i . .c w u. . r . i....,...,,
G. Bulcken , i,i . . v . , i . , c. v . . . :
J. Norris, R. Kingcaid i 6 / 9 / 78 Om Om Coi
... CW es.M T v s. k. r.. .se. .. . .. . . M iCi? .i s 10 CFR 50, Appendix B, Criteria XVI
" Measures shall be established to assure that conditions adverse to quality . . . are promptly identified and corrected.
Ti.iT..T. vTrs.T. . - - - -- -- - ""- ~~ - - - - ~ ~ ~~ ~ ~ ~ ~ - - - -- ~
> At the time of the audit, seventeen (17) ADR's were unresolved or still out-E standing. Two (2) of these are over 12 months old (ST-6.1, ST-6.2); two (2)
W are 7 months old (ST-8.1, 57-8,5); and 5 others are over ninety (90) days old (BR-24.1, .2, .3, .4 and .5).
$ The majority of these were noted to be " awaiting g implementation." However the closing out of these are not being performed in a .-
timely fashion.
.... ,.. .. .. .,..w...,.c>.-c, ii.,...............
O vs. Ga Recommend that acceptance of corrective actions be predicated upon more timely implementation of corrective measures and that action to verify implementation be expedited.
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m au fow. . . . 1.. .Q..S. ,, ;i e . .. . .
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To be completed by audited organkation
- :: c. ...criv .c r e.= . . ... . i .a s 6u. .c o .w i... c.. .r e.= . . v. s
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To be completed by B&R Quality Assurance iss .. vie..,.. =u.
O Satisfactory i n e .. v . . .. . . . asee..,.
C Unsatisfactory i s . . . .. r . . , v . .c a r . . ,
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1 QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF l sie avo n o o n *=.mario :: .uoir ... isiana ao. i.iao= Coon l B&R Quality Assurance QAMRB-3 18 i . Of9CW.SSO -IT M s i. R EP.NT RO .Y s giti= ATE: (. Ca ?S Go # 7, J. Norris, R. Kinocaid ' 6 / o /79 Oiii Cia: Olii
... DOCW ass m? vechAf go AMO PA R AO N APM ici?Es a STP-QAP-2.2, paragraph 5.2.3 "Approximately thirty days after an issue has been released, the Program Document Log Record shall be reviewed and document holders who have not acknowledged receipt of the transmittal shall be contacted to assure that the transmittal was received."
ii . ..u . var ...
D Procedure Revision Log for Document Transmittal Acknowledgements is not being
$ maintained. Clerical personnel stated 2nd Notices of Acknowledgements were not being id e sent as the receipients were abusive of the 2nd notice. QAP Transmittal #29, Correspondence #STQ 2395, noted 4 outstanding acknowledgements. QAP Transmittal #39, Correspondence #STQ 2629. noted 5 outstanding acknowledgements. QAP Transmittal #30 ...
Correspondence f5TQ 2330. noted 2 outstanding acknowledgements. NOE Procedure Transmittal #5, Correspondence #5TQ 2456, noted 3 outstanding acknowledgements.
iii Pe tE NTa Ak R EPO RT A b4 oE FIC4E MCY O vs. O ao
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Comply with the procedure.
i n si . u .u . ..... va, ;ii..-n .n ov. .... ....... !
iii.i aara. i W. Pa pe rrio ! """) / AM Q*N % ! T /Lb78 To be completed by audited organization
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68.. PA Sv 5MY A fiv 8 ACT BO.si iiMC bWO S . CMS OULEO CoMPtsf.en O A TE insi. .. rno .v. pias oan.
' / / 4 To be completed by B& R Qusfity Asastance in ni a evie w or es .... isei asviews . . ;ia. oats.
Q Satisfactory D Unntisfactory "
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is., as.v6n ., v sas,icarien, seri venerien ev. .<sses ears.
O Satisfactory D Unntistsetory '
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: UNIT: PAGE: I OF 2 (1) AuoITao o RS AMisAfgoes (33 Agogy me. (3) Aom Mo. (4) Ao# Coos B&R Quality Assurance QAMRB-3 19 telosecussao wtTne tegnspo nTso svi g(t3 OAvss tel cAvasonvi A. Geisler i 6/23/ 78 Osii Oiai Oi>>
(9) OOCumsMT vDo6ATso AMo PAR ASN Ap.e (CITsje (see attachment)
'ii.iT..e avrrieve,- - - - - - - - - - - - - - - - - - - - - - - - - - - - -
y (see attachment) it!
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,e C ves hno (ISI #sComenesme AT8cMes I
- 1. Perform a complete inter-department review of the Q.A. Manual to determine if it accurately reflects the present methods and resolve any inconsistencies. (this sho0ld be done prior to the ASME Audit in September,1978).
- 2. Revise Q.A. Procedure ST-QAP-2.1 to provide a more expeditious method of preparation, review and approval of 0.A. Program Documents.
lest asspones Asseemse To jleep massones aus tseeArpmoveo ove jties oats.
H. Pacerno ! * * * 'I / AM M 'O ! 7 /Q/76 To be completed by audited organization is71 comescTsys AcTeon essponese(seeckwos temosoukso comerksTeose o ATel e
si i su ..Ti s v. ;ii., o A rs, f / /
taes posveset Areve AcTeon, tesec6uos scusoukso consp6stsoes o Ars3 I
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i i tais suomesTTso era j tsat oats.
i / /
! l To be completed by B&R Qusfity Assurance inni svis o, . sponsa. is. naviewse .v. ;ises oavs.
O Satisfactory Q Unsatisfactory l / / ]
taet mesu6To or venericAf tons tarpvenersso er, jises oats.
Q Satistsetory Q Unsatisfactory / /
l taes meas Ama.s. (see c6osso ov e assi oats, o . ... s. a
- I ADR 19 I Page 2 of 2 Documented Violated and Paracraoh (Cite):
10 CFR 50, Appendix B, Criterion II "The applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the
!~ activities, a quality assurance program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, and instructions and shall be carried out throughout plant life in accordance with those policies, procedures or instructions."
t Observations:
i
' During the course cf the QAMR8 Audit, the auditors discovered in many cases that the QA Manual and the QA/QC Procedures did not reflect the actual manner in which work was being performed on the project. Generally, the reasons given for these ..
inconsistencies were that the manual or procedures were in the process of being j revised and work was being performed in accordance with the revised methods.
However, in some cases the revised methods have been implemented for an extended period of time (up to over 2 years) without the manual or procedures being re-vised. These types of situations are unacceptable and should not be tolerated.
The Q.A. Manual must be rigidly implemented until such time that revisions are approved (including approval by the Authorized Inspection Agency). Procedures implementing the current Q.A. Manual requirements must be developed, approved
' and followed until such time as the procedure is officially revised or deleted due to completion of an activity. _If revisions are required to the procedures, those revisions must be prepared, reviewed, approved and implemented expeditiously i
in order to minimize the transitional impact from old procedure to new procedure; but in no case should revised methods be implemented without an approved pro-cedural revision.
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' OUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JoS NO.: UNIT: PAGE: I OF 2 ill AUo8Tso o#4 AMIE Af ton ialAUoITMo (al Ao s peo. gel Ao# COOS B&R Engineering QAMRB-3 , 20 m o eus== .T . i.i.s.o.Tso .v .
R. Peverley, T. Moyer im oATsi m cATsao=v.
R. M. Klimist i 6 / 6 / 78 08's O ssi O t s.
(9) ooCualesNT weet Af so Arco PAR ASR Apoe (CITels
- l l
(seeattachment) 7,,,,-,.,,,,__---------------------
D The auditor found the qualification training files in EDec incomplete. Docume'nta-5 tion of required training programs was missing in many cases, thus providing no O evidence of attendance at such re 5 were also missing in many cases. quired programs. Personnel qualification records o
l (t 9) PoTsNTl Ab RsPORT AS6s os PIC3sNCv It al RsCoasmespeo ATaopese O vs= Go Review and update all qualification training files to assure their completeness.
If necessary, provide supplementary training to backfit the requirements of STP-PM-006-C. -
A...o-se 70. - 1 oos A, o.co.v.
i.a. L..s*T.- Hayden i.e li... .as *
- To- 'j, f @ Q, *n t. g li... 7o AT s.fn f tg - I To be completed by audited organizaiion Is78 commsctsys AcTson assposessa Isaectuos scusoukso consessveose o ATs3 I
(n el sweestTTeo ove 'ites o ATas gaat paesvamTArava AcTeosos gesec6wos scusoukso conspLsteope OATel
! / / ,
(att sweessTTso ev j esal DATs
! / / J To be completedby B&R Quality Assurance taas navesw or essposses.
(s.t neveawse avs Q Satisfactory C Unsetisfactory itaaloArsi j f ./ /
taen mesukTs or vamerscAfsosse ta73 weasesso ay, j taen s.ATas O Satisfactory Q Unsatisfactory is. ... A. s.
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is., c6.sso Sv t (all oats o A .a.n
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ADR 20 Page 2 of 2 Document Violated and Paracraoh (Cite):
B&R QA Manual. Section 2.3, item c " Personnel qualification records shall be maintained by the responsible department."
STP-PM-006-C. paragraphs 2.5, 2.6, 2.7. 2.8 requims specific documentation of personnel indoctrination and training be filed in EDCC.
STP-DC-015-E, paragraph 3.1, requires specific documentation of personnel quali-fications, including training records, be filed in EDCC.
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF l 19 8 AWOtTED O mG AN t3 ATION 83) AUOl? NO. 138 AO R seO. (at AOm COO E B&R Quality Assurance (Site) QAMRB-3 21 (Ol OISCWesEO wlTM s del mEPOstTED s e e g(75 OATE 158 CATEGOmv s J. Cleere R. Klimist i 6 / l?/ 78 Om O'Si Os>>
L,6 OOCW MENT WeOLATED AMO PAR Ae n Apoe (CITEls B&R Q.A. Manual. Section 2.3, item c " Personnel qualification records shall be maintained by the responsible department."
TT.iv. 7mvrf OTs,- - -
The auditor found numerous qualification training files incomplete. The z
D following examples are provided:
$ File of: Documentation Missing C
El C. W. Vincent Q.A. Indoctrination Program, Resume, Relevant Certifications G. T. Warnick Q.A. Indoctrination Program * -
L. W. Perry Q.A. Indoctrination Program, Resume P. Pelengaris Replacement Level II Certification (due 5/30/78)
P. Shah Replacement Level II Certification (due 5/30/78)
(t il POTENTlAn. R EPo mT A akE O E PIC8E NCY O vE= 3 MO
( s al mECOnens EMD A TIOMsa f
Review and update all qualification training files to assure their completeness.
If necessary, provide supplementary training.
(ISI mESPOsesE AsseOMED TO .. l jt e ep mEsPongs Out (g 33 APPROwSO e v e j(te) O ATE:
C. Vincent **' ,
- *) f hMQut_w 'T / taf78 To be completed by audited organizarials
( 9 73 Co m m ECTf v E A CTIO ss m EsposesEs ggNCbuGE sCMEDULEO COMPLETION O ATE) I I
1985sveamgTTED SYs l(3 9l O ATEs taas entwEmTATswE ACveOne geseChuoE sCwtoukEO COsePLET OM OATE3 l / /
.. . so...TT ED e . . : , ... O. T E . ,
! / / l To be completed by B&R Quality Ass:rance (333 mEveEw OP mEsPOmsEs (363 mEveEwEO evs jgast DATE O Satisfactory D Unsatisfactory last mEsukTs OP VEmaPICArecese I_ / /
(af t vEngPISO eve **
O Satisfactory D Unsatisfactory \';st GATas tast mEseAmesse
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: )
UNIT: PAGE: 1 OF 2 '
tal AuotTso one AmaZATaon tal Awoit mo. tal Aom No. tal Aom Coos B&R Procurement QAMRB-3 22 telpescussao vestma gs aspomiso ave g(73oAvs. (as CATsoomys R. Gustafson R, Klimist i 6 /5 / 78 Otii Dia Oiai (93 coCuassNT vio6ATso Amo PAR AG8t AP.e (CITsl l
(seeattachment) si assamvAv. oms.
u z
e (see attachment)
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(ll) PoTamTR Ab e sPo mT ASbs otrICasmCv O vas dno (s al escoheassme ATeofese i
Revise Procurement Procedure STP-PP-0014 to establish a complete training '
program as required by the B&R QA Manual. Implement the revised procedure and provide documentation of personnel qualification and training.
(t al assromsa Asseenso To: ggsaa messomst aus less Aremovso ov jtsetoATE:
W. T. Greene ! " ^ ' ') f AM Qs@ u ! 7 /Q/78 l To be completed by audited organization LIFI Co m e sCTev s A Cyso m maspoussa (smCLuos SCasoubso ComeP6sysore o ATs3 ts el suomesTTao ov e ;gsse oars
' / /
tael resvenTArive ACT3oser 48MC6uos sCasoukso Coh8PbsTBom O ATs) i lati suomearTso sy s j taal OArus
! / / (
To be completed by BaR Quality Assurance taal navssw or assronssa taal naveswso ove jtaeloAvs.
O Satisfactory D Unsatisfactory l / /
(ast assusTs or venireCATsome (373vansrsso sv ltaalOArse l )
O Satisfactory C Unsatisfactory : / /
(ael asasAmsts: (300 Cbosso evs (3:3 O Ars:
G A 443-2
, . . . . ,e e g. e-me '"h* - * * * . " * * . =
l
ADR 22 Page 2 of 2 Document Violated and Paracraoh (Cite):
B&R Q.A. Manual. Section 2.3, item c " Brown & Root personnel are indoctri- >
nated and trained . . . to ensure suitable proficiency and understanding of the requirements of the Project Procedures, the QA Manual, the Code and appli-cable regulatory requirements. Each department or group shall develop pro-cedures, manuals, or instructions which identify the material to be presented, methods of presentation, schedules for conducting sessions, and the individuals, by job title, to be trained . . . Personnel qualification records shall be maintained by the responsible department."
Observations:
There is no objective evidence that suitable and sufficient indoctrination and training of project procedures, QA Manual, the Code and regulatory require-ments is being performed within the Procurement Department. Procurement Procedure STP-PP-0014, " Personnel Indoctrination and Training", does not provide sufficient detail to detemine the adequacy of the program. As a minimum, Procurement personnel should be required to attend the Quality Assurance Introductory Program, PQA-X01-HT. Additional training programs should be developed on the requirements and methods of implementation of ANSI N.45.2.13. " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants" and of the project Procurement procedures and interfacing Engineering, Quality Assurance and Construction procedures. Personnel Qualification Training Records should be maintained to provide evidence of existing training of individuals.
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AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: I OF 2 til AvoITso eme Amsa ATsom tal Auost peo, tal Ao# ao. tal Ao* Coos l B&R Quality Assurance (Site) QAMRS-3 23 telossCussen wsTns gas asPomTso eva g(71 o ATs tasCAvssonv.
R. A. Romeo, N. W. pressler ' 6 /13 / 78 Ossi Di=> Otii i tel ooCuessfe7 vooLATse Asso PAst AGR Apoe (CITsjs i
(see attachment)
I
>. Contrary to the above, owner or other supplied items as per ST-QCP-1.1 E Paragraph 5.1.5. last paragraph, requires only a receipt inspection of the W document package to assure verification of confonnance certificate on material
$ supplied by owner or others.
w Q
1 (19 8 PofsMTs AL RsPO RT AS6s osPSCasNCv O vse @ ao ital asConseesseoATsopes, i t
- 1. Revise procedure to include complete inspection for traceability.
- 2. Review all past, owner or other supplied items, and inspect and a
document on RIR inspection for traceability.
48 88 assposess Asseeseso To, its: Appmovao ev C. Vincent ') /
!' teel massosess ousA u n A _... l'in7es fOATS.
iaf ve To be completed by audited organization 18 71 Co**sCTive ACTsose sesseosessa taseCLuos scossoukso CoesposTsoes oATal J
l ties sucessTTso ove ;gss oats, (301 peswape?ATIvs ACTeoma teseCLuos eCnsoukso CotePLaTsose oAvsl t / /
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(39 8 suSestTTeo SYs ~
ltaal o ATsa
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To be completed by B&R Quality Asatrance inni envis. O, ss.o.a. . navis-se eri ;tasi o ATs.
O Setisfactory Q Unsatisfactory i
tas mesukTs or vensa:CATeone l //
(371 venereso era (taaloATes Q Satisfactory C Unsatisfactory j' ti.i == = A. s. l //
ii., Ci.osso v . isis oats.
.-ee 4 a,
._ . _ _ _ _ _ _ . . _ _ . . , . ._ _ _ - .m ____- - . .- _ . - . -,
- i i ADR 23 Page 2 of 2 DOCUMENT VIOLATED AND PARAGRAPH (CITE):
A. ANSI N45.2.2 Section 5.2.2 "These inspections and examinations shall in-clude the following as appropriate:
- 1. Identification and Marking - Verification that identification and markings are in accordance with applicable codes, specifications, purchase orders, drawings, and this standard."
- 8. B&R QA Manual, Section 7.5 "The QC Receiving Supervisor shall inspect the item (s) to determine the condition of the item, to confirm that identifica-tion and traceability requirements have been met, and to confirm that the required documentation as specified in the P.O. is attached or on Site."
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: PAGE: 1 OF 2 (il AWoiTso op4 AMiEATION (31 AUni? MO. (3) Aom NO. (4) Aos Coos B&R Quality Assurance (Site) QAMRB-3 24 (Sl o:9CWsSso wiTM s (6lmspenTso eYs glT)oATas 463CAfsGOny:
R. A. Romeo. N. W. Pressler i 6 A 3 / 78 Orsi Cia: Oisi (93 o CuessNT veObATso AMo PAm AGR APM (CiTale ANSI N45.2.2, Section 2.2 " Procedures and instructions shall be generated, used and maintained current; these shall contain sufficient detail to provide . . . a basis for . . ., receiving, . . . implementation thereof, and inspection, in accordance with this standard."
ii.i o.se m ATIO s.
u (see attachment) z e
2 b
o (t il povsariAb maro mT Ambs omriCasmCv O vas G Ma tial meCO*eassme ATeons:
i
- 1. Revise the B&R QA/QC receiving inspection procedure.
- 2. Review and process any items which have been received which QC has not yet processed.
- 3. Replace all Construction plaEed Receiving Hold Tags which completed QC signed tags. ,
lial maspomes AsssGreso vo: I tietAPPROvso Sve j(iel oATas j C. Vincent !'te *al*'mesmosess
- ) f out A M Osm, I N 'I / l1/ 78 To be completed by audited organization ti?l ComesCTive ACTIOm messomsse giaeckuos scusoubso CourbsTeese O ATal s i es sv.. TT se e v . : iel oats.
l / / s 1293 MasvsNTATava ACT Oses (IMCbuos sCnsoubso CoMPLETioM o ATs) '
l f
- sv .= iTT s s v . ;inal oats. ;
! / / j To be completedby B&R Quality Assurance lass osview or assmensas taal naviewse eve Q Satisfactory itaal oATas Q Unsatisfactory f / /
inei assui.Ts or veniniCATien. :::: venirlso ev, ;tast oats.
O Satisfactory Q Unsatisfactory (39) esM Amusa l / /
(300 Chesso ev a (3 3 oATsa e
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- i. i ADR 24 Page 2 of 2 Observations:
- 1. ST-QCP-1.1, paragraph 4.1.3, does not define QC inspection requirements for the Inspector; i.e., after he is notified by Construction when does the Inspector perform his inspection, how long can an item remain in a receiving area before QC is required to perform the receipt inspection, and what is the status of the item until QC arrives at the inspection area.
- 2. If during QC receipt inspection a receiving inspection requirement is not satisfactory, the QC Inspector does not put a Receiving Hold Tag on the item until he completes the total inspection and all paper work is complete, which in some cases has taken days. The items may already have a Receiving Hold Tag which Construction has placed on during receipt. There is no pro-cedure requirement for tnis activity by Construction nor should this be a ,,,
Construction activity.
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/. i ~ D w4w Brown &RoctJnc.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOS NO.: UNIT:
(Il AWOITEo O mO AM12 ATIO8s PAGE: I OF I (IlAWat? MO. 135 Ao m MO . (4) Aom COD E B&R Quality Assurance (Site) QAMRB-3 25 i .i oi.Cv..E wit = .
- i. . E.O m T E. 7,
,iveoATE, i CA TE GO m ,,
R. A. Romeo, N. W. pressler '
6 /16 / 78 Oiii Oia Oi>>
(9) OCy asEMT vDOLATEO AMo PAm AO N AP*4 (C87Ela
. B&R Q.A. Manual, Section 7.5 Inspection Record (RIR) . . ." "The inspection shall be documented on a Receiving B&R Q.A. Manual Section 7.5 "For code items, the Authorized Inspector shall be e
notified by_th.e_ Pr_oje_ct_Q. A. M_ana_ger of the receiving _inspe.g_ti.g.n Apt.f_vi.ty. "_ __
ii.i O..EavAT.O .. . _
> 1.
ST-QCP-1.1 does not require a " Receiving Inspection Report" (Exhibit ST-7.9 in y the B&R QA Manual) to be completed but requires a " Storage Inspection Report" w (ST-QCP-1.1, Att. 6-A) to be completed.
5:2 5 2. The ANI was not notified or did the report require ANI notification on Reports S-280-1, S-280-1A, S-280-2 and S-280-2A (Ref. P.O. 6014). . . .
(13 3 POTENTR Ab mEPO RT A e 64 OE FIC8 ENC, O vEs G MO (ISa m ECOM ae toso ATlOMSs
- 1. Revise ST-QCP-1.1 to include the " Receiving Inspection Report".
- 2. Review previous inspections t.o assure that the ANI was notified and correct as necessary. ~
iisimE .O .EA...O-Eo 70. i s i . i A,.m O vE. . .
C. Vincent ! . m* *E..O-.E ' *) f ou t !ii. o ATE, H osIn t n > > ~7 fl3f78 To be completed by audited organizatio'n (3 73 COmmECTivE ACTION RESPONSE s (INCLWoK SCtetoubE. COhe rbETROM . ATE)
(g g) SugesITTEo Sv s l{tgj oATE:
{
(20p PREV EMT AT8v E ACT DO Ms (INCLUDE SCMEoubEo COh0 PbE700M . ATE) l / / 1 i
(til SucessTTro svs j (333 O ATEs
! / / !
To be completed by B&R Quality Assurance laat mEvsEw Or mEseOnsEs taal mEveEwEn avs j ta.1 O ATEs C Satisfactory Q Unsatisfactory l (ass mEsubTs Or VEmir:CATsOme
// '
(373vEmersto eT. 3
,taal D A TE, Q Satisfactory Q Unsatisfactory
- j taal mEks Amsts: / /
taes CLOsEo er a essaoATE:
O A .0 3 4 Em N 89wW p opqww W. eawg e** *6 h ehaseA .w= **W we e =whm.6 -
s &' - W(fRglx C TA-i QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: UNIT: FAGE: I OF I til AuoITso ens Assexaf som tal Auost no, talAom mo. (esAomCoos B&R Construction QAMRB-3 26 IDl plSCussso wlTMs (el msPonTso BY s )
g(7)OATas IG) CATEGomy s j N. W. Pressler, R. A. Romeo : 6 /13 / 78 Otil Oisi Oi>>
(99 a.CutesMT veckATgo AMO Pan Asmapoe (CITala l ANSI N.45.2.2, Section 2.2 " Procedures and Instructions shall be generated, used and maintained current; these shall contain sufficient detail to provide . . . a basis for . . .. storage and handling procedures, implementation thereof, and inspec-tion, in accordance with this standard."
i.9i ..ssav A7 .se g Construction Procedure A040KPGCP22 or no other procedure defines or designates e storage areas, such as warehouses or outside areas, as to level of storage as W required by N45.2.2.
E tesirovemT Aa. maro m? As6s os PeCasmCv 0 Tas G 'ea i133 asComemsMo ATeoMSs Construction procedures should designate warehouses, areas in warehouses, or storage areas for the segregation of items falling into categories of Level A, Level B, Level C. Level D storage requirements.
I tv as a ssromsa Asesenso von itsen assposess ous (e st Aramovao or g j(seeoAras J. Monroe ! * ^") f A tl Qcntu., ; 7 f af78 l
To be completed by audited organization (173 CommacTsvs ACTsom a sspownse geseckuos SCManuban Comentsveon n Avas (t el sweessTTso ev a l(sel OATas l / /
last easysseTATevs ACTsons treeckwos scMacukso ConerssTsom OATS 3 i
i i
tall sweemaTTso eri j taal Datas ,
t / / l To be completed by B&R Quality Assurance 1333 navesw or mascomssa taet asysawso era j tael D ATsi l 0 Satisfactory Q Unsatisfactory l / / '
last assukTs or vanaPICATeossa (173 ventremo ove ,tasi cars O Satisfactory 0 Unsatisfactory l / /
(ast maneammes tael Cbosso Sv s tall O ATsa e
e A 40 4-3
F 'O ww --- -
Brown &RootJrn QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JO8 NO.: UNIT: PAGE: I OF 2 Ill Auo:Tso onG Apeez Af tom lasAuost no, tal Aom mo. gal Aom coot B&R Construction QAMRB-3 23 talosscussEn wsTm lei stEPoseTED ef s g(Tl O ATE: tel CATEGomvi R. A. Romeo i 6/12 /78 Otil Oiai Oin' (el poCu MENT vlo BATED Amo PAm AGm AP.e (CITEle (seeattachment) g,,_,,_,,,g,,__._________-_____
> B&R Construction Procedure A040KPGCP-22, paragraph 3.16.1, allows equipment or g materials on " Hold" status to be released for installation if approved as per s HL&P QA Plan Section 3.8.6. This is not in accordance with B&R approved procedures 2 and the HL&P referenced document paragraph does not cover the subject of release.
b C
(a 18 pot ENTI Al. R EPo mT A S 63 o E PtG4EmCV O vEs G me s e at mEcomutmo Arsons:
Revise B&R Construction procedure to reference B&R QA procedures.
I leal mEsPonsE AsssGasto Toi geel Apenovso ev j(sol DATE: )
J. Monroe l't e el * ^mEsponsE
' ') f out A. W . W l /ll/ lE To be completed by audited organizition lef t commscTsvE AcTsom m EseceseEs tanc6uoE senEcubsp comebETsore oATEI l
ties sueueTTEo ove l4 00DATE:
! / / t last PREVENT ATIVE ACTeoser ilmChuot sCmEoubsp CourbETaose ATEI h
I is.) su...TTE .v. n ul ATE.
! // l To be completed by B&R Quality Ass.;rance taas mEveEw or mEsponsEi (340 mEveEwEn avs jtaalOATE. l 0 Satisfactory 0 Unsatisfactory l //
tasi mEsun.Ts or VEntP CAT so se , (375 vEnsr:En sve DATE:
ltas O Satisfactory 0 Unsatisfactory l //
lael mEM Ammar (3el ChoSED Ev e (all o ATEs e
oASe33
....g.,, e h e w @p e * ** "
- v v _ , - . - . , , . , ,. --- ,-,.-.wei.n
. ,1 ,'
ADR 27 Page 1 of 2
, Document Violated and Paragraph (Cite):
B&R Q.A. Manual, Section 14.5 "If an item is found unacceptable but requested to be used under controlled conditions by the Construction' Project Manager as noted in Section 15.0 of this manual, a " Waiver" tag or sticker (Exhibit 14.1) shall be attached to the item by a QC Inspector next to the " Receiving Hold" tag. A temporary waiver may be granted under the following conditions:
- a. The nonconformance may be corrected by receipt of Vendor's documenta-tion and procurement has received a commitment of submittal of such documentation.
- b. The nonconforming item can be removed o'r corrected at a later date (prior to operation) without change to, or contamination of the associ-ated permanent plant equipment or structures. . . .
- c. Traceability and identification as a nonconformance is maintained by tagging.
- d. Authorized Nuclear Inspector concurrence with waiver is obtained
("ASME Code Items" only).
The waiver shall be approved by the B&R Project QA Manager, the Owner and when applicable the NSSS Supplier and the Authorized Nuclear Inspector."
l l
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO.: l UNIT: PAGE: I OF llt AustTso o nG Ase83 ATiose lal Auct? me. (3) Ao s me. (44AomCoos B&R Quality Assurance (Site) QAHRB-3 29 (SlossCussao wtTMs [43mspomTso sva g(71 O ATsa (Si CATEGomys N. W. Pressler. R. A. Romeo (9) poCumsNT vloLATso AMO PAm AGm Apse (CITals
/ / Deis Oisi O'ni 10 CFR 50, Appendix B, Criteria V " Activities affecting quality shall be prescribed by documented procedures."
Ti iTs Ta vrv ioT . - -- - - - - - -- - -- -- - -- -- -- - - ~ -- -- -- -- - ~~
> B&R QA Procedure, ST-QCP-7.1, " Tool and Equipment Calibration," Revision dated y 6/14/77, which is now in effect is in noncompliance with the calibration system w as defined in the B&R QA Manual Section 12. This is due to the fact that QA 9
Procedure ST-QCP-7.1, Revision Interim Change dated 12/7/77, was an interim
$- change for only a 60-day period (STP Memo STQ-2647). To date no new procedure has been issued to comply with the B&R Q.A. Manual. ,',
toetpoTamT Aw maro mT Aswa car Casacy O vas @ mo (Ian esConessesmeATsoress Issue revised procedure which complies with the B&R QA Manual.
ts at sessposess AssaGmso for i C. Vincent l'8846 * * )mesmonsa f gesaous Appsehvsobvi.
kl I'llel"To ATsa i
fi lf 78 To be completed by audited organiistion (171 ComasCTave ACTsose esspones:( MCLuos SCMaoutso CompksToose O ATal (t el sumusTTao sv e lt tes DATE:
tast paavamT Avsys ACTsoms tamCLuos sensoukso CourksTsom OATsl
/ /
tallsumusTTso ofs l[335OATE:
! / /
To be completed by B&R Quality Assurance last arvesw or esseosesas taal naviewse svs C Satisfactory itaspOAvai C Unsatisfactory taal masubTs or vanertCAf toses 1 //
(af t vsmarsso svs ltastOATse j Q Satisfactory Q Unsatisfactory l ::. mem Amus, l / /
casi C6osso sv. sais o ATs, l
i o A.se s s
..e.4e e%.-- **a.ee e- * * * * * *" ' * * * " " " " ' " ~
,_, ,,g _% s. w. --
. c.. / < q ' ErownURcot,lr.c.
QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOB NO,: UNtT: PAGE: I OF I (si AuO TED O mG Amsz ATsOn (at AuOs? MO. (31 AO m No. (*) AOm COD E B&R Quality Assurance (Site)/ Construction QAMRB-3 2A (91 OISCWSSED WITM s (g3 agpenTED 3Ts g(7) O AYES (St CATEGOmv R. A. Romeo, N. W. Pressler i 6 / 15/ 78 Oi'i Oisi Oisi (96 OOCua8ENT veOI.ATED AMO PAR AGm AP.e (CETEls B&R QA Manual, Section 5.4 " Instructions, procedures and drawing documents shall be reviewed . . . Reviews shall be made for technical content . . . and conflict or redundancy with other documents approved for the project."
- 17. i7. 72,77 07. . - - -- - - ~ ~ - - -- - - - - - - - - - - - '- - '-
The Quality Assurance and Construction procedures are inconsistent. QA Procedure liz ST-QCP-7.1, paragraph 4.7, states "the Project QA Manager is authorized, when u requested, to extend the use of equipment beyond its calibration due date by Q issuing a memorandum to the responsible department identifying the equipment . . ."
b Construction Procedure A040KPICP-3, paragraph 3.23.1, states "the Senior o
Instrument Engineer is authorized to extend the use of equipment beyond its calibration due date by issuing a memorandum to the responsible department ,
(copy to QA) identifying the equipment . . ."
(t t 3 PO TEMTB AL mEPORT ASLE OE FICaENCY O vE= 0 MO
( t al mE CO Mad EMO ATIOpets Revise procedures to assure consistency.
(saa mESpOmsE AssseseEO 70, i j(see DATE:
C. Vincent, J. Monroe !'(seemEseOnseOwE
- ^' ') f (tse AppegwSOhvs. AW * =>- 8 7 / Q /78 l' To be completed by audited organ &stion (IT) CO mm ECTIV E ACTION R EspOngEr (INCbuG E SCMEOULEO Cone PLETBGM O ATEl
- l (t al SUSeelTTED BY e l(9 99 OATEa (303 PR EV ENT ATaw E ACTeO N: (enCLUDE SCnEOukED Cons psETBOM O ATE) l / /
(astsusaseTTED eve j ttal OATEi
' l l
=
D tw completed by B& R Quality Assurance (au REv.Ew e ,mE. ,0
- isa. m Ev eE= EO .T. ;( : OATE.
C Satisfactory 0 Unsatisfactory ' / / l 138) RESULTS O F VEntPDC ATIOM s (373 VEnlFIES SYs 0 Satisfactory l(380OAYE8 0 Unsatisfactory *
/ /
(ass meas Amsses (sel CLDsEO ev e (1st D ATE: I e
e A-ee3 a WM $e qWe .g4 gm gei p= 44.* '*N '"F' O *D* "
_ _ , _ . . . , _ , , . , - . - g w u -----7-"*r*7T-"P" ' " "'**"d"" ' " " " ' ' ' " " "
ww -
T' Brownf5RcotJnce QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project job NO.:
UNIT:
(Il AWolf so o nG ANIZ Af tem 6 PAGE: 1 OF 2 al Awol? 9e0. (3) Aom No. (4) Aom Coos B&R Construction IlQAMRB-3 30 (Sl ossCWesso WITMi [s3 mapomTso ev a g(73 oats 4 (81CATEGomys R. A. Romeo, N. W. Pressler ' 6 /15 /18 Oui Oisi Oisi (9) ooCUMsNT Vio LAT so AMO PAm AGa &P.0 (CBTsj s (see attachment) 7,,,,,,,,,,,------------------------
>. B&R Construction Procedure A040KPICP-3 " General Calibration" Revision 1, y January e areas: 23. 1978, is in noncompliance with the B&R QA Manual in the following
!d 5 1. The intervals for pressure gauge calibration as shown on the Master Index is not in accordance with the B&R QA Manual and ASME. --
gist povanTe AL aspomT AeLa oar:Ca s se C y glal asCoMMsMu ATsomme O vs= G ao Revise the B&R Construction procedure to reflect the above requirements. Review all past records to assure pressure gauges were calibrated at presc'ribed intervals.
tt 38 maspouss Assessego Toi ges: Arenowso ev J. Monroe !'tsen"$assoonsa f ous M @EO l'ste) o&Ts e7 /t2/W To be completed by audited organization (s71 ComasCTavs ACreon assoomssa (enCLuos sCnsoutso Consaksveen oavs3 tesesumaseTTso ove l(t ot oATE.
(sel PetWsNTATgve ACTpoMs (gMCLWos sCMaoWLeo ComePtsTeen oats)
/ /
(asssumansTTso evs l aaso&Tri
! / /
To be completed by B&R Quality Assurance saan navia. ., mas o u. ca., esvis=so ev, O Satisfactory ;iasioATs, D Unsetisfactory (ast mesubTs or vsesp CAvsesos 1 //
(afl vsmsFiso ove ~
D Satisfactory D Unsatisfactory ltast o ATs.
taop maneAmass l / /
i (nel CLosso sv. tagg o ATs, I
e& ess-a
.,, . . , . . . . . . . - . . -- + - - -
,,e-,w---
~
. . = .. . -
v'. ' s ADR 30 Page 2 of 2 Document Violated and paragraoh (Cite):
- 1. B&R QA Manual, Section 12.4 "All measuring and test equipment shall be calibrated and properly adjusted at specified periods or use intervals so that accuracy is maintained within specified limits."
- 2. B&R QA Manual. Section 12.4 "For Code items, the following M&TE shall be recalibrated at the specified intervals:
- c. Pressure Gauges - Before each ter,t or series of tests. A series of tests is that group of tests using the same pressure test gauge or gauges which are conducted within a period not exceeding two weeks."
l l
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT PROJECT: South Texas Project JOs NO.: UNIT: PAGE: I OF I (Il AvoITse onG AMIE AT50M (alAwol? Mo. (StAom Mo. (alaan Coos Quality Assurance (Site) QAMRB-3 31 telesecussso wsTM s ges aspomTse eva g(73 OATsi talCAvssomy R. A. Romeo, N. W. Pressler ? 6 A5 J8 Otii O iai- O isi i tot ooCunasMT veokATse Amo PAR Asm APM (CETsje '
B&R Q.A. Manual, Section 12.8 "If B&R elects to use standard testing laboratories to perform calibration services, they shall be approved by the B&R Q.A. Department I before award of contract . . ." l 7,,_,,_,,_g, _ _ _ _ - - - - - - _ _ _ _ _
).
y Outside calibration laboratories have not been reviewed and approved by the w B&R Quality Assurance Department.
2 b
c (ll) POTENT 4 An. msPomT Aebs osFaCasNCY O vs= G ao (tal esconcessMo Af toms:
Qualify outside calibration laboratories in accordance with Q.A. Manual requirements. '
in as assoonas Asesonso vo. ;tsen asseenes ous seen Aqv evt jasos oATai C. Vincent -! * * ' ') / MM ! 'T / 4 78 To be completed by audited organization inTI ComasCTtvs ACTsose assposessa lsseChuos scoescubse Comembetson o ATs3 i
tiesswenesTTso ove l gest oAvs.
I / /
(ael PasVsNTAT9We ACTposes (19eChuos sCPescubso ComePLaTsose O ATs)
I taissumanTTeo ev. j iaan o A Ts. ,
! / / i To be completed by B&R Quality Assurance (333 navesw er suspoussi taal neweswee eve ,(ael o ATs O Satisfactory Q Unstisfactory / /
l taal mesubTs or venersCAvsome (373 venirsso ev, ,tast oATas Q Satisfactory C Unntisfactory / /
l taen maanAmas, asse CLosso evi taisoATs o A... s.a g h g $ $ g h,q.h p+? ya. D # '
"' O * ~- **
-ecwr w-ew * - --e---e-- = e*- -- * - 4----*w----wiw + -
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. ~ 4- -P e4~ Erown&RootJr.c.
~ - - ---
QUALITY ASSURANCE DEPARTMENT ,
AUDIT DEFICIENCY REPORT !
PROJECT: South Texas Project JOB NO.: UNIT:
(Il AwotTso o nG AMBI ATeoM PAGE: I OF 2 (al AuotT Mo. (3) Ao m No. (el Aom Coos B&R Construction QAMRB-3 37.
i talotscussao wsTH: ge3 maromTso ove g(71 O Aves (el CAfsoomy.
N. W. Pressler. R. A. Rown ?
it) occumsMT vlobATso AMo PAR AGR APM (CITsja 6 /14 / 78 Oui Giu Otu (see attachment)
_g,,,,g, D
5 Although equipment installation work has started, Construction Procedure A040KPGCP-4 has not been revised to address the remaining segments of the 9
b housekeeping program including designation of zones, establishment of training C program for equipment personnel and personnelassigned within these to zones.
work in Zones I, II or III, and controlling te et peramtsaa. maromT Ae6s pe ricasmcv (133 m sComisu sMo474cMst O vse 6ao Comply with the requirements of ANSI N.45.2.3.
ti3 mes oass As onso Toi ii .e ausrones aus o s: -
J. Monroe ! * ** *J f A,mbveohv.w l ties 7 oats.
/Uh "18 To be completed by audited organiistion .
(178 commacTsys ACTaon esseomets lancLuos acuscus.so cosersstsom OATal ~
ties suewaTYao ev ' gest o4Ts.
ca.
na sv e T AYev a AcTio=i s.-Chuos seasoui.so co-pssy.o= o ATai t / /
i i
(313 sumaasTTso evs 'Isan DATsi 1 / / l To be completed by B&R Quality Assurance (33 neverw or masponses D Satisfactory taas esviewso eva j tasi oATas D Unsetisfactorv j 1a.3 mesubTs or vanerscations 1 / /
D satisfactory (37) vamersso ove j tael DATse Q unsatisfactory (att msM Amstes : i i (Sep Chasso ev e tall 047 a i
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ADR 31 Page 2 of 2 Document Violated and Paracraph (Cite):
ANSI N.45.2.3, Section 2.2 "The procedures and instructions for housekeeping practices shall be ' prepared and may be issued in segments to conform with the project construction schedule. The first segment establishing regulations for control of site area, site preparation, fire prevention and protection, and records shall be in force with the start of construction activities. The re-maining segments shall be prepared and approved no later than the start of equipment installation work."
m 9
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QUALITY ASSURANCE DEPARTMENT AUDIT DEFICIENCY REPORT h Texas Project JOB NO.: UNIT: PAGE: I OF l 4 M afi ATIO N (IlAuOt? MO. t al AO R Nr3. (el ADN CODE y Assurance (sik) QAMRB-3 33
.Mt (4) R EPORTED Sv -
g(71OATE (83 CATEGONv s N. W. Pressler, R. A. Romeo a 6 /14 / 78 0 'i 0 :: Oisi
? vsO6ATED AND PAR AGR APM lCITEla 2.3, paragraph 1.0 " Periodic inspection and examination of the work areas construction practices shall be performed at scheduled intervals to assure y of cleanliness and housekeeping practices."
_.,,g,______._________________
s no objective evidence that planned housekeeping inspections / examinations ng performed and documented with any schedular regularity.
(t Il POTENTI AL R EPO RT A ebE DE FIC4ENCv O VEE daa
- A TIOMsg more detailed plans and schedules for inspection activities.
surveillances on a more frequent basis.
steangs TO: ges: AppeOVED erg jttesDATE:
icent l't944 **'") mEseOsess f M Gointai-OuS l 'T fl'lL f~l3 To be completed by audited organization
.ACTlin mEseOnsEsismCLuGE SCoeEOubEO COnerbETBOM O ATE)
(983sweessTTED ev. ll191OATEs l / /
tyd ACTposes (smCbuGE SCMEDULEO COnerbETBON O ATE)
(at t SuomesTTED eve j ttal O ATEs l / /
To be completed by B&R Quality Assurance
, s s,0 .E . is.: EviE=EO v. ;is. OA75, y Q Unsatisfactory l / /
v wiris A T.0 = . :::: vE. r:EO .v. ;isei DATE.
y Q Unsatisfactory l / /
taesC60sEO evi (3:3OATE, i
-. . ., e A-se s.s l -.
t - ._..._. _ _ . .. .. _ -.._ ._ . . . . . .
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QUALITY ASSURANCE MANAGDENT REVIEW BOARD s AUDIT NO. 4 SYNOPSIS INTRODUCTION The fourth Quality Assurance Management Review Board audit of Brown,&
Root, Inc.'s Quality Assurance Program was conducted during the weeks of June 4, June 11, and June 18, 1979. The audit scope included the activities of Quality Assurance. Quality Control, Engineering, Construction, and Procurement on three fossil projects and one nuclear project.
l The audit tea = me=bers were:
Name Representing Function Petar Foscolo Construction Manage =ent Lead Auditor; Group 1 Team Leader Rosalunde K11 mist Insincering Auditor 1
Jack Norris Management Analysis Company Auditor and Consultant
( Pred Miller Comanche Peak Engineering Auditor Isidor Tribuch Operations Auditor; Group 2 Team Leader Ron Schnoor Quality Assurance Auditor Joseph Shuckrow Engineering Auditor Robert Salmons Subcontracts Auditor Preparation for the audit began May 18, 1979. This consisted of a review of Quality Program requirements and i=plementing procedures for the various projects, preparation of audit checklists, and an auditer training program conducted by the Brown & Root Quality Assurance Audit Section.
The audit plan and schedule were developed and included specific assignment of auditors to specific audit ele =ents. During the week of June 4, the audit team was split into two groups: Foscolo, K11 mist, Norris, and i
Miller audited the Sandow Project Construction and Engineering; Tribuch, Schacor, Shuckrov, and Salmons audited the White Bluff Construction Site and Sooner Project Engineering and Procurement. Because the Quality Control Systa= for fossil projects is limited to ASME 3eiler and Pressure Vessel Code activities, the audits of chase projects primarily addressed
, compliance with Code requirements.
W
, . - _ . . . - . ~ . - . . - _ - - . - _ r_.. -- - __-. -- - _ , . . . , . _ . . y- - .- , - , ,., . - - - .
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g During the weeks of June 11 and June 18, the entire team audited the Construction, Quality Assurance, and Quality Control activities at the South Texas Project Electric Generating Station (SIPECS) Site and the STPEGS Quality Assurance Engineering, and Procurement activities in the Houston Office.
Pre-audit and post-audit meetings vers held at each location for each of 4
these audits on the dates shown on the applicable attendance list, which are attached to each audit segment of this report.
This report is organized into individual sections for each project, and it is subdivided within those sections by geographic location of the audit and the elements audited.
e** ..
AUDIT OVERVIEY The audit taan performed six separate audits as described in the Introduc-tion. The results, though not necessarily based on uniform application of the audit elements, are nonetheless evidence of similar proble=s on i more than one project. These problems appear to be:
1 o Document Control o Design Control o Control of Special Processes
- f o Inspection a Corrective Action o Records o Audits i
j While the individual Audit Deficiency Reports (ADR's) and concerns cite specific evidence of proble=s, the basis for most of these is failure to follow approved procedures or a failure of the procedure to provide adequate data and/or instructions. Sixty-two percent of the deficiencies and concerns for all audited projects relate to these seven identified problem areas.
It is therefore recommended that Managesent action be addressed to all projects to assure that approved procedures are distributed to appropriate work levels, that indoctrination is conducted as to the procudural purpose and methodology, and that complian:e is enforced by Management and menitored by Internal Surveillance and Audits.
e**
QUALIN ASSURANCI PROGRAM - NUC1. EAR
SUMMARY
The scope of the QANRS-L audit of the Quality Assurance / Quality Control aspects of the Quality Assurance Program was limited to those activities where action.
that organization has the responsibility to initiate or ter=inate 1
These activities were perceived to be l
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I o Organization i
o Quality Assurance Program o Inspection o Control of Nonconformances o Corrective Action !
o Records o Audits Aspects of other portions of the Brown & Root Quality Assurance Progran that address the remaining 11 criteria of 10CTR30, Appendix B were_
generally focused on other organizations.
The most significant problem in the implementation of the Quality Assurance Program is the continuing lack of clear, concise procedures that delineata and support the authorities, responsibilities, and organizational **
interfaces of the present organization. This problem was reported in QAMR5-3, and the responses received in this audit are essentially the '
same as those provided a year ago; that is, the procedures were in the !
process of being revised and work was being dona in accordance with the revised (and unsupported) methods. Current examples are: the Project Management Office (Organization) could not adequately identify program
- documents that established its organisation, authorities, and responsibi-lities (QAMK5-4-STF-12); at the Site, the massive reorganization is not supported by approved program documents, clear definition of interdisci-
, plinary activities and authorities, adequata training of personnel, and adequate time to effect the changes required under the revised organisation
- ; (QAMRB-4-STP-A) .
' Throughout the audit, there appeared to be confusion among Project
' personnel at all levela as to organizational responsibilities and the procedural processes.
Consideration should be given to reducing the procedural program to a lerel that: (a) meets regulatory, code, and client requirements; (b) represents Brown & Root's co==itzent to itself; (c) will be enforced; i and (d) changes in practicas reflect only those changes contained in approved procedures. Personnel at all levels that implement such procedures l
and changes need to be indoctrinated in the objectives and the relevant detail of procedural implacentation.
The second area of major concern in implementing the Quality Assurance Program relates to Quality Assurance records. By definition, such records include all of the completed docunents necessary to substantiate that the saf ety related materials, components, syste=a, and structures j were designed, constructed, installed, and tested in accordance with i specific requirements. The audit team registered concern (QAMR3-4-STP-1) that the activities of reclassifying, refiling, and reorganizing the i
records f unction are not presently governed by approved procedures and work instructions. This is co= plicated by the fact that working documents are distributed from the QA Vault et the Site. This mix creates confusion for Vault personnel, results in unnecessary =1crofi1=ing, requires more l
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storage space, and increases staffing requirements. In addition, it is not evident that there is a clear definition between these itens and the attendant activities necessary to assure that the required records, as defined by ANSI N45.2.9, are explained or of sufficient detail to assure their presence at turnover.
The third area of mejor concern is that it was not evident that the audit program is covering all ele =ents of the Quality Assurance Program (QAMR5-4-STP-20) . Quality Assurance records had not been audited since April 11, 1978. Records at the Site only substantiated audits of -14 of the 18 critaria in a 12-month period. Turther, it is not evident that there is adequate follovup on previously identified deficiencias (QAMRS-4-STP-19 and 21).
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QUALITY CONTROL SYSTEM - FOSSIL SUMW.ARY The audit of the Quality Control Oystem for fossil projects appears to be, in part, supporting ASMI Sections I and VIII.
However, most of the problems observed during the audit have to do with
' the lack of understanding of the Program basis and provision of proper procedural detail to implement of this Quality Frogram. This is evidenced in most cases by a total lack of a " tier" of procedures for project Engineering, Procurement, and Construction that carries the i=plementing
( details of the Quality Control System requirements to these specific project functional areas. This lack resulted in findings where, for instance, location of required ASMZ material certifications and radiographs could not be readily determined (QAMR3-4-SN-8, QAMRB-4-SN-9). There was also no procedurally defined review by Engineering to assure the correctness or adequacy of this documentation. Thus, the Field has no assurance of code co=pliance before installation or use cf code =aterials. Further procedural definitior. of project interfaces would alleviate confusica of
- responsibilities and improve project coordination. , ..
Again, because of a lack of clear procedural detail at the appropriate levels, Quality Control reviews of procure =ent documents for AEMI code ite=s were not consistant (QAM?.3-4-SN-E, QAMRS-4-S?-I) . These reviews cannot be assured unless functional paths, interfaces, and responsibilities are clearly defined through an crganir:tien that is supported adequately by procedures.
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) The Quality Control Syste= is written primarily covards Ccnstruction l
activities. Consideration should be given to previding more clearly defined Progra= segeants for Engineering and Procure =ent activities. If a tier of procedures is not deemed necessary to adequately effect Program inple:entation, then consideraticn should be given to expanding the QCS Manual to include these details and the disttibution enlarged to include the functional areas within Engineering, CA/QC, Procure ent, and j Construction.
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F S M MY Or FDCIN:$
Fro'ect Tote!
White Seoner South fense Bluff Noes Sandow Freject ADR's/
Audit Element $tte h Site Offtee Site Office Concerr.e 1 Organisation 0 0 0 0 0/1 1/1 1/2
!! QA Prograa 0 0 0 0 0 2/1 2/1
!!! Design Centrol 0 0 0 0 1/3 2/6 3/9 B' Procurement N N N N 0 0 0 Document control '
V Instructions. N N N N 1/2 1/2 Procedures, and Drawings VI Dec aent Con- 1/1 1/3 0 0 0/3 1/3 3/12 -
trol VI: Control of 0 0/1 0 2/2 0 0 2/3 Purchased Material V:Z: Identifica- 0 0 0 0 0 0 0 ties and Centrol of Materials II Centrol of 0/1 N 3/3 N 4/5 N 7/9.
Special Proces-ses
} X laspection 1/1 N 2/0 N 2/3 N $/4 XI Test Centrol N N N N 1/0 N 1/0 III Centrol of 0/1 N 0/1 N O N 0/1 Maasaring and Test Equi;=ent IIII Randling. N K 0 N 0 F 0 Shipping, and Storage IIV !aspection. N N N N 1/0 N Test end Oper- 1/0 stir.g Status IV Noccer.formances 0 0 0 0 1/0 0/1 1/1 XVI Corrective 1/0 0 0 0 1/0 1/1 Action 3/1 IV:: Records 0 0 1/0 1/1 1/3 0/1 3/7 IVI:: Audita 0 0 0 0 N 4/1 4/1 Noits:
0 - No findings M - Not applicable AR/ Concern . top nuaser e A:R. bottos awater a Concern O
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b RICOMMF.NDATIONS FOR FUTURE QAMR2 AUDITS The following recommendations are offered to the QAMR3 to make future I
audits more affective.
- 1. The audit scope should be more precisely defined. The basis for identifying ADR's and concerns should also be more clearly delineated.
, 2. Followup on these identified areas should be consistant until,all i au'dit findings are complete and the corrective action verified. It is suggested that a QAMR3 audit log be maintained and published bi-monthly until this is accomplished.
- 3. Quality Assurance should provide a trending that shows the relationship --
of the present audit to past audits, as well against the annual audit spectru= for the annual period (June to June).
- 4. Quality Assurance should maintain a current matrix of approved applicable Project procedures codes and standards against the
! progra= criteria. This will provide a more accurate framework from which all audits can be perfor=ed, and it will also help to assure coverage as required by the Quality Assurance Program or Quality
. Control System.
j 5. The audit team members benefited substantially from the audit experience, which resulted in their improved understanding of the Quality Assurance Program scope and application. We recommend the participation by all levels of Construction Engineering and Procure-ment personnel as auditors in routine QA audits during the year.
This will provide a cross training and help asch participant to better understand the code requira=ents and their implacentation through the 3rown & Root Power Croup Quality Assurance P gra=.
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