ML20205F603

Response to ASLB 860414 Proposed Memorandum & Order Re Encl Action Plan Results Rept VII.a.4.Plan Developed in Response to Number & Qualifications of QA Auditors During 1981 & 1982.W/Certificate of Svc.Related Correspondence

ML20205F603
Person / Time
Site:	Comanche Peak
Issue date:	08/14/1986
From:	Gelzer J, Hansel J TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:
References
CON-#386-358 OL, NUDOCS 8608190259
Download: ML20205F603 (29)

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% dh;g UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

) Docket Nos. 50-445-OL TEXAS UTILITIES. ELECTRIC ) 50-446-OL COMPANY et al. )

) (Application for an (Comanche Peak Steam Electric ) Operating License)

Station, Units 1 and 2) )

)

ANSWERS TO BOARD'S 14 QUESTIONS (Memo; Proposed Memo of April 14, 1986)

Regarding Action Plan Results Report VII.a.4 In accordance with the Board's Memorandum; Proposed Memorandum and Order of April 14, 1986, the Applicants submit the answers of the Comanche Peak Response Team ("CPRT") to the 14 questions posed by the Board, with respect to the Results Report published by the CPRT in respect of CPRT Action Plan VII.a.4.

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0-Opening Request:

Produce copies of any CPRT-generated checklists that were used during the conduct of the action plan.

Response

The checklists are attached.

Question:

1. Describe the problem areas addressed in the report. Prior to undertaking to address those areas through sampling, what did Applicants do to define the problem areas further? How did it believe the problems arose? What did it discover about the QA/QC documentation for those areas?

How extensive did it believe the problems were?

Answer:

This Action Plan was prepared to respond to concerns raised by the NRC's TRT and by the NRC Region IV staff. The enclosure to the.TRT Letter of January 8, 1985 included a concern pertaining to the number (thought to be low) and qualifications (thought to questionable) of QA Auditors during 1981 and 1982 as well as the extent of Audit Program Coverage. The program coverage was thought to be incomplete and questionable.

In addition, NRC Inspection Report No. 50-445/84-32 addressed the failure of TUGCO to establish and implement a comprehensive system of planned and

)

.5 periodic audits of safety-related activities during specific time periods.

Our initial investigations revealed that a more meaningful analysis could be performed by addressing the TUGCO Audit and Auditor Qualifications Programs over the life of the plant rather than to attempt to address only specific time periods, which could have resulted in taking specific activities or program elements out of context.

Since the report deals with QA Audits, we looked at QA documentation from the outset and we found it to be marginally effective.

The detailed scope of the investigation is presented in Sections 4.1.1 and 5.0 of the Results Reports.

Question:

2. Provide any procedures or other internal documents that are necessary to understand how the checklists should be interpreted or applied.

Answer:

The checklists and guide sheet utilized for document review were generated and implemented by the Issue Coordinator; therefore, specific detailed instructions were not considered necessary. However, 1

, , . , . . . - - - , .-- .- -, - - - - - , - - , ,r -- . - - , - - - - , - - - -

e general ~ instructions are included with checklist's.and guide sheets in the working file.

Question:

3. [ Original acceptance checklists. See Transcript of-the Pre-Hearing Conference of April 22, 1986, at 24,353-57.]

Answer:

There was no TUGCO checklist generated to perform the activities that this action plan performed, i.e.,

review and evaluation of the TUGCO QA Audit Program and Auditor Qualifications.

Question:

4. Explain the extent to which the checklists contain fewer attributes than are required for conformance to codes to which Applicants are committed to conform.

Answer:

The checklists were derived from a revie'w of the-ANSI standards and 10 C.F.R. 50 as they apply to audit programs. Therefore, we believe the checklists contain a sufficient number of attributes to ensure conformance to the standards.

Question:

5. (Answer question 5 only if the answer to question 4 is that the checklists do contain fewer attributes.) Explain the engineering basis, if any, for believing that the safety margin for i

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components (and the plant) has not been degraded by using checklists that contain fewer attributes than are required for conformance to codes.

Answer:

In light of the answer to #4 above, this question is not applicable to this ISAP.

Question:

6. Set forth any changes in checklists while they were in use, including the dates of the changes.

Answer:

No substantive change was made to checklists or guide sheets during implementation of the ISAP.

Question:

7. Set forth the duration of training in the use of checklists and a summary of the content of that training, including field training.or other practical training. If the training has changed or retraining occurred, explain the reason for the changes or retraining and set forth changes in duration or content.

Answer:

Assistance was obtained from another QA/QC Review Team member to implement a portion of one che-klist (File VII.a.4 - 7.13.003). In this case, approximately one-half hour was utilized for familiarization with the specific portions of the checklist, the structure of

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e the files to be reviewed and the type of data required.

No retraining was required.

All other checklists and guide sheets were implemented by the Issue Coordinator and, therefore, no additional training was required.

Question:

8. Provide any information in Applicants' possession concerning the accuracy of use of the checklists (or the inter-observer reliability in using the checklists). Were there any time periods in which checklists were used with questionable training or QA/QC supervision? If applicable, are problems of inter-observer reliability addressed stati stically?

Answer:

With one minor exception, the checklists were used by the Issue Coordinator in reviewing documents.

It is therefore unlikely that any error in the use of checklists exists. The one exception to this condition was closely controlled and reviewed by the I.C., again resulting in a low likelihood of error.

Question:

9. Summarize all audits or supervisory reviews (including reviews by employees or consultants) of training or of use of the checklists. Provide the factual basis for believing that the audit and review activity was adequate and that each concern of the audit and review teams has been

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resolved in a way that is consistent with the validity of conclusions.

Answer:

No audit or supervisory review was conducted.

Question:

10. Report.any instances in which draft reports were modified in an important substantive way as the result of management action. Be sure to explain any change that was objected to (including by an employee, supervisor or consultant) in writing or in a meeting in which at least one supervisory or management official or NRC employee was present.

Explain what the earlier drafts said and why they were modified. Explain how dissenting views were resolved.

Answer:

No substantive modification was made to Results Report drafts as a result of management action. In fact, most of the modifications made to the report during review were for readability of the report, rather than changing content.

Question:

11. Set forth any unexpected difficulties that were encountered in completing the work of each task force and that would be helpful to the Board in understanding the process by which conclusions were reached. How were each of these unexpected difficulties resolved?

- . . - -. - - .~

Answer:

No unexpected difficulty was encountered in completing the work for this report.

Question:

12. Explain any ambiguities or open items left in the results report.

Answer:

Three items remain open after completion of the report.

These open items are:

a) The FSAR does not define the responsibility for the audit program.

b) Responsibilities of the audited organization are not spelled out.

c) At least three currently certified lead auditors have not been administered an exam by TUGCO.

These items were transmitted to TUGCO as QA/QC Program Deviations on April 10, 1986.

Question:

13. Explain the extent to which there are actual or apparent conflicts of interest, including whether a worker or supervisor was reviewing or evaluating his own work or supervising any aspect of the review or evaluation of his own work or the work of those he previously supervised.

1

r o i Answer:

The CPRT has instituted a procedure that requires personnel involved in CPRT activities to carefully examine possible areas of conflict and signify that conflict of interest does or does not exist. This process, coupled with the initial screening process performed prior to bringing third-party consultants on-site for the CPRT, reduces the likelihood of a conflict of int rest to near zero.

Question:

14. Examine the report to see that it adequately discloses the thinking and analysis used. If the language is ambiguous or the discussion gives rise to obvious questions, resolve the ambiguities and anticipate and resolve the questions.

Answer:

Mr. J. Gelzer, the Issue Coordinator, has re-examined the results report and does not see any ambiguity or obvious question. Admittedly, his close association with the contents of the report renders it difficult for him to discern questions or ambiguities.

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Respectfully submitted,

m. ReR.e, :c 'sY Review Team Leader e

W R. Gelzer, 'Jr.(/

4 Mtion Plan VII.a.4 Issue Coordinator i

The foregoing responses have been reviewed and i

are concurred in by the CFRT Senior Review Team.

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1 of 2 Filo: VII.a.4-70.OO1 PROGRAM REVIEW GUIDE SHEET AUDIT PROGRAM AND AUDITOR QUALIFICATIONS This guide sheet will be used to perform the initial review of QA program documents to extract information pertinent to the audit progam and auditor qualifications.

Baseline data of interest from the earliest available revision will be recorded. Subsequent revisions of substance to the baseline will be noted for later review.

1. PSAR/FSAR

- Review evolution of Appendices 1A(N) and 1A(B)

- List commitments pertaining to audit program, including revi si on levels and periods of effectivity.

- Review documents committed to and extract pertinent criteria to be used to evaluate adequacy of the program.

- Review evolution of Chapter 17.1

- Extract commitments and implementing instructions pertaining to audit program and cross reference where applicable to commitments, and/or add to commitment list.

- Review Question and Answer rounds involving NRC Quality Assurance Branch.

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- Extract information pertinent to audit program.

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- Evaluate items for which verbatim revisions were not incorporated into the SAR.

- Supplement commitment list.

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2. Dallas DA Manual

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- Review historical Table of Contents and identify procedures relating to audit program.

- Review identified procedures for implementation of commitments identified, as applicable, to periods of effectivity. I

- Obtain and review supplemental procedures and/or instructions, including informal or personal data which may have been used to augment the written program.

- Document deviations between written program and requirements, by period of effectivity, including any which may have been

" corrected" by informal procedures / instructions.

3. Regulatory Guides and Industry Standards

- For those documents (Regulatory Guides, Standards, etc.)

pertaining to audit program to which CPSES is committed, determine if later revisions are available and/or determine if additional documents are available that supersede or supplement the CPSES commitments.

- Extract pertinent criteria for consideration to improve the existing CPSES program including, if appropriate, recommendations for commitment to these later documents.

4. TUGCO Quality Assurance Program (Green Book)

- Extract commitments and implementing instructions to audit program and cross reference where applicable to commitments, and/or add to commitment list.

- Review evolution of procedures which evolved into Dallas DA Manual.

5. CPSES Quality Assurance Plan (Red Book)

- Extract commitments and implementing instructions to audit program and cross reference where applicable to commitments, and/or add to commitment list.

l l - Review evolution of procedures which evolved into Dallas QA l

Manual.

Concurrence /

1 of 2 Files VII.o.4-7B.OO1

. 7/31/85 AUDIT PROGRAM CHECKLIST Review the notes obtained during the program document review against the following criteria from ANSI N45.2.12-1973.

Paragraph number references are to ANSI N45.2.12-1973 (Draft 3, Rev. O, May 12, 1973)

1. Does the TUGCO audit program address each of the essential elements described in 3.2.1 through 3.2.7. (3.2)

2. Does the audit planning system define the activities to be audited, the coverage (scope), and the scheduling criteria. (3.3)

3. Are audits being conducted as early in the life of the activity as practicable, or in any case early enough to assure effective quality assurance during the activity. (3.4.1)

4. Are audits scheduled on the basis of status and importance of the activities.

Are applicable elements of the program audited at least annually or at least once in the lifetime of the activity. (3.4.2)

5. Does it appear that supplemental audits have been conducted in response to the conditions listed in 3.4.3.1 through 3.4.3.6.

(3.4.3)

6. Are individual audits implemented as scheduled and planned.

(4.1)

7. Is there provision for written individual audit plans which include the items required by 4.2.1. (4.2.1) l

8. Is there provision for selection of an audit team leader and definition of responsibilities as described in 4.2.2. (4.2.2)

9. Is there provision for the team leader to conduct a team orientation prior to initiation of the audit which covers the subjects described in 4.2.3. (4.2.3)

10. Is there provision for formal audit notification, prior to audit conduct, which addresses the topics listed in 4.2.4. (4.2.4)

11. Is there provision for conduct of a pre-audit conference at the audit site with cognizant management to address the topics in 4.3.1. (4.3.1) i

12. Is there provision for the use of checklists or procedures to conduct the audit. (4.3.2.1) l

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13. Is there direction to examine objective evidence to verify

- compliance with OA program requirements. (4.3.2.2)

14. Is there direction that selected elements of the QA program be audited to the depth necessary to determine they are effectively performed. (4.3.2.3)

15. Is there direction to investigate audit nonconformances to determine basic cause. (4.3.2.4)

16. Is there provision for acknowledgement of nonconformances by a member of the audited organization. (4.3.2.5)

17. Is there direction to report nonconformances at_the post-audit conference, and to report those requiring immediate action, to management immediately. (4.3.2.6)  ;

18. Is there direction to give specific attention to corrective action of nonconformances identified during previous audits.

(4.3.2.7)

19. Is there provision to conduct a post-audit conference with management of the audited organization to address the topics addressed in 4.3.3. (4.3.3) Is there provision for management of the audited organization to commit to a specific date for the determination of the course and schedule for corrective action if the course and schedule cannot be provided at the post-audit conference. (Staff Position, Gray Book)

20. Is there provision for the team leader to prepare and sign an audit report that addresses the items described in 4.4.1 through 4.4.6. (4.4)

21. Is there direction to distribute the report to responsible management within 30 days after the audit. (4.4) i

22. Is there provision for management of the audited organization to review and investigate audit findings, determine and schedule appropriate corrective action, and to respond to the report in writing within 30 days of receipt. (4.5.1)

23. Is there provision for the audit team leader or management of the auditing organization to perform the activities described in 4.5.2.1 through 4.5.2.4. (4.5.2)

24. Is there a requirement that audit records be collected, stored and maintained in accordance with ANSI N45.2.9. (5.1)

25. Is there a requirement that audit record files contain the items listed in 5.2. (5.2) i i

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Concurrence __ _ 2/Z /_e* + p _ _ _

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1 of 4 Fils: VII.e.4-7B.OO3 Audit Package Review Checklist Review selected audit packages in accordance with this checklist and complete a data sheet for each.

I. Audit Preparation A. Audit Plan

1. Is there a written audit plan

2. Is the audit scope consistent with the planning criteria

3. Is there a list of requirements against which the audit will be condeicted

4. Is there a list of activities to be audited

5. Is there a list of organizations to be notified

6. Is there a listing of documents applicable to the audit

7. Is the audit schedule included

8. Is there written checklists and/or procedures to which the audit will be performed, included in the plan or adequately referenced and retrievable B. Audit team selection

1. Identify team leader and team members

2. Is team leader a qualified lead auditor l

i 3. Is there documented rationale for selection of team leader and/or team members C. Audit team orientation i

1. Is there evidence of audit team orientation or briefing D. Audit notification .

1. Date of notification

2. Method of notification

3. Were all organizations listed on the audit plan notified

4. Is the schedule contained in the audit plan reflected in the notification

2 cf 4 Files VII.o.4-7B.OO3 II. Audit Performance A. Pre-audit conference

1. Date of pre-audit conference

2. Does it appear that appropriate personnel were precent B. Audit process

1. Do the checklist or procedures provide for sufficient depth and continuity of the audit

2. Was objective evidence examined to evaluate compliance with rquirements

3. Are program elements audited to the depth necessary to determine effective implementation

4. Are nonconformances and/or program deficiencies acknowledged by a member of the audited organization

5. Are conditions requiring immediate corrective action reported immediately to management of the audited organization.

6. Is specific attention given to corrective action on program deficiencies identified during previous audits C. Post-audit conference

1. Date of post-audit conference

2. Does it apear that appropriate personnel were present III. Audit Report t

A. Is the report signed by the team leader B. Does the scope described in the report reflect the scope contained in the audit plan C. Are audit team members identified D. Does the report identify persons contacted during the conduct of the audit E. Does the report describe deviations from the checklist and/or procedures (additions and deletions) with supporting rationale.

F. Is there a summary of audit results including an evaluation statment regarding the effectiveness of the audited elements

3 of 4 Fils: VII.e.4-7B.OO3 G. Are deficiencies described insufficient detail to assure that corrective action can be effectively carried out by the audited organization H. If appropriate, are recommendations for correcting deficiencies or for program improvements included in the report

- J. Report distribution

1. Is report distributed to responsible management of the audited and auditing organization

2. Date of issue

3. Number of days from post-audit conference to issue date IV. Follow-up A. Audited organization

1. Does the response provide results of review and investigation

2. Does the response state the proposed / completed corrective

, action and/or action to prevent recurrence

3. Does the rsponse include a schedule for completion of corrective action if not scheduled for completion within 30 days

4. If applicable, is there a followup report stating the corrective action taken and the date of completion

5. Was response received by requested date l

l D. Auditing organization (if applicable)

1. Is there a documented evaluation of the adequacy of the response

2. Is there a documented confirmation of completion of corrective action

3. By what means was followup accomplished 9"

-4 Cf 4 File: VII.a.4-7B.OO3 V. Records A. Audit record files content

1. Audit system plan

2. Individual audit plan

3. Audit report

4. Written replies

5. Record of completion of corrective actions Concurrence /[)g7)dj l

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1 of 1 4.SA SPECIAL AUDIT PACKAGE REVIEW Perform an in-depth review of selected audit packages in an effort to determine why the TUGCO audit program did not identify particular programmatic problem areas addressed by outside reviewers and confirmed by the QA/QC Review Team.

Problem areas to be investigated are:

- Nonconformance and Corrective Action systems, including trend analysis of adverse findings.

- Inspector Training, Qualification and Certification program. In addition to audits, look at " TAG" efforts relative to ISAP I.d.1.

Audit package review should include:

- Detail level of checklists

- Basis for checklists (requirements documents or proceduren)

- Detailed review of auditor notes

- Depth of investigation or sample size

- Deviations and/or concerns identified

- Proposed / agreed upon corrective action

- Verification of corrective action implementation / effectiveness Audit packages to be reviewed:

NCR-Corrective Action TCP-1, TCP-2, TCP-4, TCP-18, TCP-28, TCP-56, TCP-74, TCP-87, TCP-117 Inspector Training, Qualification, Certification TCP-5, TCP-36, TCP-90, TCP-122 Concurrence l

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i of C Filc: VII.e.C-7B.OOO Vendor File Review Guide Sheet and Notes The purpose of this review is to evaluate QA vendor verification activities to reach a conclusion concerning the adequacy of program coverage. .

Attached for each vendor reviewed are pertinent extracts from the files plus a graphical representation of the verification activities.

The following key applies to the graphs:

PAS - Pre-award survey FU - Follow-up ER - Equipment release inspection (number following represents the vendor rating)

ER - Equipment release with deficiency identified during inspection Audit number followed by an asterisk (*) - audit was triggered by adverse ratings

1. Review available files for vendors on attached list.

- Audit Files

- Audit Notes Files

- Vendor Compliance Files

2. Compile listing of trips to vendor

- Purpose and Trip Results i

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3. Compile listing of problems

- Category and Action Taken by TUGCO

4. Review vendor ratings and attempt to correlate to audit scheduling

5. Develop a conclusion concerning adequacy and effectiveness of l vendor compliance program l

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2 of 2 FilGI VII.o.4-7B.OOO l

Basis for Selection

. 1 From vendors identified in conjunction with the Levin to Hansel memo, select approximately ten to provide a sample across the i disciplines. Also, based on the audit index, sample from what appaars to be good coverage and poor coverage based on number and frequency of audits.

If data appears consistent, additional reviews are not necessary.

ITT Grinnell was added in an attempt to obtain specific data to support ISAP VII.b.2.

American Air Filter, Brownsville, TN Borg-Warner, Van Nuys, CA Conax, Buffalo, NY Fisher Controls, Marshalltown, IA Ingersoll Rand, Phillipsburg, NJ ITT Grinnell Corp, Lancaster, PA Pacific Air Products, Santa Ana, CA Posi-Seal International, N. Stonington, CT Power Conversion, Crystal Lake, IL l

Southwest Fabrication and Welding, Houston, TX Rockbestos, New Haven and E. Granby, CT Rosemount, Eden Prairie, MN I

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1 of 2 Filos VII.a.4-7C.OO1 l

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. AUDITOR QUALIFICATION PROGRAM CHECKLIST Review the notes obtained during the program document review against the following criteria from ANSI N45.2.12-1973 and ANSI N45.2.23-1978 as applicable.

Prior to 6/1/83, requirements are based on ANSI N45.2.12-1973.

1. Does the program require that auditors be independent of any direct responsibility for the activities which they will audit.

(2.1).

2. Does the program provide for the qualification of audit personnel, and that their selection for auditing assignments are based on experience or training which establish that their qualifications are commensurate with the complexity or specific nature of the activities to be audited. (2.2)

3. Does the program provide for the training or orientation of audit personnel to assure their competence for performing audits by one or more of the methods described in 2.3.1 through 2.3.4. (2.3)

- Orientation to provide working knowledge of ANSI N45.2 and ANSI N45.2.12. (2.3.1)

- Training programs to provide general and specialized training in audit performance. (2.3.2)

- DJT under direct supervision od an experienced, qualified I

auditor. (2.3.3)

- Orientation of technical specialists by the audit team leader.

(2.3.4)

4. Does the program provide for maintenence of auditor proficiency through one or more of the methods described in 2.4.1 through 2.4.3. (2.4)

- Regular, active participation in the audit process. (2.4.1)

- Review and study of codes, etc. (2.4.2)

- Participation in training. (2.4.3)

5. Is there a requirement to maintain records for the qualification and training for all personnel actively performing audits as well as those who previously perf ormed audits. (5.3)

2 of ~ File: VII.e.4-7C.OO1 Effcctiva 6/1/83, rGquiremento cro beccd on ANSI N45.2.23-1978

1. Does the program require that auditors be independent of any direct responsibility for the performance of the activities which they will audit. (4.1).

2. Does the program provide for qualification of audit personnel and requirements for use of technical specialists and that those selected have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited.

(2.2)

3. Does the program provide for the training or orientation of auditors to develop their competence for performing audits by one or more of the methods described in 2.2.1 through 2.2.3. (2.2)

- Orientation to provide working knowledge of ANSI N45.2, ANSI l N45.2.23 and auditing organization's procedures. (2.2.1)

- Training programs to provide general and specialized training in audit performance. (2.2.2)

- DJT under the direct supervision of a Lead Auditor. (2.2.3)

4. Does the program provide for the maintenence of lead auditor qualifications through one or more of the methods described in 3.2.

(3.2)

- Regular and active participation in the audit process.

- Review and study of codes, etc.

l l - Participation in training.

! 5. Is there a requirement to maintain records of personnel qualifications for auditors and lead auditors performing audits.

(5.1)

6. Does the program adopt the definitions of " auditor" and " lead auditor" included in 1.4.1 and 1.4.2 respectively. (1.4.1, 1.4.2)

7. Does the program provide for the qualification of lead auditors in accordance with the requirements of 2.3.1 through 2.3.5. (2.3)

8. Does the program provide for a documented annual management assesment to extend qualification, require retraining, or require requalification of lead auditors. (3.2)

9. Does the program require the requalification of lead auditors, who fail to maintain their proficiency for a period of 2 years or more, in accordance with the requirements of 3.3. (3.3) 1

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3 of "v 'I Filde VII.e.4-7C.OO1  !

10. Is there provision for the lead auditor to concur that the team members collectively have the experience or training commensurate with the scope,' compleMM,F FsMbiTYE'ha'turE of' the activities to

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be audited. ( 4.1 )"

11. Does~ t h e* p rog r am ' defi f 6e'% hWefs"pcfrfsR tfi'l'iE b'the development and administ' ation'6f r the CTddd at.idiTcfr"edfA7nin%yWo'rEen F and'for its conf ormance ti)'the'requir dsetiftr of ANSI N45.2.23-1978. (4.2)

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12. Does the program provide for the r,etention of,_ copies of objective evidence regarding the types and content of lead auditor examinations. (4.2) 22 the t _c '

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13. Is' -therra requiredent CthdtleihY'm6bitEies"kcertified as being r i qualified to lead audits, and that the certification documents the elements described in 5.2(a) through 5.2(e). (5.2) i n c.

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14. Is there ai requiremerit that 1FaV'aiuditiar"recorcis # be maintained and update ~ annually. (5.3) .r ci n o g wni ch rr -

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2 of ~. Filo: VII.a.4-7C.OO1 Effective 6/1/83, requirements are based on ANSI N45.2.23-1978

1. Does the program require that auditors be independent of any direct responsibility for the performance of the activities which they will audit. (4.1).

2. Does the program provide for qualification of audit personnel and requirements for use of technical specialists and that those selected have experience or training commensurate with the scope, complexity, or special nature of the activities to be audited.

(2.2)

3. Does the program provide for the training or orientation of auditors to develop their competence for performing audits by one or more of the methods described in 2.2.1 through 2.2.3. (2.2)

- Orientation to provide working knowledge of ANSI N45.2, ANSI N45.2.23 and auditing organization's procedures. (2.2.1)

- Training programs to provide general and specialized training in audit performance. (2.2.2)

- DJT under the direct supervision of a Lead Auditor. (2.2.3)

4. Does the program provide for the maintenence of lead auditor qualifications through one or more of the methods described in 3.2.

(3.2)

- Regular and active participation in the audit process.

, - Review and study of codes, etc.

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- Participation in training.

5. Is there a requirement to maintain records of personnel qualifications for auditors and lead auditors performing audits.

(5.1)

6. Does the program adopt the definitions of " auditor" and " lead auditor" included in 1.4.1 and 1.4.2 respectively. (1.4.1, 1.4.2)

7. Does the program provide for the qualification of lead auditors in accordance with the requirements of 2.3.1 through 2.3.5. (2.3)

8. Does the program provide f or a documented annual management assesment to extend qualification, require retraining, or require requalification of lead auditors. (3.2)

9. Does the program require the requalification of lead auditors, who fail to maintain their proficiency for a period of 2 years or more, in accordance with the requirements of 3.3. (3.3) l 1

r 3 of L Filo: VII.o.4-7C.OO1

10. Is there provision f or the lead auditor to concur that the team

- members collectively have the experience or training commensurate with the scope, complexity, or specific nature of the activities to be audited. (4.1)

11. Does the program define the responsibility for the development and administration of the lead auditor examination and for its conformance to the requirements of ANSI N45.2.23-1978. (4.2)

12. Does the program provide for the retention of copies of objective evidence regarding the types and content of lead auditor '

examinations. (4.2)

13. Is there a requirement that lead auditors be certified as being qualified to lead audits, and that the certification documents the elements described in 5.2(a) through 5.2(e). (5.2)

14. Is there a requirement that lead auditor records be maintained and update annually. (5.3)

Concurrence h/h/ ___

l 1

Filo: VII.a.4-7C.OO3

. Audit Personnel Qualification Checklist

1. Develop a list of personnel who have performed as auditor and/or lead auditor from 1973 to present

- Identify the audits in which each participated, or identify the time period of participation in the audit activity as auditor / lead auditor

2. Review training / qualification data for selected audit personnel

- Current audit staff

- Initial audit staff and early audit staff (number to be determined in process)

3. Scan training / qualification data for remaining audit personnel for questionable areas

- General background

- Length / type experience

- Formal education

- Audit training Concurrence _

i 1

I CERTIFICATE OF SERVICE I, Robert K. Gad III, one of the attorneys for the Applicants herein, hereby certify that on August 14, 1986, I made service of.

the within " Answers to Board's 14 Questions (Memo; Proposed Memo of April 14, 1986) Regarding Action Plan Results Report VII.a.4" by mailing copies thereof, postage prepaid, to:

Peter B. Bloch, Esquire Mr. Thomas F. Westerman Chairman Comanche Peak S.E.S.

Administrative Judge c/o U.S. Nuclear Regulatory Atomic Safety and Licensing Commission Board P.O. Box 38 U.S. Nuclear Regulatory Glen Rose, Texas 76043 Commission Washington, D.C. 20555 Dr. Walter H. Jordan Mr. William L. Clements Administrative Judge Docketing & Services Branch 881 W. Outer Drive U.S. Nuclear Regulatory Commission Oak Ridge, Tennessee 37830 Washington, D.C. 20555 Chairman Chairman Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Stuart A. Treby, Esquire Mrs. Juanita Ellis Office of the Executive President, CASE >

Legal Director 1426 S. Polk Street U.S. Nuclear Regulatory Dallas, Texas 75224 Commission Washington, D.C. 20555

Renea Hicks, Esquire Ellen Ginsberg, Esquire Assistant Attorney-General Atomic Safety and Licensing Environmental Protection Division: Board Panel P.O. Box 12548, Capitol Station U.S. Nuclear Regulatory Commission Austin, Texas 78711 Washington, D.C. 20555 Anthony Roisman, Esquire Mr. Lanny A. Sinkin Executive Director Christic Institute Trial Lawyers for Public Justice 1324 North Capitol Street 2000 P Street, N.W., Suite 611 Washington, D.C. 20002 Washington, D.C. 20036 Dr. Kenneth A. McCollom Mr. Robert D. Martin Administrative Judge Regional Administrater 1107 West Knapp Region IV Stillwater, Oklahoma 74075 U.S. Nuclear Regulatory Commission Suite 1000 611 Ryan Plaza Drive Arlington, Texas 76011 Ms. Billie Pirner Garde Geary S. Mizuno, Esq.

Citizens Clinic Director Office of the Executive Government Accountability Project Legal Director 1901 Que Street, N.W. U.S. Nuclear Regulatory Commission Washington, D.C. 20009 Maryland National Bank Bldg.

Room 10105 7735 Old Georgetown Road Bethesda, Maryland 20814 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P.O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Nancy Williams Cygna Energy Services, Inc.

101 California Street Suite 1000 San Francisco, California 94111 n .-

I wr RobertK.76dIII