ML20209A367
| ML20209A367 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/24/1987 |
| From: | Barnes I, Michaud P, Phillips H, Spessard R, Wagner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205L149 | List: |
| References | |
| 50-445-86-08, 50-445-86-8, 50-446-86-06, 50-446-86-6, NUDOCS 8704020163 | |
| Download: ML20209A367 (16) | |
See also: IR 05000445/1986008
Text
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APPENDIX C
CONSTRUCTION INSPECTION REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-445/86-08
Permits:
CPPR-126
50-446/86-06
CPPR-127
Dockets:
50-445
Category: A2
50-446
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Applicant:
Texas Utilities Electric Company
Construction Permit
Skyway Tower
Expiration Dates:
400 North Olive Street
Unit 1: August 1, 1988
Lock Box 81
Unit 2: August 1, 1987
Dallas, Texas
75201
Facility Name:
Comanche Peak Steam Electric Station (CPSES), Units 1 & 2
Inspection At:
Glen Rose, Texas
Inspection Conducted: April 1 through May 31, 1986
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Inspectors .
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K S. Phillips, Senior flesident Reactor
Date
Inspector, Construction, Region IV
CPSES Group
(paragraphs 1, 2, 3, 4, 5.a, and 7)
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P.'C. Wagner,Reactprinspector,RegionIV
Date
CPSES Group
(paragraphs 5.b, 5.c, and 5.d)
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sA,/rr
[ P. Michaud, Reactor Inspector, Region IV
Date
(paragraph 6)
Consultant: Parameter - J. Gibson (paragraphs ..b, 5.c, and 5.d)
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B704020163 070330
{DR
ADOCK 05000445
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Reviewed by:
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R.L.Spesspd,DeputyDirector,
Date
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Division of Inspection Programs,
Office of Inspection and Enforcement
Approved By:
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I. Barnes, Chief, Region IV
Date
CPSES Group
Inspection Summary
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Inspection Conducted: April 1 through May 31, 1986 (Report 50-445/86-08)
Areas Inspected:
Routine, unannounced inspections of Unit 1 which included a
review of plant status and plant tour of the safeguards, electrical control,
and auxiliary buildings; applicant action on previous inspection findings; and
Brown & Root (B&R) audits of site ASME activities.
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Results: Within the three areas inspected, two violations (failure of B&R to
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audit the entire ASME/QA program and to document audits, paragraphs 4.b and
4.c; and failure of Texas Utilities Generating Company (TUGCo) auditor to
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verify correction of deficiency in audit report TPC-51, paragraph 6) and one
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deviation (TUGCo QA procedure does not include all criteria for supplemental
audits, paragraph 4.c; and B&R QA procedure does not agree with supplemental
audit criteria, paragraph 4.c) were identified.
Inspection Conducted April 1 through May 31, 1986 (Report 50-446/86-06)
Areas Inspected:
Routine, announced and unannounced inspections of Unit 2
which included a review of plant status and plant tours of the reactor,
safeguards, diesel generator, electrical control, and auxiliary buildings;
applicant action on previous inspection findings; B&R audits of site
activities; electrical cable, tray, and instrumentation installation; and pipe
supports / restraints.
Results: Within the five areas inspected, two violations (failure of B&R to
fully audit their ASME/QA program and to document audits, paragraphs 4.b and
4.c; and failure of the TUGCo auditor to verify audit deficiency correction,
paragraph 6); and one deviation (TUGCo QA procedure does not include all
criteria for supplemental audits and B&R QA procedure does not agree with
supplemental audit criteria, paragraph 4.c) were identified.
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DETAILS
1.
Persons Contacted
Applicant Personnel
- J. Barker, Executive Assistant to Executive Vice President,
TUGCo
- J. Beck, Vice President, TUGCo
- T. Brandt, TUGCo Quality Engineering (QE), Supervisor EBASCO
'***R. Camp, Assistant Project General Manager, Unit 1, TUGCo
- W. Counsil, Executive Vice President, TUGCo
- P. Halstead, Manager, Quality Control (QC), TUGCo
D. McAfee, Quality Assurance (QA) Manager, TUGCo
- J. Merritt, Director of Construction, TUGCo
- J. Streeter, Director of Quality Assurance, TUGCo
- T. Tyler, Comanche Peak Response Team Program Director, TUGCo
Contractor Personnel
J. Leutwyler, QC Supervisor, B&R
R. Vurpillat, QA Manager, B&R
The NRC inspectors also interviewed other applicant and contractor
personnel during this inspection period.
- Denotes personnel present at the April exit.
- Denotes personnel present at the May exit.
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- Denotes personnel present at both exits.
2.
Plant Status and General Construction Inspections
a.
Status of Units 1 and 2
The NRC inspector reviewed Units 1 and 2 status reports.
Unit 1
construction is complete except for changes to the presently
configured and constructed plant.
TUGCo currently reports Units 1
and 2 as 99.3 percent and 81 percent complete, respectively,
b.
General Construction Inspection, Unit 2
The NRC inspector observed work in progress and work to be inspected
during future inspections.
General housekeeping, in place storage,
and welding rod material control were specifically included in these
inspections and were satisfactory.
During heavy rains, the NRC inspector observed water leaking into the
electrical area (elevation 852') at the rotofoam joint located over
electrical penetrations 2E-37 and 38 at the east end of room 103.
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Several months prior to this inspection, this was pointed out to
TUGCo management but they failed to locate the leak.
In a
conversation with the TUGCo director of construction, he stated that
TUGCo has a checklist for building leaks and this item will be placed
on the list.
Because no regulation or commitment was violated, the
NRC inspector turned this matter over to TUGCo for resolution.
The NRC inspector observed the in place storage of the Unit 2 reactor
vessel internals and found that all of the internals were outside the
vessel until flushing is complete.
They were acceptably stored.
There was evidence that standard fixtures were used to lift each
component. The access to these areas was controlled and shoe
coverings were. required prior to entering these areas.
No violations or deviations were identified.
3.
Action on Previous Inspection Findings, Units 1 and 2
(Closed) Unresolved Item (445/8606-U-01; 446/8604-U-01):
Absence of B&R
audit checklists for the ASME QA manual and work activities.
In
February 1986, the NRC inspector reviewed audits CP-17 and 18 (conducted
in 1980 and 1981) to determine if certain safety-related welding and
related work activities were audited to verify conformance with 10 CFR Part 50, Appendix B Criteria; Final Safety Analysis Report (FSAR)
commitments; QA plan / program / manual requirements; American Society of
Mechanical Engineers (ASME) III, Division I; and the contractor's QA and
construction procedures.
Further review of this subject during this
inspection has resulted in the unresolved item being upgraded to a
violation, which is described in paragraph 4.
4.
B&R Audit of Site Activities, Units 1 and 2
a.
Background and Requirements: The NRC inspector confirmed that B&R
was responsible for all site audits until about September 1978, when
TUGCo assumed responsibility for all audits except for audits of ASME
activities. This change was formally documented in FSAR,
Section 17.1.2, Amendment 3, dated November 30, 1978.
After this
date, B&R was responsible for QA functions relating to ASME Code work
only and the change stated that primary responsibility for the
construction site QA and QC programs lies with TUGCo site QA.
The
Amendment further states that this QA program is organized to provide
an integrated plan under the direct control of the TUGCo management'
QA.
The B&R ASME/QA Manual, Section 19.0, dated September 17, 1981,
requires that the ASME/QA program be audited annually. The NRC
inspector reviewed audits to determine if the ASME B&R QA program was
fully audited from 1980-1985 and if audits were effective.
Sections
of the B&R QA manual, which cover design control and special
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processes requirements of 10 CFR Part 50, Appendix B, were evaluated
in greater depth to assess how effectively these specific
requirements were audited.
b.
Audit of B&R Site ASME Activities:
The NRC inspector reviewed B&R
audit report Nos. CP-17 through CP-31 which covered the period from
1980 through 1985 and part of 1986.
This review indicated that parts
of the B&R QA program may not have been audited during 1980, 1982,
and 1984.
To clarify the above finding, B&R was requested by the inspector to
review the same audit reports and more complete audit files in
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Houston that contained checklists and field notes not presently
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located at the CPSES site.
The results of the B&R review were
presented to the NRC inspector in the form of a matrix that is
included as Appendix D to this report.
This matrix and other
supportive documentation confirmed the finding that parts of.the B&R
QA program were not audited during 1980, 1982, and 1984.
In meetings with B&R and TUGCo management personnel to discuss the
above findings, it was acknowledged that several areas were not
audited annually.
Specifically, the data in Appendix D shows that,
in 1980, 12 sections of the B&R QA Manual were not audited; in 1982,
6 sections were not audited; and in 1984, 8 sections were not
audited.
The matrix developed by B&R (Appendix 0) indicates that the B&R QA
program was completely audited for 1981, 1983, and 1985 except for
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those areas that were not applicable.
This failure to fully audit the entire ASME/QA program is a violation
of Criterion XVIII of Appendix B to 10 CFR Part 50 (445/8608-V-01;
446/8606-V-01).
c.
Documentation of B&R Audit Implementation:
The NRC inspector
selected two criteria (Control of Field Changes and Control of
Special Processes) for evaluation to determine if the audits were
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comprehensive as described by American National Standard Institute
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(ANSI) N45.2.12, paragraphs 3.1.2 and 3.1.3;
i.e., "To verify by
evaluation of objective evidence that the documented program has been
implemented.
To assess the effectiveness of the quality assurance.
program." Similarly, B&R QA Manual, Section 19.0, requires that
objective evidence be provided to show compliance with pertinent
specifications, codes, and procedures.
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(1) The NRC inspector reviewed the list of project documents to
identify applicable B&R implementing procedures which relate to
field changes by B&R construction.
The following procedures
related to this area:
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B&R QA Manual, Section 4.0, " Design Control"
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CP-CPM-4.1 (dated 1981), " Construction Request for
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Engineering Design Changes"
CP-CPM-9.13 (1984, Revision 10), " Modification of Vendor
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Supplied Catalog Items"
CGP-7 (no date), " Control of Field Sketches"
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WEI-4.6 (1982), " Instruction for Control of Welding
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Engineering CMC's"
CP-QAP-04.01 (1985), " Design Control"
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CP-QAP-02.04 (1983), " Program for Repair / Alteration of
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ASME-N Stamped Components"
Audit Reports CP-18 (1981 period), CP-21 and 24 (1983), and
CP-27 (1985) were reviewed by the NRC inspector to evaluate B&R
audit responsibility for the above areas during 1981, 1983, and
1985 that is shown as having been audited in the matrix
(Appendix D).
The above review indicated that the audit report documentation,
including the checklists, was deficient in that the NRC
inspector could not determine if the B&R design change control
function, as specified by the above noted procedures /
instructions, had been audited.
While the audit reports and
checklists do contain references to several relevant QA Manual
audit characteristics, the documentation to support the
conclusions reached was too sketchy (or non-existent) to show
that effective audits had been implemented in this area.
Failure to provide adequate documentation to support
implementation of audits in the area of field design changes is
a violation of Criterion XVIII of Appendix B to 10 CFR Part 50
(445/8608-V-02; 446/8606-V-02).
(2) Audit Reports CP-17 through CP-31 were reviewed by the NRC
inspector to determine compliance with audit requirements in the
area of special processes (Criterion IX of 10 CFR Part 50,
Appendix B).
In audit CP-17, the B&R auditors looked at
in process welding, observation of weld fitup, cleanliness, use
of correct weld process specification, and compliance with
welding parameters in the fabrication shop. With the exception
of CP-17, the 1980-1985 audit reports generally indicate a heavy
emphasis placed upon the audit of personnel / procedure
qualification and filler material control procedures and did not
show evidence of observation of field welding, compliance with
applicable procedures and specification requirements.
In
discussions with the B&R QA manager and the TUGCo QA manager
regarding the documentation of special processes, the B&R QA
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manager stated that their audits were better than their reports
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indicated; however, he agreed that the audits of special
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processes appear to be deficient as documented. He subsequently
arranged to have the~ auditors discuss this' matter with the NRC
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inspector in further detail. They, too, stated that their
audits of special processes were more comprehensive than the
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reports indicated,
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Itwasobserved>inAuditRepordCP-17(1980) that the B&R' ..
auditors concluded that several aspects relating'to their audit
of special processes were not' evaluated sufficiently to assure
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conformance with applicable codes and standards and that these
areas should be reevaluated during the next audit. The NRC
inspector reviewed subsequent aud_it reports to determine if
these specific areas relating to special processes had been~
audited and documented. The inspector could not find subsequent
documentation to confirm reevaluation of these areas and B&R,
upon request, has been unable to provide documentation of this.
specific reevaluation.
Failure to provide adequate documentation of audits performed to
insure special process controls were implemented is a violation
of Criterion XVIII of Appendix B to 10 CFR Part 50
(445/8608-V-03;446/8606-V-03).
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The NRC inspector developed a matrix of special process
procedures to determine how many procedures were audited.
Credit was given if mentioned in the report (not necessarily
audited). A
procedures) pproximately 12 (one QA Manual Section and
of 75 project documents were referenced or mentioned
in B8R audits between 1980-1985. 'This roughly equates to about
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15% of the total or about'3% per year audited,
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This item is unresolved pending a demonstration by TUGCo and 88R
that a sufficient number of procedural activities were audited
to determine compliance with Criterion XVIII (445/8608-U-04;
446/8606-U-04).
(3) Audit Reports CP-17 through CP-31 were reviewed by the NRC
inspector to determine compliance with audit requirements in the
area of inspection (Criteria X of 10 CFR Part 50 Appendix B).
The NRC inspector developed a matrix of procedures audited by
B&R from 1980-1985 and found approximately 8 of 55 applicable
project documents were referred to in the audits. This roughly
equates to 15% total and 3% per year partially audited.
It
appears that one of the main functions of quality assurance,
assuring that the inspection process verifies conformance with
engineering'and construction procedures, may not have been
audited frequently enough and to sufficient depth to assure an
effective inspection program.
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This item is unresolved pending a demonstration by TUGCo and B&R
that a sufficient number of procedural activities were audited
to determine compliance with Criterion X of 10 CFR Part 50,
Appendix B (445/8608-U-05; 446/8606-U-05).
d.
Evaluation of TUGCo and B&R Actions to Correct Previous Audit Program
Deficiencies:
The inspector evaluated the items of noncompliance
concerning B&R's performance in the area of QA audits (as described
above) and the similarity of these findings to other reported
deficiencies observed in the past and that have resulted in a
previous Notice of Violation (84-32/11).
It is clear from this
evaluation, which refers to both reviews and audits conducted many
years ago* along with more recent findings, including those currently
being addressed, that TUGCo's actions over time to correct and
improve its overall audit function have not been fully successful.
The inspector's basis for this conclusion is as follows.
The items of noncompliance concerning BAR audit program deficiencies
reported herein for the years 1980, 1981, 1982, 1983, 1984, 1985, and
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1986 appear to be similar and are apparently connected to other
previously identified items of noncompliance, specifically those
reported in NRC Inspection Report 50-445/84-32,50-446/84-11
concerning the licensee's role as auditor of the overall construction
project. The B&R audit program is an integral part of the licensee's
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QA audit program and the findings in this report appear to be further
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examples of audit program deficiencies, although it is recognized
they relate to a contractor's audit program.
Also, it is observed that the items of noncompliance appear to have a
connection to findings and recomendations stemming from an external
Management QA Audit [ Management Analysis Corporations (MAC-JPJ-471,
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Page 5. Item 9)] performed during a much earlier time frame (1978).
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Additionally, and of a more direct nature are the similar findings and
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recomendations reported directly to B&R in external audits
(MAC-77-66,ManagementSummary, Items 12and15)performedinabout
the same time frame and dealing with apparent QA audit program
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weaknesses.
The above mentioned external audit reports were not
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provided to the NRC until 1985; i.e., after the time frame that the
50-445/84-32,50-446/84-11 inspection was performed. Those reports
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were, however, reviewed during this inspection.
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ConsultantReportsMAC-77-66(1977), MAC-JPJ-471(1978), P. S. Lobbin
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(1982),andNRCReports 82-25/13(1982),83-18/12(1983), Comanche Peak
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special Team Report (July 1984),84-32/11(Sep1984),andSupplemental
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Safety Evaluation Report No. 11.
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At the time NRC Inspection Report 50-445/84-32; 50-446/84-11 was
issued, the option was offered and accepted by TUGCo letter TXX-4453
dated March 11, 1985, whereby the licensee elected to respond to
violations contained in this report as part of the Comanche Peak
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Response Team Program Plan.
However, this option did not include any
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delay relative to assuring that all audit program deficiencies,
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including deficiencies in site contractor's audit programs, were
promptly identified and corrected to preclude repetition. Rather, it
was NRC's understanding and expectation that these violations,
together with related pertinent external source issues (e.g., TRT,
MAC) would be specifically included in the assessments performed by
Issue Specific Action Plans (ISAPs) VII.a.4 and VII.a.5, given the
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scope of each. As a result of NRC review of the results reports for
these ISAPs. It is apparent that the results reports, in themselves,
do not explicitly identify and describe the disposition of these -
external source issues. This is a matter of concern when viewed in
the light of the findings noted in this report regarding the B&R
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audit program and will be the subject of separate correspondence from
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the NRC.
e.
B&R OA Manual and Implementing Procedures for Auditing: The NRC-
inspector reviewed the 58R QA Manual, Section 19.0, " Audits," dated
February 15, 1985.
BAR procedures which implement the audit program
and applicable revisions were also reviewed. . These procedures were
compared to the TUGCo QA Manual and implementing procedures to
determine if they conformed to TUGCo's overall QA program. It was
determined that Section 19.0 of the B&R QA Manual is consistent with
TUGCo QA Plan, Section 18.0, dated July 31, 1984; however, B&R
Procedure CP-QAP-19.1 is inconsistent with TUGCo implementing
Procedure DQP-QA-15. Revision 0, dated ~ September 9, 1985.
Specifically, paragraph 3.4.5 of the BAR procedure states that
supplemental /special audits and investigation may be performed if
certain adverse trends occur in the QA program while TUGCo Procedure
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DQP-QA-15. Revision 0, dated September 9, 1985, states that audits
are performed when adverse trends occur.
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In an earlier BAR procedure (CP-QAP-18.1 issued in 1975), it was
stated that supplemental ~ audits shall be performed and this wording
was used in subsequent revisions until January 15, 1982, when
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CP-QAP-19.1 was issued. -This change in requirement is a deviation
from FSAR, Section 17.1.2, which consiits to ANSI N45.2.12.
ANSI M45.2.12 states that supplemental audits are conducted when the
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following conditions are evident: significant QA program changes
occur, a safety-related item is in jeopardy due to QA program
deficiencies, an independent assessment of an item's quality or
program effectiveness is necessary, or it is necessary to verify the
implementation of corrective action. This change to supplemental
audit criteria is a deviation from paragraph 3.4.3 of ANSI M45.2.12
Draft 3. Revision 0 (445/8608-0-06;446/8606-D-06).
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-Also, during the above comparison, the NRC' inspector noticed that
TUGCo's criteria for supplemental audits deviate from ANSI N45.2.12
criteria. That is, two criteria (described in paragraphs 3.4.3.1 and
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3.4.3.5 which require assessment of contractor's QA program prior to
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contract award and assessment of item quality or program
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effectiveness) were not incorporated into TUGCo Procedure DQP-QA-15,
Revision O.
The failure to incorporate these criteria is a deviation
from the commitment to paragraph 3.4.3 of. ANSI N45.2.12, Draft 3
Revision 0(445/8608-D-07;446/8606-D-07).
S.
Electrical Cable, Tray, & Instrumentation Installation Unit 2
a.
Electrical Cable Pulls:
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(1) Procedures - The NRC inspector reviewed TUGCo Instruction
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QI-QP-11.3-26 Revision 27, " Electrical Cable Installation
Inspection" which describes work attributes such as pull card
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preparation, raceway cleanliness, conduit swabbing, raceway
indentification, cable condition, cable pulling operation, cable
splicing, cable tie material / spacing, separation criteria and
cable repairs, that must be inspected. These applicable
attributes for controlling work activities and other specific
work were observed as described below.
(2) Observation of work - The NRC inspector selected and
observed two cable pulls which were the result of a request for
rework. The cables (1 SHLD TW PR 16 AWG 600V Instrument,
material type code W-465) were pulled from (a) junction box
(JB)2S35G to JB2S224G, and (b) JB2S35G to JB2S223G. The
following in-process controls were observed:
latest approved
procedures and pull card available, cables'and pulling compounds
as specified, tension measuring device not needed, cable
temperature acceptable, raceway / conduit complete, cable free
from defects, cables protected from sharp edges / minimum bend
radius, cable routing correct, separation criteria checked,
cablesupportsprovided,cableslack(minimum)injunctionbox
acceptable,' access by scaffolding checked, cable trays / conduits
free from debris, coiled cable properly secured, unterminated
cable ends protected, QC inspector present/ knowledgeable,
nonconformance report (NCR) properly handled.
(3) Records - The NRC inspector reviewed inspection report
Nos. 2-0090547 and 2-0090552 for electrical installation and
identification of EG246135 and EG246137 pulled in safeguards
building room 77S at the 810 foot elevation.
No violations or deviations were identified.
b.
Safety-Related Cable Tray installation: The NRC inspector observed
two cable tray sections iT230SF005 and T240SDA94) in the auxiliary
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building that were not bolted down to their supports.
In some
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places, the trays were not touching the supports. The NRC inspector
also noted that cables were installed in the trays. This-item was
referred to the' applicant to determine why this condition existed,
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and the answer provided by the applicant to the NRC inspector was
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~that there are no specifications or procedural requirements for the
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trays to be bolted down prior to final turnover of the plant to
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The NRC inspector subsequently reviewed-TUGCoLInstructions-
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QI-QP-11.3-24, Revision-14, dated September, 18, 1985, " Class _IE Cable.
Tray Raceway Inspections," and QI-QP-11.3-26 Revision 24, dated -_
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October 11, 1985, " Electrical Cable Installation Inspection." The
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NRC inspector concurs with the applicant's statement that no
procedural requirements exist pertaining to the bolting down of cable-
trays prior to cable installation. The_NRC inspector also reviewed
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B&R Engineering Instruction EEI-7, Revision 5, dated October 8, 1982,
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" Cable Pulling." Paragraph 3.3.2 of this procedure states with
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respect to pre-pulling activities, " Raceway is adequately supported
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for cable pulling activity."
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The NRC inspector determined that the lack of specific requirements
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regarding cable' tray supports, including' bolting, prior to cable
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installation, may constitute procedural deficiencies. =This item is
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open pending additional inspections by the NRC inspector in a
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subsequent inspection period -(446/8606-0-08).
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c.
Instrumentation Tubint Installation: The NRC inspector identified
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tubing associated witi pressure transmitter 2PT-965, near root valve
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2SI-061, which had an inverse slope, and appeared to have been
" stepped" on. A scaffold had been erected below the tubing run,
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resulting in the tubing being approximately 1 foot above the floor of
the scaffold. There was no evidence of protection of the tubing from
,
j
adjacent work activities. Upon identification of this condition to
i
the applicant by the NRC inspector NCR I-86-201579 was initiated.
1
The NRC inspector observed that this condition was an isolated
j
occurrence (446/8606-0-09).
4
1
d.
Pressure and Flow Transmitter Installation: Also, during the above
!
mentioned inspections, the NRG Inspector identified that there were
I
loose gland packing nuts on the isolation and drain valves associated
!
with pressure transmitter 2PT-965, and flow transmitter 2FT-4560,
i
The NRC inspector further identified loose gland nuts on
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approximately 25 instrument related valves in addition to the two
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cited examples.
Identification of the two examples to the applicant
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resulted in the initiation of NRC I-86-201578, which pertains to
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The applicant subsequently provided the'NRC inspector information-
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from the valve manufacturer (Kerotest Manufacturing Corporation) that ,
the valves in question (Model D-22) require no specified torque on
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the gland nut. These valves utilize an integral diaphragm assembly,
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installed between the ste,m and disc 'to proviet the primary; pressure
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bour4ary. The packing with its retaining gland nut serves as the
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pressure boundary only in the event of ti:e dudirain rupture. The
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NRC inspector had no .further questions on,the subfact.
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.No violations or deviations were ider.chied.
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Pipe Supports / Restraints. Unit 2
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The NRC inspector' reviewed TUGCo QA audit TCF-51- (September 19t's) and l-
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found that deficiency No. 1 of this aidit concerned operation travelers
(for ASME moment restraints) that had been transtiltted to the pemanent
.
records vault without being routed to tha QA ITocssetnt PavieVGroup (DRG)
'
as required by CPM-6.3 and QI-QAP-11.1-38. TUGCo'.nemo QPA-24174 dated
,
October 22, 1982, called for corrective action to. Identify which travelers
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had been sent to the vault without DRE review and to Sulmit.a list of
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these travelers to DRG. This actich was apparently never taken.
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dated February 3[ 1$63, stated, in gart, "iney will be
'I
B&R letter 35-1195
A redised
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reviewed eventually, prior to N-5 Data Report signoff.
response on February 4,1983, changed actior:s to be taken associeted'aith
a
another audit comment, but did not include a statement addresstry the need
,
,
to review the traveliers already in the vault; 'Thit revised response was
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used as a basis for cenpleting corrective actions and clos.ing , deficiency
,
No. 1 per memo QTN-910edated hbruary 17, 1984. TUGCo
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Procedure CQI-CS-4.6, Revision 3. dated August 8,19P2, re(uires that
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auditors verify implementation of corrective actici commitments. The-
9
deficiency was apparently closed without verification that the operation
travelers b.sd been identified or reviewed. The operation travelers tre
,1
question have, Jn fact, been re. viewed per Procedure CP.-QA?-12.11:.
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Mechanical Component Ynsta11ation Verificationc N-5 Ceat W eation.
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This faiiure to assure complete corrective actio7 fur aNht deffeiency d 8
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No.1 in audit report TCP-51 is a violat%r. 9 Criterion XVI of Appendi
to 10 CFR Part 50 (445/8608-V-08; 446/8 &$- M O).
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Exit Interview
. . .
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Exit interviews were conducted May 8 and buae 3, 19 6 , with the
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applicant's representatives identified iri caragraph 1 of tlis report.
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During tl'ese interviews, the NRC inspecter, summarized the scope and
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findings of the inspection. The applicant' acknowledged tM findings.
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Subsequent to the exit, the applicant presented addtiomi infomation
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concerning'a potential violation discussed duringitr O exit. This
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information showed that no violat hr. occurred.
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APPENDIX D
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B8X Matrix of Annual Audits of ASME/QA Program (1980-1986)
The NRC inspector identified instances where the QA program was not audited.
B&R e,anagement was requested to provide a matrix of areas that they could claim
, credi+. for auditing to compare with the NRC inspector's findings concerning
areas audited.
The following matrix provided by B&R shows areas which were not
-
audited.
~
AUDITS PERFORMED (1)
1980
1981
1982
1983
QA FANUAL
, SECTIONS
9/16-19 9/21-28 3/16-18 6/21-25 4/17-20 4/25-29 8/1-4 12/12-14
,
4
Authorized
'
Nuclear
'
Inspector
0
X
N
X
N
N
X
N
Audits
X
X
X
N
N
X
N
O
'
QTRecords
X
X
X
X
X
N
X
N
l
I
Corrective
A-t ion
X
X
X
N
N
X.
N
N
j
!
l:onconforming
)'
Items
0
X
X
N
N
X
N
N
Exam & Process
'
Status
0
X
X
N
N
X
N
N
in
Handling &
l
Storage
X
X
0
0
X
N
N
X
l
Centrol of
M & TE
O
X
N
X
N
N
X
N
i
Test Centrol
0
X
N
X
N
X
X
N
'
Exams, lests &
Ins;ections
0
X
X
N
N
X
N
N
'
Centrol of
Special
'
j>
Processes
X
X
N
X
N
N
X
N
(1) See page 4 for explanation of symbols,
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3. ,
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.
.
.
2
.
. .
.
.
.
.
.
.
-
.
.
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2
AUDITS PERFORMED
,
1980
1981
1982
1983
QA MANUAL
SECT _ IONS
9/16-19 9/21-28 3/16-18 6/21-25 4/17-20 4/25-29 8/1-4 12/12-14
5
Identification
t
.& Control of~
'
Items
0
X
0
0
X'
N
N
X
Control of
,
Purchased
.
.
Items &
- ,,
,
Services
0
X
X'
N
X
N
N
X'
Document
Control-
X
.X
0
0
X
X
X
N
Instructions
Drawings &
,
Procedures.
0
X
X
N
X
N
.N
.N
Procurement
Document
Cortrol
0
X
0
0
X
N
N
X
Design &
Control
0
X
0
0
X
N
N
X
Organization
0
X
0
0
X
N
N
N
.
1
QA Program
X
X
N
X-
X;
X
N
N
-
,
,
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2
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5
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3
'
AUDITS PERFORMED
1984
1985 -
1986
QA MANUAL
SECTIONS
- 3/19-21 7/30-8/1 1/14-17 4/22-25 8/19-21 1/20-22 4/5-7
.;
Authorized'
Nuclear _
1
Inspector
0
0
X
'N
N
X
N
Audits.
NS
NS
NS
NS
NS
NS
NS
QA Records
0
0
X.
N
N
X
N
Corrective
Action
N
X
X
X'
N
N
X
Nonconforming
Items
'
N
X
N
X
N
N
X
Exam & Process
Status
N
X-
X
N
X
N
N
I
Handling &
Storage
0
0
X
N
N
X
N
Control of
M & TE
O
0
X
N
X
N
N
,
Test Control (2)
N
X
0
0
0
0
0
Exams, Tests &
_
Inspections
N
XL
N
N
X
N-
N
Control of
Special
Processes
0
0
X
N
X
0
0
s
(2) Hydrostatic testing not performed during 1985
,
s
t
. _ _ -.
4
..
.
_
4
AUDITS PERFORMED
'1984
1985
1986
QA MANUAL
SECTIONS
3/19-21 7/30-8/1 1/4-17 4/22-25 8/19-21 1/20-22 4/5-7
Identification
& Control of
~
Items
0
0
X
N
N
X
N-
Control of
Purchased
Item &
Services
0
0
X
X
N
X
N
Document
Control
X
X
X-
X
N
N
X-
Instructions
Drawings &
Procedures
X
N
N
X
N
N
X
Procurement
Document
Control
0
0
X
N.
N
X
N
'
Design &
Control
0
0
X
N
N
X
N
5rganization
X
X
N
X
N
N
X
QA Program
X
N
N
X
N
N
X
Code:
0 - Area not audited
X - Area was audited
N - Previously or subsequently audited which satisfied annual requirement
NS - No site audit group which corporate could audit
.
. . _ _ - _ - - -
-
. . _ , _