ML20215E945
| ML20215E945 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/03/1977 |
| From: | MANAGEMENT ANALYSIS CO. |
| To: | |
| Shared Package | |
| ML20214X072 | List: |
| References | |
| MAC-77-66, NUDOCS 8610160029 | |
| Download: ML20215E945 (28) | |
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FINAL REPORT MANAGEST AUDIT OF THE BROWN & ROOT QUALITY ASSURANCE PROGRAM
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k MY 9 THRU MAY 20, 1977 (c9' MAC-77-66
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June 3, 1977 C'
B610160029 860922 PDR ADOcK 05000445 A
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._ 7 INTRODUCTION N.
This management audit was conducted at the request of the Brown & Root Quality Assurance :ianagement 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 well as. cost effectiveness in implementation.
It is B&R's policy that such audits be conducted utilizing BAR personnel to the maximum extent practical. To this and the audit was conducted with two Management Analysis Company i
representatives and six* Bewun &' Root personnel representing such organi-zations as Engineering, Licensing, Quality Assurance, Purchasi.ng, Construction and Operations. The audit consisted of a one week audit of home office activities at Houston and one week at the Comanche Peak Muclear Proje-:t Construction sita. 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, B&R Quality Assurance A. H. Geisler, B&R Licensing J. H. Hobbs, B&R Licensing (Part time)
D. F. Hanlen, B&R Engineering G. A. Tell.B&R Subcontracts J. E. Roscoe, B&R Construction J. T. Wilbur, B&R Operations MANAGEMENT
SUMMARY
It is recessended t5at B&R move ahead innediately with the establish-l.
ment of site Quality Engieeriag organizations at STP and CP which are independent of Inspection but repcrting along with Inspection directly to the site Q. A. Manager.
Abandon the proposed organizational conce'pt whereby inspectors are assigned to the construction organization.
Recnnnend that the B&R Q. A. Manager realign the present organization 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. -
4 J.
Establish a task force of key representatives from Engineering, Construction, Purchasing Operations and Q. A. with full management s pport
.to embark on a program with an approximate three month completion date to consolidae and simplify the structure of the Quality Assurance Manual (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 control utilized by B&R in implementing their Quality Assurance Program.
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It would be supported by a Q. A. Manual for each site which would be
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consistent with the top manual thereby providing a sirigle B&R system for all projects relative to such things as design document control, purchasing control, special process control, work instructions, manu-facturing control, calibration, audits, records -control, etc.
The only additional manuals required would be a Corporate Special Process Procedures Manual.
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3.
Q. A. Procedures, although coordinated with affected organizations.
g are issued unilaterally with.Q. A. approval.
It is-recommanded that all future Q. A. procedures be issued only with the prior approval of all organizations affected by the procedure. This policy should apply to all levels of p adures at the home office and sites.
t 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 maintenance 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 system that is based on site input as received from the home office.
5.
The FREA system of requesting engineering infomation is being abused to pemit changes / deviations without generating the necessary g
DCN's.
Based on the established B&R system for design document change, h.
approved DCN to, the drawing or specification. formal approval of change Stailarly, the SOR system is abused in that they are used as approved changes in lieu of generating the necessary change notices and/or DCN's.
TWo ' engineering procedures were observed to be deficient in that one 6.
g was expired and the other was in an " interim use" status for the past three years.
e 7.
Changes to vendor specifications are not being transmitted to and acknowledged by the supplier and/or incorporated into the purchase i
order.
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8.
A more visible and clearly identified systen of defining release of design documents for fabrication or construction should be established as a universal Brown & Root systes.
It is reconnended that su' h a c
l system incorporate a readily recognizable controlled B&R release stamp
- on all design documents.
9.
As yet no procedure exists which defines the all important function of connunicating design information.
If the CRT system is going to represent B&R's official design data base, it should be defined procedurally.
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Checklists for the performanceaf source inspection by the Vendor Surveillance Specialist.(VS$) are prepared in generic fashion by the VSS.~ It is recomended that checklists identifying specifically what is to be inspected be prepared by the home office quality engineers in cooperation with design engineers so that important design characteristics i
can be identified.
- 11. Average turnaround time for obtaining ifouston approval on STP
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constmetion discrepancies -was 26 days for the first quarter 1977. This excassive turnarce,d time will create difficult coitrol problems on defective hardware and work as the aeount of construction increases.
12.
The Houston audit program as presently conducted is fiieffective.
Eight out of the 14 audits conducted during the past year are still open.
Some Audit Deficiency Reports are 6 to 12 months old.
The audit program should be revamped to ecmhine the findings and corrective action on a single audit report. Additionally, internal system audits should utilize a single auditor rather than audit teams for increased effectiveness.
13.
It is recommended that both construction and quality assurance start a vigorous, formalized preplanning effort characterized by lift drawings,-
material takeoff lists and inspection planning unique to each lift or 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 form.
The failure to incorporate changes into design specifications and drawings is niaking their ' intelligibility impossible.
This situation if it continues will most as:uredly result in construction errors.
Average turnaround time for FI/CR's to Gibbs & Hill is averaging a month.
or more.
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- 15. The site audit pngram is ineffective,.
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9 EXHIBIT 1 08SERVATIONS AND RECOMMENDATIONS e
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08SERVATIONS AND RECOMMENDATIONS a
H00STON
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Organization and Quality Assurance Procram 1.-
It was perceived by key managers in the Quality Assuran that salaries for Quality Ass' rance Engineers are too low. ge Organization u
In support of 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 Civil Engineer.
It is MAC's experience th'at the B&R salary scale is low by as much as 15 to 20 percent based on today's market for experi-enced quality engineers.
This situation can result in attrition amengst present B&R Quality Engineers or increased difficulties in hiring qualified engineers.
3 2.
It was perceived by several line su
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ment response time to solving problems,pervisors that B&R senior manage-notably in the procedures area was slow. This was supported by the fact that many of the problems noted in MAC's pre'vious audit were still not acted upon even though the managers involved supported the fact that system changes indicated in the audit were in order.
Additionally, the findings set forth under Design Control indicate that key procedures are still in an interim status; a further indicator of slow response time on correcting system problems. As one supervisor pJt it, "the managers are too involved in day-to-day construc-J tion and. engineering problems to place sufficient emphasis.on procedures and systems,"
".f 3.
During this audit MAC was made aware of a change in B&R 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 woul'd, in the long haul, prove' ineffective.
This practice was in vogue in many manufacturing companies a decade ago, whereby inspectors reported to the manufacturing nanager as opposed to i
the Quality Assurance (Quality Control) Manager.
In most instancas, the inspection force, due to a lack of strong management support due to the conflicts of schedule, cost and quality, was rendered virtually in-effective in implementing the necessary objective controls of acceptance, rejection and documenting nonconformances required to monitor quality compliance.
As a result, one rarely sees such an organization today even in consumer oriented product companies because it simply doesn't result in good inspection, i
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B&R made a progressive move amongst Architect Engineers when they assigned the inspection function to the Quality Organi::ation.
It is MAC's opinion that the effectiveness of the inspection is diminished i
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ii considerably, however, due to the lack of a separate site quality
, engineering function independent of inspection.
This was pointed out in last year's audit as a move that would greatly enhance the effective-ness of B&R site Q. A.; and although generally a Quality Assurance Manager, was never acted upon. greed upon by the B&R MAC strongly rriom-mands that such action be taken imediately at STP and Comanche haak in lieu of the proposed reorganization scheme set forth in the pending topical report.
- 4..The Q0a11ty Assurance Program as presently dessMted in 12 different Q.A./Q.C. manuals is too complex. SeMous 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 msponsibilities and in many instances the key foms utilized in imp 1'ement-l ing the BAR Q. A. program.
Perfoming such a consolidation would do much in the way of eliminating l
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.
5.
It was observed that Quality Assurance can unilaterally issue procedures that can have an impact on organizations other, than Quality Assurance without fornal approval by the effected organization.
A system should be established whereby fomal approval signcff is mandatory by all~ organizations outside of Quality. Assurance if they are in any way effected by the procedure.
Such a system will provide the necessary
' dialogue and discussions between organizations and force resolution of di-fferences pHor to the issue of procedures.
Such resolution may have.
to take place at the executive levels of. management on occasion.
This is, however, desirable since the final outcome represents a genuinely.
unified approach of all synagement with respect to necessary controls.
Design and Document Control 1.
STP Engineer:ing Procedure STP,0C-001-D, Section 2iS, recognizes the necessity for instructions and guides issued by the Discipline 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 e
Control Center to define the functions of each clerk and the flow through DCC of each type of document.
Examples of such DCC guides would be the prioMty of inputs into the CRT system and the utilization of CRT system output.
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2.
At both the STP site and CPSES site, the Document Control Centers
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The
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site DCC is the controlling focal point for all documentation on site.
They control the initiation, receipt, acknowledgement, maintenance, distribution, superseding, destroying, etc., of all site documentation.
They know who initiates documents, who has documents and who needs documents. They effectively utilize the CRT system to monitor status and control distribution of documents.
It is reconnended that lead personnel from Engineering DCC review and implement (where applicable) the site methods for monitoring and control. ling documentation, and utilizing the CRT system.
3.
Design change documents will.often bear identifying dates such as ZYO6055033-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.4-19-77 in this It is reconnended that design changes be identified by consecu-case.
f:ive numbering of the change notices to the document.
4.
Reconsund establishing a single means of identifying the femal release of all design documents issued for construction or fabrication.
This method should be.consunicated to all concerned.
Personnel authorized 'to release documents should be identified, 5..
Recommend that suppliers. request changes or deviations for design documents by some established means.
Engineeri.ng approved changes /
deviations be incorporated and communicated through a Change Order to'
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. the Purchase Order'. This method should serve the following advantages:
'-0, The request fanat becomes simply a request, eliminating a.
any distribution or tracking problems encountered by SDR's.
b.
Supplier beccmes legally bound to furnishing the product as approved by BAR Engineering.
All concerned parties become knowledgeable of the design c.
configuration through established P. O. change distribution.
6.
Engineering Procedure STP-0C-023-0 and Construction Procedures GCP-21, Rev. 2, Field Request for Engineering Action, both specify that the Constmction Chief Engineer may deviate from. construction j
requirements contained in safety related documents withot:t engineering approval provided he can substantiate such deviation and provided such i
j deviations do not violate SAR consitments.
Again, this appears to be another abuse to the FREA System. All changes / deviations to safety i
related documents'should be reviewed, approved and design verified by the same organization that originated the design, t
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Indoctrination and Trainino
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It was voted that there is an imediate need for a level III 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 insiinent.
Procurement Control The latitude allowed the Vendor Surveillance Specialist to establish l
his own inspection checklist from the General Vendor Surveillance Plan should be discontinued in favor of a detailed and definitive checklist issued by the Q. A. Department. This will return control of vendor surveillance to the home office (Houston) where there is personnel much more knowledgeable of the total requirement picture than the VSS i
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 inform 1 tion regarding a given vendor package appears unwieldy. A great deal of time was consumed locating applicable documents as there are different files in different locations', each containing only a portion of the total package.
l Audits i
,k The present audit system should be revised to require corrective action -
coeurf tment prior to the issuance of the audit report.
This would give top management visibilit;y 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.
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 perfon: 50 to.75 audits per yeare These 14 audits covered 5 at Houston (home office) 4 at the South Texas Project and 5 at Comanche Peak.
It is recomended 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 trouble spots.
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N COMNICHE PEAX
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Organization and Quality Assurance Program 1.
It is reconnended that the 8&R Quality Assurance Manager, establish the Project Quality Assurance Organizations such that the sita Quality Assurance Manager has total Q. A. responsibility for the project.
He should be assigned the responsibility and authority to represent B&R
.Q. A. to the owner on all Q. A. matters related to the project. This would include the realignment of certain activities assigned to the home offica such as Quality Engineering Planning of source inspections, design review Q. A. problems, resolving owner audits of the home office etc. He would report directly to the B&R Q. A. Manager and would, of course, work with the home office Q. A. organization in perforining his total Q. A.- function. The Houston coordinators would report functionally to the sita Q. A. Manager.
The site would be responsible for the pre-paration of sourca inspection checklists in the case of Comanche Peak procurement and sita quality engineers would resolve some inspection problems related to CP hardware.
In establishing such an organization th sita Q. A. Manager becomes the prime interface with the owner's Q. A. Manager on day-to-day problems.
He involves the B&R Q. A. Manager only as necessary on significant problems of a policy nature. He would have full authority to change or.
modify procedures affecting his project within the restraints of the QM B&R Quality Assurance Manual.
Such a move would provide the B&R b
Quality Assurance Manager with a direct channel of consunication to the i
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
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Houston Observations and Reconnendations, the site Q. A. organization should 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 initiata design change requests, disposition and approve nonconformance reports, handle technical problems resulting from source inspections, assist on NRC i
audits and so forth.
It is reconnended that such an organization report l
at the'same level as the inspection organization to the sita Quality Assurance Manager.
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. yg5gpe.v.c.wwwnew+7EiiMMWWMMOnn? N'EEWhhN Itwasgenerallyobservedthatconstructionandquaifty.assurancedonot
,3 issue work instructions and procedures jointly.
Historically, construction C./ -
has gone down a path of establishing procedures and work instructions which require Q. A. approval while Q. A.'has gone down a similar 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 instryc-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 recommended 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 documents 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 sita 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 t
l do take an unduly length of time to get changed due to the coordination required with the owner, the site personnel and Houston personnel.
Every effort should be made to reduce turnaround time on procedures to a few g.3d e;
days. Changes will occur and the present system (which based on open audit reports is taking months to change a procedure) must be expedited.
5, It was observed that little is being.done with respect to formalized preplanning of work.
B&R has no requirement, for example, to issue materia.1 takeoff lists for each lift of concrete to the craft superinten-dents.
Such lists prepared by ' construction engineers and supplemented by detailed inspection planning prepared by quality engineers and jointly approved by both would aid considerably in the conduct of construction operations.
If B&R were formally conuritted to such a program, it would force earlier release of design drawings to the site.
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Desion and Change Control 1.
Desion Chance 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
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design change authoHzation 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' authoH zation.
2.
Timeliness of Desion Chance Acoroval. The average time required to process FDCR's written during the month of February was 30 days with 3 still~open.
Civil Section FI/CR's for April. averaged 14 days for pro-cessing and 28 FI/CR's from ApH1 still remaining open.
Inab.111ty to process changes on a timely basis results in severe schedule pressure to work in advance of authoH zations.
3.
Limit on Chances to Desion' Documents. A inaximum limit should be placed upon tne numcer of casign enan document revision must be initiated. ges accumulated before a mandatory,
i This limit should address to quantity as well as a maximum time ever which design. changes can be accumulated.
A single design change fomat should also be implemented that is readily recognized by all organizations as the one document W
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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 documents. This problen is pH maH 1y concerned
.. with Gibbs, arid' Hill reproductions.
It is understood that corrective
. action has been. requested by BAR perso,nnel.
1 Indoctrination and Training
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It is understood that at peak manpower there will be in excess of 2.000 separata personnel training records.
With the availability of a CRT network on site, it would be well to consider putting these mcords in it for fast retMeval and reduction of clerical labor.
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Audits i
There is a need for a positive corrective action system with ineaningful casuuttments to scheduled dates of completion.
Unless the audit program is revised to involve management in reviewing corrective action slippage.
little improvement can be expected.
It is reconnended that corrective action dates be consitted to and published at the same time as the audit reports with successively higher mandatory management review with each slippage.
It was noted that the site auditors are assigned the task of.
coordinating answers to all external audits such as 84R Houston audits and TUGC0 audits. This measurability reduces the time that is available for auditing at the site.
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Construction Activities l
1.
The method of cylinder storage for. concrete testing by stacking in the " fog" room appears hazardoks as well as possibly being difficult to control as the number of cylinders, increases.
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2.
The only documentation noted at Comanche Peak of witness of mechanical and chemical testing of rebar at the vendors plant in Steelton, Pa., was done in October 1976.
If true, this appears to tie too infrequent a schedule of source inspection to maintain proper control of the supplier's activity.
-7
- 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 procedure writing be revised so that references remain references and are not a specific part of the procedure.
4.
Not all the electrical construction procedures have been written and neither has the QCP for electrical requirements.
Electrical work has already commenced without issue of these procedures. This has resulted in temporary QCI's bging issued without. the QCP document as backup.
5.
The responsibility er NDE is not clearly defined by QAP 9.1.
It appears that control of NDE is listed under 8&R Construction and the verification of performance only is a 8&R Q. A. responsibility.
CP-QCP-3.4. indicates NDE is performed by QC Engineers / Inspectors.
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EXHIBIT 2 HOUSTON AUDIT RESULTS G
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g,3 HOUSTON AUDIT RESULTS SCOPE The Houston audit was conducted during the period of May 9 through May 13, 1977. A pre-audit meeting was held per Attachment A an audit plan developed per Attachment 8 and an exit interview held par Attachment C.
AUDITORS J. P. Jackson, MAC Audit Team Leader W. 8. Williams, MAC Auditor J. T. Wilbur, B&R. Auditor G. A. Tell J. E. Roscoe D. F. Hanlan' J. C. Shuckrow A. H. Geisler
- 5. H. Hobbs AUDIT RESULTS I.
Audit Element: Organization and Quality Program
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Auditor: John P." Jackson' Scope of Audit:
1.
Reviewed Q. A. Manual, Section 1 and 2 and B&R Topical Report.
2.
Coordinated interviews with the following personnel:
Quality Assurance Organization:
T. H. Gamon, Q. A. Manager P. J. Kornoski, Nuclear Q. A. Section Manager l
P. Bulten, Fossil Q. A. Section Manager i
G. Bulcken Q. A. Audit Section'Menager i
l J. P. Clarke, Q. A. Specialist Section Manager l
R. A.. Romeo, Technical Assistant M. Meyer, Houston Coordinator, STP D. Norton, Houston Coordinator, CP Engineering
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J. Mooney, STP Project Engineer J. Paden, Engineering Q. A.
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Construction L. Ashley, Manager - Construction 1
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. Quality Classification.
Brown & Root 6es a system of quality classi-
~.7 fication based on STP DC 010 Procedure for Codifucation.
Since 10CFR50 Appendix B, Criterion 2 Quality Assurance Program requires a system of 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.
II. Audit Element: Design Control and Document Control.
Auditors:
A. H. Geisler, J. C. Shuckrow, S. H. Hobbs Scopo of Audit: Reviewed Topical Report B+R002A, Revision 1. June 1976 Sect ons 17.3,17,6 STP PSAR Sections 17.1.38 and 17.1.68, B+R Quality Assurance Manual, Sections 3.0 and 6.0 and STP Quality Assurance Program, Sections 5.3 and 5.6.
Audit Deficiencies:
Engineering bepartment is responsible for the official Q. A. records l.
of purchasing orders and change notices.
These files are not being main-tained current.
New documents have not been filed for the past six weeks.-
No apparent control system is being implemented for signout of documents from these files.
Responsibility within Engineering Department for main-
.r.
taining these files has not been clearly defined.
.y," t 2.
At present, no documented systius exists whereby the field can be assured that they are proceeding based on the latest design documents and changes.
Examples:
a.
Engineering CRT system is currently inputing based on a 6-8 week backlog.
b.
Bi-monthly document ' status lists are prepared from CRT system records; thus, they are not current.
v c.
SDR's are not inputed into the CRT system.
l
'd.
FREA's are not consistently inputed into the CRT system.
e.
Control Data Cards are not accurately being maintained.
3.
Changes to vendor specifications are not being transmitted to and acknowledged by the supplier and/or incorporated into the purchase order., Examples:
a.
No documented evidence that American Bridge was transmitted Rev. 0/DCN/12-1-76; Rev. 0/DCN/l-14-77; Rev. D/DCN/2-7-77:
Rev. E/DCN/3-2-77; and Rev. F/DCN/4-29-77 to Spec. 3A010SS012.
b.
No documented evidence that Ameron is aware of the requirements I:_Q) of three DCN's and four FREA's which substantially changed Attachment C to Speo. 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 shall maintain the files such that a document or its equivalent copy can be produced upon request". The EDCC files are not current or complete.
Examples:
ST-BR-AB correspondence file had 15 out of 83 letters miss'ing.
a.
b.
ST-AB-BR correspondence file had 52 out of 97 letters missing.
c.
ST-AB-8R and ST-8R-AB correspondence files were only current i
through 3/22/77 on day of audit (,5/11/771 d.
2YO6055033C/DCN/9-13-76 and DCN/10-13-76 not available in EDCC.
The EDCC files should be audited for completeness and, where necessary, updated. Duplicate copies should be maintained within EDCC while docu-monts are being microfilmed.
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 permit changes / deviations without generating the necessary DCM's.
Engineering procedure STP-DC-023 should be changed.
to specify that the FREA form is only a vehicle to request a change /
deviation (not an approval mechanism).
Fomal approval release should only be provided by a DCN to the drawing or speciffi:ation.
6.
FREA's are not receiving proper review and approval.
Examples:
a.
FREA 0-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 appmval 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 specifications.
The SDR systen is being abused to pemit changes / deviations without generating the necessary change notices and/or DCN's.
Engineering procedure STP-DC-024 should be changed to specify that the SDR form is only a vehicle to request a change / deviation (not an approval mechanism).
Fomal approval release should only be provided by a change notice to the purchase order and/or DCN to the specification.
- 8. Copies of approved SDR's are not being distributed to holders of applicable specifications.
9.
Completed SDR's are not being fi. led with the specification and purchase order.
Completed SDR's are only being filed with the vendor d
correspondence file.
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- 10. Revisions are being made to requirements contained within specifica-tions and drawings without receiving proper design veMff' ation.
c Example:
a.
SDR approval does not include design veMfication b.
FREA's 0-C-0103, 0-C-0110, 0-C-0120 ce 3A01055012F/DCN/4-29-77 d.' 2YO6055033C/DCN/3-14-77 11.
Engineering Procedure STP-PM-005-0 Interface Control, had an effectivity expiration date of March 13,1977. This procedure needs to be.
revised to become effective for the remainder of the project.
12.
EngineeHng Procedure STP-0C-011-A, Document Distribution, has been issued for " Interim Use" since July 1974. The distribution lists provided in Figures 1 through 4 are extremely obsolete based on the
)
present organizations.
This procedure needs major revisions to update e j
and simplify the STP document distribution program.
- 13. The means of identifying certain documents are released by authorized personnel was not observed in any effective document.
This
{
was observed for foreign documents issued to Construction and field b,'.3)
generated sketches. Engineering Procedure STP-DC-004-C defines means for handling alternate methods of processing foreign documents, however, objective evidence was not available in EDCC as described.
14.
The specific method for maintaining. the stattis of all design docu-ments (and changes thereto) and connunicating the current design j
configuration is not defined in any effective document.
It is recommended that the specific method or system be established, documented and maintained to identify the current approved design configuration and connunicate this vital information to all concerned -- construction, inspectors, vendor surveillance personnel, purchasing, vendors, etc.
III. Audit Elementr Procurement Control Auditors:
Donald F. Hanlen, James T. Wilbur Scond of Audit: Review of the procurement document control system as set forttt in the audit plan.
Deficiencies:
1.
The Vendor Surveillance Specialist (VSS) is required to make his own check list for inspection frem a general Vendor Surveillance Plan which is not specific enough to assure all regulatory requirements will be sufficiently monitored.
As an example, the Vendor Surveillance Plan for Purchase Order 4019/8019 was found to be unacceptable in identifying T
exactly what characteristics were to be inspected by the VSS.
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2.
There wasino evidence that a plan or requirement existed to keep the t
VSS check list or inspec' tor current with the latest drawing revi,sfons.
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IV. Audit Element:
Indoctrination and Training Auditor: James T. Wilbur Scope of Audit: Review of indoctrination and training procedures and programs as, set forth in the audit plan.
Deficiencies: No deficiencias identified.
Y.
Audit: Dement:
Instructions, Procedores and Drawings.
, Auditors: D 7. Hanlen, J. E, Roscoe ScopeoEAudit: Revtew manuals for proper maintenance, Deficiencies:
4 A review o'f quality Assurance Manuals revealed that 14 of 61 manual holders have not acknowledged receipt of updata transmittals, organi.
zational charts in 5 of 61 manuals are out of date, the list of mar.ual holders is grossly in error and proper matntenance of manuals by manual holders is generally poor,While a program ts currently underway by' Quality Assurance to review maintenance o.f manuals, a controlled index of manual holders and a stronger program of follow up to assure concinu-ing maintenance and update of all tssued manuals is recomended, o
(EM)yr, W4 Audit Element: Nonconforming Material Control Auditor: John P. Jackson,
Scope of Audit: Review of applicable procedures and detamine turnaround time on home office approval of STP nonconfomances.
Deficiencies: It was observed that the average turnaround time for obtain-ing Houston office approval on nonconformances for the first quarter,1977 was 26 days.
It is noted that 79% of the nonconformances exceeded the site specified need date by an average of 35 days.
This is cited as a deficiency inasmuch as promot resolution of nonconfaming items is of paramount importance in maintaining control of defective material at a construction site. As the cceplexities of construction at STP increase, the number of undispositional nonconfomances "in float" awaiting dispost-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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Audit Element: Quality Assurance Records
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Auditors: Wesley B. Williams, Gerry A. Tell, Scope of Audit: Review of the' quality records system and documen.t control as outlined in the audit plan.
Deficiencies:
- 1. There has been no monthly review of the Q. A. records system as specified in ST-Quality Assurance Prpcodure 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 nc attendant was in the area to prevent. unauthorized personnel free access to the storage area.
This was noted particularly during the noon lunch time, VIII. Audit Element: Audits Auditor: Wesley 8. Williams, Gerry A. Tell i
Scope of Audit: Reviewed procedures set forth in the audit _
Reviewed all audits accomplished during the past 12 months, plan 2.
' Deficiencies:
gkb 1.
Q. A. is not using the established audit schedule.
While there is
- a. plan to revise the fonnat and method of audit scheduling, nothi has been formally issued to correct this finding from the previou.ngs audit.
l 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 (AOR) to be satisfactorily closed out. While there is no documented time limit on how long an ADR may remain o between 6 months and one year. pen, some of these ADR's have been ope is definitely a violation of 10CFRSO Appendix 8 requirements.
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ATTACHMENT C MINUTES OF THE POST-AUDIT MEETING COMANCHE PEAK MAY 20, 1977 ATTENDEES
~
P. L. Bussolini - 8&R - Project Q. A. Mana'ger
. J. C. Shuckrow - 8&R - Q. A. Engineer
- 8. C. Scott - BAR-- Q. A. Supervisor J. E. Roscoe - 8&R - Construction Houston T. H..Ganon - BAR - Houston Q. A. Manager J. Dodd - B&R - Project Manager G. W. Bulchen - 8&R - Q. A. - Audit Section Manager W. E. Childress - B&R - Chief Project Engineer W. 8. Williams - MAC - Auditor G. A. Tell - B&R - Project Systems Coordinator E. P. Kotowski - B&R - Purchasing Supervisor R. O. Taylor - BAR - DCC Systems Coordinator L. Ashley - B&R - Nuclear Construction Manager J. Jackson - MAC - Team Leader DISCUSSION i
The meeting was opened at.11:00 a.m. by John P. Jackson, Audit Team' Leader of Management Ana,1ysis Company.
Each team member discussed his assigned areas and the findings and pertinent concerns and recommendation as pre '
sented in the attached audit report.
Discussion during the presentation was encouraged and the meeting was adjourned at 12:30 p.m.
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MINUTES OF PRE-AUDIT MEETING HOUSTON, TEXAS MAY 9. 1977
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ATTENDEES S. A. Bulcken - Audit Section Manager N. E. Erickson - Operations Manager T. H. Gamon - Manager, Quality Assurance * - Part t me W. Green - STP Purchasing Manager J. P. Jackson - fMC Team Leader W. 8. Williams - MAC - Audit Team J. E. Roscoe - B&R G. A. Tell - B&R J. Wilbur - B&R J. Shuckrow - B&R
- 5. Hobbs - B&R A. Geisler - B&R D. Hanlen - B&R DISCUSSION Mr. 6. A. Sulchen, standing in for Mr. Gamon, introduced John P. Jacksort of Management Anal being a review o~ ysis. Company. He outlined the purpose of the audit as f Brown and Root's adherence to cosmitments in the PSAR as'well as NRC regulations. He explained that the audit team was chartered j
with the responsibility of an in-depth review of Brown and Root's overall Quality Program in the same manner as was carHed out a year ago.
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 pHor to initial entry into any area chosen for audit.
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i ATTACHMENT B r,
Es AUDIT PLAN ~FOR BRWN & ROOT Q. A. MANAGEMENT REVIEW HOUSTON OFFICE PURPOSE 1
To determine' (1) conformance of Brown & Root Q. A. Pro j
procedures to 10CFR50 Appendix 8 and ANSI N 45.2, and'(gram implementing
- 2) compliance of existing practices to released procedures.
ELEMENTS REVIEWED I.
Organization and Quality Program A
Ob.iective Review organization and Quality Program for effectiveness and compliance to the Tcpical. Report and Q. A. Manual.
i B.
Method 1.
Review total organization with T. H. Gamon.
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2.
Interview functional maangers through6ut the audit period.
1
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'3.
Review manuals and procedures for adequacy of program
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Acolicable 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. Desion Control & Document Control A.
Ob.iective Review systems and procedures to assure design verification, changes, interfaces and quality requirements have been addressed.
8.
Method i
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1.
Verify comformance to design change control system.'
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2.
Verify foreign document control.
3.
Review interface control and design verification.
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C.
Acolicable Procedures
- 1. Ingineering Procedures listed below:
a..
STP-0C-001-0 Prepa' ration and Ibntrol of Project Procedures i
b.
STP-0C-002-6, Drawing Control c.
STP-0C-004-C Foreign Document Processing d.
STP-0C-005-4, Preparation and Control of Specifications e.
STP-0C-009-E, Filing and File Storage f.
STP-DC-011-A, Document Distribution g.
STP-DC-013-8, Document Change Notice Control h.
STP-DC-015-C, Design Verification 1.
STP-DC-023-0, Field Requests for Engineering Action i
j.. STP-0C-024-C, Supplier Deviation Requests k.
STP-PM-005-0. Interface Control i
1.
STP-GR-003-8, Design Quality Program 2.
Construction Procedures listed below a.
STP DCP-1, Rev. 3. DCC's General Procedures 1~
'h 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, Rev.1 Central File System I
g.
STP GCP-21, Rev. 2. Field Requests for Engineering Actions III.
Procurement Control J ' ?J.."
A.
Ob.iective Review the system of procurement document control for supplier furnished meterials to assure effective connunication of design changes and qualit;y requirements.
8.
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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Applicable Procedures 1.
B&R Q. A. Manual, Revision 3/8/77.
2.
BAR Quality Surveillance Procedure Manual, January 1977.
3.
STP-AD-003-D, Preparation of Inquiry Package.
4.
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IV.
Indoctrination and Training A.
Otdoctive Review the adequacy of the total training program including qualification and training records of personnel perfonning tasks in various craft's as well as auditor qualifications.
t B.
Method i
1.
Interview training supervisory personnel.
2.
Review Q. A. Manual and Q. A. Personnel Training Manual.
t 3.
Review personnel training files for qualifications of,.
)
personnel and accuracy of infonnation.
C.
Apolicable Procedures i
1.
BAR Q. A. Manual, Section 2.0, issued October 1976.
i 2
2.
B&R Q. A. Personnel Training Manual, Parts I & II, issued July 1976.
3.
STP-PM,006-B Personnel Training, issued April.1977.
i V.
Quality Records A.
Chiective To verify compliance of the BAR procedures with ANSI N45.2.9 as l
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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i C..Acolicable Procedures N
1.
Quality Assurance Procedure ST-QAP Section 6.1 rev. January 1977.
2.
Quality Assurance Procedure CP-QAP Section 17.1 VI. Audits
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A.
Oldective Review the 84R audit prograur 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.
Reviet all audits from previous year.
3.
Verify qualifications of all auditors.
4.
Review effectiveness and timeliness of corrective actions.
su.
C.
Acolicable Procedures -
1.
8&R-Q. A. Manual, section 2.5, revised September 1975.
c.
2.
Quality Assurance Procedure ST-QAP section 7.1 revised Septastier 1975.
3.
Quality Assurance Procedure (P-QAP section 18.1 revised July 1975.
4.
Quality Assurance Procedure CP-qAP section 5,18 revised July 1975.
5.
Quality Assurance Procedure ST-QAP section 5.18 revised Sep,tember 1975.
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ATTACHMENT C MINUTES OF POST-AUDIT MEETING HOUSTON M
11:30 a.m., May 13,1977 AT11NDEES T. H. Gamon - Manager Quality Assurance G. W. Bulcken - Audit Section Manager J. T. Mooney D. J. Oliver R. W. poverley W. T. Green N.
Erickson Audit Team
.i 1
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.
I Each team then presented. an overview of their findings and discussed the
- backup information supporting their report.
//b).
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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