ML20236E720

Forwards 780526 & 0609 Memorandums & Audit Repts Prepared by Mgt Analysis Co (Mac) & Affidavits of JB George,Jt Merritt & Eg Gibson.Related Correspondence

ML20236E720
Person / Time
Site:	Comanche Peak
Issue date:	07/23/1987
From:	Wooldridge R TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC), WORSHAM, FORSYTHE, SAMPELS & WOOLRIDGE (FORMERLY
To:	Bloch P, Jordan W, Mccollom K Atomic Safety and Licensing Board Panel
Shared Package
ML20236E723	List: ML20236E720 ML20236E741 ML20236E750 ML20236E755
References
CON-#387-4118 OL, NUDOCS 8708030061
Download: ML20236E720 (61)

Text

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N ttEtA1ED CORRESGNPMS i

WOnSnAM, FORSYTHE, S AMPE.tS Sc WOOLDRIDGE I'

TMIRTV T*C MUNDREO,2001 BRVAN TOWER

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DALLAS, TEXAS 75201 8 - e C B E aT A wCotoniOGE NCIL 0 ANDE RSON

,87 JUL 27 P3 :31 l

..E NC ER C RE LvE A kON AL D M MANSON TCLCPMONE (264)979 3000 Or COUN3EL J DAN SOMahNAN JO S tRICN vv0 RSH A M TRAvi5 E VANC4RPOOL EARL A. FOR$vtH C JUDITM M JOMhSON

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r T E LECO Pi E R (214) 8 0 0 0 011 DAva D C, LON ERGAN AS F L LLARD ROBEntn, wise TIMO1 H V A. M*CIL ROBERT M FILLMORE i

WM ETE* MEN BOYD MARM R WASEM CHRISTOB es[R R. MILTE NBE RGER ROBERT P OUVER l

MAR A $CMWAR TZ j

PLCHARD G. MOORE I

NANCYE L. BETHUREM July 23,1987 cECEuA s. BRuNER JOE A. DAVtS ERIC M PETE R SON WA) TER w WHITE Peter B. Bloch, Esquire Dr. Kenneth A. McCollom Chairman Administrative Judge Atomic Safety and Licensing Board 1107 West Knapp U.S. Nuclear Regulatory Commission Stillwater, Oklahoma 74075 Washington, D.C. 20555 Dr. Walter U 7ordan Elizabeth B. Johnson

?

Administrate, e Judge Oak Ridge National Laboratory 881 West Outer Drive P. O. Box X, Building 3500 Oak Ridge, Tennessee 37830 Oak Ridge, Tennessee 37830 Re: Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, i

Units 1 & 2); Docket Nos. 50-445 and 50-446 b

Dear Administrative Judges:

Enclosed is a copy of (1) an Office Memorandum dated May 26,1978 and entitled, " Comanche Peak Steaib Electric Station 1981-83 2300 Megawatt Instal-lation TUGCO Audit Report,"' together with the attached report prepared by Management Analysis Company,(2) an Office Memorandum dated June 9,1978 and entitled, " Comanche Peak Steam Electric Station 1981-83 2300 MW Installation MAC QA Audit Report of May 1 thru 12,1978," and (3) an Office Memorandum I

dated September 18, 1978 and entitled: " Comanche Peak Steam Electric Station 1981-83 2300 MW Installation Storage of S. S. Components at C.P."

These documents were recently found in the course of continuing document reviews of Comanche Peak files, We have brought these documents to the attention of those persons named in the correspondence who are either stillin the employ of TU Electric or working for others at Comanche Peak to determine if they remembered them or if it refreshed their recollection concerning matters relating to the MAC Report. 'Iheir supple-mental affidavits, reflecting their responses, are also enclosed.

$09CX0500o445 61 070723 G

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l Administrative Judges July 23,1987 Page Two TU Electric is continuing its document reviews and will report promptly on any other documents relating to the MAC Report if and when found.

Respect y submitted,

/

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Robert A. Wooldridge RAW /klw 1

Enclosures cc:

Service List f

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TEX AS I:TILITilb SKIO'ICly INC.

g O r r t C E M E M O R A tJ D U M r..

Henry O. Kirkland.

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n.,s,. r..uis -. June 9, 1978 l

sia,jeci COMANCHE PEAK STEAM ELECTRIC STATION 1981-83 2300 MW INSTALLATION MAC QA AL'01T REPORT 0F MAY l thru 12, 1978 With reference to the following Items of the above captioned MAC QA Audit, (Refer te the attached report - paper clipped Items).

A.

Item # IX - SPECIAL PROCESSES - RADIOGRAPHY Need a study on X-Ray vs. Iriduim B.

Item # XIV - HANDLING, STORAGE AND SHIPPING Need a study on Stainless Steel Storage Henry, 1 met with L. F. Fikar on June 8, 1978 and we discussed the above.

Mr. Fikar is to return on Monday, June 12, 1978 for an additional budget discussion. We need to brief him on the status of these Items at this time.

. hW /... /J de - B.

eorge,

' Proje General Manager JBG:skm I -_____--a-----,-__-

~ i l l i l APPENDIX A l TEXAS UTILITIES GENERATING COMPANY l AUDIT REPORT I l 1 ? I DO NOT REPRODUCE /

• (A4 f

Fed ry 0. ' Ki rYland, 7 I Project General Manager I 1 MANAGEMENT ANALYSIS COMPANY l

AUDIT REPORT

Subject:

Audit of Texas Utilities Generating Company, Dallas Of fices and Comanche Peak Stecm Electric Station Construction Site j Date of Audit: May 1-12,1978 Audit Scope: A management audit was conducted of the Quality Assurance Program of Texas Utilities Generating Company during the weeks of May i and May 8,1978. The purpose of the audit was to determine tne adequacy of the Quality Assurance Program as related to Nuclear Regulatory Commission require-ments and the ef festiveness of implementation to meet program requirements and authority delegations. Activities were audited at both the 10GC0 offices in Dallas and at the Comanche Peak construction site. Activities of the Architect / Engineer and Constructor were audited only at the construction site. The scope of the audit included comitments made in the PSAR, the Corporate Quality Assurance Manual, the Comanche Peak Quality Assurance Plan, the Project Proce. ares Manual and the Brown & Root Quality Assurance Manuals and Procedures related to the Comanche Peak site. Auditors: Dallas office, May 1-3, 1978 J. P. Jackson, MAC Audit Team Leader i J. M. t; orris, MAC Auditor i I Comanche Peak Construction Site, May 4 & S, May 8-12,1978 J. P. Jackson, MAC Audit Team Leader j J. M. Norris, MAC Auditor J. A. Hendron, MAC Auditor (May 8-12 only) l Perscanel NAME COMPAN( TITLE 1 0 D. N. Chapman TUGC0 QA Manager, *-1-2 rv e ed ~ TUGC0 Mgr, Site Surveillance, *-1-2 R. G. Tolson~ R. V. Fleck TUGC0/G&H Civ. Inspec. Supv.,

• -1 J. V. Hawkins TUGC0/G&H Prod. Assurance (QA), *-1 I

fri86 i

l TUGC0 AUDIT REPURI Personnel NAMF COMPANY TITLE i 'U "# ""C t2 v c ie 1: J. T. Me r ri t TtJSI Resident Manager, *-1 E. G. Gibson TUSI Project Engineer, *-1-2 B. J. Murray TUSI Engineering Supv., *-1 J. J. Moorhead G&H Resident Engineer, *-1-2 i B. C. Scott B&R Site QA Manager, *.1 J. P. Clarke B&R Site QC Manager, *-1 R. Mann B&R QA Records Coordir,ator,

• H. O. Kirkland B&R Proj General Mgr, *-1 U. D. Douglas B&R Project Manager, *-1 D. C. Frankum B&R Asst. Project Mgr.,
• -1 P. Foscolo B&R Proj. Chief Engineer,
• -1 L. Hancock B&R flat'l Procurement, Con-struction Branch, *-1 A. Boren TUGC0 Vendor Compliance,
• A. Vega TUGC0 QA Central Staff Function,
• 1-C. Beggs TUGC0 Systems Compliance, *-1-2 R. Gary TUGC0 V.P., Opera tions, *-1 L. Fiker TUSl V.P., Design & Procurement,
• 1 P. Bri ttain TUGCO/TUSI President, 1 1

l Interview l 1 Pre-audit meeting 2 Post audit neeting Audi t Method: The audit was conducted through a series of interviews with responsible management and supervision and examination of Quality Assurance manuals, procedures, records and work operations bcth at the Dallas headquarters of Texas Utilities I l Generating Company ar,d Texas Utilities Services, Incorporated I and at the Comanche Peak construction site. I l i Summary: The audit disclosed that recent changes in authority dele-j gations had been generally well accepted and that morale l r-l LIM e

( TUCCO AUDIT REPORT Summary (Cont' d): and team spirit were good. However, the changes had not yet been formalized in revisions to the PSAR and the j Comanche Peak Quality Assurance Plan. The audit also disclosed that present practices in the control uf design changes and of certain nonconformances do not provide the requisite level of review by the original designer. In other instances it was evident that design changes were being used in lieu of nonconformance reports. Except for the areas noted herein and below, there was generally good adherence to existing procedures, 1 1 Findings: 1. The currert activities of TUGC0 Quality Assurance per-sonnel are not consistent with the authority delegations to Brown & Root and to Gibbs & Hill as defined in the PSAR and Comanche Peak Quality Assurance Plan. Similarly, the Quality Assurance Plan and Procedures are not consistent with current and planned revisions in authority delegations to the Architect / Engineer and the Constructor, and is not complete in addressing all eighteen criteria of 10CFR50 Appendix B. The lack of a well identified plan of reorganization and responsibility I causes uncertainty in carrying out some activities. There needs to be a plan for revising the Quality Assur-ance Program; such a plan should include the establishment of an architecture of procedures to show how other TUSI/ TUGC0 and contractor manuals inter-relate with the Quality 1 Assurance Manual. The TUGC0 QA Manager should establish l a schedule and assign responsibilities for completion of the necessary procedures. The schedule should be supple-mented with a management effort to monitor adherence to the plan and achievement of the schedule. J l l 2. The current site DC DDA system of after the fact coordi-nation of design changes with the original designer j fliUC 1

1 l 2 I 10GC0 AUDIT RCPORT j l l findings: provides a significant risk of design error and does (Cont'd) not neet the requirements of 10CfR50 Appendix B, nor I l of ANSI N45.2.ll, " Quality Assurance Requirements for l the Design of Nuclear Power Plants". \\ l l i A system for expediting and documenting Gibbs & Hill hone of fice approvals should be established using l telephone, telecopier or telex as a n'eans of speeding cormion ica tion. l l 3. The Comanche Peak Quality Assurance Plan does not provide for o Quality Assurance review of procurement documents and changes thereto prior to purchase order placement, j except for site originated procurement. Such a review l is identified in 10CFR50 Appendix B, Criterion IV and is a requirement of ANSI N45.2.13. It should be required on all safety related procurement. I 4. The current combination of Chapter 17 of the PSAR, the I TUGC0 Lorporate Quality Assurance Manual, the Comanche Peak Quality Assurance Plan, Project Procedures and Brown & Root Manuals and Procedures provides a complex array of procedures which is difficult to maintain current and consistent. 5. The current system of providing inspection instructions or checklists to inspectors is too generic, placing an undue burden on the inspector in attempting to determine applicable drawings and specifications and applicable revisions thereto. A review of records of concrete pours incidates that configuration reflecting the as-poured condition is not clearly def1ned. Applicable DC DDAs are not noted in inspection documentation. Configuration needs to be clearly identified to inspectors on a current basis, including all applicable k

TUGC0 AUDIT REPORT

• l Findings:

DC DDAs and completed documentation must reflect the l (Cont'd) status of the applicable chan,Jes. j 6. Special processing markings for later in-service inspections are carelessly applied. The circle and l arrow used for such marking is soretimes incomplete and nat recognizable for its intended purpose. In one instance only a portion of the circle resembling the letter "C" was discernible. Failure to properly l mark Utese locators now will cause delay and possible error when in-service inspections are made in highly l irradiated areas. 1 7. Disposition of nonconforming items does not always achieve the requisite review by appropriately qualified design personnel. A procedure, limited to defects in concrete, was recently issued which bypasses the estab-lished nonconformance control system and, thus, violates regulatory requirements in this regard. In other instances, the DC DDA program has been used to bypass the nonconformance reporting syster. The n>ncoaformance control system should.be the means for maintaining in-spector integrity, identifying problem areas and provide a driving force for their correction. 8. The records storage facility does not currently have any means of internal fire protection during hours it is unmanned, although it is understood some method is planned., uality Assurance records, sucn as personnel Q qualifications, are not maintained in the Records Center, but are maintained in fireproof file cabine's in a trail 2r under the cognizance of Brown & Root training coordinator. 9, Approximately twenty-four percent of Central Staff audits have not been conducted as scheduled. Combining Central Staff audits, site audits and site surveillance activities

1 Tl1GC0 AUDIT REPORT Findings: by TUGC0 and by Brown & Root into a single, cohesive (Cont'd) program would provide improved visibility to the overall audit and surveillance ef fort and permit evaluation and ajustment to the audit schedule to attainable and yet effective frequencies. I i i i t i 1 ) Inac

1 1 \\ l l 1 l l l { l I APPENDIX B i I TEXAS UTILITIES GENERATING COMPANY OBSERVATIONS AND RECOMMENDATIONS 1 1 1 B0 NOT REPRODUCE j ff /2

• (A A

~- 41anry 0.' Iirk and, Project General Manager i l 1 1 MANAGEMENT ANALYSIS COMPANY i I

I 1 TUGC0 AUDIT OBSERVATIONS AND RECOMMENDAT10fK l l 1. ORGANIZATION, A. General l TUGC0 Quality Assurance has undergone considerable reorganization in the i past year. The general thrust of this ef fort has been the assumption of greater direct involvement in the management and supervision of the Comanche Peak Quality Assurance Program. It is to be noted that important shifts in responsibility were being made at the time of fMC's review. l t I As a part of this assessment, MAC evaluated the reactions of key managers, supervisors and inspectors to the overall changes that have taken place to date. It was generally observed that those interviewed thought that with few exceptions the changes were for the better. There appeared to be a team l effort on the part of QA and Construction with excellent TUSI executive l rnanagement and project management support of the QA program. There was no noticeable problem with organizational prejudice brought about by the organizational intenaixing of TUS1, Brown & Root or Gibbs & Hill work forces and supervision. B. Organization During the course of the audit MAC discussed the value of a revised organizational structure with the TUGC0 Quality Assurance Manager and the Manager, Site Surveillance. It is recommended that TUGC0 adopt an organizational realignment of activities as set forth in Exhibi! 1, whereby Quality Engineering and inspection report to the Site QA Supervisor as. two separate sub-organizational entities with responsibilities as defined in Exhibit 1. Such an organization will better supplement the existing Construction organization and will penwit better organization for handling day-to-day site problems as well as implementing recommendations of this report. This is particularly so in the area of inspection planning. hxx:

l l l 1UGC0 OBSLRVATl0NS & RI.COM& TWAT 10 0 ! l l f C. Quality Surveillance Coimittee j All minutes of meetings of the QSC since its inception were reviewed. l It is noted that the QSC was established as a mechanism for providing top TUGC0 management with a periodic upriale on such mat ters as " schedules I l and milestones" or " audits and corrective actions" l 1 It was noted that recent meetings dealt with tracking on the status of l action items as set forth in the Outstanding Surevillance Report items or the Quality Assurance Items of Concern Repnrt. In such instances it 1 appeared the Quality Surveillance Committee was taking on the role of a task force or problem solving group. The problem that exists if the QSC assumes such a role is that problems would tend to await the three month I meeting cycle before the necessary management attention is effected. It is recommended that TUGC0 re-evaluate the charter of the QSC and serious consideration given as to its value to the project recognizing that: 1. All action to resolve problems should be handled on a day-to-day basis through the functioning organization, anc r 2. The primary objective of maintaining management awareness of Quality Assurance status might be accomplished more efficiently, effectively l j and on a more timely basis through a monthly Quality Assurance progress report distributed to the TUGC0/TUSI executives. I D. guplification of Personnel l MAC reviewed the qualifications of all TUGC0/TUSI and Gibbs & Hill l Quality Assurance personnel and many of the Brown & Root personnel. It was observed that most of the TUGC0/TUSl Quality Assurance personnel have gained their Quality Assurance experience through Comanche Peak activities only. Although the project has provided valuable experience, it is rec ~ ormended that any future assignments in Quality Assurance be filled with quality engineers hired from outside the company with broad nuclear ex-perience, pre ferably in construction. Such experience added to the existing staff will serve TUGCO/TUSI well in accomplishing the important Inac

TUGC0 ODSERVATlot45 & RECOMtINDATIONS piping, electrical and startup activities ahead. fMC had occasion throughout the audit to assess the qualifications and experience of 20-30 inspectors throughout the construction site. These j observations are worth mentioning: l 1 1. The inspectors are generally young and inexperienced with many having as little as six months experience in inspection. I I 2. There was an obvious need for more seasoned inspectors to work with the novice inspectors on a day to-day basis. l 3. Too much responsibility is placed on the inspectors with respect to preparation of inspection planning, resolution of site problems and j determination of the design configuration base for performance of j inspections. i II, QUALITY ASSURANCE PROGRAM The Quality Assurance Program is defined in three basic documents: I The Corporate Quality Assurance Manual Chap *er 17 of the PSAR l The Comanche Peak Quality Assurance Pian I These documents are not in total agreement with one another. Since there is no other nuclear plant currently planned and since the authority dele-gaticns identified in the Corporate Manual are not in consonance with practices on Comanche Peak, TUGC0 should consider discontinuance of the Corporate Manual unless there are other projects to which it is to be applied. If a Corporate Manual is required at a later date, a new one could be prepared based on Comanche Peak experience and the requirements of any new projects to which it would be applied. The Comanche Peak Quality Xssu'rance Plan addresses only the following criteria of the eighteen identified in 10CFR50 Appendix B.

j \\ l l j TUGC0 OBSERVAT10llS & RECOMMalDATI0fl5 l l Organization Design Control l Procurement Administration I l Inspection l I flonconformance Control Document Control Records Audits ) With the expanded responsibilities of the TUGC0 Quality Assurance Depart-ment, the plan needs to be expanded to address all eighteen criteria to reflect the creation and functions of the Procurement Department and to be consistent with the authority delegations and functions still resting with Gibbs & Hill and with Brown & Root. 1 There needs to be a plan for procedural identification and development i and a schedule and assigned responsibilities for their completion, including i a complete architecture of Quality Assurance procedures, project procedures j and interfacing procedures of the Architect / Engineer and Constructor. The ] effort should be to minimize the number of procedures required and to f eliminate duplicating or overlapping' procedures through consolidation of detail and joint approvals of the organizations involved. It is recommended that the Quality Assurance Manager use his organization as the driving force to achieve required procedural coverage on schedule. It was noted that TUGC0 is planning on obtaining its own Code manual. The stated reason for this was the fear that Brown & Root would not achieve Code accertance. The auditors feel that the Brown & Root manual would be acceptable to the Code Survey Team and that its weld practices as exempli-fied in the Weld Shop are very acceptable. The auditors are of the opinion that obtaining a Code Stamp will be dif ficult where all the work of implementing the program is performed by others. y 111. DESIGtt C0tlTROL The present system of expediting field changes by referring design changes to the original design organization fcr approval af ter the fact does not

1 l l l TUGC0 OBSERVA110NS & RECOMMENDAT10ll5 l 1 l l meet the intent of 10CFR50 Appendix B nor of ANSI f145.2.ll, which require l that field changes be subject to design controls commensurate with those 1 exercised on the original design. TUGC0 audits have already disclosed l that the Architect / Engineer has not been reviewing field originated changes i on a concurrent basis, thus the design engineer's coninents may be received af ter the specific construction work is complete resulting in possible loss of design integrity, undue pressure on the designer to justify what has been done, loss of designer responsibility or possible extensive repairs. It is reconnnended that a system for expediting review and approval by the original designer be established on all safety related changes using telephone, telecopier or telex as necessary to coordinate and document change approvals. IV. PROCUREMENT DOCUMENT CONTROL l Except for site procurement, the Comanche Peak Quality Assurance Plan does not provide for a review of procurement documents and their changes prior to placing a purchase order. This is contrary to requirements of 10CFR50 Appendix B, Criterion IV and ANSI N45.2.13, " Quality Assurance Requi rements for Control of Procurement..... ". There is a review of pro-curement documents by Quality Assurance during Design Review, but is was ascertained that this was a review of the drawings and specifications and not the purchase order or contract. Procurement document review by Quality Assurance should assure that all necessary requirements for access to the supplier's facilities are provided and that necessary controls and documentation have been specified and that the appropriate configuration has been defined. The review should l also assure that requirements imposed are appropriate to the procurement and that there are no excessive requirements for quality program develop-ment or for the delivery of unnecessary documentation. Some of the pro-curenent packages reviewed appeared to have both blanket requirements fcir l Quality Assurance programs and excessive requirements for documentation.

1 TUGC0 OBSERVATI0flS & RECOMMLilMT10fts V. IflSTRUCT10fl5 A. Inspection Planning The current system of providing inspection instructions or checklists to the inspectors is too generic in nature. In the case of concrete inspection planning the inspector fills out a simple pour card with an attached { Concrete Placement Checklist, a Reinforcing Steel, Electrical, Mechanical ) and Embedded item Placement Checklist and a Stainless Steel Liner Checklist, l l the combination of which: 1 1. Provides no information with respect to unique, embedments or j 1 penetrations to be incorporated in the pour. l l l 2. Places an undue burden on the inspector in attempti.ng to determine applicable drawings, specifications, applicable revisions and applicable DC DDA's. Much of this input should be provided by clerical support under the direction and subsequent approval of l a quality engineer. I Inspectors estimated that 45-70" of their time is spent on docu-l mentation ratber than physical inspection activity. Well thought out planning could do much to alleviate this situation. Traceability - M P r/ e.. It was observed that Comanche Peak has established a program of unnecessary material traceability which, based on one estimate, consumes l at least a three-man level of effort and perhaps as high as a six man level of effort if one considers all the support functions required to ( implement the progran. All anchor bolts and B series cadwelds are fully traceable to heat numbers such that through an elaborate and extensive system of mapping all installations, the capability exists of identifying each embedded anchor bolt, B series cadwelds and other standard embeds to its heat number. There exists no such flRC or industry requirement fcr this ' degree of traceability, it is inter-esting to note that rebar does not require traceability on Comanche Peak (and shouldn't), MAC knows of no other project that imposes this require-QC

TUGC0 OBSERVATIONS & RLC0t1MLNDAT!ONS - ment and could not identify a Comanche peak specification or procedure requiring it. Accordingly, it is recommended that this practice be dropped innediately. Such a move would enhance inspector morale as those involved are aware that the practice serves no useful purpose. C. Procedure Simplification Newly established procedural systems are such that Construction and Quality Assurance issue procedures on similar subject matter jointly, for example, the recently issued procedure on shop travelers was jointly prepared by Construction and Quality Assurance. It is recom-mended that important procedures such as those related to concrete be revised and issued as a single procedure approved by Construction and Quality Assurance. Similarly, tnose procedures related to piping and electrical should be revised and jointly issued as a single Comanche 1 Peak procedure. D. Procedures Independent of Houston The present system of obtaining Brown & Root, Houston office approval on construction procedures should be modified. Guidelines should be worked out with the Houston office whereby they approve ' nly top level o l procedures, permitting the site full flexibility in revising detailed site procedures. Perhaps the Brown & Root, Houston office could retain approval authority on those top level documents that establish Brown & i Root policy, control the necessary type of forms, etc.

However, j

l detailed operating procedures should be changed with site approval only. Perhaps the Houston of fice would agree to a retroactive review procedure, j ( l .E. Configuration Control l l A review of records for completed concrete pours indicates that the I configuration reflecting the as-poured condition is not properly defined. It was noted that the inspectors record the particular drawin6 l i \\ number and revision letter! however, all applicable DC DDAs are not noted anywhere in the inspection supporting documentation.

TUGC0 OBSERVATIONS A RECOMMENDATIONS ! l F. Preplanning of Construction Work In discussions with construction management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for a detaih a ater:d takeoff on all Gibbs & Hill drawings which provides detailed instructions to the craf ts as to the civil, mechanical and electrical items to be included in each segment j of work. This formalized approach of taking material takeoffs in the office and providing this information to the field forces on an approved material takeoff list will do much to improve the quality of the work. Since the material takeof f is a formal process accomplished by cons truction engineers well in cdvance of the work, it provides a significant measure of preplanning, including the processing of necessary design changes to accomplish the work. Such an effort will do much to minimize field errors with respect to left out embedments or inability to complete work as a result of design errors. It is recommended, however that this effort be formalized into a Comanche Peak site procedure. As such, it will be recognized as part of the system and will do much to assure that Gibbs & Hill drawings are forwarded to the site on a timely basis to accomplish this preplanning effort. VI. DOCUMENT CONTROL While there appeared to be some problems with bringing the Automatic l Records Management System on line, the manual system backing it up appeared to be functioning satisfactorily. The auditors found no ] 1 l deficiencies in document control. I Vll. CONTROL Of PURCHASED MATERI AL, EQUIPMENT AND SERVICES The Quality Assurance Plan is not up to date in regard to TUGCO's i 1 l responsibilities for procurement, source evaluation and source sur-j veillance. TUGC0 has developed a program for rating supplier perform-ance' and shows evidence of actions when reatings are unsatisfa-tory. l The list of suppliers requiring evaluation and source surveillance is not kept up to date by the Architect / Engineer. The list in use is over i i j

TUGC0 OBSERVATIONS & RECOMMENDATIONS i four months old, but is maintained manually by the TUGC0 Supervisor of Supplier Compliance. l There does not appear tn be any method of assuring that the latest con-riguration is supplied to the personnel performing source inspection prior to shipment of procured items. The source inspector appears to be at the mercy of the supplier in determining what changes have been ] identified and incorporated. Thus, it is conceivable that items will be shipped to the site that do riot meet the desired configuration even though requirements of the purchasing document have been met. Such i receipts can cause delays and unwarranted costs in meeting the proper i configuration. It is recommended that a practice be established of identifying and confirming required configuration prior to procurement and prior to shipment of purchased materials and components. l I Vill. IDENTIFICAT10ft AND CONTR9L OF MATERI ALS, PARTS AND COMPOND4TS l ) No deficiency noted. Material reviewed in the warehouse, in open i 1 storage and in the weld shop appeared to be adequately identified. IX. SPECI AL PROCESSES I 1 A. Radiography i Iridium 192 is being used as the radiation source for all radiography at the si te. This isotope has its optimum capability at about 1.5 inch steel and is not recommended by the Code below.75 inches. thickress or It is pennitted for lesser thicknesses when the use of other radiation sources is not practical and when resolution of the outline and 4T hole l size of the penetrometer can be demonstrated. The energy levels of iridium isotopes are higher than optimum for materials.375 inches or thinner, resulting in a flat image and lack of contrast. Becauseexposdre l time relates to distance, Che isotope is normally placed against the pipe opposite the. film. With a.100 inch source size, this causes blurring ) j of the image. Lack of contrast and a blurred image makes it unlikely I bOC l

I TUGC0 OBSEPVA110NS & RECOMtirNDMIONS 1 l that hairline cracts will be seen and difficult to accurately define large indications, lhe use of iridium 192 meets the minimum requirements of the Code, but by not providing optimum identif' cation of observed anomolies it does three undesirable things. First it causes unnecessary removal and repair of indications that can be seen but not properly identified; secondly, it masks narrow cracks, tight li:k of weld pene-tration and non-fusion which can be detrimental to service life; thirdly, l it does not provide an adequate base line for in-service inspections performed af ter the plant has gone into operation. Failure to have clear identification of the original indications at that point can cause delays, the cost of which greatly exceeds the cost of providing better identifi-cation and necessary repair of defects found in the construction phase. Recommendation - It is recommended that TUGC0 require x-ray for shop welds, and consider its use wh"re practical for construction welds. X-ray machines in the range of thirty pounds of weight are available and are nearly as portable as the isotope. Because of its smaller focal spot i rize and variable voltage, x-ray can give superior radiography. The feedback of information to welders can improve the quality of welds and minimize the potential for defects. The ability to discriminate between indications having roundness or sharpness at the ends can eliminate repair. The ability to positively identify in the construction phase those indi-cations which have a potential for growth and failure can permit economical repair without radiation hazards that are inherent if found later in the operating phase. B. Welding ( No causes for concern and no procedural noncompliance were found in review of the weld shop. There seemed to be a general opinion that af ter radiography repairs are being required that are acceptable within the Code. A review of a small quantity of rejected film indicates this. ] generalization may be valid. It was disclosed during the audit that radiographs may be reviewed by as many as five individuals. Such ex-cessive review leads to supercritical evaluation of fiim and to excessive repair. As previously stated, better radiography permits better litaid

TUGC0 OBSERVATIONS & RECOMMI.flDAT10NS identification of conditions acceptable within the Code. Unnecessary repairs increase cost and reduce pipe reliability. Recoranendations - Have radiographs which have been rejected for defects reviewed by TUGC0 Level III radiographer. If a reasonable statistical sample shows that excessive repair of welds has been required, establish the policy that Code acceptable indications shall remain untouched, but shall be recorded on the reports. As'an economy, consider reducing the number of persons performing sequential review of radiographs. C. HDL Qualifications The site NDE Level Ill situation is unclear. Only Level 11 certification by Brown & Root was available for the NDE Supervisor; however, it is understood that TUGC0 has issued a letter identifying him as Level III. Recommendation - Clarify the authority and responsibility of the NDE supervisor in administering tests and evaluating and certifying per-sonnel. This is very important as related to Code work, since the level Ill will be working under the authority of the holder of the Code stamp. X. INSPECTION l There were no deficiencies noted relative to inspection; however, it was noted that a large number of inspection personnel are receiving their first nuclear construction experience on the Comanche Peak site. As a consequence, it is necessary to improve the quality of inspection planning and to increase the level of supervision and quality engineering support. Inspection planning should identify the required configuration including applicable UC DDAs, the features to be verified, the inspectipn l method and acceptance criteria..in order to minimize possible confusion and error, htac

TUGC0 OBSERVA110NS & RECOMMLilDAT10fl5 XI. TEST C0tlTROL A review was made of the TUGC0 startup administrative procedures, with the following observations. l. The procedures appear to be written around the old organization; that is, in several instances they refer to the Brown & Root QA/QC input required in the preparation of "startup work requests". 2. It was noted that an unique system is being established to handle nonconformances during the startup phase, it is recommended that wherever possible existing schemes utilized in construction be used during the startup process. This is important since most personnel involved in dispositioning such items as nonconformances and design changes will be the same persons involved in construction. XII. C0flTROL OF MEASURiflG & TEST EQUIPMEtlT lt was observed that out of 24 instruments sampled which are utilized in civil, structural, mechanical and electrical work, approximately 50 percent had not been withdrawn from the calibration laboratory since its last calibration date. This is particularly significant when it is recognized that the present system is such that if a calibration date becomes due, the instrument is recalibrates whether or not it has been issued for use. It is recommended that consideration be given to simply changing the calibration date rather than going through a calibration cycle if the tool has not been used. lt was noted that many construction tools are calibrated. It is f important te note that calibration of construction tools is not necessary with respect to 10CFR50 Appendix B. Although calibration l and maintenance is extremely important on construction tools, it may I be that frequencies may be relaxed. X111. lHSPECTION, TEST AND 0PER5TINr> STATUS ~ l No deficiencies were noted in this area. Material and equipment I observed in receiving inspection, in the warehouse and outside storage

TUGC0 OBSERVATIONS & RECOMMENDATIONS area appeared to be adequately identified. No tests were observed. XIV. HANDLING, STORAGE _ AND SHIPPING Exterior storage practices should be reviewed, The pr otective coverings of many items are damaged; some reported on monthly surveillance reports have not been corrected. ' arge temporary structures, such as those over the emergency diesel engines, require wind bracing to prevent further damage. Because of soil chemistry, rain and humidity, the current prac-tice of allowing large stainless steel piping to remain uncovered should be reviewed. Sensitized stainless is extremely sensitive to chloride, fluoride and sulphide contamination which with' water as a couplant can cause intergranular corrosion and premature failure. XV. C0f1 TROL OF NONCONFORMANCES There appears to be an effort to reduce the number of documented non-conformances, l l It was noted that DC DDAs were being utilized for nonconformance reports. Although this was observed on a small percentage of DC DDAs issued during the month of April, it is reconinended that this practice ce stopped immediately. The TUGC0 system is correctly established whereby non-conformances are written after the fact and DC DDAs are reserved for design changes before the fact. It is important that this practice be enforced since DC DDAs prepared after the fact necessitate that workers j be directed verbally to violate the drawing since the deviation will be I handled af ter the fact with DC DDAs. This is a poor Quality Assurance practice. I i Procedure CPQl-AB, Rev. O, dated 5-5-78 was issued for the purpose of providing expedient disposition of co.1 crete discrepancies. The procedure infers that discrepancies of 72 F versus 70 F or 6.2% air content versusf 6.0% maximum is perfectly acceptable when it is signed off by the field engineer. Such a systen shortcuts the established nonconforming material control system as defined in Brown & Root and TUGC0 precedures and should b i.

I 1 1 TUCCO OBSERVATIONS & RECOMMulD/h IONS 1 1 I 1 4 be discontinued. I f Lolerance", are unrea listic such that t he 72"F is acceptable, then the design specification should be changed to so indicate. It is recommended that good inspection planning be provided inspectors, i identifying the characteristics to be inspected, the method of inspection and acceptance criteria and that inspectors identify nonconformances to such criteria. This will maintain the integrity of inspectors and provides j identification of problem areas and provides a means for their cerrection. j It is reasonable to assume that on a project as large as Comanche Peak there will be several thousand nenconformance reports. The number does I 1 not reflect adversely on the quality of construction, but the failure to I identify nonconformances does reflect adversely on the integrity of I inspectors and leaves unknown the quality of the plant, l XVI. CORR _ECTIVE ACTION There were no deficiencies noted relative to corrective action on hard-ware. The Supplier Compliance Supervisor has established a method of tracking vendor performance and sMws positive ;esults from actions taken to correct supplier quality problems. A review of reports of site sur-veillance conducted by TUGC0 showed corrective action responses were being promptly received. A review of reports of survei'llance actions by Brown & Root showed generally adequate response and resolution of corrective action exce: for a period of four months when surveillance personnel were assigned to other tasks. In general, corrective action appears to be adequate and timely on vendor l and site related problems, but some deficiencies identified in audits of major contractors still persist. Sonie of the changes in authority dele-gation to major contractors appears to be action taken to correct inadequate or untimely response by those organizations; however, other actions taken, l such as handling of field changes and nonconformances, appear to be those of circumventing the problem rather than correcting it. } L l hxic

TUGC0 OBSERVATIONS & RECOMMENDATIONS XVil. RECORDS l Except for lack of internal fire protection, the quality records area is considered to be satisfactory. Some Quality Assurance records, such as personnel qualifications, are not stored in the records center but are maintained separau.ly by the Brown & Root training coordinator. There is not currently a catalog or listing of required records although j it is being prepared. A review of a selection of Quality Assurance records showed the documents in them to have been properly completed and in the correct order. Recommendation - The installation of an inert gas fire extinguishing system or the f identification of geographically separate duplicate records should be expedited. TUGC0 should review the fire protection capabilities of storage facilities in the training supervisor's trailer and consider a duplicate set of such records to be maintained in t.ne records center. XVlll. AUDITS There are several audit and surveillance programs in effect. Audits by the Quality Assurance Department Central Staff are performed on site activities, major contractors and suppliers. Site surveillance actions are perfonned under the direction of the TUGC0 QA Site Supervisor. Similar surveillance activities are carried out under the direction of the Brown & Root Site Quality Assurance Manager. While called surveillance actions, the surveillance programs are formally planned and scheduled, utilize checklists to guide the activity and record results, and issue reports of deficiencies and require correction. Except for formal and documented j pre-audit and post-audit meetings, all the elements of an audit program l are in place. It was reported that the reason for calling the activity " surveillance" was to avoid outside auditors finding the program deficient 7 ( Decause it did not include the documented pre-and post-audit meetings, yet the auditors founo that such meetings were conducted, but on an r f infonnal basis. l Recommendation - The auditors consider tne present program to be an i effective tool which could be further improved. TUGC0 should consider f bM i

( I l.. Tl)GC0 OBSERVATIONS & RLCOMMLfl0AT10fl5 1 i combining the audit and surveillance activities into a single, cohesive I effort. Such an integrated effort could cover required areas more f efficiently, without duplication and at a frequency that can be main-tained. Such an audit program should be described in written procedures and include a description of both the formal audit and the continuous audit plan (surveillance) and the method.of conducting pre-and post-audit meetinga should be described to preclude later criticisms by outside organizations. The resulting audit program should be a superior tool for management assessment of program implementation and ef festiveness. i / 's f l =

l ll S S E N D S R/ O R E UE I O R DC T C U Ei A D CA 1 E l R i E f OLSI G C RLTRiY i O PI I TI T R EDCNI P EVUOI L TRADAA I U I RU I SS I TQ . i } l i 0 1 I T L T A I C T B R I Ei I l O FC0 H EI S I C X i t RA E TV EM& I R VR SE O P YFT U Til l l S I0E LCD ANI U0 Qi 4 i t l! G N V' O l l Ei I G RA E l T W LS .CiC i E .PDSr OA i R I T O O A' I V' NHTiTE ECOTSRI V R0I E OSI 0TMYFOT l C TNPC i i G . E. I OSE f E I CPPLCI R SOSSAll DR ERir U0 O l l DPl I Qf C i i

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i TEX AS UTILITIES SElWICES INC. s-O F F I C E M E'M O R A tJ D U M r,, E. G. Gibson, J. T. Merritt, Jr. &. U. D. Dougl_as_ men no. Texas _May. 26,_1978_.. sui,jen _ C OMA N C H E_P E A K_ S T E AM_ E L E C T R I C.. S T AT I.0 N 1931-83 2300 MW INSTALLATION TUGC0 AUDIT REPORT I attach one (1) Xerox copy each of Appendix "A" and Appendix "B" of the TUGC0 Audit Report prepared by Management Analysis Company. The reports are not to be reproduced and only those with a "Need to know" are to see them. We must submit a report to L. F. Fikar in regard to the following two (2) sections: 1. Section IX, Special Processes - Paragraph "A", Radiography. 2. Section XIV, Storage of Stainless Steel Pipe Outdoors Subject to Fluoride, Chloride and Sulphide Contamination. i You are authorized to obtain expert advice should you require outside con-sultation on either of the two (2) sections. l f f l _.i _s 3 3-Hbnry 0. Kirkland, Project General Manager HOK:skm CC: J. B. George J l I

i i i l l APPENDIX A J TEXAS UTil.ITIES CENERATING COMPANY AUDIT REPORT l ( I r l i DO NOT REPRODUCE fu f Fenry O'. TirEland, 'j Project General Manager 5 4 MANAGEMENT ANALYSIS COMPANY

i AUDIT REPORT l

Subject:

Audit of Texas Utilities Generating Company, Dallas Of fices ) 1 and Conanche Peak Steam Electric Station Construction <ite ) Date of Audit: May 1-12,197f, i 1 Audit Scope: A management audit was conducted of the Quality Assurance l l Program of Texas Utilities Generating Company during the l e:eeks of May 1 hnd May 8, 1978. The purpose of tho audit was to determine the adequacy of the Quality Assurance Program as related to Nuciear Regulatory Conossion require-j ments and the ef fective 1ess of impletrentation to meet program requirements and authority delegations. Activities were i audited at both tFe TUGC0 cf fices in Dallas and at the l Comanche Peak construction site. Activities of the Architect / Engineer and Constructor were audited only at the construction site. The scope cf the audit included coninitments made in the PSAR, the Corporate Quality Assurance Manual, the Comanche Peak Quality Assurance Plan, the Project Procedures Manual l and the Brown & Root Quality Assurance Manuals and Procedures related to the Comanche Peak site. Auditors: Dallas office, May 1-3, 1978 J. P. Jackson, MAC Audit Team Leader J. M. Norris, MAC Auditor Comanche Peak Construction Site, May 4 & 5, May 8-12,1978 J. P. Jackson, MAC Audit Team Leader J M. Norris, MAC Auditor J. A. Hendron, MAC Auditor (May 8-12 only) Personnel NAME COMPANY TITLE fn D. N. Chapman TUGC0 QA Manager, *-1-2 rv e ed R. G. Tolson~ TUGC0 Mgr, Site Surveillance, *-1-2 R. V. Fleck TUGC0/G&H Civ. Inspec. Supv., *-1 J. V. Hawkins TUGC0/G&H Prod. Assurance (QA), *-1 ) lixsc

1 TU6CO AUDIf REPORI I t I l Personnel NAME CUMPAtW llTLE J. B. George TUSI Proj. General Mgr., *.1-2 rv ed J. T. Me r ri t TilSI Resident Manager,

• -1 E. G. Gibson TUSI Project Engineer, *-1-2 t

B. J. Murray TUS1 Engineering Supv., *-1 ) J. J. Moorhead G&H I'.ts i dent En gi nee r, *-1 -2 l ( B. C. Scott B&R Site QA fianager, *.1 J. P. Clarke B&R Site QC Manager, *-1 3 R. Mann B&R QA Records Coordinator,

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H. O. Kirkland B&R Proj. General Mgr, *-1 l 1 U. D. Douglas B&R Project Manager, *-1 j D. C. Frankum B&R Asst. Project Ngr.,

• -1 P. Foscolo B&R Proj. Chief Engineer, *-1 j

1 L. Hancock B&R Mat'l Procurement, Con-i struction Branch, *-1 i A. Boren TUGC0 Vendor Compliance I A. Vega TUGC0 QA Central Staff Function, + l l C. Beggs TUGC0 Systems Compliance, *-1-2 l R. Gary TUGC0 V. P., Opera tions, *-1 L. Fiker TUSI V.P., Design & Procurement,

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P. Brittain TUGC0/TUS1 Presi dent, 1 Interview 1 Pre-audit meeting 2 Post audit reeting l l Audit Method: The audit was conducted through a series of interviews with responsible management and supervision and examination of Quality Assurance manuals, procedurcs, records and work operations Loth at the Dallas headquarters of Texas Utilities l Generating Company and Texas Utilities Services, Incorporated and at the Comanche Peak construction site. Summary: The audit disclosed that recent changes in authority dele-l gations had been generally well accepted and that morale l f" "*= RE

TUGC0 AUDIT REPORT l l Summary (Cont'd): and team spirit were good. However, the changes had not yet been forn;alized in revisions to the PSAR and the Cocianche Peak Quality Assurance Plan. The audit also disclosed that present practices in the control of design l changes and of certain nonconformances do not provide the l requisite level of review by the original designer. In other instances it was evident that design changes were being used in lieu of nonconformance reports. Except for the areas noted herein and below, there was generally good adherence to existing procedures. l Findings: 1. The current activities of TUGC0 Quality Assurance per-sonnel are not consistent with the authority delegations to Brown & Root and to Gibbs & Hill as defined in the PSAR and Comanche Peak Quality Assurance Plan. Similarly, the Quality Assurance Plan and Procedures are not consistent with current and planned revisions in authority delegations to the Architect / Engineer and the Constructor, and is not complete in addressing all eighteen criteria of 10CFR50 Appendix B. The lack of a s well identified plan of reorganization and responsibility causes uncertainty in carrying out some activities. l There needs to be a plan for revising the Quality Assur- ] ante Program; such a plan should include the estat:lishment of an architecture of procedures to show how other TUSI/ TUGC0 and contractor manuals inter-relate with the Quality j Assurance Manual. The TUGC0 QA Manager should establish a schedule and assign responsibilities for completion of the necessary procedures. The schedule should be supple-mented with a management effort to monitor adherence to the plan and achievement of the schedule. f ) 2. The current site DC DDA system of after the fact coordi-l nation of design changes with the original designer (noc l 0 __._-___a

1 D 10GC0 AUDIf REPORT -A-l l Findings: (Cont'd) provides a significant risk of design error and does not meet the requirements of iOCFR50 Appendix B, nor f of AtiS1 tl45.2.ll, " Quality Assurance Requirements for s the Design of tiuclear Power Plants". I A system for expediting and documenting Gibbs & Hill i home of fice approvals should be established using telephone, telecopier or telex as a means of speeding l communication. i ( 3. The Comanche Peak Quality Assurance Plan does not provide for o Quality Assurance review of procurement documents i and changes thereto prior to purchase order placement, 1 i except for site originated procurement. Such a review I is identified in 10CFR50 Appendix t3, Criterion IV and is a requirement of AtlSI fl45.2.13. It should be required on all safety related procurement. i 4. The current combination of Chapter 17 of the PSAR, the TUGC0 Corporate Quality Assurance fianual, the Comanche Peak Quality Assurance Plan, Project Procedures and Brown & Root flanuals and Procedures provides a complex array of procedures which is difficult to maintain current and consistent. 5. The current system of providing inspection instructions or checklists to inspectors is too generic, placing an undue burden nn the inspector in attempting to determine applicable drawings and specifications and applicable revisions thereto. A review of records of concrete pours incidates that configuration reflecting the as-. poured condition is not clearly defined. Applicable DC DDAs are not noted in inspection documentation. Configuration needs to be clearly identified to inspectors on a current basis, including all applicable

TUGC0 AUDIT rep 0RT

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Findings: DC DDAs and completed docun.entation must reflect the ] (Cont'd) status of the applicable chsnges. 6. Special processing riarkings for later in-service 1 inspections are carelessly applied. The circle and arrow used for such marking is sometimes incomplete and not recognizable for its intended purpose. in one instance only a portion of the circle resembling the letter "C" was discernible. Failure to properly mark these locators now will cause delay and possible l error when in-service inspections are made in highly irradiated areas. 7. Disposition of nonconfonning iterns does not always achieve the requisite review by appropriately qualified design personnel. A procedure, limited to defects in j concrete, was recently issued which bypasses the estab- { lished nonconformance control system and, thus, violates I regulatory requirements in this regard. In other instances, the DC DDA program has bcen used to bypass 1 1 the nonconformance reporting. system. The nonconformance j control system should be the means for maintaining in-I spector integrity, identifying problem areas and provide I, a driving force for their correction. l 8. The records storage facility does not currently have any means of internal fire protection during hou' - it is unmanned, although it is understood some method is planned. Quality Assurance records, such as personr.el i qualifications, are not maintained in the Records Center, but are maintained in fireproof file cabinets in a trallpr under the cogni2ance of Brown & Root training coordinator. 9, Approximately twenty-four percent of Central Staf f audits have not been conducted as scheduled. Combining r.entral Staff audits, site audits and site surveillance activities

TUGC0 AUDIT REPORT

• FirJings:

by TUGC0 and by Brown & Hoot int' a single, cohesive (Cont'd) program would provide improved visibility to the overall audit and surveillance effort and permit evaluation and ajustment to the audit schedule to attainable and yet effective frequencies. l l I I l 1 I l l I 1 4 \\ i I l l l I li5iBii

l 1 APPENDIX B l 1 TEXAS UTILITIES GENERATING COMPANY f OBSERVATIONS AND RECOMMENDATIONS i f m f DO NOT BEPRODUCE b W ^ o I Ke6ry O. Kirkland, Project General Managn-l i' MANAGEMENT ANALYSIS COMPANY

l TUGC0 AUDIT OBSERVATIONS AND 1. RECOMMENDATIONS 1 i 1. ORGANIZATION A. General l TUGC0 Quality Assurance has undergone considerable reorganization in the past year. The general thrust of this ef fort has been the assumption of greater direct involvement in the management and supervision of the Comanche Peak Quality Assurance Program. It is to be noted that important j shif ts in responsibility were being made at the time of NAC's review. l As a part of this assessment, f1AC evaluated the reactions of key managers, supervisors and inspectors to the overall changes that have taken place I to date. It was generally observed that those interviewed thought that with few exceptions the changes were for the better. There appeared to be a team effort on the part of QA and Construction with excellent TUSJ executive management and project management support of the QA program. There was no noticeable problem with organizational prejudice brought about by the organizational intermixing of TUS1, Brown & Root or Gibbs & Hill work forces and supervision. B. 03 anization During the course of the audit MAC discussed the value of a revised organizational structure with the TUGC0 Quality Assurance Manager and the Manager, Site Surveillance. it is recommended that TUGC0 adopt an organizational realignment of activities as set forth in Exhibit 1, whereby Quality Engineering and Inspection report to the Site QA Supervisor as two separate sub-organizational entities with responsibilities as defined in Exhibit 1. ~' Such an organization will better supplement the existing Construction organization and will permit better organization for handling day-to-day site problems as well as implementing recommendations of this rcport. This is particularly so in the area of inspection planning. hoc

l TUGC0 OBSERVATIONS 5 RI'COMMENDM10fl5 ! { C. Quality Surveillance Conmit_ tee l All minutes of meetings of the QSC since its inception were reviewed. It is noted that the QSC was established as a mechanism for providing top TUGC0 management with a periodic update on such matters as " schedules and milestones" or " audits and corrective actions. It was noted that recent meetings dealt with tracking on the status of action items as set forth in the Outstanding Staevitl,nce Report Items or the Quality Assurance Items of Concern Report. In such instances it l appeared the Quality Surveillance Committee was taking on the role of a task force or problem solving group. The problem that exists if the QSC ] assumes such a role is that prablems would tend to await the three month ] meeting cycle before the necessary management attention is ef fected. It is recommended that TUGC0 re-evaluate the charter of the QSC and serious consideration given as to its value to the projec'; recognizing that: 1. All action to resolve problems should be handled on a day-to-day basis 7 j through the functioning organization, and I I ( 2. The primary objective cf maintaining management awareness of QJalitf Assurance status might be accomplished more efficiently, ef fectively F and on a more timely basis through a monthly Quality Assurance progress report distributed to the TUGC0/TUST executives. l D. Quali fication_of, Persennel, MAC reviewed the qualifications of all TUGCO/TUSI and Gibbs & Hill Quality Assurance personnel and many of the Brown & Root personnel. It was observed that most of the TUGC0/TUSI Quality Assurance personnel have gained their Quality Assurance experience tnrough Comanche Peak activities only. Although the project has provided valuable experience, it is recf onmended that any future assignments in Quality Assurance be filled with quality engineers hired from outside the company with broad nuclear ex-perience, preferably in construction. Such experience added to the existing staff will serve TUGC0/TUSI well in accomplishing tne important thac d

b TUGC0 OBSERVATIONS & RECOMMt.NDAll0NS -J-l 1 I. piping, electricai and startup activities ahead. MAC had occasion throughout the audit to assess the qualifications and , experience of 20-30 inspectors throughout the construction site. These observations are worth mentioning: 1. The inspectors are generally young and inexperienced with many having as little as six months experience in inspection. l 2. There was an obvious need for more seasoned inspectors to work with the novice inspectors on a day-to-day basis. ] 3. Too much responsibility is placed on the inspectors with respect to preparation of inspection planning, resolution of site problems and determination of the design configuration base for performance of inspections. 11. QUALITY AS$URANCE PROGRAM The Quality Assurance Program is defined in three basic documents: The Corporate Quality Assurance Manual Chapter 17 of the PSAR The Comanche Peak Quality Assurance Plan These documents are not in total agreement with one another. Since there is no other nuclear plant currertly planned and since the authority dele-gations identified in the Corporate Manual are not in consonance with practices on Comanche Peak, TUGC0 should consider discontinuance of the { Corporate Manual unless there are other projects to which it is to be 1

applied, if a Corporate Manual is required at a later date, a new one could be prepared based on Comanche Peak experience and the requirements of any new projects to which it woulJ be applied.

The Comanche Peak Quality 4ssu'rance Plan addresses only the following criteria of the eighteen identified in 10CFR50 Appendix B. ) tuoe l

TUGC0 OBSERVATION 5 & RLCOMMENDA110NS Organization i Design Control Procurement Administration Inspection Nonconformance Control Document Control Records Audits With the expanded responsibilities of the TUGC0 Quality Assurance Depart-ment, the plan needs to be expanded to address all eighteen criteria to reflect the creation and functions of the Procurement Department and to be consistent with the authority delegations and functions still resting with Gibbs & Hill and with Br own & Root. Ti,ere needs to be a plan for procedural identification and development and a schedule and assigned responsibilities for their completion, including a complete architecture of Quality Assurance procedures, project procedures I and interfacing procedures of the Architect / Engineer and Constructor. The l effort should be to minimize the number of procedurrs required and to eliminate duplicating or overlapping procedures through consolidation of detail and joint approvals of the organizations involved. It is recommended that the Quality Assurance Manager use his organization as the driving l force to achieve required procedural coverage on schedule. l It was noted that TUGC0 is planning on obtaining its own Code manual. l f The stated reason for this was the fear that Brown & Root would not achieve Code acceptance. The auditors feel t!,at the Brown & Root manual would be acceptable to the Code Survey Team and that its weld practices as exempli-fied in the Weld Shop are very acceptable. The auditors are of the l opinion that obtaining a Code Stamp will be difficult where all the work of implementing the program is performed by others. Ill. DESIGN CONTROL The present system of expediting field f hanges by referring design changes to the original design organization for approval after the fact does not SE

I TUGC0 OBSERVATiOl15 & RECOMMEllDATl'NS ' O 1 I meet the intent of 10CF R50 Appendix 8 nor of ANSI fMS.2.ll, which require I that field changes be subject to design controls commensurate with those exercised on the original design. TUGC0 audits have already disclosed l l that the Architect / Engineer has not been reviewing field originated changes en a concurrent basis, thus the design engineer's connents may be received after the specific construction work is complete resulting in possible l loss of design integrity, undue pressure on the designer to justify what ) has been done, loss of designer responsibility or possible extensive repairs. It is recommended that a system for expediting review and approval by the original designnr be established on all safety related l l changes using telephone, telecopier or telex as necessary to coordinate and document change approvals. IV. PR_0CUREMENT DOCUMENT CONTROL Except for site procurenents, the Comanche peak Quality Assurance Plan does not provide for a review of procurement documents and their changes prior to placing a purchase order. This is contrary to requirements of i 10CTR50 Appendix B, Criterion IV and ANSI N45.2.13, " Quality Assurance 1 1 Requirements for Control of Procurement..... ". There is.a review of pro-curement documents by Quality Assurance during Design Review, but is was ascertained that this was a review of the drawings and specifications and not the purchase order or contract. Procurement document review by Quality Assurance should assure that all necessary requirements for access to the supplier's facilities are provided and that necessaiy controls and documentation have been specified and that the appropriate configuration has been definea. The review should also assure that requirements imposed are appropriate to the procurement and that there are no excessive requirements for quality program develope ment or for the delivery of unnecessary documentation. Some of the pro-curenent packages reviewed appeared to have both blanket requirements foi-Quality Assurance programs and excessive requirements for documentation. II M

j l I TUGC0 OBSERVAT10flS & REC 0tttiltlDAT10fis l i i V. If4STRUCT_10flS A. Inspection Plann_in.g The current system of providing inspection instructions or checklists to the inspectors is too generic in nature. In the case of concrete inspection planning the inspector fills out a simple pour card with an attached 1 Concrete Placement Checklist, a Reinforcing Steel, Electrical, Mechanical and Embedded item Placement Checklist and a Stainle'ss Steel Liner Checklist, the combination of which: 1. Provides no informat ion with respect to unique, embedments or penetrations to be incorporated in the pour. i 1 2. Places an undue burden on the inspector in attempting to determine applicable drawings, specifications, applicable revisions and appli. able DC DDA's. 14uch of this input should be provided by clerical support under the direction and subsequent approval of ( a quality engineer. l Inspectors estimated that 45-70% of their time is spent on docu-mentation rather than physical inspection activity. Well thought out planning could do much to alleviate this situation. 4 N her - Traceability ~ - c.. It was observed that Comanche Peak has established a program of unnecessary material traceability which, based on one estimate, consumes at least a three-man level of effort and perhaps as high as a six man level of effort if one considers all the support functions required to implement the pronram. All anchor bolts and B series cadwelds are fully traceable to heat numbers such that through an elaborate and extensive system of mapping all installations, the capability exists cf identifying each embedded anchor bolt, B series cadwelds and other standard embeds to its heat number. Thcre exists no such f4RC or industry requirement for this " degree of traceability. It is inter-esting to note that rebar does not require traceability on Comanche Peak (and shouldn't), MAC knows of no other project that imposes this require-o

TUGC0 OBSERVATIONS & RECOMMENDATIONS ment and could not identify a Comanche Peak specification or procedure requiring it. Accordingly, it is recommended that this practice be dropped immediately. Such a move would enhance inspector morale as those involved are aware that the practice serves no useful purpose. C. Procedure Simplification Newly established procedural systems are r.uch that Construction and Quality Assurance issue procedures on similar subject matter jointly, for example, the recently issued procedure on shop travelers was jointly prepared by Construction and Quality Assurancu. It is recom-mended that important procedures such as those related to concrete be revised and issued as a single procedure approved by Construction and Quality Assurance. Similarly, those procedures related to piping and electrical should be revised and jointly issued as a single Comanche Peak procedure. D. Procedures Independent of Houston The present system of obtaining Brown & Root, Houston of fice approval on construction procedures should be modified. Guidelines should be worked out with the Houston office whereby they approve only top level procedures, permitting the site full flexibility in revising detailed site procedures. Perhaps the Brown & Root, Houston office could retain approval authority on those top level documents that establish Brown & l Root policy, control the necessary type of furms, etc.

However, l

detailed operating procedures should be changed with site approval only. l 1 l Perhaps the Houston office would agree to a retroactive review procedure. l i E. Configuration Control i A review of records for completed concrete pours indicates that the configuration reflecting the as-poured condition is not properly It was noted that the inspectors' record the particular drawinh defined. number and revision letter! however, all applicable DC DDAs are not ' noted anywhere in the inspection supporting documentation. 1 E l _ -_a

1 1 ) l TUGC0 OBSERVATIONS & RECOMMLUDATIONS, l l F. preplanning of Construction Work In discussions with construction management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for a detailed material takeoff on all Gibbs & Hill f drawings which provides detailed instructions to the crafts as to the civil, mechanical and electrical items to be included in each segment of work. This formalized approach of taking material takeoffs in the office and providing this information to the field forces on an approved material takeoff list will do much to improve the quality of the work. Since the material takeoff is a formal process accomplished by construction engineers well in advance of the work, it provides a significant measure of preplanning, including the processing of necessary design changes to accomplish the work. Such an effort will do much to minimize field errors with respect to left out embedmonts or inability to complete work as a result of design errors. It is recommended, however that this effort be formalized into a Comanche Peak site procedure. As such, it will be recognized as part of the system and will do much to assure that Gibbs & Hill drawings are forwarded to the site on a timely basis to accomplish this preplanning effort. V1. DOCUMENT CONTROL l While there appeared to be some problems with bringing the Automatic l Records Management System on line, the manual system backing it up appeared to be functioning satisfactorily. The audii. ors found no i deficiencies in document control. i VII. CONTROL OF PURCHASED MTERI AL, EQUlpMENT AllD SERVICES The Quality Assurance Plan is not up to date in regard to TUGCO's responsibilities for procurement, source evaluation and source sur-veillance. TUGC0 has developed a program for rating supplier perform-ance and shows evidence of actions when reatings are unsatisfactory. The list of suppliers requiring evaluation and source surveillance is not kept up to date by the Architect / Engineer. The list in use is over

TUGC0 OBSERVATIONS & RECOMMENDAT10f15 four months old, but is maintained manually by the TUGC0 Supervisor of Supplier Cortpl iance. i There does not appear to be any method of assuring that the latest con-figuration is supplied to the personnel performing source insrection prior to shipment of procured items. The source inspector appears to be at the mercy of the supplier in determining what changes have been identified and incorporated. Thus, it is conceivable that items will be shipped to the site that do not meet the desired configuration even though requirements of the purchasing document have been met. Such receipts can cause delays and unwarranted costs in meeting the proper configuration. I it is recommended that a practice be established of identifying and confirming required configuration prior to procurement and prior to shipnent of purchased naterials and components. VIII. IDENTIFICATION AND CONTROL OF MATERI ALS, PARTS AND COMPONENTS 1 No deficiency noted. Material reviewed in the warehouse, in open storage and in the weld shop appeared to be adequately identified. l IX. SPECIAL PROCESSES A. Pgdiography Iridium 192 is being used as the radiation source for all radiography at the site. This isotope has its optirnum capability at about 1.5 inch thickness of steel and is not recommended by the Code below.75 inches.

is penuitted for lesser thicknesses when the use of other radiation sources is not practical and when resolution of the outline and 4T hole size of the penetraneter can be demonstrated. The energy levels of I

iridium isotopes are higher than optimum for materials.375 inches or thinner, resulting in a flat image and lack of contrast. Becauseexposdre time relates to distance, fhe isotope is normally placed against the pipe opposit. the film. With a.100 inch source size, this causes blurring of the image. Lack of contrast and a blurred image makes it unlike'.y Inac

TUGC0 UBSERVM IONS 8 RLCOMtintDM iotlS that hairline cracks will be seen and difficult to accurately define large indications. The use nf iridium 192 meets the minimum requirements of the Code, but by not providing optimum identification of observed anomolies it does three undesirable things. First it causes unnecessary removal and repair of indications that can be seen but not properly identified; secondly, it masks narrow cracks, tight lack of weld pene-tration and non-fusion which can be detrimental to service life; thirdly, it does not provide an adequate base line for in-service inspections l performed af ter the plant has gone into operation. Failure to have clear identification of the original indications at that point can cause delays. l the cost of which greatly exceeds the cost of providing better identifi-cation and necessary repair of defects found in the construction phase. 1 Recommendation - It is recommended that TUGC0 require x-ray for shop welds, and consider its use where practical for construction welds. X-ray machines in the range of thirty pounds of weight are available and are nearly as portable as the isotope. Because of its smaller focal spot size and variable voltage, x-ray can give superior radiography. The feedback of information to welders can improve the quality of welds and minimize the potential for defects. The ability to discriminate between j i.ndications having roundness or sharpness at the ends can eliminate repair. l The ability to positively identify in the construction phase those indi-cations which have a potential for growth and failure can permit economical repair without radiation hazards that are inherer.t if found later in the l operating phase. l I B. Welding No causes for concern and no procedural noncompliance were found in review of the weld shop. There seemed to be a general opinion that after radiography repairs are being required that are acceptable within the Code. A review of a small quantity of rejected film indicates this, generalization may be valid. Jt was disclosed during the audit that radiographs may be reviewed by as many as five individuals. Such ex-cessive review leads to supercritical evaluation of film and to excessive repair. As previously stated, better radiography permits better Indii

TUGC0 OBSERVATIONS & RECOMMENDATIONS l l 1 identification of conditions acceptable within the Code. Unnecessary repairs increase cost and reduce pipe reliability. q Recommendations - Have radiographs which have been rejected for defects j reviewed by TUGC0 Level Ill radiographer. If a reasonable statistical sample shows that excessive repair of welds has been required, establish l l the policy that Code acceptable indications shall,emain unt')uched, but shall be recorded on the reports. As an economy, consider reducing the number of persons performing sequential' review of radiographs. C. UDE Quali fications The site NDE Level III situation is unclear. Only ' Level 11 Certification by Brown & Root was available for the.nE Supervisor: however, it is l 1 understood that TUGC0 has issued a letter identifying him as Level 111. Recommendation - Clarify the authority and responsibility of the NDE supervisor in administering tests and evaluating and certifying per-sonnel. This is vtry important as related to Code work, since the Level Ill will be working under the authority of the holder of the Code stamp. X. INSPECTION l There were no deficiencies noted relative.to inspection; howe'ver, it was noted that a large number of inspection personnel are receiving ) i their first nuclear construction experience on the Comanche Peak site. f s . As a consequence, it is necessary to improve the quality of inspection planning and to increase the level of supervision and quality engineering f support. Inspection planning should identify the required configuration including applicable UC DDAs, the features to be verified, the inspectipn ] ) method and acceptance criteria..in order to minimize possible confusion l and error l Inoe

TUGC0 OBSERVATIONS & RECOMMEf1DAT10NS l XI. TEST CONTR0i. A review was made of the TUGC0 startup administrative procedures, with the following observations. 1. The procedures appear to be written around the old organization; that is, in several instances they refer to the Brown & Root QA/QC input required in the preparation of "startup work requests". l 1 2. It was noted that an unique system is being established to handle nonconformances during the startup phase. It is recommended that wherever possible existing schemes utilized in construction be used during the startup process. This is important since most personnel I involved in dispositioninc) such items as nonconformances and design changes will be the same persons involved in construction. XII. CONTROL OF MEASURING & TEST EQUIPMENT 1 1 It was observed that out of 24 instruments sampled which are utilized in civil, structural, mechanical and electrical work, approximately 50 percent had not been withdrawn from the calibration laboratory since its last calibration date. This is particularly significant when it is l recognized that the present system is such that if a calibration date l becomes due, the instrument is recalibrates whether or not it has been [ issued for use. It is recommended that consideration be given to simply i changing the calibration date rather than going through a calibration cycle if the tool has not been used. l ) It was noted that many construction tools are calibrated. It is important to note that calibration of construction tools is not necessary with respect to 10CFR50 Appendix B. Although calibration j and maintenance is extremely important on construction tools, it may I be that frequencies may be relaxed. i XIII. INSPECTION, TEST AND 0PER5TIflG STATUS l No deficiencies were noted in this area. Material and equipment 1 observed in receiving inspection, in the warehcuse and outside storage l

l l TUGC0 OBSERVAT IONS & R! COMML *.?ATIONS. 1 l area appeared to be adequately identified. flo tests were observed. I XIV. HANDLING, STORAGE AND SHIPPING Exterior storage practices should be reviewed. The protective coverings of many items are damaged; some reported on monthly surveillance reports have not been corrected. Large temporary structures, such as those over i f the emergency diesel engines, require wind bracing to prevent further 1 damage. Because of soil chemistry, rain and humidity, the current prac- ) tica of allowing large stainless steel piping to remain uncovered should be reviewed. Sensitized stainless is extremely sensitive to chloride, I 1 fluoride and sulphide contamination which with water as a couplant can l cause intergranular corrosion and premature failure. XV. CONTROL OF NONCONf0RMANCES l There appears to be an ef fort to reduce the number of documented non-l I conformances. It was noted that DC DDAs were being utilized for nonconformance reports. Although this was observed on a small percentage of DC DDAs issued during l 1 the month of April, -it is recommended that this practice be stopped j l immediately. The TUGC0 system is correctly established whereby non-l conformances are written after the fact and DC DDAs are reserved for i design changes before the fact. It is important that this practice be enforced since DC DDAs prepared af ter the fact necessitate tFat workers j l be directed verbally to violate the drawing since the deviation will be handled after the fact with DC DDAs. This is a poor Quality Assurance practice. Procedure CPQl-AB, Rev. O, dated 5-5-78 was issued for the purpose of l providing expedient disposition of concrete discrepancies. The procedure infers that discrepancies of 72 F versus 70 F or 6.2" air content versusf l 6.0% maximum is perfectly acceptable when it is signed off by the field engineer. Such a systen shortcuts the established nonconforming material control system as defined in Brown & Root and TUGC0 procedures and should l

l TUGC0 OBSERVAlI0 tis & RF.COMMulDAilof15, be discontinued. If tolerantes are unrealistic such that the 72"I is ( acceptable, then the design specification should be changed to so indicate. It is recommended that good inspection planning be provided inspectors, I identifying the characteristics to be inspected, the method of inspection l and acceptance criteria and that inspecters identify nonconformances to such criteria. This will maintain the :ntegrity of inspectors and provides ] 1 identification of problem areas and provides a means for their correction. It is reasonable to assume that on a project as large as Comanche Peak there.will be several thousand nonconformance reports. The number does not reflect adversely on the quality of construction, but the failure to ider'.ify nonconformances does reflect adversely on the integrity of inspectors and leaves unknown the quality of the plant. XVI. CORRE_CTIVE ACT10t1 There were no deficiencies noted relative to corrective action on hard-ware. The Supplier Compliance Supervisor has established a method of tracking vendor performance and shows positive results from actions taken t to correct supplier quality problems. A review of reports of site sur-l t veillance conducted by TUGC0 showed corrective action responses were l being promptly received. A review of reports of surveillance actions by Brown & Root showed generally adequate response and resolution of corrective action except for a period of four months when surveillance personnel were assigned to other tasks. In general, corrective action appears to be adequate and tinely un vendor l and site related problems, but some deficiencies identified in audits of i major contractors still persist. Some of the changes in authority dele-l I gation to major contractors appears to be action taken to correct inadequate i or untimely response i>y those organizations; however, other actions taken, j such as handling of field changes and nonconformances, appear to be those of circumventing the problem rather than correcting it. l i [ hmc

TUGC0 OBSERVMIONS & RECOMMENM110NS, XVil. RECORDS Except for lack of internal fire protection, the quality records area is considered to be satisfactory. Some Quality Assurance records, such as personnel qualifications, are not stored in the records center but are maintained separately by the Brown & Root training coordinator. There is not currently a catalog or listing of required records although it is being prepared. A review of a selection of Quality Assurance records showed the documents in them to have been properly completed and in the correct order. Recommendation - The installation of an inert gas fire extinguishing system or the identification of geographically separate duplicate records should be expedited. TUGC0 should review the fire protection capabilities of storage facilities in the training supervisor's trailer and consider l a duplicate set of such records to be maintained in the records center. I XVill. AUDITS There are several audit and surveillance programs in effect. Audits by I the Quality Assurance Department Central Staff are performed on site activities, major contractors and suppliers. Site surveillance actions are performed under the direction of the TUGC0 QA Site Supervisor. Similar surveillance activities are carried out under the direction of the Brown & Root Site Quality Assurance Manager. While called surveillance actions, the surveillance programs are formally planned and scheduled, utilize checklists to guide the activity and record results, and issue reports of deficiencies and require correction. Except for formal and documented pre-audit and post-audit meetings, all the elements of an audit program r l l are in place. It was reported that the reason for calling the activity " surveillance" was to avoid outside auditors finding the program deficient l because it did not include the documented pre-and post-audit meetings, yet the auditors found that such meetings were conducted, but on an l infomal basis. Recommendation - The auditors consider the present program to be an effective tool which could be further improved. TUGC0 should consider lDQb

TijGC0 OBSERVAT10f15 f. RLCOMMLilDATIO!!S combining the audit and surveillance activities into a single, cohesive effort. Such an integrated effort could cover required areas more efficiently, without duplication and at a frequency that can be main-tained. Such an audit program should be described in written procedures and include a description of both the formal audit and the continuous audit plan (surveillance) and the n'ethod of conducting pre-and post-audit meetings should be described to preclude later criticisms by outside organizations. The resulting audit program should be a superior tool for management assessment of program implementation and effectiveness. 1

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1 \\ ARMS g INDEXED t-10ti-769 TEXAS UTILITIES SERVICES INC. L ~. OrrlCE MEMOR ANDUM o^tt O O I T. J. B. George ci. %,,, ym, S e p t e et> e r 18. 1978 4 saj.et COMANCHE PEAK STEAM ELECTRIC STATION m 4 1981-83 2300 tW INSTALLATION 4 STORAGE OF S.S. COMPONENTS AT C.P. lO j 4 l i The following information is provided to resolve any questions re-l j I maining on the storage of stainless steel piping. {9 I The initial question was raised in an open item by the NRC. They are concerned that the storage of stainless steel piping as implemented on CPSES could possibly result in intergranular corrosion problems. The problem was referred to Gibbs & Hill and using the soil testing data supplied by Mason-Johnson Co. Mr. R. Barber and Mr. G. Stern. Gibbs & Hill metallurgist, performed an extensive evaluation e' the problem. The conclusion of this evaluation was, that with prc,)er surveillance of the storage areas and proper cleaning methods used prior to fabrication and welding, intergranular corrosion would not be a problem. The results of this evaluation satisfactorily closed the NRC opan item. Subsequently an audit made by the Mgt. Analysis Co. questioned the w I storage of stainless steel piping on site. 3 l To resolve this question it was deter.ttined that an independent evalua-E MM tion should be performed. Because of their extensive studies of intergranular corrosion of stainless steel, Westinghouse Corp. was

EC l

requested to make this evaluation. d A Westinghouse engineer, Bill York, was sent to the site to evaluate 4 the storage condition, of stainless steel components. With site storage info and soil tests Dr. J. Enrietto, mana r of metallurgical l and NDE analysis for Westinghouf e, provided the Il al report. l \\ In his report, copy attached Dr. Enrietto states in part "The stain. less steal stored under the conditions described am not in danger of a premature failure by intergranular corrosion." Dr. Enrietto then described the reasons for his conclusions. B 2. R DCC DIST* Based on the original conclusions Oy Gibbs & Hill, reinforced by .n. C same conclusions made by Westinghouse. The storage of stainless daal pt piptnp as presently implemented on CPSES is adequate and not an aWoltCT WOR, j l l of concern. The present method of storags should be continued. p,, g

• JOB NO. 351195

.04 8GR- / 1 ECEIVE9 PR01tCT CONT. (NCR./ aucCo g4 I SEP 251978 . T. Merritt, ar. Resident Manager .."OlICT CEN. MOR. RCB/JTl/ cc: L. F. Fikar H. O. Kirkland 0 File w/ Report 45 5 [ l 7 l .}}