TXX-6144, Forwards Responses to Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions:Qa Overview Committee Formed & Meets on Regular Basis Since Sept 1985 & Procedure DQP-CS-4 Revised

Forwards Responses to Violations Noted in Insp Repts 50-445/84-32 & 50-446/84-11.Corrective Actions:Qa Overview Committee Formed & Meets on Regular Basis Since Sept 1985 & Procedure DQP-CS-4 Revised

ML20210B415
Person / Time
Site:	Comanche Peak
Issue date:	02/02/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-6144, NUDOCS 8702090152
Download: ML20210B415 (10)

Text

Log # TXX-6144 File # 10130 IR 84-32 IR 84-11 EE 1

E 3 1UELECTRIC '

%i!!iam G. Coumil Luetutiw 5ke Preudent February 2, 1987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NOTICE OF VIOLATION RELATED TO INSPECTION REPORT 50-445 (84-32)/50-446 (84-11)

REFERENCE:

1. Letter from D. R. Hunter (NRC) to M. D. Spence (Tl!GCO) dated February 15, 1985

2. TXX-4453 from B. R. Clements (TUGCO) to D. R. Hunter (NRC), dated March 11, 1985

3. Letter from D. R. Hunter (NRC) to M. D. Spence (TUGCO) dated July 30, 1985 Gentlemen:

In Reference 2 we notified your office of our determination that Items 1 and 2 of the Notice of Violation transmitted to us in Reference 1 were similar to l findings identified by the NRC Technical Review Team (TRT). Therefore, we t elected to exercise the option discussed in Reference 1 of responding to those

l. items as part of the Comanche Peak Response Team (CPRT) Action Plan.

I Reference 3 documents your concurrence with that decision.

The substance of Item 1 (Violation 8432-02/8411-02) was evaluated by the CPRT in ISAP VII.a.5. The substance of Item 2 (Violation 8432-03/8411-03) was avaluated by the CPRT in ISAP VII.a.4. The Results Reports for those ISAPs have been transmitted to the NRC.

fle $*#

b O ' 0 0 0 E oS O S5 hf/ b 400 North Olise Street I H. 81 Dallas, lexas 75201

. TXX-6144 Feburary 2, 1987 Page 2

)

Attached are TUGC0 responses to Items 1 and 2 submitted in accordance with the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10 Code of Federal Regulations. In each case the violation has been repeated, followed by the TUGC0 response. The TUGC0 response to Item 3 was provided in j Reference 2.

Very truly yours, n

$? .

W. G. Counsil '

RDD/dl c - Mr. Eric H. Johnson, Region IV Mr. D. L. Kelley, RI - Ragion IV Mr. I. Barnes, RI - Region IV

.Mr. H. S..Phillips Mr. Robert D. Martin, - Region IV l-t l

E

~

. Attachment TXX-6144 Page 1 Alleaed Violation

1. Failure to Reaularly Review the Status and Adeouacy of the 0A Proaram Criterion II of Appendix B to 10CFR50, as implemented by the Preliminary Safety Analysis Report (PSAR) and the Final Safety Analysis Report (FSAR),

Section 17.1, " Quality Assurance Program," and ANSI N45.2-1971, requires that the quality assurance program shall provide for the regular review by the management participating in the program for which they have designated responsibility.

Contrary to the above, the applicant did not establish quality assurance procedures to regularly review the status and adequacy of the construction quality assurance program; nor did the applicant appear to have reviewed the status and adequacy of the construction quality assurance program.

TUGC0 RESPONSE TUGC0 acknowledges that procedures were not established for the regular review of the status and adequacy of the construction quality assurance (QA) program. Notwithstanding this lack of procedures, it is TUGC0's view that managers and corporate officers by virtue of their day to day involvement were aware of the status and adequacy of the construction QA program. That awareness was based on various practices employed by TUGC0 managers and officers during the history of CPSES to evaluate the QA program. Those practices included the use of quality committees, documented management review, and independent evaluations. In addition, thes: managers and officers routinely received a variety of reports conce.ning the adequacy of the construction QA program such as TUGC0 QA internal audit reports and reports produced by independent personnel from outside of the TUGC0 organization.

1. Corrective Action and Results Achieved TUGC0 recognizes that regularly scheduled QA program assessments and reviews serve to focus management's attention on program adequacy and effectiveness. Accordingly, the Quality Assurance Overview Committee was formed and has met regularly since September 1985. The original charter for this committee was contained in Procedure DQP-CQ-5. The duties and responsibilities of this committee are currently described in the following policies and procedures:

1

, Attachment TXX-6144 Page 2 o NE0 Policy Statement Number 2, " Quality Assurance Program" (Revision 0 dated June 23, 1986): Requires the NE0 Vice Presidents to meet periodically to essess the status and adequacy of the QA program and at least annually to provide a written assessment of the overall effectiveness of the program to the Executive Vice President, NE0. The Executive Vice President, NE0 will assure that an annual independent assessment of the TUGC0 audit program is performed and the results reflected in the Vice Presidents' annual assessment.

o NE0 Procedure 2.20, " Senior Management QA Overview Program" (Revision 2, dated October 13, 1986): Defines the methodology employed by the NE0 Vice Presidents in r meeting their responsibilities as defined in NE0 Policy Statement No. 2. This procedure establishes a committee which meets at least quarterly to evaluate the status and adequacy of the TUGC0 QA program.

o NE0 Procedure 2.08, " Joint Utflity Management Audit Program" (Revision 0 dated June 23, 1986): Provides a method which the Executive Vice President, NE0 may utilize to perform the independent assessment of the TUGC0 audit program as delineated in NE0 Policy Statement No. 2.

2. Corrective Steos to Avoid Recurrence The corrective actions described above are considered sufficient to prevent further violations.

3. Date When in Full Comoliance Full compliance was achieved June 23, 1986.

i

. Attachment TXX-6144 Page 3 Alleaed Violation

2. Failure to Establish and Imolement a Comorehensive System of Plann_ed and Periodic Audits Criterion XVIII of Appendix B to 10CFR50, states, in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program." The requirements are addressed in the PSAR and FSAR, Section 17.1, " Quality Assurance Program,"

which references Regulatory Guide 1.28 (ANSI N45.2) and ANSI N45.2.12 (Draft 3, Revision 4). Those commitments require that a comprehensive system of planned audits be performed on an annual frequency.

Contrary to the above, the following examples were identified which demonstrate the failure to establish and implement a comprehensive system of planned and periodic audits of safety-related activities as required, as noted below:

a. Annual audits were not adequately addressed by the audit implementation procedures.

TUGC0 Procedure DQP-CS-4, Revision 0, dated August 9, 1978, only required two audits of vendors fabricating reactor coolant pressure boundary components, parts and equipment; png audit of vendors fabricating engineered safeguards components, parts, and equipment; and audits of balance of plant (safety-related) as required by the quality assurance manager.

TUGC0 Procedure DQP-CS-4, Revision 2, dated April 16, 1981, required only that organizations will be audited on a regularly scheduled basis.

TUGC0 Procedure DQP-CS-4, Revisions 2 and 10, did not specify auditing frequencies for design, procurement, construction, and operations activities.

TUGC0 Procedure DQP-CS-4, Revision 10, based audit requirements on Regulatory Guide 1.33, Revision 2, February 1978. This commitment did not fully address the requirements of the construction quality assurance program.

The above procedure and subsequent revisions failed to describe and require annual audits in accordance with commitments and requirements. Earlier audit procedures were not available to determine if they met requirements.

. Attachment TXX-6144 Page 4

b. Planning and staffing to perform 1983 audits was inadequate to assure that a comprehensive system of audits was established and implemented to verify compliance with all aspects of the quality assurance program, in that, of 656 safety-related procedures (which control safety-related activities) the NRC review revealed that the applicants sampled only 165, or 25 percent, during the 1983 audit program. Consequently, significant aspects of the safety-related activities were not adequately audited.

c. The Westinghouse site organization, established in 1977 to perform Nuclear Steam System Supply (NSSS) engineering services, was not audited by TUGC0 during the years of 1977, 1978, 1979, 1980 and 1981.

d. Audit of vendors that manufacture or fabricate parts, components, and equipment for reactor coolant pressure boundary and engineered safeguards systems have not been conducted annually dating back to August 9, 1978.

1

.._,.4 J .__4--_.s.-.=4. 4a____ 2.. ,.2 . _ _ . . . . 4-. ..

.. Attachment-

. TXX-6144 Page 5 y

TUGC0 RESPONSE The number and scope of audits conducted each year by TUGC0 over the history of the CPSES project reflect the evolution of the TUGC0 audit program from an initial overview function to the 'present role in which

~ TUGC0 has assumed primary audit responsibility. The TUGC0 audit program

was initially described in the CPSES QA Plan and ' beginning in 1978 in Procedure CQP-CS-4. (The procedure identification was changed to DQP-CS-4 in 1982.) The TUGC0 QA Department audit responsibilities described in the SAR were formalized in Revision 0 (dated August 29, 1978) of this procedure which established an audit plan. Consistent with TUGCO's initial overview role 'as outlined in PSAR Table 17.1-1, a minimum number of audits were planned and conducted for those organizations whose QA programs were described in the SAR. As TUGC0 assumed direct responsibility for site construction and engineering activities, the audit

,! responsibilities of the QA Department expanded commensurately.

Accordingly, procedure CQP-CS-4 was revised to address these i' responsibilities by providing for regularly scheduled audits of these activities and organizations and for the generation of an annual audit plan.

TUGC0 believes that the audit planning and scheduling practices employed ~

. by TUGC0 and its principal contractors over the history of the project collectively provided adequate audit coverage of the construction QA '

program. The conclusions of ~ the CPRT independent review regarding audit planning and scheduling, as described in the Results Report for ISAP VII.a.4, was that " Audit planning and scheduling, though in the past not

, in compliance regarding frequency and not formally systemized until recently, did appear to be well thought out in the context of the TUGC0 concept of the audit program requirements at any particular time".

Our response to each of the examples is set forth below.

i TUGC0 RESPONSE TO EXAMPLE 2.a TUGC0 has committed to meet the provisions of ' ANSI N45.2.12, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants,"

Draft 3, Revision 0 (vice Revision 4 as stated in the Notice of Violation), dated May 2, 1973. We acknowledge that the TUGC0 audit implementation procedures did not explicitly establish an annual audit frequency for all organizations or activities. However, the preplanned audits conducted each year by TUGC0 and its principal contractors provided audit coverage of the involved organizations and the activities of design, construction, procurement and others, as applicable.

1. Corrective Action and Results Achieved Procedure DQP-CS-4, " Procedure to Establish and Apply a System of Preaward Evaluations, Audit and Surveillances", was revised in November 1984 to specifically require that applicable elements of the construction QA program be audited by TUGC0 annually or at least once within the life of I an activity, whichever is shorter. Procedure DQP-CS-4 has subsequently been reidentified as DQP-QA-15.

Attachment TXX-6144 Page 6

2. Corrective Steos to Avoid Recurrence The corrective actions described above are considered sufficient to avoid further violations.

3. Date When in Full Compliance Full compliance was achieved in November 1984.

TUGC0 RESPONSE TO EXAMPLE 2.b TUGC0 denies the allegation of a violation for the reasons that follow.

With respect to staffing levels, a designated audit group staff was established in 1979 which increased in strength each year through 1983; however, the number of qualified personnel who actually performed audits during those years also included members of the QA organization other than those assigned to the audit group. It is TUGC0's view that the tota'i number of QA personnel who performed audits during 1983 represented an adequate staffing level. The CPRT indcpendent review resulted in the same conclusion as documented in the Res6ts Report for ISAP VII.a.4.

With respect to audit planning, TUGC0 has reviewed the 1983 audit plan against those safety-related procedures for activities which were being more than minimally performed during 1983. Those procedures were grouped by activity groups which were then compared to the scopes of the audits conducted during 1983. All but three of the sixty activity groups identified were subject to audit during 1983. Of the three activity groups not subjected to a specifically scoped audit during 1983, two received ancillary coverage as a result of the 1983 auditing activities and one (Protective Coatings QC Inspection) was excluded from the 1983 audit program due to the extensive review by the NRC of that area which was ongoing during 1983.

TUGC0 believes that the 1983 audit program coverage of the design and construction phase of CPSES was adequate. This conclusion was also reached by the CPRT independent review as described in the Results Report for ISAP VII.a.4. However, TUGC0 concluded that some of its administrative practices in scheduling audits should be formalized in a

, procedure or instruction. Accordingly, Instruction DQI-AG-1.7, "CPSES l Construction Phase Audit Program", was issued June 27, 1985. (This instruction has since been reidentified as Procedure DQP-AG-4.) A similar procedure for the scheduling of operations phase audits has been issued as DQP-AG-3, "CPSES Operation Phase Audit Program."

l l

i

~

Attachment TXX-6144 Page 7 TUGC0 RESPONSE TO EXAMPLE 2.c TUGC0 denies the allegation of a violation for the reasons that follow.

TUGC0 did not perform audits of the Westinghouse 111g organization because this organization is not and has never been responsible for the performance of safety-related activities. This was verified by TUGC0 during Westinghouse audits TWH-23 and TWH-24 conducted in 1982. However, subsequent to the NRC inspection TUGC0 performed an audit in November 1984 (audit number TWH-30) of the Westinghouse site activities which confirmed that the Westinghouse site organization was not responsible for the performance of safety-related work activities. Therefore, there is and was no requirement to audit this organization. The CPRT independent review resulted in the same conclusion as documented in the Results Report for ISAP VII.a.4.

To assure that we remain cognizant of the scope of work for the Westinghouse site organization, the Westinghouse Division responsible for the Westinghouse site organization has been identified on the vendor audit schedule and the TUGC0 Approved Vendors List (AVL). This assures that an annual evaluation of that Division's activities will be performed.

TUGC0 RESPONSE TO EXAMPLE 2.d TUGC0 assumed responsibility for the vendor audit program from Gibbs &

Hill beginning in January 1978. To assure the most effective utilization of audit resources, TUGC0 QA management scheduled vendor audits based on the following:

o Vendor Activity; o Evaluation ratings determined from reviews of source release inspection trip reports; o Receipt, installation or test problems communicated to the audit group from the site; o The last audit date.

This practice assured the application of audit resources to a vendor during active fabrication or when source or receipt inspections or other information indicated potential quality problems.

There were occasions when vendors were not audited annually due to satisfactory vendor ratings or lack of activity at the vendor facility.

However, it is our view that our practices resulted in an adequate vandor audit program and were equivalent to the practices endorsed by the NRC in Regulatory Guide 1.144, Revision 1. The CPRT independent review of this violation concluded in the Results Report for ISAP VII.a.4 that the failure to perform audits of all TUGC0 vendors on an annual frequency did not result in any adverse effects on the audit program because of the additional activities implemented by the QA organization to supplement the audit activity.

.. Attachment TXX-6144 Page 8

1. Corrective Action and Results Achieved Following the NRC Special Review Team inspection conducted in early 1984, TUGC0 determined that the FSAR description of its external audit program needed clarification. Consequently, in August 1984 TUGC0 revised FSAR Table 1A(B) to adopt a commitment to paragraph C.3(b), " External Audits",

of Regulatory Guide 1.144, Revision 1. This commitment requires the performance of annual evaluations and triennial audits of active vendors.

TUGC0 Procedure DQP-CS-4, " Procedure to Establish and Apply a System of Pre-award Evaluations, Audits and Surveillances," was revised in November 1934 to incorporate this commitment. (This procedure has since been reidentified as DQP-QA-15, "TUGC0 QA Audit Program.") Evaluations for all active vendors on the AVL which were last audited during or before 1983 were completed in the first quarter of 1985. As of January 1,1986 all active vendors on the AVL were within their annual evaluation and triennial audit frequency.

2. Corrective Steos to Avoid Recurrence The corrective actions described above are considered sufficient to prevent recurrence of this violation.

3. Date When in Full Comoliance Full compliance was achieved as of January 1,1986, i

. - . - . . _ . _ . .- - - . . .- - --- .