TXX-6469, Responds to NRC Re Violations Noted in Insp Repts 50-445/86-08 & 50-446/86-06.Corrective Actions:Implemented Use of Audit Planning Form.Util Disagrees W/Three Alleged Violations & Two Alleged Deviations

Responds to NRC Re Violations Noted in Insp Repts 50-445/86-08 & 50-446/86-06.Corrective Actions:Implemented Use of Audit Planning Form.Util Disagrees W/Three Alleged Violations & Two Alleged Deviations

ML20215B704
Person / Time
Site:	Comanche Peak
Issue date:	06/12/1987
From:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
TXX-6469, NUDOCS 8706170414
Download: ML20215B704 (8)

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M- Log # TXX-6469

== File # 10130 1

.5 IR 86-08

= = IR 86-06 RIELECTRIC

- # I *" * *

• William G. Counsil

' Executive Vice Preskknt 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 T0 NRC INSPECTION REPORT  ;

NOS. 50-445/86-08 AND 50-446/86-06 j Gentlemen:

We have reviewed your letter dated March 30, 1987, concern'ing the inspection conducted by Mr. H. S. Phillips and other members of the Region IV Comanche Peak Group during the 3eriod April I through May 31, 1986. This inspection covered activities autlorized by NRC Construction Permits- CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2. Attached to.your

. letter were Notices of Violations and Deviations.

On' April 27, 1987, per a telecon with your Mr. I. Barnes, we requested and received an extension as follows: IR 50-445/86-08 and 50-446/86-06 (2 violations, I deviation) extended until May 29, 1987.

On May 26, 1987, per a telecon with your Mr. Shannon Phillips, we requested and received an extension as follows: IR 50-445/86-08 and 50-446/86-06 extended until June 12, 1987.

We hereby respond to the Notice of Violations and Deviations in the attachment to this letter.

Very truly yours, W. G. Counsil RDD/dl-c - Mr. R. D. Martin, Region IV Resident Inspectors, CPSES (3)

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8706170414 870612 "

• PDR ADOCK 05000445 i G PM / g g 400 Nonh Olive Street LB 81 Dallas, Texas 73201 4

.Attichment to TXX-6469 June'12, 1987 Page 1 of 7 NOTICE OF VI0lATION ITEM A.1 (445/8608-V-01: 446/8606-V-01) l l

l A. Criterion XVIII of Appendix B to 10 CFR Part 50, as implemented by TVGC0 f Quality Assurance Plan (QAP) Section 18.0, Revision 2, dated July 31,  !

1984, and FSAR, Section 17.0, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of_ the quality assurance program to determine the-effectiveness of the program, and that they be performed in accordance with procedures or checklists, and that results be documented, and ,

followup action, including reaudit of deficient areas, shall be taken.

1. Failure to Fully Audit the B&R ASME/0A Proaram i

FSAR, Section 17.1.18, " Audits," requires that planned and l periodic audits be performed to verify compliance with all aspects  !

of the quality assurance program and to determine the l effectiveness. j B&R ASME/QA Manuals in effect since November 19, 1976, to the present require the B&R QA manager to assure that their ASME QA program is audited at least annually.

Contrary to the above, B&R failed to annually audit the entire ,

ASME/QA program as evidenced by the failure to audit 12 of 20 sections of the QA Manual in 1980, 6 sections in 1982, and 8 i sections in 1984 (445/8608-V-01; 446/8606-V-01).

RESPONSE TO ITEM A.1 (445/8608-V-01: 446/8606-V-01)

TV Electric agrees, in part, to the alleged violation and the requested information follows:

1. Reason For Violation B&R did not perform or document postponement of scheduled audits of some B&R ASME Manual sections in 1980. In addition, B&R did not perform or document postponement of the scheduled audit of ASME QA Manual Section 3.0

" Organization" in 1983. The reason for not performing or documenting postponement of the audit of these' manual sections could not be conclusively determined.

The B&R audit schedules for 1982 and 1984 included all ASME QA Manual J sections; however, due to audit postponements all manual section audits were not performed in the calendar year scheduled. These audits were l3 performed as follows: the B&R audit of manual sections scheduled for the  !

last quarter of 1982 was postponed and performed in January 1983 (note j that the Appendix D table incorrectly indicated that the Brown and Root )

audit CP-21 was performed in April 1983, the audit was actually performad j in January 1983) to avoid conflict with the TV Electric QA audit in 1 process at that time; the manual section audit scheduled for the last quarter of 1984 was postponed and performed in January 1985 to avoid  ;

conflict with the ASME resurvey conducted at the end of 1984. 1

' Attachment to TXX-6469 June 12, 1987 Page 2 of 7 RESPONSE TO ITEM A.1 (445/8608-V-01: 446/8606-V-01) CONT'D These postponements were documented through B&R internal QA correspondence or on the audit schedule. .The actions to postpone scheduled audits are considered to be prudent management decisions and not contrary to ASME QA Manual Section 19.0 as long as these postponements result in makeup audits being performed during the following calendar year.

2. Corrective Steos Taken And Results Achieved TV Electric QA Audit Report TBR-9, dated November 23, 1983, identified that B&R had not audited all ASME QA Manual sections annually as noted in this violation. The B&R response to the TV Electric audit dated December 8,1983, stated that an audit planning form specifically designed to ensure that the entire ASME QA Manual would be audited annually had been implemented. This audit planning form is effective, as evidenced by audits being performed as scheduled subsequent to the implementation of the form, with the exception of those audits intentionally postponed. >

.3. Corrective Steos Which Will Be Taken To Avoid Further Violations .

l Through implementation of the audit planning form described in the B&R i response to TV Electric QA Audit TBR-9, B&R has taken appropriate l preventative action. t

4. Date When Full Comoliance Will Be Achieved Full compliance has been achieved.

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E. Attachment to_TXX-6469 June 12, 1937 Page 3.of 7 1 1

1 NOTICE OF VIOLATION {

ITEM A.2.a (445/8608-V-02: 446/8606-V-02)

A. Criterion.XVIII of Appendix' B to 10 CFR Part 50, as ' implemented by TUGC0  !

Quality Assurance Plan (QAP) Section 18.0, Revision 2,' dated July 31, 1984, and FSAR, Section 17.0, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all. aspects of the quality assurance program'to determine the i effectiveness of the program, and that.they be performed in accordance j with' procedures'or checklists, and that results be documented, and-followup action, including reaudit of deficient areas, shall be taken.

b '2. Failure to Provide Adeauate Documentation to Support Imolementation of B&R Audit Proaram i

c B&R QA Manual, Section 19.0, issued September 17, 1981, requires  ;

that measures be established for an audit program that will l provide objective evidence of compliance with the QA manual; '

compliance with pertinent specifications, codes, and procedures;

, and a method of. keeping management informed of QA program effectiveness.

Contrary to the above:

a. B&R failed to provide adequate documentation in audit

l. reports CP-18 (1981), CP-21 and 24 (1983) and CP-27 (1985) and/or checklists to show that the implementation of field design change procedures and controls were audited (445/8608-V-02; 446/8606-V-02).

• RESPONSE TO ITEM A.2.a.

(445/8608-V-02: 446/8606-V-02)

TV Electric disagrees with the alleged violation for the reasons that follow:

In-each of the audit reports in question (i.e., CP-18, CP-21, CP-24 and CP-27), documentation of the audit of the implementation of design controls is provided. . While we believe the audit reports provide sufficient objective evidence that the requirements of B&R ASME QA Manual Section 19.0, " Audits",

have been met, the reports or backup documentation do not provide identification of the procedure provisions that may have been evaluated during the audit. Although we do not believe such specific identification is required, B&R has committed in the future to provide such specific documentation in the audit report or backup documentation.

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' ~ Attachment to TXX-6469~

June 12;-1987

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, NOTICE 0F VIOLATION ITEM A.2.b (445/8608-V-03: 446/8606-V-03)

' A'. Criterion XVIII of A'ppendix B to 10 CFR Part 50,-as implemented by'TUGC0 Quality Assurance Plan (QAP) Section.18.0, Revision 2, dated July 31, .

1984, and FSAR, Section 17.0, requires that a comprehensive system of planned and periodic audits shall be carried out to verify complianceLwith '

. all' aspects of the quality assurance program to determine the effectiveness of the program, and that they be performed in accordance with. procedures or checklists, and that results be documented, and followup action, including reaudit of deficient areas, shall be taken.

2. Failure to Provide Adeouate' Documentation to Support Implementation of B&R Audit Procram B&R QA Manual, Section 19.0, issued September 17, 1981, requires that measures be established for an audit program that will  :

provide objective evidence of compliance with the QA manual, i compliance with pertinent specifications, codes,.and procedures; j and a method of keeping management; informed of-QA program effectiveness.

Contrary to the above:

b. B&R failed to provide adequate documentation in audit reports CP-18 (1981) through CP-31 (1986) and/or-checklists to show that the implemantation.of special process procedures and controls were audited (445/8608-V-03; 446/8606-V-03).

RESPONSE TO ITEM A.2.b (445/8608-V-03: 446/8606-V-03)

TU Electric disagrees with the alleged violation for the reasons that follow:

Section 10.0, " Control of Special Process," of the B&R ASME QA Manual was audited during B&R audits CP-18, CP-20, CP-23, CP-27 and CP-29. In oach of these audit reports documentation of the implementation of special process controls is provided. While we believe the audit reports provide sufficient objective evidence that the requirements of B&R ASME QA Manual Section 19.0  ;

" Audits" have been met, the reports or backup documentation do not provide the '

specific identification of the procedure provisions that may have been evaluated during the audit. Although we do not believe such specific identification is required, B&R has committed to provide such specific documentation in future audit reports or backup documentation.

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" Attachment to TXX-6469 p June 12, 1987~

Page'5 of 7.~

NOTICE OF VIOLATION ITEM B (445/8608-y-ff: 446/8606-V-10)

8. Criterion'XVI o'f' Appendix B-to 10'CFR Part 50, as implemented by FSAR, Section 17.0, and TUGC0 QAP,. Section 16.0, Revision 0, dated July 1,1978, ,

requires that conditions adverse to quality be promptly identified, i reported,'and corrected.

Failure to Verify Correction of An Audit Deficiency FSAR, Section 17.1.16, states that.TUGC0 require measure. be established to assure that conditions adverse to quality are promptly identified, reported, and corrected.

'TUGC0 Procedure CQI-CS-4.6, Revision 3, dated August 8, 1982, states in part, ." Verification of implementation of corrective actions shall be accomplished by appropriate means."

Contrary to the.above, Audit Deficiency No. l' of TUGC0 QA Audit TCP-51

'(September 1982) was. improperly closed out. That is, the auditor did not verify the implementation of commitments to correct the deficiency prior to closing the audit finding. Records show that in this case TUGC0 had initiated. plans.for resolving the audit deficiency over an extended period of time, and eventually resolved the audit deficiency through review of the operation travelers (445/8608-V-08; 446/8606-V-10).

RESPONSE TO ITEM B (445/8608-V-08: 446/8606-V-10)

TV Electric disagrees with the violation for the reasons that follow:

The TV Electric QA Auditor cited the deficiency upon finding completed i travelers which'had not been reviewed by the Document Review Group (DRG) in j the Permanent Plant Records Vault (PPRV). . Subsequent TU QA followup 1 activities found that these travelers were being placed in the PPRV for their physical protection. As N-5 system and subsystem reviews were conducted, the j pertinent travelers were retrieved from the PPRV and sent to the DRG for ]

processing in accordance with procedure requirements. This sequence of j

m. actions was determined to be acceptable and did not constitute a violation of '

procedures in effect at the time.. Therefore, Deficiency No. 1 TUGCo QA Audit TCP-51-(conducted in September 1982) was determined to not constitute a

' deficient condition. However, the audit file correspondence regarding this )

J deficiency does not clearly document the basis for the resolution of the deficiency. .TU Electric Quality Assurance will supplement this audit file to clarify the resolution of the alleged deficiency.

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A'ttachment to TXX-6469

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.' June 12, 1987.

.Page'.6 of 7 NOTICE OF DEVIATION ITEM 1 (445/8608-D-07: 446/8606-D-07)

FSAR,' Section 17.1.2, commits to the establishment of an audit program in accordance with American National Standard Institute (ANSI) N45.2.12, Draft 3.0, Revision.0. Paragtaph 3.4.3 of this standard describes criteria as to when- supplemental audits are ' performed.

In deviation from~the above:

- 1. ' TUGC0 audit Procedure DQP-QA-15, Revision 0, left out the following supplemental audit criteria of paragraph 3.4.3 of the ANSI N45.2.12. .

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a. Paragraph 3~.4.3.1 requires assessment of contractor's QA program i prior to contract. award, and

b. Paragraph'3.4.3.5 requires assessment of item quality or program effectiveness, when required (445/8608-D-07; 446/8606-D-07).  :

RESPONSE TO ITEM 1 (445/8608-D-07: 446/8606-D-07)  !

'TU Electric disagrees with the alleged deviation for the reasons that follow:

The requirements'of Draft 3, Revision 0 to ANSI N45.2.12, paragraph 3.4.3.1, regarding preaward audits, is addressed in procedure DQP-VC-11, " Vendor Evaluation Methods."

The requirements of Draft 3, Revision'0 to. ANSI'N45.2.12, paragraph 3.4.3.5,

, regarding audits to assess item quality or program effectiveness,-are addressed in Procedure DQP-QA-15, "TUGCO QA Audit Program," Revision 0.

Paragraph 3.1.1 of.that procedure states:

" Audits will be conducted to verify establishment, implementation, and effectiveness of the quality assurance program." j Th'e' term " audits" as used in the above statement. refers to all types of audits, including preaward audits and supplemental audits. Therefore, the above statement encompasses the provisions of ANSI N45.2.12, paragraph 3.4.3.5. Routine audits are scheduled in accordance with Procedure DQP-AG-4, l "CPSES Construction Phase Audit Program." Additional audits are scheduled whenever deemed necessary by QA Management.

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'Altachment-to-TXX-6469 June 12,-1987 Page 7 of 7 NOTICE OF DEVIATION ITEM 2 (445/8608-D-06: 446/8606-D-06)

FSAR, Section 17.1.2, commits to the establishment of an audit program in accordance with American National Standard Institute (ANSI) N45.2.12, Draft 3.0, Revision 0. Paragraph 3.4.3 of this standard describes criteria as to when supplemental audits are performed.

In deviation from the above:

2. B&R audit Procedure CP-QAP-19.1, dated October 10, 1984, does not agree with TUGC0 Procedure DQP-QA-15 or ANSI N45.2.12 because B&R changed the commitment for supplemental audit criteria from "are performed" to "may be performed" (445/8608-D-06; 446/8606-D-06).

RESPONSE TO ITEM 2 ,

(445/8608-D-06: 446/8606-D-06)  !

TU Electric disagrees with the alleged deviation for the reasons that follow: ,

The discussion of this deviation in Inspection Report 50-445/86-08 refers to a revision to the B&R audit procedure which was issued in January 1982. That revision altered the procedure wording regarding supplemental audits from "are

-performed" to "may be performed."

Since 1978, the scope of the B&R Quality Assurance Program at CPSES has been limited to ASME erection activities and the B&R ASME Audit Program has been developed to meet the requirements of Section III of the ASME Boiler and Pressure Vessel Code. ANSI N45.2.12 is not applicable to activities covered by Section III of the ASME Boiler and Pressure Vessel Code, and therefore B&R Procedure CP-QAP-19.1 is not required to be consistent with ANSI N45.2.12.  :

While it is correct that the supplemental audit criteria contained in CP-QAP-19.1 and DQP-QA-15 do not agree, DQP-QA-15 is required to be and is consistent with ANSI N45.2.12, whereas CP-QAP-19.1 is not required to be consistent with ANSI N45.2.12. We believe the B&R ASME QA Manual provides adequate guidance l for conduct of supplemental audit activities.  ;

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