ML20199H259
| ML20199H259 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Comanche Peak |
| Issue date: | 08/24/1982 |
| From: | Donna Anderson TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML17198A302 | List:
|
| References | |
| FOIA-85-299, FOIA-85-59, FOIA-86-A-18 CQP-CS-7, NUDOCS 8607030243 | |
| Download: ML20199H259 (114) | |
Text
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'f-PROCEDURE /
TEXAS UTILfTTES GENERATING CO.
INSTRUCTION REVISION ISSUE PAGE NUMBER DATE CQP-CS-7 3
8/24/82 1 of 10 PREPARED BY: [ [ f udwA[)
F/4#fhL CORRECTIVE ACTION
' DATE APPROVED BY:
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DATE
1.0 INTRODUCTION
INFORMATiON ONLY 1.1 Purpose This procedure establishes the method by which TUGC0 QA will assure that conditions adverse to quality are promptly addressed by responsible personnel, that the proposed corrective actions are implemented in a timely manner, and that the action adequately corrects the deficiency.
1.2 Scope This procedure will be used when corrective actions to deficiencies identified during vendor and site audits are not implemented or are inadequate to correct the problem.
It also applies when evaluations of deficiencies identified by TUGC0 QA, Dallas, on a Significant Deficiency Analysis Report (SDAR) are overdue. Deficiencies identified during release inspections will be handled in accordance with Procedure CQP-VC-1, " Final Inspection and Release for TUGCO."
1.3 Definitions - None 1.4 References 1.4.1 CQP-CS-4 " Procedure to Establish and Apply a System of Pre-Award Surveys, Audits and Surveillances."
1.4. 2 CQP-VC-3 " Initiating Yellow Flag Sheets."
1.4.3 CQP-CS-6 " Reporting of Significant Deficiencies."
2.0 RESPONSIBILITIES 2.1 TUGC0 Vice President, Nuclear - will provide assistance as needed to assure that required corrective actions are promptly addressed.
2.2 Manager, Quality Assurance - has overall responsibility for assuring that deficiencies are promptly addressed and corrective actions are implemented and effective.
h 8607030243 860623 PDR FOIA GARDE 86-A-18 PDR j
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EQP-CS-7, Retf. 3 Page 2 of 10
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2.3 Supervisor, Quality Assurance Services - reviews recurring deficiencies to determine if they are significant conditions requiring immediate action, prepares Corrective Action Requests (CAR) and evaluates responses to CARS.
2.4 Audit Team Leader and/or Supervisor, QA Audits - Notifies the QAS l
Supervisor of uncorrected deficiencies or inadequate corrective actions.
Participates in evaluation and closeout of CARS.
2.5 QAS 31' ice Assistant and/or QAS Secretary - Maintains the Corrective ActIFn~ Request log and files.
3.0 PROCEDURE 3.1 Vendor Corrective Actions 3.1.1 When corrective actions to deficiencies previously identified during an audit have not been implemented or were inadequate to resolve the deficiency, the Audit Team Leader or Supervisor, QA Audits will submit the findings to the QAS Supervisor for review.
a.
This unacceptable situation may be identified through re-audit or review of Vendor Compliance Trip Reports in accordance with Reference 1.4.1.
3.1.2 The QAS Supervisor will review the facts and if he deems significant will prepare and submit a Corrective Action Request (CAR) (Example 1) to the Manager, Quality Assurance for his approval and issuance.
a.
The CAR form may confinn or impose controls and inspections appropriate to maintain the integrity of associated work activities.
b.
A response will be required within ten (10) working days.
3.1.3 If the QAS Supervisor oetennines the problem is minor, the deficiencies will be handled in accordance with standard audit follow-up procedures.
3.1.4 The CAR will be forwarded by transmittal to responsible vendor management.
a.
The letter will notify the vendor that no shipments will be allowed until the deficient items are corrected.
1.
Upon issuance of a CAR, the QAS Office Assistant or QA Secretary will initiate a yellow flag sheet in accordance with Reference 1.4.2, if applicable. This will notify l
the TUGC0 Vendor Compliance Release Inspectcrs of the Hold Status.
(Example 2).
'CQP-CS-7, Rev. 3 Page 3 of 10 b.
Standard internal distribution will be made.
3.1.5 Upon receipt of the response, the responsible Audit Team Leader and QAS Supervisor will perfonn an evaluation.
a.
If the response is unacceptable, the Manager, QA may place a stop work in effect until the situation has been satisfactorily resolved.
1.
Other actions as deemed appropriate may be initiated by the Manager, QA.
b.
If the response is acceptable, the Audit Team Leader or Supervisor, QA Audits and QAS Supervisor will sign the CAR.
l 1.
Implementation of corrective action will be verified by appropriate means prior to final closeout and sign off by the Manager Quality Assurance or his designee.
2.
Final closeout should be accomplished within 30 days.
3.2 Site Corrective Actions 3.2.1 When corrective actions to deficiencies identified during CPSES site audits have not been implemented or were inadequate to resolve the deficiency, the Audit Team Leader will discuss the finding (s) with the QAS Supervisor.
3.2.2 The QAS Supervisor will review the finding (s) and if deemed significant will prepare and submit a Corrective Action Request (CAR) to the Manager, Quality Assurance for his appproval and issuance.
(Example 1).
a.
If the finding is not considered significant, it will be handled in accordance with standard audit follow-up a
procedures.
3.2.3 The CAR form:
a.
May confinn or impose controls and restrictions appropriate to maintain the integrity of associated work activities.
b.
Will require a response within 5 days.
3.2.4 The CAR will be forwarced by memo to the responsible site manager.
(Example 3) a.
A copy will be transmitted to the next level of management requesting involvement in order to provide an expeditious resolution.
CQP-CS-7, Rev. 3 Page 4 of 10
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1.
If unable to hand deliver immediately, the CAR and transmittal memo should be telecopied to the responsible site manager.
b.
The TUGC0 Vice President, Nuclear will receive a copy.
3.2.5 Upon receipt of the response, the responsible Audit Team Leader and QAS Supervisor will. perfonn an evaluation.
a.
If the response is unacceptable, the Manager, QA may place a stop work in effect until the situation is satisfactorily resolved.
1.
Other actions as deemed appropriate may be initiated by the Manager, QA.
b.
If the response is acceptable, the Audit Team Leader and QAS l
Supervisor will sign the CAR.
1.
Upon acceptance of the response, an evaluation letter shall be forwarded to the responsible site manager (example 5).
2.
Implementation of corrective actions will be verified by appropriate means prior to final closecut and sign-off by the Manager, Quality Assurance or his designee.
3.
Closecut should be accomplished within 30 days.
3.3 CAR Log and Records 3.3.1 The QAS Office Assistant or QA Secretary will maintain a log of CAR's issued.
It should contain the following information:
a.
CAR #
b.
Date issued c.
Responsible Auditor d.
Assigned to e.
Response due date f.
Response received date-g.
Response accepted h.
Implementation verified 1.
Final closeout date
_ TQP-CS-7, Rev. 3 Page 5 of 10 3.3.2 A copy of the open CAR will be placed in the CAR file, a.
When the CAR has been closed, one copy will be placed in the audit file, if applicable, and one copy plus any supporting documentation will be placed in the closed CAR file.
3.4 Dallas Originated Significant Deficiency Analysis Report (SDAR) 3.4.1 SDAR's are generated in accordance with reference 1.4.3 requiring that a report be submitted to the NRC within 30 days. An engineering analysis will be requested from appropriate personnel by the Manager, Quality Assurance.
3.4.2 If the analysis has not been received within the required time frame, the TUGC0 Vice President, Nuclear will issue a memo (Example 4) requesting immediate action. The memo will be telecopied to the appropriate level of management.
3.4.3 When the analysis is received and accepted, it will be submitted in accordance with reference 1.4.3.
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- P-CS-7, Rev. 3 Page b of 10 CORRECTIVE ACTION DE00EST (CAD)
E/AMPLI 1
CA), #
Date:
2,esponse due Assigned to:
/
Name Title SU3 JECT:
INADEQUATE CORRECTIVE ACTION
- . Jescriotion of Oricinal Deficiency: (Audit / Surveillance #
/ Deficiency #
)
Jescriotion of Corrective Action Commitments:
(Ref: Response letter #
)
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Jetails of Present Condition of Deficiency:
Jescriotion of Restrictions / Holds Acolied:
1 Audi tor Date
/
/
Date QAS Supervisor a
Manager, Quality Assurance Date I:. Jetails of Procosed Corrective Action:
(To filled in by Responsible Site /Mgr. Vendor)
Imolementation Date:
/
Responsible Site / Mgr. Vendor Date I:.l Response Acceptable: Yes No
/
Auditor /Date QAS Supervisor /Date Implementation of Corrective Action Verified:
(Ref: Audit / Surveillance #
)
/
CAR Closed:
Manager, Quality Assurance Date
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CQP-CS-7, Rev. 3 Page 7 of 10 EXAMPLE 2 YELLOW FLAG SHEET
{
DATE:
March 27, 1981 P. O. NUMBER:
CP-605 INITIATOR:
D. Anderson-MESSAGE:
No releases are to be made on the above order until audit deficiencies have been closed.
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.CQP-C,5-7, Rev. 3 Page 8 of 10 EXAMPLE 3 OFFICE MEMOR ANDUM (Responsible Site Manager) famancha Paak steam r1.ctric <+a+4nn Subject TUGCo Corrective Action Request CAR No.
Audit No.
Attached is a copy of TUGCo CAR No.
which is transmitted to you for imediate action.
Please complete Part II of the attached form and return it by (five days)
By copy of this memo to we request your (next level of management) involvement in providing an expeditious resolution of the cited deficiency.
Should you have any questions, please contact (QAS Supervisor) or me.
D. N. Chapman Manager, Quality Assurance DNC/
/
cc:
(1) TUGCo Vice President, Nuclear (2) kapropriate management as referenced in letter a
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TEXAS UTILITIES GENERATING CO. IPANY Pags 9 of 10 T
LQP-CS-7 Rev. 3 EXAMPLE 4 OFFICE MEMOR ANDUM To Dallas, Texas Subject Comanche Peak Steam Electric Station Request for Imediate Action REF:
QTN-
, dated File:
SDAR-
, CP-The referenced letter is a request for an engineering evaluation of SDAR-
,CP-to be prepared and submitted to the Manager, Quality Assurance by (date)
This evaluation is yet to be received.
Please take the necessary actions to assure that the evaluation is sub-mitted imediately. Any further delay will result in an overdue response to the liuclear Regulatory Comission.
B. R. Clements BRC/DNC:
cc:
As Apolicable:
Appropriate Management e
' b':S A7 - Rev. 3
- TEX, UTILITIES GENERATING COM NY Page 10 of ;:
E '.4,'P E 5 Q'TN-423 OFFICE' M E M OR A N DU M J. T. Merritt Dallas. Texas 8/21/81 To COMANCHE PEAK STEAM ELECTRIC STATION
- Subjee, TUGC0 CORRECTIVE ACTION REQUEST RESPONSE EVA ION CAR
. 602 QA FILE:
NO. 002-AUDIT NO. TCP-6 FOLLOW-UP -2 & 3 Your response logged CPPA-12030 dated August 19, 1980 has been evaluated and found acceptable by TUGC0 QA.
Verification of implementation of your corrective actions will be performed consistent with your commitment dates.
l Should you have any additional questions, please contact A. Vega at 214-653-4895.
n D. N. Chap an Manager. Quality Assurance DNC/A'//DLA:med cc:
B. R. Clements J. B. George em 1
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l G -juL T~C E' 5 [C Ay a QTN-586 TEh3 UTILITIES GENERATING CO31rANY OFFICE MEMOR ANDUM To R.G. Tolson Dallas,Teuu December 8,1982 Subject COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT REPORT TCP-56 PROJECT TRAINING AND NONCONFORMANCES QA AUDIT FILE: TCP-56
/
Attached is TUGCO-Qk Audit Report TCP-56 which describes the results of our audit of Project Training (QA/QC ASME, Non-ASME and Engineering personnel) and Nonconformance Administration performed on November 8-12, 1982. The audit team was composed of R.F. Cote' (Team Leader), D.Z. Hathcock, A.E. Kesler and L.J.
Rillera.
Attachment A contains an audit summary including attendees of the pre-audit and post-audit meetings, and persons contacted during the audit.
Attachment B contains five (5) deficiencies, three (3) concerns, and auditors comments identified during the audit.
Deficiencies identify conditions which violate quality assurance program requirements and require immediate corrective action. Concerns identify those conditions, which left unattended, could result in program violations in the i
future. Comments address observations by the auditors which may improve the-efficiency of the QA program but do not constitute a potential breakdown of the quality assurance program.
Please respond by January 10, 1983 to Deficiency Nos.1-4 and Concern Nos.1 and 3.
In your response, please provide the following information for each deficiency:
1.
Describe what corrective action has been, or will be taken for each deficiency.
2.
Describe your action to prevent recurrence of the deficiency.
3.
Indicatethedatethatyourcorrectiveaction,asdesNbedinitem1 above, will be implemented.
Your response to concerns should identify actions taken to prevent these conditions from escalating to deficiency status.
By copy of this memo to J.B. George, please respond to Deficiency No. 5 and Concern No. 2 by January 10, 1983.
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R.G. Tolson 8 82 12/
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Page 2 Should you have any questions, please contact R.F. Cote' at 214/653-4907.
D.N.
mn y
Manager, Quality Assurance DNC/AV/D:
RFC:brd cc:
B.R. Clements J.B. George M.R. McBay G.R. Purdy I
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ATTACHMENT A AUDIT
SUMMARY
TCP-56 e
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TUGC0 QA
TCP-56 Audit Summary Audit T_eam:
R.F. Cote' - Team Leader D.Z. Hathcock A.E. Kesler L.J. Rillera Personnel Contacted:
N. Harrelson D. Leech J. Finneran J. Ryan K. Morton E. Opelski G. Creamer P. Cox H. Harrison R. Babb L. Popplewell I. Vogelsang J. Powers S. Hunt N. Smith R. Kissinger P. Patel C. Moehlman D. Sanders D. Datsun R. Williams G. Krishaw D. Westbrook H. Deem K. Mcdonald R. Rencher R. Baker C. Manning B. Scott B. Cromeans W. Whitehead D. Lewellen C. Holiday E. Hotko M. Bever D. Schmidt B. Sever A. Lancaster W. Perry W. Mahan R. Tol son E. Dantzler Audit Scope:
To verify, by review of objective evidence that QA/QC and Engineering personnel have been indoctrinated and trained in accordance with program requirements.
Administrative Nonconformance activities were reviewed for their compliance to program requirements.
Corrective action of deficiencies identified during previous Audit TCP-36 were verified for their implementation.
The following is a list of codes, standards, CPSES Procedures and/ Instructions included in the audit:
10CFR50 Appendix B Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants ANSI N45.2-1971 Quality Assurance Program Requirements
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TUGCo QA
i TCP-56 Audit Sunnary I
ANSI N45.2.9 Requirements for Collection, Storage and lith Draft, Rev. O, 1973 Maintenance of Quality Assurance Records for Nuclear Power Plants CP-QP-17.0, Rev. C'
/
Corrective Action CP-QP-16.0, Rev. 6 Nonconformances and Deficiencies CP-QAP-16.1, Rev. 11 Control of Nonconforming Items CP-EP-16.1, Rev. 1 Processing Nonconformance Reports CP-QP-2.1, Rev. 10 Training of Inspection Personnel CP-QP-2.3, Rev. 2 Documentation Within QA/QC Personnel Qualification File I
CP-QP-2.4, Rev. 0 Nondestructive Examination Personnel Training, Qualification and Certification QI-QP-2.1-3, Rev. 6 Qualification of Electrical Inspection Personnel QI-QP-2.1-10, Rev. 2 Qualification of Non-ASME Mechanical Inspection Personnel QI-QP-2.1-15, Rev. 1 Qualification of Structural Steel Inspection Personnel CP-CPM-2.2, Rev. 0 Training of Personnel in Procedural Requirements CP-EP-2.0, Rev. 4 Indoctrination Program IE Circular No. 80-22 Confirmation of Employee Qualifications Date:
October 2, 1980 i
T i
l TUGC0 QA
TCP-56 Audit Summary i
Audit S_upn_ary_:,
-In order to maintain clarity, a summary of each audit activity is provided below:
1.
Nonconfonnance Administration: ASME/Non-ASME and Er.gineering NCR(s) were reviewed to verify their compliance to procedure requirements. Overall, j
ASME and Non-ASME programs are being implemented as required. One(1) concern and one (1) comment were identified which are further addressed in Attachment B.
2.
Indoctrination and training records of Non-ASME NDE, and Non-ASME inspectors were reviewed to verify their individual personnel file contains the appropriate documentation as required by general and specific procedures and/ instructions. Presently one (1) Non-ASME NDE individual has been certified to the required procedures. This documentation file was reviewed with no findings noted.
Non-ASME inspection personnel training files were reviewed for the attributes as described above. Four (4) deficiencies and one (1) concern were identified which are further addressed in Attachment B.
3.
Indoctrination and training records of CPSES ngineers were reviewed to verify their individual' personnel training file (s) contain the appropriate documentation as required by procedure and/ instructions. One (1) generic deficiency was identified and is further addressed in Attachment B of this report.
4.
CPSES engineers education and past employment verification records were reviewed to the extent possible. This activity was performed to assess TUGC0's position regarding IE Circular No. 80-22. Subject of the circular addresses Confirmation of Employee Qualifications. This review resulted in the following condition: Education / employment verification records of the various engineering finns including job shoppers are not necessarily available for review at CPSES. Apparently these records are maintained at the corporate office from which the individual was employed, i.e., Gibbs and Hill - NY, TUSI - Dallas, TX, Brown & Root - Houston, TX, and job shoppers from various parts of the country. Thus a comprehensive evaluation concerning audit attribute IE Circular No. 80-22 could not be performed. However, Piping Design Services (PDS) provided what records they maintain regarding this subject. An evaluation of the aforenentioned areas was performed and one (1) concern was identified and is further addressed in Attachment B of this report.
TUGCo QA t
TCP-56 Audit Summary 4.
Implementation of corrective and preventive actions of deficiencies identified in previous Audit TCP-36 were verified. This verification activity included a review of ASME mechanical inspector qualification (s),
training, education, and previous employment history verification records to assure compliance to procedure requirements. No adverse conditions were identified. All items are considered closed.
62d LL R.F. Cote
Team Leader 6
i TUGC0 QA
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ATTACHMENT B j
DEFICIENCIES AND CONCERNS TCP-56 l
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TUGC0 QA 1
a
TCP-56 Indoctrination and Training Non-ASME QA/QC Deficiency No. 1 Requirement:,
Procedure CP-QP-2.3, Rev. 2, entitled, Documentation Within QA/QC Personnel Qualification File, para 3.3.2 entitled, Formal Training Records, Section B, states in part, "... Instructors shall sign and date the attendance record, which shall include: 3) Revision number of procedure / instruction, 5) Brief content of instruction Finding:
Contrary to the above, formal training records within the Non-ASME civil, electrical, and mechanical personnel certification training files do not reflect the required revision number of the instruction and/or the required brief content of the instruction.
TCP-56 Indoctrination and Training Non-ASME QA/QC Deficiency No. 2
~.Requirement:
CPSES-CP-QP-2.1, Rev. 10, Training of Inspection Personnel, Section 3.0, Procedure, states, in part, " Personnel performing inspection should have experience in and shall have completed a technical training course and examination in their area of inspection responsibilities." Also, Section 3.7, Certification, states, in part, " Inspection personnel shall be certified by the TUGC0 site QA supervisor as being qualified to perfonn their assigned tasks.
CPSES CP-QP-2.3, Rev. 2, entitled Documentation Within QA/QC Personnel Qualification File, Section 3.2, Personnel File Format states, in part, '...
each QC technician or inspector will have in a personnel file at least the following:" Section 3.2.f., states, in part, " Certification for each QC instruction / function / activity for which individual has been certified knowledgeable."
Also, Section 3.3.1A states, in part, " Certification as specific function / activity CPSES QA/QC inspection or test personnel requires an examination or a waiver granted by the quality control supervisor per CP-QP-2.1, Training of Inspection Personnel.
CPSES, QI-QP-2.1-3, Rev. 6 entitled Qualification of Electrical Inspection and Test Personnel, Section 3.3, Training Documentation, states, in part, "In addition to the electrical general technical outline, specific quality instructions have been developed by quality engineering for each electrical inspection activity. These form the basis of information required for a particular inspection function.
Electrical QC personnel are certified in a given inspection function / activity."
Finding:
Contrary to the above requirements, inspector certification records do not reflect a certification in each given inspection function as indicated by the above references. Most Level I inspector certifications contain certification for each QC instruction / function / activity as required. But the Level 11 inspector certifications do not contain certification for each activity as described by procedure. Level 11 electrical inspectors receive a Level II certification documented as "all electrical related" which exempts them from being certified in each instruction / function / activity, but the CP-QP-2.3 does not address perfonning this type of certification. The following is a list of Level I and II inspectors whose files do not contain certifications or evidence of indoctrination and training for each instruction / function / activity:
l t
TuGC0 QA
Deficiency No. 2 - Con't.
Column 1 represents the number of procedures in which an inspector was Note:
certified knowledgeable, accordin9 to the Inspector Certification Printout.
Column 2 represents the number of procedures for which there was no objective evidence of any. indoctrination or training on file.
Electrical Inspectors:
Name SSS Level Column 1 Column 2 J. B'eck 464-42-5059 II 27 12 E. Dantzler 466-09-0587 11 27 21 B. Holmes 455-84-4223 II 27 13 R. McGaughy 466-13-4083 II 27 12 S. Vore 438-44-8640 II 27 14 W. Whitehead 425-06-6557 II 27 12 i
Non-ASME Mechanical H. Andrews 419-26-3759 I
7 4
D. Brown 152-32-1851 1
12 5
D. Chandler 452-96-3159 I
11 6
T. Ellis 114-46-6505 I
10 2
D. Fitzerandolf 156-44-0910 I
6 1
D. Gray 458-94-4303 I
10 1
DZH TUCCO QA L
TCP-56 Indoctrination and Training Non-ASME QA/QC Deficiency No. 3
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Requirement:
CPSES, QI-QP-2.1-3, Rev. 6, entitled Qualification of Electrical Inspection and Test Personnel, Section 3.5, Training Certification, states, in part,
)
" Certification in a particular inspection function will normally be for a period of three years, except that certification shall expire in one year if the individual does not perform inspections in that activity during that period."
Finding:
Contrary to the above requirenent, no comprehensive method has been established to assure that the above requirement is being implemented. The instruction QI-QP-2.1 appears to address the general requirements but does not provide assurance that inspector certifications or OJT instructor qualifications are reviewed for activity applicability on a one year basis.
DZH TUGCo QA t
TCP-56 Indoctrination and Training Non,ASME QA/QC Deficiency No. 4 Requirene,nti ANSI N45.2.9, lith Draft, Rev. O, 1/17/73, Section 3.2.1, Generation of Quality Assurance Records, states, in part, "The Quality Assurance Records submitted for retention shall be legible, completely filled out and adequately identifiable to the item involved.'
Finding:
Contrary to the above requirement, CP-QP-2.1, Rev.10, Training of Inspection Personnel, requires that all training records be maintained by the training coorcinator within the permanent vault. These records are sent to the training coordinator for retention, but are not reviewed for legibility, completeness or do not adequately identify the item involved. CP-QP-2.1 does not provide detailed instructions to perform a review to assure that training / certification records are completely filled out and adequately identify the procedures or revisions involved.
DZH TUCCo QA l
TCP-56
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Engineering Indoctrination and Training Deficiency No. 5 Requirement:
CP-EP-2.0, Rev. 4, 5/12/82, para 3.0, states, in part, "The responsible party shall maintain indoctrination and training records identified herein.
Indoctrination shall be documented per attachment 2."
Finding:
A cross-section of TUSI and B&R Engineers' Indoctrination records were reviewed
~ for conformance to CP-EP-2.0.
Key personnel were randomly selected from
" authorization memos" for each of the major disciplines, and their records were observed for required reading, completeness, proper lists, and applicable revision reviews, etc.
Contrary to the above requirement, the documented indoctrination records contained one or more of the following inconsistencies:
1.
Overall, many of the signed reading lists do not contain the latest r
requirements of Rev. 4 of the required procedure, i.e., requirement to read CP-QAP-16.1.
2.
Several personnel records depicted indcctrination of Rev. 7 and Rev. 21 of a particular procedure, when in fact, the latest change for the same was Rev.4.
3.
Several records did not reference any particular procedure or documentation, e.g., a list of names and dates were listed on a sheet of paper without any heading or reference to having read a particular procedure.
4.
Indoctrination / readings for subsequent / current revisions to initial i
procedures / instructions were not always documented or retained in the personnel file.
LJR TUGCo QA
TCP-56 Engineering Indoctrination and Traintag Concern No. 1 During review of education and work experience verifications, it was found that only the PDS (Piping Design Services) verification records were available for auditing. There is no evidence at the CPSES site to demonstrate that TUSI, Gibbs & Hill,... has verified education and work experience for their personnel assigned to the site.
Out of the six (6) personnel records made available for review, two (2) engineering personnel records did not reflect objective evidence of education verifications.
(It might be noted that these two engineers received their degrees from a foreign country.)
LJR Indoctrination and Training Non-ASME QA/QC Concern No. 2 During the review of QC inspector training and certification records, it was identified that the Comanche Peak Steam Electric Station general training outlines are not being completed as delinated by the instruction provided on the general training outline fonn.
Item 3, NRC Regulatory Guides (as assigned), Item 4 Industry Standards (as assigned) and Item 5 QA/QC procedure and instructions (as assigned) are not being assigned as the instruction would indicate, but individual signatures attesting to completing the assigned reading requirements are available. The training outline does not reflect what wa.s assigned to be read by each individual. More attention should be given to documenting the assigned reading requirements.
DZH l
TUCCo QA
TCP 56 j
Nonconformance Activities Conc'ern No. 3 P ocedure CP-QAP-16.1, Rev.11, Control of Nonconforming Items, Section 3.2.1 calls for all " Scrap" and " Return to Vendor" dispositions to be initialed by the TUSI Resident Manager. This job title has not existed for some time.
Current practice observed has engineers authorized to work on NCR's performing this function.
The following needs to be accomplished to correct this inconsistency:
1.
Determine what level of authority ne.eds to perfonn this function.
If different from current practice determine the adequacy of NCR's issued under this practice.
2.
Revise CP-QAP-16.1 to reflect the actual job level responsible for performing this function.
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TUGCo QA
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TCP-56 Nonconformance Activities Comment No. 1 N'CR-82-0090 was issued because some electrical circuit terminal block parts were not being stored properly and had not been adequately marked and identified. These items were dispositioned adequately by being removed to B storage and were properly identified. Auditors concern results from the lack of hold tags being applied to this material during the two month time period from identification to disposition.
After investigation, auditors detennined that Electrical Quality Engineering is aware of the situation and has efforts directed at precluding recurrence.
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TUCCO QA
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March 25, 1983 /
QXX-1329 Mr. John Tyler Quality Assurance Manager Weidmuller Tenninations Inc.
' 821 Southlake Boulevard Richmond, VA 23235 COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT REPORT WEIDMULLER TERMINATIONS G&H SPEC. 2323-ES-100 QA AUDIT FILE: TWT-1
Dear Mr. Tyler:
Attached is TUGC0 QA Audit Report TWT-1 which describes the results of our audit of Weidnuller Terminations, Richmond, Virginia facility, performed on February 28 - March 1,1983.
The audit team was composed of R.F. Cote' (Team Leader), and S. Davis.
Attachment A contains an audit summary including attendees of the pre-audit and post-audit meetings, and persons contacted during the audit.
Attachment B contains five (5) deficiencies and one (1) concern identified during the Ludit. Deficiencies identify conditions which violate quality assurance program requirements and require immediate corrective action.
Concerns identify those conditions, which left unattended, could result in program violations in the future.
Attachment C contains evaulation results of implementation of previous audit deficiencies. All items are considered closed.
Attachment D contains evaulation results of TUGC0 QA manual review questions.
Please respond by April 27, 1983 to each deficiency and concern identified.
In your response, please provide the following infonnation for each deficiency:
1.
Describe what corrective action has been, or will be taken for each deficiency.
2.
Decribe your action to prevent recurrence of the deficiency.
3.
Indicate the date that your corrective action, as described in item 1 above, will be implemented.
.o QXX-1329 3/25/83 Page 2 Your response to concerns should identify actions taken to prevent these conditions from escalating to deficiency status.
By copy of this letter to Mr. Dan Hicks we are notifying TUSI Procurement of your stated position with regard to 10CFR Part 21.
(See Concern No. 1.)
Should you have any questions, please contact R.-F. Cote' at 214/653-4907.
Very truly yours, il
'J.N.
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DNC 9/DLA/RFC: rd Attachment cc:
B.R. Clements R.G. Tolson J.B. George M.R. McBay R.E. Ballard M. Mil 1er D. Hicks p
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ATTACHMENT A AUDIT
SUMMARY
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TWT-1 Audit Summary Audit Team:
R.F. Cote' - Team Leader S. Davis Personnel Contacted:
J. Tyler H. Murfee Audit Scope:
1.
The audit covered an evaluation of Weidmuller Terminations' QA Program to determine compliance with the applicable requirements of 10CFR50 Appendix B and ANSI N45.2-1971.
2Property "ANSI code" (as page type) with input value "ANSI N45.2-1971.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Previous audit deficiencies identified in Brown & Root Audit No.
CPS-W-172-1 were verified for their corrective action implementation.
The following is a list of items requiring followup action:
a.
CPS-W-172-1.1 b.
CPS-W-172-1.3 c.
CPS-W-172-1.4 4
3.
Concerns which were identified during Weidmuller Terminations' QA Manual review, performed by Texas Utilities Generating Co., were reviewed in order to obtain clarification of pertinent questions identified. The following QA manual review items were reviewed:
Item 1 - Specific Contract Compliance Item 2 - 10CFR50 Appendix B, Criterion I, Program Compliance Item 3 - 10CFR50 Appendix B, Criterion VI, Document Control Item 4 - 10CFR50 Appendix B, Criterion VII, Control of Purchased Material Item 5 - 10CFR50 Appendix B, Criterion XV, Non-conforming Material 1
Item 6 - 10CFR50 Appendix B, Criterion XVI, Corrective Action Item 7 - 10CFR50 Appendix B, Criterion XVII, QA Records.
The following areas were reviewed for their documented identification and implementation:
1.
Organization 2.
Quality Assurance Program 3.
Procurement Document Control 4.
Instructions, Procedures, and Drawings 5.
Document Control TUGC0 QA i
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TWT-1 Audit Summary s
6.
Control of Purchased Material, Equipment and Services 7.
Identification and Control of Material, Parts, and Components 8.
Inspection Activities 9.
Test Control Activites
- 10. Control of Measuring and Test Equipment
- 11. Handling, Storage and Shipping 12.
Identification of Material During Manufacturing
- 13. Non-conforming Materials
- 14. Corrective Action
- 15. QA Records
- 16. Audits l
The following is a list of codes, standards and specific criteria utilized i
during the audit:
10CFR50, Appendix B Quality Assurance Program Requirements for Nuclear Power Plants. Specific criteria:
I, II, III, IV, V, VI, VII, VIII, X, XI, XII, XIII, XIV, XV, XVI, XVII, XVIII ANSI N45.2-1971 Quality Assurance Program Requirements for Nuclear Power Plants. Specific Sections:
2, 3, 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 17, 18, 19 Audit Summary:
1.
Evaluation of Weidmuller Terminations' Quality Assurance Program:
Overall, the auditors found the Quality Assurance Program currently implemented at Weidmuller Terminations provides reasonable control of the items being manufactured, based on the size of the facility and the nature of the product. However, the audit resulted in the identification of five (5) program deficiencies and one (1) concern. The deficiencies and concern are further detailed in Attachment B of this report.
2.
Verification of implementation of the previous audit conmitments were reviewed. All items are considered closed.
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TUGC0 QA
TWT-1 Audit Summary 3.
An evaluation of concerns identifieu during Weidmuller Terminations' QA Manual review performed by TUGC0 QA confirmed the conditions identified.
Details are further addressed in Attachment D of this report.
j R.F. Cote' Team Leader t
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ATTACHMENT B DEFICIENCIES AND CONCERNS TWT-1 i
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TWT-1 Deficiency No. 1 Requirement No. 1:
10CFR50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, Criterion II, Quality Assurance Program, states, in part, "... The Applicant shall establish at the earliest practical time consistent with the schedule for accomplishing the activities, a quality assurance program which couplies with the requirements of this Appendix. The Applicant shall identify the structures, systems, and components to be covered by the quality assurance program..."
Requirement No. 2:
ANSI N45.2-1971, Quality Assurance Requirements for Nuclear Power Plants, Section 2, Quality Assurance Program, states, in part, "... The program shall contain provisions to assure identification of and canpliance with requirements of pertinent ANSI and other appropriate engineering codes, standards, requirements, and practices."
"... The program shall identify the items and services to which this and other standards comply."
Requirement No. 3:
Weidmuller Teminations, Inc. Quality Assurance Program, Rev. February 18, 1981, Introduction, states, in part, "... Specific contract compliance will be achieved by the issuance of suitable supplements."
Finding:
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Contrary to the above requirements, Weidmuller Terminations' Quality Assurance Program does not address provisions which assure the identification of and compliance with the applicable appendices of 10CFR50 Appendix B or ANSI N45.2.
Furthermore, no suitable supplements have been issued to comply with specific contract requirements.
In addition, Weidmuller Terminations specifically states in the Introduction section of their current QA Manual that, "This manual and the procedures in it are not intended to provide complete canpliance with any specific requirements." Therefore, it is essential Weidmuller Terminations, Inc.
Richmond facility develoo the aforementioned suitable supplements in order to achieve contract compliance.
In the development of these supplements, the following criteria should be considered as'a minimum:
Tucto QA
TWT-1 De#iciency No. 1 1.
10CFR50 Appendix B, Quality Assurance Requirements.for Nuclear Power Plants and Fuel Reprocessing Plants.
2.
ANSI N45.2-1971, Quality Assurance Requirements for Nuclear Power Plants O
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TUGco QA
TWT-1 Deficiency No. 2 Requirement:
10CFR50 Appendix B, Criterion VI, Document Control, states, " Measures shall be established to control the issuance of documents, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents including changes are reviewed for adequacy and approved for release by authorized personnel... Changes to documents shall be reviewed and approved by the same organizations that performed the original review and a pproval."
Finding:
Contrary to the above requirement, Weidmuller Terminations' QA Program does not provide for the documented review and approval of procedures, instructions and changes thereto by authorized personnel.
Note: Reference Attachment D, "QA Manual Review Clarification Resolution Results" Item 3 for other details.
RFC 1
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10CFR50 Appendix B, Criterion XVIII, Audits, states, in part, " Audits shall be performed by appropriately trained personnel not having direct responsibilities in the area being audited..."
Finding:
Contrary to the above requirement, no training records of Weidmuller Terminations audit personnel could be provided. A review of audit reports found audits perfomed by individuals having direct responsibility for the areas audited.
RFC t
TUGC0 QA
TWT-1 Deficiency No. 4 Requirement:
Weidmuller Terminations, Inc. Richmond, Virginia Quality Assurance Program QA Manual 1/18/81 Page 17, Audits, states, " Internal audits shall be carried out at six monthly intervai t to verify that specified procedures are being performed and to determine the effectiveness of these procedures."
Finding:
Contrary to the above raquirement, a review of audit reports found these reports to be six to twelve months behind the aforemontioned schedule.
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TWT-1 Deficiency No. 5 Requirement:
ANSI N45.2-1971, Quality Assurance Requirements for Nuclear Power Plants, Section 13, Control of Measuring and Test Equipment, states, in part... "When inspection, measuring and test equipment are found to be out of calibration, an evaluation shall be made and documented of the validity of previous inspection or test results and of the acceptability of items previously inspected or tested."
Finding:
Contrary to the above requirement, Weidmuller Terminations QA Program does not provide a method of determining what items were previously inspected with equipment found out of calibration.
It should be noted that auditors recommended that the inspection instrument number be recorded on the inspection report applicable to the item involved.
RFC O
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TWT-1 Conccrn No. 1 During the course of the audit, auditors noted that the posting requirements of 10CFR21, Reporting of Defects and Noncompliance, has not been complied with by Weidmuller Terminations Richmond facility.
The auditors discussed this condition with Weidmuller Terminations' Quality Assurance Manager.
In summary, Weidmuller feels, per their legal attorney that Part 21 does not apply to the items manufactured at their facility. This position produces considerable question as to how Texas Utilities Generating Company would be notified of any noncompliance or deficiency which could affect the operation of CPSES or mitigate the consequence of a potential condition.
Reporting defects and noncompliance is a purchase order requirement as well as-a regulatory requirement.
RFC 1
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e TWT-1 Evaluation Results of Previous Audit Deficiencies No. ADR-CPS-W-172-1.1 Evaluation of Corrective Action:
Auditors verified that procurement documents contain the approximate record retention period of five (5) years.
This item is considered closed.
No. ADR-CPS-W-172-1.3 Evaluation of Corrective Action:
Auditors verified calibration is being performed in-house using gauge blocks traceable to the National Bureau of Standards.
A review of calibration procedures found instructions for servicing instruments found out of calibration.
This item is considered closed.
No. ADR-CPS-W-172-1.4 Evaluation of Corrective Action:
Auditors verified that a schedule of six monthly internal audits has been established and that checklists have been utilized in the performance of audits. This item is considered closed.
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I ATTACHMENT D TWT-1 CLARIFICATION OF WE10 MULLER TERMINATIONS' QA MANUAL REVIEW
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Enclosed in this section are the following documents:
Item 1 - TUGC0 QA Manual Review questions 1 thru 7.
Item 2 - Clarification Resolution Results of Item 1.
i TV:C0 QA
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COMMENTS TO WEIDMULLER QA MANUAL REVISION DATED SEPTEMBER 2,1981 s
Based on a review of the submitted Weidmuller QA Manuci dated September 2, 1981, the following connents are made:
1.
In the Introduction, the manual states in part, " Specific contract compliasciii wlll be achieved by the issuance of suitable supplements."
i Please confirm if any supplements have been issued for the TUGC0 purchase order. If supplement: have been issued, please forward without delay so they may be included in t.he necessary review process and possibly address some of the remaining comments.
2.
Criterion 1 of 10CFR50, Appendix B states in part, "The Applicant" (Weidmuller) shall identify... Components to be covered by the Quality Assurance Program." It is not clearly delineated within the manual if all production activities at the Richmond, VA facility are treated identically
.(i.e., under the scope of this manual) for both nuclear and non-nuclear applications. Please confirm if this is the case. If such is not the case, please provide additional infonnation as to the steps Weidmuller employs to assure production and inspection personnel are aware and positively notified that a particular order being processed is for nuclear applications.
Please provide additional information and documents as to how Weidmuller satisfies these requirements.
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3.
Criterion VI - Document Control The Weidmuller Manual does not appear to address the 10CFR50, Appendix B requirement that, " Measures shall be established to control the issuance of documents, such as: instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality.
The 10CFR50, Appendix B requirement that, "These measures shall assure that documents, including changos, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed," appears to be only addressed for the QA Manual ar.d purchase orders.
Please provide additional information as to how Weidmuller satisfies these requirements.
4.
Criterion VII - Control of Purchased Material, Equipment and Services.
One of the requirements of this 10CFR50, Appendix B Criterion is that, "These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the Contractors or Subcontractors, inspection at the contractor or i
subcontractor source...."
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The right of access to a vendors facilities is briefly addressed in Procurement Document Control, page 4 and in Appendix LI. However, no where else is the system or the method to be employed in qualifying a vendor, addressed or covered.
Please provide additional infonnation as to how Weidmuller satisfies these requirements.
5.
Criterion XV - Nonconforming Material Based on a review of Weidmuller Manual section on Nonconforming Items,
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there appears to be no written direction or guidance for a documented nonconformance system as described in the following portion of 10CFR50, Appendix B, Criterion XV: "These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to affected organizations. Nonconforming items shall be reviewed and accepted, rejected, repai.ed or reworked in accordance with l
documented procedures."
Please provide additional infonnation as to how Weidmuller satisfies these requirements.
6.
Criterion XVI - Corrective Action Based on the manual reviewed, there does not appear to be a fomalized corrective action program that addresses the requirements of this 10CFR50, j
Appendix B Criterion.
Rates and quantities of "rejecte'd items" are documented in various fonns included in Appendix L but no formal distribution or review systen is described and the manual generally appears to leave it to the inspector's prerogative to detennine if a problem is " serious to repetitive" and "to report to the Production Manager (or to Purchasing)."
Please provide additional infonnation as to how Weidmuller satisfies these requirements.
7.
Criterion XVII - Quality Assurance Records The Weidmuller QA Manual appears to only address the 10CFR50, Appendix B requirements of " inspection and records" and " record retention". Other specific requirements identified in the criterion are not addressed.
j Please provide additional infonnation as to how Weidmuller satisfies these requirements.
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TWT-1 Clarification Resolution Results Item 1:
Auditors verified that no supplements have been developed which achieve specific contract conpliance. This condition is identified in Deficiency No. 1 of Attachment B of this report.
RFC Item 2:
Auditors reviewed the assembly and control process of items manufactured at WeidmulleT Terminations.
It appears that terminations manufactured at this facility are considered shelf stock items. Therefore, no special controls are required, in that all items designated for nuclear orders are Class 1E safety-relat ed.
The Certificate of Compliance states that items manufactured at Weidmuller Terminations were manufactured in compliance with ANSI N.45.2.
This condition is of particular concern since Weidmuller Terminations QA Manual states, "The manual and procedures in it are not intended to provide complete compliance with any specific requirenents."
This condition is identified in Deficiency No.1 of Attachment B of this report.
RFC Item 3:
Auditors reviewed the document control process as stated in 10CFR50 Appendix B, Section VI, and as implemented at Weidmuller Terminations. Although no formal review and approval of quality procedures and changes thereto could be identified, auditors felt that due to the size of the facility and the limited nunter of personnel involved in utilizing these procedures that this condition was at of serious concern.
However, as Weidmuller Terminations expands their facility and more personnel are needed to implement quality, the control of these procedures as identified in 10CFR50 Appendix 8 will become necessary.
This condition was discussed with the QA Manager and mutual concerns were related.
This condition resulted in Deficiency No. 2 of Attachment B of this report.
Ivsco QA
TWT-1 Clarification Resolution Results Item 4:
Auditors reviewed the control of purchased material as implemented at Weidmuller Terminations. The control process for moldings that would be used for nuclear application requires 100% visual inspection upon receipt and a Certificate of Compliance is required from the supplier which furnishes objective evidence of quality achieved.
RFC 1
Item 5:
Auditors reviewed the control of nonconforming material as required by 10CFR50 Appendix B and its implementation at Weidmuller Terminations. Although the disposition of nonconforming items is not specifically addressed in the Weidmuller QA Manual, controls are implemented in a manner similar to the appropriate appendix of 10CFR50.
Identification of your nonconformance program should be addressed in the supplement issued to resolve Deficiency No.1 in Attachment B.
RFC Item 6:
Auditors reviewed corrective action implementation as required by 10CFR50 Appendix B and its implementation at Weidmuller Terminations. Although the corrective action review is not specifically addressed in the Weidmuller QA Manual, controls are implemented in a manner similar to the appropriate appendix of 10CFR50.
It is the auditor's opinion that based on the review of this activity, the size of the facility, nature of the item, and the direct QA involvement, that deficient conditions are controlled in a quality manner.
Identification of your corrective action program should be addressed in the supplement issued to resolve Deficiency No.1 in Attachment B.
RFC i
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TWT-1 Clarification Resolution Results Item 7:
Auditors reviewed the quality assurance records facility which appears to meet the intent of the requirements of 10CFR50 Apendix.
Auditors feel that since TUGC0 receives and maintains copies of all required documentation per specification requirements that the general requirements of 10CFR50 Appendix B, Criterion XVII, Quality Assurance Records, are being implemented at Weidmuller Terminations to the extent required.
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c QTQ-321 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM y,
R.G. Tolson Dallu, Tene May 1-10Al subject COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT REPORT TCP-66 RADIOACTIVE WASTE MANAGE!ENT SYSTEMS QA AUDIT FILE: TCP-66 Attached is TUGC0 QA Audit Report TCP-66 which describes the results of our audit of Radioactive Waste Management Systems perfonned February 7 - March 22, 1983. The audit team was composed of A.E. Kesler (Acting Team Leader), and l
R.F. Cote'.
Attachment A contains an audit summary including attendees of the pre-audit and post-audit meetings, and persons contacted during the audit.
Attachment B contains six (6) deficiencies and two (?,) concerns.
Deficiencies identify conditions which violate quality assurance program requirements and require immediate corrective action.
Concerns identify those conditions, which left unattended, could result in program violations in the future. Comments address observations by the auditors which may improve the efficiency of the program but do not consititute a potential breakdown of the quality assurance program.
Please respond by June 6,1983 to each deficiency and concern identified.
In your response, please provide the following information for each deficiency:
1.
Describe what corrective action has been, or will be taken for each deficiency.
2.
Describe your action to prevent recurrence of the deficiency.
3.
Indicate the date that your corrective action, as described in item 1 above, will be implemented.
Your response to concerns should identify actions taken to prevent these conditions from escalating to deficiency status.
Should you have any questions, please contact A.Vega at 214/653-4895.
[.N.khap n
Manager, Quality Assurance DNC/brd Attachment cc:
B.R. Clements J.B. George
. M.R. It: Bay G.R. Purdy
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ATTACHMENT A AUDIT
SUMMARY
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TCP-66 Audit Summary Audit Team:
A.E. Kesler - Acting Team Leader R.F. Cote' Personnel Contacted:
R. Tolson S. Key T. Brandt K. Fann T. Vega B. Doyle D. Anderson A. Smithey C. Laurence B. Scott B. Reed L. Stolliker R. Baker R. Harrill B. Baker Audit Scope:
Audit TCP-66 was conducted to verify adequate implementatien of the applicable requirements for construction and quality control of the Radioactive Waste Management Systems (RWMS) at CPSES.
The following documentation was utilized by auditors during the audit:
Branch Technical Position ETSB No.11-1, Rev.1 ANSI B31.1-1973, "American National Standard Power Piping" Specification 2323-MS-100 CPSES - Final Safety Analysis Report CP-QP 11.12, Rev.10 811. " Inspection -of Installation of Radioactive Waste Management Systems" CP-CPM-6.9, Rev. 2. " General Piping Procedure" Field Verification Sample consisted of the welds documented on the following inspection reports:
IR-1057 - 7 welds 0687 4 welds 0154 6 welds 1202 4 welds 1080 3 welds 1204 1 weld 1078 4 welds 0480 4 welds 0565 1 weld naco 04 1
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TCP-66 Audit Sumary Audit Summary:
TCP-66 was conducted primarily to evaluate the adequacy of the QC inspections of Radioactive Waste Management Systems (RWMS) required by Branch Technical Position ETSB No. 11-1, Rev. 1 as committed to in the FSAR Table 17-A-1.
RWMS Piping was fabricated under the requirements of ANSI B31.1-1973, American National Standard Power Piping, as is all Balance of Plant Piping, per the requirements of Specification 2323-MS-100.
The inspection of the RWMS piping is specified in TUGC0 Procedure CP-QP-11.12.
The inspection procedure requires a visual inspection and nydrostatic testing. The procedure requires the documentation of the visral inspection on an Inspection Report (IR).
The inspection procedure further requires the inspector to record the welders identification sy2ol on the IR.
The inspection procedure further requires that the hydrostatic testing be inspected by QC.
It requires that all joints, high stress areas, and exposed accessible pressurized surfaces be examined during hydro and inspected in accordance with referenced acceptance criteria.
Except as noted in the deficiencies, the visual inspection of welds and hydrostatic testing appears to be adequately implemented.
ANSI B31.1-1973 requires that welders apply their assigned symbol upon completing a weld in a manner specified by his employer (pg. 62, para 127.6).
Accordingly, Brown & Root Procedure CP-CPM 6.98, Section 3.3, Note 3 requires any craftsman welding on a pipe joint enter his welder symbol in the space provided on the Weld Filler Material Log (WFML). Although the WFML is the primary means of providing traceability between pipe joint welds and the welder (s), the welders are encouraged to stamp their identific*' ion symbol when practicable. Because of tne wall thickness of the small bore
.MS piping, stamping of welder identification was not acceptable. Rathe the welder's identification was vibro-etched.
The vibro-etching has van. led over the years on a large number of welds. The lack of welder symbols and associated improper recording of sy201s on inspection reports and discrepancies between these and the WFML constitute the majority of the audit findings.
This is further complicated by the fact that small bore RWMS piping was field-run and did not have joint nu2ers designated prior to welding activities. This resulted in welding materials having been checked out on the WFML against a specific line or composite.
The lack of weld symbols on RWMS piping was identified on NCR M-81-01680, Rev.
1 dated 1/27/82. The NCR attributed the lack of these symbols to the fact that sy2ols were vibro-etched many years prior to the inspection which through time and corrosion caused them to vanish.
The NCR dispositioned the matter "use as is" because "WFML's which have been retained by welding engineering for the referenced systems specify specific line nuders and contain the sy2ol of the welders that performed the welding."
Durirg the audit the inconsistencies with this disposition were noted and brought to the attention of responsible personnel.
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TCP-66 Audit Summary During the audit, auditors observed extensive use of this NCR to accept the lack of welder's symbols on RWMS Piping. The NCR number was printed on inspection reports so that by the use of an asterisk beside a weld nunber an inspector could identify the lack of a weld symbol as satisfactory per the disposition of this NCR.
Instances were noted where welding activities conducted subsequent to the issuance of the NCR were also accepted on the basis of the NCR.
It is recognized the RWMS piping was fabricated BOP and then became subject to Branch Technical Position ETSB No.11-1, Rev.1.
The deficiencies in Attachment B are the underlying causes for the problem defined in the summary. Deficiencies considered to be isolated incidents are so noted.
AN
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Acting Team Leader l
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ATTACHMENT B DEFICIENCIES, CONCERNS AND COMMENTS TCP-66 i
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TCP-66 Deficiency No. 1 Requirement No. 1:
ANSI B31.1-1973, American National Standard Power Piping, pg. 62, para 127.6, Qualification Records, states, in part, "... The identification symbol shall be used to identify the work performed by the welder or welding operator, and after completing a welded joint, he shall identify it as his work by applying his assigned symbol for pennanent record in a manner specified by his empl oyer."
Requirement No. 2:
Weld Procedure CP-CPM 6.9B applicable to the RWKS and/or Balance of Plant Piping, requires the craftsman welding on a joint to enter his assigned symbol in the space provided on the Weld Filler Material Log.
As a matter of general policy, the B&R welding engineering group encourages welders to the extent possible, to apply their weld symbol to the weld after completing a welding ac;ivity.
Note:
For small bore RWMS, stamping of welder symbols was not allowed because of wall thickness consideration. Rather, the use of vibro-etching was encouraged. The vibro-etching process however, is not permanent and in many cases has disappeared.
Finding:
Contrary to the above requirements, field verification review performed by the auditors identified that the following weld symbols (CFS) and (ARK) were applied adjacent to W-14 on BRP-SB-XAB-22.
The applicable inspection report recorded (CFS) as the actual welder. Auditors reviewed the associated weld filler material log (WFML) and found that welder (ARK) performed the actual welding. Further review found that welder (CFS) applied his symbol to the proposed weld joint prior to welding rather than after welding the joint, then due to shift change, welder (CFS) returned his assigned weld rods to the rod control issuance facility. Based on the sample reviewed, this appears to be an isolated incident.
RFC/AEK L
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Deficiency No. 2
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l Requirement No. 1:
ANSI H45.2-1971, Quality Assurance Requirements for Nuclear Power Plants, Section 8, Quality Assurance Records, states, "... Sufficient records shall be prepared as work is performed to furnish documentary evidence of the quality of items and of activities affecting quality. Records shall be consistent with applicable codes, standards, specifications, and contracts and shall be adequate for use in management of the program."
Requirement No. 2:
CP-QP-11.12 Rev.10, Inspection of Installation of Radioactive Waste Management Systems (RWMS), para 3.1.2, Welders Qualification, states, "The inspector shall record the welder's identification symbol on the Inspection
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Report (IR).
Finding:
Auditors performed field verification of welders' symbols on a sample of 34 welds chosen from nine inspection reports.
Fifty-six percent (56%) of the sample field verified by auditors was not accurately reflected in the applicable inspection reports, specifically:
A.
For 6 of the 34 welds, the inspection report identified "no symbol SAT per NCR M-81-01680 Rev.1."
Auditors determined that weld symbols in all six cases (100%) were on the pipe.
B.
For 13 of the 34 welds (38%) the inspection report either reflected an inaccurate weld symbol or did not reflect all of the symbols on the pi pe.
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TCP-66 Deficiency No. 3 Requirements:
Gibbs & Hill Specification 2323-MS-100, pg. 4, para 4.24.5, states, in part, "The Contractor shall maintain sufficient weld data documentation to provide a traceable trail of effort for any specific weld that will satisfy the requirements of the ASME, ANSI or AWS codes as applicable and the regulatory agenci es."
NCR M-81-01680 R.1, Disposition, dated 1/27/82 states, in part, "... The WFML's which have been retained by Welding Engineering for the referenced systems do specify the specific line number and contain the symbol of the welders that performed the welding."
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NCR-M-83-00433, Approval, Dated 3/4/83 states, in part, "... The WFML's which have been retained by Welding Engineering for the referenced systems do specify the specific line number and contain the symbol of the welders that performed the welding.
Finding:
Contrary to the above requirements, 50% of the small bore weld joint welders' symbols, field verified by auditors could.not be traced as stated above:
A.
Twenty-five percent (25%) could not be traced to a line number, cnly to the applicable composite drawing B.
Twenty-five percent (25%) could not be traced to a line number or the applicable composite drawing -
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TCP-66 Deficiency No. 4 Requirements:
M CP-QP-11.12, Rev. II, Inspection of Installation of Radioactive Waste Management Systems (RWMS), pg. 2 of 11, para 3.3.1, Visual Inspection of Welds, states, "All welds on piping shall be visually inspected to verify the following:
1.) Welds shall be free of paint and other coleterious material 2.) Arc strikes Para 3.2.2, Quality Control Pretest Inspecticn, states, in part, " Prior to commencement of testing, the Quality Control Inspector shall verify:
c.) All surfaces are free of arc strikes.
Finding:
Contrary to the above requirements, during field verification auditors and Welding Engineering identified that field weld 12 on line RWM-GH-XAB-019 which had been inspected and accepted per IR-MP-0566 and hydrostatic tested per XGH-016,12/7/82, had are strikes and tungsten inclusion in the weld.
Furthemore, weld symbol (BUP) was visible where the IR stated no weld symbol SAT per NCR-M-83-00433.
Follow thru review was perfomed in order to verify when welder (BUP) had performed the above welding. No WFML applicable to the activity performed could be located. However, auditors did determin'e that welder BUP no longer worked on site at the time of inspection, precluding the
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possibility of this welding being done after the inspection was performed.
It should be noted that after identification of this condition, Welding Engineering initiated immediate correct.ive action in accordance with site procedures. Auditors felt that the above welded condition appeared to be an isolated incident. This was based on the number of welds auditors reviewed that appeared acceptable. However, the inaccuracy of the weld symbol notation on the Inspection Report is felt to support auditors' concerns regarding the adequacy of the weld symbol inspection effort.
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10CFR50 Appendix B, Criterion XVII, Quality Assurance Records, states, in part,
" Sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include at least the following...
closely-related data such as qualifications of personnel..."
Finding:
Contrary to the above requirement, no objective evidence could be provided of the qualifications of (RWMS) Inspector S. Stogdill. Based on the sample reviewed, this appears to be an isolated incident.
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Procedure CP-QP-11.12, Inspection of Installation of Radioactive Waste Management Systems, Rev.10, dated 11/15/82, Section 3.1.4 states, in part,
" Prior to completion of this inspection, the inspector shall attach As-Built Tags (Attachment 5) to the line. These tags shall be placed at strategic locations along the line to prevent oversight by other plant personnel. Prior to performance of any work on a tagged line or its components, QC shall be notified."
Finding:
Contrary to the above requirement, welding was performed in RWM-SB-X-AB-031 by welder BHH in April of 1982. These lines had been inspected and As-Built verified in February 1982.
QC was not notified as required, therefore no additional inspection was performed.
Based on the sample reviewed, this appears to be an isolated incident.
Note: This condition was reported by auditors to Welding Engineering and QC, and steps were initiated to correct this problem during the audit.
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TCP-66 Concern No. 1 CP-QP-11.12, Rev. 10 Inspection of Installation of Radioactive Waste Management Systems (RWMS), para 3.1.10 states, in part, "All socket welds shall have at least two passes."
QC performs a final inspection and not an inprocess inspection. The verification of a two pass socket weld cannot be adequately performed without witnessing the two pass requirement. This condition resulted in a review of socket welds that were ground smooth, thus removing the physical characteristics of the two weld pass. However, the above socket welds did meet the required fillet size thickness.
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TCP-66 Concern No. 2 Inspection Report MP-0421 reflects the use of CMC-75281, Rev. O which eliminated weld 16A. The lack of this weld had been identified as UNSAT during the original inspection on 6/9/82 and then showr, to be SAT on 6/23/82 per CMC-75281, Rev. O.
However, on 6/22/82 Revision 1 of CMC-75281 was issued which re-instated weld 16A and eliminated weld 17. This did not change the condition in the field, only the weld number.
It does, however, make IR-0421 incorrectly reflect that W-16A exists and W-17 does not exist. No additional IR was ever generated and this line has undergone hydrotesting.
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TCP-66 Coment Auditors feel that the requirement for welders to apply their weld symbol to the joint welded is not only intended to provide assurance that the welder was qualified as stated in MCR M-81-01680 Rev. I but also provides the client with a method of tracing welders to specific welds or lines in the event conditions exist where either the welders work was in question or the weld rod used by a particular welder (s) should become in question.
A review of the IR and/or WFML can be utilized to assess this type of condition.
Qxx-1404 TEXAS OTILITIES GENERATING COMPANY OFFICE MEMORANDUM To Fil e Dallas, Texas A*il 90 10 R't Subject AUDIT TCP-66. RADI0 ACTIVE WASTE MANAGFMENT SYSTEMS I have just reviewed a copy of audit report TCP-66 as revised bi A. Vega. The changes reflected in this audit report are major revisions and constitute a very different representation of the Rad Waste Management System than that presented in my original report. The revised edition indicates that except for items identified in the deficiencies, the visual inspection of welds and hydrostatic testing appears to be adequately implemented. Based on the deficiencies as identified during the audit and in the original report, the indication was that the QC visual inspection of Radwaste Welding is questionable.
The validity of the IR's documenting this activity were also found to be questionable.
The revised report has reduced generic finuings to those of isolated incidents resulting in a much different representatlon of what was found during the audit.
I do not agree with these changes and feel that overall, the revised report does not reflect conditions observed.
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Al'An Kesler Acting Team Leader Audit TCP-66 AEK/brd cc:
0.N. Chapman A. Vega D.L. Anderson R.F. Cote' ep
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QTN-720 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORA DUM To J.B. George Dellu, Texas
.1une 13.19R3 Subject COMANCHE PEAK STEAM ELECTRIC STATION TUGC0 QA AUDIT NOTIFICATION TCP-76 CONSTRUCTION /QC: NON-ASME MECHANICAL JUNE 27 - JULY 1, 1983 QA AUDIT FILE:
TCP-76 This memo will serve as notification of our intent to perform an audit on June 27 - July 1,1983. The audit scope will include installation and inspection of Class V Supports and Reflective Insulation.
The audit team will consist of:
R.F. Cote' - Team Leader S. Davis L.J. Rillera
+ 1 auditor to be scheduled later We plan for the pre-audit meeting to begin on Monday, June 27, 1983 at 9:30 a.m. in the TUGCo QA Auditor's office in the Construction Administration Building.
Should you have any questions, please contact R.F. Cote' at 214/653-4907.
Manager, Quality Assurance DNC/brd cc:
B.R. Clements R.G. Tolson M.R. McBay G.R. Purdy J.T. Merritt
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TEXAS UTILITIES GENERATING COMPANY QTN-750 OFFICE MEMOR ANDUM August 17, 1983 J.T. Merritt Dana., Texa.
To COMANCHE PEAK STEAM ELECTRIC STATION Subject IUbbV QA AUUll KtVUK4 CONSTRUCTION /QC: NON-ASME MECHANICAL QA AUDIT FILE: TCP-76 This letter is in regard to the audit report transmitted to you via letter QTN-732.
In error, the response due date was omitted. The date should be September 16, 1983. The letter was sent out on August 16, 1983.
If you have any questions, please contact R.F. Cote' at 214/653-4907.
D.N.Ihapm Manager, Quality Assurance DNC/tig cc:
B.R. Clements R.G. Tolson M.R. McBay G.R. Purdy A
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, O QTN-732 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM To J.T. Merritt Dallae. Texas Atigiftt 15. l oM COMANCHE PEAK STEAM ELECTRIC STATION
- Subjee, TUGC0 QA AUDIT REPORT CONSTRUCTION /QC: NON-ASME MECHANICAL QAS AUDIT FILE: TCP-76 Attached is TUGCo QA Audit Report TCP-76 which describes the results of our audit of Construction /QC: Non-ASME Mechanical, perfomed on June 27 - July 1, 1983. The audit team was composed of R.F. Cote' (Team Leader), L.J. Rillera, S. Davis, T. Jackson, and D. Schmidt.
Attachment A contains an audit summary including attendees of the pre-audit and post-audit meetings, and persons contacted during the audit.
Attachment B contains four (4) deficiencies and four (4) concerns.
Deficiencies identify conditions which violate quality assurance program requirements and require immediate corrective action. Concerns identify those conditions, which lef t unattended, could result in program violations in the future.
Please respond by September 16, 1983 to Deficiency Nos.1, 2, and 3, and Concern Nos. 1 4 In your response, please provide the following information for each deficiency:
1.
Describe what corrective action has been, or will be taken for each deficiency.
2.
Describe your action to prevent recurrence of the deficiency.
3.
Indicate the date that your corrective action, as described in item 1 above, will be implemented.
By copy of this memo to R.G. Tolson please respond to Deficiency Nos. 3 and 4, and Concern Nos. 2 and 3 by September 1983.
Your response to concerns should identify actions taken to prevent these conditions from escalating to deficiency status.
Should you have any questions, please contact R.F. Cote' at 214/653-4907.
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D.N. Chapman Manager, Quality Assurance DNC/brd Attachment cc:
B.R. Clements R.G. Tolson M.R. McBay lh
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SUMMARY
TCP-76
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TCP-76 Audit Summary Audit Team:
R.F. Cote' - Team Leader S. Davis L.J. Rillera D. Schmidt T. Jackson Persons Contacted:
G. Bass K. Ward R. Barris J. Bagley J. Lemke J. Barrett R. Smith D. Wine A. Scoggins C. Ivey R. Langston A. Walker D. Able G. Purdy J. Kubala C. Manning B. Severs B. Darin E. Dean D. Woodyard C. Cao P. Mason C. Lawerence M. Brathaer C. Chrasher Audit Scoce:
The audit was conducted to verify the adequacy of installation and inspection of Class V supports and reflective insulation activities.
The following is a list of codes, standards and specific criteria utilized in the audit:
Codes & Standards 10CFR50 Appendix B Quality Assurance Criteria for Nuclear Power Plants. Specific Criteria utilized: Sections XI, XVII, y ANSI N45.2-1971 Quality Assurance Program Requirements for Nuclear Power Plants. Specific Criteria utilized: Sections 11, 12, 18 Procedures & Instructions QI-QP-11.16-1, Rev. 21 Installation Inspections of NNS Seismic Category II Supports for Class II Piping CP-CPM 9.17, Rev. 2 Snubber Installation 4
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TCP-76 Audit Summary CP-CPM-9.19, Rev. O Installation of Aircraft Cable for Class 5 Piping CP-QP-11.19, Rev. 3 Reflective Insulation Installation Inspection CP-QP-11.16, Rev. O Inspection of Seismic Category II Supports & Structural Steel CP-CPM-9.9, Rev. 6 NNS Seismic Category II Supports CP-CPM-6.12, Rev. O Installation, Rework, & Modification of Reflective Insulation CP-CPM-6.3, Rev. 9 Preparation, Approval & Control of Operation Travelers CP-CPM-6.10, Rev. 9 Inspected Item Removal Notice Form CP-QP-18.0, Rev. 11 Inspection Report QI-QP-11.1-66, Rev.1 Fluoride Content of Aqueous Solutions Audit Summary:
The following areas were reviewed for their implementation:
1.
Installation of materials per design documents 2.
Inspections & tests 3.
Rework of materials 4.
Removal of inspected items 5.
Inspector qualifications 6.
Welder qualifications 7.
Support documentation In order to maintain clarity, a summary of each audit activity is provided below:
Summary of Reflective Insulation Installation Activities Auditors feel that the initial installation and inspection activities associated with reflective insulation appeared to be accomplished in accordance with the p; esent procedural requirements. Two (2) deficiencies were identified with regari to the removal and replacement of reflective insulation panels that were previously inspected.
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TCP-76 Audit Summary Overall, it appears that many previously required inspection and swipe tested areas where reflective insulation was applied were subsequently removed in order to facilitate work by other crafts. The removal of the panels and the reinspection of the areas where the panels were to be re-applied was not performed in a documented procedural manner.
A total of three (3) deficiencies (Ref. Deficiency Nos.1, 2, & 3) and three (3) concerns (Ref. Concern Nos.1,2 & 3) were identified and are further addressed in Attachment B of this report.
Summary of Installation & Inspection of Class V Suoport Activities Auditors feel that overall, activities associated with the installation and inspection of Class V supports appear to be adequately implemented in accordance with design, construction and inspection documents.
Auditors field verified and reviewed ten (10) Class V, Seismic Category II Supports and their applicable support package including irs to assure proper installation and inspection documentation.
One (1) Deficiency (Ref. Def. No. 4), and one (1) Concern (Ref. Concern No. 4) were identified, and are further addressed in Attachment B of this report.
R.F. Cote' Team Leader Tucco e o
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ATTACHMENT B DEFICIENCIES, CONCERNS AND COMMENT TCP-76 1
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TCP-76 Deficiency No. 1 Requirement No. 1:
CP-CPM 6.10, Rev. 9. Inspected Item Removal Notice Form, DCN # 182, para 1.0, Introduction, states, in part, "The purpose of this procedure is to ensure that once an item has been inspected and accepted, any subsequent work on the item will be identified and documented so that the reworked item may receive the required inspections.
The use of the Inspected Item Removal Notice (IRN)... is necessary only when the rework is not identified in some other manner or is specifically required by other procedures."
Inspected Item Removal Notice Form, para 2.1, IRN Preparation, states, in part, "The IRN shall be initiated, nonnally by the responsible craft foreman, or his designee when it is detennined a previously inspected item has to be removed or partially disassembled. Only the craft responsible for the installation of the item may prepare an IRN or remove the item..."
Recuirement No. 2:
CPM 6.3, Rev. 9, Preparation, Acoroval & Control of Operation Travelers, para 3.3.1, Revision Preparation, states, "All changes, regaraless of their significance, must be documented on the traveler, indicating the operations affected, description of the change, and QA/QC's concurrence. The revision number and a description of the change will be noted below the last traveler operation, or on a continuation sheet. The item being changed shall reference the user to the described change."
Finding:
Contrary to the above requirements, construction travelers are not revised to indicate the reinstallation inspection and swipe tests of removed reflective insulation panels that were previously inspected and accepted by QC. Various travelers were reviewed that were complete (i.e., signed off by Const., QC, Chem Tech) as being installed per traveler and drawing requirements. When auditors field verified this installation they noted various panels were not in place as stated above.
In addition, no inspected Item Removal Notice Fonn (IRN) was issued by the responsible craft foreman.
(Reference Concern No. 1.)
Auditors identified numerous conditions where inspectM panels had been removed without an IRN being issued so that other crafts could perfonn rework of various sytems (e.g., piping craft). The panels were then replaced without the required approved documented steps identified on the appropriate traveler or attachment. The above method of removing and installing tested and inspected reflective installation panels without the proper reinspections and test, voids the initial inspection and swipe test acceptance.
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TCP-76 Deficiency No.1 - Con't.
It should be noted that the above condi. ion is largely due to the lack of a requirement within the installation procedure for the craft to issue an IRN prior to renoving an inspected item and the failure to comply with the appropriate traveler procedure which requires the necessary steps to be taken when deviating from the approved traveler.
The following is a list of the individuals contacted regarding the above condition:
R. Langston B. Severs R. Borris G. Purdy D. Woodyard J. Barrett C. Lawerence A. Scoggins A. Walker J. Kubala B. Darin C. Cao RFC/SD 1DGco on
l TCP-76 Deficiency No. 2 Requirement:
ANSI N45.2-1971 Section 11, Inspection, states, in part, " Tests of itens processed shall be performed for each work operation where necessary to assure quality. Where a sample is used to verify acceptability of a group of items the sampling procedure shall be based on recognized standard practice and shall provide adequate justification for sample size and selection process, i
Finding:
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Contrary to the above requirement, no sampling procedure exists for the swipe test process used to verify low chloride and fluoride concentrations on stainless steel piping surfaces prior to reflective insulation installation activities.
Personnel contacted regarding the above:
A. Scoggins, H. Williams.
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TCP-76 Deficiency No. 3 Requirement:
CP-QP-11.19, Rev. 3, Reflective Insulation Installation Inspection, para 3.4, Documentation, states, "QC shall sign and date on the construction operational t ravel e r."
Finding:
Contrary to the above requirement, QC personnel are initialing and dating the construction operational traveler.
In addition, the swipe test personnel are initialing and dating the traveler. The conbination of initials in most cases overlap one another. The overlapping of initials and dates in conjunction with markovers renders the signoff points illegible in some instances as to who has signed off at a particular step of completion.
Personnel contacted regarding the above:
A. Scoggins, H. Williams RFC i
TCP-76 Deficiency No. 4 Requirement:
A.
CP-QP-18.0, Inspection Report, Revision 11 May 19, 1983, para 3.2 Inspection Report Closeout, states, in part, "After closeout of Inspection Report, the responsible QC Discipline Supervisor shall so note in the Inspection Report Log. He shall then forward the report to the Permanent Records Vault for retention."
B.
CP-QP-18.0, Inspection Report, Revision ll, May 19, 1983, para 3.1, Inspection Report Closecut, states, in part, " Inspection Report numbers shall be assigned by the QC Discipline Supervisor."
C.
Comanche Peak Steam Electric Station Quality Assurance Plan. Section 2.0, Rev. O, 7/1/78, states, in part, "A program has been established for quality assurance indoctrina* ion and training which assures that the required level of personnel competence is achieved... in the performance of quality related activities."
Finding:
A.
Contrary to the above, one (1) Inspection Report containing an unsatisfactory attribute was found in hanger package CV-1-008-722-A65C in the Permanent Plant Records Vault. Also, an Inspection Report number was not assigned to this document.
B.
Contrary to requirement C, the Task Force clerk handling the aforementioned incorrect Inspection Report had not received QA/QC i ndoctri nation.
TJ/DS tur.co e
i TCP-76 Concern No. 1 Procedure CP-CPM 6.12, Rev. O, Installation, Rework, & Modification of Reflective Insulation, para 3.6, Rework & Modification, states, " Rework or modification of insulation which has been accepted by QC, shall be accomplished after an IRN has been prepared in accordance with CPM 6.10.
This applies to QC inspections documented on travelers which are already in the records vault or on QC checklists.
The above procedure requirement appears to be in conflict with the applicable IRN procedure (Ref. Deficiency No.1. Requirement No. 2) which specifically states that an IRN shall be initiated... when it is determined that a previously inpsected item has to be removed or partially disassembled.
Procedure CP-CPM 6.12 requires the foreman to issue an IRN after it is submitted to the vault. Since no travelers have been submitted to the vault, the procedure requirement allows the craft foreman to remove and install items that have been inspected by QC without requiring notification to QC of the above action (Ref. Deficiency No.1).
It should be noted that all travelers applicable to installation of reflective insulation have been completed to the point of final inspection and walkdown.
The inspection steps violated by removing and replacing inspected items are, (1) surface cleanlines: verification prior to installation, and (2) item swice test of material surface assuring low fluoride and chloride contamination.
RFC TUGeo GA
TCP-76 Concern No. 2 Procedure CP-QP-11.19. Rev. 3, Section 3.1.1, Pipe and Equipment Surfaces, states, "All stainless steel piping and eouipment surfaces inside the containment building shall also be swipe tested by the lab to determine the chloride and fluoride concentrations. This will be done after the surface has been cleaned and just prior to installing insulation (ensuring that the surfaces are not re-contaminated before insulation is installed).
Auditor's concern is that no specific time limit is set for perfaming installation inspection after swipe test is performed. The procedure references "just prior to."
However, auditors were infomed that weeks may pass before the inspection is performed.
SD Tucco 0A 1
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Auditors are concerned about inconsistencies found on Fonn 11.1-65 used to document the results of the analysis of the swipe test for stainless steel.
The inconsistencies identified are missing signatures for personnel perfonning the checking of analysis content and the chemistry lab supervisor. These records become a part of the traveler package transmitted as quality records.
SD I
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4 s
l TCP-76 Concern No. 4 The auditors observed a protractor used by inspection personnel, which did not have a certificate of accuracy or any other evidence that would docunsmt that the instrument meets required tolerances.
(Sears Universal Protractor.) This instrument has been used to measure vertical 3" surface sway struts to a tolerance of +20 It was discussed with the B&R calibration lab (R. Gidding) that this type instrument does not fall under the calibration program, and that Section 13 of ANSI N45.2 was applicable.
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1 TUGC0 @
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QTN-732 TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM To J.T. Merritt Dalla, Texa.
July 1983 COMANCHE PEAK STEAM ELECTRIC STATION Subject TUGC0 QA AUDIT REPORT CONSTRUCTION /QC: NON-ASME MECHANICAL QAS AUDIT FILE: TCP-76 Attached is TUGCo QA Audit Report TCP-76 which describes the results of our audit of Construction /QC: Non-ASME Mechanical, performed on June 27 - July 1, 1983. The audit team was composed of R.F. Cote' (Team Leader), L.J. Rillera, S. Davis, T. Jackson, and D. Schmidt.
Attachment A contains an audit summary including attendees of the pre-audit and post-audit meetings, and persons contacted during the audit.
AttachmentBcontainsfour(4) deficiencies /
- 4) concerns, _ J muJ.;.m a cm- ++ md d _.. 3
.uc ovu u.
Deficiencies identify conditions which violate quality assurance program requirements and require immediate corrective action.
Concerns identify those conditions, which left unattended, could result in program violations in the future.
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Please respond by August 1983 to each deficiency and concern identified.
In your response, please provide the following information for each deficiency:
1.
Describe what corrective action has been, or will be taken for each deficiency.
2.
Describe your action to prevent recurrence of the deficiency.
3.
Indicate the date that your corrective action, as described in item 1 above, will be implemented.
Your response to concerns should identify actions taken to prevent these conditions from escalating to deficiency status.
(
e TCP-76 Audit Summary Audit Team:
R.F. Cote' - Team Leader S. Davis L.J. Rillera D. Schmidt T. Jackson Persons Contacted:
G. Bass K. Ward R. Barris J. Bagley J. Lemke J. Barrett R. Smith D. Wine A. Scoggins C. Ivey R. Langston A. Walker D. Able G. Purdy J. Kubala C. Manning B. Severs B. Darin E. Dean D. Woodyard C. Cao P. Mason C. Lawra'nce M. Brathaer C. Chrasher 64--
Audit Scope:
The audit was conducted to verify the adequacy of installation and inspection of Class V supports and reflective insulation activities.
The following is a list of codes, standards and specific criteria utilized in the audit:
Codes 8 Standards 10CFR50 Appendix B Quality Assurance Criteria for Nuclear Power Plants. Specific Criteria utilized:
Sections XI, XVII, V ANSI N45.2-1971 Quality Assurance Program Requirements for Nuclear Power Plants. Specific Criteria utilized: Sections 11, 12, 18 Procedures & Instructions QI-QP-11.16-1, Rev. 21 Installation Inspections of NNS Seismic Category II Supports for Class II Piping CP-CPM 9.17, Rev. 2 Snubber Installation TUGCo QA
o TCP-76 Audit Summary CP-CPM-9.19, Rev. O Installation of Aircraft Cable for Class 5 Piping CP-QP-11.19, Rev. 3 flective Insulation Installation Inspection CP-QP-11.16, Rev. O Inspection of Seismic Category II Supports & Structural Steel CP-CPM-9.9, Rev. 6 NNS Seismic Category II Supports CP-CPM-6.12, Rev. 0 Installation, Rework, & Modification of Reflective Insulation CP-CPM-6.3, Rev. 9 Preparation, Approval & Control of Operation Travelers 66-CP-CPM-6.10, Rev. 9 Inspectseft Item Removal Notice Form CP-QP-18.0, Rev. 11 Inspection Report QI-QP-11.1-66, Rev.1 Fluoride Content of Aqueous Solutions
, Audit Summary:
The following areas were reviewed for their implementation:
1.
Installation of materials per design documents 2.
Inspections & tests 3.
Rework of materials 4.
Removal of inspected items 5.
Inspector qualifications 6.
Welder qualifications 7.
Support documentation In order to maintain clarity, a summary of each audit activity is provided below:
'l Summary of Reflective Insulation Installation Activities Auditors feel that the initial installation and inspection activities associated with reflective insulation appeared to be accomplished in accordance with the present procedurM requirements. Two (2) deficiencies were identified l with regard to the removal and replacement of reflective insulation panels that i
were previously inspected.
TUGco QA t
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M TCP-76 3c,d Audit Summary
. o'p t Overall, it appears that many previously required inspection and swipe tested areas where reflective insulation was applied,was the& removed in order to J
. _ f acilitateiother crafts. The removal of the panels and the reinspection of the s
areas where the panels were to be applied was not performed in a documented 0-I 9'. Y procedural manner.
')'
r e (3) deficiencies (Ref. Defi iency Nos.1, 2, & 3) and three (3) concerns (Ref. Concern Nos. 1,2 & 3) were identified ard are further addressed in Attachment B of this report.
Summary of Installation & Inspection of Class V Support Activities Auditors feel that overall, activities associated with the installation and inspection of Class V supports appear to be adequately implemented in j
accordance with design, construction and inspection documents.
Auditors field verified and reviewed ten (10) Class V, Seismic Category II Supports and their applicable support package including irs to assure proper installation and inspection documentation.
- p; W ~.
One (1) Deficiency ydentifiedl(Ref. Def. No. 4), one (1) Concern (Ref.
Concern No. 4) +nd Onc J)~f2ito. G. ant-; which are(furhte'r', addressed in Attachment B of this report.
~
Jtd Cd C
R. F. ' Cot e '
Team Leader
)
TCP-76 Deficiency No. 1 Requirement No. 1:
CP-CPM 6.10, Rev. 9 Inspected Item Removal Notice Form, DCN # 1&2, para.1.0, Introduction, states, in part, "The purpose of this procedure is to ensure that once an item has been inspected and accepted, any subsequent work on the item will be identified and documented so that the reworked item may receive the required ins lections.
The use of the Inspected Item Removal Notice (IRN)... is necessary only when the rework is not identified in some other manner or is specifically required by other procedures."
Inspected Item Removal Notice Form, para 2.1, IRN Preparation, states, in part, "The IRN shall be initiated, normally by the responsible craft foreman, or his designee when it is determined a previously inspected item has to be removed or partially disassembled. Only the craft responsible for the installation of the item may prepare an IRN or remove the item..."
Requirement No. 2:
CPM 6.3, Rev. 9, Preparation, Approval & Control of Operation Travelers, para.
3.3.fl, Revision Preparation, states, "All changes, regardless of their significance, must be documented on the traveler, indicating the operations affected, description of the change, and QA/QC's concurrence. The revision number and a description of the change will be noted below the last traveler operation, or on a continuation sheet. The item being changed shall reference the user tn the described change."
Finding:
Contrary to the above requirements, construction travelers are not revised to indicate the reirfstallation inspection and swipe tests of removed reflective insulation panels that were previously inspected and accepted by QC. Various travelers were reviewed that were complete (i.e., signed off by Const., QC, Chem Tech) as being installed per traveler and drawing requirements. When auditors field verified this installation they noted various panels were not in place as stated above.
In addition, no inspected Item Removal Notice Form (IRN) was issued by the responsible craft foreman.
(Reference Concern No. 1.)
Auditors identified numerous conditions where inspected panels had been removed without an IRN being issued so that other crafts could perfonn rework of various sytems (e.g., piping craft). The panels were then replaced without the required approved documented steps identified on the appropriate traveler or attachment. The above method of removing and installing tested and inspected reflective installation panels without the proper reinspections and test, voids the initial inspection and swipe test acceptance.
TUGco QA t
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TCP-76 J. - [gfW h }7/p A Deficiency No.1 - Con't.
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,.t., n? hmn m ctidw' ' t ga y
It should be noted that the above condition is largely due to the lack of G procedwal requirement for the craft to issue an IRN prior to removing an inspected item and the failure to canply with the appropriate traveler procedure which requires the necessary steps to be taken when deviating from the approved traveler.
The following is a list of the individuals contacted regarding the above condition:
R. Langston B. Severs R. Borris G. Purdy. #
D. Woodyard J. Barrett C. Lawrtnce A. Scoggins A. Walker J. Kubala B. Darin C. Cao RFC/SD 4
vusco e
TCP-76 Deficiency No. 2 Requirement:
ANSI N45.2-1971 Section 11, Inspection, states, in part, " Tests of items processed shall be performed for each work operation where necessary to assure quality. Where a sample is used to verify acceptability of a group of items the sampling procedure shall be based on recognized standard practice and shall provide adequate justification for sample size and selection process.
Finding:
Contrary to the above requirement, no-sampling procedure exists for the swipe test process used to verify low chloride and fluo-ide concentrations on stainless steel piping surfaces prior to reflective insulation installation activities, f(ote:A'Ysselectingva ditors ul at determi y
view of bjec ive e enc tnat h ptasess o us ar s to be tested is an acceptab method.
Personnel contacted regarding the above:
A. Scoggins, H. Williams.
RFC I
TCP-76 Deficiency No. 3 Requirement:
CP-QP-11.19, Rev. 3, Reflective Insulation Installation Inspection, para 3.4, Documentation, states, "QC shall sign and date on the construction operational t ravel e r."
Finding:
Contrary to the above requirement, QC personnel are initialing and dating the construction operational traveler.
In addition, the swipe test personnel are initialing and dating the traveler. The combination of initials in most cases overlap one another. The overlapping of initials and dates in conjunction with markovers renders the signoff points illegible as to who has signed off at a particular step of completion.
yq y Personnel contacted regarding the above:
A. Scoggins, H. Williams RFC t
Tur.co e
TCP-76 Deficiency No. 4 Requirement:
A.
CP-QP-18.0, Inspection Report, Revision 11, May 19,1983, para 3.2, Inspection Report Closecut, states, in part, "After closecut of Inspection Report, the responsible QC Discipline Supervisor shall so note in the Inspection Report Log. He shall then forward the report to the Permanent Records Vault for retention."
B.
CP-QP-18.0, Inspection Report, Revision 11, May 19, 1983, para 3.1, Inspection Report Closecut, states, in part, " Inspection Report numbers
)
shall be assigned by the QC Discipline Supervisor."
C.
Comanche Peak Steam Electric Station Quality Assurance Plan, Section 2.0, Rev. O, 7/1/78, states, in part, "A program has been established for qualitgassurance indoctrination and training which assures that the
~c requried'Jevel of personnel competence is achieved... in the performance 7%11ty related activities."
Finding:
A.
Contrary to the above, one (1) Inspection Report containing an unsatisfactory attribute was found in hanger package CV-1-008-722-A65C in the Permanent Plant Records Vault. Also, an Inspection Report number was not assigned to this document.
B.
Contrary to requirement C, the Task Force clerk handling the aforementioned incorrect Inspection Report had not received QA/QC indoctrination.
TJ/DS
i TCP-76 Concern No. 1 Procedure CP-CPM 6.12, Rev. O, Installation, Rework, & Modification of AetTERivDJasulation, para 3.6, Rework & Modification, states, " Rework or C_modHwation of insulation which has been accepted by QC, shall be accomplished after an IRN has been prepared in accordance with CPM 6.10.
This applies to QC inspections documented on travelers which are already in the records vault or on QC checklists.
The above procedure requirement appears to be in conflict with the applicable IRN procedure (Ref. Deficiency No.1, Requirement No. 2) which specifically states that an IRN shall be initiated... when it is determined that a previously inpsected item has to be removed or partially disassembled.
Procedure CP-CPM 6.12 requires the foreman to issue an IRN after it is submitted to the vault.
Since no travelers have been submitted to the vault, the procedure requirement allows the craft foreman to remove and install items that have been inspected by QC without requiring notification to QC of the above action (Ref. Deficiency No.1).
It should be noted that all travelers applicable to installation of reflective insulation have been completed to the point of final inspection and walkdown.
The inspection steps violated by removing and replacing inspected items are, (1) surface cleanliness verification prior to installation, and (2) item swipe test of material surface assuring low fluoride and chloride contamination.
RFC TUGco 04 t
TCP-76 Concern No. 4 ANSI N45.2-1971, QA Program Requirements for Nuclear Power Plants, Section 13, Control of Measuring and Test Equipment, states, in part, " Measures shall be established and documented to assure that tools, gages, instruments, and other inspection, measuring, and testing equipment and devices used in activities affecting quality are of the prop.er range, type,.g.and accuracy to verify conformance to established requirements..."
Contrary to the above, the auditors observed an uncalibrated protractor used by inspection personnel.
(Sears Universal Protractor.) This instrument has been used to measure vertical 3" surface sway struts to a tolerance of 120 It was discussed with the B&R calibration lab (R. Gidding) that this type instrument does not fall under the calibration program, and that Section 13 of ANSI N45.2 was.pst. applicable.
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TCP-76
[
Comment Class V support CH-1-12-001-C66R appeared to ntain a w!1d discontinuity at the skewed fillet (lap,'or overlap indicati n). This i ication was brought to the attention of both the inspection and cr ft p rsonne who felt that this item was acceptable and disagreed with the audito s' o servations a
LR
&> x Tusco QA
Form Date:
9/82
'.( 0,
TUGC0 QA AUDIT PLAN VENDOR / ORGANIZATION:
Comanche Peak Steam Electric Station AUDIT NO.:
TCP-76 AUDIT DATE:
June 27 - July 1, 1983 AUDIT SCOPE:
verification of installation and inspection of Class V supports and reflective insulation APPLICABLE CODES & STANDARDS:
10CFR50 Accendix B. ANSI N45.2-1971 REFERENCE DOCUMENTS:
01-OP-11.16-1. Rev. 21 : CP-CPM 9.17, Rev. 2; CP-CPM 9.19. Rev. 0: CP-0P-11.19. Rev. 3:
CP-0P-11.1. Rev. O PROJECTED SAMPLING PLAN:
Review accroximately ten (10) completed reflective insulation pkgs. and verify field conformance.
Rcview approximately ten (10) CAT II ennnnets Snr Class V oicing eer their reouired installation and inspection criteria PREVIOUS AUDIT (S) APPLICABLE TO THIS SCOPE:
None I
OPEN ITEM (S) REQUIRING FOLLOW-UP:
None AUDIT SCHEDULE: Pro-Audit Monting - 6/13/83 - 9:30 a.m.
Audit Post-Audit Meeting - 7/1/83 - 2:00 p.m.
CHECKLIST AND/0R PROCEDURES: ATTACHED (CHECKLIST CONSISTS OF 12 PAGES)
Audit Plan and Checklist Prepared by:
..' _ote 6/15/83 Audit Team Leader Date Audit Plan and Checklist Approved by:
D.L. Anderson d/f 13 Audit Group Supervisor Date ~
DISTRIBUTION:
D. L. Anderson (Orig.)
Audit File Team Members:
L.J. Rillera
+ 1 to be assigned S. Davis
0 g
o TEXAS UTILITIES GENERATING COMPANY OFFICE MEMORANDUM To Ron Cote' Danae, Texas
.ir m o 17 - tor 1 subject TCP-76 CHECKLIST I've reviewed your checklist with the following comments:
Attachment A - General need to specifically address:
Review of drawings including all current applicable design changes to
- 1) assure as-built configuration matches drawing requirements, and
- 2) inspection ducuments are traceable to document (i.e., ref. DCA #,
CMC #, and rev. used).
Pg.1, item C - only hangers which can be field verified should be reviewed.
Pg. 3, items 10 & 12 - NRC has itentified problems in these two areas so you should pay close attention during field review.
Attachment B - No comments.
Attachment C - pg.1, item 1 - will this be verified by witnessing inspection or just by review of records? Should try to witness if work is ongoing.
Pg. 4, para 3 try to review unsat IR's that have been returned and closed out.
The checklist looks quite comprehensive overall and should provide good coverage of activities. On your audit plan, the sample should be increased to 10 each.
If you can use another person, I can get additional support from Startup Surveillance. Please let me know ASAP so that I can call C. Welch.
Any questions, please let me know.
D.L. Anderson DLA/brd
f CHECKLIST - TCP-76 Pa93 1
Of 4
l ATTACHMENT A - INSTALLATION INSPECTIONS OF NNS SEISMIC CATEGORY II SUPPORTS FOR CLASS V PIPING CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE,'_
QI-QP-II.16-1 Rev. 21 INSTALLATION INSPECTIONS OF NNS SEISMIC CATEGORY II SUPPORTS FOR CLASS V PIPING Scape:
A.
Verify by review of objective evidence th:t hangers observed in the field are traceable to the applicable const.
documents and inspection documents.
R;f. Attachment (B).
lS. V:rify that the above hangers have i
been installed and inspected per Ref.
Attachment (B) and the following inspection attributes.
L Note: Field verification should be l
performed wherever practical. When j
fic1d verification is not practical the QC insp. report will suffice.
1.
See attached memo for audit emphasis.
' ara 2.2 Check hanger materials for compliance tith bill of materials.
' ara 2.2 Verify support dimensions comply with dwg/ instruction.
cra 3.2.1 Verify weld area is clear of scale, gresse, etc.
i
CHECKLIST - TCP-76 Page cf 4 2
~
ATTACHMENT A - INSTALLATION INSPECTIONS OF NNS SEISMIC CATEGORY II SUPPORTS FOR CLASS V PIPING CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE Para 3.1.2 4.
Verify fit-up.* per dwg/WPS.
Pcra 3.2.1 5.
V;rify weld is free of slag, undercut, porosity.
iPara 3.1.2 6.
Verify weld as per drawing.
Para 3.7.1 7.
Verify support level and plunb CPera 3.7 3
Verify. location is per drawing.
.9.
Verify that weld is properly identified with the welder's symbol tnd that welder is qualified.
Sara 3.8
.).
Sway Struts "Where Applicable"
> ara 3.8.1.1 & 3.91
- . Verify spherical alignment / condition Sara 3.7.2.'3.10 L Verify correct location and orientation tra 3.8.2, (3.11.2E) 8.
Verify thread upset
~-_.
=
l CHECKLIST -TCP-76 Page 3 cf 4 ATTACHMENT A - INSTALLATION INSPECTIONS OF NSS SEISMIC CATEGORY II SUPPORTS FOR CLASS V PIPING CHECitLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE 3.
Prra 3.3.3 - Pipe Clearances 1
i Verify that pipe claarances are installed per the referenced section i
of this procedure.
- 10. Prra 3.4 - Sway Struts If sway struts are applicable, verify that they have been installed in accordance with the design document
]
provided in the associated package.
.1. Para 3.5 - Shims Where shims are utilized verify that one of the following materials is tsed:
A.
SA-36 or A-36 8.
SA-515, Grades 55, 60 or 65 C.
A-570
- 2. Para 3.6 - Threaded Nuts Verify U-bolts have been installed on the side plate as shown on the design drawing.
- 3. Prra 3.7 - Installation of Aircraft Cable T
V;rify that aircraft where applicable has been installed in accordance with
}
CPM 9.19 and the design information i
provided in the hanger package.
Note: See provided procedure.
1 CHECKLIST - TCP-76 Page 4 cf 4
~
ATTACHMENT A - INSTALLATION INSPECTIONS OF NSS SEISMIC CATEGORY II SUPPORTS FOR CLASS V PIPING CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE l
l!. Verify that restraint conforms to DCA l
No. 15741.
l R;f. Attachment (B) ques.13.
l B.
Verify the inspector has verified and documented the following:
l A.
Location and orientation as shown en design B.
Stainless steel cable angle in relationship to the axis.
Note: Consult DCA for specifics C.
Verify that weld restraints have been inspected per para 3.2.2 D.
Verify that hardware has been installed per DCA 15741.
E.
Verify that cable is not frayed.
F.
Cable ends are wrapped to prevent fraying.
G.
Stainless steel cable end loops cre bent smooth without any deformation.
H.
Stainless steel cable is of proper size.
i I.
Verify sufficient slack exists in the cable.
CHECKLIST - TCP-76 Page I cf 4 ATTACHMENT B - NNS SEISMIC CATEGORY II SUPPORTS
- i CHECKLIST ITEMS EVIDENCE OBSERVED EVAtuATION OF EVIDENCE I
CP-CPM 9.9 Rev. 6 NN5 SEISMIC CATEGORY II SUPPORTS Ref. CP-CPM 9.17 Rev. 2 CP-CPM 9.19. Rev. O trify hangers have been identified, fabricated and installed per the above l3rocedure.
1.
Para 3.1 Hanger Packages Verify that the hanger that is under r; view was fabricated and installed ir acc rdance with the applicable hanger k
P g.
Prra 3.1 V;rify that the above hanger pkg.
includes the following documents:
A.
BRH Drawing 8.
Weld Filler Material Log (WFML)
C.
Applicable DCA's Para 3.1 V;rify weld numbers have been assigned to welds in the following categories:
- 1. Full' penetration welds 2.
Welds requiring NDE other than usual 3.
Welds to pressure retaining members I
l
CHECKLIST - TCP-76 Page 2 cf 4 ATTACHMENT B - NNS SEISMIC CATEGORY II SUPPORTS CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE 1.
Para 3.2 V;rify welders symbols correlate with applicable WFML and that welders were qualified to perfonn the associated welding.
- i. Para 3.2.3 V;rify that final weld surfaces and adjacent base metal blend uniformly.
Note: Verify weld build-up is not exceeded.
i i. Para 3.2.8 - Workmanship Verify the weld surface is free of the following:
A.
Slag B.
Cracks C.
Overlaps D.
Undercut in excess of 1/32" in depth
'. Para 3.3.1 - Dead Weight Supports V~rify that dead weight supports plus cr minus 12 inches axially, and plushness plus or minus 2 degrees.
- . Para 3.3.2(b) - Seismic Restraints i
Verify all supports are plumb and level within the performance of the calibrated tool used.
Note:
Except where restricted. See procedure for details:
CHECKLIST - TCP-76 Page 3
ef 4 ATTACHMENT B - NNS SEISMIC CATEGORY II SUPPORTS e
CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE
).
Para 3.3.3 - Pipe Clearances V;rify that pipe clearances are
~
itstalled per the referenced section of this procedure.
l LO. Para 3.4 - Sway Struts If sway struts are applicable, verify j
that they have been installed in l
acc:rdance with the design document j
provided in the associated package.
.1. Para 3.5 - Shims Where shims are utilized verify that one of the following materials is used:
A.
SA-36 or A-36 8.
SA-515 Grades 55, 60 or 65 i
C.
A-570 i
- 2. Para 3.6 - Threaded Nuts Verify U-bolts have been installed on the side plate as shown on the design drawing.
- 3. Para 3.7 - Installation of Aircraft table f
ca sL*
I V;rify that aircraft where applicable has been installed in accordance with CPM 9.19 and the design information i
provided in the hanger package.
Note: See provided procedure.
CHECKLIST - TCP-76 Page 4 Cf
.1 ATTACHMENT B - NNS SEISMIC CATEGORY II SUPPORTS CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE I
- 13. Para 3.8.1 L QC Inspection Verify by review of objective evidenc e that the following activities l
cssociated with QC hanger inspection hr.v2 been performed.
a.
Fit-up inspection of full penetration welds is perfonned by QC b.
Verify that an NDE report is issued l
c.
Verify the above fonn is complete <
by the appropriate inspector and then returned to the craft.
l d.
Is the above document contained ir the hanger pkg.
l o.
Verify the above inspector is quali fied.
l t
---_ _ - _~_
CHECKLIST Page I cf 4
ATTACHMENT C - REFLECTIVE INSULATION INSTALLATION INSPECTION CHECELIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE 4
I CP-QP-11.19 Rev. 3 REFLECTIVE INSULATION INSTALLATION INSPECTION Ref. G4H Spec. MS-31 Verify by review of objective evidence that installation inspection activities are performed per spec. A procedure requirement.
, 1.
Verify the following inspections are being performed " Prior to installing itsulation."
1 Sara 3.1.1 A.
All stainless steel piping and equip. surfaces are free of particulate contaminates and organic film.
B.
When surfaces require cleaning verify that they are rinsed with Grade "A" water.
C.
Verify that a swipe test is perfonned on stainless material inside containment prior to irstallation of material.
D.
Verify that carbon steel surfaces 3
are free of oil, loose scale and other foreip materials.
E.
Verify the above tests are documented on the IR i
Note: Verify the IR addresses the panels inspected, e.g.. panel numbers.
CHECKLIST Page _2__ cf 4 5
ATTACHMENT C - REFLECTIVE INSULATION INSTALLATION INSPECTION t
CHECKLIST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE i
Para 3.2 2.
VISUAL INSPECTION AFTER INSTALLATION Verify that the following attributes have been reviewed:
A.
Verify stainless steel rivets, when used, do not exceed 2" center to center.
8.
Spot weld, when used to
" Reassemble" insulation, do not exceed 2" center to center.
C.
Verify that when screws are used that a star washer is inserted.
D.
Verify that all gaps are covered.
E.
Verify that cuts to flashing are neat.
Para 3.2 F.
Verify that accidental dents in outer cases are not more than 1/3" deep.
Note: See walk down pkg. if applicable.
G.
Verify that only mirror material is used, i.e., buckles, handles (original equip.).
H.
Verify that all units should be identified with mirror supplied
" stick on numbers."
Verify that if a unit is subdived in 2 of more sections, that the above ID numbers are used.
l CHECKLIST ATTACHMENT C - REFLECTIVE INSULATION INSTALLATION INSPECTION EVALUATION OF EVIDENCE CHECEIST ITEMS EVIDENCE OBSERVED I
Verify 'that the IR identifies the item and inspector.
Ref. CP-QP-18.0 J.
Verify inspectors qualifications Paro 3.3 FINAL WALKDOWN INSPECTION 1.
Verify that after installation a final walkdown is performed to detennine acceptability of any dents.
- 10. Verify that the above walkdown is performed jointly by Engineering and the vendor.
Paro 3.4 DOCUENTATION Verify the following documentation l
pkgs. are available and contain the appropriate infonnation:
1.
Prior to installation inspection cctivities. QC shall sign and date on the Construction Traveler.
2.
C1canliness ins ection of reflective p
insulation pieces which is performed on a monitoring bases,... shall be documented on an Inspection Report (IR) the identification numbers of the panels inspected shall be recorded on the IR.
1.
Final walkdown inspection shall be documented an an IR.
.=_- _ _ _ _ - _ _. -.
CHECKl.IST Page 4 cf 4 ATTACHMENT C - REFLECTIVE INSULATION INSTALLATION INSPECTION T-CHECut.IST ITEMS EVIDENCE OBSERVED EVALUATION OF EVIDENCE I
'P ra 3.4 DOCUMENTATION derify that unsatisfactory IR's are
- processed in accordance with this para, e.g., the IR, the traveler and support pkc (drawings design changes, etc.) shall be l transmitted to const. for rework.
lP:ra 3.5 lWNCONFORMANCES derify that non-conforming conditions are properly identified.
ilef. CP-QP-16.0 l
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ff UNITED STATES NUCLEAR REGULATORY COMMISSION y
g 7, c-W ASHINGTON. D. C. 20555 kv+....f January 23, 1985
/
MEMORANDUM FOR:
Vincent S. Noonan, Project Director for Comanche Peak Division of Licensing Office of Nuclear Reactor Regulation FROM:
Gary G. Zech, Chief Vendor Program Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement
SUBJECT:
ALLEGATION CONCERNING VENDORS USED AT COMANCHE PEAK In response to your memorandum dated December 7, 1984,,VPB inspections were performed at Litton-Veam, located in Watertown, Connecticut, on January 7-8, 1985, and at Weidmuller Terminations, located in Richmond, Virginia, on January 9-11, 1985.
The inspection at Litton-Veam determined that since July 1981, this vendor has had a documented QA program and implementing procedures which address and meet all the requirements of the 18 criteria of Appendix B to 10 CFR Part 50 and all the requirements of ANSI N45.2.
Prior to July 1981, the Veam QA program consisted of a QC manual containing statements of quality assurance and ten (10) QA process procedures. The manual and procedures addressed Mil-Standards MIL-I-45208 (for inspection), MIL-C-45662 (for calibration) and MIL-Q-9858 (for the quality program) but did not meet the requirements of Appendix B to 10 CFR 50. Veam manufactures 1E electrical multipin cylindrical metalshell connectors for cables which have been furnished for Comanche Peak.
The inspection at Weidmuller determined that the first edition of their QA program manual (dated 1980) addressed ten (10)' of. the 18 criteria of Appendix B to 10 CFR Part 50 and included appropriate' implementing procedures.
In February 1981, the QA manual was revised to address all 18 criteria of Appendix B.
Portions of the QA manual were further revised in November 1983.
As it stands, this QA manual addresses all of the requirements of Appendix B to 10 CFR Part 50 and the requirements of ANSI N45.2. Weidmuller Terminations Inc. manufactures 1E qualified electrical termination blocks which have been furnished for Comanche Peak.
In summary, the allegations have been at least partially substantiated in that some programmatic aspects of both Quality Ass ~urance programs were deficient in that they failed to meet all the requiremer,te of 10 CFR Part 50 Appendix B.
However, in both cases there was documented evidence of the existence of a Quality Control program during the time in question indicating that QC inspections were performed.
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Vincent S. Noonan January 23, 1985 i
The inspections will be documented in Inspection Reports No. 99900896/85-01 and t
No. 99900897/85-01 for Yeam and Weidmuller, respectively. Copies of these i
reports will be sent to you for reference as soon as they are issued. Should i
you have any) questions with regard to these inspections, please contact Mr.
P..
E.
Oiler (24638..
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,i Gary C ech, Chief Vendor Program Branch Division of Quality Assurance, Safeguards, i
j and Inspection Programs Office of Inspection and Enforcement l
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cc:
F. Fox R. Stark
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