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Docket Nos.: 50-445
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and 50-446 MEMORANDUM FOR: Vincent S. Noonan, Director for Comanche Peak Division of Licensing Office of Nuclear Reactor Regulation FROM:
Charles Trammell, Manager for Comanche Peak Project Division of Licensing Office of Nuclear Reactor Regulation
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SUBJECT:
SSER NO. 11 FOR COMANCHE PEAK TECHNICAL REVIEWTEAM(TRT) i Enclosed for your review and approval is SER Supplement No.11, which includes l
r the TRT's evaluation and resolution of approximately 125 technical concerns and allegations relating specifically to quality assurance and quality centrol 1
issues regarding construction practices at the Comanche Peak facility.
The SSER print date is May 30, 1985. If you have no further coments we are prepared to issue this SSER.
Charles Tramell, Manager l
for Comanche Peak Project Olvision of Licensing Office of Nuclear Reactor Regulation
Enclosures:
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SSER No. 11 DISTRIBUTION:
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Approval:
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Allegation Category:. Miscellaneous 13, Welding of Pipe Supports in L
,. Safeguards Tunnel
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Allegation Number: 'AM-18
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Characterization: It is alleged that the tube steel used to fabricate supports by welding it to baseplates in the Unit 1 safeguards "796 yard tunnel" was cut at the wrong angle,. resulting in too large a gap between i, -
the tube and baseplate.
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Assessment of Safety Stanificance: The NRC Technical Review Team (TRT) visually observed the entire "796 yard tunnel" to determine how many sup-j ports were used, and found there were several hundred tube-steel-to-baseplate j
weldsents/ installations.
A member of the TRT also attempted to contact 1
the alleger to obtain additional information to determine the approximate i
location, size, and configuration of the subject tube-steel-to-baseplate weldments,'because without this information indiscriminate destructive test-ing of the installed supports would be necessary in order to identify the 7
i location of the alleged gap. However, the alleger refused to communicate with the TRT.
The TRT visually observed the "796 yard tunnel" to identify any condition that would show improper installation or welding on the 796-foot, 6-inch elevation, and the three, short 800-foot-elevation tunnels.
Subsequently, the TRT randomly selected typical pipe supports and five hanger inspection reports (DD-1-16-025-Y33R,DD-1-16-024-Y33R,SI-1-031-041-532K, SW-1-17-716-Y33K, and AF-1-002-033-Y33K) and reviewed them to determine if the documentation of the inspections required during installation was cor-rect. The inspection reports indicated that the supports were correctly installed in accordance with Brown & Root procedures CP-CPM-6.9E, " Pipe Fabrication and Installation," Revision 7; CP-CPM-6.9F, " Fabrication and Installation of Component Supports," Revision 0; and CP-CPM-7.1G, " Piping C
Supports," Revision 0.
The TRT requested that a Brown & Root inspector take copies of the inspec-tion reports for the five pipe hangers to the field and repeat those steps i
in the inspection which could be repeated; however, no root gaps could be inspected because all welding had been completed.
Inspection included dimensional checks, measurement of welds, checks for proper anchoring, and visual inspection of welds. The TRT found no major discrepancies between the inspection reports and the field conditions. The recheck of the five inspection packages also showed that the as-installed and as-inspected conditions agreed, which indicated that both workmanship and inspection on the five hangers were adequate. Most of the rework required by the non-conformance reports (NCRs) found in the inspection packages consisted of filling in undersized fillet welds, although some rework was initiated by design change authorization (DCA).
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i The TRT learned that from July to September 1984, the NRC Region IV (RIV)
. inspectors reviewed a portion of the Unit 1 auxiliary feedwater system while performing inspection 50-445/84-26. The RIV inspectors paid specific dttention to two water lines which were connected to the condensate water l
storage tank (CP-AFATCS-01) and were located in the safeguards tunnel.
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They also inspected the pipe support in this area to the "as-built" vendor-i certified drawing (VCD), and included critical dimensions of support members, 2 i
weld size and type, support location, clearances, baseplates, workmanship, t
anchor bolt type.and placement in their inspection. The RIV inspectors 4,
also reviewed the document package for the support.
1 The RIV Inspectors inspected the following 10-inch supply line
.(AF-1-01-152-3) pipe supports / restraints identified on BRHL-AF-1-YD-002, y
and found no deficiencies or deviations, q
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AF-1-001-020-Y33R Wall-mounted, single snubber i
AF-1-001-021-Y33K Floor-mounted, double snubber 9
!3 AF-1-001-025-Y33R Wall-mounted, rigid strut 2
AF-1-001-028-Y43K Wall-mounted, double snubber
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AF-1-001-030-Y33R Ceiling-mounted, double strut AF-1-001-036-Y33R Wall-mounted, single strut-
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The RIV inspectors also examined the 8-inch return line (AF-1-035-152-3)
,r to the condensate water storage tank and the following pipe supports /
J restraints, which are identified on BRHL-AF-1-YD-001, and found no
)jJ deficiencies or deviations.
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AF-1-035-001-Y33R Wall-or ceiling-mounted seismic pipe restraint
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AF-1-035-003-Y33R Wall-or ceiling-mounted seismic pipe support
- g:M AF-1-035-032-Y33R Wall-mounted seismic sway strut 19 AF-1-035-034-Y33R Wall-mounted seismic sway strut n
AF-1-035-035-Y33K Wall-mounted double seismic snubber
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AF-1-035-037-Y33R Wall-mounted seismic sway strut 5$:
The TRT determined that the RIV inspection identified no deficiencies such
,g as those described by the alleger.
13 In assessing this allegation, the TRT attempted to inspect the alleged 31 i deficient weld root gaps. The primary responsibility for a broader and j j more in-depth inspection of hangers belonged to other TRT Groups and, as e
described above, to the Region IV report.
S N d The TRT and a B own & Root inspector went to the Unit 2 Safeguards Building
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tunnel and observed work in progress. Most of the piping had been installed, and approximately 12 pipe fitters were installing permanent hangers
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and snubbers on the tube steel.
Fitups befc.re welding appeared tight (less j
than 1/16-inch), straight, and uniform. The TRT observed no deficient if Q; fitups on the diagonal runs of the tube steel as described by the alleger.
p; Those findings are based on the technical assessment performed by the P
ib 11scellaneous Group; some of these findings appear to differ from those n i, i l ff y 5.
Conclusion and Staff Positions: The TRT was unable to identify any p?
improper fitups or gaps related to installed tube to baseplate weld-2 i
' T ments. The workmanship concerning the subject supports. appeared to be l.!
T }pt, good. Accordingly, this allegation has neither safety significance nor generic implications.
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I May 29,1985
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f Qsl </. ens Peter B. Bloch, Chairman n4m T s'c 7 M -
i Administrative Judge M
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Atomic Safety and..lconsing Board Ic
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U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i
Dr. Wsiter H. Jordan
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881 W. Outer Drive Oak Ridge, Tennessee 37830 g
Dr. Kenneth A. McCollom pjg.anla g.,..-/-f C,
Administrative Judge V "
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Dean, Division of Engineering, j
Architecture and Techr. ology Oklahoma State University hy h.e of og_, ~
Stillwater, Oklahoma 74078 j
Re: In the Matter of Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Units 1 and 2)
Docket Nos. 50-445-1 and 50-446-1 Supplementation of Applicants' Response to CASE's Request for Production l
Dear Administrative Judges:
1 This is to notify you and all parties to the above dockets that Applicants have identified a document which.we believe to be within the scope of item 10 of CASE's Interrogatories and Requests to Produce dated July 7,1980, as clarified on August 4,1980. Applicants submitted their response to item 10 on September 8, 1980 and supplemented their response by letters dated December 22,1980,. March 5,1982, and April 19, 1982. The document, a copy of which is enclosed with this t
letter, is a report prepared in May of 1978 by Management Analysis Company (MAC) following a management review and audit of the quality assurance program of the Comanche Peak Project.
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May 29,1985 I
Page Two Recently, in gathering data for a a
Ing performed for TUEC, a search was made by TUGCO personnel or inactive and closed corporate files located in TUGCO's Dallas office.
In the course of such search, the enclosed s
report was found. A memorandum dated July 11, 1978, which details TUGCO resolutions to the findings and recommendations made by MAC, is also enclosed.
TUGCO management is evaluating the failur.e to produce this document at an.
earlier time and will advise the Board and parties of the results of this ev'aluation in the near future.
Respectfully submitted, a
Robert A. Wooldridge
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Counsel for Applicants i
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Enclosures i
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Service List i
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!.., h Management Analysis Company 11100 Roseue St San Diego. CA 92121 714/4s2 13s1 y
May T7,,1978 1
7 MAC-JPJ-471 I
1 Mr. Perry Brittain l
President Texas Utilities Generating Company
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200T Bryan Tower
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Dallas,TI 75201 4
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Dear Mr. Brittain:
j Enciosed is the report of the Management Quality Assurance Audit conducted 4
j for Texas Utflities Generating Company.
i The audit disclosed that,. in general, the Quality Assurance activities were f
effective, that there is good team spirit between TUGCO/TUSI onnel. and the Architect / Engineer and the i
These de ene es are ident n
dit Report as Appendix A.. The audit aTso identified areas. of potentiaTTy, improved practice. These are identified as 0bservations and Recommendations and Appendix B'to this letter. As you know,. MAC participated' in an audit of the Comanche Peak site and significant improvement is noted since that audit.
t Management Analysis Company received full cooperation from ali personnel con-
' l tacted during the audit, TUGC0/TUSI, Brown & Root, and. Gibbs & Hill. Thest 5
i general openness of personnel and their frank discussion not only enhanced the conduct of the audit,. but exemplifies an attitude conducive to correction of any deficiencies, i
We appreciate the opportunity to be of service to Texas. Uttiities Generating 4
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Company and Texas Utilities Services,. Inc. and hope ta do so irr the future.
1 If there are any comments or questions regarding this work, please contact
- j Mr. J. ft. Norris or me at (7T4) 452-T39T.
l Sincerity,{.gJ
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John-P'. Jackson j
prinefpa.1 Partner JPJ:bew j'
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Enclosures:
Appendix A V
Appendix B
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APPENDIX A.
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M MLITIE1 GENERATINE COMPANY jl j
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AUDIT REPORT i
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Subject:
Audit of Texas UtfTities Generating Company, DaiTas Offices and Comanche Peak Steant ETectric Station Construction Site L
Date of Audit:
May T-TZ,,19fE i
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! l Audit Scope:
A management audit was conducted of the Quality Assurance-Progrant of Texas Utilities. Generating Company during the.
weeks of May T and:May 5,. T978. The purpose of the audit was to detersafris the adoquacy of the QuaTity Assurance Program as reTated to: NucTear Regulatory Consafssfon require-
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ments and the effectiveness of impTementation to.1neet progras requirements and authorfty delegations. Activities were audited at both: the TUGCU offices in DaTTas and at the Comanche Peak constructiotr site. Activities of the Architect /
Engineer and Constructor were audited onTy at the construction site. The scope of the audtt incTuded conerf tments made in the PSAR, the CoEporate Quaifty Assurance Manuai. the Comanche Peak Quality Assurance PTan,, the Project Precedures Manuai and. the Brown & Root QuaTity Assurance Manuais and Procedures reTated to: the Comanche Peak stte.
Auditors:
DalTas offfce,,May T-3',,T97E f
J:. P. Jackson, MAC Audit Teanr Leader j
J. M. Norris,, MAC Auditor I
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Comanche Peak Constructfort Site,, May & & f,, May S-TZ,197&
J. P. Jackson., MAC Audit Teant Leader i
J. M. Norrfs,, MAC Auditor J. A. Hendron,, MAC Auditor (May 6-12 onTy)
PersonneT MAME COMPANY' TITLE 1
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D. N. Chapmarr TUGCU QA Manager, *-1-2 t
R. G. Tolsort TUGCQ Mgr, Site Surveillance. *-1-2
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R'. Y. FTeck TUGCD/G&W Cfy. Inspec. Supv.
- -1 J. V. Hawkins-TUGCO/ Gal +
Prod. Assurance (QA),. *-1
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TUGCO AUDIT REPORT "
Personnel NAME COMPANY TITLE
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J. B. George TUSI Prof. General Mgr., *-T-2 g
f J. T. Marrit TUSI Resident Manager, *-1 E. G. Gibson -
TUSI Project Engineer, *-1-2 BL J. Murray TUSI Engineering Supv.., *-T l
J J. Moorhead G8H Resident Engineer, *-1-2
- -I R. Mann B&R QA Records Coordinator,.
- ij If_ O'. Kirktand B&R Prof. Generai Mge,. *-T II., D'. Dougiaz
' B&R Project Manager, *-T D. C. Frankun B&R Asst. Profect Mgr.
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P. FoscoTo BAR Prof. Chief Engineer, *-T i
L Hancock B&R Mat'T Procurement, Con-s.truction Branch, *-T A. Boren TUGCD Vendor Compifance
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C. Beggs TUGCC Systems. CompTfance, *-I-Z l
R. Gary-TUGCQ Y.P.
Operations, *-1 t.. Ffker TUSI V.P".
Desfgn & Procurement, *-1 P. Brittain TUGCD/TUSI President,.1 -
Interview l
T Pre-audit meeting:
Z Post audit meeting a
Audit Method:
The audit was conducted through a series of interviews with responsible management and supervision and examination of quaTity Assurance manuals, procedures, records and work operations both at the DaiTas headquarters of Texas UtfTities l
Generating Company and Texas Utilities Servicer, Incorporated and at the Comanche Peak construction site.
! Q Summary:
The, audit disciosed that recent changes. in authority dele-gations had been genera 1Ty weit accepted and that morale i
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p Sunnary (Cont'd): and team spirit were good. Howver y
d the f
nche Peak Quality Assurance Plan. The audit also disciosed that present practices in the control ofM y
other instances it was evident that J
Except for e areas noted..herefrt and below,. there was generally good
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adherence te existing procedures.
Findings:
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s of TUGCG Quality Assurance per-sonnet'are
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to Browrt & Root and te Gibbs & Hili as defined. in the PSAR and Comanche Peak QuaTity Assurance Plan.
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StailarTy the-Quality Assurance-PTarr and Procedures are l
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M to the Architect / Engineer and the Constructor,.
in addressing a11 X
i eighteen criterfa of 10CFR50 Appendix 8.
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t weTT fdentified plan of reorganization and-X j
h There needs te be a plan for revising the Quality Assur-i ance Program;. such a plan should include the establishment of art architecture of procedures to show-how other TUSI/
.i TUGCG and contractor manuais inter-relate with the Quality Assurance Manuar. The TUGC0 QA Manager should establistr a schedule arid assign responsibilities. for completion of the necessary procedures. The s X
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' TUGC0 AUDIT REPORT,
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w Findings:
provides a s.ignificant risk of design error and
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I A systes for expediting and documenting Gibbs'ilill home office-approvais. should be established using teTephone, telecopier or telex as a means of speeding __I communicatiore.
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The Comenche Peak Quality Assurance Plan
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except for site originated procurementr. Such a review fs identiffed in 10CFR5G Appendix E, Criterion IV' and is a requirement of ANSI N45.2'.13. It should be required
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on aIT. safety related procurements.
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4 The current connination of Chapter 17 of the PSAR, the TUGCQ Corporate Quality Assurance ManuaT, the Comanche f
9 Peak Quality Assurance Pian, Profect Procedures and b
Brown s Root Manuals, and Procedures provides aM Alich is difficult to maintain ll current and consistent.
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The current s
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, placing an
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in attempting to detennine i
applicable drawings and. specifications. and applicable i
g revisions thereto.
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DC DDAs are not 'noted in inspection documentation.
including all applicable c
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__._m TUGC0 AUDlT REPORT g Findings:
DC DDAs. and completed documentation must reflect the (Cont'd) status of the appTicabTe changes.
6.
- SpeciaT_,
mv The circle and
)f arrow used for such mariting is sometimes incomplete i
and not recognizable-for its intended purpose.
In one
'g instance only a; portion of the circle resembling the l
Tetter "C" was. discernibTe. FaiTure to pro'perly maric thesETocators now wfIT cause delay and possible error whers in-service inspections are made in highTy
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ftradiated areas.
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concrete,. was recentTy fssued.whic!rM g j
Tf d,. thus,. vioTates
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reguTatory. requirements irt this regard.
.N lg The nonconformance jI controi system should be the meand for maintaining in-
]f spector integrity, identifying problem areas and provide 3
a driving; force for their correction.
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The records storage facility does not currentTy have any 3
means of internaI fire protectiert during hours it is unmanned,. although it is understood some method is j
pTanned.~
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l but are maintained in fireproof file cabinets in a tra ler under the cognizance of Browrr & Root training coordinator.
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Approximat ts[
Combining Central,
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Sta ts,. site audits and site survei-11ance activities g
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. TUGC0 AUDIT REPORT,,
t Findings:
by TUGC0 and by Brown & Root into a single, cohesive (Cont'd) program wouTd: provide improved visibility to the overall' audit and surve11Tance effort and permit evaluation and J
ajustment to the audit schedule ter attainable and yet f
effective frequencies.
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I APPENDIX B TEXAE UTILITIEI GENERATING COMPANY t
OBSERVATIONS AND REcomENDATIONS 1,
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l TUGCG AUDIT OBSERVATIONS AND RECDM1ENDATIONS O
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0aGAuraT10s A.
General
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l TUGC0 Quality Assurance has undergone considerabie reorganization in the y
past year. The general thrust of this effort has been the assumption of j
greater direct involvement in the management and supervision of the Comanche Peak' Quality Assurance Program. It is. to be noted that important shifts in responsibility were being made at the time-of MACs review."
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As e part of this assessment, MAC evaluate <i the reactions of key managers, t
supervisors and inspectors ter the overaIT changes that have taken piace to date.
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It was. generally observed that those interviewed thought that with few exceptions the changes were for the better. There appeared to be a team effort on the part of QA and Constructfon wf th excellent TUSr. executive management and project management support of the QA programr. There was ne noticeabTe probTem: witir organizationaI prefudice brought about by the organizational interwixing of iUSr,. Brown & Root or Gibbs. & Hiti work forces. and supervision.
B.
Organization i
ji During the course of the audit MAC discussed the value of a revised organizational structure with the TUGCQ Quality Assurance Manager and the Manager, Site Survei1Tance. -
i
,wherab nd j
j n Exhibit T.
j ch an organizatTo~n wiTT better supplement the existing Construction i
organization and wit 1 perinit better organfzation for handTing day-to-day site problems as well as implementing recommendations of this report.
This. fs particularTy so in the area of inspection planning.
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TUGCO' OBSERVATIONS & RECOMMENDATIONS C.
QuaTity Surveillance Comittee ATT minutes of meetings of the QSC since its inception were reviewed.
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It. is noted that the QSC was established as a mechanism for providing top 711GC0 management with a' periodic update on such matters as "scheduies.
and miTestones" or " audits and corrective actions".
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j, It was noted that recent meetings dealt with tracking on the statys of. 7 1
action ttems as set forth in the Outstanding Surevillanet Report Items j
or-the QuaTity Assurance Items"of Concern Report.
In such. instances it #'
.;. g appeared the Quality Surveillance Comittee was. taking on the role of a task force or probTem solving. group..The problem that exists if the QSC 7
assumes sucfr a rote is th'at probTems would tend to awaft the three month 1
meeting; cycTe before the necessary management attention is effected.
It is reconnended that TUGCQ re-evaluate the charter of the' QSC and seri consideration given as to its value to; the project recognizing that:
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The prima c
j intainingynagementaawrenessofQuaifty U,
Assurance status might be accomplished more efficiently, effectively i
and on a more timely basi D
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Quaiffication of Personnel 4./dd5 MAC reviewed the qualifications of ali TUGCO/TUSI and Gibbs & Hill W es.
i Quality Assurance personnel and many of the Brown 8. Root personnel.
It was. observed that most of the TUGCO/TUSI Quality Ass ersonne a
l Although the project has provi d valuable experiencei it is rec-
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omonded that any in Qualit Assurahce be filled with
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with l
p Such experience added to the existing staff will serve TUGCD/TUSI weTT in accomplishing the important
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" ' TUGCQ OBSERVATIONS & RECatNEN0ATIONS 3'-
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piping, electrical and startup activities. ahead.
,)g MAC had occasion. throughout the audit to assess the quaTifications an
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a experience of 20-30 fnspectors throughout the construction site. These
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observations are worth mentioning:
1.
The inspectors are generall d with many having h
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as in inspection.
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- 2. There was arr obvious to work with the novice inspectors on a day-to-day basis.
3.
is piaced on the inspectors with respect to of inspection planning g of and j
ase for performance of
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II.
QUACITY ASSURANCE PROGRAM' The Quality Assurance Progrant is deffned in three basic documents:
P The Corporate Qualf ty Assurance Manual C)) apter 17 of the PSAR
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The Comanche Peak QuaTity Assurance Plan
/
ince there g iSP n0 -
since d 1
4*
'i I f
ak,. TUGCC shouTd consider discontinuance of the 5
araor t " #" t ##t== *a r-r ata r ar=3 ct= ta ~"4c" ** is== b-j appIfed. If a: Corporate Manual is required at a Tatar date, a new one could be prepared based ort Comanche. Peak experience and the requirements lg of any new projects to which it wouTd be applied.
1 p
The Comanche Peak
- p p gh.en ieenti,iee in m
,,pendix e.
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9 TUGC04BSERVATIONS & REC 0teENDATIONS.l g...
t I.
O ors aiz tioa Design Control Procurement Administration Inspectiorf Nonconfonnance ControT f._
l Document ControT 4
i, Records Audits
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With the expanded responsibil.tties of the TUGCO' QuaTity Assurance Depart-ment,tb o
1 reflect the crea on and functions o e Procurement Departnent and to be consistent wftfr the authority deiegations and functions stt1T resting' I
II with Gibbs & Hili and witfr Browr & Root.
Th or ort and development and a schedule and for their completion, incTuding-a compTete archfte re of' Quality Assurance procedures,. project procedures
~
The M effort shouTd be te minimize the number of pro ures. required and to eTiminate dupTfcating or overlapping procedures through consolidation of detafT and joint approvais of the organizations. involved.
It is recommended l
that the QuaTity Assurance Manager use his organization as, the driving force to achieve required procedural coverage on schedule.
l It was noted that TUGCG is pTanning orr obtaining its own Code manual The stated reasort for this was the fear that Browrr & Root would not achieve Code acceptance. The auditors feel that the Browrr i Root manual would be acceptabTe ts the Code Survey Teant and that its weTd practices. as exempli-
]
uaT+ %===?a Te. The auditors are of the opinion that obtaining a Code Stamp wtIT be difficult where all the work of impTementing the progrant is perfonned by others.
III.
DESIGN CONTROL T
e ges by referring design. changes approvai
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'..,TtJGC0 OBSERVATIONS & RECONMENDATIONS
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.O e ta Sat ae or iocraso Aaa aatx a aar =< A that field changes be subject to dest conmensurate with those exercised on the original desi n.
3[
, thus the design engineer nts may rece ved j
after the specific construction work is complete resulting in possible 5
loss of design integrity what has been done, or possible extens.ive '
{
repairs.
It.is recomnended that a system for expediting. review and l
approval by the~ originaT designer be established on al'i' safety reTated j
changes using teTephone,. teTecogier or teiex as necessary to coordinate and document change approvais.
l IV.
PROCUREMENT DOCUMENT CONTR0i.
2 0
Except for site procureme 4
(
TPris fs. contrary to of r.
I pendix B',. Criterforr IV" and' ANSI N45.7.TI, " Quality Assurance Requirements for ContreT of Procurement....."'. There is a review of pro-curement documents by Quality Assurance during Design Review, but is was asce'tained that this was a review of the drawings and specifications r
and not the purchase order or contract.
I Procurement document review by Quality Assurance should assure that alI i
necessary requirements for access. to the supptfer's facilities are provided and that necessary controis and documentation have been specified and
.l that the appropriate configuration has. been define'd. The review should j
arise assure that mquirements imposed are appropriate to the procurement j
and that there are no excessive requirements for quality program develop-j ment or for the delivery of unnecessary documentation. Some of the pro-curement packages reviewd appeared ta have both blanket. requirements for j
Qualit'y Assurance programs and excessive requirements for documentation.
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'TUGC0 OBSERVATIONS & RECOMMENDATIONS V.
INSTRUCTIONS
'S
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-R In the case te _ inspection-l plann ng the inspector filis out a simple pour card tta.ched
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Concrete Placement Checklist, a Reinforefng Steel, ETectrical, Mee5anical
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and Embedded Item Placement Checklist and a Stainless Steel Liner Checklist,.
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I the combination of which.
pour.
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ttempting. to detennine h
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appTicabTe drawings, specifications, appTicable revisions and y
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applicable DC D'OA?s. Muchr of this input should be prbvided by
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cTericai support under the direction and subsequent approvat of l
t quaTfty engineer Inspectors estimated that 45-70% of their time is spent on docu-
~
mentqiort rather thart physical inspectionr activity. Welt thought.
1 out pTanning could de much to alleviate this situation.
lI Traceability It was observed that Comanche Peak has established a program of unrecessary material traceability which, based on one estimate, consumes.
'l l at Taast a three-mart Tevet of effort and perhaps as high as a six man Tevet of effort if one considers aTT the support functions required to-
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implement the program. ATT anchor bolts and 8 series cadweTds are j
fully traceable to heat numbers such that through an elaborate and j
of fdantifying eactr embedded anchor bolti,. B series cadweids and other extensive system of mapping: aTT instalTations, the capability exists.
standard embeds to its heat number. There exists no such NRC or industry requirement for this degree of traceabiTity.
It is inter-esting to note that rebar does not require traceability on Comanche Peak (and shouTdn't), MAC knows. of no other project that imposes this require-
' TUGCD OBSERVATIONS 8. REC 0 m EN0ATIONS
- }
ment and could not fdentify a Comanche Peak specification or procedure requiring it. Accordingly, it is reconnended that this practice be g
dropped innediately. Such a move wouTd enhance inspector morale-as E
those involved are aware that the practice serves no useful purpose.
I C.
Procedure-Simo11fication
.j Newly established procedural systems are such that Construction and j
.QuaTity Assurance issue procedures on similar subject matter jointly 7
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i" for example,, the recentTy issued procedure. on shop travelers was.
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j fofntTy prepared by Construction and Quality Assurance. It is recom-mended.that Qu Similarly, those procedures related. ta piping and q
eTecer should be revised and fointTy issued as a single Comanche
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Peak procedure.
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D.
Procedures. Tndeoendent of' Houston '
The present systant of obtaining Browrt & Root,, Houston office approvai L
on construction procedures shouId be modiffed. Guidelines shouTd be 3
worked out witfr the Houston office whereby they approve only top levet k~
procedures,. permitting the site fuTT flexibility in revising detailed site procedures. Perhaps the Brown & Root,. Houston office could retain approval authority on those top Tevel documents that estabTish Brown &
Root policy controT the necessary type of forms,. etc. However,.
l detailed operating procedures should be changed with site approval onTy.
Perhaps the Houston office wouTd agree te a retroactive review procedure8 '5 l
Conffa (tion Contrer N
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i, d.
It was noted that the inspectors record the particular drawing s
number and revision letter O
f TUGC0 OBSERVATIONS & RECOMENDATIONS -
Q F.
Preplanning of Construction Work In discussions with construction management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for a d'etailed material takeoff on ali Gibbs & Hill drawings which provider detailed instructions to the crafts as to -the civil, mechanical and electricaT items to be included in each segment i
of work. This fonnalized approach of taking material takeoffs in the office and providing this information to the field forces on an approWd
~
materiaT takeoff Tist wfli dormuch te. improve the quaTity of the work.
Since the materieT takeoff is a format process accomplished by construction j
engineers welt in advance of the woric it provides a significant measure
,i of propianning,, incTuding the processing of necessary design changes to accomplish the work. Such an: effort will do much to minimize field. errors with respect to. Taft out embedments or inability to complete work as a.
p, recognized as part of the' system-and will de much to assure that Gibbs &
l; Hili drawings. are forwarded tc.- the site on. a timeTy basis to accomplish 1
this preplanning: effort.
i VI.
DOCUMENT CONTROL L
While there appeared to be some probTems with bringing the Automatic l;
. Records Management System on Tine,. the manual system backing it up 3
VII.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES y
t up to. date-in regard to TUGCO's.
0 M TUGCQ has developed a progrant for rating supplier perform-
-- r- --
ance and shows evidence of actions when reatings are unsatisfactory.
L
,h The ifst of suppliers requiring evaluation and source surveillance is not kept up to date by the Architect / Engineer. The-list in use is over i
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'TUGCO'0BSERVATIONS&RECOMMENbATIONS
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four months old, but caintained manuaT1y by the TUGC0 Supervisor of.
[ Supplier Compliance.
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' prior to shi cured items.
o er irr determining what changes have been dentified and incorporated. Thus,. it is conceivabTe that items wilt be-
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shipped ta the site that do not meet the desired configuratiert everr
[j g thougtr requirements of the purchasing document have been met. Sucir j
receipts can cause delays and unwarranted costs frr meeting the proper i
configuration d
It is recommended that a-practice be estabitshed of identifying and confirming required configuratiert prior to procurement and prior to shipment of purchased materfats and components.
,1I l
VIII.
IDENTIFICATION AND' CONTROL OF MATERIALS, PARTS ANU COMP 0NENTS
~
k No deficiency noted. MateriaT reviewed irt the warehouse,. in opert
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storage and in the weld shopr appeared to be adequately identified.
II k5 IX.
SPECIAL PROCESSES t
l A.
Radiography Irfdfum 192 is being used as the radiatierr source for all radiography l
at the site. This isotope has its optimum capability at about 1.5 inch
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thickness of steeT
]l It is permitted for Tesser thicknesses wherr the use of other radiatforr sources fr not practicat and whert resoTutiort of the outline and 4T hoTe q
size of the penetrameter can be demonstrated. The energy leveis of f
fridium isotopes are higher thart optimunr for wateria'is.375 inches or g
thinner, resulting in a flat image and Tack of contrast.
Because exposure 3
4 a
time relates to distance, the isotope is normally placed against the pipe opposite the film.. With a.100. inctr, source size, this causes 1 i
g of the image. Lack of W
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' TUGC0 OBSERVATIONS & RECOMMENDATIONS
-TO-g.
I 1
The use o irid urir meets the minimurrr requirements of the Code, b by not providing optimum fdentification of observed p
anomolies it does three undesirable things. First it causes unnecessary removal and repair of indications that can be seen but not procerly 1
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identified; secondly n be detrimental to servfee life; thirdly,
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oss not provide art adequate base line for in-servi'ce inspections-
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]j performed. after the plant has. gone inta operatfort. FaiTure te have cTear identification of the originaT' indications at that pofnt carr cause deTays j
the cost of whicfr greatTy exceeds the cost of providing. better identiff-cation and necessary repair of defects, found in the construction-phase.
i f
Recomendation - It is recomended that TUGC0 require x-ray for shop welds.,
and consider its use wnere practical for construction weTds.
X-ray machines irt the range of thirty pounds of weight are availabrie and are nearly as. portabTe as the,' isotope Because of its smatter-focai spot
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j size andi variable voitage,. x-ray cart gfve superior radiography.
The
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feedbacic of infonnatfort to. welders can improve the quaTity of welds and j
minimize the potentfal' for defects. The abiTity to dis M.Wete betweert indications having roundness or sharpness at the ends can eliminate repair.
f The ability to positively identify in the constructiert phase those indi-cations which have a potential for growth and faiTure can permit economical repair without radiation hazards. that are inherent if found later in the f
operating phase.
j B.
Weidinq
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No causes for concern and ne procedurai noncompitances were found. irr review of the weld. shop. There seemed to be a general opiniorr that 0
after radfography repairs. are being. required that are acceptable withirt the Code.
A review of a smeT1 quantity of rejected filer indicates this generaTization may be valid.
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It was disclosed during the audit that radiographs may be reviewed by as many as five individuals.
Sucir ex-cessive review leads to supercritical evaluatiort of fil.rrr and to excessive repair. As. previously stated, better radfography permits. better
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[ 'W e TUGC0 OBSERVATZONS & RECOMMENDATIONS
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identification. of conditions. acceptable within the Code. Unnecessary
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repairs increase cost and reduce pipe reifahflity.-
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Reconnendations - Have radiographs which have been rejected for defects reviewed-by TUGC0 Level III radiographer. If a reasonable statisticai l
sample shows that excessive repair of weids has been required, establish
]
the policy that Code acceptable indications shall remain untouched,. but _
g shall be. recorded on the reports.
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As art economy, constder reducing the number of persons performing f
sequentfai review of radfagraphs.
n C.
NDE Qualifications.
The site NDE Level III situatfort is uncTear. OnTy LeveT II certification by Browrr & Root was available for the NDE Supervisoi-- however, it fs understood that TUGCO. has issued; a Tetter identifying him is Levet III.
t f.
Reconnendatfort - CTarify the autherfrv; and responsibility of the NDE supervisor in, administering tests ano. evaluating anc certifying per-
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This is very important as reTated to Code work, since p sonnel.
Level III wilt be working under the authority of the holder of the Code stamp.
i X.
INSPECTION-
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'l There were ner deficiencies. noted relative to inspection; howev'er, it t
was noted that a large number of inspection. personneT are receiving I
their first nuclear constructfort experience on the Comanche Peak site.
As a consequence, it is necessary to improve the quality of inspection planning and to increase the TeveT of supervision-and quality engineering support.
i n order to minimize pass le confusion h~
and. error.
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j TUGC0 OBSER.VATIONS & RECOMMENDATIONS
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I XI.
TEST CONTROL l
A review was made of the TUGCG startup administrative procedures, with f l the following observatione.
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The procedures. appear to be written around the old organization; f
that is, in several instani.ar they refer to the Beme & Rect QA/QC input required in the preparation of "startup work requests".
Z.
It was noted that an unique system is being established to handle I
nonconformances during the startup. phase. It is recommended that wherever possibTe exis' ting schemes uttifzed in construction be used during the startup process. This fs important since most personnei involved in dispositioning such items as nonconformances and design changes; wiTT be the same persons. involved in construction.
XII.
CONTR0t. OF MEASURING & TEST EQUIPMENT f
It was observed that out of 2k instruments sampied which are utilized in civil, structuraT, mechanical and.eTectrical work, approx.imately 50 percent had not been withdrawn from the caTibration Taboratory since its Tast caTibration date. This is. pr.rticularTy significant when it is recognized that the present systee is such that if a calibration date.
becomes due,. the instrument is recalibrated whether or not it has been issued for use. It is recommended that consideration be given to simply changing the caTibration date rather than going througtt a calibration cycle if the toor has not been used.
It was noted that many construction teois are calibrated.
It is important to note-that calibration of constmetion toots is not necessary with respect to 10CFR50~ Appendix E.
Although calibration
}
and maintenance is extremeTy important on constructiert tools, it may be that frequencies may be relaxed.
XIII.
INSPECTION, TEST AND OPERATING STATUS No-deficiencies were noted in this area. Material and equipment observed in receiving inspection, in the warehouse and outside storage f
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' TUGC0 OBSERVATIONS & RECOMMENDATIONS l
~..
area appeared ter be adequately identified. No tests were observed.
XIV.
HANDLING, STORAGE AND SHIPPING l
l Exterior storage practices'should be reviewed. The protective coverings l
}
of many items are damagedi some reported on monthly surveillance-teports j
have not been corrected. Large temporary structures, such as -those over ll the emergency diesel engines, require wind bracing to prevent further damage. Because of soiT chemistry,. rain and humidity, ttie current pt ac- 'M tice of aITowing; Targe stainlass steel piping to remain uncovered should b. -
be ravfewed.
Sensitized. stainiess is extremely sensitive to chloride,.
3 flucrfde and suTphide contamination which with water as a couplant can i
cause intergranuTar corrosion and prematura faiTure.
i
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XV.
CONTR0t. OF NONCONFORMANCES There appears to be an effort to reduca the number of documented non-
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conformances.
Ii It was noted that DC 00As were being utfitzed for nonconformance repor*a.
j Althougte this was. observed err a small percentage of DC 00As issued during j
the monttr of ApriT, it is reconnended that this practice be stopped imediateTy. The TUGC0 system is correctTy established whereby non-confonnances are written after the fact and DC 00As art reserved for design changes before the fact.
It is i
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l Procedure CPQT-AB,, Rev. 0,, dated E-E-78 was issued for the purpose of providing expedient disnosition of concrete discrepancies. The procedure f
infers that discrepancies of 72*F versus 70*F or 6.2% air content versus 6.0%. maximum is perfectl acceptable when it is signed off by the field engineer.
u al d in Brown & Root and TUGC procedures and should l
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[f TUGC0 OBSERVATIONS & REC 0f9tENDATZONS,
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be discrmtinued.
If tolerances are unreaTistic such that the 71*F is acceptable, then the design specification should be changed to se indicate.
t It is recormnended that good inspection planning be provided inspectors, identifying the characteristics ta be inspected, th n
an such criteria. This will-of inspectors and provides L
identification-of problent areas and provides a means for their correctiert.
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It is ritasonable te assume thaEerr a profect as Targe as Comanche Peak.
1 there wf!1 be severai thousand nonconformance reports. The number does not reflect adverseiy arr the quaTity of construction, but th
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i-XVI.
CORRECTIVE ACTI0tt
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1 There were ne deficiencies noted reTative te corrective action art hard-
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ware. The SuppIfer CompTiance Supervisor has established at rr.*thod of tracking vendor performance and 'shows positive results front actions taken i
te correct supplier quality probTems.
A. review of reports. of site sur-
~i vefilance conducted by TUGC0 showed corrective actiert responses. wre being.promptly received. A review of reports of survei1Tance actions
)
by Brown & Root showed generaTTy adequate rasponse and resolution of corrective actierr
.rt surveillance i
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L Dr general,. corrective actiort appears ts. be adequate and timely on vendor and site related problems, Some of the changer in authority deie-
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at on to major contractors appears to be action takert to correct inadequate l
or untimeTy onse o those organizations;.
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'TUGC0 OBSERVAT ONS &. RECOMMENDATIONS 1 I a...
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1 XVII.
RECORDS'
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Excapt for lack of internal fire protection,. the quality records area is considered to be satisfactory. Some Quality. Assurance records, such as personnei quaiff! cations, are nor stored in the records center but are maintained separately by the Brown & Root training coordinator.
There is not currentTy a. catalog or Tfsting of required records h1though l
it is being prepared. A ruview of a' selection of Quality Assurance g
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records showed the documents in them to have.been properly completed..
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an'd in; the correct order.
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l Recomendatfort - The installatfort of arr inert gas fire extingufshing
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j systeer or the identificatfort of geographicaTTy separate duplicate records j'
shouTd be expedfted. TUGCC shouTd review the fire protectierr capabfitties /
of storage facfTitfes irr the training supervisor's trailer and consider a dupTicate set of such records te be maintained in the records center.
XVIII.
AUDIT 5
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There are severat audit anit survetITance programs in effect. Audtts by-f the Quaif ty Assurance Department Central Staff are performed on site j
activities, major contractors and suppTiers. Site surveillance actions s
are perrformed under the directiert of the TUGC0 QA Site Supervisor. Similar ki s
l survef1Tance activities are carried out under the direction of the Brown &
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Root Site Quality Assurance Manager. Whtle called survei1Tance actions, the survefTTance programs are formaTTy planned and scheduled, utfitze checkTists to guide the activity and. record resuits,. and issue reports of deficiencies and require correctiert. Except for formal and documented j
pre-audit and post-audit meetings., aTT the elements of art audit program are frr piace. It was reported that the reasort for caiIfng the activi
" surveillance
- was tot avoid outside auditors finding the program defic because it did not incTude the documented pre-and post-audit meetings I
yet the auditors found. that such meetings were conducted, but on an infor nal basis, t
Recomendation - The auditors consider the present progrant to be an effective tool which could be further improved. TUGC0 should consider
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NUGC0 OBSERVATIONS & RECOMMENDATIONS '
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1 combining the audit and survef TTance activities-into a s. ingle, cohesive effort. Such art integrated effort could cover required areas more' efficientTy, without duplicattorr and, at a frequency that can-be main-l tained.
2 and include e description of both-the fonnai audit and the continuous audit pian (surve11Tance) and the method; of' conducting pre-and poit-audit t
I meetings. shouTd be described tc preclude later-criticistas by outside organizations. The resulting audit program should. be a superior tool for f.
management assessment of progrse impTementation and effectJveneis.
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,,~C,.s ({.up.<x 4TEXe, UTILITIES GENERATING COlh_;iNY i
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1 O FFICE MEMOR ANDIThC To P*P"Y G 8 A
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July 11 107R Nt*
Subj,e Manacement Gua11tv Assurance Audit RE C ETVRD-g jut.12 197-P. G. BRITTAIN Attached are our resolutions to the findings and reconmendations. made-by Management Analysis Company as a. result of their audit in May.
Our analysis of the audit results has been discussed in general tems with John Jackson,
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FINDINGS (APPENDIX A)-
0 1.
Finding Summary: Our QA Plan and Procedures. do not reflect current autnority delegations to B&R and to G4H.
Response: At the time of. the audit we were operating under properly approved deviations. These deviations were incorporated into a permanent QA Plan Manual revision on July 1,1978.
I 2
Finding Sununary: The current practice of after-the-fact design cnange review provides significant risk of error and is in noncompliance with 10 CFR 50 Appendix B.
Response: We disagree; on both counts. The G4H Resident Engineer
]
has exercised extremely good judgment in implementing the authority delegated to him. Of the approximately 2000 changes /devia-a J
tions/clarffications issued under the system, we are aware of none l
that trave provided exposure to. a significant rist of error. To, i
provide greater visibility of the design change functiert, a system was,impiamented ort May 25, 1978 that provides an analysts of all changes and permits continuing evaluation of the field efforts.
This systest is current for ongoing activities at the present time r.
and wt1T be completed for past activities on or before July 15, i
1978. Our belief that we are in fact in compliance with 10 CFR 50,
- i Appendix $ is suppo rnal audits QA personnel and fndependent audits by We propose to Taave the design chan i
3'.
Findino Summary: TUGC0 QA does. not review all procurement doctseents and changes tnerato prior to release.
Response: We disagree that' his is a requirement. A separate QA requirement section,. approved by TUGC0 QA, is included with each
.j purchase order and is applicable to all supplements. Changes to 3
these requirements are authorized only by Quality Assurance.
d 4.
Findtne Sunusary:. The current array of QA manuals and proc.edures is comp 1ex and, atfficutt to maintairr.
3 Response: We agree The new Plan manuai was, issued July 1,1978.
^
The corporate QA Program. Manual is currently under study with the goal of streamlining it.
5.
Finding Sununary: Records do not reflect the as-poured configuration clearly.
s Response: Configuratiort has always been made visible to inspectors, W
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and steps have been takert to improve the visibility for the record.
6.
Finding Sunmary: Markings for in-service NDE inspections were not always distinct.
4 Response: We agree that_such markings should be Tegible. QC will j
inspect special process ISI markings prior to turnover.
i 1
T.
Finding Sumary: We are using the DC/00A (design change) program to bypass the nonconformance system.
Response: This is not true. If construction identifie's and corrects. a. defect or obtains an approved engineering change prior to-QC inspection. no NCR. ts. required.
8.
Finding Summary: The records storage facility does not have internal fire protectiore during; off-duty hours.
Response: Art inert gas fire protectiort system is on: order by TUSI.
Target date for installatforr is. August I,,1978.
9 Finding Sumary: ApproximateTy 245 of audits scheduled by Dallas staff have not beert conducted. Audits by TUGCG and B&R shouTd be combined fre one overali effort.
Response: Our audit scheduTe fs constantly being revised. to refTect changing manufacturing status and ta allow 'as to. use audits to investigate probien areas of the most immediate concern as they arise. We believe we cart defend our audit program,. and are leaving-it as it is; j
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OBSERVATIONS AND RECCHMENDATIONS. (APPENDIX. B) r O I
Organizatfort Recommendation: Separate inspection from Quality Engineering (planning)
Response-We had begun worte on this before the audit. Our pr$ dict assurance group: has taken responsibility for Quality Engineering.
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Recommendation: Re-evaluate the charter of the Quality Surveillance' j
committee.
Response: We have decided te dfscontinue the Quality Surveillance Consittee. Instead,. TUGCC M Manager wf TT f ssue m. report quarterly 1
to keep top management apprised of the status of QA matters, including quality trends. The first sucit-report will be issued by
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August 15,,1978.
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Recommendation: H1re more seasoned inspectors. Mtre any future j
engineers fras outside the company wittr experience irt nuclear plant i
constructfotr.
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Response-We are orr the Tockout for welt qualffied personnel and 1
continue ts review appifcants from outside the company. The reTatively young inspectors wil-1 be strengthened best and quickest
.:j by taking from them the responsibility for inspectiort pTanning and 1
provfding them wttir adequate, but concise instructions and checkTfsts This has beert done and ts effective.
p II Qualf ty Assurance Program j
Recommendation: Revamp our present QA manual system.
3 Response: We agree. TUGC0 % tssued a revised QA Manual on July 1, t
1978.
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Cofnfort: Otztainfng: our ASME Code stamp. wtiT be difficuit if all the work is done by others.
Response: We know it wf TT be dffficuit, but it cart be done. The report does not accurately record our stated. reasort for obtaining an N-stamp..
III Destart Control Reconnendation: Abandort our present system of expediting field
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O Resoonse: We iit ieave it as it is.
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IV Procurement Document Control Reconmendation: All proc'urement doctments should be reviewed by QA.
4 Response: We disagree for reasons, stated on Page 1.
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Instructions
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g Recomunendation:[ Streamline-inspection plann ng and. checklist Q,f
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vvLW preparatton.
j Response: We agree, and have-been active irt this effort since January.
Recommendation: Discontinue mapping individual standard imbeds.
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Response: Mapping has been discontinued, but we have retained. a
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reasonable degree of traceabfif ty on embedded. itmas.
Recommendationr Combine construction and-QA procedures.
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Response: Sfnce January we have been doing this for new procedures and, wnerr revising old, procedures.
h aj Reconnendtion: Discontinue requiring BAR Houston approval of procedures.
Response: All procedures except those invoTving ASME Code work are now approved at the site.
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Observation: ATT appTicabTe OC/DOA?s are not included. in supporting doctmentattort.
Response: Refer ta Page I, Appendis A,. Itenr F.
Recommendation: Establish a formai site procedure for planning-construct 1 ort worie.
Response: This planning is. being done. We don't intend to create a fomal procedure for it.
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VI Document Control O
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Observationi The ARMS system should be backed up by a manual systes p
(stated verbally in exit management interview).
Response: The auditors' lack of confidence in ARMS was the result of insufficient familiarization. with the system on their part.
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VII Control of Purchased Material, Equipment, and Services j_
Observation: The QA Plan is not up to date in this. area.
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j Response: Manual revision-was compTeted on July 1.
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i Statement:. Source inspectors. (TUGC0 QA) appear ta bei at the mercy g4 of the supplier inn deterisining what changes have beerr incorporated.',/.
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' R'esponse: This is not true. We- (TUGC0 QA) prepare our own
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I checklists after searching the appropriate files. We agree with the ?-
auditors.' (verbal) coements that this method places an additional V'y'j burden on ourselves; however,. the original (and. Togical) approach of
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depending upon G&}t ta prepare the checklists did not woric.
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o VIII Tdentificatioe and Control' of Materiais. Parts, and Components / i#
l No observations
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IX Sjecial Processes Reconnendation: The use of Iridium 192 should. be replaced by x-ray
]
for all shop welds and for field welds where practicaT.
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Response: Brown & Root is studying thf s reconnendation,. and is connitted to have a report for TUGCO/TUSI by July 15.
3 Reconnendation:-
Reduce the nisaber of individuais reviewing, radiograpns and establish the policy that Code-acceptable i
indications be recorded. but not repaired.
2,
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Response: This had been accomplished prior to the audit, but j
apparently the auditor talked with someone who wasn't aware of it.
1 Recai.wendation: Clarify the responsibility of the NDE supervisor relative to cnde work.
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Response: The auditors were confused in this area. Our only Level III at the site is in civil work, not ASME Sec. III Div. I work.
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Inspection in the report.
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Included here was a re-statement of observations covered elsewhere i
XI Test Control I
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Recommendation: Existing nonconformance control systems. should be used, during startup.
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Response: The new @ Manuai,. withi input fros TijGC0 Operations, wili address. nonconformance controi systems.
i XII Controi of Measuring and Test Ecufoment
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Recommendation: Equipment shouTd not be recaTibrated on the due date if it has not been used.
Response: The recoseendation has. been adopted for items whose caltbration is not subject te change while not in use.
Impiamentatior date was JuTy 1 XIII Inspection. Test and Operating Status
'h' No observations
)
XIV HandTing Storace and Shiocing Reconsnandation: Exterior storage & protec orppr s uld be reviewed.
We halprevio' sly reviewed oraga practices and have-55iinse:
u no: reason to beTieve that_ a penhian exists Various NRC inspectors tso-insp+.M thfs-esi.ivitjr,-~~Howevier,. Westinghouse is rewtewing this,. and their metaITurgist wi1T report by July 15.
XV ControT of Nonconformances l
Observation: This is e restatement of concern over nonconformnce control.
Response: We reject the inference 01at problems are-circumvented rather than corrected at CFSES.
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XVI Corrective Action-No spectfic findings.
XVII Records Recommendation: This section restated the need for fire protecti.on system.-
Response: The inert gas system will be installed by August 1,1978.
X IIIAudits.
Recommendation: The audit (DaTTasi and; surve11Tance (site) activtties, should be combined.
'l Jj Response: We intend to Teave our audit progan. separate from site surveillance.
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WonsuAx, Fonsrrnz, SAMPELS 8e WOOLDRIDGE TwsmTv.rsvc mumonto soon savam towan 4
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< h" A8, TEXAS 75 Sol set...onsmau mostov a. woo 6amenos uses este mai6 o. anotasose
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cectua J. saunce 4 I I[
Peter B. Bloch, Chairman 4
Administrative Judge j.
Atomic Safety and Licensing Board i ',
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 s
Dr. Walter H. Jordan A
Administrative Judge j h"*
i 881 W. Outer Drive e
Oak Ridge, Tennessee 37830 Dr. Kenneth A. McCollom Administrative Judge Dean, Division of Engineering, Architecture and Technology Oklahoma State University h
Stillwater, Oklahoma 74078 t
1 Re: In the Matter of Texas Utilities Electric Company, et al (Comanche Peak Steam Electric Station, Unitt 1 and 2)
Docket Nos. 50-445-1 and 50-446-1 Supplementation of Applicants' Response to CASE's Request for Production 3
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Dear Administrative Judges:
l i
This is to notify you and all parties to the above dockets that Applicants have
)
identified a document wh.'ch we le11 eve to be within the scope of item 10 of CASE's Interrogatories and Requests to Produce dated July 7,1980, as clarified on August 4,1980. Applicants submitted their response to item 10 on September 8, y
1980 and supplemented their respon e by letters dated December 22,1980, March 3,1982, and April 19, 1982. The document, a copy of which is enclosed with this letter, is a report prepared in May of 1978 by Management Analysis Company (MAC) following a management review and audit of the quality assurance program of the Comanche Peak Project.
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$1e Administrative Judges May 29,1985 t
Page Two i
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i' Recently, in gathering data for a prudence audit being performed for TUEC, a search was made by TUGCO personnel of inactive and closed corporate files located in TUGCO% Dallas office. In the course of such search, the enclosed report was found. A memorandum dated July 11, 1978, which details TUGCO resolutions to the findings and recommendations made by MAC, is also enclosed.
r TUGCO management is evaluating the failure to produce this document at an.
l earlier time and will advise the Board and parties of the results of this ev'aluation in the near future.
I.
l R%ddlly submitted
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- L Robert A. Wooldridge,
Counsel for Applicants l.4
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Enclosures lj cc:
Service I.ist I
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- Management Ana ysis Company 11100 Rossue St Sea Disso. CA 92121 724/452 1391 r
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May T7,1978 l
MAC-JPJ-471
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,l Mr. Perry Brittain 1
Prosident j..
Texas Utilities Generating Company
~~
j 'i 200T Bryan Tower j
DaTlas TI 75201 A
i Deer Mr. Brittain-q i.
Enciosed is the report of the Management Quaifty Assurance Audit conducted j*
for Texas Utflities Generating Company.
!h The audit disclosed that, in general, the Quality Assurance activities were
~
effective, that there is good team spirit between TUGCO/TUSI personnel and the Architect / Engineer and the Constructor.#The audit resulted in the l
(pdentification of..some failures'ta comply with reguTatory requirements, the QuaTity Assurance Pica or the.PSAR '. These deficiencies are identified in t
' an Audit Report as Appendix A.. The audit aTso identtfied areas of potentiaTTy.
4 improved practice. These are identified as.0bservations and Reconnendations and Appendix B' to this Tetter. As you know,. MAC participated: irt arr audit of the Comanche Peak site and significant improvement is noted since that audit.
Management Analysis Company received full cooperation from ali personnel con-
)
'l tacted during the audit, TUGCO/TUSI, Brown & Root, and Gibbs & Hili. That) i J
general openness of personnel and their frank discussion not only enhanced the conduct of the audit,. but exemplifies an attitude conducive to correction-L of any deficiencies.
a s
4 i We appreciate the opportunity to be of service to Texas. Utilities Generating
)
"[ Company and Texas Utilities Services Inc. and hope ta do so frr the future..
j If there are any connents or questions regarding this work, please contact Mr. J. M'. Norris or me at (714) 452-139T.
- SinceRiy,
//
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r. Johrt P. Jackson Principal Partner JPJ:bew
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Enclosures:
Appendix A
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Appendix B e
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1-APPENDIX A l} -
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TEXAE LITILITIEi GENERATINE COMPANY l,
AUDIT REPORT j
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Subject:
Audit of Texas UtfTities Generating Company, DaiTas Offices o
and Comanche Peak Staasr ETectric Station Construction Site
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Date of Audit:
May T-72,197E
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Audit Scope:
A management audit was conducted of the Qua11ty Assurance
[i Prograst of Texas Utilities Generating Company dvring the 1-t '
weeks of May T and:May 5,. T978. The purpose of the audil a
was to.detarwiriFthe adequacy of the QuaTity-Assurance
!)
Program as reTated te NucTear Regulatory Commission require-ih' h.
mants and the effectiveness of impTementation talaset program requirements and authorfty deTagations. Activities were audited at both the TUGCU offices in DaTTas and at the
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Comanche Peak construction site. Actfvitfes of the Architect /
Engineer and Constructor were audited onTy at the construction i
site. The scope of the audft included commitments made in
]j the PSAR., thir CtEporate Quaifty Assurance ManuaT, the Comanche f
Peak QuaTity Assurance PTarr., the Project Procedures. Manual j
and the Brownr & Rooti QuaTf ty Assurance Manuais and Procedures.
A reTated to: the Comanche Paek site.
Auditors:
DalTas office, May T-2,. T978 i.
J; P. Jackson., MAC Audit Teant Leader e
J. M. Norrfs., MAC Auditor f
Comanche Peak Construction Site;,, May 4 & E May 8-12,,197E N
J. P. Jackson., MAC Audit Teant Leader J. M. Norris,, MAC Auditor a
-i J. A. Hendrort, MAC Auditar (May E-TZ onTy)
Personnet NAME CMPANY' TITLE
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D. N. Chapmarr TUGC0 QA Manager, *-1-2 R. E. Tolson TUGCQ Mgr, Site Surveillance
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R. Y. PTeck TUGCD/G&W Civ. Inspec. Supv.
- -1 J. V. Hawkins TUGCO/G&H Prod. Assurance (QA)
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'TUGCD' AUDIT REPORT
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Personnel NAE CDMPANY TITLE Conta g
J. 8. George TUSI Prof. General Mgr., *-T-2 3
J. T. Marrit TUSI Resident Manager, *-1 i
E. G. Gibson -
TUSI Project. Engineer, *-1-2 E. J. Murray TUSI Engineering Supv.., *-T J J. Moorhead G&H Resident Engineer, *-I-2 E. C. Scott B&R Site QA Manager
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J P. Clarke B&R Site QC Manager, *-1-r
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R'. Manrt B&R QA Records Coordinator.
- i N D' KirkTand B&R' Prof. General Mgr, *-T u
5j II. A DougTas BAR Project Manager. *-T f.
D' C. Frankum
- BAR Asst. Project Mgr., *-T 32 g
P. FoscoTo BAR Prof. Chief Engineer, *-T L Hancock B&R Mat'T Procurement, Con-r 3
struction Branch, *-T A. Borert TUGCD Vendor Complianca,.
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It. Gary
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Systems CompTfance,. *-I-Z TUGCG V'.P., Operations, *-1
]i L. Ffker TUSI V.P'., Design & Procurement, *-1 P. Brittain TUGCD/TUSI President,1-A 3
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- Intersiew L
T Pre-audit meeting:
i Z Post audit meeting
/
Audit Method:
The audit was conducted througn a series of interviews with j
responsible management and supervision and examinatiert of p
quaTity Assurance manuais, procedures, records and work L
operations both at the DaTTas headquarters of Texas Utilities Generating CDpany and Texas Utilities Services, Incorporated and at the f.omanche Peak construction site.
Q Sumary:
The audit disclosed that recent changes. in authority dele-gations had been generalTy weit accepted and that morale
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7-Sunnary (Cont'd): and-teaar spirit were good. However.peJ::hanges.,had not MM.WomaliQ'in gejsions3Dihe'ESARand the Comanche Peak Quality Assurance Plan. The audit also f
disciosed thac present practices in the control of[lasign '
~~ iWEEchirr nonconforsmances 50 notTr~ v.ide the ga o
jiitsklevei o' fMew by h chidnal$ signer.' In other instances it was evident that[lasign changes were
,j, ing used in M m : z.,._u
.eu, of nonconfor1mance reports. Except for 3
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j e areas noted.herefrt and below,. there was ge,nerally good j-adherence tar existing procedures Ia a,.
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Findings:
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T. The current activities of TUGCG Quality Assurance per-
-sonnet are not consistent with the authority delegations 4~
1-to Browrr 3r Root and tar Gibbs & Hill as defined in the PSAR and Comanche Peak QuaTity Assurance Plan.
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SfstiarTy,, the-QueTity Assurance-PTarr and Procedures are a
not consistent with current and pTanned revisions in authorfty delegations' to the Architect / Engineer and the
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Constructor,, and is not complete in addressing all eighteen criterfe of 10CFR50 Appendix B. h lack of a weTT fdentified plan of reorganization and responsibility
. %s~.ir~ihint;y ist F,arrying' out some ' activities.
There needs to be a plan for revising the Quality Asstar-ance Program;. such a plarr should include'the establishment I
of art architecture of procedures to show-how other TUSI/
TUGC3 and contractor manuais inter-relate with the QuaTity Assurance Manuat. The TUGCD QA Manager should establish-a schedule and assign responsibilities for compTetion of the necessary procedures. The scheduTe should be suppie-l mantad witfr e management effort to monitor adherence to the plart and achievement of the schedule.
h 2.
The current site DC DDA sys. tem of after the fact coordi-natiert of design changes with the original designer s
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7 Findings:
provides a significant risk of design error and does
.not meet the requirements of 10CFREO Appendix B, nor o
of ANSI M5.2.IT, " Quality Assurance Requirements for the Design of' Nuclear Power Plants".
A systes'for expediting and documenting Gibbs' 51111 home office approvals should be established using telephone, telecopier or telex as.a means of speed,1,ng i
communicatiort.
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- 2. The Comanche Peak Quality Assurance Plan does not provide j
for a Quality Assurance review of procurement documents and changes theretor prior to purchase order placemagit, except for site originated procurements. Such a review g
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fs identiffed in 10CFR50 Appendix B, Criterion IV' and is a requirement of ANSI N45.2.13. It shoutd be required
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orraII, safety related procurements.
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- 4. The current combinatfort of Chapter 17 of the PSAR, the i
TUGCQ Corporate Quality Assurance ManuaT, the Comanche Peak QuaTity Assurance Plan, Profect Procedures and Brower i Root Manuals and Procedures provides a complex array of procedures which is difficult to maintain
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current and consistent.
- 5. The current system of providing inspection instructions or checkTists te inspectors is too generic, placing an
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undue burdert ort the inspector in attempting to datamine applicable drawings and. specifications. and applicable revisions thereto. A review of records of concrete pours incidates that configuration reflecting the as-poured condition fr. not clearly defined. AppTfcable DC DDAs are not 'noted in inspection documentation.
Configuration needs to be clearly identified to inspectors on. e current basis, incTuding all applicable m-
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Findings:
'DC 00As and completed documentation must refTect tha (Cont'd)
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status of the appTicabTe changes.
6.
SpeciaT, processing markings for later in-sarvice inspections are careTessly applied. The circle and f
arrow used. for such mariting is sometimes incisplete and not recognizable-for its intended purpose.
In one instance only a; portion of the cin:le resenbling the Tetter "C.* was.discarnibTe. FaiTure to properly maric thesETocators now wfTT cause delay and possikTe i
error when in-service inspections are made in highTy feradfated areas.
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- 7. Disposition of nonconfonsing items does not always achieve the requisite review by approprf ataly qualified destgre personneT. A procedure, Timited to defects irr concrete,. was recentTy issued.which bypasses. the estab-Tfshed nonconformance contrat systan and,. thus,. vioTates reguietary. requirements irt this regard. In other i
instances the DC DDA prograst has beert used to bypass y
the nonconformance reporting: systam. The nonconfonnance lg controT systent should be the meansNor maintaining in-t j
spector integrity, identifying problem areas and provide ff a driving force for their correctfon.
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The records storage faciTity does not currentTy have any i
means of internaT. fire protectiert during hours it is unmanned,. aTthough it is understood some method is pTanned. QuaTity Assurance records, such as personnel jg quaTifications,. are not maintained irt the Records Center, I
but are maintained in fireproof file cabinets in a trailer under the cognizance of Browrr & Root training coordinator.
i 9.
Approximately twenty-four percent of Central Staff audits jh have not beert conducted as scheduTed. Combining Central P
Staff audits, site audits and site survei11ance activities t' '
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(Cont'd) program would provide improved visibility to the overall audit and survef1Tance effort and pemit evaluation and
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ajustment to the audit schedule to attainable and yet effective frequencies.
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L APPENDIX 8 3
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3 TEXAK IITILITIES GENDAUNG COMPANY 4
OBSERVATIONS AND REcomENDAHONS 1
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A.
General c
i TUGC0 Quality Assurance has undergone considerabie reorganizatiorr in the e
l past year. The generai thrust of this effort has been the assumption of j<
greater direct involvement in the management and supervision of the l
Comanche Peak Quality Assurance Program. It is. to be noted that important shifts in responsibility were being made at the time of MAC's review."
4
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As e part of this assessment., MAC evaluated the reactions of key managers,
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supervisors and inspectors ter the overali changes that have taken piace to date.
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It was. generefly observed that tnose interviewed thought that with few exceptions the changes were for the better. There appeared to, be a team
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effort orr the part of QA and Construction with excellent TUSr. executive senagement and project management support of the QA program. There was nor noticeabTe probias wittr organizationet prejudice brought about by the organizationai intermixing of iUSr., Browrr & Root or Efbbs & hit 1 work.
forces. and supervisfort.
B.
Organization During the course of the audit MAC discussed the value of a revised organizational structure withr the TUGC0 Quality Assurance Manager and the Manager. Site Surveillance.
.It is recommended that TUGCG adopt art organizadional reaTignment of activities as set forttr irr Exhibit T, whereby Quaifty Engineering and Inspection report to the Site QA Supervtsor as two separate sub-organizationai entities. witfr responsibiTities as defined in Exhibit T.
Such an organization wfTT better supplement the existing Construction organization and will permit better organization for handi.'ng day-to-day l
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site problems as well as igiementing recomendations of this report.
l This. is particularTy se in the area of inspection planning.
4
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.TbGCQ CBSERVATIONS & REC 0HNDATIONS
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QueTity Surveillance Courrf'ttee ATT sinutes of meetings-of the QSC since its inceptiotr were reviewed.
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It is noted that the QSC was established as a mechanism for providing
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top TUGCD management with a periodic update on such matters as " schedules.
r and siTestones" or " audits and corrective actions".
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f It was noted that recent meetings dealt with ' tracking on the status of. /
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action ttens as set forth in the Outstanding Surevillance Report Items 8"
or the QuaTity Assurance Itanik"of Concern Report.
In such. instances.it #
j.f appaamd the Quality Surveillance Connittee was. taking on the role of a l.
task force or probTem solving. group. The problem that exists if the QSC
!y assumes such a rote is that problems would tend tot awaft the three month meeting cycTe before the necessary management attention is effected.
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i It is recommended that TUGCQ re-evaTuate the charter of the QSC and serious considerati.on given as to.its value tot the project recognizing that:
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AT.T actiotr tor. msoTve problems. shouTd be handled on. a day-to-day basis j
through the functioning organization, and I
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The primary objective of maintainingynagesent awareness of Quality ti Assurance status might be accomplished more efficiently, effectively and arr a more timely basis through.a monthly Quality Assurance i
progress report distributed to the!TUGCD/TUSI executives.
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Quaiiffcatiorr of Personnel MAC reviewed the qualifications of alf TUGCO/TUSI and Gibbs & Hill Quality Assurance personnel and many of the Brown & Root personnel.
It was-observed that most of the TUGCO/TUSI Quality Assurance personnel have gafned their Quality Assurance experience through Comanche Peak activities only. Although the project has provided valuable experience it is rec-onnended that any future assignments in Quality Assurance be filled with
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quality engineers hired from outside the company with broad nuclear ex-perience, preferably in constructiorr. Such experience added to the existing staff will serve TUGC0/TUSI weTT in accomplishing the important s5E
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piping, electrical and startup acdvities ahead.
MC had occasion. throughout the audit to assess the quaTifications and experience of 20-30 inspectors throughout the construction site. These l
l observations arm worth mentioning:
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The inspectors are generally young and inexperienced with many having. h
. j as lit;tle es six months experience. in inspection.
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There was an obyfous need for more seasoned inspectors te work with j,
the novice inspectors on a day-to-day basis.
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- 3. Too much responsibfTfty is piaced on the inspectors with respect to
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I properation of inspection planning, resolution of site problems and
]f detamination of the design configuration base for performance of iG faspections.
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II.
QUA[,ITY ASSURANCE PROGRAM k
The Quality Assurance Progrant is deffned in three. basic documents:
1 P
The Corporate Qualf ty Assurance Manual ij Cljapter 17 of the PSAR
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The Comanche peak QuaTity Assurance Plan
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These doctanents are not in total agreement with one another. Since there j
is no-other nuclear piant currently planned and since the authority dele-f gations identified in the Corporate Manual are not in consonance with practices on Comanche Peak,, TUGCQ should consider discontinuance of the l
Corporate Manual unless there are other projects to which it is to be applied.
If a: Corporate Manual is required at a Tatar date,. a new one g
could be prepared based on Comanche Peak ' experience and the requirements of a.ry new projects to which it wouTd be applied.
The Comanche Peak Quality Assurance Plan addresses only the folTowing
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criteria of the eighteen identified in 10CFR50 Appendix B.
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ct TUGC'0HMSERVATIONS & REcome0ATIONS ~
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Organization
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Destgrr control
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Procurement Administration Inspectiorf i
l Nonconformsnce Contral Dociment Controi Records A~udits
-e With the expanded responsibil.tties of the.TUGCC QuaTity Assurance Depart--
ment, the pian needs to be expanded to address aTI eighteen criterie to refTect the creatfort and functions of the Procurement Department and to be consistent wftte the authority deTegations and functions sti1T resting '
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!I with Efbbs & Hill and witte Browr & Root.
There needs to be e pian for procedurai identiffcation and development and a schedule and assigned rispensibilities for their completion, including-
, a compTete architecture of' Quality Assurance procedures., project procedures and interfacing Weiss of the Architect / Engineer and Constructor. The effort shouTd be to minimize the mater of procedures. required and to
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3 eliminate dupTfeating or overlapping procedures through consolidation of l
detafT and joint approvais of the' organizations involved.
It is reconnended that the QuaTity Assurance Manager use his organization as the driving force to achieve required. procedural coverage art schedule.
It was noted that TUGCC is planning orr obtaining its own Code manual The stated' reasort for this was the fear that Brower & Root would not achieve I
Code acceptance. The auditors finet that the Brower i Root manual would be acceptahTe to the Code Survey Team and that its weTd practices as exempli-ffed in. the Weld Shop are very acceptable. The auditors are of the opinion that obtaining a Code Stamp wiTT be difficult where all the work of implementing the program is perforined by others.
III.
DESIGN CONTROL The present system of expediting field changes by referring design changes to the originai design organization for approval after the fact does not Q.
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UGC0 (BSERVATIGIS & RECOMNDATIONS -
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aset the intent of 10CFR50 Appendix & nor of ANSI M45.Z.11, which require
%t field changes be subject to design controls commensurate with th
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. exercised on the original design. TUGC0 audits have already disclosed
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that the Architect / Engineer has not been reviewing field originated changer v
l f on.e concurrent basis, thus the design engineerfs connents may be~ received [ Y l
after the specific construction work is complete resulting in possible s
i loss of design integrity, undue pressure on the designer to justify what I
has been done, loss of designer msponshiTity or possible extensive i*
repairs. It.is recommended that a systres for expediting review and-j approval b'y the origfnei designer be estabitsbed on al'i' safety related j.
changes using: teTephone,. telecopier or teTex as necessary to coordinate
- 7 and document change approvais.
It 1!b IV.
PROCUREMENT 00CtMNT CONTR0i.
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Except for site procurements, the Comanche Peak Quality Assurance pian
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, does. not provide for a review of. procurement documents and their changes prior to piacing; a purchese' order This is. contrary to requirements of e,
10CFR50 Appendix %,. Criterton IV and ANSI M45.2'.TI, " Quality Assurance Requfmments for ControT of Procurement.....". There is a review of pro-curement documents by Quatit;y Assurance during Design Review, but is was asco'rtained that this was a review of the drawings and specifications i
and not the purchase order or contract.
Procurement document mvfew by Quality Assurance should assure that aTI
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necessary requirements for access. to the supplier's facilities are provided j
and that necessary controis and documentatiorr have been specified and I
that the appropriata configuration has. been define'. The review shouTd.
d elso assure that requirements imposed are appropriate to the procurement i
and that there are no excessive requirements for quality program develop-6 l
ment or for the delivery of unnecessary documentation. Some of the pro-j curement packages reviewd appeared te have both blanket requirements for i
Quality Assurance programs and excessive requirements for doctanentation.
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V.
INSTRUCTIONS e- -
A.
Inspection Planning The curmnt system of providing inspection instructions or checklists to
- I the inspectors is too generic in nature. In the case of concrete inspection-planning the inspector filis. out a simple pour card with an attached.
Concrete Placement Checklist, a Reinforefng Steel, ETectrical, Medanical J
and Ededded Item Placement Checklist and a Stainless Steel Liner Checklist,.
,f the combindtion of which:
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Provides no. irtfonnation with respect to. unique, ededments or penetrations to be incorporated. in the pour.
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Piaces an undue burden on the inspector in attemptinf to determine ~
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appTicabTe drawings, specifications, appTicable revisions and Q
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applicable DC D' A's.
Much of this input should be prbvided by g
0 ciericaT support under the direction and subsequent approval of
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- a. quality engineer..
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Inspectors estimated that 45-70% of their time is spent on docu-mentatiort rather than physical inspection activ.ity. Welt thought.
out pTanning could do much to alleviate this situation.
1 Traceability j
It was observed-that Comanche Peak has established a program of unnecessary material traceability which, based on one estimate, consumes l
at Teast a three-man Tevet of effort and perhaps as high as a six man level of effort if one considers aTT the support functions. required to-
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implement the program. ATT anchor bolts and 8 series cadweids. are fully traceable tar heat numbers such that through an elaborate and
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extensive system of mapping aIT instaliations, the capability exists of identifying each embedded anchor bolti,. B series esdweids and other standard embeds to its heat number. There exists no such NRC or industry requirement for this degree of traceability.
It is inter-esting to note that rebar does not require traceability on Comanche Peak (and shouTdn't) MAC. knows. of no other project that imposes. this 'equire-
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I TUGC0 OBSERVATIONS & RECOP9ENDATIONS -
ment and could not identify a Comanche Peak specificatiert or procedure requiring it. Accordingly, it is recommended that this practice be dropped immediately. Such a move wouTd enhance inspector morale as I
those involved are aware that the practice serves no useful purpose.
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C.
Procedurs-Simo11fication Newly established procedural systems art such that Construction and
. Quality Assurance issue procedures on similar subject matter jointly;-
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for example,, the recentTy issued procedure on shop travelers was.
l fointTy prepared by Construction and Quality Assurance. It is recom-mended. that important procedures such as those related to concrete be g
revised and fssued. as a s' ingle ' procedure approved by Construction and Quality Assurance. Similarly those procedures related. to piping and eTectricaT should be revised and fointTy issued as a single Comanche Peak procedure.
D.
Procedures. Independent of Houstort-'
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The present systant of obtaining; Browrt & Root,, Houston office approval on construction procedures shouId be modified. Guidelines should be worked out with the Houston office whereby they apprtve only top levei
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procedures, permitting the site fuTT flexibility in revising detailed site procedures. Perhaps the Brown & Root,. Houston office could retain approval authority on those top Tevel documents that estabitsh Brown &
Root polfcy, controT the necessary type of forms,. etc. However,.
detailed operating procedures should be changed with site approval onTy.
Perhaps the Houston office wouTd agree te a retroactive review procedure.
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E.
Conffeuration controT
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A riview of records for completed concrete pours indicates that the
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configuration refTecting the as-poured condition is not prope Ty defined. It was noted that the inspectors record the particular drawing number and revision Tetter, however, all applicable DC 00As are not noted. anywhere in the inspection supporting documentation, g
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' 'TUGC0 OBSERVATIONS & RECOPMENDATIONS -
F.
Preplanning of Construction Work In discussions withr constructiott management personnel it was indicated that a new scheme of construction planning is being developed. This new scheme provides for e d'etailed material takeoff on all Gibbs & Hill drawings which provides detailed instructions; to the crafts as to -the civii, mechanical and electricaT items to be included in each segment i
of work. This formalized approach of taking material takeoffs in the office and providing this information to the field forces on an approNed ~
materiaT takeoff Tist wf11 demuch to. improve the quaTity of the work.
Since the materieT takeoff is a format pro, cess accomplished by construction engineers welt fn. advance of the woric, it provides a significant measure j
of propianning., incTuding the processing of necessary design changes to accomplish the work. Such art effort will do much to minimize field errors.
l with mspect to. Taft out embedments or inability to complete work as a.
resuit of design errors. It is recommended, however that this effort bed 0 7
formalized into a Comanche Peak. site procedure. As such, it will be recopifzed as part of the'systent and wf11 do much to assure that Gibbs s j
Hii.T drawings. are forwarded to.- the site on a timeTy basis to accompTish this pmpianning effort.
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VI.
DOCUMENT CONTROL While there appeared to be some problems with bringing the Automatic
' Records Panagement System on Tine,. the manual system backing it up appeamd te be functioning satisfactor1Ty. The auditors -found no
' deficiencies in document control.
l VII.
CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SERVICES The QuaTity Assurance Pian is not up to date in regard to TUGCO's responsibfif ties for procurement, source evaluation and source sur-veilTance. TUGCQ has devitloped. e program for rating supplier perform-ance and shows evidence of actions when reatings are unsatisfactory.
,h The Ifst of suppliers rsquiring evaluation and source surveillance is not kept up to date by the Architect / Engineer. The list in use is over l
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7-TUGC0 GBSERVATIO.NS & RECDP9tENDATIONS '
four months old, but is meintained manuaT1y by the TUGC0 Supervisor of Supplier Compliance.
There does not appear to tie any method of assuring that the latest con-figuration is supplied to the personnai performing. source inspection prior to-shipment of procured items. The source inspector appears' to
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be at the mercy of the supplier irr determining what changes have been l
identified and incorporated. Thus,. it is conceivabTe that items wi1T.be-shipped ta the site that do not meet the desired configuratierr even though requirements of the purchasing document have been met. Suctr recefpts can cause delays. and unwarranted costs irr meeting the proper configuration.
I It is recomended that a practice be estabTished of identifying and conffming' required configuratiert prior to procurement and prior to shipment of purchased materiais and components.
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VIII.
IDENTIFICATI0M AND' CONTR02. OF MATERIALS, PARTS AND COMPONENTS No deficiency noted. MateriaT reviewed irt the warehouse, in opert storage and in the weld shop appeared to be adequately identified.
I'I IX.
SPECIAL PROCESSES l
A.
Radiography Iridium 1g2 is being used as the radiatiorr source for all radiography l
at the site. This isotope has its optimunt capability at about 1.5 inch thickness of steeT and is not recomended by the Code below.75 inches.
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It is permitted #cr lesser thicknesses when the use of other radiatiert sources is not practical and wherr resoTutfort of the outline and 4T hoTe size of the penetrameter can be demonstrated. The energy leveis of iridium isotopes are higher thart optimum for materials.375 inches or thinner, resulting in a flat image and Tack of contrast. Because exposure
.. I time relates to distance,, the isotope is noma 11y placed against the pipe opposite the film. lWith a.100 inch source size, this causes blurring of the image.
Lack of contrast and a biurred image makes it unlikely f
7 TUGC0 OBSERVATIONS & RECOPPENDATIONS
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that hairline cracks will be seen and difficult to accurately define large indications. The tuse of fridiunrig2 meets the minimum requirements I
af the Code, but by not providing optimum identification of observed anomalies it does three urrdesirable things. First it causes unnecessary removat and npair of indications that can be seen but not properly identified; secondly, it masks narrow cracks, tight lack of weld pene-tration and non-fusion dich can be detrimental to service life; thirdly, l
it does not provide arr adequate base line for in-service inspections-performed. after the plant has gone into operatfort. FatTure to have cTear identification of the original indications at that point care cause deTays,,
the cost of which gmtTy exceeds the cost of providing. better identiff-cation and necessary repair of defects found in. the construction-phase.
Recommendation -It is recommended that TUGC0 require x-ray for shop welds, and consider its use where practical for construction weTds.
X-ray machines in the range of thirty pounds of weight are avafiatrie and are
' nearly as. portabTe as the, isotope. Because of its smeTier-focal spot size and: variable voltage, x-ray can gtve superior radiography.
The feedback of informatiorr to. welders can improve the quaTity of welds and minimize the potentfal' for defects. The abfTity to discriminate betweert indications having roundness or sharpness at the ends can eliminate repair.
The ability to positively identify in the constructiort phase those indi-i cations which have a potential for growth and faf Ture can permit economical repair without radiacion hazards that are inherent if found later irr the operating; phase.
B.
Weiding No causes for concern and no procedurai noncompf fances were found. frr review of the weld shop. There seemed to be a generai opiniorr that after radfography repairs-are being requfred that are acceptable within the Code. A review of a small quantity of rejected film indicates this generaTization may be valid.
It was disclosed during the audit that radiographs may be reviewed by as many as five individuals.
Such ex-U cessive review leads to supercritical evaluaciert of ftint and ta excessive repair. As, previously stated, better radiography permits better filiiiE
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UGC0 OBSERVATIONS & RECOPMENDATIONS 3..
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identification. of conditions. acceptable within the Code.
Unnecessary repairs increase cost and reduce pipe reifahtlity.-
Reconnendations - Have radiographs which have been rejected for defects reviewed by TUGC0 Level III radiographer. If a reasonable statisticai l
sample shows that excessive repair of welds has been required, establish the policy that Code acceptable indications shall remain untouched,. but g
shall be recorded on the reports.
As arr econom consider reducing the number of persons performing sequentiat review of radfographs.
C.
NDE Qualifications.
The site NDE LeveT III situatfort is uncTear. Only LeveT II certification by Brower & Root was available for the NDE Supervisor;. however,. it is understood that TUGC0 has. issued; a Tetter identifying him is LeveT III.
Reconsnandatforr - CTarify the authority and responsibility of the NDE f
supervisor in administering tests and; evaluating and certifying per-sonnel.
This is very important as related to Code work, since ghe Level III will be working under the authority of the holder of the Code stamp.
s X.
INSPECTTON-There were ne deficiencies noted relative tas inspection; howev'er, it war noted that a large number of inspectfon personnet are receiving their first nuclear construction experience on the Comanche Peak site.
l As a consequence, it is necessary to improve the quality of inspection planning and to increase the TeveT of supervision and quality engineering Inspection planning should fdentify the required configuration support.
including applicable DC DDAs,. the features to be verified, the inspection method and acceptance criteria in order to minimize possible confusion h
and. error.
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TUGC0 OBSERVATIONS & REC 0t9fENDATIONS y,
.c XI.
TEST CONTR0t.
l A review was made of the TUGCa startup administrative procedures, with l
the following observation:.
1.
The procedures. appear to be written around the old organization; f
that is, in several instances they refer to the Brown & Root QA/QC input required in the preparation of "startup work requejits".
I Z.
It was noted that an unique systent is being established to handle noaconformances during the startup. phase. It is reconnended that whamver possibTe exis' ting schemes utilized in construction be used during the startup process. This is important since most personnel involved in dispositioning such items as nonconfonnances and design changes wiTT be the same persons. involved in construction.
XII.
CONTR0t. OF MEASURING & TEST EQUIPMENT f
It was observed that out'of kk instruments sampled whichr are utilized in civil, structurai, mechanfcat and. eTectrical work, approx.fmately 50 percent had not been withdrawn from the caTibration laboratory since its Tast caTibration date. This is. particularTy significant when it is recognized that the present system is such that if a calibration date W
becomes due the instrument is recalibrated whether or not it has been issued for use.
I It is recommended that consideration be given to simply changing the calibration date rather than going through a calibration i
cycle if the toot has not been used.
I It was noted that many construction toois are calibrated. It is important to note-that calibration of construction toots is not necessary with respect to 10CFR50 Appendix E.
Although calibration and maintenance is extremaTy important on construction tools, it may be that frequencies may be relaxed.
XIII.
INSPECTION, TEST AND OPERATING STATUS No deficiencies were noted in this area. Material and equipment l
observed in receiving inspection, in the warehouse and outside storage I
j TUGC0 OBSERVATIONS & RECOP9tENDATIONS.
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area appeared to be adequately identified. No tests were observed.
XIV.
HANDLING, STORAGE AND SHIPPING Exterior storage practices ~should be reviewed. The protective coverings of many items are damagedi some reported on monthly surveillance esports have not been corrected. Large temporary structures, such as those over the emergency diesel engines, require wind bracing to, prevent further damage. Because of soil chemistry, rain and humidity, ttle current pt ac- ~3 tice of aITowing Targe stafrtIsss steel piping to remain uncovered should be reviewed. Sensitized. stainiess. is extremeTy sensitive to chloride,.
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fluoride and'suTphide contamination Wtich with water as a couplant can j
cause intergranular corrosion and prematura faiTure.
XV.
CONTROL OF NONCONFORMANCES '
There appears to be an effort to reduca the number of documented non-conformances.
f It was noted that DC DDAs were being utilized for nonconformance reports.
ATthough this was observed arr a ses11 percentage of DC 00As issued during the monttr of ApriT. it is reconmended that this practice be stopped innediately. The TUGC0 systen is correctTy established whereby non-l conformances are written after the fact and DC 00As are reserved for design changes before the-fact. It is important that this practice be enforced since DC 00As. prepared after the t'act necessitate that workers be directed verbally to.vioTate the drawing since the deviatfort will be handTed after the fact with DC 00As. This is a poor Quality Assurance practice.
Procedure CPQT-AB,, Rev. 0,, dated 5-5J78 was issued for the purpose of providing expedient disposition of concrete oiscrepancies. The procedure infers that discrepancies of 72*F versus 70*F or 6.2% air content versus 6.05 maximum is perfectly acceptable when it is signed off by the field l
engineer. Such a system shortcuts the established nonconforming material l
controi system as defined in Brown & Root and TUGC0 procedures and should Q
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.,TUGC0 OBSERVATIONS & RECDPMENDATIONS~,
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be discontinued.
If tolerances are unrealistic such that the 72*F is acceptable, then the design specification should be changed to se indicate.
It is reconsnended that good inspection planning be provided inspectors, identifying the characteristics to be inspected, the method of inspection and acceptance criteria and that inspectors identify nonconformance's'to such criteria. Th,is will maintain the integrity of inspectors and provides identification of problest areas and provides a means for their correction.
It fs reasonable te assume thaion a project as. Targe.as. Comanche Peak, there w1T1 be severai thousand nonconformance reports. The number does not reflect adversely orr the quaifty of construction, but the failure te identify nonconformances does raffect adverseTy orr the integrity of f.
inspectors and Teaves unknown the quaTity of the plant.
XVI.
CDRRECTIVE ACTION There were ne deficiencies noted reTattve te corrective a: tion ort hard-ware. The SuppTier CompTiance supervisar has estabTished a method of f
tracking vender performance and ' hows positive results froar actions taken s
to correct supplier quality probTems. A review of reports of site sur-veillance conducted by TUGC0 showed corrective action responses were j
being promptly received. A review of' reports of surve11Tance actions by Brown & Root showed generaT1y adequate response and resolution of corrective action except for e period of four months whart survetT1ance personnel were assigned to other tasks.
In general,. corrective action appears to, be adequate and timely on vendor and site related problems, but some deffefencies identified irt audits of l
major contractors st117 persist. Some of the changes in authority dele-I gation to major contractors appears to be action taken to correct inadequate or untimely response by those organizations;. however,. other actions. taken, such as handling of field changes and nonconformances, appear to be those of circumventing the problem rather than correcting it.
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TUGC0 OBSERVATIONS & RECkhetENDATIES
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XVII.
RECORDS-Except for Tack of internal fire protection, the quality records area is considered to be satisfactory. Some Quality Assurance records, such as personneT qualifications, are not stored in the recordt center but l
are maintained separately by the Brown & Root training coontinator.
There is not curmntTy a catalog or Tisting of required records although,
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it is being prepared. A review. of a selection of Quality Assurance records. showed the documents in them to have been properly completed..
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an'd in the correct order.
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Reconnendation - The instatlation of an inert gas fire extinguishing
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systeer or the identification. of geographicaTTy separate duplicate records j
shouTd be expedited. TUGCU shouTd review the fire protection capabfif ties /
l 7
of storage facfTitfes. in the training supervisor's trailer and consider e dupTicate set of such records te be maintained in the records center.
XVIII.
AUDIT 5 There are severei audit and; survetTTance programs in effect. Audtts by the Quality Assurance Department Centrat Staff are perfonned on site activities, major contractors and suppTferr. Site surveillance actions are performed under the direction of the TUGC0 QA Site Supervisor. Similar 5i
>i survef1Tance activities ars carried out under the direction of the Brown &
Root Site Quality Assurance Manager. Whfie calied surveillance actions, the survatilancel programs are forma 1Ty planned and scheduled, utiliza checkTists to guide the activity and record resuits,. and issue reports of deficiencies and require correction. Except for formal and doctanented pre-audit and post-audit meetings,. aTT the elements of an audit program are in place. It was reported that the reason for calling the activity "surveiliance* was tot avoid outside auditors finding the program deficient because it did not incTude the documented pre-and post-audit meetings, yet the auditors found. that such meetings were conducted, but on an informal basis.
O Reconnendation - The auditors consider the present program to be an effective tool which could be further improved. TUGC0 should consider
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h., * ' TUGC0 CBSERVATIONS & REC 3 MEN 0ATIONS *
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,Q combining the audit and surveiTTance activities into a s. ingle, cohesive effort. Such arr integrated effort could cover required areas. more'
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efficientTy, without dupifcattorr and at a frequency that can be usin-tained. Such an audit progrant should be described in written procedures.
and include e descriptiort of both the fonnai audit and the continuous audit pian (surveiTTance) and the method of conducting pre-and post-audit meetings should be described to preclude later criticisms by outside organizations. The resulting audit progrant should be a superior tool f,or management assessment of progrur impTementation and effectiveness.
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J"lv T1 1072 J'.f f 9 Manacement Quality Assurance Audit RE C RTVED gp Jut 11 'e' P. G. BRITTAIN Attached are our resolutions to the findings and; reconnendations made-by Management Analysis Company as a result of their audit in May.
Our analysis of the audit results has been discussed in general tems with John Jackson, and we see no need to respond femally to this audit.
R.fr. Gary
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- f., 4 FINDINGS (APPENDIX A)
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1.
Finding Sussiary: Our QA Plan and Procedures do not reflect current authority delegations to 84R and to 64H.
Resoonse: At the time of the audit we were operating under properly approved deviations. These deviations were incorporated into a pennanent QA Plan Manual revision ort July 1,1978.
l 2.
Finding Summary: The current practice of after-the-fact design change review provides significant risk of error and is in j
noncompliance vith 10 CFR 50 Appendix 8.
Response: We disagree; orr Eth counts. The G4H Resident Engineer has exercised extremely good, judgment in implementing Se aumority i
delegated to him. Of the approximately 2000 cnanges/devia-tions/ clarifications issued under the systas, we are aware of none i
that have provided exposure to a significant risk of er.or. To6 provide greater visibility of the design change function, a system was, implemented on May 25, 1978 mat provides an analysis of all changes and peneits continuing evaluation of the field efforts.
This syster is current for ongoing activities at the present time i
and wtli be completed for past activities on or before July 15, 1978. Our belief that we are in fact in compliance with 10 CFR 50, Appendix B is supported.by internal audits by TUGC0 QA personnel and independent audits by twar separate NRC Inspectors. We propose to i
Teave the design change system as is.
7.
Findine Summan: TUGC0 QA does. not review all procurement documents and changes tnereto prior to release.
Response: We disagree 24t' this is a requirement. A separate QA requirement section, approved by TUGC0 QA, is included with each l
purchase order and is applicable to all supplements. Changes to these requirements are authorized only by Quality Assurance.
i 4.
Finding Sunuman:. The current array of QA manuals and procedures is c5splex and, difficult to maintain, R_eJ conse: We agree. The new. Plan manuai was issued July 1,1978.
1 Tliit corporate QA Program. Manual is currently under study with the l
goni of streamlining it.
5.
Finding Susunary: Records do not reflect the as-poured configuration clearly.
I Response: Configuration has always been made visible to inspectors,
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and steps have been taken to improve the visibility for the record.
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Finding Summary: Markings for in-service NCE inspections were not always distinct.
Response: We agree that such markings should be legible. QC will inspect special process f5I markings prior to turnover.
7.
Findino Summary: We are using the DC/DOA (design change) program to bypass the nonconforinance system.
Response: This is not true. If construction identifie's and corrects a. defect or obtains ar approved engineering change prior to QC. inspection. no NCR.1s. required.
8.
Finding Summary: The records storage facility does not have internal fire protection during off. duty hours.
Response: An inert gas fire protection system is on order by TUSI.
Target date for installatforr is. August I,1978.
9.
Finding Summary: ApproximateTy 245 of ~ audits scheduled by Dallas.
attaff aave not been ennducted. Audits by TUGCG and.BAK shouTd be combined in one overaTT effort.
Response: Our audit scheduTe is constantly being revised tz reflect changing manufacturing status and to alTow us to use audits to investigate problem areas of the most innediate concern as they aris6. We believe we can defend our audit program, and are leaving' it as it is, j
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OBSERVATI0liS AND REC 04MENDATIONS. (APPENDIX. B)
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Organizatforr Recommendation: Separate inspection from Quality Engineering (planning).
Response: We had begun work on this before the audit. Our prodict assurance group has taken responsibility for Quality Engineering.
i Recommendation: Re-evaluate the charter of the Quality Surveillance'
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Commi ttee.
Resoonse: We have decided to discontinue the Quality Surveillance Committee. Instead, TUGCQ QA Manager wili issue a. report quarterly to keep top annagement apprised of the status of QA matters,.
including quality trends. The first sucit report will be issued by August 18,1978.
Recommendation: Hire more seasoned inspectors. Hire any future engineers from outside 2e company wittr experience in nuclear plant a
construction.
RgggLn,g-We are on the Tookout for well qual.ffied; personnel and cont < nm to, review applicants from outside @e company. The reTatively young inspectors will be strengthened best and quickest by taking from them the responsibtif ty for inspection pTanning and providing them witir adequate, but concise instructions and checklists. This has beert done and is effective.
2 II Quality Assurance Proorg J
i Recommendatfon: Revamp our present QA manual system.
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Response: We agree. TUGC0 QA issued a revised QA Manual on July 1, 1978.
Ooinfort: Otttainfng: our ASME Code stamp wtii be diff1 cult if all the wort, is done by others.
i Response: We know it will be difficuit, but it can be done. The report does not accurately record our stated reason for obtaining an N-stamp.
l III Desf an Control l
Reconenendation: Abandon our present system of expediting field o
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changes.
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Response: We disagree for masons stated on Page 1.
V Instructions Recommendation: Streamline inspection planning and. checklist preparation Response: We agree, and have been active in this effort since January.
Recommendation: Discontinue mapping individual standard imbeds.
Response: Mapping has been discontinued, but we have retained a
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reasonaale degree of traceabflity on embedded items.
Recommendation Combine construction and-QA procedures.
Response: Sfnce January we have been doing this for new procedures anti wnen revising old procedures.
Reconnendtion: Discontinue requiring BAR Houston approval of procedures.
Response: All procedures except those invoTving ASME Code work are now approved at the site.
Observation: All appTicable DC/D0A?s are not included in supporting i
documentation.
Response: Refer to Page 1, Appendix A,. Itenr E.
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Reconnendatfon: Establish a formal site procedure for planning construction work.
Response: This planning is. being done. We don't intend to create a fonnal procedure for it.
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e VI Document Control O
Observation: The ARMS system should be backed up by a manual system (stated verna11y in exit management interview).
Resnonse: The auditors' lack of confidence in ARMS was the result of < nsufficient familiarization. with the system on their part.
VII Control of Purchased Material. Equipment, and Services Observation: The @ Plan is not up to date in this. area.
Response: Manual revision wes. compTeted on July 1.
Statement:. Source inspectors. (TUGC0 @) appear to be at the mercy of the supplier in determining what changes have beerr incorporated.
Response: This is not true. We (TUGC0 @) prepare our own checklists after searching the appropriate files. We agree with the auditors' (verbal) consents that this method places an additional burden on ourselves; however, the orfginal (and. Togical) approach of depending upon-Galt to prepare the checklists did not work.
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VIII Tdentificatiom and Control of Materiefs. Parts, and Comoonents No observations l
l IX Special Processes Reconnendation: The use of Iriditan 192 should be replaced by x-ray for all shop welds and for field welds where practical.
Response: Brown & Root is studying this reconnendation,. and is committed to have a report for TUGC0/TUSI by July 15.
Reconnendation: Reduce the mmber of individuais reviewing, radiogcaphs and estabitsh the policy tnat Code-acceptable indications. be recorded. but not repaired.
Response: This had been accomplished prior to the audit, but apparently the auditor talked with someone who wasn't aware of it.
ReconnendationJ Clarify the responsibility of the NDE supervisor relative to code work.
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s Response: The auditors were confused in this area. Our only Level
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insoection Included here was a 're-statenant of observations covered elsewhere in the report.
XI Test Control Recosanndation: Existing nonconformance control systems shduld be..
used during startup.
Response: The new @ Manuai,, with fnput fros TUGC0 Operations, will address. nonconformance controi systems.
XII ControT of Measurtne and Test Ecufoment Recommendation: Equipment should not be recalibrated; on the due date if it has not been used.
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Reunonsie: The recommendation has, been adopted for items whose co'sbration is not subject tar change while not fit use.
Impiamentation date wes July 1 XIII Inspection. Test and Operattne Status No observations
!i XIV Handiing, Storsoe and Shiocing i
Recommendation: Exterior storage & protectiorr practices should be reviewed.
Response: We had previously reviewed, the storage practices and have-ne reason to believe that a probian exists. Various NRC fnspectors have also inspected thfs activtty However,. Westinghouse is rewfewing this, and their met:11urgist will report by July 15.
XV Controi of Nonconformances Observation: This is a restatenent of concern over nonconformance j
control.
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Response: We reject the inference Oat problems are ciretavented ratner than corrected at CPSES.
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XVI Cerrective Action-Na specific findings.
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XVII Records l ~I
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Reconnendation: This section restated the need for fire protecti.on system.
E e' Response: The inert gas system will be installed by August 1,1978.
XVIIIAudits-Recommendation: The audit (DaTias) and surve11Tance (site) f.,
activities should be combined.
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Respon$r: We intend to Teave our audit progan. separate from site f
survei' ance.
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