ML20199H298
| ML20199H298 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Comanche Peak |
| Issue date: | 08/24/1982 |
| From: | Donna Anderson TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML17198A302 | List:
|
| References | |
| FOIA-85-299, FOIA-85-59, FOIA-86-A-18 CQI-CS-4.6, NUDOCS 8607030259 | |
| Download: ML20199H298 (15) | |
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PROCEDURE /
ISSUE TEXAS UTILITIES GENERATING CO.
INSTRUCTION REVISION PAGE DATE NUMBER J
COI-CS-4.6 3
8/24/82 1 of 13 CONDUCT OF INTERNAL, PRIME, PREPAREDBY:[.I.
8[M/d2 AND SUBCONTRACTOR AUDITS DATE APPROVED BY:
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- g, CRMATION ONLY 1.1 Purpose To establish the methods by which TUGC0 Quality Assurance Services Audit Personnel will conduct audits of TUSI, TUGCO, subcontractors, the A-E and the NSSS Supplier.
1.2 Scope This instruction addresses scheduling, preparation, reporting and follow-up activities necessary to conduct the required audits of TUSI, TUGCO, Subcontractors, the Architect-Engineer and the NSSS Supplier.
1.3 Definitinns - None 1.4 References 1.4.1 CQP-CS-4 " Procedure to Establish and Apply a System of Pre-Award Evaluations, Audits and Surveillances."
2.0 RESPONSIBILITIES 2.1 TUGCO, Vice President, Nuclear - Takes management actions as necessary to assure that corrective actions to deficiencies are accomplished in a timely manner.
2.2 Manager, Quality Assurance - Provides assistance as required to assure that corrective actions are promptly addressed and implemented. Reviews signs and transmits reports and evaluations. This authority may be delegated in writing.
l 2.3 Quality Assurance Services Supervisor - Initiates follow-up actions to assure that corrective actions are addressed and implemented in a timely I
manner. Reviews and initials audit reports and evaluations.
2.4 ' Supervisor, QA Audits - Schedules audits and issues notifications.
Assigns team leaders and members.
8607030259 860623 f.i i{
I PDR FOIA GARDE 86-A-18 PDR I
., Chi-CS-4.6,Rev.3 Page 2 of 13 2.5 Audit Team Leader - Responsible for orientation of team members and for the preparation, conduct, reporting and follow-up activities required for an audit.
3.0 INSTRUCTION 3.1 Scheduling 3.1.1 Audits will be scheduled as required in Reference 1.4.1.
3.1.2 The Supervisor, QA Audits will notify responsible management at l
least two weeks prior to the audit date. A formal notification memo should be issued; however, a telephone conversation record is acceptable.
(Example 1) a.
The notification should include:
1.
audit date 2.
audit team members / team leader 3.
scope 4.
time for the pre-audit meeting 3.1.3 The Supervisor, QA Audits will assign the audit team leader and l
team members and notify them accordingly.
3.2 Preparation 3.2.1 The Audit Team Leader will prepare for the audit by compiling and reviewing the following documents as appropriate:
a.
previous audit reports b.
applicable procedures c.
appropriate regulatory requirements l
3.2.2 A checklist shall be prepared using previous audit results and procedures, and regulatory requirements as appropriate.
l a.
A sample size should be selected where applicable.
b.
The checklist shall be approved prior to use by the Supervisor, QA Audits or Quality Assurance Services l
Supervi sor.
l 3.2.3 The Audit Team Leader will prepare an audit plan (Example 2) and will discuss the plan with audit team members prior to the audit.
a.
The audit plan shall address the following:
1.
audit scope 2.
requirements 3.
activities / organizations to be audited 4.
audit schedule 5.
checklist and/or procedures 6.
applicable documents
CQI-CS-4.6, Ree. 3 Page 3 of 13 3.3 Performance 3.3.1 The Audit Team Leader shall conduct a pre-audit conference at the audit site with cognizant organization management.
a.
The following should be addressed during the pre-audit conference:
1.
obtain signatures of attendees l
2.
introductions 3.
present the audit scope and plan 4.
discuss the audit sequence 5.
establish channels of communication 3.3.2 The auditors shall use checklists and/or procedures to conduct the audit.
)
a.
Checklists are intended to be used as a guideline.
Should the audit results warrant, auditors may deviate from the checklist requirements to assure adequate control of the activity.
b.
Additicnal notes may be used as necessary to supplement the checklist.
3.3.3 When an auditor identiffes a deficiency, the auditor shall conduct further investigation in an effort to identify the cause and effect of the deficiency.
3.3.3.1 The auditor shall exercise judgment to determine if the deficiency involves a nonconfonnance which requires immediate corrective action. These shall be reported to responsible management immediately.
3.3.4 For items where no direct violation of a requirement exists, but the auditor has noted a potential problem or item requiring some clarification; the following categories may be used.
a.
Concerns - Items which could potentially develop into a deficiency m y be listed as concerns.
1.
The auditor will detennine if action is recommended and a response required or if bringing it to management's attention is all that is necessary.
b.
Comments - This category may be used if the auditor feels the need to document questions which may have surfaced during the audit, emphasize or record commitments made, provide clarification of an audit item, etc.
1.
No response is required.
3.3.5 The Audit Team Leader shall report the results of the audit during a post-addit conference with responsible management personnel.
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,C l-CS-4.6, Rev. 3 Page 4 of 13 a.
The following should be addressed during the post-audit meeting.
1.
deficiencies, concerns, and comments identified and recommendations as applicable 2.
clarify misunderstandings 3.
establish a tentative course and schedule of corrective actions 4.
any holds which may be put in place as a result of deficiencies identified 5.
obtain signatures of post-audit attendees 3.4 Report 3.4.1 Upon completion of the audit, the Audit Team Leader shall assemble the audit package.
It should contain the following:
a.
list of attendees of the pre-and post-audit meetings b.
completed checklists c.
auditor's notes, including deficiencies, concerns, and comments identified 3.4.2 The Audit Team Leader is responsible for defining any necessary format for the report.
Each individual team member is responsible for their input in the proper format.
3.4.3 The Audit Team Leader shall prepare, sign and issue the audit report, preferably within 15 days but not later than 30 days from the post audit meeting.
a.
The audit report shall contain the following:
1.
identification of audit team members, personnel contacted, and attendees of the pre-and post-audit meetings 2.
audit scope 3.
date of audit 4.
audit summary, including an evaluation of the effectiveness of the QA program elements audited 5.
status and evaluation of corrective action commitments to previous audit findings, if applicable 6.
deficiencies, concerns, recommendations, and comments as applicable 7.
schedule for corrective action implementation, if possible 8.
Request response within 33 days 3.4.4 The Supervisor, QA Audits and Quality Assurance Services Supervisor shall review and initial the report. The Manager, QA shall review and sign the report.
3.4.5 The report shall be distributed to cognizant management of all involved organizations. Additional internal distribution may be indicated.
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CQI-CS-4.6, Rev. 3 Page 5 of 13 3.5 Follow-Up 3.5.1 The Audit Team Leader shall evaluate the response and prepare an evaluation letter.
a.
If the response has not been received within the allotted time frame, the following steps will be initiated.
1.
The QAS Office Assistant or Audit Team Leader will contact the responsible person by phone and determine the reason for the delay. A new response date will be agreed upon within a reasonable amount of time.
2.
If the response has still not been received at the end
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of the agreed upon time, items a - d (below) will be initiated for site responses. For prime contractors / subcontractors, the QAS Supervisor and Manager, QA will be involved and actions taken as appropriate to resolve the problem.
a.
a memo will be issued by the Manager, Quality Assurance. (See Example 3) b.
the memo will be telecopied to the responsible person c.
three (3) additional days response time will be allowed d.
copies of the memo will be distributed to the following management, as applicable:
1)
TUGC0 Vice President, Nuclear 2)
TUGC0 Executive Vice President and General Manager 3)
TUGC0 Manager, Nuclear Operations 4)
TUSI Executive Vice President 5)
TUSI Vice President and Project General Manager - CPSES 3.
At the end of the three days, if the response has still not been received, the TUGC0 Vice President, Nuclear will be involved and appropriate actions will be taken.
4.
All telephone conversations regarding the overdue response will be documented and placed in the audit file.
,,CCI-CS-4.6, Rev. 3 Page 6 of 13 3.5.2 The evaluation should address responsiveness and adequacy of corrective actions.
a.
If the respnse is satisfactory, an evaluation letter (Example 4) shall be prepared.
b.
If the response is unsatisfactory, the evaluation letter should include the reason the response is unacceptable and assign a new response due date (Example 5).
3.5.3 The evaluation letter shall be reviewed and initialed by the Supervisor, QA Audits; the QAS Supervisor; and reviewed and signed by the Manager, Quality Assurance.
3.5.4 Distribution shall be in accordance with paragraph 3.4.5 above j
3.6. Verification of Corrective Action 3.6.1 Verification of implementation of corrective actions shall be accomplished by appropriate means.
3.7 Audit Records 3.7.1 The following records shall be maintained in the applicable audit file by the QAS Office Assistant or QA Secretary:
a.
notification letter b.
completed checklists and/or procedures c.
auditor's notes d.
audit report e.
request for response memo, if applicable f.
response g.
evaluation and closeout Audit Notification Letter Example 1 Example 2 Audit Plan Request for Response Example 3 Evaluation Letter - Acceptable Response Example 4 Evaluation Letter - Unacceptable Response Example 5
QTE-396 M i-6 4 0. *ev 3
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rage / oi la TEXAS UTILITIES GENERATING COMPAhY OTTICE MEMOR ANDUM
.e____J. C. Kuvkendall Daum, Texu June 1. 1981 s
Comanche Peak Steam Electric Station Subjee TUGCo QA Audit Notification TUG-5 Startup Activities June 22 - July 2,1981 QA Audit File: TUG-5 This will document the telephone conversation between George Smith and Debra Anderson on May 27, 1981 with regard to an audit of Startup Activities. The audit has been scheduled for June 22 - July 2,1981.
The audit scope wil,1 include, but not be limited to, the following:
1)
Compliance with FSAR Chapter 14 2)
Review of Reactor Operating /Startup Experiences 3)
Personnel Training / Qualifications 4)
Release from Construction to TUGCo 5)
Custody Transfer Tagging 6)
Safety Tagging 7)
Work perfomed on equipment in Startup Custody S)
Maintenance 9)
Design Changes The audit teams will be organized as follows:
e Items 1 - 3: Debara Paris Tony Valdez
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Bobby Shoemake - Acting Team Leader Items 4 - 9: Debra Anderson Bailey Campbell Richard Curtis - Acting Team Leader s
We plan for the pre-audit meeting to begin on Monday, June 22 at 9:30 a.m.
Please arrange for a conference room for this meeting.
Should you have any questions, please contact Debra Anderson at 214/653-4882.
D.N.C[ap Jfs Manager, Quality Assurance DNC/AV/DLA:kh cc:
B. R. Clements R. E. Camp R. A. Jones D. E. Deviney e
<J. T. Merritt s
R. G. Tolson
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' COf-CS-4.6, Rev. 3 Page E of 13 EXAMPLt 2 TUGC0 OA AUD]T PLAN VENDOR / ORGANIZATION:
TUGC0 STARTUP AUDIT NO.:
TUG-5 AUDIT DATE:
June 22 - July 2, 1981 AUDIT SCOPE: The following Startup Activities:
Team 1 - Compliance with FSAR Chapter 14 Team 2 - Release from Construc-tion to TUGC0
- Review of Reactor Ooerating/
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- Custody & Safety Tagging Startuo Experience
- Personnel Training /0ualification
-Work oerformed on Eouio-ment in Startup Custocy
-Maintenance
-Design Changes AUDIT REQ'JIREMENTS:
Comoliance with FSAR Chaoter 14 & Startuo Administrative Pr.ocedu res APPLICABLE DOCUMENTS:
FSAR Chapter 14, Startuo Administrative Procedures, Oceratier.s OA Plan AUDIT SCHEDULE:
Monday, June 22, 1981, 9:30 am - Pre-audit meetine June 22 - July 1, 1981 - Audit Thursday, July 2, 1981, 10:30 am - Post-audit meeting CHECKLIST AND/0R PROCEDURES: ATTACHED DISTRIBUTION: AUDIT TEAM MEMBERS: Team 1 - B.Shoemake(Acting Team Leader)
AUDIT FILE: TUG-5 D. Paris T. Valdez Team 2 - H. Campbell (Acting Team Leader)
D. Anderson f
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TEXAS UTILITIES GENERATING COMPAhT
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O T TI CE h0E M O R A N D U M Dallas, Texas Te Comanche Peak Steam Electric Station
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subka Request for Immediate Response TUGC0 QA Audit / Surveillance No.
QA Audit / Surveillance File:
TUGC0 QA Audit / Surveillance No.
was transmitted to you via (log number) dated In accordance with ANSI K45.2.12, your response was cue by (due date)
As of the date of this memo, no response has been receiveo.
Your response must te received by TUGC0 OA Dallas no later than (3 days from date of memo)
Failure to respond by this date will result in tnis matter being turned over to the TUGC0 Vice President - Nuclear for resol uti on~.'
D. N. Chapman Manager, Quality Assurance DNC/AY/
cc:
TUGUU Yice President, Nuclear As Acolicable:
f TUGCC Executive Vice President & General Manager sa?
TUGC0 Manager, Nuclear Operations TUSI Executive Vice President
'TUSI Vice President and Project General Manager - CPSES I
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OTTICE MEMOR ANDUM To J. T. Merri2t Dallu, Tern December 8.1980 Comanche Peak Steam Electric Station
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Subjee k
Evaluation of Audit Response TCP-15 OA Audit File: TCP-15 Your response to the deficiency identified during our audit TCP-15 has been evaluated by TUGC0 QA. Based on your corrective action, please consider all items to be closed.
No further response is required at this time.
Thank you for your cooperation.
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w Manager, QJality Assurance DNC/AV/ JAY:1fj cc:
B. R. Clements R. G. Tolson R. F. Curtis I
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TEXAS UTILITIES GENERATING COMPAhT Page 11 of 13
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OFFICE MEMOR ANDUM June 11, 1981 J. T.' Merri tt COMANDiE PEAK STEAM ELECTRIC STATION
- Subj, Evaluation of Audit Response TCP - 12 Follow-Up QA Audit File - TCP-12 Follow-Up Your response to cur audit TCP-12 Follow-Up hks been evaluated by the TUGC QA staff.
An Attachment A to this report contains an evaluation of each finding.
additional response to Deficiency Nos.1, 2 and 3 is required by July 14, f
In your resp.onse please provide the information requested in the 1981 evaluations.
Should you have any further questions, please contact J. Antonio Yaldez at 214-653-4894.
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). N. Chapt.an
~ Manager, Quality Assurance i
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B. R. Clements
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R. G. Tolson W. G. Parry d
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ATTACHMENT A
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EVALUATION OF TCP-12 FOLLOW-UP
RESPONSE
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Page 13 of 13 TCP-12 Follow-Up Def tetency No.1:
Finding No.1.
As you stated, the cause of this finding was' that the fabrication drawing had solid lines rather than phantom lines for one of its structural sembers. An additional response describing what was done to determine and to prevent recurrence of the underlying cause of this finding is required.
Also, please include the attendance record of personnel that attended the training session.
Finding No. 2.
TUGCo QA acknowledges that CE-11039, Revision 2 was issued to reflect the as-built condition. However, the cause of this finding was that a traveler was not issued for CMC 11039, Revision O.
An additional response describing what was done to determine and to prevent recurrence of the underlying cause' cf this finding is required.
Also, please include the atteadance record of personnel that attended the training session.
O' Deficiency Ro. 2:'
TUGCo QA acknowledges the issuance of IRN Wo. 118567 and the comitment to replace the affected cable connection cards.
An e,dditional response is required. The response is to consist of the atte, dance record of personnel that attended the training session.
Deficiency No. 3:
TUGCo QA acknowledges the correction of the affected Megger Cards.
An additional response is. required. The response is to consist of the attendance record of personnel that attended the training session.
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