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HUASCO S E llVI C E SINCU11POR.\ FLU

UTILITY C' JULTANTS - ENGINEERS - CONsTRUCTCRS

T\VD HECTOR STRELTN EW Y O R K. N. Y. 10005

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March 1, 1979

Mr. Karl V. Seyfrit, DirectorU. S. Nuclear Regulatory Co= mission [

iRegion IV611 Ryan Plaza Drive, Suite 1000Arlington, Texas 76011

Re: NRC Letter f rom Mr. K. Seyf rit, Docket No. 99900505 ,

Inspection Report No. 99900505/79-01 dated February 1, 1979 f

Dear Mr. Seyfrit:

In response to your letter to Mr. B. E. Tenzer dated February 6, 1979, thefollowing information is hereby submitted. Our responses are identified inaccordance with the paragraph numbers used in Enclosure 1 to yout letter," Notice of Deviation".

NOTICE OF DE77ATION - ITEM A

Audit Records

In accordance with ANSI 45.2.9, Ebasco established the list of requiredQuality Assurance records which are delineated in Ebasco Quality AssuranceProcedure QA-G.4 " Quality Assurance Engineering Records". Ebasco Quality

Assurance Procedure D.5 " Internal Audits" also identifies those InternalAudit records designated as permanent.

The~se procedures have been audited by the NRC Region IV Inspection teamduring the following inspections:

99900505/75-0299900505/75-0399900505/76-0399900505/77-03

Based on the precedent in which secti:ns QA-II-9 & QA-I-6 of ETR-1001 andthe procedures (D.5, G.4 & E-58) were audited, we feel it is inappropriatefor the NRC to modify its interpretations of our Topical coccittments atthis late date.

However, in response to the finding of NRC Inspection Report No. 79-01, wewill modify our procedures on the subject to indicate that Internal Audit worksheets developed through the auditing of Nuclear Projects designed under Ebasco'sTopical Report ETR-1001 will be placed and retained in the Ebasco QualityAssurance Records System described in Section QA-I-6. This practice will begin

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EB3SCO SERVICCSiuanton ur n -2- March 1, 1979

Mr. Karl V. Seyfrit, DirectorU. S. Nuclear Regulatory Commission

on March 1, 1979 and all future audit reports will be processed in_accordancewith Quality Assurance I=plementing Procedure G.4 " Quality Assurance EngineeringRecords". The existing Internal Audit Record file numbers approximately 900folders or 5,000 pages of records. These records will be reproduced and placedin the Quality Assurance Engineering Department Secondary Record File. Thetransfer of this sizeable backlog of material vill be completed by December 31,1979.

NOTICE OF DEVIATION - ITEM B

Management Audits

1. Section II, Item B.3.c of the NRC Inspection Report correctly points outthat the Consulting QA Engineer (Management Audit Cocmittee Chairman)specified follow-up action on the 1977 Management Audit findings. Thereis no record of this having been carried out, nor can there be found inthe files any other correspondence related to follow up and closure.Therefore, a re-audit by a Management Audit Committee member working inthe New York office appears to be the feasible corrective measure for thisitem. This will be scheduled in conjunction with the pending 1979 ManagementAudit. To preclude a recurrence of this ites the Management Audit Log wouldbe maintained by the Quality Prograr Coordinator who will review this Logon a quarterly basis.

2. This finding reports that the 1976 Management Audit Report was not maintainedby the Audit Committee Chairman. It is considered to be explained by thechange in the Management Audit Coccittee's scope of responsibilities inaccordance with ETR-1001, Section QA-II-9, Revision 1, dated 11/16/76.From early June 1976 through the end of that year. the Management AuditCommittee was inactive while its responsibilities were being re-defined,and 1976 files were maintained by the Quality Program Coordinator. Four (4)management audits were conducted in 1976, all within the first half oftt year and in accordance with Section QA-II-9, Revision 0. However, thereis no record of follow-up and closure action being perfor=ed on deficiencies,attribucable to the Cocmittee's inactive status. The.ae activities will be.'scheduled for re-auditing during the first half of 1979 by whichever groupis now responsible for the area, the Internal or Management Audit group.

3. The system (log) for status of deficiencies has been a requirement ofCompany Procedure E-58 since December 1976. The log in its current formwas initiated in 1978. Prior to that year, status of deficiencies wasrecorded by memo. For 1976 and 1977, the status is as stated under

Items B. (1) and B. (2) above. For 1978, the copy of the log on file inthe N. Y. office did not show Deficiency Findings Nos. 1, 2 and 3 to besigned off as closed. However, J R Ice memo of 12/20/78 to W C Hermanreporting on Reaudit No. 2 recommended closure of these findings and hissignature will close out these items. Again, the log will be maintainedup to date in the future by the Quality Program Coordinator.

CBTSCO- SEIRICES, ncaa r a irc a -3- March 1, 1979

Mr. Karl V. Seyfrit, DirectorU. S. Nuclear Regulatory Commission

NOTICE OF DEVIATION - ITEM C

Foll'ow Un on Vendor Evaluations

The two vendors identified in the NRC Inspection Finding have been recontactedand have submitted their corrective action responses. Follow-up audits toverify the i=plementation of the corrective actions reported by the vendorswill be accomplished by May 30, 1979. To prevent recurrences of vendor non-responsiveness and to survey findings, Ebasco has established a CorrectiveAction Follow-Up Log which was initiated on 29 January 1979 and will beutilized on our future audits to trigger prompt vendor actions.

OPEN ITEMS - ITEM D

Ceneral Statement

! In response to the NRC comment requesting "tha steps you plan to take to! assure that Management coccitments will be met in the future", deviations! uncovered during QA program inspections conducted by the NRC will be loggedj in an Audit Su= mary Reference Sheet (Status Log) for all future inspections.

This Log will identify the Ebasco organization responsible for the corrective1

} action and provide the mechanism for monitoring the actions taken to correctI the ites. Accomplishment of the proper corrective action will be a subject

of regular internal auditing. However, in addition, at specified periodsthe Status Log will be utilized by the Chief Quality Assurance Engineer toascertain that all required actions have been accomplished.

Refer your Section I Paracraoh,B,.1

Secondary Files

Ebasco's coccitment date for this ites was based on a significant underestimation*

of the quantity of Q-designated project documents being assembled and designatedas permanent records. Schedules have now been set up at Ebasco's Nuclear Projectprimary files to require a rate for a given quantity of non-duplicated primaryfile material to be moved through microfilmning to the secondcry files. Theseschedules will be carried out to eliminate the existing backlogs at the primaryfiles and provide current secondary files for each Nuclear Project. Completionof this microfilming will be by December 31, 1979.

Refer vour Section I Paragraph B.2,

Normal Review of Drawings

This item relates to the handling of interdisciplinary reviews of drawingsother than the reviews required for safety-related drawings. A revision toEbasco Company Procedure E-7 (formerly E-71) " Processing Drawings for Reviewand Approval" will be distributed by >brch 15, 1979. This revision specificallydefines the methods of controlling " normal review" on drawings.

C D.lS ED . SERVICES: sc onf o s ui n -4- March 1, 1979

Mr. Karl V. Seyfrit, DirectorU. S. Nuclear Regulatory Commission

The back-up history file for all drawings that have been completed will bebackfitted with the documentation attesting to the review received. Thedrawings for which documentation of interdisciplinary reviews is missingwill be re-issued to those affected by the revision.

For all other drawings, the history file will be reviewed as the drawingsare issued for revision. Where documentation for previous reviews is foundlacking, the drawings will be issued for review covering the current, as wellas, previous revisions. The documentation will be in accordance with the newE-7. procedure.

Corrective action will be completed by May 31, 1979.

RefSr your Section I Paragraph B.3

Document Review List for Specifications

The Document Review List for Specifications previously issued without QAEngineering department approval was re-issued June 1, 1978 with all properauthorizations in accordance with Ebasco Company Procedure E-21 (old E-73)" Processing Project Unique Specifications for Review and Approval".

However, due to comments made by the NRC Inspectors during Inspection 78-02,a further revision of the list was initiated in July 1978. This revisionaddressed the guidelines of E-20 (old E-56) " Guidelines for SpecificationReview". These guidelines are not referenced in ETR-1001. The review processon this second revision of the review list generated numerous cocments, per-taining to revising review requirements on specifications for equipment thathad been shipped.

All comments have been resolved and the list will be' issued by March 31, 1979.

At that time, specifications issued since July 1977, that do not have adequatedo.cumentation of required reviews will be re-issued to those disciplines notpreviously included on the Document Review List for Specifications and processedin accordance with Ebasco Company Procedure E-21, " Processing Project UniqueSpecifications for Review and Approval".

Corrective action will be completed by May 31, 1979.

Refer your Section I Paragraph 5

Project Uniaue Procedures

The Engineering Department procedures which were revised for the WPPS Projectto become project unique procedures have been approved by the Manager ofStandards and Procedures. The distribution of these controlled proceduresto all cognizant personnel will be completed by April 1, 1979. All futuremodifications to Company Standard Procedures will be accomplished in accordancewith Company Procedure A-1 " Procedures - Authorization and Preparation" datedFebruary 15, 1978 which will require approval of the Manager of Standards andProcedures.

CUTSCO .SCRVICES.iitaaroa uro -5- March 1, 1979

Mr. Karl V. Seyfrit. DirectorU. S. Nuclear Regulatory Commission

Refer your Section I Paragraph B.6

Calculations

The findings against the documentation and filing of calculations by the; Applied Physics Department have been addressed. Calculation books

(Nos. 3Al-005, 3Al-006 and 3Al-007) have been provided with cover sheets,i

i tables of contents, proper references, etc. and in all other ways has

3 co= plied with the requirements of Ebasco's Implementing Procedure E-30- " Preparation of Calculations". The Applied Physics Depart =ent has completed

a thorouah review of upgrading of its docu=entation of calculations.Monitoring of this technical area will be maintained at a tightenedinspection level to provide assurance of continued effectiveness.

Refer your Section I Paragraoh B.7

Revisions to Controlled Manuals

. The coccitments of our A2 gust 10, 1978 letter have been met.IL

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Very truly yours,

h$ M WB E Tenzer, DirectorMaterials Engineering and

j Quality Assurance

1k RFW/=b

h cc: L F C ReichleB R Mazo

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