IR 05000498/1980036
| ML19341C408 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/30/1980 |
| From: | Crossman W, Gilbert D, Randy Hall, Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341C405 | List: |
| References | |
| 50-498-80-36, 50-499-80-36, NUDOCS 8103030358 | |
| Download: ML19341C408 (13) | |
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a U. S. NUCLEAR REGULATORY COMMISSION W
OFFICE OF INSPECTION AND ENFORCEMENT
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REGION IV
l Report No. 50-498/80-36; 50-499/80-36
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Docket No. 50-498; 50-499 Category A2
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Licensee:
Houston Lighting & Power Company Post Office Box 1700 Houston, Texas 77001 i
Facility Name:
South Texas Project, Units 1 and 2 l
l Inspection At:
South Texas Project, Matagorda County, Texas l
Inspection Conducted:
November 17-21 and December 1-4, 1980 Inspectors:
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gm W. G. Hubace)c, Reactor Inspector, Projects 4 ate Section (Ps.ragraphs 1, 2, 3 & 4)
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f.D. Gilbert,ReactorInspector, Engineering Dat6
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Support Section (Paragraphs 1, 3 & 4)
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Approve /:eyW. A. Crossn}an, Cnief, Projects Section
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R. E. Hall, Chief, Engineering Support Section Dats
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e Inspection Summary:
Inspection on November 17-21 and December 1-4, 1980 (Recort No. 50-498/80-36; 50-499/80-36)
Areas Insoected:
Routine, announced inspection of construction activities including items of noncompliance, unresolved items, and Show Cause Order items.
The inspection involved seventy eight inspector-hours by two NRC inspectors.
Results:
No violations were identified.
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DETAILS l
1.
Persons Contacted
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Principal Licensee Emoloyees
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]R.A.Frazar, Manager,QualityAssurance L. D. Wilson, Project QA Supervisor
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,T. J. Jordan, Supervisor, Quality Systems
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.J. B. Anderson, Quality Specialist C. L. Harvey, Quality Spec 1P ist gL. K. English, Site Manager
.L. Zwissler, QA Staff Consultant
l R. L. Hand, General QA Supervisor
Other Personnel
- 0. J. Harris, Manager, Quality Engineering, Brown & Root (B&R)
T. L. Porfilio, Design Quality Engineer, B&R R. J. Purdy, Assistant Manager, QA Systems, B&R i
,J. Ruud, Supervisor, Quality Engineering, Management Analysis Company (MAC)
F. G. Miller, Project Welaing Engineer, B&R
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.R. H. Leasburg, Site Manager, B&R
R. Kerr, QC Engineer, B&R
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The IE inspectors also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.
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3DenotesthoseattendingtheexitinterviewonNovember 19, 1980.
. Denotes those attending the exit interview on November 21, 1980.
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Denotes those attending the exit interview on December 4, 1980.
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2.
Licensee Action on Previous Inspection Findings t
(Closed) Unresolved Item (50-498/79-13-3.c; 50-499/79-13-3.c):
Illegible Procedure and Effective Dates of Revised Procedures.
Brown & Root Procedure ST-QAP-2.3, " Documentation Administration," which included examples of illegible stamp imprints, has been superseded by procedure ST-QAP-17.1, " Records Centrol," Revision 1, dated July 30, 1980.
ST-QAP-17.1 does not contain examples of stamp imprints.
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Brown & Root Procedure ST-QAP-6.1, " Procedure Development," Revision 1, dated October 15, 1980, addresses requirements for stating the effective
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dates of revised procedures.
The IE inspector observed that effective dates are now indicated on quality assurance procedures.
The IE inspector had no further questions on these matters.
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I (0 pen) Infraction (50-498/80-07-A; 50-499/80-07-A):
Failure to i
Follow Procedure for Storage of Material.
The IE inspector reviewed licensee corrective action and recurrence control described in HL&P letter
ST-HL-AE-468, dated May 23, 1980.
Brown & Root Procedure A040MECP-4, Revision 11, dated November 18, 1980, requires that weld end preparations shall be capped or otherwise orotected from damage until installation
and that surveillance by QC shall be performed.
In the interim period, prior to issuance of the revised A040MECP-4, surveillance of weld end preparations was prescribed by B&R correspondence SQA-3708, dated May 20, 1980.
Visual inspection by the IE inspector of weld end preparations located in Units 1 and 2 indicated that adequate protection is being provided in accordance with the above procedure.
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The IE inspector observed that nonconformance report (NCR) No. S-M3645, for disposition of repairs to penetration M-39 in the Unit 2 Reactor Containment Building, and corrective action request (CAR) No. S-285 relative to violation of Procedure A040KGCP-35, Revision 3, are still open.
l This matter will remain open pending closeout of NCR S-M3645 and CAR S-285 and review by IE during a subsequent inspection.
3.
License Action on Show Cause Order Items a.
(0 pen) Show Cause Order Item 7:
The licensee shall develop and implement a more effective system to provide for the control of field changes in order to assess the impact of the changes on the design.
The IE inspector reviewed implementation of the commitments in the licensee's response to this Show Cause Order item by discussion with licensee and contractor representatives and by inspection of objective evidence related to the commitments described in the attachment to HL&P letter ST-HL-AE-533, dated September 18, 1980.
The following
commitments, utilizing the identification numbers in the attacnment to
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the HL&P letter, were reviewed:
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Item No. A130 (0 pen):
Design changes proposed at the STP site are
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being submitted to Project Site Engineering (PSE) by Construction Engineering Administration (CEA) as required by Construction Pro-cedure A040KGCP-21, " Field Change Requests / Temporary Change Notices,"
Revision 11.
Inasmuch as this procedure has only recently been issued, this item will remain open pending further observation of implementation by IE during subsequent inspections.
Item No. A131 (0 pen):
Qualification and training records for Project Site Engineer and QEs were not available at the site and will be reviewed by IE during subsequent inspections.
Item No. A132 (0 pen):
Minutes of Change Review Board (CRB) activities were available for review and indicated that the site CRB appeared
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l to be functioning in accordance with Procedure STP-0C-029-B, " Change Review Board Activities," dated October 31, 1980; however, in j
view of the recent issue of the procedure, further review of i
this item will be performed during subsequent inspections.
Item No. A133 (0 pen):
Copies of Design Change Notices (DCNs) signed by the CRB Chairman were reviewed; however, due to the limited activities to date by the CRB, further review of this matter will be performed by IE during future inspections.
Item No. A134 (Closed).
The previously used FREA has been eliminated l
by implementation of Procedure A040KGCP-21 and STP-0C-023-L, " Engineer-ing Procedure for Processing Field Change Requests."
Item No. A135 (0 pen):
The IE inspector observed that DCNs are entered in a computer by site engineering personnel as required by Procedure STP-DC-028; however, this matter will remain open pending further review of implementation by IE during future inspections.
Item No. A136 (0 pen):
The IE inspector observed that daily computer printouts are provided to users of design documents at the site; however, this matter will remain open pending further review of implementation by IE during future inspections.
Item No. A137 (0 pen):
The IE inspector was informed that verifica-
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tion checklists are presently being developed by Quality Engineering and that Procedure QAP 10.1 is being revised to provide for verifi-cation by design personnel.
This matter will be reviewed during future inspections.
l Item No. A138 (Closed):
FREAs have not been issued to initiate field design changes since Precedures A040KGCP-21 and STP-DC-023-L j
were implemented on October 1, 1980.
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Item No. A139 (0 pen):
The IE inspector was informed that evaluation
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of the field change program is an ongoing process and the need for
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minor changes has already been identified.
This matter will be reviewed by IE during future inspections.
Item No. A140 (0 pen):
The IE inspector was informed that open FREAs are being handled as FCRs and the process will continue until all l
FREAs are processed.
This matter will be reviewed during future inspections.
Item No. H30 (0 pen):
The IE inspector observed that design changes are being documented as DCNs.
This matter will remain open pending further review of implementation by IE during future inspections.
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Item No. M35 (Closed):
The change review boards at the site and the Houston office were established by Procedure STP-0C-029-B implemented on October 1, 1980.
Item No. M36 (Closed):
Engineering Procedure STP-DC-029-B establishes positions of individuals servirg as Change Review l
j Board Chairmen.
Item No. M37 (0 pen): Procedures A040KGCP-21, STP-DC-028-A, STP-DC-029-B and STP-DC-023-L were issued prior to October 1, 1980; however, another procedure will be issued which will address requirements for cases where specifications permit alternate
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methods to be celected by the engineer.
This matter will remain
open pending issuance of the new procedure and subsequent review by IE.
Item No. M38 (0 pen):
Objective evide' ice of the training seminars j:
for B&R members participating in the field change program was
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not available at the site for review.
This matter will be reviewed during a future inspection.
The IE inspector observed that Brown & Root QA Manual Section 3.0,
" Design Control," was revised October 31, 1980, to reflect changes made to the lower tier implementing procedures relative to design change control.
Procedure ST-QAP-3.2, " Field Change Requests," dated March 1, 1979, will also be revised to reflect revisions to the implementing procedures.
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(0 pen) Show Cause Order Item 8:
The licensee shall develop and
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implement a more effective system of record controls.
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j The IE inspector reviewed implementation of the commitments in the licensee's response to this Show Cause Order item by discussions with
l licensee and contractor representatives and by inspection of objective evidence related to commitments described in the attachment to HL&P letter ST-HL-AE-533, dated September 18, 1980.
The following commitments, utilizing the identification numbers in the attachment to the HL&P letter, were reviewed:
Item A141 (0 pen):
Brown & Root Procecure ST-0AP-10.1, " Inspection Planning and As-Built Verification," Revision 0 addresses creation of the recorcs control system by Quality Engineering.
Implementa-
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tion of the procedure is an ongoing process and will be reviewed i
during future IE inspections.
Item A142 (0 pen):
Recording the status of documents as required by Procedure ST-QAP-17.1, " Records Control," is an ongoing process.
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Implementation of the procedure requirements will be reviewed during future IE inspections.
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Item A143 (0 pen):
Quality Engineering review of document packages required by Procedures ST-QAP-17.1 and ST-QAP-10.1 had not been implemented at the time of this inspection.
This matter will be reviewed during future IE inspections.
Item A144 (0 pen):
New microfilm equipment has been acquired but one piece (key puncher) has been returned for modification.
This item will be reviewed during future IE inspections.
Item A145 (0 pen):
Equipment for the on-site film processing laboratory has been acquired but the building to house the equip-ment has not been completed.
This matter will be reviewed during
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future IE inspections.
Item A146 (Closed):
Document flow has been altered to eliminate pre microfilming and post-microfilming suspense files.
Item A147 (0 pen):
The HL&P RMS will be adopted for the STP filing system.
Quality Assurance Engineering is in the process of developing record travelers required for filing of documents.
This matter will be reviewed during future IE inspections.
Item A148 (0 pen):
Record travelers required by Procedures ST-QAP-17.1 and ST-QAP 10.1 are being developed by Quality Engineering.
This matter will be reviewed during future IE inspections.
Item A149 (0 pen):
Review of records in the vault has not been implemented.
This matter will be reviewed during future IE inspections.
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Item M39 (Closed):
Instruction ST-QAI-17.1, " Instructions for Records Control," which establishes methods and details necessary to receive, process and control records after they are transmitted to the vault was issued on August 1, 1980.
Item M40 (Closed):
The generic checklist for safety-related records is included in Procedure ST-QAI-17.1, issued on August 1, 1980.
Item M41 (0 pen):
The C M ite microfilming facility was still under construction at the 7v cf the inspection.
The IE inspector reviewed records M fa.e individuals who had received microfilm training.
Thb e 6 will be reviewed during future IE inspections.
vne IE inspector aho observ% that a draft procedure had been developed which addresses the description of the records storage area and environmental requirements.
This procedure and its imple-mentation will be reviewed by IE during a future inspection.
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(0 pen) Show Cause Order Item (3)(a):
A review shall be made of the safety-related work described below, completed as of the daca of this Order to determine whether such work was properly performed.
If repairs are required, describe the extent of the repairs necessary and the schedule for completicn.
Also, describe the manner in whicn the review was completed and extent of the review.
The IE inspector reviewed implementation of the commitments in the licensee's response to this Show Cause Order item by discussions with licensee and contractor representatives and by inspection of objective evidence related to commitments described in the attach-ment to HL&P letter ST-HL-AE-533, dated September 18, 1980.
The following commitments, utilizing the identification numbers in the attachment to the HL&P letter, were reviewed:
Item A36 (0 pen):
The Weld Review Program has been documented in TRD 5A700GP004.
The TRD will be updated periodically to incorporate changes in the results of the program.
The IE inspector reviewed the interim report on the review of safety-related welding which was incorporated into TRD 5A700GP004-B.
This item will remain open pending issuance and review of a final report by the special task force.
Item A59 (0 pen):
The system for controlling distribution of the filler metal will be reviewed for code and specification compliance.
The IE inspector reviewed the revised procedure for control of welding materials, NECP-8, Revision 5, and in the areas inspected, found it to be consistent with the ASME Code requirements for controlling welding materials.
This item will remain open pending implementation review.
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Item A66 (0 pen):
The PSAR/FSAR and engineering specifications have been reviewed to identify the applicable edition and addenda for all specified codes and standards.
The IE inspector
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reviewed TRD 5A700GP004 and confirmed that the applicable edition and addenda for the ASME Code had been identified.
The ASME Section III Code of record has been identified as the 1974 Edition through Winter 1975 Addenda.
This item will remain open pending review for other codes and standards.
Item A67 (0 pen):
The construction and QC procedures (current and past revisions), covering safety-related piping and Category 1 structures steel, are being reviewed for consistency and compliance to project requirements.
The IE inspector reviewed Appendix B to TRD SA700GP004, an interim report for the review of safety-related welding.
The report identified, in Section 4, three requirements from TRD A010PQ002 that had not been incor-parated into MECP-4.
A review of the latest revision to MECP-4, Revision 11, confirmed that the procedure had been revised to
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include the three additional requirements.
This item wi'.1 remain open pending issuance and review of the final report.
Item A70 (0 pen):
The engineering specifications and construction procedures have been reviewed for consistency and compliance with PSAR/FSAR.
The IE inspector confirmed that the incon-sistencies identified to date in TRD SA700GP004, Appendix B, Section 4 have been reconciled for the ASME welding restart program.
This item will remain open pending issuance and review of the final report.
Item A87 (0 pen):
A gradual restart on a controlled basis in
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accordance with a step by step program of planned activities has been prepared.
The initial restart of limited ASME welding was authori;:ed by NRC Immediate Action Letter, dated November 21, 1980.
This item will remain open pending unconditional release of safety related welding.
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(0 pen) The licensee's response to the Order to Show Cause, dated July 28, 1980, lists, on page 10, thirteen steps for the gradual restarting of ASME welding.
The IE inspector reviewed the objective evidence related to completion of each step.
The status, indicated by the word open or closed, and the results of each step are provided below:
Step 1. (0 pen):
The IE inspector reviewed the five welding procedures designated for the inital ASME restart program to verify that the adequacy of the applicable ASME welding procedure qualifications had been reconfirmed by the B&R QA Department.
The five welding procuure specifications (WPSs) and supporting procedure qualifi-cation reports (PQRs) reviewed were; WPS-2014, Revision 2 PQR 0808AB106, Revision 6 WPS-2072, Revision 0 PQR 0808AA111, Revision 3 PQR 0808AA207, Revision 2 WPS-2059, Revision 0 PQR 0101AA205, Revision 3 WPS-2029, Revision 2 PQR 01t,..AA110, Revision 4 WPS-2006, Revision 3 PQR 0101AB119, Revision 5 PQR 0101AB120, Revision 6 In reviewing the two stainless steel procedures, WPS-2014 and WPS-2072, the IE inspector identified a concern, in that, the welding parameters specified in the WPSs permit heat input
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values higher than that established in the supporting PQRs.
Technical Reference Document A010PQ0020 requires that the heat input be established in the welding qualifications.
In response to the concern, Attachment 1 to correspondence No. GM-76355, dated November 23. 1980, was sent to the IE Region IV office.
Attachment 1
.'s a test report titled, "The Effect of Welding Heat Input on the HA of Unstabilized Austenitic Stainless Steel."
The report provides sufficient test data to satisfy the technical requirement.
This item will remain open until the PQRs have been revised to reflect the additional test data of Attachment 1 and establish the heat input limitations applicable to each stainless steel WPS.
Step 2. (Closed):
Corrective action on items identified in the immediate action letter from IE Region IV, dated April 17, 1980.
The IE inspector verified that the immediate action letter items had been satisfactorily completed by reviewing the following documents:
WPSs & PQRs listed in Step 1 above MECP-1, Revision 14, " Qualification of Welders and Welding Operators" MECP-4, Revison 11, " Field Fabrication of Piping Systems and Component Supports - Nuclear Systems" MECP-8, Revision 5, " Control of Welding Material"
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QA Audit ST-35, " Responses and Closecut" Performance Qualification Test Reports for Requalification of 15 Welders or Welding Operators MES-001, Revision 1, " Control Testing and Documentation of Welding Qualifications" Certifications for QC Personnel Inspecting Welder Qualifica-tion Testing GCP-1, Revision 8, " Preparation of Quality / Construction Procedures" Step 3. (Closed):
Revision of certain sections of the B&R STP QA Manual to reflect changes in the QA program.
The IE inspector reviewed the B&R QA Manual as revised by the Revision Record Sheet, Transmittal No. 27, dated October 31, 1980, to confirm that changes in the QA program conformed to the B&R QA Manual.
In the areas inspected, no discrepancies were identified.
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Step 4. (Closed):
Approval of QA Manual changes by the authorized
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nuclear inspector and ASME.
The IE inspector verified that the Hartford Steam Boiler Inspection and Insurance Company had accepted the QA Manual revisions defined
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in Transmittal No. 27.
Step 5. (Closed):
Review, revision and reissuance of implementing procedures affected by QA Manual changes where necessary.
The IE inspector verified that the following Materials Engineering and Quality Construction Procedures (MECPs) had been reviewed, revised and reissued as necessary to comply with the latest QA Manual changes:
MECP-1, Revision 14 MECP-4, Revision 11 MECP-8, Revision 5 Step 6 (0 pen):
Review, revision and reissuance of NDE procedures where necessary.
NDE Procedure review was not performed as a part of this inspection.
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Step 7. (Closed):
Completion of personnel training in applicable revised procedures.
The IE inspector reviewed records which documented the training of two welders, four QC inspectors, two weld rod control attendants and three welding technicians to the latest revision of the applicable procedures.
Step 8. (Closed):
Confirm the adequacy of Steps 5, 6 and 7 above, by an independent third party expert, a Level III inspector certified by examination.
The IE inspector verified the above by reviewing the documentation issued by the Independent Level III inspector, confirming the adequacy of Steps 5, 6 and 7 above.
Step 9. (Closed):
Training and requalification of welders.
The IE inspector reviewed the requalification records for the 15 welders or welding operators selected for the ASME Restart Program.
In the areas inspected, no discrepancies with the require-ments of MECP-1 were noted.
Step 10. (0 pen):
Reconfirmation of qualification records of selected inspectors.
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The IE inspector reviewed the qualification and certifica-tion records of five welding inspectors and determined that the records had been reconfirmed by a Level III examiner.
This item will remain open pending review of reconfirmation of records for NDE inspectors.
Step 11. (0 pen):
Resumption of ASME welding, using these requalified welders and certified inspectors, on work selected under the following two categories:
(1) Fabrication and welding in the site fabrication shop.
Typical work would include:
.. socket welding small bore pipe spools (all Classes)
.. butt welding large bore piping up to 3/4" wall thickness (Class 3 only)
.. fabricating hangers and pipe supports per ASME Subsection NF (2) Components Cooling Water System in the Unit 1 Mechanical Electrical Auxiliary Building, Cube 3J (ASME Class 3, Carbon Steel, approximately 35 butt welds).
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The IE inspector observed the restarting of ASME welding on the Component Cooling Water System in the Unit 1 Mechanical Electrical b,xiliary Building Cube 3J.
The following field welds and associated documentation were inspected:
Weld No.
Isometric Drawing Status FW0006 3M361P-CC 1428-WA3 Complete FW0010 3M361P-CC 1425-WA3 Fill Welding l
FW0009 3M361P-CC 1425-WA3 Root Welding FW0005 3M361P-CC 1428-WA3 Preparing for Fit FW0007 3M361P-CC 1428-WA3 Complete In the areas of welder qualification, weld and inspection docu-mentation, procedure compliance, inspector certification, welding surveillance, and filter metal centrol; no discrepancies were noted.
Since shop fabrication was not in progress, this item will remain open and be inspected during a subsequent inspection.
Step 12. (0 pen):
Review by Certified Level III inspectors of the work in Step 11 above, for conformance with requirements.
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inspections.
Step 13. (0 pen):
After the process described in the above steps has been satisfactorily demonstrated, the ASME welding program will be expanded into other plant areas as additional personnel are qualified.
The review of this step will be completed during subsequent i-inspections.
No violations or deviations were identified.
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4.
Exit Interview The IE inspectors met with licensee representatives (denoted in paragraph 1)
on November 19, 21 and December 4, 1980.
The IE inspectors summarized the purpose and the scope of the inspection and the findings.
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