IR 05000498/1981023
| ML20009G712 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/24/1981 |
| From: | Crossman W, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20009G702 | List: |
| References | |
| 50-498-81-23, 50-499-81-23, NUDOCS 8108040581 | |
| Download: ML20009G712 (8) | |
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s U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-498/81-23; 50-499/81-23 Category A2
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Docket No. 50-498; 50-495-
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Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: Sco i Texas Project, Matagorda Texas l
Inspection Conducted: June 1981
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h 0 ' O - II Inspe'ctor:
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H. S. Phillips, Resident Reactor Inspector Date Projects Section No. 3
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Approved:
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W. A. Crossmin, Chief, Projects Section No. 3 Date
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Inspection Summary:
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Inspection of June 1981 (Report No. 50-498/81-23; 50-499/81-23)
l Areas Inspected:
Routine, announced inspection by the Resident Reactor Inspector (IIRITincludedindependentinspectionandfollowupinspections
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l relative to noncompliances, unresolved items and Show Cause Order items.
j The inspection involved seventy-two inspection-hours by one NRC inspector.
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Results: No violations or deviations were identified.
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8108040581 010629 PDR ADOCK 05000498, G
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l DETAILS
1.
Persons Contacted l
Principal Licensee Employees i
i R. A. Frazar, Manager, Quality Assurance (QA), South Texas Project i
T. J. Jordra, Supervisor, Quality Systems
L. D. Wi',on, Supervisor, Project QA (Mechanical)
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J. W, williams, Project Site Manager
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j Gilbert Commonwealth
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K. D. Ramsey, Houston Lighting and Power Company (HL&-) QA Systems
(Consultant)
j Management Analysis Company (MAC)
R. L. Deutschman, HL&P Project QA General Supervisor (Consultant)
The RRI also interviewed other licensee and contracter personnel including members of the engineering and QA/QC staffs.
Denotes attendance at the management meetings
2.
Licensee Action on Show Cause Order, April 30, 1980 (0 pen) Show Cause Order, Item V.A.(1): Management Consultant Review.
HL&P Management of Program to Control All Aspects of the South Texas i
Project; Revision of Organizational Responsibilities to Control the Design, Procurement and Construction Activitles of the Licensee's
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Prime Contractor, Brown & Root, Inc. (B&R) and HL&P Overall Respon-
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sibility for QA/QC Program.
l HL&P summarized commitments pertaining to this item in HL&P Letter
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(ST-HL-AE-533) dated September 18, 1980.
l The RRI reviewed objective evidence to determine if the subject commit-ments were implemented and/or corrective action was completed. The
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following are the results of that review.
(Closed) Commitment H12: Provide to the NPC the Results of Analysis of Bechtel Audit.
This item was regoened in NRC Report 81-07 for the purpose of tracking the completion of B&R South Texas Quality Assurance Procedures (ST-QAPs).
The RRI determined that aii ST-QA Procedures have been developed /re-
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vised, reviewed and approved. Sixty-three procedures were reviewed by both HL&P and B&R QA personnel. The HL&P review and comments on
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each procedure were documented on a document review form. The pro-cedures were in effect as of June 17, 1981.
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The new and revised ST-QA Procedures represent a substantial effort to simplify and clarify all of the subject procedures as recomended in the Bechtel Audit of Brown & Root Site, July 24, 1980. Bechtel Letter (JKL-811040; File 2.13) to HL&P, dated March 24, 1981, docu-mented overall approval of corrective action resulting from the previous audit.
The RRI reviewed a sample of the completed procedures as follows:
ST.QAP 1.1, Organization; ST-QAP 10.1, Inspection Planning; ST-QAP 15.1, Nonconforming Items; ST-QAP 15.2, Stop Work Order; ST-QAP 15.4, Data Analysis (Trending); ST-QAP 15.5, Temporary Waiver Requests; ST-QAP 16.1, Corrective Action; ST-QAP 17.1, Records Cor-trol; ST-QAP 18.1 Audit Program and ST-QAP 18.2, Site Surveillance.
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The RRI has no further questions on this item based on the objective evidence reviewed.
l (Closed)'CommitmentH13: All Construction Procedures Revised in the
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New Format With Input from Crafts /QA.
This item was reviewed and results were documented in NRC Report
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81-07, dated April 13, 1981. The item was held open pEnding the
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development or revision and subsequent issue of six procedures.
Equipment Coating Repair Procedure CPP-10 was cancelled while in the review stages because such repair will be controlled by Nonconfonnance
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Procedures ST-QAP 15.1, and is not needed.
Electrical Termination Shack Operation Procedure, KPEP-10, was effec-tive May 21, 1981.
Site Material Control Procedure, STP-MM-SMCQ-21, was effective May 15, 1981.
Site Contracts Procedure STP-MM-HSSQ-07 was effective June 4,1981.
Site Purchasing Proceduro, STP-MM-SPQ-03, was effective May 15, 1981.
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Pipe Hanger Procedure, M0P-7, was cancelled while in the review process i
because infonnation in this procedure was duplicative, in that,
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Procedure MCP-7, Revision 1, January 2,1979, contained the same j
information.
This item is closed (0 pen) Show Cause Order, Item V.A.(9): The Licensee Shall Develop and Implement an Improved Audit System.
The RRI reviewed commitments listed in the previously refe enced letter
F (ST-HL-AE-533), and objective evidence of the implementatioa. The follow-l ing items are closed.or remain open for reasons described:
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(Closed) Commitment A153:
" Auditors are continually receiving additional training in the areas of coaes, standards, procedures and other documents related to QA programs and auditing."
This item was reviewed and results were document;d in NRC Report 81-12, dated May 8, 1981.
This item was held open pending additional training scheduled for May and June 1981.
During the current inspection, the RRI determined that an
"ASME Code Course" was held on May 26-28, 1981 and " Electrical Components, Material and Documentation for Auditors" was held on June 10-12, 1981.
B&R Letter (SQA-4845), dated June 16, 1981, documented this training effort.
This additional training effort and previous training represents an improvement or upgr:de of the audit staff consistent with this commitment.
This item is closed.
(0 pen) Commitment M4:
B&R Audit Group to Add Five Additional i
Personnel to Augment Audit Staff (NUS/SAI).
(0 pen) Commitment M42:
B&R Will Increase the Number of Resident Site Auditors.
These commitments were reopened in NRC Report 81-07, dated April 13, 1981, as a result of inadequate implementation.
The total number of B&R auditors in August 1980 was 20 (17 permanent plus 3 subcontractor furnished auditors).
Four (4) of this number were site auditors, however, there should have been five (5) since one site auditor had just terminated.
Considering this, the base number was twenty-one (21).
The above commitments, given in September 1960, add at least five (5) home office auditors and one (1) site auditor which totals to twenty-seven (27).
The following were the manpower levels from August 1980 through March 1981:
Augu;t-20.3, September-20.7, October 22.0, November 25.5, December-21.3, January-12.2, February-19.3 and March-16.3.
During the NRC inspection in March 1981, the RRI found that the manpower levels had never reached the number required to fulfill the commitments.
In fact, the average level frc,a October 1,1980 -
April 1, 1981 was 21.1 over the six months period.
The RRI stated that the commitment to add permanent auditors had not been met.
Further, the licensee's response to NRC Investigation Report 79-19, pages 58 and 62, stated that additional auditors would be added to assure that (1) auditors have more time in which to prepare and conduct audits, and (2) audit schedules are met.
HL&P Letter (ST-HL-AE-549), dated September 29, 1980, stated that full compliance in increasing the audit staff would be achieved by January 1, 1981.
Apparently, corrective actions, outlined in the previously referenced response, have not been accomplished.
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On April 22, 1981, NRC Senior Management and <.he RRI met with HL:lP Senior Management. HL&P Executive Vice-President stated that the conmitment to add B&R auditors to the audit staff would be met and all conmitments to the NRC would be reviewed and evaluated in August 1981. This was acceptable to the NRC Management and it was understood that details relative to numbers and the augmented audit program would be determined and the HL&P Manager > Quality Assurance, STP would discuss these matters with the RRt.
Subsequent to this meeting, the RRI has contat.ted the HLAP QA Manager for details on at least two occasions. The last contact was on June 5, 1981. At this time, the HL&P QA Manager stated that he was still anable to give specifics relati e to numbers to t
be added or the period of time the augmented program would cover.
He did -tate that subcontractor auditors had been added to B&R Audit haff and offers were out to pennanent personnel. His staff members have been contacted several times during the period, April ?2 through June 17, 1981.
On June 15, 1981, the RRI u s contacted by HL&? QA Systems personnel relative to the close out of Commitments M4 and M42. B&R Letter (ST-BR-HL-38752) was presented as objective evidence that B&R audit deft:iencies and weaknesses had been corrected. The RRI stated that these conmitments will not be closed until the number of auditors is the appropriate number and some type of plan is documented in a memo or otherwi;e to show the augmented audit program objectives, program duration and the basis for returning to a routine audit effort. The HL&P representative stated that he wculd contact B&R Management to determine if -"ch a plan existed or would be furnished.
That same day, the HL&P rep..entative stated that memos, giving the stafi level and the approximate program duration (approximately one year), would be transmitted to the site. The RRI stated that if these were received the items would be closed. B&RLetter(ST-BR-HL-39707), dated June 9,1981, was furnished and showed 27 auditors.
One supervisor and 6 auditors were assigned to the site audit group.
One supervisor and 20 auditors were assigned to the B&R b uston Office.
Five (5) of the 27 were subcontractor furnished auditors.
Nine (9) lead auditors were designated. The HL&P representative stated that the HL&P Executive Vice President had decided that further documentation of the program duration was unnecessary since a verbal commitment was given in the April 22 meeting relative to reviewing all consitments, made to the NRC, in August 1981.
The RRI stated that the commitments would remain open until August 1981, or tor a duration of time which would allow the augmented audit effort to show by objective evidence that audit effort could be justifiably reduced. The main thrust of this effort should be to assure that the corrective action resulting from responses to NRC Report 79-19 and Show Cause Order is working.
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3.
Licensee Action on Previously Identified Items (Closed) Unresolved Item (498/81-01-02; 499/81-01-02): Low Nitrogen on Closed Cooling Water Heat Exchanger.
The RRI reviewed the Equipment Storage and Maintenance Instruction (ESMI)
Card (M-0571-D) to verify that the scject equipment was periodicallv inspected. HL&P QA personnel had verified the nitrogen purge to be J an acceptable level on June 4,1981.
This item is closed.
(Closed) Unresolved Item (498/81-01-03; 499/81-01-03): No Cover on Recycle Hold Up Tank.
During a January 1981 inspection, the RRI noticed that one hold up tank was covered with a plastic covering while another was not. This incon-sistency was questioned.
The ESMI card and the attached Maintenance Discrepancy sheet documented that the tank was recovered on April 21, 1981.
This item is closed.
4.
Licensee System for Reporting Construction Deficiencies On March 11-12, 1981, the RRI reviewed fifty-eight (58) files at the HL&P Licensing Office at Houston. These files contrined objective evidence which showed timely evaluation of repertable/nonreportable items in file. The conclusions, reached in evaluations dealing with nonreportable itemt., appeared tc be logical.
The RRI reviewed additional objective evidence ot,tained during the in-spection described in the previous peragraph and additional information available at the site. The following are the results of this review.
(Closed) Construction Deficiency Report (CDR No.38): Cooling Water Pump Seal Water Design.
The RRI reviewed t.icensee File (LF), LF-No.56. The licensee had questioned the material used to manufacture the pump bearings as described in the manufacturer's instruction manual. The manufacturer clarified the bearing material requirements. No corrective action was necessary because the system met the design requirements.
This item is closed.
(Closed) CDR (CDR No.37): NPS Piping Support Material, A651 1035.
The RRI reviewed LF-57. The piping support material specified was ASTM A668, Class C, AISI 1010, 1020 or 1030, however, ASTM A668, Class C, 1035 was used to manufacture the supports. The supplier initiated a
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code case and was informed that AISI 1035 could be used if it were not welded. The licensee concluded that this deficiency would not have adversely affected the safety of the operation of the plant and there-fore was not reportable.
(0 pen) CDR (CDR No. 35): Reactor Vessel Outlet Nozzle Safe End Dimen-sional Error.
The RRI reviewed Licensee File No. 47. Westirghouse Memo (ST-WY-HS-00199),
from D. A. Gulling to HL&P, stated that four safe ends were acid etched to determine the location of the interface between the inconcl weld and stainless steel safe end forgings manufactured by Ccabustion Engineering.
Combustion Engineering and Westinghouse technical representatives fcad that Combustion Engineering had violated Equipment Specification 952545, paragraph 5.2.6, which states, "The reactor coolant nozzles shall have austenitic stainless steel type 304 or 316 (h" or 12.7mm) length minimum applied to the ends to facilitate field welding to reactor coolant piping." Outlet Nozzle Code R2012-3 showed only 1/16" stainless steel remaining af ter machining.
The RRI reported this matter to Region IV on June 3,1980 and informed several of the other Resident Inspectors that similar etching for arrors had been done at their sites.
The Region IV Vendor Branch became in-volved and additional information was obtained as documented in a memo-randum for Mr. G. W. Reinmuth of NRC Headquarters.
This matter remains unresolved pending the results of the Region IV inspection of this matter.
(Closed) CDR (CDR No. 27): Excessive Lift Thickness During Concrete Placement DGI-W3A.
The RRI reviewed Licensee File No. 51.
The evaluation concluded an excessive lift thickness (approximately 3 feet versus the required 14 feet) on Diesel Generator Building Wall, DGI-W3A, had been revibrated immediately after placement and proper consolidation had been accomp-lished. HL&P QA personnel inspected the subject wall after the form was removed and found the concrete to be sound and free of voiding.
This item was considered not reportable.
This item is closed.
(Closed) CDR (CDR No. 26): QA Program for Concrete Placement CII.W90.
The RRI reviewed Licensee File No. 48.
The evaluation wdt performed and the subject area was physically tested as a result of questions raised during B&R Audit ST-36.
The questions were raised as a result of in-
adequate records. This area was visually inspected and ultrasonically tested as a part of the B&R Task Force for Concrete Verification (NRC Show Cause Order, Item 3b). The test results showed the area to be structurally sound.
This item is closed.
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Concrete Voids Under Embed Plates.
The RRI reviewed Licensee File No. 33.
B&R Nonconformance Report #CS-i C3761A identified minor voiding in the concrete under crossover leg i
embed plates.
B&R engineering determined that the condition, if left
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uncorrected would not have adversely affected the safety of operations of the plant.
The RRI visua ly inspected the embeds after repair had taken place and has no further questions on this matter.
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This item is closed.
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Site Tour The RRI performed independent inspection during a site tour which included the Reactor Containment Buildings, Units 1 and 2, Mechanical Electrical
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Auxiliary Building, Unit 1 and Storage and Laydown Areas.
No violations or deviations were identified during the inspections des-cribed in the previous paragraphs.
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Management Meeting The RRI met with one or more persons identified in paragraph 1 on June 19, 1981 to discuss inspection findings and results.
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