IR 05000498/1981036
| ML20039E983 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/28/1981 |
| From: | Crossman W, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20039E948 | List: |
| References | |
| 50-498-81-36, 50-499-81-36, NUDOCS 8201110687 | |
| Download: ML20039E983 (9) | |
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f APPENDIX U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
Report No. 50-498/81-36; 50 499/81-36
Docket No. 50-498; 50-499
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Licensee: Houston Lighting and Power Company
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Post Office Box 1700 Houston, Texas 77001 i
I Facility Name: South Texas Project, Units 1 and 2 s
i Inspection at: South Texas Project, Matagorda County, Texas
Inspection Conducted: November and Dece.mber 1981 Inspector:
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H. S. PhTl' lips, Resident Reactor Inspector Date i
Project Section No. 3
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v W. 'A. Crossrr
,~ Chief, Project Section No. 3 Date
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Inspection Summary:
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Inspection of November and December 1981 (Report No. 50-498/81-36: 50-499/81-36)
i Areas Inspected:
Routine, announced inspection by the Resident Reactor Inspector (RRI) included. independent inspection; follc;.-up inspection of unresolved items,
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and Show Cause Order Items; inspection of storage and maintenance of equipment; I
inspection of extended construction delay procedures and work activities.
l The inspection involved seventy-five inspector-hours by one NRC inspector.
Resul ts: No violations or deviations were identified.
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J 8201110687 820108 PDR ADOCK 05000498 PDR T
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DETAILS 1.
Persons Contacted Principal Licensee Employees
- J. E. Geiger, Project Quality Assurance (QA) Manager
- J. W. Williams, Project Manager D. R. Keating, Project QA General Supervisor Gilbert Commonwealth
X. D. Ramsey, Consultant to Houston Lighting and Power Company (HL&P)
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QA Systems
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The RRI also interviewed other licensee and contractor personnel
including members of the engineering and QA/QC staffs.
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- Denotes attendance at the management meetings.
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Licensee Action on Show Cause Order, April 30, 1980
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(Closed) Show Cause Order, Item V. A.(1): Management Consultant Review.
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HL&P Management of Program to Control All Aspects of the South Texas Project; Revision of Organizational Responsibilities to Control the i
Design, Procurement and Construction Activities of the Licensee's Prime
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Contractor, Brown & Root, Inc. (B&R); and HL&P Overall Responsibility for QA/QC Program.
l (Closed) Show Cause Order Commitment A161:
Follow-up Audits Will Be Conducted to Verify Successful Correction of Problems and Their j
Causes.
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This commitment was made in regard to Show Cause Order, Item V.A.(9),
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however, the RRI met with the HL&P Houston QA Manager, who is respon-sible for the audit program, and discussed the fact that an HL&P
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audit of the entire Show Cause Order corrective action and commitment
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implementation effort would be necessary before Show Cause Order, Item V.A.(1) could be closed.
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As a result, HL&P Audit HBR-43 was performed July 1981. This special
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I audit was in addition to HL&P follow-up audits WPD-5, GE-16, PWRSD-5, j
HL'-87, BR-31, HL-84, BR-35, HL-90, HL-91, HL-86, HL-92, HL-95 and-
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BR-37. The HL&P Audit Group also followed up on each audit finding identified in Bechtel Power Corporation audit, dated July 24, 1980.
,r HL&P follow-up on HBR-43 audit deficiencies was documented in HL&P
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letters ST-HL-BR-6578 and ST-HL-BR-6662, dated September 28 and October 29, 1981, respectively.
This item is clo' sed.
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(Closed) Show Cause Order Commitment M4:
B&R Audit Group to Add
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Five Additional Personnel to Aucment Staff (NUS/SAI).
This commitment was implemented and was closed in f1RC Report 80-27, but was subsequently reopened in NRC Report 81-07 because the audit
staff level was reduced to the original size in only one to two months after the commitment was implemented.
The RRI considered this implementation period too short to show an
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improved audit effort.
As a result, the licensee directed the con-
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tractor to add audit personnel to implement the comitment. The staff level has been maintained at the commitment level for almost 11 months.
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This item is closed.
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(Closed) Show Cause Order, Item V.A.(9):
The Licensee Shall Develop j
and Implement an Improved Audit System.
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(Closed) Show Cause Order Commitment M42:
B&R Will Increase the i
fiumber of Resident Site Auditors.
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The basis for closing this item is the same as that described for j
Commitment M4 in the previous paragraph.
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This item is closed.
i (Closed) Show Cause Order, Item V.A.(3a): A Review Shall Be Made of i
Safety Related Helding, Including Civil-Structural and Piping, to Determine Whether Such Work Was Properly Performed and, If Repairs Are Required, i
Describe the Extent of Repairs 'lecessary and the Schedule for Completion.
(Closed) Show Cause Order C'ommitment A65:
Field Generated Reports j
Such As flonconformance Reports (flCR), Field Request For Engineering
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Assistance (FREA), and Corrective Action Reports (CAR) Have Been l
Reviewed to Verify That Each Has Been Properly Dispositioned.
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BR Letter (ST-BR-HL-4512) documented a Contractor Task Force review of Weld Data Cards, Weld Inspection (NDE) Records, Welder Training
and Qualification Records, Inspection Training and Qualification
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Records, Welding Procedures, NCE Procedures, Construction Procedures,
i flaterial Test Reports, Weld Metal Test Reports, and Radiographs. The
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Task Force reviewed these records because this type of review would
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have been performed if a documentation problem was suspected on an
flCR, FREA, or CAR. NUTEC, a consultant, participated in the subject 1-review. The Task Force report identified only three "potentially
deficient" NCRs and these were properly evaluated.
The Task Force determined that the review of each record is not necessary based on the results of the sample of records reviewed and based on the fact a
I that welds were to be reinspected. These' actions provide sufficient j
basis for closing this item.
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This item is closed.
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-(Closed) Show Cause Order Commitment A68: Past Audit and Field-Generated Documents Such As.NCRs, FREAs, and CARS Related to Welding Are Being Reviewed.
This ~ item is closed out on the same basis as Commitment A65 above.
This item is closed.
. (Closed) Show Cause Order Commitment A69: An Initial Review of Field
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Generated Documents Has Been Completed But an Evaluation of This Information Gathered Is Required.
The Task Force evaluation and report referenced in the paragraph which closed out. Commitment A65 is also the basis for closing out this item.
This item is closed.
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(0 pen) Show Cause Order Commitment A74: The Weld Characteristics and Other Pertinent Information Will Be Statistically Classified i
For Use in an Engineering Analysis of Inaccessible Welds to Determine Their Acceptability.
B&R engineering classified weld characteristics, and other pertinent
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information was given to Battelle Columbus Laboratories for use in
an engineering analysis of inaccessible welds. Their report will be furnished in January or February 1982.
Show Cause Order, Item V.A.(3a) is considered closed because 57 of the 58
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commitments pertaining to safety related welding were closed in this and past NRC reports. Further, Commitment A74 is virtually complete.in that it
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only lacks completion of the Battelle Report.
If.the report identifies
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welds that must be repaired, fol. low-up inspection will be accomplished
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during future routine inspections. This item is unresolved pending the i;
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review of the report and will be tracked as Unresolved Item (498/81-36-01;
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499/81-36-01).
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(Closed) Show Cause Order, Item V.A.(8): The Licensee Shall Develop and
. Implement a More Effective System of Records Control.
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NRC Investigation 79-19, page 10, stated, "Further, although not reviewed
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during this investigation, licensee personnel indicated significant problems relative to... the processing of quality records." This statement was
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the result of slow retrievability of records by B&R QA records personnel.
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The problem was caused by records being received in the records center and being held in suspense files until all actions pertaining to the
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record were complete. This caused retrievability problems. Although no noncompliance was identified, a need to improve the retrievability was
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evident and the order directed that the B&R QA Records System be improved.
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B&R made 12 commitments to improve their records system. The overall
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system has been established and implemented.
Commitment A146, which created a new filing system and eliminated the various suspense files,
has been totally implemented. Six other commitments to improve the system have been implemented. flRC-Report 81-25 closed out all commit-ments except as follows:
(0 pen) Item A142:
Persons charged with creating requ' ired documents will record the status of these documents as the documents are created. The T1RC inspector observed that procedures (see Item A141)
i for implementing this commitment were in effect; however, implemen-tation had not prcceeded sufficiently for meaningful evaluation of the process for recording the status of documents.
(0 pen) Item A143: When complete document packages on individual
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activities are completed in the vault, Quality Engineering will review them to verify that the documents are complete and adequate.
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The f1RC inspector observed that procedures for preparing the docu-ment packages had not been in effect long enough for production and subsequent Quality Engineering review and verification of com-j pleted document packages for current work activities.
l (0 pen) Item A147: There will be a single filing system, and documents
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will be filed with a record traveler prepared by Quality Engineers.
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The f1RC inspector observed that the procedures for the record filing
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system had not been in effect long enough to provide a basis for a
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meaningful evaluation of the system.
Record travelers have been
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developed and issued, but have not been implemented for current work activities.
(0 pen) Item A148: The record traveler will identify the records-re-l quired to substantiate each_ activity, will record the status of the file, records borrowed from the file, and will be used to identify'
overdue and missing records. The flRC inspector observed that record
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travelers have been developed and issued but have not been implemented
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for activities described in this commitment.
(0 pen) Item A149:
Records in the vault will be reviewed for adequacy
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and completeness, based on the results of the review of record require-ments.
Following. extensive effort to determine a plan for review of
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QA r3 cords in the vault, the licensee described their program for fulfilling this commitment in letter ST-HL-AE-717, dateo August 31, 1981, to the f1RC.
Steps in the program include:
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Identification of prograninatic and production records.
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Installation of a traveler system for each discipline.
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Recruitment of the necessary Quality Engineering staff to perform this review.
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Modification of the existing quality assurance procedures to describe the documentation flow.
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The RRI determined that the new system had been established and all commitments were being implemented, but the status of implementation for Commitments A142, A143, A147, A148, and A149 was about the same as described in the previous paragraph.
Since the retrievability problem has been corrected by implementing the new filing system and since the other commitments have been implemented but have not been completed, this item is considered closed.
However, since Bechtel Corporation will assume the QA responsibilities, includirig the QA Records, this item will be inspected during future routine in-spections to determine how their system will control QA Records.
This item will be tracked as Unresolved Item (498/81-36-02; 499/81-36-02).
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Show Cause Order Follow-Vo Comoleted The Region IV Task Force follow-up on corrective action and commitment implementation related to the Show Cause Order has taken more than 1,400 inspector-hours during the last 16 months.
Two hundred thirty of 236 concitments have been completely implemented, closed out, and documented in NRC reports. The six commitments which remain open are items which pertain to the Brown & Root portion of the QA program.
On September 23, 1981, HL&P announced that design engineering, quality assurance, and project management responsibilities were to be reallocated to Bechtel Power Corporation but B&R would remain as the constructor.
Since that announcement, B&R decided to totally withdraw from the project but did agree to provide caretaking services until the new contractors are on site.
Bechtel has been constructing nuclear power plants for several years.
As a result, they had submitted a Topical QA Report for several construc-tion sites. This report was approved by the NRC.
site specific procedures at several construction sites.In addition, they have These procedures appear to be working at other sites.
that they will prefer to implement these procedures at the South TexasTh Nuclear site instead of Brown & Root, Inc., procedures.
Regardless, the NRC Inspection Program requires the review of the new contractor's pro-cedures and inspection of the implementation of such procedures.
Five of the six remaining commitments were specifically applicable to
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the B&R QA Records System. The commitment to improve the record system may be inappropriate because the new contractor should have the latitude to implement their own system since there are many ways of meeting the requirements of 10 CFR 50, Appendix "B", Criterion XVII.
The sixth remaining Commitment, A74, pertains to safety related structural steel welded in accordance with AWS D1.1-75.
These welds are inaccessible.
Since B&R is withdrawing from the site, Bechtel engineering personnel will be responsible for reviewing and evaluating the final report and taking any action if necessary.
to the Show Cause Order, it appeared appropriate to track this as anSin unresolved item as described in previous paragraphs.
The nature of the commitments, such as review of old records, will prob-ably take another year to complete. Since the proper controls have been implemented, it appears to serve no useful purpose to keep the order open for another year until the last single record is reviewed. The same would be true if repair of welds were reconmended by the Battelle Report.
If significant welding deficiencies were identified, the licensee would also be required to report and correct them in accordance with 10 CFR 50.55(e)
reporting requirements.
This further supports tracking as an unresolved item.
The licensee took the most extreme corrective action possible when project responsibilities were reallocated. Adequate latitude is necessary to allow this corrective action to be implemented. Tha new contractor should be given the opportunity to establish and implement their own QA Program.
This could result in deleting or adding commitments that would be subject to flRC review and concurrence.
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In view of the above, the Show Cause Order follow-up effort is considered to be complete.
4.
Licensee Action on Previously Identified Items (Closed) Unresclved Item (498/80-11; 499/80-11): Qualification of Level II QC Inspectors.
This item was previously identified during f1RC Investigation 79-19. As a result, a complete review of B&R QA/0C personnel qualifications and re-certification of those personnel, where necessary, was completed during January - April 1980, to eliminate any doubt as to the proper qualification of QA/QC personnel.
In addition, certification requirements were made more rigorous. This was verified and documented in f1RC Report 80-25.
These actions provice basis for closing this item.
This item is closed.
(Closed) Unresolved Item (498/81-01; 499/81-01):
Steam Generator tiitrogen Purge Removed.
This item was documented in flRC Report 81-01 and was held open until the inside of the steam generator could be ',ispected and a filtering system
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could be installed. This was not possible until the sandblasting stopped.
Af ter the sandblasting stopped, HL&P performed and' documented the inspection on flovember 18, 1981.
The insides of the four generators were found to be in good condition.
Subsequently, Westinghouse personnel installed a special system to control the inside environment.
This item is closed.
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I (Closed) Unresolved Item (498/81-12; 499/81-12):
Internal Surveillance &
Subcontracts Surveillance Mechanical Section.
This item pertained to reorganization and full staffing of the subject section. The announcement to reallocate QA responsibilities makes this a moot point since another contractor will assume QA responsibilities and their organizational structure may not be structured in the same way.
This item is closed.
(Closed) Unresolved Item (498/81-09; 499/81-09): Significant Audit Deficiency Identified in HL&P Audit BR-26 Not Corrected.
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The RRI reviewed objective evidence, HL&P Correspondence ST-HL-BR-6732, dated December 2, 1981, which documented HL&P verification that the Audit Deficiency, ADR BR-26-SD-01, had been corrected.
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This item is closed.
(0 pen) Unresolved Item (498/81-30; 499/81-30): American Bridge Beams Inspected to AWS D1.1 Code Criteria versus B&R Procedure ST-QAP-10.5, Inspection Criteria.
This item pertains to inadequate inspection of the subject beams in 1971 by B&R and American Bridge inspection personnel, and subsequent B&R inspection at the site in February 1981, which identified widespread non-conformances. The significant deficiencies were undersized welds and excessive undercut. Other nonconformances were not considered structurally significant.
A thorough review of this item was documented in NRC Report 81-32. The adequacy of the original inspection at the vendor was unsatisfactory and documented in B&R audits and surveillances. The reinspection of the welding of connectors to these beams was accomplished on site in accordance
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with ST-QAP-10.5, Revision 0, dated June 6, 1981, and Revision 1, dated July 29, 1981. The RRI questioned the validity of this reinspection of welded connectors to beams because the subject beams had been visually reinspected for cracks and lack of fusion without removing the paint.
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The RRI met with licensee and contractor personnel on several occasions
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and discussed ways that this item could t,e resolved:
(1) statistically sample the critical welds and remove the paint and reinspect in accordance with AWS D1.1 acceptance criteria, or (2) evise the procedure to allow reinspection with the paint left on, provifed a valid engineering evalua-tion can support or justify such reinspection.
The RRI noted that ST-QAP-10.5, Revision 2, dated November 16, 1981,
" Reexamination of Vendor Performed Structur al Welds," directs that rein-spection for cracks and incomplete fusion t e accomplished "if detectable through the paint." On December 9, 1981, the RRI requested to see the engineering evaluation which would support such reinspection. The report was not complete; however, the licensee rearesentative stated that B&R engineering had advised him that the report may be available by December 17-18, 1981. The RRI stated that the report wili be reviewed by an NRC engineer (s)
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to determine if cracks, which may not be detected through a coating, i
could adversely affect the' structural strength.
It was emphasized that design calculations of loading conditions in the report should be provided based on such consideration. -This item remains open pending receipt and review of this report.
No violations or deviations were identified.
5.
Extended Construction Delay On September 23, 1981, the licensee announced reallocation of design engineering, quality assurance and construction management responsibilities.
As a result, the licensee's prime contractor, Brown & Root, Inc., decided to compi tely-withdraw from the project. All safety related activities performed by B&R ceased on or before December 1,1981, except for caretaking responsibilities which will continue until the new contractors are on site and they are fully prepared to assume these responsibilities.
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The RRI met with the HL&P QA Manager on several occasions to discuss transition plans. The RRI described the type procedures which the NRC typically expects to be established during construction delays and stated that NRC inspections will include, but not be limited to:
(1) availability and use of such procedures, (2) protection and preservation of equipment and materials, (3) nonconformance system, (4) utilization of inspection personnel, (5) use of measuring and test equipment, (6) QA audits, and (7) site access control.
r Approved B&R procedures, QA and Construction, are being used to control the caretaking activities such as receipt inspection, storage / maintenance of equipment and materials, and QA records.
On December 18, 1981, the site work force was approximately 1,020, and 727 of these personnel were B&R employees assigned to perform transition or caretaking functions. This work force will remain reasonably stable but
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B&R personnel will leave site as functions are completed during the next
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few months. Sufficient personnel will be assigned until the new contractors are on site and are prepared to fully assur.4 these functions.
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Brcwn & Root, Inc., and Bechtel power Corporation personnel are monitoring and reviewing all work in progress or templeted.
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placed on all of the ASME Code work to assure adequate documentation of such work which will be turned over to the new contractor.
- The RRI inspected storage of equipment in Warehouses B, C, D, and E.
All material and equipment in the laydown areas were inspected. These activities are controlled in accordance with approved procedures. All equipment and materials on site are being inventoried for turnover to the new contractor.
No violations or deviations were identified.
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