IR 05000498/1982003
| ML20052G015 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/02/1982 |
| From: | Breaux D, Crossman W, Hale C, Hill W, Hubacek W, Oberg C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20052F999 | List: |
| References | |
| 50-498-82-03, 50-498-82-3, 50-499-82-03, 50-499-82-3, NUDOCS 8205140236 | |
| Download: ML20052G015 (22) | |
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Appendix U. 5. NUCLEAR REGULATORY COMMISSION
REGION IV
Report:
50-498/82-03; 50-499/82-03 Docket:
50-498; 50-499 Category A2 Licensee:
Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project, Matagorda County, and Houston, Texas Inspection Conducted:
February 1982 T.td.T6 M M v/2/rs.
Inspectors:
M D. G. Breaux, Resignt Inspector Da'te'
f (Details Section 1)
0. R. @k fNew C.R.Oberg,InQectionSpecialist Uat'e (Details Section 2)
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e W. M. Hill, Resident Inspector Date (Details Section 3)
WZl82.
mm-h(DetailsSection4)
. G. Hubacek, STP Coordinator Date
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I[3/82. -
Approved:
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W. A. Crossman, Chief Date Reactor Project Section B
- T r. M. 7 5 A A u 41/rz l
/p. J. Hale, Chiefc-f Date'
C l
p Reactor System Secclon i
l 8205140236 820422 PDR ADOCK 05000498 G
PDR L
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2-Inspection Summary Inspection Conducte'd During February 1982 (Report 50-498/82-03; 50-499/82-03)
Areas Inspected:
Inspection of construction activities related to transfer of engineering and construction management functions from Brown & Root (B&R) to Bechtel Power Corporation (BPC) including:
BPC assessment of the Quadrex Report findings; BPC review of the existing design; BPC review of purchased goods; site caretaking activities; and QA program development.
The inspection involved 209 inspector-hours by four NRC inspectors.
Results:
No violations or-deviations were identified.
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DETAILS SECTION 1 1.
Persons Contacted:
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Bechtel B. Lex, Project Manager J. Hurley, Assistant Project Engineering Manager H. Friend, Project Manager K. Dotterer, Project QA Engineer J. McBride, Quality Engineer R. Rogers, Project Engineering Manager J. Quinnelly, Quality Engineer T. Smith, Records Manager B. Robertson, Purchasing Manager W. Melton, Project Engineering Coordinator D. Krisha, Project QA Manager 5, Cozzer, Project Quality Engineer HL&P J. Blau, Supervisor Project Engineer S. Dew, Manager Engineer T. Jordan, Project QA Supervisor J. LeBlanc Records Manager 2.
Bechtel/ Brown & Root Transition Program This section of the report details NRC activities with respect to surveillance /inspe; tion of the Bechtel/ Brown & Root transition.
In order to assess the overall transition program and to keep track on exact status of the Bechtel review and assessment of the existing Brown & Root engineering design and associated records, an NRC Region IV inspector was assigned on a full time basis to the A/E facility (Bechtel Houston).
In order for Bechtel to assume responsibility for the existing Brown &
Root design of the South Texas Project, a thorough review and assessment i
by Bechtel personnel is required.
This design review effort is divided i
into various segments called work packages.
Most of these work packages address an individual system, structure, or component.
Several of the nuclear work packages, called compliance work packages, crass design disciplines on major plant items and are reviewed to assure adequate interface control.
To help define this area of the review effort, Brown
& Root and Bechtel held work package conferences.
From these conferences, a total of 166 engineering work packages were defined and scheduled for the review process.
All of these work packages, and supporting documentation, are gathered and transmitted to Bechtel by Brown & Root.
Upon receiving these packages, Bechtel records management reviews their content to assure that what was transmitted by Brown & Root had in actuality been received.
Upon records management review and
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verification of content in the package, the contents are transmitted to
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The two areas of assessment are technical and commercial.
The design portion of the work package is assigned to an engineering group supervisor (EGS) for the technical assessment of the design.
The portion of the work package that contains procurement documentation will be transmitted to the Bechtel Purchasing Department for their commercial assessment.
As the commercial and technical assessment of a work package is completed, the two are combined in a work package final report that is then submitted to HL&P for review.
As of this report, no work package final reports have been generated. When final reports have been generated by Bechtel, and review-ed and approved by HL&P on all of the defined work packages, Phase I of the transition will be completed.
To assure that the Brown & Root /Bechtel transition activities are well defined, the NRC inspector reviewed both the Bechtel STP Phase A transi-tion procedures manual and the " Brown & Root Transition Workplan."
Meetings between the NRC inspector and Bechtel Engineering, Purchasing Quality Assurance, and Records Management were held to assess activity status and to become familiar with all activity interfaces.
3.
Findings From the beginning, it appeared that the activities scheduled for both Bechtel and Brown & Root were falling somewhat behind.
Reviews of cor-respondence between Bechtel and Brown & Root indicated there was a general atmosphere ranging from confusion to difference of opinion as'to the defined activities of the transition phase. When Bechtel initially received the Brown & Root Engineering Transition Plan in December 1981, the scheduled transmittal of the bulk of the work packages to Bechtel fell in the time frame of April 1982.
The Brown & Root contract with HL&P officially expires on April 31, 1982.
In order for Bechtel to expedite the design review activities to meet this date, the two parties involved would have.to amend package definitions and transition methodology.
Brown & Root explanation to Bechtel for the delay in transmittals was that each work package contained many discipline inputs and a finite amount of time was needed to assemble the complete package and transmit it to Bechtel.
It was decided that each of these inputs to the work package would be separately defined as subpackages.
These subpackage definitions included separate engineering design disciplines and procurement inputs.
This expanded the total number of Brown & Root transmittals to 862 engineering and 1200 procurement subpackages.
The transmittals of sub-packages-would allow Bechtel to review and assess portions of the total package' and then assemble the work package final report when all the subpackages are received and assessed.
The 1200 procurement subpackage transmittals incorporated into the work packages are broken down into 3 procuremenc inputs for each of the 417 purchase orders.
These three procurement inputs are purchasing, expediting, and supplier quality.
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Status of B&R subpackage transmittal:
B&R Subpackages Total Scheduled Scheduled to date Actual (Received)
Engineering 862 401 335 Procurement 1200 498 376 Bechtel has designated a few initial work packages as test cases to debug their review syst m.
When the final work package. report is generated on_
these test cases, an overall assessment of the review system will be made and amendments to the system may have to be incorporated.
The NRC inspector made an initial review of one of the first work package test cases; EN 612. entitled " Boron Recycle System." This work package included such engineering discipline inputs as electrical, mechanical, instrumentation and control, and procurement.
It became apparent that
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subpackage transmittals referenced design documents that had previously been transmitted _in bulk by Brown & Root.
Upon conferring with Bechtel about this, it was explained that these bulk transmittals are handled by the Technical Document Control-(TDC) Group of Records Management and contain such items as design drawings', specifications, calculations, system design descriptions (SDD), and Technical Reference Documents (TRD).
The subpackage transmittals contain a listing and status of supporting design documents and certain.other. documents such as Brown & Root STP
. hen this subpackage is transmitted to the Bechtel Engineering Reviews.
W Engineering Group Supervisors,-it is their. responsibility to gather the supporting design documents listed on the transmittal from the Bechtel Technical Document-Control Group (TDC).
The inspector noted that some documents listed as being transmitted in b'ulk by Brown & Root to TDC had not in fact been received by Bechtel.
Also, the subpackage transmittal-refers to quite a few supporting design documents that are to be submitted in bulk at a later date.
There have been no work package review draft final reports generated by Bechtel.
The inspector could not determine if there exists sufficient information transmitted at the time of the engineering review to actually verify / assure the adequacy of Brown & Root design work. Without the support documents, an extensive list of items that are open will be reflected in the work package final report.
Bechtel stated that they may s
have to do some actual design engineering work, such as doing design calculations, if these types of open items are delaying Bechtel's Engineering Review and Analysis.
The NRC inspector reviewed a Brown &
Root document (STP-GR-006-A) entitled " Transition Phase Procedural Deviations." Some of these d aiations are not compatible with procedural commitments made by Brown & Root in the past to the NRC.
These exceptions reflect that during this transition period, some Brown & Root design documents
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were revised without B&R Quality Assurance or HL&P review and approval.
Upon notifying HL&P of this situation, the NRC inspector was informed that a Quality Assurance Corrective Action Report (CAR) HG-035 had been gen-erated by HL&P relating to this concern on January 27, 1982.
A meeting was held between HL&P and Brown & Root to ensure that they fully under-stand the condition cited in the CAR.
Specifically, all design documents released per procedure STP-GR-006-A (which violate approved program requirements) must be reviewed and aoproved by B&R Quality Assurance-and HL&P.
And in the event that equip-ment has been inspected utilizing design documents which were released per procedure STP-GR-006-A, the equipment, if at site or to be shipped to the site, must be put on hold until proper review / approval is conducted.
As of March 1,1982, Brown & Root has not responded to the CAR.
Review of Bechtel procedures relating to the South Texas Project transi-tion activitics, indicates that the procedures adequately reflected the transition phase of design responsibility frem Brown & Root to Bechtel.
From the NRC inspector's initial observation of the transitional activ-ities at the Bechtel facility, the procedural commitments are being implemented.
The concerns that were raised by the NRC inspector with respect to Brown & Root activities have been communicated to HL&P.
These items will be followed by the NRC inspector and will be in subsequent NRC monthly report _
DETAILS SECTION 2 1.
Persons Contacted Houston Lighting & Power Company (HL&P)
- J. White, Special Coordinator, Engineering
- L. Klement, Licensing Engineer
- A. Harrison, Physical Description Team Leader
- A. Gutterman, Attorney Bechtel Power Corporation (BPC)
- J. Hurley, Assistant. Project Manager, Engineering
- K. Dotterer, Quality Assurance-
- S. Cozzens, Project Quality Engineering
- S. Sterns, Quality Engineer Brown & Root, Incorporated (B&R)
- B. H. Boas, SPE, Physical Plant Design Assurance
- 1. A. Hedderly, DPE, Physical Plant Design Assurance
- F. M. Garza, Piping Engineer
- J. B. Blakley, DPE, Piping & ISI Engineer
- E. W. Leschber, SPE, Physical Plant Design Engineer
- Attendees at meeting on February 24, 1982
- Attendees at meeting on February 11, 1982 2.
Visit to STP Model On February 11, 1982, a visit was made to the B&R Crestpark facility to view the STP model.
Personnel contacted during the visit are identified in paragraph 1.
The purpose of the visit was to relate some of the Quadrex Report findings identified in paragraph 4.9, ISI and Maintenance Access, to the STP model.
No conclusions were drawn on the findings; however, it was noted that some of the items observed and included by Quadrex in their report had been corrected.
Discussion with B&R personnel also indicated that action to correct the findings had been taken in specific cases.
This had occurred where the problem had been identified previous to the Quadrex design review efforts in February-March 1981.
B&R representatives indicated that many of the Quadrex findings were items previously known and had been identified to Quadrex.
3.
Status of HL&P and Bechtel Review of Quadrex Report A meeting was held at the Bechtel offices in Houston on February 24, 1982, to determine the existing management controls established by HL&P and
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Bechtel for the review and resolution of the Quadrex Report findings.
Those in attendance are indicated in paragraph 1 above.
The informa-tion given below was provided to the NRC inspector:
(a) In the HL&P organization, specific responsibility for the Quadrex Report has been assigned to a special coordinator in the STP Project Engineering Group.
The special coordinator reports to the supervisor of project engineering.
HL&P plans to review specific Quadrex findings only as they are identified in technical work packages.
The system work packages are to be submitted to HL&P for review and final acceptance.
Guidelines or instruction for HL&P review of the Quadrex finding resolution have not been issued.
Further, the HL&P repre-sentative stated that there are no plans to issue such instructions.
HL&P QA input on the Quadrex Report was not known.
(b) Responsibility for technical review and assessment of the Quadrex Report has been assigned to Bechtel.
Their initial efforts will be included in a report to be issued about March 15, 1982.
This report will document the activities of a Bechtel Task Force working out of their San Francisco offices.
The purpose of the task force was to prepare an initial assessment of the findings and to group them into various categories.
The report will then be used by the Project as a reference point for the detailed resolution of the findings.
The Houston based project team will review each finding during the work package review and make appropriate recommendations.
Thus, acceptance of a work package by HL&P would indicate their acceptance and approval of the included Quadrex Report items.
No plans presently exist for Bechtel QA involvement in review of specific Quadrex Report finding resolutions.
However, they will be involved in the review of engineering work packages.
Within the Bechtel organization, responsibility for the detailed
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review and resolution of all Quadrex findings falls under the general supervision of an assistant project engineering manager. With-in the Houston Project Engineering Group specific responsibility will be assigned to the Supervisfor, Nuclear Discipline.
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Bechtel Procedure, 1.0 STP Transition Procedure - Engineering (January 15, 1982), was reviewed for application to Quadrex Report resolution.
The procedure requires that all work packages are to be reviewed for applicable Quadrex Report items.
However, it is not sufficiently detailed to determine how the Quadrex Report items will be addressed in the package review.
Bechtel is in the process of preparing detailed work assignments.
Specific identification of findings will be included in a "Quadrex Compliance Package" (EN-619)
i which will be used as an inventory document for Quadrex findings.
Preparation of this work package will commence approximately April 1, 1982, with a target completion date of August 1, 1982.
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finding is to be identified and tracked until final resolution. The basis for the resolution will be documented or referenced in EN-619.
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The HL&P and Bechtel representatives stated that each finding in Volume I (of the Quadrex Report) would be examined.
Priority of review would depend upon the March 15 report of assessment and categorization.
It was also stated that Volumes-II and III of the report would be used only as reference documents.
After further discussion between the NRC inspector and licensee representative, HL&P agreed to reexamine their approach to Volume II and III in view of the numerous recommendations contained in these volumes that were not identified in Volume I.'
The Bechtel ' San Francisco office will not have any responsibilities for the Quadrex Report after the March 15 report has been issued, except for clarification of items in the report.
In addition, Quadrex Corporation is not expected to be involved in any subsequent resolution of their findings.
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Conclusion Regarding Quadrex Report-Management Controls The process for management of the Quadrex Report findings and their resolution is contained in the general transition procedures for engineering work package _ generation and review.
Specific tracking and documentation of resolutions for Volume I items will be the subject of a compliance work package EN-619.
Although detailed-Quadrex review criteria and procedures have not yet been generated by HL&P or Bechtel, qualified management personnel in these organiza-tions have been designated and are aware of~their respective respon-sibilities for review of the Quadrex Report.
All Quadrex items are to be resolved through the Houston Bechtel Project Engineering office.
However, backgound information and necessary clarification
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of findings may have to be obtained from Quadrex Corporation, Brown
& Root, Inc., Houston, and Bechtel, San Francisc DETAILS SECTION 3 1.
Persons Contacted Houston Lighting and Power (HL&P)
- J. E. Geiger, Project Quality Assurance Manager
- D. R. Keating, Project Quality Assurance General Supervisor
- J.-W. Williams, Project Site Manager Bechtel Power Corporation (Bechtel)
- W. F. Houston, Project Quality Assurance Engineer
- B. R. McCullough, Construction Manager Ebasco Services, Inc. (Ebasco)
- J. Crnich, Construction Manager
- C. Hawn, Quality Program Site Manager
- Denotes'those personnel who attended management meetings during the report period.
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The RRI also interviewed other licensee and contractor personnel, including members of the engineering and QA/QC staffs'.
2.
Site Transition Activities During this report period, the RRI observed site preparations for the transition of responsibilities and functions for the licensee and contrac-tors in the following' areas:
a.
Receiving, filing, and storage of records in the vault.
b.
Receiving, inspection, and storage of material and equipment in the warehouses.
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Maintenance and preservation of structures, equipment, components,
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l and materials.
Preparations were in progress as confirmed by the RRI during his review of selected records. Where the transition permitted an overlap, the con-tinuity of these functions did not present a particular concern to the RRI.
Where the responsibilities will be reassigned, particularly those which will be performed by the new constructor, there appeared to be very little time remaining to complete preparations.
Procedures have to be written and approved.
Qualified personnel must be assigned to these functions and receive training on the approved procedures.
This item is unresolved (498/82-03-01) pending further review of the transition acitivites.
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3.
ASME Transition Activities
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Brown & Root (B&R) by formal agreement dated January'15, 1982, agreed to prepare marked-up prints which indicate the ASME Section III field fabri-cation and installation status of piping systems, including the field fabrication of piping subassemblies (lines) and pipe supports.
The following items were to be documented and maintained in a Certification of Code Status Report (CCSR) or as supporting documentation:
a.
The Weld Data Card or' suitable alternative completed to the point of fabrication.
b.
Applicable Manufacturer's Data Reports, Certified Material Test Reports (CMTR), and/or Certificates of Compliance (C of C) for piping materials, filler metal, etc.
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Welding Procedure Specifications (WPS) and Procedure Qualification Records (PQR) that support the activities noted on the Weld Data Card.
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Welder /NDE personnel Qualifications.
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Installation or marked-up drawings (isometrics) that provide weld identification and status.
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NDE reports.
A licensee QA inspector conducted audit / implementation review (IR), M-022, of the ASME transition activities.
The following are examples of items considered by the licensee QA inspector during his review:
a.
Proper certifications of QC inspectors performing walkdowns.
b.
Satisfactory training for review and verification personnel.
c.
As-Built Verification Reports (ABVR) list applicable design documents required to verify hardware configuration.
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Status logs verified against documentation filed in the records vault.
e.
Signatures on drawings following completion of walk-downs.
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Completed packages were reviewed for adequacy, completeness,_and inclusion of required documents.
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Field verification of information recorded on drawings.
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Verification that installation has been documented for all ASME code system.
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QA engineers and other assigned personnel are performing review and verification of Weld Data Cards, procedures, etc.
The RRI accompanied the licensee QA inspector during a large portion of his implementation review.
Examples of items considered by the RRI during the QA audit of the ASME transition activities are given in the following:
a.
Proficiency and knowledge of the QA auditor with respect to ASME transition activities.
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Adherence to the approved implementation review (audit) plan.
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Adequacy of the audit plan to reflect the accuracy of the documenta-tion relative to the current as-built status, d.
Ability of the current Implementation Review System to identify and correct-discrepancies identified during this review.
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A package was established for.each subsystem (isometric drawing) and
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related documentation. The following packages were reviewed for adequacy
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of enclosed documents:
a.
3M361P-BR-1002-UB-3, Rev. 2C, Sheet 1 of 1 b.
3M361P-BR-1007-UB-3, Rev. 4F, Sheet 1 of-2 c.
3M361P-BR-1009-UB-3, Rev. 2D, Sheet 1 of 1 d.
3M361P-BR-1028-UB-3, Rev. 08, Sheet 1 of 1 Walk-downs of the following-lines (subsystems) were performed to determine the accuarcy of'the marked-up drawing as compared to the actual installa-tion:
a.
CC-1425 Sheet 1 of 4'
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CV-1046 Sheet 2 of 2 c.
CH-1002 Sheet 2 of 3 For line CV-1046, Sheet 2 of 2, a code plate serial number for spool
"G" and the existence of a hold tag for NCR SG 8962 were not documented.
This package had not received final review.
The QA inspector noted on the l
comment section of the Implementation Review Checklist that these items were corrected prior to final review of this package.
An additional comment by the QA inspector on the IR indicated that B&R welding engineers obtained a list of hangers and piping systems for which installation work had been performed.
This list was provided by B&R Engineering Department for package preparation.
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With respect to the above' Implementation Review '(audit) the RRI considered that the QA inspector was knowledgeable of the ASME transition activities and requirements and was qualified to perform IR M-022.~
The IR was adequate to demonstrate that the licensee had a program in effect to monitor B&R documentation of ASME Section III' field fabrication and installation status.
The NRC RRI reviewed the following ASME packages which had been completed and filed in tN records vault:
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2M361P-CV-1006-KB2 (Sheet 5 of 7. Rev. 38):
isometric drawing, hanger drawing, strut drawing, ABVB inspection checklist, and Certification of Code Status Sheet.
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2M361P-CV-1019-PB2 (Sheet-1 of 2, Rev. OB):
isometric drawing, ABVR inspection checklist, and Certification of Code Status.
Any incomplete items were listed in paragraph 7 of.the Certification of Code Status.
The RRI discussed the status of incomplete items with the licensee senior QA representative onsite.
He stated that each'of these incomplete items must be dispositioned. Where subsequent work was required, the item must be dispositioned first. With regard to subsequent identification of ASME welds or other code items for which no package had previously been prepared, the QA representative stated the ASME package will provide the field fabrication, installation, and-related documenta-tion status.
He stated that should subsequent installation be identified,
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the documentation must be available or the system or subsystem must be reworked.
The RRI had no further questions regarding ASME related activities or site audits.
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Storage and Maintenance (
The RRI observed activities in several warehouses and other designated l
storage areas with particular attention paid to the following:
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Classification and location of specific equipment:
Various storage areas were segregated and classified as Levels A through D to provide appropriate storage and environmental control for various use of equipment.
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Temperature and humidity were being measured and recorded to confirm
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that ambient conditions were being controlled as appropriate.
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Storage areas were not being used to store food, drink, or salt.
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An active program was in effect to control rodents and small animals.
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Racks, crates, and cribbing were carrying the full weight without component distortion, i
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All items were labeled and stored in a manner that allowed access for inspection.
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Fire protection systems and equipment were available for use.
h.
Sufficient dunnage was available for materials and components in-storage.
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Canvas or plastic covering was available for weather protection as required.
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Protective covers and seals were properly attached.
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Personnel access to the storage locations were adequately controlled.
The RRI reviewed the maintenance records for the following items:
V-10957 3" Motor Operated Gate Valve 1500# (CS)
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P0 No. 4038, Item 13, Serial No. E6288-20-3
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V-10958 3" Motor Operated Gate Valve 1500# (CS)
P0 No. 4038, Serial No. E 6288-20-4 V-10992 3" Motor Operated Gate Valve 1500# (CS)
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P0 No. 4038, Serial No. E 6288-20-6 V-10950 4" Motor Operated Stop Check Valve 900# (CS)
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P0 No. 4038, Serial No. E 6288-18-2
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V-10951 4" Motor Operated Stop Check Valve 900# (CS)
P0 No. 4038, Serial No. E 6288-18-3
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V-10952 4" Motor Operated Stop Check Valve 900# (CS)
P0 No. 4038, Serial No. E 6288-18-4
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H-0135 RCB MSIV Structure Supply Fan, Serial No. SF-40071
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H-0203 Chill Water Pump 21C with motor, Serial No. 813203 l
H-0204 Chill Water Pump 21A with motor, Serial No. 813201
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H-0205 Chill Water Pump 218 with motor, Serial No. 813202
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H-0130 Chemical Addition Tank, Serial No. 7-3089
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M-0311 Boron Injection Tank, Serial No. 0082
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M-0407-E Spent Fuel Pit Cooling Pump "A" with 200 HP motor, I
Serial Nos. N232B076-1 (pumr:), 7808-01-001 (motor)
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H-0122 IVC Supply Fan No. 11B with motor, Serial No. SF-40061
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H-0127 DGB Ventilation Fan 21A with motor, Serial No. SF-40076
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H-0131 DGB Vent Fan No. 21B with mctor, Serial No. 40077 H-0133 DGB Vent Fan No. 21C with motor, Serial No. 40078
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Each maintenance card had the following maintenance actions listed:
d.
Megger check b.
Heat check c.
Shaft rotation d.
Lubrication'with Gulf precision grease e.
Desiccant 60 percent RH maximum f.
Purge g.
Protective coatings
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Protective covers i.
Other:
Integrity check; "D0 NOT STR0KE"; as specified Each applicable item by type was. scheduled at periodic intervals.
The RRI determined that a satisfactory maintenance program was in effect and that adequate records were being maintained. When conditions other than normally expected were identified by the maintenance personnel,'the -
conditions were specified in the comment section of the maintenance record.
The RRI confirmed by discussion with the maintenance record personnel that a system was in effect to identify these conditions and
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bring them to management's attention for resolution and correction where appropriate.
The RRI identified'no unsatisfactory conditions during this review of maintenance records.
5, Quality Assurance Organization In correspondence dated December 11, 1981, the licensee revised the Quality Assurance Program for the Design and Construction Phase of the South Texas Project.
During a review of the organization section of this correspondence and interviews with site QA personnel, the RRI determined that one super-visor's position was being filled on a temporary basis (acting).
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Project QA General Supervisor, Quality Engineering, was acting as the Quality Engineering Project QA Supervisor (Mechanical /NDE).
The qualific-ations of the individual acting in this position were acceptable.
Through discussion with licensee personnel, the inspector determined that an active effort was ongoing to hire a qualified indiv~. dual for this posi tion.-
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This item is unresolved (498/82-03-02) pending staffing of this position by afqualified individual on a permanent basis.
6.
Unresolved Items Unresolved items are matters about which more information is requried in order to ascertain whether they are acceptable items, violations, or deviations.
Two unresolved items disclosed during this' inspection are discussed in paragraphs 2 and 5 of this report.
7.
Management Meetings Meetings were held with senior facility management periodically during the course of this inspection to discuss the' inspection scope and findings.
A summary of inspection findings was provided to the licensee at the conclusion of the report period.
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17-DETAILS SECTION 4 1.
Persons Contacted-Principal Licensee Employees
- J. E. Geiger, Project QA Manager
- D. R. Keating, Project QA General Supervisor-I. P. Morrow, Construction Superintendent D. W. Bohner, Project QA-Supervisor, Electrical /I&C Other Personnel
- J. Downs, Deputy Manager, Construction, BPC W. Houston, Project QA Engineer, BPC R. Meggison, Project QC Engineer, BPC R. Carter, Acting Assistant Project Field Engineer,.BPC J. Kopicka, Project Construction Engineer, BPC W. Warner, Training Supervisor, BPC D. Wells, QA Engineer, BPC J. Barlow, Project Material Supervisor, BPC
- D. Harris, Assistant Project QA Manager, B&R F. Rothermel, Assistant Project Manager, B&R A. Hamons, Site Surveillance Manager, B&R R. Hargrove, Acting QA Site Audit Supervisor, B&R S. Loprete, Quality Systems Manager, B&R
- Denotes attendance at the exit interview on February 18, 1982.
2.
Site Tours The NRC inspector (contract) toured the site on February 18, 1982, to observe caretaking, housekeeping, and equipment storage.
No violations or deviations were identified.-
3.
Brown & Root Site Transition Activities Brown & Root transition activities reviewed during this portion of the inspection conducted February 17 and 18,' 1982, included storage and maintenance of equipment, maintenance of QA records, updating of NCRs in the computer system, surveillance of subcontractor phaseout, and QA audits and surveillance of transition activities.
The-NRC inspector was informed that B&R involvement in STP site transition activities will end on March 31, 1982.
The'new constructor will begin assuming some of the transition duties in March 198 The NRC inspector observed that storage and maintenance of materials and equipment located in levels-C and D storage areas appeared to be in accord-ance with B&R procedural requirements.
It was observed that the stored equipment and materials were adequately protected from environmental conditions.
The QA records vault was being operated by B&R personnel in accordance with previously established B&R procedures.
QA record vault activities were being primarily conducted in support of site transition activities.
Many records previously in the vault were removed in 1981 for the vendor control program document review conducted in the B&R Houston office and have yet to be returned.
Vault storage conditions appeared to meet B&R procedural and ANSI N45.2.9 requirements.
HL&P representatives stated that upon B&R's departure, QA records vault operations will be taken over by HL&P Records Management System personnel.
The B&R Material Review Board will continue to function until March 20, 1982, on an as-needed basis for processing of nonconformance reports (NCRs).
Updating of NCRs in the computer system was in progress.
There were 4559 NCRs in the computer and approximately 1400 old NCRs remained to be entered in the system.
Approximately 650 NCRs were open and 70 NCRs had not been dispositioned.
Processing of the NCRs by B&R was expected to be completed in a timely manner.
During the transition period, B&R site surveillance personnel have per-formed periodic surveillance over subcontractor phasnout activites.
B&R surveillance efforts have been devoted to Champion (concrete supply),
Bahnson Service Co. (HVAC), and Pittsburgh Testing Laboratory (PTL),
(concrete and soils testing).
The concrete batch plant was shut down and Champion had only a minimum staff onsite.
PTL completed the last safety-related concrete cylinder break tests on February 8,1982, and continues work on some soils items related to the April 30, 1980, NRC Show Cause Order.
PTL had a minimum staff remaining onsite.
Bahnson had demobi-lized and their personnel left the site on December 10, 1981.
Bahnson's.
records were maintained in the site QA records vault and HVAC materials were in storage on the site.
The NRC inspector reviewed 18 B&R " Site Surveillance Reports" related to the above activities.
The surveillances appear to have been conducted in accordance with established B&R proce-dural requirements.
The NRC inspector discussed B&R audit and surveillance of site transition activities with the B&R acting QA Site Audit Supervisor.
Audits of transition activities have been performed but reports of these audits have not been completed and issued.
These audit reports (ST-T-1, ST-T-2 and ST-T-3) will be reviewed during a future NRC inspection.
No violations or deviations were identified during this nart of the inspection.
a
4.
Bechtel Site Transition Activities BPC transition activities reviewed during this inspection conducted February 17 and 18, 1982, included development of general construction procedures, statusing of existing construction, development of training programs and statusing of material.
BPC has developed 22 general construction procedures and 8 procedures were in the process of development at the time of this inspection.
Revisions required to reflect current site construction manager /construc-tor responr.ibilities (BPC/Ebasco) were expected to be completed during the week of February 22, 1982.
Detailed review of these procedures will be performed during a future NRC inspection.
Documentation of the status of installed equipment was in progress and was being accomplished by marking up drawings obtained from the Site Document Control Center.
Copies of marked-up safety-related drawings are provided to QA for review.
Equipment status is classified in the following categories:
installed and accepted by the current contractor; installed, not accepted; or partially accepted.
Documentation of the status of. stored material and equipment was also in progress.
Detailed review of material and equipment status will be performed during future NRC inspections.
BPC Construction Management was developing a program for indoctrination of BPC employees (except QA/QC) involved in nuclear safety-related work.
The QA orientation program for BPC QA/QC personnel was being developed by BPC QA.
BPC QC-personnel are qualified in accordance with Los Angeles Power Division (LAPD) procedures to ANSI N45.2.6 requirements. The NRC inspec-tor observed that training sessions for BPC construction management and QA personnel were held on February 17, 1982.
Detailed review of indoctrina-tion and training will be performed during future NRC insoections.
No iiolations or deviations were identified during this part of the inspection.
5.
QA Program Development The HL&P Quality Assurance Program Description (QAPD) addresses the HL&P quality assurance program (Part A) and the quality assurance program of BPC (Part B).
The Constructor's (Ebasco's) QAPD (Part C) is expected to be submitted to NRR for review on March 8, 1982.
The HL&P quality assurance program for STP is described in the HL&P Project Quality Assurance Plan (PQAP).
The PQAP specifies requirements applicable to HL&P, its prime contractor, subcontractor and vendors.
HL&P compliance with ANSI N45.2 and applicable daughter standards and imple-menting Regulatory Guide is indicated in Table 2 of Part A of the QAP.
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HL&P will assure that the prime contractors and their subcontractors and vendors performing nuclear safety-related work comply with 10 CFR Part 50 Appendix B, ANSI N45.2, and the Regulatory Guides referenced in Part A of
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the QAPD consistent with their scope of work.
HL&P plans and procedures which are used to implement quality-related activities for each major HL&P organization are listed in Table 1 of Part A of the QAPD.
The BPC QA program for STP is described in the NRC approved Bechtel Topical Report BQ-TOP-1, Revision 3A, "Bechtel Quality Assurance Program for Nuclear Power Plants" and the modifications and additions described in Part B of the QAPD.
The BPC Project Quality Program Manual (PQPM) for STP describes the requirements of BQ-TOP-1, Revision 3A, as modified by Part B of the QAPD, Revision 2.
The PQPM describes quality program activities of engineering, procurement, construction management, and quality assurance.
The PQPM does not provide detailed implementing procedures for quality activities.
Detailed procedures are contained in existing LAPD manuals including Engineering Department Procedures (EDP's), Procurement Supplier Quality Manual (PSQM), and QA Department Procedures (QADP's), and in the Field Quality Manual and the Project Procedures Manual being developed specifically for STP.
The LAPD QA Manual has been invoked for site project QA activities.
Detailed review of STP QA program development and implementation will be performed during future NRC inspections following issuance and approval of the constructor's QA program documents.
6.
Exit Interview The NRC inspector met with licensee representatives denoted in paragraph 1 at the conclusion of the inspection.
The NRC inspector summarized the l
purpose and the scopa of the inspection and the findings.
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