IR 05000498/1986014

Insp Repts 50-498/86-14 & 50-499/86-14 on 860428-0529.No Violation or Deviation Noted.Major Areas Inspected: Corrective Action & in-depth QA Insp of Performance

ML20202F128
Person / Time
Site:	South Texas
Issue date:	06/24/1986
From:	Jaudon J, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20202F095	List: IR 05000498/1986014 ML20202F090
References
50-498-86-14, 50-499-86-14, NUDOCS 8607150099
Download: ML20202F128 (7)

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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/86-14 Construction Permits: CPPR-128 50-499/86-14 CPPR-129 Dockets: 50-498 50-499 Licensee: Houston Lighting & Power Company P. O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 s Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: April 28 through May 29, 1986 i

1 Inspector

# M b W. M. McNeill, Project Engineer, Project Daty /

Section A, Reactor Projects Branch

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Approved: e M /M [2

, Chief, Rroject Section A, Dyte [

/. P/ Jaud Refactor rojects Branch

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Inspecticn Summary Inspection Conducted April 28 through May 29, 1986 (Report 50-498/86-14;

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50-499/86-14 Areas Inspected: Routine, unannounced inspection of corrective action and in-depth QA inspection of performanc Results: Within the two areas inspected, no violations or deviations were identifie egg 71gg $ge G

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DETAILS Persons Contacted Houston Lighting & Power (HL&P)

R. M. Cantrell, QA Specialist W. Carroll, Startup Engineer

• S. M. Dew, Deputy Project Manager J. E. Geiger, Manager, Nuclear Assurance C. L. Harvey, Project QA Supervisor, Quality Systems / Administrative

• 5. M. Head, Lead Licensing Engineer

• T. J. Jordan, Project QA Manager P. E. Parish, Senior QA Specialist S. D. Phillips, Licensing Engineer R. J. Rehkugler, Project QA Supervisor, Audits A. C. Von Nyvenheim, Senior QA Specialist

• J. T. Westermeier, Project Manager Bechtel Corporation (BEC)

• L. W. Hurst, Project QA Manager J. T. Jabaley, Field Document Control Supervisor

• R. H. Medina, QA Supervisor L. A. Mooney, Project QA Engineer R. M. Nilius, QA Engineer J. E. Noxon, QA Engineer D. E. Robinet, Receiving QC Engineer W. M. Senn, Lead Receiving QC Engineer W. J. Soelberg, Receiving Inspector G. B. Wagner, Lead Piping Engineer

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Ebasco Services Inc. (ESI)

4 * L. Calsyn, QC Unit Supervisor J. B. Cleere, Supervisor, QA/QC Training G. B. Conner, Lead Level III Trainer W. J. English, Field Engineer J. W. Lively, Lead Inspector J. L. Matt, Field Engineer D. Miller, Inspector J. R. Parks, QC Manager

• G. Peck, Deputy Quality Program Site Manager R. Powe, QA Engineer T. E. Rackley, Inspector J. L. Sullivan, Inspector J. V. Sullivan, QC Supervisor J. L. Vanderslice, Lead Inspector W. Williamson, Inspectc*

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The NRC inspector also interviewed other licensee and contractor employees during the course of the inspectio * Denotes those attending the exit intervie . Corrective Action The objective of this inspection was to determine whether the licensee has developed a comprehensive corrective action program to identify, follow and correct safety-related problems. In this regard, the Quality Assurance Program Description, Revision 14, dated May 2, 1986, and the following documents were reviewed:

Procedure Number Title Revision Number Date

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Project QA Plan 8 10/24/85 j SSP-8 Nonconformance Reporting 2 04/21/86

PLP-02 Reporting Design and 7 09/26/85 Construction Deficiencies to NRC PSQP-16.3-04 Trend Analysis 3 02/19/86 i

IP-4.1 Q Nonconformance Control 1 08/16/85 IP-4.2 0 Corrective Action System 1 11/20/85 QAIP-1 Trend Analysis 1 12/11/85

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STP Project Quality Program 10 02/21/86 j Manual I

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QA Manual ASME 8 02/21/85 EDP-4.61 Nonconformance Reports 1 08/07/84 GPR-2.20 Reporting Significant 2 09/23/85 Deficiencies GPR-2.19 Report Substantial Safety 2 09/23/85 Hazards Defects and Noncompliance WPP/QCI- Nonconforming Material, Parts 14 02/15/85 and Components I

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WPP/QCI- Review of Nonconformances 7 03/18/82 l ETR-1001 Nuclear QA Program Manual 13 03/28/86 SQAP-2 Deficiency Reporting 2 04/08/86 QCP-1 Identification and Control of 9 04/02/86 Deficiencies and Nonconforming Conditions QAI-004 Issuance and Processing of 8 12/13/85 Nonconformance Reports QAI-007 Reportable Deficiencies 4 03/25/85 QAI-011 Corrective Action and Stop 8 11/22/85 Work Authority The recent " Trend Analysis Reports" (issued by HL&P for the last quarters of 1985), " Design Deficiency Reports" (issued by BEC for the months of July, August, and September, 1985), "NCR/DN Data" (issued by ESI for December 1985) and the "QA Engineering Department Trend Analysis" (issued by ESI for the second half of 1985) were inspecte The NRC inspector found that the procedures addressed the identification of problems from various sources such as construction deficiencies, audit findings, preoperational events, etc., and determined that the controls for tracking and resolution of the problems identified. In the event of frequent or repetitive problems, it was found that there were at least two levels of action which identify that type of problem in either a " Standard Deficiency Report" or a " Trend Investigation Report." The trend reports applied the "Pareto Principle" to identify the elements, kinds, or types of errors which make the most.significant contribution to the total picture of errors. The HL&P trend reports divided activities into engineering, systems, operations, hardware and supplier type In addition to a trend analysis in each activity there was also an executive summary. Each section identified the type of nonconformance documentation which was used to provide the data base (e.g., Standard Deficiency Report, Audit Deficiency Report, Document Deficiency Notice, Nonconformance Reports, Maintenance Deficiency Reports, etc.). The data in a section were generally analyzed by discipline; e.g., civil, electrical, mechanical, etc., and deficiency type; e.g., failure to follow procedure, drawing, inadequate procedure, et A sample of two recently completed " Trend Investigation Reports" were reviewed by the NRC inspector. The identification of the root cause of the problem, corrective and preventive actions and followup were found in these reports. A sample of 17 nonconformance reports were likewise reviewed by the NRC inspector and the classification of the defect codes was reviewed by the NRC inspecto . . . - . - - - -

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i One concern of the NRC inspector was the effectiveness of HL&P management review of trend reports. Several input errors dere noted by the NRC s inspector in his review. For example, the total of errors on page 11 of 0 the third quarter report on engineering was incorrect. Several other s errors were also noted. In the summary of the third quarter report on engineering there was a conclusion that: "the percentage of (errors) had s

decreased in the HVAC area . . ., which had previously been a problem

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\ a rea. The method used to decrease the percentage in HVAC had been a

\' series of meeting / coordination sessions . . . . Bechtel will use this approach in the Plant Design /PSSG disciplines in order to reduce the percentage of (errors)." However, it was noted by the NRC inspector that the conclusion was based on data not corrected for activity level. If the

\ data were corrected for activity (e.g. , number of documents reviewed) then s

there was no reduction in the percentage of errors. This conclusion was T obviously unsound and should have been questioned when given a c.ritical

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3 In-Depth 0A Inspection of Performance

'\ The objectives of this inspection were to determine whether: site work is '

i i being performed in accordance with NRC requirements, safety analysis s report commitments and implementing procedures; the quality

assurance / quality control program is functioning in a manner to ensure that requirements and comitments are being met; prompt and effective action is taken to achieve permanent corrective action on significant discrepancies. In this regard, the Quality Assurance Program Description, Revision 14, dated May 2, 1986, and the following documents were reviewed:

Procedure Revision Number Title Number Date

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Project QA Plan 8 10/24/85 i

, SQAP-03 Project Audits 2 03/25/86 PSQP-1 Limited Readiness Review Audit 2 03/10/86

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Program l PSQP- Training, Qualification and 0 03/31/85 l

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Certification Audit Personnel i

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STP Project Quality Program 10 02/21/86 i Manual

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WPP/QCI Receiving Inspection 12 04/04/86 WPP/QCI Control of Inspection Planning 7 05/21/85 4L060PS1006 ASME Section III Bulk Piping 7 03/07/86 Material l

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l l ETR-1001 Nuclear QA Program Manual 13 03/28/86

SSP-24 Disassembly / Reassembly of Safety 0 11/01/85

, and Nonsafety Related Valves

! SSP-18 General ASME III Welding 4 04/29/86

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Requirements

QCP- Indoctrination, Training and 6 02/07/86 Qualification of Quality Control

Personnel

, QA-G- Qualification of Inspection, 5 03/19/86 Examination and Testing Personnel

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I QAI-018 Quality Assurance Indoctrination 4 11/12/85 and Training Program A sample of five ESI inspections were witnessed by the NRC inspector. The work packages were reviewed for each inspection. The referenced drawings

, and procedures and the documentation of the inspections were examined by I the NRC inspector. The inspections were: a flued head penetration weld in work package 6921Q; feet water system valve installation in work

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package 9315; residual heat removal valve clean up in valve checklist 1-0296; actuator torque on a main steam drag valve in work package 9359; and residual heat removal pump valve (work package not assigned). The training records of the four inspectors who performed the above inspections were reviewed by the NRC inspector to verify the

qualification of the inspectors. Receiving inspection of three lots of materials were witnessed and reviewed by the NRC inspector. The three

lots were: pipe nipples on MRR B-29089; pipe reducers on MRR B-29247; and

] hanger spring cans on MRR B-29174. The NRC independently verified the material to meet specifications and purchase order requirements, i

, One observation of the NRC inspector was that of the five ESI inspections reviewed, one had a problem with the information in the work packag Work Package No. 9315 had a valve control card for serial number ZN-4-3; i however, the valve installed was serial number ZN-4-11. The above problem

! appears to fit the definition of a nonconformanc Procedure SSP-8, paragraph 5.2.1.1, defines a nonconformance as a deficiency in characteristic, documentation, or procedure which renders the quality of

! an item unacceptable or indeterminate and requires engineering evaluatio l Additional work packages were reviewed by ESI, and no further problems ;

identified in the nine packages reviewed. This was documented in General i Surveillance Report No. SE-1465. From discussions between inspection i personnel and the NRC inspector, it appears that inspection personnel may be reluctant to document work package errors. This is an unresolved item

to be addressed in a future inspection. A larger sample of work packages

! will be reviewed to assure that work package errors are being properly j identified and documented (8614-01).

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In addition to the review of field inspections, the auditing program was also reviewed. In this regard, the auditing activities of the first quarter of 1986 were reviewed and a sample of five audits were reviewed in depth by the NRC inspector. The project audit plan for 1986 and the project audit schedule for 1986 were examined. Also the master limited readiness review audit plan and the limited readiness review audit program schedule. The audits sampled were in the activity areas of C-14, D-08, G-34, L-03, and S-4 The observation of the NRC inspector that audits were not covering all applicable procedures had been previously identified by a BEC audit and a Corrective Action Request No. 86-14:3 had been issue . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether or not the items are acceptable violations or deviations. The following unresolved item was discussed in this report:

Paragraph Item Subject 3 8614-01 Documentation of Nonconformances in work package . Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1) and Mr. D. Garrison, the NRC Resident Inspector on May 29, 1986, and summarized the scope and findings of this inspection.

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