IR 05000498/1986032

Insp Repts 50-498/86-32 & 50-499/86-32 on 861006-1121.No Violations or Deviations Noted.Major Areas Inspected: Licensee Mgt of QA Activities & QA Program Evaluation of Engineering Svc Organization

ML20212Q737
Person / Time
Site:	South Texas
Issue date:	12/19/1986
From:	Jaudon J, Mcneill W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20212Q716	List: IR 05000498/1986032 ML20212Q711
References
50-498-86-32, 50-499-86-32, NUDOCS 8702020349
Download: ML20212Q737 (7)

Text

.

APPENDIX U.S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report: 50-498/86-32 Construction Permits: CPPR-128 50-499/86-32 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 Inspection At: South Texas Project, Matagorda County, Texas Inspection Conducted: October 6 through November 21, 1986 Inspector: A $I./ /2[(afn W. M. McNeill, Project Engineer, Project Da'te '

Section A, Reactor Projects Branch Approved: e //l/) /1 /9 ftf aus%n, ChiefkProjdct Section A Date' '

Re -. Ptojects Branch Inspection Summary Inspection Conducted October 6 through November 21, 1986 (Report 50-498/86-32; 50-499/86-32)

Areas Inspected: Routine, unannounced inspection of licensee management of QA activities, QA program evaluation of engineering service organization,'and licensee action on previously identified inspection finding Results: Within the three areas inspected, no violations or deviations were identifie Okh[johdg

'

PD$

. -__

_ _

'

.

-2-DETAILS Persons Contacted Houston Lighting & Power (HL&P)

<

J. E. Adkins, QA Specialist

.

J.'B. Anderson, QA Specialist R. T. Bastier, QA Specialist G. B. Biggers, Genera ~1 Supervisor Technical Service W. C. Dekle, QA Specialist ,

D. E. Gallion, Lead Inspector J. E. Geiger, General Manager _ Nuclear Assurance J. D. Green, Operations QA Manager I. L. Guthrie, Program Manager Safeteam S. M. Head, Lead Engineer Licensing T. L. Jordan, Project QA Manager

• P. W. Ratter, Project QA Design Procurement Supervisor R. J. Rehkugler, Project QA Supervisor Audits B. J. Tedder, QA Supervisor Vendor Evaluation /Surveillence D. R. Valley, QA Specialist

• R. Wisenburg, Deputy Project Manager Bechtel Energy Corporation (BEC)

, N. Brandon, Assistant Project Records Manager A. F. Castaneda, Responsible Engineer E. T. Chang, Responsible Engineer

• K. R. Dotterer, Project QA Engineer

'

D. B. Getman, NSSS Group leader O. L. Hauglum, Project Supplier Quality Supervisor

• R. Heas, Deputy Project Manager

• Jewell, Project Procurement Manager

• A. Matink, Project Engineering Manager S. S. Mittal, QA Engineer L. A. Mooney, Project Quality Engineer L. Seals, Responsible Engineer P. G. Trudel, Nuclear Engineering Group Supervisor

• A. Zaccaria, Project Manager i

The NRC inspector also interviewed other licensee and contractor employees during the course of the inspectio * Denotes those attending the exit interview.

) i p ~ , , ,- et----

m ,.re- - ---- < - -w -

_ _ _ _ _ _ _ _ _ _

'

.

-3-2. Licensee Action on Previously Identified Inspection Findings (Closed) Violation 498;499/8612-07, part 1: Configuration Control Packages (CCPs) were issued with significant errors in the directions provide The licensee's reinspection effort defined by Construction Inspection Plan No. 2.2-62 was reviewed by the NRC inspector on a sample of six motor operators. The wiring diagram 9-E-NZ13-01, Revision 1, which identified the wiring required for Westinghouse supplied valves, was reviewed. The review of other CCPs developed by the same engineer was examined. It would appear that corrective actions, and preventative actions are satisfactor This item is close (Closed) Violation 498;499/8612-07, part 2: Vendor specified tolerances for installation of annubars were not referenced on drawing The NRC inspector reviewed the engineering. evaluation of these flow elements and the Incident Review Committee Report. The Nonconformance Reports (NCRs) to rewcrk flow elements (NCR Nos. SJ 3008 and SJ 3111) were examined. The revision of drawings was verified. The supplemental audits performed to identify the scope of this problem was inspected. It would appear that corrective actions and preventative actions are satisfactor This item is close (Closed) Violation 498;499/8612-07, part 3: Flow restriction orifices required by the Nuclear Steam Supplier were not included in the Architect / Engineer drawings for instrument and sample lines on the pressurize The engineering review of Piping and Instrument Drawings (P& ids) and Engineering Flow Diagrams by Bechtel Engineering Corporation (BEC) and Westinghouse was reviewed by the NRC inspector. The 10 CFR 50.55(e)

evaluation wa:: also reviewed. Training records verified that committed training has been performed. It would appear that corrective actions and preventative actions are satisfactor In review of the supplemental audit of the BEC and Westinghouse design input interface process performed to scope this problem, an open item was identified. The response letter by HL&P indicates one audit was performed and no significant discrepancies were found. However, there wera three audits performed S41-601, S44-601, and S47-601 and a total of 11 Standard Deficiency Reports (SDRs) issued. In that the HL&P response letter (ST-HL-AE-1754) does not fully describe the extent or scope of problems that were identified as a result of the supplemental audit activities, the NRC inspector obtained HL&P agreement to re. view the letter and supplement audit activity again to address these concerns so that the audits scope, findings, and the consequences of the findings are*more fully documented in the public record. NRC review of this is an open item (498;499/8632-01).

.

, .

,

-4-3. Licensee Management of QA Activities The objective of this inspection was to determine the status and effectiveness of licensee management and implementation of the corporate quality assurance program for ongoing activities of design, procurement, and construction. In this regard, the Quality Assurance Program .

Description, Revision 15, dated November 6, 1986, and the following documents were reviewed: Operations Quality Assurance Plan, Revision 3, dated Feburary 28, 1986; Project QA Plan, Revision 10, dated August 29, 1986; and various Standard Quality Assurance Procedures, Project Specific Quality Assurance Procedures, Quality Assurance Implementing Procedures, Interdepartmental Procedures, and Technical Service Procedure Organization The General Manager Nuclear Assurance is the senior manager for all nuclear quality activities, and he reports to a Group Vice President, who is responsible for all nuclear activities within HL& The General Manager has a staff of approximately 112 professionals. This includes a Safeteam of about 16. In the area of Quality Assurance, there are approximately 43 professionals under the Project QA Manager. Within Project QA there are about 6 professionals in Quality Control, 5 professionals in design / procurement and 11 professiona.ls in system / administration. Also within Project QA there are about 5 personnel in audits, 7 people in surveillance, and 7 professionals in analysi Within Quality Assurance there are approximately 43 professionals under Operations QA. Within Operations QA there are 14 professionals assigned under QA in various disciplines and 29 personnel assigned to QC in various disciplines. Lastly, under Quality Assurance there is Technical Services with 9 professionals. The activities of Project QA are in general defined by Project Specific QA Procedures, Standard QA Procedures, Site Standard Procedures, and Project Management Procedures. Operations QA activites are defined by QA Implementing Procedures, Inter-Department Procedures, and QC Implementing Procedures. The Technical Service group has Technical Service Procedure:. Some of the functions of these various greps are:

the Project QA group inspects and audits construction activities; the Quality Control group does second and third level surveillance over inspections; the design /procurcment group audits BEC activities of design and p.'oa.rement; the systems / adminstration group does trend analysis, records control, and document control; the audits grcup does the auditing for program effectiveness and adequacy; thc surveillance group does verification procedure implementation; the Analysis group follows corrective action and does other special projects; within Operrtions QA operational activities are reviewed with audits performed by the QA group and surveillance by the QC group; the technical service group does the QA of spare parts and other directly procured items and the corporate level audits of all HL&P QA. At this stage in the project development, there is a trend to shift staff into operational activites out of contruction activitie There is also planned an independent safety evaluation group which will be like the Safeteam in cdjunct to Q . - -- . - . . . - - - . . - - . _ _ _ _ _

, . . . -

i-5-

' '

Audits-

,

The internal and external audit activities were reviewed by the NRC'

inspector. The Institute cf Nuclear Power Operations has, for the last 3 years, audited the project activities of construction, startup end

operations. The corporate management reviews of the QA program as

'

perfonned by Technical Services were also inspected. The project audit i schedule, plan and associated procedurcs were reviewed. A sample of six

! -audits (Nos. C-16, G-34, G-46, G-53,.M-24, and S-44) and five personnel certification records were inspected in detail. Audits of the project are ;

. performed as an interparty effort meaning HL&P, BEC ar.d Ebasco (ESI) all

, participate together in audits. About 40 audits in 1986 were performed or .

! are planned with HLAP as the responsible lead with either an independent i

organization of BEC or ESI in support. 'About 30 were performed or planned i by BEC and 15 by ESI. The scope of the audits ranged from various .

,

j disciplines (civil, design, electrical, and mechanical) to more extensive scopes such a limited readiness reviews, supplemental and general j subjects. In review of the samples, it was verified that the audits wert

perfonned and documented in accordance with the implementing procedures

and personnel were properly qualified. The use of approved and detailed preplanned checklists, documentation of findings, followup on findings and l reporting to upper management of results appeared to be in orde Procurement

.

HL&P's procurement activity in the main consists of spare parts and other

! items and services necessary to support operation. The-Technical Services e i procedures detailing vendor evaluation, approval, and surveillance were i reviewed. A san:ple of eight vendcr history files (BBC, Bingham-Willamette, Elgar, GA Technologies, Johnson Controls, Kerotest Manufacturing, Lir.itorque, and Telecanique) were inspected. These files contained the vendor annual evaluations and triannual audits. It was i found that in 1986 about 40 vendor audits were performed. Almost all j vendors, although originally approved and audited by BEC, have been j reevaluated cnd apprcved by HL&P. This process also scoped the NSSS supplier for STP. Hence, the HL&P approved vendor list was found to be up to date. The vendor histocy files also contained the purchase order including changes and documentation of their QA review and approval. This i review and approval addressed technical and quality requirements. The

,

qualification records of five audit and surveillance personnel were-

inspected. Receipt inspection activities on site of nine purchase orders

,

(Numbered RPD-023334, RPD-016349, B-918, B-1549, ST-2120, ST-2234, B-749,

,

B-835, and B-945) were subjected to a records review and receipt-a' inspection of three purchase orders (Numbered B-749, B-835, and B-945)

were witnessed by the NRC inspecto '

Design i

Design activitir s of BEC are controlled by HL&P by overview surveillance at the BEC engineering offices in Housten. In addition to this activity j the same group of ilL&P does overview surveillance of BEC procurcirent

!

I

____ ._ ____ __ _

. . . -

-6-

.

activities. A sample of 13 overview surveillances (Numbered 707, 709, 717, 730, 811, 812, 813, 814, 816, 819, 818, 822, and 824) of'both of these activities were reviewed by the NRC inspector. It was found that approximately 56 overview surveillances were performed of BEC in the area of design. BEC performed approximately 45 vendor audits and 830 surveillances of which HL&P did overview on 3 of the above audits and 2 of the above surveillances. The later five overview surveillances Nos. 707, 709, 717, 730, and 811) were included in the NRC inspector's sample. The compliance to an established schedule, detailed approved checklists and implementing procedures by qualified personnel was verified by the NRC inspecto No violations or deviations were identified 4. QA Program Evaluation of Engineering Service Organization The objective of this inspection was to determine whether QA Program policies and procedures are established and implemented consistent with applicable procurement requirements for items and services that are important to the safety of a nuclear facilit In this regard, the Quality Assurance Program Description, Revision 15, dated November 6, 1986, and the following documents were reviewed: Project Quality Program Manual, Revision 11, dated September 3, 3986, and various Project Quality Assurance Procedures, Engineering Department Procedures, Project Procurement Procedures, and Procurement Supplier Quality Procedure QA Program & Organization Bechtel Engery Corporation (BEC) is a wholly owned subsidiary within Bechtel Western Power Corporation, a member of the Bechtel Group In BEC is constituteo soley for the South Texas Project effort. Other parts of Bechtel Group Inc., although not fully devoted to the project work, do support in part the project activities of BEC. This results in parallel functions in some activities such as procurement and quality assuranc The Houston offices houses both BEC and Bechtel Western Power Corporation with both organizations reporting to the Vice President and Houston manage The Program Manager of BEC reports to Vice President and Houston manage Reporting to the Program Manager is the Project Quality Assurance Manager with approximately 58 professionals. In the engineering area there is a Project Quality Assurance Engineer in the Houston office with four professionals reporting to the Project QA Manager. In addition, not within tne QA organization, but nevertheless performing a quality function, are two other groups. Reporting to the Project Engineering Manager through an assistant project engineer is a Project Quality Engineer with six professionals. The Project Engineering Manager simultaneously reports to the Engineering Manager, Bechtel Western Power Corporation, and Project Manager. Reporting to the Project Procurement Manager and the Manager of Central Procurement (San Francisco) through the Manager of Supplier Quality is the Supplier Quality Supervisor with three professionals. The program is defined first in the Quality Assurance Program Description and refined in the Project Quality Program Manual and

\

. . . -

-7-the ASME QA Manual. The program is implemented in the engineering area by Project Quality Assurance Procedures and Engineering Department Procedures. In the procurement area the program is implemented by Procurement Supplier Quality Procedures and Project Procurement Procedures in general. Management audits are performed of BEC under the Manager of QA, Bechtel Western Power Corporation. The NRC inspector reviewed the last 2 years audit The NRC inspector also reviewed the indoctrination i and training records of these personnel employed in vendor surveillance on project purchase order Engineering Controls Presently BEC has completed the basic design and modifications for the project. Design activities are limited to the administration of field changes called Field Change Requests and Field Change Notices. The NRC inspector reviewed a sample of eight Specification Change Notices (Numbered 4 to 3E169ES0014, 4 to 3E179ES0035, 7 to 4Z539ZS1054, 6 to 3Q159M50034, 8 to 3V109MS1037, 18 to 4H010PS0007, 5 to SR200RS1003, and 24 to 5A300GS1002) which are subjected to Project QA review and the result of field changes. It was verified that field changes received the prescribed controls and independent verification Procurement Controls Presently BEC has completed most of the procurement for the project. It !

was found that there was about 50 active purchase orders for safety-related (Q list) item The NRC inspector reviewed a sarrple of four (Numbered 14926-4176, 14926-6452, 1197-4041, and 14926-6437) of these purchase orders. The review and approval of the purchase orders and their changes was verified. It was verified .that the inspection plans for vendor surveillance were implemented and followed. The vendor selection and evaluation was verified for two of these purchase orders. Some purchase orders were " rollover" type purchases meaning they were inherited from Brown and Root. This activity had been previously inspected by the NRC ac part of vendor control program defined in the transition procedure Audits and Quality Assurance Records In that these two activities are "projectized," inspection of such at BEC is unecessar Audits has been addressed in the preceeding sectio Records will be the subject of a site inspection activit No violations or deviations were identifie . Exit Interview The NRC inspector met with licensee representatives denoted in paragraph 1 on November 21, 1986, and summarized the scope and findings of this inspectio l