ML19210B998
| ML19210B998 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/05/1979 |
| From: | Crossman W, Randy Hall, Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19210B988 | List: |
| References | |
| 50-498-79-13, 50-499-79-13, NUDOCS 7911130126 | |
| Download: ML19210B998 (31) | |
See also: IR 05000498/1979013
Text
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U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No.
50-498/79-13; 50-499/79-13
.
Docket No. 50-498; 50-499
Category A2
Licensee: Houstoa Lighting and Power Company
Post Office Box 1700
P.custon, Texas 77001
Facility Name: South Texas Project, Units 1 & 2
Inspection at: Houston Offices and South Texas Project
Inspection conducted: August 6-10, 1979
/0/d[79
Inspectors:
~
w-
g W. G. Hubacek, Reactor Inspector, Projects
Date
O
Section (paragraphs 1, 2, 3.k, 3.m, 7,10,
11, 12 & 13)
W
uL
lo - 2.-79
J. I. Tapia, Re(jtor Inspector, Engineering
Date
Su r :t Sectidd (paragraphs 3.i, 8 & 9)
44-. .
n/r/77
L. E. Foster, Inspection Cpecialist, RIl
sate
(paragraphs 2, 3.a, 3.b, 3.c, 3.e, 3.f, 3.g,
4, 5, 6 and 7)
/W
A
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H. S. Phillips, Resident Reactor Inspector,
Date
Projects Section (paragraphs 3.c, 3.d, 3.h,
3.j, 3.1 and 3.m)
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7911130
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Other
Accompanying
Personnel:
L. S. Waller, Engineering Aide (Co-op), Engineering Support
Section
Approved:
/4[f/g
W. A. Crossman, Chief, Projects Section
Dat'e
5
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ff) R. T Hall, C
ef, Engineering Support Secticn
.Ca t'e
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Inspection Summary:
Inspection on August 6-10, 1979 (Report No. 50-498/79-13; 50-499/79-13)
Areas Inspected:
Special, announced Mid-Term QA inspection of the establishment
and implementation of the licensee's QA program for site related activities in-
cluding design, procurement and construction. Areas inspected included QA
management, procurement control, document centrol, design control, vendor
surveillance, audits, QA/QC organization and site installation activities. The
inspection involved one hundred thirty-two inspector-hours by four NRC
inspectors.
Results. Of the eight areas inspected, five items of noncompliance were identi-
fied in three areas (failure to follow procedures for maintaining PDM QA Manuals -
infraction, paragraph 3.m: failure to follow procedure for conduct of PDM site
audits - infraction, paragraph 3.m; failure to delineate organizational change
in the PLM QA Manual - deficiency, paragraph 3.m; failure to maintain completed
audit checklists in audit files - deficiency, paragraph 3.k; and failure to
destroy or stamp deleted QA procedure - deficiency, paragraph 3.c).
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DETAILS
1.
Persons Contacted
Princiral Licensee Employees
- R. A. Frazar, Manager, Quality Assurance
- D. G. Barker, Manager, South Texas Project
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,
- J. H. Ferguson, Technical Consultant to the Vice President, Power Plant
Construction and Technical Services
- W. N. Phillips, Project QA Manager
- T. D. Stanley, Project QA Supervisor
- L. D. Wilson, Site QA Supervisor
- M. H. Smith, Plant QA Engineer
- S. A. Viaclovsky, Supervisor, Support Division
- R. L. Ulrey, Senior QA Specialist
H. G. Overstreet, Lead QA Specialist, Vendor Surveillance
- A. J. Granger, Project Engineering Manager
- B. F. Duncan, Startup Manager
A. E. Schoeneberg, Project Purchasing Manager
- R. C. Henson, Operations QA Supervisor
J. L. Blau, Supervising Project Engineer
J. R. Malleda, Lead Project Engineer - Mechanical
D. R. Valley, QA Specialist - Audit Co rdinator
P. A. Swearingen, General Supervisor, Records Management Division
M. d. Monteith, QA Technician
G. A. Marshall, Senior QA Specialist
J. A. Anderson, QA Specialist
R. R. Hernandez, Lead Project Engineer - Civil
S. C. Sims, Leader, Administrative Group
C. L. Grosso, QA Associate Engineer
Other Personnel
J. Dodd, Senior Project Manager, Brown & Root (B&R)
- C. W. Vincent, Project QA Manager, B&R
- G. T. Warnick, Site QA Manager, B&R
- H. O. Kirkland, Acting Project General Manager, B&R
- J. M. Salvitti, Assistant Construction Project Manager, B&R
- S. A. Rasnick, Manager, Construction Engineering, B&R
- R. G. Withrow, Assistant. Engineering Project Manager, B&R
D. E. Sewell, QC Civil Inspector, B&R
E. R. Vickery, Acting Lead Cadweld QC Inspector, B&R
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L. Tofte, QA Training Coordinator, B&R
G. Mills, Chief Draftsman, Structural Group. B&R
A. F. Holbrook, Assistant QA Manager, B&R
R. Childers, Assistant to QA Coordinator, B&R
R. Kimball, Project Vendor Surveillance Coordinator, B&R
A. S. Goewey, NCR Supervisor, B&R
J. Purdy, QA Turnover Supervisor, B&R
D. Shumway, Day Shift Supervisor, QC Engineering, B&R
C. M. Singleton, Area Supervisor, QC Engineering, B&R
B. F. Mitchell, Qua?.ity Engineer, B&R
C. Mudd, Supervisor, Document Control, B&R
S. Horton, Site Internal Surveillance Supervisor, B&R
D. Whittaker, Automative System Specialist, B&R
W. Abrams, QA Specialist, B&R
R. Fountan, Lead Clerk, B&R
C. Chaplin, Site QA Manager, Pittsburgh Des Moines (PDM)
M. L. Self, Site Superintendent, PDM
R. Barker, Site Engineer, PDM
A. H. Ewton, Site Manager, Pittsburgh Testing Laboratory
2.
Review of QA Program and Inspection and Enforcement History
The IE inspectors performed a review of the QA manuals and docket files
of the licensee, architect engineer and constructors to include the
following:
inspections relative to QA r: grams and site; enforcement
correspondence and responses; audits; responsibilities of key personnel;
construction deficiency reports; organization; execution of the QA pro-
gram and continued development of the QA progran for the South Texas Project.
QA procedures for the control of activities within the Houston Lighting
and Power Company (HL&P) QA, Engineering, and Purchasing Organizations are
contained within the organization's respective QA manuals.
In the case of
HL&P delegated activities, the QA procedures for control of design, pro-
curement and construction are contained within the B&R and W QA manuals.
Major subcontractors (Pittsburgh Testing Laboratory and Pittsburgh Des
Moines Steel Company) have their own QA manuals which have been approved
by the licensee.
It was noted that the HL&P organization for project management, which
is described in the Project Quality Assurance Plan (PQAP), Revision 4,
dated July 20, 1979, differs from that shown in Chapter 17 of the South
Texas Project (STP) PSAR. The functions previously performed by
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,
several HL&P departments have been consolidated in the STP organization
under the direction of the Manager, STP who reports to the Vice President,
Power Plant Construction and Technical Services. The Manager, STP is
responsible for engineering, construction, startup, cost and schedule
activities and results of STP.
Changes have also been made in the licensee's Quality Assurance department.
The QA Manager now reports to the Vice President, Power Plant Construction
and Technical Services rather than to the Executive Vice President as stated
in the STP PSAR. The position of Projects QA Manager has been added and
has responsibility for planning, development, implementation, coordination,
and administration of the Quality Assurance program for power plant pro-
jects (including STP) during engineering, design, procurement and con-
struction activities. The Projects QA Manager reports to the QA Hanager.
The position of Supervising Engineer has been changed to Project QA
Supervisor with -continued responsibility for development, implementation,
coordination and administration of STP quality activities. The Project
QA Supervisor reports to the Projects QA Manager. The Supervisor, Site
QA, who is assigned to the site, is responsible for site quality assurance
surveillance of activities for STP during construction and startup opera-
tions. The Supervisor, Site QA, reports to the Project QA Supervisor.
The review findings indicate that HL&P has developed and is continuing to
upgrade the QA program consistent with the SAR commitments relative to
design, procurement, construction, enforcement response and reporting of
deficiencies. QA manuals and procedures are being revised to depict
organization changes and improvements to the overall program. The
licensee advised the IE inspectors that the PSAR was not revised to
depict changes as NRC licensing does not desire to review the changes.
3.
On-Site Review of QA Manual and QA Manual Implementation
a.
QA Manual Reviews (HL&P and B&R)
The HL&P QA manual, identified as the STP Quality Assurance Plan (PQAP),
J scribes the HL&P Quality Assurance plan.
It delineates the policies,
organizational responsibilities and methods used by HL&P to conform to
the eighteen " Quality Assurance Criteria" set forth in Title 10, Part 50,
Appendix B of the Code of Federal Regulations.
HL&P has provided their position descriptions for QA personnel, QA forms
and QA procedures in a bound volume and has identified it as the STP
Quality Assurance Manual. This manual details the requirements to meet
their commitments made in the PSAR.
B&R has provided a QA manual which specifies their QA program for design,
procurement and construction activities associated with STP. The B&R
QA manual and associated procedures for STP were reviewed and approved
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by the licensee to ensure that B&R's QA program meets the require-
ments of the HL&P QA program.
The B&R QA manual specifies that
STP is to be constructed in accordance with ASME,Section III, 1974
Edition, Division I with Winter 1975 Addenda. The licensee has also
committed to ASME,Section III, Division II.
The B&R QAM also
specifies that the requirements of 10 CFR 50, Appendix B will be
met and that the QA procedures will meet the QAM requirements.
Several sections of the B&R and HL&P QA manuals and procedures were
examined in detail to determine if the manuals and procedures were
being updated to correct programmatic deficiencies, changes in
QA/QC organizational structure, technical requirements and if the
changes were being reviewed and approved by the licensee. B&R manual
sections and QA procedures examined in detail were:
(1) Section 10, " Examination, Inspections and Tests" (revised 8/3/79)
(2) Section 9, "Special Processes" (revised 2/5/79)
(3) Section 1, " Organization" ,
(4) Section 2, " Training"
(5)
QAP-2.6, "Nonconformances" (revised 3/15/79)
(6)
QAP-2.7, "Stop Work Authority"
(7)
QAP-2.4, "QA Document Review" (revised 3/1/79)
(8)
QAP-2.3, " Document Administration"
(9)
QAP-5.4, " Structural Integrity Tests" (revised 2/24/79)
(10)
QAP-5.6, " Post Tensioning" (revised 2/24/79)
(11) Quality Assurance Training Manual
HL&P manuals examined in detail included:
(1) HL&P Project Engineering Procedures Manual No. PEP-01,
" Preparation and Control of Project Engineering Procedures"
(2) HL&P Project Quality Assurance Plan, Revision 6, dated 6/20/79
(Sections 1, 2, 3, 6 and 8)
Procedures are being revised to eliminate deficiencies and to
improve the effectiveness of program execution.
Comparison of
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B&R manuals in the corporate office and at the site confirmed that
the manuals are being maintained current with the latest revisions.
During discussions with B&R QA personnel, the IE inspector was
informed that the site organization chart shown in the manual had
not been updated to show the latest site QA structure. The basic
responsibilities of the B&R QA department have not changed, but the
Quality Control Engineering Groups have been assigned QC responsi-
bilities for certain areas of the plant instead of the previous
discipline assignments. QC Engineering personnel continue to report
to the QA department.
Examinations of the QAMs, procedures and documentation revealed that
the licensee and constructor have adequate QA programs and appear to
be implementing the specified programs.
No items of noncompliance or deviations were identified.
b.
QA Manual Document Control (HL&P)
The licensee's PQAP Manual is issued to define and control
activities at the licensee's corporate office and STP site.
The PQAP Manual delegates responsibilities for control of
contractor's QA manuals to the contractors. The licensee is
responsible for auditing the contractor's control of their QA
manuals.
PQAP Manual, Revision 6, dated June 20, 1979, describes the
methods used for preparing and controlling quality related acti-
vities.
Sections 3, 6 and 7 specifically address document control.
The Records Managemeat Division under the QA department is respon-
sible for maintaining copies of the STP records which include
drawings, copies of all in-house correspondence, B&R's design manual
and typical reference documents, audit reports, procurement documents,
specifications and correspondence between the licensee and major
vendors (B&R and W).
This Division does not issue and distribute
information but is mainly a filing operation; however, items can be
checked out for use by licensee personnel. The IE inspector was
advised that the licensee is developing a computer system for con-
trol of documents.
Responsibility for the development control and implementation of
the PQAP Manucl is assigned to the HL&P Corporate QA Manager.
Departmental procedures are prepared by each QA Division and are
compiled into a Quality Assurance Procedures (QAP) Manual. Res-
ponsibility for control of the PQAP and QAP Manuals has been assigned
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to the Support Division of the QA department.
Each manual is num-
bered and each holder of a manual is assigned a controlled manual
number.
The leader, Administrative Support Section (QA> keeps a
record of all manual holders, latest revision to sections, date of
issue and acknowledgement of receipt by the manual holder.
A
master folder is kept up to date and includes a lists of all
revisions to the PQAP and QAP Manuals.
The IE inspector selected two persons assigned unrelated QA/QC func-
tions and interviewed them concerning their responsibilities assoc-
iated with the control of the manuals and verified that procedures and
manuals necessary for their responsibilities were available.
The IE inspector selected five PQAP Manuals (No. 50, 51, 65, 84,
and 85) and four QA Manuals (No. 5, 10, 11, and 29) for examination.
The IE inspector visited the offices of the manual holders and con-
firmed that each individual had manuals assigned to him. The IE
inspector also reviewed the latest list of revisions to the proce-
dures and verified that the manuals had been updated to include the
latest revisions.
No items of noncompliance or deviations were identified.
c.
QA Manual - Document Control (B&R)
Brown & Root, Incorporated provides written trocedures for con-
trolling the preparation, review, approval and issuance for docu-
ments affecting quality. The QA Manager is responsible for the
control of these documents.
The IE inspector reviewed B&R Procedures QAP-2.3, " Document Admin-
istration," QAP-2.2, " Control of Project Program Documents," QAP-
6.1, " Project QA Records," and QAP-6.3, " Codification of Documents,"
to determine if these prccedures were adequate. The IE inspector
held discussions with responsible management personnel, examined
the files and observed the facilities provided for the control u r
manuals.
B&R uses a " Form Control" described in Procedure QAP-2.11 for
transmittal of revised procedures. All revisions to the QA/QC
manuals are prepared and issued by the Houston QA Department. The
Revision Record Sheet is prepared and summarizes the manual
page number, description of changes and revision date, plus in-
structions for entering into the manual. A cover letter is utilized
to transmit revisions to each manual holder and this cover letter
is signed by the receiver and returned to the QA Department.
If
the QA Department does not receive the acknowledgement receipt
within 30 days, the manual holder is sent a notice requesting
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that he check his manual for the revision and return the signed
acknowledgement. The QA Department also performs audits of the
manuals.
Controlled manuals No. 10, 15, 17 and 19 were examined to determine
if the latest revision to the manuals had been incorporated by the
manual holders. The IE inspector found that Manual No. 19 contained
a procedure (QAP-5.12) which had been deleted per the "Sitamary of
Revision" dated October 13, 1978. The IE inspector was informed by
the manual holder that he kept a complete set of procedures in his
manual for reference pucposes and had inadvertently forgotten to
stamp the procedure " void" as specified in the procedure. Although
the holder stamped the procedure " void" in the presence of the
IE inspector, the failure to keep the QA manual current as specified
in QAP-2.2 is a deficiency.
The IE inspector also observed that ST-QA-2.3, " Documentation Admin-
istration," paragraph 5.3.1 shows examples of stamps to be used on
documentation. The stamp imprint is not legible and should be cor-
rected.
ST-QAP-2.2, " Control of Project Program Document," paragraph
5.3 requires transmittal memorandum or record be returned. While
reviewing this area, the IE inspector noted that the procedures do not
clearly state the effective date of revised procedures.
The matters concerning illegible procedures and effective date of
revised procedures are considered unresolved.
d.
HL&P Audit of B&R's Control of Manuals
After reviewing the controlled manuals, the IE inspector requested
the latest audit of document control which was Audit No.~BR-26,
dated June 1-4, and 11-15, 1979. The audit identified a fin?img
concerning the control of B&R QA Training Manual No. 24. The
response to this audit finding addressed only the correction of
Manual No. 24. The corrective action did not include review of
other QA training manuals or similar manuals. Therefore, corrective
action was not taken by B&R QA to identify the cause of the condi-
tion nor was action taken to promptly identifiy similar conditions
adverse to quality.
The IE inspector reviewed this audit prior to HL&P review and
follow up.
HL&P informed the IE inspector at the exit interview
that not only was this answer inadequate but responses to several
other findings in the same report were inadequate. The IE inspector
stated that HL&P follow up was not questioned since they were in the
process of reviewing the responses.
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The matter concerning the inadequate B&R response to the audit
findings is considered unresolved.
e.
QA Manual - Document Control (Site)
The IE inspector examined B&R QA Manuals No. 20, 22, 37 and 46
assigned to site personnel to determine if the manuals were con-
trolled and if the latest revisions to Procedures No. QAP-2.6, 2.12,
5.1, 5.4, 5.5, 5.6 and 7.1 had been incorporated into the manuals.
Discussions with personnel revealed that they were knowledgeable of
the procedures for the control of documents and the review of their
manuals verified that the manual procedures were current.
No items of noncompliance or deviations were identified.
f.
Drawings --Document Control (B&R Corporate Office)
The IE inspector discussed the control of drawings, specifications
and design changes with B&R Corporate Office responsible personnel
(Project Quality Engineer and Lead Clerk) to determine their know-
ledge and implementation of the procedures. A physical examination
was performed of the Engineering Document Control Center where the
receipt, storage and distribution of drawings, specifications and
other QA documents are controlled. Access to the Engineering
Document Control Cencer is restricted to certain personnel and a
list of authorized personnel is posted.
The IE inspector selected thirteen current drawings from the
master index and performed an inspection of the records (micro-
films and original vellums) to verify that all of the drawings
were of the latest revision and if they were stored and filed per
procedure.
The IE inspector selected eight other drawings from the master
list and examined all QA documentation associated with the drawings,
from the original review and approval to the latest review,
approval and distribution. Records of comments made during design
review and resolutions of these comments were also reviewed by the
IE inspectar. B&R issues a drawing revision list each week and a
current revision list of all drawings and Design Change Notices
are issued r.very two months to personnel specified on the standard
distributioa list.
Procedures and other documents examined were as follows:
(1) Procedure STP-DC-002-1, " Engineering Procedure for Drawing
Control"
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(2) Procedure STP-DC-010, " Codification System"
(3) Procedure STP-DC-005-H, " Preparation and Control of Specifications"
(4) Procedure STP-DC-014,." Engineering Procedure for Review and
Comment"
(5) Procedure STP-DC-013, " Engineering Procedure for Document Change
Notice Control"
(6) Procedure STP-DC-015, " Design Verifications"
(7) Drawings associated with concrete, piping and electrical
activities:
(a)
11C1509
(b)
(c)
IC1540-6
(d)
IC1542-5
(c)
IC1544-8
(f)
(g)
(h)
(i)
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(j)
(k)
(1)
(m)
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(n)
IC1509-6
(o)
IC4193-1
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(8) Engineering Review, Design, Change Notices and comments on
the following drawings:
IC4213-A;
15-4082-0; 0-5-0014C;
1-C4026-0 and 1-C4031-1.
(9) Complete History Card No. 3C01-IC1509 which included a
history of everything done on this drawing from April 25,
1978, to July 23, 1979.
No items of noncompliance or deviations were identified.
g.
Drawings - Document Control (Site)
To verify that the site was controlling drawings, specifications
and design changes as required by the procedures (see above para-
graph), the IE inspector discussed the control of these items with
the Document Control Supervisor and the CRT Supervisor. A walk-
through inspection of the site document control center and dis-
cussions with other personnel confirmed that documentation was
controlled, drawings and specifications were readily retrievable,
access to the area was restricted and personnel were knowledgeable
of their responsibilities.
To verify that the site had the latest revisions of drawings and
that they were distributed to required personnel, the IE inspector
requested that the site check the latest revisions to eleven draw-
ings previously selected by the IE inspector from the corporate
master list. Five concrete drawings, four piping drawings and two
electrical drawings were checked against the revisions reviewed at
the corporate office (see above paragraph) and they agreed.
No items of noncompliance or deviations were identified.
h.
HL&P Procurement Document Control
The STP QA Supervisor and the Manager of Project Purchasing were
interviewed to review the substance of QA manual provisions
relating to assigned procurement activities and determine the
location of HL&P storage facilities for procurement documents
and evaluate the adequacy / control of documents.
The IE inspector reviewed procurement documents for material or
,
ccmponents for installation activities relating to major site
contractor;. Westinghouse Electric Corporation Purchase Order
(PO) 8141 for electric penetrations; Southwest Fabrication P.O.
6014 for AShE Section III Piping 2 " and larger; Analog Control
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P.O. 4105 for instrumentation and controls I & C, (change order);
and Hayward Tyler Pump Co. P.O. 4122 (change order) for ASME III
Class 3 pumps were reviewed to assure that purchase orders contained
the scope of work, technical requirements, QA requirements, right of
access and documentation requirements.
No items of noncompliance or deviations were identified.
i.
Design Control
The Houston Lighting & Power Company Quality Assurance Manual (QAM)
implementation was reviewed with specific attention to those sections
of Criterion III which require that the design control measures pro-
vide for checking the adequacy of design by the performance of
design reviews and for subjecting design changes, including field
changes, to design control measures commensurate with those applied
to the original design. .The program established by HL&P is docu-
mented by written policies, procedures and instructions contained
or referenced in the QAM,in departmental procedures and in the
STP PQAP.
Project Engineering Procedure PEP-05, Revision 0, " Performance
of Design Reviews," was reviewed for conformance with Section
4.3 of the QAM. This section entitled, " Review of Design by
HL&P," delegates to the HL&P engineering groups the responsi-
bility for performing technical reviews of design documents
developed by the Architect / Engineer (A/E).
The procedure was also reviewed for conformance to Section
4.4 of the PQAP. This section describes the process for the
design review performed by HL&P.
Implementation of Procedure
PEP-05 was verified during this inspection by discussions with
the Lead Project Engineer-Civil who was in the process of gen-
erating a Document Review Sheet for a ravision to B&R Procedure
STP-PM0-21, " Procedure for Field Request for Engineering Action."
The Document Review Sheet generated by the Lead Project Engineer-
Inalrumentation and Control for th same document was also
reviewed.
Requests originating from the STP site to change, deviate from, or
clarify design drawings and specifications are controlled through
a system called Field Requests for Engineering Action (FREA), which
provides for review and approval of field changes by the Engineering
Department through control of the FREA form.
B&R Procedure
STP-PM0-21, " Procedure for FREA," Revision 7 provides the require-
ments for the origination, coordination, review, disposition,
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distribution and control of the FREA. Brown & Root Procedure
No. STP-DC-023, " Engineering Procedure for FREA," Revision H
provides direction for the engineering activities involved in
processing the FREA.
Implementation of the FREA system was confirmed by reviewing the
field request for modifying the height of concrete placement number
7 for the Unit 2 Reactor Containment Building (RCB).
The Engineering
Department was in the process of reviewing the site orginated request
to make the location of the eight inch channel liner plate stiffener
coincide with the top of all subsequent concrete placements so that
the probability of void formation beneath the channel, such as that
which occurred in Unit 1, will be reduced.
No items of noncompliance or deviations were identified.
j.
Brown & Root Vendor Surveillance
The IE inspector interviewed the B&R Project Vendor Surveillance
Coordinator. The vendor surveillance program is broken into five
regions across the United States.
The IE inspector reviewed the
following:
(1) B&R Vendor Surveillance Schedule Job No. CR-0421
for April,
May and June 1979.
(2) Surveillances performed in Regions 1, II, III, IV and V during
July 1979.
(3) Vendor Surveillance Reports:
Report
Manufacturer
Item
K085-92
Kerotest
ANSI B31.1. Valv
,
CO-95-006
Capital Pipe & Steel
P365-51
Prescon
Tendons
W 12050
1000 & 1200 KVA
transformers
P097-189
PDM Des Moines
NR Structural Steel
No items of noncompliance or deviations were identified.
k.
Licensee Audits of QA Program Elements
The IE inspector reviewed selected reports of licensee audits
performed to varify implementation of QA program elements related
to design control, procurement, document control, material
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receiving, construction and QA records. The audit records were
examined to determine if audited organizations received copies
of the audit reports; to determine if appropriate standards
were used for measuring performance; to ascertain if auditors
were selected in accordance with QA manual provisions; to review
corrective actions; and to review identification of substantive
design or hardware deficiencies. The following audit reports were
reviewed:
BR-7, audit of B&R Document Control Center and Engineering,
performed January 29-31, 1975
BR-9, audit of B&R QA program implementation, performed
March 15-18, 1976
BR-14, audit of B&R personnel qualifications, records,
document control, receiving inspection and storage, performed
October 26-28, 1976
BR-21, Audit of B&R Purchasing, performed August 22-23, 1978
BR-22, audit of B&R Civil Design, performed November 13-17,
1978
BR-26, audit of B&R QA program implementation, perfo med
June 4-6 and 11-13, 1979
R-27, audit of B&R welding program, performed June 11-12,
1979
HL-7, audit of HL&P Purchasing Department, performed April 18,
1978
HL-60, audit of HL&P Construction Department, performed
February 19-20, 1979
HL-67, audit of HL&P Records Management Division, performed
June 13-14, 1979
The IE inspector observed that the checklist for audit BR-7 was not
completed and that the file for audit BR-9 did not contain a check-
list. The IE inspector noted that failure to m
listshadpreviouslybeenidentifiedbytheNRCgyntainauditcheck-
and the licensee
response indicated that corrective action ha> been implemented
'.o
assure that audit checklists are maintained.
1/IE Inspection Report 50-498/77-12; 50-499/77-07, dated December 9, 1977
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During review of audit HL-60, the IE inspector noted that numerous
(13) items on two audit checklists in the file were incomplete. During
discussions with licensee representatives, it was pointed out that one
of the checklists was used ac a " feeder" to the other (record) copy;
however, it was observed that one item on the record copy was not
checked " sat", "unsat" or "N/A".
It was noted that the licensee's audit reports summarize areas
covered during audits and that only deficient areas are described
in detail in Audit Deficiency Reports issued with the reports. The
complete audit scope cannot be determined without referring to the
audit checklists. The presence of the incomplete audit checklists in
the HL-60 file was contrary to the licensee's response to previous inspec-
tion findings and to paragraph 7.2.4 of HL&P QA Department Procedure
QAP-5B which requires that completed audit checklists shall be
maintained in the QA audit files.
This is an item of noncompliance
with the requirements of 10 CFR Part 50, Appendix B, Criterion XVII,
in that a QA audit file was not properly maintained.
The IE inspector also observed that certification records of one
HL&P employee who participated in audits HL-7 and BR-21 and another
employee who participated in audit BR-14 could not be found in the
QA auditor qualification file.
Discussions with licensee represen-
tatives revealed that supporting documents, includirg completed
examinations, were on file but the actual certifications of the
two individuals had apparently been removed from the auditor
qualification file.
This matter is considered unresolved pending completion of a records
review for the missing documents by the licensee and subsequent
review by IE.
1.
Pittsburgh Testing Laboratory QA Manual Implementation
The HL&P Quality A surance program requirement for the establishment
of a test program to meet the requirements of Criterion XI of Appendix
B to 10 CFR 50 was reviewed with respect to concrete testing services.
The Pittsburgh Testing Laboratory (PTL) QA manual for inspection and
testing services was reviewed for conformance to Section 4. " Inspection
of Concrete Construction," of ANSI N45.2.5-1974, " Supplementary
Quality Assurance Requirements for Installation, Inspection and
Testing of Structural Concrete and Structural Steel During the
Construction Phase of Nuclear Power Plants."
Implementation of PTL Procedure QA-1A, " Internal Audits," was reviewed.
Specific attention was given to the site initiated corrective action
response required for all audit report findings and observations.
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The following records were specifically reviewed:
(1) PTL Corporate QA Audit Summary Reports of PTL Site Laboratory
Operations No. I through 8, covering the period from May 11,
1976, to March 12, 1979
(2) STP PTL A dit Reports No. I through 8 Responses
(3) PTL Corporate Close-out Reports
Brown & Root corporate audits of PTL were also reviewed. These
audits were nerformed in accordance with B&R Procedure ST-QAP-7.1,
" Houston QA Audits," Revised February 24, 1979.
B&R QA Audit Reports
No. P262-1, -2, -5, -6, and -7 were reviewed. Audit Reports No.
P262-3 and -4 were not located in the site QA vault as required Ly
B&R Procedures ST-QAP-7.1 and ST-QAP-2.3, " Document Admi.nistration,"
revised August 28, 1978.
Discussions with the HL&P site QA
Supervisor indic_ted that this deficiency had been identified in
HL&P audit of B&R Report No. 26 as Audit Deficiency Report (ADR)
No. BR-26-D-01.
The IE inspector was informed that the audit reports
were located at the B&R QA home office facilities but were to be
routed to the STP site QA vault for filing and retention in response
to the HL&P audit.
Intlusion of the audit repo s in the vault is considered an
unresolved item to be reviewed at a later date.
PTL Procedure No. QC-CRN, " Control & Reporting of Nonconformances,"
Revision 3 was reviewed for conformance to the PTL QA program and
for implementation.
PTL internal noncomformance reports No. 82, 83,
84, 85 and 86 were reviewed with specific attention made to the
requirement for reinspection and verification of all nonconformances.
In addition, the log of all nonconformance reports was also reviewed.
The training and indoctrination requirements of ANSI N45.2.6, " Qual-
ifications of Inspection, Examination, and Testing Personnel for
the Construction Phase of Nuclear Power Plants," were appli d to
the personnel record of one randomly selected Level II concrete
field inspecter. The file indicated conformance to the requirements
of the ANSI standard.
No items of noncompliance or deviations were identified.
m.
Pittsburgh Des Moines (PDM) QA Manual Implementation
(1) QA/QC Organization
The IE inspector interviewed the site QA Manager to determine
whether individuals were assigned to QA manual identified
positions relative to the following:
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(a) Continued development of QA/QC procedures and
instructions
(b) Inspection
(c) Audits
(d) Management of the site related program implementation
The IE inspector found that procedures are controlled by the
organization located off site and audits are performed by the
same group. PDM has on-site inspectors and a QA Manager. The
PDM QA Manager was selected for the position in the last three
weeks. He was formerly a lead inspector.
When the interview
was conducted, he appeared to be performing the responsibilities
of lead inspector and QA Manager. He stated that his workload
was declining and felt he would be able to perform both functions.
This individual was also interviewed to determine if, while as
an inspector and QA Manager, he had and now has the authority
and organizational freedom to identify nonconformances and seek
resolution from appropriate levels of management. He stated
that as an inspector and QA Manager he had received adequate
support from QA personnel and QA Managers.
It was also stated
that he had not been nubjected to threats or undue pressure
from anyone which would have influenced the performance of
his duties.
The IE inspector determined that recent organizational changes
had been made; however, such changes were neither described in
the QA manual nor shown on organizational charts. A new posi-
tion was created between the Division QA Manager and the Site
QA Manager.
The finding regarding the QA position not being described
represents a noncompliance with 10 CFR 50, Appendix B, Criterion
I and HL&P QA manual, Section 2.
The IE inspector reviewed the control and development of QA/QC
procedures and instructions and found the following:
(a) PDM QA manual document Control meast:es. Section 12,
" Manual Revisioa and Distribution," did not describe how
supplements would be integrated into the manual after
receipt. Also there is an apparent conflict between the
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supplements as used now and revision instructions
described in Section 12.0 of the manual.
(i.e., supple-
ments which changed paragraphs were not annotated in the
margin as required by the procedure.) ANSI N45.2, para-
graph 2 states in part, " Participating organizations shall
have procedures for control of the documents and changes
thereto to preclude the possibility of use of outdated or
inappropriate documents."
Section 13, " audits," was another example supporting the
NRC finding that the PDM manual dees not fully incorporate
the provisions of ANSI N45.2.
PDM Procedure No. 13 does
not state lead auditor and auditor qualifications require-
ments nor does it decribe how they are qualified. The
basis of audit frequency was not described, that is, prior
to and immediately af ter award of contracts, after signi-
ficant changes in functional areas of quality assurance
or when the safety performance or reliability of items are
suspected. This same procedure was found to contain a
reference to audit report forn 17949CR which had been
superseded by 17949DR listed in Section 15, " Sample Forms,"
Revision 3, dated November 19, 1976.
Four QA Manuals (No. 67, 132, 150 and 177) were reviewed
to determine if manuals contained current revisions and
to determine if procedures were properly distributed. The
following discrepancies were noted:
Manual 150 did not contain Ecctica CP-1, " Calibration
Procedures." hanual 177 did not contain Section CP-1
and Section IT-1, " Indoctrination and Training Pro-
cedures."
Manuals 67, 132, 150 and 177 did not contain the same
supplements (documents pertaining only to South Texas
Project). That is manuals 67 and 150 lacked Supple-
ment 210; manual 132 lacked Supplement 211; manual
177 contained no supplements.
The indoctrination and training procedure which had
been superseded by a new procedure was in the manual;
however, the old procedure was not marked " void"
" superseded" or "for information only."
Manual 67 contained a policy memorandum which imposed
additional requirements; however, the QA manual Section
12.0 does not authorize the manual to be revised or
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supplemented by memorandum. One such memorandum,
" Audit Response Cycle Policy," dated September 28,
1978, stated that Audit Deficiency Reports will be
resolved within 20 days of receipt.
These are typical examples of lack of document control.
The IE inspectors identified other examples which were
similar to those described above.
-
PDM QA manual, Section 12.0 states in part, "This manual
shall be reviewed semiannually or more frequently by the
QA Committee .
The intent of this review shall be
. . .
to keep the manual current with Code addenda and with
PDM construction and quality assurance procedures .
...
Revisions to the manual shall be highlighted by revision
numbers in the margin."
The IE inspector's findings showed that the manual was
not current nor adequately controlled.
This finding represents a noncompliance rith 10 CFR 50,
Appendix B, Criterion V.
(3) Control of PDM Site Originated Procurements
The IE inspector selected, for review, two site originated
purchase requisitions for weld materials and structural steel.
The procurement documents were located offsite at the various
plants or corporate QA records centers. Therefore, the IE
inspector reviewed Field Receiving Reports (Form 18047) No. 101
(8 dome plates) and 108 (dome plate stiffeners) and structural
steel purchased under contract No. 15680; FRR No. 51 (E 6010
and E 7028, 3/16 welding rod) under contract No. 15679 for
certification that:
(a) Specification of standards was proper.
(b) Material physical and chemical certifications met
requirements.
(c) Receipt inspection / testing was performed.
No items of noncompliance or deviations were identified.
(4) PDM Audits of PDM Site Activities
The following audit reports were revicved.
The IE inspector's
findings are described under " Comments" applicable to the
respective audits.
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' Audit Report
Comments Describing IE
No.
Date
Location
Inspector's Findings76-208 and
9/15/76
Site
Review of audit records76-212
and
indicated that the following
11/11/76
Sections of the QA manual
were not audited in 1976:
Section
Description
1.0
Design Control
7.0
Control of Measuring
,
and Test Equipment
8.0
Heat Treatment
9.0
Storage and H..ndling
10.0
Examinatior, and
Testing
11.0
Indoctrination and
Training
12.0
Manual Revision /
Distribution
13.0
Audits
14.0
Documentation
Corrective action
complete, signature
and date missing
77-201
1/2/77
Site
Section 12.0 " Manual Revision
and
and Distribution," found ac-
1/7/77
ceptable by PPM, yet NRC find-
ings show the manual in need
of revision.77-201
1/3/77
Site
Section 1.0, " Design," (con-
trol of design documents, pro-
.
cedures, specifications)
Section 8.0, " Heat Treatment,"
and Section 14.0, "Documenta-
tion," were not audited in
CY 1977. Note: Documentation
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and Heat Treatment were not
audited for two years and
additionally, no record justifying
why the Sections were not
audited.77-208
9/27 - Des
Tais audit identified document
30/77
Moines
control problems in audit De-
ficiency Reports No. 12 and 13,
yet site follow up was not
apparent.
Corrective action
signature blank, lead auditor
not identified and report not
signed.77-202
2/1-2/78 Site
Section 12.0 audit by PDM found
acceptable, yet NRC found areas
need correction. Lead auditor
not identified. Corrective
action signature blank.78-210
6/5-8/79 Des Moines Corrective action signature
blank
79-203
3/28 -
Site
Lead auditor not identified.
29/77
Corrective action signature
blank. PDM audit of Section
12.0 acceptable while NRC
findings showed correction
teeded.
The IE inspector reviewed the above audit results for trends and
found the following discrepancies:
Section 2.0 (2.1, " Drawing, Preparation and Issuance", 2.2,
" Drawing Distribution") was identified in each PDM audit as
(c), corrections required, however, the areas remained
deficient from September 15, 1976, until March 27, 1979.
Corrective action was not adequate.
Section 12.0 was repeatedly audited, yet the IE inspector
found that follow up to assure correction of document control
deficiencies on site was not adequate.
Additionally, the IE inspector found that only negative audit findings
were documented.
When audit results are so documented, it is impos-
sible for the reviewer to determine on what basis acceptable findings
are made. That is, if Section 12.0 were audited at the site, did the
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auditor look at one manual or all manuals? Did the auditor
check each Section for current revisions or only one Section?
Specifically, the audit findings were not supported by reference
to the areas audited.
PDM QA Manual Section 13.0, " Audits," states in part, "The
Corporate Chief Engineer and Division Chief Engineer shall
initiate annual, or more frequent, audits of each field con-
struction site. The purpose of these audits shall be to
determine the effectiveness of the QA program . .
The
..
Division Chief Engineer shall bring deficiencies and recommend
corrective action to the attention of the respective department
managers for their action. Audit results shall be reviewed
by responsible management to determine the required corrective
action . . .
The Division QA Manager shall initiate reaudits
.
as required to assure correction of deficiencies."
Based on the findings described above, follow-up actions were not
taken to assure that deficiencies were corrected.
In one case,
recurring deficiencies were identified in 1977, yet the de-
ficiencies have not been corrected to date (8/16/79). Documented
audit results did not reference what was reviewed /obser ed when
areas were found acceptable. The audit report did not identify
lead auditors and the procedure did not state auditor qualifi-
cations requirements. The QA program was not totally audited
in 1976. Management had not signed off the corrective action
statement on the audit report form dating back to 1976.
These findings represent a noncompliance with 10 CFR 50,
Appendix B, Criterion V.
(5) PDM Inspection Personnel Qualification
The IE inspector reviewed three PDM inspector's files to deiermine
if welding and NDE inspectors were qualified. Of the three files
reviewed, one inspector's qualifications was considered inadequate.
The PDM QA manual, Section 1.0, paragraph 10.3.1 states in part,
" Level I, II, and III NDE personnel shall be certified in
accordance with PDM Written Practice QAS I, II or III which meets
the requirement of the Code." The PDM Written Practice QAS II
requirements are basic education plus nine months of experience.
The licensee's representative interpreted nine months laboratory
crperience as work experience. The IE inspector did not concur
with this interpretation.
The IE inspector consulted NRC management and NDE specialist who
concurred that the individual did not initially meet Level II
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requirements in that the first nine months he worked he was not
qualified. However, he would be qualified subsequent to
working in this area for nine months. Work performed during
the first nine months should be reviewed by the licensee to
assure that radiographs were correctly dispositioned.
Additionally, the PDM QA manual does not state minimum inspector
qualifications. The licensee representative informed the IE
inspector that the licensee had committed to ANSI N45.6.
The above matters are considered unresolved pending additional
inspection in these areas.
(6) PDM Construction Personnel
(a) PDM Site Superintendent
The site superintendent was interviewed to determine how
welders are qualified; determine the number of personnel
supervised and cooperation of crafts and QA/QC personnel.
The IE inspector found that the superintendent and site
QA Manager are located in adjacent offices for ease of
interface between these two groups. The foreman stated
that relations between the two groups were good. He stated
that some welders who were net qualified in each position
had welded in positions which they had not been qualified.
This happened at the beginning of work at STP. The
NRC, licensee and constructor identified this problem and
corrected it early in the project.
Welder qualification records were reviewed for the following
welders: Weld Symbol 104, 112, 120, 150, 156, 168, 176, 192,
194, 195, 197 and 199. The IE inspector was unable to view
radiographs because they were sent off site to record storage.
No items of noncompliance or deviations were identified.
n.
Bowen Industries, Inc. QA Manual
The IE inspector reviewed the Bowen Industries, Inc. (Bowen) QA manual
for adequacy and implementation of program requirements. The IE inspec-
tor was informed that Bowen's (the contractor for heating, ventilating
and air conditioning (HVAC) systems installation) QA man"s was
accepted for site use, but work has not commenced on safety-related
HVAC systems. The IE inspector observed that implementing procedures
related to the Bowen QA manual have not been issued and were not
available for review.
24
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. . During the review, the IE inspector observed that the manual stated that nondestructive testing procedures shall be prepared and approved by a " Level II Examiner" and the QA Manager. Discussions with licensee representative failed to resolve the IE inspector's questions concerning approval of the procedures by a Level III person. In the absence of Bowen representatives, it could not be determined if the " Level II Examiner" was a typographical error or if the QA Manager was a Level III person authorized to apprave the procedures. This matter is considered unresolved and will be reviewed during a subsequent IE inspection. 4. QA/QC Organization (B&R) Brown & Root, Incorporated the constructor of South Texas Plant was inspected to determine if individuals had been assigned to the QA manual identified QA/QC positions. Review of the B&R QAM and discussions with personnel revealed the following: a. Br.R QA Procedures No. ST-QAP-1.0 and 1.1, dated March 1, 1979, define the B&R QA organization. b. The B&R corporate office develops the basic QA requirements (QA manual) and the site QA group develops the site procedures and instructions. c. Inspection activities at the site are controlled and implemented by the Project QA Manager, Site QA Manager and the Quality Control Engineering Supervisor. Area engineering supervisors have a staff of quality engineers who actually perform QA/QC activities. A QA Specialist, Document Control Supervisor and an Administrative Super- visor and staffs are responsible for other QA/QC activities such as preparing procedures, reviewing drawings, control of documentation and administrative duties. d. Audits are performed on the site activities by the Corporate QA staff, responsible to the Corporate QA Manager. Surveillance activities are performed by site QA/QC personnel. Audits and surveillances are performed according to procedures. e. Overall management of the site related QA program implementation is performed by the Project QA Manager. f. The B&R Site QA Manager is responsible for surveillance of activities performed by other subcontractors Os specified in Procedures No. ST-QAP-5.5, 5.4 and 5.3. No items of noncompliances or deviations were identified. 25 on"
. . 5. Control of Site installation The IE inspector selected the Reactor Containment Building structure and examined records and documentation associated with the placement of con- crete and reinforcing steel. These operations are controlled by Procedures No. 5.4, 5.5, 4.6, 2.6, CCP-3 and CCP-4. The following records of concrete placement were examined and all QA/QC records were properiy signed. a. Pour No. MEl-W251-02 b. Pour No. MEl-W928-1 c. Pour No. MEl-W217-13 Discussions were held with responcible B&R and HL&P personnel regarding the activities associated with construction inspection and documentatioa of the containment building. No items of noncompliance or deviations were identified. 6. Audits and Surveillances of Construction Activities The IE inspector examined several audit and surveillance reports applicable to construction activities. Some of the audits and surveillances were conducted both by HL&P and B&R corporate office and site person..el. The IE inspector also reviewed training end qualification records c. four B&R QA/QC personnel. Discussions were held with the B&R Training t aordinator and QA/QC personnel of HL&P and B&R. . Audits and surveillance reports examined were as follows: ST-23, Hoisting, Rigging and Champion (supplier) a. b. ST-22, Geotach and Vibroflotation c. ST-14, Concrete Construction d. ST-13, Cadwelding and Reinforcing Steel e. BR-24, HL&P Audit of B&R', Vendor Surveillance Group f. BR-19, HL&P Audit of B&R's Corporate Office and Site g. BR-22, HL&P Evaluation of Civil Engineering QA Program h. Site Internal Surveillance (SIS)-17, " Field Fabrication of Steel" 26 g an*
, . i. SIS-3, Documentation Administration, Turnover j. SIS-5, Surveillance of Calibration Facility k. B&R's Surveillance Reports of Pittsburgh Testing Laboratory's Site Work, dated January 15, 1979, and February 1, 1979 1. Site Internal Surveillance Log Book m. Status Report of Site Internal Surveillance issued on Augurt 2, 1979 The IE inspector also reviewed corrective action reports for several of the above audits and surveillances. During discussions with personnel, the IE inspector was informed that the audited organization had ten days in which to answer adverse findings; however, if responses are not received in ten days they usually receive a formal letter requesting extension of time. 'he audit group evaluates the response and if answers are not adequate, they are not accepted. The IE inspector reviewed the response to corrective actions relative to surveillance No. SIS-17, " Requirement for Field Fab- rication of Steel to ASW D1.1." The IE inspector noted that the audit report folders, at the site, did not contain complete information on the audit as required by ST-QAP-2.3. The audit reports examined did not contain approved checklists, therefore, the IE inspector could not determine if the audits were adequate. The folders only contained a summary, deficiency report, pre-audit meeting and post audit meeting. The licensee explained that the entire audit report and checklists were kept at the corporate office and that the site only retained the referenced documents. The IE inspector informed the licensee that Procedure ST-QAP-2.3 states that "only referenced documents will be kept at the home office and that all QA and NS records originating within the home office shall be routed to the site for filing." Contrary to Procedure ST-QAP-2.3, the site audit records did not contain an approved audit checklist; therefore, the IE inspector could not confirm whether the audits were performed in accordance with written instructions or an approved checklist. This is an unresolved item and will be examined during subsequent inspections. 7. Review of QA/QC Program The IE inspectors held discussions with several licensee and contractor personnel to determine the following: a. Adequacy of training on new or revised procedures b. Knowledge of their position responsibilities and procedures c. Access to management and feedbac'- from management concerning resolution of problems nn" 27
. . d. QA orientation and training for new employees Identification of nonconformances and methods for resolution e. f. Ability to perform their job functions and stop work authority g. Morale of QA/QC Personnel h. Adequacy of document control measures i. Adequacy of support of QC personnel by QA j. Ability of construction personnel to identify and correct problems k. Staffing of QA/QC positions 1. Working relationship with other licensee and contractor groups If they contact other licensee about problems they encounter m. and discuss solutions to generic type problems which may be present at the South Texas Project Results of these interviews revealed the following: site personnel have access to high management; feedback from management appears satisfactory; personnel appeared to be knowledgeable of their discipline and responsibilities; orientation of new employees on QA requirements and importance of QA/QC activities is minimal; most people are indoc- trinated by production; staff meetings are held every week and the QC supervisor attends dailv meetings with construction supervisors; staffing of positions is a ntinual problem as the site is isolated; the licensee and contracto are trying to increase staffing of the mechanical QC group and presently have fourteen new QC personnel and have eight more reporting soon; the overall working relationship between QA/QC and construction has improved over the past four months; inspectors identify nonconformances and deficiencies when they find them and most of the findings are corrected; the licensee and constructor have been evalua- ting the problems associated with voids in concrete and they believe that they have a solution to the problem; they don't frequently contact other licensees to discuss problems they have encountered with construction, vendors and installation of equipment. No new concerns were identified during these discussions; however, a licensee representative reported recent alleged incidents of intimidation of two Brown & Root QC inspectors by Brown & Root constructiun personnel. It was alleged that the construction personnel threatened the QC inspectors 28 }}}9 "*
.. and used abusive and vile language during conversations with the inspectors during the performance of their inspection duties. The IE inspector reviewed the results of licensee and Brown & Root investigations into this matter but did not discuv. the allegation with the individuals involved. The allegations wil? be the subject of a detailed investigation which will be addressed in a ssparate IE investigation report. 8. Nonconformances Criterion XV of Appendix B to 10 CFR 50 requires that measures be established to control equipment, material, services, or activities which do not conform to requirements. HL&P QAM implementation of this requirement was reviewed during this inspection. B&R Quality Assurance Procedure ST-QAP-2.6, "Nonconformances," Revised March 15, 1979, and Engineering Procedure STP-DC-022, " Engineering Procedure for Processing Nonconformance Reports," Revision D were reviewed for conformance with 1[L&P QAM and PQAP requirements. The procedures establish a system for documenting the identification, description, disposition, approval, verification and close out of nonconformances, and for providing direction for the engineering activities involved in reviewing, pro- cessing, controlling and dispositioning of nonconformance reports (NCRs) originating on site. Discussions with the site Quality Assurance Manager indicated that NCRs are being analyzed for quality trends by a site NCR Supervisor and sub- sequently transmitted to the Quality Assurance Management Review Board for review as required by Section 17.1.15B of the STP Preliminary Safety Analysis Report. NCRs originated at the home office and at vendor shops are summarized and included in the Monthly Activity Report which is also transmitted to the Review Board. Monthly Activity Report No. 44 was reviewed during this inspection. Implementation of the NCR system was evaluated by reviewing NCR No. S-C2706 which deals with the void investigation for the Unit 1 RCB. The trend analysis program NCR Report No. 3 was also reviewed during this inspection. No items of noncompliance or deviations were identified. 9. Equipment Storage and Maintenance Implementation of Criterion XIII of Appendix B to 10 CFR 50 by B&R for measures to control the storage of equipment in accordance with vork and inspection instructions was reviewed. B&R Quality Construction Procedure No. A040KPGCP-35, " Storage and Maintenance," Revision 0, 29 ' 1319 '"~
. .. Section 3.6 requires an Equipment Storage and Maintenance Instruction (ESMI) card for safety related equipment. The ESMI for the High Head Safety Injection Pump No. 3 was reviewed. It was determined that th ESMI card equipment number being used for the pump was actually the equipment number for the pump motor. Discussions with the HL&P Lead QA Engineer-Mechanical indicated that this discrepant condition had been identified by HL&P and documented in Site Discrepancy Memo (SDM) M-051. This memo addresses the Containment Spray Pump Motor ESMI card as listing the equipment number for the pump instead of the motor. HL&P has required a new plan of B&R to provide for total and accurate implementation of the requirements in the B&R Storage and Maintenance Procedure. As a result of this required action on the part of B&R, the ESMI numbering system will be revised at a later date. Implementation of the revisions to the ESMI system is considered an unresolved item to be reviewed at a later date. 10. Cadwelding Activities The IE inspector reviewed Cadweld inspection records and the status of the ongoing Cadweld records review initiated as a result of the licensee's speed letter C-046 which requested that Brown & Root undertake a thorough review of all Cadweld records. The IE inspector was informed that the Cadweld records review was approximately 50% complete as of August 8, 1979. A Brown & Root representative estimated that completion of the review will require approximately six additional months of effort. The IE inspector observed that Cadweld inspection results were recorded in Cadweld Inspection Books as required by Procedure CCP-11, " Reinforcing Steel Mechanical Splicing (Cadwelds)," Revision 9. The Acting Lead Cadweld QC Inspector stated that most inspection results are entered directly in inspection books which are taken into the field by QC inspectors or, if direct entry is not possible and field notes are used, inspection results are entered into the inspection books by the responsible inspector. A licensee representative stated that Cadwelder helpers are no longer used and all Cadwelding steps are performed by qualified splicers. The licensee representative also stated that appropriate protection is provided if Cadwelding is performed during wet weather conditions. Cadwelding work activities were not observed by the IE inspector during this inspection. During review of Cadweld QC Inspector Certification records, the IE inspector observed that one individual was certified as a " Structural Metallic daterial Technician (SM) L II," (Limited to Cadweld Inspection), 30 1319 ^-""
. ., but the IE inspector was una le to determine f:nm records in the file _ how the individual met the experience requirements for Level II stated in the Brown & Root training muaual. The Brown & Root Corporate Level III individual who signed Cadweld inspector's certification record was not availabic for interview. This matter is considered unresuived pending clarification of the indivi- dual's experience record and review by IE during a .ubsequent inspection. 11. Site Drafting Activities The IE inspector reviewed site dra. 9tivities with the Brown & s Root Chief Draftsman, Structural Groo,. he group is currently engaged in producing drawings for cable tray and structural components fabri- cated on site. Drawings completed by the group are approved on site and sent to the Brown & Root Houston office for verification. The group consists of elevet individuals, two of which are engineering students in training status. The remainder of the individuals have three or more years of drafting experience. No items of noncompliance or deviations were identified. 12. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. Nine unresolved items disclosed during the inspection are discussed in paragraphs 3.c, 3.d, 3.k, 3.1, 3.m, 3.n, 6, 9 and 10. 13. Exit Interview The IE inrpectors met with licensee representatives (denotel in paragraph 1) at the conclusion of the inspection on August 10, 1979. The IE Inspector summarized the purpose and the scope of the inspection and the findings. A licensee representative acknowledged the statements of the IE inspectors concerning the unresolved items. 1 3 1 9 .^'o ' 31 P }}