ML19256A081
| ML19256A081 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 09/22/1978 |
| From: | Crossman W, Randy Hall, Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19256A077 | List: |
| References | |
| 50-466-78-02, 50-466-78-2, NUDOCS 7811030040 | |
| Download: ML19256A081 (15) | |
See also: IR 05000466/1978002
Text
.
U. S. NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
REVION IV
Report No. 50-466/78-02
Docket No. 50-466
Category Al
Licensee: Houston Lighting a"
ver Company
Post Office Box 17
Houston, Texas
' , . ~ ' ' . ,
Facility Name: Allens Creek Nuclear Generating Station, Unit No.1
Inspection at: Houston, Texas
Inspection conducted: August 16 and August 29 - September 1,1978
Inspeetors G/, W9/,im 8.,
'7 /l2/ /7Vs'
W. G. Hubacek, Reactor Inspector, Projects Section
Date
(Paragraphs 1, 2, 3, 8 & 9)
7k/?r
g . I. Tapia, Reactor Inspector-Intern, Engineering
06te
'/
Support Section (Paragraphs 4, 5 & 6)
=v_ x
-
9/Z/f78
W. A. Crossman, Chief, Projects Section
Date
(Paragraph 7)
Approved:
F /!78
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W. A. Crossman, Chief, Projects Section
Date
f /f77
R. E. Hall, Chief, Engineering Support Section
Date
ggi?_03 0
Inspection Summary:
Inspection on August 16 and August 29 - September 1,1978 (Report No.
50-466/78-02)
Areas Inspected:
Special, announced inspection of implementation of the QA
program for design, procurement and construction.
The inspection involved
one-hundred eight inspector-hours by three NRC inspectors.
Results:
Five deviations from commitments were identified in the three
areas inspected (failure to provide an approved procedure for processing
field procurement contracts, paragraph 2; failure to prescribe vendor
surveillance report format, paragraph 2; failure to provide training re-
quirements in departmental procedures, paragraph 4; failure to provide
approved procedures for design review, paragraph 7; failure to provide
procedures for control of the Design Review Worksheet, paragraph 7).
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DETAILS
1.
Persons Contacted
Principal Licensee Employees
- R. A. Frazar, QA Manager
- F. W. Stoerkel, Project QA Supervisor
- W. N. Phillips, Projects QA Manager
- C. A. McClure, Supervisor, Support Division, QA
- T. K. Logan, Site QA Supervisor
- P. A. Horn, Project Manager, Allens Creek, Power Plant Engineering
and Construction (PPE&C)
R. E. Fulghum, Managt?, Engineering Division, PPE&C
H. P. Horelica, Construction Supervisor, PPE&C
J. R. Sumpter, Manager, Nuclear Division, PPE&C
- J. W. Hanson, Principal Engineer, Nuclear, PPE&C
- R. T. Beaubcnef, Principal Engineer, Mechanical, PPE&C
- C. F. Brauer, Engineer, Construction, PPE&C
S. C. Schaeffer, Principal Engineer, Electric, PPE&C
J. N. Bailey, Engineer, Nuclear, PPE&C
R. T. McPhail, Engineer, Mechanical, PPE&C
- T. L. Duoto, Principal Engineer, Civil Enginee ring Department
C. T. Howell, Supervising Engineer, Civil Engineering Department
R. R. Hernandez, Lead Engineer, Civil Engineering Dept.
C. M. Stripling, Supervising Engineer, Civil Engineering Department
R. A. Raymond, Engineer, Civil Engineering Department
W. C. Jones, Associate Engineer, Civil Engineering Department
P. A. Swearingen, General Supervisor, QA Records Management System
A. E. Schoeneberg, Supervisor, Project Coordinator, Purchasing
T. J. Floyd, Project Purchasing Coordinator
Other Personnel
L. F. Jones, Senior Resident Engineer, Ebasco
R. P. Grippardi, QC Site Supervisor, Ebasco
-
The IE inspectors also interviewed other licensee personnel including
members of the engineering and QA/QC staffs.
- denotes those attending the exit interview.
2.
Procurement
a.
Review of Implementing Procedures
The IE inspector reviewed procedures related to procurement to
ascertain whether they were consistent with the status of the
project and PSAR commitments.
.
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The following Purchasing Department Power Plant Procurement
Procedures were rcviewed:
Introduction, Rev. 1, 3/5/75
PP-1, " General Procurement Procedure," Rev. 5, 7/7/77
PP-2, " Procedure for Establishing Bidders Lists," Rev. 3,
5/2/77
PP-3, " Site Procurement," Rev. 2, 6/14/77
PP-4,
Inquiry Issuance," Rev. 2, 6/14/77
PP-5, " Proposal Evaluation and Supplier Selection," Rev. 2,
5/16/77
PP-6, " Procedures for Purchase Order Preparation, Changes,
Approval and Issuance," Rev. 3, 3/2/78
PP-7, " Procedure for Expediting and Procurement Status
Reports," Rev. 2, 6/14/77
PP-8, " Training," Rev. 2, 6/6/77
PP-9, " Preparation of Procedures," Rev. 2, 8/16/77
PP-10, " Power Plant Construction Procurement File System
and File Control," Rev. 5, 9/14/77
PP-ll, " Document Review," Rev. 2, 4/20/77
PP-12, " Document Control," Rev. 1, 4/20/77
PP-13, " Procedure for Processing Purchase Order Acknowledge-
ments," Rev. 3, 5/17/76
The IE inspector was informed that site procurement procedures we're
being developed.
These procedures will be reviewed during a future
inspection.
No deviations were identified except as noted in paragraph 4
related to training.
,
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b.
Review of Procurement Activities
The IE inspector was informed that major procurement activities
in progress were related to reactivation of procurement actions
that were deactivated with the deferral of the Allens Creek
proj ect.
The following documents were selected for review to
detennine if procurement activities were conducted in accordance
with PSAR commitments and established precedures:
Purchase Order File No. AC-2013 for 125 volt batteries
Inquiry File No. HOU 5204 for containment piping penetra-
tions
Inquiry File No. HOU 5207 for centrifugal pumps
Documents related to a field construction cohtract for
concrete supply
The IE inspector was informed that the field construction contract
for concete supply was being processed by Ebasco in accordance with
Ebasco draft procedure ASP-4, " Field Construction Contracts," dated
May 16,1978, which has been submitted to HL&P for review but has
not yet been approved. The IE inspector informed the applicant
that processing procurement documents ir, accordance with an un-
approved procedure constitutes a deviation from commitments con-
tained in Section 17.1.5B of the PSAR and HL&P Procedure PP-3,
" Site Procurement."
During discussions with applicant purchasing representatives, the
IE inspector was informed that, for new procurements,10 CFR Part 21 requirements will be included in the terms and conditions of the
purchase orders and in the codes and standards sections of the
specifications.
Part 21 requirements will be included in old pro-
curements by issuing supplements to the purchase orders.
Implemen-
tation of 10 CFR Part 21 requirements for Allens Creek is addressed
in Allens Creek Project Directive AC-PDIR-01, which directs the use
of Nuclear Division Procedure NDP-130, " Procedure for Reporting
Design and Construction Deficiencies, Noncompliances, and Defects
to the NRC," for evaluation of reportable defects and deficiences.
The IE inspector observed that Part 21 notices were posted at
several conspicuous locations in the applicant's office buildings.
The procurement document related to concrete supply was observed
to contain Part 21 requirements.
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c.
Vendor Surveillance
The IE inspector reviewed the applicant's vendor surveillance
activities to determine whether they were performed in accordance
with PSAR commitments and HL&P Procedure QAP-3, " Procedure for
Vendor Surveillance," Rev. 2, dated August 16, 1976. The IE
inspector was informed that HL&P is performing vendor surveillance
for NSSS items and that Ebasco has been assigned responsibility
for surveillance of most of the balance of plant items. The
planned vendor surveillance by the applicant is patterned after
that being used for another of the applicant's nuclear facilities.
The IE inspector also reviewed the notification lists for NSSS
equipment and the following vendor surveillance reports:
CBI-205-8998-1, Chicago Bridge and Iron, Nuclear, performed
February 8-9, 1978
AD-AG445-1, Anchor Darling Valve Company, performed
March 3, 1978
AD-AG445-2, Anchor Darling Valve Company, performed
April 11, 1978
AD-AG445-3, Anchor Darling Valve Company, performed
June 13-14,1978
The IE inspector observed that the format used to report the
above vendor surveillance activities was not consistent and
that Procedure QAP-3 refers to " Vendor Surveillence Report
Forms, Attachment A"; however, " Attachment A" v:as not included
with the procedure nor was it adequately described therein.
The applicant was informed that failure to provide " Attachment
A" or to adequately describe the report format was a deviation
from commitments contained in Section 17.1.5A of the Allens
Creek Quality Assurance Plan.
3.
Audits and Corrective Actions
-
The IE inspector reviewed the applicant's audit program to ascertain
whether audits were performed in accordance with commitments contained
in PEAR Section 17.1.18A and requirements in Procedure QAP-5, " Audit
Procedure," Rev. 4, dated February 1, 1978.
The following audit reports were reviewed:
HL-56, Audit of HL&P Engineering Department, Civil Division,
performed March 20, 1978
.
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HL-57, Audit of HL&P Power Plant Engineeritig and Construction.
Engineering Division, performed July 20-21, 1978
ES-6, Audit of Ebasco records for Allen Creek, performed
October 12, 1976
ES-7, Audit of Ebasco QA Engineering Department, performed
July 6-7, 1977
ES-8, Audit of Ebasco QA internal audit system, performed
November 30 - December 2, 1977
ES-9, Audit of Ebasco QA vendor evaluation system, performed
May 26-27,1978
GE-9, Audit of General Electric Purchasing, perfomed
February 23-24, 1977
GE-10, Audit of General Electric Engineering and Product QA,
performed August 9-11, 1977
GE-li, Audit of General Electric QA program for procurement,
performed November 1-3, 1977
GE-12, Audit of General Electric QA program for design and
engineering, perfomed March 6-9, 1978
The IE inspector also reviewed corrective actions related to the reports
listed above.
No deviations were identified.
4.
Quality Assurance Indoctrination and Training .l./
The Houston Lighting & Power Company (HL&P) Quality Assurance Program
Manual (QAPM) implementation was reviewed by the IE inspector with
specific attention made to that section of Criterion II of 10 CFR 50, .
Appendix B which requires that the quality assurance program provide
for the indoctrination and training of personnel performing activities
affecting quality as necessary to assure that suitable proficiency is
achieved and maintained. The quality assurance program established
by HL&P is documented by written policies, procedures and instructions
contained or referenced in the QAPM, in Departmental Procedures and in
the Project Quality Assurance Plan (PQAP).
1/This portion of the inspection was performed under the direction of the
project inspector.
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The Departmental Procedures were reviewed by the IE inspector for
confomance with Section 1.5 of the QAPM.
This section, entitled,
" Quality Assurance Indoctrination," delegates to the Quality Assurance
Department the responsibility for conducting an indoctrination for
new or transferred employees coming into departments where the em-
ployee's function within the department falls under the purview of the
QAPM.
The indoctrination is aimed at familiarizing the employee with
quality assurance, stressing the importance and meaning of quality
assurance as it applies to the employee's r.ew position.
The following Departmental Procedures were reviewed:
Civil Engineering Department Procedure 5.0, " Civil Design Training
a.
Program," Revisica 1.
b.
Nuclear Division Procedure NDP-50, " Nuclear Division Personnel
Training," Revision 2.
Environmental Protection Department Procedure NPSG-20, " Training
c.
and Continuing Education Program," Revision 3.
d.
Power Plant Engineering & Construction (PPE&C) Department,
Electrical Engineering Section Procedure EES-1, " Procedure for
Electrical Engineering Section Personnel Indoctrination, Train-
ing, and Continuing Education," Revision 5.
e.
PPE&C Department, Mechanical Engineering Division Procedure
MED-6, " Indoctrination, Training & Continuing Education,"
Revision 2.
f.
Quality Assurance Department Procedure QAP-2, " Procedure for
Qualification & Certification of Surveillance Personnel,"
Revision 2.
g.
Purchasing Department Procedure PP-8, " Training," Revision 2.
h.
Power Plant Construction Division Procedure PPC-3, "Indoctri-
'
nation and Training," Revision 1.
i.
Systems Engineering Procedure SYSE-70, " Training and Continuing
Education Program," Revision 1.
j.
Projects Division Procedures Manual.
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With the exception of f. and h., the listed procedures make no mention
of a Quality Assurance indoctrination as required by the QAPM and as
defined in Section 17.1.2A of the Allens Creek PSAR.
The definition
specifically stipulates that, "The Quality Assurance indoctrination
will be conducted by the Manager - QA or his designated representative."
Procedure f. addresses itself to the Quality ,hsurance department but
does not contain provisions for interdepartmental indoctrinations.
Section 1.5.3 of the QAPM states in part, "The Department Procedures
contain specific courses of action that establish the scope and
definition of the training program as well as indicating the frequency
requirements for retraining." The training involved follows the basic
QA indoctrination :ind is provided by each Department / Division in their
appropriate discipline areas to assure that suitable proficiency is
achieved and maintained.
It was verified by the Manager, QA, that the
defined training was not being provided.
The listed procedures do not address the requirement for retraining.
In the case of item j., a procedure does not exist to satisfy the
training and indoctrination requirements of the QAPM.
The failure to address the Quality Assurance indoctrination and the
retraining frequency requirement constitute a deviation from the PSAR
as expressed in the QAPM.
5.
Site Procedures and Staffing ]
2
The status of the HL&P Site Quality Assurance Procedures was discussed
with the HL&P Site Quality Assurance Manager.
Seven procedures have
been drafted and await review and approval.
Projected site staffing
of HL&P QA personnel was also discussed.
It is expected that three
civil engineers, three mechanical engineers, and three electrical
engineers will perform surveillance for HL&P during the construction
phase of the project.
The Ebasco QA Site Supervisor and Senior Resident Engineer were inter-
viewed for the purpose of establishing the status of site procedures
and staffing requirements.
Detailed Administrative Site Procedures,
Construction Site Procedures, and Quality Control Procedures are being
developed under the direction of the manager or supervisor responsible
!!This portion of the inspection was performed under the direction of the
project inspector.
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for their administration.
The preparation schedule for each category
of procedure was reviewed by the IE inspector.
As of this inspection,
no approved procedures were available for review.
Site staffing is
expected to involve ten QA and sixty-four QC personnel at the peak level
of activity in 1982.
Positior, requirements by discipline were identified
and reviewed.
fio deviations were identified.
6.
Field Change Requests _/
3
A review was conducted of the methods established by HL&P Puwer Plant
Constr! ction (PPC) Division for the control, review and approval of
changes identified at the construction site that modify or clarify the
established scope of work, design configuration, specifications or
Bills of Material. The PPC Division Procedure PPC-2, " Field Changes,"
Revision 1, sets forth the methods for the processing of field change
requests (FCRs) by the PPC Division so as to " ensure that appropriate
change and design control measures commensurate with those applied
to the original design are utilized."
Included in the scope of the
procedure are changes covered by nonconformances, by fiRC Reguladon
changes, and changes identified by HL&P engineers.
FCRs are reviewed
jointly by the Ebasco Site Chief Engineer and the PPC Project Engineer
to determine whether the recommended change needs Ebasco home office
engineering review. The criteria to be used in determining the re-
quirement for Ebasco home office review are listed in the procedure
and were reviewed by the IE inspector.
If the FCR does not require the Ebasco home office engineering revir:w,
as established using the criteria listed in the procedure, the review
is required to be conducted by the PPC Project Engineer and the Ebasco
Site Chief Engineer.
The procedure states that, "upon agreement with
the recommended disposition (or alternate), the PPC Construction
Supervisor will sign the FCR indicating concurrence with the recom-
mended disposition and authorization for implementation of the change."
Attached to the procedure is an example FCR which contains several
concurrence signature lines, one of which is designated as the Quality
Assurance Department.
This item, on the FCP form ,is not addressed in
the prccedure.
The stipulation of authorization by the PPC Construction Supervisor,
for implementation of field changes, is considered an unresolved item
due to the lack of correlation between the procedure and the example
form with respect to a concurring review by the Quality Assurance
~
Department.
fio deviations were identified.
2/ his portion of the inspection was performed under the direction of the
T
project inspector.
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7.
Design Control
Design, design analysis and design verification are performed by
Ebasco (A/E) and General Electric (NSSS) and are audited by HL&P QA
Department. The system of controls governing design activities, for
which Ebasco is responsible, is described in the Ebasco NJClear Quality
Assurance Program Manual.
HL&P engineering functions for review of
the finished design are accomplished utilizing the methods described
in the Allens Creek Quality Assurance Plan.
Documents reviewed in regard to design control by HL&P included:
ACitGS PSAR, Section 3.2, " Classification of Structures, Com-
ponents and Systems," and Section 17.0, " Quality Assurance";
including 17.1.l A.2, "Other HL&P Departments Having Quality
Related Functions"; 17.1.l A.3.1.1, " Design Review Committee";
and 17.1.3A, " Design Control."
HL&P QA Manual, Section 2.0, " Organization," Rev. No. 5, 12/1/76;
Section 4.0, " Engineering," Rev. No. 2, 12/1/74; and Section 5.0,
" Construction and Fabrication."
HL&P Allens Creek Quality Assurance Plan, Section 4.0, " Engineering,"
Rev. No. 1, 2/1/78.
UL&P, " Outline of Procedures - Civil Engineering," Civil Design
Section, Rev. No. 1, 1/ 31/ 75.
Ebasco Nuclear Quality Assurance Program Manual, Section QA-I-4,
" Design Control," Rev. No. 1, 8/11/77.
a.
Document Review
The responsibility for conducting review of design documentation
within HL&P is assigned to the QA, Power Plant Engineering &
Construction (PPE&C) and the Engineering Departments.
The Manager, Nuclear Division of PPE&C is responsible for con-
'
ducting review of the NSSS; the Manager, Engineering of PPE&C
is responsible for conducting review of B0P and TG; the Manager,
Engineering Design and Development of the Engineering Depart-
ment is responsible for conducting review of the switchyard,
transformers,and generator as related to the transmission
system; and the Manager, Civil Engineering of the Engineering
Department is responsible for conducting review of the site
structures and buildings.
.
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Within Ebasco, the various engineering departments are responsi-
ble for design review and verification.
For example, QA engineer-
ing performs independent reviews of specifications and drawings
to assure that appropriate quality requirements have been included,
and fluclear Licensing performs a review of safety related drawings
and specifications for compliance with flP,C regulations, the SAR
and Regulatory Guides.
The Division Managers within the engineering departments, who are
responsible for technical review of system, component or struc-
ture designs, are responible for ensuring that the system, compo-
nent or structure is included on a Design Review Requirements
List (DRRL).
On approval of the DRRL by the Design Review Committee, a
designated cognizant engineer (review coordinator) coordinates
review of the assigned system, component or structure within
the responsible engineering division.
Technical reviews are normally delegated to Principal or Super-
vising Engineers or other qualified personnel.
One of these is
usually designated as Review Coordinator.
Consultants may be
required to perform selected reviews.
The method for engineering review, approval and release of
design documents by HL&P is established in Project Division
Procedure fio. PP-5.0, " Design Review Procedure," Rev. No. 4,
9/23/77.
The design documents are transmitted to the review
coordinators and reviewers.
A cover sheet, Information Trans-
mittal Sheet, is attached which designates the review coordi-
nator, reviewers and action date for the review.
Also, a form
document, Document Review Sheet, is included for use in conveying
comments from the reviewer to the review coordinator and to
document final action on the design document.
In the case of the latter form document, it was observed by the
IE inspector, that although the form was referenced, it was not
appended to the reference procedure so as to receive the same
review and approval as the procedure.
Consequently, the form
document did not have review and approval status.
The IE inspector concluded that use of the unapproved forms was
in deviation to commitments contained in Section 1.6.2 of the
PQAP and Section 17.1.5A of the PSAR.
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.
PQAP 4.5.4 requires that a Design Review Worksheet (DRW) be
completed by the cognizant engineer and updated as additional
or revised drawings are received.
The DRW is utilized during
_
the conduct of review.
The IE inspector reviewed DRRLs and DRWs of the Nuclear and
Mechanical Engineering Divisions of BPE&C and the Civil Engineer-
ing Division of the Engineering Department.
It was observed, during procedure review of the Nuclear and
Systems Engineering QC Manuals, that no formal procedure exists
to control the maintenance and use of the Design Review Worksheet.
The PQAP, Section i.6.2, requires that the managers of the HL&P
Departments who perform quality related activitier ire required
to develope written procedures necessary to implement the re-
quirements contained in the PQAP.
The IE inspector pointed out that failure to provide a procedure
for maintenance and use of the DRW is a deviation to commitments
contained in Section 1.6.2 of the PQAP and 17.1.5A of the PSAR.
During the review of the document review procedures of the Civil
Engineering Division of the HL&P Engineering Department, it was
observed that the procedures being utilized had not been approved.
The IE inspector informed the responsible engineers that failure
to utilize approved procedures during document review is a
deviation to commitments contained in Section 1.6.2 of the PQAP
and Section 17.1.5A of the PSAR.
b.
Design Change Control
(1) Design Change
The method by which design changes are reviewed and approved
is established in Section 4.7 of the PQAP.
The responsibility for controlling design changes to safety
related systems, components and structures is the same as
design review responsibility.
Design control measures
applied to design changes are required to be the same as
those for the original design.
The category of the design change document is identified by
the Review Coordinator who initiates a Design Change Control
Worksheet.
The Review Coordinator then reviews and obtains
approval for the design change.
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.
The IE inspector reviewed the implementing procedures of HL&P
and Ebasco.
Nt deviations were identified.
(2)
Field Change
The methods for processing field change requests are identi-
fied in PPE&C Procedure PPC-12, " Field Changes," Rev. No. 1,
1/13/77.
Field changes identified during construction or testing
are processed utilizing a Field Change Request (FCR)
form.
FCRs may be initiated by HL&P or construction
personnel.
No deviations were identified.
c.
Audits
Two internal audits of HL&P were reviewed:
(1) QA audit of the Engineering Division of the PPE&C Depart-
ment on July 27-28, 1978.
It was observed by the IE
inspector that five audit deficiences were identified by
the auditors.
Acknowledgement and proposed corrective
and recurrence action were requested by September 5,1978.
(2) QA audit of the Civil Engineering Division of the HL&P
Engineering Department. One area of concern was identified.
A target date for corrective action was June 15, 1978.
The corrective action was inspected by the IE inspector during
inspection of these divisions.
No deviations were identified.
8.
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.
An unresolved item disclosed during
the inspection is discussed in paragraph 6.
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.
-
.
^
Exit Interview
The IE inspectors met with applicant representatives (denoted in
paragraph 1) at the conclusion of the inspection on August 1,1978.
The IE. inspectors summarized the purpose and scope of the inspection
and the findings.
An applicant representative acknowledged the
inspectors' findings concerning the deviations (paragraph 2, 4 and 7)
and the unresolved item (paragraph 6).
.
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