ML19321A487

First Interim Deficiency Rept Re Breakdown in Brown & Root QA Program Re Procurement Cycle of Purchased Matls at Facility.Procedures for Procurement Cycle Control & All vendor-related Activities & Records Under Review

ML19321A487
Person / Time
Site:	South Texas
Issue date:	07/14/1980
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:
References
ST-HL-AE-494, NUDOCS 8007230512
Download: ML19321A487 (5)

Text

.

Q The Light Company a-sm u e a-er sm %x s 1700 u- . Texas 77ooi (7 3> 228-921I July 14, 1980 ST-HL-AE-494 SFN: V-0530 Mr. Karl Seyfrit Director, Region IV Nuclear Regulatory Comission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76102

Dear Mr. Seyfrit:

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 First Interim Report Concerning Breakdown in Quality Program-Procurement Cycle of Purchased Materials On January 4,1980, Houston Lighting & Power Company submitted to your office a final report regarding a breakdown in the Brown & Root Quality Assurance Vendor Surveillance Program in which it failed to detect inadequate documentation records of welder certification at a Category I stael supplier's facility. As a result of this deficiency, Brown & Root initiated a Vendor Control Program to study the effectiveness of prior vendor coordination and surveillance activities.

The Vendor Control Program reviewed seven (7) Purctase Orders, engineering and purchasing interfaces, quality inspections, vendor Cocumentation and records, material release at vendors, and site receiving inspections. The findings of these reviews identified generic concerns with the quality programs related to the overall procurement cycle of purchased materials and equipment for the South Texas Project. Thus, on Jane 13, 1980, Houston Lighting & Power Company notified your office in accordance with 10CFR50.55(e) of a potentially reportable deficiency regarding the findings of the Vendor Control Program.

The generic areas of concere; in the procurement cycle which were identified from the Vendor Control Program are:

1. Review of vendors' Quality Assurance Programs prior to award of contracts were not, in all cases, properly documented in accordance with project procedures. ,

2. Approved design change documents were being utilized by vendors prior to or without issuance of a Purchase Order Change Notice making them contracturally binding-O/T 8007280 $ L 5i/

Houston Ughting & Power Canpany ST-HL-AE-494 July 14, 1980 Page 2

3. Interface agreements used to define the connunication link be' ween the South Texas Project and a vendor and to identify the processing requirements of vendor-r ded documents were not, in all cases, imposed or strictly 1 allowed.

4. Approved Supplier Deviation Requests (SDRs) were apparently utilized to make generic changes to design specifications without the issuance of required Document Change Notices (DCNs) to those specifications.

5. Vendor documentation requirements for retention at their facility and submittal to the project for review and approval were not, in all cases, adequately defined and/or implemented.

6. Trending of vendor audit deficiencies and nonconformances to identify repetitive deficiencies / discrepancies, evaluate root causes and iu1plement corrective action to prevent recurrences, was not being effectively accomplished.

7. Planned vendor surveillance inspection activities were not baing perfomed nor did documented evidence exist to substantiate tne acceptability of deviating from these planned activities.

8. Verification of personnel certification for individuals performing vendor surveillance activities was not, in all cases, adequately documented.

9. Materials received at Site reflected shipment from vendor's facilitiet other than those locations which had been approved by the project.

Due to the apparent failure to develop and/or implement a totally effective quality program during the procurement cycle, the quality status of purchased safety-related materials and equipment must be re-established. A controlled release procedure was initiated at the STP site on June 16, 1980 to provide quality control verification of required records for safety-related materials and equipment, prior to written release by Quality Engineering to Construction. The controlled release procedure will remain in ei.'act until complation of verification of records for all safety-related purchase orders.

A verification program task force review of all vendor-related activitios and records has been implemented under the direction of Quality Engineering, with specific attention being directed toward the nine (9) generic areas of concern identified from the Vendor Control Program. Satisfactory completion or satisfactory resolution of the Task Team findings concerning a safety-related purchase order ,

will result in final acceptance of the Quality documentation, equipment and materials.

w n @ung & w Wny ST-HL-AE-494 July 14, 1980 Page 3 In addition, procedures for control of the procurement cycle activities are being re-examined to provide improvements in the program to assure against recurrence of similar problems. The vendor surveillance program has been strengthened by assigning only fully trained and certified personnel to vendor surveillance activities effective January,1980. Documented meetings have been attended by all vendor surveillance personnel during March and April, 1980, to assure full understanding and compliance that all purchase order requirements must be satisfied prior to material or equipment release at the suppliers.

Management guidance is provided on a continuing basis to assure complete knowledge and understanding of current and new reouirements. All inspections required by the approved inspection plans are being performed; waivers are not being granted beyond those authorized by the inspection plan.

Additional information regarding the verification program will be provided to your office on a bi-monthly ' schedule with the next interim report to be submitted on September 15, 1980.

If there are any questions, please contact Mr. S. S. Rodgers at (713) 676-7953.

Very truly yours, k.U). O G. W. Oprea, Jr.

Executive Vice President SSR:bf

4

. Hoeston Lptq, & R:w Company ST-HL-AE- l P2g2 cc: D. G. Barker C. L. McNeese H. R. Dean R. L. Waldrop G. B. Painter A. J. uranger  :

R. A. Frazar M. D. Schwarz (Baker & Botts)

R. Gordon Gooch (Baker & Botts)

J. R. Newman (Lowenstein, Newman, Reis, Axelrad & Toll)

Director Office of Inspection & Enforcement Nuclear Regulatory Comission Washington, D.C. 20555 M. L. Borchelt Executive Vice Presiden't Central Power & Light Company ,

P. O. Box 2121 Corpus Christi Texas 78403 R. L. Range Central Power & Light Company P. O. Box 2121 Corpus Christi, Texas 78403 R. L. Hancock Director of Electrical Utilities -

City of Austin P. O. Box.1088 Austin, Texas 78767 M. C. Nitebolas City of Austin l l

P. O. Box 10iG Austin, M :,s 78767 J. B. Poston i Assistant General Manager of Operations I City Public Service Board ,

P. O. Box 1771 San Antonio, Texas 78296 A. vonRosenberg City Public Service Board .

P. O. Box 1771 San Antonio, Texas 78296

Rp l

Houston spting & Power Company ST-HL-AE-Paga Charles Bechoefer, Esquire  !

Chairman, Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Dameth A. Luebke l Atomic Safety & Licensing Commission U.S. Nuclear Regulatory Commission Washington, D.C.20555 Steven A. Sinkin, Esquire 116 Villita Street San Antonio, Texas 78205 Citizens for Equitable Utilities I c/o Ms. Peggy Buchorn l Route 1. Box 432 Brazoria Texas 77422 l Richard W. Lowerre, Esquire Assistant Attorney General for the State of Texas -

P. O. Box 12548 i Capitol Station Austin, Texas 78711 Henry J. McGurren. Esquire Hearing Attorney Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

8 l

l