ML19341C850
| ML19341C850 | |
| Person / Time | |
|---|---|
| Issue date: | 11/21/1980 |
| From: | Breaux D, Fox D, Hale C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19341C790 | List: |
| References | |
| REF-QA-99900502 NUDOCS 8103040290 | |
| Download: ML19341C850 (17) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900502/B0-03 Program No. 51200 Company:
Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Inspection Conducted:
September 29 - October 3, 1980 Inspectors:
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- u. rGox, ContractpTV Ins'pector Date Program Evaluation Section Vendor Inspection Branch I
fNl~$O D. G. Qpeaux, Inspectprf -
Date Program Evaluation Section Vendor Inspection Branch Approved by:
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C. J. HaQ/, C5iel' Date
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Program Evaluation Section Vendor Inspection Branch Summary Inspection on September 29 - October 3, 1980 (99900502/80-03)
Areas Insoected:
Implementation of Title 10 CFR 50, Appendix B and Topical Report B&R-002A, including initial QA propram inspection, 10 CFR Part 21 inspec-tion, followup on regional request, and action on previous inspection findings.
The inspection involved seventy-six (76) inspector-hours on site by two (2)
USNRC inspectors.
Results:
In the four (4) areas inspected one violation, four (4) deviations from commitment, and two (2) unresolved items were identified in four (4) of the areas.
Four (4) follow-up items were also identified.
810304 0 Sc\\b
i 2
Violations:
10 CFR Part 21 Inspection - Failure to post 10 CFR Part 21 in the facility where safety related piping stress analyses and pipe hanger design activities were being conducted.
(See Notice of Violation).
Deviations:
Initial 0A program inspection:
Superceded QA procedures were not destroyed nor stampad void (See Notice of Deviation, item 0).
Followup on regional request:
Qualification reccrds of engineering design personnel are not being maintained (See Notice of Deviation, item A); Engineering training records are incomplete or nonexistant (See Notice of Deviation, item S); Orawings issued for construction were revised without sequentially incrementing the revision level (See Notice of Deviation, item C);
Unresolved Item:
(1) Documentation made available during the inspection did not appear *.o substantiate that significant safety hazards were evaluated, documented and reported in accordance with the provisions of 10 CFR Part 21.
(2) An apparant violation exists in that Part 21 procedures are not being accurately implemented.
(See DetailsSection I, paragraph 0.3.b.)
3
,0ETAILS SECTION I (Prepared by D. F. Fox)
A.
Persons Contad ed j
R. W. Bass, Manager, QA Audits L. Brombolich, Supervision, Nuclear Power Services M. E. Byers, Assistant Project Engineer Manager H. S. Cameron, Assistant Engineering Project Manager J. R. Childers, Houston QA Coordinator H. T. Faulkner, Project Coordinator
- A. H. Geisler, Manager, Nuclear Licensing J. F. Halsey, Manager Special Problems Group
- P. S. Jordan, Project Licensing Engineer
- H. W. Overstreet, QA Supervisor, Houston Lighting and Power
- R. W. Peverley, Assistant Engineering Project Manager X. Seidle, Supervisor, Associated Technologies Inc.
J. C. Shuckrow, STP Project Coordinator, STP Project D. J. Watkins, Assistant Supervisor, Engineering Document Control Center R. A. Whitthaver, Assistant Project Engineering Manager
" Denotes those present at the exit meeting.
B.
Actinn on Previous In.soection Findings 1.
(Closed) Deviations B.1 thru B.6 (Report 80-01).
Audit Reports were deficient in content, approval, timeliness and followup.
The inspector verified the corrective actions, generic considerations and preventive measures described in Brown and Root letters of response dated April 21, 1980, and August 8, 1900.
Specifically, all audit files were revised and unsigned audit repru were signed, missing check-lists or letters indicating that they could not be located were inserted inte the appropriate audit files, and ietters stating that persons contacted ducir,7 an audit could not be ascertained were inserted into the sporopriate audit. files.
No action was required nor taken on past audit reports not issued on time.
Procedure ST-QAP-18.1 (Audit Program Procedure) and Work Instruction WI-1 (Quality Assurance Record Syster.) were revised to reflect commitments to NRC and to provide assJrance that audits will be performed as scheduled, in accordance wita pre-established checklists, timely reported and followed and corrpleted files submitted to QA records.
2.
(Closed) Deviations C.2 and C.3 (Report 80-01).
Documentation of Auditor and Supplier Surveillance Personnel certifications was not complete.
)
4 The inspector verified the preventive measures described in the Brown and Root letters of response dated April 21, 1980, and August 21, 1980.
Specifically, procedure ST-QAP-2.4 (Audit Personnel) was revised to reflect commitments to NRC with respect to maintenance of certification records, upgrading to lead auditor and certification by examination.
3.
(Closed) Deviation 0 (Report 80-01).
Engineering and QA Manuals were not identified, controlled and indexed.
The inspector verified the corrective action, generic considerations and preventive measures described in the Brown and Root letters of response dated April 21, 1980, and August 21, 1980.
Specifically, STP Engineering Manuals *,ere revised to include the required indices and manual name, number (uniquely traceable to the EDCC Controlled Distri-bution List) and status.
Procedures STP-DC-001 (Engineering Procedure for Project Procedures and Forms) and STP-GR-001 (Engineering Procedures for Manual Control) were revised to reflect commitments to NRC with respect to identification, control and indexing of STP manuals.
4.
(Closed) Deviation A (Report 80-02).
Failure to complete committed corrective action and preventive measures to previous deviations.
The inspector verified the corrective action and preventive :::easures described in Brown and Root letter of response dated August 21, 1980.
Specifically, the Senior Executive Vice President issued written instructions to the Senior Vice President and acting QA Manager to verify that ali 7esponses to NRC ;re accurate and can be completed as scheduled.
Follow-uo Item The inspector could not verify that a management plan has been imple-mented to assure that management commitments to NRC will be performed as stated and be effectively imolemented.
This item will be followed up during a future inspection.
5.
(0 pen) Deviation 3 (Report 80-02.) The Brown and Root QA Program does not implement all STP PSAR commitments.
Brown and Root letter of response dated August 21, 1980, scheduled the corrective action and preventive measures for completion by October 30, 1980.
l 6.
(0 pen) Followup item (Recort 80-02),Section I.B.6.b.(1).
The design adequacy of the inflatabie seal personnel air lock is under Brown and Root and NRC review.
The inflatable seal personnel air lock for STP Unit 1 has been fabri-cated by the third tier contractor (Murdock) and is on QA hold pending resolution of the pressure leak test requirements and incomplete
" traveller" documentation problems icentified by Brown and Root.
5 Current plans are to release the air lock for STP Unit 1 as soon as the above two items are resolved.
The air lock for STP Unit 2 is aoout sixty percrit completed.
The inspector reviewed the following documents.
a.
W. J. Wolley Co. (the second tier contractor) Letter to Pittsburg Des Moines Steel Company 1073-210C dated May 1, 1980, which transmits a listing of !nflatable seal airlocks as delivered or currently under contrac",
b.
B&R memo GM 67630 dated June 13, 1980, which transmits the original and revised Failure Mode and Effects Analysis that was used in the design review of the air lock.
The memo states that, "... the appropriate items have been updated in Section 2 to indicate the design changes that have occurred as part of this review."
c.
B&R letter to Houston Lighting and Power Company ST-BR-HLO31383 dated June 17, 1980, which references or identifies additional safety related items to be implemented in the air lock design /QA requirements.
d.
B&R letter to Pittsburg Des Moines Steel Company (the prime contractor) ST-BR-PO-1346 dated July 1, 1980, which defines a plan of action for resolving the missing documenting prcblem with the Murdock Company.
e.
B&R letter to the Pittsburg Oes Moines Steel Company ST-BR-90-1348 dated July 2, 1980, which states in part that, ".
. Houston Lighting and Power approved continued use of inflatable seals for PAL-Unit 1 & 2 on May 19,1980.... (and tnat) Specification and drawing revisions are presently in progress...."
f.
B&R memo GM-73298 dated September 29, 1980, which states that the revised FMEA concerning the inflatable seal personnel air locks identified no previously unidentified design deficiencies.
This item will continue to be followed in future inspections and via the continuing NRC headquarters evaluation.
7.
(Closed) Followup Item (Report 80-02, Sections I.B.6.b.(2)).
The ability of an individual with a valid safety concern to ultimately express the concern, in accordanca with approved procedures, to the responsible executive could not be determined.
The inspector verified that procedure STP-0C-021 (Engineering Design Procedure for Engineering Design Deficiencies) was revised to include the requirement that individuals with a safety concern deemed by the
" Incident Review Committee" to be nonreportable must cring the concern to the Senior Group Vice President - Engineering for " Final Disposition."
6 8.
(0 pen) Followup Item (Report 80-02),Section I.D.3.c(1).
Verification of design inputs to stress calculations taken from stress calculations that are taken from stress isometrics could not be confirmed.
Brown and Root management stated that the stress isometric drawings is only a transcription (reproduction) of a certain portion of a piping system taken from a design verified composite piping drawing and is only useo to aid in sisualizing the piping system layout when stress calculations and hanger locations are determined for the system.
Stress isometric drawings are checked for completeness and correctness against the composite piping drawing by a checker in accordance with procedure STP-0C-002.
Paragraph 4.3 of Appendix A r;f procedure STP-0C-002 requires that the location and type of supports indicated on the finished stress isometric i
drawing be enecked as part of the design verification process for the finished stress calculation package (which includes the appropriate stress isometric drawings).
The inspector verified that the Support Design Group did verify the accuracy of the type and location of supports shown on stress isometric drawings generated by them.
However, time did not permit the inspector to verify that the Stress Analysis Group did likewise.
The item will continue to be followed in a future inspection.
9.
(Closed) Followup Item (Report 80-02 Section I.D.3.c(2).
The basis for not verifying all revisions of P&ID and stress fabrication isometric drawings could not be determined.
Brown and Root management stated that the fabrication isometric drawing is only a transcription (reproduction) of a certain portion of a piping system taken from a design verified composite piping drawings and is used to facilitate field assembly of a piping system.
The inspector verified that fabrication isometric drawings were checked for completeness and correctness against the composite piping drawings by a checker in accordance with procedure STP-0C-002.
10.
(0 pen) Followup Item (Report 80-02,Section II.C.3.e) The status of the Brown and Root Vendor Control Evaluations and Corrections Program i
i will be evaluated.
The inspector verified that STP-PGM-13 " Guidelines for the Review and Audit of Vendor Control Program for Safety Related Equipment and Material" was issued on Septemoer 23, 1980.
i The program consists of seven phases which implement the Brown and Root Management commitment to NRC to define (and subsequently execute) a program that provides for a complete and thorougn review and audit
7 of the procurement documents, vendor control and surveillance activities, and release of safety related equipment and material to the site that is in full compliance with all Brown and Root and Houston Lighting and Power commitments to NRC.
The phases, and projected initiation and completion dates provided to the inspector are as follows:
a.
Establish Priorities and Schedule - June 15 thru October 15, 1980 b.
Generate "PO Baseline Requirements" - September 15, thru April 1, 1981 c.
Independent NUS Audit - September 1,1980 thru July 15, 1981 d.
Rt '"+ ion of Audit Findings - November 1, 1980 thru August 1, 1981 e.
Update
'se Orders - November 15, 1980 thru April 15, 1981 f.
Correct Vendor 0=
iencies - Decemoer 15, 1980 thru October 1, 1981 g.
Release of Equipment & N
%1s - January 1, 1980 thru October 15, 1981 Review of an internal memorandum between Brown and Root Senior Vice Presidents indicated that Brown and Root "made a management decision to keep the vendors operating... (since) it is going to take at least one year to get the vendo, surveillance program back in shape."
Procurement of safety related equipment and materials will be closely monitored by NRC during future inspections.
C.
Region IV Reouest for Insoection of Brown and Root Pioing Systems Designers 1.
Objectives a.
Determine the qualifications of the following relative to their activities / responsibilities.
(1) The designers of piping systems, (2) Supervisors who sign drawings for approval, and (3) Nuclear Power Service personnel (contractor to Brown and Root) b.
Determine Brown and Root's compliance with the QA program and other specific requirements.
8 c.
Evaluate for generic implications.
2.
Methods of Acccraclishment Review of the following documents and interviews with personnel to accomplish the above objectives.
a.
Appropriate sections of Chapter 17 of the PSAR and FSAR for the HLP (Houston Lighting and Power) STP (South Texas Project) Units 1 and 2 to determine the B&R consnitments with respect to organi-zation, quality assurance progran and design control.
b.
Sections 17.1,17.2,17.3,17.6 and 17.17 of the B&R (Brown and Root, Incorporated) Topical Report BAR-002A; and the corresponding sections of the B&R Quality Assurance Manual to detennine that tne B&R corporate conunitments with respect to organi:ation, quality assurance program, design and document control and QA records are reflected in Quality Assurance Policies and Procedures.
c.
Six S&R STP Engineering and Project Management procedures to deter-mine if the B&R consnit:nentu relative to design control were correctly translated into e viable STP design control program.
d.
The following documents to verify that the B&R STP design control program and QA program cmanitments were being effectively imple-mented by the Support Design Group Activity.
(1) Three (3) subcontracts for design and fabrication services, (2) Nine (9) stress calculation packages, (3) Sixteen (16) stress isometric and pipe hanger drawings, and (4) Forty-seven (47) personnel qualifications and training records.
3.
Findings a.
Deviations Three deviations related to personnel qualification and design document control were identified in this area of the inspecticn.
See Notice of Deviation Items A, B, and C.
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b.
Follow-uo Items (1) The education and experience listed on the qualifications resumes of NPS (Nuclear Power Services) and ATI (Associated Technologies Incorporated) personnel performing safety related design could not be verified by the inspector.
This item will be followed during a future inspection.
(2) Two B&R purchase orders for pipe support design, analysis and drafting services placed with NPS and ATI state in part that "all of this sublet work shall be performed in the General Contractors (B&R) facilities as directed by, and in accordance with the Subcontract Documents and the General Contractors Engineering Managers instructions." A third purchase order, placed with NPS, states that the " Seller shall furnish engineering, design, and fabrication of ASME Section III and ANSI B31.1 Pipe Hangers and Supports and the supply of necessary bulk hardware, supplementary steel and materials."
The inspector could not determine if an approved 10 CFR 50 Appendix B quality assurance program was imposed on and is being implemented by the subcontractors from the documents made available during the inspection.
The item will be followed during a future inspection.
(3) The inspector could not verify that 8&R procedures require that sufficient records of Engineering and Management per-sonnel assigned to safety related nuclear projects be maintained to furnish evidence of their qualifications to conduct their assigned duties and responsibilities.
This item will be followed up during a future inspection.
d.
Comments (1) This inspection was limited to the newly formed Support Design Group located at 5800 Ranchester Avenue, Houston, Texas.
The Stress Analysis Group, located in the Engineering Building at 4100 Clinton Road, was previously reviewed as part of inspection 80-02.
(2) The Support Design Grouo is a design group formed by B&R 5t managed and staffed by approximately 170 B&R, 79 NPS and 20 ATI personnel in a combined organi:ation.
The ecmbined crganization is under the direct supervision of a B&R Assistant Engineering Project Manager.
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10 (3) With respect to the qualifications of the designers of piping systems:
(a) Nine of ten of the qualification records and eight of ten of the training records of a randomly selected sample of B&R engineering personnel assigned to the Support Design Group were not available for examination during the inspection, thus the insoector could not
.trify the qualifications of all B&R designers.
- However, the inspector found no information which would prove that they were not qualified.
See Notice of Deviation, Items A and B.
(b) The resumes of the nine NPS and four ATI engineering personnel assigned to the Support Design Group indicated that thirteen (except for two draftsman) held an Engineering Degree from a domestic or foreign College /
University and had an average of one and three-fourths years and a minimum of one-half year direct experience in piping systems stress analysis or hanger designs.
B&R has requested verification of the accuracy of the information on the resumes from NPS and ATI.
(4) With respect to the qualifications of the supervisors who sign drawings:
(a) Three of the eight qualification recorcs and five of the eight training records of B&R management per-sonnel assigned to the Support Design Group were not avaflable (qualifications) or incomplete (training) for examination during the inspection, thus the inspector could not verify that all B&R supervisors were qualified.
See Notice of Deviation, Items A and B.
Review of the five qualification records that were available indicated that the B&R management had an average of three years (three managers had less than one-half year) direct experience in piping systems stress analysis or hanger design.
However, the three managers with less than one-half year direct experience had a minimum of five and one-half years supervisory exoerience in related engineering assignments at B&R.
The inspector found no information that the S&R manage-ment were not competent to review and approve drawings.
11 (b) The resumes of the thirteen NPS and three ATI management personnel assigned to the Support Design Group indicated that all sixteen held an Engineering Degree from a domestic or foreign College University and had an average of four years and a minimum of one half year direct experience in piping systems stress analysis or hanger design.
(5) With respect to the qualifications of Nuclear Power Services in their area of activity, other than reported herein the inspector found no information that NPS was not a qualified contractor.
However, B&R reported under the provisions to NRC 10 CFR Part 21 to NRC (Mr. Stello) on July 11, 1980, that NPS (a B&R subcontractor for the design and fabrication of pipe hangers and supports) dispositioned "Use as is" turnbuckles, welders eye nuts, clevises and sway strut eye rod forgings, and caused them to be shipped to the STP even though the casting material was in violation of ASME code material require-ments and would require special precautions to be imposed dur-ing welding to maintain the physical properties of the material.
D.
10 CFR Part 21 Insoection 1.
Objectives The objectives of this area of inspection were to examine the establishment and implementation of related procedures for 10 CFR Part 21 to verify that:
a.
10 CFR Part 21 is posted in accordance with the requirements, b.
Deviations and nonconformances are evaluated and adequate records are maintained and properly dispositioned by the responsible organizations or persons.
c.
Methods of analysis for a defect, deviation or failure to comply are clearly described and responsibilities assigned to organizations or persons in each related phase of analysis.
d.
A Director or responsible officer had been appointed to notify the commission of evaluated defects, deviations or failures to comply for substantiated safety hazard.
e.
Procurement documents for safety-related itims specify that 10 CFR Part 21 requirements apply.
i
12 f.
Evaluation of deviations were appropriate.
g.
Deviations determined to be substantial safety ha::ards were appropriately reported to the NRC.
2.
Method of Accomplishment The preceding objectives were accomplished by review of the following:
a.
Posting of the required 10 CFR Part 21 notices at the following Brown and Root facilities:
Engineering Building - 4100 Clinton Dr.
0A Building - 2950 So. Gessner Engineering Building - 5800 Ranchester Street b.
Brown and Root procedure STP-FM0-022, Rev. 2 dated February 1, 1979, " Procedure for Evaluating and reporting of defects, Non-compliances and Deficiencies"; B&R STP Project Procedures STP-CC-000 " Glossary" and STP-0C-021 " Engineering Procedure for Engineering Design Deficiencies;" three B&R purchase orders and four change notices for safety related items; Status / Summary of the " Incidents" (potential safety concerns) evaluated by the B&R Incident Review Ccmittee (IRC); IRC files and reports of items 4 thru 13, 18, 19, 23, 25, 25, 28, 32, 34, 40, 41, 45, 46, 48, 49, 53, 56, 57, and 66 thru 69; B&R letter to NRC (Mr. V. Stello) dated July 11, 1980; and HL&P letters ST-HL-AE-494 and ST-HL-AE-536 to NRC (Mr. K. Seyfrit), Nonconfonnance Reports, Audit Deficiency Reports, Design Deficiency Reports, letters, memos, meeting and telephone minutes and other documentation related to identified safety concerns.
3.
Findings a.
'tiolation One violation was identified in this area of the inspection.
See Notice of Violation enclosure.
b.
Unresolved Items (1) Based on documentation made available during the inspection, the inspector could not determine if Brown and Root had
13 fully exercised their responsibility to perform, or cause to be performed, the evaluation, documentation, or timely report-ing to NRC of twenty-eight (28) safety concerns (of which twenty-one (21) have been determined to be " substantial safety hazards" and seven deemed to be "probably reportable" by Brown & Root) under the provisions of 10 CFR Part 21.
Brown and Root Management committed to conduct an in-depth evalu-ation of this apparent noncompliance with 10 CFR Part 21, and to implement those procedural, adninistrative and documentation changes that are necessary to assure full compliance with the regulations.
This area will be inspected further during subsequent inspections.
(2) During this inspection, six (6) examples were identified where B&R was not adhereing to procedures established for implementing Part 21.
This matter has been forwarded to NRC headquarters for evaluation to determute the appropriate enforcement action to be taken.
E.
Exit Meeting An exit meetin.g was conducted with Brown and Root management personnel at the conclusion of the inspection on Octocer 3,1980.
Those individuals indicated by an asterisk in the Details Sections of this report were in attendance.
In addition, the folicwing were also present:
X. M. Broom, Senior Vice President J. R. Geurtz, General Manager, STP Project J. L. Hawks, Engineering Project Manager T. Stanley, Project Quality Assurance Supervisor (HL&P)
X. A. Swartz, Senior Engineering Manager The inspector discussed the scope of this inspection and the details of the findings identified during the inspecticn.
Management comments were generally for clarification only or to acknowledge the statements of the inspector.
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l 14 DETAILS SECTION II (Prepared by O. G. Breaux)
A.
Persons Contacted B. Childers - Houston QA Coordinator R. L. Gaona - Assistant Houston QA Coordinator D. Janecke - Manager, STP Vendor Surveillance J. C. Shuckrow - Design QA Engineer O. J. Watkins - Assistant Supervisor, Engineer Occument Control Center G. H. Watkins - Manager Engineer Document Control Center (DCC) 9.
Initial QA Program Insoection 1.
Objectives The objectives of this area of the inspection were to determine that:
a.
The necessary facilities, organizations, written and approved procedures and instructions, and practices for the quality assurance program are in place and being implemented.
b.
The quality assurance program is being implemented within the defined scope of supply for current nuclear projects.
2.
Method of Accomplishment Review of the following documents to determine that the preceding objectives were accomplished relative to Brown and Root's Quality Assurance Program.
a.
The documents reviewed to determine the specific Brown and Root South Texas Project (STP) Units 1 and 2 quality related commitments, procedures, instructions and standards were as follows:
(1) Chapter 17 titled " Quality Assurance", of the STP Preliminary Safety Analysis Report.
(2) The appropriate sections (policies and procedures) of the Project Quality Assurance Manual to determine that the commit-ments to quality were accurately reflected in the soproved in place quality assurance program for the STP consistent with the Brown and Root scope of supply for the project.
(3) Appropriate sections of the Brown & Root Quality Assurance i
Procedures Manual for the STP were reviewed
\\
15 to assure definitions of its organizations, resporsibilities, authorities, and duties within the QA organization in accor-dance with the requirements of the STP Safety Analysis Report (SAR).
b.
Specifically, the following sections and procedures were reviewed in the STP Quality Assurance Manual, and the STP Quality Assurance Procedures Manual to determine the quality related commitments:
(1) ST-QAP-6.1, " Procedure Development," issued July 15, 1980.
(2) ST-QAP-6.2, " Manual Control," issued July 15, 1980.
(3) ST-QAP-6.3, " Forms Control," issued August 4, 1980.
(4) ST-0C-011-0, " Document Distribution," issued April 1,1980.
(5) ST-QAP-15.2, "Stop Work," Issued August 5,1980.
(6) ST-QAP-15.4, " Trend Analysis," issued July 15, 1980.
(7) ST-QAP-2.6, "Nonconformance Control," Rev. 10 July 14, 1980.
(8) Section 15.0 " Nonconforming Materials or Items," Issued October 17, 1975 latest Revision August 29, 1980.
(9) Section 16.0 QA Manual, " Corrective Action," latest Rev.
September 19, 1978.
(10) ST-QAP-2.12, " Corrective Action," Latest Rev. June 6, 1978.
c.
To assure that the previously reviewed procedural requirements are being properly and effectively performed, the following documents were reviewed.
(1) In the STP Engineering Document Control Center the following document listings were reviewed for content:
" Brown & Root Specification Status Report", Job CR-0241 dated August 6, 1980.
"STP Acronym List", Job CR-0241 Dated Septemoer 2,1980.
" System Design Description", Job CR-0241 dated Septemoer 9, 1980.
16 "STP Calculation Listing," dated August 1,1980.
" Brown & Root Orawing List," dated July 31, 1980.
" Vendor Document List," dated September 8,1980.
From these listings the following documents were retrieved from Engineering Document Control Center to assure that storage and information transmittal as well as distribution was being properly performed:
Calculations - 7E319EC022, 35149MC132, and 1N070NC701.
System Design Descriptions - 9Q270MD018, 7P220S0015, and SZ329ZD004.
Specifications - 3V289VS008, 22459Zs230, and IV020W5001.
Brown & Root Orawings - 1P-CV-1116. SHT 3, 1P-ED-1131 SHT 5, and 1P-FC-1001 SHT 0A1.
Vendor Documents - QPT-1 (L819XP006A0R), WS-300 (Z459XP11ADI),
and QCP-1013 (Q089XP009AGO).
Five (5) Occument Transmittal Orders.
Five (5) Document Change Notices.
(2) In the area of nonconforming materials, parts, or components, to assure that specific QA procedures were being implemented the following were reviewed:
(a) South Texas Project Nonconformance Reports Log.
(b) Quality Assurance Analysis System "NCR Action Items List For September 27, 1980.
From this list the following NCR's were retrieved from the Houston Quality Assurance Coordinators file to review content.
NCR's H-G00324 issued December 6, 1979, H-G00335 issued March 18, 1980, H-0345 issued June 20, 1980, and H-371 issued June 27, 1980.
(3) From the Houston Quality Assurance Coordinators "Stop Work" notice log the following documents were reviewed for contant:
stop work notices H-005 issued December 4, 1979, H-004 issued October 2, 1979, H-009 issued April 9, 1980, and H-011 issued June 12, 1980.
(4) From the Nonconformance Report (NCR) Status Report, the input of " Corrective Action Report (CAR) Status" was reviewed and the following CARS were retrieved to assure proper content and status:
17 CARS H-010 dated o fy 25, 1979, H-019 dated June 4, 1980, H-025 dated July 3, 1980, H-017 dated May 6, 1980, and H-018 dated May 22, 1980.
3.
Findings In this area of the inspection (1) deviation from commitment was identified.
(See Notice of Deviation, Item 0).
With respect to deviation Item 0., two existing STP Quality Assurance Procedures were issued under the same procedure designation number.
These procedures were; ST-QAP-2.4, " Audit Personnel", issued July 22, 1980, and ST-QAP-2.4, "QA Document Review", issued April 22, 1975, and revised March 1, 1979.
In this same area it was evidenced that the deleted STP Quality Assurance Procedures ST-QAP-2.3, " Document Administration", was still referenced in five (5) existing procedures:
ST-QAP-4.2, ST-QAP-4.3, ST-QAP-5.1, ST-QAP-5.4, and ST-QAP-5.11.
This area will be inspected further during the followup of the identified deviation.