ML20031G731

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IE Insp Repts 50-498/81-25 & 50-499/81-25 on 810721-22 & 0915.No Noncompliance Noted.Major Areas Inspected:Licensee Corrective Action in Response to Show Cause Order
ML20031G731
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 10/02/1981
From: Hubacek W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20031G724 List:
References
50-498-81-25, NUDOCS 8110230556
Download: ML20031G731 (6)


See also: IR 05000498/1981025

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APPENDIX

U, 5, NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report:

50-498/81-25; 50-499/81-25

Dockets:

50-498; 50-499

Category A2

1

Licensee:

Houston Lighting and Power Company

P. O. Box 1700

Houston, Texas 77001

Facility Name: South Texas Project, Units 1 and 2

Inspection at: South Texas Project, Matagorda County, Texas

Inspection Conducted:

July 21-22 and September 15-17, 1981

Inspector: d,.PJ M eA

/c/2 /pr/

W. G. Hubacek, Reactor Inspector, Projects Section 3

Date

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Approved:

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W. A. Crossman, Chief, Projects Section 3

Date

Inspection Summary

Inspection on July 21-22 and September 15-17, 1981 i.aports 50-498/81-25;

50-499/81-25)

Areas Inspected:

Announced inspection of licensee corrective action in response

to the Show Cause Order.

The inspection involved 36 inspector-hours by one NRC

inspector.

Results:

No violations or deviations were identified.

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APPENDIX

DETAILS

1.

Persons Contacted

Principal Licensee Employees

  • T. J. Jordan, Supervisor, Quality Systems
  • R. L. Deutschman, Project QA General Supervisor

J. L. Blau, Project Engineering Manager

M. E. Powell, Team Leader, Licensing

R. M. McDaniel, Lead QA Specialist

R. R. Hernandez, Supervising Engineer, Civil

H. G. Overstreet, Procurement Project QA Supervisor

  • I.

P. Morrow, Construction Superintendent

Other Personnel

  • K. D. Ramsey, Consultant to Houston Lighting and Power Company (HL&P),

Gilbert / Commonwealth

  • D. J. Harris, Quality Engineering Manager, Brown and Root (B&R)
  • F. W. Rothermel, Assistant Project Manager, B&R
  • S. Loprete, Quality Systems Manager, B&R

R. W. Peverly, Assistant Project Engineering Manager, Support Services, B&R

B. Mitchell, Design Quality Engineer, B&R

E. Peterson, Mechanical Quality Engineering (QE), Document Supervisor, B&R

J. B. Leutwyler, Electrical / Instrumentation QE Supervisor, B&R

J. Adachi, Civil QE Supervisor, B&R

T. L. Porfilio, Design Quality Engineer, B&R

The NRC inspector also contacted other licensee and contractor personnel

including members of the QA and engineering staffs.

  • Denotes those attending the exit interview on September 17, 1981.

2.

Licensee Action on Show Cause Order Items

(Closed) Show Cause Order Item V.A(7):

The licensee shall develop and

implement a more effective system to provide for control of field changes

in order to assess the impact of changes on design.

The NRC inspector reviewed implementation of the commitments in the

licensee's response to this Show Cause Order item by discussions with

licensee and contractor representatives and by inspection of objective

evidence related to the commitments described in the attachment to

HL&P letter ST-HL-AE-533, dated September 18, 1980.

The following

commitments, utilizing the identification numbers in the attachment to

the HL&P letter, were reviewed:

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(Closed) Item A131:

Qualification and training records will be maintained

on Project Site Engineers and QE's.

The NRC inspector observed that

qualification and training records were being maintained for Project Site

Engineers and QE's.

Review of selected records indicated that the records

were maintained in accordance with procedural requirements.

(Closed)

Item A136:

Each morning, a computer printout will be provided

to users of design documents.

The NRC inspector observed that computer

printouts were distributed on a daily basis during the scheduled work week

as clarified by HL&P letter ST-HL-AE-658, dated May 1, 1981.

(Closed)

Item A137:

When construction of an item has been completed,

as-built verification checklists will be prepared and their correctness

will be verified by Design and Quality Engineering.

This checklist will

be used by the inspector for final acceptance.

The NRC inspector observed

that Procedure ST-QAP-3.2, "As-Built Verification," was issued for use

effective May 29, 1981.

The procedure delineates requirements for

preparation of As-Built Verification Reports by Quality Engineering, review

and approval by Engineering, and performance of as-built inspections by QC.

The NRC inspector also reviewed implementation of the field change control

system, both at the site and at the B&R Houston Engineering office.

The

field change control system appeared to meet the requirements of Quality

Construction Procedure A040GCP-21, and Engineering Procedures STP-DC-023,

STP-DC-028, and STP-DC-029.

Review of staffing of STP Site Engineering revealed that the staffing level

was 142 as of August 24, 1981, with a programmed strength of 195 in

June 1982.

Based on reviews documented in IE Reports 80-36, 81-05, 81-15 and this report,

the NRC inspector had no further questions regarding Show Cause Order item

V.A(7).

(0 pen) Show Cause Order Item V. A(8):

The licensee shall implement a more

effective system of record controls.

The NRC inspector reviewed implementation of commitments in the licensee's

response to this Show Cause Order item by discussions with licensee and

contractor representatives and by inspection of objective evidence related

to the commitments described in the attachment to HL&P letter ST-HL-AE-533,

dated September 18, 1980.

The following commitments, utilizing the

identification in that attachment to the HL&P letter, were reviewed:

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(Closed) Item A141:

A system will be created by Quality Engineers such

that, prior to commencement of work, the records required to substantiate

the individual activities will be identified.

The NRC inspector observed

that the records control system was implemented by the following procedures:

ST-QAP-10.1, " Inspection Planning," Revision 1

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ST-QAP-11.1, " Test Control," Revision 0

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ST-QAP-17.1, " Records Control," Revision 2

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ST-QAP-17.2, Storage of Hard Copy Record and Radiographic Film,"

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Revision 0

ST-QAP-17.3, " Records Turnover," Revision 0

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ST-QSI-17.1, " Instruction for Record Control," Revision 0

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Document travelers which identify documents to verify and provide objective

evidence of specific work activities have been developed by each discipline

and issued for use.

(0 pen) Item A142:

Persons charged with creating required documents will

record the status of these documents as the documents are created.

The NRC

inspector observed that procedures (see Item A141) for implementing this

commitment were in effect; however, implementation had not proceeded

sufficiently for meaningful evaluation of the process for recording the

status of documents.

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(0 pen) Item A143: When complete document packages on individual activities

are completed in the vault, Quality Engineering will review them to verify

that the documents are complete and adequate.

The NRC inspector observed

that procedures for preparing the document packages had not been in effect

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long enough for production and subsequent Quality Engineering review and

verification of completed document packages for current work activities.

(0 pen) Item A147:

There will be a single filing system and documents will

be filed with a record traveler prepared by Quality Engineers.

The NRC

inspector observed that the procedures for.the record filing system had

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not been in effect long enough to provide a basis for a meaningful

evaluation of the system.

Record travelers have been developed and

issued but have not been implemented for current work activities.

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(0 pen) Item A148: The record traveler will identify the records required

to substantiate each activity, will record the status of the file, records

borrowed from the file, and will be used to identify overdue and missing

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records.

The NRC inspector observed that record t;welers have been

developed and issued but have not been implemented for activities described

in this commitment.

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(0 pen) Item A149:

Records in the vault will be reviewed for adequacy

and completeness, based on the results of the review of record require-

ments.

Following extensive erfort to determine a plan for review of QA

records in the vault, the licensee described their program for fulfilling

this commitment in letter ST-HL-AE-717, dated August 31, 1981, to the NRC.

Steps in the program include:

a.

Identification of programmatic and production records,

b.

Installation of a traveler system for each discipline.

c.

Recruitment of the necessary Quality Engineering staff to perform

this review.

d.

Modification of the existing quality assurance procedures to describe

the documentation flow.

Items a, b and o are essentially complete.

Item c is ongoing and expected

to be complete by November 1, 1981.

It is expected that the Quality Engineer-

ing staff will be increased by 20 positions that will be devoted exclusively

to the record review process.

The licensee anticipates that the review

process will require approximately one year to complete after the positions

are filled.

The licensee has committed to provide Region IV with a quarterly summary

of activities related to Item A149 with the first report due December 1,

1981, and subsequent reports at three month intervals thereafter.

Items A142, A143, A147, A148 and A149 will remain open pending further

review during future NRC inspections.

3.

Exit Interview

The NRC inspector met with licensee representatives (denoted in paragraph 1)

on September 17, 1981.

The NRC inspector summarized the purpose and scope of

the inspection and the findings.

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IliSPECTI0i! PLAN

IE Inspection P,eport No.

50-498 & 50-599/81-25

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