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Insp Repts 50-498/85-07 & 50-499/85-07 on 850513-24 & 28-31. Violation Noted:No Info Recorded or Properly Noted in Metrology & Test Equipment Program Record Section
	ML20126M099
Person / Time
Site:	South Texas
Issue date:	07/09/1985
From:	Breslau B, Constable G; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20126M077	List: ML20126M073; ML20126M083; ML20126M099;
References
	50-498-85-07, 50-498-85-7, 50-499-85-07, 50-499-85-7, NUDOCS 8508010231
	Download: ML20126M099 (7)
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APPENDIX _B-

! U. S. NUCLEAR REGULATORY COMISSION

REGION IV

NRC Inspection Report: 50-498/85-07 Construction Permit: CPPR-128

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50-499/85-07 CPPR-129

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Dockets: 50-498 and 50-499

Licensee: Houston Lighting & Power Company

P. O. Box 1700

t Houston, Texas 77001

$ Facility Name: South Texas Project, Units 1 and 2

Inspection At:

South Texas Project, Matagorda County, Texas

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Inspection Conducted: May 13-24, 1985, and May 28-31, 1985

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Inspector:

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'B. A. Breslau, Reactor Inspector, Project Section B,

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Reactor Project Branch 1

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G L. Constspie, Chief, Project Section B, Reactor Efate

Project Branch 1

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Inspection Summary

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- Inspection Conducted May 13-24, 1985, and May 28-31, 1985 (Report 50-498/85-07;

50-499/85-07)

Areas Inspected: This _utine, unannounced inspection included examinations

of safety-related piping installation, Metrology and Test Equipment Program and

review of previously identified items.

.The inspection involved 63 inspector-hours onsite by one NRC inspector.

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Results: Within the three areas inspected, two violations were identified and

discussed in paragraph 3.

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DETAILS

1. Persons Contacted

Principal Licensee Employees *

R. R. Hernandez Principal, Engineer

S. K. Hubbard Senior QA Supervisor

J. W. Estella Supervisor Quality Systems

A. Khosla Engineer

F. A. White Lead Project Compliance Engineer

J. A. Bleuett SPE Construction Supervision

K. M. O'Gara Project Compliance Engineer

W. H. Kinsey Plant Manager

J. T. Westermeier Project Manager

R. L. Perryman Metrology Laboratory Supervisor

M. A. Ludwig Maintenance Superintendent

W. S. Blair Maintenance Support Supervisor

R. L. Sabol Mechanical QA Supervision

D. R. Keating Operations QA General Supervisor

M. A. McBurnett Supervision Engineer Ncclear Licensing

M. R. Wisenburg Licensing Manager

R. M. McDaniel Senior Specialist

R. C. Arthurs Project QA General Supervisor

Bechtel Power Corporation (Bechtel)

R. W. Medina' Lead QA Engineer

G. M. Washko Piping Engineer

J. Noxon QA Engineer

B. Trefethern Site Engineer /I&C

J. L. Hurley Site Engineering Manager

R. W. Miller Deputy PQAM

D. M. Stover Construction Manager

J. B. Gatewood PQAE

Ebasco Services Inc. (Ebasco)

J. A. Thompson Site Manger

R. G. Pick QA Site Supervisor

C. L. Hawn Quality Program Site Manager

The NRC inspector also interviewed additional licensee personnel, Bechtel

personnel, and other contractor personnel during this inspection.

Denote those individuals attending one or more management meetings during

the inspection periods.

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2. Licensee Action on Previously Identified Item

(Closed) Unresolved Item (8312-01) Potential breakdown in Bechtel Quality

Assurance Program. HL&P Audit Report D06-201, dated November 2, 1982,

documented the results of an audit conducted October 12-18, 1982 on

Bechtel's procurement document control activities. The results included

20 deficiencies, 7 CARS and 2 concerns. The overall evaluation of this

Bechtel procurement document control process indicated that the procurement

control process was (1) inadequately defined in implementing procedures,

and (2) was not being performed in accordance with existing procedures, or

was being performed without benefit of procedural instruction. This was

documented in CAR G-165 which was submitted to Bechtel for resolution. It

identified two specifications which failed to have applicable ANSI daughter

standards imposed upon the contractor. The specifications involved

safety-related pipe supports and containment penetrations. The resolution

was to correct specific deficiencies without consideration of any generic

program impact.

HL&P Audit Report C10-301, conducted April 1983, documented a similar

occurrence to the one described above. A specification (2A010CS001)

involving purchase of safety-related concrete services failed to have

applicable ANSI daughter standards imposed. The report also noted that

the failure to pass on quality program requirements, especially ANSI

Standards, had been noted in the past. Specific FSAR sections were

identified which required ANSI N45.2.9, N45.2.12, N45.2.13, and N45.2.23

to be included in procurement specifications.

The licensee representative, at that time, indicated that additional

information was available but the NRC inspector was unable to review

those documents at that time. A subsequent review of those documents by

the NRC inspector has been conducted which indicates there was no

breakdown in the Bechtel QA program. Bechtel's responses to the HL&P

audit findings of November 2, 1982, indicate differing opinions on how to

impose ANSI daughter standards and quality program requirements to lower

tier contractors. These responses show that Bechtel was imposing

adequate specific requirements but not in a methodology acceptable to

HL&P. These differences were dispositioned on March 3, 1983, and were

acceptable to the NRC inspector.

The HL&P audit conducted April 1983 was originally scheduled for

accomplishment July 1982 but because Bechtel's newly developed, project-

specific procedures had not been approved and implemented, the audit was

delayed on two subsequent occasions. A review of Bechtel's and HL&P's

correspondence relating to this subject was reviewed for the period of

July 1982 through December 1983. This review showed that necessary

corrective actions were taken prior to actual procurement under the

specifications.

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A~ follow-up review of Quality Assurance involvement in the current

. procurement process indicates adequate adherence to established procurement

t' program. requirements. Also, a review of selected specifications listed

.below indicate that each contains applicable ANSI daughter standards and

impose quality program-requirements.

3E189ES1000- Tray-Support

5E530ES1035 Cable Terminations

4LO60PS1006 ASME Sec. III Bulk Piping Material

4A900PS1007 ASME Sec. III Nuts and Stud Bolts

3E209ES0031 Electrical Cable Trays.

i This item is considered closed.

3. Metrology and Test Equipment Laboratory (M&TE)

The NRC inspector conducted a tour of the M&TE laboratory to review

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selected procedures and to view compliance with the M&TE Control Program.

During the. review, the NRC' inspector noted cases of procedural

noncompliance. Plant General Procedure PGP-3-ZM-1, Section 3.12.2.1,

Administrative Site Procedure ASP-23, Section 8.01.01.01, and Quality

Control' Procedure QCP 12.1,'Section 5.3.1.1 each state in part,

i "... _ Tool Data Issue / Record Card . . . recording of the identification

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and dates of all items inspected or tested with the M&TE . . . to provide

i. traceability." Contrary to the above, record card for M&TE ST-CC-3173

i did not have "value" column correctly annotated with the reading noted

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column. Several record cards were noted to have the record of use

>;. section left blank.

i Plant General Procedure PGP-3-ZM-1, Section 3.8.1.1 indicated a.

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." Cal / Repair Tag-(-5) shall be attached to retu'rned damaged or suspect

i. . .M&TE, Section 3;12.2.2 states in part "M&TE returned prior to;being

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> recalled,---calibration tag -- removed a white dot attached '. Contrary

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'to this, the NRC inspector observed the laboratory clerk attaching Form

(-5)s to every piece of M&TE being returned on May 29, 1985. When

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questioned, the laboratory clerk stated they were verbally instructed to

.> (, 'not use white dots and to put Forms (5)s on all M&TE being returned.

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' Administrative Site Procedure ASP-23, Section 8.01.03.02 and Quality

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Control Procedure QCP-12.1, Section 5.4.1 require M&TE be returned to the

calibration laboratory prior to expiration of the calibration peri'od.

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Additionally, ASP-23, Section 8.01.02 and QCP-12.1, Section 5.3.1.4

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require _immediate return of M&TE if the calibration sticker is expired.

. t Contrary to these requirements, thickness gage ST-CC-3174 and Oxygen

f.'i ; . Analyser ST-CC-3173_were not returned until 12 days and 8 days'after

'their respective expiration dates.

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' .-Plant-General Procedure PGP3-ZM-1, Section 3.3.5 requires M&TE which' ,

require calibration to have a history file. M&TE ST-CC-3173 has.the

required history _ file but:is not listed in the calibration scheduled as

o required per-Section 3.3.4 "

} , The above items are considered a violation.

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The Metrology and Test Equipment Laboratory employs Plant General'

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Procedures PGP3-ZM-1, Section 3.13 to control _the recall of-M&TE, the'

" laboratory also utilizes a " check-in/out" log which annotates issue / receipt

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of M&TE. This log indicates two pieces of test equipment "Simpson &

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Torque Wrench" have the same identification number (ST-CC-3002). 'Addi-

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-tionally, the. lab uses a M&TE past due tracking log. Neither of these:

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-logs are addressed in PGP3-ZM-1 nor are there approved procedures which .

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explain the purpose, responsibilities or actions to be taken in 'the use of '

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these logs as required per 10 CFR 50 Appendix B Criteria V & QAPD

Section.5.

The above items are considered a violation.

4. Field Inspection

The NRC inspector' performed a field inspection of safety-related piping,

specifically, the Component Cooling Water' Piping, drawings 3M 369PCC207

and SM369PCC207. Selected positions were visually compared to the field

drawings, construction specifications and work procedures.

During a review of the above piping system it was noted that the actual

installation was different from the field drawing. Drawing 3M369PCC207-A06

did not indicate a coupling which was installed on spool piece.CC-1327-1-A

between field welds FW0007 and FW0008. Further investigation of documenta-

tion revealed Field Change Request, CP-0234W, which showed the correct

installation of coupling 1F1 to spool piece CC-1327-1-A.

'The NRC inspector reviewed related nondestructive examination documentation.

The Process Dt'a Check List for field weld FW0002 in spool CC-1127-A-Al-

was incomplete; the QC inspector affixed his stamp adjacent to the

operations for performing a _ visual inspection and verifying final cleaning

-but he did not check the column for either " accept" or " reject." The QC

inspector stated that these were acceptable operations and that he forgot

to check the appropriate column after reviewing the completed NDE documents.

The Weld Data Card for field weld FW0007-1 on spool CC-1103-WA was

incomp.ete; operation steps for performing a VT and MT were designated as

QC hold points. .These points were not signed / initialed to indicate

accomplishment. This deficiency was carried over during the turnover from

Brown & Root, Inc., to Bechtel Power Corporation as part of NCR EM00001.

The indicated disposition was "N/A.", i.e. the weld was incorrectly believed

to have been cut out by Brown & Root - no visual inspection was conducted

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to verify as-built before annotating disposition. The licensee stated they

know they may'have similar problems with other weld dispositions.and are

in the process of verifying NCR EM00001. This item will be carried as an

open item (8507-03) until the processing of transition phase deficiencies

and conditions have been verified and properly dispositioned.

5. , Audit Results Review -

~The NRC inspector reviewed the following selected audit results to verify

that each is in the appropriate format as specified in the administrative

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controls. Additionally, each audit was reviewed to assure that corrective

action could be effectively carried out by the audited organization.

M14-501 ESI Welding Materials and Qualifications Control

M17-501 ESI Pipe Hangers and Supports

G01-501 BEC QA/QC Surveillances, Audits, and Inspections

G44-501 HL&P Calibration of M&TE

The NRC inspector reviewed the audited organization's responses and

corrective actions and, from this review, determined these responses to be

adequate.

No violations or deviations were identified.

6. Nonconforming Item Reports (NCRs)

The NRC inspector reviewed the below selected (NCRs). These were

examined to verify the action taken corrected the item and the cause of

.the deficiency was determined.

CM00306 Weld Filler Material

CM00076 Consumable Material

CM00154 Weld Filler Material

HM00141 Fan Cooler Discharge Ducts

HM00254 Weld Filler Material

HM00294 Weld Filler Material

Within the areas examined, the NCRs were found acceptable.

No violations or deviations were identified.

7. Surveillance Reports

The NRC inspector reviewed the following selected Surveillance Reports to

verify that responsibilities, planning, scheduling, conduct, corrective

action and records were in accordance with administrative controls.

SH-0165 Calibration

SH-0176 Weld Filler Material Control

SH-0306 Weld Filler Material Control

SH-0297 Material Control / Storage

No violations or deviations were identified.

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8. Exit Interview

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Exit interviews were held May 21, 1985, and May 31, 1985, with. licensee

management personnel. Those attending one or more of the meetings are

denoted in paragraph 1. At these meetings, the scope and findings of the

inspection were presented.

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ML20126M099

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