ML20126M099
| 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: |
| References | |
| 50-498-85-07, 50-498-85-7, 50-499-85-07, 50-499-85-7, NUDOCS 8508010231 | |
| Download: ML20126M099 (7) | |
See also: IR 05000498/1985007
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APPENDIX _B-
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U. S. NUCLEAR REGULATORY COMISSION
REGION IV
NRC Inspection Report:
50-498/85-07
Construction Permit:
CPPR-128
1
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:
7!8!8[
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'B.
A. Breslau, Reactor Inspector, Project Section B,
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Reactor Project Branch 1
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Approved:
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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'
- 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
program. requirements.
Also, a review of selected specifications listed
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.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.
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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,
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"... _ 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
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traceability." Contrary to the above, record card for M&TE ST-CC-3173
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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
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section left blank.
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Plant General Procedure PGP-3-ZM-1, Section 3.8.1.1 indicated a.
." Cal / Repair Tag-(-5) shall be attached to retu'rned damaged or suspect
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.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
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'to this, the NRC inspector observed the laboratory clerk attaching Form
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(-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
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'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
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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.
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Contrary to these requirements, thickness gage ST-CC-3174 and Oxygen
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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'
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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
required per-Section 3.3.4
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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'
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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 &
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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