ML20138H628
| ML20138H628 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 08/01/1985 |
| From: | Jordan T HOUSTON LIGHTING & POWER CO. |
| To: | Hurst L BECHTEL GROUP, INC. |
| References | |
| OL-I-CCANP-106, NUDOCS 8510290105 | |
| Download: ML20138H628 (12) | |
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P.O. Box 1700 Houston. Texas 77001 (713) 228-9211 ME f Houston Lighting Ec Power r~1 yy.
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October 4,1984 ST-HS-YQ-01050 File No.: Q16.4 Mr. L. W. Hurst Project QA Manager Bechtel Energy Corp.
P.O. Box 15 Bay City, Texas 77414
SUBJECT:
SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION PROJECT AUDIT REPORT C11-401
Dear Mr. Hurst:
Attached is the Project Audit Report for Ebasco Civil / Structural Activities, Audit Number C11-401, conducted on August 27 through September 6, 1984 The results are sumarized as follows:
No. of Items Reviewed:
1338 No. of Deficiencies:
23 No. of Concerns:
7 No. of CARS:
10 No. of DNs:
8 All concerns identified require a response.
Please submit your responses to me by November 2,1984, and transmit a copy of your concern response to A. C. Von Nyvenheim on the same date.
If you have any comments or require additional information, please contact A. C. Von Nyvenheim at extension 2415.
8510290105 850801 Sincerely,
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Houston Lighting & Power Company Mr. L. W. Hurst ST-HS-YQ-01050 Page 2 cc:
G. W. Oprea, Jr.
J. H. Goldberg J. G. Dewease L. B. Horrigan, Jr.
A. R. Beavers J. E. Geiger S. M. Dew E. W. Dotson R. L. Ulrey J. W. Williams J. L. Barker D. J. Marlowe A. C. Von Nyvenheim R. G. Holloway D. W. Halligan (BEC)
D. T. Krisha (BPC)
B. L. Lex (BEC)
K. R. Dotterer (BEC)
A. K. Priest (BEC)
R. W. Miller (BEC)
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C. L. Hawn (ESI)
Audit File C11-401 STP-RMS (w/o attachment)
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SOUTH TEXAS PROJECT AUDIT REPORT Page 1 of 8 AUDIT: No. C11-401 AUDIT DATES: August 27, 1984 -
i ESI Civil / Structural September 6,1984 Activities AUDITED ORGANIZATION:
AUDIT TEAM:
Ebasco Services Inc.
A. C. Von Nyvenheim (Team Leader)
P.O. Box 1647 T. H. McGriff (Auditor)
Bay City, Texas 77414 C. L. Grover (Auditor)
T. K. Logan (Auditor)
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/0-3-9 f Lead Auoitor
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Date duid E % <x/
a-s-er Responsible Supervisor /
Date PERSONNEL CONTACTED:
Pre-During Post-Name Title Audit Audit Audit G. Peck E5TDA Site Supervisor X
X X
R. P. Grippardi ESI QC Site Supervisor X
R. S. Morrow ESI Engineer X
X X
X X
J. R. Narron ESI Lead QA Engineer X
X P. E. Morley ESI Lead Civil Engineer X
X G. G. Hudak ESI QA Engineer X
X F. Williamson ESI Lead QC Engineer X
G. W. Morgan BEC QA Engineer X
X X
- 0. L. Ranstrom GAI Observer X
X X
M. A. Kelly ESI Records Clerk X
M. Boston ESI Records Specialist X
J. Swenning ESI QC Supervisor X
R. Pulvennacher ESI QC Level II X
P. Young ESI Records Specialist X
J. Stevens ESI QC B0P Supervisor X
T. McDonnal ESI QC Supervisor X
B. Shaw ESI Unit 2 Superintend. tit X
Audit No. C11-401 Page 2 of 8 PERSONNEL CONTACTED:
(CONT)
Pre-During Post-Name Title Audit Audit Audit U. Jenkins ETUnit 2 Assistant X
Superintendent F. R. Banker ESI Unit 2 PFE X
W. Kent ESI HVAC Superintendent X
Unit 2 G. Robert ESI Unit 2 Assistant X
Superintendent D. White ESI Unit 1 Superintendent X
C. H. powell ESI HVAC Superintendent X
Unit 1 B. O. Smith ESI Unit 1 Foreman X
G. Koekler ESI Unit 1 Superintendent X
B. Ritterhous ESI Unit 1 Superintendent X
M. Shannon ESI Unit 1 Superintendent X
N. Strawbridge ESI Unit 2 Assistant X
Superintendent A. Scott ESI Unit 2 General Craft X
Supervisor S. Christy ESI Unit 2 Superintendent X
B. W. Johnson ESI Unit 2 Superintendent X
OBJECTIVE OF THE AUDIT:
To verify proper procedural implementation of ESI's civil / structural activities.
AUDIT
SUMMARY
The overall effectiveness of ESI's civil / structural activities, in the areas audited, was marginally adequate. However there are three (3) specific areas where ESI's quality organization is not performing adequate-ly. They are:
1)
Procedural / Inspection Report inadequacies, specifically, specification requirement omissions in procedures, and/or procedural requirement omissions on inspection reports.
(Previously identified in audit l
Cll-302, performed November,1983). See CARS G-504, G-506, G-508 and l
G-511.
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2)
ESI QC is not meeting clearly established procedural requirements.
See CARS G-503, G-509, and G-512. Additionally, none of the audited QC procedures list or signify " mandatory hold points" as required by the QAPO Part C.
See CAR G-507.
3)
Problems related to expansion anchor installation and inspection activities confirm ESI's need to upgrade and effectively irtplement the respective installation and inspection procedures.
(Previously I
identified in Audit C11-302 performed November,1983). See CARS G-509, G-510. G-511 and DNs 215, 217, 218.
Audit No. C11-401 Page 3 of 8 AUDIT SUPMARY:
(CONT)
Deficiencies 1, 2, 3, 4, 6, 9, and 10 are considered of major importance.
1 Deficiency 1:
ESI QC is procedurally required to verify proper operation of the impact wrench. No objective evidence exists to support the claim that this verification is being perfonned. Additionally, one group of inspectors states that the verification is not perfonned.
This condition is not considered to adversely affect the installed connections, but this requirement is a project consnitment.
Deficiencies 2, 4, 6, and 9: Of the four deficiencies identified, no one deficiency in itself is considered of major importance; however, the types of problems identified in the four deficiencies have been previously identified and are indicative of a lack of in-depth review by the ESI and BEC quality organizations with respect to translation of specification and procedural requirements into inspection reports.
Deficiency 3: Although this deficiency may not adversely affect the hardware, it is considered indicative of inconsistent interpretation of requirements (i.e. in-process vs final inspection) which seems to point to a need for training of QC personnel to ensure consistent interpretations. This is further evidenced in deficiencies 1, 4, and
- 10. ' Additionally, the practice described does not allow for a true representation of deficiencies required for the trending program.
Deficiency 10: The project has expended a great deal of time and effort to establish systems that will prevent comingling, and will provide for traceability of material; this is in response to a NRC finding. Quality Control's practice of not actually verifying or witnessing the transfer of material markings is inconsistent with the project's comitments, and is another example where the lack of detail in ESI's QC procedures has created a problem.
DEFICIENCIES:
1.
ESI QC is either not performing or not documenting QCP-10.5 require-ments related to verifying proper operation of the impact wrench.
J CAR G-503 issued.
2.
Inspection Reports do not reflect procedurally required verifications as per QCP-10.5 and QCP-10.7.
CAR G-504 issued.
3.
During the audit, ESI QC inspectors told auditors that all inspections are considered "in-process" until material passes inspection or construction refuses to correct deficiencies; therefore, deficiencies i
do not appear on inspection reports, or on deficiency documentation.
j In support of this information, a review of all inspection reports related to QCPs 10.6 and 10.7 issued at the Fab Shop since April 10, l
l
I Audit No. Cll-401 Page 4 of 8 DEFICIENCIES:
(CONT):
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i 1983 revealed that no NCRs or DNs had been issued.
CAR G-505 issued.
4.
Specification 3A010550030 requires testing of welded studs in accor-dance with AWS D-1.1.
Contrary to this, QCP-10.6 does not address prodection testing of non-shear studs.
CAR G-506 issued.
5.
The QAPD, Part C Section QA-III-ll requires mandatory hold points to be indicated on the inspection documents. None of the QCPs related to this audit designate hold points.
t CAR G-507 issued.
6.
Specification 3YO69YS0043 Rev. 9, paragraph 7.3.7.2 states that
" Removal of backfill within three (3) feet of the ECW Pipe and between the top of the pipe and the springline, the final elevation differ-l ence, just prior to backfilling, shall not be more than four (4) inches." This requirement is not reflected in QCP-10.10, Rev. 2.
CAR G-508 issued.
7.
QCP-10.19, Rev. 4 including PCR 4 requires a 10% random surveillance of all holes drilled for cut rebar. Contrary to this, Unit 1 OC was unable to demonstrate that the above required inspections and fre-quencies have been fulfilled.
CAR G-509 issued.
8.
Omissions and/or errors related to listing required drawings / details on " Expansion Anchor / Rock Bolts Inspection Reports", related to QCP-10.19.
CAR G-510 issued.
9.
Inspection Reports for QCP-10.19 do not reflect procedurally required verifications. Specifically, Section 8.2 and 8.5 requirements for verification that "All components of the anchor shall be present and correctly assembled.".
10, ASP-5, Rev. 4, paragraph 8.03.02.02, requires OC to witness transfer of markings in accordance with the applicable OCP. QCP-10.7, rev. 3 requires QC to verify that items that have their material identification removed by the fabrication process (i.e., all thread-ing, etc), or by subdivision into smaller pieces, are properly identi-fied in accordance with the requirements of ASP-5 prior to release to the field.
CAR G-511 issued.
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Audit No. C11-401 Page 5 of 8
)
DEFICIENCIES:
(CONT):
Contrary to this, QC's practice, observed during the audit, is to log the stamps out, and to check the transferred marks after construction checks the stamp back in. Therefore, the QC inspector does not have a method to verify that all pieces were from the same material, or to detect that other pieces away from that location were marked in error.
l The inspector indicated that this was a common practice.
CAR G-512 issued.
11.
ICP-1 to CSP-10's revision is marked as Revision "2" instead of Revision "3".
Also, sequence No. 6.3 in CSP-10, Rev. 3 refers to sequence Nos. 6.1 and 6.2 in error. These should be sequence No.s 5.1 and 5.2.
DN-213 issued.
12.
Five (5) Inspection Reports were identified as not showing the following QAPD Part C, Section QA-III-11 requirements:
" Inspection documents shall specify or reference as a minimum..., by whom activities are performed...". Also " Inspection Reports shall indicate the acceptability status of items or services inspec-ted...".
1 DN-t issued.
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13.
Three (3) of five (5) Inspection Reports for proof loading of maxi-bolts were found t have "N/A" for pressure gauge ID numbers, contrary to the requirements of QCP-10.19, Rev. 4 Section 10.6.
DN-215 issued.
i 14.
One (1) of BEC's acceptance letters for blast cleaned steel panels for surface profile required by specification 3C080AS1001 and ESI's CSP-30, accepts the panel in accordance with "... Field coatings i
specification 3C080CS1001..." in error.
15.
ESI QC is not meeting the QCP-10.19, Rev. 4, paragraph 12.2 requirement for marking failed expansion anchors with " red flagging".
DN-217 issued.
16.
ESI QC did not meet the QCP-10.19, Rev. 4, requirement for passed expansion anchor inspection to be "... indicated with an approved i
l paint marker, "QC-0K", initials and date for support #2330800 in FHB j
II.
17.
CSP-30, Rev. 2, paragraph 5.01 requires the location and design of the paint storage lockers to be submitted to BEC for approval. This has not been accomplished.
DN-219 issued.
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Audit No. Cll-401 Page 6 of 8 DEFICIENCIES:
(CONT) 18.
QCP-10.8, Rev. 2, paragraph 5.1.6 states in part, "... Quality Control Site Supervisor's designee shall document his witnessing of the qualification test (s) on...". This requirement is being met by various Level II coatings inspectors, however, no objective evidence was produced to indicate who the QC Site Supervisor's designees were.
DN-220 issued.
19.
BEC Engineering had not signed acknowledgement of three (3) speed memos for density test with over 100% relative density results.
Corrected during the audit.
20.
Unit II log entrees were not up to date for the running average of the last 10 soils density tests. Computation had been made, but were not entered in the log.
Corrected during the audit.
21.
Unit II Expansion Anchor Logs contained in complete entrees for seven (7) inspection reports for August, 1984.
Corrected during the audit.
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22.
Unit I Expansion Anchor Log entrees for two (2) partial inspections, did not have a "P" prefix, designating the report as a partial inspection.
Reports and log were corrected during the audit.
23.
Coatings Receiving Inspection Report IC-40999 did not list sheet numbers.
Corrected during the audit.
CONCERNS:
1.
The list of qualified bolt-up crews for Units 1 and II, required by paragraph 5.4.7 of QCP-10.5 are not identical, beginning approximately August 9,1984. This could possibly lead to confusion particularly if construction transfers crafts people between units.
A response to this concern is required.
2.
Documentation on stud welding inspection reports is not clear regard-ing testing of studs.
It is not clear whether or not, production and/or inspection testing of studs is accomplished per AWS-01.1 as only the number of studs tested and number of studs shot is reported.
1 A response to this concern is required.
3.
QCP-10.6, Rev. 1, including pCR #3, Attachment "B", requires the QC inspector to indicate whether studs are " shear" or "non-shear". Of six (6) inspectors questioned by the auditor regarding this item, only
Page 7 of 8 Audit No. Cll-401 CONCERNS:
(CONT) one (1) inspector was able to differentiate between the shear and non-shear.
A response to this concern is required.
Specification 3A010SS0026 and 3A010SS0030 have different bending 4.
requirements for production testing of studs.
Inspectors questioned by the auditor were unsure of which criteria to use.
A response to this concern is required.
During the audit, a painter was observed in the Fab Shop touching up 5.
fabricated items with zinc-rich paint.
He was observed for approxi-mately thirty (30) minutes, during which time he never stirred his paint, this was further evidenced by the fact that the applied paint (red-grey D-6) was thinner and redder than adjacent paint (QC in-spection was not procedurally required).
A response to this concern is required.
6.
ESI Records Group has not received soils inspection or test report transmittals since 06/21/84. Activities for soils have occurred since that date with inspection and testing performed.
In the interim period from report completion to transmittal, these reports are not retained in a designated records storage area. The possibility exists that these records could be lost or misplaced prior to transmittal.
A response to this concern is required.
7.
Confusion exists within the Ebasco construction organization regarding the generating and processing of the " Drilled Hole Notification Form".
The procedural requirements in CSP-41 state that discipline superin-tendents shall compile the notification forms and submit a copy to OC weekly for safety-related hole drilling.
Since many " levels" of superintendents exist for each discipline (i.e., Area superintendents, Building superintendents, Unit superin-tendents, Assistant superintendents, etc.), the disciplines have made independent decisions as to which " level of supervision" will be responsible for this task.
Also, the method of forwarding the notification form to QC differs, (i.e., Case 1 - Building discipline superintendent forwards form directly to OC, Case 2 - Discipline unit superintendent's clerk forwards form to unit superintendent's clerk who, in turn, forwards form to OC, Case 4 - Area superintendent forwards to Building superin-tendent who forwards to QC).
A response to this concern is required.
Audit No. Cll-401 Page 8 of 8 RECOMMENDATIONS:
1.
The audit team reccmmends that ESI review all of its inspection procedures to ensure that inspection reports provide a place to document each inspection attribute required by the procedure.
2.
The response to concern number / (see above), should include, which personnel (level of supervision) are responsible for accumulating the forms, and which perscr.nel are responsible for furnishing the complet-ed forms (copy) to QC.
3.
It is also recommended that the use of generic check points be discon-tinued (i.e., block 24 of Steel Coatings Inspection Report is used to document "... surface to be coated is in conformance with the re-quirements of this procedure and specification 3C080AS1001 just prior to coating...").
ATTACHMENTS:
HL&P CARS G-503 - 512 HL&P DNs 213 - 220 l
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l POAP, Rev. 2, paragraph 10.3 reouires that inspection orocedures orovide for identification of characteristics and activities to be inspected.
1 Contrary to the above reouirement:
I OCP-10.10, Rev. 2. " Soils Inspection" does not require verification of the requirement contained in Specification 3YO69YS0043, Rev. 9, paragraph 7.3.7.2 which states in part, " Removal of backfill within the cells shall be done in a unifonn manner...
Within three feet of the ECW oice and between the top of the pipe and the spring line, the final elevation difference, just prior to backfilling, shall not be more than 8 inches.
Within three feet of the ECW pipe and between the springline and invert.
i the final elevation difference, just prior to backfilling, shall not be i
more than four inches."
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