ML20245F215
| ML20245F215 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/21/1989 |
| From: | Barnes I, Ellershaw L, Gilbert L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20245F205 | List: |
| References | |
| 50-498-89-16, 50-499-89-16, NUDOCS 8906280063 | |
| Download: ML20245F215 (10) | |
See also: IR 05000498/1989016
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-498/89-16
Operating Licenses:
50-499/89-16
Dockets: 50-498
50-499
Licensee: Houston Lighting and Power Company (HL&P)
Facility Name: SouthTexasProject(STP), Units 1and2
Inspection At: .STP, Matagorda County, Texas
Inspection Conducted: June 5-9, 1989
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Inspectors:
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L. D. Gilbert, Reactor Inspector, Materials
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and Quality Programs Section, Division of
Re tor Safety
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(. E. Ellershaw, Reactor Inspector, Materials
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and Quality Programs Section, Division of
Reactor Safety
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Approved:
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I. Barnes, Chief, Materials and Quality
Date
Programs Section, Division of Reactor Safety
Inspection Sumary
Inspection Conducted June 5-9, 1989 (Report 50-498/89-16)
Areas inspected: Routine, unannounced inspection of the audit progrem; the
procurement program; and the receipt, storage, and handling of equipment and
materials program.
Results:
In general, the audit program was consistent with the TS requirements
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and FSAR comitments. A noncited violation (NCV) was identified and reviewed
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890620o063 890622
ADOCK 05000498
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in paragraph 2 for failure to meet minor administrative requirements of the TS
and QA program. During a partial review of the procurement program, one
apparent violation (paragraph 3) was identified in regard to the failure to
incorporate applicable requirements of purchase requisitions (prs) into
purchase orders (P0s). This finding indicated a programmatic weakness, in that
technical and quality assurance reviews were performed only on prs and no
measures were established to validate that issued P0s accurately reflected PR
requirements. One unresolved item (paragraph 3) was also identified in regard
to the commercial grade procurement and dedication program. The inspection
revealed that the procurement program had not appropriately addressed this
subject area in the past, bringing the adequacy of prior procurement into
potential question. The licensee has recognized this weakness and is currently
_ finalizing program requirements ard required procurement review actions. The
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licensee has established and implemented an effective program with respect to
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receiving inspection, storage of material, and control of nonconforming parts
identified during receiving inspection.
Inspection Conducted June 5-9, 1989 (Report 50-499/89-16)
Areas Inspected:
Routine, unannounced inspection of the audit program; the
procurement program; and the receipt, storage, and handling of equipment and
materials program.
Results:
In general, the audit program was consistent with the TS requirements
and FSAR commitments. A NCV was identified and reviewed in paragraph 2 for
failure to meet minor administrative requirements of the TS and QA program.
During a partial review of the procurement program, one apparent violation
requirements of purchase requisitions (prs) into purchase orders (P0s)pplicable
(paragraph 3) was identified in regard to the failure to incorporate a
This
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finding indicated a programmatic weakness, in that technical and quality
assurance reviews were performed only on prs and no measures were established
to validate that issued P0s accurately reflected PR requirements. One
unresolved item (paragraph 3) was also identified in regard to the commercial
grade procurement and dedication program. The inspection revealed that the
procurement program had not appropriately addressed this subject area in the
past, bringing the adequacy of prior procurement into potential question. The
licensee has recognized this weakness and is currently finalizing program
requirements and required procurement review actions. The licensee has
established and implemented an effective program with respect to receiving
inspection, storage of material, and control of nonconforming parts identified
during receiving inspection,
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. DETAILS
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' Persons Contacted.
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- G'J. EpVaughn,LVice President, Nuclear Operations
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- J.:E.'Seiger, General Manager. Nuclear Assurance
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-L*R. L. Balcom, Mana'ger, Audits & Assessments
- D. R. Keating, Manager, Quality Engineering (QE)'
. J. l D. Green. Manager. -Inspection and -Surveillance
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- S. M. Dew, Manager.. Nuclear Purchasing and Materials Management
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. M.-A.) Ludwig, Manager, Material Management ~
- E. R. Rivera, Manager, Purchasing.
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- R. P..Garris . Director, Purchasing'and Contracts
- A. C. McIntyre Manager,. Support Engineering
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- C. A.: Ayala, Supervisor Licensing Engineer
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- A. W.-'-Harrison. Supervisor Licensing-Engineer
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- P. L. Walker, Senior Licensing Engineer
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- A.-K. Khosla, Senior Licensing Engineer
- W.; G. LWellborn, Manager, Material Technical Services:
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- M..F. Polishak, Material Technical Services Supervisor
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'. *J. E. Adkins, Staff.QA Specialist
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- D. E. Mathews, Purchasing Supervisor .
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R. W.'Chewning,' Chairman, Nuclear Safety Review Board'
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"NRC
' *J..E. Bess,. Senior Resident' Inspector-
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- J. I. Tapia, Senior Resident Inspector
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- D. L. Garrison, Resident Inspector.
The hRC inspector also interviewed other licensee employees during the-
inspection.
- Denotes attendance at exit interview conducted on June 9,1989.
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2.
Audit Program (40702 and 40704)
The objective of this inspection was.to verify that the licensee.has
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developed and implemented a quality assurance (QA) program relating to
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audits of activities that is in conformance with Technical
?(specifications (TS) and commitments in the Final. Safety Analysis Report
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FSAR).
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The NRC inspector reviewed the following documents to verify that
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' administrative controls exist and that they provide measures to assure
that audits are scheduled and performed by independent ano qualified
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personnel including special expertise when needed.
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' Operations'Ouality Assurance Plan, Section 15.0, Revision 3. " Quality
Assurance Audit and Surveillance"
QA Procedure QAP-2.8, Revision 1, " Plant and. Vendor Audits"
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QA Procedure QAP-1.5, Revision 3, " Deficiency Reporting"
QA Procedure QAP-2.1, Revision 1, " Training, Qualification and
Certification of Audit Personnel"
cognizance of the Nuclear Safety Review Board (program is under theNSRB) by in
The NRC inspector also verified that the audit
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LChairman of the NSRB, reviewing minutes of the NSRB meetings, and
reviewing the following documents.
Nuclear Group Policies NGP-820. Revision 6. " Nuclear Safety Review
Board"
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Nuclear Safety Review Board NSRB-04, Revision 3. " Audit / Assessment
Procedure"-
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Nuclear Safety Review Board NSRB-01, Revision 3, " Rules'of Conduct"
In reviewing the long-range audit plan and schedules-for 1988 and 1989,
the NRC inspector noted that although the audi.ts were perfomed at the.
frequency required by the TS the audit plan frequency terminology did not
conform to that'used in the TS. For example, the audit' plan frequency
uses the term " annual" when the TS specifies "at least once per 12'
months." The licensee indicated that the annual audit plan terminology
would be clarified to ensure that-the TS requirements for frequency are
incorporated into the audit plan scheduling.
To assess the implementation of the audit program, the NRC. inspector
reviewed the following audit reports. The audit reports were selectively
reviewed to ascertain adequacy of audit scope, audit content, audit
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checklist, distribution to management, followup actions, timeliness of
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reports and responses to audit findings, and audit personnel
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qualifications,
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Audit B2 - Personnel Training and Qualification, Audit Reports 89-21
and 88-21
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Audit A - Compliance to Technical Specifications and License
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Conditions, Audit Reports 89-18 and 88-23
Audit C - Nonconformance Control and Corrective Action, Audit
Reports 89-05, 88-05, and 88-37
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Audit D1 - Conduct of Operations, Audit Report 88-30
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Audit 012 - Cooperative Management Audit, Audit Report 88-64
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In' general' the audit program was consistent with the TS. requirements and
FSAR commitments. However, administrative' requirements of the TS were
violated, in that 2 of the 10 audit reports reviewed were not issued
within 30 days efter completion of the' audit as required by
Specification 6.5.2.9c of the TS. As a result of the NRC inspector's'
finding,.the licensee: issued Deficiency. Report No.89-045 to document the
' deficiency, review other audit reports for this deficiency, and implement-
corrective. action to ensure that all audit reports are issued within TS
requirements.r In addition, administrative' requirements of the QA program.
/were violated, in that, the audit package for Audit Report 88-30 (D1) did
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not contain a completed audit checklist as required by.Section 7.1.2 of-
QAP-2.8. The licensee issued Deficiency Report No.89-042 to document the-
deficiency and locate or reconstruct'the audit checklist. This is an-
apparent violation for. failure to meet the administrative requirements of:
the TS and QA program; however, the violation is not being cited bccause
it. is of minor safety. significance and meets the criteria specified in
Sect'.on V.A. of the Enforcement Policy.
(NCV498/8916-01; NCV499/8916-01)2
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Procurement Program (38701and38703I
'The objectives.of this inspection were:
(a)toascertainwhetherthe
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licensee has implemented a QA program to control procurement activities
that is in conformance with regulatory requirements and licensee'
commitments; (b) to evaluate the licensee's commercial grade procurement
activities to ensure that they-conform to established guidance and
requirements.
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a.
Program Review
The NRC inspector reviewed the documents listed below to verify that
administrative controls exist and that they provide measures to
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assure that necessary technical and quality requirements are included
in procurement documents for safety-related items or services. The
documents were also reviewed to verify that controls exist for the
selection, approval, and use of vendors.
STP-FSAR, Section 17.2.4, " Procurement Document Control."
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Amendment 62
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Operations Quality Assurance Plan, Section 7.0, Revision 4
" Procurement"
QA Procedure QAP-1.6, Revision 1. " Procurement of Items and
Services"
QA Procedure QAP-2.4, Revision 2 " Quality Engineering
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Evaluation of Vendors"
QA Procedure QAP-2.6, Revision 1, Procurement Document Review"
QA Procedure QAP-2.8, Revision 1, " Plant and Vendor Audits"
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Procedure NPMMP-4.7Q,' Revision 0, " Preparation and Issuance of
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Purchase Orders / Contracts and Supplements"
Procedure NPMMP-4.12Q, Revision 0, " Preparation of RPDs for
Items and Services"
Procedure IP-5.1Q, Revision 4 " Procedure of Items"
-In order to assess implementation of the program, the NRC inspector
reviewed the following purchase orders (P0s) in conjunction with the
applicable purchase requisitions (prs) and furnished vendor
documentation.
PO RS 9876 to Wolf Creek Generating Station for Westinghouse
P/N OT1MIC selector switches
P0 RS 8599 to ASEA Brown Boveri for underfrequency,. relays
P0 RS 8015 to A&G Engineering Co., Inc., for ASTM A-194,
Grade 2H hex jam nuts
P0 RS 10630 to Brazoria Valve and Fitting Co. for Crawford ASME
Section III Class 2 tee fittings
P0 RS 8244 to Hub, Inc., for 3-inch, ASME Section III Class 2
SB-165 pipe
P0 RS 9225 to Trentec, Inc., for ASME Section III Class 2 ball
valves
From the above review, the NRC inspector observed three instances
where the issued P0 differed from the PR with respect'to applicable
technical and quality requirements. P0 RS 9876 was issued to Wolf
Creek for Westinghouse P/N OTIMIC selector switches, with the items
designated nonsafety-related. Review of the applicable PR (i.e.,
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140234) showad, however, that the switches were required to be
procured as safety-related equipment. The NRC inspector noted that
the P0 required any original supplier certification to'be furnished
with respect to this P0.
P0 RS 10630 was issued to Brazoria Valve
and Fitting Co. for Crtwford ASME Section III Class 2 instrumentation
tees. The P0 indicated that 10 CFR Part 21 was not applicable, which
was contrary to the PR (596867) stipulation of 10 CFR Part 21
applicability.
P0 RS 8244 was issued to Hub, Inc., for 3-inch,
Schedule 80 ASME Section III Class 2, SB-165 pipe. The designated
pipe schedule contained in the PR (141051) was, however,
Schedule 160.
No documented approval by Materials Engineering or QE was observed
with respect to the changes from PR requirements contained in the
three P0s. The NRC inspector confirmed from program review and
discussion with licensee personnel that Materials Engineering and QE
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reviews are performed at only the PR stage of-procurement. The NRC
inspector additionally ascertained from discussion with the.
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Supervisor, Purchasing that no program was currently in place to
require an independent review of buyer generated P0s for verification
of compliance with PR requirements. The failure to assure P0s
reflect PR requirements is an apparent violation of Criterion IV of
Appendix B to 10 CFR Part 50.
(498/8916-02; 499/8916-02)
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b.
Commercial Grade Procurement
At the start of the inspection, the NRC inspector was informed that
licensee personnel were currently upgrading procurement program
requirements with respect to commercial gradt procurement practices.
These activities were ascertained to have been initiated as a result
of evaluation of concerns' expressed to Safeteam on the adequacy of
existing commercial grade procurement practices. The NRC inspector
reviewed STP Specification No. 5A010WS0026, Revision 0, " Specification
for Parts Classification aad Commercial Grade Items. Dedication in
Safety-Related-Applications," and also Revision 5 of Procedure IP-5.1Q
which was currently at a review and comment stage. iIt wasLnoted from
this review that the planned STP approach appeared to be consistent
with the guidance contained in EPRI NP-5652, " Guideline for the
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Utilization of Commercial Grade Items in Nuclear Safety-Related
Applications."
In response to a question concerning the planned scope of reviews of
prior commercial grade procurement, the NRC inspector was informed-
that a statistical sampling approach would be used to evaluate the
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adequacy of,these procurement. The NRC inspector recommended to
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licensee personnel that consideration be given to reviewing all prior
procurement, in that a homogeneous population would have to exist
for statistical sampling to be a valid approach.
The NRC inspector reviewed the following'five Level III P0s(i.e.,
commercial grade items requiring receiving inspection) to ascertain
the types of requirements previously imposed on vendors for
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commercial grade items and the basis for dedication of those items
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used in safety-related applications:
P0 RS 7021 to Woodward Governor for packing
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P0 RS 7358 to Anchor Darling Valve Company for an Inconel X
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wedge spring for a 2-inch, 2500 lb. double disc gate valve
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PO RS 4728 to Energy Services Group for adapter indicator for
diesel generator P/N KSV-29-1E
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P0 RS 6874 to Wholesale Electric Supply Company for Square D P/N
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HD0-70 125 VDC relays
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P0 RS 8236 to Arizona Power and Light for a crosshead
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Of the five P0s, only'P0 RS 6874 was established to be applicable to
.a safety-related use; i.e., ESF load sequencers. .This P0 identified
that dedication was-the responsibility.of HL&P and also required the:
vendor to'use its standard QA program and to pass on the requirements
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of the procurement document to lower tier supplies and
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subcontractors. The P0 additionally required certification by the
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vendor to the requirements.of the P0 and also prohibited changes in
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design, process, or material. .The seller was also required to
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identify any char.ges 'in materials of construction, design or
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manufacturing process that have taken place since 1976 and. to provide -
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applicable information with respect to manufacturer's part number,
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vendor's part number.. storage requirements, maintenance frequency,
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shelf life, installed life (usability life), and vendor
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modification / activities performed on the original manufacturer's
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part.
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In response to this P0, the vendor completed en HL&P QA Department
Conformance Certificate which identified the manufacturer's part
number and that there were no deviations from the requirements 'of the
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'P0.
This Conformance Certificate was noted by the NRC inspector to
have been sign _ed by a vendor sales representative.
No information'
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was apparently provided with respect to the other_ criteria contained
in the P0. After review.of the procurement package and discussion;
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'with licensee personnel, it was not apparent that albasis currently
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existed for dedicating these-items that was consistent with the'
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guidance contained in EPRI NP-5652.
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Commercial grade procurement and dedication practices are considered
an unresolved item pending completion of licensee activities in this
area and subsequent NRC inspection.
(498/8916-03; 499/8916-03)'
4.
Receipt. Storage, and Handling of Equipment and Materials Program (38702)
The NRC inspector reviewed the following documents in order to verify that
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administrative controls exist and that they provide measures to assure
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that received materials will be examined for conformance with requirements
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specified in the procurement documents. The documents were reviewed to
verify that acceptance criteria and responsibilities were clearly
established and that requirements for documenting the performance of
receipt inspections were specified.
QCP-1,0, " Receipt Inspection," Revision 3
QCP-6.0, " Receipt / Vendor Inspection Deficiency Reporting,"
Revision 3
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STP-FSAR, Section 17.2.7.1.3, " Receiving Inspection," Amendment 62
Weld Filler Material Matrix dated February 17, 1989
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In_ order to assess the implementation of the program,'the NRC inspector
reviewed all applicable receiving inspection documentation i.e., purchase
orders (P0s), receiving inspection reports, certified' material test
reports, certificates of compliance, heat treatment certificates, and AS*1E
Code Data Reports, pertaining to the following P0s and spare parts for
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- which 10 CFR Part 21 was invoked:
P0 RS 3843 to Westinghouse Electric Corporation for valve 0-rings
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P0 RS 7359 to Anchor Darling Valve Company for a 2-inch, 2500 'lb'.
double disc gate valve and a bonnet assembly
P0 RS 6040 to American Warming and Ventilating, Inc., for a Borg
Warner relay
P0 RS 7167 to Limitorque Corporation for 2 gasket and seal sets
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for Limitorque SMB-1 operators
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P0 RS 10969 to Hub, Inc., for 11, 1-inch X 3-inch all threaded
studs
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P0 RS 9686 to Hub, Inc., for 2, 3-inch, 300 lb. blind flanges
P0 RS 7053 to Power Conversion Products, Inc., for 2 ammeter
shunts used in Class IE battery chargers
While all of the above spare parts had been received, none had been issued
for use; thus all-were available for review in terms of item verification
and storage. The NRC inspector compared the items with the procurement
and receiving inspection documentation. There were no apparent
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discrepancies.
The NRC inspector also reviewed the QC Receipt / Vendor Inspection
Deficiency Report (R/VIDR) Log. This log is maintaired and used to
document deficiencies identified during receipt or vendor inspection
activities, and reflects the status of all R/VIDRs. Ten open R/VIDRS were
selected for review in order to verify that the identified discrepant
parts were properly tagged / marked, and segregated in the established hold
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area. The NRC inspector verified that all of the items identified in the
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10 R/VIDRs were tagged / marked as being discrepant, and were located in the
hold area.
It would appear that the licensee has established and implemented an
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effective program with respect to receiving inspection, storage of
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material / items, and control of nonconforming parts identified during
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receiving inspection.
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There were no violations or deviations identified during this part of the
inspection.
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. Exit Interview
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. An-exitinterviewwasconductedlonJune!9,1989,with.thosepersonnel
idenoted in paragraph 1
At the exit interview, the NRC inspectors
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summarized, the inspection findings. No information was presented to.the
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NRC:-inspectors that was identified by the. licensee as proprietary.s
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