ML20245F215

Insp Repts 50-498/89-16 & 50-499/89-16 on 890605-09. Violations Noted.Major Areas Inspected:Audit,Procurement & Receipt,Storage & Handling of Equipment Matls Programs

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: ML20245F199 ML20245F212 ML20245F215
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:

NPF-76

50-499/89-16

NPF-78

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

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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

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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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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)'

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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,"

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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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