IR 05000498/1978007
| ML20211F507 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/05/1978 |
| From: | Crossman W, Gilbert L, Hubacek W, Rosenberg A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20150F241 | List:
|
| References | |
| FOIA-85-378 50-498-78-07, 50-498-78-7, 50-499-78-07, 50-499-78-7, NUDOCS 8610310184 | |
| Download: ML20211F507 (9) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION ANO ENFORCEMENT
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REGION IV.
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Report No. 50-498/78-07; 50-499/78-07
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Occket No. 50-498; 50-499 Category A2 Licensee! Houston Lighting and Power Compary Post Office Box 1700
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Houston, Texas 77001
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Facility Name: South Texas Project, Units 1 & 2
' Inspection at: South Texas Project Matagorda County, Texas Inspection conducted: April 17-20,1978
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f Inspectors:
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W. G. Hubacek, Reactor Inspector, Projects Section D' ate (Paragraphs 1, 2, 3, 4, 5, 9, 11 & 12)
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A. B. Rosenberg, Reacto d nspector, Engineering Date
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Support Section (Paragraphs 9 & 10)
f WM 6/S/78 L. D. Gilbert, Reactor inspector, Engineering Date Support Section (Paragraphs 6, 7 & 8)
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2 Other
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Accompanying Personnel:
Ron J. Garcia, Engineering Aide, Engineering Support Section
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Approved:
l W. A. Crossman, Chief, Projects Section Date
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W. A. Crossman, Acting Chief, Engineering Support Date Section
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8610310184 860930
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Inspection Surrary:
17-20,1978 (Recort No. 50-498/78-07;50-499/78-07)
Insoection on AprilRoutine, unannounced inspection of construction activities
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Areas insoected:
irc;uding observation of work and review of records related to Unit 2 con-
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taincent liner erection; observation of work and review of records related to structural steel erection for Unit 1; observation of work and review of b
records related to concrete placement for Unit 1; observation of work related '
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to welding of essential cooling water pipe; review of implementation of g
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10 CFR Part 21 requirements; review of status of reported 10 CFR 50.55(e)
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The h
ite ; and follow up on previously identified inspection findings.
- ll inspection involved seventy-two inspector-hours by three NRC inspectors.
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Of the seven areas inspected, no items of noncompliance were Results:
found in five areas, two apparent items of noncompliance were found in two
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areas (infraction - failure to provide revised drawings - paragraph 9.a; infraction - incomplete inspection of structural steel documented as completed - paragraph 10.b)
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207 DETAILS
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Persons Contacted
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Principal Licensee Erployees
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- F. D. Asbeck, Construction Supervisor
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- W. H. Phillps, Project QA Manager
- S. A. Viaclovsky, QA Supervisor U-
- T. K. Logan, Lead Engineer j(-
- L. D. Wilson, Lead Specialist
'5 M. M. Johnson, Senior Engineer-T. J. Jordan, Associate Engineer
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D. C. Douglas, QA Specialist
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Other Personnel
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- J. 'Salvitti, Assistant Project Manager, Brown & Root (B&R)
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- S. Rasnick, Project Chief Engineer, B&R
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- C. W. Vincent, Project QA Manager, B&R
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J. R. Narron, Mechanical QC Supervisor, B&R
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R. S. Rogoski, Welding Engineer, B&R i
A. J. Hammons, Civil QC Supervisor, B&R T. J. Foley, Site QA Manager, Pittsburgh Des Moines Steel (PDM)
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The IE inspectors also interviewed other licensee and contractor f.
employees including members of the QA/QC and engineering staffs.
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2.
Licensee Action on Previous Inspection Findinas
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(0 pen) Unresolved Item (50-498/78-03-1; 50-499/78-03-1): Ultrasonic
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Testing of Welds. Clarification of the significance of the ultrasonic
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test symbol on Drawing 1459F31 has been provided; however, documenta-i tion pertaining to resolution of questions related to weld materials
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and the vendor surveillance report concerning Teledyne Brown were not p
i available for review. This item remains open.
(0 pen) Unresolved Item (50-498/78-03-2; 50-499/78-03-2): Documentation
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Packages for Class IE Electrical Cable. The IE inspector observed that action to resolve this item was in progress.
Form 200.59 will remain essentially as is, but means will be provided for each specification to better delineate the documentation that is to be provided to the site
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by vendors. This item remains open.
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Site Tour
The IE inspectors walked through various areas of the site to observe j'
construction activities in progress and to inspect housekeeping and
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equipnent storage.
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No itens of noncompliance or deviations were identified.
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4.
1_0 CFR Part 21 Inspection l'J.
The IE inspector reviewed licensee Part 21 procedures and controls to
determine adequacy of provisions for posting, evaluation of deviations,
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infoming the responsible officer, informing the NRC, specification of Part 21 requirerrents in procurement documents, and maintenance of records.
Procedures which were reviewed included HL&P Procedure NDP-130 and B&R
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Procedure STP-PM0-022.
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During inspection of the implementation of the established procedures,
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the IE inspector observed that Part 21 notices were posted in several
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out the site.
Four safety related procurement documents issued since
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January 6,1978, were reviewed and observed to contain appropriate specifications that Part 21 provisions apply. The IE inspector was s
i informed that no Part 21 evaluations have been performed or related reports issued by the licersee to date,
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g No items of noncompliance or deviations were identified.
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5.
Under-Consolidated Concrete In the Unit 1 Fuel Handling Building
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After removal of forms in November 1977, under-consolidated concrete i
was found in the bottom surface of the six foot thick slab at
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El+21'll" in the Unit 1 Fuel Handling Building. The slab, which was
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placed September 16 & 17, 1977, serves as the base for the spent fuel pool and as the ceiling for the ECCS pumps cubical areas.
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Initial investigation of the slab in November 1977, revealed localized i
areas of under-consolidated concrete which were not at that time considered to be reportable. As a result of chipping and further inspection, void areas and exposed rebar were discovered.
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concerning this deficiency was identified by a Deficiency and Disposition Report and a Field Request for Engineering Action dated March 8 and March 1, respectively. An analysis of the deficiency concluded that it l
could have adversely affected the safety of the plant if it were to remain uncorrected and that extensive repairs would be required to establish the capability of the slab to perform its intended safety function. The l
Region IV office of the NRC was notified on March 15, 1978, that this con-dition existed and was considered to be reportable within the context of I
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Extensive evaluation has been done to identify the cause and extent
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of the deficiency, to analyze the condition and safety implications,
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and to determine methods for repair and develop a corrective action
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The cause is considered to be congestion due to the high a
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density of rebar in the bottom of the slab corbined with inadequate use o.f vibrators by the placing crew during concrete placement.
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C The licensee has obtained the services of a contractor to determine
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perforced on void areas of the slab.
It is anticipated that four potential methods of repair will be investigated: (1) straight epoxy
injection behind embedded plates; (2) epov injection of preplaced
'Y aggregate; (3) epoxy injection through a sealed surface; and (4)
I epoxy mortar and epoxy bonding agent used in conjunction with shot-crete. The test areas will be cored and cores evaluated to determine the most suitable method of repair. Services of another contracter
to measure the shielding capability of the slab are being considered
'c since the epoxy grout to be used in the repair does not possess the i
same density as the original concrete.
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Containment Dome Liner - Unit No. 1
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Records Review
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l The IE inspector reviewed the material certification records for
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the dome liner subassembly S4-8, Pc. Mks'.196R4-A3, -All and -A16.
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The certifications were reviewed for compliance with Specification
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SA 285 Grade A of ASME B&PV Code,Section II, Part A.
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Observation of Work S
The IE inspector observed the welding of the cover pass on the f.
tcp side of Seam B on subassembly S4-8 for compliance with PDM
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WPS 67-61, Rev. H.
The welder was qualified to ASME,Section IX and used E7018 electrode for welding the seam.
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No items of noncompliance or deviations were identified.
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Containment Liner - Unit No. 2 I
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Records Review The IE inspector reviewed the material certification records for the eighth ring liner plates, Pc. Mks. 2159-1 through 2159-14.
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407, 408, The weld history records for six liner seam welds (seams
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409, 410, 411 and 414 on Dwg. E6AE/H) were reviewed for confirmation
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that the personnel and procedures utilized for welding were qualified
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to ASME,Section IX requirements.
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Observation of Work _
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b The IE inspector observed the fit-up and evidence of QC inspection
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for horizontal seams 120 and 121. Fit-up conformed to PDM Procedure
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CVT-01.
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No items of noncompliance or deviations were identified.
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Essential Cooling Water Pipe - Observation of Work 8.
The IE inspector observed'the welding of the first site weld joint for The pipe the 30 inch diameter essential cooling water piping system.
is made of aluminum bronze material conforming to SB 169, Alloy 614 of
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The automatic gas tungsten-arc welding process
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ASME,Section II, Part B.
was used for welding the open root butt joint and the joint was, completed
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A in three passes (layers). The welding procedure (WP-52.02-859, Rev. 2)
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which uses 0.045 inch diameter ECuAl-A2 (SFA 5.6, F No. 36) was qualified
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The radiographs of.the weld h.
.to the requirenuntsof ASME,Section IX.
contained areas of lack of penetration and porosity that were rejected by I
the Brown and Root Level II inspector. The weld was to be repaired using l
WP-52.02-791, Rev. 2.
The repair procedure, qualified to ASME, Section b
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y IX, uses the gas tungsten-arc welding process and 3/32 or 1/8 inch J,
RCuAl-A2 weld rod.
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9.
Concrete Placement in Unit 1 Containment
Preplacement Preparation
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The IE inspector observed preplacement activities performed on
.I related to placement No. CTI-519, S21, 521A,
'f April 17 & 18,1978,
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S33 and W13 at elevation +19 in the Unit No.1 containment.
Specifically observed were condition of forms, prepa The activities and performance of the preplacement inspection.
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observed were in accordance with B&R Specification 2A010CS028-E and Drawings 1-C-1509-4 and 1-C1571-3; however, four drawings i
(No.1-C-1509-3,1-C-1510-2,1-C-1511-2 and 1-C-1512-2) in the
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work area were'obsdNed to be out of date.
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The licensee was informed by the IE inspector that the presence
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of out of date drawings in the work area where they could be
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o used for construction activities was in noncompliance with the requirements of 10 CFR 50, Appendix B, Criterion VI.
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Delivery and Placement
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The IE inspectors also observed activities related to delivery and placement of concrete at elevation +19 in the Unit No.1
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containment.
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of mixing and transporting, temperature control, testing, adequacy of placing crews, and inspection during placement. The observed activities were in accordance with B&R Specifications 2A010CS027-E,
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2A010CS028-E and 2A01CS001-F and B&R Procedure ST-QCP-4.4; however, the IE inspectors observed that on April 18, 1978, night shift f-operations were delayed approximately one hour when an electrical i
lighting circuit failed. Lighting was restored by the use of
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portable lighting units which were obtained from the site ' reservoir work area and the placement was completed without apparent adverse c
effects. During subsequent discussions of the lighting failure, a
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licensee representative stated that standby lighting would be made
l more readily available for future planned night concrete placements.
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A limited review of placement records was made by the IE inspector
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following the placement; however, not all records had been reviewed
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and approved by appropriate licensee QA/QC personnel. The record
review will be completed during a subsequent inspection.
L No items of noncompliance or deviations were identified.
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Safety Related Structural Steel a.
Observation of Work - Fuel Handling Building
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The IE inspector observed three bolted joints at elevation +42 feet which had been marked at the joint as inspected.
(A joint is defined
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as all the connections of all structural members at an intersection.)
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The members involved included:
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308 B12 DIV 3A
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!l 308 B12 DIV 4A 308 B5-1 DIV 3A
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309 B14 DIV 3A
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309 B13-2 DIV 4A
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309 B6-2 DIV 4A
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The marked up record print and the related inspection reportsActivities a j
were reviewed for the affected joints.
observed were found to be in accordance with B&R Procedure
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QCP-4.5.
No items of noncompliance or deviations were identified.
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Observation of Work - Reactor Containment Building I
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The IE inspector observed four bolted joints at elevation -2 feet which were marked at the joint as being only partially inspected; however, review of the marked record print revealed that the I
inspection of one of the joints had been marked as completed on Discussion with the QC inspector responsible for inspection of the bolted structural joints within the contain-the drawing.
ment confirmed that the inspection of this joint had not been completed. The members involved included:
103 C17 109 B3 177 B3 i
The IE inspector informed the licensee that marking the record print to indicate that the inspection of the joint was completed when the inspection was not completed is in noncompliance with 10 CFR 50, Appendix B, Criterion XIV.
The IE inspector also observed that several 64
inspected (only 6 inspected) as. required by Procedure QCP-4.5.
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These joints had not been recorded as having the inspection completed and were subject to further inspection by the licensee.
During review of procedures related to structural steel and bolt
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inspection requirements, the IE inspector determined that there The were no definitions differentiating joints from connections.
IE inspector was informed by B&R QC that the two terms each had The IE two possible meanings and were used interchangeably.
inspector determined that the lack of definition of terms may
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inspection requirements for bolted connections.
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The IE inspectoi observed that two QC inspectors were using different rethods for marking bolt inspections on the record
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prints. One QC inspector marked each connection of a, joint,
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the other marked the whole joint when it was complete. The IE inspector obser.ved that using two methods to mark prints
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caused. confusion when reviewing the prints to determine if
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The matter of (1) the inspection requirements for bolted connections, (2) definition of joints and connections and (3)
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method of marking the record prints is an unresolved item.
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Review of Records l':-
The IE inspector reviewed Receiving Inspection Reports and Material Test Reports for members identified in paragraph 10.a
and 10.b above. These records were found to be in accordance
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with B&R Specification 3A01055030 and Procedure QCP-1.1.
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The qualification records for the two QC inspectors were reviewed
and found to be in accordance with the site Training Manual.
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No items of noncompliance or deviations were identified.
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Unresolved Items C.
Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-i'
compliance, or deviations. An unresolved item related to structural L
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steel inspection is discussed in paragraph 10.b.
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12.
Exit Interview
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The IE inspectors met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on April 20, 1978. The IE inspectors sumarized the purpose. and the scope of the inspection
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and the findings. A licensee representative acknowledged the state-
ments of the IE inspector concerning the items of noncompliance (para-
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graphs 9.a and 10.b) and the unresolved item (paragraph 10.b).
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UNITES STATES i-
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".*,***. * * g**H4(4 NUCLE AR REcuLATERY COMMISSION 0*
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REGIONIV
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611 RYAN PLAZA DRIVE.SulTE 1000 rj j
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.. E ARLINGTON, TEXAS 76011
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August 22, 1978 g-
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In Reply Refer To:
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RIV ST-AE-HL-564 i
Docket Nos. 50-498/78-12 SFN: C-0570
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50-499/78-12
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Houston Lighting and Power Company Mr. E. A. Turner, Vice President gjG 2 -i 19I6
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t" ATTN:
Power Plant Construction and E.A. TURNER
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Technical Services
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Post Office Box 1700 r.
Houston, Texas 77001 t i.
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Gentlemen:
This refers to the investigation conducted by Mr. J. J. Ward and other
25-28, 1978, of activities
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members of our staff during the period July
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by NRC Construction Permit Nos. CPPR-128 and 129 for the
.i South Texas Project facility, Units No. I and 2, concerning an allegat authorized
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by a Brown and Root employee.
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The investigation and our findings are discussed in the enclosed inve
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gation report.
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Within the scope of the investigation, no items of noncompliance were
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identified.
In accordance with Section 2.790 of the NRC's " Rules g
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2, Title 10, Code of Federal Regulations, a copy of this letter and t
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enclosed investigation report will be placed in the NRC's Public Doc
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proprietary, it is necessary that you submit a written application to Room.
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this office, within 20 days of the date of this letter, requesting that The application such information be withheld from public disclosure.
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must include a full statement of the reasons why it is claim
,l any proprietary infonnation identified is contain infonnation is proprietary.
l:j If we do not hear from you in
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be placed in the Publ'ic Document Room.this regard within th ll the Public Document Room,
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Houston Lighting and Power-2-August 22, 1978 Company
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Should you have any questions concerning this investigation ~, we will
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be pleased to discuss them with you.
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Sincerely,
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W. C. Seid1'e Chief Reactor con uction and Engineeri Support Branch Enclosure:
IE Investigation Report Nos. 50-498/78-12
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50-499/78-12
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'j U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION IV
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Report Nos. 50-498/78-12; 50-499/78-12 U,j
'6 Docket Nos.
50-498; 50-499 Category A2
'0 Licensee:
Houston Lighting and Power Company
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Post Office Box 1700 l}i Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2
.t Investigation at: South Texas Project, Matagorda County, Texas
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Investigation conducted: July 25-28, 1978 4.
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8/MM Investigator:
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J. J. Ward, Investigation Specialist Date
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Inspectors:
f W. G. Hubacek, Reactor Inspector, Projects Date
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W. A. Crossman, Chief, Projects Section Date
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Approved by:
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Date W. A. Crossman, Chief, Projects Section E
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Investigation Summary:
i Investigation on July 25-28, 1978 (Report No. 50-498/78-12; 50-499/78-12)
Areas Inspected: Special, unannounced investigation of allegations of in-
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sufficient training for implementation of newly issued procedures; inadequate nonconformance reporting system; reluctance by QA tc issue nonconformance
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reports; inadequate support of QC inspectors; poor control of QC documents; inaccurate as-built drawings; inaccessability of upper management; undue
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pressure on QC inspectors; performance of repairs without approved proce-dures; and inability of construction engineers to perform work. The
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',1 investigation involved seventy-two inspector-hours on site by three NRC inspectors.
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Results: No itets of noncompliance or deviations were identified.
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INTRODUCTION
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The South Texas Project, Units No.1 and 2, are under construction in Matagorda County, Texas near the town of Wadsworth Texas. Houston Lighting and Power
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Company is the Construction Permit holder. Brown and Root, Incorporated is
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both Architect Engineer and Constructor for the plant.
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REASON FOR INVESTIGATION e.
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The Region IV Project Inspector for STP received a telephone call from an STP employee who reported an alleged breakdown in the STP civil QA program.
SUMMARY OF FACTS
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On July 19, 1978, the RIV Project Inspector received a telephone call from an individual who identified himself as an employee at the South Texas Project.
The employee wished to report alleged irregularities in the civil QA program at STP. The allegation involved the following concerns in relation to the
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1.
Inability of civil QC inspectors to do their jobs due to issuance of new procedures withouth sufficient training in the new procedures before
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implementation.
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An inadequate nonconformance reporting system.
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QA reluctance to issue no'nconformance reports when problems are identified by QC,
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Inadequate support of QC inspectors by QA.
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Poor document control for drawings and documents used by craft and QC i
personnel.
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Inaccurate Cadweld as-built drawings for the Unit 2 fill slab.
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Inaccessability of upper managenent.'
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Undue pressure from construction on QC inspectors.
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Performance of repairs without approved procedures.
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Inability of construction engineers to do their jobs in assuring that civil
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construction was performed in accordance with drawings and procedures.
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CONCLUSIONS
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The allegation regarding insufficient training of the civil QC inspectors (
1.
was not substantiated since it is not possible to assess the amount of f
training required to implement the procedures and the degree of training
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that was actually provided.
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2.
The allegation concerning an inadequate nonconformance reporting system
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was not substantiated by specific example. The conditions described by h
the QC inspectors suggest that the reporting system has weaknesses.
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3.
The allegation of QA reluctance to issue nonconformance reports when
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problems are identified by QC could not be substantiated by specific e
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exa;rples. However, generalizations presented by the QC inspectors indicate that this situation could exist.
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The allegation of inadequate support of QC inspectors by the QA engineers 1...
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was not substantiated by specific example, but the majority of the QC E[.
inspectors interviewed stated there was lack of support.
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Review of the QC document control system and interviews with responsible 5.
individuals tends to provide support to the allegation of poor document r.
i control of drawings and documents used by QC personnel. However, no b
specific examples were provided to actually substantiate the allegation.
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The allegation concerning inaccurate Cadweld as-built drawings for the y'
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Unit No. 2 fill slab was thoroughly checked out but could not be sub-t.
stantiated.
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Y The allegation of inaccessability to upper management was expressed by
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a majority of the QC inspectors.
The allegation concerning undue pressure from construction on QC inspectors 8.
could be valid considering the extensive numbers of items on the QC in-
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spector inspection " punch lists."
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't The allegation of performance of repairs without approved procedures was
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9.
not substantiated. The specific example cited was traced to a FREA which
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contained appropriate recommended action, v
l Although the allegation regarding dhe inability of the construction
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engineers to do their job could not be wholly substantiated, the exten-sive number and types of deficiencies contained in the QC inspection a
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" punch lists" suggests the possibility that the inspections by the craft i
supervisors and the engineer is, perhaps, less than adequate.
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- f DETAILS i.
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Persons Contacted
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Principal Licensee Employees
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S. A. Viaclovsky, Project QA Supervisor, HL&P T. Stanley, QA Supervisor, HL&P Brown & Root, Inc.
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Individuals "A" through "N" 2.
Investigation July 25-28, 1978
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a.
Allegation No. 1
k Inability of QC inspectors to do their jobs due to issuance of new quality construction procedures without sufficient training in the f
new procedures before implementation.
Findings L
Individual "M" stated that he had received no training related to the new quality construction procedures prior to their implementa-
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tion on June 26, 1978. He also stated that the procedures were
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implemented by delivery of new procedures to QC personnel at
'F 10:30 a.m. on June 26, 1978, followed by immediate recall of the Individual "M" further stated that a meeting with old procedures.
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construction for the purpose of discussing the new procedures did 1i not address the procedures and that a planned orientation for QC
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inspectors failed to materialize.
, 'e Indi vi dual s "B " "C." "D," "F," "G," "H." "I," "J."
"K." "L" and l,
"N" were interviewed by RIV representatives and questioned withIn-
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regard to training that had been provided for QC inspectors.
dividuals "B," "D,"
"F," "G," "H" and "I" stated that training
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related to the new procedures was inadequate and that they had experienced difficulties in following the documentation require-
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ments contained in the procedures.
Individual
"N" stated that, although he considered the tra'ining to be inadequate, he person-
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ally had encountered no significant problems with the implementa-
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tion of the new procedures.
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Individuals "C" and "J" stated that they had been able to
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review the new procedures prior to implementation and had not
encountered any significant problems.
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Individual "L" stated that he considered the new procedures and the training provided to be adequate. He further stated m
that no substantive changes were made in the new procedures
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and that only minimal training was required prior to implemen-tation.
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Individual "K" stated that training related to new quality
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assurance procedures (QAP) was provided for supervisors and l,
lead inspectors on or about June 26, 1978, and training sessions i:
related to quality construction procedures were held by con-struction on June 12,13 and 14,1978, for construction and QC
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personnel. He also stated that training sessions are held once per week by supervisors'who select procedures to be covered and determine the priority of training required.
Individual "K" further stated that a letter issued by the B&R Project QA Manager o
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required all QA/QC personnel to read the new QAPs by July 7,1978.
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The RIV representatives reviewed the new quality construction
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procedures and documentation of the training provided to con-struction and QA/QC personnel.
It was observed that the new set
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of quality construction procedures integrates requirements previ-ously contained in two separate sets of procedures used by the
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construction and QA/QC departments. The inspection requirements
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contained in the new procedures appear to be substantially the
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same as those contained in the old procedures; however, documen-
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tation requirements for inspection of concrete preplacement and placement activities have been changed. The format used to docu-ment inspection of concrete placements has been revised and expand-ed from 28 to 64 items. This expansion of inspection items and the
new format apparently contributed to the difficulties described by some of the QC inspectors who were interviewed. Training records indicated that some QA/QC and construction personnel had attended training related to the new procedures but the adequacy of the
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training provided could not be ' determined.
No items of noncompliance or deviations were identified.
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Alleoation No. 2 The STP QA program does not provide an adequate nonconformance reporting system.
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Findings
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$2 Individual "L" stated that the old method of reporting deficiencies by Deficiency and Disposition Report (DDR) had been eliminated and a new, single purpose form, Nonconformance Report (NCR), was now j-being utilized. He also stated that anyone could identify a deft-
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ciency, but QA issues the NCR. He knew of no instance where there
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was resistance by the QA engineer to issue an NCR.
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-lC Individual "D" stated that the NCR procedure ST-QAp-2.6 did not
offer specific enough guidance for issuance of NCRs. He presented as an example, the prepour activities covered on the " Concrete Pour j.i Card" of CCP-3, Rev. 8, 5/15/78. He stated that original oral
guidance was to report all deficiencies detected by the QC inspectors as NCRs, but so many NCRs resulted from this practice that QC in-
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spectors were directed to develop " punch lists" of items which did
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not conform to plans and specifications. As a consequence, he F.
thought it was difficult to know just when he should write an NCR.
Many of the QC inspectors stated that they had encountered resistance
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by the QA engineer to process NCRs. Several QC inspectors were of the opinion that the QA engineer was not technically competent to assess deficiencies and he could not give the QC inspectors technical
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advice concerning proposed NCRs.
L, Individuals
"F," "G,"
"I," "M" and "N" made statements regarding NCRs to the effect that, they had written NCRs which were rejected for no
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reason; the QC inspectors wrote NCRs and were accused of " nit picking";
e the QA engineer's interpretation of specifications, codes or standards
cancels out the NCR; the QC inspectors' decisions regarding NCRs are overridden by the QA engineer; and there are occasions when QC in-
I spectors are instructed not to submit NCRs when they point out valid
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deficiencies.
In regard to seeking technical advice concerning problem areas, the QC inspectors were " warned about going over the supervisor's head."
E The NRC inspectors reviewed several of the examples cited in the area of improper treatment of deficiencies. The NRC inspectors could not substantiate, by review of documentation or direct obser-vation, the specific examples presented by the QC inspectors. How-ever, the conditions described by the QC inspectors suggest that the
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NCR reporting system has weaknesses.
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No items of noncortpliance or deviations were identified.
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Allegation No. 3 l
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QA reluctance to issue nonconformance reports when problems are
identified by QC.
Findings
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Individual "M" stated that QC encounters much resistance from QA in processing Nonconformance Reports (NCRs) initiated by QC and I.
that some draft NCRs were not issued nor was QC given reasons why
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they were not issued.
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Indidivuals "B,"
"F," "G," "I" and "N" stated that they had know-I~
ledge of the initiation of several potential NCRs that were submitted
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to QA for processing but were rejected by QA.
It was stated that in many cases the reasons for rejection were not comunicated to the initiators of the NCRs.
It was also stated that there was no feed-back.to the initiator on the status of NCRs that were processed.
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No objective evidence which would support this allegation could be developed.
No items of noncompliance or deviations were identified.
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Allegation No. 4 Inadequate support of QC inspectors by the QA engineer.
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Findings The civil QC inspectors agreed in majority that there was a lack of technical assistance provided by the on-site QA engineer. The QC inspectors had contacted the QA engineer in Houston several times for technical assistance, but had been cautioned against " going
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r over the supervisor's head."
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Individual "F" pointed out that the on-site QA engineer was respon-sible for procedure revision which he considered to be poorly written.
As pointed out in the Findings of Allegation No. 2, five QC inspectors stated that they were not recei;ving proper support from the QA engineer in regard to NCR reporting.
No items of noncompliance or deviations were identified.
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Allegation No. 5 Poor document control for drawings and documents used by craft and QC personnel.
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Findings
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Individual "M" stated that distribution of documents (including i
FREAs, DCNs drawings) was frequently delayed.
p Individual "A" stated that the QA library, which issues documents to the QC disciplines, has been behind in issuance and recall of
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documents.
Individual "A" stated that the delays had been caused
by rapid turnover and shortage of trained personnel in the QA library in addition to delays attributed to equipment failure in
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J the site document control center (DCC).
Individual "A" also stated that the backlog of documents in the QA library has been eliminated and that distribution is now current.
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Individual "D" stated that shortage of experienced personnel in the QA library was the major factor which caused delays in the distri-bution of documents to QC inspectors in the field.
Individual "G" stated that, due to untimely distribution of documents
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through the QA library, he has gone to construction or the DCC for the latest issues of documents that he needed to perform his in-spections.
Individual "I" stated that document control at his duty station is
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difficult due to_ adverse conditions which exist at his " gang box" which serves as his office in the field.
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Individual "L" stated that issuance of documents by the QA library
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has not always been timely but the documents are not uncontrolled.
Field inspectors have assisted in distribution of documents.
Review of the QC document control system and interviews by RIV representatives with personnel tended te. support this allegation;
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however, no specific examples were provided to substantiate the allegation.
No items of noncompliance or deviations were identified.
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Allegation No. 6 Inaccurate Cadweld as-built drawings for the Unit 2 fill slab.
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I Findings I
Specifically, it was alleged that four Cadwelds which were installed in the Unit No. 2 fill slab had been duplicated. That is, the identi-fication number for the four Cadwelds in actuality should have appeared j
twice for each of the Cadwelds on the as-built drawing F5Q-0049. The I
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NRC inspectors reviewed the control copy of FSQ-0049 in the' document
'e vault. The allegation could not be substantiated.
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Also, Cadweld 27BV819 was purported to be in the fill slab and should
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The appear on the as-built drawing, but it was in the lay-down yard.
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NRC inspectors identified the Cadweld in the lay-down yard, but it i-
did not appear on the as-built drawing.
It was observed that this
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specific Cadweld had been written over on the as-built drawing.
I-No items of noncompliance or deviations were identified.
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Allegation No. 7
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Inaccessability of upper management.
Findings
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Individual "M" stated that QC inspectors were denied access to upper management in cases where immediate supervisors were unable to provide 4.
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adequate resolution of problems identified by the inspectors.
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Statements by other QC civil inspectors tended to support this alle-
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gation; however, no specific examples were provided to substantiate the allegation.
,,y No items of nonccepliance or deviations were identified.
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Allegation No. 8
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There is undue pressure from construction on the QC inspectors.
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Findings
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-5 In regard to the preplacement inspection in accordance with the
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Concrete Pour Card (see Findings, Allegation No. 2), several of the
QC inspectors produced " punch lists" and stated that, in some cases,
neither the craft supervisor nor the Senior Discipline Engineer (or
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his representative) would sign the Concrete Pour Card until the respective Quality Control Inspector had completed his inspection.
The NRC inspectors were provided with a copy of a Concrete Pour Card which had been signed off by the Chief Project Engineer before the
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responsible QC inspector had signed off. This sequence is contrary However, follow up by the NRC inspectors to Section 3.4 of CCP-3.
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revealed that t'he control copy of the Concrete Pour Card contained
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in the records vault was corrected to show the Chief Project Engineer I
authorizing the pour after the QC inspector had signed off.
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Individuals "B " "C," "D,"
"I," "M" and "N" stated that the burden
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of all inspection is on the QC inspector. The craft supervisor
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f and construction engineer are not doing proper in-process inspection f,
as evidenced by the large number and types of deficiencies found by the QC inspectors. Also, they stated that the structural and tech-
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nical problems should have been identified by the engineer prior to the QC inspection. The QC inspectors pointed out that this practice
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greatly increases the workload placed on them.
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Individual "B" stated that construction criticizes the QC inspectors
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them. He said a statement had been made to the QC inspectors by a
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construction manager that Brown and Root signs the paychecks and implying QC should not hold up construction.
Individual "M" stated that as soon as construction signs off the
" Concrete Pour Card," they expect QC to sign right away. They do not want to allot QC any time for inspection after construction is through with the erection work.
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The NRC inspectors reviewed several " punch lists" provided by the QC inspectors. The lists contain an excessive number of items for which corrective action should have been initiated prior to the QC inspection.
No items of noncompliance or deviations were identified.
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Allegation No. 9 l
Performance of repairs without approved procedures.
Findings
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Individual "M" stated that B&R construction frequently works without
procedures. He cited a specific example wherein construction was alleged to have attempted to repair misaligned anchor bolts for waste monitor tanks located in the Unit 1 Mechanical Auxiliary Building (MEA) without a repair procedure.
The RIV representatives observed that Field Request for Engineering Action (FREA) No. 1-C-1298, dated July ll, 1978, was issued with regard to the waste monitor tank anchor bolts. The FREA contained a description of the problem and the recommended disposition includ-ing the method of repair.
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This allegation'was not substantiated.
No items of noncompliance or deviations were identified.
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Allegation No. 10
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Inability of construction engineers to do their jobs in assuring that civil construction was performed in accordance with drawings and procedures.
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Findings
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Individual "D" stated that construction engineers are not able to keep up with their work because they are severely undermanned. Can-y sequently, they rely on QC to complete the whole scope of inspection.
They must do this to keep up with the construction schedule.
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Individual "M" stated that the construction engineers are not per-forming in-process inspection. Consequently, this puts an extra burden on the QC inspectors because the QC inspectors must do the in-process inspection and the final acceptance inspection. Usually,
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there are very many discrepant items. The bulk of the inspection
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t-is left to QC because the construction engineer group is under-
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s taffed.
Individual "B" stated that the total inspection reponsibility is being placed on QC because the construction engineers aren't doing v
their job.
He said that it is obvious that the construction engi-
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e neers are not doing in-process inspection because of the large
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number and magnitude of deficiencies found during the QC inspection.
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Further, he stated, that many of the problems found by QC should F
have been found by the engineers because they are technical problems.
Also, the majority of the FREAs issued result from the QC inspection
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so it appears as though the construction engineers are not knowledge-
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able.
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Individual "I" stated in regard to the allegation that problems he is finding should have been identified during construction.
If you wait until the construction is complete and find the problem during acceptance inspection, time is lost and there is pressure to get the problems corrected.
Individual "C" stated that discrepancies are brought to the attention
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of the construction engineer.
If the discrepancy cannot be resolved, i
the QC inspector writes an NCR for QA review.
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Individual "N" stated that all inspection is left to the QC inspectors.
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The NRC inspectdrs reviewed several " punch lists" which contained items found during the inspections performed by the QC inspectors.
Many of the items were observed to be of a type which could have
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been identified and corrected during the erection process. The
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NRC inspectors also noted that, at the time of the investigation,
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forms had been removed from a concrete placement to correct dis-
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crepancies. The type and magnitude of discrepancies identified
'}f suggest the possibility that in-process inspections are inadequate.
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d No items of noncompliance or deviations were identified.
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