IR 05000498/1978007

Insp Repts 50-498/78-07 & 50-499/78-07 on 780417-20. Noncompliance Noted:Failure to Provide Revised Drawings & Incomplete Insp of Structural Steel Documented as Complete

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: IR 05000498/1977013 IR 05000498/1978001 IR 05000498/1978003 IR 05000498/1978004 IR 05000498/1978007 IR 05000498/1978010 IR 05000498/1980017 ML20150F239 ML20209B066 ML20211E985 ML20211F004 ML20211F025 ML20211F065 ML20211F072 ML20211F096 ML20211F114 ML20211F193 ML20211F216 ML20211F234 ML20211F262 ML20211F280 ML20211F398 ML20211F419 ML20211F435 ML20211F458 ML20211F473 ML20211F489 ML20211F500 ML20211F514 ML20211F518 ML20211F541 ML20211F573 ML20211F578 ML20211F583 ML20211G038
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 REGION I .. .

Report No. 50-498/78-07; 50-499/78-07 ,

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it Occket No. 50-498; 50-499 Category A2 (-

Licensee! Houston Lighting and Power Compary 4 Post Office Box 1700

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- - Houston, Texas 77001 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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N [/ 78 f Inspectors: m ,_

W. G. Hubacek, Reactor Inspector, Projects Section D' ate (Paragraphs 1, 2, 3, 4, 5, 9, 11 & 12)

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h$v &%lm A. B. Rosenberg, Reacto d nspector, Engineering S5-7f Date

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Support Section (Paragraphs 9 & 10)

f WM L. D. Gilbert, Reactor inspector, Engineering 6/S/78 Date

- Support Section (Paragraphs 6, 7 & 8)

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2 Other .

Accompanying Personnel: Ron J. Garcia, Engineering Aide, Engineering Support Section i Approved: /Ym .5/.ShV W. A. Crossman, Chief, Projects Section Date l '

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W-W. A. Crossman, Acting Chief, Engineering Support GW77 Date Section

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8610310184 860930 ,

PDR FOIA PDR GARDE 85-378

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Inspection Surrary:

Insoection on April 17-20,1978 (Recort No. 50-498/78-07;50-499/78-07)

Areas insoected: Routine, unannounced inspection of construction activities

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irc;uding observation of work and review of records related to Unit 2 con-taincent liner erection; observation of work and review of records related b to structural steel erection for Unit 1; observation of work and review of --

records related to concrete placement for Unit 1; observation of work related '

to welding of essential cooling water pipe; review of implementation of g

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i CFR Part 21 requirements; review of status of reported 10 CFR 50.55(e) h The ite ; and follow up on previously identified inspection finding :ll inspection involved seventy-two inspector-hours by three NRC inspector '.

Results: Of the seven areas inspected, no items of noncompliance were

.!: found in five areas, two apparent items of noncompliance were found in two 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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DETAILS 207

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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 1 *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 u

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. *J. 'Salvitti, Assistant Project Manager, Brown & Root (B&R)

(; *S. Rasnick, Project Chief Engineer, B&R

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E *C. W. Vincent, Project QA Manager, B&R

" J. R. Narron, Mechanical QC Supervisor, B&R 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)

f 9, The IE inspectors also interviewed other licensee and contractor employees including members of the QA/QC and engineering staff [ * denotes those attending the exit intervie [ 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

? Testing of Welds. Clarification of the significance of the ultrasonic

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test symbol on Drawing 1459F31 has been provided; however, documenta-

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i tion pertaining to resolution of questions related to weld materials p and the vendor surveillance report concerning Teledyne Brown were not i available for review. This item remains ope (0 pen) Unresolved Item (50-498/78-03-2; 50-499/78-03-2): Documentation 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 by vendors. This item remains ope .

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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 storag : No itens of noncompliance or deviations were identifie . . . .

3 _0 CFR Part 21 Inspection l

' The IE inspector reviewed licensee Part 21 procedures and controls to 4 determine adequacy of provisions for posting, evaluation of deviations,

) infoming the responsible officer, informing the NRC, specification of Part 21 requirerrents in procurement documents, and maintenance of record . Procedures which were reviewed included HL&P Procedure NDP-130 and B&R

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Procedure STP-PM0-02 $. 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

. ;i prominent locations in the site administration buildings and through-

', out the site. Four safety related procurement documents issued since

! January 6,1978, were reviewed and observed to contain appropriate s

specifications that Part 21 provisions apply. The IE inspector was i informed that no Part 21 evaluations have been performed or related

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g reports issued by the licersee to date, No items of noncompliance or deviations were identifie Under-Consolidated Concrete In the Unit 1 Fuel Handling Building

[ } After removal of forms in November 1977, under-consolidated concrete i was found in the bottom surface of the six foot thick slab at

. 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

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pool and as the ceiling for the ECCS pumps cubical area '

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

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inspection, void areas and exposed rebar were discovered. Information 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-I

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dition existed and was considered to be reportable within the context of

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. 10 CFR 50.55(e).

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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,

,' and to determine methods for repair and develop a corrective action a progra The cause is considered to be congestion due to the high density of rebar in the bottom of the slab corbined with inadequate use o.f vibrators by the placing crew during concrete placemen '

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C The licensee has obtained the services of a contractor to determine

.2 the. nethod of repair based on repair qualification tests to be I!- perforced on void areas of the slab. It is anticipated that four

potential methods of repair will be investigated: (1) straight epoxy

'Y injection behind embedded plates; (2) epov injection of preplaced I aggregate; (3) epoxy injection through a sealed surface; and (4)

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 concret .

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6. Containment Dome Liner - Unit No. 1 ,. Records Review 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 -A1 .

The certifications were reviewed for compliance with Specification

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SA 285 Grade A of ASME B&PV Code,Section II, Part ! Observation of Work S The IE inspector observed the welding of the cover pass on the tcp side of Seam B on subassembly S4-8 for compliance with PDM WPS 67-61, Rev. H. The welder was qualified to ASME,Section IX and used E7018 electrode for welding the sea ,', -

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- No items of noncompliance or deviations were identifie . Containment Liner - Unit No. 2 I Records Review

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The IE inspector reviewed the material certification records for the eighth ring liner plates, Pc. Mks. 2159-1 through 2159-1 The certifications were reviewed for compliance with Specification l SA 285 Grade A cf ASME B&PV Code,Section II, Part A.

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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 that the personnel and procedures utilized for welding were qualified to ASME,Section IX requirement k Observation of Work _ .

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

.e K CVT-0 $ No items of noncompliance or deviations were identifie . Essential Cooling Water Pipe - Observation of Work The IE inspector observed'the welding of the first site weldThe joint for pipe

' the 30 inch diameter essential cooling water piping syste ' is made of aluminum bronze material conforming to SB 169, Alloy 614 of A

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ASME,Section II, Part B. The automatic gas tungsten-arc welding process was used for welding the open root butt joint and the joint was, completed

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in three passes (layers). The welding procedure (WP-52.02-859, Rev. 2)

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which uses 0.045 inch diameter ECuAl-A2The (SFA 5.6, F No. 36) was qualified radiographs of.the weld .to the requirenuntsof ASME,Section I I contained areas of lack of penetration and porosity that were rejected by l the Brown and Root Level II inspector. The weld was to be repaired using b -

WP-52.02-791, Rev. 2. The repair procedure, qualified to ASME, Section y IX, uses the gas tungsten-arc welding process and 3/32 or 1/8 inch J,

- RCuAl-A2 weld ro 'p i No items of noncompliance or deviations were identified.

j Concrete Placement in Unit 1 Containment Preplacement Preparation

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.I The IE inspector observed preplacement activities performed on

'f April 17 & 18,1978, related to placement No. CTI-519, S21, 521A, 7 '

S33 and W13 at elevation +19 in the Unit No.1 containmen Specifically observed were condition of forms, prepar The activities l and performance of the preplacement inspection.

l observed were in accordance with B&R Specification 2A010CS028-E i

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and Drawings 1-C-1509-4 and 1-C1571-3; however, four drawings (No.1-C-1509-3,1-C-1510-2,1-C-1511-2 and 1-C-1512-2) in the work area were'obsdNed to be out of dat ;

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The licensee was informed by the IE inspector that the presence

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o of out of date drawings in the work area where they could be ,

used for construction activities was in noncompliance with the l

- requirements of 10 CFR 50, Appendix B, Criterion V . Delivery and Placement

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( The IE inspectors also observed activities related to delivery

,r and placement of concrete at elevation +19 in the Unit N .

U containmen h '

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i Specifically observed were delivery of specified mixes, duration 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, 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

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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 c

work area and the placement was completed without apparent adverse

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effects. During subsequent discussions of the lighting failure, a

licensee representative stated that standby lighting would be made l more readily available for future planned night concrete placement '

- A limited review of placement records was made by the IE inspector c' following the placement; however, not all records had been reviewed

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and approved by appropriate licensee QA/QC personnel. The record L review will be completed during a subsequent inspectio ,

No items of noncompliance or deviations were identifie . Safety Related Structural Steel Observation of Work - Fuel Handling Building  ;

t j The IE inspector observed three bolted joints at elevation +42 feet

' which had been marked at the joint as inspected. (A joint is defined

, as all the connections of all structural members at an intersection.)

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The members involved included:

308 B12 DIV 3A

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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 j The marked up record print and the related inspection reportsActivities a

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were reviewed for the affected joint *

observed were found to be in accordance with B&R Procedure

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QCP- No items of noncompliance or deviations were identifie !.

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- Observation of Work - Reactor Containment Building The IE inspector observed four bolted joints at elevation -2 feet which were marked at the joint as being only partially inspected; I however, review of the marked record print revealed that the inspection of one of the joints had been marked as completed on the drawin Discussion with the QC inspector responsible for inspection of the bolted structural joints within the contain-ment confirmed that the inspection of this joint had not been completed. The members involved included:

103 C17 109 B3 i

177 B3 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 XI ,

The IE inspector also observed that several 64 b

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inspected (only 6 inspected) as. required by Procedure QCP- These joints had not been recorded as having the inspection completed and were subject to further inspection by the license ,

During review of procedures related to structural steel and bolt inspection requirements, the IE inspector determined that The there were no definitions differentiating joints from connection IE inspector was informed by B&R QC that the The two IE terms each had

, two possible meanings and were used interchangeably.

l inspector determined that the lack of definition of terms may l

have contributed to QC inspector's misinterpretation of the inspection requirements for bolted connection B-o b

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The IE inspectoi observed that two QC inspectors were using different rethods for marking bolt inspections on the record prints. One QC inspector marked each connection of a , joint,

!; 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 -

k inspections were complete ,

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) The matter of (1) the inspection requirements for bolted y connections, (2) definition of joints and connections and (3)

method of marking the record prints is an unresolved ite k

Review of Records l':-

The IE inspector reviewed Receiving Inspection Reports and Material Test Reports for members identified in paragraph 1 and 10.b above. These records were found to be in accordance

'- with B&R Specification 3A01055030 and Procedure QCP- %

i'; The qualification records for the two QC inspectors were reviewed

and found to be in accordance with the site Training Manua i No items of noncompliance or deviations were identifie [

. 1 Unresolved Items Unresolved items are matters about which more information is required i' in order to ascertain whether they are acceptable items, items of non-L compliance, or deviations. An unresolved item related to structural steel inspection is discussed in paragraph 1 [ '

[ 1 Exit Interview

I- - The IE inspectors met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on April 20, 1978. The

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• IE inspectors sumarized the purpose. and the scope of the inspection

• 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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NUCLE AR REcuLATERY COMMISSION REGIONIV

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~* *[ 611 RYAN PLAZA DRIVE.SulTE 1000 rj j ]

• 5* .. E ARLINGTON, TEXAS 76011 " ,'

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%*****/ August 22, 1978 In Reply Refer To: -

6 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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RECE1VeD

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Houston Lighting and Power Company gjG 2 -i 19I6

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" ATTN:

Mr. E. A. Turner, Vice President

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Power Plant Construction and E.A. TURNER

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Technical Services

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' Post Office Box 1700 Houston, Texas 77001 t .

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Gentlemen:

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This refers to the investigation conducted 25-28,by Mr. of 1978, J. activities J. Ward and other members of our staff during the period July authorized by NRC Construction Permit Nos. CPPR-128 and 129 for the

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, South Texas Project facility, Units No. I and 2, concerning an allegati

' by a Brown and Root employe ;..

t The investigation and our findings are discussed in the enclosed inve

'. t: gation repor ~{ ' Within the scope of the investigation, no items of noncompliance were g identifie i*

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In Title 2, accordance10, Code of with FederalSection 2.790 of Regulations, the NRC's a copy of this letter " Rules and t

,. M enclosed investigation report will be placed in the NRC's Public Doc l * '. Roo If the report contains any information that you believe to be

"} proprietary, it is necessary that you submit a written application to

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this office, within 20 days of the date of thisThe letter, requesting that application such information be withheld from public disclosur h must include a full statement of the reasons why it is claim

,l infonnation is proprietary.

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>: . any proprietary infonnation If we do not identified hear from you inis contain ll be placed in the Publ'ic Document Room.this regard within th the Public Document Room,

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( < ,: 993 Houston Lighting and Power -2- August 22, 1978

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Company ':' Should you have any questions concerning this investigation ~, we will be pleased to discuss them with yo ..

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

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OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

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Report Nos. 50-498/78-12; 50-499/78-12 U,j Docket No ; 50-499 Category A2

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Licensee: Houston Lighting and Power Company Post Office Box 1700 l}i Houston, Texas 77001

.t Facility Name: South Texas Project, Units 1 and 2 Investigation at: South Texas Project, Matagorda County, Texas

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Investigation conducted: July 25-28, 1978

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Investigator: *M J. J. Ward, Investigation Specialist Date

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', Inspectors: A F/23 hF W. G. Hubacek, Reactor Inspector, Projects Date f Section

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W. A. Crossman, Chief, Projects Section Date (

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Approved by: - -

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)

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Areas Inspected: Special, unannounced investigation of allegations of in-sufficient training for implementation of newly issued procedures; inadequate nonconformance reporting system; reluctance by QA tc issue nonconformance ..

reports; inadequate support of QC inspectors; poor control of QC documents;

- inaccurate as-built drawings; inaccessability of upper management; undue pressure on QC inspectors; performance of repairs without approved proce-

' dures; and inability of construction engineers to perform work. The

',1 investigation involved seventy-two inspector-hours on site by three NRC inspectors.

,I Results: No itets of noncompliance or deviations were identified.

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, INTRODUCTION 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 ~

both Architect Engineer and Constructor for the plan .. , .

REASON FOR INVESTIGATION .

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 progra 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 Projec The employee wished to report alleged irregularities in the civil QA program

- at STP. The allegation involved the following concerns in relation to the STP QA program: Inability of civil QC inspectors to do their jobs due to issuance of new

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procedures withouth sufficient training in the new procedures before

. implementatio . An inadequate nonconformance reporting syste . QA reluctance to issue no'nconformance reports when problems are identified

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. Inadequate support of QC inspectors by Q . Poor document control for drawings and documents used by craft and QC i personne . Inaccurate Cadweld as-built drawings for the Unit 2 fill slab.

l Inaccessability of upper managenent.'

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• Undue pressure from construction on QC inspector . Performance of repairs without approved procedure . Inability of construction engineers to do their jobs in assuring that civil

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,- CONCLUSIONS ( The allegation regarding insufficient training of the civil QC inspectors f

was not substantiated since it is not possible to assess the amount of training required to implement the procedures and the degree of training "

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. The allegation concerning an inadequate nonconformance reporting system p? 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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' The allegation of QA reluctance to issue nonconformance reports when e problems are identified by QC could not be substantiated by specific

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exa;rples . However, generalizations presented by the QC inspectors 4 indicate that this situation could exis . .. The allegation of inadequate support of QC inspectors by the QA engineers was not substantiated by specific example, but the majority of the QC E[. inspectors interviewed stated there was lack of suppor .

S.- Review of the QC document control system and interviews with responsible .

individuals tends to provide support to the allegation of poor document i control of drawings and documents used by QC personnel. However, no b specific examples were provided to actually substantiate the allegatio i

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y' The allegation concerning inaccurate Cadweld as-built drawings for the Unit No. 2 fill slab was thoroughly checked out but could not be sub- .. stantiate Y

};. The allegation of inaccessability to upper management was expressed by a majority of the QC inspector [. The allegation concerning undue pressure from construction on QC inspectors

+ could be valid considering the extensive numbers of items on the QC in-i spector inspection " punch lists."

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',. The allegation of performance of repairs without approved procedures was

' not substantiated. The specific example cited was traced to a FREA which v contained appropriate recommended action, l

1 Although the allegation regarding dhe inability of the construction 1 engineers to do their job could not be wholly substantiated, the exten-a sive number and types of deficiencies contained in the QC inspection " punch lists" suggests the possibility that the inspections by the craft i supervisors and the engineer is, perhaps, less than adequat :

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DETAILS-f . Persons Contacted

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Principal Licensee Employees ..

S. A. Viaclovsky, Project QA Supervisor, HL&P

} T. Stanley, QA Supervisor, HL&P

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Brown & Root, In .

Individuals "A" through "N" Investigation July 25-28, 1978

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4 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 implementatio Findings L Individual "M" stated that he had received no training related to

- the new quality construction procedures prior to their implementa-

tion on June 26, 1978. He also stated that the procedures were

, !. 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

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old procedures. Individual "M" further stated that a meeting with 1i construction for the purpose of discussing the new procedures did

!Y not address the procedures and that a planned orientation for QC inspectors failed to materializ 'e

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Indi vi dual s "B " "C ." "D," "F," "G," "H."

"I ," "J ." "K." "L" and l,

"N" were interviewed by RIV representatives and questioned with

' :. regard to training that had been provided for QC inspectors. In-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-ments contained in the procedures. Individual "N" stated that,

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although he considered the tra'ining to be inadequate, he person-ally had encountered no significant problems with the implementa-

]! 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.

N: Individual "L" stated that he considered the new procedures m and the training provided to be adequate. He further stated -

that no substantive changes were made in the new procedures

and that only minimal training was required prior to implemen-tation.

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, Individual "K" stated that training related to new quality l,

assurance procedures (QAP) was provided for supervisors and i:

lead inspectors on or about June 26, 1978, and training sessions

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related to quality construction procedures were held by con-struction on June 12,13 and 14,1978, for construction and QC personnel . He also stated that training sessions are held once per week by supervisors'who select procedures to be covered and o

determine the priority of training required. Individual "K"

' further stated that a letter issued by the B&R Project QA Manager required all QA/QC personnel to read the new QAPs by July 7,197 ,.

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The RIV representatives reviewed the new quality construction

- 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-

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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-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

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indicated that some QA/QC and construction personnel had attended training related to the new procedures but the adequacy of the training provided could not be ' determine No items of noncompliance or deviations were identifie # Alleoation No. 2 The STP QA program does not provide an adequate nonconformance reporting syste .

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. Findings

$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- ..

.. ciency, but QA issues the NCR. He knew of no instance where there

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j h' was resistance by the QA engineer to issue an NC l:

-lC Individual "D" stated that the NCR procedure ST-QAp-2.6 did not 2 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

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as NCRs, but so many NCRs resulted from this practice that QC in-

- spectors were directed to develop " punch lists" of items which did not conform to plans and specifications. As a consequence, he thought it was difficult to know just when he should write an NC >,- Many of the QC inspectors stated that they had encountered resistance 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

, i advice concerning proposed NCR 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 e reason; the QC inspectors wrote NCRs and were accused of " nit picking";

the QA engineer's interpretation of specifications, codes or standards cancels out the NCR; the QC inspectors' decisions regarding NCRs are 5 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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deficiencie In regard to seeking technical advice concerning problem areas, the E QC inspectors were " warned about going over the supervisor's head."

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-

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ever, the conditions described by the QC inspectors suggest that the NCR reporting system has weaknesse '

No items of noncortpliance or deviations were identifie '

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~ Allegation No. 3 l

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l QA reluctance to issue nonconformance reports when problems are  ;

identified by Q ;

Findings

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Individual "M" stated that QC encounters much resistance from QA

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in processing Nonconformance Reports (NCRs) initiated by QC and that some draft NCRs were not issued nor was QC given reasons why

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they were not issued.

. Indidivuals "B," "F," "G," "I" and "N" stated that they had know-I~ ledge of the initiation of several potential NCRs that were submitted 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 processe <

No objective evidence which would support this allegation could be develope ;

No items of noncompliance or deviations were identifie Allegation No. 4

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Inadequate support of QC inspectors by the QA enginee 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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over the supervisor's head." r

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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 writte 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 reportin No items of noncompliance or deviations were identifie Allegation No. 5 Poor document control for drawings and documents used by craft and QC personne ,

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~D 394 Findings

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Individual "M" stated that distribution of documents (including i FREAs, DCNs drawings) was frequently delaye l p

.: Individual "A" stated that the QA library, which issues documents

to the QC disciplines, has been behind in issuance and recall of -

• documents. Individual "A" stated that the delays had been caused

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by rapid turnover and shortage of trained personnel in the QA J library in addition to delays attributed to equipment failure in 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 curren 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 fiel '

Individual "G" stated that, due to untimely distribution of documents 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-spection 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"

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which serves as his office in the fiel '

Individual "L" stated that issuance of documents by the QA library has not always been timely but the documents are not uncontrolle Field inspectors have assisted in distribution of document Review of the QC document control system and interviews by RIV

- representatives with personnel tended te. support this allegation; however, no specific examples were provided to substantiate the allegation.

No items of noncompliance or deviations were identified.

! Allegation No. 6

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Inaccurate Cadweld as-built drawings for the Unit 2 fill sla I 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

I twice for each of the Cadwelds on the as-built drawing F5Q-0049. The

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'e NRC inspectors reviewed the control copy of FSQ-0049 in the' document

• vault. The allegation could not be substantiate .

Also, Cadweld 27BV819 was purported to be in the fill slab and should

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appear on the as-built drawing, but it was in the lay-down yard. The i-NRC inspectors identified the Cadweld in the lay-down yard, but it 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 drawin I- No items of noncompliance or deviations were identifie .S Allegation No. 7

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Inaccessability of upper managemen Findings Individual "M" stated that QC inspectors were denied access to upper

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management in cases where immediate supervisors were unable to provide adequate resolution of problems identified by the inspector Statements by other QC civil inspectors tended to support this alle-

)' gation; however, no specific examples were provided to substantiate y

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the allegatio ' No items of nonccepliance or deviations were identifie Allegation No. 8 $ There is undue pressure from construction on the QC inspector >

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' Findings 5 '

In regard to the preplacement inspection in accordance with the

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 inspectio *-

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 responsible QC inspector had signed off. This sequence is contrary to Section 3.4 of CCP-3. However, follow up by the NRC inspectors

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revealed that t'he control copy of the Concrete Pour Card contained I

in the records vault was corrected to show the Chief Project Engineer authorizing the pour after the QC inspector had signed off.

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30G 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 and construction engineer are not doing proper in-process inspection f as evidenced by the large number and types of deficiencies found by f,

" the QC inspectors. Also, they stated that the structural and tech-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 the Individual "B" stated that construction criticizes the QC inspectors

' for finding discrepancies after the construction engineer overlooks

- them. He said a statement had been made to the QC inspectors by a construction manager that Brown and Root signs the paychecks and

' , implying QC should not hold up constructio 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 wor 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 inspectio * No items of noncompliance or deviations were identified.

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i. Allegation No. 9 l Performance of repairs without approved procedures.

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Findings

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 procedur 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 repai ,

This allegation'was not substantiate No items of noncompliance or deviations were identifie . . . . . ..

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Allegation No. 10

- Inability of construction engineers to do their jobs in assuring that civil construction was performed in accordance with drawings and procedure J

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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 inspectio They must do this to keep up with the construction schedul ! 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, 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-s taffe ' '

Individual "B" stated that the total inspection reponsibility is v being placed on QC because the construction engineers aren't doing

- their jo He said that it is obvious that the construction engi-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 inspectio Further, he stated, that many of the problems found by QC should F have been found by the engineers because they are technical problem ' 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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!~ 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 correcte Individual "C" stated that discrepancies are brought to the attention of the construction engineer. If the discrepancy cannot be resolved, the QC inspector writes an NCR for QA review.

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Individual "N" stated that all inspection is left to the QC inspector The NRC inspectdrs reviewed several " punch lists" which contained items found during the inspections performed by the QC inspector 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,

,, forms had been removed from a concrete placement to correct dis-

crepancies. The type and magnitude of discrepancies identified

'}f-i suggest the possibility that in-process inspections are inadequat p ..

d No items of noncompliance or deviations were identifie .

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