IR 05000498/1979003

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Ack Receipt of Informing NRC of Steps Taken to Corect Violations Noted in IE Insp Repts 50-498/79-03 & 50-499/79-03
ML20150F130
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/26/1979
From: Seidle W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Eric Turner
HOUSTON LIGHTING & POWER CO.
Shared Package
ML20150F134 List:
References
NUDOCS 7905240686
Download: ML20150F130 (1)


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UNITE 0 STATES / * #. '!

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.[ Se nercq'o NUCLE A7 CE!ULAT!SY COMMISSION ]g (

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  • S11 RYAN PLAZA DRIVE, SUITE 1000

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  • * AR LINGTON, TEXAS 70011 g, * * " * j April 26, 1979 In Reply Refer To:

RIV Docket No. 50-498/Rpt. 79-03 ST-AE-HL- 583

, 50-499/Rpt. 79-03 SFN: C-0570

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Houston Lighting and Power Company ATTN
Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700

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Houston, Texas 77001 4- Gentlemen:

'e-Thank you for your letter of April 3,1979, in response to our letter

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dated March 14, 1979, and the attached Notice of Violation. We have

. no further questions at this time and we will review your corrective

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action during a future inspection.

Sincerely,

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, ; W. C. Seid1, Chief 1- Reactor Con uction and ji Engineering Support Branch

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f " UNITEO STATES

NUCLEAR CEIULATZY COMMISSION  ;

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REGION IV

RECEIVED

, F l. o sit RYAN PLAZA DRIVE,SulTE 1000

  • Is ARLINGTON, TEXAS 76011

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  • ..** May 1, 1979 E. A,Ipagg DEEDIATE ACTION LETTER pd In Reply Refer to:

RIV Docket No. 50-498 50-499 ST-AE-HL-584 SFN: C-0570

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Houston Lighting and Power Company P- -

ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and p' '

  • Technical Services Post Office Box 1700 l

Houston, Texas 77001 L n sumta

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Gentlemen:

This refers to the telephone conversations between Mr. R. A. Frazar, and Mr. W. of this office, on April 26 and 27,1979, concerning improper storage of reinforcing steel at the South Texas Project. As you know, improper storage of reinforcing steel was identified earlier this year (See IE Inspection Report No. 498-499,79-03) and, during a recent inspection, the situation was found to have worsened.

Based on the April 26 and 27 telephone conversations, we understand that

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you have:

1. Verified, by inspection of reinforcing steel storage areas on f

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April 27, 1979, that no significant departures exist from reinforcing steel storage requirements specified in site Quality Construction Procedures.

2. Provided additional training for craft and quality personnel concerning reinforcing steel storage requirements.

3. Increased the frequency of quality control inspections and quality assurance surveillance of reinforcing steel storage areas.

4. Assigned additional personnel to the maintenance of reinforcing steel storage areas, and ordered additional timber for use in the .. . . .

storage areas. .

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Houston Lighting and Power Company -2- May 1, 1979 l

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1 If your understanding of this matter is inconsistent with the above, please

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contact this office inmediately.

Sincerely,

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Karl V.

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Director 2A

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l cc: W. C. Seidle, RIV W. E. Vetter, RIV

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j 5 UNITE 3 STATES ,

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0 40g#p NUCLEA3 CEIULAT WY COMMISSION

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' 811 RYAN PLAZA DRIVE, SUITE 1000 3 .. E

  • ARLINGTON TEXAS 78011 t . ,[

%,**I*** / April 30, 1979 ,

f In Reply Refer To:

RIV Docket No. 50-498/Rpt. 79-05 ST-AE-HL-587 g

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50-499/Rpt. 79-05 SFN:' C-0570 RECEIVE 0 W 'r 21979

Houston Lighting and Power Company E. A. Tog (da.cICYCT~O

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ATTN: Mr. E. A. Turner, Vice President - - , , -

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Power Plant Construction and - ~ ' ~

Technical Services Post Office Box 1700  ; -) C _ : P Houston, Texas 77001 L ~'

Gentlemen:  :; '-;. t.

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This refers to the inspection conducted by Mr. W. G. Hubacek and other members of our staff during the period April 2-6, 1979, of activities

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authorized by NRC Construction Permit Nos. CPPR-128 and 129 for South Texas Project, Units No. 1 and 2, and to the discussion of our findings with Mr. L. D. Wilson and other members of your staff at the conclusion of the inspection.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection con-

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sisted of selective examination of procedures and representative records,

.,.' interviews with personnel, and observations by the inspectors.

.' During the inspection, it was found that certain activities under your license appear to be in noncompliance with Appendix B to 10 CFR 50 of

' the NRC Regulations, " Quality Assurance Criteria for Nuclear Power Plants." The items of noncompliance and references to the pertinent requirements are identified in the enclosed Notice of Violation.

We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identi-fied in paragraph 2 of the enclosed report.

This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within

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30 days of your receipt of this notice, a written statement or'explana' tion'"

in reply including: (1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps which will be taken to avoid y

' further noncompliance; and (3) the date when full compliance will be ,

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achieved. * *

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' Houston Lighting & Power Company -2- April 30,1979

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' ,i During this inspection, our inspector also observed that rebar was still being stored on the ground even though this same unacceptable practice i was observed during our site inspection in February 1979, and was the r

i subject of a citation (Inspection Report No. 79-03). Although our April <

inspection was conducted a few days before your response to the rebar

'! ' storage citation was due, we feel that you had ample time to correct

this problem. Our concern that this problem still existed at the time of our April inspection was discussed with your Mr. R. A. Frazar, by telephone, on April 26 and 27,1979.

During these discussions, we were infonned that rebar was no longer being stored on the gmund and that actions had been taken by HL&P and Brown &

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Root to correct this continuing problem. These several actions were

i identified in our Imediate Action Letter which was dispatched to you on April 30,1979. Our inspector will give particular attention to rebar

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- storage practices during subsequent inspections.

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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part

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2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that

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such infonnation be withheld from public disclosure. The application a -

must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that

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any proprietary infonnation identified is contained in an enclosure to

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the application, since the application without the If we do not enclosure hear fmmwillyoualso in be placed in the Public Document Room.

this regard within the specified period, the report will be placed in l the Public Document Room.

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Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely, i

  • g W.C.Seihe, Chief Reactor Construction and

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Engineering Support Branch

Enclosures:

1. Appendix A, Notice of Violation

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2. IE Inspection Report No. 50-498/79-05 50-499/79-05

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50-498/79-05 s .-

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~50-499/79-05

s Appendix A NOTICE OF VIOLATION

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Based on the results of the NRC inspection conducted on April 2-6, 1979, i it appears that certain of your activities were not conducted in full

' compliance with the conditions of your NRC Construction Permit No. CPPR-128

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as indicated below:

A. Failure to Foll'ow Procedures for Storage of Material 10 CFR Part 50, Appendix B, Criterion V requires that activities i affecting quality shall be a

REGION IV

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Report No. 50-498/79-05; 50-499/79-05

" Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting & Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 & 2 Inspection at: South Texas Project, Matagorda County, Texas

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Inspection conducted: April 2-6,1979 Inspectars&./, f?V]ln/we$ 9'f9$~b9 W. G. Hubacek, Rbactor Inspector, Projects Section Date

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(Paragraphs 1,3,4&6)

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L.~ E. Martin, Reactor Inspector, Engineering Support Date~

Section (Paragraph 2 & 5)

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Approved:  :-- IIf Date W. A. Crossman, Chief, Projects Section ( Y{Ch / ^ / ~~4' ih Date

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[er/R. E. Hall, Chief, Engineering Support Section 11 \0'p p

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402 Inspection Summary:

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Inspection on April 2-6,1979 (Report No. 50-498/79-05;50-499/79-05)

Areas Inspected: Routine, unannounced inspection of construction activities

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including observation of housekeeping and storage for Units 1 and 2; review

! of HVAC activities for Units 1 and 2; review of procedures and records related f

to receiving, storage, and maintenance of Class 1E electrical equipment for

Units 1 and 2; and review of previous inspection findings. The inspection involved fifty-eight inspector-hours hy two NRC inspectors.

Results: Of the four areas inspected, two apparent items of noncompliance were identified in two areas (infraction - failure to follow procedures

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for storage of material - paragraph 3 and infraction - failure to follow

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procedures for preparation of nonconformance report - paragraph 5).

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DETAILS

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1. Persons Contacted fl G.

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Principal Licensee Employees

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T. D. Stanley, Project QA Supervisor

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. *L. D. Wilson, Site QA Supervisor l' *D. G. Long, QA Lead Engineer

  • T. J. Jordan, QA Lead Engineer M. M. Johnson, Senior Engineer o

D. Anderson, Engineer

  • D. W. Bohner, QA Senior Specialist
  • M. S. Monteith, QA Technician Other Personnel A
  • C. W. Vincent, Project QA Manager, Brown & Root (B&R)
  • G. T. Warnick, Site QA Manager, B&R
- *J. M. Salvitti, Assistant Construction Project Manager, B&R

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- *L. E. Tolley, Chief Civil Engineer, B&R

!! D. McCauley, Electrical Engineer B&R B. Speers, Electrical Engineer, B&R

.i. . G. B. Russom, Electrical QC Supervisor, B&R i' G. Ewert, QA Internal Surveillance Supervisor, B&R i

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- K. Sibley, Electrical QC Inspector, B&R

' ' L. W. Froelick, Projects Manager, Bowen Company, Inc. (Bowen)

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B. Parr, Site QA Manager, Bowen l7p-The IE inspectors also interviewed other licensee and contractor lQ employees including members of the QA/QC and engineering staffs.

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  • denotes those attending the exit interview.

2. Licensee Action on Previous Inspection Findinos (0 pen) Infraction (50-498/78-16-2; 50-499/78-16-2):

Failure to

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Provide Acceptance Criteria for Megger Testing of Class 1E Motors.

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The IE inspector reviewed the training records and surveillance These records

]. records pertinent to Procedure A040KPECP-2, Rev. O. Hewever, i.* indicate that the corrective action has been implemented.

this item will remain open pending completion of the Brown & Root I review of existing inspection plans and procedures for the inclusion

.j of appropriate acceptance criteria, per recurrence control comitted to.in the licensee': letter of January 8, 1979. This action was to have been completed by February 1, 1979.

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..- L t 404 (Closed) Infraction (50-498/78-16-3; 50-499/78-16-3): Failure to

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Follow Approved Procedures for QC Surveillance of Maintenance on Class lE Equipment. The IE inspector reviewed training records and HL&P and B&R surveillance reports pertinent to Procedure A040KPMCP-3, Rev. 4. The corrective action and surveillance of this action is appropriate. This items is considered closed.

(Open) Infraction (50-498/79-01; 50-499/79-01): Failure to Provide

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Procedure for a Quality Control Activity for Transcription of Cadwelding Examination Checklist Records. The IE inspector reviewed Site Work Instruction SWI 007-A and a subsequent revision SWI-007-8.

The IE inspector advised the licensee's representative that SWI-007-A did not adequately provide the required control on transcription of data from working copies of ECs to record copies. A subsequent

.' revision, SWI-007-B was immediately drafted and implemented including j training. SWI-007-B does provide adequate instructions for completing and recopying Cadwelding Examination Checklists. This item will remain i

open pending issuance of a new Cadwelding inspection report as required by recurrence control specified in the licensee's response letter of March 12,1979. This action was to have been completed by March 20, 1979.

(0 pen) Infraction (50-498/79-02;50-499/79-02): Failure to Control Superseded Drawings. The IE inspector These reviewed the surveillance reports indicate that therc

-}' reports for February and March.

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is a considerable problem with control of FREAs and DCNs and in one

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report, the IE inspector noted three incorrect drawing revisions were

! found in Control Record Copy 038 which was one of the files originally identified in the 79-02 NRC inspection report. This item will remain

' open pending results of the continued increased surveillance during p

April and the subsequent B&R evaluation and action on the results.

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. 3. Site Tour _

The IE inspector's walked through various areas of the site to observe construction activities in progress and to inspect housekeeping and i

equipment storage.

During the tour in the vicinity of the Unit 1 Reactor' Containment

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Building on April 2,1979, the IE inspector observed several instances where reinforcing steel stored in a laydown area was in contact with j

the ground. On the following day (Arpil 3,1979), additional instances

~l: of reinforcing steel stored in contact with the ground in Units 1 and 2 laydown areas were observed by the IE inspector and accompanying lii licensee representatives. Improper storage of reir) forcing steel was previously identified as an item of noncomplianceH; however, the condition of the laydown storage areas had markedly deteriorated since the problem was first identified.

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50-498/79-03; 50-499/79-03 1/IE Inspection Report No.

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' During the inspection of the Unit 1 Mechanical-Electrical Auxiliary Building (MEAB) on April 4,1979, the IE inspector observed that

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the skid mounted Boron Recycle Evaporator, which was stored in place,

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- was wet from apparent concrete curing water which was dripping from work areas located above the storage area.

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N, by a temporary shelter; however, the shelter failed to provide adequate Rust was observed on

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protection from the wet environment in the MEAB.theInsurfaces o

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addition, the equipment was observed to be covered with a thin coating of sand and dust which apparently was caused by' sandblasting operations i which had occurred in the vicinity. The vendor s instructions for the T

- equipment requires that for long-tem storage, the unit be stored indoors in a warm, dry environment.

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The IE inspector informed the licensee that the above item related

to the Boron Recycle Evaporator is considered to be an item of non-

' compliance with the requirements of Criterion V of Appendix B to 10 CFR 50 in that procedures or instructions which prescribe storage p

of materials were not followed.

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e 4. Review'of Heating Ventilating and Air Conditioning (HVAC) Activities

x The IE inspector was infomed that Bowen Industries, Inc., the HVAC

.' Safety contractor, has not begun work on safety related systems.

o~- related HVAC work is expected to commence in July or August 1979.

The IE inspector reviewed Specification No. 3V279VS007-E, " Safety

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Class Ductwork," and Subcontact No. 35-1197-0278, " Heating, The Bowen Venti-Quality J lating and Air Conditioning for Main Plant."

(- Assurance Manual reviewed by the IE inspector was an uncontrolled

.1 copy pending completion of the licensee's review and approval of

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the manual for site use. The licensee stated that the QA Manual and implementing procedures would be issued prior to the beginning o

of safety related work.

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l No items of noncompliance or deviations were identified.

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5. Electrical Components and Systems

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a. Review of Procedures and Records E. ' The IE inspector reviewed the following procedures and records Il pertaining to receiving, storage and maintenance of Class lE

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electrical equipment:

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'* A040KPECP-7, Rev. 3 April 4,1979, " Receiving, Storage I

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Installation and Maintenance of Class 1E and Nonclass 1E Lead Storage Batteries" i PurchaseOrder(P.O.)No. 35-1197-4100 for Class 1E Battery Chargers

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1 PurchaseOrder(P.O.)No. 35-1197-4109 for Class 1E

's Batteries t

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WMC records for Class 1E Batteries El-I and El-II i

WMC records for motors 2R161NPA101A, B & C

- NCR S-E1137-A and NCR S-1137-B for RHR pump motor

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0 2R161NPA101A

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.' The IE inspector's review of the maintenance records for the y- Residual Heat Removal Pump motor and NCR S-E1137-A and NCR

- S-E1137-B indicate that the nonconfomance report deficiency

.- does not reflect the total scope of the nonconfoming con-

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10 CFR 50, Appendix B, Criterion V requires that activities p affecting quality shall be accomplished in accordance with

,- approved instructions and procedures.

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l Brown & Root Quality Assurance Procedure ST-QAP-2.6, "Noncon-

fomances," paragraph 5.1 requires that the description of the

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nonconforming condition provide sufficient detail establishing

.i the sequence of events pertaining to the nonconfomance hnd an

accurate physical description of the nonconformance.

Contrary to the above:  ;

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NCR S-E1137-A and the subsequent revision to the NCR, NCR S-E1137-B, block No. 7 description of deficiency states:

" Questionable Megger Reading on Motor for RHR Pump, Equipment #2R161NPA-101A. ECP-2 and MCP-3.3.5 and 3.6 require 20 megohms on low voltage motors. The meg y reading is 250,000 ohms."

Based on the IE inspector's review of notes on the back of the 8- WMC record for motor No. 2R161NPA-101A and subsequent discussions

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with the responsible B&R Quality Control and Engineering personnel,

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it was found that the motor had been inadequately protected from-6 -

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6 407 concrete curing water and the motor terminal connection box

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was full of water on February 9,1979. This condition was ,

witnessed by QC and later substantiated by the area engineer.

The engineer responsible for initiating the proposed disposi-tion on NCR S-Ell 37A told the IE inspector that he was not aware of the condition of the motor on February 9,1979, and was not aware of possibility of there being water in the motor.

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?. On March 28, 1979, NCR S-Ell 37-B was written trans' ferring the

- responsibility of the resolution of this nonconformance to the

.; . Westinghouse site organization.

.' The megger reading for the RHR pump motor on April 4, 1979, was 0.5 megohms, almost two months after the nonconformance was originally identified.

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The description of the deficiency on NCR S-Ell 37A and NCR S-Ell 37B does not provide sufficient detail establishing the

sequence of events pertaining to, and an accurate physical description of the nonconformance to insure proper disposition and evaluation of impact on the condition of Class 1E equipment.

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b. Observation of Work

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!l.; The IE inspector observed the start of the initial equalizing 1,' ,

charge on Class lE batteries El-I and El-II.

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!: No items of noncompliance or deviations were identified.

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6. Exit Interview

.! The IE inspectors met with licensee representatives (denoted in para-

] ,' graph 1) at the conclusion of the inspection on April 6,1979. The

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IE inspectors summarized the purpose and the scope of the inspection q

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and the findings. A licensee representative acknowledged the state-

't ments of the IE inspectors concerning the items of noncompliance.

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Flay 25, 1979 l ,

Electric Tower M'051M9 n RO. Box 1700 ST-HL-AE-343 iL HoustortTexas 77001 SFN: C-0570 Ftr. W. C. Seidle', Chief Reactor Construction 6 Engineering -

Support Branch U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 SUBJECT: RESPONSE TO NRC INSPECTION FINDINGS SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION DOCKET NOS. 50-498/79-05 AND 50-499/79-05

Dear Ftr. Seidle:

The following is liouston Lighting 6 Power Company's (HL6P)

response to the items of noncompliance identified in IE Inspec-tion Report Nos. 50-498/79-05 and 50-499/79-05 dated April 30, 1979.

Failure to Follow Procedures for Storage of F!aterial 1. Corrective Action Taken The immediate corrective action consisted of covering the Boron Recycle Evaporator with an interim structure that did meet the storage requirements. On F!ay 4,1979, the interim structure was replaced with a durable struc-ture that also meets the storage requirements.

Additionally, other areas where equipment is stored in place, which might be subjected to water, were inspected to ensure compliance to storage requirements. / -

2. Recurrence Control

/.i h f The Storage and F!aintenance Program is being ' /\'. '

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revised and it will address storage require- {.I ' '

ments and inspection criteria. This program will assign responsibility to specific groups to ensure that storage requirements are me y This program will be implemented on June 1, 1979, and all action on this item of noncom-pliance will be complete on June 10, 1979.

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ifay25, 1979 2 Page Two

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Failure to Follow Procedure for Preparation of Nonconformance Reports (NCR)

1. Corrective Action Taken The noncomplying NCR has been revised and '

reissued giving a correct discussion of the condition ~ when identified.

2. Recurrence Control By memorandum, all quality control / quality , .

assurance engineering personnel have been '

I i, instructed that a proper NCR must include, -

in the descripticn of the nonconforming

! condition, the sequence of events pertain-ing to the nonconformance, if it can be de-

{termined. Full compliance was achieved on this item May 9, 1979. ___

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The completion date of all corrective action and recurrence control will be achieved June 10, 1979.

Very truly yours, W_ . O hl

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E. A. Turner, Vice President Power Plant Construction 6 Technical Services EAT:rka cc: Messrs. G. W. Oprea, Jr.

R. A. Fra:ar'

D. G. Barker M. L. Borchelt (CPL) '

J. W. Moore (CPL)

J. B. Poston (CPS)

R. C. Mecke (CPS)

R. L. Hancock (COA)

H. L. Peterson (COA)

J. H. Pepin (B6R)

C. W. Vincent (B6R)

STP RMS I

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UNITED STATES 410

,.; ,e g NUCLEAR REGULATORY COMMISSION

,' . ..j REGION IV

$ $11 RYAN PLAZA DRIVE. SUITE 1000

,o'g AR LINGTON. TEXAS 76012 October 16, 1979  ;

. In Reply Refer To: 1 RIV Docket No. 50-498/Rpt. 79-14 ST-AE-HL-600 R IO E M'r'"n 50-499/Rpt. 79-14 SFN: C-0570 ,

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Bouston Lighting and Power Company -

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Attn: Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services  :: ' , -,u_.

Post Office Box 1700 Houston, Texas 77001 , , , , , , , , ,

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Gentlemen:

I This refers to the investigation conducted by Messrs. W. G. Hubacek and B. S. Phillips of our staff during the period September 4-7 and 11-14,1979, of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units No. I and 2, concerning an allegation by a former South Texas Project employee.

The investigation and our findings are discussed in the enclosed investigation report.

During the investigation, it was found that certain activities under your license i

appear to be in noncompliance with Appendix B to 10 CFR 50 of the NRC Regulations,

" Quality Assurance Criteria for Nuclear Power Plants." The item of noncompliance and reference to the pertinent requirements are identified in the enclosed Ndtice of Violation.

One new unresolved item is identified in paragraph 2.c of the enclosed report.

'Ihis notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Section 2.201 requires you to submit to this office, within 30 days of your receipt of this notice, a written statement or explanation in reply including: .(1) corrective steps which have been taken by you, and the results achieved; (2) corrective steps

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which will 1,e taken to avoid further noncompliance; and (3) the date when full

compliance will be achieved.

During the investigation, it was found that certain of your activities appeared to deviate from commitments in the PSAR. This item and references to the specific commitments are identified in the enclosed Notice of Deviation. In your reply, Please include your comments concerning this item, a description of any steps -

that have been or will be taken to correct it, a description of any steps that I_ k ~

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r Houston Lighting and Power October 16, 1979 Company 2 have been or will be taken to prevent recurrence, and the date all corrective actions or preventive measures were or will be completed.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed investigation report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the

- Public Document Room.

Should you have any questions concerning this investigation, we will be pleased to discuss them with you.

Sincerely, W. C. Seidle, Chief

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Reactor Construction and Engineering Support Branch

Enclosures:

1. Appendix A, Notice of Violation 2. Appendix B, Notice of Deviation 3. IE Investigation Report No. 50-498/79-14

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50-499/79-14

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Docket No. 50-498/79-14 50-499/79-14 Appendix A NOTICE OF VIOLATION Based on the results of the NRC investigation conducted on September 4-7, and 11-14, 1979, it appears that certain of your activities related to the South Texas Project, Unit 2 were not conducted in full compliance with the conditions of your NRC Construction Permit No. CPPR-129 as indicated below:

Failure to Follow Procedures for Release of Stop-Work Notice S-14 Criterion V of Appendix B to 10 CFR 50 requires that activities affecting quality shall be a

REGION IV==

Report No. 50-498/79-14; 50-499/79-14 Docket No. 50-498; 50-499 Category A2

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Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: Sou'th Texas Project, Units 1 and 2 Investigation At: South Texas Project, Matagorda County, Texas Investigation Conducted: September 4-7 and 11-14, 1979 Inspectors: 6 j, 9/ -1 / M /o/// /77 W. G. Hubacek, Reactor Inspector Date Projects Section

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l0 N li H. S. Phillips, Resident Reactor Inspector Date Projects Section Approved: lJAd7 we /of//f79 W. A. Crossman, Chief, Projects Section Date Investigation Summary:

Investigation on September 4-7 and 11-14, 1979 (Report No 50-498/79-14; 50-499/79-14)

Areas Investigated: Special, unannounced investigation of allegations regarding nonconforming construction practices and insufficient quality control programs for construction at the South Texas Project. The investi-gation involved eighty inspector-hours by two NRC inspectors.

Results: One item of noncompliance (failure to follow procedures for release of Stop-Work Notice - paragraph 2.i.) and one deviation (failure to include the date and identification of person entering supplemental information on an inspection report - paragraph 2.h.) were identified during the investigation.

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INTRODUCTION The South Texas Project, Units No. I and 2, are under construction in Matagorda County, Texas . near the town of Wadsworth, Texas. Houston Lighting and Power Company is the Construction Permit holder. Brown & Root, Incorpo-rated is both Architect Engineer and Constructor for the project.

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REASON FOR INVESTIGATION During a recent site inspection,1/ the Region IV Project Inspector was notified by the licensee of alleged incidents of intimidation of QC inspectors by Brown and Root construction personnel. In addition, information concerning alleged QA/QC irregularities at the South Texas Project was received by Region IV from confidential sources.

SUMMARY OF FACTS On August 8, 1979, the licensee reported alleged intimidation incidents to the Project Inspector. Subsequently, allegations of QA/QC program irregu-

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larities were received from confidential sources. The following specific allegations were expressed:

1. Two Brown and Root QC inspectors were intimidated by five Brown and Root construction persons 2. Brown & Ract QC inspectors were involved in continuous card games during working hours for a several month period in 1977. The QC inspec-tors left the card games only to sign inspection forms when requested by j

construction and immediately returned to the card games without perferming inspections of safety-related work.

3. Waterproofing membrane was installed at night on Reactor Containment Building (RCB), Unit No. I and Fuel Handling Building (FHB), Units No.

I and 2 without proper QC inspection prior to backfill.

4. Holes left in concrete walls of safety-related structures following removal of tapered form ties were not solidly filled with grout.

t 5. Cadweld inspection reports were signed by QC inspectors who had not per-formed the reported inspections.

6. Lift 5 of RCB, Unit No. 2 contained 116 Cadwelds which were not accounted i for.

7. Some Cadweld inspection forms were hanging on the walls of the QC field shack and had not been submitted to the QA records vault since January 1979.

1/ IE Inspector Report 50-498/79-13; 50-499/79-13

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8. An inspection report for the RCB, Unit No. I equipment hatch contained an entry by a person other than the inspector responsible for the report. The entry was not sigr.ed nr dated by the person who made the entry.

9. A QC inspector was given verbal instructions to disregard a stop-work notice and sign the concrete pour card for placement No. HE2-H3.

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10. A void in the concrete in the area where the FHB ties into RCB, Unit No. I was not repaired in accordance with approved procedures.

CONCLUSIONS 1. The alleged intimidation of two QC inspectors by five construction persons could not be sustantiated or refuted due to conflicting state-ments made by these individuals during interviews by the NRC investiga-l g' tion team. The QC persons involved conveyed strong impressions that

i statements made to them by the five construction persons were perceived

as serious threats that were meant to hinder their performance as QC inspectors. The five construction persons denied making direct threats

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or using abusive language in direct conversations with the QC inspectors.

One of the construction persons. stated that he may have made statements about objects falling on one of the inspectors, but such statements were meant as safety concerns or possibly were meant as jokes but not as threats. Another construction person stated that he may have made remarks about one of the QC inspectors, but denied making abusive or intimidating remarks directly to the inspector. The licensee's actions in response to this incident have apparently been effective in preventing further similar incidents.

2. The allegation that Brown & Root QC inspectors were involved'in con-tinuous card games during working hours for several months in 1977 with detrimental effects on QC inspections could not be substantiated. The

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investigation team interviewed nine individuals who were presenl~at the site during the alleged card games, but none were aware of the card games that were alleged to have occurred in 1977. Two of the individuals stated that card games took place in 1976, but were not of the scope l alleged and did not have adverse impact on the performance of inspections by QC personnel.

3. The allegation that waterproofing membrane was installed at night on l

l RCB, Unit No. I and FHB, Units No. I and 2 without proper QC inspection l

could not be substantiated. Five individuals interviewed by the investi-

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ialidn tie ~a~m~s'tateil that 'they had no knowledge of inrproper inspection of l

the membrane prior to backfilling. Review of QC records and the inspection l

procedure for waterproofing membrane was inconclusive and resulted in the identification of an unresolved item pertaining to the frequency of ,

l inspections stated in the procedure.

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4. The allegation that holes left in concrete walls of safety-related structures after removal of tapered form ties were not solidly filled with grout (was substantiated; however, this matter was previously identi-fied and documente.1 ty the 1icensee. Corrective action was in progress.

5. The allegation that Cadweld inspection reports were si'gned by QC inspec-tors who had not performed the reported inspections could ant h sub-stan Qat_eA ,por refuted. The confidential source of this information

- declined to provide information to support this allegation. Two individuals previously named by the alleger as individuals who signed the inspection reports were no longer employed at STP and were not available for interview.

6. The allegation that Lift 5 of RCB, Unit No. 2 contained 116 Cadwelds that could not be accounted for was substantiated; however, it was determined that this matter was previously identified by the licensee and documented in a nonconformance report.

7. The allegation that some Cadweld inspection forms were hanging on the wall in the QC field shack and had' not been submitted to the QA records vault since January 1979 could not be substantiated. It was determined by direct inspection of the QC field shack that the alleged inspection records were not hanging on the wall in the QC field shack. Interviews with personnel indicated that only duplicate copies of records are maintained in the field shack and originals are promptly forwarded to the QA records vault upon completion of required inspection and Cadweld location verifications.

8. The allegation that an inspection report for the RCB, Unit No. 1 equipment hatch contained an unsigned and undated entry by a person other than the responsible QC inspector Eas substantiated and resulted in issuance of a

, citation to the licenseeJoi deviatipg from a YS'Ali~cTmmTtiienIt'o'~ ANSI ~

N45.2.9. It was determined that an entry was made on an inspection report related to placements CSI-12A and CSI-13A by the responsible QC inspector's lead inspector. The lead inspector failed to date and sign the entry contrary to ANSI N45.2.9, which requires that such entries be dated and the individual making the entry be identified.

9. The allegation that a QC inspector was instructed to disregard a stop-work notice and sign a concrete pour card for placement ME2-M3 2as ,

substantiated and resulud in~the_ issuance of a citation to the licensee

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Mr~ failure to follow procedures in the release of a sto'p47srE'Ifoti&T It was determined that the QC inspector was verbally instructed to sign the concrete pour card for placement ME2-M3 on July 20, 1979, although Stop-Work Notice S-14 applicable to the placement was still in effect.

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The Stop-Work Notice was not released in writing until August 1, 1979,

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! several days after olacement ME2-M3 was completed. Brown & Root procedures do not provide for verbal release of stop-work notices.

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10. The allegation that a void in the concrete in the area where THB, Unit No. 1 ties into RCB, Unit No. I was not repaired in accordance with approved procedures toubt not be substantiated. Individuals interviewed were aware of the sxistence of some small voids in the area but maintained that they were sma;l and were repaired in accordance with established procedures. They ,were not aware of any voids that were improperly repaired.

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DETAILS 1. Persons Contacted Principal Licensee Employees

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  • T. D. Stanley, Project QA Supervisor
  • M. H. Smith, Plant QA Supervisor
  • T. J. Jordan, QA Lead Engineer
  • R. L. Ulrey, Senior QA Specialist
  • B. K. Schulte, Junior Engineer
  • H. E. Orban, Construction Supervisor
L. D. Wilson, Site QA Supervisor W. N. Phillips, Projects QA Manager D. G. Long, QA Lead Engineer C. L. Grosso, Associate Engineer Brown & Root Employees

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G. T. Warnick, Site QA Manager

  • D. Shumway, QC Shift Supervisor
  • E. Tolley, Construction Chief Engineer
  • W. Abrams, QA Engineering Supervisor The IE inspectors also interviewed other licensee and contractor employees

including members of the QA/QC and engineering staffs.

  • Denotes those attending the exit interview on September 14, 1979.

2. Investigation Details The following specific allegations were investigated during this investi-gation. Resultant findings of the NRC investigation team are indicated below:

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a. Allegation 1: Two Brown & Root (B&R) QC inspectors were intimidated by five Brown & Root construction persons. The alleged intimidation included threats to throw the QC inspectors out of a building, to drop things on one QC inspector, and the use of vulgar and abusive language in reference to the two QC inspectors.

Investigation Findings: The investigation team interviewed eight individuals (A through H) who were identified in the allegation as the persons involved in the alleged intimidation.

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(1) Interview with Individual "F" Individual "F" stated that the first incident of intimidation occurred spproximately 1 months ago when "F" was inspecting the Unit 1 Turbine Generator (TG-1) Building. When "F" wrote a Nonconformance Report on the storage of equipment that was located in the area "F" was called a vulgar name by individual

"D".

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Individual "F" stated that approximately one week after the above incident, individual "G" threatened to throw "F" and individual "H" out of the TG-1 Building if "F" placed any more QC hold tags. "F" stated that, although "G" did not appear to be angry, the threat was not perceived as a joke.

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Individual "F" also stated that individual "A" (described as short-tempered) called "F" vulgar names on several occasions,

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some of which were witnessed by individuals "E" and "H".

Individual "F" further stated that on another occasion individual

"C" had asked what "F" was doing in the Unit 1 Fuel Handling

- Building (FHB) and questioned "F's" ability and knowledge of procedures. "F" stated that "C" used abusive language during this encounter.

During the interview "F" stated that "F" took assigned respon-sibilities seriously and that there had been no direct accusations of " nit-picking" or playing "I got you" by construction. "F" was not aware of any other cases of intimidation of QC inspectors j

by construction personnel.

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(2) Interview with Individual "H" Individual "H" stated that approximately 1 to 2 months ago while inspecting equipment storage in RCB, Unit No. 1 (accom-panied by individual "E"), "H" was at a drinking water cooler when "B" stopped for a drink and threw a used cup on the floor.

"B" picked up the cup after "H" mentioned it to him. "B" then i

asked what "H" was doing and stated that things (spud wrench)

could fall on "H's" head if anything was written up in his area.

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1 Individual "H" was with "F" when "G" stated that he would remove them from the TG-1 Building if another hold tag were f

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hung. "H" perceived this threat as harassment rather than as actual intent to physically remove "F" and "H" from the building.

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"H" feels that others may consider "H" to be a " nit-picker".

"H" has had no further contact with "B" since the incident.

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(3) Interview with Individual "E" ri c.

Individual "E" stated that "E" was present when "B" told '

"H" not to write up anything in his building. "E" heard "B" say to "H" that "something may drop on you". "E" stated that

"B" spoke on this subject for approximately five minutes and went out of his way to make his meaning clear. "E" stated that he felt concerned about "H's" safety although "B" did not appear to be angry or upset. The conversation took place near the water cooler in the RCB, Unit No. 1.

"E" recalled instances where individual "A" used vulgar lan-guage.in reference to "F" but not in direct conversation with nyn,

"E" had no knowledge of intimidation of QC personnel other than individuals "F" and "H". "E" stated that he is not aware of any recent problems with intimidation or abusive language since these incidents.

(4) Interview with Individual "D" Individual "D" stated that he had no problems in his contacts with QC and he does not consider QC inspectors to be nit pickers.

"D" did not recall any instances of the use of vulgar language in conversations with QC personnel.

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(5) Interview with Individual "B" Individual "B" stated that approximately 2 months ago in the RCB, Unit No. I he splashed water into his eyes to relieve welding burns and threw the empty cup on the floor. "B" was approached by "B" (accompanied by "E") who stated "B" could " write up" "B" for throwing the cup on the floor. "B" then picked up the cup.

"B" stated that he did not recall specifically what was said during the incident and maintained he did not threaten "H". In response to the IE inspector's questions, "B" stated that he may have said that something could fall on the QC inspector's head since they were in an area where there was the possibility of falling objects, but he stated that if such was the case, no harm was intended. "B" further stated that he may have made such a statement as a joke.

"B" stated that he gets along well with QC.

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(6) Interview with Individual "A" Individual "A" stated that he did not recall the specific instance of the use of vulgar language alleged by "F" but stated that it was possible that he may have done so.

"A" said t' hat he had had no problems with other QC inspectors.

"C" (7) Interview with Individual Individual "C" stated that he could not recall any instances

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where verbal abuse or vulgar language was used in conversations with individual "F". "C" stated that he first became aware of the problem when he was called in to discuss the matter with the Brown & Root Project Manager.

"C" feels that the QC inspectors involved are over-zealous and

" nit-picking".

"G" (8) Interview with Individual in the Individual "G" stated that he recalls speaking to "F"

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Turbine Generator Building but denied that he made any threats against "F" ior any other QC inspectors.

Discussions with licensee and Brown & Root representatives re-vealed that the individuals involved in the alleged intimidation incidents had been counselled by management and instructed to conduct themselves at a high level of professionalism. The individuals were informed that future occurrences of similar incidents could result in removal of offenders from the job-site. The licensee and Brown & Root representatives stated that this matter was viewed with grave concern and that methods of dealing with similar problems in the future, including establishing a special group to hear grievances, are being considered.

This allegation was neither substantiated nor refuted, Brown & Root QC inspectors were involved in continuous b. Allegation 2:

card games during working hours for a several month period in 1977.

l The QC inspectors left the card games only to sign inspection forms when requested by construction and immediately returned to the card games without performing inspections of safety-related work.

Investigation Finding: The investigation team interviewed nine individuals who were present at the STP site during the time of

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( the alleged card games. None of the individuals interviewed had any knowledge of the extensive card games alleged to have occurred in 1977; however, two of the individuals indicated they knew of card games which took place in 1976. The two individuals stated l

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' that the 1976 card games were not extensive but took place during periods of little construction activity and involved QC personnel who had little or no work to do. Two other individuals stated that they had heard of the 1976 card games from other site personnel but had no direct knowledge of the games. None of the nine individuals interviewed were aware of any cases where QC inspectors failed to properly inspect safety-related activities or signed inspection records only when requested by construction because of participation in card games.

This allegation was not substantiated. .

c. Allegation 3: Waterproofing membrane was installed at night on RCB, Unit No. I and FHB, Units No. I and 2 without proper QC inspection prior to the placement of backfill.

Investigation Finding: The investigation team interviewed five individuals who were involved or had previously been involved in inspection of waterproofing membrane installation. All of the individuals stated that they had no knowledge of the placement of backfill against the membrane prior to proper completion of membrane

- inspections by QC.

During review of documents related to membrane installation, the IE inspector observed that there were apparent inconsistencies in pro-

cedure CCP-12 " Installation of Waterstop and Waterproofing Membrane,"

Revision 4 relative to the scope and frequency of the required QC inspections. Paragraph 3.3.1 of the procedure states that the QC inspector will inspect the membrane system utilizing the Site QC Schedule (appendix B). Appendix E indicates that all but two items on the schedule shall be inspected on a semiweekly basis. The two items - No. 280, "Special Application Techniques Employed," and No.

308, "Not Damaged to the Point Where Membrane Needs to be Repaired,"

are shown requiring inspection daily, as applicable. Paragraph

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3.4.3.1 of the procedure states that all membrane surfaces will be i

visually inspected by QC for discontinuities and imperfections.

During discussion of the above CCP-12 requirements with licensee and contractor personnel, some individuals interpreted the procedure to require 100% inspection of the membrane, other individuals inter-

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preted the procedure to require something less than 100% inspection.

This matter is considered unresolved pending clarification of CCP-12 membrane inspection requirements and subsequent review by IE.

This allegation was not substantiated.

d. Allegation 4: Holes 1. eft in concrete walls of safety related struc-tures following removal of tapered form ties were not solidly filled with grout.

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Investigation Finding; Thel investigation team was informed by licensee and contractor representatives that improper grouting of -

tapered tie hales.was first identified in Deficiency and Dispositica Report S-0325 which was initiated on December 29, 1977. Similar, problems related to improper grouting of tapered tie holes were documented in Nonconformance Reports S-C2257, S-C3126 and S-C3130 initiated on May 18, 1979, August 30, 1979, and September 10, 1979, respectively, which remain open pending completion of corrective action.

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This allegation was substantiated; however, this actter had been identified by the licensee and corrective action was in progress, e. Allegation 5: Cadw' eld inspection reports were signed by two QC inspectors who had not performed the related Cadweld inspections.-

Investigation Findings: The confidential source of this allegation declined to provide information to support the allegation. Two individuals previously named by the alleger as individuals who signed the inspection reports were no longer in the STP area and were not available'for interview.

This allegation was neither substantiated nor refuted.

f. Allegation 6: There were 116 Cadwelds in Lift 5 of RCB, Unit No. I wall that could not be accounted for.

' Investigation Findingq: The investigation team was informed by licensee representatives that Nonconformance Report (NCR) S-C2228, dated April 26, 1979, documents that 114 Cadwelds shown by original QC documentation to be in Lift 5 of RCB, Unit No. 2, were, in fact, not in Lif t 5. 'Ine 114 Cadwelds were shown to be in Lift 5 due to errors made by QC personnel in the frame of reference used to determine as-built locations. Correct locations of the Cadwelds areexpectedtobeestablishedbygeansofthecurrentlyongoing computer-assisted records review.-

This allegation was substantiated; however, the problem was pre-viously identified by the licensee.

g. Allegation 7: Some Cadweld inspection forms were hanging on the wall in the QC field shack and had not been submitted to the QA records vault since~ January 1979.

Investigation Finding: During inspection of the Cadweld QC field shack, the IE inspector did not observe any Cadweld inspection forms hanging on the walls of the shack. The IE inspector was informed 2,/ IE Report No. 50-498/79-09; 50-499/79-09

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  • by the licensee representatives that only duplicate copies of inspection records and Field Engineering as-built location records are maintained in the field. Original records are promptly for-warded to the QA records vault after completion and checking by the lead inspector.

This allegation was not substantiated. ,

b. Allegation 8: An inspection report for the RCB, Unit No. I equip-

. ment hatch contained an entry by a person other than the inspector responsible for the report. The entry was not signed and dated by the person who made the entry.

Investigation Findings: The investigation team observed that the subject inspection report (Examination Check form for placements CSI-12A and CSI-13A, dated November 9, 1978) contained an entry on the back of the form that was made by a person other then the responsible inspector. The entry had not been signed or dated.

Discussions with licensee representatives revealed that the entry was made by the responsible inspector's lead inspector in response to remarks entered on the back of the report by the responsible inspector. The person who made the entry signed and dated his entry on September 13, 1979, while the investigation was in pro-gress. The IE inspector informed the licensee that failure to sign and date the entry on the report at the time it was made was a deviation from ANSI N45.2.9-1974 in that supplemental information was entered on the report without including the date and identifi-cation of the person who made the supplemental entry.

This allegation was substantiated.

i. Allegation 9: A QC inspector was given verbal instructions to dis-regard a stop-work notice and sign the concrete pour card for placement No. ME2-M3.

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Investigation Finding: The investigation team reviewed records related to placement ME2-M3 which indicated that the placement was made on July 20, 1979, but that a documented partial release of the related stop-work notice (F: S-14) was not* approved until August 1, 1979. Discussions witL ttt responsible B&R representa-tive revealed that he verba7iy 4ast < cted the QC inspector to sign the concrete pour card with tis ty; v : standing that the written release of the stop work notice would immeciately be issued. The B&R repre-sentative also stated that neither Section 15.0 of the B&R QA Manual nor QA Procedure ST-QAP 2.7 provide for verbal release of l

stop-work notices and that B&R QA was at fault in failing to issue a written release concurrently with the verbal release on July 20, 1979.

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The IE inspector informed the licensee that verbal release of the stop-work notite is considered to be an item of noncompliance with 10 CFR 50.-Appendix B, Criterion V, in that procedures or ,

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instructions affecting quality were not followed.

This allegatian was substantiated,

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j. Allegation 10: A void in the concrete in the area where the FEB ties into RC,B, Unit No. I was not repaired in accordance with approved

. procedures.

Investigation Finding: The investigation team interviewed seven individuals concerning the existence of a void in the area where the FHB ties into RCB, Usi' No. 1. Two of the individuals were aware of small voids in this area but stated that they were small and lid not affect the integrity of the structures. Repairs were classed as " cosmetic" and were accomplished in accordance with established procedures. The other five of the seven individuals stated that The allegation lacked they had no knowledge of a void in this area.

specific information regarding the location of the void, consequently review of pertinent records was not performed.

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This allegation was not substantiated.

3 Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-'

An unresolved item disclosed during the compliance or deviations.

investigation is discussed in paragraph 2.c.

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4. Exit Interview The IE inspectors met with licensee representatives (denoted 14, in para-1979.

graph 1) at the conclusion of the investigation on September The IE inspectors summarized the pu'rpose and the scope of the investi-gation, reviewed the allegations and the findings, and discussed the unresolved item, the item of noncompliance and the deviation.

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UNITED STATES

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N' LEAR REGULATORY COMMISSIOh +p 427 g(ps

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September 6,1979 In Naply Refer To:

RIV ST-AE-HL'-603 Docket No. 30-498/79-14 50-499/79-14 SFN: C-0570 Eouston Lighting and Power Company ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Rouaron, Texas 77001 Gentlemen:

This refers to the meeting Mr. R. A. Frazar and other members of your staff had with me and members of my staff in the Region IV office on September 5, 1979, and to the subsequent telephone conversation between you and our Mr. W. on September 6 with regard to your plans to resume the placement of concrete in the exterior shell wall of the STP Reactor Contain-ment Building (RCB) on, or about, September 6,1979.

Following the detection of voids in the RCB exterior shell wall, placement of safety-related concrete was stopped by an EL&P Stop-Work Order and confirmed by a Region IV Immediate Action Letter dated June 22, 1979. On June 29, EL&P removed the Stop-Work Order except as the Order applied to the RCB. Subsequently, we have cocpleted a review of the actions identified s in our Ic: mediate Action Letter to correct concrete placement problems which resulted in the presence of the voids. Based on our review, we have no cbjection to your plan to resutc placement of all safety-related concrete.

We will continue to monitor cicsely your work activities, management controls cod implementation of your Quality Assurance program during subsequent inspections.

If you have any questions regarding this matter, please contact this office.

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Sincerely,

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  • [ ARLINGTON, TEXAS 76012 January 11, 1980 .

In Reply Refer To:

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ST-AE-HL-602 Docket No. 50-498/Rpt. 79-14 i 50-499/Rpt. 79-14 SFN: C-0570 p - r r ..r - ~

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Houston Lighting and Power Company ATTN: Mr. E. A. Turner, Vice President EA ' uk =cn Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 Gentlemen:

Thank you for your letter of November 16, 1979, in response to our letter dated October 16, 1979, and the attached Notice of Violation. As a result of our review, we find that additional information, as discussed with your Mr. L. D. Wilson on December 13, 1979, is needed.

Specifically, your response to Item B should address steps taken to assure the implementation of recurrence control measures described in interoffice memo SQA-852, dated April 13, 1979. Your response should also state the date when full compliance was or will be achieved.

You are requested to provide the additional information within twenty days of the receipt of this letter.

Should you have any questions regarding this matter, please contact this office.

Sincerely,

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p W. C. Seidle, Chief

' Reactor Construction and Engineering Support Branch l

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ST-HL-AE-408 SFN: C-0570 Mr. W. C. Seidle, Chief Reactor Construction 6 Engineering Support Branch U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS DOCKET NOS. 50-498/79-14 AND 50-499/79-14

Dear Mr. Seidle:

The following is the additional information you requested on the items of noncompliance identified in IE Inspection Report Nos. 50-498/79-14 and 50-499/79-14 and addressed in your letter of January 11, 1980.

Failure of QC Inspector to Initial and Date Supplemental Entry 1. Corrective Action Taken The concrete placement card on which the original entry was made has been initialed and dated by the inspector who made the entry.

2. Recurrence Control Written instructions have been reissued on making b'

changes and late entries on QA documentation. --

I rown B 6 Root QC personnel will be reinstructed on the proper methods for making changes and late entries on

QA documentation. This reinstruction will be in writ- 2,

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Qenformandtheinstructiongivenwillbedocumented.

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Houws: @ ting & her Company

Fi , January 25, 1980 Page Two 3. Date Full Compliance Will be Achieved

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Corrective action and recurrence control will be completed by February 1, 1980.

Very truly yours, l *%

L lp O w-w E. A. Turner, Vice President Power Plant Construction 6 Technical Services EAT:rka

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cc: blessrs. G. W. Oprea, Jr.

R. A. Frazar D. G. Barker bl. L. Borchelt (CPL)

J. W. Floore (CPL)

J. B. Poston (CPS)

R. C. Flecke (CPS)

R. L. Hancock (COA)

bl. C. Nitcholas (COA)

W. N. Phillips T. D. Stanley G. B. Painter bl. D. Schwarz (Baker 6 Botts)

H. S. Phillips (NRC)

J. R. Geurts (BSR)

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U. D. Douglas (B5R)

C. W. Vincent (B5R)

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