IR 05000498/1980004
| ML19323E726 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/04/1980 |
| From: | Crossman W, Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19323E717 | List: |
| References | |
| 50-498-80-04, 50-498-80-4, 50-499-80-04, 50-499-80-4, NUDOCS 8005270167 | |
| Download: ML19323E726 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Report No. 50-498/80-04; 50-499/80-04
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Docket No. 50-498; 50-499 Categoray A2 Licensee:
Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name:
South Texas Project Units 1 and 2 Inspectic-at:
South Texas Project Mategorda County, Texas Meeting at Houston, Texas Inspection conducted: March 4-7 and 11-14, 1980 Inspectors:
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k W(Paragraphs
. G. Hubacek, Reactor Inspector, Projects Section Date F
1, 2, 3, 4, 5 & 6)
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W. A. Crossman, Chief, Projects Section Date (Paragraph 2)
Other Accompanying Personnel:
W. C. Seidle, Chief, RC&ES Branch (Corporate Meeting in Houston-March 11, 1980)
(Tour of South Texas Project-March 12, 1980)
Approved:
c-w Y 9 80 W. A. Crossman, Chief, Projects Section Date Inspection Summary:
Inspection on March 4-7 and 11-14, 1980 (Report No. 50-498/80-04; 50-499/80-04)
Areas Inspected:
Special inspection of implementation of the licensees nine
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point action plan for resolution of concrete placement problems described in the licensee's letter dated December 28, 1979; and a meeting with licensee i
representatives on March 11, 1980.
The inspection involved one hundred twelve inspector-hours by two NRC inspectors.
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Results:
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No items of noncompliance or deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees
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+E. A. Turner, Vice President Power Plant Construction and Technical Services
+D. G. Barker, Manager, South Texas Project (STP)
+R. A. Frazar, QA Manager
+J. W. Briskin, Project Manager, STP Houston Operation
- +W. N. Phillips, Projects QA Manager
- +L. D. Wilson, Site QA Supervisor
+T. K. Logan, QA Supervisor
+T. J. Jordan, QA Lead Engineer, Mechanical
+D. W. Bohner, QA Lead Specialist, Electrical
+L. R. Jacobi, Supervising Engineer, Nuclear Safety and Licensing
- L. K. English, Site Manager
- T. D. Stanley, Project QA Supervisor Brown and Root Employees 4K. M. Broom, Senior Executive Vice President, Power Division
- T. H. Gamon, QA Manager
- C. W. Vincent, Project QA Manager
- G. T. Warnick, Site QA Manager
- R. R. Gunter, Assistant Site QA Manager
- U. D. Douglas, Site Construction Manager W. L. Tofte, Training Coordinator (QA)
J. W. Dixon, Training Coordinator (Construction)
The IE inspectors also interviewed other licensee and contractor employees including members of the QA/QC and engineering staffs.
+ Denotes those attending the meeting on March 11, 1980.
- Denotes those attending the exit interview on March 14, 1980.
2.
Nine Point Corrective Action Program
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The IE inspectors reviewed proposed measures to provide corrective action and implementation of a nine point corrective action program as outlined in a letter from Oprea to the Director, RIV, dated December 28, 1979.
a.
Action Item No. I Fundamental Philosophies and Standards of QA Program This action item committed Brown and Root, in a seminar on January 4, 1980, ".
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fundamental philosophies and standards of our QA Program.
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The IE inspectors reviewed copies of four formal presentations given at the Brown and Root Construction and QA/QC seminar held January 4, 1980 on the STP Job site. The four presentations by Brown and Root management are as follows:
" Introduction," Vice President and General Manager South Texas Project
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"The Role of QC Personnel at South Texas Project," Project
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QA Manager
" Construction Support for STP QA Program," Project Construction Manager
" Conclusion," Vice President and General Manager South Texas Project The IE inspectors noted in review of the second presentation,
"The Role of QC Personnel at the South Texas Site," that it was emphasized frequently that the QA/QC organization har a responsibility in the area of cost and scheduling.
While this responsibility may impact on upper QA management, inspectors on the QC level must have sufficient independence from cost and sched11ing to properly perform
quality functions. To the contrary, QC inspectors have complained that they are pressured by construction to meet schedules.
Also, the presentation seems overly concerned with impressing on QA/QC personnel that they do not have the final word in acceptability or unacceptability of any given item or circumstance.
This should be an infrequent action. Properly defined accept / reject criteria, which are understood by construction as well as QC, allow QC personnel a firm position from which to make decisions.
Ambiguous accept / reject criteria, for the sake of flexibility, dilute the QC effort, cause indecision, allow confrontation, slows construction and results in poor quality work.
The above does not reflect requirements of Criterion I of Appendix B to 10 CFR 50 in that it does not support the position that the persons and organizations performing Quality Assurance functions have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions and that this required authority and organizational freedom includes sufficient independence from cost and schedule.
This action item remains open pending further review by NRC in regard to implementation of onsite QA/QC's authority and organizational freedom.
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b.
Action Item No.2 Field Requests for Engineering Action (FREA's) and Non-Conformance Reports (NCR's)
Procedures that address Field Requests for Engineering Action (FREA's)
and Non-Conformance Reports (NCR's) are:
STP QAP 2.6, "Non-Conformances," Revision No. 9,
Januacy 31, 1980.
GCP-21 " Field Request for Egnineering Action" Review of QAP 2.6, Section 5.1, " Reporting Nonconformances" revealed the following:
(1) The statement, "For the purpose of this procedure, final acceptance shall be that time when the item is presented to QC for acceptance." Has limited application.
Although the establishment of this point for acceptance inspection is appropriate for activities such as preplacement inspection for concrete, it is not adaptable to activities such as electrical cable pulling.
(2) The section should be tailored to fit inspection of ongoing work such as concrete placement, cable pulling, welding, etc.
Appendix STP-QAP-2.6-2, " Instructions for Originator" should address action on " invalid" NCRs as determined by the supervisor. As pointed out by the licensee, a statement should be included to the extent that if an NCR is not valid, as determined by the supervisor, it is returned to the originating QC inspector. Also, the reason for the disposition should be included on the NCR.
The FREA program, including trending was discussed with B&R engineering personnel on March 5, 1980.
The IE inspectors were informed that 100% re-review of approximately 6000 FREA's has been initiated to determine how FREA's have been used; if there was a change in design without describing how or why; or if the change caused by the FREA is properly documented.
The group explained that coding of FREA's is to be complete by April 1, 1980.
The first trending report is to be complete by April 15, 1980 with subsequent issue of a quarterly report.
Backfit of design will be complete by July 1, 1980.
(A completion date
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for civil / structural design backfit will be established pending review of data on July 1, 1980).
It was pointed out by a Brown and Root representative that there is no onsite approval of FREA's.
The General Construction Procedure GCP-21, " Field Requests for Engineering Action" will be revised by April 25, 1980.
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The IE inspectors determined, by review of records and discussions with the QA and Construction Training Coordinators, that three sessions for retraining of personnel in FREA and NCR procedures were held on January 11, 1980.
The three sessions included (1)
Civil / Procurement; (2) Mechanical / Electrical; and (3) Subcontract /
Administration.
Clerks and C00P's were not required to attend.
A makeup retraining sesu.on was held January 14, 1980.
Any personnel missing these two sessions were to be retrained by March 6, 1980.
IE will require further review of the outstanding issues in this action item, consequently, this item remains open.
c.
Action Item No. 3 Resolution of Disputes Between Construction and QA/QC Personnel Brown and Root issued a written policy statement which outlines specific steps to be taken when disagreements between personnel arise.
This procedure, STP-PGM-02, Revision No. O, January 7, 1980, " Pro-cedure for resolving disputes between construction and QA/QC Personnel" was reviewed by the IE inspectors. The procedure which defines the method for resolving disputes between construction and QA/QC Personnel was reviewed by the IE inspectors and noted that it defines an accept-able method for resolving disputes between construction and QC personnel.
The inspectors have no further questions at this time regarding this action item.
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d.
Action Item No. 4 Qualifications of Brown and Root QA and QC Personnel The IE inspectors reviewed with representatives from HL&P and B&R the status of this action item.
Level III inspectors have reviewed the bases by which QC personnel are qualified and the inspector's applicable work experience was reviewed in the light of his certification during the period when he was doing work.
It was determined by record review that none of approximately 150 inspectors were unqualified, but five did not have verification as to dates, etc.
These five have been placed on limited work until confirmatory data is received.
To verify information contained in qualification records, telephone calls have been made to previous employers and schools. When the employers and schools would not furnish confirmatory data, a letter of release, signed by the B&R employee, was sent to the employer
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and/or school. An arbitrary date of April 15, 1980 has been set for receipt of this material before further action is planned. At the
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time of the IE inspection, approximately 40 personnel still required verification.
Brown and Root representatives stated that the verifi-cation of previous employment and education is complicated by businesses and schools which no longer exist or some employees have been educated in foreign schools.
Actions identified for this action item have been implemented. The IE inspectors have no further questions at this time, e.
Action Item No. 5 Procedure Implementation in Regard to Concrete Pre-Planning and Placement Activities To assess implementation of procedures, the IE inspectors observed activities related to placement of concrete in slab MEl-S206A and S052 in the Unit 1 Mechanical / Electrical Auxiliary Building which occurred on March 13, 1980. Activities observed included pre-placement preparations and depositing, consolidation and finishing of concrete.
It was noted the HL&P personnel were performing surveillance as well as the B&R QC inspector who was inspecting placement activities.
It was observed that a concrete pump discharge line failed during the placement; however, the line was repaired and returned to service without any apna ant adverse effect on the quality of the concrete that was pla
_ crete placement continued by means of buckets during ths op outage.
The IE inspectors also reviewed the results of tests of concrete samples taken at the truck discharge point.
The test results appeared to meet acceptance criteria for slump and air content specified on the test records.
Concrete curing was inspected on March 14, 1980.
Although no items of noncompliance or deviations were identified during this activity, the placement was not considered large enough nor complex enough to provide a good determination of the thorough-ness of procedural implementation.
The IE inspectors discussed with responsible HL&P and B&R personnel preplacement inspection activities in regard to the in process inspection " punch list."
It was explained to the IE inspectors that the list contains items to be corrected or evaluated and accept-as-is at Pour Card sign-off.
When all items have been signed off, the
" punch-list" is signed by the QC inspector to verify the above, and attached to the Pour Card.
The " punch list" is originated by the Construction Engineer and the maintenance of it through the construc-tion and preplacement activity is his responsibility.
There is no mechanism to preclude entering on the list such items as may require an NCR or a FREA other than the Engineer's review of the list.
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The licensee and construction personnel Atated that Quality Construction Procedure A040KCCP-3, "Prepour Activities" would be revised to include a requirement for check for completion and sign-off of the " punch list" by the QC inspector and to make the
" punch list" a part of the Pour Card package.
Further discussion revealed that the " punch list" may contain safety-related itets and consequently is an activity affecting
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quality.
Consequently, the procedure for the " punch list" should
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be formalized to comply with Criterion V of Appendix B to 10 CFR 50.
This item will remain unresolved pending incorporation of the
" punch list" activity into a procedure.
This action item remains open.
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Action Item No. 6 Provision of Method for Judging When Reinspection of a Concrete Placement is Necessarv Brown and Root Quality Construction Procedure A040KCCP-3 "Prepour Activities," was revised to include reinspection criteria by Interim Change Notice No. 1, dated January 7, 1980.
The Interim Change Notice requires that, should undue delays occur after the concrete pour card signoff, QC shall consider climatic conditions, personnel traffic in the pour area, and work activities that may affect the pour area. QC will then reinspect for cleanliness of the pour, excess water (if applicable), and alteration caused by personnel traffic (if applicable). Results of reinspection will be documented on the applicable QC inspection report.
Training records indicated that Brown and Root QA/QC and construction personnel attended training sessions relative to CC?-3 in January 1980.
The IE inspectors had no further questions concerning this matter.
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Action Item No. 7 Ay mentation of the HL&P Site QA Staff Three members of the HL&P QA staff including the Projects QA Supervisor were temporarily assigned to the STP site to augment the site QA staff. The Projects QA Supervisor remains
on indefinite assignment to the site and is currently directing
STP QA activities. The other two individuals who were temporarily assigned to site QA have been released to return to their previous duties.
One of the individuals is intermittently involved in the resolution of the engineered backfill testing.
Five additional
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personnel including two civil, one electrical, one mechanical and one administrative will be added to the HL&P site QA staff.
In addition, changes in the project QA organization have been made with the removal of the Project QA Supervisor from the site QA chain of command and upgrading of the site QA Supervisor position.
Special hard hats have been prcvided to clearly identify HL&P QA personnel.
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Additional review and observation by the NRC will be required to determine the effectiveness of the changes in the site QA staff.
h.
Action Item No. 8 Refresher Training for Construction and QC Personnel Initial refresher training for construction and QC personnel was conducted on January 11 and 14,1980.
Subseqv.ent planned quarterly refresher training is described in B&R interoffice memo
" Expanded Refresher Training Schedule 1980," dated January 23, 1980 transmitted by Memo No. BC-22424 dated February 27, 1980.
Participants in the training include QA/QC Superintendents, General Foreman, Foremen, and Construction Engineers of the civil, coatings, electrical, mechanical, welding, and NDE disciplines.
The training consists of modules developed under the direction of the B&R Houston office Corporate Level III.
The training modules are presented by persons selected by the corporate Level III.
Craft journeymen and other construction personnel are not required to attend the refresher training.
The IE inspectors had no further questions concerning this matter.
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Action Item No. 9 Assessment of the Brown and Root Organization to Determine Cause of Perceived Harassment or Undue Pressure on QC Personnel
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A management assessment to determine the cause of the perception of harassment or undue pressure on site QC personnel was completed by Brown and Root in January 1980.
The management assessment concluded that the perception of harassment of QC could have existed in the past because of instances of confrontation between construction and QC.
Brown and Root engaged the services of an independent consultant to conduct a survey of QA/QC and construction personnel to oetermine the extent and causes of the perception of harassment or undue pressures on QA/QC personnel and to recommend actions which could be taken to correct adverse situations.that were identified. The consultant concluded that, based on interviews with individuals and small groups as well as analyzing questionaires completed by site QA/QC personnel, construction is
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not currently causing undue pressure or harassment directed at QA/QC personnel.
As a result of information developed during the management assessment, personnel changes have been made in the construction and QA/QC organizations.
In addition, Brown and Root has initiated the following actions:
(1) A complete revamp of the salary administration program for site QA/QC.
(2)
Reemphasis of the role of QA/QC to construction personnel.
(3)
Provisions for resolution of conflicts at the job site.
(See Item e of this section of the report).
(4)
Refresher training, meetings and seminars to strengthen the role and understanding of QA/QC.
(5) Improved communication by QA/QC management.
Additional review and observation by the NRC will be required to determine the effectiveness of the above actions.
3.
Meeting with Licensee Representatives A meeting with licensee representatives (denoted in paragraph 1) was held in Houston March 11, 1980 by the Region IV Chief of the Reactor Construction and Engineering Support Branch and members of his staff.
Matters discussed pertained to RRI functions including the licensee /NRC interface, reporting of 50.55(e) items, reporting of significant events, correspondence with the NRC, the need for periodic licensee /
RRI meetings, and improvement of communications between the licensee and the NRC.
Regarding communications, the senior licensee representative expressed concern that an apparent communications problem had developed between the licensee and Region IV.
He stated that he wished to reaffirm the
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policy of open communications between the licensee and the NRC.
The senior Region IV representative also expressed concern that a commumications problem had developed between the licensee and the RRI.
He stated that the RRI is the prime Region IV contact for all site related matters and discussed methods of improving licensee /RRI communications.
Reporting of 50.55(e) items was discussed.
The Senior Region IV representative stated that construction deficiencies must be promptly reported to the RRI within the twenty-four hour period after the i
deficiency is found.
Initial reporting may be by telephone.
If the deficiency is later determined to be not reportable, Region IV should be notified by letter of that determination.
If the deficiency is determined to be reportable, a written report is required thirty days from the date of prompt notification.
If insufficient information is available for a final report at thirty days, an interim report stating the status of the matter must be submitted to Region IV.
The interim
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- report should also state the date when the final report will be submitted or, if the final report date is unknown, subsequent interim reports should be submitted at thirty day intervals until a final report date is established.
The licensee was encouraged to discuss reportability of deficiencies with the RRI.
A handout, summarizing the reportability requirements of 50.55(e), was provided to the senior licensee representa-tive.
The senior Region IV representative also discussed reporting of incidents, accidents, unusual occurences, and other items of interest occurring at or related to activities licensed by the NRC.
For plants under construction the following events should be reported to the NRC.
Serious natural occurrences and their effects.
Serious fires or explosions.
Significant environmental events.
Actual or threatened sabotage - malicious mischief, bomb threats.
Demonstrations resulting in arrests or violence.
Lost or stolen licensed material.
Strikes which result in violence, damage or delay in the critical path of more th,an one month.
Deficiencies in design or construction which have the potential for delay in the critical path for more than one month.
An event which results in a fatality or a serious injury.
Events in which news media interest exists or is expected.
Other events of similar importance to those identified.
The licensee was requested to report such items to the RRI.
In the event the RRI is not available due to absence from the STP site the license was requested to report the above events and 50.55(e)
deficiencies directly to the Region IV office.
4.
Unresolved Items
< Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
An unresolved item disclosed during the inspection is discussed in paragraph 2.e.
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5.
Exit Meet 43 The IE inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on March 14, 1980.
The IE inspectors summarized the purpose and the scope of the inspection and the findings.
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