IR 05000498/1980021

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IE Investigation Repts 50-498/80-21 & 50-499/80-21 on 800728-0801 & 04.Major Area Investigated:Allegation of Maint Record Falsification & That Millwright Foreman Is Not Qualified
ML19347E480
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 08/28/1980
From: Driskill D, Herr R, Seyfrit K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML16251A407 List:
References
50-498-80-21, 50-499-80-21, NUDOCS 8104270460
Download: ML19347E480 (11)


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U. S. NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Investigation Report No. STN 50-49r./80-21; 50-499/80-21 Docket No. 50-498; 50-499 Licensee: Houston Lighting and Power Company Facility:

South Texas Project, Units 1 and 2 Investigation at: Bay City, Matagorda County, Texas Investigation Conducted: July 28 - August 1, and August 4, 1980 Investigators:

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I/ [A f/[fd R. K. Herr,' Investigation Specialist Date/

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D. D. Driskill estgationSpecialist Date Approved By:

M N-28'86 Karl V. Seyfrit, r ctor Date Summarv Investigation on July 28-August 1, and August 4, 1980; Report No. 50-498/80-21; 50-499/80-21.

Area Investigated l

Allegations that Brown & Root, Inc. (B&R) maintenance records in the Perm nent Plant Maintenance Department were falsified and that a B&R millwright foreman is not qualified.

This investigation involved 75 investigative hours by two NRC investigators.

Results Allegations that maintenance records were falsified and that a millwright foreman is not qualified, were confirmed.

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INTRODUCTION The South Texas Nuclear Project (STP), Units 1 and 2, is currently under con-struction near the town of Bay City, Texas. Houston I.ighting and Power Company (HIAP) is the construction permit holder, Brown & Root, Inc. (B&R), is the architect / engineering and constructica firm.

REASON FOR IhTr.STIGATION On July 22, 1980, the NRC Resident Reactor Inspector (RRI) at STP was contacted by Individual A, who alleged that B&R naintenance records have been falsified.

Individual A stated that he poscessed and would provide docu:nents which would substantiate his allegation.

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SUMM.ARY OF FACTS On July 22, 1980, Individual A entered the RRI office at STP and explained that over the past few conths 3 two employees had been terninated by B&R for falsifi-cation of records.

Individ C A explainei that recently a foreman war identified as falsifying records; however, the individual was not terninated because he had sone " stroke" with higher superrision/nanagenent.

Individual A related the following specific allegation.

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That Individual K falsified Fernanent Plant Maintenance (PPM) records identified as Cards No. M-1018B and M-10193 cn June 24, 1980, wherein the equipnent was not inspected as required and the records were falsified to indicate the _tspection had been conducted.

During the course of this investigation, another allegation surfaced wherein individuals alleged:

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That a millwright foreman (Individual K) is not qualified.

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DETAILS 1.

Persons Contacted Principal Licensee Employees

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G. W. Oprea, Jr., Executive Vica President

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  • R. A. Frazar, QA Manager
  • L. D. Wilson, QA Supervisor Present B&R Employees
  • R. H. Leasburg, Site Manager
  • G. Magnuson, Attorney other Individuals l

Individuals A through U

  • Denotes those attending exit interview.

2.

Investigation of Allegations Allegation No. 1

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That Individual K falsified Permanent Plant Maintenance (PPM) records

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identified as Cards Nos. M-1018B and M-10193 on June 24, 1980, wherein the equipment was not inspected as required and the records were falsified j

to indicate the inspection had been conducted.

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Investigative Findings

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On July 29, 1980, Individual A was interviewed and executed a signed

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state =ent, Document 1.

Individual A stated that on July 17, Individual C, a PPM record reviewer, pointed out to him that Individual K had signed off on two maintenance records indicating that he had performed the proper maintenance inspections.

Individual C complained that the two pieces of equipment, identified as M-10183 and M-1019B (vacuum degasifier pumps)

had been previously identified as inoperable by Individual B.

Individual A stated that he, along with Individuals C and G, i= mediately inspected

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the equipment.

Individual A explained that the =aintenance card instructions state that the shafts of the equipment are to be rotated; however, it was discovered that the shaf ts were " seized up" (frozen) and Sa!. 'seen in that condition since May 1980. Individual A stated that ; '. saintenance cards in question, siped off by Individual K on June 24, 1980, indicated l

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i that he rotated the shafts.

Individual A remarked that his boss, Individual G, claimed he reported the falsification to management personnel, identified as i

Individuals S and T.

Individual A commented that subsequently he learned that management allowed Individual K to make a late entry correction on the mainte-

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nance cards and that no action was taken against Individual K.

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explained that during the past six months he had two men terminated for falsifying

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similar records and that Individual I was allowed to falsify records and remain on the job because of " stroke" with higher asnagement.

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Interview of Individual B On July 29, 1980, Individual B was interviewed and executed a signed statement, Document 2.

Individual B stated that on May 20, 1980, he inspected vacuum

I degasifier pumps, identified on maintenance cards M-1018B and M-10193, and found them " seized up."

Individual B explained that he reported the situation and made the proper notation on the maintenance cards.

Individual B stated i

that to the best of his knowledge, the equipment is still inoperable.

Indivi-dual B added that when he worked for Individual K, that on one occasion, Indivi-dual K told him, along with co-workers Individuals D and E, that they were not to pull equipment maintenance cards and take them to the field when performing maintenance as had been done in the past and that in the future they are to per-form maintenance on equipment from memory.

Individual B remarked that Individual K explained that after the maintenance on equipment was conducted the inspectors could then sign off the equipment cards in the maintenance office where he

(Individual K) would maintain. hem.

Individual B emphasized that he does not presently work for Individur'. K and could not provide any further information.

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Interview of Individual r

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On July 30, 1980, Individual C was interviewed and executed a signed statement, Document 3.

Individual C stated that on July 17, 1980, while reviewing maintenance records, he discovered two vacuum degasifier pumps, P105A and P105B, l

identified on maintenance cards M-1018B and M-1019B, respectively, that had been signed off by Individual K as operating properly.

Individual C explained that i

these particular pumps were known to him to be inoperable and that a Noncon-formance Report (NCR) was written on both pumps, and that corrective action had not yet been taken.

Individual C stated he notified his supervisor, Individual G, and subsequently he and his supervisor and Individual A all inspected the pumps and found the pumps to be inoperable.

Individual C stated that he suspected that Individual K had falsified records; however, he was not surprised.

Individual C explained that on or about May 20, 1980, Individual K had told him that he had no discrepancies to report, which contra-l dicted comments that he (Individual C) had heard from Individual K's subordi-nates, identified as Individuals B, D and E.

Individual C remarked that on May 21, 1980, he, along with his supervisor, Individual G, conducted their own inspection between 0700 and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br />, and found 39 discrepancies (Document 13).

Individual C stated that it was his understanding that Individual G

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reported the situation to upper management, identified as Individuals S and T.

Interview of Individual D On July 30, 1980, Individual D was interviewed and executed a signed statement, Document 4.

Individual D stated that in June 1980, his supervisor, Individual K, held a meeting with him and his co-workers, identified as Individuals B and E, and explained a new maintenance inspection policy.

Individual D remarked that Individual K stated the following policy is now in effect:

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To discontinue reporting discrepancies on any items which had previously been reported.

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Not to inspect the interiors of vessels during integrity checks.

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Not to write up discrepancies on the storage area.

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Not to write up discrepancies on equipment that was dusty.

Individual D advised that he complied with Individual K's instructions and did not report the above type of discrepancies.

Individual D added that in mid-June 1980 he noticed that he had not been receiving the discrepancy reports back from the PPM office as had been the previous procedure.

Individual D stated that he made inquiries to the PPM office; however, he was told that they had not received any of his reports.

Individual D explained that up to that time, in mid-June, he had provided his discrepancies to Individual K who, in turn, supposedly delivered them to the PPM office.

Individual D stated that

since mid-June 1980, he has personally handed his discrepancy list to the PPM l

office, which has corrected the problem.

Individual D also remarked that on June 30, 1980, Individual K decided to train Individual J on the proper proce-

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dure of inspecting equipment and signing off equipment cards.

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claimed he observed Individuals K and J enter the MEA building which housed approximately 50 pieces of equipment.

Individual D stated that about 20 minutes later he saw Individuals K and J, at which time they claimed they had completed the inspection.

Individual D emphasized that he questions this inspection, for the following two reasons; (1) that he had inspected the equipment in question in the MEA building on numerous occasions and it takas him about two hours, and (2) that he had the only key to a compartment that contained two centrifugal charging pumps with motors, and that if these two pumps were inspected and signed off on the maintenance cards, then they were falsified.

Individual D explained that he did not release his key or provide his key to anyone during the time that Individuals K and J were inside the MEA building.

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Interview of Individual E On July 30, 1980, Individual E was interviewed and executed a signed statement Document 5.

Individual E stated that on or about May 1980, Individual I asked

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him (Individual E) along with Individual B and Individual D to meet at which time Individual I reported new inspection policies that were to be followed Individual E explained that Individual I then stated that during the inspection

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of equipment that we were no longer to report discrepancies on equipment previ-ously reported as having discrepancies, discrepancies of dirt on the equipment, and discrepancies found in the storage areas.

Individual E advised that he followed Individual K's instructions and did not report the above discrepancies when detected.

Individual E explained that during the spring of 1980, Individual K told him to turn in all discrepancies that he found on various equipment to him (Individual K) and he would then submit the discrepancies to the PPM office.

Individual E stated that sometime later, when he did not receive reports from the PPM office concerning his discrepancies, he made inquiries to the office as to what had happened to his (Individual E's)

discrepancy reports.

displayed two pages of discrepancies at which time Individual E sta came somewhat confused because he had turned in 8 or 9 pages of discrepancies.

Individual E advised that he had discussed this situation with other co-w and decided to turn in his discrepancies personally to the PPM office in the future.

Individual E added that in May 1980, Individual K initiated a new policy wherein approximately 50 percent of the inspections were to be con-ducted from memory.

Individual E explained that Individual K told him that he would hold the maintenance cards in his possession and when he (Individual E)

completed an inspection, he would then meet with Individual K and record or sign off on the maintenance card regarding the work that had been completed.

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i Individual E explained that this is somewhat difficult in that there are numerous pieces of equipment, numbering in the hundreds, and that he can not always keep track of what equipment needed what maintenance.

Interview of Individual F On July 31, 1980, Individual F was interviewed and executed a signed statement, Document 6.

Individual F stated that in mid-June 1980, he had discovered two degasifier pumps that had frcren shafts and NCR tags were placed on the two Individual F explained that on July 17, 1980, he had in his possession pumps.

the maintenance cards for the two pumps in question, maintenance cards M-1018B and M-1019B, and noticed that Individual K had signed off the cards on June 24, 1980, indicating that the corrective action had been completed and/or

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that there were no discrepancies.

Individual F stated he immediately checked the pumps and discovered the two NCR tags were still present and no corrective action had been taken.

Individual F stated it was obvious to him the maintenance cards had been falsified by Individual K.

Individual F stated as a result of this situation he immediately informed Individual K's upper management level supervisor, Individual T, of the falsification of the maintenance cards and provided the maintenance cards to Individual T for his examination.

Individual F explained that Individual T stated he would look into the matter.

Individual F renstked that subsequently Individual T returned the maintenance cards to him and explained that Individual K had merely made an " error".

Individual F stated he examined the maintenance card and found that both cards had been amended with a " late entry" that corrected the error.

Individual F stated that neither he nor Individual T made any further statements.

Interview of Individual G On July 31, 1980, Individual G was interviewed and executed a signed statement, Document 7.

Individual G stated that on July 17, 1980, Individual C reported to him that Individual K apparently had falsified two maintenance cards wherein he (Individual K) had signed off maintenance performed on equipment that was known to be inoperable.

Individual G explained that he, along with Individuals

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A and C, reinspected the equipment in question and found the shaft of each motor to be frozen; however, the maintenance card indicated that Individual K had rotated the shafts.

Individual G explained that over the past eight months, he has fired or authorized the firing of three individuals (Document 12 refers)

for the same type of falsificatica of maintenance records.

Individual G explained, because Individual K was in a supervisory position, he reported his findings to upper management for proper resolution.

Individual G remarked, a few hours later, upper management personnel (Individuals S and T), along with Individual K held a conference which resulted in Individual K being allowed to make a late entry correction on the maintenance cards, with no further action.

Individual G claimed he was somewhat surprised in that he knew that Individual K had " stroke" with upper management; however, he did not believe that Indivi-dual K had that much " stroke."

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l Individual G explained he had previously received complaints from Individual

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K's subordinates concerning having to work (conduct maintenance) on equipment from memory without benefit of the maintenance cards.

Individual G also advised l

he received compiaints that Individual K had initiated a new policy wherein

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he allegedly told his men the following:

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Not to make deficiency reports on deficiencies previously reported.

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Not to inspect interiors of vessels during integrity checks.

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Not to write up storage area discrepancies.

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Not to write up discrepancies on dirty or dusty equipment.

Individual G explained he confronted Individual K on the above new policy at which time Individual K merely explained, "I do not have discrepancies,"

and made no further comment.

Individual G explained, as a result of Individual K's attitude, he and Individual C conducted their own inspection of Individual K's equipment and within four hours discovered and recorded 39 discrepancies (Document 13).

Individual G remarked he reported this incident to Individual S (upper management); however, Individual S took no action or interest in the report.

Interview of Individual J On August 4, 1980, Individual J was interviewed and executed a signed state-ment, Document 8.

Individual J stated that he has worked for Individual K since May 1980 as a maintenance helper.

Individual J stated that on June 30, 1980, Individual K approached him and told him that he was going to train him on how to inspect and sign off maintenance cards.

Individual J explained that Individual K took him to the MEA building wherein 25 to 30 pieces of equipment were located.

Individual J stated that as they walked through the building,

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Individual K pointed out various pieces of equipment.

Individual J admitted that he only checked about half the equipment properly, however, signed off all of the maintenance cards explaining that he was only following orders from Individual K.

Individual J cited one example of this falsification which l

involved the centrifugal pumps located in a locked compartment (Documents 16 and 17 refer). Individual J remarked that neither he nor Individual K had a key for i

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the compartment and the maintenance called for a " heat check".

Individual J explained that Individual K told him to place his hand on the outside of the wall of the compartment and if the wall was warm, to sign off the maintenance card.

Individual J stated he followed Individual K's orders by placing his hand on the wall, adding that the wall was warm and then subsequently signed off the maintenance card.

Individual J explained that Individual K told him not to report discrepancies on maintenance cards if the discrepancies had been previously reported, to use his own judgment about integrity inspections regarding whether or not to inspect the interior of the vessels, not to write discrepancies on the storage area, and not to write discrepancies on dirty equipment.

Individual J admit-ted he had falsified numerous maintenance records under the direction of Individt.i K.

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Interview cl Ir.dividual K On August 4,1980, Individual K was interviewed and executed a signed state-ment, Document 9.

Individual K admitted he falsified Maintenance Card M-1018B concerning a vacuum degasifier pump, P-105A, when he signed off the maintenance card indicating he rotated the shaft of the pump. Individual K stated that he did not rotata the shaft. Individual K also admitted that during a training inspection period he ordered Individual J to sign off a couple of maintenance cards on equipment that they could not inspect, in that the equipment was located inside a locked building.

l Individual K explained that someone (identification unknown) in upper management j

told him not to report discrepancies if the discrepancies had been previously l

reported, adding that he passed this word along to his men.

Individual K also remarked that he told his men not ta report discrepancies in the storage areas,

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that it was not necessary to inspect the interior of vessels during integrity checks on each occasion, and not to report discrepancies on dirty equipment.

Individual K stated that he additionally told his men to inspect some equipment by memory, explaining that the maintenance cards could not always be located in the PPM office when the inspections were required.

Individual K remarked that

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his =en could return to the PFH office later after they conducted the inspection and sign the maintenance cards when they were located.

Individual K explained that Individuals S and T, his supervisors, confronted him concerning the falsification of his maintenance records and told him to make a late entry correction on =aintenance cards and that this would take care of the falsification. Individual K stated that Individuals S and T told him not to make incorrect entries on maintenance cards in the future.

Interviews of Individuals 0, P, Q, and R On July 31, 1980, Individuals 0, P, Q, and R, all EL&P QA department personnel, with past experience in inspecting the B&R PPM office were interviewed con-cerning their knowledge of any falsification of records. None of the indivi-duals claimed they had knowledge of any suspected falsification of maintenance records.

Individuals 0, P, Q, and R all stated that failure to record discrep-ancies on maintenance cards, even if the discrepancies were previously reported, constitutes falsification. Individuals 0, P, Q, and R concurred that maintenance cards are to represent current status on equipment and failure to report discrepancies does not present an accurate status of the equipment.

Individuals 0. P, Q, and R stated that the manner in which they inspect the records of the PPM department of B&R would not reflect any falsification on the part of PPM inspection personnel.

Individuals 0, P, Q, and R explained that as of July 31, 1980, HL&P had not performed the July inspection of the PPM department of B&R.

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l Allegation No. 2 That a millwright foreman, Individual K, was not qualified.

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Investigative Findings

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Interviews of Individuals A, C, E, F, G, H, J, N, and B representing one

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millwright general foreman, one millwright foreman, two millwright journeymen,

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one millwright helper, two system engineering technicians, one QC inspector, l

and one systems engineer supervisor, all concurred that Individual K was not qualified for his position as a millwright foreman.

Individuals H and I both executed signed statements, Documents 10 and 11, respectively, specifically covering Individual K's lack of qualifications.

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Individual H advised that during his interview with I.ndividual K (prerequisite for millwright foreman placement), he (Individual H) determined that Individual

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K was not qualified for the job and reported this to Individual T.

Individual H explained that Individual T told him that Individual U recommended Individual K for the job and that he (Individual T) felt that Individual K could work well in the PPM department.

Individual H explained he placed Individual K into the position of millwright foreman based on Individuals T and U's recommendations.

Individual H added that Individual U is no longer working for B&R.

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Interview of Individual K regarding his qualifications as a millwright foreman resulted in Individual K admitting that he was not qualified for the position of millwright foreman.

Individual K's admission is included in his signed statement, Document 9.

Interview of Individual N disclosed that B&R does not presently have a job description of millwright foreman, but B&R is in the

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process of writing position descriptions for all millwright personnel.

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CAPTIONED DOCUMENTS The written statements and copies of all documents identified herein relating to these allegations are maintained in the NRC, Region IV office. The following is a list of documents utilized in this report.

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Document 1 - Statement of Individual A dated 7-24-80 2.

Document 2 - Statement of Individual 3 dated 7-29-80 3.

Document 3 - Statement of Individual C dated 7-30-80

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Dcoument 4 - Statement of Individual D dated 7-30-80 5.

Docu=ent 5 - Statement of Individual E dated 7-30-80

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Docu=ent 6 - State =ent of Individual F dated 7-31-80 7.

Document 7 - Statement of Individual G dated 7-31-80 8.

Document 8 - Statement of Individual J dated 8-04-80 9.

Document 9 - Statement of Individual K dated 8-04-80 10.

Docu=ent 10 - Statement of Individual I dated 7-31-80 G

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Docu=ent 11 - Statement of Individual E dated 7-31-80 12. Document 12 - Assign =ent/ Terminations dated 6-10-80 13. Document 13 - Maintenance Discrepancy List (39) dated 5-21-80

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Document 14 - Maintenance Instruction Card No. M-1018B dated 4-15-80 15.

Document 15 - Maintenance Instruction Card No. M-10193 dated 4-15-80 16.

Docu=ent 16 - Maintenance Instruction Card No. M-0368-C dated 4-21-80 17. Docuesta 17 - Maintenance Instruction Card No. M-0369-D dated 4-21-80 l

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NUCLEAR REGULATORY COMMISSION

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REGloN IV

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611 RYAN PLAZA DRIVE.sulTE 1000 a

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October 17, 1980 In Reply Refer To:

RIV Docket Nos. 50-498/Rpt. 80-22 50-499/Rpt. 80-22 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Mr. D. D. Driskill of our staff on July 29, 1980, of activities authorized by NRC Construction Pemits Nos. CPPR-128 and CPPR-129 for the South Texas Project, Units Nos.1 and 2, concerning allegations of incompetency by designers of the piping systems, poor perfomance by an STP contracting fim, and possible problems relating to stress evaluations on piping. The investigation findings are discussed in the enclosed investigation report.

Based on the investigation findings, the allegations concerning incompetency by designers of tne piping systems and poor perfomance by an STP contracting fim were not sucstantiated. A detailed Vendor Branch inspection of Brown &

Root's piping stress analysis has been scheduled for October 19, 1980.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Feceral Regulations, a con' af this letter and the enclosed investigation report will be placed in the NRC's Public Document Room.

If

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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 cays

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of the date of this letter, reouesting that sucn information be withheld i

from public disclosure. The aoplication must include a full statement of the reasons wny it is claimed that the infomation is proarietary.

The appli-cation should be prepared so that any proprietary infomation identified is

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STAFF EXHIBIT N0. 68

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liouston Lighting and

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Power Cogany

October 17, 1980

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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 tnis investigation, we will be pleased to discuss them with you.

Sincerely,

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Karl V. Seyfrit

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Director

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Enclosure:

IE Investigation Report No. 50-498/80-22, 50-499/80-22

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U. S. NUCLEAR REGULATORY C0!91ISSION

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0FFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Investigative Report No.

50-498/80-22; 50-499/80-22 Docket No.

50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Facility: South Texas Project, Units 1 and 2 Investigation at: Bay City, Matagorda County, Texas Investigation conducted: July 29, 1980 Investigatcr:

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.t -it SC D.lMDnr111, InvestigacTon Specialist Date

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Approved by:

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K. V. Seyf rit, ITirecto Regi n IV Date Summarv

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Investigation on July 29, 1980 (Report No. 50-498/80-22; 50-499/80-22).

Area Investigated:

Investigation concerned allegations that designers of South Texas Project

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(STP) piping systems were incompetent, that supervisors responsible for approval of piping system designs are not competent, and that Nuclear Power Service, Inc., is the worst contractor at the STP site. An investigation was also conducted relating to the statement "Please investigate B&R stress evaluation on piping," which was provided as one of various statements /

allegations made regarding STP. This investigation involved eight (8)

investigator hours by one (1) NRC investigator.

Results:

Allegations that designers and approvers of STP piping systems and designs were incompetent were not substantiated. No facts were identified wnica would support the claim that Nuclear Power Service, Inc., is the worst contractor at STP. A review of B&R's stress evaluations on safety related piping at STP will be conducted during an NRC, Region IV, Vendor Inspection re-,

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INTRODUCTION The South Texas Nuclear Project (STP), Units 1 and 2, is currently under construction in the town of Bay City, Texas. Houston Lighting and Power Company (HL&P) is the construction permit holder; Brown and Root, Inc. (B&R)

is the architect / engineer and construction firm.

REASON FOR INVESTIGATION On June 13, 1980, an anonymous letter was received at NRC Region IV Office which enumerated ten existing general concerns of the writer at STP.

In closing, this letter contained the statement "Please investigate B&R's stress evaluations on piping." On June 27, 1980, the NRC Headquarters Duty Officer received a telephone call from an anonymous caller who alleged that,

" designers of piping systems for STP are incompetent, that supervisors who approve piping system drawings are incompetent, and that Nuclear Power Service, Inc., is the worst contractor at STP."

SUMMARY OF FACTS On June 13, 1980, an anonymous letter was received at NRC's Region IV office which identified ten existing general concerns, of the writer, at STP.

An eleventh concern was identified in the letter with the statement "Please investigate B&R's stress evaluations on piping." On June 27, 1980, the NRC Headquarters Duty Officer received a telephone call from an anonymous caller who alleged that the designers of the piping systems for the South Texas Pro-ject are not competent and that they do not know the basics of civil engineering.

The caller went on to say that supervisors who are signing drawings for approval are not competent and that Nuclear Power Service, Inc., is the worst contractor at the STP site.

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NUCLEAR REGULATORY COMMISSION UNITED STATES Oh I Ik

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AALINGTON, TEXAS 76012

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September 15, 1980 In Reply Refer to:

RIV Docket No. 50-498/ Rot. 80-23 50-499/Rpt. 80-23 Houston Lighting and Power Company Attn: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the inspection conducted by our Resident Inspector, Mr. H. S.

Phillips, during the period of August 1980 of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. R. A. Frazar and other members of your staff during the inspection period.

Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with person,nel, and ooservations by the inspector.

Within the scope of the inspection, no items of non

REGION IV==

Report No. 50-498/80-23 50-499/80-23 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda, Texas Inspection conducted: August 1980 Inspecto i!

/

yh 9- /2 - PO Ft. S. PhiH ips, Resicent Reactor Inspector Date

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.9!/2!8d Approved:

W. A. Crossman, Chief, Projects Section Date

'

Inscection Summary:

Inscection of Auoust 1980 (Report 50-498/80-23: 50-499/80-23)

Areas Inscected:

Routine, announced inspection by tne Resident Reactor Inspector (RRI) included independent inspection performed during site tours, follow-up inspections relative to noncompliances, unresolved matters and show cause order items.

This inspection involved sixty-three (63)

inspector hours by one NRC inspector.

Results:

No items of noncertpliance or deviations or unresolved matters

!

were identified.

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DETAILS 1.

Persons Contacted Princioal Licensee Emoloyees R. A. Frazar, Quality Assurance Manascr L. D. Wilson, Project QA Supervisor (. Mechanical)

J. W. Soward, QC Svervisor T. J. Jordan, Supervisor Qualtty Systems R. A. Carvel, Project QA Supervisor { Civil /StrJCtural[

0. W. Bohner, Project QA Sopervisor (Electrical)

2.

Licensee Action on Previcas Inscection Findinos On August 19, 1980, the NRC held a public meeting in Bay City, Texas, to discuss with the licensee and contractor their actions taken to date relative to the NRC Show Cause Order to RL&P dated April 30, 1980.

NRC Headquarters and Region IV staff personnel reviewed the response to the Order and discussed areas which required clarification or additional infomation. The second part of the meeting was devoted to answering any questions posed by the people of Bay City and other interested citizens.

On August 20, 1980, a Region IV follow-up inspection task force was fomed to assure an organized approach rela:ive to the review of Investigation Report 50-498/79-19'; 50-499/79-19, Appendix A Items of Nonccmplinaces and Unresolved Items.

? cur Region IV inspectors, including the RRI, were assigned to the task force and each _ member was assigned all open items.

On August 21, 1980, the RRI sent an interoffice memo to the HL&P QA Manager advising him of open items assigned to each team member. The memo requested that the licensee reytew the open items listed and indicate those items which were ready to close.

The licensee letter, dated August 28, 1980, from Mr. G. W. Oprea, Jr., HLaP Executive Vice President to Mr. Karl Seyfrtt, NRC Region IV Director, listed completed I

comitments ready for review.

3.

Site Tours l

The RRI inspected various site areas as follows: Units 1 and 2 Reactor (

Containment, Auxiliary and Fuel Handling Buildings; Warehouses A, B, ano C; Calibration Laboratory; Concrete Batch Plant, Pittsburg Test Laboratory;

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and various laydown areas for reinforcement bar, structural steel embeds, l

and piping.

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No items of noncompliance or deviations were identified.

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Management Meetings i

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The following meetings were held during the subject inspection period.

Attendees Subject Date HL&P QA Mgr; Allegations regarding PPM 8-4+B0 RIV and Resident records and piping design Inspector HL&P OA Mgr; Concrete pour delay because of 8-5-80 Resident Inspector a concern relative to stainless steel fuel poci liner plate

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being in contact with the car 5on steel stiffners welded behind the liner plate.

HL&P Construction Action taken relative to 8-4-80 Mgr B&R Construction allegations on PPM records.

Mgr; Resident Inspector

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HL&P Mgr., Resident Licensee advised RRI of OC 8-14-80 Inspector Record with a false entry.

QC inspector was terminated.

NRC Headquarters Show Cause Response 8-18 80

& Region IV Personnel

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NRC Meeting with Show Cause Response; answered 8-19-80 Licensee, Contractor que tions asked by public.

Personnel & public.

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October 24, 1980 Docket No. 50-498/Rpt. 80-26, 50-499/Rpt. 80-26

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Houston Lighting and Power Company

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ATTN: Mr. G. W. Oprea, Executive l

Vice President Power Plant Construction and

Tee b4e=1 Services

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Post Office Box 1700 i

Houston. Texas 77001

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Gentlemen:

This refers to the investigation conducted by Messrs. R. K. Herr and J. I. Tapia of our staff on September 4, 5 and 9, 1980, of activities authorized by NRC Construction Permits Nos. CPPR-128 and 129 for the Scuch Texas Project, Units No.1 and 2, concerning anegations of audit deficiencies of BE audit personnel and unqualified personnel employed by B E.

,t The investigation findings are discussed in the enclosed investigation report.

i Based en the investigation findings, the anegations have no merit.

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 ictter 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

l public disclosure. The application must include a fun stacament of the reasons I

why it is claimed that the information is proprietary. The application should

!

be propered so that any proprietary information identified is contained in an

,

enclosure to the application, since the application without the enclosure vill l

also be placed in the Public Doctament Room. If a do not hear from you in this regard within the specified period, the report win be placed in the Public

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Document Room.

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l STAFF EXHIBIT N0. 70

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Houston Lighting & Power Co.

October 24, 1980

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

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Sincerely,

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'4 C. Seif.Me Chief

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Reactor base,:uction and i

Engineering Support Branch

Enclosure:

IE Investigation Raport No. 50-498/80-26; 50-499/80-26

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U. S. NUCLEAR REGULATORY C0t9 FISSION

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OFFICE OF INSPECTION AND ENFORCE!fE.Yr

REGION IV

Investigation Report No. 50-498/80-26; 50-499/80-26 Docket No. 50-498/50-499

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Licensee: Houston Lighting and Power Company Facility: South Texas Project, Units No. 1 and 2 Investigation at: Bay City,tiatagorda, County, Texas Investigation Comducted: September 4, 5 and 9, 1980 Investigator:

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7 g-7/pyg R. K. lierr, Investigation Specialist Date Inspector:

Q lO-3.Oc J.1./Japia, Rea(tpr Inspector Date Enginishring Supp#t Section RC&ES Branch Reviewed by:

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RCSES Branch Investigacion Summary Investigation on September 4, 5 and 9, 1980 (Report No. 50-498/80-26; 50-499/

80-26)

Areas Investigated: Allegations that Brown & Root, Inc. (B&R) audit section

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intimidated by Brown and Root personnel. This investigats.on involved 32 investigator-hours by one NRC Investigator and one NRC Inspector.

Results: Investigation disclosed that the allegation concerning audit defi-ciencies was satisfactorily addressed in a report recently submitted by the RRI (See NRC Inspection Report No. 50-498/80-18; 50-499/80-18). Further investi-gation disclosed that the other allegations have no merit.

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REGloN IV

$11 RYAN Pt.AZA oRIVE. SUITI 1000

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December 19, 1980 In Reply Refer To:

RIV Docket No. 50-498/Rpt. 80-27

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50-499/Rpt. 80-27 Houston Lighting and Power Company Attn: Mr. G. W. Oprea, Jr.

?;ecutive Vice President Post W.' ice Box 1700 Hous ton, Texas 77001

,

Gentlemen:

'

This refers to the inspection conducted by our Resident Reactor Inspector, Mr. H. S. Phillips, during October 1980, of activities authorized by NRC Construction Pennits No. CPPR-128 and 129 for the South Texas Project, Units No.1 and 2, and to the discussion of our findings with Mr. R. A. Frazar 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 consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.

L l

Ouring the inspection it was found that certain of your activities were not l

conducted in full compliance with NRC requirements. Consequently, you are required to respond to this matter, in writing, in a

REGION IV==

Report No. 50-498/80-27; 50-499/80,27 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name:

South Texas Project, Units 1 and 2 Inspection at:

South Texas Project, Matagorda, Texas Inspection Conducted: October 1980

/Zf//h Inspecto w

. 5. Phillips, Resicent Reactor Inspector Date

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Approved:

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

Inscection Summarv:

Insoection of October 1980 (Recort 50-498/80-27: 50-499/80-27)

Areas Inscected:

Routine, announced inspection oy tne Resicent Reactor Inspector (RRI) inclucea follow-up inspections relative to noncompliances, unresolved matters, and Show Cause Order items.

This inspection involved one hundred fifty-nine inspector-hours by one NRC inspector.

Results: One violation was identified in one of three areas inspected (Violation -

failure to follow procedures paragraph 2.b.(3)(a) 4).

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Persons Contacted Principal Licensee Employees G. W. Oprea, Executive Vice President R. A. Frazar, Quality Assurance Manager R. A. Carvel, Project QA Supervisor (Civil / Structural)

T. J. Jordan, Supervisor Quality Systems J. W. Soward, QC Supervisor L. D. Wilson, Project QA Supervisor (Mechanical)

J. B. Anderson, Quality Systems P. G. Guidry, Quality Systems Management Analysis Comoany (MAC)

W. J. Friedrich, QA Manager for Brown and Root (B&R)

O. J. Harris, Quality Engineering Manager for B&R J. L. Ruud, Quality Engineer for B&R 2.

Licensee Action on Show Cause Order, April 30, 1980 The RRI reviewed Show Cause Order,Section V. A., Items 1,2,3,5,6,7,8, 9 and 10 in a general manner and determined that action had been takun or was sufficiently comolete to allow the RRI to recommend the restart of AWS welding on a limited basis.

Items 2, 3 and 10 were reviewed by discussing those items with'the RIV inspectors responsible for these items. The RIV inspectors' input on Items 2, 3 and 10 was positive relative to recommending limited work.

The RRI determined that Items 1, 5, 6 and 9, assigned to the RRI, should receive a more detailed review and/or follow-up inspection prior to recommending resumption of any work activity that was stopped.

The following are the results of that review:

(0 pen) Show Cause Order, Item V.A.(1): Management Consultant Review.

HL&P Management of Program to Control All Aspects of the South Texas Project; Revision of Organizational Responsibilities to Control the Design, Procurement and Construction Activities of the Licensee's Prime Contractor, Brown & Root, Inc. (B&R), and HL&P Overall Responsibility for QA/QC Program, a.

Review of Bechtel Audit The RRI determined that the Houston Lighting & Power Company (HL&P) Audit Group was tracking the status of the Bechtel audit findings.

The disposition of the audit findings appeared to be acceptable. On October 19, 1980, HL&P began an audit of HL&P and B&R organizations to verify imolementation of corrective action.

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UNITED STATES e

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NUCLEAR REGULATORY COMMISSION

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REGloN IV

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511 RYAN PLAZA DRIVE. suite 1000

ARUNGTON. TEXAS 70011

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In Reply Refer To:

November 7,1980 RIV Docket i:o. 50-498/Rpt. 80-28 50-499/Rpt. 80-28 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Offica Box 1700 Houston, Texas 77001

Gentlemen:

This refers to the inspection conducted by Mr. D. P. Tomlinson of our staff during the periods October 6-10 and October 14-17, 1980, of activi-ties authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units No.1 and 2, and to the discussion of our findings with Mr.-R. A. Frazar and other members of your staff at the conclusion of the inspection.

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

consisted of selective examinatica of procedures and representative j

records, interviews with personnel, and observations by the inspector.

l Within the scope of the inspection, no items of nonceapliance were identified.

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

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 t

l 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 l

necessary that you submit a written application to this office, within 20 days of the date of this letter, recuesting that such information be withheld from public disclosure. The application must include a full statement of the reasons wny it is claimed that the infomation is proprietary. The acolication should be prepared so that any proprietary information identified is contained in an STAFF EXHIBIT NO. 72 t>9L S Tot'A190613

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Houston Lighting and Power Company-2-November 7, 1980 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 inspection, we will be pleased to discuss them with you.

Sincerely,

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W. C. Sei 1,e, Chief Reactor C struction and Engineering Support Branch

Enclosure:

IE Inspection Report No. 50~498/80-28

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50-499/80-28

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-498/80-28; 50-499/80-28 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 Inspection Conducted: October 6-10 and October 14-17, 1980 Inspector:

///

Eb g. P. Tomlinson, Reactor Inspector, Engineering Bat 4 Support Section

.

Other A

REGION IV==

Investigation Report No.

50-498/80-29; 50-499/80-29 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Facility: South Texas Project, Units Nos. 1 and 2 Investigation at: Houston, Harris County, Texas Investigation Conducted: September 24, 1980 Investigator:

M.

. e - : - - i-D. D. Driskill, Investigation Specialist Date l

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_ /0 -/Y'fD T. L. DiGaloma, Investigative Aide (Co-Op)

Date

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Reviewed by:

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Date Summarv_

l Investigation on September 24 1980 (Report No. 50-498/80-29: 50-499/80-29).

Area Investigated: Allegation that Brown & Root, Inc. (3&R) knowingly tolerates drug use by its employees which affects the quality of construction work being done at the South Texas Project (STP). This investigation involved 15 investi-gator hours by one NRC Investigator and one NRC Investigative Aide.

Results: No items of noncompliance were identified. The alleger was unable

,

to provide any factual information relating to the allegations of drug abuse

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at STP.

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INTRODUCTION The South Texas Nuclear Project (STP), Units 1 and 2, is currently under construction near the town of Bay City, Texas. Houston Lighting and Power Company (HL&P) is the construction permit holder, Brown & Root, Inc. (B&R)

is the architect / engineer and construction firm.

REASON FOR INVESTIGATION On September 9, 1980, Individual A telephonically contacted the Nuclear Regulatory Commission (NRC), Region IV office, and alleged kncwledge of on-the-job drug use by her ex-husband and his friends while they worked for B&R.

She additionally alleged B&R tolerates drug use by its employees which is affecting the quality of construction work being done at STP.

SUMMARY OF FACTS On September 9, 1980, Individual A telephoned NRC, Region IV office, and alleged that her ex-husband had been terminated by B&R, at a non-nuclear related construction site, and was rehired by B&R at another non-nuclear related construction site. She alleged that B&R's employment policy therefore tolerates drug usage and that drugs used by B&R employees affects the quality of construc-tion work performed at STP.

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REGION IV

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~, 4 911 RYAN Pt.AZA cmiVE. SUITE 1000 AAUNGTON. TEXAS 70011

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In Reply Refer To:

Cecemcer 3,19E0 RIV Occket No. 50-498/ Rot. 80-30 50-499/Rpt. 80-30 Mcusten Lignting and Fewer Ccepany Atta: Mr. G. W. Corea, Jr.

Executive Vice President Fcst Office Sox 17CO Hcuston, Texas 77001 Gentlemen:

Tnis refers to the inspection conducted by Messrs W. G. Hubacek, L. D. Gilber:

and J. I. Taoia of cur staff during the perieds Cc:cber 21-2c-and 27-31,19E0,

,

of activities authori:ed by NRC Ccnstruction Pemits No. CFPR-123 and 129 for Soutn Texas Project, Units No.1 and 2, and to =e discussion of our fincings witn Mr. R. A. Fra:ar and otner memcers of ycur staff at the conclusion of me inscection.

Areas examined during :ne inscecticn and cur findings are discussec in the enciesed ins;:ection recor. '4itnin these areas, me inscection consistec of selective examination cf crececures anc recresentative recercs, interviews with per!onnel, anc coservations by the inspec:crs.

Within :ne secpe c,f the inspection, no violations were identified.

We have also examined actions you have taken with regard to previcusly identified inspection findings. Tne status of :nese items is identified in paragra:n 2 of the enclosed re:crt.

In acccrdance with Secticn 2.790 of the NRC's " Rules of Practice," Far: 2 Title 10, Ccde of Federal Regulations, a copy of :nis le: er anc the enciesec inscection recor will ce clacec in :ne NRC's Puclic Cocument Rocm.

If me recort contains any infomation that you believe to ::e crccrie:ary, it is necessary tna ycu su::mit a writtan acplication to this office, winnin 23 days of :ne cate of this letter, recuesting :na: sucn infornation te witneld from public disclosure. 'he acclication dust incluce a full statement of =e reasons wny it is clai=ed :na: =e infomation is procrie:ary. Tne acclica:icn sacuic te crecared so tna any procrietary infor.ation icentiffec is containec in an enclosure to ne acclicatien, since me acclication witncut ce enciesure will also ::e placec in :ne Puclic Coc=ent Rcca.

If we ce not hear frca ycu in mis regarc witnin :ne scecified cerice, the recer: will te claced in me ?uclic

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Ccc=ent Roem.

STAFF EXHIBIT NO. 74 h

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Housten Lignting and Power Company

December 3,1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

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'4. C. Seh, Chief

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Reactor Construction and

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Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/80-30 50-499/80-30

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U. 5. NUCLEAR REGULATCRY CCMMISSICN OFFICE OF INSPECTICN AND ENFCRCEMENT REGICN IV Report No. 50-498/80-30; 50-499/80-30

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Cocket No. 50-498; 50-499 Category A2 Licensee: Houst n lignting and Pcwer Company Post Office Sox 1700 Housten, Texas 77001 Facility Name: Souta Texas Project, Units 1 and 2 Inspection at: Scutn Texas Project, Matagorda

REGION IV==

Investigation Report No. 50-498/80-31; 50-499/80-31 Docket No. 50-498/499 Licensee:

Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 Facility:

South Texas.oroject, Units Nos. 1 and 2

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Investigation at:

South Texas Project, Matagorda County, Texas Investigation Conducted: October 15-17, 22-23, and November 13, 1980 Investigator:

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'N O C W x-ei A o $\\

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D. O. OrisXill, InvestigTtion Specialist Date pQp'

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R. A. Herr, Investigation 5pecialist Date

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T. J. DiGaloma, Investigative Aioe (Co-Op)

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Approved by:

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Karl V. Seyfrit, Directo Date

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b9 DUPLICATE DOCUMENT A

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Summary Investigation on October 15-17, 22-23, November 13,1980 (Report No. 50-498/

80-31; 50-499/80-31.

Area Investicated: Allegations were received indicating a Construction Foreman was fired oecause he resisted pressures being exerted on his men; that Brown

& Root, Inc. (B&R), had rehired individuals who were formerly fired as a result of an NRC investigation; and that safety-related documentation, in a particular activity, is inadequate and some have been falsified.

Results Investigation of the allegations that a Construction Foreman was fired for resisting pressures exerted on his men was determined to be unfounded.

The allegation that B&R has rehired inoividuals who were terminated as a result of an NRC investigation was substantiated.

The allegation that safety-related documentation is inadequate and has been falsified was found to have had merit, insomuch as cadweld location and inspection records were altered without the appropriate approval and justification for the alteration.

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UNITED STATES

NUCLEAR REGULATORY COMMISSION 1'1 411 RY AN PLAZA IVE,SulTE 1000

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j ARLINGTON, TEXAS 78012 l

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In Reply Refer To:

RIV Docket Nos. 50-498/Rpt. 80-32 50-499/Rpt. 80-32 i

Houston Lighting and Power Company Attn: Mr. W. F. McGuire, Manager i

Environmental Protection Department Energy Development Complex Post Office Box 1700 Houston, Texas 77001 i

Gentlemen:

i This refers to the routine, uri.nnounced inspection conducted by Mr. Lorenzo Wilborn during the period Oc+ober 21-23, 1980, of activities authorized by NRC Construction Permit Nos. CPPR-128 and 129 for the South Texas Project, Units 1 and 2, and to the discussion of the findings with Mr. R. W. Lawhn and other members of your staff at the cor.clusion of the inspection.

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Areas examined during the inspection and our findings are discussed in the

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enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and ripresentative records, interviews

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with personnel, and observations by the frspector.

Within the scope of the inspection, no items of noncompliance, deviations, or new unresolved items were identified.

In accordance with Section 2.190 of the NRC's " Rules of Practice," Part 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 infomation 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 p1riod, the report will

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be placed in the Public Document Room.

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ptg STAFF EXHIBIT NO. 76 gol2 nom

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Houston Lighting and Power Company-2-Should you have any questions concerning this inspection, we will be pleased to discuss them with you.

Sincerely,

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Glen D. Brown, Chief Fuel Facility and Material Safety Branch

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report Nos. 50-498/80-32 50-499/80-32 Docket Nos. 50-498

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50-499 l

Licensee:

Houston Lignting and Power Company (HLP)

Post Office Box 1700 i

Houston, Texas 77001 l

Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County and HLP Offices, Houston, Texas Inspection conducted: October 21-23, 1980 Inspector:

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  • bcto s/iz/go LorenzajWilcorn, Radiation Specialist Date

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'I f 1 1[N GTen IT. Brown, Chief, Fuel Facility and Material Date'

Safety Branch Summary Inscection on October 21-23, 1980 (Recort Nos.50-498/80-32; 50-499/80-32)

Areas Inscected: Routine, unannounced inspection of construction phase

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l environmental protection programs, including organization and administration; l

site evironmental control program; audits; transmission line work; special studies and monitoring programs and tour of the site and surrounding area.

ihe inspection involved sixteen (16) inspector-hours by one (1) NRC inspector.

'tesul ts: No items of noncompliance or deviations were disclosed.

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Persons Contacted

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Houston Lighting and Power Company (HLP)

    • R. W. Lawhn, Supervising Engineer E. P. Barganier, Lead Construction Supervisor
    • G. J. Gibbs, Engineer
    • H. P. Hardy, Engineering Technologist
    • R. S. Hanna, Junior Engineer R. Gangluff, Chemical Technicians' Foreman Brown and Root, Inc. (B&R)
  • A. N. Costanza, Site Environmental Coordinator
  • 0enotes those present at meeting at STP site on October 22, 1980.
    • Denotes those present at exit interview at HLP offices on October 23, 1980 2.

Licensee Action on Previous Inscection Findinos (Closed) Unresolved item (50-498/79-07/1): This item is concerned with written procedures that had not been finalized and implemented to cover the scope of the work, assignment of responsibility, sampling procedures, acceptance criteria and analytical QC activities. The procedures are dascribed in paragrnh 6 of this report. This item is considered closed.

(Closed) Unresolved item (50-498/79-07/2): This item is concerned with burial of chemical and nonsalvageable waste at a designated location on-site.

Section 4.S.1 of the FES requires that nonsalvageable it2ms be hauled from the site and disposed of in accordar.ce with local regulations. The corrective action is described in paragraph 8 of this report. This item is considered closed.

3.

Organization and Administration The inspector reviewed the organizational structures of HLP and B&R as related to environmental matters at the site. Changes we e noted as follows:

HLP D. G. Barker, Manager, South Texas Project J. G. White, Licensing and Technical Coordinator W. F. McGuire, Manager, Environmental Protection Department R. W. Lawhn, Supervising Engineer, Nuclear Projects G. J. Gibbs, Licensing Engineer B&R

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J. L. Hawks, Engineering Project Manager Robert Withrow, Engineering Staff Manager A. N. Costanza, Site Environmental Cooroinator l

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NUCLEAR REGULATORY COMMISSION

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f e11 RYAN PLAZA DnlVs. SufTe 1000 Anumeron,TsxAs ani

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January 14, 1981 In Reply Refer To:

RIV Docket No. M-498/Rpt. 80-33 50-499/Rpt. 80-33 Houston Lighting and Power Company l

ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the inspection conducted by our Resident Reactor Inspector, Mr. H. S. Phillips, during November and December 1980, of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for the South Texas Project, Units No.1 and 2, and to the discussion of our findings with Mr. R. A. Frazar and other members of your staff at the conclusion of the inspection.

Ams examined during the inspection and our findings are discussed. in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.

Within the scope of the inspection, no violations were ioentified.

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

2 of the enclosed report.

One new unresolved item is identified in paragraph 3 of the enclosed report.

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

l inspection report will be placed in the NRC's Public Document Room.

If the l

report contains any infonnation that you believe to be proprietary, it is l

necessary that you submit a written application to this office, within 20 days l

of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reaso~.

STAFF EXHIBIT NO. 77 l

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Houston Lighting and Power Company-2-January 14, 1981

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why it is claimed that the infomation is proprietary. The application should be prepared so that any proprietary infomation identified is contained in an enclosum 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 Occument Room.

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

Sincerely, ff W. C. Seid e, Chief Reactor Co struction and Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/80-33

50-499/80-33 l

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-498/80-33; 50-499/80-33 t

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REGION IV==

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.f 811 RYAN PLAZA DRIVE. SufTe M AAUNGTON. TEXAS M1

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Docket Nos. 50-498/80-34 50-499/80-34 Houston Lighting & Power Company ATTN: Mr. G. 'J. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the investigation conducted by Mr. D. D. Driskill and Mr. A. R.

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Johnson of our staff on October 27-31 and November 11-12, 1980, at your facility in Bay City, Texas, concerning allegations that unqualified personnel are working in the Brown & Root Electrical Department Temination Shack which is affecting the quality of safety-related activities, that storage of safety-related piping does not confom with applicable procedures and that differences exist in some piping isometric drawings and STP piping specification sheets. The investigation and our findings are discussed in the enclosed investigation report.

In accordance with Section 2.790 of the Commission's " Rules of Practice," Part 2, Title 10 Code of Federal Regulations, a copy of this letter together with the l

enclosed investigation report will be placed in the Commission's Public Document Room. If this report contains any information that you believe to be proprietary, i

l it is necessary that you make a written application within twenty (20) days to I

this office to withhold such infomation from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary infomation identified in the applicaticn is contained in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Cocument Rocm.

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Should you have any questions concerning this investigation, we will be pleased l

to discuss them with you.

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Sincerely, W. C. SeidTe, Chief Reactor C'onstruction and Engineering Support Brancn i

Enclosure:

Investigation Report Nos. 50-498/80-34 50-499/80-34 STAFF EXHIBIT NO. 78

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U. S. NUCLEAR REGULATORY C0 m ISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Investigation Report No. 50-498/80-34; 50-499/80-34 Licensee: Houston Lighting & Power Company Facility: South Texas Project, Units 1 and 2 l

Investigation at: Bay City, Matagorda County, Texas

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Investigation Conducted: October 27-31, 1980 and Novencer 11-12, 1980 Investigator:

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0. D. OrisXill, Investigation Specialist Date l

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Inspector:

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Allen R. Jonnson Date

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Approved by:

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W. C. 5eio(e, Chief Qate l

Reactor Chastruction & Engineering

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Support Branch l

Summary Investigation on October 27-31, and November 11-12, 1980 (Report No. 50-498/

80-34; 50-499/80-34).

l Area Investicated: Concerned Bay City, Texas citizens alleged that Brown &

l Root, Inc. (8&R), is utilizing personnel in the Electrical Decartment Termi-nation Shack at the South Texas Project (STP) who are not acquainted with l

the appropriate procedures and job requirements. This practice is effecting

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recordkeeping and calibration of tools utilized in safety-related electrical work. Allegations were also presented indicating that safety-related pipe

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is not being stored, within Storage Yard M, in comoliance with a

REGION IV==

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811 RYAN PLAZA DRIVE. suite 1000

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AAUNGTON. TEXAS 70011

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November 19, 1980 In Reply Refer To:

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RIV Docket No. 50-498/Rpt. 80-35 50-499/Rpt. 80-35 i

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Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

This refers to the inspection conducted by Mr. D. P. Tomlinson of our staff during the period November 3-7, 1980, of activities authorized by NRC Con-struction Pemits No. CPPR-128 and 129 for the South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. D. G. Barker 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 consisted of selective examination of procedures and representative recorcs, inter /fews with personnel, and observations by the inspector.

Within the scope of the inspection, no items of noncompliance were identified.

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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 inspection report will be placed in the NRC's Public Occument Room.

If the report contains any infomation 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 infomation be withheld from l

public disclosure. The application must include a full statement of the reasons wny it is claimed that the information is proorietary. The application should be prepared so that any proprietary infomation 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 frem you in this regard within the specified period, the report will be placed in the Public Occument Room.

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STAFF EXHIBIT 40.

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Houston Lighting and Power

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Company-2-Noverrber 19, 1980

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

Sincerely

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W. C. Seidle, Chief i

Reactor CoMtruction and

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Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/80-35 50-499/80-35

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

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Report No. 50-498/80-35; 50-499/80-35 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company l

Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 & 2 Inspection at: South Texas Project, Matagorda County,' Texas Inspection Conducted: November 3-7, 1980

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Inspector 4'5r.

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fl-l W-VO 0" P. Toml1 Mon, Reactor Inspector, Engineering Support Date Section Approved:

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g,f W. A. Crossman, Chief, Projects Section Ofte

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//. ro R. c.. Hall, Chief, Engfneering Support Section ytef

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Insoection Sumary:

Insoection on November 3-7,1980 (Recort No. 50-498/80-35: 50 499/80-35)

l Areas Inscecteo: Unannouncec follcw-up inspection of construction activities pertaining to tne resumption of AWS welding, re-examination and repair of

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existing AWS welds; and review of ruponses to NRC Inspection Report No.

l 50-498/79-19; 50-499/79-19 findings. The inspection involved twenty-nine inspector-hours by one NRC inspector.

Resul ts: No items of noncompliance were identified.

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DETAILS 1.

Persons Cor: acted Principal Licensee Emolayees R. A. Frazar, Manager, Quality Assurance

  • D. G. Barker, Project Manager
  • L. D. Wilson, Project QA Supervisor Other Personnel J. Locklar, Manager of Special Projects, Brown & Root (B&R)

J. Harrington, Fabricaticn Shop Superintendent, S&R F. G. Miller, Senior Welding Engineer, B&R M. D. Muscente, Welding Project Manager, B&R The IE inspector also centacted other licensee and contractor employees iriclucing members of the QA/QC and engineering staffs.

  • Denotes those attending the exit interview.

2.

Site Tour The IE inspector toured several areas of the site to observe construction operations and general housekeeping. Areas visited were Reactor Building No.1, MEAB No.1, MEAB No. 2 and several storage areas.

No items of noncompliance were noted.

3.

Resumotion of AWS Welding The IE inspector reviewed the daiiy status reports of progress on the AWS welding restart program. The:e included new work and work performed under the re-examination and repair plan from October 6 througn November 3,1980.

These reports included data on the total lengths of weld deposited daily, the cumulating length, length of weld inspected and lengtn of weld rejected.

Work is currently underway in relay rooms 2A, 2B and 2F for repair and new welding programs utilizing personnel requalified for welding and weld inspection. The IE inspector reviewed the qualification records of ten welders, six inspectors and two weld technicians working in the fabrication shop. All phases of the qualifications appeared to be in comoliance with STP-0AP 2.1, 2.2 and 2.3.

Also reviewed were records of four training sessions conducted to acquaint construction and inspection personnel with recent procedural changes. The classes covered the requirements of MECP 1, 2, 8,12, MCP 7 and CCP 15 and were attended by a total of 132 construction and inspecticn employees.

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The IE inspector observed welding activities in the fabrication shop, MEAB 1 and MEAB 2.

All activities appeared to be in compliance with applicable procedures and within the scope of the welding restart program.

In progress werenew welding and repair welding in three areas of MEAB 1, new structural welding in MEAB 2 and the new welding of cable hangers in the fabrication shop. The IE inspector reviewed the re-examination and repair records for four of the cable hangers completed prior to the Stop-Work Order in cubicle 2F of MEAB 1.

These were hangers 13,15,16 and 17 as designated on Drawing FSHE-AXI-211, Sheet #1. The inspection teams identified, corrected and documented numerous deficiencies

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such as undercut, improper contour, undersized welds and visible porosity.

All records reviewed appeared to be complete and a

REGION IV==

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$11 AYAN 7t,AZA ORIVE. Suit! 1000

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anuNorcN. rExas mit

n Reply Refer To:

Cecam er 21, 1920 3*7 Cocket No. 50-498/ Ret. 30-26 50-499/Rpt. 80-26 Housta'n lignting and Power Company Attn: Mr. G. W. Oorea, Jr.

Executive Vice President Post Offica Sox 1700 Houston, Texas 77C01 Gentlemen:

Tnis refers to me ins:ection conducted by Messrs. W. G. Hucacek anc L. O.

Gilbert of our staff during the periocs Novem er 17-21 and Decemcer 14, 1980, of activities autnori:ed by NRC Ccnstruction Permits No. CPPR-123 and 129 for Soutn Texas ?roject, Units No. I and 2, and to the discussion of our fincings with Mr. R. A. Fra:ar and other memcers of your staff at tne conclusion of tne inscection.

Areas examined curing the inscecticn and our findings are discussac in =e anciosed ins:ection recort. Within tnese areas, One ins:ection censistec of selective examination of precedures and recresentative recorcs, intarviews witn persennel, and coservations by the ins:ec:crs.

Within the sco:e of tne ins:ectica, no violations were identifiec.

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We have also examinec actions you have taken with regarc to previcus1'y icentified inscection findings. Tne status of these items is icentified in paragracn 2 of the enclosed recor.

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In ac:crdance wi-h Section 2.790 of the NRC's " Rules of Practice," Part 2,

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Title 10, Ccce of Feceral Regulations, a c cy Of :nis letter anc ne enclosec ins ecticn escor wili :e placed in ne NRC's ?uclic Occument 2,0cm.

If ne recor c:ntains any information that ycu telieve a de ;rcarietary. it is necassary tnat ycu sucmit a writ an acclication to =is cffica, witnin 20 cays f -he data of this lettar, recuesting that suca infonaticn be witnneld fr m

uolic disclosure.

Tne acclicaticn :ust incluce a full statament of me esascns wny it is claimec na: ce infomation is :rcor erary.

he acciicatien sncule

e :recarec so nat any Orcor erary infor.ation icentifiec is ::ntainec in in enclosure c ne acciication, sinca ne acclication wi ncut ne enclosure wiil also :e Olacao in me Nolic Occument Roem.
f ne :o not rear fr m /cu in :nis regarc within te s ecified pericc, One recor; will be ?Iaced in the ?"*iic Jocument Roem.

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STAFF EXHIBIT NO. 80 (>fE of Tlo3o303 H t

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Houston Lighting and Power Company Z

Cecameer 31, 1980

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Should you have any cuestions concerning this inscec fon, we will be pleasec to discuss :nem wf n you.

Sincerely,

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. C. Seidle, Chief

'gReac:ceConstructionand

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Engineering Su;:cor: 3rancn

Enclosure:

E Inscaction.0,ecor: 'lo. 50 493/30-36 20 499/80-36

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o U. S. NUCLEAR REGULATORY CCPNISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-498/80-36; 50-499/80-36 Docket No. 50-498; 50-499 Category A2 Licensee:

Houston Lighting & Power

REGION IV==

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611 RYAN Pt.AZA DRIVE. SUITE 1000

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ARUNGTON, TEXAS 78011

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November 24, 1980 In Reply Refer To:

RIV Docket No. 50-498/Rpt. 80-37 50-499/Rpt. 80-37 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.

Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen:

Tnis refers to the meeting held by Messrs. K. V. Seyfrit, W. C. Seidle,

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W. A. Crossman and R. E. Hall with Mr. J. H. Goldberg and other members

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of the Houston Lighting and Power Company and Brown and Root Company, Inc.

staff on November 18, 1980, at the Region IV office. in Arlington, Texas, to discuss the status of Show Cause Order items and limited work restart.

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 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 l

of the date of this letter, requesting that such information be withheld from l

public disclosure.

The application must include a full statement of the reasons why it is claimed that the infonnation 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 l

regard within the specified period, the report will be placed in the Public l

Document Room.

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Sincerely,

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N W.C.Seid@, Chief Reactor Construction and Engineering Support Branch

Enclosure:

IE Inspection Report No. 50-498/80-37 80-499/80-37 STAFF EXHIBIT N0. 81 D of gw$1olloo'751

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

REGION IV

Report No. 50-498/80-37; 50-499/80-37 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Meeting at: Arlington, Texas, Region IV Office (November 18,1980)

NRC Participants:

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N Y 56 K. V. Seyfrit, Dire Region IV Date

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t'/u /g o W. C. Seidle, Chief, Reactor Constraction and Date Enginee dng Support Branch Ub/ 10 m~

W. A. Crossman, Chief, Projects Secticn Date

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FD R. E. Hall ~, Chief, Engineering Support Section Date w _

M 2/ db Approved:

W. A. Crossman, Chief, Projects Section Date Meeting Summary:

Meeting on November 18, 1980 (Recort No. 50-498/80-38: 50-499/80-37)

Meeting Tooics: Announcea meeting with corporate staff memoers of Houston Lignting and Power Company and Brown & Root Company, Inc. to discuss the status of Show Cause Order items and limited work restart.

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DETAILS 1.

Persons Attending Meeting Houston Lighting and Power Company (HL&P)

J. H. Goldberg, Vice President, Nuclear Engineering and Construction D. G. Barker, Manager, South Texas Project R. A. Frazar, QA Manager Brown and Root Comoany, Inc. (B&R)

K. M. Broom, Senior Vice President J. R. Geurts, Vice President and Project General Manager S. H. Grote, Senior Vice President, Power Group R. J. Vurpillat, Power Group QA Manager NRC Participants K. V. Sey1. it, Di rector, Region IV W. C. Seidle, Chief, Reactor Construction & Engineering Support Branch W. A. Crossman, Chief, Projects Section R. E. Hall, Chief, Engineering Support Section 2.

Meeting with Corcorate Staff a.

Purcose of Meeting The purpose of this meeting was to discuss status of Show Cause

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items and restart of limited work.

b.

Status of Restart of Limited Work On October 2,1980, HL&P requested limited restart of work in the areas of AWS welding, ASME welding, and placement of complex concrete.

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Inspection of implementation of corrective actions in the sbove areas

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indicated that only the AWS welding program was complete enough to allow limited restart.

Consequently, on October 3,1980, an IAL was issued for restart of a specific anount of AWS welding.

A request was made on October 17, 1980, and the increment of AWS welding was extended by IAL on October 22, 1980.

An updated request for resumption of limited complex concrete place-ment was made by telephone on October 24, 1980, and followed uo by letter on November 3,1980, but it was subseouently determined that there were several outstanding incomplete corrective actions, t

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including inspection of the testing laboratory, specific provisions l

for control of correlation testing of concrete and several ADRs and NCRs.

Consequently, the Region IV staff did not concur with the

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requast to restart limited complex conciete placement.

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Discussion The implementation of corrective actions in regard to the Show Cause items with respect to limited restart of work as described above was discussed.

The RIV Director emphasized the need for the licensee and his constructor to thoroughly examine all areas of concern in anticipation of restart of limited work and maintain detailed comunications with RIV in regard to status of completion of outstanding comitments.

The licensee attendees acknowledged the basic problems outlined and agreed to closer comunications with the RIV staff and within the licensee / constructor staffs.

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  • "%e UNITED STATIS

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t NUCLEAR REGUL.ATORY COMMISSION

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REGION IV

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k 811 RYAN PLAZA ORNE. Su!TI1000

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ARumoTom. Texas 7eoil

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In Reply Refer To:

January 30, 1981 RIV Docket No. 50-498/Rpt. 80-38 50-499/RpT. 80-38 l

Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr.

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l Executive Vice President Post Office Box 1700 Houston, Texas 77001 i

Gentlemen:

This refers to the inspection conducted by Messrs. D. P. Tcmlinson and J. I.

Tapia of o ir staff during the period December 15-18, 1980, of activities authorized by NRC Construction Pennits No. CPPR-128 and 129 'or tL South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. R. A.

Frazar 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 consisted of selective exa'nination of procedures and representative records, interviews with personnel, and observations by the inspectors.

Within the scope of the inspection, no violations were identified.

We have also examined actions you have taken with regard. to creviously identified ir.spection findings. The status of these items is identified in paragraph 2 of the enclosed report.

In a

REGION IV==

Report No. 50-498/80-38, 50-499/80-38 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting & Power Company

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Post Office Box 1700 Houston, Texas 77001 Facility Name:

South Texas Project, Units 1 & 2

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Inspection at:

South Texas Project, Matagorda County, Texas Inspection Conducted:

December 15-18, 1980

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w I-29-81 Inspectors:

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P. TomMM3cn, Reactor Inspector, Engineering Date Support Section (paragraphs 1, 2 & 3)

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g. I. Tapia, Reactor Inspector, Engineering Date T

Support Section (paragraohs 1, 2 & 3)

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W. A. Crossman, Chief, Projects Section

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R. E. Hall, Chief, Engineering Suoport Section Cate

Insoection Sumary:

l Insoection on Decemoer 15-18, 1980 (Recort No. 50-498/80-38: 50-499/80-38)

l Areas Insoectea: unannouncea follow-up inspection of construction activities pertaining to the resumption of AWS welding, re-examination and reoair of

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existing welds, and review of responses to NRC Inspection Report No. 50-498/79-19; l

50-499/79-19 findings.

The inspection involved forty-eignt inspector-hours by A^

.~ry<

l?L't!! m r~ m 7 % e w x

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.,agrw,,. ;;p - mag were identified.

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DUPLICATE DOCUMENT 1;g tp:

Entire docinaent previously

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entered ir.to system under:

%IO3/9 D630 J

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No. of pages:

parmpa==

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OETAILS 1.

Persons Contacted

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Principal Licensee Employees

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  • R. A. Frazar, Manager, Quality Assurance
  • L. D. Wilson, Project QA Supervisor
  • B.

1. Schulte, Civil QA

  • C. L. Harvey, QA Quality Systems

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  • J. Xemper, Construction Supervisor R. A. Carvel, Project QA Supervisor Other Personnel

"R. L. Hand, Project QA General Supervisor, Management Analysis Ccmpany (MAC)

  • F. G. Miller, Chief Welding Engineer, Brown & Root (B&R)
  • D. J. Harris, Manager, Quality Engineering, B&R
  • M. D. Muscente, Welding Program Manager, B&R C. Singleton, Civil QC Superintendent, B&R J. Ruud, Supervisor, Civil Quality Engineering, Management Analysis Corp. (MAC)

The IE inspectors also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.

" Denotes those attending the exit. interview.

2.

Licensee Action on Previous Inscection Findings During this inspection certain corrective actions concerning the findings of Investigation Report No. 50-498/79-19; 50-499/79-19, and additional items extracted from the NRC transcript of the public meeting with HL&P/

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B&R on August 19, 1980, and commitments from management meetings were reviewed:

The following four items related to radiography were individually reviewed, but are being addressed together in this report:

(Closed) infraction (50-498/79-19-A-11a; 50-499/79-19-A-11a); (Closec) infraction (50-498/79-19-A-11b; 50-499/79-19-A-11b); (Closed) Construction Deficiency No.17; (Closed)

Thirteen Point Response, Item 8a.

The IE inspector randomly selected the radiographs for six ECW piping joints inspected after October 6,1980, for r

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a thorough review. The purpose of this review was to assure compliance l

with the ASME Boiler and Pressure vessel Code requirements.

Selected for i

this examination were:

ECW-1105 FW-0032, ECW-2102 FW-0012, ECW-2102 FW-0018, ECW-2102 FW-0020, ECW-2302 FW-0010 and ECW-2305 FW-0036.

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