IR 05000498/1980025
| ML19351E932 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/29/1980 |
| From: | Crossman W, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19351E929 | List: |
| References | |
| 50-498-80-25, 50-499-80-25, NUDOCS 8012190544 | |
| Download: ML19351E932 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
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REGION IV
Report No. 50-498/80-25; 50-499/80-25 Cateogry A2
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Docket No. 50-498; 50-499 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
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Inspection Conducted:
September 1980 i
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a Inspector-
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. S. Phillips, Resident Reactor Inspector Da t'e
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//[4 Approved:
m ;r W. A. Crossman, Chief, Projects Section Date
l Inspection Summary:
Inspection of September 1980 (Report 50-498/80-25; 50-499/S0-25)
Areas Inspected:
Routine, announced inspection by the Resident Reactor Inspector (RRI) included follow-up inspections relative to noncompliances, unresolved
matters, construction deficiencies reported, and Show Cause Order items.
This inspection involved one hundred sixteen inspector-hours by one NRC inspectors Results:
No items of noncompliance or deviations were identified.
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DETAILS 1.
Persons Contacted Principal Licensee Employees G. W. Oprea, Executive Vice President R. A. Frazar, Quality Assurance Manager, QA STP 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 Brown & Root Inc. (B&R) Employees J. R. Geurts, Vice President R. J. Vurpillat, QA Manager Power Group R. W. Bass, Audit Section Manager D. A. Walker, Lead Site Auditor G. R. Purdy, Manager Quality Engineering R. J. Purdy, Assistant Manager QA Systems R. W. Peverly, Assistant Project Manager Power Group Management Analysis. Company (MAC)
W. J. Friedrich, QA Manager for Brown and Root The RRI also interviewed other licensee and contractor employees, includ-ing members of the quality and engineering staffs.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (50-498/79-19-08; 50-499/79-19-08):
Quality Assurance / Control Functions not Sufficiently Independent, the QA/QC Civil Personnel Do not Have Sufficient Authority nor the Freedom to Identify Problems and Determine that they are Adequately Resolved.
The results of interviews indicate that some Civil QC Inspectors are:
(a) subjected to production pressures, (b) not always supported by the QC management, (c) harrassed, (d) intimidated, and (e) threatened.
The RRI accomplished the follow-up inspection on the findings described above oy interviewing inspectors since the noncompliance was identified by the interview process.
Accordingly, twenty-nine inspectors, including seven lead inspectors and one QC supervisor, were interviewed.
Two QA
record clerks were also interviewed relative to the QA vault area.
The personnel interviewed were asked whether conditions are new satisfactory or unsatisfactory regarding the following:
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A Questions Discipline Response Comments
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Yes No
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1 Do production 25 Civil X
pressures prevent 2 Mech X
l adequate inspection?
2 NDE X
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Do managers / supervisors 25 Civil X
give inspectors 2 Mech X
adequate support?
2 NDE X
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j Have you been harrassed 25 Civil
24 One inspector felt
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or know of harrassment 2 Mech X
construction had
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since the investigation? 2 NDE X
singled.him out because he wrote a j
nonconconformance i
report.
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Have you been threat-25 Civil
24 One said an " idle ened or know of others 2 Mech X
threat" was made.
He threatened-since the 2 NDE X
told management and NRC investigation?
the man was. disciplined.
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Have you been 25 Civil X
intimidated or know 2 MECH X
of someone who has been? 2 NDE X
.______......____......
i Do you have the free-25 Civil X
Several inspectors dom to identify non-2 Mech X
were concerned because conformances and document 2 NDE X
construction foremen
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the same?
had been told they would be fired if-
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l three NCRs were written against their area.
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Are FREAs (Eng. Action)
25 Civil X
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'used instead of non-2 Mech X
j conformance reports?
2 NDE X
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Do you have stop-work 25 Civil
.X ll authority and are 2 Mech X
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procedures clear?-
2 NDE X
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Questions Discipline Response Comments Yes 3.o Do you feel free to 25 Civil X
take safety-related 2 Mech X
problems, impasses or 2 NDE X
arguments which affect quality to your super-visors, managers, or the NRC?
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Do you feel construction 25 Civil X
Three inspectors still willfully violates 2 Mech X
expressed concern that specifications, pro-2 NDE X
construction may slip cedures, or drawings?
back into its old vays.
Two were con-cerned that B&R is hiring back those who made trouble in the past.
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Do you know of any 25 Civil X
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current alteration or 2 Mech X
falsification of QA/
2 NDE X
QC Records where the 2 QA Record Clerks X
condition has not been identified and corrected?
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Are adequate controls 25 Civil X
Four n. pectors stated in place to control 2 Mech X
that minor paper work the work in your area 2 NDE X
problems still exist of responsibility?
with complex concrete placement.
The following is a discussion of isolated negative comments:
j One inspector felt he had been singled out by construction because j
he identified a nonconformance and construction had subsequently j
pointed out procedures the inspector failed to follow.
The inspector acknowledged that he failed to follow procedures on one occasion, i
but denied that he had failed to adequately inspect areas as alleged in writing by construction personnel.
The RRI has no further questions on this matter.
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One inspector stated that he received an idle threat, but did not think the threat was serious, because the worker immediately apologized.
Regardless, it was reported per procedure, and the worker was disciplined.
The RRI had no further questions on this matter.
Several inspectors expressed concern for construction foremen because they had heard, "if foremen receive three written NCRs they would be fired." The RRI advised the licensee that this " verbal" policy is unacceptable because of its negative effect on the nonconformance reporting system. The licensee notified construction foremen that this policy is unacceptable in licensee correspondence No. ST-HS-00590, dated October 2, 1980.
The RRI has no further questions on this matter.
Four inspectors stated that minor problems exist relative to documenting complex pours and expressed the opinion that the paper work system should be improved by simplifying the signature process.
One inspector stated that too many changes occur at the preplacement.
The RRI has no further questions on this matter.
The RRI found the overall interview results to be very positive in that previously identified conditions, which caused this noncompliance, had been corrected and no recurring trends were evident during this review.
This matter is considered closed.
(Closed) Noncompliance (50-498/79-19-47; 50-499/79-19-47):
No Effective Program was Implemented for Review and Analysis of Non-conformance Reports, Examination Checks / Inspection Books or Field Request for Engineering Action.
The RRI reviewed each point in the licensee's response. The response stated, "the inadequacy of their trend analysis program was caused by the (1) lack of clear direction, procedures and analysis criteria, and (2) absence of a central project authority assigned responsibility for this work.
The RRI reviewed corrective action and results. Three documents and sub-sequent implementation of procedures and report of trend analysis results corrected the inadequacies described in the paragraph above.
The RRI reviewed the following documents which demonstrated that the licensee was in full compliance:
STP-PGM-07, " Procedure for Trending and Reporting of FREAs, NCRs,
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and SDRs," issued on May 4, 1980
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Procedure ST-QAP-15.4, "Nonconformance Trend Analysis," issued
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on July 14, 1980.
A040GQ0048, " Engineering Requirements for the Tracking and Trending
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of FREAs, NCRs and SDRs," issued July 14, 1980.
Trend Analysis Report for period ending March 31, 1980.
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Trend requirements were identified to Brown & Root, Inc.
in a letter, correspondence No. ST-HL-BR-4714, dated February 11, 1980.
This r? port trended FREAs, NCRs, however, SDRs were to be trended in the next report.
Trend Analysis Report for period ending July 31, 1980. This
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report trended all FREAs, NCRs and SDRs.
The RRI also reviewed the actions relative to commitments described in Item 2 of KL&P correspondence No. ST-KL-AE-A17, dated February 27, 1980,
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Subject: Response to NRC Investigation Findings, 79-19 Discussed in Exit Interview, January 24, 1980.
These commitments were met as a result of actions taken in the documents referenced above.
The RRI determined that the licensee was in full compliance when the Trending Report was issued for the period ending July 31, 1980, however, the licensee failed to state the date when full compliance was achieved.
The licensee has corrected this oversight by issuing a supplemental response.
The above item is considered closed.
(Closed) Noncompliance (50-498/79-19-33; 50-499/79-19-33):
Failure to Control Documents in that Contractor's QA Manual Copies are Out of Date.
The RRI and a RIV inspector verified that (a) all documents on file in the HL&P office were revised and up to date, (b) a secondary review was made by HL&P Quality Engineering Staff, and (c) an administrative technician was added to the staff.
Document control for QA procedures responsibility, within B&R, was transferred to site.
These reviews / actions were documented in HL&P office memoranda, dated September 11 and 12 1980.
The IE inspectors consider this matter closed.
l (Closed) Noncompliance (50-498/79-19-53; 50-499/79-19-53): Failure to Follow l
Procedures to Document and Correct Unsatisfactory Surveillance Conditions.
The RRI and a RIV inspector verified that unsatisfactory conditions identified during HL&P surveillances were properly documented since Janua ry 24, 1980, when HL&P personnel were verbally instructed to document such conditions. Written instructions were issued in an HL&F memorandum, l
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dated February 1, 1980.
HL&P Site Procedure PSQP-A3, Rev. 11, dated June 3, 1980, clarified actions to be taken on unsatisfactory conditions.
EL&P personnel received training on the procedure on June 18, 1980.
Under the new HL&P site organization, HL&P site function will change from a surveillance to an implementation review function and a new group will perfor= an inspection function which would compare to the surveillance f nction.
The IE inspectors have no further questions on this matter.
(Closed) Noncompliance (50-498/79-19-55; 50-499/19-55): Failure of B&R Management to Take Corrective Action in a Reasonable Time and B&R Management Did Not Get the Conditions Corrected or the Problem Resolved.
The RRI reviewed this item and documented the August follow-up inspection in NRC Inspection Report No. 50-498/80-18; 50-499/80-18, dated September 19, 1980. During this review, the lack of management involvement in assuring the correction of audit findings was apparent. Also the B&R site audit group was to increase their staff size, but had a net loss because of resignations. The licensee committed to increase management involvement and the vumber of site QA auditors. The RRI verified the implementation of these commitments during the September 1980 inspection period by review of r.ttendance rosters at pre and post audit meetings and assuring tLat two additional civil auditors have been added to the staff to replace the losses.
The RRI continued the follow-up inspection during the September 1980 period. The licensee's response and implementation of corrective action were reviewed and evaluated to verify the following:
PSAR commitments were translated into the audit procedure.
a.
b.
Impasses were usually escalated to the QA Manager and/or STP Project QA Manager, who resolved impasses or obtained action on delinquent items in accordance with the old procedure.
c.
Site Surveillances SIS-12, SIS-18, and SIS-26 were closed.
d.
The new Audit Procedure ST-QAP-7.1 was in draft, and the procedure would deal with the audited group's failure to respond and require that management be notified of delinquent audit responses.
e.
Root cause was the failure to reflect project requirements in workable procedures.
In regard to the above, the RRI determined the following:
a.
PSAR commitments were translated into revised procedures.
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b.
The inability to get a written response on SIS-18 had not been escalated to higher management as required by the old or new procedure. The RRI requested HL&P to further review B&R Houston and site audit files to determine if other examples existed where the audited groups were not notified by the QA Manager.
Site Surveillances SIS-12 and SIS-26 were satisfactorily closed; c.
however, the site audit group never received a final written response to close out SIS-18. The audit group wrote a letter dated April 15, 1980, to Houston management describing the impasse after repeated requests for the response, but this letter was rescinded. The RRI escalated this.to HL&P management for proper corrective action.
The licensee held meetings with all key management to review the requirements of HL&P and B&R audit procedures on September 26, 1980, as documented in HL&P letter, dated October 1, 1980.
d.
A new B&R Audit Procedure ST-QAP-18.1 (instead of ST-QAP-7) was approved on July 14, 1980.
Although the licensee had stated the cause of this noncompliance to e.
be the lack of workable procedures, it appears that the failure to follow procedures was the reil cause. The need to follow audit pro-cedures was empahsized by the licensee in the previously referenced meeting.
The RRI has no further questions on this matter at this time.
(Closed) Noncompliance (50-498/79-48; 50-499/79-19-48):
Failure of B&R to Perform in Depth Audits of Site Activities.
The RRI performed follow-up inspection to verify the following:
The B&R Audit Program had been redirected from " procedural" audits a.
to program / system audits. A training session was held on July 19, 1980, to explain this audit philosphy. ST-QAP-18.1 and Work Instruc-tions 1 thru 6 were reviewed.
b.
Audit schedules are met by significantly increasing the Houston / Site Audit Staff, Work was observed in addition to reviewing objective evidence (records).
c.
d.
At least one team member had discipline experience / training.
The RRI determined the following:
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a.
On July 19, 1980, a training session was documented relative to audit philosphy redirection outlined in Audit Procedure ST-QAP-18.1 and Work Instructions 1 thru 6.
b.
The final staffing level had not been reached because of offsetting losses; therefore, the audit staff increases were not as projected in the licensee's response, dated May 23, 1980. The site audit group is several audits behind because of the use of site auditors to assist in answering the NRC Investigation Report 79-19, Appendix A and Show Cause Items.
The Houston Audit Section Manager presented a make up schedule that should result in completing the scheduled audits. Houston auditors will be used to help site auditors perform required audits.
c.
The review of Site Audit ST-36 demonstrated that site audits are performed to the depth necessary to assure that activities affecting quality are being effectively implemented. A matrix had been developed to assure an organized approach to auditing Brown & Root, Inc. procedures. The audit of procedures also includes verifying that work is being performed in accordance with procedures.
d.
The site audit group had lost all of its auditors with. civil experience / training. Auditors with civil experience were being recruited; however, the group obtained auditors with civil experience from a consultant until permanent employees could be hired.
The site lead auditor position does not have sufficient supervisory e.
authority to deal with the site auditors. The position is not respected by some managers and, therefore, the audit process needs to be improved or strengthened in this area.
The licensee has updated the commitments made in the licensee's response to noncompliances, dated May 23, 1980, to reflect how the increase of audit staff will be achieved or temporarily reinforced and how the audit schedule will be maintained. Also the licensee is considering ways to strengthen the site lead auditor position.
Commitments stated in the paragraphs above will be tracked as open items under Show Cause Order Item v(9).
This item is closed.
(Closed) Noncompliance (50-498/79-16; 50-499/79-16):
Failure to Include Appropriate Quantitative or Qualitative Acceptance Criteria in Instructions, Procedures, or Drawings.
The RRI reviewed Quality / Concrete Construction Procedure A040KPCCP-25, Rev. 2, dated September 22, 1980, paragraph 8.5.10 which clearly states the acceptance criteria.
The RRI has no further questions on this matter.
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(Closed) Nine Point Plan Commitments, December 28, 1979 (Item 2):
Pro-cedure Changes to Clarify FREA and NCR as Well as Training Construction and QC Personnel in the Use of These Procedures by January 10, 1980.
The RRI determined the following:
Procedure ST-QAP 2.6, "Nonconformance Control," was rewritten a.
and issued ou January 31, 1980, to clarify the use and method of processing.
b.
Interim Changes on GCP-21, Rev. 8, " Field Change Request / Temporary Change Notices," were made on January 2 and 14, 1980, to clarify
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the use and method of processing.
Training records documented that six hundred and forty-four persons were trained on NCRs, FREAs and STP-PGM-02 on January 11, 1980.
Make up training was provided March 1980.
The RRI has no further questions on this matter.
(Closed) Nine Point Action Plan Commitments, December 28, 1979 (Item 9):
B&R Assessment of Top Level Management and Other Part of Organization
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to Determine the Cause of Perceived Harrassment and Undue Pressure on QC Personnel.
The RRI reviewed a management assessment survey performed by Time Lapse, Inc. in January 1980.
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This item is closed based on the'results of NRC interviews documented in the above review of Item No. 50-498/79-19-08; 50-499/79-19-19-08.
of NRC Investigation Report No. 50-498/79-19; 50-499/79-19.
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l (Closed) Nine Point Action Plan Commitments, December 18, 1979 (Item 7):
HL&P Assigned Key Members of the HL&P QA Staff to Site; Additional Resources; Greater HL&P Visibility.
The RRI determined the following:
l HL&P assigned W. N. Phillips and T. K. Logan to site from May 5, 1980, a.
through June 20, 1980; F. Stoerkel, part time May 5, 1980, through-i June 20, 1980.
b.
The licensee has been recruiting for several months. At least two additional positions were added to allow HL&P to become more involved with site activities.
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HL&P hard hats were marked to identify HL&P site QA personnel.
c.
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(Closed) Nine Point Action Plan Commitments, December 28, 1979 (Item 1):
B&R Will Hold a Seminar on January 4,1980, to Review, With Construction and QC Personnel, the Fundamental Philosophies and Standards of Our QA Program.
The RRI viewed the video tape of the seminar. The seminar did not adequately describe the proper roles of QA and construction relative to cost and schedule.
As a result, a second seminar was held on July 30, 1980, during which the new publication was distributed and discussed with the appropriate personnel.
The RRI has no further questions on this matter.
(Closed) Thirteen Point Response to NRC Investigation 79-19, February 7, 1980, (Item 12):
HL&P QA Surveillance is Not Documented in Accordance with HL&P Site Quality Assurance Procedures.
The RRI determined that this item was closed as a result of the licensee's corrective action which was implemented relative to Item No. 50-498/
79-19-53; 50-499/79-19-53 of NRC Investigation Report No. 50-498/79-19; 50-499/79-19 in the subject report.
(Closed) Thirteen Point Response to NRC Investigation 79-19, February 7, 1980, (Item 2):
Fail're to Take Corrective Action, that is, No Effective u
Trending Program for Root Cause of Deficiencies.
The RRI determined that this item should be closed as a result of the licensee's corrective action which was implemented relative to Items 50-498/79-19-47; 50-499/79-19-47 of NRC Investigation Report No. 50-498/79-19; 50-499/79-19 in the subject report.
(Closed) Thirteen Point Response to NRC Investigation 79-19, February 7, 1980, (Item 11):
Lack of Adequate Document Control.
The RRI determined that this item was closed as a result of the licensee's corrective action which was implemented relative to Items 50-498/79-33; 50-499/79-19-33 of NRC Investigation Report No. 50-498/79-19; 50-499/79-19 in the subject report.
(Closed) Unresolved Item (50-498/79-13-3(1); 50-499/79-13-3(1):
Inclusion of B&R QA Reports in the Site Records Vault.
The RRI verified that B&R QA audit reports are stored in the site records vault.
This item is closed.
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(Closed) Unresolved Item (50-498/79-13-6; 50-499/79-13-6):
Site B&R Audit Records Did Not Contain Approved Audit Checklists.
The RRI verified that audit records now contain checklists.
This item is closed.
(Closed) Unresolved Item (50-498/79-19-51; 50-499/79-19-51): Follow Up was not Documented in Audit Reports ST-13 and the Procedure to Require This is Being Written.
The RRI determined that follow up on B&R audit deficiencies will be documented in formal audit reports as required as B&R audit procedure ST-QAP-18.1, July 14, 1980.
This item is closed.
3.
Management Meetings The following meetings were held during the subject inspection period:
Attendees Subject Date RIV Follow-Up Task Entrance Meeting: Follow 9-2-80 Force; HL&P Personnel Up on Show Cause, Noncompliances and Unresolved Items RIV Follow-Up Task Exit Meeting: Review 9-5-80 Force; HL&P Personnel of Items Closed NRC Investigator; Entrance Meeting 9-9-80 HL&P QA Manager HL&P Executive Vice Feedback on progress / problems 9-10-80 President relative to review Show Cause/
Noncompliances.
HL&P QA Systems Super-Inspection of Show Cause/
9-15-80 visor RIV Task Force Noncompliances 9-16-80 9-18-80 HL&P QA Systems Inspection of Show Cause/
9-19-80 i
l Supervisor Noncompliances B&R QA Audit Section Manager HL&P Project Inspection of Show Cause 9-23-80
Manager, QA Systems Noncompliances 9-25-80 l
Supervisor, QA
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Discipline Super-visor.
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Attendees Sabject Date B&R Assistant Inadequate Audit Response 9-25-80 QA Manager
HL&P Executive Vice Status of RIV Task Force Review 9-26-80 President; Project i
Manager, QA Systems
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