IR 05000498/1981028
| ML20032A908 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/02/1981 |
| From: | Gagliardo J, Herr R, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20032A906 | List: |
| References | |
| 50-498-81-28, 50-499-81-28, NUDOCS 8111020540 | |
| Download: ML20032A908 (10) | |
Text
_
.
.
.
~
U. S. NUCLEAR-REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION IV
Investigatio,n Report:
50-498/81-28; 50-499/81-28
,
Dockets:
50-498; 50-499 Licensee:
Houston Lighting ar.d Power Company P. O. Box 1700 Houston, Texas 77001 Facility:
South Texas Project, Units 1 and 2 Investigation at:
Houston, Texas South Texas Project, Matagorda, Texas
.
Investigation Conducted:
July 29 - August 26, 1981 Investigator:
4v 2df878/
c R. K. Herr, Senior Investigator Date Investigation and Enforcement Staff
-=-
/d 8/
Inspector:
H S.[hillios,ResidentReactorInspector Date
!
Approved by:
/
In(vestigation and Enforcement Staff E. Gajliardo, Director Date i
Summary i
Investigation conducted on July 29 - August 26, 1981 (Report 50-498/81-28; 50-499/81-28).
r-8111020 f4pg s
-
.
.
.
.
.
m
g -,
_
__
..
_
_
..
.
a E'
.
'
,
Areas Investigated: Alleged improper activities by HL&P QA management-concerning: nonsupport of QA Department requested stop work order; nonsupport of QA audit personnal to write NCR's against licensed documents; nonsupport
. of QA procurement personnel in initiating NCR's; and disguised wrlding rework activities. This investigation involved 90 investigative hours 'cy one NRC investigator and one NRC inspector.
j Results
'
i Investigation disclosed that HL&P QA management had authority and acted within HL&P procedures to correct NCR deficiencies in the absence of a stop work order; that HL&P QA management through misunderstanding did prevent QA auditors
from writing NCR's against licensing documents; that welding was not disguised in any manner; and that HL&P QA procurement personnel were instructed properly by HL&P QA management in regards to initiating NCR's.
.
l
)
.
i
.
.
.
.
.
...
..
.
.
.
!
.
.
SUMMARY The investigation disclosed that HL&P QA personnel supported a stop work order based on an NCR that was written in June 1981; however, upper management personnel (HL&P QA and Project Managers) did not support a stop work order and chose to accelerate correction of the nonconformance in order to avoid
,
a stop work order. The investigation reflected that the NCR in question was being properly addressed in that a final resolution had been agreed upon by Brown & Root and HL&F, and was pending final implementation by 5 'wn & Root. Secondly, the investigation disclosed that HL&P QA management told QA auditor personnel not to write up NCR's on things which were out
'
of compliance with the FSAR and/or QA program description during a June 1981 meeting; however, HL&P QA management explained that a great amount of confusion and/or misunderstanding had occurred. This particular issue has been resolved with the issuance of an HL&P position statement that gives auditors the freadom to write NCR's against the FSAR and/or QA program description ThirJ1y, the investigation disclosed that one individual in the HL&P QA organization had directed his personnel to direct Brown & Root personnel to write NCR's when discrepancies occurred; however, this was in accordance with HL&P and B&R procedures.
Finally, the investigation disclosed that multiple welds were accomplished during welding (a'uminum/ bronze) operations, and B&R procedures require engineers to evaluate the effects on the mechanical properties.
In addition, informational radiographs of welds were performed and reviews were documented on these repairs / reworks to ensure proper welding in accordance with proper welding codes and procedures.
BACKGROUND On June 22, 1981, Individual A telephonically notified the reporting investigator and stated that he had received a telephone call from an
individual who identified himself as " Joe Duncan." According to Individual A, "Mr. Duncan" claimed to be a QA inspector for HL&P while located at the
,
South Texas Project.
Individual A stated that "Mr. Duncan" provided allegations set forth in this report; however, he refused to provide further details or information which might identify him.
Individual A remarked that efforts to identify "Duncan" as an HL&P ' employee were negative. The investigator was unable to identify "Mr. Duncan" on current or past HL&P orga,iizational charts or rosters. HL&P indicated that parsonnel records showed that no such person ever worked for HL&P.
-
- -
-.
-
.
- ---
-
.
-
-
--
-
--
( _.
.
.
DETAILS 1.
Persons Contacted Principal houston Lighting and Power Company (HL&P) Employees R. Frazar, QA Manager D. Barker, Project Manager Principal Brown & Root (B&R) Employee Other Individuals Individuals A through Z 2.
Investigation of Allegation!
Allegation No.1 That Individuals X and Y, HL&P management personnel, disagreed with HL&P QA personnel who wanted to issue a stop work order to Brown &
Root design engineering relating to the fact that Brown & Root design engineering effort was falling behind construction activities which might produce construction errors.
While an NCR had been issued on this topic, HL&P QA personnel thought a stop work order should have been issued.
Investigative Findings Investigation disclosed an HL&P memorandum (Attachment 1) dated June 5, 1981, executed by Individual K, concerning design review accessibility.
This memorandum identifies HL&P QA concerns about the lack of design access criteria supplied by Brown & Root, and stated that Individuals C and L would develop an NCR (subsequently identified as ST-5A, Attachment 2) and utilize this as a basis for a potential stop work order regarding access design review activities.
Individual C stated that upon receipt of Attachments 1 and 2 he drafted a stop work letter; however, he withdrew the letter after a subsequent meeting with Individual Y.
Individual C explained that Individual Y requested the opportunity to try and obtain Brown & Root's immediate attention relative to correcting the condition described in the NCR and if
<
-
-
-
-
-
-
-
- - - -
-
-
-
-
- -
-
-
- -
- -
.
-
_
.
.
he were unsuccessful then the NCR should be elevated to a stop work order.
Individual C remarked that his main goal, and the goal of his management, Individuals I and X, was to get the attention of Brown &
Root management for appropriate action in this area in order for them to readdress priorities and ensure that adequate access design (procedures)
measures were established and implemented in a timely manner.
Individual C pointed out that the original NCR (ST-5) concerning this area was executed in November 1980.
Individual C stated that subsequent contact with Brown & Root management on August 10, 1981, resulted in a satisfactory action / response to NCR ST-5A which is scheduled to be implemented on or about October 1981.
Individuals X and V, HL&P management personnel, advised that they supported Individual Y's position that a stop work order was not needed at this time and additional overall information was needed to resolve the subject NCR.
'
Individuals J, K, S, and M, HL&P QA personnel, all supported a stop work order explaining that access design problems were identified as early as July 1979, in audit report BR-25 and again in HBR-43 (performed May - June 1981).
In addition, the investigation disclosed that a consultant report dated May 1981, from the Quadrex Corporation, 1700 Del Ave., Campbell, California had also identified B&R access design problems.
Individuals J, K, S, and M stated that the stop work order is not the main issue but effective and timely corrective action by Brown & Root is the real issue.
Individuals J, K, S, and M remarked they did not care what mechanism was utilized to achieve the desired results, explaining that getting the attention of Brown & Root management to assure implemen-tion of the corrective procedures is the important aspect.
Individual Y stated that he could not specificallj recall having a meet-ing with Individual C; however, he recallad NCR ST-5A and remarked that he personally contacted Brown & Root upper management in June 1981, and requested immediate corrective action.
Individual Y stated that subsequent to August 1981, a joint meeting was held between bl&P QA and Brown & Root personnel and that proper action was initiated by Brown & Root.
He added that implementation of that action would correct the condition identified in the NCR.
Individual Y did not believe that a stop work order in this case would have accomplished the corrective action as quickly as his efforts did.
- - - -
-
-
-
-
.-
.
.
-
-
- - -
.
-.
.
-
.
r
.
.
Individual W, HL&P QA management individual, advised that he did not become aware of the NCR in question until August 22, 1981.
Individual W remarked after a raview of the NCR ST-5A that he would have supported a stop work order based on the B&R's failure to take effective and timely corrective action on the NCR regardless of the seriousness of the NCR.
Individual W stated that he would look into this situation, and if in his judgment, Brown & Root's implementation of the proposed corrective action was not timely enough, he would not hesitate to immediately issue a stop work order.
Allegation No. 2 That Individuals S and Y told HL&P audit personnel not to write up NCR's on things that were out of compliance with the FSAR or the new QA program description given to Nr.R, because "it is just a licensing document not a regulatory item."
Investigative Findings Interviews of Individuals B, N, S, and 0, HL&P QA personnel, disclosed that an audit (No. HBR-43) was conducted at South Texas Project (STP).
Individuals B, N, S, and 0 remarked that during this audit a meeting was held at STP with c.ognizant personnel including Individuals B, N, S, 0, and Z.
According to Individuals B, N, and 5 this meeting was held because questions were raised by HL&P QA management relative to manage-ments concerns that the HL&P auditors were writing NCR/ADR's against the FSAR and/or the new QA program description.
According to t
Individuals B, N, 5, and 0 Individual X stated during this meeting words to the effect, that the FSAR and the new QA program description given to NRC are just licensing documents and not regulatory items and that NCR/ADR's were not to be written on tnings that were identified as being out of compliance.
This interpretation was further substantiated in part by Individual Z who wrote a letter (Attachment 3) to Individual X setting forth the general position of Individual X during the June 11, 1981, meeting.
In addition, Individual I submitted an HL&P office memorandum dated July 24, 1981, (Attachment 4 - selected portions) that further substantiates, in part, the comments made by Individual X.
Indi-vidual Y remarked he was present during the June 11, 1981, meeting at STP but could not clearly recall what was stated.
Individuals N, 0, and J each stated that as a result of the June 11, 1981, meeting, and the remarks made by Individual X, a great deal of misunderstanding had occurred, and an HL&P's position on this matter was not clear.
r
.
-
- - -
-.
.
.
-
. - - -
- -
.
- -
-
-
-
T
.
.
Interview of Individual X resulted in Individual X stating that he was aware that some misunderstanding occurred as a result of his comments but believed the issue had been clarified.
Individual X remarked that he did not specifically state that auditors should not write NCR/ADR's on things out of compliance with the FSAR or the new QA Program Description given to NRC because they are licensing documents and not regulatory i tems.
Individual X stated that he recognized that further dialogue was necessary after the meeting to clarify certain issues.
Individual X stated that he only read the letter from Individual Z within the past day or so (August 19,1981) and that he does_not agree with the contents.
Individual.X remarked that he will write a letter to Individual Z, clarifying the HL&P QA organization's position and further make the letter available.to cognizant QA audit personnel.
Individual X executed a response letter (Attachment 5) to Individual Z which stated HL&P QA's position, and clarifies the issue. Subsequent contact with HL&P auditors disclosed that Attachment 5, cleared up all misunderstanding and emphasized that they support this position.
Allegation No. 3 That welding is being done six or seven tirnes to get acceptable weld; however, when welding six or seven times on the same weld one destroys the tensile strength. While welds are being done again, the welding is called " informational" rather than rework in an attempt to disguise the multiple effect.
Investigative Findings Interviews of Individuals P, Q, and R and review of selected records resulted in the identification of instances where multiple repair or rework was accomplished in accordance with standard repair procedures.
Interviews with an HL&P Welding Supervisor, an HL&P QA Specialist, and a B&R Welding Engineer resulted in identifying the area where the highest reject / repair rate cccurs.
The Essential Cooling Water (ECW)
System is the area. The investigators reviewed HL&P and B&R welding trend reports; HL&P correspondence No. BC32953, June 30, 1981, and B&R correspondence No. BC32961. The trends in these reports cover the periods since ASME welding was restarted in October 1980 until August 15, 1981.
These reports track the rejection rate, welder preformance analysis and tne welder / welding operator proficiency to reduce welding
,
problems cr identify welders needing additional training.
The inves-tigators determined that excessive repair rates are closely monitored and engineers must evaluate welds where more than three major repairs occur. This is required by welding procedure tiECD-4.
Investigators selected weld number 0001 in the ECW system which represented the " worst
case analysis." This weld had been repaired as many as six times as a
-
result of informational radiographic examinations identifying weld
"
. defects that had to be repaired. All of the welding that had been performed since October 1980, had been or was in the process of_ being
.
- -
-
- -
-
-
-
-
l
.
.
l re-examined and repaired as a result of commitments made to the NRC in the licensee's response to the Show Cause Order. All of the welding repairs reviewed were accomplished in accordance with B&R procedures MECP-4, Revision 15, Section 8.12, Weld and Base Metal Repairs, and in accordance with ASME Code Division 1, Class 3 requirements. The subject code does not require radiographic examination; however, the licensee elected to perform informational radiographic examinations of the aluminum-bronze material because it is a difficult material to weld.
" Informational radiography" is a term used to describe radiographs of a weld that cre not required by ASME codes, but is a test or examination which the licensee performs for his own benefit or information. Through further discussions with a Brown & Root Welding Engineer, the investigators found that, in general, Brown & Root had not welded materials where multiple repairs would have an adverse affect on the tensile strength of the materials.
The only material that had been welded and could be adversely affected was the stainless steel piping; however, there had been no such multiple repairs on sta bless steel piping since October 1980.
Interviews with Individuals T, E, and D, Brown & Root QC inspectors (mechanical), disclosed that all repair or rework was documented in accordance with Brown & Root procedures.
Further, all repair work that was ordered had an engineering evaluation and the orders were signed by the appropriate engineer.
None of the above individuals had any knowledge of undocumented repair work.
Individual T advised that there had been about five different welds (aluminum / bronze) that required five to six repairs around the weld joint-circumferences (not on the same spot), and each time a radiograph was taken to ensure proper welding.
Individual U stated that any welds performed on an identical location on the circumference /
joint in excess of three times had been cut out and removed.
Allegation No. 4 Individuals C and F, both of HL&P QA Procurement Program, are " screwing up everything" because of no experience.
In addition, they are the only ones who could write up NCR's. Also, when other HL&P QA personnel asked for an NCR to be written up they are told by Individuals C and F to go have Brown & Root write it up.
Investigative Findings Review of background experience of Individuals C and F by the investigator /
inspector disclosed both Individuals C and F have edequate education and J
{
.
.
experience f or their respective positions.
Interview of Individual X.
Individual C's former supervisor, resulted in his explaining that he did not provide Individual C with enough guidance and/or direction due to numerous other high priority comitments and the fact that he (Individual X) was physically located about 90 miles away.
Individual X explained that a number of minor problems developed in Individual C's office as a result of a lack of positive leadership from himself and/or other management supervisors.
Individual X noted that HL&P Procedures Manual PSQP-A9, page 7, paragraph 6.3.3.3, states in part, "Nonconformance Reports and/or Corrective Action Requests shall be generated by Brown &
Root or HL&P."
Individual X stated that in accordance with HL&P procedures it would be proper for Individuals C or i to instruct subordinates to tell Brown & Root personnel to write up or generate an NCR when they discovered a nonconfonning condition.
Individual X remarked that anyone in HL&P can write up an NCR.
During an interview of Individual W, Individual C's present supervisor, he explained that he recognized that Individual C did not receive adequate supervision in the past and there was a lack of proper guidance and direction on the part of HL&P management.
Individual W stated that although Individual C is physically located in excess of 90 miles away from his location, he had spent at least 1 day a week with Individual C to give him guidance and direction.
Individual W stated that he had discovered during these 1 day a week conferences with Individual C that there was a need for additional personnel, including clerical assistance, which was presently being considered.
Individual W remarked that he was clarifying Individual C's job function and telieved Individual C is a qualified and a capable individual.
I Individuals D, E, F, G, and H, HL&P QA personnel, were interviewed.
Interviews showed there was some confusion as to who actually writes up an NCR.
Three individuals stated they had not found any discrepancies and therefore had not written an NCR within the past 6 months.
One individual advised that when he discovered an NCR condition, he identified his concerns to Individual C and Individual C told him to "tell Brown &
Root to write up the NCR," add %9 that this was in accordance with HL&P procedures.
Individuals D, E, F, G, and H advised that there had been two training classes regarding HL&P procedures, including the PSQP-A9.
However, one individual admitted that he was absent curing one of the training periods.
Individual C stated that he keeps a log of NCR's that are written in his department, adding that his QA department did not normally write a great deal of NCR's.
Individual C stated that he has written aDout six NCR's during the past 6 months which have been entered into the Brown & Root NCR system in accordance with HL&P Procedure PSQP-A9.
-
-
-
-
- - -
-
-
-
-
-
-
- -
-
-
- -
-
-
- -
-
-
n y,
....
CAPTIONED DOCUMENTS A copy of all documents identified herein as attachments, relating to these allegations, are maintained in the NRC, Region IV Office. The following is a list of documents utilized in this report.
1.
Document 1 - HL&P office memo #Q-7050, dated June 5,1981 2.
Document 2 - HL&P office memo #Q-9000, dated June 11, 1981 3.
Document 3 - B&R letter, SFN #Q-0100, dated June 30, 1981 4.
Document 4 - HL&P office memo #Q-5000, dated July 24, 1981 5.
Document 5 - HL&P letter, SFN #Q-3200, dated August 24, 1981
- - - -
- -
-
-
-
- -
.
.