IR 05000498/1985023

Insp Repts 50-498/85-23 & 50-499/85-20 on 850911-1220.No Violation or Deviation Noted.Major Areas Inspected:Policies, Procedures & Implementation Re Identification & Disposition of Assertions Concerning Util Vs Brown & Root

ML20154P819
Person / Time
Site:	South Texas
Issue date:	02/19/1986
From:	Breslau B, Constable G, Madsen G, Masden G, Powers D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154P818	List: IR 05000498/1985023 ML20154P812
References
50-498-85-23, 50-499-85-20, NUDOCS 8603200422
Download: ML20154P819 (9)

Text

. .

APPENDIX U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-498/85-23 CP: CPPR-128 and 129 50-499/85-20 Docket: 50-498 and 50-499 Licensee: Houston Lighting & Power Company (HL&P)

P. O. Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection At: S. Levy Inc., Campbell, California Inspection Conducted: September 11 through December 20, 1985 Inspectors: A A// L!fb B. A. Breslau, Reactor Inspector, Project

~

Date '

Section C, Reactor Projects Branch

,

N t</ W D. A. Powers, Enforcement Officer 2!/3f5 Date

'

$ObCVL/

'G. L. Madsen, Reactor Inspector A fm /8G Date Comanche Peak, RIV Group f,/ _ ,5 ' }

,;,- ;L l-6 7fpg,'g,

'

'

G. L. Constable, Chief, Project Section C, Date '

Reactor Projects Branch 8603200422 860307 PDR ADOCK 05000498 G PDR

---

__-------____--_-d

. .

t

Approved: c 2 7 d G. L. Constable, Chief, Project Section C, Date Reactor Projects Branch Inspection Summary Inspection Conducted Between September 11, 1985 and December 20,-1985 (Report 50-498/85-23; 50-499/85-20)

Areas Inspected: Reactive, unannounced inspection of applicant's policies, procedures, and implementation relating to the identification and dispositioning of assertions associated with the Houston Lighting & Power Company v Brown & Root Litgation Record. The inspection involved 172 inspector-hours at the SLI facility located in Campbell, California, by four NRC inspector Additional inspector hours were spent reviewing documentation in Region IV office Results: Within the areas inspected, no violations or deviations were identifie ,

._

. .

DETAILS Persons Contacted

• D. F. Bednarczyk, Project QA Supervisor, HL&P

• J. B. Anderson, Senior QA Specialist, HL&P

• S. Levy, President, S. Levy, Inc. (SLI)

• C. B. Johnson, Team Leader, SLI (Manager)

• G. J. Walke, QA Manager, SLI

• R. Wisenburg, Manager, Nuclear Licensing, HL&P

• E. Baer, Attorney, Newman & Holtzinger, HL&P

• F. A. White, Lead Engineer, HL&P E. Duke, QA Specialist, SLI H. McKenna, Computations Manager, SLI V. Jones, Records Management, SLI R. Brugge, Training Instructor, SLI J. Kjembrup, Project Coordinator (Team Leader), SLI A. Engler, Reviewer, SLI G. Roy, Disposition Squad Leader, SLI In addition to the above personnel, the NRC inspectors held discussions'

with various technical and administrative members of HL&P's and SLI's staf * Denotes those present at exit intervie . Introduction On August 30, 1985, Houston Lighting & Power Company (HL&P) submitted the South Texas Project (STP) Litigation Review Program to the NRC. During October 1985, S. Levy, Inc. (SLI) began the review of the litigation record for HL&P. The NRC has reviewed the review program and has completed three inspections of this review effor Training September 11, 1985 Program Implementation November 12-15, 1985 Resolution of Assertions December 16-20, 1985 The results of these inspections are documented belo The purpose of this inspection effort was to ascertain the effectiveness of the HL&P/SLI review effort and to determine if the review was being conducted in accordance with the review program and to review HL&Ps resolution of NRC coments on their review program. To date, the review has identified approximately 5,600 assertions (potential deficiencies in systems, structures or components or their associated design or quality documents), many of which are redundant. The dispositioning of these assertions is in progress and is expected to be completed during January 1986. HL&P will issue a final report shortly after the completion of the revie _- _A

.

. , . .

,

3. Organization The NRC inspectors reviewed the litigation review organization to ascertain how the various elements of the organization implement the '

progra The organization includes approximately 58 people. .Many of the technical specialists are retired General <Elec,tric employees with many years of nuclear experience. The SLI QA organization consists of a QA manager and three QA specialists The NRC inspectors interviewed individuals from the following organizational elements:

LeadEngineer(HL&P)

ProjectQASupervisor(HL&P) '*

TeamLeaderProjectManager(SLI)

QA Manager (SLI) '

QASpecialist(SLI)

Reviewer Computations Manager Training Records Management Project Coordinator / Team Leader (SLI)

The NRC inspectors observed that SLI management was heavily involved with the overall review. The review team leader (SLI manager) had personally reviewed the ' work of each reviewer and had acted-to change his organization as necessary to achieve the objectives of the review. The NRC inspectors observed that all the work of some individuals was re-reviewed because of unsatisfactory results which had been identified by various evaluation The management and QA organizations have each identified weaknesses in program implementation. When identified, the problems were promptly and thoroughly resolved by stopping work,f managing the reviewers and causing re-reviews and retraining to be conducted as necessar No violations or deviations were identifie . Qualification of Personnel The NRC inspectors reviewed the resumes of the participants involved in-the review process. The review indicated that the individuals met the managerial / technical experience and educational levels for the positions they were. certified to perform. SLI had noted that one reviewer did not

l w- ,_

+_ -.. .. - _ _ - - - - -

- - - - . . _

i

.

. .

r

,

,

possess an engineering degree. 3LI requested and received a waiver from HL&P for this individual based upoi; the years of experience this individual possessed. Subsequently, this individual and two others were removed from the project because of inadequate document reviews. SLI has conducted a re-review of those documents which were previously reviewed by the individuals removed from the projec No violations or deviations were identified, t

5. Training The NRC inspectors reviewed training course material for individuals utilized for identifying assertions in the litigation records and identifying project documents which show that the issues have been properly addressed. On September 11, 1985, an NRC inspector attended a SLI training session for personnel who were scheduled to perform the HL&P vs. Brown & Root litigation review. The training session was conducted at the SLI facilities in Campbell, California. Approximately a dozen people were in attendance as students or trainers. Classroom instruction' was complemented by video tape presentations and two notebooks; one on the lesson plan and one on historical information, purpose of the project, work procedures, position descriptions, policies, etc.. All personnel who will be working under the HL&P/SLI contract were informed of the mechanics of the work to be accomplished, admonished on the need to produce quality work, and informed of the incentive awards to be given at the conclusion of the contract's performance period. Also, during the training session personnel were instructed on the SLI and HL&P quality assurance program, which will run concurrently with the review effort. These programs oversee and randomly sample work products from all disciplines involve The quality of training, prepared material, and various steps that were taken to ensure reviewer alertness to assertions was deemed adequate for the purposes intended. Those in attendance as students and trainers appeared appropriately responsive to the guidance give '

An NRC inspector's review of training records revedled that all participants have received the required training and were certified to perform one or more of the following litigation review functions:

(a) Reviewer, (b) Discipline Specialist, (c) Overview Specialist, and'

(d)TeamLeader. HL&P and SLI QA coverage of the ' initial assertions review -

process noted items which were not being identified. The. review process was stopped and all participants received a refresher trair.ing cours '

Litigation material that was reviewed prior to this time was re-reviewe These training sessions appear.to have provided adequate guidance for the identification of potential safety-related deficiencies in the design and construction work for ST No violations or deviations were identified.

t

'

j

.

.

.

. .

6 Review of Procedures The NRC inspectors reviewed the following Litigation Review Program implementing procedures. The purpose of the review was to determine, on a sample basis, that the implementing procedures provided adequate guidance when used in conjunction with the training program to assure that the overall program would be properly implemente Title Revision SLI Project Plan 0 SLI Review of HL&P vs. B&R Litigation Record 0 SLI Review of HL&P vs. B&R Litigation Record - Subject Groupings 0 SLI QA Audits, Surveillance and Reviews 0 SLI Deviation Reporting and Action Item Requests 0 SLI Guidelines for Review at HL&P vs. B&R Litigation Record 0 The NRC interviews (see paragraph 3 above) with selected project personnel revealed that each displayed a comprehensive knowledge of the procedures and were confident in Each member maintains a personal (performing their various functions. control copy) of the proced reviewed twenty individuals' procedure books and found each to be an up-to-date copy. Additionally, the NRC inspectors reviewed detailed memoranda and instructions which were issued as supplements to the project procedure The NRC inspectors concluded that the procedures, as written, provided ,

adequate guidance to implement the program. Revisions to procedures were reviewed during the course of the inspection. These revisions provided clarification on details of the progra *

No violations or deviations were identifie . NRC Review of the Litigation Record Initial screening of the litigation record was conducted by HL&P. The interrogatories, deposition transcripts and expert reports were screened to determine which of them are likely to contain technical information on STP design, construction or QA/QC. Those which were not screened out were sent to the-SLI offices. Once the records were received by SLI,'they were assigned document number In some cases, individual. documents were assigned multiple document numbers when the documents were too large to facilitate the revie A few documents were forwarded to SLI in error and were not subsequently

_

reviewed by SLI. The NRC inspector selected one of these documents (D-165) for NRC review in order to determine the basis for SLI not

, reviewing the document. This particular document was the deposition of J. B. Webb, Project Superintendent in the Power Division Maintenance Grou . -

i' ._ l

- - . - - . - - - - . - - . -- . - -- - . . .

l . . ..

.

1

'

The deposition was conducted on August 17, September 7-9, and October 17, 1983. The NRC inspector observed that Mr. Webb's job was described in the deposition as preparing proposals for maintenance and

capital improvements and that he occasionally supervised maintenance

<

projects. The NRC review of the deposition revealed,that questions dealt with Mr. Webb's work as overall Lead Scheduler in 1974, 1975 and

'_

1976. The subject of the deposition was . limited to questions on planning and scheduling involving schedule milestones and progress report The NRC inspector concluded that the decision not to perform a detailed review of this deposition was appropriate and in accordance with the intent of the review program.

.>

l No violations or deviations were identifie I

, Identification of Assertions -

As of December 16, 1985, SLI records indicate that the review and a identification of assertions had been completed for 593 of 595 HL&P vs. B&R '

litigation records. SLI records also indicate that about 17 percent of *

2 the' document reviews have received an independent evaluation, each

reviewer had received at least one evaluation, and the work of five l reviewers was subject to a less than ten percent evaluation.

l During the intitial phases of assertion identification, SLI and HL&P j concluded that additional training was needed. The initial 20 documents

were placed in a control group and received a 100 percent evaluation and revie The NRC inspectors performed an independent review of ten litigation documents for which the reviews and evaluations had been completed and concluded that SLI is meeting the program objectives relative to the identification of assertions contained in the HL&P vs. B&R litigation recor During the evaluation of the review identification records, the NRC inspector noted that some reviewers received limited evaluations beyond that which was conducted in association with the initial control grou The inspector indicated. that the evaluation requirements of the program procedures had been met; however, the performance of additional evaluations for a limited number of reviewers would enhance the confidence factor for the evaluation of'these reviewers. The'NRC inspector was told that additional evaluations would be performe No violations or deviations were identifie . Disposition of Assertions l

The NRC inspectors reviewed the documentation associated with six disposition numbers (representing 20 assertions). The inspector noted that the documentation was readily retrievable and supported the dispositioning of the assertion s s

-

..

-

-

,

. .. .

s

,

The NRC inspectors also reviewed.SLI's QA evaluations of completed disposition forms and reviewed the evaluations conducted on 12 of 49 completed dispositions and 3 dispositions which.had not^ received a QA review or an evaluation review. ' ,

The NRC inspectors noted'160. dispositions, which addressed 374 assertions, had been determined to be classified as nonsafety (NS), Not An Assertion

~

(NOA), or factually erroneous'(FE). Three of those classified as (NS)

were determined by the overview specialist as being safety-related and '

will receive further evaluation The NRC. inspectors determined from the review of selected assertion closure information that the identified assertions are being adequately -

dispositione . Management Oversight and Quality Assurance Programs HL&P assigned a full time project manager, a project QA supervisor and a senior QA specialist to monitor the review effort at the SLI offices in Campbell, California. In addition, a Senior Advisory Panel was established to provide a management overview of the progress of the litigation review progra HL&P began their oversight activities in August 1985_which included direct observation of SLI activitie The NRC . inspector reviewed the following documents:

SLI Monthly Status Report (August 1985)

SLI Monthly Status Report (September 1985)

HL&P QA Monthly Status Report (October 1985) .

HL&P QA Interim Report (October 18,1985)

HL&P QA Monthly Report (September 1985)

In addition, as noted above, the NRC inspectors interviewed various managers and QA personnel during the course of the inspectio The NRC inspectors observed that HL&P QA had reviewed the SLI procedures

. to verify that the program procedures adequately implemented the Litigation Review Progra ,

.

The NRC inspectors consider that the HL&P_QA program is effectively performing its intended function. >

The SLI QA program is tailored to ensure a comprehensive control'is maintained throughout the short duration'of the litigation review projec SLI has established a requirement to conduct two audi.ts and approximately four surveillances per. wee SLI QA conducted the first audit early in the litigation. review process to-establish a base line and'to determine potential problem areas. The scope

, =

,

t

,

' , , .,

. . . _

• # _ *- , A _

. . .. - . - -_ . -

.. _ _

, _. - . - . - . . - .

~

,

!

a .. .

l-

!

1 of the audit was to verify that the tasks described in the SLI litigation review 1985 Project Plan Manual were being implemented. This included the

'

Project Plan, Project Procedures LRP-1 through LRP-6, LRP-1 Guideline and working level instructions. The SLI audit teams audited tasks that had been or were being performed.

The audit' identified three deviations and five observations which addressed concerns of the auditors. Project management was responsive in

,

addressing and dispositioning these items, no adverse impact on the quality of the project was observed by the NRC inspecto The NRC inspector reviewed 29 completed SLI QA " Surveys" and 145 completed

" Reviews." These were reviewed for thoroughness and degree of objectivity

towards obtaining an adequate evaluation of the work being accomplished by-the reviewers. Additionally, the NRC inspector reviewed the related -

inspection check lists and found them to be thorough and comprehensiv Based on these observations, the NRC inspector has determined that an-adequate QA program is being maintained on this projec '

f 11. Conclusion The litigation review effort appears to be progressing smoothly and may be ahead of schedule. HL&P and SLI seem to be committed to conducting substantive reviews and the QA organizations appear to be performing indepth technical evaluations and not merely limiting their effort to paper work review The NRC inspectors conclude that the litigation review program is bein implemented as intende i 1 Exit Exit interviews were conducted on November 15, and December 20, 1985, with personnel as indicated in paragraph 1 of this report.

I

<

%

$

% 's-

< - ~ - a