ML19296D971

Responds to NRC 800124 Exit Interview Re Violations Noted in IE Insp Repts 50-498/79-19 & 50-499/79-19.Corrective Actions:Trend Analysis Program for Freas & Nonconformance Repts Being Developed

ML19296D971
Person / Time
Site:	South Texas
Issue date:	02/07/1980
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Seyfrit K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19296D970	List: ML19296D971 ML19296D972 ML19296D973
References
ST-HL-AE-417, NUDOCS 8003130688
Download: ML19296D971 (12)

Text

.] ' Houston gs L hting Power company --

Electric Tower RQ Box 1700

/ . Houston. Texas 77001 February 7, 1980 ST-HL-AE-417 SFN: C-0570 Mr. Karl V. Seyfrit, Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012

SUBJECT:

SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS DOCKET NOS. 50-498/79-19 AND 50-499/79-19 NRC EXIT INTERVIEW, JANUARY 24, 1980

Dear Mr. Seyfrit:

This letter is to provide our responses to the principle matters identified in the NRC Exit Interview conducted at the site on January 24, 1980.

1. FAILURE TO TAKE CORRECTIVE ACTION - SOME OF THE SAME DEFICIENCIES RELATIVE TO CONCRETE PLACEMENT WHICH WERE IDENTIFIED IN THE JUNE, 1979, NRC IMMEDIATE ACTION LETTER ARE STILL OCCURRING.

Corrective action as well as action taken to prevent a recurrence and the date that full compliance will be achieved in stated in correspondence reference below anci attached.

This item was initially identified to Houston Lighting & Power Company (HL&P) by the NRC in a meeting at Region IV Offices on December 21, 1979.

On December 28, 1979, we met again in your office and discussed a nine point program to correct the NRC identified problems. Subsequently, we sent the NRC a letter dated December 28, 1979 (ST-HL-AE-401) 8008130b

Hauston tyhung hher Compam Page 2 detailing our specific actions. Action Item #5 addressed the recurring problems in concrete placements.

Your letter of December 31, 1979, acknowledged receipt of our nine point corrective action program.

Our letter of January 25, 1980 (ST-HL-AE-409) provides the status of that program.

All actions on this item have been completed in accordance with our letter of January 25, 1980.

2. FAILURE TO TAKE CORRECTIVE ACTION - THERE IS NO EFFECTIVE TRENDING PROGRAM TO IDENTIFY AND CORRECT

" ROOT" CAUSES OF DEFICIENCIES. SPECIFICALLY, THERE IS NOT AN EFFECTIVE PROGRAM TO REVIEW AND ANALYZE NCRs, FREAs, ETC. FOR REPETITIVE OP""RENCES SUCH THAT " ROOT" PROBLEMS ARE IDENTIFIED AND CORRECTIVE ACTION IS TAKEN TO PRECLUDE REPETITION.

Corrective Action Taken A Trend Analysis Program for FREAs and NCRs is being developed which will:

a. Establish a coding system to identify FREAs and NCRs by uni number, building location, subject, parent uccument number, and dispo-sition. This will be complete by February 15, 1980.

b. Institute coding of current FREAs and NCRs and backfit all previously dispositioned documents. Coding will be effective February 15, 1980, and backfit will be complete by April 1, 1980.

c. Modify existing FREA tracking program to allow selective sorting and trending programs.

This will be complete by February 15, 1980.

Action Taken to Prevent Recurrence A quarterly Trending Report will be issued which will identify trends. These reports will be reviewed and all identified trends will be investi-gated for common causation. Remedial action will

Houston bgmir3 &ber Compane Page 3 be taken to remove " root" causes of reocurring deficiencies.

Date Full Compliance Will Be Achieved Promptly upon completion of our review, we will advise the NRC of the date full compliance will be achieved.

3. FAILURE TO TAKE CORRECTIVE ACTION - IMPROPER CORRECTIVE ACTION TAKEN RELATIVE TO A SPECIFICATION VIOLATION CONCERNING REQUALIFICATION OF CADWELDERS.

SPECIFICALLY, THE FSAR AND THE BROWN & ROOT SPECIFICA-TION REQUIRE REQUALIFICATION OF CADWELDERS IF TWO FAILURES OCCUR OUT OF FIFTEEN CONSECUTIVE SAMPLES.

CONTRARY TO THE REQUIREMENTS, NCR SC-3155 WAS DISPOSITIONED TO REQUIRE THE SPECIFICATION AND FSAR TO BE CHANGED AND THE CADWELDERS WERE ALLOWED TO CONTINUE CADWELDING.

Corrective Action Taken A detailed review of circumstances leading to the decision to revise or supplement requirements stated in the specification and the FSAR is underway.

This review will be complete February 15, 1980.

Corrective action will he determined by this review and implemented as appropriate.

Action Taken to Prevent Recurrence Action taken to prevent recurrence will be determined after our review of this situation is complete.

Date Full Compliance Will Be Achieved Until our review scheduled for February 15, 1980, is complete, we will not have a firm completion date.

4. INSPECTION AND TESTING PERSONNEL DID NOT MEET THE APPLICABLE PROCEDURE OR ANSI N45.2.6 QUALIFICATION REQUIREMENTS AT THE TIME OF THEIR CERTIFICATION.

Houston bght:ng iPom Compam Page 4 Corrective Action Taken A. A review of the qualifications and certifica-tions of Brown & Root QA/QC personnel is being conducted in accordance with action item #9 of our nine point corrective action program. Education and experience is being verified by direct con-tacts with previous employers and schocls. The preliminary results of the review indicates the following:

(1) Brown & Root QC Inspectors were certified to the then applicable Brown & Root QA Personnel Training Manual requirements prior to their performing any inspections. A revision to the Brown & Root QA Personnel Training Manual-STP Supplement dated October 1979 removed much of the latitude previously allowed. Personnel who do not meet the revised certification requirements are being retrained and recertified to insure that they meet the new requirements. All personnel will be recertified by May 15, 1980.

(2) Some Brown & Root QC inspectors were certified to perform inspections where their experience and educational background did not meet the requirements of the upgraded qualification and certification program outlined in the Brown & Root QA Personnel Training Manual-STP Supplement dated October 1979.

Investigations to date have identified only one individual for which there may be inadequate work experience or educational background. This individual will not be allowed to perform inspections until this matter is resolved.

B. Pittsburgh Testing Laboratory (PTL) personnel files and certification records are being reviewed.

This review will be performed by PTL management and audited by Brown & Root to establish that the review was done properly. This review will be complete by February 29, 1980, and action will be taken to insure that PTL personnel are properly qualified.

Hauuon tghting h )Wer Commac Page 5 Action Taken to Prevent Recurrence The qualification and certification program will be specifically reviewed during HL&P surveillance activities on site and audited as part of the HL&P and Brown & Root Audit Program.

Date Full Compliance Will be Achieved Action on item A. above will be complete by May 15, 1980. Action of item B. above will be complete by March 7, 1980.

5. INADEQUATE CONCRETE INSPECTION - NRC INSPECTORS IDENTIFIED UNWIRED SHEAR TIES AFTER QC SIGNOFF.

Corrective Action Brown & Root management held discussions with the entire QC organizations on February 5, 1980 to reemphasize that they are to take as much time as required to insure an accurate and thorough inspection.

Action Taken to Prevent Recurrence HL&P QA and construction personnel will ensure by their direct involvement in preplacement and placement activities that adequate time is allowed for the inspection of placement areas prior to and during the placement of concrete to insure that conditions are acceptable.

Date Full Compliance Will Be Achieved Full compliance was achieved on February 5, 1980.

6. FAILURE TO IDENTIFY A NONCONFORMING CONDITION IN THAT REQUIRED RELATIVE DENSITY TESTS FOR CLASS I BACKFILL WERE NOT CONDUCTED FOR APPROXIMATELY TWO MONTHS.

Corrective Action Taken HL&P issued a Site Discrepancy Memo on this subject on December 20, 1979. A new vibrating table was

Houston Lghtmg & Amer Companc Page 6 received on December 31, 1979. By January 9, 1980, the backlog of tests were completed; no failures of inplace densities were identified.

Action Taken to Prevent Recurrence A memo was issued to QA/QC personnel on February 1, 1980 (SQA-3329) stating that all nonconforming conditions will be documented as soon as the are identified.

Date Full Compliance Will Be Achieved Full compliance was achieved on February 1, 1980.

7. INADEQUATE PROCEDURE FOR CLASS I BACKFILL DENSITY TESTS. LOCATION (DEPTH) THAT TESTS WERE TO BE CONDUCTED WAS NOT SPECIFIED TO ASSURE PROPER COMPACTION WAS OBTAINED THROUGH EACH LIFT.

Corrective Action Taken A test program has been initiated on site, consisting of fifteen borings at approximate locations shown on the attached map. Eact boring will be made from existing backfill surface to subgrade, with standard penetration tests (ASTM D-156.) taken at 2'-6" intervals throughout each boring. The recorded blow count, N, will be plotted against depth and compared with theoretical counts to indicate whether proper density has been obtained.

This. program is currently in progress, and results are expected by February 15, 1980. A copy of the results will be sent to NRC at that time.

Action Taken to Prevent Recurrence Procedures are being changed to specify depths for conducting in-place density tests. Action will be completed by February 15, 1980.

Date Full Compliance Will Be Achieved Full compliance will be acheived by February 15, 1980.

Housuan Uc,ntmg & Pow Compam-Page 7

8. FAILURE TO CONTROL SPECIAL PROCESSES

a. RADIOGRAPHS

1. LINEAR INDICATIONR NOT ?ROPERLY IDENTIFIED OR DISPOSITIONED.

2. WALL THINNING NOT IDENTIFIED.

3. FILM ARTIFACTS NOT DOCUMENTED ON READER SHEET.

4. WIRE / FOREIGN MATERIAL

5. NO PROCEDURE FOR FILM PROCESSING CONTROL.

b. LIQUID PENETRANT RESULTS OF LIQUID PENETRANT EXAMINATION WERE NOT PROPERLY EVALUATED PER PROCEDURE.

Corrective Action T&Ren 6f I f

a. All radiography by site QA/QC personnel has been stopped, ual he re under direct [p'd;&v( ,, s supervision of # pUep? T II Engineering. , -y/

Retraining and re-certification of all site gfu p[ ,,,

NDE personnel was completed on February 1, /

1980. A procedure for the control of film Ill '/4,60 processing was issued on February 5, 1980. y 'I In the future, the shooter of an R/T film will not also do the film interpretation.

This will be incorporated in the NDE Procedures as a procedural requirement. In addition, a review of all previous R/T films will be conducted and the appropriate corrective actions taken. All NDE procedures requiring revision will be revised by February 8, 1980.

All radiographs will be again reviewed. This review will be complete by February 29, 1980.

b. All B&R personnel certified in Liquid Penetrant Examination will receive a refresher training program prior to their being allowed to perform further L/P examination. Retraining will be complete by February 8, 1980.

Houston lujiting & hmer Compant Page 8 Action Taken to Prevent Recurrence The NDE program will be specifically reviewed during HL&P surveillance and will be specially audited as part of the general HL&P and B&R audit program.

Date Full Compliance Will Be Achieved All action will be complete by February 29, 1980.

9. WELDING PERFORMED WITHOUT ADEQUATE PROTECTION FROM ADVERSE ENVIRONMENTAL CONDITIONS.

Corrective Action Taken This problem has been addressed by completely revising the Welder Training Program and adding a General Superintendent to coordinate work of the welders on the Project and to monitor their capabilities and progress, to initiate retraining where needed, and to work closely with the welding engineers and welder training department. Additionally, a new Chief Project Welding Engineer reported for duty on February 4, 1980. He will work closely with construction, welder training, B&R corporate welding engineering, and QA/QC groups to institute programs to further improve welding performance.

This new program will be implemented by February 15, 1980, including additional training of exist-ing welders on procedures / welding requirements.

Action Taken to Prevent Recurrence The new Welder Training Program will continue throughout the project. Implementation will be verified by HL&P QA surveillance on site and through the HL&P and B&R audit program.

Date Full Compliance Will Be Achieved Full compliance will be achieved by February 15, 1980.

10. FAILURE TO MEET REQUIREMENTS OF 10CFR50.55a (3)

RELATIVE TO THE QUALIFICATION OF WELDERS (IMPROPER PENETRAMETER PLACEMENT).

Houston Dditing Do.a.cr Companc Page 9 Corrective Action Taken HL&P QA issued Site Concern Memo CM-077 on December 13, 1979, requiring the plac ment of penetrameters on the source side for all radiography where the inside is accessible. Source side penetrameters have been used on all welders' qualifications since January 3, 1980, and will be used from now on when welders are qualified by radiography.

Action Taken to Prevent Recurrence The place of penetrameters will be reviewed during HL&P QA surveillance on site to determine that the procedures are being properly implemented.

Date Full Compliance Will Be Achieved Full compliance was achieved on January 3, 1980.

11. LACK OF ADEQUATE DOCUMENT CONTROL Corrective Action Taken All controlled documents on file in the HL&P QA offices have been reviewed and brought up to date as necessary. The number of controlled documents kept in the HL&P QA offices is being evaluated to determine that unnecessary documents are not maintained.

Action Taken to Prevent Recurrence The responsibility for document control of the HL&P QA site offices will be reassigned to an Administrative Technician to be hired by HL&P QA.

Date Full Compliance Will Be Achieved Full compliance will be achieved by March 1, 1980.

Houston ignung & Power Compans Page 10

12. HL&P QA SURVEILLANCE IS NOT DOCUMENTED IN ACCORDANCE WITH THE HL&P SITE QUALITY ASSURANCE PROCEDURES.

Corrective Action Taken Verbal instructions were given to all HL62 surveill-ance personnel on January 24, 1980, relative to the use of checklists to document all unsatisfactory conditions. Written instructions on this item were issued on February 1, 1980. Procedures will be revised to clarify the requirement to document all discrepancies noted during surveillance, including items being formally documented by others. All procedure revisions will be completed by February 25, 1980.

Action Taken to Prevent Recurrence Implementation of the Site Quality Assurance Pro-cedures will be verified by HL&P audits.

Date Full Compliance Will Be Achieved Full compliance will be achieved by February 25, 1980.

13. HL&P QA DID NOT PERFORM A COMPREHENSIVE AUDIT OF THE STP QA PROCEDURES AND CONSTRUCTION PROCEDURES.

Corrective Action Taken

a. The requirement in the South Texas Project Quality Plan to perform a corporate audit of B&R Construction annually had not been recognized.

Audits of Brown & Root construction will be conducted annually, with 1980 audits scheduled as follows:

(1) Civil Construction Activities - March, 1980 (2) Mechanical Construction Activities -

June, 1980 (3) Electrical Construction Activities -

August, 1980

Houston Eght:ng h IWe Conran.

Page 11

b. HL&P audit procedures will be revised to state that procedures implementation will be verified by direct observation of work being performed in the field as well as by reviews of documentary evidence of procedural adherence.

Action Taken to Prevent Recurrence HL&P management will implement an audit program to be performed by an outside consultant to assess the implementation and effectiveness of HL&P's QA Program for the South Texas Project. These audits will be conducted at leat' every 18 months.

Date Full Compliance Will Be Achieved Full compliance will be achieved by March 15, 1980. By March 1, 1980, an audit of the South Texas Project Quality Assurance Program will be scheduled.

Should you have any questions regarding the above information, please contact us.

Very truly yours, Y O

/

. . e as .

Execu ve ' 'ce-President Houston Lighting & Power Company Ghb:rka/jow Attachments cc: Messrs. E. A. Turner M. L. Borchelt (CP&L)

J. B. Poston (CPSB)

R. C. Mecke (CPSB)

R. L. Hancock (COA)

M. C. Nitcholas (COA)

D. G. Barker R. A Frazar W. N. Phillips G. B. Painter C. G. Thrash (Baker & Botts)

M. D. Schwarz (Baker & Botts)

H. S. Phillips (NRC)

J. R. Geurts (B&R)

C. W. Vincent (B&R)

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