ML19309H549
| ML19309H549 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/30/1980 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML19309H550 | List: |
| References | |
| NUDOCS 8005130487 | |
| Download: ML19309H549 (2) | |
See also: IR 05000498/1979019
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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APR 3 01980
Docket Nos. 50-498
50-499
1
Houston Lighting and Power Company
ATTN:
Mr. G. W. Oprea, Jr.
Executive Vice President
P. O. Box 1700
liouston, Texas 77001
Gentlemen:
This refers to our special investigation of construction activities at the
South Texas Project Units 1 and 2 which are authorized by NRC Construction
Permit Nos. CPPR-128 and CPPR-129.
Our investigation was separated into two
parts:
(1)
Investigation of current allegations relative to harassment,
intimidation, and lack of support of quality control inspectors by
QC management, and
(2) Assessment of the effectiveness of the QA/QC program for ongoing
activities.
This letter and the attached report address the results of our investigation
which was conducted between November 10, 1979 and February 7, 1980.
Based on the results of our investigation, it appears that certain of your
activities at South Texas Units 1 and 2 were not being conducted in compliance
with NRC requirements as described in the enclosed Appendix A.
These items of
apparent noncompliance coupled with the substantiated allegations involving
production pressure, lack of support by QC management, harassment, intimidation
and threats directed toward QC inspectors indicate impairment of the quality
assurance program at the South Texas Project.
These problems were identified
in connection with the quality assurance program of one of your principal
contractors, Brown and Root, Incorporated.
Further, similar items of noncompliance and substantiated allegations of
harassment and lack of support of QC personnel have been the subject of
previous NRC correspondence with you and indicate that your past corrective
action on these matters has been incomplete or ineffective.
Although these
problems have been to a great extent associated with Brown and Root quality
(
assurance program implementation, as licensee you have prime responsibility
for correction.
The deficiencies in the Brown and Root program were so
extensive that they should have been readily detected.
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
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APR 3 01939
.
Housten Light and Power Ccmpany
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As you are aware, the enforcement actions available to the Commission in the
exercise of its regulatory responsibilities include administrative actions in
the form of written notices of violation, civil monetary penalties, and orders
pertaining to the modification, suspension or revocation of a license.
After careful evaluation of the items of noncompliance identified in Appendix
A, and other results of our investigation, this office, pursuant to the
Cossnission's regulations in 10 CFR 2 and 50, hereby serves the enclosed Order
to Show Cause on the Houston Lighting and Power Company.
In addition to the Order, we also are proposing civil penalties, for the items
of noncompliance cited in Appendix A in the cumulative amount of One Hundred
Thousand Dollars. Appendix B of this letter is the Notice of Proposed Imposi-
tion of Civil Penalties.
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, the enclosures,
and your response to this letter will be placed in the NRC's Public Document
Room.
Sincerely,
-
Vi
o
7.-
Director
Office of Inspection
and Enforcement
Enclosures:
Appendix A - Notice of Violation
Appendix B - Notice of Proposed
Imposition of Civil Penalties
Appendix C - Cross References:
Violations to Report Details
Apendix 0 - Investigation Report
50-498/79-19; 50-499/79-19
Order to Show Cause
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APR 3 01980
Q
APPENDIX A
8 0051308f9 i
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Houston Lighting and Power Company
Docket Nos.: 50-498
50-499
Based on the results of the NRC investigation conducted during the period
November 10, 1979 through February 7,1980, it appears that certain of your
activities were not conducted in full compliance with the conditions of your
NRC Construction Permits Nos. CPPR-128 and CPPR-129 as indicated below.'
A.
10 CFR 50, Appendix B requires that licensees holding construction
permits implement a quality assurance program meeting the criteria of
Appendix B for all activities affecting the safety related functions of
structures, systems, and components that prevent or mitigate the conse-
quences of postulated accidents that cause undue risk to the health and
safety of the public.
Section 17 of the South Texas Plant Preliminary
Safety Analysis Report sets forth the Quality Assurance Program developed
by the licensee to implement Appendix B.
Contrary to the above, during the period of October 1979 through January
1980, the licensee was in continuous noncompliance with 10 CFR Part 50,
Appendix B in that the licensee and Brown & Root (B&R), did not adequately
control all activities affecting the safety related functions to assure
that such activities were conducted in accordance with the Appendix B
Criteria.
This continuous noncompliance is evidenced by numerous examples *
in the subject area of Criteria
I, III, V, VI, IX, X, XV, XVI, XVII,
and XVIII, as follows:
1.
10 CFR 50, Appendix B, Criterion I states in part, "The persons and
organizations performing quality assurance functions shall have
sufficient authority and organizational freedom to identify quality
problems . . . . including sufficient independence from cost and
schedule...."
The South Texas Project (STP) Preliminary Safety Analysis Report
(PSAR) in Section 17.1.1B (through Amendment 32, 10/17/75) states in
part, "To assure the establishment and operation of the QA/ Quality
Control (QA) Program, B&R has an organization such that those per-
forming the QA/QC functions have the freedom to identify quality
problems, to provide means for obtaining solution to problems, and
verify that solutions have been implemented.
This organization has
sufficient independence, authority and technical expertise to carry
out the program in an efficient and effective manner.
This is assured
by B&R QA Management reporting to Management levels above and indepen-
dent from pressures of production."
!
,
- Some of the listed examples occurred outside the October-January time period
for which a civil penalty is proposed.
Such examples support the findings that
similar occurrences were present during the period for which the civil penalty
is proposed.
Civil penalties are not being proposed for those examples.
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Appendix A
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APR 3 01980
Contrary to the above, the results of the investigation indicate
that the quality assurance / quality control functions in the civil
area are not sufficiently independent, the QA/QC civil personnel do
not have sufficient authority and the QA/QC civil personnel do not
have the freedom to identify problems and determine they are
adequately resolved.
The results of interviews indicate that some
civil quality control inspectors are: (a) subjected to production
pressures, (b) not always supported by the QC management, (c)
harassed, (d) intimidated, and (e) threatened.
Documented evidence obtained during the investigation indicated a
continuing trend on the part of civil quality control inspectors to
assume the position that it is easier (less pressure, harassment,
and threats) to just sign the quality control documents which are
necessary for construction to proceed, even though the procedural or
specification requirements may not have been fully met, than to be
confronted by quality control and/or construction management.
It is
noted, however, that during the investigation no items of major
safety significance were found which related to the above findings,
but the potential for future problems is great unless corrective
action is taken.
Examples supporting the above findings are as follows:
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a.
It was substantiated that during the final preparations for the
placement of concrete in Lift #5 of the Unit 2 reactor contain-
ment building shell wall .(placed 4/27/79) production pressure
was present and caused a QCE supervisor to override the advice
of his subordinates that the area of the construction joint was
dirty.
The corrective action selected, which was not totally
effective, was that requiring the least delay in the construc-
tion schedule.
That the action was not fully effective was evidenced by a
construction foreman who saw a can float to the surface of the
concrete during placement.
The QCE supervisor indicated that a
large number of construction personnel, including construction.
top site management were standing by to begin the placement and
that he signed off the necessary documents to get the placement
underway due to the critical time frame for ordering concrete
(Allegation 11A, p. 38).*
b.
A former QCE supervisor stated that whenever construction falls
behind in placing concrete, QC inspectors seem to always get
i
the blame.
The statement was made on the basis of his knowledge
of what upper management expressed in meetings and general
conversations.
He also indicated that construction always
- Page numbers refer to Report No. 50-498/79-19; 50-499/79-19.
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Appendix A
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APR 3 01980
indicates they are ready for a placement when they are not and
that QC had only 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete the inspection.
He noted
that construction scheduling pressure gradually reduced this
period (Individual A47, p. 3-26).
c.
A current QCE supervisor related that after QC had completed a
preplacement inspection, the pour card had been signed and the
concrete ordered, the QC personnel would find additional problems
such as alterations to the forms or debris dropped into the
forms.
This would occur from 3 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the sign off.
Construction personnel would try to pressure inspectors to
accept these conditions because of the time and money to
correct the situation.
He indicated that if construction
personnel were unsuccessful and the placement was delayed or
stopped, then it always seemed to be QC's fault.
He also
indicated that construction management has a major problem in
that they think of quality only as a necessary evil and that
there is much controversy over schedules and cost overruns
(Individual A35, p. 3-14).
d.
A QC inspector stated that in the summer of 1979 he had
discovered three horizontal reinforcing steel bars missing from
a wall section which was being readied for concrete placement.
On the previous day he had told construction personnel that he
thought the wall preplacement was correct.
He was verbally
abused by a person from construction (Individual A17, p. 2-12).
Fifteen of twenty-four QC civil inspectors interviewed executed
e.
signed sworn statements wherein they claimed that their super-
visors had not supported their positions during confrontations
with construction personnel.
An additional QA auditor and an
inspector on special assignment indicated the same concern.
Interviews with the construction personnel involved resulted in
signed sworn statements wherein they admitted ignoring and/or
bypassing the QC inspector's directive to stop by continuing
the work, and then going to the QC inspector's supervisor to
reverse the directive (Allegation 6). This lack of QC manage-
ment support is also evidenced by the findings resulting from
Allegations 3, 7A, 8A, and 9A (pages 18, 14, 32, 33 and 34).
f.
A QC inspector refused
, sign off on deficient Cadwelds and
initiated a nonconformanu: report (NCR) because Cadwelder
requalification was not performed as required by the specifica-
tion.
The construction supervisor admitted he had ignored the
!
QC inspector, the inspector's supervisor and the NCR and
't
ordered his men to continue Cadwelding.
This resulted from a
disagreement over interpretation of the specification
(Allegation 10A, p. 36).
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APR 3 01980
Appendix A
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g.
Five QC civil inspectors executed signed sworn statements
wherein they claimed that during a meeting a high level QA/QC
manager warned them not to talk to the NRC, indicating that
action would follow.
This was also confirmed by another QC
civil inspector (Allegation 1, p. 12).
h.
Another QC civil inspector executed a signed sworn statement
that a QC supervisor stated words to the effect that after the
NRC leaves we will have to get rid of some of the QC inspectors.
The QC supervisor acknowledged that he made such a statement in
mid-November of 1979 (Allegation 4A, p. 29).
i.
Another QC civil inspector involved in an incident where the
concrete foreman left the placement without informing the
inspector who was the acting foreman was later faced with
information that the concrete foreman had said his crew was
able to violate the specification without the inspector's
k;mwledge.
The inspector was informe that the foreman was
bragging about the incident (Allegation 8, p. 20).
,,
j.
A QCE supervisor indicated that a person in construction
attempted to harass the QA/QC program personnel by trying to
recove air conditioning from the assigned office spaces
(Individual A35, p. 3-14).
.
k.
A QC inspector admitted in a signed sworn statenent he falsely
i
signed concrete curing records at the request of a lead QC
person when he had not inspected the curing and in fact was not
1
on-site at the time the inspection was supposedly made.
The
lead QC person however, denied that such a request was made
(Allegation 1A, p. 26).
1.
A QC inspector admitted in a signed sworn statement he signed
off on a minor Cadweld deficiency (procedure violation) because
he felt his supervisors would not support him and would side
with construction (Individual A52).
In this instance the QC
inspector was intimidated by his past experience with his
supervisor and took an action to correspond with his supervisor
(p. 2-29).
m.
A QC inspector was physically threatened by a construction
general foreman.
The QC inspector, a witness and the construc-
tion general foreman all executed signed sworn statements
substantiating this event.
The construction general foreman
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indicated he lost his temper and intended no harm (Allegation
2A, p. 27).
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Appendix A
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APR 3 0 ESO
n.
A QC inspector was physically threatened by a construction
superintendent.
Both executed signed sworn statements substan-
tiating this event.
The construction superintendent indicated
he lost his temper and intended no harm (Allegation 3A, p. 28).
o.
A QC inspector was threatened by a construction general foreman.
The QC inspector, a witness and the construction general foreman
all executed signed sworn statements substantiating this event.
'
A QCE supervisor in an interview also substantiated the threat.
The construction general foreman explained that he lost his
temper and made no attempt to injure the QC inspector
(Allegation 2, p. 13).
p.
On January 4,1980 a lecture by the Brown and Root Project QA
Manager was given to the Brown and Root site QA/QC personnel
and construction engineering and supervisory personnel.
The
lecture repeatedly overemphasized the Brown and Root QA/QC
organization's responsibilities to minimize project cost and
maintain the construction schedule.
The lecture also strongly
emphasized the fact that a Brown and Root QC inspector's
decisions are subject to question, challenge and supervisory
review and reversal.
The lecture was recorded on video tape
which continues to be used as a mechanism to project the Brown
and Root policy.
In addition, the contents of the lecture were
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put into printed form and widely distributed to employees of
Brown and Root at the South Texas Project.
(Appendix 5).
2.
10 CFR 50, Appendix B, Criterion IX requires in part, " Measures shall
be established to assure that special processes... are controlled and
accomplished... using qualified procedures in accordance with...
specifications, criteria and other special requirements."
The STP PSAR in Section 17.1.9A states in part that " Houston Lighting
and Power Company (HL&P) requires written procedures and controls to
ensure special processes... are accomplished... using qualified
procedures in accordance with applicable... specifications, criteria,
and other special requirements.
These procedures shall describe the
operations to be performed, sequence of operations, characteristics
involved... examinations, tests and inspections shall be conducted to
verify conformance to specified requirements...
Compliance to these
requirements is mandatory for prime contractors."
From information provided to the inspector it was determined that a
" test fill program" resulted in the determination that for placement
of an 18 inch maximum lift thickness of soil it would be necessary to
make 12 passes with the compaction equipment.
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APR 3 0 530
Appendix A
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Contrary to the above, Brown and Root construction procedure, STP-QCP
A040KPCCP-2, Rev.
2, required only 8 passes with the compaction
equipment for the placeu rt of a maximum lift thickness of 18 inches
of soil.
Thus the construction procedure did not reflect the necessary
number of passes of compaction equipment wnich had been established
in a qualification test procedure (p.61).
j
3.
10 CFR 50, Appendix B, Criterion XVI requires in part, " Measures shall
be established to assure that conditions adverse to quality, such
as... defective... equipment... are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures
shall assure that... corrective action taken to preclude repetition."
The STP-PSAR in Section 17.1.16A states in part, " Houston Lighting
and Power Company (HL&P) will require measures be established to
assure conditions adverse to quality will be promptly... corrected...
)
In the case of significant conditions adverse to quality, measures
shall be taken to ensure the cause of the condition is determined
and corrective action is implemented to preclude repetition."
The FSAP, in Section 2.5.4.5.6.2.4 and Brown and Root Specification
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No. 3YO69YS029, Rev.
F, pragraph 9.e, and Brown and Root Procedure
No. A040KPCCP-2, paragraph 3.3.3.5 require that at least one relative
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density test be performed for every fourth field sand cone density
test.
Contrary to the above, a review of Pittsburgh Testing Laboratory data
on December 18, 1979, indicated that a relative density test had not
been performed since November 17, 1979 as a result of equipment
failure.
Plant backfill continued to be placed and several sets of
four field sand cone density tests were co.npleted without the
companion relative density tests being performed (p.64).
4.
10 CFR 50, Appendix B, Criterion V requires in part, " Activities
affecting quality shall be prescribed by documented instructions,
procedures... appropriate to the circumstances.
The STP PSAR in Section 17.1.5A states in part, " Appropriate require-
cents have been established in the Houston Lighting and Power Company
(HL&P) Quality Assurance (QA) Program to ensure quality related
activities for the South Texas Project (STP) are prescribed by
documented instructions, procedures... the responsibility for develop-
cent of these methods, procedures and instructions is delegated to
the organization performing the activities...
The HL&P QA Department
has the responsibility for Onsuring that methods, procedures and
instructors (sic) are developed and implemented for all activities
relating to the STP."
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APR 3 01980
Appendix A
_7_
Contrary to the above, Pittsburgh Testing Laboratory QA Procedure
No. IS-511-D1556-64 indicates that the in place density measurements
are to be performed according to EAASTM D-1556, however there are no
requirecents in the procedure which define the location or depth of
the samples.
A review of the records by the inspector revealed that
the samples were taken at various depths in a given lift with no
specific correlations of results available (p.
61).
5.
10 CFR 50, Appendix B, Criterion XVII requires in part, that
" Sufficient records shall be maintained to furnish evidence of
activities affecting quality."
The STP PSAR in Section 17.1.17A states, in part that, "The STP QA
Plan specifies:
1)
The records are required to be maintained to show evidence of
performance of activities affecting quality.
Typical records
to be maintained include: . . . inspection and test reports. .
Paragraph 1.3.3.1 of B&R's Quality Construction Procedure CCP-2
states, "All inspection and laboratory testing will be conducted to
assure compliance with all specifications . . . and the requirements
of this Quality Construction procedure . . . The inspectors will
document their findings . . ."
Contrary to the above, neither the applicable B&R procedure nor the
test record form SF-6 required that the lift thickness and number of
passes of the compaction equipment be documented.
These data are needed to assure that the backfill material is being
systematically placed and compacted to obtain the required densities
(p. 65).
t
6.
10 CFR Part 50, Appendix B, Criterion XVI states in part, " Measures
shall be established to assure that conditions adverse to quality,
such as failures, . . . deficiencies, deviations, . . . and noncon-
formances are properly identified and corrected.
In the case of
significant conditions adverse to quality, the measures shall assure
that the cause of the condition is determined and corrective action
taken to preclude repetition."
The STP PSAR in Section 17.1.16A states in part, "The identification
of a discrepancy or nonconformance requires certain steps to be
taken to ensi o proper closure of the item.
The specific steps to
be followed are as follows:
1 . .
5.
Verification (followup) by
original identifier of discrepancy or noncomformance to ensure its
implementation and action to preclude repetition or recurrence."
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APR 3 01980
App:ndix A
-8-
Contrary to the above, no effective program has been implemented on
a continuing basis to review and analyze Nonconformance Reports,
Examination Checks / Inspection Books or Field Requests for Engineering
Action for repetitive occurrences to ensure that root causes are
identified and corrective action is taken to preclude repetition.
Further, no formal, approved procedures to implement such a program
had been developed as of November 28, 1979 (p. 94).
7.
10 CFR 50, Appendix B, Criterion XVI as implemented by South Texas
Project PSAR Section 17.1.16, states in part, " Measures shall be
established to assure that conditions adverse to quality, such as
failures, malfunctions, deficiencies, deviations, . . . are promptly
identified and corrected.
In the case of significant conditions
adverse to quality, the measures shall assure that the cause of the
condition is determined and corrective action taken to preclude
repetition . . ."
An HL&P letter to the NPO, ST-HL-AE-374 dated August 31, 1979,
pertaining to lifting t':e HL&P Stop-Work-Order for placement of
containment shell concr ate specified that the following measures had
been implemented for all concrete placement:
1)
"Very detailed preplacement planning is carefully performed to
identify potential consolidation problems . . ."
2)
" Increased attention is given to logistics to provide for
backup equipment,. access for inspection, lighting and manpower
assignments . . ."
3)
"Special additional training for Construction and Quality
Control personnel is given to cover procedures for placement,
vibration . . ."
Contrary to the above, work observed, statements by site personnel,
quality assurance records and site internal surveillance reports
show that the corrective actions outlined in HL&P letter ST-HL-AE-374
have not been effective to preclude repetition.
Examples of this
ineffectiveness are as follows (pages 53 and 54):
1)
Concrete placement personnel were using improper consolidation
practices and lighting as observed by an NRC inspector was
inadequate for placement CIl-W818 made on November 20, 1979.
2)
Concrete placement personnel were using improper consolidation
practices on placement DG1-M1 made on December 7,1979.
Further-
more, an insufficient number of preplacement inspectors were
assigned to conduct the final inspection.
Construction work in the placement area was being performed
during the night prior to the placement and during the morning
of the placement.
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APR 3 01983
Appondix A
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This "last minute" construction activity, at least in
part, delayed the start of the placement from the scheduled
7:00 a.m. until approximately 11:00 a.m.
This scheduling
resulted in undue pressure on the QC inspectors to quickly
accept the placement conditions.
No specific placement method
(sequence) was specified in the placement plan or discussed in
the preplacement meeting.
In addition, the report of the post
placement interview did not address the problems with last
minute construction work or the loose reinforcing steel that
delayed the start of the placement and was again identified
after placement had begun.
3)
Interviews with QC inspectors and notations on Inspection
Books, Examination Checks, post placement interview reports and
Site Internal Surveillance SIS-26 for placements MEl-S047,
CS2-W7, ME2-WO12-06, CIl-W81B and ME2-W001-04 indicate that
poor consolidation practices and excessive lift thickness
continue to be problems.
8.
10 CFR 50, Appendix B, Criterion V states in part, " Activities
affecting quality shall be prescribed by documented instructions,
procedures or drawings... and shall be accomplished in accordance
with these instructions, procedures or drawings."
10 CFR 50, Appendix B, Criterion V as implemented by the STP PSAR
Section 17.1.5, states in part, "... quality related activities for
the South Texas Project (STP) are prescribed by documented instruc-
tions, procedures or drawings; accomplished in accordance with such
documents;..."
Brown & Root (B&R) Quality Assurance Personnel Training Manual Part
>
1, Supplement E, Section 5 specifies the required educational /
experience levels for Level I and II civil inspectors.
For example,
a Level 11 inspector with a degree from an accredited engineering or
science ecliege or university must have one year's experience in
quality assurance, including testing or inspection, or both.
Pittsburgh Testing Laboratory (PTL) Quality Control Procedure No.
QC-PQ-2, Appendices II and III specify the required educational /
experience levels for Level I, II and III PTL inspectors.
These
appendices identify the qualification requirements detailed in
ANSI-N45.2.6 and ASME Section III, Division 2 respectively.
Contrary to the above, of 14 Brown & Root civil QC inspectors and
i
six PTL concrete inspectors, for which qualification records were
exacined, five B&R and three PTL inspectors did not have the
required applicable QA/QC experience at the time of their certifica-
tion (p. 58).
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App:ndix A
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9.
10 CFR 50, Appendix B, Criterion VI, states in part, " Measures shall
be established to control the issuance of documents, such as instruc-
tions, procedures, and drawings, including changes thereto, which
prescribe all activities affecting quality . . ."
The STP PSAR, in Section 17.1, states in part, " Brown and Root
provides written procedures for controlling the preparation, review,
approval, and issuance of specifications, drawings, procurement
documents, procedures, instructions, and changes thereto, which
delineate activities affecting quality."
Section 6, of the Contractors Quality Assurance Manual, states in
part, " Documents used for the design, procurement, and construction
of code and safety related items shall be distributed and controlled
in accordance with approved Project Procedures. . ."
Contrary to the above, the licensee's controlled copies (Nos.
04
and 05) of the Contractors Quality Assurance Manual on January 8,
j
1980 did not contain the latest issue of interim changes.
Addi-
'
tionally, the licensee's controlled copy of the Contractors Weld
Filler Material Specification, IUO20W5001-E, did not contain the
latest document change notices (DCNs) (DCN/11/16/77 and DCN/3/28/78),
(p. 69).
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10.
10 CFR 50, Appendix B, Criterion IX, states in part, " Measures shall
be establishea to assure that special processes, including welding .
. . , are controlled and accomplished by qualified personnel using
qualified procedures in accordance with applicable codes, standards,
specifications. . ."
Section 17 of the licensee's PSAR, titled " Control of Special
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Processes," states in part, ". . . written procedures and controls
be prepared to ensure special processes, including welding, . . .
are accomplished in accordance with applicable codes, standards,
specifications, . . ."
ASME, B&PV Code 1974 through Winter 1975 Addenda,Section III,
paragraph ND-4412, " Cleanliness and Protection of Welding Surfaces,"
states in part, ". . . the work shall be protected from deleterious
contamination and from rain, snow and wind during welding . . ."
Contrary to the above, the inspector observed on at least three
occasions safety-related pipe welding activities being performed
without adequate protection from the atmospheric conditions described
above.
Subsequent examination of these welds showed that they had
'
unacceptable defects.
For example, the radiograph for field weld
0005 in line AF2004, made without adequate protection from the wind,
which would cause loss of cover gas, showed high levels of oxidation
(p. 72).
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APR 3 01980
11.
10 CFR Part 50, Appendix B, Criterion IX, states in part, "Heasures
shall be established to assure that special processes, including . .
. noadestructive testing; are controlled and accomplished . . . in
accordance with applicable codes, standards, specifications, criteria,
and other special requirements."
Section 17 of the licensee's PSAR titled " Control of Special
Processes" stc'.es in part, ". . . written procedures and controls be
prepared to assure special processes, including . . . nondestructive
'
testing . . . are accomplished . . . in accordance with applicable
codes, standards and specifications . . ."
a.
Paragraph T-233.2 of Section V of the ASME B&PV Code 1974
through Winter 1975 Addenda requires that all radiographs be
free from mechanical, chemical, or other blemishes to the
extent that they cannot mask or be confused with the image.of
any discontinuity, including; fogging, processing defects such
i
as streaks, water marks, or chemical stains.
Contrary to the above, the inspector reviewed at least 50 final
l
radiographs of production (field) welds and of welder qualifica-
tion tests which displayed significant light fogging and chemical
contamination to such an extent that proper interpretation of
,
the radiograph was not possible in whole or in part (p. 79).
'
i
b.
Paragraph T-290 of Section V of the ASME B&PV Code 1974 through
Winter 1975 Addenda states in part, " . . . radiographs shall
be examined and interpreted . . . record on a review form
,
accompanying the radiographs the interpretation of each radio-
graph and disposition of the material examined . . ."
Contrary to the above, the inspector observed at least 12
radiographs of field welds and one radiograph for a welder
performance qualification test weld which contained linear
indications that had not been recorded on the accompanying
interpretation sheet (p. 82).
ASME B&PV Code, 1974 through Winter 1975 Addenda Section III,
c.
Paragraph ND-5351, " Evaluation of Indications" specifies that
any indication which is believed to be nonrelevant shall be
regarded as a defect and shall be reexamined to verify whether
or not actual defects are present.
Surface conditioning may
precede the reexamination,
i
\\l
The contractors Liquid Penetrant Examination procedure,
o
ST-NDEP-4.1, reiterates the above requirements.
]
Contrary to the above, the inspector observed the performance
of a liquid penetrant examination for field weld number 0017 in
_
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_ _ _
.
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App 2ndix A
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APR 3 01980
the essential cooling water system for which the results were
not evaluated according to these requirements (p. 76).
12.
10 CFR 50, Appendix B, Crite ion V requires in part, " Activities
affecting quality shall be prescribed by documented instructions . . .
and shall be accomplished in accordance with these instructions,..."
The STP PSAR in Section 17.1.5B states in part, " Engineering,
construction, inspection, testing, and planning techniques are used
to assure that activities affecting quality are set forth by written
B&R instructions, procedures and drawings, and are accomplished in
accordance with these instructions, procedures and drawings."
Contrary to the above, on December 10, 1979, the inspector
determined that an interim change ST-NDEP to ST-NDEP-4.1, " Liquid
Penetrant Examination," was issued on August 30, 1979 and was
inserted in the procedure and the applicable page of the procedure
was removed.
The interim procedure is valid for 60 days.
The
in.spector observed that the invalid or cancelled insert was being
used by B&R NDE personnel during January 1980.
A similar example
was observed relative to inserts for ST-NDEP-2.1, dated March 13,
1979.
This appears to be a generic problem (p. 77).
13.
-
10 CFR 50, Appendix B, Criterion XVI states in part, " Measures shall
be established to assure that conditions adverse to quality such as
. . . deficiencies, deviations, . . . and nonconformances are
promptly identified and corrected."
The STP FSAR states in Amendment 7 dated July 16, 1979 in Chapter 3,
paragraph 3.8.1.6.3, " . . .:
a.
Subparagraph CC-4333.3, Initial Qualification Tests, serves as
an alternate to Section C.1 of Regulatory Guide 1.10, except
that a splicer will be requalified if in any 15 consecutive
Cadwelds there are two unacceptable (either visual or tensile)
Cadwelds made.
The splicer will be requalified in the position
or positions in which the failure (s) occurred."
B&R Specification No. 2A010CS028-G " Concrete Construction"
(applicable at the time in question) states in paragraph 5.3.3.6,
"When a splicer accumulates two unacceptable tests, either visual or
tensile, within a unit of 15 consecutive test samples and the rejec-
tions are not due to material deficiencies, he shall not be
permitted to continue splicing until he has requalified according to
(;
paragraph 5.3.3.5."
.
,
Contrary to the above, five Cadwelders who had accumulated two
visually unacceptable production splices within a unit of fifteen
(15) consecutive splices were permitted to continue making produc-
tion splices without requalifying (p. 37).
l
i
.
.
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APR 3 01380
Appendix A
13 _
14.
10 CFR 50, Appendix B, Criterion XVI states in part, " Measures shall
be established to assure that conditions adverse to quality, such as
failures . . . deviations . . .
and nonconformances are promptly
identified and corrected.
. . . the cause of the condition, and the
corrective action taken shall be documented and reported to
appropriate levels of management."
The STP PSAR in Section 17.1.16b states in part, "Should conditions
exist that after a reasonable time for resolution, a deficiency or
nonconformance is not corrected, the 0A Manaoer is required to report
the incident to the Power Division Senior Group Vice-President any
time agreement on corrective actions to be implemented cannot be
attained, the findings may be brought directly to the Power Division
Senior Group Vice-President for resolution."
Contrary to the above, there was no objective evidence that the
Division Senior Group Vice-President was advised of the failure to
take action on repetitive deficiencies documented in B&R site
surveillances SIS-12 and 12.1 through 12.5, nor the failure to get
responses and/or corrective action on SIS-18 and the B&R letter 5153
dated November 12, 1979 (p. 106).
15.
10 CFR 50, Appendix B, Criterion V states in part, " Activities
affecting quality shall be prescribed by documented instructions,
procedures or drawings... and shall be accomplished in accordance
with these instructions, procedures or drawings."
10 CFR 50, Appendix B, Criterion V, as implemented by South Texas
Project PSAR Section 17.1.5 states in part, "The HL&P QA Department
has the responsibility for ensuring that methods, procedures and
instructions are developed and implemented for all activities
relating to STP."
HL&P Project Quality Procedures PSQC PC, Revision 1, and PSQP-A3,
Revision 9, state in part, "All checklists shall be completed in
full, signed and dated by the QA personnel involved, and filed in
the site QA office.
Should any items on the checklist not be
applicable to the operation, that item shall be marked, NA.
Items
found to be satisfactory will be marked S.
Items not audited shall
be carked N.
Any discrepant items or deviations from specifications
shall be marked "U" and discussed in the " Remarks" section.
The OA surveillance oersonnel shall document all nonconformances and
ceficiencies accordino to PSOP-3.
(
Notification of Brown & Root Site QA:
Whenever a discrepant item or
'
condition for which B&R or a B&R subcontractor is responsible is
identified by HL&P QA, Brown & Root site QA shall be notified
immediately.
The notification may be by one of the previously
mentioned HL&P Discrepancy Notification Documents or orally.
If
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_
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_
_
,
5
l
App 2ndix A
- 14 -
1
immediate and acceptable action and recurrence control (as
applicable) are implemented by B&R pursuant to oral notification the
item may be closed out on the checklist itself if a checklist was
used.
Reference should be made on the checklist as to the correc-
tive action."
Contrary to the above, civil surveillances C.2.1 through C.2.5 were
not properly documented as required by the written procedures.
That
is, unsatisfactory conditions and corrective action were not always
documented during the period of 1978 and 1979 (p. 103).
16.
10 CFR 50, Appendix B, Criterion XV requires in part, " Measures
shall be established to control materials, parts, or components
which do not conform to requirements in order to prevent their
inadvertent use . . ."
The STP PSAR in Section 17.1.15B requires suppliers to establish and
implement procedures for controlling items or processes that do not
j
conform to requirements of the applicable codes or standards.
l
ASTM D-1586-67, identified by Houston Light and Power Company as the
applicable standard for site soil penetration tests, states in
paragraph 2.3, "The assembly shall consist of a 140 lb. weight."
Contrary to the above, site soil penetration testing activities were
allowed to continue during the period January 28, 1980 to February
4,1980 using a weight (" hammer") which had been identified as
nonconforming to the requirements of ASTM D-1586-67 (p. 67).
17.
10 CFR 50, Appendix B, Criterion XI, requires in part, " Test
procedures shall include provisions for assuring that all prerequi-
sites for the given test have been met, that adequate test instru-
mentation is available and used. . ."
The STP PSAR Section 17.0, paragraphs 17.1.11A and 17.1.11B states
in part, " Houston Lighting and Power Company (HL&P) Quality Assurance
(QA) Program requires prime contractors, subcontractors . . . designate
appropriate tests to be performed at specific stages of . . . construc-
tion.
Conduct of tests will be governed by written procedures which
will incorporate requirements and acceptance limits . . . Tests will
be conducted in accordance with these procedures . . .
"The prime contractors Brown & Root, Incorporated (B&R) . . . shall
,
ensure all necessary tests are required and conducted.
Such testing
ll
will be performed in accordance with quality assurance and engineering
"l
test procedures which incorporate . . . the test requirements . . .
Test requirements . . . are provided by the organization responsible
for the design of the item under test . . .
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0 1930
Appendix A
- 15 -
"B&R engineering will establish the required test program . . . in
appropriate specifications.
The suppliers and B&R Construction are
required to establish detailed procedures for the tests . . .
The
test procedures shall include provisions for assurance that the
prerequisite for the test have been met, that adequate instrumenta-
tion is available and will be used . . ."
A Woodward-Lundgren document, dated August 1, 1975 entitled Appendix
B-1 Revision 2, presented to the NRC on February 5,1980 as the
'
applicable QA procedure, states that split-spoon samples should be
taken according to ASTM D-1586-67.
Paragraph 2.2 of ASTM D-1586 states, "The sampler shall be constructed
with dimensions indicated on Figure 1.
The drive shoe . . . shall
i
be replaced . . . when it becomes dented or distorted." Figure 1
'shows a 1.375 inch inside diameter of the split-spoon sampler cutting
edge and a 0.75 inch taper.
Contrary to the above, the split-spoon used in the backfill test
pr'ogram during the period January 28, 1980 to February 5, 1980, did
,
not conform to the requirements of ASTM D-1586-67 in that the inside
diameter of the cutting edge was measured to be 1.5 inches and the
driven end of the split-spoon was badly distorted and had a 0.50
inch taper.
Thus the test procedure which defined the proper
'
dimensions on the equipment was not followed (p. 67).
18.
10 CFR 50, Appendix B, Criterion XVIII states in part, "A
comprehensive system of planned and periodic audits shall M carried
out to verify compliance with all aspects of the quality assurance
program and to determine the effective use of the program."
The STP PSAR Section 17.0, paragraph 17.1.18A states in part,
" Houston Light and Power Company (HL&P) requires . . . periodic
audits be performed to verify compliance with all aspects of the
program.
. . . to verify by evaluation of objective evidence . . .
program has been properly implemented; to assess the effectiveness
of the QA program; to identify . . . and to verify correction of
identified nonconformances.. .
Applicable elements of the QA Program
shall be audited at least annually . . . with the following addi-
.
tional criteria to be used for modifying the audit frequency:
'
4.
When it is suspected the safety, performance or reliability of
an item is in jeopardy due to deficiencies and nonconformances
with respect to the organization's QA Program;
(
5.
When it is considered necessary to verify implementation of
required corrective actions..."
.
30 M
Appendix A
- 16 -
The STP PSAR Section 17.0, paragraph 17.1.18B states in part,
" Brown and Root, Incorporated (B&R) has established an audit
system . . . for internal . . . audits.
Internal audits are
audits of activities of the B&R organization...
B&R performs
audits of all activities affecting quality, including but not
limited to the following:
8.
The evaluation of work areas, activities, processes, and items
(hardware)
9.
The review of documents and records
10.
An objective evaluation of
a.
Quality related practices, procedures and instruction
b.
The effectiveness of implementation..."
The B&R QA Procedure ST-QAP 7.1 reiterates the above requirements.
a.
Contrary to the above, neither the HL&P QA plan Section 8.0 nor
procedure QAP-5 " Audits" include provisions to implement the
above requirements concerning performance of supplemental
audits.
Furthemore, neither HL&P nor B&R (Houston) performed
supplemental audits to determine if suspected safety
performance or reliability of an item was in jeopardy, even
though: (1) continuing allegations were received during the
period from mid-1977 through 1979 relative to civil construc-
tion and inspection activities, and (2) significant voids were
identified in the Unit No.1 containment shell in early 1978
(followed just recently by the discovery of apparently similar
type voids in the Unit No. 2 containment vessel shell) (pages 95,
100 and 101).
b.
HL&P QA Procedure, QAP-5B in paragraph 6.2 states in part,
" Objective evidence shall be examined for compliance with
Quality Assurance requirements.
This includes review of Quality
Assurance / Quality Control procedures and documentation which
implements the Quality Assurance Program Requirements.
Selected
elements of the quality assurance effort shall be audited to
the depth necessary to determine whether or not it is being
implemented effectively."
i
Contrary to the above procedure and the previously referenced
PSAR and Appendix B, Criterion XVIII requirements, HL&P (Houston)
failed to audit the HL&P (site) QA function to the depth necessary.
_ _ _ _ _ _ _
.
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-.
APR 3 0 Ec0
.
.
Appendix A
- 17 -
1
Houston audits of site QA functions were essentially a review
of records and did not identify the fact that HL&P site procedures
PSQCP-C and PSQP-A3 were not being effectively implemented in
that nonconformances and deviations were not being identified
in the civil surveillance reports (pages 99 and 104).
c.
HL&P South Texas QA Plan Section 8.0, paragraph 8.2 states in
part, "HL&P has the responsibility for the overall auditing of
quality activities for the South Texas Project.
The frequency
of audits performed by HL&P . . . are generally as follows:
Brown & Root site construction - annually;
Brown & Root site
QA/QC
semiannually."
Contrary to the above procedure and previously referenced PSAR
and Appendix B, Criterion XVIII requirements, HL&P (Houston)
did not audit the implementation / execution of B&R site construc-
tion procedures for the years 1977, 1978 and 1979, nor the site
QA/QC procedures ST-QAP-2.7, 3.1, 3.2, 4.3, 5.3, 5.4, 5.5 and
6.1 during the years 1978 and 1979 (p.100).
19.
10 CFR 50, Appendix B, Criterion XVIII states in part, "A
comprehensive systeo of planned and periodic audits shall be carried
out to verify comoliance with all aspects of thc quality assurance
program and to determine the effectiveness of the program."
The STP PSAR Section 17.0, paragraph 17.1.188 states in part, " Brown
& Root, Incorporated (B&R) has established an audit system . . . for
internal . . . audits.
Internal audits are audits of activities of
the B&R organization. ..
B&R performs audits of all activities affec-
ting quality, including . . .
The evaluation of work areas, activi-
ties, processes, and items (hardware) . . .
An objective evaluation
of quality related practices, procedures and instruction.
The
effectiveness of implementation."
B&R QA Procedure ST-QAP 7.1 reiterates the above requirements.
Contrary to the above, B&R (Houston) audits of B&R site QA/QC and
construction activities were essentially only reviews of records and
did not determine to the depth necessary, whether the site quality
procedures were being effectively implemented.
Further, no audits
were conducted of site design control in 1978, although design lead
time over construction was and continues to be very short and
numerous Field Requests for Engineering Action and other design
change documents were being processed (p. 100).
(.
20.
10 CFR 50, Appendix B, Criterion X, requires in part, " Houston Lighting
-
and Power Company (HL&P) will establish with each of its prime
contractors... the primary inspection responsibility.
HL&P, however,
retains the responsibility for review, evaluation and surveillance
_--_
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
APR 3 01980
.
.
Appendix A
- 18 -
of the inspection procedures utilized by these organizations...
HL&P requires by contract that the principal contractors... meet
the requirements of 10 CFR 50, Appendix 8... HL&P and/or its
representative shall verify... the inspections are being performed
and documented by personnel in conformance with approved procedures..."
The STP PSAR Section 17.1.10 states in part, "A program for
inspection of activities affecting quality shall be established and
executed . . . to verify conformance with the documented instruc-
tions, procedures, and drawings for accomplishing the activity."
Paragraph 3.22.2 of Brown & Root Procedure CCP-3 requires in part
that the QC Civil Inspector ensure compliance with applicable B&R
drawings by verifying that reinforcing steel is supported and tied
to prevent displacement.
Contrary to the above, on December 7,1979, although completed QC
documentation indicated that the reinforcing steel for placement
DG1-M1 was properly installed, a sample inspection of ten vertical
tie bars, made when the placement was about 1/3 completed, identified
that three of the ten were unwired (p. 53).
21.
10 CFR 50, Appendix B, Criterion III requires in part, "the design
basis . . . for those structures, systems and components . . . are
correctly translated into specificai. ions, drawings, procedures, and
instructions.
These measures shall include provisions to assure that
appropriate quality standards are specified and included in design
documents and that deviations from such standards are ccatrolled."
The STP PSAR Section 17.1 states in part, "The HL&P QA Program
imposes the following design control requirements on its own activi-
ties as well as those of its principal subcontractors: . . . (3)
appropriate quality standards are specified and included in the
design documents, and deviations and changes from such standards are
controlled. . . (8) Design and specification changes are subject to
the same design controls which were applicable to original design."
Brown & Root QA Manual, Section 3, " Design Control Procedure"
reiterates the above requirements.
Contrary to the above, Brown and Root correspondence BC-22539
authorized design changes to welding requirements contained in
Welding Procedures MCEP-3 and MCEP-4 and Welding Specification
A010P002 without proper review and approval.
Furthermore, field
i'
welding personnel and welding inspectors tere using this letter and
the attached diagram as guidance for we hing and inspecting (p. 74).
,
1
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_
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APR 3 0 lego
Appendix A
g_
_
Each day of failure to meet the requirements of 10 CFR 50, Appendix B, con-
stitutes a separate infraction and a penalty of $3,000 is proposed for each
(cumulative civil penalties - October 1979 through January 1980 -
123 days x $3,000 = $369,000).
B.
10 CFR 50.55a(3), states in part, " . . . piping which is part of the
reactor coolant pressure boundary shall meet the requirements for Class 1
components set forth in Section III of the ASME Code . . ."
ASME Section III, NB-4321 (a) states in part, " . . . shall establish the
procedure and conduct the tests required by this article and by Section
IX in order to qualify both the welding procedures and the performance of
welders and welding operators . . ."
ASME Section IX, QW-191, states in part, " . . . the radiographic
examination . . . shall meet the technique requirements of Article 2,
Section V, . . ."
Paragraph T-263, Article 2 of Section V of the ASME Code, requ%s that a
source side penetrameter be used where accessibility permits hand place-
ment of penetrameter on the source side of the item being radiographed.
Contrary to the above, the inspector observed specimens completed by the
welders and welding operators as well as the radiographs of the weld
specimens which were made for qualification to weld on Class 1 components
with easy accessability, containing only film side penetrameters (p. 70).
On January 14, 1980, the inspector observed a weld being made on a Class 1
system, the cain reactor coolant piping, by an improperly qualified welder.
This is an infraction.
(Civil Penalty $3000)
Although the total civil penalties amount to $372,000, pursuant to Section 234
of the Atomic Energy Act of 1954, as amended, (42 USC 2282), the total civil
penalties for any thirty-day period cannot exceed $25,000.
Consequently, civil
penalties in the amount of $100,000 are proposed for the above.
This Notice of Violation is sent to Houston Lighting and Power Company pursuant
to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations.
Houston Lighting and Power Company is
hereby required to submit to this office within twenty five (25) days of the
receipt of this notice, a written statement of explanation in reply including
for each item of noncompliance, (1) admission or dental of the alleged item of
noncompliance; (2) the reasons for the item of noncompliance if admitted; (3) the
corrective steps which have been taken and the results achieved; (4) corrective
(
steps which will be taken to avoid further items of noncompliance; and (5) the
~
date when full compliance will be achieved.
'