ML19327A227
| ML19327A227 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/28/1980 |
| From: | Oprea G HOUSTON LIGHTING & POWER CO. |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19327A228 | List: |
| References | |
| NUDOCS 8008040081 | |
| Download: ML19327A227 (250) | |
Text
-
E Ln)
- 4
[ W" "* 1},
2 r
[ JUL 311980 >
n UNITED STATES OF AMERICA Cu N NUCLEAR REGULATORY COMMISSION In The Matter of S
{ HOUSTON LIGHTING & POWER S
S Docket Nos. 50-498 COMPANY (South Texas S 50-499 Project, Units 1 & 2) S LICENSEE'S RESPONSE TO ORDER TO SHOW CAUSE E
E E
E E
July 28, 1980 E
[
8008040 Uk t
o,
[ 0
. Dock m o
[ '
- RJSNHC 4
UNITED STATES OF AMERICA JUL 31 1980 > -:
Of5cs of the Seaetsy ff b NUCLEAR REGULATORY COMMISSION nch
/
In the Matter of 5 5 Docket Nos. 50-498 HOUSTON LIGHTING & POWER $ 50-499 COMPANY (South Texas Project, S Units 1 & 2)
~
[ LICENSEE'S RESPONSE TO ORDER TO SHOW CAUSE Houston Lightirg & Power Company (HL&P) files this Response to the Order to Show Cause dated April 30, 1980 (the Order), by the Director of the Office of Inspection and Enforcement (I&E) in the subject dockets. The Order is an outgrowth of an intensive inspection conducted by I&E in the period November 10, 1979, to February 7, 1980, and documented
[ in I&E Investigation Report 50-498/79-19; 50-499/79-19 (the NRC Investigation Report).
The Order requires that "the licensee . . . shall show cause . . why safety-related construction activities
[
on the South Texas Project . . . should not be stopped
{ ninety (90) days from the date of this Order and remain stopped until such time as the licensee" submits information F-L on ten (10) separate matters identified therein. The requested c information, as set forth in this Response and in Attachment 1 e
P L
s
hereto, provides the basis for permitting continued construc-tion of the South Texas Project (STP).y a Since early 1980, HL&P and its constructor, Brown & ,
E l Root, Incorporated (B&R) have undertaken a comprehensive, introspective examination of their organizations with a view l to enhancing their capability to assure that the STP is j i
designed and constructed in conformance with all applicable i standards and commitments. Both have undertaken major changes in their organization, personnel and procedures to meet this objective, as described below.
-HOUSTON LIGHTING & POWER COMPANY-HL&P management has taken steps to assure that work at the Project satisfies all requirements:
. Organization: To provide increased authority and responsibility to the HL&P Quality Assurance (QA) program, significant changes have been made in reporting relationships. Three layers of off-site supervision have been removed from between the former site QA supervisory function and the HL&P Executive Vice President.
The current structure is one in which the HL&P Executive I
- 1. The ten (10) separate items on which the licensee is required to submit information are set forth in Section V,
>I part A of the Order. References to Item (1), etc. are to the items of said Section V, part A of the Order.
1 I
I
[
Vice President has been assigned responsibility for the
[ STP, virtually on a full-time basis. Reporting directly to him is the QA Department Manager, who has assumed the full-time responsibilities of Project QA Manager
[ and has been relocated to the site and assigned full responsibility for the STP QA program, including author-ity for QA programmatic direction of B&R. He will be
- assisted and advised on a full-time basis by a seasoned outside consultant with eighteen years of QA management experience until such time as the new program is well
{
established and effectively implemented. The HL&P
( Project QA organization for STP has been restructured to include a quality engineering function with separate l Project QA Supervisors in each of the major disciplines to provide programmatic direction to B&R quality en-
[ gineering and quality control.
{ . Staffing: Since January, 1980, the HL&P site QA staff has been augmented by six QA specialists with an
( average of ten years of QA experience, four years of which is nuclear experience.
[ . Training: Retraining of key HL&P personnel in the Project Management and Quality Assurance organiza-tions on basic principles of QA has been underway; 136
{ persons have attended QA indoctrination training since
. January 1, 1980.
[
( i
Response to NRC Inspection Report: Implementation
[
of commitments specified in the HL&P Response of May 23, 1980, to the I&E April 30, 1980 Notice of Violation represents a significant development for the QA program.
Among many important improvements noted therein and accomplished to date is an upgrading of the system of audits to verify adherence to procedures.
-BROWN & ROOT-
[
B&R management has taken steps to assure that work at the Project satisfies all requirements:
{
. Attitude Improvement: B&$ management has given
( the highest priority to communicating to Project personnel B&R management's renewed commitment to quality. This includes an insistence, at all levels, that all con-struction and quality control procedures be strictly adhered to, exactly as written. The independence of
{ the Quality Assurance / Quality control (QA/QC) organ-ization from considerations of cost and schedule is
( now, and will continue to be, emphasized. Quality Control (QC) Inspectors have been reassured that they will be supported by their supervisors and all levels of B&R management. B&R considers the infusion of this management attitude into all levels of the QA/QC program
( to be of utmost importance and absolutely critical to the successful implementation of the refined QA/QC I 1
[
( [ .
program described throughout this Response to the
{
Order. The process has begun, through management and
[ supervisor meetings, seminars and training of QA/QC personnel.
. Revision of Procedures: Construction procedures are being rewritten in a format which makes them easier to implement. This will help to eliminate confusion
{ that might be created between the construction foreman and.the QC Inspector. To date, concrete construction h procedures and certain welding procedures have been revised and issued. A program for reviewing remaining construction procedures is in progress.
. Personnel Changes and Additions: The Project QA Manager has been replaced with a consultant who has had
{ 20 years of QA experience including seven years as QA manager at nuclear projects. The Project's Deputy General Manager was relocated to the site and now serves as Site Manager. This po'sition gives him not only responsibility for construction, but also for P
coordination with QA and QC activities at the Project L
site. Three additional engineers have been assigned to l r
L oversee the site concrete activities. This step was taken to provide greater assurance that all aspects of i~
L the desim are being met by Construction. Two additional y soils ens.. seers were assigned to oversee the Soils u
~
L
[-
Testing Program for assuring compliance with engineering requirements. These ar.d other changes described in the
[ response to Item (1) of the Order upgrade the qualifi-cations of the Project staff.
. Welding Supervision: A Staff position of Manager, STP Welding Program was created and staffed with a highly qualified, experienced individual in nuclear welding engineering. He reports directly to the Project General Manager. His sole responsibility is to provide
[ management oversight of the STP welding program, including the adequacy of welding program procedures, training, qualifications, monitoring of welder performance, and coordination of t.he material engineering laboratories, design engineering and field welding engineering.
{ . Training and Indoctrination: At construction seminars and meetings, repeated emphasis has been
[ placed on complying with procedures. Construction supervision, as well as engineering, quality assurance and purchasing management, have participated in a seminar emphasizing the B&R. management commitment to perform all Project work correctly the first time.
[ The changes and improvements implemented to date by both HL&P and B&R have resulted in a revitalization of the QA program for STP.
L
% I w
I I
I In response to Item (1) of the Order, a review has been conducted by experienced, independent consultants to determine the adequacy of the licensee's management of the QA program. The quality organizations of HL&P and B&R have been restructured after a careful examination of the advantages and disadvantages of alternative organizational forms. And, as noted above, the restructured organizations have been strengthened with the addition of experienced personnel knowledgeable in the special requirements of the nuclear industry.
The response to Item (1) to the Order also describes indoctrination and training programs which have been under- I taken and are planned by HL&P and B&R to infuse a sharpened sense of quality awareness from the field level to the top i management of both companies. A new B&R brochure (attached 1
response to Item (4) of the Order) reflects this attitude.
In addition to organizational and personnel changes, HL&P and B&R, in response to Iterrs (5)-(9) of the Order, have re-examined critical adminis vative systems designed to assure: (i) clearer definition of "stop work" authority; (ii) effective system for identification and correction of I nonconforming conditions; (iii) effective system for control l
l of field changes; (iv) efficient records management program; and (v) improved audit procedures. Important changes have been made in all of these areas after intensive review by I I
I l
l HL&P and B&R and consultant personnel of the advantages and disadvantages of existing systems. Several new procedures l to implement changes in these systems are in place; others are being developed and will be placed in operation within the next few months.
, -STATUS OF WORK-L All of the improvements discussed above are reflected in current steps by HL&P and B&R to (i) assure the adequacy of ongoing work; (ii) develop a program for commencing
( previously suspended activities on an orderly basis; and (iii) verify the adequacy of work previously completed.
(i) Ongoing Work The basic categories of work now ongoing at the Project site by B&R include non-safety related welding, non-complex concrete pours, cable pulling, painting, and the erection and installation of equipment, such as pumps, heat b exchangers and switch gear. B&R management has taken steps, as outlined above, to assure that work in progress satisfies all requirements. Additionally, future improvements in the p quality program at the STP, as discussed in the attached L
responses to the Order, will provide further assurance of
[ a workable and effective quality program.
r (ii) Resumption of Suspended Work L
All work at the Project site involving complex
~ safety-related concrete placement and safety-related welding i
[ .
[
was halted by HL&P and B&R in December, 1979, and April, 1980, respectively, prior to issuance of the Order. It is proposed that this work be gradually restarted on a controlled E.
basis, but only after consultation with I&E Region IV, and
{ in accordance with the following step-by-step program of planned QA and construction activities:
( A. AWS Structural Welding
- 1. Reconfirmation of the adequacy of applicable safety-related AWS welding procedure qualifications.
- 2. Corrective action on items identified in the immediate action letter from I&E Region IV, dated April 17, 1980.
{
- 3. Review and revision of applicable AWS welder
( qualification procedures, AWS welding procedures and welding material control procedures.
- 4. Review and revision of applicable non-destructive p examination procedures.
L
- 5. (
Completion of personnel training for procedures in i
{ items 3 and 4, above.
{
- 6. Confirmation of the adequacy of items 3, 4, and 5, r
L above, by an independent third party expert, a Level III g Inspector certified by examination.
t
- 7. Requalification of selected welders for AWS work.
f 8. Reconfirmation of qualification and certification L
records of selected inspectors.
I L
~
_g_
[ .
[
[
- 9. Resumption of AWS structural welding on cable tray
[ supports in Room 202 of the Mechanical Electrical Auxiliary Building of Unit 1 (MEAB-1), using these qualified welders and certified inspectors. (This is expected to begin in mid-August 1980.)
- 10. Review by certified Level III Inspectors of the
{ quality of welds and documentation of the work in item 9, above, for conformance with requirements.
- 11. After the process described in the above items has been satisfactorily demonstrated, the AWS welding program
[ vill be expanded into other plant areas as additional personnel
{ are qualified.
B. Restarting ASME Welding
( l. Reconfirmation by B&R's QA Department of the adequacy of the applicable ASME welding procedure qualifications.
- 2. Corrective action on items identified in the immediate action letter f. rom I&E Region IV, dated April 17, 1980.
3.
{ Revision of certain sections of the B&R STP QA Manual to reflect recent changes in the QA program.
[ 4. Approval of QA manual changes by the authorized nuclear inspector and ASME.
- 5. Review, revision and reissuance of implementing procedures affected by QA manual changes where necessary.
L
~
~
a .
[
[
- 6. Review, revision and reissuance of non-destructive
( examination procedures where necessary.
- 7. Completion of personnel training in applicable revised procedures.
- 8. . Confirm the adequacy of items 5, 6 and 7, above, by an independent third party expert, a Level III Inspector certified by examination.
{
- 9. Training and requalification of welders.
( 10. Reconfirmation of qualification and certification records of selected inspectors.
- 11. Resumption of ASME welding, using these requalified welders and certifie'd inspe." ors, on the following two systems:
{ a. Component cooling water system piping (carbon steel) in cubes 3B, 3F, 3J of MEAB-1.
[ b. Boron Recycle System piping (stainless steel) in cube 3C of MEAB-1.
- 12. Review by certified Level III Inspectors of the
[ .
quality of welds and documentation of the work in item 11, above, for conformance with requirements.
{ 13. After the process described in the above items has been satisfactorily demonstrated, the ASMZ welding program will be expanded into other plant areas as additional personnel are qualified.
h .
[
[ C. Complex Concrete Placement
- 1. Revision and reissuance of concrete placement procedures.
- 2. Training of personnel in the revised procedures.
Specific complex placement provisions will be addressed in l
[ separate training sessions.
{ 3. Construction, Engineering and QA management will review the results of the Unit 1 Reactor Containment Building
( Concrete Task Force investigation for impact on existing procedures and methods and will make modifications in these procedures and methods as necessary.
- 4. Assignment of complex pour coordinator from Con-struction to oversee complex concrete placement operations
{ until such time as Construction management determines that performance is satisfactory.
b 5. Assignment of a complex pour coordinator from QA to oversee concrete placement inspection activity on these
[ pours until QA management determines that QC performance is satisfactory.
- 6. Verification of the availability of qualified
( Pittsburgh Testing Laboratory concrete testing personnel.
- 7. Reconfirmation of the qualification and certification
[ of QC inspection personnel.
- 8. Review of the concrete supplier's quality program
[ to assure there are no unresclved quality program deficiencies.
I 1 l
I l
1
- 9. Reverification of the availability of adequate concrete placement equipment and personnel.
- 10. Resumption of ccmplex concrete placement to begin with those pours already formed, proceeding from simpler to more difficult pours as follows:
(a)
I (b)
North valve room walls and second shield EL -2' to +9'3" South HX walls CI2 W24 - 160 cu. yds.
El -2' to +9'3" CI2 W22 - 208 cu. yds.
I (c)
(d)
Southeast secondary shield wall EL -2' to +9'3" North valve room walls / slabs CI2 W23 - 40 cu. yds.
EL 61'3" to 68'0" CIl S68 - 102 cu. yds.
(e) Containment shell EL +53' to +63' CS2 W8 - 580 cu. yds.
(f) Dome pour I (g)
EL 150' to 155' CSl W18 - 375 cu. yds.
North valve room walls and secondary shield walls EL 9'3" to 16'0" CI2 W27 - 137 cu. yds.
I (h)
(i)
Southeast exchange wall and secondary shield walls EL 9'3" to 16' CI2 W28 - 129 cu. yds.
Southeast secondary shield walls EL 9'3" to 16' CI2 W26 - 32 cu. yds.
I 11. Review of the quality of the placement and documenta-tion of the work for.conformance with requirements.
- 12. After the processes described in the above items have been completed, the complex concrete placement program will be expanded into other areas as additional personnel are qualified. l QA management will review the implementation of these steps to verify that the quality program is functioning properly. Resumption of the work will begin gradually, with specific QA management assurance that all procedures and I
I
L
[
[
check lists are in place and the requisite number of qualified QC inspectcrs are available for each construction activity.
Each step of the resumed work will be carefully monitored; and only after B&R & HL&P QA management and Construction
{ management have assured themselves that the resumed construc-tion activities are being done correctly, and the QA/QC b system is working effectively, will the work in these activi-ties be increased.
[ (iii) Remedial Work The attached responses to Items (3)(a) and (3)(b) of the order identify certain welding and concrete work, previ-
{ ously completed, which will be thoroughly reinspected, evaluated and reworked as necessary. The remedial work will b be carefully planned and controlled and will be commenced and undertaken under the same controlled conditions as E
described above for the commencement of new safety-related
{ welding and complex concrete placement activities.
The detailed remedial action program cannot be
[ t ...lized until the planned inspection program associated with the attached response to Items (3)(a) and (3)(b) is L completed during the next few months. The results of this l 7 investigation will provide the technical basis for the L
corrective actions to be taken. The on-going work and the
{ commencement of new work will be carefully planned to minimize interference with the inspection and remedial action program.
% I a
w
L
[
[
As indicated above the foregoing activities would b be undertaken in consultation with NRC I&E Region IV.
-CONCLUSION-
[ The information in this Response and Attachment 1 was developet by a task force of HL&P and B&R personnel and consultants. The'ir work has been performed with the guidance,
{ support and review of senior management. The commitments therein are commitments of HL&P and B&R, and of their respec-
[ tive senior managements. These commitments, faithfully executed, provide assurance that the construction activities
[ at STP are, and will be, conducted in accordance with appli-cable requirements, are consistent with the public health and safety, and therefore should not be stopped.
[ HOUSTON LI ING & POWER CO ANY f
[ im drgje' W.
Oprefa"3r'. '
Dated: July 28, 1980 /,
xecutive Vice Presilc ent/
( cc: Attached Certifici'e of Service l
[
[
[ .
[
[
STATE OF TEXAS S COUNTY OF HARRIS $
GEORGE W. OPREA, JR., being first duly sworn, deposes and says: That he is Executive Vice President of HOUSTON LIGHTING & POWER COMPANY, an applicant herein; that the foregoing Response to Order to Show Cause, including Attachment 1 thereto, has been prepared under his supervision and direction; that he knows the contents thereof; and that
- I to the best of his knowledge and belief said response and j
- g the facts contained therein are true and correct.
at DATED: This.2.i day of July, 1980. . .
Signe
/ I'
/ , me, ... -
- I July, 1980.Subscribed
/ eo~rg TOprea, Vf " g ~ y and sworn to before me this->$ kday
- t of
'E /
,n B Notary rud11c in and for the County of Harris, State'of Texas
,My Commission Expires:
}n 'j.u .
. u. M s; MS: 7:I A
il o
~I
[
E ATTACHMENT 1 TO LICENSEE'S RESPONSE TO ORDER TO SHOW CAUSE I
I '
I I
I lI I
=
l
L .
[-
[
RESPONSE TO ITEM (1)
[
Order: A review shall be conducted by an experienced,
[ independent management consultant, knowledgeable in QA/QC
{ and nuclear construction, of the licensee's management of the quality assurance program to determine whether the b management of the program is adequate to exercise full control.over all. aspects of the South Texas Project. Con-b sideration shall be given to the revision of organizational
{ responsibilities to control the design, procurement and construction activities of the licensee's prime contractor,
[ Brown and Root, Incorporated (B&R). A discussion of the pros and cons of each concept shall be included. The alter-natives considered shall include as a minimum:
{ (a) the present organizational structure where B&R has implemented a Quality Assurance / Control (QA/QC)
Program, under the licensee, l
(b) an organizational structure where all levels
[.
of the B&R QA/QC organization would report to the licensee yet remain B&R employees, (c) an organizational structure where the licensee establishes a total QA/QC organization to conduct the current B&R QA/QC functions, E
(1-1)
[ .
[
[.
(d) an organizational structure where the licensee
[ contracts with another independent organization to perform the current B&R QA/QC functions,
[
(e) an organizational structure where the licensee
{ establishes a duplicate QA/QC organization, in whole or in part, to that of B&R with both groups performing duplicate functions.
A recommended course of action shall be defined by the licensee including the schedule for implementation. In evaluating the recommendations of the consultant in order to select the best concept, the licensee shall provide information on how it will exercise its overall responsibility for the QA/QC program l including the management structure, the degree of involvement,
[ l 1
qualifications, staff size, training, and experience. Of
( particular interest are the frequency and depth of participation of upper and middle management to assure that knowledge of the effectiveness of the QA/QC program is current, that such persons take the necessary actions to verify that the various QA staffs are effectively applying good QA controls, and that
[ all personnel have the proper attitude and are applying the necessary attention to detail.
[ Response:
{ HL&P has studied these matters and made significant changes in its quality assurance program on the basis of this {
b review. Important changes have also been made by B&R.
[
. (1-2)
I Bechtel Power Corp. (Bechtel) and Management Analysis Company (MAC) were retained by HL&P to aid in performing the management study required by this section of the Order. Bechtel is the largest domestic engineer-constructor of nuclear power plants. MAC is a management consulting firm specializing in the performance of management diagnostics and quality assurance audits in the nuclear industry. MAC has performed over 30 management reviews on nuclear power plants throughout the United States in the past four years.
- 1. Performance of an independent management review Having anticipated the need for an independent management review of the QA program, HL&P, in February, 1980, retained Bechtel for this purpose. Bechtel was selected because of 1
its familiarity with the quality requirements of the nuclear l I industry and, as required by the Order, its prior nuclear construction experience. Having had no prior involvement in the STP, Bechtel also met the requirement of the Order, for an ir. dependent review. Finally, Bechtel was able to bring to the task its extensive experience in performing QA audits of its own projects.
Bechtel conducted the review during the period March 4 through May 21 utilizing eleven senior auditors experienced I in nuclear construction and QA requirements. The team performed an in-depth examination of the STP quality systems.
j Checklists were prepared covering 232 separate aspects of QA L
(1-3)
I
\ - _ _ _ _
[
C.
requirements. Manuals and procedures in use by both HL&P and B&R were reviewed in detail to determine compliance with program requirements and to evaluate the adequacy of the
[. l quality systems described. QA records were randomly selected
{ for examination and numerous interviews were conducted with l project personnel.
The Bechtel report, addressing the NRC's Order, is attached as Exhibit 1. Computer printouts of the results of
[
the audit by Bechtel are available at the STP site. A
{ preliminary review of the Bechtel Report indicates that changes are required to achieve:
(1) A simplification of project procedures to make them more understandable to project personnel;
[
(2) improvements in indoctrination and training
( of personnel performing quality-related work; (3) strengthening of controls to assure that quality-related activities have been initiated, per-formed and documented; (4) greater management visibility and involvement
[ in the QA/QC program; (5) greater emphasis on pre-planning of inspection
[ activities and proper approval of inspection plans; and (6) better control of field change procedures and
{
nonconformance reporting.
[
[
r (1-4)
Il L
E Performance in each of these areas will be improved as
( the changes in the QA/QC program discussed below are implemented.
- 2. Evaluation of the cros and cons of the five alternative E organizations listed in the Order
{ HL&P also requested that Bechtel, upon completion of '
the audit, perform a review of the various organizational b alternatives as set forth in the Order. Bechtel was able to bring to the task its understanding of the STP QA program as derived from its review of the quality systems and organiza-
{ tions then in place. A detailed discussion of each alternative as prepared by Bechtel is included in Exhibit 1.
b 3. HL&P's recommended organization and basis for selection An analysis by HL&P of the NRC I&E reports on the STP E
organization and the Bechtel review identified the following three general management areas in need of improvement, each of which were addressed in considering reorganization of the i QA/QC program.
l (1) Management involvement in the quality as-surance program.
[ (2) Strengthening the quality assurance or " problem prevention" arm within HL&P and B&R.
F
" (3) Reinforcement of a positive quality attitude on the part of all levels of management within EL&P and B&R.
m A
e w
t (1-5)
[
E Five major criteria were identified which guided
( HL&P's consideration of alternative QA organizations for the STP:
(1) Owner control and visibility
{ The owner's Quality Assurancy organization must be able to effectively monitor the performance of B&R and have b sufficient authority to effect programmatic changes as necessary. That authority can emanate only from a well-E informed HL&P executive management, fully apprised of the
{ status of project quality activities.
(2) Constructor responsibility for quality After considering those alternative organizations set forth in the NRC Order which would have the effect of relieving
[
B&R of quality assurance responsibility, it was determined
{ that such a move would be counter-productive in that the construction organization's sense of responsibility for building quality into the work might possibly be impaired.
It was therefore concluded that the constructor should be accountable for implementing an effective quality assurance
[ program internal to his organization and fully understood I
and supported by all levels of management. '
(3) Owner's programmatic direction 7 The organization must emphasize the owner's role in L
providing QA programmatic direction as contrasted with the constructor's role of implementing the details of an ongoing (1-6)
[
[
quality program. The owner's programmatic direction es-( tablishes the overall objectives of the quality assurance program. This requires the inclusion of a diagnostic function--
[ analyzing problems, trends and maintaining overall project control. The constructor is charged with the responsibility
{
of implementing the quality assurance program which meets
( the programmatic objectives established by the owner. The constructor must also have a diagnostic function as described
[ above, and must also execute programs for day-to-day verifica-
{ tion of project quality assurance in accordance with systematic delegations of QA responsibilities from the owner.
( (4) Quality Assurance independence The QA organization must be insulated from any pres-
[
sures of cost or schedule from within either the HL&P or the B&R organization. The QA function, while organizationally
{
independent of project management of engineering, construc-tion and purchasing activities should have direct access to the same senior executive having responsibility for these
[
functions. This will assure that executive management,
[ project management and the QA organization are kept fully aware of project activities.
(5) Capability of implementation The new organization should be one that can be readily implemented by drawing upon existing personnel and systems
( whenever possible. Similarly, the implementation of the i
[ t (1-7)
b
[ 1 l
[
program can be helped by building, to.the maximum extent, on
( existing procedures, checklists, and records in place.
[ -
After weighing the foregoing criteria and considering
{ the areas of the QA/QC program in greatest need of strength-ening from a management standpoint, HL&P decided on an
[ alternative which, in broad terms, resembles alternative (a) of the Order in that it preserves B&R's responsibility for
[
quality assurance activities ano stengthens HL&P's program-
{ matic role in the QA program. In the case of both parties, '
however, a comprehensive infrastructure has been created which addresses every major function of a good QA/QC organ-ization.
[
Bechtel's study (Exhibit 1) identifies the possible
{ disadvantages of alternative (a). However, on careful analysis, these disadvantages are not related to the structure l
of the organization but rather to potential problems in its implementation which might be applicable to any organizational concept. In effect, EL&P has addressed and minimized the
[ disadvantages of alternative (a) by significant reorganization within the bounds of the concept, fundamental modifications
[ of QA/QC procedures, improved management implementation, and significant upgrading of the QA/QC Staff.
{
[
[-
(1-3)
{. .. . .
[
[
The organizational concepts adopted are portrayed in
[ Exhibits 2, 3 and 4 together with functional descriptions of each organizational component. Highlights of the structure
[ of each organization are discussed below. In general,
{ however, the reorganizatica increases the HL&P presence and involvement in the QA/QC program. The structure clearly
[ establishes that programmatic direction comes from HL&P's Manager of QA while implementation of the program is the
[ responsibility of the B&R Project QA Manager acting through the B&R QA/QC organization with close, continuing overview by the HL&P organization.
In the case of both organizations, the Project QA Manager has been assigned to the Project site. Where per-sonnel required to fulfill key positions in the expanded
{ organizations are not available to either HL&P or B&R, MAC personnel and individuals from other consulting organiza-
[ tions have been brought on board to fill those vacancies.
It is planned that HL&P and B&R personnel will be assigned L
to work with MAC people and other consultant personnel in
[ order to develop their capabilities and ultimately take over the assignments. Additional personnel are being recruited L
as necessary to fill out both the B&R and HL&P organizations e as manning levels dictate based on the construction schedules L
and activities. (See 4 C. and D. below) r L
(1-9)
o
[
[
- 4. Description of how licensee will exercise QA/QC
( responsibilities
~
The following is a discussion of how the licensee and
[.
its constructor will exercise QA/QC control through the new organization:
{
A. Management Structure
( (1) HL&P (a) QA Management
[
The HL&P Corporate QA Manager has been relieved of all other project activities and has been
{
assigned sole responsibility for the STP Quality ;
b Assurance program. He reports directly to the Executive Vice President and provides a direct
[
avenue of communication on QA matters to him on a day-to-day basis. The QA Manager has been relo-
{
cated full-time to the site where he can be totally engaged in project activities. The HL&P QA organ-ization has been restructured to include four distinct components: Discipline Quality Assurance;
[ Quality Control; Quality Systems; and Quality operations; each of which is described below. The separate, off-site corporate auditing function has been augmented for the purpose of increasing the number of periodic independent audits.
[
[
(1-10)
T t - -
L
[
[ (b) Discipline Quality Assurance
{ ,
The HL&P Project QA organization for STP has been restructured to provide a quality engineering function with separate Project QA Supervisors in each of the major di'sciplines: Civil / Structural;
[ Mechanical /Non-Destructive Examination (NDE); and
{ Electrical / Instruments and Controls (I&C). The primary function of each Project QA Supervisor is to provide programmatic direction to B&R on all QA matters related to his discipline. Project QA Supervisors will assess the quality engineering j
[ and inspection functions of B&R by performing mini-audits, review and approval of procedures and observation of work activities in the field.
Discipline QA Supervisors will determine the extent of quality control inspections and prepare
[ necessary checklists and guidance for this pur- '
pose.
(c) Quality Systems
{ The Quality Systems organization has respon- '
sibility for preparing QA procedures, analyzing b B&R trend data and analyzing audit findings. Such analyses will be performed with B&R input and will provide top management with timely information on
{ the quality status of the South Texas Project.
[
(1-11)
~
L I
Additionally, the Quality Systems organization
( will be responsible for providing coordination and control for all HL&P QA training and indoctrina-tion sessions.
{ (d) operations QA This group is responsible for organizing the
( operations QA plan for preoperational, startup and plant operations activities. Responsibility for coordination of the inservice inspection activities
{ for the plant is also assigned to the Operations QA group, b (e) Quality control A Quality Control function has been newly b
established within the HL&P QA organization to
{ provide an inspection of selected hold points within the B&R QC inspection program. HL&P j Discipline QA personnel will determine the extent of surveillance inspections to be performed by the HL&P Quality Control organization and provide
[ checklists for the purpose of documenting the inspections.
F (f) HL&P Procurement QA HL&P procurement QA provides programmatic u
directish to B&R vendor surveillance and auditing F
L functions and coordinates between the project and E
- (1-12)
l the HL&P vendor surveillance group. This organi-l zational component also coordinates QA review of engineering-associated documents.
(2) Brown & Root I (a) QA Management l
B&R has established a Project QA Manager l function located at the site. The position of Assistant QA Department Manager has been eliminated.
As a result, the Project QA Manager at the site reports directly to the B&R Corporate QA Manager.
He will receive programmatic direction from the HL&P Manager, STP QA.
The-B&R QA program has been restructured to provide separate and distinct organizations for Quality Engineering, Quality Control, Quality Assurance Systems, Site Audits, and Houston QA l
Coordination. All organizations report directly to the Project QA Manager. All functions are located at the site with the exception of the Houston QA coordination function.
Under the new arrangement, the B&R Project QA Manager has total control over all elements of the B&R QA program for STP (except corporate audits)
- 3 and can be fully responsive to the HL&P Manager, __
lg -
STP QA for all programmatic matters.
I (1-13)
I I
I (h) Quality Engineering The B&R Quality Engineering function will encompass the major disciplines (i.e. Mechanical, g NDE, Electrical, Instruments & Controls, Civil, 3 Structural and certain specialized functions (such as coatings and insulation)). Discipline Quality Engineers have been assigned responsibility for controlling all quality assurance activities related to their individual specialties. They will work closely with their lead discipline l counterparts in Engineering and Construction to l
resolve in a timely fashion any problems that are identified during construction to assure that the cause is determined and adequate corrective action is accomplished.
The Quality Engineers are responsible for the performance of quality engineering design reviews, purchase order reviews, reviews of design changes l and nonconformance reports, and the preparation of inspection checklists.
The Quality Engineers participate in planning QA activities (procedures, checklists, training, I etc.) associated with specific construction ac-tivities. The work of the Quality Engineers will I
(1-14)
[ assure that QC inspectors who go to the field to
{ perform inspections will be working to clear instructions and acceptance criteria.
(c) Other B&R QA Activities -
The remaining B&R QA/QC functions are similar
[ to the HL&P organizational arrangements. Quality
{ Control inspects construction activities pursuant to inspection planning instructions prepared by Quality Engineering. The system for controlling nonconforming conditions assures that inspectors are advised of the disposition of their findings.
{ (See response to Item 6) B&R Quality Assurance -
Systems coordinates records turnover procedures, the B&R QA training and. certification program, and nonconformance data analysis. The Houston QA Coordination section is responsible for inspec- -
( tions and audits of vendor activities and serves as the interface between QA and Houston Engineer-ing and Procurement activities. The Site Audits section, as part of its auditing function, verifies
{
the adequacy of the corrective actions taken in
( response to its audits. A more detailed listing of the functions of each B&R QA organizational component is reflected on Exhibit 4.
l F
g ..
L (1-15)
~
l
[-
[ B. Licensee Involvement in the Project The restructured organization for Quality Assurance, as discussed above, is designed to place the owner in a highly
( visible role. This is emphasized by a recent executive level reorganization pursuant to which the Executive Vice President of HL&P was assigned on a full-time basis to direct and manage the Company's nuclear affairs while re-
{
taining his direct reporting relationship to the President.
( All non-nuclear responsibilities have'been delegated to others so that the Executive Vice President can direct
[ virtually all his attention to the STP.
{ Upper level management of HL&P will also participate directly in all aspects of the Project, including QA/QC
( functions. Frequent on-site visits and meetings to review progress and problems will be conducted.
[ HL&P's Executive Vice President will also partici-
{ pate in periodic meetings of the B&R QA Management Review Board which is composed of B&R's Group Vice President-Power b and senior officers. The function of the Review Board is to l
assess the status of quality activities. I C. Qualifications and Experience of Personnel
[ A review has been made of the qualifications of all key personnel within HL&P and B&R by Bechtel and MAC. Efforts F
L to recruit qualified personnel for positions requiring up-r L
l L
(1-16) m
~
L l i
k
(
graded qualification ~s are being given a high priority. The
{ organization charts attached indicate positions in which MAC personnel are performing activities pending hiring by HL&P and B&R. Exhibit 5 includes the resumes of MAC personnel acting as advisor to HL&P's Manager, STP QA as well as MAC
(
personnel occupying key positions in B&R's QA and Quality
( Engineering groups. In addition, MAC has assigned six lead quality engineers in various disciplines with an average of 14 years of nuclear experience (six years minimum), to )
augment the B&R and HL&P quality engineering effort.
B&R will continue to upgrade the qualifications of its
[ QA/QC management team. This upgrading will be accomplished by formal and informal training activities and counseling of the individuals involved. The day-to-day association with MAC personnel will provide on-the-job training in important areas. Formal training programs in human relations and
( principles of supervision, which are underway, are focusing upon the need for improved communications and management
[ support of inspection personnel.
{ Technical training programs for QA/QC personnel to ensure full knowledge of procedural requirements have been
( and will continue to be conducted. The curricula for these technical programs will be modified as needed by the Quality Engineers based upon personnel performance. Trending of I.
a (1-17) I r
[. . . . .
l l
various types of deficiencies will reflect any significant !
l t failures to comply with procedural requirements, and provide 1
management with information on which to base continued l improvements in training. -
D. Staff Size l
A review of staffing requirements identified certain l
areas in HL&P requiring additional personnel (most notably in quality engineering and audits). There are now about l twenty-five professional personnel assigned to the HL&P STP QA organization. A need has been identified for approximately twenty additional personnel, and hiring efforts have been undertaken.
In the interim, a senior MAC person with extensive nuclear experience has been retained to work with HL&P's Manager, QA at the STP site and experienced MAC personnel 1
I l
have been added to the HL&P home office audit group.
+
addition, EL&P has been able to hire four experienced people In for the new site quality discipline organization in the areas of Civil / Structural and Mechanical /NDE.
B&R has already made significant personnel changes in its QA organization. The QA Department Manager has been replaced. Eleven senior level department staff personnel have been transferred into the STP Project Organization.
1 The Project QA Manager and Managers in the Project QA/QC I
1 (1-18) 1
Organization of Quality Engineering, Quality Control, Quality Systems and Site Audits have been replaced. All Vendor Surveillance personnel performing shop inspections for STP have been transferred from the Department Staff directly to the Project Organization.
MAC personnel within the B&R QA organization include a new QA Project Manager; a QE Manager and a Civil / Structural Discipline Engineer. B&R is also utilizing two persons on loan from NUS Corp. (NUS) to assist in records control activities. The B&R audit staff has been augmented with eight persons from NUS and Science Applications Inc. (SAI);
an additional five will be added shortly.
E. Training A program of retraining inspectors and crafts is currently underway. Quality engineers are establishing the necessary training programs to update construction and QC personnel on newly established quality requirements. Likewise, in the area of revised procedures, indoctrination and training sessions are underway to educate personnel on changes in QA l l procedures and organizational' interfaces and responsibilities.
- 5. Upper and Middle Management Involvement in the Project QA I Program As discussed above, a number of steps have been taken I
to increase upper and middle level management involvement in I-.. .
l l
(1-19)
\ _ _ _ - _ _ _ _ _ _ _ _ _ - - __ _
[
[
the Project QA organizations of HL&P and B&R. The HL&P Executive Vice President has been ' signed responsibility for the STP, virtually on a full c.tme basis. The HL&P QA
( Department Manager has been re.'acated to the Project site and has been assigned full responsibility for the STP QA
[ program.
A requirement has been established for periodic meetings at the site which will be attended by key upper and middle
( management personnel of both companies, including for the foreseeable future members of the B&R QA Managment Review
[ Board. Each meeting will include a report on the status of the QA program highlighting quality problems, trends, etc.
{
On June 20, 1980, a special seminar was held for executive
( management of HL&P and B&R utilizing the services of a well known QA/QC consultant, Mr. Phillip Crosby. The major
[
thrust of the seminar was a description of the significance of doing work correctly, the first time. As an outgrowth of
{
the Crosby seminar, B&R has embarked on a quality improvement
- k. program. With senior officers of B&R acting as an Oversight Committee and line managers comprising a Steering Committee,
[
the corporate commitment to quality improvement will be
( expressed through training and indoctrination and innovative programs to encourage positive attitudes toward quality performance.
L I
(1-20)
_._______________ m
[
[
- 6. Actions by Management to Periodically Assess QA Controls,
[' Attitude and Attention to Details.
In addition to the actions noted above which emphasize greater management involvement in quality activities, the QA programs of HL&P are being revised to include an annual
{
outside audit by an independent consultanu. This annual
[ audit will be in addition to the regular corporate audits ,
1 conducted from the HL&P home office. The annual audits will
[ be approximately one month in duration and will address all aspects of the QA program. They will be designed to assess
{
compliance with procedures, adequacy of controls and overall
[ effectiveness of the QA function. An in-depth interview process will be an integral part of these audits which will b
help to assess attitudes and management support for the QA program.
{
SUMMARY
l b In summary, the managements of HL&P and B&R are com-1 mitted to an intensive effort to restructure and re-vitalize
[ the STP QA program. This effort is underway and the new
[ organization is already contributing to project improvements.
The restructuring of the organization as outlined above has been accomplished and essential staff positions are being filled with qualified personnel as a matter of highest prior-ity. HL&P and B&R fully recognize that quality imprtvement b
[
(1-21)
F - -
[ t E
is a continuing program requiring concentrated and consistent L attention by management.
E E
E E
E c
L E
u b
c e
L L
r 6
F
- (1-22)
3:
l EXHIBIT 1 I~
I I FINAL g QUALITY ASSURANCE g VIANAGEMENT RE3 ORT i
OF I
! TH E SOUTH TEXAS PROJECT jI BECHTEL JOB NO. 1/129-900 lI i
FOR lI HOUSTON LIGFTING AND POWER COMPAN ll i
!I i
lI BY l BECHTEL POWER CORPORATION GAITHERSBURG POWER DIVISION
- JULY 24,1980 lI
[
[
b FINAL
[. QUALITY ASSURANCE MANAGEMENT REPORT
[ OF L THE SOUTH TEXAS PROJECT l
r FOR L
HOUSTON LIGHTING AND POWER COMPANY BY BECHTEL POWER CORPORATION I
GAIT 4ERSBURG POWER DIVISION JULY 24, 1980 c
E u
n i
r
TABLE OF CONTENTS
{
Section Pg
[ Foreword i
~
~
Part I Introduction 1 ,
Part II Recomendations 4 l 1
Part III Typical Industry Practice
{ 8 l Part IV Discussion of STP-QA Organization Options 25 Attachment A Discussion of Pros and Cons of STP-QA Organization Options A-1 b Attachment B Organization Charts B-1
(
[
[
[-
[
E r
( .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
I FOREWORD l
I This final report of Bechtel Power Corporation's study of the South Texas Project is submitted to Houston Lighting and Power Company in accordance with the Technical Services Agreement of February 21, 1980. !
I l The report identifies deficiencies in the quality program when compared with requirements and commitments, and offers recommendations for improvement, where appropriate. Industry practices proven to be effec-tive are generally described as they relate to particular problem areas.
I !
I I
I :
1 I
i l I i i
I I
I i
PART I INTRODUCTION
{
l l Bechtel Power Corporation's report on the quality systems for the South Texas Project (STP) employed by Houston Lighting and Power Company (HL&P) and by its engineer / constructor, Brown and Root, Inc., identified l
findings which are significant indicators of problem areas.
Bechtel's findings were determined from a comparison of the STP func-tioning quality systems to the regulatory requirements of 10 CFR 50, Appendix B and the provisions of ANSI N45.2 and daughter standards referenced in the STP Preliminary Safety Analysis Report. STP program l manuals and implementing procedures were reviewed for compliance with requirements and evaluated for adequacy. Checklists prepared by Bechtel consisted of 232 individual items representing key system elements l
selected for evaluation. Discrepancies, concerns, and observations were discussed with responsible personnel and auditor recommendations offered during the course of the study.
The study resulted in the identification of six " root causes" for the findings. These " root causes" point to major problems in the STP quality systems for which direct HL&P and B&R management action is required. No amount of co ~ective action to the individual findings will have any l lastinn effec.t. unless effective management action is taken to resolve root causes. The significance and importance of root causes to the j successful completion of the project cannot be overemphasized.
I Recommendations for management action, particularly related to the six
" root causes," is provided in Part II. In conjunction with this study, Bechtel was asked to participate with HL&P in an evaluation of several I l organizational options for the QA function. Part IV discusses organization, I staffing levels, and job descriptions for an improved QA organization.
l I
l 1
i
,c While improvements in the QA function are warranted by the findings, the
" root causes" identified in the report transcend the QA departments and their personnel. As long as these " root causes" exist, the organizational structure of the QA departments is of lesser concern.
In Part III, a general description of practices employed by others in the industry is provided for HL&P management as a guide in planning actions related to resolv,ing the six " root causes." The practices described are those proven to be effective in preventing or mitigating the cons ~equences of similar system problems indicated by the six " root causes."
The six " root causes" identify majcr areas requiring direct management action. Improvements in the ovarall quality effort are required if the project is to reach a success'ul completion.
It is imperative that HL&P management take an active part in the pro-ject's quality program. There must be continuing, strong, management support and involvement in the QA program, including participation in l decision making processes which affect quality. The HL&P QA manual l contains no evidence of management endorsement nor evidence of a policy statement which commits to quality performance and defines responsi-bility for attaining quality objectives. The endorsement statement must l be prepared and issued by a responsible HL&P executive to clearly establish that the quality of the work is the responsibility of the persons or
- functions doing that work, and that HL&P is committed to quality per-formance at all levels. Furthermore, HL&P management must take immediate i steps to demonstrate its quality commitment and promulgate a " quality first" philosophy throughout the project. Specific action by HL&P and l B&R management is required to strengthen the quality leadership of the project functions and to establish a strong, professional QA function within both organizations. Both HL&P and B&R mana'ement g must actively Ii provide unequivocal support to the QA functions, and day-to-day project operations must reflect a " quality first" attitude with only the safety ll of the work force having higher priority.
I i 2
k ..
L
[
Management participation in the QA program must be ensurr,d by strength-
{
ening system elements which will apprise management of how well the program is working and will involve appropriate management levels in the corrective action process. Prudent actions to resolve general problems should be initiated with appropriate management cognizance and follow-up.
An improvement in overall quality effort can only be realized by project-( wide programs aimed at motivation to quality performance and by alerting everyone to the consequences of failure to meet quality requirements. A positive quality attitude, at all levels of the project, is essential to the success of any action to correct " root causes," resolve audit findings, and effect long term improvements in the STP quality systems.
{
The remainder of this final report should be considered in the light of the foregoing observations, and action plans structured accordingly.
E
[
[
[
[
[
[ l l
E E
E F --
{ PART II RECOMMENDATIONS
[ Observations and recommendations were offered by the auditors and dis-cussed with those responsible during the conduct of the audit. The h impact of the six " root causes" on the effectiveness of the STP quality systems indfcates a need for direct action by both HL&P and B&R manage- l
[ ment to effect prompt and substantial improvement in those systems.
[ PROCEDURES. A concerted effort should be undertaken to ensure that STP-QA program requirements are adequately documented by clear, concise,
[
and achievable implementing procedures and instructions. It is recom-mended that a task force from both HL&P and B&R be organized, drawing on tha quality systems expertise of quality assurance, engineering, procure-ment and construction, for the purpose of reviewing functional procedures,
( simplifying them as required, or documenting details of important system elements for which provisions are not presently made. This effort should have the explicit endorsement of HL&P and B&R management and the commitment of the respective functional organizations for implementation.
With the importance or criticality establishing priorities, HL&P QA should coordinate and track the task force effort. A matrix should then be strectured to identify how requirements and commitments are met by functional procedures,. This will ensure that higher tier STP-QA program requirements are documented by functional procedures and will purge the quality systems of unnecessary detaffs. Once the functional procedures are in place, a 6-month hiatus should be imposed on further program
( development or revisions.
[ O_0CUMENTATION AND ANALYSIS OF DEFECTS. It is recognized that conscien-tious implementation of adequate procedures and instructions will greatly overcome observed deficiencies in documentation, including traceability to approved designs and documented evidence attesting to quality work 4 .
I I performance. It is recommended that HL&P and B&R management commit to prudent action for documenting trends of nonconformances and program deficiencies identified by audit results. The trend analysis system employed for this purpose should provide for identifying significant I trends related to generic problems for which solutions can be sought and should serve to trigger corrective action.
TRAINING AND QUALIFICATION. A comprehensive program of quality orienta-tion, indoctrination to requirements, and functional training to proce-dures is recommended for personnel performing quality-related activities and for personnel performing quality surveillance or verification func-tions. Further, it is recommended that quality orientation and indoc-trination programs involve HL&P and B&R personnel at all levels, including management, and that motivation to quality performance receive primary emphasis. When adequate procedures and instructions are finalized and in place, a comprehensive program of functional training and qualifica-tion of personnel should be undertaken to ensure effective implementation.
Provisions should be made for follow-up or refresher training, as required, to ensure consistent application of procedures. Since this effort requires extensive planning and development, it is further recommended that consideration be given to programs developed elsewhere in the
- industry and proven to be effective.
SYSTEM CONTROLS. It is recommended that the STP-QA program and its implementing procedures clearly identify responsibilities and reflect a closed-loop feedback concept that quality-related activities are initiated,
~
performed, reviewed, and documented in the proper sequence. This concept of system control is inherent in the regulatory requirements and provides assurance that quality-related activities are adquately planned, per-formed as prescribed, reviewed and approved at the appropriate level, and documented, providing evidence of system continuity. It is further recommended that system flow diagrams be used to depict the sequence of activities as an aid to conveying system concepts to personnel. This would greatly enhance STP-QA program implementation, and serve as an I
5
I I effective tool for analyzing systems for continuity and to provide managers and supervisors with a convenient means for controlling activities.
I AUDIT SYSTEM. It is recommended that the B&R audit system incorporate distribution of audit reports to management at least two-levels above the manager of the area audited in order to give proper visibility to audit results. It is further recommended that the close-out of HL&P audit findings include verification of corrective action, including a reexamination of the area to determine current control. Greater atten-tion should be given to the selection, training, and qualification of auditors and lead auditors for both HL&P and B&R. Particular emphasis should be placed on maintaining accurate qualification records which document the basis on which qualification is determined. More effective I use of the audit " trend analysis" results can be realized by distribution j
1 to functional organizations to permit prompt response to generic problems.
l MANAGEMENT INVOLVEMENT. It is recommended that both HL&P and B&R manage-ment take immediate steps to demonstrate their commitment to quality )
performance and their unequivocal support of the STP-QA program. No amount of corrective action to the individual findings will have a I lasting effect unless HL&P management adopts and promulgates a " quality first" philosphy, with only the safety of the work force having a higher
{
I priority.
The " quality first" philosophy must be supported in both organizations by day-to-day operating policy which does not compromise quality objec-tives nor accepts less than quality performance at all levels. Strong quality-oriented functional leadership must be provided to the project; l the quality functions of HL&P ano B&R must be strengthened; and a con-tinuing program of quality awareness / quality attitude must be initiated.
1 \
E \
i i I
6
ww
[
{ It is further recommended that the QA organizations be revamped to over-come noted weaknesses and to ensure that an aggressive QA function is carried out by qualified professionals in sufficient number to accomplish tae tasks. Further, the respective QA functions of HL&P and B&R should be examined to ensure independent yet complimentary QA practices.
It is recommended that a management information system and a closed-loop management corrective action system be initiated for the purpose of advising HL&P and B&R management of conditions adverse to quality, and for ensuring that timely corrective action is taken. l l
l With HL&P cognizance, it is recommended that B&R management initiate a
{
system of periodic management reviews wherein each functional group, engineering, procurement, construction, quality assurance / quality con-
[ trol, and project management, would review progress, problems, and plans. This review should be planned and scheduled and provide for
[ action items to be completed within an appropriate time frame. This formal review mechanism ensures that management attention is focused on
( significant problems and that timely corrective action is taken.
[
[
[
[
[
[
[ '
[
7
[. . .
_ _ _ _ _ _ _ _ l
L L l PART III
{
TYPICAL INDUSTRY PRACTICE
[
Quality assurance practices applied to the nuclear industry today are a blend of the experiences gained from various industrial and governmental agency practices that have evolved over the years. In a successful QA
( program, it is a management system entailing the planning, control, review, and documentation that has been designed to ensure the required
{ quality and effective performance. The narrative that follows describes some of the practices employed on other nuclear projects that may be helpful in resolving the findings identified under the six " root causes" of this audit report.
[ PROGRAM POLICIES AND PROCEDURES
[ Typical industry practice in the area of QA program development involves a multilayered document approach, ranging from broad general policies at
{ the top, which are implemented into specific, comprehensive procedures, specifications, and inspection plans at the working level, and constitutes the total quality system on the project. Several firms use an overall
{
QA program matrix which shows, by specific paragraph reference, where in the lower-tier implementing procedures the higher-tier QA program require-ments are met. This is a convenient tool for program maintenance, indoctrination and training, and audit planning. A typical matrix is provided in Figure 1.
The QA program matrix technique simplifies the task of assessing the effect of change in program requirements or policies on implementing procedures, and provides a convenient means of tracking procedural modifications Mcessitated by such changes.
I L
Implementing procedures are prepared by the organization responsible for f the work, and, to the greatest possible extent, they are prepared at the 4
m 8
{ point of use in order to reflect usual and typical practice. QA review and approval of procedures ensures that quality program requirements are met but without restricting usual practices which have proven to be
{ effective. Some firms make extensive use of system flow diagrams to enhance the communication to those who are to perform the tasks, and as a means of minimizing overcommitment and ensuring continuity.
INDOCTRINATION AND TRAINING / PERSONNEL QUALIFICATIONS
[
Industry practice in the area of indoctrination and training programs
{ varies from structured, formal programs for the quality orientation and indoctrination of personnel to the informal functional on-the-job training provided by supervisors and/or experienced personnel. In recent years, "outside" sources for specialized nuclear training have found increasing application by the industry. Among these sources are the professional and code societies such as ASQC, AWS, ASME, and SNT, the Portland Cement Association, some colleges and universities, and b certain major suppliers and contractors. Typically, the thrust of "outside" courses is a specific technical skill, technique, or subject
{ of common interest or for which there is a need for uniform practice.
{ Training efforts by the industry are usually based on the concept that personnel assigned to projects possess the requisite training and quali-fications for their job assignment and that any training provided is "as necessary" for the purpose of conveying knowledge or developing skills peculiar to nuclear work, or for meeting special nuclear-related qual-ification criteria.
On-the-job training receives heavy emphasis in the typical training program with the structured, formal techniques used for topics having
{ wide application or for speciali7ad functional training. On-the-job training, including required reading lists, information booklets or flyers, and self-learning programs, places responsibility for training and refresher training, and day-to-day performance, on the supervisor.
[
r 9 -
L .
\
Formal techniques, such as lectures, multimedia presentations, seminars, and workshops, are commonly scheduled, conducted, and documented by a ,
department or project training function.
While various techniques and training methodologies may be applied, training objectives commonly relate to regulatory requirements, code applications. procedural details, and special processes. For the
.. quality functions, training objectives are related to the special tech-niques of inspection, nondestructive examinations, test procedures, and auditing.
The qualification requirements for personnel designated to perform in these specialized aren and the means for certifying them are defined in the applicable codes and standards documents (ASME, ANSI, SNT, etc.).
While some latitude is permitted by the standards, recent NRC audits have disclosed that some firms have not developed suitable written
[ justifications on a case-by-case basis when they elect to certify per-sonnel who have lesser qualifications than the standards specify. With
( the importance of utilizing only competent personnel in these areas, the need to fully comply with these requirements can't be overstated.
DOCUMENTATION / ANALYSIS OF DEFECTS The determination of the conformance of material, structures, equipment, and systems in place is based on objective evidence; that is, records .
and documents which attest to quality. Such objective evidence is 1 I
h required by regulations and generally accepted by the industry as
" proof" that contractual obligations have been met. Without objective evidence of quality, the conformance of the work with requirements and the acceptability of that work for its intended use is indeterninate.
The need for traceability of records to design criteria and the need for ready access of data has prompted some firms to implement data management systems to ensure initiation, completion, and control of quality verifi-cation records, and to ensure that such records are maintained and are p 10
[. _ _ .
+-
l l readily retrievable. Such systems use computer programs based on unique I systems numbers which identify what records are required, what records are complete, and where records are maintained.
I Quality verification records serve a purpose almost as significant as their value as " proof." The analysis of r.: ords to determine the cause of defects and generic deficiencies supports the closed-loop system of control and corrective action. While actual practice may vary, defects are coded to facilitate grouping by process, system, defect type, and responsibility. The resulting data are then analyzed so that appropriate action can be taken to correct the root cause of identified trends.
Furthermore, some firms provide for the analysis of trends in the quality systems by the classification of deficiencies found by audits of those I systems. The correction of repetitive system deficiencies is more cost effective than the correction of defects and unsatisfactory trends associated with fabrication and installation. For instance, the cor-rection of repetitive deficiencies in the qualification of welders is more cost effective than the repair or rework of welding defects.
Firms performing trend analyses employ a means of disseminating the data to those responsible, and for effecting appropriate corrective action.
Information gained from other sources, particularly where supplier performance is concerned, is also disseminated to those responsible with the provision that feed-back be accomplished in a timely fashion.
I Flyers, bulletins, and problem alerts are among the means used to dis-seminate data and provide for close-loop feedback and corrective action.
Defect analysis usually involves a mechanism for alerting management to matters potentially reportable to the NRC under the provisions of 50.55(e) and Part 21, and for the review and analysis of these problems for reporting purposes. Because of the significance of a failure to report, the mechanism employed typically provides for problem riview at several levels with determination of reportability by a committee and with actual reporting by management. A problem review committee func-tions much in the same way as the STP Incident Review Committee, except that a decision as to what will be reviewed by the committee is not made by a single individual.
11
E I
I SYSTEM CONTROLS I While the concept of control is inherent in the regulatory criteria and in program policies, various methods are used to monitor progress and document the status of activities affecting quality. Special purpose forms, logs, registers, and " stamps" are commonly used to provide the I closed loop feedback necessary to ensure that controls are consistently l applied.
System controls consist of those actions by designated responsible persons which identify acceptable performance compared with a previously determined standard, monitor continued performance to maintain accept-ability, and record the status of the accomplishment of activities.
As intended by the regulatory criteria, system control is typically the I responsibility of the organization performing the work with actual control exercised by designated individuals with the necessary authority to accept, reject, and/or resolve discrepencies. Logs, registers, and forms are used as a convenient means of tracking system controls and to provide visual confirmation of their application. For irstance, drawing registers provide visual evidence of the status of the design, while drawing review forms document the proper review and resolution of con-flicts by responsible persons. "Open items" lists, correspondence logs, NCR logs, and inspection logs are among the devices used to track actions and ensure timely close-out.
System control practices generally include a closed-loop system of corrective action involving appropriate management levels which track action from the point of problem identification through analysis of cause and effect, action implementation, and follow-up and close-out (see Figure 2). Management involvement ,in this system ensures visibil-ity of the appropriate managerial level to generic problems for which their attention and control is warranted.
I I 12
l l
l AUDIT SYSTEMS I Systems of QA audits employed by the industry are generally consistent in terms of purpose, intent, frequency, and use of results, due in large part to the general acceptance of the requirements of ANSI N45.2.12 as the basis for those systems. Accordingly, audit systems are recognized as the primary tool for verifying that the quality-related activities comply with policy, and that implementing procedures are effectively providing planned quality results.
I L
Audit systems provide for a planned series of regular audits over the
{ lifetime of the system elements, and for special audits of selected system elements when conditions dictate. Audit schedules reflect peri-odic examination of all system elements and provide for timely audits as L project activity progresses.
I L Projects of the size and scope of STP are. generally subjected to audit programs by both the owner and by the A-E/ constructor. These audit programs are independent of each other, although the same elements are examined. Although the A-E/ constructor has primary responsibility for audits of subcontractors and suppliers, the audits may provide for owner participation or observation.
E Audits provide for the examination and evaluation of objective evidence m by means of checklists prepared either for the audit or based on generic b checklists prepared for use during the planning of the overall audit system at the outset of the project.
L Audit results are documented and reported to a management level sufficient to ensure their visibility. Audit findings are documented, using a self-closing form which identifies the discrepant condition, recommended action, the actual actions taken, and the steps used to verify and evaluate corrective action.
w
~
13
E
[-
Several firms in the industry have developed training programs to
{
prepare auditors and lead auditors to effectively implement the audit system. Where in-house training is impractical, "outside" resources are used which emphasize auditing principles and effective practices rather than specific audit procedures.
( MANAGEMENT INVOLVEMENT
{ This element has received considerable attention throughout industry, government, and academia. Today the science of management is often referred to as " organization effectiveness" and includes the sum total of the company's efforts in terms of program, people, and productivity.
It includes the tools of plans, policies, and procedures and involves various management information systems for evaluating the status and adequacy of projects.
The direct personal involvement of top management in the formulation of
( a QA Policy Statement which states the corporate commitment to the quality assurance program and demands compliance from all who work on
{
the project is essential to its success. This QA Policy Statement is often in the form of a Management memo to all employees from a Senior Executive.
Various tools are used by management to ensure their involvement to an appropriate level and as needs dictate. Project organizations are structured with the necessary degree of independence of the quality
[ functions from operational functions; quality functions are provided with strong professional leadership having the " ear" and respect of
( functional managers; quality functions are adequately staffed by trained and qualified personnel; and program manuals and implementing procedures which adequately reflect quality policy are sanctioned and authorized
{
for use by a senior level functional manager. Furthermore, organizational 7
lines of communication permit day-to-day contact with interface functions and for prompt resolution of quality problems at the functional level, J while scheduled management reviews of program status and adequacy are t
14
I I conducted with prompt management attention and follow-up given to problem areas. These management reviews often provide for regular QA ;
presentations on program status and significant quality problems, as a <
l means of furnishing management with the information they need to I maintain involvement. )
The QA departments typically prepare monthly and/or quarterly reports to management which not only summarize their activities but provide manage- )
ment with an " overview" of the progress of quality systems on a regular basis. l I
I I
I l I 1
!I I
I I
l I
15
m 1 5 rm r -Q \ > t rm > w t i t i t w \ r u- > \ rm rm i .t .
1 W FIGURE 1 8 Pages '
L. ;
REQUIREMENTS MATRIX I 10 CFR 50 APPENOIX 8 A NUCLE AA QUALITY ASSURANCE p.ANUAL cam . tester i
secreas e e > . . i . .
se ctice s
. . . . . ..iiniii. i
] i
.strise u se ctiss ue
. . . . , ..u , , . .
settece sv
. . , . . i. nn , , , .
sectiea v
. . , . . i.
A nu nieio .-.e .
sacrece rs
, , i i . e.e. se ee s . -e ... . . %L T :
e o e. e . se.e e... e d e e. . ae.
8 ed._ . _, eesome.e is. es., e e e. . * * * * * * * * * * * *
, .t a a
)
a no . . .ee-a. e ,e,.e,me. e.e '
esed e,- . ,
E r
i Desumene she gueen, reysm enn ennoe. peks.ee, G G p O posesses. es estrecesens G g e 9 9' 2 tdeasif, the serscewes. e,peme sad tempements to be k
me.wn,me es.e,.e-o . , ,em dme.. . e apperete quehey reg.nements y
n i idoned, she moser ergen.ma as poet.c. pes.ag m she payee tegeeho engt then lenskens. , O O ll
. . e..e e e e. e d a e j . .
m . a . is, es .se - .wi. e.d is, 3
- a. es. a n, -e a. d is.s e e e e
. a . ee.e. es.a g e e. . . e e
7 Re.de for segweer - -remen el see pesus et he payee 9 Ireneless seguester, geg.womente W eh Geogs bee.e g g ,
s se dos.es va %Ma 2 inceede oppepees eusen, steade.de sad demonen seawees se the deogn doce eaes se omwe ik seert.ea 9 9 4 9 9 et sweabee mee-eas, parts ses.emene and potenes til i beme dee.ga meeleca ceouses e 9 e
. ,ortem odependent eer.fasasea ef esaga .stehoe e e e ech.de, esperene een ge esd.casen preyams
. Seteest domen shenges se the some conw.e as mee aophed to she e.g.nes denen I m o teoo m o e se
L l ~
_ a
. g -
3 -
[ *
=
2 e e L -
E r ; -
z -
{
- e
[
= e e e
- e
=
._o e ! e e i
- l l mt= . i e
- 7-~ e , , ,
I I a s
- e e e e 1 e g - . . . .
e W
I q
1-e e i .
l l 2 e 4 g <-
< :_!= -
t
- :it-e 4 *:- !
_o e e g i- ! e e ,4
- !
- e
.e !~ i i e e
- - 1 i i i it 12 4 g ,- ,
z -
[
i
! e i..-
g
{. "
'2 i
[
_ p __ _ ._ _ _ _ _ . . __ _.
{ ;
_A 9 .
3 .
[ .
N i !
e -- _ - . -- t
~
~ 'siE3iNO3 do 319 7
[ ri ! o it,j si I g
i hei 'ls g, l
! ,![ .i ilo I tl i>t;. >I e il n, te
=
- r i i
3 a u '
t !"i t it i ii si ! vi
. I Ij p I a
- i ! I s i m t- l- ji i !i t i 0 it i; lI il !! =!u[
i
[ s
~
h'! !i: II il ill l
1;l oO ii ! i
'p !!< j! It ji }h
.l.
114 .i. i; 13 :i ili .i E i H 1: ![ i; i !! si ip> in ij 16 11
.> n j!! u]. 3, i.i i .s : 2l ii, i. n 3
set 31 i 2! p11
- 1...I li i
.iI } 211 21 11 <e
( _ - - . . - ~ _ - _ _ e > > > - - -
, 3 i 17
L
. - I
[
- s 7
=
5 . . . . . . _ . _ . _ . _ . . ._ . _ . _ - _._ .._ 3 ", ,_ . . . . _ .. . .O . ._O_.. . . . .. . _ . _.
- O
.f__ .__..J..-_.._ _.___.}.
[ _ _ . _ ._ _- i _. _.4_ _ _2_ _.__-- 1_ . . _ . _ . 8. - _.___ - . - _ _ __- 4' . _ . 4.-
- -{ .-_ y I
.1I -
$ .. .. i._ . . l_ _.l..- ! ___.I. .
___1 -- j_.._ _ '_ O _.. . - - . . _ _ _ . - _ - _ . . - -. - - - _ - . _ .- { [. g_ el. - - b L' .1. y _._ _ '
- 1
-~ ~ ~
. i i i
__,1_. .
. _ . ; . . . { __ ..I __d I L
__ [ _ . _ _ __ _ __;_ _. 4 4- . y .. , l
. _ __ __.. __ . ._ - . . . ._ y j '
' * ~
! y
[g e i i e i 6 I j -~ i I L ! l i ! {- _ . _ . _ _ _ . _ _ _ __ ___.y_ ! __q___.___ , s Ei. - ' ~T- - - i l l l !
$ 5!* O _ ; . i t a i .
$ l* I _
l i I i 1, tai e i i e I . . _ _ _ _ _.. . _ . . _ . . .. I I !
] ___
[ <
$h I
'~
i I i I i 1 8 i gy .. _ _ _ _ _.
> 81 l C Ei. .
E 5.= , . E 3 e ,
= ! ! ! e i 4 - 4 I . I j ;
3 I ~~- T i ! ; l i i i- - i i l i 4- j e i i t -- t-- - i , , , I
~
I ! ! i , i i i l 1
** I 8 i
l
, i d 4 i O '
~
I E [ ; 2
=
[ .
e e *
.[ 5 5 E !
u x x x y g 18
I l
g.
g I
=
1 3 "- t e i f 8
! I t I ! 9 8 ' ! ! ! a t f 1
- i . i i t i i i i i i i i i i i i i i i I <
2 2 O e ei Or . r ~I . E E I r - y- r E1 t r t Trr r t
' i i
i i i I i ! i !
- i i i t.f r-r E r I n u I t w f $F- r1T us r -
t t 6 i i i i i . I i e et i i i I i I 4 i 6 i 6 I e i 1 I i ! I t I ! i i . i i
- i t i t 6 I
t I t t t t I f ! ! ! ! I ' ! ! ! ! ' t ! i ! $
! ! t i ' t ! ! l ! '
2 i i iii i i i i i i i i i I i i i i iel I i i i i l i i i i i i i i i i i i i
* . (
i f a
- r - ,
I l
- I I I I I i 1 i ! ! l ! ! ! ! !
I I I ! !o ! I t t I !
= l i i i i i i t i 1 4 i i i i 6 6 i i I e i i i i i i
. lI l- h- i1. -i. !i l l [ ] ,[-l t l l-l. Jl l l- l l l J [ l l i l l pg [- l . l - l }
a
! ! ! I t ! t i I ! ! ! I I i ! ! !
! i t t I t t ! !
4 I 6 i i i i i i i ) , I i i i i i i I i i i i 1
- t , i ,, ., t, i
, , t, , i , , , , - i r v i e # v i i rr . i
= i i e r i . i , , ; t . , 1 i 1 i : i i , . . 1 - t
- 6 I i i i i i i 6 i e i ! i i ! I. I ! ! i i 6 I ! i i t ! l ! i .! i i i i i i i i i !
LI 2
=
i i i 6 ! I i P 11 I l l-l I l i i i I i i 6 i i i i i i i iiiiiiiiiii I I I I I I I l-I- 1 I- I l' l - l I I i l i l I i i i t
- 6 Cl l 'I i i i i i I - l' I I I E = i i e '
i ! i . i t I ! t i i ! j - 1 i I i 4 i e i i i i i i i i t I i i t i t ! t ! i I 8 I i i i i i i i i t I
! t i i i i e i
! i t ! !
e i i 6 4 I J I
= :l ! t I i i I I I I I I I 1 i i 1 i i i i i 1 1t l' f I4-I I I -l I I I I
- f ? '
I s i f ? I t ! ' l l l 1 ! i 8 i a
- i i ! ! I i I i ! . I I i i ! ! l ! ! ! I i y - I i 6 iT I ! i i i i i i e i # i i i i i 2 a i-1 I I> ! l1 I ! FI I I l 1 I-I 1 1 1 I I I I ! li l I I-I I I I I L L I-I I i + 1 < I.
I z - e i i ; , i , ! . . i , ! i i i i i i i , i i e i i e i e i e i t i i i . . . . i i w : i 2 I i i I I i
, . . . . . . . 9 . . . , i e i . . . e e. . . . . .
M ! I f I I t I 1 1 I I I I I l l I I I I I I I I I I I I I t -1 I I I i 1 1 4 . , .i .,, .
.e e e . . .
E s a i -
> 3
- i
* , ! l
! ! 1 . ! ! I ' ' ' i
- I t i e ! lej i t t '
< a
! ! ! t ! I i i i ! t i i ! 6 ! . ! i i ! 1 1 i e, f '
- I ! 4! ! ! ?
e t'~e7,1i I foi ei i ! ! i i e g - i i , , i i , i i i . i i i , i i i , i , , i e i , ie; i , i , i . I g t i I I I I I I I t i I I I I I I I I I I I I I I I I I I I I t ! I I t i I I I I I I I
< = , 1 i , , . . , : e. , i i . , , i i i . , , i i
= - i
. 1 i !1 ! i ! .
i e i i , , , i i!ii! i e i !i , + ,.i e
- i e i i . . .i .L. .ie 4 i ; . ! ! . : ! l ! ! i 6 ! i I i i i i i i g i . 4 i i i i i , , i . .
z * - l i I i f I I I I I I I I Il I i i l I I I I I I I f I I I I I I l t i i i 1- I'I I I I I
) . . t i i . ! ; e!.;e.et #io > l ;ei e;et , i i i
. ! i 21! ia i i + i I
. . i ' !
J
- i
. 6 i _jee 1 : i _ el,_
o# ,a
- eie4e.7'*I*!eUe:
- eg i ! ! io!e f ' '
! ! ' i -
i e !
! ! ; r i i .. 1 i ! i , . .! . . i e i !
a 1 i i i s ei~eTefe t .
.ej
~ T' ?
ice i !
; i i I i i i g: i i' i l e ice i i l j i i 1 I I I I I i i . i
~
s i i 7ef t eM e~ i ; * , eM i e i i i i i t i . i I I I I I I i l i i 1 I I I I I I I I I f 6 I I t I I f I I I f I f f I I e I 4, _r 4, i i i i e r i i i , , . . .
- i ! i re, . i i i .t , , i i ! i , j i , , , ! i , 6 , . , , , , i e E :
I l l 1 I l l I I I I i I i i i I I i i I i l i I I l l 1 l 1 l I I I I l 'l -l I 1 I -l i I
; . e ! !
, i < ,
2 i i i ! I i . I ! ! ' ! ' ! t !
. ' i i i i ! !
- i i !
I i ! I ! ! . l
! ! i l 8
l 8 i i i ! I
' i l l 8 I i I ? ' e i I
- i I i i i i ! I i i ! I I I f ! I ! i ! I i I i e
! 1 i i ! 4
!! t i i i ' i i i ! l ! ' i ! i i i i i ! i ! i i l '
! I i e i I '
p2 = ! e ! ! i e i i ! i i i 1 ! i i i i , i e i i i i e i e i
- i t f I t i i i e i +
i i i i i ! i i i ! ! ! i e e e
. . . ! i ? t i i i ,
, i i e i ! 4 ,
. e a i j i 4 i 1 .
I i ! ! I i I ! ! I I ! ! + i i ! ! ' ' f I t I , i i i i a s e a i l l i t i ! ' i ' ' i i :et '
+
L L, L L, i i i i r i 4
> i i 6 I !
', I a
* ' . i i .
! ! t t i !
. i ! 5
*
- j
} l { ! { l i I i j i t i j ! ~j i i ! f 4
' t 1 a t
*
- i I
i : I ! i i I I ' 8
' ! I ! I ' I I I I f I I i
-1! i i ! i
< 35 i
! i !
- i i a i i i i i i i . ! ! I i + i ! ! i i i !
i i l l 4 l i i i i t i i i i i e i I , I I I l i i i i l i i i I w f f a g o 1 I I 3' l r 4 - t i
! ;"I
[l l 8 , ". . = l .
!! .P .;
E j 3 t s
$$ }
] i E,E l I
1 '8 3 e 3 l I8 ' z ' l . i I I si bl a - a J ,1 8 ={ %'"I
*2
#- 3: 'f M 3.,1 I ri} l i
i III ' = I IEI i 3 I l i M' s j a' j C3 3 :
<f r g s iil t p i}j,WINp i 35 ' !I. ru 'I' s t- iC h] iO i i
' } r s;Mdi i j lA 0il i ll'l j. j i b_gildi}pi i i _ilfl ,il .t i .f.i. i. ". .t j .!.Il}.!1l!.l}ij j i.lj! l, ,l _i,; h.i I E B
l
.j. .
_ . 1.4_
- l-: :, :- :
2
- : : . ,. i : : : . . . . :- : 5 5 :y :: .,; : q. l:;
I g m-,-~,_o e- m e~, 19
. . 1 1
- s t
' i j
l
) =
I I i a I i a ' .I f _L I i !
. . ;3 e '
i i i e ! ! ' i * . s
. 6 i i i i I . , 1 -
. . i i 6 a 4 g i l t , i j . 4 1 t ! e
! !
- i e a e * .
t t i e
! i * ' i ! f i
- ! , I i . .1_ I e
! i fI f i i i ! . ..!! i I ! !
; : . .y Q ' ' '
i . -
- . i i i ! . i , .. . , i i i .. - - - ,
< =TTI. I. I if 2T ~l I i i t i i I 1 l_ZT "I I I ! I i I Ti i ! ! TT I
- i. > >i ._q_ i i , ,
- r i ! # '
i !
. i . i
!! ,' i + ' i
. . i i ! i i , i i i , ,
! - 6 I I ! ' I I I # 1 ! 6 i i
! - 1 I ! i i ! i '
i i i i . . 5 - l 1 t } ? l l l l i f f I 3
. , , i , , .. i 4
! ! i , e i ,
. i i. i i i , i i i i e i i i
. e i i i i
, i e i i i i . . . ...
. . . i .
- I I I I I i i i i ! j i'I .
I I i i I i
! I I I i i ! I I I I i I i I I I I
. . 4 . . . i , , ,
I I
= . . . , i
! i i ! . i i I f I J l 6 a I i 1 6 ! I I i i t j ! ! ! 1 ! l i e i i ! i 1 4 i I , I
; .._;.1 +i i 1 1
- e i ... . , i i
- i. 4 i i f .
E ... i , . . , i . i t l . , . i ... i . i i i i . . . i 1 I I i l i l I i i l' I I I I I I I I f I i i i i i l I i i i I i l I i i c . ! i ... t . , i .
. _ i I .I
. . i , i j i i e e r i i i ..i i , i i i i.. . i , i i i . 6 i . i i i J I i i I I i i I i l I I i i i i I I I i 1 I I I I i I I I i i
. , ! i .I. . 1
! i . , i e
! ! i i i i , . , ! i i a . i 1.te 1 ! . i. i i i i l i i f I i ' t ! I i i ! i .2_ i.- ' '
j - i i i i -Ti , i i 6 e i i , i i .' z - 111 l
, t.,..
1
..i...
l l l l i i t i I i [
.i.i.i. .,.......
l l l i i l l l 1 I I I l l t
.i...s.i.. ....... I . ;i .. t . l . } . l .1 . .
1
.! i
. s.. . . ...
y 2 I I I l i i I l I I I i 1 f I I I I I I I I C z
. I .i i e 6 i .
I.I I I I I I I i i I I 1 ~ I i
=
j - g - I i ! t i
* . i i i t I l 8 3 = < _, . . i n <
< a
! _ t i ! t I I i i i ! i i i ' i i . ' -_ '
i e i g - i . ! ! i i e . . , , j i i j i i .
> i i i g
- t I I I I I I I I I I t I i i I I I I I I I I I I i f i I i I i 6 i i ! I I i
., a. i1i l i
w d
=
l I i i i ! l . i . i I j i I . , , I i i i i i ; I 7TDii i i I i i7 . I . , i e I i I . I i i i i i , . 3 = - l1 1 1 1 i i I I I I I I I I I I I I
=
I I I I i I I I I I I I iiI i I I I I 3 1 ! . ! ! * . ! ! i *
* ! . i '
- i i i i i i , i e ,' i r
! I i .
~
i i e g i i i l [ i I i i i ! i i 6 i j i i e i i a
! ! ! i ! i ! ! ! l ! I f i i I ' i i i i ! l ! '
i i ' ! i
! i ! e i e i ! 6 i , e i j { i . i i . i i i i i a e i f I I f f I I I I i i i I I I f I I l l l I I I I ! ' I ! I 6 I i f I i ! i
= . . . . , , ! ! i i i , ! i , , , i i i
.i . i , . > + i !
4
- i !
., ! , i , i , , i , , , . , i , . . . , e i i i . . 1 , 4 , i i i i ,
I I i 1 I I I I I I I I I I I i i iil i i i I I I I I i l I I I I I I I
- ! , ! i i . i i i ,
i , , . 2 i l 3 ! _,__d I l I i 8 8 ' '
-_. I e i .i i , , i i ,' ,
s t .
! i i t , !
I ! i s i
-I. I i .i i i i i ! i i i ! ! ' , . ! i i i e r -
i i , . , i , i i i i
- i i . i i ! .
i e i i 6 i i i ! i i . i i I i t I ! i i ! ' I i
- i I !
I i i ! 1 1 6 I i i ! . ! i
! i I ! ' ! I i
- ! I i ! ! ! I i !
i ! ' i i i i i i i i t i i i
. I i . . i i e i - . . i , i i i 1 l i i ! ' I f + i . t ! t
*
- I t
i ! i I ! i l t I i i i i I i t i l ! . i I c 2 - 3 - i~ i i
' 7~I'; IT I i i j i i [ i17 i i
-$ I i i i i i
i i ; i i i i , i i!! i tr i i i i ! , I i iI Yi i i 171 ii i i i i a eie c e 3 i E i
- o. t !. o -
I 8 e 4
, -[ e a g F
3 h i.
- 1 -5 '
f i
- f. -
P 1 I L - s } } *I s l l
~- ' -
l }i i 1 1 3
=
i j 1 .!
-E.t
! [ -
1 : - r g
.i r -n . f J.
i t s ,= I 2 i a I i i ca E !2 r f J[ o .
=.Ii $ ';
8 >
- g l a r I .ig-ie. 8 e
- .t a. 1 1a ls !
e t [ *v
.i =I l.
3 -
'j .,
]
i
=
3 e t s i t
-y !
t
= t.
r 1 c f i 2 rj
=
t .
. =l-rp e
a
;1 e
- r i
2 3 j u > i - g d g i u t i t . a
- 1 1 t . ( - - - - - ! i s e ar .i -
- p. r '
Y g > g g g g
= w I .;f s3 1 $
i
- .i -
-1 w
. I w a!! aI =h I !'
- a 1 i s a C N O A e N 3 5 d 3 5 5 5 N S , , , , , , , , g ; e e g ; 3 g -
l* lynNVyg (e%44 01 livNu 3119) S3HnO330Wd/NV14 NOll33dSNI 01314 lvnNVW 10W ANO3 g Altivno NOttonb1SNC3 MWO?A NOll3nW1SNO3 . o k 20
[ ..
- . r s
m [ J l - , ,. i ! . . .,,. , ,
! i i 10
- e. . . 4 ,
ici .e. . . i i 6 . ;ei ! . i i i i i ; e. 1 i i i
! t
- i i 2 i i . .
. 'ei r . . ee, ! ,
iot i e. ! ,e. [ < 0 (MEj M - A E EJLi 1
-ei i l L I t iI I I I 4 it1
- o I I I I I i
.e
- 1. 1 I I I e.
L- N I I +E4 PA e%4 hM4 I 1 ; e. +
! i i e:
2 i i i i ~1 i i . , , i i i . , , , , i . . i , . . . . i
> - ! I I ! l l =
l ' [
+ t i j I i a i i I ici i .e. i .ete.
. I i i . . i 6 , e i . i i eie e. .eio;ei isie.e. e l' I I I iI i i i l i i I I I I I i 1 i i i I I i I I I I 1 ! I I I I I I I I I I I I I I I I l- i i .ei e r i .
e, . . . 1 l i i 1 . t i 4 i i i i i i i l I i I . i i i i i i i i 4 i i i i ! I I ! l l I I i i i i
.e_e1 e sie e et e.e e i i , . . , , 4 i i i i i i i
= l l I ' ' I I I i l i i i I ( l I i l i i l i I i i i i I i l i ! l ! I I I i i i l i i i I C --
e .e. , . ,
! *iiiI i I ! I i
! I I I i i i i i I I i I I I ! ! ! ! ! I i i i ! ! l ! ! I i I ! I I I I J e- .e- :e .e-
.* e. io, . i ,
[ 3 i i i i i f i i ! I i i i l I I I I ! I I I I i l ' i i i I i i I ! I i i 1 1 1 1 I I 1 1 l l
'.; e . . i . i . . . i , ,
e i i i i i e i . i m e. a e j ! l ! ! t i. l i I i l 1 ! I i ! ! I i ! I I i ' I I i i l i ! l ! I I i i l l I I I I i i z
- 4 e - -
4
- i i i ! i i i l i I t i
[ ! I l l < 3 1 ! t I i 2 3 - ; y , . . ,
. , i ; ,
j f* i ' t i i i ! ! i ii*
- l i i ! i i t , '
i i ! i i ' i i ! l i ! i 4 I I i
- i i i t i i e i i i !
s 3
- e g . .. .e... ..e ..
e [ < 3 , ' :-_1 i.F i . l l e i . . i i i i I i i , i . , i 3
) I i i e i 6 i l , e i e i . I i 1
n E ~' ' ' e- - - . i ! I i i i e i i ! i 6 7 i , ! ! i i e ! I I I !
= .
I { l i I 6
! r i ! l ! I I I I 1 i 1
- e. *
'[ .t~
)
.p. e e 'e e
8 e e l 6 . i ' i I , I i i I I i , i i e i 4 t i i i i { i l l i i i i a i e i I i i i i [ : E4 ! I i , i , i ! l e i
? . .
i i i i i i i I e i i ! I i i i i i l i ! i i i , i i i i ! j * .9: [ 7 -- _) - a __ t [ eun 1 p __ ._. ____ _ __. _ _. .[ _ 1 i, i 1 - - [ # , iI * [; . I ! ! .i ( a is I' ' 'Jr . a ). .I
; j f. [ [ b! -
)-
r e i j.:i 1 7 5] , ' =} -{#' ,i;:.
. i !'s
-}e t-.J! ..
[
' i 3: g-.Ia g: .l: :*: l32 l: *
!";! ,I 3 1 1}J,: ) I' .}ll-] s t ! g, . l J .13i i s. r[ 1 1 I I. . i ~,a 1 ; .I: : ij} 3 Nr..= ! $ ; f. , r.: . # ,]I!j [ [ ,e: ,.,r, r, 3 i: . l .: bIl j s' E I h f ;1
. 1.
i .8: e ,[} [: i =1 ( .i 3vv .. - y.t -.2.. 3 ..
.g is.
> [ gg-)i ,4 r{ i .;a;,. * ,
r m ,' l .gj oj
- 2,i's a 8 i i-
- : j l'
- .i pf.
[ . .. 4. 1 .1 e-.J. .1 y 1.,J.
-j-g
=. . . . .k . I .t .t .i i . .s gi e... .t.' .< } i .t>e?.s. .
j
! Ei t i. =.> E ::: llll r. :t I
' ! ' ' !j
! I I I 11:I la i! !IIIIi I;i , g g;glg!g g ;2 sir #s;,,,ig;;;l;;;1 ,
- le::: : :::::nl:.: :
s ruo-m msv - ,,tni [ 'vaava vo u mn uthgU,gyg - ,, uaino anan,o so ..nono. ,,nu, n~, nss m,m. un nono i 21 A._ v' im i
, ,, . = , 4-1
. i 3
I I 3; ..
- ~ ~
e ,
, i. i
_ i. e _e i i ! 4 I i. j
, t i t '#
. i t i . 8 ?
,1 i i i .
i i t i ! i i ! 4, i I :
._Li -t I I !l l s
_.L_L ___J l i i ete i , T- --f nT _LT r ! T- _1 -~~~ 'I i i i
.t.e I
, . _ -f . ei t
i,}s n e i i i i i t . 5 !! Y M -t t- l . ll -Yel i ! " i l
; !I,, #
!i!! l ll! ll,l p.
l 3 I
! 1 J _J J i
6 i i ! - ' i ii e i. i I i l 1 ! i . i t
. . ' . . eeo _.
ei leie.eie. i -4.*J_ e i!
- I i ,' i'* '*' l ; l,!! ,!
[ l .
- 1 I I I l-l I I I I L i l i I I I I I I I f I I I I I I I I I I I I I ! .I
! I a
1 i l I 1 8 t 1 ' I i ! I ' ! ' ' ' f '
- i , i i i i , . . 6 6 i . . '
! i ' ' ' '
. g ; 4 I i I i I f I ' ' ,
i 4 ( l ] ! I i ! I I I ! ! ' I ' ! ' .
~
3 ,
, . i i f.
, .'i 2
..~' 'Le j l i I ! ' ' ' ! '
. i , i j i i ; i i i i . .
'ei i i i i i ' l '
' 3 l l [ I i i f 1 l l I I I I I I I I I I I I I
. , i , i , , . : , , , i . . - -
I l I l _ l I I I I I
, ; ; i i i , , i i i i I
i
. 1 i i i i i i ! !
i i e' ! ! 4! f ,.. l, l l 1 1 1 i i i i I I I i I i t i i i i i l I I I I I I I I I i i I I I I i '
! , i i i i i e , r i i 1 2 1 1 t i ! ! t f s .
i; ji i, ! - l Jl ! I , i; i i t i 1 ! I i * ! i ! ' q , i i i 1 e i 6 i i i
! I i i i
!.t': I ! I 5 # I l 1 l [ t i I I i I ~1 1 I I I I I j . , , i ,
I I i i I I I I i i i I I I I I ! ' I i i ,
. . . . i i i e i i i . i i
- i i ' ' ' ' ' '
. : , . , , i '
. 1 t ! i i ! f e' ' t - ' I si 3 , i , I ! i i .
! i i ! i ! i ' i i ! i i ! '
q ; i
' i ' ! ! ' ' ! '
, i i , i , 4
.e. i i i i i ' I 8 s -
u s b *-
. . . ! i
_L
+#- ! le. !
le>
, =
1 : i ? f
- i :. i i e i i i , i . . l . ies t ! I i ' '
g ; ,i ei ii t1 i,I i, ti fitif fi Ii i i i I I , i ; i , , i
.et i . -
e e #'e's ft ,- I i f I I I ! 7 ! 8 I i 8 ' ' ' I I I ' l 3 I I ' I r 1
; :__; _9__ y._ -y j %
7 . 4 - iU = I i f I I I I I I fl!!! l I l I I I I l I
! < I N i-I I I I I i !
7 i i i ~T ll1 l I i 7 i i I I I I I i l l I I I I I I 4 ' ' I k ' ' l ' ' I ' ' 3 i i ,- I i _i i
-N i i ,
_,i l ! i. !
, i
, i 1 : 1 i ,_ . t i e i i i e :
i ! i '
,,- Yi ! I g,,
I I ! I i 4 I
; ! I ! i i I I i ! I I ! I
, , , . . i i i . . i i .' i ! i i i i i i. i >
# ; I I I I i t i i i I f I i i i i I I I i f I I I I f I I I I ' I i 3 I I 1 i i , 6 i ; i e a e 8 i ' i
~ , i i i i i ~ .' i i e ,
s
! 8 t t t 8 i !
e i . . . i i e
! ! ! ' 4 i ! '
, iii i i I I_
I 1 1 1 6 I I i I I i ii I i I I I I I I I I I I 3 i i r i
+
r
^ !
- i-+* : ! ' ;' , i j _
i ; i . I i i l i * ' J . 1 I
. I f j i '
! ' i
- - g a
l i h I i f ! _ a, e i i , i r_i_ i
. j i t i _ ,e f f I f i ! I 1
_: i I I 1 i i i i ' ' l ' 3 d - _ L._. __ _ - I ~ l[
~
I
, i j
g. i
; --t - ;
i 1! I .i t i i
! rt _
- a. ", 3 -
i I i.
=
- 1 I
I8 3 I .
- I i $ l' .
$ i J :i v y }
6 3 3 i ; l e
' i a 3
=
8
)- y -( ~t i
s s I r . I s 2
=
I i.. .
.g
- Ia 3 ; ' , 3 s a .
.i j I.
1 1 a s r { e- r = J 2 :g ;
.i ; e ; (e c
- al "'t i 1 1 1n8f s f "l *
, 1
. i_ , i. _. g *; I. .I.,
1 2 - > < ' E _- _s .a .l.! ."-... a 3 a
* ' " i i 1- i i t ti i I
i <13 2 i } ". t !3
- t t s y a ! !
.! ': .! } i e ;i 1 [ i i.. ,rJ,ij i
3 1 3 d i ! ! J J a i !E } o 3 a 3 2 4 2 3 a .
.: 2 s t is 8 . - . e = = :
_ - . . - - e a s . :
. . . . .= .= . . .c .e . .e 3 3 3 3 ) : : :
- - - - -l t
3 2lI,II I I s lynNYW IN 3 W1Hyd10 1vnNvn 53anc330ug <j lvnNvn lvnNvn l 33NvunSSV AltivnO All1VnD WillednS Ad30 1N3WJHn3CWd WANO3 7,nsyn 8 8 IN1W3Hn308d IN3W3e030Hd 013f 3 8q9 DNISYH3 Mod 3 l 22 _ . a I
I . - g . I F r M $ 9
- . i e i .
1 ! I
. . 4 .
2 .
- i e ei
; .eio:eie . i e 4 = mww t .r 1 4 I1 I
- i . . ! e i i !
'* I i i i i 3 J .,
. . I i
. i i i I -
M
=
f I ,i{ i i-t t i i i
-l -
l i h I I i I "C t
- I 3 i i e I i
. 1 I I I I I lt 2 . . . , i , e ,
i - . i i ! I i j I
. - I I I I i i 1 i s . i i i i t I j = i i z . ,
1 I l 1 { I I
$ - . . i
- i !
I w # t 1 1 5 8 I
< . i ,e.
E z .
~ < j =
2 . i
. i $ - i i i , !
g - i i . g I I I I I I I I I I < I 3 . . , , I t i g . . 2 8 'l I I I I I I I i .i e i i b,* ' I
, i
. i . .
= : 6 L 1 I I I I I I I i z e- ' ' '
; t !
2 I l t i I I i 1 1 u I
. . i i i I - . i . i . .
3 . , , , 9 i i f M l I I I 0 f a i 1
- e i
* . , i 1- , < , , < l I 43 = ! i
- 1 i i i
! > I l i i
i; l ll I
; I I
I y,
- I '
e i 3 - l s I
.O 8s C cl . E 6
} ,
3l. 1'11. jll2 l T3l1: l . 8 l l f $1 f*! !j- {
= .!-
}i .. . . ! jj b1. t .g,..
w>w
=
I e l'.i, jillI;I' , ii 2 J JE i; w- -
< =,a:. . . 3
> o -r- - - . m ~ . E i O e 4 -
- l 4 4a 53vo033Owd 1430 533
- ^wis Ninov l l 3
i 23 l
l FIGURE 2 CORRECTIVE ACTION FLOW DIAGRAM IDENTIFICATION AGREEMENT ON ACTION ACTION CLOSE OUT tronasAu AUDETOR - AUOtTEE AUOl'On - AUDETEE AUDtTEE PRootEM DisCOvf Rv
. Auosi "=+ Follow ur
. NsrECreON
- Review @ ,,,,,,,
g W REVsEw Oax:TivE eNVESTIGATE m-$ $ PROSLEM + OUALITY b swVENTE @ g VAjlD TE @ EV O NCE 5 ' REMEDIAL
- I PRESENTATION @ ACTION VE,ggy DETERMINE Q' Q-'
- r-- DOCU.
PRO uMMENT g ExTEw @ + + . ," "" a ag,Egal N9 Y h Ds3CussaOff M CORF.E CTIVE , Sb I DETERMINE TON ' Saess.m EVALUATION gAusg
-' I E VEhlFY I
I 5 5 DOCUMENT AGREEMENT TO h ( g CURRENT CONTROL + VE R8FY CORRECTIVE ACT000s I DOCUMENT AprRAISE e ACTIOy PROVIDE DOCUMENT I RECOMe8 ENDED - CONSEQUENCE e ASSIGJ.AsENT OEuf CTIVE ACTUAL @d , (e D E ACTbON 4NCLUDING & $4GNIFICANCE e COMPLETION OUALITV mRRECTIVE I I e INVESTIGATION e REMEDI AL h DATg h EVIDENCE h ACTM)N Q' I I 8
- CORRECTIVE ! l I k CLOSE OUT@ 3
.e s I
8 I DiscusssON ANO i bas =>! TENTATIVE l f l AGREEMENT 3 g d i e
L [ { PART IV [ DISCUSSION OF STP-QA ORGANIZATION OPTIONS [ At HL&P's request, an evaluation of alternative QA organizational arrangements proposed for the South Texas Project by the NRC has been h completed. In addition, in response to HL&P's request, recommendations on qualification criteria for quality personnel, functions, and responsi- { bilities of key QA and QC personnel, staffing levels, and salary levels found elsewhere in industry are provided. [ Subsequently, Bechtel QA management proposed a sixth option of QA orga-nization for the South Texas Project. This option is to engage a third party consultant to supplement either HL&P or Brown and Root or both organizations until such time as the required levels of profi-ciencies were achieved. Attachment A discusses the " pros" and " cons" of all six options. { AUT0 NOM 0US ORGANIZATIONS While considering the several alternative organizational options, the concept of autonomous organizations was recommended. Under this " total-quality" approach, all QA and QC functions are placed in a single orga-nizational entity. The QA departments of HL&P and B&R, each organized on a " total quality" basis, would be independent of one another, each reporting to its own management. This would permit management cognizance and participation by both firms. L HL&P QAEs would act as programmatic planners whose primary function I { would be to conceptually guide and monitor B&R discipline QAEs in implementing viable QA policies, procedures, and inspection plans which would be verified by B&R QC2s. This approach retains the programmatic direction with the utility and leaves the technical direction and - implementation with the Constructor. The balance of responsibility is u 25
L .. [ consistent with the overall utility /constructt,r relationship for shared { QA responsibility. [ Proposed organization charts giving representative tasks for these realigned groups were provided with this recommendation. These are presented in sequential order in Attachment 8 and are in sufficient detail to illustrate the concept recommended. [ { PERSONNEL MANAGEMENT TOOLS To further the accomplishment of the functional objectives embodied in the proposed organizational concept, it is recommended that HL&P QA tasks be documented by standardized job descriptions, and that com-petitive corresponding salary ranges be established for QAEs range from i entrylevel classifications up through supervisory / management grades. ( These should be structured carefully to ensure that the proper knowledge, training, expertise, and compensation are provided for each quality-( related job. { .HL&P should first structure their job descriptions to meet their organi-zational needs and then should structure the compensation scale to competitively attract and retain the qualified personnel necessary to perform these QA functions. As a guide to HL&P in planning a compensa-tion scale, a senior level QAE with the appropriate educational back-ground, 10 years' experience, including six on nuclear projects, would attract a salary of $35,000 - $40,000 elsewhere in the industry. [ A senior level QAE, referred to above, would generally possess the ( following qualifications: { o A recognized degree in engineering or scientific discipline. . i o Advance study in engineering or science, or specialized study I in quality, engineering, or nuclear power plant construction. [ 26 .
Approximately 10 years' practical work experience in engineer- { o ing, procurement, construction, and quality disciplines, including 6 years' nuclear project experience. [ The position description should be written to permit management the opportunity to exercise some judgment in selecting a candidate if justifi-caticn can be provided for accepting equivalent qualifications. At the same time, a senior level QAE would demonstrate job knowledge and { proficiency in the following: Technical knowledge in the application of engineering, procure-o ment, or construction practices sufficient to comprehend regulatory reauirements. o Knowledge of quality assurance principles and their application F u to engineering, procurement, and construction. { o Proficiency in oral and written communication. o Knowledge of the application of the corrective action process to nonconforming conditions. o Knowledge of the application of the corrective action process to nonconforming conditions. o Knowledge of regulatory requirements and functions which impact QA activity. [ In general, the senior level QAE would participate in the formulation and implementation of the project quality asserance program, direct the activities of other QAE, as necessary, and have responsibility for one or more of the following activities when assigned by a QA supervisor. Prepare checklists, lead or participate in QA audits. I o 27
I o Monitor project engineering, procurement, and construction quality-related activities. o Review reported nonconformance conditions and monitor corrective I actions. o Review engineering and procurement documents for inclusion of quality-related requirements. o Review project functional precedures for conformance with QA program requirements. Prepare bulletins and problem alerts and follow-up actions, as I o necessary. o Review and report on new or revised regulatcry requirements. o Review, comment on, and monitor quality verification / inspection plans. I o Follow-up and evaluate corrective actions for the adequacy of completed actions. o Maintain effective internal project communications and relation-ships and external contacts with regulatory agencies, contractors, and others, as required. The foregoing is intended to merely suggest an approach which HL&P can use in structuring the QA staff necessary to fulfill the function to be established by the reorganization concept proposed. STAFFING LEVELS .I Maximum constructor manning can normally be expected at about 60-65 percent construction completion. There are some typical ratios among l l 28 l
[ { QAEs, QCEs, and craft manning levels utilized on projects of similar l size and scope. The ratio of QAEs to QCEs is usually about 1:6 and that between QCEs to the crafts about 1:20. The QAE to QCE ratio may not be { l appropriate for the South Texas Project at this point because of the greate,r emphasis to be placed on QA program development and renovation [ than is normally the case. [ Utility QA manning is normally limited to management control and overview functions, such as surveillance and audit. A typical ratio of utility [ QA personnel to constructor QA/QC totals is about 1:10. Again, because of QA program development and renovation coupled with HL&P's desire to provide closer surveillance over Brown & Root program implementation { until a basis for confidence in the Constructor's ability to implement this program is established, the ratio will undoubtedly be lower on the South Texas Project. In summary, the HL&P QA organization should provide broad guidance for l B&R to implement. Both companies should have autonomous QA organiza- ) ( tions to permit smooth implementation of complementary quality assurance activities. HL&P should review its job descriptions to match the tasks { required to fulfill its quality responsibility; and equitable salary and I benefit plans should be maintained to attract and retain qualified personnel. These actions, when undertaken 'and supported by Management, { should better equip all personnel to perform the quality-related tasks to attain STP-QA program objectives, and should foster greater confidence in HL&P's and B&R's capability to manage the STP-QA program. Finally, the organizational concept identified as Option A in Attachment A to this report will best serve the purpose of the STP project, provided ( that the necessary changes in "taffing, training, and procedures are effectively implemented. [ . l E 29 t
L E l E l ATTACHMENT A l L DISCUSSION OF PRO'S AND CON'S OF STP-QA ORGANIZATION OPTIONS l F ) I l E I I l I l i l } s 1 i I l I :
DISCUSSION OF PR0'S AND CON'S [ [ OPTION A - The Present Organizational Structure Where B&R Has Implemented A QA/QC Program Under The Licensee. (A Basic Assumption is ( that While the Present Organizational Structure Remains, the Implementation of the Program and Personnel Involved will be { Improved and Upgraded as Necessary, Including Personnel Replacement and Augmentation as Appropriate) [ PRO [ 1. Simplest to Implement This is essentially the traditional QA/QC program relationship that exists at present. The Bechtel analysis revealed only a few defi-( ciencies in QA programmatic documents of either HL&P or B&R. There would be minimum time and effort required to revise programmatic { documents. Further, retention of the existing organizational structures and interfaces between HL&P and B&R QA/QC would mean minimum perturbation of ongoing work by either organization.
- 2. Minimum Impact on the Project - on the Doers Retention of the existing organizational structure of the assurance
[ functions of both companies would mean continuance of the existing interface between those who do the work, " doers," and those respon-( sible for assuring that the activity was done correctly, " assurers." Both assurers and doers would benefit from working to existing { programmatic procedures defining the work process within each company with which they are already familiar.
- 3. Builds the HL&P and B&R QA Organizations for the Future
[ Inherent in this consideration is the premise, as stated above, that the original struc'.t.res and civision of responsibility would A-1
1 remain intact, and the staffing of the organizations would be significantly upgraded. This would permit both organizations to increase the competence of their respective companies in performance of the traditional utility-AE/ Constructor roles. I 4. Doers Retain Full Responsibility for the Quality of the Work and the
- Quality of the Assessment Function
- Inherent in the definition of Quality Assurance contained in 10 CFR, Part 50, Appendix B is recognition of the fact that quality assurance -
] encompasses activities associated with doing a job correctly as well as verifying and documenting satisfactory progress and com-i pletion of the work. This option retains the fundamental precept
- of the doers retaining responsibility for both doing and controlling the work. This fundamental precept has been implemented successfully by numerous utility /AE/ constructor combinations over the years in nuclear power plant construction, and is considered to be basically
; sound.
- 5. Maintains Clear Assignment of Responsibility
- Compared to Options B, C, and D, Option A retains the most clear cut definition of HL&P versus B&R QA program responsibilities.
;E
- 5 CON
- 1. It Didn't Work with Present Staffs A compelling argument against this option is that the present arrangement "didn't work." We list maintenance of the organiza- l tional structure / division of responsibility status quo as a " con" f
because it definitely could be perceived as such by external
)
evaluators, not because we consider it to be the case in this instance. The easiest and most natural reaction to situations such i as that in which the South Texas Project (STP) finds itself is to 4
" reorganize." It gives the illusion of change, if nothing else. l Not to do so will undoubtedly bring a negative reaction.
A-2
- 2. Management Attitude Problems Won't be Resolved Without Real Intro-
{ spective Assessment of Root Causes [ Maintaining the present organizational structure will not attack a primary weakness or root cause of the STP difficulties, i.e., attitudes toward quality by Management and the heads of departments. ( 3. Substantially New QA Management Staffs Required Based on NRC Report and Bechtel Audit Report [ As discussed under PRO Item 3, it is inherent in our consideration of this option that the staffing of the QA organization (both HL&P and B&R) would be significantly upgraded. This is essential to rectify a basic, prime root cause of the STP difficulties - weakness in the management capabilities within the QA organizations of both compar.ies. ( OPTION B - An Organizational Structure Where All Levels of the B&R QA/QC Organization Would Report to HL&P [ PRO [ 1. Provides a Significantly Different "New Look" This option, as ir the case with Options C, 0, and to an extent, E, has the very real political plus of doing so q thing dramatically different organizationally, as opposed to Option A. It further is one method of satisfying the NRC position that HL&P must be more ( involved.
- 2. Provides Greater Degree Of HL&P Control Over the QA/QC Function
{ There is no question that Option B, whereby B&R QA/QC organiza-tional personnel would receive direct supervision by HL&P personnel, provides a greater degree of control by HL&P than do Options A or [ E. i [ A-3
. s I 3. May Provide Reduced Manpower for the Inspection Function I An integrated QA/QC organization should allow for some overall l reduction in total QA/QC personnel in the composite organization I versus the separate organizations presently employed, particularly at the supervisory levels. Better supervision should also permit I enhanced efficiency.
- 4. Provides for More Doing by the HL&P OA Organization Direct supervision of B&R QA/QC personnel by HL&P would increase the HL&P involvement in all aspects of the B&R QA program, and I thereby reduce the present, more detached, reviewing role.
is also listed as CON 5.) (This
- 5. Perceived Reduction in Duplication of Effort In an integrated QA/QC organization, it should be possible to j eliminate some redundant tasks. J CON I 1. Cannot Be Totally Implemented Due To Necessity for B&R to Retain Code Stamp QA Responsibility
.I l The QA responsibilities assigned to an ASME B&R Code Section III l N-Stamp holder are essentially indivisible. This poses a dilemma, which for the STP has only two known viable solutions; neither is considered to be acceptable. The first would be for HL&P to get the N-Stamp. While this is achievable, its administration would be l difficult. The other approach would be for B&R to retain a par-tially redundant QA/QC function responsive to only the ASME Code (as opposed to the 10 CFR 50 Appendix B) requirements. While this would be the easiest approach to implement (i.e., nothing would have to change in the B&R manual) it is replete with operational I difficulties. A-4
l l 2. Major Impact on B&R QA/QC People in Serving Two Organizations The old saying about serving two masters applies here. There will be a subliminal conflict of interest on the part of the B&R per-I sonnel being " integrated" into the HL&P organization. This stems from the necessity of coping with the relatively short-term scpervision and direction by HL&P personnel, while recognizing that I they are still B&R employees, and their overall career fu'tures remain with B&R. Then, too, there is the perception of people in l this position who feel that they are subject to replacement. The result of such a situati'on is for the better, more competent, and l conscientious people to quit and take their skills elsewhere. With g the present availability of openings for experienced personnel in B the industry today, this could be a real concern.
- 3. Clouds Assignment cf QA Program Responsibilities l
The question of "who is responsible" arises. It is anticipated l that B&R would insist upon a scope change under this option whereby they would be relieved of responsibility for the performance of the B&R QA/QC personnel working under HL&P supervision. This would shift total responsibility for the assurer functions to HL&P. But what about the doer functions (design, c'onstruction, procurement, I etc.) retained by B&R? it is reasonable to assume that B&R would still be held responsible for these functions. As a result, there would still be the necessity for both companies to possess QA policy manuals and procedures. The task of sorting this out in a [ clear, concise manner at the detailed level is difficult at best, and has potential for severe implementation problems. {
- 4. Deleterious Impact of Internal Interface Between B&R Doers and QA Organization l
Extending the thoughts introduced in 3 above, this option comprises a scenario whereby either HL&P or " integrated" B&R QA/QC personnel A-5
( are interfacing directly with B&R doers (e.g., designers, con- { struction superintendents, buyers, etc.). This has the potential for a greater degree of confrontation, contention, and frustration ( on the part of both doers and assurers (but particularly the B&R doers) than existed in the previous relationships.
- 5. Potential Loss of HL&P Overview Due to Involvement in Detail
[ This is the strongest argument against this option. HL&P has demonstrated, by performance to date, difficulty in fulfilling the overview role in the traditional utility /AE/ constructor relation-ship in place on the STP. By getting involved in the details of the B&R QA/QC program by direct supervision of it, HL&P will further diminish their capability to perform their utility role in the overview of both the HL&P and B&R QA programs. , l ( 6. Relieves B&R of QA Program Responsibility { This consideration has been discussed in " CON" Items 3 and 4 above. l OPTION C - HL&P Establish a Total QA/QC Organization to Conduct the B&R { QA/QC Functions [ PRO 1
- 1. Most Dramatic New Face to NRC (of five options)
( It is apparent that this optior, of the five proposed, would respond in a significant and dramatic manner to the NRC expressed { position that HL&P must be "more involved" in the STP QA program.
- 2. Maximum Exercise of Client Control of QA/QC
{ This option envisions establishment of a QA/QC organization in HL&P [ that would totally replace the B&R QA and QC organizations. Since HL&P would be performing the QA/QC function in lieu of B&R, they would be in total control. - A-6
l I 3. Clear Assignment of Quality Responsibility i While B&R would retain the doer responsibility, HL&P would take over the total assurer responsibilities, thus providing a clear l I division of responsibilities between the two companies.
- 4. Increased Responsiveness to QA/QC by B&R Doers Potentially, the doers would be less inclined to be intransigent with the QA/QC client personnel in direct interfaces than they would be with fellow personnel in the B&R organization.
l 5. Potential Manpower Reduction in Site Inspection { Same rational as Option B, PRO Item 3.
- 6. Reduction In Duplication of Effort With HL&P performing the total QA/QC function, one entire layer of QA/QC organization (e.g. B&R) is eliminated.
- 7. More Doing by HL&P QA - Less Reviewing Self evident.
I CON p
- 1. B&R Relieved of "Q" Responsibility
{ There are two aspects of this consideration. First, B&R would be relieved of the total " assurer" QA function. Second, which is much { more subtle and potentially deleterious, is the probability that
.the B&R doers would tend to feel that the responsibility for work quality, as opposed to quality assurance, had also passed to HL&P.
This " inspect in the Quality" syndrome, seen to various degrees in even traditional QA/QC relationships, is considered much more A-7 .
L [ ! likely to occur in the set-up comprising this option. Should it { occur, it would violate one of the principal tenets of quality , assurance; i.e., the doers are responsible for the quality of their ! work.
- 2. Unofficial-Undocumented Q Organization Within B&R
( A sub-rosa, unofficial, undocumented, and programmatically uncon-trolled organization would emerge in B&R to "make sure it's right" before HL&P QA/QC inspects the work. { B&R would function to see that it was " clean" before exposing nonconforming work to discovery by the HL&P assurers. There is no question that B&R construction supervision would assure themselves that the work is performed in accordance with the approved design documents before inspection - whether performed by ( HL&P or B&R QA/QC personnel. This function should be overt, above board, and controlled. .
- 3. HL&P Does Not Have Properly Qualified Personnel in Sufficient Quantities--and May Have Difficulty in Getting Them
{ - [ To assume the B&R QA/QC function, HL&P will require a significant increase in total QA/QC personnel. The lack of qualified QA people < is currently a problem. It is anticipated that HL&P would continue to encounter significant difficulty, and require considerable time, to properly staff their own organization to perform these functions.
- 4. Cannot Totally Implement Due to Necessity for B&R to Retain Code
{ Stamp QA Responsibility { Same rationale as Option B, CON Item 1. [ [ A-8
I I 5. Impact of HL&P QA Personnel Interfacing with B&R Working Level I The thought introduced here is the difficulty of HL&P QA/QC in learning and working with the B&R procedural process, and, further, I the potential tendency to want to introduce changes into the B&R system. This impact could come in several ways. For example, HL&P QA personnel would presumably perform the QA review of B&R program-matic procedures (engineering, construction, procurement, etc.). The HL&P QA/QC organization would also potentially get into the detailed procedural system via the audit / surveillance function. The potential for such involvement to result in continual turmoil within the B&R procedural documents is considered to be very real. I Snould this develop, it would be one more way in which B&R would feel relieved of responsibility for the " quality", i.e., how they perform their work.
- 6. Potential Loss of HL&P Overview Due to Involvement in Detail - Loss of Objectivity This is essentially the same consideration as was introduced under Option B, CON Item 5, only more so. By being totally wrapped up in performir.g the B&R functions, it will be extremely difficult for HL&P to provide the detached, overview function inherent in their position as licensee.
iI OPTION D - HL&P Contracts with Another Independent Organization to Perform The Current B&R QA/QC Functions PRO
- 1. A Second, Most Dramatic "New Look" of Five Options i
Introduction of a third party to perform the B&R QA/QC functions is considered to be second only to Option C in evidencing a dramatic change to the NRC. 1 I A-9 L -
l I. I 2. Greater Client Control Than Options A, B, Or E I By totally relieving B&R of the QA/QC functions, this option is considered to provide greater independent control of B&R QA/QC than , any of the other options except for C. HL&P would be better able l to " set the dials" of the third party QA/QC personnel than they would be by supervising the B&R QA/QC personnel directly (Option B). I 3. Places HL&P in a Problem Resolving Mode I By using the third party to bear the brunt of the day-to-day QA/QC relationships with B&R, a buffer would be provided between HL&P and I B&R. HL&P would only be involved when disagreements are escalated for resolution.
- 4. Provides Clear Definition of QA Program Responsibility Between HL&P and B&R This consideration is the same as that discussed under Option C, PRO Item 3, except that the third party would assume the QA/QC responsibilities.
- 5. Increased Responsiveness to QA/QC by B&R Doers I
This is the same thought introduced under Option C, Item 4, although B&R might be more inclined to argue, etc., with a third party QA/QC individual than if it were a HL&P employee. However, B&R employees would be much less inclined to browbeat a third party individual than they would a fellow B&R employee. CON I 1. B&R Relieved of Q Responsibility I Same as Option C, CON Item 1. I A-10
1 I I 2. Cannot Totally Implement Due to Necessity for B&R to Retain Code , Stamp Responsibility l I This is the same consideration as discussed in Option B, CON Item 1 I 1 and Option C, Item 2, except with introduction of an outsider to perform the code assigned QA/QC responsibilities of the N-Stamp holder. Potentially, B&R could contract with the third party and maintain code approval (since B&R would retain the responsibility to go with the stamp) easier than if B&R were totally relieved of responsibility via HL&P doing the contracting. I 3. Add a New Perturbation by Addition of a New Interface Relationship Instead of B&R QA/QC interfacing with HL&P, as at present, this option introduces a totally new organization and procedures. Correspondence control, procedural documents, and day-to-day inter-faces would all change with a corresponding period of confusion.
- 4. Maximum Impact on Construction Effort - Schedule I A new outside QA/QC organization would cause the most serious impact on the effort, of the five options proposed. New people, procedures, philosophies, and ground rules will all tend to slow down and perturb the work to some degree.
- 5. Unofficial-Undocumented Q Organizations in B&R This consideration ,s the same as discussed under Option C, CON Item 2.
- 6. Both Organizations Lose Experience From Direct Involvement l
With B&R relieved of total QA/QC responsibility, and HL&P now further away from the~B&R program implementation, it is considered that both companies would lose something from their disinvolvement. I l I A-11 l
L
- 7. Increases Interface Problems - B&R/ Third Party /HL&P
{ This consideration is discussed in CON, Item 3 above. l
- 8. Confuses Division of Responsibility Between HL&P and Third Party Numerous instances may occur where B&R disagrees with the third party. The mechanisms for resolving such differences, coupled with a nai tendency on the part of B&R to want to " appeal" third party decisions to HL&P, will make it quite difficult on occasion to get resolution of disagreements involving three parties. Un-doubtedly, HL&P would desire to reserve the right to have final say
{ on such B&R - third party issues. This will require extreme care on the part of HL&P to back the third party sufficiently so that they do not lose credibility with B&R, but not to let the third l party go overboard in direction for which B&R can validly claim cost and/or schedule impact or interference. ( OPTION E - HL&P Established a Duplicate QA/QC Organization (In Whole or Part) to that of B&R With Both Groups Performing Duplicate Functions { PRO [
- 1. Increases the Total QA/QC Presence and Overview The beefing up of the HL&P QA organization to achieve a one-on-one
[ functional relationship with B&R QA/QC would be beneficial over the current arrangement by increasing the total QA/QC presence and ( involvement on the job.
- 2. Doers Retain Full Responsibility for the Quality of Their Work p Same consideration as Option A, PRO Item 4.
L u e A-12
[ .
- 3. Second (of all options) Easiest to Implement on a Planned Basis
{ The beefing up of the HL&P QA/QC functions could be accomplished on a phased basis with little or no programmatic document change.
- 4. Little Impact Ongoing Project
[ The evolutionary manner in which this option could be implemented should be achievable with little, if any, impact on ongoing work by .{ either B&R or HL&P.
- 5. Builds for Future Increasing the HL&P QA involvement in the overall activities of the STP should be beneficial both to the STP in particular and the HL&P QA Organization in general.
CON
- 1. Redundant Organization It is obvious that providing a HL&P " reviewer" one-on-one with the rL. B&R " doer" in QA/QC is neither efficient nor cost effective.
- 2. Overstaffing Causes Gaps in Implementation ("I Thought He Did It")
The more complex and large the total QA/QC staffing and program becomes, the greater the chance for things to fall through the cracks. l
- 3. Clouds Assignment of QA Program Responsibility c
This consideration is similar to that introduced in Option B, CON p Item 3, only with a different connotation. If HL&P is duplicating
- all (or most) of the B&R QA/QC functions, it will be difficult to r see how B&R can feel responsible for QA/QC matters if HL&P QA/QC.is
- b. walking in their footsteps.
u . A-13
E I
- 4. HL&P Does Not Have Properly Qualified Personnel in Sufficient
[ Quantities and May Have Difficulty in Obtaining Them Same as Option C, CON Item 3. l [ OPTION F - A third party consultant could be hired to supplement either or both organizations until such time that the required { levels of proficiency are acquired. This is a subset to any other option, but in particular to Option C. It would serve as an interim plan leading to others. PRO
- 1. Quick Response Time This is the only way that HL&P can implement its responsibilities
{ in short order. The requirement to place qualified personnel in l all QA/QC supervisory / managerial slots would address one of the I prime root causes. { p 2. Owner Control and Visibility L. With HL&P's engagement of a third party consultant to supplement the existing Site QA/QC organization, HL&P can demonstrate its continued control over the progress of execution of the STP QA ( Program. { 3. Organization Autonomy (Full-Service) i The organization autonomy concept is uninterrupted by the addition { of a third party consultant to the STP-QA site team. The full service QA/QC organizations within HL&R and B&R reporting to their respective managements are still in place. I u l r l A-14 i
4 I 4. QA/QC Independence The addition of the third party consultant to the project does not diminish the organizational independence of the QA/QC function.
- 5. Capable of Implementation The concept involving the use of a third party QA consultant has been effectively implemented elsewhere, the most recent example having been the Marble Hill Station.
I CON
- 1. Short-Term Costs Are High The addition of a third party organization of professional QA/QC consultants to the project will add considerable short-term expense to the project.
- 2. B&R Relieved of Q Responsibility This is the same consideration as discussed in Option B, CON Item 6; Option C, CON Item 1; and Option D, CON Item 1.
I 3. Cannot Totally Implement Due to Necessity for B&R to Retain Code Stamp Responsibility This is the same consideration as discussed in Option B, CON Item 1; Option C, CON Item 4; and Option D, CON Item 2.
- 4. Adds a New Perturbation by Addition of New Interface Relationship Same as Option D, CON Item 3.
A-15
l { 5. Maximum Impact on Construction Effort - Schedule Same as Option D, CON Item 4. [
- 6. Unofficial - Undocumented Q Organization in B&R This is the same consideration as discussed in Option C, CON Item 2 h and Option D, CON Item 5.
{ 7. Both Organizations Lose Experience from Direct Involvement Same as Option D, CON Item 6.
- 8. Increase Interface Problems - B&R/ Third Part/HL&P Same as Option D, CON Item 7.
- 9. Confuses Division of Responsibility Between HL&P and Third Party Same as Option D, CON Item 8.
[ E E E E E-4 7 A-16
e r L E ATTACHMENT B ORGANIZATION CHARTS E E E E E E E E E E L
W 'M M M M M M M M STP QA ORGANIZATION Site HL&P HL&P Project QA Manager Corp. QA Manager i I Site Site Site Site Site H0 Mech /NDE Civil / Structural Elec/I&C Procurement Quality Audits QE QE AE QE Systems PROGRAMMATIC DIRECTION e Establish broad objectives, policies, goals, and e Provide overall e Establish overall e Develop overall parameters requirements for guides for program audit system approval of evaluation / y e Review and approve B&R policies and key procedures suppliers / maintenance e Establish schedules subcontractors and checklists e Conduct overall surveillance activities of B&R's e Establish trend program implementation e Monitor imple- analysis program o Perform routine / mentation of continuous and e Conduct management. reviews of status and adequacy of supplier sur- e Establish status special audits program implementation veillance by B&R and adequacy review program o Report findings to e Establish responsive system of reporting deficiencies e Assure imple- proper management to NRC mentation of e Provide I&T/ effective program qualification e Maintain auditors' s Establish communication link directly to B&R organ- of receipt inspec- certification qualifications ization and provide detailed guidance as required tion system guidance
7 J 1 n n n n n n n n M n n n n n n n r-Site n BSa Project QA Hyr. TECHNICAL DIRECTION Site. Site H0 Site Quality Assurance QC Vendor Engr. Mgr. Mgr. Surveillance QA Services Audits e Survey vendor shops e Initiate QA program e Develop and imple-Mech /NDE _ Mech /NDE policies and proce- ment audit plans QE Insp. e Select qualified dures vendors according e Establish audit to established e Review engineering, schedules Electric Electric criteria procurement, con-Insp. QE struction procedures e Conduct continuous e Audit vendors during for Q-activities and special audits
?' course of work per- I N Civil /Struct. _
Civil /Struct. formance e Develop I&T software e Train and qualify i' QE Insp. and conduct I&T auditors programs e Initiate standardized Recg. Insp. e Structure and imple- checklists Procurement Storage ment overall quality
" system controls" e Report findings to o Monitor work per- e Verification of work - Management Infor- management formance for tech- activities according mation nical adequacy of to approved inspec- - Trend distribution e Verification corrective Q-related activities tion plans - Deviation analysis action for (1) completion e Provide techaical e Documentation of co* e Provide Records (2) adequacy guidance to QCE's pleted work activi-Management Services and field engineers ties on work plans and inspection to QA e Assist in problem records e Support audits resolution e Assurance that veri-j e Coordinate policy / fication records are
- programmatic deci- properly completed i
sions with Client and retained ! QAEs
1 m m m m rm m m rm m m rt m m m m rm rm u
. STP- QA ORGANIZATION Site HL&P llL&P Project QA Manager Corp. QA Manager 10 - 15
{ Site Site Site 1 Site Site 11 0 l tiech/NDE Civil / Structural Elec/I&C i Procurement Quality Audits l QE QE AE i QE Systems PROGRAMMATICblRECTION Site i 8 B&R Project QA Mgr. TECilNICAL DIRECTION .
. Site l Site l 11 0 Site Quality Assurance QC Vendor QA Services Audits Engr. Mgr. Mgr. Surveillance Continuous
_ Mech /NDE _ Mech /NDE 4-5 QE Insp. Electric - Electric QE Insp. _ Civil /Struct. _ Civil /Struct. QE Insp. l Procurement Recg. Insp. Storage
- Includes Surveillance 55 - 60 10 - 15 Safety related
HIAP & B&R CCD I l I 7-r- h. EXECUTIVE V. P. I' HL&P
- c. W. OPREA lt..
MANACER STP CORP - AUDIT QA MANAGER, STP g D.C. BARKER R. L. ULREY R. A. FRAZAR (ACTIE) L. E. ZWISSLER (MAC) l l 7 .. I .I - , I l i g QA PROGRAMMATIC l DIRECTION , i L______q i I B&R QA MANAGER STP < W.J. FRIEDRICH (MAC) k EXHIBIT 3 EXHIBIT 4 e L
/
6 f I:
s ORATE STRUCR'RE
\
\
GROUP V.P., POWER B&R W. N. RICE CR. V.P. DR. K.M. BROOM SR. V.P. SR V.P. SR. V.P. OPERATIONS POWER ENGINEERING POWER CONSTRUCTION S.H. CROTE E. A. SALTARELLI J.C. BAZOR I l i I I I I I I I I I i 1 1 I I I I I I i 1 I I
)
l I ; I I I l CENERAL MANAGER l g URPORATE AUDIT STP R. W. GASS J.R. CEURTS l I I I I I I I i I i ! l l 1 MATERIAL MANACD(ENT ENGINEERING CONSTRUCTION
\
EXHIBIT 2 7/24/80 ; D
i o s s 't Exact rrva VICE FRE51 DENT G.k. etEEA. JE. 4 r'
$44.T5 TEIAS (A MAHACER B. A. FRA1A3 L.I.ThW D (MAc)
L1 Ps T. QCALITT CONfnuL pgst tyttus qA SLTERTI$fE PtW1 QA Cui. Sl'PEEVIL1B J.W. SokARD (TA( ANT) L . ...p._. (2 CITIL. 2 MICE. 2 ELEC/T6C) MrCMME CITTL/5TRLER:kAL SITI EITI PROJECT racJt.CT QA SLTt3VI5(E QA SUPERVIsre L.D. WItsou N a.A. CAFVYL j l I HL4F DiscirLINf _qA
- 1. Faeports selected enestrarttee met tettlee as directed by 49ecipline QA taapsettaa teatreettene. 1. Raspanothie for assurina 1*Plomentation l et meressary QA/QC activities withis the I
- 1. Aeoutes qualif ted taspeetere are s'.111 sed. d isca pi tee
- 1. topores taopoettaa resulte. 2. Reetows taspect les plesimina derete.
- 1. Reviews manceof ormance reporte.
4 Prepares meneenfermance reporte se reptred.
~
S. Assuree toepection opspeest is property guels fied and certified.
- 4. Reetete selected destam decsmeets.
- 5. Performs audite of site, sur;11ere, sed subcentrartes s se reguired oy the QA Ramag l 6. Participates la WRC audita, j
l g I. Assures adequee7 of eupplier med $4R terreet tee ar t tee.
- 4. Reeteve and appreeen eclected eupr11ere end sakentracters i withis the djeripline. l
- t. I I
v T i Ih
}
.\ w.
BL&P GLALITT A&EL'RANC3 086ABIZATIon e d CCCP A?Dt1 P. L. U1 PET _ stWPCT (JA StrPtaV1w3 FA83# . WC/ t &C Pa84TRMtFJIT Qt ALITT SYSTDIS OPFRAftcess t !TI ikR EYN OPPICI 5173 BOUSTrEl OPPICE I buPDVf X2 QA EITERTISM SUFF3 FT SM aPFPAf tulq QA MA51 alt.R If. E*JtFR 3.C. OVta.;YRFFT
~
T.J. Jt1 stas (TAcAgrr) J T l l I
'll'F P308EPENT3'J lt1APjALI_T_7 f*ST_Dts eit &Pgrt tTInitip
- 1. Coordinates between the project 1. Prepares IIIAF Q1 Meemal and and the EIAP wonder ei.rset tleece
- 1. Devel pe operet taue quality assurance 1.
adotaletrettaa precedures program, Perferos joint utility endits se atac1. ear stees sugT11ere. group f or Westleshoose furetrhi d equipeset and piples and food- related te constrwettaa m et. 2. tor tas. 2. Perforse recetyt taapeet tee for opere Performe jetzt audits with Westiashouse/LI er their supp11ere. ester heatore Parte . 3. Perf see Eaternal medite (IflAP ergamisattees).
- 2. Caerdiestes WIAP QA recorde
- 1. teordteates resolwe tae , d vender ternever. 3. Tevelers Wif/I?! progree. 4.
problems identif tad by NL&P per. Perfetas avdtte er Architert Engtecer/Ceestrutter. sommet 141 showe. 1. Maimesima NLAP werhans filee. 4. Adeletetere Pst/ISI eaetract. 5. Assures emreettw set tees.
- 1. Freet4ee progreestie dieeettee 4. Prepares ERC resp eses. 5. Perferes quality contret tospeet tnes 4. Deports audf
- results to ogper macaresset, to B&A weedor outwet1Imace and esting operat ines/eatatoaance.
auditleg f net teme. 3. Perperes resp ose to PIAP 7. Perforse suppleseetal audits se regetred. Portedte torperate r}A ei.dtte. 6. Audito operet tas/malatessere activities 4 Perferee everviews of $6E vender g, p ,, servet11 mere med sedit act ivt- g,,, ggg,, y. I'*** , g,, , ,, qA Andtte e-stem tursover/startup mettwittee. trend prestas.
- 8. Coordinates wt** HLAP Diecipline QA se 5 Coordtaates taput to pre}ert 7,'
" Masseement of the B1AP QA planolad fe feverest of oFetse turnover trelatag sad certjfieet ten W etartup activities 6.
Caerdientes (A revlee of easie-eerleg asserteted derwarmte, g. Toterfere with Operat tana OA F. Coordtaates with ette dtsetpline digtelee la planetag for tram-
' A fuerk.see f or tapet to coe 's sittee fran Constreettaa to Operet tnes, survettlance med audit arttut+
ties 9 Review of all CA deporteret
- 8. nevices saa precedures and plane seeersted precedures.
for endito med weeder surgetI- 1. Masate este audit Pro ram.
- 11. Malatetes qualtfled auditore for ette audite.
- 12. Schedules avdtte.
- 13. A**eres edequae, of QA correc.
tive acti e program for 3-y, 9'
/
j (1HIBIT 3 4 me,
g ,( l 1 L g BROWN & ROOT QUALITY ASSURANCE ORCANIZATION i p. t 6 4 I PROJECT QA { MANAGER l & W.J. FRIEDRICH 7.~ ( 1 I i e b QUALITY ENGINEERINC HOUSTON QA OL MANAGER MANAGER MANACER COURDINATION D. W. JANECEE C. R. PURDY C. T. WARNICK D. HARRIS (MAC) ASST. MANAGER R. R. CUNTER 9 I i kA B&R Quality Engineering B&R Quality Control B&R H asten QA i~
- 1. Reviews all Pos within discipline. 1. Inspects construction activities as 1. Performs vendor inspecticus as required
- 7. Reviews selected design documents. directed by Quality Engineering Inspec- by QA engineering planning instructions:
- 3. Reviews and approves nonconforMance tion planning instructions. 2. Assures qualifiad scuree inspectors areI reports. 2. Assures qualified inspectors are utilized. ut111 ed. !
- 4. Reviews design change notices and 3. Reports inspection results. 3. Reports insoecticn results. I field changs requests. 4. Prepares nonconformance reports as required. 4. Ccordinates inspectien resulte.
- 5. Prepares all inspection planning 5. Assures inspection equipment fa properly 5. Preparesnoncouformancereportsasre-)
instruction records in conjunction qualified and calibrated. quired. j with Construction Engineering. 6. Coordinates corporate audits and correz
- 6. Reviews and approves completed tive actions. i l
record packages. 7. Coordinates engineering QA setivttfe9
- 7. Resolves QC technical problems. 8. Prepares and controls QA Budgets & ScZ
- 8. Administers testing and inspection subcontracts related to the disci- !
I pline.
- 9. Assures adequacy of corrective actions for B&R subcontractors and suppliers.
- 10. Reviews and approves quality construc-tion procedures.
l
' 11. Prescribes training programa for restric- l tion and certification.
- 12. Reviews and approves QA Programa for i g- subcontractors.
F u j i i fI f h U
'k
( l %. t
9 CORPORATE AL*DITS SECTION MANACER R. M. BASS l l 4 l l l l l l l QA SYSTD(S SITE AUDIT MANAGER MANAGER W. ABRAMS l l J. T. MOORE ' i I ASST. MANACER R. J. PURDT l l l B&R QA Systems B&R Site Audits Houston Audits
- 1. Prepares and maintains B&R STP QA Manual 1. Maintains cualified auditors. 1. Maintains Qualified Auditors.
and performs secretarial function for 2. Conducts B&R STP QA mini-audit program 2. Conducts STP System audits procedures. at site. 3. Assures adequacy of corrective
- 2. Coordinates B&R QA records turnover. 3. Schedules mini-audits. setions
- 3. Maintains B&R STP QA file. 4. A
- n' ire g adequacy of corrective action 4. Reports audit results to Executive.
- 4. Prepares draft responses (coordina- resulting from their audits. MCMT.
tion) to NRC Inspection Reports. 5. Reports mini-sudits to B&R Project QA l
- 5. Prepares responses to HL&P audits Manager. 1 (cerdination).
A. Administration support.
- 7. Prepares monthly QA reports including dula susmaary data on STP QA trer,6 program.
- 8. Coordinates B&R QA training and certifi-cation program.
/
EXHIBIT 4
/'
7/24/80 [ h
I ! EXHIBIT 5 QUALIFICATIONS OF KEY MAC PERSONNEL
- 1. NAME: L. E. Zwissler STP ASSIGNMENT: Support for HL&P QA Manager -
I EDUCATION: BSCE Armour Institute EXPERIENCE: MS Applied Mechanics, Rutgers Nuclear: 8 years
-- QA Manager, Employer: Argonne National Lab Supplementary QA Experience:
QA Manager, Aerojet General, 10 years -- PROFESSIONAL: Registered Professional Engineer, Senior Member ASQC
- 2. NAME: W. J. Friedrich STP ASSIGNMENT: Project QA Manager B&R i EDUCATION: BS Metallurgy, University of Pittsburgh EXPERIENCE:
Nuclear: 8 years Site QA Manager, Zimmer Station Employer-Kaiser Engineers, 3 1/2 years Site QA Manager, Sundesert Station Employer-San Diego Gas & Electric, 1 1/2 years Site QA Manager, Rancho Seco Station Sacramento Municipal Utility District, 3 years Supplementary QA Experience: l -- QA Manager, Rohr Aerospace, 2 years I Manager Nondestructive Testing Dept. Employer-Aeroject General, 10 years PROFESSIONAL: Registered Professional Engineer
-- Member ASNT, Level III Examiner l
B
- 3. NAME: D. Harris STP ASSIGNMENT: Support for B&R Quality Engineering Manager EDUCP. TION: AA Aeronautics-Sacramento City College EXPERIENCE:
Nuclear: Supervisor LOFT Program, Manager l Receiving Inspection Employer: Idaho Nuclear, 3 years l Manager Manufacturing QA, Supervisor Quality Engineering B Employer: General Atomic, 6 years Supplementary QA Experience:
-- Quality Engineer Employer: Aerojet General, 14 years PROFESSIONAL:
Registered Professional Engineer Member ASQC 1 E 1 l .- l I : L 1
RESPONSE TO ITEMS (2) AND (10)
~
1 Order: (2) A review shall be completed or new data obtained g to provide information to address the following issues with respect to the Category I structural backfill: (a) 2est fill program which established the soil conditions, lift thickness, compactive effort, and equipment characteristics necessary to develop the g necessary in-place densities, (b) comparison of material (s) tested and described in Section 2.5.4.8.3 of FSAR addressing liquefaction with those used in the field, I (c) the sequence of construction of existing backfill l including the loose lift thickness and number of passes of the equipment, (d) the adequacy of existing backfill material in-cluding that under structures founded on backfill, (e) and the rationale behind the use of 18" loose lifts compacted by 8 passes of the equipment to achieve the required densities. (10) The licensee shall verify or correct it necessary, the FSAR statements contained in Section 2.5.4, Stability of Subsurface Materials, especially Section 2.5.4.5, I Excavations and Backfill. I (2-1)
L [ b Response: ,_ I. Introduction . _.. In January 1980, to respond to questions raised by the [ NRC I&E, HL&P and B&R initiated a comprehensive test boring program to assess and verify the adequacy of the in-place Category I structural backfill at the STP. This program was conducted by geotechnical engineers from Woodward-Clyde Consultants (WCC). The program, completed in April 1980, [ verified the overall adequacy of the Category I structural backfill, but recommended further confirmatory investiga-tions and analyses in four specific areas to assure engi-neering adequacy of the backfill. Professor H. Bolton Seed, { a leading expert on soils liquefaction, assisted in defining I [ the methods for analyzing the results of the test boring program. b At the time the NRC Show Cause Order was issued in I { April, 1980, data"obtained during the test boring program was under analysis. Upon issuance of the NRC Show Cause b Order, a special Task Force comprised of geotechnical and QA engineers from B&R and HL&P was established to perform an b in-depth study to verify the acceptability of previous { backfill placement and testing methods, and to demonstrate the adequacy of the in-place category I structural backfill. b WCC, which was in the process of completing their analysis b [ (2-2)
[ of the previously obtained test boring data, was assigned by the Task Force to investigate, analyze, and conduct other [ special studies to verify the condition of the category I [ structural backfill. WCC's activities, conclusions, and recommendations are described in the following responses of the specific issues listed in Item (2). A. B&R/HL&P Category I Structural Backfill Task Force In order to fully evaluate the adequacy of the Category ( I structural backfill at the STP, keeping in mind those specific areas which had been identified in Item (2), the . B&R/HL&P Task Force identified the following planned reviews and associated studies to be performed (the list references { applicable subjects identified in Item (2) of the Order): ( (1) A test fill program to reconfirm the adequacy of the construction methods used during the Category I structural backfill placements - Items (2)(a) [ and (2)(e). (2) A comparison of backfill material tested for the [ Engineering design studies with the material actually placed - Item (2)(b). (3) Plan views and profiles to show the sequence of [ backfill placements and lift thicknesses (eleva-tions) together with the locations of the in-place density tests and results - Items (2)(c) and (2)(d). (4) Review of all backfill construction Earthwork Inspection Reports to determine compliance with the provisions of the backfill specification and the construction procedures - Items (2)(c), (2)(d), and (10). { [ [ (2-3)
(5) Statistical' analyses of the in-place density tests to determine the postulated density distribution - Item (2)(d). (6) Determination of the relative density requirements of the backfill, based on engineering adequacy, and considering the possibility of localized areas having densities less than the construction quality control acceptance criteria - Item (2)(d). (7) Analysis of the significance of density distribu-tions within the surface lift, immediately below Category I structural foundations - Item (2)(d). 1 (8) Review of previous boring program results for evaluation of the engineering adequacy of the backfill, specifically, any encountered density I indications below the construction quality control acceptance criteria - Item (2)(d). (9) Comparative determination of maximum / minimum I laboratory density test results by independent laboratories-(Items (2)(a) and (2)(d). I (10) Evaluation of all data concerning generic or cpecific problem with the backfill construction and quality control programs, and development of I recommendations for corrective actions as required-(Items (2)(c) and (2)(d). B. Category 1 Structural Backfill Indeoendent Review Committee i Early in the Task Force review process the need was identified for an independent assessment of the Category I l l structural backfill by leading experts in geotechnical engineering. Accordingly, in May 1980, the firm of Shannon
& Wilson, Inc. was retained as consultant to B&R to establish an Independent Review Committee of geotechnical experts to review the category I structural backfill construction for i
1 I I I (2-4) ( - j
E I I the STP. The following experts in the field of Geotechnical _ Engineering were chosen for the Independent Review Committee: Stanley D. Wilson, Consulting Engineer and Committee Chairman; H. Bolton Seed, Professor of Soil Mechanics, University of California at Berkeley; and Alfred J. Hendron, Jr., Professor j of Soil Mechanics, University of Illinois at Urbana. Resumes for the three committee members are attached as Exhibits 6, 7 and 8. The principal purpose of establishing the Independent Review Committee was to assess the engineering acceptability of the Category I structural backfill already in place. The following tasks, many of which supplement and/or duplicate the studies of the B&R/HL&P Task Force, were originally I outlined: (1) Reviewing laboratory tests and design analyses I : performed on the backfill concerning liquefaction and settlement. (2) Reviewing the recommendations and criteria for I compaction of the backfill as documented in a series of geotechnical engineering reports issued by WCC. ) i (3) Reviewing the construction specifications and procedures for compaction of the backfill, in-1 I cluding the actual construction and quality control methods employed in the field. l l (4) Reviewing the prescribed and implemented inspec-I tion and testing procedures for compaction control of the backfill placement, including the quality control methods and documentation implemented in I the field. ;- 1 I (2-5)
E [ [ (5) Reviewing and analyzing compaction quality control test results collected and documented covering the [. construction period from 1976 to 1980. (6) Reviewing the results of special investigations of [ the placed backfill to assess adherence to the design requirements, including the results of the test boring program performed during the spring of 1980. (7) In the event low density pockets are delineated in the backfill, reviewing the efficiency of thc ( methods proposed by B&R Engineering to treat those i pockets to bring them into conformance with the design requirements.
)
[ (8) Inspecting the on-site laboratory facilities and equipment used by the existing testing agency, and reviewing the laboratory test procedures. { (9) Reviewing the procedures, observing field opera-tions, and evaluating the results of the test fill ( program. These activities and other subjects identified for review by [ the Independent Review Committee, are described in the { committee report, which is included as Exhibit 9. C. Highlight of Study Conclusions ( The studies conducted confirmed the adequacy of the
\
Category I structural backfill placed at the STP. The dis- ! [ cussion presented in sections II-VI below describe these { studies and the conclusions of the Task Force and the Inde-pendent Review Committee. The following are highlights of those conclusions:
" . . . that with the type of compaction equipment
( used, the number of passes actually accomplished and the thickness of the layers placed, a dense, homogenous, b' [ (2-6) f e _
[ [ compacted structural backfill resulted which is more than adequate for the intended use and is generally in i r accordance with specification requirements. However, four zones have been detected in which the Standard Penetration Resistance of the structural backfill, based on a commonly accepted correlation, would indi- .( cate a relative density less than 80%. The test locations for the borings were selected in an unbiased manner and their number is adequate to provide a repre-sentative sample of the fill conditions. The studies
. show that in three cases the zones are found to have a safety factor greater than 1.5 against liquefac-tion, and for the fourth case the minimum factor of safety is 1.4. The negligible pore pressures which might build up in isolated. zones are not considered significant with respect to the adequacy and safety of
( the overall structural backfill.
. . . that the procedures used yielded values of
( relative density which are conservative and exceeds the specification requirements. The actual frequencies of field and laboratory testing far exceed the specification { requirements and are judged to be most adequate.
. . . that the backfill immediately under the mat
[ foundations has a relative density lower than 80%. The detailed studies . .
. show that even for an assumed relative density as low as 45%, the presence of such a layer will have no significant effect on the performance
( of the building as a result of the shaking produced by the SSE, and the factor of safety was found to be in excess of 1.8. {
"From the results of the June 1980 test fill . .: .
- 1) that the project vibratory rollers are capable i of compacting the specified lift thickness to the L
required densities; 2) that there is uniformity of compaction throughout backfill placed in 18-inch or [ smaller lifts, except for the upper portion of the top lift; 3) that the density testing depth below the backfill surface is not a critical factor, since tests taken in the upper lift or upper part of underlying (- lift produce conservative results (lower density values with additional compactive effort and retests accomplished as required [ minimum. comp)a;ction criteria, to obtain engineeringand 4) eight roller p integrity and safet acceptance testing.y, and a proper starting point for
; 1.
[ [ (2-7)
- I
. . . that the condition of the fill as placed is better than the design requirements." (See Exhibit 7, pp. 35-37).
II. RESPONSE TO ITEM (2)(a): Test Fill Program Reviews have been completed and, in addition, new data has been obtained regarding the Category I structural back-fill test fill program which establishes the soil condi-tions, lift thickness, compactive effort, and equipment characteristics necessary to achieve the required in-place densities. A. Backfill Construction Criteria , The STP Quality Construction Procedure for Category I ~ structural backfill was first developed in 1976 and was j based on specification requirements and existing industry practices. The specification required that the backfill be placed in lifts not exceeding 18 inches loose thickness and
, be compacted to a relative density of at least 80 percent.
The design specification required that the adequacy of Con-ll struction's backfill procedure be verified by acceptable production placements (i.e., the first 20 in-place density l 1 i tests obtained in unrestricted Category I areas). l Although the specification required a test fill program only if Construction elected to place backfill using the
.l specification option of 24 inch lifts, Construction elected I =
'I (2-8)
- I
1 I I to conduct a self-imposed test fill program on the use of 18 l inch lifts. The roller manufacturer's studies:were also l considered in the development of backfill construction criteria and procedures. The criteria and procedures from 1976 were, with minor variations, the same requirements as those in use at the time of issuance of the Order. ~ For backfill compaction, B&R Construction selected a "10-ton" steel drum vibratory roller (Dynapac CA-25SD) which develops a centrifugal force a 44,000 lbs. at 28.3 cps (1700 vpm). Dynapac recommended a compacted lift thickness for sand fill: of 600 mm (about 24 inches) and 6 passes in order to achieve 90 to 95 percent modified proctor density. (The specified 80 percent relative density is approximately equal to 95 percent modified proctor.) The self-imposed test fill program (which is described in the Test Fill Report) showed that 80 percent relative density could be obtained at a testing depth of 18 to 24 inches (i.e. in the top portion of the underlying lift) after only 4 passes. Testing within the surface lift at 8
- I to 14 inch depths indicated 8 to 10 passes would be required.
At that time, the B&R Site Geotechnical Engineering representative made an evaluation of the results, and con-servatively recommended that provisions for a minimum of 12 roller passes should be incorporated into the construction I (2-9)
[ [ procedures. However, B&R Construction concluded that a ( minimum of 12 passes would actually be necessary only on the surface lift, which would not receive further densification [ by compaction of overlying lifts, and that a minimum of 8 { passes would be a feasible construction operation provision for the lower lifts. The correctness of Construction's procedure was subsequently verified by acceptable production placements (i.e. the first 20 in-place density tests obtained in un-restricted Category I areas), which also are included { in the Test Fill report. B. Test Fill Program The test fill program conducted in 1980 together with the results from the self-imposed test fill program conducted in 1976 and all other test trials, are described in detail ( in B&R Technical Reference Document titled " Test Program for Compaction of Category I Structural Backfill" (TRD 3A700GP002-B), [ and a general description is contained at pages 17 through i 26 of Exhibit 9. Essentially all test fill density data obtained from ( the several programs and trials fall within the same band of variations, when evaluated on a dry density basis. The [ apparent "anomolies" can be largely attributed to normal { variation in test data. 1 [ [ , (2-10)
[ [ The Independent Review Committee has evaluated the ( field data based on tests by the onsite laboratory, and comparative tests performed by WCC and by Mr. Clarance Chan, a well-known authority on soils laboratory testing. The { comparative tests demonstrated that the on-site laboratory tests give conservatively high minimum laboratory densities and consequently conservative construction quality control acceptance criteria. C. Conclusions The Independent Review Committee has evaluated the field and laboratory data and has presented conclusions in b their interim report (see Exhibit 9). The Committee's final evaluation will be presented in a comprehensive report upon conclusion of all planned studies related to Category I Structural Backfill. Based upon the review and preliminary evaluation of the test fill data, both the B&R/HL&P Task Force and the Inde-pendent Review Committee have concluded that the construction methods and equipment used to place and compact the 17-18 [ inch lifts (maximum loose thickness) results in an end product which meets or exceeds project design requirements. This conclusion is based on the following: ( (1) The test data shows that no inadvertent L horizontal zones of low density occurred in the under-lying lift for any of the roller coverages and after y only 4 roller coverages, a uniform density distribution L N - (2-11)
L [ b was achieved throughout the underlying lift within the accuracy of the test methods.- ( (2) It is demonstrated that the zones specified for production acceptance testing (i.e., the lower i portion of the top lift and the top portion of the { underlying lift) are conservatively representative of the density of the material in the underlying lift. Accordingly, there is no engineering need to set specific L testing depths below the fill surface. existing at the time of testing, as long as each lift is tested. l However, B&R has nevertheless defined depths for in-place i density testing as a means of assuring systematic field [ quality control. l I { (3) After 10 roller coverages the lower and middle portions of the surface and final lift are l representative of the density of the material in the p underlying lift. There is no evidence that increasing L number of roller coverages, beyond the minimum of 12 coverages required by the Construction Procedure for r the top lift, appreciably increases the observed low L densities within the uppermost portion of the top and final lift. (4) The test data indicates that the influence of increased compaction extend to a depth of at least 3 feet below the lift being compacted. The point of maximum densification occurs approximately 25-inches below 'he surface. This compares well with the 18-inch maximum loose lift thickness, since the maximut lift thickness should not be much less than the depth to maximum densification. (5) The construction procedure requirement of 8 [ roller coverages prior to initiating acceptance density testing in the underlying lift and 12 minimum roller ~ coverages to initiating acceptance testing in the top [ and final lift is an efficient and effective procedure. I L III. RESPONSE TO ITEM (2)(b): Description of Fill Material 7 An evaluation has been made by the B&R/HL&P Task Force L to reconfirm the compliance of the Category I structural F L-r (2-12)
[ ' [ backfill material placed at STP site with the design basis material characteristics described in FSAR Section 2.5.4.8.3. The evaluation covers the geologic conditions of the
-source area, the determination of engineering properties, and assessment of the cyclic loading characteristics of the material. The liquefaction potential of the backfill material
{ as placed and compacted is addressed in section V below. A. Source Selection Program In 1974, Woodward-Clyde Consultants conducted an exten - sive regional investigation of potential material sources for Category I structural backfill. { Samples from the following potential borrow areas in the vicinity of the STP site were tested in the laboratory to evaluate the sources based on physical characteristics, strength, minimum and maximum densities, and permeability:
- 1. Gifford-Hill plant at Eagle Lake
[ 2. Gifford-Hill gravel pile at north short of Eagle Lake
- 3. Parker Brothers plant at Eagle Lake
- 4. Thorstenberg materials plant at Skull Creek, Eagle Lake S. Bloomington borrow area
- 6. Matagorda' Beach sand along Gulf shoreline
- 7. Celanese plant on Colorado River Bank l"
- 8. Spoil material west of Celanese plant at Wadsworth, Texas I
L (2-13) 1
I I
- 9. Pierce-Runnels Ranch 6 miles north of I Bay City, Texas.
Several sources in the Eagle Lake area (Colorado River alluvium) have like properties (e.g., Parker Brothers plant, Thorstenberg plant, and Gifford-Hill plant). The results from preliminary testing of the materials from these source areas are provided on PSAR Figure 2.5.4-la. The Eagle Lake source area consists of one common allu-vial deposit by the Colorado River (see Section B below). The material obtained from a process stockpile at the Gifford-Hill plant was judged representative for backfill materials which could be delivered by the several suppliers mining the deposit. The Thorstenberg processing plant was selected as the I primary supplier. Additional deliveries were subsequently started from the Parker Brothers Eagle Lake and Altair plants and from a second Thorstenberg pit. l B. Material Investigation __ (1) Geology I _ All the commercial operating plants in the Eagle Lake I { l Area, which includes Altair, lie within the Quaternary forma-tions or terrace ceposits of the Colorado River. The geology of this area of Colorado County has been extensively inves-tigated in the past. The sand and gravel deposits are entirely siliceous, most of the pebbles being composed of chert and
. T-1 I
1 (2-14) l
L [ 1 quartz, although pegmatite is common. The source of the fine and course aggregates are Quaternary fluvial deposits of the Colorado River. The deposits share a common provenance, . [ mode of transportation, and deposition. All of the borrow materials commercially available in the Eagle Lake area, therefore, are very similar in physical properties and characteristics because of the common geologic [ . origin. [ (2) Determination of Engineering Procerties _ _ The sample obtained from the Gifford-Hill plant was subject to laboratory testing in 1974 for determination of static and dynamic properties. The tests included gradation, compaction by Modified Proctor method, minimum and maximum densities, perme- [ ability, CID triaxial, strain and stress controlled cyclic triaxial, and resonant column tests. The specification criteria derived from the test sample characteristics covered { material gradation, coefficient of uniformity, overall particle shape, and freedom from organic matter. ( (3) Construction Quality control - .. Samples of backfill material used at the STP were tested for compliance with the specification requirements at three { times: (1) before initial delivery from the plant, (2) while on-site stockpiles, and (3) after placement (in conjunction r L with the in-place density tests). The gradation band of the actually placed materials are shown on FSAR Figure 2.5.4-59 ( and 60. (2-15)
E (4) Liquefaction Potential of Material Placed The Category I structural backfill material placed for the STP is from the same geologic formation and has the same [ gradation and particle shape characteristics as the material tested for the engineering studies. E
.The structural backfill borrow material used for the
{ design phase dynamic testing had a minimum dry density of 93.5 pcf, and a maximum dry density of 128.1 pcf. The dynamic test specimens were typically compacted to 119.2 pcf (actual range between 118.6 and 121.0 pcf as shown in Tables [ 2.5.4-17 and 18 of the FSAR), which is equal to 80% Relative { Density for the tested material. Using dynamic test results the liquefaction analysis I showed a factor of safety greater than 2.5 against initial liquefaction, and greater than 3.5 for liquefaction at + 10% E strain. { The NRC Investigation Report states that the minimum dry density noted was 105.3 pcf and the maximum dry density I noted was 123.0 pcf. The 80% Relative Density, corresponding to the noted maximum-minimum densities, is equal to 119.4 pcf dry density. This is the same 80% Relative Density dry unit [ weight (within 0.2 pcf) used in the dynamic tests. r The change in minimum and maximum dry density, noted l in the NRC Investigation Report, is due to subtle changes ? b M (2-16)
[ [ in the gradation and coefficient of uniformity which have occurred over the four years of construction of the struc- { tural backfill. These normal subtle changes are permitted by the construction specification limits for acceptable material and do not significantly influence the engineering properties, with respect to liquefaction. Therefore, the liquefaction analysis performed for the design and presiinted in the FSAR is considered to be valid. The liquefaction ( characteristics are further discussed in the Independent Review Committee's report (See Exhibit 3). [ IV. RESPONSE TO ITEM (2)(c): Construction Secuence { A comprehensive Engineering evaluation is being made of the construction conditions, placement sequence and testing of the category I structural backfill placed at the STP. Thus far the Task Force has completed a tabulation of density [ ' tests with depth in the backfill placements and the field { verification of lift thicknesses in accessible areas. Yet to be completed are the sequence of construction and the remaining lift thicknesses. The results will be used for 1 statistical analysis of the density distribution within the backfill, for evaluation of the backfill placement and compaction operations, and for assessment of the engineering adequacy of the in-place backfill. The data compiled during the evaulation will also be used as input to the studies of c L I L (2-17)
- r. .
I ~ I the adequacy of the existing backfill which is addressed in Section V (the response to Item 2(d)) and in the evaluations l by the Independent Review Committee. The data compilation is described in B&R Technical Reference Document titled " Category I Structural Backfill Placement and Quality Control Data" (TRD 3A700GP001-B). A. Data Review Program The locations and sequence of the various Category I backfill placements and corresponding in-place density test results will be documented for Units 1 and 2 together with summaries of the reported construction methods and conditions. l The backfill placements to be documented and evaluated include specifically the placements in support of the founda-tions for the Fuel-Handling, Mechanical-Electrical Auxiliary,
.I and Diesel Generator Buildings for both units, as well as the backfill surrounding these buildings, and against the Reactor Containment Buildings. The bedding and backfill for the Essential Cooling Water System Piping are also to be included.
The activities include data retrieval and processing; and the development of cross-sections and plan views as necessary to provide a visual representation of the spatial relationships of lift placements and in-place density
- testing.
I (2-18)
L [ [ The Earthwork Inspection Reports will be carefully reviewed to determine whether or not the reported activities { are in accordance with the applicable specifications and ( construction procedures. - An evaluation will be made of the validity and repre-sentativeness of the in-place density test data based on the { inspection reports, considering the reported construction methods, sequence, and conditions. The report will there-( fore be sufficiently comprehensive to allow identification l of data subsets possibly affected by any particular unique [ construction condition. { Statistical analyses will be performed using in-place density test results representing the as-built conditions. b Data subdivisions will be determined based on building areas F and construction conditions. The objective for the statistical L analysis is to establish a postulated distribution of the { overall density within an acceptable level of confidence. The in-place density test data and statistical results F L will also be evaluated in comparison to the results of the p- soil test boring program. L B. In-clace Density Tests Results _ _ _ ( As a first step in the review of backfill construction ~ quality control records, the in-place density tests were l l u 1 ~ r ^ (2-19) e _.____
k ( ( tabulated for each foot of depth of backfill placements for the different Category I Building areas and also for the { non-Category I Turbine-Generator Building areas. The data (- is also summarized in attached Table 1, "In-Place Relative Density." . [ As evidenced by the data in Table 1, the average in-place { relative density per building area, as determined by construc-tion quality control testing, ranges between 92.9-percent ( and 102.3-percent. The overall weighted average is 95.4-percent relative density for Unit 1 and 94.6-percent relative density [ for Unit 2, which should be compared to the minimum required { 80-percent relative density and the required average relative density of 84-percent. - I b C. Field Verification of Lift Thickness __ _ _ Exposed excavation slopes in the Category I structural [ backfill were mapped by WCC geologists to document the { thickness of the individual lifts within the backfill. Seventeen sections were mapped in eight separate excavations. The locations of the excavations and mapping sections are L shown on the attached Figure 1 and the lift thicknesses found are shown on the attached Figures 2 through 5. ( The typical compacted lift thickness was found to be about 10 inches which corresponds to a loose lift thickness of about 12 inches. The observed lift thickness varied r between 3.6 inches and 16.8 inches. L F L (2-20) ~
[ [ The geologists also noted a characteristic fabric in the particle orientation of the backfill material. The fabric gives a " cemented" character to the backfill and [ allows the excavations to stand on nearly vertical slopes. D. Conclusions ._ _ . . _ . The field verification of lift thickness demonstrates { that the production placements of backfill'were performed within the 18 inch maximum criteria for loose lift thick-( ness. The in-place density test data demonstrates that the backfill has been compacted to relative density values { significantly in excess of the required minimum of 80% and average of 84%. The number of in-place density tests is also significantly larger than the minimum frequency required 1 by the specification. E [ l [ [ [ ~ (2-21) l
[ .. [ [ . TMG 1 { IN-PLACE RELATIVE DENSITY Mean Relative Number Completed Unit 1 Density, % of Tests Thru Reactor Containment Building (outside) 95.4 356 8/11/79 Reactor Containment Building (Pedestal) 102.3 14 (complete) Mechanical-Electrical Auxilary Building 93.0 316 11/19/79 ( Fuel-Handling Building 95.3 340 1/8/80 Diesel-Generator Building 96.5 66 11/30/79 E Turbine-Generator Building . (non-Cat. 1) 96.3 622 11/06/79 1714 { 95.4* Unit 2 Reactor Containment
- Building (outside) 95.8 447 12/29/79 Reactor Containment Building (pedestal) 99.8 13 (complete)
Mechanical-Electrical Auxiliary Building 92.9 267 1/30/80 Fuel-Handling Building 94.0 452 1/26/80 g Diesel-Generator Building 96.1 -67 1/07/80 Turbine-Generator Building (non-Cat. 1) 94.5 653- 1/31/80 { 94.6* 1899
- Weighted Means based en F number of tests L
(2-22) ~ J
[ [ [ r____, g _ __ _ , [ l I i ! - l l N J62,000 l l
,I I 1
j ! ~'b -12 A OFFSET j l I I I i TGB [ l 1 l I
.A-9 A-Il A-lO
[ i TGB l i I 9. 1 - I T' l l l DGB ! !
^~'
- b. -- - - 8 n---_I DGB
. A-14
, A-15 A N 361,563Q N 361,500
%s %s F MEAB F MEAB
[ H B
- A-1 H
A-Bo I r
- l' I -
.A-5 , H A-3
{ 8 A-7*
~
#8
~
I
- A-16 UNIT l
_ UNIT 2 { o k k O [ t a 1 1 a W a
% W N J61,000 SOUTH TEXAS PROJECT
{ UNITS I 8 2 LOCATIONS OF LIFT SECTIONS [@ 8 A-l Through A-16 SKETCHED BY: I b - OATE: 7/7/86 h 4 OA TE: Nh 8B (N N' W ORAFTED SY- - CHECKED BY: ,h3 d d DATE: 7 I2! /7 O (2-23) VERIFIED BYN $-h_M OA TE; duh 4 TEM 2C FIGURE i r
m_ n n_ n n ~1 7 m n n n v n n n n n n n r
*8 1 -
I t 0 Locollen: A-8 odjacent to Locoilens A-2 odjacent ~ to l.acollon: Aj3 odjacent to MEAB-2 MEAB-2
- MEAS-2 Coordinales: N 61 428 E 45113 Coordinates: N 68 351 E 45 Ill Coordinales: N 68 298, E 45 068 Life: Tseas Cunn. Thhas & Life: TMas Cwn Thhas EL. Life: Thkne Cusa. Thhas &
End of Sec , Ground Surfes p.,ege 44 24.2 43 ^ 24. 4 - Os g, g 12 23.3 4 23.7 3*3 8.2 P*884*a ' u m 3.7 28.7 03 3.2 21 2 12
- m OS 2.7 46 23.2 20.4 Y 2.3 203 a7 20 20.3 4.0 22.3 83 O.4 08
~ g,4 gg g 14 21.7
'" aa a*
40
- a. .... ...
\ Os 2.3 20 6 beagsses co gao \ 00 8s t bPeellel 1.0 LAcolion: A-4 odjacent to 4.3 IS S Locollon: A-5 odjacent to a7 MEA 8-2 MEA 8-2 "* '**
as ao g3 Coordinales: N 61303, E 45 012 Coordinates: N 61304, E 44 941 lif e: Th6ns Persial Curn- Tune & I ifl: Tiens cuan. Thhae & End at seceiaa Possial End of secolon
' {Perliel 3.2 232 4.8 22.4 09 .
O9 A3 33 3 39 28.3
- 09 IO 3.4 24.4 2.9 20.3 09
.., 2.s 2a3 SOUTH TEXAS PROJECT
*~*
s.. s e.4 ., n., UNITS I & 2 3* 0.7
- 4e.3 OF 18 3 LIFT SECTIONS A-l to A-5 07 OF OO .87.4 OO 18.0 saticado av Z. ' a cata: Wr/ef
,f p.,,s.g p ,,y omattro sv < m. M # ~f/- # O cuscato av.llt# /.-,[ oats:oa t t . 2/2s les winesto er:UIsJd cals: .1hijgL
, ITEM 2C FIGullE 2
m W W W W W W W W W W W W W W W W W i Location: A-p adjacent to Location: A-7. odjacent to Location: A-lO adjacent to East side MEAB-2 MEAB-2 TGB-2 Coordinales: N 61302. E 44 899 Coordinales: N 61309, E 44 862 Coordinales: N 61872. E :5 054 Life: Thhas Cum Thhne EL Life: Thhne . Cum Thhne EL. t ill: Thane Cum Thhas EL. Ead et S ecelea "End ei Sestlesq p Peellet kad of Sessies Pesthi P f *'8888 ~/ 3.4 ' 213 y 38 235 - S.4 2L4 8.2 03 29 219
- 4. 4 224 4.4 22.8 "4 7.S 2SS i 87 LO
- 3. 4 33 28.S 34 28.8 08 41 24.8 3.3 25 207 8.0 m Os 2.1 PJ IS S 38 218 8F IS S l
l S.2 07 l t2 - 4.4 22.4 g, ggg 04 4.0 22.0 OS l& T gg 0.4 o.S on 34 28.4 _ la.2 00 1I7 nr 2.1 2a7 Location: A-8 odjacent to Location: A-9 odjacent to East side as TGB-2 TGB-2 s.s asa Coordinales: H 61343. E 44 862 as Coordinates: N 61854 E 44 873 s.o ss.O Life: Thhns ' Cum Thkas & Life: Thnne End of Seceson- Paasial fad of SecIlon , Cum Thhas & Os 18.6 (Partial 00 48.0 60 234 Os II pensjaj S.2 23D S.4 21.s
,_, af -
4.4 24.1 33 28 T Ei 40 21F OS 28 20* 32 229
- o. SOUTH TEXAS PROJECT os 28 223
- 2. 8 89 9 09 ,
UNITS I 8 2 8* ' 3.3 18 9 a, 80 20.F LIFT SECTIONS A-6 to A-lO 88 30 susicuso ev: ZM .. . . cast FN /Ao J oO Pes ales 87 8 00 19. , omas tso sr. M6-efc cars 7 W-## sese of Liff J cuscuso av: .j d oats E2 d gL vandsto er f ' 8-.m . navs : M1thiLL
- ITEM, 2C FIGURE 3 l
t 1 t r 2 r- r ca rm rm rm rm m rm.___f \ rm rm rm rm rm . rm rm r-LOcellOn A-ll adjacent to East side LOcellon: A- 12 odjacent to EOsl side Locollon: A-12 (Offset) Odjacent to East side TG8-2 TG8-2 ! TG8-2 COOrdinales: N'61873 E 44 974 Coordinales N 6'l 940. E 4 4 989 Coordinates: 'N 64 932. E 44 976 1 ill: Thhas curn Thhas EL. Life: Thbas Cum. Thhne Et.. Life: Thkas cum Thhas & Ea4 et Sessies
- Geomad surface '
g, re,isa J gh.gg, 6.2 27.9 g 3,,g.g.1(5 helle6, 20 0.3 Os - 6.0 217 O.7 08 ~ OS l o,e 43 23.3 ~ 4.4 24.5 4.3 22 s g3 0.6 04 3.s 22.3
# 04 06
. 3. 2 28.6 0.4 a4 O8 30 24.7 10 m
af 24.7 to 2.4 20s . a5 I OS 2.5 24 0 80 g. 3 2.0 23.7 04 0.7 1.3 23 6 3 0.7 8.3 19.7 1.3 23.0 a3 4.4 23.8 0.7 as 04 0.4 as ut 4 0 d c. g
\a 0.. es Lisa 14.4 00 h reasses 28.7 '
00
\ rensses 28.7 Location: A-13 Northeast of Location: A-14 Northeast Of RC8-1 RC8-1 Coordinales: N 61753, E45 582 Coordinates: N 61692, E 45 598 Life: Thhns Curn. Thhne EL. Lif t: Thans Cum Thkas EL Gaeum4 Surface restlei 4.3 24.3 06 ,
03 l4 2 End of Sociles- estilal 3 32 234 2.9 23 3 23 22.7 7 2.4 27.2 SOUTH TEXAS PROJECT
* ,4 ie 22.3 2.0 2a.s 8'
UNITS I & 2 o 2i.7 06 88 as.* 07 28.8 LIFT SECTIONS A-li lo A-14 06 88 Of 0l 20S
. 00 20.4 0.0 24.4 suitCato er: 7M- - east 7 7 3 )
g g,,, g g ,, .g ff, g re, .iu se.. e, tein, carcara avs M a***: #> ' 'r o vgnwiso er: isudsau cals: Z11;StL_. ITEM 2C FIGURE 4
x i, r., r- r r r r- _ r r, r- r rm_ r, r- rm r- r, _ cm_ _ r--- i f f a Locollon: A-15 East of RC8 -l Location: A-16 South of FHB -1 Coordinales: N 61 626. E 4 5 701 Coordinales: N 64 276. E45 396
- 8. if e Thkas Cum lhnna EL. Life Thhas cum Thhne EL.
g End of $9salea- ,Pesliel 4.7 27.7
- 0.8 3.9 28.9
, 0.9 3.0 26.0 End of Sostion
- 0. 7 Peellel 2.3 23.3 0.7 3.4 24.s '
1.7 27.0-08 O.S O8 23.4 - 0.9 28.2 04 09' ,
*00 23 0 25.3 Penales \- se.0.0 o .e use SOUTH TEXAS PROJECT UNITS 18 2 LIFT SECTIONS A-15 to A-16 smascuto ev: I & w assa: MV8M oasesgo e, /Gueo asse .'f-2^ so enscuro av:1441osts:
vsainco es.uldm h/JL osss 3lh,iL ITEM 2C FIGURE 5
[ V. RESPONSE TO ITEM (2)(d): Adequacy of Existing Backfill Determination of the adequacy of the existing backfill { is based on information derived from programs required by Items (2)(a), (2)(b), and (2)(c) together with the results from b the field investigation boring programs. Special evaluations have been made regarding the conditions and engineering significance of the top lift of the backfill immediately { below foundations, and of the overall adequacy of the density distribution within the backfill. The presence of [ pockets, with a comparatively less density than the overall backfill has also been considered. b The Independent Review Committee has reviewed all [ pertinent aspects of the structural backfill design studies, specification criteria, construction procedures, and inspec-E tion and testing documentation. The committee members l j 1 also made direct independent site observations. A. Special Studies and Investigations _ . _ . _ .j { (1) Backfill Immediatelv Below Foundations . _ . _ The significance of the density distribution within E the surface lift immediately below mat foundations was { analyzed by the committee. The test fill program (see { Section II above) de.monstrated that the lower and middle [ parts of the surface lift can be effectively compacted E E (2-28)
[ [ while the top part remains in a comparatively less dense state. { The NRC Investigation Report concluded that 6 to 9 ( inches of material below the mat foundations- may not have - sufficient density to satisfy the quality control criteria, [ (at Page 63). The performance of the top layer below mat { foundations during an earthquake event causing an acceleration of 0.lg, was evaluated for two assumed density distributions b that envelope the case described by the NRC report. The analytically determined factor of safety against liquefac-b tion was found to be 1.85 assuming a relative density of { only 45% for a 4-inch layer immediately below the mat foundations. The results would not change significantly by b assuming as an alternate condition, that the middle portion of the lift (4 to 10-inch depth) has been compacted to as little as 60% relative density. - { (2) Boring Investigations The boring program completed in April, 1980 was con-ducted to obtain supplementary field test data to evaluate p the engineering adequacy of the Category I structural L backfill. [ Initially a total of 288 standard penetration tests were performed within the Category I structural backfill of r L which 97.2% (280 tests) indicated relative densities above r L (2-29)
I the 80% acceptance criterion. Relative densities below 80% occurred in 4 locations (5 pockets; one location included l two pockets) of Unit 2. These low density pockets were further investigated by drilling an additional 26 borings. It was determined that 4 of these pockets are of very limited extent, typically about 100 square feet or less in one lift. However, one area located west of the Unit 2 Reactor Containment Building (RCB) was found to consist of a zone near the subgrade with several sub-pockets having I relative density below the 80% construction quality control I criteria. (See Exhibit 9 for general description.) The Independent Review Committee analyzed these con-ditions to determine the liquefaction potential of the areas having less than 80% relative density. The analysis of the area west of the Unit 2 RCB shows that the factor of safety against liquefaction is greater than 1.5 at all locations except for one isolated test re-sult having a factor of safety of 1.4. The other 3 areas (which include 4 pockets) have substantially higher factors . 1 of safety against liquefaction. B. Conclusions _. I The Independent Review Committee has concluded that the backfill is sufficiently dense to provide a substantial l degree of safety against liquefaction during the postulated l L (2-30) F -
E- [ [ Safe Shutdown Earthquake (SSE). The boring program was { judged adequate to provide a representative sample of the backfill conditions, and the Independent Review Committee I concluded that the condition of the backfill: as-placed is - adequate. The condition of the surface lift, immediately [ below mat foundations, was determined not to have signifi- { cant effect'on the performance of the buildings in a postu-lated SSE event. - [ VI. RESPONSE TO ITEM (2)(e): Rationale of Construction Procedures _ _ . [ The 18 inch maximum loose lift thickness is defined by the structural backfill design specification, while the 8 [ passes is the minimum required compaction effort required by_ the construction procedures for subsurface lifts. The { formulation of the construction procedure is briefly described [ in section II above. The test fill program described in that Section reconfirmed the correctness of the specification [ and construction procedure criteria. { The design specification for Category I backfill relies on in-place density tests of each lift to assure adequate l [ compaction. The construction procedure uses the minimum of 8 roller passes with the "10-ton" vibratory roller as a [ control point by conservatively defining the minimum effort { that is to be required before interrupting the work for in- [ [ (2-31) ) i
l [ [ place density testing. The incremental gain in density for { each pass beyond 8 is rapidly diminishing. The-density distribution with depth within the backfill, as observed in the underlying lift, has also gained significant homogeneity after 8 passes on the overlying lift. - [. Exerting a minimum compaction effort of 8 passes [ generally ensures engineering adequacy of the backfill independent of the in-place density tests, i.e. the backfill will have adequate strength and liquefaction resistance. Compliance with the operational requirements of the compac- [ tion procedure generally assures that the underlying lift [ reaches the 80 percent relative density quality control I criterion within the accuracy of the testing methods. Localized deviations from that criterion are-inconsequential. The use of maximum 18 inch loose lifts, has resulted in an average of nearly 95 percent relative density, as [ measured by in-place density tests. The Standard Penetration Tests (test borings) indicate that the final density of the [ completed backfill, which includes all the overlapping L ' effects of subsequent compaction of overlying lifts, exceeds 100 percent relative density, at most locations. [ Thus, the use of 18 inch loose lifts compacted by a minimum of 8 passes has been a sound construction practice, j t resulting in Category I structural backfill which conserva- 1 l E tively satisfies the engineering adequacy requirements. l L (2-32)
i i VI. RESPONSE TO ITEM (10): FSAR Descriouion A comprehensive evaluation is being performed of FSAR Section 2.5.4, " Stability of Subsurface Materials", especially Section 2.5.4.5 " Excavations and Backfills." Based on the evaluation completed to date an FSAR amendment will be sub-i mitted to clarify the description of the construction process. Two particular items have initially been investigated: Section 2.5.4.5.6.2.4, " Placement and Control Requirements for Backfill", regarding the performance of one relative density test (ASTM D2049) for every fourth field test; and Section l 2.5.4.5.6.2.5, " Backfill Inspection and Testing Requirements", ' regarding inspection of backfill placements. A. Summarv of FSAR Review and Verification l (1) Placement and Control Recuirements for Backfill ) I The actual number of maximum / minimum Relative Density laboratory tests has been compared to the actual number of in-place density tests for the plant area. " Plant area" includes the backfill for the main structures, but excluces the Essential Cooling Water System piping and structures. The following results were obtained based on data collected l through April 3, 1980: I l l (2-33) i
[ [ In-Place Density Max./ Min. [ .-.-.. Area Tests Lab. Tests .. Ratio _ _ _ . . . Unit 1: All Work 2571 (incl. 646 -3.98 619 retests) Cat. I 1734 429 4.04 Unit 2 : { All Work 3127 (incl. 775 4.03 854) Cat. I 1802 448 4.02 - [ The above data shows that on the average one maximum / { minimum laboratory density test has been obtained for four in-place density tests, in the plant area. However, the ( laboratory tests have not always been made for every fourth field test, but there have been varying intervals depending on [ the work schedule, and placement sequence considering whether { material came from different sources. These variations are not significant since the acceptance criteria ~are based on the average of 20 laboratory tests. A preliminary investigation of the placements of Category [ I structural backfill for the Essential Cooling Water System ( (ECWS) piping has revealed that the required frequencies of maximum / minimum laboratory density testing were not adhered to. NRC I&E Region IV has been notified and a nonconformance h ,m [ (2-34)
L [ [ report (S-C-4004) has been written. The nonconformance will { be resolved when the placement sequence and in-place density testing data for the ECWS piping has been compiled. ( B. Backfill Inspection and Testing Requirements __. _ . . _ _ The QC Inspectors from the testing agency were on duty [ during the backfill placements. Inspection was-performed { with the objective to assure that the criteria of t%1e specification and construction procedures were satisfied. b For example, the QC Inspectors determined that the lifts were within the 18-inch maximum thickness and that the [ minimum required number of roller passes were performed. { The QC Inspectors recorded the observations on checklists. Observance of the minimum required 8 roller passes was re- [ corded as " acceptable," witl$out notation of the actual total number of passes. Likewise, the lift thickness was [ recorded _as "18-inch"'= indicating that the specification [ limit was satisfied even though the actual thickness generally was much less than 18 inches. A complete review of the Earthwork Inspection Reports is being performed to further verify compliance with the construction and inspection requirements. The lift thick- [ nesses have been verified as far as practical by mapping of exposed cut surfaces in the backfill. The lifts are F L found to vary between 3.6 and 16.8 inches after compaction. E (2-35)
[ [~ The future inspection activities will be conducted under { engineering direction to assure satisfactory inspections supported by comprehensive documentation. ( C. FSAR Amendments - . . - . FSAR Subsection 2.5.4.5.6.2.4, " Placement and Control [ Requirements for Backfill" - the second paragraph of the { subsection will be changed as follows: One relative-density test (ASTM D 2049) and one gradation test (ASTM D 422) were performed on the ( average for every four field tests in the plant area, to ensure compatibility between field and laboratory tests. FSAR Subsection 2.5.4.5.6.2.5, " Backfill Inspection and Testing { Requirements" - the first paragraph of the subsection will be changed as follows: b The testing. agency provid'ed QC inspection of the back-fill, the placement and testing of the material in the field for degree of compaction. The QC inspectors [ observed the type of material, lift thicknesses, operation of compaction equip:nent, and all other pertinent material or construction conditions affect- { ing the quality of work and compliance with the specifications. The QC inspectors noted conform-ance with the limiting criteria of the specification r L and construction procedure for structural backfill and reported the acceptability of the operation. The frequency of . . . etc. I L MS:06:F I C m ~ (2-36) - i
L EXHIBIT 6
\
[
\
[ Elk Prefzssional Qualifications and Chairman, Committee on His interest in instrumentation [ Birgraphical Data for Performance of Earth Supported began while he was a teaching L Structures (1968-69). fellow and assistant professor of Stanley D. Wilson, P.E. 1961, Recipient of Research soil mechanics and foundation p Consulting Civil Engineer Prize engineering at Harvard University L (Formerly Executive Vice-President, 1968 Recipient of Arthur M. from 1946 to 1953. Mr. Wilson Shannon & Wilson, Inc., Seattle) Wellington Prize developed a tiltmeter, now known 1969, Sixth Karl Terzaghi as the Slope Indicator instrument, { Lecturer 1978. Karl Terzaghi Award after extensive research of earth and rock movements under dynamic Education . American Society for Testing and loads and landslide conditions. Since that time, he has been { Sacramento Junior College, 1930-32 Materials Boston Society of Civil Engineers involved in the research and development of many other fleid University of Minnesota,1943 Consulting Engineers Council of p S.M. in Civil Engineering, Washington and laboratory instruments. L Harvard University,1948 Harvard Society of Engineers and Mr. Wilson contributes his Scientists experience in instrumentation and International Society of Soil extensive knowledge about the [ Rsglstration Commonwealth of Massachusetts Mechanics and Foundation Engineering deforrnations of earth and rockfill dams on many major hydroelectric Stata of California Member, Naticnal Academy of projects. He serves as a consultant { Stats of Minnesota Stats of Nevada Engineering Society of Sigma Xi to the Comision Federal de Electricidad and Secretaria Stats of Oregon U.S. Committee on Large Dams Recursos de Hidraulicos in Mexico,
~
Stats of Washington to Agua y Energia Electrica in
- Argentina and to Empresa Nacional Professional Background de Electricidad S.A. in Chile on the
_ Professional Societies Mr. Wilson is an internationally design and construction of major and Honors recognized authority on earth and hydroelectric and water storage rockfill dams and serves as a dams. Fellow, American Society of Civil Engineers consultant on major hydroelectric In the United States, he advised on { Soil Mechanics and Foundations Division: Chairman, Publications projects all over the world. He is also an expert in laboratory and field Brownlee and Oxbow Dams in Idaho, Mammoth Pool Project in Committee (1950-52). Chairman, instrumentation used in California, Muddy Run and Seneca Committee on Technical ge technical engineering and has pumped storage projects in F devel ped techniques and special L Stssions (1953). Member, Pennsylvania, Ludington Pumped equipment for measurement of Storage Reservoir in Michigan Exscutive Committee (1954-57). earth and rock movements. and Rock Island Dam in t
I . Wishington. Other consulting Publications Switzerland, Vol.1,1953, assignments were performed for the p. 106-110.
" Improved Technique Saves Time U.S. Army Corps of Engineers on in Obtaining Undisturbed Chunk " Effects of Stress Histo y on the fiva major dams and associated rail Samples of Clay" by R.W. Strength of Clays" by A.
I and highway relocations, and for the Division of Dam Safety of the Cilifornia Department of Water Brandley and S.D. Wilson, Civil Engineering, Vol.18, No. 4, April,1948, p. 238-240. Casagrande and S.D. Wilson, Harvard Soil Mechanics Series, No. 43, Harvard University, I R: sources. He also served as inst t entat n he Seattle "Small Soil Compaction Apparatus Duplicates Field Results Closely" by S.D. Wilson, Engineering News-June,1953.
" Field Measurement of Stresses in an Anchored Steel Bulkhead" by District, U.S. Army Corps of I Engineers, on left abutment stability problems at Libby Dam.
Record, Vol.145, No.18, November, 1950, p. 34-36.
" Comparative Investigatior' of a S.D. Wilson, paper presented at the American Society of Civil Engineers annual convention, New York, H.is consulting assignments in other October,1955 (Not in print).
I prrts of the world included the Karnafull Project in East Pakistan, tha Volta River Project in Ghana Miniature Compaction Test With Field Compaction" by S.D. Wilson, paper presented at the American
" Safe Loads on Dog-Leg Piles" by J.D. Parsons and S.D. Wilson, Society of Civil Engineers annual Transactions, American Society of I and the Bandama River Projects in Ivory Coast.
Mr. Wilson also has served as a meeting, January,1950 (Not in print), Civil Engineers, Vol. 21,1956,
- p. 695-721.
"Effect of Rate of Loading on " Detection of Landslides" by S.D.
consultant on major projects Strength of Clays and Shales at Wilson, Proceedings,11th involving the stability of open-pit
,,by A. Northwest Conference on Road minis, major slide investigations Casagrande and S.D. Wilson, Building, University of Washington, and protection work adjacent t I ,
restrvoirs. Mr. Wilson is an active lecturer, Geotechnique, Vol. 2 No. 3 June,1951, p. 251-263.
"Effect of Compaction on Soil 1958, p.118-123.
" Suggested Method of Test for Moisture-Density Relations of Soils I educator and member of many advisory and consulting boards for gov;rnment agencies and industrial Properties" by S.D. Wilson, Proceedings, Conference on Soil Stabilization, Massachusetts Using Harvard Compaction Apparatus" by S.D. Wilson, Procedures for Testing Soils, firms. He is an affiliate professor I at ths University of Washington and lectures frequently at the University institute of Technology,1952 p.148-158.
" Control of Foundation Settlements American Society for Testing and Materials, Philadelphia, Pennsylvania, April,1958, of California and other universities. p.133-135.
He his conducted short courses on Y Preloadin9 bY S.D. Wilson' instrumentation for the U.S. Army Journal of the Boston Society of " Application of the Pn.nciples of Civil Engineers, Vol. 40, No.1, Soil Mechanics to Open-Pit Mining" { Corps of Engineers. Among the January,1953, p.10-24. by S.D. Wilson, Quarterly of the I J advisory boards on which he has s;rved are the Safety Panel of Consultants for the Energy "Prestress Induced in Consolidated-Ouick Triaxial Colorado School c/ Mines, Vol. 54, No. 3, July,1959, p. 93-113. Res; arch and Development Tests" by A. Casagrande and " Horizontal Displacements of Clay Administration and the advisory S.D. Wilson, Proceedings, 3rd Foundations" by S.D. Wilson and , panni on soil mechanics for the International Conference on Soil C.W.lHancock, Jr., Proceedings, l Office of the Chief of Engineers, Mechanics and Foundation 1st Pan-American Conference on U.S. Army. Engineering, Zurich and Lausanne. Soil Mechanics and Foundation
I i r-r- f Engineering, Mexico DF, Vol.1, Society for Testing and Materials. 1959, p. 41-64. and S.D. Wilson, Journal of the Philadelphia, Pennsylvania, Soil Mechanics and Foundations "Effect of Consolidation Pressure STP 322,1962, p.187-197. Division, American Society of Civil on Elastic and Strength Properties Discussion by S.D. Wilson and Engineers, Vol. 93, No. SM4, July, l of Clay" by S.D. Wilson and R.J. R.P. Miller of " Foundation 1967, p. 325-353 Di: trich, American Society of Vibrations" by F.E. Richart, Jr., Civil Engineering Research " investigation c, Embankment Transactions, American Society Performance" by S.D. Wilson, Conference on Shear Strength of of Civil Engineers Vol.127, Pt.1, Cohesive Soils, Aoulder, Colorado. 1962, p. 913-917, Journal of SoilMechanics and 1960, p. 419-435 and 1089-1092. Foundations Division, American
" Slides in Over-Consolidated Clays Society of Civil Engineers, Vol. 93,
" Slope Stabilization in Open-Pit No. SM4, July,1967, p.135-156.
Along the Seattle Freeway" by Mining" by S.D. Wilson, Mining S.D. Wilson and K.A. Johnson, Congress Journal, Vol. 46, No. 7, Proceedings,2nd Annual "How To Determine Lateral Load July,1960, p. 28-33. Capacity of Piles" by S.D. Wilson Engineering Geology and Soils Engineering Symposium, Idaho and D.E. Hilts, Wood Preserving "An Unsolved Problem of Embankment Stability on Soft News, Vol. 45, No. 7. July,1967, State University,1964, p. 29-43. p.12-17; also published under the Ground" by A. Casagrande;
" Instrumentation for Movement same title in Pi/e Foundation discussion by S.D. Wilson, ca.1961 I (Not in print).
Within Rockfill Dams" by S.D. Wilson and C.W. Hancock, Jr., Know-How, American Wood Preserves institute, Washington,
" Landslide Causes and instruments and Apparatus for M* M. > H I Corrections" by S.D. Wilson, Procredings,9th Anneal S iland R ek Mechanics, American Society for Testing and
" Performance of Muddy Run Embankment" by S.D. Wilson and Conference on Soil Mechanics Materials, Philadelphia, D. Marano, Journal of the Soil End Foundation Engineering, Pennsylvania, STP 392,1965, Univ;rsity of Minnesota,1961, p.115-130. Mechanics and Foundations
- p. 26-33. Division, American Society of Civil
" Vibration Apparatus for Engineers, Vol. 94, No. SM4, July, "FiIld Problems: Field Determination of Elastic Proper:les 1968, p. 859-881.
Me:surements" by W.L Shannon, of Soil" by S.D. Wilson and E.A. Kaarsberg, Felsmechanek und " Field instrumentation of S.D. Wilson and R.H. Meese, Excavations" by S.D. Wilson, Foundation Engineering, G.A. Ingenieurgeologie (Rock Proceedings,18th Annual Soil Leonirds, ed., McGraw-Hill Book Mechanics and Engineering Co., New York,1962, p.1025-1080. Geology), Vol. 4, No.1,1966. Mechanics and Foundation p.14-24. Engineering Conference, University of Kansas,1969. ast Loa i " yS W " Landslides in the City of Anchorage" by S.D. Wilson, The "Recent Advances in Technology E.A. Sibley, Journal o/ the Soil Prince William Sound, Alaska. of Earth Retaining Structures" by M:chtnics and Foundations S.D. Wilson, Proceedings,17th i Division. American Society of EartWake of M and Annual Conference on Sod Civil Engineers, Vol. 88, No. SwiS* Aftershocks, Vol. 2. Pt. A, F.J. Mechanics and Foundation l Dec:mber,1962, p.1-31. Wood, ed., U.S. Coast and Geodetic Engineering, University of Survey, Washington, D.C.,1967, Minnesota,1969.
, "Th] Use of Slope Measurin9 p. 253-297.
Devic;s To Determine Movements Earth and Rockfill Dams" by S.D'
" ,*The Turnagain Heights Landslide, Wilson and L.R. Squier, State o/
. d Te g S A Anchorage Alaska" by H.B. Seed the Art Volume,7th International l
l *
?
l 1 l I .I . l ! t Conf;rence on Soil Mechanics an'd Denver, Colorado,1972, Vol. 2, of Dams and Slopes" by 1. Arango l ' Fcundation Engineering, Mexico, p. 96-122. and S.D. Wilson, Proceedings, 5th I 1969, p.137-223. "The Baldwin Hills Reservoir Pan-American Conference on Soil t, "Pr;dicted Performance of a Failure in Retrospect" by A. Mechanics and Foundation . Bracid Excavation" by H.O. Casagrande, S.D. Wilson and E.D. Engineering, Buenos Aires,1975, , Gold:r, J.P. Gould T.W. Lambe, Schwantes, Proceedings, Specialty Vol. 2, p. 385-394 G.P. Tschebotarloff and S.D. Conference on the Performance of " Influence of Field Measurements Wilson, Joumal of the Soil Earth and Earth-Supported on the Design of Embankment , MechInics and Foundations Structures, Purdue University,1972 Dams" by S.D. Wilson, Specialty ; Division, American Society of Civil p. 551-588. Session 8, Deformation of Earth- 1 Engineers, Vol. 96, No. SM3, May, " Instrumentation for Dams" by S.D. Rockfill Dams, 9th International , l 1970, p. 801-815. Wilson, Bulletin, Association of Conference on Soil Mechanics and ,
"Fi:Id Measurements - Earth Engineering Geologists, Vol. 9, No. Foundation Engineering, Tokyo, !
Structures" by S.D. Wilson, Soil 3, Summer,1972, p.143-157, 1977, p.19-35. r
" Instrumentation Applied to Slope " Foundation instrumentation-I Mrchtnics Obs rvational lecture Series, Methods in Soil and Stability Problems" by S.D. Wilson inclinometers, Reference Manual I Rock Engineering, Soil Mechanics and D.E. Hilts, Transportation for a 45-Minute Color Video-Tape Engineering Journal, American Presentation" by S.D. Wilson and r I and Section,Foundation Division, American Society of Civil Illinois Society of Civil Engineers, Vol. 98, P.E. Mikkelsen, FHWA TS-77-279, Engineers, and Department of No. TE3s August,1972, p. 563-576; U.S. Department of Transports: ion. j'{
M:t:rlits Engineering, University of also Transactions, American Federal Highway Administration, , lilinois, Chicago,1970, p. 67-90. Society of Civil Engineers, Vol.138, Washington, D.C.,1977. l*
" Observational Data on Ground p.316,1973. "In-Situ Determination of Dynamic Movements Related to Slope ., Deformation of Earth and Rockfill Soil Properties" by S.D. Wilson, I St:bility (6th Terzaghi Dams" by S.D. Wilson, F.R. Brown, Jr. and S.D. Schwarz, by S.D. Wilson, Joumal ofLecture)"
the Soil Embankment-Dam Engineering, Dynamic Soil and Rock Testing {1 t M:chtnics and Foundations Casagrande Volume, R.C. in the Field and Laboratory for ; Division, American Society of Civil Hirschfield, S.J. Paulos, eds., John Seismic Studies, American Society ' I Engineers, Vol. 96, No. SMS, Wiley & Sons, New York,1973. for Testing and Materials, Sept;mber,1970, p.1519-1544; p. 365-417. Philadelphia, Pennsylvania,1977 (in 1 also published under the same title press). ' l
" Landslide Instrumentation for the Iin Civil Engineering Frontiers in Minneapolis Freeway" by S.D. ,, Current Trends m, Design and )
Environmental Technology, Wilson, Transportation Research Construction of Embankment D:p:rtment of Civil Engineering, Record 482,1974, p. 30-42. Dams by S.D. Wilson and R.J. , IUniv:rsity of California, Berkeley, Marsal, paper submitted to the 1971, p.145-172. " Incompatibility of Materials and e a nal mnce on large lt l j D: sign Considerations for Deep-Effect on Dam Performance" bY S.D- Dams,1978 (in press). . R:tained Excavations in Over- Wilson, paper presented at the , 1 Consolidated Seattle Clays" by Program on Recent Developments f j R.J. Strazer, LK. Bestwick and in Design, Construction and I S.D. Wilson, Proceedings, Performance of Embankment Expansive Clays and Shales in Dams, University of California. l ; Berkeley, June,1975 (Not in print). Highw:y Design and Construction, {l Fed:ral Highway Administration, "Sehmic Stability and Deformations i 'I -4 i
N
. EXHIBIT 7 I
H. Bolton Seed I . Biographical Sketch I. Born in 1922, H. B. Seed was educated at London University where he received the degrees of B.Sc. and Ph.D. and at Harvard University where he was awarded the S.M. Degree. He has been a member of the teaching staffs I at London University and Harvard University and has also been employed as a foundation engineer with the consulting firm of Thomas Worcester, Inc. Since 1950 he has been on the staf f of the University of California I at Berkeley where he is Professor of Civil Engineering and a former Chairman of the Department of Civil Engineering. He also serves as a consultant to a number of major engineering companies and government agencies including the Executive Office of the President, the U. S Army Corps of Engineers, the U. S. Water and Power Resources Service, the National Science Foundation, the Federal Energy Regulatory Commission, the Department of the Interior, the Advisory Committee on Reactor Safeguards , the State of California Department of Water Resources, and the State of California Division of Safety of Dams, as well as government agencies in Canada, Guatemala, Argentina, Saudi Arabia and Venezuela. He is also a member of the State of California Seismic Safety Commission and the I US - USSR Task Force on Foundation Design for Cold Regions and Unusual Geologic Conditions. In recent years he has also served as Chairman of the Committee, Advisory to the Secretary of the Interior, on Geological-Seismological Factors Pertaining to the Siting of Nuclear Desalting Plants; i as a consultant to the National Aeronautics and Space Administration, and l the U. S. Geological Survey; as a U. S. Delegate to the Panel on Aseismic i Design and Testing of Nuclear Facilities of the International Atomic Energy Agency, and the U. S. - Japan Science Conference on Soil Dynamics; as l Co-Chairman of the U. S. - Japan Science Conference on Soil Behavior and I Ground Motions During Earthquakes; and on the Independenc Panel, appointed by the Secretary of the Interior, to investigate the Cause of Failure of Teton Dam. His world-wide consulting work is primarily concerned with design I aspects of nuclear power plants, major earth dams projects, of f-shore structures and seismic design problems. j I The author of over 200 papers on soil mechanics problems, he has been the recipient of a number of awards by the American Society of Civil Engineers including the Norman Medal (1968, 1977), the Karl Ter:aghi Award 1 (1973), the Croes Medal (1960, 1962 and 1972), the Middlebrooks Award (1958, I 1964, 1966 and 1971), the Thomas Fitch Rowland Prize (1961), the Wellington Prize (1968), and a Society Research Prize (1961) h In 1967 he was invited j l by the Society to present the Fourth Ter aghi Lecture at the Structural I Engineering Conference in Seattle, and in 1970 he was elected a member of the National Academy of Engineering. In 1976 he received the Bendix Award for distinguished research from the American Society on Engineering Education I and a Distinguished Teaching Award from his colleagues at the University of I 1
..m I Californie He was elected Fellow of Kings College, London University in
)
1 1978, and he was the 1979 Rankine Lecturer of the Institute of Civil Engineers, Great Britain. He has served as a rnerber of the Executive Committee of the Soil Mechanics and Foundations Division of the American Society of Civil Engineers, the Executive Committee of the Department of Soils, Geology and Foundations of the Transportation Research Board. He is Secretary of the U. S. National Corr:nittee on Soil Mechanics and Foundation Engineering and a member of the Executive Committee of the International Society for Soil Mechanics and Foundation Engineering. He is also an active rnerber of the Seismological Society of America, the Structural Engineers Association of Northern California, a Sumber of Committees of the Geotechnical Engineering Division of ASCE, the Earthquake Engineering Research Institute, the U. S. Committee I on Large Dams, and the International Society for Soil Mechanics and Foundation Engineering.
~
/
I I I . . I I - I I I EXHIBIT 8 Professional Background and Experience Name: Alfred J. Hendron, Jr. Address: 2230c Civil Engineering Building I University of Illinois at Urbana-Champaign ! Urbana, IL 61801 ' Date of Birth: October 4, 1937 ' Marital Status: Married with 2 children l Citizenship: Natural Born - U.S. Education __ l Ph.D. 1963 University of Illinois Major: Soil Mechanics I Urbana, Illinois Minors: Foundations Geology Theoretical and Applied Mechanics l M.S. 1960 University of Illinois Civil Engineering Urbana, Illinois l B.S. 1959 University of Illinois Civil Engineer Urbana, Illinois (Bronze Tablet)ing I Positions Held September 1970 - Present Professor of Civil Engineering University of Illinois September 1968 - September 1970 Associate Professor of Civil Engineering I University of Illinois September 1965 - September 1968 Assistant Professor 6f Civil Engineering l University of Illinois September 1963 - September 1965 1/Lt. U. S. Army Corps of Engineers l Research Engineer U. S. Army Engineer Waterways Experiment Station ; I. June 1961 - September 1963 Research Associate University of Illinois June 1960 - September 1960 Engineer, Shannon & Wilson Soil Mechanics and Foundation Engineers Seattle, Washington i
[ Alfred J. Hendron, Jr. Page Teaching Experience Undergraduate Courses, University of Illinois ' 1961-1963 Introductory Soil Mechanics ( 1965-Present Introductory Soil Mechanics Foundation Engineering Civil Engineering Design Course for [ Senior Honors Students Graduate Courses ( 1965-Present Rock Mechanics Applied Rock Mechanics Applied Soil Mechanics [ Soil Dynamics (Including Earthquakes effects) Graduate Thesis Supervision * ( Directed 4 Ph.D. Theses Currently directing 2 Ph.D. Theses [ Research Exoerience [- 1961 - 1963 Research Associate, University of Illinois Conducted research on the high pressure compres- j sibility of sands and measurement of the l { coefficient,of earth pressure at rest. ' 1963 - 1965 U. S. Army Engineer Waterways Experiment Station l Conducted research on stress wave propagation [ in soils, design of structures for dynamic l loading, and developed a research program in rock mechanics. 1965 - Present University of Illinois Presently conducting research on the following [ specific topics: (1) Ground vibrations produced from blasting tunnels and open cuts in rock. Presently [ responsible for blasting vibration measure-ments being made on Washington D.C. Subway project. [' (2) Compressibility of large sized granular j materials such as that used in rock fill and rolled earth dams. [ (3) Theoretical studies of inelastic and time dependent stress distribution around tunnels. (4) Effect of pore pressures on the strength L of rock. (5) Three dimensional analysis of slope stability in a jointed rock mass. r (6) Design of tunnel linings in soil and rock. L (7) Ground motions produced by nuclear explosions. I' - l
L Al fred J. Hendron, Jr. [ Page Offices held and other services to professional societies (1) Member of the Research Committee of the Soil Mechanics and Foundations [ Division of the American Society of Civil Engineers (1967-69). (2) Member of Subcommittee 12 of Committee D-18, ASTM, Properties of ( Soil and Rock, 1965-1970. (3) Co-chairman of Panel on " Stress Wave Propagation 'in Soils," [ International Symposium on Soil Dynamics. Albuquerque, New Mexico, sponsored by ASCE & NSF, August 1967. { (4) Panel member for " Dynamic Loading," Session of a national Specialty Conference on Placement and Improvement of Soil to Support Structures," sponsored by the Soil Mechanics and Foundations Division of the Arnerican Society of Civil Engineers, M.I.T. , August 1968. { (5) April 1968 - Gave lectures on rock mechanics to Metropolitan Section ASCE, New York City. (6) April 1969 - Gave lectures on rock mechanics to Metropolitan Section ASCE, Washington, D.C. (7) Selected to give a lecture on " Field Instrumentation in the Design of Underground Structures in Rock," Metropolitan Section, ASCE, [ New York City, May 1970. (8) Panel member on " Dynamic Loadings and Deformations," Session for f L ASCE, Soil Mechanics and Foundation's -Division Specialty Conference on'" Lateral Stresses in the Ground and the Design of Earth Re-taining Structures," Cornell University, June 1970. (9) Member of Panel on " Deformation Modulus of Rock Foundations," ASTM Symposium on Deformation Properties of Rock, Denver, February 1969. [ (10) Selected by NSF as one of the U. S. Members to exchange meeting with Japanese Engineers on the Topic of Ground Motions produced by earthquakes, U. of California at Berkeley, August 1969. [ Member of Committee on Soil Dynamics, Soil Mechanics Division, (11) , ASCE, 1970 - present. I [ (12) Member of Publications Commi'. tee for Journal of the Soil Mechanics l and Foundations Division, ASCE, 1970 - present. l [ c L I
Alfred J. Hendron, Jr. Page l Consulting Exoerience l Examples of Rock Engineering Exoerience
- 1. Consultant to the American River Constructors on the stability of 300 I ft. high rock slopes for the spillway cut at Hell Hole Dam, American River Project.
I 2. Consulted, as associate of Dr. D. U. Deere, on rock mechanics problems related to the foundations of the Wori Trade Center Building, New York City (110 story office building).
- 3. Consultant to New Yor.k Port Authority on Controlled Blasting Techniques to reduce damage to adjacent structures for Journal Square Subway Terminal.
I 4. Consultant to Western Contracting Company on stability of 150 ft high vertical spillway cut, Stocton Dam, Stocton, Mo.
- 5. Consultant to British Columbia Hydro Authority, Canada, en assessing stability of Portage Mountain Underground Powerhouse .
- 6. Consultant to Fenix and Scisson on the design of a rock cavity and steel casing at a depth of 6,000 ft. In weak rock on Amchitka Island.
- 7. Slope stability problems along the Transandean Pipeline, Colombia, S.A., for. Williams Brothers Construction Co.
- 8. Consultant to Joseph S. Ward, Foundation Engineers on the design of a school to resist blasting vibrations, Manchester, New Jersey.
- 9. Consultant to Architest's Collaborative, Cambridge, Mass., on controlled blasting techniques and blasting vibrations on IBM building complex, Fishkill, N.Y.
- 10. Stability of soil and rock slopes for Transalaskan Pipeline.
~
- 11. Consultanti to Deleuw Cather & Co. on Blasting Specifications for Washington D.C. Subway.
- 12. Stability of open pit mine slope - Climax Molybdenum Co. , - Climax, CO.
- 13. Consultant to British Columbia Hydro on the effects of a new reservoir on the stability of Downie Slide (1 billion cubic meter slide). ,
1
- 14. Consultant to Gibbs & Hill on a slope adjacent to the Ohio River ;
j near Pittsburgh for sludge pipeline construction, slope 500 ft high. ' l
- 15. Consultant on effect of blasting on stability of slopes of Caue 1 Mine, Itibira, Brazil, slope 800 ft high.
l l ( Alfred J. Hendron, Jr. Page , Examples of Foundation Engineering and Earthouake Engineering Exoerience [ 1. Consultant to Williams Brothers Construction Compa . on slope stability problems encountered in construction of tr.e Transandean Pipeline in southern Colombia, S.A.
- 2. Consultant to Woodward-Clyde and Associates on the Foundation Design of Davis-Besse Nuclear Reactor for earthquake loadings.
- 3. Consultant, as an associate of Dr. N. M. Newmark, on the foundations for a 40 story building in Vancouver, B.C. , designed for earthquake loading.
- 4. Consultant to Waterways Experiment Station on the Earthquake Stability of Dam Slopes. ~
[ 5. Consultant to H. G. Acres Ltd. on Seismic considerations for Nuclear Reactor Foundations as a part of a study for 6 New England States on Projected Power Needs. {
- 6. Consultant, as an associate of Dr. N. M. Newmark, to the Divisions
[ of Reactor Licensing and Reactor Safety of the Atomic Energy Comis-sion, on the adequacy of nuclear reactor foundations to resist i earthquake loading, September 1967 - present. The following is a list of the Nuclear Power Station Foundations reviewed during this [ time: Ft. Calhoun Arnold Cooper Pilgrim [ Surry Crystal River i l Shoreham Prairie Island Salem Farl ey [ Rancho Seco Diablo Canyon Calvert Cliffs Oconee Sequoyah Indian Point [ Hatch Brunswick Bailey D. C. Cook Kewaunee Zimmer Fitzpatrick 3 Mile Island [ Bermi Russellville Turkey Point Easton Bell [- 7. Dynamic stability assessment of 3 TVA dams subjected to design earthquakes. F l [ _s_ L F .
[ , l l Al fred J. Hendron , Jr. Pt.ge l l Experience on Desion of Protective Structures and Nuclear Effects I 1. Consultant to TRW Systems, Redondo Beach, California on Dynamic 1 Scil Properties pertinent to the hardness of the Minuteman System.
- 2. Presently member of a panel in Dept. of Defense to review design of all Safeguard Structures for Vulnerability and hardness.
- 3. Consultant to Omaha District Corps of Engineers on the con-I struction of underground protective structures in rock.
- 4. Consultant to Air Force Space and Missile Systems Organization '
l on Hardness of Minuteman Structures as an associate of Dr. N. M. Newmark. S. Consultant on problems in soil dynamics and rock mechanics to the I l U. S. Army Engineer Waterways Experiment Station, Vicksburg, MI. l 6. A member of the "Decoupling Advisory Group" formed by the Defense i Atomic Support Agency. Responsibility is to comment on stability I I. problems which might be encountered in building underground cavities 100-360 ft in diameter and to give the shear strength properties of rock masses which are important in determining the decoupling charac-teristics of cavities over-driven by the detonation of a nuclear device. l 7. Received Army Commendation Medal in 1965 for representing the Chief of the Coprs of Engineers as a consultant to the Norwegian Government I l and NATO on the engineering of large underground facilities. Recent Publications "The Behavior of Sand in One-Dimensional Compression," Ph.D. Thesis, U of I, Dept. of Civil Engr. , July 1963; "The Dynamic Stress-Strain Relations for a Sand as Deduced by Studying its Shock Wave Propagation Characteristics l in a Laboratory Device," w/T. E. Kennedy, Proceedings of the 1964 Army Science Symposium, Vol. II, West Point, N.Y. , June 1964; " Static and Dynamic Con-strained Moduli of Frenchman Flat Soils," with M. T. Davisson, Proceedings l of the Symposium on Soil-Structure Interaction, Univ. of Arizona, Tucson, Arizona, Sept.1964; " Damage to Model Tunnels Resulting from an Explosively-Produced Impulse," with G. B. Clark and J. N. Strange, U. S. Army Engineer Waterways l Experiment Station, Vicksburg, Mississippi, Research Report No. 1-6, Report 1, May 1965; "The Design of Surface Construction in Rock," w/D. U. Deere, F. I D. Patton, and E. J. Cording, Ch. II in Failure and Breakage of Rock, American Inst of Mining Metallurgical and Petroleum Engineer,1967. "The Effect of L Soil Properties on the Attenuation of Air Blast-Induced Ground Motions," with H. E. Auld, pp. 29-47, Proceedings of the International Symposium on Wave r Propagation and Dynamic Properties of Earth Materials, University of New k Mexico Press, 1968. " Mechanical Properties of Rock," Chapter 2, pp. 21-53, of the book " Rock Mechanics in Engineering Practice," edited by K. G. Stagg and O. C. Zienkiewicz, published by John Wiley & Sons, London, 1968, 442 pg. l j l I i
Alfrcd J. Hendron, Jr. [t Page " Dynamic Behavior of Rock Masses," with N. N. Ambraseys, Chapter 7, pp. 203-236 of the book " Rock Mechanics in Engineering Practice" edited by K. G. Stagg and O. C. Zienkiewicz, published by John Wiley and Sons, London,1968, 442 pages. " Foundation Exploration for Interstate 280 Bridge over Mississippi River near Rock Island Illinois," with J. C. Gamble and G. Way, Proceedings of the Twentieth Annual Highway Geology Symposium, University of Illinois, ( Engineering Experiment; Station, Urbana, 126 pp. " Compressibility Characteristics of Shales Measured by Laboratory and In Situ Tests," with G. Mesri, J. C. Gamble and G. Way, pp. 137-153, ASTM Special Technical Publication 477, [ " Determination of the In Situ Modulus of Deformation of Rock," June 1970. " Rock Engineering for Underground Caverns," with E. J. Cording and D. U. Deere (In Publication, ASCE Proceedings of a Symposium on the Design of Large Underground Openings, Phoenix, Arizona, February, 1971). " Dynamic Stability [ of Rock Slopes," with E. J. Cording, (In Publication, Proceedings of the 13tn Symposium on Rock Mechanics, Univ. of Illinois,1971). " State of the Art of Soft-Ground Tunneling," with R. B. Peck and B. Mohraz, Proceedings of the 1st [ North American Rapid Excavation and Tunnel.ing Conference, Chicago, Illinois, June 5-7, 1972, AIME, 1972, pp. 259-286. " Specifications for Controlled Blasting in Civil Engineering Projects," with L. L. Oriard, Proceedings of the ( lst North American Rapid Excavation and Tunneling Conference, Chicago, Illinois, June 5-7, 1972, AIME, pp. 1585-1610. Consulting Experience Directly Acolicable for the Design of Large Underground Chambers for Storage ,
- 1. 1971-present: Consultant to Gulf Oil on 4 large underground chambers l for storage of gas, Fannett Come, Texas. j
- 2. 1972-present: Consultant to Dome Petroleum on the use of salt caverns in Windsor Canada for gas storage. Caverns in service now,-status reviewed >
3 or 4 times a year. ! [ l
- 3. Consultant to Morton Salt on control of solution mining in the following brinefields (
( Port Huron, Michigan ! Rittman, Ohio ' Hutchinson, Kansas [ 4. Consultant to the Solution Mining Research Institute on subsidence and cavity stability Report on a study of sinkhole development above cavities in two [ brinefields and discussion of means for detecting this behavior sufficiently in advance to prevent such behavior. I 5. Consultant to BASF-Wyandotte, Wyandotte, Michigan on control of subsidence and prevention of sinkhole formation above cavities in bedded salt. ( 6. Consultant to Duke Power Co. on current design of Bad Creek underground powerhouse. e .
Al fred J. Hendron, Jr. [ Page 7. Past consultant to British Columbia Hydro-Authority on stability of the Portage Mountain Underground Powerhouse. (96 ft span,1000 ft long,180 ft'high).
- 8. Consultant to Morton Salt on the possible use of the Silver Springs brine field for gas storage.
- 9. Consultant to U. S. Department of Defense on many tunnels and underground chambers at Nevada Test Site.
[ 10. Past consultant to U. S. Corps of Engineers on the use of large underground structures in rock for protective construction. [ 11. Consultant to NATO and Norwegian Government in 1965, as a Corps of Engineer officer, on large underground chamber construction. Received Army commendation medal for this assignment. {' [ [ ! [ [ [ [ [ E E F L L
- EXHIBIT 9 SHR-1000-01-1 E
INTERIM REPORT TO E BROWN & ROOT, INC. E g ON L ADEQUACY OF CATEGORY I STRUCTURAL BACKFILL [ . SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION l by A. J. Hendron, Jr. H. Bolton Seed { Stanley D. Wilson E t1 E
. Seattle, Washington /
' July 12,1980
{, u u M 4
l I
. TABLE OF CONTENTS l Page j i
l
- 1. INTRODUCTION 1 1.1 Appointment of Expert Committee 1 1.2 Scope of Expert Committee's Review 1 1.3 Activities of Expert Committee 3
- 2. STRUCTURAL BACKFILL COMPACTION 4 -
1 I 2.1 Introduction 4 2.2 Compaction Requirements 5 I a. PSAR Requirements and Woodward-Clyde Reports 5
- b. Structural Backfill Specifications 5 l c. Quality Construction Procedure 6 2.3 Site Observations and Findings 7
- a. Test Fill Program 7 l
- b. Lif t Thicknesses - 7
- c. Number of Compactor Passes 8 2.4 Testing Procedures 9
- a. Field Density Tests 9 1
I
- b. Maximum-Minimum Densities 9 l
2.5 Test Results and Records 10 l 2.6 Supplemental Testing of Site Soils for Maximum-Minimum I Densities 11 2.7 Review of Pertinent Settlement Measurements 13 2.8 Field Boring Program to Evaluate Compacted 1 Structural Fill 14 I a. General 14
- 1) Phase I Borings 14
[ , 2) Phase II Borings 14
- b. Validity of Standard Penetration Tests (SPT) 14
- c. I.Tnit I Results 15
- d. Four Potential Problem Areas -- Unit 2 15
- e. Construction Document Review of Potential L Problem Areas 16 E
u m i ~
I : TABLE OF CONTENTS (Cont'd) Page
- 3. EVALUATION OF TEST FILL 17 '
I 4. 5. ANALYSIS OF LIQUEFACTION POTENTIAL BASED ON SPT DATA 26 l ANALYSIS OF LIQUEFACTION RESISTANCE OF STRUCTURAL BACKFILL UNDERLYING BUILDING MAT FOUNDATIONS 27 5.1 Introduction 27 5.2 Undrained Analysis of Liquefaction Potential 30 1 5.3 Analysis of Liquefaction Allowing for Pore Pressure Redistribution 33 5.4 Final Assessment of Liquefaction Potential 34 5.5 Conclusion 35
- 6. CONCLUSIONS 35 LIST OF FIGURES Page Figure No. _
1 June 1980 Test Fill,4 Pass Lane 18 I 2 June 1980 Test Fill,6 Pass Lane 19 1 3 June 1980 Test Fi,1,8 Pass Lane 20 4 June 1980 Test Fill,10 Pass Lane 21 5 June 1980 Test Fill,12 Pass Lane 22 6 June 1980 Test Filll-Density vs. Passes 23 7 Liquefaction Potential, Bulk Deposit 28 8 Liquefaction Potential, Isolated Pockets 29 9 Rigid Block on Sand Layer 31 10 Sand Layer at 50-foot Depth 31 Table I. Maximum-Minimum Density Tests Conducted by Clarence Chan at University of California, Berkeley 12 I ii
[ APPENDICES [ Appendix 1 Experimental Investigations of Influence of Loose Layer on Liquefaction
. Characteristics of Composite Samples Appendix 2 AnalyticalInvestigation of Influence of Pore Pressure Redistribution on Liquefaction Characteristics of Loose Layer Underlain by Dense Layer
[ . of Sand ( , l l [ [ . [ [
~
[ [ [ ik E l lii e
SHR-1000-01-1 l l INTERIM REPORT TO BROWN & ROOT, INC. ON I ADEQUACY OF CATEGORY I STRUCTURAL BACKFILL SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION I. INTRODUCTION I 1.1 Appointment of Excert Committee Brown & Root (B&R) appointed in late May,1980, an Expert Committee of independent consulting engineers to assist them in evaluating the adequacy of the structural backfill at Units 1 and 2, South Texas Project Electric Generating Station. The following individ1als agreed to serve on this Committee: Dr. A. J. Hendron, Jr., Professor of Civil Engineering, University of Illinois, Urbana, Illinois I Dr. H. Bolton Seed, Professor of Civil Engineering, University of California, Berkeley, California I Stanley D. Wilson, Consulting Engineer, Seattle, Washington I 1.2 Scope of Expert Committee's Review _. The need for a review of the adequacy of the Category I structural backfill results from an Order to Show Cause by the Nuclear Regulatory Commission (NRC), which among other things addresses the adequacy of the structural backfill in Units 1 and 2. Prior to the appointment of the Committee, a comprehensive investigation by means of the Standard Penetration Test (SPT) identified four problem areas of very limited extent in which the SPT gave numerical values of blow count, which when converted to relative density by means of commonly accepted correlation methods, l indicated values of relative density less than construction quality control criteria of l 80% rstative density. 1
l l The principal purpose for the Committee centers around aksessing the Engineering acceptability of the Category I structural backfill already in place. The k following tasks were originally outlined: ( a) Review the laboratory tests and design analyses performed on the backfill concerning liquefaction and settlement. b) Review the recommendations and criteria for compaction of the backfill made in a series of engineering reports. c) Review the construction specifications and procedures for compaction of the backfill. This review shall include the actual construction and quality control methods employed in the field. [ - 1 d) Review the prescribed and implemented inspection and testing procedures j ( for compaction control of the backfill placement. This review shall include the quality control methods and documentation implemented in the field.' e) Review the engineering analyses and evaluations made from the test results collected and documented covering the construction period from 1976 to 1980. [ f) Review the results of special investigations conducted in the placed backfill whose purpose was to essess its adherence to the design require-b ments. This will include the results of test borings carried out in two phases during the spring of 1980. g) In the event "sof t zones" are delineated in the backfill, review the efficacy of the methods proposed by B&R Engineering to treat those zones to bring { - them into conformance with the design intent. h) Review and analyze the compaction control data collected during the backfill placement. [ () Inspect the laboratory facilities and equipment used by the Testing Agency. Review the laboratory test procedures followed. [ 2 1
j) For the fleid test fill program planned for early June 1980, review the procedures, observe fleid operations, and participate in the evaluation of I ( results. ( . Additional specific investigations, activities, and subjects for review were identified by the Committee as the work progressed. [ 1.3 Activities of Expert Committee _,. [ Committee Member Wilson met with representatives of Brown & Root,Inc. and others in Houston on May 20,1980 to discuss the membership of the Committee and its responsibilities. - h - The first meeting of the Committee was held in Houston on May 27. An additional briefing meeting with Seed was held in Berkeley on June 11,1980. [
, On June 13, Wilson visited the site and inspected the test fill, the backfill area, and the laboratory of Pittsburgh Testing Laboratory; and on June 20, Hendron visited
{ the site and inspected the test fill, the backfill area, and carefully observed the testing techniques at the testing laboratory. Seed felt that he did not have to visit the site at this time because of his familiarity gained by involvement in the project since 1973. The second meeting of the Committee was held in San Francisco on June 26, [ 1980. ( The third meeting of the Committee was held in Seattle on July 8,1980. { Shannon & Wilson, Inc. (Houston) was engaged by Brown & Root, Inc. to assist the Committee in its data gathering process and in a detailed review of the structural { backfill compaction operations. In addition, a large number of documents were made available to the Committee for their review, and special studies were undertaken by the Committee members themselves and by others engaged at the request of the Committee; also, the Committee requested and received all other information that the Committee deems necessary for development of this interim report. . The results of L these special studies are included in this report. I u -- 3
( The Ccmmittso gr20tly apprzeictes tha co:perztien and support it rcesiv d et all times from Brown & Root, Inc., Woodward-Clyde Consultants (New Orleans), and Houston Lighting and Power Company. { The Committee notes that H. Bolton Seed has previously served as consultant to Woodward-Clyde Consultants on this project, that permission to serve on this panel as an independent consultant was approved by all parties concerned, and the Committee has judged that there is no conflict of interest. ( 2. STRUCTURAL BACKFILL COMPACTION _ 2.1 Introduction __ {- This section presents an appraisal of compaction requirements, procedures, inspections, on-site testing and record keeping for Category I structures. Included is a
, description of a field boring program conducted by Brown & Root (B&R) with
{ assistance from Woodward-Clyde Consultants (WCC) for the purpose of evaluating the backfill compaction. [ Units 1 and 2 at the South Texas Project Electric Generating Station (STPEGS) [ each consist of the following major structures: 1) Reactor Containment Building with surrounding tendon gallery; 2) Fuel Handling Building; 3) Mechanical-Electrical Aux-( iliary Building; 4) Diesel Generator Building; and 5) Turbine Generator Building. All these- buildings and foundations are Category 1, except the Turbine Generator { Buildings. The upper 20 to 68 feet of natural soils beneath the major plant structures were { excavated to expose appropriate, firm bearing soil. The structures were then supported either on natural soil or on compacted structural backfill. The Reactor Containment Buildings and the northern portion of the Fuel Handling Buildings were supported on natural site soil about 68 feet below general plant grade. The southern portion of the Fuel Handling Buildings and the other major structures were founded at higher elevations over structural backfill varying in depth from about 15 to 40 feet. E . - 4 i
[ The structural backfill that surrounds and underlies the major plant structures was constructed using a clean, well-graded, medium to coarse sand imported from an ( off-site borrow area. 2.2. Compaction Requirements . _ _ _
- a. PSAR Requirements and Woodward-Clyde Reports
{ _ _ _ _ The PSAR commitment was for structural backfill to be of a quality and degree of compaction consistent with design assumptions for safe support of I Category I structures. Based upon an assessment of strength, compressibility and liquefaction potential of available granular soils (References 1 and 2), a specification for structural backfill was developed (Reference 3). [ -
- b. Structural Backfill Specifications , ,
( - The specification requirements for Category I Structural Backfill are pre-sented in Reference 3. The pertinent requirements are summarized below: {
- 1) Gradation limits are as shown on FSAR Figure 2.5.4-59. The coeffi-cient of uniformity shall be greater than 4, with particle shape to be subrounded to angular. (Paragraph 4.1)
- 2) Structural backfill material in unrestricted areas shall be placed in b uniform layers not exceeding 18 inches loose thickness. Lifts up to 24 inches loose thickness may be used if their adequacy is demonstrated
[ by a test fill. Where hand-operated tampers are used in restricted areas, layers are not to exceed 8 inches loose thickness. (Paragraph 7.1) {
- 3) All Category I structural backfill material shall be compacted to a minimum relative density of 80 percent with a running average of at 1 east 84 percent, as determined according to ASTM D-204 N 9.
[ , (Paragraph 8.1.1 a) [
- 5
- 4) At least one field density test shall be performed per 20,000 square feet of each lift in unrestricted areas. In restricted areas, at least one ,
( field density test shall be performed for each 200 cubic yards. (Paragraph 9.0. d)
- 5) At least one relative density test (ASTM D-2049) shall be performed for every fourth field test or at more frequent intervals as necessary to ensure compatibility between field and laboratory tests. (Paragraph 9.0e)
- 6) Quality Assurance Requirements. The verification of the structural backfill and quality control acceptance will be based on in situ testing of the compacted backfill according to Paragraphs 9.0.d, 9.0.e.
( - (Paragraph 10.0.c) ( c. Quality Construction Procedure _ The quality construction procedure, as given by Reference 4, prescribes { methods for achieving the Structural Backfill specification requirements. One state-ment is as' follows:
"Once a loose lift is placed, it will be compacted until it passes
( the density requirements before the next lift .is placed and spread." (Paragraph 3.3.1.3) l r This constitutes an "end-result" (" quality result") requirement in accord-ance with specification paragraph 10.0.c (given above), Reference 3. The procedure also states minimum passes of compaction equipment: eight b. one-way passes minimum in unrestricted areas, except for surface compaction (top 12 inches) where a minimum of 12 passes is given. In restricted areas, the number of , [ passes is that needed to satisfy the compacted density- requirements. In both restricted and unrestricted areas, compaction efforts are to continue until passing test obtained.
..._ I L
I w J 6
E ' 2.3 Site Observations and Findings Committee members visited the project site in June 1980 and inspected all visible portions of the structural backfill, including excavations, test pits and work in progress. They were favorably impressed with the excellent quality of the structural backfill materiais, its observed high density and its uniformity in gradation from one area to another. The excavations indicated great uniformity of compaction through-out, as demonstrated by probing by hand from the surface and into the vertical sides of test pits. At the request of the Committee, site observations and evaluations were made by a Principal Engineer from Shannon & Wilson, Inc., Geotechnical Consultants. The Principal Engineer, Thomas E. Kirkland, has 22 years of geotechnical experience and previous extensive involvement in nuclear power plant backfill construction and quality control. Site observations and evaluations by Mr. Kirkland involved:
- 1) reviewing the test fill program; 2) evaluating lift thicknesses; and 3) determining the number of passes used by compaction equipment during structural backfilling. With respect to items 2) and 3) above, information was gained in documented interviews with knowledgeable site personnel, including a B&R Earthwork Construction Foreman and representatives of B&R and Houston Lighting and Power (HL&P) Quality Assurance, B&R Engineering, and Pittsburgh Testing Laboratory (PTL).
- a. Test Fill Program I _
The test fill procedures, fill testing and laboratory work were reviewed. Details of the test fill program are presented in Reference 5. An evaluation of the results is presented later in this report. I
- b. Lif t Thicknesses _.
Before compaction was allowed to begin in any area, the testing agency (PTL) checked for proper lift thickness; adjustments were made as needed. Confor-mance to requirements were marked on PTL Form SF-1. The primary method used to measure loose lift thickness (18-inch maximum specified) was by probing and supple-l mented by hand level checks. I I ,
i The Shannon & Wilson Principal Engineer measured compacted lift thick-nesses in open excavations at the site previously observed by the Committee Members. ) The areas observed are those - where subsequent excavation had taken place at locations previously constructed as structural backfill. Photographs were taken to ( show lift thicknesses. Compacted thicknesses ranged generally from 10 to 16 inches, thus demonstrating compliance with the maximum 18-inch loose lift requirement. In addition, Woodward-Clyde geologists have mapped compacted lif t thick-nesses in open excavations at the site. Seventeen sections were mapped and I photographed in eight separate excavations surrounding Units 1 and 2. The results of this mapping are 'given in Reference 6. The minimum lift thickness identified was
,, 0.3 feet (3.6 inches), and the maximum lift thickness identified was 1.4 feet g (16.8 inches). These results demonstrate further compliance with the 18-inch maxi-L mum loose lift requirement.
( It was reported that lift thicknesses in restricted areas were 4 to 6 inches or smaller. E
- c. Number of Compactor Passes The number of passes was not documented by the testing agency beyond the required minimum by the procedures. Instead, the earthwork construction foreman, who called for in-place density testing when ready, continued compaction in unrestricted areas until the density requirements were met.
Those knowledgeable site personnel interviewed all reported that 16 to 20 b or more passes was generally obtained on each lift in unrestricted areas. This high number of passes was standard practice in order to consistently achieve the required [ densities. { In restricted areas, compaction operations with hand-tampers were con-tinuous as thin lifts of structural backfill were placed by hand shovel. Compaction { continued until the density requirements were met. E u -.. g l
. 1
. _ _ _ _ _ _ _ _ _ _ . I
g . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ 2.4 Testing Procedures _
- a. Field Density Tests
( All field density tests were conducted using the sand cone method (ASTM D-1556) which is in accordance with specification requirements. The testing proce-dures utilized in the field by Pittsburgh Testing Laboratory (PTL) were observed by the Committee Members and by the Shannon & Wilson Principal Engineer. The methods, procedures and workmanship were judged to be quite satisfactory, in accordance with project requirements and good industry practice. [ b. Maximum-Minimum Densities The maximum and minimum densities, needed in calculating relative den-sity, were determined in accordance with ASTM D-2049 as modified. The approved h modifications are as follows: ( 1) Maximum density shall be performed using a vibratory table of com-monly available design and performance. The theostat setting provid-ing the maximum density shall be determined for each soil type used. {
- 2) For each borrow source, 20-test averages are determined for maxi-mum and minimum densities. In-place density quality control accept-ance criteria are determined using the current 20-test average l E, maximum - minimum values. The 20-test average values are updated l after each five new maximum-minimum tests are completed.
The specifications require that at least one set of maximum-minimum l ( densities be obtained by ASTM D-2049 for every fourth field test. A review of Units I und 2 plant area test data through April 3,1980 indicate an average frequency of about one maximum-minimum test for every four density tests. (Actual ratios are 1:4.04 for { Unit I and 1:4.02 for Unit 2.) The laboratory testing procedures utilized by Pittsburgh Testing Laboratory (PTL) were observed by the Committee Members and by the Shannon & Wilson Principal Engineer. The methods and procedures were judged to be satisfac-tory, and the workmanship was very good. L r 9
1 2.5 Test Results and Records .__. Inspection and Nt records are required to document compliance with licensing ( and specification requirements. A detaned review of these documents is in progress in accordance with Reference 7, and will be further addressed in the final Committee report. Twelve figures, six each for Units 1 and 2, have been prepared to present an abbreviated summary of the production density testing. These figures summarize the relative density results area by area at one foot intervals of elevation. For each elevation, the number of tests is recorded along with the relative density range and mean relative density. A summary box is also presented to list the number of tests in [ restricted and unrestricted areas, the total number of tests, the overall range in relative density for the area, and mean relative density. The data will be subject to ( statistical evaluations which will also be considered in the final report. The abbreviated summary shows the following data: { Mean Relative Density % Building Area Unit 1 Unit 2 Reactor Containment 95.4 95.8 Containment Pedestal 102.3 99.8 i { Fuel Handling Mech.-Elect. Aux. 95.8 93.0 94.0 92.9 i Diesel Generating 96.5 96.1 I The data shows consistently high results at all elevations and average [ values exceeding the specified minimum average of 84 percent relative density. The
' testing frequency is high and exceeds specification requirements. The uniformity of structural backfill compaction is demonstrated by these results.
{ A review has been made of over 200 grain size curves of structural backfill material, covering the entira construction period. These curves fall within the specificatien limits and show uniformity of soils supplied for structural backfill. All L structural backfill material consisted of a processed granular aggregate imported from two suppliers located in the Eagle Lake area some 55 miles north of the project site. l g 10
g . In view of the very uniform quality of structural backfill soils, as demonstrated by the sieve analyses, it is the Committee's judgment that sufficient tests were conducted to determine maximum and minimum densities. ( 2.6 Supplemental Testing of Site Soils for Maximum-Minimum Densities To evaluate the validity of the maximum and minimum densities being obtained by Pittsburgh Testing Laboratory (PTL), supplemental tests were conducted by Clarence Chan, Research Engineer cnd Lecturer, Richmond Field Station, University l 1 of California, who is a well known expert in the fleid of soil testing. Clarence Chan's 1 results are summarized on Table I. ' Supplemental tests were also conducted by Richard Ladd of Woodward-Clyde ( Consultants, Clifton, New Jersey, who is also a noted expert in the field of soil testing. The results obtained by Richard Ladd are given in Reference 5. In determining the maximum density, Clarence Chan used an electromagnetic vibrating table and ran each sample at three theostat settings: 50, 75 and 100. The { maximum dry density for each sample occurred at a setting of either 75 or 100. The maximum' density results recorded on Table I are for repeated tests at that amplitude which produced the highest value of maximum density. The dry method by ASTM D-2049 was used to determine maximum density. The wet method used for one sample had a lower maximum density than by the dry method. Two methods were used to determine the minimum density by Cla9nce Cham
- 1) glacing soil by flat scoop, and 2) using 3000 grams of soil slowly tilted ano rotated in
( a 2000 mi graduated cylinder. [ The maximum density tests conducted by Woodward-Clyde Consultants in Clifton, New Jersey used a cam-driven vibrating table from the All American Tool and Manufacturing Co., Inc. Several amplitudes (peak to peak) were run to determine the { optimum amplitude to use in testing. Samples were therefore run at the following amplitudes (peak to peak): 0.002, 0.004, 0.006, 0.010, 0.015 and 0.020 inches. The amplitude that produced the maximum density was 0.006 inches, peak to peak. r L - 11
O i TABLE I MAXIMUM-MINIMUM DENSITY TESTS CONDUCTED BY CLARENCE K. CHAN [ MAXIMUM DRY DENSITY, LB./CU. FT. __ . 8A 8B 8C Average [ Dry 128.1 128.7 126.2 127*8 ASTM - D2049 Method 127.4 128.6 128.0 Rheostat Setting Wet of 75 or 100 126.2 - - 126*2 Method Modified Proctor 125.0 126.6 123.3 [- on Steel Plate 123.2 124*5 Results by PTL at Site 125.9 128.7 125.8 126.8 [ hilNIMUM DRY DENSITY. LB./CU. FT. 8A 8B 8C Average [ Placed by Flat Scoop 101.9 103.0 101.6 (60 gm. ea.) 102.2 102*0 102.5 100.9 2000 ml. graduate 97.6 100.0 96.8 cylinder 96.7 100.2 98*0 96.5 Results by PTL at Site 105.0 106.6 104.6 105.4 ( GRADATION . - . - 8A 8B 8C ( % Passing # 4 8 98 67 97 64 98 68 16 42 39 43 1 { 30 24 22 25
. 50 13 9 10 100 2 2 2
[, 200 1 1 1 L Pu 0 0 0 F L Note: Samples obtained from 8-pass lane (Rows A, B and C) of June 1980 test fill. r L I . , 12
b L l Eight mSthods wtra used at Woodward-Clyda, Now Jerssy, to cvalutta mini-mum density for this type of soil (refer to Reference 5). It is reported by Woodward-Clyde that varying amounts of sample segregation were observed in the two methods which involved slow tilting of a 2000 ml graduated cylinder. The supplemental tests confirm that the maximum density values being obtained at the site by PTL are valid and within expected limits of normal testing variations. It is to be noted that higher values of maximum density were obtained using electromagnetic vibrating tables (Clacence Chan table and PTL table at project site) than by using the cam-driven table at New Jersey. The reason for this, which has been seen previously by testing similar soils, is that slightly higher densities are possible wheri the vertical up and down motion is supplemented by some amount of horizontal movement such as occurs only with electromagnetic tables and not with the
. cam-driven table.
{ 1 Review of the various methods for obtaining minimum density has resulted in our conclusion that the flat scoop method, as used by Clarence Chan, is the most valid to use for the present study, although there is considerable evidence that the minimum density may actually be somewhat lowea than determined by this method. For the samples tested by Clarence Chan, the average minimum density as obtained by flat ( scoop placement is 102.0 pounds per cubic foot (pef). For the same samples, PTL averaged 105.4 pef by the ASTM D-2049 funnel method. Use of the flat scoop method, [ which results in minimum density values 3 to 4 pef lower than obtained by PTL, would therefore raise an 80 percent relative density value to about 84 percent. Thus the production test results are judged to be conservative, and the actual relative densities { would be higher than reported. 2.7 Review of Pertinent Settlement Measurements _ _ _ _ A review was made of pertinent field settlement measurements, in particular s for the Unit 2 Auxiliary Building, to see if there was any compression of the structural b backfill after it had been placed. No such compression was noted, although the
, accuracy of the measurement is such that the compression worm have to be of the order of 0.02 foot or larger to be detected. A compression of A02 /oot: represents only 0.12% in a 17-foot thick soil layer, a very low order of m'gr TA 7(ch would indicate
[ a very dense fill. 1
. 13
b 2.8 Field Boring Programs to Evaluate Comoacted Structural Fill
- a. General
( Standard Penetration Test (SPT) borings were made at Units 1 and 2 to evaluate the density of Category I structural backfill. The borings were made in two phases, as follows: {
- 1) Phase I Borings __._,
l Twenty-one borings were drilled during the period of January 28 to [ February 8,1980. Out of 288 Standard Penetration Tests (SPT) conducted in the structural backfill, only eight indicated relative density less than the 80 percent minimum construction control criteria, as determined using the, Gibbs and Holtz correlation of SPT N-values versus relative density (Reference 8). These eight tests showed four potential problem areas, with one of these areas having two zones with relative density less than the construction quality control criteria.
- 2) Phase II Borings ____
Twenty-eight additional borings were made during the period of March 24 to April 11,1980, to better define the horizontal and vertical extent of those areas and zones identified in Phase I with density less than construction quality control criteria. All borings were advanced using Failing Model 36 type of drill rigs, (. using a bentonite drilling mud. The results of the two boring programs are described in References 9 and 10. [ Validity of Standard Pene_ cation Tests (SPT) b. i Deviations in sampler dimensions and hammer weight from the specifica-tions established in Woodward-Clyde Consultants' (WCC) drilling procedure were noted during the first phase of borings. WCC's procedures were to conduct the Standard Penetration Test (SPT) in accordance with ASTM D-1586. The deviations are indicated on the following table: [: - 14
\
___ ________ l
8 Actual Measurements ASTM:D-1586 Custom Auger Drive Shoe ASTM i Reouirements Worn Shoe l Good Condition 2 Shoe 3 ,
~
l Shoe O.D. 2" 1.98" 1.98" 2.00" I i Shoe I.D. 1 3/8" 1.45" 1.40" 1.40" l Shoe Taper Length 3/4" 0.50" 0.62" 0.75" l Hammer Weight 140# 139.8# 142# 140# 1 NOTES: Worn shoe used for Phase I borings 101, 102, 103, 104, 105, 106, 203, 204, 204A, 204B, 207, 208X (12 borings) 2 Good condition shoe used for Phase I borings 201, 201A, 202, 205, 205A, 205B,-206, 208, 209 (9 borings) 3 ASTM shoe used for all Phase II borings (28 borings). All l measurements within procedure tolerances. As shown in this table, some of the measurements varied but only slightly from those given in ASTM D-1586. In reviewing the impact of these deviations on the , SPT N-values, it is judged that the thinner walled tubes used in the Phase I borings (0.53 and 0.58 inches versus 0.625 inch by ASTM D-1586) would tend to result in less driving resistance as the split-barrel sampler penetrates the sand. Thus the SPT N-values are valid or on the conservative side. The slightly higher hammer weight (142 pounds) would also tend to produce conservative results (i.e. decrease in blow counts). In summary, it is the judgment of this Committee that the small variations I in size and shape of the shoe, as noted in the above table, and the small deviations in hammer weight did not have any significant influence on the test results.
- c. Unit i Results I
Within Unit 1, results of the Standard Penetration Tests indicate that the structural backfill equals or exceeds construction quality control criteria of 80% relative density, as determined using the Gibbs and Holtz correlation.
- d. Four Potential Problem Areas -- Unit 2 _._
Four small areas at Unit 2 have densities, based on the Gibbs and Holtz correlation, less than the construction quality control criteria. The location of these 'I areas are shown in Reference 11 and are generally situated as follows: I 15
l l g 1) Area 1. West of Unit 2 Reactor Containment Building, adjacent to i 5 Tendon Gallery Access. , I
- 2) Area 2. Northwest of Unit 2 Reactor Containment Building l l
- 3) Area 3. East of Unit 2 Mechanical-Electrical Auxiliary Building l
- 4) Area 4. W"t of Unit 2 Fuel Handling Building l
Area 1 has several smallisolated zones and pockets with a density less than construction quality control criteria. I l The extent of zones with densities less than construction criteria within I Areas 2 and 3 are limited to one compacted lift thickness (approximately 16 inches). They are judged to be one rolling lane wide (6 feet wide based on the drum width of l vibratory rollers at the South Texas Project (STP) site). The length of zones is small, estimated to be less than 10 feet long as determined by borings. l Area 4 has two small zones less than construction quality control criteria, I separated'by approximately 18 feet of structural backfill that exceeds the construction j quality control criteria. The lower zone is about 7 by 20 feet in plan view size, with the upper zone about 7 by 10 feet in horizontal dimensions. The significance of these four potential problem areas is covered subse- 1 l ' l quently in this report, under " Analysis of Liquefaction Potential Based on SPT Data." I e. Construction Document Review of Potential Problem Areas I f In the period between Phases I and II borings, a review was conducted to investigate existing conditions based on available records. Refer to Reference 14. l In Area 1 (same area designations as before) the records show that excava-tion slopes were cut to final grade in March 1977, and were exposed through the middle I of December 1977. In addition, foundation preparations consisted of trimming the toe of some slopes in Area 1, creating near-vertical slopes of varying height, in order to compact the underlying soils. The combination of lengthy exposure and near-vertical I 16 I _ _____ ___ i I
k slopes resulted in repeated sloughing and trimming of the side slopes. Static rolling was reported to have been performed to avoid the sloughing. These circumstances ( caused difficult backfill construction conditions which probably caused the low densities. It appears that these placement conditions are unique to Area 1 and were not experienced elsewhere. In a portion of Area 1, the required overexcavation of natural subgrade led to placement of lift I to a depth of 2.5 feet. In another portion of lift 1, where this lift was tested for relative density at the time of construction, the lift thickness was less than one foot. Thus testing did not occur where the construction difficulties resulted in local areas not receiving full compactive effort. The record search involving Areas 2. 3 and 4 revealed no unusual conditions l [ which would contribute to slightly low density results. l It is the judgment of the Committee that the construction difficulties encountered in Area 1 resulted in the zones with densities less than construction control criteria. Based upon the construction record review and the two-phase SPT boring program, it is also the judgment of this Committee that the small zones of slightly low density in Areas 2, 3 and 4 are of very limited extent and do not significantly affect the high quality and dense condition of the corr pacted mass of structural backfill, as discussed in more detail in a subsequent sectio 1 of this report. The construction conditions during backfill placements and possible engineering problems will be further evaluated by BUR during the continued dhow Cause Order [_ investigations and will be considered in the Committee's final % port. ( 3. EVALUATION OF TEST FILL __ The details of the test fill constructed and monitored during June 1980 have { been described in Reference 5. The test fill was compacted in two 18-inch thick lifts above a test base lift and densities'were taken at levels 6 inches apart in each lift after the placement of lifts 1 and 2. Tests conducted after placement of the first lift are denoted as step B tests and tests conducted after the placement of lift 2 are L denoted as step C tests. The results of these density tests are presented in Figures 1, y 2, 3, 4, and 5 for lanes with 4, 6, 8,10, and 12 one-way passes of the Dynapac Model b L 17 r _ _ _ _ _ _ _ . _ _ _ _ . . _ _ _ _ _ _ _
[ DRY DENSITY - POUNDS PER CUBIC FOOT I i i i i i i i i i i i i 112 113 114 115 118 117 118 119 120 121 122 123 124
+ 31 -
b A i 1 g 4 PASS LANE [ N N TEST DATA 030 - - TEST LIFT 2 h ! A N
+ 29 -
O , E l E C E TEST LIFT 1 ,
" 2B
+ -
h N [ h j T TYPICAL 6-lHCH TEST INTERVAL TEST BASE LIFT I ? NOTES:
- 1. POINTS PLOTTED AT MIDPOINT OF DENSITY TEST E 3 STEP C TESTING
[ + 26 -
- 2. EACH DATA POINT REPRESENTS AVERADE OF THREE (AFTER LIFT 2 PLACED)
TESTS, FROM R0WS A, 8 AND C TEST!NG G 3 STEP B TESTING l ( AFTER LIFT 1 PLACED)
)
L SOUTH TEIAS PROJECT JUNE 1980 TEST FILL 4 PASS LANE 13 FIG.1
L [ 5 DRY DENSITY - POUNDS PER CUBIC FOOT { l 112 i 113 114 i 115 i 118 117 i 118 119 i 120 1 121 a 122 i 123 124 l~ ;
+ 31 -
i a 1 l l l 6 PASS LANE l [ N TEST DATA
+30 -
TEST LIFT 2 { _ Y q
\
+ 29 -
C \ . L' ( E i
\ -
1 E b$ TEST LIFT 1 ,,
~
+ 2B -
y E { 7 TYPICA.l 6-INCH TEST INTERVAL TEST BASE LIFT I
. Y '
NOTES:
- 1. POINTS PLOTTED AT MIDPOINT OF DENSITY TEST E 3 STEP C TESTlHG
+2!i -
- 2. EACit DATA P0lHT REPRESENTS AVERAGE OF THREE - (" " ' )
TESTS, FROM R0WS A, 8 AND C TESTING C 3 STEP B TESTING ( AFTER LIFT I PLACE 0) u l 7 SOUTH TEXAS PROJECT 4 JUNE 1980 TEST FILL 6 PASS LANE g FIG. 2
ORY DENSITY - POUNOS PER CUBIC FOOT I I i i i i i i i 1 4 4 i 1 112 113 114 115 116 117 118 119 120 121 122 123 124
+ 31 -
(.. . 4 I I 8 PASS LANE [ N TEST DATA N
~
+30
[' TEST LIFT 2 { a
.s
+ 29 -
CQ N x
$._ h '
b TEST LIFT 1
+ 2B -
y
}.
_ N / E r TYPICAL 6-INCH TEST INTERVAL TEST BASE LIFT I Y {- NOTES:
- 1. POINTS PLOTTED AT MIDP0lHT OF DENSITY TEST C 2 STEP C TESTING j
+26 -
- 2. EACH DATA POINT REPRESENTS AVERAGE OF THREE
( R UFT 2 NCED) j TESTS, FROM R0WS A, 9 AND C TESilNG G S STEP 3 TESTING ( AFTER LIFT 1 PLACED) ~ L r SOUTH TEXAS PROJECT L_, JUNE 1980 TEST FILL 8 PASS LANE 7 ] 20 FIG. 3
[ .. [ ORY DENSITY - POUNOS PER CUBIC FOOT i i i i i a i i i i i. I I I 112 113 114 115 116- 117 118 119 120 121 122 123 124
+31 -
[ A I i b 10 PASS LANE [~ . TEST DATA N
+30 - '
TEST LIFT 2 { y A
+29 -
A % 9 [ 7 E
'\ -
O 9 TEST LIFT 1
+ 28 -
y I 0 . [ T TYPICAL 6-INCH TEST INTERVAL TEST BASE LIFT I Y {- q l NOTES:
- 1. POINTS PLOTTED AT MIDPOINT OF DEN!iTY TEST E 3 STEP C TESTING 02 B. 2. EACH DATA POINT REPRESENTS AVERAGE OF THREE TESTS, FROM R0WS A, 8 AND C TESTING C O STEP B TESTING
[ ( AFTER LIFT 1 PLACED) [ p SOUTH TEXAS PROJECT JUNE 1980 TEST FILL c 10 PASS LANE - 21 FIG.4 l {
l l i i i i i ORY DENSITY - POUNDS PER CUBIC FOOT i i i i i i i i i 112 113 114 115 116 117 118 119 120 121 122 123 124 l -
^
I I e% N l 12 PASS LANE I
% TEST DATA l +30 -
N w
- l TEST LIFT 2 '
l t
~
A W
+29 -
G h N N l i % - I55 - N l
~
+ 28 TEST LIFT 1 \ '
h l D l T I _ TYPICAL 6-INCH TEST INTERVAL TEST BASE LIFT I 1 NOTES: l
- 1. POINTS PLOTTED AT MIDPOINT OF DENSITY TEST E 3 STEP C TESTING
+21i
- 2. EACH DATA POINT REPRESENTS AVERAGE OF THREE ( AFTER LIFT 2 PLACED)
TESTS, FROM R0WS A, 8 AND C TESTING C 3 STEP 3 TESTING
. ( AFTER LIFT I PLACED)
} l I I I SOUTH TEXAS PROJECT l JUNE 1980 TEST FILL 12 PASS LANE l 22 FIG. 5
AFTER LIFT 2 PLACED [ 122.0 - { 121.0 - - { 120.0 Q A
- ~
~
119.0 - 118.0 - C * = - 5 k 117.0 - - 5 116.0 -
= .
5 [ 115.0 - - 2 114.0 -
.9 113.0 - -
112.0 - 111 0 - STEP C TESTING
' ' f f
._i 4 6 8 10 12 l NUMBER OF PASSES LEGEND NOTE: EACH DATA POINT REPRESENTS THE AVERAGE OF THREE TESTS, FROM e TOP 0F TEST LIFT 2 R0WS A, B, & C TESTING O MIDDLE OF TEST LIFT 2 I G- 30TTOM OF TEST LIFT 2 L
5 TOP OF TEST LIFT 1 G] M100LE OF TEST LIFT 1
, E BOTTOM OF TEST LIFT 1 F SOUTH TEIAS PROJECT L A TOP OF TEST BASE LIFT JUNE 1980 TEST FILL
{ DENSITY VS. PASSES - 23 FIG. 6
CA-25SD vibrating rollte, r:spectivcly. This is a 10-ton roller which was used for all Category I unrestricted structural backfill placement for STPEGS. ( In each case it is shown that the density of the lower lift is increased significantly by compaction of the lift above it; it is also obvious that the top 6 inches of the top lift is not compacted well regardless of the number of passes. Its density (see Figure 6) is about 112.5-114 pef, which corresponds to an average relative density of 49% (Ymin = 102.0; ymax = 127.8). A comparison of Figures 1 through 5 indicates that the density at any level generally increases at a decreasing rate with an increasing number of roller passes. It is important to note from Figure 3 that the unit weights in lift I after the placement of lift 2 vary between 120.3 pounds per cubic foot (pcf) and ( 121.4 pef for 8 passes of the roller. An inspection of Figures 4 and 5 indicates that the unit weight variations are between 119.6 pef and 121.4 pef and 119.6 pef and 121.8 pcf for 10 and 12 passes, respectively. This indicates that within the errors of determining { density and with the normal variations that can be expected within any area with the same number of passes, there is not a significant difference between 8 and 12 passes for densities observed in lift 1. [ A summar~y of Figures 1 through 5 is shown in Figure 6. This figure shows that , the unit weights in lift I range from 119.5 pcf to 121.8 pcf, after placement of lift 2, for b lanes with from 8 to 12 passes. It is also shown on Figures 5 and 6 that for 12 passes ( the unit weights in the middle and lower portion of the last lift placed, on lift 2 in the ( case of the test fill, are between 119.5 and 120 pcf. Thus the requirement of a minimum of 12 passes for the uppermost lift yield densities in the lower 1/1 to 2/3 of ( the top lift which are comparable to densities achieved in the lift immediately below the top lift. Thus from the data presented it can be concluded that from the top 6 inches and downward that the unit weight of the test fill increases from 119.5 in the { surface lift to 121.8 pef in the underlying lift for the sands used in the test fill. [ Maximum and minimum densities (ymax and Ymin) determined on samples taken from the 8-pass lane indicate that the average values of ymax and ymin are 127.8 pcf and 102.0 pef, respectively. (See Par. 2.6 and Table I.) Thus the relative densities corresponding to 119.5 and 121.8 pcf are 73% and 81%, respectively. The 81% would be ( representative for the lifts within the backfill which have been subject to additional influence from compaction of overlying lifts. It should be noted that the field testing [ laboratory determined ymax and ymin to be 126.8 pef and 105.4 pef, respectively, with F L 24 P
( tha maximum valua ditcrmin:d from ths standard ASTM vibratory table and the minimum density determined by the ASTM funnel method. According to their values , of Ymax and ymin the relative densities corresponding to densities of 119.5 and 121.8 pef { are 70% and 80%. Thus it is apparent that monitoring the fill by the laboratory methods used in the field laboratory make the fill appear to be of lower quality than if { the fill was monitored by means of relative density based on the research methods used by Clarence Chan and elsewhere. This results primarily because of the difference in the unit weights reported for yminimum. Since the field compaction was monitored by relative densities determined from the field laboratory tests and additional passes were ordered if the fill did not test at a minimum of 80%, then it is probable that the actual structural fill has been placed at relative densities somewhat higher than were b recorded. { - Af ter testing and evaluating the test lanes compacted with 4 to 12 passes of the vibratory roller, an additional 10 one-way passes were made on the test fill so that there would be 14,16,18, 20 and 22 passes on the uppermost lift. This range more { closely reflects the actual number of compactor passes obtained during production backfilling for Category I structures. These results are also presented in Reference 5. Based upon these test fill results, the Committee concludes as follows: a) The vibratory compactors used on this project are capable of obtaining b required densities witn the use of 18-inch lifts (maximum loose thickness). ( b) Below the upper portion of the top and final lift, there is uniformity of compacted density throughout the structural backfill without zones of { loose soil sandwiched between zones of dense backfill. c) Performing density tests in the lower portion of the top lift or the upper portion of the underlying lift, as generally accomplished during production testing, produces conservative results. As long as each lift is tested to determine conformance with specification requirements, there is not a particular need to set specific testing depths below the fill surface existing at the time of testing, c L r L s 25 ? .
{ d) It app =.rs from this t:st fill program that ex:rting a minimum effort of 8 passes ensures engineering adequacy of the backfill independently of the construction quality control criteria. The construction procedures ce { therefore judged correct to determine the point of starting the in-place density testing.
- 4. ANALYSIS OF LIQUEFACTION POTENTIAL BASED ON SPT DATA The liquefaction potential of a sand deposit may be evaluated based on a b correlation of the stresses developed in a deposit with the Standard Penetration Resistance of the sand (N-value). The basis for this procedure is a series of detailed
[ studies of sites which are known to have liquefied or not liquefied in earthquakes in Japan, Guatemala, Argentina, China, Venezuela, etc. as well as the United States. The correlations established and the procedure for making evaluations have been { described by Seed,1979 (Reference 11), but it should be noted that the correlations presented at that time have since been confirmed by an abundance of data from more recent earthquakes. Following this approach, analyses have been made to determine the N-values which would have to be developed in the sand backfill at the South Texas Project site b to provide a factor of safety of 1.5 against liquefaction if the water table were at the ground surface and the site were subjected to 0.lg from a Magnitude 6 earthquake. ( Details of the computations are presented in Reference 12. { For these conditions, and assuming that borings were made when the water table depth was about 30 ft below the ground surface, the following results are obtained: { Depth Below N-value required N-value required for FS=1.5 { - Ground Surface - ft 20 for FS = 1.5 14.2 in isolated loose oceket* 10 40 16.5 12 f 60' 16.5 12 L 70 17 12.3 g
- Note: The N-value required to prevent liquefaction in an isolated loose pocket is less L than that required in a uniform mass because the strains in the loose pocket are controlled by the stiffness of the surrounding denser soil but the stresses are determined by the shear modulus of the looser sand in the pocket--see L Appendix 2 of Reference 12.
F L 26
The results presented in the above table are plotted in Figures 7 and 8 where they are compared with all the penetration resistance values of the sand which are i believed to represent relative densities less than 80%, based on the Gibbs and Holtz correlation. It may be seen that in all cases, except one, the sand is found to have a l factor of safety greater than 1.5 against liquefaction and, for the one test which does l not meet this criterion,- the factor of safety is 1.4. This isolated zone where the factor ' I I of safety is found to be 1.4 would build up only negligible pore pressures during the SSE and is not considered significant in assessing the engineering adequacy of the overall i fill. On the basis of this analysis it is concluded that in spite of isolated locations where the relative density of the fill may be less than the value of 80% originally specified, the fill is sufficiently dense at all points tested to provide a substantial l - degree of safety against liquefaction during the postulated SSE. Since the test ! locations were randomly selected in an unbiased manner and their number is adequate l to provide a representative sample of the fill condition, it can therefore be concluded that the condition of the fill as placed is adequate. l I 5. ANALYSIS OF LIQUEFACTION RESISTANCE OF STRUCTURAL BACKFILL UN.DERLYlNG BUILDING MAT FOUNDATIONS 5.1 Introduction __ The test fill shows that the upper portions of the top layer consistently has a lower density than the underlying layers, even after rolling with 12 or more passes. Because of the concern expressed by the NRC, an analysis has been made of the liquefaction resistance of such a zone underlying the mat foundations for the Auxiliary Buildings. The lowest possible relativel density under adverse construction circum-stances is judged to be greater than 45 percent. Our studies show that a layer of soil
.with a relative density assumed to be 45% underlying building mat foundations will have greater resistance to liquefaction than a similar extensive layer due to two effects:
(1) The stiffer soil adjacent to the layer under the building will limit the strains in the loose layer and thus reduce the stresses below those which would develop if the layer were continuous. 27
8TANDARO PENETRATION RE318TANCE (N) 0 10 20 30 40 50 80 1 4 e i i [ 10 - { [ 20 - [ ~ N-VALUE REQUIRED TO PROVIDE
- F.S .= 1.5 AGAINST LIQUEFACTION
{ 7 FOR BULK OEPOSIT w y 30 - [ a g .. [ = E w 40 - [ i
=
[ 50 - [ .
. .. e .
[ 80 - t . . . . _ 70 {- - - [ [ SOUTH TEXAS PROJECT LIQUEFACTION POTENTIAL BULK DEPOSIT { FIG. 7 _ l
STANDARD PENETRATION RESISTANCE (N) 0 10 30 30 40 50 60 0 i i i i i 10 I 20 -
! E 1
5,30 - -
- E N-VALUE REQUIRED TO PROVIDE -
2 F.S.= 1.5 AGAINST LIQUEFACTION E FOR ISOLATED POCKETS OF LOOSE SANO
.5 3 40 - -
=
I I 50 i I 60 -
. - 70 SOUTH TEXAS PROJECT LIQUEFACTION POTENTIAL ISOLATED POCKETS l FIG. 8 29 l
i __-- _. _.
(2) The large area of contact between the loose layer and the underlying dense sand will permit dissipation of pore water pressures which will ( develop differentially in the two layers, thereby decreasing the pore pressures that develop in the loose layer, and increasing the pore l { pressures in the underyling sand. The beneficial effects of these two factors can be considered separately and later { combined to determine the overallliquefaction potential of the loose sand. 5.2 Undrained Analysis of Liouefaction Potential _ _ _ Suppose the system is modeled as shown in the attached Fipre 9 and that the building is represented by a rigid block of soil, equal in effective weight to that of the ( soil above 50 ft depth. This is somewhat conservative since the actual building is heavier than the excavated soil. The Auxiliary Building is used for analysis purposes. { . . Suppose also that if a layer of soil at 50 ft depth and with D,, = 45% were subjected in the free field to the SSE it would liquefy. These conditions are snown in { Figure 10. Then the stress conditions causing liquefaction of a layer of soil with D, = 45% may be determined from Figure 10. Thus T * # av max o { q , = 0.65 x o x o
,xr d
~~
-' ~
[ and at a depth of 50 ft c = 50 x 130 = 6500 psf a ' = 50 x 67.6 = 3380 psf r = 0.82 Hence for a = 0.lg (SSE) max r' L -
= 0.65 x 0.1 x x 0.82 = 0.10 -
338 f L u I L r e 30
[ 0 FT. $ -v RIGID BLOCK (REPRESENTING AUX. BLDG.) l [ g*8 C"O [ ; f l l f f f f f I l f ' { 50 FT.. _ _. _ -. _ ___ _ _ _ _ _ _ _ _ _ [ZUNEZB ZONE A i 0, = 455 0, = 80s l l RIGID BLOCK ON SAND LAYER l l l FIG. 9 l l l f~ ~~ ~ 0 FT. . .. _ _. I 7 sat = 130 LBS./CU. FT. l l 7b= 67.6 LBS./CU. FT. l I l
- g. 50 FT. ::::::::::::::: :::y :: ::
~
- -- - - :~- - ~ - --.~- -- - ~ - -
~ ~ ~ ~ ~ ~ ~ ~ ~ ' ~ ~ ~ ~ ~ ~ ~ ~ ~ ~
i f 4 Or =455 I. 1 g SAND LAYER AT 50-F00T DEPTH l FIG.10 l l l I 31. -
[ Thus, for D_ a 45%, e stress entin of 0.10 wruld be requir:d to c uss liqu fection. [ l It may be noted that this corresponds, for M = 6, to an Ny -value for the soil of l about 7 and a measured N-value of 9.5* Now referring to Figure 9, it may be seen { that the loose layer with D r= 45% is confined above by the base of the Auxiliary ) Building and on all other sides by sand with D = r 85%. For compatibility of deformations in the system, it is necessary that the shear strain for the soil in Zone B is the same as that in Zone A, i.e. the shear strains for the soil in Zone B are limited to the same magnitude as those for the soilin Zone A. Thus in Zone A (D = 80%) [ {
^!=0.65x0.1x 3380 x 0.82 = 0.1 -- --
o
.T = 0.1 x a '
{ . .
= 0.1 x 3380 psf
[ = 338 psf and shear strain, y is given by
. , 338 7"#
{ D = 80 where G s de shear mddus of sand wM D r" Dr = 80 (Note that for D = 80%, N > 30 and
- r 1 v
> 0.44. Hence o y, Factor of Safety against liquefaction > > 4.4.]
[ In Zone B (D = 45%) Shear strain is sa=e as in Zone A Hence Y = 338 { G ' [ D = 80 Shear stress = T
=Y,xGDr = 45 where G D = 45 is shear modulus of sand with D = 45%.
F ( _ . _ . .
- Note that this is only true if it is assumed that a sand with D = 45% would liquefy under the postulated conditions. In all probability such a soi[ would have a small F factor of safety against liquefaction but the conservative assumption that it would L liquefy is made for present purposes.
p 32.-
[ 338 i.e. Shear stress = T y = g xG { D = 80 r D = 45 r ( Since effective overburden pressure a ' = 3380 (as for Zone A) T r" i
. Stress Ratio in Zone B = g av = 338
* ~
{ . o 3380 G D = 80 r i GD #
= 45 '
l b = 0.1 x U D = 80 r [ c For sand, the ratio C D = 45
= 0.67 -----
D = 80 r Hence the stress ratio developed in Zone s = 0.1 x 0.67
= 0.067
{ [ But the stress ratio required to cause liquefaction for sand with D r= 45% was previously shown to be 0.1 for a Magnitude 6 earthquake. Hence, without benefit of l ( pore pressure dissipation, the factor of safety against liquefaction of the loose layer of sand in Zone B is given by
- s
' av_
=
( FS = 0.067
* ~ ~ ~ ~
o dev [ 5.3 Analysis of Liquefaction Allowing for Pore Pressure Redistribution __ Because under earthquake shaking, the rates of generation of pore water ( pressure in a loose sand and dense sand will be very different, there will be some u 33
I redistribution of pore water pressure as the higher pressures generated in the loose sand dissipate into the low pore pressure zones in the dense sand. This effect alone would cause the liquefaction potential of a loose sand layer with extensive drainage boundaries to be significantly less than for the same layer under undrained conditions. Two types of studies may be used to assess the potential effects of pore pressure redistribution on the liquefcetion potential of the loose sand (Dy= 45%) layer underlying the mat foundations for the structures.
- 1. Laboratory test data conducted on composite samples involving adjacent layers of loose sand and ense sand. Such tests, summarized in Appendix 1, show that due to pore pressure redistribution, a loose sand may have its liquefaction resistance in:reased by factors varying from 12% to 38%
depending on the conditions of the two layers involved. For the marked difference in relative densities involved at the base of the mat foundations for the structures where the relative density changes from 45 to 80% over a very short distance, it may be expected that the liquefaction resistance of the loose sand would be increased by a factor of about 1.2 due to pore pressure dissipation and redistribution effects.
- 2. Analytical studies of pore pressure redistribution for the conditions exist-ing at the base of the Auxiliary Building. These studies are summarized in Appendix 2, and show that due to pore pressure redistribution along the base of the loose layer, the effective liquefaction resistance of this layer will be increased by a factor of the order of 1.25.
I~ Overall, an increase in liquefaction resistance of 1.25 due to drainage effects seems a reasonable value to adopt. 5.4 Final Assessment of Liouefaction Potential __, _ _ _ , _ Since, under undrained conditions, the factor of safety against liquefaction of I the loose layer is about 1.5 and due to pore pressure redistribution the liquefaction resistance can be expected to increase by a factor of about 1.25, the overall factor of
- I 34
( safety against liquefaction of this layer may be considered to be of the order of 1.5 x 1.25 = 1.85. Other factors might also be cited as increasing the stability of this layer ( (penetration of cement into sand, for example) but the indicated factor of safety of 1.85 is already high enough to dispel concern regarding the consequences of the { existence of a 4 inch-loose layer of sand with relative density of about 45% under the , base of Category I buildings. The effect of density distribution within the full depth of the surface lift can be assessed based upon this analysis. For example, the results of {
- this study would not be significantly changed if the layering of the sand under the Building were
[ 0"- 4" sand with Dr= 45% 4" - 10" sand with D, = 60% 10" - 19 ft sand with Dr= 80% since the sand with D, = 60% would already have a sufficiently high resistance to { liquefaction that pore pressures developed by direct earthquake shaking in this layer would be negligible and it would behave, for all practical purposes, as a sand with D = r 80%. This considered case envelopes the possible 9-inch depth of material with less { than 80% relative density hypothesized by the NRC. [ 5.5 Conclusion ___. _ Although the analysis was made specifically for the Auxiliary Building, it is our judgment that similar analyses would show similar results for any of the Category 1 ( building mat foundations. Therefore, it is concluded that the presence of a 4 to 10-inch thick layer of loose sand under Category I building mat foundations will have ( no significant effect on the performance of these buildings as a result of the shaking produced by the SSE. [
- 6. CONCLUSIONS _ _ . _
[ The Expert Comr9 tee has reviewed in detail the density of the Category I structural backfill at the South Texas Project Electric Generating Station. We conclude that with the type of compaction equipment used, the number of passes actually accoinplished and the thickness of the layers placed, a dense, homogeneous, I compacted structural backfill resulted which is more than adequate for the intended [ s 35 l I
( us2 and is gen: rally in accordance with specification requirements. IIowever, four l zones have been detected in which the Standard Penetration Resistance of the { structural backfill, based on a commonly accepted correlation, would indicate a l relative density less than 80%. The test locations for the borings were selected in an l unbiased manner and their number is adequate to provide a representative sample of { the fill conditions. The studies included in this report show that in three cases the zones are found to have a safety factor greater than 1.5 against liquefaction, and for the fourth case the minimum factor of safety is 1.4. The negligible pore pressures which might build up in isolated zones are not considered significant with respect to the adequacy and safety of the overall structural backfill. The Committee has evaluated the actual field control procedures for determin-ing relative density and concludes that the procedures used yielded values of relative density which are conservative and exceeds the specification requirements. The actual frequencies of field and laboratory testing far exceed the specification { requirements and are judged to be most adequate. Based on a review of the data from the June 1980 test fill, the Committee considers it probable that the backfill immediately under the mat foundations has a l relative density lower than 80%. The detailed studies included herein show that even ' for an assumed relative density as low as 45%, the presence of such a layer will have no significant effect on the performance of the building as a result of the shaking b produced by the SSE, and the factor of safety was found to be in excess of 1.8. [ From the results of the June 1980 test fill, the Committee further concludes:
- 1) that the project vibratory rollers are capable of compacting the specified lift
{ thickness to the required densities; 2) that there is uniformity of compaction through-out backfill placed in 18-inch or smaller lifts, except for the upper portion of the top lift; 3) that the density testing depth below the backfill surface is not a critical factor, since tests taken in the upper lif t or upper part of underlying lift produce conservative results (lower density values with additional compactive effort and retests accom-plished as required); and 4) eight roller pass.es is a satisfactory minimum compaction criteria, to obtain engineering integrity and safety, and a proper starting point for acceptance testing. n . E c F L 36 F. { t .
. __ - __ _ 1
The overall conclusion is that the condition of the fill as placed is better than the design requirements. M . WA m L ; A. J./Hendro4/Jr. CT - l r H. Bolton Seed thcbo e. ] I UA-(m Stanley DUWilson I I I E I I h I I l 37 l
I LIST OF REFERENCES
- 1. Woodward-Clyde Consultants, Basic Soils Data - South Texas Project, July 1975 (3 Volumes) TPNS No. YO50XRO37-WL
- 2. Woodward-Clyde, Consultants, Excavations and Backfill for Power Plant Struc-tures, South Texas Prefect. Units 1 and 2, August 8,1975.
- 3. Brown & Root,Inc. STPEG5 Specification," Structural Backfill," 3YO69YS029
- 4. Brown & Root, Inc. STPEGS Quality Construction Procedure, " Structural Back-fill," A040KPCCP-2 3 5. Brown & Root, Inc. STPEGS " Test Program for Compaction of Category I E Structural Backfill," TRD 3A700GP002 I '
- 6. Woodward-Clyde Consultants memorandum dated 7 July 1980, "(Preliminary)
Mapping of Structural Backfill Lift Thicknesses," WCC-STP-025
- 7. Brown & Root, Inc. STPEGS Technical Reference Document, " Category I Strue-tural Backfill Placement and Quality Control Data," 3A700GP001
- 8. Gibbs, H.J., and Holtz, W.G., Proceedings. Fourth International Conference on Soil Mechanics and Foundation Engineering, Vol.1,1957, pp. 35* 39.
- 9. WCC letter dated May 28,1980, (ST-WC-BR-5671) regarding relative density of structural backfill
- 10. WCC letter dated May 28,1980, (ST-WC-BR-5672) regarding relative density of structural backfill i
- 11. Seed, H. Bolton, " Soil Liquefaction and Cyclic Mobility Evaluation for Level Ground During Earthquakes," Journal of the Geotechnical Engineering Division, ASCE, Vol.105, No. GT-2, February 1979, pp. 201-255
- 12. Seed, H. Bolton, letter dated June 16, 1980, to Woodward-Clyde Consultants regarding liquefaction potential of STP site I l g
I I I I se
[ i Appendix 1 ExperimentalInvestigations of Influence of Loose Layer on Licuefaction Characteristics of Composite Samples _
- 1. Cyclic Triaxial Tests by Mulilis I Mullis performed cyclic triaxial tests on composite samples, 7 inches high and 2.8 inches in diameter with compositions as follows:
Series 1: 2-V2 inches sand with Dr = 85% 2 inches sand with D = 50% r 2-U2 inches sand with D7 = 85%
~
Series 2: 1-3/4 inches sand with Ur = 85% I 3-V2 inches sand with Dr = 50% l-3/4 inches sand with Dr = 85% In both series the liquefaction resistance of the composite samples was greater than that of the loosest layer in the sample and the com* posite sample behaved Jike a sample with an effective relative density greater than 50%. This was attributed to the re-distribution of water content as cyclic loading progressed with~ water moving from the loose sand, which developed pore pressures rapidly, to +.he dense sand which developed pore pressures slowly, to produce an equlibrium condition. This has the effect of I making the loose sand behave as if it were in fact denser than it really is. The magnitude of this increase in effective relative density, as shown by the test results is I summarized below: Thickness of Layer Combined Thickness of Effective D for '_ with Dr= 50% Layers with Dr= 85% Composite Sdmple 2" 5" 69 % j 3-U 2" 3-U 2" 59 % ) I ' Thus the average increase in effective relative density above that of the loosest layer in the sample is given by: 1 I l l 39
Effective Relative Density = 1.3 x (D )1oosest r layer
- 2. Cyclic Simole Sheat Tests by Mori 2
{ These tests were conducted using simple shear tests on samples 90 inches long by 42 inches wide by 4 inches thick. Samples were constructed as a 3-layered system r as follows: ( . 1.3 inches of sand with D = 70% r 1.7 inches of sand with D, = 50% 1.0 inches of sand with D, = 70% In this case also it was found that the liquefaction resistance of the composite sample r L was greater than that of the loosest layer in the sample, presumably also due to differential rates of pore pressure generation and redistribution of pore pressures { betwcen tae loose and dense sand layers, m { The tests showed that the liquefaction resistance of the composite sample was equivalent to that of a uniform sample having a relative density of 56%. In other words the' loose sand behaved as if the ; Effective Relative Density = 1.12 x (D r) loosest layer Both of these test programs show that pore pressure dissipation and associated water
/
content redistribution by drainage can be expected to increase the effective liquefac-tion resistance of a loose sand layer when it is adjacent to a dense layer of similar [ material. For the samples investigated the increase in resistance varied from 12 to 38% even when the dense sand was relatively thin. Greater effects would be expected { for thin layers of loose sand adjacent to increased thicknesses of dense sand. References . _
- l. Mulilis, John Paul (1975) "The Effects of Method of Sample Preparation on the Cyclic Stress-Strain Behavior of Sands," Ph.D. Thesis, University of California,
[ Berkeley.
- 2. Mori, Kenji (1977) " Factors Affecting the Liquefaction Characteristics of
[ Sands," Ph.D. Thesis, University of California, Berkeley. m L 40
L
. Appendix 2
[ AnalyticalInvestigation of Influence of Fore Pressure Redistribution on Liquefaction { , Characteriples of Loose Layer Underlain by Dense Layer of Sand [ For this study an analysis was made of the re-distribution of pore water presstjes in the soll deposit underlying the Auxiliary Building The sand underlying the building was assumed to have a relative density of 45% ( for a thickness of 4 inches and thereafter a relative density of 80% to a depth of 20 ft below the base of the building. This was considered a conservative representation of a ( situation where the relative densities varied as follows: 4" sand with Dr= 45% { 6" sand with Dr= 60% 6" sand with Dr= 80% { It was assumed that the two sand layers in the analytical model had properties [ as follows: Dg = 45% Dr= 80% Thickness : 4 inches 20 ft [ Coefficient of Permeability : 2 x 10
~3 cm/see 1 x 10 cm/see E 7 Coefficient of Volume Change : 2 x 10 sq ft/lb 5 x 10 sq ft/lb
[ Under undrained conditions it was assumed that the loose sano would develop a ( , pore pressure ratio of 100% and liquefy in an average of 4 stress cycles applied over a period of 8 seconds. The analysis was made using the procedure developed by Seed et al (1976) and verified experimentally by Yoshimi (1977) to determine the pore pressure distribution' after 8 seconds of similar shaking if pore pressures were allowed to dissipate from the loose sand to the dense sand as shaking progressed. The analyses showed that after 8 seconds, the pore pressure ratio in the loose sand layer would be about 29%. [
- 41
[ A similar analysis was made for an earthquake causing liquefaction of the loose sand layer, under undrained conditions, in 2-1/2 stress cycles developed over a period of 6 seconds. With allowance for drainage it was found that pore pressure ratio in the loose sand layer at the end of 6 seconds would be about 34%. ( Assuming the applied cyclic stresses produced a pore pressure ratio of 35% in ( the loose sand layer it may readily be shown that this corresponds to a factor of safety of 2.5 in terms of the the number of cycles required to cause liquefaction, or alterna-tively, a factor of safety of 1.25 in terms of the stresses which would have to be { developed to cause liquefaction to occur. [ In other words, the effect of pore pressure dissipation and redistribution is equivalent to increasing the resistance of the loose sand by a factor of 1.25. If the sand would just liquefy with no drainage, the factor of safety would be 1.25 if drainage is considered. This is in good agreement with the experimental results of Mulilis and { Mori. References ._ _ _ ,
- 1. Seed, H. B., Martin, P. P. and Lysmer, J. (1976) " Pore Water Pressure Changes Duiing Soil Liquefaction," Journal of the Geotechnical Engineering Division, ASCE, Vol.102, No. GT4, Proc. Paper 12074, April,1976, pp. 323 -346.
- 2. Yoshimi, Y., et al. (1977) " Soil Dynamics and Its Application to Fouadation Engineering," State-of-the-Art Report, Proceedings, IX International i Conference on Soil Mechanics and Foundation Engineering, Tokyo, Japan,1977.
[ -
)
i [ [ . O s [ [ 42
L [ - I i l RESPONSE TO ITEM (3)(a) .. Order: __ A review shall be made of the safety-related work described below, completed as of the date of-this Order to determine whether such work was properly performed. j l If repairs are required, describe the extent of the repairs necessary and the schedule for completion. { Also describe the manner in which the review was ( completed and extent of the review. (a) Safety-related welding including civil-structural and piping. Response: _ __ [ A. B&R/HL&P Safetv-Related Welding Task Force _ _ _ _ __ _ _ _ . ._ _ Upon issuance of the Show Cause Order, B&R and HL&P formed a special Task Force review team -to formulate { a comprehensive program to re-assess and verify safety-related welding at ST?, and to determine whether the b safety-related welding work completed as of the date of ' the Order was properly perfe;med. The Task Force was also given the responsibility of identifying any repair work that might be required, and establishing a schedule for completion of such work. L F (3a-1) r
k The Task Force includes working level engineers, supervising engineers, and technical support staff personnel from the B&R and HL&P Engineering, B&R Con-struction and B&R QA/QC Departments. In addition,-a well-known consulting organization, Nutech, was retained to assist the Task Leader in organizing and conducting the review. Nutech is also providing staff support, working level engineers, and supervising engineers for l the Task Force. Nutech has obtained additional qualified personnel in the field of nondestructive examination from Southwest Research Institute (SWRI). In addition, early in the review process the Task Force established ari Independent Review Committee - consisting of two Nutech engineers knowledgeable and experienced with the ASME Code and one SwRI engineer knowledgeable and experienced in nondestructive examina-I tion. The Committee members are: R. F. Reedy, Chief Consultant, Nutech l D. P. Hegglin, QA Engineering Manager, Nutech S. A. Wenk, Institute Engineer, SwRI Copies of the Committee members' resumes are attached l as Exhibit Nos. 10, 11 and 12. l The functions of the Independent Review Committee are to independently review and approve the Task Force programs and reports, assure the Task Force is properly I l . I I (3a-2)
[ . [. implementing the programs, provide technical and code advice, and assist the Task Force in making recommenda-tions for corrective action and additional review. [ It was agreed by the Welding Task Force that "embedments such as supports and the fuel transfer tube," as referenced in the Show Cause Order, Item (3)(b)., { involved issues of material traceability and,the applica-tion of Section III of the ASME Code, and that those ( items would be best addressed by the Welding Task Force in response to Show Cause Item (3)(a), and are dealt with in this response. The Task Force defined the scope of the review to { encompass safety-related field welds performed by B&R h from the start of construction until the time safety-related welding was halted by HL&P and B&R in April
- E 1980. The safety-related welds being examined by the
{ Task Force include all ASME Section III pipe and pipe hanger welds and Seismic Category I structural steel welds made in accordance with the AWS D1.1 Structural I Welding Code. The Task Force implemented a program l directed at providing the necessary confidence in the { quality of the completed welding work. This program defined a series of activities starting with a complete review of all welding documentation; review of all E r I (3a-3) r [. _
[ [ welder and inspector qualification records; examination of the traceability of all base metal and weld filler { material; and finally verification and re-examination of selected welds through a random sampling program. The random sampling plan was implemented based on MIL-STD-105D, " Sampling Procedures and Tables for { Inspection by Attributes" (including Change 2). The review of safety-related welding was divided into the following areas:
- 1. A review of the Nondestructive Examination (NDE) program and a reevaluation of all existing radiographs and other NDE Reports.
. This included the performance of additional NDE as required for the review.
- 2. A review of the safety-related AWS welding i E
program, including welding procedures, weld { documentation and acceptability of field purchased base material.
- 3. A review of the ASME welding program, includ-ing welding procedures, weld documentation and acceptability of field purchased base
{ material. Also included is an investigation of the concerns regarding the fuel transfer 1 tube and steam generator supports. I u F (3a-4) F
b
- 4. A review of welder qualifications and welding
{ filler material test reports.
- 5. A review of the " unresolved items" identified
/ in the NRC Investigation Report; past NRC, HL&P and B&R audit reports; and field generated documents, including Nonconformance Reports { (NCRs), Field Requests for Engineering Action (FREAs), and Corrective Action Requests l (CARS) related to safety-related welding. The Task Force review program has been documented in the B&R Technical Reference Document (TRD) entitled ! j " Review of Safety-Related Welding" (TRD 5A700GP004). j Each of the general areas of review has been divided 1 I into more detailed and defined tasks and, where required, forms and checklists have been developed to aid in data collection and review. The TRD will be updated periodi- { cally to incorporate changes in and results of the program. C' l B. Task Force Program Review _.
- 1. Nondestructive Examination (NDE) Procram . - . --
1.1 Program Review __ f The review of the NDE program has four tasks: (1) a review of NDE procedures; (2) a review of Inspector qualifications; (3) an evaluation of the authenticity I I , (3a-5)
b I of original radiography, including performance of l additional NDE; and (4) a reevaluation of existing I radiographs and other NDE reports. The NDE procedures l have been reviewed for completeness and compliance with Code and project requirements. The qualifications of personnel who inspected ASME piping and Category I structural welds are being reviewed to verify that the personnel were properly qualified and certified in accordance with Code and project requirements. For ASME piping, the existing radiographs and NDE inspection results on weld data cards, weld data repair cards, and QC inspection reports are being reviewed for complete-l ness and compliance to code and project requirements. 1.2 Results _ _ . The review of Nondestructive Examination procedures has identified the need for improvements which have been and are being incorporated into the NDE procedures. A review of the qualification files for NDE inspectors who performed safety-related inspections on site identi-fied various types of irregularities in the qualification of twenty-one of the seventy personnel. These irregulari-ties include uncertified personnel performing NDE (7); lack of recertification after rehire (3); inspector signed as a higher level (5); no eye exam during NDE I (3a-6)
[ exam (1); and expiration of eye exam certification (1). In addition, the Task Force review determined that files covering nine inspectors out of the twenty-one ( identified above contained documentation showing insuffi-cient training and/or experience for performing examina-tions. Personnel qualifications will be reviewed by the Brown & Root Level III and the Task Force Level III to determine the corrective action for the Task Force ( findings. Further review is required of previous QA procedures and training manuals containing project requirements for personnel qualifications. In addition, the Level III program of certifications and NDE examina-tions'is being reviewed. - The authenticity of the original radiographs has been established by matching readily identifiable [ indications on a radiographic film to the same indi- { cations on the surface of the corresponding weld or an additional radiographic film of tha corresponding weld. [ There was no evidence of any falsification of radiographs. A reevaluation of all final-accepted radiographs [ has been performed. These radiographs were reviewed by { certified NDE Level III examiners in radiography for compliance with the ASME Code and project requirements. [ Each radiograph was evaluated for defect interpretation [ [ (3a-7)
l l l l and specific film characteristics required by the ASME Code and Project procedures. Twenty-four percent of l the radiographed welds, which had previously been j accepted, were considered unacceptable because of one or more of the following problems with their associated radiographs: improper identification; improper use.of I l documentation of penetrameter; lack of required sensi-l tivity; lack of required density; or rejectable indications. l Approximately sixteen percent of the welds had radiographs with rejectable indications. l l In order to evaluate the previously accepted I l examinations on ASME welds, additional NDE (visual examination and liquid penetrant) was performed on a l randomly selected sample of eighty welds and evaluated in accordance with Code and Project requirements. The { re-examination of socket welds found fourteen of forty-three' welds having unsatisfactory conditions. The re-examination of the pipe butt welds (other than ECW pipe) in the sample found one unsatisfactory weld out of twenty-two re-examined. Fifteen Control Rod Drive l Mechanism welds were also included in the sample and l the examinations found no unsatisfactory conditions. The reexamination of thirteen accessible ECW pipe butt i I l 1 I (3a-8)
I welds, which were in a separate sample, revealed indi-cations in six welds. These are surface indications which are believed to be non-relevant under the Code, and were caused by weld spatter and sharp corners which should have been cleared prior to acceptance.
- 2. Safety Related AWS Welding Program 2.1 Program Review i The review of AWS welding has three tasks associated with it: a review of AWS Category I weld documentation, a review of Category I structural steel material certifi- l cations, and a review of AWS welding procedures. All AWS Category I erection weld documentation has been reviewed and tabulated. From this tabulation, a random sample of welds was selected for re-inspection. For i
AWS Category I shop welding, all shop work requests have been reviewed to identify those requests which required welding. A random sample of the welding work requests was selected for a detailed documentation review. The Category I structural steel material certifications are being reviewed for compliance with Code and project requirements. The AWS welding pro-cedures are also being reviewed for compliance with Code and project requirements by comparison against primary documents (i.e., AWS Code, AISC Manual, and Design Specifications ) . lI (3a-9)
l 2.2 Results The results of the review of Category I shop and field erection weld documentation are: (a) lack of ( evidence that the inspectors in all cases performed all in-process checks on all welds; (b) lack of sufficient traceability of final inspection documentation in all cases for eacli weld or group of welds; (c) lack of { assurance that all the existing inspection documentation ( represents all completed field welds; and (d) lack of verifiable documentation that welders who were qualified [ in limited positions were always welding within their qualifications. While all of this detailed documentation { was not necessarily required by the Code or Project ( procedures, it would have been beneficial to the Task Force in their evaluation of the condition of the completed welds. Following NDE program documentation { review, visual examination of a random sample of seventy-nine Category I Structural Steel welds was performed. [ This examination revealed certain irregularities with sixty-one welds, such as undersized welds, improper i [ ! contour, overlap, undercut, and arc strikes. These j [ results identify that the specified weld acceptance criteria were not always properly applied by some L inspectors. E L r (3a-10) r
L [ [ 3. ASME WELDING PROGRAM . . _ _ 3.1 Program Review { . The review of ASME welding consists of a review of ASME piping weld documentation, a review of ASME welding procedure specifications, an ASME piping walkdown, and an investigation of the NRC concerns with the fuel { transfer and-steam generator supports. For ASME piping, weld documentation data has been compiled from the b system isometric drawings, technical reference documents, weld data cards, weld data repair cards, well material requisitions, and material certifications for base and { filler materials. Evaluations are now being made for each weld based on information obtained in other tasks (i.e. , review of.NDE procedures, review of inspector qualifications, reevaluation of. existing radiographs, [ . review of ASME welding procedure specifications, review I { of welder qualifications and review of welding material l certifications). The weld data cards are also being reviewed for completeness and proper sign-offs. The review of ASME pipe hanger documentation will be performed in a manner similar to the ASME pipe weld [ documentation review. The ASME welding procedure specifications are being reviewed for compliance with l Code and project requirements by comparison against F L ? w (3a-11) ~
k l i primary documents (i.e., ASME Code, Design Specifications 1 and Technical References Documents). The ASME piping l walkdown will be performed to physically verify informa- [ tion collected in the ASME pipe weld documentation review. The fuel transfer tube and the steam generator ( supports are being investigated to verify the basis on which changes were made in Code classification material { traceability, and inspection /hydrotesting. ( 3.2 Results Approximately 1300 ASME welds (including 480 welds [ in the Essential Cooling Water System) have been completed or are in-process and the applicable weld data has been
~
collected. Detailed technical review has been accomplished for approximately twenty per cent of the welds and the results indicate that in some limited instances, inadequate [ attention was given to recording the-data on some weld {. data cards. The review has identified certain procedural irregularities that require-investigation before a resolution can be made. Technical review of-the data collected on pipe welds will continue to completion. A review of pipe supports and hangers will commence as ( soon as the task on pipe welds is completed. The investigation of the NRC concerns regarding the fuel { transfer tube and steam generator supports is in process. I s t (3a-12) r-
L
- 4. Welder Qualification and Weld Material
{ 4.1 Program Review The review of welder qualifications is performed by reviewing welder performance qualification test records to verify that all welders who welded ASME piping and Category I structural steel were qualified [ in accordance with applicable codes and project require-ments. Continuity of certification is being checked against employment records for these welders. The Task Force listed the manufacturer's heat / lot numbers for the weld filler materials used in each ASME weld, in order to verify traceability. The associated certified i material test reports will be reviewed for Code com-pliance, and the material type will be checked against { that required by the welding procedure specification. The system for controlling distribution of the filler ( metal will be reviewed for Code and specification ccmpliance. 4.2 Results . - . { A review of the welder performance qualification by radiography indicated two irregularities in the [. procedures: (1) the use of film side versus source side penetrameters on some of the welder coupons tested; and (2) the use of.. less stringent ASME acceptance r c L (3a-13) c
[ criteria instead of the AWS acceptance criteria for the AWS test coupons. These concerns will be evaluated to determine the acceptability of the affected qualifications. [ Review of welder qualification records covering approximately twenty-five percent of the ASME pipe welds has found no discrepancies. This review will be com-pleted when all weld data cards have been reviewed. The welders employed on AWS Structural Steel field [ erection welds were properly qualified to weld in at least one position. Welding filler materials used for safety-related welding have been identified. It has been det' ermined that the materials were supplied by vendors approved by [ the project and traceability has been maintained. The certified material test. reports will be evaluated for E compliance to Code and Project requirements. { 5. Review of Documents Pertaining to Welding _ ._ _ 5.1 Program Review A review of the " unresolved items" identified in the NRC Investigation Report is being performed to - E evaluate and resolve the reported concerns. Past NRC, { HL&P, and B&R audit reports have been reviewed to determine the extent to which audit deficiencies have I L been properly dispositioned. Field generated documents E " l F (3a-14) r .
L [ including Nonconformance Reports (NCRs), Field Requests for Engineering Action (FREAs), and Corrective Action { Requests (CARS) have been reviewed to verify that each [ has been properly dispositioned. The PSAR/FSAR and engineering specifications have been reviewed to [ identify the applicable edition and addenda for all specified codes and standards. The construction and QC { , procedures (current and past revisions) covering safety- [ related piping and Category I structural steel are being reviewed for consistency and compliance to project [ requirements. l 5.2 Results { ' An investigation of the " unresolved i.tems" identified [ in the NRC Investigation Report will continue to completion. Past audits and field generated documents such as NCRs, FREAs and CARS related to welding are being reviewed. { The review of past audit reports has indicated that written audit plans were not developed in accordance [ with ANSI N45.2.12, Draft 3, Rev. 4, " Requirements for Auditing Quality Assurance Programs for Nuclear Power [ Plants". An initial review of field generated documents [ has been completed, but an evaluation of the information gathered is required. r L (3a-15) (
I l The engineering specifications and construction I procedures have been reviewed for consistency and 1 j compliance with PSAR/FSAR. Some inconsistencies have I l been noted regarding codes and standards effectivity- - dates. The results on the ongoing review of welding - and construction procedures are being evaluated for i incorporation into the current procedures. These j results and the noted inconsistencies will be evaluated to determine whether the installed equipment could have been affected. C. Revised Welding Inspection Program _ . _ _ . _ . _. . The findings from the review completed to date indicate that it is necessary to change the Task Force weld inspection program to one that emphasizes. physical examination of accessible welds. Certain tasks in the original Task Force program such as review of material certifications, welder qualifications, ASME weld documen-tation and the review of governing documents will be continued to completion. The revised welding inspection program divides the safety-related weldments into four groups: (1) Cate-gory 1 Structural Steel Welds, (2) ASME Essential Cooling Water (ECW) Pipe Welds, (3) ASME Pipe Welds other than ECW Welds, and (4) ASME NF Support and
- I Hanger Welds.
(3a-16)
L [ b 1. Category I Structural Steel Welds _ p All accessible welds will be visually re-examined L by inspectors who have been retrained to the AWS { Cede D1.1-75 with special emphasis on the detailed requirements of the code. This training will also include a detailed review of.the welding and NDE procedures which include the Code and design specification requirements. The results of the [ reexamination will be evaluated and accessible l welds will be repaired as required. The weld characteristics and other pertinent information will-be statistically classified for use in an engineering analysis of inaccessible welds to [ determine their acceptability.
- 2. ASME Essential Cooling Water Pipe Welds . . _ _ _ . _
The Task Force reevaluation of the radiographs identified that a significant number of ECW pipe welds, which had previously been accepted, contain [ rejectable indications. Also, the reexamination by liquid penetrant method indicated certain E surface conditions were not cleared prior to final { acceptance of the weld. The Task Force has deter-mined that the following action will be taken: b (a) the B&R Level III and the Task Force Level I u ~ ~ (3a-17) m t
L [ III will review the radiographs found by the Task Force to have unacceptable indications in order to determine the welds requiring repair. In cases [ where the welds are buried in or under concrete, an engineering evaluation will be performed to determine the necessity of repair; (b) before commencing needed repairs, the entire weld will be [ . examined by liquid penetrant and radiographic [ methods irrespective of whether spot or full radiography was employed originally; (c) follow-ing these examinations, all rejectable indications will be repaired; (d) the repaired segments of the welds will be reexamined by rauiography and [ liquid penetrant for final acceptance; and (e) the results will be evaluated with regard to j b inspector and welder performance to determine if { additional welds need inspection. 3. I ASME Pipe Welds Other than ECW Welds _. __ _ ( The B&R Level III will review the qualifications of liquid penetrant inspectors to determine whether [ additional welds require reexamination. In addition, { he will reevaluate the remaining radiographs to establish the need for weld repairs. Based on the b findings stated in Section 3.1.2 of this response, F L F L (3a-18) r
L [ [ all accessible socket welds and a larger sample of [ butt welds will be reexamined. All rejectable indications will be repaired and reinspected for final acceptance unless.the welds are embedded in concrete. In these cases, an engineering evaluation [ will be performed to determine the necessity of [ repair. .
- 4. ASME NF Support and Hanger Welds __ __ _
The existing weld documentation will be reviewed and evaluated. A sample of the support and hanger welds will be reexamined to determine the overall [ condition of the welds. In addition, the inspec-tions performed by unqualified personnel will be [ repeated. D. Status of Welding Program { _ _ _ __ All work at the STP Site involving safety-related [ welding was halted by HL&P and B&R in April, 1980. Region IV I&E has been notified, pursuant to 10CF250.55(e) [ of deficiencies in the STP welding program, as discussed { above. As discussed in the Licensee's Response to order to Show cause, a gradual restart on a controlled b basis in accordance with a step-by-step program of planned activities has been prepared. In addition to b the efforts of the Task Force described above, a number b c L (3a-19)
1 of improvements have been made in the B&R welding and NDE Programs. Procedures have been rewritten in simplified [ language, using a new format and which contains relevant information from specifications, technical reference documents, codes, standards and regulatory documents. Improved training programs for welding and NDE activi-ties have also been implemented. Results of the Task [ Force efforts are being carefully analyzed for further improvements to these programs. E. Repairs and Schedule for Completion _ _. __. _ The repair work required as a result of the Task Force review of welding wil'1 commence and be undertaken i [ under the same controlled conditions as previously described for the commencement of new safety-related { welding. Consideration will be given to making repairs ' { as ongoing examinations are being performed in accordance with the revised welding inspection program.
)
[ I E MS:06:E i E l E - r (3a-20) i
ROGER F. REEDY, P.E. CHIEF CONSULTANT ( Professional Recognition .. American Society of Civil Engineers [ American Society of Mechanical Engineers ASME Boiler and Pressure Vessel Comittee [ Member - Main Comittee . l Chairman - Subcomittee on Nuclear Power (S.C. III) , ASME Nuclear Codes and Standards Comittee { ANSI /ASME N626.3 Specialized Professional Engineers Chairman - ASME Pressure Vessel and Piping Division Registration _ [ Structural Engineer, State of Illinois Civil Engineer, States of California, Illinois, Indiana, [~_ Michigan and Wisconsin Education { BS in Civil Engineering, Illinois Institute of Technology [
~
Professional Experience - 1976 - NUTECH, San Jose, California [ Chief Consultant ' 1956 to 1976 - Chicago Bridge and Iron Co., Oak Brook, IL [ Senior Engineer Sumarv { Mr. Reedy has worked in the pressure vessel industry since 1956. This experience includes design, analysis, fabrication and [ erection of nuclear containment vessels and reactor vessels. His background includes boiling water, pressurized water and HTGR L [ RrR-1 l 12/01/79 I l E u r L nutech I c -
\
R. F. Racdy (Continuad) . nuclear power plants, as well as pressure vessels for the petro-l leum, chemical and other energy industries. l In addition, Mr. Reedy has been involved in licensing, engineer-ing review and pnoj ect coordination. He has testified before l regulatory groups including USNRC, ACRS and ASLB regarding design criteria, analysis, fabrication techniques and fracture teugh-ness. Mr. Reedy has actively participated on major nuclear codes and standards committees in the development of criteria for nuclear power plant components and is currently a member of the ASME Boiler and Pressure Vessel Main Committee. - 1 I I I I l I I I RFR-1 12/01/79 I
EXHIBIT 11 l DANIEL P. HEGGLIN, P.E. l ENGINEERING MANAGER I Professional Recognition l American Society of Mechanical Engineers Registration . - - l Quality Engineer, State of California ~ Education l BS in Mechanical Engineering, Illinois Institute of Technology l } Professional Experience 1978 - NUTECH, San Jose, California Engineering Manager 1976 to 1978 - Edward E. Varnum Co., Inc. Quality Engineer 1964 to 1976 - Chicago Bridge and Iron Company Project Manager Summary Mr. Hegglin has had experience in the steel fabrication industry since 1.964. As a consultant, he was responsible for working with j management and staff of domestic and overseas material manu-facturers and fabricators to develop management and manufacturing programs which met the requirements of the ASME Code. l Additionally, Mr. Hegglin was responsible for the training and indoctrination of the people with whom he worked. Mr. Hegglin has performed audits to assure conformance to Code I cnd Company operating manual requirements at steel plate mills, l 1 foundaries, pressure vessel manufa:turers, tank manufaeturers, l . r DPH-2 03/01/80 nutech
L [ D. P. Hegglin (Continued) b . end valve companies, and has directed development of manu-b facturing, fabrication, inspection, and testing procedures, procurement specifications, nonconformance dispositions and cor- [ rective action measures. [ In proj ect management, Mr. Hegglin has been involved with manu-facturing and field construction of nuclear steel containment liners, and pressure vessels. { Quality Engineer, Corporate Auditing Supervisor, His previous experience as a and Proj ect Quality Assurance Manager for BWR and PWR nuclear reactor pressure vessels and metal containment vessels has provided him a broad base of experience in problems and techniques of shop b fabricatiori, field erection, and a working knowledge of nuclear codes and standards. b [ - b [ [ l E 1 E r L r - t DPH-2 03/01 /80 l l
EXEIBIT 12 [ Quality Assurance Systema and Er.s;.-d.s Division SAMUEL A.WENK [ institute Engineer 8.S. In Metallurgical Engineering, Virginia Polytechnic Institute,1936 [ Mr. Wenk's first activities in nondestructive testing were during World War 11 when he served as chief of inspection, Pittsburgh Ordnance District. After the war, at Battelle Memorial Institute, he [ organized and was chief of the nondestructive test research division which developed NDT methods L, for nuclear fuel elements, continuous fluoroscopic examination of longitudinal pipe welds, and other NDT solutions to industrial problems. He joined the Lawrence Radiation Laboratory in 1957 as chief of the engineering test secuen. In 1960, he became involved in the development of linear acceferators ( for high energy radiography, radiation therapy, and physics research. Prior to joining Southwest Re-search Institute, he had gained wide recognition for his work in high-energy and neutron radiogra-phy. Mr. Wenk was one of the small group which reviewed and edited the original ASNT NDT { Handbook. He presented the ASNT Lester Honor Lecture in 1967 and served three terms as a na-tional director and as chairman of the Long Range Planning Committee. He is a past national presi-dent of the society and served as chairman of the Board of Directors of ASNT from October 1978 to October 1979. Mr. Wenk also has served on the Executive Committee of ASTM Committee E-7 since 1950 and is a past national director of ASTM (1%5-8). He was chairman o' the National Materials Advisory ( Board Committee on Nondestructive Evaluation, which prepawa NMAB 252. He also served as member, Special Panel on Materia!s Fabrication and Testing,1957-8, and member, Standing Com-mittee on Evaluation of Materials, MAB 7,1960 3. He has been a consulting member of the Radio- * [- graphic Subcommittee of ASME and American National Standards Institute (ANSI Nuclear Advi. sory Board). He has written numerous papers in the field of nondestructive testing. He is certified by ASNT as a Level Ill examiner in radiography, neutron radiography, magnetic particle, and liquid penetrant testing and is a registered professional es.3ineer in Ohio. As Institute Engineer, Mr. Wenk is responsible for special projects within the area of his technical expertise in nondestructive testing, primarily in the field of radiography, where he is currently in- { volved in the development of a light weight, high-energy X ray source. He is also closely studying the feasibility of utilizing real-tim; imaging systems for nuclear power plant applications. {- PROFESSIONAL CHRONOLOGY: Metallurgical trainee, U.S. Steel Corporation,1937-8; open-hearth metallurgist, Jones and Laughlin Steel Corporation, 1938-40; U.S. Army lieutenant colonel, chief of inspection Pittsburgh Ordnance District,1940-5; chief metallurgist, Bowser, Inc.1946-8; E, Battelle Memorial Institute, 1948-57 (research engineer, Welding Division, 1948-50; chief NDT Re-search Division,1950 7); head, Engineering Test Section, Lawrence Radiation Laboratory,1957-9; radiographic product manager, Applied Radiation Corporation, 1959-60; manager, accelerator ap-plications, Varian Associates,1960 7; assistant chief Nondestructive Evaluation Section AVCO Space Systems Division,1967-9; manager, radiographic applications. High Voltage Engineering Cor-potation,1%9-70; Southwest Research Institute,1970-(senior research engineer,1970-1; manage, Field Services Department of Special Engineering Services,1971-4; manager, Research and Devel- { opment,1974 4; institote engineer,1976-). Memberships: Sigma XI, Fellow-American Society for Nondestructive Testing American Society for Testing and Materials, American Men of Science, Engineers of Distinction. 7 Rev Oct/79 ~ L I~ E I .
- h. .
[ [ ' RESPONSE TO ITEM (3)(b) . ( Order: A review shall be made of the safety- related work described below, completed as of the date of this Order to r [ determine whether such work was properly performed. If f. I. [ repairs are required, describe the extent of the repairs [ w . necessary and the schedule for completion. , [ Also describe the manner in which the review was I completed and extent of the review. i b *** i { (b) Safety-related concrete structures including i embedments such as supports and the fuel transfer l [ tube. A. Overview { Upon issuance of the Order, B&R and HL&P initiated [ a special Task Force review to perform a comprehensive l assessment of safety-related concrete structures at i STP.1/ The Task Force review is being conducted to determine whether safety-related concrete construction work, completed as of the date of the Order, was properly b _ _ _ . . _ . . . If It was determined by the Concrete Task Force that { "embedments such as supports and the fuel transfer tube," as referenced in the Order, involved issues of material traceability and the application of Section III of the ASME Code, and that those items would be addressed E by the Welding Task Force in response to Item (3)(a), above. l (3b-1) r I - _ _ _ _ _ _ _ _ _ _ _ _ _ _
l 8 1 I 1 I performed so as to meet all applicable structural I design requirements. In the course of the review, the Task Force is to determine whether any repair work is l required, and if so, it will establish a schedule for ! completion of such work. Thus far, no deficiencies requiring repair work have been identified. The schedule for completion of the Task Force review, which requires highly specialized technical l expertise and a large number of concrete placement examinations, is set forth in Exhibit 13 hereto. The schedule contemplates that Unit 1 and 2 Reactor Con-tainment Buildings (RCBs) will be reviewed by the end of August, 1980; Unit 1 and 2 Mechanical Electrical Auxiliary Buildings (MEABs) by the end of September, 1980; and Unit 1 and 2 Fuel Handling Buildings (FHBs) i by the end of October, 1980. l The Task Force includes over twenty full-time engineers from HL&P and B&R, who are receiving special-ized assistance from an outside panel of consultants, composed of experts in concrete technology and statistics, including J. F. Artuso, President, Construction Engineering, Inc.; T. J. Reading, private concrete engineering consultant; Dr. R. C. Mielenz, private consultant in reapplication of petrography; and Dr. A. W. Wortham, private consultant in statistics (the Consultants 1 E 1 (3b-2) I-
1 I k Panel). Copies of the resumes of these individuals are ( attached as Exhibit Nos. 14, 15, 16 and 17. The Consultants Panel has assisted the Task Force [ in designing the overall review program, and- is working { closely with Task Force members in implementing the program. In several important aspects of the program, { i.e., visual inspection and physical testing, Panel members are directly involved in the performance of , tests at the site. l { The E&P/B&R Task Force and its Consultants Panel are examining a representative sampling of concrete placenents in the Unit 1 and Unit 2 MEABs, the FHBs and the RCBs. With respect to the RCBs, which are the first category of structures under review, the Task ' [ Force and Consultants Panel are examining internal placements. In addition, they are reviewing the re-sults of previous E&P/B&R investigations of the RCB shells, which were completed shortly before the { issuance of the Show Cause Order, in order to determine [ whether further investigation of the shells is required. If it is determined that further examination is necessary, i
)
[ such examination will be conducted under special direction l of the consultants Panel. { In addition to the investigations noted above, a f list of unresolved concerns previously identified in
~
c l s (3b-3)
L [ [ NRC, HL&P and B&R audits has been compiled, and will be [ addressed either in the normal course of the' review or through special investigation. The schedule.for comple-tion of this review is indicated in Exhibit 13. The Task Force Review Program has been documented { in a Technical Reference' Document (TRD) entitled " Review b of Safety Related Concrete Structures Including Embedments" (TRD 2A700GP003). Each of the general areas of review ^ has been divided into more detailed and defined tasks { and, where required, forms and checklists have been developed to aid in data collection and review. The TRD b will be updated periodically to incorporate changes in and results of the program. b B. Preliminarv Findings __ , { The Task Force, with the direct assistance of the Consultants Panel, has completed 50% of the ultra-sonic testing of Unit 1 RCB and has found high strength concrete, with only one discrepancy which appears to be due to a surface condition. The discrepancy is being [ further investigated and is expected to be resolved t shortly. Identification of rebar cover and location of b face steel has been completed in two of the five Unit 1 RCB placements to be investigated and there was excellent { c'orrelation to design requirements. Sampling by coring, r L chipping and boring in Unit 1 RCB will be accomplished F 1 ~ (3b-4) _ - _ _ _ - I
L [ [ in the next two weeks. A Status Report by the Task { Force will be submitted to NRC I&E, Region IV by August 15, 1980. This Report will fully set out the status of E Task Force findings and' conclusions. Based on the extent of the review and analysis of safety-related concrete in the Unit 1 RCB, the Task [ Force and Consultants Panel members are of the preliminary opinion that the concrete in that structure is of satis- [ factory quality. (See Exhibit 18, (letter of July 26, 1980, from J. F. Artuso to B&R) { l Set forth below is a more detailed description of [ the Task Force review of safety-related concrete structures. C. Task Force Review _ _ _ _ .
- 1. Structures Reviewed - - - . . . -
{ The Task Force and Consultants Panel determined that the safety-related concrete work at STP could b effectively be evaluated by identifying and thoroughly examining a statistically-based sampling of all generic l categories of concrete placements. Categories of { placements located in both Unit 1 and Unit 2, in the RCBs, the MEABs and the FHBs are being examined. In each building, five generic placement types--thick slabs, thin slabs, thick walls, thin walls, and high lift placements--are being considered. [. (3b-5)
[ [ .
- 2. Method and Schedule of Examination
( 2.1 General _ As indicated in the attached schedule, the Task [ Force is proceeding with its examination of structures in four phases. { First, a thorough documentation review is being conducted to bring together all of the design [. and construction documentation for particular placements and to determine the final design configurations, as [ well as the completeness of the documentation packages. { In the second phase, a review'is being made to determine the "as built" configuration and to compare this to the ( "as designed" configuration, documented during the first phase of the review. Third, a visual inspection is [ being conducted by the Consultants Panel and Task [ Force, in order to determine whether there are potential structural defects and to identify those areas where follow-up testing is required. Fourth, the Consultants Panel is directing a testing program in which a variety of specialized tests are performed on plant structures. Each of these phases of the program are now underway, { and are expected to be completed in the time frames described herein. r' The review process is being conducted in sequence L for the three safety-related buildings. As noted above, the greater part of the review. effort to date L (3b-6)
L [ [ has been concentrated on the Unit 1 RCB. As the review ( of the RCBs for both Units is completed, the concentra-tion of review work will shift to the MEABs, and then to the FHBs. 1 2.2 Phase 1: Documentation Review
~
{ __ To assure that proper documentation has been ( performed, all test reports, batch plant records, pour cards, inspection reports, drawings, Design Change [ Notices (DCN), Field Requests for Engineering Action { (FREA), Nonconformance Reports (NCR), and Corrective Action Reports (CAR), which pertain to the selected b placements are being reviewed and evaluated as to their correctness and completeness. Test reports are being evaluated for the cemen,t, admixture, aggregates and water used, as well as slump, air content, compressive strength, unit weight and concrete temperature. Each report is being checked.for completeness, design compliance, and for proper signatures or initials. Batch plant records are being evaluated for completeness ( of record, proper signatures or initials, and compliance with applicable procedures. Pour cards are being checked for QC signatures, listing of NCRs, FREAs, p' DCNs, and drawings, and notations of other unsatis-L factory conditions which should have resulted in the issuance of an NCR. Preplacement, placement, and L r (3b-7) I
E [ curing inspection checklists are being reviewed for ( proper signatures, time span between preplacement inspection and the date of pour, and notations of other l [ unsatisfactory conditions which should have resulted in { the issuance of an NCR. Where available, punchlists are also being evaluated for proper signoff of each item. The "as-designed" condition is the configuration [ documented by the drawings and DCNs that were in effect { at the date of the placement, all FREAs pertaining to that placement, all NCRs submitted at any time concern-ing that placement, and any required work as a result of the NCRs. These documents are being evaluated to determine where every embedment, penetration, anchor [ bolt, construction joint, opening and dimension change should be located. Also defined by these documents are the dimensions and location of the actual placement. As of the date of this filing, the only documenta-tion review that has been ccmpleted is for Unit 1 RCB. ! ( Review is partially completed for the Unit 2 RCB and is scheduled to be finished in the next month. Based on its review to date, the Task Force has concluded.". hat documentation is complete, with minor { discrepancies. In those limited areas where discre-r L pancies exist, the Task Force is either providing for L s (3b-8)
I new documentation, or is verifying the placement through inspection or testing, as required. 2.3 Phase 2: As-Built Verification _ _. . The "as-built" inspection program consists of
- obtaining field measurements for
- placement location and dimensions (thickness, openings, plumbness, square-ness, size, and identification, if available). Once the "as-built" condition is documented, it will then be g compared to the "as-designed" condition and all dis-g crepancies will be identified.
j As of the date of this filing, the "as-built" condition of the five placements for the Unit 1 RCB has 5 been completed and the comparison to the "as-designed" condition is underway. No significant discrepancies have been found. 2.4 Phase 3: Visual Insuection _ I ~ The visual inspection is being performed by the special Consultants Panel and selected examiners from ! the Task Force and addresses the following areas: general appearance of the surface, the nature and j extent of cracking, . evidence of volume change, evidence of cement / aggregate reactions, secondary deposits on l l ~ surfaces (efflorescence, exudation, incrustation), secondary deposits in cracks or voids (efflorescence, I (3b-9)
[ leaching, incrustation), construction joint alignment, [ construction joint cleanliness, control joints (expan- - sion, contraction), the nature and extent of- deflections, the nature and extent of dislocations resulting in { joint movement, tilting, shearing or misalignment of structural elements, apparent effectiveness of curing, ( the extent and significance of surface characteristics, (such as scaling, spalling, peeling, popouts, pitting, E dusting, staining or discoloration, cold joints, pour { lines, corrosion of reinforcement, soft spots, sand streaks or pockets, honeycomb, air / water voids, segre-( gation or stratification), indication of inadequate consolidation in general, indications of adequate b consolidation behind embedments, the adequacy of repairs { based on soundness and appearance (tie holes, cosmetic, structural), satisfactory embedment of penetrations, based on appearance and sounding as applicable, dis-location or misalignment of embedded plates, satis-factory embedment of plates based on appearance and [ sounding as applicable, apparent consolidation surrounding anchor bolts, general appearance of seismic joints, evidence of grout leakage, adequacy of existing 7 repairs. L As a result of the above inspection, the Consultants Panel is to indicate potential areas on the selected l l ~ 1 4 (3b-10)
[ .. [ [ placement in which destructive tests (cores or probe [ holes) should be performed to verify the sonic test results. The cognizant design engineer is to review [ and approve the location or core holes with regard to { potential of cutting reinforcing steel and subsequent consequences thereof. The Consultants Panel is to also visually examine every core obtained to evaluate the quality of consolidation and uniformity of the concrete. [ The Consultants Panel is to direct the drilling of [ probe holes and, utilizing fiberoptics, visually examine the cleaned holes to evaluate the quality of consolidation. In addition to the visual examinatio.ns of the cores, selected cores are to be examined using petrographic and microscopial techniques. The Consultants Panel is [' to also address previous unresolved concerns and allega-tions by visually inspecting such areas and recommending specific tests where such methods would resolve specific concerns or allegations. - { As of the date of this filing, the visual inspec- [ tion has been completed for the five areas of_the Unit 1 RCB. The overall condition of the concrete was L judged by the Consultants Panel to be good with { only minor discrepancies noted. (See Exhibit 18) L ) - (3b-ll) - l _ _ _ _ _ _ - _ _ - - I
[ [ 2.5 Phase 4: Testing [ Testing is to include Ultrasonic Testing (Pulse Through Method), Petrographic Examination, Compressive Strength Tests, Unit Weight Evaluation, Pachomete*r for reinforcing evaluation and Windsor Probe for compressive strength indication and correlation with Ultrasonic [ Testing data. Each selected sample area is being tested by sonic methods on the smaller grid. The sonic correlation and reference standard are being developed on the sample area utilizing cores or bore holes where possible. The strength and uniformity as measured [ Cores and Windsor Probe, are being made on the selected sample areas. The rebar placement location and cover b are being made on the selected sample areas. { As of the h te of this filing, the testing has commenced in the Unit 1 RCB and is expected to be ( completed within the next two weeks. 2.6 Statistical Samoling Basis [ The statistical approach for the sampling utilized { in this evaluation is based on experimental design methodology. Concern in this evaluation is over homo-geneity between placements as well as within placements. Also of interest are individual placement characteristics and whether individual placements meet design criteria. b ~ (3b-12)
E { [ The size of the sample areas for each placement varies ( depending upon placement size. The sample areas are to be no greater than 100 square feet nor more than 30 [
. percent of the surface area o.f the placement. A minimum
{ of three random sample areas are being selected from each placement to assure measures are obtained of ( possible within-placement variation. This approach gives an overall capability for observing structural [ variation, generic variation and within-placement variation. Statistical tests of significance are to be { performed to address differences using a high confidence [ level (.95). Averages for all placements are being assessed and high confidence limits (.95) are to be [ established to give statistical assurance of overall { mean properties. Where necessary, individual placements are to be assessed to present valid statistics concerning the' j i capability of the placements in their performance relative to design intent. In this event, distribution-( free statistical methods will be used. Using these methods, a range of values is determined for a parti- [ cular design characteristic of interest. The range of values may vary depending upon the importance of the { characteristic. The values most likely to be con- [ [ - (3b-13)
I I sidered are .90 and .95 percentiles of the distribution. A .95 confidence level is to be used. In the event it becomes apparent that larger samples or more specialized methods are determined to be required, the study plan is to be cha6ged accordingly. l D. Review of Unresolved Concerns About Concrete Structures In the course of the review, the Task Force and Consultants Panel members have compiled a list of unresolved concerns previously identified in NRC, HL&P and B&R audits. As noted above, these individual items of concern are being factored in and addressed, where possible, during the review. Where in the judgment of the Task Force and Consultants Panel a particular item needs special investigation outside the scope of the j general review, such an investigation will be conducted, using the investigation review techniques discussed in C.2 above. Resolution of all outstanding unresolved issues is scheduled to be completed in accordance with the review schedules noted. E. Necessarv Repairs and Schedule for Completion. __ As of the date of this filing, no deficiencies requiring repair work have been identified. I intended that as the testing phase for each building is It is l completed, all repairs will be identified--including (3b-14)
[. [ repairs necessary due to destructive examination--and [ that a careful, controlled plan for repair will be established and implemented. [ F. Review and Upgrading of MAP /B&R Concrete Procedures _. ._ { To provide assurance that ongoing safety-related concrete work is meeting all requirements, HL&P and B&R ( have completed a review of all concrete placement and concrete inspection procedures and applicable training [ procedures, independent of the Special Task Force { review described above. Revised procedures are now in place, and retraining is being performed where necessary. [ This was done pursuant to a commitment to perform all reviews and implement all necessary procedural changes [ which ensure that continuing placement of non-complex { concrete is in compliance with all requirements. (See HL&P letter to Victor Stello, Jr., NRC, dated May 23, 1980 - Response to NRC Notice of Violation) l Accordingly, additional QC inspectors have been i added to assure that proper preplacement inspections [ are being conducted. Both construction and QC proce-dures have been revised to require formal preplacement and postplacement meetings which include discussion of placement method, sequence of activities, lift thickness and postplacement discussion of deviations including { [ l [ - (3b-15)
L- [ [ delays and required change of sequence. Procedures
-have been rewritten in simplified language, using a new format and which contains relevant information from
{ specifications, technical reference documents, codes, [ standards and regulatory documents. Consolidation refresher training is now required every 90 days for consolidation placement craft personnel. Any improved methods of placement or inspection which are identified in the postplacement meetings or ( in the Status Report of the Task Force will be incor-porated in further revisions to the procedures and [ training manuals. , f MS:06:C ( ( { { ( r L t (3b-16)
l e ar aunt I autv I ausui g 11 11111.H 111 MM i ll >=l l i I I-el l ! ! I. .I l i l I-H l l l H ! l i l !=W l i I Nel i l l Ha! 11 i HW l l ! Hal l l l lil l 111 l'H l l l I '
*gw l I
, i
% : i l
l ! ! 1 ! , I l l l j t, l .i I l l I co ., ;
. M10 tut.0 . i
. =u= l ! t
",z.,'.tf
. t. -w o..r. i i
,W."."',*....
i ' ~
-+n...a.u,,- _'s". '" tat' ve'...,-
..m .
y g i \ m l m,om-.o.-.-......., 1 l ')
, ""t%.- ..._.._
U .T gt l l 8
' I ,
o., . w ,x w. .mn ' !
, i i l to. l l l 1 {
*w -
. .. oo. .c m. .,..c. .4..-.~. . .
i , _ i i i w i ,. . f 1 . i co o .- . . i _ can,9 a g.e.e
- .s c ' O. . ,
g
. I
/
I I
! . t t' '
. I 1 l "E*Y '
l C k w m.t
.m......,~--....,.,z.m/
l ') ..,..%.".".,.o
... i .. . o - .o
; . 3 . .c.. .
g TT ~ T i i i 8
,....,..,cc.m.,,..1. '1 e. bl.**'m""..,,,
w . ., T ML t l? 'O ' O lm1 = l
.aw. . . . . .y. . . .'. - -"."-= y==: -,
<N ,
\ t.stJ!roog{Igt:'"
s : _ q, : - l '".
.. . . u.t crio., ,
~
I 8
!.l I
. i.
t I I B ; 8 l . l 4 + T t t 3 3 g I E.W.,4.& 5 g 1 P.O 05
. l
[ .n .co c. l i 8 I I I I i i I 3 e i {
..,.....EL.I.#A,.,Y,~, .
t__.,
~ . . - . . . - . .- . co c. ,
.c..
A t - ,- l i - I l i i i I ! _ i N. .!.i.l.!.M+.i l H.+.+Hnim-H..H i.iv.M.N.: !..p+._4+.: % H-mi-H.!,I.H. M14++.!+H++nH.Hs+H, .l.N.M.H4 A+H! RfAr l JUNE l JULY l AUGUST
,o,,, i.u o _
.t. teo s.O 1.senGatE55 m 8~'Y _q ru w.tv. _
w v f. ( -tanoev."
+
l.D. .S.T 30.Ct4.*f
. ws9s.e v.i.e f.o.u wsv eG g g .gpg(T ppg o . 1 o, x.
.O .D.o.o. fie < ttone
-_ ' __.____L__m- ____ ___ _ _-. - '- "'*r-
1980 r i sEPrEueEx l oct < st a movEveE4 oECEusta 0 I I I i== 11 I l=i i l i I H.! I I I WW I I i H4 i l l HW I I I I.i.I I 11 ! N I I i H411 I i-d i I I -
.I I I I l W l l 1 !="i i l I inW I i l b. lllI!*!.IllllabIIIIl-,4111IW I I
- I l
l I i i I' ! l i
! j i i.
i j , i EW EO a*. a*, i V 7 ! l
, [
4 f i [ I t.
; }
l e 1 l 1 i i I
' l s
i i I i w I e o,.e - .....As msu.,ott, 0 vi.. s eo.st?
- o. . .s e.u.st.Y. . s ou..st.Y,
,, ,, ,, i l
g..=em- /+ d so so so s" o 9i o . 13 #8 II I 'I mitt og O.DREPLErf ,, og ap. af ,I s9BFE- Cv ge. m C,e_asett?E
,ergeg[T,)se
- u. --
f asygCTIQIs u
- C.o.nsPLETE u C.oneptfTt u i
etyg 7 37,Q4
- i. i I i
'l s, 'e, i i
'em i,
.i il .
- g. * *G g. l O. O. "5'"
O. e' ;. i' s. il'. ,l el l al l i ia
! ., i, i .
- i. , i, i, ii .
is .. i, e. e* . LL :L 1. L LL L L. .1 y;
,,, i i
[i ii w;; !: 1T I! Tat,; l I Ti
"').",V': l Ts
",'91':i a:w;;' 1:
I 'TT r* y
, .,= n.
49 T
+ ..=
.n co a sq3
=
nay
.a. i
, = ,.. .=..%
"*u , v4.
Co.a.m
}
t i r y i v e i 8 1 i I e I g i g l'. l
. l l 1
, , i i p
..=,uma .
. .n m o, . m o, m o, l v eurio=s l
, e uao.ro.s . .u, =aurmas s case ..=.mueuro.s o, i .u, s = auro.: j
.40 CO8Keasus amo gtwstt **st 49 C0'uct mar s se D cosect auss 8e9 Conect mass I
l l l l l J l EXHIBIT 13 l 1 I f I .
! 1 *W+k=WH=i-i !*I+IMM4%+Hvi=i44-W++%!*H+H+%i4+ !eHH444-M+i- ..a!5M44H+W4-W44=im+1 1 M.M.H 4%i+H W-W-%-W.W . !>
l SEPTEMBER OCTOBER l Nov E M B E R I DECEMBER I ~,. =v e c. v o. = ev SOUTH TEX AS PROJECT ao, no. N _.3 t __._M :::c ctytEn
~ ' * "
ZZZ Z Z- Z
,,.,, g.2:p_
c mon < 7.= = h ,m _' @ SHOW CMJSE ORDER ITEM 3b
/
"CONCREXSTRUCTURE REVIEW" /
'= A- DETAL ACTION PLAN
/, " "l l- -
r..,. __ a
l . l
. EXHIBIT 14 EMPLOYMENT EXPERIENCE AND CDUCATION RESUME SOCIAL SECURITY I;UMEER (FIAHL: Artuso, Joseph F.
Laurel Mountain Park 200-20-2875 Laughlintown , Pa.15655 (- (412) . 238-2755 , TITLE~- . JOB DESCRIPT10l: F ROH TO (Detail Ucrk Performed) No. Yr. Mo.. Yr. E> resident Manago C.E.C. and 9 76
' Con.s truction Engineering perform consultations Cons ul tan ts also to Duquesne Light Co.
Ronsultant to'Duquasne QA Dept. on Quality Right Co. Quality Assuranca- Assurance and Site Depcrtment , Quality Control catters a EDUCATIQU Schools , Cc11cces , Training Coursos , (QA) etc. (General Education First) Degree Granted and Major Date li c . l[ School Employer and speciLocationfy or Title of Course Completed Mrs . Carnegic Mellon University B.S. Civil Engineering 1948 Hationci Council of . Level III Inspection 5/31/75
. Engineer Engiriocring Cxaminers . , . . . ,.
ENGII;EERIi;G REGISTRATION ST ATES A!!D CIT EXAlili;ATIONS D ISCli LI NC LICC;:S L UUMBEP.S l IRegisteredProfc:sioncl Engineer in the states of Pennsyl tani c, Chio , itew York , Marylcnd and Wect Virginia IRegi:tc. cod as Quality Control . Enginscr in state of California . l ,
!!EMB EP. SHIP It' PROFESSIGMAL SOCIETIES P ROF . ! IO"L'_ 50 C T ET E.9 U AT I g;t.LCT" !,TTJJJ, A.S.C.E. A.5.C.E. lask Cecia ttee of Inspection Accaci::
A.C.I. A. C. I . Cocui ttees 214, 30? and 311 A . S . T . !t . A.!!.C. I . R-45-3. 5 Structural Concre te & Stcci it. R . M . C . A . ecche r o f A.C. I .
* . Cou=i ttee 359 ( AS"E Soc. III, Div. 2) Cons tr*:ct' .
. Materials & Excc. ACI-ASME Comui ttee on Cencru.-
Pressure Components for Nuclear Servica I' PUCLICATIONS l
"Concretc Cans truc" I Contributino Editor - Section Handbcok" on Tesiing published & by Inspe: tionMill McGra'.
" ACI M:nu:1 of Concreto In:pcetion" Publicat.ic,n SP-2 l Mctder ACI Comai'.tce 311
( Page 2 PREVTOUS EXPCRIENCE DETAILS Joseph F. Artuso { 1948 - 1957 Various responsibilities in construction activities. [- -1957 ---1962 Application and Sales Engineering-Westinghouse ~ -- -- - - - Electric Corporation, Blairsville 14etals Plant, 11aterials flanufacturing Department, Blai rsville , Pa. { Application and Sales of special high strength and high temperature alloys and castings. 1962 - 1964 Assis tant l4anager Cement-Concretc Department - [ Pittsburgh Testing Laboratory, Pittsburgh, Pa. ~ Supervised tasting and inspection of concrete and
. building materials.
1964 - 1969 Manager Coment - Concrete Department - Pittsburgh --~ Testing Laboratory, Pittsburgh , Pa. Supervised [ testing of cement, concrete, aggregate masonry and inspection of concrete construction. This included supervision duties on two Nuclear Power Projects. [ 1969 - April, 1974 - Assistant to Vice President - Pittsburgh Testing Labora t.ory , Pi ttsburgh , Pa . Supervised Quality (_ Control on fluclear Power Plant. Co ns tructi on including testing and inspection of concretc, rein-forcing steel, soils and s tructural steel. Perfor:4 [ general supervisory dutics in the company, this --
-)
included supervisory duties on seven Nuclear Power Projects. b April, 1974 - to 197G Vice President - Pittsburgh Testing Laboratory,
. Pittsburgh, Pa. Quali ty Assurance lianager. P ri =a ry
[ responsibility covering all Pittsburgh Testing Laboratory nuclear powcr plant Testing and Inspection Projects. [ Jan., 197G to Sept. Director Site Quality Control Section - Responsible for the establishtunt and implementation of the Site Quality [.* 197G Control Progran for Duquesne Light Co. - Scaver Valley Power Station - Unit 2 (!!uclear) E r - L r [ _ _ _ _ _ _ _ _ _ _ _ _ _
EXHIBIT 15 [ April 1979 [ Professional Record of Thoac.s J. R== ding 3arn: July 5, 1915 { gtcation [ 35 in Civil En6 1neering from Chio University, 1936. Graduated with H16h-est Honor. MS (with major in Civil Engineering) from Massachusetts Institute of Technology, 1939. ( Additional courses in MIT Craduate School, 1940 4 1. Job Exterience (in Reverse Chrenolerical Order) [ Since retiring fren U.S. Arsy Corps of Engineers at end of 1977, has entered private practics as a Consulting Concrete En61neer. Twenty four years as Chief Faterials Engineer for the Missouri River Division of the Corps. Responsible for saterials aspects of multipuv se dams, pavements, 9 Win.gz and other st=uctures built in civil and military con-struction. Checked quality of construction in the field, includin6 adequacy of contractar quality control and Gov't. quality assurance. Made condition surveys of st=uctures in service. Principal emphasis was on concrete, but also dealt with other materials - steel, paint, masonry, plastics, rock, etc.(1953-77). Pour and one-half years as Materials Engineer en Corps Ft. Randall Project * ( in South Dakota - a large dam of concrete and earthfill const=uction. Respon-a1ble for inspection of a6gregate production and concrete operations. (1949-53). { Three years as head of Corps District Laboratory in ran== = City, Missouri. Laboratory included branches in soil mechanics, concrete and chemistry. (1946 4 9). . Two m as Civil Engineer for the McClcskey Company of Philadelphia, working on Verld War II concrete ship construction in Tamps, Flcrida. (1943-45). [ Three and one-half years as Research Engineer fer the Fortland'Cament ~ Assoc 2ation, working in the MIT T.4baratory. Investigated stralas, stresses and cracking in concrete walls frca drying, shrinkage anti temperature change. 3cth mods 1 and analytical studies were involved. (1939 4 3). Two m in field survey werk. (1936-38). Other ? efessienal Activities Fellow in ACI. Also,
- s. Member of the 3 car:i of Direction (1965-68).
[ - [ - - - - - - - - - - - -
{---- - 1 { b. Member of the Technical Activities Committee (1973-79), l which :una the tech 4-=1 affairs of the Institute.
- c. Chairman of Committee 506 which produced ACI and ANSI Standard ACI 5C6-66 on Shoterating, and publ*ahd a symposium on the subject.
{ --
-- d Nirman of Committee 359 which produced ACI and ANSI Standard ACI 309-72 on Consolidation of Concrete.
E e. Chairman of Committee 201 which published a Cuide to Durable L Concrete in the December, 1977 ACI Jour M- . f Past or pzhrsent member of several other tee %4-=1 committees.
- g. Recipient of the Disti36uished Service Award.
F h. Recipient of the Kennedy Award. Fellow in ASCE. Member or AS M.. Member of Committee C-1 on Cement and C-9 on Concrete A6 gregates. { Member U.S. Con 6ress en Iarge Dams. Registered Civil En61neer.
~
Author of several publications. 17squent speaker. Consultin Recent assig=sents (gscatassignnents of whichinare thestill United States, active) Canada, and Pacana. includes
- a. Providing sulfate resistant concrete for chemical plant in Tennessee.
r b. Speaking at advanced concrete course at U.S. Vatarways Experiment L Station ,
- c. Exper. witness for Cov't on a.centracter's claim.
1
- d. .ake
" condition survey of old Mississippi River Iack.
l e. Prspre sanual on concrete vibrators and operati.y precedures for a L. vibrater manufacturer.
- f. Consultant to centractor on pavement vibration :ssearch study L carried out jointly with State of Kansas.
Listed in Who's Vho in En61neering". _-. l
~
e
EXHISIT 16 [ , January 1, 1979 [- PROFESSIONAL BIOGRAPHY [ ( Dr. Richard C. Mielenz,. P.E. " Geologist and Petrographer Gates Mills, Ohio ( office: Route 1, Box 103, Brigham Road, Gates Mills, Ohio 44040 Telephone: (216) 423-3261 . Birth: December 18, 1913, Burlingame, California ( Elenentarv Education: Agassiz Grammar School, Horace Mann Junior High School, and Mission High School, San Francisco, California Collegiate Education: ( Marin Junior College, Kentfield, California - 1931-33, Degree of Associate of Arts, 1933 (Valedictorian) { University of California, Berkeley, California - 1934-36, Degree of Bachelor of Arts (A. S. ) in Geological Sciences, 1936 (Cum Laude) University of California, Berkeley, California, Degree of Doctor of Philosophy in Geological Sciences, 1939. Thesis: Geology of the Southeastern Part of San Senito l [ County, California l l Professional E=cloyment: [ 1939-41 Geologist in Training, Standard 011 Company, Taft, California F L Training and experience in oil field practice and operation. 1941-47 Petrographer, Engineering Laboratories, Bureau of (( Reclamation, U.S. Department of the Interior, Denver, Colorado. Application of petrography and geology to civil ! engineering, especially research and practice in testing and selection of concrete aggregates, soils and rock for L engineering purposes and causes fer deterioration of concrete in service. r L r
I ' 1947-50 Chief, Petrographic Laboratory, Engineering Laboratories, Bureau of Reclamation, U.S. Department of the Interior, Denver, Colorado. 4 Practice and supervision of application of petrog-raphy and geology to civil engineering problems and materials. I 1950-56 Assistant Chief, Chemical Engineering Branch, and Chief, Petrographic and Special Investigations Laboratory. I , Practice and supervision of application of petrog-raphy, geology, and chemical engineering to civil engi-neering problems and materials. 1956-64 Director of Research, Master Builders, Division of American Marietta Corporation (later Martin Marietta Corporation). Cleveland, Ohio. -- i Applied research and development on concrete , mortars, i and grouts and concrete-making materials, including practice
- and supervision of petrographic investigations.
I 1964-68 Vice President - Product Development, Master Builders,
- Division of Martin Marietta Corporation, Cleveland, Ohio.
E 1968-78 Vice President - Research and Development, Master Builders, Cleveland, Ohio. Applied research and development of new products
. . elated to concrete and concrete constructions.
1951- Private censultant to government and industry, with emphasis on petregraphy applied to durability of concrete, concrete-making materials, and rocks and soils for engineering purposes. Professional and Technical Societies: A=arican Concrete Institute (ACI) 4 Tellow President (1977-78) - Vice President (1975-77) Member (former Chairman), Cocaittee 114 - Research and Deve1 cement
!g[ Member, Co=hictee 212 - Admixtures for Concrece ;g , Member (for=er Chair =an) , Cc=mittee 116 - Glcssary of Terms in concrete Technolcgy.
American Society for Casting and Materials (AS*M) Te11cw
- I Vice Chairman, Cc=mittee C-9 on Concrete and Ccncrete Aggregates i
1
Chairman, Group I Sch'ccmmittee on Research Member, Executive Subcommittee i Former Chairman, Subcommittee C09.03.08 on Admixures for l Concrete Member, Subcommittee C09.01.04 on Editorial and Definitions Member, Subcommittee C09. 02.02, Chemical Reactions of l Aggregates in Concrete Member, Subcommittee C09.02.06, Petrography Applied to Concrete and Concrete Aggregates Member, Subcommittee C09.02.07, Pore Structure of Concrete and Concrete Aggregates Former ASTM Representative to RILEM (International Union of Testing and Research Laboratories for Materials and f Structures) l Transportation Research Scard l Member, Committee A2E02, Durability of Concrete in Service (Chemical Aspects) l I Geological Scciety of America Fellcw l Mineralogical Society of America . Life Fellcw National Society of Professional Engineers l Member ! Chio Society of Professional Engineers Member International Union of Testing and Research Laboratories for Materials and Structures (RILEM) Member I Member, Ccemittee 31-PC1, Perfor=ance Criteria for Materials Renors: l c 1948 Wason Medal for the most meritorious paper published in the >0 o Journal of the American Cencrete Institute. 1948 Sanford E. Thcmpson Award,.',merican Society for Testing and Materials for a paper entitled " Tests Used by the sureau of I Recla=ation for Identifying Reactive Concrete Aggregates." g 1951 Sanfer:i E. Thcmpson Award, ASTM, for a = aper entitled "Effect
~
g of Calcination on Natural Poccolans." l u _ _ _ _ . , _ _ . - , . _ , _ - , . ,- --,.m --- , - - - ,w,-
[ 4- [ 1955 Sanford E. Thompson Award, ASTM, for a paper entitled
" Petrographic Examination of Concrete Aggregate" 1959 Wason Medal for Cutstanding Research on Concrete, ACI
{ , 1964 second Stanton Walker Lacturer en the Material Sciences,
" Diagnosing Concrete Failures," University of Maryland,
[ Silver Spring, Maryland 1966 Frank E. Richart Award, ASTM, "for notable service to ASTM in the field of concrete and concrete aggregates" { 1973 Henry L. Kennedy Award, ACI, "in recognition of long and effective technical and administrative services to the [ Institute" 1974 Third Raymond I. Davis Lecturer, ACI, on " Moving the Spirit ( to R & D in the Concrete Industry" 1976 Award of Merit, ASTM, "for numerous contributions to the advancement of voluntary consensus standards for concrete [ and concrete aggregates, and for admixtures and additions ' to concrete, in the course of a long and distinguished , association with Co=mittee C-9" l 1977 Delmar L. Bicem Distinguished Service Award, ACI l Publications: Approximataly 50 papers and articles on durability of concrete in service, testing and selection of aggregates, rocks, and soils { for engineering purposes, testing and selection of admixtures for concrete, and encouragement of research and develo= ment in the
~
concrete industry. Perscnal
References:
Walter E. Price Consulting Engineer 3035-0 via Vista Laguna Hills, California [ 714-586-0577 Clyde E. Kesler ( a Professor of Civil Engineering University of Illinois o Champaign-Urbana, Illinois 61801 217-333-3394 Lewis E. Tuthill l r Concrete Engineering Consultant l L 4617 Cabana Way I Sacramenco, California 95822 916-457-9007
)
L F 1
l Donald R. Graham Supervising Materials Engineer Bechtel Corporation 50 Beale Street B San Francisco, California 94119 I 415-764-6343 Robert F. Adams l- Consulting Concreta Engineer 5971 Annrud Way
- Sacramento, California 95822 i 916-428-9121 1
Howard J Cohan, Chief I Division of General Research I Bureau of Reclamation g ! Engineering and Research Center E Buildtne 67, Denver reeeral Ceneer l P.O. Box 25007 I Denver, Colorado 80225
'3.03-234-3131 Milo's Polivka Professor of Civil Engineering I University of California l Davis Hall i
Berkeley, California 94720 415-642-3555
~~
James R. Wright Deputy Director l Institute for Applied Technology National Bureau of Standards Building 225, Rocm B-ll5 I Washington, D.C. 20234 l 1 301-921-3574 - Jchn F. McLaughlin Head, School of Civil Engineering I Purdue University I West Lafayette, Indiana 47907 317-494-8237 l Gary R. Mass I. Concrete and Materials Engineer l Har:a Engineering Ccmpany o
. 150 South Racker Drive
- Chicago, Illinois 60606 312-855-7080 I
l David C. Dressler, President Master Builders Division Martin Marietta Corporaticn Lee at Mayfield Cleveland, Ohio 44118 116-371-5000 l
l- EXHIBIT 17 i Biographical Data i Wartham, Albert W. I citizenship: U.S. Birthplace: Athens, Texas Prof. Interests: Management Industrial Engineering Management Science Statistics
. Quality Control Energy Development and conservation Education: ,
Ph. D., Mathematicil Statistics, Oklahoma State University, 1954 M.S., Mathematics, Oklahoma State University,1949 B.S ., Mathematics, East Texas State University,1947 Fvtrience: Industri'al consultant, EDS World Corporation 1977-I Consultant, Dresser Industries 1977-Consultant, Department of Energy 1977-g consultant, Aluminum Association, New York, 1975 j Board of Directors, College Station Savings Association, 1973 Owner, Wide-Worth Specialty Company, 1973 Consultant, Product Founders, Inc., 1972 1 Consultant, Department of the Army-- Project SCAMP, 1971-1972 Board of Directors, Bank of A&M, 1969-1971 Consultant, Ling Temco Vaught Electrosystems, Inc., 1970-1971 l Consultant, Professional Engineering & Management Consultants, ~Inc., 1970-1972 . g Consultant, Street, McNichols & Associates, Inc. , 1970-1972 g Consultant, Department of the Army-MICOM.1970
' Consultant , International Comput,er Graphics, Inc., 1969-1970 Consultant, MESCO, 1968 Consultant, DPD Manufacturing Company, 1968 I Consultant, Texas Hospital Association, Austin, 1966 Principal Investigator, over $1,000,000 in various grants and contacts consultant and President, General Sensors, Dallas, Texas, 1963-1964 Manager, Diode Department, Texas Instruments, Dallas, Texas 1962-1963 Manager,1962 Long Range P:.anning, Texas Instruments, Dallas, Texas,1961-1['
Manager,. Management Systems, Texas Instruments, Dallas, Texas 1960-1961
' Manager, Quality Assurance & Industrial Engineering, Texas Instruments, Dallas, Texas, 1958- 1960 I Chief, Operations Research, Texas Instru=ents, Dallas, Texas, 1957-1958 -
1 I
b [ north , m ere n.
~ *
( Supervisor, Weapcas System Evaluation Group, Ch'ance Vought Aircraft, Dallas, Texas, 1954-1957 Consultant, Morton Foods, John E. Mitchell Gin Co., TEPCCR, Texas Instruments, Inc. , 1951-1957 [ Senior Project Analytic.21 Engineer, Chance Vought Aircraft, Dallas, Texas, 1951-1953 Educational r Division Head, Energy Research Division, Texas Engineering Experiment L Station, Texas AGt University, 1975_1976 Professor, Deparencnt of Industrial Engineering, Texas MM University, 1972-1976 ( Professor and Head, Depart:nent of Industrial Engineering Texas A&M University, 1965-1972 , Graduate Faculty Member, Texas A6M Un'rersity, 1964-Present Associate Professor, Institute of Stat stics, Texas A&M University, [ 1964-1965 Adjunct Professor, Industrial Engineering Depart:nent, Southern Methodist University, 1959-1962 [ Instructor, Mathematics, nkinhe State University, 1953-1954 Research and Graduate Assistant, Statistics, nkl=hm State University, 1947-1951 Governmental ( Associate Akinhtrator for Industd.a1 Programs and Special Assistant for Conservatien and Environment, Federal Energy Administration, Washington, D. C., 1974-1975. Society Memberships: , Phi Kappa Phi , Sigma Xi Upsilon Pi Epsilon Alpha Sigma Eta [ Alpha Pi M2 Pi Mu Epsilon . Society of Logistics Engineers
- American Society of Quality Control-American Mathematical Association P American Statistical Association .
[' American Society for Engineering Education - American Institute of Industrial Engineers . Electronics Industries Association E American Ordinance Association I L F L r .
O I l Wortham, Albert E l Honors, Awards, Listings, and Patents: l Hamble Oil 5 Refining Ccmpany Honor Lecturer,1963 Chosen. as one of Top 40 Young Men of the South by University and Industrial Leaders of the South,1961 Lifetime member, Board of Govemors, Cklahoma State University "American Men of Science," 1967 ,
"Who's Who in the South 4 Southwest," 1967-1968 Elected Fellow in the American Society for quality Control l
i PInfessional Engineer -- State of Texas I Quality Engineer Reliability Engineer l Committee Memberships and Offices: Professional Societies l Shewhart Award Cemittee, 1969-1973, Chaiman American Society for Quality Control: Director, Dallas-Ft. Worth Section, 1959-1960; Chairman, 1957-1958; Regicnal Director, g 1959-1960; National Executive Director, 1960-1961; Naticnal Treasurer, 1962-1963; National Executive Secretary, 1961-1962; l National Vice President,1963 3 American Management Association Meeting on Planning, Mexico City, 5 Principal Speaker arai Co-chaiman, April,1968 l EDUCD4, Institutional Representative and Board Member,1968 American Statistical Association, Nor-J1 east Texas Section, President l I and Organizer
- l American Statistical Association, Regional Director l Industrial Development Research Council, Board of Director l American Institute of Industrial Engineers,' Co-chaiman, Prcu m, 1969 National Convention Electronic Industries Associatien, Maintainability and Educatien I
I Cemittee Inter-Institutional Pregram Planning Grcup for Technology, Scuthwest Educatienal Develcpment Laboratorf, Austin, Texas, 1968-1971 h Ccmputer Cemittee, Southem Regional Educaricnal Board Member, 5 Legislative Cemittee en Data Precessing, State of Texas,1969-l 1972 American Institute of Industrial Engineers, Editorial 3 card Member, Ia 1 ' 1968-1972 American Statistical Associatien, Applied Science and Engineering Comittee ! Texas ASM Universirr Systems Engineering Ccmittee, College of Engineering l Carriculum Cemittee, Gra@uste College Sel! Study Cccittce
g'. i Wortham, Albert W. -
.MA=ic Contributions:
Frca 1963 to present, successfully directed research efforts of over 50 Ph.D. students and over 100 master's students. (Chaiman of their graduate ceumittee.)
- I Frca 1963 to present, developed over 20 courses of graduate and under-graduate level in statistics, quality centrol and industrial 4
f engineering. j Frca 1963 to present, developed two Ph.D. programs and one undergraduate
- Program.
I l 4 I l 4 I 4 I ~I I I I:, I I I -4
l [ " " *
- Construction Edgineering CEC
[ Consultants Inc. quahtg wnhol'anguuming Sox 241, 0augl10nhown, @a. 15635, 412 - 238-2755 [ July 25,1980 [ Mr. J. L. Haw.ks Chairman ~ Show Cause Item 311 Brown & Root, Inc. [ P.O. Box 3 Houston, Texas 77001 ( Re: Inspection and Testing for Show Cause Item 3b South Texas Nuclear Power Plant {
Dear Sir:
This represents a progress summary report of the visual inspection and testing for the Show Cause Item 3b, conducted [ to date. The Consultants, T. J. Reading and myself, completed the [ visual inspection of the five generic placements in Unit 1 Containm.mt and have both developed the evaluation given herein. [ The visual inspection revealed that all of these concrete , placements were sound and properly consolidated and do ( not require any structural repairs. The " check list" rating was between a good and excellent for all five placements. One side of two placements had been coated and therefore [ were manually sounded to determine structural integrity. This soundness was confirmsd by Sonic Tests conducted to date. l The documentation for these placements were reviewed. Only one NCR applied to the visual inspection. This was a free fall condition which exceeded the specification limits. L, The reported location of the free fall was examined visually
, and there were no signs of segregation or improper consoli-J, dation.
L I L O i W e o
2 of 2 l Re: Inspection and Testing for Show Cause Item 3b South Texas Nuclear Power Plant The sonic testing (used to determine internal soundness) and Magnetic Device Testing (used to locate major face rebars) of the five placements is about 40 per cent complete. These test results, conducted to date, indicate that there are. no internal honeycombs or voids and the major re-inforce-( ment conforms to the drawings. A formal report will be issued upon completion of all testing . l and inspection. i Sincerely, f i
. lY J. ?. Artuso
$3w O' PRESIDENT u-I l -
l l 1 I l B 1 lJ l
, cc: T. J. R eading I
I -
[ t [ RESPONSE TO ITEM (4) ( Order: The licensee shall cause the Brown and Root, Incor-porated brochure titled, " Implementation of the Brown and Root Quality Assurance Program at the South Texas Project Jobsite," which was widely distributed to site personnel and the subject of seminars on January 4, 1980, rescinded and ( the associated video tape to be destroyed or revised. Further, the licensee shall cause the republication of a new QA Program brochure which has been approved by the licensee { which reflects the fundamental philosophies of 10 CFR Part 50, Appendix B, and conduct new seminars with Construction and QC personnel on the fundamental philosophies and standards of the licensee's QA Program with emphasis on the roles [ played by the respective personnel and the underlying purpose ( of the Program. Response: l [ l The referenced brochure has been rescinded and is being { replaced with a new QA Program brochure approved by HL&P that reflects the fundamental philosophy of 10 CFR Part 50, [a Appendix B. The video tape associated with the January 4, 1980 seminars has been removed from the Project Site and will not be shown to Construction or QC personnel as a [ training aide. New seminars for Construction and QC personnel l r L r
%-]L3 _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
L . b [ r' on the objectives and standards of the E&P and B&R QA L Programs as they relate to the South Texas Project will be ( commenced promptly. The brochure and the seminars emphasize the roles played by the Construction and QC personnel and the underlying purpose of the QA Program. A copy of the [ text of the new brochure is attached as Exhibit 19. 1 E E E E 4 4 L r u r L ~ ! _~
b [ [ { EXHIBIT 19 [ TsE SOUTH TEXAS PROJECT QUALITY ASSURANCE PROGRAM A. INTRODUCTION This document describes the purpose of Brown & Root's Quality Assurance program for the South Texas Project (STP) and your role and responsibility as a part of that program, and states Brown & Root's management commitment to a strong and independent quality assurance function. { The Quality Assurance program is an essential part of the design and construction of the plant. The plant is designed to be in compliance with all applicable NRC regulations and industry codes and standards. The role ( of the QA/QC program is to make sure that the plant is constructed in accordance with that design. a Q The implementation of the QA/QC program involves a significant amount of inspection and supporting documenta-tion. This is necessary to fully support NRC require-F L ments to ensure the health and safety of the public is F L h ._
l .. [ ( protected. In order to verify that the plant is con-structed with the required quality, there are many mandatory inspection points and procedural controls to assure that the design is being met. These activities must be documented in order to provide objective evidence that the quality requirements are achieved. ( B. INDEPENDENCE OF QA/QC QA/QC activities must be performed objectively without regard to the pressures of cost and schedule. B&R has established its organization in such a way that QA/QC is entirely independent from the Construction, L Engineering and Project Management organizations. ( QA/QC reports directly to the Group Vice President who is responsible for the entire Power Group. It is vitally important that each and every member of the QA/QC organization realize that he is required to perform his job in the field with absolute independ-( ence from all other organizations on the site. QA/QC personnel must resist all pressures to compromise your responsibilities to assure the quality of the work on 4 this plant. There must be no question in your minds that,.in the performance of your duties, you will be I' L fully and fairly supported by your supervisors and all levels of Brown & Root QA/QC management. L e (A-2) .
[ [ C. REGULATORY FRAMEWORK AND E&P'S RESPONSIBILITY The Nuclear Regulatory Commission (NRC) is responsible { by federal law for reviewing, inspecting, and approving the design, construction, and operation of nuclear [ power plants. In the case of STP, HL&P is directly responsible to the NRC for nuclear safety. [ HL&P can be fined or denied a license because of fail-ure to comply with regulatory requirements. Addition-ally, E&P must promptly report to the NRC anything that could affect safety. D. BROWN & ROOT'S RESPONSIBILITY B&R is the architect-engineer and constructor. [ B&R is responsible to E&P for designing and building the STP in accordance with NRC requirements and project [ quality objectives. E&P and B&R have established a { Quality Assurance program to assure that these objectives and requirements are met. Each of us has an important role to play in this program but none is more crucial than the QA/QC function. Although there is a separate, independent QA/QC organization for the Project, we are [a all part of the quality program--working together to
? assure that the objective of a safe and reliable nuclear power plant is achieved.
F l E u (A-3) _ _ . _
[ E. ROLES OF ENGINEERING AND CONSTRUCTION STP is being designed by the B&R engineers to be { in full compliance with all applicable codes, standards, and regulatory requirements. The full burden of respon-( sibility for the adequacy of the plant design erawings and specifications rests with Engineering. Engineering must do its job in accordance with quality procedures which ensure that these objectives are met. Everyone on the Project has the responsibility for building the STP in conformance with the design specified by Engineering. All of us must be dedicated to perform-ing our work correctly the first time. Major construction ( activities require careful, detailed planning in advance of performing the work to assure that adequate resources
, of equipment, material and properly trained manpower
{ are available. Part of this proper planning of construc-tion activities is providing the time necessary for QC l personnel to accomplish their inspection and documenta- l tion activities in an orderly manner. F. ROLE OF QUALITY ASSURANCE
, The purpose of quality assurance is to assure that , all work on STP meets regulatory requirements as repre-sented in drawings and specifications approved and l
I (A-4) . _______ - - - - - -. J
[ [ released by Engineering. Quality assurance involves all of us in performing "those planned and systematic actions necessary to provide adequate confidence that a structure, system or component will perform satisfac-torily in service" (extracted from the NRC Regulations on Quality Assurance). In short, Quality Assurance places a responsibility on everyone to follow the strict letter of procedures and instructions. Quality Assurance personnel, in determining the acceptability of work and structures, must check the work performed against the design documents, specifications, and [' procedures strictly as written. This is a critically { important function. It is accomplished by Quality Control inspectors who witness the work as it is per-formed, and document and follow through on the results of their inspections. { QA/QC personnel verify that the work is completed ( l in compliance with the approved design and procedures by conducting their reviews at planned inspection points in accordance with pre-approved checklists. Any deviations noted are reported in writing. When a
, deviation is noted, it may be necessary that the work ,
)
in question be stopped until the nonconformance is p resolved. In such a case, Quality control inspectors L have the authority to stop work. E u ~ (A-5)
L . [ [ If a difference of opinion arises between Con-struction and Quality control personnel concerning the acceptability of any work, individuals are expected to conduct themselves in a professional manner and to ( refer unresolved matters to successively higher levels of management for resolution.. Until such matters are resolved, the QC inspector has full authority to stop work on the item in question. Heated exchanges, threats { of violence or other unprofessional behavior have no ( place on this job and will not be tolerated. Attached is a procedure to be followed in resolving differences [ between Construction and QA/QC personnel in an orderly { way. G. DEVIATIONS FROM DESIGN Because craftsmen and inspectors are not involved in establishing design, they are not allowed to deviate from design requirements specified by Engineering no l ( matter how minor the deviation may seem. All require-l ments must be observed with equal care. Requirements can be waived or changed only by design engineering personnel. All work on a nuclear plant must be in ( strict accordance with the approved engineerin'g design. L Requests for changes in design to meet constructability
~
p problems, must be resolved with Engineering before work L is undertaken. F * (A-6)
k .. t H. REPORTING UNSATISFACTORY WORK Adherence to design requirements is your first and foremost obligation. If, however, you feel that defects in workmanship or materials are not being properly ( handled through normal operation of the QA/QC program, including discussions with your supervisors, you have ( an obligation to directly contact any of the following persons and personally express your concerns: George Oprea, Executive Vice President, HL&P - (713) 228-1763 Steve Grote, Senior Vice President, B&R - (713) 676-3903 Shannon Phillips, Resident NRC Inspector - (713) 228-9211 Karl Seyfrit, District Director, Region IV - { (817) 334-3452 I.
SUMMARY
AND CONCLUSION In summary, we would emphasize the following vital points.
- 1. HL&P and B&R have an overriding responsibility for ensuring that the plant is constructed in accordance
[ with the design and applicable government regula-tions.
. I
b ..
- 2. QA/QC is an important element in ensuring that
[ this facility meets the design requirements.
- 3. QA/QC activities are to be conducted regardless of cost and schedule considerations.
( 4. Violence or intimidation will not be tolerated.
- 5. Anyone who feels that the HL&P or the B&R Quality Assurance system has failed to identify defective materials or workmanship has a duty to report his concern to his management or the NRC.
( The management of HL&P and B&R are committed to building a safe and reliable nuclear power plant. The [ key to meeting this target is a force of dedicated { people operating in a professional, business-like manner. We sincerely ask for, and expect, your coopera-tion and personal dedication to meeting our quality objectives. , [. L [ [..4 P9 r L L P ( A-8 )'
{ r E E TEXT OF E BROWN & ROOT, INC. SOUTH TEXAS PROJECT PROCEDURE FOR RESOLVING DISPUTES L BETWEEN [ CONSTRUCTION AND QA/QC PERSONNEL ' i E i i E Lc 4 E u [ ( A-9)
I . I 1.0 PURPOSE The purpose of this procedure is to state Brown & Root I policy regarding the implementation of the South Texas ' l Project QA Programs, and to define the method for resolving disputes between Brown & Root Construction and QA/QC personnel. I 2.0 SCOPE The scope applies to the resolution of differences of opinion on technical or procedural requirements that cannot be resolved by the Construction and QA/QC personnel directly involved. I 3.0 DISTRIBUTION Distribution shall include:
- 1. Project General Manager
- 2. Engineering Project Manager
- 3. Construction Project Manager
- 4. Project Controls Manager i
- 5. Project Materials Manager
- 6. Project QA Manager I ,'*
Other copies shall be distributed, as required, in I order to assure complete compliance with this document. I (A-10 ) -
E g 4.0 PROCEDURE 4.1 Policy I I Brown & Root is dedicated to furnishing high quality, reli-able plants and services. All work shall comply with applic-able design documentation and good construction practices. Ordinarily a rejection of construction work by a QC inspector should be immediately accepted and the work corrected immediately. In cases where genuine and substantial differences of opinion arise and'the matter cannot be easily and speedily resolved at the working level, extended arguments should be avoided by prompt referral of the matter for resolution by higher QA/QC authority. I To implement this policy, the following procedure has been adopted. To be fully effective, this program must be understood, accepted and fully implemented by each employee. Therefore, all supervisors in the Engineering, Construction, and QA/QC organizations shall cooperate to assure complete compliance. 4.2. Procedure Details If differences of opinion on technical or procedural requirements between a Construction supervisor and a QC ( A-ll)
E .. t [ l inspector cannot be speedily resolved between them at [ the working level, the decision of the QC inspector 1 { shall prevail subject to the following procedure:
- 1. If the Construction supervisor wishes a review, he
( shall contact his own direct supervisor who shall in turn contact his counterpart supervisor in the QA/QC organization. The decision of which inter- { pretation is correct will be made by the QC super-visor in consultation with the construction - supervisory personnel. The QC supervisor will utilize whatever technical assistance he deems necessary to supplement his own knowledge in [ making this decision. b The QC supervisor's decision and the justification { will be documented on the appropriate report, and the QC inspector will be furnished a copy thereof. b Other involved parties will be given a copy if p requested. L [ 2. If there is still disagreement, the differences
, will be referred immediately to the highest level i
of Brown & Root QA/QC supervision then present at L the site for review and final decision and docu-mented, as provided above. E E (A-12)
E .. .. [ [ The decision of the QC inspector shall be complied with b by the' Construction organization unless that decision is changed through the foregoing procedure. [ Differences of opinion between Brown & Root Construction and Brown & Root QA/QC personnel on technical or procedural requirements are to be resolved promptly and in a businesslike manner. Violence, threats of violence, or harassment by any Brown & Root employee of any other [ Brown & Root employee will not be tolerated. An offended employee should bring such conduct to the attention of b his own immediate supervisor. All such complaints { shall be reviewed immediately by the Brow.2 & Root Project Management for proper action which may include termination of employment of the offending employee. This is a normal function of the "Open-Door Policy" which allows any employee to bring any job related ( problems to the attention of his successive supervisors and ultimately to company officers without fear of retaliation or intimidation. a
5.0 REFERENCES
L c None L [ MS:06:D (A-13 )
I I RESPONSE TO ITEM (5) ll Order: The licensee shall define more clearly the stop work authority, temporary or otherwise, including implementation of the stop work authority.
Response
A. The New Systems for Ston Work Authority Both E&P and B&R have more clearly defined the l stop work authority for STP. STP QA program documents identify the following individuals as having authority to stop work not being performed in accordance with applicable requirements: for E&P: the Manager, STP QA; Project QA Super-visors; and QA/QC Discipline Personnel for B&R: the QA Manager; the Project QA Manager and the QA/QC Engineers; Supervisors and Inspec-tors. A general description of the stop work authority follows. A.1. E&P Stop Work Orders The E&P Discipline Project QA Supervisors (PQAS) have the responsibility to assure that Stop Work Order authority is implemented for STP site activities. The
, PQAS can stop work by notifying the responsible organi-zation in writing (i.e., B&R Construction or appropriate l representatives of any other affecred contractor or vendor).
I (5-1)
E. [ [ Upon discovery of nonconforming conditions, HL&P Discipline QA/QC personnel are responsible for immediate { oral notification of the nearest cognizant QA/QC person or the supervisor of the organization performing the ( work. If the identified process is halted immediately [ and the condition resolved to the satisfaction of the { person calling attention to the problem, no further action is required except decrmentation in accordance b with site discrepancy administration procedures. If the process is not immediately halted or the condition is not resolved, the person identifying the problem is ( required to impose an immediate Emergency Stop Work Order (ESWO) by orally informing the cognizant QA/QC [ person or the supervisor of the organization performing { the work. The person identifying the problem shall also immediately report the ESWO to his PQAS. The PQAS [. have several alternative courses of action, including but not limited to, issuance of a written Stop Work Order (SWO); rescission of the ESWO in writing with (, 4 justification; or the initiation of maetings with upper
, management to discuss rectifying the discrepancy. All actions taken by the PQAS shall be documented.
[ . [ (5-2)
r b Written SWO's issued by HL&P will describe the [ , finding (s), the date and time the finding (s) were made, the requirement violated and the scope of the SWO. Each SWO will be numbered. The SWO will require from ( the responsible organization's QA management a written response, including an explanation as to the cause of [ the cited condition and the identification of a schedule [ for resolution of the problem. Upon receipt of an HL&P SWO, the organization performing the work shall take the necessary steps to stop work. A.2. B&R Stop Work Orders _ QC Inspectors have authority to stop work. B&R ( revised procedures provide that nonconformances identi-fied by B&R QC Inspectors shall be documented in [ Inspection Reports and in Nonconformance Reports (NCRs) { .(see response to order to Show cause Item (6), below). When issuing an NCR, and in other appropriate situations, a QC Inspector also applies a hold tag, as required. r The NCR prohibits continuation or commencement of the L designated activity until the NCR is dispositioned and ( the hold tag removed. O In some circumstances a formal SWO may be necessary. A SWO would have a broader scope than a hold, affecting F L a category of work rather than a limited construction activity. If a SWO appears appropriate, the cognizant I L (5-3)
[ ! [ QA/QC personnel shall submit written notification of the deficiencies to the B&R Project QA Manager. If the { Project QA Manager decides a stop work order is required, he shall immediately orally notify the supervisor of [ the organization performing the work and the HL&P STP QA Manager. [ If the Project QA Manager determines that a SWO is { required he shall complete and transmit a "Suop Work Notice" to the organization performing the. Work. A [ duplicate copy shall be signed, dated and returned to B&R Project QA Manager by the supervisor of the organ-ization performing the work, thereby acknowledging [ receipt and verifying that the work has been stopped. If the Project QA Manager determines that an SWO is not [ required, the QA/QC personnel who reported the condition { and the cognizant construction supervisor shall be so notified. b Authorization to resume work affected by a SWO may only be given by the B&R Project QA Manager when all l responses, corrective actions, recurrence controls and [a ' other requirements have been satisfactorily responded to and have been determined to be acceptable by the I' HL&P Manager, STP QA. Written approval of the EL&P (5-4) _ _ _ _ _ _ _ _ _ _ _ - _ .
[ [ Manager, STP QA is a prerequisite for issuance of a total or partial release by the organization performing the work. ! b As a result of corporate audits of the B&R QA [ Program, audit deficiencies of a sufficiently serious nature may warrant the issuance of a SWO. In such b cases, the SWO will be issued by the B&R Power Group QA - { Manager. Lifting of the SWO by the B&R Power Group QA Manager is subject to the same condition as those noted [ above. B. Implementation E The revised HL&P and B&R procedures will be issued { for use by August 15, 1980. The stop work authority of QC Inspectors is being emphasized in training of Project personnel. E [ [ E.4 E n L [ (5-5)
L [ [ RESPONSE TO ITEM (6) [ . order: The licensee shall develop and implement a more [ effective system to provide for the identification and [ correction of the root causes of the nonconformances which occur. [ Response:
Introduction:
The process of identifying and correcting the causes of nonconformances involves three separate elements: ( documenting nonconformances, analyzing the documented noncon-formances to identify underlying causes, and correcting the [ causes identified. The discussion below deals separately { with each of the three elements. A. Identifving and Documenting Nonconformances
- 1. Background Under the procedures in effect at the time of the NRC investigation, Quality Control (QC) Inspectors
[ recorded inspection results on one of a variety of different forms. When nonconformances were found in a final inspection, the QC Inspector recorded uhat fact in a draft Nonconformance Report (NCR), which was c submitted to his or her Lead QC Inspector. From the r' L . L _. L i F (6-1)
L [ [ { Lead QC Inspector, the draft NCR was passed succes-sively to the QC Supervisor, the Quality Assurance (QA) b Engineer and the QA NCR Supervisor. After the QA NCR Supervisor prepared the final [ typed NCR, it was successively routed through a number [ of concerned organizations for review and approval of the disposition provided by the discipline engineer. The NCR, with the disposition indicated, was then routed back through a number of offices for information purposes before Construction received the form and [ corrected the nonconformance. The NRC Inspection Report called for improvements in the NCR System. b These changes are described below. { 2. The New Procedure for Recorting Nonconformances (a) Inspection Planning b Quality Engineering (QE) will participate in construction planning and will determine inspection hold points for work activities. For each inspec- [ tion hold point QE will determine the inspection characteristics required, and those inspection bl characteristics will be recorded on preprinted {o Inspection Report (IR) forms (discussad below), to be used by Quality control (QC) inspectors in b their planned inspections. When witnessing work _ _ _ - _ nD ^"
L [ [ in process prior to an inspection hold point QC' [ Inspectors shall identify to construction con- { ditions which, if allowed to remain would not conform to design. Such conditions which cannot b be reworked to design configuration will be deemed a nonconformance at the. time identified. Conditions [ which do not conform to design that an inspector { finds at the inspection hold point will also be deemed nonconfcImances. (b) Inspection Recorts QC inspectors will be required to record the l results of all planned inspections and reinspec-tions on an IR. This form will be a permanent QA record. It will be numbered and controlled by the l QC Inspector and will identify whether an inspected { item is considered to be satisfactory or unsatis-factory. The IR will track all items found in planned inspections to be unsatisfactory, from the time of initial identification to the time the items are satisfactorily resolved. The form will, [, when applicable, provide for recording of rein-spections, nonconformance report numbers, and temporary waiver request numbers. { When a planned inspection for acceptance of work is being conducted, all checklist items noted r L r I ' (6-3)
[ , b on the Inspection Report will be verified as "S" (satisfactory), "U" (unsatisfactory), or "N/A" { (not applicable). The QC Inspectors will promptly notify the Construction Foreman or General Foreman [ of items recorded as "U" and will initiate a Nonconformance Report (NCR). If a need to depart [ from existing design requirements is identified in { the planning stage or discovered while work is in process, but prior to reaching a planned inspec- [ tion point for acceptance of work, a Field Change Request (FCR) will be prepared for submittal to Engineering. (The FCR program is described in the response to item 7 below). An FCR will not be prepared to seek approval for use of installed equipment or materials that do not meet design requirements. { (c) Nonconformance Reports b During planned inspections, all items or conditions found to be out of conformance with [ design documents will be marked as " unsatisfactory" [ on the IR, and will also be identified and docu-mented on an NCR. The NCR is a numbered and controlled form that will be initiated by the QC r L Inspector and acknowledged by the signature of the [ - (6-4)
[. .. Construction Foreman or General Foreman. Where I appropriate, hold tags or other work constraints { will be applied by the QC Inspector at the time the NCR is issued. Nonconformance reports are [ also generated at vendor facilities and will be processed in a procedure similar to the procedure ( for site generated NCRs described below. { If nonconforming items or conditions can be reworked to original design configuration or brought into compliance through a " standard repair procedure", the NCR will be dispositioned by the Lead QC Inspector and the Construction General Foreman. Once the disposition is complete and approved, the QC Inspector will remove the hold [ tags and work may proceed. The QC Inspector will record on the IR the fact that the NCR has been satisfied. NCR's falling into this category will I be forwarded to the cognizant Quality Engineer for review, written approval, and record retention. Since no design evaluation is required, it will ( not be necessary to include these NCR's in the Material Review Board process discussed below. If the item will not or cannot be reworked to p the "as-designed" configuration, the NCR will be t submitted to QE for review. If it is determined I L (6-5) _ - _ _ _
I I that the NCR is not v alid (i . e . , the QC Inspector misinterpreted the requirement), the NCR will be dispositioned, and explanatory comments noted in l the justification section of the form. If it is l determined that the NCR can be dispositioned by rework or a " standard repair procedure", neither i of which requires further design evaluation, that j disposition will be noted on the form. In either case the form will be returned so that any needed
~
rework or standard repairs can be completed and the QC Inspector can record on the IR that the conditien has become satisfactory. It is expected that the procedures of the revised nonconformance system described above will result in a resolution of most nonconforming items through an orderly interaction of QC, Construction, and QE. (d) Material Review Board Any NCR requiring design evaluation will be forwarded by QE to a Materials Review Board (MRB). The MRB will be an on-site committee consisting of 3 ," a Senior Representative from B&R Project General Management (PGM), QA, Design Engineering, and Construction. An Authorized Nuclear Inspector I I (6-6)
E l [ - (ANI) and representatives from Westinghouse (NSSS), Purchasing, and Materials Control will be on call as required by the MRB. { The MRB will be responsible for providing ( dispositions to all NCR's requiring design evalua-tien. The MRB is not a committee that acts by a majority; the concurrence of each member is required for disposition of an NCR. The MRB will consider the potential reportability of each NCR and refer to the Incident Review Committee those potentially reportable. The MRB members will prepare the proposed [ disposition based on consultation with their respective organizations. When the MRB members concur on the disposition and'any required Design { Change Notice (DCN) has been approved, each member signs the NCR. When necessary, on-call members ( will be consulted before accepting a proposed disposition. L Any nonconformance involving ASME codes will I L* be resolved by the ANI and the MRB. Fonconformance Reports written against Westinghouse (NSSS) equipment I* L will be assigned to the Westinghouse on-call MRB r member for resolution. After the disposition has L _. (6-7) _ _ _ _ - _ _ _ _ _ _
E [ , C ~ been entered on the NCR and approved by Westinghouse, [ the B&R MRB members review and approve the NCR. When the MRB review has been completed, the E signed NCR, with disposition noted, will be sent { to Construction for implementation and to QC for inspection.
- 2. Implementation The necessary procedures will be issued in l September, 1980. An attempt will be made to expedite required review by the Authorized Nuclear Inspector of the necessary revisions to the STP QA Manual so that E
the new procedures can be implemented for ASME work. { B. Trend Analysis
- 1. Background b Trend analysis is a systematic review of noncon-formance experience to prevent future nonconformance by
[ identifying and eliminating underlying causes of past [ incidents. Prior to February 1980, the trend analysis function at STP was an informal process undertaken by various members of Project Management. Results were reflected primarily in the corrective action taken. o The formal trend analysis that was performed analyzed a r' L portion of the STP inspection reports, Nonconformance Reports, and selected Field Requests for Engineering l Action (FREAs). These data were not normalized. The r i r - (6-8)
i identification of a trend was based on evaluation of I the significance of the absolute number of incidents in I a given category of activity. g 2. The New Trend Analysis Prograt f A revised and upgraded program to identify repeti-tive " trends" in nonconformances is being instituted. The trend analysis program will serve as a reliable I method for collect ng data, an effective means of reperting the data, and a vehicle for instituting corrective action when adverse trends are identified. t A new Data Analysis Group (DAG), comprised of quality systems engineers within B&R QA, will be responsible for identifying the methods to be used to collect data, the ways to categorize and monitor deficient conditions by the use of quality indicators, data normalization and graphic representation, and the methods of reporting this information to management. Formal procedures will require the collection of data from all QA records recording nonconforming d:enditions. To implerent this part of the system, a new uniform coding system is being developed under which all those charged with collecting data for trending will be trained in the use of the system to assure uniform I application. At a minimum, standardized codes will be 'I I (6-9) l
[ [ developed for the following categories: building or [ area, activity, failure type and time interval. { Procedures will define the list of documents that will be trended. Responsibility will be assigned to - - [ specific B&R organizations for review of each type of document, collection of data and submission to DAG. b Examples of documents included in the list are: Non-conformance Reports; Corrective Action Requests (CARS) (discussed below), Vendor Surveillance Reports; and Stop Work Orders (discussed in the response to Item I (5)). DAG will be responsible for reporting the results of its analyses to B&R QE. QE will review suspect [ areas to determine whether the incidents that make up a trend have a common cause. If a common cause is identi- [ fied, QE will issue a CAR for recurrence control. Once { a corrective action is undertaken, QE will have the responsibility to follow up and assure that the correc-tive action is satisfactory and properly implemented. The trend analysis performed by DAG will be made available to the E&P QA organization. This organization (, will utilize the B&R data and other data collected by F' E&P surveillance and audits to perform an independent H trend review that will be available to E&P management p for use in assessing the performance of the B&R quality L program. l l
.. (6-10) - _ _ _ _ _ _
[ [
- 2. Implementation Revised trending procedures for Project General Management and Engineering were developed and issued for use in May and April of 1980. A trending report issued April 15, 1980 by B&R Project General Management was essentially based on those procedures. Detailed draft procedures for the DAG now being reviewed will be finalized in mid-August, appropriate training will then be conducted, and the procedures implemented in early September, 1980. The first quarterly report of the new DAG is expected to be issued for fourth quarter 1980.
In the interim, until DAG is in operation, Project General Management will continue to issue trending reports. After implementation of the new procedures, there will be a continuous effort to develop and put into use improved techniques for data analysis. C. Corrective Action Under procedures in effect at the time of the NRC investigation, significant recurring problems were intended to be remedied through the issuance of CARS. [ With the creation of DAG, MRB, and new procedures associated with these nonconformance review groups, the basis for the CAR system is substantially strengthened. DAG will improve the process of identifying trends u
\
i
L [ adverse to quality. QE will then have responsibi-lity for identifying the causes of those trends and issuing { CARS for recurrence control. CARS shall be issued to identify for correction, significant or repetitive [ conditions adverse to quality, procedure inadequacies and failure to implement procedures which have no [ direct effect on items. The CAR will have specified time limits for taking responsive action and may constrain or " hold" work on specific tasks or by specific crews until resolved. A failure to respond within the time limits may result in issuance of a Stop Work Order. After a CAR is issued, QE will determine when corrective action has been taken, and whether it was effective in preventing recurrence of the problem. A Stop Work Order may be { issued if the investigative finding is that the correc-tive action has been ineffective, providing a strong incentive to respond promptly to CARS. Implementation of the improvements to the Corrective Action Request procedure is to occur in conjunction ~c with the revised nonconformance program described in Q A.2 above. I' H r L r L (6-12) _
RESPONSE TO ITEM (7) b order: The licensee shall develop and implement a more effective system to provide for the control of field changes h in order to assess the impact of the design changes on the design. Response: * { A. Background Under the procedures in effect at the time of the NRC investigation, the B&R construction forces and the HL&P startup organization utilized a form titled " Field Requests for Engineering Actions" (FREA) to propose { design changes from the field. The FREA was also used by Engineering to document design changes or deviations that could not readily be incorporated on the design drawings, and other minor design changes that did not appear to merit implementing the procedure for issuing j a Document Change Notice. The completed FREA form ' could serve as the design change mechanism or the change could be made on a Document Change Notice. [ Deviations from design could also be approved by pro-cedures involving a Nonconformance Report (NCR). F' H r L e L I (7-1)
l B. The New Field Design Change Program A new program is being adopted to replace each of { the present change mechanisms and to provide more effective control of field design changes. The new program will provide more follow-through information to the QC inspectors, will enable more rapid and efficient ( determinations through enhanced engineering staffs at { the site, and will require complete documentation, including justification of all change requests. All of this will enhance and facilitate the assessment of the individual and cumulative impact of the changes on-the plant design. ( B.l. Enhanced On-Site Engineering Staff All design changes proposed at the STP site will ( be submitted to the Project Site Engineering organiza- { tion, a staff of engineers located at the site (PSE) . This group is led by the Assistant Engineering Project Manager-Site (AEPM-Site), who reports to the Engineering Project Manager. The Project Site Engineering organi-zation is made up of a group of qualified engineers
, from each of the design disciplines and the Engineering Quality organization. Qualification and training records will be maintained on these personnel. Each PSE is responsible to the Project Engineer of his r
L f (7-2)
k [ . [ discipline for the technical aspects of the job, is a { member of that design discipline, is competent in the { relevant design area, has adequate understanding of the requirements and objectives of the original design, and has access to pertinent background information. The PSE reports to the AEPM-Site for his day-to-day respon-sibilities. The AEPM-Site is the primary interface ( between the Engineering Organization and the Construc-tion and Quality Assurance organizations at the site. In the past, the Project Site Engineering organ-ization has been limited in its capability to approve design changes without the prior approval of the Discipline ( Project ~ngineer at B&R's Houston Engineering Office. . Under the new design change control concept, however, both the responsibilities and capabilities of the { Project Site Engineering organization will be signif-icantly expanded to enable a much greater latitude in the approval of design changes. This will enable prompt and competent design review of the proposed changes at the site.
, If the Project Site Engineering organization has Q
the necessary technical resources to evaluate the requested change, and the request is approved, the l L AEPM-Site will issue a Design Change Notice (DCN). If L e (7-3) . _ ___________________-
[ : [ the proposed change requires resources not available at the site, he will forward the proposal to the B&R ( Engineering Office in Houston for evaluation. The design verifica, tion process, whether at the site or in l [ Houston, will include independent engineering review { and verification to assure that the design change will meet the intended design criteria for the affected - ( structure, system, or component. The prerequisites for issuance of DCN will include documentation of the reason for the change, justification for the change, [ engineering evaluation of the change, and, an assessment of the effect of the changes on the plant design. B.2. Change Review Board { As a further means of ensuring that the impact of design changes on plant design have been assessed, a [ Change Review Board will be established within B&R Engineering, both at the Site and the B&R Houston [ office. The primary function of this Board is to ( provide a mechanism to ensure that proper interdis-l cipline design reviews have been conducted within the ' o a B&R Engineering Organization. Each Board will be {. constituted from representatives of the major engi- I' neering disciplines, Engineering Quality, and Systems e Design Assurance. The Engineering Project Manager will l 5
E l appoint a Board Chairman at each location. The Site l Board will review all DCN's approved by the Project Site Engineering organization and the Board at the Houston Engineering office and will review all other DCN's. Copies of each DCN will be issued to the Board members prior to each meeting. Each Board member will assess the impact of the change on his area of design j responsibility and will identify additional changes required to accommodate the original change. During the meeting, the Board Chairman will assure that such I reviews have been conducted, all additional changes I g have been identified, and the change has been found technically acceptable, and will sign the DCN form signifying its approval when all of these assurances have been obtained. It is not the function of the I Board to perform detailed reviews of changes, but to l ensure that such reviews have been completed and to review the results thereof. B.3. New Field Chance Recuest and Desicn Chance Notice Forms To assure that the new system for controlling field changes is properly implemented, and to preclude the use of field change requests in place of NCRs to 9 report nonconforming conditions, a new system of forms I will be adopted. The currently used FREA will be l I l (7-5)
. I l t E
l l eliminated. Construction and Startup will propose i field changes by submitting Field Change Requests I (FCR's) to the Project Site Engineering organization. l An FCR may only be used to request a change when a need to depart from design requirements is identified in the planning stage or discovered while work is in progress, but prior to reaching a planned inspection point. If a nonconforming condition is found to exist during a planned inspection of work, an NCR must be prepared. l An FCR cannot be used as a substitute for an NCR; nonconformances will not be approved for "use-as-is" or
" repair" without the filing of an NCR.
When either the Project Site Engineering organi-zation or the Engineering office in Houston accepts an FCR, it will issue a Design Change Notice (DCN). No such design changes will be approved without issuance of a DCN form. The DCN will be controlled to ensure that there is objective evidence that all of the essential design control elements--justification for the change, engineering evaluation of the change, assessment of the effect of the accumulated changes on l 1 plant design, Change Review Board action, and revision of related documents--are satisfied. It is the DCN which is reviewed by the change Review Board and carefully B I
. (7-6)
[ : [ controlled and integrated into the doctiment control system for as-built verification. B.4. Autcmated Design Change Tracking System A computer based control system will be used ( to keep track of design changes and provide "real-time" information on the status of design. Each day a de- [, scription of each DCN processed that day will be entered into a computer by Engineering personnel at the site ; and in the Houston office. Each morning, a computer ( printout will be provided to users of the design docu-ments. The printout will list each approved DCN and its effective date, with respect to the particular document, thus assuring that each document user will have up-to-date information, including all changes, on the relevant portion of the facility design described in that document. This will assure that construction and inspection are based on the same current design ( information. B.S. As-Built verification [ When the construction of an item has been com- [a pleted, part of the final inspection process will A r' include the verification that the as-built configura-L tion is in conformance with the design. As-built p verification checklists will be prepared and their L correctness verified by design and quality engineering. F L J (7-7)
[ ! E The checklist will then be used by the inspector for the final inspection activity. This approach will ensure that all design changes have been incorporated _ _ into the plant and will provide objective evidence of { such. C. Implementation Implementation of the improved program for control-ling field changes is occurring in five (5) steps: (a) All procedures have been prepared and submitted I H for internal B&R and EL&P review to insure continuity and coordination. They will be issued for use on August 29, 1980. { (b) A training seminar is being prepared by a professional member of the B&R Training Department. This b program will be presented to all B&R members of s the Project who will participate in this program. (c) During the first few weeks of using the revised { procedures, members of the B&R Engineering staff will constantly monitor the program to aid individuals in its understanding and use. During this period, no FREA's will be issued, but those previously issued can be closed in that form. E' L (d) Finally, as a result of the initial implementation g period, an evaluation will be performed to determine U __ P s ~ (7-8)
if minor changes are required. Any FREA's not u approved by end of October,1980 will be treated [ as Field Change Requests and will be processed within that system. I I [ m [ [ O 9 L I L l L ~
L [ : [ RESPONSE TO ITEM (8) [ Order: The licensee shall develop.and implement a more effective system of record controls.
Response
A. Background On-site quality assurance records are stored in the on-site QA Vault. Documents are transmitted with an accompanying transmittal sheet to the QA Vault for r storage. The transmittal sheet itemizing the documents is signed to acknowledge receipt, an incoming identifi-cation number is assigned and the documents are reviewed { for completeness by QA Records Control Center personnel. Incomplete or inadequate documents are placed in a suspense file until the originating department is notified of the deficiencies and the deficiencies are corrected. Completed records are placed in the pre- [ microfilm suspense files pending microfilming, and in the postmicrofilm suspense file pending film processing in Houston, and a determination that the microfilm F copies are acceptable. Thereafter, the records are placed in the permanent files and data useful for cross l' L indexing is entered in a recently acquired computerized record index system. L L (8-1)
I I ! l B. New Record Processing Procedures l I With the assistance of a consultant, Nuclear Power I Consultants, Inc., the following objectives for the on-site STP record control system have been identified: I 1. The record requirements for each construc-l tion activity should be delineated. i
- 2. The system should be capable of providing j prompt information on the status of required l
1 records, so that it will be possible to determine I whether required records are being created, the i location of records and whether the records have been initiated or completed. l 3. As records are created they should be l controlled and protected to assure that the recorded status and location of the records remain correct. t 1
- 4. The system should include techniques to assure that the foregoing objectives are met.
I These objectives are being applied to the records control system and several opportunities for improve-L ment have been identified. A system will be created by
,< quality engineers such that, prior to commencement of work, the records required to substantiate the individual P
L activities will be identified. Persons charged with 7 creating required documents will record the status of (8-2)
E i [ those documents as the documents are created.- This will establish a current listing of required documents that can be used to identify missing or overdue records. When complete document packages on individual work ( activities are completed in the QA Vault, Quality Engineering (QE) will review them to verify that the [, documents are complete and adequate. { To shorten the time for processing records before placing them in permanent storage locations, new micro- [ film equipment is being acquired to speed up filming and to establish an on-site film processing laboratory [ devoted to the QA vault needs. This new equipment will { be used to reduce the time required to film documents and to substantially shorten the current processing time required to develop, process and verify the film. Efforts will continue to enter into the automated record index system information on new records and on ( records previously placed in storage. This computerized index permits rapid identification of records related [ in any of a variety of possible ways (e.g. , purchase [" o order, inspector, heat number, drawing number). While the backlog of data is being put into the L computer data base, a new filing system is being imple-p mented to eliminate the various suspense files. There L F L (8-3)
( ! [ will be a single filing system, and the documents will be filed with a record traveler prepared by quality engineers. The record traveler will identify the records required to substantiate each activity, will ( record the status of the file and the location of documents borrowed from the file, and will be used to [ identify overdue and missing records. { As part of a continuing program records already in the QA Vault will be reviewed for adequacy and complete-( ness, based on the results of the review of record 4 requiremenus. If record deficiencies are identified, [ corrective action will be taken. C. Implementation { The instructions for bnplementation will be issued by August 1, 1980. Complete generic check lists for all safety related records will be in use by November 1, 1980. It is anticipated that on-site microfilming capability will be in place and staffing and training complete by January 31, 1981. L r L4 e r' L r L F L / (8-4) - --- --
L l [ . C RESPONSE TO ITEM (9) [ Order: The licensee shall develop and implement an improved audit system. [ Response: A. Background E&P requires in its' QA Program that planned and { periodic audits be performed to verify compliance with all aspects of the quality program. E&P performs such audits internally as well as on Westinghouse Electric Corporation, B&R, and on others as necessary, to determine that the STP QA Program has been developed and documented { in accordance with established requirements... E&P and B&R have shared responsibilities for implementing audit systems. B&R, as architect - engineer and constructor, { has been responsible for all quality functions on the project within its scope, including the implementation b of an audit system in accordance with 10CFR50, Appendix B, Criterion XVIII. It was E&P's intent from the onset of the Project to audit B&R's performance, and [ l E&P committed in the PSAR to having an independent F' audit system. The B&R audit responsibility was to be L performed by the B&R home office QA Audit Section. F L i L I (9-1) -
[ [ E&P attempted to fulfill its audit responsibility ( through its Houston QA Support Services Division. { Steps have been taken to improve both the- E&P and B&R audit programs. B. Improvement of the Audit System Both E&P and its contractor, B&R, have substan- [ tially revised and improved their audit systems. [ B.1. Supplemental Audits E&P's corporate auditing procedure and STP QA Plan have been modified in accordance with criteria addressed in the PSAR, for determining the need for supplemental audits. ( As discussed in response to Item (6) to the Order, B&R is developing a centralized trend analysis system. The B&R audit group and Project QA management will { regularly receive the reports of the trend analysis group, thereby enabling them to identify problem areas and establish the need for performing supplemental audits. E&P has established its own program to analyze (, trends based on the B&R trending data as supplemented by E&P collected data. The E&P Site QA group has established a Quality Services group that will review [ L documents, record unsatisfactory conditions and menitor L !. . . (9-2)
b .. [ . B&R trending reports. The E&P audit group and Project QA management will receive both E&P and B&R trend { analyses. B.2. Upgraded Audit Staffs b The audit staffs of E&P and B&R have been up-graded through both increases in manpower and training l programs directed at improving the auditing skills of , l the respective staffs. E , Until E&P and B&R can increase their permanent audit staffs to sufficient numbers of qualified personnel, consulting firms have been employed to provide experienced' nuclear auditors to augment current audit staffs to meet current scheduling require-t ments. The function cf the E&P corporate audit group has [ been redefined to minimize conflicting assignments and { responsibilities of auditors thereby creating a group whose primary function is to prepare for and conduct [ audits of, quality-related activities. Auditors are continually receiving additional training in the areas of codes, standards, procedures, and other documents [, related to QA programs and auditing. O Recent B&R audit section staff meetings have L emphasized the elements to be reviewed in an audit, p u including the need to review actual work in progress along with objective evidence. B&R will increase the ~ i l _ . (9-3) -
[ [ number of Resident Site Auditors. Their functions will be to audit and monitor day-to-day quality, construction, { and engineering activities on site and provide Project and QA management with prompt reports of results. [ B.3. New Audit Procedures The E&P corporate audit procedure has been revis- [ ed to require both the review of objective evidence F L - (records) and direct observation of work being per-formed to assure procedural adherence and compliance b with quality requirements. The E&P corporate audit group has scheduled and commenced audits of B&R con-struction activities. [ E&P has developed an annual audit plan, which will be reviewed every six months at a minimum and revised accordingly. In addition to the annual audit { plan, a more detailed audit schedule is issued quarterly. This schedule provides for supplemental audits as well ( as required audits. A matrix has been prepared delineating all B&R procedures applicable to STP and the corres-b ponding audit (engineering, construction, discipline, l [, etc.) to which they apply. This matrix is utilized by I' the E&P and B&R audit groups to assure all quality L activities are audited within the required frequency. At least one audit team member must be experienced or trained in the discipline being audited. A revised r k g (9-4)
L [ audit schedule and an update of audits conducted in the [. previous quarter, including an evaluation of the audits { performed, are issued each quarter. B.4. Corrective Action for Audit Findings b Project and QA management will attend pre-audit briefings and post-audit exit critiques to ensure that b the audits are understood and that findings are addressed [, promptly. Management will ensure that agreement on action required is achieved and that implementation of corrective action is timely. Responsibility for correc-tive action within a specified time will be assigned. The organization with this responsibility shall clearly ( state in the written response to the audit findings, the corrective action taken to prevent recurrence and [ the schedule for completion. { Follow-up audits will be conducted to verify successful correction of the problems and their causes. C. Implementation The required improvements in the audit programs of E&P and B&R have to a large extent already been e [, accomplished. The E&P corporate audit group has been
, performing audits of B&R construction activities since March, 1980.
The audit staffs of HL&P and B&R are r currently under expansion, adding qualified personnel. L e L (9-5)
C .. [ [ Many of these positions are temporarily filled with [ qualified and certified audit personnel from consultant { organizations; however, recruiting and hiring is underway to replace the consultants with permanent staff. Necessary procedure revisions have been issued. The matrix of B&R STP procedures has been prepared and both b E&P and B&R have new schedules of future audits, [ including time and personnel provisions for the per-formance of supplemental audits. Audits of STP civil disciplines were conducted by E&P and B&R in March and April, respectively. { [ [ [ [ [ [. L s L P l . _ _ _ _ _ _ (9-6)
b .. [ [ RESPONSE TO ITEM (10) [ ( Order: The licensee shall verify or correct if necessary, the FSAR statements contained in Section 2.5.4, Stability of [ Subsurface Materials, especially Section 2.5.4.5, Excavations and Backfill. {
Response
[ See response to Item (2), page (2-33 ) through (2-36 ) . [ [ [ [ [ [ [ [. [ r L I
d) Os DOCKETED USNRC S. , l 2 JUL 311980 > : E 'l UNITED STATES OF AMERICA eD:fDM,sw @C nch - NUCLEAR REGULATORY COMMISSION to [ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Jca IN THE MATTER OF 5 5 HOUSTON LIGHTING & POWER 5 DOCKET NOS. STN 50-498-OL
- I COMPANY, ET AL.
5 5 STN 50-499-OL (South Texas Project, 5 Units 1 and 2) CERTIFICATE OF SERVICE I hereby certify that copies of Applicant Houston Lighting & Power Company's Response to Order to Show cause in the above captioned proceeding, including Attachment 1 thereto, were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this 29th day of July, 1980: I charles Bechhoefer, Esq., Chairman Atomic Safety and Licer.ing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555
. Richard L. Black, Esq.
Hearing Attorney
, Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard W. Lowerre, Esq.
I Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station Austin, Texas 78711
Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 - - Ms. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 l Steven A. Sinkin, Esq. 116 Villita San Antonio, Texas 78205 l Mrs. M. Keen I l 2602 Encino Bay City, Texas 77414 Ms. Irene H. Anderson 8715 Starcrest, #18 l San Antonio, Texas 78217 l l Mr. Gale van Hoy Houston Gulfcoast Buildings & Conrtruction Trades Council 2704 Sutherland Houston, Texas 77023 I l
, Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C.
i l 20555 Atomic Safety and Licensing Appeal j Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Chase R. Stephens Docketing and Service Section l Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission
, Washington, D.C. 20555 t
I / l /7A/ f ^ ^m Melbert D. $chwarf" ~
/
- Date
- July 29, 1980 E
.}}