ML19347E410
| ML19347E410 | |
| Person / Time | |
|---|---|
| Site: | South Texas, Perkins, 05000198 |
| Issue date: | 04/23/1981 |
| From: | Hayes D, Phillips H, Shewmaker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML16251A407 | List:
|
| References | |
| NUDOCS 8104270281 | |
| Download: ML19347E410 (60) | |
Text
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A O-04/23/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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HOUSTON LIGHTING & POWER COMPANY, Docket Nos. 50-498 ET_ A_L,.
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50-499 L
(South Texas Project, Units 1 and 2)
NRC STAFF TESTIMONY OF ROBERT E. SHEWMAKER, H. SHANNON PHILLIPS, AND D. W. HAYES, RELATIVE TO I&E REPORT 79-19 AND THE SHOW CAUSE ORDER OF APRIL 30, 1980 Q.
Will the panel members please state your full name, employer, job title and specifically, your responsibilities relative to the South Texas Project.
A.
My name is Robert E. Shewmaker and I am Senior Structural Engineer, Program Development and Appraisal, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission. During tne period relevant to this testimony, I was Senior Structural Engineer, Division of Reactor Construction Inspection, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission. As to my duties relative to the South Texas Project, I reviewed a series of allegations and investigations prior to November,1979, which resulted in a recommendation for further action and was assigned the task as the headquarters liaison for the special investigation beginning in November, 1979, and the preparation and issuancde of I&E Report 79-19.
I further proposed the enforcement action and participated in enforcement decisions
$104270 R y
k h relative to the Show Cause Order of April 30, 1980, and other enforcement action' stemming from 79-19.
My name is H. Shannon Phillips and I have been the resident reactor inspector at the South Texas Project since August 22, 1979.
I am responsible for coordinating all safety related inspection efforts relative to the NRC region and the site.
In addition, I was a member of a special investigation team, investigating allegations made in November, 1979, concerning lack of QC management support, intimidation and harassment of quality control inspectors and assessing of the overall effectiveness of the quality assurance / quality control (QA/QC) program at the South Texas Project. This investigative effort resulted in the issuance of I&E Report 79-19, the Staff's Order to Show Cause dated April 30, 1980, a Notice of Violation and a Proposed Imposition of Civil Penalties.
My name is D. W. Hayes and I am the Chief, Reactor Projects Section l
1.B. Region III, U.S. Nuclear Regulatory Commission. During the period relevant to this testimony, I was Chief, Engineering Support Section 1, I
Region III, U.S. Nuclear Regulatory Commission.
I was assigned the task to head a team of five inspectors investigating allegations concerning lack of QC management support, intimidation and harassment of quality control inspectors and assessing the overall effectiveness of the QA/QC program at the South Texas Project which led to the issuance of I&E Report 79-19, as well as, the Staff's Show Cause Order of April 30, 1980, a Notice of Violation and a Proposed Imposition of Civil Penalties.
Q.
Has the panel prepared statements of educational and professional qualifications?
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. A.
Yes.
Q. Are the statements attached to this testimony?
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A.
Yes.
Q.
What is the purpose of the panel's testimony?
A.
The purpose of this testimony is to respond specifically to concerns relative to the construction of the South Texas Project identified during the investigation which resulted in I&E Report; 79-19, and to summarize the enforcement action chosen as a result of those findings; that is, the Staff's order to Show Cause dated April 30, 1980, the Notice of Violation and the Proposed Imposition of Civil Penalties.
In addition, this panel will directly address Board Issue A, which states:
If viewed without regard to the remedial steps taken by HL&P, would the record of HL&P's compliance with NRC requirements, including:
(1) the statements in the FSAR referred to in Section V.A.(10) of the Order to Show Cause; (2) the instances of non-compliance set forth in the Notice of Violation and the Order to Show Cause; (3) the extent to which HL&P abdicated responsibility for construction of the South Texas Project (STP) to Brown & Root; and l
(4) the extent to which HL&P failed to keep itself knowledgeable about necessary construction l
activities at STP, be sufficient to determine that HL&P does not have the necessary managerial competence or character to be granted licenset to operate the STP?
In addition, this panel's testimony impacts to varying degrees on other issues and contentions currently before this Board. Specifically, to the extent this testimony evidences a course of conduct by the
. Applicant from which corporate character and competence can be inferred, it will be relevant to those issues.
Q.
Will the panel summarize the events which led to the formation of the special investigation team which drafted 79-19.
A.
Yes. Although Houston Lighting & Power was cooperative in correcting specific problems when cited, the same or similar problems eventually resurfaced, and it was felt these recurring problems evidenced the Applicants' inability to control construction activity.
(Fordetails concerning this construction history, see the direct testimony of Staff Panel 1). The Division of Reactor Construction Inspection in Headquarters was aware of this construction history.
In June, 1979, a Staff review in headquarters of six inspection and enforcement reports resulting in a recommendation that an additional investigation be i
conducted in order to exhaust all possible questions relative to the allegations contained in the six reports. Further discussions were held between headquarters management and Region IV management and it was concluded that the mid-term QA inspection, which was scheduled to occur in 1980, should be performed a year earlier.
The report of the mid-term QA inspection, dated October 5,1979, referenced as I&E Report 79-13 and previously identified as Staff Exhibit No. 27, was reviewed in headquarters during October of 1979 and this report revealed several quality assurance deficiencies. During
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discussions relative to the necessity of an escalated inspection, I
an additional series of allegations were conveyed to the resident reactor inspector, Shannon Phillips, relative to lack of QC manage-(
ment support, harassment, and intimidation of contractor quality l
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. control employees. As a result of the above, the Director of the Office of Inspection and Enforcement, Mr. Victor Stello, Jr., directed on November 3, 1979, that an in-depth investigation be made into the continuing allegations of lack of QA management support and harassment of contractor quality control employees.
In addition, it was directed that the Staff investigate the current effectiveness of the quality assurance program.
Q.
Will the panel summarize how this special investigative team was
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formed in order to perform this investigation.
A.
Yes. Although the regional offices have the responsibility for implementing the routine inspection program, headquarters has the responsibility for implementing special investigations or escalated enforcement actions. The Director of Inspection and Enforcement directed the Director of Reactor Construction Inspection to be responsible for implementing this special investigation. Mr. D.W. Hayes was designated the investigation team leader and coordinated the investigation activity l
which occurred between November 10, 1979, through February 7, 1980.
Mr. Robert E. Shewmaker was the liaison for headquarters and both reviewed the results of 79-19 and participated in the decisions relative to enforcement. Mr. H. Shannon Phillips was the South Texas Project resident reactor inspector and so could provide the desired continuity from the special investigation through the follow-up inspections. Other members of the team were chosen by reasons of their expertise in specific aspects of nuclear construction.
Q.
I show you a letter, with attachments, dated April 30, 1980, to Houston Lighting & Power making reference to this special investigation
. and marked for identification as Staff Exhibit No. 46. Are you able to identify this document, with its attachments?
A.
Yes. This letter transmitted to Houston Lighting & Power Company the results of the NRC special investigation designated I&E Report 79-19 which is attached to this letter as Appendix 0; together with Appendix A, the Notice of Violation; Appendix B, the Notice of Proposed Imposition of Civil Penalties; Appendix C, cross-references between violations and report details; and the Staff Order to Show Cause.
Q.
Turning the panel's attention to Appendix 0, I&E Report 79-19, what particular allegations gave rise to this investigation?
A.
This special investigation was conducted as a result of allegations received on November 2,1979, by the Resident Reactor Inspector, H. Shannon Phillips, from workers at the South Texas Project.
The allegations concerned lack of management support, threats and harassment of civil QC inspectors. Similar allegations had been previously made and had been investigated. The purpose of the escalated i
investigation which was initiated on November 10,1979, was to (1) investigate and detemine the validity of these recurring allegations, and (2) assess the effectiveness of the quality assurance / quality control i
program at the South Texas Project.
Q.
How were the allegations investigated?
A.
The investigation was conducted using routine inspection and investigation techniques; including, observation, review of documents, performance of tests, and both formal and informal discussions with site personnel.
In addition, investigations were for the first time on this project given the authority to take sworn statements. Over 100 formal
. and informal interviewed were conducted with Houston Lighting & Power and Brown & Root construction and management personnel.
In addition,
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Brown & Root inspectors and engineers, Pittsburgh Testing Laboratory personnel and other site personnel, such as craftsmen, office workers and training personnel were interviewed.
Q.
Would the panel please summarize its findings as a result of this special investigation.
A.
Yes.
It was concluded that procedural and programmatic inadequacies in the HL&P and Brown & Root organizations had resulted in a failure to systematically identify quality control problems and further a failure to routinely correct and prevent the recurrence of identified problems. Such inadequacies, resulted in a lack of adequate control over safety related activities.
It was concluded that the lack of detailed involvement by Houston Lighting & Power, in the total scope of construction activities at the South Texas Project, was an apparent major reason behind the discovered problems. This lack of detailed knowledge and involvement in daily construction activity hindered Houston Lighting
& Power's ability to maintain adequate control over its general contractor, Brown & Root.
Allegations of harassment, threats and/or intimidation of Brown &
Root quality control inspectors, which had been common knowledge by way of rumor, were substantiated by this investigation. These conditions had gone on apparently unchallenged by Houston Lighting and Power, and Brown
& Root, to the point that the quality of work at the South Texas Project could have been affected. However, it should be stressed that while most I
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. of the allegations investigated were substantiated, no irreparable construction deficiencies were found in structures already completed.
The special investigation further revealed that curient activities and recent QA records indicated that the QA/QC program had not prevented recurrence of poor concrete practices, which at times resulted in voids in structural concrete. The team concluded that contributing factors were procedures lacking in clarity and qualitative acceptance criteria; personnel with inadequate training, experience and/or education; and production pressures in the form of harassment and intimidation of employees.
With respect to specific areas, the investigation revealed backfill procedures were inadequate and consequently backfill may not have been sufficiently compacted to meet required densities, and serious problems were identified in the areas of safety related welding controls, welder I
qualifications and NDE performance and interpretation.
With respect specifically to the Applicant's QA program, QA audits and surveillance programs were improperly implemented and the Applicant failed to perform continuous and effective trend analysis of site documents that record problem areas, thus allowing chronic problems to persist. An overall lack of aggressive and effective QA/QC program and management was found.
The principal failure found by the inspection team was not the inadequacy of the QA/QC written, in-place, program; but rather, the failure of both Houston Lighting Power and Brown & Root to effectively implement l
l the in-place requirements and procedures. Decisions to vary from written
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procedures were frequently made by low level management, thus impairing quality control over in-process construction.
As a result of these findings, the Office of Inspection and Enforcement issued an Order to Show Cause, effective in 90 days, requiring Houston Lighting & Power to set forth its reasons why safety related construction activities at South Texas Project should not be stopped and remain stopped until certain specified actions were completed. Specifically, Houston Lighting & Power was directed to complete 10 specific actions in order to permit the Office of Inspection and Enforcement to evaluate whether future activities at the South Texas Project could be conducted in accord with Appendix B,10 C.F.R. Part 50.
To summarize the actions mandated by the NRC, Houston Lighting & Power was directed to do the following:
1.
Contract an experienced, independent management consultant firm, knowledgeable in QA/QC and nuclear construction, in order to evaluate Houston Lighting & Power's management of the quality assurance program.
Consideration of certain organizational responsibilities relative to design, procurement and construction were mandated and recommendations were to be made incorporating a schedule for implementation.
2.
Review existing data or obtain new data in regard to safety related arrects of Category I structural backfill.
3.
Review safety related welding in the civil structural and piping area, as well as safety related concrete structures, and report on the extent of necessary repairs, incorporating a schedule for completion of those repairs.
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. 4.
Rescind a Brown & Root brochure entitled " Implementation of the Brown & Root Quality Assurance Program at the South Texas Project Job Site" and issue a new brochure incorporating the fundamental pMlosophies contained in 10 C.F.R. Part 50, Appendix B.
This brochure S attached to Report 79-19 as Appendix 5.
5.
Houston Lighting & Power was to define more clearly which employees had stop work authority and to describe how that line of responsibility was to be implemented.
l 6.
Develop and implement a more effective system to provide for the identification and correction of " root causes" of nonconformances.
7.
Develop and implement a more effective program to provide for the control of field changes in order to assess the impact on the overall design of the structure.
l 8.
Develop and implement a more effective system of records control.
9.
Develop and implement an improved audit system.
10.
Verify or correct, if necessary, the FSAR statements contained in Section 2.5.4.
In addition to the overall directives contained in the Show Cause Order, Houston Lighting & Power was cited for 22 items of non-compliance and levied with a cumulative fine of $100,000.
A more detailed explanation of the investigative findings is set forth in the text of I&E Report 79-19, which is attached to this l
l testimony as Attachment D to Staff Exhibit No. 46, and is incorporated I
herein.
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. I Q.
As summarized above and more fully set forth in I&E Report 79-19. will the panel please address each Item of Noncompliance it found.
and cite the specific findings the violation is based upon.
A.
Yes.
10 C.F.R. 50, Appendix B, Criterion I, states in part,.
"the persons and organizations performing quality assurance functions shall have sufficient authority and organization freedom to identify
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quality problems... including sufficient independence from cost and schedule...." Contrary to this criterion, the results of the special investigation indicated that the quality assurance / quality control function in the civil area was not sufficiently independent, the QA/QC civil personnel did not have sufficient authority and the QA/QC personnel did not have the freedom to identify problems and to adequately resolve problems indicated. Numerous examples which support the investigative team's findings may be reviewed on pages 2-4 of Appendix B, Notice of.
Violation, to the transmittal sent to HL&P on April 30, 1980. This findings formed the basis for Item of Noncompliance 1.
Q.
Going to Item of Noncompliance 1 of Appendix A to the Commission's letter to Houston Lighting & Power of April 30, 1980, and looking at the second paragraph on page 2, do you agre,e with the matter set out in that
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paragraph?
l A.
Yes.
l Q.
Looking at the first sentence of that paragraph which I
f-essentially states that it was easier for the 1.ispectors at the South Texas Project to sign off the quality control documents than to be confronted by their supervisors and/or construction management, please state the basis for that finding.
I
. A.
This finding is based upon comments and statements by a significant number of quality control inspectors at the South Texas Project. Several of the inspectors made statements under oath to the affect that it was easier to sign off quality control documents than to confront their supervisors and/or construction management and thc3e statements are summarized in 79-19.
Q.
Again looking at the second paragraph on page 2 of the Notice of Violation, I call your attention to the second sentence of that paragraph which concludes no item of major safety significance was found in relation to the quality control inspectors not adequately performing their tasks.
Please set forth your basis for that statement.
A.
This conclusion is based upon two factors; first, although the quality control inspectors who were interviewed indicated that they were less than vigorous in calling deficiencies to the attention of management, in nearly every case where an inspector was interviewed he added that despite the problems of lack of support, harassment and the like from construction and/or.nanagement, he still did his job. Secondly, the j
special teams' investigation of safety related structures supported the i
I conclusion that no items of major safety significance were impacted since the team did not identify any instances where quality control inspectors fail to carry out their assigned responsibilities.
Q.
Again, referring to the second paragraph on page 2 of the Notice of Violation, what is the basis for the statement that potential is great l
for future problems unless corrective action is taken in regard to QA/QC program implementation?
. A.
The investigative team concluded after careful review of the findings that it was only logical to expect that the effectiveness of the QA/QC program would eventually diminish, given continued excessive production pressures on QC, inability to rely upon management support and further incidents of harassment and intimidation.
Q.
Are the matters set forth in paragraph A1.of Item of Noncomplicnce 1 true to the best of your knowledge?
A.
Yes.
Q.
Will the panel now please continue to address each item of noncompliance it found and cite the specific find'ngs the violation is based upon.
A.
Yes.
10 C.F.R. 50, Appendix B, Criterion IX requires in part,
" measures shall be established to assure that special processes... are controlled and accomplished... using qualified procedures in accordance with... specifications, criteria and other special requirements." From information provided to the team it was determined that a " test fill program" resulted in the determination that for placement of an 18-inch maximum lift thickness of soil backfill it would be necessary to make 12 passes with compaction equipment. Contrary to the above, construction procedures required only 8 passes with the compaction equipment for the placement of a maximum lift thickness of 18 inches of soil. Thus, the construction procedure did not reflect the necessary number of passes made by compaction equipment which had been established in a qualification test procedure. These findings formed the basis of Item of Noncompliance 2.
. Q.
Did HL&P, Brown & Root or Pittsburgh Testing Laboratory have any records or idea of how many passes of compaction equipment were made in a fill area before testing?
A.
No.
Q.
Did the investigative team, in the course of its investigation, obtain records to establish the loose lift thickness placed for backfill?
A.
No.
Q. Was there routine periodic inspection of placement of all backfill material prior to compaction?
A.
No.
Q.
Did HL&P, or any of its subcontractors or testing agencies, routinely and periodically test the material in the field for degree of compaction?
A.
Yes. One field density test (sand cone) was performed for every 20,000 square feet of lift material placed. However, the investigation revealed that ti. s periodic testing was not always performed in the most conservative soil location.
Q.
What is the basis of your answer?
A.
Interviews with cognizant personnel and review of testing records.
Q. Was at least one relative density test and one gradation test performed for every forth field test to ensure backfill material properties have not changed?
A.
Yes, except for the period between November 17, 1979, and January 7,1980.
. Q.
What is the basis of your answer?
A.
A review of the records at the site.
Q.
In regards to the period beginning November 17, 1979, and ending January 7,1980, how many field tests were performed?
A.
Approximately 64.
Q.
During that same period, how many relative density and gradation tests were performed?
A.
None.
Q. Was there any reason why such tests were not performed during this period?
A.
Yes, the vibrator table needed to perform the relative density test was broken.
Q.
During that period, did HL&P or any of its subcontractors continue to place backfill?
A.
Yes.
Q.
Did HL&P or any of its subcontractors have any idea of how many nasses of compaction equipment were made in a fill area prior to the relevant compaction test being performed?
A.
No.
Q.
On what basis were such tests performed?
i A.
When construction notified the cognizant quality control personnel that the area was " ready" to be tested.
Q.
Were there any records to establish the loose lift thickness did l
not exceed the 18-inch maximum provided in the specifications?
. A.
Lift thicknesses were not specifically being measured or recorded by the relevant quality control inspectors. Lift elevations were being recorded, however, this data cannot be correlated to lift thickness. The problem in such correlation is that the test records relative to elevation measurements were not maintained by placement area, but were candom depending upon the several areas tested.
Q.
Why is it important that the Licensee or NRC know if soil compaction is adequate?
A.
To assure that the soil will adequately support Category 1 structures under all postulated conditions.
Q.
What is the correlation or relevance between the number of passes with compaction equipment in any area to the determination of whether compaction is adequate?
A.
Whether compaction is adequate or meets specifications, may be determined by an in process test. These tests were performed by HL&P.
However, in order to assure the in-process procedures used to arrive at the desired results are adequate, and representative, the number of passes with compaction equipment should be noted.
In this way, prediction can be made relative to the degree of compaction after knowing the number of passes with compaction equipment.
It should be stressed, however, that the number of passes with compaction equipment is only one of several variables which determine the degree of compaction.
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. Q..Does the loose lift thickness placed have any bearing on whether compaction might be adequate?
A.
Yes. Loose lift thickness is yet another variable which goes into what compaction effort is required to obtain a specific degree of compaction.
The thicker the loose lift the greater compaction effort required to obtain a given dentity.
Q.
In the case of the South Texas Project, did quality control inspectors note the number of passes with compaction equipment prior to testing the soil for adequate density?
Q.
In the case of the South Texas Project, did quality control inspectors note the loose lift thicknesses prior to beginning the cumpaction effort?
A.
No.
Q.
In the case of the South Texas Project, did quality control inspectors note the number of passes with compaction equipment prior to testing the soil for adequate density?
A.
No.
Q.
Based upon the NRC special investigation, were there loose lift thicknesses in excess of of 18 inches?
number A040KCCP-2.
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. Q.
Is such a lift thickness measured before or after compaction?
A.
Before.
Q.
Did the inspections performed by the NRC indicate that compaction was not adequate at times?
A.
Yes, during an inspection it was learned that boring 204, near containment building number 2, encountered loose material near the base of the foundation mat. The extent and thickness of the area of loose material had not been determined as of February 21, 1980; however, Woodward-Lundgren was contracted to make a subgrade verification report for that area.
Pending receipt and review of that report, this item was considered unresolved by the investigative tea'm.
Q.
During the performance of compaction tests, were any unusual conditions noted concerning number of passes or the amount of " watering"?
A.
Yes, the problem with the number of passes with compaction equipment has previously been explained.
In addition, inspectors noted that the tested soil was watered. This relates to the fact that the highest maximum density is obtained for some soils in a saturated state.
Q.
Were these matters called to the attention of representatives of the licensee?
A.
Yes.
Q.
What were the licensee's replies?
A.
It was stated that it was only human nature that the Brown and Root inspectors wanted to make sure that the tests passed.
.m.
. Q.,Will the panel now please continue to address each item of non-compliance it found and cite the specific findings the violation is based upon?
A.
10 C.F.R. 50, Appendix B, Criterion XVI requires in part, " measures shall be established to assure that conditions adverse to quality, such as... detective... equipment... are properly identified and corrected.
In the case of significant conditions adverse to quality, the measure shall assure that... corrective action taken to preclude l
repetition." Contrary to the above, a review of Pittsburgh Testing Laboratory records on December 13, 1979, indicated that a relative density test had not been performed as part of the Applicant's test fill program since November 15, 1979, as a result of equipment failure.
Nonetheless, plant backfill continued to be placed and several sets of
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four field sand cone density tests were completed without the companion relative density test being performed. This procedure is in contra-diction to the FSAR which requires at least one relative density test be performed for every fourth field sand cone density test. This finding formed the basis for Iten of Noncompliance 3.
Q.
Please cite that section of the FSAR which set out the frequency of compaction field tests, relative density tests and gradation tests on soils.
A.
Section 2.5.4.5.6.2.4 entitled " Placement and Control Requirements for Backfill" states:
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. The compaction field tests were made according to
- ASTM D 1556, ASTM D 2167 or ASTM D 2922. At least one field density test was perfonned per 20,000 feet of each lift in unrestricted areas.
In restricted areas, at least one field density test was performed for each 200 yards.
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.
Whenever fill or backfill was placed during a work shift, at least one field test and one laboratory relative density test were conducted during the shift, provided that the compaction operation was completed in some area.
Q.
Referring to the last paragraph of that section, did the investigation substantiate that at least one field test and one laboratory relative density test were performed during each shift?
A.
No. The vibrator necessary for the relative density test was broken for the period between November 17, 1979 and January 7,1980.
l Q.
Did the failure of the Applicant to perfonn the relative density test during that period materially impair the backfill testing progran?
A.
No. During the period when the relative density tests were not conducted, the Applicant took continuous samples to be tested when the testing equipment became operative. Technically, this is proper since l
test results will not be affected by the passage of time. Practically, in the event the subsequent tests revealed inadequate results, the Applicant would be l
forced to rework any area of backfill to correct deficient areas.
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. Q.
Turning the panel's attention to E 2.5.4.5.6.2.5 of the Applicant's FSAR, entitled Backfill Inspection and Testing Requirements, please state what that paragraph provides.
A.
That section states:
The testing agency provided QC inspection of the backfill, the placement and testing of the material in the field for degree of compaction. The QC inspectors observed the type of material, lift thick-nesses, operation of compaction equipment, and all other pertinent material or construction conditions affecting the quality of work and compliance with the specifications. The QC inspectors noted c.onformance with the limiting criteria of the specification and construction procedure for structural backfill and reported the acceptability of the operation. The frequency of testing and selection of tests locations for placed material were according to the requirements identified in these six categories:
Q.
What did this first paragraph of 2.5.4.5.6.2.5 provide?
i A.
This section mandated that quality control inspectors observe and inspect backfill, the placement and testing of the material in the field for degree of compaction. However, the records kept in response to this FSAR commitment were inadequate. There were no records kept, nor procedures established to indicate precisely what the inspectors looked for or found.
Accordingly, the investigation team could not establish the adequacy of the quality inspectors' check based upon a review of applicable records.
Q.
Did the investigation indicate whether there were periodic and routine inspections of the placement of all backfill material and tests of l
material in the field for degree of compaction?
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A.
No. Testing personnel were called by construction personnel when, in the minds of construction, the area was ready to be tested.
Q.
Did inspectors observe the type of material, the loose lift thick-ness, the operation of compaction equipment and all other pertinent material or construction conditions 7.ffacting the quality of work and completion of the specifications on backfill?
A.
Yes; however, such inspections were performed on a spot, rather than a routine basis.
Inspectors did not observe the number of passes of compaction equipment nor did they routinely measure and record the loose lift thickness of backfill.
Q.
What is the basis for this answer?
A.
Discussion with both testing and construction site personnel responsible for the activity and by a review of records on the site.
l Q.
Why does the NRC wish to know how backfill is placed during construction?
A.
This information is needed to assure the Commission that design specification requirements are met relative to soil densities needed to support Category I structures under all postulated conditions.
Q.
Why does the NRC wish to know what field or laboratory tests were nade regarding relative density of backfill and when such tests were made?
A.
Not only must it be verified that design specification requirements have been met, but, it is equally important to be able to determine how such specifications were met.
In this regard, a documented, in process testing l
program is essential.
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. Q.,Why would the NRC wish to know if there were periodic and routine inspections of placement of backfill material?
A.
Again, to ensure that design specifications were met and, in addition, to verify that a systematic and uniform placement has occurred according to procedure has occurred. This information is important since density tests are performed only on a smail portion of the total volume of backfill material placed and accordingly are an important sampling check.
Q.
Why would the NRC want to know the msterial was tested in the field and the degree of compaction?
A.
The degree of compaction is a measure of the soil strength and its ability to support the structures founded on such material.
Q.
Why would the NRC wish to know whether inspectors observed the type of material, the loose lift thickness, the operation of compaction equipment and other pertinent construction conditions affecting the quality of work and compliance with specifications?
A.
This is desirable in order to verify that a systematic and uniform placement of backfill material has occurred and that such placement has resulted in the meeting of design specification requirements to support structures.
Q.
In regard to the second paragraph in FSAR H 2.5.4.5.6.2.4 is it important that a laboratory test be performed to confi nn field tests every fourth time or is it enough that just an average of one/ fourth of the field samples are verified in the laboratory?
l A.
The two tests measure in process construction activity; because of this, when you perform such tests,are only important relative to when one places the next lift over the tested lift. The NRC interpreted the Applicant's FSAR-conservatively, and consequently, read it to mean one l
relative density and one gradation test for every fourth field test, in contrast to an average of every fourth time. This interpretation is supported by that section's last paragraph which states that whenever backfill is placed during a work shift, at least one field test and one laboratory relative density test will be conducted.
Q.
Will the panel now please continue to address each item of non-compliance it found and cite the specific findings the violation is based upon?
A.
Yes.
10 C.F.R. 50, Appendix B, Criterion V requires in part,
" activities affecting quality shall be prescribed by documented instructions, procedures... appropriate to the circumstances." HL&P QA department has responsibility for ensuring that methods, procedures and instructions I
are developed and implemented for all activities relating to the South I
I Texas Project, nonetheless, the QA procedures for Pittsburgh Testing Laboratory indicated that the in-place density measurements were to be I
perfomed according to ASTM-D-1556. Contrary to the above, there are no requirements in these procedures which define the location or depth of soil samples to detemine density. This finding fomed the basis of Item l
of Noncompliance 4.
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. Q.
Why shouldn't the depth of, and location of, backfill tests be left to the judgment of an inspector?
A.
In any lift of backfill that is tested, it is necessary to take the samples from the elevation of least density. Thus, to be conservative, tests should be performed in this zone, as determined in pretesting. This location within a lift may vary because of such parameters as soil type and compactive effort. No such provisions were made in the in-place relative density test procedures.
Q.
So, it is the panel's feeling that the matters stated in Item of Noncompliance No. 4, pages 6 and 7 of Appendix A, are true?
A.
Yes.
Q.
Will the Panel now please continue to address each item of non-compliance it found and cite the specific findings the violation is based upon?
4 A.
Yes.
10 C.F.R. 50, Appendix B, Criterion XVII requires in part, that,
" sufficient records shall be maintained t'o furnish evidence of activities affecting quality." Contrary to this documentation requirement, neither the applic:ble Brown & Root procedures nor the test records w'th respect to soil compaction required that lift thickness and number of passes of the compaction equipment be documented. This data is necessary to ensure that backfill material is being systematically placed and compacted to obtain the required specification densities.
This finding formed the basis of Item of Noncompliance 5.
l l
l 10 C.F.R. 50, Appendix B, Criterion XVI states in part, " measures shall be established to assure that conditions adverse to quality, such as failures,... deficiencies, deviations,... and nonconformances are properly identified and corrected...." Contrary to the above requirement, no effective program had been implemented at the South Texas Project on a continuing basis to review and analyze nonconformance reports, examination checks / inspection books or field requests for engineering action for repetitive occurrences to assure that root causes to problems were identified and corrective action was taken to preclude repetition.
In addition, no formal approved procedures to implement such a program had been developed as of November 28, 1979. This finding formed the basis for Item of Noncompliance 6.
10 C.F.R. 50, Appendix B, Criterion XVI as implemented by the South Texas Project PSAR 9 17.1.16, states in part, " measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deviations, deficiencies... are properly identified and corrected...." Contrary to the above, in the context l
of lifting a stop work order for placement of containment shell concrete.
l HL&P failed to implement corrective actions proposed.
In addition, work observed during the resumption of concrete pouring, statements by site l
personnel, and review of quality assurance records indicated that the corrective action outlined by HL&P in an August 31, 1979 letter had not been effective in precluding repetition of the earlier cited problems.
l This finding formed the basis for Item of Noncompliance 7.
10 C.F.R. 50, Appendix B, Criterion V states in part, " activities l
affecting quality shall be prascribed by documented instructions,
. procedures or drawings... and shall be accomplished in accordance with these instructions, procedures or drawings." In implementing this criterion the STP PSAR states in part, "... quality related activities for the South Texas Project are prescribed by documented instructions, procedures or drawings; accomplished in accordance with such documents;...." The quality assurance personnel training manual set forth required educational levels for QC inspectors. Contrary to the requirements set forth in the Brown & Root and Pitt:: burgh Testing Laboratory (PTL) quality assurance manuals, of the 14 Brown & Root civil QC inspectors and 6 PTL concrete inspectors for which qualification records were examined, 5 Brown & Root and 3 PTL inspectors did not have the required QA/QC experience at the time of their certification. This finding formed the basis of Item'of Non-ccmpliance 8.
Q.
Are the matters set forth in Item of Noncompliance No. 8, at page 9 of Appendix A to 79-19 true as stated therein?
A.
Yes.
Q.
Please continue in citing each item of noncompliance and the factual basis for each item.
A.
10 C.F.R. 50, Appendix B, Criterion VI states in part that, " measures shall be established to control the issuance of documents, such as instructions, i
procedures, and drawings, including changes thereto, which prescribe all l
activities affecting quality...." Contrary to the above, controlled copies of the contractor's quality assurance manual on January 8,1980, did not contain the latest interim changes.
In addition, the Applicant's l
controlled copy of the contractor's weld filler material specification did l
l 1
l
. not contain the latest document change notices. These findings formed the basis of. Item of Noncompliance 9.
10 C.F.R. 50, Appendix B, Criterion IX states in part, " measures shall be established to assure that special processes including welding... are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications...."
Ccntrary to the above, the inspection team observed at least three occasions where safety-related pipe welding activitios were being performed without adequate protection from atmospheric conditions. Subsequent examination of these welds showed that they had unacceptable defects. This finding formed the basis for Item of Noncompliance 10.
10 C.F.R. 50, Appendix B, Criterion IX states in part, " measures shall be established to assure that special processes, including...
nondestructive testing; are controlled and accomplished... in accordance with applicable codes, standards, specifications, criteria, and other special requirements." Three instances were discovered where nondestructive testing was not performed in accordance with applicable codes, standards and specifications.
(a) Applicable codes require all radiographs be free from mechanical, chemical or other blemishes to the extent that they cannot mask or be confused with the image of any discontinuity. Contrary to the above, the inspection team reviewed at least 50 final radiographs of production field welds and of welder qualification tests which displayed significant light fogging and chemical contamination to such an extent that proper interpretation of the radiograph was not possible in whole or in part.
(b) Applicable specifications state radiographs shall be examined and interpreted on a review form accompanying the radiographs. Contrary to the above, the inspection team observed at least 12 radiographs of field welds and one
. radiograph for a walder performance qualification test weld which contained linear indications that had not been recorded on the accompenying interpretation sheet.
(c) Applicable specifications state that any indication which is believed to be nonrelevant shall be regarded as a defect and shall be reexamined to verify whether or not actual defects are present. Contrary to the above, the inspection team observed the performance of a liquid penetrant examination for field weld No. 0017 in the essential cooling water system for which the results were not evaluated according to the above-cited requirements. These findings formed the basis for Items of Noncompliance lla., lib., and 11c.
10 C.F.R. 50, Appendix B, Criterion V requires in part " activities affecting quality shall be prescribed by documented instructions...."
The Applicant incorporated this requirement in its PSAR in 517.1.5b wherein it is stated that " engineering, construction, inspection, testing, and planning techniques are used to assure that activities affecting quality are set forth by written B&R instructions...."
Contrary to the above, on December 10, 1979, the inspection team determined that an interim change was issued on August 30, 1979, and was inserted in the procedures at the applicable page. These interim procedures are valid for only 60 days. The inspector observed that the invalid or cancelled insert was still being used during January 1980. A similar example was observed relative to inserts for ST-NDEP-4.1, Revision 9, dated March 13, 1979. Consequently, this appeared to be a generic problem, and formed the basis for Item of Noncompliance 12.
10 C.F.R. 50, Appendix B, Criterion XVI states in part, " measures shall be established to assure that conditions adverse to quality such as
... deficiencies, deviations,... and nonconformances are properly identified and corrected." Contrary to the above, five Cadwelders had
30 -
accumulated two visually unacceptable production splices within a unit of 15 consecutive splices and were permitted to continue making production splices without requalifying with respect to procedures. This finding formed the basis of Item of Non ompliance 13.
10 C.F.R. 50, Appendix B, Criterion XVI states in part, " measures shall be established to assure that conditions adverse to quality, such i
as failures... are promptly identified and corrected... and the corrective action taken shall be documented and reported to the appropriate levels of management." Pursuant to this criterion, the STP PSAR states that deficiencies or nonconformances must be reported to the Power Division Senior Group Vice President any time agreement on corrective action to be implemented cannot be obtained. Contrary to the above, there was no objective evidence that the Division Senior Group Vice President was advised of the failure to take action on repetitive deficiencies documented in Brown & Root site surveillances SIS-12 and 12.1 through 12.5, nor advised of the failure to get respoases and/or corrective action on SIS-18 and the Brown & Root letter 5153 dated November 12, 1979. This finding formed the basis of Item of Noncompliance 14.
10 C.F.R. 50, Appendix B, Criterion V states in part, " activities affecting quality shall be prescribed by documented instructions... and shall be accomplished in accordance with these instructions, procedures, Pursuant to that code section, HL&P quality procedures required that all check lists shall be completed in full, signed and dated by the QA personnel involved and any discrepancies or deviations from specifications shall be marked and discussed. Contrary to the above, y
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. civil surveillances C.2.1 through C.2.5 were not properly documented as required. by the written procedures. That is, unsatisfactory conditions and corrective actions were not always. documented during the period of.
1978 and 1979. This finding fomed the basis of Item of Noncompliance 15.'
Q.
I turn the Panel's attention to pages 102-106 of I&E Report 79-19 and ask if the matters set forth therein_ are true to the best of your knowledge.
A.
Yes.
Q.
Will the Panel continue to cite each Item of Noncompliance it found and the factual basis for such item?
l A.
Yes.
10 C.F.R. 50, Appendix B, Criterion XV requires in part, " measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use Contrary to the above, site soil penetration testing activities were allowed to continue during the period January 28, 1980 through February 4,1980, using a weight (" hammer") which had been identified as nonconforming to the requirements of ASTM D-1586-67. This finding formed the basis of Item of Noncompliance 16.
10 C.F.R. 50, Appendix B, Criterion XI, requires in part, " test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is l
available and used..." Contrary to the above, the split-spoon used in the backfill test program during the period January 23, 1980 to February 5,
- 1980, did not confom to the requirements of ASTM 0-1586-67 in that the inside diameter of the cutting edge was measured tu be 1.5 inches and the driven edge of the split-spoon was badly distorted and had a.50-inch taper. Thus,.the test procedure which defined the proper dimensions on the equipment was not followed, and formed the basis for Item of Noncompliance 17.
. 10 C.F.R. 50, Appendix B, Criterion XVIII states. in part, "a comprehehsive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program." Contrary to the above, the inspection team found three separate instances where the audit function of the Applicant's quality assurance program was impaired.
(a)
Neither HL&P nor Brown & Root perfomed supplemental audits to detemine if safety performance or reliability of an item was in jeopardy even though there were continuing allegations relative to civil construction and inspection activities, as well as, significant voids identified in early 1978.
(b) HL&P further failed to adequately aedit its QA function. Essentially HL&P reviewed the records of the site QA function, but did not identify the fact that HL&P site procedures were not being effectively implemented in that nonconfomances and deviations were not being identified in the civil surveillance reports.
(c) Contrary to the above code and sections of HL&P's PSAR, it did not audit the implementation / execution of Brown & Root site construction procedures for the years 1977, 1978 and 1979; nor the site QA/QC procedures during the years 1978 and 1979. These findings fomed the basis for Items of Noncompliance 18a., 18b., and 18c.
Again relying upon that part of 10 C.F.R. 50, Appendix B, Criterion XVIII, just cited, the STP PSAR states in part, " Brown & Root, (B&R) has established an audit system... for internal... audits...."
Contrary to the above, Brown & Root's audits of site QA/QC and construction activities were essentially only paper reviews of records and did not determine whether the site quality procedures were actually being effectively implemented. Further, no audits were conducted of site
i i design control in 1978, although design lead time over construction was and continues to be very short. This finding formed the basis for Item of Noncompliance 19.
10 C.F.R. 50, Appendix B, Criterion X, states in part, "a program for inspection... shall be... executed... to verify conformance with the drawings." Houston Lighting & Power was to establish with each of its prime contractors the primary inspection responsibility and HL&P was to retain responsibility for review. To that effect, Brown & Root specifications require in part that the DC civil inspector ensure compliance with appliable drawings by verifying that reinforcing steel is supported and tied to prevent displacement. Contrary to the above, on December 7,1979, although completed QC documentation indicated that the reinforcing steel for placement DG1-M1 was properly installed, a sample inspection of 10 vertical tie bars, made when the placement was about 1/3 completed, indicated that three of the ten were unwired. This finding formed the basis of Item of Noncompliance 20.
10 0.F.R. 50, Appendix B, Criterion III requires in part that,
" measures shall be established to assure that... the design basis
... for those structures, systems and components... are correctly translated into specifications, drawings, procedures, and instructions.
These measures include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled." Contrary to the above, Brown & Root authorized design changes to welding requirenents without
I proper review and approval. This finding formed the basis of Item of Noncompliance 21.
10 C.F.R. 50.55a(d)(3) states in part, "... piping which is part of the reactor coolant pressure boundary shall meet the requirements of Class 1 components set forth in Section III of ASME Code..." Such requirements specify not only the weld procedure but qualifications for welding operators. Contrary to the above, the inspection team observed radiographs of specimens completed by welders containing only film side penetrameters. On January 14, 1980, the inspector observed a weld being made on a Class 1 system, the main reactor coolant piping by an improperly qualified welder. These findings formed the basis for an infraction identified as Item B.
As a result of the findings set forth above, the 21 items of noncompliance togetner with Item B were incorporated in the Notice of Violation, attached to the April 30, 1980 transmittal letter to Houston Lighting & Power, identified as Appendix A to Staff Exhibit No. 46.
Q.
In regard to the detailed findings just testified to, and the various findings set forth in Appendix D, is it this Panel's position l
that the matters set forth in Appendix D; that is, I&E Report 79-19, are true to the best of your knowledge?
A.
Yes.
Q.
Based upon your investigation, did Houston Lighting & Power have knowledge of Brown & Root's quality assurance / quality control program at
[
the South Texas Project?
A.
Yes, Houston Lighting & Power had to review and approve this program and from that it can be concluded they had knowledge.
u_
l i Q.
Did Houston Lighting & Power have knowledge relative to the manner in which Brown & Root was implementing its QA/QC program at the South Texas Project?
A.
Based upon our investigation, although HL&P was given sufficient information to be aware 'of the nature of the Brown & Root QA/QC program, as. implemented, it was the team's conclusion that HL&P failed to take the appropriate corrective action based upon the manner in which Brown & Root was carrying out its QA/QC program.
Q.
Based upon the investigation, what was the cause of HL&P's failure to take the appropriate action after being given information concerning the manner in which Brown & Root was carrying out its QA/QC program?
A.
HL&P stationed an inadequate number of employees at the site, and further, those persons detailed to the site by HL&P did not have the requisite experience to perform the needed supervision.
In addition, HL&P overly relied upon Brown & Root to implement the QA/QC program and had inadequate involvement in site activities.
In addition HL&P inadequately followed up on surveillance and audit findings relative to Brown & Root's QA/QC program; HL&P site personnel did not sufficiently keep corporate management informed of site activities; and corporate management was negligent in not keeping itself informed of site activities and accompariying problems.
Q.
Prior to the findings set forth in 79-19, did HL&P have sufficient knowledge to cause it to investigate the question whether QA/QC inspectors of Brown & Root were being intimidated or harassed by construction personnel?
A.
Yes. Based upon the escalated investigation, several cases were found where complaints or allegations were previously made directly to
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HL&P personnel.
In addition, HL&P had full knowledge of the several NRC investigations involving alleged QA/QC inspector harassment for the period two years prior to 79-19.
l Q.
Based upon your investigative findings, did HL&P apply proper I
resources and succeed in assuring that there was a proper QA/QC program l
at the South Texas Project?
A.
No. The basis for this conclusion is that there was an overall lack of detailed involvement at the site by HL&P; HJ.&P failed to recognize and subsequently correct inadequacies in site staffing; there was a failure to take or verify that adequate actions were taken to correct recurring problems and, finally, there was a failure to maintain an adequate audit program which would have revealed the inadequacies of the QA/QC program.
Q.
Did HL&P manage construction at the South Texas Project?
A.
No. HL&P delegated that task to Brown & Root.
Q.
Did HL&P properly audit Brown & Root's QA/QC operations at the site?
A.
No. This failure has previously been referred to in Items of Noncompliance Nos.1,18 and 19, as well as Show Cause Items 1, 4, 6 and 9.
Q.
What responsibilities did HL&P take in its PSAR to assure that the QA/QC program was properly carried out at the site?
A '. The corrinitments made by HL&P were contained in Chapter 17 of the PSAR and, essentially, followed the requirements of 10 C.F.R. 50, Appendix 8.
I l'.
Q.
Did HL&P's action inditSte that it took responsibility for the QA/QC program at the site?
A.
ho. There was a general lack of management involvement in site activities, a failure to recognize and correct inadequate site staffing, l
failure to identify or correct recurring problems and a _ failure to maintain an adequate audit surveillance system over construction activities.
Q.
Do the Items of Noncompliance, Show Cause items, and civil penalties represent all of the inadequacies identified by this special investigative group during its investigation?
A.
No, due to the widespread problems identified, and the limited time during which the team was collected at the South Texas site, the team set forth a number of unresolved items and open allegations to be followed up by Region IV after the team's investigative efforts were concluded. A listing of these unresolved items and open allegations is set forth in Appendix A to this testimony.
In addition, the next NRC Staff panel will testify to the current status of these open allegations and unresolved matters.
Q. With respect to the Notice of Violation, what response was expected of Houston Lighting & Power?
. A.
As a result of the Notice of Violation and the findings set forth in I&E Report 79-19, a civil penalty in the amount of $100,000 was proposed.
HL&P promptly paid that assessed penalty, enclosed in a transmittal dated May 23, 1980.
In addition, pursuant to the provisions of 10 C.F.R. 6 2.201, Houston Lighting & Power was required to submit to the NRC within 25 days of receipt of the Notice of Violation, a written statement of explanation in reply to each iten of noncompliance, (1) stating either an admission or denial of the alleged item of noncompliance; (2) the reason for the item of noncompliance if admitted; (3) the corrective action which had been taken and the results achieved; (4) corrective steps which will be taken to avoid further items of noncompliance; and (5) the date when full compliance will be achieved.
Q.
I show you a transmittal from Houston Lighting & Power to the l
NRC, dated May 23, 1980, and marked for identification as Staff Exhibit No. 47 and further ask if you are able to identify this transmittal.
A.
Yes. This transmittal contained HL&P's proposed correctt/e actions for the items of noncompliance set forth in the Notice of Violation attached to I&E Report 79-19.
Q.
Did this panel perform a follow-up investigation to determine whether the corrective actions proposed in HL&P's letter of May 23, 1980, were in fact implemented?
l A.
No. The task of following up corrective actions taken by HL&P l
was delegated to Region IV by headquarters. A panel of Region IV I&E personnel will testify to the status of the corrective actions proposed.
Q.
As sumarized earlier, and more fully documented in 79-19, 1
previously identified as Staff Exhibit No. 46, will the panel please
. address each item in the Show Cause Order which HL&P had to answer prior to resuming construction activity at the South Texas Project and cite the specific findings these items are based upon?
A.
Yes. Since the findings contained in 79-19 reflected widespread noncompliance by both HL&P and its principal contractor, Brown & Root, and in view of the past record of inspection and enforcement at the South Texas Project and the importance of quality assurance during censtruction of a nuclear power plant, pursuant to 10 C.F.R. Parts 2 and 50, as previously stated, the Staff issued a Show Cause Order to HL&P to explain why safety-related construction activity on the South Texas Project, Units 1 and 2, should not be stopped 90 days from the date of that Order (April 30, 1980) and remained stopped until such time as the Licensee completes certain items set forth in the order.
HL&P was directed to retair an experienced, independent management consulting firm, knowledgeable in both QA/QC matters and nuclear construction to determine whether.1e management of the South Texas Project was adequate.
It was apparent to the investigation team that due l
to Brown & Root's inability to adequately conduct a QA/QC program coupled with HL&P's inability to effectivaly monitor Brown & Root's program, an independent consultant was needed to pinpoint problems and restructure the system.
l t
40 -
Q.
Looking at page 9 of the Order to Show Cause, and referring to the second paragraph, on what basis did the investigative team conclude that allegations of harassment, intimidation and the lack of support of QC inspectors were substantiated?
A.
Primarily, this conclusion was based upon consistent and corroborating statements made by quality controi inspectors, witnesses and other persons involved at the South Texas Project.
Q.
What impact, if any, does this finding have on the question of HL&P's ability to manage construction at the South Texas Project?
A.
Both HL&P and Brown & Root management were aware cf repeated com-plaints and allegations of harassment, intimidation and lack of support for quality control inspectors over a period exceeding two years, yet, failed to take effective action to identify the root cause for such problems and correct those problems in order to prevent recurrence.
Q.
Looking at the next sentence in that paragraph within the Show Cause Order, please explain the basis for the conclusion that the QA/QC program at the South Texas Project at the time the Show Cause Order was issued was deficient and did not meet the standards required to assure that construction would not meet NRC requirements.
l A.
Shortcomings were identified in the QA/QC program in the following areas :
1.
Control of concrete placement activities; 2.
Welding and nondestructive examination activities; G
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Control of backfill material placement and testing; 4.
Identification of recurring problems; 5.
Effectiveness of corrective action; 6.
Independence and authority of civil QC inspectors; 7.
Auditing program.
Q.
With respect to.HL&P, please state an example where there was a failure to correct and/or prevent recurrence of identified quality problems.
A.
First, it must be noted that HL&P, as the construction permit holder, is responsible for assuring that an effective QA/QC program is established, implemented and maintained. This is so even though authority to implement the program may be delegated.
An example where HL&P failed to correct and prevent recurrence of i
identified quality control problems may be found in the preplacement, place-ment and postplacement of concrete. Preplacement problems included last-minute construction work with undue pressure on quality control inspectors to accept that work, repeated identification of omitted or improper spacing of rebar, and inadequate numbers and qualifications of QC inspectors.
Place-ment problems included impropar consolidation practices, poor lighting and planning, as well as excessive lift thicknesses.
Postplacement problems included failure to adequately review the preplacement and placement problems to profit from the identification of those problems through experience.
_ Q.
Based upon the investigation, did HL&P lack detailed involvement in the total scope of activities associated with the construction of the South Texas Project?
A.
Yes.
Q.
What effect did this have on the ability to identify and correct quality related problems?
A.
Because of inadequate involvement and overdependence upon Brown &
Root, HL&P failed to maintain adequate knowledge of site activities to assure quality control problems were being properly identified and effectively corrected.
Q.
In April of 1980, did the South Texas Project quality assurance management recognize the necessity and desirability for organizational freedom of quality assurance / quality control from construction?
A.
No.
Q.
What is the basis for your rtatement?
A.
Primarily, a review of the construe. tion site quality assurance program, and by review of the brochure " Implementation of the Brown & Root Quality Assurance Program at the South Texas Project Job Site" reveals an attitude which places construction pressures on par with quality assurance.
In addition, a lecture to construction and QA/QC personnel was given in January,1980, by the project QA manager which again overemphasized construction pressures over quality assurance.
In short, the lecture repeatedly overemphasized the Brown & Root's quality assurance organization's responsibility for minimizing project cost and maintaining construction schedule.
Q.
How did this lecture and the brochure pertain to the requirement that there be organizational freedom for the quality assurance / quality control organization?
A.
NRC regulations require that persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality related problems; to initiate, recommend, or provide solutions; and to verify implementation of those solutions.
In light of the above, to impo:e cost and scheduling responsibilities on QA/QC is counter to the above responsibilities.
Q.
Is there a copy of the brochure just mentioned in the record of this proceeding?
A.
Yes, the brochure entitled " Implementation of the Brown & Root Quality Assurance Program at the South Texas Project Job Site" is attached as Appendix 5 to I&E Report 79-19, previously identified as Staff Exhibit No. 46.
Q.
What other matters were stressed in the lecture previously referred to regarding QA/QC7 i
A.
The lecture stressed that the QC inspectors' decisions relative to stop work authority and judgments were subject to question and/or challenges through supervisory review and approval.
i f
Q.
As of February,1980, what effect did the QA/QC program have on 1
correcting concrete practices?
A.
The QA/QC program, as of that date, was ineffective in preventing recurrence of poor concrete practices.
Q.
What construction defects, if any, resulted from these concreting practices?
A.
Voids in structural concrete and severe deformation of the containment l
liner, as previously testified to by this Panel and Panel 1.
Q.
Were there QA/QC questions raised by the investigation in regard to the soil foundation?
A.
Yes. These problems have been identified and been the subject of extensive testimony above.
Q.
Did HL&P or Brown & Root perform any effective trend analysis of problems on the South Texas Project?
A.
No.
Q.
What effect did this failure to perform this trend analysis have on quality assurance and quality control?
A.
As previously stated, this failure resulted in net identifying recurring problems, and accordingly, these problems continued to resurface.
l Q.
As a result of the findings of the special investigation, were immediate action letters issued?
A.
As a result of the ongoing special investigation, a meeting was held with HL&P on December 28, 1979, to discuss tne then current status of the findings. As a result of that meeting, an immediate action letter dated
. December 31, 1979, was sent, halting complex concrete construction until certain actions were taken.
In adoitton, an immediate action letter was issued initially on April 17, 1980, and then revised on June 10, 1980, which addressed the areas of welding and welder qualifications. This action also was initiated due to investigative findings. This inmediate action letter documented the fact that the Licensee had halted ASME Code welding and other safety-related welding on April 11, 1980.
It was agreed that this halt would continue until existing welding procedures were confirmed to be adequate. Also, corrective action for audit deficiencies was to be completed prior to resumption of welding activities.
Q.
What other action was mandated by the Show Cause Order?
A.
Next, a review was directed to be performed upon existing data relative to Category I structural backfill and new data was to be developed to ensure the NRC that a test fill program would be established and, inter alia, that the existing backfill material was adequate. Based upon the investigation, it was decided that an overall reevaluation of the backfill program was indicated. Problems were identified in HL&P's te:t fill program, soil sampling program and record keeping relative to field activities.
In addition, soil penetration tests were performed improperly.
l l
l
, A review was also mandated as a result of the investigation findings in safety related work relative to welding and concrete placement activities. Deficiencies were identified in welding procedures, welder qualifications, and welding documentation. With respect to concrete placement activity, deficiencies were identified in the manner in which vibrators were used, preplacement inspection of reinforcing steel, the adequacy of concrete punch list cards, and quality assurance related
~ documentation.
The inspection team reviewed Brown & Root's brochure entitled "Implemenation of the Brown & Root Quality Assurance Program at the South Texas Project Job Site." As a result of that review, it was determined that the brochure put a disproportional emphasis upon project budget and efficiency considerations. HL&P was directed to require Brown & Root to rescind this brochure and replace it with a QA program brochure which properly emphasizes quality control considerations over construction cost.
Houston Lighting & Power was instructed to more clearly define stop l
l work authority, including implementation of a program to educate i
cognizant personnel with respect to the details of that authority. This requirement arose out of the investigation team's interviews with various quality control inspectors. Reviewing the various interviews with the inspectors, a genuine confusion was revealed with respect to who does or l
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Power was directed to develop and implement a more effective system to provide fcr the identification and the correction of root causes of nonconformi.g events.
In effect, this requirement mandated that HL&P incorporate a tracking system relative to nonconforming events. This requirement was deemed desirable in light of HL&P's prior inability to identify problem areas without NRC intervention.
Houston Lighting & Power was further directed to develop and implement a more effective system to provide for the control of field changes in order to document those changes and evaluate their impact upon the overall design of the plant. The investigation revealed that there was no clear line of demarcation between when a nonconforming report should be issued as contrasted to when a field request for engineering action should be written. Since HL&P or Brown & Root could not adequately identify when design changes were implemented by field requests for engineering action and accordingly could not factor the need for those changes into the overall design of the plants, this distinction was important.
As part and parcel to all of the above, it was evident to the inspection team that HL&P generally lacked an effective system of record controls and accordingly, it was directed to develop and implement such a system. Without such a system, an effective audit program cannot be carried on nor can problems effectively be identified and corrected.
. This problem further led the investigative team to direct HL&P to develop and implement an improved audit system.
Lastly, as a result of the. investigation relative to the backfill program, certain representations contained in the Applicant's FSAR were called into question. Accordingly, HL&P was directed to either /erify or correct, if necessary, the FSAR statements contained in Section 2.5.4 addressing the stability of subsurface materials.
Q.
Did HL&P respond to the Staff's April 30, 1980 Show Cause Order?
A.
Yes. By a document dated July 28, 1980, Houston Lighting &
Power set forth its response to the Staff's Order to Show Cause, together with corrective action taken. This docunent is identified as Staff Exhibit No. 48.
Q.
Is this panel prepared to testify as to the proposed corrective action by Houston Lighting & Power and the subsequent follow-up investigations performed by the NRC Staff to ensure that such corrective action had been implemented?
A.
No. A separate NRC panel, composed at Region IV I&E personnel was delegated 'the responsibility to follow up on the corrective action proposed to ensure it had been properly implemented. This will be the subject of a separate NRC panel.
Q.
Turning the panel's alteration to Issue A which has been previously set forth, and which says in essence, if viewed without regard to the remedial steps taken by HL&P following 79-19, would the record of HL&P's compliance with NRC requirements be sufficient to determine that HL&P does not have the necessary managerial competence or character to be l
. granted a license to operate the South Texas Project, has this panel fomed an opinion relative to Issue A?
A.
Yes.
Q.
What is that opinion?
A.
HL&P's record is not sufficiently poor to conclude it does not have the necessary managerial competence or character to be granted an operating license for the South Texas Project.
First, as summarized in 79-19, it appears that the lack of detailed involvement by HL&P in the total scope of the construction activities associated with the South Texas Project was one reason behind the problems found. This lack of involvement was the result of inexperience in nuclea construction, rather than irresponsible corporate management.
However, although the problems seemed pervasive with respect to quality assurance and quality control, no irreparable construction deficiencies were found in any of the construction already completed. Second, the scope of managerial effort required during the construction phase of a project of this magnitude is far greater than that required once the plant is in operation. Thus, although shortcomings in the management of HL&P relative to plant construction is relevant to, and probative of, how it will perfom under an operating license, such prior behavior should not be deteminative.
In addition, HL&P has shown a willingness to implement corrective action.
Accordingly, the Staff is of the opinion that HL&P's record prior to 79-19 is insufficient by itself to detemine that HL&P does not have the necessary managerial competence or character to be granted an operating license. Furthermore, assuming the remedial steps ordered to be taken by l
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the HRC, and the additional proposed corrective action suggested by the i
Applicant were implemented, the Staff believes that the South Texas Project would be in compliance with NRC requirements to be granted an operating 1icense.
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PROFESSIONAL QUALIFICATIONS OF D. W. HAYES OFFICE OF INSPECTION AND ENFORCEf1ENT, REGION III UNITED STATES NUCLEAR REGULATORY C0fillISSION fir. Hayes is Chief, Engineering Support Section I, Reactor Construction and Engineering Support Branch, Office of Inspection and Enforcement, Region III, Glen Ellyn, Illinois.
Mr. Hayes is. responsible for supervision of seven reactor inspectors in the conduct of-a prescribed inspection program at nuclear power facilities under construction within the eight midwestern states.
Mr. Hayes attended Illinois Institute of Technology under the Navy V-12 and ROTC programs, majoring in Electrical Engineering.
Prior Work History Mr. Hayes has been in his present or similar positions since Septs 1ber, 1973.
From August 1970 until September 1973, he was assigned and performed the duties of a reactor inspector, Division of Compliance, Region III, U.S.
Atomic Energy Commission (Office of Inspection and Enforcement, United States Nuclear Regulatory Commission). f1r. Hayes has conducted, or partici-pated in over 100 inspections of reactor facilities under construction, including special investigative inspections at North Anna Nuclear Power Facility, flidland Power Facility, fiarble Hill and the South Texas Project.
Prior to his employment with the Atomic Energy Commission, fir. Hayes worked for the Battelle Northwest Laboratory from January 1965 until August 1970, as a Senior Research Engineer and as a Control Engineer.
In addition, from 1948 until January 1965, fir. Hayes was employed by the General Electric Company in various positions relating to nuclear ece,y, including Reactor Engineer, fiaintenance fianager, Supervisor, Planning and Scheduling and flaintenance Foreman, flulticraft Crews.
PROFESSIONAL QUALIFICATIONS OF ROBERT EUGENE SHEWMAKEA OFFICE OF INSPECTION AND ENFORCEMENT, HEADQUARTERS UNITED STATES NUCLEAR REGULATORY COMMISSION At the present time Mr. Shewir.aker is a Senior Civil-Structural Engineer, Headquarters, Office of Inspection and Enforcement, Bethesda, Maryland and is attached to the Civision of Program Development and Appraisal.
At the time of his involvement in the South Texas Project he was the Senior Civil-Structural Engineer for the Division of Reactor Construction Inspection in the same Office.
In that capacity his responsibilities included development of the technical inspection requirements in the civil engineering discipline including the design and construction of reinforced and prestressed concrete structures, foun-dations, structural steel buildir.gs and structural testing and surveillance for'the nationwide program.
He also provided expert technical assistance to Regional offices and resident inspectors as well as various other Divisions within the Office of Inspection and Enforcement and other NRC Offices in the civil engineering discipline.
His responsibilities also included the supervision of task groups for special assign-cents related to construction inspection program development, trial impicmentation of program alternatives, or evaluation of generic problems.
For inspections and investigations that were technically complex or had wide potential significance in terms of safety, public interest or criminality he was responsible as an indi-vidual team member or a team leader / team liaison individual.
He was also responsible for the presentation of related actions before the Commission and Congressional staff.
Mr. Shewmaker received a Bachelor of Science degree from the University of Illinois in 1962, majoring in civil engineering.
In addition, Mr. Shewmaker received a Master of Science degree from the University of Illinois in 1963, majoring in structural engineering.
Professional Affiliations / Activities Mr. Shewmaker is a Registered Professional Civil Engineer in the State of Maryland and tne Commonwealth of Virginia and is a member of the American Society of Civil Engineers, the American Concrete Institute and the Prestressed Concrete Institute.
He has been a member of ACI Ccmmittee 349, Code Reauirements for Nucleae Safety Related Concrete Structurcs since its scope was revised in 1971. He has been a member of ACI 359, Code for Concrete Reactor Vessels and Containments, a joint committee with ASME of the Boiler and Pressure Vessel Code,Section III, Division 2 since it was organized in 1971. He was c member since 1967 of the earlier committee that preceded the formation of ACI 359. He served as a member of ACI 352, Joints and Connections in Monolithic Cancrete Structures during the mid 1970's. He is a member of ne University c' :llinois Bronze Tablet. Chi Epsilon, Sigma Tau, Tau Beta Pi and Sigma Xi scnolastic achievement honor societies.
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. Prior Work History Nov. 1980 - Present Senior Structural Eno_ineer. Procram Aporaisal Branch Division of Program Develcoment and Appraisal - For facilities under construction, appraise the application of the inspection and enforcement program to assure maximum benefit with regard to the protection of the public health and safety as well as the fulfillment of NRC requirements and recommend needed inspection and enforcement program changes to obtain such assurance with the available resources. (NRC) 1977 - 1980 Senior Civil-Structural Engineer, Division of Reactor Con-struction - Responsible for providing technical assistance to Headquarters and Regional offices in the field of civil engineering for facilities under construction or under major modi fica tion.
Responsible for special assignments relating to investigations and special inspections and the resolution of problems in the civil engineering discipline and the defense of the ensuing actions before the Commission and Congressional staff.
Responsible for coordination with technical counter-parts in the other NRC off, ices. (NRC) 1974 - 1977 Senior Structural Engineer, Headquarters Reactor Technical Assistance Branch,R0 - Responsible for providing expert advise and assistance to HQ and Regional staffs and manage-ment on items related to soil mechanics, foundations, civil and structural engineering during construction, inspection, testing and operation of nuclear facilities and coordination with other NRC offices.
(NRC/AEC) 1972 - 1974 Structural Engineer, Structural Engineering Branch, Directorate for Technical Review, Licensing.- Responsible for review and evaluation of SAR's with regard te structures and seismic analysis for nuclear facilities. Also provided technical assistance to Directorates of Licensing, of Reactor Operations and of Reactor Standards on matters in civil engineering. (AEC) 1971 - 1972 Structural Engineer, Structural Engineering Branch, Division of Reactor Standards. - Responsible for development of reactor standards, codes and criteria related to structural engineering, tsciew and evaluation of SAR's for structural safety and advising other divisions in related safety matters with specia-lized knowledge in reactor containments and auxiliary structures.
I (AEC) 1969 - 1971 Reactor Engineer (Structural) - Containment and Component Technology Branch, Division of Technical Review, Reactor Licensing. - Responsible for technical review of nuclear facilities.
(AEC) i 1
1966 - 1969 Senior Structural Engineer, Bechtel Corooration - Responsible for design of various concrete and steel structares with containment design group lead responsibility on a dual unit prestressed containment.
Responsibility for computer analyses.
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. dynamic analyses and design as well as field coordination from the design office.
1965 - 1966 Structural Engineer, ABAM Engineers - Responsible for design of prestressed concrete piers, bridges, buildings, and shell structures in high seismic areas using computer analyses.
Also involved in the production and erection of precast elements.
1963 - 1965 Lieutenant, USA, Corps of Engineers - Responsible as Project Engineer on construction projects in Panama and as an instruc-tor in military engineering, US Army School of the Americas, Canal Zone.
Responsible as engineering civic action team leader in Panama, Columbia & Dominican Repub ic for 146th Engineer Detachment, 8th Ssecial Forces Group.
PROFESSIONAL QUALIFICATIONS OF HARRY SHANNON PHILLIPS OFFICE OF INSPECTION AND ENFORCEtiENT, REGION IV UNITED STATES tlVCLEAR REGULATOP,Y COMtilSSION Mr. Phillips is the Resident Reactor Inspector, South Texas Project, Bay City, Texas.
In this position, he serves as Senior Resident Reactor Inspec-tor, responsible for coordinating all safety related inspections and acts as a liaison between the NRC region and site. He has held this position since Augus t, 1979.
fir. Phillips received a Bachelor of Science degree from the University of florth Alabama in 1962, majoring in chemistry and math.
In addition, tir. Phillins received a masters of science from liississippi State Univer-sity, '
71, majoring in materials engineering with a metallurgical option Prior i _ li story 1977 - L U.S. Nuclear Regulatory Commission, Region III, Glen Ellyn, Reactor Inspector (Projects).
Project Inspector for safety related construction activities (structural, mechanical, electrical, material) at several nuclear sites in several states. Duties included evaluation of management, organization, procedures and practices for compliance to rules, orders, and regulations. Perfonas evaluations and investigations related to issuance, suspension, modification and revocation of license.
Review and analyze company / corporate reports to deter-mine possible violations of the AEC act ofl954.
1972 - 1977 Defense Supply Agency (DSA), DEFENSE CONTRACT ADt1INIS-TRATION SERVICES OFFICE (DCAS0), Houston, Texas, Quality Assurance Division Chief.
Direct and administer Quality Assurance effort on 938 Department of Defense contracts at 353 contractor facilities located throughout Louisiana, and Southeast Texas. Supervise five subordinate branch supervisors and a staff of five plus 45 technical specialist.
1970 - 1972 DSA, Defense Contract Administration Services Region, l
Dallas, Texas, flaterials Engineer. Served as Staff
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Engineer and Advisor to Quality Assunnce Directorate on f
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. all Metallurgical / Mechanical Manufacturing Processes.
Performed engineering surveillance at all major con-tractors in Texas, Oklahoma, Arkansas, New flexico, and Louisiana on Military hardware.
1965 - 1975 Army Missile Command, Redstone Arsenal, Alabama, Solid State Chemist. Materials testing of all systems compo-nents used in Army Missile Systens. Worked in chemical, metallurgical and materials engineering capacity.
1963 - 1965 Post Engineers, Redstone Arsenal, Alabama. Corrosion Control Chemist.
Corrosion Control Program for 40 high/ low pressure Boiler Plants as well as efficiency s tudies.
1963 - 1965 Norton Abrasive Company, Huntsville, Alabama. Analytical Chemist, Quality Control of refractories manufactured in electric arc furnaces. All wet and instrumental tests required to control refractories, i
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APPENDIX A UNRESOLVED ITEMS AND OPEN ALLEGATIONS 1.
UNRESOLVED ITEMS 79-19 Tracking Report Page No.
Section No.
Subject 79-19-01 E.1. a 24 Licensee is correcting discrepancy Allegation 12 found in traceability of embedded steel plates 79-19-02 E.1.b 35 Licensee is correcting problems Allegation 10A found in the resolution of old NCRs on Storage /Mainten.
79-19-09 E.2.4 51 Need for additional controls to procedures addressing prepour, constr., curing of conc.
79-19-12 E.2.b.
54 Recheck on conc. transit trucks standing or in-transit w/o agitation 79-19-13 E.2.c.
57 Final inspections on completed placements not adequately controlled and up to date 79-19-14 E.2.c.
58 Sampling of pumped concrete and the lack of correlation program 79-19-15 E.2.c.
58 Conflict of personnel qualification req'ts for concrete placement (ANSI vs ASME) 79-19-17 E.2.c.
59 Need for systematic program to assure that training is given to all on spec / proc. revs.
79-19-19 E.3.b.
63 Compaction of upper part of last lift which may remain below Cat. I b1dgs; B&R literature 79-19-20 '
E.3.b.
63 Retest fill section comple'ted with excessive number of passes by double roll overlap 79-19-23 E.3.d.
65 Records of fill lifts vs. location in order to reconstruct fill placement procedure lacking 79-19-25 E.3.e.
66 Decrease in relative density (bulking) of compacted mat'l in wet state under vibration l
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Section No.
Subject
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79-19-26 E.3.e.
66 Discrepancies in min-max relative densities of materials used vs.
reported is SAR for liquefaction 79-19-29
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67 Attempt to correlate Std Penetration values to those from oversized, blunt spoon & nonconforming hammer
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79-19-30 E.3.f.
67 Boring 204, loose mat'l near base of fnd. mat of RCB Unit 2 - Aug. '77 l
washout area l
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69 Details of welder qualification procedures - work stoppage; root gap & backing ring in question 79-19-35 E.4.c.(3)(a) 73 Alignment procedures on S. Gen. B&C and Code stamp on lower 5. Gen.
supports considered now as b1dg.
79-19-36 E.4.c.(3)(b) 73 No Code inspection by ANI on weld
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now embedded in concrete on the fuel trans. tube 79-19-37 E.4.c.(3)(c) 74 Control of attachments on material post-weld heat treat. - lower SG supports & others 79-19-40 E.5.a.(2) 76 Test reports of ifquid penetrant l
examination not serialized and i
documentation of examinations inadeq.
79-19-42 E.5.c.
83 No training for QC personnel in liq.
pene. by flourescent mat'Is, processing & reading radiographs, visual AWS, recordkeeping I
79-19-43 E.7.a.
88 Procedure for NCRs lacks processing, i
approvals, feedback & records rctention details 79-19-44 E.7.c.
92 Review of documentation involved with Receiving documentation inr some vendors 79-19-45 E.7.c.
93 No procedures for trending FREAs and reviewing cumulative impact of all changes I
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, 4, Tracking Report Page No.
Section No.
Subject 79-19 46 E.7.c.
94 Unsatisfactory conditions found during ECs not being documented 79-19-49 E.8.c.
96 Aduit requirements of ANSI N45.2.12 not part of the POM contract 79-19-51 E.8.d.(3) 101 Audit B&R-27 followup not documented and procedure ta require this in general is being written 79-19-52 E.8.d.(3) 101 Question of whether all B&R procedures have been audited by B&R Houston. Design control not audited in 1978 79-19-54 E.9.b.(2) 105 Inadequate responses to surveillance findings in that bases for closecut lacking 79-19-58 E.3.a.
61 Resolution of why spec was revised from 12 to 18" lifts that was counter to the B&R cog. engr.
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. 2.
OPEN ALLEGATIONS Tracking Report Page No.
Section No._
Subject 79-19-04 E.1.b.
39 Vertical cracks in structural steel Allegation 12A clips in the boron injection room of RCB Unit 1, E1. 36' 40 Pipe sleeve weld defect 1/4" deep I' 79-19-05 E.1.b.
Allegation 13A Az. 300*, El. 8' in RC8 Unit I near work panel 15 79-19-06 E.1. b.
41 Classification of containment polar Allegation 14A crane 79-19-07 E.1.b.
42 Storage of elec./ mech penetrations and lack of understanding by warehouse electricians of Megger tests on motors 79-19-56 E.1.b.
43 Curing of the conc. intake structure
, Allegation 16A on which an NCR was written 79-19-57 E.1. b.
44 NRC told of voids in concrete with no Allegation 17A definita closecut or resolution 79-19-59 E.1.b.
46 Missing 3 horiz. rebars Allegation 19A
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