ML19347E411
| ML19347E411 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/23/1981 |
| From: | Crossman W, Randy Hall, Hubacek W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML16251A407 | List:
|
| References | |
| NUDOCS 8104270287 | |
| Download: ML19347E411 (70) | |
Text
5%
V 04/23/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of
)
HOUSTON LIGHTING AND POWER COMPANY, Docket Nos. 50-498 ET A1.
)
50-499
)
(South Texas Project, Units 1 & 2)
)
HRC STAFF TESTIMONY OF WILLIAM A. CROSSMAN, RAMON E. HALL, WILLIAM G. HUBACEK, H. SHANNON PHILLIPS, DAN PAUL TOMLINSON AND J. I TAPIA RELATIVE TO THE INSPECTION AND ENFORCEMENT ACTIVITY FOLLOWING THE SHOW CAUSE ORDER OF APP.IL 30,-1980 Q.
Will the panel members please state your name, employer, job title, and specifically, your responsibilities relative to the South Texas Project.
A.
My name is William A. Crossman and I a": Chief, Section 3, Reactor Projects Branch, Office of Inspection and Enforcement, Region IV, United States Nuc? ear Regulatory Commission.
I am responsible for the supervision of the project inspectors whose job it is to inspect nuclear power plants under construction in Region IV, including the South Texas Project.
My name is Ramon E. Hall and I am Chief, Systems and Technical Section, Office of Inspection and Enforcement, Region IV, United States Nuclear Regulatory Commission.
I am responsible for the supervision of f
the engineering specialist inspectors who inspect nuclear power plants within Region IV, including the South Texas Project.
810.4270%h i
,- c i
a<
d-
,4
, )
My name is William G. Hubacek and I am a Reactor Inspector, Section 3, Reactor Projects Branch, Region IV, Office of Inspection and Enforcement, United States Nuclear Regulatory Commission.
I am responsible for oroject inspection of nuclear power plant facilities under construction within Region IV, including the South Texas Project.
My name is H. Shannon Phillips and I have been the Resider.t Reactor 1r.pector at the South Texas Project since August 26, 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 investigative team, investigating allegations concerning lack of QC management support, intimidatian and harassment of quality control inspectors and the assessment of the effectiveness of the quality assurance / quality control program at the South Texas Project. This investigative effort resulted in the issuance of Staff Report 50-498/79-19 and 50-499/79-19 (79-19), the Staff's Order to Show Cause, dated April 30, 1980, a Notice of Violation and a Proposed Imposition of Civil Penalty.
My name is Dan Paul Tomlinson and I am a Reactor Inspector, Engineering and Materials Section, Office of Inspection and Enforcement, Region IV, United States Nuclear Regulatory Commission.
In this position, I plan, perform and report routine inspections and assist with or perform special investigations as required.
I am responsible for project inspection of nuclear power facilities under construction in Region IV, including the South Texas Project.
My name is J. I. Tapia and I am a Reactor Inspector, Engineering and Materials Section, Office of Inspection and Enforcement, Region IV,
c O
, United States fluclear Regulatory Commission.
In this position, I am responsible for project inspection of nuclear power facilities within Region IV, including the South Texas Project.
Q.
Has the panel prepared statements of educational and professional qualifications?
A.
Yes.
Q.
Are the statements attached to this testimony?
A.
Yes.
Q.
What is the purpose of the panel's testimony?
A.
The purpose of this panel's testimony is to report upon the results of fiRC investigations and inspections following the issuance of I&E report 79-19. This testimony will address two broad areas:
(1) the current status of HL&P's corrective action relative to the enforcement actions resulting from I&E report 79-19 and (2) construction activity at the South Texas Project since the issuance of I&E Report 79-19, as reflected in the Staff's inspection and enforcement reports on the Project. Specifically, this panel's testimony will respond to Board Issues B, E, and, in part, D.
These issues state:
Issue B.
Has HL&P taken suf'icient remedial steps to provide assurance that it 4 ra has the managerial competence and character to operate STP safely?
Issue E.
Is there reasonable assurance that the structures now in place at the STP (referred to in Sections V(2) and (3) of the Or'ler to Show Cause) are in conformity with the construction permits and the provisions of Commission regulations? If noi.,
has HL&P taken steps to assure that such structures are repaired or replaced as necessary to meet such requirements?
Issue D.
In light of HL&P's prior performance in the construction of the STP as reflected, in part, i
e-
, in the Notice of Violation and Order to Show Cause dated April 30, 1980 and HL&P's responses thereto (filirgs of May 23, 1980 and July 28,1980),and actions taken pursuant thereto, do the current HL&P and Brown & Root (B&R) construction QA/QC organizations and practices meet the requirements of 10 C.F.R. Part 50, Appendix B; and is there reasonable assurance that they will be implemented so that construction of STP can be completed in conformance with the construction permits and other applicable requirements?
In addition, the panel's testimony impacts to varying degrees on the other issues currently before this Board. Specifically, to the extent this testimony evidences a course of conduct by the Applicant from which corporate character or competence can be inferred, it will be relevant to those issues.
Q.
Will the panel please explain the inspection and enforcement responsibility of Region IV relative to the South Texas Project since 79-19?
A.
Yes. Region IV is responsible for the routine, periodic inspections performed by the NRC at the South Texas Project.
In addition, Region IV has been delegated the responsibility to follow-up the deficiencies identified in I&E Report 79-19 to assure that the corrective actions committed to by HL&P were implemented or are in the process of being implemented. This follow-up inspection activity has been performed in addition to, and in conjunction with, the routine inspections which Region IV would otherwise normally perform.
Q.
Turning the Panel's attention to the first of the two broad areas it will address, will the panel please summarize the NRC inspection and enforcement history at the South Texas Project since April 30, 1980?
a-e-
.,m---
,..-. e
. A.
Yes, in 1980 the NRC performed thirty-eight (38) inspections or investigations at the South Texas Project. During these inspections or investigations,10 items of noncompliance were identified and Notices of Violations were issued. As of April 13, 1981, seven (7) inspections or investigations were completed during 1981, resulting in one item of noncompliance. Each of the ite,s of noncompliance cited since 79-19 are described in a list attac'hed to this testimony as Appendix A.
Q.
Are these latest items of noncompliance similar to those items HL&P has been cited for in the past?
A.
Yes.
Of the ten items of noncompliance, four (4) were for HL&P's failure to follow procdedures, four (4) were for HL&P's failure to respond to various requirements in a timely manner, one (1) was for failure to develop appropriate procedures, and one (1) was for HL&P's failure to assure that purchased material conformed to procurement documents.
Q.
Would the Panel please identify the various inspection and enforcement reports issued since 79-19?
A.
Yes. Of the forty-five (45) Inspection and Enforcement reports issued subsequent to 79-19, four (4) have been identified and marked as Staff Exhibits in previous testimony (I&E Reports 80-06, 80-07, 80-24 and 80-25 have been previously identified and marked as Staff Exhibit Nos.
31, 35, 40, and 45, respectively), the remaining Inspection and Enforcement reports issued subsequent to 79-19, through April 13, 1981, are identified and marked as Staff Exhibit Nos., as follows:
I&E Report Exhibit No.
I&E Report Exhibit No.
80-01 49 80-02 50
, 80-03 51 80-04 52 80-05 53 80-08 54 80-09 55 80-10 56 80-11 57 80-12 58 80-13 59 80-14 60 80-15 61 80-16 62 80-17 63 80-18 64 80-19 65 80-20 66 80-21 67 80-22 68 80-23 69 80-26 70 80-27 71 80-28 72 80-29 73 80-30 74 80-31 75 80-32 76 80-33 77 80-34 78 I
80-35 79 80-36 80 80-37 81 80-38 82 81-01 83 81-02 84 81-03 85 81-04 8C l
81-05 87 81-06 88 81-08 89 These reports will be referred to by I&E Report number and/or Staff Exhibit number throughout the balance of this testimony.
l l
Q.
Next, turning the panel's attention to the current status of i
HL&P's corrective actions relative to the dcTiciencies identified in I&E Report 79-19; will the panel please first reference each iten of l
i noncompliance; summarize the corrective action HL&P committed to in its response of May 23, 1980, previously identified as Staff Exhibit No. 47; and then state the findings and conclusions of the fiRC follow-up inspection which evaluated the adaquacy of the implementation of HL&P's corrective action?
A.
Yes. With respect to Item of Noncompliance No.1, HL&P stated in its May 23, 1980 response that this item,.c ribing incidents of intimidation and harassment of quality control personnel as evidence that the quality assurance function at the South Texas Project lacked
\\
sufficient organizational authority and independence, could neither be confirmed nor denied since the NRC findings were based upon information which did not disclose names of persons, specific places and dates.
However, HL&P went on to state that its review suggested that such incidents of intimidation and harassment probably did occur. Similarly, HL&P acknowledged that its QA/QC program, as implemented, was inadequate.
Among the many commitments HL&P made in an effort to upgrade its QA/QC program, were an extensive polling of all site personnel in order to pinpoint the source or sources of perceived production pressures; an evaluation and revision of the in-place program; an increased visibility of both Brown & Root and HL&P management at the project site, various meetings at both manage'1ent and construction levels to emphasize the role of QA/QC in construction activity; an increase in the site QA/QC staffing l
level; and various measures to increase feedback from inspectors to high J
l l
level management.
The status of the various corrective actions relative to the QA/QC program was the subject of two separate NRC reviews.
John Gilray, NRC I
l I
, Quality Assurance Engineer, reviewed for adequacy HL&P's revised QA/QC program for construction. Mr. Gilray will offer separate testimony on the issue of whether HL&P's written program confoms to 10 C.F.R. 50, Appendix B, and thus, this issue will not be addressed here.
In addition, an NRC inspection, referenced as I&E Report 80-25 and previously identified as Staff Exhibit No. 45, perfomed during September, 1980 evaluated the effectiveness of program implementation.
As to this second review, Resident Reactor Inspector H. Shannon Phillips accomplished the follow-up inspection by asking a battery of questions of 29 quality control inspectors and two quality assurance record clerks.
The personnel interviewed were asked questions relative to production pressures, management support, harassment, threats, intimidation, freedom to identify nonconformances, stop work authority, resolution of safety related problems, and falsification of QA/QC records. The resident reactor inspector found the overall answers to such questions were very positive in that previously identified conditions which resulted in Item of Noncompliance No. 1, had been corrected and no recurring trends were evident during this review.
Q.
Did you find any evidence that it was still easier for the QC inspectors to sign off on quality control documents, rather than be confronted by their supervisors and/or construction management?
A.
No.
As a result of the questioning just mentioned, and the review conducted in connection with Show Cause Items 1 and 5, no evidence was found that it was still easier for the QC inspectors to sign off on quality control documents, rather than be confronted by their supervisors and/or construction management.
l
e 4
. Q.
Did you find any evidence to contradict the conclusion of I&E Report 79-19 that there was no incident of major safety significance found which resulted from this practice of quality control inspectors?
A.
No.
Q.
Please continue to address each item of noncompliance.
A.
With respect to Item of Noncompliance No. 2, HL&P stated in its May 23, 1980 response that this Item of Honcompliance was substantiated.
Essantially, the item of noncompliance stated that although a test fill program established that 12 passes with compaction equipment would be required for placement of an 18 inch maximum lift thickness, construction procedures required only eight passes with such equipment.
HL&P correctly noted that this Item of Noncompliance is inseparably linked to Show Cause Item No. 2 and any response must be viewed in light of HL&P's response to Show Cause Item No. 2.
Similarly, follow-up inspections have been performed with those inspections relative to Show Cause Item 2.
HL&P has reviewed the test results obtained during backfill placement in order to substantiate the acceptability of construction procedures.
In addition, the effect of the construction procedures on the adequacy of the existing backfill has been evaluated as part of the response to Show Cause Items 2(c) and 2(d).
The status of this cor,ective action was the subject of two ;&E l
inspections. By an I&E inspection conducted between June 23 and 26, 1980, referenced as I&E Report 80-17 and previously identified as Staff Exhibit No. 63, Brown & Root Technical Reference Document " Test Program for Compaction of Category I Structural Backfill" dated June 2,1980, was 1
reviewed.
The purpose of this test program was to provide assurance that i
+
. the construction methods defined previously were sufficient to produce a backfill which satisfied PSAR commitments of 80% relative density throughout each layer. Since, as of the 80-17 report date, the test fill program was not yet complete, and further, since the soil boring and test program was still being evaluated to support a response to Show Cause Item No. 2, Item of Noncompliance No. 2 needed to be followed up in a subsequent inspection. That follow-up inspection occurred during October,1980, and was reported in I&E Report 80-30, previously identified as Staff Exhibit No. 74. HL&P's responses to Show Cause Order Items 2(a) and 2(e), previously closed out in I&E Report 80-24, were evaluated by NRC Inspector J. I. Tapia in light of Brown & Root's " Test Program For Compaction of Category I Structural Backfill" and, based upon r
a review of this document and prior responses, Item of Noncompliance No.
2 was considered closed. The NRC inspector concluded that HL&P's failure to require twelve (12) passes with compaction equipment prior to the start of end process density testing was of no safety significance. This conclusion is based upon the fact that the fill test program showed eight (8) passes would be an appropriate starting point for end process testing, since typically that number of passes produced the requisite density.
With respect to Item of Noncompliance No. 3, HL&P admitted in its May 23, 1980 filing that notwithstanding the fact that test apparatus for measuring relative soil density was out of order for a period of time, plant backfill continued to be placed and several sets of four sand cone density tests were completed without the associated relative density test being performed.
In response, HL&P purchased a backup vibratory head, a l
, component part to equipment for measuring relative density and, more importantly, issued instructions, dated February 1,1980, clarifying the requirements relative to promptly documenting nonconfomig conditions.
During an I&E Inspection conducted between June 23 and 26,1980, referenced as I&E Report 80-17 and previously identified as Staff Exhibit No. 63, NRC Inspector J. I. Tapia reviewed HL&P's commitments and.
determined the status of implementation.
It was verified that a backup vibratory head and a spare mold for measuring relative density had been procured and both instruments were available on site.
In addition, Brown
& Root's instruction letter, dated February 1,1980, was reviewed relative to clarifying subcontractor responsibilities concerning identification and repordng of nonconforming conditions.
It was verified that all cognizant employees on site had reviewed these instructions.
Q.
What safety significance is there in the fact that no relative density test was performed between November 17, 1979 and January 7, 1980?
A.
None, it was determined that during the period the testing equipnent was inoperative, samples were taken to be tested at a later time when the vibratory head became functional. Upon obtaining the necessary equipment in January of 1980, the saved samples were tested and found adequate. This is technically proper. Consequently, although HL&P's failure to promptly correct the broken equipment was a violation, the failure of HL&P to perform this in-process construction test each day construction progressed was of no safety significance.
Q.
Is there any other significance to the fact that no relative density test was performed between November 17, 1979 and January 7, 1980.
. A.
Yes. One of the situations which the NRC is continually watchful of is the occurrence of false statements in various filings from Applicants.
False statements may or may not cause concern.
Upon investigation, such statements may be found to be innocent oversights or intentional misrepresentations. Similarly, such statements may be either critical or immaterial in regard to their impact upon plant safety. Any evaluation with respect to false statements must be made in the context of how they were made and submitted to the NRC and the safety significance of these statements.
In any event, a false statement must be evaluated based upon its affect on the NRC's confidence in the Applicant's reliability and capacity for truthfulness.
During the course of the special investigation, one of the areas chosen for particular audit was that of engineered fill placement. As a result of facts gathered with respect to in-process control of soil foundation material, the truthfulness of two sections of the FSAR were called into question. These concerns gave rise to Show Cause Iten No.
10; specifically, HL&P was directed to verify or correct, if necessary, the FSAR statements contained in Section 2.5.4, stability of subsurface materials, especially Section 2.5.4, excavations and backfill.
With respect to the particular FSAR statements, no information was gathered by the NRC to indicate that the statement was made as a deliberate attempt to deceive the NRC. The investigation found that the statements were made based upon construction specifications that the designer had prepared for the contractors to implement.
In this instance, what was done in the field was not documented. HL&P could not establish that the specifications had been followed, or that there were
. no instances of safety significant deviations from the specification. As a result of this assessment, the NRC, as it has done in the past, permitted HL&P to correct or revise the FSAR statements. In FSAR amendment 12, submitted September 12,1980 HL&P amended its FSAR statements to conform to what actually occurred.
It was in this context that Item 10 appeared in the Order to Show Cause. Currently, the NRC is satisfied that the revisions made to the FSAR on.these two items now reflect what was completed in the field during construction of engineered backfill.
Q.
Since the Show Cause Order, have other instances of false statements or document falsification been called to the attention of the NRC?
A.
Yes, two instances of document falsification have been alleged and substantiated by the NRC.
Q.
Please explain.
A.
On May 6,1980, Resident Reactor Inspector, H. Shannon Phillips, was contacted by an individual who alleged that Brown & Root management j
altered construction records, changed draft nonconformance reports, promoted unqualified personnel, and were intimidating quality control inspectors. Specifcally, the individual contacting the resident inspector indicated that a fabrication checklist containing a " hold i
point" was not inspected as required and yet the record was falsified to o
l indicate that the inspect; n had in fact occurred.
In addition, it was l
alleged a draft nonconformance report written by a QC inspector on this matter was rewritten in November,1979, by the site QA manager and/or his staff and pertinent information was purposely deleted.
It was also l
l
. alleged that a QA subcontractor inspector received a fomal warning of improper inspection practices and that this warning was removed from his personnel file without proper authorization.
Q.
How were these allegations investigated?
A.
In June,1980, NRC investigators R. K. Herr, and D. D. Driskill, traveled to the South Texas site and interviewed the various personnel involved, as well as reviewing the alleged falsified records. Tnis investigation resulted in I&E Report 80-14, identified as Staff Exhibit No. 60.
With respect to the falsified fabrication checklist, the individual 6
allegedly falsifying this docunent admitted he did not inspect the " hold point" yet initialed and dated the document. With respect to the rewriting of a draft nonconfomance report, it was detemined that the first draft of the nonconfomance report identified both the passing of a
" hold point" by PDM welders and the backdating of the PDM by the individual nentioned in the first allegation. The subsequent Brown &
Rc,ot nonconfomance report, only reflected the passing of a " hold point" as a nonconfomance and does not address the backdating previously mentioned. Upon investigation, Brown & Root explained it considered the matter of backdating an internal Brown & Root personnel matter and therefore omitted mention of this incident in its fort.cl nonconformance report.
Next, with respect to a formal warning being improperly removed from a personnel file, this allegation was not substantiated. Apparently, the individual who backdated the document described above received a written warning from his supervisor, for failure to conduct proper inspections.
. 1 Tha warning stated that the individual was to " exercise strong care in making accurate and complete surveillance reports" in the future. This warning was contained in the Brown & Root personnel folder for this individual.
Q.
What further action, if any, was taken by the fiRC?
A.
The f1RC brought this matter to the attention of HL&& and Brown and Root.
In addition, as document falsification is potentia'ly a criminal act, this matter was referred to the Justice Departcv.nt for enforcement considerations. The Justice Department has subsequently declined to prosecute.
Q.
What is the current job status of the individual who admitted to falsifying documents?
A.
Shortly after receiving I&E Report 80-14, this individual was terminated.
Q.
What other instances of document falsification or false statements were called to the attention of the f1RC?
A.
On July 22, 1980, the 11RC Resident Reactor Inspector, H. Shannon Phillips, was contacted by an individual who alleged that Brown & Root maintenance records had been falsified. On this date, an individual entered the resident reactor inspector's office and explained that over the past two months, two employees had been terminated by Brown & Root for falsification of records. This individual explained that recently a foreman was identified as falsifying records; however, the individual was not terminated because he had some " stroke" with higher supervision / management.
Specifically, this person alleged that this forenan falsified permanent plant maintenance (PPM) records e entified as
. Cards fio. M-1018BM-10198 on June 24, 1980, wherein the equipment was not inspected as required and yet the records were falsified to indicate the inspection had occurred. During this same investigation, various individuals indicated that this foreman instructed them that the following policy was in effect:
(a) To discontinue reporting discrepancies on any items which have previously been reported.
(b) flot to inspect the interiors of vessels during integrity checks.
(c) flot to write up discrepancies on the storage area.
(d) flot to write up discrepancies on equipment that is dusty.
On August 4, 1980, the foreman accused was interviewed and executed a signed statement.
'his individual admitted to falsifying maintenance card M-10183 concerning a vacuum degasifier pump when he signed off the maintenance card indicating he rotated the shaft of the pump. He went on to indicate during the interview that he did not rotate that shaft.
This foreman also admitted that during a training inspection, he ordered a subordinate to sign off a couple of maintenance cards on equipment that they could ?
inspect due to the fact the equipment was located inside a locked building. The foreman offered the explanation that someone (identification unknown) in upper management told him not to report discrepancies if the discrepancies had been previously reported, adding that he passed this word along to his men. He also stated that he told his men not to report discrepancies in the storage area, that it was not necessary to inspect the interior of vessels during integrity checks on each occasion, and not to report discrepancies on dirty equipment. This
. foreman further indicated that he told his men to inspect some equipment by memory, explaining that the maintenance cards could not always be located in the PPM oft ice when the inspections were required. This foreman stated that his supervisors confronted him concerning the falsification of maintenance records and told him to make a late entry correction on maintenance cards and that this would take care of the falsification.
The supervisors also told this foreman not to make incorrect entries on maintenance cards in the future. The findings and conclusions of this investigation are in I&E Report 80-21.
Q.
What further action, if any, was taken by the NRC?
A.
The NRC brought this matter to the attention of HL&P and Brown and Root.
In the course of HL&P's internal review following 79-19, the supervisor who the person making this allegatich identified as fostering this behavior was terminated and individual K in I&E Report 80-21 quit soon thereafter.
In addition, as document falsification is potentially a criminal act, this matter was referred to the Justice Department for enforcement considerations. The Justice Department has subsequently declined to prosecute.
Q. Will the panel continue to address each Item of Noncompliance, HL&P's corrective action, and the NRC follow-up inspections?
A.
Yes. With respect to Item of Noncompliance No. 4, HL&P in its May 23, 1980 response admitted that no instruction was given as to the depths below the backfill lift surface soil density was to be tested, or the specific location for conducting such tests. This was left to the discretion of the inspector. HL&P committed to revising its structural backfill procedures in order to identify criteria for testing depth and l
l
, location.
In I&E Report 80-17, identified as Staff Exhibit No. 63, NRC Inspector J. I. Tapia reviewed the changes affected and discussed with HL&P the adequacy of its response. The NRC inspector determined that the changes in the procedures adequately resolved the noncompliance regarding depth and location of in-place testing of granular backfill in all areas except the very top layer. Accordingly, HL&P procedures relating to the sampling of the top backfill layer were to be revised to incorporate the requirements at a later date, but in any event, before work begins on t'le top layer.
Final resolution of this item was closed out in Inspection 80-24.
With respect to Item of Noncompliance No. 5, HL&P admitted, in its response of May 23, 1980, that procedures did not require documentation of the specific number of passes with compaction equipment and the actual loose lift thickness in inches during backfill operations. This was another example cited in 79-19 af HL&P's failure to adequately document its in-process procedures.
In I&E Report. 80-19 conducted between July 22 and 24, 1980, and identified as Staff Exhibit No. 65, this item was the subject of a follow-up inspection. NRC Inspector J. I. Tapia reviewed changes to procedures relative to requirements for recording soil loose lift thickness and the number of passes with compaction equipment.
Upon reviewing these documents for content, it was determined that QA records now require documentation of loose lift thickness and number of roller passes.
In addition, the specific roller patterri to be used is also defined. Based upon this review, the NRC :nspector determined that the changes affected in the procedures resolved this Item of Noncompliance.
19 -
With respect to item of Noncompliance No. 6, HL&P admitted in its that no effective program had been implemented response of May 23, 1980, for the review and analysis of nonconformance reports, examination checks / inspection books, or field requests for engineering action on a continuing basis. HL&P in its May 23, 1980 response stated that three documents have been or will be developed which delegate authority for the proper nandling of nonconformance reports, field requests for engineering These documents outline action and examination checks / inspection books.
the proper procedure for performing trend analysis on such events and for reviewing the results of that analysis.
In the course of an I&E inspection conducted during September,1980, referenced as I&E Report 80-25 and identified as Staff Exhibit No. 45, Resident Reactor Inspector H. Shannon Phillips had cause to review the The resident reactor inspector reviewed status of the corrective action.
three documents which demonstrated HL&P was in full compliance;
" Procedure For Trending and Reporting of FREAs, NCRs, and SDRs,"
"Honconformances Trend Analysis," " Engineering Requirements for the A review of the Trend Tracking and Trending of FREAs, NCRs, and SDRs."
31, 1980, indicated that all Analysis Report for the period ending July The resident reactor inspector FREAs, NCRs, and SDRs were tracked.
considered this matter closed based upon the adequacy of the above documents and proper tracking.
With respect to Item of Noncompliance No. 7. HL&P, in its response admitted that concrete placement activities continue to of May 23, 1980, Such be a problem, after being previously identified and not corrected.
problems included improper consolidation practices, poor lighting, lack
m
. of adequate numbers of quality control proplacement inspectors, production pressures and excessive lift thicknesses.
In reply, HL&P committed to supply enough quality control inspectors to assure that preplacement inspections would be conducted in a thorough manner.
Procedures were revised to require the completion of the preplacement inspection by QC inspectors,and their subsequent signing off of pour cards, prior to the delivery of concrete. This is viewed as an effort to reduce construction schedule pressures.
In addition, lighting was improved, supervision and training were increased, and both pre-and post-placement meetings were to be held to discuss placement activity.
Ir I&E Reports 80-19 and 80-24, identified as Staff Exhibit Nos. 65 and 40, respectively, NRC Inspector J. I. Tapia, reviewed the newly issued Brown & Root quality concrete construction procedure which was issued in response to Item of Noncompliance No. 7.
The new procedure describes the methods and requirements for all activities involved with concrete construction.
Improper consolidation and excessive lift thicknesses are addressed by specifying the maximum limit for deposition and definition of proper vibrating techniques. Documentation relative to the retraining of 188 persons was reviewed.
Formal requirements for both pre-and post-placement meetings for all safety related concrete placements were reviewed. The problem of inadequate lighting was addressed and implementation was verified.
It was further verified that i
the problem of last minute construction activity causing undue pressure on quality control inspectors was resolved by revising the procedures for concrete placement to require the completion of the preplacement inspection and the subsequent " sign off" of the pour cards by the QC
, f rspectors as a prerequisite to the delivery of concrete for placement.
In addition, new procedures define the quality control inspectors authority to hold work when he believes that the quality of work being accomplished is unacceptable.
The NRC sought clarification from HL&P relative to its commitment to provide additional QC inspectors. HL&P explained that it committed to increesing the relative number of preplacement QC inspectors based on construction activity, but did not mean to commit to an increase in the absolute nunbers of QC inspectors.
Pending receipt of this clarification this item was not closed out.
Following receipt of this clarification, the NRC inspector considered HL&P's corrective actions adequate and closed this matter.
Item of Noncompliance No. 8 cited various unqualified civil and concrete quality control inspectors. HL&P substantially admitted to this item of Noncompliance in its May 24, 1980, response.
In its response to this Item, HL&P committed to verify the education and job experience of all Brown & Root and Pittsburgh Testing Laboratory inspectors During an I&E Inspection coriducted August and September, 1980, I&E Report 80-24, identified as Staff Exhibit No. 40, the records of the education and job experience of various quality control inspectors were reviewed and verified. The NRC inspector verified that a review of the qualifications and certifications of all civil QC personnel was conducted by HL&P. As of September 12, 1980, HL&P had retrained and qualified 23 concrete QC inspectors.
In addition, new procedures were issued outlining the process to be followed for verifying a new employee's educational background and prior work experience.
In addition to reviewing this new
[
. procedure, the NRC inspector randomly selected one QC inspector's file and verified that the three years of college education listed on his form had been confirmed by receipt of an official transcript from the listed college. HL&P's review of all civil QC personnel and the revised procedures relative to the substantiation of new employee's education and work background resolves this Item of Noncompliance.
Item of Noncompliance No. 9 cited HL&P for its failure to control documents in that a QA manual did not include interim changes or the latest document change notices. HL&P admitted to this Item in its May 23, 1980, response. HL&P represented in its reply that all controlled documents were revised and updated.
Further, to avoid further Items of Noncompliance in this area, an administration technician had been added to the site HL&P OA staff, to be responsible for document control.
During an I&E inspection conducted in September,1980, Resident Reactor Inspector H. Shannon Phillips verified that (a) all documents on file in the HL&P office were revised and up to date, (b) a secondary review was made by HL&P quality engineering staff, and (c) an l
administrative technician had been added to the staff.
Document control of quality assurance procedures previously controlled by the Brown & Root home office, was transferred to the site. These reviews and actions were l
documented in HL&P office memoranda, dated September 11 eid 12,1980; accordingly, the NRC inspector considered this matter closed.
In addition HL&P no longer uses interim changes as more fully explained in response to Item of Noncompliance No. 12.
With respect to Item of Noncompliance No.10, HL&P admitted in its May 23, 1980, response that welding operations were being conducted in an
. environment not controlled to protect against contamination and adverse atmospheric conditions.
Essentially, sand blasting was occurring in a work area immediately adjacent to welding activity and consequently the airborne sand from the blasting was spoiling the welds. HLSP committed to rewriting work procedures to require protection against contamination from rain, snow, and airborne particles during welding operations.
In I&E Report 80-24, identified as Staff Exhibit No. 40 Reactor Inspector Dan Tomlinson reviewed the revised procedures and verified that adequate requirements had been implemented for maintaining cleanliness during the welding process. A training session for all welders and welding supervisors instructing them in the revised procedures was conducted on February 15, 1980.
In light of the above, this item was considered closed.
Items of Noncompliance Nos. 11a and 11b cited HL&P for its failure to properly control radiography and to properly interpret radiographic film quality. HL&P admitted to both these Items of Noncompliance in its May 23, 1980, response. With respect to corrective action, HL&P committed to reviewing all radiographic film to identify discrepancies, revising radiograph film processing procedures to clarify film processing techniques, retraining and certification of all NDE personnel, as well as a revision of the requirements for recording film conditions.
In I&E Report R0-38, identified as Staff Exhibit No. 82, conducted between December 15 and 18, 1980, NRC Inspector Dan Tomlinson addressed HL&P's various corrective actions. The NRC inspector randomly selected radiographs from six essential cooling water (ECW) piping joints nondestructively examined after October 6, 1980, for a thorough review.
, The purpose of this review was to assure compliance with the ASitE Boiler and Pressure Vessel Code req '.ements. A total of 48 radiographs were reviewed for shooting technique, proof of coverage, penetrameter selection and placemer
.lm densities, film identification, image sensitivity and adequacy of developing technique.
Each film was individually evaluated using Code acceptance standards and the reactor inspector's results were then compared to the corresponding Applicant interpretation sheets.
For the sample of film examined, all characteristics and evaluations appeared to be in compliance with applicable code requirements. These findings formed the basis for the inspector's conclusion that HL&P was currently properly controlling radiography and properly interpreting radiographic film weld quality.
HL&P further admitted to Item of Noncompliance No. 11(c), citing the Applicant for its failure to control liquid penetrant examinations.
In its May 23, 1980, response, HL&P stated that its investigation leads it to believe that this violation was an isolated incident; however, HL&P went on to state that in (rder to address the problem in an orderly manner, all liquid penetrant examinations at the site were suspended by quality assurance until corrective measures could be taken and all persons conducting liquid penetrant examinations were given additional l
training in inspection techniques, procedures and criteria.
During an inspection resulting in I&E Report 80-24, identified as Staff Exhibit No.
40, NRC Inspector Dan Tomlinson verified that all NDE personnel had been retrained in the requirements of inspection procedures with an emphasis i
upon the importance of adhering to such requirements. Training was followed by a reexamination and recertification of all liquid penetrant t
I L
, inspection personnel.
In consideration of the above action, this matter was considered closed.
HL&P admitted to Item of Noncompliance No.12, which again cited its failure to follow procedures, this time in the context of the use of interim procedures. Essentially, procedures governing an NDE activity were modified by an interim change which was to expire 60 days from its issuance. Nonetheless, this interim change was being used 4 months beyond its expiration date.
In its response, HL&P committed to reviewing all outstanding interim changes and to remove : hose changes from issuance.
In addition, HL&P decided to eliminate the use of interim changes. During the inspection which led to I&E Report 80-24, identified as Staff Exhibit No. 40, NRC InspectJr Dan Tomlinson inspected HL&F's revised procedures.
It was verified that the use of interim changes had been eliminated and all interim changes in existence were recalled.
Future changes will be made by way of permanent procedural revisions which require internal review prior to issuance, rather than through the use of interim changes.
In response to Item of Noncompliance No. 13, HL&P affirmed that it failed to take corrective action when Cadwelders needed requalification.
According to the FSAR and Brown & Root specifications, any Cadwelder accumulating 2 unacceptable production splices within a unit of 15 consecutive splices was to be requalified.
In violation of this FSAR o
requirement 5 Cadwelders continued production without requalification after accumulating 2 visually unacceptable splices. HL&P revised specification to provide that when a splicer accumulates 2 unacceptable tensile (not visual) tests within a unit of 15 consecutive test samples,
& he shall not be permitted to continue slicing until he has requalified.
In addition, it was verified that quality control inspectors were empowered to stop work in progress until observed discrepancies are resolved. The issuance of Quality Construction Procedure No.
A040KPCCP-25 authorized the QC inspector to stop work in progress until the nonconforming conditions was resolved by a project site engineer.
In addition, this procedure requires that all such conditions and subsequent engineering dispositions be documented on nonconformance reports and that the quality control inspectors are to be made aware of the disposition of the nonconformance report. All of the above corrective actions were verified in I&E Report 80-24, previously identified as Staff Exhibit No.
40, by NRC Inspector J. I. Tapia and accordingly this item was closed.
Item of Noncompliance No. 14 cited HL&P f:r its failure to take corrective action in a reasonable time and for management's failure to resolve problems in a timely fashion.
HL&P admitted to the truth of this item in its May 23, 1980 response.
In this response, HL&P developed and approved new audit procedure containing a paragraph entitled " Failure To Respond" providing that if an acceptable response to an identified deficiency is not received within 30 days following identification, a j
letter shall be prepared, with copies to senior QA managenent and the i
group vice president. Corrective action would then be taken at that level.
l Resident Reactor Inspector H. Shannon Phillips reviewed this item l
and documented his inspection effort in I&E Report 80-18, identified as Staff Exhibit No. 64. Mr. Phillips identified a similar problem during this inspection. There was still a lack of involvement by management in l
l l
, assuring audit findings were being corrected. Consequently, a Notice of Violation was issued. The resident reactor inspector again reviewed this matter during his September inspection, as documented in I&E Report 80-25 and identified as Staff Exhibit No. 45. The resident reactor inspector reviewed and evaluated HL&P's plan relative to implementation of its corrective action in such areas as; (a) whether PSAR commitments were translated into specific procedures, (b) whether impasses were usually escalated to the QA manager and/or STP project QA manager, (c) the status of site surveillances SIS-12, SIS-18, and SIS-26, (d) the consequences of the audited group's failure to respond, and (e) whether the " root causes" of impasses were caused by the failure to reflect project requirements in workable procedures.
Based upon the review and evaluation of the management actions described above, the resident reactor inspector concluded this item was adequately resolved and closed this matter.
With respect to Item of Noncompliance No. 15, in its May 23, 1980, response, HL&P admitted that unsatisfactory conditions identified during HL&P surveillances of Brown & Root construction activity were not properly documented. As a result, HL&P committed to retraining all HL&P surveillance personnel relative to check list documentation of all unsatisfactory conditions. Written instructions were issued in an HL&P l
memorandum, dated February 1,1980. An HL&P site procedure, dated June l
3,1980, clarified actions to be taken in the event of the discovery of an unsatisfactory condition. HL&P personnel received training on this procedure June 18, 1980. Subsequent to 79-19, the HL&P site i
organization, HL&P site organization's function changed from a l
l
. surveillance function to an implementation review function; in addition, a new group was created to perform an inspection function similar to the old surveillance function. An NRC follow-up inspection documented in I&E Report 80-25 concludes that all unsatisfactory conditions identified during HL&P surveillances were properly documented and that the implementation review funccion replaced the surveillance function.
HL&P admitted the findings set forth in Item of Noncompliance No.
16, in that it failed to control the use of a nonconforming hammer in penetration testing of Category I backfill.
In its response of fiay 23, 1980, HL&P stated that at the beginning of the soil penetration test program, the hammer and chains on the test rig were found to weigh 148.9 pounds rather than the required 140 pounds. A nonconformance report was written by consultants Woodward-Lundgren but was not dispositioned until February 4, 1980. Thus, this item was cited in 79-19 as not only an example of HL&P using a nonconforming hammer, but in addition, it is a further example of HL&P's inability to properly process nonconformance reports.
During the investigation which resulted in I&E Report 80-17, identified as Staff Exhibit No. 63, the report of Woodward-Clyde consultants was reviewed by NRC inspectors. This report documented the fact that the initially reported weight of the hammer included the weight of the hoisting chain.
Upon reexamination, the actual hammer weight was found to be 138.9 pounds, another hammer was found to weigh 142 pounds.
Since ASTii D-1586 does not prescribe acceptance tolerances, both hammers were considered acceptable by Woodward-Clyde consultants. Any variability introduced by these minor weight variations would be masked l
l t
o
. by other uncontrollable variables in the penetration test process.
In addition, HL&P committed to the revision of site work procedures for handling nonconfomance reports for out-ide consultants prior to resumption of work activities. As of 80-17 these revisions had not yet occurred.
During a subsequent NRC inspection documented in I&E Report 80-19, identified as Staff Exhibit No. 65, an NRC inspector reviewed the revised procedures which defined the handling of nonconfomances in this context. These procedures were similar to the procedures for handling nonconformances in other contexts and were thus found adequate and this item was considered closed.
In its May 23, 1980, response, HL&P admitted to its failure to control the dimensions of the split spoon in soils test control, this failure formed the basis of Item of Noncompliance No. 17. HL&P stated that although the Terzaghi spoon used had different dimensions than the split spoon specified by ASTM D-1586, this difference had no effect on the standard penetration test results. During the NRC inspection which preceded the issuance of I&E Report 80-17, identified as Staff Exhibit No. 63, an NRC inspector reviewed the analysis perfomed which led to that conclusion, agreed and closed this issue. The calculations supporting the evaluation and conclusions were also reviewed and found acceptable.
HL&P admitted in its May 23, 1980, response that it failed to provide for, and conduct, supplemental audits as part of its quality
/
assurance plan and audit system. This finding fomed the basis of Item of Noncompliance No. 18(a). HL&P committed to establishing procedures to implement commitments included in its PSAR, to establish qualitative
criteria for the evaluation of audit effectiveness and the need for supplemental audits. This failure to implement P5AR commitments into procedural specifications also formed the basis of Item of Noncompliance No. 18(b). HL&P admitted that it failed to perform audits to the depth necessary to assure implementation of site QA/QC and construction procedures because audit activities were limited to periodic onsite i
surveillance and examination records in belief that such activities satisfied audit requirements. Auditing was further impeded by insufficient time to prepare for audits and evaluate audit findings.
This formed the basis of item of noncompliance No. 18(b). HLP committed to perform in depth audits by reorganizing the audit function, revising procedures to require in depth audits to assure implementation of procedues related to work activity, and by increasing the audit staffing level.
Report 80-18, referenced above, documented a follow-up inspection which determined that HLP audit group is performing effective and in-depth audits. Additionally, the audit capability and the Staff had been increased by reorganizing the audit function and by adding personnel.
It was noted in this I&E Report that this item was considered closed, however, effectiveness of future audits at the prescribed frequency will be monitored.
I&E Report 81-07, dated April 13, 1981, documented such a review of HL&P audits. This item is closed based upon verifying the above cited corrective action.
HL&P admitted that it failed to perform semi-annual audits of Brown
& Root site organizations and procedures, as well as failing to perform annual audits of Brown & Root construction site activities, as required
s s
-. by the PSAR and applicable HL&P QA procedures..These findings formed the basis of Item of Noncompliance 18(c).
I&E Report 81-07, dated April 13, 1981, documented that HL&P was performing effective audits at the prescribed frequency.
Q.
Is it this finding, and findings similar, which led the NRC to conclude that HL&P abdicated too much of the responsibility for the construction of the South Texas Prcject to Brown & Root?
A.
Yes.
Q.
What corrective action did HL&P propose as a result of this Item of Noncompliance?
A.
Since March 1, 1980, HL&P's corporate audit group has been scheduling and performing audits of Brown & Root construction activities.
HL&P auditing procedure, QAP-5B, was revised on March 31, 1980, to state that not only will objective evidence be examined to ensure compliance with QA requirements, but procedural implementation will be verified by direct observation of work being performed.
During a routine NRC investigation which resulted in the issuance of I&E Report 80-27, identified as Staff Exhibit No. 71, resident reactor inspector, H. Shannon Phillips determined that HL&P had developed a matrix to assure all procedures will receive proper consideration when planning audits.
Current schedules indicated that all procedures / organizations are planned for or are being audited. As a result of the broad corrective action taken, the resident reactor inspector had no further questions on this item; but, indicated he would continue to monitor the frequency of audits during future routine inspections.
. HL&P admitted in its May 23, 1980, response that it failed to audit Brown & Root site activities to a sufficient degree. Apparently, Brown &
Root corporate offices in Houston audited Brown & Root site activities primarily by a review of records; there were no procedural checks to assure that activities affecting quality were implemented effectively.
These findings formed the basis of Item of Noncompliance No.19.
Brown &
Root initiated a new audit program, changing from the procedural audit system to a program /systen audit. This change assures that all criteria and the implementation of those criteria are adequately reviewed and evaluated on a periodic basis.
Q.
What is meant by a program / system audit rather than a procedural audit?
A.
A procedural audit is merely a paper review of activities represented to have occurred in the field. This system contributed to upper corporate management losing touch with what was happening in the field.
In contrast, a program / system audit is both a paper audit and a more in-depth review to determine whether what is represented on paper occurred, in fact, in the field.
In short, it is an attempt to tie procedures to their ability to effectively control work in the field.
During an inspection for I&E Report 80-25, this system was reviewed to verify it had been i;plemented and as a result of positive findings the resident reactor inspector determined this item should be closed.
With respect to Item of Noncompliance No. 20, HL&P revised its procedures and retrained its personnel in regard to the proper procedures in tieing reinforcing steel. The NRC special investigation found during a spot inspection that 3 of 10 shear ties examined were unsecured. HL&p
. admitted this Item of Noncompliance and committed to the revision of site procedures, to correct excessive production pressure on QC inspectors and to hold routine post-placement meetings to identify problem areas.
During the inspection which led to the issuance of I&E Report 80-30, identified as Staff Exhibit No.74, in addition to verifying that the above action committed to was implemented, the NRC inspector reviewed an analysis which showed that the ties, without being bound, were not capable of moving beyond a 12 inch spacing because of horizontal reinforcing steel. The maximum allowable spacing of ties, according to the design, is 24 inches as compared to 12 inches provided in the South Texas specifications. This analysis indicated, therefore, that the actual shear load requirenent, was half of the shear load capacity provided. Thus, HL&P's failure to properly tie the rebar was of no safety significance. Based upon this analysis, NRC Inspector J. I. Tapia concluded that the integrity and strength of the diesel generating building mat had not b'een degraded by the lack of shear tie wiring which formed the basis of Item of Noncompliance No. 20.
Q.
What, if anything, does this Item of Noncompliance illustrate?
^
A.
This item, as is also the case for Items of Noncompliances Nos.
12, 16, 17 and others, illustrates HL&P's failure to identify and
[
l correct, in a timely manner, situations which potentially could affect safety related structures at the South Texas Project.
Q.
Please now address the final two Items of Noncompliance.
A.
In Item of Noncompliance No. 21, HL&P admitted to failing to control design changes in root openings and weld dimensions, in that Brown & Root initiated engineering changes in certain welding procedures
. without complying with applicable portions of the Brown & Root QA Manual for control of design changes. HL&P represented that design change procedures were to be revised and all administrative and technical personnel in the welding engineering department and QA/QC personnel
.olved with design changes would be trained in the design change system, making them fully cognizant of the correct method of requesting cssign changes.
NRC Inspector Dan Tomlinson in I&E Report 80-24 verified that the proposed corrective action was implemented, and based upon the adequacy of that action, this matter was closed.
Item B in I&E Report 79-19 stated that HL&P did not use a penetrameter on the source side, as required by the ASME Code.
It was determined that, notwithstanding access to the source side, work was done with only a film side penetrameter. HL&P admitted this failure.
By way of explanation, radiography of welds utilizing a film side penetrameter is allowed by the ASME B&PV Code only in cases where the part configuration prevents hand placing of the penetrameter on the source side, otherwise source side testing is to be performed. During the construction of the South Texas Project, it had developed as common practfre during qualification testing of welders to use the film side technique, even though no such configuration restriction existed preventing welders to use the penetraneter on the source side.
In I&E Report 80-24, NRC Inspector Dan Tomlinson verified that all radiographers have been retrained in the proper placement of penetraneters and in the limited use of the film side technique.
In accordance with restart commitments, all ASME welds made to date will be reinspected as part of the program to assure that quality welds have been produced regardless of
'. errors in the welder qualification testing method. All future welder test coupons subject to radiograph examination will be shot using a source side penetra^eter when possible.
Q.
Turning the panel's attention to its follow-up of the 10 items in the NRC Show Cause Orcar, specifically Item No. 1. did HL&P retain an experienced, independent management consultant to determine whether the management of the QA/QC program is adequate to exercise full control over all espects of the South Texas Project?
A.
Yes.
It should be first noted that HL&P responried to all directives set forth in the Staff's April 30, 1960 Show Cause Order in a filing dated July 28, 1980, entitled " Licensee's I<esponse to Order to Show Cause." In this response, HL&P stated it retained Bechtel Power Corporation, Gaithersburg Power Division, during February,1980. Bechtel conducted an audit of HL&P's QA/QC program during the period beginning March 4 and ending May 21, 1980, utilizing 11 auditors experienced in nuclear construction and QA requirements. HL&P's response to the Sho.'
Cause Order has previously been identified as Staff Exhibit No. 48 and Bechtel's independent management review of HL&P's QA progran is attached to that exhibit as Exhibit No. 1.
Q.
In its management review, did Bechtel consider the pros and cons of the various organizational alternatives referred to as (a) through (e) in Show Cause Item No.1; and if so, please state the recommended course of action?
A.
Yes, each organizational alternative, together with its pros and cons, was addressed in turn. HL&P chose to maintain a modified version of the in-place organizational structure where Brown & Root has
. responsibility to implement a QA/QC program under the overall supervision of HL&P. The program was revised to enhance the direct role of upper management with the ongoing activities at the site. This goal was accomplished by having the corporate QA manager for HL&P assigned to the South Texas site and he in turn reporting directly to the HL&P Executive Vice President.
Numerous other changes were accomplished and will be the subject of the testimony of NRC quality assurance engineer, John Gilray, and attention is directed to Mr. Gilray's testimony for an elaboration upon the quality assurance program changes.
Q.
Turning the panel's attention to show cause Item 2(a), did HL&P review the test fill program which established soil conditions, lift thicknesses, compactive efforts and equipment characteristics necessary to develop in-place deasities?
A.
Yes.
In its response of July 28, 1980, HL&P stated that it retained consultants and formed an independent review committee to review all soil >ad backfill matters. HL&P stated that the quality construction proceo.re for Category I structural backfill was first developed in 1976, basca upon specification requirements and existing industry practices.
It stated that the self-imposed test fill program showed that approximately 80% relative density could be obtained by 4 passes over loose lifts of between 18 to 24 inches. However, the Brown & Root site geotechnical engineer conservatively recommended that provisions for a minimum of 12 roller passes be initially incorporated into construction procedures. However, Brown & Root subsequently concluded that the minimum of 12 passes would actually only be necessary on the surface lift. The test fill program is described in detail in a document
. entitled " Test Program For Compaction of Category I Structural Backfill" which is attached as Exhibit 9 to what has previously been identified as Staff Exhibit No. 48. HL&P concluded, along with its task force and independent review committee, that the construction nethods in use at the time of 79-19 resulted in an end product which meets or exceeds project design requirements.
During an NRC inspection which led to the issuance of I&E Report 80-24, identified as Staff Exhibit No. 40, NRC Inspector J. I. Tapia reviewed information which addressed the test fill program which established soil conditions, lift thicknesses, compactive efforts, and equipment characteristics necessary to develop the requisite in-place densities. This review was in addition to that performed during an inspection by Mr. Tapia which resulted in the issuance of 1&E Report 80-12, identified as Staff Exhibit No. 58.
During the latest inspection, Mr. Tapia reviewed the procedures used to perform the test fill program, and Technical Reference Document " Test Program For Compaction of Category I Structural Backfill" and the results of the program as documented in HL&P's responses. Mr. Tapia was satisfied that the documentation l
demonstrated that the density of lower lifts is significantly increased by compaction of subsequent lifts. This multiplying effect, demonstrated to Mr. Tapia that the requirement for a minimum of 8 passes of the compaction equipment required before testing lifts was adequate. As a l
practical natter, if the requisite density was not achieved using the minimum number of passes, additional passes with compaction equipment were made until the required density was achieved prior to contir.uing the i
construction effort. Mr. Tapia also reviewed the interim report of the i
i l
l l
. expert committee of independent engineers which concluded that the testing of the upper portion of the underlying lift produces conservative results. Based on the above analysis, Mr. Tapia was satisfied that the Show Cause Order requirenents for HL&P to address the test fill program used to establish in-place density testing criteria had been met and closed this item.
Q.
With respect to Show Cause Item 2(b), did HL&P make a comparison of the materials it tested and described in Section 2.5.4.8.3 of its FSAR in regard to liquefaction analysis to those materials used and tested in the field during the NRC special investigation?
A.
Yes.
In its response of July 28, 1980, HL&P found no material difference between the soil properties tested in 1974 and the soil properties found during the special NRC investigation. The change in minimum and maximum dry densities, noted in the NRC special investigation, was due, according to HL&P, to subtle changes in the gradation and coefficient of uniformity which occurred over the four year construction history of the backfill.
In I&E Report 80-24, NRC Inspector J. I. Tapia reports on the analysis he performed to verify HL&P's position. The NRC inspector reviewed HL&P's response and its resoluti0n of the discrepancy and densities of materials used in the design to those which were in place at the site. The NRC inspector concluded that the apparent discrepancy was acceptable since the 80% relative density values had not shifted significantly, and this is the critical variable. After computation of this value, which is used in the liquefaction analysis, a.18 pound l
difference results between the design 80% relative dry density and the l
l l
'.- field 80% relative dry density was considered to be a negligible difference. These figures, relative to the liquefaction analysis performed for the design and presented in the FSAR are valid and applicable to the backfill material in place. As a result of this analysis, Item 2(b) was closed.
Q. With respect to Show Cause items 2(c) and 2(d), was a review made by HL&P concerning the sequence of construction procedures relative to the existing backfill, including the loose lift thickness and number of passes of equipment; and if so, was the adequacy of that backfill material reviewed?
A.
Yes, the adequacy of both the sequence of construction procedures and the existing backfill in place has been the subject of review by an independent review committee and an expert's panel of engineers. NRC Inspector J. I. Tapia has been reviewing interim reports from these various groups and has found that the existing backfill is adequate. However, as of March, 1980, the NRC was awaiting the results of the final analysis from these groups in order to evaluate and close out this matter.
Q.
What is the current status of the NRC's follow-up activity relative to HL&P's evaluation of existing backfill?
A.
The NRC recently received the final report of the Independent Review Committee and is currently evaluating the adequacy of that report.
Pending the results of that analysis, the NRC will address this item in a subsequent I&E Report.
. Q.
Did HL&P provide a rationale behind the use of 18 inch loose lift thicknesses compacted by 8 passes of compaction equipment to achieve the required densities in response to Show Cause Item 2(e)?
A.
Yes.
In its response of July 28, 1980, HL&P stated that design specifications for Category I backfill rely upon in-place d nsity tests to assure adequate lift compaction. The use of a maximum of 18 inch loose lifts and a minimum of 8 passes over those loose lifts describe in-process checks aimed at achieving the end result. According to HL&P if, following the in-process procedures the required densities were not met, additional passes with compaction equipment would cecur.
In addition, due to the multiplying effect of compacting one lift over another, it is HL&P's position that the use of 18 inch loose lifts compacted by a
- nimum of 8 passes is sound construction practice which results in Category I structural backfill which conservatively satisfies the requisite densities.
NRC Inspector J. I. Tapia reviewed the information provided by HL&P addressing the rationale behind the use of 18 inch loose lifts compacted l
by 8 passes of equipment to achieve the required densities during an inspection which led to the issuance of I&E Report 80-24, identified as Staff Exhibit No. 40. Upon reviewing all Applicant data and verifying i
that a test fill program had been conducted in June,1980, and further based upon the explanation offered in response to Show Caese Item 2(a),
NRC Inspector Tapia considered this matter closed.
Q.
I turn the panel's attention to Show Cause Item 3, which directed HL&P to review certain safety related work to determine whether such work was properly performed, describe the extent of any necessary l
t
. repairs and to set forth a schedule for completion of those needed repairs. Specifically, with respect to Show Cause Item 3(a), has HL&P performed a review of safety related welding including civil structural and piping?
A.
Yes.
Brown & Root and HL&P formed a special task force review team to formulate a comprehensive program to reassess and verify safety related welding at the South Texas Project in response to Show Cause Item No. 3(a). The task force was given the responsibility of identifying any repair work that might be required and establishing a schedule foc completion of such work.
In addition, a consulting firm was retained and an independent review committee was formed to review and approve the programs and reports generated by the task force.
The review of nondestructive examination procedures (NDE) identified the need for improvement and HL&P has committed to incorporating such inprovements into NDE procedures. Specifically, the task force identified irregularities in NDE inspector qualifications, radiographed welds, procedures in identifying unacceptable welds, documentation of in-process checks relating to AWS welding were not properly documented, procedural irregularities identified in ASME welding, previously accepted ECW pipe welds found to be unacceptable, and, as a result, all welding processes were to be reassessed and corrections implemented.
As a result of the special investigation resulting in I&E Report 79-19, and the specific problems identified in safety related welding, all such welding was halted by HL&P and Brown & Root in April, 1980.
Pursuant to discussions between the NRC and HL&P, all safety related welding was to be gradually restarted on a controlled basis in accordance
. with a step by step program of planned activities.
In accordance with this plan, ASME safety related production welding was restarted on a limited basis on fiovember 24, 1980. This welding was expanded on January 5, 1981, in accordance with a 10 week work plan submitted to the NRC.
The various aspects of liL&P's safety related welding program have been under the periodic surveillance of the f4RC. This matter will be closed out in an I&E Report after the flRC assesses the results of this limited work effort. To date, it appears that HL&P has implemented the various commitments it represented it would undertake in its July 28, 1980, respor.se to the f4RC Show Cause Order. This matter is scheduled to be addressed more fully in I&E Report 81-14, which has not yet been issued.
Q.
Is the f4RC surveillance over Show Cause Item 3(b) mandating a review of HL&P's safety related concrete structures, including embedments such as supports and the fuel transfer tube, in a similar review posture?
A.
Yes.
In response to Show Cause Item fio. 3(b), HL&!' and Brown &
Root initiated a special task force to review and assess safety related concrete structures at the South Texas Project. This task force was to determine whether safety related concrete construction work, completed as of the date of the Show Cause Order, was properly performed so as to meet l
all applicable structural design requirements.
In addition, as was the case with safety related welding, a consultant panel was gathered to assess the work of the task force in identifying the problems and designing solutions.
The task force proceeded in four phases; first, a documentation review was performed relative to design and construction documents; secondly, a review was to be made to determine the "as built" configuration of safety related structures and to compare that to the "as
, designed" configurations; next, a visual inspection was to be conducted in order to determine whether there are potential structural defects; and lastly, a number of specific tests were to be performed on plant structures.
As is the case with safety related welding, safety related concrete processes and structures are under periodic surveillance by the NRC and HL&P's corrective action in response to this Show Cause Item is still under evaluation. To date, the corrective action proposed by HL&P appears adequate and implementation of that corrective action is proceeding on a limited basis. On January 13, 1981, the NRC authorized the commencement of the limited resumption of complex concrete placement based upon connaitments made previously by HL&P. This matter will be addre.ised by the NRC at a time when it has h3d an opportunity to assess the final report recently submitted by HL&P concerning corrective action on complex concrete activity.
Q.
Turning the panel's attention to Show Cause Item No. 4, did HL&P cause Brown & Root to rescind a brochure entitled " Implementation of the Brown & Root Quality Assurance Program at the South Texas Project Job i
Site" and the associated videotape following receipt of the Show Cause l
Order of April 30, 1980?
A.
Yes.
Q.
Did HL&P cause the republication of a new QA program brochure to reflect the fundamental philosophies of 10 C.F.R. Part 50, Appendix B, and further, did it conduct seminars with construction and QC personnel on the contents of the brochure and its philosophies?
. A.
Yes, on July 30, 1980, Resident Reactor Inspector, H. Shannon Phillips, attended a seminar.given by HL&P during which the new publication was distributed and discussed. Residrqt Reactor Inspector Phillips also noted that the prior brochure had been rescinded and the new publication properly emphasized the necessity for quality assurance The conclusion that the brochure properly emphasized the need for quality assurance was based upon the fact that quality assurance personnel are to report to a management level such that they have the required authority and orgenizational freedom, inculding freedom from cost and schedule, to identify quality problems and verify solutions. All site personnel were distributed the brochure. These actions by HL&P were verified by the NRO and documented in I&E Report 80-18 and accordingly the matter is considered corrected.
Q.
With respect to Show Cause Item No. 5, has the Licensee defined more clearly the stop work authority, temporary or otherwise, including implementation of that stop work authority?
A.
Yes, in its response to the Show Cause Order, dated July 28, 1980, HL&P more clearly defined the stop work authority at the South Texas Project. The HL&P project QA supervisor has the responsibility to assure that stop work orders are implemented.
In addition, Brown & Root quality control inspectors have authority to stop work. Authorization to resume work affected by a stop work order may only be given by the Brown
& Root project QA manager when all responses, corrective action, recurrer.ce controls and other requirements have been satisfactorily met.
During an NRC inspection which resulted in the issuance of I&E Report 80-27, Resident Reactor Inspector, H. Shannon Phillips, reviewed
, this Show Cause Item. The resident reactor inspector reviewed the state of affairs prior to the Show Cause Order and determined that HL&P and Brown & Root manuals authorized and required stop work orders be issued under certain conditions; however, the lower tier of management and QC inspectors were not adequately trained as to when they could exercise such authority. Additionally, the procedures did not clearly describe how quality control inspectors could exercise such stop work authority.
The reactor inspector reviewed the revised procedures to assure Show Cause commitments were implemented.
In the new procedures stop work authority was clearly defined by giving ai. QC inspectors authority to stop work. Based upon this review this item is closed.
Q.
What, if anything, has HL&P done to satisfy Show Cause Item No.
5 which directed it to develop and implement a more effective system to provide for the identification and correction of " root causes" of the nonconformances which have occurred in the past?
A.
HL&P, in its July 28, 1980, response, analyzed the problem by breaking it into three separate elements:
documenting nonconformances, analyzing the documented nonconformances to identify underlying causes, and correcting the causes identified.
Under a new program quality engineering will participate in construction planning and will determine
(
inspection hold points for work activities. Any nonconformance report requiring design evaluation will be forwarded by the quality engineer to l
l a materials review board. This board will be an onsite committee consisting of senior representatives from Brown & Root quality assurance, l
design engineering and construction. The materials review board will be responsible for providing dispositions to all nonconformance reports i
i 1
~,
. requiring design evaluation.
In addition, HL&P committed to a trend analysis system to perform reviews of nonconforming experiences to prevent further similar nonconformances by identifying and eliminating underlying causes of past incidents.
Prior to 79-19 and the Show Cause Order, the tracking of nonconformances was done on an informal basis and not as a required part of HL&P's quality cssurance program. The revised trend analysis program was upgraded by providing a data analysis group, comprised of quality systems engineers responsible for identifying the methods to be used to collect data, the ways to categorize and monitor deficient conditions, and developing methods to report these findings to management.
This system was reviewed by Quality Assurance Engineer, John Gilray, of the NRC Quality Assurance Branch, and found to be adequate. However, this system can only be evaluated over time after reviewing its ability to flush out recurring problems. This system was the subject of an interim inspection performed in connection with I&E Report 80-27 and thus far found to be adequate. However, during this same inspection, HL&P was cited for an Item of Noncompliance in that it failed to follow procedures which prevent the use of nonconforming materials. Here again, this is an example where, in spite of adequate in-place procedures, HL&P has not followed such procedures.
Q.
Has HL&P developed and implemented a more effective system to 4
provide for the control of field changes in order to assess the impact of the changes on the overall design, as mandated by Show Cause Item No. 7?
A.
Yes.
. Q.
Why would the NRC require that such a systea be developed?
A.
Although viewed individually, field changes may seem insignificant, the cumulative effect of field changes may impact upon the overall design of the structure. Accordingly, HL&P needed a system to verify that either individually or cumulatively field changes did not adversely affect the overall design of the project.
Q.
Please state the system implemented by HL&P to provide for such controls.
A.
All design changes proposed at the South Texas site are submitted to the project site engineering organization (PSE). This group is to determine if they are to be referred to HL&P, Houston Engineering, for disposition.
Either PSE or Houston Engineering evaluates the requested change, and issues a design change notice. The prerequisites for the issuance of a design change notice include documentation relative to the reason for the change, justification for the change, engineering evaluation of the change, and, assessment of the effect of the change on plant design.
In addition, relevant personnel are made aware of this t
change by means of a computerized tracking system. As a further means of l
ensuring that the impact of the design change on the overall plant design has been assessed, a change review board will be established within Brown
& Root engineerina at Houston and the site with the primary function to l
provide a mechanism to assure that proper interdiscipline design reviews have been conducted.
l The implementation of these commitments has been the subject of part of three I&E Reports; 80-30, 80-36; and 81-05. Brown & Root issued revised procedures describing the new South Texas Project field design l
. change program which HL&P had committed itself to in its July 28, 1980, response to the NRC Show Cause Order. The NRC inspector reviewed procedures outlining that program in documents entitled; " Field Change Request / Temporary Change Notice"; " Engineering Procedure For Processing Fiela Change Rerrdst"; " Engineering Procedure For Design Change Control";
and " Engineering Frucedure for Change Review Board Activities." These procedures appeared to satisfy the requirements of the Show Cause Item; however, full implementation of the procedures could not be reviewed at that time and will be the subject of subsequent inspections. This item continues to be the subject of NRC surveillance; however, to date, the Applicant appears to be implementing adequately the commitments deemed appropriate in response to Show Cause Item No. 7.
Q.
In response to Show Cause Item No. 8, has HL&P developed and implcmented a more effective systems of records control?
A.
HL&P's response to Show Cause Item No. 8, similar to its response to Show Cause Item No. 7, appears adequate, but its effectiveness cannot be judged until the NRC can evaluate its effectiveness after being implemented over a period of time.
In an attempt to develop a more effective system of records control, HL&P retained the assistance of Nuclear Power Consultants, Inc., and developed four main objectives for the new system:
(1) the records requirements for each construction activity be individually delineated; (2) there should be a system capable of providing prompt information concerning the status and location of relevant records; (3) as records are created they should be controlled and protected to assure that the
. +
recorded status and location remain correct and; (4) techniques should be incorporated in the system to assure that the other objectives are met.
Whether or not these objectives were implemented in a system which more effectively controlled records has been reviewed and is documented in three NRC I&E Reports; 80-30, 80-36, and 81-05. HL&P and Brown & Root have developed several new procedures and have revised existing procedures in an attempt to implement its commitment in Show Cause Item No. 8; including, procedures relative to " Inspection Planning and As Built Verification," " Records Control," " Instructions for Records Control," "QA Document Administration for the QA Vault," in order to implement the commitments outlined above.
To date, the NRC inspectors have been satisfied that HL&P has made reasonable progress in satisfying the commitments it made in response to Show Cause Item No. 8.
- However, i
by the nature of the commitments, implementation can only be verified by evaluation over a reasonable period of time. Accordingly, the NRC continues to monitor this item and, to date, is satisfied with its implementation.
Q.
In response to Show Cause Item No. 9. has HL&P developed and implemented an improved audit system?
i j
A.
Yes, any response to this Show Cause Item must be viewed in the context of HL&P's response to Items of Noncompliance 14,18a,18b,18c, and 19. HL&P's response to the above named Items of Noncompliance sets forth the nature of the revised audit program and the NRC response to that program is set forth in the I&E Reports identified earlier in this testimony in the context of discussing those items of noncompliance.
However, in reference to the Show Cause Iterc, the NRC is articularly
. interested in how effectively HL&P has implemented its audit program. To date, the approved audit program has been adequately implemented and will continue to be monitored on a periodic basis.
The effectiveness of their audit programs depends on (1) in depth auditing to assure the entire QA program is effectively implemented, (2) high level management involvement to assure that the program is a vital communication link to actual QA program implementation and the auditors observations relative to construction work activity (3) high level management involvement when impasses occur between the audit organization and the audited organization, (4) performing supplemental audits when suspected safety, performance or reliability performance or reliability of an item is in jeopardy due to deficiencies and nonconformances with respect to the organizations QA program and when necessary to verify corrective action, and (5) maintaining an adequate audit staff to l
adequately perform the HL&P and B&R audit functions.
To date the approval audit program has been adequately implemented and commitments are almost completely implemented relative to audit system improvements, however, the NRC will continue to monitor audit systems as part of its inspection effort.
1 Q.
In response to Show Cause Item No. 10, has HL&P verified or corrected the FSAR statements contained in Section 2.5.4, Stability of Subsurface Materials especially Section 2.5.4.5, Excavation and Backfill?
A.
Yes.
HL&P amended these sections in FSAR Amendment 12, this l
matter has previously been more fully discussed in this testimony in the i
context of Items of Noncompliance Nos. 2 and 3.
, Q.
Aside from the Items of Noncompliance and Show Cause Items just addressed, were other infractions or potential infractions ident',fied in 79-19?
A.
Yes. Due to the broad scope of 79-19, various matters which were potential infractions were left unresolved to be addressed by Region IV in the course of its follow-up activities. Thirty (30) unresolved items were identified and seven (7) open allegations were left for subsequent investigation.
Q.
What is the current status of these matters?
A.
26 of the unresolved items and all of the open allegations have been addressed and closed; a list of the I&E Reports which contain the NRC findings and conclusions on each of these matters is attached to this testimony as Appendix B.
Q.
Is there any other means of identifying, evaluating and resolving possible construction deficiencies?
I l
A.
Yes. As required by 10 C.F.R. Q 50.55(E)(1), a holder of a construction permit is under a duty to notify the NRC of each deficiency found in design and construction, which, were it to remain uncorrected, could adversely affect the safety of operations.
The permit holder is under a duty to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> j
of discovering each reportable deficiency and must submit a report of the matter within thirty (30) days. The report must include a description of the deficiency, an analysis of the safety implications and the corrective action taken.
If sufficient information is not available for a
(
l definitive report within thirty (30) days, an interim report must be filed.
l
[
l
. The history of HL&P's reporting pursuant to 10 C.F.R 5 50.55(E)(1) for the South Texas Project is attached to this testimony as Appendix C.
Q.
Based upon the NRC inspections and investigations set forth above, is there reasonable assurance that the structures now in place at the South Texas Project are in conformity with construction permits and the provisions of Commission regulations? Please explain the panel's answer.
A.
Yes. The report by the special inspection team (79-19) concluded there were no major safety related problems with the completed structures or systems. Upon review of that report, HL&P's various responses to the enforcement actions resulting from that report and the NRC's inspections both before and subsequent to 79-19, it is concluded there are no major safety related problems with the completed structures or physical systems. The ongoing NRC inspections should assure the continued adequacy of construction.
Q.
Based upon the NRC inspections and investigations set forth above, is there reasonable assurance that the current QA/QC program will be implemented so that construction can be completed in conformance with the construction permits and applicable NRC regulations?
A.
Yes. HL&P's corrective actions, as previously outlined, should assure implementation of the QA/QC program.
In addition, ongoing NRC inspections should assure the continuing application of the corrective actions taken following the enforcement action accompanying 79-19.
a O
APPENDIX A Items of Noncompliance Since Show Cause Order Inspection General Description of Report Dates Inspectors Item. of Noncompliance 80-01 Dec 1979 H. S. Phillips Failure to provide timely notice of a construction deficiency Jan, Feb 1980 Failure to follow test procedures 80-05 Mar 1980 H. S. Phillips Failure to provide timely reply to the transmittal letter for an item of noncompliance Failure to provide timely notification of a construction deficiency Failure to provide a timely written report for a construction deficiency 80-07 Apr 8-11, 1980 W. G. Hubacek Failure to follow procedure for storage of material 80-18 Jul 1980 H. S. Phillips Failure to develop appropriate procedures' to assure traceability of embed material Failure to assure that purchased material conformed to procure-ment documents i
Failure to respond to B&R audit findings 80-27 Oct 1980 H. S. Phillips Failure to follow procedures which prevent the use of non-conforming materials 81-01 Jan 1981 H. S. Phillips Failure to follow procedures for storage and maintenance of equip-l ment l
l
APPENDIX B D_i_sposition of Unresolved Items and s
Open All 1.
UNRESOLVED ITEMS 79-19 79-19 Tracking Report Page No.
Section No.
Subject Report / Status 79-19-01 E.1.a 24 Licensee is correcting discrepancy 80-18/ Closed Allegation 12 found in traceability of embedded steel plates 79-19-02 E.1.b 35 Licensee is correcting problems 81-01/ Closed Allegation ICA found in the resolution of old NCRs on Storage /Mainten.
79-19-09 E.2.a 51 Need for additional controls in 80-30/ Closed procedures addressing prepour, constr., curing of conc.
79-19-12 E.2.b.
54 Recheck on conc. transit trucks 80-24/ Closed standing or in-transit w/o agitation 79-19-13 E.2.c.
57 Final inspections on completed 80-24/ Closed placements not adequately controlled and up to date 79-19-14 E.2.c.
58 Sampling of pumped concrete and the Open lack of correlation program 79-19-15 E.2.c.
58 Conflict of personnel qualification 80-30/ Closed req'ts for concrete placement (ANSI vs ASME) 79-19-17 E.2.c.
59 Need for systematic program to 81-04/ Closed assure that training is given to all on spec / proc. revs.
i 79-19-19 E.3.b.
63 Compaction of upper part of le:t 80-24/ Closed lift which may remain below Cat. I bldgs; B&R literature 79-19-20 '
E.3.b.
63 Retest fill section comple'ted with 80-24/ Closed excessive number of passes by double roll overlap l
79-19-23 E.3.d.
65 Records of fill lifts vs. location Open in order to reconstruct fill placement procedure lacking 79-19-25 E.3.e.
66 Decrease in relative density 81-03/ Closed (bulking) of compacted mat'l in wet state under vibration
l Tracking Report Page f _o.
Section No.
Subject Report / Status j
73-19-26 E.3.e.
66 Discrepancies in min-max relative 80-24/ Closed densities of materials used vs.
reported is SAR for liquefaction 79-19-29 E.3.f.
67 Attempt to correlate Std Penetration 80-24/ Closed values to those from oversized, blunt spoon & nonconforming hammer 79-19-30 E.3.f.
67 Boring 204, loose mat'l near base of 80-24/ Closed fnd. mat of RCB Unit 2 - Aug. '77 washout area 79-19-31 E.4.b.
69 Details of welder qualification 80-24/ Closed 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 Open and Code stamp on lower S. Gen.
supports considered now as bldg.
79-19-36 E.4.c.(3)(b) 73 No Code inspection by ANI on weld 80-28/ Closed now embedded in concrete on the fuel trans. tube 79-19-37 E.4.c.(3)(c) 74 Control of attachments on material Open post-weld heat treat. - lower SG supports & others 79-19-40 E.5.a.(2) 76 Test reports of liquid penetrant 80-24/ Closed examination not serialized and documentation of examinations inadeq.
79-19-42 E.5.c.
83 No training for QC personnel in liq.
80-24/ Closed pene, by flourescent mat'Is, processing & reading radiographs, visual AWS, recordkeeping 79-19-43 E.7.a.
88 Procedure for NCRs lacks processing, 80-27/ Closed approvals, feedback & records retention details 79-19-44 E.7.c.
92 Review of documentation involved 81-05/ Closed with Receiving documentation for some vendors 79-19-45 E.7.c.
93 No procedures for trending FREAs and 80-27/ Closed reviewing cumulative impact of all changes
A Tracking Report Page No.
Section No.
Subject Report / Status 79-19-46 E.7.c.
94 Unsatisfactory conditions found 80-27/ Closed during ECs not being documented 79-19-49 E.8.c.
96 Aduit requirements of ANSI N45.2.12 81-04/ Closed not part of the PDM contract 79-19-51 E.8.d.(3) 101 Audit B&R-27 followup not documented 80-25/ Closed and procedure to require this in general is being written 79-19-52 E.8.d.(3)~
101 Question of whether all B&R 80-27/ Closed procedures have been audited by B&R Houston.
Cesign control not audited in 1978 79-19-54 E.9.b.(2) 105 Inadequate responses to surveillance 80-27/ Closed findings.in that bases for closecut lacking 79-19-58 E.3.a.
61 Res31ution of why spec was revised 80-30/ Closed fr'.n 12 to 18" lifts that was
.0unter to the BLR cog. engr.
l l
l l
f l
2.
OPEN AlIfGA110NS Tracking Report P.ge No.
Section No.
Subject Report / Status 79-19-04 E.1.b.
39 Vertical cracks in structural steel 81-01/ Closed Allegation 12A clips in the boron injection room of RCB Unit 1, E1. 36' 81-06/ Closed 40 Pipe sleeve weld defect 1/4" deep at 79-19-05 E.1.b.
Allegation 13A Az. 300*, E1. 8' in RCB Unit I near work par.el 15 79-19-06 E.1. b.
41 Classification of containment polar 81-01/ Closed Allegation 14A crane 79-19-07 E.1.b.
42 Storage of elec./ mech penetrations 81-01/ Closed and lack of understanding by warehouse electricians of Megger tests on notors 79-19-56 E.1.b.
43 Curing of the conc. intake structure 80-38/ Clos ed
, Allegation 16A on which an NCR was written 79-19-57 E.1.b.
44 NRC told of voids in concrete with no 80-24/ Closed Allegation 17A definite closecut or resolution 79-19-59 E.1.b.
46 Missing 3 horiz. rebars 80-38/ Closed Allegation 19A F
-n.-
~
APPENDIX C SOUTH TEXAS PROJECT 50.55(e) ITEMS Initial Interim Final Title Report Report Report 1.
Cracks in fuel handling building wall 02/10/77 02/14/77 02/17/77 2.
Weld defects in Category I structural steel (American Bridge) 04/26/77 05/26/77 05/17/77 3.
Reinforcing steel incorrectly positioned in containment sheel wall 07/18/77 08/17/77 09/30/77 buttress 08/29/77 4.
Weld fabrication of 16 steel embedments (Bostrom Bergen) 06/15/77 06/24/77 5.
Weld defects in steam generator and reactor pressure vessel supports 10/05/77 11/03/77 11/11/77 6.
Unconsolidated concrete in the Unit 1 fuel handling building 03/15/78 04/14/78 09/18/78 7.
High-pressure safety injection pumps failed to meet specification 07/28/78 10/19/78 requirements during performance testing 8.
Dimensional error in the base slab of the Unit 2 mechanical-10/04/78 10/31/78 10/29/79 electrical auxiliary building 04/24/79 9.
Deficient beam to column connections in Unit 1 reactor containment 10/25/78 12/27/78 06/05/79 building (This item was reopened based on further evaluation by Brown & Root) 09/24/80 09/30/80 10/24/80 10.
Undersize threads on anchor bolts 10/27/78 07/30/79 11.
Clay ramp in backfill 11/03/78 01/18/79
- 12. Unit 1 containment building voids (in lift 15) 10/20/78 11/20/78 06/05/79 13.
Anchor bolts fabricated of incorrect material 02/05/79 03/08/79 01/28/80 06/05/79 12/31/79
. Initial Interim Final Title Report Report Report 14.
Essential cooling water intake structure gantry crane was not 05/16/79 06/15/79 10/09/79 designed to withstand design basis tornado wind loadings
- 15. Voids in lift 8 of the Unit 1 containment building 06/18/79 07/16/79 02/18/80 08/15/79 16.
Inadequate support of safety injection system containment emergency 10/25/79 11/21/79 05/30/80 sump pipin9 03/19/80 17.
Failure of Brown & Root vendor surveillar e program to detect a 12/04/79 01/04/80 problem in the QA program of a Category 1 miscellaneous steel supplier (inadequate certification documents for Bostrom Bergen welders) 18.
Nonconforming backfill material (low blow count) around Unit 2 02/04/80 03/21/80 02/27/81 power block 05/30/80 09/23/80 12/12/80 19.
Unit 2 reactor containment liner bulge 02/07/80 03/24/80 06/06/80 07/11/80 09/25/80 03/03/81 20.
Rejectable indications in radiographs of girth welds in the essential 03/12/80 04/10/80 cooling water system pipe 06/13/80 09/12/80 12/12/80 i
21.
Voids in concrete under crossover leg embedments - Unit 1 03/12/80 04/09/80
~
. Initial Interim Final Title Report Report Report _
22.
Failure of polar crane clip stud welds 03/20/80 04/16/80 06/23/80 08/01/80 09/15/80 f-11/25/80
- 23. High piezeometer readings in the essential cooling pond 03/28/80 04/25/80 24.
Potential for reduced cooling with failure in the steam generator 03/26/80 03/27/80 blowdown system 25.
Linear indication in inconel bead on cold leg of Unit 1 steam 04/03/80 05/02/80 generator i
26.
Unqualified motor operator for turbine driven auxiliary feedwater 04/10/80 04/11/80 05/07/80 pump valves 27.
Stop work on safety-related and code welding 04/11/80 05/15/80 l
08/13/80 11/25/80 i
28.
Essential cooling water gantry crane seismic analysis 05/29/80 06/26/80 10/01/80 l
29.
Reactor vessel outlet nozzle safe ends 06/03/80 07/03/80 30.
Breakdown in QA program for concrece placement CIl - W90 (Unit 1 06/04/80 07/03/80 09/04/80 i
Secondary shield wall) 08/01/80 31.
Excessive lift thickness of concrete placement DG1 - W3A (diesel 06/05/80 07/03/80 generator building) 32.
Breakdown in the quality program - procurement cycle of purchased 06/13/80 07/14/80 materials 09/12/80 10/31/80
2
~
. Initial Interim Final 4
Title Report Report Report i
- 33. Material control of structural steel bolts 06/17/80 07/17/80 i
08/22/80 t
09/23/80 l
11/05/80 01/20/81
- 34. Minimum / maximum soil density tests on essential cooling water pipe-06/20/80 07/17/80 line backfill material 09/23/80
- 35. Diesel generator fuel oil tank room exhaust fans 06/20/80 07/10/80 09/03/80
}
36.
Lineal indications in previously accepted piping welds 06/25/80 07/24/80 09/23/80 j
12/12/80
Essential cooling water pump seal water injection system 07/03/80 08/01/80 12/11/80 10/16/80 s
39.
Inspection of stud welds on concrete embedments 07/31/80 08/28/80 03/05/81 10/08/80 12/17/80.
40.
Containment gas analysis system (COMSIP) overpressurization 06/05/80 06/06/80'
- 41. Verticality of the spent fuel-storage racks 08/22/80 09/17/80
{
- 42. Motor-pump shaft failure in COMSIP containment hydrogen monitoring 08/25/80 09/18/80 system 43.
Environmental qualification of electrical equipment for auxiliary 08/25/80 09/24/80 l
feedwater pumps 01/09/81 i
44.
Inapplicable reference tc ASME code case N-182 for Class 1 09/05/80-09/29/80 l
component supports 4
O
. Initial Interim Final Title Report Report Report 45.
Breakdown in the vendor surveillance program for Class lE 09/18/80 10/15/80 electrical equipment (Incorporated into generic deficiency reported 6/13/80 -
Item 32 above) 46.
Breakdown in quality program for service level 1 coatings and 09/22/80 10/21/80 paintings j
47.
Code weld defects in main steam line pipe whip restraints 09/26/80 10/24/80 48.
Reactor cavity ventilation design 10/17/80 11/11/80
- 49. Tensile strength of one inch HILTI KWIK-bolt expansion anchors 12/12/80 01/09/81 50.
Cable tray hanger design 12/05/80 01/07/81 02/27/81 51.
Structural steel welds deviate from AWS code requirements 01/08/81 (American-Bridge)
't e
PROFESS 10flAL QUALIFICATI0flS OF llILLI A!! A. CROSS'!AN OFFICE OF IliSPECTION AliD EriFORCEl1ENT, REGION IV Uf11TED STATES NUCLEAR REGULATORY COMl1ISSION T1r. Cressnan is Chief, Projects Section, Reactor Construction and Engineering Support Branch, Region IV, Office of Inspection and Enforce..icnt, Arlington, T2xas.
In this position, he is responsible for the supervision of the project inspactors who inspect the South Texas Project and other nuclear facilities that are under Region IV jurisdiction.
fir. Crossman has held this position since flay,1974 and in the course of his responsibilities he has reviewed, approved and parformed inspections and investigations related to the South Texas Project.
fir. Crossnan received a Bachelor of Science degree in chemical engineering from the University of Texas in 1950.
He is a registered Professional Engineer in fluclear Engineering in the State of California.
Prior !! ark History Prior to joining the Atomic Energy Commission (fluclear Regulatory Comaission) in February 1968, f1r. Crossman was an employee of the General Electric Company froa itarch 1950 to July 1965.
During this period of e..iployaent, he was a supervisor of nuclear related work; including nuclear reactor operation, plutonium and uranium recovery, irradiated fuel processing, plutontua produc-tion and radioactive waste nanagement.
From July 1%5 to Deceaber 1967,
- 1r. Crossman was a supervisor in fluclear Reactor Operations for Douglas-United fluclear, Inc.
i I
i i
-P00RORBNAL
PROFESSIONAL QUALIFICATIONS 0F RAMON E. HALL OFFICE OF INSPECTION AND ENFORCEMENT, REGION IV UNITED STATES NUCLEAR REGULATORY C0FJ4ISSION Mr. Hall N Chief, Engineering Support Section, Reactor Construction and Engineering Support Branch, Region IV, Office of Inspection and Enforcenent.
Arlington, Texas.
In this position, he is responsible for the supervision of the engineering specialist inspectors who inspect the South Texas Project and other nuclear facilities that are under Region IV jurisdiction.
Mr. Hall has held this position since July 1976,and in the course of his responsibilities, he has reviewed, approved and performed inspections and investigations related to the South Texas Project.
Mr. Hall received a Bachelor of Science degree in Chemical Engineering from the Washington State University in 1955.
He is a registered Professional Engineer in Nuclear Engineering in the State of California.
Prior Work History 1976 - 1981 Chief, Engineering Support Section - Supervised a unit responsi-ble for multi-discipline engineering support for inspection of power reactors under construction and in operation. (NRC) 1974 - 1976 Reactor Inspection Program Specialist - Performed special engi-neering studies and mvised and maintained a documented inspection program concerning power reactors in test and start-up phases.
(NRC:HQ) 1971 - 1974 Reactor Inspector, Construction, Teet, and Start-U2 - Evaluated utility programs and practices against AEC requirements for nuclear power stations during construction, test, and start-up phases. (AEC) 1968 - 1971 Manager, Vehicle Flight Readiness - Conducted management and technical reviews of the adequacy of prelaunch preparation of Delta and Saturn SIV s Astronautics Company) pace-launch vehicles. (McDonnell-Douglas 1967 - 1968 Manacer, Manufacturing Engineering - Managed a manufacturing engineering component of approximately fifty engineers involved in support of the AEC plutonium prcduction program at Hanford.
(Douglas United Nuclear)
2-1955 - 1967 The following positions were held in order of increasing responsibility in support of the AEC plutonium production program at Hanford. (GE)
Manager, N Reactor Plant Production Operating Shift Manager, N Reactor Plant Supervisor, Process Engineering, N Reactor Plant Project Representative, Research & Engineering, N Plant Process Planning Engineer, N Plant fuel Development Engineer, Research & Engineering Reactor Process Engineer, Research & Engineering o
e 9
e e
l I
l l
l l
PROFESSIONAL QUALIFICATIONS OF WILLIAll G. HUBACEK 0FFICE OF INSPECTION AND ENFORCEMENT, REGION IV UNITED STATES NUCLEAR REGULATORY COMMISSION lir. Ilubacek is a Reactor Inspector, Reactor Construction and Engineering Support Branch, Region IV, Office of Inspection and Enforceient, Arlington, Texas.
In this position, he is responsible for project inspection of the South Texas Project and other nuclear facilities within Region IV juris-diction. !1r. Ilubacek has held this position since June,1974, and in the course of this position has been regularly assigned to perfona inspections related to the South Texas Project.
11r. Ilubacek received a Bachelor of General Studies degree fran the University of Nebraska in 1973. He is a registered Professional Engineer in Naclear Engineering in the State of California.
Prior llork Histong 1974 - PRESENT Reac_ tor Inspector, Region IV, United States Nuclear Regulatory Commission.
In this position he is responsi-ble for project inspection of nuclear facilities under Region IV jurisdiction, including the South Texas Project.
1958 - 1974 Nuclear Inspector / Operator, United States Army Engineer Power Group.
Duties included a variety of job assignments j
in nuclear related work; including operator / instrument technician, instrument shop supervisor, shift supervisor, l
nuclear power plant superintendent, and chief of the instrumentation training section.
1
PROFESSIONAL QUALIFICATIONS OF llARRY SHANNON P!!ILLIPS OFFICE OF INSPECTION AND ENFORCEi1ENT, REGION IV UllITED STATES NUCLEAR REGULATORY C0!il11SSION
!!r. 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.
!!r. Phillips received a Bachelor of Science degree from the University of North Alabana in 1962, najoring in chemistry and nath.
In addition,
!!r. Phillips received a masters of science from flississippi State Univer-sity, in 1971, majoring in materials engineering with a netallurgical option.
I!crk llisto,ry, 1979 - Present Resident Reactor Inspector, South Texas Project. Duties Tnclude coordinating ar1 safety-related inspection efforts relative to the NRC Region and the site, as
- ~ well as, maintaining a field office and being a liason with Regional, state and local agencies.
1977 - 1979 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.
Performs evaluations and investigations related to issuance, suspension, nodification and revocation of license.
Review and analyze company / corporate reports to deter-mine possible violations of the AEC act ofl954.
1972 - 1977 Defense Syfyly Ageng (DSA), DEFENSE CONTRACT AD:11HIS-TRATION SERVICES OFFICE (DCA50), Houstca, Texas, Quality Assurance Division Chief.
Direct and adainister Quality Assurance effort on 988 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 Aininistration Services _Rejion, Dal1as, Tiiis -~liitirTaTs~'Eliginfir.- Served as Staff ~
Engineer and Advisor to Quality Assurance Directorate on all lietallurgical/itechanical 11anufacturing Processes.
Perforaed engineering surveillance at all major con-tractors in Texas, Oklahoma, Arkansas, flew !!axico, and Louisiana on flilitary hardaare.
.A_my ilis_sile Conmand, Redstone Arsenal, Alabama. Solid 1955 - 1975 i
State Chemist. itaterials testing of all syste:as compo-nents used in Amy ilissile Systems. 11orked in chemical, metallurgical and naterials engineering capacity.
1963 - 1965 Post _ Engineers, Redstone Arsenal, Alabama.
Corrosion Control Che.nist.
Corrosion Control Program for 40 high/ low pressure Boiler Plants as well as efficiency studies.
1963 - 1965 Norton Abrasive Company, Huntsville, Alabana. Analytical
-lisiist,'~QJiliTy Control of refractories manufactured in C
- ~
electric arc furnaces.
All wet and instrumental tests required to control refractories.
1
[
PROFESSIONAL Ql'ALIFICATIOlis 0F DAN PAUL TOMLINSON OFFICE OF INSPECTION A'?D Ef;FORCEMENT, REGION IV UNITED STATES NUCLEAR REGULATORY C0! MISSION Mr. Tomlinson is a Reactor Inspector in the Reactor Construction and Engineering Support firench of the Region IV Office of Inspection and Enforcement located in Arlington, Texas.
In this position, he assists in the preparations for inspections pcrtaining to nuclear facilities that are being constructed under an NRC Con-struction Pen.1it or Authorization.
He performs direct inspections of license activities during construction of facilities to ascertain status of compliance with design specifications, confomance of the as-built facility to the pro-visions of the Construction pennit or Authorization and whether the quality of ccnstruction is such that the facility can be operated safely.
Prior l'ork Histog 1978 - Present Reactor Inspector, Engineering Supp Eid reports routine inspections in,or_tJction - Plans, perfoms accordance with the provisions of the NRC Inspection and Enforcement Manual. Assists with or perfonts reactive inspections and investigations as required.
1973 - 1978 Ouality Assurace specialist - Served as a Resident Inspector for Defense LogisYics Administration, Los Angeles, at a manufacturing plant supplying components for the Navy Nuclear l
Program. Was responsible for procurement, fabrication, inspection and testing of control rod drive machanisms and valves for various naval programs.
1970 - 1973 quality Assurance Inspector - Perfonrad inspections in five disciplines of nondestructive examination in febrication shops and aboard various naval ships.
1968 - 1970 Supervisor Nondestructive Examination - Supervised from four to twelve inspectors in all'disciplTnes of nondestructive examination.
1901 - 1968 Quality Assurance Inspec_t_cr, - performed nondestructive excminations o
at Naval ~ Shipyard, San Fr e m 3.
Attended seven job-related schools during this period to improve qualifications and expertise.
i 1957 - 1961 Apprentice Shipfi_tter_ - Worked under the supervision of a journeyman as I acquired the basic knowledge and skills of the trade.
POORORIBRL
PROFESSIONAL QUALIFICATIONS OF J. I. TAPIA Office of Inspection and Enforcement, Region IV United States Nuclear Regulatory Commission Mr. Tapia is a Reactor Inspector in the Reactor Construction and Engineering Support Branch of the Region IV Office of Inspection and Enforcement located in Arlington, Texas.
In this position, he assists in the preparation for, and conducts, inspections pertaining to nuclear facilities under construction.
He performs direct inspection of licensee activities during construction of facilities to ascertain the status of compliance with design specifications, conformance of the as-built facility to the provisions of the Construction Permit and whether the quality of construction is such that the facility can be operated safely. Mr. Tapia has held this position since 1976.
Mr. Tapia received a Bachelor of Scier.ce degree from the University of Houston in 1975 and a Master of Science degree in civil engineering from Stanford University in 1976. Mr. Tapia is a member of The American Society of Civil Engineers; The International Society of Soil Mechanics and Foundation Engineering; and The American Concrete Institute, serving as a member of that Institutes' Committee on Quality Assurance Systems for Concrete.
Mr. Tapia is a certified engineer-in-training in both the States of California and Texas.
l l
i L