ML19347E470

Responds to NRC Ltr Re Violations Noted in IE Investigation Repts 50-498/78-13,50-499/78-13,50-498/78-12 & 50-499/78-12. Corrective Actions:Qc Personnel Retrained,Brown & Root Procedure Clarified & Previous Work Reviewed

ML19347E470
Person / Time
Site:	South Texas
Issue date:	10/03/1978
From:	Eric Turner HOUSTON LIGHTING & POWER CO.
To:	Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML16251A407	List: ML19347E470 ML19347E485 ML19347E488 ML19347E490 ML19347E492
References
ST-HL-AE-293, NUDOCS 8104270434
Download: ML19347E470 (7)

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L RG 8ox 1700 il fn ud Houston.Tc.sas 77001 ~ october 3, 19 73 ST-HL-AE-293 SFN: C-0510 Mr. W. C. Seidle '

' Chief, Reactor Construction and Engineering Support Branch USNRC, Region.IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011 i

SUBJECT:

Meeting with the NRC on Aqgust 15, 1978 RE: 50-49S RPT. 7S-13 50-499'RPT. 73-13 50-493 RPT. 75-12 ^

50-499 RPT. 78-12 -

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Dear Mr. Seidle:

We appreciate the opportunity to .,eet with you concerning the South Texas Pioject Electric Generating Station Civil QA Program.

Attached i's our response to the allegations presented in yot report 50-498/78-12 and 50-499/78-12. Our in-depth review 1 caves us confident that the construction work performed meets the requirements i, for our project. The~ actions taken to correct any possible weaknesses;

in our quality assurance program are open to'your review during future

inspections.

contact me.

If you have any questions regarding this catter, please Very truly yours, j

j d_ . !N E. A. Turner, Vice President Power Plant Construction and Technical Services' FAT /cas Attachment cc: Mr. R. A. Fra:ar Mr. H. L. Key

. STAFF EXHIBIT NO.10

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• RESPCNSE TO ?.I ' r.GATIC::S

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(RE: SRC. Report 50-495/7 2 and 50-499/7S-12)

Allegation No. 1:

Inability of civil QC inspectors to do their jobs due to issuance of new procedures withcu: sufficient training in the acw prc:cdures before implementation.

A. Discussien:

Our review showed that attendance at training courses on the revised procedures was no: ndatory for QC pe'rsonnel. Therefore, c:.known to SSR canagement, several inspectors did not attend. All inspectors were given a reading list including a check sheet which had to be signed acknowledging that he had read and understood each procedure.

'B. Corrective Action:

i The training was repeated and the reading lis:s reissued and signed.

C. Action Taken to Prevent Recurrence:

B5R will take attendance rosters to ensure that appropriate perscarel have received required training. Make-up training will be conducted when needed.

Allegation No. 2:

The STP QA Program does not provide an adequate nonconformance reporting system.

A. Discussion:

There have been interpreta:ional problems relative to the use of Nenconfornance Reports (NCR) versus Field Requests for Engineering Action (FREA).

3. Corrective Action:

A clarification has been added to the B5R procedure stating defini-tively ahen an NCR is to,be used and when a FREA can be prepared.

C. Action Taken to Prevent Recurrence:

HLSP site QA is closely monitoring nonconforcance reporting by SSR and has increased the performance of surveillance of concrete placement inspection.

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• QA rt :tance to issue Nonconfcrman by QC.

Inadequate support of QC inspectors by QA.. . ports when problens A. Discussion:

It was determined that only one NCR was not processed. This case involved an out of scquence approval sign-of f of an inspection record and it was not appropriate to process the NCR since the condition involved. was promptly corrected and no defective material was HLSP cannot find any evidence to substantiate these allegations; however, it appears that there is a n'ced for rore effective communication between the QC inspectors and QC supervision.

B. Corrective Action:

e The. B5R Project QA Manager is striving to spend more time in the field to ensure the effectiveness of the program.

the B5R Project QA Manager has counselled the BER QA/QC staffAdd relative to objectives of QA/QC and the necessity of reporting all departures fron design, Codes, standards or safe practices.

HLSP has conducted an extensive review of puplacement and placement activities to assure that quality has not been

, compromised due to the condition described by these alle;ations.

No abnormalities were found during this review.

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C.

Action Taken to Prevent Recurrence:

HLSP site QA is closely monitoring B5R QA/QC activitin.

Allegation No. 5:

Poor document personnel. control for drawings and docu ents used by craft a.nd QC A. Discussion:

Due to procedural differences, QC personnel in the field were not obtaining dccumentation in the same time frame as craft personnel.

In spite of this delay, QC inspection personnel had, on their own initiative, actively sought out the correct documentation when disparities were noted between craft and QC documentation.

B. Corrective Action:

Extensive review of prtvlous work hns been done to ensure that no work .:ss accepted to in:orrect design documen. . tion. Additionally, the precedure for prcviding documentation to the inspectors has been revised to ensure proper proccssing with runners assigned to distribute new documents and pick up out-d.ited revisions fcca the field.

C. Action Taken to Prevent .:ecurrence:

In addition to the revised procedure for transmitting documents to the inspectors, air conditioned udrk stations ucre ordered and are now being received to provide better conditions for inspectors to review documentation and prepare for upcoming inspections.

' Allegation No. 6:

Inaccurate Cadweld as-built drawings.

A. Discussion:

This allegation has been cade several times before and has been

, shown by extensive review by B5R, HLSP and the NRC to be ensubstantiated. Another review by B5R and HLSP has reached the sane conclusion.

B. Corrective Action:

No corrective action was required.

C. Recurrence Control:

HLSP will continue to conitor this item to ensure conpliance with the procedures.

Allegation No. 7:

Inaccessibility of upper management.

A. Discussion:

In order to provide more effective management of the QA/QC program, the B5R Project QA .thnager has recently reorgani:ed the site QA/QC organization and redefined some job descriptions.

As a result of the changes, some QC inspectors are unhappy. because they feel they no longer have the latitude they need to perform their job. Our review showed these opinions were unjustified.

Effective systems for identification of probices to management are implemented.

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_B. 'orrective Action:

3GR canagecent' has reaffirred, by =eco and personal neeting, ltha:L

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, an'disconcerns.

the . responsibility of the inspectors to. identify problens-

- Additionally, ther have been directed that.- they may pursue valid concerns past- their itcedi~ ate supervisor, even if he disagrees withi them, without fear of reprisal.

C. . Recurrence Control:

2 The B&R Project _QA abnager_ has initiated core ' frequent observaticas and discussions in the field with the inspectors in order to -

-i provide visibility of nanasenent ' concern and opportunity to

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discuss QC inspectors' concerns. IILSP site QA personnel willi continue to be receptive .to reviewing QC inspectors' concerns.

Allegation No. 8:

-UnbuepressurebyConstruction.

i A. Discussion:

There are pressures on the Inspectors to perform in a tinely and expeditious tanner as well as to assure ' quality; however,

' ' if the inspector performs his job effectively, we do not view these pressures as abnormal. There have been occasions when preplacement "punchlists" appeared abnormally long. The quantity of itens on these lists.cade .the inspector think that the Construction engineer was not properly assuming his responsibility or that construction was trying to pass off incorrect work. It is our cpinion that these types of findings are those that QC inspectors should find, but the quantity concerns us.

B. Corrective Action:

F6R Construction has directed its Construction engineers and craft forecen to ensure that craft personnel are making every effort to meet the project recuirenents, lihen compliance with specification or procedure requirements cannot be ce: within the limitations of the design, .either the FREA or NCR syste= will be utili;ed to resolve the problea. Additionally, the use of the "punchlist" has been odified to allow anyone who identified an item to enter the infor ation on the punchlist. SSR will

/ assign additional personnel to Construction Engineering to perform construction ~ inspection of inprocess work.

u. ..ecurrence control:

<> + I The B5R Project QA 35 nager has initiated more frequent observatior:s and discussions in the field with the inspectors in crder to provide visibility inspectors'of concerns.

canage :nt concern and opportunity to discuss QC As stated earlier, HL5P' site QA personnel uil continue to be receptive to reviewing QC inspectors' concerns.

In additien, HL6P QA tanagecent has ce: with the 35R QC Inspectors and "Ljervisors to review the project objectives and the role of QA/QC in achieving those objectives. Erphasis was placed on the absolute necessity of team work to do the job right and to utilize the availabic project problem solving channels for i<'enti fying and resolving problems. Plans for enhancing the c. etiveness of cur program were revies.cd also.

Allegation No. 9:

Performance of repairs without approved procedures.

. N. Discussion:

There have been occasions .shere repair procedures were authorized via the telephone prior to obtaining an approved FREA.

. B. Corrective Action:

The use of telephone ninutes has been restricted solely to inter-preting the intent of design documents. In all other cases either the FREA or Docunent Change Notice (DCN) systen must be used. Those cases involving lack of approved procedures have been reviewed and no unacceptable conditions were found. B5R Engineering will transfer appropriate responsibility to the the Construction engineers or to design engineers assigned to -

the field to enhance resolution of field engineering problems.

C. Recurrence Control:

B5R QA/QC and HL5P QA will continue to conitor ongoing repair activities to ensure compliance with the procedural requirements.

Allegation No. 10:

Inability of Construction Engineering.

A. Discussion:

. As noted earlier, the quantity of items on the construction "punchlist' tends to indicate that the craf t personnel, craf t foreman and Construct engineers are eithdr not fully aware of procedural requirecents or have not consistently implemented these requirements.

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_tvAaccLive Action

• B5R QC and Construction forces h'.vc been counselled 'eith re;ard to their respcnsibilitics and nethods to be ysed in the eff2etive supervision or their p0rsonnel. Additional trainin; ..ill be provided to both Construction and QC personnel. B5R Construction engineering will assign additional personnel to perfJrm inp:ncess review of teork to ensure tha desi;n dactnents and canstruction procedures are net.

C. Recurrence Control:

Both HL5F QA nnd Constructicn Division personnel have stepped un their surveillance of ccnstructi:n activities to casure corpliance.

Also, more, effective supervision will be provided by 3LR to both Construction and QC on all shifts.

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C.,# UNIT!D STATES NUOLEAR REGL;.ATORY COMMIOSION "

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. ... November 15, 1978 5 lE.

In Reply Refer To:

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'IE RLE COPY M

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Docket No. 50-498/Rpt. 7S-10 EE 50-499/Rpt. 7S-16 @H EE EEE EE=

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Houston Lighting and Power Company T.x ATTN: Mr. E. A. Turner, Vice President =E.

Power Plant Construction and E-E Technical Services lll5{

Post Office Box 1700 ta+

Houston, Texas 77001  !.i5 h!M Gentlemen: Es lE This refers to the inspection conducted by Mr. W. G. Hubacek and other EE members of our staff during the period October 24-27, 1978, of activi- ME ties authorized by NRC Construction Permit *:os. CPPR-128 and 129 for E=f South Texas Project, Units No. I and 2, and to the discussion of our E'i findings with Mr. W. N. Phillips and other members of your staff at [.3 the conclusion of the inspection. .ggg EE Areas examined during the inspection and our findings are discussed in [M the enclosed inspection report. Within these areas, the inspection E:.=

consisted of selective examination of procedures and representative h==;

records, interviews with personnel, and c:)servations by the inspectors.

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During the inspection, it was found that certain activities under your '=M

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license appear to be in noncompliar.ca with Appendix 3 to 10 CFR 50 of the NRC Regulations, " Quality Assurance Critieria for Nuclear Power E=i

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Plants." The items of noncompliance and references to the pertinent requirements are identified in the enclosed Notice of Violation. .gg We have also examined actions you have taken with regard to previously 3 identified inspection findings. The status of thesa items is identified  ;=.. .

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in paragraph 2 of the enclosed report.

Es One new unresolved icem is identified in paragraph 7 of the enclosed igii report.

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.:=3-STAFF EXHIBIT Nu.11 pH

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1 J-g- g L.E s Houston Lighting & Power IM:

Company November 15, 1978 p.e.pe.a+

This notice is sent to you pursuar.t to the provisions of Section 2.201 EEE of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal  !%i Regulations. Section 2.201 requires you to submit to this office, with-

[i in 30 days of your receipt of this notice, a written statement or expla- "==

nation in reply including: (1) corrective steps which have been taken by :42 you, and the results achieved; (2) corrective steps which will be taken

, to avoid further noncompliance; and (3) the date when full compliance  %

tiL will be achieved.

g In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the fb d$

enclosed inspection report will be placed in the NRC's Public Document t==

Room. If the report contains any information that you believe to be 55 proprietary, it is necessary that you submit a written application to EE=

this office, within 20 days of the date of this letter, requesting that ME!

such inforration be withheld from public disclosure. The application *?

i must include a full statement of the reasons why it is claimed tnat the E..

infomation is proprietary. The applicatior, should be prepared so that !55 any proorietary infomation identified is contained in an enclosure to iisi the application, since the applicacion without the enclosure will also iEl be placed in the Public Document Room. If we do not hear from you in eel this regard within the specified period, the report will be placed in Eis::-

the Public Document Room. iEE ss Should you have any questions concerning this inspection, we will be pleased to discuss them with you. .

Sincerely,

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W. C. Seidt J Chief

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Reactor Construction and ..

Engineering Support Branch  :...

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Enclosure:

IE Inspection Report tio. 50-498/73-16

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50-499/78 -16

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Appendix A n.

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NOTICE OF VIOL

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Based on the results of the NR inspection conducted on October 24-27, 5 1978, it appears that cercain of your activities were not conducted in .M full compitance with the conditions of your NRC Construction Pemit Nos. CPPR-128 and 129 as indicated below: g

1. Failure to Provide Procedure for Housekeecing Insoection k lEt 10 CFR Part 50, Appendix B, Criterion Y requires that activities KEE affecting quality be prescribed by documented instructions or W~'

procedures appropriate to the circumstances. .=t Procedure GCP-4, " Housekeeping," Rev. O referenced Procedure QCP-2.3, " Housekeeping," wnich contained QA requirements for 5

inspection of housekeeping. g gg-Contrary to the above:  !=

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Procedure QCP-2.3 was recalled on July 17, 1978, and was not m- W placed until October 27, 1978. There was no procedure in effect h=e during the interim period which prescribed QA inspection of house- T keeping. Q

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This is an infraction. [f

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2.- Failure to Provide Accectance Criteria b 10 CFR Part 50, Appendix B, .'riterion V requires that procedures include appropriate quantitative and qualitative acceptance cri-k;'.1 teria for detemining that important activities have been properly gig accomplished. p_

mi Contrary to the above: sc It was detemined by the IE inspector that the megger testing of Class IE motors was performed for the eignt mon:hs preceding tnis inspection without acceptance criteria for detemining that the readings cbtained were acceptable. The licensee die not identify F acceptance criteria for megger tests performed en Cem;cnent Cooling Z Water pum: motors Nos. 3R20lNPA101A, B, C and 3R20lNPA201A, B, C, 7; as part of the warenouse maintenance program described in procecure  :;=ig ,

MCP-3. i=3 Lan This is an infraction. G_l

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3. Failure to Follow'Aporoved Procedures gg 10 CFR Part 50, Appendix B, Criterion V reqeires that activities khk affecting quality shall be accomplished in a:cordance with in- "EE structions and prc edures developed for these activit;es. ggg mEE B&R Procedure MCP-3, Rev. 3 of August 4,1978, paragraph 3.1.2.2 iME and Appendix C, paragraphs iia. thru d. *wauires 100% surveillance E55 of maintenance on Class IE equipment.and initials of QC personnel . iiEEi performing this surveillance on all the Warehouse Maintenance [Mij

. Cards. pgg

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Contrary to the above: Mi Review of the Warehouse Maintenance Cards for Component Cooling ..".

Water pump motors Nos. 3R20lNPA101 A, B, C and 3R20lNPA201A, B, C iii revealed that QC surveillance had been performed on only 25% of 555 the maintenance activities as evidenced by QC personnel initials  !?5=

on only 25% of the Warehouse Maintenance Cards. Licensee repre- [ME sentatives acknowledged this to be the case. ((

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This is an infraction. ij@g

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U. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT .

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REGION IV  :==

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Report No. 50-498/78-16; 50-499/78-16 Ei:

Docket No. 50-498; 50-499 Categcry A2 {g-j Licensee: Houston Lighting and Power Company [5E Post Office Box 1700  !==

Houston, Texas 77001 i{

Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County, Texas .zie Inspection conducted: October 24-27, 1978 g='

?My Inspectors: N w- // !78 ~

W. G. Hubacek, Reactor Inspector, Projects Date EM

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Se'ction (Paragraphs 1, 2, 3, 4, 5, 6, 8, 10 & 11)

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w5 I! !E.~1F Date l _ J. 1.j apia, Reaptor Inspector, Engineering l Suppe Section (Paragraphs 2, 8 & 9) M..

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h < k . ll 15 OYL Date L. E. Mprtin,' Reactor Inspector, Engineering ==~

"yppt/rt Sectioh (Paragraph 7)

Other Accompanying Personnel: R. E. Hall, Chief, Engineering Support Section Approved: -- ~

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W. A. Crossman, Cnief, Project Section Date ij.:3

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DUPLICATE DOCUMENT b  !' ' '

i ering support Section Cate Entire docurcent previously '"

entered into system under:

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