ML19347E473
See also: IR 05000498/1980013
Text
{{#Wiki_filter:_ _ _ _ _ . . _ U. S. NUCLEAR REGULATORY COMMISSION 0 FFICE F INSPECTI N AN ENF RCEMENT , REGION IV Report No. 50-498/80-13; 50-499/80-13 Oocket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 - Houston, Texas 77001 . Facility Name: South Texas Project, Units 1 and 2 Investigation at: South Texas Project, Matagert.. County, Texas Investigation conducted: May 27, 1980, and February 25-27, 1981 Inspectors: M. A.N-oet.( 3 //2/3'/ W. G. Hubacek, Reactor Inspector Date Projects Section No. 3 h p .3-17-84 - 0. P. Tom b-son, Reactor Inspector Date Engineering and Materials Section . Approved: F~ 3//7/8/ W. A. Crossman, Chief, Projects Section No. 3 Date p 3-n-7/ R. E. Hall, ' Acting Chief, Engineering and Date Materials Section Investication Summary: Investication on May 27, 1980, and February 25-27, 1981 (Recort No. 50-498/80-13: 50-499/80-13) Ara =s Invasticated: SP cial, eranr.curced investigati:n of all ;;d irregularities
' in the welding program; vendor surveillance program; and safety-related piping. The investigation involved forty-three hours by two NRC inspectors. Results: No violations or deviations were identified. l l 8.104270 @ . - . . . ._ . -- . - . - - - - . -.
. . _ INTRODUCTION The South Texas Project (STP), Units No. I and No. 2 are under construction in Matagorda County, Texas, near the town of Wadsworth, Texas. Houston Lighting and Power Company (HLAP) is the Construction Permit holder. Brown and Root, Incorporated is both Architect Engineer and Constructor for the project. REASON FOR INVESTIGATION On May 1, 1980, a former employee at the STP site contacted the Region IV Office by telephone and expressed concerns related to welding activities at STP. ' Region IV contacted the individual by telephone on May 5, 1980, and obtainea additional information concerning the welding program. The individual was interviewed by Region IV inspectors at his home on May 27, 1980, at which time he reiterated his original concerns regarding the welding program and expressed additional concerns regarding vendor surveillance and safety-related piping activities. SUMMARY OF FACTS , , The following specific allegations were expressed: 1. Some 150 to 200 safety-related structural welds in the Reactor Containment Building (RCB) were made "out of position." 2. A Brown and Root (B&R) welding engineer allowed the welder qualification training school to rotate weld test specimens during qualification of welders, contrary to requirements that the test specimens be stationary. l 3. Welds in approximately four or five runs of 14" to 20" carbon steel pipe located in the Unit 1 Mechanical Electrical Auxiliary Building (MEAB) failed to meet ANSI B31.1 visual inspection requirements. i 4. Weld Data Cards for MEAB work which took place on Monday and Tuesday ! were signed by an individual who had died the previous Friday. l 5. Reactor Coolant System welding was done without an In-Service Inspection j (ISI) representative present at the site. 6. Licensee QA personnel did not monitor welding on the Reactor Coolant System (RCS) during the second shift. 7. DurjngthefirstRCSlooppipingweld,interpasstemperatgresreached ! 600 F in some cases. Maximum allowed temoerature was 350 F. 1 l 8. A B&R Level II radiographic inspector was not properly qualified to perform inspecticas at this level af p.oficiency. ! 2 l l . - - . _ _ . -.-. - - - - . _ -
. , _ Radiographs of the RCS loop piping welds were being accepted to a 9. 4T sensitivity rather than to the required and more stringent 2T sensitivity. Minimum pipe wall thickness problems identified at another nuclear site .10. were not addressed at STP by B&R. 11. The B&R vendor surveillance program was deficient. Minimum pipe spacing requirements were not considered by B&R during design 12. of STP. - - CONCLUSIONS The alleged 150 to 200 "out of position" structural welds in the RCB 1. could not be substantiated or refuted. No evidence of "out of position" welds was found during review of records and discussions with licensee In any event, all of the safety-related and contractor representatives. structural welds will be re-examined and repaired as necessary as a result of the licensee's ccmmitment to the NRC Order to Show Cause, dated April 30, 1980. The alleged rotation of weld test specimens during welder qualifications 2. was confirmed; however, this matter had previously been identified as an unresolved item during NRC Investigation No. 79-19 and corrective action was verified during NRC Inspection No. 80-24. The allegation that welds in 14" and 20" carbon steel pipe failed to meet 3. ANSI B31.1 visual inspection requirements was substantiated in that it was determined that the ASME Boiler and Pressure Vessel (B&PV) Code, Class 3 (not ANSI B31.1) pipe welds did not meet code visual acceptance requirements and that seven of eight information radiographs taken exhibited rejectable These welds will be 100% radiographed and repaired as necessary indications. in accordance with the licensee's commitments in response to the NRC Order to Show Cause. . The allegation that Weld Data Cards (WDCs) were prematurely signed on 4. Friday for work that took place on the following Monday and Tuesday was partially substantiated in that it was determined that Weld Material Corrective action to Requests (WMRs) were presigned but WDCs were not. preclude recurrence of the presigning of WMRs is described in B&R Corrective Action k' quest (CAR) S-165. The allegation that RCS welding was done without an ISI representative 5. present at the site was found to be without merit as it was determined that thcre was no requirement for an ISI representative to be on site Brown and Root Procedure MECP-4 wnica adaresses ASME I&PV at that time. Ccde, Section XI requirements for in-service inspection of nuclear componer:s was issued and implemented prior to the start of RCS welding. 3 . - - - ._ , - , - __ -,- - . - - - - ._. . . -
. _ 6. The allegation that licensee QA personnel did not monitor welding on the RCS during the second shift was not substantiated. It was determined that licensee QA personnel had monitored second shift welding activities although there was no specific procedural requirement to do so. 7. The allegation that interpass temperatures reached'600 F during the first RCS weld was not substantiated by record reviews or interviews with cognizant personnel. 8. The allegation that a B&R Level II radiographer was not properly qualified was not substantiated. Review of records of all radiographers on site
' indicated that all were qualified and certified at that time in accordance with the requirements of SNT-TC-1A. , 9. The allegation that radiographs of RCS loop piping welds were accepted to a 4T sensitivity rather than 2T sensitivity was not substantiated. Review of radiographs of RCS welds indicated that a 2T sensitivity was used as the basis for accepting or rejecting the welds. 10. The alleged failure of B&R to address pipe minimum wall thickness problems which were found at another site was determined to be irrelevant to STP in that the affected pipe vendor did not supply pipe to STP. The licensee stated that a pipe wall thickness verification program is planned for STP. 11. The alleged deficiency of the B&R vendor surveillance program was confirmed; however, the licensee had previously reported the deficiencies in the program r to the NRC in accordance with the requirements of 10 CFR Part 50.55(e) and corrective action on this matter is continuing. ! 12. The allegation that minimum pipe spacing requirements were not considered by B&R during design of STP was not substantiated. Pipe spacing require- ments are addressed in B&R design standards which are part of the B&R " Nuclear Power Plant Design and Dratting Manual-Nuclear Steam Supply Systems" that is applicable to the design of STP. l ! l 4 1 ! - . . - - - - . . . . - . .- . . . - - - . . . . .- . - - - - , ~.
. , - Details 1. Persons Contacted Principal Licensee Employees
- R. A. Frazar, Quality Assurance Manager
- L. D. Wilson, Project QA Supervisor (Mechanical /NDE)
- T. J. Jordan, Quality Systems Supervisor
W. Jones, Welding Supervisor G. Marshall, Senior QA Specialist - . Other Personnel Former employee at the South Texas Project W. J. Friedrich, QA Manager for Brown and Root (B&R), Management Analysis Company (MAC)
- R. L. Hand, Project General QA Supervisor for
Houston Lighting and Power Company (HL&P), MAC
- C. L. Harvey, QA Specialist for HL&P, Gilbert Associates
F. G. Miller, Chief Welding Engineer, B&R R. Young, Lead Weld Technician, B&R K. Silverthorne, Project Welding Engineer, B&R D. Shumway, NDE Superintendent, B&R H. Bachmyer, Weld Technician, B&R The NRC inspectc s also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.
- Denotes those attending the exit interview on February 27, 1981.
2. Investigation Details The following specific allegations were investigated during this investiga- tion. Resultant findings of the NRC investigation team are indicated below: a. Allegation No. 1 Some 150 to 260 safety-related structural welds in the RCB were made "out of position." Investigation Findings: The NRC inspectors interviewed cognizant licensee and contractor employees and reviewed records pertaining to structural steel welding in the RCS including welder qualification records for the paricd from Octcbar 1973 through February 1950, a support location drawing, and all WMRs related to welders with limited qualifications during the same time period. The NRC inspectors found no evidence that the structural weids were made by welders whr were not qualified in the positions used; however, it could not be conclusively determined that no "out of position" welds 5 - _ - - , ._ . .. . - . . . . .. _ _. -- . , _ - - _ _ _ - .
- . _ It was noted that the affected welds were included had been made. in the licensee's commitment to re-examine and repair as necessary, 100% of the safety-related structural welds stated in the response to the Order to Show Cause, dated April 30, 1980. The NRC inspectors had no further questions regarding this allegation. b. Allegation No. 2 A B&R welding engineer allowed the welder qualification training school to rotate weld test specimens during qualification of welders, contrary to requirements that the test specimens be - a stationary. Investigation Findings The NRC inspectors observed that rotation of the weld test specimens was prev ously identified in NRC Investigation Report No. 79-19 as i unresolved item No. 79-19-31. It had been determined that, because of limited access to the test specimen in the welding booths,, welders while were previously allowed to rotate test srecimens(pipe) uy 180 welding the pipe in the 2G position which required the axis of the pipe to be vertical and the weld deposited circumferentially in the Corrective action relative to this matter, horizontal position. which prohibits rotation of test specimens, was completed by the licensee and the unresolved item was subsequently closed in NRC Report No. 80-24. The NRC inspectors had no further questions regarding this allegation. Allegation No. 3 c. Welds in approximately four or five runs of 14" to 20" carbon steel pipe located in the Unit 1 Mechanical Electrical Auxiliary Building (MEAB) failed to meet ANSI B31.1 visual inspection require- ments. Investigation Findings The NRC inspectors determined that the failure of the subject welds r (which are ASME B&PV Code, Class 3, not ANSI B31.1) to meet v inspection requirements had previously been identified by the licen Subsequently, eight information radiographs were taken of the welds These welds are seven of which exhibited rejectable indications. include and repaired as nec:::ary in ic:Ordance with the licensee's 30, 1550. commitments to the NRC Order to Show Cause, dated April The NRC inspectors had no further questions regarding this allegat l t i b . . _ . . _. , . _ . . _ . . , _ _ . - , , _ , _ _ . _ _ . _. ,_..._ ., - .
- , _ d. Allegation No. 4 Weld Data Cards for MEAB work which took place on Monday and Tuesday were signed by an individual who had died the previous Friday. Investigation Findings During interviews with licensee and contractor representatives, the NRC inspectors were informed that the incident involved WMRs, not WDCs as alleged. The incident, which involved several cases of WNRs that were initialled by the deceased individual and dated ' following his death, was described in Corrective Action Report No. 5-165 initiated on November 12, 1979. It was considered acceptable practice for weld technicians to review pre prepared hMRs for compliance with procedures to facilitate construction, but not acceptable for the weld technicians to leave the review dates incomplete for others to complete on the dates of weld material issuance. The actual date of the weld technicians review was required to be entered on the kNR. No other cases of improperly initialled WNRs were found. The NRC inspectors had no further questions regarding this allegation. e. Allegation No. 5 Reactor Coolant System welding was done without an ISI representative present. Investigation Findings The NRC inspectors determined that the presence of an ISI representa- tive during RCS welding was not. required. Discussions with licensee representatives indicated that an ISI contractor had been consulted and that B&R Procedure MECP-4, which addresses ASME B&PV Code, Section XI rcquirements for in-service inspection of nuclear components, was issued and implemented prior to the start of RCS welding. The NRC inspectors had no further questions regarding this allegation. f. Allegation No. 6 Licensee QA personnel did not monitor welding on the RCS during the second shift. 7
. - - Investigation Findings The NRC inspect,rs determined that there were no specific procedural requirements for licensee monitoring of second shift welding activities, but that monitoring was performed on an "as needed" basis as determined by the licensee QA Supervi e r, Mechanical /NDE. A licensee representative stated that he monitored welding activities approximately five times during initial welding of the RCS; however, these inspections were not documented. The NRC inspectors had no further questions regarding this allegation.
g. Allegation No. 7 DurgngthefirstRCSloorpipingweld,interpasstemperatgresreached 600 F in some cases. Maximum allowed temperature was 350 F. Investigation Findincs The NRC inspectors interviewed licensee and contractor representatives who were involved in the firs RCS loop piping weld. All of the individuals interviewed stated that the initial RCS pipe weld was doneslowlyanddeliberatelyandthattherateofwejdmetaldepositions was such that reaching interpass temperatures of 600 F would have been impossible. Review of recordg failed to indicate any instances in which the maximum allowed 350 F interpass temperature was reached or exceeded. The NRC inspectors had no further questions regarding this allegation. h. Allegation No. 8 A B&R Level II radiographic inspector was not properly qualified to perform inspections at this level of proficiency. Investigation Findings The NRC inspectors reviewed personnel records of all radiographers employed on site during the alleger's term of employment. The minimum education and experience requirements of SNT-TC-1A, " Personnel Qualifications and Certification in Nondestructive Testing." appear to have been met in all cases. The NRC inspectors had no further questions regarding this allegation. i. Allecation No. 9 Radiograohs of the RCS loop piping welds were being accepted to a 4T sensitivity rather than to the required and acre stringent 2T sensitivity. 8 . _ __ . . . _ _ . _ . __, ___ _ _ _____ ___.__._ - . _ .
> Investigation Findings The NRC inspectors . reviewed the ASME B&PV Code, Section V, Article 2 to determine the correct sensitivity level for interpretation of these radiographs. The Code states that a 50 designated source-side penetrameter shall display at least a 2T sensitivity. This means that - a penetrameter thickness of 0.050" shall be used and shall exhibit, on the radiograph, an image of a 0.100" diameter hole. The NRC inspectors reviewed the radiographs of Reactor Coolant Loop piping joints FW-0011, FW-0012, FW-0019 and FW-0027. No provision is made to record the radiograph sensitivity level on the film interpretation sheet, but ' viewing of the radiographs indicated that each film exiti5ited an image of the IT hole. The radiographs are, therefore, showing a p9retrameter hole of 0.050" or a 1% sensitivity as opposed to the Code required 2% sensitivity on a 2% penetrameter. The radiographic qsality of the Reactor Coolant Loop piping exceeds the requirements established in the ASME B&PV Code. The NRC inspectors had no further questions regardir.g this allegation. j. Allegation No. 10 Minimum pipe wall thickness problems identified at another nuclear site were not addressed at STP by B&R. Investigation Findings During interviews of licer.see and contractor representatives, the NRC inspectors were informed that the minimum pipe wall thickness problems identified at another nuclear site were not applicable to STP in that the vendor of the affected pipe was not a pipe supplier for STP. This was later confirmed by contact with the NRC inspector assigned to the other site. The licensee also stated that no evidence of minimum pipe wall thickness problems had been identified at STP; but a procedure for ultrasonic verification of pipe wall thickness is being developed and will be implemented on a sampling basis. l The NRC inspectors had no further questions regarding this allegation. k. Allegation No. 11 The B&R vendor surveillance program was deficient. Investigation Findings On two occasions the licensee has regert:d, in accordance with i 10 CFR Part 50.55(e), deficiencies in the Brown and Root vendor surveillance program. The first report on December 4, 1979, involved the failure of the 9&R vendor surveillance program to detect an apparent deficiency related to certification of welders at a Category I steel supplier's facility. A final report on this matter was submitted to the NRC on January 4, 19 0. As a . 9 . m vc -,--- - v -. . e =w- g y--isewe.-.7---. e.* ~ v w - w w
. _ . - . . - _ result of this deficiency, B&R initiated a vendor control program to review the effectiveness of prior vendor coordination and surveillance activities. Subsequent identification of generic concerns with the quality programs related to the overall procurement cycle of purchased materials and equipment for the South Texas Project led to notification of the NRC on June 13, 1980, of the second potentially reportable deficiency in the B&R vendor surveillance program. Corrective action ' on this matter is continuing and is expected to continue through October 1981. The NRC inspectors had no further questions regarding this allegation.
1. Allegation No. 12 Minimum pipe spacing requirements were not considered by B&R during design of STP. , Investigation Findings Interviews with licensee representatives indicated that pipe spacing is addressed in design standards wnich are part of the B&R " Nuclear Power Department Design and Drafting Manual for Nuclear Steam Supply Systems," which is applicable to the South Texas Project. The NRC inspectors observed that minimum pipe spacing requirements were con- tained in the above manual. The NRC inr 'ctors had no further questions regarding this allegation. 3. Exit Interview The NRC inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the investigation on February 27, 1981. The NRC inspectors summarized the purpose and scope of the investigation and the findings. , , eh. 10 ' .s , ,, . - - - _ . . .- - - , . . , . - , . .-- - - - - - , . . - - - . - . , - , . . , - . - . , - . - - . ~ , , . . .
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- > _ . INVESTIGATION PMN IE Investigation Report No. 50-498/80-13; 50-499/80-13 Licensee: Houston Lighting and Power Company Location: .Matagorda County, Texas Facility: South Texas Project, Units 1 & 2 . Type of Licensee: E, 1250 MWe, PWR Type of Investigation: Allegations of improper welding activities Dates of Invese,igation: May~27, 1980 and February 25-27, 1981 Dates of Previous Ir.pection: May 12-15, 1980 Inspectors: WGHubacek, DPTomlinson SCOPE OF INVESTIGATION 099014B - allegations by a former HL&P Welding Supervisor 2307038 l l l I L ! .G W2GJ rh Is: - Reactor InspectJr Date Approved Sate -- ____ - -. _ .- . . , , ., . .. -. _ - . . - . ..
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. W / mafsow% UNITED STATES NUCLEAR, REGULATORY COMMISSION ,
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. 'S REGloN IV
7 i "f E 611 RYAN Pt.AZA DRlVE sulTE 1000 7. . AAtJNGTON, TEXAS 76012
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. % .w.t J I October 9, 1980
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l In Reply PAfar To: RIV ' Docket No. 50-498/Rpt. 80-14 50-499/Rpt. 80-14 . Houston lighting and Power Company ATIN: Mr. G. W. Opraa, Executive Vica Frasidenc Power Planc Construccion and Tae%4*=1 Services Post Offica Box 1700 Houscou, Tazas 77001 Genciamun: This refers to che investigacion conduccad by Messrs. D. D. DrisM11 and R. K. Earr of our staff during the period June 5-6, 18-20 and 24-25, 1980, of activicias authorized by NRC Conscruccion Permics Nos. C??R-128 and 129 for cha South Texas Project, Units Nos. I and 2, concerad's allegacions of delacion of infor=acion on an NCR, ine%4 ^ef on of QC inspectors, unqualified promocion of an individual, and falsificacion of 3E.' surveillanca records. The investigacion findings are discussed in the enclosed investigacion report. Based on the investigacion findings, the allegacions concerning incinidation of inspectors and the promocion of an unqualified individual cannot be sub- stanciacad. Falsificacion of B&1 QC records was confirmed. In addition, 1: vas substanciated thac informacion on an NCR was omitted, however the infor- mation did noc altar che correceive accion of the macaricis involved.
In accordance with See:1on 2.790 of ha NEC's " Rules of Practice," ? arc 2, l Title 10, Code of Federal Regulacions, a copy of this lac ar and the enclosed investigacion report will be placed in the NEC's Public Documanc Roon. If
- he report contains any informacion chac you believe to be propriscary, it is
necessary chac you submic a wric:an applicacion to this offica, vichin 20 days of the data of dis lactar, requesting chas such infor=acion be widheld from public disclosura. na applicacion musc include a full scacemanc of the reasons l why ic is claimed thac :he informacion is propriacary. 3e applicacion should be preparsd so that any propriacary informacion identified is contained in an enclosura :o the applicacion, since the applicacion vi:houc :he enclosun vill also be placed in the Public Doc unant Roon. If we do coc haar fron you in this regard within the specliisd period, che report v4'i be placad in tha ?ublic Documanc Roon. l l STAFF EXHIBIT NO. 60 Otd6 of $01/20006 . - -. - . - - - - - - - . - - - - - - .. -
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e . . . Houston Lighting and Power Company -2- Octo'er 9, 1980 o Should you have any questions concarning this investigation, we will be pie.2 sed to discuss them with you. Sincarely, f' Kari 7. Seyfria Director . Inclosure: II Invas:13ation Report No. 56-498/80-14 1 50-499/S0-14 , i ! l l r . . _ _ _ _ _ . . - _ . , . - - , -
. . _ . . . U.' S. NUCI. EAR REGUI.ATORY CC.'OfISSION OFFICE OF INSPECTION AND ENTORCE.'S.NT REGION IV Investigation Report No. STN 50-498/80-14; 50-499/80-14 Docket No. STN 50-498 ' Licensee: Houston Lighting and Power Ccapany Facility: South Texas Project, Units Nos. I and 2 Investigation at: 3ay City, Matagorda County, Texas Investigation Conducted: June 5-6; June 18-20; June 24-26, 1980 . Investigator: WG - 8 7 < j f f c) R. K. if(rr Investigation Specialist C4 te / r - Investigator: ( a k . /) O ' 2&h, 6%C D. D.7:5Eill, Investig'Itton Specialist Date k [p.(A.Crossaan, Chief,ProjectsSection,EC&IS Reviewed by: - . A.dI.--- 74WPC Date {i Branch -f Reviewed by: ~ /,- . ~ ' #!IL' -- - 'd C.Seidle,glef,RC&ESBranca Date . i f I I l l . T4.T { 'O .g 7 w f My_ Nge . s -I '8)W,
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Entire document previously - '. - entered into systen under: 70 ll266096
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. . . _ . . 2 i Summarv 1 ' Investigation on June 5-6; June 18-20; June 24-26, 1980 (Report No. 50-498/80-14; 50-499/80-14) Area Investigated: Allegations that some Brown & Root (B&R) subcontract surveillance records were falsified, that B&R Quality Control inspectors were ! being intimidated, and that an unqualified person was promoted to a B&R
supervisory position. This investigation involved 72 investigator-hours by two (2) NRC investigators. 1 Results 4 Allegations that some subcontract surveillance records were falsified were confirmed. Investigation of intimidation of QC inspectors and promotion . of an unqualified person disclosed that these allegations have no merit. i > '
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.g . _ _ . . . _ . __ _ _ _ - . - . . /- n ste '% a o , UNITED STATES ' ! ' , , ,. , j NUCLEAR REGULATORY COMMISSION -,. E REGION IV 3. ,[[ 611 RYAN PLAZA ORIVE. SutTE 1000 %, ...../ - ARLINGTON. TEXAS 76012 June 30, 1980 In Reply Refer To: RIV Docket Nos. 50-498; 50-49" ,_. 80-15 . Houston Lighting & Power Company ATTN: Mr. G. W. Oprea , Jr. Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen: This refers to the investigation conducted by Messrs. R. K. Herr and D. D. Oriskill, of our staff, on June 5-6, 1980, of activities authorized by NRC Construction Pemits Nos. CPPR-128 and CPPR-129 for South Texas Project, Units 1 and 2, respectively. Since this investigation did not involve any design or other information which could be considered proprietary as defined by Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, it will be distributed without the customary review. No items of noncompliance or deviations were identified. Should you have any questions concerning this investigation, we will be pleased to discuss them with you. Sincerely, , 7 . . f l , ,', M vt,C/;l?.
~ !+ . iarl V. Seyfrit/,. Director j Enclosure: IE Investigation Report No. 50-498; 50-499/80-15 l ' STAFF EXHIBIT NO. 61 DtA.fE of l 800'll50007 ' -- _ --_ '""'~---%-. . _ . . _ . ._ _
U. S. NUCLEAR REGULATORY CCMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV a Report No. 50-498/80-15; 50-499/80-15 - Occket No. 50-498; 50-499 Category A2 Licensee: Housten Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 Facility: South Texas Project, Units 1 and 2 ~. Investigation at: Bay City, Matagorda County, Texas Investigation Conducted: June 5-6, 1980 Investigator: - [/AA 27 /ffd - R. K. Herr, Investigation Specialist Date / Investigator: Zh?C r -b r ' ' 9,G 0. D. Oriski , Investigation Specialist Date Approved By: A Af _ .. N d!7c! - Tt Karl V. Seyfrit, Directe, R'egion IV 'Date ' f i - - m . n. -- : wg: na. --..e v ~~ , m -~ w + -a - e ,; , --
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. - -2- Area Investicated Allegations tnat a consultant firm had reconsnended that construction be ' discentinued at the South Texas Project site for a year until all problems had been corrected. This investigation involved 22 investigative-hours by two NRC Investigators. , . Results No items of noncompliance were identified. The allegations were discussed with the source. The allegation was not substantiated. i > & l t . - . . - _ . . - . . . . - - . _ _ . . _ - ..._- ._ . . _ - . - . _ ._. _-- ,,. _ ._ _ _.__-... _----...- _ _ . - - - . - - ~ . _ _ - , - _ - .
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July 16, 1980 In Reply Refer To: RIV Docket No. 50-498/Rpt. 80-16 50-499/Rpt. 80-16 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr. Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by our Resident Reactor Inspector, Mr. H. S. Phillips, during the period of June 1980, of activities authorized by NRC Construction Pennits No. CPPR-128 and 129 for the South Texas Project. Units No. I and 2, and to the discussion of our findings with Mr. R. A. Frazar and other members of your staff during the inspection period. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. Within the scope of the inspection, no items of noncompliance were identified. One new unresolved item is identified in paragraph 7 of the enclosed report. 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 enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any infonnation that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such infonnation be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application sMuld be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Docurrent Room. l STAFF EXHIBIT NO. 62 l t $009170380 . - - - - - - - -
. . _ . - . . Houston '.ighting and Power Company -2- July 16, 1980 . Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, f. ,p' Reactor Construction and . C. Seidle, Chief Engineering Support Branch Enclosure: IE Inspection Report No. 50-498/80-16 50-499/80-16 .
. - % . U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region IV Report No. 50-498/80-16; 50-499/80-16 . Docket No. 50-498; 50-499 Category A2 Licensee: Houstan Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 , Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County, Texas Inspection conducted: June 1980 Inspector,: M4 NMN H. S. Phillips, Rejpcent Reactor Inspector Date Approved: ce 7 O W. A. Crossman, Chief, Projects Section Gate , Insoection Su: mary: Inscection during June 1980 (Recort No. 50-498/80-16: 50-499/80-16) Areas Insoectec: Routine, announceo inspection ey tne Resicent Reactor Inspector (RRI) included independent inspection performed during site tours; follow-up inspections relative to noncompliances and unresolved matters; inspection of safety-related components, containment structural steel welding, QA records system; and management meetings. This inspection involved fifty-seven inspector-hours by one NRC inspector. Results: No items of noncompliance or deviations were identified. . . 4 i ~ r - c. - -- - - - ,[j ' DUPLICATE DOCUMENT S ' l Entire document previously - " ' * entered into system under: g a 8009/7638 8 - j ' ano . $ No. of pages: 8 N l t w .s bk b., ...yMI ~ ' A'"- N ' - -.
_ _ , , DETAILS 1. Persons Contacted Princioal Licensee Emolayees
- G. W. Oprea, Executive Vice President.
- R. A. Frazar, Quality Assurance Manager
- J. W. Briskin, Manager Houston Operations
- R. L. Ulrey, Suppcrt QA Manager
- A. H. Guttermin, Attorney
W. N. Phillips, Projects QA Manager L. O. Wilson, Site OA Supervisor J. W. Seward, Lead QA Specialist M. S. Monteith, QA Specialist T. J. Jordan, Supervisor Quality Systems Brown & Root. Inc. (B&R) Emoloyees
- K. M. Broom, Senior Vice President
- J. L. Hawks, Engineering Project Manager
Management Analysis Comoany (MAC)
- J. P. Jackson, Senior Vice President
- L. E. Zwissler, Vice President
Bechtel . I !
- J. M. Amaral, QA Manager
, i The RRI also talked with and interviewed several other licensee and contractor employees, including members of the quality, technical and engineering staffs. i
- Denotes those attending management meeting at the Region IV office.
2. Licensee Action en Previ_ous Inscection Findings (0 pen) Noncompliances, Unresolved Items and Show Cause Letter (50-498/ ! 79-19; 50-499/79-19): Special investigation of alleged threats / harassment and assessment of the effectiveness of the QA program. The RRI attended severt seetings both on and off site relative to inspection findings which were documented in the above referenced report. Follow-up i l inspection results were documented as follows: l -2- l !
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o NUCLEAR REGULATORY COMMISSION I
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7 %D REGloN IV 3 f.:.' "I }jj ARUNGTON TEXAS 79012 7 O $11 RYAN PLAZA omsvt. SulTE 1000 \\, <df ..... July 16, 1980 In Reply Refer To: RIV Docket No. 50-498/Rpt. 80-17 50-499/Rpt. 80-17
Houston Lighting and Power Company ATTN: Mr. E. A. Turner, Vice Presid st , Power Plant Construction and Technical Services Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by Mr. R. E. Hall and other me=bers of our staff during the period June 23-26, 1980, of activities authorized by NRC Construction Permits No. C??R-128 and 129 for South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. R. A. Frazar of your staff at the conclusion of the inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective enm h acion of procedures and representative records, interviews with personnel, and observations by the inspectors. Within the scope of the inspectica, no items of noncompliance were identified. One new unresolved item is discussed in paragraph 3. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Coda of Federal Regulations, a copy of this letter and the enclosed f I inspection report will be placed in the NRC's Public Document Room. If the report contains any information that yet, believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the infornacion is proprietary. The appliention should be prepared so that any proprietary inforration identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. STAFF EXHIBIT N0. 63 Q h OY 5oo9o50525 .-. - - - - - - . - - - -
. - - . Houston Lighting and Power Company -2- July 16, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, / . '
'g'J. C. Seidle, Chief 'f' Reactor Construction and Engineering Support Branch Enclosure: IE Inspection Report No. 50-498/80-17 50-499/80-17 l ! i e GD . l . - - . _ .__ . . . _ _ _ _ . - - _ - . . - - - - ~ - - - - - . . ~ - - - - - - -
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. U. S. NUCLEAR REGULATORY CCt91ISSION ', CITICE OF INSPECTION AND ENFORCEMENT REGION IV , Report No. 50-498/80-17; 50-499/80-17 Docket No. 50-498; 50-499 Category A2
Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County. Texas < Inspection Conducted: June 23-26, 1980 .
s' /* ,- . . . ' Inspectors: - ~ - ' ' I* * .* R. E. Hall, Chief, Engineering Support Section Dat? 7 /4 *T - p. I. Tapia, Reactor Inspector, Engineering Support ate Section 's ~7 10 . . K. Chaudhary, Reactor Inspector, Engineering Support /D(te Section, Region I - . l _ - ? - a R. B. Landsman,' Reactor Inspector, Engineering Support Da e Section, Region III - . Approved: /4 W. A. Crossaan, Chief, Projects Section Date'/d _:-_- -l f,S 7b/k> ' ' DUPLICATE DOCUfiENT 2gineering Support Section /page g s .
Entire document previously entered into system under: ' R O D 9 O f f, $ 3 Q [; , hNO y; , , No. of pages: / [E02.Is h M 6: m t2;. w .,H.2y a i k a i _; _. . . . . _ . _ _ , - , . . ~ . . . . . . - . . . . , . _ . _ _ _ _ _ . . . _ . . . - . _ . . _ _ _ . _ . _ . . _ _ _ . . . _ . - _ . . . _ . . , _ _ _ . .
. - . Inspection Summary: Inspection on June 23-26, 1980 (Report No. 50-498/80-17; 50-409/80-17) Areas Inspected: Special, announced follow-up inspection of construction activities including observation of work and review of records pertaining to the NRC Inspection Report No. 50-498/79-19; 50-499/79-19 findings related to earthwork. The inspection involved one hundred and eight inspector-hours by four NRC inspectors. Results: No items of noncompliance or deviations were identified. . l l l , 2 l l . . . . . - . . . . . - . . - . . - - - - . . . _ _ - . . . . - . .
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,, / i REGION IV t *r J k / f sit avan mza on:vt.su TEtoco %, .....f AnuNotes, TaxAs 7 sot 2 In Reply Refer To: Septas er 19, 1980 RIV Docket No. 304 % /Rpc. 30-18 30-499/Epc. 60-LS Ecuston Lighting and Fever Company Actn: M.r. G. W. Oprea, Executive Vice President Post Office Sox 1700 Houston, Texas 77001 Gentlemen: This refers to the inspeccion condue:ed by our Resident Reactor Inspector, P.r. H. S. Phillips, during the period of July 1980, of activities authorized by NRC Construer.1on Per=1ts No. C??R-128 and 129 for the South Texas Project, Units I and 2, and to the discussion of our findings with F.r. R. A. Prazar and other nembers of your staff during the inspection period. Areas exa=ined during the inspection and our findings are discussed in the t ! enclosed inspeccion report. Wichin these areas, the inspec: ion consisted of ' selective exa=inacion of procedures and representative records, interviews with ! personnel, and observacions by the inspector. l During the inspeccion, 1: was found that cer:ain activicies under your license ! appear to be in noncompliance wi:h .4:pendix 3 :o 10 CFR 30 of the NRC Regulacions, ! "Quali:7 Assurance Cri:eria for Nuclear Power Plants." The 1: ens of necconpliance and references :o the pertinen: requirements are identified in :he enclosed Notice of Violacion. . One new unresolved i:em is identified in paragraph 7.b(2) of :he enclosed report.
- his nocice is sent to you pursuant to che provisions of Section 2.201 of the
NRC's " Rules of ?ractice," Part 2, Title 10, Code of Pederal Regulations.
See:1on 2.201 requires you to submit to this office, within 30 days of your l receipt of this nocice, a written scaca:nene or explanacion 1: reply including: (1) correc:ive steps which have been caken by you, and the resul:s achieved (2) corree:1ve sceps which will be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved. l STAFF EXHIBIT N0. 64 l l Onf E of so112109
. .. . _ Houston 1.ighting and ?over 2 September 19, 1980 Company .. -- In accordance with Section 2.790 of the NRC's " Rules of Practice," Psrc 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietarf, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such infor=ation be withheld fron public disclosure. The application aust include a fell statenent of the reasons why it is claimed that the information is proprietary. The application should - ,be propered so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure vill also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we vill be plerased _ to discuss them with you. .. , - --- Sincerely, ll / ' 8 .: . ," d g 'J. C. Seidle, Chief Reactor Construction and Engineering Support 3 ranch , Enclosures: 1.- - Appendi:c A, Notice of Violation f,lh I -T?. Inspection Report No. 30 !.98/80-13 ..o n : < - -. 50-499/80-18 , ,. - - _ - _ _ - - . -- . _ . . _ _ _. _ - - . - - . -
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_ . , Docket No. 50-496/80-18 50-499/80-18 Appendix A NOTICE OF VI0I.ATION . Based on the results of the NRC inspection conducted on July 23-26, 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your Construction Permits No. CPPR-123 and 129 as indicated below: A. Failure to Develop Appropriate Procedures to Assure Traceability of Embed Material 10 CFR 50, Appendix B, criterion V states, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in .u
- _ accordance with these instructions, procedures or drawings."
The South Texas Project PSAR, Section 17.1.8 3 states in part, " Brown & Root (B&R) assures, by procedures, that materials, items and components subject to fabrication, processing or assembly maintain their identity." B&R QA Manual, Section S.0 states in part, " Project procedures shall be established and implemented to provide . . methods for insuring trace- '; . ability of items to documentation . . . . Brown & Root QC inspectors shall verify that proper identification of field installed items has been maintained throughout erection or installation by compartson with iso- metrics, flow sheets, WDC, etc." Contrary to the above: On July 23, 1980, during Pour No. MEA 2-WOO 8-3A, the RRI determined that l ! Quality Construction Procedure A040 KPCCP-3, Revision 4, "Prepour Activi- ties," which specifies the inplace inspection to be performed by the QC inspector, did not provide methods for assuring traceability of field l installed items- to documentation. Specifically, the procedure does not , require QC inspectors to verify that proper identification of field l I installed items has treen maintained throughout erection oc installation by comparison with isometrics, flow sheets, VDC, etc. Discussions with the lead and discipline QC inspectors, confirmed that they do not verify traceability of field installed items. A similar matter was previously identified as Unresolved Item No. 50-498/79-19-01; 30-499/79-19-01 in II Investigation Report No. 50-498/ 79-19; 50-499/79-19. . This is an infraction. D u.P t o f l Soll\\oO \\ \\ $
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. . . . _ 3. Failure to Assure that Purchased Material Conformed to Procurement Documents 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be accomplished in accordance with instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplish- ed in accordance with these instructions, procedures, or drawings." The Brown & Root Vendor Surveillance Plan for Bostrom-Bergen requires that the vendor inspector inspect for workmanship in accordance with paragraph 4.28.9 of AWS D1.1 which states, "after welding, are shields shall be broken free from shear connectors and anchor studs and where practicable from all other studs." i ' Contrary to the above: On July 23-26, 1980, the RRI inspected storage / issue areas "F," "M," and "P," and observed over seven hundred Sostrom-Bergen embeds, which had six to eight stud welds per embed. The ceramic are shields had not been completely broken free on the majority of embeds inspected, although it was practicable to do so. On at least twenty embeds, the shields that were lef t prevented visual inspection for 360 degrees. The majority of the embeds had smaller pieces of the ceramic shields in place which prevented full vi:ual inspection of the welds. This is an infraction. C. Failure to Respond to 3&R Audit Findings 10 CFR 50, Appendix B, Criterion V states, " Activities affecting quality shall be acccmplished in accordance with instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplish- ed in accordance with these instructions, procedures, or drawings." B&R Procedure ST-QAP-7.1, revised February 24, 1975, paragraph 5.8.1 states in part, "If an acceptable response is not received within ten (10) working days after the committed response date, the Audit Section Manager shall prepare appropriate correspondence (internal memorandum or B&R letter) to the manager of the audited organization from the Quality Assurance Manager requesting immediate attention and response." Contrary to the above: Audit deficiencies resulting f;om Brown and Root, Inc. Audit No. ST-36 conducted March 24 and April 7-10, 1980, were discussed by the auditors , with the audited organization in a post audit meettag held on April 14, l 1980. Subsequent documentation of the audit findings was completed on May 13,1980, and a committed response date of May 29, 1980, was required. An impasse between the auditors and the audited organization concerning corrective action of several of the deficiencies was evident on or before June 20, 1980. Discussion by the RRI with the B&R Audit Section Manager , ,
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- . , on July 25, 1980, revealed that he.had not prepared appropriate correspond- ence and sent it to the audiced organization after not having received an acceptable response within ten working days after the committed response ' date. This is an infraction. ,
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. . . - U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCE.'E.NT REGION IV Report No. 50-498/80-13; 50-499/80-18 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County, Texas Inspection Conducted: July 1980 Inspector: e d H. S. Phillips Resident Reactor Inspector Date Approved; _ '//8 4 8/ w _- W. Crossman, Chief, Projects Section Date .. Inseection Su..:sary: It.seection of July 1980 (Recort 50-498/80-13: 50-499/80-13) Areas Inscected: Routine, announced inspection by the Restdent Reactor Inspector (RRI) included independent inspection performed during site tours, follow-up inspections relative to concompliances, unresolved matters, show cause order items; inspection of concrete placement activities, structural steel and supports j inside/outside containment. This inspection involved one hundred inspector- ! hours by one NRC inspector. Results: Three items of noncompliance were identified in three of four areas inspected (infraction - failure to respond to B&R audit findings paragraph 5.b; infraction - failure to develop appropriate procedures to assure material traceability paragesph 6; and infraction - failure to assure that purchased material conformed to procurement documents - paragraph 7.b(3). 1 I ! pm :. n; -. m ,, >. m + l . -
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. - . DETAILS 1. Persons Contacted Principal Licensee Employees R. A. Frazar, Quality Assurance Manager J. W. Briskin, Manager Houston Operations L. D. Wilson, Project QA Supervisor (Mechanical) J. W. Soward, QC Supervisor T. J. Jordan, Supervisor Quality Systems R. A. Carvel, Project QA Supervisor (Civil / Structural) D. W. Bohner, Project QA Supervisor (Electrical) G. Steinmann, Lead Site Engineer L. R. Jacobi, Licensing Brown & Root, Inc. (B&R) Employees J. R. Geurts, Vice President R. W. Bass, Audit Section Manager D. A. Walker, lead Site Auditor C. R. Guruprasad, Audit Team Member C; E. Williamson, Audit Team Leader D. Robertson, B&R Site Engineering J. Baysinger, B&R Construction (Ada) G. R. Purdy, QA Engineering Manager G. R. Murphy, B&R Engineering R. Osborne, Head Warehouseman D. Foeher, Embed Foreman L. Sciba, Fabrication Foreman Management Analysis Company (MAC) J. P. Jackson, Senior Vice President W. J. Friedrich, QA Manager for Brown & Root J. Rudd, QA Engineer for Brown & Root 2. Licensee Action on Previous Inspection Findings (0 pen) Noncompliance (50-498/79-19-55; 50-499/79-19-55): Failure to Take Appropriate Corrective Action on Audit Findings. See paragraph 5 of this report for details of a similar noncompliance. (Closed) Unresolved matter (50-498/79-19-01; 50-499/79-19-01) Allegation , No. 12: That traceability of embeds is lost af ter leaving the B&R ' Receiving Group. This matter was upgraded to an item of noncompliance. See paragraph 6 for details. ! 2 . l __ . - - -. . - . . . - - - - - -
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. . - - - - - . - . - . - . - .. . . . t - . ' . UNITED STATES /pa%q'o, NUCLEAR REGULATORY COMM!SSION NM[I '"alo^JNh!b503" WI ~ ..... August 8, 1980 In Reply Refer To: RIV Docket No. 50-498/Rpt. 80-19 50-499/Rpt. 80-19 Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr. Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by Mr. J. I. Tapia of our staff during the period July 22-24, 1980, of activities authorized by NRC Construction Pemits No. CPPR-128 and 129 for South Texas Project, Units No.1 and 2, and to the discussion of our findings with Mr. R. A. Frazar { of your staff at the conclusion of the inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. Within the scope of the inspection, no items of noncompliance were identified. We have also examined actions you have tak2n with regard to previously identi- fied inspection findings. The status of these items is identified ir. paragraph 2 of the enclosed report. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, i Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in tue NRC's Public Document Room. If the ! report contains any infomation that you believe to be proprietary, it is l necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an l enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. g STAFF EXHIBIT NO. 65 1609060 @ g .
3 - . . Houston Lighting and Power Company -2- August 8, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, W. C. Seidle, Chief Reactor Construction and , Engineering Support Branch Enclosure: IE Inspection Report No. 50-498/80-19 50-499/80-19 ( . _ , - . - _ _ . _ , _ _ . . _ _ _ _ , . , , , _ _ - . , _ , , _ _ _ ._ , , ,, . _ _
. ~ . U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT , Report No. 50-498/80-19; 50-499/80-19 ' Docket No. 50-498; 50-499 . Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 l Inspection at: South Texas Project, Matagorda County,: Texas Inspection conducted: July 22-24, 1980 l Inspector: 7- M /fJ.I.Tapia,ReactorInspector,EngineeringSupport Date ' // Section i ( Approved: SN F - %~ W. A. Crossman, Chief, Projects Section Date fd-Td R. E. Hall, Chief,' Engineering Suppnrt Section Date Insoection Summary: Inscection on July 22-24, 1980 (Report No. 50-498/80-19; 50-499/80-19) Areas Inspected: Routine, unannounced follow-up inspection of construction activities including observation of work and review of records pertaining to the NRC Inspection Report No. 50-498/79-19; 50-499/79-19 findings related to , earthwork and concrete. The inspection involved twenty inspector-hours by ! one NRC inspector. Results: No items of noncompliance or deviations were identified. w. . ny - -- ~ : -~ m '^ . . . ., .. u - , DUPLICATE DOCUMENT ' Entire document previously y entered into system under: a 'i ANO %OO D Sovd5 L - - U No. of pages: 8 ' 1: . Mx ' r- -c;La L a u& G.;4&~ L as o
. - DETAILS 1. Persons Contacted Princioal Licensee Employees
- R. A. Frazar, Manager, Quality Assurance
- T. J. Jordan, Supervisor, Quality Systems
T. K. Logan, Lead Engineer, Quality Assurance
- R. A. Carvel, Supervisor, Civil / Structural Quality Assurance
- L. English, Site Construction Manager
l Other Personnel G. T. Warnick, Quality Control Manager, Brown & Root.(B&R) C. M. Singleton, Civil Quality Control Supervisor, B&R V. Berger, Quality Assurance Administrator, B&R J. L. Murphy, Quality Engineer, B&R A. Fernandez, Training Supervisor, B&R J. Ruud, Supervisor of Civil Quality Engineering, B&R B. Horning, Consultant, Management Anal' 2;s Corporation The IE inspector also interviewed other licensee and contractor personnel including members of the engineering and QA/QC staffs.
- Denotes those attending the exit interview.
> 4 2. Licensee Action on Previous Insoection Findinos During this inspection, certain corrective actions described in the Houston Lighting and Power Company (HL&P) letter to the NRC, dated May 23, 1980, were inspected. The letter was in response to the items of noncompliance resulting from the special investigation as reported in Investigation Report No. 50-498/79-19; 50-499/79-19. This inspection is a continuation of the follow-up activities initiated during inspection No. 50-498/80-17; 50-499/80-17, and specifically addresses those items related to Category I structural backfill and concrete. Those items were identified as Infractions No. 5, 7, 13, 16 and 20 in Appendix A to the NRC letter to HL&P dated April 30, 1980. In the discussion below, the track numbers from IE Investigation Report No. 50-498/79-19; 50-499/79-19 are indicated. (Closed) Infraction (50-498/79-19-24; 50-499/79-19-24): Failure to Document Soil Lift Thickness and Number of Passes of Equipment as Part of QA Records. The IE inspector reviewed the changes in procedures effected by Revision a to Brown & Root (B&R) Quality Construction Procedure A040XcCCP-2, " Structural , -2- - -
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In Reply Refer To: i RIV l Docket No. 50-498/Rpt. 80-20 l 50-499/Rpt. 80-20 l ! l ' Houston Lighting and Power Company ATTN: Mr. G. W. Oprea, Jr. Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by Mr. D. P. Tomlinson of our staff during the period July 28-29, 1980, of activities authorized by NRC Construc- tion Permits No. CPPR-128 and 129 for the South Texas Project, Units No. I and 2, and to the discussion of our findings with Mr. L. D. Wilson and other members of your staff at the conclusion of the inspection. Areas entnined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of
i selective a - in= tion of procedures and representative records, interviews with ( 4 ) personnel, and observations by the inspector. I Within the scope of the inspection, one item of noncompliance was reviewed. This item was identified through your internal audit program, properly reported, and corrected in a timely manner as discussed in the attached report. Consequently no additional information regarding this item of noncompliam e is needed at this time.
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 enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any information that you believe to be proprietary, it is i necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. N b STAFF EXHIBIT NO. 66 . , ' 800esooogg _. . m----,n.= ,.,w_...,_.,-..e,_y,-- y,.g-: ---,,w-y .,.g r,.,.- . , -_,.,m9,-y,-.--n--g,,,..,--p-,-.. .f-,.,,- , - . ,.c,n ,m , , - . , , , - . . , .,.me,-,..-,., , , , .,. ,,,, ,es,,wm,
. . . - Houston Lighting and Power 2 August 18,' 1980 ' Company Should you have any questions concerning this inspection we will be pleased to discuss them with you. Sincerely, Y _- - = w & - W. C. Sei ih, Chief Reactor Co struction and Engineering Support Branch Enclosure: IE Inspection Report No. 50-498/80-20 50-499/80-20 ( , ./ l l I . OM- ,y .m- . -,w-ym_r-, ,iy-w- w- w sm-er 1* --*
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_ \\ ' l U. S. NUCLEAR REGULATORY C0t9 FISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-498/80-20; 50-499/80-20 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting & Power Company hst Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 & 2 4 Inspection at: South Texas Project, Matagorda County, Texas Inspection Conducted: July 28-29, 1980 Inspector: f/ff/rt . P. Tomlinson, Reactor Inspector, Engineering Support 'Date Section Approved: __ 82 - W. A. Crossman, Chief, Projects Section ' Date R. E. Hall, Chief, Engineering Support Section 'Date Inspection Summary ) Inspection on July 28-29, 1980 (Report No. 50-498/80-20; 50-499/80-20) Areas Inspected: Routine, unannounced inspection of construction activities pertaining to the issuance and disposition of Noncomformance Reports (NCRs). The inspection involved eight inspector-hours by one NRC inspector. ' Results: No items of noncompliance or deviations were identified. l l l Os95 of 8009300gng 1 ) . . . . - . .-- -- _-_--._ . _ . . . _ - _ . .
. _ _ _ _ _ _ _ _ _ _ _ _ . , - DETAILS . 1. Persons Contacted Principal Licensee Employees R. A. Frazar, Site, QA Manager
- L. D. Wilson, Project QA Supervisor, NDE/ Mechanical
- T. J. Jordan, Quality Systems Supervisor
- J. W. Soward, QC Supervisor
Other Personnel T. Warnick, QC Manager, Brown and Root (B&R) The IE inspector also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs.
- Denotes those attending the exit interview.
2. Review of Previously Issued and Dispositioned NCRs The IE inspector selected NCRs No. S-M1354-A, S-M1355-A, S-M1356-A, and S-M1357-A for review. All four were issued against activities that j occurred in the B&R fabrication shop and all four involved structural ' supports for the steam generators. ,/ The four NCRs, all written during November 1979, were complete, legible and appeared to have been properly dispositioned. NCR No. S-M1357-A, however, was examined more thoroughly than the others as it was one of the items mentioned in RIV Investigation Report No. 50-498/80-14; 50-499/80-14. The NCR states that the B&R QA surveillance inspector assigned to the fabrication shop was not notified by subcontractor construction personnel of a mandatory " Hold Point." QAP 5.5, 4.2.2 requires subcontractors to notify B&R QA when approaching a " Hold Point," and to proceed no further without B&R QA being present. The only exception to this is that QA may waive the " Hold Point" in writing. The QA inspector, notified of a " Hold Point" that had been passed, performed the parts of the inspection that could be accomplished after-the-fact and signed off the " Hold Point." i He did this partial inspection on November 11, 1979, but recorded it as I being done on November 10, 1979. The QA inspector informed his supervisor of these facts on November 12, 1979, and NCR No. S-M1357-A was generated shortly thereafter. All B&R QA inspectors were reinstructed in the require- ments of the " Hold Point" on the Fabrication Check List (FCL). Construction , l personnel employed by subcontractors were also reinstructed in the importance ! of " Hold Points," " Notification Points, and " Hold Tags." ! Investigation Report No. 50-498/80-14; 50-499/80-14 contains an allegation of record falsification and cites this FCL and " Hold Point" as an example. This allegation was substantiated in the NRC investigation report and was ! , l 2 . . _ - . . . ~ . . . . - . . . . . . -
_ - r ~ l admitted to by the B&R QA inspector. No citation was issued, since i the NCR was issued promptly following the violation becoming known to the supervisor and well before the IE investigation. The allegation of falsification was not presented to the NRC until May 1980. Prior , ' to the beginning of the investigation, all corrective action had been I accomplished and the cognizant QA inspector was moved to another position ' within the QA organization which involves no accept / reject responsiblity. , No additional items of noncompliance or deviations were noted. 3. Exit Interview The IE inspector met with the licensee representatives (denoted in para- graph 1) at the conclusion of the inspection on July 29, 1980. The IE f inspector summarized tne scope and findings of the inspection. l l l l l , l 3 . p- w eem-w---- -- m.-. we - ,-, - , . --- e. y - -- r+w-y y*y
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