ML20031A002
| ML20031A002 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 09/10/1981 |
| From: | Jordan W CITIZENS FOR EQUITABLE UTILITIES, HARMON & WEISS |
| To: | HOUSTON LIGHTING & POWER CO. |
| References | |
| NUDOCS 8109180260 | |
| Download: ML20031A002 (15) | |
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TJ UNITED STATES OF AMERICA V:n c', 9,,q }
NUCLEAR REGULATORY COMMISSION
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In the Matter of
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HOUSTON LIGHTING AND POWER COMPANY
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Docket No. '50-498 (Sout h Texas Proj ect, Units 1 and 2)
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,07 CITI" ENS FOR EQUITABLE UTILITIES f f TB g FIRST SET OF INTERROGATORIES TO HOUSPC LIGHTiNC AND POWER COMPANY CONCERNINC eg#,2 I)SSJ 7:
STRUCTURAL STEEL SUPPLIED BY AMERICA?
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BRIDGE DIVISION OF U.S.
SPEEL CORPORATI D
INTRODUCTION
%-e These interrogatories are being filed in connection wi Citizens for Equitable Utilities ' motion to admit additional contentions and establish a discovery period with respect to failures in vendor surveillance atid possible saf ety hazards in-volving structural steel supplied to the South Texas Project by the American Bridge Division of U.S. Steel Corporation ("American Bridge").
We request that they be answered in wr'iting and under oath by employees, agents, or contractors of Houston Lighting and Power Company who have personal knowledge of the f acts in cpes tio n.
We note that these interrogatories are necessarily general because they are basei on newspaper reports on the underlying f ac ts.
We have at+.empted to structurs the interrogatories to ob-tain a complete rendition of the facts on thAs round in order to minimize the need for further discovery on the issues.
- However, we expect that a second or third round of discovery will probably a
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be necessary in some areas.
The term " documents" as used here encompasses all memoranda, notes, correspondence, and other papers containing writing, whether by hand or machine, and all other means of recording information, including computer thpes, and tape recordings.
The doctrine of eiusdem generis or similar theories do not apply to these inter-rogatories.
The listing of specific matters of any sort should be taken or,1y as examples and not as in any way narrowing the scope of more general terms.
These interrogatories are based primarily on five newspaper,.
articles concerning the structural s tcel supolied by American Bridge and quoting Mr. Don Beeth of HL&P as a source of informa-tion on the subj ect.
The articles are ettached for reference.,
INTERROGATORIES 1.
Please provide copies of all press releases, statements by Hot ston Lighting and Power Company (HL&P) or Brown and Root, Inc. ( B& R ), or other documents providad to members of the press by either HL&P or B&R concerning the def ects found in the steel supplied by American Bridge, as discussed in the attached articles, and the actions taken by HL&P or B&R with respect to those defects.
2.
The attached articles refer to uncertain quantities of steel, ranging from " tons of steel" to "8,000 beams of structural steel delivered to the South Texas Proj ect over the last four years. "
a.
Please identify the exact quantity of steel by type of steel, size, intended use,.and any other identifying characteristic, that has signific ant been supplied by American Bridge to the South Texas Project since the beginning of the proj ect.
Please f
include the shipment dato and the quantity and types of stersi in each shipment.,
b.
Referring to the answer to 2(a), please identify all of the steel that Mr. Beeth was referring to in providing the information reflected in the attached articles.
c.
Please describe generally each of the types of def ects found by HL&P or B&R inspectors at the South Texas Project in the steel identified in response to 2(b) and state HL&P 's opinion as to the cause of each.
In each case, identify the standard, specification, or procedure under which a defect was determined to axist and explain whether a subsequent change in a stan-dard, sp eci fic ation, or procedure has eliminated or modified the defect.
d.
Please identify all steel or shipments of steel from American Bridge that HL&P believes 'may contain defects similar to those described in 2(c), that was not identified in response to 2(b).
Please explain why HL&P believes this steel may contain auch defects.
e.
Referring to the steel identified under 2(b) and 2(d), please identify the precise status of each piece of steel, including partic..larly the following:
(1)
Did American Bridge quality control personnel prepare any nonconformance
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-4, reports of which HL&P or B&R : s aware with respect to any of the steel?
Please explain when HL&P or B&R became aware of the reports.
(2)
Please describe any inspection of the steel or other actions taken with respect to the steel by employees of HL&P er B&R at the American Bridge f acility that supplied the piece of s te el.
In this connection, please provide copies of all documents reflecting or relating to these inspec-tions or other actions, including but not limited to nonconformance reports, inspection check lists, documents relating to or reflecting an evaluation of the quality control performance of American Bridge, and any' other documents related to B&R or HL&P actions at' American Bridge concerning the steel in question.
(3'i Please describe any inspection of the steel or other actions taken in co
,oc-tion with accepting the steel at the South Texas Proj ect Site by employeer of HL&P or BiR.
(4)
Please describe the location where the steel was stored on site prior to installation and state how long the steel was stored in that location.
(5)
What corrective actions have been taken with respect to the steel, if any.
When and how was the need for corrective action first discovered, and when was the action 'taken?
(6)
Please identify each piece of steel that has been installed and state when it was install;d and its precise location.
f.
Please describe the actions taken by HL&P and B&R to re-examine and determine the integrity of any i
steel supplied by American Bridge,,as identified 6nder 2(a) that was not identified and discussed under 2(b).
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3.
All American Bridge steel was required to be subj ected to a quality control / vendor surveillance program at the American Bridge facility or facilities.
each American Bridge f acility involved, a.
Please describe she B&R and HL&P vendor surveil-lance prograr', including the number of positions, the precise function of each, and the formal lines of communication between HL&P and B&R personnel and American Bridge personnel.
Include a descrip-tion of how the vendor surveillance program fits in the B&R and HL&P organizations, including parti-cularly identification o'f the home office positions and personnel responsible for the vendor surveillance program.
If the answers are different for different periods in the life of the proj ect, please provida answers for all periodo and explain the reasons for any changes, b.
Please identify all HL&P and B&R personnel who have been responsible for ordering and scheduling delivery of American Bridge steel since January 1, 19 77, in-cluding everyone who had the authority to direct American Bridge to increase production or speed deliveries.
c.
Please describe in detail the inspections required to be performed at the American Bridge facility, including reference to whether they were required to cover arc strikes or weld spatter and to any changes in the scope of the inspection, during
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the li f e of the proj ec t, and to who was to perform the inspection.
In this connection, please provide copies of any documents detail-ing the items to be inspected under the appli-cable codes; speci fic ations, or procedures.
d.
Please identify all B&R or HL&P employees or agents involved in the vendor surveillance program at the f a.:iiity, including their position (s), dates of employment in each position, reat n for termination or change of position; and most recent address available 4
to HL&P or B&R.
If possible, identify separately all such employe:S er agents involved in the surveillance related to the steel icuati fied in 2(b).
4.
When the Ameri:an Bridge steel is shipped to the site of tre South Texaa Proj ect, it must be accepted by B&R or HL&P prior to be' eg used on the proj ect.
a.
Please describe in detail the procedures for
.7-spection and accer/cance of the American Bridge steel from the beginning of the proj ect to the present.
In particular, describe in detail any inspections that are required to be performed by B&R or HL&P personnel and provide copies of any documents describing how those. inspections are to be performed.
m.
b.
Please identify all of the B&A and HL&P employees or agents involved in or respon-sible for the acceptance of American Bridge steel at the South Texas Proj ect, including their position (s), dates of employment in each position, responsibilities in each position, reason for termination or change of position, and most recent address available to HL&P or B&R.
If possible, identify separately all such employees or agents involved in the surveillance related to the steel identified in 2(b).
Specifically identify which pieces of steel were c.
thoroughly inspected at the South Texas Proj ect site prior to installation and which were not.
Provide copies of any documents reflecting the performance of the inspections.
5.
The attached articles indicate that quality control procedures were changed on June.4 and July 29 in response to the hundreds of nonconformances that had been found under previous procedures, Please provide copies of the standards, specifi-a.
cations, and procedures for inspecting American Bridge steel at the South Texas Proj ect that were in effect before the defects discussed by Mr. Beeth in the attached articles were disc. overed and of
'all subsequent versions of the standards, sp eci f i-cations, and procedures.
Explain the reason for each change made in the inspection standards, speci-fications, or procedures.
b.
For each specification or procedure, identify each provision that HL&P and B&R believe is required by the American Welding Society code and each that HL&P and B&R believe is not, and explain why, tha latter were included in the standard, specifications, or procedure.
Iden-tify each instance in which the specification or procedure reflects or adopts an exception to the AWS code, and state the justification for the exception.
1 c.
Identify each NCR written on the American Bridge l
steel that is considered to involve a " cosmetic" def ect with no structural significance, and describe the action taken or to be taken with respect to the steel in question.
I d.
Identify each NCR written on the American Bridge steel that is considered to involve a defect that is not coametic, and describe the action taken or to be taken with respect to the steel in ques tio n.
e.
According to the attached articles, a number of quality control inspectors believed the procedure changes would result in their overlooking substan-dard work, would prohibit them from reporting I
some serious def ects, or would otherwise be improper.
Please identify each of the individuals in ques tion and summarize his concerns.
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6.
When and how did HL&P firs t learn of the defects discussed by c!r, eeeth and reported in the attached articles?
Please provide copies of all documents related to HL&P's first learning of the problem.
a.
Please deschibe in detail HL&P 's actions to remedy the defects and otherwise to respond to their discovery.
b.
Please identify and describe in detail all HL&P investigations and other actions under-taken to determine whether the failure of vendor surveillance and substandard steel extends beyond the steel discussed by Mr.
Beeth, as reported in the attached articles.
7.
Please provide copies of all Written communications with the NRC cor.cerning the American Bridge steel identified under 2(b) and of any notes or other HL&P or B&R documerits reflecting or relating to conve$rsations or communications with the NRC on that subject.
Respectfully submit.ted,
/ <K 6
n J / J )~ f William ST Jordan, III HARMON & WEISS 1725 I Street, N.W.
Suite 506 Washington, D.C.
20006 (202) 833-9070 DATED:
September 10, 1981 l
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A rash of defielect wc!ds on structer-tbod d W h M w m
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pair program that may ast $1 m!Ilion er s.dd.
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More than half the nonconforn nnea The wcld prob!cm, it was learned, reports, he said, hvo!ved simple "cos.
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t' also led to a change in quaIIty control. meth" defacts, such r.' nM spatter au GJ
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t mima,anding has now been cleared sprayed on a stMing surface area. Arc fs h
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Beeth said the questionable weMsi. ports wise on more se-fous flaws that'
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Beem s'ald the weM prouem ca the "Ba* !! they attempt to restrict the is-the crious!y flawed weUs en 1 1
t ww,fng c.cer was repated to the Nu-spector on AW31: ems,andIcomeInck can Bridge material.
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in quanty ccctrol were not reported to Phillips said the AW3 code prohibits in terms of safety," he sam.
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eM aM strucmraMety,6 d the NRC because this is not required, weM spatter in socce cfrr"M*=. but' tM material we.s not in.ranr<
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To ccacentram attention m 6e mae h enn Ph!n!ps, the NRC's reddest on 25. Inch. thick twww !!ke thom at the ings t:ut was st!Ilin thelaydon t
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inspector at the gxvject site near Bay South Texas Prcyact it "would be !!ke a He said any effort to seek i l-trvision in quality assaance amwua City' sam he learned early in July of chigger craw!!ag cp an elephant's tan."
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'Ibe NRC lssued a show<ause order weldhg costs wocid depend ca l
g'3 w!!b weM spatter or are strikes, bet 2 the American BrMge welds, inttmkt. tion of quality control men =
"But you can be sure our l It directed um-project engineers and inspectws over against the preket in April ISSO, citing of thesupplycontract.
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i look fx four typcs of structuaHy sign!D.
He explained the welds must meet an aad defeetIve weIds and weIding not going to ignore the paa cant defects - undersized 3%
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retminu =uist," he sak!.
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specifications and quality assurance by Brown & Ecot Inc., the project con, "We understand the materin!
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However, Beeth sam, some W tractor, then remaned in staga starting quately inspected by Amer 6ci aterpeta a cun-pr**ng. procedures are up to the project l
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ast ocmser = me -Meg - au custome<a re.mse t
r "I tom them in early July that as long was reorganized.,
found by the custou.er's regre E
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as = aspectas M total freedom to Beeth of HIM sam a r' shta Brown m e the custamer's W i
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h; lie said a second revision was is:ned locit at anything under the AW3 code, & Root welding gew %s-is ih working Beeth said the welds totak
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July 29 to clear up any reknie stand-that's no probiern," Phillig cald. -
overtime fw amrsi man &S 2 repair thcusand, bt be had so !!gt.r g
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t pettlem, Ia "ty %W, lesJer d a San Antento.
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they do something that docsn't meet wmhe specsfications, they just change the
,ii the terins Seeth, homever, d the decision to,
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accept welds' with ondy cosmetic ble.
y copie are mighes was "a pedect{r legitimaM thQ
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"It it's caught at the supplPts, fine,"
I was cde-he said. "But if it's shvady on site, do F
m Bridge you W.a millics dollars Am.uog -
r, and was something that is just cosmetse?"
ptiws He also saki that "we don't hire in-pi. win."
spectars to design or make egrjacertag
.a d several judgme4ts - we EW "fm to do f m rmdily.thag"t.jf.cifcm
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a A major repair pr"Stam to correct. IIIAP for the beams and the cost of re-patt will
.I Shannon Phdllps. NRC resident inspec-i olds'judgM defectM in steel beams American Bridge. "You can be sure our i
1j mpplied by the American Bridge Division people won't overlook the possibihty of ;weldir.g co d U.S. Steel Corp. for the Bay City nu-t' lear pro}get has cost ilouston Lightmg & recovermg the cosi " he said.
materiai on the % inch-thick I. beams at F * *
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make the negotiations more difficult. Dane llarns, spokesman for U.S. S Dr. Donald Beeth, light com any
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,pckesman en nuclear affairs, sai in IIouston, the "irent company of Ameri-the MtC. The inspectors wrote several defects are in huge structural steel beams used to erect the plant. Some of the de, can Bridge, said that the steel had tweninspecte I
hundred such "non conformance re-i fects were not caught untd after the steel Brown & Root inspetors before being ports," he said.
Problems with the welds were also dis.
f hadbeeninstalled hesaid.Some of the toms have teen covered shipyd. "It was found by the customer's cussed during a hearirg before the NRC' representative to meet the customer's on whether or not illAP should be grant-g jM with concrete, but, if necessary, the con-crete wdl. be chipped away so t L
ed a licerse to operate the plant. Those
.'q welds ca6 be inspected or aditionel steel Ilridge plant in Orange. *% e don't know if M.
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changed so that welds with only cosmetic extra Vitarn* ins need'ed' I
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problems could be accepted. allowirg in.
CillCAGO (UPI) - Millions of Ameri-spectors to concentrate on finding more cans, caught up ta a health fond fad, are ;
I senous defects, which could affect the popping vitamin pills of all shapes and ;
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stres. Ilut Amencan Medical Association More than half of the &fects are cos-r -- -
rse metic, he said. These include weld spattcr expris doubt the extra vitamins
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lon? significance Spattrr is tiny sycks of.,necessary. Tests are a 2.
" metal that stick to the surface of the steel. ( min levels in the body w-2
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W, ciency, the journal said.
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. to fusion of the welded parts, are undersize i
In an ask an-expert column in the jour-
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.irl. or cut under the surface at the wrongangle. These defects can nal, an internist and a biochemist each l At
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spond to a patient's requett for tests to
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' a, g;"',,' ;. %<.. ". : ,',. y,,,,-4 ' found by American Bridge inspectors. Materials from vendors such raps hunt,ing
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bONDON ( AP) - Shooting and fishing d
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ed A full-time resident inspector from ' right, urged pople who hunt and fish to Brown & Root has been assigned toAmerican Bndge, and the
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8 betn solved, Iketh said. "We no longe:-', new evidence which shows that E l3 have bad loads coming in," he said.'
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7 'thousand welds have been reinspected.
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1 ordered to overlook other high school there he yorked has be
' ter2 beinfects he said. Te c! car up this rmsunderstanding, inspection vocedures.t. indicted on a. c t) pes of de h iti id wtre revW s second time on Ju!y 29, he.. manufacture cocaire, dicted by a federal grand jury here, al
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f Te Ilevisions in inspection procedure do not require approval of the federal Nu i with Anthony Corr (clear Regalatory Commission as inng as ) bury,
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Tons of improperly wclded steel beams have been deliv.
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ered to the South Texas Nuclear Project and the question of structural integrity at the unfinished power plant remains l
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officials said Friday.
i S-te of the massive steel beams already are encased in p.
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J concrete in walls at the raclear power plant. Many, how.
ever, have not been erected and are being inspected and rc. '[ ' '. g*-J.,*
d'Iys-e y.,.f*/'-l',r".,**,**1 paired. said Don Beeth, a spckesman for the project's man. 4 ~'
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aging partner, llouston Lighting & Power Co.
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IIc thinks not. Atleast half the flaws are cosmetic Beeth U
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said. A full evaluation of possible structural defects is not l' * " " *.
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ccmplete and is complicated t*j the fact that rome of the )... g.., ;, ,*.,,,",
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steel already has been used.
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"We have the continual knotty problem of the inaccesst. '-
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b!c beams," he said. The problem was discovered around t,*-;',(.b *< M*e. *,.%%'(
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the first of the year durin;; inspections of steel delivered to
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the Bay City project site from American Bridge Division of L
u' U.S. Sted Corp;. Beeth said.
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The steel had been delivered over "a considerab!c period of time" before the tiaws were Identified, Beeth said. "It f
t was not a single shipment."
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1 Inspection of the steel at the project site ;;cncrated "sev-t eral hundred" non-ennformance reports to the Nuclear Regulatory Commission. resident NI1C project inspector
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Shannon Phillips said Friday.
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. American Bridge plant before the beams were shipped.
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sh uld," Beeth said. Project c.ntrccEr Br?.wn 8 Woot ine,,
now his its twa inspector sta,ti:ned at Am". ricin Bridge.'",,;
Bc th said thd possibl!1ty cf sXking r:Imbursem:nt from l
a qmerican Bridge lp"something wa arc awate rf. $,e-a
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Welding has been a longstanding problem a the $2.7 b!.
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lion plant partly owned by Austin, but it was Brown & Ron f
,1 wciders who fouled up in the past, not the subcontractors. Er At one point, all project welding was halted and thousands l'
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of welds reinspected and repaired.
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Dy CANDICE HUGHO
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i The reinspection and repair of 8,0n0 percent of the first 1.000 beams reln-f' beams of structural steel delivered to the spected after the problem was noted, Rolk f~
- South Texas Project over the last four Beeth said. But when inspectors began o
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b years should be finished by the end of the climinating cosmetic flaws and concen-
'44U ' year, says a projcet spokesman.
trating on s'-uctural ones, the reject rate 1:.y.) *
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ppedto6 percent,Beethsaid.
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welds w!!! cost about $800.000, said Don 1 lAt this point the reinspection program y ~ ',*
Beeth, a spokesman for llouston Light.. Involves only the steel that hasn't been i
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ing & Powcr the $2 7 billion nuclear plant partly crected. Inspectingthe beams alreadyin I h
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' place could involve chipping out sections
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owned by Austin.
of the massive concrete walls.
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Amulcan Bridge Division of U.S. Stect Co, already has been installed, Dec year,, we probably won't chip anything ! j M -(
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dards none of the steel beams was delivery inspection program at the i
American Bridge fabricating plant in d
flawed to such a degree that it could not
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meet design criteria, Beeth said.
Orange. Brown & Root now is looking at $iffM E
cacia beam destined for the nuclear plant, [
Instead of just overseeing the American Project of ficials will not know until the I
repair program has ended why the in.. Bridgeinspectionprogram.
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spection system "did not catch the prob.
f tem early on," Beeth said. Although the -
blost of the 8,000 steel beams ordered g
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steel has been coming to the llay City from American Bridge already have
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>r construction site since 1977, the problem been dellycred to the South Texas proj-j
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.. with defective welds was not uncovered cct, Beeth said.
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By CANDICE HUGHES tion site by the American Bridge terpreted orders to focus on strucJ '
america +statuman stan Division of U.S. Steel Corp., proj-turtl probleres rather than cos-'
l1 cet officials said.
metic flaws as meaning they
. t Faulty welds on structural steel
- ,hould overlook some substaddard '
delivered to the South Texas Nu.
Brown & Root inspectors appar. work
- e clear Pro]:ct have turned into a ently overlooked the problem dur-mil'lo.i-dollar problem, project of. Ing initial inspections of stect be*
Phillips said today he put project 6
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ficials said today, fore delivery, Phillips said, officials on notice that they were f heading for a violation of NRC "We consider it a significant htostof thestcelhasnotbcentn-y ed s us ge m:of cost and mag stalled,headded.
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said Don Beeth, spokesman f:r the All the American Drldce steel is "I have no problem (with the.['^'~ '
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project's managmg partner !!ous. being re inspected ree:rding to r;vis:d procedare) as 1:ng as it i ton Lighting & PorcrCo.
revised inspection procedures that doesn't preclud2 them from find.
f.i focus ca structur:11 rather than
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The flawed welds generat:d cosmetic flaws, project officials ing ether things " Phillips sild.
hundreds of non-conformance re* said. The repatr program could IIL&P 's reportedly reviewing 1
f ports to the Nuclear Regulatory cost $1 mtllion or more,they said.
the supply contract with American
.,r Commisssion, said Shannon Phil.
lips, NRC resident project inspec-The revision in inspection proc. Drldge division to see ti sccking re-
- tor, edures prompted by the problems imbursementis feasible.
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has caused some controversy at
}l h The problem was caught by (* the Day City construction site, The city of Austin owns 16 per.
- cent of the project. which is four spectors for contractor Brown & Phillips confirmed.
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Root Inc. once the steel had been years behind schedule and threc.,
If delivered Ca the Bay City construc-Some inspectors reportedly in-times above the originalcost.
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3-1 1
UNITED STATES OP AMERICA NUCLEAR REGULATORY COMMISSIOM BEFORE THE ATOMIC SAFCTY AND LICENSING BOARD
)
In the Matter of
)
)
Docket No. 50-498 HOUSTON LIGHTING AND POWER CO.
)
S0-499 (South Texas Project, Units 1
.)
and 2)
,)
)
CERTIFICATP, OP SERVICE I hereby certify that the September 10, 1981 letter to the Members of the Board and the enclosed filings were mailed first class pos tage pre-paid to the following:
,, Charles Bechoefer, Esq., Chairman Melbert Schwartz, Jr., Esq.
Atomic Safety and Licensing Baker and Botts Board Panel One Shell Plaza U.S. Nuclear Regulatory Commission Houston, TX 77002 Washington, D.C.
20555 Dr. James C.
Lamb, III
- 313 Woodhaven Road Chapel Hill, North Carolina 27514
,, Mr. Ernest E.
Hill Lawrence Livermore Laboratory University of California Jack R. Newman, Esq.
P.O. Box 808, L-123 Lowenstein, Newman, Reis, Livermore, California 94550 Axelrad & Toll - Suite 123 1025 Connecticut Ave., N.W.
Brian Berwick, Esq.
Washington, D.C.
20036 Assistant Attorney General Environmental Protection Div.
Docketing and Service P.O.
Box 12548, Capitol Station Section Austin, Texas 78711 office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555
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I s
I-.
Lanny Sinkin
- Jay M. Gutierrez, E.Jquire 2207-D Nueces Office of the Executive Legal Director Austin, TX 78705 U.S Nuclear Regulatory Commission Washington, D.C.
20555-Atomic Safety and Licensing Board Mrs. Peggy Buckhorn U.S. Nuclear Regulatory Executive Director Commission Citizens for Equitable Utilities, Inc.
Washington, D.C.
20555 Route 1, Box 1684 Brazoria, TX 77422 Betty Wheller, Esq.
Tim Hoffman, Esq.
Ho f fm an, Steeg & Wheeler 1008 S. Madf. son Amarillo, TX 79101
.d.
>;p, c' William S. Jordan, III
- Express Mail
- Hand delivered O
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