ML20055B296
| ML20055B296 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/12/1981 |
| From: | Miraglia F Office of Nuclear Reactor Regulation |
| To: | Purple R NRC |
| Shared Package | |
| ML20055B245 | List: |
| References | |
| FOIA-82-266 810621, NUDOCS 8207210229 | |
| Download: ML20055B296 (10) | |
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Per.your rc~q'uest of June 10, ~1981, attached are.-the ilRR :
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SALP evaluations for the set 7.feias" Project >and "
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NRR Perforr.ance Evaluation r
Facility:
South Texas Froject Project Manager:
D. Sells Appraisal Period: July 1,1980 - June 30,1981 1.
Performance Elements a.
In the early months of this appraisal period the quality of amendments to the FSAR required close attention in that instructions for posting were not always satisfactory.
This administrative problem has greatly improved over the appraisal period.
GenerM letter responses were
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riot always prompt, but HL&P performance has improved significantly in this. area during the last quarter of the period.
b.
HL&P has consistently strived to provide responses in a timely and responsive manner.
My experience with, a'nd observation of, the HL&P licensing staff has been that they place extra emphasis on providing timely and responsive answers _to the staf f.
This has significantly improved since October 1980 when a management reorganization occurred that established the position of Vice President for Engineering Design and Construction.
c.
HL&P has displayed 'an acceptable level of knowledge with regard to regulations, guides, standards, and generic issues.
Where misunderstanding and doubt has occurred it has been principally because the staff has not yet clearly defined the criteria to be applied.
d.
Technical competence has been greatly improved during the last nine months of the appraisal period by the addition of more experienced people to the HL&P staff and 'to the staff of Brown & Roof the architect engineer and constructor.
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e.
HL&P has prepared themselves for meetings with NRR and conducted the meetings in a professional and coripetent manner.
f.
A still long unresolved open item is the question of an acceptable soil-structure interaction analysis.
HL&P is currently re-evaluating the work that has been accomplished to' date and future discussions will be held to resolv; this matter upon completion of the HL&P review.
The use of Hafnium rods in the core can be expected to become a significant issue, however, Comanche Peak is the lead plant at the present time.
g.
Organization;and management capabilities is one of the subjects of the l
q current expedited hearing now in progress.
I do not expect this hearing, i
on limited issues, to be completed before early 1982.
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HL&P is just beginning to develop and Sove into the operating licensing training and examination area in detail. Activity completed prior to June 30, 1981 indicates that HL&P is taking good initial and positive steps to meet NRC requirements.
i.
It is too early in the licensing review to develop a laundry list of specific issues in view of the fact that staff review, except in the area of QA and Management Competence and Character, has not progressed far enough to identify specific issues needing priority resolution.
2.
The performance of HL&P with regard to the OL licenisng application has shown steady improvement over the appraisal period. This improvement has been most noticeable since October 1980 when a reorganization occurred within HL&P and with the addition of more technical people to the HL&P staff.
3.
Notable Strengths and Weaknesses a.
Strengths 1.
Have developed a strong and aggressive upper management team to supervise the project.
2.
Have expanded and developed an improved and more qualified QA program staff to oversee and monitor the design and construction effort of Brown and Root.
.b.
Weaknesses 1.
Need to develop methods that more quickly anticipate the needs of NRC.
2.
Need to continue the development of' the technical and operational staff to assure adequate support when Unit 1 becomes operational (September 1984 to April 1985 in my opinion).
4.
Based upon my observation of oth9r utilities over the past nine years, I rate HL&P's performance - above average. The HL&P staff has been very responsive to my requests and provided telephone input many times on very short notice.
Their recent activities to become more heavily involved in overseeing the work of Brown and Root should provide egeptional dividends as construction continues.
S.
This report reflects the views of the PM and has not been circulated to other NRR divisions for comment due to the short turnaround in responding to an I&E request. Comments will be solicited prior to the Regional SALP meeting currently scheduled for August or September 1981 (Collins to Moseley Memorandum, May 21, 1981 attached).
on e is, Project Manager Licensing Branch No. 3 Division of Licensing s
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Working Paper SALP Staff Summary - South Texas Project '(STP) Units 1 and 2 June 1981 I.
Regional Evaluation (August 1979 - July 1980)
See memorandum, Collins to Moseley dated May 21, 1981, attached.
II.
CDR History (January 1, 1979 - December 31,1980)
Records indicate that five Construction Deficiency Reports (CDRs) were submitted in 1979 by the licensee.
Thirty-three were submitted in 1980.
Region IV has cited Houston Lighting and Power (HL&P) for failure to notify and failure to report in accordance with 10 CFR 50.55(e)
(Reports 80-01 and 80-05).
The deficiencies reported during 1980 are varied in nature and do not appear to indicate a trend in any one specific area.
Three such reports covered major deficiencies dealing with non-conformJng backfill, nonconsolidation of concrete and damage to the
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containment liner.
III.
Noncompliance History (January 1, 1979 - December 31, 1980 - 24 months)
Construction Facility Number of_
Noncompliances Per_
Noncompliance Comparison Noncompliances Inspection Ma_nhour_
South Texas Project 1 (42
.010 South Texas Project 2 43
.010 Region IV average - 7 reactors 2
.014 National average - 78 reactors 18
.014 Comparisons between. facilities under construction are particularly difficult.
Also, inspection effort is dependent to some degree on the level of construction activity and percentage of the facility completion. At the close of the review period, South Texas Project Unit I was approximately 60 percent complete and Unit 2 about 23 percent complete.
Most of the items of noncompliance were applicable to both facilities.
Approximately one-half of the total number of noncompliance items were against Criterion V of 10 CFR 50 Appendix B and involved the failure
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to follow written instructions or procedures generallyTri tTE~ areas of doc _ument control, material storage, concrete placement, and welding.
N During the first ten months of 1979, 16 items of noncompliance were identified.
Two of the licensee responses to Notices of Violations during this period were deemed inadequate requiring additional regionel and licensee corresp,ondence over 3-4 months to adequately resolve.
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IV.
Allegation / Investigation Review (January 1,1979 - December 31,1980)
A total of 14 investigative inspections at South Texas Project were conducted during the two-year review period in response to various allegations.
Four investigations occurred in 1979; the fourth such effort was significantly larger in scope and was prompted by the licensee's performance records and Clegations made in November 1979.
Two factors stand out:
1)
The inspection record shows that although the licensee's
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performance up to November 1979 was cooperative and generally diligent in correcting specific problems, when cited, the same or simUar nrnbleme eventitall ced; and 2)
There existed a significant list of allegations concerning irregularities in civil construction and quality programs; lack of management support, and intimidation and harassment of _QA inspectors by constructi_on personnel.
This investigation started on November 9,1979 and continued through February 7, 1980.
It revealed various management weaknesses.
Prob-lems were identified in the areas of safety-related. welding controls; HL&P QA audit and surveillance programs were found to be improperly implemented.
Their QA/QC program had not prevented recurrence of poor concrete practices.
There was evidence of inadequate training, experience and/or education among those involved in quality functions.
As alleged, there were substantiated cases of harassment and intimi-dation of employees stemming from production pressures.
Twenty-two j
items of noncompliance were identified.
In February 1980, as a result of these findings, HL&P was fined
$100,000 in civil penalties (the maximum allowed) and issued an Order to Show Cause.
This Order required HL&P to set forth its reasons why certain safety-related construction activities at the South Texas Project should not be stopped until specified corrective actions were taken.
The licensee discontinued complex safety-related concrete pours and safety-related welding subject to AWS and ASME requirements.
HL&P was directed to complete ten specific actions in order for NRC to evaluate whether future work at the South Texas l
Project could proceed in accordance with the regulations.
I In 1980 ten separate investigations were performed at the South Texas Project in response to allegations from employees, former employees, intervenor groups, and concerned citizens.
These allegations involved purported drug use by employees,_irrogolarities in construction processos. incompetent /unqu_a_lified personnel, questionable hiring and firing of employees _, and recorde falsification.
l V.
Performance Appraisal Branch Coments No PAS inspection conducted.
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- VI.
NRR Project Manager Comments There are no co y NRR Project Manager.
VII.
Miscellaneous IE records for the South Texas Project during the review period indi-cates that Units 1 and 2 received a total of 2064 inspection /inves-tigation manhours for CY 1979, and 1970 inspection / investigation manhours for CY 1980, for a total of 4034 manhours.
More than 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> were devoted to the investigation conducted between November
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1979 and February 1980 (Report 79-19).
The Region IV average is about 1730 inspection manhours per plant and the national average is 1200 inspection manhours, for 78 construction-phase reactors over the 2-year period between 1/1/79 and 12/31/80.
Safety-related complex concrete pours and safety-related welding was discontinued at South Texas Project as a result of NRC esca-lated enforcement action taken in early 1980.
The licensee has been slowly resuming this work in the Spring of 1981 on a piece-meal basis.
Incremental resumption of safety-related construction addressed by the ifliC I)rder is subject to approval by the NRC.
Region IV has augmented inspection of the licensee's actions.
Unit-1
- 60 pe ent complete with an OL scheduled for September 1983 an nit'2 is 23 percent complete with an OL scheduled for i
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September 1985.
ASLB hearings relating the issue of an OL comenced in May 1981 and are expected to continue through September 1981.
VIII.
SALP Staff Coments This licensee has more items of noncompliance than most construc-tion licen_ sees.
The Region has expended an inordinate amouritof tirile investigating allegations received primarily from employees working at the site.
Serious allegations regarding production pressures that effectively thwarted quality functions were l
substantiated as were others involving lack of support by QC management, harassment, intimidation and threats directed toward QC inspectors.
Early evidence of harassment, intimidation, and lack of QC management support was known to HL&P. Actions by the lice _nsee to correct these problems were_ inenmolete or inefTective.
i I
It appears that HL&P abdicated too much of the responsibility for l
the construction of the South Texas Project to Brown & Root, their i
A-E and constructor.
l The IE record, through the end of the review period, indicates that extensive effort has been expended by the-NRC site inspector and region-based inspectors to followup and resolve the problems l
identified in the investigation documented in report 79-19.
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noted above there were ten investigations performed in 1980 to look into a series of allegations that in many respects are similar to those previously received.
Based upon the licensee's QA program difficulties, the number of noncompliances, the extent and nature of NRC regulatory actions, the SALP staff would view the South Texas Project as below average during the period reviewed.
Region IV reports that the licensee has made improvements in their oerfnemande~as a result of licensee corrective actions already taken or initiated.
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HRR Performance Evaluation Facility:
South Texas Project Project Manager:
D. Sells
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Appraisal Period:
July 1,1980 - June 30,1981 1.
Performance Elements
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a.
In the early months of this appraisal period the quality of amendment ~s to the FSAR required close attention in that instructions for posting were not always satisfactory.
This administrative problem has greatly improved over the appraisal period. Generic letter responses were not always prompt, but HL&P performance has improved significantly in this area during the last quarter of the period.
b.
HL&P has consistently strived to provide responses in a timely and responsive manner. My experience with, and observation of, the HL&P licensing staff has been that they place extra emphasis on providing timely and responsive answers to the staff.
This has significantly improved since October 1980 when a management reorganization occurred that established the position of Vice President for Engineering Design and Construction.
c.
HL&P has displayed an acceptable level of knowledge with regard to regulations, guides, standards, and generic issues.
Where misunderstanding and doubt has occurred it has been principally because the staff has not yet clearly defined the criteria to be applied.
d.
Technical competence has been greatly improved during the last nine months of the appraisal period by the addition of more experienced people to the HL&P staff and to the staff of Brown & Root, the architect engineer and constructor.
e.
HL&P has prepared themselves for meetings with NRR and conducted the meetings in a professional and competent manner.
f.
A still long unresolved open item is the question of an acceptable soil-structure interaction analysis.
HL&P is currently re-evaluating the work that has been accomplished to date and future discussions will be held to resolve this matter upon completion of the HL&P review. The use of Hafnium rods in the core can be expected to become a significant issue, however, Comanche Peak is the lead plant at the present time.
g.
Organization and management capabilities is one of the subjects of the current expedited hearing now in progress.
I do not expect this h' earing, on limited issues, to be completed before early 1982.
At
?E
. h.
HL&P is just beginning to develop and move into the operating licensing training and examination area in detail.
Activity completed prior to June 30,1981 indicates that HL&P.is taking good initial and positive steps to meet URC requirements.
i.
i It is too early in the licensing review to develop a laundry list of" specific issues in view of the fact that staff review, except in the k
area of QA and Management Competence and Character, has not progressed far enough to identify specific issues needing priority resolution.
2.
The performance of HL&P with regard to the OL licenisng application has shown steady improvement over the appraisal period.
This improvement inas l
been most noticeable since October 1980 when a reorganization occurred within HL&P and with the addition of more technical people to the HL&P staff.
L 3.
Notable Strengths and Weaknesses a.
Strengths 1.
Have developed a strong and aggressive upper management team to supervise the project.
2 Have expanded and developed an improved and more qualified QA program staff to oversee and monitor the design and construction effort of Brown and Root.
b.
Weaknesses l
1.
Need to develop methods that more quickly anticipate the needs of NRC.
2.
Need to continue the development of the technical and operational staff to assure adequate support when Unit 1 becomes operational (September 1984 to April 1985 in my opinion).
4.
Based upon my observation of other utilities over the past nine years, I rate HL&P's performance - above average.
The HL&P staff has been very responsive to my requests and provided telephone input many times on very short notice.
Their recent activities to become m' ore heavily involved in overseeing the work of Brown and Root should provide exceptional dividends as construction continues.
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5.
This report reflects the views of the PM and has not been circulated to other URR divisions for comment due to the short turnaround in responding to an I&E request. Comments will be solicited prior to the Regional SALP meeting currently scheduled for August or September 1981 (Collins to Moseley Memorandum, May 21, 1981 attached).
on Se 1s, Project Manager
. Licensing Branch No. 3 Division of Licensing t
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JUN 181982 Dockets:
50-498/81-37 50-499/81-37 Houston Lighting and Power Company ATTN:
Mr. G. W. Oprea, Jr.
Executive Vice President c
P. O. Box 1700 Houston, TX 77001 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Board Report of the South Texas Facility, Units 1 and 2, Construction Permits CPPR-128 and CPPR-129.
The SALP Board met on September 11, 1981, to evaluate the performance of the subject facility for the period July 1, 1980, through June 30, 1981.
The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report.
These analyses and evaluation were discussed with you at your office in Houston, Texas, on October 16, 1981.
The performance of your facility was evaluated in the selected functional areas:
Containment and other Safety-Related Structures; Support Systems; Licensing Activities; and Corrective Action and Reporting.
The SALP Board evaluation process consists of categorizing performance in each functional area.
The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP Board Report.
As you are aware, the NRC has changed the policy for the conduct of the SALP program based on~our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff.
This report is consistent with of the revised policy.
On May 11, 1982, you were requested to provide comments concerning our evaluation of your facility.
In that 20 days have passed, and no comments have been received, the SALP Board Report is being issued as an NRC Report.
PD12 M iijs9e g RPS-B h RPB1 DRRP RA7pIV g WCrossman/dsm GMadsen JGa iardo JCollins 6/8/82 6/g /82 6/ #82 6/ </82 A9
Houston Lighting and Power 2
Company M 173 'co'~
Should you have any questions concerning this letter, we will be pleased to discuss them with you.
. Sincerely,
'*hnctnci sv.ed sve U. I ce _t:r -
John T. Collins 5
Regiona'l Administrator
Enclosure:
Appendix - NRC Report 50-498/81-37 50-499/81-37 bec to DMB (IE01) bec distrib. by RIV:
BC W. Crossmhn PM W. Hill AE00 W. Seidle ELD D. Sells, NRR IE FILE H. Phillips IE/RPRIB W. Hubacek NRR/DHFS R. Stewart NRR/0LB J. Tapia RAD ASMT BR J. Collins RESEARCH RPB2 PDR:HQ TPB LPDR C. Wisner NSIC INFO SYSTEM NTIS TEXAS DEPT. OF HEALTH RESOURCES RIV FILE
11 MAY 1982 Dockets:
50-498/81-37 50-499/81-37 Houston Lighting and Power Company ATTN:
Mr. G. W. Oprea, Jr.
Executive Vice President P. O. Box 1700 Houston, TX 77001 Gentlemen:
This refers to the Systematic Assessment of Licensee Performance (SALP) Board Report of the South Texas Facility, Units 1 and 2, Construction Permit CPPR-128 and CPPR-129.
The SALP Board met on September 11, 1981, to evaluate the performance of the subject facility for the period July 1, 1980, through June 30, 1981.
The performance analyses and resulting evaluation are documented in the enclosed SALP Board Report.
These analyses and evaluation were discussed with you at your office in Houston, Texas, on October 16, 1981.
The performance of your facility was evaluated in the following functional areas:
Containment and other Safety-Related Structures; Support Systems; Licensing Activities; and Corrective Action and Reporting.
The SALP Board evaluation process consists of categorizing performance in each functional area.
The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP Board Report.
As you are aware, the NRC has changed the policy for the conduct of the SALP program based on our experiences and the recently implemented reorganization which emphasizes the regionalization of the NRC staff.
This report is consistent with the revised policy.
Any comments which you may have concerning our evaluation of the performance of your facility should be submitted to this office within 20 days of the date of this letter.
Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which issues the SALP Report as an NRC Report.
In addition to the issuance of the repcrt, this letter will, if appropriate, state the NRC position on matters relating to the status of your safety program.
WCross[ man /dsmGMadRPB1 [
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RPS-B SRI RPB4 DRRP MAQA7 n WHubacek HPhi lips WSeidle JGagl ardo Ecji,.i.-JC' lins 4/23/82 4/ /82 4 M /82 4
/82 4/M/82 4/ '7/82%d* 4/ /82
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Houston Lighting and Power 2
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Mf 7332 Company Comments which you may submit at your option, are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely,
'tOriginal Signed by: "
Gs
.L' MADsEN**
G. L. Madsen, Chief Reactor Project Branch 1
Enclosure:
Appendix - NRC Report 50-498/81-37 50-499/81-37 YLo b/h8 sr. e cc to DMB (IE
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bcc distrib. by RIV:
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'S I'Y W. Crossman P
W. Hill A D W. Seidle EL D. Sells, NRR IE ILE H. Phillips IE/ RI W. Hubacek NRR/ H R. Stewart NRR/
J. Tapia RAD MT BR J. Collins RES A:CH RPB2 P
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DRg C. Wisner NSIC LNIC S'iSTEH NTIS TEXAC DEPT. Or " ALin RESCURCES-RIV FILE l
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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION REGION IV Systematic Assessment of Licensee Performance Report:
50-498/81-37 50-499/81-37 Dockets:
50-498 & 50-499 Category A2 Licensee:
Houston Lighting and Power Company P. O. Box 1700 Houton, Texas 77001 Facility Name:
South Texas Project, Units 1 and 2 Appraisal Peri.d:
July 1, 1980-June 30, 1981 Appraisal Completion Date:
September 1, 1981 Licensee Meeting:
October 16, 1981 SALP Board:
W. C. Seidle, Chief, Reactor Project Branch 2 W. A. Crossman, Chief, Reactor Project Section B D. E. Sells, NRR Project Manager H. S. Phillips, Senior Resident Inspector W. G. Hubacek, STP Transition Coordinator R. C. Stewart, Reactor Inspector J. I. Tapia, Reactor Inspector 7
Reviewed by:
m-W. A. Crossman, Chief Date Reactor Project Section B Approved by:
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W. C. Sei~dle, Chief 04te ~/
JM Reactor Project Branch 2 (SALP Board Chairman) l
2 I.
Introduction Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations and data annually and to evaluate licensee performance utilizing these data and observations as a basis.
The integrated systematic assessment is intended to be sufficient-ly diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management.
II.
Criteria The assessment of licensee performance is implemented through the use of seven evaluation criteria.
These criteria are applied to each functional area that is applicable to the facility activities (construction, pre-operation or operation) for the categorization of licensee performance in these areas.
One or more of the following evaluation criteria are used to assess each applicable functional area.
1.
Management involvement in assuring quality 2.
Approach to resolution of technical issues from safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management) 7.
Training effectiveness and qualification Attributes associated with the above evaluation criteria form the guidance for the SALP Board for categorization of each functional area in one of three categories.
Performance categories are defined as follows:
Category 1:
A combination of attributes which demonstrates achievement of superior safety performance; i.e., licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Reduced NRC attention may be appropriate.
Category 2:
A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that
3 satisfactory performance with respect to operational safety or construction is being achieved.
NRC attention should be maintained at normal levels.
Category 3:
A combination of attributes which demonstrates achievement of only minimally satisfactory safety performance; i.e., licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
Both NRC and licensee attention should be increased.
III. Summary of Results Functional Areas Category 1.
Soils and Foundations NA 2.
Containment and other Safety-Related 2
Structures 3.
Piping Systems and Supports NA 4.
Safety-Related Components NA 5.
Support Systems 2
6.
Electrical Power Supply and NA Distribution 7.
Instrumentation and Control Systems NA l
8.
Lice'nsing Activities 1
9.
Corrective Action and Reporting 3
IV.
Performance Analyses l
The SALP Board obtained assessment data applicable to the appraisal period of July 1,1980, to June 30, 1981.
The data for the South Texas Project (STP) was tabulated and analyzed and a performance analysis was developed for each of six functional areas.
The SALP Board met on October 16, 1981, to review the performance analyses and supporting data and to develop the SALP Board Report.
1 i
4 Functional Area Analysis 1.
Soils and Foundations All activities completed.
2.
Containment and other Safety-Related Structures Limited work has been done relative to containment concrete activities.
However, two noncompliances were ident.ified: (a) failure
)
to maintain / inspect traceability of imbeds, and (b) failure to test for air content of grout.
Limited work effort observed since the licensee lifted a self-imposed stop work order appeared to be satisfactorily performed.
C One noncompliance was identified in the area of other safety-related structures:
failure to assure that purchased material (inspection of Nelson stud welding to embeds) conformed to procurement documents.
This welding was performed and inspected initially by Bostrom Bergen and was again inspected by Brown & Root (B&R) vendor inspectors.
This item and several 50.55(e) reports have indicated a weakness in the B&R vendor surveillance program.
Proper corrective action has been taken to correct this programmatic weakness.
The Board considered management control in this functional area to be of a Category 2 level.
3.
Piping Systems and Supports Region IV has performed very little inspection in this area for two reasons:
(a) NRC efforts have been concentrated on QA programmatic areas, and (b) the volume of work activity has been low.
In recent months, work has stopped in this area to allow design engineering to catch up.
The Board did not make an assessment in this functional area.
4.
Safety-Related Components, Including Vessels, Internals and Pumps Work activities in this area have been very low relative to setting equipment because:
(a) status of construction, and (b) sandblast l
activities inside Unit 1 Containment and Auxiliary Buildings.
One nonconformance was identified as a generic problem in IE Report 50-498/81-01; 50-499/81-01:
failure to follow procedura for storage and maintenance of equipment.
Corrective action to date appears to be adequate but final follow-up inspection has not been l
completed.
I 1
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5 Due to limited work, the Board did not assess this area.
5.
Support Systems Including HVAC, Radwaste and Fire Protection There was limited work in the areas of radwaste and fire protection during the assessment period.
No problems were identified in these areas during this time.
On May 8,1981, HL&P notified Region IV in accordance with 10 CFR 50.55(c) of a construction deficiency concer.ning the
)
consideration of certain faulted condition heat loads in the design of portions of the HVAC system (see item V, 1, b, (10)).
A determination was made, based on an assessment of preliminary thermal environmental data, that certain spaces and cubicles within the MEAB and FHB would require additional HVAC capacity.
- However, work relating to this item was halted due to changeover of A/Es for STP.
The Board assessed performance in this functional area as Category 2.
6.
Electrical Power Supply and Distribution No work activity has occurred in this area; however, the storage and maintenance has been inspected and appears to be generally satisfactory.
No assessment was made in this area.
7.
Instrumentation and Control Systems See item 6, above.
8.
Licensing Activities Licensee activities dealing with licensing requirements have improved significantly during the reporting period.
Responses to requests for information have been timely and of good quality during the reporting period.
Licensee understanding of NRC requirements is adequate.
The Board assessed the licensee's performance in this functional area to be Category 1.
9.
Corrective Actions'and Reporting l
The constructor (S&R) continues to experience difficulty relative to corrective action.
It also appears that the root cause of the problem associated with NRC and licensee identified deficiencies is that the deficiencies are not effectively corrected and are not corrected in a timely canner.
6 Some improvement has been noted, but the constructor has not been able to properly address the issue because of the extreme demands placed on all licensee and contractor organizations by the NRC Show Cause.
Response effort to the NRC Show Cause has resulted in extensive reexamination / repair programs, special technical and QA reviews, organizational restructuring, numerous personnel changes, and rapid turnover of personnel including key management positions.
In all fairness, the performance of the constructor site organization should be evaluated during more normal conditions.
Senior licensee and constructor management must continu~e to be intimately involved with the corrective action process to assure that this area is improved.
Licensee reporting of construction deficiencies in accordance with 10 CFR 50.55(e) requirements has been satisfactory in all respects.
The Board assessed licensee performance in this functional area to be Category 3.
10.
Conclusion The Board based their overall assessment on review of the QA program corrective action and on observing limited work activity caused by the IE Investigation Report 50-498/79-19; 50-499/79-19, Show Cause and Stop Work Orders imposed on Brown & Root, Inc., the prime contractor, by the licensee.
The rating was most heavily influenced by B&R's continued inability to correct the root causes of problems and take corrective action in a timely manner.
The QA program's success is largely dependent upon the correction of the cause of deficiencies.
Although Houston Lighting and Power Company (HL&P) has taken affirmative steps and actions in the area described above, the implementation of corrective action measures and procedures is still considered a weak area.
Tnerefore, the overall rating for licensee performance is determined to be Category 3, because of HL&P's inability to compel a significant improvement in B&R's performance in this area.
11.
Board's Recommendations The Board recommended augmented inspection of the South Texas Project through the transition phase of construction and into restart of construction until performance demonstrates that normal inspection activities may be resumed.
7 V.
Supporting Data and Summaries 1.
Reports Data a.
LER Numbers Reviewed (not applicable) b.
Construction Deficiency Reports The licensee's system for reporting construction deficiencies is located in the Houston offices.
Deficienci.es identified 2
onsite are forwarded to the Incident Review Committee (IRC) for evaluation.
IE Inspection Report 50-498/81-07; 50-499/81-07 documented a review of this system which included: (1) reviewing licensee written reports for 1980, and (2) reviewing 58 IRC evaluations from April 26, 1977, to July 3, 1980.
Eleven reports from July 1,1980, to June 30, 1981, were reviewed and evaluated.
These deficiencies are described below:
(1) Design of Auxiliary Feedwater Pump (All environmental factors not considered in design.)
(2) Breakdown in QA Program Relative to Application of Paint to Steel and Concrete Surfaces Except for Liner Plate (3)
Reactor Containment Building Structural Steel Beams Loading (4) Unacceptable Surface Condition of Weld in Main Steam Piping and Secondary Shield Wall Whip Restraints (5) Cooling of Primary Shield Wall Penetration Insufficient Air Flow Between Reactor Coolant Nozzle and Seal Plate (6)
Inadequate Cable Tray Hanger Design (7) Hilti Anchor Bolts Design Strength Inadequate (8) American Bridge Structural Steel Welds Deficiencies (9) Non-Approved Hilti Revised QA Manual (10) Faulted Condition Heat Loads in Design of Portions of the HVAC System (11) Computer Program Verification A trend was noted relative to the deficiencies reported; that is, 7 of 11 were design problems.
As a result of this trend and other information, a special NRC inspection of the L
8 design engineering organization was requested on May 27, 1981.
That inspection and review is still in progress and final results are not available.
c.
Part 21 Reports The licensee reported two 50.55(e) construction deficiencies as a result of two Part 21 reports which were reported to the licensee.
These items are as follows:
(1) CONSIP Pump Shaft Failure (2)
Steam Generator Water Level Measurement System Error 2.
Licensee Activities The licensee's construction activities have been low during the subject period because of the NRC Show Cause Order and Stop Work Orders imposed by the licensee.
3.
Inspection Activities A special team was assigned to follow up on the IE Investigation 79-19 and the Show Cause Order.
This effort continued during the entire reporting period and involved approximately 1318 inspector-hours.
An insignificant number of inspector-hours was devoted to the routine inspection program because of follow-up and reactive inspection.
4.
Investigation and Allegations Review Twelve investigations were conducted during the subject period which involved 756 inspector-hours.
These investigations are summarized below:
Subject Results a.
Three allegations relative to Allegations were not confirmed.
(1) painting records, (2) weld rod oven power loss, (3) RCB-2 settlement.
{
b.
Seven allegations relative to Specification, improper coating; (1) improper specification improper coating records at revision; (2) improper appli-contractor were confirmed.
cation of coatings, (3)
Remainder were not confirmed.
design enginects not 1.
9 Subject Results qualified, (4) QC coating records falsified, (5) coat-ing records not authentic, (6) American Bridge coating records incomplete (7) improper coating repair, c.
Two allegations relative to The first all,egation was
[
(1) B&R foreman intimidating confirmed; however, morale employees, (2) B&R management and personnel problems were took no action on electrical turned over to HL&P department problems.
management.
d.
One allegation relative to Allegation confirmed.
site personnel knowing that an NRC investigation was to occur.
e.
Eleven allegations relative All allegations confirmed to (1) B&R intimidation of except unqualified personnel employees, (2) inadequate and concrete form shift.
inspection of materials leaving warehouse, (3) electrical personnel not qualified, (4) concrete form shifted, (5) HL&P/B&R forewarned of NRC inspection, (6) FREA procedure improper, (7) B&R performing work that should not have been performed,-
(8) low morale, (9) termination shack calibration practices improper, (10) B&R did not advise employees of results of employee survey, (11) procurement of electrical supplies improper.
f.
One allegation relative to Allegation not confirmed.
g.
Four allegations relative to Allegation (4) was confirmed (1) electrical shop records /
but item was not safety-calibration, (2) storage of related.
safety-related piping in lay down area "M",
(3) storage of
10 m
Subject Results safety-related piping in fab shop area, (4) B&R piping isometric drawings differ from specification sheets.
h.
Three allegations relative to Allegation (2) was confirmed (1) B&R foreman fired because and (3) had "some merit."
he resisted production pressures, (2) B&R rehired personnel formerly fired because of conditions identified in IE Report 79-19, (3) Cadweld records inadequate and falsified.
i.
One allegation relative to Allegation was not confirmed, drug use at STP must affect quality of construction.
j.
Five allegations relative to Allegations were not confirmed.
(1) construction deficiencies not properly reported, (2) clearly promoted to project quality engineer not qualified, (3) B&R auditor at STP not qualified, (4) management intimidated an employee, (5) B&R engineer's experience inadequate for position to which he was to be promoted.
k.
Four allegations relative to Allegations (1) and (2) were (1) designers of STP piping not confirmed, while (3) was systems are not competent, turned over to Region IV (2) supervisors signing /
Vendor Inspection Branch.
approving drawings not l
competent, (3) Nuclear l
Power Service, Inc., is worst contractor onsite, (4) B&R stress analysis of piping system questioned.
1.
Two allegations relative to Allegations were confirmed.
(1) permanent plant equipment not inspected and records falsified to show inspection results, (2) millwright foreman not qualified.
~
11 5.
Escalated Enforcement Actions a.
Civil Penalties, and b.
Orders The NRC imposed a $100,000 civil penalty and issued a Show Cause Order to the licensee on April 30, 1980.
The licensee paid the civil penalty and provided a complex and detailed response on July 28, 1980.
In accordance with the Order, on 2
August 19, 1980, a public meeting was held between~NRC and licensee senior management to discuss the subject response.
Senior representatives from B&R also attended.
These proceedings were documented and placed in the Public Document Room.
As a result of this meeting, HL&P summarized all commitments made in the written response, commitments made between NRC and licensee management, and commitments made at the public meeting in HL&P letter (ST-HL-AE 533) dated September 18, 1980.
Parties to intervene requested that all construction work be stopped but this request was denied.
However, the Commission did decide to have accelerated hearings on the QA portion for the operating license to determine the licensee management's character and competence.
These hearings started on May 12, 1981, in Bay City, Texas, and are expected to extend into late fall 1981.
c.
Immediate Action Letters Nine immediate action letters were issued relative to confirming stop work actions imposeo by the licensee.
The following is a summary.
(1)
Issued July 17, 1980, confirming licensee self-imposed Stop Work Order to check adequacy of controls for AWS welder qualifications and requalifications.
(2)
Issued October 3, 1980, confirming licensee's commitments regarding re-examination, repair, and restart of AWS welding.
(3)
Issued October 22, 1980, confirming licensee's commitments for additional AWS safety-related welding.
12 (4)
Issued November 21, 1980, confirming licensee's commitments regarding initiating ASME welding activities.
(5)
Issued January 5,1981, confirming licensee's commitments regarding the ASME safety-related welding 10-Week Work Plan and resumption of safety related AWS welding.
I (6)
Issued January 13, 1981, confirming licensee's commitments regarding initiating complex concrete work activities.
1 (7)
Issued February 19, 1981, concerning substitution of certain ASME welding identified in the ASME safety-related welding 10-Week Work Plan.
(8)
Issued March 31, 1981, confirming licensee's commitments regarding further limited ASME safety-related welding as outlined in licensee's 12-Week Work Plan.
(9)
Issued April 16, 1981, confirming licensee's commitments regarding expanding complex concrete work activities.
6.
Management Conferences Held During Appraisal Period The following were management meetings held during the SALP reporting period:
a.
At the request of the licensee, a management meeting was held on June 17, 1980, to discuss actions being developed regarding Show Cause Order items, b.
At the request of the licensee; a management meeting was held to discuss actions being taken regarding Show Cause Order items related to Special Investigation 79-19.
c.
November 18, 1980, to discuss status of outstanding Show Cause Order items and restart of work.
d.
March 23, 1981, to discuss restart to ASME welding and current status of Show Cause Order commitments.
2
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