ML20058J489

Stipulation Agreeing That Listed Exhibits Be Admitted Into Evidence W/O Formal Proof of Admissibility,Authenticity & Truthfulness.Exhibits Encl

ML20058J489
Person / Time
Site:	South Texas
Issue date:	08/05/1982
From:	Gutierrez J, Newman J, Sinkin L Citizens Concerned About Nuclear Power, INC., HOUSTON LIGHTING & POWER CO., NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Shared Package
ML20058J475	List: ML20058J471 ML20058J489
References
NUDOCS 8208090278
Download: ML20058J489 (41)

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r UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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HOUSTON LIGHTING AND POWER

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Docket Nos. 50-498 COMPANY, ET AL.

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x (South Texas Project, Units 1 G.. J' and 2)

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STIPULATION',',

Pursbnt to 10 C.F.R. 5 2.7,53,-il s hdreby ~st.ipulated and agreed w

by and between the parties to the above captioned proceeding, by and through their respective attorneys and representatives, that the following exhibits may be admitted into evidence, without formal proof with respect to their admissibility and authenticity, and not with respect to the truth of the matters therein stated:

Staff Exhibit No.

Description Date 133 I&E Report 81-37 May.11, 1982 (released to PDR June 18, 1982) l 134 Letter, Oprea I

to Collins June 24, 1982 l

l 135 Letter, Rice l

to Collins June 16, 1982 l

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l 8208090278 820805 l

PDR ADOCK 05000498 G

PDR

, CCANP Exhibit No.

Description Date 68 1976 NRC Region IV Trend Report January 4,1977 69 1977 NRC. Region IV Trend Report January 6 1978 s

70 1978 NRC Region IV Trend Mpg'rt February 2, 1979 r

~This stipulation is. entered'and' agreed to by and between the

-i undersigned persons on behalf "_of :the-parties to this proceeding.

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... Respectfully submitted, it' N

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J tk R. Newman, on/ behalf of uston Lighting and Power Company,

[ roject Manager of the South Texas Project, acting for itself and the other applicants s

4% /, iL Lanny Sfnkin, on behalf of CitizefConcernedAboutNuclear Power, Inc.

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[theNRCStaffqy N. GuyJerrez, on behelf of Dated at Bethesda, Maryland this 5th day of August,1982.

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11 MAY 582 Dockets:

50-498/81-37 50-499/81-37

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. C 'i Houston Lighting and Power Company % -,

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Mr; G. W. Opena, Jr.

c Executive Vice President D..( [,

l P. O. Box 1700 Houston,-TX 77001

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o Gentlemen:

the Systematic Assessment loff Licensee Performance (SALP) Board y

Report of the South Texas Facility, Units"1 and 2, Construction Permit This refers-The SALP Board met on September 11, 1981, to evaluate CPPR-128 and CPPR-129.

the p'erformance,of the subject facility for the period July 1, 1980, through June 30,1981.":The performance analyses and resulting evaluation are in the enclosed SALP Board Report.

16, 1981.

with you at your office in Houston, Texas, on October The performance of your facility was evaluated in.the following functional Containment and other Safety-Related Structures; Support Systems; Licensing Activities; and Corrective Action and Reporting.

areas:

The SALP Board evaluation process consists of categorizing performance in each The categories which we have used to evaluate the performance of your facility are defined in Section II of the enclosed SALP functional area.

As you are aware, the NRC has changed the policy for the h

conduct of the SALD program based on our experience Board Report.

This report is consistent with the revised policy.

staff.

Any coments which you may have concerning our evaluation of the performan of your facility should be submitted to this office within 20 days of the date Your comments, if any, and the SALP Board Report, will both appear as enclosures to the Region IV Administrator's letter which is of this letter.

SALP Report as an NRC Report. letter will, if appropriate, state the NRC pos status of your safety program.

STAFF EXHIBIT 133 G

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. c3 Houston Lighting and Power 2

5 A MAY 582 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.

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Sincerely,

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,. ' ; Mrtsinal sisn.e ny,

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e M,4. L.? Madsen, Chief Reai: tor Project Branch 1 Enclosure':

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w Appendix - NRC Report 50.498/81-37 9n-499/81-37

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i-APPENDIX U. S. NUCLEAR REGULATORY COMISSION REGION IV Systematic Assessment of Licensee Perfonnance _

Report:

50-498/81-37 50-499/81-37 1

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.,, ~t Category A2 Dockets:

50_498 & 50-499 Licensee:

Houston' Lighting and PS # Company

's P. O. Box 1700~.77001,~s.,

Houton, Texas

.p.. s Facility Name:

SouthTexasProjecf6p'its1.,and2

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- Appraisal Period:

July 1,1980-JdnN30).1981',

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Appraisal' Completion Date:

September.1[-1981 Licensee Meeting:

October-16, 1981 SALP Board:" h. C. Seidle, Chief, Reactor Project Branch 2

'-W. A. Crossman, Chief, Reactor Project Section B

0. E. Sells, NRR Project Manager H. S. Phillips, Senior Resident Inspector W. G. Hubacek, STP Transition Coordinator R. C. Stewart, Reactor Inspector i

J. I. Tapia, Reactor Inspector Reviewed by:

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7[81 W. A. Crossman, Chlef Date Reactor Project Section B Approved by:

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W. C. Seidle, Chief Odte

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JM Reactor Project Branch 2 (SALP Board Chairman) e

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I.

Introduction

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Systematic Assessment of Licensee Performance (SALP) is an integrated NRC l

staff effort to collect available observations and data annually and to l

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 national basis for allocating NRC resources and toprov,idemeaningfulguidanceitolicenseemanagement..

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II.

Criteria

a. c.3 The' assessment of licenset peiformance is, implemented through the use of seven evaluation criteria..Thiselcriteria are applied to each functional area that is applicable to tho' facility l activities (construction, pre-operation or operation) for the cat,egorization of licensee performance in

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these'< areas.

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.w-One or more of the following' evaluation criteria are used to assess each applicable functional area.

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Management involvement in assuring quality 2.

Approach to resolution of technical issues from safety standpoint 3.

Responsiveness to NRC initiatives 4.

Enforceme'nt history j

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 tne 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 ano effectively used such that a high level of t

performance with respect to operational safety or construction is being achieved.

Reduced NRC attention may be appropriate.

Categorv 2:

A combination of attributes which demonstrates achievement of satisfactory safety performance; i.e., licensee management attention and involvement are evicent and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that

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satisfactory performance with respect to operational safety or construction is being achieved.

NRC attention should be maintained at normal levels.

Catecorv 3:

A combination of attributes which demonstrates achievement of only minimally satisfactory. safety performance; i.e.', licensee management attention or invo,1vement is acceptable and considers nuclear safety,;but weaknesses are a:vident; licensee resources appear to be strained or not effectively:usEd such that minimally -satisfactory v

performance with respect to operational safety pr construction is being achieved.

Both NRC and licensee attention should be increased.

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III. Summary of Results 9 <i-

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f;:,[9L Catecorv Functional Areas

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1.

Soils and Foundations

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. NA 2.

ContainmentandotherSAfety-Related 2

Str,uctures.

3.

Piping Systems and Support's NA 4.

Safety-Related Components NA 5.

Support Systems 2

6.

Electrical Power Supply and NA Distribution 7.

Instrumentation and Control Systems NA 8.'

Lice'nsing Activities 1

9.

Corrective Action and Reporting 3

kV.

Perfomance Analyses The SALP Board obtained assessment data applicaole to the appraisal period of July 1,1980, to June 30, 1981.

The data for the South Texas Project (STP) was tabulated and analyzad 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 develcp the SALP Board Report.

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4 Functional Area Analysis 1.

Soils and Foundations All activities completed.

2.

Containment and other Safety-Related Structures p..

3 Limited work has been.de.ne relative to containment concrete activi t.i es.

However,'two noncompliances were identified: (a) failure to maintain / inspect trac.e',abil.ity 'of imbeds, and (b) failure to test for air content of grout.? itimited work effort observed.since the licenseeliftedaself-jspos'eistop1 work order appeared to be satisfactorily ' performed 6 M-ou

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, One noncompliance was identified in the ' area of other safety-related structures:

failure to' assure.that purcha' sed 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.

Picing Systems and Succorts 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 Comoonents. Including Vessels, Internals and Pumos Work activities in this area have been very low relative to setting equipment because:

(a) status of construction, and (b) sandblast activities inside Unit 1 Containment and Auxiliary Buildings.

One nonconformance was identified as a generic proolem in IE Report 50-498/81-01; 50-499/81-01:

failure to follow procedure for storage and maintenance of equipment.

Corrective action to date appears to be adequate but final follow up inspection has not been completed.

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5 Due to limited work, the Board did not assess this area.

5.

Succort Systems Including HVAC, Radwaste and Fire Protection There was limited work in 't' e areas of radwaste and fire protection h

during the assessment period.

No problems were identified in these areasduringthistime..;-p r

.s On May 8,1981, HL&P notified Region IV in accordance with 10 CFR 50.55(e) of a hanstruction deficiency concerning the

ofportionsoftheHVACj(ystem(seeitemV,1,.b,(10)). consideration of ce A

determination was made', ibased, onjan, assessment of preliminary thermal environmental' data,5that certa'in spaces and cubicles within

.46,e MEAB and FHB would..requireladdi.tional'HVAC capacity.

However, th rk relating to this item w~s' halted due to. changeover of A/Es for a

' STP.

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'N The Board assessed performance in this functional area as Category 2.

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El'e'etrical Power Sucoly and Distribution No work activity has occurred in this area; however, the storage and maintenance has been inspected and appe.ars to be generally satisfactory.

No assess $ent was made in this area.

7.

Instrumentation and Control Systems See item 6, above.

8.'

Licensino 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 r'equirements is adequate.

The Board assessed the licensee's performance in this functional area to be Category 1.

9.

Corrective Actions and Recortino The constructor (B&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 effecti.vely corrected and are not corrected in a timely manner.

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Some improvement has been noted, but the constructor has not been able to properly address the issue because of the extreme demanas l

placed on all licensee and contractor organizations by the NRC Show I

Cause.

Response effort.to the NRC Show Cause has resultad in extensive reexamination / repair programs, special technical and QA reviews, organizational 7. 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.'

v Senior licensee and,constructo'r. management must continue to be intimately involved vitRthat corrective action process to assure that this area is improyed.Q-

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'10 CFR 50.55(e) requirements Jias b'een satisfactory in all respects.

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The Board assessed licensee performance in this functional area to be Category 3.

10.

Eobclusion The Board based their overall assessment on review of the QA crogram corrective action and on observing limited work activity cat. sed 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.

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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.

Therefore, 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

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inspection activities may be resumed.

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7 V.

Succortinq Oata and Summaries 1.

Reports Data a.

LER Numbers Reviewed (not applicable) u

b.. Construction Defic {e"ncy Reports t

Thelicensee'ssysk5Elorreportingconstructiondeficiencies is located in the Houston offices.

Deficiencies identified onsite are forwarded to the; Incident Review Committee (IRC) for

'IE Insp'cticn Report 50-498/81-07; 50-499/81-07 evaluation.

e documented a reviewpoC.this system which included: '(1) reviewing licensee written re.pdrt'sifor'.1980', and (2) reviewing 58 IRC evaluations from April 25', 1977, to July 3,1980.

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Eleven reports from Julyal,1980, to June 30, 1981, were reviewed and evaluated.

These deficiencies are described below:

(1) Design of Auxiliary Feedwater Pump (All environmenta'l

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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 Leading (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 No,zzle and Seal Plate (6)

Inadequate Cable Tray Hanger Design (7) Hilti Anchor Bolts Design Strength Inadequate (8) American Bridge Structural Steel Welds Deficiencies I

(9) Non-Approved Hilti Revised QA Manual (10) Faulted Condition Heat Loads in Design of Portions of the HVAC System l

l (11) Computer Program Verification 1

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 a

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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 2-

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The licensee reporte4:two 50.55(e) construction deficiencies as a result of two Part.21 reports which were reported to the licensee.

These itams. are as follows:

(1) CONSIP Pump Shkft' Fai16re J ?, - Ff.

(2) SteamGenerato}5NaIerLevelMeasurementSystemError

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Licensee Activities

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" 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.

.i r 3.

IEs'oection Activities A special team was assigned to follow up on the IE Investigatjon 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

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revision; (2) improper appli-contractor were confirmed.

cation of coatings, (3)

Remainder were not confirmed.

design engineers not

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9 Subject Results qualified, (4) QC coating records falsified, (5). coat-ing records not authentic, (6) American Bridge doating",

J records incompletei (7) improper coating repair.

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r Two allegations Ne'litive to,

The first allegation was c.

(1) B&R foreman inti M'ating confirmed; however, morale d

employees, (2) B&R 'nianahement

- and personnel problems were took no action on'eTectricalN turned over to HL&P department problem G @

cianagement.

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site-personnel knowing '

that an NRC investigation 'was to occur.

11 r ei] Eleven allegations rtiative All allegations confimed to (1) B&R intimidation of except unqualified personnel employees,-(2) inadequate and concrete form shift.

inspection of materials leaving warehouse, (3) e.lectrical 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, c

(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.

pipe sleeve weld defects.

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 WIP#

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.y 10 Subiect Results safety-related piping in fab shop area, (4) B&R piping isometric drawings differ from specification ~ sheets'.

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Three allegationsi' relative to A11egation'(2) was confirmed (1) B&R foreman fired because and (3) had "some merit."

he resisted productio'n pressures,-(2) B&Rjehired '

personnel formerly : fired because of condit1Mit$f identified in IE' Report %79-19; g'

(3) Cadweld records inadequate' and falsified.

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One allegation relative to Allegation was not confirmed.

drug use at STP must affect

<f quality of construction.

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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.

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Four allegations relative to Allegations (1) and (2) wire (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 competent, (3) Nuclear 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 snow inspecticn results, (2) millwrignt foreman not qualified.

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11 5.

Escalated Enforcement Actions a.

Civil Penalties, and b.

Orders y

-. The NRC imposed a $10Q,000 civil penalty and issued a Show J Cause Order to th'e0.icensee on April 30, 1980.s The licensee paid the civil penalty and provided a complex and detailed response on-July?28', 1980., In accordance with the Order, on August 19,1980,afubli, cme'etingwasheldbetweenNRCand licensee senior managemgnt to discuss the subject response.

Senior representatives ftom B&R also attended.

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proceedings were'doddm<e'nted 'and placed in the Public Document Room.

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As a result of this. meeting, 'HL&P sumarized all commitments made in the written response, commitments made between NRC and licensee management, and commitments made at the public meeting y in HL&P letter (ST-HL-AE 533) dated September 18, 1980.

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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.

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Immediate Action Letters Nine immediate action letters were issued relative to

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confirming stop work actions imposed by the licensee.

The following is a summary.

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(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

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welding.

(3)

Issued October 22, 1980, confirming licensee's commitments,

for additional AWS safety related welding.

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(4)

Issued November 21, 1980, confirming licensee's comitments regarding initiating ASME welding activities.

(5)

Issued January 5, 1981, confirming licensee's commitments regarding the.ASME safety-related weldirig 10-Week Work l

Plan and resumption of safety related AWS welding.

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(6)

Issued Janua W 13, 1981, confirming lican'see's commitments regarding inf.tiat'ing complex concrete work activities.

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(7)

Issued Febr,uary, 19; 1981, concerning substitution of certain ASME WJding identified in the ASME safety related welding 10We,it(Wo)3. Plan.

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Issued March'31,.1981, confirming licensee's commitments regarding further.1simited ASME safety-related welding as outlined in.1;icensee's 12-Week Work Plan.

(9) Issued April 16, 1981, confirming licensee's commithents regarding expanding complex concrete work activities.

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Management Conferences Held During Acoraisal Period The following were management meeting's 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.

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I June 24,19P2

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1 ST-Hl.- AE-841 -

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.Fi.l,e Number G3.12

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Mr. John T. Collins L

hegional Administrator Region IV '.['M, l

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Nuclear Regulatory Commission 611'Ryan Plaza Dr., Suite 1000 Arlingtor., TW76012

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Dear Mr. Collins:

j to South lexas Project

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f( f Units 1 A 7 Docket Nos. STh 50-498, STN 50-499

- Systematic Assessment of License Perfnnnance (SALP)

Board Report fo,r the South Texas Pro.iect o

i We have reviewed the 5AU) Heur,rt for the STP dated May 11, 1982. Tne i

report, Which covers the period f rom July 1.1910. to June 30,19P.1, states l

thet the overall ratinc '%as most heavily influenr.ed by B&R's continued inability tn entrect the root cause of problems and take corrective action in a timely reanner.'- We understand that the SALP Board's cenccen ccntered priri.arily cri sort.t audit ceficiency reports ( ADR's'). Currective Actinn rieu;ests (CAR's) and unresnived items that were outstandir.g during the review per fod, end the period of time required to resolve and implerrent the necessary cor-e rective actions. We believe that actions taken by HLAP demoristrate that we have put in place a project management system that assures our contractors i

effectively inTlement corrective action in a timely v.anner.

I b the reonrt noter., the period fro July 1. loFC, to iluni.% ; 19?!,

e nr: a narr.d T.e"ioc 61 the 'it'.

'c,t uns+ tn tna.tr.m. Ceip r Dedei re-suitec in extensive reexau.ination und repr.ir, special technical and 0A reviews, organizational restructurino and chanacs in personnel, including some key managenent positions.

As a result. HLAP. focused on accelerating the irrplementation of an improved overall program that provided the basic features necessary to achieve successful resolution of specific issues such as ADR's and CAR's.

By the end of the SALP review ocriod nany improvements f

I had been made in the DA prngram.

After implementing the program improvements HL&P took a9gressive action to assure that BAR promptly implemented required corrective actions.

For example, at the beginning of 1981 there were a large number of outstanding

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STAFF EXHIBIT 134

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1 ii.... inn Lightiing L hius Comparn June 24. 1982 1

$1-HL-AL-841 File Number G3.12 i

Page 7 ADR's and CARS, however, by the~ timo of the SALP Boaro n.eeting'with HL AD l

n.angen.cnt in October, there had been si significant reduction in the number of cutstandinu ADP.'s and CAR s.

By?tne end of 1981. BAR correct We actions were essentially ut to date.

i To assure that its contractors eknt'inue to implement corrective action in a tinely manr>?r, HL&P procedures htvpbeen revised tn reouire that when-ever a response to an ADR or CAR is'.overdde for an excessive period the matter will auti.matically be escalated to' success'.ively higher levels of management in the delinquent organizations, and in HLAP. - l:

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.n.

As a result of the chanae in contractors on the Project, we anticipate a more responsive attitude toward corrective action reouirements in the Both Cechtel and Ebasco have brought toithe Pro.icct organizations future.

a high level of: successful experience in nuclear: design and construction which was previously. lading in the contractor at STP.. In addition to the. in.-

pro.ed level of nuclear experience among key project personnel, both orcanizations are impirmenting procedures that have proven successful on other nuclear projects.

Both Bechtel and Ehasco procedures reuuire that HL F.P overdue currective action item 5 be er.calated to higher manace-mr.t.

nas directed BecntEl to assure that apDroprietc Action 15 taLN. on the feel remaining items thr.t itill require resulution ur'impicmentation. )

In sun:. we aprce that the "0A prooram's success is largely dependent upon the correction of the cause of deficiencies.' and we believe the our betions renresent hipnt'itant sten toward clirtination of thc root cau as of past problems.

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STAFF EXHIBIT 135 g.,

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[I Brownf5 Root,Inc.

Post of6ce sox Three, Houston, Texas 77001..a-I

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A Hviiburton Company

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June 3f,, 3982

f.) [ Q (G 9 7 i?.'77; y

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3 f, *., M lj g Mr. John T.

Collins d [..

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Deputy Director Ph t

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U. S.. Nuclear Regulatory h

Comm15cjon

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}d 611 Ryan F.laca Drive Arlington, Texac 76011

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o RE:

South Texas Project. Units 1 and P l

D,ocket Not._50.428,50-499 i

2 1

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Lear Mr. Co311ns:

1 2

Ne have received and reviewed ther Systernatic Assess-n.e nt of Licensee Performance ("SALP") heDort Ter the abov' j

facility, $enued under cover letter cated May 11, 1982, j

frorr. C. i., Madsen to G.

W.

Oprea, Jr.

The first page of L

I of the fecility the Neport indienteu that the apprainn3 was compicted on September 1, 1981.

The Report and c'ovnr i

letier further indicate that there Wac a meetinF of the l

SALP Loard with Mr. Oprea snd other representatives of 1

11ceneen Houston Lighting & Power Company ("HL&P") on 3

October 16, 1981, to discuss a preliminary draft of the and the performance analysis and evaluation SALP F.cport j

contedned in it.

Brown & Moot, Inc. ("BER") was not, invited by HL&P to J

1 ine October 16, 1981, meeting and had no epnnrtunity ?.o

.: c.=e n'. on the draft.':,.7 5 h p e.;

n' port.1' U.te 5*

.mv cther wa; f n the preparat'.or. of tne **inti version' t T %

lievertheless. Paragraphs 9 and 10 in the SALP heport.

Beport draw a number of conclusions about B&R's alleged j

inability to correct action in a timely manner.

l i

i As you know, on September 16, 1981, HL&P dion:19aed g

B&R from its architect-engineer and construction manager On December 16, 1981, HL&P filed e. civil suit agsinst f

i role.

BER in the District Court.for Matagorda County, Texas.

The muit alleges, among other things, that B&R breached j'

s its contra:tual obligations to HT.&P by defective perform-ance in the engineering and construction or the se:uth Texas As the above dates indicate,' the meet,in; between Froj e ct.

One sal,P Board and Mr. Oprea and other-HL&P officials'to discuss the draft SALP Report took piece after HI.kP had dismissed B&R and, prenumably, wh33e HL&P was prepar3.ng.

its civil action against B&H.

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Secause of this pending litigation, I shall not here olfberate on our disagreements with the observations in _

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p Parsg.rapM 9 and 10 shout B&R's performance. ~ T da, howeve:,

wish to note our understandinF,that your inspectnra do not sl I

nor=ully seek to determine the nnT,ure Of the interaction betweer. !IRC licennees such as HLLP and their contractofu f

or ar,ent t, c.ucin :as R&R.

Thir. may have givnn rd P.e to the lt proo;.emo referenced in Faragraph'..b and 10.

Wh$1e those s

interactions may be of.Little interest to the NMO for.1,tc regulatory purposes, in our viek,'.those interact. ions i

nt-cessarily affected the nature, s'nd tiining of B&R's ccprect-

$ve actions.

1t is unfortuna@,i%herefore,.that HL&P did not c1cet to invite D&R to the Octob"er 16, 1983, ineeting to h

~

disc'uss your draft Report.

D&R)ws:fiffectively prec3uded thereby from disaunaing with you the ' man ~ difficulties iwe q]I y

oncountered.i's desi$ ng with H!.&Pf r. Prdject Management Team,

'i nr. well as MLir?'s inana gement, and from otherwise enm:r.cnting on the draft Report.

This could possibly have avoided 'the E

unfort.unate implieution of the obuervations in the SALP k

Report regard $,ng B&F..

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' i Very tru

yours,

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7 A'Y

. i Wil.lu

.. Rice f

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G. W. Opren J. H. Goldberc y

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[ f. 8 CR C[;.it rgt I".101 C'. IV 6t t P Y A'. PL A A o AIVE. sulTE 1000 AR LINGT o**, if A A5 7 6012 Je uary 4, 1977

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W. /.. Cress =an, Chief, Projects' Sect' ion I :(iG?-

?.I::D A';Al'? SIS - 1976

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Yne start of a new year'is a gnod.'tihli, to', step' b'ack and take a look at the perfor=ance of our assigned lic'ensees during the past year.

if, in out$ valuation, we detecb negarive t' rends, then we should pro =ptly arra=ge through regional supen-ision to discuss these findings with corporate =anage=ent.

~

Please re:;uest ycur yacilities Inspectors to conduct a trend analysis 6f the perfoz-*ce of each of their assigned " active" licensees during calendar year 1976.

Specific areas to be considered should include:

Nu=ber and repetitiveness of Construction Deficiency Reports.

(

Enforce =entihistory, e.g., nu=ber and repetitiveness of non-0 ce=pliance ite=s.

Responsiveness of licensee to enforce =ent action.

Nc=ber of outstanding u= resolved ite=s - ti=eliness of resolution.

Corporate u.anage=ent involve =ent in regulatory matters.

=m8' Effectiveness of QA/QC progra=s.

A.y other trends indicative of poor perfor--ce.

Please fervard ycur written evaluations to =e be COE January 28, 1977.

/ *,

/l W. C. SeidleT Chief Reactor Construction and EngineerinE Support Branch l

cc:

R. E. Hall W. E. Vetter CCANP EXHIBIT 68

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. i..r TREND ANALYSIS 1976 REACTOR CONSTRUCTION BRANCH Na N

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1-MD! ORA'D";: TOP.:

W. G. Hubacek -

R.C. Taylor',j, R. C. Stewar.'t' C. 2. Oberg';; -

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U. A. Cros$sc$i,:>. Chief, Proj ects Section TROM:

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TREND ANALYSIS M4976, J f

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Enclo' sed is a ce=o from Bill'SeidIsc concerning' licensee performance trend analysis.

To answer his que'stions please provide the following CY 76

.infor ation.

4 f a.

Nu=ber and Recetiveness of Construction Deficienev Reoorts (I have this infor=ation already) b.

Enforce =ent History t

i Tor each facility list:

(1)

Inspection Report Nu=ber (2)

Dates of Inspection (3)

Number of Violation (4)

Number of Infractiers (5) Nu=ber of Deficiencies (6)

Number of Deviations (7) Mandaye involved (for that inspection)

(9)

Re= arks (indicate if repeat fro = 1976 and 1975)

(6)

Nu=ber of outstanding unresolved itecs c.

Responsiveness of Licensee to Enforcement Action W

(1) 1s licensee on ti=e with answer to our letter?

l (2) Are answers adequate? Do ve have to go back for more information?

l (3)

Is corrective action done promptly?

(4) Are any inadequate answers our fault?

(5)

Is the licensee responsive in your opinion? Why?

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Ku Ser of Unresolved Iters - Ticelinest. Resolution (1)

u=bers are given in b.(9) ebove.

(2)

Are unresolved ite=s cleared rapidly?

(3)

Average time to clear.

(4)

Are nu=bers/ inspection on the increase? Why?

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Corocrate Management In'vokve=ent in ?,egulation Matters (1)

Sufficientmanad'eNentrepresentationofexits?

(2)

Attituderec,eptive.(.[,

(3)

Signature on licensee? letters appropriate level?

(4)

Is management involjed?'{ (indicate basis for answer)

' '.'?'. ::$

f.

Effectiveness of QA/QC Program

',5 This is a very subjective ritter.

I desire your own opinion and what you base your opinion.on.

If too early in construction phase to state, indicate this.

Also indicate what you believe we can do

.tofhave them improve their program.

g.

A.v Other Trends Indicative of Poor Perforrance List and discuss any other indications that may point out poor /

good performance.

As a last item, E ve me your. general reco=mendation on advisability of i

holding a periodic management meeting with all licensees to discuss past perforcance and identify possible problems for the licensee to avoid.

As indicated in the enclosure, this is to be your assessment of your "ac'tive" facilities.

Please have your informati'on to ne by COB on January 25, 1977.

WYn = = -, a.-

M. A. Crossman, Chief Projects Section

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Enclosure:

As stated cc:

W. C. Seidle i

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I TREN: ANI. LYSIS l

SOUTH TEXAS, UNITS 1 & 2 l

b.

Enforcement History See attachment c.

Responsiveness of Licensd6 to Enforcement Matters

'.7 (t) Yes

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(2) On the basis of $ndl completed correspondence cycle - yes they are adequate.

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(3) Yes a

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• f (5) Yes - licensee personneli while well qualified, are somewhat in-experienced at QA and have expressed appreciation for the occasional suggestion on how to head off problens.

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N0mber of Unresolved Items.- Tireliness Resolution (1)

In b above (2)

es (3) (iene'ral one inspection cycle.

(4) No e.

Corporate Management Involvement (1) Both licensee and general contractor sit'e management and usually the licensee's home office project QA manager attend the exits..

(2) Very l

l (3) Executive Vice President appears adequate.

1 (4)

I believe licensee management is very involved. The impression is that the executive VP is of the opinion that their program should be good enough that we will have njt negative findings.

l f.

Effectiveness of QA/0C Program l

It appears that the licensee has gathered a group of technically sound, agressive people to maintain surveillance over the general contractor who has line level QA/QC responsibility. The general contractor (Brown & Root) l.

3 0A/Q: appears to have an acequate prcerar but has some reluctance to exercise its authority.

Few strong positions are taken unless the licensee provokes action.

Programmatically both the licensee and. Brown & Root are quite adequate.

The only real solution (s) are:

(1) The licensee take over full QA/QC responsibility with P&R having none, or

.~

(2)~ Replace B&R QA/0C'.s'jte management and perhaps some home office management with personnel with more intestinal fortitude.

.- c.;,(d,- _ ;

g.

Any Other Trends f

As a further point on f.abov?ll-it was the licensee who provoked B&R

-T'

.e QA into taking -action agai'nstiyDM;.B&R s'upported the December 30, 1976, Stop Work Order with a vety' weak group of descrepancies uncovered by an

.a'fdit performed that day, but h'ad-been maintaining full time surveillance

' over PDM for six weeks.,_It has' always been ax'i.omatic that it is far easier to be agressive and firm with subcontractors than with your com-panies' construction forces for obvious reasons such as continued employ-I ment.

Here we have the situation where B&R QA could not bring it upon t6e'selves to take effective action with a subcontractor. What is

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. probable when B&R begins the more difficult and important work involving piping and electrical systems? I think we wait and see.

I see no reason for periodic senior level management meetings. Manage-ment meetings should be reserved for actual need so as to keep high visibility status.

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January 6,197E I'

MEMOP.4NDUy. F00.:

W. G. Hubacek R. G. Tayl o r..', 'T

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R. C. Stewart S -'

C.

P.. Dberg ;.,b.,-

s.,.

W. A. Crossman24hi.ef, Projects Section FRGv.:,

TREND ANALYSIS {W,71977 N -.

SU5 JECT:

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a.

re-x

.s. i Please perfer. a trend analysis of the: performa~nce of each of your assigned

e:tive" liter. sees fer the calendar year 1977.

In cases where responsibility for licensets is being reassign'ed..the inspector who was responsible for the 1icensee ir. :aiendar year 1977 will prepare the analysis.

Your analysis should int 16ce tne followin5 information:

a.

f; umber and Recetiveness of Construction Deficiency Reoorts b.

Enforcs +r.: History For escr. facility list:

(1)

Inspection Report fiumber (2)

Da es of Inspection (3) tiu er of Violations (t) fiu ::er of Infractions l

(5) ric oer of Deficiencies l

(6) t;u.oer of Deviations (7)

P.ar. days involved (for that inspection)

(8)

Re arks (indicate if repeat from 1977 and 1976)

(9) t;.: rer of unresolved ite s c.

Responsiver.ess of Licensee to Enforce ent Action (1)

Is licensee on time with answer to our letter?

(2) Are answers adequate?

Do we have to go back for more infomation?

(3 Are any inadequate answers our fault?

(4 Is corrective action done promptly?

(5 Is the licensee responsive?

CCANP EXHIBIT 69

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Un res o':. e : 1: ens (1) Ars unresolved items cleared rapidly?

(2) Are nutbers/ inspection on the increase? Why?,

(3) riarber of unresolved items' escalated to enforcerent items.

-'7 E.

Coroo-ate Menacerent Inv'ol,vement in P.e:ulation Matters (1) Sufficien: r.anage:En't" representation at exit ir.terviews?

(2) Attitude reces:ive?"J. '

Signature or, iftenseed. 'tt'ers appropriate level?

(3) e (4)

Is r.anagement involvedty($l.Indi.cate basis for ar.swer)

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f.

Effectiveness of 0010: Procran ]

'},

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Tf11s is a very subjectivetmatt'fr.

I desire 'your own opinion and basis for your opinion.

If toc'early in construction phase to state. indicate this.

. iso indicate what you'believe we can do to have them improve th eim,

er (12) Dates of Inspection l3) -Am:1)er af Wiolations { Or6er af infractions 1 Sunber.ef -Deficiencies 1 dumberaf Seviations 4 Sandays involved (for that inspection) .:i 'Ammarts (indicate if repeat frec 3976 an'd 1977) 714 -%mber af.amresolved items ~ %sponstyds of Licensee to Enforcement Actior. c. (1) 1s 11ceasee en time trith answer to our letter?Do are have to go -12).Are ansmers adequate 7 -amation? Are arty Snadequate answers ourfault? _ds corrective ecttondone srtuptly? ~ 43 Ms 2.he 11consee responsivet -4tIV . -[ CCANP EXHIBIT 70 .k;ggseHiefnErT.Nossacn7mh i %3E M I; N i h ::,- i i [. I r.::,c ; -. '. n u.M ::W h: c.i!,1Pi i 8 l c. ' Onreselve' 1tecs 1

1) Are unresolved ite=s cleared rapidly?

l l

2) Are ntsnbers/ inspection on 1.he increase? Why?

Li 3) humber of unresolved itams escalated to enforcement iter.s. ]l: l. a. Corporate Managsoent Involvenent in Regulation Matters j! j (1 . Sufficient managemenj representation at exit interviews? 1} l i (2 Attitude receptivsl.. ~ l (3 Signature on licensee. letters appropriate leveli (4 Is management triv'olved?. (Indicate basis for answer) ,. c. \\ ) T. Iffactiveness ef 0VOC P'ro'erar. { ~ . l'Ucs-This-1s e eerymIhjectis matter. 3 desire your own opinion end r & asis Tor.yourepinion. Of too early in construction phase to state.1ndicatethis. Riso'4ridicate what you believe ese can do to have that deprove their 4,vgrer.. This inforw. tion should not L be included in the doceented analysis, but you should be prepared l .to dis cans 1tudth W. Seid)a. 1 1 .ir j ,.s. Art'y Sther Trends Indicative of Poor Perforinance )' 4.ist end.sfiscuss arny ether indications that any point out poor / good P .perforuance. I [ Tlease have your1nformation to me by IDS en Tebruary 2B,1975. n t w Lo-=e a b w. A. c~ -- g W. A. Crossman, Chief frnjects Section x:: er.z.s saie i ) ~. .[.i.b.. *:. 1 ~ .: N- / ?. r.> a - n- - - ~ cr..r. ... -x A>. - ... w - h~ :-Y . n _.. ~.. - _ _. e ..-.:.t. T ....;~~ *:...- Si* ; '. : '. '.s .,e ( * *

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A s.#?.: O'. T I s a! 7t: * : .i Octoter 15, 1579 1 's 't 1 l. A LA MEMTnANDUM FO:.: W. A. Crossman, Chi f, Prcjects Section J t r o.:... x 1 i FROM: P. C. Stewar, Re'attor inspector, Projects Sectior. SUSJE~T: TREND ANAI.YS. I!.-c.i.t7.E. ' ' ..u&j{ 13? ' 7'GNy'co'.inerespbnse to your memorandum, same ThE attacnec information'is Drov E g subject, cate Fecruary 2,1979...The inVprmation, preparec Dy each of the assignec prc.3ect inspectors, include orily. those facilities that were in an active cons ructier, status curine:CY 197E. r . f C

< f l

l W.' 'y l.%- fs R. C. Stew ,, Reactor Inspector 1 Projects Sectior-I i P h r ) s B [ s1 s 0 a p i i i. I 4 5.utr Texas Project 1 & 2, DN 50-49E;50-49E TREh; ANALYSIS - 1978 Number and Recetitiveness of Construction Deficiency Reports a. Seven items were reported as potential cnstruction deficiencies of o which four were determined to be reportable in the context of 50.55(e). Two of the items (voids in LiTt 15 of' Unit 1 containment and voids in the ' slab under Unit 2 spent,', fuel pool) were repetitive. Slt r N b. Enforcement History [:.[, ' 5 (See attached sheet) -Q. 3 .+ ru: c. Responsiveness of Licensee'.tetEnfdrcement Action ~ s (1) NWovemberThe licensee was timely'y ; 4in all responses e 15, 1978, wh'ich transmitted report No. 78-16. The response to this letter was dated January'8,1978. This late response was apparently due to simultaneous reassignment of the Project QA Supervisor and the Site QA Supervisor at that time which caused a . temporary discontinuity in their tracking system. (2) ' Answers were generally adequate except the initial response to report No. 78-16. Items failed to adequately address corrective actions to preclude recurrence. A subsequent response, which we requested, was adequate. (3) Inadequate answers were not our fault. The licensee attributed the inadequacy of their response to repo'rt No. 78-16 to undue haste in preparation after being informed by our office that their response was overdue. l (4) Corrective action was done promptly. j (5) The licensee has been responsive. l l d. Unresolved Items (1) Unresolved items were cleared in a timely manner.. (2) The number of unresolved items per inspection has increased. This ( increase may be attributed in part to increased construction activity at STP and to the focusing of our attention on certain areas because i of recent allegations. Another factor is the recent change (June 1978) of the site quality procedures which has caused some confusion in I implementation and documentation. (3) None of the unresolved items were escalated to enforcement items. f' m s 1:..- Ts a:- F r:;e:- e. Corporate Manacement in Regulation Matters ~ (1) There was sufficient management representation at exit interviews. (2) Management's attitude was r'eceptive. l 1~ I (3) Signature on licensee },et$ers was of appropriate level. A.... v .(4) Management appears to tie ~ involved in QA matters. Their involvement ~ appears to have interis'ified since our management meetings which took place following our invsstigations of allegations. Their increased involvement is e0idencef,b'y;their recent recrganizatio) of the STP project team by which Hli&P(Sas become much more active in construction and QA activities. lIntadditlpn,.HL'&P'ma'nagement has been frequently observed at the STP site'during o'ur inspections. ~ ' N., y / 4/ f. Effectiveness of OA/0C Program v - s (oral presentation) /f 9 Any Other Trends Indicative of Poor Performance Frequent allegations of questionable QA/QC practices. e l I e b r l l l i l l l ___,__m._Am.. i I ' b e ::e:- i;.,r e n r L'.s. L 2, Du EU '9i,; SL-4 H ENFORCEMENT HISTORY Report No. Dates y_ J_, D D U M/D' Remark,s_

• .'s. t 78-01

1/10-13 0 52 - 0 0 0 6-3/8 .., f:.. 78-02 1/25-27 0 '.',0,. '0. 0 2' 2 Environmental .:y. ~ , y j. i_0 78-03 2/21-24 O 0-2 9-3/4 0'.. ) k..:.%..1Wf.9 ~*. O a 78-0~4 3/21-23 O 10 Infraction not cited Y '? ya 'O ."s0 '0 0 -3/4 Investigation 78-05, 3/21 0 ~ s 78-06 4/04-07 0 40 O' O O 3-1/2 78-07

{(4/17-20 0

2 0 0 1 9 78-08 5/16-19 0 0 0 0 0 3 78-09 5/16-19 0 0 0 0e 0 6 Investigation 78-10 5/30-6/2 0 0 0 0 2 7 78-11 6/11-14 0 0 0 0 0 9 78-12 6/25-28 0 0 0 0 0 9 Investigation Meeting 78-13. 8/15 0 0 0 0 0 78-14 8/22-25 0 0 0 0 0 6-7/8 Investigation 15 9/11/14 0 2 0 0 3 6-1/2 Investigation ( 78-16 10/24-27 0 3 0 0 1 9-78-17 12/05-08 0 0 0 1 0 6 78-18 12/19-22 0 0 0 0 1 6 l l l t v m .t e uh C ' ' '. ~ UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING AND POWER COMPANY, . Docket Nos. 50 498 ET AL. 6 50-499 -s (SouthTexasProject, Units 1&74.)) ~ s 'd CERTIFICATE'0F ' SERVICE . & m. I hereby certify that copies of."UGU4CNOTION TO RE0 PEN RECORD FOR LIMITED ' PURPOSE OF ADMITTING 00GUMENTS" 0 4 'fSTIPULATION" in the above-captioned - proceeding have been served on the' follo,wirig;by deposit in the United States maiT,~first class, or, isN ndicated by an asterisk, through deposit in the Nuclear Regulatory Commiss. ion'ninternal mail sistem, this 6th day of August, 1982: w Charles Be'c'hhoefer, Esq., Chairman *. Administrat'ive Judge Brian Bemick, Esq. Atomic' Safety and Licensing Board Assistant Attorney General Panel Environmental Protection Division U.S. Nuclear Regulatory Commission P.O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711 Dr. James C. Lamb III Administrative Judge Jack R. Newman, Esq. 313 Woodhaven Road Lowenstein, Newman, Reis, Chapel Hill, NC 27514 Axelrad & Toll 1025 Connecticut Avenue, N.W. Mr. Ernest E. Hill Washington, DC' 20036 Administrative Judge Lawrence Livermore Laboratory University of California Mrs. Peggy Buchorn P.O. Box 808, L-46 Executive Director l Livermore, CA 94550 Citizens for Equitat>le Utilities, Inc. Melbert Schwarz, Jr., Esq. Route 1, Box 1684 Baker and Botts Brazoria, TX 77442 One Shell Plaza Houston, TX 77002 Mr. Lanny Sinkin Citizens Concerned About William S. Jordan, III, Esq. Nuclear Power Harmon & Weiss 2207 D. Nueces 1725 I Street, N.W. Austin, TX 78705 Suite 506 Washington, D.C. 20006 , Kim Eastman, Co-coordinator Atomic Safety and Licensing Board Barbara A. Miller Panel

• Pat Coy U.S. Nuclear Regulatory Comission Citizens Concerned About Nuclear Washington, DC 20555 Power 5106 Casa.Oro Atomic Saf.ety and Licensing Appeal San Antonio, TX 78233 Board Panel *.

t U.S. Nuclear Regulato'ry Comission Docketing and Service Section*,* Washington,PC 20555 Office of the Secretary U.S. Nuclear Regulatory Comissiom 's Washington, DC 20555 .. Mr. David Prestemon*

• Jid, ", ',

Legal Coun,sel // Atomic Safety and Licensing '.. g. Board Panel U.S. Nuclear Regulatory Comissidn Washington, D.C. 20555

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