ML20062B976
| ML20062B976 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 10/03/1978 |
| From: | Eric Turner HOUSTON LIGHTING & POWER CO. |
| To: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20062B973 | List: |
| References | |
| NUDOCS 7811020387 | |
| Download: ML20062B976 (7) | |
Text
..
ITOW Houston 4
i e.m jN g ; L. ht.&g ing
- yw Power
- i.. n n.Q y
Company L
i a
i; j j
ij E!rctric Tower al 0
HQ Box 1700 il i i O Houston. Texas 77001 october 3, 1973 ST-HL-AE-293 SEN:
C-0510 Mr.
h'. C. Seidle Chief, Reactor Construction and Engineering Support Branch USNRC, Region IV 611 Ryan Plaza Drive, Suite 1000 i
Arlington, TX 76011 9
SUBJECT:
Meeting with the NRC on August 15, 1978-RE:
S0-498 RPT. 7S-13' 50-499 RPT. 78-13 50-498 RPT. 78-12 S0-499 RPT. 78-12 j
Dear Mr. Seidle:
1 h'e appreciate the opportunity to meet with you concerning 3
the South Texas Project Electric Generating Station Civil QA Program.
Attached is our response to the allegations presented'in your report 50-498/78-12 and 50-499/78-12.
Our in-depth review leaves us confident that the construction work performed meets the requirements 1
for cur project. The actions takea to correct any possible weaknesses -
in our quality assurance program are open to your review during future inspections.
If you have any questions regarding this-matter, please contact me.
i Very truly yours,
. a.. /n
/,
E. A. Turner, Vice President Power Plant Construction and Technical Services EAT /cas Attachment i
cc:
Mr. R. A. Frazar Mr. H. L. Key 7 8','..0 3 0 3 % 7
.' r s
~'
)
/
RESPONSE TO ALLEGATIONS (RE:
NRC Report 50-498/ 7S-12 and 50-499/7S-12)
Allegation No. 1:
l Inabi.'ity of _ civil QC inspectors to do their -jobs due to-issuance of new
'w procedt.res without sufficient trGining in the new procedures before impleaenettion.
3 A.
Discussion:
t Our review showed that attendance at training courses on the-revis'ed procedures was not mandatory for QC personnelt Therefore, unknown to B6R management, several inspectors-did not attend. All inspectors were given a reading list including a' check sheet.which l
had to be signed acknowledging that he had read and understood i
each procedure.
B.
Corrective Action:
[
C O
The training was repeated and the reading lists reissued and signed.
C.
Action Taken to' Prevent Recurrence:
9
!/
1 B6R will take attendance rosters to ensure that appropriats personnel have received required training. Make-up training will be conducted i
when needed.
s 4
..M 7/
Allegation No. 2:
The STP QA Program does not provide an adequate nonconformance reporting i
system.
i A.
Discussion:
There have been interpretational problems relative to the use of '
l Nonconformance Reports (NCR) versus Field Requests for Engineering.
4 Action (FREA).
B.
Corrective Action:
A clarification has been added to the B5R procedure stating defini-l 3
tively when an NCR is to be used and when a FREA can be, prepared.
4 i.
C.
Action Taken to Prevent Recurrence:
s; HLSP site QA is closely monitoring nonconformance reporting by B5R and has increased the performance of surveillance of A.,
l ccacrete place: tent inspection.
i
[
f -
"\\.
' T~
g
. - -, - -. -. - ~.,..
..,-.--,,,,-r
Allegation No. 3 and Allegation No d :
QA reluctance to issue Nonconformance Reports when probleras are identified by QC.
Inadequate support of QC inspectors by QA.
A.
Discussion:
It was determined that only one NCR was not procersed.
This case involved an out of sequence approval sign-off of an inspection record and it was not appropriate to process the NCR since the condition was promptly corrected and no defective material was involved.
HL6P cannot find any evidence to substantiate these allegations; however, it appears that there is a need for more effective communication between the QC inspectors and QC supervision.
B.
Corrective Action:
The B6R Project QA bbnager is striving to spend more time in the field to ensure the effectiveness of the program. Additionally, the B6R Project QA Manager has counselled the B6R QA/QC staff
~
relative to objectives of QA/QC and the necessity of reporting all departures from design, Codes, standards o' safe practices.
HL6P has conduct 3 d an extensive review of preplacement and placement activities to assure that quality has not been compromised due to the condition described by these allegations.
No abnormalities were fourid during this review.
C.
Action Taken to Prevent Recurrence:
HL6P site QA is closely monitoring B6R QA/QC activities.
Allegation No. 5:
Poor document control for drawings and documents used by craft and QC personnel.
v A.
Discussion:
Due to procedural differences, QC personnel in the field <ere not obtaining documentation in the same time frame as craft personnel.
In spite of this delay, QC inspectis a persunnel had, on their own initiative, actively sought out the correct documentation when disparities were noted between craft and QC documentation.
I j
i l
k~
r s
[
3 s,
- ~
5 a
B.
C'drrective Action:
Extensive review of previeds work has been done to ensure that no worL was accepted to it. correct design documentation.
Additionally, the preced;re for providing documentation to the inspectors has been revised to ensure proper processing with runners assigned to 4'atribute new documents and pick up out-dated revisions from the ficId.
3 C.
Action Takcn tc Prevent Recurrence:
In addition to the revised sp cocedure for transmitting documents to the inspectors,' air condi tioned work stations were ordered l
l and are now being received-to provide better conditions for inspectors to review documentation and prepare for upcoming l
inspections.
)
I G
({}
Allegation No. 6:
Inaccurate Cadweld as-built drawings.
l
{
s A.
Discussio.n:
This allegation has been made several times before and has been shown by extensive (review by B6R, HLGP and the NRC to be I
unsubstantiated.
Another review by B6R and HL6P has reached the same conclusion.
._B.
Corrective etion j
No corrective action was required.
C.
Recurrence Control:
HL6P will continue to monitor this item to ensure compliance with the procedures.
I AlIegation No. 7:
Inaccessibility of upper management.
A.
Discussion:
In order to provide more effective canagement of the QA/QC program, the B6R Project QA Manager has recently reorganized the site QA/QC organization and redefined some job descriptions.
As a result of the changes, some QC inspectors are unhappy because they feel they no longer have the latitude they need to perform their job.
Our review showed these opinions were unjustified.
Effective systems for identification of problems to management are implemented.
b
-s r
_4 B.
Corrective Action:
BGR management has reaffirred, by memo and personal aceting, that it is the responsibility of the inspectors to identify problems and concerns.
Additionally, they have been directed that they may pursue valid concerns past their immediate supervisor, even if he disagrees with them, without fear of reprisal.
C.
Recurrence Control:
The BSR Project QA Manager has initiated more frequent observations and discussions in the field with the inspectors in order to provide visibility of managenent concern and opportunity to discuss QC inspectors' concerns.
HLGP site QA personnel will continue to be receptive to reviewing QC inspectors' concerns.
Allegation No. 8:
g
(
Undue pressure by Construction.
A.
Discussion:
There are pressures on the Inspectors to perform in a timely and expeditious manner as well as to assure quality; however, if the inspector performs his job effectively, we do not view these pressures as abnormal.
There have been occasions when preplacement "punchlists" appeared abnormally long. The quantity of items on these lists made the inspector think that the Construction engineer was not properly assuming his responsibility or that construction was trying to pass off incorrect work.
It is our opinion,that these types of findings are those that QC inspectors should find, but the quantity Concerns us.
B.
Corrective Action:
B5R Construction has directed its Construction engineers and craft foremen to ensure that craft personnel are making every effort to meet the project requirements.
When compliance with specification or procedure requirements cannot be met within the linitations of the design, either the FREA or NCR system will be utilized to resolve the problem.
Additionally, the use of the "punchlist" has been codified to allow anyone who identified an item to enter the information on the punchlist.
B5R will assign additional personnel to Construction Engineering to perform construction inspection.of inprocess work.
~
- s C.
Recurrence Control:
The B6R Project QA 1Snager has initiated more frequent observations and discussions in the field with the inspectors in order to provide visibility of management concern and opportunity to discuss QC inspectors' concerns.
As stated earlier, IILGP site QA personnel will continue to be receptive to reviewing QC inspectors' concerns.
l In addition, llLGP QA management has met with the B6R QC Inspectors i
and Supervisors to review the project objectives and the role of QA/QC in achieving those objectives.
Emphasis was placed on the absolute necessity of team work to do the job right and to utilize the available problem solving channels for identifying and resolving project problems.
Plans for enhancing the. effectiveness of our program dere reviewed also.
j-Allegation No. 9:
C Performar:e of repairs without approved procedures.
)
A.
Discussion:
1 There have been occasions where repair procedures were authorized via the telephone prior to obtaining an approved FREA.
d B.
Corrective Action:
~
The use of telephone minutes has been restricted solely to inter-preting the intent of design documents.
In all other cases either the FREA or Document Change Notice (DCN) system must be j
used.
Those cases involving lack of approved procedures have been reviewed and no unacceptable conditions were found.
B6R Engineering will transfer appropriate responsibility to the the construction engineers or to design engineers assigned to
(
the field to enhance resolution of field engineering problems.
C.
Recurrence Control:
B6R QA/QC and HL5P QA will continue to monitor ongoing repair activities to ensure compliance with the procedural requirements.
Allegation No. 10_:
Inability of Construction Engineering.
A.
Discussion:
l As noted earlier,. the quantity of items on the construction "punchlist" J tends to indicate that the craft personnel, craft foreman and Constructio e
engineers are either not fully aware of procedural requirements or have not consistently implemented these requirements.
t l
l
, e L
B.
Corrective Action:
BSR QC and Construction forces have been counselled with regard to their responsibilities and methods to be used in the effective supervision of their personnel.
Additional training will be provided to both Construction and QC personnel.
B5R Construction engineering will assign additional personnel to perform inprocess review of work to ' ensure the design documents and construction procedures are met.
C.
Recurrence Control:
Both HL6P QA and Construction Division personnel have stepped up their surveillance of construction activities to ensure compliance.
Also, more effective supervision will be provided by B5R to both Construction and QC on all shifts.
c O
e f
f l