ML20080Q564

Advises That,Due to Seriousness of Violations by Brown & Root & Util at South Texas Project,full-scale Public Hearing in Matagorda County,Tx Mandatory

ML20080Q564
Person / Time
Site:	South Texas
Issue date:	05/20/1980
From:	Van Hoy G AFFILIATION NOT ASSIGNED
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20079E666	List: ML20080Q539 ML20080Q564
References
FOIA-83-289 NUDOCS 8310140088
Download: ML20080Q564 (1)

Text

Appendix C p.

.w ..g 3

[

l- . ,

l vt . .

. ;5 :. 't ;23 -

%o-4 .g*_ h

• j y" '{

U % %iv-W w$4 .- -

M iii.p sg ~A.=T I amA*I . m:*

- w.

4-01245551c: 05/20/5C IC5 I56BNGZ CS: =5He T1372e4G33 w3* 708. -0USTON Tr 7T 05-20 0941A EST p.

> T E 0:3ECT045 0FFICE OF INSPECTION AND O EN800cE=ENT. v!CTOR STELLO ErEC. LEGAL DIR, US NUCLEAS 4E0VLATORY COMMISSION _

eAS-IN TON DC 20555 0 1 *.

THE SE320'swE!5 0F THE VIOLATIONS BY BRonN AND ROOT AND HOUSTON 8S LIGm.T AND P0aER AT THE SOUTH YEXAS NUCLEAR PROJECT MAKE IT MANDATORY _

THAT ME NAVE A FULL $CALE PUBLIC HEARING IN THE AREA 0F INTERE8T, F MATAGOPDA COUNTY THE COOPERATION OF YOUR OFFICE IN THIS NATTER WILL r BE GREATLY APPPECIATED CALE VAN MOY HOUSTON CULFC0AST SUILDING8 TRADE COUNCIL @

~

09181 EST ..

'i:.

"CO*F HGP C (I

.n ni G

C 23 A70 e31o140c88 830823 PDR FOIA I HAMLINe3-289 PDR -

1

- m G

v

, 3 i ,4 . b. . ~ ..N 9.- .* .

.= .. , - - .

..c ._ . .  ;

"ustin

, 'X .701

car Set.:t r Latsa.n:

Tiiis is in fi:.al i r.:pt se tc 3.:or letter dated ;' arch 14, 1980 which referenced an aarlier latter (Cct aar 19, 1979) ca the $3uth Texas Project. On April 8,

' .~ 0 0 w e p ro c r'?d a n i nt e : '.3 2  ; anse to you.

T: s i T. est Qation r.e'ar: ad . , in the 4,'.a rim l i - 3 r ':s -an c: pi?ted, a

; :g af :'a ^ --isc:  ; s .ce- ' ald t I . .:. '01 . .

nt actians a t' a foi n of a civil .. 3 .' ' o.3'.a.'y) >nd .a ^ 2, a i r;-m pct.ed

'

.s t .he licensee, H:es tur. L ;hti ,g :mid Pc. .:r C :- ery. A4 .; of trese

'n- Siits is enclosed fcr  : - ~ofc. atian. W oi: 'il find ' 1 this

' ~

'le concens cf

. i -sti' .at, C ': .

. , ;3rt

.ed by the 'r .it'

'en - d .e dic c s  : ca ,. :t

-; .3.

2,,

.g ........=:.

..e

,,. . . ,h ..,e

. ,., g.

, t. .,,...,...,

e

, <'.-;s.

i.f ..a r . , ha of furtkar 7ssist=.nce, please ccn'.act us.

Sincerely, ,.? h.

'lillic. J. Di eks ACli' y ~

"r

'o 3i 9Ctor e, c r e .i 's i . e.!s c'

. l _ r '. ; #, 'a t d 2/2:.'30 ., th .c ' n .: . s

.~.n.

. '. _ ,. c.,.b.. .

Tt

)

.. . .i

>. c frit. 71V

- ' n: -

75 h..D.

a .:

G . ,./ . , 2. . _ .. .. , ., ,  :

.; R. E . S r. e r- -

~Z

. ..c, u;A G. Er;.ter 't: ._.3 _.  ::: ,578)

c. ~~. - A N L." ' t'

.a. . - , . . r .,, . _,. .

j. p .

a

\ r. y 78

.. ... :v, .c .>

.. .t R. . C.

~"c

,o,, - .E E/ .' '. .

.e

2. 1 c  :.

,S;mpscn,

. .t\

s. i .t. ,1, , it - -

'g

-. : i u, : n g

'>l v

.c Y E L L u-,W r.a. ,. ..'_ .

StE cn...c v ..Jd e. -

a

si RCI:IE RCI:IE RCI: IE ELD 2: IE D:IE -:3 5 50 RES % ,.ner C..'ReinT.uth HDThornburg 20: : ng 'J 5 + e ; i :

J2) 5/

. 5/ '50 5/ /SO 5/ /80 5/ /20 .E3 E 2 ,30  !

O

., ~ . ..

- ~ . ,, .

.,,a

. .e . o. .

,. n...- .

..c . .a u, .. ,

t,ustin, TX Ii701 Car Senator :e ntren:

This is in final carpense to your letter dated " arch 14, 1980 which referenced an earlier letter (October 19, 1979) cn the Scuth Texas Project. On April 8, I?E0 'e provided an interim response to you.

' e i castigatica .efe. red to in the intacia la'tsr ".as :sen completed, a tr i a' g Of t':a r -i s si: c.ers has ':2 2n F21d (2 /1;/50), 2-1 enforce. ment a: Lions in the 'cr:n of a civil penalty (scr.etary) and an 3rder '.rce been proposed 3;ai st the iicensee, Houston Lighting and Pcwer Cer.pany. A copy of these d;c. 2nts is enclosed for your inforTation. As you will fi n d frcm this i- E r. tion the cancerns of your caneti kent, "r. Clif'c M G qe ..cre in art s;bs' intiated by the in,r-stigstion and .e did f'-d pecbi'-,s in the proje:t a h;ch .e are ha. ring cc. rected throujh '.he '.se of t:.c 0;.ier 2nd our follt. up ns sctic,as.

if .e can t? of furt'.ar assistance, please contoct us.

Sincerely, William J. Sirc.s

. :u. .i.g ut.1ce .iise a,cr ior ,, ,L. :s cicture:

. . . ' *a

. '*P, n

, . . '?s

.c a -:,c t.  ;

M. Licitra, ?ER H. 3. ?L,ill i.cs , R:V

' . . '..'e.s, '.i.*

Pr .

n . .n: , c, . ..r e s W.~ 2 Di sc il, . E0 H. D. Thorr. burg, IE f

D.

. .l' .: . k, , ..v

.A

/*i.,..

a.

rs ?

r.,.i .ah,

.Ju T

2 .C r e. .c

.'er.

T. - s- O,  : .. C T. t.  ;. . .t C. ..

.e., . ._,,

u. . . . . e i, .

ac

.- _ d.

cen

. .; J - .> 6 ~/ a3 mi J. Cock, S?A L. 'J . "ci d : cad, IE H. Shepar, ELO s -ill-2220 -06)

J. P. '1 array, ELO c ?_ CY V. Stello, IE IE Fi'es R. C. DeYcung, IE C. .esi Fi'es 0 Thcmpson, IE IE '. cad;ng EDO Peading /

.( .

p( kPU:5" RCI: I E

-?

Y' /E h PCI: IE 6 f" (Ct.,:UE E,LCk[d,L

. ,';r ' b0D:IE,{

N.~ ,'.'.

D: Id' ti EDO 5/12.50 m '- =

' e r .' W r w th HOT h , r rt u rg , ' .~ F 7CCaYoung VSteI!o Jco W 5 ,- ,30 5/ ,00 5 /, f. ,'80 S ' . ISO 5/ '80 5/../EO 5/ ,- i O s.. .

e. P .

Houston

~

~

r ComJany Electric Tower

( - --

EQBox 1700 lI h -l l Houston. Texas 77001 May 23, 1980 Nuclear Regulatory Commission Washington, D.C. 20555

~

Attention: Mr. Victor Stello, Jr.

Director Office of Inspection and Enforcement Re: Docket Nos. 50-498 50-499 Gentlemen:

This is filed in answer to the " Notice of Proposed Imposition of Civil Penalties" (April 30, 1980) in the subject dockets.

As indicated in the " Reply to Notice of Violation" (Reply) filed today in this docket, the items of noncompliance, as we understand them, are essentially substantiated. Accord-ingly, that Reply is hereby incorporated by reference, pursuant to the Notice of Proposed Imposition of Civil Penalties, and a check in the amount of $100,000 is forwarded herewith.

We shall now devote our entire attention to attacking the " root causes" of the items of noncompliance for which this penalty has been assessed while undertaking preparation of a comprehensive response to Section V of the Order to Show cause (April 30, 1980) in the subject docket.

Very truly yours, HOUSTON LIGHTING & POWER COMPANY 0 l B'y // ,

rgE[W. Oprep'/ Jr . "

xecutive Vict Pf(s'ident Enclosure ~7 cc: Attached Certificate'of Service

/ 7 bA O,o/ft. 0'u a $/ i$ /

a / ph 7 i

y-UNITED STATES OF AMERICA t NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD I

IN THE MATTER OF S

S HOUSTON LIGHTING & POWER S DOCKET NOS. STN-498 OL I

COMPANY, ET AL. E STN-499 OL-4 (South Texas Project- S 3

Units 1 and 2) S CERTIFICATE OF SERVICE I hereby certify that copies of Applicant Houston Lighting

& Power Company's Answer to the Notice of Proposed Imposition of Civil Penaltities in the above-cpationed proceeding, were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this 23rd day of May, 1980:

r Charles Bechhoefer, Esq., Chairman

! Atomic Safety and Licensing Board i U. S. Nuclear Regulatory Commission Washington, D.C. 20555 I Dr. James C. Lamb, III 313 Woodhaven Road

. Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Henry J. McGurren, Esq.

. Hearing Attorney

} Office of the Executive Legal Director i U. S. Nuclear Regulatory Commission 4

Washington, D.C. 20555 l

Richard W. Lowerre, Esq.

Assistant Attorney General l for the State of Texas j P. O. Box 12548, Capitol Station

! Austin, Texas 78711 J

4

Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Mrs. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 Steven A. Sinkin, Esq.

116 Villita San Antonio, Texas 78205 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Chase R. Stephens Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4  ?> /' ! av,,

Dated: May 23, 1980

, _ , _ . . - , - .-- - ., - --- r---

e i Houston r

1 Com3any J Electric Tower W L.- 20 Box 1700 11 11 i a Houston Texas 77001 1

May 23, 1980 i Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Victor Stello, Jr.

Director Office of Inspection and Enforcement Re: Docket Nos. 50-498 50-499 Gentlemen:

This answer is filed pursuant to Section VI of the

" Order to Show Cause" (April 30, 1980) in the subject dockets.

Applicants do not seek a hearing with respect to this matter.

Section VI of the " Order to Show Cause" states that any answer filed in response to the Order "shall admit or deny each allegation made in Section II and III" of the Order.

Section II essentially recounts the Nuclear Regula-tory Commissions' (NRC 's ) Inspection and Enforcement (I&E) activity on the South Texas Project. To the extent we are aware of such activities we admit the facts as stated therein; however, there are certain matters peculiarly within the Commission's knowledge of which we are unaware and which we can neither affirm or deny (e.g. "On November 2, 1979, the RRI was contacted on site by a Brown and Root QC inspector who alleged that civil QC inspectors were being harassed and intimidated by Brown and Root construction personnel", p. 8).

! It is our understanding that the allegations in Section

) III are, with one exception, based on the items of noncompliance I specified in the " Notice of Violation" (April 30, 1980). Appli-cants hereby incorporate the text of their " Reply to Notice of s Violation" (Reply) filed this date. It will be noted that each item of noncompliance is answered in the Reply with a clear m

gam /

2 ya O-90.

4

• Houston Liftmg & Pow Company

• > Nuclear Regulatory Commission May 23, 1980-Page  !

affirmation or denial; accordingly, we regard the matters under-lying Section III as having been answered.

With respect to the one allegation that "two apparent false statements in the FSAR were identified regarding test and observation actually performed" the supporting information is not found in the Notice of Violation. This item will be addressed in the response to Section V, item 10 of the Order to Show Cause.

In response to the second paragraph on page 9, the substance of the allegation (with respect to certain incidents of'harrassment and intimidation) is conceded in the response to the first item of noncompliance; we also note the extensive remedial actions which have been, and will be, implemented to >

prevent recurrence of these conditions. To the extent the para-graph suggests that STP may not be constructed to NRC standards, we do not believe that major nonconforming conditions exist, although the matter is under study pursuant to Section V of the Order. We note, in particular, I & E's conclusion that "during the investigation no items of major safety significance were found which related to harassment or intimidation of QC personnel."

As indicated in the response to the Notice of Violation, manage-

, ment is committed to completion of a project conforming to NRC

)

requirements, intends to be more involved in the program and will take steps to assure a "high visibility" for QA/QC functions.

In response to the third paragraph on page 9, clearly lack of detailed involvement by management was a contributor to the problems noted in the paragraph, but it is an overstatement to suggest that this war the only reason behind these problems.

As discussed in the cover letter, the reasons for the items of noncompliance are complex, involving several " root causes." We do, believe, however, that to attack these " root causes" active i'nvolvement at the highest levels of B&R and HL&P management will be required.

In the paragraph beginning at the bottom of page 9 and continuing to page 10, the statement is made that " South Texas Project QA management does not fully recognize the requirement for QA/QC organizational freedom." As indicated in the cover letter transmitting our Reply to the Notice of Violation, management is sharply aware of the need for such l

Houston Lefting & Power Company

1. -Nuclear R gulatory Commission May 23, 1980 Page i freedom and major steps have already been taken to assure this freedom and independence. The lecture referred to in the para-i graph has been disavowed by B&R management. New lectures and seminars as well as written materials will emphasize the import-l ance and status of the QA/QC function. (See also response to item 1 in the Reply to the Notice of Violation).

We'believe that all other aspects of Section III are restatements of pertinent sections of the Notice of Violation 1 which are fully answered in our Reply of this date. We note, however, that the matter of whether " serious questions" exist with backfill compaction (last paragraph, p. 10) must await completion and. disposition of relevant studies mandated in Section V of the Order to Show Cause.

I In accordance with the provisions of Section V of the Order to Show Cause, we will submit to the NRC within 90 days from the date of the Order the information requested in items

A (1) -

(10). In addition, HL&P and Brown & Root representatives will participate with the NRC in a public meeting as described in Section V B. of the Order.

Very truly yours, HOUSTON LIGHTING & POWER COMPANY 0/ ,- *

/, ef ., 3

{ [By eorgf W. Oprph, gr/

Executive Vice Pr(sident cc: Attached Certificate of Service

. - - . . _ . . . . _ . . - _ _ _ . . _ . . _ - . _ _ _ _ _ _ _ . _ . _ . . _ _ . ~ . . . _ _ _

~

r 4

Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Mrs. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 Steven A. Sinkin, Esq.

116 Villita San Antonio, Texas 78205 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Chase R. Stephens Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 4

/f L /'; *j '(L/I

< -r _ s t. s-)

Melbert D.'Schwarz Dated: May 23, 1980

- _ - --, -- - w .,,, . . . , - - . , - - - - - -

e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF S S

HOUSTON LIGHTING & POWER S DOCKET NOS. STN-498 OL COMPANY, ET AL. S STN-499 OL S

(South Texas Project S Units 1 and 2) S CERTIFICATE OF SERVICE I hereby certify that copies of Applicant Houston Lighting

& Power Company's Answer to Order to Show Cause in the above-cpationed proceeding, were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this 23rd day of May, 1980:

Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20355 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Henry J. McGurren, Esq.

Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard W. Lowerre, Esq.

Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station Austin, Texas 78711

STATE OF TEXAS S S

COUNTY OF HARRIS S GEORGE W. OPREA, JR., being first duly sworn, deposes and says: That he is Executive Vice President of HOUST0N LIGHTING i & POWER COMPANY, an Applicant herein; that the foregoing answer to Order to Show Cause dated April 30, 1980 has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said

, answer and the facts contained therein are true and correct.

. DATED: This 42&f dday of %o / / , 1980.

Signed h 'u.w e

) f, ,

]( u g rgef . Opre g Jr Subscribed and sworn to before me thisg h ' day of #h j ,

1980.

A U Yr Notary Public in and for the Llfa )6 County of Harris, State of Texas My commission expires:

! )-/4-f(/

I e

i

n eq y Houston r

si company I

} B&Uk Town RO Box PD) a -l- 1 Houston. Texas 77001 May 23, 1980 Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Victor Stello, Jr.

Director Office of Inspection and Enforcement Re: Docket Nos. 50-498 50-499 Gentlemen:

This is in response to Appendix A (Notice of Violation) to your letter of April 30, 1980, transmitting your Investigation Report '(50-498/79-19; 50-499/79-19) covering the results of your inspection of the South Texas Project (STP) in the period November 10, 1979 - February 7, 1980.

Attached is a reply to each item of noncompliance addressed in the sequence specified in the Notice of Violation (keyed to the relevant Nuclear Regulatory Commission (NRC) track-ing number) and providing with respect to each item an explana-tion in..the form specified at page 19 of the Notice of Violation.

Each response is preceded by a Summary which provides a brief description of the item, as perceived by the NRC, based on our review of the Investigation Report and Notice of Violation.

In some instances our review identified differences between the Notice of Violation and the Investigation Report; in other cases, the Report provided valuable amplification of the Notice of Violation. In preparing the attached reply an effort was made to address the Notice in the context of the underlying Report.

In some instances, it has proven impossible to affirm or deny statements of fact in the Report because of the absence of information which would identify persons, places and dates involved in certain items of noncompliance. This was especially true in connection with matters arising out of the alleged instances of harassment, intimidation and lack of support of

~

u wfoi& ?t g,L/>il,2si-

//p < r

Houston Lghting & Pbur Company

' Nuclocr Rngulatory Commission May 23, 1980 Page quality control inspectors by quality control management.

Nevertheless, our review indicates that such instances probably did occur. .As indicated in the reply to Item 1 (79-19-08),

important steps have been taken in recent months to assure that QA/QC. personnel have the requisite freedom and authority to identify problems and determine that they are adequately re-solved, free.from production pressures. Our inquiries of site personnel suggest that this concern has been brought under control. We plan further steps to reinforce our commitment to ,

an independent quality organization with clear authority backed by management. Although we share the NRC's view that these problems did not create major deficiencies in construction already completed, we recognize that vigilance is required to assure that the underlying conditions (e.g., production pres-sures, insufficient QA/QC visibility) are not permitted to 4

recur.

As to the remaining 21 instances of noncompliance, our review confirms, with minor exceptions, I&E's specific i findings as set forth in the Notice of Violation. Pursuant j to the Order to Show cause,Section V, paragraph (3) , a review

, is being made of safety-related welding and concrete structures to determine if such work was properly performed.

s' Our reply describes the corrective actions taken or to be taken with respect to each item of noncompliance but, in our review, we have tried to focus on the underlying or " root causes." As a consequence of that review, we have identified several areas where performance can and will be improved:

1. Translating specifications and requirements into

]

clear and simplified procedures down to the job level..

i , 2. Improvement of systems for documenting non-conforming conditions and systematic trend analyses to identify programmatic weaknesses.

3. Upgraded training and indoctrination of personnel at all levels in quality-related tasks with special emphasis on the project goals of reliability and safety.

4. Stronger system controls, reflected in procedures which assure that quality-related activities are initiated, controlled and properly documented.

4 6

Houston Lipiting & Pour Company Nuclcar R gulatory Commicsion May 23, 1980 Page 5. Improvement of the system of audits to verify adherence to procedures and identify deficiencies for resolution at the appropriate level of management.

6. Increased visibility of, and active participation by, upper management in QA/QC activities.

Our review to date indicates that each instance of non-compliance is traceable to one or more deficiencies in the foregoing areas. This is reflected in the discussion of causes and corrective actions on each item in the attached reply. It will be our objective to attack these " root causes" over the next several months. In part, our progress will be reflected in the response to the Order to Show Cause, but we intend to advise the Office of Inspection and Enforcement in the interim as corrective steps are developed and implemented.

We recognize that these goals will be attained only with dynamic and aggressive leadership, exercised with consistency over the long term. Upper management has the responsibility to assure that quality functions have a high degree.of visibility to enhance quality awareness throughout the project. We will address this matter in greater depth in our response to Section V of the Order to Show Cause and otherwise keep you advised.

3 Very truly yours, HOUSTON LIGHTING & POWER COMPANY

,A

.; ,l./l , .

N ,y.*b:us./ />,2 George /W.' Opreg Jrg'

' Q xecutive Vice President cc: Attached Certificate of Service

STATE OF TEXAS S S

COUNTY OF HARRIS S GEORGE W. OPREA, JR., being first duly sworn deposes and says: That he is Executive Vice President if HOUSTON LIGHTING

& POWER COMPANY, an Applicant herein; that the foregoing reply to the Notice of Violation dated April 30, 1980 including the attachment hereto has been prepared under his supervision and direction; that he knows the contents thereof; and that to the -

best of his knowledge and belief said reply and the facts contained therein are true and ccrrect.

DATED: This efM/') day of M O /f_ '

, 1980.

f) }

Signe : nw,/f , _., , M f

G 'rge/W.OpreafJr'.'

Subscribed and sworn tq before me this Iday of NICO i ,

1980

{

q olw 7)toash Notary Public in and for the County of Harris, State of Texas My commission expires:

l~f~e G

t e

,m m - -

- g, e v - --- nn - - - -,-. g--m--.-----.---

O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

- IN THE MATTER OF S S

HOUSTON LIGHTING & POWER S DOCKET NOS. STN-498 OL COMPANY, ET AL. S STN-499 OL S

(South Texas Project $

Units 1 and 2) S CERTIFICATE OF SERVICE I hereby certify that copies of Applicant Houston Lighting

& Power Company's Reply to Notice of Violation in the above- >

cpationed proceeding, were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this 23rd day of May, 1980:

) Charles Bechhoefer, Esq., Chairman Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road -

Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Henry J. McGurren, Esq.

Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard W. Lowerre, Esq.

Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station i

Austin, Texas 78711 4

y - - - - ,y , ~, . - - c -

,m ,.__.r--r-r-- -- - v m c -

• r-.-=w--- - ' --- ~-- - - -e -

e Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Mrs. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 Steven A. Sinkin, Esq.

116 Villita San. Antonio, Texas 78205 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety and Licensing Appeal '

Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Chase R. Stephens Docketing and Service Section Office of the Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 7 ,o k/[ !; % C .'w m.9 s Melbert D. Schwarf /

Dated: May 23, 1980 I

l

79-19-08 ATTACHMENT to letter of May 23, 1980 Responses to items of noncompliance ITEM A-1 Lack of QA/QC freedom, independence and sufficient well defined authority A. Summary This item, relying basically on the statements of unidentified individuals, describes incidents of intimi-dation and harassment of Quality Assurance / Quality Control (QA/QC) personnel which impaired their independence and authority to identify problems and ensure that they were satisfactorily resolved.

B. Reply (1) Affirmation or Denial It is not possible to affirm or deny statements of fact in the absence of information which would identify persons, placeg and dates involved. However, our own review suggests that such instances probably did occur.

(2) Reason for item of noncompliance The problems arose out of perceived production pressures and perceived lack of support of QA/QC personnel by quality management. Beyond these specific factors, the QA program was not given enough " visibility" and status by management, and training / indoctrination failed to place 1

79-19-08 enough emphasis on quality awareness and understanding of the purpose and intent of the QA program.

(3) Corrective actions to date and results achieved A number of actions have been taken by Brown &

Root, Inc. (B&R) and Houston Lighting & Power Company (HL&P) that are directed toward ensuring that the intent of the QA program is properly understood and implemented by project personnel. These activities are directed specifically at removing production pressures, providing positive support by management, and eliminating harassment, intimidation, and threats to inspection personnel.

(a) In January, 1980, B&R conducted a management assessment of the causes of the perception of harassment, or undue pressure on site QC personnel. Extensive interviews of construction and QA/QC personnel were conducted, and an outside consultant (Greg Howell, President of Timlapse, Inc.) was employed to survey attitudes among QA/QC and constructiti personnel. This assessment documented sources of friction on the site. HL&P has also increased its involve-ment in the QA/QC program in order to assist B&R in ensuring that the program is carried out in an effective manner.

Particular attention is being directed to uncovering sources of harassment or intimidation of QA/QC personnel at the job 79-19-08 site. HL&P Site Surveillance is researching selected allega-tions of intimidation and harassment to determine their validity and causes. The effects, if any, on the quality of plant construction are being analyzed where instances are identified. HL&P audit BR-32 also included interviews with selected B&R QA/QC and construction personnel directed toward identifying any real or perceived sources of intimida-tion or harassment.

(b) A complete reevaluation of the B&R salary administration program for QA/QC personnel was conducted during January-February, 1980, and a revised QC calary administration program was implemented on March 30, 1980.

Care was taken to ensure fair and equitable compensation for QA/QC personnel. The new salary structure should assist the QC organization in attracting additional qualified personnel to the site and help reduce personnel attrition by providing incentives.

(c) The B&R project QA/QC organization was re-evaluated during January-February, 1980, and in March, 1980, revisions to the organization were implemented including an upgraded reclassification of QC supervisory personnel to provide equal stature with their construction counterparts.

79-19-08 (d) B&R project management has issued a procedure, STP-PGM-02, " Procedure for Resolving Disputes Between Con-struction and QA/QC Personnel," rev. O, January 7, 1980, which clearly defines a step by step process whereby any differences of opinion between construction and QC personnel are resolved through the use of successive levels of super-vision in order to eliminate confrontations which could result in harassment and intimidation. The procedure has been discussed in indcctrination sessions for construction supervision and QA/QC personnel. On April 9, 1980, HL&P Site Surveillance issued a memorandum to selected HL&P and B&R personnel requesting that HL&P be promptly notified of any instances of harassment or intimidation of QC personnel.

(e) On March 27, 1980, the B&R project general manager issued a statement reiterating the mandate that project procedures, specifications and drawings be rigorously followed.

(f) In January, 1980, B&R QA management began visiting the South Texas Project (STP) site on a frequent basis for closer contact with site QA/QC personnel and to provide opportunities for employees to voice concerns and make suggestions to improve performance. On February 15-16 and February 22-23, 1980, a formal training seminar on employee motivation, human relations, and supervisory skills

79-19-08

)

was held for construction and QA/QC supervision. This program was conducted by professors in organizational behavior management from the University of Houston.

(g) During March, a meeting was held for B&R QA/QC personnel in which B&R power group management and QA department management discussed the B&R open-door policy for all employees which provides access to top corporate manage-ment for any employee to express concerns as to any aspect of the STP operation or his personal treatment as an employee.

Dedication to achieving quality objectives was emphasized.

(h) In January, 1980, the position of B&R assistant QA department manager was abolished, thereby shortening the communication chain between site QC personnel and top QA management to facilitate communication and resolution of problems.

(i) In January and February, 1980, two B&R con-struction supervisory personnel against whom allegations of intimidation and harassment had been made were removed from the project.

(j) In March, 1980, B&R project and QA management met with QA/QC supervision to emphasize the role of QC supervision and the importance of support of inspectors' decisions and assistance to inspectors in the resolution of

79-19-08 problems. As a means of observing QC support in day-to-day activities, HL&P Site Surveillance personnel have attended essentially all concrete placement meetings as well as concrete placements since early January of 1980. Surveillance personnel were requested to pay special attention to incidents of intimidation or harassment and to submit to the HL&P Site QA Supervisor written reports on observations.

(k) In March, 1980, "QA Bulletins" were insti-tuted throughout the QA/QC department, including all site B&R QA/QC personnel, to provide better understanding of overall activities, capabilities and support within the department. The objective was to improve individual under-standing of the interdependence of personnel in all project quality related activities.

(1) A program of regular refresher training of B&R construction and QA/QC personnel in project procedures has been instituted to ensure better understanding of procedures governing their work. The construction procedure delineating refresher training requirements will be complete by June 13, 1980.

(m) An extensive recruiting program has been instituted to increase the staff for the QC function (both inspectors and support personnel) to provide increased manpower for inspections, improve technical support and reduce production pressures.

79-19-08 (n) On May 8-9, 1980, B&R QA management conducted meetings with site QC supervisors to review NRC Report Number 79-19. B&R QA management will continue to provide additional perspective on problems, the need for better communications and proper support of inspection personnel.

(o) A complete review of B&R QA/QC personnel qualifications and recertification of those personnel, where necessary, was completed during January-April, 1980, to eliminate any doubt as to whether QA/QC personnel are properly qualified. In addition the certification requirements were made more rigorous.

(p) Extra radios have been provided to HL&P Site Surveillance personnel to enable monitoring of B&R radio traffic. These radios increase communication between HL&P and B&R construction and QA/QC personnel and have helped HL&P to evaluate the rapport between B&R construction and QA/QC personnel. Further, B&R QA/QC personnel have been provided additional radios.

(q) HL&P Site Surveillance personnel have been instructed to spend more time in the field. HL&P Site Surveillance personnel have also been provided specially marked "high visibility" hard hats. This action is aimed at increasing HL&P QA visibility in the field and lessens the probability of harassment or intimidation.

. ._ _. _ , _ _ =_ . . _ . . __ . _ _

79-19-08 (r) In May, 1980, a supervisory skills course was initiated for first-line QA/QC supervision. A course was obtained from Practical Management Associates and encompasses necessary supervisory skills, and diagnosis of causes of personnel problems.

All of the above activities have been targeted at assuring the proper implementation of the QA/QC program and to remove pressures, harassment, intimidation or threats which can interfere witn inspection activities. Many of these efforts are specifically designed to ensure complete support of inspection personnel by QA/QC supervision and management. Feedback has been solicited from inspection personnel with regard to the results of these efforts.

Reports and comments received to date have been generally favorable.

(4) Corrective steps which will be taken to avoid further items of noncompliance (a) The B&R Quality Engineering function at the site will be significantly strengthened to provide additional technical support for inspection personnel. An outside consultant will be retained to assist in the organization, development and implementation of these activities.

(b) The number of design engineering personnel at the project site will be significantly increased. This 79-19-08 should provide improved communication of the interpretation of engineering requirements.

(c) Further steps to assure "high visibility" for the QA/QC function via more direct involvement at the highest levels of management are being studied and will be reported in the response to Section V of the Order to Show Cause.

(5) The date when full compliance will be achieved Based on the activities listed under (3), above, we believe that any perceived pressures, intimidation, harassment, or lack of support have been substantially reduced. We do not believe that such difficulties today impair the implementation of the QA program. Efforts will continue throughout the duration of the Project to ensure that the program is properly implemented. These activities will be reinforced by training and indoctrination and active participation by management in quality activities throughout the course of the project. Certain of these continuing activities will be addressed in response to Section V of the order to Show cause.

79-19-18 W

ITEM A-2 Failure to complete backfill compaction in accordance with a qualified procedure A. Summary A " test fill program" conducted by B&R indicated that 12 passes with compaction equipment would be required for placement of an 18 inch maximum lift thickness of soil. The construction procedure required only 8 passes.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

Engineering specifications require that all essential ele-ments of the backfill construction procedure be identified, including lift thickness and consolidation equipment compaction passes. There is no clearly identified and documented basis for the number of passes specified in the construction procedure for 18 inch lifts.

(2) Reason for item of noncompliance Based on consultant recommendations, the engineer-ing specification specified formal test fill requirements only for 24 inch lifts and not for 18 inch lifts. Procedural requirements for 18 inch lifts were based on successful results of the in-place density tests. Having achieved

= _-- . _ . - . .__ --- ._. .- - - .

79-19-18 i

acceptable results from the in-place tests, construction

) specified that a minimum of eight passes would be required prior to testing for all lifts except for the surface lift where 12 passes K-7uld be required. It should be noted that as a result of the test fill program for 18 inch nominal lifts the necessary density was attained with 8 to 10 passes for 8-14 inch depths and after only 4 passes for 18-24 inches depth. However, the test conditions were not well documented.

(3) Corrective action to date and results achieved A test fill program is being conducted to verify i

the method and criteria in the construction procedure. The history and logic of the development of the original and subsequent revisions to the procedures will be documented in response to the Order to Show Cause (Section V A, item

, (2)(a)). The test results obtained for the qualification of the procedures during the initial backfill placement will be retrieved insofar as possible to further substantiate the acceptability of the construction procedure. Any possible effects of the construction procedures on the adequacy of the existing backfill will be evaluated as a part of the response to the Order to show Cause (Section V A, items 2(c) and 2(d)).

4 i

79-19-18 (4) Corrective action which will be taken to avoid further items of noncompliance Although backfill placements are now substantially complete, the engineering specification will be revised to require documentation to support any change in construction procedures. This will be accomplished by June 6, 1980. The case in question, however, raises the matter of the need for care in the development of procedures to implement job specifications. This generic question will be reviewed thoroughly and progress will be reported in the response to the Order to Shos Cause.

(5) Date when full compliance will be achieved Resolution of this item of noncompliance will be final upon completion of studies mandated by Section V A, item 2 of the Order to Show Cause.

l 1

79-19-22 ITEM A-3 Failure to take prompt corrective action when test apparatus failed, halting testing A. Summary Notwithstanding that test apparatus for measuring relative density of soils was known to be out of commission, plant backfill continued to be placed and several sets of four sand cone density tests were completed without the requisite relative density test being performed.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance Both B&R personnel and Pittsburg Testing Laboratory (PTL) personnel were aware that the vibratory- head for measuring density was out of operation but failed to document this fact on a Nonconformance Report (NCR). Efforts were underway to obtain a replacement vibratory head. In the interim, it was decided that the ultimate objective of the test could be satisfied by taking samples and placing them in the laboratory for later analysis, as supplemented by a comparative review of results of other ongoing tests. Care was taken to identify the area from which each sample was taken. This does not, however, excuse the violation.

79-19-22 l

(3) Corrective action to date and results achieved A back-up vibratory head for measuring relative density was purchased. Where deemed necessary other PTL back-up equipment has been ordered. The more fondamental problem illustrated by this item is the failure to (a) promptly document the condition on an NCR and (b) halt 4

production activities pending the satisfactory dispositon of the NCR. Instructions (SQA-3329 dated February 1, 1980) have been issued clarifying and strengthening the requirement to promptly document nonconforming conditions. B&R and PTL personnel have been advised as to the absolute necessity for complying with project QA/QC requirements.

(4) Corrective steps which will be taken to avoid further items of noncompliance We will examine the need for additional indoctrination of site subcontractor personnel performing activities affecting quality.

(5) Date when full compliance will be achieved The steps in (3) above have already been completed.

Training and indoctrination will be a continuing activity, the details of which will be available to the NRC.

1 e

- . , - - - , p. , y.. r_- - , , , , , , - - .

79-19-21 ITEM A-4 Failure to establish procedures for systematic sampling as part of soil testing program A. Summary Testing procedures employed by a subcontractor, Pittsburg Testing Laboratory (PTL) provided no instruction as to the depths below the backfill lift surface and location where tests should be performed. Accordingly, there was no systematic means of determining test depths and location.

B. Reply (1) Affirmation or Denial The item of noncompliance as reflected in the summary is substantiated.

(2) Reason for item of noncompliance The PTL procedure left the selection of the depth of, and location for, backfill tests to the judgment of an inspector rather than providing quantitative inspection criteria for depth and location.

(3) Corrective actions to date and results achieved The structural backfill specification has been revised (3YO69YS029-F/DCN/2-14-80) to specifically identify criteria for testing depths. The Earthwork Inspection and Testing Specification has been revised (2YO60SS033-C/DCN/2-14-80) to explicitly state the need for considering possible variations i

79-19-21 in density with depth. These change notices formalize the judgments that previously were made by the inspectors.

PTL's procedures were revised on February 19, 1980 to include the specification criteria for testing depth accompanied by necessary additional implementation instructions.

(4) Corrective steps which will be taken to avoid further items of noncompliance The specifications and procedures will be revised to require that sample locations shall be determined by a random numbering system, based on plant grid coordinates.

This action and the steps already taken and described above will solve the immediate problem. The underlying problem, however, is the adequacy of specifications and procedures to provide quantitative inspection criteria. The underlying problem will be reviewed thoroughly and progress of this review will be made available to the NRC.

(5) Date when full compliance will be achieved Insofar as the identification of test depths for future backfill testing programs is reflected in revised specifications and procedures, compliance has already been achieved. Insofar as identification of test locations for future backfill testing, these will be reflected in revised procedures. Compliance will be achieved on June 20, 1980.

However, the adequacy of past activities will not be fully assessed until completion of the studies being made in response to item 2 of Section V A of the Order to Show cause.

79-19-24 ITEM A-5 Failure to document soil lift thickness and number of passes of equipment as part of QA records A. Summary The PTL procedures failed to require documentation that B&R construction procedures (which specify minimum roller passes and actual lift thickness) have been met.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance The inspection procedures as implemented by PTL only required inspection to assure that the criteria of the Structural Backfill Construction Procedure had been satisfied.

There were no explicit instructions to document the exact number of roller passes.

The actual lift thickness should have been documented in inches (Item 9 of SF-1); however, the inspectors, due to the lack of specific instructions, noted the maximum allow-able thickness, and by checking " acceptable" indicated that the thickness was equal to or less than the limiting criteria.

(3) Corrective action to date and results B&R engineering specification requires the inspector to observe the number of compaction passes and lift thickness.

79-19-24 Although PTL had the inspection responsibility and its procedures only referred to the foregoing specifications, the PTL procedures failed to identify documentation require-ments in sufficient detail. -The.PTL and the'B&R procedure will be revised by June 20,.1980 to reflect the applicable requirements of the specification.

(4) Corrective steps which will be taken to avoid further items of noncompliance The fundamental _ problem associated with this item of noncompliance is the failure to completely implement specifications and procedures in job instructions and inspection requirements. B&R and PTL's procedures will be revised to provide implementation instructions to the inspectors. A comprehensive review to assure that specifications are 1 translated into clear procedures for the crafts, and inspection plans for QC personnel, is underway and will be an on-going effort.

(5) Date when full compliance will be achieved Compliance will be achieved by June 20, 1980. A full evaluation of any problem associated with the deficiency and allied items of noncompliance will be reported in response to items 2c and 2d of Section V A of the Order to Show Cause.

18-

,m,a r - - - - - - - - - - , --,,.,-----,-r n -, .,-.- , n.-.-.,, , - - - -_ . ,, , - . , , ., . - , . , - - --

---r--n,--,

79-19-47 ITEM A-6 Nonconformance Reports, Examination Checks / Inspection Books, and Field Requests for Engineering Action -

Trend Analysis A. Summary The NRC Report states that no effective program has been implemented for the review and analysis of NCR's, Examination Checks / Inspection Books, or Field Requests for Engineering Action (FREA's) on a continuing basis. The concern is that " root causes" will not be identified and corrective action taken to prevent repetition of the deficiencies or nonconformances. In addition, no formal, approved procedures to implement such a program had been developed as of November 28, 1979.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated. The noncompliance item points out deficiencies associated with the recurrence control program resulting from the absence of a formal program to detect discrepancy trends.

(2) Reasons for item of noncompliance Quality Assurance Procedure ST-QAP-2.12, 3rrective Action", is the governing document on the project for recurrence control. As stated in the Scope section of this document,

79-19-47 "This procedure covers the methods for preventing recurrence of a nonconformity, failure, or incident by determining the cause of the adverse condition and initiating necessary corrective action."

Since mid-1978, 17 Corrective Action Requests have been issued under ST-QAP-2.12 regarding recurrence control.

However, only limited analyses of nonconformance trends were performed from May 1, 1978 through September 1, 1979.

Six trend analysis reports were issued during this period, none of which identified any significant trends. In September, 1979, the supervisor responsible for trend analyses was transferred to another job, and the nonconformance trend analysis position was not filled until December, 1979.

Trend analysis reports issued after September, 1979, were limited to reporting the net change in the NCR status for the reporting period.

The inadequacy of the trend analysis program can be attributed to lack of clear direction, procedures and criteria. A contributing factor was the absence of a central project authority assigned responsibility for this work.

(3) Corrective actions to date and results achieved Three documents have been or will be developed which delegate authority for the proper handling of NCR's and FREA's for performing trend analyses, and for reviewing the results of the analyses. These documents are:

79-19-47 (a) STP-PGM-07, " Procedure for Trending and Reporting of FREA's, NCR's, and SDR's (Supplier Deviation Requests)." This was approved and issued for use on May 5, 1980.

(b) Procedure ST-QAP-15.4, "Nonconformance Trend Analyses" will be issued by July 14, 1980.

(c) A040GQ004-b, " Engineering Requirements for the Tracking and Trending of FREA's, NCR's, and SDR's." This was approved and issued for use on April 16, 1980.

The first trending report under the new procedures

. was issued April 15, 1980. This report considered all NCR's and FREA's issued to March 31, 1980. SDRis were not included in the first report, but they will be addressed in the second report. The trend analysis report will be issued quarterly.

(4) Corrective steps which will be taken to avoid further items of noncompliance Review of the first trending report discussed above was inconclusive and thus does not provide a basis for evaluating the usefulness of the revised program. The large amount of data analyzed complicated the evaluation. Also, review of the data indicated that further effort is required to develop additional criteria for trend analyses. Further

79-19-47 effort is also required to bring into the program a capability for analyzing additional project documents and reports that identify problems.

In order to identify areas of the nonconformance trend analysis program that need improvement, B&R will conduct a basic reexamination of the entire program. The following items will be evaluated during this review:

a. Creation of a centralized trend analysis section that would be responsible for all project trend analyses and issuance of cor-rective action requests resulting from the analyses.

b. Establishing uniform codes for nonconformance problems independent of the type of document being analyzed.

c. Establishing a definitive list of documents that require trend analysis (including Examina-tion Checklists and Inspection Books).

d. Establishing and implementing procedurally the criteria for identifying a significant nonconformance trend.

e. Establishing responsibility (ies) for analyzing and correcting root causes identified by the trend analysis program.

79-19-47

f. Establishing criteria and responsibility for identifying problems that may be identified only in Examination Checks / Inspection Books.

g. Training of personnel in the importance of and the proper use of effective nonconformance programs.

(5) The date when full compliance will be achieved

'All corrective actions involved in this noncompliance will be further addressed in respons~e to Section V of the Order to Show cause.

e

79-19-10 ITEM A-7 Concrete Placement Activities A. Summary Concrete placement activities problems previously identified had not been corrected in accordance with prior commitments.

These continuing problems involved proper consolidation practices, poor lighting, lack of adequate numbers of inspection personnel, production pressures and excessive lift thicknesses. These are matters previously identified as placement problems and, contrary to prior commitments, corrective action has not been incorporated into concrete placement procedures.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for the item of noncompliance Analysis of this noncompliance shows that the problems identified above are a result of insufficient training, unsatis-factory procedures and production pressures.

(3) Corrective action to date and results achieved The following corrective actions have been taken:

a. Production Pressure - Additional QC inspectors have been added to the Quality control Staff to assure that

79-19-10 preplacement inspections are conducted in a thorough manner.

Procedures have been revised to require the completion of preplacement inspection and sign off of the pour card by the B&R QC inspector prior to the delivery of concrete to the construction area. Other measures described in the response to Item 1, above, have been taken to eliminate the production pressures which might be perceived by the QC staff.

b. Inadequate lighting - Construction procedure CCP-4 has been revised to add placement lighting to the preplacement/ placement checklist. This requirement is applicable to all safety-related pours.

c. Reinspection - Revisions to Site Procedures A040KPCCP-3, 4, 8, 12, 19 have been made which instruct the inspector that after he has inspected and accepted an item, if additional activity should occur in that area that would make quality of that item indeterminate or unacceptable, he shall reinspect that item and document his results on the applicable examination check.

d. Supervision - Placement foremen, field engineers and QC inspectors have been reinstructed on their obligation to identify any improper consolidation practices and to ensure that the placement receives proper consolidation.

79-19-10

e. Training - Procedure CCP-4 revised March 7, 1980, requires consolidation training every 90 days for consolidation placement craft. The most recent class was held April 18, 1980. These training classes emphasize consolidation procedures and ACI recommended practices.

f. Placement meetings - Construction procedure CCP-4 has been revised to require formal preplacement and postplace-ment meetings. The required agenda for preplacement meeting includes review and discussion of the specific placement method to be undertaken and the sequence of activities.

The prescribed agenda for postplacement meetings includes discussion of all deviations from the placement as planned, including delays and required changes in the sequence of activities.

g. Procedures - Procedures are being rewritten in a new format with the involvement of the craft supervisors.

These rewritten procedures will contain all relevant informa-tion from specifications, technical reference documents, codes, standards and regulatory documents. They are being written in such a way that they can be easily understood by 4

79-19-10 craft personnel. Technical terms are being replaced, a

whenever possible, by simpler terms or phrases.

(4) Corrective steps which will be taken to avoid further items of noncompliance As noted above, a number of significant corrective actions have already been initiated. Thcse efforts will continue throughout the duration of construction. Procedure CCP-4 will be revised by June 2, 1980, to reflect the requirement to discuss adherence to the specified lift thickness during each preplacement meeting. As improved methods of placing concrete are identified, they will be evaluated for incorporation into project construction procedures and training manuals.

(5) Date when full compliance will be achieved Actions a. through f. in Section (3) above have already been accomplished. Action g. Wil] be completed by July 21, 1980. The actions discussed in Section (4) will be an on-going project activity, i

y --: ,-- - < y 3+s,. ---3  % -. ,.p ,_.+ -- --,.,,_m.. -

,-,--_---..r .-- ,,_..a - --- - - - - - -.--a---

79-19-16 ITEM A-8 Failure to follow procedures with regard to qualification of civil and concrete QC inspectors A. Summary

, The qualifications of 14 B&R civil inspectors and six PTL concrete inspectors were checked against requirements in the B&R Quality Assurance Training Manual and the PTL Quality Control Procedure QC-PQ-2. The check revealed five B&R inspectors and three PTL inspectors did not have sufficient QA/QC experience at the time of their certification.

B. Reply (1) Affirmation or Denial The items of noncompliance have been substantiated as follows:

A total of 14 discrepancies were identified relative to the certification of B&R inspection personnel. They are summarized as follows:

A. Civil Discipline (ASME Section III Division 2 Appendix VII:

a. Two personnel did not satisfy the educa-tion requirements.

b. Two personnel did not satisfy the minimum experience requirements.

)

79-19-16

c. One of the inspectors who required a greater degree of experience possessed an unrelated college degree.

B. Nondestructive Examination Discipline (SNT-TC-1A):

No discrepancies.

C. All other Disciplines (ANSI N45.2.6):

a. Five personnel did not satisfy the education requirements (i.e., verified high school education); and

b. Four personnel did not satisfy the minimum experience requirements. Two of these also failed to satisfy educational requirements.

A total of ten discrepancies were identified relative to the certification of PTL testing personnel.

They are summarized as follows:

a. Five individuals were found to not be high school graduates at the time they were employed or transferred to STP for work assignments; however, they have at this time completed the required educational training through General Educational Development equivalence testing.

79-19-16

b. The necessary applicable prior experience background of three individuals could not be verified in writing; however, these individuals have now completed sufficient time and experience at STP to qualify for the level at which they were hired.

c. Two individuals were found to have insufficient appropriate prior experience background but now have such experience as a result of their time and work experience at STP.

(2) Reason for item of noncompliance B&R did not to provide detailed procedures requiring documentation for verification of previous employment and education.

(3) Corrective action to date and results achieved The education and experience of present B&R and PTL QC inspectors have been verified, and personnel have been provided additional training and recertified accordingly.

(4) Corrective action to be taken to avoid further items of noncompliance Effective April 1, 1980, the education and experi-ence of all B&R and PTL candidate inspectors are required to be verified prior to certification.

79-19-16 1

(5) Date when full compliance will be achieved B&R employment practices have been revised to reflect the requirement to verify previous education and work experience for STP QA/QC personnel. We are reviewing the need for verification of education and previous work experience for site subcontractor inspection personnel.

This review will be completed by July 7, 1980.

b e

i

- - . . - - , r .._ , , _ , _ . ,, _.. -

79-19-33 ITEM A-9 Failure to control documents in that contractor's QA Manual copies are out of date A. Summary HL&P copies of the B&R's Quality Assurance Manual i did not include. interim changes, and B&R Weld Filler Material Specification, 1UO20WS001-E, did not contain the latest Document Change Notices (DCN's).

B.- Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of. noncompliance The B&R QA " interim changes" procedure made tracking of latest revisions to documents difficult. Additionally, the library file clerk failed to incorporate revisions into the weld filler specification.

(3) Corrective actions to date and results achieved The following corrective steps have been, or are being, taken.

(a) All controlled documents on file in the HL&P office have been revised by the HL&P QA file clerk and brought up-to-date as necessary.

79-19-33 (b) A secondary review is being be made by the HL&P QA site Quality Engineering staff to ensure that the documents are up to date. This review will be complete by June 2, 1980.

4 (c) To avoid further items of noncompliance an Administrative Technician has been added to the site HL&P QA staff to be responsible for document control in the HL&P,QA library.

(4) Corrective steps which will be taken to avoid further items of noncompliance The corrective actions described above should reduce the probability of recurrence. The more fundamental issue, however, is quality-related document control. The document control system, including interim changes, will be evaluated to determine what necessary changes must be made

to th e exi st i ng document control system.

I (5) Date when full compliance will be achieved I The corrective actions outlined in (3) above will be completed by June 1, 1980. The corrective action outlined in (4) above will be completed by July 21, 1980, and results will be made available to the NRC.

79-19-34

-ITEM A-10 Failure to control welding as a process with regard to cleanliness A. Summary NRC inspectors observed the performance of welding

. operations in circumstances which did not protect against contamination and adverse atmospheric conditions. Instances are documented at pages 71 and 72 of the Investigation Report.

B. Reply (1) Affirmation or Denial

, The item of noncompliance is substantiated.

(2) Reason for item of noncompliance Procedures failed to incorporate detailed require-ments for protection against adverse environmental conditions.

Training and craft supervision did not sufficiently address i

j the reasons to protect welding operations from such conditions.

(3) Corrective actions to date and results achieved i

Procedures are being revised to include require-ments for protection against deleterious contamination from rain, snow, wind and airborne particles during welding i operations. The reasons for protecting welding operations

'against. adverse environmental conditions were stressed in

)

• i

) ._ . ._ _ _ _ _ . _ _ _ _ _ _ . _ _ _ . _ _ . . _ . . _ - _ _ _ - _ _ _

79-19-34 training activities completed February 15, 1980, and the Training Department will continue to reiterate the importance of the requirement during future training of welders to B&R Material Engineering Construction Procedures. This will be done prior to start up of safety related welding activities.

It has been emphasized that this is a requirement of all on-site welding activities.

(4) Corrective steps which will be taken to avoid '-

further items of noncompliance Welding technicians will monitor field activities with increased emphasis on this matter and report any infractions to the Chief Welding Engineer or QC. The underlying problem will be addressed by assuring that job specifications are translated to meaningful procedures and job instructions.

Adherence to such instructions will be emphasized in training and indoctrination.

(5) Date when full compliance will be achieved Procedures discussed in (3) above will be issued by July 21, 1980. Certain training activities have, as noted above, been completed. Indoctrination and training will be a part of the continuing welding improvement program.

79-19-39 ITEM A-ll.a Failure to control radiography, a special process, leading to poor radiographic quality A. Summary At least 50 radiographs were found to display significant light fogging and chemical contamination to the extent that proper interpretation was not possible.

B. Reply (1) Affirmation or Denial This item of noncompliance is substantiated.

(2) Reason for item of noncompliance Nondestructive examination (NDE) procedures did not define processing techniques or film acceptance criteria.

(3) Corrective actions to date and results achieved All radiographic film hcs been reviewed by the NDE Level III to identify film discrepancies. When deficiencies were found, an NCR was issued which required reexamination of the item. Additionally, a radiographic film processing procedure (NDEP 2.2) has been issued to clarify film pro-cessing techniques.

In January, 1980, all site radiography was suspended except for that conducted under the direct supervision of the NDE Level III. Retraining and recertification of site NDE personnel was completed on February 5, 1980.

79-19-39 (4) Corrective steps which will be taken to avoid further items of noncompliance QA/QC personnel will closely monitor the implementa-tion of the revised NDE program and procedures. Training, including refresher training, will continue to ensure that site NDE personnel remain qualified. Film interpretation will be performed by qualified personnel other than the individual shooting the film.

(5) Cate when full compliance will be achieved All corrective action has been taken and full compliance has been achieved. Monitoring and training activities will be an on-going effort.

e 4

I

1 1

79-19-39 ITEM A-ll.b Interpretation of radiographic film-weld quality A. Summary At least twelve radiographs of field welds and one radiograph for a welder qualification test contained linear indications that had not been recorded on the accompanying interpretation sheet.

B. Reply (1) Affirmation or Denial This item of noncompliance is substantiated.

(2) Reason for item of noncompliance This noncompliance was caused by lack of clarity in existing NDE procedures, acceptance and recording criteria and improper film interpretations.

(3) Corrective actions to date and results achieved In January, 1980, all field radiography by site QA/QC personnel was halted unless it was directly supervised by.the NDE Level III. Concurrently, a review of all previously shot field weld joint radiographic film was conducted by the NDE Level III radiographer. Retraining and certification

was completed for all site NDE personnel on February 5,

1980. Finally, Radiographic Procedure NDEP-2.1 has been i

i s

4

1 l

79-19-39 revised to clarify the requirements for recording film I conditions and indications.

(4) Corrective steps which will be taken to avoid further items of noncompliance All NDE procedures will be reviewed to ensure that they provide clear guidance and correct criteria for the implementation of nondestructive examination. Film inter-pretation will be performed by qualified personnel other than the individual actually shooting the film.

(5) Date when full compliance will be achieved Corrective action described in (4) will be completed by July 14, 1980. Full compliance will be achieved by that date. Continuing efforts, aimed at training of personnel and assuring that procedures convey NDE requirements in a clear manner, will be a continuing Project effort.

9 a

79-19-39 ITEM A-ll.c Failure to control liquid penetrant examinations A. Summary Liquid penetrant examinations were not conducted in accordance with procedures, nor were the results interpreted in accordance with applicable criteria, in that steps were not taken to verify that indications were not defects.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance This item of noncompliance was caused by failure of QA/QC personnel to properly follow procedures and to understand criteria for recording results of liquid penetrant examinations.

(3) Corrective _ actions to date and results achieved This is believed to be an isolated incident; how-ever, in order to address the problem in an orderly manner, all liquid penetrant examinations at the site were suspended by QA unless under the direct supervision of the NDE Level III until corrective measures could be taken. All NDE personnel conducting liquid penetrant inspections have received additional training in inspection techniques, procedures and criteria.

79-19-39 (4) Corrective steps which will be taken to avoid further items of noncompliance Training will continue throughout the construction phase of the Project effort per the documented refresher training program.

(5) Date by which full compliance will be achieved All corrective action was completed by January 31, 1980. Training and indoctrination will be a continuing activity.

79-19-41 j l

1

l ITEM A-12 Failure to follow procedures in that a prvcedure was used after an expiration date A. Summary Procedures governing an NDE activity were modified by an " interim" change which was to expire sixty (60) days from its issuance. The interim change was being used notwith-standing its expiration four (4) months earlier.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance Document control procedures which have proven satisfactory for formal revisions have not been adequate to provide positive control of interim changes.

(3) Corrective actions to date and results achieved A survey of all outstanding QA " interim changes" has been conducted and outdated changes have been removed.

(4) Corrective steps which will be taken to avoid further items of noncompliance Further revisions to the QA document control system will e]iminate references to " interim changes."

4 79-19-41 (5) Date when full compliance will be achieved Changes.to the QA document control system will be completed by July 14, 1980. This should correct matters of the type described in this item of noncompliance.

'l 4

1 k

i l

, . - _ . . . . - _ . . . . . . , -. . . . . ~ - - . - . . . . - . .

79-19-03 ITEM A-13 Failure to take corrective action when cadwelders needed requalification A. Summary Requirements of both the FSAR and the B&R specification required requalification of any cadwelder accumulating two unacceptable production splices within a unit of 15 consecutive splices. Five cadwelders continued production without requalification after accumulating two unacceptable splices.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance The problem developed as a result of unclear specifications and procedures. BER QC personnel felt that paragraph 5.3.3.5 of Specification 2A0lOCS028 should be

~

interpreted to mean that when a cadwelder had two visual rejections within a unit of 15 consecutive shots, the cadwelder would have to be recertified. (This in fact is not the correct interpretation of the design requirements.)

( 79-19-03 (3) Corrective-actions to date and results achieved In order to correct the specific deficiency, B&R Specification 2A010CS028 has been revised. The specifica-tion now provides that when it is identified that a splicer accumulates two unacceptable tensile tests within a unit of 15 consecutive test samples, he shall not be permitted to continue splicing until he has requalified according to paragraph 5.3.3.5 of the specification. When it is identified that a splicer has accumulated two consecutive visual rejections l

l in any one position, his next two production splices for.

that position shall be visually inspected (i.e., preparation and final). This clarification was incorporated into tha l specification.with DCN 11/12/79. The five cadwelders identified on NCR 3115 were allowed to continue work. During the time clarification was being obtained, all cadwelds which were shot by these.caldwelders were final inspected.

(4) _ Corrective steps which will be taken to avoid further items of noncompliance The steps which have already been taken will control the immediate problem. In a larger sense, the violation suggests that there is a need to review procedures to assure that they clearly translate project specifications into understandable procedures. Attention is now being

79 19-03 devoted to this matter and will be a continuing Project effort.

(5) Date when full compliance will be achieved An evaluation will be made of B&R's nonconformance procedure to determine if it adequately addresses whether work is allowed to proceed pending final disposition. This evaluation will be completed by June 16, 1980. Continuing efforts aimed at assuring that procedures reflect and convey in a clear manner project specifications will be an on-going effort.

i 79-19-55 ITEM A-14 Failure to take corrective action in a reasonable time and management did not get the problems resolved A. Summary This item cites examples of long-standing unresolved nonconformance situations identified through the B&R Site Internal Surveillance (SIS) activity. The identified SIS reports were brought to the attention of QA management but were not flagged for action by the B&R Division " Senior Group Vice President" as required by the PSAR.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reasons for item of noncompliance The noncompliance resulted from the failure to translate a PSAR commitment into a B&R procedure. This was an oversight. In practice, the Group Vice President was not usually notified of delinquent responses to SIS or audit findings. Impasses in the resolution of such matters were usually escalated to the QA Manager and/or STP Project QA Manager who, in turn, initiated the action required to resolve an impasse or obtain action on a delinquent item.

r-79-19-S5 (3) Corrective actions to date and results achieved

, SIS report (SIS-12) has been closed, and SIS reports (SIS-18 and SIS-26) will be closed by May 30, 1980.

A new audit procedure replacing STP-QAP-7.1 is now being drafted. In the interim delinquent deficiencies will continue to be escalated to senior'QA Management for resolution.

(4) Corrective steps which will be taken to avoid further items of noncompliance The new audit procedure discussed in (3) will have a section entitled " Failure to Respond" providing that if an acceptable response to an identified deficiency is not received within 30 days, a letter shall be prepared, with copies to senior QA Management and Group Vice President. In addition, the revised procedure will require notification of management via a tabulation of delinquent Audit Deficiency Reports.

As noted above, the item illustrates an instance of failure to reflect project requirements (in this case, the PSAR) into workable procedures. This underlying or root cause will be addressed as an on-going effort, progress of which will be available to the NRC.

(5) Date when full compliance will be achieved

ne new audit procedure discussed above will be in place by July 14, 1980.

79-19-53 ITEM A-15 Failure to follow procedures to documerit and correct unsatisfactory surveillance conditions A. Summary Surveillances by HL&P of civil activities produced instances in which unsatisfactory conditions were not docu-mented by HL&P personnel. A practice developed where unsatis-factory conditions were not documented if HL&P knew that B&R had initiated corrective action.

B. Reply (1) Affirmation or Denial The circumstances described at pages 102 and 103

of the Investigation Report are substantiated.

(2) Reason for item of noncompliance 4 The item of noncompliance is traceable to inadequate procedure implementation.

(3) Corrective actions to date and results achieved Verbal instructions were given to all HL&P surveillance personnel on January 24, 1980, relative to checklist documenta-  !

tion of all unsatisfactory conditions. Follow-up written instructions were issued on February 1, 1980, clarifying the requirement to document all discrepancies identified during scheduled surveillance.

A

79-19-53 (4) Corrective steps which will be taken to avoid further items of noncompliance PSQP-A3 (Discrepancy Administrative Procedure) will be revised to add criteria instructing surveillance personnel to document all unsatisfactory conditions identi-fied during unscheduled surveillance. Complete implementa-tion of the Site Quality Assurance Procedures will be veri-fied by HL&P QA audits, Future training sessions will call attention to the importance of documenting noncomforming conditions and corrective action for all job-site activities.

(5) Date when full compliance will be achieved All actions associated with scheduled surveillance is complete and full compliance has been achieved. All corrective actions associated with unscheduled surveillance wil2 be complete by June 1, 1980. Continuing efforts to assure that personnel properly implement procedures will continue thoughout the Project.

i l

I I

l

79-19-27 ITEM A-16 Failure to control the use of a nonconforming hammer for penetration A. Summary A weight (" hammer") on a soil penetration test machine used by Woodward-Lundgren (a geotechnical consulting firm) was documented as not conforming to weight specifications; yet soil penetration testing activities were allowed to continue for one week prior to disposition of this nonconforming item.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated. l (2) Reason for item of noncompliance On January 28, 1980, the date of the beginning of the soil penetration test program, the hammer and chains on the test rig was found to weigh 148.9 pounds rather than 140 pounds as required by ASTM D 1586-67, and an NCR was written by Woodward-Lundgren. Work on the testing program continued, without the NCR being dispositioned. The NCR was dispositioned on February 4, 1980.

1 79-19-27 (3) Corrective actions to date and results achieved The NCR was fully dispositioned in accordance with the appropriate procedures. The hammer minu: the chains was reweighed and found to weigh 139.8 pounds. It was determined that use of the hammer was acceptable and would have no material effect on the test program. Further, a subsequent evaluation of the use of this hammer with test data was made and found acceptable. On March 19, 1980, the consultant provided additional indoctrination to its staff to ensure proper implementation of procedures.

(4) Corrective steps which will be taken to avoid further items of noncompliance The consultant's (Woodward-Lundgren) procedures will be reviced to provide additional criteria for resolu-tion of NCR's prior to continuing work. In addition, the consultant, by July 2, 1980, will have established a new QA monitoring function which will review and report on the reso ution of nonconforming items or activities.

(5) Date when full compliance will be achieved All corrective actions including the amendment to this consultant's procedures will be completed by July 2, 1980. We are examining the need for additional indoctrina-tion of site subcontractor personnel performing inspection activities.

79-19-28 l

l ITEM A-17 Failure to control the dimensions of the split spoon in soils test control A. Summary A split spoon used by Woodward-Lundgren (a geotechnical consulting firm) did not conform to the requirements of ASTM D 01586 in that the inside diameter of the cutting edge was measured to be 1.5 inches (rather than 1.375 inches) and the driven end of the split spoon was badly distorted and had a 0.5 inch taper.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance This noncompliance resulted from the failure of the consultant to perform proper inspection of the test equipment prior to the performance or the test. The split spoon barrel and the cutting edge were in fact nonconforming.

(3) Corrective actions to date and results achieved The consultant's NCR has been fully dispositioned.

The engineering evaluation has established that the nonconforming condition of the spoon and cutting edge had no material 79-19-28 effect on the results of the test program, on March 19, 1980, the consultant's staff received additional indoctrina-tion regarding Project QA/QC requirements.

(4) Corrective steps which will be taken to avoid further items of noncompliance Corrective action has been completed.

(5) Date when full compliance will be achieved While the corrective action currently identified has been completed, we are examining the need for additional S

indoctrination of site subcontractor personnel performing activities affecting quality. The conclusions from this examination will be available to the NRC.

79-19-48 79-19-50 ITEM A-18.a Failure to provide for, and conduct, supplemental audits as part of the HL&P QA Plan and audit system A. Summary The HL&P Project QA Plan (PQAP) failed to identify the criteria for performing supplemental audits as required by the PSAR and by ANSI standards. Further, such supplemental audits were not performed.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

Neither the applicable HL&P PQAP procedure, QAP-5, nor the HL&P PQAP described the criteria for the performance of supplemental audits. As a result, neither HL&P nor B&R performed supplemental audits of cite civil activities.

(2) Reason for item of noncompliance The original text of the HL&P PQAP and procedures did not incorporate the PSAR commitment to conduct supple-mental audits. Subsequent revisions of the PQAP and pro-cedures also overlooked the commitment.

79-19-48 79-19-50 (3) Corrective actions to date and results achieved Section 8 of the HL&P PQAP, the HL&P auditing pro-cedure, QAP-5, and the B&R auditing procedure, ST-QAP 18, are being revised to include the commitments of PSAR at Section 17.1.18a to establish qualitative criteria for the evaluation of audit effectiveness and the need for supplemental audits.

(4) Corrective steps which will be taken to avoid further items of noncompliance Section 8 of HL&P PQAP, the HL&P auditing pro-cedure, QAP-5, and B&R audit procedure, ST-QAP 18.1, will be reviewed to ensure that all applicable PSAR commitments and related criteria have been adequately addressed by the auditing program and procedures.

(5) Date when full compliance will be achieved The PQAP and auditing procedures will be in full compliance with the PSAR commitment by July 14, 1980.

Further steps aimed at ensuring the translation of project requirements into applicable procedures will be an on-going activity.

79-19-48 ITEM A-18.b Failure of HL&P to perform adequate audits in that unsatisfactory conditions were not observed A. Summary The HL&P QA Program was not implemented as required by the PSAR and applicable audit procedures in that HL&P failed to audit B&R site activities.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance HL&P audits of B&R site activities were limited to periodic on-site surveillance and examination of records in the belief that such activities satisfied audit requirements.

Auditing functions were further impeded by insufficient time to prepare for audits and to evaluate audit findings.

Further, insufficient time and personnel forced the auditors to review only documentation of previously conducted site surveillance as a means of completing the required " audits" in a timely manner.

(3) Corrective actions to date and results achieved In November, 1979, the function of the HL&P corporate audit group was changed to minimize conflicting activities

79-19-48 and responsibilities of auditors. This change established a group of auditors whose primary function is to prepare and conduct audits of quality-related activities. Concurrently, auditors have been given additional training in the area of codes and standards. Finally, the HL&P auditing procedure has been revised to require more than cursory examination of documentation. Auditors must now verify procedural implementa-tion by direct observation of quality-related activities.

This activity will be supplemented by review of quality documentation.

(4) Corrective steps which will be taken to avoid further items of noncompliance To allow the auditors more time in which to pre-pare and conduct audits, additional qualified auditors will be added to the present staff. Until these positions are filled by permanent personnel, HL&P will utilize the serv-ices of an outside consultant to supplement the present staff.

(5) Date when full compliance will be achieved All corrective action will be complete by June 20, 1980. There will be a continuing program to assure that PSAR commitments and other job specifications are included in construction procedures.

79-19-48 ITEM A-18c Failure to perform audits on the prescribed frequency A. Summary HL&P failed to perform semiannual audits of B&R site organization and procedures and annual audits of B&R construction site activities, as required by the PSAR and applicable HL&P QA procedures.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance Historically, HL&P corporate audits of B&R site

' activities involved auditing the B&R site quality organization and not necessarily specific B&R construction procedures.

HL&P reviewed only documentation of B&R audits of construction practices and supplemented these reviews with site surveillance.

Additionally, HL&P QA management failed to recognize the requirement of the Project Quality Assurance Manual which provided for semiannual audits.

(3) Corrective actions to date and results achieved Since March 1, 1980, the HL&P corporate audit group has been scheduling and performing audits of B&R

79-19-18 construction activities. HL&P auditing procedure, QAP-5B, was revised on March 31, 1980 to state that not only will objective evidence be examined to ensure compliance with QA requirements, but ". . . procedural implementation will be verified by direct observation of work being performed. . .

(4) Corrective steps which will be taken to avoid further items of noncompliance A matrix has been prepared which lists all applicable B&R procedures and the corresponding audit requirements.

This matrix will be used to assure that procedures governing activities affecting quality are audited.

(5) Date when full compliance will be achieved Full compliance has been achieved.

79-19-48 ITEM A-19 Failure of B&R to perform in-depth audits of site activities A. Summary B&R (Houston) audits of the B&R site activities were primarily a review of records, lacking in the depth necessary to determine whether or not B&R site procedures for activities affecting quality were being implemented effectively. Further -

an audit of site design control was not performed in 1978.

B. Reply (1) Affirmation or Denial The items of noncompliance are substantiated.

(2) Reason for item of noncompliance B&R audits were ineffective due to inadequate attention by QA management, personnel turnover and inadequate numbers of experienced personnel.

(3) Corrective actions to date and results achieved B&R has initiated the following actions to correct these problems and prevent their recurrence:

(a) The B&R audit program has been reoriented from current " procedural" audits to program /

system audits following the B&R QA Manual and 10CFR50, Appendix B elements. This change

79-19-48 will assure that all criteria are adequately reviewed and evaluated on a periodic basis.

~

(b) To assure that audit schedules are met, significant additional staffing of the Houston audit section has been authorized.

(c) Meetings have been held with audit section per-sonnel (Houston and site groups) to define in more detail what should be reviewed. Actual work in progress will be observed to verify implementation of requirements.

(d) At least one audit team member will be experienced and/or trained in the discipline being audited.

(4) Corrective steps which will be taken to avoid further items of noncompliance HL&P will review recently implemented changes to verify that they meet quality requirements. Additional Resident Site Auditors will be appointed. Their functions will be to audit and monitor day-to-day quality, construction and engineering activities on-site, and to provide project and QA Management with prompt reports of results.

(5) Date when full compliance will be achieved Full compliance will be achieved by July 22, 1980.

79-19-11 ITEM A-20 Failure to inspect reinforcing steel 'or f loose rebar prior to concrete placement A. Summary B&R procedures require that the civil inspector verify that reinforcing steel is supported and tied to prevent dis-placement. Although QC documentation indicated that steel was properly installed, a sample inspection of vertical tie bars (made when the placement was about one-third completed), iden-tified that three of the ten shear ties examined were unsecured.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance This item of noncompliance was attributable to additional traffic i. this area during the placement activity and pressures upon QC personnel to quickly accept the placement conditions.

However, the four civil inspectors assigned to this placement were interviewed as to the horizontal and vertical movement of rebar during the placement of concrete. Three inspectors observed no movement of rebar. One inspector observed movement and had the rebar repositioned and secured.

79-19-11 (3) Corrective actions to date and results achieved Meetings have been held with QA/QC per'sonnel to reemphasize that they are to take as much time as required to ensure that an accurate and thorough inspection is made.

Revisions to Site Procedures CCP-3, 4, 8, 12, 19 have been made which instruct the inspector that if, after he has inspected and accepted an item, additional activity should occur in the inspected area that might affect quality, he shall reinspect that item and document his results on the applicable examination checklist. Corrective action to avoid excessive production pressure on QC functions and related measures discussed in the reply to item 1 will help to avoid the conditions which gave rise to this item of noncompliance. Post placement meetings

~

are held to identify problems that may have occurred during the placement and suggestions on ways to correct these problems

,. prior to another similar placement. Attendees at the post placement meetings are engineering, QC inspectors, and the concrete placing foreman responsible for the pour. In response to Investigation Report (page 53), an engineering assessment will be made to determine the effect of unwired shear ties on the referenced pour.

79-19-11 (4) Corrective steps which will be taken to prevent further items of noncompliance The generic problem of excessive production pressures on QA/QC personnel is discussed in item 1. The corrective steps which have been taken, especially items (3)(a), (c), (h),

(k) and (q), of item 1 should help to prevent situations of the type identified in this item of noncompliance. Further training and indoctrination underscoring that QC personnel will not be pressured to meet production requirements will be an on-going program.

(5) Date when full compliance will be achieved The specific item has, as noted, been corrected. The training and indoctrination discussed in (4) will be an on-going Project activity.

79-19-38 ITEM A-21 Failure to control design changes in root openings and weld dimensions A. Summary By correspondence, B&R initiated engineering changes in certain welding procedures without complying with applicable portions of the B&R QA Manual for control of design changes.

B. Reply (1) Affirmation or Denial The item of noncompliance is substantiated.

(2) Reason for item of noncompliance The item of noncompliance represents a failure to follow applicable design change controls. Applicable procedures were changed on April 9, 1980, in accordance with the require-ments of the QA Manual, and the change made via the correspondence discussed above in the " Summary" is now an acceptable procedure.

(3) Corrective action taken and results achieved As noted above, the procedural changes made by the correspondence have now been incorporated.in the appropriate document. Work already performed pursuant to these procedures has been found acceptable.

i l

79-19-38 (4) Corrective steps which will be taken to prevent further items of noncompliance All administrative and technical personnel in the Welding Engineering Department and QA/QC personnel involved with design changes will be trained in the design change system, making them fully cognizant of the correct method of requesting design changes.

(5) Date when full compli_ance will be achieved The training described in (4) will be completed by June 30, 1980. All welding and QA/QC personnel will receive additional training in the importance of adhering to quality requirements and following approved procedures for making design changes. This will be an on-going effort.

79-19-32 ITEM B - Failure to follow ASME B&PV Code per 10 CFR j 50.55a for radiography qualification technique A. Summary Procedures followed in welder qualification did not use penetrameter en the source side as required by the ASME code. Notwithstanding access for a source side penetrameter, work was done with only a. film side penetrameter.

B. Reply i

(1) Affirmation or Denial The item of noncompliance is substantiated.

1 (2) Reason for item of noncompliance The film side penetrameter was used based on the requirements of paragraph T-262.2 of ASME,Section V. That section discusses " inaccessibility" in regards to the place-ment of penetrameters. Subs 3ction B, Article 33, SE-142, Paragraph 6 of ASME Section V provides for the use of a film side penetrameter when placement of a source side penetrameter is " impracticable." The work in question involved a welder qualification activity that was done on pipe with sufficient inside diameter (ID) to use c film side penetrameter. It was felt, however, that qualification tests should simulate field conditions where the ID might not be accessible for a

79-19-32 film side penetrameter. Accordingly, the provisions of ASME Section V were relied upon.

(3) Carrective actions to date and results achieved Notwithstanding the question existing with respect to the applicable code provision, source side penetrameters will be used where permitted by ID of the piece being welded.

Radiography personnel have been re-trained and re-certified to correct procedures.

(4) Corrective steps which will be taken to avoid further items of noncompliance A comparison test will be performed to determine the difference in the results obtained using a film side penetrameter versus a source side penetrameter for radiographing welder qualification coupons. The incident reflects both a i need for further indoctrination in the need to follow applicable job requirements and a need for more careful translation of job requirements and specifications into procedures and work instructions.

(5) Date when full compliance will be achieved Full compliance is now achieved with respect to applicable RT requirements in welder qualification tests as indicated in (3). As indicated in (4), there will be an on-going program of retraining and indoctrination as well as a more careful delineation of work procedures to meet job requirements.

NRC Poem 103t (11 . 77) ' rege of Pages THIS NUM8ER MUST APPEAR ON ALL PACK.

AGES AND PAPERS RELATING TD THIS ORDER I ORDER NO.

U. S. NUCLEAR REGULATORY COMMISSION l POINT OP ISSUE:

y$

WASHINGTON, D. C. 20565 REQUISITION NO.

005825 E PURCHASE ORDER PER YOUR b ON3 op 5/1/$0 DATE p E DELIVERY OPOER UPOER CONTRACT NO. ' 07 '1 COST SYMBOL . ALLOTMENT APPROPRIATION SYMBOL AND TITLE E C2-20-22 G0? 3130200.4c0 $39.00 TO CONSIGNEE AND DESTINATION S

Contineatal Airlines S U. 5. inclear Regulatwy Consission 7309 *a'orld 'iay West " A ""* * **"' '3 I Los Angeles, sA 70002 a p Office of Inspection and *nforcement g , dashing % 0. C. 20555 R

f O VIA Re: P.O.No CI-EO-l 46 l OELIVERY F.O.B. TIME FOR DELIVERY GOV *T 8/L NO. OfSCOUNT TERMS t *f/A Complete 5/1/3C 3/A Net 30 f Please furnish the following on the terms specified on both sedes of thes sheet and on the attached sheets, if any, except that any such

! terms which might be inconsistent with the terms of any existing Federal contract or agreement under which this order is placed will noi appiv.

Item No. ARTICLES OR SERVICES QUAN. UNIT UNIT PRICE AMOUNT f

FOR OFFICE REC 07.CS OL'LY i

• apent of charges for shipment of package to 1 MG $3?.00 $37.00

!custon Light and Power Campany on P.ay 1,1933.

j ihis purchase order is issued pursuar.t to the 4

,iuthortty of 41 U.S.O. 252(c)(3).

l 1

If there are any questions in regard to this order, please call f!s. Cindy Trageser on (331) 427-4490.

CT

! TOTAL $39.00 CONSIGNEE COPY l

RECEIVED DATE