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March 26, 1980
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1 MEMORANDUM FOR:
W. C. Seidle, Chief, RC&ES Branch THRU:
W. A. Crossman, Chief, Projects Section FROM:
H. S. Phillips, Resident Reactor Inspector, STP COMMUNICATIONS WITH S't? MANAGEMENT / SUPERVISION
SUBJECT:
The meeting held,in Houston between Houston Lighting & Power (HL&P) and NRC personnel was a useful meeting; however, I would like to bring certain infor-mation to your attention relative to communication. As you know, the main thrust of the meeting was er=r==mication.
Of course, comununication is some-thing that can always be improved; however, some at the meeting may have thoughtthere has been little er==mmication.
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l Two enclosures may help clear the air if there is a misconception.. Enclosure 1 is an outline of subjects discussed at a meeting held on' October 5, 1979, and attended by HL&P manag===nr and supervision. Attendees were Bill Phillips, Projects QA Manager; Logan Wilson, Site QA Supervisor; Tom Jordan, Lead Mechanical Engineer; Dave Long, Lead Electrical Fngineer; Tim Stanley, QA Project Supervisor; Leon English, Construction Manager; and D. Barker, Project Manager. Enclosure 2 is a list of formal meetings., not to mention the countless daily contacts and informal meetings.
There has been a lot of communications between the RRI and HL&P site personnel.
However, conzaunication has been poor.with respect to HL&P management above.this level. That is, these managers have chosen not to listen when I describe non-compliances with which they disagree. BL&P descriptions of RRI findings have been misunderstood by HL&P management for some reason. Responses to NRC report findings have been developed and sent to Region IV by the managers without the benefit of firsthand knowledge of the problem.
8506070156 840620 PDR FOIA H. S. Phillips OLASPIB4-393 PDR Resident Reactor Inspector
Enclosures:
1.
RRI/ Licensee Meeting to Discuss Policy,
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RRI/ LICENSEE MI~i""INC TO DISCUSS PCLICT. Iku.? ACE. C05fL'NICATIONS AND REPORTS 1.
Purpose of Reyident a.
' Read MC 2512 Ob$ectives MC 2592 Reactor Insoection Program for Sites Havinc a Resident Insoector
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Construction Phase (1) Aeolicability The construction phase of the reactor inspection progra= applies to construction activities a: the site.
In general, construction inspection activities begin about the time the CP (or L'n'A-2) is issued and ends at issuance of an OL.
Final construction inspection activities overlap vich the preoperational testing and operational preparedness activities.
The inspection recuire-
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ments identified in this program should normally.be completed prior.to OL issuance.
The initial implementation of the resident inspection program will start when a resident inspector is stationed at the site.
This inspection program augments MC 2512 for sites having a resident inspector during the construction phase.
(2) Obiectives The objective of the resident inspection program during the construe:1on phase is to provide increased observation of safety-related construction activities and increased observation of completed and partially completed components, structures and systems. More specifically, as in MC 2512, the intent is to determine whether components. structures and systems are in accordance with NRC requirements and licensee commitments to ensure reactor coolant system integrity, safe shut-down capability, and prevention / mitigation of accidents leading to release of radioactivity.
2.
NRC Poliev Interface - Senior Site Representative designated by licensee NRC does not direct licensee or contractor to do anything Lines of Conummication Day to day operation Resident Inspector - Senior Site Representative Notification of work activity
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. Special Co==unication Residen Inspector to EL&P corporate office excep-don rather than rule Management meeting a: least once per week to discuss inspection findings Conflic: of Interes:
Agency has directed inspectors, especially site inspectors, to avoid conflict of in:eres::
on site J
off site Pro or Con Nuclear i
NRC is a Regulatory Group, therefore, it is not proper for us to promote nuclear power or work againt it Personal opinion as a citizen - it is a safe energy source The decision to use nuclear power or not is a decision that has already been made by the US Congress, thus the majority. The majority should be the group to decide - not a small group.
3.
Enforcement MC 0800 - enforcement actions outline the actions to be taken and define inspection findings are:
Violations - caused an incident or substantial potential for causing an incident Infraction - inadequate procedural / management controls in the QA implementation i
Deficiency - an item of noncompliance in which the health and safety of the public is not threatened or remote Deviation - licensee's failure to conform to a connitman:
Unresolved Matter - more information is needed to determine if an item is acceptable, an item of noncompliance or a deviation NOTE:
An URM is also used when clarification is needed
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I will identify items as defined above to engineers and specialists as they occur during the week. At this time, the engineers / specialists should pre-sent to the Resident inspector information which shows the practice to be acceptable Sample Only 4.
Resident Enforcement Poliev.
Findings will be reported as observed.
l Minor items where procedures have been violated will be evaluated on a case-by-case basis.
If corrective action can be taken on the spot for 4
minor problems (and caps), I will try to avoid writing such items up as items of noncompliance if promptly corrected.
Repetitive minor, items will result in noncompliance Resident policy on differences in technical findings 5.
Resorts a.
Interim Reports
.b.
Monthly Inspection Reports c.
Documentation Criterion IVII for license " Sufficient records shall be mMntained to furnish evidence of activities affecting quality. The records shall include at least the following:
" logs "results of reviews, inspection, tests, audits, monitoring of work performance and materials analysis."
The NRC has only inspection reports to document procedures review, work obseravtion and review of records.
Accordingly, I will document reviews, inspections and observation of work.
d.
Perspective I'will try to lend perspective to findings: paper deficiency how many right or wrong an infraction - how many items were correct versus how many were observed to be incorrect
J URM (major - site unique) - real potential to become item of non-
. compliance URM (minor - site unique) - end caps, few pieces of rebar URM - clarification needed on a procedure is an example.
If not corrected promptly before the activity recurs could become a deficiency.
Observation - nonsafety rela:ed or something that could indirectly lead to an ite= of noncompliance 6.
Office Hours Core hours - 7:30 - 4:00 Backshift requirement Wise use of time.'
Called Meetings Coordinate times with me since my inspection plann ng and leave plans d
are independent.
7.
130;end EL&P Lovalties I owe my loyalty to the NRC and you owe yours to EL&P. This is natural and healthy.
As I see it, the only thing that is more important is the health and safety of the public.
A safety issue, major or minor, transcends company loyalties.
Every worker, engineer and manager is a part of Quality Assurance. A great many persons think of quality as an organf ration.
No - an organization is not quality assurance. The organdration only checks to see d*
all work activity is quality. work, that is, requirements, lead to specifications, lead to procedures, lead to work is accordance with procedures, lead to quality design, procurement, construction, and a safe operating plant
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. Date Attendees Sub_iect 10/5/79 B. Phillips NRC policy, interface, communication, T. Stanley reports L. Wilson T. Jordan D. Barker L. English 10/5/79 Bill Phillips Meeting to discuss various topics, MC 0800
' 10/8/79 D. Long Discussion of NRC report of findings relative to civil (concrete)
'10/9/79 T. Logan Meeting to introduce NRC Co-op student D. Long to site QA supervision 10/10/79 J.Soward,'EL&P Meeting to discuss NSSS responsibilities B. Leslie, Westinghouse and operation 10/10/79 B. Gebhardt, B&R Meeting with B&R project engineers on R. Parrish, B&R Essential Cooling Pond 10/11/79 L., Wilson Weekly inspection debriefing Lead Engineer 10/12/79 L. Wilson Weekly debriefing on Steam Generators /
Lead Engineers Vessel manuals versus site manual inconsistency 11/1/79 Logan Wilson Weekly meeting to debrief on "C" inspectio:
NOTE: ALLEGATIONS RECEIVED NOVEMBER 2nd 11/8/79 Logan Wilson Brief meeting to say no inspection findings, thus no long meeting required 11/13/79 Logan Wilson Entrance meeting Lead Engineer RIV NRC Inspectors 11/21/79 Logan Wilson Weekly debriefing on "C" inspection Lead Engineer program 12/6/79 logan Wilson Investigation team interim exit QA Staff
ew RRI/HL&P MANAGEMENT MEETINGS The following management meetings have been held between the RRI and EL&P/
contractor personnel:
Date Attendees Subiect 9/4/79 Tim Stanley Get well plan.for concrete after Logan Wilson stop work Dave Long 9/7/79 Bill Phillips Miscellaneous topics about project l 9/12/79 D. Long Discussion on civil work activity 9/14/79 L. Wilson Exit meeting on investigation 79-14 l
D. Long T. Jordan 9/18/79 D. Long.'
Meeting requested by Long to discuss NRC/ contractor interface 9/20/79 L. Wilson Weekly "C" inspection debriefing 9/20/79 Glen Marshall Meeting to discuss status of Dave Long mechanical work 10/1/79 T. Stanley Discussed findings relative to inspection (telephonic) of shell wall pour.
Stanley was very surprised relative to NRC findings on Sept. 17th indicating he had not been very well informed.
10/3/79 Tom Jordan RRI objected to receiving notice of (acting QA meeting to be held with the RRI on 10/5/79.
supervisor)
No one informed the RRI of the meeting prior to receiving the notice.
He said I would have to talk to HL&P HQ.
10/3/79 T. Stanley Talked to Stanley on same subject
-(telephonic) 10/3/79 J. Soward Meeting to discuss unresolved (mechanical) matters 10/4/79 D. Long Civil matters All HL&P site Meeting to view CBS program QA personnel 4
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' Date Attendees Subjec,,
12/7/79 Logan Wilson, site QA Supv.
Meeting was not called but resulted Claud Grosso, EL&P Civil Eng.
from problems on shear tie (over 100)
T. Warnick, B&R QA Mgr.
found untied.
Twenty found by NRC C. Singleton, B&R QC Supv.
prior to 100 found. Discussed proble=
Q. Lindsay, B&R Conc. Supv.
with individuals.
J. Nailor, B&R Inspector L. English, HL&P Const. Mgr.
NOTE:
RRI ON LEAVE FROM 12/19 - 1/10 12/10/79 L. Wilson Mid QA responses (inadequate)
- 7. Jordan 50-498/79-13; 50-499/79-13 1/28/80 Bill Phillips Inadequate responses to NRC Inspection L. Wilson Reports No. 79-13, 79-15 and proposed
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answer to 79-16.
RRI stated that continue unsatisfactory response could only lead to escalated enforcement or management meeting.
Frazar came into this meeting briefly and Bill Phillips said " Dick I think this is something you need to sit in on."
He replied, "What is it"?
Phillips said, "It's the NRC responses that is, the NRC is very unhappy with our responses format, etc."
Frazar replied, "That's what I hired you guys for, you solve the problem, I don't have i
time."
1/29/80 B&R QA Manager B&R organization of audit groups.
B&R B&R QA Project Manager corporate audits and site audits.
History Manager Audit Section of B&R audits.
1/30/80 Bill Phillips Audits' T. Logan Civil test borings 2/4/80 T. Logan Backfill program 2/5/80 B&R QA Audit Mgr.
Audits 2/8/80 R. Jacobi, Licensing RRI informed Jacobi of requirement to HL&P send a letter if 50.55(e) not reportable after reporting (borings) 2/12/80 D. Long Bulge problem NOTE: RRI MEETING 2/13-15/80 l
o Date Attendees Subject 2/18/80 L. '411 son Meeting en 50.55(e) repor borings 2/19-29/80 PS.I in Bethesda M
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UNITED STATES
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- '/ y H:~'h NUCLEAR REGULATORY COMMISSION REGION IV
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T i - Nf May 27, 1981
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MEMORANDUM FOR:
K. V. Seyfrit, Director trhil G. L. Madsen, Chief, Reactor Projects Branch THRU:
W.' A. Crossman, Chief, Projects Section 3 lt Yt FROM:
H. S. Phillips, Resident Reactor Inspector South Texas Project
SUBJECT:
IN-PLACE STORAGE AND PROTECTION 1
_ I&E Inspection Procedures in MC 2512 and 2592 require NRC inspectors to i
determine if NSSS and. Safety Related Equipment is adequately protected while stored in-place. Historically, this has been a problem which has been caused by lack of clarity to ANSI N 45.2.2 and Regulatory Guide 1.38, which give the licensee / contractors guidance on storage of items.
The licensee is required to meet 10 CFR 50, Appendix B, Criterion XIII, which i
requires that equipment be handled, cleaned, shipped, stored and preserved in 4
such a manner as to prevent damage and deterioration.
In certain instances, j
special protective measures must be specified and implemented. This general r
requirement is sufficient since it simply requires adequate protection.
However, the problem is with ANSI N 45.2.2, the Standard which describes an acceptable way to meet Criterion XIII. The subject Standard is not particularly clear with respect to the following areas:
The Standard defines storage as:
"The act of holding items at the con-struction site or in an area other than its permanent location".
Comment:
Tnis definition does not cover equipment stored "in-place".
In many instances, equipment is stored in-place until final installation. This i
period covers months and sometimes years during which the equipment is subjected to even harsher conditions than those experienced in warehouses or other storage areas, The Standard should define terms such as interim, temporary, in-place and pennanent storage.
Paragraph 6.1.1 of the Standard states:
" Levels and methods of storage i
necessary are defined to minimize the possibility of damage or lowering of quality due to corrosion,- contamination, deterioration or physical r
damage from the time an item is stored upon receipt until the time the item is removed from storage and placed in its final location.
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1 Memo.for Seyfrit 2
May 27, 1981 Comment:
The Standard does not define nor adequately address in-place storage.
The Standard gives the impression that equipment is moved out of the warehouse into a completed containment and auxiliary building where conditions are the same as the storage level from which it was removed.
Also the licensee interprets this paragraph to mean that storage, as described in the Standard, ends when stored in-place.
paragraoh 6.5 of the Standard states in oart, " Items released from storage and placed in their final locations, within the power plant, shall be inspected and cared for in accordance with the requirements l
of Section 6 of the Standard and other applicable standards".
Comment:
Licensee-interpretation (see enclosure) of this paragraph states that only paragraphs 6.4.1 and 6.4.2 apply and equipment that is in-place
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need not meet the other paragraphs of Section 6, including the environ-mental storage. conditions of paragraph 6.1.2(1)-(4). That is, it is not possible and/or practical to maintain storage levels in containment and the. auxiliary buildings as were maintained in the warehouse areas.
Recomendation:
l It is not practical, or perhaps possible, to mintain the whole area inside the containment or auxiliary buildings to Level A, B, C or D Levels, however, the Standard or Regulatory Guide should be revised to:
(1) define in-place storage and (2) require that the imediate environ-ment around the equipment stored in-place be equivalent to the level
- of storage from which it was removed.
It is requested that this matter be referred to cognizant Headquarters personnel for appropriate action.
i H. S. Phillips, Resident Reactor Inspector South Texas Project
Enclosure:
Houston Lighting & Power Company Letter ST-HL-AE-652, dated 4-13-81 l
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Ap-il 13, 1981
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Mad:en, Chief React:r Prej ects Branch U.'S. Nuclea'r Regulatory Commission Office of Inspection and,Enforcemen:
Region...
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50tEH E.uS PROJECT EI.ECTRIC GENERATING STATION RESPCNSE TC NRC INSPECTION FINDINGS DOCyET NCS. 50-498/S1-01 AND 50-499/S1-01
Dear :
.'r. Madsen:
Tne following is our response to the Nctice of riciation related to Inspection.;epo-: Sos. 50 J95/SI-01 and 50 J99/SI-01, dated Mar:h 20, 1951.
So=e ':anfusion curently exists related :: the :e =s " storage," " main-tenance," and "in-place prote:: ion" as used in the South Texas Pr:f e:: (STP}
General Construe:icn Procedure (GCP)-35 and as described in ANSI N45.2.2.
Prier to addressing each finding it is i=portant tha: the South Texas Project position be clarified.
I is the policy of the South Texas Proj ec :o s:rie:1y adhere to ANSI N*5.2.2 as it applies to the pertinen proj ec activities.
ANSI N45.2.2 applies per applicable sections to packaging, shipping, receiving, storage anc nanc4:ng or materia.,.
The standard does not apply in :.:s entirety to in-place prote : ion.
ANSI N45.2.2 identifies *a clear distinction be: ween its scope related to packaging, shipping, receiving, storage and handling. and the case in which items a e placed in their final locations within the power plan:, refered to by the South Texas Proj ect as in-place trotection.
Examples are:
A.
Storage is defined in the standard as, "the act of holding items at the construction site or in an area other than its permanen:
location in the plant."
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In this case, the =aintenance and inspections will continue and the environment will-be controlled by procedure in ac-cordance with ANSI N45.2.3.
ne conclusion is that:
A.
Thir inte:.:retation is in accordance with the recuirements of ANSI N45.2.2, ANSI N45.2.3, MSI N45.2.S or Regulato y Guide 1.38.
3.
The project will continue to comply with applicable subparts of both ANSI S45.2.2 and ANSI N45.2.3.
Responses to the specific findings are as follows:
Finding No.1 - NS.SS ecuipment was not protected as recuired by "D" storage recui ements POSITION The conditions cited are valid in that the equipment did not meet either the Equipment Storage and Maintenance Ins: uction Record requirements or Sections 6.4.1 and 6.4.2 of ANSI N45.2.2.
We wculd like to point out, however, that the STP position on ANSI N45.2.2 is that Level "0" storage requirements do not amply to in-place ecuipment.
CCRRECTIVE STEPS hEICH HAVE BEEN TAKEN All equipment listed in the NRC repor was sealed to preclude airbc ne contamination.
Other equipment and areas not listed were inspected for similar conditions.
On October.29,1980, an HL5P I=plementation Review was concluded on storage and maintenance.
That review resulted in the issuance of three Conective Action Repor:s having to do with maintenance of documentation, organi:ati6n dese-iption of the sto age and maintenance department,_and access control.
As of March 19, 1981, all three were re-solved and closed out.
On March 10, 1981, BSR Quality Engineering responded to an HL&P QA request to review the s:stus of NRC reports issued since 1975 dealing with storage and maintenance.
All previously-identified NRC findings were found to be completed with no lapses of nonconformances.
In addition, the letter describes the QC 100% su:veillance of maintenance of safety-related items.
On March 12, the revised Westinghouse NSSS Storage Manual was issued.
By the letter of March 12, 1981, from HLSP Construction to BSR Construction, HLSP has tightened the access control through HLSP approval of the access-list.
On March 19, 1981, HL&P Construction required the B6R Permanent Plant Maintenance Department to establish a regular schedule of maintenance for NSSS components.
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CORRECTIVE STEPS h*dICH WILL BE TAKEN TO AVOID FURT:!ER VIOLATIONS l
On February 25,.1951, the firs of the weekly housekeeping walk-through l
inspections was performed and documented.
Tne walk-through inspections
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are perfor:ed by the Area Ma. agers and 35R QC.
Since the walk-throughs I
began, the housekeeping has =a prially i= proved. A p oposed revision l
i r - ss wi.,. c a-ify the distinction be: ween wa ehouse storage anc in-o:
s place protection and also the relationship and attendsn requirements of s:orage versus in-place protection.
The proposed revision also clearly
,makes the Area '.hnagers resc.onsible for in.01 ace trotection.
On Janua:v. 26, i
1951, HL5P Cons: uction required 35R by memo to:
1.
Increase control of access, 2.
. Defer sandblast activities until maintenance and housekeeping
' requirements are reestablished, 3.
Have housekeeping maintenance requests monitored by area engineers, and 4.
Use the most stringen requirements where doubt exists.
On Feb nar/ 12, 1981, MLSP QA issued a letter te B&R Construction and QA Management identifying both NRC and HL5P recen: findings relative to both the condition and con: ol of in-place ecuipmen as well.as housekeeping.
This le::er required a SSR Managemen: Action Plan addressing:
3hysical conc..:: en of equipment, 2.
P oble=s not identified or resolved by 35R, 3.
Untimely resolution of in-place storage and maintenance discrepancies, 4.
Access control, 5.
ESMI card deficiencies, and 6.
Inadequate instructions.
The response has been provided and is c.ently under review.
On March 9, 1981, B&R Quality Engineering commenced weekly checks of storage and maintenance activities.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED All above-mentioned items have been co=pleted except for evaluation of the B8R Management Action Plan and the issuance of the proposed revision of GCP-35.
This activity will be - completed by May 11, 1981.
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r Finding No. 2 - Failure to identify tha: the.HR p=rs were cents:-
insted and to issue a.Nonconfo=ance Recor:
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- ne Equipmen 3::rzge and Maintenance Ins: uction (ISMI) cards for this equipmen: did no: contain sufficient infe=ation; thus, the 3
QC Inspector (inspe::ing to the card require =ents) had no reason to 3enerate an NCR, resulting in the cited situation.
j CORRECIVE S3PS hEIG iiAVE BEEN TAKEN N
b inese steps are the same as in _*1nd:. Lng N.o. 1.
In ac... cit:.on, the ::M.
i cards have been revised to delineate the c.rocer in rlace c.rotection
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requi ements and the pu=ps have been reeleaned, cor osion inhibitor has been reinstalled, and griffolyn resealed.
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CORRICIVE STEPS hEIG WILL BE TAKEN TO AVOID :URTHER VIOLATIONS 4nese steps are the same as in Finding No.1.
a DATE hEEN FUL:. COMPL:ANCE WI'L BE AGIIVED i
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8 All actions will be 00molete b.y May 11, 1981.
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Finding no. 3 - ESMI cards for N555 ecuitment did no: adecuarely address I
vendor and N45.2.2 recu.rements for in-cla:e storage e
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POSITION The citation is valid in tha: the cards did not contain adequa:e recuire-
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=ents, bu: the requirements are those applicable to care and inspection,
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not storage.
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CORRECTIVE STEPS hEIG HAVE BEEN TAKEN 3
i These stens are the same as in Findin No. 1.
In addition, the ESMI i
1, ca-ds hav'e been changed to include adec.uate in.ulace c.rotection t
requirements.
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CORRECTIVE STEPS hMICH WILL BE TAKEN TO AVOID FURTHER VIOUTIONS z
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g These steps are the same as in Finding No.1.
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DATE KEEN FULL COMPLIANCE WILL BE ACHIEVED c
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R All actions will be complete by May 11. 1981.
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Finding No. 4 - Failure to provide adecuate prc ee:icn for ecui;=en:
in -he Y.'AS Uni: I anc :o orovice ::.=e:v c:.scos:.:.cn :or a.Nonconio=ance Recon
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- e finding is ::nsidered valid, h
COR.:EC nc o 4:PS hEICH HAVE BEEN TAKIN
.ne conective action is essentially the sa=e as for Finding No.1; however, some clarifications are recnired.
ESMI Verification Repor:
no. 13:, dated Nove=ber 29, 1979, was answered by correspondence BC-23237, which stated that the pu=ns and motors had been cleaned, a ta paulin placed over the plastic drapes, and the roof of the Kelly Cicsure sealed.
This action was verified by QC, and at this time the pu=m and motors were considered to be in satisfactory condition.
For this reason, no NCR was generated in relation to 79-22.
Subsecuently,
= ore sandblasting was initiated, and on Septe=oer 9,,1980, NCR No.
7 SG-2691 was generated as a result of the last sandblasting operation.
-"he nine-=onth lag between 79-22 and SG-2691 was because the situation identified by 79-22 was :orrected by a:: ions referenced in corespondence 3C-23237 dated November 29,1979, and SG-2691 was written agains: a later occurence.
ane pu=ps were rc:a:ec three times after SG-2691 e
h was initiated.
hese ca:es are septe=cer 12,19S0; Oc ober 6,1980; E
and Nove=ber 13, 1980.
Subsecuently, these pu=ps have been cleaned, inspected, lubricated, and rotated.
The motors have been re=cred to the wa ehouse, where they will be cleaned and inspected.
F CORRECTIVE STEPS hMIOi WILL BE TAKEN TC AVOID FURTHER VIOLATIONS
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These steps are the same as in Finding No. 1.
In addition, a manage =en:
I decision has been =ade to re-evaluate maintenance cerfo:=ed on noncon-
- o=1ng ecus.p=ent :or :ne purpose a: el1=:.nat:.ng =a:.ntenance steps which g
could further da= age an ite: prior to conection of the nonconfor=ance.
P DATE hEEN FULL COMPLIANCE WILL BE ACHIEVED n
The motors referenced will be cleaned and inspected no later than Septe=ber 1, 1981.
All other actions will be co=cleted by May 11, 1981.
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If you have any cuestions regarding these co==i:=ents, please contac: =e.
Verv truly yours, s
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