ML20134A501
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HOUSTON REGION AL GROUP CLU August 19, 1980
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Karl Seyfrit Director Regian IV, NRC L3 611 Ryan Plaza Drive Arlington, Texas 76011 l
Dear Mr. Seyfrit,
The Houston Sierra Club has the following comments to make concerning the South Texas and Allen Creek's nuclear projects and our feelings on nuclear power in general.
We request that these, comments be placed in the official hearing record for the hear-ing on HL&P's proposal for further quality assurance programs at the South Texas Nu-cl% r Project.
The official Sierra Club position starting in January of 1974 was that no fur-ther nuclear power plants should be completed until the following 3 issues had been satisfactorily resolved: the safety of nuclear power plants, safe disposal of radio-active wastes, and the possible use of stolen nuclear materials for acts' of terror-ism.
Decently the Sierm Club has revised its policy on nuclear power so that we now support the cessation of all construction and plannig of nuclear power plants and a gradual phase out, over a reasonable length of time, of all existing nuclear plants.
In line with the concerns expressed for the above mentioned problems we would like to emphasize the followings i.) We feel the Emergency Core Cooling Systems (SCCS) are inadequately designed and tested as shown by the frequent break downs due to mechanical failure and oper-ator error and are not adequate in providing failsafe mechanisms to avoid a Loss of Coolant Accident (LOCA).
2.) Present insurance for nuclear power limits liability to 560 million dollars (Price-Anderson Act) when property damage, by the governments own estimates could reach as high as 17 billion dollars. This gives the nuclear industry a tremendous subsidy paid for by the American taxpayers. In addition to the limited liability, most of the insurance is funded by the government. If it is safe enough for Ameri-cans to risk their lives and property then it is safe enough for utilities and in-surance companies involved with nuclear power plants to risk their assets.
t 3.) N'o safe method of disposal of radioactive wastes generated by nuclear pow-er has been found to date which will insure integrity of the waste site for the 500,000 years needed for reduction of the radioactivity to a supposedly acceptable risk level.
4.) The spread of nuclear weapons and the risk of nuclear war is encouraged by the use and proliferation of nuclear power plants.
5.) The increased heat energy generated by nuclear power plants, if not suf-ficiently cooled to preheating temperatures, will result in the degradation of
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our streams and lakes from thermal collution.
8508150327 850703 PDR FOIA LEIGHTOB4-293 PDR uNot blind opposition to progress out opposition to blind progress"
'l ATTACHMENT 7
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LETTER FROM THE HOUSTON REGIONAL GROUP 0F THE SIERRA CLUB
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. 6.) Uranium mining has caused and continues to cause unacceptably high levels of cancer in miners and has contamir.ated large areas of the West.and exposed the general public to increased risks of cancer.
7.) Whclear power supplies only 2 9% of our total energy use and does not replace the energy needs that foreign oil serves for petrochemical feed stocks, fuel for home heatirg, and fuels for transportation needs.
The Houston Sierra Club Executive Committee on April 16, 1979 passed a resolu-tion opposing the construction of the Allen's Creek nuclear power plant due to the generic problems mentioned above, that all nuclear power plants have. and which have not been resolved.
Our concern with the South Texas nuclear power plant (and even more so with Allen's Creek) stems from the nearness of the plants to large population centers and the possiblity of a large accidental release of radioactivity. We are concerned with the way the South Texas Project is being constructed. Not only have quality assurance personnel been pressured and threatened with physical harm from Brown &
Root construction personnel but the very integrity of the containment structure is in question. Many voids have been found in the concrete as well as a bulge in the steel liner of the reactor containment vessel. This shoddy and slopoy workmanship is best exemplified by a void that was discovered to be 48 feet long and several feet wide and thick.
We are very concerned that RL&P has proposed that Brown & Root continue to be in charge of quality assurance at the plant when they have so miserably failed to maintain the high quality needed for such a potentially dangerous technology.
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The Houston Sierra Club requests tnat Brown & Root not be permitted to remain v"
in charge of quality assurance. This is inviting more abuse of quality control re-gulations.
I Sincerely,
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Brandt Mannchen Houston Sierra Club Chairperson 1822 Richmond #2 Houston, Texas 77098 l
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MEl*ORAtlDUti FOR: llilliam L. Fisher, Acting Chief 4
General Programs Section, PDB
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FROM:
G. C. Gower, Senior Program Development Specialist, PDB
SUBJECT:
SOUTH TEXAS PROJECT Al'D ZIMMER Enclosed are copies of the sunnary reports prepared on South Texas (STP) and Zimer as a result of reviewing the headquarters inspection files, and the draft report of investigation (81-13) on Zimmer..
There is a difference in the two reports primarily because of the approach taken.
STP was looked at first with a more involved set of guidelines; whereas in the case of Zitr,ier approximately the same time was expended on file review, but significantly less time was devoted to report preparation.
G. C. Gower, Senior Program Development Specialist, PDB:PDA:IE
Enclosures:
As stated cc:
it. C. 11oseley J. Taylor S. E. Bryan J. Stone Distribution:
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Review of the South Texas Projcct AllgructionInspectionCoverage-Cor
.fations and Their Investigation A.
Purpose The purpose of this review was to gather available information and prepare lists of significant problems, from which determinations might be made relative to basic causes behind the problems; determine if the defined IE inspection program could have identified the problems and then develop recommendations for program changes if needed.
The attached note (Attachment A) provides additional guidance on this effort.
B.
Method The inspection file folders on the South Texas Project were reviewed starting in 1974 (predocketing) up through 1979.
These records include the investigation reports and enforcement correspondence.
HL&P's response to the NRC Order to Show Cause, Congressional testimony and Commission correspondence were also reviewed.
From the inspection reports lists of allegations (1977 thru 1979) were developed and later sorted into eight problem areas (Appendix 1A).
Whether or not each allegation was substantiated is noted in the margin.
The HL&P's response, noted above, was rAviewed to obtain a list of other significant problems developed by the HL&P and B&R Safety-Related Welding Task Force (Appendix IC).
This task force was set up to help HL&P respond to the Show Cause Order.
A likely basic cause 'for each of the significant problems was developed to the extent possible from the written record and discussions w th i
other PDA staff.
(Appendices 18 and 1C).
To determine the cegree to which the routine IE inspection program could have identified the problems indicated by the allegations and those found as a result of their investigation, ' comparisons were made in each cas9 against relevant parts of the IE inspection procedures and where some degree of coverage was apparent the inspection procedure numbe s were given.
(Appendices IA, 2A, 2B, 2C, 2D, and 2E).
Ir order to determine the extent to which routine inspections made at STP (thru 12/79) found the same - or quite similar prcblems identified as a result of aliegations and their investigation, a review of each routine inspection report was made and each identified problem that 9
appeared-to be the same, or reasonably similar, was listed (Appendix 3).
Along with this listir.g notations were made whether or not enforcement resulted.
Also during the file review a listing was made of those persons in the licensee and contractor organizations that attended the exit discussions following each routine inspection (listing not included here).
C.
Discussion 1.
Appendix 1A provides a listing of STP allegations sorted into eight problem areas.
This listing served to group the allegations so that one might speculate as to the basic causes behind the identified problems.
Appendices 1A and 1B deal. with allegations and 1C covers the finding from the licensee's Taak Force on Safety-Related Welding Practices.
The eight problem areas identified are as follows:
a)
Records Falsification and QC Documentation (21)*
I b) QC Inspectors Threatened Undue Presssures (12)
Inadequate Suppor.t for QC Inspectors (5) c)
d)
Procedural Violations (17) e) QC Inspectors and Workers not Qualified (3) f) Nonconformance Reporting System Inadequate (4) g)
Document Control Problems (2) h) Miscellaneous (8)
Items a, b and d appear significant due to the numbers of allega-tions listed.
Item d, Procedural Violations stand out in that 11 of the 17 allegations were substantiated.
Further verification of this problem is evident from the enforcement history which shows that from 1976 thru 1979 there were 23 citations out of 36 total, or 64% of the enforcement actions, were against Criterion V (Instructions, Procedures & Drawings).
The record indicates that early evidence of a trend had been established in this problem area by late 1978 since 11 citations had been issued against Criterion V by that time.
- number of allegations in problem area.
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a Item e) dealing with unqualified workers and QC inspectors is not noteworthy in terms of the number of allegations (only 3 -
none substantiated) but appears to be tied into part of Appendix 1C where basic causes have been assigned to the 9 significant problems identified by the task force on welding.
With one exception, the causes attributed to these findings, if correct, point in one way or another to the qualifications and experience of welding. engineers, welding foremen, NDE personnel and QC inspectors, all of which may have been in short supply within the area at the time.
With respect to item a) Records Falsification, 9 of the 21 allega-tions were substantiated.
The first allegation occurred in 1977 and was confirmed.
It was not until the first investigation in April 1979 that the second and third allegations were substantiated.
From 5/79 thru 12/79 almost every allegation was substantiated.
The basic causes listed for this problem are speculative since they have been inferred from the situations described.
The problems in this area at STP were, for the most part, in the Cadwelding area and to a lesser. extent in concrete placement.
Several points seem evident from this problem at STP (and other recent cases):
1) it is doubtful that most of the record falsification problems would have been detected had it not been for allegations ; 2) the same, or similar problems, are likely to exist to some extent in other construction 'reas b't without allegations they probably will go u
undetected
, 3) if the above is correct, new inspection /
-investigat methods and techniques are needed to reduce and control this problem.
Regarding item b, QC Inspectors Threatened and Undue Pressures Applied, the first allegation occurred in July 1977; two followed in 1978 and the rest (9) were made in 1979.
All were the subject of investigations.
The last series of eight occurred in late 1979 and prompted the special investigation (79-19).
The record is quite clear that the basic cause behind the problem stemmed primarily from pressures to move plant construction along or prevent furth'er delays.
There is evidence that animosity built up between QC and construction forces for'various reasons, some of which were:
QC inspectors felt they were doing in process inspections normally done by construction workers; QC inspectors were not given sufficient time to complete their inspections l
before the next work phase was scheduled to start; some QC inspectors lacked proper training and qualifications in the areas they were assigned to inspect; and there were repe&ted instances when
-QC inspectors were overruled by their own supervision.
Item c above, Inadequate Support for QC Inspectors, is listed as a separate problem; however, the relationship this set of allega- -
3.
Routine Insoection Coverage There is good IE inspection procedure coverage of the problem areas indicated by the 79-19 investigation findings and the results of-the licensee's Special Task Force on Safety-Related Welding as shown in Appendices 2A thru 2E.
However, the degree to which the procedures, if implemented, would have turned up the same, or similar, problems is thought to be strongly influenced by the experience, practical knowledge and technical depth of the inspectors,.
This is especially the case in the problem areas listed in Appendices 28, 2C, 2D and 2E.
In the routine inspection areas having to do with determining the
' qualifications of welders, NDE personnel, and QC inspectors, there appears to be a problem of knowing where and what to look for.
It~was noted tnat the routine inspections did find unqualified personnel; and the investigators (79-19) identified unqualified
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personnel, but for different reasons.
Also, those involved in the licensee's task force on wela.ing found unqualified welders and NDE personnel in yez other areas of their qualification requirements.
-The routine IE inspection program, as evidenced by the inspection reports, enforcement actions and unresolved items as shown in Appendix 3, identified few, if any instances of 1) record falsifi-cation,2) undue pressure, intimidation or threats against QC inspectors, or 3) inadequate support for QC personnel.
The
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inspection record shows that with the above exceptions, the routine inspection program at STP did provide general coverage in the problem areas' identified
.0ne-new inspection procedure has been issued, 35061B, effective 4-1-80, that contains a requirement for private meetings with QC
-inspectors.
This requirement may help bring to the surface earlier the type of concerns that personnci at STP came forth with in the form of allegations.
This procedure also includes inspection points dealing with incompetent craftsmen and foremen,. independence of QC inspection activities, adequate treatment of reported nonconformances, trend analysis of nonconformances and the effectiveness of the licensee's audit program.
These inspection areas cut across many of the problem areas that surfaced at STP in the form of allegations.
~4.
Reco'mmendations To make the IE program more sensitive and discriminating it is recommended:
1 a)
That special procedures be issued to provide detailed i
guidance on the investigation and followup of allegations.
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c e
b)
That the task of investigating allegations, of the STP variety, be assigned to investigators and other skilled inspectors that are not routinely associated with the plant's inspection effort.
c)
That inspection guidance be provided to require licensee corporate representation at exit discussions at a level above site managers and supervisors on a periodic basis and more often when it is apparent that persistent problems are not being promptly corrected.
d)
That guidance be provided to re-emphasize the importance of drafting citations to ensure, where appropriate, that indi'vidual items of noncompliance are viewed by IE as symptomatic, with possible broader implications; that will require licensee review and possibly corrective action beyond the single item of noncompliance.
e)
That existing procedures, such as 35060B and 35061B and perhaps other licensee performance appraisal pro-cedures, be modified to require a more in depth analysis of licensee's enforcement history (and allegations) to determine if trends are apparent that might indicate specific areas of weakness, QA/QC inadequacies or management difficulties.
f)
That the whole problem of records falsification be examined by IE.
This effort could include matters such as its potential impact on quality, relative sensitivity of areas involved, IE's capability to
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detect falsification, need for added inspector awareness, new skills and techniques to deal with it.
g)
That efforts be made to enhance IE's capability to detect unqual,ified craftsmen, NDE personnel and QC inspectors.
To sharpen the IE inspector's skills i.n this area, special training sessions conducted by certification specialists should be considered.
The potential for local shortages of skilled workers and fully trained technical staff in the area where plants are to be constructed should be recognized early and inspection emphasis provided to deal with the problem at the onset.
Attachment A CHECK 0F MAJOR CONSTRUCTION CASES 1.
List the basic cause for each of the significant problems identified as a result of. allegations and the investigation (s) which followed.
(Include other big problems which were identified "too late" as a result of even.ts or licensee investigation.)
2.
Determine if the defined inspection program (IE Manual) could have identified the problems and their basic cause.
Make a list showing for each problem an assessment of the ability of the present program to identify the basic cause.
3.
Determine if the routine inspections which were made identified any of the problems.
Make a list showing the extent of identification.
(Prior to any discussion with Regional personnel on this item, talk to Moseley, Taylor, or Bryan. )
4.
Develop recommendations for program modifications (including enforcement, Event Report followup) to make program more sensitive and discriminating.
Source Documents
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(1)
Inspection Reports (2)
Investigation Reports (3) ~ 10CFR 5'0.55, 10CFR 21 Reports (4)
Enforcement Correspondence and Responses (5)
Inspector Evalua' tion Reports (if any) t i
p Appendix 1A Problem Areas Identified or Indicated As a Result of Allegations and The Investigations that Followed a) Records Falsification and QC Documentation S*
- PTL_ reports falsified to show tests were done(1**
77-03 NS
-CadweldrecordsmadetoghowQCinspectionswere done when they were not 78-09 NS
- Inaccurate Cadweld as-builts drawings (2 78-12 NS
- Cadweld locaticn sketch lacks sufficient data (2 78-15 NS
- Excessive time (6 weeks +) to record Cadweld date 78-15 NS
- Construction personnel gcord Cadweld locations instead of QC personnel 78-15
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- Cadweld locations shown 'at wrong elevation (2 78-15 NS
- Cadweld powder lots and sleeves not traceable (2 5
- Cadweld examination checklists changed prior to being stored in records vault 79-01 NS
- Data on " duty copies" of examination checklists not transferred to record copies 79-01 NS
- Cadweld preignition inspection records falsified 79-01 NS
- Cadweld records are all " screwed up," much
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" whiting out" a'nd signing off of ECs and as-builts(2 79-01 S
-CadweyacceptedalthoughQCrecordsshowexcessive voids 79-01
- S = substantiated, NS = not substantiated
? = neither confirmed or refuted see end of list for nunbers of IE proceudres that may call for inspection coverage.
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e 1A '
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-continued-
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-Therearewidespreaddiscrepaggiesindocumentation of Cadweld as-built locations 79-09
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- Cadweld inspection reports were signed by QC inspectors who= bad not performed the inspections 79-14 S
- One hundred sixt{gn (116) Cadwelds could not be accounted for 79-14 NS
- Some completed Cadweld inspections forms left hanging on field shack wall and not submitted to QA records 79-14 S
- Inspection report showed an entry by a person other than the inspector actually responsible for the report
'79-14 S
-Traceabilityof(gmbeds.islostafterleavingB&R Receiving group 79-19 5
- QC inspector falsified concrete curing records 79-19 S
- Surveillance Deficiency Report of B&R was changed for no apparent reason and concret audit schedule waschangedfornoapparentreason(3 79-19 Possible IE Inspection Procedure Coverage
. 1) 45055B 2) 470538, 47054B, 3) 35100B i
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1A b) QC Inspectors Threatened, Undue Pressures (1
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- Civil QC inspector threatened with beating by B&R construction foreman 77-08 NS
- B&R signs paychecks implying QC should not hold up construction 78-12
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- QC inspectors expected to do in process inspections of work besides their own 78-12
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- Two B&R QC inspectors were intimidated by five B&R construction workers 79-14 S
- QC/QA personnel told that-their supervisors know if any inspector talks to NRC and that NRC is tired of STP complaints 79-19 S
- QC inspector was threatened by general foreman 79-19 NS
- QC inspector was threatened by construction worker 79-19 NS
- QC inspector was threatened by carpenter 79-19 S.
- QC inspector was threatened by general foreman with harm 79-19 5
- QC inspectors told that if they talk to NRC they will be fired 79-19 S
- QC inspectors,are taught not to expect any support from supervisors 79-19 Possible IE Inspection Procedure Coverage 1) 47051B and 351008 includes inspection areas on independence of QA/QC.
Procedures 35060B and 35061B (effective 7-1-80 and 4-1-80) include coverage of this problem area
l lA c)
Inadeauate Support for QC Inspectors (2 NS
- QC civil inspectors lack technical assistance from QA engineers 78-12
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- Inaccessability to upper management 78-12
.S
- Concrete pour card signed off by supervisor after QC inspector refused to sign it.
79-09 S
- QC inspectors have lost support of their supervisors when inspectors are confronted by construction personnel 79-19 S
- QC inspectors do not have immediate communications (by radio) with their supervisors.
Supervisors refused to supply radios 79-19 Possible IE' Inspection Procedure Coverage 1) 47051B and 351008 includes inspection areas that may have detected
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this problem area.
Two new procedures, 35060B and 35061B were made effective on 7-1-80 and 4-1-80 which includes more definitive inspection requirements regarding problems with QA/QC effectiveness.
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d)
Procedural Violations f15
-QCholdpyntsliftedbyconstructionorlicensee personnel 78-09
- Performance of repairs without procedures (3 78-12 f15
- Unqualified helpers doing Cadwelding(2 78-15 NS 5
- Cadweld centering marks made after firing of Cadwelds 78-15
- Lack of segnd shift QC inspection coverage for 5
Cadwelding 78-12
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- Cadwelding is done-during wet weather 78-15
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- Waterproofing membranes installed without proper QC inspection 79-14 S
- Holes in concrete walls resulting from removal of tapered form ties not filled with grout 79-14 5
- QC inspector instructed to disregard a stop-work notice and syn a concrete pour card in violation 79-14 of procedure NS
-Voidinconcretewasnotgepairedinaccordance with approved procedures 79-14 S
- General foreman knowingly violated concrete specifi-cation on freefall and lateral movement 79-19 5
- QC inspector and construction personnel agreed to pour 24 inch lifts instead of 18 inch lifts as specifications require 79-19 5
- Concrete foreman left while pour was in progress and placement crew would not correct procedural violations with pour 79-19 S
- Vendors used markers containing halogens on stainless steel and stored stainless with carbon steel 79-19
'S
- Nonconformance Reports (NCRs) procedures not followed in that flCR drafts are not numbered (serialized), only approved NCR are serialized 79-19
1A
-continued-S
- Cadwelders were not requalified as required by byQC((cationwhere2of15spliceswererejected speci 79-19
-Partofcontainmentshellwallconcreggpourwas S
not totally inspected for cleanliness 79-19 Possible IE Inspection Procedure Coverage 1) 47051B and 35100B includes inspection of the QA program elements pertinent to this problem, but a more direct procedure, 35061B was made effective on 4-1-80 which is more direct in inspecting for this problem.
2) 35061B effective 4-1-80, 470538 and 47054B in some areas.
3) 47051B 4) 470538 6
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T c-1A e) QC Insoectors/ Workers not Qualified E
NS.
- QC inspector couldn't reapy {yil drawings - failed c
test records not in vault 78-09 NS
- Not' sufficient time to study new procedures 78-12
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- B&R foreman can neither read nor write (2 78-15 Possible IE Inspection Precedure Coverage 1) 35100B (qualification procedure requirements) 2)'
35061B (effective 4-1-80) e W
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lA f) 'Nonconformance Reporting System Inadequate NS
-QCinspectorsencounteredresista.nce({rggQAto process nonconformance reports (NCR) 78-12 NS'
- NCR were rejected for no reason (2 78-12 NS
-QCinspectorsinst{gctednottosubmitNCRson valid deficiencies 78-12 S
- Large number of nonconformance reports about maintenanceofstorggequipmentarebeingfil.ed away with no action 79-19 Possible IE Inspection Procedure Coverage 1) 351008'(requirement for procedure) 2)
35061B (effective 4-1-80) 4 8
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lA g) Document Control Problems NS Control (gf drawings and documents used by crafts is poor 78-12 S
- Cadweld location sketch lost (1 78-15 Possible IE Inspection Procedure Coverage 1) 35100B (requirement for procedure) 2)
350618 (effective 4-1-80)
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1A h) Miscellaneous NS
-QC inspector. attempted to bribe B&R construction 78-14 person
.Only 3 QC civil inspectors do-Cadweld inspections (1 78-15 S
S
- Unit 2 structures mislocated.by one foot from 78-15 position on ' drawings NS
- B&R QC inspectors involved in continuous card 79-14 games S
- Concrete foreman stated that construction practices were worse on previous pours causing significant 79-19 voiding NS
- Former B&R employee sent a memo to B&R management stating he had information that would make current 79-19 NRC investigtion "look like a picnic"
- Cracks exist in structurh1 steel chip in boron 79-19 injection room
--Pipe sleeve weld in containmnet building contains 79-19 a defect 4
Possible IE Inspection Procedure Coverage 1) 470538 S
- not investigated
n Appendix 1B Probable Causes for Problem Areas Identified as a Result of Allegations and Their Investigation
)
a)
Records Falsification and QC Documentation Problems There were 21 separate allegations falling within these two general - but related - areas.
Nine of the allegations were substanticted; ten were not and two were neither substantiated nor refuted.
Some basic causes for these problems could ae:
failure to follow l
procedures explicitly, insufficient time to do job correctly, lack of job diligence, poor attitude and ind'fference to NRC requirements.
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'b)
QC Inspectors Threatened - Undue Pressures Applied There were 12 separate allegations falling within this area.
Six were substantiated; three were not and three were neither substantiated nor refuted.,
The most obvious basic cause for this group of problems stems from production pressures.
However, the record' indicates that animosity built up between the inspectors and the construction forces for various reasons:
Friction occurred because QC inspectors were expected to do routine in process inspections as well as their own.
- Also, pressures occurred when QC was not allowed enough time to complete their inspections.
There is evidence that some QC inspectors lacked proper training and qualification in the areas they inspected.
Repeated instances of QC being overruled - some valid, some not -
contributed to this problem.
c)
Inadequate Support for QC Inspectors There were five allegations with this problem area.
Three were substantiated; one was not and one could not be verified or refuted.
It is believed that the basic causes for this problem area are three-fold:
unqualified QC inspection personnel, support for QC positions in contention with construction often lessened or faded away as the issue moved to higher levels of management; i.e., lack of organizational freedom and management attitude as exemplified by the B&R brochure, titled, " Implementation of the B&R QA Program at STP Jobsite."
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1B d)
Procedural Violations There were 17 separate allegations involving procedural violations, most of which derlt with concrete and Cadwelding activities.
Eleven allegation were substantiated; four were not and two were neither substantiated nor refuted.
Production pressures are believed to be the major cause for this group of problems.
Other.
factors that appear to have contributed are:
disagreement with part, or all of the requirements called for in the procedures, indifference to procedural requirements and a poor attitude with respect to having to do most everything by procedure.
e)
QC Inspectors and Workers not Qualified There were three allegations in this problem area; none of which-were fully substantiated.
Even though investigators were not able to substantiate these allegations, it is generally acknowledged that the conditions alleged did exist.
Lack of an experienced and trained pool of workers to draw from, lack of adequate trainin'g before being placed in the job for various reasons are believed to be the major causes behind this problem area, f)
Nonconformance Reoorting System Inadequate
.There were four allegations in this problem area.
Only one was substantiated, leaving three not substantiated.
The nature of three of the allegations - although not substantiated -
leads one to conclude their basic cause to be related to construction pressures.
Another cause, thought to have played a part in this area, is that some reported nonconformances were thought by some not to be valid for various reasons or were minor concerns not worthy of documenting.
g)
General Document Control Problems There were two allegations in this area; only one was substantiated.
The basic cause for reported problems in this area appears to have been inattention to procedural requirements by clerical personnel, sloppy ~ record keeping practices, or a failure to appreciate the need - which may translate into inadequate training practices.
e e
1B
.h)
Miscellaneous Eight allegations were placed in this-general problem area.
Three were substantiated; three were not and two were not investigated.
Do to the varied and unusual nature of these allegations no attempt was made to identify a basic cause.
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t Appendix IC Significant Eroblems Identified by Licensee Ta'sk Force Related to Welding Practices and Basic Causes l
1.
Qualification files for 21 of 70 NDE inspectors had various irregularities in qualification.
The 21 cases identified involved the following:
uncertified personnel performing NDE, no recertification after rehire, inspector signed as being certified at higher level and absence of eye exam or re examination.
l 2.
Nine of twenty-one NDE inspectors' documentation showed insufficient training and/or experience.
The basic causes for the above'two problems are believed to be a shortage of experienced and fully qualified persons available for hire, coupled with a high turnover rate.
Inadequate contractor training programs also contributed to the overall problem.
3.
Twenty-four percent of the radiographed welds previously accepted were considered unacceptable because of improper identification, penetrameter documentation, rejectable indications, or lack of required sensitivity or density.
' 4.
Fourteen of forty-three socket welds re examined found to have unsatisfactory conditions.
5.
Six of thirteen pipe butt welds revealed surface indications.
6.
Of seventy-nine Category I AWS structural steel welds examined, sixty-one had irregularities such as contour, overlaps, arc strikes and undersized welds.
The basic causes for items 3 through 6 appear to stem from conditions such as lack of fully qualified or experienced NDE and welding inspec-tion personnel.
Also, one cannot rule out the possibility that production pressures may have played some role in bringing about a lenient weld acceptance policy.
7.
AWS Category I shop and field erection weld documentation indicated:
a lack of adequate traceability, lack of assurance all quality checks were done, lack of assurance that all welds were in.:eed documented and a lack of assurance that welders were always welding within the-limits of his qualifications with respect to positions.
l L.
1C Assigning a likely basic cause for the above problem is most difficult without having examined the particular documents.
8.
Welder performance qualifications for ASME piping and Category I structural steel (by radiography) showed that film side penetrameters were used rather than source side penetrameters during RT of welder test coupons and that less stringent ASME acceptanc.e criteria were used instead of the required AWS criteria.
9.
Some inconsistencies were noted regarding the effectivity dates of various codes and standards.
It would appear that the basic cause for the above two problems rests primarily with the Welding Engineer's performance in his job.
The Welding Foreman, a;so, would be expected to have caught this deficiency.
Inadequate QC surveillance contributed to this problem at some point.
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Appendix 2A Review of IE Investigation Report (79-19) for Routine Inspection Coverage of Concrete Activities Investigation Findings Relevant IE Procedure Poor vibrator practice, 47053B, 2.f insufficient lighting at night 470548, 2.f Rebar ties not wired in place 470538, i,b; 4.d, 47054 8 1.b Insufficient number of preplace-470538, 2.f ment inspectors, poor scheduling 470548,.2.f of work Failure to take remedial 351008, 7.a action on identified problems
'470538, 1.c (goncrete pours)
Pumped concrete sampling point 47053B, 2,e, not as per specifications 470548, 2.d.
B&R inspector qualifications 351008, 1.b
. requirement lack adequate 47056 B, 1.b (5) experience levels Five B&R and three PTL inspectors 47056 B, 1.b (5) lacked required experience for certification; however records showed them to be certified
Appendix 28 Review of IE Investigation Report (79-19) for Routine Inspection Coverage of Soils Activities Investigation Findings Relevant IE Procedure Backfill procedures do not 351008
. specify depth of certain required
- 450518, tests 450558, 5.c Failure to complete backfill
~450558, 1.b compaction (8 vs 23 passes) as 450558, 5.b pei procedure Failure to take relative density 45055B,' 1.d tests as per procedure
'450558, 5.c l
l, Failure to take prompt corrective 450558, 1.e.
action'to replace defective soil
. test equipment l'
Failure to document lift thickness 450558, 5.b and number of compaction passes per procedure Failure to use correct weight
- 45051B, hammer specified in soil test 450558, 1 procedure Failure to identify deviations 4.5051B from ASTM specifications refer-enced in procedure
Appendix 2C Review of IE Investigation Report (79-19) for Routine Inspection Coverage of Welding and NDE Activities Investigation Findings Relevant IE Procedure QA Manual' completely outdated 351008, 8
(_'76 vs '79) 35200B, 1.d.(1)
Improper methods used to qualify 550558 welders (making of specimens) 55065B Improper radiograph technique 55055B
'psed to qualify welders (location of.penetrameters)
Welding in unprotected areas and 550538, 2 under generally dirty conditions Absence of required weld records on 55051B, 2.h-structural steel hangers and clips 550558, 1,2,3, 490538 Design changes made prior to review 351008, 3 and approval requirements 35200B, 1.e (3)
Liquid penetrant examination not
,55055B, 4 evaluated according to requirements 55061B, 2 InadequateprocedurescovEring 550518, 2.J radiograph traceability, acceptance 55065 B criteria, dark room practices, final 550718, 2.J x-ray film quality Failure to detect and record reject-55071B, 2.d able defects noted on radiograph of 49053B, 3 pipe welds 55061B, 2 Welder. qualification test coupons 55053B did.not meet minimum quality 55061B, 2 requirements of ASME.
Film inter-pretation faulty.
Radiographers qualified as Level I,
- 48051B, II, and III had not been adequately 55051B, 2.e.
trained as. film interpreters 55073C, 2.c
}.
Appendix 20 Review of Investigation Report (79-19) for Inspection Coverage of Activities Related to Project Audit Systems,
. Surveillance Systems and Control of Nonconformances Investigation Findings' Relevant IE Procedure i.
No effective program to review, 351008, 7 analyze NCRs, ECs and FREA for trending purposes and correction
^
lof' repetitive problems
- HL&P and B&R failed to require or 351008, 2 perform supplemental audits when 35200B, 1.d. (6) j' conditions indicated a need HL&P failed to audit site QA-
'351008, 2 functions to the depth necessary 352008,l.d.(6)
L, and in areas required by procedures t
B&R failed to audit B&R site QH/QC 35100B, 2 acti'ities to the depth required 352008,1.d(6) v
~
and at frequencies (supplemental) l, indicated by repetitive deficiencies
- Civil surveillance activities were 35100B, 10 l.
not properly documented as required by procedures u
)
Upper management was not advised of 351008, 7 failure to take action on
- repetitive 35200B,1.d(6) deficiencies in B&R. surveillance in accordance with requirements 1
-\\_
j j
t 4
L
.mm.
-continued-Task Force Findings Relevant IE Procedure s
10.
Some inconsistencies were noted regarding 351008, 3 & 4 codes and standards effectivety dates 55051B, 2 IE investigation 79-19 observed this deficiency.
Problem area adressed in these IE reports.
6 e
S 9
C
e Appendix 3 Review of Routine STP Insoections to Determine Extent to Which Problems Areas Were Identified The Same or Similar Problem Identified IE Report Enforcement Lack of procedures to control 74-01*
field design changes (B&R) 74-02*
75-01*
75-02*
yes Indoctrination / training and 74-01*
qualification of personnel-procedural deficiencies Qualification of QA auditors 74-01*
74-02*
Foundation soil densities lower 76-02 UI**
than expected HL&P failed to perform scheduled 76-02 UI audit B&R did not follow procedure on 76-03 yes vibrofloation work Problem about verification and 76-06 UI record keeping of rebar installation Unqualified welder used on contain-76-07 yes ment liner - lack of procedural control Construction procedures for Cadwelding 77-05 yes not followed QC procedures for Cadwelds not followed 77-05 yes Problem with transposition of data 77-05 no on QC records predocketing/ preconstruction inspections
- unresolved item O
e
-e.
a I
3
-continued-The Same or Similar Problem Identified IE Report Enforcement Surveillance of earthwork not 77-06 yes done as required by schedule Unqualified QC personnel used 77-06 yes on concrete work Problem with signoff of QC records 77-06 UI on concrete Problem with weld seam buildup.on 77-07 UI containment liner Un~ qualified QC inspector used on 77-09
.yes concrete work (repeat item)
Problem with lack of followup on 77-10 UI HL&P internal audit findings
~
QC audit records not maintained 77-12 yes by HL&P - no audit check list Audit not performed by Design 77-12 yes Review Committee Failure to follow procedures 78-01 yes during concrete placement -
cold weather precautions a'nd improper vibrating Problems with UT procedure on 78-03 UI special weld Failure to follow procedures for 78-04 yes control of welding (POM)
Problems noted with verification 78-04 UI of soil compacticn r ilure to provide revised drawings 78-07 yes a
fcr containmen
s-
..1 3
-continued-The Same or Similar Problem Identified IE Report Enforcement Problem noted on auditor 79-13 UI certification (earlier problem noted in 74-01 and 74-02)
ProblemnotedwithPDMinshection 79-13 UI
~
personnel. qualifications - no minimum standards Problem noted with questionable 79-13 UI Level II qualifications - Cadwelding activities (earlier problem noted on 78-17)
Failure to follow concrete consoli-79-15 yes dation procedure-(vibration work)
(repeat of 78-01 problem)
Problem with excessive water in 79-16 yes concrete forms (earlier problem in 79-04) t 9
s*
BRIEF OVERVIEW - ZIMMER Significant Problems
'Q.C. Documentation Procedure violatioris Nonconformance Reporting System Deficiencies in drawings, specifications, instructions and procedures (both Q.C. and construction)
Material control Licensee audits / corrective action
- Same or similar general problem areas as observed at South Texas.
A.
' General Observations 1.
Zimmer construction has been extremely drawn out.
CP issued in 10/72; scheduled completion 1/77.
May be 5 years over schedule if latest estimate of plant completion is correct.
2.
Therewere(upto1/81)atotalof13inhestigations. These investigations, from the record, apptar to have been thorough.
They addressed the allegations in depth and dealt primarily with QA/QC problems.
In retrospect, only one investigation (78-18 in August 78) stands out as an indicator of possible future problems of the type addressed in the draftinhestigationreport81-13.
3.
TheinspectionandinhestigationrecordforZimmer,whencomparedto South Texas (STP), shows similar major problems with QC documentation, proceduralhiolationsand,toalesserextent,aninadequatenon-conformance reporting system.
4.
In addition to those problea areas noted in three (above), the record indicates significant problems at Zimmer with a) inadequate specifications, F o/ A - 8 t d 'l3 1
L%
L
f' e
' instructions and procedures (both in construction and QC);
b) material control,f c) licensee and constructor audits / corrective action.
5.
The inspection coverage at Zimmer appears to have been extensive and comprehensive. All inspection areas appear to have been covered - some perhaps to an extreme.
6.
Early inspections (up through 1976) at Zimmer appear to have been -
in line with the IE inspection program.
However, during 1977, 1978 and 1979 inspector-hours per year (600 to 1200) for construction appear to have exceeded significantly the hours contemplated by the IE program (400-500). Also, during 1977 through 1979 between 12 to 16 different, inspectors contributed to the construction inspection effort during one year.
(Hormally, three to six different inspectors are thought to,be sufficient for adequate coverage.)
7.
There were early signs of problems with the licensee / constructor audit programs.(73-03, 75-03, 77-02). More recently, other audit program weaknesses showed up during the first part of 1979; largely evident in areas under Sargent-Lundy control such as design of pipe hangers / rest,raints and suppression pool modifications.
In this connection, a significant number of enforcement items in the latest draf t investigation report (81-13) appear to stem from inadequate licensee /
constructor audits of contractor work.
For example, five audit reports are cited as cases where CG&E had'not followed up on deficiencies found during their audits of S&L.
8.
The impression is left after reading the Zimmer file that Sargent and Lundy had fallen down in several critical areas at Zimmer.
This could indicate that SLL was not adhering to their established QA program.(topical rsport SL-TR-1A) en Zimmer, or possibly en other plants i
S&L is werking cn.
Questions arise as to what, mechanism is employed to alert Region IV of such problems when they occur and what actions have been taken en a generic basis with the other five plants (10 reactors)
S&L is listed as ALE.
o.
9.
The inspection / investigation record at Zimmer does not indicate that QC inspector intimidation or harassment was a problem.
There was one instance mentioned where QC inspectors were doused with water;anotherinYolvingasearchbysecuritypersonnelandathird incident in which an inspector was going to be fired but was not.
10.
The record shows numerous instances of enforcement citations in the areas of QC documentation, procedure violations, materials control and most notable - deficiencies in instructions, procedures and specifications.
These areas appear to be, in large part, associated with KEI's role as plant constructor.
Perhaps KEI's relatively limited experience with commercial nuclear plant construction, coupled with the fact that Zimmer is the first nuclear plant for CG&E, is_at fault here.
11.
The notices of violation sent to the licensee were obserhed to be limited to the item of noncompliance with little. if any,1lnference that the instant concern may be indicative of a larger more pervasive problem that should be looked into and corrective action taken if warranted.
B.
Recommendations 1.
It is recommended that the IE Inspection Program place additional emphasis on inspecting licensee / constructor audit programs (Criterion XVIII) at an early stage of construction and that periodic reappraisals be made to insure that licensees / constructors are indeed making the required audits, that appropriate corrective actions are implemented and when necessary, followup reaudits are performed and documented.
2.
In connection with the above, it is recommended that IE consider the need to draw an inference, both through inspector contact and written enforcement language, of the probability that there is a " linkage" between certain items of noncompliance and weaknesses in the licensee /
constructor audit programs.
Furthermore, it may be appropriate in many
/
,e
, ;e,
4_
enforcementcasestorequestlicenseetoehaluatetheirauditprograms and if indicated, make commitments to increase their audits in identified
. problem areas in addition to correcting a particular item of non-compliance.
3.
It is recommended that the design problems encountered at Zimmer and which appear to reflect adversely on Sargent and Lundy be studied to determine if they are generic in nature or isolated to Zimmer.
Additionally, it appears that the inspection roles between Region IV and the other regions need to be clarified with regard to A&E firms to insure that problems found at one plant can be prcmptly looked into as well as addressing the possible generic aspects.
'4.
It is recommended that existing IE inspection procedures, and other performance appraisal procedures, be modified to require a more (and perhaps earlier) indepth analysis of licensee's enforcement history to determine if trends such 'as procedural hiolations in drawings, procedures and specifications and licensee audit programs, are apparent and which may require added licensee attention and IE inspection coverage.
9 0
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