ML20138J333
| ML20138J333 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/18/1985 |
| From: | Elias E, Fischel D CHICAGO, UNIV. OF, CHICAGO, IL, HOUSTON LIGHTING & POWER CO. |
| To: | |
| References | |
| OL-I-CCANP-092, OL-I-CCANP-92, NUDOCS 8510290317 | |
| Download: ML20138J333 (10) | |
Text
A ~ $Y Y?? 0 d-
[- $0kgf fg 7/7/fC D"V77 NO. 81-H-0686-C i
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- I HOUSTON LIGHTING & POWER S
r-COMPANY, INDIVIDUALLY AND S
c-
-c I
AS PROJECT MANAGER UNDER S
I THE SOUTH TEXAS PROJECT S
PARTICIPATION AGREEMENT S
l BETWEEN THE CITY OF SAN S
IN THE DISTRICT COURT OF i
ANTONIO, TEXAS, CENTPAL S
POWER AND LIGHT COMPANY, S
MATAGORDA COUNTY, TEXAS HOUSTON LIGHTING & POWER S
r COMPANY AND THE CITY OF S
130TH JUDICIAL DISTRICT l
S S
Plaintiffs S
VS.
S S
S S
Defendants S
PLAINTIFFS' SPECIFICATION OF CLAIMS AND ISSUES 87 M umisano.
OF COUNSEL g,,,,
FOR ALL PLAINTIFFS:
cineral trn, n.j LFgg Daniel R. Fischel start
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University of Chicago ag3 taririto V
School of Law
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Counsel for All Plaintiffs roa, ",
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Erwin Elias r4*f f Baylor Law School
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Counsel for All Plaintiffs,,,,,,,, y g
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w 8510290317 850718 (DR ADOCK 05000498 4>
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i S.
CCNCEFl!NG INGINEERING AND ENGINEERING MANAGEMENT l'
31.
Fr = 1973 to 1981 S&R progress in engineering was not sufficient to support either the Centract schedule or a reasonable completion date for STP.
32.
By July, 1981, E&R, despite over eight years of opportunity, had completed less than one-half the engineering necessary to complete STP.
l' 33.
B&R was unable to perform the engineering for STP in a manner consistent with the standards agreed to by S&R in its contract because:
a.
B&R corporate officers and managers lacked experience in nuclear design and construction; b.
E&R failed to attract and hire ccrporate officers and managers with the skill and expertise necessary to comple e STP.
< f.
c.
B&R did not employ a sufficient number of seasoned engineers and engineering managers with nuclear experience to overcome S&R's lack of experience;
.d.
B&R Engineering Management failed to properly and adequately define the scope of the project, to accurately estimate the engineering necessary to complete the job, and to plan, organize and manage the engineering effort to complete the design of STP.
u e.
B&R engineering management. failed to l
implement effective interdisciplinary
'c coordination and systems integration; T
f.
B&R Management failed to properly coordi-nate and schedule engineering, construc-tion and quality assurance activities necessary to complete STP; g.
E&R engineers and engineering managers were unable to solve technical problems necessary for licensing and completion of the design; i
FICXC6C/018A01 L
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h.
S&R was unable to retain the few officers and managers who had any nuclear experi-l-
ence at all;
(
i.
S&R failed to prepare and issue speci-fications for engineered equipment in a timely manner necessary to support timely ccmpletion of the STP design; j
j.
S&R failed to exercise proper management and coordination of engineering subcon-tracts, which was vital to completing the STP design; k.
B&R engineering failed to provide ade-quate technical support of the procure-ment process to ensure timely receipt of vendor engineering vital to completing final design.
(
l.
ESR failed to anticipate and acccmmodate normal evolution of the design and design
- Q changes resulting from B&R design changes, vender changes, regulatory changes and Owners' preferences; E&R engineering was unable to produce m.
usable final design to support needed constructien; n.
B&R engineering management failed to properly review and verify the design to ensure that changes were made and that the design was adequate and licensable; o.
B&R failed to accommodate its efforts to foreseeable changes attributable to the fact that STP incorporated a new Westing-t.
house reactor model with a number of r
unique design features, all of which were well known to B&R when it signed the Contract.
It is part the job of an A/E to plan for and accommodate design lV changes in an orderly and efficient manner; B&R failed to do this part of its job.
L FECXC6C/CISA01 i e
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'i p.
ESR failed to update design decisions and design documents as changes occurred or new information, such as new load infor-mation, became available; q.
In 1981, B&R refused HL&P's direct and d
urgent requests to replace inexperienced top corporate officials with individuals experienced in nuclear design and con-struc. ion; r.
B&R consistently gave owners information r
concerning its engineering ability and I
progress which proved to be and was inaccurate.
34.
S&R's failure to perform engineering services necessary to complete STP in a manner consistent with the professional standards agreed to by B&R r
in its Contract is not excused by external factors beycnd E&R's reasonable control.
4:s 35.
B&R's failure and inability to perform the engi-9 neering work in a timely and effective manner ad-versely affected those activities necessary to purchase engineered items of equipment to be used at STP.
E&R's engineering failure contributed to delays and difficulties in the procurement activity in the following respects:
I.
B&R Engineering failed to prepare speci-a.
fications for engineered equipment and subcontracts in a timely manner.
B&R engineering failed to meet B&R's own i
established schedules for the issuance of these specifications.
This failure was f
concealed from owners and caused delay at STP; g-b.
B&R Engineering failed to prepare techni-cally adequate specifications, making it difficult or, in many instances, impossi-ble for EL&P to promptly review and g
approve the specifications.
This techni-7 cal inadequacy necessitated changes which created confusion and delay in the procurement activity; FECXO6C/018A01.
I l
c.
B&R Engineering failed to prepare adequate bid evaluations and bid recommendations B&R Engineering failed to provide timely turnaround on vendors' submittals (i.e.,
drawings, system design reviews, and i
software);
d.
B&R Engineering failed to develop infor-mation needed by vendors in a timely i
manner (i.e.,
drawings, specifications and changes);
i e.
B&R Engineering failed to resolve non-conformance reports, corrective action reports and field requests for engineering assistance in a timely manner; f.
B&R Engineering failed to submit material requisitions to the purchasing or subcon-
[
tracting groups, or submitted them belatedly;
(&%
g.
B&R Engineering prepared inadequate i N documentation to support material requi-sitions; h.
B&R Engineering directives affecting the scope of purchase orders and subcontracts directly to vendors adversely affected cost and schedule.
i 36.
B&E was unable to manage and coordinate engineer-ing, construction and quality assurance activities.
B&R officials with authority to perform this function had little or no experience in nuclear management, i
design, construction or quality assurance, and did not have the background, skill and expertise needed.
B&R officials with authority to perform this function t.
received inadequate support from B&R's top management.
f, Although HL&P insisted that B&R replace these persons with qualified experienced personnel, B&R refused to do so.
}p; 37.
In 1981, B&R's efforts at system design review od' began to disclose serious design deficiencies.
Those deficiencies were the result of B&R inexpe-rience and poor B&R engineering management.
FECXO6C/Ol8A01 i i
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l 35.
3y September of 19S1, B&R was at least two years 8
behind the 1979 Baseline and significant redesign was indicated.
I 39.
ESR was unable to adapt to and accommodate changes which were reasonable and foreseeable during the design and engineering life of STP or any nuclear pcwer plant.
40.
3&R's inability to adapt to and acccmmedate design f
changes prevented B&R engineers from completing the design of STP in time to support critical con-struction.
41.
B&R's inability to plan for and acccmmodate design changes, its lack of experience in the design and construction of nuclear power plants, its failure to recruit a sufficient number of experienced en-gineers with nuclear engineering experience, its peer engineering management, its insufficient plan-ning and coordination of design activities, its failure to have procedures adequate to ensure inter-disciplinary coordination, its failure to update preliminary calculations and engineering analysis, and its failure to review and verify plant design, all are demonstrated by the following specific examples of deficient B&R engineering performance:
a.
Cable Trav Routina and Succorts.
B&R's use of seventeen separation groups and its concept of "related circuits" com-plicated the task of providing and implementing electrical separation and hazard protection required by NRC regu-lations.
As a result, B&R never completed the design and never implemented either i
requirement satisfactorily.
This failure
}.
demonstrates B&R's lack of nuclear L
experience and its inability to acquire and use engineers with adequate experi-i ence to perform the job.
The B&R design L
caused needless congestion and interfer-ences, making construction, cable pulling and electrical terminations extremely difficult.
B&R's cable tray support design effort evidences coor design process and resulted in cesigns that had to be re-verified and redene.
- Overall, t
FICXC6Cf013A01 _
)
3 B&R's cable tray routing and support design was not timely and could not support construction; b.
Cable Cacacity.
B&R's overly conserva-
- ve derating factors resulted in over-sized cables, which further aggravated the cable tray routing design problems; r
c.
Plant Electrical Distribu* ion Svstems.
f B&R's failure to update bisic calcula-I tiens as electrical loads grew resulted
[
in undersized unit auxiliary transform-ers, unit standby transformers and emergency transformers.
As a result, major plant electrical system functions had to be redesigned and unit auxiliary transformers had to be replaced.
E&R's failure to update loads and margins in basic calculations shows poor interdisci-plinary coordination, poor engineering management and practice.
As a result of
- y.,
these failures, the plant could not have operated in all required modes; d.
DC Power Sucolies.
B&R's failure to update and correct basic calculatiens as j
new loads became known demonstrates poor interdisciplinary coordination, a failure
{
to understand special nuclear require-ments and poor engineering management and i
practice;
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e.
Picina Sutterts and Pipe Whip Restraints.
j 1-B&R's inability to manage and coordinate subcontractors to carry out the design l
and fabrication of piping systems in a t,
timely manner demonstrates its lack of experience in nuclear design and con-l struction, ceupled with its inability to acquire the requisite skill and knowl-edge.
It also demonstrates poor engi-neering management, poor interdisciplin-i 73 ary coordination and poor engineering Jk practice.
Piping system design was not timely to support needed construction.
Piping layout was not cocrdinated and j
resulted in many interferences requiring t
FECXO6C/018AOl '
m_.
- ~.
I i
an inordinate amount of rerouting and reanalysis.
Pipe support / hangar design was not timely.
The size of overly conservative pipe whip restraints hindered efficient piping installation in the reactor containment building; l
f.
HVAC Systems.
B&R's failure to update basic calculations performed early in the job resulted in serious design deficien-cies.
B&R HVAC engineers failed to 4
understand and comply with basic nuclear power plant design requirements.
Exten-sive re-design of the HVAC systems was necessary, with substantial resulting impact on the related Chilled Water, Ccmponent Cooling Water, and Essential L
Cooling Water rystems.
In its design of the Residual Heat
(
Removal / Safety Injection Systems, B&R first ignored, then failed to understand, 1
4 regulatory requirements regarding proper
$ zg safe shutdown of the plant.
3 The Containment Spray System could not
{
have been installed as designed because i
i its pipe supports were out of alignment with the pipe support inserts.
If j
insta11able, the system would not have worked properly because HVAC duct work interfered with the spray action of its four spray no::les.
l g.
IVC.
The IVC is an example of a techni-cal problem that existed at the time B&R i
wa; terminated as A/E.
B&R's failure to
(,
properly understand and consider regulatory requirements resulted in problems affecting the IVC structural design.
Because of its inexperience, B&R was unable to solve this problem before it was terminated as A/E.
s
.a h.
River Make-up Pumping Facility.
B&R's performance in connection with the river make-up pumping facility is another example of overall poor engineering FECXO6C/C18A01 '
as
i i
I management, poor interdisciplinary coordination and poor engineering prac-tice, resulting in design that was not i
timely; i
i.
Main Cooline Reservoir Embankment.
B&R ran the circulating water system pipes through the reservoir embankment without providing a means for guarding against
{
undetected leaking, which could threaten l
the integrity of the embankment.
While the design of the embankment was conser-vative, the potential for undetected leaking created the possibility of massive embankment failure.
B&R's J
failure to appreciate the impact of an l
embankment failure on a nuclear plant demonstrates B&R's lack of experience in a
the nuclear industry and lack of understand-ing of special nuclear requirements; j.
Anchor Bolt Intecrity Verification.
B&R's inability to verify the integrity
- t --
p of misfabricated anchor bolts to the 1
4 satisfaction of the NRC is another j
example of a technical problem that B&R could not solve.
It demonstrates lack of nuclear experience and poor engineering management; k.
Nuclear Coatings.
B&R's inability to deal with the requirements for nuclear coatings is a direct example of B&R's inability to acquire the requisite skill L
and experience to handle nuclear con-struction and design.
Nuclear coating problems had a tremendous impact on I '-
mechanical construction at STP prior to the time that B&R was removed as A/E; T-f 1.
Steam Generator Blow-down System.
B&R's i
~
decision to eliminate the processing portion of this system indicates its lack g,
of nuclear experience and lack of under-y-
L standing of special nuclear requirements.
This system had to be substantially redesigned; L
FECXO6C/018A01 '
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~ _ _ _ _ _ _ _ _.
l.
T l
m.
Essential Cooling Water Gantv Crane.
B&R's failure to specify a ganty crane that could withstand tornado forces, and l
its subsequent inability to resolve this technical problem satisfactorily, illustrates poor engineering practice and management and an inability to solve technical problems; n.
Conconent Cooling Water System.
The h
design of this system was entirely within B&R's scope of responsibility.
B&R could not design the system to perform all of
~I its required functions, which demonstrates 1
d ESR's inability to properly design and 4
verify important nuclear systems; n..
Eeam-to-Column.
B&R's failure to consider thermal loads in the design of structural steel in the RCB created technical problems which existed long before E&R was terminated as architect / engineer.
l g These problems demonstrate the weakness of B&R's design verification procedures and represent problems which E&R could not solve prior to being terminated as f
architect / engineer; 1
o.
Comtuter Code Verification.
E&R's failure to verify and control its computer codes and nuclear calculations demon-strates its lack of experience and understanding of nuclear requirements and demonstrates poor engineering management and practice.
a.
l C.
CONCERNING PROJECT MANAGEMENT t.
42.
B&R's failure to perform project management, includ-(
)
ing engineering management, construction management, and its failure to adequately plan and schedule its work and to administer the work of subcontractors
(
contributed significantly to B&R's inability to complete the design of STP.
Specifically:
I a.
B&R failed to implement a systematic, centralized and consistent plan for STP controls;
[
FECXO6C/018AOl -