ML20148C280
| ML20148C280 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/22/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19309H550 | List: |
| References | |
| 50-498-79-19, 50-499-79-19, NUDOCS 8005130491 | |
| Download: ML20148C280 (19) | |
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APR 3 01980
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, APPENDIX A NOTICE OF VIOLATION 4 Houston Lighting and Power Company Docket Nos.: 50-498 50-499 Based en the- msults of the NRC investigation conducted during the period November 10, 1979 through February 7,1980, it appears that certain of your '
a:tivitiestere not conducted in full compliance with the conditions of your NRC Construction Permits Nos. CPPR-128 and CPPR-129 as indicated below.' ! A. 10 CFR 50,' Appendix B requires that licensees holding cor.struction pemits implement a quality assurance program meeting the criteria of Appendix B for all activities affecting the safety related functions of structures, systers, and components that prevent or mitigate the conse-quences of postulated accidents that cause undue risk to the health and-safety of the public. . Section 17. of the South Texas. Plant Preliminary Safety Analysis Report sets forth the Quality Assurance Program developed by The licensee to implement Appt ndix B. Contrary to' the above, during the period of October 1979 through January 1980, the licensee was in continuous noncompliance with 10 CFR Part 50, . Appendix B in that the licensee and Brown & Root (B&R), did not adequately 1 control all activities affecting the safety related functions to assure that such activities were conducted in accordance with the Appendix B ' Criteria. This continuous. noncompliance is evidenced by numerous examples
- in the subject area of Criteria I, III, V, VI, IX, X, XV, XVI, XVII, and XVIII, as follows:
- 1. 10 CFR 50, Appendix B, Criterion I- states in part, "The persons and organizations performing quality assurance functions shall have ,
sufficient authority and organizational freedom to identify quality problems . . . . including sufficient independence from cost and schedule...." The South Texas Project (STP) Preliminary Safety Analysis Report (PSAR) in Sectinn 17.1.1B (through Amendment 32,10/17/75) states in part, "To assure the establishment and operation of the QA/ Quality Control (QA) Program, B&R has an organization such that those per-forcing the QA/QC functions have the freedom to identify quality problems, to provide means for c"aining solution to problems, and ver'fy that solutions have been implemented. This organization has ; sufficient independence, authority and technical expertise to carry ' out the program in an efficient and effective manner. This is assured by B&R QA Management reporting to Management leuls above and indepen-dent from pressures of production."
"Some of the listed examples occurred outside the October-January time period ;
for which a civil penalty is proposed. Such examples support the findings that 1 similar. occur:ences were present during the period for which the civil penalty is proposed. Civil penaltiet are not being proposed for those examples.
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.AppenbixA. '
. APR 3 01S80
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Contrary t'o the abse, the results of the investigation indihate L that the quality assurance / quality control functions in the civil area are not sufficiently. independent, the QA/QC civil personnel do l
- not' have. sufficient; authority'and the QA/QC- civil personnel do nct
~ have the freedom to identify problems and determine;they are
. adequately resolved; The results of interviews indicate that some-civil quality control. inspectors are: (a)- subjected to production pressures,-(b) not'always supported by the QC management,:(c)
- . harassed, (d)- intimidated, and (e) threatened.
~ Documented evidence obtained during the inva,tigation indicated a continuing trend'on the part of civil quality control inspectors to assume the' position that it. is easier (less pressure, harassment, and threats) to just sig the quality control documents which are
' necessary_ for construction to proceed, even:t5ough the procedural or-specification requirements.may not have been fully met, than to be confronted by quality control and/or construction management. .It is -
noted, however, that during the investigation no items of major I safety significance were found which related to the above findings, but the potential for future problems is great unless corrective action is taken. Examples supporting the above findings are as follows:
- a. It was substantiated that during the final preparations for the
. placement of concrete in Lift #5 of the Unit 2 reactor contain-ment building shell wall .(placed 4/27/79) production pressure was present and caused a QCE supervisor to override the advice of his subordinates that the area of the construction joint was dirty. The corrective action selected, which was not totally i effective, was that requiring the least delay in the construc- .)
tion schedule. l i
.That the action was not fully effective was evidenced by a constre tion foreman who saw c ca3 float to the surface of the concrete during placement. The QCE supervisor indicated that a large number of construction personnel, inclucting construction.
top site management were standing by to begin the placement and that he signed off the necessary documents to get the placement underway due to the critical' time frame for ordering concrete (111agation 11A, p. 38).*
- b. A former QCE supervisor stated that whenever construction falla behind in placing concrete, QC inspectors seem to always get the blame. The statement was made on the basir of his knowledge of what upper management expressed in meetings and general conversations. He also indicated that construction always "Page numbers refer to Report No. 50-498/70-19; 50-499/79-19.
l :,. x .. 1 [ ,;.'\.. ' App 3ndix A 1 . APR ' 3 0 1980 - indicates they.are ready for a placement when they are not and'.' that;QC had only 24 hours to complete the inspection. He noted that ' construction scheduling pressure ' gradually reduced this : L period (Individual A47, p. 3-26). l
- c. . A current QCE supervisor related that after QC had completed a
, preplacement inspection, the pour card had.been signed and the .
concrete ordered, tne QC personnel would find additional problems such as alterations to the forms or ' debris dropped into the - forms.: This would occur from 3 to 24 hours after the sign.'off. Construction personnel would try to pressure inspectors to accept these conditions because of the time.and money to correct the situation. - He indicated that if construction
. personnel were unsuccessful; and the placement was delayed or stopped, then it .always seemed to be QC's . fault. He also indicated that construction management has a major problem in 1 that they think of' quality only as a necessary evil and that
-there is such controversy over schedules and cost overruns
..(Individual A35, p. 3-14). .
- d. rs QC inspector stated that in the summer of 1979 he had ,
discovered three horizontal reinforcing steel bars missing from ' a wall section which was:being readied for concrete placement. On the previous day he had told construction personnel that he thought .the wall . preplacement was correct. He was verbally ~ abused by a person from construction (Individual A17, p. 2-12).
- e. Fifteen of twenty-four QC civil inspectors interviewed executed si,ned t sworn statements wherein they claimed that their super- ,
visors had not supported their positions during confrontations l with construction personnel. An additional QA auditor and an. ' inspector on special assignment indicated the same concern. , Interviews with the construction personnel' involved resulted in signed sworn statements wherein they admitted ignoring and/or . bypassing the QC inspector's ' directive to stop by continuing. l the. work, and then going to the QC inspector's supervisor to 'l reverse the directive (Allegation 6). This lack.of QC manage- ! ment support is alsc evidenced by the findings resulting from Allegations 3, 7A, 8A, and 9A (pages 18, 10 32. 33 and 34). ) I A QC inspector refused to sign off on deficient Cadwelds and f. initiated a nonconformance report (NCR) because Cadwelder requelification was not performed as required by the specifica- i
, tion. The construction supervisor admitted he had ignored the l QC inspector, the inspector's supervisor and the NCR and ordered his men to continue Cadwelding. This resulted from a disagreement over interpretation of the specification (Allegation 10A, p. 36).
ApperiixLA; APR 3 01980
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lg. 'Five QC civil inspectors executed signed' sworn statements- - ' wherein they claimed that during a meeting a.high level QA/QC. manager warned them not to talk to the NRC,. indicating that " action would follow. Thit, was also: confirmed by another QC i civil inspector (Allegation 1, p.12). i
- h. . Another QC civil inspector.' executed a signed sworn statement . j that~ a QC supervisor stated words to the.effect that after the i NRC leaves we will hava to get rid of some of the QC inspectors.
' The QC supervisor acknowledged that he made such a statement in mid-November of 1979 (Allegation 4A,. p. 29),
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- i. Another QC civil' inspector involved in an incident where the-concrete foreman left the placement without informing the inspector who was the acting foreman was later faced with information that the concrete foreman had said his crew was.
able to violate the specification without the inspector's knowledge. The. inspector was informed that the foreman was bragging about the incident (Allegation 8, p. 20). 1 I
- j. A QCE supervisor indicated that a person in construction .I attempted to harass the QA/QC program personnel by trying to .
remove air conditioning from the assigned office spaces ! (Individual A35,' p. 3-14).
- k. A QC inspector admitted in a signed sworn statement he falsely signed concrete curing records at the request of a lead QC person when he had not inspected the curing and in fact was not on-site at the time the inspection was supposedly made. The lead QC person however, denied that such a request was made (Allegation lA, p. 26).
- 1. A QC inspector admitted in a signed sworn stateme't he signed off on a minor Cadweld deficiency (procedure violation) because he felt his supervisors would not support him and would-side with construction (Individual A?2). In this instance the.QC inspector was intimidated by his past experience with his supervisor and took an action to correspond with his supervisor 1 (p. 2-29). !
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- m. A QC inspector was physically threatened by a ronstruction !
general foreman. The QC inspector, a witness and the construc-tien general foreman all executed signed sworn statements substantiating this event. The construction general foreman indicated he lost his temper and intended no harm (Allegation 2A, p. 27). 1
APR 3 01980
' Appen.aix~ A' -
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- n. A QC' inspector was physically.ttweater.ad by a construction superintendent. Botn executed signed sworn statements substan-tiating this event. The construction superintendent indicated he lost his temper and intended no harm (Allegation 3A, p. 28).
- o. A QC inspector was threatened by a construction general foreman.
~ The QC inspector, a witness and the construction-general foreman -j all executed signed sworn statements substantiating this event. :
A QCE supervisor 'in an interview also substantiated the threat. i The construction general foreman explained that he lost his i temper and made no etempt to injure the.QC inspector-(A11egathn 2, . p. lb. ~
- p. On January 4,1980 'a lecture by the Brown and Root Project QA j Manager was given to the. Brown and Root site QA/QC personnel 'j and construction engineering and supervisory personnel. The ;
lecture repeatedly overemphasized the Brown and Root QA/QC : organization's responsibilities to minimize project cost and i maintain the construction schedule. . The lecture also strongly ! emphasized the fact that a Brown and Root QC inspector's '3 decisions are subject to question, challenge and supervisory ! review and reversal. The lecture was recorded on video tape ' which continues to be used as a mechanism to project the Brown, , and Root policy. In addition, the contents of the lecture were : put into printed form and widely distributed to employees of l Brown and Root at the South Texas Project. (Appendix 5). l
- 2. 10 CFR 50, Appendix B, Criterion IX requires in part, " Measures shali ;
be established to assure that special processes... are controlled and { accomplished... using qualified procedures in accordance with... i specifications, criteria and other special requirements." ! The STP PSAR in Section 17.1.9A states in part that " Houston Lighting i and Power Company (HL&P) requires written procedures and controls to i ensure special processes. .. are accomplished.. . using qualified ! procedures in accordance with applicable... specifications, criteria, j c.d other special. requirements. These procedures shall describe the j operations to be performed, sequence of operations, characteristics ! involved... examinations, tests and inspections shall be conducted to j verify confomance to specified requirements... Compliance to these j requirements is roandatory for prime contractors." j s From information provided to the inspector it was determined that a l
" test fill program" resulted in the determination that for placement of an 18 inch maximum lift thickness of soil it would be necessa y to )
l make 12 passes with the compaction equipment. ; { l l I'
L 1.' Appendix A APR 3 01980
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v .... - L . Contrary to the above, Brown and Root construction procedure, STP-QCP. l A040KPCCP-2, Rev. 2, required only 8 passes with the compaction
- . equipment for the placement of.a maximum lift thickness of 18 inches of soil. Thus the construction procedure. did not reflect the necessary-number of'pases of cocaction equisiment which had been established in a qualification test procedure.(p.61). l l
3 10.CFR 50, Appendix B, criterion XVI requires in part, " Measurer shall
, be established to assure that conditions adverse to quality, such .
as... defective... equipment... are promptly identified and cort ected. [ u In the c*.se.cf'significant conditions adverse to quality, the measures shall assure that... corrective action taken to preclude repetition." ) The STP-PSAR in Section 17.1.16A ststes in part, " Houston Lighting. and Power Company (HL&P)'will require measures be established to assuru conditions adverse to . quality will be promptib .. corrected... In the case of significant conditions adverse to quality, measures ; shall be taken to ensure the cause of the condition is determined i and corrective action is implemented to preclude repetition." The FSAR in Sectior 2.!. 1.2.4 'and Brown and Root Specification No. 3YO69YS029, Rev. F, .agraph 9.e, and Brown and Root Procedure. I No. A040KPCCP-2, paragraph 3.3.3.5 require that at least one relative !
, density test be performed for every fourth field sand cone density
$ test.
Contrary to the above, a review of Pittsburgh Testing Laboratory data en December 18, 1979, indicated that a relative density test had not been performed since Novenber 17, 1979 as a result ef equipment . failure. Plant backfill continued to be placed and several sets of .) four field sand cone deCty tests were completed without the ' companion relative density tests being performed (p.64).
- 4. 10 CFR 50, Appendix B, Criterion V requires in part, " Activities :
affecting quality shall be prescribed by documented instructions, procedures... appropriate to the circumstances. The STP PSAR in Section 17.1.5A states in part, " Appropriate' require-cents have been established in the Houston Lighting and Power Company-(HL&o) Quality Assurance (QA) Program to ensure quality related activities for the South Texas Project (STP) are prescribed by docuoented instructions, procedures... the responsibility for develop-ment of these methods, procedures and instructions is delegated to the organization performing the e.ctivities... The HL&P QA Department has the responsibility for ensuring that methods, procedurts and instructors (sic) are developed and implemented for all activities relating to the STP." l 4
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Appendix A1 '
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4 Contrary to the above, Pittsburgh Testir.y Laboratory QA Procedure No. IS-511-01556-64 indicates that the .3 place den ity measurements are to be performed according to.EAASTM u-1556, however there are no requirements in the procedure which define the location or depth of l
-he samples. A review of the records by the inspector revealed that 1 the samples were taken'at various depths in a given lift with no specific correlations of results available (p. 61).
- 5. 10 CFR 50, Appendix B, Critation XVII requires in part,-that ,
" Sufficient records shall be maintained to furnish evidence of I activities affecting quality."
l The STP PSAR in Section 17.1.17A states, in part that, "The STP QA - Plan specifies:
- 1) The records are required to be maintained to shcw evidence of perforoance of activities affecting quality. Typical records to" be maintained include: . , . inspection and test reports. .
Paragraph 1.3.3.1 of B&R's Quality Construction Procedure CCP-2 states, "All inspection and laboratory testing will be conducted to assure compliance with all specifications . . . and the requirements cf this Quality Construction rmcedure . . . The inspectors will
, document their findings . . ."
Contrary to the above, neither the' applicable B&R procedure nor the test record form SF-6 required that the lift thickness and number of passes of the compaction equ4 ment be documented. These data are needed to assure that the tackfill material is being systenatically placed and compacted to obtain the required densities (p. 65).
- 6. 10 CFR Part 50, Appendix B, Criterion XVI states in part, " Measures shall be *.stablished to assure that conditions adverse to quality, such as failures, . . . deficiencies, deviationt, . . . and noncon-formances are preparly identified and correctet. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."
The STP PSAR in Section 17.1.16A states in part, "The identification ; cf a discrepancy or nonconfonance requires certain steps to be j taken to ensure proper closure of the item. The specific steps to ' be followed are as follows: 1 . . 5. Verification (followup) by Original identifier of discrepancy or noncomfemance to ensure its implementation and action to preclude repetition or recurrence."' l _ - _ _ _ ,_.- - . _ . . _ _ . , _ - . _ _ - _ _ . . . _ _ _ _ w --
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,,1 APR 2 01980 -
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;y 1 i Appen, dix A -- 8'- ;
P , , ,, Contrary;to the' above, no effective program has been implemented on. . a centinuing basis to review and analyze Noncenformance Reports, Exa:ination Checks / Inspection Books op Field Requests. for: Engineering 1 Action'for repeti'!ve occurrences to ensure that root causes are l identified-and corrective'. action is- taken to' preclude: repetition.
. Further, no formal, approved procedures. to implement such a program had been developed as of November 28; 1979'(p. 94h l
- 7. 10 CFR 50,iAppendit B, Criterion XVI'as' implemented by SouthLTexas.
. Pro.iect PSAR Section 17.l.16, states in 'part, " Measures shall' be established to assure that conditions adverse to quality, 'such as
. failures, malfunctions, deficiencies,: deviations, . . . are promptly l
- identified and corrected. In the case'of significant conditions adverse tc. quality, the measures shall assure that the .cause of,the condition .is determined and corrective action taken to preclude:
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' repetition . . ." !
1 An HL&P' letter to the NRC, ST-HL-AE-374 dated August 31, 1974 - pertaining to lifting the HL&P Stop-Work-Order for placement of u containment shell concrete specified that. the following measures had be'en implemented for. all concrete placement:
- 1) "Very detailed prep 1r.coment planning is carefully performed to identify potential consolidation problems . . ." - -
- 2) " Increased attention ic given to logistics to provide for backup equipment, access for inspection, lighting and mar. power assignmenu . . ."
- 3) "Special additional training for Construction and Quality Control personnel is given to cover procedures for placement, .
vibration . . ." Contrary to the above, work observed, statements by site personnel, quality assurance records and site internal surveillance reports show that the corrective actions outlined in HL&P letter ST-HL-AE-374 have not been effective to preclude repetition. Examples of this ineffectiveness are as follows (pages 53 and 54):
- 1) Concrete placement personnel were using improper consolidation practices and lighting as observed by an NRC inspector was inadequate. for placement CIl-W818 made on November 20,1979.
- 2) Concrete placement personnel were using improper consolidation I practices on placement DGi-H1 made on December 7,1979. Further-more, an insufficient number of preplacement inspectors were assigned to conduct the final inspection.
1 Construction work in the placement area was being performed i during the night prior to the placement and during the morning
- of the placement.
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. APRi3 0"1983 ;
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i This;".last minute" construction activity, at least in-i . part, delayed the start of the placement from the scheduled 7:00. a.m. . until approximately 11:00 a.m. This . scheduling o resulted in undue pressure on the QC inspectors to quickly .. p accept the placement conditions. No specific placement method
~(sequence) .was specified. in the placement plan or. discussed in i the preplacement eeeting. . In' addition, the report of the post-L q placement interview did not address the Mroblems with last '
' minute' construction work or the' loose reinforcing steal that
- . delayed the. start of the placement and was again identified
- i. after plar. ament had begun.
Interviews with QC inspectors and notations on Inspection 3)
- Books, Examination Checks, post placement interview reports and F . Site Internal Surveillance 513-26 for placements MEl-5047, 4
CS2-W7, ME2-WO12-05, CIl-W81B and ME2-W001-04' indicate that { poor consolidatior practices:and excessive lift thickness ! continue' to be proDiens. ! -8. 10. CFR 50, Appendix B, criterion V states in part, " Activities l af fecting quality shall be prescribed by. documented instructions, j' procedures or drawings .. a sd snall be accomplished in accordence i with these instructioris, procedures or drawings." i . i , 10; CFR 50, Appendix B, Criterion V as implemented by the STP PSAR l Section 17.15, states in part " ...ouality related activities for i ! the South Teus Project (STP) are prescribed by dc umented instruc-tions, procecures or drawings; accomplished in accordance with such . documents ; . . . " T i i Eron & Root (B&R) Quality Assurance Personnel Training Manual- Part i 1, Supplement E, Section 5 specifies the required educational / j experience levels for Level 1 and II civil inspectors. For example, 1 i a Level II inspector with a degree from an accredited engineering or science college or university must have one year's experience in
- quality assurance, including testing or inspection, or both.
f [ Fittsburgh Testing Laboratory (PTL) Quality Control Procedure No. l QC-PQ-2, Appendices II and III specify the required educational /
- f. experience levels for Level I, II and III PTL inspectors. These
! apperidices identify the qualification requiremente detailed in i ANSI-N45.2.6 and ASME Srztlon III, Division 2 respectively. b F Contrary to the above, of 14 Brown & Root civil QC inspectors and I six PTL concrete inspectors, for which qualification records were
- exacined, five B&R and three PTL inspectors did not have the i required applicable QA/QC experience at the time of their certifica-l tion (p. 58).
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. APR .3 01980 h.pendix.A; 10 -
- 9. 10 CFR 50, Appendix B, Criterion VI, states in part, " Measures..shall~
'be' established to control the issuance of documencs, such as instruc-tions, procedures, . and drawings, including changes thereto, which -
prescribe all activities affecting quality . . ." The STP PSAR, in Section 17.1, states.in part, " Brown and Root l provid" written procedures for cc,ntrolling the preparation, review, q approva6 and issuance of: specifications, drawings,' procurement i documents, procedures, instructions, and changes thereto, which- ' delineate activities affecting quality." l Section 6, of the. Contractors Quality Assurance Manual, states in part, Documents used for the design, procnvement,' and construction of code and safety related items shall be distributed and controlled in accordance with approveo Project Procedures. . '"- Contrary to the above, the licensee's controlled copies (Nos. Of I and 05).of. the Contractors Quality Assurance Manul on January 8, 1 1980 did not contaiin tne latest issue of interim changes. Addi-tionally, the licensee's controllod copy of the Contractors Weld - Filler Material Specification, IUO20W5001-E, did not contain the latest document change notices (DCNs) (DCN/11/16/77 and DCN/3/28/78), - (p. 69).
- 10. 10 CFR 50, Appendix B, Critariois I.Y, states in part, " Measures shall be established to assure that specic.. processes, including welding .
. . , are controlled and accomplished by qualified personnel using qualified procedures in accordance with applicable codes, standards, specifications. . ."
Section 17 of the licensee's PSAR, titled " Control of Special Processes," states in part, ". . . written procedures and controls be prepared to ensure special procesen, including welding, . . . are accomplished in accordance with applicable codes, standards, specifications , . . . " ASME, B&oV Code 1974 through Wintcr 1975 Addenda, Section III, paragraph ND-4412, " Cleanliness and Protection of Welding Surfaces," states in part, ". . . the work shall be protected from deleterious contamination and from rain., snow and wind during welding . . ." Contrary to the above, the inspector observed on at least three occasions safety-related pipe welding activities ceing performed without adequate protection from the atmospheric conditions oescribed above. Subsequent examination of these welds showed that they had unacceptable defects. For example, the radiograph for field weld 0005 in line AF2004, made without adequate protection from the wind, i vnich would cause loss of cover gas, showed high levels of oxidation I (p. 72). L 1 i
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' JA;: pen' dix' A - APR 3 01980
- 11. 10 CFR Part 50, Appendix B, Criterion 4X< states in part, " Measures shall be established to assure that special processes', . including . .
.., nondestructive testing; are controlled and accomplished . . . in-acccrdan:e with' applicable codes, standards, specifications, criteric, and other special requirements."
Section 17 of the licensee's PSAR titled " Control of Special l Processes'.' states in part,' ". . . written procedures and controls be~ ; prepared to assure special processes, including .. . . nondestructive I testing . . . _ are accomplished . . . in accordance with applicable codes,. standards and specifications . . ."
- a. . Paragraph T-233.2 of Section V of the ASME B&PV Code'1974: j through Winter 1975 Addenda requires that all radiographs be free from mechanical, chemical, or other blemishes to the -
~ extent that they cannot mask or be confused.with'the image.of 4 any discontinuity,' including; fogging, processing defects 'such ;
as strecks, water marks, or chemical stains. ) l Contrary to the above, the inspector reviewed at least 50 final i radiographs of production (field)-welds and of weMar qualifica- ' tion tests which displayed significant light fogging and chemical contamination to such an extent that proper interpretation of the radiograph was nn possible in whole or in part (p. 79).
- b. Parngraph T-290 of Section V of the ASME B&PV Code 1974 through Winter 1975 Addenda states in part,'" . . . radiographs shall be examined and interpreted . . . record on a review form accompanying the radiographs the interpretation of each radio-graph and disposition of the material examined . . ."
Contrary to the above. the inspector observed ai least 12 radiographs of field welds and one radiograph for a welder performance qualification test weld which contained linear i indications that had not been recorded on the accompanying interpretation sheet (p. 82). , c. ASME B&PV Coc% 1974 through Winter 1975 Addenda Section III, , Paragraph ND-6351, " Evaluation of Indications" specifies that l any indication which is believed to be nonrelevant shall be regarded as a defect and shall be reexamined to verify whether or not actual- defects are proent. Surface conditioning may I pre:ede the reexamination. The contractors Liquid Penetrant Examination procedure, ST-NDEF-4.1, reiterates the above requirements. Contrary to the above, the inspec%r observed the performance of a liquid penetrant examination for field weld number 0017 in
L AppenditAt ' -
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- r the 3ssential cooling water system for which the_results were not evaluated according to these requirements (p. 76). .
- 12. 10 CFR 50, Appendix B, Criterion V requires in. part, " Activities i affecting quality shall be prescribed-by documented instructions . . . l Jand~ shall be accomplished in accordance with these instructions ..."
The STP PSAR.in'Section 17.1.5B states in part, " Engineering, . . construction, inspection, testing, and planning techniques are used .1 to assure that activities.affecting quality are set forth by written ! B&R' instructions; procedures and . drawings, and are 'acconglished in acccrdance with these instructions, procedures and drawings." Contrary to the above, on December 10,1979,; the inspector. determined that an interim change. ST-NDEP to ST-NDEP-4.1, " Liquid i Penetrant Examination," was; issued on~ August-30, 1979 and was inserted in the procedure and the applicable page of the procedure was removed. The interim procedure is valid for 60 days. The
. inspector observed that t.ne invalid or cancalled insert was' being '
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.used by B&R FDE personnel during Janury 1980. A similar example was observed relative to inserts for ST-NDEP-2.1, dated-March 13, 1979. This appears to be a generic problem (p. 77). t
- 13. 10 CFR 50, Appendix B, Criterion XVI states in part, " Measures shall ,
be established to assure that conditions adverse to quality such as
. . . deficiencies, deviations, . . . and nonctciarmances are promptly identified and corrected."
The STP FSAR states in Amendment 7 dated July 16, 1979 in Chapter 3, paragraph 3.8.1.6. 3, " . . . . :
- a. Subparagraph CC-4333.3, Initial Qualification Tests, serves as an alternate to Section C.1 of Regulatory Guide 1.10, except -
that a splicer will be requalified if in any 15 consecutive Cadwelds there are two unacceptable (either visual or tensile) Cadwelds made. The spi'cer will be requalified in the position . or positions in which tne failure (s) occurred." B&R Suecification No. 2A010CS028-G " Concrete Construction" (app' 4 cable at the time in question) states in paragraph 5.3.3.6, "When a splicer accumulates two unacceptable tests, either visual or. tendle, within a unit of 15 consecutive *.ast samples and the rejec-tions are not due to material deficiencies, he shall not be permitted to continue splicing until he has requalified according to paragraph 5.3.3.5.* Contrary to the above, five Cadwelders who had accumulated two visually unacceptable production splict.s within a unit of fifteen (15) consecutive splices were permitted to continue making produc-tion splices without requalifying (p. 37). _ _ _ . -.__ m__ m . - - _ _ _ _ . - _ _ ,_-w- ---
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APR 3 01980 Appcodix A -
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- 14. Ib CFR 50, Appendix B, Criterion XVI states *n part, " Measures shall
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be establisned to assure that conditions adverse to quality, such as failures >. . . deviations . .. . and nonconformances- are prortptly-identified and corrected. . . the cause of the condition, and the. corrective action taken shall be . documented and reported to appropriate levels;of management." The STP PSAR'in Se: tion 17.1.16b' states in part, "Should conditions
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exist that after a reasonable time for. resolution, a deficiency or conconformance is not correctec, the QA Manager is required to report
. the incident to the Power Division-Senior Groco Vice-President.any.
. Ilme agreement on corrective. actions- to be implemented cannot be attained, the findings may be brought directly to the Power Division Senior Group Vice-Presidemt for resolution."- Contrary to $he above, there was no objective evidence that the Division Sentor Group Vice-President was advised of the failure to take action on repetitive deficiencies documented in B&R site. surveillances SIS-12 and 12.1 through 12.5, .nor the. failure to get responses and/or corrective action on SIS-18 and the B&R letter 5153-dated November 12, 1979 (p. 106); ; 15._ 10 CFR 50, Appendit B, Criterion V states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings....and shall h accomplished in accordance with these instructions, procedures or drawings." 10 CFR 50, Appendix B, Criterion V,'as implemented by South Texas Project PSAR Section 17.1.5 states in part, "The HL&P QA Department ' has the responsibility for ensuring that methods, procedures and instructions are developed and implementad for all activities , relating to STP." ' HL&P Project Quality Procedures PSQC PC, Revision 1, and PSQP-A3, Revision 9, state in part, "All . checklists shall be completed in full, signed and dated by the QA personnel involved, and filed .in-the site QA office. Should any items on the checklist not be applicable to the operation, that item shall be marked, NA. Items found to be satisfactory will be marked S. Items not codited shall be marked N. . Any discrepant items or dnviations from specifications shall be marked "U" and discussed in the " Remarks" section. The % surveillance personnel shall document all nonconformances and TefTfencies according to PSOP-3. Notification of Brown & Root Site QA: Weever a discrepant item or condition for which B&R or a B&R subcontractor is responsible is identified by HL&P QA, Brown & Root site QA shall be notified immediately. The notification may be by one of the previously centioned HL&P Discrepancy Notification Documents or orally. If
' ~
) Appendix A - 14.-
t - immediate and acceptable action and recurrence control (as applicable) are implemented by B&R pursuant to oral notification the ' item may be closed out on the checklist itself if a checklist was used. Peference should be made on the checklict as to the correc- l tive action." l Contrary to the above, civil surveillances C.R.1 through C.2.5 were not properly documented as r6 quired by the written procedures. That l is, unsatisfactory conditions and r.orractive action were not always .l documented during the. period of 1978 and 1979,(p.103). i
- 16. _10 CFR 50, Appendix B, Criterion XV requires in part, '! Measures i shall be established to control materials, parts, or components i which do not conform to requirements in order to prevent their '
inadvertent use . . ." The STP PSAR in Section 17.1.158 requires suppliers to establish and implement procedures for controlling items or processes that do not conform to requirements of the applicable codes or standards. ASTM D-1586-67, identified by Houston Light and Power Company as the applicable standard for site soil penetration tests, states in paragraph 2.3, "The assembly shall consist of 'a 140'1b. weight." Contrary to the above, site soil penetration testing activities were allowed to continue during the period January 28, 1980 to February 4,1980 using a weight (" hammer") which had been identified as nonconforming to the requireuents of ASTM D-1586-67 (p. 67).
- 17. 10 CFR 50, Appendix B, Criterion XI, requires in part, " Test procedures shall include provisions for assuring that all prerequi-sites for the given test have been met, that adequate test instru-mentation is available and used. . "
l The STP PSAR Section 17.0, paragraphs 17.1.11A and 17.1.11B states in part, " Houston Lighting and Power Company (HL&P) Quality Assurance l (QA) Program requires prime contracters, subcontractors , . . designate '
. appropriate tests to be performed at specific stages of . . . construc-ti on. Conduct of tests will De governed by written procedures which will incorporate requirements and acceptance 1 kits . . . Tests will i ts conducted in accordance with these procedures . . . J "The prime contractors Brown & Root, Incorporated (B&R) . . . shall ensure all necessary tests t.re required and conducted. Such testing will be performed in accordance with quality assurance and engineering test procedures which incorporate . . . the test requirements . . .
Test requirements . . . are provided by the organization responsible for the design of the item under test . ..
, , , , . + .
L
. , .1 1.
Appendix A-(- q, ' APR 3 0 d80-' l'
. , . . , , r l
"B&R engineering will establish the required , test program . ... . in -
L . appropriate specifications. The suppliers and B&R Construction are required to' establish' detailed pr'o cedures for the. tests . . . cThe-test procedures shall include provisisns for assurance that' the -
. prerequisite for the test have been met, that adequate instrumenta---
stion' is available and will be used . . ."-
, A. Woodward-Lundgren document, dated August l',1975 entitled' Appendir [
m B-1 Revision 2, presented to the NRC on. February 5,1980'as~ the 9 applicable QA procedure, states that split-spoon samples should be taken according to ASTM D-1586-67.- Paragraph 2.2 cf. ASTM D-1586 states, "The sampler shall be constructed-with dimensions indicated on Figure _1. The drive shoe . . . . shall a be replaced . ... . when it becomes dented or distorted." Figure IL shows a 1.375 inch inside diameter of the split-spoon sampler cutting edge and a 0.75 inch taper.- Contrary to the above,'the split-spoon used in the.backfD1 test prog am during the period January 28, 1980 to February 5, 1980,3 did not confonn to the requirements of ASTM D-1586-67 in that the inside diameter of the cutting edge was measured to be 1.5 inches and the driven end of the split-spoon was badly distorted and had a 0.50 > inch taper. Thus the test procedure which defined the proper dimensions on the equipment was not followed (p. 67).
- 18. 10 CFR 50, Appendix B, Criterion XVIII states in part, "A co prehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and.to determine the effective use of the program."
The STP PSAR Section 17.0, paragraph 17.1.18A states in part,
" Houston Light and Power Company (HL&P) requires . . . periodic audits be performed to verify compliance with all aspects of the.
program. .. . to verify by evaluation of objective evidence . . . program has been properly implemented; to assess the effectiveness of the QA program; to identify . . . and to verify correction of identified nonconformances.. . Applicable elements of the QA Program shall be audited at least annually . . . with the following addi-tional criteria to be used for modifying the audit frequency:
- 4. When it is suspected the safety, performance or reliability of an item is in jeopardy due to deficiencies and nonconformances with respect to the organization's QA Program;
- 5. When it is considered necessary to verify inglementation of required corrective actions. . ."
;_ . - . - . - ~. -. . ~. .- .. . - - . --
+ . < . Appen' dix A' ' APR 3 01987
- 16 .
t F a Th's STP PSAR Section 17.0, paragraph 17.1.108 states _in part;
" Brown and-Root, Incorporated (B&R) has established an audit system . . . for internal -. . ' - audits. . Internal. audits are i.
audits of activities of the B&R organization... B&R performs audits of all. activities' affecting quality, . including but not limited to the following:
- 8. The evaluation of work areas, activities, processes, and items
.(hardware)
- 9. The review of documents and records i i 10. _ An objective evaluation of i
- a. Quality related practices, procedures and instruction
- b. The effectiveness of implementation. . ."
The- B&R QA Procedure ST-QAP 7.1 reiterates the above requirements. s
- a. Contrary to the above, neither the HL&P QA plan Section 8.0 nor procedure QAP-5 " Audits" include provisions to implement the nuve requirements concerning performance of supplemental :
audits. - 1 Furthermore neither HL&P nor B&R (Houston) pstformed I supplemental audits to determine if suspected safety perforcance or reliability of an item was in jeopardy, even thcugh: (1) continuing allegations were received during the period from mid-1977 through 1979 relative to civil censtruc- l tien and inspection activities', and (2) significant voids were identified in the Unit No.1 containment shell in early 1978
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(followed just recently by the discovery of apparently similar- I type voids in the Unit No. 2 containment vessel shell) (pages 95, ] 100 and 101).
- b. HL&P QA Procedure, QAP-5B in paragraph 6.2 states in part,
" Objective evidence shall be examined for compliance with Quality Assurance requirements. This includes review of Qetiity Assurance / Quality Control procedures and documentation which implements the Quality Assurance Program Requirements. Selected elements of the quality assurance effort shall be audited to the depth necessary to determine whether or not it is being implemented effectively."
Contrary to the above procedure and the previously referenced PSAR and Appendix B, Criterion XVIII requirements, HL&P (Houston) failed to audit the HL&P (site) QA function to the depth necessary.
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- - - = - - ' ' ~
y jhg ;o- . c. 1 , LAppendix~A , Houston audits of site QA' functions were essentially.a review of record, and did not identify the fact that HL&P site procedures
.PSQ:P-C and PSQP-A3 were not~being effectively' implemented in .!
^
that r.cnconformances and deviations were not being identified ' in the civil surveillance reports (pages 99 and 104). . l
- c. 'HL&P South Texas- QA Plan.Section 8.0, paragraph 8.2 states in 1 part, "HL&P has the' responsibility for the overall, auditing of '
quality activities for the South Texas. Project. The frequency of ' audits performed by HL&P . . . . are generally as follows: Brown & Root site construction annually; Brown & Root site QA/QC - semiannually." Contrary to the above procedure and previously ' referenced PSAR and Appendix B, Criterion XVIII requirements, HL&P (Houston) 3 did not audit the implemntation/ execution of E&R site construc- i tion procedures for the years 1977, 1978 and 1979, nor the site , QA/QC procedures ST-QAP-2.7, 3.1, 3.2, 4.3, 5.3, 5.4, 5.5 and. 6.1 during the years 1978 and 1979 (p.100). IS. 10 CFR 50, Appendix-B, Criterion XVIII state: in part, "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance a 4 program and to determine the effectiveness of the program." , The STP PSAR Section 17.0, paragraph 17.1.188 states in part, " Brown >
& Root, Incorporated-(B&R) has established an audit system . . . for .
internal . . . audits. Internal audits are audits of activities of ' the B&R organizatica. . . B&R performs audits of all activities affec-ting quality, including . . . - The evaluation of work areas, activi-ties, processes, and items (hardware) . . . An objective evaluation cf quality related practices, procedures ar.d instruction. The + effectiveness of implementatior , 5&R QA Procedure ST-QAP 7.1 reiterates the above requirements. i i Contrary to the above, B&R (Houston) audits of B&R site QA/QC and ! construction activities were essentially only reviews uf records and l did not determine to the depth necessary, whether the sita quality procedures were being effectively implemented. FurtlAr, no audits ' were conducted of site design control in 1978, althowjh design lead l ime over construction was and continues to be very short and ; numerous Field Requests for Engineering Action and other design cnenge cocuments were being processed (p. 100). l
- 20. 10 CFR 50, Appendix B, Criterion X, requires in part, " Houston Lighting and Po4r Company (HLAP) will establish with each of its prime j contractors... the primary inspection responsitilit'y. HL&P, however, !
retains the responsibility for review, evaluation and surveillece : , i I l l l i
'Appekdix A .
A of the inspection procedures util hed by these organizations.... HL&P requires by contract that the principal contractors... meet-
. the requirements of 10 CFR 50, . Appendix l B. .. HL&P and/or its representative shall verify... the inspections'are.being performed and documented by. personnel in conformance with. approved procedures..."
The STP PSAR Section 17.1.10 sta'tes in part,, !'A program for
- inspection of. activities affecting quality shall be established and 'i executed . . . to verify. conformance with the- documented instruc- a tions, procedures, and drawings for accomplishing the- activity." ,
Paragraph 3.22.2 of Brown & Root Procedure CCP-3 requires in pan that the QC Civil Inspector ensure compliance with applicable B&R drawings by verifying that reinforcing steel. is supported and tied : te prevent displacement. , Contrary to the above, en December 7,1979, although completed QC i documentation indicated that the reinforcing steel for placement DG1-M1 was properly installed, a sample inspection of ten vertical ; tie bars, made when the placement was about 1/3 completed, identified
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that three of the ten were unwired (p. 5: '. -
- 21. 10 C7 50, Appendix.B. Criterion III requires in part, "the design bar . , . for those structures, systems and components . . . are ,
corttetly translated into specifications, drawings,-procedures, and instructions. These measures shall include provisions to assure that ] apprspriate quality standards are specified and included in design documents and that deviations from such standards are controlled." The STP PSAR Section 17.1 states in part, "The HL&P QA Program impeses the following design control requirements on its own activi-ties as well as those of its principal subcontractors: . . .-(3) . appropriate quality standards are specified and inclu: led in the I design documents, and deviations and changes from such ttandards are-centro 11ed. . . (8) Design and specification changes are subject to the same design cortrols which were applicable tt criginal design." j Brown & Root QA Manual, Section 3, " Design Control Procedure" reiterates the above requirements. j Contrary to the above, Brown and Root correspondence BC-22539 authorized design changes to welding requirements contained in Welding Procedures MCEP-3 and MCEP-4 and Welding Specification A010P002 without proper review and approval. Furthermore, field welcing personnel and welding inspectors were using this letter and the attached diagram as guidance for welding r.nd inspecting (p. 74). I i l
APR 3 01930 Appendix A . . Each day of failure to meet the requirements of 10 CFR 50, Appendix B, con-stitutes a separate infraction c.nd a penalty of $3,000 is proposed for each (cumulative civil penalties - October 1979 through January 1980 - 123 days x S3,000 = S369,000). B. 10 CFR 50.55a(3), states in part, " . . . piping which is part of the reactor coolant pressure boundary shall meet the requirements for Class 1 components set forth in Section III of the ASME Code . . ." ASME Section IIT, NB-4321 (1) states in part, " . . . shall establish the procedure and conduct the tests required by this article and by Section IX in order to qualify both the welding procedures and the performance of welders and welding operators . . " . ASME Section IX, QW-191, states in part, " . . . the radiographic l examination . . . shall meet the technique requirements of . Article 2, Section V, . . . " Paragraph T-263, Article 2 of Section V of the ASME Code, requires that a scurce side penetrameter be used where accessibility permits hand place- ! ment of 'penetrameter on the source side of the item being radiographed. 1 Centrary to the above, the inspector observed specimens complet:d by the l welders and welding operators as well as the radiographs of the weld specimens which were made for qualifdcation to weld on Class 1 components with easy accessability, containing only fila side penetrameters (p. 70). On January 14, 1980, the inspector observed a weld being made on a Class 1 system, the cain reactor coolant piping, by an improperly qualified welder. This is an infraction. (Civil Penalty $3000) Although tne total civil penalties amount to $372,000, pursuant to Section 234 of the Ato ,ic Energy Act of 1954, as amended, (42 USC 2282), the total civil pen?.1 ties for any thirty-day period cannot exceed $25,000. Consequently, civil penalties .in the anount of $100,000 are proposed for the above. l This Notice of Viciation is sent to Houston Lighting and Power Compar.y pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations. Houste, Lighting and Power Company is hereby required T.o submit to this office within twenty five (25) days of the receipt of this notice, a written statement of explanation in reply including for each item of noncompliance, (1) admission or denial of the alleged item of noncompliance; (2) the reasons for the item of noncompliance if admitted; (3) the corrective steps vnich have been taken and the results achieved; (4) corrective steps wnich will be taken to avoid further items of noncompliance; and (5) the cate wr.en full cocpidance will be achieved.
_ , - -- ~ ~ ~ ~ AyM 3 0 ~ 1980l APPENDIX B , , NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES - 1
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Houston Lighting and Power Company. Docket Hos.L50-498-50-499 This office proposes to Limpose civil penalties pursuant to Section 234 of' Lthe . Atomic. Energy Act of 1954, as amended (42 USC 2282), and to 10 CFR 2.205 in the cumulative amount of One Hundred Thousana Dollars ($100,000) for the aggregate items of noncompliance set forth-in Appendix A to the cover letter. . In proposing to in: pose civil penalties pursuant' to this section of the Act and in fixing the proposed amount of thei penalties, the factors identified in the Statements of Consideration published in the Federal. Register with the rule i making action which adopteri 10 CFR 2.205 (36 FR 16894), August 26, 1971, and the ~" Criteria.for Determining Enforcement Action," which was sent to NRC - licensees on Dececher 31, 1974, have been taken into' account. The Houston Lighting and Power Company may, within twenty five (25) days. of the date of this notice, pay total civil penalties in the cumulative amount of One Huncred Thousand Dollars ($100,000) or naay protest the imposition of the civil- penalt'ies in whole or in part by a written answer. Should.the Houston Lighting and Power Company fail to answer within the time specified, this office vill issue an Order imposing the civil penalties in the amount proposed above. . Should Houston Lighting and Power Company elect to file an answer I pretesting the civil' penalties, such answer may (a) deny the items os noncom- : pliance listed in the Notice of Violation in whole or in part; (b) demonstrate- ) extenuating circucstances; (c) show error in the Notice of Violation; or. l (d) show other reasons why the penalties should not be imposed. In addition to protesting the civil penalties in whole or in part, such answer may request racission or citigation of the penalties. Any written answer in accordance. with 10 CFR 2.205 should be set forth separately from your statement or explanation in reply pursuant tn 10 CFR 2.201, but you may incorporate-by specific refert:nce '(e.g. , giving page and paragraph numbers to avoid repetition). The Houston Lighting and Power Company'.s attention .is directed to the other provisions of 10 CFR 2.205 regarding, in particular, failure to answer and 1 ensuing orders; answer, consideration by this off ice and ensuing ordert; requests for hearings, hearings and ensuing orders; compromise; and coFlection. Upon failure to pay any civil penalty due which has beer subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, the matter may be referted ts the Attorney General, and the penalty, unless compromised, recitted, or citigated, may be collected by civil action pursuant to Section 234c of the Atomic Energy Act of 1954, as amended, (42 USC 2282). m- - ooJ2UJW L 8ec6513e M 6 , O
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APR 3 0'1930 l
. . . 1
; APPENDIX C CROSS
REFERENCES:
NONCOMPLIANCES TO REPORT DETAILS l NONCOMPLIANCE- CRITERION REPORT SECTION REPORT REFEPENCE PAGE NO. A. 21................. I . . . . . ; . . . . . . . . . E . 1. d . . . . . . . . . . . . . . . . . . . 49 2 .................. IX .............. E.3.a ................... 61 64 3 ................. XVI............... E.3.c ................... 4..................V...............E.3.a.................. 61 5 ................. XVII ............. E.3.d ................... 65 6 ................. XVI ......... .... E.7.d ................... 94 53, 54 7 . . . . . . . . . . . . . . . . . XV I . . . . . . . . . . . . . . E . 2. b . . . . . . . . . . . . . . . . . . . 8 .................. V ............... E.2.c ................... 58 9 .................. VI .............. E.4.a.................... 69 10 .................. IX .............. E.4.c.(2)(c) ............ 72 lla ................. IX .............. E.5.b.(2)(a) ............ 79 82 115 . . . . . . . . . . . . . . . . . I X . . . . . . . . . . . . . . E . 5 . b . ( 2 ) ( b ) . . . . . . . . . . . . 11e ................. IX .............. E.5.a.(2) ............... 76 12 ................... V .............. E.5.b.(1)(a) ............ 13 ................. XVI .............. E.1.b.(Allegation 10A) .. 37 77 14 ................. XVI .............. E.9.b (3) .............. 106 15 .................. V ............... E.9.a.(1) .............. 103 16 .................. XV .............. E.3.f.................... 67 17 .................. XI ............ . E.3.f ................... 67 18a ............... XVIII ............. E.8.c ................... 100 95 1Ba ............... XVIII ............. E.8.d.(2) .............. 101 18a ............... XVIII ............. E.8.d.(3) ............ . 99, 104 1R: ............... XVIII ............. E.8.d.(1) .............. 100 18: ............... XVIII ............. E.8.d.(2) .............. 100 19 ................ XVIII ............. E.8.d.(3) .............. 53 20 ................... X .............. E.2.b ................... 21 .................. III ............. E.4.c.(3)(d) ............ 74 B. ............... 50.55(a) .......... E.4.b ................... 70 1 l l
' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of )
)
- K"USTON LIGHTING AND POWER COMPANY .) Docket Nos. 50-498
-(South Texas Project, Units 1 & 2) ) 50-499 ORDER TO SHOW CAUSE (EFFECTIVE IMMEDIATELY)
I The Houston Lighting and Power Company is the t.ilder of Construction Permit Nos. CPPR-128 and CPPR-129, issued on December 25, 1975. These permits authorize, in accordance with their provisions, construction of the South Texas Project, Units 1 and ?, in Matagorda County, Texas. II As a result of allegations that QC inspectors were being threatened if they icentified unacceptable items during concrete placements, an investigation (F.eport No. 50-498/77-08; 50-499/77-08) was conduct 9d by the NRC Region IV , (Arlington, Texas) Office during July 1977. Ten QC inspectors were interviewed, six stated they had experienced some harassment, but none stated that the harasscent led to overlooking unacceptable items. In December 1977, an investi-gation (Report No. 50-498/77-14; 50-499/77-14) of an allegation that certab l radiographs, mailed to a concerned citizen, revealed faulty welds, was not . 1 substar,tiated as the alleger was apparent'y the victim of a hoax. In March 157E, an investigation (Report No. 50-498/78-05; 50-499/78-05) was conducted of an allegation from an individual who felt he would become a potential I woum
a -s -er a # 4 l . L . l l scapegott for allowing the improper ese of procedures; this allegation was not substantiated. .In May 1978, an investigation (Report No. 50-498/78-09; 50-499/78-09) was conducted of allegations made by an anonymous individual that
- Cadweld records involving qualifications of QC inspectors were being falsified and QC inspectors were under pressure to violate inspection procedures and, thereby, not hold up construction work. There was no evidence that Cadweld records had been falsified. Interviews with QC inspectors indicated that while there was normal pressure to get the job done there was no edue pressure to
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violate procedures. One QC supervisor stated that his " holds" (inspection hold points) had so::etimes been overruled by higher authority, but he stated this was management's prerogative and did not resrlt from construction pressure. In July 1978, an investigation (Report No. 50-498/78-12; 50-499/78-12) was conducted of allegations made by an individual that QC Civil inspectors were inadequately trained on new procedures; the nonconformance reporting system was inadequate; QC inspectors were not given adequate support; upper management was inaccessible; and construction personnel placed undue pressure on QC inspectors. The allegations, for the n.;st part, could not be substantiated. The investigatinn results did indicate apparant low morale of some QA/QC Civil inspectors and some maknesses in the Civil QA program. In early August 1978, Region IV rereviewed the results of the past several investigations and noted that although most of the allegations were not substantiated, low morale of QC personnel was certainly evident during the investioations. This observation prompted Regfan IV management to conduct a
z j' 7 _ '
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special. meeting with licensee's corporate management representatives in their. l corporate offices in Houston, Texas, on August 15, 1978 (Report No. l
'50-498/78-13; 50-499/78-13). The specific. purpose of the meeting was.not only' .
'1 to express concern about the apparent low morale of some Civil QA/QC personnel, i l
but also to discuss apparent' weaknesses in the implementation of the site ! QA/QC Civil program, and the adequacy of the present QA/QC staffing level. Region IV concluded the meeting by stating that although they recognized that.
'l most of the items discussed were based on allegations which were not substan-tiated, there was concern about'certain perceived + indications. Specifically. .
there appeared to be a morale problem in the site Civil QA/QC organization; the long QC inspector punch lists would suggest that the construction surveil-lance inspections by the craft foremen and field engineers were less than' l adequate 'and, thereby, placing additional pressures on QC inspectors to complete final inspections; the observations made by Region IV inspectors that Civil QC 1 inspectors appeared to spend very little time at their desk preparing for inspections could suggest that QC inspectors have too heavy an inspection workload; finally, with regard to the adequacy of staffing, concern was expressed that the .'taffing plan for the current status of the project l indicated that the site was below the specified QA/QC manpower level by some 21 Brom and Root personnel and by some 2 licensee personnel. One mor.:h latcr, en Septether 15, 1978, a meeting was held in the Region IV office witr. licensee and Brown and Root management to further discuss commit-ments cade by the licensee during the August 15, 1978, meeting in Houston.
E 3 . . .
~ .a .
4a i
. . 8 Also diteussed.during the meeting were findings identified during-the l Septad er 11-14, 1978,- Region IV: investigation of.Cadweld irregularities which
-resulted in the issuance of an Immediate ' Action Letter on September 14, 1978,-
confirming a licensee imposed stop work order'on placement of concrete in the Unit'l Reactor Containment Building. The September 15 meeting was followed by a-licensee letter dated. October 3,:1978 to the kegion :IV office which addressed the several allegations that were the subject of the July 1978-Region IV investigation that led to the special: meeting with the licensee on' i
-- August 15, 1978.' The actions committed t.o by the licensee, as' set forth in the October 3 letter, to correct the apparent low morale problem.and strengthen 1 J
the QA/QC program were included in the inspection agenda for forthcoming Region IV inspections. The results of Region IV inspections conducted during the next several conths indicated that actions were being taken by the licensee to strengthen the onsite QA/QC program and improve the morale of site QC i inspectors. Regicn IV continued to receive allegations which were primarily directed toward site QA/QC activities. During the period August 1978 to November 1979, five investigations were conducted by Region IV. In August 1978, an invest-igation (Report No. 50-498/78-14; 50-499h8-14) was conducted of an alleged solicitation of bribes by a former QC inspector. The allegation, involving one car.'s word against another, was not substantiated. An additional allega-tic. revealed during the investigat. ion that QC inspectors would be adversely affected by the termination of the former QC inspector was not substantiated. ! w
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as .- . l
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3'. In September:1978,. an' inve; tigation (Report No. 50-498/78-15; 50-499/78-15) was conducted of allegativas made by,a QC inspector . involving installation and Lins'pection of. Cadwelds,' mislocation of a Unit 2 structure 1 and the inability of some construction foremen to read and write. Four of the thirteen allegations
.were. substantiated, resulting in two items of noncompliance. Allegations that were substantiated included' the loss of a field sketch, application of centering marks to rebar after Cadwelds were' completed, lack of second shift QC inspector coverage for Cadwelding,- and that only three Cadweld QC inspectors were available for Cadweld inspection. The allegation concerning mislocation of a Unit 2 structure was, in fact, a survey error which resulted in the Mechanical /Eiectrical Auxiliary Building concrete mat being one foot too narrow. :This item had already been identified by the licensee.
4 In January and February 1979, an investigation (Report No. 50-498/79-01; 50-499/79-01) was conducted of allegations made by a former employee conceraing installation and. inspection of Cadwelds. Two of the six allegations were substantiated resulting in one item of noncoitpliance. Allegations that were substantiated included the copying over of dirty Cadweld Examination Checklists and entering the QC inspector's initials on the clean checklists by another person; and the acceptance of a Cadweld with excess voids in the filler metal. In May 1979, an investigation (Report No. 50-498/79-09; 50-499/79-09) was. conducted of allegations concern',ng refusal of a QC inspector to sign a concrete pour card and widespread discrepancies in the Cadweld "as-built" location records. Both allegations were substantiated, but no items of noncom-pliance were identified. In September 1979, an investigation (Report No. 50-498/79-14; 50-499/79-14) was conducted of alleged intimidation of QC inspectors
.~ . _ . . _ _
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i by constru: tion per/,onnel and QA/QC' program' irregularities. Four of ths ten l I
- allegations were substantiated resulting in an item of noncompliance and a deviation. Allegations that were substantiated, included the finding that holes were, in fact, left in walls of safety-related structures after removal of. form ties; Lift 5 of the Unit 2 Reactor Containment Building contained Cadwelds that'were not accounted for; an inspection report contained an unsigned and undated entry by a person other than the QC< inspector; and a QC inspector )
was verbally instructed to disregard a stopwork notice. l In addition to the several investigations of allegations, an investigrtion of I l an altercation between a construction engineer and a QC inspector was conducted i in May 1979, and was documented b Inspection Report No. 50-49E/79-04; 50-499/ 79-04. The incident was confirmcd, but licensee actions were considered appropriate and no items of noncompliance were identified. l l Significant civil / structural problems identified and reported to Region IV by l the licensee curing 1978 and 1979, in accordance with 10 CFR Part 50.55(e), included unconsolidated concrete in the slab under the spent fuel pool in the Unit 1 Fuel Handling Euilding; a dimensional error in the base mat of the Unit 2 Mechanical / Electrical Auxiliary Building (MEAE2); placement of Category I backfill over a clay ramp in the MEAB2 arsa; concrete void behind the liner plate in Lift 15 of the Unit 1 Reactor Containment Building (RCB) exterior
7'-- n' ,' wall; and concrete voids in Lift 8 of the Unit'l RCB wall. The-voids in Lift '! 8'and later in other areas of the Units 1 and 2 RCB exterior. walls were identi-fied by the' licensee as.a-result of Regicn IV concerns which were expressed following the disccvery of the voids'in Lift 15 of the Unit 1 RCB. 4 Region IV issued 'ive Immediate Action Letters (IAL) to the licensee during the period January 1978 to November 1979. An IAL confirming a licensee
.l imposed stopwork order on concette placement in the RCB1 was issued in l September 1978,- The stop work resulted.from problems concerning installation -
and inspection of Cadwelds 1dentified during the investigation conducted in i i Septem;er 1978. An IAL concerning impropor storage of reinforcing steel was l issued in April 1979. The IAL was the result of. reinforcing steel storage discrepancies identified during an inspection (Report No. 50-498/79-05; 50-499/79-05) conducted in April 1979. An IAL confirming a licensee imposed stopwork order related to placement of safety-related concret.e was issued in June 1979. The stopwork order was the result of.the discovery of concrete voids in Lift 8 of the Unit 1 RCB. Another IAL was issued in June 1979 which confir:ed the partial release of the stopwork order for safety related concrete but continued the stop work for RCB exterior shell wall placements. An IAL issued in September 1979 involved relece of the stopwork order affecting RCB
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shell wall placemeats. 1 1 In accition to the ten investigations performed during the July 1977 ta j Novecher 1979 period, a special Mid-Team QA inspection (Report No. 50-498/79-13; 50-499/79-13) was conducted during the week of August 6, 1979, on an I 1 l
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l; - . a * { .. accel'erated schedule. NRC participants in the inspection included two Region IV inspectors, the RRI designee from Region ~ III, and an Inspection ' Specialist . l frem Region'II. Five items of noncompliance related to QA program implementation were identified during the inspection. l ictor Resident Inspector (RRI) was assigned to the! South Texas Project on August 26, 1979, and assumed resident duties on September 2,1979. On November 2, 1979, the RRI was contacted on site by a Brown and Root QC inspector viho alleged ; that civil QC inspectors were being harassed and intimidated by Brown .and Root construction, personnel. .i III As a result of the allegations received on November 2,1979, past allegations of a similar nature and repeated failures on the part of both HL&P and B&R to effectively correct poor construction practices, a special investigation effort was initiated. The purpose of this investigation effort, conducted over the period of November 10, 1979 to February 7,1980, was to determine the validity of th'e recent ellegations ar.d to assess the effectiveness of the Quality Assurance / Quality Control (QA/QC) program at the South Texas Project (STP). The investigation team reporting directly to the HQ staff was comprised of an iv.'estigator and one inspector from the Region IV, one inspector each l from tne Region I and II offices and two from the Region III office. l l l
The-~ details of these findings _ are described in the-investigation report No. 50-498/79-19-and 50-499/79-19. The items-of noncompliance'resulting from the special' investigation are described in' Appendix A of the trcnsmittal
-letter of this Order.
The allegations of harassment, intimidation and lack of support of QC inspectors were substantiated during the investigation and demonstrate shortcomings in j the manage:nent or poor management attitude and practices at-the STP. Further, the results of the investigation ~ establish that the OA/QC program at the South Texas Project is deficient and does not meet the stanards required to assure that . STP will be . constructed to NRC requirements. Procedural and progra.nmatic inadequacies in the HL&P and-B&R organization have ret,ulted in a failure to identify quality problems and a failure to correct and prevent recurrence of identified problems. The lack of adequate controi-by a&R over safety-related activities and the lack of detailed involvement of HL&P in the total scope of activities associated with the STP has apparently been the reason behind these problems. This lack of detailed knowledge and involvement has hindered HL&P's ability to maintain adequate control of B&R, which for this facility is designer, constructor and provides the majority of the su; port personnel for the quality assurance / quality control program. The South Texas Project QA management does net fully recognize the requirement for QA/QC organizational freedom. This is evidenced by a January 4, 1980 lecture by the B&R Project QA manager to the B&R site QA/QC and construction
4 . and. engineering supervisory personnel. .This lecture which has not'yet been i revised repeatedly overemphasized the B&R QA/QC organization's responsibilities l 1 for. minimizing project cost and maintaining the construction sene.iule. In 1 addition, the lecture stressed the fact that a B&R QC inspector's decisions i are subject to question, challenge and supervisory review and reversal, The inspection of current activities and recent QA records indicate that the QA/QC program has not prevented recurrence of poor concreting practices that at times resulted in voids in structural concrete. A recent example.of this was the lack of ' quality controls during the Unit 2 containment shell void evaluation in December 1979, which resulte1 in severe deformation of the containment liner. - Procedures lacking in clarity and qualitative acceptance criteria; personnel with inadequate training, experience and/or education; and production and scheduling pressures, harassment and intimidation may have contributed to this situation. In the area of soil foundations, serious questions remain as to whether the inplace compacted backfill has met the required densities. When the licensee recently initiated a test program to provide answers to these questions, the QA/QC program failed to adequately review and control this operation, in tnat standard test requirements were not followed. l l H 1 l
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c Althcugh cafety-relatsd pipe i;elding activities are at an early stage at the STP, -
. serious problems- were identified in the areas of welder qualification, welding prccess.centrcls and NDE performance and interpretation.
l Improper i=plementation of the HL&P 'and B&R QA audits and surveillance programs and failure to perform continuous and effective trend analysis of site documents that record problem areas have allowed these conditions to persist. l During the review of backfill instaliation and testing activities two apparent false statements in the FSAR were identified regarding test and' observation work actually performed. (Sections 2.5.4.5.6.2.4 and 2.5.4.5.6.2.5) l At the present tice work involving complex safety-related concrete placement ; l at the site is stepped as confirmed by an Immediate Action Letter from Region IV l dated December 31, 1979 and safety related welding is stopped at the site as cor.firced by an Inmediate Action Letter from Regic:. IV dated April 17, 1980. Potential for future significant construction deficiencies exist if the , l quality assurance program is not improved prior to proceeding to the more l cocplex construction stages of this project. IV Tne f a:ts se forth in parts II and III, above, reflect widespread noncompliance by the licersee and its principal contractor, Brown and Ecot, with 10 CFR Part 50, Appendix B, of the C.ommission's regulations. In view of this past record and the it; rtance of quality assurance during construction of a nuclear power plant,
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'I have determined that the public health, safety, and interest requires that
-this Order be temporarily effective as of this date, pending further Order of tne Co=ission.
V A. Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED THAT, the licensee, holder of Construction Permits No. CPPR-125 and No. CPPR-129, shall show cause , iri the manner hereinafter provided, why safety-related construction activities on the South Texas Project, Units 1 and 2 should not be stopped ninety (90) days from the date of this Order and remain stopped until such time as the licensee completes the following items and submits in writing under oath to the Director, Office of Inspe tion and Enforcement information addressing each of the i et..s: (1) A review shall be conducted by an experienced, independent nanagement consultant, knowledgeable in QA/QC and nuclear construc-tion, of the lic?nsee's management of the quality assurance program to detemine whether the management of the program is adequate to exercise full control over all aspects of the South Texas Project. Consideration shall be given to the revision of organi::ational responsibilities to control the design, procurement and constructier.
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., 1 activities of the 'licenseas prime contractor, Brown and Root, Incorporated (B&R). A discussion'of the pros and cons of each I concept shall be included. The alternatives considered shall include as a minimum:
(a) the present organizational structure where B&R has implemented a Quality Assurance / Control (QA/QC) Program, under the licensee, l 1 l l (b) an organizational structure where all levels of the B&R QA/QC
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organization smuld report to'the licensee yet remain B&R employees, (c) an organizational structure where the licensee establishes a l l l total Q/t/QC organization to conduct the current B&R QA/QC functions, (d) an organiz tional structure where the licensee contract , with
- ancther independent organization to perform the current B&R QA/QC functions, (e) an organizational structure where the lf.censee establishes a duplicate QA/QC organization, in whole or in part, to that of B&P. with both groups performing duplicate functions.
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I l A re:o:cended' course of-action shall.be defined by'the licensee j
. including the schedule for implementation. In evaluating the j i
recc:mendations of the consultant in order to select the-best concept, the licensee shall provide information on how it will exercise its overall responsibility for the QA/QC program including i 1 the management structure, the degree of involvement, qualifica-i tions, staff size, training, and experience. Of particular ir,terest l are the frequency and depth of' participation of upper' t.ad middle management to assure that knowledge of the effectiveness of the y 1 QA/QC program is current, that such persons take the necessary I actions to verify that the various QA staffs are effectively applying good QA controis, and that all personnel have the proper attitude and are applying the necessary attention to de', ail. (;!} A review shall be completed or new data obtained to provide infermation to address the following issues with respect to the i Category I structural backfill: 1 (a) test fill program which established the soil conditions, lift thickness, compactive effort, and equipment characteristics necessary to develop the necessary in place densities, l (t) cer.parison of material (s) tested and described in Section 2.5.4.8.3 of FSAR addressing liquef action with those used in the fields
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'(c) the sequence of construction ot . existing backfill including the i loose lift thickness and number _of passes of 'he t equipment, i
(d) the adequacy of existing backfill material including that under structures founded on backfill, I l l l (e) and the rationale behind the use of 18" loose lifts compacted l
-by 8 passes of the equipment to achieve the required densities. j l
(3) Ar ' hall be made of the safety-related work described below, completitd as of the date of this Order to determine whether such work was properly performed. If repairs are required, JeScribe the extent of the repairs necessary arid the schedule for completion. Alse describe the manner in which the review was completed and extent of the review. (a) Safety-related welding including civil-structural and piping. (b) Safety
- related concrete structures including embedments such as supports and the fuel transfer tube.
(2) The licensee shall cause the Brown and Root, Incorporated brochure titled, " Implementation of the Brown and Root Quality Assurance Program at the douth Texas Prpject Jobsite," which was widely l I l
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distributed to sita personnel and the Aubject of seminars on ! January 4,1980,: rescinded and the associated video tape to be l 1 destroyed or revissd. Further, the licensee shall cause.the ;
. republication of a new.QA Program brochure which has been approved- j by the licensee.which reflects the fundamental philosophies-of. .
10 CFR fart 50, Appendix B, and conduct new semi:<ars with ' Construction and QC personnel on the fundamental philosophies and i standards of the licensee's QA Frogram with' emphasis on the roles ;
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played by the rispective personnel and the underlying purpose of f the Program. i l (5) The licensee shall define more clearly the stop work authority, , temporary or otherwise, including implemr.)tation of the stop work ; authority. 9 (6) The licensee shall develop and implement a more effective system to , i
;rovide for the identification and correction of the root causes of !
the nonconformances which occur. ; (7). The licensee shall develop and implement a more effective system to i
-i yrovide for the cor. trol of field changes in order to assess the impact l l
Of the cesign. changes on tne design. 3 j i
- (E) The licensee shall develop and implement a more effective system of j i: i i record controls. )
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i (9) The licensee shall develop and implement an improved audit system. l I (10) The licensee shall verify or correct if necessary, the FSAR statements . contained in Section 2.5.4, Stability of Subsurface Materials, especic11y Section 2.5.4.5, Excavations and Backfill. l B. In addition, pursuant to the Atomic Energy Act of 1954, as amended, and I the Comission's regulations in 10 CFR Partr 2 and 50, IT IS HEREBY ORDERED THAT: After the responses to Section A above have been submitted, the licensee shall participate in a public meeting with the NRC in a location near the South Texas Project site to discuss the I licensee's response to that section of the Order. Senior representatives of Brown and Root will be expected to participate. , l The Director, Region IV, will inform the licensee and members of the public at least two weeks in advance of the specific time and location of the meeting. C. The Directar, Office of Inspection and Enforcement, will review the responses to Section A, above, to determine whether safety related construction will be ennducted in accordance with Appendix B of 10 CFR Par- 50 of the Commission's regulations, and "ay take, as appropriate, further action.
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VI Tne licensee eay file a written answer to this Order under oath or affirmation within twenty-five days of the date of this Order. Any answer filed shall specifically admit or deny each allegation made in Section II and III, above, and may set forth the matter of fact and law upon which the licensee relies. The licensee. or any other person whose interest may be affected by this Order may recuest a hearing within twenty-five days of this Order. Any request for I a hearing shall be addressed to the Director, Office of Inspection and Enforcement, U. S. Nuclear Regulatory Commission, Washington, D. C. , 20555, with a copy to the Executive Legal Director at the same acdress. If a t. earing. is requested by a person whose interest may be affected by this Order, the Commission will issue an Order designating the' time and place of any such
. heari ne. Such a request for a hearing SHALL NOT STAY THE TEMPORARY EFFECTIVENESS OF THIS ORDER. Upon failure of the licensee to file an answer within the time spe:ified, the Chector, Office of Inspection and Enforcement, will without I further notice, issue an brder Suspending Construction Permit Nos. CPPR-128 and CPFR-129 if the required actions are not taken in the specified time period.
VII In the event a hearing is held, the issue to be considered at such hearing snallhe:
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whether the licensee shall be required to take the actions specified in Section V(A), above, within 90 days of the date of this Ordet. In the event that a need for further enforcement action becomes apparent, either in the course. of- the hearing .or at any other time, appropriate betion will be - taken by .the Director.
-FOR THE NUCLEAR REGULATORY COMMISSION 7
Y Victor StelloWr. g. Director Office of Inspection and Enforcement Dated at Bethesda, Maryland. this 97/ day of A$ A d f , 1980 - v ..}}