ML20151B355
| ML20151B355 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/15/1980 |
| From: | NRC COMMISSION (OCM) |
| To: | |
| Shared Package | |
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| References | |
| FOIA-80-551 NUDOCS 8012180263 | |
| Download: ML20151B355 (73) | |
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os BRIEFING CN INVESTIGATION OF CA-QC PROBLEMS.'. f: (~, 7
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AT SOUTH TEXAS NUCLEAR PROJECT (Closed to Public Attendance)
Tuesday, April 15, 1980 s._.
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1 UNITED STATES OF AMERICA 2-NUCLEAR REGULATORY COMMISSION 3
4 BRIEFING ON INVESTIGATION OF QA-CC PROBLEMS 5
AT SOUTH TEXAS NUCLEAR PROJECT 6
(Closed to Public Attendance) 7 8
9 Rocm 550 East-West Towers Bethesda, Ma'ryland 10 Tuesday, April 15, 1980 11 12 The Commission met, pursuant to notice, at 2:55 pm.
13 John F. Ahearne, Chairman of the Commission, presiding.
14 PRESENT:
15' Chairman Ahearns Commissioner Hendrie 16 Commissioner Bradford 17 ESO PRESENT:
18 19 W.Dircks K. Cornell 20 M. Malsch, J. Murray
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21 V.Stello C. Seyfrit W. Hayes 22 R.
Herr 23 H. Phillips R.
Shewmaker H. Thornburg i
24 R. Fortuna Seidel 2S J. Hoyle l
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PROCEEDINGS 2
CHAIRMAN AHEARNE:
The Commission meets in a c1cse-3 meeting.
4 MR. STELLO:
We are here to discuss with you this s.
5 afternoon the results of our enforcement di.fficulties for the construction activities in the South Texas Project.
6 There is a long history associated with the 7
South Texas Project that goes back, I guess a couple of 8
9 years ago, and even some recent allegations we have receivedasrecentkyasdaybeforeyesterday.
10 S
that the issue on the adivsability on the 11 problems involve 2 with the quality control at South Texas 12 has been quite high.
It has been the subject of censid'erabl 13 news media interest, it was on the national televisien 14 and the problems have been ---
15 CHAIRMAN AHEARNE:
This was also a result of g
Mr. Gonzale='s amendment wasn't it?
7 MR. STELLO:
Mr. Gonzale: did request an FBI 1g 1
investigation into the issue.
g CHAIRMAN AHEARNE:
I think it is also what l
20 led him to put in an amendment, making it a crime to try to impede into quality control inspectors.
MR. STELLO:
It wasn't clear.
i 23 COMMISSIONER BRADFORD: Do you look on this as 24 one continuing investigation or have there been 5 or 6 l
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different investigations?
2 MR. STELLO:
There have been 5 or 6 different 3
investigations, and there are still some on going.
OIA
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4 for example, was still looking in to some of the issues as 5
the result of the invest'igations in the effor.t with the 6
FBI work, and the results of the work that the Region did y 7
The briefing, and the purpose of the briefing,.to 8
get that up front, is I think at the point we are going to 9
decide:
what's the appropriate enforcement action, based 10 on what e,have found as docu=ented in the draft report 11 that we sent to you.
We think that we are at the point 12 now where it is ti=e to take some sort of action.
13 We are g ing to be describing to the Commission, I
14 at least in general terms what course of action seems to 15-be warranted, based on what we understand today. I will make the point that things continue to move, and we continue 16 to get more information, and as this new information comes g
in, we might decide to change our minds and take a different yg course of action, but based on what we know today, to g
stop shop today, hopefully we could conclude to brief you as to what we understand and can describe to you the kinds of enforcement action we feel is appropriate, and hopefully, have some sort of agreement, at least in principle 23 that this is the correct way to go or if we need to do more, 24
.to have some understanding of what that more might be.
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1 With that introduction, let me ask Bob to go 2
through the briefing now.
I would prefer not tio use 3
that overhead, which I think would be a distraction to 4
everybody, and to just pass out copies of the slides if 5
that would be easier.
6 CEAIRMAN AHEARNE:
I'm presuming the people back 7
here have copies?
8 MR. SEEh h E R:
I think we have enough.
We 9
brought 25.
10 CEAIRMAN AEIARNE: Bob, you are?
11 MR. SEEhhER:
Bob Shewmaker.
12 Okay, the Attachments you got that is Appendix 13 5, in the advanced copy of the report that we sent, we 14 didn't have a clean copy of that document when it was 15 printed.
I CEAIRMAN AHEARNE:
I'm going to suggest that f
16 k.7 Mr. Stello could identify for I&E a certain kind of 18
-marking pencile that would be able to be xeroxed and be legible.'
I find that so far, this is a second.in a series 79 f documents in which the outlines of things are 20 unreadible in them.
21 MR. STELLO:
Some of the documents we get are mar ed dat way and it becomes difficult.
I think the 23 E#*
us documents you are referring to were copies that 24 we received frcm cthers, and that's the way they were marked 25 e
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MR. SHEWMAKER:
Okay, the purpose of the 2
investigation was ticked off, the most recent investigatien 3
was one of two fold.
First, was to address the allegations 4
that dealt with harassment /ir.timidations of quality control 5
inspectors at the site, and the allegations basically were 6
that the construction personnel were causing this pressure 7
and creating these situations.
8 CHAIRMAN AHEARV.E: The allegations came through
'from where?
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9 10 MR. SHEWMAKER: They came from one individual on the 2nd of November, and those were characterized and 11
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12 broken down into 12 specific allegations.
CHAIRMAN AHEARNE: Did that individual represent 13 himself, or did he represent a group.of quality controllers.
14 MR. SHEWMAKER:, He represented himself, but in 15' the allegations that he made, it covered things that had 16 happened to other people.
So he had charac'terized, 17 generally what he felt had been going on and the things 7g
.that he had heard and talked to other people.
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20 MR. SHEWMAKER:
No.
Th'e most recent is ---
21 MR. STELLO:
Because there are two Februaries.
22 The first was in February 1977r was by and we are going to cover that a little bit and the background.
The l
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most recent ones that were behind the present investigation 25 i
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was February of this year.
Maybe we ought to use some 2
of these names so we can keep the two separated.
3 MR. PHILLIPS:
My name is Phillips, I'm the 4
Resident Inspector for South Texas.
Just a little bit 5
of clarification.
5 6
This individual did represent'four other 7
inspectors.
8 CHAIRMAN AHEARNE:
Thank you.
9 MR. SHr M.R:
Maybe we can add in right
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10 here, the total of the previous investigations has been 11 something;11 separate investigations that have been cartied 12 on before this big investigation was kicked o'ff this 13 Novamher. So there was a series and we will go in to the 14 background.
15 The second part of the investigation was to
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16 review the current, at the time, Novembdr'of '79, i
17 effectiveness of the quality assurance program as it was
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18 being implemented at the site.
The concept there was 19 pick enough areas where work is currently going on, look and see if the QA program is functibning, we have go't to 20 21 get sufficient sampling and enough detail to be able to draw a conclusion.
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those were the two' basic g6als and aims of 23 O* 1^vestigation.
24 2S What we are going to do now is give you a brief en O
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1 what the findings were so you have the bottom line a little 2
bit early as we go through.
3 In the QA/QC area, the findings, the ones that 4
we consider-really critical were aginst three of the 5
criterion Appendix B.
6 The first being -- the first criterion which 7
deals with freedom of the QC organization to function. An.d 8
we identified the lack of independence on their part of 9
a cost and schedule and the freedom to identify problems.
10 CHAIRMAN AHEARNE:
Now, is that an explicit 11 criterion in our ---
12
' MR. SEEWMAKER: Yes, the words cost and schedule are used in the criteria; and freedom to identify problems.
13 What we found in the investigation -- we sort of 14 15-
. broke'it down in to five reas, and we have findings and ExamP es of production pressure ---
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CHAIRMAN AHEARNE:
I'm sorry to stop you, but 17 could you be a little more -- tell me what exactly the 18 linkage -- the independence of cost and schedule is in 79 8
ur riteria?
Obviously I'm asking, because having 20 read this I'm quite interested in it.
MR. STELLO:
Maybe it would be easier to read it.
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23
" Criterion.I,.the Applicant shall establish, 24 i
at the earliest practical time, consistent with the
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which implies to criterion I,"
which is a little ambiguous.
2 There are five parts which gets to the cost and schedule, 3
do you want to hear everything?
4 COMMISSIONER N RIE:
Somebody call CP&L and 5
ask them to prht a copy for Vick'.
6 (Simultaneous discussions.)
7 MR. MALSCH:
It is in Criterion I.
8 MR. STELLO: What does it say, Marty?
9 MR. MALSCH: It says --
10 MR. SEYFRIT:
It says:
"Such persons and 11 organizations shall have sufficient authority in 12 organizational freedom to quality problems,.i'nitiate 13 recommend or try to provide solutions and verify implemen-14 tation of solution.".It doesn' t have the words ---
15 MR. MALSCH:
"Such persons or organizations J.6 performing quality. assurance functions shall report to a 17 management level such that this required authority and crganizational freedom, including sufficient independence 18 from cost.and schedule when opposed to safety considerations 19 are pr vided."
20 21 CHAIRMAN AHEARNE:
Including -- say it again?
22 MR. MALSCH:
Including sufficient independence 23 from cost and schedule when opposed to safety...."
24 CHAIRMAN AHEARNE: Fine, thank you.
25 COMMISSIONER HENDRIE:
That's correct.
Criterion I
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CHAIRMAN AEIARNE:
I'm sor.".f, go ahead.
2 MR. SHEWMAKER:
What we had done was group the 3
examples that we found in the 'five groups, production 4
pressure, lack of QC management support, which has been one 5
of the things that came out of the allegations, harassment, 6
intimidation and threats, physical threats against the 7
person, and we will go in to the details of this.
a Under Criterion 15, we basically -- which 9
deals with non-conformance of how one tracks and handles 10 those, these will not be the exact wo.rds out of there, 11 but I will try to characterize them.
They fail to control 12 and monitor the trends of the nonconfornances.
They 13 would identify a single nonconformance, but to look and see how the total of those affect what is happening at 14 1,5-the safety of things was.not being done.
on criterion 18, which deals with the audit, 16 the fact that you need the audit function, we found that 17 they had failed'to adequately utilize the audit function 18 t
in performing the total of the QA program, things like 19 that.
Audits were not completed as specified in the 20 schedule.
The audits weren't in depth sufficient to find the kindh of problems that we sought, 22 i
So in 1 coking at the -QA/QC program, really the 23 i
finding is that we see it impaired the QA/QC programs.
24 CHAIRMAN AHEARNE: There is nothing implicit then, l
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in the criterion that would cover hassling, intimidation.
2 MR. STELLO:
What it is, it says that the 3
people who have the responsibility to construct the 4
plant are putting too much pressure on' the CA people 5
and you really don't have the freedom to go. ahead and stop 6
the conflict er get QA activities corrected.
7 MR. SHEWMA.KER:
One of the other things that we 8
didn't cite here, that I think comes out in this is the 9
fact that the person who initiates or identifies an ite=
10 of nonccmpliance is. supposed to be on the end of the 11 chain after it goe5 up in resolution state, so that he Waeds ' how it was resolved or if it was washed away 12 whatever happened.
And that was not happening. So' 13 this is why, then, we saw some of these people continually 14 bringing these allegations up, but they 'never knew what 15
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16 CHAIP EN AHEARNE:
I guess what I'm trying to 77 get at or your answer is that it is covered under 18 l
organizational freedom.
I could see that on one set, 19 the lack of a system being set up, and for example the i
point that you just made, it..is more of a systematic 21 problem.
22 On the other hand, I.can see physical 23 intimidation competing with the organization,looks as 24 though it has gotten -- you are saying they both are 25 1
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covered under that.
2 MR. SHEWMAKIR:
Criterion I would be really, the 3
only one that would address the kinds of things like 4
harassment, or at least that was our assessment.
5 MR. STEIlo: There are what, 18 criterion 6
independent of 37 The first one gets to this issue 7
pretty well.
I don't think that there is a great debate 8
that clearly says the kind of thing you saw would have 9
been harassment / intimidation, the subtleties of the system.
.10 That clearly is not what you would anticipate as a health 11 criteria.
12 CEAIRMAN AHEARNE:
I wasn't implyi:Tg that I 13 thought it was a health situation.
14 MR. STEIlO:
No, no.
Those kinds of things 15' are spoken to.
16 MR. SEEWMAKER:
In the second major -category 17 on findings, we 'put in what we call safety, and there were 18 two items there and we will describe in detail why we 19 have these there.
We ended up with questions concerning the 20 adequacy of safety related backfill, and as vick indicated, 21 there have been some developments that are happening right 22 n w, and we will ti y and bring y'ou up to date on those 23 when we get to'the back of the briefing on the related 24
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1 Then there is a group of unresolved safety items 2
that came out of the investigation team.
We had to end 3
it some where and there are items identified that have to 4
be followed up, which are the normal kinds of things we 5
find on inspection investigations.
6 Now, we will turn to the next page and cover 7
the area -- I will,give you some more background on this --
regarding the scope of the previous allegations.
8 9
CHAIRMAN ANNE: But as far as any of the
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10 other -- such as the concrete and that stuff, you 11 concluded there were no safety issues?
MR. SEEWJutER: We will address the.cnes that 12 we think are still to be resolved as the result of this 13 investigaticit.
I just wanted to sort of give you an 14 overview of the end point before we got there.
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be,that as far as adequacy of safety related items, the g
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-questions,at least in your presentation, it is only.on i
I the soil backfill or at least that was my interpretation, that you had concluded that the areas such as the concrete was adequate.
l MR. SEMm.R:
Okay, let me clarify that.
22 What we are saying is,for the scope of this i
investigation, out of the allegations that this team 24 pursued, we found no items that would lead us to believe 25 e
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that there is a safety problem.
1 2
Now, we are still looking at things from the 3
past that weren't covered in this investigation.
4 The first allegations on this plant were back 5
in February of '77, and as we indicated, there was a 6
series of allegations coming in and there were a series 7
of investigations to come of those as they came in.
There 8
were a total of 11 separate investigations carried out by 9
Region IV.
Something on the order of 53 allegations, which 10 is a matter of how'you cut them up sometimes, but on that 11 order of the magnitude of allegations.
12 About 14 or a nu=ber like that, 14 or 15 of those we substantiated.
Now, while these were being conducted 13 14 by the Region, they did not have authority to take sworn 15-statements.
We did find.that one of these individuals
- '16 was talked to both by Region IV in the earlier allegations, and as the result of these sworn statements taken in this 17 I
investigation the story has changed.
Whether that t
18 happened in other cases, we really haven't really 9
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As Vick indicated, there was considerable interest because of the number of these, the media, Congressional interest and as the result of this,.the mid term inspection schedule was moved up by a year frem 1980 to 1979.
So that mid term QA was kicked off in 4
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j August of this past year.
Some of the findings,of not 2
in compliance that came out of that mid term QA, 3
correlate to some degree of some of the findings of this 4
recent one.
I will just mention what they are.
j 5
out of the mid term QA program or' inspection was 6
found that one of the subcontractors was not following his 7
bAmanualorprocedures,proceduralviolations.
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8 adequate audits by the utility and Brown and Root on that 9
subcontract.
l 10 Audit check lists were not maintained 'in the file 11 system.
Those records that had been made were not in the 12 files for the people to.use and try to make trend analysis 13 on.
28Y failed to identify changes in the organization 14 15 in the subcontractor, the QA organization.
Those were the 16 kinds of things that came out of that mid term.
17 The FBI has been involved in this case ---
CHAIRMAN AHEARNE: Who ordered it?
ig NR. SHIWMAKER:
I guess Gonzalez, basically.
gg ney were 1 ng a e p estion of fals m ed 20 re rds.
There was a question of trying to establish 21 s
e rec rds related to the Cadwelding and locations of the 22 cadwelds.
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Now, they were investigating over the period of June to October, and they have sent their material to the I
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prosecutor down in that area, and on December the 4th, in 2
a letter to CGC, Justice declined further prosecution on 3
that case.
They did find two instances of false records, 4
but it turns out that they are things that are not 5
required as far as the NRC and as far as safety related.
6 TheY were commit =ents on the part of the licensee, for 7
his own use.
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' COMMISSIONER BRADFORD:
Commitments made in g
what context?
10 MR. SEEWMAKER: Basica11y what happened, they i
11 were trying,from the records they had, trying to establish exact position in' horizontal and elevation, where the' 12 actual cadweld splice was located in the placement or
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13 in a concrete placement.
This was after the Cadweld splice 1,
had already seen accepee<> as passing a11 of the requirements.
13 so really, once the splice is accepted,. there is really g
no need to know where it is.
It is where you are maybe g
building 100 spiir,es and you are only testing two out 4
of 100, you want to know where that group of 100 is in case your sample.i fail, to go back and find out where i
those are that might be questionable, because the test sample somehow didn't pass the test, but these had already 22 passed the test, so there is no need to identify those.
23 i
COMMISSIONEE BRADFORD:
There is a co=mit=ent, 24 i
though?
In what form is the licensee going to take?
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1 MR. SHEWMAKER:
I cannot say whether it was in 2
a procedure or a spec or where?
3 MR. SEYFRIT:
It is in their internal procedures, 4
really that they have set forth that are desired.
5 I'm Carl Seyfrit.
And while it is not something
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6 that is required by NRC regulations, the fact that they 7
commit to it in their procedures, we attempt to make sure 8
that they follow their procedures.
So we, indeed, I believe 9
cited them for failure to have followed their procedures, 10 in spite of the fact that they are not required by our
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11 regulations.
12 MR. SEEWMAKER: So that was the involvertent a*.
-13 Justice and the FBI and OIA has indicated that they 14 would keep Justice informed of any new developments.as i
15 the result of the investigation that we have going on.
16 They were aware that that was underway.*
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17 COMMISSIONER BRADFORD: Does your investigation ig have a review of. the FBI interviews?
gg MR. SEEWMAKER:
It did not.
MR. THORNBURG:
OIA has looked more in that 20 respect to those things.
We fixed on a time period that i
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would be overlapped to the November 2nd allegations.
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tried to look at the near term to see if harassment and l
23 intimidation was sort of a' continuing thing and looked at the I
I QA picture at about that time.
And OIA has looked more l
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in to that.
2 MR. SEYFRIT:
I might add that we did get 3
copies of the FBI's report.
In the Region we went through 4
it and tried to glean from it, any items.that might be 5
alleged that we had not previously been aware of..And 6
we did find, I think, two or three that we had not been 7
previously aware ef, and we did, indeed, look in to these 8
in some of our later work.
9 CHAIRMAN AREARNE: Is someone from OIA here?
10 MR. STELLO:
Yss.
MR. FORTUNA:
What is'that document date?
11 CHAIRMAN AEIARNE: What is the letter that you 12 are 1 king at?
13 MR. FORTUNA:
It is the letter dated l
14 15-December 4th, as Mr. Shewmaker says, addressed to Mr. Bickwit, the General Counsel, from the Attorney General 16 down in the Sou*he District of Texas, and indeed, that the g
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no substantive violations, and including a copy of the Bureau's report.
I was just curd.ous as to what it was.
CHAIRMAN AEEARNE:
Marty, did we write to them?
MR. MALSCH:
I'm not. aware of it, I'm not sure.
23 MR. FORTUNA:
Yes, we were all aware of this.
24 In fact, the declaration was contained in the FBI report and 25 s
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I am familiar with this.
2 MR. STELLO:
Let me see if I can -- Gonzalez 3
wrote a letter
.to Bell requestion that this letter 4
be investigated..
Bell, in turn, requested the FBI to 5
look in to the ihatter. They looked in to the matter, wrote 6
their report which went to the Attorney General in the 7
state, who, in turn, decided not to prosecute.
8 MR. FORTUNA:
Yes, the two things came up.
One 9
was independent of the other.
When Gonzalez wrote to-10 Bell, Bell bucked it down to Civiletti who was then in 11 charge of Criminal.
They it got bucked further back down 12
'into the bowels of Criminal Division of the Justice 13 Department.
Headquarters was then aware, that their region, which they called the United States Attorney's 14 ffice, was in fact doing. this investigation.
15 We t ld headquarters in Washingt6n that their 16 region had declined, and that was confirmed in this last 17 t.ece of correspomdence, in this 1.tte= ee us eo Bickwie, 1,
that we are aware here on the record.
And that's 79 why there is still on-going Justice Department interest g
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in it at their headquarters.
They are still mildly 21 concerned that the letter which Gonzalez sent to them, 22 a year ago this time, whereby they rote back to this 23 agency to another office, OIA sent a monitor to take a look see, in conjunction with the office of' Inspection and 1
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1 Enforcement, so the left hand will know what the right 2
hand is doing.
That was the only thing that co'ncerned me.
3 CHAIRMAN AHEARNE:
It happens all of the time.
4 MR. SEYFRIT:
It might be worth mentioning too, 5
at the same time, this letter went to Griffin Bell.
It was 6
the letter that was sent to the Chairman of the Co= mission, 7
Mr. Hendrie. receive,d such letter that discussed the same 8
issues, but without specific reference to the request for 9
Justice Department to get involved.
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10 CHAIRMAN AEEARNE:
Now, does CIA still have some 11 on-going work on this?
12 MR. FORTUNA:
This is the status of what we i
13 have.
14 The ene gentleman that we could afford to 15-pick out of the South Texas thing, per the arrangement that was made with OIA and I&E, Mr. Thornbu'rg, Mr. Cummings 16 and Mr. Stallo, or particularily Mr. Thornburg, that 77 we w uld take a look at each district, that the special 18 task group which did t.% final on that mid term inspection, 19
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"I 20 and looking at the allegations that have been made in about August or September,that time frame.
We have a wrap-up as to the field work. We do not have a wrap-up as to a report, which is going to be in the form of a memorandum down to the Department and 4
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So they beat 2
us, so to speak, on the present status of the site.
We 3
are looking at it back in time, only as to harassment, 4
intimidation and that sort of thing. Anything that we 5
glean along uhe way frem our interviewees r'egarding 6
potential safety issues, gets sant back 'to I&E.
7 As I was saying a little earlier, we have finished
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8 this pocket of work here,'we still have threads that go 9
out and we can take a look at those kinds of questions.
10 Does that' focus on where we are?
11 MR. STELLo: Yes.
As I understand it, based on 12 what you have found this far,is consistent wi'th the 13 results of what the task group has found.
You have not 14 found anything that suggests that we have taken any wrong 15 turns in the harassment and intimidation and things of that i
16
' sort or have you asked different questions?
17 Have you found something that we ought to know 18 that is of any problem of any kind?
MR. FORTUNA:
Any interview statements that we 19 s
take have been dribbled off to your effice as we take them.
20 However, we are going not going to make a recommendation 21 kind of report, we are going to wrap it up, tie it together 22 and you can analyze it and make'ydur own judgment.-
23 MR. STELLO:
I did try to get the point across 24 2S that based on -- I understand that OIA ccme up with 4
a
m
'O.-
j 1
.J 131 21 1
the same consistency that.we have come up with, so that 2
we don't have any concern that there is any surprises.
3 MR. FORTUNA:
I don't see any surprises in what 4
we have done.
It is just more of the same as opposed to 5
somet. Sing different.
6 CHAIRMAN AHIARNE: Fine.
7 MR. SEEWMAKER:
I think we have finished.'OIA.
~
8 The Resident Inspector was ass,igned to this 9
site in late August of 1979, and by the way, we do have 10 the special Investigation Team here today to answer any 11 specific questions, and the Resident Inspector was a me.=ber 12 of that team.
13 As we have said before, the allegations that were 14 investigated here numbered ~12 when they were boiled down.
15' As the result of the investigation, 19 additional allegation 16 were developed.
Mr. Stello directed the Special Investigation 17 on Noved er 3rd.
yg CHAIPMAN AHIARNE:
Vick, was that triggered by yg this set Of allegations to the Resident Inspector?
MR. STILLO:
In part.
It was also the result of g
what -- the FBI report, any new allegations, we decided 22 that we needed a rather thorough look at those questions 23 to decide whether there was an issue here and to somehow deal with it correctly.
My feeling at that point was that 25
Jg 22 1
of the investigation, I wanted it to be independent of 2
. what the Region had done, in an effort to get an independent 3
look beyond the investigations that they had done, since 4
at least what they had come up with and what the FBI had 5
come up with, the new allegations suggested that perhaps 6
it wasn't being tied together the way it should, and I 7
decided that the Task Force may be able to look at. it, 8
in part, the other concerns.
~
9 MR. SHEWMAKER:
The team that was put together, 10 we tr'ied to get people from the different disciplines of the areas that were specified that we would icok at. So 11 we had some one in the civil area, soils, welding and 12 in the QA/QC area.
The team was run'tnder Headquarters 13 direction and we had representatives from all of the 14 Regions except Region V..
15 As I said before, this investigation was 16 different in that -- different from the earlier investigatic 17 gg
. that had been done on South Texas in that the Team had the authority to take signed sworn statements.
g They actually conducted 57 formal interviews, 20 and took 24 rworn signed statements. There was scmething like 50 less formal interviews made.
22 The time period covered from November 10th through February 7th and it involved some 1100 inspector hours.
The areas that we covered by the investigation, 25 6
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m Q
3 133
=
s 23 I
1 we were really in some five major areas.
2 Category I, concrete structures,
. the area 3
that most all of the allegations had been related to, 4
that activity area of concrete placement in the civil 5
area.
i
~
6 The other, areas that we wanted to look at, but 7
in order to try And evaluate the effectiveness of the 8
current program in the QA/QC, included soils, welding a,nd 9
NDE, the. handling"of audit reports and nonconformance to 10 general, and the audit function.
Very little welding 11 had actually been done at the time, and of course, 12 nothing was really being done in the electrical area.
13 We indicated in the transmittal letter of the
- 14 early draft of the report that we would. try and have it 15' finalized today, but we do not have it finalized.
We are 16 going to be having a meeting after this' session to try 17 and finish it up.
There are some changes, really nothing 18 major.
I might point out one that you might consider, if 19 somebody is really counting numbers it might change somebody 20 idea, but on Page 2 of the draft, and this is the one 21 that is dat,ed April 9, 1980, under that paragraph that is underlined that says:
".Results" about a third of the way 22 23 down the page or half way down, it says:
"8 of the initial 24 12... ",
that should be "9".
We had one that was a partial 2S that we looked at in the lasu couple of days, and we decided s
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we need to throw that in to a nonsubstantiated.
2 In the second line there, where we say:
"Two of 3
the initial 12 were partially substantiated.."
it should 4
read:
"One of the 12 was. partially substantiated."
5 We will, of course,' transmit copies of that 6
as soon as it is final.
The last person came in today, 7
that was able to sign it.
One person had a series of 8
heart attacks so he won't be signing.
He is still out.
9 We have passed out the Appendix 5 which should 10 replace the one that was in the earlier version.
Now, to' get to the results of the investigation 11 in some detail, and I don't know how much detail you. want 12 13 9"
' "*"can look at which of the allegations we felt. fit in to the five categories that we had in the g
15 "I "
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i independence of the QC inspectors.
l 16 l
Under threats, we basically had what I considered, 17 really three very strong ones where we had a situation that l
had a threat by someone that we would consider in a management function.in the construction side of Brown & Root.
In one case it was a construction ~ superintendent, and in two other cases it was a foreman.
And in all 22 l
cases, the person who was alleged to have made the threat 23 l
admitted to making the threat, and in all three of these 24 cases admitted that it was made under a loss of temper?
25 e
sai
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CHAIRMAN AHEARNE:
What kind of a threat?
2 MR. SHEWMAKER:
I think you would characterize 3
them as a threat of physical harm.
4 CHAIRMAN AHEARNE:
By " characterize,"
do you 5
mean that they were?
~
6 MR. SHEWMAKER: That's right.
Bodily injury.
7 COMMISSICNER BRADFORD:
I ought to stomp you 8
around.
9 MR. THORNBURG:
That's getting close.
10 MR. SHEWMAKER:
We saw scme instances of 11 harassment, the type of thing, one that I recall a 12 construction person w&s boasting around the dits that 13 I was able to get away with this particular procedural 14 violation while this QC inspector was there.
And that 15' QC inspector heard that as a rumor.
That is the type of 16 thing that underminds and harasses that-QC inspector.
17 The Attachment 5, which has the Brown and Root 18 corporate policy, they had a meeting where that was given 19 as a speech, then it was later printed and handed out to 20 everybody.
CHAIRMAN AHEARNE:
I gather, by the fact they 21 went to the difficulty of actually printing this they 22 felt that was fine.
23 MR. SHEWMAKER:
They did believe that.
24 That, to me, is an example of harassment, and the 25 s
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A
'Q j
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statements that were macke to QC people about:
Well, you 2
may not be here much longer; that sort of thing.
- Threats, 3
verbal type harassment.
4 We have exa=ples of intimidation.
The case of I
5 A-52, we wanted' to lock at that particular one.
~
6 This is a case of where he did something because, 7
he felt his supervisor.would not support him.
In other
~
8 words, he took an action based on what he was expecting 9
or the way he.was expecting his supervisor to react.
So 10 he was intimidated by what that suprvisor told him in the 11 past.
12 The lack of man 4gement support, that was one of the allegations -- one of the things that came through on 13 a lot of the allegations that the low-level QC inspector 14 identify something, and will not, say sign'off on a 15 Pour card which would release construction to go ahead 16 with construction.
It hoes up to the supervisor and maybe 17 another level up, and that supervisor was being -- would gg get in to a discussion with construction, and the supervisor 19 wu s gn n
verr ding de CQ -- low-level QC 20 l
inspector.
The QC inspectors ended up with a feeling that:
i 22 well, why should I flhg it, everytime I flag it somebody j
23 is going to override it, a situation I don't think, is one 24 would generate a feeling on our part that all of the 25 l
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27 1
problems are going to be identified and properly taken 2
care of.
3 CEAIRMAN AEEAENE: But certainly I would have 4
viewed this as management support.
5 MR. ShTdMAKER: The paper itself, yes.
And i't 6
brings in the cost and scheduling, you know.
7 CHAIRMAN AHIARNI:
That not only brings it in,.
8 that makes it.
9 MR. SHIWMAKIR: Right, and it is repeated often.
10 Production pressures, the instance that I remember 11 most vividly is probably the one that there was a hold 12 up by QC, they knew all of the high-level coristruction 13 managers were standing around, the concrete was on the 14 way, and everybody was trying to get.the QC to sign off.
15-They had a very short time and in some of the instances 16 they had actually reviewed the placement, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> b.efore, and they found out that construction had gone back in 17 and done some additional work, then the QC would go in 18 there and would find' additional problems.
19 "I
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20 P#*******
21 All of those things together really built a finding against Criterion I, th'at basically says there is g
a lack of required independent QA function and we did find one or two nonccmpliance examples'in these five 25
(
6
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A "138 23 i
t 1
categories.
2 The other significant quality related problems.
3 First we would put in the area of the civil QC inspector 4
qualifications, and civil procedures.
The finding there 5
that we actually had four items of noncomplaince.
The 6
one that would be, I think, the most significant is the '
I 7
question of what we found in the failure to folicw.their, g
own procedur'es in qualifying the QC inspectors.
There g
were instances found where QC inspectors did not have 10 adequate training or experience for the job that they were 11 assigned to do.
MR. THORNBURG: This could feed to 'the intimidation 12 and independence thing, because l'f the guy isn't too we'll 13 qualified and starts nit-picking the construction foreman, 14 he is under pressure to produce, and I think that also 15 P ays a' role too.
l i
16 COMMISSIONER BRADFORD: When you said the people p
aren't qualified, which standard are you using?
MR. SHEWMAKER: 2cse basically were the standards that Brown & Root had established which do reference scme 20 of the ANSI standards.
21 COMMISSIONER BRADFORD:
They are underqualified 22 4
by Brown.& Root's own standards?
MR. SHE*dMAKER: Right, which incorporates sc:::e 24 6
of the ANSI standards.
25 COMMISSIONER BRADFORD: We have a Reg. Guide on standards?
-- --.--.--.z..
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29 1
MR. STELLO: That's what I have asked Minogue to 2
develop.
3 MR. THORNBURG: There is a Reg Guide in this particular area, but the definitions a; e not as tight as 4
5 we believe they ought to be.
6 COMMISSIONER BRADFORD:
Does that Reg Guide apply 7
to this plant?
' ~
8 MR. THORNBURG:
I would assume so.
9 MR. SEYPRIT:
I'm not sure that it does.
Reg Guides typically apply only when they e= brace them as part 10 of their submittal, and I don't know, in this case, 11 specifically whether they did or not.
We do.know that they, 12 e= brace scme of the ANSI standards and those are the ones 13 that are really at issue here.
But I'm not.really sure 14 15-whether they embrace the, Reg Guides or not.
MR. DIRCKS: Whatever it is, I.think we ought to 16 look at it.
77 COMMISSIONER BRADFORD: But that cccmitment is 18 I
enough for you to inspect against, to line up their g
qualifications against the ANSI standards?
20 MR. THORNBURG:
(Nods in the affirmative.)
21 MR. STELLO:
We can inspect against what they 22 have.
The issue is, is the standard which applies to I
this activity good enough?
The conclusion is that it l
24 l
is not, it needs to be upgraded in a better, either Reg Guide 25 l
\\
(
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- 7..)
140 30 1
or Regulation and promulgated that will beef up 2
considerably the requirements for CQ inspectors.
l 3
CEAIRMAN AHIARNE:
Is that equivalent to saying 4
the ANSI standard is too?
5 MR. SHEWMAKER:
Yes'.
6 The next general area is the area of soils and l
i P ank backfill that was looked at in t "f ng to make an 7
8 assessment on the effectiveness of the current QA/QC g
program implementation.
10 We found several areas of noncompliance in that 11 specific area of soils.
Six, to be exact.
We f und failure to comp 1ete compaction in 12 accordance with the qualified procedure.
Failure to 13 documentlift thicknesses in one of the passes which 14 ne has to determine in order to understand what the 15 quality you are actually putting in to place.
We found 16 two failures to control test equipment.
Test equipment g
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18 We found failure. to have a systematic, field sampling program.
We found failure to take prompt corrective action of test equipment failure.
In addition to those noncompliances, we found other questions that home in'on the soils question that we ended up with.
We have seme confesion in trying to identify the materials that were actually.used in 25 e
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laboratory test programs where liquefaction stud.ies, 2
versus the materials that were used in the field.
We have 3
been trying to get that clarified on the phone today, 4
and I guess it is still unresolved as to whether the 5
materials that were. tested in the laboratory for lique-6 faction analysis are actually, in fact,'the materials 7
that were. put in place in the field.
8 CHAIRMAN AHEAR!TE:
You say that there is some 9
question.
Has the question been documented or is there a 10 questien,that exists which is it a question 'that we believe 11 there was a different material tested?
12 MR. SHEWMAKER:
Well, on the basis of the information we have, what brought it to the inspector's 13 attention was the information we had, there was a 14 possibilityweweretalkingabouttwodifferenbmaterials.
15' t
And as yet, we have not gotten the documentation from the 16 licensee that would indicate otherwise.
We are seeking 17 that information.
j gg We also found that we were unable, and they 19 were unable with their records at the time, to establish 20 the field placement sequence that had been reached,'in f
order to try and go back and see in what sequence the g
r l
backfill material was placed.
We have not been able to 3
i get that information.
i We.have a question about the compaction,that G
l
O 15E li 0,.
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32 1
degree of ccmpaction under those buildings resting on 2
this backfill material.
When the last lift was placed, 3
the last six or nine inches of that last lift was to be lef t 4
loose, and in some instances what is done in construction, 5
you come back and cut that material away then fill on the 6
firm material.
They were not doing that.
They have 7
indicated that they have literature that shows that this 8
is acceptable.
We still have not homed in and been able 9
to resolve that question.
'10 There was a question over a test fill program, 11 and the adequacy of what they had done in a test fill 12 program to establ!.sh what lift thickness and how many 13 passes with the patching equipment they would have to make in order to achieve the design densities. -
14
/
/
15 When the team left the site, of course, some of 16 these questions were relayed to the licensee in an 17 exit interview, and the licensee embarked on an exploratory ig-program of this in-place' material, and we are still 19 beginning to get some of the results of that.
So all of that is not yet really analyzed yet.
We will talk about 20 a little bit of that at the end, of this latest information.
21 That characterizes the questions that we had 22
~
in the soils area'.
23 One thing I would like to add before'I go to the next area is that there have not been allegation in this 25 1
-e
- ~.
!.i i
33 1
particular -- this particular discipline has not had 2
allegations in this area.
The only reason that we looked 3
at it was it is a major area of safety related work 4
that has been on-going, and was looked at because of our 5
attempt to.look at the total QA/CC program effectiveness.
6 The next area that was looked at is the welding 7
and NDE area.
The major findings there:we have had.6 non-
~
8 compliances in this area, the major ones being:
failure 9
to test the welder qualifications specimens with the 10 proper radiographic techniques, so that what happens is 11 what ends up with a question of whether or not the I
welders are properly qualified.
This', I believe, the 12 13 number is something like 150 welders' qualifications is 14 a question because of this, i
15' There has not been a great deal of welding I
completed, so if we are going to catch something like this, 16 this was the time to identify it before a lot of high 17 quality welds had been put in place.
18 The other major item in this area was failure 19 to control radiography and the liquid penetrants.
We 20 f und problems in radiography, the quality of the 21 radiographs, probicms in their interpretation of what 22 they.saw in the radiographs.
In the liquid penetrants, 23 I
we saw problems in the indications they had of flaws 24 were not re-examined as required by the code requirements.
I
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The other noncompliances in that area dealt 2
with failure to control documents, documents out of date, 3
not being superseded properly and voided.
Failure to 4
control weld area cleanliness.
Our investigators acutally 5
observed this g6ing on in an unclean situation for welding, 6
and it does effect the welding.
Failure to control design 7
changes in welds, and failure to handle the outdated 8
procedures.
9 The next major area dealt with the -- their 10 methods of handling the nonconformance.
These include 11 all types of nonconformances.
Many sites have assigned different names and. acronyms to the way they handle their 12 13 reports.
At this particular site, they call it an NCR, Nonconformance Report, they also have another 14 f a which is called a FPEA, which is'a Field Request 15 f r Engineering Analysis c.r Action.
16 We f und thati while a ny-of the things had been 17 i entified in one or other of these types of record keeping 18 mechanisms, there seemed to be an attempt to put more of 9
them in the FREA cateogry and the FREAs at the site are not looked at in total.
In other words, I built. up a list of about 1000 FREAs, but no one ever.looks at them to trend them and if I have, say, 50 FREAs on a containment building, no one ever looks at the aggregate of 24 50 together to see what the total effect is.
Each one is
,;5 4
4 5
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33 1
in itself,' isolated.
So what the team found was that things that were identified as discrepancies that we would 2
3 normally see in the -- what we call the NCR group that 4
are looked at on trend analysis, were, in fact, not being 5
classified in to that grouping at South Texas. So we see 6
that there is a total number of discrepancies that fall 7
in to this category that really hasn' t been at all. tracked.
8 We had the one finding in that particular area.
9 Again, that was somewhat related to some of 10 the allegations. The inspectors said, you know, I tried to initiate an NCR which has to be tracked, and they turn 11 around, the supervisor or construction puts the pressure on 12 and it ends up being a FREA, which means none of this is 13 tracked very well, as far as trending and what the total 14 15' effects are.
The next major' area was the area of audits. We 16 found four nonccmpliances in that area.
I think we have 17 to classify all of those as critical, the audits being.
18 really the total bounds in defense and depth that we are 19 lo king at it in a QA/CA program.
We found in this failure 20 f the licensee to provide procedures or to perform l
21 supplemental audits that they had indicated would be 22 perf rmed in their reference documents.
The adequacy and 23 requency f acdits did not meet what they indicated 24 ey u
do.
2S 4
R
.' 5..*
'A
.190 36 1
We,found the depth of the audits by Brown & Root, 2
that they had to perform, were not sufficient.
We found 3
failure to follow procedings to document the control 4
to unsatisfactory conditions, and failures.to t,ake prompt 5
corrective actions.
6 So those in total as outlined'in noncompliances 7
that were found, we have a number of items, as I indicated, 8
we will have to follow up.
Some of them relate to these 9
'five areas I have outlined.
One of the areas that we 10 specifically came away thinking needed beefing up in this 11 case, I think we come out with the impression that we have a situation here where the licensee is, in fact, not 12 Anhin 13 exercising sufficient control over his contractor.
this case this contractor has what I consider the total 14 15 packages.
He is the designer, the engineer, he is the e nstructor and builder, and he also has the QC funesions.
16 S
he has all three parts of the package and in that 17 j
18
-situation, it certainly is important that the licensee
[
have a very close handle on that total scope of work.
19 l
COMMISSIONER BRADFORD: What would happen if 20 he required the QA/QC to be done by HP&L instead of --
g l
well, by a separate entity all together, anyway, not by i
22 Brown & Root?
l 23 l
MR. SHEhMR:
Well, we have -- there was an l
24 instance at one plant where a requirement was placed --
25
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37 1
right new, I guess we would have'to say that a licensee 2
would certainly not be staffed to ever handle.anything 3
like that.
4 COMMISSIONER BRADFORD:
Did you ever have 5
licensees to do the QA/QC instead of the construction 6
company?
7 MR. SHEWMAUR:
Yes, there are licensees,---
You have to look, there is a difference.
Some of them 8
'do it all themselves.
9 MR. SEYFRIT:
There are a number of different 10 combinations that you see.
We have one licensee which also 11 has Brown & Root as the constructor, at Comanche Peak where 12 the utility, while they don't do all of the QA/QC work, 13 they have taken over absolute control of that function.
g
.15.
The QC/QA people from Brown & Root report to TUGCO
-supervisors.
That way, the have taken control, and as a' matter of fact ---
COMMISSIONER BRADFORD: Did that,also come as the result of unsatisfactory experience with Brown & Root?
MR. SEYFRIT:
I think that is probably a fair 20 statement isn't if Phil?
21 s
MR. SEIDEL:
You are talking about TUGCO, 22 Texas Utilities Generating Company, they were dissatisfied 23 with the performance of the corporate -- Brown & Root 24 QA.
They just decided that one day all of the Brown & Root
' ~
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140
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38 1
QA/QC people would report to their company.
However, the 2
QA/QC people still get their pay checks from Houston.
3 CHAIRMAN AHEARNE: Do we see any improvement?
4 MR. SEIDEL:
I would say, yes, some improvement.
5 CHAIRMAN AHEARNE:
Do we have any other examples 6
of Brown & Root?
7 MR. SEYFRIT:' I think these are the only'two
~
8 at the present time that. Brown, & R. cot is involved in, 9
South Texas and Comanche Peak.
10 COMMISSIONER BRADFORD:
I guess I should ask 11 rather than assu=e that because of TUGCo's dissatisfaction 12 was the same sort of thing as seen here, and Inot that,.
13 for example, construction was proceeding too slowly?
14 MR. SEYFRIT:
No, I don't think that it was 15
,that.
It wasn't exactly the same either.
For example, 16 I don't know of any indication that TUGCO had that there 17 was the harassment and intimidation and that sort of 18 thing taking place.
That did not appear to be a factor 19 in their decision, but they didn't feel that the job 20 was being adequately, controlled in terms of the numbers of items reworked and ---
21 CHAIRMLN AHEARNE: Were the numbers too high or 22 too lew?
'~
23 MR. SEYFRIT: They were obviously too high, I 24 n-ey el ey wanted ---
25 4
0
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143 39 1
COMMISSIONER BRADFORD: That's why I didn't 2
assume that.
3 MR. SEYFRIT:
I mean the problems in construction 4
were not being delt with.
5 COMMISSIONER BPADFORD:
I see, they were having 6
to go back and do things over?
7 MR. SEYFRIT:.That's correct, and they wanted to 8
reake sure that the inspection was properly done the first g
time around so that this didn't happen.
10 MR. THORNBURG: So that the work got done properly 11 before the inspection.
MR. SEYTRIT: So those kinds of factors were 12 involved.
13 I might mention that I have had communications 14 15-fr m HL&P, and they have.been -in contact with TUGCO, and they are discussing and considering the. possibility of 16 their taking the same kind of action.
They have not 17 yet made such a decision, and I don't know whether I would
~
18 want to push them in that direction right now or not, but g
I'm not sure that that's the total answer.
You buy somethine but then.I.think you give up some other independence that may be as desirable.
CHAIRMAN AEIARNE: What other indece'ndence do
~
23 you have?
24 MR. SEYFRIT: Well, if EL&P takes over the entire 25 G
9
)
130 40 1
job of controlling the quality assurance / quality control 2
effort, they still have the ultimate end of rap'id 3
construction and so forth, so some of the same driving 4
forces that are present now with Brown' & Root would be 5
present in EL&P.
g 6
CHAIRMAN AHEARNE: So you are saying there is 7
some alternative plan rathe'r than Brown & Root?
8 MR. SETERIT:
Yes, I think frankly, that a much, much stronger EL&P presence on site, without necessariby 9
10 taking over.
11 CEAIRMAN AEEARNE:
I see.
MR. THORNBURG:
We are sort of moving ahead 12 13 in a way.
We are considering encouraging Houston Power and Light to get more involved.
We haven't talked quite 14 about 15 CHAIRMAN AHEARNE:
I will stop my digression at 16 the moment.
Here, you have Brown & Root having 17 18
- construction in two agencies, you have the TUGCO proposition where Brown & Root does the construction and 79 the Brown & Roct people still have to report to the utility.
- Now, you were pointing out that that would s
lose some of the' independence, but ---
23 MR. SEYFRIT:
No, I didn't suggest that it would lose, I just don't think that you gain any independence.
25 G
g 4
A t
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OJ m-r 41 1
CHAIRMAN A N.NE:
Well, to some extent -- Well, 2
go ahead.
3 MR. SEYTRIT: It is not clear.
4 MR. STELLO:
I think it is an area that does need to be looked at, but the~ bottom line i}s there needs 5
6 to be an improvement i. the QA/QC organization, at least,
7 in terms of ths way in which you.are getting the job done.
That's one way. There are others we will talk about' at the 8
~
end.
y MR. SHEWMAKER: Okay, conclusions.
I don't think 10 we need to rehash the first few there.
11 We have reached the conclusion that we have got 12 a CA pr gram that is impaired, we have got lack of 13 independence.
4
- *E*" *^
- 15 only in the civil area.that we have seen.
That is really
~
the only major area that has heavy work activities.
We have really no clear cause that affects relationships resulting in deficient systems and components as a result of this. We don't see, in the l
20 civil area, as a result of this l'nvestigation, any major l
21 problems with regard to safety.
22 CHAIRMAN AHEARNE:
As you went through your 23 l
description, one of the questions that was sort of 24 pu:: ling about it,is that are the quality control pecple not 25 l
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42 1
nearly adequate, so is the fact that they get harassed 2
and pushed around and don't raise their problems, those 3
problems that they don't raise don't seem to have led 4
at least in judgment so far, in safety problems.
That 5
could be because they don' t raise the problem in non-6 safety ' areas, it could be because of the preblems. they 7
raise could be that they are not being very competent
~
8 if the problems they raise weren't really problems.
. 9 MR. STELLO:
Well, that's a third possibility, 10 and even in spite of the difficulty, the job is not 11 getting done, although that the a'ctivity doesn't stop 12 them from saying I don't think you have to irivestigate 13
' them.
And one way to measure that is to look at the end 14 product.
When you look at the concrete of the South 15 Texas project, it doesn't look like Marble Hill.
16 CHAIRMAN AHEARNE:
No, no.
There is anothe'r 17 way had, I'm not sure what would have been done is to 18 1 ok at the kinds of things on which they got harassed or look at the issues they have decided not to raise in 19 which you judge whether or not those are real issues.
20 MR. STILLO: Are you aware of any issues thati 21 were not raised because of the activities or harassment?
22 MR. SH TAKER:
No, a'll of the people that were 23 in'terviews basically said that, you know, they had always 24 2S brought everything up.
I guess it is just this feeling
O 133 43 i
l 1
of frustration --
2 CHAI30 FAN AEEARNE:
But you also mentioned seme 3
area that they felt should have been in NCRs but instead 4
became FREAs.
Did you look at those and say, yes, those 5
really should have been NCRs?'
6 MR. SHIWMAKER:
I think we looked at it frcm 7
the standpoint of trying to compare it to what we would 8
see on another job, and we would say, yes, it probably 9
should be in the categog of an NCR, because that is the system that gets r. racked.
So you.have a long-term 10 evaluation.
13.
CHAIRMAN AEEARNE:
But you really though, 12 t f ng to make an estimate of were they not really i
13 competent people to raise the problems, or where they 14 P* P * #*b8 I F#
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15' We did, of co' rse, identify some MR. SEEWMAKER:
u 6
of these QC inspectors at level one that were not g
adequately qualified.
I guess we did sit,down and look 18 l
and see if those were the ones who were well trained.
Depends on how you look at the.
20 I
problem.
If you look at a specific instance, there 21 was harassment not with respect to a particular item, but there was a whole series as was pointed out,and on scme of the others; nobody looked at all of the problems 24 contained in the sum.
There is a batte~' of harassment of 25
,, ~,, -,,, -
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13y 44 1
the QA people that's a conclusion that affects the QA 2
program and the purpose of the QA program is to' assure 3
safety,, so it is --
4 CHAIRMAN AHEARNE:
Yes, I know. I was just trying 5
to get a sense of how much of 'that would be.due to the 6
the fact that a bunch of people like that are competent.
7 MR. HAYES:
That seems to be disconnected,with 8
safety here, and I find that an incompetent QA program isn' t what I think ought to then achieve in connection with 9
/
10 safety.
11 MR. DIRCKS:
But isn't it the single items of 12 harassment ---
CEAIRMAN AHEARNE:
My point is that we have 13 a QA program that really icoks terrible.
Now one of the 14 things you conclude ordinarily would be terrib1e,is'the
'15 Prodnet.would be terrible. But that's not what you find.
16 I was just wondering skeptically is it because 77
- CA P' E * '"#
- 18 MR. SEYFRIT:
Well, at the risk of being somewhat' 9
misunderstood, I would like to make,a comment to maybe bring this in to some degree of perspective.
It was mentioned here earlier that there was 22 something like 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> of effort went in to this inspection.
Our routine program up to this point represent:
something on the order of an ecual number of hours, making it 5
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45 1
a little less than more, over a long period of time.
So we 2
have concentrated a great deal of effort and compacted 3
it into a small space, and I'm not really sure, you knew,.
4 I can't put nu=bers to this, but I rather imagine that if 5
you look at the' rate of noncompliance items ~or some such 6
measure as that, per inspector hour of e'ffort,~you would 7
see that they are not'that greatly different.
And what 8
I'm suggesting is the possibility that over a longer period 9
of time, if we had looked at these same areas, the same numberofthingswouldcomeup,butinsingleisolated 10 11 cases rather than a broad spectrum.
12 MR. THORNBURG:
It is a little over the 13 average.
~ MR. SEYFRITS:
It may be.
14 MR. STELLO:
I.think the way it is cited it is 15 a different issue here.
That is the issue of harassment 16 and intimidation and the way the QC inspectors have been 17 treated.
18 CHAIRMAN AHEARNE:
Victor,'I'm not saying that
{9 we can tolerate harassment of the QC people.
That's not the issue I was trying to make.
MR. STELLO:
That is clearly not a situation that you want to tolerate.
I think, a strange relationship 23
~
between QC people and construction people is normally troubl-You would expect to see SCme normal adversary role, because l
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I think it is a natural involvement and-it is too much 2
here.
It is beyond that.
But you always look at the 3
product to decide where are you.
If the product looks 4
like it is good, in this third possibility, although these 5
problems are there, that somehow they are s'till managing 6
at this point to still get through and have this quality 7
job done so that the product is still, at least for the 8
most part acceptable.
We are seeing~the innocent problems.
9 Now, we are going to get, very quickly, in.to this 10 soil issue, which is not a trivial problem.
It is a safety 11 problem.
It is related to the QA, it is not related to 12 these allegations. But the way in which they'have been 13 doing the job, it is producing, at least in this particular 14 area, questions which are fairly significant.
So it is not 15' to say that the product is completely free of the problem, you can see a realtionship,'at least there is an inner 16 1
ene, that some of the problems were saved because of the soil, we are nc'< saying some new problems which we are 18 l
l 19 finding out even now, today.
I S
if I think you give us just another moment, 20 there will be a clearer connection.
21 MR. SEEWMAKER:
Okay.
I would like to give you 22 a rundown,, sort of on the'currdnt status.
We will leave
^
23 the soils there until last.
24 As far as concrete activities, as the result of 25 9
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47 1
i their immediate action letter, the complex concrete 2
placements have been halted since December 21st.
3 Now, I will explain what complex concrete 4
placement is.
That would include all cencrete in the 5
reactor containment buildings, and it also includes, as 6
defined and identif;i.ed by.the licensee and the cons-Wactor.,
those other place $ents in Category I buildings that were 7
8 involved, complicated embedments, anchors, supports and that
~
9 sort of thing, and heavy r,einforced areas.
10 CHAIR'#.AN AEEARNE: And the reason for that 11 stoppage was?
12 MR. SEEWMAKER: The reason for that' stoppage 13 was, in fact, the findings of.this investigation, the 14 question of some QC inspectors not being adequately 15 qualified.
We did have some findings with noncompliances 16 in procedures in the concrete placement.
And they --
17 failure to follow those procedures will have a more 18 pro m a ced effect on the completed structure in these complex placements.
So these have been halted and-19 O*D
"*Y*
20 Just recently in the area'of welding, and 21 because of the question about qualification of those
- 8' P" #
23 order, I believe on what, March 18th?
MR. SEIDEL:
Yes, and it was reconfirmdd on the 25 1*4 th.
/
h.
.1 o a..
48 1
MR. SHEWMAKER: Then it has been reconfir=ed just 2
recently, yesterday.
3 And that deals with welding --
ASME Code 4
welding and that associated with Category 1 welding.
5' That is sort of an evolving situation, and would appear 6
that that came out as the result of findings of this 7
investigation, the facts that these welders are not 8
qualified.
9, Another thing that came out of the investigation 10 were the findings of' harassment and intimidation... The 11 licensee has hired an independent consultant to come in and look at the environment under which the QC people'and 12 construction people have to work.
13 CHAIRMAN AHEARNE:
That hasn't been completed, 14 O*"7 15' MR. SHENMAKER: The study has been completed.
W'e '
6 have not recalved a copy of
'.t.
I understand the Region people have looked at that at the site.
We do have an 1,
executive summary, which sort of summarizes that.
MR. PHILLIPS: We have received a copy of it, but I'm not sure they reached th'e same conclusion.
21 CHAIRMAN AHEARNE:
In what sense?
22 MR. PHILLIPS:
That they believe there isn't I
any pressure of any great amount at this time.
~
MR. SHEWMAKER: They concluded that the pressures 25 6
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were really not coming from construction, but the situatica 2
was being created within their own management organization 3
and the QA/QC group.
They even made the statement that 4
the. working relationship between individuals in constructio 5
and QA/QC is so'und.
That seems to be about 180 degrees 6
from the findings of this team.
7 CHAIRMAN AEIARNE:
This was, you say, done by,
8 a consultant hired by the company?
9 MR. SEIDEL:
A Mr. Howard was the auditor.
10 I know nothing about tlis consultant firm.
CHAIRMAN AEEARNE:
It is not a group that I&E 11 is familiar with.
12 13 MR. PHILLIPS:
No.
MR. SEZWMAKER:,They outlined some steps that 14 they felt the licensee should take.
I might just mention 15 thoso qsickly.
The licensee has put those in a letter.
16 CHAIRMAN AENARNE: And the licensee is ---
p MR. SEEWMAKER:
Trying to take some action.
18 CHAIRMAN AHEARNE: But based upon the 9
consultants.
MR. SEEWMAKER:
Their recommendations.
21 Reemphasize the role of QA/QC to construction personnel, and I don't know their. exact speech and for forth, but that acutally came before, I believe, just 24 before this report was available.
25 E
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Additional training and seminars, and meetings 2
to strengthen the role and understanding of the purposes 3
of functions of QA/QCs.
4 CEAIRMAN AEZARNE: Seminars with whom?
5 MR. SEEh%uER: All the workers.
~
6 Revised salary schedules for QA/QCs.
And the 7
last, $mprovement of the communications by QA/QC 8
management at site meetings and with all the low-level
~
9 personnel in QA/QC.
10 In addition, the license 6 has committed to 11 some changes in the QA program, and the way they are going 12 to implement that, and those came about as the result of 13 a meeting which was made up of people from the team and 14 Region IV the end of December.
And there was a series of 15' 9 steps that Were -- or items that were outlined.
The licensee has been proceeding to try and implement these 16 9 steps, and at the present time, it appears that 5 of 17 these still have not been fully satisfied.
The Region ig has been following the licensee's implementation of these 19 c mmitments, maybe Phil would want to say something about 20 that.
21 MR. SEIDLE:
With regard to the 9-point program g
there still are some 5 items wh'ich remain open.
23 Item number one, which is a concern about Brown &
g Root ' costs which was expressed, I think, in a January 4th 25 e
9
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meeting.
2 COMMISSIONER EENDRIE: This is the Appendix 5 3
speech?
4 MR. SEIDEL: Yes. There is concern regarding cn-5 site authority,"for the QAs t'o have more organizational 6
freedom.
They are pernitted to place noncomplex concrete 4
l P acements.
They have been observing their activities to 7
8 see just how this will impact on the QC performance.
9 With regard to the second item under number 2, 10 which deals with the FREAs and NCRs,.they had not 11 completed a coding and printing effort.to code all of these 12 FREAs into engineering disciplines and looking for trends.
13 This is not completed.
14 They have not revised their procedure'for
~
control of FREAs.
With. regard to Item No. 5, apparently 15 this has to do with procedure revision with regard to 16 Pre-P anning placement activities, specifically we are l
17 18
-talking about a list before concrete is put in place, thereby, on-site engineering / construction QC people 9
identify what must be done before placing the concrete, yet they are placing it in an informal manner, it has 21 never been formalized.
Yet.they rely on that.
This has not been done yet.
Item No. 7 of this 9 point program is augmentation of site CA staff.
Are they indeed adequately 25 e
.o 102
~
52 1
staffed. We don *t know the number of on-site QA.
2 surveillance people representing the licensee, are they 3
sufficient.
We.will have to obse'rve to see if these 4
numbers are adequate.
Are they functioning adequately.
5 In other words, h' ave they brought about 6
changes as a result of this task force effort that has 7
improved their performance at the site.
Item No. 9 is the last Item.
I said Item 7, 8,
Item No. 9 is the last item.
Of course, they have made 9
commitments to reemphasize the role of the quality 10 control program. This is in progress, this effort is 11 not c=:plete. They made a co=mitment to conduct refresher 12 training methods, this is in progress.
With regard to 13 the salary administration program, that is trying to make g
5.
the salaries of OCs competitive.with QCs elsewhere, and the relationship to the workers at the site, there has been no action taken to do that, as we know of with regard to 17 this item.
18 With regard to 1.rproved communications, this l
is in progress, but it is not complete.
Concerning the i
20 relationship of resolution of conflicts between QC inspectors and construction people, a procedure has been 22 generated, reviewed and approved on how to handle.these 23 types of conflicts.
Whether or not it works or not, remains 24 to be seen.
Again, we will have to inspect their activities 25 o
n
'Q
.)
1G3 53 1
and their judgments.
2 That essentially summarizes those.
3 MR. S M MAKER:
Okay, the last item under 4
current status is an up-date on the soi.1 situation.
5 tou will probably find when you go back to your 6
offices tonight you have received a PN.
We just recently 7
. received information that the MEAB, that's Mechanical 8
Electrical Auxiliary Building, where Unit 2 has a 9
differential settlement both north to south, of one inch, 10 the south end having moved downward.
The licensee has 11 indicated that this is the result of the heavier loadings due to construction sequence which has been placed en the 12 south end.
13 The licensee has indicated that no piping'is 14 currently attached in this building, and that they feel 15 that the.iituation ought to correct itself as they get the loading more uniform,as will be the case when the g
structure is Completed.
We really have not had a chance to evaluate this at all.
I guess we have the question of 9
whether that may or may not relate to seme'of the deficiencies we identified in the backfill program, and whether or not there is a cause of effect there, I can't 22 say at this time.
We are looking at that possibility.
As far as our planned actions, there is, of course, 24 a new allegation related to drugs, which is being investigate O
.- s
'f 1Gd 54 1
We are looking at and considering ---
2 CHAIRMAN AEEARNE:
This intimidation, does that 3
relate to the procedure?
4 MR. SEEWMAKER:
That's my understanding, yes.
5 s
MR. SEYFRIT:
Yes, but in'a different 6
discipline than we have talked about before.
There was 7
a CC man involved, that was 1 out'of 4 as I understand it.
8 It was a discipline of mechanical rather than civil.
It is 9
a different group of people.
10 CHAIRMAN AHEARNE:
It is still Brown & Root then?
MR. SEYF.RIT :
Oh, yes, it is all Brown & Root 11 on both sides, that's right.
12 MR. SEEhMR:
One of the planned actions is 13 civil penalty in the area of these noncompliances that we--
14 15-ere were a ta 2,nonccmpliances defined by this
~
investigation.
That is being considered.
16 I
We also are considering an order which would g
handle trying to correct the situation that we see.
CHAIRMAN AHEARNE:
What would you base the order on?
20 MR. SHEWMAKER: The order would. address corrective 21 action in the area of welder and welder requalification 22 l
and relock at any welds that were completed by those 23 welders that didn't have adequate qualifications.
It would address the NCR and FREA trending 25 O
e e
1G5 55 I
situation.
The audit surveillance, the problem of 2
qualification of the civil CC inspectors, and somehow 3
we need to address a mechanism or provide a mechanism 4
for getting increased involvement of the licensee in to 5
the QC functions.
6 CHAIRMAN AEIARNE: Why do you just restrict it 7
to the civil, is it the turn of events that the other is 8
still on going?
9 MR. SEIWMAKER:
I guess, as far as I know, 10 the team didn't really get in to all areas, as far as 11 qualifications of inspectors.
I guess we don't know that 12 at this time.
Perhaps it should be broadened.
13 MR. STELLo:
I think the issues is that we
~
14 do know where there is a problem.
he houefully are coinc 15
'to cover this with an u=brella that says you have got.to 16 get your whole act together and make sure that this doesn' t occur.
17 The recent incident of yesterday when they cut 18 back now, in the welding area, is, I think, a good sign gg that they are looking very carefully and are stopping the 20 work when things aren't moving correctly.
To the extent of the. attitude, I don't see that they will have further E#
"I 9
"I 23 cite them for that.
g You left out one area, Bob, that I think is 25
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.100 v.
56 1
important.
We are going to have to find a way we can 2
get some answers to these questions on the soiis, as there 3
are some areas where we have made some measurements and
/
- 4 the soil is not up to the standards that it should have 5
been, the area is not under construction at-the moment, 6
but off to the side.
We are going to have to lay a ti=e 7
table, as there really.is a serious question on the soil, under some of these structures when the construction 8
9 begins.
We should get to that very quickly, so.we don't have to have a situation develop exactly the same as in 10 11 the past.
We should perhaps find a mechanism to get that information.
12 CEAIRMAN AEIARNE:
Is there any way we can reach 13 Brown & Root?
14 15-MR. STELLO:
We are looking at that question.
C5HAIRMAN AHEARNE':
I recognize that the licensee 16 is probably responsible, but ---
17 MR. STELLO:
This most recently allegation that g
we are speaking of, depending on how that goes, it.may 19 give us a mechanism to get there directly.
COMMISSIONER BRADFORD: What does that' mechanism 21 look like?
22 MR, STELLO:
This particular allegation has a 23 flavor to it where Brown & Root personel, we got hold of 24 an individual and requested he sign a particular document 9
O I
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107
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57 1
saying you didn't see any safety problems here, and he l
2 will sign this document to relieve his drug charges.
3 This at least has a potential for ---
Now,' what part,of our 4
COMMISSIONER BRADFORD:
5 regs is it that ---
~
6 MR. STELLO:
I wasn't thinking in terms of our 7
regs.
8 COMMISSIONER BRADFORD: It is a matter of violation.
9 of law?
10 MR. STELLO:
Whether we can.get them specifically u der Part 21 on this issue.
11 12 CHAIRMAN AHEARNE:
Isn't there some way -- we haul in licensees to public meet'ings, is there any way 13 we can insist that the licensee can burden Brown & Root ---
~
g MR. STELLO: Abs.olutely.
15
. CHAIRMAN AHEARNE: They are the ones that we 16 l
l ought to be really ---
17 MR. STELLO: That's the last item.
18 At the meeting we are talking about, it is quite apparent this wil'1 be one of the major isskies, and we hope to direct this to the officials from Brown & Root as 21 i
l well as the licensee, but my view is the licensee is 22 the individual who is responsible.
He has got to get 23 his act together, and if that means that he has got to do 24 something different with Brown & Root than.he is doing, 25 t
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we should direct that change or he can find some other 2
way to do it, but the first responsibility, the'first 3
level we look at is the licensee.
There are questions as to whether or not we ought 4
5 to find -- want to look at mechanisms to get to the a
architect /&ngineering firm and the next level would be 6
j f
Brown & Root.
Bill raised this question in the briefing last week. I don't know if there is an easy answer.
g MR. MURRAY:
Generally, I would say no.
This 9
is a function for bhe licensee to perform and we hold them 10 responsible for all of those things not dene.
If we 11 were to deal directly with the AE, that would imply 12 somehow that this regulatory agency would want to see 13 the plant get built, and I don't think we want to imply 14 15-da e just m e e sure,e at it gets M t safely.
9 16 MR. MURRAY4 If it does not get built at all, we say to the licensee, you make s".re it gets built safely, 18 we just want to make sure.
CHAIRMAN AEEARNE: Let us assume that we do go 20 out with some sort of notice, et cetera, we put out 21 a public announcement as such, do we put in Brown & Root?
MR. STELLO:
In this particular meeting we are 23 referring to, specifically, especially in light of this 24 particular piece of paper, there is no doubt in my mind 25 e
e
1GO 59 1
their senior officials of the company must be there if 2
this issue is squared away.
3 CHAIRMAN AHEARNE:
What I was trying to get at, 4
for example, let's suppose you go forward somehow, some 5
penalty goes out in the press release saying the NRC 6
is laying a fine on such and such a licensee.
We go 7
on to say this ils because.of the continual violations of
~
8 standard noncompliances of QA/QC of Brown & Root.
9 MR. STELLO: 'We haven't normally done this.
10 CHAIRMAN AEEARNE:
I know that.
11 MR. STELLO:
I don't like to decide this --
12 I will be happy to look at it.
CEAIRMAN AEEARNE:
I would like very much for' 13 14 y u to look at that.
MR. STELLO:
I, guess I don't see anything
'15 fundamentally wrong,.especially with respect to the 16 meeting we are going to have.
I think we want to be 17 lear to the Brown & Root officials ---
8 CHAIRMAN AEEARNE:
What kind of schedule do 9
you have on this'for considering these ---
MR. STELLO: With respect to the enforcement 21 package?
CHAIRMAN AHEARNE:
Yes.
23
~
MR. STELLO:
If things settle down for a day or two and we can get it developed, I would suppose in 25 i
.......-..-s
)
s' 170 60 1
about a week we can have the enforcement package.
The 2
order we are talking about is much more difficult.
3 I guess I can assume the report will be finalized 4
within that time.
5 MR. DIRCKS: Assuming there are no more allegations.
6 MR. STEILO:
Well, there already are.
These will 7
not be finished.
8 MR. THORNBURG:
The scope of the investigation g
has to stop.
MR. STELLO:
I had the problem of looking at a 10
~
what way which to get in to the press announcement, 11 pa Micular act'.on would involve Brown & Root specifically.
12
~
I just want some more time to think about that.
13 MR. MALSCR:
Are any of the Part 21 violations 14 15-similar to the B&W situation?
MR. STELLO:
Yes, that is one.of the issues 16 that came out of the briefing last week.
17 lMR. SETERIT: What is the Part 21 connection here?
18 MR. STELLO:
We are going to look in to it, 9
i no one has an answer at the moment.
l 20 CDitCSSIGER IENDRIE: What you have is a QA/QC program-in which there appears to be more than the normal and perhaps l
22 irreducable amount of friction between the construction and I
23 j
QC/QA shops.
There appears to be less management support in the QC than we would like to see and relations of that 25 9
n.
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Q 171 61
'l kind.
2 Nevertheless, it isn't clear to me from what 3
you have said today, there is any very clear evidence to 4
me, much of any evidence, that in spite of the QC, program, 5
it hasn't been effective and resulting in a satisfactory 6
construction product.
7 Now, it is certainly not a situation that one 8
would encourage er want to tolerate going on, because as 9
they go on with the plant, getting in to more complicated 10 areas, especially over in the mechanical and electrical 11 areas, it is that much tougher to get a cuality product 12 than it is in some of the heavy concrete work that.they 13 are doing now.
So you would like to get a hold of it.
14 It isn't clear to me that, in fact, there is much evidence, if any evidence of safety.related deficiencies, and if there 15
~
16 isn't, then you have to say,'well, it is a safety related 17 problem that people are snarling at the QC inspectors and so on, I think that is the point you stressed.
18 MR. STELLO:
Let me make one exception to what y,9 you said.
I think in the area of soils --
g C010i!CCIONER HENDRIE: Well, the soils question is an open one.
I'm not talking about that.
g MR. STELLO: That's a QA breakdown.
The QA system g
wasn't doing its job in making the engineer's backfill done, in the way that was supposed to get it done.
So that's ---
e 8
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62 1
COMMISSIONER HENDRIE: But you wouldn't cite 2
them because the construction people were being nasty 3
to the QC people.
You cite them because they failed to 4
get the soils ccmpaction specified.
5 MR. STELLO: That's exactly right.-
6 COMMISSIONER HENDRIE:
Now, I was going to ask.
~
7 Do you'have a thought for where you are going on the 8
enforcement action here?
9 MR. STELLO: What appears to be warranted is 10 a civil penalty based on --'
COMMISSIONER HENDR'II: It appears that the 11 12 utility is in motion.
13 MR. STELLO:
Yes, the utility is in motion.
CHAIRMAN AHEARNE:
Except that it hasn't 14 15' caught up with the system.
COMMISSIONER HENDRIE:
Listen, you get 3,000 16 construction workers and assorted people on the site, not 17 much of this surprises me.
gg MR. STELLO:
You take the experience of it 19 being a half dozen of both arguments.
He has found and 20 rrected the problem himself, he has decided to take 21 s me a tion, that's a QA function itself.
22 CHAIRMAN AHEARNE:
Who, the licensee?
MR. STELLO:
He decided the welding wasn't going 24 the way he thought it ought to go and stopped it again.
25 o
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1 Well, the civil penalty to me seemed to be ---
2 COMMISSIONER HENDRIZ:
Is it clear you are
.3 going to get the best action from the collection of people.
4 in South Texas, I guess, is what I'm getting to.
5 MR. STIILO :
Well, that's not all.
I think we 6
have to get an order which gets in to some of the areas
~
7 and problems of the past, in to causing things to get
~
8 turned around.
I think that's necessary.
9
.I'm also beginning to believe that the concept 10 of:
Let's get together and have a pi.iblic meeting, do 11 thisonk.ocalatthesite,andgetputthingsonthetable 12 and let's talk'about them.
I think that is"an important 13 thing also.
I will propose that the enforcement package l,
14 include a civil penalty, and I don't think it is going to 15 be big dollars;.
The requirements that ought to be in the order, including an order to have a public meeting on 16 or before some date, whatever I decide on.
In a nutshell, 17 that's the kind of enforcement package, as I see it, 18 19 that is appropriate now.
COMMISSIONER BRADFORD:
Let me ask a couple of 20 questions if I could about the investigative technique.
i 21 There has been a pretty high turnover of people 22 leaving. If I'm' reading-the summaries of the interviews 23 24 correctly, I didn't notice you had interviewed many of 25 the people who had left.
Is that correct?
Qs L..)
17d 64 i
1 MR. HAYES:
That is true.
2 COMMISSIONER BRADFORD: Why not?
3 MR. HAYES:
Most of them weren't available.
4 COMMISSIONER BRADFORD: Wait a minute, of course, 5
they are available, if they haven't left the counrtry.
6 MR. HAYES: Right.
Well, I guess in part, we 7
looked to OIA, but in part too, we had to bring this 8
thing to a lull some time, and there were quite a number 9
of them..Where do you stop, I guess is the ---
10 COMMISSIONER BRADFORD: We2.1, just intuitively, 11 I would have thought that you might some time get a more 1.2 complete discussion, shall we say, of practices of the 13 site by interviewing people who didn't also have a continuing job stake in what they were saying.
14 MR. STELLO:
But that had taken place in the 15 earlier interviews, before they left.the site.
16 COMMISSIONER BRADFORD:
Okay, so you are saying y, y that is true?
A8 l
l MR.STELLO:
In the earlier interviews that are 9
already done.
The scope of this particular group that I had in mind was to take a look right new and get in to it with the OIA activity, looking back in to the previous allegations of people who had raised ---
COMMISSIONER BRADFORD:
Okay, as long as somewhere in the agency these people are being picked up.
25 CHAIP24AN AREARNE:
Is that what OIA is doing?
0
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1 MR. FORTUNA:
Yes, sir.
~
l 2
MR. STELLO:
In our first investigation 3
interviews we did that too, take a look at the people who,
4 had left.
5 MR. SEYTRIT: The ones that were conducted by the 6
Region before this present one, there were a number of peopl
~
7 who had left the employe that we did talk to.
I can't 8
give you an actual count'of those, and I'm sure I can't 9
say that we talked to each and every one of them, but we -
did talk to a number of them.
10 MR. THORNBURG: There is another point though.
11 Dee sat down and talked to another 50 people without taking 12 their names.
They talked a little bit about turnover rates 13 and general problem areas.
Is that correct?
14 MR. EAYES:
Yes.
This turnover kept coming up.
25 A lot of people quit, but I did make an attempt to talk g
to people who were there, recognizing they were not the g
people who had left.
I asked dem w W some of dose 1g people left, and I got a variety of answers, I would say about a third of them was because of poor management.
They said the management is all fouled here, I have never worked in a pla.ce where management is so screwed up.
Comments like that.
Another third felt that the merchants in Bay city was taking advantage of them, they 24 didn't like the area, their families didn't like the area 25 S
176 66 1
and that was why they were moving.
I didn't get the answer that I thought I might get, harassment and things like that.
4 COMMISSIONER EENDRIE: Sounds normal to me.
COMMISSIONER BRADFORD: Well, excep't that the 3
~
6 numbers, if I understand them correctly, 22 of the 39 in 7
' the CQ inspection group, as of February 1, 1979, voluntarily 8
terminated or were terminated or reassigned.
I don't know, 9
maybe that's normal, but that sounds like an awful lot.
10 Well over h'alf, and it is against that background that 11 it seems to me that it would be desirable for somebcdy to 12 somehow be talking to that group as well and see what 13 they have to say.
14 MR. SEYFRIT: We have talked to t number of the=
15' because they show up on other jobs.
As he indicated, about 16 a third of them leave because they can make more money 17 some place else and we see some of those showing up in other
{
18 places.
COMMISSIONER BRADFORD: Yes, but you wouldn't 19
' 20 he talking with them some place else.
You have got to 21 systematically go after this group.
l MR. SEYFRIT:
Right.
l 22 23 COMMISSIONER BRADFORD: Again, reading from the 24 summaries I couldn't tell, they are signed at the end, and M
S en--
1 1
0 67 1
knowledge and belief, this statement is true."
Is that 2
a sworn statement?
3 MR. MURRAY:
It is.
4 MR. SEYFRIT:
I think we weEe going to'try and 5
clarify in the sody of the report, the first Appendix'in 6
there are sworn statements, that is, where you have 7
statements, and it is entitled at the top uniquely, and 8
I can't remember.the exact title.
Then the second part of it, where there are 9
10 statements indicated there are summaries of other 11 interviews.
Ncw, all of those that come under the. heading 12 of "Su= mary of Statements" are sworn statemerrts, but they have been su==arized here in order to try to protect the 13 14 identify of the individuals.
COMMISSIONER BRADFORD:
I see, but if in fact, 15 anything in one of those statements were to turn out to 16 be deliberately false, that would be a prosecutable 17 gg
, violation in itself.
MR. SEYFRIT:.That's correct.
79 MR. MURRAY: It would be in violatf.on of the law.
20 MR. SHEWMAKER:.All of those in A,ppendix 2 are 21 signed sworn statements.
Those that have been ey;1uded l
22 are su= mary statements.
l g
COMMISSIONER BRADFORD:
I guess I don't have any 24 other questions, but just a comment though.
25 b
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'.. -)'.6 'f.3 68 1 I'm struck by what seems to be a fairly wide-2 spread network of undesirable events, 'violatioris, what 3 have you, but especially so in light of the fact that this 4 is your 5th or 6th investigation of this or similar 5 problems with this company. This would be striking enough 6 if it were the first investigation. They seem to be 7 very slow learners and.so I would certainly be supportive 8 of ~~~ 9 CHAIRMAN AEEARNE: Eleven. COMMISSIONER BRADFORD: Eleven such investigations 10 Well, in any case, the point is that it all takes 11 n, I think, basically more seriousness than.this is si= ply 12 the first ti=e around. 13 CHAIM AEEAM: Has de company been c ted 14 15-f r vi lations prior to this? MR. SEYTRITi Yes, they have been cited a nu=ber 16 I e of. times. g CHAIRMAN AHEARNE: Have there been penalties? MR. SEYFRIT: There have been no civil penal. ties. MR. STELLO: I think the answer to the question 20 that I thought about myself, you have to look at the number of hours you put in to it, the number that was expressed earlier, th'e number is higher than 'probably one would j expect. 24 I also, don't think that the licensee, until l 25 this investigation', and the exit interviews following these -- m
O 173 c. a 69 investigations,really had an appreciation of the problem. 1 Maybe, Carl, correct me if I'm wrong, I guess maybe it 2 would be fair to say that I don't think we really gave his 3 the impressicn that he really had this kind of a problem 4 5 until now. 6 MR. SEYFRIT: I think that's f air. I think furthe: that it would be fair to say that he, perhaps, had.not 7 8 recognized it was that broad a problem. The previous and investigations were spread out over a period of ti=e, 9 10 in general they were. conducted to look in to specific allegations on specific points and we just simply didn't 11 broaden them to look at this kind of perspective. 12 One can certainly look in hindsight that mayb'e 13 we ought to have looked'b1 to it, and we didn't see at 14 the time, a legal reason.to do that. We were :trying to 15 take care of spccific problem's as they came up. 16 COMMISSIONER BRADFORD: I have one specific 17 . question that I skipped over. ~ 18 one of the interviews it was said that one of 19 "Whenever you the supervisors said words to.the effect: 20 call the NRC, I will find out about it. I will find out 21 about it, I will know who' caused trouble." 22 I" E# IY ""Y 23 making a statement in quite that way, but you do, in fact, l 4 in looking at these allegations, look in to the allegation i 1
f ~ ",,. e. 180 70 1 if Brown & Rcot got a call from us,every time he had i 2 a call expressing concern. 3 MR. SEYFRIT: I think that OIA is looking in to 4 that, to the best of my knowledge. 5 MR. FORTUNA: No. 6 COMMISSIONER BRADFORD: CIA is not looking in to 7 that? MR. SHEWMAKER: Let me address that. We picked 8 9 up that same thing in the report, and that is one of the 10 allegations that has not been investigated. In fact, we are hoping that OIA will pick that up. 11 MR. FOR M A* We will now. 12 MR. SHEWMAKER: We have that one. We will be 13 getting with you. g Dick did loon in to N s U G: 15. a e DM Herr was our h esdgator. 16 MR. HERR: In fact, you will find that he did admit saying those words. I confronted him on that. COMMISSIONER BRADFORD: At least in the summary, he just gives a different twist to it. MR. HERR: But he did admit.saying the words: "Everytime somebody goes to the NRC, I'm going to find out about it." He admits that, then he says, but what I meant was, when they come down here they do the 24 investigation, then I find out. He says I don' t have to 25 4 .g O -,----a..,,,,,.,,--l,.
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-s ) ^ a. / 101 ( 71 1 explain how. He said it was true, the guy said it, but 2 he put a different intrepretation on it. 3 COMMISSIONER BRADFORD: There is clearly an 4 ambiguity there. The person alleging S.t said schething 5 to the effect tiiat every time'a ccmplaint is madei I get i 6 a call that tells me who made it. It is, that telling hi= ~ 7 who made it part'that" disturbs me: 8 MR. STELLO: Yes.* We will look -in to it. 9 MR. SHZ h MER: It is not defined as allegation 10 18-A, that'particular one. CHAIRMAN AHEARNE: I need a vote to close this 11 12 meeting. All in favor? 13 (Chours of ayes.) 14 CHAIRMAN AHNE: John, you say I.should also 15 ask to.look at the. transcript to.see which portions can 16 be released. 17 MR. HOYLE: Yes, we should ask the staff to 18 1 k at those portions to see which parts should be 19 re eased. 20 MR. STELLO: I would hope that I would not have 21 to release this transcript until at least after we decided on the enforcement. g COMMISSIONER BRADFORD: I would vote to withhold 24 it as a practical matter. 25 CHAIRMAN AEEARNE: Yes, so would I. O e
~ '() ',) o 3 n e-o 9 ~' .L 0. o 72 1 COMMISSIONER EENDRIE: I would join that. I 2 must say, I didn't find any of the discussion wilich is likely 3 to be separable and releasable in a contemplated enforcement 4 process. 5 CHAIRMAN AEEARNE: Thank you very much. 6 (Whereupon, the meeting was c=ncluded-at 4:55 7 P***I 8 i .-9 u 10 11 12 13 14 15' 16 17 18 19 t 20 21 i 22 l 23 24 25 G
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e Q 9 0 0 PURPOSE OF INVESTIGATIM (.,.) INVESTIGATE CURRENT (NOV. 1979) ALLEGATIONS OF llARASSMENT, INTIMIDATION OF CONTRACTOR QUALITY CONTROL INSPECTORS AT THE SITE. ~ REVIEW EFFECTIVENESS OF QUALITY ASSURANCE PROGRAM IMPLEMENTATION. e O 9 .,. ) 6 o 9 a.
i 1 j BACKGROUNIl i. j SERINS OF ALLEGATIONS MADE DURING Tile PERIOD FEBRUARY 1977'T0 NOVEMBER 2, 1979. MOST OF Tile ALLEGATIONS WERE NOT SUBSTANTIATED. ~ C0NSIDERABLE MEDIA INTEREST. CONGRESSIONAL INTEREST. ~ i MIDTERM QUALITY ASSURANCE INSPECTION SCllEDULE MOVED UP ONE YEAR (T0 AUGUST 10, 1979) - SOME COMMON PROBLEMS IDENTIFIED. l FBI INVESTIGATION - JUNE 1979 - OCTOBER 1979. DEPARTMENTOFJUSTICEEXPRESSEDINTEREST. DIA LOOKING INTO HISTORY OF ALLEGATIONS WITil IE TECllNICAL ASSISTANCE. RESIDENT INSPECTOR ASSIGNED AUGUST 26, 1979. ALLEGATIONSMADEBYWORKERSTORESIDENTINSPECTORONNdVEMBER2,1979. DIRECTOR,.IE DIRECTS INVESTIGATION NOVEMBER 3, 1979. I H l El l
l i INVESTIGATION MULTIDISCIPLINE TEAM UNDER 110 DIRECTION ' \\..) i REGIONS I, II, III, IV REPRESENTED FORMAL INTERVIEWS - 57 (24 STATEMENTS UNDER OATID LESs FORMAL INTERVIEWS - 50 1 ~ TIME PERIOD - NOVEMBER 10, 1979 TO FEBRUARY 7, 1980 I 1113. INSPECTOR HOURS l AREAS COVERED -- CATEGORY I CONCRETE AND STRUCTURES DIRECTLY ASSOCIATED WITil Tile ALLEGATIONS r' -- S0ILS J l -- WELDING /NDE 1 -- IIANDLING 0F NONCONFORMANCE REPORTS -- AUDITS c3 C') i 4 O
RESULTS__0F INVESTIGAT10M' NUMBER OF ALLEGATIONS SUBSTANTIATED REGARDING CONTRACTOR BROWN & ROOT QC INSPECTORS (CIVIL) -- THREATS c -) -4 ^ -- IIARASSMENT ~ -- INTIMIDATION -- LACK 0F MANAGEMENT SUPPORT i -- PRODUCTION PRESSURES AMOUNTS TO LACK 0F REQUIRED INDEPENDENCE OF QA FUNCTION OTHER SIGNIFICANT QUALITY RELATED PROBLEMS -- QUALITY OF CERTAIN PLANT BACKFILL QUESTIONED -- WELD QUALITY / WELDER QUALIFICATIONS -- DISPOSITION OF NONCONFORMANCE REPORTS -- ADEQUACY OF AUDITS ~ A NUMBER OF ITEMS FOR FOLLOWUP s s TOTAL OF 22 ITEMS OF NONCOMPLIANCE cj NO CLEAR TRACK TO GENERICALLY DEFICIENT. SYSTEMS, STRUCTURES OR
i CDELUSIONS_ QUALITY ASSURANCE PROGRAM IMPAIRED. LACK OF INDEPENDENCE OF GA INSPECTION FUNCTION - CIVIL DISCIPLINE. ({} NO CLEAR CAUSE - EFFECT RELATIONSillP.RESULTING IN DEFICIENT l SYSTEMS COMPONENTS AND STRUCTURES. ~ i l l / i i l W C) CB l l i
CERENT STATUS _ i IMMEDIATE ACTION LETTER IN EFFECT - COMPLEX CONCRETE PLACEMENTS SINCE DECEMBER 21, 1979 IIAVE BEEN llALTED. ) LICENSEESTOPWbRKORDER-WELDINGASOFMARCll 18, 1980. WORK IS i RESUMING AS CORRECTIVE ACTION IS MADE'. I l LICENSEE IIAS STUDIED WORK ENVIRONMENT. CONCLUSIONS LICENSEE IIAS CollMITTED TO CllANGES IN GA PROGRAM IMPLEMENTATION. i ). N [ 6 t* H i C) l c, t.
1, i. .. c 1 _ f j PLANNED NRC ACTION i i CIVIL PENALTY 1 i '0RDER(S)
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UNITED STATES i 8 d NUCLEAR REGULATORY COMMISSION =,3 4 .? *: wAsumcToN. o. c.2csss Q Crx,$ JUN 2 4 IS80 o... MEMORANDUM FOR: Karl V. Seyfrit Director, RIV FROM: Harold D. Thornburg, Director, Division of Reactor Construction Inspection IE
SUBJECT:
FOLLOWUP ACTIVITIES ASSOCIATED WITH THE S. TEXAS ORDER Both Region IV and Headquarters representatives have been and continue to be involved in the problems at S. Texas. Therefore, it is necessary in my view to delineate the responsibilities of our respective offices in assuring proper resolution and followup of these problems. Accordingly, Region IV should assume responsibility for the following items: 1. Detailed review and verification of corrective actions by.the licensee on the specific items of noncompliance identified in the Investigation Report' (50-498/499/79-19). 2. Detailed review and verification of corrective actions on the comittments made in the licensee's responses to the Order. 3. Provide RCI with written status reports on the licensee's and Region IV's activities relating to the Order at as,propriate intervals but not to exceed intervals greater than 2 weeks. (These status reports are not intended to replace the fonnal inspection reports.) .s 4. Make arrangements for a public meeting. Meeting should' be scheduled at. Bay City,. Texas 2 to 3 weeks following receipt of the HP&L response (due end of July). Public announcement of the meeting should be mada as a minimum, two weeks before the scheduled date. These and other details should be coordinated with Headquarters. j F 5. Prepare a draft Commission paper sumarizing the S. Texas problems and providing the basis and ju:tification for lifting or continuing the Order as appropriata. This paper will probably be needed in late August or early September. In carrying out these dutieh, particularly items 1, 2 and 3, the services of the resident inspector should be utilized to the greatest extent possible . CONTACT: G. W. Reinmuth, IE 49-27551 g a m 35 q g' ' do p / p_
g O '192 K. V. Seyfrit A'N 2 '4 1950 because of his unique snowledge of the is' sues derived frem his earlier participation on the special investigation team. Other members of that team or RCI staff knowledgeaole in specific areas may also be called upon for assistance as necessary. Headquarters RCI will be. responsible for the following: 1. Reviewing and pro [$1'ng connents on adequacy of the responses to the Order received frem the licensee. Region. IV input will be solicited. Completion of review is tentatively planned for 30 days following receipt of licensee's reply. 2. Monitoring the reviews, verifications and status reports provided by Region IV. Visits to the site will be made by RCI staff as well as the investigation team leader under the direction of RCI. e. h3. Conducting the public meeting (V. Stallo). Selected Region IV representatives will be invited to participate. 4'. Reviewing any other reports addressing the S. Texas ' Order. -(OIA, other) ' " 5. Making the final decisions regarding licensee satisfaction of the conditions of the Order. Region IV will be requested to concur in major decisions. 6. Conr.unicating decisions / actions / requests regarding the case to the Ccmmission, other NRC officer, others as necessary and to Region IV management. It should be noted that the'Incediate Action Letters relating to items also i covered by the Order should be considered a part of the same action as the Order. Accordingly, Region IV should not take unilateral action irt rescinding or closing out the IAL's. Other. routine inspections of the S. Texas project in accordance with the nonnal planned inspection program should continue.in a normal manner. These should be administered and conducted separately from those activities associated with the Order. Comunications on these matters should be made directly to me, Taylor, Reinmuth or Shewmaker. The cooperatien, received from Region IV in the past and expected in the futune, is appreciated. p ( 89 4 Harold D. Thornburg, Director Division of Reactor Construction Inspection, IE x
a = o. Q ^) 1G3 K.hSeyfrit -3 JUN 2 41530 1 cc: V. Stallo, IE J. Cumings OIA R. C. DeYoung, IE D. Thompson IE B. H. Grier, RI J. P. O'Reilly, RII J. G. Kappler, RIII R. H. Engelken, RV D. Hayes, RIII S. Phillips, RIII R. E. Shewmaker, IEV R. Compton, RII E. Jernigan, RI R. Landsman, RIII O e* N A-l l [ Lls. m
y -g g.v u u c-n n c u v q i u n i uv....... yg4-wassmaten. o C.2osss y k, - ,[ r April 21, 1960 J f/ CFFICE OF THE SECRET ARY.
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1 MEMORANDUM FOR': ~ William J. Dirck, Acting EDO Samuel J. Chil etary n/ p l> < :- FROM: STAFF REQUIREMENTS - BRIEFING ON INVESTIGATION OF
SUBJECT:
PROBLEMS AT SOUTH TEXAS NUCLEAR PROJECT, 2:50 P.M., TUESDP APRIL 15, 1980, ROOM 550, EAST-WEST TOWERS, BETHESDA, MARYLAND (CLOSEDTOPUBLICATTENDANCE) The Commission
- discussed the draft South Texas Investigation Report, 11, 1980.
. hich was forwarded to the Commission on April w The Comission requested: That I&E point out in the enforcement package that deficiencies 1. in the Brown & Root QA-QC program are the reason for the enforcement action; (I'i&E) (SECY Suspense: 4/25/80) That DIA investigate whether an NRC employee was informing N 2. Brown & Root of complaints made to NRC and of the individual complainants' identity; (OIA) (SECY Suspense: 5/16/ 0 ge :a. Commissioner Bradford requested: That I&E interview civil QC inspectors who had terminated.3 3. their employment at the site. (I&E) (SECY Suspense: 4/30/8,0) CC: Chairman Ahearne Commissioner Gilinsky -Comissioner Kennedy Commissioner Hendrie Commissioner Bradford Commission Staff Offices
- Comissioner Kennedy was not in attendance.
9 7 M .3-4 V w x
H/JG J5 b h !' O- 'N UNITED STATES $2 rtag % NUCLEAR REGULATORY COMMISSION
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611 RY AN PLAZ A DRIVE, sulTE 1000 e o $ *-(i ARLINGTON, TEXAS 76012 h Y E s y December 31, 1979
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U -ottD In R; ply Refer To: RIV FILE CO@ SECENEC Dsck';t No. 50-498/499 g SN G *' Houston Lighting and Power Company ATTN: Mr. G. W. Oprea Executive Vice President P. O. Box 1700 Houston, Texas 77001 Gentlemen: This refers to a special inspection at the South Texas construction site during the past six weeks, meetings with yot and members of your staff on December 21 and 28, 1979, and to your letter dated December 28, 1979 As a result of our special inspection effort, a number of problems associ-ated with the placement of concrete were identified and discussed with you. Consequently, we understand that you: 1. Have initiated a Nine-Point Corrective Action Progra= to elimate proble=s connected with concrete placement and inspection activities. (The Nine-Point Corrective Action Program is contained in your December 28 letter.) 2. Plan to limit safety related concrete placements to placements classified as Non-Complex until such time as the Nine-Point Corrective Action Program has been fully implemented. I 3. Plan to notify the Region IV Office when you have implemented the Nine-Point Corrective Action Program and such notification is to occur at least 48 hours prior to the resumption of safety related, complex concrete placement to permit NRC verification of satisfactory implementation of the Corrective Action Program. If your understanding of this matter is inconsistent with the above, please contact this office immediately. Sincerely, c, pH,, w _ Karl V. Seyfri Director f CERTIFIED MAIL - RETURN RECEIPT REOUESTED y 3-9
a aerug'o UNITED STATES f."" NUCLEAR REGULATORY COMMISSION 's ]$$ g E WASHIN GTON, D.C. 20555 's J OFFICE OF THE SECRETARY CERTIFICATION I hereby certify that the attached 26 pages contain a true copy of the letter dated Jan 26, 1961 from K.V. Seyfrit to Brown & Root, ING. concerning the LLVIP< audit con-ducted hv Mr. D. F. Fox on Januarv 5-8. 1991 together with that letter's attachments on file witn the tJnited States tiuclear Regulatory Commission's Public Document Room, 1717 "H" Street. N. W., Washington, D.C. QvcuN IC, {lM 'O " C Date Official Custodian of the Records of the Public Document Room ~ " Office of the Secretary of the
- Commission e
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y#% UNnrED STATES - NUCLEAR REGULATORY COMMISSION f '
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107 I cEmu sv 811 RYAN PLAZA DRIVE. SulTE 1000 .as p u nTrw Tsva n 7sott 2 8 JAN 1981 Docket No. 99900502/81-01 Brown and Root, Incorporated Attn: Mr. W. M. Rice Group Vice President, Power Group 4100 Clinton Drive Post Office Box 3 Houston, Texas 77001 Gentlemen: This refers to the QA Program Insp,ersion conducted by Mr. D. F. Fox of this office on January 5-8, 1981, of ycur facilities at Houston, Texas, and to the discussions of our findings with you and members of your staff at the conclusion of the inspec-tion. ~ Areas examined during the QA Program inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an ' examination of procedures and representative records, interviews with personnel, and observations by the inspector. During this inspection it was found that the implementation of your QA Program failed to meet certain NRC requirements. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. Please provide us within twenty-five (25) days of the date of this letter a written statement containing, (1) a description of steps that have been or will be taken to correct these items, (2) a description of steps that have been or will be taken to prevent recurrence, and (3) the dates your corrective actions and preventive measures were or will be completed. You will note that Daviation A of the enclosed Notice of Deviation is related to management failure to' assure compliance with committed corrective action that was contained in your 'iatter of December 16, 1980, responding to NRC inspection report 99900502/80-03. Specifically, qualification and, training files of all engineering personnel performing safety related work on the l South Texas Project were not updated by December 31, 1980 as committed. This is the third inspection in which committed corrective actions or pre-ventive measures for previous inspection findings were found to be not completed as comitted. Reference Report No. 99900502/80-01, Deviation A and 99900502/80-02, Deviation A. This suggests a breakdown in the effective implementation of the Brown & Root Quality Assurance Program for the South Texas Project. A E Ob l
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s_ o. ( 193 Brown and Root, Inc. 2 Consequently, in your response, in addition to correcting of the specific devia-tions identified the Notice of Deviation enclosure, please define the specific steps that you have taken, or plan to take, to assure that managecent commit-ments will be performed as. stated and be effectively implemented. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any infomation that you believe to be proprie-tary, it is necessary that you submit a written application to this office within thirty (30) days of the date of this letter, requesting such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the infomation is proprietary. i The application should be prepared so that any proprietary infomation identified is contained in an enclosure to the application, since the application without .I the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be please i to discuss them with you. Sincerel, ] t /Karl V. Sey' ri.t Director
Enclosures:
1. Notice of Deviation l( 2. Inspection Report No. 99900502/81-01 s ,- = - n.,---, g ; y., .g,
~ f."' 109 trown and Root, Inc. Bocket No. 99900502/81-01 NOTICE OF DEVIATION Based on the results of an NRC inspection conducted January 5-8, 1981, it appears that certain of your activities were not conducted in accordance with NRC requirements. A. Brown and Root letter of response dated December 16, 1980, described corrective actions and preventive measures for. the four deviations '.~ identified in I&E Inspection Report 99900502/80-03. Brown and Root 'c6nWitted to a completion date no later than December 31, 1980, for falJ'ActionrelatedtoNoticeofDeviation,ItemsAandB. Contrary to the above, corrective action for Notice of Deviation, items A and B, was not completed as committed. (See Details Section I, para-
- l graphs B.10 and B.11.)
8.* South Texas Project. Engineering Procedures STP-DC-007 (Preparation and Control of System Design Descriptions) and STP-DC-019 (Technical Reference Control) state that design criteria documents, in conjunction with System - Design Descriptions, comprise the STP Design Manual. Design criteria documents may be issued as Technical Reference Documents which are reviewed, approved, distributed to Assistant Engineering Project Managers, Discipline Project Engineers, Project Quality Engineers and others by the Engineering Document Control Center and made available for use on the South Texas Project. Technical Reference Documents require the signed approvals of the Originator (as applicable), the Discipline Project Engineer, Project Quality Engineering, the Engineering Project Manager, and Quality Assurance and/or the Client (as required). Contrary to the above, Technical Reference Document A010PQ003-A (Penetra- ,I tion Sealing System) and six (6) others that were issued and distributed in mid 1978 by the Engineering Document Control Center, and that were contained in the STP Design Manuals assigned to the Assistant Engineering Project Manager, the Discipline Project Engineer and the Project Quality l Engineer, did not exhibit the required signatures of the Discipline Project l Engineer, the Project Quality Engineer, the Engineering Project Manager l and Quality Assurance to document their review and approval of the docu-ments. Refer to report section I.C.3.a.(1) for details. 10 I ~ -~~ a w. - m., 4 n w: '.z my'r ~ ' ~ ~~"'TW~~ "'
g. -.. 200 2 I C.
- Section 6.3.1. of the South Texas Project Quality Assurance Manual states in part that "To ensure that the responsible engineering personnel are working to the latest revision or issue of an Engineering document, a comprehensive document status list shall be published at least every two months by the EDCC (Engineering Document Control Center).
Contrary to the above, a comprehensive document status list has not been published, nor updated, bi-monthly by the EDCC since October 2, 1980. Refer to report section I.C.3.a.(2) for details. CDenotes deviations from the requirements of Criterion V of Appendix B to 10 CFR 50 that states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, or a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, I procedures, or drawings.. e i l I i .. -,., -.. ~..,_, a ;w-tre7magm ~+.w+. "m* ' > ' _- =
o 201 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900$02/81-01 Program No. 51200 Company: Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3. Houston, Texas 77001 Inspection Conducted: January 5-8, 1981 Inspectors: W '/ * #/I I (
- 0. F. Fox, Principal Inspector Date Program Evaluation Section Vendor Inspection Branch
~ -- _D t % A >/2 3 /r / D. G. Breaux, Inspector j Date Program Evaluation Section Vendor Inspection Branch k /'b7'hf Approved by: C. J./fta l, ~ Chi e f Date Progr. valuation Section [ Vendor Inspection Branch l Summary Inspection on January 5-8, 1981 (99900502/81-01) Areas Insoected: Implementation of Title 10 CFR 50, Appendix B and Topical Report B&R-002A, including follow-up on previous inspection findings, design document control, procurement source selection, and supplier nonconformance and corrective actions. The inspection involved seventy (70) inspector-hours on site by two (2) USNRC inspectors. Results: In the four (4) areas inspected, three (3) deviations from commitment were identified in two (2) of the areas. l l t 010 p. a
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202 I 2 Deviations: Follow-up on Previous Inspection Findings: Corrective action committed in a Brown and Root response to a previous deviation had not been completed as scheduled (See Notice of Deviation, Item A). Design Document Control: Unapproved Technical Reference Documents were contained in the Design Manual (See Notice of Deviation., Item B). The Engineering Document Control Center did not publish a document status list as comitted (See Notice of Deviation, Item C). l mmM
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r ~ 203 3 DETAILS SECTION I (Prepared by D. F. Fox) A. Persons Contacted "K M. Broom, Senior Vice President, Power Group H. S. Cameron, Assistant
- Engineering Project Manager
- J. R. Childers, Houston QA Coordinator
- H. T. Faulkner, Project Coordinator
- A. H. Geisler, Manager, Nuclear Licensing G. L. Gibson, Discipline Project Engineer, Pip ~ng Engineering J. F. Halsey, Manager Special Problems Group
- J. L. Hawkes, Manager, STP Engineering
-i
- S. J. Kelley, Training Coordina'tTr "H. W. Overstreet, QA Supervisor, Houston Lighting arid Power J. E. Padden, Manager, Engineering Documentation
- R. W. Peverley, Assistant Engineering Project Manager
- J. C. Shuckrow, STP Project Coordinator, STP Project
'*R. J. Vurpillat, Manager, Quality Assurance, Power Group G. H. Watkins, Supervisor, Engineering Document Control Center
- Denotes those present at the exit meeting.
B. Action on Previous Inspection Findinas 1. (Closed) Followup Item (Report 80-01, Section III.B.3.g). Deter-mine if the apparent breakdown of the Brown and Root Vendor Surveil-lance Program was generic. The inspector verified that a Brown and Root task force, the " Vendor Control Program," reviewed seven (7) procurement files and identified nine (9) generic areas of concern in the overall South Texas Project procurement cycle for safety related equipment. These concerns were reported to NRC, Region IV on July 14, 1980, and a new task force, the " Vendor Control Evaluation and Correction Program" was established by Brown and Root. The task force will resolve these concerns and assure that all safety related purchase orders are sufficiently accurate and complete so as to result in the final acceptance of safety related equipment, and its documentation, by Houston Lighting and Power, for use on the South Texas Project. We will inspect the results of this activity during our normal inspec-tion program. l n w M WM"W "i n . -_~ < -,---a n-x a
.. - _... _ ~ - - [ 204 4 2. (Closed) Followup Item (Report 80-01, Section III.B.3.c.(1)). Determine if the apparent lack of effectiveness of the Brown and Root Vendor Surveillance Program was reportable under 10 CFR Part 21. The inspector verified that the generic concerns related to the breakdown of the Vendor Surveillance Program were identified and evaluated by Brown and Root. The generic concerns were subsequently-reported to NRC Region IV as a potentially reportable deficiency by Houston Lighting and Power Co. in their letter ST-HL-2-AE-494 dated July 14, 1980 in accordance with the provisions of 10 CFR Part 50.55(e). Separate reporting of this breakdown in the Brown and Root Quality Assurance Program by Brown and Root under the provisions of 10 CFR Part 21 is not required. 4 i' 3. (Closed) Followup Item (Report 80-01, Section,III,-B.3.h) Determine if the Brown and Root purchase order for Reactor Vertical Supports reflected all safety related requirements identified in the South Texas Project FSAR. The inspector verified that this purchase order was scheduled for indepth review for inclusion of all applicable engineering, quality and regulatory requirements as part of the Brown & Root " Vendor Control Evaluation and Correction Program" prior to November 15, 1981. 4. (Closed) Deviation (Report 80-02, deviation B). Brown and Root has not implemented the overall Quality Assurance / Control Program for the South Texas Project that is described in section 17.1 of the PSAR. ( The inspector verified the corrective action, generic considerations and preventive, measures described in the Brown & Root letter of response dated August 8, 1980. Specifically, differences between the PSAR and the operating QA program were identified and resolved. A ' revised Houston Lighting and Power and Brown and Root " Quality Assurance Program for the South Texas Project" was submitted to NRC (NRR) on October 31, 1980. Brown and Root commitment to implementing the revised QA Program was contained in a memorandum dated January 8, 1981, from the Group Vice President, Power Group, to the Quality Assurance Manager. 1 ,__gm. .wm masa-a.thf
n 205 5 5. (Closed) Followup Item (Report 80-02, section I.B.6.b.(1)). Determine if the Brown and Root design for the personnel airlock with inflatable seals meets applicable requirements. a. With respect to the acceptability of the inflatable seal personnel airlock by NRR, Brown and Root management stated that the single active failure criteria and redundancy require-ments of the Brown and Root door seal design meet, or exceed, those of the McGuire door seal design which w'as accepted by NRR. Significant differences between the two (with respect to the,ab~ove, only) noted by the inspector are as follows. (1) Air lines to the STP seals do not penetrate into the containment as do the McGuire air lines. i (2) Solenoid valves in the air lines to the STP seals are designed to fail open as do those in the McGuire air lines. Brown and Root stated that they would evaluate the. design to determine if the valves should be changed to fail closed to prevent.bleedback through the instrument air supply system should an air line check valve fail. (3) STP will use Class lE pressure switches to detect seal deflation in addition to incorporating a seal leak.. rate detection system rather than only depend on a control room annunciator which will actuate whenever any of the seals deflate as McGuire does. (4) STP plans to incorporate two independent backup air supply systems to maintain seal inflation in the event of the loss of the instrument air system rather than the singular ( reserve air tank system for'the McGuire seals. (5) The STP design does not provide for test coupons of the seal material to be located in close proximity to the air-lock as does the McGuire design. (6) The Brown and Root procurement documents did not include l the requirement for a certificate of compliance for each door seal with respect to the ability of the seal material t to withstand post accident beta radiation exposure. Brown and Root stated that this requirement will be incorporated into the next revision of the design specification (2C269 SS06) for the airlock. 1 ~m=% - " MW * ** '""' u _ m m.-
20s 6 b. With respect to the adequacy of the Brown & Root inflatable seal airlock design, the inspector determined that design specification was verified in accordance with established procedures. The design was also evaluated using a Failure Mode and Analysis Technique which identified several potential deficiencies that were subse-quently corrected. However, the inspec'or identified several technical concerns with respect to door and seal pressure reten-tion capability. As a result of these and other unanswered ques-tions, Brown and Root management stated that they would conduct a documented formal multidisciplined design review of the personnel air lock design during the first quarter of 1981. 6. (Ciosed) Followup Item (Report 80-02, Section I.D.3.c.(1)). Verification of design inputs to stress calculations that are taken frcm stress iso-metrics could not be confirmed. Brown and Root management stated that a stress ' isometric drawing is only a transcription-(reproduction) of a certain portion of a piping system taken from a design verified composite piping drawing and is only used to aid in visualizing the piping system layout when stress calculations and hanger locations are determined for the system. Stress isometric drawings are checked for completeness and correctness against the composite piping drawing by a checker in accordance with procedure STP-DC-002. The inspector verified that the Stress Analysis Group (which is now part of the Support Design Group) did verify the accuracy of the type and location of supports shown on stress isometric drawings generated by them. 7. (Closed) Followup Item (Report 80-02, Section II.B.1.a) Evaluation. of the Consequences of the potential misuse of uncertified personnel for performing vendor surveillance activities. BYownandRootmanagementstatedthattheyhavefoundnoevidenceto date that unqualified (as distinct from uncertified) individuals performed particular inspections. 8. (0 pen) Followup Item (Report 80-02, Section II.C.3.e) The status of the Brown and Root Vendor Control Evaluation and Correction Program will be evaluated. 1 The program consists of seven phases which implement the Brown and Root Management commitment to NRC to define (and subsequently execute) a program that provides for a complete and thorough review and audit of the procurement documents, vendor control and surveillance activi-ties, and release of safety related equipment and material to the site that is in full compliance with all Brown and Root and Houston Lighting and Power commitments to NRC. m m m .__.,,m._.-
.-.._.....m_-- 20 7 The phases, approximate status, and revised initiation and completion dates provided to, or determined by, the inspector are as follows: a. Establish Priorities and Schedule - June 15 thru January 31, 1981 - 85% Complete versus 41% projected b. Generate "PO Baseline Requirements" - November.3, 1980 thru June 30, 1981 - 15% Complete versus 54% projected. c. Independent NUS Audit - September 1, 1980 thru September 15, 1981 - - 10% Complete versus 38% projected. d. Resolution of Audit Findings - February 15, 1981 thru September 30, 1981. ( e. Update Purchase Orders - March 1, 1981, thru October 15, 1981. f. Correct Vendor Deficiencies - March 15, 1981, thru October 31, 1981. g. Release of Equipment & Materials - February 15, 1981 thru November 15, 1981. Procurement of safety related equipment and materials will be closely monitored by NRC during future inspections. 9. (Closed) Violation (Report 80-03). Failure to meet 10 CFR Part 21 posting requirements ir, the facility where safety related piping stress analysis and pipe hanger design activities were being con-ducted. ~ ( The inspector verified the corrective action and preventive measures described in the Brown & Root letter of response dated December 16, 1980. Abbreviated notices,containing Section 206 of the Energy Reorganization Act and that. describe the content and location of the 10 CFR Part 21 Regulations and procedures, as well as the individual to whom reports may be made, were posted in a conspicuous position at all locations were safety related activities were being conducted. Quality Assurance Management committed to verify the posting at all locations on at least a quarterly basis. 10. (Closed) Deviation (Report 80-03, deviation A) Qualification ~ records /' of engineering personnel conducting safety related activities were not being maintained. e.m e.
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208 8 ~. Brown and Root did not update the qualification record files of all engineering personnel conducting safety related activities on the South Texas Project by the committed date of December 31, 1980. This is a deviation from commitment. See Notice of Deviation, Item A. Brown and Root updated all qualification and training record files of engineering personnel during the inspection. The files were less than 16% complete at the time the deviation was issued and were approximately 65% complete by December 31, 1980. Brown and Root Design Quality -Engineering reportedly did not sign off or approve any documents for issue since January 1, 1981, that were originated or signed by any individual whose qualification or training record was incomplete or inadequate. The inspector verified that a full time Training Coordinator was 4 assigned to Engineering, the Engineering Proced,ure For Training (STP-PM-006) was revised, and that the files are currently being maintained in the access controlled office of the Training Coordinator. ~ 11. (Closed) Deviation (Report 80-03, deviation B). Training records of engineering personnel conducting safety related activities were incomplete or non-existant. Brown and Root did not update the training record files of all engineering personnel conducting safety related activities on the South Texas Project by the committed date of December 31, 1380, See Notice of Deviation, Item A. Refer to item 10 above for additional details. 12. (Closed) Deviation (Report 80-03, deviation C) Hanger design and fabrication drawings were design verified and approved with duplicate .r identification numbers. Pipe fabrication isometric drawings were revised and issued without using the next sequential revision number. The inspector verified the corrective action and preventive measures described in the Brown and Root letter of response dated December 16, 1980. Specifically: a. With respect to drawings being approved with duplicate identi-fication numbers: (1) all affected drawings were corrected; (2) the potential for duplicate numbers being affixed to more than one drawing appeared to be restricted to the Support Design Group in that their drawing numbers convey intelligence (ie, the actual location of the support or hanger) whereas drawings issued by other Brown and Root design activities do not; (3) the pro-cedure for Drawing Control (STP-CD-002) will be revised by January 31, 1981 to require the Discipline Project Engineer to - - _ m _ awem --- ~ ~ : - e "' m
~ i a; 1 ...i.. ... o. m.. t . _m _m 209 9 1 verify that the drawing number is both correct and unique prior to his signing the drawing; (4) The Engineering Document Control Center Computer Program for logging in newly issued design dccuments will not accept a new entry if the total identifica-tion number is a duplicate of an already existing listed number. b. With respect to pipe fabrication drawings being revised to indicate the type and location of pipe supports and issued without using the next sequential revision number, the title block of all such drawings issued in support of, or as part of, a calculation package will be crossed out to prevent subsequent inadvertant use of the wrong revision of the drawing by the contractor. The original drawing will then be revised to. reflect the type and issued as the next sequential revision of the drawing. 13. (Closed)UnresolvedItem(Reiert80-03,SectionI.D.3.b(1)). Docu-mentation made available during the inspection'did not appear to substantiate that significant safety hazards were evaluated, documented, Y and reported.in accordance with the provisions of 10 CFR Part 21. The inspector determined that during the.first quarter of 1981: a. Existing files on safety concerns will be reviewed for inclusion of pertenent data relating to the safety concern, Sufficient information will be retained in the file such that the history and status of the safety concern will be clearly defined and t that will assure meeting the record retention requirements of Section 21.51 of 10 CFR Part 21. b. The Engineering Document Control Center wil.1 retain all files on safety concerns. c. The Procedure for Evaluating and Rep'rting of Defects, Noncom-o pliances and Deficiencies, STP-PGM-022, is being revised. d. Quality Assurance will audit for compliance with 10 CFR Part 21 requirements on a quarterly basis for at least the next year and annually thereafter. 14. (0 pen) Unresolved Item (Report 80-03, Section I.D.3.b.(2)) An apparent violation exists in that Brown and Root was not adhering to their procedure for implementing 10 CFR Part 21' requirements. The matter has been forwarded to NRC headquarters for evaluation to determine the appropriate enforcement action to be taken. 15. (0 pen) Followup Item (Report 80-03, Section I.B.4) Verify implementation of a management plan to assure that Commitment to NRC will be performed as stated and be effectively implemented. ...>..-m.-.--- -- --:~ r . 1 n ~~~ ~ ~ ~ 1 1
_. ~. _ _. _. _. -.. g39 10 Brown and Root developed a routine system and a followup form (NRC Action Item Commitment List) which was implemented on inspection 80-03. In view of the reccurance of Brown and Root management not meeting one of their commitments for the last (80-03) inspection, Brown and Root Power Group executive management issued two memoranda to Quality Assurance on January 8, 1981, which contain provisions for preventing reccurance of the failure to complete corrective action as committed. The memoranda state that: a. All Brown and Root commitments shall be met in the performance of our responsibilities on the project. b. Each NRC identified deviation, unresolved item, or other out- ~ standing item will be listed (as well-as the individual respons-ibile for action thereon) and distributed accordingly. ( c. An internal commitment date is to be estab'lished which is earlier (generally two weeks) than the date committed to NRC. d. Quality Assurance is responsib'le for following the implementation and completion of corrective actions. e. Prior to the commitment date to NRC, Quality Assurance is to independently verify, by review of objective evidence, that the corrective actions have been completed. The senior vice presi-dent is to be notified for each specific failure to complete corrective action. f. The status of open B&R commitments to NRC will be reported at the regular STP - QAMRB meetings. ( The effectiveness of these measures will be closely followed during future inspections. 16. (Closed) Followup Item (Report 80-03, Section I.C.3.b(1)). Objective evidence was not available that the education and experience listed on the qualification / resume sheet of all NPS (Nuclear Power Services) and ATI (Associated Technologies Incorporated) personnel who were conducting safety related activities for the Brown and Root Support Design group was in fact verified by either Brown and Root or NPS/ATI. The inspector verified that Brown and Rcot requested written confirm-ation from both NPS and ATI that the alleged education and experience for all present and future employees assigned to the STP be verified. g me+va * *".**) Y OON* =E
o,.. 411 11 NPS and ATI provided a list of their employees whose alleged education and experience had been verified along with a copy of their procedure for Employee Verification and one sample of a complete verification package. No misrepresentations were apparently uncovered to date. However, verification of the alleged education and experience for six (6) of the twenty one (21) ATI employees currently assigned to the STP had not been completed as of January 7, 1981. Brown and Root management thereupon requested on January 7, 1981 that ATI complete the verification process for these employees and advised ATI that the verification must be done in accordance with the intent of NRC circular IEC 80-22. The manager of the Support Design Activi.ty which deploys these six (6) ATI employees stated that only verified and qualified personnel will be permitted to perform safety related activities on the STP. 17. (Closed) Followup (Report 80-03, Section I.C.3.t(2)). Objective evidence that an approved 10 CFR 50 Appendix B quality assurance program was imp.osed on NPS and ATI personnel who were conducting safety related activities for STP. The inspector verified that on January 7, 1981, the manager of the Support Design Group notified the on-site (STP project) NPS and ATI management in writing that all work done in the Brcwn and Root offices (on STP) is to be done under the Brown and Root Quality Assurance Program via the use of (STP) Engineering Procedures and for them to assure that their personnel are complying with the procedures. P'ocedures which 18. (Closed) Followup (Report 80-03, Section I.C.3.b(3)). r require that sufficient records be maintained for engineering and management personnel assigned to safety related nuclear projects to furnish objective evidence of their qualification to perform their assigned duties and responsibilities were not available during the inspection. Brown and Root Power Division Procedure DL 035 dated June 10, 1980 (Procedure for Verification of Education and Experience) defines the process for verifying the educational background and prior job experi-ence of new Brown and Root employees. The Group Vice President, Power Group, stated in his memorandum of l l October 28, 1980 that: The Power Group will assume the responsibility for checking l a. (verifying) each new Power Group professional as they are hired l (using procedure DI.035) beginning May 21, 1980. I i f l -.-,_ -..-- - --_7 y :- - 7 ,y _ _ _ ~.
212 12 b. Letters were mailed on September 15, 1980, requesting documented evidence of the educational background and prior job experience for each STP engineer, designer and project control professional employed prior to May 21, 1980. c. Most of the responses have been returned, examined, and placed in the individual's file. d. Adherence to Power Group Procedure OL-035, and surveillance of contract companies, will assure that every professional person working on any Power Group job will have documented evidence of his or her education and work experience. This item completes an Inspection of employment practices at Brown and Root in that: (1) the education and work experience infor-mation contained in employees' job applications are being verified by the employing organization; and (2) there is' objective, docu-mented evidence / records that attest to the education and experience of both permanent and contract employees. C. Design Document Control 1. Objectives To determine if approved procedures have been established and are being implemented for the cor. trol and distribution of design documents that provide for: a. Identification of personnel, positions, or organizations responsible for preparing, reviewing, approving, and issuing design documents. b. Identification of th'e proper documents to be used in perfarming the design. c. Coordination and control of design (internal and external) inter-face documents. d. Ascertaining that proper documents, and revisions thereto, are l accessible and are being used. I e. Establishing distribution lists which are updated and maintained current. 2. Methods of Accomplishment The preceding objectives were accomplished by: lg .-., c. : _ .g n - x;wwww w =m=97 ' M :
13 a. Review of the following documents to determine if procedures-have been established to control design document generation, review, approval, distribution, and use in the areas icentified in objectives a. through e. above: (1) Sections 17.3, 17.5, and 17.6 of the ERC accepted (Brown and Root) Topical Report B&R-002A (Quality Assurance Program for Nuclear Power Plants) Revision 3, including changes made thru March 24, 1980, to determine the Brown and Root Corporate programmatic commitments relative to the control of design documents. (2) Sections 3, 5, and 6 of the B&R STP (South Texas Project) Quality Assurance Manual to determine if the corporate commitments relative to control of design documents were correctly translated into qualit'y aspurance requirements a and procedures. (3) Thirteen (13) applicable procedures contained in the STP Engineering Procedures Manual to determine that the STP quality assurance program requirements and procedures were' correctly translated into a' viable engineering program for control of design documents. h. The following documents were reviewed to determine if the quality assurance program for control of design documents was being effectively implemented on current design activities affecting quality by the B&R engineering organizations: Six (6) Calculations, Three (3) Design Manuals, ~4 Three (3) Design Verifications, Twenty (20) Internal & Foreign Drawings, Two (2) Procurement Files, One (1) Report, Three (3) Specifications, Two (2) System Design Descriptions ~, and Nine (9) Technical Reference Documents. 3. Findings a. Deviations from Commitment Two (2) deviations from commitment were identified in this area of the inspection. See Notice of Deviation, Items B & C. (1) With respect to Deviation B: a. The STP Design Manual (DM) is controlled assemblage of approximately 200 System Design Des'criptions (500) ~ l{ w-=-
n. ~~ 2bj 14 and design criteria documents such as Technical reference Documents (TRD). The Manual describes the salient features of the STP design; defines the require-ments for its structures, systems and components; pro-vides design criteria, specifications, procedures, analyses and guidance; and identifies directly, or through references, the design inputs that provide the point or origin for the system discriptions con-tained therein. (b) Two (2) issued TR0s examined by the inspector and five (5) additional TR0s subsequently found by the STP Design Quality engineer in each of the three DMs examined did not exhibit evidence of the required review and approval signatories. These TR0s were g issued through the official Browp and Root Engineering Document Control Center. Although six (6) of the seven (7) TR0s contained a statement in their abstract that they were issued for review and comment, no such disclaimer appeared in the " body" of the document that would be used or referenced by the designer. One such documents was BL369RQ014 - A, dated July 5, 1978, and entitled " Typical Pipe Supports for 6" Nominal Diameter Pipe and Under." This TRO was contained in the Design Manual located at the pipe hanger and support activity. While there is no evidence that this unapproved pro-cedure was used to actually provide guidance and/or input to the design of safety related pipe supports, its very presense in the facility where the design activity was ongoing off.ers the potential for its inadvertant misuse. (2) With respect to Deviation C: (a') Section 6.0 of the STP Quality Assurance Manual states that a comprehensive document status list shall be published at least every two months by the EDCC (Engineering Document Control Center) to ensure that the responsible engineering personnel are working to the latest revision or issue of an Engineering document. (b) Contrary to this procedure, the responsibility for issuing an engineering document status list has been l assigned to a different activity, the Computer Support l Group, that does not provide the same controls for the accuracy of their data base as does the EDCC. i l l --r
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1 2.15 15 D. Exit Meetina An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on January 8, 1981. In addition to those individuals indicated by an asterisk in the Details Sections of this report, the meeting was attended by: W. M. Rice, Group Vice President, Power Group K. A. Swartz, Senior Engineering Manager P. S. Jordan, Nuclear Licensing Staff Manager K. R. Cook, Deputy Project General Manager J. R. Orlando, QA Coordinator, Vendor Surveillance R. P. Negri, Assistant. Quality Assurance Manager C. E. Bingman, Assistant Manager, Vendor Surveillance lI The inspector discussed the scopi of the inspection and the details of the findings identified during the inspection and the form and content of letters of response to NRC inspection reports. Management comments were generally f.or information only or for acknowledgement of the state-ments of the inspector with respect to the deviations presented. T 1 prr' Tve'N7 r r e } '~
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. ~ ;... m. =:. ~ 216 16 I l DETAILS SECTION II i (Prepared by D. G. Breaux) A. Persons Contacted
- P. J. Bulten - VCP QA Task Force Leader R. G. Burnette - B&R/HL&P Lead Coordinator
- J. R. Childers - QA Coordinator H. T. Faulkner - Project Coordinator E. J. Manning - Superviser QA Manual Review R. C. McMahill - Senior Engineer T. J. Ries - Regional Coordinator Vendor Surveillance
- Denotes those present at the exit meeting.
B. Procurement Source Selection 1. Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for the selection of qualified suppliers of services, materials, parts and components that provide for: Requirements for evaluation of the potential supplier's capa-a. bility to provide items or services in accordance with the technical and quality assurance specifications of the procure-ment documents. b. ' Methods of evaluating potential suppliers that are consistent with applicable regulatory, code and contract requirements and should include source evaluation audits, review of historical performance, and/or review and evaluation of the supplier's QA program, manual and procedures. Consideration of the complexity, inspectability and safety c. significance of purchased items or services when selecting the method of source evaluation. d. Performance of source evaluation audits that include appropriate checklists or instructions for systematic review of the prospective supplier's QA system. ,7,, m-,,-. 9, - % y,- P~~~ ~ ~ ~ ~ ~ ~
E y-17 e. Qualification requirements for personnel performing source evaluation audits. f. Source selection being based on historical product performance that includes review of past procurement and operating experience with identical or similar items and is limited to relatively simple services or off-the-shelf items. g. Periodic re-evaluation of suppliers and that an up-to-date listing of the evaluation status is being maintained. h. Distribution of supplier evaluation status documents to purchasing and assuring that contracts are awarded only to companies desig-nated in these documents. i. Measures to assure that the supplier's bid conforms to the pro- -( curement document requirements and that resolution of unaccept-able conditions identified during bid evaluation are corrected before the contract award. 2. Method of Accomolishment The preceding objectives were accomplished by reviewing the following documents relative to the Brown and Roots Quality Assurance Program. The appropriate sections (policies and procedures) of the a. recently revised, (as of October 31, 1980) " Brown and Root, Inc. Quality Assurance Program Description During Design and Construction of'the South Texas Project Electric Generating Station" were reviewed to determine that commit-ments to quality were reflected in the area of procurement {( source selection. b. The following procedures were reviewed in the South Texas Project Quality Assurance Procedures Manual to assure that quality related commitments were being procedurally implemented. (1) ST-QAP-4.2, " Houston Purchasing Activities" (2) ST-QAP-7.1, "Vandor Surveillance Organization" (3) ST-QAP-7.2, " Vendor Surveillance and Houston Coordination Activities" (4) ST-QAP-15.4, " Trend Analysis" .. ~,.,, _ _ _ _...._v,,.~.,
mwa-- w; c-m.--~ ~m---- - m -- -- 216 18 (5) ST-QAP-18.1, " Audit Program" c. To assure that the previously reviewed quality commitments were being properly and effectively performed with respect to procure-ment source selection, the followirig documents were reviewed: (1) Four (4) South Texas Project procurement files on selected purchase orders from the Purchasing Department were shown to contain Pre-Award procurement activities such as: (a) QA Department Quality Assurance Vendor Questionaire (b) Engineering Capability and Experience Questionaire (c) Pre-Award Facility Survey 0 (d) Commercial, Technical, and Quality Assurance evaluations (e) Final recommendation of award for license approval. (2) South Texas Project Approved Vendor List, dated December 23, 1980 was checked for proper distribution and timely updating. (3) Five QA Manual Review reports conducted by the QA Audit Section were reviewed for content and proper manual status follow-up. (4) Three (3) Vendor Pre-Award Survey's conducted by the QA Audit Section were reviewed for content and proper. review. (5) The Audit Deficiency Report (ADR) Trend Analysis System. { was examined to see that Quality Commitments 're being a met and that the system is in place and functioning. (6) Documents being gathered by the Vendor Control Program Task Group, in the area of Quality Assurance evalua-tion of the Vendor's quality program and its implementation, are listed on the QA Support Documentation List and the Vendor Control Program (VCP) Vendor History Matrix. The Document list and History matrix were reviewed for content and proper procedural implementation. Quality Assurance Support Documentation compilation that was committed to in the Vendor Control program was reviewed for content of the following document types: (a) Vendor QA Manual Reviews and associated documentation. (b) Preaward Survey Reports and associated documentation.
.t* 219 ~ 19 (c) Correspondence justifying waiver of preaward evalu-ation activity. (d) Quality Assurance bid evaluation correspondence. (e) Vendor Audits and associated documentation. ~ (f) Correspondence changing QA Vendor approval status. (7) Five (5) Audit Deficiency Reports (ADR) were-examined for content and proper review and approval. 3. Findings a. Deviati~ons I In this area of the inspection no deviations from commitment were identified. b. Unresolved Items or Follow-uo Items None were identified. c. Comments It was observed during this inspection that the thrust of Pre-award Survey's and subsequent annual Supplier Quality Assurance Evaluation has been shifted from the responsibility of Vendor Surveillance to the Quality Assurance Audit Section. Procedures defining and reflecting this change have been issued, or in their final draft stages, at the time of inspection. ( A concerted effort by the audit section to control previously undispositioned audit findings in the area of supplier Quality Assurance Programs is in process. The use of the recently implemented Audit Deficiency Report (ADR) Trend Analysis System should aid in this area of control. To expedite the process of closing out audit findings, the audit section is working with vendor surveillance. Instead of possibly waiting (1) year for the annual Supplier Quality Assurance Program re-evaluation to verify that supplier corrective action to audit findings had been implemented, vendor. surveil-lance can assist in this area by verification of supplier action during their more frequent in process source inspections.
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. ~... 220 20 C. Supolier Nonconformance and Corrective Action 1. Objectives The objectives of this area of the inspection were to verify that procedures have been established and implemented for: a. Disposition of nonconformances that provide for: (1) Measures by the purchaser and supplier for identification, control, review, and disposition of items or services that do not meet procurement document requirements. (2) Submittal of nonconformance notice to purchaser by supplier which shall include recommended disposition and technical ( justification. (3) Submittal to the purchaser for approval of dispositions containing one or more of the following nonconformances: (a) Technical or material requirement violated. (b) Violated requirement in supplier document approved by purchaser. (c) Non'conformance cannot be corrected by continuation of the original process or by rework. (d) Original requirement is not met but the item can be restored so that its function is unimpaired. (4) Purchaser. disposition of supplier recommendations, verifi- ~ cation of disposition, and maintenance of records of noncon-formance. b. Corrective action that provides for: (1) Identification of and timely corrective action for conditions adverse to quality which occur during the procurement process that are the responsibility of the purchaser. (2) Review and evaluation of conditions adverse to quality to . determine the cause, extent, and measures neeced to correct and prevent recurrence. (3) Reporting these conditions and the corrective action to management. - - - r -me ~ "'
a n., ~.- gg3 21 (4) Assuring that corrective action is implemented and ma'intained. (5) Verification of supplier's corrective action system. 2. Method of Accomplishment The preceding objectives were accomplished by review of the following documents relative to. Brown and Root Quality Assurance Program. a. The appropriate sections of the recently revised (as of October 31, 1980) Brown and Root, Inc. " Quality Assurance Program Description During Design and Construction of the South Texas Project Electric Generating Station" were reviewed to determine that commitments to quality were reflected in the area of Supplier Nonconformance and Corrective Action.* ( b. The following procedures were reviewed in the South Texas Project Quality Assurance Procedures Manual to assure that quality related commitments were'being procedurally implemented. (1) ST-QAP-7.1, " Vendor Surveillance Organization" (2) ST-QAP-7.2, " Vendor Surveillance and Houston Coordination Activities" (3) ST-QAP-15.1 " Nonconforming Item 3" (4) ST-QAP-16.1 " Corrective Action" (5) Vendor Surveillance Policy Notes VSPN-012 "Nonconformances." I Review of the following documents to. assure that the quality c. commitments are being properly and effectively performed with respect to Supplier Nonconformance and Corrective Action. (1) Five (5) Vendor Surveillance Plans (2) Five (5) Vendor Surveillance Reports (3) Two Vendor Control Program pa,ckages that contained Surveillance / Inspection History such as: (a) Vendor Sur/eillance Reports and Surveillance / Inspection Reports. ,4 -M E--- -e-, y-Tg. g % =4 p
nn ccc 22 (b) Certificates of Conformance (c) Nonconformance Reports (4) Five (5) Vendor Surveillance Work Folders (5) Six (6) Nonconformance Report (NCR) and their accompanying correspondence. (6) Five'(5) Nonconformance Report (NCR) closure notifications to supplier. (7) Nonconformance Report (NCR) Status Report dated December 31, 1980. 1 3. Findings i a. Deviations In this area of the inspection no deviations from commitment were identified. b. Unresolved Items or Follow-up Items None were identified. ( l l l l t m. m.-.. -,.~
I [a... 'jg UNITED STATES NUCLEAR REGULATORY COMMISSION y3 8 [5
- jg%j WASHINGTON, D.C. 20555 a'
B ,. %y..syf OFFICE OF THE SECRETARY CERTIFICATION 18 I hereby certify that the attached pages contain a true copy of the Letter dated Mav 1R. 1981 fo rm a.T. en11 ins to Brown & Root Co., Inc. regardi no LCVI P i'n s p e c t i o n by l Mr. 0.F. Fox on April 13 - 17, 1981, together with that letter's attachments. on file with the United States Nuclear Regulatory Commission's Public Document Room, 1717 "H" Street, N. W., Washington, D.C. l htywQl ID, l W4 Lqc Ab " Date Official Custodian of the Records of the Public Document Room Office of the Secretary of the Commission i (SEAQ 1 1 wr, g-e 9 -- meo ~ _ _. -w Q_- me wwmm -c-n
_.n 225 MT O Docket iio. 99900502/31-02 3rown and Root, Incorporated ATTii: Mr. L ri. Rice , Group Vice President, Power Group
- 100 Clinton Drive Post Office Box 3 nuuston, Texas 77001 Gentlecen:
This refers to the inspection conducted by :tr. D. F. Fox of this office en Acril 13-17,19:31, of your facilities at Houston, Texas, and to the ciscussions
- our fincings with you and members,of your staff at tne conclusion of the
$. m etion. Areas examined during this inspection and our findings are discussec in the enclosea inspection report. Within these areas, the inspection consisted of an axamination of procedures and representative records, interviews with person::el, anc osservations oy tne inspector. During this inspection it was found that you failed to reet certain URC req re-l ments. The specific findings and references to the pertinent requirements am 4 iuentified in the enclosures to this letter. t Tne iictice of Violation is sent to you pursuant to the provisions of 10 CF:1 Part 2.201. You are required to sutait to this office within 30 days of the date of this letter a written statement containing, (1) a description of steps tnat nave been or will be taken to correct tnese items, (2) a description of steps that have been or will be taken to prevent recurrence, and (3) the. dates Cen-your corrective actions and preventive measures were or will be completed. siceration may be given to extending your response time for cccc cause shown. You are also requested to submit a similar written statement for each item which appears in the enclosed iiotice of Monconformance. This is the fourtn inspection in which Engineering and Quality Assurance training and qualification records were found to oe not maintained as comitted (See iiotice of Nonconfonnance enclosure, Item C and previous Inspection Report 6es. 99900502/30-01, 99900502/S0-03, and 99900502/81-01.) This suggests a breakdown in the effective implementation of the Srown and :icot IdM Quality Assurance Program in this area for the South Texas Project. ii E Consequently, in addition to responding to the specific items identifiec in the
- G dotice of donconformance enclosure, please define the specific steps that you have taken, or plan to take, to assure that your coccitments in the area of
- -i ion wi l oe erYectively implementaa.
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n _ _ _ _ ~ m _____. _, 225 Brown and iloot, Incorporated 2 In accorcance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the hRC's Public Cocument Room. If this report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of your intention to file a request for withholding; and (b) sub-mit within 25 days from the date of. this letter a written application to this office to witnhold such infomation. If your receipt of this letter has been celayed sucn that less than seven days are available for your review, please notify tais office promptly so that a new oue date may be established. Consistent with Section 2.790(b)(1), any such apolication must be accompanied by an affidavit executed by the owner of the infomation which identifies the cccurent or part.sougnt to oe withneld, and which contains a full statement of toe reasons on toe basis wnich it is claimec that the 'infomation shoulc be witanela frca public cisclosure. This section further requires the statecent to acaress with specificity the considerations listed in 10 CFR 2.790(b)(A). Tne infomation sougnt to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard witnin the specified periods noted above, the report will be placec in tne Paolic Cocument tioom. Snould you nave any questiens concerning this inspection, we will te pleasec to ciscuss them with you. Sincerely, John T. Collins Acting Director Region IV
Enclosures:
1. hotice of Violation E. Ilotice of lionconfomance 3. Inspection Report.io. 99900502/81-02 I i l l { l l i
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m m. -- e-,- 3,.. m. _ .w. - 220 Brown and Root, Incorporated Docket No. 99900502/81-02 ~ NOTICE OF VIOLATION Based on the results of NRC inspections conducted on September 29, through October 3, 1980 and April 13-17, 1981, it appears that certain of your activities were not conducted in full compliance with NRC requirements as indicated below: Section 21.21 of 10 CFR Part 21 requires that "A director or responsible officer subject to the regulations of this part. . shall notify the Commission when he obtains information reasonably indicating a failure to comply, or a defect ... Initial notification required by this paragraph shall be made within two days following receipt of the information.... If initial notification is by means other than written communciation, a written r,eport shall be submitted to the appropriate Office within 5 days after the information is obtained." Contrary to the above, Brown and Root failed to submit a written report to NRC within the required five days that a significant safety defect existed in delivered piping supports. The responsible officer determined on July 3, 1980, that safety concern number 57 was reportable under the provisions of 10 CFR Part 21. Houston Lighting and Power verbally reported the item to NRC on July 3, 1980, but Brown and Root did not submit a written report to NRC until July 11, 1980. This is a Severity Level VI Violation (Supplement II). t l l % 2 ave 9 E11Am15 PDR OA999 EECBRRT 99900502 PDR l l t a
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.m.. e ....--a.m..._...__. 227 Brown and Root, Inc. Docket No. 99900502/81-02 NOTICE OF NONCONFORMANCE Based on the results of an NRC inspection conducted April 13-17, 1981, it appears that certain of your activities were not conducted in accordance with NRC require-ments. A. Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be accomplished in accordance with instructions and procedures. Sections 3.0 and 2.5 of Brown and Root procedure STP-PMO-022 (Procedure for Evaluating and Reporting of Defects, Noncompliances and Deficiencies) respectively state in part that, "Each defect, noncompliance or deficiency evaluated by the Incicent Review Committee will be recorded on an NCR (or ADR, if appropriate). All subsequent documentation related to such defect, noncompliance or deficiency shall reference the governing NCR (or ADR). The NCR (or ADR) in turn will have an attachment listing all related documents to effect a cross-referencing mechanism.... The total docu-mentation package shall be filed under the NCR (or ADR) and stored with the. classification of a permanent QA record. Therefore, all documentation relating to a possibly reportable or reportable incident including correspondence, meeting minutes, telephone minutes, evaluation reports and written reports will be identified for file copy by the NCR (or ADR) number and transmitted to the Quality Assurance Record Center.... "A written report is required to be submitted to the NRC... on each defect, noncompliance or deficiency reported to the NRC per 10 CFR 21 or 10 CFR 50.55(e).... An outline for these written reports is provided in Attach-ment C to this procedure." Contrary to the above, safety concerns 9, 22, 23, 26, 45, 46, 53, 66, 69, and 20 others evaluated by the Incident Review Committee were not recorded on an NCR or ADR, nor did all subsequent documentation related to these safety concerns reference a governing NCR or ADR. In addition, the total documentation packages for these concerns (1) were not stored with the classification of a QA record; and (2) were not transmitted to the Quality Assurance Record Center. Furthermore, the written report submitted to NRC regarding safety concern 81 (Cable Tray Hanger Design Deficiency), and others, did not contain all the information required by Attachment C to the Brown and Root procedure. 46f8I40YE PDR 99900502 . - - =--
.-.n---..-_ 22fi ~ 2 B. The NRC Letter of Acceptance of the Brown and Root Topical Report B&R-002A (revision 3, September 1977) states in part that, " Programmatic changes by Brown and Root to this topical report are to be submitted to NRC for review prior to implementation. Organizational changes which do not affect the program are to be submitted no later than 30 days after announcement." Contrary to the above, programmatic and organizational chsnges made to the program by Brown and Root during the past year were not submitted to NRC as required. Refer to Details Section paragraph C.3. for details. C, Criterion V of Appendix B to 10 CFR Part 50 states that activities affecting quality shall be. accomplished.14 accordance with instructions and procedures. Brown and Root South Texas Project Procedure STP-PM-006 (Personnel Training) states that, "Each personnel qualification file shall include... Pro-jected or completed Procedural,, Reading List (Form 200.81)... Projected or completed Training Requirements Checklist. (Form 200.129)... Evidence of completion of Q? Introductory Series." Contrary to the above, the qualification files of four employees hired since February 12, 1981, did not include Form 200.81 (two of the employees), Form 200.129 (three of the employees), nor evidence of completion of QA Introductory Series (all four employees). D. Sections 6.2.1.1.3.8 and 3.11.5.2 of the FSAR for the South Texas Project nuclear power generation station state that, " Mechanical and electrical components of safety related equipment were qualified for their potential normal operational environment and worst-case accident (DBA) environment. The two general categories of postulated accidents considered in equipment qualification were LOCA and MSLB... For in-containment equipment, the DBA LOCA source term is an equivalent 100% core meltdown." i Contrary to the above, the material used for the inflatable seals of the containment personnel and auxiliary air locks was not fully qualified for the worst-case accident (DBA) environment in that the Beta radia-tion resistance of the seal material had not been determined to date, norwastherequirementforqualifyingthesealmaterialtowithstand Beta radiation (1.4 x 10 Rad, per NUREG-0588) included in the pro-curement documents for the air lock. E. Criterion V of Appendix B to 10 CFR Part 50 states that activities affect-ing quality shall be accomplished in accordance with instructions and procedures. .-m
.~ _ _ _ 220 3 Brown and Root procedure DL 035 (Power Personnel Services Procedure for Verification of Education and Experience) states in part that, "The applicant shall provide documented evidence of completion of high school or college attendance, as applicable. Documented evidence is understcod to mean an original transcript or dipicma which may then be xeroxed by a Personnel Services Specialist if additional copies are required. The copies shall be initialed and dated by the Personnel Services Specialist to verify authenticity." Contrary to the above, a Persor.nel Services Specialist did not authenticate by initialing and dating copies of transcripts or diplomas that were contained in the personnel department record files of four of the eight examined files of newly hired employees. a = f m ~ '
e. 230 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 99900502/81-02 Company: Brown and Root, Incorporated Power Engineering 4100 Clinton Drive Post Office Box 3 Houston, Te.xas' 77001 Inspection Conducted: April 13-17, 1981 U Inspector: D. F. Fox, Contractor Inspector Date Reactor Systems Section Vendor Inspection Branch / b N/ Approved by:' le,~ Chief Oate C. JC @ Systems Section ReactTr Vendor Inspection Branch Summary Inspection on April 13-17, 1981 (99900502/81-02) Areas Inspected: Implementation of Title 10 CFR Part 50, Appendix B, and Topical Report B&R-002A, including follow up on previous inspection findings, design process management, and technical personnel background verification. The inspec-tion involved 46 inspector-hours on site by one NRC inspector. Results: In the three areas inspected, one violation and five nonconformances were identified. No unresolved or follow up items were identified. Violation: Follow up on Previous Inspection Findings: Failure to submit a written report of a significiant defect in piping supports within the time j required by 10 CFR Part 21. (See Notice of Violation) Nonconformances: Follow up on Previous Inspection Findings: Failure to adhere to the requirements in the Brown and Root 10 CFR Part 21 implementing procedure (See Notice of Nonconformance, Item A). Design Process Management: Failure l to submit to NRC changes in the QA program and organization described in the Brown and Root Topical Report (See Notice of Nonconformance, Item B); Failure to include Beta radiation resistance requirements in the specification for l personnel and auxiliary air lock inflatable seal material (See Notice of l 0
m.__ m_ 231 2 Nonconformance, Item C); Failure to maintain required training records (See Notice of Nonconformance, Item D). Technical Personnel Background Verifica-tion: Failure to follow procedure for authenticating copies of educational diplomas or transcripts of new employees (See Notice of Nonconformance, Item E). s e D ~ ^s _,x u Oww w s enO9m mF '*" ~~ ~ W~-- .me w - vn m V a ^
......-~-..-..._.....-m-_c. l 232 3 ^ DETAILS A. Persons Contacted
- R. J. Vurpillat, Manager, Quality Assurance
- H. T. Faulkner, Project Coordinator H. L. Bell, Project Staff Manager G. C. Priddy, Manager, Personnel
- P. A. Padden, Manager, Engineering Documentation R. W. Peverley, Assistant Engineering Progject Manager
- J. R. Childers, Houston Quality Assurance Coordinator
- B. F. Mitchell, Manager, Design Quality Engineering
- P. S. Jordan, Manager, Nuclear Licensing Staff
- K. R. Cook, Project Deputy General Manager
- S. J. Kelly, Training Coordinator M. Weintraub, Subcontracts General Manager
- J. A. Signorrelli, Manager, Technical Staff J. F. Halsey, Manager, Special Problems Group
- A. H. Geisler, Manager, Nuclear Licensing
- Denotes those present at the exit meeting.
B. Action on Previous Insoection Findings 1. (0 pen) Follow up Item (Report 80-02, Section II.C.3.e). The status of the Brown and Root Vendor Control Evaluation and Correction Program will be evaluated. The program consists of seven phases which implement the Brown and Root management commitment to NRC to define (and subsequently execute) a program that provides for a complete and thorough review and audit of the procurement documents, vendor control and surveillance activities, and release of,afety related equipment and material to the site that is in full compliance with all Brown and Root commitments to NRC. The phases, approximate status, and initiation and completion dates l provided to, or determined by, the inspector are as follows: l l a. Establish Priorities and Schedule - June 15, 1980, through j January 31, 1981; 100% Completed as of March 15, 1981. One hundred and sixty procurement actions were identified, prioritized l and scheduled for review. i i ..m - m m
l "l 200 4 r b. Generate "PO Baseline Requirements" - November 3, 1980, through July 17, 1981; 8% Complete versus 58% projected. Independent NUS Audit - September 1, 1980, through September 8, c. 1981; 2% Complete versus 62% projected. d. Resolution of Audit Findings - February 15, 1981, through October 9, 1981; 0% Complete versus 25% projected. Update Purchase Orders - March 1, 1981, through November 6, e. 1981; 0% Complete versus 17% projected. f. Correct Vendor Deficiencies - March 15, 1981, through December 4, 1981; 0% Complete versus 11% projected. g. Release of Equipment and Materials - February 15, 1981, through December 4, 1981; 0% Complete versus 20% projected. Procurement of safety related equipment and materials will continue to be closely monitored by NRC during future inspections. 2. (Closed) Deviation (Report 80-03, deviation D). Superseded QA procedures were not destroyed nor stamped void. The inspector verified the corrective action and preventive meast es described in Brown and Root letters dated December IE. 1980, January 20, 1981, and March 18, 1981. Specifically: a. Quality assurance reviewed the QA Manual for procedures with non-unique identification and for reference to voided or superseded documents. b. A list of non-unique QA procedures and inappropriately referenced documents in QA procedures was generated and distributed to , holders of'QA Manuals. ~ c. A draft revision of the QA Manual was issued for internal review and comment. d. The revised QA Manual is committed for issue prior to the ASME resurvey which is currently scheduled for August 1981. 3. (Closed) Unresolved Item (Report 80-03, Section I.D.3.b.(2). An apparent violation exists in that Brown and Root was not adhering to l their procedure for implementing 10 CFR Part 21 requirements. I t [_ ~ ~'
. u. _ r.m. _. 234 ~ 5 This item was elevated to a violation as well as a nonconformance. See Notice of Violation enclosure and Notice of Nonconformance enclosure, Item A. 4. (Closed) Follow up Item (Report 80-03, Section I.B.4). Verify imple-mentation of a management plan to assure.that commitments to NRC will be performed as stated and be effectively implemented. The inspector verified thaf. Brown and Root developed a system and a form (NRC Action Itam Commitment List) which was implemented for inspection 81-01 findings. The system and form requir.ed he following: a. Each NRC identified deviation, unresolved ' item, or other out-standing item be listed (as well as the individual responsible for action thereon) an,d distributed accordingly, b. An internal commitment date be established tiat is earlier (generally two weeks) than the date commit.ced to NRC. Quality Assurance is responsible for following the implementation c. and completion of corrective actions. d. Prior to the commitment date to NRC, Quality Assurance is to independently verify, by review of objective evidence, that the corrective actions have been completed. The Senior Vice President is to be notified for each specific failure to complete corrective action by the internal commitment date, e. The status of open B&R commitments to NRC be routinely reported at the STP - Quality Assurance Management Review Board meetings. The effectiveness of the system will be followed during future inspections. 5. (Closed) Nonconformance (Report 81-01, Item A). Corrective action committed in a Brown and Root response to a. previous finding had not been completed as scheduled. The inspector verified the corrective action and preventive measures described in Brown and Root letter of response dated February 16, 1981. Specifically: l l l _,.c.. _ m
-. w.- n...._... 233 6 a. Brown and Root developed and implemented a system to identify and assure completion of commitments made to the NRC. See related Item B.4 above for details, b. An "NRC Action Item Commitment List" was transmitted to appro-priate management personnel for action / followup on January 15, 1981. c. A management meeting was held and documented on January 13, 1981, at which the importance of meeting commitments to NRC was stressed to all South Texas Project management by Brown and Root executive management. Brown and Root completed the co'rective action during inspection 81-01. r 6. (Closed) Nanconformance (Report 81-01, Item B). Unapproved Technical Reference Documents were contained in the South Texas Project Design Manual. The inspector verified the corrective action and preventive measures described in Brown and Root letters dated February 16, 1981, and March 18, 1981. Specifically: a. All STP Design Manuals were reviewed and brought into conformance with the procedural requirements for the cor. tent and control thereof. b. Procedure STP-DC-007 was cancelled in its entirety on April 17, 1981, and was replaced by three new procedures issued on the same day. STP-50-001-B (STP Design Manual), STP-SD-002-B (System Design Description), and STP-SD-003-B (Technical Reference Documents) collectively contain the germane requirements of STP-0C-007 and all committed changes thereto. c. Nine additional STP procedures have been revised to date. d. Training on the new and revised procedures was completed or l committed. 7. (Closed) Nonconformance (Report 81-01, Item C). The Engineering I Document Control Center did not publish a document status list as required. l l 1 l l ...-.,n,, __--....w
a -.-- __.a~....~ ~......... ~. - - 7 ~ The inspector verified the corrective action and preventive measures described in Brown and Root letters dated February 16, 1981, and March 18, 1981. Specifically: a. A current document status list was issued as committed. The list consisted of two separate issues, one of which (Brown and Root Document Status List) identified the current states of Brown and' Root generated design documents. The second list, (Vendor Document Status List) identified the current status of vendor design documents received by Brown and Root. b. A new organization was formed on February 16, 1981, the EDC (Engineering Document Control), and assigned the responsibility for control and bi-monthly issue of both document status lists. c. Procedure STP-DC-028-B was revised to reflect the new Engineer-ing Document Control organization. d. The design document control system was' revised and upgraded to provide additional control over the generation, revision, verification, issue, and distribution of design documents. e. All affected STP procedures are to be revised to reflect the new crganization and document control system by May 1, 1981. C. Desian Process Management 1. Objectives The objectives of this area of inspection were to examine the estab-lishment and implementation of quality related procedures for the design process to verify that; The design process system is defined, implemented, and enforced a. i in accordance with approved procedures, instructions, or other documentation for all groups performing safety related design activities. l b. Design inputs are properly prescribed and used for translation into specifications, drawings, instructions, or procedures. Appropriate quality standards for items important to safety c. are identified, documented, and their selection reviewed and approved. 1 l l ~h_ sK D-p- 9 StFegg W *
.. x.-. -. - -..... -. - _ ~ _ ~ 237 8 d. Final design can be related to the design input with this traceability documented, including the steps performed from design input to final design. Design activities are documented in sufficient detail to permit e. design verification and auditing. f. The methods are prescribed for preparing design analyses, draw-ings, specifications, and other design documents so they are planned, controlled, and correctly performed. 2. Methods of Accomplishment 'The preceding objectives were. accomplished by: a. Review of the following documents to determine if procedures have been prepared, approved, and issued to prescribe a con-trolled system for the management of the design process that is consistent with commitments to NRC and objectives a. through f. above. (1) Sections 17.2, 17.3, 17.5, and 17.6 of the NRC accepted Brown and Root (B&R) Topical Report, B&R-002A Revision 3, and amendements thereto, to determine the B&R corporate commitments relative to managment of the design process. (2) Sections 2, 3, 5, and 6 of the B&R South Texas Project. (STP) QA Manual, to determine if the B&R corporate commitments relative to managment of the design process were correctly translated into quality assurance policies and procedures that provide control over activities affecting the quality of design within the B&R scope of supply. (3) Thirteen STP applicable design control procedures that are contained in the STP Engineering Procedures Manual, to verify that procedures have been established to l implement the committed quality assurance program and l to prescribe design activities that are within the B&R scope of supply. b. Review of Section 3.8 of the P!AR, Sections 3.6, 3.11, 6.1, l and 6.2 of the FSAR, and Section 3/4.6 of the Technical Spec-ifications for the South Texas Project, to determine the i regulatory requirements, safety classification, technical requirements, specific design inputs, and quality assurance il requirements of the three containment air locks and other containment penetrations. _m _,.-...m._~~ .,..,,....,,, y
ym n.=.. ... a n . - ~, 238 g c. Revie'w of the design specifications 1C15-501 and 2C26955006 (both titled " Steel Liner Work for Reactor Containment Structures"), subcontract procurement files (35-1197-0011 with the Pittsburg - DeMoine's Steel Company), three B&R and 33 Woolley drawings, and the Executive Design Review of the South Texas Project Personnel Air Lock, to determine if sources of design input, such as PSAR/FSAR commitments and regulatory / quality requirements, were correctly and traceably translated into verified final design documents ~ and the ultimately procured personnel air lock. d. The following additional documents were reviewed to determine if the. quality assurance program for the management of the design process was being effectively implemented for the current B&R activities affecting the quality of the design within the B&R scope of supply: (1) Calculations (four), (2) Design verifications (five), (3) Drawings (twenty-two), (4) Personnel training ' records (four), (5) Safety concerns (seventy-seven), (6) Specifications (five), (7) System Design Descriptions (eleven), and (8) Technical Reference Documents (eleven), 3. Findings a. Nonconformances Three nonconformances were identified in this area of the inspec-tion. See Notice of Nonconformance enclosure, Items B., C., and D. (1) With respect to nonconformance B. The following nonexclusive list of differ _ences between the in place QA Program and the program described in the Brown and Root Topical Report B&R-002A (Revision 3, September 1977, including amendments dated October 17, 1978, and March 24, 1980) were identified by the inspector: i - - -,. ~.,, - ,.- - w sr.- 3 mwemw:w m rt%w~ r
r m __., _. _ 239 10 Some organizational structures and titles are different from those described in the Topical Report. The QA Manager does not report to the Power Division Group Vice President. The position of " Assistant Quality Assurance Manager" - has been added to the QA organization. The actual in place QA and Engineering organizations, interfaces, and functions are not as described in the Topical Report. The revisions of the Regul'atory Guides endorsed by the in place QA Program are differerit from those identified in the Topical Report. Review and approval of procurement documents by Engineering, Quality Assurance, and Purchasing is not. as described in the Topical Report. The responsibility for, and execution of, the QA Audit and Vendor Surveillance activities are not as described in the Topical Report. (2) With respect to the inflatable,eal personnel air lock: (a) Section 3.8.1.1.6 of the South Texas Project PSAR states in part that: "... Access into the Containment Building is provided by an equipment hatch, a personnel airlock and an auxiliary airlock. The personnel airlock is an approxi-mately 10-feet diameter welded steel assembly with double doors. The auxiliary airlock is a 5-1/2 feet diameter welded steel assembly with double doors. Each door is hinged and furnished with double 0-ring gaskets, l with leakage test taps between the gaskets...." (b) Subsequently, the design evolved to use inflatable seals, rather than compression seals, reportedly to facilitate access for heavy equipment. Section 3.8.2.1.2 of the South Texas Project FSAR states in part that "The personnel and auxiliary air locks are ( double, inflatable seal airlocks with pressure bar-I riers..." I i "~ . z -- - --
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240 ~~ ~ ~ 11 The appropriateness of the inflatable seal design was independently questioned by a B&R reviewer and NRC inspectors. Specifically, the ability to assurs long-term sealing without naving access to the inner sedis for maintenance, and the dependence upon active non-fail-safe systems to maintain seal tightness and thus containment integrity, were questioned. - A subsequent independent " Executive (Design) Review" was conducted by a consulting organization for Brown and Root. The review concluded that ". the inflat-able seal concept planned for STP should provide adequate safety. Details of the STP personnel air lock systems need further review and analysis door sealing,herein to insure ac,ceptable performance as describe'd under accident conditions..." The Brown and Root Senior Vice President of Engineer-ing stated that the design of the personnel and auxiliary air locks would be reevaluated within the next month and a decision made to either conduct the failure mode and effects analyses and qualifica- ' tion program re:)mmended by the independent reviewers or to re-engineer the doors to deploy compressive 0 ring seals. b. Unresolved and Follow Up Items None were identified. D. Technical Personnel Background Verification 1. Objectives To verify that measures have been established and are being effectively implemented that assure: a. The education and work experience information contained in employees' job applications are being verified by the employing organization, b. There is objective, documented ev'idence or records that attest to the employees' education and experience. 2. Method of Accomplishment The preceeding objectives were accomplished by an examination of: a. Brown and Root Procedure DL-035, Revision 0 dated May 21, 1980', (Procedure for Verification of Education and Experience).
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m -._ a _.- 2g 12 b. Personnel department record files for the following individuals: (1) Six individuals who were extended an offer of employment, but have not yet reported for work. (2) Eight employees who started to work during the first quarter of 1981. (3) Three employees who started to work prior to 1981. 3. Findings One nonconformance was identified in this area of the inspection. (See Notice of Nonconformance enclosure, Item E). The Personnel Manager stated that procedure DL'-035 would be revised by June 10, 1981, to include specific requirements for verification and documentation of the alleged education and experience of newly hired or transferred employees who are engaged in nuclear safety related activities. Subsequently, the personnel files of all such employees will be reviewed and retrofitted by June 30, 1981. Specific actions will be taken on a case-by-case basis for those individuals whose alleged education or experience can not be verified or was falsified. E. Exit Meeting An exit meeting was conducted with Brown and Root management personnel at the conclusion of the inspection on January 8, 1981. In addition to those individuals indicated by an asterisk in paragraph A. of this report, the meeting was attended by: J. R. Ayres, Manager, Materials K. M. Broom, Jenior Vice President S. M. Dew, Assistant Engineering Project Manager T. L. Porfilio, Discipline Quality Engineer W. M. Rice, Group Vice President, Power Group E. A. Saltarelli, Senior Vice President The inspector discussed the scope of the inspection and the details of the findings identified during the inspection, including the processing of identified safety concerns. Management comments were generally for information only or for acknowledgement of the statements of the inspector with respect to the nonconformances presented. ._-..wm**"***""7 - - ~ "T***'
.c m__. gn aggy UNITED STATES [9 NUCLEAR REGULATORY COMMISSION 242 d o
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,c, o ,,a CFFICE OF THE SECRETARY CERTIFICATION I hereby certify that the attached 22 pages contain a true copy of the letter dated Aug. 19, 1981 from K.V. Seyfrit to Brown & Root, Inc. regarcing tne LLVIV 'i n s p ec t i o n D.F. Fox on July 20 - 24, 1961, together with s,,.. t6at letter's attachments on file with the United States Nuclear Regulatory Commission's Public Document Room, 1717 "H" Street, N. W., Washington, D.C. hjuc l0 (Q' & . Life. N. AUJK g 'Date Official Custooian of tne Records of the Public Document Room ~ Office of the Secretary of the Commission e 9 i (SEAL) Wi '3. a O
wm.w_.. ~n a - ~ w v E AUG 191981 Docket No. 99900502/81-03 ?.6 ,P S/ T ? s ~ / "&!.c- '-I !. - Go, p Brown & Root, Incorporated ew AT O. 7.."W. M. Rice C GCI 5 5 4 @-! Group Vice President, Power Group g ,,,,,. m. m m. f/ 410G Clinton Drive g s cc. Houston TX 77001 Gentlemen: I /i 1 This refers to the inspection conducted by Mr. D. F. Fox of this office on July 20-24, 1981, of your facilities at Houston, Texas, and to the discussions of our findings with Dr. K. M. Broom and members of your staff at the con-clusion of the inspection. Areas examined during this inspection and our findings are discussed in the enclosed report. Within these areas, the inspection consisted of an examination" of procedure 3 and representative records, interviews with personnel, and obser-vations by the inspector. During this inspection it was found that you failed to meet certain comitments to the NRC. The specific findings and references to the pertinent requirements are identified in the enclosures to this letter. This is the fourth inspection in which the corrective actions or preventive measures for a total of seven previous inspection findings were not cc ;le:ac as committed. Reference Item A of the Notice of Deviation enclosures of Reports 99900502/80-01, 99900502/80-02, and 99900502/81-01. Repeatedly in your response to these previous findings and during a meeting with you and members of your staff in our Region IV offices, you have comitted to imple-ment effective corrective and preventive measures, but this problem still i persists. This suggests a.more serious breakdown in the effective implemen-l tation and control of your Quality Assurance Program.' Consequently, provide I us within 30 days from the date of this letter a written statement containing, (1) a description of steps that have been or will be taken to assure that Brown and Root commitments to NRC will be performed as stated and be effectively implemented; (2) a description of steps that havetoeen or will be taken to prevent future recurrence of this item, and (3) the dates your corrective actions and preventive =*a ures were, or will be, completed. You are requested to take action promptly concerning this matter. The responses directed by this letter are not sub, ject to the clearance pro- \\ cedures of the Office of Management and Budget as required by the Papenvork Reduction Act of 1980, PL 96-511. l 4110eoG3e1 :::=:: - Ca PDR CM99 EECBRRT f A 99900502 PDR 00 ,,,,,0-RIV "Q.,.,b,I,E -.iado.. ... ATC.o..i ns.. ... XV.5 ef.r1.t.. -a >! ,,,,,RS ,,,U. P>'..yP,U/ f ..CaiaN...... . U.Po. a p.oy... .0 fax / i **> 8./.13. /. 81......... 8. /3..../.8.1.......... 8/./j../. 81....... .. 8 /. /../.81......8//./. 81... ... 8//7../.81 9ee. ..e e ,e as 9%Ow.w. O., . Q .%.* f% $*% 9'% 9'% $* f'% O % S e
{. . Brown and Root, Inc. 2 In accordance with 10 CFR 2.790 of the Comission's regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any infonnation that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone within 10 days from the date of this letter of ycur intention to file a request for withholding; and (b) sub-r,it within 25 days from the date of this letter a 4ritten application to this office to withhold such infomation. If your re 't of this letter has been delayed such that less than seven days are avails le for your review, please notify this office promptly so that a new due date may be established. Consistent with Section 2.790(b)(1), any such application must be accompanied by an affidavit executed by the owner of the infomation which identifies the docunent or part sought to be withheld, and which contains a full statement of the reasons on the basis which it is claimed that the' infonnation should be withheld from public disclosure. This section further requires the statement to address with specificity the considerations listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit. If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, Karl V. Seyfrit Director
Enclosures:
1. Notice of Nonconfonnance 2. Inspection Report No. 99900502/81-03 bcc: IE/V&SPB (Reinmuth) l IE Files AE00 NMSS NRC:POR r QAB l Reg. Directors, I, II, III, V JEGagliardo, RIV l ...................e '""*"') can > I ..,.pgy ymgggypyp.1,yyn-- - q _ - - - _. _ _....,......___..,,.,a-m-_ _ - _ _ _ _ _ _ _ _ _ _ _ _
n--. 245 Brown and Root, Inc. Docket No. 99900502/81-03 NOTICE OF NONCONc0RMANCE Based on the results of an NRC inspection conducted July 20-24,1981, it appears that certain of your activities were not conducted in accordance with NRC requirements: I Brown and Root letter of response, dated June 12, 1980, to nonconfomance D of NRC inspection report 99900502/81-02 states in part that, "The procurement specification (S-006) for the air lack has been modified and the Technical Reference Document (TRD 5N119NQ013, Revision B) has been revised for quali-8 fying the air lock seal material to withstand a beta radiation of 3.3 x 10 Rad. This corrective action is complete. Vendor response to the material requisition for the seal materials has been requested by July 1,1981." I Contrary to the above, the vendor response to the material requisition was not requested by July 1, 1981. Furthermore, the material requisition was not completed anc transmitted to the vendor by conclusion of this inspec-tion, since the procurement specificaticn and Technical Reference Document were not issued until July 22, 1981 and June 22, 1981, respectively. 99900502 - - ~ _ _~ .-- y________yrg : ~ s__
...~..-----. M. w..a : m.e=sa m ~- ORGANIZATION: BROWN AND F , INC., POWER GROUP ~ 246 HOUSTON, T REPORT NO.: 99900502/81-03 INSPECTION DATEIS): 7/20-24/81 INSPECTION ON-S.'TE HOURS: 76 CORRESPONDENCE ADDRESS: Brown and Root, Incorporated ATTN: Mr. W. M. Rice, Group Vice President Power Group 4100 Clinton Drive Houston, TX 77001 ORGANIZATION CONTACT: Mr. R. J. Vurpillat, QA Manager TELEPHONE: (713) 678-5226 PRINCIPAL PRODUCT: Architect Engineering Services NUCLEAR INDUSTRY ACTIVITY: The total effort comitted to domestic nuclear dIsign activities at the Houston facilities is approximately 11% of the 10,200 permanent and contract employee staff of the Power Group. The major project design is South Texas Project Units 1 and 2. ASSIGNED INSPECTOR: p% E / J 2. / f l D. F. Ecx, Reactor Systems Section (RSS) Date OTHER INSPECTOR (SI: D. D. Chamberlain, RSS k APPROVED BY: w C.J.HaJ1 Chief, RSS Date INSPECTION BASES AND SCOPE: A. BASES: 10 CFR Part 50, Appendix B and the SAR for the South Texas Project Units 1 and 2. B. SCOPE: Design inspection, design verification, design change control, design corrective action and status of previous inspection findings. DEsIon:D ORIGIRL Certified B7 LSAAA3 V
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b,i/ ,3GANIZAT10N: BROWN AND 7T, INC., POWER GROUP HOUSTON,.. S EPORT NO.: 99900502/81-03 INSPECTION RESULTS: PAGE 2 of 6 I VIOLATIONS: None L NONCONFORMANCES: Contrary to comitments contained in the Brown and Root, Inc. letter of response, dated June 12, 1981, to NRC Inspection Report 99900502/81-02, corrective action for a previously identified nonconformance had not been completed as stated. This is the fourth inspection in which correc-tive actions or preventive measures were not completed as comitted. L UNRESOLVED ITEMS: None s L. STATUS OF PREVIOUS INSPECTION FINDINGS: 1. (Closed) Follow up Item.(80-02): The status of the Brown and Root (B&R), i Vendor Control Evaluation anf Correction Program will be evaluated. The NRC inspector reviewed the status of the task force established by B&R to review all procurement documents for safety-related equipment and material to assure that all B&R and Houston Lighting and Power (HL&P) ccmmitments to NRC are met prior to release of the items to the South Texas Project (STP) site. B&R management stated that: (1) all purchase orders will be reviewed and updated by November 30,1981;(2) all affected items will be brought into full compliance and released by December 31, 1981; the shift in the role of NUS in the program from that of an independent auditor of the updated procurement documents to that of determining the extent that the vendor's existing programs and activities met the requirements contained in the updated procurement documents, will be identified to HL&P by August 14, 1981; and (3) Technical Referece Document N.o. 7A700GP007, will be issued by August 14, 1981, to define and control all aspects of the Vendor Control and Evaluation Program. Implementation will be retrofitted to include the identifica-tion and upgrading, as necessary, of those safety-related items pre-viously released'to the site for construction or installation. This area will be examined further during subsequent inspections. 2. (Closed) Violation (81-02): Failure to submit a written report of a significant defect in piping supports within the time required by 10 CFR Part 21. N**@""T,* ,7 g -
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1 be eO .. OP.GANIZATION: ' BROWN AND T, INC., POWER GROUP l HOUSTON, if.AAS REPORT NO.: 99900502/81-03 INSPECTION RESULTS: PAGE 3 of 6 B&R management stated that the delay in submitting the report to NRC resulted from their understanding of the 10 CFR Part 21 reporting requirements at that time. The B&R 10 CFR Part 21 implementing procedure (STP-PGM-022) was revised on July 1, 1981, to require verbal notification to NRC within two calendar days and written notification within five calendar days following the determination of reportability. 3. (Closed) Nonconformance (81-02): Failure to adhere to the recuire-ments in the B&R 10 CFR Part 21 implementing procedure. The B&R Incident Review Comittee reviewed all previously identified safety concerns to deter nine their reportability and the minimum supplemental documentation needed to document B&R's decision on each safety concern. T.hree safety concerns were determined report-able pursuant to 10 CFR Part 21 and the requisite notification made to NRC. Procedure STP-pGM-022 was revised on July 1, 1981, to specifically define the identification, evaluation, reporting, and documentation requirements for safety concerns identified subsequent to July 1,1981. 4. (Closed) Nonconfomance (81-02): Failure to submit to NRC changes in the QA program and organization described in the B&R Topical Report. B&R management stated that th Topical Report.has not been revised because the only current nuclear design activity, the South Texas Project (STP), is not committed to that QA program. B&R plans to revise the topical and detemine the optimum date for submission to NRC by December 31, 1981. 5. (Closed) Nonconfomance (81-02): Failure to include beta radiation resistance requirements in the specification for personnel air lock inflatable seal material. The subject specification was revised and issued on July 22, 1981; how-ever B&R did not complete the corrective action described in their June 12, 1981 letter of response to this nonconfomance prior to the conclusion of this inspection. (See B. above.) 6. (Closed) Nonconfomance (81-02): Failure to maintain required train-ing records. The training files were reviewed and the required training and docu-mentat:on was completed for all affected STP individuals. Procedure STP-Pl-006-E was revised on July 20, 1981, to includo specific require-ments for the control, maintenance, and storage of training records. i . _ = - _ _ rm w -m -r e--.- -S1
ORGANIZATION: BROWN AND ~ 'T, INC., POWER GROUP 249
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.5 REPORT NO.: 99900502/81-03 INSPECTION RESULTS: PAGE4 of 6 Additional B&R personnel were assigned to the training and record retention functions and affected STP supervisors were given training on implementing.the requirements of the revised procedure. 7. (Closed) Nonconfonnance (81-02): Failure to follow procedure for authenticating copies of educational diplomas or transcripts of new employees. The STP corporate personnel files were reviewed and the required authentication or. verification was completed for all STP individuals. Procedure DL 035 was revised on June 9,1981, to include specific requirements for verification and documentation of the education and experience of newly hired or transferred employees assigned to the STP. E. OTHER FINDINGS OR COMMENTS a 1. Design Insoection The related sections of the STP PSAR and FSAR and applicable imple-menting procedures were examined to determine the commitments con-cerning safety-related design activities. One system design descrip-tion, two specifications, two Technical Reference Occuments, the plant physical model, eleven drawings, seven calculations, two design activity logs and reports, two safety concerns, two purchase orders, thirteen records of design verification, three hold tags, and other documentation relating to the containment structure, mechanical equipment auxiliary building and fuel handling build-ing HVAC, and the auxiliary feedwater systems were examined to verify effective implementation. Within the scope of the inspection, the committed program was being implemented. However, the following items were noted. Approximately 2600 physical interferences, encroachments on equip-a. ment access or personnel passageways, were uncovered during the construction of the plant physical model and resulted in numerous documents being issued to identify changes that are needed in the related engineering drawings. Based on information from B&R personnel approximately 3500 of the 33,300 drawings issued to date have a total of 5,000 " holds" or " hold areas" associated with them. Certain of these drawings have been used by vendors to fabricate piping spool pieces that were subsequently shipped to the site prior to clearing of the " holds." The current status of these items could not be determined by examination of available B&R engineering records. B&R management stated that they would develop and imple-ment a system to identify, track, and' assure clearing of design " holds" on an item prior to the design requirements freeze date e es -o-en e mme.- we e = . se see we -*s*va -ewMe" ""#'F ' *""',IP- ~ "" "* ' 7 Y" * * *T ~~
SGANIZATIONi BROWN AND ' INC., POWER GROUP 250 '. ~. HOUSTON, % 3 i WORT NO.: 99900502/81-03 INSPECTION RESULTS: PAGE 5 of 6 for the item. Furthennore, the need for, and methodology of, providing positive assurance against the inadvertent installation of such items will be evaluated. b. An August 25, 1980 reanalysis of the pressure and temperature transient of the contairment after a postulated LOCA indicates that the original L (May 18, 1978) analysis used to generate the data for the STP.FSAR 0 j was conservative by 3 psi in peak pressure, 2.4 F in peak vapor tempera-ture and 0.20F in peak sump temperature. The inspector noted that 1 certain of the input parameters used in the reanalysis were different from those reported in the FSAR. These and other inconsistencies in the FSAR were discussed with B&R management who stated that the FSAR { would be reviewed and needed changes would be identified to HL&P on a timely basis and affected design documents would be revised accordingly. k Auxiliary feed water pumps, purchased from the Bingham-Williamette [ c. l { Company under P0s 35-1197-4053 and 35-1197-8053, were deliverd to ~ the STP site with motor operators for the turbine trip and throttle r ! kj valves that were not qualified to IEEE-323 and IEEE-344 as required h by procurement specification STP-35149M50430 dated March 31, 1977. 1 ( The B&R Incident Review Comittee (IRC) deemed this safety concern J (No. 40) to be reportable pursuant to 10 CFR Part 21 and on April 10, l( 1980, notified the NRC. Review of B&R's engineering and procurement h files did not reveal any indication that the requirement for qualified y operators was waived. B&R management stated that the supplier of the j ( turbine (Terry Corp.) had replaced the operators on one.of the delivered turbines with qualified operators and reportedly is in the process of ( replacing the others. ? ( d. B&R engineering stated that the heating and ventilating (HVAC) systems for the STP mechanical equipment auxiliary building (MEAB) and the fuel h<( l handling building (FHS) appeared to provide insufficient cooling during certain modes of plant operation or postulated plant events. The B&R l d IRC deemed this safety concern (No. 96) to be reportable pursuant to l M 10 CFR Part 21 and on May 8, 1981, notified the NRC. B&R management j stated that the reasons for the cooling capacity of the systems, as designed, not meeting current heat removal requirements were that: (1) [ j the capacity requirements were calculated in the mid 1970s from the heat loads identified at that time and were not revised nor updated since then; (2) certain heat loads were inadvertantly omitted from the analysis; and (3) additienal capacity is needed to accomodate the new equipment l and additional heat loads now required in the MEAB and FHB. B&R management stated that the calculation of the required HVAC capacity will be updated i by October 13, 1981 and will be revise ta include the effect of pipe e ruptures by June 1982. B&R anticipates that the procurement documents for the new HVAC systams, which will be used to supplement the existing I [ HVAC systems, will be issued by July 1982. ( I t j., L ..,. N 'j9'*E T N W #@* 7'T E f' V " 1" se
ORGANIZATION: BROWN ANC T, INC., POWER GROUP HOUSTON, - AS REPORT NO.: 99900502/81-03 INSPECTION RESULTS: PAGE 6 of 6 2. Design Verification The related sections of the STP PSAR and FSAR and applicable imple-menting procedures were examined to determine if procedures are consistent with commitments to NRC. The qualifications of the design verifiers and the detailed documentation of the design verification of two specifications, one computer code, three calculations, and five drawings relating to the containment structure and its post LOCA pressure a'nd temperature transient analysis were examined to determine if the committed program-was being effectively implemented. Within the scope of this inspection, the committed program was being implemented. 3. Design Change Control a The Brown and Root Quality Assurance Manual and the applicable engineer-ing procedures were examined to determine the quality assurance program commitments. The following documents were examined to verify imple-mentation of the commitments; Design Change Tracking System (computer printout), 31 Design Change Notices, 14 revised drawings, and six revised calculations. Relative to the documents examined, the quality assurance program commitments were being implemented. 4. Design Corrective Action The Brown and Root Quality Assurance Manual and the applicable pro-cedures were examined to determine the quality assurance program commi tments. Twelve identified Engineering Design Deficiencies were examined to verify implementation of the commitments. Within the scope of this area of the inspection, the Quality Assurance pro-gram commitments were being implemented. However, it was not apparent that the present program adequately addresses recurring design errors for needed design corrective action. This area will be examined further during a future inspection. _ _ ~~ w-v m e ~ n w ' ~ r r v- m
J.__ 252 co.s PANY: R sp., L Roo7 S.L--6 _.. DOCKET NO.,227,g_p,fg2 cire: 7/2 Y/ F/ i irre.63pection centerence Post, Espection conference. (Please WME mease Print) TITLE (Please Print) ., ORGANIZATION P Lnt) Y. E.Y. E I Ai r a,f M T Ah,CEtTHA_ D, D. CMrtiB6RLAlt4 C6NTRAcnR In$frr tor .U5dRC % G. H R M. M b>w;t L Pwste r &_A H t. t' /* n a. nee ks ser zis < s._Myx ~~d 4 R. K R ('u L 1 ',- :. -8.. m.v. n il D. A 2 A.jictk 5%;.<- De. En. 8i/ 4a-sQ L. Cho.mhers s,v' A ~.,.) C k is +R D. Q. wk,;,x L icem n crrn. --RW E. E Abran's %v Gua/, i& g. diL t d f SJzpf*n.l / 2'6.x D r M am-6A%t EhE d. C. 6Hu c.K.ECW Tc51&J OLAuTt G+d6C. G> E. R. 6.~E. NGLkY STP TRdG SuPGNLW Wk . DnLL STP V6 i cett:.t, B4R bEAf S/'. I 'li e' / ;* c f) f NI.du~ur OMc Et, E dTF2wIlan VOEsk % 4, M TU b5fMN A 53I T*p AFF)H bW l l '*FT'F* P **Tu """* " I'T w-l*** Ff*1" *"*utf 7D'y D K "**" y * * * *-' *" ~ '- " ' ' .y - - 7, m.;-, p 5.g, -eng, ,r 3-
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. _ = V_ m _. 6* EE%q' g/ UNITED 5TATES {} '( 8 y,.,.;,o, 'r, NUCLEAR REGULATORY COMMISSION E REGION IV y-f s11 RYAN PLAZA oRIVE, SUITE 1000 o
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AR uNGTON. TEXAS Mo12 September 17, 1979 Mr. Billy C. Neill, Director Motor Equipment Services Division Roon 6A22, Federal Office Building 819 Taylor Street Fort Worth, Texas 76102
SUBJECT:
REQUEST FOR VEEICLE FOR SOL'IH TEXAS PROJECT (STP) RESIDENT INSPECTOR
Dear Mr. Neill:
Mr. Leo L. Floyd of my staff recently contacted you in reference to the subject request. During this.talephone conversation, you stated that the first step in obtaining a vehicle is to subnit a letter to your office describing the type of vehicle needed and how the vehicle will be used. The Nuclear Regulatory Co ission (NRC) recently decided to assign Resident Inspectors to nuclear reactor construction sites. Mr. H. S. Phillips, NRC Rasident Inspector, was assigned to South Texas on August 27, 1979. As a result of this assignmant,~he vil'1 need either a four door station wagon or sedan to perform his inspection duties. The following outlines the justifi-cation and typical mileage: Justification Use of a govern =ent vehicle will increase the Federal Inspector's visibility on site. This site has had congressional and public attention for sometima, therefore, denenstration of government attention is very i=portant. Access to the site will be easier since STP security would more readily allow an official goverre.mt vehicle on site than a private vehicle. The inspector must travel around the STP site, which covers 12,220 acres, to perform required inspections. Obviously, the inspector must have a vehicle in order to cover such a large area and to perform inspections in a nsnner which would be efficient and cost effective. .. l M y/ f 4 - *. n o DEPOSITIOPh j, ( ) . EXHIBIT. s f @8 B.9
p. J/ s E Mr. Billy G. Neill September'17, 1979 The inspector must travel to and from the Post Office each day to pick up the mail. The inspector must perform backshift inspections at any hour of the day. Again access would be easier. The inspector will have to gain access to the site during strikes, natural disasters and unusual occurrences such as demonstrations, bomb threats, civil strife, etc. An official vehicle would afford instant access and would afford protection from acts of violence and/or vandalism. The inspector may be required to respond to emergency situations involving the transportation of nuclear materials in the southern part of Texas. The vehicle'will also be used by other NRC inspectors at the site who routinely travel from Dallas to the South Texas Project to perform inspections. The vehicle will be used for official use only; it will not be used by the Resident Inspector for the purpose of commuting between his residence and the site.. Typical Milease Performing Site Inspections 188.0 miles /mo. (regular and offshift) ) Daily Mail Pickup 946.0 milas/mo. i (site to Bay City - RT 44 mi.) l Trip to Dallas-Esadquarters 350.0 miles /mo. j (bi-monthly) 1 other Miscellaneous Trips 100.0 miles,/mo. I 4 l Total 1584.0 miles /mo. ^ j I would appreciate anything you can do to expedite this matter since the inspector needs the vehicle as of September 3,1979. Please contact this I office at telephone number 334-2411, if you have further questions regarding I this matter. I Sincere I kA>(i ~ d l K. V. Seyfrit Director l l i --_--_m -4,.. .}}