ML20211F458
| ML20211F458 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/02/1975 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Oprea G HOUSTON LIGHTING & POWER CO. |
| Shared Package | |
| ML20150F241 | List:
|
| References | |
| FOIA-85-378 NUDOCS 8610310165 | |
| Download: ML20211F458 (15) | |
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UNITED STATES
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Office of Inspection & Enforcement
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Region IV
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d 611 Ryan Plaza Drive, Suite 1000 3-Arlington, Texas 76012 e, //
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1 April 2, 1975 ST-AE-HL-514 SFN: C-0570 Houston Lighting and Power Company Docket Nos. 50-498 and ATTN:
G. W. Oprea, Jr.
50-499 Executive Vice President P. O. Box 1700 gY g y gg f
Houston, Texas 77001 4
Gentlemen:
This refers to the inspection conducted by Messrs. M. W. Dickerson, W. A.
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,Crossman, W. G. Hubacek and R. C. Stewart of this office on March 1 -
1975, of the implementation of your quality assurance program for construc-tion activities related to your application for a construction permit for
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the South Texas Project, Units 1 and 2, and to the discussion of our find'ings held by the inspectors with you and members of your staff at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the Within these areas, the inspectfon consisted enclosed inspection report.
of selective examination of procedures and representative records, inter-views with personnel, and observations by the inspectors.
During the inspection, it was found that your quality assurance program was deficient in that certain activities appeared not to meet the requirements of Appendix E to 10 CFR 50 of the NRC Regulations, ' Quality Assurance Criteria for Nuclear Power Plants.' The items and references to the pertinent require-ments are identified in Section I of the summary of the enclosed report.
Please provide ut, within 30 days, in writing, with your comments concerning these items, a description of any steps that have been or will be taken to correct them, a description of any steps that have been or will be taken to prevent recurrence, and the date all corrective actions or preventive measures will be completed.
We have also examined actions you have daken with regard to previously identi-
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The status of these items is identified in Section IV fied unresolved ite=s.
of the sum =ary of the en, closed report.
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l' 198 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 If this inspection report will be placed in the NRC's Public Document Room.
report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from The application must include a full statement of the rea-public disclosure.
The application sons why it is claimed that the informatien is proprietary.
should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure If we do not hear from you in will also be placed in the Public Document Room.
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 glad to discuss them with you.
Sincerely, W
G. L. Madsen, Chief Reactor Construction and Operations Branch
Enclosure:
IE Inspection Report No. 50-498/75-02 50-499/75-02 I
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193 SL70'JUUY OF FINDINGS I.
Enforcement Action A.
Items of Nonconpliance None B.
Deviations 75-02/B-1 QA Program Procedures Although the existing procedures contained in the Brown and Root, (B&R) Quality Assurance / Quality Control Manual are all Inc.
The manual, program =atic and not quality control as indicated.
(Details II, as a Quality Assurance Manual, is incocplete.
A, paragraph 3.b(1))
i 75-02/B-2 Quality Control Procedures The procedures contained in the B&R QA/QC Manual, as presently Based written, are not applicable to quality control activities.
on guidelines by which the procedures appear to have been developed, the cocpleted manual vill depict only QA effort and consequently, a projected schedule for development of quality control procedures (Details II, paragraph 3.b(1) & 3.b(4))
r is not available.
i 75-02/B-3 Field Initiated Design Activity The procedure describing engineering quality assurance (ST QCP-6) i does not contain provisiens for control of field initiated design
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change activities.
(Details II, paragraph 3.b(5))
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75-02/B-4 QA Organization-Construction e
The procedure describing the B&R Construction QA organization does s,.
not clearly delineate the authority and duties of persons performing (Details II, paragraph 3.b(3) /Lt P
quality assurance functions.
3.b(4))
Licensee Action on Previously Identified Enforcement liatters II.
ai None Ill. New Unresolved Itees i
None 4
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Status of Previously Repnrtad Unrzaolved Iter 2
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74-1/2 Desien Change Procedures - Licensing Review Brown & Root (B&R) procedures STP-DC-012 "SAR Change Control, and STP-DC-013 "Docunent Change Notice Control" have now been issued and approved for use.
This matter is considered closed.
(Details I, paragraph 2.a) 74-2/3 Engineering Procedures HL&P engineering procedures now appear to be in conformance with the revised PQAP issued on 3/1/75 for the South Texas Project. This natter is considered closed.
(Details I, paragraph 2.b)
V.
Design Changes None VI.
Unusual Occurrences None VII. Other Significant Findings 1.
The primary purpose of this inspection was to review the applicant's and Brown & Root's Quality Assurance Program for construction and to review corrective action relative to previously identified open itecs.
s 2.
Houston Lighting & Power Company reported that as of February 28, 1975, design and engineering was approximately 37% complete and pro-curement was 5% complete.
No significant changes in major procure-ment activities have occurred since the previous inspection.
3.
No significant change has occurred relative to the HLAP plans for their site quality assurance organization from that repbrted in the previous report.
yyyy, Management Intervieu On March 20, 1975, at the conclusion of the inspection, a meeting was held with HL&P manage ent to discuss the results of the inspection. The following individuals were present:
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Htuston Li2hting & Prvar Crmpeny (HLEP)
G. W. Oprea, Jr. - Executive Vice President J. D. Cowart - Vice President R. M. McCuistion - Vice President, Engineering E. A. Turner - General Manager, PPEEC
.A. R. Beavers - General Manager, Purchasing & Stores D. G. Barker - Manager, Quality Assurance Department R. E. Fulghur. - Manager, Projects - PPE&C Brown & Rcot, Inc. (B&R)
G. L. Morris - Senior Vice President, Engineering K. M. Broem - Manager, Power Services The senior reactor inspector described the purpose of the inspection and stated that details of the inspection findings would be documented.
Each inspector attending the management interview presented a brief description of his findings.
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I 202 DETAILS I Prepared By: M. W. Dickerson &
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W. G. Hubacek 1.
Persons Contacted 8-The following individuals, in addition to those listed under the Manage-ment Interview section of this report, were contacted during the inspection:
Houston Lighting & Power Company i
R. A. Frazar, Supervising Engineer, Quality Assurance W. N. Phillips, Supervisor,1 Project Services R. E. Powe, Engineer-Quality Assurance, South Texas Project G. A. Marshall, QA Technician l A,,
2.
Previously Reported Unresolved Items j.
ln Design Change Procedures - Licensing Review (74-1/2)
L a.
Control of design changes which result as a part of the licensing review had previously been stated to be a function of the A/E's ll
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design control activities. This item had remained open pending a review of Brown & Root's design control procedure.
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During this inspection it was established that B&R procedure STP-DC-012, "SAR Change Control" had been approved and 4
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issued for use on 2/17/75. The procedure provides for control of changes which are made to the PSAR. Included is a require-ment for the changes to be reviewed for impact on matters
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outside of licensing activities, including design. The review,
].,' 1 relative to matters outside of licensing, is provided for by BLR l
Procedure STP-DC-013, " Document Change Control Approval",
issued and approved for use on 3/3/75. The latter provides, for
>h general project use, the control of document change notices.
Based on a review of these two documents, this matter is con-4 sidered closed.
,4 b.
Engineering P'rocedures (74-2/3)
During the previc,us inspection it was established that engineering 1
procedures had been developed by HL&P for the South Texas Project. However, this item had remained open pending issuance (continued) i i,
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~U 203 of a revision to the South Texas Project Quality Assurance Plan (PQAP) since continuity of the guidance to the plan, relative to
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engineering procedures, could not be established.
The revised PQAP issued and approved for use on 3/1/75, now defines the interfaces between the policies contained in the Quality Assurance Program Manual and the detailed departmental procedures. This matter is considered closed.
3.
Construction Procedures HL&P Quality Surveillance Procedures for the South Texas Project still remain to be completed. However, the inspector verified from schedules, and completed drafts of procedures, that HL&P appears to be proceed-ing with the preparation of precedures consistent with the dates established for their completion.
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4.
Design and Procurement (Field) a.
Design At present there are no plans for field engineering to be conducted by B&R. However B&R procedure, ST-QCP-6, " Engineering Quality Assurance", dated 2/2f8/.75, states.that if design activities are extended to on-site engineering that such activities will require revision of the procedure and would be controlled in
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accordance with its provisions. HL&P engineering procedures do not differentiate relative to engineering performed in the field or elsewhere but require review by HL&P engineering for key elements of the finished design. The review is accomplished by review of design specification and design documents by the responsible HL&P departments, the Design Review Committee and the Quality Assurance Department.
b.
Procurement Site procurement is delineated by HL&P in Power Plant Purchas-ing Procedure, PP-3, " Site Procurement". The procedure states that the AE has the responsibility for site procurement, the HL&P Purchasing Department has the responsibility for monitoring site procurement for conformance to established policies and procedures and the HL&P Purchasing Department will review the AE's procedures and completed activities for site procurement. In addition, HL&P Quality Surveillance (continued)
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Procedure, QSP-ST-G8, is scheduled for complation 7/1/75.
QSP-ST-G8 will describe the HL&P quality assurance activities relative to field purchases control. In addition, B&R Quality Control Procedure ST-QCP-12, " Field Purchasing", is scheduled for completion 6/2/75. Purchases exceeding $5,000 or those involving QA requirements require the approval of HL&P.
5.
Vendor Surveillance Vendor surveillance for the South Texas Project is delineated in the PQAP and HLkP departmental procedures. HL&P performs audits of Westinghouse and B&R to determine that a quality assurance program for fabrication and procurement has been developed, implemented and documente d.
HL&P participates with Westinghouse and B&R on selected audits and vendor surveillance of equipment suppliers.
Westinghcuse is responsible for vendor surveillance over NSSS items
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B&R and services whether Westinghouse manufactured or purchased.
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is responsible for vendor shop surveillance of procured equipment during the fabrication phase. The B&R Vendor Surveillance Coordinator is responsible for the organization and direction of shop inspectors.
'l' Sequence schedules are obtained from each vendor so that specific HL&P checkpoints for B&R shop inspection visits can be designated.
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and B&R are in the process of developing schedules for vendor audits.
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l The inspector reviewed the following PQAP sections and HL&P depart-f rnental procedures:
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" Purchasing Department"
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PQAP Sections:
- 2. 8 2. 11
" Quality Assurance Department"
[l "Outside Organizations and Interfaces"
- 3. 2 f
- 5. 0
" Procurement"
- 6. 2 "Off-site Fabrication" s-HL&P Departmental M
Proc edur e s:
PP-1
" General Procurement Procedure"
" Procedure for Establishing Bidders, List" PP-2 PP-3
" Site Procurement" PP-4
" Inquiry Issuance" PP-5
" Proposal Evaluation and Supplies Selection" l
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" Procedure for Purchase Order Preparation, PP-6 l.
Changes, Approval and Issuance" (Continued) 4
_ _.. - _ _ _ _, _. _ _., _. _, _. ~ _ _
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" Procedure for Vendor Quality Assurance" QAP-3
" General Quality Assurance Operating Procedure" i
QAP-4
" Procedure for Document Review" QAP-7 QAP-10
" Audit Procedure" The vendor surveillance requirements of the above departmental pro-certures and sections of the PQAP were discussed with cognizant HLLP personnel. Implementation of the requirements appeared to be commensu. ate with the status of the project.
No discrepancies were noted.
Vendor Surveillance Audits and Corrective Actions 6.
The inspector reviewed records of vendor surveillance audits performed The number of audit reports available for review was by HLLP and B&R.
The following S
limited by the early status of the South Texas Project.
audit reports were reviewed:
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5 Preaward Survey of Sunstrand Energy Systems, performed on l
a.
February 18, 1975 by HL&P QA.
3.
Preaward Survey of Olaf Soot Consulting Engineers, performed on b.
February 19, 1975 by HL&P QA.
i.
Vendor Survey of Teledyne Materials Research, performed on c.
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September 18, 1974 by B&R QA and HL&P QA.
9 21-22,1974 by Vendor Survey of EDS Nuclear, performed on August
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d.
B&R QA.
e' Vendor Survey of Nuclear Services Corporation, perfo'rmed on 2 -
e.
August 22-23, 1974 by B&R QA.
Audit WN-1 of Westinghouse Electric Corp. Nuclear Center, f.
PWR Systems Division, Product Assurance Department, performed on October 23, 1973 by HLLP'OA.
29-31, 1975 Audit BR-7 of. Brown & Root, performed on January I
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by HLLP QA.
Audit of HLLP QA Department performed on October 2-3,1974 by h.
the HL&P QA Program Evaluation Committee.
6 (continued)
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Audit WL-2 of Woodward-Clyds Consultants parformsd en February 26, 1974 by HL&P QA.
The audits appear to have been conducted in accordance with approved procedures. HL&P management has taken an active role in the resolution of audit identified discrepancies. Audit activities appear to be commensurate with the status of the project.
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4 207 DETAILS II_
Prepared By: W. A. Cro s sman te R. C. Stewart
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Fersons Contacted
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Houston Lighting & Power Company (HL&P)
_D. G. Barker, Manager, Quality Assurance R. A. Frazar, Supervising Engineer, QA (South Texas)
W. N. Phillips, Project Services, QA F. D. Asbeck, Project Engineer, Construction (Allens Creek)
R. E. Powe, Engineer, QA (South Texas)
Brown & Root, Inc. (BLR)
L. A. Ashley, Manager, Construction
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R. A. Sanford, Chief Project Engineer, Construction
'Z D. L. Kelley, Project Civil Engineer, Construction
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T. P. Gardner, Site Project Manager, QA l3 C. L. Crane, Project Manager, Construction
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9 2.
Scope of Inspection
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The purpose of this phase of the inspection was to examine the implemen-
'h tation of BLR's QA program for construction of the South Texas Project,
,I as the second Pre-Construction Permit /SER QA Inspection effort.
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The scope covered by Details IIincludes QA Manual review and procedure i
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.f, development as they pertain to B&R's construction QA program implemen-L I
tation.
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1 3.
Manual Review
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South Texas Quality Assurance Plan (POAP) a.
BLR responsibilities as Constructor for the South Texas Project, Units 1 and 2, are outlined in the HL&P PQAP, Section 6.0,
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" Fabrication and Construction", Rev. O, 3/1/75.
2:
li Definition o,f quality related activities and areas of primary B&R QA/QC
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responsibility for control of these activities by are contained in Subsection 6. 3, " Construction".
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Examination of HL&P plans which address B&R commitments in the above areas did not reveal any significant departures from NRC requirements.
l 1
. Quality Assurance / Quality Control Procedures Manual b.
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General l
Measures which define implementation of the B&R QA program are outlined in the various QA procedures contained in this manual. In-office review included nine of a total of forty scheduled procedures. Another five were added at the utility's corporate office for a total of fifteen or 27% completed.
l The inspec' tor observed that all procedures in the manual A'
were designated as " Quality Control Procedures" but It was inspection revealed them to be programmatic.
pointed out to the Project QA Manager that if the remainder j
l of the procedures were developed utilizing the same guide-l lines, the completed manual would contain only QA pro-g t
cedures.
l' It was determined also that although Procedure No.
ST-QCP-2 states that the B&R QA program is applicable I
to the design, procurement and construction phases of i
t the South Texas Project, the manual appears to be pre-
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dominately for construction activities.
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In conclusion, it was pointed out that the manual, as a
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QA Program Manual, was not complete and the procedures E'
are incorrectly designated as Quality Control I)rocedures.
In view of this, no schedule for development of QC pro-
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cedures, as they apply to the South Texas Project, is available.
Examination of individual procedures revealed the following:
ST-QCP-2. Project Quality Assurance / Quality Control (2) d' Program I'
The B&R QA program for construction is described in the B&R QA/QC Procedures Manual, Procedure No. ST-QCP-2,
" Project Quality Assurance / Quality Cor. trol Program",
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issue date 2/28/75.
(continued)
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~ 1 209-The description presents an overall plan for B&R's construction OA program and contains the necessary material to depict relationship between the eighteen QA criteria of Appendix B of 10 CFR 50 and the associated QA procedures. The description is endorsed by a state-ment of' policy to provide necessary authority for establish-ment and implementation, however, the description is designated as si Quality Control Procedure.
(3)
ST-QCP-1, Project Organization and Administration Procedure No. ST-QCP-1, " Project Organization and Administration", issue date 2/28/75 was examined in regard to its application to construction QA activities.
The procedure does not adequately define the QA organi-
^-
zation for administration of the B&R QA program. Contrary to Criterion I, which states in part, "The authority and duties of persons and organizations performing quality assurance functions shall be clearly established and delineated in writing. " The procedure depicts functions reporting to the Corporate and Site Project QA Managers and does not specifically relate to per.sonnel as a singular positio~n or a lead individual with a staff to perform the function (s). Consequently, position descriptions which outline authority and duties are not available. In the absence of such information, a determination cannot be
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made as to the independence of personnel concerning verification and acceptance authority.
(4)
ST-QCP-22, Earthwork t
The B&R QC Procedure, ST-QCP-22, " Earthwork", sets forth the QA requirements to be maintained during back-filling activities associated with safety related structures.
l It was observed by the inspector that, although the procedure i
describes the control measures to be established during backfilling activities, the procedure does not include QC Inspection instructions that would provide quantitative or qualitative acceptance criteria for determining that the l
prescribed QA activities have been satisfied. During r
subsequent discussions held with the B&R representatives, the inspector was informed that detailed implementing QC instructions, or procedures, were not availabic (see b(1) above).
(continued)
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(5)
ST-OCP-6, Engineering Quality Assurance Examination of QC Procedure, ST-QCP-6, " Engineering Quality Assurance", issue date 2/2-8/75, did not reveal any reference to measures for control of field initiated l
design control activities. Review of ST-QCP-2, paragraph
- 4. 3, " Design Control" did not contain a commitment for control of field initiated design changes, neither did the index reveal in anticipated procedure nor a schedule for develop-ment.
- d Discussion with the BLR construction organization revealed that a procedure was scheduled for this activity to outline the construction group's responsibility in this area. A l,
procedure to address the QA aspects of this activity has not been scheduled for development nor is the activity i
addressed in existing procedures.
a 4.
Project Construction Organization The inspectors discussed site organization and construction activities f...
with the HL&P Construction Project Engineer (Allens Creek) and the i
i" B&R Construction organization.
j.
The HL&P Project Engineer for the South Texas Project has not been assigned at the present time. The Allens Creek Project Engineer out-s lined the typical HL&P site construction organization and discussed duties and responsibilities as provided in the PQAP.
>b The B&R construction representatives discussed the construction organi-zation as it pertained to Houston office and site activities. A projected schedule of construction procedures was presented and position descriptions of responsible personnel were examined. It was noted that the warehouse-man was required to be familiar with and observe quality control procedures l
related to his position.
Projected procedure development and staffing appears to be commensurate with project status in the area of the, construction program.
5.
BLR Site OA/QC Program Implementation The BLR subcontractor activities involving site geotechnical studies were reviewed by the inspector. The inspector examined the Woodward-Lundgren & Associates QA Manual. "Geotechnical Studies South Texas Project", dated 8/13/74, Rev. 2, dated 12 / 30/74. In addition, the (continued)
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d It was observed by the inspector that a review of the
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Woodward-Lundgren QA Manual was conducted by the B&R and HL&P jl QA Departrnents. QA record files reflect both internal and external audit activities that appear timely and consistent with the status of the progress of the site geotechnical studies.
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UNITED STATES OF AMERICA f
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huCLEAR REGULAT0tf COe9155!0N y
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1 Docket Mos. 50-498 4
HOU510N LIGHTING AND POWER COMPANY.
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(South Texas Project. Units 1 & 2)
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y NRC STAFF TESTIM 0'tY OF WILLIAM A. CROS$ HAM.
RAMON E. HALL. WILLIAM G. HUSA !K. M. 5HAMMON PHILLIPS.
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.lW DAN PAUL TCHLIM50N AND J.1 TAPIA RELAT!YE TO THE IMSPECTION 3
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- 10. 1974 AND ENF0aCEMENT ACTIVITY FOLLOWING THE SHOW Cf USE ORDER OF AP t
Q. W111 the panel perters please state your name, ewleyer. Job
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7 title, and specifically, year responsiblittles relative to the South
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. M t 4.7~, QI N My name is William A. Crosse.an 4nd I am Chief. Sectics 3 l[ gE, {,
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Reactor Projects 8 ranch. Office of Inspection and Enforcecent. Region If.
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I 4:3 responsible for the
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i g Q United States Nuclear Regulatory Comission.
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supervision of the project inspectors whose job it is to inspect nuclear%,"
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power plants under construction in Region IV. including the South Texas f
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My name is Ramon E. Hall and I as Chief. Systems and Technical S'
5ection. Officr of Inspection and En' ore.ement. Region IV. United States
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Nuclear Regulatory Comission.
the engineeetng specialist inspectors who inspect nuclear power plants U.
i '~s wtrain Reg:en IV. tnetusino the auth Texas Project.
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i h name is William C. hbacek and I as a Reactor Inspector. Section 4.,.'
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responsibleforprojectinspectionofnuclearpowerplantfact11ttes h..y I
under construction within Region IV, including the South Texa's Project.
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% name is H. Shannon Phillips and I have been the Resident Reactor
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Inspector at the South Texas Project since August
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responsibit for.' coordinating all safety related inspection efforts r
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relativ'e to the NRC Region and'the site. In addition. I was a aerber of s
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kk a special investigative team, investigating allegations concerning lack
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inspectors and the assessment of the effectiveness'of the quality d
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This assurance / quality control program at the South Texas Project.
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investigative effort resulted in the issuance of Staff Report J..
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50-458/75-19and50479/79-19(7919). the Staff's Orcer to Show Cause.
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,2 a' Hotice of Violation and a Proposed Imposition of
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dated April 30. 1980,
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o Civil Penalty.
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My name is Den Paul To=11ason and I an a Reactor Inspector.
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W Enginetring and Materials Section. Office of Inspection and Enforcement. *
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I la this 1.3.
a Region IV. United States Ruclear Regulatory Cocatssion.
re position. I plan, perform and report routtne inspections and assist with r
I am responsible for s
or perfom special investigations as required.
[,
- project inspection of nuclear p'ower factittles under construction in
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Region IV. including the South Texas Project..
j' Ny name is J.1. Tapia and I an a Reactor Inspector. Engineering and
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Materials Section. Office of Inspection and Enforcement. Region IV.
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m t-t United States stuclear Regulatory Consission. In'this posttion. 1 en responsible for project. inspection of nuclear power fact 11 ties withia
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i Region IV including the South Temas Prsject.
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Q. Was the panel prepared statanents of educational and g
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[i professional qualtf tcations?
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- Q. Are the statements attached to this testteoy ?
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Yes.
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Q. What is the purpose of the panel's testtaog ?
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The purpose of this panel's testimon is to report upon the I,,1 results of NRC investigattou and inspections following the issuance of (L.
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!&E report 79 19. This testiony will address two broad areas: (1)the
- 1. :
i, current status of HL&P's corrective action relative to the enforcement
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'> Jr actions resulting from 1&E report 7919 and (2) construction activity at
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the South Texas Project since the issuance of 1&E Report 7919. as
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, / 'i f 't; reflected in the Staff's inspection and enforcement reports on the
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-s Project. Specifically. this panel's testtoony will respond to Board
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i Issues B. E. and, to part. D.
These issues state:
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!ssue 8.
Has HL&P taken sufficient remedial steps E. 7*
- l-to provide assurance that it aw has the managertal
[., '
competence and character to operate STP safely?
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Issue E.
Is there reasonable assurance that the structures now in place at the STP (referred to in Sections V(2) and (3) of the Order to Show Cause) d U,,
are in confomity with the construction pemits an is.
the provisions of Canatssion regulations? If act.
has HL&P taken steps to assure that such structures ty.
i<-
are repaired or replaced as necessary to meet such I'
requirements?
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Issue D.
In light of HL&P's prior performance in U
the construction of the STP as reflected. in part.
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.4 In the motice of Violation and Order to Show cause w
dated April 30. 1980 and HL&P's resoonses therete n
23, 1980 and Jub 28.1980),and (filings of Mayactfons taken pursuant thereto. do the current KL&P l
and Brown & Root (B&R) construction QA/QCorganizations and p i
of 10 C.F.R. Part 50. Appendia Bs and is therereasonable assuran 5.-
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?
so that construction of STP can be completed laconformance w
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applicable requirecents?
In addition, the panel's testimon tapacts to varying degrees on the.
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I-i Specifically, to the eatent D'
other tssue's currently before this Board.
from which t
this testinov evidences a course of conduct by the Applicyt corporate character or competence can be inferred. It will be relevant ts I;;
those issues.
Q. Will the panel please explain the inspection and enforceoemt f..
i n
responsibility of Region 1Y relative to the South Texas Project s nce
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.e 79 197 Yes. Region IV 15 responsible for the routine, periodic
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,".j In inspections perforted by the NRC at the South Texas Project.
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follow-up 7-adition. Region IV has been delegated the responsibility to
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the deficiencies identified in 1&E Report 7913 to assure t a l1 corrective actions coccitted to by Mt&P were implemented or are f-la the
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This follow.up inspection activity has i
process cf being toplemented.
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been perforotd in addition to. and in conjunction with, the rout ne
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i inspections which Region !Y would otherwise nornelly perform.
L.;
Q. Turning the Panel's attention to the first of the two broad t:
I g.
i areas it will address. will the panel please sumarize" the MRO inspect on t<-
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19807 V
and enforcement history at the South Texas Project since April 30, L
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Yes. in 1983 the NRC perforced thirty-eight (38) inspections or A.
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tevestigations at the South Texas Project. During these inspections or x
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investigations.10 items of noncorollance were identificd and Notices of y'
ttolations were issued. As of April 13, 1981 seven (7) inspections or t.-.
F-Investigations were completed 'during 1951. resulting ta one ites of noncompitance. Each of the'itent of noecompitance cited since 79 19 are described in a list attached to this testicotty as Appendia A.
[
9.
Q. Are these latest itens of noncocellance stallar to those itens r
j.
I' c.'
Mt&P has been cited for in the past?
1 Of the ten items of noncoceliance. four (4) were for
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b HLLP's failure to follou proededures four (4) were for MLLP's fatture to a.
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respond to various requirewnts in a tinely manner. one (1) was for
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failure to dev'elop appropriate procedures and one (1) was for HL&P's failure to assure that purchased material conformed to procurement f.j'
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documents.
$. y Q. Ecold the Panel please identify the various inspection and
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enforcement reports issued since 79-197
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W Of the forty-five (45) Inspection and Enforcewnt reports
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Yes.
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7 1ssuedsubsequentto79-19.four(4)havebeent$entifiedandmarkedat
,I, 80-06. 80-07, 80-24 and 3-l StaffExhibitsinprevioustestimony(!&E. Reports 80-25 have been previously identified and marked as Staff Cahibit Mos.
31, 35, 40, and 45. respectively), the remaining Inspection and s
,(2..
i 13, 1981.
Enforcement reports issued subsequent to 7919 through Aprt)
!"f are identified and marked as Staff Exhibit Nos. as followss j..~
ist neoert Exhthis no.
tit a. cort tihihit no.
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These rept,rts will be referred to by 11E 8eport number and/or Staff q$.
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5 O.. Next, turning the panel's attention to the current status of L'.' -
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c H GP's corrective actions relative to the deficiencies ident
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f Report 79-19; will the panet please first reference each iters o w.
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previously identified as Staff Exhib t
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4 response of May 23, 1950, and then state the findings and conclusions of the ultC follow.up y
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. inspection which evaluated the adequacy of the implementat on e
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corrective action?
N Yes. With respect to Item of Noncoripliance No.1. NL&P stated v
4 f
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response that this ites, describing incidents of f.
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p' 23, 1980 in its May intimidation and harassment of quall y control personnel as evidence that----
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(p, the quality assurance function at the South Texas Project tacte b
suffletent organi24tional authority and independence, e.ould neither be 5
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confireed nor denied since the NRC findings were based upon information A.
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dates.
which did not d'isclose names of persons. Specific places and W.
h However, NL1P went on to state that its review suggested that suc Similarly.
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HL&P acknowledged that its QA/% program, as implacented, was inadequa e.
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pinpoint the source or sources of perceived production pressures; an 3~
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evaluation and revision of the in place program; an incrtased, visibi
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-s of both Brown & Root and HL&P canagement at the project site, various O
l neetings at both management and construction levels to er.phasite the ro e j
of QA/QC in construction activity; an increase in the site QA/QC staffing level; and various measures to increase feedback from inspectors to high O.
level management.
The status of the various corrective actions relative to the Q futC
[:
program was the subject of two separate NRC reviews. John $11 ray, t..
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[s se Sas11ty Assurance Engineer, reviewednr. siiray will effer separate tes (s:Ff m:
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frogramforconstruction,ritten program conforms to 10..
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the issue of whether Ht&P's w will not be addressed here.
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Appendia 8. and thus, this issueferenced as I&E Report 30 25 an f,-
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Q addition, an RRC inspection, reff Exhibit no, d5. performed dur ng tation.
5 :^
previously identified at Sta tiveness of program implemen f
t llips September.1980 evaluated the effec tor laspector E Shannon phi L
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ident Reac tions of b;.
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ction by asking a battery of quesrecord$1hsl g:'_...
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As to this second review. Res
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accoglished the follow-up insped two quality assurance d ction u? -
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{ f, lt 29 quality control inspectors ansked questions relative to pro uion,freedon g.
The personnel interviewed were aharassment. threats,fattnidat rm~,
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e(safety n-pressures, canagement support,stop work authority,resoluttoa sident
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to identify nonconformances.ification of Q4/QC records. The re i s were very h'. f n.~
related problems, and fals overall answers to such quest onsulted in Iteo
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reactor inspector found the identified conditions which re
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of Roncogliance No. 3. had been - -...it was still east
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scW 1$i Q. Did you find any evidence thatlity coptrol documents, rath n be Ia'.,
evident u
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.f inspectors to sign off on qua and/or construction annagement
?
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l confronted by their supervisors tioning just sentioned, and the S. no evidence
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A. No. As a result of the quesith Show Cause Itecs 1 and L.t.. '
to sign off on (g: j review conducted in connection will easier for the QC taspectors 2
O i supervisors
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j was found that it was st ather than be confronted by the r
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Q. Did you find arty evidence to contradict the conclustoa of ILE
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Report 79-19 that there was no incident of major safety significance y
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found which resulted from this practice of quality control f aspectorst 0
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No.
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r'.r Q. please continue to address each itse of noncongliance.
[.,;-
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L With respect to item of noncomp11ance No. 2. ML&p stated in its g.
2.
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- 2 response that this item of honcogitance was substantiated..-
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May 23, 1980 c
Essentially, the itaa of noncompitance stated that although a test fill (s.
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progran estabitshed that 12 passes with comattion equipment would n Ff required for placenent of an 18 inch maxtenan 1tft thickness. construc on.-- --
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F NLAP procedures required only eight passes with such equipment.
l correctly noted that this Item of Noncompliance is inseparably Itaked to i
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Shou Cause item No. 2 and any responst mst be viewed in light of it EP's
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Similarly, follow-up inspections have 3
respense to Show Cause Iteo No. 2.
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been performed with those inspectices relative to Show Cause Itas 2.
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MLLp has reviewed the test results obtained during backft11 placemen
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order to substantf ate the acceptabil!ty of construction procedures.
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z addition, the effect of Oe construction procedures on the adequacy of
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Show i
the existing backft11 has been evaluated as part of the response to O
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Causeitems2(c)and2(d).
The status of this corrective action was the subject of two I&E By an ILE inspection conducted between Ju,ne 23 and 28
~
pc,;$
r inspections.
1980. referenced as ILE Report 80-17 and preitously identified as Staff 7
I.
Exhibit No. 63. Brown & Root Technical Reference Document " Test Program P.5 for Copaction of Category I Structural Backf tll* dated June 2.1980. was V
j.
The purpose of this test program was to provide assurance that reviewed.
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3 reeste 4 o
the construction methods defined previously were sufficient to p i
backf tll which satisfied PSAR coccitments of act relative deastty
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Sface, as of the 80-17 eeport date. the test ftil I~
i and test l ?
j throughout each Tayer.
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(J program was'act yet complete. and further, sface the sett bor ng p
Shoe Cause program was still being evaluated "to support a response to Iten No. 2. Itas of Moncompliance No. "2 needed to be followed w is a k
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That follw-up inspection occurred esrtag 3
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r subsequent inspection.
October.1980, and was reported is 1&E Report 80-30, previously t-r-
L f.f 2
HL&P's responses to Shw Cause Order J
identified as staff Exhibit no. 74 f
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Itecs 2(a) and 2(e). previously closed out in I&E Report 80-24. were
' Root's ' Test
[. },
evaluated by E Inspector J. I. Tapia in 11ght of trown 4 3
d based upon Program For Compaction of Category I Structural Backf t11* an,
b.,-
liance No.
a review of this document and prior responses. Itaa of Noncomp The E faspector concir.ed that HL&p's failure
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2 was considered Closed.
ior to the torequiretrelve(12)passeswithcoepactionequipmentprThis
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'Wi start of end process density testing was of no safety significance.
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conclusion is based epon the fact that the fill test progran s owe f/;
, a i
(B) passes would be an appropriate starting point for end process
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T d the requisite P'
testing. s{nce typically that nuceer of passes produce f
4 f
l d in its dens 1ty.
With respect to Item of Noncoepitance No. 3. Hk&p admitte E.;
1 paratus for filing that notwithstanding the fact that test ap May 23,1980 iod of time.
seasuring relative soll density was out of order for a per f four sand cone plant backfill continued to be placed and several sets o density test
. )
density tests were cepleted without tae associated relative J
In response. HL&P purchased a backup vibratory head. 4
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being perforced.
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rel,atise density end. sore Q.,
p component part to egalpment for measuringF bruary 1. 1980. clarifying the jb.
aI' tapertantly.1ssued fastructions, dated, etingnoncanforelicondt'ttons.
J requirements relative to progtly documenN rin
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s referenced as I&t Report 80-17 and prev ouviewed,6tL&P's connitiens an 1
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ko. 43 k'C Inspector J. I. Tapta re It was vertfled that a backup; e
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determined the status of implementation. ringrelative; density.hadtIten.
[
vibratory head and a spare ecid for measuilable r;n site.. in addition. Brown,
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procured and both Instruments were ava
- 1. 1980,was revi @ '
[
1 l-
& Root's tastruction letter. dated Februarysponsiblittles conceratag t
t relative to clarifying subcontractor re ing conditions.,It was fc
. s identif,1 cation and reporting of noncenforms on site had reviewed th f.
1.
I.
a verif ted that all cognitant ecoloyee g '. ;*. Uf. ~
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tthat!crelative
__5,Q..
Q. What safety significance is there t'n the facand January lM b,-a instruct,fons.
i
- . 4 ', " g
- 17. 1979
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. denstty test was perforced between Move:ter period the testing I,s.. f t
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Mone, it was determined that during t etaken to be tested at a i*g.,
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equfpnent was Inoperative, samples werehnctional. Upon obtatning the s
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,, b time when the vibratory head became 1980. the saved secoles were tested l
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t necessary equipment in January of Consequently, a.lth.ough f-
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fou d adequate. This is, technically proper. broken equipoent w'asi a g
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n HL&P's failure to proegtly correct thein-process construc tion test each day p
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the f ailure of HLLP to perform this ignificance.
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construction progressed was of no safety s hat go reistive
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i Is there any other significance to the fact tand January 7.
- 17. 1979
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density test was performed between Movetter f
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Yes. One of the situations which the RRC is continually r,'s A.
wtchful of is the occurrence of false statements in various filings from 2
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False statements say or may not cause concern, E.'
Applicants.
a investigation, such statements may be found to be innocent oversights or t.,..
f ft intentional misrepresentations. 51m11arly, such statements any be either f:
critical or tenaterial in regard to their irr ct upon plant safety. Any.
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of hw they were made and submitted to the NRC and the safety. -
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significance of these statements.
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S be evaluated based upon its affect on the MR 's confidence in the
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chosen for particular audit was that of engineered fill placement.
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result of facts gathered with respect to in-process control of soll
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10; specifically. EtP was'dtrected to vertfy or correct, if necessary.
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the F5AR statements contained in Section 2.5.4. stability of subsurface
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materials especially Section 2.5.4. excavations and backftll.
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intth respect to the particular FSAR stater.ents, no information was gathered by the NRO to indicate that the statement was made as a The investigation found that the
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deliberate attempt to deceive the NRC.
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statements were made based upon construction specifications that the
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In this designer had prepared for the contractors to implement.
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instance, what was done in the field was not documented. Ett could not
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establish that the specifications had been followed, or that there were j
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3 no instances of safety significant deviations from the specification.
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a result of this assesscent, the NRC, as it has done in the past.
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permitted ML&P to correct or revise the F5AR statesents. la F54R rf'.'
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amendment 12. submitted Septes6er 12.1980 1
It was in this context f,A...
statements to conform to what actually occurred.
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that Itee 10 appea' red in the Order to Show Cause.
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1 satisfied that the revisions made to the FSAR on these two items now
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reflect what was cos9 sted in the field during construction of engineered d....~
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backft11.
- q. Stace the Sh = cause Order,have other instances of rais.
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Q. Please explain..'"~~~
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was contacted by an individen) who alleged that Brown & Root management
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Y 75 if-altered construction records, changed draft nonconformance reports.
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1-f promoted unqualified personnel,and were intimidating quality control Specifcally. the individual contacting the resident d.r inspectors.
inspector indicated that a f abrication checklist containing a ' bold i
point
- was not inspected as required and yet the record was falsified to a-tg:
In addition. It was k,
indicate that the inspection had in fact occurred.
L-k alleged a draft nonconformance report written by a QC inspector on this U
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untter was rewritten in November,1979. by the site QA manager and/or afs t
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staff and pertinent thformation was purposely deleted.
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personnel f t'le without proper authorization.
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Q. Hon 'were these allegations' tavestigated?
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la June.r1980. MRC investigators E. K. Here, and D. D. Driskill.
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traveled to the South Tests site and intervleued the'various personnel r
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involve'd. as well as reviewing the alleged falsified records. This
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no. 40.
With respect to the f41stfled fabrication checklis"c. We individual I
allegedly f alsifying this docunent admitted be did not inspect the
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reertting of a draft nonconformance report. it was dettreined that the 1,
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f t-st draft of the nonconformance report identified both the passing of a k.~ e,.ln.5.
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matter of backdating an internal Broen & Root personnel anute. and
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therefore cettted mention of this incident in its formal nonconformance.
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Next. with respect to a formal warning being isgroperly recoved from k _. ~
report.
Apparently. the
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l individual who backdated the document described above received a writtem j
warning from his supervisor, for fatture to conduct propee inspections.
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trong care te The warning stated that the individual was to ' exercise st ' la the future s-L-
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syttng accurate and complete survet11ance repor s l foldee for this l
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warning was contained to the troen & Root personne l'c indivtesel.
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In addttton. as document f alstftcation.is,poteattally a
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cristnal act. this matter was referred t4 the Justicet has subsequently q.;
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enforcement considerations. The Justice Depar men decitned to presicute.
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{3 Q. What is the current job status of the individual who adm t e
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falsifstng documents?
i i dividual was
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Q. What other instances of document f alsification
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terminated.
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statecents were called to the attenttee of the NRC?the h,[ f ef.'
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A. On July 22,1930 lleged that Brown & Root
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saintenance records had been falsifned.
d explatned that over f,'
entered the resident reactor inspector's office aninated tty Brown & Root
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's-the past two scaths, two ecployees had been term h t recently a
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for f alsification of records. This individual explained t a y
the individual was
.p foreman was identified as falsifying reccedu homever, v
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ith higher not te-atnated beesuse he had some ' stroke' wSpect p r.
supervision / management.
d identified as
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wherein the equipmen,m h
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5 101885 10198 on June 24. 1980 the records were falsified to indicate the Cards No.
inspected as required and yet During this same investigation. verfees g
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i h that the ndividuals indicated that this forense Instructed t en i
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(a) To discontinue reporting discrepancies on any itens wh J
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previously been reported.
i Not to inspect the interfors of vessels during integr ty j
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checks.
Not to write up discrepancies on the storage crea.
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Not.to write up discrepancies on equipment that f,
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4, 1980. the foreman ac,cused was laterviewed and execute
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'I On August This individual sdattted to falsifying mintenance
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a signed statement' ifier pu@ when he signed off the Q:2 2
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. card W 101ES concerning a vacuum degss
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- 1.;%.t caintenance card ir.dicating he rotated the shaft o N--o This t te that shaft.
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to indicate during the interview that he did not ro a p
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foreman also aNitted that during a treintog inspection.
s ri-ipment that subordinate to sign off a couple of maintenance cards on equ t was located inside a they could not inspect due to the fact the equi;oen I
The foreman offered the explanation that someone locked building.
t (identificationunknown)inuppermanagenenttoldklanottorepor A
td adding discrepancies if the discrepancies had been previously repor e.
He also stated that he told that,he passed this word along to his men.
that it was not his een not to report discrepancies in the storage arta.
i integrity checks on necessary to inspect the interior of vessels dur ng This dirty equipment.
each occasion. and not to report discrepancies on
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f ilith respect to Itee of Noncore11ance Re. 8. HL&P admitted
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that no effective program had been implemente 23,1980, tesponse of May for the review and analysis of nonconformance reports. esam t
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ti on a checks / inspection books. er field requests for engineering ac on y
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- 23. 1980 response stated t ah t three continuing basis. HL&P in its May for the documents have been or will be developed which delegate aut ineering proper handling of nonconformance reports. fleid requests fo tline h
action and examination checks / inspection books. These docun h events and for the proper procedure for performing trend analysis on suc reviewing the results of that analysis, 83 in the course of an 1&E inspection conducted during Se
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Exhibit Mo. 45 referenced as 1&I Report 80 25 and identified as Staff
,d Reactor Inspector H. Shannon Pht111ps had cause to revi The resident reactor inspetter reviewed Resident status of the corrective action.
liancet three docu ents which demonstrated NL&P was in full coep m
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" Procedure For Trending and Reporting of FREAs. NCRs. and f
'Nonconforrances Trend Analysis.' ' Engineering Requirenen h
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Tracking and Trending of FREAs. NCRs. and 50Rs." A revi i
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Trend
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- 31. 1980 indicated that all t
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Analysis Report for the period ending July I
FREAs. RCRs. and SDRs were tracted. The resident reactor l
considered this statter closed based upon the adequacy of t l
l documents and proper tracking.
With respect to Ites of Moncompliance No. 7. HL&P. la its ii continue to admitted that concrete placement activ t es of May 23. 1980, d Such be a problem, after beteg previously identified and not corre i
lighting lack problems included improper consolidation practices, poor l
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of adequate maters of quality control preplacement f aspectors.
i production pressures and excessive lift thicknesses.' In reply. M.&P
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l carmitted to supply enough quality control inspectors to assure that f
i preplacenent inspections would be conducted in a thorough sanner.
t s.
I procedures were revised to require the con 91stion of the preplacement I
i i g off of pour inspection by E inspectors.and their subsequent s gn n This is viewed as an effort to cards. p'rior to the dettvery of concrete.
In addition lighting was reduce construction schedule pressures.
igroved. supervision and tra,ning were increased. and both pre and j
7 i
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post-plscement ceetings were to be held to discuss placement activity.
In I&E Reports 33-19 and 80-24 identified as Staff Exhibit Mos. ES and 43. respectively. NRC Inspector J. I. Tapia, reviewed the newly issued Brown & Root quality concrete construe'tton procedure which was 1
i The new procedure
,g 1ssued in response to Iten of Moncomp11ance No. 7.
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describes the methods and requirerents for all activities involved with N.
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5 Ic9reper consolidation and excessive lift 5,
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thicknesses are addressed by specifying the matisum 11 alt for deposities 3
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Documentation relative to and definition of proper vibrating techniques.
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Formal requirerents for both
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the retraining of 188 persons was reviewed.
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pre-and post-placement meetings for all safety related concrete plate:Entt were reviewed. The problem of inadequate itshting was it was further verif ted that 1,
addressed and 1.uplenentation was verified, Ej the problem of last minute construction activ eg causing undee pressure en quality control inspectcrs was resolved by revising the procedJres for
'I Ij concrete placement to require the corpletion of the preplacenent P
inspection and the subsequent " sign off* of the pour cards by the M
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traspectors as a prerequisite to the delivery of concrets for placement.
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I In, addition, new procedures define the quality control inspectors authority to hold work when he believes that the quality of work being accoeglished is unacceptable.
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The RRC sought clarification from HL&P relative to its comitment to I
ML&P. explained that it coccitted to
~i provide additional QC inspectors.
increasing the relative number of preplacenent QC inspectors based on h
l' construction activity. but did not eitan to comit to an increase in t e l ification absolute numbers of QC inspectors., Pending receipt of this c ar Following receipt of this clarification.
this itwa was not closed out.
d the NRC inspector considered HL&P's Corrective actions adequate an closea this matter.
Iten of Moncoceltance Jo. 8 cited various unqualified civil and
..y d to this concrete qua11ty control inspectors.' HLIP substantially admitte In its response to
- 24. 1980 response.
Iters of Moncoepliance in its May' ky i ce of
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all Brcwn & Root &nd Pittsburgh Testing Laboratery inspectors During an
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1980, 11 Report 80-24
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i' 1&E Inspection conducted August and Septeeber.
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identified as Staff Exhibit No. 40. De records of the education a r
experience of various quality control inspectors were reviewed and The RAC inspector verified that a review of the qualifications verified.
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and certifications of all civil QC personnel was conducted by HLLP.
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- 12. 1980. HL1P had retrained and qualtfled 23 concrete C
' '..a of Septecter In addition, new proceducts were issued outilatng the
'd inspectors.
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l process to be followed for verifying a new eeployee's educationa In addition to reviewing this new backgruund and prior work experience.
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Inspector's file procedure, the M; inspector randomly se'iected one Q:
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-and verified.that the three years of coll' age educatfon Ifsted on
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I had been conf trced by receipt of an official transcript fr f
HL&P's review of all civil QC ' personnel and the revised 5 -
' d ation and I
college.
procedures relatt[e to the substantiation of new employee s e uc work background resolves this Item of honcompliance.
Item of Roxo plia.nce No. 9 cited MLLP for its f ailure to contr I
the documents in that 4 CA manual did not in:1ude interis changes or HL&P admitted to this Item in its May 1atest docur. tnt thange notices-t ELPreprest'iledinitsfeplythatallcontrolled 23, 1980, resprise.
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Further, to avoid further Items of n.
documents vert revised and updated.
had been added
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j' f Nonconpliance in this area. an ad:ifnistration technician trol.
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to the site KL? CA staff, to be responsible for docueent cca f.0-
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"c Durie.g as 132 inspection conducted in September 1950. Res 7'
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(a)alldocumentsen W
'.d Reactor laspect5 M. $bain9n Phillips vertflee that
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a dary file in the K17 office were revised and up to date. (b) 4 seconh f... T"-
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(c)an review was eth hy NL&P quality enaineering staff, and
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Docurent control adEilnistratist tettwician had been added to the staff.
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b the Brown & Root of quality asswesatt prockdaret previously controlled y i
transferred to the site. These reviews and action home of fice, 2 1980s documented in CLP office eemoranda, dated September 11 an I
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In accordingly. the M0 inspector considered this matter closed.
li d in afdttien Ri? m,a longer uses interim changes as more fully exp t
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i li response to tira of Noncompliance No.12.
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U to iten of Moncoeg11ance No.10. HL&P admitted in its r1 l
d cted 'a an
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.l May 23. ISSh eEspnse that welding operations were being con u b
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23 t-environment not controlled to protect against contamination and advers p
P Essentially, sand blasting was occurring in a f
et.espheric conditions.
d consequently the ii work area iceediately adjacent to welding act v ty an f-NL&P coresitted
{
l airborne sand from the blasting was spotling the welds.
I :
t ination f
to rewriting wort procedures to require protection against con am h
In from rain snow. and airborne particles during welding operations.
a Itt Report 80-24, identified as Staff Exhibit No. 40. Reactor Inspector I
Can T elinson reviewed the revised procedures and verified that ade
[
requirements had been tr.plemented for maintaining cleanliness du A training sessica for all welders and welding s,f welding process.
d on
)
supervisors instructing them in the rtvised procedures was conducte
,t.
In light of the above. this item was considered
~
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February 15. 1980.
h.
closed.
I, Items of Monec :pliance Mos.11a and lib cited ELP for its f ailure l
diographic
,:.'a't ~
,a 5
to properly control radiography and to preperly interpret ra
- 4. f.:
- e s.,. <
.e
,. y *,v.,'1 f -W ' g k R &P admitted to both these Items of Ncncoepitance in its
.,o
. 3,. *
.1 fils quality.
( ;..s response. With respect to corrective actfon.
i
'~
u Itay 23, 1980 comitted to reviewing all radiographic film to identify discrepanc es.
ing revising radiograph film processing procedarts to clarify flim process
(
. l ll as techniques, retraining and certification of all EE personne, as we I
a revision of the requirements for recordits film conditions.
In !&E Report 80-38. identified as Staff Exhibit No. 82, conduct j
ddressed j
between December 15 and 18. Ig80.'NRC Inspector Dan Tomlinson a
't r
d l selected f
ff E &P's various corrective actions. The MA: inspector ran om y radiographs from six essential cooling water (ECW) piping joints 1]
gh review.
nondestructively examined after October 6.1980. for a thorou r
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e on 2oo 24 The purpose of this review was to assure cocpliance with De A$!!E Beller i
and Pressure Vessel Code requirements. A total of 48 radiographs wert reviewed for shooting technique, proof of coverage, penetranater L
selection and placement film denststes, file identification, toege 4
{
sensitivity and adequacy of developing technique.
Each film was individually evaluated using Code acceptance standards and the reactorL V
inspector's results were then compared to the corresponding Appittant i
F For the sample of file exantned, alt interpretation sheets.
I
,8 characteristics and evaluations appeared to be is corettance with These findtags forwed t'he basis for the appitcable code requirements.
f el '.j*
inspector's conclusion that R&P was currently property contro11 tag i
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radiography and properly interpreting radiographic film weld quality.
i, i, EtP further ad.11tted to Item of Roncompliance No.11(c). citin5 the s
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Appitcant for its fatture to control itquid penetrant examinatter.4.
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response. Etp stated that its investigation leads it i
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to t'elieve that this violation was an isolated incident; however. ESP
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went on to state that in order to address the problem in as orderly
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sanner, all 11guid penetrant examinations at the site were suspended by y'
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quality assurance until corrective measures could be taken and all persons conducting liquid penetrant exantnations were given additional
, }l training in inspection techniques, procedures and criteria.
During an
')
inspection resulting to I&E Report 30 24. Identified as Staff Exhibit No.
e
[
l
(.'
- 40. ERf. Inspector Dan Tomlinson vertfled that all RCE personnel had been retrained in the requirements of inspection procedures with an orphasis I
upon the importar.:e of adhering to such requirements. Training was followed by a reexantnation and recerttffcation of all liqi14 penetrant F
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25
I In consideration of the above action. this matt inspection personnel.
ta tited its was considered closed.
ELP adcitted to Iten of Moncog11ance No. 22, which nga l..
f the use of 3
fatture to follow procedures. this time in the contest o 50E activity interia procedures. Essentially. procedures governing anto emp y[,
were modified by an interia change which was d 4 aonths issuance. Nonetheless this interia change was bein beyond its empiration date.
h es from all outstanding interia changes and to reciove those c ang i
bf In addition. R &P decided to eliminate the use I
t 80 24. identified issuance.
changes. During the inspection which led to !&E tepo i
p as Staff Exhibit No. 40. ARIt was verified that the use of interla
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...)l revised procedures.
ce were recalle'd.
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been eliminated and all interia changes in exis en d ral revisions Y (.,
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Future' changes will be made by way of pemanent proce
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which r'equire internal review prior to
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r-f' ' %S' i 4 fire'ed that it use of interte changes.
In response to Ites of Moncog11ance No.13. NL&P af 1
d d requalification.
i failed to take corrective action when cadwelders nee any Cadweldee.
f, According to the F5AR and Brown & Root specifications.hin a un j
, l
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accumulating 2 unacceptable productfos splices witJe violati
".,g' consecutive spilces was to be requalified.
ithout requalification requirement 5 Cadwelders continued production w E &P revised
,f6
' ]s after acewiutating 2 visually unacceptable spilces.
lts2 unacceptable specification to provide that when a splfcer accuew a e
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'r tive test saeples.
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tensile (not visual) tests within a unf t of 15 consec
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he shall not be permitted to continue slicing ontti he has requa 3
in addition,it was verified that quality control taspectors were j
espowered to step work in progress untti observed discrepancies are i
i The issuanca of Quality Construction Procedure No.
resolved.
ntil A040rfCOP 25 authorized the QC inspector to stop work to progress u
?
3 In
, the nonconforming conditions was resolved by a project site enginee b q ent I
addition this procedure requires that all such conditions and su se u r
ts and that engineering dispositions be docuranted on nonconfornance repor b
disposition of the quality control inspectors are to be made aware of the f
h All of the above corrective actions were.
j' the nonconformance report.
Staff Exhibit No.
[
vertfled in ILE Report 80-24. previously identified as C
l ed.
- 40. by MRC Inspector J. f. Tapia and accordingly this item was c os s
no.14 cited HL&P for its fatture to take t
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Item of Monconp11ance to l '
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corrective action in a reasonable time and for management's failure iA f
HLU adattted to the truth of this
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resche problec:s in a timely fashion.In this response. HL&P developed h.
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s iters la its May 23,1980 response.
"fallure To 3
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approved new audit procedure containing a paragraph entitled p
N fied Respond
- providing that if an acceptable response to an identi i
deficiency is not received within 30 days following identificat on, a
?
letter shall be prepared, with copies to. senior CA managenent a 3
that Corrective action would then be td em et group vice president.
l level.
item f1 Resident Reactor Inspector H. $hannon Phillips reviewed this i
3 fdentified as g
and docurented his inspection effort la 11E lteport 80-18 a
Mr. Phillips identified a steller problem during Staff Exhthtt No. 64.
There was still a lack of involvement by renagement in r
2 this inspection.
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f' assuring audit findings were being corrected. Consequently. a Motice o The resident reactor inspector again reviewed this.
I ytolationwasissued.
t 30-25
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.l matter during his Septester inspection. as docunented in !&E epor The resident reactor inspector and identified as Staff Exhibit No. 45.
I e
its reviewed and evaluated R&P's plan relative to taplementation of
[
corrective action ja such areas as; (a) whether PSAR temitments we ll translated into specific procedures. (b) whether impasses were usua y.
1
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escalated to the QA annager and/or STP project QA manager. (c) the stat J
C-4 l
0 f
. the consequences o,
ofsitesurveillances$15-12.515-18.and515-26.(6)
- the audited group's failure to respond, and (e) whether the ' root causes j
. i 8
s 1f, of tapasses wert, caused by the failure to reflect project requiremen
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workable procedures.
4' Based upon the review and evaluation of the management actions D
'O i item was
,I
- described above tN r'esident reactor inspector concluded th s
?j t., C I (p,n.O adequately resolved and closed this catter.
23, 1953
.s f f $f
-N i
- n; Idith respect to item of Monco=pitance No. 15. In its May 4 :. 5 I'..,
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d during p-y l ;r, ~ L, response. Ht&P ad=itted that unsatisfactory conditions identifiep,4..
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R&P surveillances of Brown & Root construction activ,ity were notf
{s i,y As a result. HL&P cornitted to retraining all R&P
.. a, l
. properly documented.
surveillance personnel relative to check list docunentation of all I
unsatisfactory conditions. Written instructions were issue
, }
l d in an R&P e
y j
3 2
An R&P site procedure, dated June t
,4, mensrandua. dated February 1. 1980.
8 3.1980. clarified actions to be taken in the event of the discovery i*
q an unsatisfactory condition. ML&P personnel received training on this
.y Subsequent to 79-19. the R&P site i
^ ' '
- 18. 1980.
procedure June
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organization. R&P site organization's function chtrged from a '
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survet11ance function to an implementation review function; in addition.
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.l a, mew group was created to perform an inspection function sin {1ar to
., )
An tut; follow-up inspection documented in JAE old surve111ance function.
Report 80-25 concludes that all unsatisfactory conditions idntified
~
during HLLP surveillances were properly documented and that the f
implerentation review function replaced the surveillance function.
HL&P admitted the findings set forth in Item of Noncon9 (ance No.
1
- 16. In that it failed to control the use of a nonconforming hamer in In its response of May 23.
i penetration testing of Category I backft11.
j 1983,HL&P stated that at the beginning of the soll penttration test program, the hamer and chains on the test rig were found to weigh 148.9
{j A nonconformance report was
~c,j pouncs rather than the required It3 pounds.
h d untti written by consultants Woodward-Lundgren but was not dispositione
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Thus, this ites was cited in 73-19 as not only an f
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February 4. 1983.
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esa:gle of HLLP using a nonconforming hamer, but in additfoe. It is a q.'
g' 4;-u wy t cas:.
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further example of HL&P's inability to properly process nonconformance j ;,3 1....,
o,.
h I
g' e am'T c reports.
I b.r**
During the investigation which resulted in I&E Report 80-17 I
identified as Staff Exhibit No. 63, the rtport of Woodward-Clyde l
4 r.
consultants was reviewed by MRO inspectors. This report docueented the fact that the initially reported weight of the hamer included the weight
~.
Upon reexamination, the actual hamer weight was
'i of the holsting chain.
another hamer was found to weigh 142 pounds.
-j L
found to be 138.9 pounds,
.i
$1nce ASTit 0-1586 does not prescribe acceptance tolerances, both hamers
~;
i were considered acceptable by Wood ard-Clyde consultants. Any' fj j-variability introduced by these minor weight variations would be masted 1
4 21 or
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23 In by other uncontrollable variables in the penetration test process.
addition. HL&P comitted to the revision of site work procedures for handling nonconformance reports for outside consultants prior to As of 83-17 these revisions had not yet resuretion of work activities.
[
During a subsequent WRC faspection documented in ISE Report occurred.
M-19, identified as Staff Exhibit no. E5. an ERC Inspector reviewed the j
b revised procedures which defined the handling of nonconformances in this
[
I S
These procedurts were sicliar to the procedures for handling - -,r.
,i s
context.
d this nonconformances in other contests and were thus found adequate an
.j F
,f iters was considered closed.
response. ML&7 admitted to its failure to n]
In its May 23. 1960 control the dinensions of the split spoon in soils test control this r
fi NL&P stated failure forned the basis of Ites of Esncorpitance No.17.
that although the Terzaght spoon used had different dimensions than the
{'
t split spoon specified by ASTH D-1556. this difference had no effect on
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l DJring the ht0 inspection which 7; ',
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the standard penetratien test results.
glr.g, {,..
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., g preceded the issuance of !&l. Report 83-17. Identified as Staff Exhib
' y No. 63. an ERC inspector reviewed the analysis performed which led to The calculations that conclusion, agre.ed and closed this issue.
l supporting the evaluation and conclusions were also reviewed and found N
1 acceptable.
HL&P abitted in its May 23. 1933 response that it fatted to provide for. and conduct. supplerental audits as part of its quality
~
Thts finding formed ue basis of Item
.s assurance' plan and audit systen.
O}
of Noncompliance No.18(a). NL&P ccc=itted to establishing procedures to isolecent cocnitments included in its PS!Jt. to establish qualttative
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criterta for the evaluation of audit effectiveness and the need h.
suppienental audits. This failure to implement PSAR comitments f ate procedural spectffcations also formed the basis of Itee of Moncoglianc
.p R&P admitted that it failed to perfore audits to the depth I
No.18(b).
necessary to assure implementation of site WtlC and constructionb
..r; procedures because audit activities were limited to periodic onsite c
surveillance and exastnation records in belief that such act i
3.
Auditing was further igeded by -
k 1
satisfied audit requirements.
insufficient time to prepare for audits and evaluate audit findtags.
i EP committed i
This formed the basis of tten of noncompliance No. 18(b).
i to perform in depth audits by reorgantzfag the audit function revis ng l.
procedures'to regaire in depth audits to assurt implementatfoa of b
e ffing procedues related to work activity, and by increasing the audit sta r
dl level.
e.., ".
Report 8018, referenced above, docucented a follow.up inspection
- f. 7. ** -
1 ffective and in-p.,
.E
.
- lm..y which determined that EP audit group is performing e i., ' ','
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a
,;g depth audits.
increased by reorgantzing the audit function and by adding personnel.
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was noted in this 1&E Report that this item was considere c ose.
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. 3 however, effectiveness of future audits at the prescribed frtquency w j!
!&E Report 81-07, dated April 13. 1981, documented such a
-)
be.,onitored.
This ites is closed based upon verifying the
- }
restew of R &P audits.
'.s
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above cited corrective action.
f1 R&P a&sitted that it fatted to, perform seat annual audits of Brown as well as falling to perfors
, A Root site org'anizations and proceduras, l. 3.-s
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gf annual audits of Brown & Root construction site activities, as require k
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by the PSAR and app 1'icable HLLP QA procedures. These findings fam basis of 1ters of Moncomp11ance 18(c).a I&E Report 81-07. dated April 13 L.
1981, docunenteit that NL&P was performing effective audits' at the r
prescribed frequency.
Is it this finding. and findings sisilar, which le'd the'IctC to 4 Q.
conclude that HLLP abdicated too such of the responsibility fo.' the V
construction of the South Temas Prcject to Brown & Roott
)
t A.
Yes.-
a Q. What corrective action did HL&P propose as a result of this Ites of Moncompliance?
$1nce N rch 1. 1980. HL&P's corporate audit group has been r
A.
scheduling and performing audits of Brown & Root construction activities.
- . ~.
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31, 1980 to state HLLP auditing procedure. QAP.53, was revised on mrch
. -f,i that not only will objective evidence be exactned to ensure co=p1tance n
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with CA require ients, but procedural 1::plementation will be vettf ey, '.,
l d by
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dirttt ottervation of work being performed.
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.j-During a routine M!tt invest 12ation which resulted ir the issuance of
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,j 1&E Report 84 27. identified as Staff Exhibit No. 71 resident reactor
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)I inspector. H. '$hannon Phillips dettrained that HL&P had developed a
.\\*
p matria to assure all procedures will retelve proper consideration when i
Current schedules indicated that all planning audits.
As a
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procedures / organizations are planned for or are betr.g audited.
- r result of the broad ccrrective action taken, the resident etactor inspector had no further questions on this item; but. indicated he wo I
continue to annitor the frequency of audits during future routine i
e
- 4 inspections.
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. 32 it fatted to audit
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response that HL&P adottted in its May'23, 1980,
Apparently, troun &
Brown & Root site activities to a sufflctent degree.
ite activities I -l -
t Root corporate offices in Houston audited Sroun & Root s P
d ral checks to I u primarily by a review of records: there were no proce ut d effectively.
i-assun that activities affecting quality wert ing'lemen e No. 19. Brown 4 j
These findings formed the bests of Item of Moncocoltancethe pr f*
~
Root initiated a new audit program, changing fromThis chan 9
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system to a program /systes audit.
l 'eviewed and l
and the toplementattaa of those cetteria are adequate y s
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evaluated on a periodic basis.
Q. What is meavit by a progra=/ system audit rather than e
t
'c i ities auditt A procedural audit ts cerely a paper restew of act v 2 's
_.,D A.
g This' system contributed to represented to have occurred in the field.
h t was happening in the
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upper corporate management losing touch wit:t w a F [. id dit and a h...,73
- p. '. ;.,.,h In costrast. a program /systera audit is both a paper au.I m
field.
h t is represented on paper 7
d,
acre ta. depth review to determine whether w aIn short, it is a
" yc-F 6
occurred, in fact, in the field.
ork in the field.
l proceducts to their ability to effettively contro w t m was reviewed During an inspect on for I&E Report 80 25, this sys e i
lt of positive findings to verify it had been icplemented and as a resuitem should be closed.
i the resident reactor inspector deteretned th s
&P revised its J
- With respect to Iters of %ncompilance Ito. 20. ML I
the proper procedurts
]
procedures and retrained its personnel in regard to l.
- i found during
---j in tietng reinforcing steel. The NRC special investigation H:1P d were unsecured.
a spot inspection that 3 of 10 thear ties etamine
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adottted this Iten of Noncogliance and comitted to the revision of site
'I i
procedures, to correct excessive production pressure on QC inspectors and L
to hold routine post. placement meetings to identify probles areas.
ci, During t6e inspection which led to the issuance of 1&E Report 80 30
)
fidentified as Staff Exhibit No.74. in addition to verifying that the above action committed to was implemented, the NRC Inspector reviewed an t
{'
. analysis which showed that the ties, without being bound, were not E.,
3 j
capable of moving beyond a 12 inch spacing because of hortaontal j
reinforcingsteel.Themaximunallowabiespacingofties,accordingto the design is 24 inches as coepared to 12 fnches provided in the South
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Texas spectitcations. This analysis indicated. therefore, that the
,i j
actual shear load requirenent, was half of the shear load capacity 1
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[e Thus. MLtP's failure to properly tie the retar was of no provided.
A
. d. -
4 Based upon this analysis. NRC Inspector J.1. Tapia safety significance.
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k concluded that the integrity and strength of the diesel generating D' '.,.,
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'. . [.h f, t but1 ding mat had not been degraded by the latt of sheer tie wirfng which{,"
3
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5
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,p formed the basis of Iters of honcogitance No. 20.
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Q. What. if anything, does this Item of 'loncomp114nce illustrate 7 r-
[
5 This item. as is also the use for Itees of Monccepliances Nos.
t 2'
r 'f' A.
d and others. 111ustrates HL&P's failure to identify and
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- 3
- 12. 16. 17 correct, in a timely manner, situations which potentf ally could affect 1d safety related structures at the South Texas Project.
y
(.j Q. Please now addrest the final two Items of Nancomplian:e.
. 'd.j In item of Moncompliance No. 21. HL&p adattted to falling to A.
root openings and weld dimensions, to that control design changes in
.' 3 Brown & lloot initiated engineering changes in certain welding procedures h
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h without complying with applicable portions of the Brown & Root QA Manual
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-for control _of design changes. R &P represented that design c ange h
procedures were to be revised and all administrative and technical
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h personnel in the welding engineering department and QA/QC personnel I E involved with design changes wou'J be trained in the design change p,
system, making thee fully cognizant of the correct method of requesting 3
NRC Inspector Dan Ton 11nson in 1&E Report 80 24 verified I
design changes.
that the proposed corrective action was jarlemented, and based upon the--"-- ~
adequacy of that action,this satter was closed.,
N "1
Iten B in ILE Report 79.lg stated that, ESP did not use a i
It was penetrameter on the source side, as required by the ASME Code.
- -l determined that, notwithstanding access to the source side work was done i
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. with only a 'f tle side penetrameter. E LP adattted this failure. By way 1
of explanation, radiography of selds utilizing a film side penetranater
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fy f, [, j n /,'.< g. y
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lC is allowed by the AST B&PV Code only in cases where the part v'.. J.
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je s N }.J'q',5,@l; configuration prevents hand piacing cf the peaetremter on the source l, ' ~,O.] g fn~'.7,M r). $ _'
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j, j,"q'r,j side. otherutse source side testing is to be performed. During the N'
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construction of f.he South Texas Project, it had developed as cocoon
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practice during qualtf tcation testing of welders to use the file side technique, even though no such configuration restriction existed In IAE preventing welders to use the penetraneter on the source side.
_,g, Report 80 24. KRC Inspector Dan Tomlinson verified that all radiographers have been retrained in the proper placement of penetrameters and in the 51siteduseofthefilms'idetechnique. la accordance with restart f
J!
commitments, all ASME welds made to date will be reinspected as part of
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the program to assure that quality welds have been produced regardless of L,
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35 All future welder errors in the welder Natification testing method.
fest coupons subject to radiograph examination will be shot using a j
source side penetraneter when possible.
Q. Turning the panel's attention to its follow-vp of the 10 items in the NRC Show Cause Order. specifically iten No.1. did ESP retai experienced. Independent management consultant to determine w l control over management of the QA/QC program is adequate to esercise ful r'
allaspectsoftheSouthTexasProject?
It should be first noted that HL&P responded' to all A.
Yes.
30,1980 Show Cause Order in a j
directives set forth in the Staff's April entitled *1.lcensee's Response to Order to s
p j
filing datid July 28. 1980.
~~
In this resoonse. K1P stated it retained Bechtel Power Show Cause."
Bechtel Corporatten. Caithersburg Po er Olvision, during February,1983.
conducted an audit of E1P's QA/QC program during the period beg
?
21.1980. utt112tng 11 auditors emperienced in Q
G' P. arch 4 and ending May K LP's response to the Shcw
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eucteer cc..st.actica and CA requirements.
'e Cau?.e Order has previcusly been identified as Staff Exhibit No. 43
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Bechtel's independent management rtview of K1P's QA program is i,*
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..I to that exhibit as Exhibit No. 1 f
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In its management review. did Bechtel consider the pros and con Q.
h (e) of the various organizational alternatives refernd to as (a) throug 1
J j
In Show Cause item No.it and if so, please state the reconcended c 4
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.~,1 of attica?
i d
Yes, each organizational alternative, together with its pros an jj A.
i cons,was addressed in turn. E LP chose to maintain a modified ve t
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of the in-place organizational structure where Brwn & Root has I
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e'rall supervistee,
h responsibility to Iglemnt a QA/QC program under t e ov The progran was revised to' enhance the direct role of upper it This goal taas j.
of E SP.
management with the ongoing activities at the s e. E nP assigned to the accogitshed by having the corporate CA canager for LP Executive -
South Texas site and he, t.n turn reporting directly to De E j
the'
- Noerous other changes were accomp11'shed and will be
.i I
1 John Gilray.
j Vice president.
subject of the testtoo v of E qua11ty assurance angineer.
i laboretten and attention is directed to Mr. Gil' ray's testisey for an e f
upon the quality assurance program changes.
1P Q. Turning the panel's attention to show cause Ites 2(*).
z,
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ll co'nditions. Ilf t.
review the test fill program which estabitshed so
.?
y acteristics necessary L-h thicknesses comattive efforts and equipment c ar to develop in place densttles?
E&P stated that it
- 28. 1980; N,
In its response of July lttee to review
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f, all soll and backfill cetters.
developed in 1978
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procedere for Category I structural backf t11 was f rst
,I t practices.
based upon specification requirements and eatsting indus ry i
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s lt stated that the self.l g osed test fill progras showed that d by 4 passes over j
approsteately 40% relative density could be obtaine
& Root site.
,j loose lifts of between 18 to 24' inches. However, the Brown 9
istons for a geotechnical engineer conservatively reccmended that prov
.1 d into constructios Q
-1 sinican of 10 roller passes be initially incorporate l d d that the f
., 3 procedures. However Brown & Root subsequently conc u e l
on the surface
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sintrus of 12 passes would actually only be necessary
'.o r
document The test fill program is described in detati in 4 ilft.
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246
.-l' 37 entitled " Test Program For Corgaction of Category 1 Structural Backft11
^
d ified as which is attached as Exhibit 9 to wha't has pretteusly beta i ent t
I MLLP concluded, along with its task force and Staff Exhibit No. 48.
independent review committee, that the construction methods in vse at t ttee of 7919 resulted in an end product which seets er exceeds project
..q.
i s
dettgn requirements.
During an NRC inspection which led to the issuance of !&E Report 40 24 idenstfled as staff Exhibit No. 40. NRC Inspec. tor J.1..Tapia i
[
miewed inforr.ation which addressed the test fill program which 2'
estabitshed soil conditions. Inft thicknesses. coepactive efforts,and
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equipment characteristics necessary to develop the requisite in. place 3.a C
dtastties. This review was in addition to that performed during an
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thspection by Mr. Tapia which resulted in the issuance of 1&E Report g, [.,.
.g During the latest inspection,
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4012, identified as Staff Exhibit Mo. 58.
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1 I',, - h Mr. Tapia reitewed the procedures used to perform the test ft11 progree,
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And Technical Reference Occument ' Test Program For Compaction o f Category M '. _.'.'" 3, >
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cd 1 Structural Backf t11" and the results of the program as document k
Mr. Tapia was' satisfied that the documentation Mttp's-responses.
derenstrated that the density of lower lifts is significantly increased i'
hy compaction of subsequent Iffts. This multiplying effect demons to Mr. Tapia that the requirement for a siniost of 8 passes af the As a W
, ;4 torpaction equipoent required before testing Ilfts was adequate.
3 practical matter, if the requisite density was not achieved'usfag the mintasa number of passes, additional passes with compaction equipment
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were made untti the required density was achieved prior to continufag y
Mr. Tapia also reviewed the interta report of the s
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tonstruction effort.
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empert comittee of Independent engi eers which conck'd that the
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Ilft produces conservative t
- testing of the upper portion of the underlying
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i Based on the above analysis. Mr. Tagla was satisfied that the p
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results.
Shes Cause Order requirenents'for R&P to address the[ test fill program r
used to establish in. place density testing criteria had been met and ".
I 1
closed this item.
I.
9
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Q. ' W1?% respect to' Shou Cause It. rs 2(b). did R&P eake a comparison e
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j of 'the c.aterials it tested,and described in Mction 2.5.4.8.3 of its FSAR -
.j in regard to liquefaction analysis to.those materials used and tested in.
H y
the field during the MRO special, investigation?
A.
Yes. In its response cf July 23. 1980 R &P found no ssaterial difference between the soll properties tested iniS74 and the soll a
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' q".P -
,, ;i properties found during the special bRC investigation.
N The change in
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' d Q. D ' 'k{J mini.wi and esasicum dry densities. noted in the hE special fd%), blc
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- y *.). 'A'R '=..y investt5ation. was due, acccrding to R&P'. to subtle changes in the m@y- ~
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gradation.an$ coefficient of uniformity wh':h occi:rred over the four yea t
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'l. /*. + $. ;. j -p construction history of the tackftll.
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3, In 1&E Report 80-24. KRO Inspector J. I. Tapia reports on the
.d,.
The NRC inspector enalysis he perforced to verify R&P's position.
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reviewed ELP's response and its resolution of the discrepancy and
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densities of materials used in,the design to those which were in place at
+
2
'. _ 4.1 The RRO inspector concluded that the apparent discrepancy was e
the site.
acceptable since the 80t relatt've density values had not shifted 0
i Aftee cocputation of significantly and this is the critical variable.
'.,)j this vetoe, which is used in the liquefaction analysts. a.18 pound E
difference results between the ', design 80t relative dry density and the l
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field 80t relative dry density was considered to be a negligible These figures, relative to the Itquefaction analysis
.dtfference.
performed for the design and presented in the FSAR are valid and As a result of this-applicable to the backf t11 asterial in place.
F;.
analysts. Ites 2(b) was closed.
[
Q. nitth respect to show tause iteas 2(c) and 2(d) was a review eade by Ht&P concerning the s'equence of construction precedures relative to the existing backfill. including the loose lift thickness and number of passes of equipoent; and if so,was the adequacy of that backft11 If saterial revtewed?
. l...
Yes. the adequacy of both the sequence of construction A.
procedu'res and the esisting backf t11 in place has been the subject of
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review by an independent review comittee and an expert's panet of 4/j
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engineers. MRC Inspector J.1. Tapia has been reviewing interfe reports
&' y '-(s.N 'f ;. '; '2 6
5 from these various groups and has found that the existing backftll ts
. V,.p*iy.* p ' " ;' t.;.
adequate. However, as of March 1980. the MRC was cuatting the results
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of the final analysts from these groups in order to evaluate and close
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out this natter.
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Q. nihat is the current status of the MRC's follow-up activity
(
relative to HttP's evaluation of existing backf tilt
\\y The kRC recently received the final report of the Independent A.
Review Committee and is currently evaluating the adequacy of that report.
.i pending the results of that analysis, the RAC will address this ite#s ta a
,)
subsequent 11E Report.
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. 40 Q. Did HLLP pro' vide a rationale behind the use of 14 inch loose
,1tf t thicknesses compacted by 8 passes of compaction equipment to achieve the required denstiles in response to Show Cause Iten 2(e)?
A.
Yes. In its response of July 28. 1980 E &P stated that design e
spectf tcations for Category I backft11 rely upon in-place density tests to assure adequate 11ft toegaction. The use of a caminst of 14 inch l'
.j loose itf ts and a sinteua of 8 passes over those loose'ltfts describe L
t N
According to ML&P in. process checks timed at achieving the end result.
M
.f vl, if. following' the in-process procedures the required densttles were not
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met. additional passes with compaction equipment would occur. la
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addition. due to the multiplying effect of cor$ acting one lift over y
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another. it is HLtP's position that the use of 18 inch loose lifts
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results in Category I structural backf t11 which conservatively satisfies 3..
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- Y the requisite densttles.
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e MRC Inspector J.1. Tapia reviewed the Infor=ation provided ky HL&PZ.,
.~ ;O g * * ~.n; >.,.sp'.4;n
- Q.J.,,j'[e
",i, >f a$p addressing the rationale behtad the use of 18 inch loose 1tfts compacted N.t.
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by 8 passes of equipment to achieve the required densttles during an g
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,ti.d' inspection which led to the issuance of !&E Report 80 24. Identiffed as
].l t
d Staff Exhibit No. 40. Lfpon reviewing all Applicant data and verifying 9
that a test fill program had been conducted in June.1980. and further N
based upon the explanation offered in response to Show Cause Itas 2(a).
...... ~ '
's
T NRC Inspector Tapta considered this matter closed.
.a
.."M I turn the panel's attention to Show Cause item 3. which
- * :g Q.
.s, dirtettd HL&P to review certain safety related work to determine whether
.',(;;l such work was properly performed. describe the extent of any necessa'ry
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repatrs and to set forth a schedule for coceletion of those needed
, repairs. Specifica11y. with respecttoshowCauseItem3(a),hasML&P performed a review of safety related welding including civil structural and piping?
A.
Yes. Brown & Root and MLLP formed a special task force review I
team to forzulate a comprehensive program to reassess and verify safety related welding at the South Texas Project la response to $how Cause Ites
.l.
.e e
i,.
No. 3(a). The task force was given the responsihtlity of identifying a v u
repair work that night be required and estabitshing a schedule for s -
completion of such work. In addition, a consulting firm was retained and t--',
,1 an independent review cornittee was formed to review and approve the
.1 programs and reports generated by the task force.
k.]
The review of nondestructive exactnation procedures (MDC) identified
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the need for improvement and HL&P has consattted to incorporating such, s
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inprovements into NDE procedures. Specifically. the task force identtfled irregularities in CE inspector qualifications. radiographed
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welds, procedares in identifying unacceptable welds, docunentation of h
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in process checks relating to Af$ welding were not properly documented.
3 J
s 4
procedural irregularittes identified in ASME welding. previously accepted EC'J pipe welds found to be unacceptable. and. as a result. all welding
'l processes were to be reassessed and corrections toplemented.
t o
. r' h a result of the special investigation resulting in !st Report
.j.
79 15. and the spectitt problems identified in safety rtiated welding.
'" #7 i
all such welding was halted by HL&P and Srt>at & Root in April.1980.
,.),j Pursuant to discussions between the NRC and ML&P. all safety related j.
I' welding was to be gradually restarted on a controlled basis in accordance 7.
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In accordance with
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with a step by step program of planned activities.
5
, $ hts plan. ASt! safety related production welding was restarted on 4 I 11mited basis on Neverter 24,1980. This welatng was expanded on January S. 1981, in accordance with a 10 week work plan submitted to the NRC.
The various as'pects of HL&P's safety related welding progree have been i
l
' under the periodic surveillance of the NRC. This natter will be closed j
out in an.1&E Report after the NRC assesses the results of this limited To date. It appears that ML&P has implemented the various wort effort.
. contattments it represented it would undertake in its July 28. 1980 I
This matter is scheduled to be
'j response to the NRC Show Cause Order.
addressed more fully in 1&E Report 8114, which has not yet been issued.
.4
- J (j
Is the NRC surveillance over Show Cause Itte 3(b) sandattag a
.'j s Q.
review of Hi&P's safety related concrete structures, including ewbedments such as supports and the fuel transfer tube,14 a sistlar review posture?
.r>
' i s ' r,
., ',, y In response to Show Cause Item No. 3(b). HLLP and Brown 4
( A.
=
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A.
Yes.
',/
. gr.,,
- p. j Root initiated a special task force to review and assess safety related (L
f*
- 0'.e'ja.
L This task farce was to concrete structures at the South Texas Project.
+'
deterntne whether safety related concrete sonstruction work. coepleted as 6
n.
of the date of the show Cause Order, was properly perforced so as to meet
.I [
In addition. as was the 1
all appitcable structural design requirements.
1
- i case with safety related welding. a consultant panel was gathered to
.l
. 2'4 assess the work of the task force in identifying t!.a problems and
- ..1 designing solutions. The task force proceeded in four phases; f'trst. a
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documentation rettew was perforced relattve to design and construction
'i s
documentst secondly, a review was to be made to determine the *as built *
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,I configuratics of safety related structures and to compare that to the *as I
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designed
- configuratf ons; next. a visual inspection was to be condu iand
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fn order to detemLtt whether there are potential structural defects lastly, a nwter of specific tests were to be performed on plant structures.
d
'I
~j As is the case with safety related welding, safety related c'on rete NRC.'and j
processes and structures are under periodic surveillance by the i) is still HL&P's corrective action in response to this $how Cause Iten
=
o
[ 3' 1
To date. the corrective action proposed by HL&P.
1 j
under evaluation.
is,' '
appears ad, equate and tr.plementation of that corrective action "1
- 13. 1981. the MRC authorized proceeding on a limited basis. On January f.
ce comencement of the limited resuretion of complex concrete
.I This' matter will be based upon comitnents made previously by Nt&P.
l2 l
addressed by the NRC at a tice when it has had an opportunity t r/
-3 tive action I
'c 1.,
e e-the final report recently sub=itted by HL1P concerning corrJc
$d1.' i.
,I at f2 j
1
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on cocales s% cratt activity.
Q. Turning the panePs attention to show Cause Ite.i No. 4.
d.E
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5 j. -e, t.
i' P <' '~. - = -
h cause Brown & Root to rescind a brochure entitled *!cplecentatio
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Brown & Root Quality Assurance Program at the South Texas Proje j
Site
- and the associated videotape following receipt of the Show
,r 5
Order of April 33.'19307 A. Yes.
Q. 01d HL&P cause the republication of a new QA program
~
dix B.
f reflect the fundamental philosophies of 10 C.F.2. Part 50. Appett l
4 and further. did it conduct secinars with construction and QC pers t.
.h on the contents of the brochure and its philosophfes?
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. 44 r
f Rest' dent Reactor Inspector. H. Shannon A.
Yes,on July 30. 1980 d d a seminar given by HL&P during which the new
,Phillips, atten e Resident Reactor Inspector.
pubitcation was distrhted and discussed.
d the Phillips also noted that the prior brochure had been rescladed an
'[
'lity assurance new pubitcation properly e W
- sited the necessity for qua I
t
)
, properly eghastzed the need for quality
}I The conclusion that the 6 l are to.
assurance was based upon the fact that quality assurance personne i d authority report to a canagement level such that they have the requ re dl to ' -
f.
)
and organizational freedos, inculding freedom from cost and sche u e.
onnel were Identify quality problems and verify solutions. All site pers t
N-These actions by HL&P were vertited by the Mt*
,3
- j distributed the brochure.
i l the matter is
.j. 1
- and documented in I E Report 80-18 and accord ng y L
.'I f74 considered corrected.
'.,' C' y% y. g'..
Q. With respect to Show Cause Ites Ro. S. has the Licensee de v
4 ise. includins g'
u,.
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.'d, ?f4pg(.. w Q. L more clearly the stop work authority, tenorary or otherw Tg
' v. i N
b.7,.f-t,e:wws..:xyr b.r.MO q ;t trolementation of that stop work authority?
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Yes. In its response to the' $how Cause Order dated July H [
..h.
f ;
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South 3,-
1980. HL&P more clearly defined the stop work authority at the n
E e ' ;*
1 I
7, o The HL&P project QA supervisor has the responsibility to 3
Inaddition. Brown &R5ot
" i-Texas Project.
assure that stop work orders are implemented.Authorization to l
3
].
r; quality control inspectors have authority to stop work.
.M 1
the Browe
. ~; (*!
f resume work sffected by a stop work order may only be given by
i.y,;
& Root project QA manager when al) responses, corrective action.
[.
if torily set.
recurrence controis and other requirements have been sat s ac
,*-A i
,. -.;;j 1
During an MRC inspection which resulted in the issuance of IE i
.. 31
- 3) 21 e iewed Report 80-27. Resident Reactor Inspector. H. Shannon Phillips, r v
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The resident reactor inspector reviewed the state this Show Cause Iten.
to the Show cause Order and determined that MLLP a'nd l
i
-of affairs pr or j
Brown & Root manuals authorized and required stop work orders be issued under cartain conditions; however, the lower tier of management and QC 1
inspect' ors were not adequately trained as to when they could exercise Additionally the procedures did not clearly describe such authority.
how quality control inspectors could exerct'se such stop work authority...
p The reactor inspector reviewed the revised procedures to assure $hou -
Cause'comitments were trolemented. In the new procedures stop work v.
s'
,h authority was clearly defined by giving all QC inspectors authority to Based upon this review this item is closed.
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~
stop work.
Q. What if anything. hat Hl.1P done to satisfy Show Cause Ites No.
p 6 which directed it to develop and trolement a more effective systes to i
. J, '. #
provide for the identification and correction of ' root causes' of the
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e.cnconformances which have occurred in the past?
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A.
HLhP. in its July 23. 1980. response analyzed the problem by 2
documenting nonconfomances.
7,', *. ~y
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'.: 1 breaking it into three separate elementst s
- r g,
- s - f *,,,'
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- _
.I analysing the documented nonconformances to identify underlying causes.
Under a ne' program quality w
and correcting the causes identitled.
F engineering util participate in construction planning and will deterstne
[
.],
inspection hold points for work. activities. Any nonconformance report i
.JJ requiring design evaluation will be fomrded try the quattty engineer to
]
This board will be an onstte cornittee a materials review board.
'.f consisting of senior representatives from Brown & Root quality assurance.
.3 The materials review board will be
- l:1 design engineering and construction.
responsible for providing disposttions to all nonconformance reports i
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. 46
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j In addition.*E&P.comitted to a trend
'V requiring design evaluation.
analysis systen to perfore reviews of nonconforming experiences to
[
4 prevent further stellar nonconformances by identifying and etteineting
(
l vaderlying causes of past incidents. prior to 731g and the Show Cause I s' Order. the tracking of nonconformances was done on an Informal basis and L'
r.
The revised.
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act as a required part of R &P's quality assurance program.
trend analysis progree was upgraded by providing a data analysis group, comprised of quality systems engineers responsible for identifying the -..
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methods to be used to collect data. the ways to categorize and monitor
.e.,
deficient conditions,and developing methods to report these findings to s
1 management.
.., 7:.'
This system was reviewed by Quality Assurance Engineer. John 411 ray.
b '*,.
~
of the NRC QuaMty Assurance tranch. and found to be adequate. However.
V.*.
this system can only be evaluated over time after reviewing its abfitty e
"ff, to flush out recurring probleas. This systers was the subject of an g?
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interte inspection performed in connection with lit Report 60-27 and thus i
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N ', 8 However, during this satt inspecti.on. K8P was 7.e v ' p=. 4 ',*w.
l 4 far found to be adequate.
4 1
- 4. c
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- "' ';..1T
- ,4. *d cited for an Ites of Noncoegliance la that it fatted to follow procedures c,
.: s 4
l,.
i is an which prevent the use of nonconforatng materials. Here agata. th s
..' (
p exagle where. in spite of adequate in. place procedures. MLLP has not followed such procedures.
Q. Has MLLP developed and implemented a sore effective systes to S,'
provide for the control of field changes ta order to assess the legact o Show Cause Itea No. ??
- :/
. the changes on the overall design, as mandated by
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- 47
- P Q. imy would the NRC require Oat such a system be developed?
E A.
Although viewed individually. field changes may seen l
insignificanti the cumulative,effect of field changes may is9act upon t's Accordingly.14L&P' seeded a system to
~
everall design of t>e structure.
['
verify that either individually or cusulatively field changes did not t
t l
adversely affs ct the overall design of the project.
[
P' esse state the systas implacented by 14 P to provide for such Q.
[
t controls.
t All design changes proposed at the South Texas site are
'I A.
This group subaltted to the project site engineering organization (PSE).
is to determine if they att to be referred to HL&P. bston Engineering.
Elther PSE or liouston Engineering evaluates the, 3
- 4.)
requested change and issues a design change notice. The prerequisites for disposition.
e c
for*the issuance of a design change nottee include documentation relative
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- ey,t.::.r, +,1:q to the reason for the change. justification for the change. engineering l(, fd,.
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evelvation of the change. And, assesscent of the effect of the change on
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- e r
plant design.
y:
As a further means of change by means of a corputerized tracking syst'em.
en'suring that the igact of the design change on the overall plant design has been assessed a change review board util be established within Brom
,J L Root engineering at Houston and the site with the primary function to O.
provide a mechanism to assure that proper 1sterdiscipline design reviews 7
, L6, have been conducted.
..)
The icplacentation of these cornitnents has been the subject of part l
4 of three 1&E Reportst 80-30. 80 36; and 81-05. Brown & Root issued
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f restsed procedures describing the new So4th Texas Project field design 1
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- 28. 1960
- change program which ic.1P had commt'tted itself to in its July
. response to the NRC Shw Cause Order. The NRC taspector reviewed i
procedures outlining that program in doceents entitledt " Field Changa Request /Tenporary Change Motice's ' Engineering Procedure For Processing
}
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Field Change Request *;
- Engineering Procedure For Design Change Contro1*n and ' Engineering Procedure for Change Review Board Activities'.' These procedures appeared to satisfy' the requirements of the Shw Cause Item; r
I however. full t= placentation of the procedures could not be reviewed at This l' ten F
l
- thattibeandwillbethesubject,of,subsequentinspections.
continues to be the subject of MRC surveillance; h wever, to date. the Appittant appears to be implementing adequately the connitments decced '
I.,
appropriate in response to Shw Cause Iten No. 7.
3 L
O. In response to Show Cause l' ten No. 8. has HL&P deve' loped and
'1, implemented a core effective systems of records control?
s.,.
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HL&P's response to Show Cause Itern No. 8. sistlar to its 4,
s
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?... ': -U te response to Show Cause Iten No. 7. apptars adequate, but its
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,f, gg _. M.;i ef fectiva..iss car.r.ot be juted vatil the RRC can evaluate its f,,].<8
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effectiveness after being teptemented.over a period of time.
f.5--
4 In an attempt to develop a more effective system of records control.
HL1P retained the assistance 'of Nuclear P >er Consultants. Inc.. and
[
A developed four cain objectives for the new system: (1) the records requirements for each construction activity be individually delineated; r
.~
9'4 (2) there should be a system capable of providing +rompt information t
concerning the status and location of relevant records; (3) as records
[
are created they should be controlled and protected to assure that the y
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recordedstatusandlocationremaincorrectandt(4)techniquesshou a the systers to assure that the other object'ives are met.
1pcorporated Whether or not these objectives were taplemented in a systes which ted more effectiv'ely controlled records has been reviewed and is documen 80-30, 80-36. and 81-05. ML&P and Brown & Root e
la three NRC,1&E Reportst have developed several new procedures and have revised existing Itee f
procedures in an attempt to icolement its cornit ent in show Cause
~
i Planning and As
.No. 8; including, procedures relative to " Inspect on i
j Butit Verification." " Records Control.* " Instructions for Recor g,
l Control.". "QA Document Administration for the Q
. 'I i
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t i
To date, the RK inspectors implement the corrittants outlined above.
a' i f ing have been satisfied that HL&P has made reasonable progress in sat s y
),
the comittsents it made in response to Show Cause item No. 8. However.
j by the nature of the comitments implementation can only be vertfle Accordingly. the NRC
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evaluation over a reasonable period of time.
g! y. ;_,* s l. -$.
."$..,'.s 2M i fied with its Ne -
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- continues to cenitor this lits and, to date, is sat s
(+!
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7.
Septementetica.
. agi.
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Q. In response to Show Cause item No. 9. has HL&P developed an
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. e
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v; tripleoented an teproved audit systen?
a Ye:, arty response to this Show Cause Item sust be viewed in the 1
t A.
- 14. 184. 183. 18c.
context of HL1P's response to Iters of Moncompliance i
HLLP's response to the above named Itecs of Moncoegliance sets
.i and 19
.y forth the nature of the revised audit prograts and the NRC response to
\\,
U i in this 1'
]
that program ts set forth in the 1&E Reports identified earl er 1
liance.
]
testicorty in the context of discussing those ite'ns of noncomp l
However in reference to the $how Cause Item, the NRC is particular i
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50 To interested in how effectively E 1P has implemented its audit program.
d and v111
- date, the approved audit program has been adequately tep1emente continue to be monitored on a periodic' basis.
Theeffectivenessoftheirauditprogramsdependson(1)indepth e
auditing to assure the entire C& program is effectively teplemented. (2) high level managecent involvement to assure that the program is a vital i
comunication link to actual CA program implementation and the auditors
'..c observations relative to construction work activity. (3) high level i
management involvement when ic; asses occur between the audit organfration s
i
{
and the audited organization. (4) performing supplemental audits when suspected safety, perfor=ance or r 11att11ty perforeance or r:11ab111ty of an item is in jeopardy due to deficiencies and nonconformances with f'
respect to the organizations QA program and when necessary to verify y,
correctiveaction,and(5)maintaininganadequateauditstaffto r
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adequately perfuro the HL&P and SLR audit functions.
4,.,.;
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- I ! e,2[","f '),',,, p so date tu a;;reval audit program has been adecuately teptemented
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and corrattnents are almost completaly isolecented relative to audit l
y system improve':ents. however, the NRC will continue to monitor audit
' I systems as part of its inspection effort.
In response to Show Cause Iten No. 10. has HLLP verified or Q.
corrected the T$AA statements contained in Section 2.5.4. Stability of I
Subsurface Materials especially Section 2.5.4.5. Excavation and Backfilif
.l l'
Yes. HL&P amended these sections in f5AA Amendment 12. this A.
l' l
matter has previously been more fully discussed in this testimony in the
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content of items of Koncocpliance Nos. 2 and 3.
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Q. Aside from the Items of Moncoa911ance and Sho=# Cause Items just
- addressed, were other infractions or potential infractions identified in 79-19?
Due to the broad scope of 79-19 various cetters which A.
Yes.
were potential infractions were left unresolved to be addressed by Region
!Y in the course of its follow-up activities. Thirty (30) unresolved itemswereidentifiedandseven(7)openallegationswereleftfor subsequent investigation.
L e
)
Q. What is the current status of these metters?
26 of the unresolved items and all of'the open allegations have 1
A.
been addressed and closed; a list of the IK Reports which contain the i
{
NRC findings and conclusions on each of these matters is attached to this L
G.
testimony as Appendiz 3.
g; Q. Is there any other means of identifying evaluating and
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,s l
resolving possible construction deficiencies?
,-; 4 f i y,-
>{t f-r As required by 10 C.F.R. I 50.55(t)(1). a holder of a A.
Yes.
- 9.. I d.g. t,y,,.{
construction permit is under a duty to notify the NRC of each defletency
[
, 4
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~
found in destga and construction which, were it to remain uncorrected.
could adversely affect the safety of operations.
i l
The permit holder is under a duty to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> L
of discovering each reportable deficiency and must submit a report of the
.t matterwithinthirty(30) days. The report east include a description of r
jh the deficiency, an analysts of the safety implications and the correctfve j
actfon taken. If suffittent information is not available for a N
definitive report within thirty (30) days, an interia report must be q
filed.
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(1)
The history of HL&P's reporting pursuant to 10 C.F.R 5 50.55(
I "for the South Tesas project is attached to this testinov as App t
a
- 4. Sased upon the NRC f aspections and investigations set fo l ce at above. is there reasonable assurance that the structures nas in p a i
rmits and the South Texas project are in conformity with construct on pe I
4 lt the panel's f.
the provisions of Commission regulations? please exp a e
~~
~
b i
Yes. The report by the special inspection team (79-19) answer.
A.
leted 3
concluded there were no major safety related problems with the co structures or systems. Upon review of that report. HL&P's vario 1
t and the a
responses to the enforcement actions resulting from that repor i
' d..
is concluded NRC's inspections both before and subsequent to 79-19. it d
C l ted structures e
. n there are no cafor safety related problees with the comp e
- Uj
't MRC inspections should. assure the
,s y A
't or physical systems. The onsein9 L
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- f..a/ e, %**v,:.,7 e, continued adequacy of construction.
(
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- 4. Baseo upon the MAC inspecticns and investigations se
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7 above. Is there reasonable assurance that the current QA/C". p
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n
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ith e
" 9 be taplemented so that construction can be completed in conf
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the construction peretts and appitcable NRC regulations
}
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$' ?
A ld Yes. HL&P's corrective actions, as previously outilned, shou
'a 4
.j In addition, ongoing NR; A.
'G assure implementation of the QA/QC program.
k tive faspections should assure the can'ttnuing appittation of the co
'r e
'.m,'~.,
79-19.
f.,
i actions tat'en following the enforcement action accompanying
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51
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APPDtDII A o
Items of floncorgitance Since
{
Show Cause Order t
~
General Description of Inspection ~
Item of Moncomo11ance_
accert __.
M Insoectors_
Failure to provide tisely notice of 80-01 Dec 1979 H. 3. Phillips o construction deficiency Failure to follow test procedures Jan. Feb 1980 80-05 Mar 1980 H. 3. Phillips f* allure to provide timely reply i
9 to the tran,smittal Jetter for an l
~~
item of nonconglfance 3
J..a Tallure to provide timely notification of a construction
' 'J deficiency I
6
-.]
Fatture to provide a timely written report for a construction deficiency a
i 80-07 Apr 8-11. 1980 W. 8. Hubacek Failure to follow procedure for
. s.'.
. storage of material
.. a
'i.'
'e Failure to develop appropriate 7,,,..
H. S. Phillips f
b O
80 18 Jul 1930 procedures to assure traceability.
fQ h*.- [#, -.[,7. ' f * *,% r, W i s ! ceJ of e d ed materini s,
- rp[ /
Failure to assure that purchased I
- g*
b material confomed to procure-
'e ment documents 2
e i
Failure to respond to BWt
..~
audit findings v.
Failure to follow procedures 80-27 Oct 1980 H. S. Phillips which prevent the use of non-5 conforming materials 4
.. i j
- TJ Failure to follow procedures for
.F 81-01 Jan 1981 H. 3. Phillips storage and maintenance of equip-ment
. a.
J
- .1
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r
'q i
1 i
3
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a
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~
- a,..*
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-3,x.c
- m I
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GM 0 s 0.*
?E
- 2il 3.
3
,..~*i'..
- a. -L - ll
..N.Wi.F.bNfMh$9.jdaN Wa's-'$5E*AN W 2"'E d =* h " W "' *.
1.
l
__ L.--
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d'"~'"~
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3 t
APPENDit_t Disposition of thresolved item and '
Cpen All~ehTtTont r
/
~
1.
tMts01.Vto ITC4 t
~*.
'q i
8 Report / Status l
.73 19 79-19 M
40-18/ Closed Report Pege Tracking t
No 5eci en
.Ltcensee is correcting discrepancy L.
I
' No.
fevnd in trece6biljty of embedded 24 t.1.a 79 29 01 Allegetfen 12
.seet plates..:
81-01/ Closed b
a i
Licensee is correcting prette.e R
,'fou d la the.resolutten of old MC s *
' 35' J
E.1.6 n
.en Storage /Mataten. 8 79-19-02 Allegation 10A 80-30/ Closed t k
~
t
.Need for addittenal contre s s
.' preceeures addressfag propewe.
51 t.2.a
.23 13-09 constr.,curingofconc.
80-24/ Closed
{
i Reteeck on come. ' transit trucktit w/o agitatten i
M 54
,%4 a
' I>
71 13-12 E.2.t.
' Standing er.in-trant 80-24/C10 sed
- l'
. :h
. en comp!sted Final inspectionspt.cesents not edegyately centretted
$7
.i. d 4
73-13 13
. and up to date E.2.c.
e g
..y
'Open
~]
facof f ag of pwapN concrete and the 1
54 lack of terrelatten peogras go.30/C1csed
+E 2 J
f.2.c.
Conf 1tet of personnel quallf t:stles pm,[.y
.)'
b f.,,....,'
79 13 14 e
reg'ta for concrsta placement (Amst fk
(-
}
54
. j,i..i,'tir. O'.4 Aq-73 13-15 4104/C7esed E.2.c.
' [- i'Q *4 f
. w 4
d - 4:.-~
4
, '.. i
- 4. J.,)
w Weed fee systematte program toensure thgt traisin g f n'
- .- f
'-l-
< f:*$,'. 4 s.**,
k AhN]
en spec /prec. rows.
80 24/C1csed E.2.c.
79 11-17
- ,4.
e Coecactten of wpper part of lastIf ft which may re
'J r
I
'.s 3 63 L 3 b.
79 11-11 blogs; SLR literature..
go.24/ Closed tetest till section compteted withencessive num
,k '
f 43 l
79-19-20
- t.3.b.
roll overles t
r Open of fill lif ts vs. locat'**
/ v,.*
in order to reconstruct fill records 61 E.3.d.
placement procedu e lacking
?? 19 23 r
3103/ Closed Decrease la relative density (bulking) of compac
' 64
,t.
E. 3. e.
'73*13-25 state under v14re,tten s
l e.
j l'
+
q
.]y
.1
~. a, {
t W.
L i
.g
... 3 n
i
..r e,.
u a
a
..M.*
-w v ;.
=
y m,
L00193 0.2 O i.Jjd E.1 p':t.fi
n -
_:. _ - =
. r.a..
_ w~.. a w -
QGsh a
- 2 '*
f[
[
~
Sepect/ Status _
A Tracting report p.ge
[ubjec3 sto t
80 24/ Closed-S c,tlen Discrepancies in sin-san relative 9%
E.3.e.
66 densities of saterials weed vs.
73 19 26- -
raported is 1A4 for liquefactlen 80 24/ Closed i
Atteopt to correlate Std Penetration 79 19-29 t.3.f.
67
- alues to these from everstaed, t-blunt spoon & nonceafersing hammer 80-24/ Closed teeing 2ce, leese mat'l near base of ind. sat of SCS Unit 2
- Aug. '77 75 11 30 E.3.f.
67 washout area 80-24/ Closed Details of welder quellf fcation i
- 69 2'.
?$-19-31 E.4.t.
procedures
- werk stoppage; root
,1 gap & backing ring in question i,.
f Open Altgreent procedures en 5. Cea. B&C
. 'p:
73-11 35 t.4.c.(3)(a) 73 and Code stamp on f ewer 5. Cen, t
'"fJ supports considered now as b1dg.
80 28/C1csed No Code inspection by ANI en weld
.';g
^I
's now eetedded ia concrete on the twel 73 fj 0 73-13-36 t,4.c.(3)(b)
.e
.d.f ?l tran.. tone 4
Open g
Control of attacheents on esterial n
'-',g 4,,..
post-weld heat treat. - tower SG
%c mm 71-19-37 E.4.c.(3)(c) 74
-T.,.f.d' ? %.., tyf. '/g A 80-24/ Closed
[5J supports & ethers
?
U; '.
3 Test reports of Ilevfd penetraat
'-?*-
85 examination Nt stef aHrod end
, 4:
- p
- jy ',
'1'
- 's j',
71*H*e4 E.3.a.(2) 76
% ',J4 b'.
documentation of esaminatier.s inadet.
- } ;=~. r '. O
. I' e
i n5-4
.,(
80-24/ Closed We training for QC personnel f a lig.
pene, by fleurescent nat*13,
(
79-11-a2 t.5.c.
83
~
processing & reading radiographs.
F cfsual AVS, recordkeeping 80 27/ Closed Procedure for NCRs lacks processing, 48 71 13 43 E.7.a.
approvals, feegback & records retention details
.e '
si eutiesed
.e.,.,et d-u.eniati. 0ei..d
, w..
wit,e cei,i.,g dou.e.t.ti sf,
7,.n.o E.1.c.
..,'..?
',.q;,
some v.endert 80 27/ Closed
..-c3 No procedures for trending fatAs and revle.tng cumviative impact et all.
.,i '
71 19-45 t.7.c.
93 e
changes
' ic j'
i
- .A.
.. 3) q
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a
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4 J.
'd e, d v..
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, 'd i
e I g
e y
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w as=====
l.
W133p
- 6. ' (*>. ',J U O. E.".9.
l 'ej i
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...:_a'_
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_ afc. u : *..
.,~ r u - a u _- ~
o t**
2Od 3-l 1
k.
Tracting Seport.
Page Report / Status Section We, g
80-27/Clostd y
Unsatisfattery condittees fewad
)
75 11-46 E.7.c.
94 durlag ECs not being documented 81-04/ Closed C
Adult requirements of A8t$1 M5.2.12 F
79-19 49 E.8.c.
96 not part of the PQM contract f
80-25/ Closed V.
avoit R&t-27 fe11w not doewented 71 19 51 E.8.d.(3) 101 and precedure te require this (4 i
general is being writtee 80 27/ Closed 848 Question of whether at 71 l'S' 52 ~ t. 8.'d. ( 3 ) ~ 101 procedures have been audited by 044
~
Cesign Centeel not audited Mouston.
{n 1978 80 27/ Closed Inadetwate ressenses to survel11ance L
71 19-54 E.9.6.(2) 105 findlags in that bases for closeewt
?
-U..i lacking 80-30/ Closed
.i
- eselwif sn of =by spec was revised i
.. 1 71 19 58 E. 3. a.
41 from 12 to 18* Ittts that was
~ ic'I cow ter to the SLR cog, enge.
n L'
- ~j
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t s.\\p
(;
L
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- .-f.7.1, i;'
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giL1 AttfC47 tog Report /$ tat'n Tracting
- R. port Pt.ge Section No.
Mjd 81-01/Clesed No,._
vertical cracts la structural steal c11ps in t.ha heron lajectlen reos of 71-11 04 f.1.6.
31 a
Alica,atles 12A RCS Unit 1 ti. 34' Sl@ Closed Pipe sleeve weld defect 1/4" Jeep at f
44 A4. 300*, E1. 8' la RCS Unit 1 near o
11 11 05 f.1.6.
j Allegatfoe 11A work par.el 15 81-01/Ciosed Classificattee of contalnaent retar i
i t.1. 6.
41 11 11 C6, Allegatlea 14A 81-01/ Closed crane I
Storage of elec./ mech peretrattens r,
.I 21-11-07 f.1.6.
'42
.1 and lack of understandtag by sarshouse electef clans of Megger r.
f
't tests on poters IC 38/ Closed
(
turing of the coac. (atake strweture
...d 71 11 56 f.1.6.
43 on i.hich an NCR was weltten
.4
,Allegaties 164 80-24/ Closed NRC told of eelds te concrete with ne p
,J 44 71-11 57 f.1.D.
definite closeewt er resetuttee 5
. ']~f 80-33/C1csed N
Allegatfea 17A i
71-19-51 C.I.b.
46 Misstag 3 herf t. esbars c
r
- i. ? - ' \\
r Allegation 114 r. j.-
4
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APPENDII C l
SOUTH TEXA5 PR(k1ECT j
)
t.
- ~
__50.55fel ITfMS _
s I ;
)
r y
r lJ']
-Intttal Interim
- Final
[
Report
" Report._, M-e t.es r.
Tftli f
02/10/77 02/14/77 02/17/77 l
P f
1, Cracks la fuel hand 11ag butiding wsII 04/26/77 l 05/26/77 05/17/77 N
- 2. We1J defects in Category I structural steel (American Bridge)
I 07/38/77 08/17/77 09/30/77 4
1 Relaforcing steel facerrectly positiones in containment sheet wall 08/29/77
(
o I.
3 06/24/77 buttress 06/15/77 6
Weld fabrication of 16 steel entLednents (Bostros Bergen),
10/05/77..,, 11/03/77 11/11/77 i
4,
- 5. Weld defects in Steam generator and reactor pressure vessel supports s
03/15/78 04/14/78 09/18/78 V
Unconsolidated concrete la the thf t 1 fuel handitag batiding 10/19/78 07/28/18 6,
m[;.
- 7. High-pressure safety injectlen pugs failed to meet specificatfee 9
requirements during performance testing 30/04/78 10/31/78 10/29/79 r.
s, Dimensional error le the base slab of the Unit 2 sechaafcal-
[~
g i.1 04/24/79 4
10/25/78 12/27/78 06/05/79 electrical ausillary building
/
l.
Deficient bene to column connections in Unit I reacter contafament 9.
building 09/24/80 09/30/80 I
i (This Itee was reopened based as further evalsation by Brown & Root) 10/24/80
'1 0 7/30/79 10/27/78 I
'[
01/18/79 L
Understre threads on anchor belts 10.
11/03/78 g
f,~ l 4
@l
- 11. Clay ramp in backffli 10/20/78 11/20/78 06/05/79 Cs y
s 02/05/79 03/08/79 01/28/80 Q
I Unit I containment butiding volds (in If(415)
' 1,'
.T 12.
4
.L-N.s 06/05/19 Anchor bolts fabricated of f acorrect material 9
ri 12/31/19 i
13.
p yf e,-
r
'~~
,y l',
1-y.-
r 4
h 4.'
L.'
k.....'
.1.;a..
- ..'/f.y,;f; m.
,.;. :<e
.e
-L;;r; L.
- --~- - ~ _. w -
', ~.r
, ; y,.~
e 3
.t*,.
p
=
. ' r. _. f+li ',
%y 4-
- 7.v d. f -..
y er-t, r M Adc/ 1 eJ- ',. U. *-
o.
y j.
e b
e 2
t t.
I,.
s Initte!
laterls
- Final i
e.q peport Report.
peport Tltie.
1 05/16/79 06/15/79 10/09/79 t
Essential coolin9 water intake structure fantry crane was not
-i 14.
designed to withstand des 19e bests tornado wind loadin9s 06/18/79 07/16/79 02/18/08
- 15. Selds in lift S of the lhtt 1 containment buildfe?
08/15/79 i
' '.h 10/25/79. 11/21/79 05/30/80 Inadequate support of safety injection systes costalanent emergency 03/19/M
~
[-
16.
suno pipin9 01/04/80 a.
12/04/79 I
Failure of aroun & Root vendor surveillance program to detect a 6,.
s problem 14 the Q4 program of a Category I siscellaneous steel 17.
suppiter (inadequate certf fication hmts for Gostron Bergee r,
i melders)
' 03/21/80 02/27/81 02/04/88
- ~.
monconforslag backft11 meterial (loe blow count) around thf t 2. *
- 09/23/80 05/30/80 4
18.
[-
power block a
12/12/80 m,-f J 8 g'
i
~
thtt 2 reacter contalanent 1tner bu19e 02/07/80 03/24/80 8
.i 06/06/80 p
' 19.
07/11/80 3 :M'9 09/25/80
- f 03/03/81 L
i i
03/12/00 04/10/80 Rejectable ladicattens in radfegraphs of girth welds in the essential i
06/13/80
(
l of 20.
l coolin9 water systes pipe 09/12/80 12/12/80
' O.*
04/09/80 i.
J.-
.1 i
03/12/80 l
M ic Solds is concrete under crossover leg estednents - tinit 1 w
'4 21.
c.
[04 Co -
l:
- u-8 l'
It0
- ~
hO
- A f
4 I
I n.
- -,,., r
.7 a
7 7-3:, -
2
~ ~ ;" '. c w 3-*
,,, ; -.. ; r -..;- (,
- m..
- 3_ a
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j
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-... Y.'s
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w
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....d..%4 '[d,1'g o+
-.9 R.-f;U V,...',,.
- w t%> -
s a., ;-.i u
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er s sg )E@n.,'
o
.c y
1-3, y rT.! 's.
r, 7. y ~.
.c. $..
.,' Q a J. :.
c '.
1 3 2,,[.2 h'.
-g.
n.:,.,h:
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1 e
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2 V
1 I
f
'.1 Initial Interte
, Final
[
y Title _
Report Report Report
.j g
qf 03/20/80 04/16/80 l
- 22. Fallure of polar crane clip stud welds 06/23/80
/
i
.*a i
s'd 08/01/80 Og/15/80 i
I.-
f; 11/25/80
,I
- t. ~
04/25/80 03/28/80
.N
- 23. Stigit plereaneter readings in the essentf 41 cooling pond 03/27/80 4
- 24. Potentist for reduced coollag with failure in the steam generator 03/26/80 4
blowdown systen k.
05/02/00 I
q 04/03/80 l
- 25. Linear Indication in inconel bead on cold leg of limit I steam I
rc
,,j generator 04/10/80 04/11/00 05/07/90 I
U i
- 26. Unqualtfled noter operator for turbine driven avullf ary feeesater' p
pump valves l
r 04/11/80 05/15/80
(
- 27. Step work en safety-related and code welding 08/13/80 c,
l M
's 4
11/25/80 I
h3 j
05/29/80 06/26/80
- 28. Essential cooling water gantry crane setsele analysis 10/01/80 m
i-
~
07/03/e0 l-I aractor sessel outlet mente safe ends 06/03/80 4
29,
.O f, 06/04/80 07/03/00 09/04/80 Breatomne in 04 pewgree for concrete placement Cl! - Wee (tanf t I 08/01/80
.t 30.
- Of Secondary shield wall)
~
b' 07/03/00 Escessive lift thickness of concrete placement OG1 it3A (diesel 06/05/80 d
31.
i-
-.u ;
generator building)
M
'fDi 06/11/a0 07/14/a0 Breakdome to the quality prograts - procurement cycle of purchased 09/12/80 C
.G 32.
YJ!
satorials 10/31/80 C;)
~,
of 1s 1
F g.y.
=..; g. _
n,
, ; e -..-. =-
3
.sss r
3.t. ;
v.
b I
(
(
l.
3(
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i
-g -
'. (_*}-.c, hr,",* *.
.i h t
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~
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[
- b I
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Inttlel Interte final Title
!cpor1.
accort
, Report
(.
- c Itatorial centre) of structural steel belts 06/17/80 07/17/80 l
33.
08/22/83 f.
i 09/23/80 p
?
11/05/80 j
A 01/20/81 I.
i Y,
34 Mlatows/mostuun sell density tests en essential coellog water pipe-06/20/05 07/17/80
[
09/23/80 j,
[
line backftll material 06/20/80 07/10/80 09/03/80
?
l
- 35. Diesel generator fuel ell tank rose exhaust fans
- ~
2 I
- 36. Lineal indicattens in prevleusly accepted pfplag welds 06/25/80 ' 07/24/80 09/23/80 12/12/00 E
- 37. Use of AISI 1035 meterial in fabefcetten of ILPS piping supports 07/03/s0 07/31/m'
?
t 87/03/80 08/01/80 12/11/80 3s. Essential coeltag water pump seat water infectfen system 10/16/80 l.
t 87/31/08 08/28/88 03/05/88
['
3g. Inspectlen of stud welds en concrete embedmonts 10/08/80 b
'l
. S 12/17/88
[
t w-06/05/88 88/05/88
- 40. Centainment ges analysis system (CIM5tP) overpresseriratfee i
F l
.i 09/17/a0 i
00/22/80 41 Verticality of the spent fuel storage rects
[.
08/25/88 eg/la/as 1
b
- 42. Meter-pump shaft failure in Cats!p contalement hydrogee asaltering n
~
system I
Of 08/25/M 09/24/00 g
Environmental guellficattaa of e'lectrical equipment for sentilary 41/09/81 i
h 43.
wl i
ree&sater pumps 09/2g/00 CD I'
l 89/95/M m,
Inappilcable reference to A$st code case N-182 for Class 1 b
44.
2 i
IM
~
ra-pamant supports i
h
-o.
a 9
^
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<*"T' r 7 T..'%'-
'" ~*
,-,v
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- 4
?,f 6-
- s
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P