ML20211F514
ML20211F514 | |
Person / Time | |
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Site: | South Texas ![]() |
Issue date: | 02/20/1980 |
From: | Seidle W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | Eric Turner HOUSTON LIGHTING & POWER CO. |
Shared Package | |
ML20150F241 | List:
|
References | |
FOIA-85-378 ST-AE-HL-601, NUDOCS 8610310187 | |
Download: ML20211F514 (16) | |
See also: IR 05000498/1978014
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Q 431 ' .. u &* UNITED 5TATES / u%, NUCLEAR REGULATORY COMMISSION [ -p g REGION IV
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*; e 611 RYAN PLAZA DRIVE. SUITE 1000 *
j Q. ARLINGTON. TEXAS 76012
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%, o.b' ..+ February 20, 1980 In Reply Refer To: RIV ST-AE-HL-601 Docket No. 50-498/Rpt. 79-14 SFN: C-0570 50-499/Rpt. 79-14 Bouston Lighting and Power Company ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and Technical Services Post Office Box 1700 Bouston, Texas 77001 Gentlemen: Thank you for your letters of November 16, 1979, and January 25, 1980, in response to our letters dated October 16, 1979, and January 11, 1980. We have no further questions at this time and will review your corrective cetion during a future inspection. Sincerely, J '_ -lL ' W.C.Seif1h, Chief Reactor Cohitruction and Engineering Support Branch gECEWED g 2219B0 s.6.M 8610310187 860930 PDR FOIA GARDE 85-378 PDR . . . . . . . . _ . _ . RECEIVED : i FEB 291980 - , , ' .5OUTH TEXAS PROJECT ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ j
f - - . . - - . . . . . . . . . . . . . . ]' . ' ..f- o p *8 coq'o 5f UNITED STATES Lg 432 j ;g, j NUCLEAR REGULATORY COMMISSION , l ' =\ /go REGloN IV Is 'i o 611 RY AN PLAZA DRIVE. SUITE 1000 ARLINGTON, TEXAS 76012 , b [ , o a % ,,,,, / January 10, 1980 Is Reply Refer To XIV Decket No. 50-498/Rpt. 79-22 50-499/Rpt. 79-22 .S ptCEWen - ' z_ p- _g'M[ 'g) A Y Houston Lighting and Power Company iE2 E.A g dP . ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and - Technical Services ' - - Post Office Box 1700 "' ' Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by Mr. W. G. Hubacek of our staff during the period December 11-14, 1979, of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for South Texas Project, Units 1 and 2, and to the discussion of our findings with Mr. L. D. Wilson and other members of your staff at the conclusion of the inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. Within the scope of the inspection, no items of noncompliance were identified. Two new unresolved items are identified in paragraphs 3 and 4 of the enclosed
1 report.
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
l enclosed inspection report will be placed in the NRC's Public Document Room.
If the 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 public disclosure. The application must include a full state- ment of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document
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Room. If we do not hear from you in this regard within the -specifierper'fod,-~~'~~"" the report will be placed in the Public Document Room. '5 . ' ' p'"* h ' '} i -- .. .. . - -, @ . l . .
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( , {} 433 ' Houston Lighting and Power Company 2 January 10, 1980 Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, M N W.C.Seidh, Chief Reactor CoMtruction and Engineering Support Branch Enclosure: IE Inspection Report No. 50-498/79-22 50-499/79-22 . ,_ _ . _ _ _ _ - _ - _ . _ - . _ _ - - _ _ . _ _ - _ - _ _ _ - - . . _ . _ - _ - - _ _ _ _
I.. . ( . * , . 1 \ ![) . U. S. NUCLEAR REGULATORY COMMISSION 434 g 0FFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-498/79-22; 50-499/79-22 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda, Texas Inspection conducted: December 11-14, 1979 Inspector: %= - /[9h W. G. Hubacek, Reactor Inspector, Projects Section ' Da te Approved: / ~ : //9/80 W. A. Crossman, Chief, Projects Section 'Date Inspection Summary: Inspection on December 11-14, 1979 (Report No. 50-498/79-22; 50-499/79-22) Areas Inspected: Unannounced inspection of construction activities including: HVAC activities; ASME Certificates of Authorization; review of licensee action on previous inspection findings; and observation of work related to concrete placement for Unit 1. The inspection involved twenty-nine inspector-hours by
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one NRC inspector.
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Results: No items of noncompliance or deviations were identified.
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K ' :- * . . , \ r. * O 435 DETAILS 1 , 1. Persons Contacted Principal Licensee Employees ' T. D. Stanley, Project QA Supervisor *L. D. Wilson, Site QA Supervisor *L. K. English, Site Manager *D. G. Long, QA Lead Engineer T. G. Jordan, QA Lead Engineer J. B. Anderson, QA Specialist J. W. Soward, QA Specialist B. R. Schulte, Junior Engineer D. W. Bohner, Lead QA Specialist *M. S. Monteith, QA Specialist Other Personnel *R. R. Gunter, Assistant QA Manager, Brown & Root (B&R) *J. M. Salvitti, Assistant Construction Project Manager, B&R *L. E. Tolley, Construction Chief Engineer, B&R W. W. Scales, Chief Systems Engineer, B&R G. T. Warnick, Site QA Manager, B&R B. N. Kesarinath, Area Chief Engineer - Reactor 1 & 2, B&R The IE inspector also interviewed other licensee and contractor employees including members of QA/QC and engineering staffs. * denotes those attending the exit interview. 2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-498/79-13; 50-499/79-13): Bowen QA Manual Statement Regarding Level II Examiner. The IE inspector was informed that the Bowen QA manual statement that nondestructive testing pro- cedures shall be prepared and approved by a " Level II Examiner" contained a typographical error and the current revision of the QA manual has been corrected to read " Level III Examiner." This correction
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was contained in Revision 1 dated October 2, 1979. This matter is considered resolved. 3. Site Tour The IE inspector walked through various areas of the site to observe construction activities and to inspect househeeping and equipment
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"' . .. . rC t ' .. p 438 j, During the tour through the Unit 1 Mechanical / Electrical Auxiliary , * Building (MEAB-1), the IE inspector observed that Centrifugal Charging ' Pump 1A and its associated electric motor (PPM 1601-16) were heavily coated with dust from sandblasting activities which had occurred in the vicinity of the pump. It was noted that the dust had apparently infil- trated through the Kelly Klosure which enclosed the pump and a plastic sheet which was draped over the pump. It was also observed that the dust had entered a mechanical coupling between the pump and its electric motor. The coupling was separated in accordance with instructions con- tained on for the pump.the Equipment Storage and Maintenance Instruction (ESMI) card The IE inspector was informed that the above storage conditions had been ' identified by a Brown & Root QC inspector and the IE inspector was pro- vided a copy of an ESMI verification report dated November 29, 1979, which documented QC's findings. A licensee representative stated that immediate ster would be taken to correct the inadequate storage conditions. The IE inspector expressed concern regarding the adequacy of protection of stored equipment from dust and grit resulting from sandblasting acti- vities. This matter is considered unresolved pending completion of corrective actions review by in IE. response to the ESMI verification report and subsequent 4. Heating Ventilating and Air Conditioning (HVAC) The IE inspector was informed by licensee representatives that Bowen Industries Incorporated (Bowen) has not begun safety-related work on HVAC systems for the South Texas Project. A date for commencemest of safety-related work was not available. A licensee representative also stated that the Bowen QA manual and implementing procedures would be issued and approved and that personnel would receive indoctrination and related training in QA manual requirements prior to the start %f safety- activities. The IE inspector observed storage conditions of six Reactor Containment Fan Cooler (RCFC) fans which were located in Kelly Klosure "A". It was noted that the ESMI cards for RCFC fans specified that a level B storage environment was required. The IE inspector observed that Kelly Klosure
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during wasthe unheated and the roof leaked during a light rain which was falling inspection. structure. Workmen were observed to be making repairs to the During discussions of the storage conditions with a Brown & Root repre- sentative, the IE inspector was informed that work to upgrade Kelly Klosure "A" had been initiated prior to the NRC inspection and that heaters for the structure were on order. This matter is considered unresolved and will be followed during subsequent IE inspections. 3
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L ' , 5. ASME Certification \ \ The IE inspector was informed that the effective ASME codes for the South Texas Project are the Section III, Division 1, 1974 edition, in- cluding the Winter 1975 addenda for piping systems, and Section III, Division 2, Trial Use Copy, 1973, including addenda 1 through 6, for the containment liners. The IE inspector observed that Houston Lighting and Power Company has been issued Certificates of Authorization No. N-1656 and N-1657 to complete form N-3 for STP Units 1 and 2. Brown & Root has been issued the following ASME Certificates of Author- ization: , N-1270 authorizing use of the N symbol for construction of Section III, Division 1 items for which overall responsibility is retained and for I which fabrication and installation for Section III Division 1 items are I subcontracted to the appropriate Certificate of Authorization holders. N-2221 authorizing use of the N symbol for field construction of Class 1, 2, 3 and MC vessels; Class 1, 2, 3 fluid conditioning devices and piping systems and Class 2 and 3 storage tanks at various field sites, subject to site audit. N-2221-1 authorizing use of the N symbol for field construction of Class 1, 2, 3 and HC vessels; Class 1, 2 and 3 fluid conditioning devices and piping systems and Class 2 and 3 storage tanks at the South Texas Project, Units 1 and 2. N-2222 authorizing use of the NA symbol for the joining of stamped items to other stamped items of material for Class 1, 2, 3 and CS construction at various field sites subject to audits.
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4 N-2222-1 authorizing use of the NA symbol for installation of Class 1,
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2 and 3 components, parts appurtenances, piping assemblies and component supports and Class CS core support structures at the South Texas Pro- j ject, Units 1 and 2.
, ' N-2223 authorizing using of the NPT symbol for field fabrication of
Class 1, 2 and 3 component parts and appurtenances, piping subassemblies, component supports and tubular products welded with filler metal and { i Class CS core support structures at various field sites, subject to site audit. ! N-2223-1 authorizing use of the NPT symbol for field fabrication of Class 1, 2 and 3 components, parts and appurtenances, piping sub- assemblies, component supports and tubular products welded with filler metal and Class CS core support structure parts at the South Texas Project, Units I and 2. No items of noncompliance or deviations were identified. 4 ~ . _ - . _ _ _ - - - - _ - _ -
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. - (I-)' \p . , . ,- 438 6. Concrete Placement On December 14, 1979, the IE inspector observed selected activities related to placement of concrete in EAB-1 to ascertain whether require- ments of Procedure CCP-4, " Concrete Placements and Finishing," were met. The placement included pour numbers El-SO45, El-S039A, El-122-01Z, El-W122-05 and El-WO27-09A. The concrete pour cards for the place- ment specified the delivery of approximately 650 cubic yards of six B-1-3-11 concrete. The IE inspector observed delivery, placing, and consolidation and reviewed testing records during approximately three hours of initial placement activities. The IE inspector observed that marginal lighting conditions initially existed in two wall placement areas but these were corrected by the installation of additional-lighting. Early in the placement, the IE inspector also observed some isolated areas where small quantities of water from a slow drizzle penetrated the weather protection which had been erected over the placement area. Subsequent repairs to the weather protection appeared to be effective in stopping the water leaks. - \ During discussion of the water leakage, a Brown & Root representative stated that water that had accumulated on the horizontal fom would not be allowed to be incorporated into the concrete being placed. No items of noncompliance or deviations were identified. 7. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non- compliance, or deviations. Two unresolved items disclosed during the inspection are discussed in paragraphs 3 and 4. 8. Exit Interview The IE inspector met with licensee representatives (denoted in para- graph 1) at the conclusion of the inspection on December 14, 1979. The IE inspector summarized the purpose and the scope of the inspection and the findings. A licensee representative acknowledged the statements of the IE inspector concerning the unresolved items. ,5 PBT " - --
,- .. ! , , ( '( h O i 439 , ' a o UNITED STATES * [n anc,%,, NUCLEAR REGULATORY COMMISSION O\ REGION IV n sit RYAN PLAZA DRIVE,sulTE 1000 E , f, [ 6 C ARLINGTON, texas 7so12 g, AB *p.4* - . g + n'.: 4p'* April 4, 1980 ..... In Reply Refer To RIV Docket No. 50-498/80-04 ,_ ,. ... u s Z :- 8 y - - - - 50-499/80-04 - .-_ . . - . - .. -_ --a :_ - Houston Lighting and Power Company . ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and _ 3 , .y .g Technical Services , --p---- Post Office Box 1700 Houston, Texas 77001 Gentlenen: This refers to the inspection conducted by Messrs. W. A. Crossman and W. G. Hubacek of your staff during the period March 4-7 and 11-14,1980, of activities authorized by NRC Construction Permits No. CPPR-128 and 129 for South Texas Project, Units 1 and 2, and to the discussion of our findings with Mr. W. N. Phillips and other members of your staff at the conclusion of the inspection. Areas exa=ined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector.
I Within the scope of the inspection, no items of noncompliance were identified.
One new unresolved item is identified in paragraph 2.e of the enclosed report. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If the report contains any 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 public disclosure. The application must include a full statement of
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- the reasons why it is claimed that the information is proprietary. The
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application without the enclosure vill also be placed in the Public Document
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Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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a l' , ( (, r t -} , . . 440 Houston Lighting and Power Company 2 Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, * / l <l[ W/'ll'&~ 1I - W. C. Se(die, d Chief Reactor Construction and Engineering Support Branch , Enclosure: IE Inspeccion Report No. 50-498/80-04 50-499/80-04 :
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( ( ' i V , U. S. NUCLEAR REGULATORY COMMISSION - 441 0FFICE OF INSPECTION AND ENFORCEMENT PIGION IV Report No. 50-498/80-04; 50-499/80-04 Docket No. 50-498; 50-499 Categoray A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project Units I and 2 Inspection at: South Texas Project Mategorda County, Texas Meeting at Houston, Texas Inspection conducted: March 4-7 and 11-14, 1980 f 8 Inspectors: N m -x e W. G. Hubacek, Eeactor Inspector, Projects Section Date (Paragraphs 1, 2, 3, 4, 5 & 6) : //fYfs.e W. A. Crossman, Chief, Projects Section Date (Paragraph 2) Other Accompanying Personnel: W. C. Seidle, Chief, RC&ES Branch (Corporate Meeting in Houston-March 11, 1980) (Tour of South Texas Project-March 12, 1980) Approved: m fF o W. A. Crossman, Chief, Projects Section Date Inspection Su: fr.ary: Inspection on March 4-7 and 11-14 1980 (Report No. 50-49S/80-04; 50-499/80-04) Areas Inspected: Special inspection of implementation of the licensees nine O ps 99 vf
r - - ( . ;,) 3' , ( '( [ . . - 442 point action plan for resolution of concrete placement problems described in the licensee's letter dated December 28, 1979; and a meeting with licensee representatives on March 11, 1980. The inspection involved one hundred twelve inspector-hours by two h7C inspectors. Results: No items of noncompliance or deviations were identified.
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. i it . ( { ; LJ , . DETAILS 44o . 9610 1. Persons Contacted Principal Licensee Employees +E. A. Turner, Vice President Power Plant Construction and Technical Services +D. G. Barker, Manager, South Texas Project (STP) +R. A. Frazar, QA Manager +J. W. Briskin, Project Manager, STP Houston Operation *+W. N. Phillips, Projects QA Manager *+L. D. Wilson, Site QA Supervisor +T. K. Logan, QA Supervisor +T. J. Jordan, QA Lead Engineer, Mechanical +D. W. Bohner, QA Lead Specialist, Electrical +L. R. Jacobi, Supervising Engineer, Nuclear Safety and Licensing *L. K. English, Site Manager *T. D. Stanley, Project QA Supervisor Brcwn and Root Employees *K. M. Broom, Senior Executive Vice President, Pcwer Division *T. H. Gamon, QA Manager *C. V. Vincent, Project QA Manager *G. T. Warnick, Site QA Manager *R. R. Gunter, Assistant Site QA Manager *U. D. Douglas, Site Constructica Manager W. L. Tofte, Training Coordinator (QA) J. W. Dixon, Training Coordinator (Construction) The IE inspectors also interviewed other licensee and contractor employees including members of the QA/QC and engineering staffs. + Denotes those attending the meeting on March 11, 1980. * Denotes those attending the exit interview on March 14, 1980. 2. Nine Point Corrective Action Program The IE inspectors reviewed proposed measures to provide corrective action and implementation of a nine point corrective action program as outlined in a letter from Oprea to the Director, RIV, dated December 28, 1979. a. Action Item No. 1 Fundar.pntal Philc ecrhf er and Standards of QA PrcStam This action item co=mitted Brown and Root, in a seminar on January 4, 1980, ". . . to review with Construction and QC personnel the fundamental philosophies and standards of our QA Program . ,. ." 3
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. J ~* . ( l' l } 444 *~ The IE inspeetors reviewed copies of four formal presentations given at the Brown and Root Construction and QA/QC seminar held January 4, 1980 on the STP Job site. The four presentations by Brown.and Root management are as follows: " Introduction," Vice President and General Manager South Texas Project . "The Role of QC Personnel at South Texas Project," Project QA Manager " Construction Support for STP QA Program," Project Construction Manager " Conclusion," Vice President and General Manager South Texas Project The IE inspectors noted in review of the second presentation, "The Role of QC Personnel at the South Texas Site," that it was e=phasized frequently that the QA/QC organization has a responsibility in the area of cost and scheduling. While this responsibility may- impact on upper QA management, inspectors on the QC level must have sufficient independence from cost and scheduling to properly perform * quality functions. To the contrary, QC inspectors have complained that they are pressured by construction to meet schedules. Also, the presentation seems overly concerned with impressing on QA/QC personnel that they do not have the final word in acceptability or unacceptability of any given item or circumstance. This should be an infrequent action. Properly defined accept / reject criteria, which are understood by construction as well as QC, allow QC personnel a firm position from which to make decisions. Ambiguous accept / reject criteria, for the sake of flexibility, dilute the QC effort, cause indecision, allow confrontation, sicws construction and results in poor quality work. The above does not reflect requirements of Criterion I of Appendix B to 10 CFR 50 in that it does not support the position that the persons and organizations performing Quality Assurance funct'ans have sufficient authority and organizational freedom to identify
quality problems; to initiate, recommend, or provide solutions;
! and to verify implementation of solutions and that this required ! authority and organizational freedom includes sufficient independence
- from cost and schedule.
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This action item remains open pending further review by .NTsc in
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regard to implementatien of ensite QA/QC's authority ar.d crpnizatioca'. freedom.
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* ( < 8 }, s '~) - * b. Action Item No.2 Field Requents for Engineering Action (FREA's) and Non-Conformance
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Reports (NCH's) Procedures that address Field Requests for Engineering Action (FREA's) and Non-Conformance Reports (NCR's) are: STP QAP 2.6, "Non-Conformances," Revision No. 9, Janua ry 31, 1980. GCP-21 " Field Request for Egnineering Action" Review of QAP 2.6, Section 5.1, " Reporting Nonconformances" revealed the following: (1) The statement, "For the purpose of this procedure, final acceptance shall be that time when the item is presented to QC for acceptance." Has limited application. Although the establishment of this point for acceptance inspection is appropriate for activities such as preplacement inspection for concrete, it is not adaptable to activities such as electrical cable pulling. (2) The section should be tailored to fit inspection of ongoing work such as concrete placement, cable pulling, welding, etc. Appendix STP-QAP-2.6-2, " Instructions for Originator" should address action on " invalid" NCRs as determined by the supervisor. As pointed out by the licensee, a statement should be included to the extent that if an NCR is not valid, as determined by the supervisor, it is returned to the originating QC inspector. Also, the reason for the disposition should be included on the NCR. The FREA program, including trending was discussed with B&R engineering personnel on March 5, 1980. The IE inspectors were informed that 100% re-review of approximately 6000 FREA's has been initiated to determine how FREA's have been used; if there was a change in design without describing how or why; or if the change caused by the FREA is properly documented. The group explained that coding of FREA's is to be complete by April 1, 1980. The first trending report is to be complete by April 15, 1980 with subsequent issue of a quarterly report. Backfit of design will be cocplete by July 1,1980. (A completion date for civil / structural design backfit will be established pending review of data on July 1, 1980). It was pointed out by a Brown and Root representative that there is no onsite approval of FREA's. The General Construction Procedure GCP-21, " Field Requests for Engineering Action" will be revised by April 25, 1980. 5 - - _ - ._ .- , - ..__
* , ( . (- ( e 0 - 44G ' The IE inspectors determined, by review of records and discussions with the QA and Construction Training Coordinators, that three sessions for retraining of personnel in TREA and NCR procedures were held on January 11, 1980. The three sessions included (1) Civil / Procurement; (2) Mechanical / Electrical; and (3) Subcontract / Administration. Clerks and C00P's were not required to attend. A makeup retraining session was held January 14, 1980. Any personnel
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missing these two sessions were to be retrained by March 6, 1980. IE will require further review of the outstanding issues in this action item, ccnsequently, this item remains open. c. Action Item No. 3 Resolution of Disputes Between Construction and QA/QC Personnel Brown and Root issued a written policy statement which outlines specific steps to be taken when disagreements between personnel arise. This procedure, STP-PGM-02, Revision No. O, January 7, 1980, " Pro- cedure for resolving disputes between construction and QA/QC Person ~nel" was reviewed by the IE inspectors. The procedure which defines the method for resolving disputes between construction and QA/QC Personnel was reviewed by the IE inspectors and noted that it defines an accept- able method for resolving disputes between construction and QC personnel. The inspectors have no further questions at this time regarding this action item. d. Action Item No. 4 Qualifications of Brown and Root QA and QC Personnel The IE inspectors reviewed with representatives from HL&P and B&R the status of this action item. , . Level III inspectors have reviewed the bases by which QC personnel are qualified and the inspector's applicable work experience was reviewed in the light of his certification during the period when be was doing work. It was determined by record review that none of approximately 150 inspectors were unqualified, but five did not have verification as to dates, etc. These five have been placed on limited work until confirmatory data is received. To verify information contained in qualification records, telephone calls have been made to previous employers and schools. When the c=plcyers and schcols would r.ct furr.ish confirmatcry data, a letter of release, signed by the B&R employee, was sent to the employer aad/or school. An arbitrary date of April 15, 1980 has been set for receipt of this material before further action is planned. At the 6 .. __ - . . - -__m.. .-. ._ - , . , - - - -p .- ,._, ,.
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time of the IE inspection, approximately 40 personnel still required verification. Brown and Root representatives stated that the verifi- cation of previous employment and education is complicated by businesses and schools which no longer exist or some employees have been educated in foreign schools. Actions identified for this action item have been implemented. The IE inspectors have no further questions at this time. e. Action Item No. 5 Procedure Implementation in Regard to Concrete Pre-Planning and Placement Activities To assess implementation of procedures, the IE inspectors observed activities related to placement of concrete in slab MEl-S206A and S052 in the Unit 1 Mechanical / Electrical Auxiliary Building which occurred on March 13, 1980. Activities observed included pre- placement preparations and depositing, consolidation and finishing of concrete. It was noted the HL&P personnel were performing surveillance as well as the B&R QC inspector who was inspecting placement activities. It was observed that a concrete pump discharge line failed during the placement; however, the line was repaired and returned to service without any apparent adverse effect on the quality of the concrete that was placed. Concrete placement continued by means of buckets during the pump outage. The IE inspectors also reviewed the results of tests of concrete samples taken at the truck discharge point. The test results appeared to meet acceptance criteria for slump and air content specified on the test records. Concrete curing was inspected on March 14, 1980. J Although no items of noncompliance or deviations were identified during this activity, the placement was not considered large enough nor complex enough to provide a good determination of the thorough- ness of procedural implementation. The IE inspectors discussed with responsible KL&P and B&R personnel preplacement inspection activities in regard to the in process inspection " punch list." It was explained to the IE inspectors that the list contains ite=s to be corrected or evaluated and accept- as-is at Four Card sign-off. When all items have been signed eff, the " punch-lis*" is si ned F by the QC inspector to verify the above, and attached to the Pour Card. The " punch list" is originated by the Construction Engineer and the maintenance of it through the construc- tion and preplacement activity is his responsibility. There is no mechanism to preclude entering on the list such items as may require an NCR or a FREA other than the Engineer's review of the list. 7
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f' . - . ' ( { , r) 448 * The licensee and construction personnel stated that Quality Construction Procedure A040KCCP-3, "Prepour Activities" would be revised to include a requirement for check for completion and sign-off of the " punch list" by the QC inspector and to make the " punch list" a part of the Pour Card package. . Further discussion revealed that the " punch list" may contain safety-related items and consequently is an activity affecting quality. Consequently, the procedure for the " punch list" should be formalized to comply with Criterion V of Appendix B to 10 CFR 50. This item will remain unresolved pending incorporation of the " punch list" activity into a procedure. This action item remains open. f. Action Item No. 6 Provision of Method for Judging When Reinspection of a Concrete Placement is Necessary Brown and Root Quality Construction Procedure A040KCCP-3 "Prepour Activities," was revised to include reinspection criteria by Interim Change Notice No. 1, dated January 7, 1980. The Interim Change ' Notice requires that, should undue delays occur after the concrete pour card signoff, QC shall consider climatic conditions, personnel traffic in the pour area, and work activities that may affect the pour area. QC will then reinspect for cleanliness of the pour, excess water (if applicable), and alteration caused by personnel traffic (if applicable). Results of reinspection will be documented on the applicable QC inspection report. Training records indicated that Brown and Root QA/QC and construction personnel attended training sessions relative to CCP-3 in January 1980. The IE inspectors had no further questions concerning this matter. g. Action Item No. 7 Augmentation of the HI,&P Site QA Staff Three members of the HI.&P QA staff including the Projects QA Supervisor were temporarily assigned to the STP site to augment the site QA staff. The Projects QA Supervisor remains on indefinite assignment to the site and is currently directing STP QA activities. The other two individuals who were temporarily assigned to site QA have been released to return to their previous duties. One of the individuals is intermittently incolved in the resolution of the engineered backfill testing. Tive additienal 8 -
s ( ?) , - ( f( ( i - . . 449 ' personnel including two civil, one electrical, one mechanical and one administrative will be added to the HL&P site QA staff. In addition, changes in the project QA organization have been made with the removal of the Project QA Supervisor from the site QA chain of command and upgrading of the site QA Supervisor position. Special hard bats have been provided to clearly identify HL&P QA personnel. Additional review and observation by the NRC will be required to determine the effectiveness of the changes in the site QA staff. h. Action Item No. 8 Refresher Training for Construction and QC Personnel Initial refresher training for construction and QC personnel was conducted on January 11 and 14, 1980. Subsequent planned quarterly refresher training is described in B&R interoffice memo " Expanded Refresher Training Schedule 1980," dated January 23, 1980 transmitted by Memo No. BC-22424 dated February 27, 1980. Participants in the training include QA/QC Superintendents, General Foreman, Foremen, and Construction Engineers of the civil, coatings, electrical, mechanical, welding, and NDE disciplines. The training consists of modules developed under the direction of the B&R Houston office Corporate Level III. The training modules are presented by persons selected by the corporate Level III. Craft journeymen and other construction personnel are not required to attend the refresher training. The IE inspectors had no further questions concerning this matter. ' i. Action Item No. 9 Assessment of the Brown and Root Organization to Determine Cause ' of Perceived Harassment or Undue Pressure on QC Personnel A management assessment to determine the cause of the perception of harassment or undue pressure on site QC personnel was completed by Brown and Root in January 1980. The management assessment concluded
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that the perception of harassment of QC could have existed in the
l past because of instances of confrontation between construction and QC.
Brown and Root engaged the services of an independent censultant
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to c:. duct a survey of QA/QC and censtructi^n perrennel to determine the extent and causes of the perception of harassment or undue pressures on QA/QC personnel and to recommend actions
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which could be taken to correct adverse situations that were
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identified. The consultant concluded that, based on interviews with individuals and small groups as well as analyzing
l questionaires cc.mpleted by site QA/QC personnel, construction is
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- . . (: - . . - ( 'f( t' 13 ~ 450 not currently causing undue pressure or harassment directed at " QA/QC personnel. As a result of information developed during the management assessment, purnonnel changes have been made in the construction and QA/QC organizations. In addition, Brown and Root has initiated the following actions: (1) A complete revamp of the salary administration program for site QA/QC. (2) Reemphasis of the role of QA/QC to construction personnel. (3) Provisions for resolution of conflicts at the job site. (See Item c of this section of the report). (4) Refresher training, meetings and seminars to strengthen the role and understanding of QA/QC. (5) Improved coc=unication by QA/QC management. Additional review and observation by the NRC will be required to determine the effectiveness of the above actions. 3. Meeting with Licensee Representatives A meeting with licensee representatives (denoted in paragraph.1) was held in Houston March 11, 1980 by the Region IV Chief of the Reactor Construction and Engineering Support Branch and me=bers of his staff. Matters discussed pertained to RRI functions including the licensee /NRC interface, reporting of 50.55(e) items, reporting of significant events, correspondence with the NRC, the need for periodic licensee / RRI meetings, and improvement of co=sunications between the licensee and the NRC. Regarding communications, the senior licensee representative expressed concern that an apparent coc=unications problem had developed between the licensee and Region IV. He stated that he wished to reaffir= the policy of open communications between the licensee and the NRC. The senior Region IV representative also expressed concern that a ' communications problem had developed between the licensee and the RRI. He stated that the RRI is the prime Region IV contact for all site related matters and discussed methods of i= proving licensee /RRI ce==ucications. Reporting of 50.55(e) items was discussed. The Senior Region IV representative stated that construction deficiencies must be promptly reported to the RR1 within the twenty-four hour period af ter the deficiency is found. Initial reporting may be by telephone. If the deficiency is later determined to be not reportable, Region IV should be notified by letter of that deter =ination. If the deficiency is determined to be reportable, a written report is required thirty days
, ' i from the date of prompt notification. If insuf ficient information is
available for a final report at thirty days, an interim report stating
. t the status of the matter cust be submitted to Region IV. The interi= t i
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. ( f F) 451 I( - . . . ( i . ' report should also state the date when the final report will be submitted * or, if the final report date is unknown, subsequent interim reports should - be cubmitted at thirty day intervals until a final report date is established. The licensee was encouraged to discuss reportability of deficiencies with the RRl. A handout, summarizing the reportability requirements of 50.55(e), was provided to the senior licensee representa- tive. ( The senior Region IV representative also discussed reporting of incidents, accidents, unusual occurences, and other items of interest occurring at or related to activities licensed by the NRC. For plants under construction the following avents should be reported to the NRC. Serious natural occurrences and their effects. Serious fires or explosions. Significant environmental events. Actual or threatened sabotage - malicious mischief, bomb threats. Demonstrations resulting in arrests or violence. Lost or stolen licensed material. Strikes which result in violence, damage or delay in the critical path of core than one month. Deficiencies in design or construction which have the potential for delay in the critical path for more than one month. An event which results in a fatality or a serious injury. Events in which news media interest exists or is expected. Other events of similar importance to those identified. The licensee was requested to report such ite=s to the RRI. In the event the RRI is not available due to absence from the STP site the license was requested to report the above events and 50.55(e) deficiencies directly to the Region IV office. 4. Unresolved Items Unresolved items are matters about which = ore infor=ation is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. An unresolved ite disclcsed during the inspection is discussed in paragraph 2.e. 11 ~
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_ . . . l_i ! - . . (' ?.l s, . e) L 452 . : 5. Exit Meeting The IE inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on March 14, 1980. The IE inspectors sumarized the purpose and the scope of the inspection and the finding's. , / s ? ! ( , .) , s. I fi / _a ), 8 . il
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f , APPENDIX 5 . 01 J ,,' o . j , Implementation of the 453 ~ '. Brown & Root , Quality Assurance Program at the . ' South Texas Project Jobsite ! i * I ; l . * e . , ' ' * . . ,__ - - s - . ..- ' ' . ;.. , . .
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* * AGENDA f{,j
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* BROWN a ROOT CONSTRUCTION AND QAMC SEMINAR
- STP JOBSITE
JANUARY 4,1980 !. INTRODUCTION II. THE RO'LE OF QC PERSONNEL AT SOUTH . TEXAS PROJECT * III. CONSTRUCTION SUPPORT FOR STP QA * PROGRAM IV. CONCLUSION < * . A e e e e b e *
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. .- * 455 * . Implementation of the - , l Brown &. Root Quality Assurance. Program at the South Texas Project Jobsite i ! ! !. INTRODUCTION i The South Texas Project Quality Assurance , program. to be fully effective. must be understood, accepted and fully implemented by each employee on this Project. The purpose of this meeting is to reiterate Brown I & Root Management policy regarding the respon. ' sibl!!tles and dulles of Brown & Root Construction and QA/QC personnel in implementing this QA program. - The Project QA Manager will describe in detail the - role QA/QC personnel play on this Project, their duties and responsibilities. and standards of per- , formance and conduct expected by Brown & Root Management. The Project Construction Manager will describe how Construction p,ersonnel support the Quality * Assurance program and what standards of perfor. mance and conduct are expected from Construc- tion personnel. . J.R. Ge urts
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Vice Preeldent & General Manager
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South Texas Project
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=m.cc2tTiZs Ols)cooramerurumAru; II. THE COLE CF CC PERSONNEL AT SOUTH TEXAS PROJECT . * cveryone on the trm, wtrking together, as - acctmplish the sbjective af a safe nucle:r powsr . A. 'INTRCDUCTION PI Mt- 45G > In the past yeer due to events like Three Mlle l ' island. public attention was focused on the safety D. ROLE OF QASC * cspects of nuclear power plants, and the effective- ness of the Quality Assurance programs under Now let us examine specifically the role of the QA/ which they are built and operated. This attention , QC organization in regard to safety. It is the has caused increased pressure and tensions among * responsibility of QA/QC to verify that this project c!! Involved pa ties, the Nuclear Regulatory Com- Is constructed in compliance with the applicable mission. the HL&P and Brown & Root. Therefore. design documents. This is an important and with the eyes of the world upon every move,it has specific role in assuring nuclear safety, but Q A/QC become evident that we re-e.aamine and restate the * does not carry the sole and total responsibility for purpose and the function of the Quality safety. Safety is a responsibility shared with Con- Assurance / Quality Control program and personnel struction and Engineering. It is Construction *s within the framework of the Brown & Root team. responsibility to build the plant in accordance with applicable design documents. Engineering also S. REGULATORY FRAMEWORK shares in the responsibility for safety in that the design must satisfy all of the applicable federal First. let us briefly review the role of the Nuclear and Industry codes and standards. Rigvistory Commission. The Unteed States Con- gress through the Atomic Energy Act charged the it is also the responsibillry of the QA/QC Commission with the responsibillry to oversee the organisation to ensure that this verification is car- comp!!ance with safety standards through the pro- ried out in a timely cost effective manner. la is cass of licensing responsible public ut!!ity com- Important that each of us ple:e his own respon- pznies to plan and construct nuclear power plants sibility in proper perspective with the concurrent end later to operate these plan:s when completed. responsibility of the engineers and construction Thus the NRC is responsible for reviewing. forces. QA/QC like construction and engineering inspecting and approving all aspects of the design, starts with plans, speelfications and other docu- construction and operation of the plants. This ments speelfying requirements and procedural regulatory power is exercised through the licensing methods. In verifying the acceptalality of the erec- r s directly upon the utility company as tion and fabrication it is expected and required hcensee. Thus the licensee is directly responsible that we follow the design documents, specifica- to the NRC for nuclear safety. The licensee can be ticms and procedures strictly as written by the ; i fined or denied a license because of failure to com- engineers. ply u ith regulatory standards or to promptly report to the NRC anything that could or might possibly The QA/QC organization while carrying out their affcct safety.
, ' required function in a timely and cost effective
C. EROWN & ROOT *S TOTAL RESPONSIBILITY manner shares another Brsan & Root team responsibility of completing the project on
i schedule within the projected cost estimnie. Time
The lirrnsee has placed a tremendous confidence In Brown & Root as the eng'neers constructors of completinn is of great importance to the nuners
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ond project general managers at South Texas Pro. and to the public. However. Quality is the top con.
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Jrct. The safety of this plant is of paramount sideration for Construction as well as in QA/QC.
l Thus the ultimate goal of the Brown & Root team '
importance to Brown & Root. This responsibillry for saftry is the responsibihty of every Brown & Is a safe plant constructed on schedule at the Root employee. Each of us has a role to play on the lowest possible cost. 2 3
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. . cainot be mots easily resolved. The QA/QC * E. NECESSITY F03 ATTITUDE CF RESPECT ,AND COOPERATION 4 {I i erg:nlaatirn while Independ;nt must r:cognist that high:r cuthorities do eatst sha h:v2 trial if the Brown & Root team is to succeed in meetin9 responsibility far design, ccnstructisn end sIfety. their ultimate goal. a safe plant at the most * economic cost and shortest possible schedule. it is necessary that an atmosphere of mutual respect H. QASC DECISIONS CAN BE CilALLENGED , cnd understanding be maintained at all times. It We all have pride in our work, and it is an injury to tiso means that QA/QC must perform inspections our pride when our work is questioned or criticized. promptly so that work does not progress wasteful- ly. It means that Construct 2n must be willing to . All Brown & Root team members must realiae that they are not the final word, and that their dect- correct deficiencies whenever found. slons are subject to challenge and tha,t it is i This is not to imply that Construction must accept . appropriate for higher authority to make decisions * vpholding or re}ecting their work.Too of ten people every QA/QC rejection of its work without ques- feel that a challenge of their decision is an abuse. tion. The QA/QC personnel are not the final word an attempt to discredit them.an attempt to under- on the acceptability or unacceptability of any mine their authority, or an attempt to cover up given item or circumstance. shoddy and unacceptable work. Perhaps this attitude results from the lack of understanding the F. OTHERS HAVE A ROLE IN THE REVIEW responsibilities others share in the design and con- AND APPROVAL PROCESS struction of a nuclear power plant. The Brown & Root team is divided necessarily into o team of specialists. The QA/QC is but one ele. ment of that team and is not expected by anyone to I. INTERNAL STRUCTURE OF QA/QC be ' capable of making the ultimate decision on The Project QA/QC is made up of a number of esery concern of acceptability. It is the function of specialized groups and functions. Each QC inspec- the QA/QC organization to document the as. built tor has a clearly defined area and scope of work. condition of the plant. It is the responsibility of and he has the responsibility to inspect the work in engineering to disposition departures from the his jurisdiction to assure that it is performed cpplicable design documents that will not be according to plans and specifications. The inspec- reworked to conformance. lt is important to reallae for has the responsibility and absolute authority to that esen the engineer's disposition is subject to prevent the work from proceeding until the work is s- and approval by the owner and the Nuclear satisfactory. This is a power which must be emer. Regulatory Commission's design review prior to cised with a high sense of responsibility. It is a Issuing the ouner an operating license for thi<. ' power and authority which is not absolute or final. pla n t. but which may be subject to challenge and review by others vested with even greater authority and G. INDEPENDENCE OF QASC responsibillry. It is never easy to accept a reversal . of one's decision but it should help if se realize The QA/QC organlaation. although a full fledged member of the Brown & Root Project Management that a reversal of such a decision may not mean. Team, enjoys a unique organlaational status in and probably does rat rnean. that the decision was wrong or that it was an abuse of authority to refuse that it also reports directly to the top eaecutive to ** sign off" work which a higher authority later msnagement of Brown & Root Power Division. This independence is provided to assure that undue approves, it may not be immediately apparent to * you why such a reversal of the decision does not pressures cannot be applied to cause non' conform- mean that the decision was wrong, but let's Ing work to be accepted. There are even higher esamine that and I think you will understand that cuthorities in the owner's organlaation and the what I am saying is correct. NRC to resolve questions of such 6erious nature as
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All of this tdds up to en: big job fir QA/QC per- St CESSIVE LEVELS CF DECISIONS TO . **"" - """d**'""''""'"'"*" . APPZOVE DEVIATIONS , 4d8 ing o 1:t af skill end a 1:t af spectilPers:n:1 traits it is carrect that the OC Inspect r is s41 cllowed to si charret:r. First.cf czurse. ls etchnict.1 empersist caercise discretion in walving deviations from required to interpret the plans. specifications and . slict and literal compliance with plans and other requirements and standards and to evalute specifications and he must refuse to ** sign off" the comp!!ance with these requirements of the any work which does not' conform er.ectly to the construction work performed., We have a highly dr: wings, specifications and/or procedures. There skilled group of QA/QC personnel, and all of you are higher authorities within the QA/QC and have demonstrated your qualifications in thesr E:sineering organlaations who are allowed e areas. The personality traits and character traits broader discretions and greater authority to required are more subjective and require iden. approve work not within strict and/oc literal comp- tification and close considerations. Let's look at flance with the drawings or words of the specifica- them one by one. ' tions, but which are within the real Intent of the * design engineer. It is entirely proper for these authorities to have and to apply a broader degree of discretion in approving, as natisfactory, a literal deviation which is within the Intent of the plans 1. Integrity. Honesty and Candor cnd specifications. But even they are restricted in their discretion, and they are act permitted to These are so closely related they may be cpprove dedations if they could possibly involve a treated as one. Obviously we cannot have departure from the Intent of the design enginar. reliability in the assurance of safety and The design engineer may. of course. Interpret, quality unless the QC inspections and all cl:rify, or change the design documents to permit QA/QC personnel are trustworthy and the acceptance of the work as it has been per. reliable to a degree that inspires complete f: med. If you realize that you are part of a large confidence and allows no suspicion. Any term. mith a very important but limited scope of dd in Ws area would require replace- tuthority and responsibility and that no one is the ment of such person. final uord. It should be easier to accept the Ides that Construction has a right to question QA/QC Support of Nuclear Power 2* decisions. and that a quecinn or even a reversalis nst necessarily discrediting or undermining QA/QC personnel have great respon. cuthurity. sibility for accomplishing the purposes of e nstructing a safe nuclear plant at Should there arise a case in which the matter is so minimum c st and on schedule. srrious that it Indicates incompetence or bad faith . er bed judgement or even misunderstanding on the 3. Loyalty to Broum & Root p:rt of your immediale supervisor who reviewed th matter and allowed construction to prevail , You have a responsibility to your ever your rejection. you have the duty to pursue the employer as a part of the Brown & Root m tter further until you are satisfied that compe- team responsible for building this plant. tint authority within Ifrown & Root at the highest As a member of this team you are IJvel. If necessary has received notice, considered '., expected to pull for the team and that
thr matter and found it safe And further, if you means all of the team. Including the con-
i still feel you are right.you have a duty to report the struction crews. That means you must I matter to the Nuclear Regulaton Commsission. have respect for your team. and realize
that an absolutely safe plant is the prim- K. QUALITIES REQUIRED OF QA/QC ary objective of the entire organization. PERS ONNEI. not just QA/QC. There is no room here 6 7 . % .
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. . for o QA/QC man who lacks c:nfidence L. SUMMARY AND CONCLUSION la the mmgemint or "la his I;llow - , * ,worksrs so the Brswn & Root term.Thers Wh:t l*ve bein t:lking tbout is cf vitilimportrnce is s:s room fir o m:n echo would seek to 4 -Ued ta cti cf i;s here todry - ta sich cf us Individurlly, embarrass or harm his company when he to the organlaation unit which we represent, to our . could instead help his company do its job company. Brown & Root,and to the public and our right. country. It is important that we all understand our * proper function in helping to.sc,1ve our Nation's Devotion to Duty energy problem. 4. QA/QC personnel must be dedicated to in summary, let us emphasize the vltat and impor. g the vital safety and quality assurance ., tant points. function they are hired to perform and they must be unwilling to become a party ,k 1. QA/QC is but one element in ensuring to unacceptable practices just to save that the f acility we are involved in build. their job. The inspector who would charge Ing will be safe when it is finished and that violations had occurred in the past Pl aced in operation. and that he participated and failed to report them because he **was makin9 2. QA/QC is but one member of the Brown good money.** Is contemptible, and has no & Root team commissioned to build this nuclear power plant, each member having Pl ace at Brown & Root- his share of the total responsibility for the Team Spirit cost and timely completion of a facility 5. which will be safe to operate. QA/QC personnel are expected to 3. All Brown & Root employees here on this approach their work with a team spirit. - nuCItar project operate within an You are not here to catch and punish organlaational structure where super-
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violators. but to assist other team mem- vis rs have greater responsibility and bers to perform their work correctly. You authority than those whom they euper. are expected to check and assure that vise. The supervisors have the respon- mistakes are detected and corrected at the sibility to review technical decisions and proper time before their correction modify or reverse them where needed, and becomes too costly. You are expected to to enforce discipline. including the duty to do a difficult and sometimes unpleasant reprimand or discharge those who are not job with tact and diplomacy. Be helpful Performing in accordance with the estab. and go the extra mile to help expedite and lished system. simplify corrective measures. f ' , 4. Within the QA/QC organization we have a special responsibility for ensuring that 6. Responelveness to Authority the plant is constructed in accordance with the design. The ultimate respon- Each employee has a boss and responsive. sibility for the safety of the plant rests ness to the directions * of one's supervisor with the Power Division Management. is an essential part of the discipline 5. ewe all. Individually, have a responsibillry necessary to make any organ!*ation oper- ate effectively. In QA/QC wotk this to the NRC. If anyone feels that the means responsiveness to technical as well system has failed in its paramount objec- as the administrative decisions of your ' tive of safety. he has a duty to report his concern to the NRC, after first being sure superiors. Your supervisor is the proper authority to evaluate your decisions and that responsible Brown & Roet officials
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* . . Ill. CONSTRUCTION SUPPORT FOR STP QA * This is o'comptes subject which requir:s m:tur2 ~ 4g PROGRAM judgemert cnd se:derstrnding. Within the QA/QC ergenization you have the capacity of such unders- The Project QA Manager has spoken to you this 3:ading. If you have any questions, take them to afternoon about the duties and responsibilites of
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your supervisor individually and he will explore QA/QC at STP. I emphaslie the responsibilities of them in depth. If you still have questions or con- Construction on building a safe nuclear power terns. I will be on site Several days a week and Pl ant. We are that part of the team charged sith maintain an **Open Door Policy ** to discuss any erection of the engineer's design. other matters with you. , ! How do we so about this effort and remain cost effective? Number one . we have to plan our merk in such a manner that we can build the plant one Ptsjxt QA Manager time as near as possible to the plans and specifica- . tions. We have to have engineering approval for l any deviations.There has been in the past history of this project some differences of opinion betmeen the construction foremen and the QC Inspectors , over what constituted a deviation from the dram- ; Ings and specs. The Project QA Manager has pointed out that the QC Inspector has very limited latitude when an interpretation is required. When the construction foreman does not agree with the j' , QC Inspector, at this point they should call in their immediate supervisors to resolve the dispute. Con- struction Management on this project' will not tolerate verbal or physical harassment of QC Inspectors by construction employees and such intimidation will be grounds for termination. In many cases it wl!! be more cost effective to cor- rect the deviation than call in several layers of management to get involved in the problem. We need at all times to strive to keep our pride out of a decision that could add additional cost and delays. ' There is exhibited on this project at the superviso- ry level a spirit of cooperation and team effort. I feel with added communication we can have this same team spirit throughout the ranks. We are developing a program to familiarize all construc- , tion foremen with the requirements and duties of the QC inspectors. ., Quality is not inspected into any product. We build quatiry products. then inspect them to assure we have maintained a quality product. Construction Management on this project recogn. Izes and supports our QA/QC Department as an 11 10 . k . 3 .
e . . leergr:l part af the tit:1 prrJIct org:nization. Gimea my chilce I wruid prsf2r to h:ve Qu:llty ! 4G f "' In' ""* ' "" c nclustrn.1 w:nt t2 say we still brve a big job - Centrol on any project th ,t i em cssoci: tad with in ahead of us in completing the South Texas Project. ; the future. ~ Complete cooperation from all contributing a ; groups is required and intimidation and harass. l unuld like to close with this statement.1 have an ment frem any quarter will not be tolerated. We *Tpen Door Policy" and, will be available to dis- will be taking a number of steps in the future to cuss your problems with you at any time that you followup and seemphastre the Brown & Root cannot get a satisfactory response from your ' dedication to quality that you heard today. I have smyervisor. I every confidence in our Brown & Root team In our ability to recognize the importance of each con. tributing group of people and in our'abillry, work- ing together, to build a safe nuclear power plant of Pasj2cs Construction Manager great importance to Brown & Root and to our . Client. Houston Lighting & Power. I appreciate your attention and thank you for coming. J.R. Geurts Vice President & General Manager South Texas Project . # .D e % . *
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. EROWN a RSOT. INC. STP.PGM.02 , * REV.NO.0 * . SOUTH TEXAS PROJECT PAGE 2 OF 3 1.0 PURPOSE . STP.PGM.02 The purpose of this procedure is to state Brown & * Root policy regarding the implementation of the REVISION O South Texas Project QA programs, and to define the method for resolving disputes between Brown * & Root Construction and QA/QC personnel. 2.0 SCOPE PROCEDURE FOR RESOLVING DISPUTES The scope applies to the resolution of differences BETWEEN of opinion on technicat or procedural requirements CINSTRUCTION AND QAA2C PERSONNEL that cannot be resolved by the Construction and QA/QC personnel directly involved. January 7,1980 3.0 DISTRIBUTION Distribution shall include: 1. Project General Manager 2. Engineering Project Manager l 3. Construction Project Manager / /7 / 4. Project Controls Manager j Project Material Man 1ger 5. 6. Project QA Manager J.R. GEURTS DATE STP PROJECT GENERAL MANAGER Other copies shall be distributed. as required. In order to assure complete compliance with this document. 4.0 PROCEDURE -" 4.1 Policy Brown & Root is dedicated to furnishing high jquality. reliable plants and services. All work shat: comply with applicable design documentation and good construction practices. , Ordinarily a rejection of construct;on work by a QC Inspector should be immediately accepted and the work corrected immedir.tely. In cases uhere ' genuine and substantial differences of opinion ' arise, and the matter cannot be easily and speedily resolved at the working level, extended arguments . abould be asolded by prompt seferral of the matter for resolution by higher QA/QC authority. 14 15 .
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- y ~ ' ' ' STP.PGM.02 4G3 decision la charged through the foregning pre. . ** REV.NO.O ccdira. . PAGE 3 OF 3 Differences of opinion between Br wn & Root . Construction and Brown & Root QA/QC personnel - To implement this policy the following procedure on technical or procedural requirements are to be has been adopted. To be fully effective, this resolved promptly and in a businesslike mar. net. proginm must be understood accepted and fully Violence. threats of violence.,or harassment by Implemented by each c'mployee. Therefore. all any Brown & Root employee of any other Brown & supervisors in the Engineering. Construction, and Root employee will not be tolerated. An offended . QA/QC orgenlaations shat! cooperate to assure * employee should bring such conduct to the atten. complete compliance. tion of his own immediate supervisor. All such complaints shall be reviewed immediately by the 4.2 Procedure Detatis Brown & Root Project Management for proper action which may include termination of employ- il differences of opinion on technical or procedural ! ment of the offending employee. This is a normal requirements between a Construction supervisor * function of the "Open Door Policy" which allows cad a QC inspector cannot be speedily resolved between them at the working level. the decision of any employee to bring any job related problems to the attention of his successive supervisors and the QC inspector sha!I prevail subject to the ultimately to company officers without fear of f llouing procedure: retallation or intimidation. 1. If the Construction supervisor wishes a 5.0 REFERa. 4CES review he shall contact his own direct supervisor who shall in turn contact his None counterpart supervisor in the QA/QC organization. The decision of which Interpretation is correct will be made by the QC supersisor in consultation with the Construction supervisory personnel. The QC supervisor will utillre whatever technical assistance he deems necessary to supplement his own knowledge in mak. Ing this decision. The QC supervisor's decision and the justification will be documented on the appropriate report. and the QC inspector u til be furnished a copy thereof. Other involved parties will be gisen a copy if requested. 2. If there is. still disagreement, the differences will be referred immediately ' to the highest level of Brown & Root QA/
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QC supervision then present at the site for revies and final decision and docu. mented as provided above. The decision of the QC Inspector shall be compiled with by the Construction organlaation unless that 17 16 s . .
4 ~ '^ ' ' pdc o UNITED STATES o, NUCLEAR REGULATORY COMMISSION g g f ~ 611 RY AN PLAZA DRIVE, SUITE 1000 ,; a ,4 % ) o ARLINGTON, TEXAS 76012 g b3 ., g N*'o / **** April 30, 1980 4G4 In Reply Refer To: RIV Docket No. 50-498/Rpt. 80-07 C< 50-499/Rpt. 80-07 gg p.; l@iF T Houston Lighting and Power Company 3E.2 N 1 UbE ATTN: Mr. E. A. Turner, Vice President Power Plant Construction and , 3 - :.. Technical Services l'9 Ej?d[N Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the inspection conducted by Mr. W. G. Hubacek of our staff during the period April 8-11, 1980, of activities authorized by NRC Construc- tion Permits No. CPPR-128 and 129 for South Texas Project, Units No. I and 2, and to the discussion of our findings with L. D. Wilson and other members of your staff at the conclusion of the inspection. Areas examined during the inspection and our findings are disscussed in the enclosed inspection report. Within these areas, the inspection consisted of selective examination of procedures and representative records, interviews with personnel, and observations by the inspector. During the inspection, it was found that certain activities under your license appear to be in noncompliance with Appendix B to 10 CFR 50 of the NRC Regulations, " Quality Assurance Criteria for Nuclear Power Plants." The item of noncompliance and references to the pertinent requirements are identified in the enclosed Notice of Violation. We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in paragraph 2 of the enclosed report. This notice is sent to you pursuant to the provisions of Section 2.201 of the
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NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
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Section 2.201 requires you to submit to this effice within 30 days of your receipt of this notice, a written statement or explanation in reply including: (1) corrective steps which have been taken by ycu, and the results schieved;
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(2) corrective steps which will be taken to avoid further noncompliance; and
l (3) the date when full compliance will be achieved. I i
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. ( ( s . 1 . . Uouston Lighting and Power Company -2- April 30, 1980 4G5 , 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 the 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 public disclosure. The application must include a full statement of the reasons why it is claimed that the information is proprietary. The application should be prepared so that any proprietary information identified is contained in an enclosure to the application, since the application without the enclosure will also be placed in the Public Document Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room. Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Sincerely, f, 6- W.C.Seidl) Chief Reactor Construction and Engineering Support Branch Enclosures: 1. Appendix A, Notice of Violation 2. IE Inspection Report No. 50-498/80-07 50-499/80-07
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. ( ( bI . J , 50-498/80-07 50-499/80-07 . Appendix A NOTICE OF VIOLATION .: Based on the results of the NRC inspection conducted on April 8-11, 1980, it appears that certain of your activities were not conducted in full compliance with the conditions of your NRC Construction Permit CPPR-129 as indicated below: Failure to Follow Procedure for Storage of Material 10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality shall be performed in accordance with instructions, procedures or drawings. Brown & Root Quality Construction Procedure GCP-35, " Storage and Maintenance," Revision 3, requires that protective covers and closures be intact. Contrary to the above: During inspection of equipment storage on April 8, 1980, the IE inspector observed that a protective cover had been removed from a weld preparation on pipe penetration M-39 in the Unit 2 Reactor Containment Building (RCB) and a steel hook, used to support scaffolding on the exterior of the RCB, was in direct contact with the weld preparation. This is an infraction. N god .- . . - - - - ---.____.___,___m_____ _ _ _ _ _ _ _ _ _ _ _ .
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* 407 U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-498/80-07; 50-499/80-07 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Inspection at: South Texas Project, Matagorda County, Texas Inspection Conducted: April 8-11, 1980 Inspector: MA 91,k1d 8 9'!?C W. G. Hubacek, Reactor Inspector Date Projects Section Other Accompanying Personnel P. G. Wisco, Nuclear Technologist, Philippine Atemic Energy Commission Approved: e rw ' [8C W. A. Crossman, Chief, Projects Section Da'te Inspection Summarv: Inspection on April 8-11, 1980 (Report No. 50-498/80-07; 50-499/80-07) Areas Inspected: Routine, unannounced inspection of licensee's corrective action in response to previously identified inspection findings. The inspection involved twenty-three inspector hours by one NRC inspector. Results: One item of noncompliance was identified (infraction - failure to follow procedure for storage of material - paragraph 3). G e$ . . . . . _ . - - - _ _ . _ _ - . _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ . _ _ _ _ _ . , _
- - . . ( (i ' 'l :.1 4G8 DETAILS . 1. Persons Contacted Principal Licensee Employees *L. D. Wilson, Site QA Supervisor *D. G. Long, QA Lead Engineer, Civil T. J. Jordan, QA Lead Engineer, Mechanical *J. W. Soward, QA Specialist, Mechanical *H. E. Orban, Construction Engineering Supervisor Brown and Root Employees *G. T. Warnick, Site QA Manager *R. W. Bass, QA Audits Manager *G. Martin, Assistant Project Manager *H. O. Kirkland, Senior Construction Manager *G. Morgan, QA Subcontractor Surveillance Supervisor G. D. Parks, Corporate Level III, Civil The IE inspector also contacted other licensee and contractor employees including members of the QA/QC and engineering staffs. * Denotes those attending the exit interview. 2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-498/79-03; 50-499/79-03: Long Term Storage Requirements in NSSS Manual. The IE inspector observed that the " South Texas Project Recommended Storage Criteria," Revision 1, dated February 15, 1980, addresses frequencies of inspections and defines inspection requirements.
I l This matter is considered resolved.
(Closed) Unresolved Item (50-498/79-13; 50-499/79-13): Certification of Level II Cadweld Inspector. The IE inspector observed that a memorandum, dated August 21, 1979, stated that the certification document for the Brown & Root $&D Cadweld inspector did not display the ccrrect amount of work experience necessary for Level II certification in that a time waiver was omitted from the certification form. The memorandum waived one year of the required work experience. A licensee representative stated that the responsible Corporate Level III was aware of the Cadweld inspector's lack of the required work experience, but had inadvertently failed to provide the waiver at the time of the initial certification. Waivers were permitted by the B&R certification requirements in effect when the Cadweld inspector was initially certified. Waivers are not permitted by the current revision of the Brown & Root training manual. This matter is considered resolved. 2
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.,_ - : i . * ( ( ' ! . . , 4GB (Closed) Deviation (50-498/79-14-B; 50-499/79-14-B): Failure to Sign , or Date a Supplemental Entry on a QA Record. The supplemental entry on the Examination Check Form documenting QC inspection of concrete placements CSI-12A and CSI-13A, dated November 9, 1978, was signed and dated on September 13, 1979, by the individual who made the supplemental entry. The IE inspector observed that written instruction SQA-3303, " Construction / QA Documentation," dated January 30, 1980, addresses handling of corrections and additions to construction and QA generated documents. Instruction of QA/QC personnel in the requirements of SQA-3303 has been accomplished and documented. This matter is considered resolved. (Closed) Infraction (50-498/79-14-A; 50-499/79-14-A): Failure to Follow Procedures for Release of Stop-Work Notice S-14. The IE inspector ascertained that the B&R site QA Manager has been informed by verbal and written communications of the need to follow procedural requirements for the release of Stop-Work Notices. Discussions with licensee repre- sentatives indicate that the verbal release of Stop-Work Notice S-14 was an isolated occurrence. Individuals responsible for release of Stop- Work Notices displayed adequate knowledge of procedural requirements and stated that these requirements will be strictly followed. This matter is considered resolved. (Closed) Unresolved Item (50-498/79-14; 50-499/79-14): Frequency of Inspections Required by B&R Procedure CCP-12. The IE inspector observed that Interim Change Notice No. 1, dated March 7, 1980, has been issued which clarifies the scope and frequency of CCP-12 inspection requirements. The IE inspector also observed that HL&P issued a memorandum, dated February 11, 1980, which requested that B&R compare all existing B&R Quality Construction Procedure requirements contained in the bodies of the procedures against the requirements contained in the attached QA Plans and Schedules. This matter is considered resolved. (Closed) Unresolved Item (50-498/80-02; 50-499/80-02): Reinspection of Former QC Inspector's Work. The lE inspector reviewed the results of B&R QC reinspection of the work of a former QC coatings inspector who was terminated for falsification of personnel records. The reinspection indicated that the former coatings QC inspector's work was adequately
- performed and documented.
This matter is considered resolved. 3. Site Tour
- The IE inspector walked through various areas of the site to observe
construction activities and to inspect housekeeeping and storage of materials and equipment. During inspection of the Unit 2 Reactor 3 * .- .. - - - - , -- , , - ,e.-
. . ( ( . ' ( ' .) ') 470 . . . Containment Building (RCB), the IE inspector observed that a protective , cover had been removed from a pipe penetration (M-39, Component Cooling Water) and a steel hook, used to support scaffolding on the exterior of the RCB, was in direct contact with the weld preparation on the end of the penetration inside the RCB. ~ This condition is in noncompliance with Brown & Root Procedure GCP-35, " Storage and Maintenance," Revision 3, which requires that protective covers be intact, and 10 CFR 50, Appendix B, Criterion V, which requires that procedures be followed. 4. Exit Interview The IE inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on April 11, 1980. The IE inspector summarized the purpose and the scope of the inspection and the findings.
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CDMhbbf Ilouston Lighting & Pimer P.O. Box 1700 Houston. Texas 77001 (713) 228 9211 . . . - . . . ,... . . . .. .- . . . - . . _ - , - - - . . . . . . . . - . . . . . . . . . - - - , . - . . . . . . ..
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>!ay 23, 1980 ST-HL- AE-468 SFN: C-0570 . Mr. W. C. Seidic, Chief Reactor Construction 6 Engineering Support Branch U.S. Nucicar Regulatory Commission Office of Inspection and Enforcement Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76012 SUBJECT: SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION RESPONSE TO NRC INSPECTION FINDINGS DOCKET NOS. 50-49S/80-07 AND 50-499/80-07 Dear Mr. Seidle: The following is our response to the item of noncompliance identified in IE Inspection Report Nos. 50-49S/80-07 and 50-499/80-07, dated April 30, 1980. Failure to Follow Procedure for Storage of Material Corrective Action Nonconformance Report No. S-M3645 was generated to provide disposition for repairs to penetration M-39 in Unit 2 Reactor Containment Building (RC5-2). Further surveillance of RCB-2 revealed other penetrations /
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sleeves without proper end cover protection. Corrective Action Request No. S-285 was issued to Brown S Root Construction for violation of A040KPGCP-35, Revision 3, paragraph 3.6(6) . Recurrence Control _. rocedure A040KPMECP-4 will be revised to delineate specific surveil- lance requirements for mechanical penetrations / sleeves which require .- . protection of machined end preps. The anticipated date for release N of this revision is July 15, 1980. ,~ 0 ~/V < gyg(p 30 ,r .
c\ '. , g8; ting & Poner (Comp (.f . . .. m)
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Page Two '~' -., , ' In the interim, Site Mechanical QA has been instructed by correspondence no. SQA-3708 to perform surveillance of installed mechanical penetra- ' ' tions/ sleeves which require protection of machined end preps on a once weekly basis.' The once weekly surveillances will be documented on an * Examinition Check Form. La* Very truly yours, . A h E. A. Turner, Vice President Power Plant Construction 6 Technical Services EAT:rka cc: Messrs. G. W. Oprea, Jr. M. L. Borchelt (CPL) R. L. Range (CPL) J. B. Poston-(CPS) A. vonRosenberg (CPS) R. L. Hancock (C0A) . M. C. Nitcholas (C0A) H. R. Dean R. L. Waldrop C. L. McNeese D. G. Barker R. A. Fra ar W. N. Phillips L. D. Wilson G. B. Painter M. D. Schwarz (Baker 6 Botts) C. G. Thrash (Baker E Botts) 11. S. Phillips (NRC) J. R. Geurts (B6R) C. W. Vincent (B5R) STP RMS B6R DCC - (
' ' [ pac E\ ~* o UNITED STATES ' NUCLEAR REGULATORY COMMISSIOw REGloN IV j[ " y /./ h ' & p 611 RYAN PLAZA DRIVE. SUITE 1000 O* L I o /-[ ARLINGTON, TEX AS 76012 M (LO % ***** / June 9, 1980 G 6 f N \YM Rms In Reply Refer To: RIV pC Dodet No. 50-498/80-07 50-499/80-07 / L Houston Lighting and Power Company 1ECEIVED ATTN: Mr. E. A. Turner, Vice President . Power Plant Construction and Ij(jf] j p }gg) Technical Services Post Office Box 1700 ; Houston, Texas 77001 ' "OUTH TEXAS PROJECT Gentlemen: Thank you for your letter of May 23, 1980, in response to our letter dated April 30, 1980, regarding an apparent item of noncompliance. We have no further questions at this time and we will review your corrective action during a future inspection. Sincerely, h- W. C. Seid , Chief Reactor Coltstruction and , Engineering Support Bra 6ch
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> ' ( - ST-AE 53 * 47.) SFN: C-0570 * UNITED STATES Date Recaived: 4-20-81 /p urug%, NUCLEAR REGULATORY COMMISSION ' * t} l '""n'a$^$^. !bi'?#5" /1[xqxb 1 - ' ~ b $l f. f - .. . .... April 17,1981 - : 2 ', . ' In Reply Refer To: ' RIV - . Docket Nos. 50-498/Rpt. 81-13 50-499/Rpt. 81-13 2d _.CW RECEIVED Houston Lighting and Power Company g g .3 3 g g ) ATTN: Mr. G. W. Oprea, Jr. SOUTH TEXAS PROJECT! Executive Vice President Post Office Box 1700 Houston, Texas 77001 Gentlemen: This refers to the meeting held by Mr. K. V. Seyfrit and Region IV staff members with Mr. G. W. Oprea, Jr. , and other members of the Houston Lighting and Power Company and Brown and Root Company, Inc., staff on March 23, 1981, at the Region IV Office in Arlington, Texas, to discuss the status of Show Cause Order items in regard to resumption of ASME safety-related welding on a regular production basis. 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 the inspection report will be placed in the NRC's Public Document Room. report contains any infomation that you believe to be proprietary, it is necessary that you submit a written application to this office, within 25 days of the date of this letter, requesting that such infomation be withheld from public disclosure. The application must include a full statement of the reasons The application should why it is claimed that the information is proprietary. be prepared so that any prcprietary infomation identified is contained in an enclosure to the application, since the application without the enclosure will - also be placed in the Public Dccunent Room. If we do not hear from you in this regard within the specified period, the report will be placed in the Pcblic Document Room. Should you have any questions concerning this meeting, we will be pleased to discuss them with you. Sincerely, # v Karl V. Seyfrit Director Enclosure: IE Inspection Report Nos. 50-498/81-13 50-499/81-13 - go6b b g
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~ ( ' _, . . . * - . $Y3 , . . U.S. NUCLEAR REGULAT0kY COMMISSION OFFICE OF INSPECTION AND ENFORCEPENT REGION IV Report No. 50-498/81-13; 50-499/81-13 Docket No. 50-498; 50-499 Category A2 Licensee: Houston Lighting and Power Company Post Office Box 1700 Houston, Texas 77001 Facility Name: South Texas Project, Units 1 and 2 Meeting at: Arlington, Texas, Region IV Office (March 23, 1981) Approved: ku.'/Yrdb5 & Yk7h1 Date ' p. V. Seyfrit Director, pgion IV Reviewed: M6 == W. A. Crossman, Chief, Projects Section No. 3 [[/J ' ' Date // Meeting Sunnary: Meeting on March 23.1981 (Recort No. 50 198/81-13: 50-499/81-13)- Meeting Tooics: Announced meeting witn corporate staff memoers of Houston Lignting anc Power Company and Brown and Root Company, Inc., to discuss the status of Show Cause Order items in regard to resumption of ASME safety-related welding on a regular production basis. .
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~ i ( (, 1 4~6 ~ . . - . ' DETAILS 1. Persons Attendina Meeting Houston Lichtina and Power (HL&P) G. W. Oprea, Jr. , Executive Vice President J. H. Goldberg, Vice President, Nuclear Engineering and Construction D. G. Barker, Manager, South Texas Project R. A. Frazar, Manager, Quality Assurance Brown and Root Comoany, Inc. (B&R) W. M. Rice, Senior Vice President, Power Group J. R. Geurts, Vice President and Project General Manager R. J. Yurpillat, Power Group QA Manager Nuclear Reculatory Commission, Recion IV K. V. Seyfrit, Director J. T. Collins, Deputy Director J. E. Gagliardo, Director, Investigation and Enforcement Staff G. L. Madsen, Chief, Reactor Projects Branch W. C. Seidle, Chief, Engineering Inspection Branch W. A. Crossman, Chief, Projects Section No. 3, RPB R. E. Hall, Chief, Systems and Technical Section, EIB W. G. Hubacek, Projects Inspector, RPB 2. Meeting with Corcorate Staff a. Purpose of Meeting The purpose of this meeting was to discuss the status of Show Cause Order items in regard to resumption of ASPE safety-related welding activities on a regular production basis. . b. Status of Restart of Limited Welding By letter, dated October 2,1980, Houston Lighting and Power Company (HL&P) requested limited restart of AWS and ASME safety-related welding and placement of complex concrete. An IAL, dated October 3,1980, K. V. Seyfrit to G. W. Oprea, Jr. , established that AWS welding in regard to re-examination, repair,
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and limited restart was allowable, but restart of ASPE welding and
i placement of complex concrete were not allowed due to incomplete
corrective action. On November 19, 1980, HL&P updated their October 2 letter to the NRC and requested limited restart of ASPE safety-related welding
, l in accordance with a scheduled plan. By IAL, dated November 21, l
- 1980, K. V. Seyfrit to G. W. Oorea, Jr. , limited restart of Ast1E
f ' safety-related welding was allowed.
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' .- - , ( ' * 477 ; . - . t * On January 5,1981, an IAL, K. V. Seyfrit to G. W. Oprea, Jr. , allowed expansion of ASME safety-related welding in accordance with a 10 Week Work Plan. By letter of March 13, 1981, G. W. Oprea, Jr. to K. V. Seyfrit. HL&P requested resumption of ASME safety-related welding on a production basis. c. Discussion A meeting of HL&P with the Region IV staff was held on March 23, 1981, to discuss the status of implementation of corrective action in regard to Show Cause Order items with respect to resumption of ASME safety-related welding on a production basis. During the discussion, it was d:termined that corrective action had not been adequate with regard to the cuality assurance aspects required for resumption of ASME welding on a production basis. Consequently, the RIV Director pointed out that implementation of Show Cause Order item corrective action was not complete and ASME welding on a production basis should not commence. The status of corrective action did not, however, appear to be so incomplete as to preclude extension of limited ASME welding. The Region IV Director re-emphasized the need "or the licensee and his contractor to thoroughly examine and complete corrective action in areas of the STP Quality Assurance program so as to fulfill commitments to the Show Cause Order. The licensee attendees acknowledged the eroblem areas outlined and agreed to concentrate their effort in these areas to complete adecuate implementation. :
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.. . . . . .. . .y. :. g g..pp,q.ggezy,y , y2 g.gg3 . ... .. 3. . . : -- ;. . . . . . _. . . ,, ; . .e : a: . - . r - . : . . > f - * 5 . . A o"s etJ e . . 2 . I . .< . . 3 s a .< s ,ct o , > .o-.a.,cv s ts - . sci 1 n .! : . v etr e- , co s tro:c e , u se ing .:. .e m.. .-; . .- .. .: . e. s -e.~ c w ea"* 2 N *i - i- . - n a iew,ia. . ** . * . C4 :e".m' 1- a c0=c hatica ef a*t 4* tes wa'** c *'** "*.*e'.e s aN N* [ e l'c ese* { o* o e; **nima'.ly setts:a:t:~. sdeety ed *?%":e. , , ** g; ,;esietes ,c-es* g * Famagemea.1 atteetten er intel'eewt is 4:*e7*A: ;. sa'ety, cut ...kne n . aee e.ac -1: l ice-se -e sc.~.-s *w' u * * ! . firainec c' ect eddective*y c -2 s 4' trat o'i'ea' * et*8f' / T pe-f o*=a9t e wi'.."1 ret et', to c:* re.$ eanal sa et 60* h hE aed h ceasee attertice.' shog g d t- &*. ,9 MU'" e aHC. II " { a c'ti e w ed. , , *. . * U I. Sumradrv cf Resetts !. ! . . ru,etions Areas M ? 8 - M ,. ' 1. Soils anc Fo maations ' 1 I s - 3 2. Containment and other Safe:y-Related .. . . : Structures s, . .: ..' 1 4, t 3. Piping Systems and Sappe s M g , - ; - " ,.. ~4 S'afety-Related Components , - J';* /i. .. . , , 2 [ . - 5. Support Systees . 1 M h 6. Electrical Power Sucaly and ( * i Cfstribution ~ - . -1. cn M v f. . 7. Instrumentation and Contrul Systems - j ' . , ;* - - 8. , Lic using Activitits - . . - .'h - 4 . , . - , , Corrective Action and Eep:-ting 2 * / 3. . ,- .,- . . ' N. . . .i IV. Performance Analvses . h. . ~]- . .M ao-caf s.a! * ,M The SALP Board obtained assessaeet data aWica:ie The cata _t de- tM Sou~* Texas '.!" . 2 period of July 1.1980, to Jew ~aJ.1981.a .aly:ec and a pe"y u.ance ar.alys* s mas Project (SIP) was tabulated a-w: y .- . *] , . ..{. a developed fcr each of six fi.r.cior.a1 areas. . .The SALP Bosed set on Oc*.cder 15. IS8i. to rwiew t:se perfe-maxa , , " rf Eeoo"~-- ",.1 anal yses and supporting data a-c to ceveloo the SA*J Eoar: , . . t .. -.. i . - g.. .. 3 . .. . ~.. . . . .y ., . . - 1 4 e.;-e2 + c). .. V. . , . .1, - .;. * . ,. ' < . . g * . * '* -n ' ==.- g a - g . .g .,,....----w -- . - * s' ,, , **- . 4 - . < ~ 1 e .. _ - .. - .p ,4 .) . . . . . ' ,
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, w s _* _ _ _ . ' ' '**L-- . s M.- :3T . * 'O'1 !*1%.; * C 1.w E. '* n.- SG & 2. d' iNu':L., $' ***NE - s * * * , , . . s- . .. 481 - . . . . . '. a ~ 4 . . .a' - s, ,. 4 . a.,, e.a yg., * 9 - 1. Sc H a n 3:.reat ea, , s . . . All acUnities coas;etec - . 2. Co-t 4 ***et arc et%** Sa'et eee*atec St=a tu*es * = . f Li mt i ec wo% Ns twea c. ease -eiative tc coetafrweent coacrete f. , acev e.,. e .e.e.. t.: ,,-mit a,ces .e-e ice miec (a) e,wre : 1: sa'.Ma*n/fasaec* *-s ee:11st, of leoets. a*c (t) *ailuee 1 test t 'c' air teetemt c' g cat. ti-ate weet ef'=rt ette*ve: Sirce t e i , itceat ee lif tec a sei* # .:: sed sta= worn e- er 420*a-*c tc Je * .. sat s'a torily re-*ce--c. ' * , Cre no-ec.r:1f aace was ica -1*ie: in the aree of et%- safety--. stec * - s t-.;t.rro s: fa41u-e t: assu e inat p.:-chase: pa*erfal (ins u ct :n ! 3 of helsen stud welcin- : ee:e n ) co-ferves to :r:cu eeent .l cc:eens. This weic =; .as pe-fo-med aad irs:ectes initial;* ty - - . .- , fost-o ter;enThis and was a;ain inscectec by tre.n & R::* (544) eene:r 4 tee eac several 50.55te) reperts have inci etec a I ', * . I Inspectors. weaa ness in the E.M vexer su-wet 11ance progras. P-coer cor-t:t =e ' 'l action has been tamen 1: ccrrect this programe.atic weats.ess. .'. j , The Beard considered ma 4;ement control in 'his functional area to
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N i 1 . be of a Catego*y 2 level '- ~~W' . e - [ *4 }, 3. Pieine Systevis and Suce.s I i e .- i Region IV has peeforoEc we y little insoection in this area f * two ' . : reasons: (a) ht: effo-ts have been concentrated on CA progrewr.atic d ' 1 areas. and (D) the voi ame of wcet activity Pas been 10w. IP rT'en* a A months. were n.as stocoec in ,this area to allow design engirmev irag g. , , * . .]. ' . to catch W . . . ->" . ,t3. - ... . The Board die not make an assessment in tais functional area. . _ go- .* ., 4 Sa*etv-telated Comecae=ts . Yneludf ac Vessels. Inteenats and pu s '. l " 2 , , 3 Werk activities in t*:is area have been very low relative to s.e-ting . i ~ - -I equi >=ent because: (a). status of construction, and (t) sanc=iast * t 3 activities inside Unit 1 Containment and Auxiliary 8vilaings. ' h 4 _ 4 f.ii ^ . 't One nonconfermance seas identified as a generic preolee in IEfailure to fdif ow proc 'l ' ,'.,8 ~ Beport 50-498/61-01: M-09/81-01:. ,,Id - ;? storage and saintenarce of ecutoment. Cerrective action te da Ir*' i 'f' , sepears to de Seewte eut final follow-up insoection cas net seen - , c 3.)1 coegleted. lt _ ?l4 .* .' w . ' *. . i .'.a a , *'. . y. . . .a . - - 4 . .s a I ,.,, f J ' = * 7 .. . . . . . . . . . ~ . . . . , . . . , , , , , ,,_ _ ( .; , . .. 1 " - . . .a., - * .; . ' 3 * . . i c: - u S * . g a*. .4 , . ... r o I > . . .< . 2 4 .*. 0 , e 8 . $. ' P . . . . . . . . . - - . - . - , , , . . T *^. '. . . ','~ "s . y*, j u~ .. --w s . . . . . - . ~ ..a s , :.; * . * . .; ; ' 5 . . em
Wi&.c.W;? '.ez.;. id=;GWkiMhk%s%i?S'565#5.%9hb&hus1QQbn . - . . . , . ; .. ,. - ..e...... . . . . ..s . .. ...... .. . . . :. . . ... .. ..... . - . ...,.. . ..,........ . . . : . . . 46o . .. . . . .. . , . - 5 . , *I , . - - .:: mee te ii.,te. -rs. t e m-= e,c not a,,,,, in,s a,a. : - t ^ .. * 1. Socee-t 5<st,.. t e.c us i n.- e.ac a. 34.te . e c a -, e-e t ,-. , c.: . I 1%e's -es lie' icd wo-t in tw areas of ree.este anc '8 v n stection- [ ow-ing t e assessmen pe-*oc. No precleos we-e icentiftec ir trese [ ace 4s curing tais tiw , ( . ** 9 ; On % v E. 1981. HLLS no?8*.e4 cegion IV in ace:-dence with l * It CM SC.55te) ef a co-s -scisca ceficiency con:e m x ta.e 8 t* ,' ' ecas 'aecation et ce-tat e 's.:*teo con:itier reat teacs t.- tAe cesiga , of porticas cf tFs 6 40 syste= (see ite.r v.1. c. (10M. . . octe"ca .ior .as =a se. tese: on an assessee .t ef p-e h s:rary ' i * tSema n eav3 -onsental cat.a. the t terta **: s:sces a.ac cuc :-e.e.e es .'ts.in . the P!t? a=,: F-3 -ov1d m.*-e aceitica41 Hva ca:act:3 , j week relating to inis ites .as r.alted cae to c'saa.gecie- c' a Es for g STP. . ,. ,? . .. . ,j The Board assessed pe' *c-unce in this functional ana as "ategc y 2. g, -i l l * + 6. Electr4 cal po-ee Su elv a : C" s te'bu tien 4 2 '.: <. g l vu , g No work activity has occ.--ed in this area; however, t"# storage and g,
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. . maintenance has Leen inse.mted and a;; pears to be generally .d d..7 * J ' satisfactory. 7;, ,.' .g . . - -. .-- - ... .j No assessment was mace in tsils area. . . - . * s . . * * 7. Instrumentation and Cent-e1 Svstees . m . * )j . . . , 5ee ites 6. above. , a * . . , d Licensine activittei , & - . - 8. ,' * i h ; c. Licensee activities dealing with Itcensing requirements have increwed ." . ~ ~ ; r- .. 1 significantly curing the vrting period. - 8esponses to reowests for information .have been timely and of good ovality curing tne . .;~., ; ;. .J.- - .. .3 -g - reporting period. Licensee unoerstanding of NRC requirveent.s is .'= - adequate. . ., . .a . The Beard assessed the licensee's performance in this functional *'j .. - , area to t>e Category 1. ...- .. . * - - . S. Corevetive setto'ns and tere-ting - ,e ;. . ;- . . . . . ....' - . . - - . The constructor (BAR) c:v tinues to emperience difficulty relative to . , . ~
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- corrective action. It a*so acoears tnat the rect.cause of toe t probles associated with M : and 11:ensee identified ce*iciencies is - ']'.' '/. ".i that the oeficiencies are stet ef fectively correctec anc are not i ', . ' ,% * : corrected in.a timely manner. *u. / .. t % ? .g .- . - . - , . * ... * - . .. p % , , Lg . :7,4 .. . . . .s s 4 . . . - . . . . .. ... . . . . . . . . . . .. , ,, * ,, j - I * .
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.;) . problem. associated wita MR* and ifceasee icentifiec te'icie icies is - - , that the deficiencies are not ef fective y correctee a,c are not 7 ctreected in a timely maarmee. . , . , ' F. . . ..
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f . . e . % . . _..; * ~.' - ~ - .~ ~ ~ * - - v.- L.W. . - _ , . , . . _ ' ._ c.g _ . . ~ - 3 gg._ *. _ - ._ #. .;.33; * 1 ** .' ~ me 9* ' , , . * h.*.ay. *.'.. * .,P' 5 .' *. . ne * 'j . . . ....=. ...=..a.*'.e.fi * , i. y - *. . .- . . sg .. . , . .* * . . s,. .,.,.f...... . , s> . g s. y -s . f., #r;t ,s.*j.. ** e . , , , .c . 4 .. . . , ._ * ., . * . .o . " . - r - *,. . . ) . 7 - , e ? * . - ~m ; - l e,ettre "at. anc S w a-.es .'* e- , ,. : m , f. e . .. ...w. .** , pe c-ts **at.a % s a. Lit hun:>en Kevie ed (not a;olicatie) - I. , & b. Const vetion qv*tetency tecorts E- * , ".e liceasee's syst.e 'er repo-ting c nst%ction ce*tciencies * * is treatec in the % ston =ffices. .' enc 7encies in-tif ied * c s* e are fe warce: to tSe Instoer se ie. C # tice ;IRC) for ' t o ".atica. ![ :nsocetien Eeport 50- m /n-07: Sc-anfu-p - f, c . m tea a reve*w cf pis systee nc- inclocec G) revie.irg ' , licersee written *epo*ta ter 196*. aae (?) rew'ewte; 5e IRC f. .~. . e.a bations from April 25, 1977, t J. y 3, lit 0. g a lleven reco-ts f=oe July 1, 1990, t: June 30. 1c51, were rewte ec ano evaluatec. These cef4ciencies are desc deed below: < * ..w ' ; .e . j , .. . .g (1) Cesign of Au.ziliary Fee 6 ater Puse (All envirennental (.'.( . .a . . , ** ,e. factors not consioe-eo in oesig'*.) .J- .j . (2) Savakcown fr. 08. Prog am Relative to Acclication of Paint ,, u . .".q s , . ; to Steel and Concrete Surf aces beept for Liner Plate - , .1 . * ' 'J4 . , (3) Reactor Containment Building Structural Steel Seems Leadirg , u,, . * y.f . * . * (a) Unacceptable Surface Condition of W1d in Main Steam ,d s' , . 'f Piping and Seconcary Shield Wall w' sip Restraints . ... , 1 J f; .. ~'8 (5) Cooling of Primary Shield kall Penetration Insufficient - . . . .3 - Air Flow Between Reactor Cooict hoz:le anc Seal Plate " :. ' @] ;; , - .- . .. * ,,! ..! .' (6) Inacequate Cable Tray Hanger Design ~ _ . . . ,, - - ' ,' * i - (7) Hilti Anchor Bolts Design Strength Inaceovate -, ,'- J. '. , , : .: . - _ r -( . A ;t . .!ik . ' - s '.? '.; ,,. . < 6 5 , : . (8) American Bridge Structural Steel Welds Deficiencies t 4. f. ..w - A. - , .- % --a c.. . . ' r. , , . (9) kon-Approved Hilti Revised QA manual . . . . - - ' . .-?r a.,j . ,;j * 's . _. .,.f. ,] (10) Faulted' Condition Heat Loacs in Cesign of Portions of the 8. ' HVAC $ystee - - = . , <J * * ~ - . v.y 3 , , . . ."~ . u- - . - ' ' . .. . ' ':'j .. . .(*4) Computes Progras verification . - - ~ ~ ~ *ft .* ' - 5 . ' d, A tre was noted relative to the deficiencies reported;*that L D ' J . is, 7 of.11 were design problees. As a result of this r . /d . - ' '.j * trend and other inforeation. _a special NRC inspection of the - ' . *. ... . . . *d. - .s . r p. ,. ;i - ..A . . . . . .J , .,- ., . . eq . .e .p^ :.1
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i. , OFFICE MEMORANDUM August 3, 1978
. ' Mr. W. N. Phillips ST-HL-10099 To SFN: C-0570 4g1 from Mr. T. D. Stanley Subject South Texas Project Electric Generating Station NRC Exit Interview Su= mary of July 28, 1978 FILE COPY . - . The NRC, Region IV Office, was informed by telephone of specific allegations pertaining to the B6R Civil QC effort at the South Texas Project. On July 25-28, 1978, the NRC performed an investigation of the allegations. The NRC found no items of noncompliance and discussed one area of concern with Mr. Viaclovsky and myself on July 28, 1978.- The concern will be discussed later in this summary. n e NRC interviewed a number of B6R personnel during the investigation. ' The allegations that were made are noted below: // / (PA.04CE.O _ 1. Civil QC Inspectors cannot do their job properly due '. 6/. _. to insufficient training in the new integrated proce- dures. - ,. . . ~. - 2. Inadequate nonconformance reporting system. Here exists a reluctance by inspection personnel to issue a Nonconformance Report (NCR) because they do not un- , - derstand the new NCR system. _ 3. Poor document control of drawings. Th e do e hbtb) inspection personnel require are not b ring received by them in a timely manner. . 419/3 4. Inadequate Cadweld traceability on as-builtsg3fppg in Unit 2. 5. Repairs were being made without approved procedures. . 6. Inadequate support of Civil QC Inspectors. Supervisory personnel are not available when needed. 7. Construction Engineering is not doing their job. As mentioned earlier, the NRC found no items of noncompliance as a result of the investigation of the above alleged conditions. The one con- cern they pointed out involves Criterion 1 of 10CFR50, Appendix B. They are of the opinion that QC personnel are performing functions during in- process inspection that are the responsibility of Construction Engineering. QC personnel later perform the final acceptance inspection after they were involved in the in-process effort. They feel that QC is not as independent as it should be. It was the NRC's opinion that QC is not performing over and above their responsibilities, but Construction Engineering may not be doing enough regarding the prime responsibility of building this plant in accordance with the drawings, specifications, etc. It is my contention that B6R QC is performing it's function adequately. , . 4 , , H0095212 , -5 - M
-_ q ~ 1 **~~# l . "'I L.ighting & l'0%t: . . H0usl0B s 3. 2S78 < 133 ' OFFICE MEMORANDITH S _ L-10099 402 L SpH: C-0570 n= To From Subject (Cont.) . examples and/or instances in- ific f The <h The NRC Inspectors d allegations were given specby the personnel who werewith ~ involving the above mentioneThe NRC discussed were observations and/orthese opin oThere d on by were, however, tcrviewed. mmary. discussions which dtook out placeNRC which are presentlyand are not being included workeiined this esse su t:ntial problem areas pointeIt l and did not should bediscuss However,noted any that the NRC of these the NRC rece v could B4R. input from the B6R Civil QC personne truction. dation of quality at the South items with QA Management or B6R Consfind no substa Texas Project site. 5P take no specific actions i as but that It is this writer's opinion support HL B5R QA Management h in the r a result of this investigation, i i s and to maintain control of t et efforts to establish firm site pol c eQC function on sit cet. ject requirements are SAV:rkh cc: Messrs. E. A. Turner R. A. Fra:ar H. L. Key F. D. Asbeck .
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H0035213 -- -
.- . . . - -o- y e ,. . ,. . ." , . . , . . ' .; . . . .. q,;: 9.pve :.=.. A. ._ ' - - - ~-- % , * 1 . . ,,.y, k.;. 7 ~ .h , , j'8 'ghgl h * @av g 148l. - 4S3 y:F.p . Ber. T. D. Stanley o ics;uinea4 move - N , g g,/ hat - ; (g'~.i . . ' ' ' . . * [, ' Augast 23, 1 e ' * * ler. 8. A. Viaslove - w . \ . ' south Temas Project Electric Generattag Station - .,p . commmmu nessedias NaC opinians . . - : ,. . - , j . ; (1) Morste: Disgriastled employees should be released if they ase ' , "dHIEIing yuebleme. Easpectisa perseemet mast eest la asser6= . l , ; esse with annasement smideniase er direesives. , . . j ' (2) lana punch-11sts's QA/QC sammet stap identifying these Frob. , . , . ' - leen. s4R C.anstruction should beef op their staff ae problems saa be identified la a timely amener. , - (3) Preparation etter to inseeetions: 841 4A/QC has providad in. g . nyecsers with sa area to use for plasming purposes. BS shoald . < - add additional perseemet to alleviate the owedurden; housver, , !
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1anyection ,..; -- 9 have been edespnesely morettag assivities 1 .
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- with no esmycenLee in quality. -! . . . "--a ' '(4) Staff 1ntt As noted above, quality has not been % . as Eeuth Texas. *h that ML4P and SE add pereennel to A114= * > ~ viste the sve durden. . ; ,, Y
i
- In order to define det is exyIseted of 348 (WQC a asesing ens held , !
I j en Angmet 23, 1978, d ish involved the attashed asserendial. This is a '
very positive stop. , , , ! The shove Atoms have been identified ensly Dr 243 and attempts
l there. bas been no degred- ! are betag sade to obtais relief. In my op
* atlan of steality at the South Teass Project site. In affisies, !"'47 sits t> 1s follouing up en itsee that es imC identified as pesothle poublems
, t '
' during their resses i _:<--**= et allegasisme. ! - There has been a mober of site pereennet shnages la the 343 site . 04/QC ammagemmt ranks ever the last fem aanths. These shanges sore en-
l '
finitely positive. la order for the South Teams Project GA/qC N to faction effectively these pereennel regaire our espport. I fest 13 8 if * 4 ' HL4P andesmines this basis annegament saan the Frejest will supericnes 1 ' greater problems. In eenslautes, this job is a teen effort and Bf.1 kcl = / neerlag. 84A Constructies, ets., uses sentribute their share se sabe thisl_g{l job a enneese. l - . - .: , b . 383F8 . I 1 ' t ! . . - . 4 . H0SG1856 V i - ,., ,. - --.m s.maa i __ _ 1 8 '- " - T]g __ ( -m n 7 ,7- -- ._- . ,,_ __ , ,_ ' 9 O *g "s ' A A g [f,. e mmmm. * . 4 ,' , L \ ( 10
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. . . *I . - 00 2.f 340 aa - .-a-n gf , - 4 Brown &RootJnc. poet cAs s. m ae, o,, re.ee Am 14'7 . - " - gym -t BATE: Au pet 24, 1978 in: All STF9CE QA/qC 7 : i .X3 30: Fatal: C. W. Timoest . 30: St>-169 SERIsCT: Operating Policy and Ceedmet of STytG8 Ek/QC perma ===t A . . It hea heen brought to my attestion that there is ecue coefusion It la sur or misunderstanding re,epossibility to ver- as to ear (QA/QC) responsibilitiae to the STFECS. _ ify that this project is constreated la compliance with dec e nata. It is Cae- the appropriate designIt fa n a w f=. This reopensibility La assigned to ME Bauston Basianering. d ith , stractime's d-- responsibility tm . to erect sad fabricate the STFECS is accor ance win verifying the acc thsee design 'rication of BTF908 it te espected that yee will follow to the latter the precedurseIn se e applicable ta avr projaet.Obrimmely if clearest vialatione of Cedes, Standards, er safe of this project. practices are ebeerved La the normal saurae of your work, the conditime unst he re- Ported to year esparviser. If fer whatever reases yew It is have a geestian as his roepomeibility to to abat directies provida yee with that to followsupport. yee are to eenemit year empervisor. I nomid slae like ta emphasLas chet ie is all of our respeesibilitisa te perieru EG8 ser taaka in the moet ==T*'hissa mesmer possible ao as met ta enduly Leyeet the sty 'esestractims # 'im. In the performensa of ear job it is espected that so will aimers seeduet euraalves If in the perfernance ef your jeb you ah==ta eneouster is a prof assiemal meaner. othere she are met sendmeting themmalves in a profeestemel mammer, report this to year asperviser and he will revies the 4==ta==t and -tact wbsterer lassis of . --* required to reesive the prehlen. If yes enemuster It ta set necessary to put op with verbal -u --* forabuse eerrecties. free say level.this, pleas The separviser will report this to the appreyrista I would alas like te bring to your ate == Mas that 3 are all trova Talklas & Reet employees. I de not believe that any of me does see meat te do the best job Flessa possible. keep does te people will set centribute to the melation of say probleme.these c ' . ' ' x, d W . v. vine.se 7 ,- - . . . . - * I , sTr Project QA Manager ! ... * ,----./ , . ,3 cw/cla . - - . - . . . * * * J. N. Salvitti ( ect T. E. Canoe 8* A* T18e18'*k7-(31AF) / tl * . ' * . 5. Paperno _/ 'I Y_ g . J. R. Meeree FI12: A010Q tE;D .r e la , . . -. ~ *.-- - _ , - _ -- /.. . _ . -- ._ , e H0340066
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