ML20211F514
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| ML20211F514 | |
| Person / Time | |
|---|---|
| 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
Text
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE. SUITE 1000 *
j Q. ARLINGTON. TEXAS 76012
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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,
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W.C.Seif1h, Chief
Reactor Cohitruction and
Engineering Support Branch
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8610310187 860930
PDR FOIA
GARDE 85-378 PDR . . . . .
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RECEIVED :
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FEB 291980 -
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.5OUTH TEXAS PROJECT ._
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Lg 432
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' =\ /go REGloN IV
Is 'i o 611 RY AN PLAZA DRIVE. SUITE 1000
ARLINGTON, TEXAS 76012
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% ,,,,, / January 10, 1980
Is Reply Refer To
XIV
Decket No. 50-498/Rpt. 79-22
50-499/Rpt. 79-22 .S
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Houston Lighting and Power Company iE2
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ATTN: Mr. E. A. Turner, Vice President
Power Plant Construction and -
Technical Services '
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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
!
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.
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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
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U. S. NUCLEAR REGULATORY COMMISSION
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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: %= -
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W. G. Hubacek, Reactor Inspector, Projects Section ' Da te
Approved: /
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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
.
one NRC inspector.
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Results: No items of noncompliance or deviations were identified.
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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
7
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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storage.
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j, During the tour through the Unit 1 Mechanical / Electrical Auxiliary
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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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"A"
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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.
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5. ASME Certification
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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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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
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Class CS core support structures at various field sites, subject to site
audit.
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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.
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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. -
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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.
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a o UNITED STATES
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[n anc,%,, NUCLEAR REGULATORY COMMISSION
O\ REGION IV
n sit RYAN PLAZA DRIVE,sulTE 1000
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ARLINGTON, texas 7so12 g, AB *p.4*
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+ n'.: 4p'* April 4, 1980
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In Reply Refer To
RIV
Docket No. 50-498/80-04 ,_ ,. ... u
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Houston Lighting and Power Company .
ATTN: Mr. E. A. Turner, Vice President
Power Plant Construction and _ 3 , .y .g
Technical Services ,
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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
,
- the reasons why it is claimed that the information is proprietary. The
l
application without the enclosure vill also be placed in the Public Document
j
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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Houston Lighting and Power Company 2
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Sincerely,
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W. C. Se(die,
d Chief
Reactor Construction and
Engineering Support Branch
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Enclosure:
IE Inspeccion Report No. 50-498/80-04
50-499/80-04
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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
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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
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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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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 . ,. ."
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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
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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.
4
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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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.
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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
,
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
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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.
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* 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
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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
l
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
,
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
l
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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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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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.
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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. ,
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APPENDIX 5 . 01 J
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Implementation of the 453
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Quality Assurance Program
at the
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South Texas Project Jobsite
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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
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Implementation of the -
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Quality Assurance. Program
at the
South Texas Project Jobsite
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!. 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
t
Vice Preeldent & General Manager
!
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
l
ond project general managers at South Texas Pro. and to the public. However. Quality is the top con.
l '
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.
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cainot be mots easily resolved. The QA/QC
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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
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. 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
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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 -
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,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-
'
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
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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
, l to relan them where required. are aware of the situation.
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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
'
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'
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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
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. 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
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EROWN a RSOT. INC. STP.PGM.02
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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
/
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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.
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STP.PGM.02
4G3 decision la charged through the foregning pre.
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** 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/
l
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
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pdc o UNITED STATES
o, NUCLEAR REGULATORY COMMISSION g g f
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611 RY AN PLAZA DRIVE, SUITE 1000
,; a ,4 % ) o
ARLINGTON, TEXAS 76012 g b3 ., g
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**** 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
l
NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
l
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;
'
(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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Uouston Lighting and Power Company -2- April 30, 1980 4G5
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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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, 50-498/80-07
50-499/80-07
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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.
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U. S. NUCLEAR REGULATORY COMMISSION
,
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).
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DETAILS
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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.
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(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
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. 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.
1
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CDMhbbf Ilouston Lighting & Pimer P.O. Box 1700 Houston. Texas 77001 (713) 228 9211
. . . - . . . ,... . . . .. .- . . . - . . _ - , - - - . . . . . . . . - . . . . . . . . . - - - , . - . . . . . . ..
- . . . .
>!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 /
-
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. ,~
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,'i bby 23,19S0
Page Two
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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
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o UNITED STATES
' NUCLEAR REGULATORY COMMISSIOw
REGloN IV j[ "
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611 RYAN PLAZA DRIVE. SUITE 1000
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/ 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
/
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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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RECE!VED
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QllAl.lTV P?!" tar.F.
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* 47.) SFN: C-0570
* UNITED STATES Date Recaived: 4-20-81
/p urug%, NUCLEAR REGULATORY COMMISSION
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April 17,1981
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In Reply Refer To:
'
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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
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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
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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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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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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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Systeaatic asassmqt cf .ue-see ss -ea m ce
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Repo*t: E-4%/SI-37 -
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Dockets: 50-4M & 50-499
, Licensee: M uscoe LigSting sec Pe.e* Co eany
P C. ica 17CO
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Aporaisal~C moletion rate: Se::te*cer 1.1911
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' Licensee resting: Ceteber 15, 1581
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.j SALP Soarc:
W. C. Seidle, Chief, Peacto* P-ciect Branch 2
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..) W. A. Cronssan Chief, Reacto* P-ciect Section B
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N D. E. Sells h12 Projec*. Manager
.J H. 5. Phillips, Senior Resicent Insoeetor
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W. G. Pubacek, STP Transition Coordinator
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. .] R. C., Stewart. Reactor Inspector
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J. I. Tapia, Reactor Inspector
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Approved by:
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W. C. Selole, Cr.tet
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Reacter P-cject Branch 2
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1. Manageernt invohevt in assuring oua!*ty .
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*9 Attribv.es associates sta the atove eval.atica c-iteria fars the
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7 one of three categories.
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, "' Cateeory 1: A combination of attributes' w*ich creenstrates achievesent j
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A costi'4ation of attributes we.icn deeonstrates achieve,ent
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ru,etions Areas M ?
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IV. Performance Analvses
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* ,M The SALP Board obtained assessaeet data aWica:ie The cata _t de- tM Sou~* Texas
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2 period of July 1.1980, to Jew ~aJ.1981.a .aly:ec and a pe"y u.ance ar.alys* s mas
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developed fcr each of six fi.r.cior.a1 areas. .
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2. Co-t 4 ***et arc et%** Sa'et eee*atec St=a tu*es *
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cc:eens. This weic =; .as pe-fo-med aad irs:ectes initial;* ty
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4 tee eac several 50.55te) reperts have inci etec a
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weaa ness in the E.M vexer su-wet 11ance progras. P-coer cor-t:t =e '
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action has been tamen 1: ccrrect this programe.atic weats.ess.
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.- i Region IV has peeforoEc we y little insoection in this area f * two
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months. were n.as stocoec in ,this area to allow design engirmev irag g.
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The Board die not make an assessment in tais functional area.
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activities inside Unit 1 Containment and Auxiliary 8vilaings. '
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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 , (
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; 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
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,' ' ecas 'aecation et ce-tat e 's.:*teo con:itier reat teacs t.- tAe cesiga
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of porticas cf tFs 6 40 syste= (see ite.r v.1. c. (10M.
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octe"ca .ior .as =a se. tese: on an assessee .t ef p-e h s:rary '
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tSema n eav3 -onsental cat.a. the t terta **: s:sces a.ac cuc :-e.e.e es .'ts.in
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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
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,j The Board assessed pe' *c-unce in this functional ana as "ategc y 2.
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No work activity has occ.--ed in this area; however, t"# storage and g,
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* 7. Instrumentation and Cent-e1 Svstees
.
m .
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.
.
. ,
5ee ites 6. above. ,
a *
. . ,
d Licensine activittei
,
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-
. - 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
.
,
. ~
. s@. s * 2.;A
-
corrective action. It a*so acoears tnat the rect.cause of toe
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probles associated with M : and 11:ensee identified ce*iciencies is
-
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'/. ".i that the oeficiencies are stet ef fectively correctec anc are not i
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: corrected in.a timely manner.
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ceteemirattea m es:e. case: on a.- -
the-eal crd W~ta'.
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c.sta. trat ce ata
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work, relating to t3is ite=t was Pelteo se to span;er.e- c' 4.ts i
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2. (
. The Board assessed pe de eunce in tP's fractional ama as Categorf 't
s f
r. } <o, [
J
6. Elect-ient o w e so tv a e Dist-ieu
- ( n
.
- .
No work activity has occurred in tett seea; hoe eve *. *N storage aad
.
,
j saintecance has been inspected ano aap+ars to be gene-s:1y -
.
-
1 satisfac*.ory.
.
. .? ,
* . :1 ' Iso assessawit meas mania in tMs area.
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,. .s Instrureatation anc to % 1 systems'
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See itee 6 above.
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8. Licerstne Activities.
.p = .
: .
.
- .,. g.s
.
Licensee activities dealina with if censing requireve Fesposses .s *:
rave
reuests to re,ed
..
c. e - p
y *
, *J
r.4 significantly during t.%e reporting period.for information have gbeen
*
.
reporting period. Licensee isnderstaging of MRC res.- e-e .ts is
1
' . .I adequate.
3 -The Board assessed the licensee's performance
4... * - ip tMs fsnctional
,
. 3
" '
.~,
.] area to be Catescry 1. - >
,t
'
<a
e- . .
.ij . 9. terrective Actions aho senortion
+
:.a he construc*.or (B&k}' continues to es5rience cifNea*ty relative to
,' It also appears that stie rtet ca.se of the
.M corrective action.
'
.;)
.
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.
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Th. 8-*td .***s**d Itceesee Pe 'c-rance in this 'uncttu .: a ea to' f
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3 :a.. ,ry 3. .
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.M 2eae l .-. 'a!:
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19 p. 4.1 tease.1 their over alt assessaeet cn re.iew of t he c1 ;.*ogree
./ y, sad on oose v'r; ilmited week activ'tr causec ey
cor.. 4 s ., ec t t oe.id ...tuj tf on Repo* 51-m/79-19; 50-4*5,79p,ve, .;. Sho. cause
.
7 4.. '. q
H-.'**r*tiyGrd" s posec o- I ?w, & Eoot. Inc.. ts
* the it
)1 ,a , and the liceasee. The rating was *ost heavity inf;uencee
.
' cont' *W. taability to c:r*ect tne rcet causes of g cetems
7
try 8t* * #aai in ..: Ttm GA g.repa .'s
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'. and t?.s u,rrerttee action in a ttmaly massee.!argely dependent upo's t
.j j succe.a 16
i ,
* deficf*"'l***
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a
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. ,s
knusta,n Lighting and 8dae- Coscany N' .Se) has ten e
* ' .* A) n ,.,h st.n and actices in the area ceserteed at....e , tne
.I .; af f t,..t s..
j ~. -J
.
9,o), .rje stier, t.f corrective actie9 Peasures
The-e*c-e. the overall and procsJ.
rating sees is still
for licensee
'i . 4 r.4 g .L area.
*
,
.sj c or's i 16 determined to t>e C.ategory 3. because or u.. &p's
p,p fe ....c o
3 .
.
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[ inabilf't go gem I a sigatificant incrovement in S&R's performance
. .- ,,
g in-thsg area.
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. , J*. Boa *d' D [******'*ttens
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79 g. erd recos nded augeested inspection of the $owth femas
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pe,J,e.L theowgh tee transition phase of.cens*ruction and into
a of ce
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a. Lit hun:>en Kevie ed (not a;olicatie) - I.
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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:
<
*
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'
; .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
,,
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. .".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
" :.
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.- . ..
*
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..! .' (6) Inacequate Cable Tray Hanger Design ~
_
.
.
.
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'
,' * i - (7) Hilti Anchor Bolts Design Strength Inaceovate -,
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. (8) American Bridge Structural Steel Welds Deficiencies t
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. (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 $ystee
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.(*4) Computes Progras verification . - - ~ ~ ~
*ft .* ' - 5 . ' d, A tre was noted relative to the deficiencies reported;*that L
D '
J . is, 7 of.11 were design problees. As a result of this r
. /d .
-
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*
trend and other inforeation. _a special NRC inspection of the - '
.
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ces ya eagia.e-4 q'e perf:st ee
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FebdI* s a*e not coa * I A*Ie.
w. e.: .is stili
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-
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c. Pa- , 21 tepoets
.
a
. .
j e * . The 't icensee e.ocete- t.c 50.5He) coesteuctica teec".-dce'ictr inecies as
*" a result of t.: Fa . O reco-ts =eic9 ****
licensee. Tn*se ness a-e as follo-s:
-
i.
-y .,
. 4 r
'4
.
(1) CN!P Pue: Snatt re tu e
. 's
'
.,
. , -
eraau-arent Systet E--:r
* I (2) Steam Generatee wte . eve: ,_
.
'd
Lice-se. Act vit'es
,
2. * '
.
.
3 The lice see's :$nstruct'ce activities P. ave been icwSte: e.;-W
serkt*. ,
..f
*. k@ r.
.
* t
subject ceMeo trecause.cf t.'e MO Show Ca;rse C oer an:
..~ <b T , *
,j C Mers irpose: ty the lice see
" A-Q .Y
*g. -
, -
, (t
4 3. Insoeetica Activities
.
. .,e{.t
'y,,. ./. -;
- '
{ A scecial team was assig9e: toThis follow upcentinvec
en the IE Investication
. ... ef fort a;se-ng the
,. . .
j'
N;,g.~":
<* *C
5. ' ' ^* "; - y 79-13 aN tM Show Cause Orr.ee.ectire rees-ting period at favolves
N.?
.
. ,;3 An insf g-if(cart a*Mer of Srspectee-hev s was
' U.'J;,j n- . ..: inscecte*-bours.
.M devotec to toe routine irs.2ection program because of 'citow-up and
. .:f g. .
-.' .
- a; ,.;:4 retetive inspection. ,
,t*;*y : - .?- '.'.. . ..,
.
.J
..* *
.s1 Tevest ication and A11ecatfeas Review
,
. f. .,.s m. -
; J. e. .g 4. '
bject pe-iod which
' *'i * 4 . . .
-
,n.. .
, . 3, . * .- . g,-[iz.9 ,j .
, . Twelve investigations wre conducted dering the suinvolv
' . {, $ .
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. .below- .
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Mg$
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. -s.e4ect
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. .
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sesults
Ls . i. m. 3
.
,.;*; 4*t*%. * .1' Allegations were net confirmed.
.: ,-. ' , . . .--. . .
a. Three allegations vitative to
.s. ... s. !. .# .' (1) painting receres. (2) seld
eMb 2J' .. .d rod even po wr loss. (3) RCS-2 -
Qh* ? . ~
. .,
-
**2 settlement.
. ,- ?.d4] .
b.. .
.
~
*
. *M. o Specification. imeceper coatingi-
..'% r .,
~
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*
' Se,en sitegations re14Efve to . improper coating recc-es at
.
.- .
b.
3,.%u .- (1) is: roper specification
Q' y;s . p ' ' :.*;.. "*Jl,7. ..,,.h,.
14 g$o - g.51
' --
v'c -
.
'.i 53 ,-]j.M *
. .
revision; (2) fuorooer appli-. contractor were confirmed.
Reentncer were not confireec.
- c.ation of coatings. (3) -
p tb '
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desigt, engineers not
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d.
,i .' site pe*se-w i knewing
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.k forevamec of >RC ins:ection.
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should net have. been pe ' creed.
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supplies improper.
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. .i pipe sleeve weld def ects.
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calibestion. (2) stsrage of
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.
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re ee ttec cer..;t':-
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4
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.
.. Five allegations relative to
.
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ff . (1) construction ceficie-cies
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net prcperly reported. .
'a* .1 - i (2) clearly prometed to prejeci
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.
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' '] , , Four ellegations relative to
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not confirmed, while (3) was
#
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i f? turned over to Regien IV
,
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. "$ systess are not concetent, ~ Vender Inspection Branch,
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Ihe hI". irQ$ leg a 11 % ,C00 c'<** *erett) arc * s t.td a Sh.ier
.
*
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! Cause Omee to tM licea>ce, c i Ac*i! n. ;3 J. A Pee-see
; ca:c tac civil reaalty a . get.(:-c a cw:*-s a 4 :*Li'h:
'
et;,:Pse nn Ah IF. W :* et:tr a v.e . t- t e !*:v. '
A.o st 19. li n , a cu,13 e..* ' r; m "e c :9 -* n M * a-J
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1*ce nsee seaic- w a;e r-? t: : se.s s tr e 4. ;r:. et cnse.
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,
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8
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18 smarized ai* ccm:itr+9 s
.
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?-
; .mact ir. the written retscase. C.re'treits race tetice9 44C a - [
k Ilceesee manapeens, and coarstr4ats ra:e at w xlic meetin;
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in !GP 1etter (Si-rt'-AE Sn) cated Septe-ter 15,15!3.
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4, cia cecice to have' accelerated rearings on t.se Ga ;c".iei for
*
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the c:erating 19 tease to cete*siae the lice 9see aanagene :t's
*
character and carpeterce. , Tr%4 rearings sta .ec o.1 P'ay 12 {
* ,
..
"-
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8 1581, in Bay City. Texas, and a~e expected to eite*4 into late f,
* fall 1981. ,
,
c. Immediate Ac*. ion Letters
y- - . . , ..
"
j Nine irrediate action letters weae issued relatice to *
-
* -The
-
confleming step.wcet actions ta;.ssec by toe lice .see.
*
I
,
4 following is a summary. y
, .
*
,
- .. . crifirming licensee self-iaoosed.
.
(1) Issued July 17, 1983,
, .
I- -
;; *
.J.'..
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.
5tep Work Creer to check adequacy of contacis for Av5
-'
welcer qualifications ard redalifications.
- (2) Issued Cctcher 3. 1963, confirming lice'esee's ceruitmer.ts .
,-3 regarding re examination, repair, and resta :s of Aki
! ']y .
welding.
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, (3) IsIued Octoter 22. 1980 confirwirq iicensee's commitmec.ts
for additional Ad5 safety-related welcing.
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(6) Isseee .;a pa ,r 17.192* , c af *-=i cr see's C'-
a " es:s
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regarcirg tr. t ht i.7 :: W es c:*.:*ete c ei at:4::'es .
(7') Issuec fecc M li 1Sil, c.ance-P 7 s.tSttitu-ic . ef
certain ASW = ele.,t; i eat * f.: it t w A M sfit.*r*'ata:
welcing 10-wees wart r!a,.
,! (3) Issued rar:s 21. h !1. :: *l*.in; " censee's.c: 9't.e-ts
" ,
:
n;sreie.g further 1trae As*E sa'etv--elated wel:i n as
7
' cutlined in licensee's 12-week won 7:an.
-
:. ,
*
(9) Issued April IE.1951. c:a'irsing lice *see's c:.Mit. e*. s
..*e
~ g .' t
~ reg.rdtr.; expa Jing coc7 em cen:-ete wort. act'wities;
1
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.
*
.! 6. Panace-eat ceafereaces Weld Derfa- Accea'se* e*iod
-
M.w .d ~
~
h The felicwing were management sutings held da-tag the SALP
' lreportingperioc:
* . 1..
=
r ~; . a. At the recuest of the lice 9see, a sana;ecent eettieg was beid
*. on June 17, 1980, te discuss actions W eg cevelcpec regaecte;
W, .
;
.! Show Cause Crcer items.
~'.'.
.
.
d
At the request of the licensee, a'sa-a; m t' meeting was held
.
'
. .i
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b.
to discuss actions being taken regaading Show Cause Creer
itees related to Special Investigatien 75-19.
i
. .
a
. . .
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- c. Nove4 er 18, 198G, to discuss status of outstanding Sh = Cause
'
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Orcer itees and restart of work.
.
.:.
.
4" March 23. 15E1, to discuss restart t: A M welding and curre-t .
d. .
. ..-
status of Show cause Orcer commitments.
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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. ,
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OFFICE MEMORANDITH S _ L-10099 402
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SpH: C-0570
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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
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y:F.p . Ber. T. D. Stanley o ics;uinea4 move - N , g g,/ hat
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Augast 23, 1
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* ler. 8. A. Viaslove
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south Temas Project Electric Generattag Station
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.,p . commmmu nessedias NaC opinians
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(1) Morste: Disgriastled employees should be released if they ase '
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"dHIEIing yuebleme. Easpectisa perseemet mast eest la asser6= . l
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; esse with annasement smideniase er direesives. ,
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(2) lana punch-11sts's QA/QC sammet stap identifying these Frob. ,
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- leen. s4R C.anstruction should beef op their staff ae problems
saa be identified la a timely amener. ,
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(3) Preparation etter to inseeetions: 841 4A/QC has providad in. g
. nyecsers with sa area to use for plasming purposes. BS shoald .
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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. -!
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'(4) Staff 1ntt As noted above, quality has not been % . as
Eeuth Texas. *h that ML4P and SE add pereennel to A114=
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viste the sve durden. . ; ,,
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- In order to define det is exyIseted of 348 (WQC a asesing ens held ,
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I j en Angmet 23, 1978, d ish involved the attashed asserendial. This is a '
very positive stop. , ,
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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
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during their resses i _:<--**= et allegasisme. !
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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-
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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 *
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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 =
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neerlag. 84A Constructies, ets., uses sentribute their share se sabe thisl_g{l
job a enneese. l
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Brown &RootJnc. poet cAs s. m ae, o,, re.ee Am
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-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
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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
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sTr Project QA Manager ! ...
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J. N. Salvitti (
ect T. E. Canoe 8* A* T18e18'*k7-(31AF) / tl * . ' * .
5. Paperno _/
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. J. R. Meeree FI12: A010Q
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