ML19312D978

Responds to 800430 Show Cause Order.Matters Re Section III Answered in Reply to Notice of Violation.Mgt Is Committed to Become More Involved in Program & Make Qa/Qc Functions Highly Visible & Independent.Certificate of Svc Encl

ML19312D978
Person / Time
Site:	South Texas
Issue date:	05/23/1980
From:	Oprea G HOUSTON LIGHTING & POWER CO.
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8006030023
Download: ML19312D978 (6)

Text

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Houston L' ting r ~ - -

Company ggrhm Uh.u ikt (l0PD.

i Ekdnc Tmwr l ff RCt &n D00 j11l Houston. Texas 77001 May 23, 1980 l

Nuclear Regulatory Commission i Washington, D.C. 20555 Attention: Mr. Victor Stello, Jr.

Director Office of Inspection and Enforcement ]

Re: Docket Nos. 50-498 50-499 Gentlemen:

This answer is filed pursuant to Section VI of the

" Order to Show Cause" (April 30, 1980) in the subject dockets.

Applicants do not seek a hearing with respect to this matter.

Section VI of the " Order to Show Cause" states that any answer filed in response to the Order "shall admit or deny each allegation made in Section II and III" of the Order.

Section II essentially recounts the Nuclear Regula-tory Commissions' (NRC 's) Inspection and Enforcement (I&E) activity on the South Texas Project. To the extent we are aware of such activities we admit the facts as stated therein; however, there are certain matters peculiarly within the Commission's knowledge of which we are unaware and which we can neither affirm or deny (e.g. "On November 2, 1979, the RRI was contacted on site by a Brown and Root QC inspector who alleged that civil QC inspectors were being harassed and intimidated by Brown and Root construction personnel", p. 8).

It is our understanding that the allegations in Section III are, with one exception, based on the items of noncompliance specified in the " Notice of Violation" (April 30, 1980). Appli-cants hereby incorporate the text of their " Reply to Notice of Violation" (Reply) filed this date. It will be noted that each item of noncompliance is answered in the Reply with a clear 8006030gg3 l 1

Houston Ughting & Pbwer Company Nuclear Regulatory Commission

. May 23, 1980 Page affirmation or denial; accordingly, we regard the matters under-lying Section III as having been answered.

With respect to the one allegation that "two apparent false statements in the FSAR were identified regarding test and observation actually performed" the supporting information is not found in the Notice of Violation. This item will be addressed in the response to Section V, item 10 of the Order to Show Cause.

In response to the second paragraph on page 9, the substance of the allegation (with respect to certain incidents of harrassment and intimidation) is conceded in the response to the first item of noncompliance; we also note the extensive remedial actions which have been, and will be, implemented to prevent recurrence of these conditions. To the extent the para-graph suggests that STP may not be constructed to NRC standards, we do not believe that major nonconforming conditions exist, {

although the matter is under study pursuant to Section V of the j Order. We note, in particular, I & E's conclusion that "during j the investigation no items of major safety significance were i found whicb related to harassment or intimidation of QC personnel." 1 As indicated in the response to the Notice of Violation, manage-ment is committed to completion of a project conforming to NRC requirements, intends to be more involved in the program and will take steps to assure a "high visibility" for QA/QC functions.

In response to the third paragraph on page 9, clearly lack of detailed involvement by management was a contributor to the problems noted in the paragraph, but it is an overstatement to suggest that this was the only reason behind these problemc.

As discussed in the cover letter, the reasons for the items of noncompliance are complex, involving several " root causes." We do, believe, however, that to attack these " root causes" active involvement at the highest levels of B&R and HL&P management will be required.

In the paragraph beginning at the bottom of page 9 and continuing to page 10, the statement is made that " South Texas Project QA management does not fully recognize the requirement for QA/QC organizational freedom." As indicated in the cover letter transmitting our Reply to the Notice of Violation, management is sharply aware of the need for such

Houston Lighting & Pour Company Nuclear Regulatory Commission

, May 23, 1980 Page freedom and major steps have already been taken to assure this freedom and independence. The lecture referred to in the para-graph has been disavowed by B&R management. New lectures and seminars as well as written materials will emphasize the import-ance and status of the OA/QC function. (See also response to item 1 in the Reply to the Notice of Violation).

We believe that all other aspects of Section III are restatements of pertinent sections of the Notice of Violation which are fully answered in our Reply of this date. We note, however, that the matter of whether " serious questions" exist with backfill compaction (last paragraph, p. 10) must await completion and disposition of relevant studies mandated in Section V of the Order to Show Cause.

In accordance with the provisions of Section V of the Ordre to Show Cause, we will submit to the NRC within 90 days from the date of the Order the information requested in items A (1) -

(10). In addition, HL&P and Brown & Root representatives will participate with the NRC in a public meeting as described in Section V B. of the Order.

Very truly yours, HOUSTON LIGHTING & POWER COMPANY 9 'ir

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/ eorc4% W. Opryh,Jfr Executive Vice President cc: Attached Certificate of Service mb e

4 STATE OF TEXAS S S

COUNTY OF HARRIS S GEORGE W. OPREA, JR., being first duly sworn, deposes and says: That he is Executive Vice President of HOUSTON LIGHTING

& POWER COMPANY, an Applicant herein; that the foregoing answer to Order to Show cause dated April 30, 1980 has been prepared 1

under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said ,

l answer and the facts contained therein are true and correct.

DATED: ThisdQ34 day of M C?//

, 1980.

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I Signe : jewt , - u rgef . Opre g J Subscribed and sworn to befo're me thisg hi day of %, j ,

1980.

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. Notary Public in and for the County of Harris, State of Texas My commission expires:

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD IN THE MATTER OF S S

HOUSTON LIGHTING & POWER S DOCKET NOS. STN-498 OL COMPANY, ET AL. S STN-499 OL i l

S (South Texas Project S l Units 1 and 2) S l

CERTIFICATE OF SERVICE I hereby certify that copies of Applicant Houston Lighting

& Pcwer Company's Answer to Order to Show Cause in the above-cpationed proceeding, were served on the following by deposit in the United States mail, postage prepaid, or by hand delivery this 23rd day of May, 1980:

Charles Bechhoefer, Esq., Chairman  !

Atomic Safety and Licensing Board l U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. James C. Lamb, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Henry J. McGurren, Esq.

Hearing Attorney 4

Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Richard W. Lowerre, Esq.

Assistant Attorney General for the State of Texas P. O. Box 12548, Capitol Station

t. Austin, Texas 78711 m

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Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court House Bay City, Texas 77414 Mrs. Peggy Buchorn, Executive Director Citizens for Equitable Utilities Route 1, Box 432 Brazoria, Texas 77422 Steven A. Sinkin, Esq.

116 Villita San Antonio, Texas 78205 Atomic Safety and Licensing Board Panel ,

U. S. Nuclear Regulatory Commission l Washington, D.C. 20555 l

Atomic Safety and Licensing Appeal Board Panel U. S. Nuclear Regulatory Commission Washington, D.C. 20555 l

Mr. Chase R. Stephens Docketing and Service Section -

Office of the Secretary of the Commission U.S. Nuclear Regulator.y Commission Washington, D.C. 20555 l

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Melbert D.'Schwarz Dated: May 23, 1980 A

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